From: Cogliano, Gerain

Sent: Monday, February 22, 2016 3:42 PM

To: Jones, Danielle <Danielle_Y_Jones@omb.eop.gov>

Cc: Farber, Glenn <Farber.Glenn@epa.gov> Subject: EPA response to 2 more interagency comments on RMP NPRM

Hi Danielle,

Below please find EPA’s response to the following interagency comments:

Comment 1: reporting of methane and other GHG releases. To the extent allowed under Section 112(r)(7) of the Clean Air Act, DOE recommends requiring reporting and quantification of methane and other greenhouse gas emissions resulting from an accidental
release. Increased reporting of accidental releases would allow for improved quantification of climate

related damage s associated with hazardous release.”

Comment 2: climate resilience planning.
Climate

- related impacts

— such as more frequent and intense heat

- waves, rising sea levels, and more frequent and severe weather events

— pose increasing risks to energy infrastructu re. To the extent allowed under the Clean Air Act, DOE recommends that climate resilience planning be a required component of covered facilities’ risk management plans (RMPs) and process hazard analysis (PHA).”

EPA Response: These suggested comments are beyond the scope of this rulemaking.



## Gerain Cogliano

OLEM's Regulatory Steering Committee Representative

Policy and Regulatory Management Team Leader Policy Analysis and Regulatory Management Staff (PARMS) Office of Program Management (OPM) Office of L and and Emergency Management (OLEM)

EPA West Room 4130 Phone Number: 202

- 566

- 1929 Fax Number: 202

- 566

- 1934 Mail Code: 5103T cogliano.gerain@epa.gov

From: Jones, Danielle [ mailto:Danielle_Y_Jones@omb.eop.gov ]

Sent: Monday, February 22, 2016 10:44 AM

To: Cogliano, Gerain < Cogliano.Gerain@epa.gov > Subject: RMP Comments

Gerain,

Two more comments just came in.Overview:

This rule primarily addresses risk management and response for chemical releases and the purpose is to improve safety at facilities that use and distribute hazardous chemicals. Because methane is one of the

reg ulated substances (with a threshold quantity of 10,000 lbs.; Clean Air Action, Section 112(r)(7)), we recommend that the investigation and post

- release compliance audits should include reporting of methane and other greenhouse gas releases. Additionally, we recommend that the required process hazard analysis (PHA) include climate change resilience planning for facilities at risk of climate

- related impacts such as rising sea levels, higher temperatures, and more severe weather.

Comment 1: reporting of me thane and other GHG releases. To the extent allowed under Section 112(r)(7) of the Clean Air Act, DOE recommends requiring reporting and quantification of methane and other greenhouse gas emissions resulting from an accidental
release. Increased reporting of accidental releases would allow for improved quantification of climate

related damages associated with hazardous release.”

Comment 2: climate resilience planning.
Climate

- related impacts

— such as more frequent and intense heat

- waves, rising sea levels, and more frequent and severe weather events

— pose increasing risks to energy infrastructure. To the extent allowed under the Clean Air Act, DOE recommends that climate resilience planning be a required component of covered facilities’ risk management plan s (RMPs) and process hazard analysis (PHA).”

Danielle Y. Jones Policy Analyst Office of Management and Budget Phone: (202) 395

- 1741 | djones@omb.eop.gov