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 climaterelated 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 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 Land 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 

regulated 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 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 climaterelated 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 plans (RMPs) and process hazard analysis (PHA).”

Danielle Y. Jones

Policy Analyst

Office of Management and Budget

Phone: (202) 395-1741 | djones@omb.eop.gov