Yesterday at the Region 7 Ammonia Safety Day hosted by Garden City Ammonia Program in Kansas City, KS a questioned was posed to EPA. “How much time is allotted for a updated RMP filing when a plant has an expansion that would change the PHA?”
First it was a great question, second there are also other things beside a significant change to a PHA that would require an update to your filed RMP. Some people are under the impression that they just update every five years. Most plants will have to update before the five year anniversary date. Here is snap shot from GCAP’s PSM book. Look for a story of the Safety Day coming soon.
