This week EPA put out a news release regarding an RMP inspection at an Ethanol plant in CO. But this news release had something in it that I had never seen before in the hundreds of RMP news releases I have read since 1999. The news release contained a breakdown of the demographics within the WCS for the facility. So this led me to wondering… why does this matter and is EPA now using demographics to choose facilities to inspect?
The news release stated…
“This enforcement action will benefit the community, which includes minority and low-income areas. Minority populations comprise nearly half of the residents within a five-mile radius of the facility and 45 percent are below poverty level. Approximately 35 percent of the area’s population is Hispanic.”
Someone in the government took the time to look up this data, but the big questions remain unanswered:
- did EPA know this data when it decided this facility would be inspected?
- did EPA base their inspection priorities on the demographics surrounding the facility?
- what difference does demographics have to play in complying with RMP?
Is this a political move in this year of an election? Just seems very odd to me that EPA would even spend the time with demographics and why they would put them in a news release.
I am just thinking out loud here, but I would be willing to bet a years pay that the vast majority of RMP facilities are in low income neighborhoods and that these neighborhoods have a high number of families living below the poverty level, regardless of race or nationality. About 95% of my time is spent in PSM/RMP facilities and I have yet to drive through a gated Country Club Community to reach any of the plants I travel to!!!!
So what is EPA trying to say with their change in their news release format? Are they making RMP compliance a political tool? In contrast to another RMP Inspection news release yesterday regarding three Water Treatment Plants being cited, there is no mention about the demographics these treatment plants could impact. Now I do not know this for a fact, but my vast experience working in water treatment plants does tell me that these plants CAN BE IN CLOSE proximity to nice neighborhoods. In fact, many of the treatment plants built in the more affluent areas have better landscaping that any of us could afford so that it “blends into the neighborhood”. These treatment plants have a much smaller footprint than an ethanol plant so they are easier to put in communities, but ironically, MOST OF THEM will have a larger impact than the ethanol plant’s 5 mile radius; yet no mention of their impact or the demographics!!!
This is troubling and I certainly hope that EPA is not making RMP a political issue in this election year. They should at least be consistent and list the WCS radius and dempgraphics in all of their news releases regarding RMP compliance.
Am I paranoid here or has anyone else seen this?
Here are the News Release that I am referring to.
Three Utah facilities to pay penalties for Risk Management Program violations
Colorado ethanol plant to pay $5,850 penalty for Risk Management Program violations
And officially, EPA states these as their selection criteria:
The implementing agency will, according to the regulations at 40 CFR §68.220(b), select stationary sources for audits based on any of the following criteria:
- accident history of the stationary source;
- accident history of other stationary sources in the same industry;
- quantity of regulated substances present at the stationary source;
- location of the stationary source and its proximity to the public and environmental receptors;
- the presence of specific regulated substances;
- the hazards identified in the RMP; and
- a plan providing for neutral, random oversight.