While doing some “Pre-Start Up Review” work for a client, I was tasked with reviewing the Emergency Response aspect of the facility’s ability to respond to an NH3 incident. As part of this review I asked the question… Have we coordinated our emergency response needs with the LEPC and the local FD(s)? This is a NEW facility and it will NOT have on-site ER capabilities so planning/coordinating with the off-site entities is CRITICAL, especially since the facility is the largest in town and without a doubt the largest inventory of an EHS. So we are debating the timing on the Tier II submittals – I absolutely state they must be done before receiving the NH3, but EPA allows for a 3-month window to submit after receipt of the EHS over the 500-pound threshold for NH3. Sort of defeats the “emergency planning” concept of the “Emergency Planning and Community Right to Know Act (EPCRA) if we don’t tell the LEPC and FD we have 9,000 pounds of NH3 for 3 months – considering the fact that most releases occur when? START-UP! But we can debate this at another time. What I want to share with everyone is the amended RMP requirements regarding 68.93 Emergency response coordination activities. The amended requirements state: