Topic: RMP 2018: The Reconsideration
On May 17, 2018, EPA Administrator Pruitt signed a proposed rule that would rescind all of the accident prevention program provisions that EPA had added to its Risk Management Plan (“RMP”) rules in the final days of the Obama administration. The proposal also seeks to make a number of changes to the information sharing and local government coordination aspects of the 2017 RMP amendments – though certain of those new 2017 requirements would remain in place.
Join us for a discussion of how EPA has proposed to change the RMP rule and the potential implications for the regulated community. We will also discuss the status of the court cases challenging both the Obama administration’s 2017 RMP amendments and the more-recent Trump administration rule that delayed the effective date of those amendments.
Whit Swift, Partner, Bracewell, LLP
Whit Swift is a Partner in the Austin office for Bracewell, LLP and a member of the firm’s Environmental Strategies Group. He advises industrial companies on air quality matters, such as state and federal new source review permitting and Title V operating permit matters. In connection with that permitting work, he has represented applicants in contested permit matters before the Texas Commission on Environmental Quality (TCEQ) and the Texas State Office of Administrative Hearings (SOAH).
In addition to permitting work, Whit assists major manufacturing, energy, chemical and petrochemical companies with compliance issues related to the Clean Air Act (CAA). His CAA compliance work includes both compliance counseling and enforcement defense work under state and federal programs, including the federal Risk Management Plan (RMP) program, federal regulatory requirements governing sources of hazardous air pollutants (National Emissions Standards for Hazardous Air Pollutants (NESHAP), release reporting, and State Implementation Plan (SIP) rules regulating point sources.
Kevin Collins, Partner, Bracewell, LLP
Kevin Collins is a Partner in the Austin office for Bracewell, LLP and a member of the firm’s Environmental Strategies Group. Kevin is a former Assistant U.S. Attorney from the Eastern District of Texas, and he can help you manage the problems that arise during government investigations. His goal is to help you avoid significant penalties or uncertain litigation by negotiating a favorable outcome. But he has the trial experience to stand firm against the government when it demands too much or oversteps its lawful authority.
Kevin has focused on process safety since he assisted the Baker Panel investigate and issue its report on safety culture and corporate oversight of BP’s North American refineries in 2005. This focus results in four main areas of assistance to you: (1) responding to government investigations after industrial accidents; (2) representing you during OSHA (process safety management standard) and EPA (RMP) enforcement proceedings; (3) improving safety culture in refineries and chemical plants; and (4) preparing for industrial accidents by helping you to develop useful business-continuity plans, legal resource handbooks, release-reporting guides, and meaningful tabletop exercises and emergency field drills.
Kevin’s combination of process safety experience, trial experience, and technical understanding will help you solve your problems. He is a member of the AIChE, speaks often on the criminalization of process safety, and is an adjunct faculty member of The University of Texas at Austin.
|POWER Engineers, Inc. (formerly Zephyr)
2600 Via Fortuna, Suite 450
Austin, TX 78746
5:30 – 6:00 p.m. – Reception and Meal
6:00 – 6:05 p.m. – Central Texas Chapter Business
6:05 – 7:00 p.m. – Presentation
A&WMA International Members and Students – No Charge
A&WMA Local Associates – $10* Local Associates should plan to renew for 2018 ($40 Local Associate fee, plus $10 meeting fee) at their first meeting of the year.
Guests (Non-Students): $20*
*We accept credit card payments as well as cash and check.
RSVP: Please reply via email to me at Steve.Katz@aecom.com to RSVP on or before Noon, August 21.