Risk Management Plans (RMP)
The Clean Air Act (CAA) Section 112(r) (Emergency Management) provisions codified in Title 40 Code of Federal Regulations Part 68 (40 CFR 68, Chemical Accident Prevention Provisions), a.k.a. Risk Management Program or RMP, require "an owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process" to develop and maintain a system of measures to prevent accidental releases of the regulated substances and to mitigate consequences of such releases if anaccident occurs. Different requirements apply to each of the three Program Levels established in the regulation.
A Risk Management Plan (RMPlan) is to be developed for each stationary source subject to the 40 CFR 68 requirements, which codifies the following RMP elements:
- General Information and Emergency Contacts for the stationary source;
- List of all Regulated Processes and the Program Level for each process;
- Worst-case and Alternative Off-site Consequence Analyses (OCA) for all or selected representative Regulated Processes;
- Five-year Accident Historyproviding the basic information for each applicable accidental release;
- Specific information regarding the PreventionProgram Data Elements for each Program Level 2 and/or Program Level 3 process; and
- A summaryof the Emergency Response Program.
Sage Environmentalpersonnel have extensive experience in preparation and audits of Risk Management Plans for stationary sources containing from one to dozens of PRM-regulated processes.
The RMP regulation is necessarily complex and often confusing. The areas that require most time duringthe preparation of a Risk Management Plan include:
- Identification of all RMP-regulated processes and estimation of the maximum quantity of each regulated toxic and/or flammable substance in each process and in the largest vessel of each process;
- Development and proper documentation of the worst-case and alternative OCA's for the minimalrequired number of scenarios for toxic and/or flammable substances;
- A review of all accidents that occurred at the stationary source in the five years preceding the Plan preparation; selecting the reportable accidents; and codifying the information required to be reported for each accident.
- Codifying the Prevention Program Data Elements for each Program 2 and/or Program 3 process.
Sage personnel identified errors and/or areas of improvement in approximately 80% of Risk Management Plans prepared by facility personnel or other consultants. Typical items that require improvement included:
- Representation of the whole Stationary Source as a single RMP-regulated process.
- Missing the regulatory deadlines for timely updates and submission of the Risk Management
- Significant underestimates or overestimates of the quantities of toxic and flammable substances in regulated processes;
- Representation of all processes as Program 3 processes at complex facilities, which results in unnecessary and potentially dangerous increase in environmental liability;
- Improper, insufficient, or over-extended Off-site Consequence Analyses;
- Untimely re-classification of Program 1 and Program 3 processes based on the Accident History; and
- Lack of or insufficient background documentation of all plan elements in a stand-alon document.
For a complex Stationary Source that potentially contains multiple RMP-regulated processes (e.g., a petroleum refinery), Sage typically starts the preparation of a new plan or a review of the existing plan with interviewing the on-site personnel. Our extensive experience with preparation of RMPlans allows us to identify fields potentially requiring most attention. Process Flow Diagrams, P&IDs, and other information gathered at the facilityare reviewed and processedas necessaryto complete the following goals:
- establish process boundaries within the stationary Source;
- create a list of all significant process vessels, including vessel volumes;
- document regulated substances, including flammable mixtures, in each vessel;
- document applicable material component concentration ranges;
- document theoperating parameters (e.g., the maximum controlled liquid level, temperature, and pressure);
- calculate the maximum quantity of each RMP-regulated substance in each process, taking into account the weight of each substance in pipes.
The next significant step in our analyses is typically the completion of OCA for each process. Program 1 and Program 3 processes are separated using the information above and analyses of the Five-year Accident History. The minimal required number of worst-case and alternative release scenarios proceeds to submittal and the rest are documented. A simplified RMP*Comp software developed by U.S. EPA is most often used by plan preparers to estimate the end-point distances. Sometimes, refined modeling using more sophisticated programs may benefit the Stationary Source. If such occasion is identified, Sage Environmental completes refined modeling upon consultation with the client.
Documentation the Accident History and PPDE typically requires significant inputs from the client's on-site personnel. Sage Environmental assists clients in the preparation of the information by providing checklists and questionnaires organized in easy-to-understand Excel spreadsheets. We then process the information and transfer it into RMP*Submit software, completing a parallel QA/QC process.
Sage Environmental personnel completed dozens of RM Plan documentation and submission projects. References are available upon request.