Risk Management Program (RMP) provisions 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 RMP requirements apply to different types of RMP-regulated chemicals handled at the stationary source (i.e., toxic or flammable substances) and each of the three Program Levels established in the regulation. These two factors also define the number of Worst-case and Alternative Off-site Consequence Analyses (OCA) for all or selected representative Regulated Processes.
Sage Environmentalpersonnel have extensive experience in preparation 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 bereported foreachaccident.
- 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 related to RMP applicability determination included:
- Representation of the whole Stationary Source as a single RMP-regulated process.
- Significant underestimates or overestimates of the quantities of toxic and flammable substances in regulated processes; and
- Lack of or insufficient background documentation of all plan elements in a stand-alone 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.
Sage Environmental personnel completed dozensof RMPlan documentation and submission projects. References are available upon request.