Prevention Program Documentation
Risk Management Program (RMP) provisions require an owner or operator of each stationary source subject to the 40 CFR 68 requirements to develop a Risk Management Plan in the standard format developed by U.S. Environmental Protection Agency (EPA). In addition, background and supporting documentation for each Plan is required to be developed for some Plan elements (e.g., Off-site Consequence Analyses assumptions and calculations are to be documented).
For other elements in Risk Management Plans the background and supporting information documentation is not directly required by the regulation but is necessary to support the Plan contents in case of external audits. Specific information regarding the PreventionProgram Data Elements (PPDE) for each RMPLevel 2 and/or Level 3 process is an example of such Plan elements. Sage recommends keep all Plan documentation in a single binder or folder.
Sage Environmentalpersonnel have extensive experience in preparation and auditing 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 Prevention Program documentation include 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.
- Significant underestimates or overestimates of the quantities of toxic and flammable substances in regulated processes, which results in improper program level determination;
- Representation of all processes as Program 3 processes at complex facilities, which cause an 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 istory; 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 documentation of the Prevention Program Data Elements for each Program 2 or Program 3 process with interviewing the on-site personnel. Easy-to-understand Excel spreadsheets are provide to complete the required data gathering, which then undergoes additional QA/QC review.
The information for each process is submitted to the EPA using Web-based RMP*eSubmit tool. Sage personnel enters the information or reviews the information entered by facility on-site personnel for completeness and accuracy.
Proper documentation the PPDE background and supporting information is an important part of proper Prevention Program documentation. Sage Environmental assists clients in the preparation of the information by providing checklists and questionnaires organized in easy-to-understand Excel spreadsheets. The documentation is then organized for storage in a single place or document.
Sage Environmental personnel completed dozensof RMPlan documentation and submission projects. References are available upon request.