Review of the Existing Plans for Completeness and Accuracy
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. Sage recommends keep all Plan documentation in a single binder or folder.
Sage Environmentalpersonnel have extensive experience in audits of Risk Management Plans and their supporting information 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 foreach 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 Plans;
- 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 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 History; 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 an audit of the existing plan with reviewing the plan interviewing the on-site personnel. Our extensive experience with preparation of RMPlans allows us to identify fields potentially requiring most attention. Very often, RMPlan audits are completed using RMP Audit checklists developed by the EPA for their inspectors and auditors, which ensures that all required documentation has been identified and gathered in a single location or document if an external audit occurs.
An auditing process typically starts with a verification and determination of completeness of the background and supporting information regarding the number of processes and chemicals presented in each process. The next significant step in our analyses is typically a review of OCA for each process and the Five-year Accident History. Where appropriate, Sage may recommend using refined modeling in OCA.
A review of documentation the Accident History and PPDE typically requires significant efforts. Sage personnel reviews the information using checklists and questionnaires organized in easy-to-understand Excel spreadsheets.