The Risk Management Program (RMP) rule is intended to minimize accidental releases of toxic and flammable substances by requiring owners of processes containing greater than a threshold quantity of a regulated substance to consider release hazards, conduct offsite consequence analyses, evaluate prevention programs and consider accidental release history. At each site subject to RMP, specific elements of the RMP are summarized in a Risk Management Plan (RMPlan), which is submitted to the EPA and becomes available for public review (subject to national security issues and data disclosure limitations).
Sage reviews RMPlan elements for accuracy and completeness, including the Registration Information, Hazard Assessment, Five-year Accident History, Prevention Program, and Emergency Response information. Sage conducts interviews on the recent refinery process unit history and review management of change (MOC) documentation, if necessary, to verify that there are no new processes or process changes that need to be addressed in this RMPlan update.
Sage documents applicability of the RMP for all on-site processes, including processes not included in the current plan. The documentation includes, as a minimum, a table listing the major vessels in each process as shown on unit P&IDs. The documentation indicates the concentration of each regulated substance or mixtures in stream, and maximum quantity of substance in the process and in the largest vessel. Sage checks with PSM management to determine if PSM Process Safety Information (PSI) has already developed this information before calculating quantities from P&ID review. The collected data can be used to determine and document the maximum quantity of each regulated substance(s) in the process to two significant digits per §68.160(a)(7) and determine program applicability.
For the Hazard Assessment evaluation, documentation regarding the threshold quantities of regulated substances is initially reviewed to assess if all required worst-case and alternative release scenarios were evaluated and properly selected for RMPlan reporting. Sage confirms that the appropriate number and type of alternative release scenarios are contained in the RMPlan, and will "spot check" each reported scenario to ensure correct parameters were used for the endpoint calculation.
Sage determines the Program 1 or 2/3 status of the process(es) for RMPlan reporting purposes by evaluating the worst-case release scenario of regulated flammable and/or toxic substances and presence of off-site public receptors within the end-point distance.
All Prevention Program Data Elements are assessed for completeness and then entered in either Section 7 or Section 8 of the RMP submission. Sage personnel may assist you in completing What-if Checklists or HAZOP analyses required to develop site-specific accident prevention program(s).
Do You Know
Sage offers on-site RMP Training. We can prepare a RMP training and compliance presentation specific to STRC, and conduct a 6-hour on-site training course for the facility personnel responsible for implementation of the 40 CFR 68 requirements. The presentation will be prepared as a PowerPoint Presentation slideshow to facilitate plenty of topic discussion.