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Florida Accidental Release Prevention and Risk Management Planning (ARP/RMP) Act

Department of Community Affairs, Division of Emergency Management. Preparing for Facility Risk Management Plan Audits. Florida Accidental Release Prevention and Risk Management Planning (ARP/RMP) Act. State Emergency Response Commission. Background Information.

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Florida Accidental Release Prevention and Risk Management Planning (ARP/RMP) Act

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  1. Department of Community Affairs, Division of Emergency Management Preparing for Facility Risk Management Plan Audits Florida Accidental Release Prevention and Risk Management Planning (ARP/RMP) Act State Emergency Response Commission

  2. Background Information • 1998 - Florida DCA received delegation to implement Section 112(r) & Risk Management Program regulations. • Florida’s RMP Program fits well with DCA’s existing emergency planning and response programs (Division of Emergency Management & EPCRA Program). • Florida State Emergency Response Commission - SERC Involvement. • Program’s Philosophy - Emphasizes technical assistance to facilities to achieve compliance with RMP requirements to reduce occurrence of chemical accidents.

  3. Purpose of Section 112(r) and the Risk Management Program Requirements • To reduce & prevent accidental chemical releases. • To reduce the severity & minimize the consequences of chemical releases. • To improve coordination & communication between regulated facilities & local emergency preparedness & response agencies to improve emergency response.

  4. Facilities Typically Regulated Under RMP: • Drinking water treatment plants • Wastewater treatment plants • Food and cold storage facilities • Ammonia retailers • Chlorine repackagers and distributors • Chemical manufacturers • Utilities • Petrochemical facilities • Pulp mills • Fertilizer producers • Swimming pool service/supply businesses • Military, energy installations (mostly federal facilities)

  5. Program Level Screening for Regulated Processes • Regulated processes assigned to one of three program levels, based on: G Potential for off-site consequences G Accident history G OSHA Process Safety Management (PSM) G Within certain Standard Industrial Classification (SIC) Codes identified as having significant accident history. < Program 1 - no offsite impacts < Program 2 - streamlined prevention program (7 components) < Program 3 - full RMP program (12 components)

  6. Program Level 1 Process: • No offsite accident history in previous 5 years. • No offsite consequences associated with WCR. No public receptors located w/in distance to toxic or flammable endpoints. • Emergency response procedures between facility & local response agencies. * Mostly remotely located facilities or processes using listed flammables.

  7. Program Level 3 Processes: • Public receptors w/in distance to toxic or flammable endpoints. • Accident history • Not eligible for Program 1 AND • Process subject to OSHA PSM Standard (29 CFR 1910.119) OR • Process is in SIC Code with significant accident history

  8. Program Level 2 Processes: • Public receptors w/in distance to toxic or flammable endpoints. • Accident history. • Not eligible for Program 1 or 3 ‚ Florida Facilities - Majority of processes are Program 2 or Program 3 processes.

  9. Overview of Risk Management Program Requirements • If facilities use, store, manufacture, or process substances on the Section 112(r) list above TQ, must develop and implement a Risk Management Program. • Section 112(r) Listed Chemicals - 77 Toxic Substances & 63 Flammable Substances. • Most Common in Florida - Ammonia, Chlorine, Sulfur Dioxide, Hydrochloric Acid, Hydrofluoric acid, & Nitric acid. • Requirements & Complexity vary based on Program Levelof Process.

  10. Major Elements of a Risk Management Program: S Hazard Assessment ‚ Off-Site Consequence Analysis G Worst-Case Release Scenario - All G Alternative Release Scenario - Programs 2 & 3 ‚ 5-Year Accident History - All S Document Management Program - Programs 2 & 3 S Prevention Program - Programs 2 (streamlined version) & 3 (comprehensive) S An Emergency Response Program - Programs 2 & 3 (Note: Program 1 requires coordination with local response agencies)

  11. Overview of RMP requirements, cont... • Risk Management Plan (RMP) - Summary of facility’s Risk Management Program must be submitted to the EPA’s National RMP Reporting Center. • The RMP contains: S Facility Registration S Hazard Assessment S Prevention Program S Emergency Response Program S Executive Summary S Certification

  12. Prevention Program (Program Level 2) • Specific Requirements for Program 2 & Program 3 comprehensive. Reference handouts & audit checklists. • Required Prevention Program Components: G Safety information G Hazard review G Operating Procedures G Training G Maintenance G Compliance audits G Incident investigations

  13. Prevention Program (Program Level 3) Required Prevention Program Components: G Process Safety Information G Process Hazards Analysis G Operating Procedures G Training G Mechanical Integrity G Management of Change G Pre-Startup Review G Compliance Audits G Incident Investigation G Employee Participation G Hot Work Permit G Contractor Program

  14. Emergency Response Program Requirements: • Facilities with Program 1 processes must coordinate with local emergency response agencies. • Facilities with Program 2 or Program 3 processes must coordinate with local emergency responders if employees not required to respond to chemical releases at facility. • Must also have appropriate mechanisms in place to notify emergency responders.

  15. Emergency Response Program Requirements, cont... For Program 2 or 3 Facilities that will respond to chemical releases. • Written ER program is developed & maintained onsite. • Procedures/actions to be taken in event of chemical release. • Procedures for notifying the public & local responders for releases. • Information on first aid & medical treatment. • Procedures for use of ER equipment & inspection, testing & maintenance. • ERP Coordination with local responders. • Training for employees.

  16. Preparing for Facility RMP Audits < Audit Selection Criteria < Overview of DCA’s RMP Audit Process < On-Site Audit Findings < Available Technical Resources

  17. Audit Selection Criteria • Previous and current accident history of facility • Overall accident history of other facilities in same industry • Facility location & proximity to population centers • Chemical characteristics & quantities of RMP-regulated chemicals on-site • Compliance with or inspection by allied agency programs • Results of compliance audits • Neutral, random oversight • Other factors deemed necessary by DCA to protect public safety & health.

  18. Overview of the DCA’s RMP Audit Process • Off-Site Audit Activities - Basic “Desk Audit” S Initial Phase of DCA’s RMP audit process. S Focuses on the data contained in RMP summary. S Compliance with plan requirements. S Use “Desk Audit” Checklist. S Determination of the following: ‚ Whether rule applies to facility ‚ Appropriate program level ‚ Completeness & adequacy of data submitted in RMP ‚ Review for completeness, accuracy, dates, & scenario data.

  19. RMP Audit Process (cont...) Second Phase of Desk Audit - Documentation Review • Send audit notification letter requesting RMP supporting documentation. • Request for PHA, training records, incident investigation reports, ERP, compliance audit reports. • Use “Documentation Review / On-Site” Audit Checklist. • Review of supporting documentation. • This approach reduces time on site. Helps determine focus of audit visit. • Schedule date(s) for on-site audit. Send notification of on-site audit.

  20. RMP Audit Process (cont...) • On-site audit activities - Focus on overall Risk Management Program S Plant Tour of facility’s process chemicals & operations. S Interview facility representatives. S Review of facility operations, procedures, supporting RMP documentation, etc. S Adequacy & completeness of RMP documentation. S Development & implementation of required RMP elements. S Emergency Response - Coordination with local response agencies. S Document findings - “On-Site” Audit Checklist.

  21. What Can You Do to Prepare for an RMP Audit? • Review DCA’s Audit Checklists. • Obtain & organize RMP supporting documentation prior to scheduled audit date. • Include SOPs, hazard assessments, PHA & process safety information, training records, maintenance logs, MOC forms, ER procedures, etc.). • Determine appropriate facility personnel to include in audit. • Most of all ... Don’t Worry! Our primary goal is compliance assistance !

  22. What Should You Expect During an On-Site Audit? • RMP Audit Team - Usually 2 persons • LEPC Staff Contact invited to accompany team. • Audit agenda & assignments faxed prior to visit date. • Opening meeting (audit purpose/objectives, agenda, safety issues, etc.) • Tour of facility’s regulated chemicals and processes. • Review RMP supporting documentation. • Interview facility representatives. • Exit briefing (findings, identified deficiencies, recommendations, schedule for audit report, schedule for corrections, copy of audit checklist).

  23. What Should You Expect After an On-Site Audit? • DCA issues Preliminary Determination Report S Includes audit team’s observations, findings, recommendations. S Identifies deficiencies to be corrected S Identifies necessary revisions to RMP S Includes timetable(s) for correcting deficiencies and/or revising RMP

  24. What Should You Expect After an On-Site Audit? (cont...) • Facility Response to Audit Report S Must be received within approved timetable(s) S Usually allow 60 - 90 days for corrections & revisions. S Written request for extension prior to deadline date, if needed. S Upon receipt & review of requested information, DCA issues: ‚ Final Determination Report - If information correct & complete. ‚ Interim Audit Report - If additional information is necessary.

  25. General On-Site Audit Findings: (Note: Based on 30 on-site RMP audits) • WTPs & WWTPs • Ammonia refrigeration • Chlorine & Other Chemical Repackagers • Inadequate documentation, development, and/or implementation of 1 or more prevention program components. • “Bookshelf” & Generic Programs. Good program, but not implemented. • Many facilities complying with technical aspects of program, but documentation incomplete.

  26. Specific On-Site Audit Findings: • Hazard Assessments - Not available onsite; Incorrect modeling parameters. • Incorrect program level status S Program Level 1 - Public receptors were identified within endpoint distances. S Program Level 2 - Refrigeration facilities subject to OSHA’s PSM. • Most deficiencies to date pertained to: S Mechanical Integrity S Operating Procedures S Training Program S PHA

  27. Specific On-Site Audit Findings: • Mechanical Integrity - PM protocols not developed or implemented. Inspection and testing not performed. Minimal record keeping. • Operating Procedures - Operating phases, limits not addressed. Mostly emergency shutdown & assignments. • Training Program - Operator & Maintenance training incomplete. Documentation. • PHA - incomplete hazard ID (such as hurricanes, overpressurization, equipment failure, human error, etc.)

  28. Other On-Site Audit Findings: • Management of Change & Pre-Startup Safety reviews - not performed. • Contractor Safety Program - Non-existent. Not implemented • Emergency Response Program - Not coordinated with local responders. Procedures for ER equipment use & inspections not documented. Inadequate training.

  29. Other Related Regulations: • OSHA Process Safety Management - Program Level 3 processes • SARA Title III / EPCRA - Tier Two reports • Section 304 requirements - Accident Notification S Notify State Warning Point within 15 minutes of release S 1-800-320-0519

  30. Available Technical Assistance and Resources: •Contact DCA’s Risk Management Planning Program staff at: S (850) 413-9970 S (800) 635-7179 (Florida only) • Florida’s RMP Program web page for state & federal requirements, audit checklists, step-by-step guidelines. www.dca.state.fl.us/cps/arprmp/start.htm • Guidance documents, model RMP plans, other RMP resources also available from EPA www.epa.gov/ceppo

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