A Good RMP Program

1. A Good RMP Program Mary Peyton Wall Bureau of Air Quality Air Toxics Section October 1, 2009

2. Introduction • History and applicability • Short overview of RMP program • Compliance inspections • Expectations for a good RMP program • Incident investigations

3. History & Applicability • Industrial disasters • Bhopal, India • Emergency Planning and Community Right-to-know Act (EPCRA) • Section 112(r) of the Clean Air Act (CAA) • Chlorine – RMP threshold is 2,500 lb • 2 or more one ton cylinders

4. Program Levels • Level 1 • Specific eligibility requirements • Level 2 • Level 3 • NAICS codes • OSHA Process Safety Management program

5. Risk Management Program • Three major elements: • Hazard Assessment • Prevention • Emergency Response • Key element is prevention of accidental air releases

6. Risk Management Program • Risk Management Program refers to all of the requirements in the regulation that are to be implemented at the facility • Risk Management Plan (RMP) refers to the document that summarizes the program, which must be submitted to the EPA

7. Hazard Assessment • Off-site consequence analysis • Worst-case release scenario • Alternative release scenario • Define off-site impacts • Population • Environment

8. Hazard Assessment • Update at least once every five years • Release scenarios and off-site population impacts

9. Prevention Program • Process safety information (PSI) • MSDS • Technology of process: block flow diagram, process chemistry, maximum intended inventory, safe upper/lower limits, consequences of deviations

10. Prevention Program • Process safety information (PSI) • Equipment in process: materials of construction, piping and instrument diagrams (P&IDs), electrical classification, relief system design, ventilation system design, material and energy balances, safety systems

11. Prevention Program • Process Hazard Analysis (PHA) • Determine and evaluate hazards of the process: what-if/checklist, HAZOP study • Hazards of process • ID any previous incident which had potential for catastrophic consequences • Engineering and administrative controls

12. Prevention Program • PHA, continued • Determine and evaluate hazards of the process: • Consequences of failure of engineering and administrative controls • Stationary source siting • Human factors • Evaluation of possible safety and health effects of failure of controls

13. Prevention Program • PHA, continued • Team with expertise in engineering and process operations • At least one person with experience and knowledge specific to process and one with experience in PHA methodology

14. Prevention Program • PHA, continued • Address team’s findings and recommendations; resolve in timely manner • Update and revalidate at least once every five years • Maintain all PHAs for life of process

15. Prevention Program • Operating procedures (OPs) • Develop and implement written OP • Identify safety and health considerations • Identify safety systems and functions • Review as often as necessary and certify annually that OPs are current and accurate

16. Prevention Program • Training • Overview of process and OPs • Refresher training at least every 3 years • Documentation: name of employee, date of training, verification of understanding • Train new employees ASAP

17. Emergency Response • Non-responders • Coordinate with local emergency responders • Responding Facilities • Written emergency response plan • Procedures for informing public and emergency response agencies

18. Emergency Response • Responding Facilities • Written emergency response plan • Proper first aid and emergency medical treatment • Procedures for emergency response • Equipment maintenance • Training for relevant employees

19. Points to Mention • RMPs must be resubmitted at least once every five years • 2009 resubmit • Electronic submittal (CDX) • No longer report quantities of chemicals in executive summary portion of submitted RMP • Executive summary is FOI-able

20. Expectations of a Good Program • Chemical Safety Alerts and other hazard warnings • http://www.epa.gov/emergencies/publications.htm#alerts • Implementing an RMP at your facility • Not just what a consultant gives you

21. Expectations of a Good Program • Effectiveness • Drills • Fire department • Community • Employee awareness • Switch PHA methods • What if/Checklist vs HAZOP

22. Expectations of a Good Program • Compliance Audits • Regulation requires at least once every 3 years • Perform more often • Use the regulation as a guide • Our inspection does not count as a compliance audit

23. Expectations of a Good Program • Facility siting • Account for other structures: offices, industries, schools, new construction (i.e., housing boom, shopping centers, etc.) • Consider additional receptors: roads/highways, school bus stops, community events

24. Expectations of a Good Program • Address near misses • Reasons why they happen • Prevention • Install secondary and tertiary controls/valves • Do not rely on one backup

25. Expectations of a Good Program • Operating procedures • Address all steps in the process • Write out “understood” processes • Who is responsible for each step, if necessary (i.e., contractor vs facility) • Avoid referencing other documents • Same formats for all procedures

26. Expectations of a Good Program • Become involved with your Local Emergency Planning Committee (LEPC) • http://yosemite.epa.gov/oswer/lepcdb.nsf/HomePage?openForm

27. Contacts • Angel Thompson – 803-898-4058 • Connie Turner – 803-898-0341 • Mary Peyton Wall – 803-898-4064 • Heinz Kaiser – 803-898-4089

28. Questions?