Countdown to the RMP deadline

With only two months remaining until the June 21, 1999 deadline for submittal of risk management plans, required under Section 112(r) of the 1990 Clean Air Act Amendments (CAAA), affected facilities should be in the final stages of preparation. Before you conclude that your plan is complete, however, take a few minutes to consider whether you have addressed all the issues that could affect your facility.

Background
The Section 112(r) Risk Management Program (RMP) was promulgated in June 1996 with a three-dimensional purpose: 1) to inform the public about potential hazards associated with industrial facilities; 2) to develop a dialogue between those facilities that handle hazardous materials and the surrounding community; and 3) to ensure that the public is adequately protected from accidental releases to the atmosphere. Following the pattern of the Superfund Authorization and Recreation Act (SARA) Title III, Section 313 regulation, the U.S. Environmental Protection Agency (EPA) opted to fulfill these intentions by requiring public disclosure and holding owners and operators highly accountable.

The Risk Management Program uniquely combines hazard identification, quantitative risk assessment and emergency planning requirements (see Figure 1). Facilities that use toxic or flammable substances in quantities that exceed RMP thresholds are required to prepare and submit a risk management plan that includes these aforementioned elements, depending on the relevant Program level. The plan must be reviewed periodically and made available to the public. Because of this new level of public scrutiny, the development and implementation of risk communication programs that address the concerns of various stakeholders has become perhaps the most important result of the program.

To determine whether your facility is prepared for the approaching deadline, consider the following:

1. Is your facility subject to the RMP?
A list of the regulated substances, threshold values and exemptions is available on EPA's Web site at www.epa.gov/swercepp/rules/listrule.html. Remember, however, that even if your quantities are below the threshold values, the RMP "general duty clause" requires all facilities to protect the public from accidental releases to the atmosphere, regardless of the substance, amount stored on-site or any other restrictions. It is up to the owner or operator to be knowledgeable about potential risks and to control plant activities so that the public and the environment are protected from accidental releases.

2. Have you made an accurate Program level determination?
The applicable Program requirements for a particular process depends upon a number of factors (see Figure 2). The first step in achieving compliance is appropriate Program level determination. Equally important, a plant may be able to step down to a less rigorous Program level, or opt out of the Program completely by making operational changes.

3. Does your hazards assessment identify realistic and significant scenarios?
Emergency response plans are only effective when they are prepared for the accidents most likely to occur. As illustrated in Figure 3, refined dispersion modeling can be invaluable in predicting potential off-site impact, as compared to the simplified methods suggested in the EPA's Off-Site Consequence Analysis (OCA) guidelines. In the case of formaldehyde, for instance, sophisticated modeling approaches can make a difference between presenting no predicted off-site impact, versus potentially alarming results. Similar dramatic differences can be demonstrated for other cases.

Figure 3

Comparison of accidental release endpoints from a formaldehyde release calculated using various techniques

Description

Evaporation rate

Distance to 10 ppm*

Actual event

Unknown

200 ft

EPA's OCA Look-Up Tables
Simple Method - Urban

12,400 pounds/minute

19 miles

EPA's OCA Look-Up Tables
Simple method - Rural

12,400 pounds/minute

16 miles

EPA's OCA Look-Up Tables
Sophisticated method - Urban

297 pounds/minute

0.81 miles

EPA's OCA Look-Up Tables
Sophisticated method - Rural

297 pounds/minute

1.8 miles

ALOHA-CAMEO

Cannot handle formaldehyde

Refined model - Urban

2.66 pounds/minute

180 feet

Refined model - Rural

2.66 pounds/minute

416 feet

*parts per million

4. Is your prevention plan (OSHA PSM) current and complete?
The RMP Prevention Plan requirements are based on the Process Safety Management (PSM) program developed by the Occupational Health and Safety Administration (OSHA). Program 3 processes likely already have a PSM program in place; however, it is important to review your PSM program to ensure that it is accurate, up-to-date and complete, particularly in the areas of proper documentation and training.

5. Are all significant hazards controlled, regardless of the RMP requirements?
Perform a walk-through assessment to identify hidden problems. Remember that the general duty clause requires every facility that presents a significant risk to the public to control that risk, even if the facility is technically exempt from the RMP based on regulated substances and threshold quantities.

6. Is there consistency among the elements of your plan?
Identification of worst-case and most likely release scenarios, assessment of the related hazards and development of appropriate emergency response plans must be based on consistent data in order for the plan to be effective in case an accident occurs.

7. Will it work?
Don't wait until an accident occurs to determine the effectiveness of your plan. By conducting accidental release drills, both privately and in coordination with local emergency responders, you can identify and resolve potential shortcomings in your plan.

8. Have you established ongoing communication with the surrounding community, and are you prepared to communicate the risks and protective measures associated with your facility?
Evaluate your relationships with your neighbors and include an ongoing risk communication plan in your RMP strategy. Although risk management plans will not be published on the Internet, as EPA initially intended, they will be available for public review through local emergency response committees (LEPCs). Make sure that you understand the concerns of various stakeholder groups, and that you can defend reliable release prevention and emergency response information.

9. Are you informed about RMP submittal requirements?
EPA's December 1998 RMP*SubmitTM User Manual (www.epa.gov/swercepp/whatnew.html) provides instructions for submitting plans and completing each data element. Using EPA's free RMP*Submit program (www.epa.gov/ceppo/rmpsubmt.html) or related programs, facilities can also electronically submit their risk management plans.

While the Risk Management Program may represent yet another regulatory hoop to jump through, it is also an opportunity to tighten your control measures, perhaps preventing an accident that could have devastating effects for the community, as well as your company. It provides the impetus for improving community relations by allowing you to present a balanced, realistic picture of the risks associated with your plant.

This article originally appeared in the 04/01/1999 issue of Environmental Protection.

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