Reed, Amy, Burns & McDonnell, Risk Management Plans: Common Deficiencies, 2015 MECC-KC
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A presentation at the 2015 Midwest Environmental Compliance Conference, May 13-14, 2015, Overland Park, KS
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Reed, Amy, Burns & McDonnell, Risk Management Plans: Common Deficiencies, 2015 MECC-KC
- 1. Risk Management Plans: Common Deficiencies Amy M. Reed, PE and Laura I. Brewer May 2015
- 2. 2 EPA RMP Program & Eligibility On June 20,1996, the EPA issued the Accidental Release Prevention Requirements or Risk Management Plan (RMP) into law. The purpose is to establish management systems for chemicals which have the potential to effect public health and the environment and to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. The RMP rule (40 CFR Part 68) applies to stationary sources (facilities) with processes that contain more that the threshold quantity of a regulated substance.
- 3. 3 RMP Program Levels Level 1 • No history of offsite accidents • No public receptors • Emergency response coordinated with local emergency organizations Level 2 • Not eligible for Program Level 1 or 3 Level 3 • Subject to OSHA PSM Wrong program level determination between Program 2 and 3 facilities in OSHA and non-OSHA delegated states
- 4. 4 RMP Program Content 4 Hazard Assessment Prevention Program Emergency Response What can we do better?
- 5. 5 Management System Roles ► Organizational chart does not address RMP elements. ► Failure to document individuals responsible for implementing each requirement of the risk management program. ► Failure to define the lines of authority through an organization chart.
- 6. 6 RMP Org Chart Example
- 7. 7 Hazard Assessment ► Incorrect Modeling Input for Worst Case & Alternative. • Incorrect use of passive mitigation • Rural versus Urban ► Alternative Scenario Evaluations (Look at more than one!) ► Missing Supporting Documentation. • Population data • Modeling output/calculations
- 8. 8 Process Safety Information # 1. MSDS 5. Documentation on codes & standards 2. Maximum Intended Inventory 3. Safe upper/lower limits 4. Block flow diagrams and P&IDs Check for Missing PSI Components
- 9. 9 Hazard Review/Process Hazard Analysis ► Revalidate at least every 5 years. ► At least every 3 times, EPA recommends completely redoing the PHA or Hazard Review versus a revalidation. ► Maintain the Hazard Review/PHA for the life of the process. ► Document response to action items. ► Ensure review includes external elements such as tornadoes, hurricanes, and/or earthquakes.
- 10. 1 0 Operating Procedures Each operator is to be trained on SOP’s, understand and follow them at all times, and suggest updates or improvements.
- 11. 1 1 Mechanical Integrity ► If preventative maintenance schedule does not follow manufacturer recommendations or design/codes/standards, document the explanation of why and how this conforms with good engineering practices. ► Historical inspection results should be reviewed to determine inspection frequencies or equipment replacement. ► Document of the results of the inspection should clearly identify if the equipment passed, failed, or requires corrective action. ► If equipment inspection shows a deficiency, document how process will be operated safely in interim until repaired.
- 12. 1 2 Contractor Safety (Program 3) ► No program in place or the program simply regurgitates the regulations. ► Communicate with contractor to make sure they are trained on your PSI, emergency response, and safe work practices associated the covered process. ► Audit the contractor while they are working onsite to ensure they are following safe practices.
- 13. 1 3 Training Requirements ► No description of training or testing methods. ► No documentation of initial or 3-year refresher training. ► Documentation of training on operating AND maintenance procedures should be maintained.
- 14. 1 4 Employee Participation (Program 3) ► Failure to develop a written plan of action for employee participation. ► Failure to consult with employees regarding training. ► Include in hazard reviews/PHA, O&M procedures.
- 15. 1 5 Management of Change (Program 3) ► Replacement in Kind versus Change ► Have affected personnel been informed and trained in the change? ► Do O&M procedures require an update because of the change? • Have personnel been trained? ► Is the PHA, OCA, or RMP applicability impacted by the change? • Was the hazard assessment updated? ► Does the PSI need to be updated as a result of the change? • Has a PSSR been performed?
- 16. 1 6 Compliance Audits ► Not completed every 3 years. ► Cannot locate the last two compliance audits. ► Incomplete resolution of the prior audit. Document who is responsible for responding to deficiencies, how deficiencies were resolved, and when deficiencies were resolved. ► Vague audits. Audit checklist needs to have more than “yes/no” answers, document evidence of compliance.
- 17. 1 7 Incident Investigations ► Must be initiated within 48 hours. ► Includes incidents which have or could reasonably have resulted in a catastrophic release. • If passive or mitigative safeguards prevented the release this could reasonably have resulted in a catastrophic release incident and requires an incident investigation • If incident is listed as an alternative release scenario, consider conducting an incident investigation. ► Must review findings with affected personnel and contractors whose jobs tasks are relevant to the finding or recommendation.
- 18. 1 8 Emergency Response ► Responding versus non-responding facilities. • Non-responding facility develops an emergency action plan which addresses: “Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel”, or “Response to releases of hazardous substances where there is no potential safety or health hazard” and relies on Local, County, or State Emergency response crews for all other response. Exempt from HAZWOPER training. Steps to notify emergency responders there is a need for response, and Emergency evacuation procedures.
- 19. 1 9 Updating, Correcting, or Resubmitting the RMP Within 6 Months Every 5 Years Requires revised PHA/Hazard Review Requires revised OCA Alters the program level of covered process. Update and Resubmittal required EPA Central Data Exchange requires certifier to maintain login and password; Stringent protocols used to protect CDX account Accidental Release Within 1 Months Change in Facility Emergency Contact No longer subject to progam
- 20. 2 0 Questions
Editor's Notes
- Differences between OSHA and EPA threshold determinations may make determinations confusing. Chlorine threshold for EPA RMP is 2500 lb while OSHA is 1500 lbs or Aqueous Ammonia applies only if greater than 44wt% and 15000 lbs for OSHA or 20wt% and 20,000 lbs for EPA RMP. Program levels apply to individual processes, so a facility with multiple covered chemicals may be covered under varying levels At no time can a process that is interconnected be divided, the whole process is covered unless they are defined as two separate processes which will not interact New public receptor construction may trigger a program 1 to move to program 2 or 3 levels. A facility must submit and comply with the program level change within 6 months.
- Worst Case Release Analysis and 5 year history needed for all levels, but alternative case analysis is only for level 2 and 3. Hazard assessment and hazard analysis are not the same thing Goal is to prevent accidental releases of substances that cause harm to the public and environment through a MANAGEMENT SYSTEM which develops a strategy to define the specific risks, Manage activities (training, maintenance, operations, planning, etc.), and comply with reporting/documentation/communication. There is no one “right” way to develop and implement a program.
- Designate a qualified person or position with overall responsibility RMP is a management system, each role will have certain assigned responsibilities for individual requirements of the RMP There should be a commitment for facility management and the approach to managing the risks which should be implemented on an ongoing, and daily way of operation.
- There are different methods to determine offsite consequences. No one method is defined. General methods (EPA guidance) will most likely overestimate distance to endpoints. More complex models can be used but are typically more costly to provide a less conservative method. Rural vs. urban sites. The regulations require you to take account of whether your site is rural or urban. To decide whether the site is rural or urban, the rule offers the following: “Urban means that there are many obstacles in the immediate area; obstacles include buildings or trees. Rural means that there are no buildings in the immediate area and the terrain is generally flat or unobstructed.” Some areas outside of cities may still be considered urban if they are forested. The distinction between urban and rural sites is important because the atmosphere at urban sites is generally more turbulent than at rural sites, causing more rapid dilution of the cloud as it travels downwind. Therefore, for ground-level releases, predicted distances to toxic endpoints are always smaller at urban sites than at rural sites. Alternative scenarios should reach an endpoint offsite unless no such scenario exists.
- The intent of Consequences of Deviation and Steps to avoid: purpose is to define what is normal and what constitutes upset operation. The procedure needs to identify operating parameters and contain operating instructions about pressure limits, temperature ranges, what to do when an upset condition occurs, what alarms and instruments are pertinent if an upset condition occurs, and other subjects. Operating procedures are important to training. Consequences of deviation and steps to avoid provide key information which needs to be conveyed to the personnel. For example, mechanical changes to the process made by the maintenance department (like changing a valve from one manufacturer to another or other subtle changes) need to be evaluated to determine if operating procedures and practices also need to be changed. All management of change actions must be coordinated and integrated with current operating procedures and operating personnel must be oriented to the changes in procedures before the change is made. When the process is shutdown in order to make a change, then the operating procedures must be updated before startup of the process. Training in how to handle upset conditions must be accomplished as well as what operating personnel are to do in emergencies such as when a pump seal fails or a pipeline ruptures. Communication between operating personnel and workers performing work within the process area, such as non-routine tasks, also must be maintained. The hazards of the tasks are to be conveyed to operating personnel in accordance with established procedures and to those performing the actual tasks. When the work is completed, operating personnel should be informed to provide closure on the job.
- There are clearly contractor and owner responsibilities for this standard. Owner must check contractor safety performance, ensure they follow facility safe work practices, and act responsibly while on site. Owners must train contractors on the process safety information, emergency response activities, and safe work practices. Contractor must ensure their employees are trained, know the process hazards and applicable emergency actions, follow all safe work practices, and maintain documentation of training. Contractors must notify the owner of any unique hazards or hazards which occur on the work site. They must report any injury or illness which occurs at the facility.
- Operators must be CERTIFIED in writing that they are competent to operate the process – at least every three years. Documentation must include that the operator has received and understood the training. Training must include process safety information, specific safety and health hazards, emergency operations, operating procedures, Maintenance personnel must be trained on the same information a contractor is trained on = process safety information, emergency response activities, and safe work practices. Maintenance must be trained on procedures applicable to performing their job safely, and maintenance procedures to maintain the ongoing integrity of the process equipment.
- Replacement in kind is any process or equipment change performed in accordance with established design specifications. A "replacement in kind" does not require enactment of the Management of Change Procedure. Examples include: "Like for like" equipment replacement such as the replacement of piping that is the same size and material with the same routing as the piping being replaced; Replacement of pressure relief valves as part of the five year replacement interval (provided identical relief valves are used); Replacement of instrumentation with instrumentation that has the same specification and ranges; and Changes that do not require a change to the facility's process safety information such as if the design, materials of construction and parameters for flow, pressure and temperature satisfy the design specifications of the device replaced