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EPA RMP Program & EligibilityOn 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.
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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
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RMP Program Content
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Hazard Assessment
Prevention Program
Emergency Response
What can we do better?
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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.
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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
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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
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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.
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Operating Procedures
Operating procedures
must include consequences of
deviation and the steps to
avoid the consequences
of deviation.
• Review operating procedures annually• Make sure operating procedures are up to date
Each operator is to be trained on SOP’s,
understand and follow them at all times, and
suggest updates or improvements.
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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.
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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.
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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.
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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.
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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?
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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.
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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.
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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.
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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
Recommended