Hydrocarbon Processing | 7 September 2016
Prospective Costs of the EPA’s Proposed Risk Management Plan Chemical Accident Prevention Requirements
On 14 March 2016, the US Environmental Protection Agency (EPA) published proposed revisions to its Risk Management Plan (RMP) facility safety program in the US Federal Register. The proposed revisions include several changes to accidental-release prevention requirements, including:
- Third-party audits of an RMP program following an accident
- Considering inherently safer technology during hazard assessments
- Conducting root cause analysis of management failures in relation to an incident
- Taking actions to correct the root cause
- Sharing information with emergency planners and the public
The EPA describes these proposed revisions as improvements to lessons-learned processes. Facilities affected by the proposed rule include petroleum refineries, large chemical manufacturers, wastewater treatment systems, chemical and petroleum wholesalers and terminals, food manufacturers, packing plants, agricultural chemical distributors, and midstream gas plants. The EPA allowed businesses to comment on the proposed changes until 13 May 2016.
What is the RMP?
Designed to protect public health and the environment from chemical accidents, the RMP applies to all stationary sources with processes that contain more than a threshold quantity of a chemical or material listed as regulated substances under Section 112(r) of the Clean Air Act. The EPA’s RMP rules were designed to share many similarities with the Occupational Safety and Health Administration’s (OSHA’s) Process Safety Management (PSM) standards. The RMP and PSM have many of the same criteria, and the requirements, guidance, and interpretations of the two programs generally align.
Processes covered by the RMP fall within one of three prevention program levels based on their potential for offsite consequences, accident history, and regulation under OSHA’s PSM rule. The first level, Program 1, includes 642 facilities that must comply with limited accident-prevention requirements, including hazard assessment and emergency response requirements.
Program 1 includes:
- Processes that would not affect the public during a worst-case release and no accidents with offsite consequences in the last 5 years
- Small quantities of flammables and less volatile toxins
Program 3 applies to the vast majority of facilities subject to the RMP (10,615 facilities), and has the most stringent requirements. Facilities subject to Program 3 include processes subject to OSHA’s PSM rule or facilities within one of 10 specified North American Industry Classification System codes, such as refining, chemical manufacturing, and energy production.
Program 2 applies to 1,285 facilities and covers processes not eligible for Program 1 and not subject to Program 3. Program 2 facilities consist mainly of water and wastewater treatment in Federal OSHA states. Sources in all three programs must prepare and submit an RMP to the EPA at least once every five years.
Read the full story here.