Wed Oct 28, 1998 12:07:10 PM Avagene Moore:Welcome to the EIIP Technology Arena! ... Wed Oct 28, 1998 12:07:22 PM Avagene Moore:We are here today today to talk about Risk Management Plans (RMP) and the deadline for compliance with the EPA RMP Rule. ... Wed Oct 28, 1998 12:07:29 PM jefflorrain:Full java. Wed Oct 28, 1998 12:07:30 PM Avagene Moore:Our special guests today are Jeff Lorrain and Kelly Carmichael, Law Engineering and Environmental Services, Inc. ... Wed Oct 28, 1998 12:07:43 PM Avagene Moore:Jeff Lorrain is a Senior Scientist in the Environmental, Health and Safety Department at LAWGIBB?s National Technical Center in Atlanta. ... Wed Oct 28, 1998 12:07:56 PM Avagene Moore:and we hope he can maintain his connection ... Wed Oct 28, 1998 12:08:31 PM Avagene Moore:Jeff has over 19 years experience .... Wed Oct 28, 1998 12:08:44 PM Avagene Moore:providing environmental consulting services to industrial, commercial and governmental clients on a broad range of issues. ... Wed Oct 28, 1998 12:09:01 PM Avagene Moore:Through working with many regulatory agencies, Jeff has a solid working knowledge of RCRA, CWA, CAA, EPCRA, TSCA, FIFRA, NEPA and their application to industrial and commercial facilities. ... Wed Oct 28, 1998 12:09:15 PM Avagene Moore:Kelly Carmichael is with the Chicago Branch of LAW; his current responsibilities at LAW include air quality related projects in the iron and steel industry. ... Wed Oct 28, 1998 12:09:29 PM Avagene Moore:Thank you for joining us today, Jeff and Kelly. My questions will be to Jeff; once we have completed the formal part of our session, we will open the floor to Q&A with the audience. Prior to the Q&A, we will give brief instructions for keeping order in the Tech Arena. ... Wed Oct 28, 1998 12:09:44 PM Avagene Moore:One other point for first- timers in the Virtual Forum: URLs on the screen are live links. Click on the link and you can view the slides, graphics, etc. in your browser window to demonstrate the discussion today. ... Wed Oct 28, 1998 12:09:55 PM Avagene Moore:My first question, Jeff -- - Please give us a very brief history of the RMP --- what is the purpose? Wed Oct 28, 1998 12:10:31 PM jefflorrain:The Accidental Release Prevention Rule or RMP is part of the Clean Air Act Ammendments of 1990 [Section 112(r)]... Wed Oct 28, 1998 12:10:48 PM jefflorrain: The purpose of the regulation is to ensure that facilities that use large quantities of certain hazardous materials take appropriate actions to protect the community surrounding the facility. Wed Oct 28, 1998 12:10:53 PM Avagene Moore:Which facilities in our communities are impacted by the RMP Rule? Wed Oct 28, 1998 12:11:13 PM jefflorrain:The RMP Rule applies to facilities that have more than a specific "threshold quantity" of any one of a list of 77 toxic or 66 flammable compounds within a single process (e.g. propane storage and distribution)... Wed Oct 28, 1998 12:11:33 PM jefflorrain:The "process" concept is important. The rule addresses individual processes rather than the facility as a whole... Wed Oct 28, 1998 12:11:54 PM jefflorrain:The list of compounds and thresholds is included in the EPA's Risk Management Planning Page. Wed Oct 28, 1998 12:11:58 PM Avagene Moore:Would you please summarize program requirements for the RMP? Wed Oct 28, 1998 12:12:23 PM jefflorrain:The RMP Rule has three tiers of requirements (programs 1, 2 and 3). The requirements (Program 1, 2, or 3) applicable to a process are dependent on the potential risk to the community posed by that process... Wed Oct 28, 1998 12:12:45 PM jefflorrain:Things considered in determining the program level include: Wed Oct 28, 1998 12:13:10 PM jefflorrain:1- Nature of chemical within the process; Wed Oct 28, 1998 12:13:33 PM jefflorrain:2- Quantity of chemical; Wed Oct 28, 1998 12:13:45 PM jefflorrain:3- Past accident history of facility; and Wed Oct 28, 1998 12:13:57 PM jefflorrain:4- Character of area surrounding the facility... Wed Oct 28, 1998 12:14:13 PM jefflorrain:The requirements for each program level are summarized on the following slide... Wed Oct 28, 1998 12:14:16 PM Avagene Moore:http://www.emforum.org/varena/rmp/slide1.htm Wed Oct 28, 1998 12:14:44 PM jefflorrain:Note that each program includes hazard assessment and emergency response elements... Wed Oct 28, 1998 12:15:22 PM jefflorrain:he hazard assessment element includes an estimate of the area potentially impacted by a "worst case" accident... Wed Oct 28, 1998 12:15:48 PM jefflorrain:For toxics it includes an estimated distance from the facility the chemical could remain at dangerous concentrations.. . Wed Oct 28, 1998 12:16:02 PM jefflorrain:For Flammables it assumes an explosion and estimates the distance of potential damage... Wed Oct 28, 1998 12:16:50 PM joe ashby:at last at last Wed Oct 28, 1998 12:16:54 PM Avagene Moore:(Be patient -- Jeff will be back in a moment.) Wed Oct 28, 1998 12:17:21 PM Avagene Moore:Seems more than Jeff are having problems today. Wed Oct 28, 1998 12:18:18 PM Avagene Moore:Jeff is back. Wed Oct 28, 1998 12:19:28 PM Avagene Moore:Jeff, can you finish your response to the last question, please? Wed Oct 28, 1998 12:20:05 PM Avagene Moore:I believe you were at the end of response to question 3. Wed Oct 28, 1998 12:20:19 PM jefflorrain:I'm not able to control the size of the window..stand by please. Wed Oct 28, 1998 12:21:49 PM Avagene Moore:Kelly, can you add to Jeff's response and complete it? Wed Oct 28, 1998 12:22:28 PM Avagene Moore:I am sorry Jeff is having such a difficult time. Murphy's law apparently. Now there goes Kelly. Wed Oct 28, 1998 12:22:40 PM Amy Sebring:Avagene, can we put up the next slide... Wed Oct 28, 1998 12:22:48 PM Amy Sebring:and hope at least one can connect? Wed Oct 28, 1998 12:23:07 PM Avagene Moore:http://www.emforum.org/varena/rmp/slide2.htm Wed Oct 28, 1998 12:23:57 PM Amy Sebring:I am not sure why we are having so much difficulty with connections today... Wed Oct 28, 1998 12:24:10 PM Avagene Moore:This slides relates to offsite consequences, heart of why states and locals should be interested in the RMP. Wed Oct 28, 1998 12:24:12 PM Amy Sebring:have not made any changes to software. Wed Oct 28, 1998 12:24:38 PM Avagene Moore:Jeff and Kelly are back -- - if they can stay. Wed Oct 28, 1998 12:24:38 PM Amy Sebring:Jeff and Kelly seem to be back for the moment anyway! Wed Oct 28, 1998 12:24:39 PM jefflorrain:I'm back..Sorry. Wed Oct 28, 1998 12:24:53 PM Amy Sebring:Pls continue. We have next slide up. Wed Oct 28, 1998 12:24:55 PM Kelly Carmichael:Im back also...sorry. Wed Oct 28, 1998 12:25:07 PM jefflorrain:I'm ready for the next question. Wed Oct 28, 1998 12:25:23 PM Avagene Moore:Just a moment, Jeff..... Wed Oct 28, 1998 12:25:36 PM Avagene Moore:How is this different from SARA Title III requirements and the work done by LEPCs? Wed Oct 28, 1998 12:25:51 PM jefflorrain:he RMP could be thought of as the next generation of community-right-to-know... Wed Oct 28, 1998 12:26:09 PM jefflorrain:SARA III requires facilities to disclose the presence of hazardous materials, while RMP requires facilities to implement accident prevention programs... Wed Oct 28, 1998 12:26:29 PM jefflorrain:Since there is a significant community relations aspect to the RMP, facilities will want to work closely with the LEPC to communicate to the public the levels of protection that are in place. Wed Oct 28, 1998 12:26:31 PM Avagene Moore:Why should State and Local government be concerned about the RMP? Wed Oct 28, 1998 12:28:04 PM jefflorrain:I'm back, let me repeat the last statement ... Wed Oct 28, 1998 12:28:13 PM jefflorrain:Local EM orgs will likely be asked by facilities to plan responses to Off-Site Consequences of accidental releases estimated for different scenarios.... Wed Oct 28, 1998 12:28:28 PM jefflorrain:Show slide 2 Wed Oct 28, 1998 12:28:32 PM Avagene Moore:http://www.emforum.org/varena/rmp/slide2.htm Wed Oct 28, 1998 12:29:36 PM jefflorrain:I'm back.. Wed Oct 28, 1998 12:29:52 PM jefflorrain:I'll repeat... Wed Oct 28, 1998 12:29:59 PM jefflorrain:The planning will include "worst case" and alternative or more likely release scenarios... Wed Oct 28, 1998 12:30:13 PM jefflorrain:The following slides present important points about the worst case relase scenario... Wed Oct 28, 1998 12:30:26 PM jefflorrain:Show slide 3. Wed Oct 28, 1998 12:30:27 PM Avagene Moore:http://www.emforum.org/varena/rmp/slide3.htm Wed Oct 28, 1998 12:30:54 PM jefflorrain:The following slide presents important points about the more likely release scenario... Wed Oct 28, 1998 12:31:44 PM Avagene Moore: http://www.emforum.org/varena/rmp/slide4.htm Wed Oct 28, 1998 12:32:35 PM Avagene Moore:The offsite consequences analysis generates information that can be summarized on the following slide: Wed Oct 28, 1998 12:32:41 PM Avagene Moore:http://www.emforum.org/varena/rmp/slide5.htm Wed Oct 28, 1998 12:32:59 PM jefflorrain:The Off site consequences analysis generates information that can be summarized on the following slide: Wed Oct 28, 1998 12:33:11 PM Avagene Moore:Jeff, I threw that one in for you .... Wed Oct 28, 1998 12:33:12 PM jefflorrain:Show slide 5. Wed Oct 28, 1998 12:33:37 PM Avagene Moore:We are ready for question 6, Jeff. Jeff, would you give us a summary of what exactly is required for compliance? Wed Oct 28, 1998 12:34:18 PM jefflorrain:Compliance requirements vary tremendously depending on the processes at a facility. However, a general approach to compliance includes these steps... Wed Oct 28, 1998 12:34:32 PM jefflorrain:Deternine applicability...Do you have any of the listed compounds in quantities greater than the threshold quantity?... Wed Oct 28, 1998 12:34:45 PM jefflorrain:Determine Program level (program 1,2 or 3)... Wed Oct 28, 1998 12:34:56 PM jefflorrain:Plan and implement RMP elements required for the appropriate program level... Wed Oct 28, 1998 12:35:09 PM jefflorrain:Document program in an Risk Management Plan (due to EPA by June 1999). Wed Oct 28, 1998 12:35:21 PM Avagene Moore:Is there guidance available for those who need some help in meeting the deadline? Wed Oct 28, 1998 12:35:30 PM jefflorrain:Yes, Epa has put together a very useful website ( insert Ceppo). And the census bureau's "land view" is a good tool for estimating populations in the hazard zones for off-site consequences. Wed Oct 28, 1998 12:35:36 PM Avagene Moore:http://www.epa.gove/swercepp/acc-pre.html Wed Oct 28, 1998 12:35:51 PM Avagene Moore:Can you suggest a compliance strategy for anyone who may be struggling with the RMP requirements? Wed Oct 28, 1998 12:35:59 PM jefflorrain:The following is a very general compliance strategy... Wed Oct 28, 1998 12:36:02 PM Amy Sebring:(Note: links are on the background info page for this session.) Wed Oct 28, 1998 12:36:16 PM jefflorrain:1) Determine applicability... Wed Oct 28, 1998 12:37:14 PM jefflorrain:2) Evaluate modifting process to avoid applicability (best solution)... Wed Oct 28, 1998 12:37:26 PM jefflorrain:3) DetermineProgram level and the required program elements... Wed Oct 28, 1998 12:37:37 PM jefflorrain:4) Determine which of the required elements are already in place for the facility... Wed Oct 28, 1998 12:39:02 PM Kelly Carmichael:5) Plan and implement required elements (begin communication with the local EM orgs and community early...don't let the community find the information on the internet for the first time)... Wed Oct 28, 1998 12:39:15 PM Avagene Moore:(thanks, Kelly) Wed Oct 28, 1998 12:39:29 PM Kelly Carmichael:6) Document program in an RMP to be sumbitted to EPA and posted on the internet...Submitt plan by June 21, 1999. Wed Oct 28, 1998 12:39:34 PM Avagene Moore:I understand you have some ?dos and don?ts? to share with us; please clarify. Wed Oct 28, 1998 12:40:08 PM Kelly Carmichael:Yes...please show slide 6 then 7. Wed Oct 28, 1998 12:40:11 PM Avagene Moore:http://www.emforum.org/varena/rmp/slide6.htm Wed Oct 28, 1998 12:40:23 PM Avagene Moore:http://www.emforum.org/varena/rmp/slide7.htm Wed Oct 28, 1998 12:40:40 PM Avagene Moore:Jeff or Kelly .... Wed Oct 28, 1998 12:40:50 PM Avagene Moore: any closing advice to our audience about RMP and the June ?99 deadline? Wed Oct 28, 1998 12:41:15 PM Kelly Carmichael:I think the "DOs" just presented are for the industrial community. The EM community should anticipate a role of being the bridge connecting industry to environmental groups and the community... Wed Oct 28, 1998 12:42:14 PM Kelly Carmichael:EM orgs should prepare to work with responsible industrial facilities to communicate to the public the prevention programs designed to preclude the necessity of an emergency response as well as actions planned to protect the community in the event of an accident. Wed Oct 28, 1998 12:42:18 PM Avagene Moore:Thank you, Jeff and Kelly. This has been a test for both of you ... Wed Oct 28, 1998 12:42:29 PM Avagene Moore:At this point, Jeff and Kelly will entertain questions. If you have a question or comment, please indicate by typing a question mark (?) and sending it to the chat screen. Compose your question or statement but hold until you are recognized by the moderator. First question, please. Wed Oct 28, 1998 12:43:07 PM jefflorrain:I'm back. where is the discussion? Wed Oct 28, 1998 12:43:11 PM Ann Willis:? Wed Oct 28, 1998 12:43:32 PM Avagene Moore:We are ready for Q&A, Jeff. Kelly filled in for you. Ann, your question please. Wed Oct 28, 1998 12:44:01 PM Ann Willis:Do you recommend using plan generation software such as Strohl Systems LDRPS? Wed Oct 28, 1998 12:44:30 PM Amy Sebring:? Wed Oct 28, 1998 12:45:02 PM jefflorrain:The documentation is a rather small par t of the whole effort... Wed Oct 28, 1998 12:45:35 PM Ann Willis:Right, but how do you enforce consistency among plans? Wed Oct 28, 1998 12:47:03 PM Kelly Carmichael:I believe the EPA is standardizing many of the submittals, right Jeff? Wed Oct 28, 1998 12:47:31 PM Avagene Moore:Amy, you have a question - - please submit. Wed Oct 28, 1998 12:47:43 PM Amy Sebring:I am hearing facilities defining the difference between PSM (process safety management) and RMP's by saying PSM is inside the fence, RMP is outside the fence. Where is this coming from? Wed Oct 28, 1998 12:48:04 PM Amy Sebring:It doesn't seem to be accurate or tactful. Wed Oct 28, 1998 12:48:13 PM Avagene Moore:Kelly, can you respond, please? Wed Oct 28, 1998 12:49:08 PM Kelly Carmichael:PSM is primarily geared for worker safety. Whereas the RMP is focused on community safety and reducing community risk. Wed Oct 28, 1998 12:49:40 PM Amy Sebring:? follow up Wed Oct 28, 1998 12:49:44 PM Avagene Moore:Amy Wed Oct 28, 1998 12:50:16 PM Amy Sebring:P Wed Oct 28, 1998 12:50:22 PM jefflorrain:The programs have similar elements such as prevention including Preventive maintenance,ect. Wed Oct 28, 1998 12:50:31 PM Amy Sebring:PSM is incorporated into level 3... Wed Oct 28, 1998 12:50:40 PM Amy Sebring:it would just seem smarter to me to say... Wed Oct 28, 1998 12:50:57 PM Amy Sebring:anything designed to protect the workers is also going to... Wed Oct 28, 1998 12:51:01 PM Amy Sebring:protect the community. Wed Oct 28, 1998 12:51:31 PM jefflorrain:Thats true... Wed Oct 28, 1998 12:52:10 PM jefflorrain:RMP estimates the impacts to the community who do not work in the plant. Wed Oct 28, 1998 12:53:30 PM Kelly Carmichael:? Wed Oct 28, 1998 12:53:33 PM Avagene Moore:Any closing remarks, Jeff or Kelly. We are about out of time. Wed Oct 28, 1998 12:54:12 PM Avagene Moore:Sorry, Kelly. Wed Oct 28, 1998 12:54:27 PM Avagene Moore:Your comment or question. Wed Oct 28, 1998 12:54:58 PM Kelly Carmichael:Jeff, could you expand on the coverage of this program. Is it only big industry that must submit the plan? Wed Oct 28, 1998 12:55:57 PM jefflorrain:NO, a number of small businesses will be included... Wed Oct 28, 1998 12:56:40 PM jefflorrain:Any bussiness with more than 10,000lb of propane is included, for example. Wed Oct 28, 1998 12:56:59 PM Avagene Moore:Thank you, Jeff and Kelly, for being here and providing excellent overview of RMP. ... Wed Oct 28, 1998 12:57:09 PM Avagene Moore:Next week, Weds Nov 4, 12 noon EST, we have a session with Dennis Hickethier and Tim Cambbell on the Sr. Officials Workshop: Preparedness and Response for Terrorism Incidents.