Edited Version October 28, 1998 Transcript
EIIP Tech Arena Online Presentation
"Risk Management Plans"
Law Engineering and Environmental Services, Inc.
Law Engineering and Environmental Services, Inc.
EIIP Tech Arena Moderator: Avagene Moore
The original transcript of October 28, 1998 online Tech Arena discussion is available in EIIP Virtual Forum Archives (http://www.emforum.org). The following version of the transcript has been edited for easier reading and comprehension. Typos were corrected, date/time/names attributed by the software to each input were deleted but the content of questions and responses are as stated by each participant. Answers from the participants to questions by the audience are grouped beneath the appropriate question to facilitate meaning.
Avagene Moore: Welcome to the EIIP Technology Arena! We are here today to talk about Risk Management Plans (RMP) and the deadline for compliance with the EPA RMP Rule.
Our special guests today are Jeff Lorrain and Kelly Carmichael, Law Engineering and Environmental Services, Inc.
Jeff Lorrain is a Senior Scientist in the Environmental, Health and Safety Department at LAWGIBB's National Technical Center in Atlanta. Jeff has over 19 years experience providing environmental consulting services to industrial, commercial and governmental clients on a broad range of issues. 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.
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.
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.
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.
Avagene Moore: My first question, Jeff --- Please give us a very brief history of the RMP --- what is the purpose?
Jeff Lorrain: The Accidental Release Prevention Rule or RMP is part of the Clean Air Act Amendments of 1990 [Section 112(r)]. 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.
Avagene Moore: Which facilities in our communities are impacted by the RMP Rule?
Jeff Lorrain: 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).
The "process" concept is important. The rule addresses individual processes rather than the facility as a whole. The list of compounds and thresholds is included in the EPA's Risk Management Planning Page.
Avagene Moore: Would you please summarize program requirements for the RMP?
Jeff Lorrain: 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.
Things considered in determining the program level include:
1- Nature of chemical within the process;
2- Quantity of chemical;
3- Past accident history of facility; and
4- Character of area surrounding the facility.
The requirements for each program level are summarized on the following slide.
Jeff Lorrain: Note that each program includes hazard assessment and emergency response elements.
The hazard assessment element includes an estimate of the area potentially impacted by a "worst case" accident.
For toxics - it includes an estimated distance from the facility, the chemical could remain at dangerous concentrations.
For flammables - it assumes an explosion and estimates the distance of potential damage.
Avagene Moore: How is this different from SARA Title III requirements and the work done by LEPCs?
Jeff Lorrain: The RMP could be thought of as the next generation of community-right-to-know. SARA Title III requires facilities to disclose the presence of hazardous materials, while RMP requires facilities to implement accident prevention programs.
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.
Avagene Moore: Why should State and Local government be concerned about the RMP?
Jeff Lorrain: Local EM organizations will likely be asked by facilities to plan responses to Off-Site Consequences of accidental releases estimated for different scenarios. Show SLIDE 2.
Jeff Lorrain: The planning will include "worst case" and alternative or more likely release scenarios. The following slides present important points about the worst case release scenario. Show SLIDE 3.
Jeff Lorrain: The following slide presents important points about the more likely release scenario. Show SLIDE 4.
Jeff Lorrain: The offsite consequences analysis generates information that can be summarized on the following slide. Show SLIDE 5.
Avagene Moore: Jeff, would you give us a summary of what exactly is required for compliance?
Jeff Lorrain: Compliance requirements vary tremendously depending on the processes at a facility.
However, a general approach to compliance includes these steps:
Determine applicability. Do you have any of the listed compounds in quantities greater than the threshold quantity?
Determine Program level (program 1,2 or 3)
Plan and implement RMP elements required for the appropriate program level
Document program in an Risk Management Plan (due to EPA by June 1999).
Avagene Moore: Is there guidance available for those who need some help in meeting the deadline?
Jeff Lorrain: Yes, EPA has put together a very useful Website
<http://www.epa.gove/swercepp/acc-pre.html>. And the census bureau's "land view" is a good tool for estimating populations in the hazard zones for off-site consequences.
Amy Sebring: Note: links are on the background info page for this session.
Avagene Moore: Can you suggest a compliance strategy for anyone who may be struggling with the RMP requirements?
Jeff Lorrain: The following is a very general compliance strategy:
1) Determine applicability
2) Evaluate modifying process to avoid applicability (best solution)
3) Determine Program level and the required program elements
4) Determine which of the required elements are already in place for the facility
5) Plan and implement required elements (Begin communication with the local EM organizations and community early. Don't let the community find the information on the Internet for the first time)
6) Document program in an RMP to be submitted to EPA and posted on the Internet. Submit plan by June 21, 1999.
Avagene Moore: I understand you have some do's and don'ts to share with us; please clarify.
Kelly Carmichael: Yes. Please show slide 6 then 7.
Avagene Moore: Jeff or Kelly, any closing advice to our audience about RMP and the June '99 deadline?
Kelly Carmichael: I think the "DO's" 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.
EM organizations 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.
Avagene Moore: Thank you, Jeff and Kelly. 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.
Ann Willis: Do you recommend using plan generation software, such as Strohl Systems LDRPS?
Jeff Lorrain: The documentation is a rather small part of the whole effort.
Ann Willis: Right, but how do you enforce consistency among plans?
Kelly Carmichael: I believe the EPA is standardizing many of the submittals, right Jeff?
Amy Sebring: I am hearing facilities defining the difference between PSM (process safety management) and RMP by saying PSM is inside the fence, RMP is outside the fence. Where is this coming from? It doesn't seem to be accurate or tactful.
Kelly Carmichael: PSM is primarily geared for worker safety. Whereas the RMP is focused on community safety and reducing community risk.
Jeff Lorrain: The programs have similar elements such as prevention including Preventive maintenance, etc.
Amy Sebring: PSM is incorporated into level 3, it would just seem smarter to me to say anything designed to protect the workers is also going to protect the community.
Jeff Lorrain: That's true. RMP estimates the impacts to the community who do not work in the plant.
Avagene Moore: Any closing remarks, Jeff or Kelly. We are about out of time.
Kelly Carmichael: Jeff, could you expand on the coverage of this program. Is it only big industry that must submit the plan?
Jeff Lorrain: No, a number of small businesses will be included. Any business with more than 10,000 lbs. of propane is included, for example.
Avagene Moore: Thank you, Jeff and Kelly, for being here and providing excellent overview of RMP. Thank to our audience also.
Next week, Wednesday Nov 4, 12 noon EST, we have a session with Dennis Hickethier and Tim Campbell on the Sr. Officials Workshop: Preparedness and Response for Terrorism Incidents.