RISK MANAGEMENT PLAN (RMP)
Section 112(r) of the Clean Air Act Amendments requires EPA to publish regulations and guidance for chemical accident prevention at facilities that use certain hazardous substances over a defined threshold amount. The reporting threshold for Anhydrous Ammonia is 10,000 pounds.
These regulations and guidelines are contained in the Risk Management Plan (RMP) rule. A RMP:
Identifies the potential effects of a chemical accident
Identifies steps the facility is taking to prevent an accident
Spells out emergency response procedures should an accident occur
This information provides valuable information to local fire, police, and emergency response personnel to prepare for and respond to chemical emergencies in their community. An RMP is to be filled every 5 years with the EPA.
Information you must provide in your RMP:
Facility emergency contact information
Quantity of the hazardous chemical
Dates for the review or update of the PSM elements
Worst-case and alternate case release scenarios
The worst case and alternate case scenarios are developed by facility personnel accessing the most severe release scenario which could occur that would allow for the maximum quantity of the hazardous chemical released, how far it would migrate from the facility, and what population of people in the area could be affected. The same is done for a more likely event (alternate case scenario).
The five-year submission window is not the only time for updating the submitted RMP. Under certain circumstances, the RMP may have to be updated or resubmitted prior to the five-year anniversary.
An updated RMP is due within six months if any of the following occur:
There is a change that requires a revised PHA or hazard review.
There is a change that alters the program level to any covered process.
A revised off-site consequence analysis (OCA) was performed.
The changes listed above will reset the five-year anniversary date, which means the new date will be five years from when the update was filed.
Another change that may occur is called a correction. A correction may have to be submitted to the RMP due to any of the following situations:
An accidental release of a regulated substance that requires an incident investigation.
Information about the incident must be added to the accident history and incident investigation sections of the RMP within six months of the occurrence.
The facility emergency contact information changes; the new information in the RMP must be added within one month of the change.
A Protexus specialist will assist our clients with the filing of their RMP. Our specialist will guide facility personnel with gathering the necessary information for the filing as well as work with them to determine or review what event would result in the maximum release of the hazardous chemical.
Once all the information has been gathered, we can be registered as your preparer and file your RMP with the Central Data Exchange (CDX).
Tier II Reports
Tier II is the Emergency Planning and Community Right to Know Act (EPCRA) Section 312 Tier II Emergency and Hazardous Chemical Inventory report. These reports help communities plan and respond to emergencies and help various state and local agencies understand the risks posed by materials in facilities. This applies only to hazardous chemicals onsite that are at or above the reporting threshold.
Tier II reporting is annual and due by March 1st.
A Protexus specialist can assist with the development of the chemical list required to report their quantities and the submission of the documents to the applicable SERC, LEPC, and fire department.