Process Safety Management

EPA Clean Air Act

 Risk Management Plans
 Many Times Companies Who Must
Comply with PSM, must also Comply with
the Requirements of EPA Risk
Management Plans (RMP)
 The RMP Standard was to be a Mirror of
the PSM Standard…Didn’t happen!
 Remember…PSM Protects the Workforce,
RMP Protects the Community
Could RMP Be Required Here?
 Risk Management Plan

 Mandated by CAAA, Section 112 (r), 40 CFR

Part 68
 Promulgated - May 24, 1996
 Published Federal Register - June 20, 1996
 More than 100,000 facilities affected
 Designed to help reduce risk of accidental
release of hazardous substances
 3 years to implement
 Risk Management Plan
(continued)
 Affects owners of a stationary source with
regulated substances above a threshold quantity
(TQ):
 77 acutely toxic
 63 flammable
 Department of Transportation (DOT) classified
explosive substances
 Focuses on lethal effects resulting from acute
exposures
 Includes mandated substances
Not the Same as PSM
 Mandated Substances
 Ammonia
 Anhydrous Ammonia
 Anhydrous Hydrogen
Chloride
 Anhydrous Sulfur Dioxide
 Bromine
 Chlorine
 Ethylene Oxide
 Hydrogen Cyanide
 Hydrogen Fluoride
 Hydrogen Sulfide
 Methyl Chloride
 Methyl Isocyanate
 Phosgene
 Sulfur Trioxide
 Toluene Diisocyanate
 Vinyl Chloride
Toxic & Flammable Substances
How Did EPA Select Toxic & Flammable
Substances

 Extremely hazardous substances under SARA

 Gases and highly volatile liquids
 Vapor pressure > 10 mmHg
 Thresholds ranging from 500-2,000 lbs.
 Thresholds based on toxicity and volatility
 NFPA 4 - Most dangerous
 Flammable gases and volatile flammable liquids that could create
vapor cloud explosions
 Thresholds set at 10,000 lbs.
 Threshold Quantity
Determination
 Total quantity of a regulated substances
contained in a process at any one time
 Process included interconnected vessels
or separate vessels that could be involved
in a release (OSHA PSM definition)
EPA Risk Management Plans
(RMP) Basics
CAA 112(r)
 Requirements of 112 (r)

 Established a general duty clause to:

 Identify hazards that may result from releases

 Design and maintain a safe facility
 Minimize the consequences or releases
 Requirements of 112 (r)

 Management system for RMP Required

 Offsite consequence analysis must be
performed including:
 Worst-case scenario
 Alternative release scenario
 Must Include 5-year accident history
 Requirements of 112 (r)

 Prevention program must be developed

including:
 7-elements “mini-PSM” program
 14 elements OSHA-PSM program expanded to
address offsite effects
 Emergency response program is required
 Risk management plan Submission:
 Electronic submission to Federal EPA
 Available to public (in the public record)
 Regulatory audits must be performed
 Requirements of 112 (r)
 Basic Requirements
 Executive summary
 Registration
 Off-site consequence analysis
 Five-year accident history
 Emergency response plan
 Prevention program summary information
 Certification
 Submission

Sound Much Easier than PSM…Right?

 Requirements of 112 (r)

 A summary (RMP) is Provided to:

 EPA

 Indirectly to:
 States
 Locals

 Public
 Manufacturing Industries
Affected
 Chemical manufacturers
 Industrial Organics & Inorganics
 Paints
 Pharmaceuticals
 Adhesives
 Sealants
 Fibers
 Manufacturing Industries
Affected
 Petrochemical
Products
 Refineries
 Industrial Gases
 Plastics and Resins
 Synthetic Rubber
 Non-Manufacturing Affected

 Non-Manufacturing Facilities affected

 Utilities
 Electric and Gas (Anhydrous Ammonia)
 Public Sources
 Drinking Water and Waste Water Treatment
(Chlorine)
 Agriculture
 Fertilizers, Pesticides (Anhydrous Ammonia)
 Other Manufacturing

 Electronics
 Semiconductors
 Paper
 Fabricated metals
 Industrial machinery
 Furniture
 Textiles
 Other Industries

 Food and Cold Storage

 Propane Retail
 Warehousing
 Wholesalers
 Federal sources
 Military and Energy Installations
 Hazard Assessment

 Offsite consequence data

 Population estimate in the release plume
 Public receptors in the release plume
 Environmental receptors in the release plume
 Performed at least every 5 years
 Performed Within 6 months of a change
that increases or decreased distance by a
factor of 2 or more
Overview Worst-Case Scenario

 Greatest release quantity from vessel or piping

 May include administrative controls
 Toxic gases
 Quantity released in 10 minutes
 Toxic liquids
 Instantaneous spill to ground; volatilization; passive
mitigation
 Toxic gases liquefied by refrigeration
 Worst-Case Scenario
(continued)
 All flammable substances
 Quantity for vapor cloud explosion
 One worst case for each process
 One worse case representing all toxic
substances
 Alternative Release Scenario
(ARS)
 Next likely release scenario
 Much reach endpoint offsite
 One scenario representative of all
flammables is required
 ARS Selection

 Past Accident history events

 Process hazard analysis events in PHA’s
 Worse case with mitigation
 Example scenarios:
 Piping or hose failures
 Seal failures
 Vessel overfilling or venting
 Offsite Consequence Analysis

 Toxic endpoint must be identified

 Flammable endpoints must be identified
 Use appropriate models or guidance
 Within circle, identify
 Public receptors and population
 Environmental receptors
 Hospitals, Nursing Homes, Schools,
Governmental Agencies

Receptor - Persons that could be affected by a release

All Public Facilities
in this Release Release
Plume Must be Plume
Identified &
Surveyed
 Registration and Submittal

 Submit a comprehensive RMP to:

 EPA
Indirectly or Referred to:
 State Emergency Response Commission
(SERC)
 Local Emergency Planning Committee
(LEPC)
 The Chemical Safety and Hazard
Investigation Board
With the New Administration - The Process Has Changed
 Registration and Submittal
(Continued)
 Name, mailing address, telephone of
stationary source
 CAS number of all regulated substances
greater than TQ
 SIC code
 Dun and Bradstreet number
 Certification signed by owner or operator
 Auditing the Program

 Just Like PSM, You Must Audit the

Program (at least every 3 years)

 Conduct audits of the management

system
 RMP Example

An Actual Example of a Submitted

RMP
Basic Facility Info

Facility ID 100000060613
Facility Name Dixie Cold Storage
Street Address Line 1 7199 W. Bert
City New Orleans
State LA
Zip Code 711222
County Cadme Parish
Owner or Operator Name Alan Smith
Parent Company Pride Corporation
Latitude 39.435617
Longitude -083.898650
Number of RMP Submissions 4
Most Recent Submission Info

RMP ID 47270
Submission Type correction for prior submission
Submission Date 12/19/2006
Reason For Submission New accident history information
Deregistration Date 12/29/2006
Deregistration Effective Date 12/28/2006
Deregistration Reason Other
Deregistration Reason (Other) Sold facility
Process Toxic Amount Total (lbs) 13,200
Process Flammable Amount Total (lbs) 0
Process Amount Total (lbs) 13,200
Number of Potential Offsite Consequence Processes 1
Potential Offsite Consequence Toxic Amount Total (lbs) 13,200
Potential Offsite Consequence Flammable Amount Total (lbs) 0
Potential Offsite Consequence Amount Total (lbs) 13,200
All Process NAICS 49312
Exec Summary Submission Date 12/19/2006
Executive Summary

This Risk Management Plan (RMP) covers the Pride Storage

Plant in New Orleans, LA. The reason for submitting this RMP
is to comply with the mandatory five years update and to
report the change of ownership from ACME Foods to Pride
Corporation. This facility has two refrigeration systems using
anhydrous ammonia as the refrigerant. The amount of
anhydrous ammonia contained in only one of the systems is
above the EPA threshold reporting quantity of 10,000
pounds.

Because anhydrous ammonia is listed by both the US

Occupational Safety and Health Administration (OSHA) and
the US Environmental Protection Agency (EPA) as a
hazardous chemical, our accidental release prevention
program is designed to comply with the Process Safety
Management (PSM) and Risk Management Program (RMP)
regulations of these two agencies. These regulations are
designed to prevent the accidental release of ammonia and
to minimize the negative consequences should a release
occur…
Submission - Other Facility Info

Owner or Operator Name Alan Smith

Owner or Operator Address Line 1 7199 W. Bert
Owner or Operator City Shreveport
Owner or Operator State LA
Owner or Operator Zip 711222
Parent Dun and Bradstreet Number 7334170
Second Parent Dun and Bradstreet Number 0
Number of Full Time Employees
44
Number of FTE CBI Flag No
Covered by OSHA PSM Standard Yes
Covered by EPCRA Section 302 Yes
Covered by CAA Title V No
Last Safety Inspection Date 02/16/2005
Last Safety Inspection By State environmental agency
OSHA Star or Merit Ranking No
LEPC Name New Orleans / Cadme LEPC
Submission - Contact Info
Owner or Operator Phone 3186881212
Facility URL www.pride.com
Facility Phone 3186881222
Facility Dun and Bradstreet Number 7444170
RMP Contact Linda Darnell
RMP Contact Title Corporate PSM Director
RMP Contact Email Linda.Darnell@pride.com

Submission - Additional Info

RMP Complete Flag Yes
Predictive Filing No
No RMP Accidents Last 5 Years No
Complete Check Date 12/20/2006
Postmark Date 12/13/2006
Anniversary Date 06/21/2009
Confidential Business Information N
Submission - Lat/Long Info
Latitude 39.435617
Longitude -083.898650
Valid Lat/Long Yes
Lat/Long Method GPS - Unspecified
Lat/Long Location Type Storage Tank
FRS Latitude 39.43
FRS Longitude -83.89

Submission - Counts and Totals

Number of RMP Accidents 1
Number of Processes 1
Number of Process Chemicals 1
Number of Toxic Worst-case Scenarios 1
Number of Toxic Alternate Case Scenarios 1
Number of Flammable Worst-case Scenarios 0
Number of Flammable Alternate Case Scenarios 0
RMP Accident Flammable Total (lbs) 0
RMP Accident Toxic Total (lbs) 2,530
RMP Accident Amount Total (lbs) 2,530
Total RMP Accident Deaths 0
Total RMP Accident Injuries 0
Total RMP Accident Evacuated/Sheltering In Place 0
Total RMP Accident Property Damage $
Processes
Process Description Ammonia Refrigeration
Program Level 3
Confidential Business Information No
Toxic Amount Total (lbs) 13,200
Flammable Amount Total (lbs) 0
Process Amount Total (lbs) 13,200
Number of Process Chemicals 1
Number of Toxic Worst-Case Scenarios 1
Number of Toxic Alternate Scenarios 1
Number of Flammable Worst-Case Scenarios 0
Number of Flammable Alternate Scenarios 0

Process Chemicals
Process Chemical ID Ammonia (anhydrous)
CAS number 007664417
Chemical Type Toxic
Process Chemical Amount (lbs) 13,200
Confidential Business Information N
Worst-Case Toxic Scenarios

Percent Weight (Within Mixture) 0

Physical State Gas liquified by pressure
Model Used EPA's RMP*Comp(TM)
Release Duration (minutes) 10
Wind Speed (meters/sec) 1.5
Atmospheric Stability Class F
Topography Urban
Passive Mitigation - Dikes No
Passive Mitigation - Enclosures No
Passive Mitigation - Berms No
Passive Mitigation - Drains No
Passive Mitigation - Sumps No
Confidential Business Information No
Alternate Case Toxic Scenarios

Percent Weight (Within Mixture) 0

Physical State Gas liquified by pressure
Model Used EPA's RMP*Comp(TM)
Wind Speed 3
Atmospheric Stability Class D
Topography Urban
Passive Mitigation - Dikes No
Passive Mitigation - Enclosures No
Passive Mitigation - Berms No
Prevention Program 3

Safety Info Review Date 04/01/2004

PHA Update Date 03/31/2002
PHA Technique - What If No
PHA Technique - Checklist No
PHA Technique - What If/Checklist No
PHA Technique - HAZOP Yes
PHA Technique - FMEA No
PHA Technique - FTA No
PHA Change Completion Date 03/31/2005
Accidents

Accident Date 09/12/2006

Accident Time 0540
Number of Chemicals 1
Flammable Amount Total (lbs) 0
Toxic Amount Total (lbs) 2,530
Released Amount Total (lbs) 2,530
Number of Deaths 0
Number of Injuries 0
Number Evacuated / Sheltered 0
Total Property Damage $0
Environmental Damage Yes
NAICS of Process Involved 49312
Release Event - Spill No
Release Event - Fire No
Release Event - Explosion
Emergency Response Plan Info

Facility In Community Plan Yes

Facility Own Response Plan Yes
Specific Facility Response Plan Yes
Inform. Procedures in Response Plan Yes
Emergency Care in Response Plan Yes
Plan Review Date 04/01/2004
Response Training Date 04/28/2004
Local Response Agency Shreveport Fire Department
 EPA RMP 1998 Changes
Compliance Elements
 Follow-up / completion of PHA
recommendation
 Re-validation of your PHA every 5 years
 Compliance audits (required every 3
years)
 Follow-up / completion of compliance audit
recommendations
 EPA RMP 1998 Changes
Compliance Elements
 Annual review and certification of
operating procedures
 Employee training
 Updates related to system modifications,
inventory changes, operational changes
 Off-site consequence analysis Updated
 EPA RMP Summary

 Not all PSM sites are RMP sites and vice

versa
 Chemical Substances and TQ’s are Not
the Same for PSM
 Focused on Protecting the Surrounding
Community - Off Site Consequence
 Electronically submitted to EPA
 PSM & RMP- Why?

To Protect the Workforce

To Protect the Surrounding Community

To Maintain System Integrity

To Comply with the Law

It’s Not About a Program, It’s About People!

 What’s Next

 Course Summary
 References & Resources
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