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Due to the
Montreal Protocol, the phase-out of global warming chemicals (GWC)
and ozone depleting substances (ODS) has been scheduled for
banning their production and use through various deadlines, from
1999 up to 2020 in North America.
HRP has assisted facilities across the United States, Mexico,
and Canada in meeting these regulatory deadlines and upgrading
their facilities to appropriate design codes and standards, as
well as providing appropriate safety management planning.
With the replacement of GWCs and ODSs, the following projects
may be required at your facility:
-
Air Emission
Discharge Permitting (EPA/State);
-
Risk
Management Planning (EPA);
-
Process Safety
Management Planning (OSHA);
-
Electrical,
Piping, Ventilation Upgrades (NFPA, OSHA);
-
Stormwater
Management Plans (EPA/State); and
-
Spill
Prevention Control and Countermeasure Plans (EPA).
Risk Management
Plans (RMPs) were originally a compliance requirement in 1999
for facilities who maintained regulated chemicals, such as one
of the 63 flammables or 97 different toxic materials above
threshold values. Subsequently, follow-up audits were scheduled
for five years, following initial implementation.
The year 2004 has arrived and facilities are occupied nationwide
with performing their renewal audits by the present deadline
of June 21, 2004. If necessary, facilities must also update
the facility Process Hazard Analyses (PHA), complete a revised
Federal notification via the revised RMP Submit software, and
modify Release Scenarios utilizing updated census information (Landview
VI).
HRP can assist with the renewals, updates, and development of
RMPs (Program 1, 2, or 3) to allow facilities the flexibility of
operating in a safe environment, as well as effectively conduct
manufacturing operations. HRP has successfully completed
compliance reviews and prepared risk/process safety management
plans for over 15 facilities in the Northeast, Southeast, and
Midwest United States, and Mexico.
One project of interest is represented in a
case study for RMax's Greer, SC facility. Following
successful completion, subsequent project coordination and
preparation of air permits, RMP/PSMs were also conducted for
RMax's Fernley, NV and Dallas, TX facilities. This demonstrated
HRP's ability to complete projects on a corporate level for
several facilities.
HRP proposes to work closely with our clients in order to
complete a DRAFT of the plans by at least two months prior to
the startup of the regulated process. Subsequent revisions can
then be made to the plan prior to placing the regulated systems
into operation. Also, once the plan has been finalized, but
prior to having 10,000 pounds of regulated materials on site,
HRP will submit electronically only the required RMP information
to EPA.
Case Study
Regulation
Risk Management Plan (RMP) Rule
A process at a stationary source is subject to the requirements
of § 112(r) of the Clean Air Act Amendments of 1990 (EPA’s
Accidental Release Prevention / Risk Management Plan Rule) if it
has above a threshold quantity (TQ) of a listed toxic or
flammable substance.
The RMP Rule defines three “Program Levels” based on a process’
relative potential for public impacts and the level of effort
needed to prevent accidents. For each Program Level, the RMP
Rule defines requirements that reflect the level of risk and
effort associated with the process. The three Program Levels are
briefly summarized below:
-
Program 1 –
Process with no public receptors within the distance to an
endpoint from a worst-case release and with no accidents
with specific offsite consequences within the past 5 years.
-
Program 2 –
Process not eligible for Program 1 or subject to Program 3.
-
Program 3 –
Process not eligible for Program 1 and either subject to
OSHA’s Process Safety Management (PSM) Standard or
classified in one of the following SIC codes: 2611, 2812,
2819, 2821, 2865, 2869, 2873, 2879, 2911.
Whether a process
is classified as a Program 1, 2, or 3 processes, its RMP must
include (or address) the following three elements: Hazard
Assessment, Prevention Program, and Emergency Response Plan.
Program 1 imposes limited hazard assessment requirements and
minimal prevention and emergency response requirements. Program
2 imposes streamlined prevention program requirements, as well
as additional hazard assessment, management, and emergency
response requirements. Program 3 imposes OSHA’s Process Safety
Management standard as the prevention program as well as
additional hazard assessment, management, and emergency response
requirements.
Process Safety Management (PSM) Program
OSHA’s PSM requirements, according to 29 CFR 1910.119
(a)(1)(ii), are applicable to “… a process which involves a
flammable liquid or gas (as defined in 1910.1200(c) of this
part) on site in one location, in a quantity of 10,000 pounds or
more…” The PSM regulation requires employers to prepare and
implement a PSM Program that includes all of the following:
-
Employee
Participation
-
Process Safety
Information:
-
Information pertaining to the hazards of the chemical
-
Information pertaining to the technology of the process
-
Information pertaining to the equipment in the process
-
Process hazard
analysis using one or more of the following:
-
Operating
procedures:
-
Steps for
each operating phase
-
Operating
limits
-
Safety and
health considerations
-
Safety
systems and their functions
-
Training:
-
Initial
training
-
Refresher
training
-
Training
documentation
-
Contractors:
-
Pre-startup
safety review
-
Mechanical
integrity:
-
Hot work
permits provisions
-
Management of
change
-
Incident
investigations
-
Emergency
planning and response
-
Compliance
audits
-
Trade secrets
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A facility
must be in compliance with the requirements of both the
RMP and PSM regulations prior to having more than 10,000
pounds of regulated material on site.
For more
information, please contact
Tad
Goetcheus, P.E. at 1-800-246-9021 |
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