Guides to Chemical Risk Management EPA 550-B-99-015 May 1999 Evaluating Chemical Hazards in the Community: Using an RMP's Offsite Consequence Analysis I T-> • >''•*!•••- ------- Permission to reproduce this guide is granted with the accompanying credit line: "Reproduced from Guides to Chemical Risk Management, Evaluating Chemical Hazards in the Community: Using an RMP's Off site Consequence Analysis, with permis- sion from the National Safety Council's Environmental Health Center, May 1999." May 1999 The Current Status of the Risk Management Program Rule As of the publication date of this backgrounder, key elements of EPA's Risk Management Program Rule are still not final. Public access to the offsite consequence analysis data continues to be debated. EPA has not officially decided on how it will respond to Freedom of Information Act requests. The agency has said that while the offsite consequence analysis data will not be distrib- uted to the public on the Internet, it will supply paper copies of the data upon request. Also, EPA intends to increase the reportable quantity of hydrocarbon fuels (i.e., propane). Concurrently, the U.S. Court of Appeals granted an interim stay of the Risk Management Program Rule as it applies to facilities using propane in a process. For the most current information, see http://www.epa.gov/ ceppo. For More Information The National Safety Council is maintaining the Chemi- cal Emergency Management Web site at www.nsc.org/ xroads.htm as a resource supplement to this series of publications. The site is a directory of Risk Management Program-related links to organizations, regulations, chemicals, rules, and regulations involved in emergency management and the safe handling of chemicals. A selection of articles and papers written about the Risk Management Program Rule and local efforts to identify and analyze risk in the community is also included. The site will be constantly expanding as industry and commu- nities develop new information required under the Risk Management Program Rule. Other Publications in this Series Other documents in the Guides to Environmental Risk Management Series are listed below: U New Ways to Prevent Chemical Incidents U How Safe Am I? Helping Communities Evaluate Chemical Risks U What Makes a Hazard Hazardous: Working with Chemical Information U Chemical Safety in Your Community: EPA's New Risk Management Program These documents can be downloaded for free from the Chemical Emergency Management Web site at www.nsc.org/xroads.htm. About this Document The Environmental Health Center produced this guide under cooperative agreement CX 826604-01-0 with the U.S. Environmental Protection Agency. It is part of a series of publications on the Risk Management Program Rule and issues related to chemical emergency manage- ment. ------- Evaluating Chemical Hazards in the Community: Using an RMP's Offsite Consequence Analysis Chemical incidents that cause fatalities, injuries, and property damage occur all too frequently. Fortu- nately, catastrophic incidents such as the 1984 methyl isocyanante release in Bhopal, India, are extremely rare. But the potential for disaster is always present. According to the Chemi- cal Safety and Accident Investigation Board (CSB), for the years 1987 through 1996, an average of 60,000 chemical releases, spills, and fires occurred annu- ally—42 percent of the incidents occurred at fixed facilities (Figure 1). The CSB estimates that during this 10-year period, 2,565 people were killed or injured by chemical incidents. Hazardous substances in the community present both reporting opportuni- ties and challenges. Chemical names, quanti- ties, locations, and health effects, as well as popula- tions vulnerable to a release, are key story elements. But frequently this information is difficult to obtain. The Risk Man- agement Program Rule (RMP Rule), a new U.S. Environmental Protection Agency (EPA) regulation set to take effect June 21, 1999, will provide some answers by (1) requiring regulated facilities to conduct a hazard assess- ment and (2) making it available to the public. The hazard assessment will consist of an inventory of listed substances, a five- year history of releases, and an offsite consequence analysis (OCA). The OCA is the centerpiece of the hazard assessment; it is an estimate of harm to people and the environment beyond the facility's fenceline that can result from a chemical release. The OCA answers four basic questions needed to understand a chemical hazard: Q What hazardous substance(s) could be released? i_) How much of the substance(s) could be released? Q How large is the hazard zone created by the release? L) How many people could be injured? Total Transportation and Fixed-Facility Incidents 1987-1996 1996 1995 10,000 20.000 30.000 40.000 50.000 60,000 Fixed Facility Incidents [ Transportation Incidents Figure 1: The CSB reported that an average of approxi- mately 60,000 hazardous materials incidents occurred annually between 1 987 and 1996—42 percent of the incidents occur at fixed facilities. These incidents were placed into five categories: fixed-facility transportation, outside, other, and no data. This chart only reflects data on two categories and repre- sents 85 percent of the total incidents (Chemical Safety and Hazard Investigation Board April 1999). ------- Types of Facilities Regulated by the Risk Management Program Rule Chemical Distributors 7 ':• Electric/Gas Utilities 5% Chemical/Petrochemica I Refineries and Allied Industry 5% Propane Retailers and Users 44% Ammonia Refrigeration 9% Agriculture Retailers 10% Other 11% Drinking Water and Municipal Waste Treatment Facilities 14% Figure 2: Facilities that have more than specified threshold quantities of any of 77 acutely toxic substances or 63 flammable substances must submit an RMP Initially 44 percent of the 66,000 facilities affected by the Risk Management Program Rule were propane distributors and users. This number could change dramatically if proposed legislation to exempt propane from the RMP or an EPA proposal to raise the reporting threshold for hydrocarbon fuels become effective. The History of the RMP Rule The RMP Rule builds on the earlier emergency planning and community right-to-know efforts implemented under the Emergency Planning and Community Right To Know Act of 1986 (EPGRA). Under EPGRA, facilities are required to file reports if the quantities of the hazardous chemicals exceed specified thresh- olds. In 1987, EPGRA launched another impor- tant right-to-know program called the Toxics Release Inventory. Under this program, facilities report emissions of hazardous substances to EPA. With these programs, EPGRA extended right-to-know beyond the workplace and into the community. In 1990, Congress took additional measures to protect communities from hazardous chemicals by including accident preven- tion and emergency preparedness measures in the Glean Air Act Amend- ments of 1990. Section 112(r) of the Glean Air Act authorizes EPA to develop regulations that prevent and prepare for accidental releases. These regulations are contained in the Accidental Release Preven- tion Requirements: Risk Management Program Rule, also known as the RMP Rule (40 GFR Part 68). The RMP Rule focuses on preventing accidental chemical releases, reduc- ing risk to the community from exposure to hazardous chemicals, and minimizing the consequences of releases on the environ- ment. The RMP's primary goal is to protect communi- ties from releases of toxic or flammable chemicals that are prone to cause immediate, serious harm to public and environmental health. Flammable and toxic chemicals that can cause severe, acute health effects are covered under the rule; pyrotechnic and explosive chemicals are not. Facilities such as chemical plants, oil refineries, propane retail- ers, fertilizer warehouses, ammonia users, and water treatment plants, must comply with the EPA's RMP Rule by submitting a summary of their risk management plans (RMPs) to EPA by June 21,1999 (Figure 2). The RMPs must be submitted if any process at a site contains more than specified amounts of 140 hazardous substances, such as propane, ammonia, or chlorine. Hazard Versus Risk Understanding the distinction between hazard and risk is central to using the OGA as one of the tools for determining how a community can manage hazardous chemicals. The OGA analyzes hazards. The RMP Rule does not require a risk assessment. A hazard is something that is capable of causing harm. The bigger the hazard, the greater the capacity to cause harm (DiNardi 1997). The hazard is based on properties intrinsic to the material and the level and duration of exposure. For example, hydrofluoric acid is toxic, propane is flammable. Little can be done to change these characteristics. The severity of the hazard often depends on exposure. The extent of exposure can be influenced by the quantity of the substance released, the circumstances of the release (for example, ------- Figure 3: This is a typical map found in an RMF? showing hazardous areas, vulnerable populations, and sensitive environments. This map shows the endpoint, distance to endpoint, and the hazard zone for one possible scenario. The hazard zone is a circle because wind variability could cause the toxic cloud or fire effects to go in a number of directions. weather conditions, topography, mitigation measures), and the proxim- ity to the point of release. The severity of the hazard can be reduced, for ex- ample, by lowering the quantity of the chemical stored onsite or by improv- ing facility or process design. Risk is a measure of probability. The greater the risk, the more likely the hazard will cause harm (DiNardi 1997). Ideally, risk should be quantified—for example, a 10 percent probability that a certain event will occur. Too frequently, however, data on rates of equipment failure and human error are unavailable, so it is not possible to reliably quantify the risk of a chemical release. Nevertheless, we know from experience that certain events happen more frequently than others do—for example, releases frequently occur during transfer operations or process startups. Catastrophic events, like the Bhopal tragedy, occur rarely and would be considered high-hazard, low-risk events. An inci- dent that occurs fre- quently but does not generate an offsite conse- quence would be consid- ered a low-hazard, high-risk event. Predicting the Distance to Endpoint Potential offsite conse- quences of accidental chemical releases are predicted by air dispersion models, which estimate the area that may become hazardous under certain conditions. The models integrate information about chemical properties and release conditions and forecast the scenario's distance to endpoint. Though the flow of some dense gases and vapors will be guided by terrain features, wind direction will generally control movement, creating hazards downwind from the point of release. Since it is not possible to reliably predict when accidents will occur or what the wind direction will be when they do occur, released gases and vapors may travel in any direction. Therefore, the total area that may be affected by a release is represented by a circle with its center at the point of release. The radius of the circle represents the distance to endpoint (Figure 3). The area within the circle is the hazard zone. The OCA identifies vulner- able populations and sensitive environmental areas within this circle. Hazard zones can easily be displayed graphically on local maps that show vulnerable populations, such as nearby homes, schools, nursing homes, businesses, or parks and recreational areas. These ------- 6 vulnerable populations are referred to in the RMP Rule as public receptors. Envi- ronmental receptors, such as vulnerable parks and designated wildlife and wilderness areas, may also be identified. Models in the Real World A facility can use EPA's chemical-specific end- points or other emergency air dispersion models to calculate the distance to endpoint. The RMP Rule does not specify which model should be used other than the model should be one that (1) is publicly available, (2) accounts for the required modeling conditions, and (3) is recognized by industry as acceptable. The advantage of using an air dispersion model is that it may be more accurate than EPA's meth- odology for predicting the mixing of pollutants in air and the distance to end- point. However, the results of any model should be viewed cautiously since few of the fundamental algo- rithms used by all of the models can be verified in actual field tests. Models are designed to simulate reality—a very complicated set of vari- ables and interrelations that is difficult to under- stand and replicate. Differences in the methods used to combine the effects of each variable can result in hazard distances that vary widely; predicted hazard distances often lie within a band of uncer- tainty. Some OGA's will predict a very large distance to endpoint. Facilities must quantify distances up to 25 miles. Still, estimating distances beyond six miles tends to be particularly uncertain because of local variations in meteorological conditions and topography. For example, atmospheric turbulence is a major factor in determining how quickly a toxic cloud will mix with the surrounding air and be diluted. And how quickly a cloud will be diluted to below the endpoint value will affect the distance it travels. It is dangerous to assume that atmospheric turbulence and wind speed and direction will remain constant from the point where a pollutant is being released (Evans 1998). Worst-Case and Alternative Release Scenarios All RMPs are required to contain an OCA for a worst-case release sce- nario (Figure 4). If both regulated toxic and flam- mable substances are present in a process, separate scenarios for each type of substances must be prepared. Many facilities will also need to prepare alternative release scenarios. Worst-case scenarios assume there is a rapid, Figure 4: This map shows a worst-case scenario and a more likely alternative scenario for a typical facility. The differences between the size of the hazard zone in a worst-case and an alternative scenario can be based on a number of factors, including the facility's emergency response capability, accident history, or design improve- ments. ------- ground-level release of the greatest possible amount of a chemical from a single vessel or pipe. Passive mitigation devices, such as dikes and containment walls around the process, may be assumed to capture or control the release if they would be likely to survive the incident. However, active mitiga- tion devices that require human, mechanical, or other energy to manage releases must be assumed to fail in the worst-case scenario. In addition, weather conditions are assumed to be very mild, producing minimal mixing of the toxic gas or vapor cloud. These conditions produce a large, stable cloud with a persistent, high chemical concentra- tion—the most severe type of hazard. EPA states that the maximum hazard zone for worst-case scenarios may be quantified for distances up to 25 miles. (Note: Some scenarios may extend further than 25 miles, but will not be quantified beyond that point.) Alternative release scenarios are based on more realistic factors and must have an offsite endpoint, if possible. Facilities are given more latitude in designing these events. Alternative sce- narios may be based on the facility's five-year accident history or on a review of process hazards conducted as part of the RMP Rule's accident prevention requirements. Unlike worst-case sce- narios, the weather conditions are assumed to be typical for the area. In addition, these more likely scenarios assume that both active and passive Where to Find EPAS Chemical- Specific Endpoints Many facilities appear to be using EPAs chemical-specific endpoints for toxics and flammables. EPAs RMP Offsite Consequence Analysis Guidance includes a table of values for chemical-specific endpoints. EPAs endpoints are intentionally designed to be conservative, erring on the side of greater public protection. EPAs methodology is automated in a computerized application called RMP*Comp™. The program can be downloaded from EPAs Web page for Chemical Accident Prevention and Risk Management Planning at http://www.epa.gov/swercepp/ds- epds.htm. The ready availability of these tools will help to standardize the results provided from various facilities and will enable emergency planners, community members, and facilities to more easily compare and evaluate RMP data from various processes. mitigation systems operate as intended. Facilities that do not maintain any chemicals that could cause an offsite impact and that have not had any accidents with an offsite consequence in the past five years are consid- ered low hazard and are not required to submit the alternative scenario analysis. The Value of Worst- Case Scenarios Characterizing danger only by using worst-case scenarios can be mislead- ing and unnecessarily alarming. Worst-case scenarios estimate the maximum possible area that might be affected by an accidental release. They help ensure that potential hazards to public health are not overlooked. They are not intended to represent a "public danger zone." Nor do worst-case scenarios reflect whether processes are safe. Both safe and unsafe processes using the same chemicals at the same quantity will have similar hazards. The objectives of the worst-case scenario are (1) to create an awareness Endpoints The term "endpoint" is frequently used in the RMP Rule. Endpoints are used when facilities and emergency planners perform OCAs to predict areas that may become hazardous if dangerous chemicals are released. For accidents involving flammable chemicals, the distance to endpoint represents the area in which people could be hurt. An explosion could shatter windows and damage buildings, possibly causing injuries because of flying glass or falling debris. Therefore, a flammable endpoint represents a blast wave capable of breaking glass (one pound per square inch of pressure) or radiant heat intense enough to blister human skin. A toxic endpoint defines the outer boundary of a concentration considered hazardous to the community. For accidents involving toxic chemicals, the distance is based on the ability of a victim to escape the area. Most people can be exposed to an endpoint concentration for one hour without suffering irreversible health effects or other symptoms that would make it difficult to escape. People within the distance to endpoint are likely to be exposed to higher concentrations and greater hazards. Individuals exposed to higher concentrations for an extended period may be seriously injured. ------- Worst-Case and Alternative Release Scenario Parameters Factor Event selection Mitigation Toxic endpoint Flammable endpoint Wind speed/atmospheric stability class Outdoor temperature/ humidity Temperature of released substance Surface roughness/nearby obstacles Dense or neutrally buoyant gases Height of release Amount released Toxic gas release rate Toxic liquid releases Distance to endpoint Worst-Case Release Scenario Produces greatest distance to an offsite endpoint Can consider the effect of passive systems that survive the event From Appendix A of RMP Rule Blast wave pressure from the explosion of the vapor cloud 3.4 miles per hour and F class stability, unless higher wind or less stable atmosphere can be shown at all times in last 3 years Highest daily maximum temperature in the prior 3 years and average humidity Liquids, other than gases liquefied by refrigeration, are released at highest outdoor temperature during the prior 3 years or the process tempera- ture, whichever is higher Urban or rural, as appropriate Model accounts for gas density Ground level Greatest possible amount from a single vessel or pipe All in 1 0 minutes • Instantaneous release • Pool area is 1 centimeter deep or size of passive mitigation area • Rate at which it evaporates must be calculated Greatest offsite distance, up to 25 miles Alternative Release Scenario More likely than worst-case scenario based on the 5-year accident history or failures identified in analysis of process hazards Can consider effect of passive and active systems that survive the event From AppendixAof RMP Rule Blast wave from the explosion of the vapor cloud or radiant heat 6.7 miles per hour and D class stability or typical conditions for the site Typical conditions for the site The appropriate process or outdoor temperature Urban or rural, as appropriate Model accounts for gas density Determined by scenario Determined by scenario Determined by scenario Determined by scenario Offsite, if appropriate ------- about potential hazards at the facility and in the community and (2) to motivate a reduction of these hazards. Tim Gablehouse of the Jefferson County, Colo- rado, Local Emergency Planning Committee (LEPC) stressed that the issue of worst- case scenarios should not be the focus of public discussion. Instead, it should lead to an emphasis on emergency response, risk communication, and prevention efforts. The purpose of the RMP is not to generate unnecessary fear, but to educate the public about hazard reduc- tion and emergency response. Local emergency plan- ning organizations can use RMPs to prepare response plans and allocate re- sources. Knowing who is vulnerable saves time and resources when preparing communications strategies; locating equipment; and establishing industry, community, and govern- ment working relationships. Alternative Release Scenarios Based on more likely conditions, alternative release scenarios offer more realistic, useful emergency planning information for the facility and the public. Facilities are given latitude in selecting credible release conditions for these scenarios and can use accident history informa- tion or other knowledge of the process for selecting the hypothetical incident. Questions Reporters Might Ask a Facility Manager What hazardous chemicals do you have at the site that could endanger workers and the community? What quanti- ties are kept onsite? What are their health effects? How many people could be injured in a worst-case release scenario and in a more likely alternative release? What public receptors (e.g., schools, nursing homes, and resi- dences) did you identify? Are local emergency responders capable of handling the number of people that could be injured by such incidents? What environmental receptors (e.g., parks, wildlife sanctuaries, and wetlands) did you identify? What have you done to minimize Y2K and other computer problems that could affect process controls and result in a release? Have you secured your computer systems from outside sabotage? What steps have you taken to ensure site security? To fortify chemical stores? Did you use EPAs methodology to determine your worst- case and alternative scenario distances to endpoint? If not, what method did you use, and why is it better than EPAs? How do the distances compare with the ones based on EPAs guidance? Can you provide a tour of the site to show how you are reducing the likelihood of a release? Can we bring our own experts? How is the facility reducing its hazards? By substituting less hazardous chemicals? By reducing chemical quantities? By improving safety designs and worker/contractor training? How will these hazard reduction initiatives increase safety? Is the facility willing to share its OCAs and process hazard analysis with the community? Do you have an uninhabited buffer zone around the sites borders to protect neighbors? Annotated List of Accident Prevention References and Links References and links to documents or Internet sites should not be construed as an endorsement of the views contained therein. Federal Information EPAs Chemical Emergency Preparedness and Prevention Office http ://www. epa. g ov/ceppo This EPA office maintains a comprehensive Web page that includes chemical accident prevention and risk management planning information. EPA will maintain an online database of all RMPs—in RMP*Info. However, RMP*Info will not contain the OCA data. ------- 1O RMP Off site Consequence Analysis Guidance (http:// www.epa.gov/swercepp/acc-pre.html) is for owners and operators to use when analyzing OGAs. RMP*Gomp™ (http://response.restoration.noaa.gov/chemaids/rmp/ rmp.html) is a software package that performs the calcula- tions described in the BMP Off site Consequence Analysis Guidance. These are available free through the Internet. Another useful EPA publication is General Guidance for Risk Management Programs (http://www.epa.gov/ swercepp/acc-pre.html). Chapter 4 of this guidance specifically addresses OGAs. Chapter 11, Communication with the Public, includes information on how facilities can address public questions about OCAs and hazards. In addition to model RMPs developed by other entities, a section of EPA's Web site for Chemical Accident Preven- tion and Risk Management Planning (http://www.epa.gov/ swercepp/ap-ingu.htm) provides guidance documents regarding model risk management program plans for specific industries. These documents contain chapters that are similar to Chapter 4 of General Guidance for Risk Management Programs, instructing industries how to conduct OCAs for the specific chemicals they typically use. Already available model plans include the following: Q Risk Management Program Guidance for Ammonia Refrigeration Q Risk Management Program for Propane Users and Small Retailers Q Risk Management Program Guidance for Propane Storage Facilities Q Risk Management Program Guidance for Chemical Distributors Q Risk Management Program Guidance for Warehouses Q Risk Management Program Guidance for Wastewater Treatment Plants EPAs Resource Conservation and Recovery Act, Underground Storage Tank, Superfund, and EPCRA Hotline http://www.epa.gov/epaoswer/hotline This site provides information on how to contact the EPA-sponsored Hotline that addresses the Risk Manage- ment Program Rule. Other information resources are also provided. Many related documents, including those listed on the EPA site above, can be ordered by calling (800) 424-9346 or (703) 412-9810 in the Washington, B.C., area. Chemical Safety and Hazard Investigation Board (CSB) http://www. chemsafety gov The Chemical Safety and Hazard Investigation Board Web site has information about incidents investigated by the board, as well as a library of chemical safety docu- ments and information on the year 2000 issue. Background Documents The 600K Report: Commercial Chemical Incidents in the United States, 1987-1 996 http://www.csb.gov/! 999/news/n9916.htm Chemical Safety and Hazard Investigation Board. 1999. The 600KReport: Commercial Chemical Incidents in the United States, 1987-1996. ------- Why the 1 0-Kilometer and 1 -Hour Limits? www. nsc. org/xroads. htm Evans, Mary. 1999. Dr. ALOHA: Why the 10-kilometer and 1-hour limits? CAMEO Today (May/June 1998). The Occupational Environment: Its Evaluation and Control DiNardi, S.R. 1997. The occupational environment: Its evaluation and control. AIAH. Organizational Contacts Chemical Manufacturers Association Contact: James Solyst, Team Leader, Information Management/Right-To-Know Address: Chemical Manufacturers Association 1300 Wilson Boulevard Arlington, VA 22209 Phone: (703)741-5233 E-mail: j im_soly st@mail. cmahq. com U.S. Environmental Protection Agency Contact: Carole Macko, Communications Team Leader, Chemical Emergency Preparedness and Prevention Office Address: U.S. Environmental Protection Agency 401 M Street, SW 5104 Washington, DC 20461 Phone: (202) 260-7938 E-mail: macko.carole@epamail.epa.gov Working Group on Community Right-to-Know Contact: Paul Orum, Coordinator Address: Working Group on Community Right-to-Know 218 D Street, SE Washington, DC 20003 Phone: (202) 544-9586 Web site: www.rtk.net/wcs E-mail: orum@rtk.net Gablehouse & Epel Position: Timothy R. Gablehouse, Attorney and Counselor at Law Address: Gablehouse & Epel 1050 Seventeenth Street, Suite 1730 Denver, CO 80265 Phone: (800) 818-0050 Web site: http://www.gablehouse-epel.com E-mail: Gablehouse@aol.com 44The OCA is the centerpiece of the hazard assessment; it is an estimate of harm to people and the environment beyond the facility's fenceline that can result from a chemical release. 11 Printed on Recycled Paper ------- The Environmental Health Center (EHC) is a division of the National Safety Council, an 85-year-old nonprofit, nongovernmental or- ganization. The National Safety Council is a national leader on accident prevention and home, workplace, auto, and highway safety issues. The National Safety Council established EHC in 1 988 to undertake environmental communications activities aimed at helping society and citizens better understand and act knowledgeably and responsibly in the face of potential environmental health risks. Since that start, EHC has built a strong record of effective, nonpartisan communication on envi- ronmental health risks and challenges. May 1999 ENVIRONMENTAL HEALTH CENTER A Division of the National Safety Council 1025 Connecticut Avenue, NW • Suite 1200 Washington, DC 20036 www.nsc.org/ehc.htm (202) 293-2270 ------- |