-------

        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                 REGION 10
                            1200 Sixth Avenue, Suite 900
                              Seattle, WA 981 01 -31 40
                                  March 2010
U.S. EPA-Region 10
Risk Management Program Training
HAMMER Training Center
Richland, Washington
Welcome RMP Facilities:
We appreciate your investment of time and effort to attend this training. Our objective is
to inform our facilities of changes in registration protocols and to familiarize you with the
tools and requirements of the Risk Management Program.

In case you have further questions regarding the program please refer to the list of
resources below.
Best Regards,

Javier Morales
EPA Region 10
RMP 112r Coordinator
Emergency Response Unit
Office of Environmental Cleanup
(206)553-1255
 morales.javier@epa.gov
Contacts for further information:
   •  Region 10 RMP website:
     http://yosemite.epa.gov/R10/airpage.nsf/Enforcement/rmp
   • EPA Headquarters website:
     http://www.epa.gov/emergencies/content/rmp/index.htm
   • Help line: (800) 424-9346

-------
Region 10 Risk Management Training Manual                                   EPA 910-K-10-001 March 2010

   Risk Management Program Training Manual

   Risk Management Plan	1
     Program Elements	1
     Management System	6
     Five Year Updates and New Reporting Tools for 2010	11
   Hazard Assessment	20
     An analysis of the potential offsite consequences of accidental releases from RMP
     covered facilities	20
     RMP*Comp	21
     LandViewฎ 6 and MARPLOT	22-23
     ALOHA	24
   Prevention Program	31
     Process Safety Information	31
     Process Hazard Analysis	37
     Operating Procedures	47
     Training	53
     Employee Participation	61
     Mechanical Integrity	64
     Management of Change/ Pre-startup Safety Review	69
     Compliance Audits	75
     Hot Work Permit	80
     Contractors	82
     Incident Investigations	86
     Emergency Response	92
     Appendix	98

-------
RMP Program Elements
Program 1
Worse-case release
analysis

5-year accident history

Certify no additional
prevention steps needed











Coordinate with local
responders
Program 2
Worse-case release analysis
Alternative release analysis
5-year accident history
Document management
system
Safety Information
Hazard Review
Operating Procedures
Training
Maintenance
Incident Investigations
Compliance Audit





Develop plan and program
(if applicable) and coordinate
with local responders
Program 3
Worse-case release analysis
Alternative release analysis
5-year accident history
Document management
system
Safety Information
Hazard Review
Operating Procedures
Training
Maintenance
Incident Investigations
Compliance Audit
Management of Change
Pre-Startup Review
Contractors
Employee Participation
Hot Work Permits
Develop plan and program
(if applicable) and coordinate
with local responders
Submit one Risk Management Plan for All Covered Processes

-------
R10 Risk Management Training Manual
                                                                         EPA 910-K-10-001
                                                                                           March 2010
   Risk Management Program
                Training
              March 9-11,2010
              HAMMER Facility
           Richland, Washington
 Training Objectives
 Smoke billows from heavily damaged Formosa
 Plastics plant following April 23 explosion. Photo:
 Kevin German/The State Journal-Register. (CSB)
                         Understand the mission
                         of the Risk Management
                         Program and your
                         facility's safety culture
                         Understand common
                         deficiencies identified
                         from inspections
                         Understand the elements
                         required under the Risk
                         Management Program
 Purpose of Risk Management Program
                        Prevent or minimize
                        the consequences of
                        catastrophic releases
                        of toxic, reactive,
                        flammable, or
                        explosive chemicals

-------
R10 Risk Management Training Manual
                                                                                          EPA 910-K-10-001    March 2010
  Importance  of Safety Culture
   March 2005, Texas City, Texas oil
   refinery explosion.
J  The UK Health & Safety
•  Executive defines safely
—  culture as "... the product
   of the individual and
   group values, attitudes,
   competencies and patterns
   of behavior that determine
   the commitment to, and
   the style and proficiency
   of, an organization's health
   and safely programs."
  Program  Eligibility
     n Stationary Source in
       a Single Process
     n Listed of Regulated
       Substance
     n Threshold Quantities
        • 63 Flammables
        • 77 Toxic
          Substances
List of Lists at:  http://vosemite.epa.gov/oswer/lol.nsf/homepage
  Program Level
Program 1
   • No history of offsite accidents
   • No public receptors
   • ER coordinated w/ local emergency organizations
   • Industries subject to OSHA Process Safety Management
   • Complex processes -NH3 refrigeration, refineries, pulp &
   paper mills, fertilizer manufactures, industrial gas
   manufacturing, Water Treatment Plants/Wastewater
   Treatment Plants
Program 2
   • Not eligible for Program 1 or 3
   • Bulk storage and distribution of chemicals, fertilizer
   wholesalers, frozen and dehydrated food manufactures

-------
R10 Risk Management Training Manual
                                                                           EPA 910-K-10-001
                                                                                             March 2010
  Program Universe
         Region 10 -479 covered facilities

                31
                                         nwA
                                         DOR
                                         • ID
                                          AK
  Program Universe
  400 -I  359
  350 -
  300 -
  250 -
  200 -
  150 -
  100 -
   50 -
   0
# of Hazardous Chemical Facilities
74
      24
             15
                          12
  Exemptions to Program

  • Farmers using ammonia fertilizer
  • Flammable substances used as fuel or held for
   sale as a fuel at a retail facility
  • Chemicals in transportation, including storage
   incident to transportation
  • Naturally occurring hydrocarbon  mixtures prior
   to entering a processing plant
  • Laboratory chemicals

-------
R10 Risk Management Training Manual
                                                                                 EPA 910-K-10-001
                                                                                                     March 2010
  General Duty Clause
                        Section 112(r)(1)-

                        "General duty to identify,
                        prevent the release of
                        extremely hazardous
                        substances, and minimize
                        consequences, if a
                        release were to occur."
  Content of Program
  Hazard Assessment - The potential worst-case
  and more probable accidental release
  scenario. 5 yr accident history.

  Prevention Program - Safety information,
  hazard review/analysis, operating procedures,
  mechanical integrity/maintenance, employee
  training.

  Emergency Response - Emergency response
  plan or program, employee training,
  procedures for informing the public and local
  responders.

-------
R10 Risk Management Training Manual                                    EPA 910-K-10-001    March 2010
   Management System
   Common Deficiencies:
          •   A company organizational chart that does not address the RMP elements
          •   Failure to document other persons responsible for implementing individual
             requirements of the risk management program and
          •   Failure to define the lines of authority through an organization chart or similar
             document

   REQUIREMENTS

   If you have a Program 2 or Program 3 process the management system provision
   requires you to:
      •   Develop a management system to oversee the implementation of the risk
          management program elements;
      •   Designate a qualified person or position with the overall responsibility for the
          development, implementation, and integration of the risk management program
          elements; and
      •   Document the names of people or positions and define the lines of authority
          through an organizational chart or other similar document, if you assign
          responsibility for implementing individual requirements of the risk management
          program to people or positions other than the person or position with overall
          responsibility for the risk management program.

   HOW TO MEET THE MANAGEMENT SYSTEM REQUIREMENTS

   Sources covered by this rule are diverse, so you are in the best position to decide how to
   appropriately implement the risk management program elements at your facility.
   Therefore, the rule provides considerable flexibility in complying with its program
   requirements.

   WHAT DOES THIS MEAN FOR ME AS A SMALL FACILITY?

   Identification of a qualified individual or position with overall responsibility may be all you
   need to do if the person or position named directly oversees the employees operating
   and maintaining the processes. You must define the lines of authority with an
   organizational chart or similar document only if you choose to assign responsibility for
   specific elements of the risk management program to persons or positions other than the
   person with overall responsibility. For a small facility, with few employees, it is likely that
   you will meet the requirements of this provision by identifying the one person or position
   with the overall responsibility of implementing the risk management program elements. If
   this is the case, you need not develop an organizational chart.

-------
R10 Risk Management Training Manual
                                                              EPA 910-K-10-001   March 2010
   WHAT DOES THIS MEAN FOR ME AS A MEDIUM OR LARGE FACILITY?

   As a medium or large facility you may have more personnel turnover than smaller sites.
   For this reason, it may make more sense at your facility to identify a position, rather than
   the name of the specific person, with overall responsibility for the risk management
   program elements.
   As a relatively large or complex facility, you may choose to identify several people or
   positions to supervise the implementation of the various elements of the program;
   therefore, you must define the lines of authority through an organizational chart or similar
   document.

   Defining the lines of authority and roles and responsibilities of staff that oversee the risk
   management program elements will help to:

       •  Ensure effective communication about process changes between divisions;
       •  Clarify the roles and responsibilities related to process safety issues at your
         facility;
       •  Avoid problems or conflicts among the various people responsible for
         implementing elements of the risk management program;
       •  Avoid confusion and allow those responsible for implementation to work together
         as a team; and
       •  Ensure that the program elements are integrated into an ongoing approach to
         identifying hazards and managing risks.

   Remember that all of the positions you identify in your documentation will report their
   progress to the person with overall responsibility for the program. However, nothing in
   the risk management program rule prohibits you from satisfying the management
   provision by assigning process safety committees with management responsibility,
   provided that an organizational chart or similar document identifies the names or
   positions and lines of authority.

   MANAGEMENT DOCUMENTATION SAMPLE
Risk Management Program Element
Overall responsibility - RMProgam
Manager
Hazard Review
Safety Information
Operating Procedures
Training
Maintenance
Incident Investigation
Emergency Planning and Response
24-Hour Emergency Contact
Compliance Safety Audits
RMP Plan Updates (5-year and
changes)
Responsible Employee(s)
(Specific names or positions)











-------
     R10 Risk Management Training Manual
                                                                     EPA 910-K-10-001    March 2010
MANAGEMENT RESPONSIBILITIES FOR RMP/PSM - Program 3
Elements of RMP/PSM
1) Management System:
Responsible Parties
A) President/CEO/Operations Manager, etc - Overall Responsibility for the
development, implementation and integration of the risk management program
elements.
Each Section Below Reports to the above (President/CEO/Operations Manager, etc.)
2) Employee
Participation
3) Process Safety
Information:
4) Process Hazard
Analysis:
5) Operating
Procedures:
6) Lockout/Tagout:
7) Site Security:
8) Line Opening/Process
Equipment:
9) Training:
10) Mechanical
Integrity:
11) Preventative
Maintenance:
12) Management of
Change ^
13)Pre-Startup Safety
Review ^
14) Compliance Audits:
15) Incident
Investigations
: 16) Hot Work, Permits
17) Contractors:
18) Emergency Action
Program ^
19) Trade Secrets
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
D) Training Coordinator ,^r
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C)
Refrigeration Engineers D) Safety Mgr. ^^^. ^
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C)
Maintenance Foreman D) Safety Mgr.
A) President/CEO B) Security Mgr. C) Maintenance and Refrigeration Mgr. D)
Plant Managers
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
D) Training Coordinator
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman , C) Safety
Mgr. ^
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C) Plant
Managers D) Safety Mgr.
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C)
Maintenance Foreman D) Safety Mgr
A) Maintenance and Refrigeration Mgr. B) Engineering Foreman C)
Maintenance Foreman D) Purchasing Agent
A) President/CEO B) Safety Mgr.
Not applicable
Date Last Revised:

-------
R10 Risk Management Training Manual
                                                                        EPA 910-K-10-001    March 2010
 Management System

 • Required for Program Level 2 & 3 facilities

 • Must be documented
 • Must describe who is ultimately in-charge and
   those authorized to make decisions and
   implement the plan
 Overall responsibility
   Assign a qualified
     person or position
     that has the overall
     responsibility for the
     development,
     implementation, and
     integration of the
     Risk Management
     Program elements
 If you are a small facility
 One individual may be
   adequate to oversee
   the:
   Development
   Implementation
   Integration of the RMP
   elements

-------
R10 Risk Management Training Manual
                                                                      EPA 910-K-10-001
                                                                                       March 2010
 If you are a large facility
   , Document all
     individuals
     responsible for
     implementing
     individual RMP
     requirements and
     defined the lines of
     authority through
     an organization
     chart or similar
     document
 Identify the lines of authority

 Example: Training -shared responsibility
 • Maintenance Manager
 • Engineering Foreman
 • Safety Mgr.
 • Training Coordinator


 Group Reports to Plant Manager
 Management
 Common Deficiencies
 • A company organizational chart that does not
   address the RMP elements
 • Failure to document other persons
   responsible for implementing individual
   requirements of the risk management
   program
 • Failure to define the lines of authority through
   an organization chart or similar document
                                               10

-------
R10 Risk Management Training Manual
                                                         EPA 910-K-10-001   March 2010
   Five Year Updates and New Reporting Tools

   Five-Year Updates
   All facilities with a current Risk Management Plan (RMP) must completely update
   all nine sections of their RMP at least once every 5 years from the initial
   submission or most recent update (even if no changes occur). [40 CFR
   ง68.190(b)(1) of the Clean Air Act].

   Your five-year anniversary date is listed in the notification letter which was sent to
   you after you submitted your last RMP. You can also find your anniversary date
   in the Registration Section of the hard copy of your RMP and online in the
   Registration Section of RMP*WebRC (a web based tool for minor
   corrections/updates).

   RMP*eSubmit: New web-based tool designed for complete RMP
   submissions
   You will use RMP*eSubmit, an online reporting tool which simplifies the
   submission process. EPA uses industry-standard technology, including
   encryption used by most commercial banks, as well as stringent user ID and
   password protocols to protect your information.

   You will be able to access your entire RMP online at anytime (Fig. 1). In addition
   to updating your facility's RMP at least every five years or when other specified
   update circumstances occur, RMP*eSubmit allows  you to perform other recurring
   activities to ensure that your risk management program is current. These
   activities include, among other things, providing employee refresher training,
   performing compliance audits, and updating your safety information, hazard
   review (or process hazards analysis), operating procedures, and offsite
   consequence analysis.
       Preparer
                      1. RMP Entered
                                           4. Update
        Certifier
2. Notification and
  Copy of Record
                               3. Approval and
                                 Submission
                                         5. Confirmation
                                         Figure 1:
                                         How the RMP
                                         Submission
                                         Process Will
                                         Work
                                      11

-------
R10 Risk Management Training Manual
                                                          EPA 910-K-10-001   March 2010
   Why has EPA developed RMP*eSubmit?

   The web-based RMP*eSubmit tool offers many advantages (Fig.2), including, but
   not limited to:
      •  Online (24/7) access to your RMP,
      •  Ability to review, submit, correct, update and validate all sections of your
         RMP at a secure website (http://www.epa.gov/cdx/, CDX),
      •  A one-time only, mailed in, Electronic Signature Agreement with all
         subsequent transactions online via the CDX website, and
      •  The ability of a facility's certifier to designate a "Preparer" who will be able
         to prepare, correct and/or update one or more RMPs and transmit them to
         the facility for review and approval. Note that only the facility's certifying
         official can submit the RMP(s) to EPA
                                                EPA's Firewall
n^r^
      What about the
     certification letter?
                  Replaced by a one-
                   time Electronic
                 Signature Agreement
    RMP
   Database
                                                            Figure 2:
                                                            RMP*eSubmit -
                                                            RMP Submission
                                                            via the Internet
                                       12

-------
                Updates & Required Corrections
                     Risk Management Plan
   Updates [ง68.190]
   •   Changes that typically require updating information in more than one
      section of the RMP
Change That Occurs
No changes occur
A newly regulated substance is first
listed by EPA
A regulated substance first becomes
present above its threshold quantity in: -
-a process already covered; or --a new
process
A change occurs at your facility that
requires a revised PHA or hazard review
A change occurs at or near your facility
that requires a revised offsite
consequence analysis (e.g., you
increase your inventory of a regulated
substance such that it increases the
distance to the endpoint by a factor of 2
or more, or a new public receptor is
constructed near your facility)
A change occurs that alters the Program
level that previously applied to any
covered process
Date by Which You Must Update your RMP
At least once every 5 years from its initial
submission or most recent update
Within 3 years of the date EPA listed the newly
regulated substance if your facility has more than
a threshold quantity of that substance in a
process
On or before the date the quantity of the
regulated substance exceeds the threshold in the
process
Within 6 months of the change
Within 6 months of the change
Within 6 months of the change
         De-registration is a special type of "Update"
Change That Occurs
A change occurs that makes the facility
no longer subject to the requirement to
submit an RMP
Date by Which You Must De-register your RMP
Submit a de-registration letter indicating that the
RMP is no longer required to EPA within 6
months of the change
To De-register:
Submit a letter to the RMP Reporting Center within six months and include the
effective date of the de-registration (the date on which you facility was no longer
covered by Part 68). The letter should be signed by the owner or operator.
Include your RMP ID number (the 12-digit EPA ID number).
                                 13

-------
                Updates & Required Corrections
                      Risk Management Plan
  Required Corrections [ง 68.195]
     •   Changes are usually limited to one section of the RMP
       Change That Occurs
 Date by Which You Must Correct your RMP
An accidental release meeting the
reporting criteria of ง 68.42 occurs at
your facility
Add to and correct accident history information
and incident investigation data elements within
6 months of the date of the accident

Revising other RMP sections is not required
unless facility changes resulting from an accident
trigger a full update	
Facility emergency contact information
changes
Correct the emergency contact information in
RMP within one month of the change

Revising other RMP elements not required). This
correction can be done via the Internet
Minor administrative change (i.e.,
correct a clerical error or supply
additional information)
Correct the information as soon as practicable
(revising other RMP elements is not required).
This correction can be done via the Internet
                                   14

-------
R10 Risk Management Training Manual
                                                                  EPA 910-K-10-001   March 2010
          RMP*eSubmit

   EPA's initiative for Internet-based
           RMP Submissions
             The First Year
                Topics
    RMP*eSubmit Overview
    Schedule
    Publications
    Registration Process
    RMP Data Entry & Submission Process
    • Common Problems
    The First Year - Region 10's Experience
   EPA's initiative for web-based RMP submissions
         Old System:  RMP*Submit
                                            15

-------
R10 Risk Management Training Manual
                                                                                                   EPA 910-K-10-001     March 2010
     EPA's initiative for web-based  RMP submissions
             Disadvantages of RMP*Submit

          Limited validation
          Facilities often lose their last submission
          Heavy processing load with manual steps
          Cumbersome mail back notification and resubmission cycle
          New Certification Letter required for each submission
          Security issue: mailing of sensitive data
     EPA's initiative for web-based  RMP submissions
              New system:  RMP*eSubmit
                   RMP Submission via the Internet
    What about the
   certification letter?
                  Replaced by a one-
                   time Electronic
                 Signature Agreement
     EPA's initiative for web-based  RMP submissions
             Central Data Exchange (CDX)


     • EPA's secure portal for entering and retrieving information

     • Many other data systems currently using CDX:
         > AQS, eBeaches, elUR, LEAD, NEI, NESHAFS, PMN, RCRA, SDWIS, TRI-
           ME, TSCA, UCMR2, RMP*WebRC
     • Facilities use CDX to gain access to RMP*eSubmit

     • Facilities can use their existing CDX account if they have one
                                                                  16

-------
R10 Risk Management Training Manual
                                                                                  EPA 910-K-10-001
                                                                                                      March 2010
    EPA's initiative for web-based RMP submissions
    How the Electronic Signature Process Works
          Facility
        1. Owner/Operator
          obtains Login
          ID & Password
                   Schedule
    RMP*eSubmit Activated
    . March 2009
    Removed RMP*Submit from website
    • June 2009
    No longer accept submissions from  RMP*Submit
    • January 2010
                 Publications
    See www.epa.gov/emergencies/rmp:
    • A Checklist for Submitting Your Risk Management
      Plan (RMP) for Chemical Accident Prevention
    • RMP*eSubmit User's Manual
    . RMP Fact Sheet
    • The General Duty Clause Fact Sheet
    • Chemical Emergency Preparedness and Prevention in
      Indian Country
    • Updated RMP technical guidance documents (General
      guidance, industry sector guidance, OCA guidance)
                                                       17

-------
R10 Risk Management Training Manual
                                                                                                         EPA 910-K-10-001
                                                                                                                                  March 2010
            RMP*eSubmit User's Manual
         RISK MANAGEMENT PLAN
     RMP'eSusMiT USERS' MANUAL
         Users' Manual for
          RMP'eSubmit
               "How To" Guide
       Updated September 2O(&
         Basic Steps to set up RMP'eSubmit access for a facility
                      CDX Registration Process
                         Common Problems
                    RMP'eSubmit User's Manual
                       Chapter 1 Getting Started
      Certifying official sets up CDX account & registers for RMP*eSubmit
       - Add Program: "Risk Management Plan (RMPESUBMIT)"
       - Add Role/Program ID: "certifying official"
      Certifying official completes Electronic Signature Agreement (ESA) via
      online form
       - ESA includes list of facilities belonging to the certifier
       - Certifying official  prints and signs the ESA
       - Certifying official  mails ESA to the RMP Reporting Center
      RC validates the ESA, sets up database access & emails certifying
      official an authorization code for a preparer
      Preparer sets up their own CDX account
       - Add Role: "preparer" (using authorization code obtained from
          certifying official)  "Preparer" doesn't receive the code.
         Basic Steps to set up RMP'eSubmit access for a facility

                          RMP Data Entry

                    RMP'eSubmit User's Manual
        Chapter 2 Entering Data (First-Time, Corrections, Resubmissions)
     5.  Preparer enters RMP data for facility
                      RMP Submission Process
                     RMP'eSubmit User's Manual
                   Chapters How to Submit Your RMP
     6.   Certifying official: Approval, Certification and Submittal of the RMP
     	Certifying Official Doesn't Submit the RMP.	
                                                                      18

-------
R10 Risk Management Training Manual
                                                                              EPA 910-K-10-001    March 2010
           Common Problems
         Step 3. Approval and Submission
      Region 10 - The First Year
           Five-Year Updates in R-10
   All facilities must
   completely update all
   nine sections of their RMP
   at least once every 5
   years, even if no changes
   occur.
   Current/Registered
   Facilities:  479
    . 289 Updates (2009)
    • Late re-submissions: 41
EPA Region 10
2009 RMP Resubmissions: 5 Year Updates
X 300
o. of Facilit



1
1 2 3 4 5 6 7 8 9 10 11 12
Month
         Where Do I Go  For More
                Information?
   EPA RMP Website:
    • http ://www.epa .gov/emergencies/rmp
   EPA Listservs:
    • https://lists.epa.gov/read/all forums/subscribe?name=ca
      llcenter oswer
   EPA Region 10 RMP Website:
    . http://vosemite.epa.gov/R10/CLEANUP.NSF/sites/rmp
   EPA Region 10 CEPP Newsletter
   EPA Region 10 RMP Coordinator:
   Javier Morales,  206-553-1255
                                                     19

-------
R10 Risk Management Training Manual                                     EPA 910-K-10-001    March 2010
   Hazard Assessment

   An analysis of the potential offsite consequences of accidental releases from
   RMP covered facilities

   If you are RMP covered facility, you are required to conduct an offsite consequence
   analysis to provide information to the state, local, and federal governments and the
   public about the potential consequences of an accidental chemical release. The offsite
   consequence analysis consists of two elements:

       •   A worst-case release scenario, and
       •   Alternative release scenarios.

   To simplify the analysis and ensure comparability, EPA has defined the worst-case
   scenario as the release of the largest quantity of a regulated substance from a single
   vessel or process line failure that results in the greatest distance to an endpoint. In broad
   terms, the distance to the endpoint is the distance a toxic vapor cloud, heat from a fire,
   or blast waves from an explosion will travel before dissipating to the point that serious
   injuries from short-term exposures will  no longer occur.

   Alternative release scenarios are scenarios that are more likely to occur than the worst-
   case scenario and that will reach an endpoint offsite, unless no such scenario exists.

   You may use  EPA's RMP  Offsite Consequence Analysis Guidance (tables) to carry out
   your consequence analysis. EPA's guidance  is optional, and you are free to use other air
   dispersion models, fire or explosion models, or computation methods provided that:

       1.  They are publicly or commercially available or are proprietary models that you
          are willing to share with the implementing agency;
       2.  They are recognized by industry as applicable to current practices;
       3.  They are appropriate for the chemicals and conditions being modeled;
       4.  You use the applicable definitions of worst-case scenarios; and
       5.  You use the applicable parameters specified in the rule.

   In addition to  EPA's RMP Offsite Consequence Analysis Guidance (tables), air
   dispersion/ fire or explosion models such as RMP*COMP, ALOHA and DEGADIS are
   commonly used.
                                          20

-------
R10 Risk Management Training Manual                                 EPA 910-K-10-001   March 2010
   RMP*Comp

   RMP*Comp is a free program you can use to complete the offsite consequence
   analyses (both worst case scenarios and alternative scenarios) required under
   the Risk Management Program rule. When you use RMP*Comp, you don't need
   to make any calculations by hand and the program guides you through the
   process of making an analysis.

   The RMP*Comp program steps users through a short list of questions about the
   CAA regulated chemical (such as the amount released) in the offsite
   consequence analysis-both worst-case and alternative scenarios can be run.
   Based on entered information, RMP*Comp estimates the distance to endpoint
   according to EPA's recommended procedures. The facilities can then enter the
   RMP*Comp values into their final RMP plan.

   About RMP*Comp, Version 1.07:

   The current version is RMP*Comp 1.07. This version was posted on October 29,
   2001. It corrects bugs found in previous versions and modifies some
   functionality. If you have been using an earlier version, you should Download
   RMP*Comp, Version 1.07. Because the recommended RMP consequence
   analysis procedures may change in  the future, please check this web page
   before you begin a consequence analysis to be sure that you are using the latest
   version of RMP*Comp.

         •  To download the RMP*Comp program, or to get more information
            about RMP*Comp, go to the EPA Emergency Management webpage
            at: http://www.epa.gov/emergencies/tools.htm
                                     21

-------
R10 Risk Management Training Manual                                 EPA 910-K-10-001  March 2010
   LandViewฎ 6

         •   For Risk Management Plan reporters who need to obtain the latitude
            and longitude of their facilities.
         •   Download from the EPA Emergency Management webpage at:
            http://www.epa.gov/emergencies/tools.htm

   The LandView 6 and MARPLOTฎ software were created by agencies of the U.S.
   Government and are in the public domain. They can be copied, used and
   distributed freely without the requirement for royalty payments or further
   permissions. However, the Census Bureau cannot provide technical support for
   products created by others using LandView.

   The LandView database software:

         • Uses  the Population Estimator function to calculate Census 2000
            demographic and housing characteristics for user defined radii.
         • Creates  simple thematic maps of Census 2000 data.
         •   Allows users to browse and query the Census, EPA or USGS
            databases and show the query results on the map.
         •   Provides the capability to locate a street address or intersection on a
            map based on TIGER/Lineฎ 2000 road features and address ranges.
         •   Can automatically retrieve LandView database information for user
            selected map objects.

   Released January 20,  2004. LandView 6 updates the Census 2000 statistical
   data as well as the Environmental Protection Agency (EPA) and U.S. Geological
   Survey (USGS) databases contained in LandView 5 that was released  in
   November, 2002. If all you need to do is prepare  EPA Risk Management Plans,
   then there is no need to upgrade from LandView 5 to LandView 6.

   Source: U.S. Census Bureau Geography Division
                                     22

-------
R10 Risk Management Training Manual                                  EPA 910-K-10-001   March 2010
   MARPLOT

         Mapping Applications for Response, Planning, and Local
         Operational Tasks

   An updated version of the MARPLOT mapping program is now available. The
   updated program is part of the CAMEO software suite, created for hazmat
   responders and planners by OR&R in collaboration with EPA. The program is
   available at no cost.

   MARPLOT may be used to fulfill the requirements of 40 CFR Part 68.30
   "Defining offsite impacts—population." The application can:

      •  Estimate (in the RMP) the population within a circle with its center at the
         point of the release and a radius determined by the distance to the
         endpoint defined  in 68.22(a).
      •  The population shall include residential population. The presence of
         institutions (schools, hospitals, prisons), parks and recreational areas, and
         major commercial, office, and industrial buildings shall be noted in the
         RMP. [68.22(b)]
      •  You can create and document maps of the worst case/alternative release
         scenarios. In addition, you can document the population estimates within
         the threat zones.  [68.39(e)].

   Working in MARPLOT'S easy-to-use CIS interface, you can switch between three
   base maps: standard map files, high-resolution aerial photos, and topographical
   maps. You can get population estimates inside selected areas and can
   customize  maps using drawing tools and an extensive symbol set.

   MARPLOT 4.1.1 incorporates web-mapping services and supports the use of
   shapefiles  and a variety of raster formats. You'll be able to click on a location of
   interest to get its elevation and an instant weather forecast, and you can work
   with Landview-like population functions. As you work with the new version, the
   latest U.S.  Census county maps, and state and national map layers will
   automatically download.

   For full details and to download the free application, go to MARPLOT web-page:
   http://www.epa.gov/emergencies/content/cameo/marplot.htm
                                      23

-------
R10 Risk Management Training Manual                                  EPA 910-K-10-001   March 2010
   ALOHA

   Areal Locations of Hazardous Atmospheres

   Part of the CAMEO suite, ALOHAฎ is an atmospheric dispersion model used for
   evaluating releases of hazardous chemical vapors. ALOHA allows the user to
   estimate the downwind dispersion of a chemical cloud based on the
   toxicological/physical characteristics of the released chemical, atmospheric
   conditions, and specific circumstances of the release. Graphical outputs include
   a "cloud footprint" that can be plotted on maps with MARPLOT to display the
   location of other facilities storing hazardous materials and vulnerable locations,
   such as hospitals and schools.

   Specific information about these locations can be extracted from CAMEO
   information modules to help make decisions about the degree of hazard posed.
   Key Program Features

         •   Generates a  variety of scenario-specific output, including threat zone
            plots, threat at specific  locations, and source strength  graphs.
         •   Calculates the rate of release for chemicals escaping from tanks,
            puddles (on both land and water), and gas pipelines and predicts how
            that release rate changes over time.
         •   Models many release scenarios: toxic gas clouds, BLEVEs (Boiling
            Liquid Expanding Vapor Explosions), jet fires, vapor cloud explosions,
            and pool fires.
         •   Evaluates different types of hazard (depending on the release
            scenario): toxicity, flammability, thermal radiation, and overpressure.
         •   Displays threat zones on MARPLOT maps (and on ArcView and
            ArcMap with  the Arc Tool extensions).
         •   Works seamlessly with companion programs CAMEO Chemicals and
            MARPLOT; it can also be used as a standalone program.
   For more information, see Downloading, Installing, and Running ALOHA.
   http://www.epa.gov/oem/content/cameo/aloha.htm
                                      24

-------
R10 Risk Management Training Manual
                                                                                      EPA 910-K-10-001
                                                                                                           March 2010
               Hazard Assessment
         Predicting Potential Impacts to the Community
       Offsite Consequences Analysis
          Common Inspection Deficiencies Highlighted
    Agenda
    — Types of Scenarios
    — Definitions
    - Required Scenarios &
      Parameters
    — Release Mitigation
    — Modeling
    - Offsite Impacts Receptors
    - OCA Documentation

   )rch2010               EPA Region 10
                Types of Scenarios
    Worst-case release
    scenarios

    - Based on conservative
      assumptions
    - Represent a very
      severe accident that is
      unlikely to occur
Alternative release
scenarios

 - Based on more
   realistic assumptions
 - More likely to occur
                                                          25

-------
R10 Risk Management Training Manual
                                                                                                            EPA 910-K-10-001
                                                                                                                                      March 2010
                          Definitions

     Offsite: Areas beyond the property boundary of the stationary source,
     and areas within the property boundary to which the public has
     routine and unrestricted access during or outside of business
     hours
     Worst-case Release Scenario: The release of the largest quantity of a
     regulated substance from a vessel or process line failure that results
     in the greatest distance to an endpoint
      -  Does not depend on Program Level
     Alternative Release Scenario: Scenarios that are more likely to occur
     than the worst case scenario and that will reach an endpoint offsite,
     unless no such scenario exists
      -  Should consider the 5-year release history and failure scenarios identified in
         the PHA or Hazard Review
     Public Receptors: Public Receptors: Offsite areas such as residences,
     schools, office buildings, and parks where members of the public could
     be exposed
             Required OCA Scenarios
                       Common Deficiencies
     For Each Program 1 Process
      - One worst-case scenario for each Program 1
        process
         • Wo public receptors in worst-case scenario zone and
         • No accidents with OFF-Site consequences in last five
           years
      - No alternative scenarios are required
         Required OCA Scenarios (cont'd)
                       Common Deficiencies

     For All Program 2 and 3 Processes
     - One worst-case scenario for all toxics
     - One worst-case scenario for all flammables
     - Additional worst-case scenarios if different public receptors
       could be affected
         •  Public Receptors: Offsite areas such as residences, schools,
           office buildings, and parks where members of the public
           could be exposed
     - At least one alternative scenario for each toxic
     - At least one alternative scenario for all flammables
                                                                        26

-------
R10 Risk Management Training Manual
                                                                                                          EPA 910-K-10-001
                                                                                                                                    March 2010
                  Release  Mitigation
                       Common Deficiencies
    Activities or equipment designed to contain released substances to
    minimize exposure
    Passive mitigation
     -  Function without human, mechanical, or other energy input
     -  Can use in worst-case and alternative release scenario analyses if
        capable of withstanding release event
     -  Examples include building enclosures, dikes, and blast walls
    Active mitigation
     -  Need human, mechanical, or other energy input to function
     -  Can be considered only in alternative release scenario analyses, must
        be capable of withstanding release event
     -  Examples include interlocks, shutdown systems, pressure relieving
        devices, flares,  emergency isolation systems, etc.
                 Effectiveness of Building Mitigation
                  for Alternative Release Scenarios
                Modeling OCA Scenarios
                                                                       27

-------
R10 Risk Management Training Manual
                                                                                            EPA 910-K-10-001
                                                                                                                   March 2010
        Calculating Release Scenarios


    Methods to calculate release scenarios:
     - EPA
        • RMP *Comp - Computer software, easy to use, need basic
         data parameters (volume, size of container)
        • EPA tables - EPA guidance documents
     - Industry specific guidance
        • TFI [myRMP]
     - Other Models - Such as /Area/ Locations of Hazardous
       Atmospheres (ALOHAฎ), DEGADIS
            Offsite Consequence Parameters
                       Common Deficiencies
                       '  Offsite consequence analysis
                         must include:
                          - Toxics
                             • Toxic end points
                          - Flammables
                             • Overpressure, Radiant
                              heat, Concentration -
                              lower flammability limit
                          - Must also consider:
                             • Wind speed, stability
                              class, ambient
                              temperature, height of
                              release, and topography,
                              Liquid or gas release
              OCA Release Calculations
                    Common Deficiencies
    Determine Distance
    to Endpoint (DTEP)
     - Air dispersion models
        • Based on Human
         Health Impacts within
         the area of a circle (of
         radius DTEP)
     - Common Models
        • RMP'COMP (EPA)
        • ALOHA
        • DEGADIS (TFI)
Define Off-Site Impacts
 -  Public Receptors
       - Residential
        Population Estimate
        (Number)
       - Institutions, . . . major
        commercial, office . ..
        buildings (Presence)
    • Most recent Census data
     (LandView/Marplot) or
     "other updated
     information"
 -  Environment
    • National/State Parks etc.
    • Local U.S.G.S maps
     and/or Landview
                                                              28

-------
R10 Risk Management Training Manual
                                                                                                   EPA 910-K-10-001
                                                                                                                           March 2010
             Distance To End  Points
                 Common Deficiencies

    Wrong modeling Input for endpoint calculations
     - Incorrect use of Passive Mitigation
     - Incorrect use of "Rural" vs. "Urban" topography
     - Hazard review information not considered for the alternative release
       scenario
    Defining off site impacts on population
     - Did not use or misused the "circle" map when defining the off-site
       impacts
    Did not use most recent census data or provide "other updated
    information"
     - Did not identify environmental receptors within the circle
     - Did not use USGS data to identify environmental receptors
    Used old data for the update
     - Incorrect quantities, physical locations etc.
    Did not maintain the documentation for all of the calculations,
    estimates, etc
     - Dated,  detailed documentation
         The Most Common Deficiency


    Documentation Missing

     -Worst-case scenario ง 68.39(a)
        • Description of the vessel or pipeline and
          substance selected as worst case, assumptions
          and parameters used, and the rationale for
          selection; assumptions shall include use of any
          administrative controls and any passive mitigation
          that were assumed to limit the quantity that could
          be released. Documentation shall include the
          anticipated effect of the controls and mitigation on
          the release quantity and rate.

     -Alternative scenario ง 68.39(b)
                                                                  29

-------
R10 Risk Management Training Manual
                                                                                   EPA 910-K-10-001     March 2010
         Review and Documentation
                 Common Deficiencies

                           Offsite consequence
                           analysis
                            - review and update the
                              offsite consequence
                              analyses at least once
                              every 5 years, or
                            - Within 6 months of any
                              process change that
                              could increase or
                              decrease the DTEP 2X
          Five-year accident history
                  Common Deficiencies

   An Accident is Reportable .  . . if the release:

    - Onsite Deaths, injuries or property damage.

    -  [Known] Offsite Deaths, injuries, property damage,
      or environmental damage,  evacuations, or sheltering-
      in-place.

   Requires corrections to the RMP within 6
   months.  {ง 68.195 Required Corrections}
       • Includes data required under งง 68.168, 68.170(j) [Prgm 2],
        and68.175(l)[Prgm3]
                                                        30

-------
R10 Risk Management Training Manual                                     EPA 910-K-10-001   March 2010
   Prevention Program

   Process Safety Information

   Complete and accurate written information concerning process chemicals, process
   technology, and process equipment is essential to an effective process safety
   management program and to a process hazards analysis. The compiled information will
   be a necessary resource to a variety of users including the team that will perform the
   process hazards analysis; those developing the training programs and the operating
   procedures; contractors whose employees will be working with the process; those
   conducting the pre-startup reviews; local emergency preparedness planners; and
   insurance and enforcement officials.

   The information to be compiled about the chemicals, including process intermediates,
   needs to be comprehensive enough for an accurate assessment of the fire and
   explosion characteristics, reactivity hazards, the safety and health hazards to workers,
   and the corrosion and erosion effects on the process equipment and monitoring tools.
   Current material safety data sheet (MSDS) information can be used to help meet this
   requirement, which must be supplemented with process chemistry information including
   runaway reaction and over pressure hazards if applicable.

   Process technology information will be a part of the process safety information package
   and it is expected that it will include diagrams as well as employer established criteria for
   maximum inventory levels for process chemicals; limits beyond which would be
   considered upset conditions; and a qualitative estimate of the consequences or results
   of deviation that could occur if operating beyond the established process limits.
   Employers are encouraged to use diagrams which will help users understand the
   process.

   A block flow diagram is used to show the major process equipment and interconnecting
   process flow lines and show flow rates, stream composition, temperatures, and
   pressures when necessary for  clarity. The block flow diagram is a  simplified diagram.

   Process flow diagrams are more complex and will show all main flow streams including
   valves to enhance the understanding of the process, as well as pressures and
   temperatures on all feed and product lines within all major vessels, in and  out of headers
   and heat exchangers, and points of pressure and temperature control. Also, materials of
   construction information, pump capacities and pressure heads, compressor horsepower
   and vessel design pressures and temperatures are shown when necessary for clarity. In
   addition, major components of control loops are usually shown along with  key utilities on
   process flow diagrams.

   Piping and instrument diagrams (P&IDS) may be the more appropriate type of diagrams
   to show some of the above details and to display the information for the piping designer
   and engineering staff. The P&IDS are to be used to describe the relationships between
   equipment and instrumentation as well as other relevant information that will enhance
   clarity. Computer software programs which do P&IDS or other diagrams useful to the
   information package, may be used to help meet this requirement.
                                         31

-------
R10 Risk Management Training Manual                                     EPA 910-K-10-001   March 2010
   The information pertaining to process equipment design must be documented. In other
   words, what were the codes and standards relied on to establish good engineering
   practice. These codes and standards are published by such organizations as the
   American Society of Mechanical Engineers, American Petroleum Institute, American
   National Standards Institute, National Fire Protection Association, American Society for
   Testing and Materials, National Board of Boiler and Pressure Vessel Inspectors,
   National Association of Corrosion Engineers, American Society of Exchange
   Manufacturers Association, and model building code groups. In addition, various
   engineering societies issue technical reports which impact process design. For example,
   the American Institute of Chemical Engineers has published technical reports on topics
   such as two phase flow for venting devices. This type  of technically recognized report
   would constitute good engineering practice.

   For existing equipment designed and constructed many years ago in accordance with
   the codes and standards available at that time and no longer in general use today, the
   employer must document which codes and standards  were used and that the design and
   construction along with the testing, inspection and operation are still suitable for the
   intended use. Where the process technology requires  a design which departs from the
   applicable codes and standards, the employer must document that the design and
   construction is suitable for the intended purpose.

   Source: OSHA Guidance on PSM (1910.119)
                                          32

-------
R10 Risk Management Training Manual
                                                         EPA 910-K-10-001   March 2010
         RMP PROCESS SAFETY INFORMATION Requirements

   Title 40: PART 68—CHEMICAL ACCIDENT PREVENTION PROVISIONS
   Subpart C—Program 2 Prevention Program, ง 68.48
   Subpart D—Program 3 Prevention Program, ง 68.65

   • Common  Deficiencies:
      >  Missing or outdated MSDS
      >  Missing Maximum Intended Inventory
      >  Missing safer upper/lower limits
      >  Missing documentation on changing obsolete equipment/design or still
         safe
      >  Missing Block Flow Diagrams
      >  Missing or unapproved PI&D
      >  Missing ventilation system design
      >  Missing "good engineering practices"

   •  Purpose of process safety information:
      •   Understand the safety-related aspects of the equipment and processes,
         know what limits are placed on your operations and adopt accepted
         standards and codes that apply.
      •   Foundation for an effective prevention program.

   • Owner/Operator  responsibility:
      •   PROGRAM 2: Compile and maintain up-to-date safety information related
         to the regulated substances, processes, and equipment.
      •   PROGRAM 3: Complete a compilation of written process safety
         information before conducting any process hazard analysis required by
         the rule. The compilation of written process safety information is to enable
         the owner or operator and the employees involved  in operating the
         process to identify and  understand the hazards posed by those processes
         involving regulated substances. This process safety information shall
         include information pertaining to the hazards of the regulated substances
         used or produced by the process, information pertaining to the technology
         of the process, and information pertaining to the equipment in the process.

   PROGRAM 2: PROCESS SAFETY INFORMATION REQUIREMENTS
      You must compile and maintain
          this safety information
    You must ensure
 You must update the safety
       information if
      Material Safety Data Sheets
      Maximum intended inventory
      Safe upper and lower
      parameters
     Equipment specifications
      Codes & standards used to
      design, build, and operate the
      process	
That the process is
designed in compliance with
recognized codes and
standards
There is a major change at
your business that makes the
safety information inaccurate
                                      33

-------
R10 Risk Management Training Manual
                                                              EPA 910-K-10-001   March 2010
   PROGRAM 3: PROCESS SAFETY INFORMATION REQUIREMENTS
         For chemicals, you must
         complete information on
For process technology, you
       must provide
   For equipment in the
 process, you must include
      information on
      • Toxicity
      • Permissible exposure limits
      • Physical  data
      • Reactivity
      • Corrosivity
      • Thermal & chemical stability
      • Hazardous  effects of
        inadvertent mixing of materials
        that could foreseeably occur
  A block flow diagram or
  simplified process flow
  diagram
  Information on process
  chemistry
  Maximum  intended
  inventory
  Chemical Safe upper &
  lower limits: temperature,
  pressure, flows, or
  composition
  An evaluation of the
  consequences of deviation
Materials  of construction
 Piping & instrument
 diagrams (P&IDs)
Electrical  classification
 Relief system design &
 design basis
 Ventilation system design
 Design codes & standards
 employed
Safety systems
 Material and energy
 balances  for processes built
 after June 21, 1999
                                          33

-------
R10 Risk Management Training Manual
                                                                         EPA 910-K-10-001    March 2010
       Process Safety Information

         Risk Management Program

                            •
      Focus
      o Process Safety
        Information
        Requirements
      o Program Level
        Differences
        • Program 2
        • Program 3
      o Common
        Deficiencies
      General Requirements
      o Hazard
        Information of the
        regulated
        substance used in
        the process
      o Information on the
        technology in the
        process
      o Information on the
        equipment in the
        process
                                                34

-------
R10 Risk Management Training Manual
                                                                                      EPA 910-K-10-001    March 2010
       Program 2 Requirements
                                        Maximum
                                    13]  Intended
                                        Inventory
        MSDS
                                          Equipment
                                          Specifications
      Safe Upper/Lower Limits    Ljy ;:;•


  March 2010                EPA Region 10
       Program 3 Requirements
                                        Maximum
                                     j]  Intended
                                        Inventory
        MSDS
                                          Process
                                          Chemistry
      Safe Upper/Lower Limits   Consequences of Deviation

  March 2010                EPA Region 10
       Program 3 Requirements



    Block Flow Diagram
                                  Material of Construction
  March 2010                EPA Region 10
                                                          35

-------
R10 Risk Management Training Manual
                                                                                EPA 910-K-10-001    March 2010
       Program 3 Requirements
     Relief System Design
                              Electrical Classification
                        Material 4
                        Energy
    Ventilation System Design     Balance
                                     Safety System
       Common Deficiencies
    o Missing:
       • MSDS
       • Maximum Intended
        Inventory
       • Safer upper/lower
        limits
       • Documentation on
        existing equipment
        with codes,
        standards or
        practices no longer
        in general use.
       Common Deficiencies
                            o Missing:
                              • Block  Flow
                                Diagrams
                              • PI&D or
                                unapproved
                              • Ventilation
                                system design
                              •"Good
                                engineering
                                practices"
                                                     36

-------
R10 Risk Management Training Manual                                     EPA 910-K-10-001   March 2010
   Process Hazard Analysis

   The process hazard analysis is a thorough, orderly, systematic approach for identifying,
   evaluating, and controlling the hazards of processes involving highly hazardous
   chemicals. The employer must perform an initial process hazard analysis (hazard
   evaluation) on all processes covered by this standard. The process hazard analysis
   methodology selected must be appropriate to the complexity of the process and must
   identify, evaluate, and control the hazards involved in the process.

   First, employers must determine and document the priority order for conducting process
   hazard analyses based on a rationale that includes such considerations as the extent of
   the process hazards, the number of potentially affected employees, the age of the
   process, and the operating history of the process. All initial process hazard analyses
   should be conducted as soon as possible, but at a minimum, the employer must
   complete no fewer than 25 percent by May 26, 1994; 50 percent by May 26,  1995; 75
   percent by May 26, 1996; and all initial process hazard analyses by May 26,  1997.
   Where there is only one process in a workplace, the analysis must be completed by May
   26, 1994.

   Process hazard analyses completed after May 26, 1987 that meet the requirements of
   the PSM standard are acceptable as initial process hazard analyses. All process hazard
   analyses must be updated and revalidated, based on their completion date, at least
   every five years.

   The employer must use one or more of the following methods, as appropriate, to
   determine and evaluate the hazards of the process being analyzed:
       •   What-if,
       •   Checklist,
       •   What-if/checklist,
       •   Hazard and operability study (HAZOP),
       •   Failure mode and  effects analysis (FMEA),
       •   Fault tree analysis, or
       •   An appropriate equivalent methodology.

   A discussion of these methods of analysis is  contained in the companion publication,
   OSHA 3133, Process Safety Management Guidelines for Compliance. Whichever
   method(s) are used, the process hazard analysis must address the following:
       •   The hazards of the process;
       •   The identification of any previous incident that had a potential for catastrophic
          consequences in the workplace;
       •   Engineering and administrative controls applicable to the hazards and their
          interrelationships,  such as appropriate application of detection methodologies to
          provide early warning of releases. Acceptable detection methods might include
          process monitoring and control instrumentation with alarms, and detection
          hardware such as hydrocarbon sensors;
       •   Consequences of failure of engineering and administrative controls;
       •   Facility siting;
       •   Human factors; and
       •   A qualitative evaluation of a  range of the possible safety and health effects on
          employees in the workplace  if there is a failure of controls.
                                          37

-------
R10 Risk Management Training Manual                                     EPA 910-K-10-001   March 2010
   OSHA believes that the process hazard analysis is best performed by a team with
   expertise in engineering and process operations, and that the team should include at
   least one employee who has experience with and knowledge of the process being
   evaluated. Also, one member of the team must be knowledgeable in the specific
   analysis methods being used.

   The employer must establish a system to address promptly the team's findings and
   recommendations;  ensure that the recommendations are resolved in a timely manner
   and that the resolutions are documented; document what actions are to be taken;
   develop a written schedule of when these actions are to be completed; complete actions
   as soon as possible; and communicate the actions to operating, maintenance, and other
   employees whose work assignments are in the process and who may be affected by the
   recommendations or actions.

   At least every five years after the completion of the initial process hazard analysis, the
   process hazard analysis must be updated and revalidated by a team meeting the
   standard's requirements to ensure that the hazard analysis is consistent with the current
   process.

   Employers must keep on file and make available to OSHA, on request, process hazard
   analyses and updates or revalidation for each process covered by PSM, as well as the
   documented resolution of recommendations, for the life of the process.
                                         38

-------
R10 Risk Management Training Manual
                                                                       EPA 910-K-10-001    March 2010
              AppatdixF
                                               -74-
                                                                              WWTP
Checklist for
                                                  t-30
                                                  Ammonia &ys
Anhydrous Ammonia -Basic Rules
Are storage tank(s} painted white or other light reflecting caters
and maintained in good older?
k storage area free of readily ignitablematerials?
Are storage tank(s} kept away from wells or other sources of
potable water aupplyt
Aie storage tank(s) located with ample working space all around?
Are storage tank(s) properly vented and away from areas where
operataix are likely to be?
Does receiving system include a vapor return?
b storage capacity adequate to receive full volume of delivery
vehicle?
Aie storage tankfsj secured against overturn by wind, earthquake
and/or floatation?
AK tank bottam(s) protected from external corrosion?
Is aqua ammonia system protected from possible damaj^ from
moving vehicles?
Are storage tank(i} labeled as to content?
Are all appurtenances suitable for aqua ammonia service?
Are all storage tank(s) Fitted with liquid level gauges?
Are liquid level gauge(s) adequately protected from physical
damage?
If tubing is used, is it fitted with a fail closed valve?
Are all storage tank(s) fitted with overfill fittings or high level
alarms?
Are tank(s } fitted with pressure/vacuum valves?
is an ammonia gas scrubber system used?
Are piping and hose materials suitable for aqua ammonia service?
ฅest*WNA



















Comments



















    General Guidance on Risk Management Programs for Chemical Accident Prevention (40 CFR
    Part 68). EPA-550-B-04-001 April 2004
                                               39

-------
R10 Risk Management Training Manual
                                                         EPA 910-K-10-001   March 2010
   What-lf Checklist Log Sheet - Sample
CO
Q

"co
•a
CD
E
E
o
o
CD
a:
CO p..
& CD"
CO "O
w <
CO
CO
O)

CO
w
C CO
CD -Q
FT CO
II
ฐ "35
O o


CO
CD
CO
3
CO
o

CO
c
o
"co
CD
3
o
CD
E >?

— >
S-B
UJ <
E
CD
-i—'








CD
O
Z



>•
s- ^
O Q. O
f^ฃ

^ >- -C
S CD CO

CD M-
~~ 3 ฐ CO
~ -X CD -K
c ง- c/> 15 ง
งell 1 I
^^ __ "^ c/)
^^ fli

O > (/) ^ C H_. "^
Enl — rrt — /i\ ITT
ฃ.

ซ_ 03 ^ ^_ $^ ^ C O ^""
_(/)Q-OCCCCCO(/)
> ^ ฃ?
w ^ CO c % ^.

ฃ CD CD -^ Q. CD
s= 3 E E^ c E
-*ฑ CO Q. o O) ^ Q-
ง 2 O" CD i^ D"
> Q. CD .11 T3 O CD
CD
O 1—
•^ 3 —
m CO ^
^ CO S^
ฃ 2 CD
O 0- >
5








CD
O
Z



>•
0
CD JE
CO O
CO CO CD $U
m t— o O
> O CO ">

CO 3 ^ CD


•S CD 3 '4= 2
. ฐ > CO C ^
> E CD CO CD -ri
(Y ^ — ni H-* o
(/) O E Q. Q. E
>< s_ "a c CD
s_ ^3 O CD s- m CO
O O_NO_^CO"O CD
^ — ^ fll CO ^^" > -^ '^ CO ^
_O) (^ i_ ~- CO ^ Q_ __ — ••TT

CDpQ^O^Q^i-5j2~5jQ
Qiw.ฃoWฃ<8Jo<8Q.
a:
W >,
CD -Q
M— !—
*- 8
m c ^
ง — N
> .!5 "co
CD
•— 3 —
m CO <5
r- CO ^
S 2 CD
O Q. >
CNl
_CO
^
a:
w

Q_ >2
Q- E
O CO
CD ^
CD 2
Q Q.



Z

E
CO
O)
^ o

Q. Ql
IH —
I ซf ง
CO >- .> (O
^ co "gj 5 2
"O C CD ^j
C -HJ CD 'C ^ CO _
0 " - C Q."0 3 E
•^=2cCDCOtD CT CO
CO i— O) ^ ^ ฃ1 CD 1—

l.l^lwiioiii
> CO
W ~ ^
CD ^ 3
ฃ CD CO
^ J2 CO
~ W 2
> Q. "CD
> O CO
CD
•— 3 —

(^ CO CO
O CL >
CO
                                      40

-------
R10 Risk Management Training Manual
                                                                         EPA 910-K-10-001
                                                                                          March 2010
           Process Hazard Analysis or
                 Hazard Review
      Program Levels:
      There are three program levels.


      A facility program level is determined
        by the result of the off site
        consequence analysis and whether
        or not it is subject to the OSHA PSM
        standard.
      Program 1
      o The off site consequence analysis proves
        that a catastrophic release (worst case
        scenario) does not reach a public receptor
        or an environmental receptor.

      o Also has not had an incident that caused
        a death, injury or a restoration response
        for an environmental receptor
                                                41

-------
R10 Risk Management Training Manual
                                                                           EPA 910-K-10-001
                                                                                             March 2010
      Program  3
      o The process is subject to the OSHA
        process safety management
        standard, 29CFR 1910.119

      o The process in the NAICS code
        32211, 32411, 32511, 325181,
        325188, 325192, 325199,325211,
        325311 or 32532.
      Program  2
    o The off site consequence analysis
      proves that a catastrophic release
      (worst case) would reach a public or
      environment receptor but the facility
      does not meet the requirements of
      Program 3.
          Program 2 - Hazard Review
    Conduct a review of the hazards of the regulated process.

           Identify opportunities for equipment malfunction
           or human error.
           Identify safeguards used or needed to prevent
           such occurrences.
           Identify the steps used or needed to detect or
           monitor releases

           Document the results and ensure the problems
           identified are resolved in a timely manner.

           Review and update at least every 5 years and
           or when major changes occur.
                                                  42

-------
R10 Risk Management Training Manual
                                                                                   EPA 910-K-10-001
                                                                                                       March 2010
         Process Hazard Analysis  -Program 3
   The owner or operator shall perform an initial process
   hazard analysis (PHA), and identify, evaluate, and
   control the hazards involved in the process,
       Why a Process Hazard Analysis?

       o To identify activities or occurrences that
         are potential safety problems.
       o To determine and develop corrective
         measures needed to reduce or eliminate
         the exposure.
       o To establish a system to assure that all
         findings and recommendations are
         addressed.
     Types of Process Hazard Analysis Allowed

       o    What-if
       o    Checklist
       o    What-if/Checklist
       o    Hazard and Operability Study (HAZOP)
       o    Failure Mode and Effects Analysis
       o    Fault Tree Analysis
       o    An appropriate equivalent methodology
                                                       43

-------
R10 Risk Management Training Manual
                                                                                     EPA 910-K-10-001
                                                                                                         March 2010
       Let's look at a "What if" concept

       o Develop a PHA team to ask questions
         pertaining to actions, processes and
         procedures that occur within an operation.

       o Each question addresses a potential failure
         in operating or maintenance procedures or
         an activity that could effect a process in an
         adverse way.
       The PHA Team
       o The  PHA mus t be p  erformed by a team wit h
         expertise in  engineering and process operations
         and the team must include appropriate personnel.


       o The t earn  must i nclude on e employee that  is
         familiar with the process and one individual that is
         familiar with the PHA methodology being used.
       Example questions
       o Do the operating procedures address the
         possibility of a release during power outage?

       o Are the inspections of the power hoists
         adequate?

       o Are the fork truck masts tall enough to impact
         the  overhead piping or equipment?
                                                         44

-------
R10 Risk Management Training Manual
                                                                                               EPA 910-K-10-001
                                                                                                                      March 2010
        Examples:  Responses
        o Power outages are adequately addressed in the
          operating procedures and operator training.


        o The hoists are being inspected monthly as per
          the manufacturers recommendations and OS HA
          requirements.


        o The fork trucks could make contact with several
          evaporators in the cold storage warehouse.
        PHA : Fork truck operations
        o Exposure was identified.


        o Need to determine actions that will reduce and or
          eliminate the exposure.


        o Need to prioritize and document the actions that are
          needed, (time line, responsibility, etc.)


        o Need to establish a tracking system for comple;


        o Do not overlook accountability
        Did the PHA address
         The hazards of the process?

         Identification of any incident that had a likely potential for
            catastrophic consequences?


         Engineering and administrative controls applicable to
         hazards and interrelationships?


         Consequences of failure of engineering and administrative
            controls?
         Stationary source siting?


         Human factors?
         An evaluation of a range of the possible safety and health
            effects of failure of controls?
                                                               45

-------
R10 Risk Management Training Manual
                                                                                     EPA 910-K-10-001
                                                                                                          March 2010
       System to address the team findings

       o The owner or operator shall established a system
         to p romptly add  ress the team's f indings  and
         recommendations;
       o Assure that the recommendations are resolved in
         a timely manner and documented; document what
         actions are to be taken;
       o Complete actions as soon as possible;
       o Develop a written schedule of when these actions
         are to be completed;
       o Communicate t  he   actions    to   operating,
         maintenance, and other employees whose work
         assignments are in  the process and who may be
         affected by the recommendations.
       5 year up-dates
       o The PHA must be updated and revalidated by a
         team every five years after the completion of the
         initial PHA to assure that the PHA is consistent
         with the current process,
       Document Retention
       o The owner or operator must retain the
         PHA's and updates or revalidations for
         each process covered, as well as the
         resolution of recommendations, for the life
         of the process.
                                                         46

-------
R10 Risk Management Training Manual                                     EPA 910-K-10-001    March 2010
   Operating Procedures

   Operating procedures describe tasks to be performed, data to be recorded, operating
   conditions to be maintained, samples to be collected, and safety and health precautions
   to be taken. The procedures need to be technically accurate,  understandable to
   employees, and revised periodically to ensure that they reflect current operations. The
   process safety information package is to be used as a resource to better assure that the
   operating procedures and practices are consistent with the known hazards of the
   chemicals in the process and that the operating parameters are accurate. Operating
   procedures should be reviewed by engineering staff and operating personnel to ensure
   that they are accurate and provide practical instructions on how to actually carry out job
   duties safely.

   Operating procedures will include specific instructions or details on what steps are to be
   taken or followed in carrying out the stated procedures. These operating instructions for
   each procedure should  include the applicable safety precautions and should contain
   appropriate information on safety implications. For example, the operating procedures
   addressing operating parameters will contain operating instructions about pressure
   limits, temperature ranges, flow rates, what to do when an upset condition occurs, what
   alarms and instruments are pertinent if an upset condition occurs, and other subjects.
   Another example of using operating instructions to properly implement operating
   procedures is in starting up or shutting down the process. In these cases, different
   parameters will be required from those  of normal operation. These operating instructions
   need to clearly indicate the distinctions  between startup and normal  operations such as
   the appropriate allowances for heating up a unit to reach the normal operating
   parameters. Also the operating instructions need to describe the proper method for
   increasing the temperature of the unit until the normal operating temperature parameters
   are achieved.

   Computerized process control systems add complexity to operating  instructions. These
   operating instructions need to  describe the logic of the software as well as the
   relationship between the equipment and the control system; otherwise, it may not be
   apparent to the operator.

   Operating procedures and instructions are important for training operating personnel.
   The operating procedures are  often viewed as the standard operating practices (SOPs)
   for operations. Control room personnel  and operating staff, in general, need to have a
   full understanding of operating procedures. If workers are not fluent  in English then
   procedures and instructions need to be prepared in a second language understood by
   the workers. In addition, operating procedures need to be changed when there is a
   change in the process as a result of the management of change procedures. The
   consequences of operating procedure changes need to be fully evaluated and the
   information conveyed to the personnel.

   Source: OSHA Guidance on PSM (1910.119), Appendix D: page D-5
                                          47

-------
R10 Risk Management Training Manual                                     EPA 910-K-10-001   March 2010
   For example, mechanical changes to the process made by the maintenance department
   (like changing a valve from steel to brass or other subtle changes) need to be evaluated
   to determine if operating procedures and practices also need to be changed. All
   management of change actions must be coordinated and integrated with current
   operating procedures and operating personnel must be oriented to the changes in
   procedures before the change is made. When the process is shutdown to make a
   change, then the operating procedures must be updated before startup of the process.

   Training in how to handle upset conditions must be accomplished as well as what
   operating personnel are to do in emergencies such as when a pump seal fails or a
   pipeline ruptures. Communication between operating personnel and workers performing
   work within the process area, such  as non-routine tasks, also must be maintained. The
   hazards of the tasks are to be conveyed to operating personnel in accordance with
   established procedures and to those performing the actual tasks. When the work is
   completed, operating  personnel should be informed to provide closure on the job.

   Source: OSHA Guidance on PSM (1910.119)
                                          48

-------
                                               EPA 910-K-10-001
R10 Risk Management Training Manual
       Operating Procedure Requirements Summary
                                                           March 2010
Steps for Each Phase
Initial startup
Normal operations
Temporary operations
Emergency shutdown
Emergency operations
Normal shutdown
Start-up following a normal or emergency shutdown
or major change
Lockout/tagout*
Confined space entry*
Opening process equipment or piping*
Entrance into the facility*
Operating Limits
Consequences of deviations
Steps to avoid, correct deviations
Equipment Inspection
Safety & Health Considerations
Chemical properties & hazards
Precautions for preventing chemical exposure
Control measures for exposure
QC for raw materials and chemical inventory
Special or unique hazards
Safety Systems & Their Functions
What systems are there and how do they work
Annual Certification Requirement
Conduct annual certification
Program 2

-------
R10 Risk Management Training Manual
                                                                      EPA 910-K-10-001
                                                                                      March 2010
 Operating Procedures
 • Must be:
   n Appropriate for the equipment and operations
   n Complete
   n Easily understood by facility's operators
   n Readily accessible to workers who operate or
    maintain the process
 • Review/modify as often as necessary to
   reflect current practices and process
   changes
  Operating Procedure
  Requirements Summary
Initial startup
Normal operations
Temporary operations
Emergency shutdown
Emergency operations
Normal shutdown
Start-up following a normal or
emergency shutdown or major change
Lockout/tag out*
Confined space entry*
Opening process equipment or piping*
Entrance into the facility*
„•
ซ•
„•
ซ•
„•
ซ•
„•




„•
ซ•
„•
ซ•
„•
ซ•
„•
„•
ซ•
„•
ซ•
  Operating Procedure
  Requirements Summary
  | What systems are there and how do they work
  ^^^^^^^^^^^^^^^^^m
  Conduct annual certification

                  EPARegion 10
                                              50

-------
R10 Risk Management Training Manual
                                                                                   EPA 910-K-10-001    March 2010
  Operating  Procedures
                   m
Must give clear
instructions for safety
conducting activities
involving a covered
process
Steps must include:
 n Initial start-up
 n Normal operations
 D Temporary operations
 D Emergency operations
 n Normal shut down
 n Start-up following
  emergency or major
  change
  Operating Procedures
 • Must have:
    n Consequences of
     deviations
    n Steps required to
     correct or avoid
     deviation
 • Know your
   operating limits!!
  Operating  Procedures

                        D Safety and health
                          considerations:
                           • Properties of, and physical
                             hazards presented by, the
                             chemicals used in the
                             process
                         h • Precautions necessary to
                             prevent exposure,
                             including engineering
                             controls, administrative
                             controls, and personal
                             protective equipment
                                                        51

-------
R10 Risk Management Training Manual
                                                                        EPA 910-K-10-001    March 2010
 Operating Procedures
                           i Control measures
                            to be taken if
                            physical contact or
                            airborne exposure
                            occurs
                           i Quality control for
                            raw materials and
                            control of
                            hazardous chemical
                            inventory levels
                           i Any special or
                            unique hazards
 Operating Procedures
   Operating procedures
   must be readily
   accessible to
   employees who are
   involved in a process.
 Operating Procedures
 • Procedures must be current
   and accurate and that
   procedures have been
   reviewed as often as
   necessary.
 • Must certify annually!!
                                                52

-------
R10 Risk Management Training Manual                                      EPA 910-K-10-001   March 2010
   Training

   Site-specific, up-to-date, and documented employee training programs are crucial to
   ensure that employees understand their job in relation to the chemical process, its
   hazards, and the precautions necessary to prevent process safety incidents. (CCPS)

   Employee Training: All employees, including maintenance and contractor employees,
   involved with highly hazardous chemicals need to fully understand the safety and health
   hazards of the chemicals and processes they work with for the protection of themselves,
   their fellow employees and the citizens of nearby communities. Training conducted in
   compliance with OSHA 1910.1200, the Hazard Communication standard, will help
   employees to be more knowledgeable about the chemicals they work with as well as
   familiarize them with reading and understanding MSDS. However, additional training in
   subjects such as operating procedures and safe work practices, emergency evacuation
   and response, safety procedures, routine and nonroutine work authorization activities,
   and other areas pertinent to process safety and health will need to be covered by an
   employer's training program.

   In establishing their training programs, employers must clearly define the employees to
   be trained and what subjects are to be covered in their training. Employers in setting up
   their training program will need to clearly establish the goals and objectives they wish to
   achieve with the training that they provide to their employees. The learning goals or
   objectives should be written in clear measurable terms before the training begins. These
   goals and objectives need to be tailored to each of the specific training modules or
   segments. Employers should describe the important actions and conditions under which
   the employee will demonstrate competence or knowledge as well as what is acceptable
   performance.

   Hands-on-training where employees are able to use their senses  beyond listening, will
   enhance learning. For example, operating personnel, who will work in a control room or
   at control panels, would  benefit by being trained at a simulated control panel or panels.
   Upset conditions of various types could be displayed on the simulator, and then the
   employee could go through the proper operating procedures to bring  the simulator panel
   back to  the normal operating parameters. A training environment could be created to
   help the trainee feel the full reality of the situation but, of course, under controlled
   conditions. This realistic type of training can be very effective in teaching employees
   correct procedures while allowing them to also see the consequences of what might
   happens if they do not follow established operating procedures. Other training
   techniques using videos or on-the-job training can also be very effective for teaching
   other job tasks, duties, or other important information. An effective training program will
   allow the employee to fully participate in the training process and to practice their skill or
   knowledge.

   Source: OSHA Guidance on PSM (1910.119)
                                          53

-------
R10 Risk Management Training Manual                                     EPA 910-K-10-001   March 2010
   RMP TRAINING REQUIREMENTS
          Common Deficiencies
             •  No date or employee ID on Training Records
             •  No description of training or testing methods
             •  No documentation of initial or 3-year refresher training

          Purpose of a training program
             •  Provides workers with the information they need to:
                   •   Understand how to operate safely, and
                   •   Why safe operations are necessary

          Owner/Operator Responsibility
             •  Provide initial training to all workers in the covered process including
             safety and health hazards, operating procedures, emergency operations
             including shutdown and safe work practices
             •  Provide refresher training at least every three years
             •  Ascertain and document that each employee received and understood
             the training,
             •  O/O  shall prepare a record which contains:
                   Employee ID,
                   Date of training, and
                   The means used to verify that the employee understood the training

      Training requirements for other Prevention Program (3) Elements
          •   Mechanical integrity - Training for process maintenance activities
          •   Management of change & Pre-startup review - Training of each  employee
             involved in operating a process has been completed in any updated or new
             procedures prior to startup of a process after a major change
          • Contractors
             The contract O/O shall assure that each contract employee is trained
             Has received and understood the training,
             Identity of the contract  employee, the date of training, and the means used to
             verify that the employee understood is documented
          • Emergency   response program
             Training for all employees in relevant procedure
                                          54

-------
R10 Risk Management Training Manual
                                                            EPA 910-K-10-001   March 2010
              TRAINING DOCUMENTATION FORM - SAMPLE
   Topics:

   Accident Prevention Program, safety orientation
   Personal Protective Equipment Type:
   Chemical Hazard Communication
   First Aid
   Portable Fire Extinguishers
   Date(s) of Training:
List of employees who completed
this training:








Testing Method and Results








   Trainer/Employer
                                        55

-------
R10 Risk Management Training Manual                                        EPA 910-K-10-001   March 2010
                              Operator Certification Form
Name:                                           SSN:
Job Title/Position:	      Process Area/Dept:
This document certifies that as of June 21,1999, this employee has the required knowledge, skill and
abilities to safety carry out duties and responsibilities as specified in the operating procedures for the
following process(es):
(1)    	      (2)

(3)    	      (4)

(5)    	      (6)

(7)    	      (8)

(9)    	      (10)

(11)   	      (12)
Employee Signature:
Name:                                           Date:
Supervisor Signature:
Supervisor Name:	       Date:
                                             56

-------
R10 Risk Management Training Manual
                                                                                EPA 910-K-10-001
                                                                                                   March 2010
 Training
                        A training program,
                        • Provides workers with the
                          information they need to:
                          • Understand how to
                            operate safely, and
                          • Why safe operations are
                            necessary
                        • Ensures that the rest of the
                          prevention program is
                          effective
   Training Program Elements
 • Operating Procedures
 • Maintenance or Mechanical Integrity
 • Management of Change and Pre-Startup
 • Contractor
 • Emergency Response
   Program 2 & 3
   Operating Procedure Training
 • Initial Training -
   • Presently operating a process, and newly
     assigned to a covered process:
     • Have been trained or tested competent in the
       operating procedures and safe work practices
     • Employees operating a process on June 21, 1999;
       O/O certification
                                                     57

-------
R10 Risk Management Training Manual
                                                                       EPA 910-K-10-001
                                                                                        March 2010
 Program 2 & 3
 Operator Training Requirements

 • Refresher training
   • At least every three
     years
 Maintenance - Program (2)
 Mechanical Integrity - Program (3)
  > Hazards of the
   process
  ' How to avoid or
   correct an
   unsafe
   condition
  ' Procedures
   applicable to
   job tasks
 Management of Change and
 Pre-Startup Training
   Operators, maintenance
   and contract employees
   must be trained in any
   updated or new procedures
   prior to startup of a process
   after a major change
   Training must be complete
   prior to introduction of
   regulated substance to a
   new or changed process
                                               58

-------
R10 Risk Management Training Manual
                                                                   EPA 910-K-10-001   March 2010
 Emergency Response Training
  Employees
  must be trained
  in relevant ER
  procedures -

   Document
 Contractor Must Insure Contract
 Employees are Trained in:
   Safe work practices
   Known hazards and
   emergency response
   activities (Program 3)
   Maintenance
   procedures related to
   process hazard
 Training Documentation
 Owner/Operator Requirements

   • Ascertain that each employee:
    • Received and understood the training,
     Prepare a record which contains:
     • Employee ID,
     • Date of training, and
     • The means used to verify that the employee
      understood the training
                                             59

-------
R10 Risk Management Training Manual
                                                         EPA 910-K-10-001   March 2010
 Training Basics

 • Site-specific

 • Up-to date

 • Documented
 Training Deficiencies

   • No date or employee ID on
    Training Records
   • No description of training or
    testing methods
   • No documentation of initial or
    3-year refresher training
           RMP Prevention
                   Program
           Training Requirements
                             •
                                      60

-------
R10 Risk Management Training Manual
                                                             EPA 910-K-10-001   March 2010
   Employee Participation
   Common Deficiencies:

      •   Failure to develop a written plan of action regarding the implementation of the
          employee participation
      •   Failure to consult with employees and their representatives on the conduct and
          development of process hazards analyses
      •   Failure to provide employees and their representatives access to process
          hazards analyses and to all other information required to be developed under the
          chemical accident prevention rule

   Because of their first-hand knowledge of problems and practical solutions, non-
   supervisory employees (operators, mechanics, etc.) should be included in the process.
   (CCPS)

   The employee participation rule applies to Program 2 and 3 facilities. It requires you to
   consult with your employees and their representatives on the conduct and development
   of process hazards analyses and other required process safety management elements.

   The Risk Management Program is a tool to be used by everyone in a facility, not just
   management. Parent company developed RMPs should have local input, review and
   relevance.

   The table below briefly  summarizes what you must do:

   Program 3 Facilities: EMPLOYEE PARTICIPATION REQUIREMENTS
Write a plan
Consult with
employees
Provide access to
information
Develop a written plan of action regarding how you will implement
employee participation.
Consult your employees and their representatives regarding conducting
and developing PHAs and other elements of process safety management
in the risk management program rule.
• Review and certify operating procedures
• Determine frequency of training with employee input* (Program 2)
• Review maintenance procedures, use of equipment and need for
upgrade or retrofit* (Program 2)
• Review incident investigations with all affected personnel*
(Program 2)
Ensure that your employees and their representatives have access to
PHAs and all other information required to be developed under the rule.
                                         61

-------
R10 Risk Management Training Manual
                                                                    EPA 910-K-10-001    March 2010
       Prevention Program
          Employee Participation
 Employee Participation
                      • Because of their first-
                       hand knowledge of
                       problems and
                       practical solutions,
                       non-supervisory
                       employees
                       (operators,
                       mechanics, etc.)
                       should be included in
                       the process. (CCPS)
 Employee Participation - Defined
   Consult with employees and their
   representatives on the conduct and
   development of:
   • Process hazards analyses
   • Other process safety management
     elements in chemical accident prevention
     provisions.
                                              62

-------
R10 Risk Management Training Manual
                                                                      EPA 910-K-10-001   March 2010
 Employee Participation
      Requirements
 Written plan of action
 regarding the
 implementation of
 the employee
 participation.
 Plan Might Address

 • Training - topic and
   frequency
   Mechanism for
   Operator Input
   • Contact
   • Scheduled review

   Availability of PHA
   documents
                                               63

-------
R10 Risk Management Training Manual                                     EPA 910-K-10-001   March 2010
   Mechanical Integrity

   OSHA believes it is important to maintain the mechanical integrity of critical process
   equipment to ensure it is designed and installed correctly and operates properly. PSM
   mechanical integrity requirements apply to the following equipment:

          •  Pressure vessels and storage tanks;
          •  Piping systems (including piping components such as valves);
          •  Relief and vent systems and devices;
          •  Emergency shutdown systems;
          •  Controls (including monitoring devices and sensors, alarms, and interlocks);
             and
          • Pumps.

   The employer must establish and implement written procedures to maintain the ongoing
   integrity of process equipment.  Employees involved in maintaining the ongoing integrity
   of process equipment must be trained  in an overview of that process and its hazards and
   trained in the procedures applicable to the employees' job tasks.

   Inspection and testing must be  performed on process equipment, using procedures that
   follow recognized and generally accepted good engineering practices. The frequency of
   inspections and tests of process equipment must conform with manufacturers'
   recommendations and good engineering practices, or more frequently if determined to
   be necessary by prior operating experience. Each inspection and test on process
   equipment must be documented, identifying the date of the inspection or test, the name
   of the person who performed the inspection or test, the serial number or other identifier
   of the equipment on which the inspection or test was performed, a description of the
   inspection or test performed, and the results of the inspection or test.

   Equipment deficiencies outside the acceptable limits defined by  the process safety
   information must be corrected before further use. In some cases, it may not be
   necessary that deficiencies be corrected before further use, as long as deficiencies are
   corrected  in a safe and timely manner, when other necessary steps are taken to ensure
   safe operation.

   In constructing new plants and equipment, the employer must ensure that equipment as
   it is fabricated is suitable for the process application for which it will be used. Appropriate
   checks and inspections must be performed to ensure that equipment is installed properly
   and is consistent with design specifications and the manufacturer's instructions.

   The employer also must ensure that maintenance materials, spare parts, and equipment
   are suitable for the process application for which they will be used.
   Source: OSHA Guidance on PSM (1910.119)
                                          64

-------
R10 Risk Management Training Manual
                                                                               EPA 910-K-10-001
                                                                                                  March 2010
  Mechanical Integrity

  • Written procedures
  • Training
  • Inspections and testing
  • Corrective actions
  • Fabrication/installation of new equipment
  • Maintenance materials and parts
 Written Procedures
   Shut down & start up and/or isolation procedures
   for each specific task.  (LOTO)
   Training requirements & methods to assure that
   training is adequate, (testing should be considered )
   Inspection/testing procedures addresses needed
   frequency & operational tolerances.
   Methods for assuring that new equipment or
   modifications to existing equipment are suitable
   for the process.  (MOC covers this)
  Inspection Practices

  • Follow recognized and generally good
   engineering practices for inspections and
   testing.

    n Manufactures recommendations
    n Industry standards (ASME, NFPA, MAR, Etc.)
    n Prior operating experience
                                                     65

-------
R10 Risk Management Training Manual
                                                                                                  EPA 910-K-10-001
                                                                                                                          March 2010
  Pressure Relief Devices
  MAR Bulletin 110, Section 6.6.3
  (Excerpts)
  Revision: May 24, 2007
  Pressure relief devices shall be replaced or recertified in accordance with
      one of these three options:
  1.   Every five (5) years from the date of installation.
      MAR originally recommended (in 1978) that pressure relief valves be
      replaced every five years from the date of installation. This
      recommendation represents good engineering practice considering the
      design and performance of pressure relief devices; or
  2.   An alternative to the prescriptive replacement interval, i.e., five years, can
      be developed based on documented in-service relief valve life for specific
      applications using industry accepted good practices of relief valve
      evaluation; or
  3.   The manufacturer's recommendations on replacement frequency of
      pressure relief devices shall be followed.

  Exception: Relief devices discharging into another part of the closed-loop refrigeration
      system are not subject to the relief valve replacement practices.
  Inspection Frequency
    Ensure frequency of inspections and tests
    consistent with applicable manufacturers'
    recommendations, good engineering practices,
    and prior operating experience.

     n Hourly
     n Daily
     n Monthly
     nAnnually
     n Manufactures recommendations
              Inspection Documentation
             Document each inspection with
     nDate
     nName of the person who performed
       inspection
     n Serial number or other identifier of equipment
     n Description
     n Results
                                                                 66

-------
R10 Risk Management Training Manual
                                                                           EPA 910-K-10-001
                                                                                             March 2010
  Documentation Format


  • Meets 29 CFR 1910 and 40 CFR 68
  • Simple to maintain but captures all of the
   necessary information
  • Accountability for both the inspection/test
   completion and the documentation of the results
  • Corrective action (when needed) and
   documentation tied to the inspection report.
  Documentation Formats
  Complexity
   Routine checklist
    n Hourly task
    n Simple items
    n Little training required
     to execute
   Complex checklist
    n Hourly or less
    n All items can be critical
    n Requires extensive
     training
  Inspection Identified
  Equipment Deficiencies

  • The owner or operator shall correct
   deficiencies in equipment that are outside
   acceptable limits (defined by the process
   safety information in Sec. 68.65) before
   further use or in a safe and timely manner
   when necessary means are taken to
   assure safe operation.
                                                  67

-------
R10 Risk Management Training Manual
                                                                     EPA 910-K-10-001
                                                                                     March 2010
 Design and Installation

   Appropriate checks and inspections shall
   be performed to assure that equipment is
   installed properly and consistent with
   design specifications and the
   manufacturer's instructions.
 Maintenance Materials
   The owner or operator shall assure that
   maintenance materials, spare parts and
   equipment are suitable for the process
   application for which they will be used.
                                              68

-------
R10 Risk Management Training Manual
                                                             EPA 910-K-10-001    March 2010
    Management of Change/ Pre-startup Safety Review
   For existing processes that have been shutdown for turnaround, or modification, etc., the
   employer must assure that any changes other than "replacement in kind" made to the
   process during shutdown go through the management of change procedures. P&IDs will
   need to be updated as necessary, as well as operating procedures and instructions. If
   the changes made to the process during shutdown are significant and impact the training
   program, then operating personnel as well as employees engaged in routine and non-
   routine work in the process area may need some refresher or additional training in light
   of the changes. Any incident investigation recommendations, compliance audits or PHA
   recommendations need to be reviewed as well to see what impacts they may have on
   the process before beginning the startup.

   Management of Change Requirements (Program Level 3)'
MOC procedures
must address:

Technical basis for
the change

Impact on safety and
health

Modifications to
operating
procedures

Necessary time
period for the
change
Authorization
requirements for
proposed change
Employees
affected by the
change must:
Be informed of the
change before
startup

Trained in the
change before
startup









Update process safety
information if:

A change covered by
MOC procedures results
in a change in any PSI
required under EPA's
rule (see ง 67.65)











Update
operating
procedures if:

A change
covered by MOC
procedures
results in a
change in any
operating
procedure
required under
EPA's rule (see ง
67.69)





   Pre-Startup Safety Review

   For new processes, the employer will find a PHA helpful in improving the design and
   construction of the process from a reliability and quality point of view. The safe operation
   of the new process will be enhanced by making use of the PHA recommendations
   before final installations are completed. P&IDs are to be completed along with having the
   operating procedures in place and the operating staff trained to run the process before
   startup. The initial startup procedures and normal operating procedures need to be fully
   evaluated as part of the pre-startup review to assure a safe transfer into the normal
   operating mode for meeting the process parameters.
                                         69

-------
R10 Risk Management Training Manual                                    EPA 910-K-10-001   March 2010
   Interrelationship of Process Safety Management] Elements

   An essential part of verifying program implementation is to audit the flow of information
   and activities among the [Process Safety Management] elements. When information in
   one element is changed or when action takes place in one element that affects other
   elements, the Safety Compliance Officers or Health Compliance Officers (SCO/HCO)
   shall review a sample of the related elements to see if the appropriate changes and
   followup actions have taken place.

   The following example demonstrates the interrelationship among the elements:
   During a routine inspection of equipment (Mechanical Integrity), the maintenance
   worker discovers a valve that no longer meets the applicable code and must be
   changed. Because the type of valve is no longer made, a different type of valve must be
   selected and installed (Management of Change). The type  of valve selected may
   mandate different steps for the operators (Operating Procedures) who will require
   training and verification in the new procedures (Training). The rationale for selecting the
   type of valve must be made available for review by employees and their representatives
   (Employee Participation).

   When the new valve is installed by the supplier (Contractors), it will involve shutting
   down part of the process (Pre-startup Safety Review) as well as brazing some of the
   lines (Hot Work Permit). The employer must review the response plan (Emergency
   Planning) to ensure that procedures are adequate for the installation hazards.

   Although Management of Change provisions cover interim  changes, after  the new
   valve is in place the Process Safety Information will have to be updated before the
   Process Hazard Analysis is updated or revalidated, to account for potential hazards
   associated with the new equipment. Also, inspection and maintenance procedures and
   training will  need to be updated (Mechanical Integrity).

   In summary, 11  PSM elements can be affected by changing one valve.  A SCO/HCO
   would check a representative number of these 11 elements to confirm that  the required
   follow-up activities have been implemented for the new valve.
   GENERAL GUIDANCE ON RISK MANAGEMENT PROGRAMS FOR CHEMICAL ACCIDENT
   PREVENTION (40 CFR PART 68). EPA-550-B-04-001 April 2004

    Process Safety Management of Highly Hazardous Chemicals, OREGON OCCUPATIONAL SAFETY
   AND HEALTH DIVISION DEPARTMENT OF CONSUMER AND BUSINESS SERVICES, Program
   Directive A-177, Issued April 5, 1993, Revised August 15, 2000.
   SCO/HCO: Safety Compliance Officers or Health Compliance Officers
                                         70

-------
R10 Risk Management Training Manual
                                                                     EPA 910-K-10-001
                                                                                      March 2010
         Management of Change
        Pre-startup Safety Review
                 US EPA Region 10
      Management of Change  ง 68.75
       •  Owner/Operator
              Shall
       - Establish and
         Implement written
         procedures to
         manage changes
          • Except for
           "replacements in
           kind"
                 US EPA Region 10
     Except for "replacements in kind"
                 US EPA Region 10
                                              71

-------
R10 Risk Management Training Manual
                                                                                           EPA 910-K-10-001     March 2010
  Changes that Affect a Covered Process"
   DESCRIPTION OF PROPOSED CHANGE
          AND POTENTIAL HAZARDS
                              Technical basis
                              Impact on safety and health
                              Impact on operating
                              procedures
                              Time period for the change
                              Authorization requirements
                              Affected employees
                              informed/trained
                              prior to start-up
                              Updated process safety
                              information
DESCRIPTION OF PROPOSED
 CHANGE AND POTENTIAL
      HAZARDS
                       US EPA Region 10
    Deficiencies:  Not Implementing MOC

    Have affected personnel (i.e., operations, maintenance, and
    contract) been informed of and trained in this change?

    Are operating procedures or maintenance procedures required
    to be updated as a result of this change?
    - If yes, have affected personnel been trained in the updated
      operating procedures?

    Is the PHA Offisite Consequence Analysis, or RMP applicability
    affected by this change?
    - If yes, has a hazard assessment update been performed (if
      needed) and has the revised RMPIan been submitted?

    Is process safety information required to be updated as a result
    of this change?
    - If yes  has a Prestartup Safety Review been performed?
                       US EPA Region 10
                                                             72

-------
R10 Risk Management Training Manual
                                                                                      EPA 910-K-10-001
                                                                                                           March 2010
          Pre-startup Safety Review
    For modified facilities
    where a change is
    needed to the
    process safety
    information
    For new facilities
                     US EPA Region 10
          Pre-startup Safety Review
> Evaluate beforehand
     Before you push
        STABT
                            Construction & equipment is in
                            accordance w/ design specs

                            Safety, operating, maintenance, &
                            emergency procedures are in place fi
                            adequate

                            PHA has been performed and
                            recommendations resolved for new
                            facilities
                       Modified facilities meet the
                       requirements contained in MOC

                       Training has been completed for
                       employees involved in operating the
                       new process
                     US EPA Region 10
            MOC & PSSR Example
    During a routine
    inspection, a
    maintenance worker
    discovers a valve that
    no longer meets the
    applicable code and
    must be changed.
                                  Old Style
                           Replacement
                     US EPA Region 10
                                                          73

-------
R10 Risk Management Training  Manual
                                                                                                                   EPA 910-K-10-001
                                                                                                                                               March 2010
             MOC & PSSR Example (cont'd)

   Management Of Change: Because the type of valve is no longer made, a
   different type of valve must be selected and installed.

      Operating Procedures: The type of valve selected may mandate different
      steps for the operators.

      Training: The operators will require training and verification in the new
      procedures.

      Employee Participation: The rationale for selecting the type of valve must
      be made available for review by employees and their representatives.

      Process Safety Information: Will have to be updated before the Process
      Hazard Analysis is updated or revalidated.

      Process Hazard Analysis: Must be updated or revalidated in order to
      account for potential hazards  associated with the new equipment.

      Mechanical  Integrity: Inspection and maintenance procedures and training
      will need to be updated.

  March 2010                    US EPA Region 10                         10
                   MOC & PSSR Example (cont'd)
  P re-start up Safety Review: Required for modified facilities where a
  change is needed to the process safety information.

     - Contractors: When the new valve is installed by the supplier it
        will involve shutting down part of the process.

     - Hot Work Permit: In addition to shutting down part of the
        process, some of the lines will need to be welded.

     - Emergency Planning:  The  employer must review the
        emergency response plan to ensure that procedures are
        adequate for the installation hazards.
                             US EPA Region 10
                                                                             74

-------
R10 Risk Management Training Manual                                     EPA 910-K-10-001   March 2010
   Compliance Audits
   Employers need to select a trained individual or assemble a trained team of people to
   audit the process safety management system and program. A small process or plant
   may need only one knowledgeable person to conduct an audit. The audit is to include an
   evaluation of the design and effectiveness of the process safety management system
   and a field inspection of the safety and health conditions and practices to verify that the
   employer's systems are effectively implemented. The audit should be conducted or led
   by a person  knowledgeable in audit techniques and who is impartial towards the facility
   or area being audited. The essential elements of an audit program include planning,
   staffing, conducting the audit, evaluation and corrective action, follow-up and
   documentation.

   Planning in advance is essential to the success of the auditing process. Each employer
   needs to establish the format, staffing, scheduling and verification methods prior to
   conducting the audit. The format should be designed to provide the lead auditor with a
   procedure or checklist which details the requirements of each section of the standard.
   The names of the audit team members should be listed as part of the format as well. The
   checklist, if properly designed, could serve as the verification sheet which provides the
   auditor with the necessary information to expedite the review and assure that no
   requirements of the standard are omitted. This verification sheet format could also
   identify those elements that will require evaluation or a response to correct deficiencies.
   This sheet could also be used for developing the follow-up and documentation
   requirements.

   The selection of effective audit team members is critical to the success of the program.
   Team members should be chosen for their experience, knowledge, and training and
   should be familiar with the processes and with auditing techniques, practices and
   procedures.  The size of the team will vary depending on the size and complexity of the
   process under consideration. For a large, complex, highly instrumented plant, it may be
   desirable to  have team members with expertise in process engineering and design,
   process chemistry, instrumentation and computer controls, electrical hazards and
   classifications, safety and health disciplines, maintenance, emergency preparedness,
   warehousing or shipping, and process safety auditing. The team  may use part-time
   members to provide for the depth of expertise required as well as for what is actually
   done or followed, compared to what is written.

   An effective  audit includes a review of the relevant documentation and process safety
   information,  inspection of the physical facilities, and interviews with all levels of plant
   personnel. Using the audit procedure and checklist developed in  the preplanning stage,
   the audit team can  systematically analyze compliance with the provisions of the standard
   and any other corporate policies that are relevant. For example, the audit team will
   review all aspects of the training program as part of the overall audit. The team will
   review the written training program for adequacy of content, frequency of training,
   effectiveness of training in terms of its goals and objectives as well as to how it fits into
   meeting the  standard's requirements, documentation, etc. Through interviews, the team
   can determine the employee's knowledge and awareness of the safety procedures,
   duties, rules, emergency response assignments, etc. During the inspection, the team
                                          75

-------
R10 Risk Management Training Manual                                      EPA 910-K-10-001   March 2010
   can observe actual practices such as safety and health policies, procedures, and work
   authorization practices. This approach enables the team to identify deficiencies and
   determine where corrective actions or improvements are necessary.

   An audit is a technique used to gather sufficient facts and information, including
   statistical information, to verify compliance with standards. Auditors should select as part
   of their preplanning a sample size sufficient to give a degree of confidence that the audit
   reflects the level of compliance with the standard.  The  audit team, through this
   systematic analysis, should document areas which require corrective action as well as
   those areas where the process safety management system is effective and working in
   an effective manner. This provides a record of the audit procedures and findings, and
   serves as a baseline of operation data for future audits. It will assist future auditors in
   determining changes or trends from previous audits.

   Corrective action is one of the most important parts of the audit. It includes not only
   addressing the identified deficiencies, but also planning, follow up,  and documentation.
   The corrective action process normally begins with a management review of the audit
   findings. The purpose of this review is to determine what actions are appropriate, and to
   establish priorities, timetables, resource allocations and requirements and
   responsibilities. In some cases, corrective action may involve a simple change in
   procedure or minor maintenance effort to remedy the concern. Management of change
   procedures need to be used, as appropriate, even for what may seem to be a minor
   change. Many of the deficiencies can be acted on promptly, while some may require
   engineering studies or in-depth review of actual procedures and practices. There may be
   instances where no action is necessary and this is a valid response to an audit finding.
   All actions taken, including an explanation where no action is taken on a finding, needs
   to be documented as to what was done and why.

   It is important to assure that each deficiency identified  is addressed, the corrective action
   to be taken noted, and the audit person or team responsible be properly documented by
   the employer.

   To control the corrective action process, the employer  should consider the use of a
   tracking system. This tracking system might include periodic status reports shared with
   affected levels of management, specific reports such as completion of an engineering
   study, and a final implementation report to provide closure for audit findings that have
   been through management of change, if appropriate, and then shared with affected
   employees and management. This type of tracking system provides the employer with
   the status of the corrective action. It also  provides the documentation required to verify
   that appropriate corrective actions were taken on deficiencies identified in the audit.
   Source: OSHA Guidance on PSM (1910.119)
                                          76

-------
R10 Risk Management Training Manual                                    EPA 910-K-10-001   March 2010
                       RMP Compliance Audit Requirements

   Title 40: PART 68—CHEMICAL ACCIDENT PREVENTION PROVISIONS
   Subpart C—Program 2, ง 68.58, Subpart D—Program 3, ง 68.79

   •   Common Deficiencies:
       >  Not completed at least every three years
       >  Do not identify and review all RMP elements
       >  Checklist not site-specific
       >  Do not identify who is responsible for addressing deficiencies
       >  No date when deficiencies were corrected
       >  How the deficiencies were addressed
       >  Findings and recommendations not addressed
       >  Resolutions/ corrections not documented
       >  Failure to address previous PHA
       >  Failure to ensure all written procedures are consistent
       >  Failure to certify audit

   •   Purpose of a compliance audit:
       •   Evaluate and measure the effectiveness of your risk management program
          (RMP):
          o  Reviews each of the prevention program elements
             1.  Ensure RMP is up-to-date and being  implemented
             2.  Identify problem areas and take corrective actions
       •   Run a safer operation.

   •   Owner/Operator responsibility:
       •   Certify that they have evaluated compliance  at least every three years to verify
          that the procedures and practices developed under the rule are adequate and
          are being followed.
       •   Have at least one person knowledgeable in the process.
       •   Develop a report of the audit findings.
       •   Promptly determine and document an appropriate response to each of the
          findings and document that deficiencies have been corrected.
       •   Retain the two (2) most recent compliance audit reports. This requirement does
          not apply to any compliance audit report that is more than five years old.

   •   Prevention Program Elements
       -S  Safety Information
       v'  PHA/Hazard Review
       S  Operating Procedures
       -S  Training
       S  Maintenance/Mechanical Integrity
       S  Compliance Audits
       -S  Incident Investigation
       S  Management of Change (MOC)
       S  Pre-startup Safety Review
       -S  Hotwork
       S  Contractors - Employee Participation
                                         77

-------
R10 Risk Management Training Manual
                                                                     EPA 910-K-10-001    March 2010
      Risk Management Program

          Compliance Audits

CA Program Level Requirements
Program 2
Safety Information
Hazard Review
Operating Procedures
Training
Maintenance Mechanical Integrity


Compliance Audits
Incident Investigation

Program 3
Process Safety Information
Processes Hazard Analysis
Operating Procedures
Training
Maintenance Mechanical Integrity
Management of Change
Pre-Startup Review
Compliance Audits
Incident Investigation
Employee Participation
Hot Work Perm it
Contractors
March 2010 EPA Region 10 2
    Compliance Audits Process
                At least one person
                knowledgeable of the
                process.
          Document findings, ^
          responses and corrections of
                                              78

-------
R10 Risk Management Training Manual
                                                                                EPA 910-K-10-001
                                                                                                    March 2010
           Compliance Audits
              Documentation
               Document findings,
               responses and corrections of
               any deficiencies
                                   Identify problem
                                   areas and take
                                   corrective actions.
     Compliance Audits Common

                Deficiencies

    Not completed at least every three years
    Did not identify and review all RMP elements
    Checklist not site-specific
    Did not identify who is responsible for addressing
    deficiencies
    Failure to address previous PHA
    Failure to ensure all written procedures are consistent
    Failure to certify audit
    No date when deficiencies were corrected
    How were the deficiencies addressed
    Findings and recommendations not addressed
    Resolutions/ corrections not documented
                                                      79

-------
R10 Risk Management Training Manual                                  EPA 910-K-10-001   March 2010
   Hot Work Permit

   Non-routine work which is conducted in process areas needs to be controlled by
   the employer in a consistent manner. The hazards identified involving the work
   that is to be accomplished must be communicated to those doing the work, but
   also to those operating personnel whose work could affect the safety of the
   process. A work authorization notice or permit must have a procedure that
   describes the steps the maintenance supervisor, contractor representative or
   other person needs to follow to obtain the necessary clearance to get the job
   started. The work authorization procedures need to reference and coordinate, as
   applicable, lockout/tagout procedures, line breaking procedures, confined space
   entry procedures and hot work authorizations. This procedure also needs to
   provide clear steps to follow once the job is completed to provide closure for
   those that need to know the job is now completed and equipment can be
   returned to normal.

   Source:  OSHA Guidance on PSM  (1910.119)
                                       80

-------
        R10 Risk Management Training Manual
                                                                         EPA 910-K-10-001   March 2010
                                UF HOT WORK PERMIT
    This Hot Work Permit is required for any operation involving open flames or producing heat and/or
    sparks and must be completed by a Competent Hot Work Supervisor (CHWS) and posted at the site.
    Hot Work includes, but is not limited to: Brazing, Torch Cutting, Grinding, Soldering, and Welding.
    If the required precautions cannot be met, Hot Work is not permitted.
     HOT WORK DONE BY
        |  CONTRACTOR
     DATE:
            WO#
     BUILDING NAME, BLDG #, ROOM #, LOCATION
     NATURE OF JOB
     NAME OF HOT WORK OPERATOR
     I verify the above location has been examined, the precautions
     checked on the Required Precautions Checklist have been
     taken to prevent fire, and permission is authorized for work.
     NAME OF COMPETENT HOT WORK SUPERVISOR
     (CHWS)
     Contact #
            Fax*
     PERMIT
     REQUEST
     PERMIT
     EXPIRES
DATE
DATE
     SIGNATURE OF CHWS
            To be signed during inspection
     EH&S Approval
        REQUIRED PRECAUTIONS CHECKLIST
        Q]  Available sprinklers, hose streams,
            and extinguishers are in service/operable.
        Q]  Hot work equipment in good repair.
        Requirements within 35ft of work
        Q|  Flammable liquids, dust, lint and
            oil deposits removed.
          ]  Explosive atmosphere in area eliminated.
        Q|  Floors swept clean of combustibles.
          I  Combustible floors wet down,
    Combustible floors wet down,
     covered with damp sand or fire-
     resistant sheets.
    Remove other combustibles where
    possible. Otherwise protect with
    fire-resistant tarpaulins, screens or
    shields.
    All wall and flj^^xpeninffs covered.
                                                            Fire-resistant tarpaulins suspended
                                                            beneath elevated hot work.
Work on walls or ceilings/enclosed equipment
    Construction is noncombustible and without
    combustible covering or insulation.
    Combustibles on other side of walls
      wed away.
       danger emsts by conduction of heat into
    ranother room or area
    Enclosed equipment cleaned of all
     combustibles.
     ^ntainers purged of flammable liquids
     and vapors.

Fire watch/hot work area monitoring.
    Fire watch will be provided during and
     continuously for 30 minutes after work,
     including during any work breaks.
    Fire watch is supplied with suitable
     extinguishers.
    Fire watch is trained in use of this equipment
     and in sounding alarm.
Q|  Fire watch may be required for adjoining
     areas, above and below.
Q|  Hot work area inspected  30 minutes after
     job is completed.

Other precautions Taken
Q|  Confined  space entry permit required.

Q|  Area is protected with smoke or heat
     detection.
Q|  Ample ventilation to remove smoke/vapor
     from work area.
O  Lockout/tagout required.
    Comments:
|  Submit Form
                 FAX TO EH&S ฉ352-392-6367 PRIOR TO 8:OOAM OF PERMIT REQUEST DATE
                                 This Permit was developed for compliance with:
                    EH&S HOT WORK SAFETY POLICY UFEHS-SAFE1-07/22/2003
                                                   81
         Reset Form

-------
R10 Risk Management Training Manual                                  EPA 910-K-10-001   March 2010
   Contractors

   Employers who use contractors to perform work in and around processes that
   involve highly hazardous chemicals, will need to establish a screening process
   so that they hire and use contractors who accomplish the desired job tasks
   without compromising the safety and health of employees at a facility. For
   contractors, whose safety performance on the job is not known to the hiring
   employer, the employer will need to obtain information on injury and illness rates
   and experience and should obtain contractor references. Additionally, the
   employer must assure that the contractor has the appropriate job skills,
   knowledge and certifications (such as for  pressure vessel welders). Contractor
   work methods and experiences should be evaluated. For example, does the
   contractor conducting demolition work swing loads over operating  processes or
   does the contractor avoid such hazards?

   Contract employees must perform their work safely. Considering that contractors
   often perform very specialized and potentially hazardous tasks such as confined
   space entry activities and non-routine repair activities it is quite important that
   their activities be controlled while they are working on or near a covered process.
   A permit system or work authorization system for these activities would also be
   helpful to all affected employers. The use of a work authorization system keeps
   an employer informed of contract employee activities, and as a benefit the
   employer will have better coordination and more management control over the
   work being performed in the process area. A well run and well maintained
   process where employee safety is fully recognized will benefit all of those who
   work in the facility whether they be contract employees or employees of the
   owner.

   Source: OSHA Guidance on PSM (1910.119)
                                       82

-------
R10 Risk Management Training Manual
                                                                       EPA 910-K-10-001
                                                                                        March 2010
                                SAMPLE DOCUMENT
       ZIP
RISK IDENTIFICATION NO.
EFFECTIVE DATE OF RATING
       FEDERAL IDENTIFICATION NUMBER
                                    STATE OF COVERAGE
Coverage Period
(1)
Effective
Month/Day/
Year

(2)
Expiration
Month/Day/
Year


(3)
Class
Code

(4)
Payroll

(5)
Claim
Identification
Number Assigned

(6)
Injury
Type
Code

(?)
Open/Closed
-Final
(0/F)

(8)
Incurred Losses
(Paid plus
Reserves)

       PLEASE FOLLOW THE INSTRUCTIONS ON THE BACK PAGE FOR COMPLETING THIS WORKSHEET, AND
       RETURN IT TO NCCI PRIOR TO THE RATING EFFECTIVE DATE.
                                                                              ERM-6{Rev. 12/03)
                                            Page 1 of 2
       ฃ 2002 National Council ฉn Compensation Insurance* Inc.
                                               83

-------
R10 Risk Management Training Manual
                                                                                 EPA 910-K-10-001
                                                                                                    March 2010
         Hot Work Permit
   o Permit for each hot work operation conducted on
     or near a covered process.


   o The permit shall document that the fire
     prevention and protection requirements in 29CFR
     1910.252(a) have been implemented prior to
     beginning the hot work operations.


   o The permit shall indicate the date(s) authorized
     for hot work and the object(s) upon which hot
     work is to be performed.


   o The permits shall be kept on file until completion
     of the hot work operations.
        Contractors
  o Requires that the owner or operator has
    obtained and evaluated contract owner
    or operator's safety performance and
    programs before selecting the contractor


     • How does your contracting or finance
       office fulfill this requirement?

     • Do you review the State OSHA website
       for injuries or accident/insurance claims?
        Facility Responsibilities

  o Inform the contract owner or operator of the known
   potential fire, explosion, or toxic release hazards
   related to the contractor's work and the process.


  o Explain to the contract owner or operator the
   applicable provisions of the emergency response or
   the emergency action program.

  o Develop and implement safe work practices
   consistent with ง68.69(d), to control the entrance,
   presence, and exit of the contract owner or operator
   and contract employees in the covered process areas.

  o Periodically evaluate contractor in meeting their
   responsibilities
                                                      84

-------
R10 Risk Management Training Manual
                                                                         EPA 910-K-10-001   March 2010
       OSHA / WISHA Report Forms
       Workers Compensation experience rating report
                          E -7T
       BP Texas City Explosion
     I  15 fatalities
                                                 85

-------
R10 Risk Management Training Manual                                     EPA 910-K-10-001   March 2010
   Incident Investigations

   Incident investigation is the process of identifying the underlying causes of incidents and
   implementing steps to prevent similar events from occurring. The intent of an incident
   investigation is for employers to learn from past experiences and thus avoid  repeating
   past mistakes. Some of the events are sometimes referred to as "near misses," meaning
   that a serious consequence did not occur, but could have.

   Employers need to develop in-house capability to investigate incidents that occur in their
   facilities. A team needs to be assembled by the employer and trained in the techniques
   of investigation  including how to conduct interviews of witnesses, needed documentation
   and report writing. A multi-disciplinary team is better able to gather the facts  of the event
   and to analyze them and develop plausible scenarios as to what happened, and why.
   Team members should be selected on the basis of their training,  knowledge  and ability
   to contribute to  a team effort to fully investigate the incident.

   Employees in the process area where the incident occurred should be consulted,
   interviewed or made a member of the team. Their knowledge of the events form a
   significant set of facts about the incident which occurred. The report, its findings and
   recommendations are to be shared with those who can benefit from the information. The
   cooperation of employees is essential to an effective incident investigation. The focus of
   the investigation should be to obtain facts, and not to place blame. The team and the
   investigation process should clearly deal with all involved individuals in a fair, open and
   consistent manner.

   Source: OSHA Guidance on PSM (1910.119), Appendix D: page D-11
                                          86

-------
R10 Risk Management Training Manual
                                                      EPA 910-K-10-001   March 2010
Requirements
Initiate an investigation promptly, but
within 48 hours.
Assemble an Investigation Team.
Summarize the investigation in a
report.
Address findings/recommendations.
Review the report with your
staff/contractors.
Retain Report for Five Years.
Program 2
X

X
X
X
X
Program 3
X
X
X
X
X
X
   Important to Remember:

      •   Does this meet Five-Year Accident History criteria?

           o  Required to submit RMP correction within 6 months.

      •   Does this incident impact other Prevention Program elements?

   At a Minimum,  Key Elements should always be routinely reviewed
   following an incident:

      • Operating   Procedures;

      • Maintenance  Procedures;

      •   Process Hazard Analysis; and

      • Training
                                    87

-------
R10 Risk Management Training Manual
                                                                        EPA 910-K-10-001    March 2010
    Incident Investigation
        Risk Management Program
i
What's an Incident?
      Definitions

     • Incident - Event which resulted in, or
       could reasonably have resulted in a
       catastrophic release of a regulated
       substance, (includes near misses)
     • Incident Investigation - Written analysis of
       an accident/incident using various methods of
       causal determination.
     • Catastrophic Release - One that presents an
       imminent and  substantial  endangerment to
       public health and the environment.
                                                88

-------
R10 Risk Management Training Manual
                                                                           EPA 910-K-10-001    March 2010
     Examples of
     Catastrophic  Releases
                          i Process fires
                          i Explosions
                          i Reportable spills and
                           releases
                          i Flammable, toxic, or
                           reactive piping
                           failures
                          i Line breaking
                           accidents
                          i Equipment failures
     Requirements for
     an Investigation
                            Begin within 48
                            hours of accident or
                            incident.
                            Establish
                            knowledgeable
                            investigation team.
                            Summarize the
                            investigation in a
                            written report.


Incident Investigation
Requirements
Initiate an investigation
promptly, but within 48 hrs.
Assemble Investigation Team.
Summarize the investigation
in a report.
Address
findings/recommendations.
Review the report with your
staff/contractors.
Retain Report for Five Years.
Program 2
X

X
X
X
X
Program 3
X
X
X
X
X
X
March 2010 EPA Region 10
6
                                                  89

-------
R10 Risk Management Training Manual
                                                                        EPA 910-K-10-001    March 2010
     Incident Investigation
       Important to Remember:
          . Does this meet Five-Year Accident
           History criteria?
            • Required to submit RMP correction within i
             months.
          . Does this incident impact other
           Prevention Program elements?
     Incident Investigation
     Prevention  Program Elements
         At a Minimum, Key Elements
         should always be routinely
         reviewed following an incident:

         • Operating Procedures;

         • Maintenance Procedures;

         • Process Hazard Analysis; and

         • Training
     Incident Resolution
  Employer must either:
   • Adopt the incident
    investigation team's
    recommendation or
   • Justifiably decline to
    adopt the
    recommendations
                                                90

-------
R10 Risk Management Training Manual
                                                                                EPA 910-K-10-001    March 2010
     Declining  Recommendations
     Owner/Operator must:
      • Inform team members;
      • Document the justification in writing:
        . Analysis and recommendations were based on
          factual errors
        . Recommendation not necessary to protect
          employees, contractors, or the public
        . Alternative measure would provide sufficient
          protection
        . Recommendation presented was not feasible for
          adoption
     Incident Investigations
     at Progressive Companies
     •  Not merely looking at only the specific findings,
       but look beyond "what broke"
     •  Determine root cause to ensure recurrence is
       eliminated, if possible
     •  Look at management systems and organizational
       structure that could be improved
     •  Use information from investigation to assess the
       program
     •  All  incidents are investigated, including "near
       misses"
       Goals of the Investigation
                    Use investigation as a
                    program management
                    tool
                    Prevents injuries
                    Prevent process
                    shutdown
                    Prevent recurrence
                                                     91

-------
R10 Risk Management Training Manual                                     EPA 910-K-10-001   March 2010




   Emergency Response

                 RISK MANAGEMENT PROGRAM REQUIREMENTS

   40 CFR 68 Subpart E - Emergency Response

   •  Does not apply to facilities that exclusively have Risk Management Program Level 1
      processes;
   •  All facilities with Program Level 2 or Program Level 3 processes are required to
      comply.  If a facility has at least one Program 2 or Program 3 process, Part 68
      requires the facility to implement an emergency response program if its employees
      will respond to some releases involving regulated substances.

   Facilities have two options when developing programs to address accidental releases of
   regulated substances.  The choices are:

      1.     Evacuate their employees and use coordinated response plans with local fire
             departments and/or community emergency response resources (non-
             responding facility) or
      2.     Have their employees respond to accidental releases of regulated
             substances (a responding facility)

   The requirements of Subpart E are different based on a facility's choice of being a non-
   responding facility or a responding facility.

   EPA recognizes that, in some cases (particularly for retailers and other small operators
   with few employees), it may not be appropriate for employees to conduct response
   operations for releases of regulated substances.  For example, it would be inappropriate,
   and probably unsafe, for an ammonia retailer  with only one full-time employee to expect
   that a tank fire could be handled without help  of the local fire department or other
   emergency responders. EPA does not intend to force such facilities to develop
   emergency response capabilities. At the same time, the facility is responsible for
   ensuring effective emergency response to any release at the facility.   If the local public
   responders are not capable of providing such  responses, the facility must take  steps to
   ensure that effective response resources are available (e.g., by hiring response
   contractors or obtaining agreements with regional hazmat teams).

   40 CFR 68.90 - Non-Responding Facilities

   •  As required under OSHA, develop and implement an Emergency Action Plan;
   •  Coordinate with local  response agencies:
             o  Included in the Community Emergency Response Plan in response to a
                potential release of a toxic chemical and/or
             o  Ensure that the local fire department is capable and aware of their
                responsibility to respond to a flammable gas fire.
   •  It is recommended that the facility document coordination efforts by keeping copies
      of correspondence, posting emergency response contact information and the
      procedures that will be used in the event of a response.
                                         92

-------
R10 Risk Management Training Manual                                     EPA 910-K-10-001   March 2010
   40 CFR 68.95 - Responding Facilities

   •   Must have an Emergency Response Program that protects the public and the
       environment;
   •   Emergency Response Program elements must include:
             o  Written response plan, which includes;
                    •   Procedures for informing the public and emergency response
                       agencies about releases;
                    •   Documentation of proper first aid and emergency medical
                       treatment necessary to treat human exposures;
                    •   Procedures and measures for emergency response.
             o  Procedures for using, inspecting, testing, and maintaining emergency
                response equipment;
             o Training  for employees;
             o  Procedure for updating the response plan;

   Although EPA's required elements for emergency response are essential to any
   emergency response program, they are not comprehensive guidelines for creating an
   adequate response capability.  Rather than establish another set of federal requirements
   for an emergency response program, EPA has limited the  provision of its rule to those in
   the CAA mandates.  If a facility has a regulated substance on site, it already  is subject to
   at least one emergency response rule; OSHA's emergency action plan requirements (29
   CFR 1910.38).  Under OSHA's HAZWOPER regulations, any facility that handles
   "hazardous substances" (a broad term that includes all of the CAA regulated substances
   and thus applies to all facilities with covered processes) must comply with either 29 CFR
   1910.38(a) or 1910.120(q).

   If a facility has a "hazmat" team, it is subject to the 29 CFR 1910.120(q) regulations.  If a
   facility's emergency response program is developed to comply with the OSHA
   requirements and satisfy the elements listed for a "responding facility", generally, no
   other action need to be taken to comply with the EPA requirements. The goal is to
   create on comprehensive emergency response program that can respond quickly and
   effectively to any type of emergency at a particular facility.

   General Guidance on Risk Management Programs for Chemical Accident Prevention (40 CFR
   PART 68). EPA-550-B-04-001 April 2004
                                         93

-------
R10 Risk Management Training Manual
                                                                            EPA 910-K-10-001
                                                                                              March 2010
  Emergency  Response
                           Facilities have the
                           option to respond to
                           their own
                           emergencies or rely
                           on local HAZMAT
                           responders
                           For all Program 2 or
                           3 facilities, they must
                           decide on how
                           emergencies will be
                           handled
  Non-Responding Facilities
  All Non-Responding
  Facilities:
   n Do not need an Emergency
    Response Program, if:
     • Coordination with local
       response agencies is
       arranged;
     • A formal notification
       procedure is in place to
       activate the response
  Non-Responding Facilities
                           Must Coordinate:
                            n Toxic substances -
                              must be included in
                              the Community
                              Emergency Response
                              Plan
                            n Flammables - local fire
                              department regarding
                              response procedures
                                                   94

-------
R10 Risk Management Training Manual
                                                                                 EPA 910-K-10-001
                                                                                                    March 2010
  Non-Responding  Facilities
    Notification must:
     n Establish
       appropriate
       mechanism to notify
       emergency
       responders in an
       emergency
     n Identify an
       emergency contact
       that the responder
       will call for a toxic or
       flammable release
  Responding  Facilities
                         Emergency Response
                         Program:
                          n Written Emergency
                           Response Plan
                          n Procedures for using,
                           inspecting, testing, and
                           maintaining emergency
                           response equipment
                          n Training for employees
                          n Have procedures to
                           update the emergency
                       ^'C  response plan
      Emergency Response Program
    Emergency Response Plan:
     n Procedures for informing the public and emergency
      response agencies about releases
     n Documentation of proper first aid and emergency
      medical treatment necessary to treat human
      exposures
     n Procedures and measures for emergency response
      after an accidental release
     n Complies with other contingency plan regulations or
      the Integrated Contingency Plan Guidance
     n Coordinated with the Community Emergency
      Response Plan
                                                      95

-------
R10 Risk Management Training Manual
                                                                                    EPA 910-K-10-001
                                                                                                        March 2010
    First Responder Training
                         Facilities must:
                          n Comply with OSHA
                            regulations for HAZWOPER
                          n If employees of the facility
                            are members of the
                            HAZMAT team, they are
                            subject to additional
                            HAZWOPER requirements
  Emergency Response Triggers
   • An event or release that:
      n Affects ongoing operations
      n Requires evacuation of employees or the public
       from the area
      n Poses or has the potential to pose conditions that
       are immediately dangerous to life and health
      n Poses a serious threat of fire or explosion
      n May cause high levels of exposure to toxic
       substances
      n Creates uncertainty that the employees can
       handle the situation with their regular equipment
       and exposure limits have not been exceeded
      n Causes a situation to be unclear or information is
       lacking to make informed decisions
  EPA  & OSHA
  Requirements
EPA requires that
facilities to have
emergency response
procedures to inform the
public and responders
and have  measures in
place to manage an
offsite release of a
hazardous substance.

OSHA requires that
facilities protect their
employees by
evacuation, accounting
for employees and
moving responders into
position to manage a
release.
                                                        96

-------
R10 Risk Management Training Manual
                                                                          EPA 910-K-10-001    March 2010
 OSHA Regulations
   Facilities who chose to rely on responders must
   have an Emergency Action Plan (29 CFR
   1910.120 (q) (1) &29 CFR 1910.38)


   Facilities who chose to manage their own
   response must have an Emergency Response
   Plan (29 CFR 1910.120 (q) (2)) and possibly 29
   CFR 1910.156 (fire brigades)
 Communication
                         Most important to
                         protect employees and
                         the community
                         Must be able to
                         communicate with
                         emergency responders
                         regarding safety and
                         employees and
                         community regarding
                         evacuation or
                         sheltering-in-place
 Alarm  Systems
                         Employers must have and
                         maintain alarm systems
                         Alarm system must use a
                         distinctive signal for each
                         purpose
                         Capable of being
                         perceived above all
                         ambient noise or light
                         levels
                         Be distinctive and
                         recognizable as a signal to
                         evacuate the work area
                                                 97

-------
R10 Risk Management Training Manual                                            EPA 910-K-10-001   March 2010
    Appendix

       • RMP   Definitions
       • Acronyms


    68.3  Risk Management Program Definitions

    For the purposes of this part: 40 CFR part 68, CAA 112(r) Risk Management Program

    Accidental release means an unanticipated emission of a regulated substance or other extremely hazardous
    substance into the ambient air from a stationary source.

    Act means the Clean Air Act as amended (42 U.S.C. 7401 et seq .)

    Administrative controls mean written procedural mechanisms used for hazard control.

    Administrator means the administrator of the U.S. Environmental Protection Agency.

    AlChE/CCPS means the American Institute of Chemical Engineers/Center for Chemical Process Safety.

    API means the American Petroleum Institute.

    Article means a manufactured  item, as defined under 29 CFR 1910.1200(b), that is formed to a specific
    shape or design during manufacture, that has end use functions dependent in whole or in part upon the
    shape or design during end use, and that does not release or otherwise result in exposure to a regulated
    substance under normal conditions of processing and use.

    ASME means the American Society of Mechanical Engineers.

    CAS means the Chemical Abstracts Service.

    Catastrophic release means a  major uncontrolled emission, fire, or explosion, involving one or more
    regulated substances that presents imminent and substantial endangerment to public health and the
    environment.

    Classified information means "classified information" as defined in the Classified Information Procedures
    Act, 18 U.S.C. App. 3, section  1(a) as "any information or material that has been determined by the United
    States Government pursuant to an executive order, statute, or regulation, to require protection against
    unauthorized disclosure for reasons of national security."

    Condensate means hydrocarbon liquid separated from natural gas that condenses due to changes in
    temperature, pressure, or  both, and remains liquid at standard conditions.

    Covered process means a process that has a regulated  substance present in more than  a threshold  quantity
    as determined under ง68.115.

    Crude oil means any naturally  occurring, unrefined petroleum liquid.

    Designated agency means the state, local, or Federal agency designated by the state under the provisions
    ofง68.215(d).

    DOT means the United States Department of Transportation.
                                                  98

-------
R10 Risk Management Training Manual                                              EPA 910-K-10-001    March 2010
    Environmental receptor means natural areas such as national or state parks, forests, or monuments;
    officially designated wildlife sanctuaries, preserves, refuges, or areas; and Federal wilderness areas, that
    could be exposed at any time to toxic concentrations, radiant heat, or overpressure greater than or equal to
    the endpoints provided in ง68.22(a), as a result of an accidental release and that can be identified on local
    U. S. Geological Survey maps.

    Field gas means gas extracted from a production well before the gas enters a natural gas processing plant.

    Hot work means work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing
    operations.

    Implementing agency means the state or local agency that obtains delegation for an accidental release
    prevention program under subpart E, 40 CFR part 63. The implementing agency may, but is not required to,
    be the state or local air permitting agency. If no state or local agency is granted delegation,  EPA will be the
    implementing agency for that state.

    Injury means any effect on a human that results either from direct exposure to toxic concentrations; radiant
    heat; or overpressures from accidental releases or from the direct consequences of a vapor cloud explosion
    (such as flying glass, debris, and other projectiles) from an accidental release and that requires medical
    treatment or hospitalization.

    Major change means introduction of a new process, process equipment, or regulated substance, an
    alteration of process chemistry that results in any change to safe operating limits, or other alteration that
    introduces a new hazard.

    Mechanical integrity means the process of ensuring that process equipment is fabricated from the proper
    materials of construction and is properly installed,  maintained, and replaced to prevent failures and
    accidental releases.

    Medical treatment means treatment,  other than first aid, administered by a physician or registered
    professional personnel under standing orders from a physician.

    Mitigation or mitigation system  means specific activities, technologies, or equipment designed or deployed to
    capture or control substances upon loss of containment to minimize exposure of the public  or the
    environment. Passive mitigation means equipment, devices, or technologies that function without human,
    mechanical, or other energy input. Active mitigation means equipment, devices, or technologies that need
    human, mechanical, or other energy  input to function.

    FPA means the National Fire Protection Association.

    Natural gas processing plant (gas plant) means any processing site engaged in the extraction of natural gas
    liquids from field gas, fractionation of mixed natural gas liquids to natural gas products, or both, classified as
    North American Industrial Classification System (NAICS) code 211112 (previously Standard Industrial
    Classification  (SIC) code 1321).

    Offsite means areas beyond the property boundary of the  stationary source, and areas within the property
    boundary to which the public has routine and unrestricted  access during or outside  business hours.

    OSHA means the U.S. Occupational Safety and Health Administration. Owner or operator means any
    person who owns, leases, operates, controls, or supervises a stationary source.

    Petroleum refining process unit means a process unit used in an establishment primarily engaged in
    petroleum refining as defined in NAICS code 32411 for petroleum refining (formerly SIC code 2911) and
    used for the following: Producing transportation fuels (such as gasoline, diesel fuels, and jet fuels), heating
    fuels (such as kerosene, fuel gas distillate, and fuel oils), or lubricants; Separating petroleum; or Separating,
    cracking, reacting, or reforming intermediate petroleum streams.
                                                    99

-------
R10 Risk Management Training Manual                                              EPA 910-K-10-001    March 2010
    Population means the public.

    Process means any activity involving a regulated substance including any use, storage, manufacturing,
    handling, or on-site movement of such substances, or combination of these activities. For the purposes of
    this definition, any group of vessels that are interconnected, or separate vessels that are located such that a
    regulated substance could be involved in a potential release, shall be considered a single process.

    Produced water means water extracted from the earth from an oil or natural gas production well, or that is
    separated from oil or natural gas after extraction.

    Public means any person except employees or contractors at the stationary source.

    Public receptor means offsite  residences, institutions (e.g., schools, hospitals), industrial, commercial, and
    office buildings, parks, or recreational areas inhabited or occupied by the public at any time without
    restriction by the stationary source where members of the public could be exposed to toxic concentrations,
    radiant heat, or overpressure, as a result of an accidental release.

    Regulated substance is any substance listed pursuant to section 112(r)(3) of the Clean Air Act as amended,
    in ง68.130.

    Replacement in kind means a replacement that satisfies the design specifications.

    Retail facility means a stationary source at which more than one-half of the income is obtained from direct
    sales to end users or at which more than one-half of the fuel sold, by volume, is sold through a cylinder
    exchange program.

    RMP means the risk management plan required under subpart G of this part.

    Stationary source means any buildings, structures, equipment, installations, or substance emitting stationary
    activities which belong to the same industrial group, which are located on one or more contiguous
    properties, which are under the control of the same person (or persons under common control), and from
    which an accidental release may occur. The term stationary source does not apply to transportation,
    including storage incident to transportation, of any regulated substance or any other extremely hazardous
    substance under the provisions of this part. A stationary source includes transportation containers used for
    storage not incident to transportation and transportation containers connected to equipment at a stationary
    source for loading or unloading. Transportation includes, but is not limited to, transportation subject to
    oversight or regulation under 49 CFR parts 192, 193, or 195, or a state natural gas or hazardous  liquid
    program for which the state has in effect a certification to DOT under 49 U.S.C. section 60105. A stationary
    source does not include naturally occurring hydrocarbon reservoirs. Properties shall not be considered
    contiguous solely because of a railroad or pipeline right-of-way.

    Threshold quantity means the quantity specified for regulated substances pursuant to section 112(r)(5) of
    the Clean Air Act as amended, listed in ง68.130 and determined to be present at a stationary source as
    specified in ง68.115 of this part.

    Typical meteorological conditions means the temperature, wind speed, cloud cover, and atmospheric
    stability class,  prevailing at the site based on data gathered at or near the site or from a local meteorological
    station.

    Vessel means  any reactor, tank, drum, barrel, cylinder, vat, kettle, boiler, pipe, hose, or other container.

    Worsf-case release means the release of the largest  quantity of a regulated substance from a vessel or
    process line failure that results in the greatest distance to an  endpoint defined in ง68.22(a).

    [59 FR 4493, Jan. 31, 1994, as amended at 61 FR 31717, June 20, 1996; 63 FR 644, Jan. 6, 1998; 64 FR 979, Jan. 6,
    1999; 65 FR 13250, Mar. 13,2000]
                                                    100

-------
R10 Risk Management Training Manual
                                                           EPA 910-K-10-001   March 2010
                             Definitions of Acronyms

   AlChE       American Institute of Chemical Engineers
   ALOHA      Arial Locations of Hazardous Atmospheres
   ANSI         American National Standards Institute
   API          American Petroleum Institute
   ASHRAE     American Society of Heating, Refrigerating and Air-Conditioning
                Engineers
   ASME       American Society of Mechanical Engineers
   ASTM        American Society of Testing Materials
   BLEVE       Boiling Liquid, Expanding Vapor Explosion
   CAA         Clean Air Act
   CAS         Chemical Abstracts Service
   CBI          Confidential Business Information
   CCPS        Center for Chemical Process Safety
   CEPPO      Chemical Preparedness and Prevention Office
   CERCLA     Comprehensive Environmental Response, Compensation and Liability
                Act
   CFR         Code of Federal Regulations
   CSB         U.S. Chemical Safety and Hazard Information Board
   DOT         U.S. Department of Transportation Environmental Protection Agency
   EPA         U.S. Environmental Protection Agency
   EPCRA      Emergency Planning and Community Right-to-Know Act
   FMEA        Failure Mode and Effects Analysis
   FTA         Fault Tree Analysis
   HAZMAT     Hazardous Materials
   HAZOP      Hazard and Operability Analysis
   HAZWOPER  Hazardous Waste Operation and Emergency Response
   IDLH         Immediately Dangerous to  Life and Health
   MAR         International Institute of Ammonia Refrigeration
   LEPC        Local Emergency Planning Committee
   LFL         Lower Flammable Limit
   MOC         Management of Change
   MSDS       Material Safety Data Sheet
   NAICS       North American Industrial Classification System
   NFPA        National Fire Protection Association
   NIOSH       National Institute for Occupational Safety and  Health
   NOAA       National Oceanographic and Atmospheric Administration
   NRC         National Response Center
   OSHA       Occupational Safety and Health Administration
   P&ID         Process and Instrumentation Diagram
   PFD         Process Flow Diagram
   PHA         Process Hazard Analysis
   PSI          Process Safety Information
   PSM         Process Safety Management
   PSSR        Pre-Startup Safety Review
   RMP         Risk Management Program
   SERC        State Emergency Response Commission
   SIC          Standard Industrial Classification
                                       101

-------