EPA Region 10 Chemical Emergency Prevention and Planning Newsletter Jan/Feb 2011


Clean Air Act 112(r) Risk Management Program (RMP!
January - February 2011
US EPA Region 10
Best Practices
•	Document Management
•	Sample document
control policy
Where is your PSI?
RMP Training for 2011
New Feature
CHEMICAL EMERGENCY
PREVENTION & PLANNING
Newsletter
US EPA Region 10.
ERU ECL-116
1200 6th Avenue, Suite 900
Seattle, Washington 98101
206.553.1255
Fax: 206.553.0124
http://vosernite.epa.gov/R10/airpage.
nsf/Enforcement/rrnp
Newsletter Contacts:
For RMP: Javier Morales at
morales.iavier@epa.gov
For SPCC/FRP: AK: Matt Carr at
carr.matthew@epa.gov
WA OR ID: Michael Sibley at
sibiey.michael@epa.gov
For EPCRA: Suzanne Powers at
powers.suzanne@epa.gov
For free Subscription:
allen.stephanie@epa.gov
REPORT
<2
CHEMICAL or OIL SPILLS
to the NATIONAL RESPONSE CENTER
1-800-424-8802
Best Practices from the Field
Through RMP training and inspections we meet many talented
people with innovative ideas. This new feature in the CEPP
Newsletter "Best practices from the field" will feature the know-
how and best practice methods from facilities with excellent
safety programs. The first article presents an example of how
to manage your RMP/PSM documents. We thank the author,
Dawn Kominski, Director of Regulatory Affairs, Tessenderlo
Kerley, Inc. for sharing this "best practice".
RMP/PSM Document Management
The Risk Management Program is very paperwork intensive and
adequate recordkeeping is a constant challenge. For companies with
multiple locations having a written, uniform system for recordkeeping
is essential to maintaining RMP and PSM (Process Safety Information
-OSHA) documentation.
A written recordkeeping program detailing where documentation
should be stored allows for any employee at a site to find needed
information. This is important if the person normally responsible for
the information is out and another employee needs a document. It is
especially important during an audit if key personnel are out of the
office. For employees that travel between multiple sites, a uniform
program allows them to easily find documentation regardless of which
site they are visiting.
To help our facilities conquer the paperwork challenge, an internal cor-
porate document was developed that detailed how RMP documents
are to be stored. The general framework is as follows:
•	A separate area is to be designated for RMP documents. This
area could be a file cabinet or even a separate room.
•	All documents are to be filed by RMP element. This allows docu-
ments to be retrieved by element at any time.
•	If information is not in the specific RMP element folder, a doeu-
continued on Page 2
Page 1

-------
Chemical Emergency Prevention & Planning Newsletter
January - February 2011
^Best Practices from the Field^
RMP/PSM Document Management
continued from Page 1
ment is to be inserted stating where the
information can be found (i.e., operating
procedures - control room; equipment files
- maintenance building).
• The RMP area is to be accessible at all
reasonable times to employees.
Having a separate area for all documents
and/or a list of where the documents can be
found is helpful in keeping the documents
updated and during an audit or inspection. It
also gives employees one place to find critical
information. For smaller facilities where there
may not be room for a separate office/area for
RMP information, a conference room works
well. Conference rooms are typically located
in common areas and may be large enough to
add a file cabinet.
Once information is gathered in one area,
keeping the information updated is the next
challenge. The written document control
program can be used to detail responsibilities
for updating information or a separate respon-
sibilities document can be generated. The
responsibility section can be as detailed as a
responsibility list for each separate document
or it can be very general and state what job
functions have an impact on updating the vari-
ous RMP documents. The person(s) that have
the responsibility for updating RMP informa-
tion may vary by facility depending on avail-
able staff and whether there are corporate
resources available to assist the facility.
A written program for recordkeeping (location
and updating requirements) does not need to
be elaborate. However, having a written pro-
gram will help small and large facilities in their
efforts to maintain up-to-date records and
can be especially helpful to maintaining RMP
documentation as employees change over
time. (See sample document in next article.)
\	J
RMP Document Control continued:
Example of recordkeeping program
RMP/PSM Filing and Document
Control/Circulation Policy
•	The plant shall maintain a separate PSM filing
system
•	Separate files will be maintained for each PSM
element, with sub-files for each heading as listed
below.
15. Risk Management Plan Specific
Information (RMP Binder)
15.1	Copy of the most current plan
which includes:
•	Registration Information
•	Worst-case release scenario
analysis
•	Alternative release scenario
analysis
•	Off-site impacts including
o Population
o Environment
•	5 year Accident History
•	Prevention Program
•	Emergency Response information
•	Executive Summary
15.2	Copy of any plan updates
15.3	Appendices of backup information
•	Scenario descriptions, estimated
quantity released, rate, duration
•	Methodology used to determine
distance to endpoint
•	Data used to estimate population
and environmental receptors
•	Coordination with local emergency
responders
15.4	Management System
•	Document identifying person or
position with overall responsibility
of the risk management program
•	Document other persons
responsible for implementing
individual requirements of the risk
management program
Find the complete document in the Tools Section
of the Region 10 RMP webpage where all Best
Practices Sample Documents can be downloaded.
Link.
Page 2

-------
Chemical Emergency Prevention & Planning Newsletter	January - February 2011
How to apply your document control system -
Has anybody seen our process safety information (PSI) ??
(Reprinted from Process Safety Beacon 9/2010)
What is Process Safety information (PSi)? It is
the information about the process chemistry,
equipment and technology of your plant. It is
collected from many places inside and outside
your company: research and development,
engineering, operations, and also suppliers
of raw materials, process technology, and
equipment. As an operator or maintenance
person, your first exposure to the PSI may have
been at a Process Hazard Analysis (PHA).
The PSI was that stack of drawings, manuals,
documents, and books that provided information
to the PHA team. PSI is also frequently used
in Management of Change (MOC) reviews. It
is important to understand the existing system
SO yOU Can evaluate the consequences of	7 A piping and instrumentation drawing (P&ID)
proposed changes. For example, a new valve
must meet the specifications for the pipe
where it is installed. That means the valve,
gaskets, bolts, and other components all need
to be correct. How do you know? Verify them
according to the piping specifications in the PSI
from the plant engineering design.
Some other important examples of PSI include
piping and instrumentation drawings (1),
hazardous area classification drawings (2),
and the reports from process hazard analyses
(3), management of change reviews, incident
investigations, personal protective equipment
requirements, operating and maintenance
procedures, and others.
What can you do?
2. A hazardous area classification drawing
PSI is essential to safe plant operation and
maintenance, but it is valuable only if it is
correct, up to date, and used. And you
must know where to find it! Here are some
examples of things you can do to ensure that
the PSI for your plant is correct, and we are
sure you can think of many other examples:
• If asked to go into the plant and update
piping drawings, take that job seriously.
continued on Page 4


s
F* ir> Her
RnW*. D
Mir. Sun, Mr Ahmjm, Ptptr, Mr 5»<4!wm, Mr vwi ill frwn ibc ABC AfffMbm
Id 1IKP. - AIR SUPPLY LLNB TO	5VW1Y 5CFM 
3. Part of the documentation of a Process Hazard Analysis (PHA) study
Page 3

-------
Chemical Emergency Prevention & Planning Newsletter
January - February 2011
RMP/PSM Document Management
continued from Page 3
A valve not shown on the drawing may be the difference in
preventing a spill - you can't close it if you don't know it is there!
If you find that an operation is normally done differently from the
written operating procedure, tell your supervisor, so that either
the procedure is modified, or the operation is done as required by
existing procedures.
•	If you find an error on a drawing, tell your supervisor or plant
engineer so it can be corrected.
•	If you are trying to use a drawing and there are too many
corrections, tell your supervisor an engineer that the corrections
make the drawing confusing, and a new drawing is needed.
•	Remember that control system documentation is part of the PSI
and must be updated when changes are made.
Where Do I Go For More Information?
http://www.epa.gov/emerqencies/
rmp will be updated as new
information becomes available.
EPA maintains numerous listservs to
keep the public, state and local officials,
and industry up to date, including
several that pertain to emergency
management. You can sign up for our
list serve to receive periodic updates:
https://lists.epa.gov/read/all forums/
subscribe?name=callcenter_oswer
EPA Region 10 RMP Coordinator:
Javier Morales 206-553-1255
EPA Region 10 RMP Website:
http ://yose m ite. epa. gov/R 10/
C L E AN U P. N S F/s ites/rmp
Plan to attend the FREE EPA Risk
Management Training Day in your area
RISK MANAGEMENT
PROGRAM (RMP)
Training
Eugene, Oregon - March 17, 2011
Boise, Idaho - May 16, 2011
Seattle, Washington - Coming Fall 2011
Additional information can be found on
EPA Region 10's RMP Website: Training Information
I Q \
w
Superfund, TRI, EPCRA, RMP & Oil
Information Center - The Information
Center can also answer questions
related to Clean Air Act section 112(r)
and RMP reporting requirements.
(800) 424-9346 or TDD (800) 553-7672
(703) 412-9810 or TDD (703) 412-
3323 in the Washington, D.C. area
Normal Hours of Operation:
Monday - Thursday 10:00 a.m.
- 3:00 p.m. Eastern Time
Extended Hours of Operation
(May, June, and July):
Monday - Friday 9:00 a.m. -
5:00 p.m. Eastern Time
Closed Federal Holidays
http://www.epa.gov/superfund/
contacts/infocenter/
Risk Management Program (RMP)
Reporting Center - The Reporting
Center can answer questions about
software or installation problems.
The RMP Reporting Center is available
from 8:00 a.m. to 4:30 p.m., Monday
through Friday, for questions on the
Risk Management Plan program.
(703) 227-7650 (phone)
RMPRC@epa.cdx.net (e-mail)
This newsletter provides information on
the EPA Risk Management Program,
EPCRA, SPCC/FRP and other issues
relating to Accidental Release Prevention
Requirements. The information should
be used as a reference tool, not as
a definitive source of compliance
information. Compliance regulations are
published in 40 CFR Part 68 for CAA
section 112(r) Risk Management Program,
40 CFR Part 355/370 for EPCRA, and
40 CFR Part 112.2 for SPCC/FRP.
Page 4

-------