API PUBL 760 Model Risk Management Plan Guidance for Petroleum Refineries Guidance in Complying with EPA's RMP Rule (40 Code of Federal Regulations, Part 68)

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API PUBL 760 Document Information:

Title
Model Risk Management Plan Guidance for Petroleum Refineries Guidance in Complying with EPA's RMP Rule (40 Code of Federal Regulations, Part 68)

American Petroleum Institute

Publication Date:
Feb 1, 2001

Scope:

PURPOSE AND SCOPE

The Environmental Protection Agency's (EPA's) risk management program (RMP) rule (40 CFR Part 68) requires affected facilities to implement an RMP and develop a risk management plan (RMPlan). An RMP consists of three components: hazard assessment, prevention program, and emergency response program. Implementing these activities requires a facility to establish management systems to execute the necessary work to comply with the rule.

The RMPlan, on the other hand, is simply a description of the RMP activities carried out in the facility. A facility must submit its RMPlan to a central location from which the RMPlan will be available to regulators, local emergency planners, and the public.

The purpose of this Guide is to provide some information on how a petroleum refinery can prepare an RMPlan. A "model" or template of an RMPlan executive summary is provided in Appendix C. The main sections of the Guide provide suggestions on how refineries can perform some of the underlying work necessary to comply with the RMP rule; some of this information must be summarized in the RMPlan.

This Guide presumes that refineries are aware of relevant codes, standards, and regulations which preceded the RMP rule. Thus, the Guide focuses on areas of work required by the RMP rule that extend beyond existing compliance activities. For example, the Guide provides detailed suggestions on how to perform hazard assessments. On the other hand, the Guide does not go into great detail on how to implement a process safety management (PSM) program. Rather, it focuses on strategies for summarizing the results of the prevention program activities for use in the RMPlan.

Finally, this Guide is not a standard that must be followed by everyone. Site-specific needs may demand an RMPlan development approach that differs from that provided in this Guide.

Note: Section 112(r)(1) of the CAA entitled "Purpose and General Duty" (often referred to as the general duty clause) states the following:

It shall be the objective of the regulations and programs authorized under this subsection to prevent the accidental release and to minimize the consequences of any such release of any substance listed... [in Subpart F of 40 CFR 68]..or any other extremely hazardous substance. The owners and operators of stationary sources producing, processing, handling, or storing such substances have a general duty in the same manner and to the same extent as Section 654 of Title 29 to identify hazards which may result from such releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur.

This "general duty clause" has been in effect since the 1990 CAA Amendments were enacted. This Guide discusses compliance with the RMP rule only, and not the general duty clause of the CAA. Section 113(b) of the CAA allows EPA to assess penalties of up to $27,500 per day for each violation.

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