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Document API PUBL 761 is offered by IHS as part of an online subscription. This subscription contains many documents on the same topic.
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API PUBL 761 Document Information:
Title
Model Risk Management Plan Guidance for Exploration and Production (E&P) Facilities
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 a risk management program
(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 an oil
and gas exploration and
production (E&P) facility can prepare an RMPlan. A "model" or an
example of an RMPlan executive
summary is provided in Appendix C. The main sections of the Guide
provide suggestions on how
E&P facilities can perform some of the underlying work necessary
to comply with the RPM rule;
some of this information must be summarized in the RMPlan.
This Guide presumes that E&P facilities are in compliance with
relevant codes, standards, and
regulations. 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 information 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 the
information provided in this Guide.
However, it is hoped that the ideas in this Guide will be generally
useful to all E&P facility
operators so that the RMPlans can be prepared in an efficient way that
reduces compliance costs and
promotes consistency and understanding.
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. Companies should consider using guidance provided in
Guidance for Implementation of the
General Duty Clause Clean Air Act Section 112(r)(1), published by EPA,
and their own judgment to
determine how best to comply with the general duty clause.
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