American Petroleum Institute

Risk Management Program (RMP) Rule (40 CFR 68) Developments: June 1998 to June 1999
 N PUBL 760 ERTA

Annotation

1.1 PURPOSE AND SCOPE

The Environmental Protection Agency's (EPA's) risk management program (RMP) rule (40 CFR 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 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 rigid standard that must be followed by everyone. Site-specific needs may demand an RMPlan development approach that differs from that provided in this Guide. However, it is hoped that the ideas in this Guide will be generally useful to all refinery operators so that RMPlans can be prepared in an efficient way that reduces compliance costs and promotes consistency and understanding.