American Petroleum Institute

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

Annotation

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.