Model Risk Management Plan Guidance for Petroleum Refineries

This Guide provides some information on how a petroleum refinery can prepare an RMPlan. This Guide presumes that refineries are aware of relevant codes, standards, and regulations which preceded the RMP rule. The Guide focuses on areas of work required by the RMP rule that extend beyond existing compliance activities.

The Guide does not go into great detail on how to implement a process safety management (PSM) program, it focuses on strategies for summarizing the results of the prevention program activities for use in the RMPlan.
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.
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.
A "model" or template of an RMPlan executive summary is provided in Appendix C.

Table of Contents
Special Notes
Preface
Executive Summary
How To Use This Guide
Acronyms
1: Introduction
1.1 PURPOSE AND SCOPE
1.2 OVERVIEW OF THE RMP RULE
1.3 DESCRIPTION OF COMMON REFINERY PROCESSES/ACTIVITIES
2: Determining RMP Coverage at a Refinery
2.1 IDENTIFYING CANDIDATE REFINING OPERATIONS SUBJECT TO RMP RULE COVERAGE
2.2 IDENTIFYING REGULATED SUBSTANCES IN REFINING PROCESSES
2.3 DETERMINING PROCESS INVENTORY OF REGULATED SUBSTANCES
2.4 CONSIDERING OTHER EXEMPTIONS
2.5 ESTABLISHING COVERED PROCESSES
Tables
3: RMP Program Levels and Management System
3.1 PROGRAM LEVEL ELIGIBILITY CRITERIA
3.2 ASSESSING PROGRAM LEVEL STATUS FOR REFINERY PROCESSES
3.3 ESTABLISHING AN RMP MANAGEMENT SYSTEM
Table 3-1 Program Level Considerations
4: RMP Rule—Hazard Assessment
4.1 IDENTIFYING THE OBJECTIVES OF THE HAZARD ASSESSMENT
4.2 SELECTING CANDIDATE WORST-CASE RELEASE SCENARIOS
4.3 SELECTING CANDIDATE ALTERNATIVE RELEASE SCENARIOS
4.4 MODELING PARAMETERS
4.5 PERFORMING MODELING CALCULATIONS
4.6 IDENTIFYING PUBLIC AND ENVIRONMENTAL RECEPTORS
4.7 COMPILING A 5-YEAR ACCIDENT HISTORY
4.8 DOCUMENTATION AND UPDATING OF THE OFFSITE CONSEQUENCE ANALYSIS
4.9 EXAMPLE OF A REFINERY HAZARD ASSESSMENT
4.10 DISCUSSION OF HAZARD ASSESSMENT ISSUES
Figures
Tables
5: RMP Rule—Prevention Program
5.1 EMPLOYEE PARTICIPATION
5.2 PROCESS SAFETY INFORMATION
5.3 PROCESS HAZARD ANALYSIS
5.4 OPERATING PROCEDURES
5.5 TRAINING
5.6 CONTRACTORS
5.7 PRE-STARTUP SAFETY REVIEWS
5.8 MECHANICAL INTEGRITY
5.9 HOT WORK PERMITS (SAFE WORK PRACTICES)
5.10 MANAGEMENT OF CHANGE
5.11 INCIDENT INVESTIGATION
5.12 COMPLIANCE AUDITS
6: RMP Rule—Emergency Response Program
7: RMP Rule—Risk Management Plan
7.1 DEVELOPING AN EXECUTIVE SUMMARY
7.2 COMPLETING THE RMP DATA ELEMENTS CHECKLIST
7.3 DISTRIBUTION/COMMUNICATION OF OCA INFORMATION IN THE RMPIan
7.4 RESUBMITTING A REVISED RISK MANAGEMENT PLAN
Table 7-1 Elements of the RMPIan Executive Summary
8: Preparing for an RMP Compliance Audit
8.1 THE RMP AUDIT PROCESS
8.2 DOCUMENTATION TO SUPPORT RMP COMPLIANCE
Table 8-1 Definitions of Auditing Terminology
Table 8-1 Definitions of Auditing Terminology (cont'd)
REFERENCES
APPENDIX A-An Approach for Determining the Quantity of Regulated Flammable Substances in Distillation Columns/Towers
APPENDIX B-Vapor Cloud Explosion Modeling Using the Approach in EPA's OCA Guidance
APPENDIX C-Refinery Model Risk Management Plan Executive Summary
APPENDIX D-RMPIan Submission Forms
APPENDIX E-Glossary
APPENDIX F-Consolidated Version of the RMP Rule (40 CFR 68)
APPENDIX G-Worksheets for Facilitating Compliance with the RMP Rule
APPENDIX H-EPA's RMP Audit Checklist

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