Florida

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Preparing for Facility Risk Management Plan Audits
Florida Accidental Release Prevention and Risk
Management Planning (ARP/RMP) Act
State Emergency Response Commission
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Background Information
1998 - Florida DCA received delegation to
implement Section 112(r) Risk Management
Program regulations. Floridas RMP Program
fits well with DCAs existing emergency planning
and response programs (Division of Emergency
Management EPCRA Program). Florida State
Emergency Response Commission - SERC
Involvement. Programs Philosophy - Emphasizes
technical assistance to facilities to achieve
compliance with RMP requirements to reduce
occurrence of chemical accidents.
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Purpose of Section 112(r) and the Risk Management
Program Requirements

• To reduce prevent accidental chemical
  releases.
• To reduce the severity minimize the
  consequences of chemical releases.
• To improve coordination communication between
  regulated facilities local emergency
  preparedness response agencies to improve
  emergency response.

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Facilities Typically Regulated Under RMP

• Drinking water treatment plants
• Wastewater treatment plants
• Food and cold storage facilities
• Ammonia retailers
• Chlorine repackagers and distributors
• Chemical manufacturers
• Utilities
• Petrochemical facilities
• Pulp mills
• Fertilizer producers
• Swimming pool service/supply businesses
• Military, energy installations (mostly federal
  facilities)

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Program Level Screening for Regulated Processes
Regulated processes assigned to one of three
program levels, based on G Potential for
off-site consequences G Accident history G OSHA
Process Safety Management (PSM) G Within certain
Standard Industrial Classification (SIC) Codes
identified as having significant accident
history. lt Program 1 - no offsite impacts lt
Program 2 - streamlined prevention program (7
components) lt Program 3 - full RMP program (12
components)
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Program Level 1 Process
No offsite accident history in previous 5
years. No offsite consequences associated with
WCR. No public receptors located w/in
distance to toxic or flammable endpoints.
Emergency response procedures between facility
local response agencies. Mostly remotely
located facilities or processes using listed
flammables.
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Program Level 3 Processes

• Public receptors w/in distance to toxic or
  flammable endpoints.
• Accident history
• Not eligible for Program 1
• AND
• Process subject to OSHA PSM Standard (29 CFR
  1910.119)
• OR
• Process is in SIC Code with significant
  accident history

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Program Level 2 Processes

• Public receptors w/in distance to toxic or
  flammable endpoints.
• Accident history.
• Not eligible for Program 1 or 3
• Florida Facilities - Majority of processes are
  Program 2 or Program 3 processes.

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Overview of Risk Management Program Requirements
If facilities use, store, manufacture, or
process substances on the Section 112(r) list
above TQ, must develop and implement a Risk
Management Program. Section 112(r) Listed
Chemicals - 77 Toxic Substances 63 Flammable
Substances. Most Common in Florida -
Ammonia, Chlorine, Sulfur Dioxide, Hydrochloric
Acid, Hydrofluoric acid, Nitric acid.
Requirements Complexity vary based on Program
Level of Process.
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Major Elements of a Risk Management Program
S Hazard Assessment Off-Site Consequence
Analysis G Worst-Case Release Scenario - All G
Alternative Release Scenario - Programs 2 3
5-Year Accident History - All S Document
Management Program - Programs 2 3 S Prevention
Program - Programs 2 (streamlined version) 3
(comprehensive) S An Emergency Response Program
- Programs 2 3 (Note Program 1 requires
coordination with local response agencies)
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Overview of RMP requirements, cont...
Risk Management Plan (RMP) - Summary of
facilitys Risk Management Program must be
submitted to the EPAs National RMP Reporting
Center. The RMP contains S Facility
Registration S Hazard Assessment S Prevention
Program S Emergency Response Program S Executive
Summary S Certification
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Prevention Program (Program Level 2)
Specific Requirements for Program 2 Program 3
comprehensive. Reference handouts audit
checklists. Required Prevention Program
Components G Safety information G Hazard
review G Operating Procedures G Training G
Maintenance G Compliance audits G Incident
investigations
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Prevention Program (Program Level 3)
Required Prevention Program Components
G Process Safety Information G Process Hazards
Analysis G Operating Procedures G Training G
Mechanical Integrity G Management of Change
G Pre-Startup Review G Compliance Audits G
Incident Investigation G Employee Participation G
Hot Work Permit G Contractor Program
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Emergency Response Program Requirements
Facilities with Program 1 processes must
coordinate with local emergency response
agencies. Facilities with Program 2 or Program
3 processes must coordinate with local emergency
responders if employees not required to respond
to chemical releases at facility. Must also
have appropriate mechanisms in place to notify
emergency responders.
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Emergency Response Program Requirements, cont...
For Program 2 or 3 Facilities that will respond
to chemical releases. Written ER program is
developed maintained onsite.
Procedures/actions to be taken in event of
chemical release. Procedures for notifying the
public local responders for releases.
Information on first aid medical treatment.
Procedures for use of ER equipment inspection,
testing maintenance. ERP Coordination with
local responders. Training for employees.
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Preparing for Facility RMP Audits
lt Audit Selection Criteria lt Overview of DCAs
RMP Audit Process lt On-Site Audit Findings lt
Available Technical Resources
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Audit Selection Criteria

• Previous and current accident history of
  facility
• Overall accident history of other facilities in
  same industry
• Facility location proximity to population
  centers
• Chemical characteristics quantities of
  RMP-regulated chemicals on-site
• Compliance with or inspection by allied agency
  programs
• Results of compliance audits
• Neutral, random oversight
• Other factors deemed necessary by DCA to protect
  public safety health.

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Overview of the DCAs RMP Audit Process

• Off-Site Audit Activities - Basic Desk Audit
• S Initial Phase of DCAs RMP audit process.
• S Focuses on the data contained in RMP summary.
• S Compliance with plan requirements.
• S Use Desk Audit Checklist.
• S Determination of the following
• Whether rule applies to facility
• Appropriate program level
• Completeness adequacy of data submitted in
  RMP
• Review for completeness, accuracy, dates,
  scenario data.

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RMP Audit Process (cont...)
Second Phase of Desk Audit - Documentation
Review Send audit notification letter
requesting RMP supporting documentation.
Request for PHA, training records, incident
investigation reports, ERP, compliance audit
reports. Use Documentation Review / On-Site
Audit Checklist. Review of supporting
documentation. This approach reduces time on
site. Helps determine focus of audit visit.
Schedule date(s) for on-site audit. Send
notification of on-site audit.
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RMP Audit Process (cont...)

• On-site audit activities - Focus on overall Risk
  Management Program
• S Plant Tour of facilitys process chemicals
  operations.
• S Interview facility representatives.
• S Review of facility operations, procedures,
  supporting RMP documentation, etc.
• S Adequacy completeness of RMP documentation.
• S Development implementation of required RMP
  elements.
• S Emergency Response - Coordination with local
  response agencies.
• S Document findings - On-Site Audit Checklist.

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What Can You Do to Prepare for an RMP Audit?
Review DCAs Audit Checklists. Obtain
organize RMP supporting documentation prior to
scheduled audit date. Include SOPs, hazard
assessments, PHA process safety information,
training records, maintenance logs, MOC forms, ER
procedures, etc.). Determine appropriate
facility personnel to include in audit. Most of
all ... Dont Worry! Our primary goal is
compliance assistance !
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What Should You Expect During an On-Site Audit?
RMP Audit Team - Usually 2 persons LEPC Staff
Contact invited to accompany team. Audit agenda
assignments faxed prior to visit date.
Opening meeting (audit purpose/objectives,
agenda, safety issues, etc.) Tour of facilitys
regulated chemicals and processes. Review RMP
supporting documentation. Interview facility
representatives. Exit briefing (findings,
identified deficiencies, recommendations,
schedule for audit report, schedule for
corrections, copy of audit checklist).
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What Should You Expect After an On-Site Audit?
DCA issues Preliminary Determination Report S
Includes audit teams observations, findings,
recommendations. S Identifies deficiencies to be
corrected S Identifies necessary revisions to
RMP S Includes timetable(s) for correcting
deficiencies and/or revising RMP
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What Should You Expect After an On-Site Audit?
(cont...)
Facility Response to Audit Report S Must be
received within approved timetable(s) S Usually
allow 60 - 90 days for corrections revisions. S
Written request for extension prior to deadline
date, if needed. S Upon receipt review of
requested information, DCA issues Final
Determination Report - If information correct
complete. Interim Audit Report - If additional
information is necessary.
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General On-Site Audit Findings (Note Based on
30 on-site RMP audits)

• WTPs WWTPs
• Ammonia refrigeration
• Chlorine Other Chemical Repackagers
• Inadequate documentation, development, and/or
  implementation of 1 or more prevention program
  components.
• Bookshelf Generic Programs. Good program,
  but not implemented.
• Many facilities complying with technical
  aspects of program, but documentation incomplete.

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Specific On-Site Audit Findings
Hazard Assessments - Not available onsite
Incorrect modeling parameters. Incorrect
program level status S Program Level 1 - Public
receptors were identified within endpoint
distances. S Program Level 2 - Refrigeration
facilities subject to OSHAs PSM. Most
deficiencies to date pertained to S Mechanical
Integrity S Operating Procedures S Training
Program S PHA
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Specific On-Site Audit Findings
Mechanical Integrity - PM protocols not
developed or implemented. Inspection and testing
not performed. Minimal record keeping.
Operating Procedures - Operating phases, limits
not addressed. Mostly emergency shutdown
assignments. Training Program - Operator
Maintenance training incomplete.
Documentation. PHA - incomplete hazard ID
(such as hurricanes, overpressurization,
equipment failure, human error, etc.)
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Other On-Site Audit Findings

• Management of Change Pre-Startup Safety
  reviews - not performed.
• Contractor Safety Program - Non-existent. Not
  implemented
• Emergency Response Program - Not coordinated
  with local responders. Procedures for ER
  equipment use inspections not documented.
  Inadequate training.

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Other Related Regulations
OSHA Process Safety Management - Program Level
3 processes SARA Title III / EPCRA - Tier Two
reports Section 304 requirements - Accident
Notification S Notify State Warning Point within
15 minutes of release S 1-800-320-0519
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Available Technical Assistance and Resources
Contact DCAs Risk Management Planning Program
staff at S [phone] S [phone]
(Florida only) Floridas RMP Program web page
for state federal requirements, audit
checklists, step-by-step guidelines. www.dca.state
.fl.us/cps/arprmp/start.htm Guidance
documents, model RMP plans, other RMP resources
also available from EPA www.epa.gov/ceppo