I have an ongoing project with an entity that takes me on a trip through hundreds of Risk Management Plans that have been submitted to the EPA.  Now most EHS professionals know that the majority of the data and text submitted in these plans is available on the world-wide web for anyone and everyone to see.  The only thing that is not supposed to be published is the results of the Off-Site Consequence Analyzes and even that data is found in about 10% of the plans I review.  But senior managers are often shocked at what is "published" about their facility when they are made aware of what I find and in many cases, the information is woefully inaccurate and sometimes just flat out wrong.  Case in point...

I was sorting some data for the client and came across an anhydrous ammonia leak that killed six (6) emergency responders in Indiana back in 2015.  Do you remember that incident?  I sure did not and tracking chemical incident back in 2015 was something I did on this site each week.  So I began to question my ability to gather accurate accident information and began to "Google" to find this catastrophic incident.  I even searched the OSHA Fatality Database but then it dawned on me that IN is an OSHA State Plan, so I go to the OSHA State website looking for any evidence of this accident.  I find nothing; other than the incident in my Incident Alerts Database from 2015 of which makes no mention of killing 6 responders.  The RMP states the accident was an overpressure event releasing 446 pounds of NH3 via the Relief Valves.  But here is what anyone can see:

Names and location have been removed to protect the company...

Err RMP 6 FFs died

For the record, when I find one of these errored reports, especially when the RMP preparer is a 3rd party like myself, I do send the RMP contact an e-mail bringing these concerns to their attention.  Sadly I find the majority of these errors are never "corrected"; even in 5-year updates they somehow find a way to NOT correct the record.  I see some RMPs that contain incidents from 2001 in a 2016/17 5-year update!

Lastly, double and triple check that your Worst-Case and Alternative-Case release scenarios are NOT included in your Executive Summary.  This is actually a citable error, although it is rarely cited  by EPA.  This data was supposed to have been removed way back in 2000!   Just last year EPA sent out a security notice regarding this OCA data and their concerns of the data falling into the wrong hands.  The Chemical Safety Information, Site Security and Fuels Regulatory Relief Act (CSISSFRRA), signed into law on August 5, 1999, is the basis for the regulations and restrictions described in this notice. CSISSFRRA was enacted to address concerns that Internet posting of OCA sections of RMPs would pose law enforcement and national security risks.

Just a ballpark number, but a quick and tricky sorting of RMP data indicates there are over 1,000 ACTIVE plans and another 1,600 deregistered plans that mention their OCA distances in their executive summary.  I can not say how one can find this information but this is what I am talking about, taken from an RMP that was submitted just last year (2016) ...

NOTE:  I have removed the security sensitive data!


3. Worst-Case Release Scenarios

Plant 2: Ammonia, anhydrous

Failure of a High-Pressure Steel tank through a puncture or failure at the valve will have no effect on the adjacent ammonia tank. However, in the worst case scenario the maximum combined quantity of ammonia stored in the 10,000 gallon and 1,000 gallon tank equal 9,650 gallons as they are kept only 87% full. This amounts to XXXXXXXXX lbs of ammonia. If this maximum quantity of ammonia (XXXXXXXXX lbs) was simultaneously released from both tanks, the resulting denser-than-air vapor would release at ground level with a toxic endpoint distance of XXXXXXXXX miles. This distance extends past the property boundaries and would affect the surrounding population of XXXXXXXXX. The toxic concentration endpoint for anhydrous ammonia is 0.14 mg/l. (200 ppm).

Assumptions and Calculations follow (OCA Guidance):

RMP*CompVer 1.07

Results of Consequence Analysis

Chemical: Ammonia, anhydrous
CAS #: 7664-41-7
Category: Toxic Gas
Scenario: Worst-case
Liquefied under pressure
Quantity Released: REMOVED BY ME FOR SECURITY CONCERNS BUT AVAILABLE ON THE WWW
Release Duration: 10 minutes
Release Rate: REMOVED BY ME FOR SECURITY CONCERNS BUT AVAILABLE ON THE WWW
Mitigation Measures: Release in enclosed space, in direct contact with outside air

Topography: Urban surroundings (many obstacles in immediate area)
Toxic Endpoint: 0.14 mg/L; basis: ERPG-2
Estimated Distance to toxic endpoint: REMOVED BY ME FOR SECURITY CONCERNS BUT AVAILABLE ON THE WWW

- - - - - - - Assumptions About This Scenario- - - - - - -
Wind Speed: 1.5 meters/second (3.4 miles/hour)
Stability Class: F
Air Temperature: 77A F (25A C)
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

4. Alternative Case Release Scenario

Plant 2: Ammonia, anhydrous

An accidental release of ammonia for both processes would more likely occur as a result of a transfer hose failure. This type of release would occur at the time of receiving new quantities of ammonia and having the facility's ammonia tanks refilled. The transfer hose is 2" in diameter and is 22' long. If there were a failure in this hose, the resulting ammonia release would only involve the quantity of ammonia that existed within the transfer hose. This quantity is XXXXXXXXX pounds of ammonia.

With this of an ammonia release, the resulting toxic distance endpoint is <XXXXXXXXX miles. This would not extend past the property boundaries, therefore, this type of ammonia release would not generate a public health emergency.

Assumptions and Calculations follow (OCA Guidance):

RMP*CompVer 1.07

Results of Consequence Analysis

Chemical: Ammonia, anhydrous

CAS #: 7664-41-7
Category: Toxic Gas
Scenario: Alternative Case
Liquefied under pressure
Release Duration: 10 minutes
Release Rate: REMOVED BY ME FOR SECURITY CONCERNS BUT AVAILABLE ON THE WWW
Mitigation Measures: Release in enclosed space, in direct contact with outside air

Topography: Urban surroundings (many obstacles in immediate area)
Toxic Endpoint: 0.14 mg/L; basis: ERPG-2
Estimated Distance to toxic endpoint: REMOVED BY ME FOR SECURITY CONCERNS BUT AVAILABLE ON THE WWW

- - - - - - Assumptions About This Scenario- - - - - - -
Wind Speed: 3.0 meters/second (6.7 miles/hour)
Stability Class: D
Air Temperature: 77A F (25A C)
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -


So as shown above, there is a lot of information out there about RMP facilities and in too many cases there is too much information available.  I have yet to see EPA issue citations to a 3rd Party "Preparer" for errors found in the submittal; these citations ALWAYS go to the "certifying" stationary source!  But in some cases, EPA citations should be the least of our concerns - our brand and reputation are at stake in a lot of these errors.  Giving the RMP just a little attention could reduce compliance issues AND improve our reputation in the communities we operate.

 
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