# Presentation: 128335

## RMP PLAN IN HAND TRAINING:  CHLORINEProgram Level Module

**U.S. EPA**** **
**Chemical Emergency Preparedness and Prevention Office**

## What Requirements Apply to My Operations?

- Different requirements apply to covered processes based on the potential risks to public and level of effort needed to prevent accidents
- Program Level 1
- Program Level 2
- Program Level 3

## Program Levels

- Remotely located processes with small quantities of chlorine may be subject to Program Level 1
- If not:
- If you have been complying with OSHA’s PSM Standard, the process will be subject to Program Level 3
- Otherwise, the process will be subject to Program Level 2

## Am I Eligible for Program 1?

- Conduct the worst-case release analysis to determine if a catastrophic accident could impact public receptors
- Review any chlorine accidents in the past five years to determine if there have been any impacts beyond your property

## How Do I Analyze the Worst Case?

- Worst-case scenario for a process is the release, over 10 minutes, of the entire quantity of chlorine in your largest storage vessel:
- 150-pound cylinder (15 pounds/minute)
- One-ton cylinder (200 pounds/minute)
- 17-ton tank truck (3,400 pounds/minute)
- 90-ton railcar (18,000 pounds/minute)

## Distance to Endpoint for Worst Case 

- 150-pound cylinder
- 0.8 miles rural, 0.4 miles urban
- One-ton cylinder
- 3 miles rural, 1.8 miles urban
- 17-ton tank truck
- 12 miles rural, 5.8 miles urban
- 90-ton railcar
- >25 miles rural, 14 miles urban

## How Do I Determine Impacts?

- Determine whether there is any residential population or public receptors in a circle around your plant
- Public receptors include offsite residences; institutions; industrial, commercial, and office buildings; and parks or recreational areas

## How Do I Determine Impacts?

- Use U.S. Census data to estimate population
- Draw a circle on a map of your community
- Use EPA’s LANDVIEW©

## Program Level 2 or 3?

- Chlorine processes at privately owned facilities are Program 3
- Chlorine processes at publicly owned facilities are:
- Program 2 in states without a delegated OSHA program
- Program 3 in states with delegated OSHA program

## What Are the General Requirements?

- If you have at least one covered process, you must:
- Analyze the potential impact of the worst-case release scenario
- Prepare a five-year history of accidental releases from your process(es); and
- Prepare and submit an RMP to register your facility and document your risk management program activities

## Program 1 Requirements

- If you have a Program 1 process, you must also:
- Sign and date the Program 1 certification statement
- Coordinate emergency response with local planning and response officials

## Program 2 Requirements

- If you have a Program 2 process, you must also:
- Develop and implement a prevention program to reduce the risk of an accidental release
- Analyze the potential impact of an alternative, less severe accidental release

## Program 2 Requirements (continued)

- Develop an emergency response program to prepare for such releases in the future
- Formalize responsibility for implementing your risk management activities
- Complete the Program2/Program 3 certification statement

## Program 3 Requirements

- If you have a Program 3 process, you must also:
- Develop and implement a prevention program to reduce the risk of an accidental release identical to that required under the OSHA PSM Standard
- Analyze the potential impact of an alternative, less severe accidental release

## Program 3 Requirements (continued)

- Develop an emergency response program to prepare for such releases in the future
- Formalize responsibility for implementing your risk management activities
- Complete the Program2/Program 3 certification statement

## When Does This Need to Be Done?

- If you have a covered process, you must comply with the requirements of the rule no later than June 21, 1999
- This date applies to any process with a threshold quantity of a regulated substance on June 21, 1999

## How Do I Submit My Risk Management Plan?

- EPA has developed the RMP*Submit system to allow facilities to prepare and submit their RMP in electronic format.
- This system will be distributed free of charge in January 1999
- You may apply for a waiver and submit your RMP on paper

## Where Do I Go For More Information?

- EPA’s* Risk Management Program Guidance for Wastewater Treatment Plants*
- American Water Works Association Research Foundation’s *Compliance Guidance and Model Risk Management Program for Water Treatment Plants*
- For specific questions, contact the EPA Hotline or the risk management program contact for your state