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Prepare and Stay Aware!

R M P . H a z a r d

CONDUCTING A
HAZARD
ASSESSMENT
FOR THE
FLORIDA ACCIDENTAL RELEASE PREVENTION AND RISK MANAGEMENT PLANNING (ARP/RMP) ACT

A Hazard Assessment is a required analysis for stationary sources covered under Florida’s Accidental Release Prevention and Risk Management Planning Act (ARP/RMP) and the federal Risk Management Planning Program, Section 112(r) of the Clean Air Act Amendments of 1990 [CAA 112(r)]. The purpose of this Web Page is to familiarize an owner/operator with the requirements and to help in the completion of a Hazard Assessment.

A Hazard Assessment is an analysis of the potential and past dangers posed by a location that processes, uses, stores, or handles toxic and flammable chemicals covered under Florida’s ARP/RMP Act. There are two main analyses that comprise a Hazard Assessment. The first is an Off-Site Consequence Analysis which is the study of potential dangers involved in a accidental release of covered chemicals. The other analysis is a Five-Year Accidental Release History. This is a study of  accidental releases that have taken place in the five years prior to the submission of a Risk Management Plan.

Off-Site Consequence Analysis

As stated previously; an Off-Site Consequence Analysis is the study of potential dangers involved in an accidental release of regulated chemicals.  The purpose of this analysis is to inform the community of a possible danger so that they may be prepared in the event of a accidental release.

There are two types of analysis that make up an Off-Site Analysis, a Worst-Case and an Alternative Release Scenario Analysis. A Worst-Case Release Scenario is an analysis of how far away the worst possible accidental release from a facility would affect the surrounding public and environmental receptors. This analysis is used to determine a stationary source's Program Level under Florida ARP/RMP and is a requirement for the Risk Management Plan. An Alternative Release Scenario is an analysis of the distance within which receptors would be affected under circumstances that are more likely to occur accidentally. This analysis is required under Programs 2 and 3 of the Florida ARP/RMP.

Different Ways of Completing an Off-Site Analysis.

There are many ways of completing a Off-Site Consequence Analysis. This document will show a method using RMP.Comp, to calculate the estimated distances to a toxic or flammable endpoint.  The distance can be illustrated in a map, using a circle drawing instrument to show the area around a facility that a toxic or flammable endpoint would effect public or environmental receptors. RMP.Comp is a computer program that will calculate the distance to a flammable or toxic endpoint once you have entered the information pertaining to your chemical process. To obtain RMP.Comp you can down load it from EPA’s Web Site.

The U. S. Environmental Protection Agency (EPA) also has adocument called RMP Offsite Consequence Analysis Guidance that explains Hazard Assessments. You can acquire this document from EPA’s Web Site by clicking "HERE". It is under the heading "Offsite Consequence Analysis Risk Management Program Guidance".

Worst-Case Release Scenario Analysis

There are two reasons for performing a Worst-Case Release Analysis. The first reason is to determine the appropriate Program Level for each covered chemical process. The Worst-Case Release Scenario also enables the owner/operator to better understand and prepare for off-site impacts.

To complete a Worst-Case Release Scenario follow these steps:

1. Determine the regulated chemical processes which are located at your stationary source.
To do this, compare your processes with the Environmental Protection Agency’s "List of Regulated Substances and Threshold Quantities for Accidental Release Prevention" . If you have one or more of these toxic or flammable chemicals that exceeds the threshold quantities in a process then use the following steps to complete a Worst-Case Release Scenario Analysis. You may not need to submit the distance for each analysis but it is necessary to calculate the distances for each process in order to determine the process' program level.

2. Choose one of your chemical process to be analyzed.

3. Open RMP.Comp

4. Read information on screen and choose "next".

5. Click on the chemical in the covered process from the list then click on "next".

6. RMP.Comp will offer the choices of Worst-Case or Alternative Scenarios. Make sure Worst-Case Scenario is marked and then choose "next".

7. Answer the questions presented by RMP.Comp. There are different questions for different processes and chemical types.

8. Once you have obtained the "Estimated Distance", print out the results by clicking on the printer in the top right corner of RMP.Comp. The print out will show all the information entered into and calculated by this analysis.

9. If you have not analyzed each covered process choose another process and start at #2. If you have analyzed every covered process continue on to #10.

10. Now you must find out if there are any public or environmental receptors within a circle with the greatest distance as it’s radius and it’s center at the release point from the covered process.
This document will demonstrate how to find public and environmental receptors by using census data and U. S. Geological Survey Maps.  A regulated source may use other methods to determine the receptors within the endpoint.  Other methods include the CAMEO and LANDVIEW computer programs.

Steps to determine public receptors within the greatest distance to an endpoint:

  1. Obtain a street map that displays the area your facility is in. Make sure that there is enough room to draw a circle (with the "estimated endpoint" as the radius) around where your facility is located.
  2. Choose a chemical process that you have calculated the estimated distance to an endpoint.
  3. Locate and mark where the process is housed on the street map.Drawing of a circle hazard1.tif (562042 bytes)
  4. Draw a circle with the process as the center and make the radius the distance (to scale) of the greatest distance to an endpoint of the process you chose in (b).  This can be done by using a engineering compass. You may also use a piece of string cut to the proper distance (to scale) and tacked on one end to where the process is located and tied to a marker on the other end.
    Drawing of a circle hazard2.jpg (74326 bytes)Drawing of a circle hazard3.jpg (76113 bytes)
  5. Determine if the following public receptors are located within the circle:
Public Receptors Check if Yes
Schools   
Residences         
Hospitals        
Prisons       
Public recreational area or areas       
Major commercial, office or industrial areas          

 

Steps to determine environmental receptors within the greatest distance to an endpoint:

  1. Obtain a U. S. Geological Survey Map (link for information on obtaining a U. S. Geological Survey Map) that displays the area your facility is located. Make sure that there is enough room to draw a circle (with the "estimated endpoint" as the radius) around where your facility is located. Use the same method as described above to locate public receptors
  2. Choose a chemical process that you have calculated the estimated distance to an endpoint.
  3. Locate and mark where the process is housed on the U. S. Geological Survey map.
  4. Draw a circle with the process as the center and make the radius the distance (to scale) of the greatest distance to an endpoint of the process you chose in (b).  This can be done by using a engineering compass. You may also use a piece of string cut to the proper distance (to scale) and tacked on one end to where the process is located and tied to a marker on the other end.
  5. Determine if the following public receptors are located within the circle:
Environmental Receptors Check if Yes
National or state parks, forests, or monuments         
Officially designated wildlife sanctuaries, preservations of refuges         
Federal wilderness areas        

 

11. Once you have completed these steps you will be able to use this information in deciding the program level for each of your processes.  You may use RMP.Level to determine the program level for each process.

Alternative Release Scenario Analysis (For Programs 2 and 3 only)

An owner/operator should complete a Alternative Release Scenario Analysis for processes covered under Programs 2 or 3. For each Program 2 or 3 process at least one Alternative Release Scenario must be submitted for each covered toxic process and at least one Alternative Release Scenario representing all covered flammable processes.

An Alternative Release Scenario Analysis is preformed similarly to a Worst-Case Release Scenario. The major difference is in the responses and calculations in RMP.Comp. In the Alternative Release Scenario a facility may take active mitigation measures in to consideration when completing the necessary calculations. You can follow the same process that is use in this document for doing a Worst-Case Scenario but remember to select "Alternative Scenario" instead of "Worst-Case Scenario" as explained by step (6.)

Five-Year Accidental Release History

A Five-Year Accidental Release History is a review of accidental releases that have taken place at a covered stationary source in the five years previous to the submission of a Risk Management Plan. An owner/operator must report all releases that caused deaths, injuries, evacuations, shelters to be opened, property damage, or environmental damage.

Data required. For each accidental release included, the owner

or operator shall report the following information:

(1) Date, time, and approximate duration of the release;

(2) Chemical(s) released;

(3) Estimated quantity released in pounds;

(4) The type of release event and its source;

(5) Weather conditions, if known;

(6) On-site impacts;

(7) Known offsite impacts;

(8) Initiating event and contributing factors if known;

(9) Whether offsite responders were notified if known; and

(10) Operational or process changes that resulted from investigation of the release.

The level of accuracy of numerical estimates may be provided to two significant digits.

 

Updated:
April 23, 2014 14:25