I recently came across a client who for whatever reasons had two (2) Risk Management Plans submitted for the same group of buildings, structures, equipment, installations and substance emitting stationary activities which belong to the same industrial group, which are located on one contiguous property, which are under the control of the same person (or persons under common control), and from which an accidental release may occur.
The wording above is NOT mine, but how EPA defines the term “facility”. So the client rightfully wanted to reduce their paperwork burden and when I suggested consolidating the two (2) plans into a single plan with a single renewal date they were all for it. So this is how we did it…
First, I want to give thanks to the RMP Help Desk, as several of these professionals were most helpful in getting the plans consolidated, as well as providing guidance as to how the RMP e-Submit software worked.
The first thing we had to do was to fill out APPENDIX G. RISK MANAGEMENT PROGRAM REQUEST TO CONSOLIDATE EPA FACILITY ID NUMBERS. This form can be found on page 160 of 160 in the RMP e-Submit Users Manual (2014). And although the form does not require it, EPA will ask for an explanation as to why you want to consolidate the plans. In our case, it was clear that the original submittal should have been one (1) risk management plan with two (2) processes; but you will need to have a valid reason and they will double check that your “facility” meets their definition.
After we submitted APPENDIX G, we got a response within a couple of weeks that EPA had consolidated our RMPs into a single plan. They moved the newer RMP into the older RMP and by doing so, ALL the data from the RMP that got moved was essentially erased. This meant that we now had a single RMP with a single ID number and now we had to RESUBMIT our “updated” RMP. This meant that I had to establish which of the two processes was the WORST CASE RELEASE scenario and which was our Alternative Release scenario. Just by pure luck, the original RMP’s WCS was still the WCS for the “facility” as the second process is MUCH smaller and has much smaller vessels. The ARS was easy as well since we had updated them to be the same back in the 2012 5-year Update.
But I still had to go into the new RMP and “add” the 2nd process and its chemical (luckily both processes are ammonia refrigeration processes). So for those who have never had multiple processes within a single RMP, it is really easy to add processes. You just need the same data as the existing process already in your plan. You will be answering the same exact questions as it pertains to your new process as did the old process. I would suggest that while making your “resubmission” that you take the opportunity to update ALL the data and dates so that all your processes are reviewed and updated at the same time. Keep in mind that some of your dates and data WILL DIFFER! Not every process will have done an MOC in the same month, or the SOPs may be on a different schedule from process to process. So be sure your data and dates are CORRECT.
But the beauty of doing this exercise is SIMPLICITY! Now this business has a SINGLE Risk Management Plan which means now there is only one (1) plan that needs to be updated every five years AND your now 100% correct in your submittal.