OH EPA offers some RMP Program Level scenarios

Ohio EPA has offered up three (3) scenarios to walk us through the thought process of establishing the “program level” for our RMP covered process(s).  These are actually quite good examples…

What Program?

Chemical distribution facility stores isopropylamine in 55‐gallon drums inside a warehouse; 80 total drums close to one another; and 10,000 pound RMP threshold is exceeded.

1. Warehouse located 50 yards inside facility line
2. Nearest public receptor is 100 yards from fence line
3. Distance endpoint for worst case scenario release from single drum equals 88 yards

Answer: Program 1 (no public receptor within endpoint distant of worst case scenario and no accidental releases of isopropylamine resulting in offsite impacts in last 5 years)

An agricultural retailer located in commercial area has a 200‐ton tank of anhydrous ammonia and an 18,000‐gallon propane tank. Retailer unloads both chemicals from bulk tanks into smaller tanks then transported to farms. The facility is within 0.15 mile of residences and downtown.

1. Facility has one covered process: the 200‐ton tank of ammonia
2. Propane not subject; flammable fuel for sale by retailer.
3. Worst case analysis potentially impacts residences and downtown.
4. Facility not subject to OSHA PSM (retail exemption)
5. Ammonia storage not one of listed NAICS codes 

Answer: Program 2.

A bulk products terminal has co‐located petroleum tanks containing 10,000,000 pounds of a regulated flammable in one area, and co‐located chemical tanks
containing 500,000 pounds of toluene diisocyanate in another area. Facility is within 0.2 miles of another industrial facility.

1. The facility has two covered processes: flammable mixture tank (Process A) and the toluene diisocyanate tanks (Process B).
2. Worst case scenario analysis finds Process A will potentially impact adjacent industrial facility, but Process B will have no offsite impact receptors
3. Process A is subject to OSHA PSM, but Process B is not. 

Answer: Facility is subject to both Program 3 (Process A) and Program 1 (Process B).

CLICK HERE for the Ohio EPA presentation