Chemical Accident Prevention is high on everyone’s priority list. The EPA even has a rule for it. The Risk Management Plan (RMP) Rule (40 CFR Part 68) governs accident prevention under Section 112(r) of the Clean Air Act Amendments. The “RMP Rule” established regulations that facilitate accident prevention at facilities that use certain highly hazardous chemicals listed in the regulation. For example, many facilities that use anhydrous ammonia are required to prepare and implement an RMP at their location, and must submit the RMP to the EPA every 5 years. Whoa, you say. What’s in an RMP?
An RMP is a set of documents and procedures that govern the following actions at a facility when that facility has the highly hazardous chemicals in a process in quantities above a Threshold Quantity. For ammonia refrigeration the threshold is 10,000 pounds.
Why would a facility want to prepare an RMP? First of all, because these plans provide your local police, fire and emergency response personnel with information needed so that they can respond to an incident at your facility in the most effective way possible. And, Secondly, because these plans must be submitted to EPA. They must also be resubmitted every five years.
Did you know that the Environmental Protection Agency implements the Risk Management Plan (RMP) Rule in Michigan – not the Michigan Department of Environmental Quality?
Did you think that once you “complete” your Risk Management Planning (RMP) and Process Safety Management (PSM) programs there is no more work to be done? Often, regulatory requirements are thought of as one and done. You prepare the document and its done, you don’t have to look at it again for five years. Not in this case.
These programs require vigilance, especially if the processes at your facility often change. For starters, both PSM and RMP include periodic actions that must be completed regularly. Here’s an abbreviated listing:
So, as you can see with this truncated list of periodic requirements, there is a lot to do after the main part of the program is established. I will say this, it gets a little easier as personnel understand what is expected of them and adopt a PSM/RMP safety culture.
One final thought. Remember to document all of your reviews and date all of your changes. The old saying still holds true. If it wasn’t documented and you can’t prove a review took place, it didn’t happen.
Once again SRM is attending and hosting a booth at the semi-annual Michigan Environmental Compliance Conference (MECC) located at the Lansing Center on June 12 and 13, 2018. There will be over 70 educational sessions, 38 exhibitors, and 18 DEQ program exhibitors. Click here for more information.
Come visit SRM at Booth 35. We hope to see you there!!
Beginning July 1, 2018, all hazardous waste shipments from
small and large quantity hazardous waste generators, and all
shipments of polychlorinated biphenyl (PCB) waste, requiring a
uniform manifest, must be submitted to the U.S. EPA for
tracking in the online e-Manifest system.
The receiving TSDF is responsible for submitting the e-Manifest information it receives to the U.S. EPA. It is also responsible for paying any e-Manifest processing fees due to the U.S. EPA following deployment. To ensure a smooth transition, generators are encouraged to review e-Manifest resources shared with them by their TSDF and to review resources on the MDEQ and USEPA websites.
Highlights for Generators
The eManifest online system is located in the USEPA CDX online system under RCRA Info and is currently available to explore. You will need to open a CDX account if you don’t already have one. There is a Youtube video from USEPA that walks you through a fictitious site and may be helpful.
To get more information, check out the MDEQ and USEPA resource pages, or contact SRM for assistance.
When it comes to industrial storm water management, historically we have always been concerned about preventing industrial materials from coming in contact with precipitation and draining into nearby storm drains, streams and lakes. We were able to accomplish this by not really knowing where all our drains went or how they were connected beneath our properties.
Now some may argue, “it just ain’t so! But, the fact is many companies out there don’t know or remember where all the underground drainage lines are, and they might not all be present on those old drawings. Were they moved? Were they abandoned or plugged? Sometimes our maintenance departments don’t have any definitive records about these underground structures.
This situation presents a real predicament with the addition of the new visual water sampling requirements in our general storm water permits. Not only do we need to collect and visually evaluate samples, we need to know where on the property the water came from for each of those samples. Basically, we need to divide our facility and property into drainage areas.
Each drainage area has a place where it discharges off-site into a storm drain, ditch, stream or lake. That discharge point becomes a sampling point. For some facilities it may be one sample location, but for others, it may be three or four sample locations.
For those of you with facilities in other Michigan Compliance Year river basins or other states, these requirements are likely familiar to you and you are already complying at those facilities. But for those for whom these requirements are new, it will take some level of effort to properly evaluate the drainage characteristics of your facility so you can feel comfortable with and can demonstrate to your local inspector that you know where the water is coming from and where it is going.
So, what do you do about it? A little detective work and taking a close look at your catch basins and culverts can help. Dust off those old drawings if you have them and consider calling Charlie the retiree who was your facility plumbing expert for 30 years. In some extreme cases, you may consider conducting a dye study.
Once you delineate your drainage areas and identify where the storm water is going, then you can select your sample locations. If your facility is relatively homogeneous with respect to industrial materials, parking lots and storage areas, you may be in luck. The permit allows you to alternate similar drainage areas for sampling. For example, if two of your drainage areas (Area A and Area B) both have the same operations, materials and vegetative characteristics, you sample from area A during one quarter and then from area B during the next quarter. To do this, drainage areas need to be very similar in their characteristics, so make sure you carefully document why they are similar in your Significant Material Inventory.
When finalizing your sampling locations, remember to include safety considerations so that the samples can be collected easily, safely and with little explanation to the person doing the sampling. Lowering someone down the side of an embankment using a rope is not a good way to collect storm water samples. Buy or fabricate sample devices that will make the sampling job easy and more importantly safe. For example, a pole with a sample jar clamp on the end will allow you to reach hard to get to places. You can also consider lowering a sample jar attached to the end of a rope into a manhole.
In some cases, you might consider installing a sample platform where a culvert discharges into a ditch or stream. And of course, traffic cones or barriers and high visibility equipment for sample locations near roads and driveways are also a must. Whatever you do, make sure you finish your hazard analysis and proof out your hazard mitigation techniques before the storm event arrives.
Need some help? Our Certified Storm Water Operator at SRM would be happy to answer your storm water questions. Give us a call!