Document BR25aDxdoko03NZwKvRgJr1Gj
Region 6 - Enforcement & Compliance Assurance Division
Virtual Partial Compliance Evaluation Findings
Evaluation Date(s): Media Program: Regulatory Program(s)
September 15, 2020 - November 3, 2020 Air Clean Air Act Section 112(r) and 40 C.F.R. Part 68 Chemical Accident Prevention Provisions - Risk Management Program (RMP)
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Phone Number Facility Contact:
Sendero Carlsbad Midstream, LLC
Sendero Carlsbad Plant
1025 Bounds Road
Loving, New Mexico, 88256
1000 Louisiana Street, Suite 6900
Houston, Texas, 77002
Eddy County
(575) 361-3526
Clint Cone
Operations Manager, RMP Contact
ccone@senderomidstream.com
FRS Number: Media Identifier Number: NAICS: SIC:
110070507627 1000 0023 7246 (EPA Facility Identifier) 21113 Natural Gas Extraction 1311 Crude Petroleum and Natural Gas
Personnel participating in evaluation:
Clint Cone
Sendero Carlsbad Plant
Travis Combs
Sendero Carlsbad Plant
Brad Boister
Sendero Carlsbad Plant
Wes Whatley
Sendero Carlsbad Plant
Ted Lilly
Sendero Carlsbad Plant
Howard Cole
US EPA
Justin McDowell
US EPA
Operations Manager Plant Foreman President & CEO Employee Employee Inspector Inspector
EPA Lead Inspector Signature/Date
JUSTIN MCDOWELL
Digitally signed by JUSTIN MCDOWELL DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=JUSTIN MCDOWELL, 0.9.2342.19200300.100.1.1=68001003655843 Date: 2020.12.16 16:17:02 -06'00'
12/16/2020
Justin McDowell
Date
Supervisor Signature/Date
SAMUEL
TATES
Digitally signed by SAMUEL TATES DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=SAMUEL TATES, 0.9.2342.19200300.100.1.1=68001003655433 Date: 2020.12.16 17:41:59 -06'00'
Samuel Tates
12/16/2020 Date
6ENFORM-020-R8.2 (02/12/2020)
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Sendero Carlsbad Midstream, LLC / Sendero Carlsbad Plant Evaluation Date: 09/15/2020 - 11/03/2020
Section I - INTRODUCTION
PURPOSE OF THE EVALUATION
On September 16, 2020, the United States Environmental Protection Agency (EPA) Region 6 sent an email to facility personnel at the Sendero Carlsbad Midstream, LLC (Sendero Carlsbad Plant), located in Loving, New Mexico, to announce the initiation of a Clean Air Act Risk (CAA) Management Plan (RMP) Virtual Partial Compliance Evaluation (VPCE). The email informed Sendero personnel of the start of the VPCE which included a Microsoft Teams video opening conference scheduled on September 17, 2020. During the opening conference, Region 6 inspectors Howard Cole and Justin McDowell met with Clint Cone, Travis Combs, Brad Boister, Wes Whatley and Ted Lilly. I presented my credentials and informed Sendero personnel that this was an EPA evaluation to determine compliance with the federal Chemical Accident Prevention Program. The scope of the VPCE was to evaluate the facility's compliance with the CAA Section 112(r) and the Chemical Accident Prevention Provisions in 40 C.F.R. Part 68 as well as the General Duty Clause. EPA inspectors discussed general VPCE procedural questions, confidential business information (CBI) procedures, interview schedules, the proposed timeline and the exit conference and final report. This VPCE is a new compliance monitoring tool that EPA Region 6 is utilizing during the COVID-19 Public Health Emergency. This evaluation included reviewing and obtaining copies of documents and records and conducting interviews and taking of statements via video conference.
FACILITY DESCRIPTION
According to the facility, "Sendero Carlsbad Midstream, LLC (Sendero) owns and operates a bulk petroleum plant, the Sendero Carlsbad Plant in Eddy, New Mexico that receives, stores, and transfers petroleum. The facility is designed to process natural gas liquids by fractionation into end products that will be delivered to end markets. As such, the Sendero facility is classified as a Program 3 RMP facility. The facility handles flammable mixtures consisting of regulated chemicals in excess of the threshold amounts. Sendero employs four full-time employees.
Section II - OBSERVATIONS
EPA Region 6 documented its observations on the Program Level 3 Checklist (Appendix #1).
Section III - AREAS OF CONCERN (AOC)
Closing Meeting - EPA convened a closing meeting on November 3, 2020, to discuss the Areas of Concern (AOC) noted during the VCPE, the evaluation report completion process, and answer questions from Sendero personnel.
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Sendero Carlsbad Midstream, LLC / Sendero Carlsbad Plant Evaluation Date: 09/15/2020 - 11/03/2020
AOC 1 - 40 C.F.R 68.65 (d)(1)(ii) Process Safety Information
"(d) Information pertaining to the equipment in the process. (1) Information pertaining to the equipment in the process shall include: (ii) Piping and instrument diagrams (P&ID's);"
This process safety information included piping and instrument diagrams (P&ID's); the following were inaccurate P&IDs: car seal open designation was not indicated on valves prior to PSV-120A, PSV-329, PSV-401A, PSV-402, PSV-404A/B, PSV-405A/B, PSV-408A, PSV-412, and PSV-430A/B.
------------------------------------------------------------------------------------------------------------------------------------------ AOC 2 - 40 C.F.R 68.65 (d)(2) Process Safety Information
"(d) Information pertaining to the equipment in the process. (2) The owner or operator shall document that equipment complies with recognized and generally accepted good engineering practices."
Sendero failed to properly classify process piping containing methane, ethane, propane, butane, natural gas liquids, natural gas condensate, and natural gas in accordance with API 570 Sections 6.3.4. Piping Services Classes and Table 1.
Sendero designated the following piping circuits as Class 2: a. LH01 b. LH02 c. GH04 d. GH05 e. FL01 f. DR01 g. DR02
The Versa Integrity Group Process API 570 Piping External Inspection Report classifies the above piping circuits as Class 2 which should have been designated as Class 1.
Recognized and Generally Accepted Good Engineering Principles
API 570 Section 6.3.4.1 General
All process piping systems shall be categorized into different piping classes except for piping that has been planned on the basis of RBI. Such a classification system allows extra inspection efforts to be focused on piping systems that may have the highest potential consequences if failure or loss of containment should occur. In general, the higher classified systems require more extensive inspection at shorter intervals in order to affirm their integrity for continued safe operation. Classifications should be based on potential safety and environmental effects should a leak occur. Owner/users shall maintain a record of process piping fluids handled, including their classifications. NFPA 704 provides information that may be helpful in classifying piping systems according to the potential hazards of the process fluids they contain.
6.3.3 Setting Inspection Intervals Without the Use of RBI The owner/user or the inspector shall establish inspection intervals for thickness measurements and external visual inspections and, where applicable, for internal and supplemental inspections.
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Sendero Carlsbad Midstream, LLC / Sendero Carlsbad Plant Evaluation Date: 09/15/2020 - 11/03/2020
For Class 1, 2, and 3 piping, the period between thickness measurements for CMLs or circuits should not exceed one-half the remaining life, or the maximum intervals recommended in Table 1, whichever is less. Whenever the remaining life is less than four years, the inspection interval may be the full remaining life up to a maximum of two years. The interval is established by the inspector or piping engineer in accordance with the owner/user's QA system.
Table 1--Recommended Maximum Inspection Intervals
Type of Circuit Thickness Measurements
Visual External
Class 1
5 years
5 years
Class 2
10 years
5 years
Class 3
10 years
10 years
Class 4
Optional
Optional
1.7.10 Piping Service Class - A classification system of piping that allows specific inspection efforts to be focused on areas having the highest potential consequences if failure or other loss of containment should occur.
1.5.2 Piping service classification, along with applicable special considerations, as defined in section 6.3.4 of API 570, Fourth Edition, February 2016
------------------------------------------------------------------------------------------------------------------------------------------ AOC 3 - 40 C.F.R 68.67 (a)(1) Process Hazard Analysis
"(a) The owner or operator shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this part. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. The owner or operator shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process.
The owner's Plant 1 hazard analysis was not appropriate for the complexity of the process as it did not identify, evaluate, and control the hazards involved in the process as it did not address failure of utilities (e.g., electric, gas, water, steam, instrument air) and did not address the causes for deviations in the process.
------------------------------------------------------------------------------------------------------------------------------------------ AOC 4 - 40 C.F.R 68.67 (c)(5) Process Hazard Analysis
"(c) The process hazard analysis shall address: (5) Stationary source siting;"
Sendero's Plant 1 stationary siting process hazard analysis was not appropriate for the complexity of the process as it did not identify, evaluate, and control the hazards involved in the process.
The owner's Plant 1 process hazard analysis for stationary sources/facility siting did not use What-If; Checklist; What-If/Checklist; Hazard and Operability Study (HAZOP); Failure Mode and Effects Analysis (FMEA); Fault Tree Analysis; or an appropriate equivalent methodology.
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Sendero Carlsbad Midstream, LLC / Sendero Carlsbad Plant Evaluation Date: 09/15/2020 - 11/03/2020
The owner's Plant 2 process hazard analysis did not address the stationary source/facility siting hazards involved in the process.
------------------------------------------------------------------------------------------------------------------------------------------ AOC 5 - 40 C.F.R 68.67 (c)(6) Process Hazard Analysis
"(c) The process hazard analysis shall address: (6) Human factors"
The owner's Plant 1 human factors process hazard analysis was not appropriate for the complexity of the process as it did not identify, evaluate, and control the hazards involved in the process.
The owner's Plant 2 process hazard analysis did not address the human factors hazards involved in the process.
------------------------------------------------------------------------------------------------------------------------------------------ AOC 6 - 40 C.F.R 68.73 (b) Mechanical Integrity
"(b) Written procedures. The owner or operator shall establish and implement written procedures to maintain the on-going integrity of process equipment."
1. Sendero did not implement written procedures to maintain the on-going integrity of process equipment. The following monthly car seals checks were not performed: Plant 1-December 2019, April 2020, May 2020, June 2020, July 2020, August 2020 September 2020. Plant 2-June 2020, August 2020.
2. The owner did not implement written procedures to maintain the on-going integrity of process equipment. The owner's mechanical integrity preventative maintenance program requires inspection of pressure safety valves annually. The following PSV were not inspected annually: PSV-337, PSV-400, PSV- 406, PSV-410, PSV-428, PSV-110, PSV-1022.
------------------------------------------------------------------------------------------------------------------------------------------ AOC 7 - 40 C.F.R 68.73 (d)(3) Mechanical Integrity
"(d) Inspection and testing. (3) The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience."
The frequency of inspections and tests of process equipment was not consistent with applicable manufacturers' recommendations and good engineering practices.
1. Sendero preventative maintenance required that GasAlertMicroClip-Honeywell Analytics/BW 4-gas personnel monitors need to be calibrated and evaluated for proper function.
The following 4-gas personnel monitors have not been calibrated every six months or bump tested daily: KA418-1134207, KA418-1134208, KA418-1134209, KA418-1134211, KA418-1134212, KA419-1010839 KA419-1010841, KA419-1010851, KA419-1022909, KA419-1022910, KA419-1064098, KA419-1064127, KA419-1064168, KA419-1122961, KA419-1122969.
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Sendero Carlsbad Midstream, LLC / Sendero Carlsbad Plant Evaluation Date: 09/15/2020 - 11/03/2020
2. The owner's preventative maintenance requires that every fire detector and gas detector need to be calibrated and evaluated for proper function. The facility has not provided preventative maintenance in accordance with the manufacturer's recommendations for any of the following detectors in the facility in 2020: Detcon FP700 Gas Detection Plant 1; Searchpoint Optima Plus Gas Detection Plant 2; FS20X Flame Detection Plant 1.
------------------------------------------------------------------------------------------------------------------------------------------ AOC 8 - 40 C.F.R 68.75 (a) Management of Change
"(a) The owner or operator shall establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to stationary sources that affect a covered process."
1. Sendero did not implement written procedures to manage changes to process technology and equipment that affect a covered process when it failed to develop or implement a temporary management of change for the removal of the Residual Suction Scrubbers PSV.
2. The owner did not implement written procedures to manage changes to process technology and equipment that affect a covered process when it failed to develop or implement a written management of change for the removal of the Plant 1 flare header.
3. The owner did not implement written procedures to manage changes to process technology and equipment that affect a covered process when it failed to develop and implement a written manage of change prior to decreasing the set pressure of PSV-305 from 475 pound-force per square inch (psig) to 450 psig to protect T-305.
------------------------------------------------------------------------------------------------------------------------------------------ AOC 9 - 40 C.F.R 68.75 (b) Management of Change (MOC)
"(b) The procedures shall assure that the following considerations are addressed prior to any change: (1) The technical basis for the proposed change; (2) Impact of change on safety and health; (3) Modifications to operating procedures; (4) Necessary time period for the change; and, (5) Authorization requirements for the proposed change."
1. MOC-2019-P006 (Project Description- Add PSV to Residue Suction Line for overpressure protection): The owner did not implement written procedures to manage changes in process equipment that affect a covered process. The MOC did not address the following:
a. Technical basis for the change-the MOC does not address the complexity of the process- There is no indication of the PSV the set pressure, type of PSV, what vessels are protected, how the PSV impacts the pressure and backpressure of the flare system, the chemical that would be released, the temperature of the chemical released.
b. The impact of the change on personnel health and safety- There is no indication of the fire or explosion hazard, or does the PSV relieve to a safe location.
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Sendero Carlsbad Midstream, LLC / Sendero Carlsbad Plant Evaluation Date: 09/15/2020 - 11/03/2020
c. The time period for the change- There is nothing indicating the time period for the change or if the change was ever completed.
d. PSI is revised as needed- There is no indication of when the redlined (revision date) PSV was added, who redlined the P&ID, and no technical information regarding the new PSV (mfg., type, model number, serial number, set pressure), and no indication of the valves that need to be car sealed open.
e. Mechanical integrity inspection, testing and maintenance procedures are modified- there is no indication that the PSV was added to the annual PSV testing plan.
2. MOC-2018-P001 (Project Description-change routing of PSV discharge from atmosphere to safer location):
The owner did not implement written procedures to manage changes in process equipment that affect a covered process. The MOC did not address the following:
a. Technical basis for the change- There is no indication of the location of the PSV, the equipment it services, the set pressure, the chemical that would be released, the temperature of the chemical released. There is no indication of what the change entails, new pipe materials, size length of pipe, effect on operation of PSV and how it will mitigate the hazard. b. The impact of the change on personnel health and safety- There is indication of the fire or explosion hazard. There is no indication of the possible health effects of exposure and how the change would mitigate the hazard. c. The time period for the change- There is nothing indicating the time period for the change or if the change was ever completed. d. PSI is revised as needed- No P&ID was attached to the MOC. e. Affected employees and contractors are trained prior to the change- There is no indication that employees or contractors have been trained. f. MI inspection, testing and maintenance procedures are modified- There is no indication as to whether additional inspection or UT testing will be necessary. g. Authorization & certification for the proposed change- There is no indication as to whether the change was approved and when it was approved. h. The Facility Supervisor or his designee will decide who is responsible for completing each
applicable task on the MOC Form- There is no indication of who is responsible for completing each task. i. The Facility Supervisor will sign the MOC Form after all tasks are complete and before actual
work begins- The MOC form has not been signed by the Facility Supervisor indicating that all tasks are complete. j. There is no indication that the work has been complete.
3. MOC 2018-T002: 7
Sendero Carlsbad Midstream, LLC / Sendero Carlsbad Plant Evaluation Date: 09/15/2020 - 11/03/2020
Project Description: Blind V-324 NGL surge tank and make programming changes, use Cryo-Booster pumps to cool Stabilizer NGL until permanent fixes are implemented.
The owner did not implement written procedures to manage changes in process equipment that affect a covered process. The MOC did not address the following:
a. The time period for the change- There is nothing indicating the time period for the change, if the change is temporary or permanent, or if the change was ever completed.
b. Affected employees and contractors are trained prior to the change- There is no indication that employees or contractors have been trained.
c. MI inspection, testing and maintenance procedures are modified- There is no indication as to whether additional inspection or UT testing will be necessary.
d. Authorization & certification for the proposed change- There is no indication as to whether the change was approved and when it was approved.
e. The Facility Supervisor will sign the MOC Form after all tasks are complete and before actual work begins- The MOC form has not been signed by the Facility Supervisor indicating that all tasks are complete.
f. There is no indication that the work has been complete.
4. MOC 2018-P004 (Project Description- ESD valves on the suction of the NGL booster pumps and the suction of the stablizer pipeline pumps):
The owner did not implement written procedures to manage changes in process equipment that affect a covered process. The MOC did not address the following:
a. Technical basis for the change-The MOC does not address the complexity of the process There is no indication of the set pressure for the pumps and valves, functioning of the valves, or changes in operating procedures, or board operation.
b. The time period for the change- There is nothing indicating the time period for the change or if the change was ever completed.
c. Affected employees and contractors are trained prior to the change- There is no indication that employees or contractors have been trained.
d. MI inspection, testing and maintenance procedures are modified- There is no indication as to inspection and testing of the ESD.
e. Authorization & certification for the proposed change- There is no indication as to whether the change was approved and when it was approved.
f. The Facility Supervisor or his designee will decide who is responsible for completing each applicable task on the MOC Form- There is no indication of who is responsible for completing each task.
g. The Facility Supervisor will sign the MOC Form after all tasks are complete and before actual work begins- The MOC form has not been signed by the Facility Supervisor indicating that all tasks are complete. 8
Sendero Carlsbad Midstream, LLC / Sendero Carlsbad Plant Evaluation Date: 09/15/2020 - 11/03/2020
------------------------------------------------------------------------------------------------------------------------------------------ AOC 10 - 40 C.F.R 68.85 (b) Hot work permit
"(b) The permit shall document that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot work operations; it shall indicate the date(s) authorized for hot work; and identify the object on which hot work is to be performed. The permit shall be kept on file until completion of hot work operations.
1910.252(a)(2)(iii)(B) Fire watchers shall have fire extinguishing equipment readily available and be trained in its use. They shall be familiar with facilities for sounding an alarm in the event of a fire. They shall watch for fires in all exposed areas, try to extinguish them only when obviously within the capacity of the equipment available, or otherwise sound the alarm. A fire watch shall be maintained for at least a half hour after completion of welding or cutting operations to detect and extinguish possible smoldering fires.
While reviewing hot work permit "MCSI 1.12.19", it indicated that the hot work ended at 5pm as well as the C4 atmospheric monitoring ended at 5pm.
----------------------------------------------------------------------------------------------------------------------------------------- AOC 11 - 40 C.F.R 68.90 (b)(2) Applicability (Emergency Response)
(b) Non-responding stationary source. The owner or operator of a stationary source whose employees will not respond to accidental releases of regulated substances need not comply with 68.95 of this part provided that: (2) For stationary sources with only regulated flammable substances held in a process above the threshold quantity, the owner or operator has coordinated response actions with the local fire department;
The facility had yet to fully coordinate response actions with the local emergency planning committee and fire department. ------------------------------------------------------------------------------------------------------------------------------------------ AOC 12 - 40 C.F.R 68.95 Emergency response program
(a) The owner or operator shall develop and implement an emergency response program for the purpose of protecting public health and the environment. Such program shall include the following elements:
(1) An emergency response plan, which shall be maintained at the stationary source and contain at least the following elements: (i) Procedures for informing the public and the appropriate Federal, state, and local emergency response agencies about accidental releases; (ii) Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures; and (iii) Procedures and measures for emergency response after an accidental release of a regulated substance;
The Emergency Action Plan did not document proper first aid and emergency medical treatment necessary to treat accidental human exposures.
------------------------------------------------------------------------------------------------------------------------------------------
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Sendero Carlsbad Midstream, LLC / Sendero Carlsbad Plant Evaluation Date: 09/15/2020 - 11/03/2020
Section IV - FOLLOW UP Additional information was received by EPA after the closing meeting on November 3, 2020 and two follow-up meetings were held on November 12, 2020 and November 16, 2020. Section V - LIST OF APPENDICES
Appendix #1 - RMP Program Level 3 Process Checklist
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RMP Program Level 3 Process Checklist
Facility Name: Sendero Carlsbad Plant
Section A - Management [68.15]
Management system developed and implemented as provided in 40 CFR 68.15? Comments:
S
M
U
N/A
Has the owner or operator:
1. Developed a management system to oversee the implementation of the risk management program elements? [68.15(a)]
Y
N N/A
2. Assigned a qualified person or position that has the overall responsibility for the development, implementation, and integration of the risk management program elements? [68.15(b)]
Y
N N/A
3. Documented other persons responsible for implementing individual requirements of the risk management program and
Y
N N/A
defined the lines of authority through an organization chart or similar document? [68.15(c)]
Section B: Hazard Assessment [68.20-68.42]
Hazard assessment conducted and documented as provided in 40 CFR 68.20-68.42? Comments:
S
M
U
N/A
Hazard Assessment: Offsite consequence analysis parameters [68.22]
1. Used the following endpoints for offsite consequence analysis for a worst-case scenario: [68.22(a)] For toxics: the endpoints provided in Appendix A of 40 CFR Part 68? [68.22(a)(1)] For flammables: an explosion resulting in an overpressure of 1 psi? [68.22(a)(2)(i)]; or For flammables: a fire resulting in a radiant heat/exposure of 5 kw/m2 for 40 seconds? [68.22(a)(2)(ii)] For flammables: a concentration resulting in a lower flammability limit, as provided in NFPA documents or other generally recognized sources? [68.22(a)(2)(iii)]
Y
N N/A
2. Used the following endpoints for offsite consequence analysis for an alternative release scenario: [68.22(a)] For toxics: the endpoints provided in Appendix A of 40 CFR Part 68? [68.22(a)(1)] For flammables: an explosion resulting in an overpressure of 1 psi? [68.22(a)(2)(i)] For flammables: a fire resulting in a radiant heat/exposure of 5 kw/m2 for 40 seconds? [68.22(a)(2)(ii)] For flammables: a concentration resulting in a lower flammability limit, as provided in NFPA documents or other generally recognized sources? [68.22(a)(2)(iii)]
Y
N N/A
3. Used appropriate wind speeds and stability classes for the release analysis? [68.22(b)]
Y
N N/A
4. Used appropriate ambient temperature and humidity values for the release analysis? [68.22(c)]
Y
N N/A
5. Used appropriate values for the height of the release for the release analysis? [68.22(d)]
Y
N N/A
6. Used appropriate surface roughness values for the release analysis? [68.22(e)]
Y
N N/A
7. Do tables and models, used for dispersion analysis of toxic substances, appropriately account for dense or neutrally buoyant gases? [68.22(f)]
Y
N N/A
8. Were liquids, other than gases liquefied by refrigeration only, considered to be released at the highest daily maximum temperature, based on data for the previous three years appropriate for a stationary source, or at process temperature, whichever is higher? [68.22(g)]
Y
N N/A
Hazard Assessment: Worst-case release scenario analysis [68.25]
9. Analyzed and reported in the RMP one worst-case release scenario estimated to create the greatest distance to an endpoint resulting from an accidental release of a regulated toxic substance from covered processes under worst-case conditions? [68.25(a)(2)(i)]
Y
N N/A
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10. Analyzed and reported in the RMP one worst-case release scenario estimated to create the greatest distance to an
Y
N N/A
endpoint resulting from an accidental release of a regulated flammable substance from covered processes under worst-
case conditions? [68.25(a)(2)(ii)]
11. Analyzed and reported in the RMP additional worst-case release scenarios for a hazard class if the worst-case release from another covered process at the stationary source potentially affects public receptors different from those potentially affected by the worst-case release scenario developed under 68.25(a)(2)(i) or 68.25(a)(2)(ii)? [68.25(a)(2)(iii)]
Y
N N/A
12. Has the owner or operator determined the worst-case release quantity to be the greater of the following: [68.25(b)]
If released from a vessel, the greatest amount held in a single vessel, taking into account administrative controls that limit the maximum quantity? [68.25(b)(1)]
If released from a pipe, the greatest amount held in the pipe, taking into account administrative controls that limit the maximum quantity? [68.25(b)(2)]
Y
N N/A
13.a. Has the owner or operator for toxic substances that are normally gases at ambient temperature and handled as a gas or liquid under pressure:
13.a.(1) Assumed the whole quantity in the vessel or pipe would be released as a gas over 10 minutes? [68.25(c)(1)]
Y
N N/A
13.a.(2) Assumed the release rate to be the total quantity divided by 10, if there are no passive mitigation systems in place? [68.25(c)(1)]
Y
N N/A
13.b. Has the owner or operator for toxic gases handled as refrigerated liquids at ambient pressure:
13.b.(1) Assumed the substance would be released as a gas in 10 minutes, if not contained by passive mitigation systems or if the contained pool would have a depth of 1 cm or less? [68.25(c)(2)(i)]
Y
N N/A
13.b.(2) If released substance would be contained by passive mitigation systems in a pool with a depth > 1 cm;
Assumed the quantity in the vessel or pipe (as determined per 68.25(b)) would be spilled instantaneously to form a liquid pool? [68.25(c)(2)(ii)]
Calculated the volatility rate at the boiling point of the substance and at the conditions specified in 68.25(d)? [68.25(c)(2)(ii)]
Y
N N/A
13.c. Has the owner or operator for toxic substances that are normally liquids at ambient temperature:
13.c.(1) Assumed the quantity in the vessel or pipe would be spilled instantaneously to form a liquid pool? [68.25(d)(1)]
Y
N N/A
13.c.(2) Determined the surface area of the pool by assuming that the liquid spreads to 1 cm deep, if there is no passive mitigation system in place that would serve to contain the spill and limit the surface area, or if passive mitigation is in place, was the surface area of the contained liquid used to calculate the volatilization rate? [68.25(d)(1)(i)]
Y
N N/A
13.c.(3) Taken into account the actual surface characteristics, if the release would occur onto a surface that is not paved or
Y
N N/A
smooth? [68.25(d)(1)(ii)]
13.c.(4) Determined the volatilization rate by accounting for the highest daily maximum temperature in the past three years, the temperature of the substance in the vessel, and the concentration of the substance if the liquid spilled is a mixture or solution? [68.25(d)(2)]
Y
N N/A
13.c.(5) Determined the rate of release to air from the volatilization rate of the liquid pool? [68.25(d)(3)]
Y
N N/A
13.c.(6) Determined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis
Y
N N/A
Guidance, any other publicly available techniques that account for the modeling conditions and are recognized by
industry as applicable as part of current practices, or proprietary models that account for the modeling conditions
may be used provided the owner or operator allows the implementing agency access to the model and describes
model features and differences from publicly available models to local emergency planners upon request?
[68.25(d)(3)]
What modeling technique did the owner or operator use? [68.25(g)] Choose an item.
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13.d. Has the owner or operator for flammables:
13.d.(1) Assumed the quantity in a vessel(s) of flammable gas held as a gas or liquid under pressure or refrigerated gas released to an undiked area vaporizes resulting in a vapor cloud explosion? [68.25(e)]
13.d.(2) For refrigerated gas released to a contained area or liquids released below their atmospheric boiling point, assumed the quantity volatilized in 10 minutes results in a vapor cloud? [68.25(f)]
13.d.(3) Assumed a yield factor of 10% of the available energy is released in the explosion for determining the distance to the explosion endpoint, if the model used is based on TNT-equivalent methods? [68.25(e)]
14. Used the parameters defined in 68.22 to determine distance to the endpoints? [68.25(g)]
15. Determined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis Guidance, any other publicly available techniques that account for the modeling conditions and are recognized by industry as applicable as part of current practices, or proprietary models that account for the modeling conditions may be used provided the owner or operator allows the implementing agency access to the model and describes model features and differences from publicly available models to local emergency planners upon request? [68.25(g)] What modeling technique did the owner or operator use? [68.25(g)] Choose an item.
16. Ensured that the passive mitigation system, if considered, is capable of withstanding the release event triggering the scenario and will still function as intended? [68.25(h)]
17. Considered also the following factors in selecting the worst-case release scenarios: [68.25(i)] Smaller quantities handled at higher process temperature or pressure? [68.25(i)(1)] Proximity to the boundary of the stationary source? [68.25(i)(2)]
Hazard Assessment: Alternative release scenario analysis [68.28]
18. Identified and analyzed at least one alternative release scenario for each regulated toxic substance held in a covered process(es) and at least one alternative release scenario to represent all flammable substances held in covered processes? [68.28(a)]
19. Selected a scenario: [68.28(b)] That is more likely to occur than the worst-case release scenario under 68.25? [68.28(b)(1)(i)] That will reach an endpoint off-site, unless no such scenario exists? [68.28(b)(1)(ii)]
20. Considered release scenarios which included, but are not limited to, the following: [68.28(b)(2)] Transfer hose releases due to splits or sudden hose uncoupling? [68.28(b)(2)(i)] Process piping releases from failures at flanges, joints, welds, valves and valve seals, and drains or bleeds? [68.28(b)(2)(ii)] Process vessel or pump releases due to cracks, seal failure, or drain, bleed, or plug failure? [68.28(b)(2)(iii)] Vessel overfilling and spill, or overpressurization and venting through relief valves or rupture disks? [68.28(b)(2)(iv)] Shipping container mishandling and breakage or puncturing leading to a spill? [68.28(b)(2)(v)]
21. Used the parameters defined in 68.22 to determine distance to the endpoints? [68.28(c)]
22. Determined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis Guidance, any other publicly available techniques that account for the modeling conditions and are recognized by industry as applicable as part of current practices, or proprietary models that account for the modeling conditions may be used provided the owner or operator allows the implementing agency access to the model and describes model features and differences from publicly available models to local emergency planners upon request? [68.28(c)] What modeling technique did the owner or operator use? [68.25(g)] Choose an item.
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
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23. Ensured that the passive and active mitigation systems, if considered, are capable of withstanding the release event triggering the scenario and will be functional? [68.28(d)]
24. Considered the following factors in selecting the alternative release scenarios: [68.28(e)] The five-year accident history provided in 68.42? [68.28(e)(1)] Failure scenarios identified under 68.50? [68.28(e)(2)]
Hazard Assessment: Defining off-site impacts-Population [68.30]
25. Estimated population that would be included in the distance to the endpoint in the RMP based on a circle with the point of release at the center? [68.30(a)]
26. Identified the presence of institutions, parks and recreational areas, major commercial, office, and industrial buildings in the RMP? [68.30(b)]
27. Used most recent Census data, or other updated information to estimate the population? [68.30(c)]
28. Estimated the population to two significant digits? [68.30(d)]
Hazard Assessment: Defining off-site impacts-Environment [68.33]
29. Identified environmental receptors that would be included in the distance to the endpoint based on a circle with the point of release at the center? [68.33(a)]
30. Relied on information provided on local U.S.G.S. maps, or on any data source containing U.S.G.S. data to identify environmental receptors? [Source may have used LandView to obtain information] [68.33(b)]
Hazard Assessment: Review and update [68.36]
31. Reviewed and updated the off-site consequence analyses at least once every five years? [68.36(a)]
32. Completed a revised analysis and submit a revised RMP within six months of a change in processes, quantities stored or handled, or any other aspect that might reasonably be expected to increase or decrease the distance to the endpoint by a factor of two or more? [68.36(b)]
Hazard Assessment: Documentation [68.39]
33. For worst-case scenarios: a description of the vessel or pipeline and substance selected, assumptions and parameters used, the rationale for selection, and anticipated effect of the administrative controls and passive mitigation on the release quantity and rate? [68.39(a)]
34. For alternative release scenarios: a description of the scenarios identified, assumptions and parameters used, the rationale for the selection of specific scenarios, and anticipated effect of the administrative controls and mitigation on the release quantity and rate? [68.39(b)]
35. Documentation of estimated quantity released, release rate, and duration of release? [68.39(c)]
36. Methodology used to determine distance to endpoints? [68.39(d)]
37. Data used to estimate population and environmental receptors potentially affected? [68.39(e)]
Hazard Assessment: Five-year accident history [68.42]
38. Has the owner or operator included all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage? [68.42(a)]
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
Y
N N/A
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39. Has the owner or operator reported the following information for each accidental release: [68.42(b)] Date, time, and approximate duration of the release? [68.42(b)(1)] Chemical(s) released? [68.42(b)(2)] Estimated quantity released in pounds and percentage weight in a mixture (toxics)? [68.42(b)(3)] NAICS code for the process? [68.42(b)(4)] The type of release event and its source? [68.42(b)(5)] Weather conditions (if known)? [68.42(b)(6)] On-site impacts? [68.42(b)(7)] Known offsite impacts? [68.42(b)(8)] Initiating event and contributing factors (if known)? [68.42(b)(9)] Whether offsite responders were notified (if known)? [68.42(b)(10)] Operational or process changes that resulted from investigation of the release? [68.42(b)(11)]
Section C: Prevention Program
Implemented the Program 3 prevention requirements as provided in 40 CFR 68.65 - 68.87?
Y
N N/A
S
M
U
N/A
Prevention Program- Safety information [68.65]
1. Has the owner or operator compiled written process safety information, which includes information pertaining to the hazards of the regulated substances used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process, before conducting any process hazard analysis required by the rule? [68.65(a)] Does the process safety information contain the following for hazards of the substances: [68.65(b)] Material Safety Data Sheets (MSDS) that meet the requirements of the OSHA Hazard Communication Standard [29 CFR 1910.1200(g)]? [68.48(a)(1)] Toxicity information? [68.65(b)(1)] Permissible exposure limits? [68.65(b)(2)] Physical data? [68.65(b)(3)] Reactivity data? [68.65(b)(4)] Corrosivity data? [68.65(b)(5)] Thermal and chemical stability data? [68.65(b)(6)] Hazardous effects of inadvertent mixing of materials that could foreseeably occur? [68.65(b)(7)]
2. Has the owner documented information pertaining to technology of the process? A block flow diagram or simplified process flow diagram? [68.65(c)(1)(i)] Process chemistry? [68.65(c)(1)(ii)] Maximum intended inventory? [68.65(c)(1)(iii)] Safe upper and lower limits for such items as temperatures, pressures, flows, or compositions? [68.65(c)(1)(iv)] An evaluation of the consequences of deviation? [68.65(c)(1)(iv)]
Y
N N/A
Y
N N/A
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3. Does the process safety information contain the following for the equipment in the process: [68.65(d)(1)] Materials of construction? 68.65(d)(1)(i)] Piping and instrumentation diagrams [68.65(d)(1)(ii)] Electrical classification? [68.65(d)(1)(iii)] Relief system design and design basis? [68.65(d)(1)(iv)] Ventilation system design? [68.65(d)(1)(v)] Design codes and standards employed? [68.65(d)(1)(vi)] Material and energy balances for processes built after June 21, 1999? [68.65(d)(1)(vii)] Safety systems? [68.65(d)(1)(viii)]
Y
N N/A
4. Has the owner or operator documented that equipment complies with recognized and generally accepted good engineering practices? [68.65(d)(2)]
Y
N N/A
5. Has the owner or operator determined and documented that existing equipment, designed and constructed in accordance with codes, standards, or practices that are no longer in general use, is designed, maintained, inspected, tested, and operating in a safe manner? [68.65(d)(3)]
Y
N N/A
Prevention Program- Process Hazard Analysis [68.67]
6. Has the owner or operator performed an initial process hazard analysis (PHA), and has this analysis identified, evaluated, and controlled the hazards involved in the process? [68.67(a)]
Y
N N/A
7. Has the owner or operator determined and documented the priority order for conducting PHAs, and was it based on an
Y
N N/A
appropriate rationale? [68.67(a)]
8. Has the owner used one or more of the following technologies to conduct process PHA: [68.67(b)] What-if? [68.67(b)(1)] Checklist? [68.67(b)(2)] What-if/Checklist? [68.67(b)(3)] Hazard and Operability Study (HAZOP) [68.67(b)(4)] Failure Mode and Effects Analysis (FMEA) [68.67(b)(5)] Fault Tree Analysis? [68.67(b)(6)] An appropriate equivalent methodology? [68.67(b)(7)]
Y
N N/A
9. Did the PHA address: The hazards of the process? [68.67(c)(1)] Identification of any incident that had a likely potential for catastrophic consequences? [68.67(c)(2)] Engineering and administrative controls applicable to hazards and interrelationships?[68.67(c)(3)] Consequences of failure of engineering and administrative controls? [68.67(c)(4)] Stationary source siting? [68.67(c)(5)] Human factors? [68.67(c)(6)] An evaluation of a range of the possible safety and health effects of failure of controls? [68.67(c)(7)]
Y
N N/A
10. Was the PHA performed by a team with expertise in engineering and process operations and did the team include appropriate personnel? [68.67(d)]
Y
N N/A
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11. Has the owner or operator established a system to promptly address the team's findings and recommendations; assured
Y
N N/A
that the recommendations are resolved in a timely manner and documented; documented what actions are to be taken;
completed actions as soon as possible; developed a written schedule of when these actions are to be completed; and
communicated the actions to operating, maintenance, and other employees whose work assignments are in the process
and who may be affected by the recommendations? [68.67(e)]
12. Has the PHA been updated and revalidated by a team every five years after the completion of the initial PHA to assure
Y
N N/A
that the PHA is consistent with the current process? [68.67(f)]
13. Has the owner or operator retained PHAs and updates or revalidations for each process covered, as well as the resolution of recommendations for the life of the process? [68.67(g)]
Y
N N/A
Prevention Program- Operating procedures [68.69]
14. Has the owner or operator developed and implemented written operating procedures that provide instructions or steps for conducting activities associated with each covered process consistent with the safety information? [68.69(a)]
Y
N N/A
15 Do the procedures address the following: [68.69(a)] Steps for each operating phase: [68.69(a)(1)] Initial Startup? [68.69(a)(1)(i)] Normal operations? [68.69(a)(1)(ii)] Temporary operations? [68.69((a)(1)(iii)] Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner? [68.69(a)(1)(iv)] Emergency operations? [68.69(a)(1)(v)] Normal shutdown? [68.68(a)(1)(vi)] Startup following a turnaround, or after emergency shutdown? [68.69(a)(1)(vii)] Operating limits: [68.69(a)(2)] Consequences of deviations [68.69(a)(2)(i)] Steps required to correct or avoid deviation? [68.69(a)(2)(ii)] Safety and health considerations: [68.69(a)(3)] Properties of, and physical hazards presented by, the chemicals used in the process [68.69(a)(3)(i)] Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment? [68.69(a)(3)(ii)] Control measures to be taken if physical contact or airborne exposure occurs? [68.69(a)(3)(iii)] Quality control for raw materials and control of hazardous chemical inventory levels? [68.69(a)(3)(iv)] Any special or unique hazards? [68.69(a)(3)(v)] Safety systems and their functions? [68.69(a)(4)]
Y
N N/A
16. Are operating procedures readily accessible to employees who are involved in a process? [68.69(b)]
Y
N N/A
17. Has the owner or operator certified annually that the operating procedures are current and accurate and that procedures
Y
N N/A
have been reviewed as often as necessary? [68.69(c)]
18. Has the owner or operator developed and implemented safe work practices to provide for the control of hazards during
Y
N N/A
specific operations, such as lockout/tagout? [68.69(d)]
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Prevention Program - Training [68.71]
19 Has each employee involved in operating a process, and each employee before being involved in operating a newly assigned process, been initially trained in an overview of the process and in the operating procedures? [68.71(a)(1)]
Y
N N/A
20. Did initial training include emphasis on safety and health hazards, emergency operations including shutdown, and safe
Y
N N/A
work practices applicable to the employee's job tasks? [68.71(a)(1)]
21. In lieu of initial training for those employees already involved in operating a process on June 21, 1999, an owner or operator may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures [68.71(a)(2)]
Y
N N/A
22. Has refresher training been provided at least every three years, or more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process? [68.71(b)]
Y
N N/A
23, Has owner or operator ascertained and documented in record that each employee involved in operating a process has received and understood the training required? [68.71(c)]
Y
N N/A
24. Does the prepared record contain the identity of the employee, the date of the training, and the means used to verify that the employee understood the training? [68.71(c)]
Y
N N/A
Prevention Program - Mechanical Integrity [68.73]
25. Has the owner or operator established and implemented written procedures to maintain the on-going integrity of the process equipment listed in 68.73(a)? [68.73(b)]
Y
N N/A
26. Has the owner or operator trained each employee involved in maintaining the on-going integrity of process equipment?
Y
N N/A
[68.73(c)]
27. Performed inspections and tests on process equipment? [68.73(d)(1)]
Y
N N/A
28. Followed recognized and generally accepted good engineering practices for inspections and testing procedures? [68.73(d)(2)]
Y
N N/A
29. Ensured the frequency of inspections and tests of process equipment is consistent with applicable manufacturers' recommendations, good engineering practices, and prior operating experience? [68.73(d)(3)]
Y
N N/A
30. Documented each inspection and test that had been performed on process equipment, which identifies the date of the
Y
N N/A
inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of
the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the
results of the inspection or test? [68.73(d)(4)]
31. Corrected deficiencies in equipment that were outside acceptable limits defined by the process safety information before further use or in a safe and timely manner when necessary means were taken to assure safe operation? [68.73(e)]
Y
N N/A
32. Assured that equipment as it was fabricated is suitable for the process application for which it will be used in the construction of new plants and equipment? [68.73(f)(1)]
Y
N N/A
33. Performed appropriate checks and inspections to assure that equipment was installed properly and consistent with design specifications and the manufacturer's instructions? [68.73(f)(2)]
Y
N N/A
34. Assured that maintenance materials, spare parts and equipment were suitable for the process application for which they
Y
N N/A
would be used? [68.73(f)(3)]
Prevention Program - Management Of Change [68.75]
35. Has the owner or operator established and implemented written procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to stationary sources that affect a covered process? [68.75(a)]
Y
N N/A
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36. Do procedures assure that the following considerations are addressed prior to any change: [68.75(b)] The technical basis for the proposed change? [68.75(b)(1)] Impact of change on safety and health? [68.75(b)(2)] Modifications to operating procedures? [68.75(b)(3)] Necessary time period for the change? [68.75(b)(4)] Authorization requirements for the proposed change? [68.75(b)(5)]
Y
N N/A
37. Were employees, involved in operating a process and maintenance, and contract employees, whose job tasks would be
Y
N N/A
affected by a change in the process, informed of, and trained in, the change prior to start-up of the process or affected
parts of the process? [68.75(c)]
38. If a change resulted in a change in the process safety information, was such information updated accordingly? [68.75(d)]
Y
N N/A
39. If a change resulted in a change in the operating procedures or practices, had such procedures or practices been updated accordingly? [68.75(e)]
Y
N N/A
Prevention Program - Pre-startup Safety Review [68.77]
40. If the facility installed a new stationary source, or significantly modified an existing source, (as discussed at 68.77(a)) did it perform a pre-startup safety review prior to the introduction of a regulated substance to a process to confirm: [68.77(b)]
Construction and equipment was in accordance with design specifications? [68.77(b)(1)]
Safety, operating, maintenance, and emergency procedures were in place and were adequate? [68.77(b)(2)]
For new stationary sources, a process hazard analysis had been performed and recommendations had been resolved or implemented before startup? [68.77(b)(3)]
Modified stationary sources meet the requirements contained in management of change? [68.77(b)(3)]
Training of each employee involved in operating a process had been completed? [68.77(b)(4)]
Y
N N/A
Prevention Program - Compliance audits [68.79]
41. Has the owner or operator certified that the stationary source has evaluated compliance with the provisions of the prevention program at least every three years to verify that the developed procedures and practices are adequate and being followed? [68.79(a)]
Y
N N/A
42. Has the audit been conducted by at least one person knowledgeable in the process? [68.79(b)]
Y
N N/A
43. Are the audit findings documented in a report? [68.79(c)]
Y
N N/A
44. Has the owner or operator promptly determined and documented an appropriate response to each of the findings of the
Y
N N/A
audit and documented that deficiencies had been corrected? [68.79(d)]
45. Has the owner or operator retained the two most recent compliance reports? [68.79(e)]
Y
N N/A
Prevention Program - Incident investigation [68.81]
46. Has the owner or operator investigated each incident that resulted in, or could reasonably have resulted in a catastrophic release of a regulated substance? [68.81(a)]
Y
N N/A
47. Were all incident investigations initiated not later than 48 hours following the incident? [68.81(b)]
Y
N N/A
48. Was an accident investigation team established and did it consist of at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of a contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident? [68.81(c)]
Y
N N/A
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49. Was a report prepared at the conclusion of every investigation? [68.81(d)]
Y
N N/A
50. Does every report include: [68.81(d)] Date of incident? [68.81(d)(1)] Date investigation began? [68.81(d)(2)] A description of the incident? [68.81(d)(3)] The factors that contributed to the incident? [68.81(d)(4)] Any recommendations resulting from the investigation? [68.81(d)(5)]
Y
N N/A
51. Has the owner or operator established a system to address and resolve the report findings and recommendations, and are the resolutions and corrective actions documented? [68.81(e)]
Y
N N/A
52. Was the report reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable? [68.81(f)]
Y
N N/A
53. Has the owner or operator retained incident investigation reports for at least five years? [68.81(g)]
Y
N N/A
Section D - Employee Participation [68.83]
1. Has the owner or operator developed a written plan of action regarding the implementation of the employee participation required by this section? [68.83(a)]
Y
N N/A
2. Has the owner or operator consulted with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in chemical accident prevention provisions? [68.83(b)]
Y
N N/A
3. Has the owner or operator provided to employees and their representatives access to process hazards analyses and to all other information required to be developed under the chemical accident prevention rule? [68.83(c)]
Y
N N/A
Section E - Hot Work Permit [68.85]
1. Has the owner or operator issued a hot work permit for each hot work operation conducted on or near a covered process? [68.85(a)]
Y
N N/A
2. Does the permit document that the fire prevention and protection requirements in 29CFR 1910.252(a) have been implemented prior to beginning the hot work operations? [68.85(b)]
Y
N N/A
3. Does the permit indicate the date(s) authorized for hot work and the object(s) upon which hot work is to be performed?
Y
N N/A
[68.85(b]
4. Are the permits being kept on file until completion of the hot work operations? [68.85(b)]
Y
N N/A
Section F - Contractors [68.87]
1. Has the owner or operator obtained and evaluated information regarding the contract owner or operator's safety performance and programs when selecting a contractor? [68.87(b)(1)]
Y
N N/A
2. Informed contract owner or operator of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process? [68.87(b)(2)]
Y
N N/A
3. Explained to the contract owner or operator the applicable provisions of the emergency response or the emergency action program? [68.87(b)(3)]
Y
N N/A
4. Developed and implemented safe work practices consistent with 68.69(d), to control the entrance, presence, and exit of the contract owner or operator and contract employees in the covered process areas? [68.87(b)(4)]
Y
N N/A
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5. Periodically evaluated the performance of the contract owner or operator in fulfilling their obligations (as described at 68.87(c)(1) - (c)(5))? [68.87(b)(5)]
Y
N N/A
Section G - Emergency Response [68.90 - 68.95]
Developed and implemented an emergency response program as provided in 40 CFR 68.90-68.95? Comments:
S
M
U
N/A
1. Is the facility designated as a "first responder" in case of an accidental release of regulated substances"
Y
N N/A
1.a. If the facility is not a first responder:
1.a.(1) For stationary sources with any regulated substances held in a process above threshold quantities, is the source included in the community emergency response plan developed under 42 U.S.C. 11003? [68.90(b)(1)]
Y
N N/A
1.a.(2) For stationary sources with only regulated flammable substances held in a process above threshold quantities, has the owner or operator coordinated response actions with the local fire department? [68.90(b)(2)]
Y
N N/A
1.a.(3) Are appropriate mechanisms in place to notify emergency responders when there is need for a response? [68.90(b)(3)]
Y
N N/A
2. An emergency response plan is maintained at the stationary source and contains the following? [68.95(a)(1)]
Procedures for informing the public and local emergency response agencies about accidental releases? [68.95(a)(1)(i)]
Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures? [68.95(a)(1)(ii)]
Procedures and measures for emergency response after an accidental release of a regulated substance? [68.95(a)(1)(iii)]
Y
N N/A
3. The emergency response plan contains procedures for the use of emergency response equipment and for its inspection,
Y
N N/A
testing, and maintenance? [68.95(a)(2)]
4. The emergency response plan requires, and there is documentation of, training for all employees in relevant procedures? [68.95(a)(3)]
Y
N N/A
5. The owner or operator has developed and implemented procedures to review and update, as appropriate, the emergency response plan to reflect changes at the stationary source and ensure that employees are informed of changes? [68.95(a)(4)]
Y
N N/A
6. Did the owner or operator use a written plan that complies with other Federal contingency plan regulations or is consistent with the approach in the National Response Team's Integrated Contingency Plan Guidance (``One Plan'')? If so, does the plan include the elements provided in paragraph (a) of 68.95, and also complies with paragraph (c) of 68.95? [68.95(b)]
Y
N N/A
7. Has the emergency response plan been coordinated with the community emergency response plan developed under EPCRA? [68.95(c)]
Y
N N/A
Section H - Risk Management Plan [40 CFR 68.190 - 68.195]
1. Does the single registration form include, for each covered process, the name and CAS number of each regulated substance held above the threshold quantity in the process, the maximum quantity of each regulated substance or mixture in the process (in pounds) to two significant digits, the five- or six-digit NAICS code that most closely corresponds to the process and the Program level of the process? [68.160(b)(7)]
Y
N N/A
2. Did the facility assign the correct program level(s) to its covered process(es)? [68.160(b)(7)]
Y
N N/A
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3. Has the owner or operator reviewed and updated the RMP and submitted it to EPA [68.190(a)]? Reason for update:
Five-year update. [68.190(b)(1)]
Within three years of a newly regulated substance listing. [68.190(b)(2)]
At the time a new regulated substance is first present in an already regulated process above threshold quantities. [68.190(b)(3)]
At the time a regulated substance is first present in an new process above threshold quantities. [68.190(b)(4)]
Within six months of a change requiring revised PHA or hazard review. [68.190(b)(5)]
Within six months of a change requiring a revised OCA as provided in 68.36. [68.190(b)(6)]
Within six months of a change that alters the Program level that applies to any covered process. [68.190(b)(7)]
4. If the owner or operator experienced an accidental release that met the five-year accident history reporting criteria (as described at 68.42) subsequent to April 9, 2004, did the owner or operator submit the information required at 68.168, 68.170(j) and 68.175(l) within six months of the release or by the time the RMP was updated as required at 68.190, whichever was earlier. [68.195(a)]
5. If the emergency contact information required at 68.160(b)(6) has changed since June 21, 2004, did the owner or operator submit corrected information within thirty days of the change? [68.195(b)]
Y
N N/A
Y
N N/A
Y
N N/A
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