Risk Management Plans (RMPs)
See the special section "RMP Toolbox" for the latest information and documents on RMPs!
Developed under the Clean Air Act Amendments of 1990, EPA requires facilities with compounds exceeding threshold quantities (TQs) to prepare risk management plans (RMPs) to protect the general public and environment from accidental releases.
Hazard Assessment: Identify "worst-case" and "other more likely significant accidental release" scenarios; identify offsite consequences; and document a five-year history of significant accidental releases.
Prevention Program: Each RMP will include an prevention program to reduce accidental release hazards.
Emergency Response Plan: Covers standard response actions such as evacuation routes, employee emergency response procedures, first-aid, and notification of authorities.
The program ranks facilities according the following classification:
Program 1 (Least Stringent): 1) No "significant" accidental release in last five years, 2) minimum specific distances between compounds and nearest offsite receptors.
Program 2: The default category from Tiers 1 & 3, Tier 2 facilities are the ones that already subject to other governmental programs to reduce the risk of release.
Program 3 (Most Stringent): In general, applies to facilities that are required to have an OHSA Process Safety Management (PSM) Plan.
All facilities have 3 years to comply with ruling. This period ends June 21, 1999.
Visit the RMP Toolbox, or
call (800) 682-7255 to obtain a repint of
the Environmental Solutions' magazine article entitled
"Federal Program for Regulating Highly Hazardous Materials Finally Takes
Off, " written by BES staff.
A recently published report by the Lawrence Livermore National Laboratory (LLNL) recommends passive bioremediation "wherever possible," and an immediate modification of the Risk-Based Cleanup Action (RCBA) to support a tier-one decision making process.
Oversight agencies (i.e., Regional Water Quality Control Boards) have endorsed the report, and are calling for aggressive implementation. Utilizing measures specified will allow agencies to close low-risk, soil-only, petroleum contaminated, leaking underground storage tank (LUST) sites. For low-risk groundwater sites (shallow groundwater with maximum depth to water less than 50 feet and no drinking water wells screened in the shallow groundwater zone within 250 feet of the leak), remediation should be replaced with monitoring.
Read memos below for specifics:
Developed by the American Society of Testing and Materials (ASTM), the Risk-Based Corrective Action (RBCA; "Rebecca") Standard (38-94) is designed to simplify the human health risk assessment process. It was recently endorsed by the EPA, and Block Environmental Services has utilized its approach at several Bay Area sites.
This approach breaks the site investigation into Tier 1, 2, and 3 levels. Tier 1 is the least contaminated and Tier 3 the most contaminated. Tier 1 is based on comparing chemical concentrations to "evergreen" risk-based cleanup levels such as the EPA Region IX Preliminary Remediation Goals (PRG's) or the values (BTEX only) provided in the guidance. Note that RBCA levels are much less stringent than EPA levels which would ultimately reduce cleanup costs. For example, the residential soil cleanup standard for benzene in the ASTM guidance is 1.05 mg/kg compared with 5 mg/kg specified by the EPA-a five-fold reduction for benzene! For more information about this important document and its applications call (800) 682-7255.
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