Risk Management Program

What You Need To Know
The U. S. Environmental Protection Agency introduced the Risk Management Program (RMP) with the primary goal of increasing the public's safety with respect to the industrial and commercial use of certain hazardous chemicals.

While the regulations are new, it is important to note that there are no new risks to the community.  The companies that must comply with the regulations have operated in Will County for many years.  They have developed and continually fine-tuned accident prevention and response plans which are reviewed with local emergency responders.

The Risk Management Program will only make good plans better.  How? By taking chemical safety to an even higher level.  The regulations require companies that use, store or manufacturer specified amounts of the listed 140 toxic and flammable chemicals to prepare Risk Management Plans (RMPs).  The plans needed to be filed with the EPA and Local Emergency Planning Committees (LEPCs) by June 21, 1999.

While local companies have developed "what if" scenarios for many years, the regulations require them to "stretch" these accident scenarios.  The EPA calls these "worst-case scenarios" and while highly unlikely to occur, they do help companies and emergency responders to prepare even better plans.  Under the regulations, companies must also prepare "alternative-release scenarios."

The regulations require only that companies submit RMPs to the EPA and LEPCs, not to the public-at-large.  Companies in Will County do not think that's enough.  They created the Risk Management Consortium to communicate their plans directly to the public.

An overview of important RMP elements follows:

• Hazard assessment and accident scenarios
• Accident prevention programs
• Emergency response plans

Hazard Assessment and Accident Scenarios
Hazard assessments are the core of accident prevention programs and emergency response planning because they provide knowledge of the types of accidents that could occur and the potential effects.  As mentioned, this process involves the development of worst-case and alternative-release scenarios.

Worst-case scenarios are hypothetical accidents involving hazardous substances that result in the most severe consequences - the instantaneous rupture of a large tank, for example.  Worst-case scenarios assume that active mitigation systems do not function and that emergency response procedures are not employed.

Alternative-release scenarios are more likely to occur than worst-case scenarios.  An example is a chemical spilling from a ruptured hose.  These scenarios allow for mitigation systems to function and for emergency response plans to be employed.

The development of these scenarios, as required by the RMP regulations, does not mean such accidents would ever occur, or that the consequences would be as far-reaching as the scenarios show.  Most chemical releases that actually occur have no impact beyond a facility's fenceline.

Finally, RMPs require facilities to describe accidents involving regulated chemicals that caused significant effects, inside or outside of their fencelines, within the past five years.

Accident Prevention Programs
The primary goal of the RMP regulations is to prevent accidents from ever occurring.  Industry clearly supports this goal.  Accident prevention is integrated into virtually every aspect of facility operations, from the design and maintenance of piping, tanks and other systems, to the training of employees and day-to-day management.

Measures that promote accident prevention are not only required by the many governmental regulations, but by many corporate and facility operating procedures, as well.  Most facilities in Will County have had accident prevention programs in place for a number of years.  Preparing RMPs provides another opportunity to improve these programs.

Information on the facilities' specific accident prevention programs is included in each facility's RMP summary brochure.

Emergency Response Plans
A word about Local Emergency Planning Committees (LEPCs).  As mentioned, RMPs must be submitted to LEPCs as well as the EPA.  Individual facilities have primary responsibility for responding to emergencies within their fencelines and for coordinating their responses with local fire departments.  LEPCs are responsible for developing plans for safeguarding the public if hazards move off-site.

Will County has an active Local Emergency Planning Committee made up of state and local officials, fire, police, emergency management, emergency medical services, hospitals, media and industry.  The function of the LEPC is to develop emergency plans to protect the public in the event of chemical accidents and to communicate these plans to the public.

Although the LEPC works closely with industry and include industry representatives, their primary goal is to protect the public.  The RMP information for each facility has been woven into the LEPCs Comprehensive Chemical Contingency Plan to increase our effectiveness.

How are release scenario distances determined?
To calculate the release scenario distances, facilities used either the EPA's "off-site consequences" or "look-up" tables, or other EPA-accepted computer models.

Models are used to determine how far the effects of a chemical release, fire, or explosion could reach.  The distances are based on the amount and the type of chemical involved, weather conditions, and topography.  For toxic chemicals, the amount of the chemical (concentration) that could cause harm is figured into the calculation to determine the farthest distance from the facility a given amount of chemical could potentially reach and harm people.  For flammable releases, distances are calculated by determining how far harmful heat and/or explosive overpressures from a fire and/or explosion could reach.

What do the release scenario maps show?
The release scenario maps show potential distances which toxic chemicals or heat or explosive overpressures could reach.  The scenario maps show these distances as circles, with the plant at the center.  In the case of a toxic chemical, the chemical would typically travel with the prevailing winds in a corridor or "plume", rather than affecting the entire circled area.

How are exposure levels determined?
To determine the potential distance the effects from chemical releases could travel, the government and other health and safety groups have set "endpoints" for exposure to toxic chemicals.  They have also set exposure levels for heat and/or explosive overpressures for flammable chemicals.  All of these measurements are based on protecting human health.

There are two types of toxic "endpoints".  One, which is set for a number of the toxic chemicals, is called the Emergency Response Planning Guidelines (ERPG) established by the American Industrial Hygiene Association.  The guideline used as endpoint is the "EPRG-2" level, which is the amount of the chemical to which an average person could be exposed for up to one hour without developing irreversible or serious health effects that could limit the person's ability to protect him or herself.

The second type of toxic endpoint, called the Level of Concern (LOC), is used when the ERPG value for chemical has not been set.  LOC is one-tenth of the Immediately Dangerous to Life and Health (IDLH) level developed by the National Institute of Occupational Safety and Health (NIOSH).  An IDLH level is an exposure likely to cause death, or to cause immediate or delayed health effects, or to prevent a person from escaping from an exposed area.

Distances for flammable exposures are based on explosive overpressures and/or radiant heat.

What is a flammable release?
This is the release of a regulated flammable substance that could lead to a fire or explosion.  A flammable release is considered hazardous because of high levels of thermal radiation (heat) and overpressure from explosions.  In risk management planning, facilities must show in their scenarios the distances that potentially harmful levels of heat or explosive overpressures could travel in the event of a chemical release and fire and/or explosion.

What are mitigation or mitigation systems?
Mitigation or mitigation systems refer to specific activities, technologies or equipment designed or used to capture or control chemicals that have been released so that exposures to the public or the environment are minimized.  "Passive mitigation" means equipment, devices or technologies that function without human, mechanical or other energy input.  "Active mitigation" means equipment, devices or technologies that require human, mechanical or other energy input to function.

If you have any questions, or would like more information about the Risk Management Program, please contact our office.