Five Year Updates
EPA Risk Management Plans (RMP) must be updated at least once every five years. Otherwise, you must fully update your RMP for re-submission sooner than the five-year date, if any of the changes specified below occur [as specified in 40 CFR 68.190(b)].
- Within 6 months of a change that alters the Program Level that applies to any covered process;
- Within 6 months of a change that requires a revised off-site consequence analysis;
- Within 6 months of a change that requires a revised PHA or Hazard Review;
- The date on which a regulated substance is first present above a threshold quantity in a new process; and,
- Three years after the date when a substance is first regulated by EPA.
- If a stationary source is no longer subject to RMP, the owner or operator shall submit a de-registration to EPA within six months indicating that the stationary source is no longer covered.
Re-submissions re-set the five-year anniversary date by which you must next update your RMP. To qualify as a Five Year Update, you must update all nine sections of your RMP. This should not be confused with the submission of a corrected RMP which does not reset the five year anniversary date.
A Correction should be used to report administrative or other changes at your facility (e.g. changes in emergency contact information, facility address, or change in accident history). This does not require an update of your entire RMP. Submitting a corrected RMP does not change your five-year anniversary date. A Corrected RMP must be submitted:
- Within six months of the release or with the Five Year Update, whichever is earlier.
- Within one month of any change in the emergency contact information.
The Five Year Update usually consists of three components:
- Hazard Assessment Update
- Process Hazard Analysis (PHA) or Hazard Review (HR) Update
- Certification and submittal of the RMP to the EPA and/or State Administering Agency (AA)
Risk Management Professionals’ experience developing and managing the onsite implementation of the regulatory programs allows efficient and cost effective updates. Furthermore, Risk Management Professionals takes the opportunity to review available documentation in order to provide key insights on program improvement.
Hazard Assessment Update
The Hazard Assessment must be reviewed and updated at least once every five years. If changes in processes, quantities stored or handled, or any other aspect of the stationary source might reasonably be expected to increase or decrease the distance to the endpoint by a factor of two or more, the owner or operator shall complete a revised analysis within six months of the change and submit a revised risk management plan.
Risk Management Professionals has extensive experience with a wide range of EPA approved Dispersion Models. Our Hazard Assessment Reports are structured in a format that is easily updatable and understandable by facility personnel and regulators. All calculations, assumptions, model input and output parameters are always justifiable and summarized in detail. This allows the client an easy method for updating the document in 5 years as required. Furthermore, Risk Management Professionals’ Hazard Assessment reports allow easy justification for all determinations made and their regulatory compliance.
PHA and/or HR Updates
For many facilities, the Process Hazard Analysis or Hazard Review Five Year Revalidation schedule is synchronized with the Five Year Update cycle of the RMP. Risk Management Professionals provides engineering support and facilitation to evaluate the hazards of any process. Our engineers have broad process knowledge which provides efficient and cost-effective guidance for our clients. Risk Management Professionals’ engineers have extensive experience implementing the following Process Hazard Analysis methodologies:
- Hazard and Operability (HAZOP)
- Layer of Protection Analysis (LOPA)
- What-If and Checklist Analysis
Upon completion of the analysis, Risk Management Professionals works closely with clients to develop comprehensive reports and action item tracking methods to ensure compliance with government and company requirements.
In addition to program development and 5-year updates, Risk Management Professionals has assisted numerous facilities comply with government regulations and Management of Change procedures through revalidation or updates to their existing PHA’s.
Certification and Submittal
The RMP*eSubmit application allows you to securely submit your RMP over the Internet through the EPA Central Data Exchange (CDX). To use RMP*eSubmit, the Certifying Official for your facility (typically the facility owner or operator or a designated senior management official employed by the facility) must first be registered in CDX. Additionally, the Certifying Official must complete and sign an Electronic Signature Agreement (ESA) which will be used to verify the identity of the Certifying Official in the system. The ESA must be mailed to the RMP Reporting Center and approved prior to being able to prepare or certify an RMP using RMP*eSubmit. The registration process for the online RMP*eSubmit application is different if you already have a CDX user account (such as for previously registering to use RMP*WebRC or any other CDX application), and is based on whether your role is a Certifying Official or a Preparer.
If the facility has not already, Risk Management Professionals will assist in the registration and submission using the RMP*eSubmit application.
We work closely with the State AA to ensure acceptance of the submittal. We also understand that the RMP and State Accidental Release Prevention Programs are living programs that must be updated and maintained for the life of the process. After submission, all digital program files are provided upon completion of the project. The files are in Microsoft Office format. The printout summarizing the submittal data, dispersion model output files, and all other relevant digital files used in the production of the reports are provided.