Serving the Oil & Gas Industry

Risk Management Plans

Risk Management Plans (RMP) are a federal requirement, under 40 CFR 68, for any facility storing a regulated substance over the threshold quantity in a process. A process is defined, by the EPA, as "any activity involving a regulated substance, including any use, storage, manufacturing, handling, or on-site movement of such substances, or combination of these activities."

In the Oil and Gas Industry a common regulated substance that triggers the need for an RMP is natural gas liquids, or NGL, tanks. Risk management plans are broken down into three programs.

  • Program 1 - Processes which would not affect the public in a worst-case release
  • Program 2 - Processes not eligible for program 1 or subject to program 3 are placed in program 2
  • Program 3 - Processes not eligible for program 1 and either subject to OSHA's PSM standard under federal or state OSHA programs or classified in one of ten specified NAICS codes are placed in program 3.

ESR Environmental personnel are experienced in RMP evaluation, classification, and assembly