Hydrogen is an RMP regulated flammable substance at a threshold quantity of 10 000 lb. The RMP rule applies when the total weight of hydrogen in the bulk tank plus the weight of hydrogen in the process meets or exceeds 10 000 lb. More details about calculating the 10 000 lb system threshold quantity can be found in CGA H-5, Installation Standards for Bulk Hydrogen Supply Systems [4].

This guidance document provides generic information necessary to support the hazard assessment and the process hazard analysis portion of the prevention program. Specifically, it includes a typical system flow diagram (TSFD), a typical system HAZOP, and offsite consequence analysis (OCA) information for a bulk liquid hydrogen system. Tables and charts for the assessments of the appropriate worst-case and alternative-case release scenarios are also included. In addition, information is provided to assist in the development and submission of a typical risk management plan.

This guidance document does not constitute a total RMP. Facilities covered by the RMP rule must also:

– Compile and report a history of accidental releases for the 5 years prior to the submission of the RMP plan as provided in 40 CFR 68.42 [2];

– Develop a management system to oversee the implementation of all elements of the RMP for program 2 or program 3 regulated processes as provided in 40 CFR 68.15 [2];

– Determine one of three program levels to assign the covered process as provided in 40 CFR 68.10 and comply with the applicable program level general requirements as provided in 40 CFR 68.12. Details for program 2 are provided in 40 CFR 68.48 through 68.60, and program 3 details are provided in 40 CFR 68.65 through 68.87 [2];

– Develop and implement an emergency response program for the purpose of protecting public health and the environment as provided in 40 CFR 68.95, except as provided in paragraph (b) of 40 CFR 68.90 [2]; and

– Prepare and submit a single risk management plan as provided in 40 CFR 68.150 that includes the information required by 40 CFR 68.155 through 68.185 for all covered processes [2].

As illustrated above, this guidance document does not represent a total RMP nor does it provide all the information required in a complete risk management plan submission. The very nature of the guidance document is to provide "guidance only" and not to present a complete or model RMP. Each individual company must exercise its own judgment regarding how they use this guidance document and how they achieve RMP compliance.

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