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  • RMP Covered Facilities

    Who is covered by the RMP rule under CAA §112(r)(7)? Section 112(r) of the CAA contains several provisions. The two most relevant to the regulated community at this time are Sections 112(r)(1) and 112(r)(7). Owners and operators of stationary sources at which regulated or any other extremely hazardous substances are…

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  • Are methane processes at landfills subject to RMP?

    Some landfills collect methane gas and either vent, flare, or store it for subsequent fuel use. Are methane processes at landfills subject to the requirements of the EPA Risk Management Program? In general, methane processes at landfills will not be covered under the Risk Management Program. Methane that is collected…

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  • Are bulk storage terminals exempt from filing a Risk Management Plan?

    There is no general exemption for bulk storage terminals. However, the threshold exemption for "regulated substances in naturally occurring hydrocarbon mixtures prior to entry into a natural gas processing plant or a petroleum refining processing unit" would exempt certain storage terminals, such as crude oil storage terminals where the regulated…

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  • Do the risk management program regulations cover the loading and unloading of transportation containers?

    Would the risk management program regulations cover the loading and unloading of transportation containers? The definition of stationary source includes transportation containers used for storage not incident to transportation and transportation containers connected to equipment at a stationary source for loading or unloading (40 CFR Section 68.3). In a January…

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  • Which chemicals are covered by the general duty provisions?

    For CAA section 112(r)(1), General Duty, what are the chemicals that are covered? There is no specific list of substances which subject a stationary source owner or operator to the general duty provisions. The general duty provisions apply to owners and operators of all stationary sources which have any "extremely…

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  • How large would a pipe have to be to contain a threshold amount of methane?

    An owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process must comply with the requirements in 40 CFR Part 68. How large would a pipe have to be to contain a threshold amount (10,000 pounds) of methane? Assuming…

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  • Can EPA add chemicals to the list of regulated substances under Part 68?

    Can EPA on its own initiative add chemicals to the list, or must it receive a petition from an outside party first and then follow the petition process? EPA may revise the list of regulated substances at the discretion of the Administrator or as a result of petitions. Modifications to…

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  • How does EPA verify accuracy and completeness of RMPs?

    What does EPA plan to do to verify the accuracy and completeness of submitted Risk Management Plans (RMPs)? All RMPs received by EPA go through an electronic verification process that checks the submission for its completeness. This completeness check determines whether information has been provided for all of the required…

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  • Vulnerable Zone Determination

    Vulnerable zones are areas that could be affected by a release from a chemical accident at a facility subject to the risk management program requirements in 40 CFR Part 68. How can one determine if they live or work within a vulnerable zone? The Vulnerable Zone Indicator System (VZIS) allows…

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  • Identification of Industrial Buildings, Commercial Buildings, and Recreational Areas

    Pursuant to the hazard assessment requirements in 40 CFR Part 68, Subpart B, an owner or operator is required to conduct an offsite consequence analysis and analyze a worst-case release scenario and alternative release scenarios as part of a risk management plan (RMP). When completing these scenarios, public receptors need…

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  • Five-Year Accident History for Non-Gas Releases

    Pursuant to 40 CFR §68.42(a), the owner or operator of a stationary source subject to the risk management program regulations must document significant accidental releases of regulated substances from a covered process in the five years prior to the submission of an initial or updated risk management plan (RMP). For…

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  • Why were ERPG-2 values selected as toxic endpoints instead of ERPG-3?

    An endpoint is needed for analysis of offsite consequences of potential accidental releases of regulated substances. The endpoint to be used for each regulated toxic substance is provided in Part 68, Appendix A, and is the Emergency Response Planning Guideline level 2 (ERPG-2) developed for the substance by the American…

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  • Release scenarios for substances exhibiting flammability and toxicity

    Under the hazard assessment requirements in 40 CFR Part 68, Subpart B, an owner or operator must analyze worst-case release scenarios and more likely alternative release scenarios, and must document a five-year accident history. If a regulated substance exhibits characteristics of both toxicity and flammability, should owners and operators consider…

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  • Worst-case “quantity released” reporting for a mixture

    In section 2, element 2.5, of an RMP, facilities must report the quantity of toxic chemical that the facility used for the worst-case analysis. When reporting this data element in RMP*eSubmit for a mixture, should facilities report the entire weight of the toxic mixture potentially being released or only the…

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  • What is the content of Part 68, Subpart F and when was it promulgated?

    The regulatory text of the June 20, 1996, Risk Management Program Rule ( 61 FR 31668 ) does not include Subpart F. What is the content of Subpart F and when was it promulgated? Subpart F of 40 CFR Part 68 consists of the regulations concerning the list of regulated…

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