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  • Is gasoline exempt from the requirements of Part 68?

    Is gasoline exempt from the requirements of 40 CFR Part 68? Although gasoline is not specifically listed as a regulated substance under 40 CFR Section 68.130, it may contain one or more regulated substances. On January 6, 1998 ( 63 FR 640 ), EPA exempted from threshold determination regulated flammable…

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  • RMP Self-Paced Training Courses

    Does EPA offer any self-paced training courses covering the Risk Management Program under Clean Air Act Section 112(r)? Yes, EPA Region 7 developed self-paced training modules for facilities with program level 1, 2 or 3 processes. The modules cover topics such as RMP applicability, offsite consequence analysis, 5-year accident history…

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  • Compliance date for adding covered processes

    What happens if I bring a new covered process on line (e.g., install a second storage tank) after submitting my original RMP? For a new covered process added after the initial compliance date, you must be in compliance on the date you first have a regulated substance above the threshold…

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  • “Other EPA Systems Facility Identifier” for RMP Facility

    A facility subject to the Risk Management Program requirements in 40 CFR Part 68 must enter an “Other EPA Systems Facility Identifier” in Section 1.3 of the Risk Management Plan (RMP). The RMP*eSubmit User’s Manual provides the priority order of identification numbers facilities should use to complete this section. What…

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  • Covered chemicals and the definition of process

    Does a chemical need to be in a process to be covered by the CAA §112(r) risk management program requirements? The risk management program requirements apply to owners and operators of stationary sources that have more than a threshold quantity of a regulated substance contained in a process (40 CFR…

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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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  • Compliance Audit Date for First Time RMP Submissions

    Facilities subject to the Risk Management Program (RMP) requirements in 40 CFR Part 68 with Program Level 2 and 3 processes must perform compliance audits at least once every three years (40 CFR §§68.58 and 68.79). Section 7.10 of the RMP requires the date of the most recent compliance audit…

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  • Naturally Occurring Hydrocarbon Mixtures Exemption

    Pursuant to the risk management program regulations under 40 CFR §68.115(b)(2)(iii), regulated substances in naturally occurring hydrocarbon mixtures prior to entry into a natural gas processing plant or a petroleum refining process unit do not need to be considered when determining whether more than a threshold quantity is present at…

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  • Hot Work Permit Review Date

    Stationary sources subject to the Program 3 Prevention Program requirements in 40 CFR Part 68, Subpart D, must include in their Risk Management Plan the date of the most recent review or revision of hot work permit procedures in Section 7.13. What date should the owner or operator enter in…

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  • RMP Facility Relocates

    Under the risk management program regulations in 40 CFR §68.190, owners or operators must revise and update their risk management plan (RMP) if they meet any of the specified criteria or deregister the RMP within 6 months if they are no longer subject to the rule. However, what should stationary…

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  • RMP*Comp and emergency response

    Can I use RMP*Comp for emergency response? No. It's a planning tool. Many other tools are available for response, including ALOHA . You can learn more by reading CAMEO tools for RMP .

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  • Minimum and Maximum Distance to Endpoint

    The Chemical Accident Prevention Provisions require the completion of a worst-case release scenario analysis (40 CFR §68.25). This analysis includes estimating the greatest distance to endpoint as defined by the parameters in §68.22. Is there a required minimum or maximum distance for the distance to endpoint in the worst case…

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  • Are facilities that have received ISO 14001 certification exempt from audits?

    If we have been audited by a qualified third party, for ISO 14001 certification or for other programs, are we exempt from audits? No. However, you may want to inform your implementing agency that you have gained such certification and indicate whether the third party reviewed Part 68 compliance as…

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  • Will risk management plan (RMP) submissions be subject to audits?

    Will risk management plan (RMP) submissions be subject to audits? If so, who will conduct the audits? Yes. According to 40 CFR §68.220(a), the implementing agency will periodically audit RMPs in order to review their adequacy, and may require revisions of RMPs as necessary to ensure compliance. The implementing agency…

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  • Applicable requirements for Title V air permits

    Under the CAA, air permitting authorities must ensure that sources are in compliance with applicable requirements to issue a permit. Do the CAA §112(r) provisions constitute applicable requirements for Title V air permits? Yes. Section 112(r) is an applicable requirement for CAA Title V air permits under 40 CFR Parts…

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