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  • Inclusion of accidents under different ownership in the accident history

    If a facility has recently changed ownership, is the new facility owner required to include accidents which occurred prior to the transfer of ownership in the accident history portion of the RMP submitted for the facility? Yes, accidents involving covered processes that occurred prior to the transfer of ownership should…

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  • Why did EPA select the twenty percent concentration cut-off value for aqueous ammonia?

    The list of regulated substances in 40 CFR §68.130 includes aqueous ammonia that is at a concentration of 20 percent (by weight) or greater. Why did EPA select 20 percent as the concentration cut-off value? Commonly used commodity solutions of ammonia (which mean the bulk shipments, not bottles of ammonia…

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  • Does "consider off-site consequences" mean perform an environmental impact assessment?

    What does EPA mean by “consider offsite consequences”? Do we have to do an environmental impact assessment (EIA)? EPA does not expect you to do an EIA. Potential consequences to the public and the environment are already analyzed in the offsite consequence analysis. In the PHA, EPA only expects you…

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  • Stationary source subject to OSHA PSM but below EPA threshold

    A stationary source is subject to the OSHA process safety management standard (PSM) because it exceeds the OSHA PSM threshold for chlorine. The stationary source does not, however, exceed the threshold for chlorine (or any other regulated substances) in a process under the Risk Management Program regulations (40 CFR §68.130)…

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  • If a facility moves (their address changes) is it assigned a new RMP Facility ID?

    Yes. The facility is treated as a new facility and would be assigned a new number by EPA.

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  • Are wetlands included in the definition of "environmental receptors"?

    No. EPA has defined environmental receptors as natural or state parks, forests, or monuments; officially designated wildlife sanctuaries, preserves, refuges, or areas; and Federal wilderness areas, that are easily identified on local U.S. Geological survey maps (40 CFR §68.3). Therefore, wetlands would not be reported in the hazard assessment under…

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  • Submitting a partial RMP

    Can a facility submit a partial risk management plan (RMP) (e.g., using the predictive filing option) and then update the plan when all elements of the RMP can be implemented? No. Facilities should not attempt to submit partial risk management plans (the RMP*eSubmit software will not allow incomplete RMPs to…

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  • Do I have to include on-site incidents in my accident history?

    If I have a large on-site incident, but no offsite impact, would I have to report it in the five-year accident history? It would depend on whether you have onsite deaths, injuries, or significant property damage. You could have a large accident without any of these consequences (e.g., a large…

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  • Amounts of regulated substances in a delivery truck's tank

    My stationary source has a process that contains a maximum of 4,000 lbs. of a regulated substance that has a 5,000 lb. threshold quantity. When the level of the regulated substance in the process reaches 1,000 lbs., a delivery truck comes on site and connects to the process to replenish…

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  • Are chemicals in a tank car exempt from threshold determinations under 40 CFR Part 68?

    The definition of stationary source does not apply to transportation, including storage incident to transportation (40 CFR Section 68.3). Are chemicals in a tank car (e.g., tanker truck or rail car) therefore exempt from threshold determination? The chemicals in the tank car are exempt only if the tank car is…

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  • Are motor fuels exempt from threshold determination?

    Are motor fuels (e.g., gasoline and diesel fuel) exempt from threshold determination? EPA provided a specific exemption from threshold determination for regulated flammable substances in gasoline used as fuel for internal combustion engines. This exemption applies solely to gasoline. However, there is a general exemption from threshold determination for regulated…

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  • Are the risk management program requirements applicable to federal facilities?

    Yes. The requirements at 40 CFR Part 68 are applicable to an owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process (40 CFR §68.10(a)). The definition of stationary source includes buildings, structures, equipment, installations, or substance emitting stationary…

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  • Amounts of chlorine present in sodium hypochlorite

    Must the amount of chlorine present in sodium hypochlorite be considered when determining whether a process is subject to the Risk Management Program regulations in 40 CFR Part 68? No. The risk management program regulations apply only to processes that contain more than a threshold quantity of one of the…

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  • Is replacing a process tank considered a modification?

    If an RMP covered facility replaces a storage tank that is a covered process with a new tank containing the same regulated substance, is this considered to be a modification of an existing process, or a new process? Assuming the new tank contains the same substance and occupies the same…

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  • CAMEO Training Opportunities

    Where can I find CAMEO training opportunities? Information on CAMEO training and events is available at the EPA CAMEO website.

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