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  • Adding chemicals to list of regulated substances

    CAA §112(r)(3) provides EPA the authority to amend the list of regulated substances. Does EPA expect to add chemicals to the list of regulated substances in the near future? At this time, EPA does not expect to add any chemicals to the list of regulated substances. The statute, however, requires…

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  • Local meteorological data for alternative release scenarios

    For alternate release scenarios, RMP*Comp uses set values for meteorological conditions like humidity, wind speed, temperature, stability class, and so on. Is there a way to change those values? I want to use meteorology data from my own location. RMP*Comp indeed uses fixed values for certain atmospheric parameters, and does…

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  • Are there any RMP recordkeeping requirements?

    Are there any recordkeeping requirements specified in the risk management program (RMP) regulations in 40 CFR Part 68? The owner or operator of a stationary source that is subject to the RMP regulations must maintain records supporting the implementation of Part 68 for five years (§68.200).

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  • Can I submit a plan that includes substances not currently present at the facility?

    Can an RMP regulated facility submit a Risk Management Plan (RMP) that includes substances not held at the facility at the time of submission? Yes. Predictive filing is an option that allows owners and operators of facilities whose operations involve highly variable types and quantities of regulated substances (e.g., chemical…

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  • Is classified information exempt from inclusion in the risk management plan (RMP) under 40 CFR Part 68?

    Yes. Part 68 does not require disclosure of classified information in violation of federal laws, regulations, or executive orders ( 61 FR 31695 ; June 20, 1996). The regulations clearly state that the RMP will exclude classified information (40 CFR §68.150(d)). Classified data or information excluded from the RMP may…

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  • Double wall tanks and "passive mitigation"

    Performance of the hazard assessment required under 40 CFR Part 68, Subpart B, includes analysis of both worst-case release scenarios (40 CFR §68.25) and alternative release scenarios (40 CFR §68.28). In each of these analyses, passive mitigation systems may be taken into consideration. If a tank has a "double wall,"…

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  • Will we be audited if a member of the public requests an audit of our facility?

    The implementing agency will have to decide whether to respond to such public requests. EPA’s intention is that part 68 implementation reflect that hazards are primarily a local concern.

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  • How must an owner estimate the population when defining off-site impacts?

    How must an owner or operator estimate the population when defining off-site impacts as part of the facility’s risk management plan (RMP)? The owner or operator must estimate the residential population within a circle with its center at the point of the release and a radius determined by the distance…

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  • Submitting Annual Certification for Operating Procedures to EPA

    The owner or operator of a facility who must prepare a Risk Management Plan (RMP) for a Program 3 process is required to develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information (40 CFR…

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  • Updating RMP with Change in Ownership

    Pursuant to the risk management program regulations in 40 CFR §68.10, an owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process must prepare a risk management plan (RMP). If a facility changes owner, but the manufacturing operations have…

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  • Different results using ALOHA and RMP*Comp

    I tried running the same scenarios in ALOHA and in RMP*Comp. I got different answers. Why? The results you obtain using RMP*Comp may not closely match the results you obtain running the same release scenario in a more sophisticated air dispersion model such as ALOHA or DEGADIS. That's because of…

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  • Guidance for on-site compliance evaluations under CAA §112(r)

    CAA §112(r)(6)(L) provides employees and employee representatives with rights to participate in EPA CAA §112(r) compliance evaluations. What formal guidance is available from EPA regarding the involvement of facility employees and employee representatives in EPA and delegated Agency on-site compliance evaluations conducted under CAA §112(r)? The EPA Office of Land…

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  • RMP Executive Summary Elements

    The owner or operator of a stationary source subject to 40 CFR Part 68 must include an Executive Summary in their Risk Management Plan. What elements must be included in the RMP Executive Summary? Pursuant to 40 CFR §68.155, the Executive Summary must briefly describe the following: accidental release prevention…

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  • Distinction between "process" and "covered process"

    What is the distinction between a "process" and a "covered process" under the risk management program regulations at 40 CFR Part 68? Process means any activity involving a regulated substance, including any use, storage, manufacturing, handling, or on-site movement of such substances, or combination of these activities. A "covered process"…

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  • Worst-case release scenarios for toxics and flammables involving the same process

    At my facility, if the worst-case release scenarios for regulated toxic substances and the worst-case scenario for regulated flammable substances involve the same process, must I analyze both? Yes. If the worst-case release scenarios for regulated toxic substances and regulated flammable substances in Program 2 and 3 processes are associated…

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