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  • Inclusion of release scenarios in executive summary

    Do I have to include a description of my worst-case and alternative release scenario in my executive summary? I'm concerned that the description contains sensitive information, which if included in the executive summary will be available to the public without restriction. No, facilities are not required to include a description…

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  • Withdrawal of an erroneous RMP submission

    What should a facility do if it submitted a risk management plan (RMP) but later discovers that it was never subject to the risk management program requirements? If a facility discovers that it submitted an RMP in error and was never subject to the risk management program regulations, it should…

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  • Changes required for adding new reactor vessels for same substance

    What if I change a process by adding new reactor vessels, but do not change the substances? Because increasing the number of reactor vessels is usually a major change to your process, you will have six months to update your RMP to reflect changes in your prevention program elements and…

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  • Who is responsible for preparing and submitting an RMP for leased propane tanks?

    If an owner of a stationary source leases propane tanks from a gas supplier, who is responsible for preparing and submitting the risk management plan (RMP) addressing the propane tanks? The owner of the stationary source is responsible for preparing and submitting the RMP. The risk management program regulations apply…

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  • New owner using existing RMP

    If a Risk Management Plan (RMP) facility is sold to a new owner, does the new owner have to develop a whole new RMP? Or can they use the existing RMP? No, a facility does not complete a new RMP as the facility keeps the original EPA Facility ID number…

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  • If a party registers a facility as a refinery, oxygenate blending facility or import facility and then does not produce or import gasoline at that facility during an averaging period, must the party report to EPA?

    See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Refiners, importers, and oxygenate blenders are required to report to EPA only during averaging periods when the party produces or imports some volume of gasoline, even if the party has previously registered with EPA.(9/26/94) This question and answer…

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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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  • Does a company that produces RFG have to register all oxygenate blending facilities or just those that produce RFG? All import locations or just those that import RFG?

    See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Registration is required only for oxygenate blending facilities at which RFG is produced, and not for oxygenate blending facilities where oxygenate is blended with conventional gasoline only. If an oxygenate blender decides to blend RBOB with oxygenates to…

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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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  • 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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  • Voluntary Implementation and Submission of RMP

    Pursuant to the risk management program regulations in 40 CFR Part 68, owners and operators of a stationary source that have more than a threshold quantity of a regulated substance in a process must implement and submit a risk management plan (RMP) to EPA. If the risk management program regulations…

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  • EPA identification of facilities failing to submit RMPs

    What does EPA do to identify facilities that did not file an initial or updated RMP but were required to do so? EPA examines a number of existing databases to identify potential non-filers. If anyone has any information about any facility that may be subject to the Risk Management Program…

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  • Determining a facility's latitude and longitude

    A facility subject to the risk management program requirements in 40 CFR Part 68 must specify its latitude and longitude coordinates in Section 1.5 of the risk management plan (RMP). What tools are available to accurately determine a facility’s latitude and longitude? The owner or operator of a regulated facility…

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  • If a facility changes owners, but the manufacturing operations have not changed, are they REQUIRED to update their RMP?

    Yes. If the owner of a facility changes, the RMP on record with EPA should reflect the current owner by the date ownership changes or responsibility for operation of the facility is transferred. You do not have to update each section of your RMP if the only thing that has…

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  • When must RMPs be submitted, updated, and corrected?

    When must the risk management plans (RMPs) required under 40 CFR Part 68, Subpart G, be submitted? When are updates and corrections required? Compliance with the risk management program requirements (including submission of an RMP) is required by the date on which a regulated substance first becomes present above a…

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