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Risk Management Program (RMP)
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Obtaining an RMP ID Number
How can a facility subject to the Risk Management Plan (RMP) requirements obtain its RMP ID number? The owner or operator of a regulated RMP facility that has already submitted an RMP, may obtain the facility's identification number (RMP ID Number) by contacting the RMP Reporting Center (703-227-7650). An RMP-covered…
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Does EPA have enforcement authority for the risk management program regulations?
Yes. Under §113 of the CAA, the Agency has the authority to bring administrative and judicial actions against violators. Judicial actions can be civil and criminal in nature. Section 113(a)(3) authorizes the Agency to order violators to comply with the risk management program regulations. Under section 113(b), the Agency may…
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Criteria for selecting stationary sources to audit
What criteria will be used to select stationary sources for periodic compliance audits of risk management plans (RMPs) submitted under 40 CFR Part 68, Subpart G? The implementing agency will, according to the regulations at 40 CFR §68.220(b), select stationary sources for audits based on any of the following criteria…
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Is there a citizen suit provision applicable to RMP?
Is there a citizen suit provision applicable to CAA §112 and the risk management program rule? Yes, section 304 of the CAA includes a citizen suit provision for violations of emission standards or limitations promulgated under the Act.
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Accessing RMP Data
Is Risk Management Plan (RMP) data available to the public and, if so, where can it be found? Risk Management Plans (RMPs) prepared and submitted pursuant to CAA section 112(r) are, by statute, available to the public. Members of the general public may obtain RMP data by visiting a designated…
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How may state and local rules be more stringent?
In what ways may state and local rules be more stringent? Does this document ( General Risk Management Program Guidance ) provide guidance on state and local differences? States and localities may impose more detailed requirements, such as requiring more documentation or more frequent reporting, specifying hours of training or…
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Determining frequency of coordination activities
The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs annually, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)). Are stationary sources responsible for determining if coordination activities should occur more often than annually? Ultimate responsibility…
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How long will it take?
The expectation is for cleaning to take less than one day. The duration will be dependent on the size of the structure and the scope of work.
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Do I need to leave my structure during the cleaning?
While it is strongly recommended that you leave the property during the cleaning, you are not required to do so.
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What about cleaning basements or attics?
Basements or attics will be considered for cleaning if they are finished and habitable areas.
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Who Must Develop an Emergency Response Program?
The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date…
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Statutory authority and regulatory source for the risk management program
What is the statutory authority and the regulatory source for the risk management program regulations that are codified in 40 CFR Part 68? The risk management program regulations were promulgated pursuant to the §112(r) accidental release prevention provisions of the Clean Air Act, as amended in 1990. The regulatory sources…
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RMP Information Center
If I have additional questions regarding the RMP regulations, who can I contact via telephone for further assistance? You may contact the EPCRA, RMP & Oil Information Center, a publicly accessible service that provides up-to-date information on the regulatory requirements of the RMP program, including the applicability, program levels, off-site…
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Will there be photos and videos taken of my property?
Yes, photos and videos of your property will be taken as a requirement of the program. This is done to ensure that the conditions of the property both pre- and post-cleaning are documented thoroughly.
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