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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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How do the changes in the 2006 Amendments apply to mobile refuelers?
Mobile refuelers are now exempt from the following sized secondary containment provisions that still apply to all other bulk storage containers and mobile/portable bulk storage containers: • Sections 112.8(c)(2) and (11) for petroleum oils • Sections 112.12(c)(2) and (11) for animal fats and vegetable oils These provisions previously required sized…
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Will applicants be evaluated on whether or not they leverage funds?
Cost share and leveraging of non-federal funds is not a requirement of this Funding Opportunity, but if leveraging is proposed, applicants will be evaluated based on how they will obtain the leveraged resources, the likelihood the leveraging will materialize during grant performance (e.g., if they have letters of commitment), the…
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Is it possible to distribute the majority of project funding in Year 2 and 3?
Yes. Applicants should commit to being able to issue its first Project RFA within one year of being selected as Principal Recipient (page 9 of the RFA), however this is not a threshold eligibility requirement. There are no specific requirements as to the timing of issuing Project RFAs and funding…
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Will there be a non-federal cost share or match required of grants made by the principal recipient?
No, non-federal cost share is not required. If an applicant proposes voluntary cost share, they should carefully review section III.B on page 21, description of Supporting Materials in section IV.D on page 27, and section V.B.
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How will the budget for year six be treated in case of a continuation of sampling past 2029?
Sampling past 2029 will not be covered under this assistance agreement.
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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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SPCC Rule schedules for inspections, tests, and evaluations
The SPCC rule requires inspections, tests, and evaluations of above ground containers (40 CFR §112.8(c)(6)). Does the rule set schedules for how often these need to be conducted? The SPCC Rule does not prescribe a specific frequency or methodology for performing the required inspections, evaluations, and tests for aboveground containers…
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Can the application also include program admin support for various coalition partners outside of the principal recipient?
Yes. Coalitions are allowable. Applicants should reflect related admin-related costs in the budget narrative. Please see Question 2 under this section for additional information.
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