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  • Redoing calculations if RMP*Comp is updated

    Will RMP*Comp be updated? If so, would I have to redo calculations I might already have made with an earlier version? No, you do not have to redo your work if you have already completed your consequence analyses. RMP*Comp is based on the EPA's Offsite Consequence Analysis Guidance (OCA Guidance)…

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  • Different distances to toxic endpoints with different versions of RMP*Comp

    I've noticed that for certain chemicals, RMP*Comp gives substantially different distances to the toxic endpoint than previous versions. Why? In the current version of RMP*Comp, we have incorporated new chemical-specific distance tables for ammonia, chlorine, and sulfur dioxide. The generic tables are still used for other chemicals (you can see…

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  • Distance to endpoint calculations used by RMP*Comp

    Does RMP*Comp perform some math or modelling in order to arrive at an endpoint distance, or is it simply interpolating from the tables in the EPA's Offsite Consequence Analysis Guidance (OCA Guidance)? RMP*Comp follows the procedures set out in the OCA Guidance . This means that for some scenarios, the…

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  • Secondary containment for oil-filled operation equipment under SPCC

    On December 26, 2006, EPA provided an optional alternative to the general secondary containment requirements in 40 CFR §112.7(c) for qualified oil-filled operational equipment ( 71 FR 77266 ). Because the alternative is optional, an owner or operator could choose to comply with the existing SPCC requirements to provide general…

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  • SPCC requirements for transfer areas associated with exempt USTs

    Gas stations typically are not subject to the SPCC Rule because completely buried storage tanks subject to 40 CFR Part 280 or 281 are exempt per §112.1(d)(4). However, a gas station would be subject to the SPCC Rule if it has more than 1,320 gallons of oil in aggregate above…

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  • Do the changes in the 2006 Amendments apply to oil-filled manufacturing equipment?

    No. The amendment does not change any requirements for oil-filled manufacturing equipment. Oil-filled manufacturing equipment remains subject to the SPCC requirements (including those for containment), but an owner/operator may determine that secondary containment is impracticable and comply with the alternative measures in section 112.7(d).

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  • What is an oil spill contingency plan?

    Instead of providing secondary containment for qualified oil-filled operational equipment, an owner or operator may prepare an oil spill contingency plan and a written commitment of manpower, equipment, and materials to quickly control and remove discharged oil. He/she must also have an inspection or monitoring program for the equipment to…

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  • Secondary containment requirements for mobile refuelers

    What secondary containment requirements apply to mobile refuelers? General secondary containment requirements in §112.7(c) still apply to mobile refuelers at SPCC regulated facilities. General secondary containment should be designed to address the most likely discharge from the container and from oil transfers into or from the mobile refueler. The general…

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  • Is it permissible for a training provider to employ more than one training manager?

    Answer : Yes. The Rule requires that a training provider employ a training manager that meets the qualifications in 40 CFR 745.225(c)(1). EPA does not interpret this to be a limitation on the permissible number of training managers. Therefore, a training provider may employ more than one training manager so…

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  • Eligibility for qualified oil-filled operational equipment in event of a discharge

    Does a facility automatically lose eligibility for the option for qualified oil-filled operational equipment if the equipment has an oil discharge? No. Facilities that choose this alternative and later have a reportable oil discharge from qualified oil-filled operational equipment do not automatically lose eligibility. However, the spill reporting requirements would…

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  • Can qualified facilities also use the alternative requirements for qualified oil-filled operational equipment?

    Yes. Facilities that meet the criteria for qualified facilities and qualified oil-filled operational equipment may benefit from both of the alternative approaches. Since an impracticability determination is not necessary for qualified oil-filled operational equipment, the owner/operator can self-certify the SPCC Plan and is not required to have a PE develop…

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  • If a renovator takes the refresher course early, would the new certification be valid for five years from the date of training, or five years from the date that the previous certification expires?

    Question : I’m a training provider and have been accredited for the renovator refresher course. If a renovator takes the refresher course early (i.e., before their previous certification has expired), would the new certification be valid for five years from the date of training, or five years from the date…

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  • I'm an accredited training provider. Can the final course assessment to be administered in an "open book" format?

    No. The training provider is responsible for maintaining the validity and integrity of the course test to ensure that it accurately evaluates the trainee’s knowledge and retention of the course topics. A course test administered in an open book format does not evaluate whether a student has sufficiently learned and…

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  • RMP*Comp and emergency response

    Can I use RMP*Comp for emergency response? No. It's a planning tool. Many other tools are available for response, including ALOHA . You can learn more by reading CAMEO tools for RMP .

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  • Minimum and Maximum Distance to Endpoint

    The Chemical Accident Prevention Provisions require the completion of a worst-case release scenario analysis (40 CFR §68.25). This analysis includes estimating the greatest distance to endpoint as defined by the parameters in §68.22. Is there a required minimum or maximum distance for the distance to endpoint in the worst case…

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