RMP*eSubmit Users` Manual

RMP*eSubmit Users` Manual
United States
Environmental Protection
Agency
Office of Solid Waste
and
Emergency Response
EPA 555-B-09-001
September 2009
www.epa.gov/emergencies
RISK MANAGEMENT PLAN
RMP*ESUBMIT USERS’ MANUAL
RISK MANAGEMENT PLANS
UNDER THE CLEAN AIR ACT
Risk Management Plans (RMPs) must be fully updated and re-submitted at
least once every five years. Most RMPs were submitted by the initial
deadline of June 21, 1999, and were updated and re-submitted in 2004,
unless they were updated and re-submitted previously. EPA is releasing
RMP*eSubmit to facilitate secure online RMP resubmissions in calendar
year 2009.
WHAT’S NEW FOR 2009?
In 2009, you will submit your RMPs online. You will use the new RMP*eSubmit on
EPA’s secure network, the Central Data Exchange (CDX), which manages thousands of
data submissions from states and industry to a variety of EPA programs.
Reporting requirements are the same as in 2004. While the format of your reporting
will change, the 2004 rule changes will remain in effect.
You will be able to access your RMP online anytime. Owners and operators of
facilities, and individuals they designate as prepares of their RMPs, will be able to
access the facility RMP at any time online.
The new RMP*eSubmit will replace RMP*Submit 2004. Once the new RMP*eSubmit
is available, we will remove the old system from the EPA Web site as we will no longer
be able to fully support the software. For a limited time, we will accept resubmission on
diskettes produced under the old system, but any corrections for incomplete
submissions must be made online.
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WHERE TO GO FOR HELP
RMP Reporting Materials
EPA’s Web site: http://www.epa.gov/emergencies/content/rmp/index.htm includes the
Risk Management Program rule, Off-Site Consequence Analysis specific guidance and
calculator, the list of regulated substances, fact sheets, guidance documents, industryspecific model plans, FAQs, this RMP*eSubmit Users’ Manual, and other information.
RMP Contacts
Under the Clean Air Act, Section 112(r), states can choose to take delegation of the
Chemical Accident Prevention Program. If they do, they become the Implementing
Agency for that state. Contact your EPA Regional staff for assistance. We maintain
their contact information on our Web site:
http://www.epa.gov/emergencies/content/regional.htm
RMP Regulatory Questions
Contact the RCRA, Superfund, and EPCRA Call Center for your policy, regulatory
compliance, and reporting requirements questions.
800-424-9346
800-553-7672
703-412-9810
703-412-3323
Toll Free
TDD
Metropolitan DC area and international calls
Metropolitan DC area and international TDD calls
Monday – Thursday: 10:00 a.m. – 3:00 p.m. Eastern Time Extended Hours of Operation: Monday – Friday: 9:00 a.m. – 5:00 p.m. Closed Federal Holidays RMP*eSubmit Software Support
Contact the RMP Reporting Center for specific software questions about RMP*eSubmit.
703-227-7650
Monday – Friday: 8:00 a.m. – 4:30 p.m. Eastern Time
Closed Federal Holidays
[email protected]
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TABLE OF CONTENTS
Where To Go For Help .................................................................................................. ii
RMP Reporting Materials..............................................................................................ii
RMP Contacts ..............................................................................................................ii
RMP Regulatory Questions ..........................................................................................ii
RMP*eSubmit Software Support ..................................................................................ii
Chapter 1 Getting Started ............................................................................................ 1
Introduction.................................................................................................................. 1
Before You Start .......................................................................................................... 2
CDX and the Registration Process for RMP*eSubmit ................................................. 3
Preparing RMP and Facility ID Option Page.............................................................. 26
Chapter 2 Entering Data (First-Time, Corrections, Resubmissions) ...................... 28
RMP*eSubmit – Section 1. Registration .................................................................... 28
Section 2. Toxics: Worst-Case .................................................................................. 45
Section 3. Toxics: Alternative Release ...................................................................... 50
Section 4. Flammables: Worst Case ......................................................................... 56
Section 5. Flammables: Alternative Release ............................................................. 59
Section 6: Five-Year Accident History ....................................................................... 63
Section 7: Prevention Program: Program Level 3...................................................... 73
Section 8: Prevention Program: Program Level 2...................................................... 86
Section 9: Emergency Response .............................................................................. 95
Executive Summary................................................................................................... 99
Chapter 3 How to Submit Your RMP ....................................................................... 101
Certifying a Submission in RMP*eSubmit................................................................ 101
Certification Statement ............................................................................................ 104
Chapter 4 Submitting CBI and Trade Secrets Submitting Papers RMPs ............. 110
CBI and Trade Secrets ............................................................................................ 110
Submitting Paper RMPs .......................................................................................... 110
Chapter 5 Notifying EPA that Your Facility is no Longer Covered by RMP: De-
registration............................................................................................... 111
How to De-register Your Facility .............................................................................. 111
Chapter 6 Reporting Center Contact Information Acronyms of Terms................ 112
Current Mailing Address for RMP Reporting Center ................................................ 112
Acronyms of Terms ................................................................................................. 113
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APPENDICES
A
Risk Management Plan Form
B
Sample Certification Letters
C
CBI Substantiation Form
D
CBI Unsanitized Data Element Form
E
Risk Management Program De-registration Form
Available at: http://www.epa.gov/emergencies/docs/chem/rmp_esubmit_appendices.pdf
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CHAPTER 1 GETTING STARTED
Introduction
The RMP*eSubmit Users’ Manual provides assistance in preparing and submitting Risk
Management Plans (RMPs). RMP*eSubmit application software is the Web-based free
tool EPA developed to facilitate electronic submission and is designed to significantly
reduce errors in submission through validations for data elements. If you are unable to
submit your RMP electronically, contact the RMP Reporting Center: 703-227-7650.
RMP*eSubmit allows you to:
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View the current version of your RMP (if you have already reported an RMP); Create a new RMP online (if this is a first-time submission); Make corrections to, or create a complete resubmission of your RMP; Identify and correct any errors in your RMP prior to submission; Print a copy of your RMP; Access help screens to assist you in completing your RMP; Submit your RMP online; and View a copy of the record of your RMP. You must be registered as a Preparer and/or Certifier in the Central Data Exchange
(CDX), RMP Program in order to use RMP*eSubmit.
Definitions: Central Data Exchange (CDX) is a secure, online location on EPA’s network. CDX provides standardized and secure information collection services and infrastructure for EPA program partners. For example, CDX manages several Agency regulatory and monitoring programs, receiving submissions from facilities. Certifiers are facility owners or operators who must certify the accuracy and completeness of the information reported in the RMP. They have signed and
submitted a one-time Electronic Signature Agreement (ESA) to the EPA. The ESA legally binds the Certifier’s electronic submission to their signature. Only Certifiers can submit the RMP. Preparers have been granted permission by a facility to access the facility’s existing RMP. They prepare data for a new or updated RMP. CDX notifies the Certifier when the new or corrected RMP is ready for the Certifier’s review and submission. Preparers cannot submit the RMP. Office of Emergency Management
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Before You Start
Are you subject to the RMP reporting requirements? Check the requirements on
EPA’s Web site: http://www.epa.gov/emergencies/content/rmp/index.htm, or call the
appropriate contact on “Where to Go for Help” page at the beginning of this manual.
For updates and resubmissions, check your 5-year anniversary date if you already have
an RMP in the system.
What is your EPA Facility ID? If you already have an RMP in the system, you have
an EPA Facility ID. It is essential that we match your new RMP to any earlier versions.
Your EPA Facility ID appears in a letter sent by the EPA Reporting Center after your
first-time submission. The number has twelve digits. Call the EPA Reporting Center if
you need help: 703-227-7650.
What category are your processes in: Program Level 1, 2 or 3? Each process at
your facility having more than a specified amount (threshold quantity) of a covered
chemical (regulated substance) will be in one of these categories. The category
determines some of your reporting requirements and governs how you enter the data.
Is your RMP a First-time Submission, a Resubmission, or a Correction?
Definitions:
A First-time Submission means that an RMP has never before been submitted
for your facility (by you or any previous owner/operator). This requires that you
enter information for all nine sections of the RMP. Elements for all nine sections
are discussed in Chapter 2.
A Resubmission is an update of all nine sections of your RMP. If you are the
owner or operator of an RMP-covered facility, EPA’s Chemical Accident
Prevention regulations at 40 CFR part 68 require that you fully update and
resubmit your RMP at least once every 5 years. Resubmitting your RMP will re­
set your five-year anniversary date. If you have previously submitted an RMP,
your facility information will be pre-populated in RMP*eSubmit.
A Correction should be used to report administrative or other changes at your
facility (e.g., changes in emergency contact information, facility address, or
change in accident history). This does not require an update of your entire RMP.
Submitting a corrected RMP does not change your five-year anniversary date. If
your facility has not resubmitted an RMP by its anniversary date, you will not be
able to make an RMP Correction and will be required to resubmit your RMP.
NOTE: For more information on resubmission and corrections, please see page
44 of this Users’ Manual, section Reason for Resubmission:.
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CDX and the Registration Process for RMP*eSubmit
The new RMP*eSubmit application allows you to securely submit your RMP over the
Internet through the EPA Central Data Exchange (CDX).
The requirements to submit using RMP*eSubmit are:
1. You must have Internet access;
2. JavaScript must be enabled on your computer;
3. The Certifying Official (Certifier) and Preparer must have Central Data
Exchange (CDX) accounts (see the “Registration” section to learn how to
obtain those accounts);
4. The Certifier must complete an Electronic Signature Agreement (ESA) to
obtain the Authorization Code (AuthCode) for preparing a submission. The
Authorization Code is necessary to prepare and submit an RMP;
5. Preparers must activate their RMP*eSubmit access in CDX using the unique
facility Authorization Code provided to them by the Certifying Official for their
facility.
Getting Started with RMP*eSubmit
To use RMP*eSubmit, the Certifying Official for your facility (typically the facility owner
or operator or a designated senior management official employed by the facility) must
first be registered in CDX. Additionally, the Certifying Official must complete and sign
an Electronic Signature Agreement (ESA) which will be used to verify the identity of the
Certifying Official in the system. The ESA must be mailed to the RMP Reporting Center
and approved prior to being able to prepare or certify an RMP using RMP*eSubmit.
Registration for RMP*eSubmit
The registration process for the online RMP*eSubmit application is different if you
already have a CDX user account (such as for previously registering to use
RMP*WebRC or any other CDX application), and is based on whether your role is a
Certifying Official or a Preparer.
The following information will take you step-by-step through the CDX registration
process and will help you get started as a Certifier or Preparer.
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Registering for CDX User Account
A CDX account is needed to use the RMP*eSubmit application. To register for an
account, log into CDX at http://cdx.epa.gov, read the Warning and Privacy notices and
select “Click here to continue” to go to the CDX home page.
1. Begin by selecting the link “If you are new to CDX and wish to register, please
click here.” Then follow Step 3.
2. If you already have a CDX user account, begin by selecting “If you already
have a CDX ID and password, click here.” Then go to page 15 to log in to CDX
using your User Name/Password and then follow direction from page 9 (on
Step 7) to add the RMP*eSubmit Program and Certifying Official Role.
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3.
On the Registration Warning Notice page, select the “Click here to continue”
link.
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4.
On the Terms & Conditions page, read, then select the “I ACCEPT” button.
The link will take you to the Registration page.
Terms and Conditions (Screen 1)
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Terms and Conditions (Screen 2)
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5.
Complete your one-time registration on the CDX Registration screens. Provide
your User Name, Password and other information, then click “Next.”
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6.
Complete the registration information for the organization, then click “Next.”
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7.
On the CDX Registration: Add Program page, select the radio button for “Risk
Management Plan (RMPESUBMIT)” and click “Next.”
NOTE: Make sure you have selected the Risk Management Plan button before
clicking “Next.”
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8. On the “Add Role” page, select your role as “A SUBMITTER,” then select
Program ID Type as either “Certifying Official” or “Preparer.”
• If you are a “Certifying Official,” enter “N/A” in the ID field. Click
“FINISHED” and continue to Step 9.
• If you are registering as a “Preparer,” skip to page 21.
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9.
As the Certifying Official, enter your official business title or role (e.g., Owner,
Operator, Senior Management Official, etc…), and click “Save.”
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10. You will now see the congratulations screen confirming your CDX registration.
Click “Finished” on this page to go to the Security Questions page.
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11. You will now see a screen with a list of security questions. Select and answer
five questions from the list. When you certify an RMP, the program will
randomly ask one of the five selected questions as an additional verification of
your identity.
Click on “Save Answers” after you have selected your five questions. This will
activate the receipt page for the eSIG-PIN questions that you just answered.
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12.
Click “Continue” to go to your MyCDX to see the added Account Profile.
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Logging into CDX
Log into CDX with your existing CDX User ID and password and proceed to your
MyCDX page, where you will see your Account Profiles (see below screen shot).
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CDX Registration
You will now see your MyCDX page with available account profiles. Click the
“RMPESUBMIT: Certify Submission” link to add RMP facilities.
NOTE: Only the Certifier has the option to add facility(s).
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Click “Add New RMP Facilities” to create your Electronic Signature Agreement
(ESA) for each facility you will be certifying.
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You will now add the facilities you want to be associated with your profile. To
add more than one facility, you can click the “Add Another Facility” button, then
click “Save.”
It is important to enter the correct Facility ID of the specific facility for which you
will be submitting and RMP. For any new facility/first-time submittals, the Facility
ID field can be left blank, but you need to furnish the complete facility information
(name and complete location address). Once you click the “Save” button, the
ESA (with relevant facility information) will appear. See the screenshot of the
ESA on the next page.
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Upon completion, CDX will prompt you to print the ESA.
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Once you have printed and closed the ESA, a Successfully Registered
confirmation page will be displayed. This completes your registration as a
certifier.
Next, follow the provided instructions on how to sign (Wet Ink Signature) and mail
the ESA to the RMP Reporting Center. The RMP Reporting Center will verify the
ESA for completeness, approve and generate the Authorization Code
(AuthCodes) required to prepare the RMP for each facility. Since the ESA must
be mailed and received, please allow 2 to 4 weeks for ESA approval.
An e-mail containing AuthCodes for each requested and approved facility
will be sent to the Certifying Official at the e-mail address provided during
CDX registration. Once the e-mail is received, the AuthCode(s) may be
used to prepare RMP(s). The Certifier is responsible for providing the
AuthCode to the Preparer so that he or she can register in CDX and prepare
the RMP.
NOTE: For first-time submissions, the e-mail to the Certifier will include a new
Facility ID) in addition to the Auth Code. Once the Preparer enters the AuthCode
he will be directed to the RMP*eSubmit welcome screen with the new ID and
location address.
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To complete registration after selecting the Program ID role of “Preparer” (Step
8), you must follow the on-screen instructions. You will enter the AuthCode in
the “ID” field. The AuthCode will be provided by your Certifying Official.
NOTE: If you have already added the Certifier role and also want to be a
Preparer, you can access this screen by returning to MyCDX (click the link on the
sidebar). On the MyCDX page, choose “Edit Current Account Profiles.” Next,
click “List Roles” and “Add New Program ID.” Then select “Preparer” as the
Program ID Type and enter the AuthCode for the facility in the “ID” field. Click
the “Add” button.
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You will receive a confirmation page stating that you have completed the
registration as a Preparer.
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Click “Finished.” Go to your MyCDX inbox which will have the added role (e.g.,
prepare submission). See the screenshot on the next page.
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Your MyCDX page will now display the roles that you have added to your profile
(i.e., For Certifier – Certify Submission, and for Preparer – Prepare Submission).
Note: A Preparer’s MyCDX page will only have the RMPESUBMIT: Prepare
Submission link.
Click on the “Prepare Submission” link and you will be able to select the facility
ID that you need to update the RMP. (If you are assigned multiple RMPs, a
drop-down list of the Facility IDs assigned to you will be shown. Choose the
correct Facility ID and proceed.) See the screenshot on the next page.
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Preparing RMP and Facility ID Option Page
Once you select a facility ID from the drop-down list, click “Proceed” and you will
be directed to the RMP*eSubmit welcome page to prepare the RMP (Correction
or Resubmission) using the RMP*eSubmit application and submit it to your
Certifying Official for certification. See the screenshot on the next page for the
RMP*eSubmit welcome screen and an example of a selected facility.
NOTE: If you only have 1 facility under “Preparers File” you will directly be
accessing the RMP Welcome screen page instead of the page list below.
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For a first-time submission, the Welcome page will resemble the screenshot
below.
For a Correction of Resubmission, the screen will resemble the screenshot
below.
Select the appropriate button (Correction or Resubmission) and you will have
access to the RMP*eSubmit program to update your RMP.
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CHAPTER 2 ENTERING DATA (FIRST-TIME, CORRECTIONS,
RESUBMISSIONS)
RMP*eSubmit – Section 1. Registration
All covered facilities must complete the registration portion of the RMP, even if they
have only a Program 1 process. The registration consists of facility identification
information. You cannot enter data for Sections 2 through 5, 7, and 8 until you have
entered process-specific information.
The following is a discussion of each element in Section 1. Registration.
1.1
Source identification
1.1a. Facility name:
Provide the name of your facility. The name must be specific to the site; if the site is
part of a large corporation, the name may be the corporate name plus the location (for
example, “ABC Chemicals - Hightown Plant”). Throughout the Risk Management
Program, the term “facility” means “any buildings, structures, equipment, installations or
substance emitting stationary activities (i) which belong to the same industrial group, (ii)
which are located on one or more contiguous properties, (iii) which are under the control
of the same person (or persons under common control), and (iv) from which an
accidental release may occur.”
1.1 b. Parent company #1 name:
Your parent company is the corporation or other business entity that owns at least 50
percent of the voting stock of your company. If you are owned by a joint venture, enter
the first of your two major owners here. If your company does not have a parent
company, leave this data element blank.
1.1c. Parent company #2 name:
If you are owned by a joint venture, enter the name of the second major owner here.
1.2
EPA facility identifier (display only):
The facility ID number for your facility is displayed: it is not editable. If you need a new
facility ID number, contact the RMP Reporting Center at 703-227-7650.
1.3
Other EPA systems facility identifier (only 15-characters allowed):
In EPA’s efforts to streamline facility reporting, incoming facility information needs to be
linked with existing facility information across different environmental programs. To help
ensure your facility's RMP data is properly linked and that your facility does not receive
multiple EPA facility IDs, please enter one of the following facility identification numbers
in the following priority order:
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1. First, if you have a TRI (Toxic Release Inventory) ID number (15 characters),
enter it here. If you know you have a TRI ID, but do not know the number, you
can find it by searching the TRI database on the Internet at:
http://www.epa.gov/enviro/html/tris/adhoc.html or by calling the EPA’s
Superfund, TRI, EPCRA, RMP & Oil Call Center at: 1-800-424-9346.
2. Second, if you do not have a TRI ID, but report to EPA under another program
and have a number referred to as a "FINDS" or Unique Identification Number
(UIN), (these will be 12 characters), enter it here. If you know you have a
FINDS or UIN number, but do not know what it is, you can find it by searching
EPA's Facility Identification Initiative (FII) database on the Internet at:
http://www.epa.gov/enviro/html/fii/fii_query_java.html
3. Third, use any one of the following numbers:
• If your facility is covered by hazardous waste regulations under the
Resource Conservation and Recovery Act (RCRA), enter your RCRIS
Handler ID (12 characters). You can find your RCRIS ID on the Internet at:
http://www.epa.gov/enviro/html/rcris/rcris_query_java.html (clicking this link
opens a new browser window)
• If your facility is covered by regulations under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA),
enter your CERCLIS Site ID (7 characters). You can find your CERCLIS ID
on the Internet at: http://www.epa.gov/enviro/html/cerclis/cerclis_query.html
• If your facility does not have an ID number as described above, leave this
data element blank.
1.4
Dun and Bradstreet Numbers (DUNS):
1.4a. Facility DUNS:
The Data Universal Numbering System (DUNS) is a nine-digit identification number that
allows your facility to be cross-referenced to various business information. If you have a
DUNS number, it should be available from your treasurer or financial officer. You can
also obtain the number from your local Dun and Bradstreet office (check the telephone
book White Pages). If you do not have a DUNS number, leave this field blank.
1.4b. Parent company #1 DUNS:
Provide DUNS number of your parent company (ies), if applicable. If you are owned by
a joint venture, provide the numbers for your two major owners. If you do not have a
parent company or your parent company does not have a DUNS number, leave this
field blank.
1.4c. Parent company #2 DUNS:
Provide DUNS number of your second parent company if you are owned by a joint
venture. Otherwise, leave this field blank.
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1.5
Facility location address:
Provide your facility location address, including the street, city, state, and ZIP code
(including the 4 digit extension, if applicable) of your facility. This is the location where
regulated substances are present. The city should be the local legal jurisdiction, for
example, a township or village. Use local street and road designations, not post office
or rural box numbers. This location may not represent the mailing address. EPA
will not attempt to mail correspondence to this address. All correspondence will
be mailed to the address provided at 1.6 c-g. If your location and mailing address
are the same, then you will fill in the same address at 1.6 c-g.
1.5a. Street 1:
Provide your facility location address.
1.5b. Street 2:
Provide any additional facility location address information.
1.5c. City:
Provide the city name from your facility location address.
1.5d. State:
Provide your facility location address. This is not editable for an RMP Correction or
Resubmission.
1.5e. ZIP code:
Provide the ZIP code from your facility location address, including the 4-digit extension
(if applicable).
1.5f. County:
The drop down list will populate with a list of counties based upon the selected state.
You must select your facility state from the drop down list before selecting the facility
county in this element. Select a county from the drop down list that appears when you
click the button (labeled with a down arrow). If you edit this element with a county
different from the county entered previously, you will have to select or enter a new
LEPC in field “1.10 LEPC.”
Facility latitude and longitude (decimal degrees):
1.5g. Latitude (dd.dddddd):
Provide the latitudinal coordinates of your facility. Facility latitude must be a value
between -90 and 90. Decimal degrees use the format: +/- dd.dddddd where:
"-" = west of the prime meridian (longitude) or south of the equator (latitude)
"+" = east of the prime meridian (longitude) or north of the equator (latitude)
NOTE: If you edit your facility’s latitude, it must fall within the specific lat/long
boundary for your facility’s address, or it will be rejected by RMP*eSubmit.
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1.5h. Longitude (dd.dddddd):
Provide your facility longitude in decimal degrees. You must provide the longitudinal
coordinates of your facility. Facility longitude must be a value between - 180 and 180.
Decimal degrees use the format: +/- ddd.dddddd where:
"-" = west of the prime meridian (longitude) or south of the equator (latitude)
"+" = east of the prime meridian (longitude) or north of the equator (latitude)
NOTE: If you edit your facility’s longitude, it must fall within the specific lat/long
boundary for your facility’s address, or it will be rejected by RMP*eSubmit.
1.5i. Lat/Long method:
You also must indicate the method that you used to determine your latitude and
longitude data. Select the method for which you obtained your lat/long coordinates from
the drop down list.
1.5j. Lat/Long description:
The table below lists the codes to be used for this element and provides a brief
description of each method. The most common methods for determining latitude and
longitude are I1 (Interpolation-Map), and I4 (Interpolation-Digital Map Source). Use I1 if
you obtained your latitude and longitude from a paper map. Use I4 if you obtained your
latitude and longitude from a computer-based geographic information system (GIS),
such as LandView®. Select the appropriate lat/long description from the drop down list.
Code
Abbreviation
Description
AB
A building, structure, or portion thereof that houses the
Administrative Building administrative functions of a facility as opposed to
production or manufacturing activities
AE
Atmospheric
Emissions Treatment
Unit
Equipment installed for the express purpose of treating
chemical emissions prior to their release into the
atmosphere
AM
Air Monitoring Station
Equipment installed at a predetermined location for the
automatic, manual, or periodic collection of environmental
air samples
AS
Air Release Stack
A free-standing vertical structure constructed for the
conveyance and release of chemical emissions into the air
AV
Air Release Vent
A horizontal structure constructed for the release of
chemical emissions into the air, typically from the side or
roof of a building
CE
Center of Facility
A representative center point within the boundary of a
facility
FC
Facility Centroid
The calculated center of a contiguous facility
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Code
Abbreviation
Description
IP
Intake Pipe
A pipe or intake opening constructed for the collection and
conveyance of water
LC
Loading Area Centroid
The calculated center of a portion of a facility associated
with loading activities
LF
Loading Facility
The portion of a facility associated with loading and/or
transshipment activities
LW
Liquid Waste
Treatment Unit
Equipment installed for the express purpose of treating
chemical emissions prior to their release to water, publicly
owned treatment works (POTW) or off-site transfer
NE
NE Corner of Land
Parcel
The northeast most corner or boundary of a land parcel
NW
NW Corner of Land
Parcel
The northwest most corner or boundary of a land parcel
OT
Other
See descriptive comment field
PC
Process Unit Area
Centroid
The calculated center of a portion of a facility associated
with processing and/or manufacturing activities
PF
Plant Entrance
(Freight)
The entrance to a facility associated with transshipment
activities
PG
Plant Entrance
(General)
The front gate or general entrance of a facility
PP
Plant Entrance
(Personnel)
The entrance to a facility associated with employees
PU
Process Unit
The portion of a facility associated with processing and/or
manufacturing activities
SD
Solid Waste
Treatment/Disposal
Unit
The portion of a facility associated with the treatment
and/or disposal of solid waste
SE
SE Corner of Land
Parcel
The southeast most corner or boundary of a land parcel
SP
Lagoon or Settling
Pond
The portion of a facility designed to accommodate
sedimentation or settling of chemical by-products
necessitated by the manufacture, production, or use of
chemicals
SS
Solid Waste Storage
Area
The portion of a facility associated with the storage of solid
waste
ST
Storage Tank
A receptacle or chamber used for storing bulk fuels or
chemicals
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Code
Abbreviation
Description
SW
SW Corner of Land
Parcel
UN
Unknown
WA
Wellhead Protection
Area
An area at the earth's surface buffering a wellhead
WL
Well
A shaft drilled in the earth for purposes such as obtaining
subsurface drinking water, or collecting groundwater
monitoring samples
WM
Water Monitoring
Station
A location or study area for the automatic, manual, or
periodic collection of water samples
WR
The point at which a pipe constructed for the conveyance
Pipe Release to Water and release of water-borne chemical emissions reaches a
water body
The southwest most corner or boundary of a land parcel
1.5k. Horizontal accuracy measure (in meters):
Provide the horizontal accuracy measure (in meters). If you have difficulty obtaining this
information, please contact the EPA’s Superfund TRI, EPCRA, RMP & Oil Call Center
at: 1-800-424-9346 for additional guidance.
1.5l. Horizontal reference datum code:
You must select the code from the available drop down list that represents the reference
datum used in determining the lat/long coordinates you entered in 1.5 g and 1.5 h,
respectively. If you have difficulty obtaining this information, please contact the EPA’s
Superfund TRI, EPCRA, RMP & Oil Call Center at: 1-800-424-9346 for additional
guidance.
The range of permissible values includes:
Horizontal Datum Code
Horizontal Datum Description
001
North American Datum of 1927
002
North American Datum of 1983
003
World Geodetic System of 1984
North American Datum Code of 1927
The North American Datum (NAD) of 1927 uses the Clarke 1866 spheroid to
represent the shape of the earth. The origin of this datum is a point on the earth
referred to as Meades Ranch in Kansas. Many NAD 1927 control points were
calculated from observations taken in the 1800s. These calculations were done
manually and in sections over many years. Therefore, errors varied from station
to station.
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North American Datum Code of 1983
The North American Datum of 1983 is based upon both earth and satellite
observations, using the GRS80 spheroid. The origin for this datum is the earth’s
center of mass. This affects the surface location of all longitude–latitude values
enough to cause locations of previous control points in North America to shift,
sometimes as much as 500 feet. A 10-year multinational effort tied together a
network of control points for the United States, Canada, Mexico, Greenland,
Central America, and the Caribbean.
Because NAD 1983 is an earth-centered coordinate system, it is compatible with
global positioning system (GPS) data. The raw GPS data is actually reported in
the World Geodetic System 1984 (WGS 1984) coordinate system.
World Geodetic System of 1984 (WGS84)
The World Geodetic System of 1984 is the reference frame used by the U.S.
Department of Defense and is defined by the National Imagery and Mapping
Agency (formerly the Defense Mapping Agency). WGS 84 is used by
Department of Defense for all its mapping, charting, surveying, and navigation
needs, including its GPS "broadcast" and "precise" orbits. The latest revision of
WGS 84 was in 2004, which will be valid up to about 2010.
1.5m. Source map scale number:
This is the proportional distance on the ground for one unit of measure on a map or
photo. This information must be supplied if you have chosen a lat/long method of type
Interpolation - Map (I1) or Interpolation - Photo (I2). If you have difficulty obtaining
this information, please contact the EPA’s Superfund TRI, EPCRA, RMP & Oil Call
Center at: 800-424-9346 for additional guidance.
1.6
Owner or operator:
1.6a. Name:
Provide the name of the legal owner or operator of the facility (person, company,
association, or government agency). This is not editable for an RMP Correction.
1.6b. Phone:
Provide the owner or operator’s business phone number, including area code.
1.6c. Street 1:
Provide the owner or operator’s business mailing address street – line 1. In this
instance, you should use post office and rural box numbers, if appropriate. This is the
address to which all correspondence will be mailed.
1.6d. Street 2:
Provide the owner or operator’s business mailing address street – line 2. In this
instance, you should use post office and rural box numbers, if appropriate. This is the
address to which all correspondence will be mailed.
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1.6e. City:
Provide the owner or operator’s business mailing address city. The city should be the
local legal community, for example, a township or village. This is the address to
which all correspondence will be mailed.
1.6f. S
tate:
Use the drop down list to select the state of the owner or operator’s business mailing
address. This is the address to which all correspondence will be mailed. You may
also select a state from the list that appears when you click the down arrow.
1.6g. ZIP code:
Provide the owner or operator’s business mailing address, including street, P.O. or rural
box, city, state, and ZIP code (including 4-digit extension, if applicable). This is the
address to which all correspondence will be mailed. If the address is in a foreign
country, select the country, then provide the state and ZIP code.
Foreign country address (if applicable):
Country:
Provide the owner or operator’s foreign business mailing address country.
State/Province:
Provide the owner or operator’s foreign business mailing state or province.
ZIP/Postal code:
Provide the owner or operator’s foreign business mailing address ZIP/postal code.
1.7 Name and title of person responsible for RMP 40 CFR Part 68
implementation:
1.7a. Name of person:
Provide the name of the person with overall responsibility for the Risk Management
Program at your site. Although the individual’s name is not required, the title of the
person or the position that has this responsibility is required.
1.7b. Title of person or position:
Provide the title of the person or position with overall responsibility for the risk
management program at your site. Although the individual’s name is not required, the
title of the person or the position that has this responsibility is required.
1.7c. E-mail address (optional):
Provide the e-mail address of the person or position with overall responsibility for the
risk management program at your site. The individual’s e-mail address is not required.
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1.8
Emergency contact:
1.8a. Name:
Provide the name of the person designated as the emergency contact. If you have a
regulated toxic substance, you may already have designated a facility emergency
coordinator in your notification to your Local Emergency Planning Committee (LEPC)
under EPCRA Section 312. If you have more than one contact person, provide just one
name for this entry. You may want to list the other emergency contacts in your
Executive Summary.
Your emergency contact name should be:
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An employee or contract employee of your facility;
Knowledgeable about your site;
Aware of all emergency plans and procedures; and
Able to provide emergency response support or direct response personnel to
provide support.
1.8b. Title:
Provide the title or job classification of the person designated as the emergency contact.
If you have a regulated toxic substance, you may already have designated a facility
emergency coordinator in your notification to your LEPC under EPCRA Section 312.
Your emergency contact should be:
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An employee or contract employee of your facility;
Knowledgeable about your site;
Aware of all emergency plans and procedures; and
Able to provide emergency response support or direct response personnel to
provide support.
1.8c. Phone:
Provide the phone number, including area code, where the emergency contact can be
reached during normal business hours. You will most likely provide the facility
telephone number here. If your facility does not have a phone number, you may
provide the business phone number of the emergency contact, the phone number of a
dispatcher, or the customer service phone number.
1.8d. 24-hour phone:
Provide a 24-hour phone number for your facility.
1.8e. Ext. or PIN:
Provide an extension or PIN #, in this space, if applicable.
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1.8f. E-mail address (optional):
Provide the e-mail address, where the emergency contact can be reached during
normal business hours. If your facility does not have an e-mail address, leave the field
blank.
1.9
Other points of contact (optional):
1.9a. Facility or parent company e-mail address (optional):
You may provide an e-mail address to which inquiries from the public could be sent.
The e-mail address could be for the person who developed your RMP or your public
liaison office.
1.9b. Facility public contact phone (optional):
You may provide a phone number for public inquiries. It could be the phone number of
the person who developed your RMP or of your public liaison office.
1.9c. Facility or parent company WWW homepage address (optional):
You may provide the Internet address where you have more details on your accident
prevention program, offsite consequence analysis, or other facility or corporate
information.
1.10 LEPC:
Select the name of your LEPC for your planning district from the drop down list. LEPCs
were created to do local planning under the Emergency Planning and Community Right
to Know Act (EPCRA) of 1986. In RMP*eSubmit, you will select your LEPC's name
from a drop down list based on the facility county information that you have entered. If
you are unsure or do not know the LEPC associated with your county, select
Other/Unknown.
Specify if Other selected:
If the LEPC that represents your county does not appear on the drop down list in field
and you know the name of your LEPC, select Other/Unknown and type the LEPC name.
NOTE: If you do not know your LEPC's name, you can call your local fire
department or refer to the LEPC database on the Internet:
http://yosemite.epa.gov/oswer/lepcdb.nsf/HomePage?openForm
1.11 Number of full-time equivalent employees on site:
Provide the number of full-time equivalent employees who work at your facility. To
determine the number of full-time equivalent employees at your facility, add together the
fractions of full-time work performed by part-time or seasonal employees and round to
the nearest whole number. Do not include contract employees. If your facility is
unmanned or is only staffed by part-time employees, you should briefly explain these
circumstances in the Executive Summary.
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1.12 Covered by:
1.12a. OSHA’s PSM:
This element refers to OSHA’s Process Safety Management (PSM) of Highly
Hazardous Chemicals Standard (29 CFR 1910.110). This data element applies to your
facility as a whole and is not a process-by-process determination. Therefore, if any
process at your facility is subject to the OSHA PSM standard, check this box, even if the
PSM process is not covered by the RMP rule.
NOTE: For further information about OSHA’s PSM standard, visit:
http://www.osha.gov/SLTC/processsafetymanagement/
1.12b. EPCRA Section 302:
If you have on site more than a threshold quantity of a substance that is an Extremely
Hazardous Substance (EHS), you are subject to EPCRA Section 302 notification
requirements (a one-time notification to the State Emergency Response Commission
(SERC) and LEPC that you have one of the listed EHS on site). If you are subject to
those requirements, check this box, regardless of whether the EHS is covered by the
RMP rule or is held in a process below the Section 112(r) threshold quantity. Two quick
hints:
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If you are subject to the RMP rule because you have more than a threshold
quantity of a toxic substance listed under Section 112(r), you are subject to
EPCRA Section 302 and must select this data element.
If you are subject to the RMP rule only as a result of flammable substances, you
are not subject to EPCRA Section 302, and you can leave this data element
blank.
1.12c. CAA Title V:
If your facility has a Title V operating permit, check this box.
Air operating permit ID:
If your facility has an air operating permit ID, provide the ID number.
1.13 OSHA star or merit ranking (optional):
Check this box if your facility has received a star or merit ranking under OSHA’s
Voluntary Protection Program and thus is exempt from audits conducted pursuant to
Section 68.220(b)(2) and (7).
1.14 Last safety inspection (by an external agency) date:
Provide the date of your last safety inspection by an external agency.
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1.15 Last safety inspection performed by an external agency:
Select the agency (or agencies) that performed the inspection from the drop down list.
Choose from the following:
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EPA
Fire department
Never had one
OSHA
State environmental agency
State occupational safety organization
Specify if Other selected:
Provide the external agency if not present in element 1.15. If your last safety
inspection was a joint inspection, enter multiple agencies. If the agency does not
appear in the drop down list in element 1.15, select the Other option and provide
the name of the agency.
1.16 Will this RMP involve Predictive Filing?
Predictive Filing is an RMP filing option that allows your facility to submit an RMP which
includes regulated substances which may not actually be present at the facility at the
time the RMP is submitted. This option is intended to assist facilities such as chemical
warehouses, chemical distributors, batch processors and the like whose operations
involve highly variable types and quantities of regulated substances but who are able to
forecast their inventory with some degree of accuracy. Under 40 CFR Section 68.190,
a facility is required to update and resubmit its RMP no later than the date on which a
new regulated substance is first present in a covered process above a threshold
quantity. By using Predictive Filing, you will not be required to update and resubmit
your RMP when you receive a new regulated substance if that substance was included
in your latest RMP submission (as long as you receive it in a quantity that does not
trigger a revised offsite consequence analysis as provided in 40 CFR Section 68.36).
If you use Predictive Filing, you should implement your Risk Management Program and
prepare your RMP in exactly the same way as if all of the substances included in the
RMP were actually present. This means that you must meet all rule requirements for
each regulated substance for which you file, whether or not that substance is actually
present onsite at the time you submit your RMP. Depending on the substances for
which you file, this may require you to perform additional worst-case and alternativecase scenarios and to implement additional prevention program elements.
NOTE : If your facility uses this option you must still update and resubmit your
RMP if you receive a new regulated substance which was not included in your
latest RMP. Your facility must also continue to comply with the other update
requirements stated in 40 CFR 68.190.
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If your facility uses Predictive Filing, the RMP database for your facility will indicate that
your facility has filed a predictive RMP. This will indicate that some of the chemicals in
your RMP may not actually be present onsite, but will not indicate which specific
chemicals are onsite at any given time. Therefore, you may receive more frequent
questions from the public, local officials, or implementing agencies about your actual
chemical inventory. EPA encourages you to engage in more frequent dialogue with
these parties, and in particular with local emergency planners, emergency responders,
and community officials to update them on your current inventory of regulated
substances. Check this box if your RMP involves Predictive Filing. This is not
editable for an RMP Correction.
Section 1. Registration: Processes
The following information includes a description of all elements in Section 1.
Registration: Processes.
WARNING! If you delete a chemical or an entire process record in Section 1.
Processes, all chemical records linked to the deleted chemical or deleted process in
sections 2, 3, 4, 5, 7 and 8 will also be deleted.
Process ID: The process ID is a system generated number which has no bearing on
your submission.
Process description (optional):
This description helps you to track multiple processes as you fill out the remaining
sections of your RMP. Provide your process description in this element.
1.17a. Program level:
Enter or edit the program level that corresponds to each process (program level options
cannot be selected or edited in an RMP Correction). The rule imposes different
requirements on processes based on the potential for public impacts and the level of
effort needed to prevent accidents. EPA has set three levels of requirements that apply
to covered processes:
Program level 1
Process has experienced no
accident in past 5 years that
resulted in significant off-site
impacts,
No public receptors in worst­
case circle, and
Program level 2
Process is not eligible for
Program 1 or subject to
Program 3.
Program level 3 (unless
eligible for Program 1)
Process is subject to OSHA
PSM, or
Process is in NAICS code
32211, 32411, 32511, 325181,
325188, 325192, 325199,
325211, 325311, or 32532.
Emergency response
coordinated with local
responders.
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WARNING! Changing the Program Level will delete other sections in the RMP that
depend on its value. For example, changing the Program Level from 2 to either 1 or 3
will delete the Section 8 Program corresponding to the Program Level 2 Process, if one
exists. Changing the Program Level from 3 to either 1 or 2 will delete the Section 7
Program corresponding to the Program Level 3 Process, if one exists.
If you can qualify a process for Program 1, it is in your best interests to do so, even if
the process is already subject to OSHA PSM. For Program 1 processes, the
implementing agency will inspect and enforce only on compliance with the minimal
Program 1 requirements. If you assign a process to Program 2 or 3 when it might
qualify for Program 1, the implementing agency will inspect or enforce for compliance
with all the requirements of the higher program levels. If, however, you are already in
compliance with the prevention elements of Program 2 or Program 3, you may want to
use the RMP to inform the community of your prevention efforts. The Program Level
cannot be edited for an RMP Correction.
KEY POINTS TO REMEMBER
In determining program levels for your process(es), keep in mind the following:
1. The program levels apply to individual processes and generally indicate
the risk management measures necessary to comply with this regulation for the
process, not the facility as a whole. The eligibility of one process for a program
level does not influence the eligibility of other covered processes for other
program levels.
2. Any process can be eligible for Program 1, even if it is subject to OSHA
PSM or is in one of the NAICS codes subject to Program 3.
3. Program 2 is the default program level. There are no "standard criteria" for
Program 2. Any process that does not meet the eligibility criteria for either
Programs 1 or 3 is subject to the requirements for Program 2.
Refer to Chapter 2 of the General Guidance for Risk Management Programs for more
information on determining the Program levels of your processes. Once you determine
the program level, simply enter 1, 2, or 3 for this data element.
1.17b. NAICS codes:
If you know your facility’s NAICS code, enter your NAICS code. To add a NAICS code
to your process, click the Add NAICS code button, which will take you to the Select
NAICS to add screen. To delete the existing NAICS code, click the Delete NAICS
button.
1.17c. Chemicals (regulated substances):
Enter your chemical in this field. For each covered process, provide the names of all
regulated substances held above the threshold. Many regulated substances have
synonyms; however, you must enter the name of the regulated substance as it appears
in Section 68.130. If you have a NFPA-4 flammable mixture containing regulated
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flammables, you may list it as a “flammable mixture.” List all of the regulated
substances contained in the mixture; however, only report the quantity of the entire
mixture, not the individual substances. RMP*eSubmit contains a pick list of all
regulated substances. For an RMP Correction, a chemical cannot be added; only
the Chemical Quantity [lbs] can be updated.
Chemical Update
1.17c.1 Chemical name:
The chemical name field is not editable.
1.17c.2 CAS number:
The CAS number field is not editable.
Chemical type:
The chemical type field is not editable.
Chemical threshold quantity:
The chemical threshold quantity is not editable.
1.17c.3 Chemical quantity (lbs):
For each chemical reported in 1.17 c.1, estimate the maximum quantity (in pounds) held
in the covered process at any one time during the calendar year to two significant digits.
For example:
5,333 pounds should be reported as 5,300 pounds
128,000 pounds should be reported as 130,000 pounds
NAICS Code(s)
The North American Industry Classification System (NAICS) categorizes businesses by
fitting them into descriptive categories that correspond to five-digit or six-digit codes.
NAICS codes have replaced SIC codes, which you may be familiar. For this data
element you should provide the NAICS code that most closely corresponds to the
process; it will not necessarily be the same NAICS code for your facility as a whole.
You may also enter additional NAICS codes if you wish to identify other aspects of a
process not captured by the NAICS codes for the primary activity.
You should determine the NAICS codes for your processes based on your activities on
site using the 2002 North American Industry Classification System Manual*, which can
be viewed at http://www.census.gov/epcd/naics02/naicod02.htm. You may also access
the full list online: http:www.census.gov/epcd/www/naics.html.
*NOTE: RMP*eSubmit will be updated to include the 2007 NAICS Codes in the
near future.
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Once you have selected the sector that most appropriately reflects the sector for your
facility (Step 1), you must select the subsector, which enables you to select a more
specific sector within your industry (Step 2). Next, you must select the industry group
that represents your facility (Step 3). The last option is to select the NAICS code that
reflects your facility (Final Step).
1.
T
he Step 1 – Select Sector drop down list enables you to add the sector of the
NAICS code to Section 1. Processes.
2.
The Step 2 – Select Subsector drop down list enables you to add the subsector of the NAICS code to Section 1. Processes. 3.
T
he Step 3 – Select Industry Group drop down list enables you to add the
industry group of the NAICS code to Section 1. Processes.
4.
The Final Step – Select NAICS code drop down list enables you to select
your NAICS code to Section 1. Processes.
Process ID:
The process ID is automatically generated by the RMP*eSubmit system and is not
editable.
Process name:
The process name is not editable in this screen. The process name can be edited in
the Section 1. Processes screen.
Program level:
The program level is not editable in this screen. The program level is set when you add
or edit a process.
1.18 RMP Preparer Information
1.18a. Name:
Provide the name of the person who prepared the Risk Management Plan for the
facility. If you provide the name of the Preparer, you must provide the remaining
contact information in fields 1.18 b-g.
1.18b. Telephone:
Provide the telephone number of the person who prepared the Risk Management Plan
for the facility.
1.18c. Street 1:
Provide the street address of the person who prepared the Risk Management Plan for
the facility.
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1.18d. Street 2:
Provide any additional street address information for the person who prepared the Risk
Management Plan for the facility.
1.18e. City:
Provide the city of the person who prepared the Risk Management Plan for the facility.
1.18f. State:
Select the state of the person who prepared the Risk Management Plan for the facility
from the drop down list.
1.18g. ZIP code:
Provide the ZIP code of the person who prepared the Risk Management Plan for the
facility.
Foreign country address (if applicable):
Country:
If the RMP Preparer is located in a foreign country, select the appropriate country from
the drop down list.
State/Province:
If the RMP Preparer is located in a foreign country, provide the appropriate country
state/province.
ZIP/Postal code:
If the RMP Preparer is located in a foreign country, provide the appropriate country
ZIP/postal code.
Reason for Correction:
If you are submitting an RMP Correction, select the appropriate reason for RMP
Correction.
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New data element required by EPA
Change in emergency contact information
Optional data element requested by EPA
Clerical error corrected
Additional information supplied
Minor administrative change
Notification of facility ownership change
New accident history information
Removed OCA description from executive summary
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Reason for Resubmission:
If you are submitting an RMP Resubmission, select the appropriate reason for RMP
Resubmission.
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5-year update (40 CFR 68.190(b)(1))
Change in program level of covered process (40 CFR 68.190(b)(7))
Process no longer covered (source has other processes that remain covered) (40
CFR 68.190(b)(7))
Newly regulated substance listed by EPA (40 CFR 68.190(b)(2))
Newly regulated substance above TQ in already covered process (40 CFR
68.190(b)(3))
Regulated substance present above TQ in new (or previously not covered)
process (40 CFR 68.190(b)(4))
Revised PHA/Hazard Review due to process change (40 CFR 68.190(b)(5))
Revised OCA due to change (40 CFR 68.190(b)(6))
Voluntary update (not described by any of the above reasons)
Section 2. Toxics: Worst-Case
Worst-case release scenario analysis of covered processes as follows:
Report one worst-case release scenario for each Program 1 process. Program 1
processes must have no public receptors within the distance to the endpoint in the
worst-case analysis.
If your facility has Program 2 or Program 3 processes, report one worst-case release
scenario to represent all Program 2 and Program 3 processes having toxic regulated
substances present above the threshold quantity, and one worst-case release scenario
to represent all Program 2 and Program 3 processes having flammable regulated
substances present above the threshold quantity. If you have more than one Program 2
or 3 process, you will report the worst-case release scenario for the Program 2 or 3
process that would have the greatest potential impact on the public (i.e., the greatest
distance to endpoint). You may also need to submit an additional worst-case scenario
for either hazard class (i.e., toxic or flammable), if a worst-case release from elsewhere
at your facility would potentially affect a different set of public receptors than those
affected by your initial worst-case scenario(s).
You may include one graphic (map or diagram) in electronic format for each release
scenario that you report, but it is not required.
Complete this section for each toxics worst-case scenario you report.
The following is a discussion of each element in Section 2. Toxics: Worst Case.
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2.1
Chemical
2.1a. Process name:
The process description from which the chemical was entered in Processes 1.17. This
field is disabled and cannot be edited as it reflects information entered in Section 1.
Processes.
2.1b. Chemical name:
The regulated toxic chemical you evaluated in the worst-case scenario previously
entered in Processes 1.17. This field is disabled and cannot be edited as it reflects
information entered in Section 1.17 Processes.
2.1c. Percentage weight of chemical:
If your worst-case scenario involves the release of a mixture containing a regulated
substance, enter the percentage weight of the regulated substance in the mixture.
(Leave blank if it is not a mixture.)
2.2
Physical state:
Select the physical state of the chemical as it is released in the scenario from the drop
down list.
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Gas (Select if the chemical is a gas)
Liquid (Select if the chemical is a liquid)
Gas liquified by pressure
Gas liquified by refrigeration
2.3
Model used (select one):
Select one of the options for the source of your results for your worst-case release. If
you select the Other model name (specify) option, you must specify the other model
name in the Model Used Text (if Other) field. The options are listed below:
a.
E
PA’s OCA Guidance Reference Tables or Equations
b.
E
PA’s RMP Guidance for Ammonia Refrigeration Reference Tables or Equations
(now in General Guidance for Risk Management Programs)
c.
PA’s RMP Guidance for Waste Water Treatment Plants Reference Tables or
E
Equations (now in General Guidance for Risk Management Programs)
d.
EPA’s RMP Guidance for Warehouses Reference Tables or Equations
e.
EPA’s RMP Guidance for Chemical Distributors Reference Tables or Equations
f. EPA’s RMP*Comp™
g. Areal Locations of Hazardous Atmospheres (ALOHA ®) (Toxics only)
h. Other model name (specify)
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2.4
Scenario:
Select one of the following that describes your worst-case release scenario from the
drop down list:
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Gas Release: A gas release of the substance in a vapor state. If you hold a gas
liquified under refrigeration, report the release as a liquid.
Liquid Spill and Vaporization: A release of the substance in a liquid state with
subsequent vaporization.
2.5
Quantity released (lbs):
Enter the quantity of toxic chemical you used for your worst-case scenario analysis in
pounds in whole numbers. If you have less than one pound released, round up to one
pound. You may want to clarify this in your Executive Summary.
2.6
Release rate (lbs/minute):
Enter the rate of release to the outside air in pounds per minute in whole numbers. For
example:
4.3 pounds should be reported as... 4 pounds
19 pounds should be reported as... 20 pounds
See Chapter 4 of the General Guidance for Risk Management Programs.
2.7
Release duration (minutes):
Enter the length of time in minutes for the entire quantity from the vessel, pipeline, or
other source to be released to the outside air.
For gases, a gas liquified by pressurization alone, or a gas liquified by refrigeration
where the released refrigerated liquid forms a pool of 1 cm or less in depth, you should
assume that the release duration is 10 minutes.
For a liquid or a gas liquified by refrigeration where the released refrigerated liquid
forms a pool deeper than 1 cm, the release duration should be the time required for a
pool formed by the released substance to completely vaporize.
Although in some cases it may take longer than 60 minutes for the pool to completely
volatilize, most dispersion models use the release rate and calculate the maximum
downwind dispersion distance within 60 minutes; therefore, you may enter 60 minutes
for your duration even if the duration from your modeling is longer than 60 minutes. You
can also enter the exact duration from your modeling up to 9999.9 minutes.
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2.8
Wind speed (meters/second):
If you used the OCA guidance or one of EPA's model program guidance documents,
enter or edit 1.5 meters per second. If you modeled your scenario separately, enter or
edit the wind speed used.
2.9
Atmospheric stability class:
If you used the OCA Guidance or one of EPA’s model program guidance documents,
list select F stability from the drop down list. If you modeled your scenario separately,
select the appropriate stability class used from the drop down list.
2.10 Topography:
Select whether the local topography is urban or rural from the drop down list. Urban
means that there are many obstacles in the immediate area; obstacles include buildings
or trees. Rural means that the terrain is generally flat and unobstructed in the
immediate area.
2.11 Distance to endpoint (miles):
Enter the distance to the endpoint in miles to 2 significant digits, using the endpoint
specified for the chemical in 40 CFR Part 68, Appendix A. Convert your modeling
results into miles by dividing the distance in feet by 5280 or yards by 1760. Refer to the
following to determine 2 significant digits:
0.397 miles should be reported as 0.40 miles
9.345 miles should be reported as 9.3 miles
20.764 miles should be reported as 21.0 miles
2.12 Residential population within distance to endpoint:
Enter the estimated population within the circle with a center at the point of the release
and a radius determined by the distance to the endpoint to two significant digits (e.g.,
5,500 people rather than 5,483). Population estimates include only residential
populations.
2.13 Public receptors within distance to endpoint:
Select one or more of the public receptors within distance to endpoint by checking the
check box that corresponds with the specified receptor in fields 2.13 a-g.
a. Schools: Public and private elementary, secondary, or post-secondary
educational institutions (e.g., colleges).
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b. Residence: Public and private residences and dwellings wherever people
live.
c. Hospitals: Public and Private Hospitals. Places that provide emergency care
and or long term care of the sick or elderly.
d. Prisons/Correction facilities: Prisons where men or women are
incarcerated. Holding places or state of confinement for criminals.
e. Recreation areas: Recreation areas include stadiums, parks, and public
pools.
f. Major commercial, office industrial areas: Commercial, office, or industrial
areas include industrial parks, office buildings, shopping malls, commercial
areas, and commercial farms.
g. Other: Include any other additional information here.
2.14 Environmental receptors within distance to endpoint:
Select one or more of the environmental receptors within distance to endpoint by
clicking the check box that corresponds with the specified receptor in fields 2.14 a-d.
These options are a combination of national or state parks, forests, or monuments
which are within a circle whose center is the point of the release and the radius is
determined by the distance to the endpoint. Select all that apply.
a. National or state parks, forests, or monuments
b. Officially designated wildlife sanctuaries, preserves, refuges
c. Federal wilderness areas
d. Other (Specify). (Include any other additional information.)
2.15 Passive mitigation considered:
Select one or more of the passive mitigations considered within distance to endpoint by
checking the check box that corresponds with the specified receptor in fields 2.15 a-f.
This field is an indication that officially designated wildlife sanctuaries, preserves, or
refuges are within a circle whose center is the point of the release and the radius is
determined by the distance to the endpoint.
a. Dikes: A dike is a low wall that acts as a barrier to prevent a spill from
spreading.
b. Enclosures: An enclosure is a physical containment of the release within a
structure (e.g., a building).
c. Berms: A berm is a mound or wall of earth at the top or bottom of a slope that
prevents a spill from spreading.
d. Drains: A drain is a channel that carries off surface water.
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e. Sumps: A sump is a pit or tank that catches liquid runoff for drainage or
disposal.
f. O
ther: List a type of passive mitigation considered other than what is listed
above.
2.16 Graphics file:
You may load one graphic file to illustrate each release scenario by clicking on the
Load/Unload File button. Entering a graphics file name in this field will not
automatically cause that file to be included in your RMP submission. Graphics will be
accepted in either GIF or JPEG file format. If you have a graphics file present in your
RMP that you would like to remove, you can also unload the graphic file using the
Load/Unload File button.
Section 3. Toxics: Alternative Release
Alternative release scenario analysis of Program 2 and Program 3 processes as
follows:
Present one alternative release scenario for each regulated toxic substance held above
the threshold quantity in a Program 2 or 3 process, including the substance considered
in the worst-case analysis.
Present one alternative release scenario to represent all flammable substances held
above the threshold quantity in a Program 2 or 3 process.
Note that alternative release scenarios should be those that will reach an endpoint
offsite, unless no such scenario exists.
You may include one graphic (map or diagram) in electronic format for each release
scenario that you report, but it is not required.
Complete this section for each toxics alternative release scenario you report.
The following is a discussion of each element in Section 3. Toxics: Alternative Release.
3.1
Chemical
3.1a. Process name:
The process description, from which the chemical was entered in Section 1. Process.
This field is disabled and cannot be edited as it reflects information entered in Section 1.
Processes.
3.1b. Chemical name:
This is the regulated toxic chemical you evaluated in the alternative scenario. This is the
name of the chemical that you selected in 1.17.
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3.1c. Percent weight of chemical (if in a mixture):
If your alternative scenario involves the release of a mixture containing a regulated
substance, enter the percentage weight of the regulated substance in the mixture.
(Leave blank if it is not a mixture.)
3.2
Physical state:
Select the physical state of the chemical as it is released in the scenario from the drop
down list.
ƒ
ƒ
ƒ
ƒ
Gas (Select if the chemical is a gas)
Liquid (Select if the chemical is a liquid)
Gas liquified by pressure
Gas liquified by refrigeration
3.3
Model used:
Select one of the options for the source of your results for your alternative release. If
other model name option is selected, you must specify the other model name in the
Model Used Text (if Other) field. The options are list below:
a. EPA’s OCA Guidance Reference Tables or Equations
b. EPA’s RMP Guidance for Ammonia Refrigeration Reference Tables or
Equations (toxics only) (now in General Guidance for Risk Management
Programs)
c. EPA’s RMP Guidance for Waste Water Treatment Plants Reference Tables
or Equations (now in General Guidance for Risk Management Programs)
d. EPA’s RMP Guidance for Warehouses Reference Tables or Equations
e. EPA’s RMP Guidance for Chemical Distributors Reference Tables or
Equations
f. EPA’s RMP*Comp™
g. Areal Locations of Hazardous Atmospheres (ALOHA®)
h. Other model name (specify)
3.4
Scenario:
Select one of the following that describes your alternative release scenario from the
drop down list or enter another “Scenario Text”:
ƒ
ƒ
ƒ
Transfer Hose Failure: Failure of the connection between two or more vessels.
Liquid.
Pipe Leak: Release through a rupture in a pipe
Vessel Leak: Release through a rupture in a vessel
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ƒ Overfilling: Release due to filling a pipe, vessel, or other container past its
capacity
ƒ Rupture Disk/Relief Valve: Release due to failure of a rupture disk/relief valve
to function properly. A rupture disk/relief valve is a valve that relieves pressure
beyond a specified limit; a relief valve recloses upon return to normal operating
conditions
ƒ Excess Flow Valve Failure: Release caused by the failure of excess flow
device to function properly and prevent surges from reaching downstream
equipment
ƒ Other (specify): Specify your scenario if not described in the drop-down menu
3.5
Quantity released (lbs):
Enter the quantity of toxic chemical you used for your alternative scenario analysis in
pounds in whole numbers. If you have less than one pound released, round up to one
pound. You may want to clarify this in your Executive Summary.
3.6
Release rate (lbs/minute):
Enter the rate of release to the outside air in pounds per minute in whole numbers. For
example:
4.3 pounds should be reported as... 4 pounds
19 pounds should be reported as... 20 pounds
See Chapter 4 of the General Guidance for Risk Management Programs for
more information.
3.7
Release duration (minutes):
Enter the length of time in minutes (0.1 to 9999.9) for the release to the outside air of
the quantity you chose for the alternative scenario.
For gases, a gas liquified by pressurization alone, or a gas liquified by refrigeration
where the released refrigerated liquid forms a pool of 1 cm or less in depth, you should
assume that the release duration is 10 minutes.
For a liquid or a gas liquified by refrigeration where the released refrigerated liquid
forms a pool deeper than 1 cm the release duration should be the time required for a
pool formed by the released substance to completely vaporize.
Although in some cases it may take longer than 60 minutes for the pool to completely
volatilize, some dispersion models use the release rate and calculate the maximum
downwind dispersion distance within 60 minutes; therefore, you may enter 60 minutes
for your duration even if the duration from your modeling is longer than 60 minutes. You
can also enter the exact duration from your modeling up to 9999.9 minutes.
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See Chapter 4 of the General Guidance for Industry for more information.
3.8
Wind speed (meters/second):
If you used the OCA guidance or one of EPA's model program guidance documents,
indicate 3 meters per second. If you modeled your scenario separately, provide the
wind speed used.
3.9
Atmospheric stability class:
If you used the OCA Guidance or one of EPA’s model program guidance documents,
list D stability. If you modeled your scenario separately, enter the stability class used.
3.10 Topography (select one):
Select whether the local topography is urban or rural from the drop down list. Urban
means that there are many obstacles in the immediate area; obstacles include buildings
or trees. Rural means that the terrain is generally flat and unobstructed in the
immediate area.
3.11 Distance to endpoint (miles):
Enter the distance to the endpoint in miles to 2 significant digits, using the endpoint
specified for the chemical in 40 CFR part 68, Appendix A. Convert your modeling
results into miles by dividing the distance in feet by 5280 or yards by 1760. Refer to the
following to determine 2 significant digits:
0.397 miles should be reported as 0.40 miles
9.345 miles should be reported as 9.3 miles
20.764 miles should be reported as 21.0 miles
3.12 Estimated residential population within distance to endpoint (numbers):
Enter the population within the circle with a center at the point of the release and a
radius determined by the distance to the endpoint to two significant digits (e.g., 5,500
people rather than 5,483). Population estimates include only residential populations.
3.13 Public receptors within distance to endpoint:
Select one or more of the public receptors. Public receptors must be identified within
the circle with a center at the point of the release and a radius determined by the
distance to the endpoint. Public receptor means locations where members of the public
may be exposed to toxic concentrations, radiant heat, or overpressure as a result of the
release. Public receptors include locations within the facility's property boundary to
which the public has routine and unrestricted access during or outside business hours
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(e.g., a recreation field). Locations inhabited or occupied by the public at any time
without restriction by the source (such as fences or security guards) are public receptors
(see the General Guidance for Risk Management Programs for more information on
identifying public receptors). You do not need to list specific locations or estimate
populations at these locations. The presence of these receptors may be determined
using local street maps. Select all that apply in fields 3.13 a-g.
a. Schools: Public and private elementary, secondary, or post-secondary
educational institutions (e.g., colleges).
b. Residences: Public and private residences and dwellings wherever people
live.
c. Hospitals: Public and Private Hospitals. Places that provide emergency care
and or long term care of the sick or elderly.
d. Prisons/Correction facilities: Prisons where men or women are
incarcerated. Holding places or state of confinement for criminals.
e. Recreation areas: Recreation areas include stadiums, parks, and public
pools.
f. Major commercial, office industrial areas: Commercial, office, or industrial
areas include industrial parks, office buildings, shopping malls, commercial
areas, and commercial farms.
g. Other: Include any other additional information here.
3.14 Environmental receptors within distance to endpoint:
Select one or more environmental receptors. Environmental receptors must be
identified within the circle with a center at the point of the release and a radius
determined by the distance to the endpoint by clicking the check box in field 3.14 a-d.
Environmental receptor means natural areas, such as national or state parks, forests, or
monuments; officially designated wildlife sanctuaries, preserves, refuges, or areas; and
federal wilderness areas that could be exposed at any time to toxic concentrations,
radiant heat, or overpressure as a result of the release. Environmental receptors can
be identified on local U.S. Geological Survey maps, which can be found at many
libraries. Select all that apply:
a. National or state parks, forests, or monuments
b. Officially designated wildlife sanctuaries, preserves, refuges, or areas
c. Federal wilderness areas
d. Other (Specify) (Include any other additional information.)
3.15 Passive mitigation considered:
Mitigation means specific activities, technologies, or equipment designed or deployed to
capture or control substances that have been released to minimize exposure of the
public or the environment. Passive mitigation means equipment, devices, or
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technologies that function without human, mechanical, or other energy input. Select all
that were considered in defining the release quantity or rate to the worst-case scenario
or alternative release scenario.
a. Dike: A dike is a low wall that acts as a barrier to prevent a spill from
spreading.
b. Enclosures: An enclosure is a physical containment of the release within a
structure [e.g., a building].
c. Berm: A berm is a mound or wall of earth at the top or bottom of a slope that
prevents a spill from spreading.
d. Drain: A drain is a channel that carries off surface water.
e. Sump: A sump is a pit or tank that catches liquid runoff for drainage or
disposal.
f. O
ther: (specify)
3.16 Active mitigation considered:
Active mitigation means equipment, devices, or technologies that need human,
mechanical, or other energy input to function. Select all that were considered in
defining the release quantity or rate of the alternative release scenario.
a. Sprinkler Systems: A system for protecting a building against fire by means
of overhead pipes which convey an extinguishing fluid through heat activated
outlets.
b. Deluge Systems: A system to overflow an area of a release with water or
other extinguishing fluid.
c. Water Curtain: A spray of water from a horizontal pipe through nozzles: the
curtain may be activated manually or automatically.
d. Neutralization: A
means of making a toxic chemical harmless through
chemical reaction.
e. Excess Flow Valve: A device in the outlet of a vessel at a hose connection
that stops the flow or liquid or gas if the piping or hoses downstream fail and a
predetermined excess flow rate is reached.
f. Flares: A device for disposing of combustible gases from a chemical process
by burning them in the open.
g. Scrubbers: A pre-release protection measure that uses water or aqueous
mixtures containing scrubbing reagents to remove discharging liquids and
possibly also treating the discharging chemical.
h. Emergency shutdown systems: C
ontrols that are triggered when process
limits are exceeded and that shutdown process.
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i. Other (specify): Enter a type of passive mitigation considered other than
what is listed above.
3.17 Graphics file:
You may load one graphic file to illustrate each release scenario by clicking on the
Load/Unload File button. Entering a graphics file name in this field will not
automatically cause that file to be included in your RMP submission. Graphics will be
accepted in either GIF or JPEG file format. If you have a graphics file present in your
RMP that you would like to remove, you can also unload the graphic file using the
Load/Unload File button.
Section 4. Flammables: Worst Case
Report one worst-case release scenario for each Program 1 process. Program 1
processes must have no public receptors within the distance to the endpoint in the
worst-case analysis.
If your facility has Program 2 or Program 3 processes, report one worst-case release
scenario to represent all Program 2 and Program 3 processes having toxic regulated
substances present above the threshold quantity, and one worst-case release scenario
to represent all Program 2 and Program 3 processes having flammable regulated
substances present above the threshold quantity. If you have more than one Program 2
or 3 process, you will report the worst-case release scenario for the Program 2 or 3
process that would have the greatest potential impact on the public (i.e., the greatest
distance to endpoint). You may also need to submit an additional worst-case scenario
for either hazard class (i.e., toxic or flammable), if a worst-case release from elsewhere
at your facility would potentially affect a different set of public receptors than those
affected by your initial worst-case scenario(s).
Complete this section for each flammable worst-case scenario you report.
The following is a discussion of each element in Section 4. Flammables: Worst Case.
4.1
Chemical
4.1a. Process name:
The process description from which the chemical was entered in Processes 1.17. This
field is disabled and cannot be edited as it reflects information entered in Section 1.
Processes.
4.1b. Chemical name:
The regulated flammable chemical you evaluated in the worst-case scenario.
4.2
Model used (select one):
Select one of the options for the source of your results for your worst-case release:
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a. EPA’s OCA Guidance Reference Tables or Equations
b. EPA’s RMP Guidance for Propane Storage Facilities Reference Tables or
Equations (Flammable only)
c. EPA’s RMP Guidance for Waste Water Treatment Plants Reference Tables
or Equations (now in General Guidance for Risk Management Programs)
d. EPA’s RMP Guidance for Warehouses Reference Tables or Equations
e. EPA’s RMP Guidance for Chemical Distributors Reference Tables or
Equations
f. EPA’s RMP* Comp™
g. Other model name (specify)
4.3
Scenario:
This data element is fixed. By regulation, for flammables, the worst case assumes an
instantaneous release and a vapor cloud explosion, which is an explosion of a cloud
containing a flammable vapor or gas and air.
4.4
Quantity released (lbs):
Enter the quantity of the flammable substance you used for your worst case scenario
analysis in pounds to two significant digits. If you have less than one pound released,
round up to one pound. You may want to clarify this in your Executive Summary.
4.5
Endpoint used:
This data element is fixed. Because the scenario is fixed by regulation as vapor cloud
explosions, the endpoint which applies to vapor cloud explosions is fixed at 1 psi
overpressure.
4.6
Distance to endpoint (miles):
Enter the distance to the endpoint in miles to two significant digits, using the endpoint
specified for the chemical in 40 CFR part 68, Appendix A. Convert your modeling
results into miles by dividing the distance in feet by 5280 or yards by 1760. Refer to the
following to determine two significant digits:
0.397 miles should be reported as 0.40 miles
9.345 miles should be reported as 9.3 miles
20.764 miles should be reported as 21.0 miles
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4.7
Residential population within distance to endpoint:
Estimate the population within the circle with a center at the point of the release and a
radius determined by the distance to the endpoint to two significant digits (e.g., 5,500
people rather than 5,483). Population estimates include only residential populations.
4.8
Public receptors within distance to endpoint:
Public receptors must be identified within the circle with a center at the point of the
release and a radius determined by the distance to the endpoint. Public receptor
means locations where members of the public may be exposed to toxic concentrations,
radiant heat, or overpressure as a result of the release. Public receptors include
locations within the facility's property boundary to which the public has routine and
unrestricted access during or outside business hours (e.g., a recreation field).
Locations inhabited or occupied by the public at any time without restriction by the
source (such as fences or security guards) are public receptors (see the General
Guidance for Risk Management Programs for more information on identifying public
receptors). You do not need to list specific locations or estimate populations at these
locations. The presence of these receptors may be determined using local street maps.
Select all that apply.
a. Schools: Public and private elementary, secondary, or post-secondary
educational institutions (e.g., colleges).
b. Residences: Public and private residences and dwellings wherever people
live.
c. Hospitals: Public and private Hospitals. Places that provide emergency care
and or long term care for the sick and elderly.
d. Prisons/Correctional facilities: Prisons where men or women are
incarcerated. Holding places or state of confinement for criminals.
e. Recreation areas: Recreation areas include stadiums, parks, and public
pools.
f. Major commercial, office, or industrial areas: Commercial office, or
industrial areas include industrial parks, office buildings, shopping malls,
commercial areas, and commercial farms.
g. Other: Include any other additional information here.
4.9
Environmental receptors within distance to endpoint:
Environmental receptors must be identified within the circle with a center at the point of
the release and a radius determined by the distance to the endpoint. Environmental
receptors means areas, such as national or state parks, forests, or monuments; officially
designated wildlife sanctuaries, preserves, refuges, or areas; and federal wilderness
areas that could be exposed at any time to toxic concentrations, radiant heat, or
overpressure as a result of the release. Environmental receptors can be identified on
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local U.S. Geological Survey maps, which can be found at many libraries. Select all
that apply.
a.
b.
c.
d.
National or state parks, forests, or monuments
Officially designated wildlife sanctuaries, preserves, or refuges
Federal wilderness areas
Other (specify) (Include any other additional information here)
4.10 Passive mitigation considered:
Mitigation means specific activities, technologies, or equipment designed or deployed to
capture or control substances that have been released to minimize exposure of the
public or the environment. Passive mitigation means equipment, devices, or
technologies that function without human, mechanical, or other energy input. Select all
that were considered in defining the release quantity or rate to the worst-case scenario
or alternative release scenario. If the selection for field 4.10.a. does not apply, use the
text field in 4.10.b. to enter the passive mitigation considered in your scenario.
a. Blast Wall: A heavy wall used to isolate buildings or areas that contain highly
combustible or explosive materials
b. Other (specify)
4.11 Graphics file name:
You may load one graphic file to illustrate each release scenario by clicking on the
Load/Unload File button. Entering a graphics file name in this field will not
automatically cause that file to be included in your RMP submission. Graphics will be
accepted in either GIF or JPEG file format. If you have a graphics file present in your
RMP that you would like to remove, you can also unload the graphic file using the
Load/Unload File button.
Section 5. Flammables: Alternative Release
Complete this section for each flammable alternative release scenario you report. If a
flammable substance is used in multiple processes, only one scenario is required. You
will only be able to add or update a scenario if you have entered a flammable chemical
in Section 1. Processes section.
Complete this section for each flammable alternative release scenario you report.
The following is a discussion of each element in Section 5. Flammables: Alternative
Release.
5.1
Chemical
5.1a. Process name:
The process description from which the chemical was entered in Processes 1.17.
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5.2
Model used:
Select the source of your results for your alternative release from the options:
a. EPA’s OCA Guidance Reference Tables or Equations
b. EPA’s RMP Guidance for Propane Storage Facilities Reference Tables or
Equations (Flammables only)
c. EPA’s RMP Guidance for Waste Water Treatment Plants Reference Tables
or Equations (now in General Guidance for Risk Management Programs)
d. EPA’s RMP Guidance for Warehouses Reference Tables or Equations
e. EPA’s RMP Guidance for Chemical Distributors Reference Tables or
Equations
f. EPA’s RMP*Comp™
g. Other model name (specify)
5.3
Scenario:
Select one of the following or enter another scenario in Other:
ƒ Vapor Cloud Explosion: An explosion of a cloud containing a flammable vapor
or gas and air.
ƒ Fireball: The atmospheric burning of a fuel-air cloud in which the energy is
mostly emitted in the form of radiant heat. As the buoyancy forces of the hot
gases begin to dominate, the burning cloud rises and becomes spherical in
shape. Fireballs are often caused by the ignition of a vapor cloud of a flammable
substance.
ƒ BLEVE: Boiling Liquid Expanding Vapor Explosion (BLEVE) is used to describe
the sudden rupture of a vessel/system containing liquified flammable gas under
pressure due to radiant heat flux. The pressure burst and the flashing of the
liquid to vapor creates a blast wall and potential missile damage, and immediate
ignition of the expanding fuel-air mixture leads to an intense combustion creating
a fireball.
ƒ Pool Fire: The combustion of material evaporating from a layer of liquid at the
base of the fire.
ƒ Jet Fire: Gas or liquid discharging or venting from a rupture will form a gas jet
that "blows" into the atmosphere in the direction the hole is facing, all the while
entraining and mixing with air. If the jet is flammable and encounters an ignition
source, a flame jet may form.
ƒ Vapor Cloud Fire: A flash fire results from the ignition of a released flammable
cloud in which there is essentially no increase in the combustion rate.
ƒ Other: (specify)
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5.4
Quantity released (lbs):
Enter the quantity of the flammable substance you used for your alternative scenario
analysis in pounds to two significant digits. If you have less than 1 pound released,
round up to 1 pound. You may want to clarify that in your Executive Summary.
5.5
Endpoint used:
For vapor cloud explosions, the endpoint is 1 psi overpressure; for a fireball the
endpoint is 5 kilowatts per square meter for 40 seconds; for vapor cloud fires or jet fires,
a lower flammability limit (expressed as a percentage) may be listed as specified in
NFPA documents or other generally recognized sources. These are listed in the OCA
Guidance. Enter the endpoint used in the text field.
5.6
Distance to endpoint (miles):
Enter the distance to the endpoint in miles to two significant digits, using the endpoint
specified for the chemical in 40 CFR part 68, Appendix A. Convert your modeling
results into miles by dividing the distance in feet by 5280 or yards by 1760. Refer to the
following to determine two significant digits:
0.397 miles should be reported as 0.40 miles
9.345 miles should be reported as 9.3 miles
20.764 miles should be reported as 21.0 miles
5.7
Residential population within distance to endpoint:
Estimate the population within the circle with a center at the point of the release and a
radius determined by the distance to the endpoint to two significant digits (e.g., 5,500
people rather than 5,483). Population estimates include only residential populations.
5.8
Public receptors within distance to endpoint:
Public receptors must be identified within the circle with a center at the point of the
release and a radius determined by the distance to the endpoint. Public receptor
means locations where members of the public may be exposed to toxic concentrations,
radiant heat, or overpressure as a result of the release. Public receptors include
locations within the facility's property boundary to which the public has routine and
unrestricted access during or outside business hours (e.g., a recreation field).
Locations inhabited or occupied by the public at any time without restriction by the
source (such as fences or security guards) are public receptors (see the General
Guidance for Risk Management Programs for more information on identifying public
receptors). You do not need to list specific locations or estimate populations at these
locations. The presence of these receptors may be determined using local street maps.
Select all that apply:
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a. Schools: Public and private elementary, secondary, or post-secondary
educational institutions (e.g., colleges).
b. Residences: Private residences and dwellings wherever people live.
c. Hospitals: Health care facilities.
d. Prisons or Correctional facilities: Places of incarceration.
e. Recreation areas: Including stadiums, parks, and public pools.
f. Major commercial, office, or industrial areas: Including industrial parks,
office buildings, shopping malls, commercial areas, and commercial farms.
g. Other: (Include any other additional information here)
5.9
Environmental receptors within distance to endpoint:
Environmental receptors must be identified within the circle with a center at the point of
the release and a radius determined by the distance to the endpoint. Environmental
receptor means natural areas, such as national or state parks, forests, or monuments;
officially designated wildlife sanctuaries, preserves, refuges, or areas; and federal
wilderness areas that could be exposed at any time to toxic concentrations, radiant
heat, or overpressure as a result of the release. Environmental receptors can be
identified on local U.S. Geological Survey maps, which can be found at many libraries.
Select all that apply by clicking the appropriate check boxes.
a. National or state parks, forests, or monuments
b. Officially designated wildlife sanctuaries, preserves, or refuges
c. Federal wilderness areas
d. Other (Include any other additional information here)
5.10 Passive mitigation considered:
Mitigation means specific activities, technologies, or equipment designed or deployed to
capture or control substances that have been released to minimize exposure of the
public or the environment. Passive mitigation means equipment, devices, or
technologies that function without human, mechanical, or other energy input. Select all
that were considered in defining the release quantity or rate to the worst-case scenario
or alternative release scenario by clicking the appropriate check boxes.
a. Dike: A dike is a low wall that acts as a barrier to prevent a spill from
spreading.
b. Fire Wall: A wall constructed to prevent the spread of fire.
c. Blast Wall: A heavy wall used to isolate buildings or areas that contain
highly combustible or explosive materials.
d. Enclosure: Physical containment of the release within a structure (e.g., a
building).
e. Other: (specify)
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5.11 Active mitigation considered:
Active mitigation means equipment, devices, or technologies that need human,
mechanical, or other energy input to function. Select all that were considered in
defining the release quantity or rate of the alternative release scenario.
a. Sprinkler Systems: A system for protecting a building against fire by means
of overhead pipes which convey an extinguishing fluid through heat activated
outlets.
b. Deluge Systems: A system to overflow an area of a release with water or
other extinguishing fluid.
c. Water Curtain: A spray of water from a horizontal pipe through nozzles, the
curtain may be activated manually or automatically.
d. Excess Flow Valve: A system for diverting overflow.
e. Other (specify):
5.12 Graphics file name:
You may load one graphic file to illustrate each release scenario by clicking on the
Load/Unload File button. Entering a graphics file name in this field will not
automatically cause that file to be included in your RMP submission. Graphics will be
accepted in either GIF or JPEG file format. If you have a graphics file present in your
RMP that you would like to remove, you can unload the graphic file using the
Load/Unload File button.
Section 6: Five-Year Accident History
Complete this section for each reportable accident.
The following is a discussion of each element in Section 6. Five-Year Accident History.
6.1
Date of accident:
Enter the date on which the accident occurred (MM/DD/YYYY).
6.2
Time accident began:
Enter the time the release began. Use standard time references (i.e., HHMM = 1237).
You must also select the AM or PM check box option to indicate what time of day the
accident occurred.
6.3
NAICS Code of process involved:
Provide an NAICS code by using the NAICS Code Selector field to select the North
American Industry Classification System (NAICS) codes associated with your covered
processes.
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6.4
Release duration:
Enter the approximate length of time of the release in hours (Format: HHH) and in
minutes (Format: MM).
6.5
Chemicals Involved:
Indicate the regulated substance(s) released. Use the name of the substance as listed
in Section 68.130 rather than a synonym. If the release was a NFPA-4 flammable
mixture containing regulated flammables, you may list it as a “flammable mixture” and
list all of the regulated substances contained in the mixture. For the quantity released,
you only report the quantity of the entire mixture, not the individual substances. Only
report chemicals that are listed substances.
6.6
Release event:
Indicate which of the following release events best describes your accident. Select at
least one item from the available check boxes.
a. Gas Release: A gas release is a release of the substance in a vapor state. If
you hold a gas liquified under refrigeration, report the release as a liquid spill.
b. Liquid Spill/Evaporation: A liquid spill/evaporation is a release of the
substance in a liquid state with subsequent vaporization.
c. Fire: A product (e.g., fuel) in a state of combustion.
d. Explosion: A
rapid chemical reaction with the production of noise, heat, and
violent expansion of gasses.
e. Uncontrolled/Runaway Reaction: An indication that the release event
involved an uncontrolled or runaway reaction. A release event caused by an
uncontrolled chemical reaction that generates excessive heat, pressure, or
harmful reaction products. Such events may involve highly exothermic
chemical reactions, self-reactive substances (e.g., substances that undergo
polymerization), unstable, explosive, or spontaneously combustible
substances, substances that react strongly with water or other contaminants,
oxidizers, peroxide-forming substances, or other types of chemical reactions
that generate harmful products or byproducts. This category of release event
may often occur in conjunction with one of the previous categories. In such
cases, be sure to check this category in addition to any other applicable
release event category (e.g., explosion). The burning of ordinary flammable
substances is not typically included in this category.
6.7
Release source:
Select at least one:
a. Storage Vessel: A storage vessel is a container used only to store or hold
(as opposed to react, mix, or move) a regulated substance. Storage vessels
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include transportation containers (e.g., railcars or tank trucks) being used for
on-site storage.
b. Piping: Piping refers to a system of pipes used to carry a fluid or gas.
c. Process Vessel: A process vessel is a container in which regulated
substances are manufactured, reacted, or mixed.
d. Transfer Hose: A transfer hose is a flexible tube used to connect, often
temporarily, two or more vessels.
e. Valve: A
valve is a device used to regulate the flow in piping systems or
machinery. Relief valves open to release pressure in vessels.
f. P
ump: A pump is a device that raises, transfers, or compresses fluids or that
attenuates gases by suction or pressure or both.
g. Joint: The surface at which two or more mechanical components are united.
h. Other (specify):
6.8
Weather conditions at time of event:
This information is important to those concerned with modeling the effects of accidents.
Reliable information from those involved in the incident or from an onsite weather
station is ideal. However, the rule does not require your facility to have an on-site
weather station. If you do not have an on-site weather station, use information from
your local weather station, airport, or other source of meteorological data. Historical
wind speed and temperature data (but not stability data), can be obtained from the
National Climatic Data Center (NCDC) at 828-271-4800. NCDC staff can also provide
information on the nearest weather station. To the extent possible, complete the
following:
a. i. Wind speed: Wind speed is an estimate of how fast the wind is traveling.
b. ii. Wind speed units: Indicate the units in which the speed is expressed as
either miles per hour, meters per second, or knots.
c. iii. Wind direction: Wind direction is the direction from which the wind
comes. For example, a wind that blows from east to west would be described
as having an eastern wind direction. Describe wind direction as one of the 16
standard compass readings [N, S, E, W, NE, SE, NW, SW, NNE, ENE, ESE,
SSE, SSW, WSW, WNW, NNW], using the abbreviation. For example, wind
direction must be reported as S for south, NE for northeast, or SSW for southsouthwest.
d. Temperature: E
nter the ambient temperature at the scene of the accident in
degrees Fahrenheit. If you did not keep a record, you can use the high (for
daytime releases) or low (nighttime releases) for the day. Local newspapers
publish these data.
e. Atmospheric stability class: Depending on the amount of incoming solar
radiation as well as other factors, the atmosphere may be more or less
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turbulent at any given time. Meteorologists have defined six atmospheric
stability classes, each representing a different degree of turbulence in the
atmosphere. When moderate to strong incoming solar radiation heats air
near the ground, causing it to rise and generating large eddies, the
atmosphere is considered unstable, or relatively turbulent. Unstable
conditions are associated with stability classes A and B. When solar radiation
is relatively weak, air near the surface has less of a tendency to rise and less
turbulence develops. In this case, the atmosphere is considered stable or
less turbulent with weak winds; the stability class is E or F. Stability classes
D and C represent conditions of more neutral stability, or moderate
turbulence. Neutral conditions are associated with relatively strong wind
speeds and moderate solar radiation. Select either A, B, C, D, E, or F by
selecting the appropriate entry from the drop down list.
SURFACE WIND SPEED AT
10 METERS ABOVE
GROUND
DAY
NIGHT*
Thinly
Overcast
or > 4/8
low cloud
< 3/8
Cloud
C
E
F
B-C
C
D
E
C
C-D
D
D
D
C
D
D
D
D
Incoming Solar Radiation
Meters per
second
Miles per hour
<2
<4.5
A
A-B
B
2-3
4.5-7
A-B
B
3-5
7-11
B
5-6
11-13
>6
>13
Strong** Moderate
Slight***
f. Precipitation present: Precipitation may take the form of hail, mist, rain,
sleet, or snow. If there was precipitation present at the time of the event,
check the check box in this field.
g. Unknown weather conditions (check if a-d are all unknown): If you do
not have information regarding the weather at the time of the event, select the
check box available in this field. EPA recognizes that you may not have
weather data for accidents that occurred in the past. You must, however,
collect these data during future accident investigations.
6.9
On-site impacts:
Complete each of the following about on-site effects. Enter a number for each entry; if
there were no impacts, enter 0.
a. Deaths: Enter
the number of on-site deaths that are attributable to the
accident or mitigation activities. Onsite deaths include anyone (employees,
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contractors, responders, or others), who was killed by direct exposure to toxic
concentrations, radiant heat, or overpressures from the accidental release or
from indirect consequences of a vapor cloud explosion from an accidental
release (e.g., flying glass debris or other projectiles). If there were no on-site
deaths, enter 0. Specify the deaths as:
i. Employees or contract employees
ii. Public responders (example: fire department personnel)
iii. Public (example: visitors)
b. Injuries: An injury is any effect that results either from direct exposure to
toxic concentrations, radiant heat, or overpressures from the accidental
release or from indirect consequences of a vapor cloud explosion from an
accidental release (e.g., a window shattering after an explosion) and that
requires medical treatment or hospitalization. Medical treatment means
treatment, other than first aid, administered by a physician or registered
professional personnel under standing orders from a physician (OSHA OII
Log, 1904.12). Your OSHA occupational injury and illness log will help
complete these items for employees. Enter the appropriate value for these
fields. If there were no on-site injuries, enter 0. Specify the injuries as:
i. Employees & contract employees
ii. Public responders (example: fire department personnel)
iii. Public (example: visitors)
c. Property damage: Estimate the value of the equipment or business
structures at your facility that were damaged by the accident or mitigation
activities. Record the value in US dollars. Insurance claims may provide this
information. Do not include any losses that you may have incurred as a
result of business interruption. If there was no onsite property damage or no
known damage, enter 0.
6.10 Known offsite impacts:
These are impacts of which you should be aware (e.g., from media reports) or that were
reported to your facility. You are not required to conduct an additional investigation to
determine off-site impacts. Enter a number for each entry; if there were no impacts,
enter 0.
a. Deaths: Enter
the number of offsite deaths that are attributable to the
accident or mitigation activities. Offsite deaths include anyone who was killed
by direct exposure to toxic concentrations, radiant heat, or overpressures
from the accidental release or from indirect consequences of a vapor cloud
explosion from an accidental release (e.g., a window shattering after an
explosion). Responders killed while on site responding to the release
are considered on-site deaths and should not be reported here (See 6.9,
Onsite Impacts). If there were no known offsite deaths, enter 0.
b. Hospitalizations: E
nter the number of people requiring hospitalization.
Hospitalization means any effect that result either from direct exposure to
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toxic concentrations, radiant heat, or overpressures from accidental releases
or from indirect consequences of a vapor cloud explosion from an accidental
release (e.g., a window shattering after an explosion) and that requires
hospitalization (i.e., admittance to the hospital). If there were no known offsite hospitalizations, enter 0.
c. Other medical treatment: Enter the number of people requiring medical
treatment. Medical treatment means any effect that result either from direct
exposure to toxic concentrations, radiant heat, or overpressures from
accidental releases or from indirect consequences of a vapor cloud explosion
from an accidental release (e.g., a window shattering after an explosion) and
that requires medical treatment. If there was no known medical treatment,
enter 0.
d. Evacuated: E
stimate the number of people who were evacuated to prevent
exposure that might have resulted from the accident. A total count of the
number of people evacuated is preferable to the number of houses
evacuated. People who were ordered to move simply to improve access to
the site for emergency vehicles are not considered to have been evacuated,
but people who normally-occupy a building or area and who are prevented
from entering or returning (i.e., blockaded) in order to prevent potentially
harmful exposure should be considered to have been evacuated. If there
were no evacuations, enter 0.
e. Sheltered-in-place: Estimate the number of people who were sheltered-in­
place during the accident. Sheltering-in-place occurs when the incident
commander orders residents to remain inside their home or place of work
until the emergency has ended, preventing exposure to the substance.
Usually these are associated with an emergency broadcast or similar method
of mass notification by response agencies. If no one sheltered in place, enter
0.
f. Property damage: Estimate the value of the equipment or structures off-site
that were damaged by the accident or mitigation activities. Record the value
in U.S. dollars. Insurance claims may provide this information; any level of
off-site property damage triggers reporting. There is no lower limit below
which you would not have to report. If there was no property damage, enter 0.
g. Environmental damage: Indicate whether any environmental damage
occurred and specify the type. The damage is not limited to environmental
receptors listed in the rule. Any damage to the environment (e.g., dead or
injured animals, defoliation, and water contamination) must be reported.
Select all that apply.
• Fish or animal kills.
• Tree, lawn, shrub, or crop damage
• Water contamination
• Soil contamination
• Other (specify)
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6.11 Initiating event:
Select the check box for the one initiating event that best describes the immediate
cause of the accident.
a. Equipment Failure: A device or piece of equipment failed or did not function
as designed. For example, the vessel wall corroded or cracked.
b. Human Error: An operator performed a task improperly, either by failing to
take the necessary steps or by taking the wrong steps.
c. Natural (weather conditions, earthquake): Weather conditions, such as
lightning, hail, ice storms, tornados, hurricanes, floods, high winds or
earthquakes caused the accident.
d. Unknown.
6.12 Contributing factors:
These are factors that contributed to the accident’s occurring, but were not the initiating
event. If you conducted an investigation of the release, you should have identified
factors that led to the initiating event. Select all that apply.
a. Equipment failure: A device or piece of equipment failed to contain
substance or did not function as designed, thereby allowing a substance to be
released.
b. Human error: A person performed an operation improperly or made a
mistake which resulted in an accident.
c. Improper procedures: The procedure did not reflect the proper method of
operation, the procedure omitted steps that affected the accident, or the
procedure was written in a manner that allowed for misinterpretation of the
instructions.
d. Overpressurization: T
he process was operated at pressures exceeding the
design working pressure.
e. Upset condition: Release was caused by incorrect process conditions (e.g.,
increased temperature or pressure).
f. By-pass condition: The failure occurred in a pipe, channel, or valve that
diverts fluid flow from the main pathway when design process or storage
conditions are exceeded (e.g., overpressure). By-pass conditions may be
designed to release the substance to restore acceptable process or
storage conditions and prevent more severe consequences (e.g., explosion).
g. Maintenance activity or inactivity: The failure occurred because of
maintenance activity or inactivity. An example of maintenance activity is
putting the wrong gasket on a tank fitting. An example of maintenance
inactivity is storage racks that remained unpainted for so long that corrosion
caused the metal to fail.
h. Process design failure: T
he failure resulted from an inherent flaw in the
design of the process (e.g., pressure needed to make product exceed the
design pressure of the vessel).
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i. U
nsuitable equipment: The equipment used was incorrect for the process.
For example, the forklift was too large for the corridors.
j. Unusual weather conditions: Weather conditions, such as lightning, hail,
ice storms, tornados, hurricanes, floods, high winds, earthquakes and caused
the accident.
k. Management error: The
failure occurred due to any management error or
management system error not included in categories a through j. Such
factors may include inadequate training, inadequate oversight, inadequate
hazard analysis, or other management-related factors.
l. Other (specify).
6.13 Off-site responders notified:
Indicate whether response agencies (e.g., police, fire, medical services) were notified.
Check one of the following boxes:
a. Notified only.
b. Notified and responded.
c. No, not notified.
d. Unknown.
e. Other (specify).
6.14 Changes introduced as a result of the accident:
Indicate any measures that you have taken at the facility to prevent recurrence of the
accident. Select at least one.
a. Improved/upgraded equipment: A
device or piece of equipment that did
not function as designed was repaired or replaced.
b. Revised maintenance: Maintenance procedures were clarified or changed
to ensure appropriate and timely maintenance including inspection and
testing (i.e., increasing the frequency of inspection or adding a testing
method).
c. Revised training: Training programs were clarified or changed to ensure
that employees and contract employees are aware of and are practicing
correct safety and administrative procedures.
d. Revised operating procedures: Operating procedures were clarified or
changed to ensure that employees and contract employees are trained on
appropriate operating procedures.
e. New process controls: New process designs and controls were installed to
correct problems and prevent recurrence of an accidental release.
f. New mitigation systems: New mitigation systems were initiated to limit the
severity of accidental releases.
g. Revised emergency response plan: T
he emergency response plan was
revised.
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h. Changed process: Process was altered to reduce the risk (e.g., process
chemistry was changed).
i. Reduced inventory: Inventory was reduced at the facility to reduce the
potential release quantities and the magnitude of the hazard.
j. None: No changes initiated at facility as a result of the accident (i.e., none
were necessary or technically feasible). There may be some accidents that
could not have been prevented because they were caused by events that are
too rare to merit additional steps. For example, if a tornado hit your facility
and you are located in an area where tornados are very rare, it may not be
reasonable to design a “tornado-proof” process even if it is technically
feasible.
k. Other: (specify).
Section 6. Chemical Update
The following is a discussion of each element in Section 6. Chemical Update.
Accident ID:
The Accident ID is automatically generated by the CDX RMP*eSubmit system and is
not editable.
Chemical ID:
The Chemical ID is automatically generated by the CDX RMP*eSubmit system and is
not editable.
Chemical Name:
The Chemical Name field is not editable. The Chemical Name can only be edited in the
Section 1. Process screen.
CAS Number:
The CAS Number field is not editable.
Chemical Type:
The Chemical Type field is not editable.
6.5b. Quantity released (lbs):
Provide the chemical quantity for your process chemical in this field. For each chemical
reported in 1.17.c.1, report the maximum quantity (in pounds) held in the covered
process at any one time during the calendar year to two significant digits. For example:
5,333 pounds should be reported as 5,300 pounds
107,899 pounds should be reported as 110,000 pounds
128,000 pounds should be reported as 130,000 pounds
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6.5c. Percent weight of chemical (toxic only):
Provide the percentage weight of the regulated substance in the scenario.
Section 6. NAICS Code Selection
The North American Industry Classification System (NAICS) categorizes businesses by
fitting them into descriptive categories that correspond to five-digit or six-digit codes.
NAICS codes have replaced SIC codes, which you may be familiar with. For this data
element you should provide the NAICS code that most closely corresponds to the
process; it will not necessarily be the same NAICS code for you facility as a whole. You
may also enter additional NAICS codes if you wish to identify other aspects of a process
not captured by the NAICS codes for the primary activity.
You should determine the NAICS codes for your processes based on your activities on
site using the 2002 North American Industry Classification System Manual, which can
be viewed at http://www.census.gov/epcd/naics02/naicod02.htm. You may also access
the full list online: www.census.gov/epcd/www/naics.html.
Once you’ve selected the sector that most appropriately reflects the sector for your
facility (Step 1), you must select the sub-sector, which enables you to select a more
specific sector within your industry (Step 2). Next, you must select the industry group
that represents your facility (Step 3). The last option is to select the NAICS code that
reflects your facility (Final Step). All steps must be competed in succession.
The Populate Selection button enables you to populate the five-year accident history
record with any selections you’ve made from any of the available drop down list in the
and returns you to the previous screen, Section 6. Five-Year Accident History.
The Discard Selection button enables you to discard any selections you’ve made from
any of the available drop down list without saving and returns you to the previous
screen, Section 6. Five-Year Accident History.
NAICS Code Selection
The following is a discussion of each element in Section 6. NAICS Code Selection.
1.
he Step 1 – Select Sector drop down list enables you to add the sector of the
T
NAICS code to an accident scenario.
2.
he Step 2 – Select Sub-Sector drop down list enables you to add the T
subsector of the NAICS code to an accident scenario. 3.
he Step 3 – Select Industry Group drop down list enables you to add the
T
industry group of the NAICS code to an accident scenario.
4.
he Final Step – Select NAICS from following list drop down list enables
T
you to select your NAICS code to an accident scenario.
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Section 7: Prevention Program: Program Level 3
Complete this section for each prevention program you report for a Program 3 process.
You will only be able to add or update a scenario if a Program Level 3 process is
present within Section 1. Processes section.
How Must Prevention Program Data Be Reported?
Prevention program data must be reported on a process-by-process basis. In other
words, you must fill out the prevention program section of the RMP for each Program 2
or Program 3 process you have that is subject to the RMP rule.
How to report the prevention program for a process depends on how many units the
process contains and whether the prevention program applies different safeguards to
different units in the process. The RMP rule broadly defines "process" to include
interconnected or co-located production and storage units. Under the definition,
multiple units and, in some cases, whole sources may be a single "process" for
purposes of the RMP rule. For multiple unit processes, EPA recognizes that prevention
program implementation may involve different safeguards for different units in the
process. For example, different production units may have different operating
procedures. At the same time, some safeguards, such as management of change
procedures, may apply to all the units in the process.
If your process consists of two or more units and different safeguards apply to different
units in that process, you can report the prevention program for that process in one of
the two following ways. You must, however, use one of the two ways to report your
program.
Use the description field in the prevention program to describe in narrative form how
your prevention program is implemented with respect to the different units in the
process. You could start by listing the common prevention program elements you
implement for all of the units (e.g., use of an alarm system or standard management of
change procedures). You would then indicate what additional prevention program
elements you employ for specified units (e.g., use of a dike for certain process units).
Report your prevention program for the process on a unit-by-unit basis by filling out the
prevention program portion of the RMP for every unit in the process, rather than for the
process as a whole. That way, the differences in the program as it relates to each unit
will be clear from the report. However, as noted above, some aspects of a prevention
program may be common to all units. To complete the prevention program record for
each unit, enter the remaining data which is unique to each.
If your process consists of only one unit, or you apply every element of your prevention
program to all the units in the process, you are not required to complete the description
section of this portion of the RMP or report on a unit-by-unit basis. However, you may
use the description field to elaborate on your prevention program.
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Many prevention program data elements ask you to enter the date for the most recent
"review or revision" of a prevention program element required by Part 68. For your first
RMP submission, if you are subject to prevention program requirements only under the
RMP rule (as opposed to other federal or state laws), you should enter the date by
which you completed the prevention program element being addressed. For instance,
for data element number 7.5, "Date of most recent review or revision of operating
procedures," you should enter the date by which you met the operating procedures
requirements of Section 68.69(a) of the RMP rule (if applicable to you). Since this
requirement must be met by the time your first RMP is due, you may enter the date you
complete or submit your first RMP. In the case of data element number 7.3 ("Date on
which safety information was last reviewed or revised"), you should enter the date you
met the requirement of Section 68.65(a) (if applicable to you), since Section 68.65(a)
requires you to meet the requirement before you conduct the process hazard analysis
for the process.
If you are subject to prevention program requirements under other federal or state laws,
you may be in compliance with RMP prevention program requirements as a result of
complying with the other laws. Sources subject to OSHA PSM, for example, may
already meet RMP prevention program requirements for Program 3 processes, since
those requirements are nearly identical to OSHA PSM prevention program
requirements. For your first RMP submission, if you have fulfilled RMP prevention
program requirements in complying with other federal or state laws, you should enter
the date you complied with the requirement or the date you last reviewed or revised the
relevant aspect of your program, whichever is later. For example, OSHA PSM and the
RMP rule both require covered sources to compile and update (under specified
circumstances) process safety information. I f you previously compiled the information
for purposes of complying with OSHA PSM and you have not updated it since, you
should enter the date you compiled it for OSHA in your RMP. If you have updated the
information since compiling it, you should enter the date of the update.
For subsequent RMP submissions, you should enter the date by which you completed
any review or revision of a prevention program element. Several prevention program
elements must be reviewed and, if necessary, revised following a change affecting the
process (see, e.g., requirement to update safety information in Section 68.75(d)).
Under the compliance audit requirement of Sections 68.58 or 68.79 of the RMP
Program, all prevention program elements must be reviewed and, if appropriate, revised
every three years. When you re-submit your next RMP (due every 5 years or sooner
based on the requirements in Section 68.190), you are required to fully update and
certify all nine sections of the RMP. If, by the time you re-submit, you have reviewed or
revised one or more prevention program elements as a result of a change or an audit,
you must enter the date of your review or revision.
Section 7: Prevention Program: Program Level 3
Complete this section for each prevention program you report for a Program 3 process.
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How Must Prevention Program Data Be Reported?
Prevention program data must be reported on a process-by-process basis. In other
words, you must fill out the prevention program section of the RMP for each Program 2
or Program 3 process you have that is subject to the RMP rule.
How to report the prevention program for a process depends on how many units the
process contains and whether the prevention program applies different safeguards to
different units in the process. The RMP rule broadly defines "process" to include
interconnected or co-located production and storage units. Under the definition,
multiple units and, in some cases, whole sources may be a single "process" for
purposes of the RMP rule. For multiple unit processes, EPA recognizes that prevention
program implementation may involve different safeguards for different units in the
process. For example, different production units may have different operating
procedures. At the same time, some safeguards, such as management of change
procedures, may apply to all the units in the process.
If your process consists of two or more units and different safeguards apply to different
units in that process, you can report the prevention program for that process in one of
the two following ways. You must, however, use one of the two ways to report your
program.
Use the description field in the prevention program to describe in narrative form how
your prevention program is implemented with respect to the different units in the
process. You could start by listing the common prevention program elements you
implement for all of the units (e.g., use of an alarm system or standard management of
change procedures). You would then indicate what additional prevention program
elements you employ for specified units (e.g., use of a dike for certain process units).
Report your prevention program for the process on a unit-by-unit basis by filling out the
prevention program portion of the RMP for every unit in the process, rather than for the
process as a whole. That way, the differences in the program as it relates to each unit
will be clear from the report. However, as noted above, some aspects of a prevention
program may be common to all units. To complete the prevention program record for
each unit, enter the remaining data which is unique to each.
If your process consists of only one unit, or you apply every element of your prevention
program to all the units in the process, you are not required to complete the description
section of this portion of the RMP or report on a unit-by-unit basis. However, you may
use the description field to elaborate on your prevention program.
Many prevention program data elements ask you to enter the date for the most recent
"review or revision" of a prevention program element required by Part 68. For your first
RMP submission, if you are subject to prevention program requirements only under the
RMP rule (as opposed to other federal or state laws), you should enter the date by
which you completed the prevention program element being addressed. For instance,
for data element number 7.5, "Date of most recent review or revision of operating
procedures," you should enter the date by which you met the operating procedures
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requirements of Section 68.69(a) of the RMP rule (if applicable to you). Since this
requirement must be met by the time your first RMP is due, you may enter the date you
complete or submit your first RMP. In the case of data element number 7.3 ("Date on
which safety information was last reviewed or revised"), you should enter the date you
met the requirement of Section 68.65(a) (if applicable to you), since Section 68.65(a)
requires you to meet the requirement before you conduct the process hazard analysis
for the process.
If you are subject to prevention program requirements under other federal or state laws,
you may be in compliance with RMP prevention program requirements as a result of
complying with the other laws. Sources subject to OSHA PSM, for example, may
already meet RMP prevention program requirements for Program 3 processes, since
those requirements are nearly identical to OSHA PSM prevention program
requirements. For your first RMP submission, if you have fulfilled RMP prevention
program requirements in complying with other federal or state laws, you should enter
the date you complied with the requirement or the date you last reviewed or revised the
relevant aspect of your program, whichever is later. For example, OSHA PSM and the
RMP rule both require covered sources to compile and update (under specified
circumstances) process safety information. If you previously compiled the information
for purposes of complying with OSHA PSM and you have not updated it since, you
should enter the date you compiled it for OSHA in your RMP. If you have updated the
information since compiling it, you should enter the date of the update.
For subsequent RMP submissions, you should enter the date by which you completed
any review or revision of a prevention program element. Several prevention program
elements must be reviewed and, if necessary, revised following a change affecting the
process (see, e.g., requirement to update safety information in Section 68.75(d)).
Under the compliance audit requirement of Sections 68.58 or 68.79 of the RMP
Program, all prevention program elements must be reviewed and, if appropriate, revised
every three years. When you re-submit your next RMP (due every 5 years or sooner
based on the requirements in Section 68.190), you are required to fully update and
certify all nine sections of the RMP. If, by the time you re-submit, you have reviewed or
revised one or more prevention program elements as a result of a change or an audit,
you must enter the date of your review or revision.
Section 7: Prevention Program: Program Level 3
The following is a discussion of each element in Section 7. Prevention Program:
Program Level 3.
Prevention Program Description:
If different safeguards apply to different units in your process, use this field to explain
how the prevention program for the process relates to the different units in the process.
For example:
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"This process includes three interconnected production units, A, B, and C.
Everything in this prevention program applies to all three units, with the following
exceptions:
• The dates of the PHA, which are 01/02/08, 6/5/07 and 4/3/07 for units A, B,
and C, respectively.
• Production unit A uses only a scrubber as a process control, while units B
and C have relief valves and scrubbers.
• The water curtain indicated as a mitigation measure applies only to
production unit C."
If you have so many "exceptions" that it gets too complicated to explain as
above, but you still have many common data elements, you can report your
prevention program on a unit-by-unit basis. To complete the prevention program
record for each unit, provide the remaining data which is unique to each.
7.1
NAICS code for the process:
Provide the NAICS code that most closely corresponds to the process; it will not
necessarily be the same NAICS code as your facility as a whole. The NAICS code that
you choose must be one that you've already entered in the Registration Section for the
covered process. RMP*eSubmit contains a list of the NAICS codes that you have
already entered for your registered processes as a pick list for this data element.
7.2
Chemical(s):
For each prevention program, provide the names of all regulated substances held
above the threshold in the covered units. If you have an NFPA-4 flammable mixture
containing regulated flammables, you may list it as a “flammable mixture.” You do not
need to list the individual substances in the flammable mixture.
7.3
Date on which the safety information was last reviewed or revised:
The safety information requirements for Program 3 processes can be found at 40
CFR68.65. For your first RMP, provide the date by which you complied with the safety
information requirements of Section 68.65(a) (compile safety information) for the
process. For subsequent RMPs, provide the date the safety information was most
recently reviewed or revised. Safety information may be reviewed or revised as a result
of, among other things, a change to the process (see Section 68.75(d)) or a periodic
audit of the prevention program (see Section 68.79(a)). If the safety information was
not reviewed or revised since the previous RMP was submitted, re-enter the date
provided in the previous Risk Management Plan (RMP).
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7.4 Process Hazard Analysis (PHA):
7.4a. Date of last PHA or PHA update:
Provide the date you completed or updated your most recent PHA.
7.4b. The technique used:
Check any of the following techniques that you used to evaluate the hazards of your
process or part of the process (see Chapter 8, Appendix A, of the General Guidance for
Risk Management Programs for a description of these techniques). Select at least one
by clicking on the check box for each corresponding technique:
ƒ
ƒ
ƒ
ƒ
ƒ
ƒ
ƒ
What If
Checklist
What If/Checklist (combined)
HAZOP
Failure Mode & Effects Analysis
Fault Tree Analysis
Other (specify)
7.4c. Expected or actual date of completion of all changes resulting from last
PHA or PHA update:
Provide the date you completed or expect to complete any changes resulting from the
PHA. This may be blank if there were no changes.
7.4d. Major hazards identified:
Select any major hazards that were identified for the Program 3 process or part of the
process as a result of the PHA. Major hazards are described below. Select at least one
by clicking on the check box for each corresponding technique:
7.4.d. Major Hazard
Description
1. Toxic release
If an accidental release occurred, a regulated toxic substance could
be released. For listed toxics, a toxic release will always be a
major hazard.
2. Fire process
Upsets, leaks, equipment failure, etc., could result in a fire. For
listed flammables, fire will always be a major hazard. Fire may also
be a hazard for some listed toxics and in some processes could
cause a toxic release.
3. Explosion
Confined or unconfined vapor cloud explosions. For listed
flammables, explosion will generally be a major hazard. Explosion
may also be a hazard for toxics, especially those handled under
extreme conditions.
4. Runaway reaction
An uncontrolled reaction that proceeds at an increasing rate.
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7.4.d. Major Hazard
Description
5. Polymerization
A chemical reaction that produces the bonding of two or more
monomers.
6. Overpressurization
Instantaneous energy release or detonation.
7. Corrosion
Corrosion could lead to destruction of equipment and release of a
regulated substance. Corrosion is likely to be a major hazard for
substances identified as corrosives on MSDSs unless the
equipment used limits the hazard.
8. Overfilling
Filling a tank or vessel beyond its maximum safe capacity.
9. Contamination
A release could occur if inappropriate substances are introduced
into storage or process vessels. Contamination may be a major
hazard when controlling inappropriate substances (e.g., H2O) is
difficult.
10. Equipment failure
Equipment failure is likely to be a major hazard for most processes,
because such failure could lead to a release. Equipment failure
includes cracks, weld failures, disk failures, ruptures,
pump/gauge/control system failures, etc.
11. Loss of cooling,
heating, electricity,
instrument air
These losses could be major hazards, if they could lead to
releases. For example, loss of cooling could lead to an increase in
pressure and failure of a vessel or pipe and a loss of heating or
power could lead to unstable processes. These conditions are less
likely to be major hazards for substances handled at atmospheric
temperatures and pressures.
12. Earthquake
Report earthquakes as a major hazard only if they occur or are
likely to occur at your site such that you plan and design for them.
13. Floods (Flood Plain)
Report floods as a major hazard only if they occur or are likely to
occur at your site such that you plan and design for them.
14. Tornadoes
Report tornadoes as a major hazard only if they occur or are likely
to occur at your site such that you plan and design for them.
15. Hurricanes
Report hurricanes as a major hazard only if they occur or are likely
to occur at your site such that you plan and design for them.
16. Other
Specify any other major hazards not listed above.
7.4e. Process controls in use:
Select all of the process controls used on the process or part of the process. Process
controls are equipment and associated procedures used to prevent or limit releases and
are described below. If none are applicable, check None.
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7.4.e. Process Control
Description
1. Vents
An opening provided for the discharge of pressure or release of
pressure from tanks, vessels, or processing equipment.
2. Relief Valves
A valve that relieves pressure beyond a specified limit and recloses to
normal operating pressure upon return.
3. Check Valves
A device for automatically limiting the flow in a piping system to a
single direction.
4. Scrubbers
A pre-release protection measure that uses water or aqueous mixtures
containing scrubbing reagents to remove discharging liquids and may
treat the discharging chemical.
5. Flares
A pre-release protection measure used for flammable gases and
vapors to remove and possibly treat discharged liquids.
6. Manual Shutoffs
Manual controls of the shutoff flow to a pipe or vessel.
7. Automatic Shutoffs Controls the shutoff flow to a pipe or vessel and are triggered
automatically when process conditions are exceeded.
8. Interlocks
A switch or other device that prevents activation of a piece of
equipment when a protective door is open or some other hazard
exists.
9. Alarms and
Procedures
Systems that trigger a warning device after the occurrence of a
hazardous condition and procedures to activate an alarm system.
10. Keyed Bypass
A bypass system that is activated by a control signal.
11. Emergency Air
Supply
A backup system to provide air to a process when the regular air
supply fails.
12. Emergency Power Backup power systems.
13. Backup Pump
A secondary pump intended to serve the same function as the primary
pump if the primary pump fails.
14. Grounding
Equipment and
Bonding
Devices that ground and bond electrical equipment to avoid explosions
and to provide a good electrical path to the ground.
15. Inhibitor Addition
A substance that is added to a reaction that is capable of stopping or
retarding a chemical reaction.
16. Rupture Disks
A device that relieves pressure beyond a specified limit.
17. Excess Flow
Device
Flow-limiting equipment that protects downstream equipment from
surges.
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7.4.e. Process Control
Description
18. Quench System
A system that cools by removing excess heat or immersing liquid into
a cooling medium.
19. Purge System
A system that replaces the atmosphere in a container with an inert
substance to prevent the formations of an explosive mixture.
20. None
None are applicable.
21. Other
Specify any other process controls that you may use on your process
and that are not specified above.
7.4f. Mitigation systems in use:
Select all of the mitigation systems you have in place to control a release from the
process or part of the process. Mitigation systems are described below. If none are
applicable, check None.
7.4.f. Mitigation
Systems
Description
1. Sprinkler systems
A system for protecting a building against a fire by means of overhead
pipes that release an extinguishing material through heat activated
outlets.
2. Dikes
Upsets, leaks, equipment failure, etc., could result in a fire. For listed
flammables, fire will always be a major hazard. Fire may also be a
hazard for some listed toxics and in some processes could cause a
toxic release.
3. Fire walls
A wall constructed to prevent the spread of fire.
4. Blast walls
A heavy wall used to isolate buildings or areas that contain highly
combustible or explosive materials.
5. Deluge system
A system to overflow an area with a release of water or other
extinguishing fluid.
6. Water curtain
A spray of water from a horizontal pipe through nozzles. The curtain
may be activated manually or automatically.
7. Enclosure
Something that facilitates the physical containment of a release within a
structure (e.g., a building).
8. Neutralization
Controlling a release by neutralizing the released chemical.
9. None
None are applicable.
10. Other
Specify any other mitigation systems you may have in place on your
process and that are not listed above.
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7.4g. Monitoring/detection systems in use:
Select all of the monitoring and detection systems you have installed to detect a release
of a regulated substance from the process or part of the process. Monitoring and
detection systems are described below. If none are applicable, check None.
7.4.g. Monitoring &
Detection Systems
Description
1. Process area
detectors
Detection systems located on or close to process equipment.
Detection systems include indicator tubes, and chromatographic,
spectrometric, electrochemical, and colorimetric gas analysis.
2. Perimeter Monitors
Integrated detection networks at the source boundary. Detection
systems can include fluorescent SO2 analyzers, photoelectric tape
sensors, or electrolytic chlorine detectors.
3. None
None are applicable.
4. Other
Specify any other monitoring and detection systems you have in
place and that are not listed above.
7.4h. Changes since last PHA or PHA update:
Select all of the changes made to the process or part of the process since the last PHA.
If none are applicable, check None.
7.4.h. Changes Since Last PHA /
PHA Update
Description
1. Reduction in chemical inventory
A decrease in the quantity of regulated substances
stored on-site.
2. Increase in chemical inventory
An increase in the quantity of regulated substances
stored on-site.
3. Change in process parameters
Examples of changes in process parameters include
an increase or decrease in temperature, pressure,
flow rates, etc.
4. Installation of process controls
The addition of controls such as those described in 7.4
e. or 8.4 d.
5. Installation of process detection
systems
The addition of systems such as those described in
7.4 g. or 8.4 f.
6. Installation of perimeter
monitoring systems
The addition of systems such as those described in
7.4 g. or 8.4 f.
7. Installation of mitigation systems
The addition of systems such as those described in
7.4 f. or 8.4 e.
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7.4.h. Changes Since Last PHA /
PHA Update
Description
8. None recommended
Select None recommended if the PHA team did not
recommend any changes to the process.
9. None
None are applicable.
10. Other (specify)
Specify any other changes made to the process since
the last PHA that are not listed above.
7.5
Date of most recent review or revision of operating procedures:
The operating procedures requirements for Program 3 processes can be found at 40
CFR 68.69. For your first RMP, provide the date by which you complied with the
requirements of Section 68.69(a) (develop and implement written procedures) for the
process. For subsequent RMPs, provide the date of the most recent review or revision
of the operating procedures. Operating procedures may be reviewed or revised as a
result of, among other things, a change to the process (see Sections 68.69(c) and
68.75(e)), annual certification of the operating procedures (see Section 68.69(c)), or a
periodic audit of the prevention program (see Section 68.79(a)).
7.6
Training:
7.6a. Date of most recent review or revision of training programs:
For your first RMP, provide the date by which you ensured that the training you provide
the employees operating the process meets the requirements of Section 68.71(a). For
subsequent RMPs, provide the date of the most recent review or revision of the training
you provide. Training programs may be reviewed or revised as a result of, among other
things, a change to the process (see Section 68.75(c)) or a periodic audit of the
prevention program (see Section 68.79(a)). If the training was not reviewed or revised
since the previous RMP was submitted, re-enter the date provided in the previous RMP.
7.6b. Type of training provided:
Select the type of training provided (select all that apply). Training information can be
found in the RMP regulation at 40 CFR 68.54 and 68.71.
7.6c. Type of competency testing used:
Indicate the type of competency test used: written test, oral test, demonstration, or
observation by selecting the appropriate check box(es). Competency tests are used to
determine and evaluate comprehension of the training materials. Training information
can be found in the RMP regulation at 40 CFR 68.54 and 68.71.
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7.7
Maintenance:
7.7a. The date that you most recently reviewed or revised the maintenance
procedures:
For your first RMP, provide the date by which you complied with the requirements of
Section 68.73(b) (establish and implement written maintenance procedures) for the
process. For subsequent RMPs, provide the date of the most recent review or revision
of the maintenance procedures. Maintenance procedures may be reviewed or revised
as a result of, among other things, a change to the process (see Section 68.75(c)) or a
periodic audit of the prevention program (see Section 68.79(a)). If the procedures were
not reviewed or revised since the previous RMP was submitted, re-enter the date
provided in the previous RMP.
7.7b. The date of the most recent equipment inspection or test:
Provide the appropriate date. Maintenance information can be found in the RMP
regulation at 40 CFR 68.56 and 68.73.
7.7c. The equipment that was inspected or tested (list equipment):
Specify the equipment inspected or tested. Maintenance information can be found in
the RMP regulation at 40 CFR 68.56 and 68.73.
7.8 Management of change:
7.8a. The date of the most recent change (if any) that triggered the management
of change procedure:
Provide the appropriate date. Management of Change information can be found in the
RMP regulation at 40 CFR 68.75.
7.8b. The date that you most recently reviewed or revised the management of
change procedures at your site:
For your first RMP, provide the date by which you complied with the requirements of
Section 68.75(a) (establish and implement written procedures) for the process. For
subsequent RMPs, provide the date of the most recent review or revision of the
procedures. Management of change procedures may be reviewed or revised as a
result of, among other things, a periodic audit of the prevention program (see Section
68.79(a)). If the procedures were not reviewed or revised since the previous RMP was
submitted, retain the date provided in the previous RMP.
7.9 Date of most recent pre-startup review:
The pre-startup review requirements for Program 3 processes can be found at 40 CFR
68.77. Provide the date of the most recent pre-startup review (if any) for this process.
7.10 Compliance audits:
7.10a. Date of most recent compliance audit:
Provide the date of your most recent compliance audit. If you have not conducted a
compliance audit prior to your first submission, leave these fields blank.
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NOTE: A compliance audit is required every three years. Compliance audit
information can be found in the RMP regulation at 40 CFR 68.58 and 68.79.
7.10b. Expected or actual date of completion of all changes resulting from the
compliance audit:
This may be left blank if there were no changes. Incident Investigation information can
be found in the RMP regulation at 40 CFR 68.60 and 68.81.
7.11 Incident investigation:
The incident investigation requirements for Program 3 processes can be found at 40
CFR 68.60 and 68.81.
7.11a. Date of your most recent incident investigation (if any):
Provide the date of your most recent incident investigation, if any. If you have not had
an incident investigation, leave this field blank.
7.11b. The expected or actual date of completion of all changes resulting from the
incident investigation:
Provide the expected or actual date of completion of all changes resulting from the
incident investigation. This may be left blank if there were no changes or all changes
are complete.
7.12 Date of most recent review or revision of employee participation plans:
The employee participation requirements for Program 3 processes can be found at 40
CFR 68.83. For your first RMP, provide the date by which you complied with the
requirements of Section 68.83(a) (develop a written plan) for the process. For
subsequent RMPs, provide the date of the most recent review or revision of the plan.
Employee participation plans may be reviewed or revised as a result of, among other
things, a periodic audit of the prevention program (see Section 68.79(a)). If the plan
was not reviewed or revised since the previous RMP was submitted, retain the date
provided in the previous RMP.
7.13 Date of most recent review or revision of hot work permit procedures:
The hot work permit requirements for Program 3 processes can be found at 40 CFR
68.85. For your first RMP, provide the date by which you ensured that you comply with
the requirements of Section 68.85. For subsequent RMPs, provide the date of the most
recent review or revision of your permit procedures. Hot work permit procedures may
be reviewed or revised as a result of, among other things, a periodic audit of the
prevention program (see Section 68.79(a)). If the procedures were not reviewed or
revised since the previous RMP was submitted, retain the date provided in the previous
RMP.
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7.14 Date of most recent review or revision of contractor safety procedures:
The contractor safety requirements for Program 3 processes can be found at 40 CFR
68.87. Leave this field blank if you do not have any contractors. Otherwise, for your
first RMP, provide the date by which you complied with the requirements of Section
68.87(b) (4) (develop and implement safe work practices for contractors) for the
process. For subsequent RMPs, provide the date of the most recent review or revision
of the procedures. Contractor safety procedures may be reviewed or revised as a result
of, among other things, a change to the process (see Section 68.75(c)) or a periodic
audit of the prevention program (see Section 68.79(a)). If the procedures were not
reviewed or revised since the previous RMP was submitted, retain the date provided in
the previous RMP.
7.15 Date of most recent evaluation of contractor safety performance:
Leave this field blank if you do not have any contractors or have not yet evaluated
contractor performance. Otherwise, provide the date of your most recent evaluation of
contractor safety performance. If you have more than one contractor involved in
operating or maintaining the process, provide the date that you completed your
evaluations of all the contractors.
Section 8: Prevention Program: Program Level 2
Complete this section for each prevention program you report for a Program 2 process.
You will only be able to add or update a scenario if a Program Level 2 process is
present within Section 1. Processes section.
How Must Prevention Program Data Be Reported?
Prevention program data must be reported on a process-by-process basis. In other
words, you must fill out the prevention program section of the RMP for each Program 2
or Program 3 process you have that is subject to the RMP rule.
How to report the prevention program for a process depends on how many units the
process contains and whether the prevention program applies different safeguards to
different units in the process. The RMP rule broadly defines "process" to include
interconnected or co-located production and storage units. Under the definition,
multiple units and, in some cases, whole sources may be a single "process" for
purposes of the RMP rule. For multiple unit processes, EPA recognizes that prevention
program implementation may involve different safeguards for different units in the
process. For example, different production units may have different operating
procedures. At the same time, some safeguards, such as management of change
procedures, may apply to all the units in the process.
If your process consists of two or more units and different safeguards apply to different
units in that process, you can report the prevention program for that process in one of
the two following ways. You must, however, use one of the two ways to report your
program.
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Use the description field in the prevention program to describe in narrative form how
your prevention program is implemented with respect to the different units in the
process. You could start by listing the common prevention program elements you
implement for all of the units (e.g., use of an alarm system or standard management of
change procedures). You would then indicate what additional prevention program
elements you employ for specified units (e.g., use of a dike for certain process units).
Report your prevention program for the process on a unit-by-unit basis by filling out the
prevention program portion of the RMP for every unit in the process, rather than for the
process as a whole. That way, the differences in the program as it relates to each unit
will be clear from the report. However, as noted above, some aspects of a prevention
program may be common to all units. To complete the prevention program record for
each unit, enter the remaining data which is unique to each.
If your process consists of only one unit, or you apply every element of your prevention
program to all the units in the process, you are not required to complete the description
section of this portion of the RMP or report on a unit-by-unit basis. However, you may
use the description field to elaborate on your prevention program.
Many prevention program data elements ask you to enter the date for the most recent
"review or revision" of a prevention program element required by Part 68. For your first
RMP submission, if you are subject to prevention program requirements only under the
RMP rule (as opposed to other federal or state laws), you should enter the date by
which you completed the prevention program element being addressed. For instance,
for data element number 7.5, "Date of most recent review or revision of operating
procedures," you should enter the date by which you met the operating procedures
requirements of Section 68.69(a) of the RMP rule (if applicable to you). Since this
requirement must be met by the time your first RMP is due, you may enter the date you
complete or submit your first RMP. In the case of data element number 7.3 ("Date on
which safety information was last reviewed or revised"), you should enter the date you
met the requirement of Section 68.65(a) (if applicable to you), since Section 68.65(a)
requires you to meet the requirement before you conduct the process hazard analysis
for the process.
If you are subject to prevention program requirements under other federal or state laws,
you may be in compliance with RMP prevention program requirements as a result of
complying with the other laws. Sources subject to OSHA PSM, for example, may
already meet RMP prevention program requirements for Program 3 processes, since
those requirements are nearly identical to OSHA PSM prevention program
requirements. For your first RMP submission, if you have fulfilled RMP prevention
program requirements in complying with other federal or state laws, you should enter
the date you complied with the requirement or the date you last reviewed or revised the
relevant aspect of your program, whichever is later. For example, OSHA PSM and the
RMP rule both require covered sources to compile and update (under specified
circumstances) process safety information. If you previously compiled the information
for purposes of complying with OSHA PSM and you have not updated it since, you
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should enter the date you compiled it for OSHA in your RMP. If you have updated the
information since compiling it, you should enter the date of the update.
For subsequent RMP submissions, you should enter the date by which you completed
any review or revision of a prevention program element. Several prevention program
elements must be reviewed and, if necessary, revised following a change affecting the
process (see, e.g., requirement to update safety information in Section 68.75(d)).
Under the compliance audit requirement of Sections 68.58 or 68.79 of the RMP
Program, all prevention program elements must be reviewed and, if appropriate, revised
every three years. When you re-submit your next RMP (due every 5 years or sooner
based on the requirements in Section 68.190), you are required to fully update and
certify all nine sections of the RMP. If, by the time you re-submit, you have reviewed or
revised one or more prevention program elements as a result of a change or an audit,
you must enter the date of your review or revision.
Complete this section for each prevention program you report for a Program 2 process.
How Must Prevention Program Data Be Reported?
Prevention program data must be reported on a process-by-process basis. In other
words, you must fill out the prevention program section of the RMP for each Program 2
or Program 3 process you have that is subject to the RMP rule.
How to report the prevention program for a process depends on how many units the
process contains and whether the prevention program applies different safeguards to
different units in the process. The RMP rule broadly defines "process" to include
interconnected or co-located production and storage units. Under the definition,
multiple units and, in some cases, whole sources may be a single "process" for
purposes of the RMP rule. For multiple unit processes, EPA recognizes that prevention
program implementation may involve different safeguards for different units in the
process. For example, different production units may have different operating
procedures. At the same time, some safeguards, such as management of change
procedures, may apply to all the units in the process.
If your process consists of two or more units and different safeguards apply to different
units in that process, you can report the prevention program for that process in one of
the two following ways. You must, however, use one of the two ways to report your
program.
Use the description field in the prevention program to describe in narrative form how
your prevention program is implemented with respect to the different units in the
process. You could start by listing the common prevention program elements you
implement for all of the units (e.g., use of an alarm system or standard management of
change procedures). You would then indicate what additional prevention program
elements you employ for specified units (e.g., use of a dike for certain process units).
Report your prevention program for the process on a unit-by-unit basis by filling out the
prevention program portion of the RMP for every unit in the process, rather than for the
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process as a whole. That way, the differences in the program as it relates to each unit
will be clear from the report. However, as noted above, some aspects of a prevention
program may be common to all units. To complete the prevention program record for
each unit, enter the remaining data which is unique to each.
If your process consists of only one unit, or you apply every element of your prevention
program to all the units in the process, you are not required to complete the description
section of this portion of the RMP or report on a unit-by-unit basis. However, you may
use the description field to elaborate on your prevention program.
Many prevention program data elements ask you to enter the date for the most recent
"review or revision" of a prevention program element required by Part 68. For your first
RMP submission, if you are subject to prevention program requirements only under the
RMP rule (as opposed to other federal or state laws), you should enter the date by
which you completed the prevention program element being addressed. For instance,
for data element number 7.5, "Date of most recent review or revision of operating
procedures," you should enter the date by which you met the operating procedures
requirements of Section 68.69(a) of the RMP rule (if applicable to you). Since this
requirement must be met by the time your first RMP is due, you may enter the date you
complete or submit your first RMP. In the case of data element number 7.3 ("Date on
which safety information was last reviewed or revised"), you should enter the date you
met the requirement of Section 68.65(a) (if applicable to you), since Section 68.65(a)
requires you to meet the requirement before you conduct the process hazard analysis
for the process.
If you are subject to prevention program requirements under other federal or state laws,
you may be in compliance with RMP prevention program requirements as a result of
complying with the other laws. Sources subject to OSHA PSM, for example, may
already meet RMP prevention program requirements for Program 3 processes, since
those requirements are nearly identical to OSHA PSM prevention program
requirements. For your first RMP submission, if you have fulfilled RMP prevention
program requirements in complying with other federal or state laws, you should enter
the date you complied with the requirement or the date you last reviewed or revised the
relevant aspect of your program, whichever is later. For example, OSHA PSM and the
RMP rule both require covered sources to compile and update (under specified
circumstances) process safety information. If you previously compiled the information
for purposes of complying with OSHA PSM and you have not updated it since, you
should enter the date you compiled it for OSHA in your RMP. If you have updated the
information since compiling it, you should enter the date of the update.
For subsequent RMP submissions, you should enter the date by which you completed
any review or revision of a prevention program element. Several prevention program
elements must be reviewed and, if necessary, revised following a change affecting the
process (see, e.g., requirement to update safety information in Section 68.75(d)).
Under the compliance audit requirement of Sections 68.58 or 68.79 of the RMP
Program, all prevention program elements must be reviewed and, if appropriate, revised
every three years. When you re-submit your next RMP (due every 5 years or sooner
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based on the requirements in Section 68.190), you are required to fully update and
certify all nine sections of the RMP. If, by the time you re-submit, you have reviewed or
revised one or more prevention program elements as a result of a change or an audit,
you must enter the date of your review or revision.
The following is a discussion of each element in Section 8. Prevention Program:
Program Level 2.
Prevention Program Description:
If different safeguards apply to different units in your process, use this field to explain
how the prevention program for the process relates to the different units in the process.
For example:
"This process includes three interconnected production units, A, B, and C.
Everything in this prevention program applies to all three units, with the following
exceptions:
• The dates of the PHA, which are 01/02/08, 6/5/07 and 4/3/07 for units A, B
and C, respectively.
• Production unit A uses only a scrubber as a process control, while units B
and C have relief valves and scrubbers.
• The water curtain indicated as a mitigation measure applies only to
production unit C."
If you have so many "exceptions" that it gets too complicated to explain as
above, but you still have many common data elements, you can report your
prevention program on a unit-by-unit basis. To complete the prevention program
record for each unit, provide the remaining data which is unique to each.
8.1
NAICS code for the process:
Provide the NAICS code that most closely corresponds to the process; it will not
necessarily be the same NAICS code as your facility as a whole. The NAICS code that
you choose must be one that you've already entered in the Registration Section for the
covered process. RMP*eSubmit contains a list of the NAICS codes that you have
already entered for your registered processes as a list for this data element.
8.2
Chemical(s):
For each prevention program, provide the names of all regulated substances held
above the threshold in the covered units. If you have an NFPA-4 flammable mixture
containing regulated flammables, you may list it as a “flammable mixture.” You do not
need to list the individual substances in the flammable mixture.
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8.3
Safety information:
8.3a. The date that you most recently reviewed or revised the safety information:
For your first RMP, provide the date by which you complied with the safety information
requirements of Section 68.48(a) (compile safety information) for the process. For
subsequent RMPs, provide the date the information was most recently reviewed or
revised. Safety information may be reviewed or revised as a result of, among other
things, a major change to the process (see Section 68.48(c)) or a periodic audit of the
prevention program (see Section 68.58(a)). If the safety information was not reviewed
or revised since the previous RMP was submitted, retain the date provided in the
previous RMP.
8.3b.
Federal or state regulations or industry-specific design codes and
standards used to demonstrate compliance with the safety information
requirement (select at least one):
Are you subject to any of the following federal or state regulations? Do you use any of
the following industry-specific design codes and standards to demonstrate compliance
with the safety information requirement? If none are applicable, check None.
8.3b.i. NFPA 58 (or state law based on NFPA 58):
NFPA stands for National Fire Protection Association; NFPA 58 is a propane (LP gas)
handling code. Note that state propane laws are generally based on NFPA 58. Select
NFPA 58 if your process is subject to a state or local law based on NFPA 58 or if you
follow NFPA 58 in any event.
8.3b.ii. OSHA (29 CFR 1910.111):
OSHA’s rule for operations handling anhydrous ammonia, select 29 CFR 1910.111 if
your process is subject to this rule.
8.3b.iii. ASTM Standards:
Select this if you follow American Society of Testing Materials standards. ASTM
establishes standards for materials, products, systems, test methods, specifications,
classifications, definitions, and recommended practices.
8.3b.iv. ANSI Standards:
Select this if you follow American National Standards Institute standards. ANSI
nationally coordinates voluntary standards. ANSI standards cover areas such as
definitions, terminology, symbols, and abbreviations; materials, performance
characteristics, procedure, and methods of rating; methods of testing and analysis; size,
weight, and volume, safety, health, and building construction.
8.3b.v. ASME Standards:
Select this if you follow American Society of Mechanical Engineers standards. ASME
conducts research and develops boiler, pressure vessel, and power test codes. It also
develops safety codes and standards for equipment.
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8.3b.vi. None:
If your facility does not apply to the Program 2 process any national standards such as
those noted above, and is not subject to any federal or state rules or laws such as those
noted above, select None.
8.3b.vii. Other (specify):
If you apply any other standards to your process safety equipment, select Other and
specify the standards you apply. Some examples of other standards include the
National Electrical Manufacturers Association (NEMA) standards and the American
Petroleum Institute (API) standards. There may also be other codes that apply.
8.3b.viii. Comments:
In this section, please explain how federal, state, or local regulations or industry-specific
design codes and standards are being used to demonstrate compliance with the safety
information requirement.
8.4
Hazard review:
The hazard review requirements for Program 2 processes can be found at 40 CFR
68.50.
8.4a. The date of completion of the most recent hazard review or update:
Provide the date of completion of the most recent hazard review or update (must be
within the five years prior to submission of the RMP).
8.4b. The expected or actual date of completion of all changes resulting from the
hazard review:
This may be left blank if there were no changes.
8.4c. Major hazards identified:
Provide all major hazards that were identified for the Program 2 process or part of the
process at your facility as a result of the hazard review. Major hazards are described in
7.4 d.
8.4d. Process controls in use:
Provide all process controls used on this Program 2 process or part of the process.
Process controls are equipment and associated procedures used to prevent or limit
releases. If none are applicable, check None. Process controls are described in 7.4 e.
8.4e. Mitigation systems in use:
Provide all mitigation systems you have in place to control a release should one occur
from this Program 2 process or part of the process. Mitigation systems are described in
7.4 f. If none are applicable, check None.
8.4f. Monitoring/detection systems in use:
Provide all monitoring and detection systems installed to detect a release of a regulated
substance from the Program 2 process or part of the process. Monitoring and detection
systems are described in 7.4 g. If none are applicable, check None.
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8.4g. Changes since last hazard review or hazard review update:
Provide all changes made to the process or part of the process since the last hazard
review. Hazard review changes are described in 7.4 h. If none are applicable, check
None.
8.5
Date of most recent review or revision of operating procedures:
The operating procedures requirements for Program 2 processes can be found in the
RMP regulation at 40 CFR 68.52. For your first RMP, provide the date by which you
complied with the requirements of Section 68.52(a) (prepare written procedures) for the
process. For subsequent RMPs, provide the date of the most recent review or revision
of the operating procedures. Operating procedures may be reviewed or revised as a
result of, among other things, a major change to the process (see Section 68.52(c)) or a
periodic audit of the prevention program (see Section 68.58(a)). (See Chapter 7 of the
General Guidance for Risk Management Programs for a discussion of what constitutes
a major change.) If the operating procedures were not reviewed or revised since the
previous RMP was submitted, retain the date provided in the previous RMP.
8.6
Training:
Training requirements for Program 2 processes can be found at 40 CFR 68.54.
8.6a. Date of most recent review or revision of training programs:
For your first RMP, provide the date by which you ensured that the training you provide
the employees operating the process meets the requirements of Section 68.54 (a). For
subsequent RMPs, provide the date of the most recent review or revision of the training
you provide. Training programs may be reviewed or revised as a result of, among other
things, a change to the process (see Section 68.54 (d) (c)) or a periodic audit of the
prevention program (see Section 68.58 (a)). If the training was not reviewed or revised
since the previous RMP was submitted, retain the date provided in the previous RMP.
8.6b. Type of training provided:
Select the type of training provided (select all that apply).
1. Classroom
2. On the job
3. Other (specify)
8.6c. Type of competency testing used:
Indicate the type of competency test used. Competency tests are used to determine
and evaluate comprehension of the training materials. Training information can be
found in the RMP regulation at 40 CFR 68.54 and 68.71.
1. Written test
2. Oral test
3. Demonstration
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4. Observation
5. Other (specify)
8.7
Maintenance:
8.7a. The date that you most recently reviewed or revised the maintenance
procedures:
For your first RMP, provide the date by which you complied with the requirements of
Section 68.56 (a) (establish and implement written maintenance procedures) for the
process. For subsequent RMPs, provide the date of the most recent review or revision
of the maintenance procedures. Maintenance procedures may be reviewed or revised
as a result of, among other things, a change to the process (see Section 68.56(a)) or a
periodic audit of the prevention program (see Section 68.58(a)). If the procedures were
not reviewed or revised since the previous RMP was submitted, retain the date provided
in the previous RMP.
8.7b. The date of the most recent equipment inspection or test:
Provide the appropriate date. Maintenance information can be found in the RMP
regulation at 40 CFR 68.56 and 68.73.
8.7c. The equipment most recently inspected or tested (list equipment):
Specify the equipment inspected or tested. Maintenance information can be found in
the RMP regulation at 40 CFR 68.56 and 68.73.
8.8
Compliance audits:
Maintenance requirements for Program 2 processes can be found at 40 CFR 68.58. If
you have not conducted a compliance audit prior to your first submission, leave these
fields blank.
8.8a. The date of your most recent compliance audit:
Provide the date of your most recent compliance audit.
NOTE: A compliance audit is required every three years. Compliance audit
information can be found in the RMP regulation at 40 CFR 68.58 and 68.79.
8.8b. The expected or actual date of completion of all changes resulting from the
compliance audit:
Provide the expected or actual date of completion of all changes resulting from
compliance audit. This may be left blank if there were no changes or all changes are
complete. Incident Investigation information can be found in the RMP regulation at 40
CFR 68.60 and 68.81.
8.9
Incident investigation:
Maintenance requirements for Program 2 processes can be found at 40 CFR 68.60.
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8.9a. The date of your most recent incident investigation (if any):
Provide the date of your most recent incident investigation. Incident investigation (if
any) can be found in the RMP regulation at 40 CFR 68.60. If you have not had an
incident investigation, leave this field blank.
8.9b. The expected or actual date of completion of all changes resulting from the
incident investigation:
Provide the expected or actual date or completion of all changes resulting from the
incident investigation. This may be left blank if there were no changes or all changes
are complete. Incident Investigation information can be found in the RMP regulation at
40 CFR 68.60 and 68.81.
8.10 Date of most recent change that triggered review or revision:
Provide the date of most recent change that triggered review or revision of safety
information, the operating or maintenance procedures, or training. This may be left
blank if there were no changes.
Section 9: Emergency Response
The extent to which you need to fill out this portion of the RMP depends on whether
your employees will respond to releases of regulated substances at your facility. Under
Section 68.90(b), if your employees will not respond to releases, you are not required to
comply with the requirements for an emergency response program provided you meet
the following criteria:
1. If you hold one or more regulated toxic substances over threshold quantities,
your facility must be included in the community emergency response plan
developed under the Emergency Planning and Community Right-to-Know Act
(EPCRA);
2. If you hold only one or more regulated flammable substances over threshold
quantities, you must have coordinated response actions with the local fire
department; and
3. You must have appropriate mechanisms in place to notify emergency responders when there is a need for a response. If your employees will respond to releases of regulated substances at your
facility, you are subject to Section 68.95 and must fill out all the data items in
this section of the RMP. If your employees do not respond to releases of
regulated substances at your facility, you need only respond to the first two
(9.1 a and 9.1 b) and last three (9.7 a, 9.7 b and 9.8) emergency response
data elements.
Complete this section once for all covered processes.
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The following is a discussion of each element in Section 9. Emergency Response.
9.1 Written emergency response (ER) plan:
9.1a. Is your facility included in the community emergency response plan?
If your facility is subject to part 68 because it has one or more regulated toxic
substances above threshold quantities, it is probably included in a local emergency
response plan under the Emergency Planning and Community Right-to-Know Act
(EPCRA). Under Section 303 of EPCRA, local emergency planning committees
(LEPCs) must prepare an emergency response plan for facilities in their planning district
having toxic substances listed under EPCRA 302 in excess of the threshold planning
quantity established under that section. Most of the toxic substances listed in Part 68
are also listed under EPCRA 302, and the EPCRA thresholds for those substances are
generally the same or lower than the Part 68 thresholds for the same substances.
Consequently, Part 68 facilities with toxic substances listed under both EPCRA and Part
68 should be included in community emergency response plans.
In addition, facilities subject to Part 68 as a result of flammable substances may also be
covered by community emergency response plans, since LEPCs can, and sometimes
do, include other hazardous substances, including flammables, in their plans. If you are
not sure whether your facility is included in your community’s local emergency plan,
check with your LEPC.
As noted above, if your employees are not going to respond to releases of regulated
substances at your facility and you have one or more Part 68 regulated toxic
substances over threshold quantities, your facility must be included in the local
emergency response place under EPCRA. Click the check box for this question if your
facility is included in the community’s emergency response plan.
9.1b. Does your facility have its own written emergency response plan?
Click the check box for this question if you have a response plan (not just an emergency
action plan as required by OSHA under 29 CFR 1910.38).
9.2 Does your facility's ER plan include specific actions to be taken in
response to accidental releases of regulated substance(s)?
These data elements (9.2, 9.3, 9.4) reflect the three mandatory components of the
emergency response plan required under Section 68.95(a)(1). For an emergency
response plan to be in compliance with this requirement, you must be able to answer
“yes” to each of these questions. Click the check box for this question if your facility's
ER plan includes specific actions to be taken in response to accidental releases of
regulated substance(s).
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9.3 Does your facility's ER plan include procedures for informing the public
and local agencies responding to accidental releases?
Click the check box for this question if your facility's ER plan includes procedures for
informing the public and local agencies responding to accidental releases.
9.4 Does your facility's ER plan include information on emergency health care?
Click the check box for this field to respond with “yes” to each of this question.
9.5 Date of most recent review or update of your facility's ER plan:
Provide the date on which you most recently reviewed or updated your plan. Section
68.95(a)(4) requires that ER plans be reviewed and updated “as appropriate” to reflect
changes at the facility and to ensure that employees are informed of changes.
9.6 Date of the most recent ER training for your facility’s employees:
Provide the date of the most recent emergency response training at your facility.
Emergency response training includes drills involving your personnel with or without
outside emergency response agencies and tabletop exercises of your emergency
response plan. Single purpose drills (e.g., alarm system drills) may be listed, but
exercises that test more aspects of the plan are preferable.
Part 68 does not specify a schedule for conducting employee response training. You
should not, however, that other planning requirements (e.g., HAZWOPER) may
establish a more formal schedule for conducting training (e.g., eight hours of annual
refresher training.)
9.7 Local agency with which your facility's ER plan or response actions are
coordinated:
If you have an ER plan, indicate the name and phone number of the agency with whom
you have coordinated your plan. Section 68.95(c) requires that a facility’s ER plan be
coordinated with the community emergency response plan under EPCRA for the
facility’s community. The LEPC for the facility’s community will typically be the agency
with which ER plans are coordinated.
If you do not have an ER plan, indicate the agency with which you have coordinated
response activities. As noted above, section 68.90(b) provides that if you have
regulated toxic substances and your employees will not be responding to releases of
those substances, your facility must be included in the community emergency response
plan developed by the LEPC for your community. If that is the case for your facility,
indicate the name and phone number of your LEPC here. If you have only regulated
flammable substances and your employees will not be responding to releases of those
substances, you must have coordinated response actions with the local fire department.
If that is case for your facility, indicate the name and phone number of your local fire
department here.
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9.7a. Name of agency:
If you have an ER plan, provide the name of the agency with whom you have
coordinated your plan.
9.7b. Phone number:
If you have an ER plan, provide the phone number of the agency with whom you have
coordinated your plan.
9.8 What other federal or state emergency plan requirements is your facility
subject to?
Indicate all of the federal and state emergency response regulations or statutes to which
your facility is subject. Select at least one. All RMP facilities are subject to OSHA
emergency planning requirements at 29 CFR 1910.38 or 29 CFR 1910.120.
a. OSHA Regulations at 29 CFR 1910.38. These are OSHA’s Emergency
Action Plan regulations. All RMP facilities are subject to either these OSHA
regulations or OSHA regulations at 29 CFR 1910.120.
b. OSHA Regulations at 29 CFR 1910.120. These are OSHA’s Hazardous
Waste Operations and Emergency Response (HAZWOPER) Plan
regulations. All RMP facilities are subject to either these OSHA regulations or
OSHA regulations at 29 CFR 1910.38.
c. Clean Water Act Regulations at 40 CFR 112. These are EPA’s Oil Spill
Prevention Control and Countermeasures (SPCC) regulations under the
Clean Water Act.
d. RCRA Regulations at 40 CFR 264, 265, and 279.52. These are EPA’s
permitting regulations for solid waste under the Resource Conservation and
Recovery Act (RCRA).
e. OPA 90 Regulations at 40 CFR 112, 33 CFR 154, 49 CFR 194, or 30 CFR
254. These are EPA, U.S. Coast Guard, Department of Transportation, and
Department of the Interior facility response plan regulations under the Oil
Pollution Act of 1990 (OPA 90).
f. State EPCRA Rules or Laws. These are state emergency planning and
community right-to-know (EPCRA) laws. Federal EPCRA does not require
facility response plans, but some state laws may.
g. Other. Specify any other emergency response regulations or laws to which
your facility is subject.
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Executive Summary
The Executive Summary must include a brief description of your facility's risk
management program. You determine the length; it may be as short as two or three
pages or, if you have many processes, it may need to be longer. You should view the
Executive Summary as an opportunity to communicate in your own words the nature of
the risks posed by your facility to your community and to explain what you have done to
minimize those risks. The summary can be an excellent vehicle to display the effort and
resources your facility has put into its accident prevention program. Your Executive
Summary cannot be claimed as CBI. Do not include any CBI data in your Executive
Summary.
The following is a discussion of each element in Executive Summary.
The Executive Summary must briefly describe the following elements:
The accidental release prevention and emergency response policies at your
facility
Describe your facility's overall approach to chemical safety. You may want to include
any corporate policies (if applicable) and an overview of senior management
commitment to safety and implementation of safe procedures.
Your facility and the regulated substances handled
Provide a description of your facility so that the public has a clear picture of the facility,
its processes, and products. Describe the primary activities at the facility (e.g.,
manufacturer of polyethylene, pulp mill, etc.) and the regulated substances used. In
addition, you may want to mention the quantities of these substances handled or stored
at your facility.
The general accidental release prevention program and chemical-specific
prevention steps
You may wish to mention the rules and regulations with which your facility complies,
such as the OSHA PSM rule. You should also highlight practices that you believe are
important to your prevention program. The steps you list may be either technological
(e.g., backup systems) or procedural/managerial (e.g., improved maintenance or
training).
The five-year accident history
Do not present accident history information in table form here; more details will be
provided in the data elements. This should be a written summary; for example,
“We have had five accidental releases of chlorine in the past five years; the
largest release was 1,500 pounds. No one offsite was injured, but several
houses were evacuated as a precautionary measure during the October 2005
and May 2006 releases.”
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The emergency response program
Briefly describe the elements of your response program such as coordination with local
emergency responders, training received by personnel, drills conducted by your facility,
public notification and alert systems, as appropriate.
Planned changes to improve safety
List any upcoming events such as training, installation of new mitigation or control
equipment or technology, organizational changes, etc., that will improve safety at your
facility.
NOTE: A summary of the off-site consequence analysis (OCA) for the worstcase and alternative release scenarios(s) is no longer required to be included in
the Executive Summary. While the RMP rule originally required that the
Executive Summary briefly describe the OCA for worst-case and alternative
release scenario(s), EPA amended the RMP rule in 2004 to remove this
requirement because of security concerns. Your Executive Summary should not
describe nor include information concerning your worst case or alternative
release scenarios.
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CHAPTER 3 HOW TO SUBMIT YOUR RMP
Certifying a Submission in RMP*eSubmit
After the Preparer has prepared and submitted the RMP to the Certifying Official, the
Certifying Official may approve it by certifying and submitting to EPA for processing.
An automated e-mail will be sent to the Certifier and the Preparer. This e-mail is
a notification that a submission has been made by the Preparer and is ready for
review and submission to EPA by the Certifier. The Certifier’s MyCDX Inbox
“Certify Submission” link will show a List of Pending Submissions to be certified.
The Certifier can login to MyCDX and either (a) Certify or (b) Reject a submitted
RMP. The Certifier may also review a previously submitted, certified and
approved RMP for which the Certifier has authorized access.
If the submission is rejected, then an e-mail will be sent to the Preparer to make
necessary corrections before they submit the RMP again to the Certifier for
certification and submission.
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The Certifier has the option to select and review a copy of the previously
submitted approved RMP for a facility by clicking the “View Current RMP” on the
list of associated RMPs.
The RMP selected to be viewed will be in PDF format. See the example
screenshot below.
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If the Certifier accepts and proceeds with the submission, the Certifier will follow
the next process to electronically sign the certification statement.
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Certification Statement (Screenshot 1)
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Certification Statement (Screenshot 2)
Click “Accept” to accept and complete certification, or click “Decline” to decline
the certification.
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Authentication of CDX Credentials
Enter your CDX password to authenticate the submission and click “Login”.
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Re-authentication of CDX Credentials
Now the user will be challenged with 1 of the 5 questions and answers in the
registration process. This step will re-authenticate the CDX credentials. Enter
the answer and click “Answer.”
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Electronic Signature:
Click the “Sign” button to submit your RMP.
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The Certifier will see the following screen as an acknowledgement for the
submission.
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CHAPTER 4 SUBMITTING CBI AND TRADE SECRETS SUBMITTING
PAPERS RMPS
CBI and Trade Secrets
On January 6, 1999, EPA published a final rule in the Federal Register specifying which
RMP data elements may not be claimed as confidential business information (CBI) or
trade secret and what procedures must be followed to claim information as CBI. The
regulatory provisions (Sections 68.151 and 68.152), provide that if you claim any RMP
information as CBI, you must submit to EPA a sanitized RMP, a Substantiation Form
(for explaining why you believe the information meets the criteria for CBI), and an
Unsanitized Data Elements Form (on paper only) (see Appendices C and D for forms).
The sanitized, or redacted, RMP should not include any confidential business
information. If you must claim any CBI in your RMP, call the RMP Reporting Center
for further instructions. Online reporting of an RMP in which the facility claims CBI or
Trade Secrets is not possible at this time.
Submitting Paper RMPs
If you are unable to submit your RMP online, use Appendix A: Risk Management Plan
Form (http://www.epa.gov/emergencies/docs/chem/rmp_esubmit_appendices.pdf) in
this manual or call the RMP Reporting Center for assistance.
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CHAPTER 5 NOTIFYING EPA THAT YOUR FACILITY IS NO LONGER
COVERED BY RMP: DE-REGISTRATION
How to De-register Your Facility
Changes may occur at your facility that make it no longer subject to the RMP
regulations at 40 CFR Part 68 (e.g., you replace the regulated substances in your
process with unregulated substances.) If your facility is no longer covered by RMP, you
must notify EPA as specified in Section 68.190(c) (see box below). Note that the
regulation uses the term “stationary source” to refer to a facility.
68.190 Updates
(c) If a stationary source is no longer subject to this part, the owner or operator
shall submit a de-registration to EPA within six months indicating that the
stationary source is no longer covered.
To de-register, you should submit a letter to the RMP Reporting Center within six
months and include the effective date of the de-registration (the date on which your
facility was no longer covered by part 68). The letter should be signed by the owner or
operator and include your RMP ID number (the 12-digit ID number assigned by EPA).
You may use the Risk Management Program De-registration Form (Appendix E) of this
manual. http://www.epa.gov/emergencies/docs/chem/rmp_esubmit_appendices.pdf
If you de-register your facility and it later again becomes subject to the RMP regulation,
you will need to resubmit an RMP following the resubmission process. You must use
the original EPA Facility ID # to resubmit. You should keep a record of your Facility ID #
upon de-registering. If you have de-registered and do not have your Facility ID #,
contact the RMP Call Center.
De-registered facilities will be noted as such in RMP*Info. De-registered RMPs will
remain in RMP*Info for 15 years.
Important Reminder
Remember to include the 12-digit EPA Facility Identification number (usually beginning
with 1000) that was assigned to your facility. The EPA Facility ID was given to you in
the notification letter you received from the RMP Reporting Center regarding the
submission status of your RMP.
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CHAPTER 6 REPORTING CENTER CONTACT INFORMATION
ACRONYMS OF TERMS
Current Mailing Address for RMP Reporting Center
Mail the signed letter to:
RMP Reporting Center
P.O. Box 10162 Fairfax, VA 22038 For courier and overnight delivery packages, the address is:
RMP Reporting Center c/o CGI Federal, Inc. 12601 Fair Lakes Circle Fairfax, VA 22033 Office of Emergency Management
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Acronyms of Terms
ANSI
ASTM
AUTHCODE
BLEVE
CAA
CAS
CBI
CDX
CERCLA
DUNS
EHS
EPA
EPCRA
ESA
FII
GIS
GPS
HAZWOPER
LEPC
MSDS
NAD
NAICS
NCDC
NFPA
OCA
OPA
OSHA
PHA
PIN
POTWs
PSM
RCRA
RMP
TRI
UIN
WGS
American National Standards Institute Standards
American Society of Testing Materials Standards
Authorization Code
Boiling Liquid Expanding Vapor
Clean Air Act
Chemical Abstracts Service Registry Number
Confidential Business Information
Central Data Exchange
Comprehensive Environmental Response, Compensation, and
Liability Act
Data Universal Numbering System
Extremely Hazardous Substance
Environmental Protection Agency
Emergency Planning and Community Right-to-Know Act
Electronic Signature Agreement
Facility Identification Number
Geographic Information System
Global Positioning System
Hazardous Waste Operations and Emergency Response
Local Emergency Planning Committee
Material Safety Data Sheet
North American Datum
North American Industrial Classification System
National Climatic Data Center
National Fire Protection Association
Offsite Consequence Analysis
Oil Pollution Act
Occupational Safety and Health Administration
Process Hazard Analysis
Personal Identification Number
Publicly Owner Treatment Works
Process Safety Management
Resource Conservation and Recovery Act
Risk Management Plan
Toxic Release Act
Unique Identification Number
World Geodetic System
Office of Emergency Management
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