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  • Identifying public receptors and property with restricted access

    Does public receptor cover only buildings on a property or the entire property? If the owner of the land next to my site restricts access to the land, is it still a public receptor? Public receptors are not limited to buildings. For example, if there are houses near your property…

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  • Must I anticipate a specific cause for the worst-case scenario for a toxic substance?

    When analyzing the worst-case scenario for regulated toxic substances, must I anticipate a specific cause (e.g., fire, explosion, etc.) of the scenario? No. The worst-case analysis for a release of regulated toxic substances must conform to specific assumptions as identified in § 68.25(c) and (d). Anticipated causes of the release…

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  • No trespassing signs restricted access onsite or offsite public receptor

    The definition of public receptor is "offsite residences, institutions (e.g., schools, hospitals), industrial, commercial, and office buildings, parks, or recreational areas inhabited or occupied by the public at any time without restriction by the stationary source ..." Offsite is further defined to include "areas within the property boundary [of the…

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  • Quantity of a regulated substance in an aqueous solution

    When using RMP*Comp to conduct an offsite consequence analysis (OCA), a facility must specify the quantity released. What quantity should be entered for a regulated toxic substance in an aqueous solution, the total quantity of the aqueous solution or just the quantity of the toxic substance? The entire quantity of…

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  • Worst-case release scenarios for toxics and flammables represented by Program 2 or 3 processes

    A stationary source subject to the risk management program regulations at 40 CFR Part 68 comprises multiple Program 2 and Program 3 covered processes. The owner or operator must do a single worst-case release analysis to represent toxic regulated substances and a single worst-case release analysis to represent flammable regulated…

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  • Statutory authority and regulatory source for the risk management program

    What is the statutory authority and the regulatory source for the risk management program regulations that are codified in 40 CFR Part 68? The risk management program regulations were promulgated pursuant to the §112(r) accidental release prevention provisions of the Clean Air Act, as amended in 1990. The regulatory sources…

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  • When to Revise OCA

    The risk management program in 40 CFR Part 68 requires facilities to conduct an off-site consequence analysis (OCA) to provide information to state, local, and federal governments and the public about the potential consequences of an accidental chemical release. When does a facility need to revise its OCA? The owner…

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  • Worst-case Release Scenario for Separate, Interconnected Vessels

    Pursuant to the risk management program regulations, facilities must perform an offsite consequence analysis for the worst-case release scenario. Do the quantities of two separate vessels that are interconnected with a closed valve need to be aggregated for the worst-case release scenario analysis? No. Worst-case release is defined as the…

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  • Five-year Anniversary Due Date and Time

    Pursuant to the risk management program regulations in 40 CFR §68.190, the owner or operator of a stationary source shall revise and update the RMP at least once every five years from the date of initial submission. At what time on the 5-year anniversary date is the RMP due? The…

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  • Required Contractor Contact Information

    A facility that uses a contractor to prepare its RMP must include in the registration section the name, mailing address, and telephone number of the contractor who prepared the RMP (40 CFR §68.160(b)(14)). When a contractor only prepares a portion of an RMP on behalf of a facility, does the…

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  • Hot Work Permit Procedures and Date

    Stationary sources subject to the Program 3 Prevention Program requirements in 40 CFR Part 68, Subpart D, must include in their Risk Management Plan (RMP) the date of the most recent review or revision of hot work permit procedures in Section 7.13. What are hot work permit procedures and what…

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  • RMP Information Center

    If I have additional questions regarding the RMP regulations, who can I contact via telephone for further assistance? You may contact the EPCRA, RMP & Oil Information Center, a publicly accessible service that provides up-to-date information on the regulatory requirements of the RMP program, including the applicability, program levels, off-site…

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  • Certification Statement for Correction

    Does the certifying official have to sign a certification statement for a correction to a Risk Management Plan? If so, does that certification apply to the entire RMP or just for the correction being made? Yes, the certifying official must sign a digital certification statement in RMP*eSubmit, and it will…

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  • Which chemicals are covered by the general duty provisions?

    For CAA section 112(r)(1), General Duty, what are the chemicals that are covered? There is no specific list of substances which subject a stationary source owner or operator to the general duty provisions. The general duty provisions apply to owners and operators of all stationary sources which have any "extremely…

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