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  • Is the RMP submission date the postmark date or EPA's receipt?

    Initial RMPs must be "submitted" by a certain date, and RMPs must be updated at least every five years from the date of its submission. What constitutes "submission" for purposes of meeting and determining these deadlines - postmarking the RMP or EPA's receipt of the RMP by the due date…

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  • Updating RMP if substance no longer held in excess of threshold quantity

    If a facility had a covered process that was previously subject to the Program 2 or 3 requirements, but no longer holds the regulated substance in excess of the threshold quantity due to a decrease in production or storage, must the facility update its risk management plan (RMP)? If a…

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  • Who should sign the certification statement?

    The owner or operator of a stationary source must submit in the RMP a statement certifying that the RMP is accurate and complete (40 CFR §68.185). Who should sign this certification statement? EPA has not promulgated regulations under 40 CFR Part 68 specifying who must sign the certification statement nor…

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  • Are facilities required to use an Integrated Contingency Plan?

    A number of federal statutes and regulations require emergency response planning (e.g., risk management planning under the Clean Air Act Section 112(r), contingency planning under RCRA, and facility response planning under the Oil Pollution Act). On June 5, 1996, the National Response Team (NRT), published the Integrated Contingency Plan ("One…

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  • Will an Integrated Contingency Plan satisfy RMP requirements?

    The National Response Team's Integrated Contingency Plan guidance, or "One Plan," provides a format for consolidating multiple emergency response plans required under RCRA, OPA, SPCC, DOT, OSHA, and CAA §112(r). Will an Integrated Contingency Plan satisfy all of the risk management program requirements under 40 CFR Part 68? No. An…

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  • Inclusion of release scenarios in executive summary

    Do I have to include a description of my worst-case and alternative release scenario in my executive summary? I'm concerned that the description contains sensitive information, which if included in the executive summary will be available to the public without restriction. No, facilities are not required to include a description…

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  • Withdrawal of an erroneous RMP submission

    What should a facility do if it submitted a risk management plan (RMP) but later discovers that it was never subject to the risk management program requirements? If a facility discovers that it submitted an RMP in error and was never subject to the risk management program regulations, it should…

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  • Changes required for adding new reactor vessels for same substance

    What if I change a process by adding new reactor vessels, but do not change the substances? Because increasing the number of reactor vessels is usually a major change to your process, you will have six months to update your RMP to reflect changes in your prevention program elements and…

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  • Who is responsible for preparing and submitting an RMP for leased propane tanks?

    If an owner of a stationary source leases propane tanks from a gas supplier, who is responsible for preparing and submitting the risk management plan (RMP) addressing the propane tanks? The owner of the stationary source is responsible for preparing and submitting the RMP. The risk management program regulations apply…

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  • New owner using existing RMP

    If a Risk Management Plan (RMP) facility is sold to a new owner, does the new owner have to develop a whole new RMP? Or can they use the existing RMP? No, a facility does not complete a new RMP as the facility keeps the original EPA Facility ID number…

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  • “Other EPA Systems Facility Identifier” for RMP Facility

    A facility subject to the Risk Management Program requirements in 40 CFR Part 68 must enter an “Other EPA Systems Facility Identifier” in Section 1.3 of the Risk Management Plan (RMP). The RMP*eSubmit User’s Manual provides the priority order of identification numbers facilities should use to complete this section. What…

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  • Compliance Audit Date for First Time RMP Submissions

    Facilities subject to the Risk Management Program (RMP) requirements in 40 CFR Part 68 with Program Level 2 and 3 processes must perform compliance audits at least once every three years (40 CFR §§68.58 and 68.79). Section 7.10 of the RMP requires the date of the most recent compliance audit…

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  • RMP Facility Relocates

    Under the risk management program regulations in 40 CFR §68.190, owners or operators must revise and update their risk management plan (RMP) if they meet any of the specified criteria or deregister the RMP within 6 months if they are no longer subject to the rule. However, what should stationary…

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  • Voluntary Implementation and Submission of RMP

    Pursuant to the risk management program regulations in 40 CFR Part 68, owners and operators of a stationary source that have more than a threshold quantity of a regulated substance in a process must implement and submit a risk management plan (RMP) to EPA. If the risk management program regulations…

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  • EPA identification of facilities failing to submit RMPs

    What does EPA do to identify facilities that did not file an initial or updated RMP but were required to do so? EPA examines a number of existing databases to identify potential non-filers. If anyone has any information about any facility that may be subject to the Risk Management Program…

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