Search Frequent Questions

Displaying 1 - 15 of 133 results

• Obtaining an RMP ID Number

  How can a facility subject to the Risk Management Plan (RMP) requirements obtain its RMP ID number? The owner or operator of a regulated RMP facility that has already submitted an RMP, may obtain the facility's identification number (RMP ID Number) by contacting the RMP Reporting Center (703-227-7650). An RMP-covered…

  • Last published: May 9, 2024

• Does the distance to endpoint start at the process or stationary source boundary?

  When selecting the worst-case release scenario for Program 2 and 3 processes as required by 40 CFR §68.25, a stationary source owner or operator must analyze the release scenario that results in the greatest distance to an endpoint. Does the "greatest distance to an endpoint" refer to the greatest total…

  • Last published: May 22, 2024

• Using meteorological station data for off-site consequence analyses

  For the purpose of the offsite consequence analyses required under 40 CFR Part 68, Subpart B, there are several instances in which data gathered at a local meteorological station may be used to establish the modeling parameters of wind speed, atmospheric stability, temperature, and humidity for the stationary source. How…

  • Last published: May 22, 2024

• Underground storage tank off-site impacts to groundwater, drinking water, or soil

  For the worst-case and alternative release scenarios of an underground storage tank, should I consider any impact on groundwater, drinking water, or soil? No. As part of the worst-case and alternative release scenarios, you need to define the offsite impacts to the environment (40 CFR §68.33) by listing the environmental…

  • Last published: May 22, 2024

• Administrative controls considered when determining worst-case release quantity

  For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity…

  • Last published: May 22, 2024

• Are Mechanical Controls Considered Administrative Controls?

  For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity…

  • Last published: May 22, 2024

• Worst-case release from smaller process with larger distance to endpoint

  The owner or operator of a stationary source covered by the risk management program regulations must conduct a worst-case release scenario analysis as part of the required hazard assessment (40 CFR §68.25). The worst-case release is defined as the release of the largest quantity of a regulated substance from a…

  • Last published: May 22, 2024

• Does EPA have enforcement authority for the risk management program regulations?

  Yes. Under §113 of the CAA, the Agency has the authority to bring administrative and judicial actions against violators. Judicial actions can be civil and criminal in nature. Section 113(a)(3) authorizes the Agency to order violators to comply with the risk management program regulations. Under section 113(b), the Agency may…

  • Last published: May 23, 2024

• Criteria for selecting stationary sources to audit

  What criteria will be used to select stationary sources for periodic compliance audits of risk management plans (RMPs) submitted under 40 CFR Part 68, Subpart G? The implementing agency will, according to the regulations at 40 CFR §68.220(b), select stationary sources for audits based on any of the following criteria…

  • Last published: May 23, 2024

• Is there a citizen suit provision applicable to RMP?

  Is there a citizen suit provision applicable to CAA §112 and the risk management program rule? Yes, section 304 of the CAA includes a citizen suit provision for violations of emission standards or limitations promulgated under the Act.

  • Last published: May 23, 2024

• How may state and local rules be more stringent?

  In what ways may state and local rules be more stringent? Does this document ( General Risk Management Program Guidance ) provide guidance on state and local differences? States and localities may impose more detailed requirements, such as requiring more documentation or more frequent reporting, specifying hours of training or…

  • Last published: May 26, 2024

• Can I use any previous three year meteorological data for worst case scenario?

  I am trying to complete my worst case release scenario for the Risk Management Plan under §68.25. I understand that I am required to use a wind speed of 1.5 m/s and F atmospheric stability class as specified in §68.22(b), unless I can prove that at no time over the…

  • Last published: May 29, 2024

• If a door is outside the work area but used by workers to enter and exit the room, does the door need to be covered with plastic?

  If the work area is smaller than the entire room, and the door is not within the work area, you do not need to cover the door with plastic. However, all personnel, tools, and other items, including the exterior of containers of waste, must be free of dust and debris…

  • Last published: November 19, 2024

• For an exterior renovation where vertical containment is set up at a distance of less than ten feet from the work surface, must we still extend the ground containment beyond the vertical barrier to meet the ten-foot requirement?

  My firm replaces windows. Various obstacles make it difficult to set up the ten-foot exterior ground containment in a way that would enable our renovators to perform the work and still effectively contain dust. In these cases, we lay the ground containment, but also use vertical containment measures to completely…

  • Last published: November 19, 2024

• In the EPA Certified Renovator Initial course, plastic sheeting is taped to the floor at several corners, but not around the entire perimeter. Must the plastic be "sealed" to the floor on all four edges by tape or just taped at several locations?

  It depends on the specifics of the renovation job. The RRP Rule requires the renovation firm to cover the floor surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in the work area 6 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to…

  • Last published: November 19, 2024