Non-residential population in off-site consequence analyses

Must an owner or operator include in their risk management plan (RMP) estimates of the non-residential population when defining off-site impacts for the off-site consequence analysis?

Owners or operators are required to note in the RMP the presence of any major institutions (i.e., schools, hospitals, or prisons), public recreational areas, arenas, and major commercial and industrial developments, but they are not required to estimate the number of people present at such sites (61 FR 31668, 31709-31710; June 20, 1996).