United States
             Environmental Protection
              Office of Solid Waste
              and Emergency Response
EPA 550-B99-003
June 1999
RMPs Are on the Way!
How LEPCs and Other Local
Agencies Can Include Information
from Risk Management Plans in
Their Ongoing Work
Chemical Emergency Preparedness and Prevention Office
                               Printed on recycled, paper


                                                                              June 1999


At the end of this document you can find a list of chemicals covered by the RMP regulation.
Some recent events have affected the list of flammable substances. On May 21,1999,
Administrator Browner signed an administrative stay of the effective date of the RMP rule as it
applies to flammable hydrocarbon fuels (including propane, butane, ethane, methane and others)
stored in quantities no greater than 67,000 pounds in a process.  Industries now covered by
EPA's stay include distributors and users of natural gas/liquified natural gas, utilities, and exotic
fuel users. The Administrator also signed a proposed rule to establish this exemption.
Depending upon comments received, a final rule is expected in the Fall.

On April 27, 1999 the U.S. Court of Appeals issued a stay that applies to LP Gas/propane only -
at thresholds of 10,000 pounds and above. EPA's administrative stay is different from the court
stay, since it extends to industries that use any RMP listed flammable hydrocarbon as fuel, not
just propane.  Also, EPA's stay has an eligibility cap of 67,000 pounds, while the court stay has
no cap.

The court-ordered stay will be in effect until further review by the court and its scheduling of oral
arguments for the early Fall 1999 term. If the judicial stay is lifted, facilities using LP
Gas/propane will then be subject to EPA's administrative stay and the final rule establishing the
flammable hydrocarbon exemption.

In addition to the judicial and administrative stays, there have been two other Congressional
initiatives. On April 26, Senator Inhofe introduced a bill to exempt flammable fuels from RMP.
On March 25, Congressman Blunt and eight other Representatives introduced a bill to prohibit
RMP listing of liquified petroleum gas (mostly propane).

For up-to-date information about the coverage of flammable hydrocarbons, see the CEPPO
homepage at http://www.epa. gov/ceppo.                    ;


                                    WASHINGTON, D.C. 20460
                                                                                      OFFICE OF
                                                                               SOLID WASTE AND EMERGENCY
Dear LEPC and SERC Members,

        EPA has published new guidance on the Clean Air Act's Risk Management Program (RMP) for LEPCs
and other local agencies.  I have enclosed a copy ofRMPs Are On The Way that has been carefully tailored to
present the risk management program as it pertains to local agencies. This comprehensive guide describes the
elements of RMP and integrates accident prevention with emergency preparedness at the local level.

        The risk management information that becomes available in June 1999 will give you new opportunities
to protect your communities from the hazards of chemical releases. By facilitating the communication of RMP
information to the public, and by fostering public dialogue with industry concerning chemical hazards in your
community, you can bolster and enhance your achievements in emergency planning. I hope that the suggestions
on risk communication in this guidance prove useful to you in this process.

        Many  of you will remember our booklet, It's Not Over in October, which we published two years after
the Emergency Planning and Community Right-To-Know Act was passed. EPCRA required LEPCs to develop
comprehensive emergency plans by October 1988. At that time we encouraged LEPCs to continue their
preparedness and information management work once their contingency plan was complete. Many of you took
that advice and EPA recognizes the important role you play in chemical safety. Now 10 years later, the Clean
Air Act provides another opportunity for you to continue and expand your fine work by addressing chemical
accident prevention.                                            :

        I encourage you to complete and submit to us the evaluation form that can be found at the back of the
guidance.  We want to ensure that we are providing you with the best tools and information to meet your needs.

        I  also would like to draw your attention to information that may assist you to develop contingency
plans to meet the Year 2000 (Y2K) challenge. The Federal Emergency Management Agency (FEMA) has
produced a guide, Contingency and Consequence Management Planning for Year 2000 Conversion- A Guide for
State and Local Emergency Managers, which is available on the Internet at http://www.fema.gQV/v2k/ccmp.htm.
Communicating with industry about their Y2K preparedness and coordinating your emergency response plans
will ensure that you are ready to address possible Y2K consequences. To increase awareness about the potential
for chemical safety problems due to the Y2K problem, CEPPO has developed a Y2K Alert: Prevent Year 2000
Chemical Emergencies. This alert, which targets facilities in the chemical process industry, emphasizes
contingency planning and provides a list of Y2K information resources. We have included the alert at the end of
this document.  It is also posted on the CEPPO Website at  http://www.epa.gov/ceppo.

        Congratulations on your fine work!  Let's continue to work together to ensure chemical safety in our
            OOM^X .   /   v?
                                      Jim Mafcm, Director
                                      Chernlcal^mergency Preparedness and Prevention Office
             Recycled/Recyclable (Printed with Vegetable Oil Based Inks on 100% Recycled Paper (20% Postconsumer)




     The Emergency Planning and Community Right-to-Know Act of 1986
     (EPCRA) calls for the establishment of local emergency planning
 committees (LEPCs). LEPCs are to have broad-based membership whose
 primary work is to receive information from local facilities about chemj-
 cals in the community, use that information to develop a comprehensive
 emergency plan for the community, and respond to public inquiries about
 local chemical hazards and releases. There are now more than 3,500
 LEPCs, and they reflect the diversity of our country.  Most LEPCs are orga-
 nized to serve a county; some are for a single large city; others cover the
 better part of an entire state.                                     i

 We are publishing this booklet in anticipation of the impact a new regula-
 tion will have on LEPCs. The regulation implementing section ll?.(r) of
 the Clean Air Act requires facilities to develop a risk management pro-
 gram to prevent and mitigate the effects of chemical accidents, and to
 document the program in a Risk Management Plan (RMP). These RMPs
 will be available to state and local agencies and to the public. Therefore,
 LEPCs will have access to  more detailed information about chemical haz-
 ards in their communities. LEPCs can use this information to improve
 emergency response plans, inform the public about chemical accident
 hazards and risks, and work with industry and the public to reduce risks
 and improve chemical safety.                                    i

 This booklet will not teach you everything about the RMP regulation.
 Rather, the purpose of this booklet is to describe how LEPCs and similar
 local agencies can take advantage of the risk management program to  :
 build on their existing planning and right-to-know activities under EPCRA.
 We intend this booklet to follow the style of and replace It's Not Over in
 October, a document that EPA and other groups published in 1988 to
 encourage new LEPCs not to stop working once they had completed their
 emergency plans by the October 1988 deadline. For more detailed infor-
 mation about the RMP regulation, consult EPA's General Guidance for Risk
 Management Programs (http://www.epa.gov/ceppo).

 The RMP regulation contains a new deadline: June 21,1999. This time,
 however, the deadline is for industry.  By that date, covered facilities must
 have in place a risk management program and submit an  RMP to EPA.
 This deadline for industry is an opportunity for LEPCs. June 1999 can be
 a beginning for LEPCs, a time to update your existing emergency plans
 with the new RMP  information, a time to better understand chemical haz-
 ards in your community and share your understanding with the public, a
 time to declare in word and deed that you will promote chemical safety in
your community by focusing on preventing accidents.

 RMPs are on the way!  We hope that this booklet helps you and your LEPC
 in your important work of protecting human life and the environment
where you live.



New Information Is Becoming Available
about Chemicals in Your Community	
   Information You Already Have	;	
   New Information	
   Information Sources and Contacts	
A Role for Everyone in Chemical Safety
What Is the RMP Regulation?	
   What Chemicals Are Covered?	
   What Facilities Are Covered?	
   What Must a Facility Do? 	„	
       Hazard Assessment	„	
       Management System	„	
       Prevention Program	„	
       Emergency Response Program	
   Different Requirements for Different Kinds of Facilities
RMPs Are Coming! 	
   What Information Is in an RMP? ...
      Executive Summary	
      Offsite Consequence Analysis .
      Five-Year Accident History	
      Prevention Program 	
      Emergency Response Program
   Confidential Business Information
   How Can LEPCs Access RMPs?	
More on Offsite Consequence Analysis

LEPCs Coordinate Chemical Safety
Activities in the Community	
   Get Everyone Involved	
   Enhancing LEPC-lndustry Relations; Encouraging Compliance .
      Release Modeling		
      Working with Small Businesses 	
      Response Coordination	
      Industry Outreach	
   New Partnerships	
   Talk with Neighboring Communities	

Risk Communication: LEPCs Are a Bridge
between the Public and Local Industry 	22
   Basic Rules of Risk Communication	22
   Hazards Versus Risks	23
   Three Scenarios 	2H
   A Special Case: Dealing with Worst-Case Scenarios 	26
   Respond to Concerns 	27
Improving Your Emergency Plans .

Working with Industry to Prevent
A Few More Suggestions ............................... 31
   Funding Your Activities .............................................. 31
   Liability [[[ 31
   Handy Reference [[[ 32
Appendices and Attachments
   Appendix A: Checklist - Ideas for Action
   Appendix B: EPA Regional Office Contacts for EPCRA and RMP Programs
   Appendix C: Some Background Information: Comparison of Green Book
      and RMP Offsite Consequence Analysis (OCA) Guidance
   Appendix D: Regulated Substances: Chemicals Covered by the RMP


 In 1990, section 112{r) was added to the Clean Air Act (CAA).
 Section 112{r) calls on EPA to establish requirements for facilities to
 reduce the likelihood and severity of accidental chemical releases,
 using hazard assessments, prevention programs, and emergency
 response planning. EPA implemented section 112(r) in its Risk
 Management Program regulation.  Facilities that are covered by the
 Risk Management Program will summarize their program activities
 in Risk Management Plans (RMPs). Facilities are required to submit
 their RMPs to EPA by June 21,1999, and EPA will make the RMPs
 available to the public soon after that.  A host of new information
 will be available to you!

 The provisions for accidental release prevention  in CAA section
 112{r) and the Risk Management Program regulation build on the
 planning and preparedness foundation laid by the Emergency
 Planning and Community Right-to-Know Act of 1986 (EPCRA—also
 known as SARA Title III). EPCRA is intended to encourage emer-
 gency planning efforts at state and local levels and to increase pub-
 lic awareness and understanding of potential chemical hazards pre-
 sent in the community. EPCRA sets up a framework for emergency
 planning at the state and local levels and provides the authority to
 collect chemical information that is important to communities. The
 CAA section 112(r) program provides a complementary approach to
 chemical safety—it requires that facilities take steps to identify
 and control on-site hazards.  It also provides for public access to
 information about the actions facilities are taking to prevent and
 mitigate the potential  offsite effects of these hazards.           :

Information You Already Have

Under EPCRA, you currently receive information from covered facil-
ities on the chemicals they have, the quantities of chemicals stored,
the hazards associated with those chemicals, and information on
storage locations and conditions. Specifically, the EPCRA program
provides you with the following information:
•  Notification from facilities that have extremely hazardous sub-
   stances (EHSs) in excess of threshold planning quantity
   amounts. This information is reported directly to the local
   emergency planning committee (LEPC).  (EPCRA sections 302
   and 303)

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    Notification of emergency information about accidental releas-
    es of reportable quantities of EHSs and substances regulated
    under CERCLA (CERCLA hazardous substances). This informa-
    tion is reported to the LEPC's community emergency coordina-
    tor.  (EPCRA section 30H)

    Material Safety Data Sheets (MSDSs) - or lists of hazardous
    chemicals - from facilities that have threshold quantities of
    hazardous chemicals and that must have an MSDS under the
    Occupational Safety and Health Act, and annual inventory
    information on the quantity, hazard category, and location and
    storage conditions of hazardous chemicals at facilities at
    threshold levels. This information is reported directly to the
    LEPC. (EPCRA sections 311 and 312)

    Annual reports on total yearly releases of toxic chemicals from
    regulated facilities. This information is reported to EPA.  EPA
    compiles this information in a database called the Toxics
    Release Inventory (TRI) and makes the information available to
    the public. (EPCRA section 313)
New Information

Under the CAA section 112(r) Risk Management Program, additional
information will soon be available to you - in the RMPs that facili-
ties will submit to EPA.
    Facility hazard assessments, including worst-case release and
    alternative release scenarios;

    Facility accident prevention activities, such as use of special
    safety equipment, employee safety training programs, and
    process hazards analyses conducted by the facility;

    Past chemical accidents at a facility; and

    Facility emergency response programs and plans.

Both EPCRA and the CAA section 112{r) Risk Management Program
encourage communication between facilities and the surrounding
communities about chemical safety and chemical risks. Regulatory
requirements, by themselves, will not guarantee safety from chemi-
cal accidents. Information about hazards in a community will allow
local emergency officials and the public to work with industry to
prevent accidents.

 For example, facilities are required to provide information about
 possible worst-case scenarios under the Risk Management Program
 - and officials and the public can use the information to under-
 stand the chemical hazards in the community and then engage in a
 dialogue with industry to reduce risk. In this way, accident preven-
 tion is focused primarily at the local level where the risk is found.

 Information Sources and Contacts                i

 Q:  Where can I get updates on the latest EPCRA and BMP guidance
    and program information?

 A:  EPA's Chemical Emergency Preparedness and Prevention
    Internet Homepage at http://www.epa.gov/ceppo/

 Q:  Where can I order copies of documents?

 A:  National Service Center for Environmental Publications (NSCEP)
    Toll-Free: (800)490-9198                               ;

 Q:  Where can I get answers to my questions and order single
    copies of documents?

 A:  The RCRA, Superfund and EPCRA Hotline
    Toil-Free: (800) H2H-93H6
    TDD: (800) 553-7672                                   \
    DC Area: (703)412-9810
    Fax: (202) 651-2061                                    ',
    Monday-Friday, 9:00 a.m. - 6:00 p.m. EST


 Industry complies with EPCRA and RMP reporting requirements
and participates actively with LEPCs and State Emergency
 Response Commissions (SERCs) to ensure that the public under-
stands chemical  hazards in the community and that community
responders are prepared to take appropriate steps if an accident
happens. In addition to the reporting requirements, the RMP regu-
lation requires facilities to develop a risk management  program to
ensure that the facility has implemented accident prevention and
emergency response programs that fit the chemical hazards at the
facility. In addition to these specific requirements, CAA section
112(r)(l) establishes a  general duty for industry to operate safely.

EPA's federal role is to provide national leadership, guidance, and
technical assistance for implementing both EPCRA and  the RMP reg-

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                         CAA Section 112(r) Implementing Agencies

                         Agencies charged with implementing the R1\J1P regulation will
                         conduct outreach, technical assistance, training, reviews of
                         RMPs, audits of RMPs, and inspection of risk; management pro-
                                                               I          i
                         grams at facilities.  In its Guidance for Implementing A^ncles
                         (see table of resources for how to obtain a cppy), EPA n'otes that
                         each state and: locality will have its own appjroach to encourag-
                         ing chemical safety. EPA will work with eacri interested state
                         and/or local agency to develop an appropriate BMP implemen-
                         tation program.                         I          :

                         To learn which agency is implementingthe IpMP regulation in
                         your area, you can call your EPA Regional Office (see contact
                         list at the back of this booklet), or visit the C^PPO websjte at
                         http://www.epa.gov/ceppo.              j          ;
ulation; provide access to TRI data about chemical releases (under
EPCRA section 313); and receive risk management plans from indus-
try and then make them available to state and local agencies and
the general public. Additionally, EPA Regional offices will imple-
ment all or part of the risk management program in states that have
chosen not to seek formal delegation from EPA to implement the
RMP program.

The states, through the SERCs, provide EPCRA leadership to ensure
that an emergency planning and EPCRA implementation structure is
developed and to provide training and technical assistance to com-
munities.  Under the Clean Air Act, state (as well as local and
regional) air permitting agencies issue permits to some facilities
that are also covered by the RMP regulation.  In addition, EPA will
delegate to interested states and local agencies the authority to
implement the RMP program - this is already happening in
Georgia, Florida, North Carolina, South Carolina, New Jersey,
California, Puerto Rico, and the Virgin Islands. Some SERCs are
involved in implementingthe RMP program.

At the local level, LEPCs carry out the emergency planning and
community right-to-know requirements of EPCRA. First responders
(who are typically represented on LEPCs) implement contingency
plans when response to a chemical accident  is necessary. LEPCs
will increasingly be a source of information about chemical  risks in
the community, as information  under the RMP regulation becomes
available in Risk Management Plans.

    A major role for LEPCs is to work with industry and the inter-  J
    ested public to encourage continuous attention to chemical   {
    safety, risk reduction, and accident prevention by each heal  }
    stakeholder.                                           I

The public can  get involved by increasing its awareness and
understanding of chemical hazards and supporting actions to
ensure public safety and protection of the environment.


The RMP regulation (HO CFR part 68) is designed to prevent acci-
dental releases to the air of substances that may cause immediate,
serious harm to public health and the environment and to mitigate
the effects of releases that do occur. The regulation is available
from EPA. Call the RCRA, Superfund and EPCRA Hotline at (800)
H24-9346 or visit EPA's website at http://www.epa.gov/ceppo.

What Chemicals Are Covered?

The RMP regulation applies to processes at facilities that have more
than a threshold quantity of any of 77 acutely toxic substances,
such as chlorine and ammonia, and 63 highly volatile flammable
substances, including propane. These substances are called "regu-
lated substances"  in this booklet to distinguish them from chemi-
cals on other lists.

Most of the acutely toxic regulated substances are also extremely
hazardous substances (EHSs) under EPCRA section 302. The flam-
mable regulated substances are all subject to reporting under
EPCRA sections  311 and 312. Each toxic regulated substance is
assigned a threshold quantity under the RMP regulation that is
generally higher than the threshold planning quantity for the same
substance under EPCRA.  All flammable regulated substances have
a threshold quantity of 10,000 pounds under the RMP regulation,
the same as the threshold for these substances under EPCRA sec-
tions 311 and 312.  The list of RMP regulated substances and thresh-
olds is provided at the back of this booklet.

The RMP thresholds are applied to individual "processes" at a reg-
ulated facility, while EPCRA thresholds are applied to the site as a
whole. A process, as defined by the RMP regulation, means any
activity involving a regulated substance, including any use, storage,
manufacturing, handling, or on-site movement of such substances,
or combination of these activities. Any group of vessels that are
interconnected,  or separate vessels that are located such that a reg-
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ulated substance could be involved in a potential release, is consid-
ered a single process. Consequently, there may be some facilities in
your community that report under EPCRA for a specific substance
and might appear to meet the threshold quantity under the RMP
regulation as well, but in fact are not subject to the RMP rule
because they do not have a threshold quantity in a single process.

What Facilities Are Covered?

EPA has estimated that about 69,000 facilities are potentially sub-
ject to the regulation, including manufacturers, warehouses, retail
businesses, and public facilities. The rule does not apply to trans-
portation, including pipelines. Regulated substances present in
gasoline, when in distribution or related storage for use as fuel for
internal combustion engines, also are not covered.  In addition, the
rule provides an exemption for the use of ammonia by farmers as a
fertilizer (although not for those businesses that produce or sell
ammonia to those farmers).
  Examples of specific operations that tnay be regulated
  under the RMP rule:                 '
      Manufacturers of inorgan-
      ic chemicals and industri-
      al gases
      Manufacturers of plastics,
      resins, and organic chemi-
      Manufacturers of agricul-
      tural chemicals
      Petroleum refineries and
      gas processing plants
      Metal and equipment
      Food businesses with
      large ammonia refrigera-
      tion systems
      Propane retailers and dis-
Pulp amd paper mills

Larger industrialfacilities
and institutions jhat store
propane for use|as fuel

Agricultural retajlers who
sell ajmmonia fertilizer
     I         \
Largejr water treatment
and vj/astewateritreatment
systefns       ,
     !         i
Refrigerated warehouses,
warehouses that handle
chemicals, and chemical
distributors    '

Electitic companies

Large U.S. military and
Department of Energy
installations   :

 What Must a Facility Do?

 There are five main elements of facility compliance with the BMP
 regulation:                                               ,
 (1) A hazard assessment;

 (2) A management system;

 (3) A prevention program;

 (H) An emergency response program; and                    1

 (5) A Risk Management Plan (RMP) that describes these activities.

 The first four elements are described here. The Risk Management
 Plan is described in more detail in the next chapter.

 Hazard Assessment

 The hazard assessment consists of two components:
 (a) A five-year history of serious accidents involving the regulated
    substances. Every covered facility must provide detailed infpr-
    mation on any serious accident that occurred in the previous
    five years and had specific impacts either on the site or in the
    surrounding community.

 (b) Descriptions of one or more potential accidental release sce-
    narios involving the regulated substances. Every facility must
    analyze the potential offsite consequences of a worst-case (cat-
    astrophic) release.

 EPA has defined the parameters of a worst-case scenario (such a;s
 atmospheric conditions, endpoints, and release criteria) for this
 analysis. In addition, if the worst-case scenario could impact the
 public, one or more alternative releases that are more likely to
occur must be examined. (Some of these special terms are
explained in the section of this booklet called "More on Offsite  ;
Consequence Analysis.")                                   ;

 For each release scenario, the facility must estimate the greatest
distance from the facility to a point beyond which no serious acute
effects are anticipated. The facility must also identify the popula-
tions and environments potentially affected.

Management System

Every facility that has a worst-case analysis showing potential off-
site impacts is required to develop a management system to over-
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facility suqject to tne
tion. to coordinate its
see the implementation of the Risk Management Program elements.
The management system provision also requires the facility to des-
ignate a qualified person or position with overall responsibility for
the development and implementation of the risk management pro-
gram elements and to document the names of people or positions
and define lines of authority.

Prevention Program

The main objective of the Risk Management Program regulation is
to prevent accidents from occurring, and  this is done by ensuring
that every covered facility implements a  chemical accident preven-
tion program. To do this, the facility must understand its hazards
and integrate safety  into all aspects of its processes and business.
The facility must make safety a way of life so that the risk from
chemical accidents to employees and the public is minimal. The
prevention program must be implemented on a daily basis if it is to
achieve its goal—no chemical accidents.

The prevention program is intended to formalize a series of man-
agement practices for identifying hazards and managing the risk of
a chemical accident. A good prevention  program focuses on hazard
analysis, process controls, operating procedures, employee training,
and maintenance activities. Not all facilities are required to devel-
op a prevention program. A facility with  only Program 1 processes
(see box on next page) is not subject to prevention program
requirements and will provide no data on its prevention activities.

Emergency Response Program

At a minimum, every facility subject to the regulation must coordi-
nate its response activities with the LEPC for its area or with local

In addition, if a facility will use its own employees to respond to
releases (for example, with a facility hazmat team), the facility must
implement a  full emergency response program that  includes a plan,
training, and  plan review and updates. The facility may choose to
develop one plan following National Response Team guidance
(available at http://www.epa.gov/ceppo) as described on page 19.
The facility must coordinate its plan with its LEPC plan.

  Facilities May Have Processes Subject to Different Risk
  Management Requirements Baited on the Different
  Risks They Present                                   ;
  Program 1 Processes                            ;     ;
      No accidental releases resulting in offsite impacts within  '
      five years of RMP submittal                  '
      No public receptors in worst-case scenario zonelandi
      Emergency response procedure:; coordinated with local  ,
      emergency organizations
  Program 2 Processes                            ;
      Not eligible for Program 1 or subject to Program $        I
  Program 3 Processes
      Not eligible for Program 1 and
      Subject to OSHA process safety management staindaid;
         or in NAICS code 32211, 32HM, 32511, 325181} 32518'8,  :
         325192, 325199, 325211, 325311, or 32532            '
Different Requirements for Different Kinds of

Facility risk management programs will vary. The RMP regulation
requires facilities to develop a program that reflects the different
levels of risk and complexity that different processes pose. A
process falls into one of three categories—Program 1, Program 2, or
Program 3—based on accident history, worst-case scenario results,
and industrial sector. In general, Program 1 processes are less com-
plex, pose less risk to the public, and have had no accidents with
offsite consequences. Program 2 and 3 processes are more complex
and have worst-case scenarios that would impact the public. The
compliance requirements for Program 1 processes are less stringent
than are the requirements for Program 2 and 3 processes, which are
also more formal.

The Risk Management Plan describes the activities that each facility
is conducting to comply with the regulation, its "risk management
program." Initial RMPs will be submitted to EPA by June 21,, 1999.
The information in the RMP will be updated every five years or
sooner under certain circumstances, including major changes to the
facility or its covered processes.  In addition, facilities will keep
additional supporting documentation on their risk management
program on site.
                                                                                           - **y«,-
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                                  What Information Is in an RMP?
                ie commt
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         the executive sum-
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               are a new

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        r"datain CAMEO.
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An RMP consists of an executive summary in text form as well as
answers to a series of questions focusing on individual elements of
the risk management program. The latter information is reported
as data, such as names, dates, multiple choice selections, and "yes"
or "no" answers.

Each RMP will contain information on the identity of the facility, its
offsite consequence analysis, five-year accident history, prevention
program, and emergency response program.

The RMP is not like a contingency plan—even though we call it a
"plan." The RMP is primarily a series of data fields with numbers,
words and phrases, and yes/no answers to specific questions. You
can use information in the data fields to understand steps the facili-
ty is taking to prevent or respond to a possible accident; for example,
there will be information about employee safety training, /nspec-
tions by non-facility personnel, equipment maintenance, and man-
agement oversight.

Executive Summary

The executive summary in the RMP is your introduction to the facil-
ity. This section includes a brief description of the facility, its pri-
mary operations and processes, and the regulated substance(s)
handled. The executive summary also reviews the release scenar-
ios from the offsite consequence analysis; general and chemical-
specific release prevention activities; the five-year accident history;
the emergency response program; relevant facility response and
prevention policies; and any planned changes to improve safety.


The registration section in the  RMP provides information about the
facility (e.g., street address and emergency contacts) and the
processes in which regulated substances are found.  The facility-
specific data include points of contact for emergencies and risk
management program questions as well as standard address infor-

For each covered process, the registration section lists the regulated
substances (and quantities) in the process, the program level of the
process, and the North American Industry Classification System
(NAICS) code for the process. The NAICS code identifies what the
process does (for example, water treatment or metal plating).
These data will help you identify specific operations at a facility or
compare them with similar operations elsewhere.

 Offsite Consequence Analysis

 Facilities with any Program 1 processes must include at least one
 worst-case release scenario in their RMPs. Facilities with Program 2
 or Program 3 processes must include in their RMPs information
 about both worst-case release and alternative release scenarios.
 The number of scenarios depends in part on the type and number
 of regulated substances in covered processes. EPA has defined
 many of the release modeling parameters for the scenarios,
 although some facility-specific data (for example, certain weather
 conditions) can be used.

 In the RMP, facilities report the modeling parameters and disper-
 sion model(s) that they used to do their offsite consequence analy-
 ses. You can use this information to "re-create" a facility's results,
 using CAMEO and ALOHA, EPA's Offsite Consequence Analysis
 Guidance, or RMP*Comp (available at http://www.epa.gov/ceppo).
 For each release scenario, facilities report in the RMP the distance
 beyond which no serious, acute effects are anticipated; the residen-
 tial population within that distance (in  all directions from the point
 of release); and which categories of public receptors (for example,
 schools, residences, hospitals, commercial/industrial areas) or envi-
 ronmental receptors (national/state parks, wildlife sanctuaries, and
 federal wilderness areas) are located within that  distance. Facilities
 may choose to submit a graphic file to illustrate each scenario on a
 local map.

 Five-Year Accident History

 The accident history that facilities report in their  RMPs provides
 information on each accidental release from a regulated process
 that resulted in specific on-site  or offsite impacts during the pre-
 ceding five years,  in greater detail than the EPCRA section 30H
 reports that you have received in the past. Releases from non-cov-
 ered processes, even if they involved regulated substances, or
 releases of non-listed substances from  covered processes, are not

 For each accidental release reported in the accident history section
 of the RMP, facilities report standard descriptive information, as
well as some new information such as the weather conditions, on-
site and known offsite impacts,  the initiating event and contributing
factors, whether offsite responders were notified, and any changes
made at the facility as a result of the accident.

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Prevention Program

In the BMP, facilities report prevention program information sepa-
rately for each covered process. This section of the RMP identifies
the major hazards for the process; the relevant process controls,
mitigation systems, and detection and monitoring systems; and any
changes made to the process since the last hazard evaluation. This
section also provides dates indicating when specific prevention
activities (for example, updates of procedures) were last conduct-
ed. This information provides a basis for comparing similar opera-
tions at different facilities.

Facilities must retain a substantial amount of supporting documen-
tation to comply with program requirements of the RMP regulation.
While facilities are required to make this documentation available
to EPA or the state implementing agency, they are not required to
make it available to the public. If certain items are of interest to you
or to members of the public, you may want to talk to facilities about
making this information available. Much prevention program docu-
mentation will relate to internal tracking or standard work records,
but there will also be hazard review or PHA (process hazards analy-
sis) recommendations, compliance audit reports, and accident
investigation reports. EPA is encouraging facilities to make as much
of this information as possible (or some form of summary) avail-
able to the public if requested. Because the RMP regulations
expand the information collection authority granted to LEPCs under
EPCRA section 303(d)(3) to apply to facilities with flammable regu-
lated substances, the LEPC can get any of this information that is
necessary to develop an emergency plan.

Emergency Response Program

The RMP does not provide detailed information on the facility
emergency response program. There is a series of yes/no ques-
tions indicating whether the facility has a response program and
also some dates indicating when specific activities (for example,
drills or exercises, plan review) were last conducted. Facilities that
have chosen to develop their own response capability will keep an
emergency response plan and procedures on site. As noted above,
the LEPC can request this information from all facilities subject to
CAA section 112(r) in developing an emergency plan.

Confidential Business Information

 Facilities can claim some RMP data as confidential business infor-
 mation (CBI). An LEPC interested in obtaining data claimed CBI may

 request that EPA determine whether the claim is valid. If EPA deter-
 mines that the information is not CBI, and after EPA has notified the
 facility claiming CBI, the information may be released. If EPA deter-
 mines that the information is CBI, an LEPC may nonetheless be able
 to obtain the information under 40 CFR 2.301{h){3), which provides
 for sharing of CBI with state and local governmental agencies hav-
 ing responsibilities under the CAA or its implementing regulations.
 However, LEPCs can gain access to CBI data under this rule only if
 they can protect  its confidentiality.

 Under EPCRA section 303(d}(3), LEPCs may compel an EPCRA sec-
 tion 302 facility to provide any information necessary to enable the
 LEPC to develop and implement an emergency plan. An EPCRA sec-
 tion 302 facility must comply with such LEPC requests for informa-
 tion even  if the facility has made a valid CBI claim under the RMP

 How Can LEPCs Access RMPs?

 EPA will place RMPs, except for the offsite consequence analysis
 information, on the Internet in a format that will allow the public to
 search them and  download any that are of interest.  This database,
 called RMP*lnfo,  will be located with other EPA data in Envirofajcts
 on the Internet at http://www.epa.gov/enviro beginning in the
 Summer of 1999.

 To simplify access by state and local governments, EPA will set up
 separate databases containing the full RMPs for all of the facilities
 in each state. Additionally, in  the Fall of 1999, EPA will finalize
 RMP*Review, software for use by implementing agencies, LEPCs,
 and others to manage their databases.  Please contact your EPA
 Regional Office CEPP contact for details (see Appendix B).


 Not all LEPC members may have an extensive technical background,
but you will want  to (1) understand how a facility derives its worst-
case and alternative release scenarios and (2) be familiar with the
underlying terminology. The following are answers to some of
EPA's most frequently asked questions.
Q: What Is Meant by a Worst-case Release Scenario?

   EPA has defined a worst-case release as the release of the
   largest quantity of a regulated substance from a single vessel or

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   EPA requires that the worst-case release scenario incorporate
   certain parameters related to the chemical released, conditions
   of the release, atmospheric conditions, and health effects of
   concern ("toxic or flammable endpoints"). Facilities use these
   parameters to estimate the distance away from the location of a
   release beyond which no serious, acute effects are anticipated.
   These parameters are discussed in more detail below.

Q: What Is Meant by an Alternative Release Scenario?

   The RMP regulation requires Program 2 and 3 facilities to pro-
   ject potential releases of regulated substances that are more
   likely to occur than worst-case scenarios and to predict the con-
   sequences of such releases. These are called alternative
   release scenarios.  The RMP regulation provides information
   that facilities must use for such predictions as part of doing the
   offsite consequence analysis required for the risk management
   program at the facility.

Q: What Is a Toxic Endpoint?

   A toxic endpoint is the endpoint for a regulated toxic substance.
    For a particular regulated substance, it is the concentration of
   that substance in air below which it is believed that most peo-
    ple could be exposed for up to one hour without serious health
    effects. EPA has determined toxic endpoints for each of the
    regulated toxic substances. The toxic endpoints are listed in
    the RMP regulation.

 Q: What Is a Flammable Endpoint?

    A flammable endpoint is the endpoint for a regulated flamma-
    ble substance.  How it is measured depends on the type of
    release considered. For example, the flammable endpoint for a
    vapor cloud explosion is based on the pressure from the result-
    ing blast wave. The flammable endpoints to use for different
    types of releases are provided in the RMP regulation.

Q: What Is a Stability Class?

    Pasquill stability classes (ranging from "A" to "F") are meteoro-
    logical categories of atmospheric conditions. Pasquill stability
    class A represents unstable conditions under which there are
    strong sunlight, clear skies, and high levels of turbulence in the
    atmosphere, conditions that promote rapid mixing and disper-
    sal of airborne contaminants. At the other extreme, class F rep-

    resents light, steady winds, fairly clear nighttime skies, and low
    levels of turbulence. Airborne contaminants mix and disperse
    far more slowly with air under these conditions, and may travel
    further downwind at hazardous concentrations than in other
    cases. Stability class D, midway between A and F, is used for
    neutral conditions, applicable to heavy overcast, daytime or

 Q: What Is the Distance that Facilities Must Estimate for Their
    Release Scenarios?

    Facilities must estimate the distance from the location of a
    release to the endpoint that could result from the accidental
    release of a regulated substance. They  must estimate this dis-
    tance for each release scenario  in their RMP. To understand
    what populations could be at risk from an accidental release,
    the facility is to draw a circle with the facility at the center. The
    radius of the circle is the distance to the endpoint.

 Q: How Is The Distance to an Endpoint Estimated?

    Facilities estimate the distance to an endpoint by first estimat-
    ing the amount of a regulated substance that would be released
    in an incident (either a worst-case release scenario or an alter-
    native release scenario), and then using air dispersion model-
    ing techniques {or a tool that incorporates such techniques) to
    estimate the distance to an endpoint for that amount of the reg-
    ulated substance.  Note that the distances that facilities report
    in their RMPs are estimates. EPA has guidance documents
    (Offsite Consequence Analysis Guidance as well as industry-
    specific guidance for developing RMPs) and software
    (RMP*Comp) to help facilities estimate the distances. Facilities
    may use EPA's guidance or any other air dispersion modeling
    techniques provided that the techniques meet certain condi-
    tions as outlined in the RMP regulation.

Q:  What Is Meant by Air Dispersion Modeling Techniques?

    Air dispersion modeling techniques are mathematical models
    that are used to estimate the distance that a released substance
    would travel from the location of the release to the endpoint,
    given the amount of the substance released and certain condi-
    tions of the release. The estimated distance will vary depend-
    ing on the air dispersion model used.

Q:  How Certain Is The Distance to The Endpoint?

    For a  given scenario, people can use different release models
    and obtain predictions of the distance to an endpoint that may
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   vary significantly. Even using the same model, different input
   assumptions can cause wide variations in the predictions.

   LEPCs need to recognize that the predicted distances lie within
   a considerable band of uncertainty and communicate this fact
   to the public when they discuss the scenario results.
   Differences in models may explain why two facilities handling
   the same covered substances in the same amounts may have
   come up with different results. (Of course, differences in pre-
   vention programs may also account for different results, partic-
   ularly in the case of alternative release scenarios.)  EPA's
   approaches are generally intended to produce conservative
   results—they are more likely to overestimate distances. For
   other models, you may want to ask the facility for an assess-
   ment of where its distance prediction lies v/ithin the plausible
   range of uncertainties.

Q: If There Is an Accident, Will Everyone Within the Distance to the
   Endpoint Be Hurt?

   In general, no. For an explosion, however, everyone within the
   circle would certainly feel the blast wave because it would
   move in all directions at once.  However, while some people
   within the circle could be hurt, it is unlikely that everyone
   would be.  But releases usually do not lead to explosions. A fire
   is more likely than an explosion, and fires are usually concen-
   trated at the facility.

   For toxic chemicals, the released chemicals would usually move
   in the direction of the wind. Only people in a small fraction of
   the circle would be exposed if a release occurred. Whether
   someone is hurt depends on many factors, such as whether the
   chemical is dispersed by the wind, or if the release is stopped

    Generally, it is the people who are closest to the facility who
    face the greatest danger. Although it is not impossible for peo-
    ple beyond the distance to the endpoint to be hurt, it is much
    less likely. However, the risk should not be dismissed. The
    RMP regulation assumes that a worst-case release involves the
    failure of the single largest vessel containing a regulated sub-
    stance at the facility.  It is conceivable, although highly unlikely,
    that more  than one vessel could fail at the same time, resulting
    in a larger release than the worst-case scenario predicts. In
    such a case, people beyond the distance to endpoint could be

 Q:  How Likely Are the Worst-case and Alternative Release

    It is generally not possible to provide accurate numerical esti-
    mates of how likely it is that these scenarios will actually hap-
    pen. Quantifying risk for accident scenarios is rarely feasible
    because there are few data related to rates for equipment fail-
    ure and human error.

    In general, the risk of a worst-case scenario occurring is low.
    Although catastrophic vessel failures have occurred, they are
    rare events. Combining them with worst-case weather condi-
    tions (as required by the BMP regulation) makes the overall
    scenario even less likely. This does not mean that such everits
    cannot or will not happen, but they are very unlikely to happen.
    For the alternative scenario, the likelihood of the release is
    greater and will depend, in part, on the scenario chosen.

Get Everyone Involved

LEPCs should have broad-based membership that includes, at a
minimum, representatives of elected officials, law enforcement,
emergency management, fire service, emergency medical services,
healthcare professionals, local environmental and transportation
groups, hospitals, the media, community groups, and owners arid
operators of the facilities covered under EPCRA.

Wide-ranging community involvement will increase the credibility
of the LEPC plan and improve community cooperation in an emer-
gency. Both EPCRA and the RMP regulation assume that citizens
want chemical safety in the community. Including concerned citi-
zens on the LEPC and inviting them to your meetings will promote
communication between industry and the public, foster under-
standing of chemical hazards, and help quell rumors.

Enhancing LEPC-Industry Relations;
Encouraging  Compliance

Since EPCRA passed in 1986, a rule of thumb is that effective LEPCs
include active and committed industry representatives.  Industry
representatives bring expert understanding of chemicals and chem-
ical processes. Numerous facilities have provided financial and
other support to make LEPCs successful.
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The RMP regulation provides specific opportunities for you to work
more closely with the facilities in your community on risk commu-
nication, accident prevention and risk reduction, and compliance
assistance. (See the later sections for discussions of risk communi-
cation and accident prevention.) As you work with facilities
through these and other issues, you may become the organization
they turn to when they need to understand community concerns
and help in providing constructive answers to questions from the
public. In helping them, you can work to ensure that  they address
community issues related to chemical safety quickly and accurately,
which will, in turn, make your LEPC the group on which the commu-
nity relies.

Depending on the skills of your membership, the LEPC may be able
to serve as a local source of RMP compliance assistance.  Although
you may not want to become involved with more technical issues,
almost all of the RMP program elements are well-suited to your

Release Modeling

EPA has provided free copies of CAMEO (a software program that
helps LEPCs manage and interpret information about a facility and
its chemical inventory) to more than 2,000 LEPCs. Using ALOHA
and  LandView (a software program that provides Census Bureau
data and helps users map facilities and nearby populations), LEPCs
can now assist facilities in conducting the offsite consequence
analysis required by the RMP regulation. Small businesses will
appreciate help in collecting and entering their release modeling
data and identifying public and environmental receptors that could
be impacted by a release. LEPCs can then  incorporate this updated
facility information into the community plan.

Users should be aware, however, that ALOHA has some limitations
which may make it unsuitable for RMP offsite consequence analysis
modeling in certain situations. For example, ALOHA  does not have
the capability to model the offsite consequences of flammable sub-
stance releases, and for toxic substances, ALOHA only provides
endpoint distances out to a maximum of 6 miles from the source
 (large releases of certain chemicals, such as chlorine, will exceed
this distance under worst-case conditions). If you desire to conduct
 RMP OCA modeling in these and other situations for which ALOHA
 is unsuitable, you should use a different model.

 One such model is RMP*Comp. RMP*Comp is a software program
 designed by EPA and the National Oceanic and Atmospheric

Administration (NOAA) specifically for the purpose of conducting
RMP OCA modeling. It follows the methods and techniques
described in EPA's RMP Offsite Consequence Analysis Guidance.
RMP*Comp is capable of providing OCA modeling results for all 140
RMP regulated substances and provides endpoint distances opt to a
maximum of 25 miles. RMP*Comp is available for free—you can
download it from the Internet (http://www.epa.gov/ceppo) or order
a copy from the National Service Center for Environmental            ^
Publications (NSCEP) at 1-800-490-9198.

Working with Small Businesses

Local planning and response officials can help small businesses
sort out facility-specific preparedness issues, identify response
resources, and formalize their emergency response program. The
RMP regulation also may serve as an incentive for facilities to adopt
the "One Plan" approach and formalize incident command issues.
This provides a perfect opportunity to discuss mutual aid agree-
ments and joint training and exercise programs.

Response Coordination

Facilities that do not have their own response team must coordinate
with the LEPC concerning listed toxic chemicals, and with the fire
department about listed flammable chemicals. Local fire officials,
in conjunction with the building inspector, can work with facilities
to improve fire prevention practices, including compliance with
NFPA standards or other fire and related codes.                      tf||
Industry Outreach

LEPC industry representatives can provide other facilities with
technical assistance or contacts for further information on a variety
of prevention program issues. Assistance could include explaining
issues related to the OSHA Process Safety Management (PSM)  '
Standard (a regulation requiring certain facilities to implement-acci-
dent prevention activities similar to those described on page 8) or
help in collecting and understanding safety information, industry
safety standards, or approaches to employee training and equip-
ment maintenance.
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New Partnerships

The availability of RMP information also provides LEPCs with ah
opportunity to develop new partnerships with other organizations
in the community. People and groups may need to be reminded
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that you have available much specific information about chemicals
in your community. Although they may not be interested in the
entire RMP, medical professionals, the news media, planning/zon-
ing officials, and researchers will likely find specific sections of the
RMPs from local facilities of particular interest. Working with them
will further extend the reach of the LEPC into the community, creat-
ing a stronger constituency for the LEPC that enables you to take
advantage of a wider base of skills and experience.

Medical professionals (including emergency medical technicians,
doctors in private practice,  health clinics, and hospitals) will appre-
ciate information on potential acute health hazards as well as the
recommended treatment for exposures. Distributing a list of nearby
facilities and their regulated substances can assist in the first step; if
the medical professionals are interested, you can request a copy of
the emergency response plan and then selectively send out the first
aid and emergency medical treatment information. At the same
time, keep in mind that clinics and hospitals will want to know if
they are potentially vulnerable to an air release;.

The news media can play an effective role in risk communication.
If you do not already have regular representation from local news-
papers and radio and television stations on your LEPC, this is a
great time to get them involved. Once the RMPs are available in the
summer of 1999, you will be in position to work with the news
media to spread the risk reduction message in your community.

You might consider producing press packets to help the local news
media understand and use RMP information. At the same time, you
can describe the other related activities of the LEPC and get addi-
tional exposure for efforts such as commodity flow studies and
field exercises.

You may have multiple audiences within the news media. While
news reporters with an interest in environmental, public safety, and
health issues will likely find RMP information intriguing, broadcast
meteorologists may actually be the best people for discussing the
dispersion of air releases with the public.

The accidental release scenarios in the offsite consequence analy-
sis will provide local planning and zoning officials with more
information when they address development issues. Being aware
that a new school, hospital, residential area, or shopping center
could be directly affected by a facility using an acutely toxic or
highly flammable substance can only improve the decision-making

                                                                - -
Engineering and environmental professionals, and researchers
at local colleges and universities, are likely to find RMP information
of even greater interest than EPCRA and other environmental data.
If there are specific operations or types of facilities of significant
concern to the community, these individuals may be willing to share
with you the burden of analyzing the relevant data and communi-
cating it to the public.

Talk with Neighboring Communities

Consult with your neighboring LEPCs, especially if you have com-
mon chemical risks and concerns.  If two or more adjacent localities
have similar facilities or facilities affecting more than one LEPC, you
can split up the work of collecting and comparing RMP information.
Using fewer resources, you will be able to produce results and
share them with others. Such efforts can also serve as the basils for
risk reduction and further coordination, including joint training and
field exercises, mutual aid agreements, and pooling of financial
resources to accomplish larger-scale initiatives.

In an emergency, you may have to call on neighboring communities
for help or they may call you.  In many cases, contingency plans
must include several communities to be effective. Consider the
need to:
(I)  Identify whom to call in other planning districts if you need
    help in an emergency;

(2)  Ask them how they are funding their activities;

(3)  Identify available response equipment and personnel;

(H)  Negotiate procedures for mutual assistance for emergencies
    that cross boundary lines;

(5)  Coordinate your hazards analyses;

(6)  Coordinate your review of transportation routes; and

(7)  Investigate sharing computers or other resources.

In addition to these planning and response activities, talk to your
neighbors about steps you can take together to prevent chemical
accidents. You might go together to visit a facility that has a note-
worthy safety record.  You might invite an expert in process safety
management to speak to a joint meeting of your LEPCs (and invite
the public to attend!).
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   Each Lf PC should consider its neighboring LEPCs as partners \
   and sources of help. Other LEPCs share your problems;      }
   working with them may help you find common solutions.    «


Both the EPCRA and RMP regulations provide an opportunity to
promote and strengthen dialogue between the community and
industry on accident prevention and chemical emergency pre-
paredness issues. Risk communication is an opportunity to build a
level of trust among the LEPC, companies with hazardous chemi-
cals, and the community at large.

   One of the most important factors that affects people's per-
   ceptions about risk is whether they feel in control. Offer
   people a means to participate in decision-making about
   chemicals in the community. Because LEPCs include repre-
   sentatives from government, industry, and citizen groups,
   they offer a good setting for encouraging the different inter-
   ests to work together.

Keep in mind the importance and legitimacy of public concerns
about chemicals in the community.  People generally are less toler-
ant of risks they cannot control than of those they can. For example,
most people are willing to accept the risks of driving because they
have some control over what happens to them. However, they are
generally less comfortable accepting the risks of living near a facili-
ty that handles hazardous chemicals if they feel that they have no
control over whether the facility has an accident. The Clean Air
Act's provision for public availability of RMPs, along with EPCRA's
requirements for providing annual reports on hazardous chemicals,
gives the public an opportunity to take part in reducing the risk of
chemical accidents that might occur in your community.

Interested citizens may independently obtain RMPs (except for
CBI). These citizens might then ask LEPCs to explain the informa-
tion in the RMPs. Although it often is left to technical experts, edu-
cating the public about risks and involving them in decisions about
what is an "acceptable" level of risk are important challenges for

Basic Rules of Risk Communication

Risk communication means establishing and maintaining a dia-
logue with the public about the chemical hazards in your communi-

ty and discussing the steps that have been or can be taken to
reduce the risk posed by these hazards. There are seven "rules" of
risk communication that have been developed based on many
experiences of dealing with the public about risks.
(1) Accept and involve the public as a legitimate partner

(2) Plan carefully and evaluate your efforts

(3) Listen to the public's specific concerns

(H) Be honest, frank, and open

(5) Coordinate and collaborate with other credible sources

(6) Meet the needs of the media

(7) Speak clearly and with compassion

    There is an informal eighth rule for risk communication:
    Know what you are  talking about. Not everyone on the LEPC
    will know everything about hazardous chemicals. Call on  \
    chemical engineers, health professionals, scientists, and
 j  school teachers (e.g., science, chemistry) to help you. Retired
{  professionals are frequently helpful.

Hazards Versus Risks

Hazards are inherent properties that cannot be changed. Chlorine
is toxic when inhaled or ingested; propane is flammable.  There is
little that you can do with these chemicals to change their toxicity
orflammability. If you are in an earthquake zone or an area affect-
ed by hurricanes, earthquakes and hurricanes are hazards. When a
facility conducts its hazard review or process hazards analysis.it
will identify hazards and determine whether the potential expo-
sure to the hazard can be reduced in any way (e.g., by limiting the
quantity of chlorine stored on-site).

Risk is usually evaluated based on several variables, including the
likelihood of a release occurring, the inherent hazards of the chem-
icals combined with the quantity released, and the potential impact
of the release on the public and the environment. For example,^ if a
release during loading occurs frequently, but the quantity of chemi-
cal released is  typically  small and does not generally migrate offsite,
the overall risk to the  public is low (even though workers may be at
risk). If the likelihood of a catastrophic release occurring is
extremely low, but the number of people who could be affected if it
occurred is large, the overall risk may still be low because of the low
probability that a release will occur. On the other hand, if a release
occurs relatively frequently and a large number of people could be
affected, the overall risk to the public is high.

%  ff. ^

The RMP regulation does not require facilities to assess risk in a
quantitative way because, in most cases, the data needed to esti-
mate risk levels (for example, one in 100 years) are not available.
Even in cases where data such as equipment failure rates are avail-
able, there are large uncertainties in using those data to determine
a numerical risk level for any given facility. Therefore, you may
want to assign qualitative values (high, medium, low) to the risks
that you have identified at facilities in your community, but you
should be prepared to explain the terms if you do. For example, if
you believe that the worst-case release is very unlikely to occur,
you must give good reasons; you must be able to provide specific
examples of measures taken to prevent such a release, such as
installation of new equipment, careful training of workers, and rig-
orous preventive maintenance. You can ask facilities to provide
documentation to support claims about the level of risk.

Three Scenarios When You May Need to
Communicate with the Public about Chemical

Scenario A:   During or immediately after an accidental
chemical release

When there is an accident, the news media and the public always
have questions. First they might ask:
    What is going on?

    Am I or my children at risk?

    Should we evacuate or shelter in place?

•   What are you doing to stop this accident from spreading?

A little while later, they might ask:
    How did this happen?

    How long will we feel "short-term" health effects?

    Are there any hidden health effects?

•   What are you doing to prevent this from happening again?

To answer questions like these, you will need to have a community
emergency plan and know the contents of that plan. Do you have a
record of chemicals in the community and what their potential
health effects are? Do you identify an emergency contact for each
facility in the community? Does your emergency plan include clear

provisions for determining whether evacuation and/or sheltering
in-place might be necessary? Has one person (or office) been
assigned to provide information to the public?  Have you prepared
sample press releases so that you can quickly provide helpful;
information to the public? Do you have procedures for telling the
public about upcoming LEPC meetings so that the public can attend
and ask questions? Have you worked with the mayor's office alnd
local response agencies to ensure that the LEPC is the focal point
for risk communication?
Scenario B:
Routine or past accidental releases ofchemi-
After accidental releases, the news media and the pubic may
become more interested in chemical hazards in the community.
They may search the Toxic Release Inventory (TRI) available under
EPCRA section 313 for more information about chemical releases.
After June 1999, they may search for information provided under
the RMP regulation about accidental releases during the past five
years. This search could lead to newspaper articles and television
reports about chemicals being released in the community. You may
then hear questions like these:
    What risk do these exposures pose for my family?

    Do these emissions affect our health?

    Why are facilities allowed to release these chemicals?    i

    Is the facility in compliance with federal, state, and local laws?

•   Are there other facilities that should be reporting similar
    events?                                             ,

The LEPC might take several actions. Invite a toxicologist or a doc-
tor to an LEPC meeting to discuss specific chemical hazards with
the public. Share your information about other facilities 5n the
community. Share information on the risk management program
regulation and EPCRA.  Invite the facility emergency coordinator to
explain steps the facility takes to prevent serious accidents even
though there are routine releases.  Work with facilities to take
action to reduce risk.                                     '.
                                                                          ^TUJSS^      x >8gF* ^ * ?


Inlilll PI BlllI*

Scenario C:   Chemicals Stored in the Community

The search of TRI and RMP databases could eventually lead to sto-
ries about all the chemicals stored in the community. The public
and the news media may then ask questions like these:
   Are the chemicals stored properly?

   What are the chances of dangerous chemicals leaking?

   Can these stored chemicals lead to an accident?
    If these chemicals are released, what could be the health

   Can we reduce the amount of chemicals stored in the com-
   munity, and use less hazardous chemicals and inherently safe

   What else can we do to reduce the risk of accidents?

In this instance, the LEPC can turn to all the data it has collected
from EPCRA and RMP reports. These questions can be more easily
addressed if you have one software program like CAMEO to man-
age data. You may also want to hold a meeting that includes facility
representatives so that everyone can discuss realistic steps to pre-
vent accidental chemical releases in the community.

A Special Case: Dealing with Worst-Case

In the beginning, public interest might focus on the worst-case sce-
nario, rather than on prevention and preparedness.  Worst-case
scenario information must be explained to the public in a way that
promotes perspective and understanding, rather than confusion.
The experience of the heavily industrialized  Kanawha Valley of
West Virginia illustrates how worst-case scenario data can open
lines of communication between  industry and the public. Despite
fears that information on worst-case scenarios would produce
strong negative reactions toward  local industry, the chemical indus-
try worked with EPA and state and local officials to release worst-
case data well ahead of the RMP rule schedule. The Safety Street
demonstration proved that the public could understand informa-
tion on potential accidents and risks and act constructively. Due in
part to a pro-active approach by industry, and with the sponsorship
of the LEPC, the public evaluated the information presented to the
community and was able to take part in a constructive dialogue
with industry and public officials.

  Potential Risk Communication Activities
  1. Open a risk management dialogue
  with facility owners/operators, com-
  munity leaders, and the public to
  focus on risk reduction activities.

  2. Understand how the public will
  access information and what impact
  this will have.

  3. Reach out to the small business
  community. Many small facilities
  will hot have the expertise or
  resources to respond effectively to
  the technical questions that their
  RMPs may produce. By reaching out
  to them, you can help develop a
  more community-wide approach to
  addressing risk management ques-
  H. Identify key issues of concern in
  your community. Use LEPC meetings
  as a forum to collect and document
  concerns, which then can be for-
  warded to individual facilities, as
5. schedule follow-up meetings or
presentations at other public gath-
er ngs to allow LEPC aind ir dustry
re sresentatives to responc to these
6. Draw upon sample ques ions and
answers contained in, the F isk
Ccmmunication chapter of EPA's
General Guidance on Risk
Management Programs. We rk with
industry to understand the underly-
ing issues and develop an< wers to
specific questions, focusin \ on actu-
7. Plan a special meeting tcj unveil
8. pork with the news media to
reach a wider audience.
9. Explore using community bulletin
beards on local access cab e televi-
sion stations and community
In ernet sites.
Respond to Concerns
LEPC involvement creates a process through which people, who
otherwise might be mistrustful or even adversarial, can work   !
together to understand, address, and prepare for chemical risks in
the community. Sometimes, anger about what the public percejves
as risky situations arises not so much from the actual risk but from
people's feeling that they have no control over what is happening to
them. You can reduce this by including the public as a partner in
discussions about what is an acceptable risk in your community
and how to reduce risks.
An LEPC that arms itself with basic information about the BMP pro-
gram, makes an effort to look at the RMPs for facilities in the com-
munity, and encourages facilities to involve the LEPC, response
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  What You'll Find in the RMP                   !

  Based on a hazard review or proce ;s hazard analysis for each
  covered process, a facility will list in the RMP:     '

     The regulated substances in th; process;      :
     The NAICS code for the process;

     The major hazards of the chemicals (toxic release, f re,
     explosion) and of the process (ror example, overfill  ng,
     overpressurization, runaway reaction);

     The process controls in use;

     Any mitigation systems; and

     Information on whether the facility has monitoring  Dr
     detection systems.
  For Program 2 processes, the RMP will also include a list of
  industry codes and standards that :he facility complies with for
  the process.

The RMP regulation is intended to prevent chemical accidents and
mitigate the consequences of the accidents that do occur. Facilities
will take the first step in achieving this goal when they develop and
implement their risk management program, especially in the formal
elements of the prevention program. However, the availability of
RMP information (particularly the offsite consequence analysis and
the results of the hazard evaluation) is expected to encourage the
second step of this process: an ongoing dialogue between the com-
munity and industry leading to practical changes that can reduce
the risk of a chemical accident.

As with emergency preparedness, the LEPC should serve as the
forum for the community and industry on accident prevention. You
will want to meet with facility officials to discuss the offsite conse-
quence analysis, understand the facility's prevention program, and
perhaps suggest additional steps to prevent accidental chemical
releases.                                                I

Using RMP*lnfo, the national RMP database, you will be able to
gather the information necessary to compare practices at local facil-
ities with other facilities in the same industry in  your state or even
;5pariSons with a, local 'facility-^
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    r, same majoi^hazards as

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          S.^'^WV VJ, ^,  y,  -Q ^ ", ^ SSt
           systems/than si3
   -^ - lrt---i.--;*l&^If^^^'7^^T»*? ^ ^MC. *%*
   ,j* facilities UhaveT you may
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  * ^   ^^^i^q*.^  ^  •  -   -
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tlon program to draw
in other parts of the country.  RMP*lnfo will let you search on a par-
ticular chemical and NAICS code to identify other facilities that use
the same regulated substance in the same type of process as the
local facility of interest to you (for example, chlorine for water treat-
ment). Information on the number of employees will help you
focus on facilities of similar size, which will make the comparisons
more appropriate.

If you ask local facility officials in advance, they may be willing to
provide technical or other forms of assistance to help you under-
stand accident prevention techniques in specific industries.

Once you have a list of other  similar facilities, you can print out the
RMPs or parts of the RMPs for these Facilities and compare them to
the RMP for your local facility. (This could even be a good research
project for students at the local high school!)

You may be pleasantly surprised by the results of your work; you
may find that your local facility is among the best in the nation. On
the other hand, if the local facility does not have certain process
controls or a detection system typically used by similar facilities, or
if it stores ten times as much  of the regulated substance as anyone
else, you have some solid information with which to start a dia-
logue on risk reduction.

In addition, keep in mind this is the first time that these types of
data have ever been collected on a national basis. In some cases,
local facilities may be very interested in what you find. Based on
the prevention programs of similar facilities in  other parts of the
country, local facilities may initiate state-of-the-art accident preven-
tion practices.


Now that you have an idea of how you can become involved in the
Risk Management Program and accident prevention, you may have
a few questions about how to proceed. The following are sugges-
tions to help you identify resources for information, funding, and
legal issues.                                            '

Funding Your Activities

Some states and communities have appropriated general revenue
funds for LEPC activities; others are relying on implementation fees
and existing state agency budgets. Because states have limited
resources, each LEPC must find the means for achieving its goals.
Some LEPCs will do their work with little funding.  Your LEPC mem-
bers may already be donating their time.

EPA's Chemical Emergency Preparedness and Prevention (CEPP)
Technical Assistance Project Grants offer funding for state, local, and
Tribal agencies for implementing the Risk Management Program
and for developing the underlying support system. Awards are
made using the Clean Air Act Section 112(1)(H) and Section   :
103(b)(3) authorities. These authorities allow EPA to award grants
related to the Risk Management Program directly to local govern-
ments.  The grantee must provide matching funds equal to 25 per-
cent of the total project cost. To obtain further information on the
CEPP grants, contact CEPPO.                              ;


Some LEPCs and individual LEPC members have expressed concern
that they might be held legally liable if they approve an emergency
response plan that proves to be inadequate during an accident.
Check with your SERC about your state law and ask about liability
considerations and protection. Some LEPC members have asked
whether they invite liability issues by reviewing facility RMPs.
SERCs are generally considered state agencies and are, therefore,
covered by the state's immunity provisions. Some states have
extended this immunity to LEPCs through laws or through legal
decisions.  Others have provided liability coverage for LEPCs.
LEPCs may also be able to address liability concerns by clearly stat-
ing (1) the  limitations of any review they conduct of RMPs, and (2)
that they neither have nor assume any legal obligations for review-
ing RMPs.
           a-XT,- "$ r *%3*-~*".. v.%, ,s
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                                             Risk Management Program  Resources
                                      Source of Information
                                                                 Location and Telephone Number
                                      BMP Implementing Agency for my state
                                      EPA Regional Contact
                                      EPA's Chemical Emergency Preparedness  http://www.epa.i3ov/ceppo
                                      mnd Prevention Office website  „_„ _„. ,
                                      The RCRA, Superfund and
                                      EPCRA Hotline
                                                                 Toll free: (&00) 424-9346
                                                                 TDD: (500) 553-7672
                                                                 Washington, DC area:
                                                                    Fax: 202-651-2061
 liilllilNf i 1 III llliiilllllliiiiiilsiiiif
                                     Handy Reference

                                     Using the table above, fill out the information that applies in your
                                     case, clip, and save for your use. For information about the EPA
                                     Regional Contact, see Appendix B.


Contents of this Section:
     A: Checklist-Ideas for Action
     B: EPA Regional Office Contacts for EPCRA
        and RMP Programs                 ;
     C: Some Background liiformation-
        Comparison of Green Book and RMP  '•
        Offsite Consequence                 ;
        Analysis (OCA) Guidance Methodology
     D: Regulated Substances-Chemicals
        Covered by the RMP Regulation and
        Their Threshold Quantities

     •  Y2K Alert
     •  Customer Satisfaction Survey        .
                                                             page A-1

 RMPs Are on the Way!


Q Visit EPA's chemical emergency preparedness and prevention
website at http://www.epa.gov/ceppo. This site contains all the up-to-
date information about both EPCRA and the RMP regulation, including
electronic copies of relevant documents.

Q Call the RCRA, Superfund and EPCRA Hotline at 1-800-H2H-93H6 for
answers to your questions and for help in getting copies of documents.

Q Identify facilities. Use the list of regulated substances at the back of
this booklet and your EPCRA section 312 reports (Tier II) to identify facili-
ties that may be covered by the new RMP regulation. Remember, though,
that EPCRA reports provide information on chemicals for the facility as a
whole, while the RMP rule applies to a facility based on how much of a
chemical it has in a single process.

Q Contact these facilities and see if they want to work with you in shar-
ing RMP information in your community.

Q Arrange public information-sharing events with interested facilities.
            Having special LEPC meetings for this purpose;
            Having local facilities host meetings that include the LEPC
            and members of the public; arid
            Organizing an event at a shopping mall or auditorium at
            which several facilities can discuss their RMP information,
            with interested local citizens.
Q Work with facilities to: reduce chemical inventories; substitute less
hazardous chemicals; use inherently safe technologies; and add new pre-
vention measures.                                             i

Q Develop a public recognition program to honor your firefighters,
police department, and other first responders for their expertise in   ;
responding to hazmat incidents. Honor facilities who have a noteworthy
accident prevention program. Honor volunteer groups like the Red Cross.

Q Recruit effective LEPC members. Check to see if inactive members
want to continue on the LEPC. If not, take this opportunity to recruit inter-
ested and effective new members. Check with your SERC and/or neigh-
boring LEPCs for ideas about new members.                       ,

Q Ensure a representative LEPC. Make sure your LEPC membership  is
 broad-based and representative of your community.

Q Leverage Resources. Organize your LEPC to use available resources
 such as students, retired chemical engineers, chemists, health profession-
 als, and trade and volunteer organizations.
                                                                                         page A-S

RMPs Are on the Way!
                                 Q Include small business representatives in your membership and
                                 invite them to meetings.

                                 Q Publicize the LEPC. Form a subcommittee with the assignment to make
                                 the LEPC better known in the community. Advertise your meetings in the
                                 newspapers and on TV and radio. Invite the news media to attend your
                                 meetings and report on them. Tell your citizens about the information
                                 you have about chemicals in the community.

                                 Q Educate the community. Form a subcommittee on public education
                                 and information to help the public understand chemical risks in the com-
                                 munity, to  respond to requests for information about chemicals in the
                                 community, and to involve the public in the emergency planning process
                                 as well as chemical accident prevention activities.

                                 Q Review this booklet's section on New Partnerships. Who in your
                                 community might be interested  in the LEPC and its work?

                                 Q Review your current community response plan. How can it be
                                 improved  using new BMP information?

                                 Q Coordinate plans. Ensure that your community response plan is coor-
                                 dinated with the emergency response programs of facilities in the com-

                                 Q Develop an up-to-date list of response and mitigation equipment
                                 in the community. Where is the equipment stored? The new BMP infor-
                                 mation should be of help to you on this task.

                                 Q Get training and technical assistance. Contact your SEBC and/or
                                 your EPA regional office to find out about training and other sources of
                                 technical assistance in your area.

                                 Q Find the contact person. Contact your SEBC and/or your EPA regional
                                 office to find out who will be the official implementing agency for the
                                 BMP program in your area as well as what BMP initiatives are underway
                                 in your state.

                                 Q Get a copy of EPA's Guidance for Implementing Agencies to learn
                                 how you can get more involved in the workings of the program. You may
                                 even decide to be the BMP implementing agency in your area.

                                 Q Obtain  the Toxic Release Inventory (TRI) data for facilities in your
                                 area to ensure that you have all available information about chemicals in
                                 your community.
page A-4

You can also consult EPA's CEPPO website (http://www.epa.gov/ceppo) for information about Regional and state
contacts.                                                  :
EPA Region
Point of Contact and Telephone Number
    Maine, Vermont, New Hampshire, Massachusetts,
    Connecticut, Rhode Island
Ray DiNardo
US EPA Region 1 New England (Mail Code: SPP)
JFK Federal Building
One Congress Street
Boston, MA 0211H-2023
(617) 918-180H
     New York, New Jersey, Puerto Rico, Virgin
John Higgins
US EPA Region 2 (Mail Code: 211)
2890 Woodbridge Avenue
Edison, NJ  08837-3679
(732) 906-619H
     Delaware, Virginia, Pennsylvania, District of
     Columbia, West Virginia, Maryland
 David Wright
 US EPA Region 3 (Mail Code: 3HW33)
 1650 Arch Street
 Philadelphia, PA 19103-2029
 (215) 81H-3293
     North Carolina, South Carolina, Kentucky,
     Tennessee, Georgia, Florida, Alabama, Mississippi
 Bill Taylor
 US EPA Region H
 Atlanta Federal Center
 61 Forsyth Street, SW
 Atlanta, GA 30303
 (H04) 562-9167
     Ohio, Indiana, Illinois, Michigan, Minnesota,
 Mark Horwitz
 US EPA Region 5 (Mail Code: SC-9J)
 77 West Jackson Blvd.
 Chicago, IL6060H
 (312J 353-90H5
                                                                       Continued on next page
                                                                                    page A-5

  RMPs Are on the Way!

  EPA Region
                                             Point of Contact and Telephone Number
      Texas, Louisiana, Arkansas, Oklahoma, New
     Iowa, Kansas, Missouri, Nebraska
                                             Steve Mason
                                             US EPA Region 6 (Mail Code: 6E-E)
                                             Allied Bank Tower
                                             1W5 Ross Avenue
                                             Dallas, TX 75202-2733
                                             (21H) 665-2292
                                             Mark Smith
                                             US EPA Region 7 (ARTD/TSPP)
                                             726 Minnesota Ave.
                                             Kansas City, KS 66101
                                             (913) 551-7876
Colorado, Utah, North Dakota, South Dakota,
Montana, Wyoming
 US EPA Region 8 (Mail Code: EPR-ER)
 One Denver Place
 999 18th Street, Suite 500
 Denver, CO 80202-2H05
 (303) 312-6837
     Arizona, Nevada, California, Hawaii, Guam,
     America Samoa
                                            Nate Lau
                                            US EPA Region 9 (Mail Code: SFD-5)
                                            75 Hawthorne Street
                                            San Francisco, CA 9H105
                                            (415) 7HH-23HH
  Oregon, Washington, Idaho, Alaska
Lisa McArthur
US EPA Region 10 (Mail Code: HW-093)
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-0285

                                                          OCA Guidance

                                             Help owners or operators of regulated sources to con
                                             duct offsite consequence analysis required under
                                             CAA section 112{r).
                    • •"«<
77 toxic gases and liquids and 63 flammable gases
and volatile, flammable liquids.
Toxic liquids (with a few exceptions) have vapor pres-
sure at ambient temperature of at least 10 millimeters
of mercury.
                                             Endpoints set by rule as (1) Emergency Response
                                             Planning Guideline Level 2 (ERPG-2) set by AIHA or (2)
                                             EHS LOG. Many endpoints are different from EHS
                                             Endpoints set by rule for blast overpressure from
                                             vapor cloud explosions, heat radiation from fires, and
                                             dispersion to the flammability limit.
                                             Use of endpoints:
                                             Specified endpoints must be used for consequence
                                                                  continued on next page
                                                                                page A-7

  RMFs Are on the Way!
                                                                   OCA Guidance
          Initial Screening (Green Book) /Worst-Case Releases (OCA Guidance)


                                                    Greatest quantity in a single vessel or in a pipe, con-
                                                    sidering administrative controls.

                                                   e Rate

                                                   c Gases

                                                    Gases under ambient conditions:
                                                    Substances that are gases under ambient conditions
                                                    and are handled as gases, as liquids under pressure,
                                                    or refrigerated liquids that would form pools with a
                                                    depth of I cm or less upon release are assumed to be
                                                    released over 10 minutes.
                                                    Liquefied refrigerated gases:
                                                    Gases handled as refrigerated liquids at ambient
                                                    pressure that would form pools with depth greater
                                                    than 1 cm are treated as liquids.
                                                    Method provided for reducing the release rate for
                                                    gases released in enclosures.


                                                    Liquid release:
                                                    Assumed to be instantaneous.
                                                    Release to air:
                                                    Pool evaporation; equation for pool evaporation uses
                                                    a mass transfer coefficient for water of 0.67 cm/sec
                                                    (i.e., evaporation rate increased by factor of about 3
                                                   over Green Book rate).
                                                   Liquid density:
                                                   Chemical-specific density factors provided for estima-
                                                   tion of pool size.
                                                   Method and data  provided for estimating release
                                                   rates for common water solutions and oleum.
                                                   Method provided for estimating release rate from
                                                   diked area.
                                                   Method provided for reducing the release rate for liq-
                                                   uids released in buildings.
                                                   Factors provided for estimation of release rate at 25°C
                                                   and the boil ing point. Factors generally significantly
                                                   larger than Green Book factors because of revised
                                                   mass transfer coefficient and revised chemical-specific
                                                   Temperature correction factors provided for tempera-
                                                   tures between 25 and 50°C
page A-8


                                                             OCA Guidance
Initial Screening (Green Book)/Worst-Case Releases (OCA Guidance)-continued

                                              c Solids

                                               None regulated.
                              Vapor cloud explosion of entire quantity assumed,
                              with yield factor of 10%.
                                stability, wind speed 1.5 meters per second.
                             „»*% ,f%
                              **>;. -jafe
       jy bejus

 Neutrally buoyant gases and vapors:
 Gaussian model used for neutrally buoyant plumes.
 •  10-minute releases; i.e., release assumed to stop
   after 10 minutes (with 10-minute averaging time).
 •  60-rninute releases (with 30-minute averaging
 Dense gases and vapors:
 SLAB model used for dense gases.
 •  10-rninute releases (with 10-minute averaging
 •  60-rninute releases (with 30-minute averaging
 Vapor cloud explosions:
 TNT-equivalent model used for vapor cloud explo-
                           tbles Provided
                              Neutrally buoyant plume tables:
                              • Rural-10 minute and 60 minute.
                              • Urban -10 minute and 60 minute.
                              Dense gas tables:
                              • Rural - lO'minute and 60 minute.
                              • Urban -10 minute and 60 minute.
                              Chemical-specific tables:
                              • Ammonia liquefied under pressure.
                              • Ammonia solution.
                              • Chlorine.
                              • Sulfur dioxide.
                              Vapor cloud explosion distance table.
                             Maximum Distance in Tables

                                               25 miles
                                                                                    page A-9

RMPs Are on the Way!
                                                                OCA Guidance
     Reevaluation (Green Book) /Alternative Scenario Analysis (OCA Guidance)
                                                  Estimate quantity based on site-specific information.

                                                ie Rate
                                                fc Gases
                                                 Cases underpressure:
                                                 Estimation methods for:
                                                 .  Gaseous release from tank (based on hole size and
                                                    tank pressure.
                                                 •  Gaseous release from pipe.
                                                 •  Release of gas liquefied under pressure:
                                                    - from vapor space,
                                                    -from liquid space.
                                                 Liquefied refrigerated gases;
                                                 Gases handled as refrigerated liquids at ambient
                                                 pressure are treated as liquids.
                                                 Method provided for reducing the release rate for
                                                 gases released in enclosures.
                                                 Active mitigation measures also discussed.


                                                 Liquid release:
                                                 Estimation methods for:
                                                 •  Release from tank under atmospheric pressure.
                                                 •  Release from pressurized tank.
                                                 •  Release from pipe.
                                                 Liquid density:
                                                 Considered as for worst case.
                                                 Considered as for worst case.
                                                 Release to air:
                                                 Pool evaporation,  as for worst case
                                                 Same methods for passive mitigation as for worst
                                                 Active mitigation for liquid release and for release to
                                                 air discussed.
                                                 Same as for worst case.

                                                c Solids

                                                 None regulated.
page A-10

                                                            OCA Guidance
Reevaluation (Green Book)/Alternative ScfenaHLo Analysis (OCA Guidance)-cont.
I Substances

  Methods provided for:
  •  Vapor cloud fires.
  .  Pool fires.
  .  BLEVEs.
  •  Vapor cloud explosions, based on less conservative
    assumptions than the worst case.

 al Conditions

  D stability, wind speed 3 meters per second.

lies Provided

  Neutrally buoyant plume tables:
  • Rural -10 minute and 60 minute.
  • Urban-10 minute and 60 minute.
  Dense gases:
  • Rural -10: minute and 60 minute.
  . Urban -10 minute and 60 minute.
  Chemical-specific tables:
  . Ammonia liquefied under pressure.
  • Ammonia solution.
  • Chlorine.
  • Sulfur dioxide.
  Vapor cloud explosion distance table.
  Vapor cloud fire distance tables:
  •  Neutrally buoyant plumes.
  •  Dense gases.
   BLEVE (fireball) distance table.

  ;ance in Tables

   25 miles
                                                                                  page A-11

 RMPs Are on the Way!
page A-

This list is current at the time of publication of this booklet. For an up-to-date list at any time, consult EPA's CEPPO
website at www.epa.gov/ceppo.

Regulated Substance
Acrylyl chloride
Aljyl alcohol
Ammonia (anhydrous)
Ammonia (cone. 20% or greater)
Arsenous trichloride
Boron trichloride
Boron trifluoride
Boron trifluoride compound
with methyl ether (1:1)
Carbon disulfide
Chlorine dioxide
Chloromethyl ether
Chloromethyl methyl ether
Crotonaldehyde, (El-
Cyanogen chloride ((CN)CI)
Ethylene oxide
Formaldehyde (solution)
Hydrochloric acid
(cone. 30% or greater)
Hydrocyanic acid
Hydrogen chloride (anhydrous)
Hydrogen fluoride/Hydrofluoric acid
(cone. 50% or greater)









Regulated Substance
Hydrogen selenide
Hydrogen sulfide
Iron, pentacarbonyl-
Isopropyl chloroformate
Methacrylonitrile .
Methyl chloride
Methyl chloroformate
Methyl hydrazine
Methyl isocyanate
Methyl mercaptan
Methyl thiocyanate
Nickel carbonyl
Nitric acid (cone. 80% or greater) 7697-37-2
Nitric oxide
Oleum (fuming sulfuric acid)
Peracetic acid
Perchloromethyl mercaptan
Phosphorus oxychloride
Phosphorus trichloride
Propyl chloroformate
Propylene oxide
Sulfur dioxide (anhydrous)
Sulfur telrafluoride
Sulfur trioxide
Titanium tetrachloride
Toluene 2,4-diisocyanate
Toluene 2,6-diisocyanate
Toluene diisocyanate
(unspecified isomer)
Vinyl acetate monomer





continued on next page
                                                                     page A-13

 RMPs Are on the Way!
1 Flammables 1 ! I
Regulated Substance
Carbon oxysulfide
Chlorine monoxide
Ethyl acetylene
Ethyl chloride
Ethyl ether
Ethyl mercaptan
Ethyl nitrite
Isopropyl chloride
Methyl ether
Methyl formate
2-Pentene, {£)-
2-Pentene, (Z)-
Regulated Substance
Vinyl acetylene
Vinyl chloride
Vinyl ethyl ether
Vinyl fluoride
Vinylidene chloride
Vinylidene fluoride
Vinyl methyl ether