RMP SERIES
EPA's Risk
Management
Program
How Does It Affect Propane
Retailers and Users?

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    Does This Apply to Me?
Under a new EPA chemical accident
prevention rule, some propane retailers and
users will have to implement a risk
management program and file a risk
management plan (RMP) with EPA by June
21, 1999. If you handle, store, or use propane
in excess of 10,000 pounds (equivalent to one
2,500-gallon water capacity tank) at your
facility in one or more tanks, you are likely to
be subject to this rule. The use of propane as
a fuel jg covered by the rule.

If you have other chemicals at your facility,
you can get a complete list of substances
regulated under this rule and their thresholds
from EPA,

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      What's It All About?
The risk management program rule (also
known as Clean Air Act section 112(r), the
RMP rule, or part 68) is designed to prevent
serious chemical accidents that could affect
public health and the environment and to
improve the response to any accidents that do
occur.

The rule requires covered facilities to developj
and to implement an integrated system to
identify hazards and manage risks.  If you are
subject to this rule, you must analyze worst-
case releases, document a five-year history of
serious accidents, coordinate with local
emergency responders, and file a risk
management plan with EPA. If your worst-
case release could affect the public, you also
must analyze more realistic alternative
scenarios and develop and implement a
prevention program that includes, among
other steps, identification of hazards, written
operating procedures, training, maintenance,
and accident investigation.  If your employees
respond to accidental releases, you must
implement an emergency response program.
The RMP you submit to EPA will summarize
your program and will have to be made
available to the public.

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         Compliance Tips
The good news is that many propane retailers
and users already are complying with many of
the prevention requirements because these
steps are part of the way you operate safely.
If you are complying with NFPA Standard 58
under state law or are subject to the OSHA
Process Safety Management Standard, you
are likely to be in compliance with almost all
of the prevention program requirements and
may need to take few steps  to satisfy this  part
of EPA's rule. If you already have an
emergency response plan, you are likely to be
in compliance with that part of EPA's rule as
well.

Besides helping you prevent accidents, the
rule can improve the efficiency of your
operation by ensuring that your workers are
trained in proper procedures and by using
preventive maintenance to reduce equipment
breakdowns.

EPA is working with the State of Delaware
and the National Propane Gas Association
(NPGA) to develop a guidance document
specifically for propane retailers and users
that will help  you understand the
requirements  as they relate  to your
operations. The propane guidance will make
compliance less burdensome by providing
Industry-specific information and analyses.

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     Where Can I Get More
           Information?
If you have access to the Internet, you can get
copies of the rule and a wide variety of
technical assistance materials at the home
page of EPA's Chemical Emergency
Preparedness and Prevention Office
(http://www.epa.gov/swercepp/).

You also may obtain copies of these materials
as well as answers to your specific questions
from EPA's hotline at (800) 424-9346 during
normal business hours.

The full text of the rule can be found in Title
40 of the Code of Federal Regulations (40
CFR part 68), which is available at most
public libraries.

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