United States
Environmental Protection
Agency
Office of Solid Waste and
Emergency Response
Office of Enforcement and
Compliance Assurance
EPA 550-K-11-001
January 2011
www.epa.gov/emergencies
www.epa.gov/compliance
for
Air Act
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This document is intended solely for the guidance of government personnel. It is not intended and cannot be relied
upon to create rights, substantive or procedural, enforceable by any part, in litigation with the United States. The
Agency reserves the right to act at variance with this guidance and change it at any time without public notice.
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ASChE
ANSI
APS
ASME
CAA
CBS
CCPS
CFR
D&B
EPA
EPCRA
ERNS
HAZWOPER
LEPC
NCP
NFPA
NRS
OSHA
PHA
PPE
PSM
RMP
SARA
SERC
American Institute of Chemical Engineers
American National Standards Institute
American Petroleum Institute
American Society of Mechanical Engineers
Clean Air Act
Confidential Business Information
Center for Chemical Process Safety
Code of Federal Regulations
Dun and Bradstreet
Environmental Protection Agency
Emergency Planning and Community Right-to-Know Act
Emergency Response Notification System
Hazardous Waste Operations and Emergency Response
Local Emergency Planning Committee
National Contingency Plan
National Fire Protection Association
National Response System
Occupational Safety and Health Administration
Process Hazard Analysis
Personal Protective Equipment
Process Safety Management
Risk Management Plan
Superfund Amendments and Reauthorization Act
State Emergency Response Commission
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INTRODUCTION 1
Purpose 1
Background 1
INTERRELATED OPPORTUNITIES FOR ACCIDENT PREVENTION 2
Chemical Safety Audits 2
Accident Investigations 3
The General Duty Clause 4
RMP INSPECTIONS AND AUDITS 4
RISK MANAGEMENT PROGRAM REQUIREMENTS 5
Table 1: RMP Program Levels 6
DEVELOPING AN RMP INSPECTION PROGRAM 7
Objective 7
Approaches to an RMP Inspection 7
How to Use Reviews/Audits/Inspections 7
THE RMP INSPECTION PROCESS 9
Step (1): Selecting Facilities for RMP Inspections 9
Step (2): Off-Site Activities 10
Collecting Background Information 11
Table 2: Background Information 11
Planning the Inspection 12
Table 3: Potential Inspection Components 12
Prepare Inspection Staff and Plan Logistics 12
Step (3): At the Site 14
Entering the Facility. 14
Opening Meeting 15
Collecting and Analyzing Information 16
Personal Protective Equipment 18
Closing Conference 18
Step (4): Concluding Activities 20
Follow-up Meeting 20
Inspection Report 20
Step (5): Post-Inspection Actions 22
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Annex A: RMP Audits Conducted Pursuant to 40 CFR Part 68.220 A-1
Annex B: Site Safety Plan for On-Site Activities B-1
Annex C: Inspection Report C-1
Annex D: Inspection Checklist D-1
Annex E: Risk Management Program and OSHA PSM: List of Regulated Substances E-1
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Purpose
This document provides guidance for implementing agencies that conduct inspections of facilities (i.e.,
stationary sources) subject to 40 CFR Part 68, also called the EPA Risk Management Program. It is designed as
a tool for inspectors reviewing industry compliance with the Risk Management Program regulation. However,
this guidance does not reflect all requirements that a facility must meet to be in compliance with the regulation.
Background
The Environmental Protection Agency (EPA) works closely with stakeholders to reduce the likelihood and
severity of chemical accidents.
Several important planning and legislative initiatives have been introduced since 1968. These include the
National Contingency Plan (NCP) (started in 1968), EPAs voluntary Chemical Emergency Preparedness
Program started after the December 1984 accident in Bhopal (India), the Emergency Planning and Community
Right-to-Know Act of 1986 (EPCRA), and the Accidental Release Prevention requirements under Section
112(r) of the Clean Air Act (CAA), as amended in 1990. These initiatives address the entire safety continuum
dealing with chemical accident preparedness, response, and prevention.
In this document "RMP" denotes Risk Management Plan, which summarizes
the source's risk management program and is submitted to EPA
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for
From a government point of view, chemical accident prevention '. Accident prevention opportunities include:
involves: (1) working with facilities (both management ; , Chemical safety audits
personnel and employees) to improve their chemical safety ; . Acci(jent investigations
management program, and (2) encouraging communities to ; . ^^ ^Q ^
coordinate nsk reduction activities with facilities even as they ;
enhance emergency preparedness for response to possible \ ^
accidents. Improving the safe use and management of chemicals
begins with an understanding of:
* How and why accidents occur;
* How industry identifies chemical and process hazards;
How industry designs, maintains, and operates a safe facility; and
* How the consequences of accidents are minimized.
Industry has the expertise and responsibility, with assistance from their employees, to make sure that the
elements of safe operation (e.g., procedures, training, and maintenance) are brought together and managed day-
to-day. Government agencies can help facilities by inspecting their safety management programs, comparing
them to successful practices used by other facilities, and stimulating improvements.
The Risk Management Program regulations are among several tools implementing agencies have to help
facilities prevent chemical accidents. Existing and new programmatic tools are briefly described below. Each of
these programs is designed to help identify the causes of accidental chemical releases as well as the means to
prevent them from occurring. Additionally, these activities can be used to promote coordination within the local
community.
Chemical Safety Audits
Chemical Safety Audits are designed to:
* Share information about chemical safety practices and technologies when visiting facilities that handle
hazardous substances;
Heighten awareness of the need for and promote chemical safety at chemical facilities and in the
communities where chemicals are located; and
* Build cooperation among facilities, government agencies, and others.
Chemical safety audits are usually voluntary and may include facilities not covered by the Risk Management
Program provisions. One purpose of conducting a chemical safety audit at a facility is to identify and
characterize the strengths and weaknesses of specific chemical accident prevention program areas, as a means
to highlight the elements which form an effective program. Additionally, chemical safety audits facilitate the
sharing of information about successful practices and generally result in (non-mandatory) recommendations for
safety improvements. This can lead to process safety improvements, which may prevent or mitigate releases by
the audited facility.
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Accident investigations
The fundamental objective of a chemical accident investigation
is to determine the facts, conditions, circumstances, and causes
or probable causes of chemical accidents. In determining the root
causes or management system failures resulting in an accident, the
ultimate goal of the accident investigation is to reduce the likelihood
of recurrence, minimize the consequences associated with accidental
releases, and make chemical production, processing, handling, and
storage safer. The accident investigation also looks at contributing
factors of the event that may have broad applicability to industry,
and the potential to develop recommendations and lessons learned
to prevent similar accidents in the future. In addition to determining
causes, lessons learned, and recommendations, EPA accident
investigations may be combined with inspections in order to identify
specific violations of regulatory or statutory requirements, leading to
enforcement actions.
The Chemical Safety Board began
operating in 1998 after it was
funded by Congress, EPA and
the Chemical Safety Board have
developed a Memorandum of
Understanding which addresses
their respective authorities
and coordination on accident
investigation. To view this MOU,
see http://www.epa.gov/oem/docs/
chem/csbepa. pdf.
For further information concerning
the Chemical Safety Board, visit
the web site at www. chemsafety.
gov or www.csb.gov.
CAA Section 112(r)(6) established an independent safety board
known as the Chemical Safety and Hazard Investigation Board ("the
Chemical Safety Board"). One of the objectives of the Chemical Safety Board, as directed by the CAA, is to
investigate, determine and report to the public, the facts, conditions, circumstances, and cause or probable cause
of any accidental release resulting in fatality, serious injury or substantial property damage.
The Chemical Safety Board does not issue fines or citations, but does make recommendations to facilities,
regulatory agencies such as OSHA and EPA, industry organizations, and labor groups. Congress designed the
CSB to be non-regulatory and independent of other agencies so that its investigations might, where appropriate,
review the effectiveness of regulations and regulatory enforcement. In the event of a large chemical accident,
EPA inspectors will likely interact with CBS investigators. The two agencies have developed a Memorandum of
Understanding to address their respective authorities and coordination on such investigations (see inset at right).
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The General Duty Clause
CAA Section 112(r)(l), known as the "General Duty Clause," further expands the range of activities EPA can
undertake to promote chemical safety.
Owners and operators of facilities producing, processing, handling, or storing extremely hazardous substances
have a general duty to:
* Identify hazards associated with a potential accidental release, using appropriate hazard assessment
techniques;
* Design and maintain a safe facility, taking steps to prevent releases; and
Minimize the consequences of accidental releases that do occur.
The General Duty Clause is not limited to a finite list of chemicals or established thresholds.
To the extent state or local law establishes a similar general duty, implementing agencies other than EPA can
take actions to promote safe operating practices and the prevention of chemical accidents.
RMP Inspections and Audits
RMP inspections and audits help ensure compliance with the Risk Management Program, but the two terms
carry different meanings within the context of 40 CFR Part 68. Within Part 68, the term "audit" refers to the
process that implementing agencies may use to verify the quality of the RMP submitted to EPA and require
revisions when necessary to ensure compliance with the requirements of subpart G of the rule. Like inspections,
RMP audits will generally involve on-site verification of a facility's underlying risk management program.
However, section 68.220 of the rule requires implementing agencies to select facilities for audits based
on specific criteria, and to follow a specific process for resolving audit findings (involving steps known as
preliminary determinations and final determinations) prior to any enforcement action.
RMP inspections are different from audits in that facilities are not necessarily selected for inspection based on
Part 68 regulatory criteria, and inspections can lead directly to implementing agency enforcement actions for
regulatory violations. Also, RMP inspections always involve on-site verification activities. In general, the on-
site activities performed by implementing agency inspectors and auditors are the same, and this guidance can
be applied to either activity. However, most implementing agency oversight and enforcement of CAA Section
112(r) and 40 CFR Part 68 involves inspections, rather than audits. Annex A contains additional information
related to the specific requirements for implementing agencies when conducting audits in accordance with the
process described in section 68.220 of the rule.
The above-mentioned activities are not mutually exclusive. Many times, a combination of activities may be
used to achieve results. For example, an agency might investigate a chemical accident at a facility. While the
investigation may determine a root cause, a chemical safety audit may confirm that procedures are being used
to reduce the risk of future accidents. Additionally, the agency may also perform an inspection to evaluate
compliance with the General Duty Clause and/or RMP requirements.
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Risk
CAA Section 112(r) requires EPA to publish rules and guidance
for chemical accident prevention. The rules promulgating the
list of regulated substances (published January 31, 1994) and
the Risk Management Program provisions (published June 20,
1996) are found at 40 CFR Part 68. The Risk Management
Program contains three elements: a hazard assessment, a
prevention program, and an emergency response program. The
entire program is to be described and documented in a Risk
Management Plan (RMP) which is submitted to EPA (delegated
state and local implementing agencies receive RMP data from
EPA).
In general, the RMP submitted by most facilities includes the
following:
* Executive summary;
* Registration information;
* Off-site consequence analysis;
Five-year accident history;
Prevention program; and
Emergency response program.
Who is covered?
EPA estimates that approximately 13,000
facilities are covered by the provisions of 40
CFR Part 68, including:
* Chemical manufacturers (industrial
organics and inorganics, paints,
Pharmaceuticals, adhesives, sealants,
fibers),
* Petrochemical (refining and gas
processing operations, plastics and resins,
synthetic rubber),
Other manufacturing (electronics,
semiconductors, paper, fabricated metals,
industrial machinery, furniture, textiles),
* Agriculture (fertilizers),
* Public facilities (drinking and waste water
treatment works),
Electric utilities,
* Food and cold storage,
* Chemical warehousing,
* Chemical wholesalers,
* Military and energy installations, and
* Other facilities.
Owners or operators of a facility with more than a threshold
quantity of a regulated substance (one of the 140 listed toxic and flammable substances in 40 CFR Section
68.130) in a process, as determined under section 68.115, must submit an RMP no later than the latest of the
following dates:
Three years after the date on which a substance is first listed under 40 CFR 68.130; or
* The date on which a regulated substance is first present in a process above a threshold quantity.
The Risk Management Program regulations also define the activities that facilities must undertake to identify
and minimize the risks posed by regulated substances in covered processes. Specifically, EPA defined three
"program levels" to ensure that individual chemical processes are subject to appropriate requirements based on
the size of the process and the associated risks (see table on next page).
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Table 1: BMP Program Levels and Requirements
DESCRIPTION
Requirements apply to
processes where (1) a
Worst case release, as
determined by the hazard
assessment, is not expected
to reach public receptors; (2)
no accidental release has
occurred in the last five years
that caused specified offsite
impacts; and (3) the facility
has coordinated emergency
response procedures with the
local planning and response
organizations. The most likely
processes for this program level
are those at remotely located
facilities and/or those using
listed flammable chemicals.
Requirements apply to
processes that do not meet
the eligibility requirements of
Program 1 or 3.
Requirements apply to
processes not eligible for
Program 1, and which are in
certain specified industrial
categories or are already subject
to the OSHA Process Safety
Management (PSM) standard.
These generally include
higher-risk, complex chemical
processing and petroleum
refining operations.
REQUIREMENTS
Conduct an offsite
consequence analysis
that evaluates worst-
case accidental release
scenario(s);
Document the five-year
history of certain accidental
releases of regulated
substances from covered
processes;
Coordinate response plans
with local emergency
planning and response
agencies; and
Revise, update, and submit
the RMP at least every five
years.
Conduct an offsite
consequence analysis
that evaluates worst-
case accidental release
scenario(s);
Document the five-year
history of certain accidental
releases of regulated
substances from covered
processes;
9 Coordinate response plans
with local emergency
planning and response
agencies; and
Revise, update, and submit
the RMP at least every five
years.
Evaluate alternative accident
release scenarios and establish:
An integrated prevention
program for managing risk;
Provisions for responding to
emergencies; and
An overall management
system supervising the
implementation of these
program elements.
Conduct an offsite
consequence analysis
that evaluates worst-
case accidental release
scenario(s);
Document the five-year
history of certain accidental
releases of regulated
substances from covered
processes;
Coordinate response plans
with local emergency
planning and response
agencies; and
Revise, update, and submit
the RMP at least every five
years.
Evaluate alternative accident
release scenarios and establish:
An integrated prevention
program for managing risk;
Provisions for responding to
emergencies; and
An overall management
system supervising the
implementation of these
program elements.
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an
Objective . BMP Inspections focus on
The RMP regulation states that implementing agencies shall conduct : verifying compliance with the
inspections for the purposes of regulatory development and enforcement "'ฎ* MSnsgsment Program
of the CAA. RMP inspections focus on the underlying Risk Management ; a Plan.
Program, as well as the data contained in the Risk Management Plan. An
RMP is a blueprint of how Risk Management Program provisions are incorporated into process safety at the
facility, just as an emergency response plan is a blueprint of an emergency response program for a community
or a facility. Risk Mangement Plans do not directly protect the public; Risk Managment Programs are the
comprehensive approach to protecting the public.
Approaches to an RMP inspection
Full compliance with the Risk Management Program regulations cannot be determined without on-site or
independent verification of all or part of the information submitted in an RMP. However, each implementing
agency should determine the scope of the inspection process to be used. This determination is based on available
resources, priorities, expertise, and other factors. Inspecting to ensure compliance with the Risk Management
Program regulation may consist of a range of off-site and on-site activities. Off-site activities might include
determining that the rule applies to the facility, that the facility placed itself in the correct program level,
and that the facility submitted a complete and correct RMP. On-site activities might include verification of
documentation; interviews with facility managers, employees, and employee representatives; and observations
of ongoing process operations or maintenance activities.
To ease the inspection burden, the implementing agency should also determine how the scope and conduct
of on-site inspection activities can be coordinated with other regulatory inspections. For example, the
implementing agency might coordinate with either the federal or state OSHA office within its jurisdiction. If
chemical facilities are subject to the OSHA Process Safety Management (PSM) Standard, OSHA has its own
authority over the facilities' prevention program. Also, other state agencies, such as state fire marshal offices,
state departments of agriculture, or state environmental offices may regulate certain activities at RMP facilities.
Coordinating inspection activities and sharing appropriate information with such agencies may save inspection
resources and decrease the burden on the facility.
How to Reviews/Audits/inspections
The Risk Management Program regulations mention the use of completeness checks, reviews, audits, and
inspections. These terms are defined below.
RMP Completeness Checks. The implementing agency may conduct an in-office "completeness check" of
the RMP. RMP*eSubmit (a submission system developed by EPA) will check each RMP before it is submitted
to ensure that all the required data elements have been completed. The software program will indicate which
fields are missing any required information. In addition, the EPA reporting center will use a similar technique to
review every RMP submitted to see if all necessary fields have been completed.
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RMP Reviews. Implementing agencies may want to review the data in an RMP to identify discrepancies. For
example, the Executive Summary and registration data can be compared to chemical inventory data submitted
to the state under EPCRA section 312 (always remembering that EPCRA section 312 and CAA section
112(r) may have differences in thresholds). Agencies may also want to review RMPs to identify internal
data inconsistencies (e.g., dates listed for activities should be verified as internally consistent), facilities with
potential problems based on their accident histories, and unusual data (e.g., failure to list appropriate hazards
under the prevention program). For example, if an RMP reports that there has recently been a major change in
a process that triggered a review or revision of certain requirements (see 68.170(k)), but the RMP indicates that
these requirements have not been reviewed or revised since the date of the change, further inquiry is warranted.
RMP Audits. In an audit, the implementing agency evaluates the adequacy of the RMP submitted to EPA and
requires revisions to RMPs when necessary to ensure compliance with the Risk Management Plan requirements
of Part 68. As previously discussed, implementing agencies must select facilities for audits and resolve audit
findings using criteria and procedures specified in 40 CFR 68.220. See Annex A for additional information on
RMP Audits.
Inspections. Inspections complement other compliance monitoring activities and are valuable for evaluating
compliance with the CAA Section 112(r) requirements. Many implementing agencies that have programs for
the protection of public health and safety already have staff who are qualified to conduct on-site inspections
(e.g., water permitting agencies visit water treatment plants; fire inspectors check on propane distributors). With
proper training, it may be efficient for these regulators and inspectors to add 112(r) compliance elements to their
inspection checklist.
Pursuant to an inspection, a facility may be required to revise its RMP and correct deficiencies in its underlying
Risk Management Program. For example, if an inspection indicated that a facility had not reviewed and updated
operating procedures after a change and that such updates were needed, the facility could be required to update
the procedures, re-train workers in the new procedures, and submit a revised RMP. Inspections may also result
in a variety of enforcement actions and penalties. Implementing agencies should consult legal counsel and
applicable agency policies to determine appropriate enforcement actions following an inspection.
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(1): Selecting Facilities for RMP Inspections ; There are several basic steps to
EPA policy requires EPA regional offices to prioritize inspections at ; conducting an RMP inspection:
"high-risk" facilities. High-risk facilities include facilities with a large ; 1. The first is selecting facilities to
residential population within the facility's worst-case scenario vulnerable j be inspected.
zone, facilities with a history of significant accidental releases, and ; 2. Next, there is a range of
facilities with very large quantities of regulated substances held on site ; potential off-site, on-site, and
(or with multiple regulated substances held above a threshold quantity). j concluding activities.
While EPA expects that every RMP facility will periodically be inspected, ; 3. Finally, there is a series of post-
implementing agencies should inspect high-risk RMP facilities more j inspection actions.
frequently than other RMP facilities. }
EPA policy also requires regional offices to periodically search for regulated facilities that have failed to submit
RMPs (i.e., "RMP non-filers"), identify known RMP facilities that have failed to update their RMP as required
by the rule, and take appropriate enforcement or compliance assistance actions in order to resolve the status of
such facilities.
Beyond these considerations, implementing agencies have significant flexibility to select facilities for
inspection. In making their selections, implementing agencies may choose to consider additional factors such as
geographic location or clustering, proximity to minority or low-income residential areas, industry sector trends,
and specific facility hazards or characteristics.
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Step (2): Activities
If more than one inspector is participating in the inspection, the entire inspection team should participate
in a planning meeting prior to the inspection. This meeting should include any personnel from outside the
implementing agency who will participate in the inspection, such as personnel from other agencies (e.g., fire
marshal, emergency management staff, or environmental management staff), or outside contractors or experts
who will provide technical support to the inspection team. Additionally, if possible, the implementing agency
should include LEPC members and/or local response agency members. To the extent that Offsite Consequence
Analysis information is shared during planning, the members of the team should be aware of restrictions on
dissemination of this information to the public.
The lead inspector should determine at this point whether the facility will be notified in advance of the site visit.
Prior notification may be dictated by implementing agency policy or practices. If the facility is to be notified in
advance of the visit, the lead inspector should schedule the date, time, and point of arrival at the facility.
CAA Section 112(r)(6)(L) provides facility employees and employee representatives with the same rights
to participate in the physical inspection of any workplace conducted pursuant to CAA Section 112(r)
as provided in the Occupational Safety and Health (OSH) Act (29 CFR 1903.8). Therefore, if there is
advance notification of the site visit, the notification should be provided to both the owner/operator and
facility employees/employee representative(s).
* If advanced written notification to the owner/operator is provided (e.g., Notice of Inspection (NOI) Letter)
it should reference the statutory right for employees and employee representatives to participate in Section
112(r) inspections. The notification also should instruct the owner/operator to notify, upon receipt of the
notification, the employee representative(s), if any, of the date and time of the on-site inspection and make
arrangement for their participation. The owner/operator should be instructed to provide a copy of the
notification to the employee representative(s).
ป The owner/operator also should be instructed to post the notification, upon receipt, in the area subject to
the inspection.
If the name and contact information of the employee representative(s) is readily available to the lead
inspector, a copy of the notification should be sent to the employee representative(s) concurrently with the
notification being sent to the owner/operator.
The lead inspector should:
Brief all inspectors on the rationale for the inspection;
* Assign each inspector specific section(s) of the inspection report, including collecting facility background
information related to his/her report section;
Identify related regulatory requirements (e.g., hot work permit, HAZWOPER); and
Establish a schedule for completing collection of the necessary background information, conducting the
pre-visit meeting, conducting the inspection, and completing the inspection report.
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Collecting Background Information
Preliminary preparation is crucial to a well organized inspection. It is useful to collect as much of the facility
background information as possible in advance of the inspection. The lead inspector may elect to notify the
facility (both owner/operator and employee representative(s)), state, and local officials of the pending inspection
and request appropriate background information. The inspector(s) then can review this information prior to
the visit, prepare a detailed list of topics and questions to help organize their on-site activities, and minimize
the amount of time spent at the facility. The table on the following page lists some examples of background
information that may be useful to inspectors.
Submitted BMP
RMP*lnfo and/or RMP*Review (database available to the implementing agency from EPA).
History of releases at the facility
and/or similar facilities
On-scene coordinator reports, Accidental Release Investigation Program (ARIP) questionnaires,
RMPs, Emergency Response Notification System (ERNS) data, EPCRA 304 release notifications,
Toxic Release Inventory data, state release files.
Chemical processes
Industry standards and processing techniques from trade and professional groups (e.g., American
Institute of Chemical Engineers (AlChE), ASME, and the Chlorine Institute), process flow diagrams,
and piping and instrumentation diagrams.
EPCRA Chemical Inventory Data
SERC, LEPC, local fire department.
Other information
OSHA facility inspection information, EPA databases, state databases.
Inspectors should also determine the applicability of existing checklists specific to the facility being inspected
such as checklists developed by EPA in sector-specific RMP guidance may be used (e.g., ammonia refrigeration,
publicly owned treatment works, chemical warehouses, propane users). Inspectors should also familiarize
themselves with industry and government standards specific to the facility (e.g., standards developed by OSHA,
NFPA, and ANSI).
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Planning the Inspection
An on-site inspection might include review of programs and records, verification of data, interviews with
employees, and analysis of prevention measures. See the following table of potential inspection components for
suggestions.
Review
Table 3: Potential Inspection Components
accident history
incident investigation reports, and documentation of corrective measures taken
preventive maintenance program
process hazard analysis or hazard review, including review of safety information and risk scenarios
soundness of air modeling results
operation and maintenance records, inspection procedures, and repairs records
training records and review of emergency plan exercise program
emergency response program capabilities, including exercises, equipment, training, off-site
programs, public notification, procedures, and communication with local emergency responders
management of change program, pre-start review program, employee participation program, hot
work permit program, and contractor employee training
Verify
facility classification and program designation
air modeling methods and results
model input parameters
mitigation measures and systems
process enhancements, including facility-conducted compliance inspection results and
recommendations
Evaluate
additional (unreported) covered processes
Engineering review
processes
Engineering analyses
release prevention measures
Engineering verification
mitigation measures, design parameters
Prepare Inspection Staff and Plan Logistics
The lead inspector should hold a pre-visit meeting with all inspectors as close to the date of the inspection
as possible. By this time, all inspectors should be familiar with this guidance and any information they have
collected about the facility to be inspected and its processes. Additional information to be obtained at the
facility should be identified and inspectors should develop individual plans for conducting their portion of the
inspection. For extensive inspections, the pre-visit meeting should:
* Establish the entry authority of each inspector;
Review each inspector's area of responsibility;
Review the inspection objectives and highlight areas of special interest;
Review any site-specific personal health and safety issues, and complete, if necessary, a site safety plan for
on-site activities;
Review information about key personnel and operations at the site;
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* Establish an agenda for each day of the site visit;
Review logistical matters (e.g., nightly team meetings to discuss results and plan the next day's activity);
Review the RMP submitted by the facility and preliminarily evaluate compliance with regulatory
requirements;
Arrange for proper management of confidential business information (CBI); and
* Cover any additional topics.
The lead inspector should also:
Develop site-specific guidance, if needed;
Reserve work space and equipment at the facility;
Develop employee interview questionnaires, if an interview is planned; and
* Schedule opening meetings, closing meetings, and daily debriefings.
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Step (3): At the Site
Entering the Facility
Upon entering the facility, the inspector(s) should present official credentials. The inspector(s) should not
relinquish credentials or allow photocopying of them. The inspector(s) should arrive at the facility during
normal working hours. The inspector(s) may sign a "sign-in" sheet, log, or visitor register. However, the
inspector(s) must not sign any type of "waiver" or "visitor release" which would relieve the facility of
responsibility for injury or limit the rights of the inspecting agencies to collect or use data obtained from the
facility. If a waiver or release is presented, the lead inspector should explain that such a document will not be
signed and request a blank "sign-in" sheet. If the inspector(s) is refused entry as a result of not signing the
release, the lead inspector should report all pertinent facts to the implementing agency's legal counsel. If the
matter cannot be resolved, the inspector(s) should leave the facility. All events surrounding the refused entry
must be fully documented, including the name(s) and title(s) of the person(s) refusing entry, and the stated
reason for denying access to the facility. The inspector(s) should also document any observations made at the
facility prior to the denial of entry.
In addition to presenting official credentials, the lead inspector may also present a Notice of Inspection to
provide further clarification to the facility that the purpose of the inspection is to determine compliance with
CAA Section 112(r) as well as with CERCLA Section 103(e) and EPCRA Sections 302 -312.
Once credentials have been presented and entry gained, the lead inspector should advise the owner/operator
that CAA Section 112(r) requires employee representatives be given an opportunity to participate in the
physical inspection of the facility (as referenced in the NOI if advance notification had been provided). As soon
as practicable after entering the facility, the lead inspector should determine whether the facility employees
are represented and, if so, offer the employee representative(s) an opportunity to participate in the on-site
inspection.
If employees are not represented by an authorized representative or employees have not chosen a representative
for the Section 112(r) inspection (e.g., chosen by employees at large or through an established employee
safety committee), the lead inspector should determine, if able, the employee(s) who may serve as employee
representative(s) for purposes of the inspection. If the lead inspector is unable to make such a determination,
the inspector(s) should interview during the course of the inspection a reasonable number of employees the
inspector(s) deems necessary to conduct the inspection.
Pursuant to CAA Section 112(r)(6)(L) and the OSH Act, the employee representative is to be an employee of the
employer. Having an employee who works at the facility and has knowledge of the Risk Management Program
participate in the inspection may assist the inspector(s) in evaluating compliance with CAA Section 112(r)
requirements. However, if the inspector(s) determines that good cause has been shown why accompaniment
by a third party who is not an employee of the employer is reasonably necessary to the conduct of an effective
and thorough physical inspection of the workplace, such third party may accompany the inspector(s) during the
inspection. The determination to include a third party is at the discretion of the inspector(s).
The lead inspector should document in the inspection report the offer to employees and employee
representatives the opportunity to participate in the Section 112(r) inspection.
The inspection should not be postponed or unreasonably delayed if an employee representative
is unavailable when the inspector(s) arrives to begin the on-site visit. The reason for an employee
representative not being available to participate in the inspection should be noted in the inspection report
14
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(e.g., representative is not present at facility; representative does not accept offer to join inspection due to
participation in an ongoing strike or labor dispute.)
If management personnel attempt to interfere with participation by employees and employee representatives
in the inspection, the lead inspector should advise management that such participation, as indicated in the NOI
letter, is a statutory right pursuant to CAA Section 112(r)(6)(L). Any attempt by management to interfere in
such participation should be documented in the inspection report. Depending upon the nature and scope of
the management interference, the lead inspector may determine the interference to be a refusal to permit the
inspection.
Opening Meeting
The inspector(s) should conduct a joint opening meeting with management personnel (e.g., plant manager,
superintendents of safety and operations, legal counsel, corporate representative) and the employee
representative(s). The lead inspector should clearly explain the purpose and objectives of the inspection.
If either management personnel or the employee representatives object to a joint opening meeting, the
inspector(s) should conduct separate opening meetings.
The lead inspector may give management personnel and employee representative(s) each a copy of this
guidance to help them understand the scope, purpose, and objective of the inspection. In addition, this guidance
may help management personnel and employee representatives in assembling information to be reviewed by the
inspector(s). At a minimum, the following items should be addressed during the opening meeting:
* Discussion of entry and information gathering authorities;
Inspection purpose and objectives;
On-site agenda;
* Identification and management of CBI;
Information necessary to conduct the inspection;
Safety issues (e.g., facility-specific safety orientation training, emergency response procedures and alarms
that may sound in an emergency); and
Schedule for closing conference.
The inspector(s) should also request a detailed overview of the chemical processes and/or manufacturing
operations at the facility, including block flow and/or process flow diagrams indicating chemicals and processes
involved.
Prior to walking around the facility, the inspector(s) should request an explanation of the facility's Risk
Management Program, including, at a minimum:
* How the elements of the program are implemented;
* Personnel who are responsible for the implementation of the various elements of the program; and
A description of the facility's records documenting compliance.
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At the conclusion of the opening meeting, the lead inspector should request access to the following information,
where applicable:
* Documentation for the hazard assessment, including selection of model and procedures followed;
Documentation supporting reports under the five-year accident history (e.g., follow-up release reports,
initial notifications);
Documentation for the process hazards analysis or hazard review;
* Standard operating procedures;
* Training records (e.g., hazard communication, emergency response) for all employees;
Pre-startup safety review;
Integrity or preventive maintenance records;
* Hot work permit program;
* Written procedures to manage change to processes;
* Plan of action for implementation of employee participation;
* Written process safety information;
Incident investigation reports;
The emergency response plan developed by the facility;
The two most recent compliance audit reports; and
* Documentation on coordination with local officials on emergency response activities.
Collecting and Analyzing Information
After the opening meeting, the inspector(s) may accomplish
their tasks individually or in small groups, performing their
work as quickly and efficiently as possible. Special attention
should be paid to:
Verifying the reported program level; and
* Comparing the facility's RMP to policies and
procedures actually implemented, especially for
production or equipment changes.
Annex D, Inspection Checklist (on page D-l) may be used
as guidance to ensure regulatory requirements are met
and a basic level of data quality is achieved. However, this
checklist is not intended to be comprehensive of all applicable
requirements. Accordingly, the checklist is not a substitute for
knowledge and understanding of the regulations.
Confidential Business Information
During the course of the inspection,
inspector(s) may have access or obtain
information that may be entitled to
confidential treatment.
It is the source's responsibility to
identify this information as Confidential
Business Information (CBI) to the
inspector(s), in accordance with the
Risk Management Program regulations.
This information will be handled in
accordance with the implementing
agency's procedures (e.g., 40 CFR Part
2 for EPA personnel).
Before visiting the site, inspector(s)
should check to see if their agency has
training or programs on handling CBI.
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; Air Act 112(r)
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During the inspection, a variety of materials will be gathered relating to operations at the facility. These
materials should be referenced in the inspection report and maintained in a central file. Examples of the types of
material that might be included are:
* Sample facility memoranda, guidelines, safe operating procedures, policy statements (e.g., safety
practices, Responsible Care);
Correspondence between the facility and the implementing agency; or
Graphic materials such as photographs, maps, charts, plot plans, organizational charts.
All materials should be labeled with:
* Name of facility;
* Names of inspection team members;
Date of inspection; and
* Other identifying information.
While collecting information, and in order to aid the inspection without causing interference to the conduct
of the inspection, the inspector(s), as provided by Section 112(r)(6)(L), may determine the following is
appropriate:
* To permit additional employer and employee representatives to participate in the inspection.
* To permit different employer and employee representatives to participate in the inspection as the
inspector(s) visits different areas of the workplace. For example,
ป Provide for participation of employees who have familiarity with specific work areas or have expertise
with certain process units.
ป Address issues concerning workplace areas containing confidential business information or trade secrets
by including employees in the inspection who are authorized to have access to those areas.
To provide for an effective inspection and to assist in the collection and analysis of information, the inspector(s)
may interview employees. As statutorily provided, such employee interviews may be conducted privately.
Consent by management personnel to conduct private employee interviews is not necessary. Any interference by
management personnel with the ability of the inspector(s) to conduct private interviews should be documented
in the inspection report. Such interference includes attempts by management to be present during private
interviews.
Employee interviews should occur during normal working hours and at other reasonable times during
or after the on-site visit at the facility or at an alternate location agreed upon between the inspector and
employee.
The inspector interviewing an employee should provide the employee with contact information (e.g., a
business card). While the NOI letter should include contact information, the lead inspector also should
provide such contact information to the employee representative(s).
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The inspector(s) should inform employees and employee representatives participating in the inspection
that only matters related to the inspection (e.g., workplace hazards; processes; emissions units) are to be
discussed.
During the course of the inspection, the inspector(s) has the statutory right to deny participation in the
inspection to any person whose conduct interferes with a fair and orderly inspection. Such denial should be
documented and explained in the inspection report.
Personal Protective Equipment (PPE)
In addition to normal protective equipment (e.g., safety shoes, hard hats, goggles), inspector(s) may need special
equipment:
* Flame-retardant coveralls in all areas of the facility where there is potential for flash fires and as may be
required by facility policy;
Emergency escape respirators during the walk-around portion of the inspection (personnel conducting
these inspections should have received proper training in the use of emergency escape respirators);
Alert monitors approved for the environment where they will be used (e.g., HCN, C12); and
Electronic equipment (e.g., still cameras, video cameras, cellular phones) that are safe for use in the
process areas being inspected.
Inspectors should follow facility guidance relative to the appropriate use of PPE and request notice of any
unusual conditions which may dictate specific precautions.
Closing Conference
Prior to the closing conference, the inspector(s) should meet
privately to review preliminary inspection observations and
establish topics for the conference. Significant observations
should be presented to management personnel and employee
representatives. Any issues requiring clarification should be
listed for discussion with the management personnel and
employee representatives. The lead inspector will determine
what should be communicated during the closing conference.
The inspector(s) should conduct the closing conference with
management personnel (e.g., plant manager, superintendents of
safety and operations, legal counsel, corporate representative)
and the employee representative(s). Other employees who
participated in the inspection should also be invited to the
closing conference.
If either management personnel or the employees/
employee representatives object to a joint closing
Closing Conference
Maintain a professional courteous
demeanor.
Make management and employee
representative(s) aware of helpful
standards, guidelines, or resources.
Alert management and employee
representative(s) to situations
requiring immediate remediation.
Avoid implying a "consulting"
relationship.
Do not state that violations have been
observed.
Avoid statements that affect
subsequent enforcement actions.
conference, the inspector(s) should conduct separate closing conferences.
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The inspector(s) should use the closing conference to gather additional information, answer questions and
verbally communicate preliminary inspection observations. The closing conference provides an opportunity for
management personnel and employee representatives to enhance their ability to take timely action to correct
deficiencies as a result of receiving preliminary inspection observations and appropriate compliance assistance.
The inspector(s) should maintain a professional, courteous demeanor throughout the inspection, including
the closing conference. The inspector(s) should ensure management personnel and employee representatives
are aware of any standards, guidelines, or resources that would be helpful in improving the facility Risk
Management Program. However, the inspector(s) should be careful to avoid making suggestions which imply a
"consultant" type of relationship, such as endorsing one product or firm exclusively.
The inspeetor(s) should never state that the facility is "in compliance" or that "violations" have been
observed. Determining that a violation has occurred is done after the inspection by the appropriate enforcement
program in consultation with legal counsel. The inspector(s) should not make any representations that could
affect subsequent enforcement actions against the facility (e.g., guaranteeing no enforcement will be taken if a
facility performs certain actions to correct a deficiency).
* In addition to verbally communicating preliminary inspection observations, the inspector(s), consistent
with regional practice, may provide written information concerning such observations during the closing
conference or after conclusion of the inspection. However, this information should not identify or
characterize such observations as "violations."
An "in-compliance" letter should not be sent to a facility.
The lead inspector should alert management personnel and employee representatives to situations that are in
need of immediate remediation (e.g., improper storage of incompatible chemicals).
The lead inspector should document in the inspection report whether a closing conference was conducted and,
if so, with whom. If a closing conference was not conducted, the report should include the reasons why the
conference was not conducted and confirm that contact information was left.
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(4): Concluding Activities
FoSSow-up Meeting
The inspector(s) should meet as soon as possible after completion of the site visit to ensure details of the
inspection are accurately recorded. At a minimum, inspector(s) should:
Immediately review and edit personal notes taken during the site visit for clarity and completeness;
Review report format, and identify any additional information needed to complete the report;
Review all important preliminary observations and facts obtained;
Agree on a date for the final report;
Differentiate recommendations from any observed potential noncompliance; and
Resolve recommendations that are not supported by team consensus.
Inspection Report
Sufficient documentation of the inspection is to be provided to allow for a compliance determination to be
made. To ensure sufficient documentation with complete information, the inspection report documenting a
Section 112(r) inspection should include the following basic elements. Annex D, Inspection Checklist (on page
D-l) may be helpful and also may be used as a component of the inspection report.
A basic profile of the facility and general information about the inspection:
ป Facility name, location, mailing address;
ป Facility contact, phone number, e-mail address;
ป Employee representative(s), phone number(s), e-mail address(es);
Nature, extent, and substance of the employee(s) and employee representative(s) involvement;
ป Date of inspection and name of inspector(s);
ป Inspection activities - e.g., processes and emission units evaluated; on-site observations; employee
interviews; whether compliance assistance was provided and if so, nature of assistance; any action taken
by facility to come back into compliance during on-site visit;
* Date and program levels of submitted RMP;
A description of the criteria, rationale, and factual information used to select the facility for an inspection
(including information on enforcement actions resulting from previous Section 112(r) inspections); and
* Observations and recommendations.
Each observation should be supported and documented with information collected through such activities as
document reviews, sampling, interviews and/or facility walkthroughs. The inspector(s) should only provide
factual observations without any legal conclusions about whether there were violations or deficiencies.
Preliminary inspection observations should be accompanied by recommendations based upon a comparative
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analysis of the observation with applicable rules, regulations, standards, and accepted guidance. Each
recommendation should cite the specific rules, regulations, standards, accepted guidance, or technical basis used
to formulate the recommendation. If more than one inspector participated in the inspection, the lead inspector
should consult with appropriate personnel in the implementing agency to determine if recommendations that
are not supported by team consensus should be included. Each inspector should sign the report. The original
report should be maintained by the implementing agency. When finalized, a copy of the report may be provided,
consistent with Regional practice, to facility owners/operators; employee representatives; the State Emergency
Response Commission; the Local Emergency Planning Committee in whose area the facility is located; and/
or other federal, state, and local agencies as appropriate. However, when considering whether to provide an
inspection report, the regional office must take into account the necessity to ensure trade secrets and confidential
business information are protected pursuant to statutory requirements and implementing agency regulations and
policies. Also, any potential enforcement action is not to be compromised when providing an inspection report.
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(5): Post-inspection Actions
Post-inspection actions will largely depend on the observations of the inspector and the information obtained
during the inspection. If observations and other information support the determination of violations, there
are several types of enforcement actions among which the implementing agency may choose to pursue.
Such actions include, for example, notices of violations, administrative orders, monetary fines and penalties,
injunctive relief, and supplemental environmental projects. Implementing agencies should consult applicable
enforcement response policies in order to determine appropriate enforcement actions.
Inspections do not necessarily result in enforcement actions. If the implementing agency concludes that
enforcement action is not warranted (e.g., only minor deficiencies are discovered during the inspection), the
implementing agency may choose to take no post-inspection actions or to provide compliance assistance. Such
assistance could include providing training, regulatory guidance, reference materials, or other information to
the facility owner/operator. Since implementing agencies have discretion in regulatory enforcement matters,
inspectors, case development officers and legal counsel should work in a coordinated manner when determining
the appropriate enforcement response.
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Annex A:
RMP Audits Conducted Pursuant to 40 CFR Part 68.220
Annex B:
Site Safety Plan for On-Site Activities
Annex C:
Inspection Report
Annex D:
Inspection Checklist
Annex E:
Risk Management Program and OSHA PSM:
List of Regulated Substances
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Annex A: RMP Audits Conducted Pursuant to 40 CFR
Part 68.220
This Annex describes the process for conducting audits in accordance with 40 CFR Part 68.220. In general,
the guidelines contained in the main document may be applied to both inspections and audits. However, Part
68.220 contains specific guidance to implementing agencies on selecting facilities for RMP audits, as well as on
resolving audit findings.
Selecting Facilities for RMP Audits
Under 68.220(b), the implementing agency may select facilities for audits based on any of the following criteria:
1. Accident hi story;
2. Accident history of other facilities in the same industry;
3. Quantity of regulated substances;
4. Location and proximity to the public and environmental receptors;
5. Presence of specific regulated substances;
6. Hazards identified in the RMP; or
7. A plan providing for neutral, random oversight.
Related criteria could include the number of accidental releases, whether there have been any catastrophic
accidental releases, and the known toxicity of chemicals used in the processes.
Facilities with a "Star" or "Merit" ranking under OSHA's voluntary protection program are exempt from audits
based solely on criteria (2) and (7). However, these facilities may be audited based on any of the other five
criteria [68.220(c)]. Each implementing agency should develop a targeting system, based on their resources and
priorities.
Under 40 CFR 68.220(d), the implementing agency shall have access to the facility, supporting documentation,
and any area where an accidental release could occur.
After-Audit Actions
Preliminary Determination
Based on the results of the audit, the implementing agency may issue the owner or operator a written
preliminary determination of necessary revisions to the facility's RMP to ensure that the RMP meets the
criteria of 40 CFR Part 68, Subpart G. The preliminary determination should include an explanation of the
basis for the revisions, reflecting applicable industry standards and guidelines (such as American Institute of
Chemical Engineers (AIChE)/Center for Chemical Process Safety (CCPS) guidelines and American Society
of Mechanical Engineers (ASME) and American Petroleum Institute (API) standards). The preliminary
determination should also include a timetable for the implementation of the revisions [68.220(e)].
A-1
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The owner or operator should respond in writing to the preliminary determination. The response should
state that the owner or operator will implement the revisions contained in the preliminary determination in
accordance with the timetable included in the preliminary determination, or should state that the owner or
operator rejects the revisions in whole or in part. For each rejected revision, the owner or operator should
explain the basis for rejecting that revision. Such explanation may include substitute revisions [68.220(f)(l)].
The owner or operator should submit the written response to the implementing agency within 90 days of
issuance of the preliminary determination. The implementing agency may specify a shorter period of time in the
preliminary determination to protect public health and the environment. Prior to the written response being due
and upon written request from the owner or operator, the implementing agency may provide additional time for
the response to be received [68.220(f)(2)].
Final Determination
After providing the owner or operator an opportunity to respond to the preliminary determination, the
implementing agency may issue the owner or operator a written final determination of necessary revisions to
the facility's RMP. The final determination may adopt or modify the revisions contained in the preliminary
determination, or may adopt or modify the substitute revisions provided in response to the preliminary
determination. A final determination that adopts a revision rejected by the owner or operator should include an
explanation of the basis for the revision. A final determination that fails to adopt a substitute revision provided
under 68.220(f) should include an explanation of the basis for finding such substitute revision unreasonable
[68.220(g)].
Thirty days after completion of the actions detailed in the implementation schedule set in the final
determination, the owner or operator will be in violation of subpart G of part 68 unless the owner or operator
revises the RMP, as required by the final determination, and submits the revised RMP [68.220(h)].
Once a final determination has been made and the facility is deemed to be in violation of 40 CFR Part 68,
the audit report along with the final determination should be referred to the appropriate program within
the implementing agency for enforcement actions. If warranted, the implementing agency may initiate an
enforcement action, rather than use the preliminary and final determination process.
The public should have access to the preliminary determination, response, and final determination pursuant to
42 U.S.C. 7414(c) [68.210(a), 68.220(1)]. The disclosure of classified information by the Department of Defense
or other federal agencies or contractors of such agencies will be controlled by applicable laws, regulations, or
executive orders concerning the release of classified information [68.210(b)].
None of the actions described above will preclude, limit, or interfere in any way with the authority of the
implementing agency to exercise its enforcement, investigatory, and information gathering authorities under the
CAA concerning accidental releases [68.220(j)].
A-2
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B: Site Plan for
The EPA Safety Manual and other EPA policies articulate certain safety planning efforts prior to field activities.
The following format is consistent with these requirements. Extensive training and certifications, and further
planning in the form of a more extensive Site Safety Plan, may be necessary in addition to the following plan.
FACILITY:
LEAD INSPECTOR:
DATE:
DESCRIPTION OF ACTIVITIES
Location and approximate size of facility:
Description of activities to be performed by each of the inspectors:
Proposed date of on-site activities beginning:
Duration of the planned activities:
Site topography:
Site accessibility by roads and air:
B-1
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HAZARDOUS AND HEALTH INVOLVED OR AT THE SITE
(Fill in any information that is known or suspected)
CHEMICAL AND PHYSICAL
PROPERTIES
Expiosivity
IDENTITY OF SUBSTANCE AND PRECAUTIONS
Radioactivity
Oxygen deficiency
(e.g., confined spaces)
Toxic gases
Skin/eye contact hazards
Heat stress
Pathways from site for hazardous substance dispersion:
B-2
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WORK PLAN INSTRUCTIONS
Recommended level of protection:
] ] A
n B
[Jc
Cartridge type if level C:
Monitoring equipment to be used:
Accompanying/helping persons (facility/contractors):
Safety clothing/equipment required for those persons:
OSHA required training and certification (29 CFR 1910.120) received by those persons:
FIELD INVESTIGATION AND DECONTAMINATION
Decontamination procedures (e.g., contaminated protective clothing, instruments, equipment):
Disposal procedures (e.g., contaminated equipment, supplies, disposable items, washwater):
B-3
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CONTACTS
Hospital Name/Location:
Hospital Phone No.:
Fax:
Emergency Medial Treatment Phone No.
Fax:
Ambulance Phone No.
Fax:
Police Phone No.
Fire Assistance Phone No.
Regional Health and Safety Officer
(or position with similar duties):
Phone No.:
B-4
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C:
Note: A report similar to this will be generated by RMP*Review, the software available to RMP implementing
agencies.
EPA facility ID #:
City:
Date:
State:
County:
INSPECTION TEAM:
Lead Inspector:
Inspectors:
Date(s) of facility visit:
I. FACILITY IDENTIFICATION
Name:
Street Address:
City:
State:
.County:
Zip:
Latitude:
Longitude:
Dun & Bradstreet (D&B) No.:
Name, address, and D&B of corporate parent company (if applicable):
Owner/operator:
E-mail Address:
Phone No.
Mailing Address:
C-1
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City: State: Zip:
Contact information of person responsible for 40 CFR Part 68 implementation:
Name: Title: Phone No.:
E-mail Address:
Name and title of emergency contact:
Name: Title:
Day Phone: 24-hour Phone: Cell:.
E-mail Address:
Names, titles, phone numbers and e-mail addresses of facility personnel/employee representatives involved in
inspection. Include information on nature, extent, and substance of such involvement (e.g., accompanied site
tours; provided documents and explanatory information; participated in interviews):
II. AND LEVELS OF SUBMITTED RMP
Date of Initial Submission: / /
Date of Latest Update: / /
Process (Program 1, 2, 3) as reported in RMP:
Process ID#: Program Level: NAICS Code:
CRITERIA, RATIONALE, and FACTUAL INFORMATION used to select the facility for an inspection
(including information on enforcement actions resulting from previous Section 112(r) inspections:
C-2
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III. INSPECTION ACTIVITIES
(e.g., processes and emission units evaluated; on-site observations; employee interviews; whether compliance
assistance was provided and if so, nature of assistance; any action taken by facility to come back into
compliance during on-site visit):
IV. AND RECOMMENDATIONS
Signatures:
Lead Inspector:
Inspectors:
Approved by:
Signature: Date:
Title:
* Observations and recommendations may be presented in one or more attachments and referred to in the report.
C-3
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D:
Process inspected:
Inspector:
Instructions: This checklist may be used for verification of RMP and Program compliance
(Check boxes coding: Y=Yes, N=No, P=Partial, A=Not Applicable)
Note: Compliance Objectives are listed in the order they appear in the RMP rule
D-1
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Compliance Objectives Notes
1. MANAGEMENT AND PLAN (SUBPART A)
[68.1-68.15]
Applicability [68.1]
_ I . I Does the owner or operator of the stationary source have
more than a threshold quantity of a regulated substance in a
process? [68.10(a)]
_ 1 .2 Has the process had, in the five years prior to submission of
the RMP, an accidental release of a regulated substance where
exposure to the substance, its reaction products, overpressure
generated by an explosion involving the substance, or radiant
heat generated by a fire involving the substance led to any of
the following off-site:
(i) Death; (ii) Injury; or (iii) Response or restoration activities
for an exposure of an environmental receptor? [68.10(b)(l)]
_ 1 .3 Is the distance to a toxic or flammable endpoint for a worst-
case release assessment less than the distance to any public
receptor? [68.10(b)(2)]
_ 1 .4 Has the owner or operator coordinated emergency response
procedures between the stationary source and local
emergency planning and response organizations?
[68.10(b)(3)]
_ 1.5 Is the covered process subject to OSHA PSM standard, 29
CFR 1910. 119? [68.10(d)(2)]
_ 1.6 Is the covered process in one of the NAICS codes listed in 40
CFR ง68.10(d) (1)?
Inspector may need to re-answer 1.5 and 1.6 for multiple processes in comments section.
_ 1 .7 Has the owner or operator submitted a single RMP, which
included a registration that reflects all covered processes, as
provided in 68. 150 to 68. 185? [68.12(a)]
1.8 For Program 1 processes inspected, has the owner or operator:
[68.12(b)]
_ 1.8.1 Analyzed the worst-case release scenario for the process(es),
as provided in 68.25; [68.12(b)(l)]
_ 1.8.2 Documented that the nearest public receptors is beyond the
distance to an endpoint defined in 68.22(a); and [68.12(b)(l)J
_ 1.8.3 Included the scenario(s) in the RMP as provided in 68.165?
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Compliance Objectives Notes
1.8.4 Completed the five-year accident history for the process as
provided in 68.42 [68.12(b)(2)]; and
1.8.5 Included the history in the RMP as provided in 68.168?
[68.12(b)(2)]
1.8.6 Ensured that response actions have been coordinated with
local emergency planning and response agencies?
[68.12(b)(3)]
1.8.7 Included the appropriate certification statement for Program 1
processes? [68.12(b)(4)]
1.9 For Program 2 processes, has the owner or operator:
[68.12(c)]
1.9.1 Developed and implemented a management system as
provided in 68.15? [68.12(c)(l)]
1.9.2 Conducted a hazard assessment as provided in 68.20 through
68.42? [68.12(c)(2)]
1.9.3 Implemented the Program 2 prevention steps provided in
68.48 through 68.60 or implemented the Program 3
prevention steps provided in 68.65 through 68.87?
[68.12(c)(3)]
1.9.4 Developed and implemented an emergency response program
as provided in 68.90 to 68.95? [68.12(c)(4)]
1.9.5 Submitted, as part of the RMP, the data on prevention
program elements for Program 2 processes as provided in
68.170? [68.12(c)(5)]
1.10 For Program 3 processes, has the owner or operator:
[68.12(d)]
1.10.1 Developed and implemented a management system as
provided in 68.15? [68.12(d)(l)]
1.10.2 Conducted a hazard assessment as provided in 68.20 through
68.42? [68.12(d)(2)]
1.10.3 Implemented the prevention requirements provided in 68.65
through 68.87? [68.12(d)(3)]
1.10.4 Developed and implemented an emergency response program
as provided in 68.90 to 68.95? [68.12(d)(4)]
1.10.5 Submitted, as part of the RMP, the data on prevention
program elements for Program 3 processes as provided in
68.175? [68.12(d)(5)]
D-3
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Compliance Objectives Notes
Management [68.15]
Has the owner or operator:
1.11 Developed a management system to oversee the
implementation of the Risk Management Program elements?
[68.15(a)]
1.12 Assigned a qualified person or position that has the overall
responsibility for the development, implementation,
and integration of the Risk Management Program elements?
[68.15(b)]
1.13 Documented other persons responsible for implementing
individual requirements of the Risk Management Program
and defined the lines of authority through an organization
chart or similar document? [68.15(c)J
Findings:
Documentation obtained to support Findings:
D-4
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Compliance Objectives Notes
2. RMP (SUBPART G)
[68.150-68.190]
2.1 Did the owner or operator submit an RMP on or before June
21, 1999? Postmark date of initial submission:
[68.10, 68.10(a)(l), 68.150(a) & (b)]
If submission was after June 21, 1999, was submittal required
because: [68.10 & 68.150(b)]
2.1.1 Initial listing of a regulated substance under 68.130 after June
21, 1999 [68.10(a)(2) & 68.150(b)(2)]
2.1.2 A regulated substance was first present at the stationary
source above the threshold quantity in a process [68.10(a)(3)
&68.150(b)(2)]
2.2 Has the owner or operator revised and updated the RMP
within 5 years of initial submission? Date of the last revision
and update [68.190(a)]:
2.3 If required, has the owner or operator submitted a revised
RMP for any of the following: [68.190(b)]
2.3.1 Within 3 years after EPA first listed a newly regulated
substance? [68.190(b)(2)]
2.3.2 No later than the date on which a new regulated substance is
first present in an already covered process above a threshold
quantity? [68.190(b)(3)]
2.3.3 No later than the date on which a regulated substance is first
present above a threshold quantity in a new process?
[68.190(b)(4)]
2.3.4 Within six months of a change that requires a revised PHA or
hazard review? [68.190(b)(5)]
2.3.5 Within six months of a change that requires a revised off-site
consequence analysis as provided in 68.36? [68.190(b)(6)]
2.3.6 Within six months of a change that alters the Program level
that applied to any covered process? [68.190(b)(7)]
2.4 Has the owner or operator included information submitted as
CBIintheRMP? [68.150(d)]
2.4.1 If so, were the provisions of 68.151 and 68.152 followed?
D-5
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Compliance Objectives Notes
RMP: Executive Summary [68.155]
2.5 Has the owner or operator included a brief description of the
following elements in the executive summary of the RMP:
[68.155]
2.5.1 The accidental release prevention and emergency response
policies at the stationary source? [68.155(a)J
2.5.2 The stationary source and regulated substances handled?
[68.155(b)]
2.5.3 The general accidental release prevention program and
chemical-specific prevention steps? [68.155(c)J
2.5.4 The five-year accident history? [68.155(d)]
2.5.5 The emergency response program? [68.155(e)J
2.5.6 Planned changes to improve safety? [68.155(f)]
RMP: Registration [68.160]
2.6 Has the owner or operator included a single registration form
in the RMP which covers all regulated substances handled in
covered processes? [68.160(a)]
2.7 Does the registration include the following data: [68.160(b)]
2.7.1 Stationary source name, full address, Dun and Bradstreet
number; longitude and latitude with method and description?
[68.160(b)(l)&(2)]
2.7.2 Corporate parent company name and Dun and Bradstreet
number? [68.160(b)(3)]
2.7.3 The name, telephone number, and mailing address of the
owner or operator? [68.160(b)(4)]
2.7.4 The name and title of the person or position with overall
responsibility for RMP elements and implementation?
[68.160(b)(5)]
2.7.5 The name, title, telephone number, and 24-hour number of the
emergency contact? [68.160(b)(6)]
2.7.6 For each covered process, the name and CAS number of each
regulated substance held above the threshold quantity in the
process, the maximum quantity of each regulated substance
or mixture in the process, the NAICS code, and the Program
level of the process? [68.160(b)(7)]
2.7.7 The stationary source EPA identifier? [68.160(b)(8)]
D-6
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Compliance Objectives Notes
_ 2.7.8 The number of full-time employees at the stationary source?
[68.160(b)(9)]
_ 2.7.9 Whether the stationary source is subject of 29 CFR
ง1910.119, OSHA's Process Safety Management Standard?
[68.160(b)(10)]
_ 2.7.10 Whether the stationary source is subject to 40 CFR Part 355,
the Emergency Planning Requirements of the Emergency
Planning and Community Right-to-Know Act?
_ 2.7. 1 1 If the stationary source has a CAA Title V operating permit,
its permit number? [68.160(b)(12)]
_ 2.7. 12 The date of the last safety inspection of the stationary source
by a Federal, state, or local government agency and the
identity of the inspecting entity? [68.160(b)(13)]
RMP: Off-site Consequence Analysis [68.165]
2.8 Does the RMP include the following: [68. 165(a)]
_ 2.8. 1 One worst-case release scenario for each Program 1 process?
[68.165(a)(l)]
_ 2.8.2 For Program 2 and 3 processes, one worst-case release
scenario to represent all regulated toxic substances held above
the threshold quantity and one worst-case release scenario to
represent all regulated flammable substances held above the
threshold quantity? [68.165(a)(2)]
_ 2.8.3 For Program 2 and 3 processes, were additional worst-case
scenarios also submitted, if required by 68.25(a)(2)(iii)?
[68.165(a)(2)]
_ 2.8.4 For Program 2 and 3 processes, was information submitted on
one alternative scenario for each regulated toxic substance
held above the threshold quantity and one alternative scenario
to represent all regulated flammable substances held above
the threshold? [68.165(a)(2)]
2.9 Does the RMP include the following information for each
submitted release scenario: [68.165(b)J
_ 2.9. 1 Scenario type (explosion, fire, toxic gas release, or liquid spill
and vaporization)? [68.165(b)(5)]
_ 2.9.2 Chemical name of released substance? [68.165(b)(l)]
_ 2.9.3 Percentage weight of the chemical in a liquid mixture (toxics
only)? [68.165(b)(2)]
_ 2.9.4 Physical state of substance (toxics only)? [68.165(b)(3)]
, , D-7
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Compliance Objectives Notes
2.9.5 Basis of results (model name if used)? [68.165(b)(4)]
2.9.6 Quantity released in pounds? [68.165(b)(6)]
2.9.7 Release rate? [68.165(b)(7)]
2.9.8 Release duration? [68.165(b)(8)]
2.9.9 Wind speed and atmospheric stability class (toxics only)?
[68.165(b)(9)]
2.9.10 Topography (toxics only)? [68.165(b)(10)]
2.9.11 Distance to endpoint? [68.165(b)(ll)]
2.9.12 Public and environmental receptors within the distance?
[68.165(b)(12)]
2.9.13 Passive mitigation considered? [68.165(b)(13)]
2.9.14 Active mitigation considered (alternative releases scenarios
only)?[68.165(b)(14)]
RMP: Five-Yenr Accident History [68.168]
2.10 Has the owner or operator provided the five-year accident
history information in 68.42 on each accident covered by
68.42? [68.168]
2.11 Does the RMP include the following information for each
reported accidental release: [68.42(b)J
2.11.1 Date, time, and approximate duration of the release?
[68.42(b)(l)]
2.11.2 Chemical(s) released? [68.42(b)(2)]
2.11.3 Estimated quantity released in pounds and percentage weight
in a mixture (toxics)? [68.42(b)(3)]
2.11.4 NAICS code for the process? [68.42(b)(4)]
2.11.5 The type of release event and its source? [68.42(b)(5)]
2.11.6 Weather conditions (if known)? [68.42(b)(6)]
2.11.7 On-site impacts? [68.42(b)(7)]
2.11.8 Known offsite impacts? [68.42(b)(8)]
2.11.9 Initiating event and contributing factors (if known)?
[68.42(b)(9)]
2.11.10 Whether offsite responders were notified (if known)?
[68.42(b)(10)]
2.11.11 Operational or process changes that resulted from
investigation of the release? [68.42(b)(ll)]
D-8
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Compliance Objectives Notes
RMP: Prevention Program/Program 2 [68.170]
2.12 Has the owner or operator included the following information
for each covered process in Program 2: [68.170(a)]
2.12.1 The NAICS code for the process? [68.170(b)]
2.12.2 The name(s) of the chemical(s) covered? [68.170(c)]
2.12.3 The date of the most recent review or revision of the safety
information and a list of Federal or state regulations or
industry-specific design codes and standards used to
demonstrate compliance with the safety information
requirement. [68.170(d)]
2.12.4 The date of completion of the most recent hazard review or
update? [68.170(e)]
2.12.4.1 The expected date of completion of any changes resulting
from the hazard review or update? [68.170(e)(l)]
2.12.4.2 Major hazards identified? [68.170(e)(2)]
2.12.4.3 Process controls in use? [68.170(e)(3)]
2.12.4.4 Mitigation systems in use? [68.170(e)(4)]
2.12.4.5 Monitoring and detection systems in use? [68.170(e)(5)]
2.12.4.6 Changes since the last hazard review? [68.170(e)(6)]
2.12.5 The date of the most recent review or revision of operating
procedures? [68.170(f)]
2.12.6 The date of the most recent review or revision of training
programs? [68.170(g)]
2.12.6.1 The type of training providedclassroom, classroom plus on
the job, on the job? [68.170(g)(l)]
2.12.6.2 The type of competency testing used? [68.170(g)(2)]
2.12.7 The date of the most recent review or revision of maintenance
procedures and the date of the most recent equipment
inspection or test and the equipment inspected or tested?
[68.170(h)]
2.12.8 The date of the most recent compliance audit and the
expected date of completion of any changes resulting from
the compliance audit? [68.170(1)]
2.12.9 The date of the most recent incident investigation and the
expected date of completion of any changes resulting from
the investigation? [68.170(j)]
D-9
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Compliance Objectives Notes
2.12.10 The date of the most recent change that triggered a review or
revision of safety information, hazard review, operating or
maintenance procedures, or training? [68.170(k)]
RMP: Prevention Program/Program 3 [68.175]
2.13 Has the owner or operator included in the RMP information
addressing 68.175(b) to 68.175(p)? [68.175(a)]
2.13.1 The NAICS code for the process? [68.175(b)]
2.13.2 The name(s) of the substance(s) covered? [68.175(c)]
2.13.3 The date on which the safety information was last reviewed or
revised? [68.175(d)]
2.13.4 The date of completion of the most recent process hazard
analysis (PHA) or update and the technique used? [68.175(e)]
2.13.4.1 The expected date of completion of any changes resulting
from the PHA? [68.175(e)(l)]
2.13.4.2 Major hazards identified? [68.175(e)(2)]
2.13.4.3 Process controls in use? [68.175(e)(3)]
2.13.4.4 Mitigation systems in use? [68.175(e)(4)J
2.13.4.5 Monitoring and detection systems in use? [68.175(e)(5)]
2.13.4.6 Changes since the last PHA? [68.175(e)(6)]
2.13.5 The date of the most recent review or revision of operating
procedures? [68.175(f)]
2.13.6 The date of the most recent review or revision of training
programs? [68.175(g)]
2.13.6.1 The type of training provided - classroom, classroom plus on
the job, on the job? [68.175(g)(l)]
2.13.6.2 The type of competency testing used? [68.175(g)(2)]
2.13.6.1 The type of training provided - classroom, classroom plus on
the job, on the job? [68.175(g)(l)]
2.13.6.2 The type of competency testing used? [68.175(g)(2)]
2.13.7 The date of the most recent review of revision of maintenance
procedures and the date of the most recent equipment
inspection or test and the equipment inspected of tested?
[68.175(h)]
D-10
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Compliance Objectives Notes
2.13.8 The date of the most recent change that triggered
management of change procedures and the date of the
most recent review or revision of management of change
procedures? [68.175(1)]
2.13.9 The date of the most recent pre-startup review? [68.175(j)]
2.13.10 The date of the most recent compliance audit and the
expected date of completion of any changes resulting from
the compliance audit? [68.175(k)]
2.13.11 The date of the most recent incident investigation and the
expected date of completion of any changes resulting from
the investigation? [68.175(1)]
2.13.12 The date of the most recent review or revision of employee
participation plans? [68.175(m)]
2.13.13 The date of the most recent review or revision of hot work
permit procedures? [68.175(n)]
2.13.14 The date of the most recent review or revision of contractor
safety procedures? [68.175(o)]
2.13.15 The date of the most recent evaluation of contractor safety
performance? [68.175(p)]
RMP: Emergency Response Program [68.180]
2.14 Has the owner or operator included the following information
in the RMP on the emergency response program: [68.18]
2.14.1 Does a written emergency response plan exist? [68.180(a)(l)]
2.14.2 Does the plan include specific actions to be taken in response
to an accidental release of a regulated substance?
[68.180(a)(2)]
2.14.3 Does the plan include procedures for informing the public and
local agencies responsible for responding to accidental
releases? [68.180(a)(3)]
2.14.4 Does the plan include information on emergency health care?
[68.180(a)(4)]
2.14.5 Date of the most recent review of update of emergency
response plan? [68.180(a)(5)]
2.14.6 Date of the most recent emergency response training for
employees? [68.180(a)(6)]
D-11
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Compliance Objectives Notes
2.15 Has the owner or operator provided the name and telephone
number of the local agency with which emergency response
activities and the emergency response plan is coordinated?
[68.180(b)]
2.16 Has the owner or operator listed other Federal or state
emergency plan requirements to which the stationary source
is subject? [68.180(c)]
RMP: Certification [68.185]
2.17 Has the owner or operator: [68.185]
2.18 For Program 1 processes, submitted the certification
statement in 68.12(b)(4)? [68.185(a)]
2.19 For Program 2 or 3 processes, submitted the appropriate
certification statement that to the best of the signer's
knowledge, information, and belief formed after
reasonable inquiry, the information submitted is true,
accurate, and complete? [68.185(b)J
Findings:
Documentation obtained to support Findings:
D-12
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Compliance Objectives Notes
3. (SU BPART B)
-
Hazard Assessment: Applicability [68.20]
3.1 Has the owner or operator prepared a worst-case release
scenario analysis as provided in 68.25 and completed the five-
year accident history as provided in 68.42? [68.20]
Hazard Assessment: Offsite Consequence Analysis Parameters [68.22]
3.2 Has the owner or operator used the following endpoints for
offsite consequence analysis for a worst-case scenario:
[68.22(a)]
3.2.1 For toxics: the endpoints provided in Appendix A of 40 CFR
Part 68? [68.22(a)(l)]
3.2.2 For flammables: an explosion resulting in an overpressure of
1 psi? [68.22(a)(2)(i)]
3.3 Has the owner or operator used the following endpoints for
offsite consequence analysis for an alternative release
scenario: [68.22(a)]
3.3.1 For toxics: the endpoints provided in Appendix A of 40 CFR
Part 68? [68.22(a)(l)]
3.3.2 For flammables: an explosion resulting in an overpressure of
1 psi? [68.22(a)(2)(i)]
3.3.3 For flammables: a fire resulting in a radiant heat/exposure of 5
kw/m2 for 40 seconds? [68.22(a)(2)(ii)]
3.3.4 For flammables: a concentration resulting in a lower
flammability limit, as provided in NFPA documents or other
generally recognized sources? [68.22(a)(2)(iii)J
3.4 In the release analysis, has the owner or operator used
appropriate values for the following parameters:
3.4.1 Wind speed and atmospheric stability class?
3.4.2 Ambient temperature and humidity?
3.4.3 Height of the release?
3.4.4 Surface roughness?
3.4.5 Dense or neutrally buoyant gases?
3.4.6 Temperature of the released substance?
D-13
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Compliance Objectives Notes
Hazard Assessment: Worst-case Release Scenario Analysis [68.25]
3.5 Has the owner or operator of Program I processes:
3.5.1 Analyzed and reported in the RMP one worst-case scenario
for each Program 1 process? [68.25(a)(l)J
3.6 Has the owner or operator of Program 2 or 3 processes:
3.6.1 Analyzed and reported in the RMP one worst-case release
scenario estimated to create the greatest distance to an
endpoint resulting from an accidental release
of a regulated toxic substance from covered processes under
worst-case conditions? [68.25(a)(2)(i)]
3.6.2 Analyzed and reported in the RMP one worst-case release
scenario estimated to create the greatest distance to
an endpoint resulting from an accidental release of a regulated
flammable substance from covered processes under worst-
case conditions? [68.25(a)(2)(ii)]
3.6.3 Analyzed and reported in the RMP additional worst-case
release scenarios for a hazard class if the a worst-case release
from another covered process at the stationary
source potentially affects public receptors different
from those potentially affected by the worst-case release
scenario developed under 68.25(a)(2)(i) or 68.25(a) (2)
(ii)?
3.7 Has the owner or operator determined the worst-case release
quantity to be the greater of the following: [68.25(b)J
3.7. 1 If released from a vessel, the greatest amount held in a single
vessel, taking into account administrative controls that
limit the maximum quantity? [68.25(b)(l)J
3.7.2 If released from a pipe, the greatest amount held in the pipe,
taking into account administrative controls that limit the
maximum quantity? [68.25(b)(2)]
3.8 For toxic substances that are normally gases at ambient
temperature and handled as a gas or liquid under pressure, has
the owner or operator: [68.25(c)(l)J
3.8.1 Assumed the whole quantity in the vessel or pipe would be
released as a gas over 10 minutes? [68.25(c)(l)J
3.8.2 Assumed the release rate to be the total quantity divided by
10, if there are no passive mitigation systems in place?
[68.25(c)(l)]
3.9 For toxic gases handled as refrigerated liquids at ambient
pressure, has the owner or operator: [68.25(c)(2)J
D-14
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Compliance Objectives Notes
3.9.1 Assumed the substance would be released as a gas in 10
minutes, if not contained by passive mitigation systems or if
the contained pool would have a depth of 1 cm
orless?[68.25(c)(2)(i)]
3.9.2 Assumed the quantity in the vessel or pipe would be spilled
instantaneously to form a liquid pool, if the released
substance would be contained by passive mitigation systems
in a pool with a depth greater than 1 cm? [68.25(c)(2)(ii)J
3.9.3 Calculated the volatilization rate at the boiling point of the
substance and at the conditions specified in 68.25(d)?
[68.25(c)(2)(ii)]
3.10 For toxic substances that are normally liquids at ambient
temperature, has the owner or operator: [68.25(d)J
3.10.1 Assumed the quantity in the vessel or pipe would be spilled
instantaneously to form a liquid pool? [68.25(d)(l)J
3.10.2 Determined the surface area of the pool by assuming that the
liquid spreads to 1 cm deep, if there is no passive mitigation
system in place that would serve to contain the spill and limit
the surface area, or if passive mitigation is in place,
the surface area of the contained liquid shall be
used to calculate the volatilization rate? [68.25(d)(l)(i)]
3.10.3 Taken into account the actual surface characteristics, if the
release would occur onto a surface that is not paved or
smooth? [68.25(d)(l)(ii)]
3.10.4 Determined the volatilization rate by accounting for the
highest daily maximum temperature in the past three years,
the temperature of the substance in the vessel, and the
concentration of the substance if the liquid spilled is a
mixture or solution? [68.25(d)(2)]
3.10.5 Determined the rate of release to air from the volatilization
rate of the liquid pool? [68.25(d)(3)]
3.10.6 Determined the rate of release to air by using the
methodology in the RMP Offsite Consequence
Analysis Guidance, any other publicly available
techniques hat account for the modeling conditions
and are recognized by industry as applicable as part of
current practices, or proprietary models that account
for the modeling conditions may be used provided the owner
or operator allows the implementing agency access to the
model and describes model features and differences
from publicly available models to local emergency planners
upon request. [68.25(d)(3)]
D-15
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Compliance Objectives Notes
3.11 For flammables, has the owner or operator:
3.11.1 Assumed the quantity in a vessel(s) of flammable gas held as
a gas or liquid under pressure or refrigerated gas released to
an undiked area vaporizes resulting in a vapor cloud
explosion? [68.25(e)]
3.11.2 For refrigerated gas released to a contained area or liquids
released below their atmospheric boiling point, assumed the
quantity volatilized in 10 minutes results in a vapor cloud.
[68.25(f)]
3.11.3 Assumed a yield factor of 10% of the available energy is
released in the explosion for determining the distance to the
explosion endpoint, if the model used is based on TNT-
equivalent methods? [68.25(e)J
3.12 Has the owner or operator used the parameters defined in
68.22 to determine distance to the endpoints? [68.25(g)J
3.13 Has the owner or operator determined the rate of release to
air by using the methodology in the RMP Offsite
Consequence Analysis Guidance, any other publicly available
techniques that account for the modeling conditions and are
recognized by industry as applicable as part of current
practices, or proprietary models that account for the modeling
conditions? [68.25(g)]
3.13.1 Modeling technique used:
3.14 Has the owner or operator ensured that any passive mitigation
system considered for the worst case analysis is capable of
withstanding the release event triggering the scenario and will
still function as intended? [68.25(h)]
3.15 Has the owner or operator considered selecting a scenario
involving a smaller quantity handled at higher process
temperature or pressure, or located closer to the boundary of
the stationary source, if such a scenario would result
in a greater distance to an endpoint beyond the
stationary source boundary? [68.25(1)]
Hazard Assessment: Alternative Release Scenario Analysis [68.28]
3.16 Has the owner or operator identified and analyzed at least one
alternative release scenario for each regulated toxic substance
held in covered processes and at least one alternative release
scenario to represent all flammable substances held in covered
processes? [68.28(a)]
D-16
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Compliance Objectives Notes
3.17 Has the owner or operator selected a scenario: [68.28(b)J
3.17.1 That is more likely to occur than the worst-case release
scenario under 68.25? [68.28(b)(l)(i)]
3.17.2 That will reach an endpoint off-site, unless no such scenario
exists? [68.28(b)(l)(ii)]
3.18 Has the owner or operator considered release scenarios which
included, but are not limited to, the following: [68.28(b)(2)]
3.18.1 Transfer hose releases due to splits or sudden hose
uncoupling? [68.28(b)(2)(i)]
3.18.2 Process piping releases from failures at flanges, joints, welds,
valves and valve seals, and drains or bleeds? [68.28(b)(2)(ii)]
3.18.3 Process vessel or pump releases due to cracks, seal failure, or
drain, bleed, or plug failure? [68.28(b)(2)(iii)]
3.18.4 Vessel overfilling and spill, or overpressurization and venting
through relief valves or rupture disks? [68.28(b)(2)(iv)]
3.18.5 Shipping container mi shandling and breakage or puncturing
leading to a spill? [68.28(b)(2)(v)]
3.19 Used the parameters defined in 68.22 to determine distance to
the endpoints? [68.28(c)]
3.20 Has the owner or operator determined the rate of release to
air by using the methodology in the RMP Offsite
Consequence Analysis Guidance, any other publicly
available techniques that account for the modeling conditions
and are recognized by industry as applicable as part of current
practices, or proprietary models that account for the modeling
conditions? [68.28(c)]
3.21 Has the owner or operator ensured that the passive and
active mitigation systems, if considered, are capable of
withstanding the release event triggering the scenario and will
be functional? [68.28(d)]
3.22 Has the owner or operator considered the following factors in
selecting the alternative release scenarios: [68.25(e)J
3.22.1 The five-year accident history provided in 68.42?
[68.25(e)(l)]
3.22.2 Failure scenarios identified under 68.50 or 68.67?
[68.25(e)(2)]
D-17
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Compliance Objectives Notes
Hazard Assessment: Defining Off-site Impacts - Population [68.30]
Has the owner or operator:
3.23 Estimated population that would be included in the distance
to the endpoint in the RMP based on a circle with the point of
release at the center? [68.30(a)J
3.24 Identified the presence of institutions, parks and recreational
areas, major commercial, office, and industrial buildings in
the RMP? [68.30(b)]
3.25 Used most recent Census data, or other updated information
to estimate the population? [68.30(c)J
3.26 Estimated the population to two significant digits? [68.30(d)]
Hazard Assessment: Defining Off-site Impacts - Environment [68.33]
Has the owner or operator:
3.27 Identified environmental receptors that would be included in
the distance to the endpoint based on a circle with the point of
release at the center? [68.33(a)J
3.28 Relied on information provided on local U.S.G.S. maps,
or on any data source containing U.S.G.S. data to identify
environmental receptors? [Source may have used LandView
to obtain information ] [68.33(b)J
Hazard Assessment: Review and Update [68.36]
Has the owner or operator:
3.29 Reviewed and updated the off-site consequence analyses at
least once every five years? [68.36(a)J
3.30 Completed a revised analysis and submit a revised RMP
within six months of a change in processes, quantities
stored or handled, or any other aspect that might reasonably
be expected on increase or decrease the distance to the
endpoint by a factor of two or more? [68.36(b)J
Hazard Assessment: Documentation [68.39]
Has the owner or operator:
3.31 For worst-case scenarios: a description of the vessel or
pipeline and substance selected, assumptions and parameters
used, the rationale for selection, and anticipated effect of the
administrative controls and passive mitigation on
the release quantity and rate? [68.39(a)J
D-18
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Compliance Objectives Notes
3.32 For alternative release scenarios: a description of the
scenarios identified, assumptions and parameters used,
the rationale for the selection of specific scenarios, and
anticipated effect of the administrative controls and mitigation
on the release quantity and rate?[68.39(b)]
3.33 Documentation of estimated quantity released, release rate,
and duration of release? [68.39(c)J
3.34 Methodology used to determine distance to endpoints?
[68.39(d)]
3.35 Data used to estimate population and environmental receptors
potentially affected? [68.39(e)]
Hazard Assessment: Five-Year Accident History [68.42]
3.36 Has the owner or operator included all accidental releases
from covered processes that resulted in deaths, injuries, or
significant property damage on site, or known offsite deaths,
injuries, evacuations, sheltering in place, property damage, or
environmental damage? [68.42(a)J
3.37 Has the owner or operator reported the following information
for each accidental release: [68.42(b)J
3.37.1 Date, time, and approximate duration of the release?
[68.42(b)(l)]
3.37.2 Chemical(s) released? [68.42(b)(2)]
3.37.3 Estimated quantity released in pounds and percentage weight
in a mixture (toxics)? [68.42(b)(3)]
3.37.4 NAICS code for the process? [68.42(b)(4)
3.37.5 The type of release event and its source? [68.42(b)(5)J
3.37.6 Weather conditions (if known)? [68.42(b)(6)]
3.37.7 On-site impacts? [68.42(b)(7>]
3.37.8 Known offsite impacts? [68.42(b)(8)]
3.37.9 Initiating event and contributing factors (if known)?
[68.42(b)(9>]
3.37.10 Whether offsite responders were notified (if known)?
[68.42(b)(10)]
3.37.11 Operational or process changes that resulted from
investigation of the release? [68.42(b)(ll)J
D-19
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Compliance Objectives Notes
Findings:
Documentation obtained to support Findings:
D-20
-------
Compliance Objectives Notes
4. 2 PREVENTION (SUBPART C)
-
Program 2 Prevention: Safety Information [68.48]
Has the owner or operator:
4.1 Compiled and maintained the following up-to-date safety
information, related to the regulated substances, processes,
and equipment: [68.48(a)J
4.1.1 Material Safety Data Sheets (MSDS) that meet the
requirements of the OSHA Hazard Communication Standard
[29 CFR 1910.1200(g)]? [68.48(a)(l)]
4.1.2 Maximum intended inventory of equipment in which the
regulated substances are stored or processed? [68.48(a)(2)J
4.1.3 Safe upper and lower temperatures, pressures, flows, and
compositions? [68.48(a)(3)]
4.1.4 Equipment specifications? [68.48(a)(4)]
4.1.5 Codes and standards used to design, build, and operate the
process? [68.48(a)(5)]
4.2 Ensured the process is designed in compliance with
recognized and generally accepted good engineering
practices? [68.48(b)]
4.3 Updated information if a major change has occurred that
made the information inaccurate? [68.48(c)J
Program 2 Prevention: Hazard Review [68.50]
4.4 Has the owner or operator conducted a review of the hazards
associated with the regulated substances, processes, and
procedures? [68.50(a)]
4.5 Did the review identify:
4.5.1 The hazards associated with the process and regulated
substances? [68.50(a)(l)]
4.5.2 Opportunities for equipment malfunctions or human errors
that could cause an accidental release? [68.50(a)(2)]
4.5.3 The safeguards used or needed to control the hazards or
prevent equipment malfunctions or human error?
[68.50(a)(3)]
4.5.4 Any steps used or needed to detect or monitor releases?
[68.50(a)(4)]
D-21
-------
Compliance Objectives Notes
Has the owner or operator:
4.6 Determined by inspecting all equipment that the processes are
designed, fabricated, and operated in accordance with
applicable standards or rules, if designed to meet industry
standards or Federal or state design rules? [68.50(b)J
4.7 Documented the results of the review? [68.50(c)]
4.8 Ensured that problems identified were resolved in a timely
manner? [68.50(c)]
4.9 Updated the review at least once every five years or whenever
a major change in the processes occurred? [68.50(d)J
4.10 Resolved all issues identified in the review before startup of
the changed process? [68.50(d)J
Program 2 Prevention: Operating Procedures [68.52]
4.11 Has the owner or operator prepared written operating
procedures that provide clear instructions or steps for
safely conducting activities associated with each covered
process consistent with the safety information for that
process? [68.52(a)]
4.12 Do the procedures address the following: [68.52(b)J
4.12.1 Initial startup? [68.52(b)(l)]
4.12.2 Normal operations? [68.52(b)(2)]
4.12.3 Temporary operations? [68.52(b)(3)]
4.12.4 Emergency shutdown and operations? [68.52(b)(4)]
4.12.5 Normal shutdown? [68.52(b)(5)]
4.12.6 Startup following a normal or emergency shutdown or a
major change that requires a hazard review? [68.52(b)(6)J
4.12.7 Consequences of deviations and steps required to correct or
avoid deviations? [68.52(b)(7)]
4.12.8 Equipment inspections? [68.52(b)(8)]
4.13 Has the owner or operator ensured that the operating
procedures have been updated, if necessary, whenever a major
change occurred and prior to startup of the changed process?
[68.52(c)]
D-22
-------
Compliance Objectives Notes
Program 2 Prevention: Training [68.54]
Has the owner or operator:
4.14 Certified that each employee presently operating a process,
and each employee newly assigned to a covered process
have been trained or tested competent in the operating
procedures provided in ง 68.52 that pertain to their duties?
[68.54(a)]
4.15 Provided refresher training at least every three years, or more
often if necessary, to each employee operating a process, to
ensure that the employee understands and adheres to the
current operating procedures of the process? [68.54(b)J
4.16 Determined, in consultation with the employees operating the
process, the appropriate frequency of refresher training?
[68.54(b)]
4.17 Certified that each employee was trained in any updated or
new procedures prior to startup of a process after a major
change? [68.54(d)]
Program 2 Prevention: Maintenance [68.56]
Has the owner or operator:
4.18 Prepared and implemented procedures to maintain the on-
going mechanical integrity of the process equipment?
[68.56(a)]
4.19 Trained or caused to be trained each employee, involved in
maintaining the on-going mechanical integrity of the process,
in the hazards of the process, in how to avoid or correct
unsafe conditions, and in the procedures applicable to
the employee's job tasks? [68.56(b)J
4.20 Has every maintenance contractor ensured that each contract
maintenance employee is trained to perform the maintenance
procedures developed? [68.56(c)J
4.21 Has the owner or operator performed or caused to be
performed inspections and tests on process equipment that
follow recognized and generally accepted engineering
practices? [68.56(d)]
D-23
-------
Compliance Objectives Notes
Program 2 Prevention: Compliance Audits [68.58]
Has the owner or operator:
4.22 Has the owner or operator certified that compliance audits
are conducted at least every three years to verify that the
procedures and practices are adequate and are being
followed? [68.58(a)]
4.23 Has compliance audit been conducted by at least one person
knowledgeable in the process? [68.58(b)J
4.24 Has the owner operator developed a report of the audits
findings? [68.58(c)]
4.25 Has the owner or operator promptly determined and
documented an appropriate response to each of the findings
of the audit and documented that deficiencies had been
corrected? [68.58(d)]
4.26 Has the owner or operator retained the two most recent
compliance audit reports, unless more than five years
old? [68.58(e)]
Program 2 Prevention: Incident Investigation [68.60]
Has the owner or operator:
4.27 Has the owner or operator investigated each incident which
resulted in, or could reasonably have resulted in a catastrophic
release? [68.60(a)]
4.28 Were all incident investigations initiated not later than 48
hours following the incident? [68.60(b)]
4.29 Was a summary prepared at the conclusion of every
investigation, which included: [68.60(c)]
4.29.1 Date of incident? [68.60(c)(l)]
4.29.2 Date investigation began? [68.60(c)(2)]
4.29.3 A description of incident? [68.60(c)(3)]
4.29.4 The factors that contributed to the incident? [68.60(c)(4)]
4.29.5 Any recommendations resulting from the investigation?
[68.60(c)(5)]
4.30 Has the owner or operator promptly addressed and resolved
the investigation findings and recommendations, and are the
resolutions and corrective actions documented? [68.60(d)J
D-24
-------
Compliance Objectives Notes
4.31 Has the owner or operator reviewed the finding with all
affected personnel whose job tasks are affected by the
findings? [68.60(e)]
4.32 Has the owner or operator retained investigation summaries
for five years? [68.60(f)]
Findings:
Documentation obtained to support Findings:
D-25
-------
Compliance Objectives Notes
5. 3 PREVENTION (SUBPART D)
-
Program 3 Prevention: Process Safety Information [68.65]
_ 5.1 Has the owner or operator compiled written process safety
information, which includes information pertaining to
the hazards of the regulated substances used or produced
by the process, information pertaining to the technology of
the process, and information pertaining to the equipment in
the process, before conducting any process hazard analysis
required by the rule? [68.65(a)J
5.2 Does the process safety information contain the following for
hazards of the substances: [68.65(b)J
_ 5.2.1 Toxicity information? [68.65(b)(l)]
_ 5.2.2 Permissible exposure limits? [68. 65(b)(2)]
_ 5.2.3 Physical data? [68.65(b)(3)]
_ 5.2.4 Reactivity data? [68.65(b)(4)]
_ 5.2.5 Corrosivity data? [68.65(b)(5)]
_ 5.2.6 Thermal and chemical stability data? [68.65(b)(6)]
_ 5.2.7 Hazardous effects of inadvertent mixing of materials that
could foreseeably occur? [68.65(b)(7)J
5.3 Does the process safety information contain the following for
technology of the process: [68.65(c)(l)J
_ 5.3.1 A block flow diagram or simplified process flow diagram?
5.3.2 Process chemistry? [68. 65(c)(l)(ii)]
5.3.3 Maximum intended inventory? [68. 65(c)(l)(iii)]
5.3.4 Safe upper and lower limits for such items as temperatures,
pressures, flows or compositions? [68.65(c)(l)(iv)]
5.3.5 An evaluation of the consequences of deviations?
[68.65(c)(l)(v)]
5.4 Does the process safety information contain the following for
the equipment in the process: [68.65(d)(l)J
5.4.1 Materials of construction? [68.65(d)(l)(i)]
5.4.2 Piping and instrument diagrams? [68. 65(d)(l)(ii)]
5.4.3 Electrical classification? [68.65(d)(l)(iii)]
5.4.4 Relief system design and design basis? [68.65(d)(l)(iv)]
D-26
-------
Compliance Objectives Notes
5.4.5 Ventilation system design? [68.65(d)(l)(v)]
5.4.6 Design codes and standards employed? [68.65(d)(l)(vi)]
5.4.7 Material and energy balances for processes built after June
21, 1999? [68.65(d)(l)(vii)]
5.4.8 Safety systems? [68.65(d)(l)(viii)]
5.5 Has the owner or operator documented that equipment
complies with recognized and generally accepted good
engineering practices? [68.65(d)(2)J
5.6 Has the owner or operator determined and documented that
existing equipment, designed and constructed in accordance
with codes, standards, or practices that are no longer in
general use, is designed, maintained, inspected, tested, and
operating in a safe manner? [68.65(d)(3)J
5.7 Has the owner or operator performed an initial process hazard
analysis (PHA), and has this analysis identified, evaluated,
and controlled the hazards involved in the process? [68.67(a)J
5.8 Has the owner or operator determined and documented the
priority order for conducting PHAs, and was it based on an
appropriate rationale? [68.67(a)J
5.9 Has the owner or operator used one or more of the following
technologies: [68.67(b)]
5.9.1 What-If? [68.67(b)(l)]
5.9.2 Checklist? [68.67(b)(2)]
5.9.3 What-If/Checklist? [68.67(b)(3)]
5.9.4 Hazard and Operability Study (HAZOP)? [68.67(b)(4)]
5.9.5 Failure Mode and Effects Analysis (FMEA)? [68.67(b)(5)]
5.9.6 Fault Tree Analysis? [68.67(b)(6)]
5.9.7 An appropriate equivalent methodology? [68.67(b)(7)J
5.10 Did the PHA address: [68.67(c)]
5.10.1 The hazards of the process? [68.67(c)(l)]
5.10.2 Identification of any incident which had a likely potential for
catastrophic consequences? [68.67(c)(2)J
5.10.3 Engineering and administrative controls applicable to hazards
and interrelationships? [68.67(c)(3)J
5.10.4 Consequences of failure of engineering and administrative
controls? [68.67(c)(4)]
D-27
-------
Compliance Objectives Notes
5.10.5 Stationary source siting? [68.67(c)(5)]
5.10.6 Human factors? [68.67(c)(6)]
5.10.7 An evaluation of a range of the possible safety and health
effects of failure of controls? [68.67(c)(7)]
5.11 Was the PHA performed by a team with expertise in
engineering and process operations and did the team include
appropriate personnel? [68.67(d)J
5.12 Has the owner or operator established a system to promptly
address the team's findings and recommendations; assured
that the recommendations are resolved in a timely manner
and documented; documented what actions are to be taken;
completed actions as soon as possible; developed a written
schedule of when these actions are to be completed; and
communicated the actions to operating, maintenance and
other employees whose work assignments are in the process
and who may be affected by the recommendations? [68.67(e)J
5.13 Has the PHA been updated and revalidated by a team every
five years after the completion of the initial PHA to assure
that the PHA is consistent with the current process? [68.67(f)]
5.14 Has the owner or operator retained PHAs and updates
or revalidations for each process covered, as well as the
resolution of recommendationsfor the life of the process?
[68.67(g)]
Program 3 Prevention: Operating procedures [68.69]
5.15 Has the owner or operator developed and implemented
written operating procedures that provide instructions or steps
for conducting activities associated with each covered process
consistent with the safety information? [68.69(a)J
5.16 Do the procedures address the following: [68.69(a)J
5.16.1 Steps for each operating phase? [68.69(a)(l)]
5.16.1.1 Initial startup? [68.69(a)(l)(i)]
5.16.1.2 Normal operations? [68.69(a)(l)(ii)]
5.16.1.3 Temporary operations? [68.69(a)(l)(iii)]
5.16.1.4 Emergency shutdown including the conditions under which
emergency shutdown is required, and the assignment of
shutdown responsibility to qualified operators to ensure that
emergency shutdown is executed in a safe and timely manner?
[68.69(a)(l)(iv)]
D-28
-------
Compliance Objectives Notes
5.16.1.5 Emergency operations? [68.69(a)(l)(v)]
5.16.1.6 Normal shutdown? [68.69(a)(l)(vi)]
5.16.1.7 Startup following a turnaround, or after emergency shutdown?
5.16.2 Operating limits: [68.69(a)(2)]
5.16.2.1 Consequences of deviations? [68.69(a)(2)(i)]
5.16.2.2 Steps required to correct or avoid deviations? [68.69(a)(2)(ii)J
5.16.3 Safety and health considerations: [68.69(a)(3)]
5.16.3.1 Properties of, and hazards presented by, the chemicals used in
the process? [68.69(a)(3)(i)]
5.16.3.2 Precautions necessary to prevent exposure, including
engineering controls, administrative controls, and personal
protective equipment? [68.69(a)(3)(ii)J
5.16.3.3 Control measures to be taken if physical contact or airborne
exposure occurs? [68.69(a)(3)(iii)J
5.16.3.4 Quality control for raw materials and control of hazardous
chemical inventory levels? [68.69(a)(3)(iv)J
5.16.3.5 Any special or unique hazards? [68.69(a)(3)(v)]
5.16.4 Safety systems and their functions? [68.69(a)(4)]
5.17 Are operating procedures readily accessible to employees
who are involved in a process? [68.69(b)J
5.18 Has the owner or operator certified annually that the operating
procedures are current and accurate and that procedures have
been reviewed as often as necessary? [68.69(c)J
5.19 Has the owner or operator developed and implemented safe
work practices to provide for the control of hazards during
specific operations, such as logout/tagout? [68.69(d)J
Program 3 Prevention: Training [68.71]
5.20 Has each employee presently involved in operating a process,
and each employee before being involved in operating a
newly assigned process, been initially trained in an overview
of the process and in the operating procedures? [68.71(a)(l)J
D-29
-------
Compliance Objectives Notes
5.21 Did initial training include emphasis on safety and health
hazards, emergency operations including shutdown, and safe
work practices applicable to the employee's job tasks?
[68.71(a)(2) allows in lieu of initial training for those
employees already involved in operating a process on June
21, 1999 an owner or operator may certify in writing that the
employee has the required knowledge, skills, and abilities to
safely carry out the duties and responsibilities as specified in
the operating procedures] [68.71(a)(l)]
5.22 Has refresher training been provided at least every three
years, or more often if necessary, to each employee involved
in operating a process to assure that the employee understands
and adheres to the current operating procedures of the
process? [68.71(b)]
5.23 Has owner or operator ascertained and documented in a
record that each employee involved in operating a process has
received and understood the training required? [68.71(c)J
5.24 Does the prepared record contain the identity of the
employee, the date of training, and the means used to verify
that the employee understood the training? [68.71(c)J
Program 3 Prevention: Mechanical integrity [68.73]
5.25 Has the owner or operator established and implemented
written procedures to maintain the on-going integrity of the
process equipment listed in 68.73(a)? [68.73(b)J
5.26 Has the owner or operator trained each employee involved in
maintaining the on-going integrity of process equipment?
[68.73(c)]
Has the owner or operator:
5.27 Performed inspections and tests on process equipment?
[68.73(d)(l)]
5.28 Followed recognized and generally accepted good
engineering practices for inspection and testing procedures?
[68.73(d)(2)]
5.29 Ensured the frequency of inspections and tests of process
equipment is consistent with applicable manufacturers'
recommendations, good engineering practices, and prior
operating experience? [68.73(d)(3)J
D-30
-------
Compliance Objectives Notes
5.30 Documented each inspection and test that had been performed
on process equipment, which identifies the date of the
inspection or test, the name of the person who performed the
inspection or test, the serial number or other identifier of the
equipment on which the inspection or test was performed, a
description of the inspection or test performed, and the results
of the inspection or test? [68.73(d)(4)]
5.31 Corrected deficiencies in equipment that were outside
acceptable limits defined by the process safety information
before further use or in a safe and timely manner when
necessary means were taken to assure safe operation?
[68.73(e)]
5.32 Assured that equipment as it was fabricated is suitable
for the process application for which it will be used in the
construction of new plants and equipment? [68.73(f)(l)]
5.33 Performed appropriate checks and inspections to assure that
equipment was installed properly and consistent with design
specifications and the manufacturer's instructions? [68.73(f)
(2)]
5.34 Assured that maintenance materials, spare parts and
equipment were suitable for the process application for which
they would be used? [68.73(f)(3)]
Program 3 Prevention: Management of change [68.75]
5.35 Has the owner or operator established and implemented
writtenprocedures to manage changes to process chemicals,
technology, equipment, and procedures, and changes to
stationary sources that affect a covered process? [68.75(a)J
5.36 Do procedures assure that the following consideration are
addressed prior to any change: [68.75(b)J
5.36.1 The technical basis for the proposed change? [68.75(b)(l)]
5.36.2 Impact of change on safety and health? [68.75(b)(2)]
5.36.3 Modifications to operating procedures? [68.75(b)(3)]
5.36.4 Necessary time period for the change? [68.75(b)(4)]
5.36.5 Authorization requirements for the proposed change?
[68.75(b)(5)]
D-31
-------
Compliance Objectives Notes
5.37 Were employees, involved in operating a process and
maintenance, and contract employees, whose job tasks
would be affected by a change in the process, informed of,
and trained in, the change prior to start-up of the process or
affected part of the process? [68.75(c)J
5.38 If a change resulted in a change in the process safety
information, was such information updated accordingly?
[68.75(d)]
5.39 If a change resulted in a change in the operating procedures or
practices, had such procedures or practices been updated
accordingly? [68.75(e)]
Program 3 Prevention: Pre-startup review [68.77]
5.40 Has the owner or operator performed a pre-startup safety
review for new stationary sources and for modified stationary
sources when the modification was significant enough to
require a change in the process safety information? [68.77(a)J
5.41 Did the pre-startup safety review confirm that prior to the
introduction of regulated substances to a process: [68.77(b)J
5.41.1 Construction and equipment was in accordance with design
specifications? [68.77(b)(l)]
5.41.2 Safety, operating, maintenance, and emergency procedures
were in place and were adequate? [68.77(b)(2)J
5.41.3 For new stationary sources, a process hazard analysis had
been performed and recommendations had been resolved or
implemented before startup? [68.77(b)(3)J
5.41.4 Modified stationary sources meet the requirements contained
in management of change? [68.77(b)(3)J
5.41.5 Training of each employee involved in operating a process
had been completed? [68.77(b)(4)]
Program 3 Prevention: Compliance audits [68.79]
5.42 Has the owner or operator certified that the stationary
source has evaluated compliance with the provisions of the
prevention program at least every three years to verify that
the developed procedures and practices are adequate and are
being followed? [68.79(a)]
5.43 Has the audit been conducted by at least one person
knowledgeable in the process? [68.79(b)J
5.44 Are the audits findings documented in report? [68.79(c)]
D-32
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Compliance Objectives Notes
5.45 Has the owner or operator promptly determined and
documented an appropriate response to each of the findings
of the audit and documented that deficiencies had been
corrected? [68.79(d>]
5.46 Has the owner or operator retained the two most recent
compliance audit reports? [68.79(e)J
Program 3 Prevention: Incident investigation [68.81]
5.47 Has the owner or operator investigated each incident which
resulted in, or could reasonably have resulted in a catastrophic
release of a regulated substance? [68.81 (a)]
5.48 Were all incident investigations initiated not later than 48
hours following the incident? [68.81(b)J
5.49 Was an incident investigation team established and did it
consist of at least one person knowledgeable in the process
involved, including a contract employee if the incident
involved work of the contractor, and other persons with
appropriate knowledge and experience to thoroughly
investigate and analyze the incident? [68.81(c)J
5.50 Was a report prepared at the conclusion of every
investigation? [68.81(d)]
5.51 Does every report include: [68.81(d)J
5.51.1 Date of incident? [68.81(d)(l)]
5.51.2 Date investigation began? [68.81 (d)(2)]
5.51.3 A description of the incident? [68.81(d)(3)]
5.51.4 The factors that contributed to the incident? [68.81(d)(4)]
5.51.5 Any recommendations resulting from the investigation?
[68.81(d)(5)]
5.52 Has the owner or operator established a system to address and
resolve the report findings and recommendations, and are the
resolutions and corrective actions documented? [68.81(e)J
5.53 Was the report reviewed with all affected personnel whose job
tasks are relevant to the incident findings including contract
employees where applicable? [68.81(f)]
D-33
-------
Compliance Objectives Notes
Program 3 Prevention: Employee participation [68.83]
Has the owner or operator:
5.54 Developed a written plan of action regarding the
implementation of the employee participation required by this
section? [68.83(a)]
5.55 Consulted with employees and their representatives on the
conduct and development of process hazards analyses and
on the development of the other elements of process safety
management in chemical accident prevention provisions?
[68.83(b)]
5.56 Provided to employees and their representatives access to
process hazard analyses and to all other information required
to be developed under chemical accident prevention rule?
[68.83(c)]
Program 3 Prevention: Hot work permit [68.85]
5.57 Has the owner or operator issued a hot work permit for each
hot work operation conducted on or near a covered process?
[68.85(a)]
5.58 Does the permit document that the fire prevention and
protection requirements in 29 CFR 1910.252(a) have been
implemented prior to beginning the hot work operations?
[68.85(b)]
5.59 Does the permit indicate the date(s) authorized for hot
work and the object on which hot works to be performed?
[68.85(b)]
5.60 Are the permits being kept on file until completion of the hot
work operations? [68.85(b)]
Program 3 Prevention: Contractors [68.87]
Has the owner or operator:
5.61 Obtained and evaluated information regarding the contract
owner or operator's safety performance and programs when
selecting a contractor? [68.87(b)(l)]
5.62 Informed contract owner or operator of the known potential
fire, explosion, or toxic release hazards related to the
contractor's work and the process? [68.87(b)(2)J
5.63 Explained to the contract owner or operator the applicable
provisions of emergency response program? [68.87(b)(3)J
D-34
-------
Compliance Objectives Notes
5.64 Developed and implemented safe work practices consistent
with ง68.69(d), to control the entrance, presence, and exit
of the contract owner or operator and contract employees in
covered process areas? [68.87(b)(4)]
Findings:
Documentation obtained to support Findings:
D-35
-------
Compliance Objectives Notes
6. EMERGENCY RESPONSE (SUBPARTE)
-
Emergency Response: Applicability [68.90]
6.1 Has the owner or operator of a stationary source developed
an emergency response program, unless the source need not
comply? [68.90(a)]
If the employees of the stationary source will not respond to
accidental releases of regulated substances:
6.2 For stationary sources with any regulated toxic substance held
in a process above the threshold quantity, is the stationary
source included in the community emergency response plan
developed under EPCRA? [68.90(b)(l)]
6.3 For stationary sources with only regulated flammable
substances held in a process above the threshold quantity, has
the owner or operator coordinated response actions with the
local fire department? [68.90(b)(2)]
6.4 Are appropriate mechanisms in place to notify emergency
responders when there is a need for a response? [68.90(b)(3)]
Emergency Response Program [68.95]
6.5 Has the owner or operator developed and implemented an
emergency response program for the purpose of protecting
public health and the environment? [68.95(a)J
6.6 Does the program include the following elements: [68.95(a)J
6.6.1 An emergency response plan which is maintained at the
stationary source? [68.95(a)(l)J
6.6.2 Procedures for the use of emergency response equipment and
for its inspection, testing, and maintenance? [68.95(a)(2)J
6.6.3 Training for all employees in relevant procedures?
[68.95(a)(3)]
6.6.4 Procedures to review and update, as appropriate, the
emergency response plan to reflect changes at the stationary
source and ensure that employees are informed of changes?
[68.95(a)(4)]
6.7 Does the emergency response plan contain the following
elements: [68.95(a)(l)]
6.7.1 Procedures for informing the public and local emergency
response agencies about accidental releases? [68.95(a)(l)(i)]
D-36
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Compliance Objectives Notes
_ 6.7.2 Documentation of proper first-aid and emergency medical
treatment necessary to treat accidental human exposures?
6.7.3 Procedures and measures for emergency response after an
accidental release of a regulated substance? [68.95(a)(l)(iii)]
6.8 Did the owner or operator use a written plan that complies
with other Federal contingency plan regulations or is
consistent with the approach in the National Response Team's
Integrated Contingency Plan Guidance ("One Plan")? If so,
does the plan include the elements provided in paragraph (a)
of 68.95, and also complies with paragraph (c) of 68.95?
[68.95(b)]
6.9 Has the emergency response plan been coordinated with
the community emergency response plan developed under
EPCRA? [68.95(c)]
6.10 Has the owner or operator provided to the local emergency
response officials information necessary for developing and
implementing the community emergency response plan
requested by the LEPC or emergency response officials?
[68.95(c)]
Findings:
Documentation obtained to support Findings:
D-37
-------
E: and
List of
(bf
106-98-9
97-00-7
590-21-6
109-67-1
57-14-7
106-99-0
504-60-9
107-01-7
590-18-1
624-64-6
557-98-2
563-46-2
115-11-7
646-04-8
627-20-3
463-82-1
97-02-9
563-45-1
75-07-0
74-86-2
107-02-8
107-13-1
814-68-6
Varies
107-18-6
107-05-1
107-11-9
7664-41-7
7664-41-7
7790-98-9
7787-36-2
1 -butene
1 -chloro-2,4-dinitrobenzene
1 -chloropropylene {1 -propene, 1 -chloro-}
1 -pentene
1 ,1 -dimethylhydrazine {Dimethylhydrazine}
{Hydrazine, 1,1 -dimethyl-}
1 ,3-butadiene
1 ,3-pentadiene
2-butene
2-butene-cis
2-butene-trans {2-butene, (E)}
2-chloropropylene {1 -propene, 2-chloro-}
2-methyl-1 -butene
2-methylpropene {1 -propene, 2-methyl-}
2-pentene (E)-
2-pentene (Z)-
2,2-dimethylpropane {Propane, 2,2-dimethyl-}
2,4-dinitroaniline
3-methyl-1 -butene
Acetaldehyde
Acetylene {Ethyne}
Acrolein {2-propenal}
Acrylonitrile {2-propenenitrile}
Acrylyl Chloride {2-propenoyl Chloride}
Alkylaluminums
Allyl Alcohol {2-propen-1-ol}
Allyl Chloride
Allylamine {2-propen-1-amine}
Ammonia (Anhydrous)
Ammonia (>=20% for RMP) (>44% for PSM)
Ammonium Perchlorate
Ammonium Permanganate
10,000
10,000
10,000
15,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
5,000
20,000
5,000
15,000
1,000
10,000
10,000
20,000
|SSปtitit^;
dfel^lit**;
**
**
1,869
2,271
1,930
1,753
**
1,929
1,983
**
1,844
2,031
1,827
1,849
2,028
1,911
1,536
1,955
714
2,994
527
2,105
1,577
1,758
2,723
'< f ^VvTl
\vW$|
l^Liljl
5,000
1,000
5,000
2,500
150
250
5,000
1,000
10,000
15,000
7,500
7,500
0.012
0.0011
0.076
0.0009
0.036
0.0032
0.14
0.14
E-1
-------
7784-34-1
7784-42-1
10294-34-5
7637-07-2
353-42-4
7726-95-6
13863-41-7
7787-71-5
7789-30-2
598-73-2
106-97-8
25167-67-3
75-91-2
614-45-9
75-15-0
463-58-1
353-44-5
9004-70-0
7782-50-5
10049-04-4
7791-21-1
13637-63-3
7790-91-2
96-06-2
67-66-3
542-88-1
107-30-2
76-06-2
None
None
4170-30-3
123-73-9
80-15-9
460-19-5
506-77-4
675-14-9
108-91-8
Arsenous Trichloride
Arsine {Arsenic Hydride}
Boron Trichloride {Borane, Trichloro-}
Boron Triflouride {Borane, Trifluoro-}
Boron Triflouride Compound with Methyl Ether (1 :1)
{Boron, Trifluoro[oxybis[methane]-,T-4}
Bromine
Bromine Chloride
Bromine Trifluoride
Bromine Pentafluoride
Bromotrifluorethylene {Ethene, Bromotrifluoro-}
Butane
Butene
Butyl Hydroperoxide (Tertiary)
Butyl Perbenzoate
Carbon Disulfide
Carbon Oxysulfide {Carbon Oxide Sulfide (Cos)}
{Carbonyl Sulfide}
Carbonyl Fluoride
Cellulose Nitrate (>12.6% Nitrogen for PSM)
Chlorine
Chlorine Dioxide {Chlorine Oxide (CI02)}
Chlorine Monoxide {Chlorine Oxide}
Chlorine Pentrafluoride
Chlorine Trifluoride
Chlorodiethylaluminum {Diethylaluminum Chloride}
Chloroform {Methane, Trichloro-}
Chloromethyl Ether {Bis(chloromethyl) Ether}
{Methane, Oxybis[chloro-} {Dichloromethyl Ether}
Chloromethyl Methyl Ether {Methane, Chloromethoxy-}
Chloropicrin
Chloropicrin and Methyl Bromide Mixture
Chloropicrin and Methyl Chloride Mixture
Crotonaldehyde {2-butenal}
Crotonaldehyde, (E)- {2-butenal, (E)-}
Cumene Hydroperoxide
Cyanogen {Ethanedinitrile}
Cyanogen Chloride
Cyanuric Fluoride
Cyclohexylamine{Cyclohexanamine}
mm
15,000
1,000
5,000
5,000
15,000
10,000
10,000
10,000
10,000
20,000
10,000
2,500
1,000
10,000
20,000
1,000
5,000
20,000
20,000
10,000
10,000
15,000
836
45
444
374
1,451
386
**
1,997
2,014
1,897
571
210
75
1,616
91
565
2,833
2,810
1,256
980
2,079
100
2,500
250
1,500
1,500
15,000
2,500
5,000
7,500
2,500
2,500
1,500
1,000
1,000
1,000
5,000
100
500
500
1,500
1,500
5,000
2,500
500
100
0.01
0.0019
0.01
0.028
0.023
0.0065
0.16
0.0087
0.0028
0.49
0.00025
0.0018
0.029
0.029
0.03
0.16
i 141'!
E-2
-------
75-19-4
110-22-5
334-88-3
94-36-0
19287-45-7
110-05-4
4109-96-0
557-20-0
75-37-6
105-64-6
105-74-8
124-40-3
75-78-5
106-89-8
74-84-0
107-00-6
75-00-3
60-29-7
75-08-1
1338-23-4
109-95-5
75-04-7
74-85-1
371-62-0
75-21-8
107-15-3
151-56-4
7782-41-4
50-00-0
110-00-9
684-16-2
302-01-2
7647-01-0
74-90-8
1333-74-0
10035-10-6
7647-01-0
7664-39-3
Cyclopropane
Diacetyl Peroxide (>70% for PSM)
Diazomethane
Dibenzoyl Peroxide
Diborane {Diborane (6)}
Dibutyl Peroxide (Tertiary)
Dichlorosilane {Silane, Dichloro-}
Diethylzinc
Difluoroethane {Ethane, 1 ,1 -difluoro-}
Diisopropyl Peroxydicarbonate
Dilauroyl Peroxide
Dimethylamine {Methanamine, N-methyl-}
Dimethyldichlorosilane {Silane, Dichlorodimethyl-}
Epichlorohydrin {Oxirane, (Chloromethyl)-}
Ethane
Ethyl Acetylene {1 -butyne}
Ethyl Chloride {Chloroethane} {Ethane, Chloro-}
Ethyl Ether {Ethane, 1,1'-oxybis-}
Ethyl Mercaptan {Ethanethiol}
Ethyl Methyl Ketone Peroxide
Ethyl Nitrite {Nitrous Acid, Ethyl Ester}
Ethylamine {Monoethylamine} (Ethanamine}
Ethylene {Ethene}
Ethylene Fluorohydrin
Ethylene Oxide {Oxirane}
Ethylenediamine {1 ,2-ethanediamine}
Ethyleneimine {Aziridine}
Fluorine
Formaldehyde (Solution)
Furan
Hexafluoroacetone
Hydrazine
Hydrochloric Acid (>=37% for RMP)
Hydrocyanic Acid {Hydrogen Cyanide}
Hydrogen
Hydrogen Bromide
Hydrogen Chloride (Anhydrous for CAA 1 12(r) RMP and PSM)
{Hydrochloric Acid}
Hydrogen Fluoride/hydrofluoric Acid (>=50% for RMP)
{Hydrofluoric Acid}
mm
10,000
2,500
10,000
10,000
10,000
5,000
20,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
20,000
10,000
1,000
15,000
5,000
15,000
15,000
2,500
10,000
5,000
1,000
1,773
**
5,000
999
1,261
1,786
545
1,331
2,195
1,767
1,323
1,678
1,451
1,331
1,762
2,106
1,379
2,669
1,440
79
1,591
639
1,918
1,510
434
**
503
121
5,000
500
7,500
100
2,500
10,000
7,500
7,500
2,500
1,000
5,000
5,000
7,500
100
5,000
1,000
1,000
1,000
500
5,000
1,000
5,000
5,000
1,000
0.0011
0.026
0.076
0.09
0.49
0.018
0.0039
0.012
0.0012
0.011
0.03
0.011
0.03
0.016
E-3
.-. v merit
-------
7722-84-1
7783-07-5
7783-06-4
7803-49-8
13463-40-6
75-28-5
78-82-0
78-78-4
78-79-5
75-31-0
75-29-6
108-23-6
463-51-4
78-85-3
126-98-7
920-46-7
74-82-8
74-83-9
74-87-3
79-22-1
115-10-6
1338-23-4
453-18-9
421-20-5
107-31-3
60-34-4
74-88-4
624-83-9
74-93-1
556-64-9
79-84-4
74-89-5
75-79-6
13463-39-3
7697-37-2
10102-43-9
100-01-6
Hydrogen Peroxide (>= 52% for PSM)
Hydrogen Selenide
Hydrogen Sulfide
Hyroxylamine
Iron, Pentacarbonyl- {Iron Carbonyl (Fe(co)5), (Tb-5-11)-}
Isobutane {Propane, 2-methyl}
Isobutyronitrile {Propanenitrile, 2-methyl-}
Isopentane {Butane, 2-methyl-}
Isoprene {1 ,3-butadiene, 2-methyl-}
Isopropylamine {2-propanamine}
Isopropyl Chloride {Propane, 2-chloro-}
Isopropyl Chloroformate
{Carbonochloridic Acid, 1 -methylethyl Ester}
Ketene
Methacrylaldehyde
Methacrylonitrile {2-propenenitrile, 2-methyl-}
{Methylacrylonitrile}
Methacryloyl Chloride
Methane
Methyl Bromide
Methyl Chloride {Chloromethane} {Methane, Chloro-}
Methyl Chloroformate {Carbonochloridic Acid, Methylester}
{Methyl Chlorocarbonate}
Methyl Ether {Methane, Oxybis-}
Methyl Ethyl Ketone Peroxide (>60% for PSM)
Methyl Fluoroacetate
Methyl Florosulfate
Methyl Formate {Formic Acid, Methyl Ester}
Methyl Hydrazine
Methyl Iodide
Methyl Isocyanate {Methane, Isocyanato-}
Methyl Mercaptan {Methanethiol} {Thiomethanol}
Methyl Thiocyanate {Thiocyanic Acid, Methyl Ester}
Methyl Vinyl Ketone
Methylamine {Methanamine} {Monomethylamine}
Methyltrichlorosilane {Silane, Trichloromethyl-}
Nickel Carbonyl {Nickel Tetracarbonyl}
Nitric Acid (>=80% for BMP) (>=94.5% for PSM)
Nitric Oxide {Nitrogen Oxide (No)}
Nitroaniline {Para Nitroaniline}
mm
500
10,000
2,500
10,000
20,000
10,000
10,000
10,000
10,000
15,000
10,000
10,000
10,000
5,000
10,000
10,000
15,000
10,000
10,000
20,000
10,000
5,000
1,000
15,000
10,000
28
1,308
2,500
206
2,151
3,149
1,933
1,760
1,734
1,390
1,664
1,497
2,853
1,202
489
1,655
1,235
2,066
1,248
1,343
2,244
1,729
472
91
1,196
943
7,500
150
1,500
250
5,000
100
1,000
250
150
2,500
15,000
500
5,000
100
100
100
7,500
250
5,000
100
1,000
150
500
250
5,000
0.00066
0.042
0.00044
0.14
0.1
0.0027
0.82
0.0019
0.0094
0.0012
0.049
0.085
0.018
0.00067
0.026
0.031
i 141'!
E-4
-------
7783-54-2
10102-44-0
10544-72-6
10544-73-7
10102-44-0
75-52-5
8014-95-7
20816-12-0
7783-41-7
10028-15-6
19624-22-7
109-66-0
79-21-0
7601-90-3
594-42-3
7616-94-6
75-44-5
7803-51-2
10025-87-3
7719-12-2
110-89-4
463-49-0
74-98-6
106-96-7
107-12-0
627-13-4
109-61-5
115-07-1
75-56-9
75-55-8
74-99-7
107-44-8
7783-79-1
7803-62-5
7803-52-3
7446-09-5
5714-22-7
Nitrogen Trifluoride
Nitrogen Oxides (NO, N02, N204, N203)
Nitrogen Tetroxide {Nitrogen Peroxide}
Nitrogen Trioxide
Nitrogen Dioxide
Nitromethane
Oleum (Fuming Sulfuric Acid) (65-80% for PSM)
{Sulfuric Acid, with Sulfur Trioxide}
Osmium Tetroxide
Oxygen Difluoride {Fluorine Monoxide}
Ozone
Pentaborane
Pentane
Peracetic Acid (>60% Acetic Acid for PSM)
{Ethaneperoxoic Acid} {Peroxyacetic Acid}
Perchloric Acid (>60% for PSM)
Perchloromethylmercaptan
{Methanesulfenyl Chloride, Trichloro-}
Perchloryl Fluoride
Phosgene {Carbonic Dichloride} {Carbonyl Chloride}
Phosphine {Hydrogen Phosphide}
Phosphorus Oxychloride {Phosphoryl Chloride}
Phosphorus Trichloride {Phosphorous Trichloride}
Piperidine
Propadiene {1 ,2-propadiene}
Propane
Propargyl Bromide {3-bromopropyne}
Propionitrile {Ethyl Cyanide} {Propanenitrile)
Propyl Nitrate
Propyl Chloroformate {Carbonochloridic Acid, Propylester}
Propylene{1-propene}
Propylene oxide {oxirane, methyl-}
Propyleneimine {Aziridine, 2-methyl}
Propyne{1-propyne}
Sarin
Selenium Hexafluoride
Silane
Stibine {Antimony Hydride}
Sulfur Dioxide (Anhydrous for RMP)
Sulfur Pentafluoride
mm
10,000
10,000
10,000
10,000
500
5,000
5,000
15,000
15,000
10,000
10,000
10,000
15,000
10,000
10,000
10,000
10,000
10,000
5,000
608
1,914
977
707
42
803
364
1,142
2,085
**
2,381
1,494
1,649
1,968
1,395
1,485
1,697
1,762
418
5,000
250
250
250
250
2,500
1,000
100
100
100
100
5,000
150
5,000
100
100
1,000
1,000
100
2,500
100
1,000
500
250
0.01
0.0045
0.0076
0.00081
0.0035
0.003
0.028
0.022
0.0037
0.01
0.59
0.12
0.0078
E-5
-------
7783-60-0
7446-11-9
7783-80-4
116-14-3
10036-47-2
75-74-1
75-76-3
509-14-8
7719-09-7
7550-45-0
584-84-9
91-08-7
26471-62-5
1558-25-4
27137-85-5
10025-78-2
79-38-9
75-50-3
75-77-4
2487-90-3
108-05-4
689-97-4
75-01-4
109-92-2
75-02-5
107-25-5
75-35-4
75-38-7
Sulfur Tetraflouride {Sulfur Fluoride, (Sf4) (T-4)-}
Sulfur Trioxide {Sulfuric Anhydride}
Tellurium Hexafluoride
Tetrafluoroethylene {Ethene, Tetrafluoro-}
Tetrafluorohydrazine
Tetramethyllead {Plumbane, Tetramethyl-}
Tetramethylsilane {Silane, Tetramethyl-}
Tetranitromethane {Methane, Tetranitro-}
Thionyl Chloride
Titanium Tetrachloride {Titanium Chloride (Ticl4)(T-4)}
Toluene 2,4-diisocyanate
{Benzene, 2,4-diisocyanato-1 -methyl-}
Toluene 2,6-diisocyanate
{Benzene, 1 ,3-diisocyanato-2-methyl-}
Toluene Diisocyanate (Unspecified Isomer)
{Benzene, 1 ,3-diisocyanatomethyl-}
Trichloro(chloromethyl)silane
Trichloro(dichlorophenyl)silane
Trichlorosilane {Silane, Trichloro-}
Trifluorochloroethylene {Ethene, Chlorotrifluoro-}
Trimethylamine {Methanamine, N,n-dimethyl-}
Trimethylchlorosilane {Silane, Chlorotrimethyl-}
Trimethyoxysilane
Vinyl Acetate Monomer {Acetic Acid Ethenyl Ester}
Vinyl Acetylene {1 -buten-3-yne}
Vinyl Chloride {Ethene, Chloro-}
Vinyl Ethyl Ether {Ethene, Ethoxy-}
Vinyl Fluoride {Ethene, Fluoro-}
Vinyl Methyl Ether {Ethene, Methoxy-}
Vinylidene Chloride {Ethene, 1,1-dichloro-}
{1,1-dichlorethylene}
Vinylidene Fluoride {Ethene, 1,1-difluoro-}
mm
2,500
10,000
10,000
10,000
10,000
10,000
2,500
10,000
10,000
10,000
10,000
10,000
10,000
10,000
15,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
154
624
**
601
1,849
732
174
979
978
1,007
892
917
1,893
1,403
1,929
1,689
1,237
1,579
1,695
1,542
990
**
250
1,000
250
5,000
5,000
1,000
250
100
2,500
5,000
10,000
1,500
0.0092
0.01
0.004
0.004
0.02
0.007
0.007
0.007
0.05
0.26
iimuaiiw* iiป!" uuiitiucuiiy *itniayซiieiii rruyi&m inspections unuei v>itian An MCI aecuuii i
E-6
-------
-------
-------
vvEPA
United States
Environmental Protection
Agency (5104A)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
------- |