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
         	23
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).
                                                                                                           11

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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;
 12

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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.
                                                                                                    13

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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.
                                                                                                  15

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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.
 16
                                                             ;                          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).
                                                                                                   17

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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.
 18

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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
 20

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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.
                                                                                                   21

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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
                                                          23

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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)].
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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:
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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:
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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.
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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 provided—classroom, 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

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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

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 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

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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

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 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

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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

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 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

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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

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 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

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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

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 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

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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

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 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

-------
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

-------
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

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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







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                                                                                                                          E-6

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vvEPA
    United States
    Environmental Protection
    Agency (5104A)
    Washington, DC 20460

    Official Business
    Penalty for Private Use
    $300

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