United States Office of Solid Waste EPA 540-B-14-001
Environmental Protection and March 2014
Agency Emergency Response www.epa.qov/emerqencies
RISK MANAGEMENT PLAN
RMP*eSUBMIT USERS' MANUAL
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
RISK MANAGEMENT PLANS
UNDER THE CLEAN AIR ACT
Risk Management Plans (RMPs) must be fully updated and re-submitted at least
once every five years. Most RMPs were submitted by the initial deadline of June
21,1999, and were updated and re-submitted in 2004 and 2009, unless they were
updated and re-submitted previously. EPA released RMP*eSubmit to facilitate
secure online RMP resubmissions beginning in calendar year 2009.
WHAT'S NEW?
Since 2009, you have been able to submit your RMPs online via RMP*eSubmit. This software
is on EPA's secure network, the Central Data Exchange (CDX), which manages thousands of data
submissions from states and industry to a variety of EPA programs. Several updates to the
software have occurred since 2009.
Reporting requirements are the same as in 2004. While the format of your reporting changed
in 2009, the 2004 rule changes will remain in effect.
You can access your RMP online anytime. Owners and operators of facilities, and individuals
they designate as Preparers of their RMPs, can access the facility RMP at anytime online.
RMP*eSubmit replaced RMP*Submit 2004. EPA no longer supports the RMP*Submit 2004
software.
NAICS Codes update. The 2012 version of the North American Industry Classification System
(NAICS) codes has been integrated into RMP*eSubmit.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
WHERE TO GO FOR HELP
RMP Reporting Materials
EPA's Website: http://www.epa.gov/emergencies/content/rmp/index.htm includes the Risk
Management Program rule, Off-Site Consequence Analysis specific guidance and calculator, the
list of regulated substances, links to factsheets, guidance documents, industry-specific model
plans, FAQs, this RMP*eSubmit Users' Manual, and other information.
RMP Contacts
Under the Clean Air Act, Section 112(r), states can choose to take delegation of the Chemical
Accident Prevention Program. If they do, they become the Implementing Agency for that state.
Contact your EPA Regional staff for assistance. We maintain their contact information on our
Website: http://www.epa.gov/emergencies/content/regional.htm
RMP Regulatory Questions
Contact the Superfund, TRI, EPCRA, RMP & Oil Information Center (also known as the "Info
Center") for your policy, regulatory compliance, and reporting requirements questions.
800-424-9346 Toll Free
703-412-9810 Metropolitan DC area and international calls
Monday - Friday: 10:00 AM - 5:00 PM Eastern Time
Closed on Federal Holidays
RMP*eSubmit Software Support
Contact the RMP Reporting Center for specific software questions about RMP*eSubmit.
703-227-7650 All domestic and international calls
Monday - Friday: 8:00 AM - 4:30 PM Eastern Time
Closed on Federal Holidays
RMPRC@epacdx.net
in
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
TABLE OF CONTENTS
Where To Go For Help iii
RMP Reporting Materials iii
RMP Contacts iii
RMP Regulatory Questions iii
RMP*eSubmit Software Support iii
Chapter 1 Getting Started 1
Introduction 1
Before You Start 1
CDX and the Registration Process for RMP*eSubmit 2
Preparing RMP and Facility ID Option Page 17
Adding the Preparer Role 18
Chapter 2 Entering Data (First-Time, Corrections, Resubmissions) 22
Section 1. Registration 22
Section 2. Toxics: Worst-Case 42
Section 3. Toxics: Alternative Release 49
Section 4. Flammables: Worst Case 57
Section 5. Flammables: Alternative Release 61
Section 6: Five-Year Accident History 67
Section 7: Prevention Program: Program Level 3 79
Section 8: Prevention Program: Program Level 2 92
Section 9: Emergency Response 100
Executive Summary 104
Chapters How to Submit Your RMP 107
Certifying a Submission in RMP*eSubmit 107
Certification Statement (Part 1) 109
Certification Statement (Part 2) 109
Chapter 4 Submitting Confidential Business Information and Paper RMPs Ill
Confidential Business Information Ill
Submitting Paper RMPs Ill
IV
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
Chapter 5 Notifying EPA that Your Facility is no Longer Covered by RMP: De-registration 112
How to De-register Your Facility 112
Chapter 6 Propane Withdrawal Form and Request to Consolidate EPA Facility IDs Form 113
When to Uses these Forms 113
Chapter 7 Reporting Center Contact Information Acronyms of Terms 114
RMP Reporting Center Contact Information 114
Acronyms of Terms 115
Appendices A-l
APPENDICES
Appendix A. Risk Management Plan Form A-l
Appendix B. Sample Certification Letters B-l
Appendix C. CBI Substantiation Form C-l
Appendix D. CBI Unsanitized Data Element Form D-l
Appendix E. Risk Management Program De-registration Form E-l
Appendix F. Risk Management Program Propane Withdrawal Form F-l
Appendix G. Risk Management Program Request to Consolidate EPA Facility ID Numbers G-l
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
CHAPTER 1 GETTING STARTED
Introduction
The RMP*eSubmit Users' Manual provides assistance in preparing and submitting Risk
Management Plans (RMPs). RMP*eSubmit application software is the Web-based free tool EPA
developed to facilitate electronic submission and is designed to significantly reduce errors in
submission through validations for data elements. If you are unable to submit your RMP
electronically, contact the RMP Reporting Center: 703-227-7650.
RMP*eSubmit allows you to:
• View the current version of your RMP (if you have already reported an RMP)
• Create a new RMP online (if this is a first-time submission)
• Make corrections to, or create a complete resubmission of your RMP
• Identify and correct any errors in your RMP prior to submission
• View a copy of the record of your RMP
• Print a copy of your RMP
• Submit your RMP online
• Access help screens to assist you in completing your RMP
You must be registered as a Preparer and/or Certifier in the Central Data Exchange (CDX), RMP
Program in order to use RMP*eSubmit.
Definitions:
Central Data Exchange (CDX) is a secure, online location on EPA's network. CDX
provides standardized and secure information collection services and infrastructure for
EPA program partners. For example, CDX manages several Agency regulatory and
monitoring programs, receiving submissions from facilities.
Certifiers are facility owners or operators who must certify the accuracy and
completeness of the information reported in the RMP. They have signed and submitted
a one-time Electronic Signature Agreement (ESA) to the EPA. The ESA legally binds the
Certifier's electronic submission to their signature. Only Certifiers can submit the RMP.
Preparers have been granted permission by a facility to access the facility's existing
RMP. They prepare data for a new or updated RMP. CDX notifies the Certifier when the
new or corrected RMP is ready for the Certifier's review and submission. Preparers
cannot submit the RMP.
Before You Start
Are you subject to the RMP reporting requirements? Check the requirements on EPA's Web
site: http://www.epa.gov/emergencies/content/rmp/index.htm, or call the appropriate contact
on "Where to Go for Help" page at the beginning of this manual. For updates and
resubmissions, check your 5-year anniversary date if you already have an RMP in the system.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
What is your EPA Facility ID? If you already have an RMP in the system, you have an EPA
Facility ID. It is essential that we match your new RMP to any earlier versions. Your EPA Facility
ID appears in a letter sent by the RMP Reporting Center after your first-time submission. The
EPA Facility ID has twelve digits. Call the RMP Reporting Center if you need help: 703-227-7650.
What category are your processes in: Program Level 1, 2 or 3? Each process at your facility
having more than a specified amount (threshold quantity) of a covered chemical (regulated
substance) will be in one of these categories. The category determines some of your reporting
requirements and governs how you enter the data. More about Program Levels can be found
later in this chapter.
Is your RMP a First-time Submission, a Resubmission, or a Correction?
Definitions:
A First-time Submission means that an RMP has never before been submitted for your
facility (by you or any previous owner/operator). This requires that you enter
information for all nine sections of the RMP. Elements for all nine sections are discussed
in Chapter 2.
A Resubmission is an update of all nine sections of your RMP. If you are the owner or
operator of an RMP-covered facility, EPA's Chemical Accident Prevention regulations at
40 CFR part 68 require that you fully update and resubmit your RMP at least once every
5 years. Resubmitting your RMP will re-set your five-year anniversary date. If you have
previously submitted an RMP, your facility information will be pre-populated in
RMP*eSubmit.
A Correction should be used to report administrative or other changes at your facility
(e.g., changes in emergency contact information, facility address, or change in accident
history). This does not require an update of your entire RMP. Submitting a corrected
RMP does not change your five-year anniversary date. If your facility has not
resubmitted an RMP by its anniversary date, you will not be able to make an RMP
Correction and will be required to resubmit your RMP.
CDX and the Registration Process for RMP*eSubmit
The RMP*eSubmit application allows you to securely submit your RMP over the Internet
through the EPA Central Data Exchange (CDX).
The requirements to submit using RMP*eSubmit are:
1. You must have Internet access
2. The Certifying Official (Certifier) and Preparer must have Central Data Exchange (CDX)
accounts (see the "Registration" section to learn how to obtain those accounts)
3. The Certifier must complete an Electronic Signature Agreement (ESA) to obtain the
Authorization Code (AuthCode) for preparing a submission. The Authorization Code is
necessary to prepare and submit an RMP
4. Preparers must activate their RMP*eSubmit access in CDX using the unique facility
Authorization Code provided to them by the Certifying Official for their facility.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Getting Started with RMP*eSubmit
To use RMP*eSubmit, the Certifying Official for your facility (typically the facility owner or
operator or a designated senior management official employed by the facility) must first be
registered in CDX. Additionally, the Certifying Official must complete and sign an Electronic
Signature Agreement (ESA) which will be used to verify the identity of the Certifying Official in
the system. The ESA must be mailed to the RMP Reporting Center and approved prior to the
Preparer being able to prepare or the Certifier being able to certify an RMP using
RMP*eSubmit.
Registration for RMP*eSubmit
The registration process for the RMP*eSubmit application is different if you already have a CDX
user account (such as for previously registering to use TRI-MEweb or any other CDX
application), and is based on whether your role is a Certifying Official or a Preparer.
The following information will take you step-by-step through the CDX registration process and
will help you get started as a Certifier or Preparer.
Registering for CDX User Account
A CDX account is needed to use the RMP*eSubmit application. To register for an account, log
into CDX at http://cdx.epa.gov, read the Warning Notice and Privacy Policy, then click "Register
with CDX."
vvEPA
United States Environmental Protection Agency
CDX Home About CDX Recent Announcements Terms and Conditions Help
Central Data Exchange
CDX,
EH Contact Us
\-rni i; !, ,-
'
1
Log in to CDX
Welcome
'Welcome to the Environmental Protection Agency (EPA) Central Data Exchange (CDX) - the Agency's electronic reporting site. The Central Data Exchange concept
has been defined as a centra! point which supplements EPA reporting systems by performing new and existing functions for receiving legally acceptable data in
various formats, including consolidated and integrated data
CDX: The EPA OCTS;LT2 Oracle Database has been decommissioned effective April 15, 201 3. For more details click here.
Warning Notice and Privacy Policy
Read the Terms and Conditions. Then choose "I Accept" and click "Proceed".
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
&EPA
United Stales Environmental Protection Agericv
CDX,
CDX Home About CDX Recent Announcements Terms and Conditions Hetp
Terms and Conditions
The access and use of CDX Registration for the electronic submittal of environmental information require the creation of a user ID and password that I must
maintain and keeo confidential. I will review the following steos concerning the creation and maintenance of a user ID and password.
Warning Notice
EPA's Central Data Exchange Registration procedure is part of a United States Environmental Protection Agency (EPA) computer system, which is for
authorized use only. Unauthorized access or use of this computer system may subject violators to criminal, civil, and or administrative action. All information -
on this computer system may be monitored, recorded, read, copied, and disclosed by and to authorized personnel for official purposes, including law-
enforcement- Access or use of this computer system by any person, whether authorized or unauthorized, constitutes consent to these terms.
Privacy Statement
EPA will use the personal identifying information which you provide for the expressed purpose of registration to the Central Data Exchange site and for
updating and correcting information in internal EPA databases as necessary. The Agency will not make this information available for other purposes unless
required by law. EPA does not sell or otherwise transfer personal information to an outside third party. [Federal Register: March 1 8, 2002 (Volume 67,
Number 52)][Page 12010-12013].
Choosing a CDX Password
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The Core CDX Registration page contains the Active Program Services List. Scroll to the
"RMPESUBMIT: Risk Management Plan" link and click.
SEPA
Inited States Environmental Protection Ayency
CDX Home About CDX Recent Announcements Terms and Conditions Help
Core CDX Registration acontaaus
2. Request Role Access 3. Provide User and Organization Information 4. Confirmation
Begin typing a program service name or related keywords to filter the list of available services (e.g . air quality system, AQS, or Clean Air Act).
Active Program Services List
1. Request Program Service
ACRES: Assessment Cleanup and Redevelopment Exchange System
ARCS: Aircraft Reporting and Compliance System
CEDRI: Compliance and Emissions Data Reporting Interface
CROMERRLiteTest: CROMERR Lite Testing Utility
CROMERRTEST: CROMERR Test Sandbox
CSPP: Submissions for Chemical Safety and Pesticide Programs
EAB: Environmental Appeals Board
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Using the drop-down menu, select "Certifying Official" and click the "Request Role Access"
button.
NOTE: To add only the "Preparer" role to your CDX account, you will need to visit
https://cdx.epa.gov/ and select "Register with CDX". Read the Terms and Conditions
thoroughly. Chose the "I Accept" radio button at the bottom of the page, then click the
"Proceed" button. (To add the Preparer role, go to page 18.)
SEPA
United Slates Environmental Protection Agency
CDX Home About CDX Recent Announcements Terms and Conditions Help
Core CDX Registration
1. Request Program Service '
Registration Information
Program Service Risk Management Plan
Role: Not selected
CDX*
LH Contact Us
2. Request Role Access
3. Provide User and Organization Information 4. Confirmation
Select a role from the droD down list and Drovide any required additional information, if applicable.
Select Role
Request Role Acces
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
This brings us to the Core CDX Registration page. Scroll down to "Part 1: User Information"
section and provide the requested information.
lited States Environmental Prelection Agency
CDX Home About CDX Recent Announcements Terms and Conditions Help
Core CDX Registration
1. Request Program Service © 2. Request Role Access
Registration Information
Program Service Risk Management Plan
Role Certifying Official
3. Provide User and Organization Information
Essential information is marked ,vith an asterisk!
Description of Fields
Last Name v
Suffix
Password "
Re-type Password '
Security Question " '
Security Question 2 '
Security Question 3 •
Search Tor your organization using the text oox oelow. You may search by entering the Organization Name or the Organization ID.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Once completed, move on to "Part 2: Organization Information".
Part 2: Organization Information
Search for your organization using the text box below. You may search by entering the Organization Name or the Organization ID.
[RMP
Select your organization from the table below.
Organization Id
Organization Name Address
Mo data was found matching your criteria.
City State ZIP Code
Can't find your organization? Use advanced search or request that we add your organization.
Use the search function to find your organization or you can request to add your organization.
To add your organization, click on "request that we add your organization" link. Then, enter
your organization information and select "Submit Request for Access".
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
Find your organization by using the search function either by "Organization Name" or
"Organization ID". Click on your organization's corresponding "Organization ID" link.
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Complete the additional contact information and select "Submit Request for Access".
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You will be directed to a Confirmation page. Shortly afterward you will receive an email
confirmation.
Cc
>'DU ht'.-t suctessf ally crejted *n account with tnt EPA Central Data Exchange (CDX;,
In order TO coflplite you" registration »nO Mgii using the systen, you will deed to confirn your account by clicking the
hxp»rlink btlcw and succ»nf ully logging in. You will n*«d to rnt»r th* Uj»rIO (SeFJONU) anil Pauword that IMP* MltCttd
during the registration process.
If you click tn* link and it appears to be broken, pleaie copy and pasi* it into e neu brouatr u
One* you hav* successfully logged into your account, you nay be required to provide additional information. Any
additional information will need to be completed before you are able to access your Progran Service,
Please do f*ot respond to this nessage. If you Have questions concerning tils ••equest, you nay contact us 6y enall at
h»lpd>ikit»PMi(x . nat or by calling the COX T«ctinlcil Support Stiff through oar toll free telephone- support on JJS-SPB
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can also be re»cn*d at (97B) *9
Sincerely
CDX Help Desk
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Follow the attached link in the email to activate your account.
&EBV
CDX,
Confirmation
Once you've clicked the link provided in your email, you'll be directed to the Central Data
Exchange page. Log in using your CDX User ID and Password.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Select and answer five Challenge Questions and click the "Save Answers" button.
United Slates Environmental Protection Agency
CDXHome About CDX Recent Announcements Terms and ConrJfions FAQs Help
CDX,
Central Data Exchange
CDX Registration: Additional Verification
1. Identity Verification '
Lagged in as GEF1ON1 3 (Log i
CU Contact Us
Last Login: 5 29 2013 3:54:36 PM
2. Electronic Signature Agreement
You are registered for a program that requires eSignature PIN Verification. Please select five (5) challenge questions and answers. The questions that you select
should be questions that you can remember, but difficult for anyone else to guess.
Select 5 Challenge Questions and Answers
Who is your favorite author? ,Y |
What is your favorite hobby?
What was your high school's mascot?
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What is your favorite vacation destination?
What was your first pet's name?
This takes us to the Central Data Exchange page. Look for the MyCDXtab. Click the "Certify
Submission" link to add RMP facilities.
SEPA
United States Environmental Protection Agency
CDX*
CDXHome About CDX Recent Announcements Temis and Conditions FAQs Help
Central Data Exchange
Logged in as GEFION1 3 (Log out)
E3 Contact Us
Last Login 5 29 201 3 3:54 36 PM
MyCDX Inbox {2} My Profile Submission History
News and Updates
Manage Your Program Services No new5 updates
Status Program Service Name
o RMPESUBMIT: Risk Management Plan
Role(s)
Certify Submission
CDX Help Desk: 888-890-1 995 I (970) 494-5500 for callers from Puerto Rico and Guam
EPA Home | About CDX Frequently Asked Questions | Privacy and Security Notke | Terms and Conditions | Contt
10
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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Click the "Add New RMP Facilities" link to create your Electronic Signature Agreement (ESA) for
each facility you will be certifying.
(/.S, Gnvtrtmmtnttl PfQttstian Aqtncy
Now add the facility you want to be associated with your profile. To add more than one facility,
click the "Add another Facility" button, then click "Save".
It is important to enter the correct Facility ID of the specific facility for which you'll be
submitting an RMP. For a new facility/first-time submittal, the Facility ID field can be left blank,
but you need to furnish the complete facility information (name and full location address).
Once you click the "Save" button, the ESA (with relevant facility information) will appear.
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farms for IBCTC diaa one fadp'. you may add more than cmr Facility- ID by cickiag en 'Add Anotfaer Facility' When you faa\ e entered
aL of ™w FaciHf.• IDiji. click "Sav?" to iiw and print vonr Elfctrooic Sipiatafc A
Cfwngc Password
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11
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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Upon, completion, CDX will prompt you to print the ESA. Print all ESA pages.
RISK MANAGEMENT PLAN (RMP)
Electronic Signature Agreement
In accepting the electro-lie sigiJl^e erect* -ilia! iisued ixy !h« United Stales Environnwnlal
PA) to iign elecvoik RMP faints, submitted [a EPA's Central
Enchange (COX), on belulf of]
G«f>on Fros:
Loki Ctemknls
1234 Ware-io j« Way
Charleston
SC
J9J01
8433219876
uxi Chemicals
Warehouse Way
Charleston
sc
Certifying Official:
Registrant Qrganiiaoon:
Registrant i Mjiliig Addrnt 1:
HefisJisnt's Mailing Address 2:
City:
Swte:
Z.I>C«t.:
Phone fiumber
e-mail Address;
CDX User ID:
.1. :, •,.*•.-.
Facility Location Addreia 1:
Facility lootloi Address 2:
City:
State:
Ire, Cede:
tPA Facility WentifiBn
Agree to crotect my RMP electronic signature credential, CDX user name |Log«n ID)
and COX pais'.vord from LJS» by anycn* exc*;jt n**r. I w I. not divjlgu or dtrlegata ny
CDX uwsr name and pan word to arty other individual; I will not store my paiav.tird in
an jnproiected iocat-o-v aid I ivi'l r*ot allow my oasstvord to be v-ritten into
comoJter scriots to achieve *jtomated logh:
Agree to tontacl the Central Data ^change (CDX} Help Oeik at 1-888-890-1995 AS
sooci as aossisle, but oo la^ef than 24 hours, after sus-sectiog or detem-iiiing nai my
CDX .isef name and e>ass<.vord and/or electronic sigiatj.'* credential have t>ec-ome
Understa-wl that I vvlll be Informed through my registered eleclrorc mall 1*-mall)
sddress whenever my us«r idenrificstion or o*ssk\rwd have been modified:
UndersTa'vJ that COX reports the last date mv CD)! user -wme aid password wwe
used invnerji-dlely after successfully logging into CDX;
Agree that I wilt review tw ctFiieits of all RMP electronic submissions prior to
submission;
Und«rsi*!%d and agree that i vA\l be teld as legally bound, obligated, or responsible
bv my use of my electronic s^iattxe as 1 tvojld oe usmg mv oaid-v.ntten sig^iasjre;
a -ai •3EFCMJ
te.--lrup.c- Signature
Certify any
Certif>' any
ed e-r^-ia I address. Th»-s e-mail vj'ilt f^focm me th»t a submission *tas beei
the certlfier an-rf the facility. In «WU»on. it will -rontaln the date of c«*tific.«iof> and
the tame of ttiB Ccrtifyite Official. The ••mail will also contain a copy of record of
mv 5 jortiiiiion (or my review
{S| AgrtM that K I r.»caiv» notification For a submission From my account that I do not
helieune that I S jiamilled. 1 will noCafy Ihe CDX Help Desk ai soon Ji poliiu'e. but no
latef than 2^1 hours, after receipt;
(9| AŁr*« to contact COX H«lp D*»k if 1 do not r*c*iv* a nextiftcatiot n§c*ipt to aitfwr mv
CDX !r»ixjK oc registered e-iTiai I within 5 business days- 'or any submissiori that I
certified using my electronic signature credential;
• 1C | '.ViH -xrtl'y CDX within 2 '.v-seki H r he event that t am rw tortger a certifyi-ie official
for the facility listed In this agreenie-n so that my RMP electianic s->g as I tonii-vje to reareient
the regelated entity soeclfi«d above as signatory of that organization's electronic
submissions,
Show, below is the CDX User ID that I created for my role as. 'Certifying Official ' and
.'rfi--le registei-lng for RMP'eSubmit. My CDX User ID will serve as mv elecirwaic sig'-at^e
c redemtlaJ when I certify RMP submissions, t understa-wt that I v^ll be asked for mv COX
tser ID ?™J passvtord each time ' efectroni^sl ly sigi sn RMP form subm-ssion,
CDX USER ID for CERTIFYING OFFICIAL: GEFION13
12
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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Owner or Operator Authorization
Please Indicate t<*e option that a33 lies TO your facility and proviecessafv signature
t*
lection Agency
Option A: Owner or Operator ti Ctrttfylnf O#FkW.
I, , as the owner or operator of this facility will be t
certifying official for this facility and am a jihoriied to submrt documents on th*
facility's behalf.
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letftuDk Siii
»Ctrti^ any
I
Option i: Owner or Operator authorlact a deiifnate-d senior management official
•mpfoytd by th* facility to certify d«umenti on fielllty'i b*h*H.
_, as the owner or operator of !h>s facilitv a
i. -. B4 Hr:it,,r , D
_, to be t*»e certifying official ftx
_f wtth Bermlsslon to submit doc jments on the
s behalf-
Certify any
Definitions
1. Electronic signature means ai\ informalion in d'gi'.a1 form l*vat ii ;nc[ jded in or
logiL3il>- dssctiaifid with am eleitrunic dorijtmanc for Eh« cur pose of enpres&iig the
same meaning and lo?en?^ori as would a handwritten signature if affixed to an
equivalent paoer document vwt*i the same reference to ITS same content. T>«
elsctronie doe jment baair or has on it an «1«tronic signaMr^ wh^? it *nct jdlc^ gr has
logically associated with iT suci i
2. Electronic signature credential rmimn to the Tocen held by the individual user that is
used to eltctrflrtkaHy sign electronic ajbrniiSrons. In th* caift of RUP, l»w electronic
signature cfedenrtlal1 consists of the COX User ID and oassword riat an RMP Certtfler
entered v,tien they created t^eir CDX account. The COX User ID and oassvwrd urtll be
ask«J each time a iiser att««npt3 to certrfv an fiMP electronic s.iampssl&n through COX
and tha correct answvn v/i II allow far the certification and submission of the RMP flbe
to EPA.
3. The Owner or Operator is typically the highest management official ai the facilitv.
terrify 3nv
.'-. i-TnLiL
PLEASE MAIL THE COMPLETED ELECTRONIC SIGNATURE AGREEMENT
PROMPTLY TO:
U.S. Environmental Protection Agency
Attention: RMP Reporting Cenltt
P. O. Box 10152
Fairfax, VA 22038
l? you prefer to tend vojf Electronic Signature Agreement by certified mall, courier or
overnight mad |e.g . Fed E*. LPS. etc.I please address it to;
RMP Reporting C»it*r
c/oCGI Federal, inc.
12601 Fair Lakes Circle
FalrfM.VA 22033
Phone: 703-227-7650
e click PRINT & CLOSE to get a hard copy of this agreement.
I
Certify any
13
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
Once you have printed all pages of the ESA and closed the document, a Successfully Registered
confirmation page will appear. This completes your registration as a Certifier.
Next, follow the instructions on how to sign (Wet Ink Signatures). Mail aM pages of the
completed ESA to the RMP Reporting Center. The RMP Reporting Center will verify the ESA for
completeness. It will then approve and generate the Authorization Code (AuthCode) needed to
prepare an RMP for each facility. Since the ESA must be mailed, received, and processed, please
allow one week from the date of receipt for your ESA approval.
An email containing an AuthCode for each requested and approved facility will be sent to the
Certifying Official at the email address provided during CDX Registration.
Ce
:..::-.tr. Jteclmnti Slyulmt AarMmtnl IESAJ ClIST
This was sent fro* the TEST environneni I
Vour Electronic iignjturt Agrttitnt {ESA) h*s th««n received »nc APPROVED for th« f«- «*ch facility \D prepare i lubninlon uiing RllP"«Siita»it. For nor* inforniTior pl««s« follou th«
instructions in t»t« HNP'eSubnlt - user
*uthorii»tion Code; 9dfS9f 39-6e42-44J6-93-41-WfSSdl391e«
EP* Facility ID: 19W 6621
Facility; Lofci
»r*hDL'ie Way
Charleston SŁ, 2948-1
unites states Environmental Protection Agency c*?it-al Data Exchange
Once the email has been received, the AuthCode will be used to prepare RMP. The Certifying
Official is responsible for providing the AuthCode to the Preparer so that they can register in
CDX and prepare the RMP.
NOTE: For first-time submissions, the email to the Certifier will include a new Facility ID
in addition to the AuthCode. Once the Preparer enters the AuthCode, they will be
directed to the RMP*eSubmit welcome screen with the new ID and location address.
NOTE to Preparers: The AuthCode is a long string of letters and numbers. Please copy the
AuthCode from your email and paste it in the box when prompted.
NOTE: If you already have the Certifier Role and you also want to be a Preparer, you can
access this screen by returning to MyCDX. Click the "CDX Home" link on the top left hand
side and click "Go to MyCDX". On the MyCDX page, choose "Manage Your Program
Services". Next, click "Request a New Role" under the "RMPESUBMIT: Risk Management
Plan" link.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Central frata
y jruq«- Program
Select "Preparer" from the drop-down menu and click "Add selected role". Enter your
AuthCode and click the "Save" button.
Ifll pnir"Ti iirm iril nil frnrr fil Im tlh r Titii
15
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Your MyCDX page will now display the roles that you have added to your profile (i.e., For
Certifying Official - Certifying Submission, and for Preparer - Prepare Submission).
NOTE: A Preparer's MyCDX page will only have the "RMP*Prepare Submission" link.
CDX,
MM I W*
fl-U n*|i
frntr.il D.H.I
'i, A . .
Click the "Prepare Submission" link and you'll be able to select the Facility ID you need to
update the RMP. (If you are assigned multiple RMPs, a drop-down list of the Facility IDs
assigned to you will be shown. Choose the correct Facility ID and Proceed.)
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Preparing RMP and Facility ID Option Page
Once you select a facility ID from the drop-down list, click "Proceed" and you'll be directed to
the RMP*eSubmit Home page.
Central Data Exchange
Contact
Last Login 1 7 2014 12:05:10
Application Profile Settings
Status Progra
& CEDRI1
& eNOI E
and VC
~ RS-US
& iBoard
Program Client ID !
Program :
RMPESU3MIT
& ODS: Ozone Depleting Substances
Substances Review
Ozone Depleting
From the RMP*eSubmit Home page you'll prepare your facility's Risk Management Plan (First-
time Submission, Correction, or Resubmission) using the RMP*eSubmit application. Once
completed, you'll submit the RMP to your Certifying Official for certification.
NOTE to Preparer: If you are the Preparerfor one facility, you'll directly be accessing the
RMP*eSubmit Home page. If you are the Preparerfor more than one facility, you'll see a
dropdown list from which to choose the facility that needs to be updated (as shown in
the previous screen shot).
For a first-time submission, the Home page will resemble the screenshot below.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
For a Correction or Resubmission, the screenshot will resemble the screenshot below.
Adding the Preparer Role
Select the appropriate button (Correction or Resubmission) and you will have access to the
RMP*eSubmit program to update your RMP.
si Prolection Agency
CDXHorae About CDX Recent Announcements Terms and Conditions Help
Terms and Conditions
CDX,
Contact Us
A
The access and use of CDX Registration for the electronic submittal of environmental information require the creation of a user ID and password that I must
maintain and keep confidential. I will review the following steps concerning the creation and maintenance of a user ID and password.
Warning Notice
EPA's Central Data Exchange Registration procedure is part of a United States Environmental Protection Agency (EPAj computer system., which is for
authorized use only. Unauthorized access or use of this computer system may subject violators to criminal, civil, and or administrative action. All information
on this computer system may be monitored, recorded, read, copied., and disclosed by and to authorized personnel for official purposes, including law
enforcement. Access or use of this computer system by any person, whether authorized or unauthorized., constitutes consent to these terms.
Privacy Statement
EPA will use the personal identifying information which you provide for the expressed purpose of registration to the Central Data Exchange site and for
updating and correcting information in internal EPA databases as necessary. The Agency will not make this information available for other purposes unless
required by law. EPA does not sell or otherwise transfer personal information to an outside third party. [Federal Register: March 1 8; 2002 [Volume 67,
Number 52)][Page 1201 0-1 201 3].
Choosing a CDX Password
Fnr my reni^trarinn nurnn^ps I snrpp rn splprr a na^^wnrH which will nnr hp
ISD I Accept
O I Decline
- nup<;<;pH I'P n
namp mv rhildrpn's namp1; hirThHa1^ Ptr 'i
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
On the Core CDXRegistration page, scroll to the "RMPESUBMIT: Risk Management Plan" link
and click.
v>EPA
United States Environmental Protection Agency
CDX Home About CDX Recent Announcements Terms and Conditions Help
Core CDX Registration
CDX,
CH Contact Us
. Request Program Service
2. Request Role Access 3. Provide User and Organization Information 4. Confirmation
Begin tyaing a program ser/ice name or related keywords to filter the list of available ser/ices (e.g . air quality system. AQS, or Clean Air Act)
Active Program Services List
ACRES: Assessment Cleanup and Redevelopment Exchange System
ARCS: Aircraft Reporting and Compliance System
CEDRI: Compliance and Emissions Data Reporting Interface
CROMERRLiteTest: CROMERR Lite Testing Utility
CROMERRTEST: CROMERR Test Sandbox
CSPP: Submissions for Chemical Safety and Pesticide Programs
EAB: Environmental Appeals Board
This brings us to the Request Role Access section. This time, let's choose "Preparer" and click
the "Request Role Access" button.
CDX,
LJ Contact Us
3. Provide User and Organization Information 4. Confirmation
CDX Home About CDX Recent Announcements Terms and Conditions Help
Core CDX Registration
1. Request Program Service '
Registration Information
Program Service: Risk Management Plan
Role: Not selected
2. Request Role Access
Select a role from the drop down list and provide any required additional information, if applicable
Select Role
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Enter (paste) the AuthCode in the box provided and click "Save". The AuthCode will be provided
by your Certifying Official.
xvEPA
States Environmental Prote
CDX,
CDXHome About COX Recent Announcements Terms and Conditions FAQs Help
Core CDX Registration
1. Request Program Service '
Registration Information
Logged in as JPNOBLERMP (Logout)
L3 Contact Us
Last Login: 1,7,2014 11:55:17 AM
2. Request Role Access '
3. Organization Information
Program Service: Risk Management Plan
Role: Preparer
Authorization Code '
For a First-time submission, the Welcome page will resemble the screenshot below.
About CDX
MyCDX
Inbox
Change Password
Freqw
Questions
Kelp & Support
CDXHome
Terms & Conditions
Logout
Welcome to RMP"eSubrnii. This is a tool developed by the U.S. Environmental Protection Agency J.EPA} to assist you in entering and submitting your Risk Management
Plan (RMP).
Your facility will have submitted an electronic signature agreement :.ESAj and named both a certifier and prepareds^ fervour facility. You should find the name of your
facility b-elc-w.
If you would tike to vie\vycur facility's most current RMP. select the View Current R\IP button.
A First-time submission require; that you enter information for all nine sections of theRM?. A Section Selection function \viLI appeal' on the next page.
If you have previously submitted an RMP. your facility information \villbepre-populated. In order to make a Correction to your existinsRM? or a Re submission.
please click on the appropriate butt on for further action.
A Correction should be used to report administrative or other changes at your facility (s.s. changes in emergency contact information, facility address, or change in accident
history). This does not require .an update of your entire RMP Submitting a corrected RMP does not change your five-year anniversary date. I: your facility ha; not
submitted an RMPR.esubmissionby its anniversary date, you will not be able to make an RMP Correction. You must submit anRMPRssubmisstonin this instance. The
Correction button enables you enter the data for your facility and update the RMP as a correction.
A Re submission is an update of all nine sections of your RMP. Revising your previous RM? appropriately and submitting the updated RMPResubmission \vill re-set
your five-year anniversary date. The Resubmissicn button enables you enter the data for your facilttv and update the RMP as a Resubrnission.
NTN'G! You can not use this system if you are reporting Confidential Business Information tCEQ. Please contact the RM? R.eponing Center at ?Oi-429-501S for
questions regai'dtns CBI reportins.
Selected Facility:
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
For a Correction or Resubmission, the screen will resemble the screenshot below.
Welcome toRMP*eSubinit. This is a tool developed by the U.S. Environmental Protection Aeency [EPA1, to assist you in enterins and sufcmittinr your P_isk Management
About CDX
MyCDX
Inbox
Change Password
Frequently Asked
Questions
Terms & Conditions
Logout
Your facility ^vill have submit ted an electronic signature agreement :,ESA> and named both a certiner and preparer;*': fervour facility. You should find thenains of your
facility below.
If you would like to viewycur facility's most current PJi.IP. select the Vieir Current RMP butt en.
A First-time submission requires that you enter information for all nine sections of the RMP. A Section Selection fun::icc will appear on the next pase.
I: you have previously submitted an RMP. your facility information v.-ill be pre-pepulated. In order to make a Correction tc your existing F_M? cr 5 Resubmission.
please click on the appropriate button for further action.
A Correction sticuld te used tc fiport administrative cr other chanses at your facility (e.sr. clunees in emereencv contact information, facility address, or chanjs in a:;ider.t
histon.^. This does not re-quire an update of vcur entire PA5*. SubmittinE a corrected RT^IP dees not change your five-year anniver;ar>- date. If your facility has not
submitted an FJM? P,eiubmisi.ion by its anniversary date: vcu will not be able to make an R3.IP Correction. You must submit an RIvI? Resubmission in this instance. The
Correction button enables you enter the data for your facility and update the RZ\I? as a correction.
A Resubmission is an up date of all nine sections ofyearRMI*. Revisins your previous FJXI? appropriately and submitiinE the updated F.3.1? R.esubmi;sionT.villre-iet
your five-year anniversary date. 7ne F_esubrnissicn button enables you enter the data for your facility and update the RM? as a F.esubmissioiL
'VARXIXG! Ycucannct use this system if you are reporting Ccnfidential Business Information i'CBI;. Please contact cheR^^IPR-eportins Centei-at 501-423-5013 for
questions regarding CBI reponing.
Select the appropriate button ("Correction" or "Resubmission") and you will have access to the
RMP*eSubmit program to update your RMP.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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CHAPTER 2 ENTERING DATA
(FIRST-TIME, CORRECTIONS, RESUBMISSIONS)
Section 1. Registration
All covered facilities must complete the registration portion of the RMP, even if they have a
Program 1 process. The registration section requires facility identification information. You
cannot enter data for Sections 2 through 5, 7, and 8 until you have entered process-specific
information.
About CDX
F.lyCDX
Inbox
Change Password
Frequently Asked
Questions
Help & Support
CDX Home
Terms & Conditions
Logout
U.S. Environmental Protection Agency
RMP*eSubmit Section Selection
Recent ^nncuncements Ccntact Us
Logged in as. GEFION13
I EPA Facility ID:
1100000215689
Loki Chemicals
Transaction Type: First
Time Submission
Introduction to RP.1P*eSubmit
Section 1. Registration
Enter Registration Information
Section 2. Toxics: Worst Case
Section 3. Toxics: Alternative Release
The following is a discussion of each element in Section 1. Registration. Click the "Enter
Registration Information" button.
NOTE: Please remember to periodically use the "Save and Return" button at the bottom
of the page. As a security measure, if you remain inactive in the system for 19 minutes,
the system will log you out at the 20th minute and your entered data will not be saved!
Each time you save, the system will return you to the RMP*eSubmit Section Selection
page. Click the "Enter Registration Information" button to enter more data.
NOTE: If you do not wish to keep the information you've entered, click the "Discard
Changes" button.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
U.S. Environmental Protection Agency
e~: ^""Co-cements Ccrtact U=
EPA Facility ID:
100000215689
Transaction Type: First
Time Submission
1.1. Source Identification:
1.1-3- Facility name *
1 1 b Parent company #1 name
1 1 c Parent company #2 name
1.2. EPA facility identifier:
1.3. Other EPA systems facility ID:
1.4. Dun and BradStreet numbers (DUNS)
14 a Facility DUNS:
1 4 b Parent company #1 DUNS:
1 4 c Parent company #2 DUNS:
1.5. Facility location address:
Norse Chemical Manufacturers
1234 Warehouse Way
1.1 Source identification
l.la. Facility name:
Provide the name of your facility. The name must be specific to the site; if the site is part of a
large corporation, the name may be the corporate name plus the location (for example, "ABC
Chemicals - Hightown Plant").
Definition:
Throughout the Risk Management Program, the term facility means "any buildings,
structures, equipment, installations or substance emitting stationary activities (i) which
belong to the same industrial group, (ii) which are located on one or more contiguous
properties, (Hi) which are under the control of the same person (or persons under
common control), and (iv) from which an accidental release may occur."
1.1 b. Parent company #1 name:
The parent company is the corporation or other business entity that owns at least 50 percent of
the voting stock of your company. If your facility is owned by a joint venture, enter the first two
major owners here. If your facility does not have a parent company, leave this data element
blank.
l.lc. Parent company #2 name:
If your facility is owned by a joint venture, enter the name of the second major owner here.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
1.2 EPA facility identifier (display only):
The facility ID number for your facility is displayed. This is a be
If you need a new facility ID number, contact the RMP Reporting Center at 703-227-
7650.
1.3 Other EPA systems facility identifier (only 15-characters allowed):
In EPA's efforts to streamline facility reporting, incoming facility information needs to be linked
with existing facility information across different environmental programs. To help ensure your
facility's RMP data is properly linked and that your facility does not receive multiple EPA facility
IDs, please enter one of the following facility identification numbers in the following priority
order:
• First, if your facility has a 15-characters Toxic Release Inventory identification number
(TRI ID), enter it here. If your facility has a TRI ID, but you do not know the number, you
can find it by searching the TRI database,
http://www.epa.gov/enviro/facts/tri/customized.html or by calling the EPA's Superfund,
TRI, EPCRA, RMP & Oil Information Center (also known as the Info Center), 1-800-424-
9346.
• Second, if your facility does not have a TRI ID, but reports to EPA under another
program and has a number referred to as a FINDS or Unique Identification Number (DIN
with 12 characters), enter it here. If your facility has a FINDS or DIN number, but do not
know what it is, you can find it by searching EPA's Facility Identification Initiative (Fll)
database, http://www.epa.gov/enviro/html/fii/fii query java.html.
• Third, use any one of the following numbers:
o If your facility is covered by hazardous waste regulations under the Resource
Conservation and Recovery Act (RCRA), enter your RCRIS Handler ID (12
characters). You can find your RCRIS ID via
http://www.epa.gov/enviro/html/rcris/rcris query java.html (clicking this link
opens a new browser window)
o If your facility is covered by regulations under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), enter your CERCLIS Site ID
(7 characters). You can find your CERCLIS ID via
http://www.epa.gov/enviro/html/cerclis/cerclis query.html
o If your facility does not have an ID number as described above, leave this data
element blank.
1.4 Dun and Bradstreet Numbers (DUNS):
1.4a. Facility DUNS:
The Data Universal Numbering System (DUNS) is a nine-digit identification number that allows
your facility to be cross-referenced to various business information. If your facility has a DUNS
number, it should be available from your treasurer or financial officer. You can also obtain the
24
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
1234 Warehouse Way
number from your local Dun and Bradstreet office (check the telephone book White Pages). If
you do not have a DUNS number, leave this field blank.
1.4b. Parent company #1 DUNS:
Provide DUNS number of your parent company(-ies), if applicable. If your facility is owned by a
joint venture, provide the numbers for your two major owners. If your facility does not have a
parent company or the parent company does not have a DUNS number, leave this field blank.
1.4c. Parent company #2 DUNS:
Provide DUNS number of your second parent company, if your facility is owned by a joint
venture. Otherwise, leave this field blank.
11.5. Facility location address:
1.5.a. Street 1 *
1 5 b Street 2
1.5.C. City: *
1 5 d State *
1 5 e Zip *
1 5 f County: *
| Facility latitude and longitude (decimal degrees):
1 5 g Latitude (dd dddddd). "
1 5 h Longitude (ddd ddddddj *
1 5 i LaMong method *
1 5 j Lat'long description: *
1.5.k. Horizontal accuracy measure (m): *
1 5 I Horizontal reference datum code "
Charleston
SOUTH CAROLINA
32.733433
-79.869919
A2 Address Matching - Block Face
AB Administrative Building
World Geodetic System of 1984 v]
1 5 m Source map scale number *
11.6. Owner or operator:
1.6.a. Name: *
1 6 b Phone:'
Required only if 1.5i is selected as Interpolation-Map or
Interpolation-Photo
ErikSnorri
843 -123 -4567
1.5 Facility location address:
Provide your facility location address, including the street, city, state, and ZIP code (including
the 4 digit extension, if applicable. This is the location where regulated substances are present.
The city should be the local legal jurisdiction, such as a township or village. Use local street and
road designations, not post office or rural box numbers. This location may not represent the
mailing address. EPA will not attempt to mail correspondence to this address. All
correspondence will be mailed to the address provided at 1.6 c-g. If your facility location and
mailing address are the same, then you will fill in the same address at 1.6 c-g.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
l.Sa. Street 1:
Provide your facility location address.
l.Sb. Street 2:
Provide any additional facility location address information.
l.Sc. City:
Provide the city name from your facility location address.
l.Sd. State:
This is a pre-populated field and can't be edited.
l.Se. ZIP code:
Provide the ZIP code from your facility location address, including the 4-digit extension (if
applicable).
1.5f. County:
The drop down list will populate with counties based upon the facility location state. Select a
county from the drop down list that appears when you click the down arrow. If you edit this
element with a county different from the county entered previously, you will have to select or
enter a new LEPC in field "1.10 LEPC."
Facility latitude and longitude (decimal degrees):
l.Sg. Latitude (dd.dddddd):
Provide the latitudinal coordinates of your facility. Facility latitude must be a value between -90
and 90. Decimal degrees use the format: +/- dd.dddddd where:
"-" = west of the prime meridian (longitude) or south of the equator (latitude)
"+" = east of the prime meridian (longitude) or north of the equator (latitude)
NOTE: If you edit your facility's latitude, it must fall within the specific lot/long
(latitude/longitude) boundary for your facility's address, or it will be rejected by
RMP*eSubmit
l.Sh. Longitude (dd.dddddd):
Provide your facility longitude in decimal degrees. You must provide the longitudinal
coordinates of your facility. Facility longitude must be a value between -180 and 180. Decimal
degrees use the format: +/- ddd.dddddd where:
"-" = west of the prime meridian (longitude) or south of the equator (latitude)
"+" = east of the prime meridian (longitude) or north of the equator (latitude)
NOTE: If you edit your facility's longitude, it must fall within the specific lot/long
boundary for your facility's address, or it will be rejected by RMP*eSubmit.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
l.Si. Lot/Long method:
You also must indicate the method that you used to determine your facility's latitude and
longitude data. Select the method for which you obtained your lat/long coordinates from the
drop down list.
l.Sj. Lot/Long description:
The table below lists the codes to be used for this element and provides a brief description of
each method. The most common methods for determining latitude and longitude are II
(Interpolation-Map), and 14 (Interpolation-Digital Map Source). Use II if you obtained your
facility's latitude and longitude from a paper map. Use 14 if you obtained your facility's latitude
and longitude from a computer-based geographic information system (CIS).
Code
AB
AE
AM
AS
AV
CE
FC
IP
LC
LF
LW
NE
Abbreviation
Administrative Building
Atmospheric Emissions
Treatment Unit
Air Monitoring Station
Air Release Stack
Air Release Vent
Center of Facility
Facility Centroid
Intake Pipe
Loading Area Centroid
Loading Facility
Liquid Waste Treatment
Unit
NE Corner of Land Parcel
Description
A building, structure, or portion thereof that houses the administrative
functions of a facility as opposed to production or manufacturing
activities
Equipment installed for the express purpose of treating chemical
emissions prior to their release into the atmosphere
Equipment installed at a predetermined location for the automatic,
manual, or periodic collection of environmental air samples
A free-standing vertical structure constructed for the conveyance and
release of chemical emissions into the air
A horizontal structure constructed for the release of chemical
emissions into the air, typically from the side or roof of a building
A representative center point within the boundary of a facility
The calculated center of a contiguous facility
A pipe or intake opening constructed for the collection and
conveyance of water
The calculated center of a portion of a facility associated with loading
activities
The portion of a facility associated with loading and/or transshipment
activities
Equipment installed for the express purpose of treating chemical
emissions prior to their release to water, publicly owned treatment
works (POTW) or off-site transfer
The northeast most corner or boundary of a land parcel
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
NW
NW Corner of Land Parcel The northwest most corner or boundary of a land parcel
OT
Other
See descriptive comment field
PC
Process Unit Area Centroid
The calculated center of a portion of a facility associated with
processing and/or manufacturing activities
PF
Plant Entrance (Freight) The entrance to a facility associated with transshipment activities
PG Plant Entrance (General) The front gate or general entrance of a facility
PP
Plant Entrance (Personnel)
The entrance to a facility associated with employees
PU
Process Unit
The portion of a facility associated with processing and/or
manufacturing activities
SD
Solid Waste
Treatment/Disposal Unit lof solid waste
The portion of a facility associated with the treatment and/or disposal
SE
SE Corner of Land Parcel The southeast most corner or boundary of a land parcel
SP
Lagoon or Settling Pond
The portion of a facility designed to accommodate sedimentation or
settling of chemical by-products necessitated by the manufacture,
production, or use of chemicals
SS
Solid Waste Storage Area The portion of a facility associated with the storage of solid waste
ST
Storage Tank
A receptacle or chamber used for storing bulk fuels or chemicals
SW
SW Corner of Land Parcel The southwest most corner or boundary of a land parcel
UN
Unknown
WA
Wellhead Protection Area An area at the earth's surface buffering a wellhead
WL
Well
A shaft drilled in the earth for purposes such as obtaining subsurface
drinking water, or collecting groundwater monitoring samples
WM
Water Monitoring Station
A location or study area for the automatic, manual, or periodic
collection of water samples
WR
Pipe Release to Water
The point at which a pipe constructed for the conveyance and release
of water-borne chemical emissions reaches a water body
1.5k. Horizontal accuracy measure (in meters):
This data provides a single, uniform statistical methodology for estimating the positional
accuracy of points on maps and in digital spatial data. If you have difficulty obtaining this
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information, please contact the EPA's Superfund TRI, EPCRA, RMP & Oil Information Center at 1-
800-424-9346 for additional guidance.
1.51. Horizontal reference datum code:
You must select the code from the available drop down list that represents the reference
datum used in determining the lat/long coordinates you entered in 1.5 g and 1.5 h,
respectively. If you have difficulty obtaining this information, please contact the EPA's
Superfund TRI, EPCRA, RMP & Oil Information Center at 1-800-424-9346 for additional
guidance.
The range of permissible values includes:
Horizontal Datum Code
Horizontal Datum Description
001
North American Datum of 1927
002
North American Datum of 1983
003
World Geodetic System of 1984
North American Datum Code of 1927
The North American Datum (NAD) of 1927 uses the Clarke 1866 spheroid to represent the
shape of the earth. The origin of this datum is a point on the earth referred to as Meades Ranch
in Kansas. Many NAD 1927 control points were calculated from observations taken in the
1800s. These calculations were done manually and in sections over many years. Therefore,
errors varied from station to station.
North American Datum Code of 1983
The North American Datum of 1983 is based upon both earth and satellite observations, using
the GRS80 spheroid. The origin for this datum is the earth's center of mass. This affects the
surface location of all longitude-latitude values enough to cause locations of previous control
points in North America to shift, sometimes as much as 500 feet. A 10-year multinational effort
tied together a network of control points for the United States, Canada, Mexico, Greenland,
Central America, and the Caribbean.
Because NAD 1983 is an earth-centered coordinate system, it is compatible with global
positioning system (GPS) data. The raw GPS data is actually reported in the World Geodetic
System 1984 (WGS 1984) coordinate system.
World Geodetic System of 1984 (WGS84)
The World Geodetic System of 1984 is the reference frame used by the U.S. Department of
Defense and is defined by the National Imagery and Mapping Agency (formerly the Defense
Mapping Agency). WGS 84 is used by Department of Defense for all its mapping, charting,
surveying, and navigation needs, including its GPS "broadcast" and "precise" orbits. The latest
revision of WGS 84 was in 2004.
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1.5m. Source map scale number:
This is the proportional distance on the ground for one unit of measure on a map or photo. This
information must be supplied if you have chosen a lat/long method of type Interpolation - Map
(II) or Interpolation - Photo (12). If you have difficulty obtaining this information, please contact
the EPA's Superfund TRI, EPCRA, RMP & Oil Information Center at 800-424-9346 for additional
guidance.
| 1.6. Owner or operator:
1 6 a Name *
ErikSnorri
1 6 b Phone: *
1 6 c Street 1: *
1 G d Street2
1 6 e City *
1 6 f State *
1 5 9 Zip *
1 6 g Foreign country address Country: *
1.6.f. State/Province: *
1.6.h. Zip/PostalCode
S43 -123 -4567
11234 Warehouse Way
Charleston
SOUTH CAROLINA
Edda Prose
| 1.7. Name and title of person or position responsible for Part 68 (RMP) implementation:
1 7 a Maine of person
1 7 b Title of person or position *
1.7.C. E-Mail address
1.6 Owner or operator:
1.6 a. Name:
This is the name of the legal owner or operator of the facility (person, company, association, or
government agency).
1.6b. Phone:
Provide the facility owner or operator's business phone number, including area code.
1.6c. Street 1:
Provide the facility owner or operator's business mailing address, street - line 1. In this
instance, you may use post office and rural box numbers, if appropriate. This is the address to
which all correspondence will be mailed.
1.6d. Street 2:
Provide the facility owner or operator's business mailing address, street - line 2. In this
instance, you may use post office and rural box numbers, if appropriate. This is the address to
which all correspondence will be mailed.
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1.6e. City:
Provide the facility owner or operator's business mailing address, city. The city should be the
local legal community, for example, a township or village. This is the address to which all
correspondence will be mailed.
1.6f. State:
Use the drop down list to select the state of the facility owner or operator's business mailing
address. This is the address to which all correspondence will be mailed. You may also select a
state from the list that appears when you click the down arrow.
1.6g. ZIP code:
Provide the facility owner or operator's business mailing ZIP code (including 4-digit extension, if
applicable). This is the address to which all correspondence will be mailed. If the address is in
a foreign country, select the country, then provide the state/province and postal code.
1.6g. Foreign country address (if applicable):
Country:
Provide the owner or operator's foreign business mailing address country.
1.6.f. State/Province:
Provide the owner or operator's foreign business mailing state or province.
1.6.h. ZIP/Postal code:
Provide the owner or operator's foreign business mailing address ZIP/postal code.
1.7 Name and title of person responsible for RMP 40 CFR Part 68 implementation:
1.7 a. Name of person:
Provide the name of the person with overall responsibility for the Risk Management Program at
your facility site. Although the individual's name is not required, the title of the person or the
position that has this responsibility is required.
1.7b. Title of person or position:
Provide the title of the person or position with overall responsibility for the Risk Management
Program at your facility site. Although the individual's name is not required, the title of the
person or the position that has this responsibility is required.
1.7c. Email address (optional):
Provide the email address of the person or position with overall responsibility for the Risk
Management Program at your facility site. The individual's email address is not required.
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1.8.a. Name *
1 3 b Title *
1 3 c Phone "
1 3 d 24-hour phone *
1.8.e. Ext or PIN
1 3 f E-Mail address *
1.9. Other points of contact:
1.9.a. Facility or parent company E-Mail address
1.9.b. Facility public contact phone
1 9 c Facility or parent company VMW homepage address
1.10. LEPC:
Specify if Other selected
1.11. Number of fulltime equivalent employees on site: *
B
1.12. Covered by:
1 12 a OSHAPSM:
1 12 b EPCRA section 302:
1 12 c CAA Title V
(enter M,'A if not applicable;
Other/Unknown
"
or Claim as CBI? D
n
n
n
1.8 Emergency contact:
1.8a. Name:
Provide the name of the person designated as the emergency contact. If your facility has a
regulated toxic substance, you may already have designated a facility emergency coordinator in
your notification to your Local Emergency Planning Committee (LEPC) under EPCRA Section
312. If your facility has more than one emergency contact, provide just one name for this entry.
You may want to list the other emergency contacts in your Executive Summary.
Your emergency contact name should be:
• An employee or contract employee of your facility;
• Knowledgeable about your site;
• Aware of all emergency plans and procedures; and
• Able to provide emergency response support or be able to direct/assist emergency
response personnel to provide support.
1.8b. Title:
Provide the title or job classification of the person designated as the emergency contact. If you
have a regulated toxic substance, you may already have designated a facility emergency
coordinator in your notification to your LEPC under EPCRA Section 312.
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1.8c. Phone:
Provide the phone number, including area code, where the emergency contact can be reached
during normal business hours. You will most likely provide the facility telephone number here.
If your facility does not have a phone number, you may provide the business phone number of
the emergency contact, the phone number of a dispatcher, or the customer service phone
number.
1.8d. 24-hour phone:
Provide a 24-hour phone number for your facility.
1.8e. Ext. or PIN:
Provide an extension or PIN #, in this space, if applicable.
1.8f. Email address:
Provide the email address for the emergency contact who can be reached during normal
business hours. If your facility does not have an emergency contact email address, enter N/A.
1.9 Other points of contact (optional):
1.9a. Facility or parent company email address (optional):
You may provide an email address to which inquiries from the public could be sent. The email
address could be for the person who developed your RMP or your public liaison office.
1.9b. Facility public contact phone (optional):
You may provide a phone number for public inquiries. It could be the phone number of the
person who developed your RMP or of your public liaison office.
1.9c. Facility or parent company (www. homepage address (optional):
You may provide the Internet address where you have details on your accident prevention
program or other facility/corporate information.
1.10 LEPC:
Select the name of your LEPC for your planning district from the drop down list. LEPCs were
created to do local planning under the Emergency Planning and Community Right to Know Act
(EPCRA) of 1986. In RMP*eSubmit, you will select your LEPCs name from a drop down list
based on the facility county information that you have entered. If you are unsure or do not
know the LEPC associated with your county, select Other/Unknown.
Specify if Other selected:
If the LEPC that represents your county does not appear on the drop down list and you
know the name of your LEPC, select Other/Unknown and type the LEPC name.
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NOTE: If you do not know your LEPC's name, you can contact your local fire department
or your State Emergency Response Commission (SERC):
http://www2.epa.gov/epcra/state-emeraency-response-commissions
1.11 Number of full-time equivalent employees on site:
Provide the number of full-time equivalent employees who work at your facility. To determine
the number of full-time equivalent employees at your facility, add together the fractions of full-
time work performed by part-time or seasonal employees and round to the nearest whole
number. Do not include contract employees. If your facility is unmanned or is only staffed by
part-time employees, you should briefly explain these circumstances in the Executive Summary.
D
n
n
n
Other
v
| 1.12. Covered by:
1 12 a OSHAPSM:
1 12 b EPCRA section 302
1 12 c CAA Title V
1 12 d Air operating permit ID
1.13. OSHA Star or Merit Ranking:
1.14. Last safety inspection (by an external agency) date:
1.15. Last safety inspection performed by an external
agency: *
Specify if Other selected
1.16. Will this RHP involve Predictive Filing?:
1.17. Processes
1.18. RMP Preparer Information:
If an outside contractor prepared this risk management plan please enter information concerning this contractor in the fields below
If you enter an outside contractor name in 1 18 a then you must complete 1 18 b through 1-18.f.
1 18 a Name
1 18 b Telephone: *
1 18 c Streetl *
1 18 d Street2
1 18 e City: "
D
To register covered processes return to Section Selection page
Section 1 Add Process button
1.12 Covered by:
1.12a. OSHA'sPSM:
This element refers to OSHA's Process Safety Management (PSM) of Highly Hazardous
Chemicals Standard (29 CFR 1910.110). This data element applies to your facility as a whole and
is not a process-by-process determination. Therefore, if any process at your facility is subject to
the OSHA PSM standard, check this box, even if the PSM process is not covered by the RMP
rule.
NOTE: For further information about OSHA's PSM standard, visit:
http://www. osha. gov/SLTC/processsafetymanagement/
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1.12b. EPCRA Section 302:
If you have more than a threshold quantity of a substance that is an Extremely Hazardous
Substance (EHS) on site, your facility is subject to EPCRA Section 302 notification requirements
(a one-time notification to the State Emergency Response Commission (SERC) and LEPCthat
states your facility has one of the listed EHS on site). If your facility is subject to those
requirements, check this box, regardless of whether the EHS is covered by the RMP rule or is
held in a process that is below the Section 112(r) threshold quantity. Two quick hints:
• If your facility is subject to the RMP rule because you have more than a threshold
quantity of a toxic substance listed under Section 112(r), you are subject to EPCRA
Section 302. Select this data element.
• If your facility is subject to the RMP rule only as a result of flammable substances, you
are not subject to EPCRA Section 302. Leave this data element blank.
1.12c. CAA Title V:
If your facility has a Title V operating permit, check this box.
1.12d. Air operating permit ID:
If your facility has an air operating permit ID, provide the ID number.
1.13 OSHA star or merit ranking (optional):
Check this box if your facility has received a star or merit ranking under OSHA's Voluntary
Protection Program. Your facility is exempt from audits conducted pursuant to Section
68.220(b)(2)and(7).
1.14 Last safety inspection (by an external agency) date:
Provide the date of the facility's last safety inspection by an external agency.
1.15 Last safety inspection performed by an external agency:
Select the agency (or agencies) that performed the inspection from the drop down list. Choose
from the following:
• EPA
• Fire department
• Never had one
• OSHA
• State environmental agency
• State occupational safety organization
Specify if Other selected:
Provide the external agency if not present in element 1.15. If the last safety inspection
was a joint inspection, enter multiple agencies. If the agency does not appear in the
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
drop down list in element 1.15, select the Other option and provide the name of the
agency.
1.16 Will this RMP involve Predictive Filing?
Predictive Filing is an RMP filing option that allows your facility to submit an RMP which
includes regulated substances which may not actually be present at the facility at the time the
RMP is submitted. This option is intended to assist facilities (such as chemical warehouses,
chemical distributors, batch processors, and the like) whose operations involve highly variable
types and quantities of regulated substances, but who are able to forecast their inventory with
some degree of accuracy. Under 40 CFR Section 68.190, a facility is required to update and
resubmit its RMP no later than the date on which a new regulated substance is first present in a
covered process above a threshold quantity. By using Predictive Filing, you will not be required
to update and resubmit your RMP when you receive a new regulated substance if that
substance was included in your latest RMP submission (as long as you receive it in a quantity
that does not trigger a revised offsite consequence analysis as provided in 40 CFR Section
68.36).
If you use Predictive Filing, you should implement your Risk Management Program and prepare
your RMP in exactly the same way as if all of the substances included in the RMP were actually
present. This means that you must meet all rule requirements for each regulated substance for
which you file, whether or not that substance is actually present onsite at the time you submit
your RMP. Depending on the substances for which you file, this may require you to perform
additional worst-case and alternative-case scenarios and to implement additional prevention
program elements.
NOTE: If your facility uses this option, you must still update and resubmit your RMP if
you receive a new regulated substance which was not included in your latest RMP. Your
facility must also continue to comply with the other update requirements stated in 40
CFR 68.190.
If your facility uses Predictive Filing, the RMP database for your facility will indicate that your
facility has filed a predictive RMP. This will indicate that some of the chemicals in your RMP
may not actually be present onsite, but will not indicate which specific chemicals are onsite at
any given time. Therefore, you may receive more frequent questions from the public, local
officials, or implementing agencies about your actual chemical inventory. EPA encourages you
to engage in more frequent dialogue with these parties, and in particular with local emergency
planners, emergency responders, and community officials to update them on your current
inventory of regulated substances. Check this box if your RMP involves Predictive Filing.
be an
1.17 Processes
The following information includes a description of all elements in Section 1.17 Registration:
Processes.
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NOTE: Information on Processes will be entered on the Add Process page. Click the "Add
Process" button under "Section 1. Registration" on the RMP*eSubmit Section Selection
page. WARNING! If you delete a chemical or an entire process record in Section 1,
processes, all chemical records linked to the deleted chemical or deleted process in
sections 2, 3, 4, 5, 7 and 8 will also be deleted. Program level options cannot be selected
or edited in an RMP Correction.
Process ID: The process ID is a system generated number which has no bearing on your
submission.
Process description (optional):
This description helps you to track multiple processes as you fill out the remaining sections of
your RMP. Provide your process description in this element.
RMP'eSubmit Section 1. Processes
About COX
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terms SCo
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I EPA Facility ID: 100000002542
F«rme« Coop Association (Abilene )
| Piocess ID:
Proctsi Description
1 17 a Program 1ml •
1 17 B MAJCS Codes •
Are you claiming Confidential Business Information |CBI) In this Section?
1000030515
Anhydrous Ammonia
42291 OBSOLETE COPE Farm Supplws WholMslws [»]
1 17 c Chsmicsls (regulated s«6stanc«9)
Ammonia (anhydrous) (766441-7) (T) |»|
An -' usnoles oittcal or manewor* information
* EH icon denotes a Held trial can =e clamed as Confiflential Business Information (CB11 CIK* Here for more mlcrmaScn on now to submit CBI daims
1.17a. Program level:
Enter or edit the program level that corresponds to each process. The rule imposes different
requirements on processes based on the potential for public impacts and the level of effort
needed to prevent accidents. EPA has set three levels of requirements that apply to covered
processes:
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
, r. . Program level 3
Program level 1 Program level 2 ,......,
(unless eligible for Program 1)
Process has experienced no accident Process is not eligible for Program 1 Process is subject to OSHA PSM, or
in past 5 years that resulted in or subject to Program 3. Process is in NAICS code 32211
significant off-site impacts, 32411/ 32511, 32518, 32518, 32519,
No public receptors in worst-case 325199, 325211, 325311, or 32532.
circle, and
Emergency response coordinated
with local responders.
WARNING! Changing the Program Level will delete other sections in the RMP that depend on
its value. For example, changing the Program Level from 2 to either 1 or 3 will delete the
Section 8 Program corresponding to the Program Level 2 Process, if one exists. Changing the
Program Level from 3 to either 1 or 2 will delete the Section 7 Program corresponding to the
Program Level 3 Process, if one exists.
If you can qualify a process for Program 1, it is in your best interests to do so, even if the
process is already subject to OSHA PSM. For Program 1 processes, the implementing agency will
inspect and enforce only on compliance with the minimal Program 1 requirements. If you assign
a process to Program 2 or 3 when it might qualify for Program 1, the implementing agency will
inspect or enforce for compliance with all the requirements of the higher program levels. If,
however, you are already in compliance with the prevention elements of Program 2 or Program
3, you may want to use the RMP to inform the community of your prevention efforts. The
KEY POINTS TO REMEMBER
In determining program levels for your process(es), keep in mind the following:
1. The program levels apply to individual processes and generally indicate the risk
management measures necessary to comply with this regulation for the process, not the
facility as a whole. The eligibility of one process for a program level does not influence
the eligibility of other covered processes for other program levels.
2. Any process can be eligible for Program 1, even if it is subject to OSHA PSM or is in one
of the NAICS (North American Industry Clarification System) codes subject to Program 3.
3. Program 2 is the default program level. There are no "standard criteria" for Program 2.
Any process that does not meet the eligibility criteria for either Programs 1 or 3 is
subject to the requirements for Program 2.
Refer to Chapter 2 of the General Guidance for Risk Management Programs for more
information on determining the Program levels of your processes. Once you determine the
program level, simply enter 1, 2, or 3 for this data element.
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1.17b. NAICS codes:
If you know your facility's NAICS code, enter your NAICS code. To add a NAICS code to your
process, click the "Add NAICS" button, which will take you to the Select NAICS to add screen. To
delete the existing NAICS code, click the "Delete NAICS" button.
1.17c. Chemicals (regulated substances):
Enter your chemical in this field. For each covered process, provide the names of all regulated
substances held above the threshold. Many regulated substances have synonyms. However,
you must enter the name of the regulated substance as it appears in Section 68.130. If you have
a NFPA-4 flammable mixture containing regulated flammables, you may list it as a "flammable
mixture." List all of the regulated substances contained in the mixture; however, only report
the quantity of the entire mixture, not the individual substances. RMP*eSubmit contains a pick
list of all regulated substances. For an RMP Correction, a chemical cannot be added; only the
Chemical Quantity (in pounds) can be updated.
Fanners Coop Association ( Abilene }
1 17 c.1 Chemical Name
1 17 c 2 CAS Number
Chemical Type
Chemical Threshold Quantity
" denotes critical or mandatory information
I A S3) icon denotes 3 Held mat can oe claimed as Confidential Business Information (CBl) dick Here lor more information on how to susrrol CBI claims
Chemical Update
1.17c.lChemical name:
The chemical name field cannot be edited.
1.17c.2CAS number:
The CAS number field cannot be edited.
Chemical type:
The chemical type field cannot be edited.
Chemical threshold quantity:
The chemical threshold quantity cannot be edited.
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1.17c.3Chemical quantity (Ibs):
For each chemical reported in 1.17 c.l, estimate the maximum quantity (in pounds) held in the
covered process at any one time during the calendar year to two significant digits. For example:
5,333 pounds should be reported as 5,300 pounds
128,000 pounds should be reported as 130,000 pounds
NAICS Code(s)
The North American Industry Classification System (NAICS) categorizes businesses by fitting
them into descriptive categories that correspond to five-digit or six-digit codes. NAICS codes
replaced SIC codes in 1997. For this data element you should provide the NAICS code that most
closely corresponds to the process; it will not necessarily be the same NAICS code for your
facility as a whole. You may also enter additional NAICS codes if you wish to identify other
aspects of a process not captured by the NAICS codes for the primary activity.
You should determine the NAICS codes for your processes based on your activities on site using
the 2012 North American Industry Classification System Manual, which can be viewed at
http:www.census.gov/epcd/www/naics.html.
Once you have selected the sector that most appropriately reflects the sector for your facility
(Step 1), you must select the subsector, which enables you to select a more specific sector
within your industry (Step 2). Next, you must select the industry group that represents your
facility (Step 3). The last option is to select the NAICS code that reflects your facility (Final Step).
1. The Step 1 - Select Sector drop down list enables you to add the sector of the NAICS
code to Section 1. Processes.
2. The Step 2 - Select Subsector drop down list enables you to add the subsector of the
NAICS code to Section 1. Processes.
3. The Step 3 - Select Industry Group drop down list enables you to add the industry
group of the NAICS code to Section 1. Processes.
4. The Final Step - Select NAICS code drop down list enables you to select your NAICS
code to Section 1. Processes.
Process ID:
The process ID is automatically generated by the RMP*eSubmit system and this information
can't be edited.
Process name:
The process name can't be edited in this section. The process name can be edited in the Section
1. Processes screen.
Program level:
The program level can't be edited in this screen. The program level is set when you add or edit a
process.
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| 1.18. RMP Preparer Information:
If an outside contractor prepared this risk management plan please enter information concerning this contractor in the fields below
If you enter an outside contractor name in 1 18 a then you must complete 1 18 b through 1.18.f.
1 18 a Name
1 18 b Telephone *
1 18 c Street 1 "
1 18 d Street2
1 18 e City "
1 18 f State '
1 18 g Zip '
1 18 g If foreign country address Country *
1 13 f State/Province *
1 13 h Zip/Postal Code.
^
v
Discard Changes
Save arxj Return
An * denotes critical or mandatory information.
| A tO icon denotes a field that can be claimed as Confidential Business Information (CBI:. Click Here for more information on how to submit CBI claims.
1.18 RMP Preparer Information
1.18a. Name:
Provide the name of the person who prepared the Risk Management Plan for the facility. If you
provide the name of the Preparer, you must provide the remaining contact information in fields
1.18 b-g.
1.18b. Telephone:
Provide the telephone number of the person who prepared the Risk Management Plan for the
facility.
1.18c. Street 1:
Provide the street address of the person who prepared the Risk Management Plan for the
facility.
1.18d. Street 2:
Provide any additional street address information for the person who prepared the Risk
Management Plan for the facility.
1.18e. City:
Provide the city of the person who prepared the Risk Management Plan for the facility.
1.18f. State:
Select the state of the person who prepared the Risk Management Plan for the facility from the
drop down list.
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1.18g. ZIP code:
Provide the ZIP code of the person who prepared the Risk Management Plan for the facility.
l.lSg.lf Foreign country address: Country:
If the RMP Preparer is located in a foreign country, select the appropriate country from the
drop down list.
1.18f. State/Province:
If the RMP Preparer is located in a foreign country, provide the appropriate country
state/province.
1.18h. ZIP/Postal code:
If the RMP Preparer is located in a foreign country, provide the appropriate country ZIP/postal
code.
Section 2. Toxics: Worst-Case
Worst-case release scenario analysis of covered processes as follows:
Report one worst-case release scenario for each Program 1 process. Program 1 processes must
have no public receptors within the distance to the endpoint in the worst-case analysis.
If your facility has Program 2 or Program 3 processes, report one worst-case release scenario to
represent all Program 2 and Program 3 processes having toxic regulated substances present
above the threshold quantity, and one worst-case release scenario to represent all Program 2
and Program 3 processes having flammable regulated substances present above the threshold
quantity. If you have more than one Program 2 or 3 process, you will report the worst-case
release scenario for the Program 2 or 3 process that would have the greatest potential impact
on the public (i.e., the greatest distance to endpoint). You may also need to submit an
additional worst-case scenario for either hazard class (i.e., toxic or flammable), if a worst-case
release from elsewhere at your facility would potentially affect a different set of public
receptors than those affected by your initial worst-case scenario(s).
You may include one graphic (map or diagram) in electronic format for each release scenario
that you report, but it is not required.
Complete this section for each toxics worst-case scenario you report.
The following is a discussion of each element in Section 2. Toxics: Worst Case.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
U.S. Environmental Protection Agency
RMP*eSubmit Section Selection
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Introduction to RMP*eSubmit
Section 1. Registration
Section 2. Toxics: Worst Case
Transaction Type: First
Time Submission
Section 3. Toxics: Alternative Release
Select the "Add Scenario" button under Section 2.Toxics: Worst Case
NOTE: Please remember to periodically use the "Save and Return" button at the bottom
of the page. As a security measure, if you remain inactive in the system for 19 minutes,
the system will log you out at the 20th minute and your entered data will not be saved!
Each time you save, the system will return you to the RMP*eSubmit Section Selection
page. Click the "Enter Registration Information" button to enter more data.
NOTE: If you do not wish to keep the information you've entered, click the "Discard
Changes" button.
U.S. Environmental Protection Agency
RMP'eSubmit Section 2. Add Scenario
Logged in as. GEFION13
I EPA Facility ID:
1100000215689
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Transaction Type: First
Time Submission
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Select a Chemical from the following list
1000030J14
Continue Add Scenario
I An "*" denotes critical or mandatory1 information.
I A ISiil icon denotes a field that can be claimed as Confidential Business Information iCBI;. Click Here tor more information on how to submit CBI claims.
Select the "Continue Add Scenario" button.
43
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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» • Recent ^.nncuncem&nts Contact Us
-ogjeSinas. GEFION13
EPA Facility ID:
100000215689
Transaction Type: First
Time Submission
Are you claiming Confidential Business Information (CBI) in this Section? LJ
2.1. Chemical
Process Name
2 1 a Chemical Name
2 1 b Percent weight of chemical
2.2. Physical state:
2.3. Model Used:"
2 3.a EPAs OCA. Guidance Reference Tables or Equations
2 3 b EPAs RMP Guidance for Ammonia Refrigeration Reference Tables or Equations
O
O
2 3 c EPAs RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations O
23d EPA's RMP Guidance for Warehouses Reference Tables or Equations O
2 3 e EPAs RMP Guidance for Chemical Distributors Reference Tables or Equations O
2 3 f EPAs RMP'CompCTM) O
2 3 g Areal Locations of Hazardous Atmospheres [ALOHA(R)] O
If your facility is claiming Confidential Business Information (CBI) in this section, check the box.
If claiming CBI and you've checked the box, a pop-up message will appear describing the step
that must be taken by the Preparer.
2.1 Chemical
a. Process name:
This field contains the process description from which the chemical was entered in Processes
1.17. This field is disabled and cannot be edited as it reflects information entered in Section 1.
Processes.
b. Chemical name:
This field contains the regulated toxic chemical you evaluated in the worst-case scenario
previously entered in Processes 1.17. This field is disabled and cannot be edited as it reflects
information entered in Section 1.17 Processes.
c. Percentage weight of chemical:
If your worst-case scenario involves the release of a mixture containing a regulated substance,
enter the percentage weight of the regulated substance in the mixture. (Leave blank if it is not a
mixture.)
2.2 Physical state:
Select the physical state of the chemical as it is released in the scenario from the drop down
list.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
• Gas (Select if the chemical is a gas)
• Liquid (Select if the chemical is a liquid)
• Gas liquified by pressure
• Gas liquified by refrigeration
| 2.3. Model Used:'
23a EPAs OCA Guidance Reference Tables or Equations O
2 3 b EPAs RMP Guidance for Ammonia Refrigeration Reference Tables or Equations O
2 3 c EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations O
23d EPAs RMP Guidance for Warehouses Reference Tables or Equations O
2 3 e EPAs RMP Guidance for Chemical Distributors Reference Tables or Equations O
23f EPAs RMP'CompiTM; O
2 3 g Areal Locations of Hazardous Atmospheres [ALOHA(R)] O
2 3 h Other model name (Specify) ©
Model Used Text (if Other): I
2.4. Scenario: * '
2.5. Quantity released (Ibs): *
'" "'
2.6. Release rate (Ibs/minute): *
-1
2.7. Release duration (minutes): *
2.8. Wind speed (meters/second): *
2.9. Atmospheric stability class: *
2.10. Topography: *
2.11. Distance to endpoint (miles): *
Launch EPA's RMP'Comp
2.3 Model used (select one):
Select one of the options for the source of your results for your worst-case release. If you select
the Other model name (specify) option, you must specify the other model name in the Model
Used Text (if Other) field. The options are listed below:
a. EPA's OCA Guidance Reference Tables or Equations
b. EPA's RMP Guidance for Ammonia Refrigeration Reference Tables or Equations (now in
General Risk Management Program Guidance )
c. EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
(now in General Risk Management Program Guidance )
d. EPA's RMP Guidance for Warehouses Reference Tables or Equations
e. EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
f. EPA's RMP*Comp™
g. Areal Locations of Hazardous Atmospheres (ALOHA ®) (for Toxics only)
h. Other model name (specify)
2.4 Scenario:
Select one of the following that describes your worst-case release scenario from the drop down
list:
• Gas Release: A gas release of the substance in a vapor state. If you hold a gas liquified
under refrigeration, report the release as a liquid.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
• Liquid Spill and Vaporization: A release of the substance in a liquid state with
subsequent vaporization.
2.5 Quantity released (Ibs):
Enter the quantity of toxic chemical you used for your worst-case scenario analysis in pounds in
whole numbers. If you have less than one pound released, round up to one pound. You may
want to clarify this in your Executive Summary.
2.6 Release rate (Ibs/minute):
Enter the rate of release to the outside air in pounds per minute in whole numbers. For
example:
4.3 pounds should be reported as... 4 pounds
19 pounds should be reported as... 20 pounds
See the General Risk Management Program Guidance for more information.
2.7 Release duration (minutes):
Enter the length of time in minutes for the entire quantity from the vessel, pipeline, or other
source to be released to the outside air.
For gases, a gas liquified by pressurization alone, or a gas liquified by refrigeration where the
released refrigerated liquid forms a pool of 1 cm or less in depth, you should assume that the
release duration is 10 minutes.
For a liquid or a gas liquified by refrigeration where the released refrigerated liquid forms a
pool deeper than 1 cm, the release duration should be the time required for a pool formed by
the released substance to completely vaporize.
Although in some cases it may take longer than 60 minutes for the pool to completely volatilize,
most dispersion models use the release rate and calculate the maximum downwind dispersion
distance within 60 minutes. Therefore, you may enter 60 minutes for your duration, even if the
duration from your modeling is longer than 60 minutes. You can also enter the exact duration
from your modeling up to 9999.9 minutes.
2.8 Wind speed (meters/second):
If you used the OCA guidance or one of EPA's model program guidance documents, enter or
edit 1.5 meters per second. If you modeled your scenario separately, enter or edit the wind
speed used.
2.9 Atmospheric stability class:
If you used EPA's OCA Guidance Reference Tables or Equations or one of EPA's model program
guidance documents, list select Fstability from the drop down list. If you modeled your
scenario separately, select the appropriate stability class used from the drop down list.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
2.10 Topography:
Select whether the local topography is urban or rural from the drop down list. Urban means
that there are many obstacles in the immediate area; obstacles include buildings or trees. Rural
means that the terrain is generally flat and unobstructed in the immediate area.
2.11 Distance to endpoint (miles):
Enter the distance to the endpoint in miles to 2 significant digits, using the endpoint specified
for the chemical in 40 CFR Part 68, Appendix A. Convert your modeling results into miles by
dividing the distance in feet by 5280 or yards by 1760. Refer to the following to determine 2
significant digits:
0.397 miles should be reported as 0.40 miles
9.345 miles should be reported as 9.3 miles
20.764 miles should be reported as 21.0 miles
2.12 Residential population within distance to endpoint:
Enter the estimated population within the circle with a center at the point of the release and a
radius determined by the distance to the endpoint to two significant digits (e.g., 5,500 people
rather than 5,483). Population estimates include only residential populations.
2.13. Public receptors within distance to endpoint
2 13 a Schools D
2 13 b Residences D
2 13 c Hospitals D
2.13.d. Prison/Correctional facilities D
2 13 e Recreational areas D
2.13.f. Major commercial, office or industrial areas D
2 13 g Other L
2.14. Environmental receptors within distance to endpoint
2 14 a National or State parks forests monuments D
2 14 b Officially designated wildlife sanctuaries preserves or refuges Q
2 14 c Federal wilderness area D
2 14 d OtherQ
2.13 Public receptors within distance to endpoint:
Select one or more of the public receptors within distance to endpoint by checking the box that
corresponds with the specified receptor in fields 2.13 a-g.
a. Schools: Public and private elementary, secondary, or post-secondary educational
institutions (e.g., colleges).
b. Residence: Public and private residences and dwellings wherever people live.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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c. Hospitals: Public and Private Hospitals. Places that provide emergency care and or long
term care of the sick or elderly.
d. Prisons/Correction facilities: Prisons where men or women are incarcerated. Holding
places or state of confinement for criminals.
e. Recreation areas: Recreation areas include stadiums, parks, and public pools.
f. Major commercial, office industrial areas: Commercial, office, or industrial areas
include industrial parks, office buildings, shopping malls, commercial areas, and
commercial farms.
g. Other: Include other types of public receptors.
2.14 Environmental receptors within distance to endpoint:
Select one or more of the environmental receptors within distance to endpoint by clicking the
check box that corresponds with the specified receptor in fields 2.14 a-d. These options are a
combination of national or state parks, forests, or monuments which are within a circle whose
center is the point of the release and the radius is determined by the distance to the endpoint.
Select all that apply.
a. National or state parks, forests, or monuments
b. Officially designated wildlife sanctuaries, preserves, refuges
c. Federal wilderness areas
d. Other (Specify). (Include other types of environmental receptors.)
| 2.15. Passive mitigation considered
2 15 a Dikes
2 15 b Enclosures
2 15 c Berms
2 15 d Drains
2 15 e Sumps
2 15f Other
n
n
D
n
n
2.16. Graphic file
Loadi'LJnloadFile
Discard Changes
Delete Scenario
None
Save and Return
I An ' denotes critical or mandatory information.
| A Hill icon denotes a field that can he claimed as Confidential Business Information (CBI;. Click Here for more information on how to submit CBI claims.
You are In an encrypted secure session.
2.15 Passive mitigation considered:
Select one or more of the passive mitigations considered within distance to endpoint by
checking the box that corresponds with the specified receptor in fields 2.15 a-f. This field is an
indication that officially designated wildlife sanctuaries, preserves, or refuges are within a circle
whose center is the point of the release and the radius is determined by the distance to the
endpoint.
a. Dikes: A dike is a low wall that acts as a barrier to prevent a spill from spreading.
48
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
b. Enclosures: An enclosure is a physical containment of the release within a structure
(e.g., a building).
c. Berms: A berm is a mound or wall of earth at the top or bottom of a slope that prevents
a spill from spreading.
d. Drains: A drain is a channel that carries off surface water.
e. Sumps: A sump is a pit or tank that catches liquid runoff for drainage or disposal.
f. Other: List other types of passive mitigation.
2.16 Graphics file:
You may load one graphic file to illustrate each release scenario by clicking the "Load/Unload
File" button. Entering a graphics file name in this field will not automatically cause that file to
be included in your RMP submission. Graphics will be accepted in either GIF or JPEG file
format. If you have a graphics file present in your RMP that you would like to remove, you can
also delete the graphic file using the "Load/Unload File" button.
You can select one of the three buttons at the bottom of the page: "Discard Changes", "Delete
Scenario", or "Save and Return".
Section 3. Toxics: Alternative Release
Alternative release scenario analysis of Program 2 and Program 3 processes as follows:
Present one alternative release scenario for each regulated toxic substance held above
the threshold quantity in a Program 2 or 3 processes, including the substance
considered in the worst-case analysis.
Present one alternative release scenario to represent al| flammable substances held
above the threshold quantity in a Program 2 or 3 processes.
Note that alternative release scenarios should be those that will reach an endpoint
offsite, unless no such scenario exists.
You may include one graphic (map or diagram) in electronic format for each release
scenario that you report, but it is not required.
Complete this section for each toxics alternative release scenario that you report.
Section 3. Toxics: Alternative Release
Section 4. Flammables: Worst Case
Section 5. Flammables: Alternative Release
Section 6. Five-Year Accident History
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Select the "Add Scenario" button under Section S.Toxics: Alternative Release
NOTE: Please remember to periodically use the "Save and Return" button at the bottom
of the page. As a security measure, if you remain inactive in the system for 19 minutes,
the system will log you out at the 20th minute and your entered data will not be saved!
Each time you save, the system will return you to the RMP*eSubmit Section Selection
page. Click the "Enter Registration Information" button to enter more data.
NOTE: If you do not wish to keep the information you've entered, click the "Discard
Changes" button.
The following is a discussion of each element in Section 3. Toxics: Alternative Release.
Logos:! mas. GEFION13
Transaction Type: First
Time Submission
Are you claiming Confidential Business Information (CBI) in this Section? D
3.1. Chemical
Process Name
31 a Chemical Name
3 1 b Percent weight of chemica
3.2. Physical state:
3.3. Model Used: *
3 3 a EPA's OCA Guidance Reference Tables or Equations
3 3 b. EPAs RMP Guidance for Ammonia Refrigeration Reference Tables or Equations
3 3 c EPAs RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations O
33d EPAs RMP Guidance for Warehouses Reference Tables or Equations O
3 3 e EPAs RMP Guidance for Chemical Distributers Reference Tables or Equations O
3 3 f EPAs RMP'CompfTM) O
3.3.g. Areal Locations of Hazardous Atmospheres [ALOHAiRI] O
3.1 Chemical
a. Process name:
This field contains the process description, from which the chemical was entered in Section 1.
Processes. This field is disabled and cannot be edited as it reflects information entered in
Section 1. Processes.
b. Chemical name:
This field contains the regulated toxic chemical that you evaluated in the alternative scenario.
This is the name of the chemical that you selected in 1.17.
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
c. Percent weight of chemical (if in a mixture):
If your alternative scenario involves the release of a mixture containing a regulated substance,
enter the percentage weight of the regulated substance in the mixture. (Leave blank if it is not a
mixture.)
3.2 Physical state:
Select the physical state of the chemical as it is released in the scenario from the drop down
list.
• Gas (Select if the chemical is a gas)
• Liquid (Select if the chemical is a liquid)
• Gas liquified by pressure
• Gas liquified by refrigeration
3.3 Model used:
Select one of the options for the source of your results for your alternative release. If the other
model name option is selected, you must specify the other model name in the Model Used Text
(if Other) field. The options are list below:
a. EPA's OCA Guidance Reference Tables or Equations
b. EPA's RMP Guidance for Ammonia Refrigeration Reference Tables or Equations (toxics
only) (now in General Risk Management Program Guidance)
c. EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
(now in General Risk Management Program Guidance )
d. EPA's RMP Guidance for Warehouses Reference Tables or Equations
e. EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
f. EPA's RMP*Comp™
g. EPA's Areal Locations of Hazardous Atmospheres (ALOHA®)
h. Other model name (specify)
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I 3.4. Scenario: '
Scenario Text tif Other selected;
| 3.5. Quantity released (Ibs): * ™
rrn
I 3.6. Release rate (Ibs/minute): * L
fsnn
3.7. Release duration (minutes): *
3.8. Wind speed (meters/second): *
3.3. Atmospheric stability class: *
3.10. Topography: *
3.11. Distance to endpoint (miles): *
3.12. Estimated residential population within distance to endpoint (numbers): *
3.13. Public receptors within distance to endpoint
3 13 a Schools
3 13 b Residences
3 13 c Hospitals
3 13 d PrisoivCorrectional facilities
3 13 e Recreational areas
3 13 f Major commercial office or industrial areas
3 13 g Other _
Other
Launch EPA's RHP'Comp
D
D
n
n
n
n
3.4 Scenario:
Select one of the following that describes your alternative release scenario from the drop down
list or enter another "Scenario Text":
• Transfer Hose Failure: Failure of the connection between two or more vessels. Liquid.
• Pipe Leak: Release through a rupture in a pipe
• Vessel Leak: Release through a rupture in a vessel
• Overfilling: Release due to filling a pipe, vessel, or other container past its capacity
• Rupture Disk/Relief Valve: Release due to failure of a rupture disk/relief valve to
function properly. A rupture disk/relief valve is a valve that relieves pressure beyond a
specified limit; a relief valve recloses upon return to normal operating conditions
• Excess Flow Valve Failure: Release caused by the failure of excess flow device to
function properly and prevent surges from reaching downstream equipment
• Other (specify): Specify your scenario if not described in the drop-down menu
3.5 Quantity released (Ibs):
Enter the quantity of toxic chemical that you used for your alternative scenario analysis in
pounds in whole numbers. If you have less than one pound released, round up to one pound.
You may want to clarify this in your Executive Summary.
3.6 Release rate (Ibs/minute):
Enter the rate of release to the outside air in pounds per minute in whole numbers. For
example:
4.3 pounds should be reported as... 4 pounds
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
19 pounds should be reported as... 20 pounds
See the General Risk Management Program Guidance for more information.
3.7 Release duration (minutes):
Enter the length of time in minutes (0.1 to 9999.9) for the release to the outside air of the
quantity that you chose for the alternative scenario.
For gases, a gas liquified by pressurization alone, or a gas liquified by refrigeration where the
released refrigerated liquid forms a pool of 1 cm or less in depth, you should assume that the
release duration is 10 minutes.
For a liquid or a gas liquified by refrigeration where the released refrigerated liquid forms a
pool deeper than 1 cm, the release duration should be the time required for a pool formed by
the released substance to completely vaporize.
Although in some cases it may take longer than 60 minutes for the pool to completely volatilize,
some dispersion models use the release rate and calculate the maximum downwind dispersion
distance within 60 minutes. Therefore, you may enter 60 minutes for your duration, even if the
duration from your modeling is longer than 60 minutes. You can also enter the exact duration
from your modeling up to 9999.9 minutes.
See General Risk Management Program Guidance for more information.
3.8 Wind speed (meters/second):
If you used the OCA guidance or one of EPA's model program guidance documents, indicate 3
meters per second. If you modeled your scenario separately, provide the wind speed used.
3.9 Atmospheric stability class:
If you used the OCA Guidance or one of EPA's model program guidance documents, list D
stability. If you modeled your scenario separately, enter the stability class used.
3.10 Topography (select one):
Select whether the local topography is urban or rural from the drop down list. Urban means
that there are many obstacles in the immediate area; obstacles include buildings or trees. Rural
means that the terrain is generally flat and unobstructed in the immediate area.
3.11 Distance to endpoint (miles):
Enter the distance to the endpoint in miles to 2 significant digits, using the endpoint specified
for the chemical in 40 CFR part 68, Appendix A. Convert your modeling results into miles by
dividing the distance in feet by 5280 or yards by 1760. Refer to the following to determine 2
significant digits:
0.397 miles should be reported as 0.40 miles
9.345 miles should be reported as 9.3 miles
53
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
20.764 miles should be reported as 21.0 miles
3.12 Estimated residential population within distance to endpoint (numbers):
Enter the population within the circle with a center at the point of the release and a radius
determined by the distance to the endpoint to two significant digits (e.g., 5,500 people rather
than 5,483). Population estimates include only residential populations.
3.13 Public receptors within distance to endpoint:
Select one or more of the public receptors. Public receptors must be identified within the circle
with a center at the point of the release and a radius determined by the distance to the
endpoint. Public receptor means locations where members of the public may be exposed to
toxic concentrations, radiant heat, or overpressure as a result of the release. Public receptors
include locations within the facility's property boundary to which the public has routine and
unrestricted access during or outside business hours (e.g., a recreation field). Locations
inhabited or occupied by the public at any time without restriction by the source (such as
fences or security guards) are public receptors (see the General Guidance for Risk Management
Programs for more information on identifying public receptors). You do not need to list specific
locations or estimate populations at these locations. The presence of these receptors may be
determined using local street maps. Select all that apply in fields 3.13 a-g.
a. Schools: Public and private elementary, secondary, or post-secondary educational
institutions (e.g., colleges).
b. Residences: Public and private residences and dwellings wherever people live.
c. Hospitals: Public and Private Hospitals. Places that provide emergency care and or long
term care of the sick or elderly.
d. Prisons/Correction facilities: Prisons where men or women are incarcerated. Holding
places or state of confinement for criminals.
e. Recreation areas: Recreation areas include stadiums, parks, and public pools.
f. Major commercial, office industrial areas: Commercial, office, or industrial areas
include industrial parks, office buildings, shopping malls, commercial areas, and
commercial farms.
g. Other: Include any other additional information here.
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3.14. Environmental receptors within distance to endpoint
3.14.a. National or State parks forests, monuments
3.14.D. Officially designated wildlife sanctuaries preserves or refuges
3.14.C. Federal wilderness area
n
n
D
3 14 d Other
3.15. Passive mitigation considered
3 15 a Dikes
3 15 b Enclosures
3 15 c Berms
3.15.d. Drains
3.15.6. Sumps
3 15f OtherF
n
n
n
n
n
3.14 Environmental receptors within distance to endpoint:
Select one or more environmental receptors. Environmental receptors must be identified
within the circle with a center at the point of the release and a radius determined by the
distance to the endpoint by clicking the check box in field 3.14 a-d. Environmental receptor
means natural areas, such as national or state parks, forests, or monuments; officially
designated wildlife sanctuaries, preserves, refuges, or areas; and federal wilderness areas that
could be exposed at any time to toxic concentrations, radiant heat, or overpressure as a result
of the release. Environmental receptors can be identified on local U.S. Geological Survey maps,
which can be found at many libraries and online via the USGS Maps, Imagery, and Publications
Website. Select all that apply:
a. National or state parks, forests, or monuments
b. Officially designated wildlife sanctuaries, preserves, refuges, or areas
c. Federal wilderness areas
d. Other (Specify) (Include any other additional information.)
3.15 Passive mitigation considered:
Mitigation means specific activities, technologies, or equipment designed or deployed to
capture or control substances that have been released to minimize exposure of the public or
the environment. Passive mitigation means equipment, devices, or technologies that function
without human, mechanical, or other energy input. Select all that were considered in defining
the release quantity or rate to the worst-case scenario or alternative release scenario.
a. Dike: A dike is a low wall that acts as a barrier to prevent a spill from spreading.
b. Enclosures: An enclosure is a physical containment of the release within a structure
[e.g., a building].
c. Berm: A berm is a mound or wall of earth at the top or bottom of a slope that prevents
a spill from spreading.
d. Drain: A drain is a channel that carries off surface water.
e. Sump: A sump is a pit or tank that catches liquid runoff for drainage or disposal.
f. Other: (specify)
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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3.16. Active mitigation considered
3-16.a. Sprinkler systems
3 16.b. Deluge systems
3 16 c Water curtain
3 1G d Neutralization
3 15 e Excess flow valve
3 16 f Flares
3 16 g Scrubbers
3 1G h Emergency shutdown systems
3 1G i Other
D
LJ
D
D
D
D
D
D
3.17. Graphic file
None
Discard Changes
denotes critical or mandatory information.
icon denotes a field that can be claimed as Confidential Business Information (CBI). Click Here for more information on howto submit CBI claims
3.16 Active mitigation considered:
Active mitigation means equipment, devices, or technologies that need human, mechanical, or
other energy input to function. Select all that were considered in defining the release quantity
or rate of the alternative release scenario.
a. Sprinkler Systems: A system for protecting a building against fire by means of overhead
pipes which convey an extinguishing fluid through heat activated outlets.
b. Deluge Systems: A system to overflow an area of a release with water or other
extinguishing fluid.
c. Water Curtain: A spray of water from a horizontal pipe through nozzles: the curtain may
be activated manually or automatically.
d. Neutralization: A means of making a toxic chemical harmless through chemical reaction.
e. Excess Flow Valve: A device in the outlet of a vessel at a hose connection that stops the
flow or liquid or gas if the piping or hoses downstream fail and a predetermined excess
flow rate is reached.
f. Flares: A device for disposing of combustible gases from a chemical process by burning
them in the open.
g. Scrubbers: A pre-release protection measure that uses water or aqueous mixtures
containing scrubbing reagents to remove discharging liquids and possibly also treating
the discharging chemical.
h. Emergency shutdown systems: Controls that are triggered when process limits are
exceeded and that shutdown process.
i. Other (specify): Enter a type of passive mitigation considered other than what is listed
above.
3.17 Graphics file:
You may load one graphic file to illustrate each release scenario by clicking on the
"Load/Unload File" button. Entering a graphics file name in this field will not automatically
cause that file to be included in your RMP submission. Graphics will be accepted in either GIF or
56
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MARCH 2014
JPEG file format. If you have a graphics file present in your RMP that you would like to remove,
you can also unload the graphic file using the "Load/Unload File" button.
Section 4. Flammables: Worst Case
Report one worst-case release scenario for each Program 1 process. Program 1 processes must
have no public receptors within the distance to the endpoint in the worst-case analysis.
If your facility has Program 2 or Program 3 processes, report one worst-case release scenario to
represent all Program 2 and Program 3 processes having toxic regulated substances present
above the threshold quantity, and one worst-case release scenario to represent all Program 2
and Program 3 processes having flammable regulated substances present above the threshold
quantity. If you have more than one Program 2 or 3 process, you will report the worst-case
release scenario for the Program 2 or 3 process that would have the greatest potential impact
on the public (i.e., the greatest distance to endpoint). You may also need to submit an
additional worst-case scenario for either hazard class (i.e., toxic or flammable), if a worst-case
release from elsewhere at your facility would potentially affect a different set of public
receptors than those affected by your initial worst-case scenario(s).
Complete this section for each flammable worst-case scenario you report.
The following is a discussion of each element in Section 4. Flammables: Worst Case.
Section 4. Flammables: Worst Case
Section 5. Flammables: Alternative Release
Add Scenario
Section 6. Five-Year Accident History
Section 7. Prevention Program: Program Level 3
Add Program
Select the "Add Scenario" button under Section 4.Flammables: Worst Case
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U.S. Environmental Protection Agency
Logged in as, GEFION12
EPA Facility ID:
100000215689
Transaction Type: First
Time Submission
Mo flammable chemicals exist in Section 1 17 Processes that can be reported in this section
To add a flammable chemical to be reported in this section please enter the chemical information in Section 1 17 first
NOTE: Chemicals can not be added in Section 1 17 in Correction mode
I An "*' denotes critical or mandatory information.
I A BID icon denotes a field that can be claimed as Confidential Business Information (CBI;. Click Here for more information on how to submit CBI claims.
NOTE: Please remember to periodically use the "Save and Return" button at the bottom
of the page. As a security measure, if you remain inactive in the system for 19 minutes,
the system will log you out at the 20th minute and your entered data will not be saved!
Each time you save, the system will return you to the RMP*eSubmit Section Selection
page. Click the "Enter Registration Information" button to enter more data.
NOTE: If you do not wish to keep the information you've entered, click the "Discard
Changes" button.
EPA Facility ID: 100000215689
Transaction Type: Resubmission
Are you claiming Confidential Business Information (CBI) in this Section?
4.1. Chemical
Process Name
4.1.3. Chemical Name:
4.2. Model Used: *
4 2.a EPA's OCA Guidance Reference Tables or Equations
4.2 b. EPA's RMP Guidance for Propane Storage Facilities Reference Tables or Equations
4.2.C EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
4.2.d. EPA's RMP Guidance for Warehouses Reference Tables or Equations
4.2 e EPA's RMP Guidance for Chemical Distnbutors Reference Tables or Equations
4.2.f. EPA's RMP"Comp(TM)
4.2.g. Other model name (Specify)
Model Used Text (if Othe
4.3. Scenario: *
4.4. Quantity released (Ibs):
4.5. End Point Used: '
I 4.6. Distance to endpoint (miles): '
I 4.7. Estimated residential population within distance to endpoint (numbers): *
nch EPA's RMP'Comi
D
4.1 Chemical
a. Process name:
The process description from which the chemical was entered in Processes 1.17. This field is
disabled and cannot be edited as it reflects information entered in Section 1. Processes.
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b. Chemical name:
The regulated flammable chemical you evaluated in the worst-case scenario.
4.2 Model used (select one):
Select one of the options for the source of your results for your worst-case release:
a. EPA's OCA Guidance Reference Tables or Equations
b. EPA's RMP Guidance for Propane Storage Facilities Reference Tables or Equations
(Flammable only)
c. EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
(now in General Risk Management Program Guidance)
d. EPA's RMP Guidance for Warehouses Reference Tables or Equations
e. EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
f. EPA's RMP* Comp™
g. Other model name (specify)
4.3 Scenario:
This data element is fixed. By regulation, for flammables, the worst case assumes an
instantaneous release and a vapor cloud explosion, which is an explosion of a cloud containing
a flammable vapor or gas and air.
4.4 Quantity released (Ibs):
Enter the quantity of the flammable substance you used for your worst case scenario analysis in
pounds to two significant digits. If you have less than one pound released, round up to one
pound. You may want to clarify this in your Executive Summary.
4.5 Endpoint used:
This data element is fixed. Because the scenario is fixed by regulation as vapor cloud explosions,
the endpoint which applies to vapor cloud explosions is fixed at 1 psi overpressure.
4.6 Distance to endpoint (miles):
Enter the distance to the endpoint in miles to two significant digits, using the endpoint specified
for the chemical in 40 CFR part 68, Appendix A. Convert your modeling results into miles by
dividing the distance in feet by 5280 or yards by 1760. Refer to the following to determine two
significant digits:
0.397 miles should be reported as 0.40 miles
9.345 miles should be reported as 9.3 miles
20.764 miles should be reported as 21.0 miles
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4.7 Residential population within distance to endpoint:
Estimate the population within the circle with a center at the point of the release and a
determined by the distance to the endpoint to two significant digits (e.g., 5,500 people
than 5,483). Population estimates include only residential populations.
| 4.8. Public receptors within distance to endpoint
4.8.a. Schools
4.8.b. Residences
4.8.C. Hospitals
4-8-d- Prison/Correctional facilities
4-8-8- Recreational areas
4.8.f. Major commercial, office or industrial areas
4.8.g. Other
radius
rather
D
4.9. Environmental receptors within distance to endpoint
4-9-3- National or State parks, forests, monuments
4.9-b. Officially designated wildlife sanctuaries, preserves or refuges
4.9.C. Federal wilderness area
4.9.d. Other
| 4.10. Passive mitigation considered
4.10.a. Blast Walls
D
4.10.b. Other
I 4.11. Graphic file
Loadi'Unload File
None
4.8 Public receptors within distance to endpoint:
Public receptors must be identified within the circle with a center at the point of the release
and a radius determined by the distance to the endpoint. Public receptor means locations
where members of the public may be exposed to toxic concentrations, radiant heat, or
overpressure as a result of the release. Public receptors include locations within the facility's
property boundary to which the public has routine and unrestricted access during or outside
business hours (e.g., a recreation field). Locations inhabited or occupied by the public at any
time without restriction by the source (such as fences or security guards) are public receptors
(see the General Risk Management Program Guidance for more information on identifying
public receptors). You do not need to list specific locations or estimate populations at these
locations. The presence of these receptors may be determined using local street maps.
Select all that apply.
a. Schools: Public and private elementary, secondary, or post-secondary educational
institutions (e.g., colleges).
b. Residences: Public and private residences and dwellings wherever people live.
c. Hospitals: Public and private hospitals. Places that provide emergency care and or long
term care for the sick and elderly.
d. Prisons/Correctional facilities: Prisons where men or women are incarcerated. Holding
places or state of confinement for criminals.
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e. Recreation areas: Recreation areas include stadiums, parks, and public pools.
f. Major commercial, office, or industrial areas: Commercial, office, or industrial areas
include industrial parks, office buildings, shopping malls, commercial areas, and
commercial farms.
g. Other: Include any other additional information here.
4.9 Environmental receptors within distance to endpoint:
Environmental receptors must be identified within the circle with a center at the point of the
release and a radius determined by the distance to the endpoint. Environmental receptors
means areas, such as national or state parks, forests, or monuments; officially designated
wildlife sanctuaries, preserves, refuges, or areas; and federal wilderness areas that could be
exposed at anytime to toxic concentrations, radiant heat, or overpressure as a result of the
release. Environmental receptors can be identified on local U.S. Geological Survey maps, which
can be found at many libraries and online via the USGS Website. Select all that apply.
a. National or state parks, forests, or monuments
b. Officially designated wildlife sanctuaries, preserves, or refuges
c. Federal wilderness areas
d. Other (specify) (Include any other additional information here)
4.10 Passive mitigation considered:
Mitigation means specific activities, technologies, or equipment designed or deployed to
capture or control substances that have been released to minimize exposure of the public or
the environment. Passive mitigation means equipment, devices, or technologies that function
without human, mechanical, or other energy input. Select all that were considered in defining
the release quantity or rate to the worst-case scenario or alternative release scenario. If the
selection for field 4.10.a. does not apply, use the text field in 4.10.b. to enter the passive
mitigation considered in your scenario.
a. Blast Wall: A heavy wall used to isolate buildings or areas that contain highly
combustible or explosive materials
b. Other (specify)
4.11 Graphics file n am e:
You may load one graphic file to illustrate each release scenario by clicking on the
"Load/Unload File" button. Entering a graphics file name in this field will not automatically
cause that file to be included in your RMP submission. Graphics will be accepted in either GIF or
JPEG file format. If you have a graphics file present in your RMP that you would like to remove,
you can also unload the graphic file using the "Load/Unload File" button.
Section 5. Flammables: Alternative Release
Complete this section for each flammable alternative release scenario you report. If a
flammable substance is used in multiple processes, only one scenario is required. You will only
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be able to add or update a scenario if you have entered a flammable chemical in Section 1.
Processes section.
Complete this section for each flammable alternative release scenario you report.
The following is a discussion of each element in Section 5. Flammables: Alternative Release.
Section 5. Flammables: Alternative Release
Section 6. Five-Year Accident History
Select the "Add Scenario" button under Section 5.Flammables: Alternative Release
NOTE: Please remember to periodically use the "Save and Return" button at the bottom
of the page. As a security measure, if you remain inactive in the system for 19 minutes,
the system will log you out at the 20th minute and your entered data will not be saved!
Each time you save, the system will return you to the RMP*eSubmit Section Selection
page. Click the "Enter Registration Information" button to enter more data.
NOTE: If you do not wish to keep the information you've entered, click the "Discard
Changes" button.
--'.•• -!"-,. .:-:.-! -. :\ •:•-.-:--.: ==
EPA Facility 10:100000215689
Transaction Type: Resut
Are you claiming Confidential Business Information (CBI) in this Section?
5.1. Chemical
Process Name:
5.1.a. Chemical Name
5.2. Model Used: *
5 2.a. EPA's OCA Guidance Reference Tables or Equations
5.2 b. EPA's RMP Guidance for Propane Storage Facilities Reference Tables or Equations
5.2.c. EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
5.2.d. EPA's RMP Guidance for Warehouses Reference Tables or Equations
5.2.e. EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
5.2.f. EPA's RMP*Comp{TM)
5.2 g. Other model name (Specify)
Model Used Text (if Other);
Vapor Cloud Explosion "
5.3. Scenario:
Scenario Text (if Other selected]'
5.4. Quantity released (Ibs):
5.5. Endpoint used: *
5.6. Distance to endpoint (miles): *
LFL value: ' y
Launch EPA's RMP'Compfl1
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5.1 Chemical
a.
The process description from which the chemical was entered in Processes 1.17.
5.2 Model used:
Select the source of your results for your alternative release from the options:
a. EPA's OCA Guidance Reference Tables or Equations
b. EPA's RMP Guidance for Propane Storage Facilities Reference Tables or Equations
(Flammables only)
c. EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
(now in General Risk Management Program Guidance)
d. EPA's RMP Guidance for Warehouses Reference Tables or Equations
e. EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
/. EPA's RMP*Comp™
g. Other model name (specify)
5.3 Scenario:
Select one of the following or enter another scenario in Other:
• Vapor Cloud Explosion: An explosion of a cloud containing a flammable vapor or gas
and air.
• Fireball: The atmospheric burning of a fuel-air cloud in which the energy is mostly
emitted in the form of radiant heat. As the buoyancy forces of the hot gases begin to
dominate, the burning cloud rises and becomes spherical in shape. Fireballs are often
caused by the ignition of a vapor cloud of a flammable substance.
• BLEVE: Boiling Liquid Expanding Vapor Explosion (BLEVE) is used to describe the sudden
rupture of a vessel/system containing liquified flammable gas under pressure due to
radiant heat flux. The pressure burst and the flashing of the liquid to vapor creates a
blast wall and potential missile damage, and immediate ignition of the expanding fuel-
air mixture leads to an intense combustion creating a fireball.
• Pool Fire: The combustion of material evaporating from a layer of liquid at the base of
the fire.
• Jet Fire: Gas or liquid discharging or venting from a rupture will form a gas jet that
"blows" into the atmosphere in the direction the hole is facing, all the while entraining
and mixing with air. If the jet is flammable and encounters an ignition source, a flame jet
may form.
• Vapor Cloud Fire: A flash fire results from the ignition of a released flammable cloud in
which there is essentially no increase in the combustion rate.
• Other: (specify)
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5.4 Quantity released (Ibs):
Enter the quantity of the flammable substance you used for your alternative scenario analysis in
pounds to two significant digits. If you have less than 1 pound released, round up to 1 pound.
You may want to clarify that in your Executive Summary.
5.5 Endpoint used:
For vapor cloud explosions, the endpoint is 1 psi overpressure; for a fireball the endpoint is 5
kilowatts per square meter for 40 seconds; for vapor cloud fires or jet fires, a lower
flammability limit (expressed as a percentage) may be listed as specified in NFPA documents or
other generally recognized sources. These are listed in the OCA Guidance. Enter the endpoint
used in the text field.
5.6 Distance to endpoint (miles):
Enter the distance to the endpoint in miles to two significant digits, using the endpoint specified
for the chemical in 40 CFR part 68, Appendix A. Convert your modeling results into miles by
dividing the distance in feet by 5280 or yards by 1760. Refer to the following to determine two
significant digits:
0.397 miles should be reported as 0.40 miles
9.345 miles should be reported as 9.3 miles
20.764 miles should be reported as 21.0 miles
5.7 Residential population within distance to endpoint:
Estimate the population within the circle with a center at the point of the release and a radius
determined by the distance to the endpoint to two significant digits (e.g., 5,500 people rather
than 5,483). Population estimates include only residential populations.
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| 5.8. Public receptors within distance to endpoint
5.8.a. Schools
5-8-b- Residences
5.8.C. Hospitals
5-8-d- Prison/Correctional facilities
5.8.e. Recreational areas
5.8.f. Major commercial, office or industrial areas
5.8-g. Other
| 5.9. Environmental receptors within distance to endpoint
5.9.a. National or State parks, forests, monuments
5.9.b. Officially designated wildlife sanctuaries, preserves or refuges
5.9.C. Federal wilderness area
5.9.d. Other
| 5.10. Passive mitigation considered
5.10.a. Dikes
5.10.b- Firewalls
5.10.C. Blast walls
5-10-d. Enclosures
5.10.e. Other
| 5.11. Active mitigation considered
5.11.a. Sprinkler systems
5.11.b. Deluge systems
5.11.C. Water curtain
5.11.d. Excess flow valve
5.11.e. Other
15.12. Graphic file
Load/Unload File
'
'
2
\
2
I
J
None
Discard Changes
Delete Scenario
Save and Return
5.8 Public receptors within distance to endpoint:
Public receptors must be identified within the circle with a center at the point of the release
and a radius determined by the distance to the endpoint. Public receptor means locations
where members of the public may be exposed to toxic concentrations, radiant heat, or
overpressure as a result of the release. Public receptors include locations within the facility's
property boundary to which the public has routine and unrestricted access during or outside
business hours (e.g., a recreation field). Locations inhabited or occupied by the public at any
time without restriction by the source (such as fences or security guards) are public receptors
(see the General Risk Management Program Guidance for more information on identifying
public receptors). You do not need to list specific locations or estimate populations at these
locations. The presence of these receptors may be determined using local street maps. Select
all that apply:
a. Schools: Public and private elementary, secondary, or post-secondary educational
institutions (e.g., colleges).
b. Residences: Private residences and dwellings wherever people live.
c. Hospitals: Health care facilities.
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d. Prisons or Correctional facilities: Places of incarceration.
e. Recreation areas: Including stadiums, parks, and public pools.
f. Major commercial, office, or industrial areas: Including industrial parks, office buildings,
shopping malls, commercial areas, and commercial farms.
g. Other: (Include any other additional information here)
5.9 Environmental receptors within distance to endpoint:
Environmental receptors must be identified within the circle with a center at the point of the
release and a radius determined by the distance to the endpoint. Environmental receptor
means natural areas, such as national or state parks, forests, or monuments; officially
designated wildlife sanctuaries, preserves, refuges, or areas; and federal wilderness areas that
could be exposed at any time to toxic concentrations, radiant heat, or overpressure as a result
of the release. Environmental receptors can be identified on local U.S. Geological Survey maps,
which can be found at many libraries and online via the USGS Website. Select all that apply by
clicking the appropriate check boxes.
a. National or state parks, forests, or monuments
b. Officially designated wildlife sanctuaries, preserves, or refuges
c. Federal wilderness areas
d. Other (Include any other additional information here)
5.10 Passive mitigation considered:
Mitigation means specific activities, technologies, or equipment designed or deployed to
capture or control substances that have been released to minimize exposure of the public or
the environment. Passive mitigation means equipment, devices, or technologies that function
without human, mechanical, or other energy input. Select all that were considered in defining
the release quantity or rate to the worst-case scenario or alternative release scenario by
clicking the appropriate check boxes.
a. Dike: A dike is a low wall that acts as a barrier to prevent a spill from spreading.
b. Fire Wall: A wall constructed to prevent the spread of fire.
c. Blast Wall: A heavy wall used to isolate buildings or areas that contain highly
combustible or explosive materials.
d. Enclosure: Physical containment of the release within a structure (e.g., a building).
e. Other: (specify)
5.11 Active mitigation considered:
Active mitigation means equipment, devices, or technologies that need human, mechanical, or
other energy input to function. Select all that were considered in defining the release quantity
or rate of the alternative release scenario.
a. Sprinkler Systems: A system for protecting a building against fire by means of overhead
pipes which convey an extinguishing fluid through heat activated outlets.
b. Deluge Systems: A system to overflow an area of a release with water or other
extinguishing fluid.
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c. Water Curtain: A spray of water from a horizontal pipe through nozzles, the curtain may
be activated manually or automatically.
d. Excess Flow Valve: A system for diverting overflow.
e. Other (specify):
5.12 Graphics file name:
You may load one graphic file to illustrate each release scenario by clicking on the
"Load/Unload File" button. Entering a graphics file name in this field will not automatically
cause that file to be included in your RMP submission. Graphics will be accepted in either GIF or
JPEG file format. If you have a graphics file present in your RMP that you would like to remove,
you can unload the graphic file using the "Load/Unload" File button.
Section 6: Five-Year Accident History
Complete this section for each reportable accident.
Section 6. Five-Year Accident History
Section 7. Prevention Program: Program Level 3
Select a Prevention Program from the following list to update or delete:
1000025829 (111339) Loki Chemicals has prepared a unified Ri v
Section 8. Prevention Program: Program Level 2
Add Program
Section 9. Emergency Response
Enter Emergency Response
Executive Summary
Enter Executive Summary
Select the "Add Accident" button under Section 6. Five-Year Accident History
NOTE: Please remember to periodically use the "Save and Return" button at the bottom
of the page. As a security measure, if you remain inactive in the system for 19 minutes,
the system will log you out at the 20th minute and your entered data will not be saved!
Each time you save, the system will return you to the RMP*eSubmit Section Selection
page. Click the "Enter Registration Information" button to enter more data.
NOTE: If you do not wish to keep the information you've entered, click the "Discard
Changes" button.
The following is a discussion of each element in Section 6. Five-Year Accident History.
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t Announcements I Contact Us
EPA Facility ID: 100000215689
Are you claiming Confidential Business Information (CBI) in this Section? O
6.1. Date of accident (MM/DD/YYYY):'
6.2. Time accident began (HHMM): '
6.3. NAICS Code of process involved:
m
6.4, Release duration: *
6.5. Chemicals involved:
Wind direction:
6.8.d. Precipitation present:
6. 8.e Unknown weather conditions (check if a-d are all unknown): I
If your facility is claiming Confidential Business Information (CBI) in this section, check the box.
If claiming CBI and you've checked the box, a pop-up message will appear describing the step
that must be taken by the Preparer.
6.1 Date of accident:
Enter the date on which the accident occurred (MM/DD/YYYY).
6.2 Time accident began:
Enter the time the release began. Use standard time references (i.e., HHMM = 1237). You must
also select the AM or PM check box option to indicate what time of day the accident occurred.
6.3 NAICS Code of process involved:
Provide an NAICS code by using the NAICS Code Selector field to select the North American
Industry Classification System (NAICS) codes associated with your covered processes.
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• - : :e -. :- :: ^: . v
EPA Facility ID: 100000215689
Select NAICS Code
Step 1 - Select Sector
Step 2 - Select Sub-Sector
Step 3 - Select Industry Group
Final Step - Select NAICS from the following List
To cancel your selection click the "Discard Selection" button. To populate your selection click the "Populate Selection" button.
Discard Selection
NAICS Code Selection: The North American Industry Classification System (NAICS) categorizes
businesses by fitting them into descriptive categories that correspond to five-digit or six-digit
codes. NAICS codes have replaced SIC codes, which you may be familiar with. For this data
element you should provide the NAICS code that most closely corresponds to the process; it will
not necessarily be the same NAICS code for you facility as a whole. You may also enter
additional NAICS codes if you wish to identify other aspects of a process not captured by the
NAICS codes for the primary activity.
You should determine the NAICS codes for your processes based on your activities on site using
the 2012 North American Industry Classification System Manual, which can be viewed online:
www.census.gov/epcd/www/naics.html.
Once you've selected the sector that most appropriately reflects the sector for your facility
(Step 1), you must select the sub-sector, which enables you to select a more specific sector
within your industry (Step 2). Next, you must select the industry group that represents your
facility (Step 3). The last option is to select the NAICS code that reflects your facility (Final Step).
All steps must be competed in succession. See below for more information.
Step 1 - Select Sector drop down list enables you to add the sector of the NAICS code to
an accident scenario.
Step 2 - Select Sub-Sector drop down list enables you to add the subsector of the NAICS
code to an accident scenario.
Step 3 - Select Industry Group drop down list enables you to add the industry group of
the NAICS code to an accident scenario.
Final Step - Select NAICS from following list drop down list enables you to select your
NAICS code to an accident scenario.
The "Populate Selection" button enables you to populate the five-year accident history record
with any selections you've made from any of the available drop down list in the and returns you
to the previous screen, Section 6. Five-Year Accident History.
The "Discard Selection" button enables you to discard any selections you've made from any of
the available drop down list without saving and returns you to the previous screen, Section 6.
Five-Year Accident History.
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6.4 Release duration:
Enter the approximate length of time of the release in hours (Format: HHH) and in minutes
(Format: MM).
RMP*eSubmit Section 6. Add Chemical
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6.5.a. Select Chemical: '
1.1-Dimethylhydrazine [Hydrazine. 1.1 -dimethyl-] (57-14-7) (T)
1.3-Butadiene (106-99-0) (F)
1.3-Pentadiene (504-60-9) (F)
1-Butene (106-98-9) (F)
1-Chloropropylene [1-Propene. 1-chloro-] (590-21-6) (F)
1-Pentene (109-67-1) (F)
2,2-Dimethylpropane [Propane, 2.2-dimethyl-] (463-82-1) (F)
2-Butene (107-01-7) (F)
2-Butene-cis (590-18-1) (F)
2-Butene-trans [2-Butene. (E)] (624-B4-6) (F)
2-Methyl-l-butene (563-46-2) (F)
2-Methylpropene [1 -Propene. 2-methyl-] (115-11-7) (F)
2-Pentene. (E)- (646-04-8) (F)
Acetylene [Ethyne] (74-86-2) (F)
Acrolein [2-Propenal] (107-02-8) (T)
Acrylomtrile [2-Propenenitrile] (107-13-1) (T)
Continue Add Chemical
6.5 Chemicals Involved:
Indicate the regulated substance(s) released. Use the name of the substance as listed in Section
68.130 rather than a synonym. If the release was a NFPA-4 flammable mixture containing
regulated flammables, you may list it as a "flammable mixture" and list all of the regulated
substances contained in the mixture. For the quantity released, you only report the quantity of
the entire mixture, not the individual substances. Only report chemicals that are listed
substances.
a. Select Chemical: Select chemical from the scrolling list and click the "Continue Add
Chemical" button. Chemicals can be added one at a time.
b. Quantity released (Ibs): Provide the chemical quantity for your process chemical in
this field by clicking the "Add Chemical" button. For each chemical reported in
1.17.c.l, report the maximum quantity (in pounds) held in the covered process at
any one time during the calendar year to two significant digits. For example:
5,333 pounds should be reported as 5,300 pounds
107,899 pounds should be reported as 110,000 pounds
128,000 pounds should be reported as 130,000 pounds
6.6 Release event:
Indicate which of the following release events best describes your accident. Select at least one
item from the available check boxes.
a. Gas Release: A gas release is a release of the substance in a vapor state. If you hold a
gas liquified under refrigeration, report the release as a liquid spill.
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C. Liquid Spill/Evaporation: A liquid spill/evaporation is a release of the substance in a
liquid state with subsequent vaporization.
d. Fire: A product (e.g., fuel) in a state of combustion.
e. Explosion: A rapid chemical reaction with the production of noise, heat, and violent
expansion of gasses.
f. Uncontrolled/Runaway Reaction: An indication that the release event involved an
uncontrolled or runaway reaction. A release event caused by an uncontrolled
chemical reaction that generates excessive heat, pressure, or harmful reaction
products. Such events may involve highly exothermic chemical reactions, self-
reactive substances (e.g., substances that undergo polymerization), unstable,
explosive, or spontaneously combustible substances, substances that react strongly
with water or other contaminants, oxidizers, peroxide-forming substances, or other
types of chemical reactions that generate harmful products or byproducts. This
category of release event may often occur in conjunction with one of the previous
categories. In such cases, be sure to check this category in addition to any other
applicable release event category (e.g., explosion). The burning of ordinary
flammable substances is not typically included in this category.
6.7 Release source:
Select at least one:
a. Storage Vessel: A storage vessel is a container used only to store or hold (as
opposed to react, mix, or move) a regulated substance. Storage vessels include
transportation containers (e.g., railcars or tank trucks) being used for on-site
storage.
b. Piping: Piping refers to a system of pipes used to carry a fluid or gas.
C. Process Vessel: A process vessel is a container in which regulated substances are
manufactured, reacted, or mixed.
d. Transfer Hose: A transfer hose is a flexible tube used to connect, often temporarily,
two or more vessels.
e. Valve: A valve is a device used to regulate the flow in piping systems or machinery.
Relief valves open to release pressure in vessels.
f. Pump: A pump is a device that raises, transfers, or compresses fluids or that
attenuates gases by suction or pressure or both.
g. Joint: The surface at which two or more mechanical components are united.
h. Other (specify):
6.8 Weather conditions at time of event:
This information is important to those concerned with modeling the effects of accidents.
Reliable information from those involved in the incident or from an onsite weather station is
ideal. However, the rule does not require your facility to have an on-site weather station. If you
do not have an on-site weather station, use information from your local weather station,
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airport, or other source of meteorological data. Historical wind speed and temperature data
(but not stability data), can be obtained from the National Climatic Data Center (NCDC) at 828-
271-4800 or via the NCDC Website. NCDC staff can also provide information on the nearest
weather station. To the extent possible, complete the following:
a. i. Wind speed: Wind speed is an estimate of how fast the wind is traveling.
ii. Wind speed units: Indicate the units in which the speed is expressed as either
miles per hour, meters per second, or knots.
iii. Wind direction: Wind direction is the direction from which the wind comes. For
example, a wind that blows from east to west would be described as having an
eastern wind direction. Describe wind direction as one of the 16 standard
compass readings [N, S, E, W, NE, SE, NW, SW, NNE, ENE, ESE, SSE, SSW, WSW,
WNW, NNW], using the abbreviation. For example, wind direction must be
reported as S for south, NE for northeast, or SSW for south-southwest.
b. Temperature: Enter the ambient temperature at the scene of the accident in
degrees Fahrenheit. If you did not keep a record, you can use the high (for daytime
releases) or low (nighttime releases) for the day. Local newspapers publish these
data.
C. Atmospheric stability class: Depending on the amount of incoming solar radiation as
well as other factors, the atmosphere may be more or less turbulent at any given
time. Meteorologists have defined six atmospheric stability classes, each
representing a different degree of turbulence in the atmosphere. When moderate to
strong incoming solar radiation heats air near the ground, causing it to rise and
generating large eddies, the atmosphere is considered unstable, or relatively
turbulent. Unstable conditions are associated with stability classes A and B. When
solar radiation is relatively weak, air near the surface has less of a tendency to rise
and less turbulence develops. In this case, the atmosphere is considered stable or
less turbulent with weak winds; the stability class is E or F. Stability classes D and C
represent conditions of more neutral stability, or moderate turbulence. Neutral
conditions are associated with relatively strong wind speeds and moderate solar
radiation. Select either A, B, C, D, E, or F by selecting the appropriate entry from the
drop down list.
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METERS ABOVE GROUND °AY NIGHT*
Meters per
second
<2
2-3
3-5
5-6
>6
Miles per hour
<4.5
4.5-7
7-11
11-13
>13
Incoming Solar Radiation
Strong**
A
A-B
B
C
C
Moderate
A-B
B
B-C
C-D
D
Slight***
B
C
C
D
D
Thinly Overcast
or > 4/8
low cloud
E
D
D
D
<3/8
Cloud
F
E
D
D
d. Precipitation present: Precipitation may take the form of hail, mist, rain, sleet, or
snow. If there was precipitation present at the time of the event, check the check
box in this field.
e. Unknown weather conditions (check if a-d are all unknown): If you do not have
information regarding the weather at the time of the event, select the check box
available in this field. EPA recognizes that you may not have weather data for
accidents that occurred in the past. You must, however, collect these data during
future accident investigations.
6.9. On-site Impacts (enter numbers only):
Employees or contractors
6.9.a. Deaths: *
6.9_b. Injuries: *
6.9-C. Property damage ($): *
Public responders
Public
6.10. Known off-site impacts (enter numbers only):
6.10.a.
Deaths: *
6_10.d.
Evacusted: *
6.10.g. Environmental damage
6.10.g.l Fish „
or animal kills
6.10.g.4- Soil
contamination
6.10.b.
Hospitalizations:
Sheltered-in-
place: *
6.10.g.2. Tree.
lawn, shrub or n
crop damage
6.10-9-5. Other
(soecifvt
6.10.C. Other medical
treatments: *
6.10.f. Property
damage ($): *
6-10. g. 3. Water
contamination
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6.9 On-site impacts:
Complete each of the following about on-site effects. Enter a number for each entry; if there
were no impacts, enter 0.
a. Deaths: Enter the number of on-site deaths that are attributable to the accident or
mitigation activities. Onsite deaths include anyone (employees, contractors,
responders, or others), who was killed by direct exposure to toxic concentrations,
radiant heat, or overpressures from the accidental release or from indirect
consequences of a vapor cloud explosion from an accidental release (e.g., flying glass
debris or other projectiles). If there were no on-site deaths, enter 0. Specify the
deaths as:
i. Employees or contractors
ii. Public responders (example: fire department personnel)
iii. Public (example: visitors)
b. Injuries: An injury is any effect that results either from direct exposure to toxic
concentrations, radiant heat, or overpressures from the accidental release or from
indirect consequences of a vapor cloud explosion from an accidental release (e.g., a
window shattering after an explosion) and that requires medical treatment or
hospitalization. Medical treatment means treatment, other than first aid,
administered by a physician or registered professional personnel understanding
orders from a physician (OSHA ON Log, 1904.12).Your OSHA occupational injury and
illness log will help complete these items for employees. Enter the appropriate value
for these fields. If there were no on-site injuries, enter 0. Specify the injuries as:
i. Employees or contractors
ii. Public responders (example: fire department personnel)
iii. Public (example: visitors)
C. Property damage ($): Estimate the value of the equipment or business structures at
your facility that were damaged by the accident or mitigation activities. Record the
value in US dollars. Insurance claims may provide this information. Do not include
any losses that you may have incurred as a result of business interruption. If there
was no onsite property damage or no known damage, enter 0.
6.10 Known offsite impacts:
These are impacts of which you should be aware (e.g., from media reports) or that were
reported to your facility. You are not required to conduct an additional investigation to
determine off-site impacts. Enter a number for each entry; if there were no impacts, enter 0.
a. Deaths: Enter the number of offsite deaths that are attributable to the accident or
mitigation activities. Offsite deaths include anyone who was killed by direct
exposure to toxic concentrations, radiant heat, or overpressures from the accidental
release or from indirect consequences of a vapor cloud explosion from an accidental
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release (e.g., a window shattering after an explosion). Responders killed while on
site responding to the release are considered on-site deaths and should not be
reported here (See 6.9, On-site Impacts). If there were no known offsite deaths,
enter 0.
b. Hospitalizations: Enter the number of people requiring hospitalization.
Hospitalization means any effect that result either from direct exposure to toxic
concentrations, radiant heat, or overpressures from accidental releases or from
indirect consequences of a vapor cloud explosion from an accidental release (e.g., a
window shattering after an explosion) and that requires hospitalization (i.e.,
admittance to the hospital). If there were no known off-site hospitalizations, enter 0.
c. Other medical treatments: Enter the number of people requiring medical
treatment. Medical treatment means any effect that result either from direct
exposure to toxic concentrations, radiant heat, or overpressures from accidental
releases or from indirect consequences of a vapor cloud explosion from an
accidental release (e.g., a window shattering after an explosion) and that requires
medical treatment. If there was no known medical treatment, enter 0.
d. Evacuated: Estimate the number of people who were evacuated to prevent
exposure that might have resulted from the accident. A total count of the number of
people evacuated is preferable to the number of houses evacuated. People who
were ordered to move simply to improve access to the site for emergency vehicles
are not considered to have been evacuated, but people who normally-occupy a
building or area and who are prevented from entering or returning (i.e., blockaded)
in order to prevent potentially harmful exposure should be considered to have been
evacuated. If there were no evacuations, enter 0.
e. Sheltered-in-place: Estimate the number of people who were sheltered-in-place
during the accident. Sheltering-in-place occurs when the incident commander orders
residents to remain inside their home or place of work until the emergency has
ended, preventing exposure to the substance. Usually these are associated with an
emergency broadcast or similar method of mass notification by response agencies. If
no one sheltered in place, enter 0.
f. Property damage ($): Estimate the value of the equipment or structures off-site that
were damaged by the accident or mitigation activities. Record the value in U.S.
dollars. Insurance claims may provide this information; any level of off-site property
damage triggers reporting. There is no lower limit below which you would not have
to report. If there was no property damage, enter 0.
g. Environmental damage: Indicate whether any environmental damage occurred and
specify the type. The damage is not limited to environmental receptors listed in the
rule. Any damage to the environment (e.g., dead or injured animals, defoliation, and
water contamination) must be reported. Select all that apply.
• Fish or animal kills
• Tree, lawn, shrub, or crop damage
• Water contamination
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• Soil contamination
• Other (specify)
6.11. Initiating event: *
6.11.a. Equipment
failure:
6.11.d. Unknown:
6.12. Contributing factors:
6.11.b. Human
error:
6.11.C. Natural
(weather
conditions.
earthquake):
6.12.a. Equipment
failure
6.12.d.
Overpressurization
6.12.g.
Maintensnce
activity/inactivity
6.12-j. Unusual
weather
conditions
6.12.1. Other
(snenifvl
6.12.b. Human
error
6.12.6. Upset
condition
6.12.h. Process
design failure
6.12.k.
Management error
6.12.C. Improper
procedures
6.12.f. By-pass
condition
6.121 Unsuitable
equipment
6.11 Initiating event:
Select the check box for the one initiating event that best describes the immediate cause of the
accident.
a. Equipment failure: A device or piece of equipment failed or did not function as
designed. For example, the vessel wall corroded or cracked.
b. Human error: An operator performed a task improperly, either by failing to take the
necessary steps or by taking the wrong steps.
c. Natural (weather conditions, earthquake): Weather conditions, such as lightning,
hail, ice storms, tornados, hurricanes, floods, high winds or earthquakes caused the
accident.
d. Unknown.
6.12 Contributing factors:
These are factors that contributed to the accident's occurring, but were not the initiating event.
If you conducted an investigation of the release, you should have identified factors that led to
the initiating event. Select all that apply.
a. Equipment failure: A device or piece of equipment failed to contain substance or did
not function as designed, thereby allowing a substance to be released.
b. Human error: A person performed an operation improperly or made a mistake
which resulted in an accident.
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C. Improper procedures: The procedure did not reflect the proper method of
operation, the procedure omitted steps that affected the accident, or the procedure
was written in a manner that allowed for misinterpretation of the instructions.
d. Overpressurization: The process was operated at pressures exceeding the design
working pressure.
e. Upset condition: Release was caused by incorrect process conditions (e.g., increased
temperature or pressure).
f. By-pass condition: The failure occurred in a pipe, channel, or valve that diverts fluid
flow from the main pathway when design process or storage conditions are
exceeded (e.g., overpressure). By-pass conditions may be designed to release the
substance to restore acceptable process or storage conditions and prevent more
severe consequences (e.g., explosion).
g. Maintenance activity/inactivity: The failure occurred because of maintenance
activity or inactivity. An example of maintenance activity is putting the wrong gasket
on a tank fitting. An example of maintenance inactivity is storage racks that
remained unpainted for so long that corrosion caused the metal to fail.
h. Process design failure: The failure resulted from an inherent flaw in the design of
the process (e.g., pressure needed to make product exceed the design pressure of
the vessel).
i. Unsuitable equipment: The equipment used was incorrect for the process. For
example, the forklift was too large for the corridors.
j. Unusual weather conditions: Weather conditions, such as lightning, hail, ice storms,
tornados, hurricanes, floods, high winds, earthquakes and caused the accident.
k. Management error: The failure occurred due to any management error or
management system error not included in categories a through j. Such factors may
include inadequate training, inadequate oversight, inadequate hazard analysis, or
other management-related factors.
I. Other (specify).
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6.13. Off-site responders notified:"
6.13.a. Notified
only:
6.13.d. Unknown: O
6.13.b. Notified
and responded:
6.13.6. Other
(specify):
6-13-C- No. not
notified:
O
6.14. Changes introduced as a result of the accident: *
6.14.3.
Improved/upgraded D
equipment
6-14-d- Revised
operating |T|
procedures
6.14.g. Revised
emergency n
response plan
6-14-j- None
6.14.D.
Revised
maintenance
6-14.6- New
process
controls
6.14.h.
Changed
process
6.14.k. Other
(specify)
Discard Changes
D
6.14.C. Revised
training
6-14-f. New mitigation
systems
6.14.1. Reduced
inventory
Delete Accident
Save and Return
6.13 Off-site responders notified:
Indicate whether response agencies (e.g., police, fire, medical services) were notified. Check
one of the following boxes:
a. Notified only
b. Notified and responded
C. No, not notified
d. Unknown
e. Other (specify)
6.14 Changes introduced as a result of the accident:
Indicate any measures that you have taken at the facility to prevent recurrence of the accident.
Select at least one.
a. Improved/upgraded equipment: A device or piece of equipment that did not
function as designed was repaired or replaced.
b. Revised maintenance: Maintenance procedures were clarified or changed to ensure
appropriate and timely maintenance including inspection and testing (i.e., increasing
the frequency of inspection or adding a testing method).
C. Revised training: Training programs were clarified or changed to ensure that
employees and contract employees are aware of and are practicing correct safety
and administrative procedures.
d. Revised operating procedures: Operating procedures were clarified or changed to
ensure that employees and contract employees are trained on appropriate
operating procedures.
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e. New process controls: New process designs and controls were installed to correct
problems and prevent recurrence of an accidental release.
f. New mitigation systems: New mitigation systems were initiated to limit the severity
of accidental releases.
g. Revised emergency response plan: The emergency response plan was revised.
h. Changed process: Process was altered to reduce the risk (e.g., process chemistry
was changed).
i. Reduced inventory: Inventory was reduced at the facility to reduce the potential
release quantities and the magnitude of the hazard.
j. None: No changes initiated at facility as a result of the accident (i.e., none were
necessary or technically feasible). There may be some accidents that could not have
been prevented because they were caused by events that are too rare to merit
additional steps. For example, if a tornado hit your facility and you are located in an
area where tornados are very rare, it may not be reasonable to design a "tornado-
proof" process even if it is technically feasible.
k. Other (specify).
Section 7: Prevention Program: Program Level 3
Complete this section for each prevention program you report for a Program 3 process. You will
only be able to add or update a scenario if a Program Level 3 process is present within Section
1. Processes section.
Section 7. Prevention Program: Program Level 3 | ' '|
Select a Prevention Program from the following list to update or delete:
1000025829 (111339) Loki Chemicals has prepared a unified Ri
Update/Delete Program
Section 8. Prevention Program: Program Level 2
Section 9. Emergency Response
r Emergency Response
Executive Summary
Enter Executive Summary
Return to RMP*eSubmit Home
Cancel Submission
Submit to Certify
How Must Prevention Program Data Be Reported?
Prevention program data must be reported on a process-by-process basis. In other words, you
must fill out the prevention program section of the RMP for each Program 2 or Program 3
process you have that is subject to the RMP rule.
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How to report the prevention program for a process depends on how many units the process
contains and whether the prevention program applies different safeguards to different units in
the process. The RMP rule broadly defines "process" to include interconnected or co-located
production and storage units. Under the definition, multiple units and, in some cases, whole
sources may be a single "process" for purposes of the RMP rule. For multiple unit processes,
EPA recognizes that prevention program implementation may involve different safeguards for
different units in the process. For example, different production units may have different
operating procedures. At the same time, some safeguards, such as management of change
procedures, may apply to all the units in the process.
If your process consists of two or more units and different safeguards apply to different units in
that process, you can report the prevention program for that process in one of the two
following ways. You must, however, use one of the two ways to report your program.
Use the description field in the prevention program to describe in narrative form how your
prevention program is implemented with respect to the different units in the process. You
could start by listing the common prevention program elements you implement for all of the
units (e.g., use of an alarm system or standard management of change procedures). You would
then indicate what additional prevention program elements you employ for specified units
(e.g., use of a dike for certain process units).
Report your prevention program for the process on a unit-by-unit basis by filling out the
prevention program portion of the RMP for every unit in the process, rather than for the
process as a whole. That way, the differences in the program as it relates to each unit will be
clear from the report. However, as noted above, some aspects of a prevention program may be
common to all units. To complete the prevention program record for each unit, enter the
remaining data which is unique to each.
If your process consists of only one unit, or you apply every element of your prevention
program to all the units in the process, you are not required to complete the description
section of this portion of the RMP or report on a unit-by-unit basis. However, you may use the
description field to elaborate on your prevention program.
Many prevention program data elements ask you to enter the date for the most recent "review
or revision" of a prevention program element required by Part 68. For your first RMP
submission, if you are subject to prevention program requirements only under the RMP rule (as
opposed to other federal or state laws), you should enter the date by which you completed the
prevention program element being addressed. For instance, for data element number 7.5,
"Date of most recent review or revision of operating procedures," you should enter the date by
which you met the operating procedures requirements of Section 68.69(a) of the RMP rule (if
applicable to you). Since this requirement must be met by the time your first RMP is due, you
may enter the date you complete or submit your first RMP. In the case of data element number
7.3 ("Date on which safety information was last reviewed or revised"), you should enter the
date you met the requirement of Section 68.65(a) (if applicable to you), since Section 68.65(a)
requires you to meet the requirement before you conduct the process hazard analysis for the
process.
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If you are subject to prevention program requirements under other federal or state laws, you
may be in compliance with RMP prevention program requirements as a result of complying
with the other laws. Sources subject to OSHA PSM, for example, may already meet RMP
prevention program requirements for Program 3 processes, since those requirements are
nearly identical to OSHA PSM prevention program requirements. For your first RMP submission,
if you have fulfilled RMP prevention program requirements in complying with other federal or
state laws, you should enter the date you complied with the requirement or the date you last
reviewed or revised the relevant aspect of your program, whichever is later. For example, OSHA
PSM and the RMP rule both require covered sources to compile and update (under specified
circumstances) process safety information. If you previously compiled the information for
purposes of complying with OSHA PSM and you have not updated it since, you should enter the
date you compiled it for OSHA in your RMP. If you have updated the information since
compiling it, you should enter the date of the update.
For subsequent RMP submissions, you should enter the date by which you completed any
review or revision of a prevention program element. Several prevention program elements
must be reviewed and, if necessary, revised following a change affecting the process (see, e.g.,
requirement to update safety information in Section 68.75(d)). Under the compliance audit
requirement of Sections 68.58 or 68.79 of the RMP Program, all prevention program elements
must be reviewed and, if appropriate, revised every three years. When you re-submit your next
RMP (due every 5 years or sooner based on the requirements in Section 68.190), you are
required to fully update and certify all nine sections of the RMP. If, by the time you re-submit,
you have reviewed or revised one or more prevention program elements as a result of a change
or an audit, you must enter the date of your review or revision.
EPA Facility ID: 100000215689
Are you claiming Confidential Business Information (CBI) in this Section?
Prevention Program Description:
7.1. NAICS Code for process: '
7.2. Chemicals*
7.3. Date on which the safety information was last reviewed or revised: *
7.4. Process Hazard Analysis (PHA(
7.4.a. Date of last PHA or PHA update '
7.4.D. Technique used (must select at least one) *
7.4 b.t What if: D 7.4 b.2. Checklist:
7.4.b.4. HAZOP:
7.4.b.7. Other (specify):
7.4 b-5. Failure mode & effects
analysis:
7.4.C. Expected or actual date of completion of all changes resulting from last PHA or PHA update:
7-4-0.3 What [{'Checklist Combined: f~|
7.4.b-6 Fault tree analysis:
7.4.d. Major hazards identified (must select at least one)'
7.4.d.1. Toxic release: | | 7.4.d.2. Fire:
7.4.d.3. Explosion
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Section 7: Prevention Program: Program Level 3
The following is a discussion of each element in Section 7. Prevention Program: Program Level3.
Prevention Program Description:
If different safeguards apply to different units in your process, use this field to explain how the
prevention program for the process relates to the different units in the process. For example:
"This process includes three interconnected production units, A, B, and C. Everything in
this prevention program applies to all three units, with the following exceptions:
• The dates of the PHA, which are 01/02/08, 6/5/07 and 4/3/07 for units A, B, and C,
respectively.
• Production unit A uses only a scrubber as a process control, while units B and C have
relief valves and scrubbers.
• The water curtain indicated as a mitigation measure applies only to production unit C."
If you have so many "exceptions" that it gets too complicated to explain as above, but you still
have many common data elements, you can report your prevention program on a unit-by-unit
basis. To complete the prevention program record for each unit, provide the remaining data
which is unique to each.
U.S. Environmental Protection Agency
Transaction Type: First
Time Submission
7.1. Select HAICS code for process:'
Continue Add Program
7.1 NAICS code for the process:
Provide the NAICS code that most closely corresponds to the process; it will not necessarily be
the same NAICS code as your facility as a whole. The NAICS code that you choose must be one
that you've already entered in the Registration Section for the covered process. RMP*eSubmit
contains a list of the NAICS codes that you have already entered for your registered processes
as a pick list for this data element.
7.2 Chemicals:
For each prevention program, provide the names of all regulated substances held above the
threshold in the covered units. If you have an NFPA-4 flammable mixture containing regulated
flammables, you may list it as a "flammable mixture." You do not need to list the individual
substances in the flammable mixture.
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U.S. Environmental Protection Agency
Nitric acid (cone 80% or greater) (7697-37-2) (T) •*
7.3 Date on which the safety information was last reviewed or revised:
The safety information requirements for Program 3 processes can be found at 40 CFR68.65. For
your first RMP, provide the date by which you complied with the safety information
requirements of Section 68.65(a) (compile safety information) for the process. For subsequent
RMPs, provide the date the safety information was most recently reviewed or revised. Safety
information may be reviewed or revised as a result of, among other things, a change to the
process (see Section 68.75(d)) or a periodic audit of the prevention program (see Section
68.79(a)). If the safety information was not reviewed or revised since the previous RMP was
submitted, re-enter the date provided in the previous Risk Management Plan (RMP).
7.4 Process Hazard Analysis (PHA):
a. Date of last PHA or PHA update:
Provide the date you completed or updated your most recent PHA.
b. Technique used (must select at least one): Check any of the following techniques
that you used to evaluate the hazards of your process or part of the process (see
Chapter 8, Appendix A, of the General Guidance for Risk Management Programs for
a description of these techniques). Select at least one by clicking on the check box
for each corresponding technique:
• What If
• Checklist
• What If/Checklist Combined
• HAZOP
• Failure Mode & Effects Analysis
• Fault Tree Analysis
• Other (specify)
c. Expected or actual date of completion of all changes resulting from last PHA or
PHA update: Provide the date you completed or expect to complete any changes
resulting from the PHA. This may be blank if there were no changes.
Major hazards identified: Select any major hazards that were identified for the
Program 3 process or part of the process as a result of the PHA. Major hazards are
described below. Select at least one by clicking on the check box for each
corresponding technique:
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7.4.D. MAJOR HAZARD
1. Toxic release
2. Fire process
3. Explosion
4. Runaway reaction
5. Polymerization
6. Overpressurization
7. Corrosion
8. Overfilling
9. Contamination
10. Equipment failure
11. Loss of cooling, heating,
electricity, instrument air
12. Earthquake
13. Floods (Flood Plain)
14. Tornadoes
15. Hurricanes
16. Other
^^^H ^^^H
If an accidental release occurred, a regulated toxic substance could be released.
For listed toxics, a toxic release will always be a major hazard.
Upsets, leaks, equipment failure, etc., could result in a fire. For listed
flammables, fire will always be a major hazard. Fire may also be a hazard for
some listed toxics and in some processes could cause a toxic release.
Confined or unconfined vapor cloud explosions. For listed flammables, explosion
will generally be a major hazard. Explosion may also be a hazard for toxics,
especially those handled under extreme conditions.
An uncontrolled reaction that proceeds at an increasing rate.
A chemical reaction that produces the bonding of two or more monomers.
Instantaneous energy release or detonation.
Corrosion could lead to destruction of equipment and release of a regulated
substance. Corrosion is likely to be a major hazard for substances identified as
corrosives on MSDSs unless the equipment used limits the hazard.
Filling a tank or vessel beyond its maximum safe capacity.
A release could occur if inappropriate substances are introduced into storage or
process vessels. Contamination may be a major hazard when controlling
inappropriate substances (e.g., H2O) is difficult.
Equipment failure is likely to be a major hazard for most processes, because such
failure could lead to a release. Equipment failure includes cracks, weld failures,
disk failures, ruptures, pump/gauge/control system failures, etc.
These losses could be major hazards, if they could lead to releases. For example,
loss of cooling could lead to an increase in pressure and failure of a vessel or
pipe and a loss of heating or power could lead to unstable processes. These
conditions are less likely to be major hazards for substances handled at
atmospheric temperatures and pressures.
Report earthquakes as a major hazard only if they occur or are likely to occur at
your site such that you plan and design for them.
Report floods as a major hazard only if they occur or are likely to occur at your
site such that you plan and design for them.
Report tornadoes as a major hazard only if they occur or are likely to occur at
your site such that you plan and design for them.
Report hurricanes as a major hazard only if they occur or are likely to occur at
your site such that you plan and design for them.
Specify any other major hazards not listed above.
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d. Process controls in use: Select all of the process controls used on the process or part of
the process. Process controls are equipment and associated procedures used to prevent
or limit releases and are described below. If none are applicable, check None.
7.4.E. PROCESS CONTROL
DESCRIPTION
1. Vents
An opening provided for the discharge of pressure or release of pressure from tanks,
vessels, or processing equipment.
2. Relief Valves
A valve that relieves pressure beyond a specified limit and recloses to normal
operating pressure upon return.
3. Check Valves
A device for automatically limiting the flow in a piping system to a single direction.
4. Scrubbers
A pre-release protection measure that uses water or aqueous mixtures containing
scrubbing reagents to remove discharging liquids and may treat the discharging
chemical.
5. Flares
A pre-release protection measure used for flammable gases and vapors to remove
and possibly treat discharged liquids.
6. Manual Shutoffs
Manual controls of the shutoff flow to a pipe or vessel.
7. Automatic Shutoffs
Controls the shutoff flow to a pipe or vessel and are triggered automatically when
process conditions are exceeded.
8. Interlocks
A switch or other device that prevents activation of a piece of equipment when a
protective door is open or some other hazard exists.
9. Alarms and Procedures
Systems that trigger a warning device after the occurrence of a hazardous condition
and procedures to activate an alarm system.
10. Keyed Bypass
A bypass system that is activated by a control signal.
11. Emergency Air Supply A backup system to provide air to a process when the regular air supply fails.
12. Emergency Power
Backup power systems.
13. Backup Pump
A secondary pump intended to serve the same function as the primary pump if the
primary pump fails.
14. Grounding Equipment
and Bonding
Devices that ground and bond electrical equipment to avoid explosions and to
provide a good electrical path to the ground.
15. Inhibitor Addition
A substance that is added to a reaction that is capable of stopping or retarding a
chemical reaction.
16. Rupture Disks
A device that relieves pressure beyond a specified limit.
17. Excess Flow Device
Flow-limiting equipment that protects downstream equipment from surges.
18. Quench System
A system that cools by removing excess heat or immersing liquid into a cooling
medium.
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7.4.E. PROCESS CONTROL DESCRIPTION
19. Purge System
20. None
21. Other
A system that replaces the atmosphere in a container with an inert substance
prevent the formations of an explosive mixture.
to
None are applicable.
Specify any other process controls that you may use on your process and that
not specified above.
are
e. Mitigation systems in use: Select all of the mitigation systems you have in place to
control a release from the process or part of the process. Mitigation systems are
described below. If none are applicable, check None.
7.4.F. MITIGATION DESCRIPTION
1. Sprinkler systems
2. Dikes
3. Firewalls
4. Blast walls
5. Deluge system
6. Water curtain
7. Enclosure
8. Neutralization
9. None
10. Other
A system for protecting a building against a fire by means of overhead pipes that
release an extinguishing material through heat activated outlets.
Upsets, leaks, equipment failure, etc., could result in a fire. For listed flammables,
will always be a major hazard. Fire may also be a hazard for some listed toxics and
some processes could cause a toxic release.
fire
in
A wall constructed to prevent the spread of fire.
A heavy wall used to isolate buildings or areas that contain highly combustible or
explosive materials.
A system to overflow an area with a release of water or other extinguishing fluid.
A spray of water from a horizontal pipe through nozzles. The curtain may be activated
manually or automatically.
Something that facilitates the physical containment of a release within a structure
(e.g., a building).
Controlling a release by neutralizing the released chemical.
None are applicable.
Specify any other mitigation systems you may have in place on your process and that
are not listed above.
f. Monitoring/detection systems in use: Select all of the monitoring and detection
systems you have installed to detect a release of a regulated substance from the
process or part of the process. Monitoring and detection systems are described
below. If none are applicable, check None.
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7.4.G. MONITORING &
DETECTION SYSTEMS
1. Process area detectors
Detection systems located on or close to process equipment. Detection systems
include indicator tubes, and chromatographic, spectrometric, electrochemical, and
colorimetric gas analysis.
2. Perimeter Monitors
Integrated detection networks at the source boundary. Detection systems can
include fluorescent SO2 analyzers, photoelectric tape sensors, or electrolytic
chlorine detectors.
3. None
None are applicable.
4. Other
Specify any other monitoring and detection systems you have in place and that are
not listed above.
g. Changes since last PHA or PHA update: Select all of the changes made to the process
or part of the process since the last PHA. If none are applicable, check None.
.4.H. CHANGES SINCE LAST PHA / I
UPDATE
DESCRIPTION
1. Reduction in chemical inventory
2. Increase in chemical inventory
3. Change in process parameters
4. Installation of process controls
5. Installation of process detection systems
6. Installation of perimeter monitoring
systems
7. Installation of mitigation systems
8. None recommended
9. None
10. Other (specify)
A decrease in the quantity of regulated substances stored on-
site.
An increase in the quantity of regulated substances stored on-
site.
Examples of changes in process parameters include an increase
or decrease in temperature, pressure, flow rates, etc.
The addition of controls such as those described in 7.4 e. or 8.4
d.
The addition of systems such as those described in 7.4 g. or 8.4 f.
The addition of systems such as those described in 7.4 g. or 8.4 f.
The addition of systems such as those described in 7.4 f. or 8.4 e.
Select None recommended if the PHA team did not recommend
any changes to the process.
None are applicable.
Specify any other changes made to the process since the last PHA
that are not listed above.
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7.B.C.3. Demonstration:
7.5. Date of most recent review or revision of operating procedures: *
| 7.6. Training
7.6.a. Date of most recent review or revision of training programs: *
7.6.b. Type of training provided (must select at least one) *
7.6.b.1- Classroom: Q 7.6.b.2. On the job:
7.6.b.3. Other (specify):
I 7.6.c. Type of competency testing used (must select at least one) *
7.6.C.1. Written test: O 7.6.C.2. Oral test:
7.6.C.4. Observation: [Ł| 7.6.C.5. Other (specify):
| 7.7. Maintenance
7.7.a. Date of most recent review or revision of maintenance procedures: *
7.7.b. Date of most recent equipment inspection or test: *
7.7.c. Equipment most recently inspected or tested (equipment list): *
I 7.8. Management of change
7.8.a. Date of most recent changes that triggered management of change procedures:
7.8.b. Date of most recent review or revision of management of change procedures: *
7.5 Date of most recent review or revision of operating procedures:
The operating procedures requirements for Program 3 processes can be found at 40 CFR 68.69.
For your first RMP, provide the date by which you complied with the requirements of Section
68.69(a) (develop and implement written procedures) for the process. For subsequent RMPs,
provide the date of the most recent review or revision of the operating procedures. Operating
procedures may be reviewed or revised as a result of, among other things, a change to the
process (see Sections 68.69(c) and 68.75(e)), annual certification of the operating procedures
(see Section 68.69(c)), or a periodic audit of the prevention program (see Section 68.79(a)).
7.6 Training:
a. Date of most recent review or revision of training programs: For your first RMP,
provide the date by which you ensured that the training you provide the employees
operating the process meets the requirements of Section 68.71(a). For subsequent
RMPs, provide the date of the most recent review or revision of the training you
provide. Training programs may be reviewed or revised as a result of, among other
things, a change to the process (see Section 68.75(c)) or a periodic audit of the
prevention program (see Section 68.79(a)). If the training was not reviewed or
revised since the previous RMP was submitted, re-enter the date provided in the
previous RMP.
b. Type of training provided: Select the type of training provided (select all that apply).
Training information can be found in the RMP regulation at 40 CFR 68.54 and 68.71.
c. Type of competency testing used: Indicate the type of competency test used:
written test, oral test, demonstration, or observation by selecting the appropriate
check box(es). Competency tests are used to determine and evaluate
comprehension of the training materials. Training information can be found in the
RMP regulation at 40 CFR 68.54 and 68.71.
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7.7 Maintenance:
a. The date that you most recently reviewed or revised the maintenance
procedures: For your first RMP, provide the date by which you complied with the
requirements of Section 68.73(b) (establish and implement written maintenance
procedures) for the process. For subsequent RMPs, provide the date of the most
recent review or revision of the maintenance procedures. Maintenance procedures
may be reviewed or revised as a result of, among other things, a change to the
process (see Section 68.75(c)) or a periodic audit of the prevention program (see
Section 68.79(a)). If the procedures were not reviewed or revised since the previous
RMP was submitted, re-enter the date provided in the previous RMP.
b. The date of the most recent equipment inspection or test: Provide the appropriate
date. Maintenance information can be found in the RMP regulation at 40 CFR 68.56
and 68.73.
c. The equipment that was inspected or tested (list equipment): Specify the
equipment inspected or tested. Maintenance information can be found in the RMP
regulation at 40 CFR 68.56 and 68.73.
7.8 Management of change:
a. The date of the most recent change (if any) that triggered the management of
change procedure: Provide the appropriate date. Management of Change
information can be found in the RMP regulation at 40 CFR 68.75.
b. The date that you most recently reviewed or revised the management of change
procedures at your site: For your first RMP, provide the date by which you complied
with the requirements of Section 68.75(a) (establish and implement written
procedures) for the process. For subsequent RMPs, provide the date of the most
recent review or revision of the procedures. Management of change procedures
may be reviewed or revised as a result of, among other things, a periodic audit of
the prevention program (see Section 68.79(a)). If the procedures were not reviewed
or revised since the previous RMP was submitted, retain the date provided in the
previous RMP.
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7.9. Date of most recent pre-startup review:
7.10. Compliance audits
7-10-3- Date of most recent compliance audits:
7.10.b. Expected or actual date of completion of all changes resulting from the most recent compliance
audits:
7.11. Incident investigation
7-1la- Date of most recent incident investigation (if any):
7.11.D. Expected or actual date of completion of all changes resulting from the incident investigation:
7.12. Date of most recent review or revision of employee participation plans: *
7.13. Date of most recent review or revision of hot work permit procedures: *
7.14. Date of most recent review or revision of contractor safety procedures:
7.15. Date of most recent evaluation of contractor safety performance:
Discard Changes • Delete Program • Save and Return
7.9 Date of most recent pre-startup review:
The pre-startup review requirements for Program 3 processes can be found at 40 CFR 68.77.
Provide the date of the most recent pre-startup review (if any) for this process.
7.10 Compliance audits:
a. Date of most recent compliance audit: Provide the date of your most recent
compliance audit. If you have not conducted a compliance audit prior to your first
submission, leave these fields blank.
NOTE: A compliance audit is required every three years. Compliance audit information
can be found in the RMP regulation at 40 CFR 68.58 and 68.79.
b. Expected or actual date of completion of all changes resulting from the compliance
audit: This may be left blank if there were no changes. Incident Investigation
information can be found in the RMP regulation at 40 CFR 68.60 and 68.81.
7.11 Incident investigation:
The incident investigation requirements for Program 3 processes can be found at 40 CFR 68.60
and 68.81.
a. Date of your most recent incident investigation (if any): Provide the date of your
most recent incident investigation, if any. If you have not had an incident
investigation, leave this field blank.
b. The expected or actual date of completion of all changes resulting from the
incident investigation: Provide the expected or actual date of completion of all
changes resulting from the incident investigation. This may be left blank if there
were no changes or all changes are complete.
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7.12 Date of most recent review or revision of employee participation plans:
The employee participation requirements for Program 3 processes can be found at 40 CFR
68.83. For your first RMP, provide the date by which you complied with the requirements of
Section 68.83(a) (develop a written plan) for the process. For subsequent RMPs, provide the
date of the most recent review or revision of the plan. Employee participation plans may be
reviewed or revised as a result of, among other things, a periodic audit of the prevention
program (see Section 68.79(a)). If the plan was not reviewed or revised since the previous RMP
was submitted, retain the date provided in the previous RMP.
7.13 Date of most recent review or revision of hot work permit procedures:
The hot work permit requirements for Program 3 processes can be found at 40 CFR 68.85. For
your first RMP, provide the date by which you ensured that you comply with the requirements
of Section 68.85. For subsequent RMPs, provide the date of the most recent review or revision
of your permit procedures. Hot work permit procedures may be reviewed or revised as a result
of, among other things, a periodic audit of the prevention program (see Section 68.79(a)). If the
procedures were not reviewed or revised since the previous RMP was submitted, retain the
date provided in the previous RMP.
7.14 Date of most recent review or revision of contractor safety procedures:
The contractor safety requirements for Program 3 processes can be found at 40 CFR 68.87.
Leave this field blank if you do not have any contractors. Otherwise, for your first RMP, provide
the date by which you complied with the requirements of Section 68.87(b) (4) (develop and
implement safe work practices for contractors) for the process. For subsequent RMPs, provide
the date of the most recent review or revision of the procedures. Contractor safety procedures
may be reviewed or revised as a result of, among other things, a change to the process (see
Section 68.75(c)) or a periodic audit of the prevention program (see Section 68.79(a)). If the
procedures were not reviewed or revised since the previous RMP was submitted, retain the
date provided in the previous RMP.
7.15 Date of most recent evaluation of contractor safety performance:
Leave this field blank if you do not have any contractors or have not yet evaluated contractor
performance. Otherwise, provide the date of your most recent evaluation of contractor safety
performance. If you have more than one contractor involved in operating or maintaining the
process, provide the date that you completed your evaluations of all the contractors.
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Section 8: Prevention Program: Program Level 2
Complete this section for each prevention program you report for a Program 2 process. You will
only be able to add or update a scenario if a Program Level 2 process is present within Section
1. Processes section.
Section 8. Prevention Program: Program Level 2
Section 9. Emergency Response
Enter Emergency Response
Executive Summary
Return to RMP'eSubmit Horn
Submit to Certify
How Must Prevention Program Data Be Reported?
Prevention program data must be reported on a process-by-process basis. In other words, you
must fill out the prevention program section of the RMP for each Program 2 or Program 3
process you have that is subject to the RMP rule.
How to report the prevention program for a process depends on how many units the process
contains and whether the prevention program applies different safeguards to different units in
the process. The RMP rule broadly defines "process" to include interconnected or co-located
production and storage units. Under the definition, multiple units and, in some cases, whole
sources may be a single "process" for purposes of the RMP rule. For multiple unit processes,
EPA recognizes that prevention program implementation may involve different safeguards for
different units in the process. For example, different production units may have different
operating procedures. At the same time, some safeguards, such as management of change
procedures, may apply to all the units in the process.
If your process consists of two or more units and different safeguards apply to different units in
that process, you can report the prevention program for that process in one of the two
following ways. You must, however, use one of the two ways to report your program.
Use the description field in the prevention program to describe in narrative form how your
prevention program is implemented with respect to the different units in the process. You
could start by listing the common prevention program elements you implement for all of the
units (e.g., use of an alarm system or standard management of change procedures). You would
then indicate what additional prevention program elements you employ for specified units
(e.g., use of a dike for certain process units).
Report your prevention program for the process on a unit-by-unit basis by filling out the
prevention program portion of the RMP for every unit in the process, rather than for the
process as a whole. That way, the differences in the program as it relates to each unit will be
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clear from the report. However, as noted above, some aspects of a prevention program may be
common to all units. To complete the prevention program record for each unit, enter the
remaining data which is unique to each.
If your process consists of only one unit, or you apply every element of your prevention
program to all the units in the process, you are not required to complete the description
section of this portion of the RMP or report on a unit-by-unit basis. However, you may use the
description field to elaborate on your prevention program.
Many prevention program data elements ask you to enter the date for the most recent "review
or revision" of a prevention program element required by Part 68. For your first RMP
submission, if you are subject to prevention program requirements only under the RMP rule (as
opposed to other federal or state laws), you should enter the date by which you completed the
prevention program element being addressed. For instance, for data element number 7.5,
"Date of most recent review or revision of operating procedures," you should enter the date by
which you met the operating procedures requirements of Section 68.69(a) of the RMP rule (if
applicable to you). Since this requirement must be met by the time your first RMP is due, you
may enter the date you complete or submit your first RMP. In the case of data element number
7.3 ("Date on which safety information was last reviewed or revised"), you should enter the
date you met the requirement of Section 68.65(a) (if applicable to you), since Section 68.65(a)
requires you to meet the requirement before you conduct the process hazard analysis for the
process.
If you are subject to prevention program requirements under other federal or state laws, you
may be in compliance with RMP prevention program requirements as a result of complying
with the other laws. Sources subject to OSHA PSM, for example, may already meet RMP
prevention program requirements for Program 3 processes, since those requirements are
nearly identical to OSHA PSM prevention program requirements. For your first RMP submission,
if you have fulfilled RMP prevention program requirements in complying with other federal or
state laws, you should enter the date you complied with the requirement or the date you last
reviewed or revised the relevant aspect of your program, whichever is later. For example, OSHA
PSM and the RMP rule both require covered sources to compile and update (under specified
circumstances) process safety information. If you previously compiled the information for
purposes of complying with OSHA PSM and you have not updated it since, you should enter the
date you compiled it for OSHA in your RMP. If you have updated the information since
compiling it, you should enter the date of the update.
For subsequent RMP submissions, you should enter the date by which you completed any
reviewer revision of a prevention program element. Several prevention program elements
must be reviewed and, if necessary, revised following a change affecting the process (see, e.g.,
requirement to update safety information in Section 68.75(d)). Under the compliance audit
requirement of Sections 68.58 or 68.79 of the RMP Program, all prevention program elements
must be reviewed and, if appropriate, revised every three years. When you re-submit your next
RMP (due every 5 years or sooner based on the requirements in Section 68.190), you are
required to fully update and certify all nine sections of the RMP. If, by the time you re-submit,
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you have reviewed or revised one or more prevention program elements as a result of a change
or an audit, you must enter the date of your review or revision.
Complete this section for each prevention program you report for a Program 2 process.
Prevention Program Description:
If different safeguards apply to different units in your process, use this field to explain how the
prevention program for the process relates to the different units in the process. For example:
"This process includes three interconnected production units, A, B, and C. Everything in
this prevention program applies to all three units, with the following exceptions:
• The dates of the PHA, which are 01/02/08, 6/5/07 and 4/3/07 for units A, B and C,
respectively.
• Production unit A uses only a scrubber as a process control, while units B and C have
relief valves and scrubbers.
• The water curtain indicated as a mitigation measure applies only to production unit C."
If you have so many "exceptions" that it gets too complicated to explain as above, but you still
have many common data elements, you can report your prevention program on a unit-by-unit
basis. To complete the prevention program record for each unit, provide the remaining data
which is unique to each.
EPA Facility ID: 100000215689
Transaction Type: Resubmissioi
Are you claiming Confidential Business Information (CBI) in this Section?
Prevention Program Description:
1. NAICS Code for process:"
8.2. Chemicals: *
a.3. Safety information
3.3.a. Date on which the safety information was last reviewed or revised: *
83.D.1. NFPA 58 (or st!
NFPA 58):
B.S.b.4. ANSI Standards
83b2 OSHA(29CFR 1910 111)
ANSME Standards
| 8.3.b. Federal/State regulations or industry-specific design codes and standards used to demonstrate compliance with safety information reguirement (must select at least one)
8.3 b 3 ASTM Standards
8.3.b.6. Nona
8.1 NAICS code for the process:
Provide the NAICS code that most closely corresponds to the process; it will not necessarily be
the same NAICS code as your facility as a whole. The NAICS code that you choose must be one
that you've already entered in the Section 1. Registration for the covered process.
RMP*eSubmit contains a list of the NAICS codes that you have already entered for your
registered processes as a list for this data element.
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8.2 Chemicals:
For each prevention program, provide the names of all regulated substances held above the
threshold in the covered units. If you have an NFPA-4 flammable mixture containing regulated
flammables, you may list it as a "flammable mixture." You do not need to list the individual
substances in the flammable mixture.
8.3 Safety information:
a. The date that you most recently reviewed or revised the safety information:
For your first RMP, provide the date by which you complied with the safety information
requirements of 40 CFR 68.48(a) (compile safety information) for the process. For
subsequent RMPs, provide the date the information was most recently reviewed or
revised. Safety information may be reviewed or revised as a result of, among other
things, a major change to the process (see Section 68.48(c)) or a periodic audit of the
prevention program (see Section 68.58(a)). If the safety information was not reviewed
or revised since the previous RMP was submitted, retain the date provided in the
previous RMP.
b. Federal or state regulations or industry-specific design codes and standards used
to demonstrate compliance with the safety information requirement (select at
least one):
Are you subject to any of the following federal or state regulations? Do you use any of
the following industry-specific design codes and standards to demonstrate compliance
with the safety information requirement? If none are applicable, check None.
b.1. NFPA 58 (or state law based on NFPA 58):
NFPA stands for National Fire Protection Association; NFPA 58 is a propane (LP
gas) handling code. Note that state propane laws are generally based on NFPA
58. Select NFPA 58 if your process is subject to a state or local law based on
NFPA 58 or if you follow NFPA 58 in any event.
b.2. OSHA (29 CFR 1910.111):
OSHA's rule for operations handling anhydrous ammonia, select 29 CFR
1910.111 if your process is subject to this rule.
b.3. ASTM Standards:
Select this if you follow American Society of Testing Materials standards. ASTM
establishes standards for materials, products, systems, test methods,
specifications, classifications, definitions, and recommended practices.
b.4. ANSI Standards:
Select this if you follow American National Standards Institute standards. ANSI
nationally coordinates voluntary standards. ANSI standards cover areas such as
definitions, terminology, symbols, and abbreviations; materials, performance
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characteristics, procedure, and methods of rating; methods of testing and
analysis; size, weight, and volume, safety, health, and building construction.
b.5. ASME Standards:
Select this if you follow American Society of Mechanical Engineers standards.
ASME conducts research and develops boiler, pressure vessel, and power test
codes. It also develops safety codes and standards for equipment.
b.6. None:
If your facility does not apply to the Program 2 process any national standards
such as those noted above, and is not subject to any federal or state rules or
laws such as those noted above, select None.
b.7. Other (specify):
If you apply any other standards to your process safety equipment, select Other
and specify the standards you apply. Some examples of other standards include
the National Electrical Manufacturers Association (NEMA) standards and the
American Petroleum Institute (API) standards. There may also be other codes
that apply.
b.8. Comments:
In this section, please explain how federal, state, or local regulations or industry-
specific design codes and standards are being used to demonstrate compliance
with the safety information requirement.
I 8.4. Hazard review
8 4 a Date of completion of most recent hazard review or update *
8.4.b. Expected or actual date of completion of all changes resulting from the hazard review:
01/31/2014
03I3H2014 ^\ •
8.4.C. Major hazards identified (must select at least one) * ^*"
8 4 c 1. Toxic release
8.4. C-4. Runaway reaction:
8.4. c. 7. Corrosion:
8.4. c. 10. Equipment failure
84 c 13 Floods
8 4 c 16 Other (specify):
tfl 8.4. c. 2. Fire:
8-4-C-5. Polymerization
D 8.4. c. 8. Overfilling:
31 8.4. c. 11 Loss of cooling heating
electricity, instrument air:
g 8.4. c. 14. Tornado
D B 4 c 3 Explosion U
8 4.c 6 Over pressurization
8 8-4-C-9. Contamination: D
B B.4.C 12 Earthquake
D 8.4.C 15 Hurricanes B
8.4, d, Process controls in use (must select at least one) *
84 d 1. Vents:
8.4. d-4. Scrubbers:
8.4. d-7. Automatic shutoffs
84d-10. Keyed bypass:
8 4 d 13 Backup pump
84d 16. Rupture disks:
8 4.d.19. Purge system:
8 4 d 21 Other (specify):
8 4.d.2. Relief valves:
B.4.d.5. Flares:
D 8 .4.d.B. Interlocks:
8.4.d-1l Emergency air supply:
B 8.4. d. 14. Grounding equipment
D 8.4. d. 17. Excess flow device:
B 8.4.d.20. None:
B 8. 4. d. 3. Check valves: D
B.4.d.6. Manual shutoffs: B
8.4-d 9. Alarms and procedures: B
B 8 4 d 12 Emergency power: B
D 8.4. d 15 Inhibitor additions:
D B.4.d.18. Quench system:
8.4 Hazard review:
The hazard review requirements for Program 2 processes can be found at 40 CFR 68.50.
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a. The date of completion of the most recent hazard review or update:
Provide the date of completion of the most recent hazard review or update (must be
within the five years prior to submission of the RMP).
b. The expected or actual date of completion of all changes resulting from the hazard
review:
This may be left blank if there were no changes.
c. Major hazards identified:
Provide all major hazards that were identified for the Program 2 process or part of the
process at your facility as a result of the hazard review. Major hazards are described in
7.4 d.
d. Process controls in use:
Provide all process controls used on this Program 2 process or part of the process.
Process controls are equipment and associated procedures used to prevent or limit
releases. If none are applicable, check None. Process controls are described in 7.4 e.
8.4.e. Mitigation systems in use (must select at least one) *
8-4-6-1 Sprinkler system: 8.4 e.2. Dikes:
8-4-eA Blast walls:
8.4 e.7. Enclosure:
8.4 e. 10. Other (specify):
8.4.e.5. Deluge system:
8-4 6-8 Neutralization:
8-4-6-3. Fire walls:
8-4-e-6-Water curtain:
8 4 e-9 None:
8.4.f. Monitoring/detection systems in use (must select at least one) *
8.4.f.1. Process area detectors: ® 8.4.f.2. Perimeter monitors:
84f4 Other (specify):
I 8.4.g. Changes since last hazard review or hazard update (must select at least one) *
8 4 g 1 Reduction in chemical inventory 8 4 g 2 Increase in chemical inventory
f: 4 "i '• Ir-ts atir:1] cf :iGi:~S'E. -|Htsrtinn
8-4-9-4- Installation of process controls: w
8.4.g.8. None recommended:
8 4 g 10 Other (specify)
84 g 7 Installation of mitigation
systems:
8 4 g 3 Change in process parameters
8 4.g.6 Installation of perimeter ,
monitoring systems:
8.4.g.9 None: D
I 8.5. Date of most recent review or revision of operating procedures: *
e. Mitigation systems in use:
Provide all mitigation systems you have in place to control a release should one occur
from this Program 2 process or part of the process. Mitigation systems are described in
7.4 f. If none are applicable, check None.
f. Monitoring/detection systems in use:
Provide all monitoring and detection systems installed to detect a release of a regulated
substance from the Program 2 process or part of the process. Monitoring and detection
systems are described in 7.4 g. If none are applicable, check None.
g. Changes since last hazard review or hazard review update:
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Provide all changes made to the process or part of the process since the last hazard
review. Hazard review changes are described in 7.4 h. If none are applicable, check
None.
8.5 Date of most recent review or revision of operating procedures:
The operating procedures requirements for Program 2 processes can be found in the RMP
regulation at 40 CFR 68.52. For your first RMP, provide the date by which you complied with the
requirements of Section 68.52(a) (prepare written procedures) for the process. For subsequent
RMPs, provide the date of the most recent reviewer revision of the operating procedures.
Operating procedures may be reviewed or revised as a result of, among other things, a major
change to the process (see Section 68.52(c)) or a periodic audit of the prevention program (see
Section 68.58(a)).(See Chapter 7 of the General Guidance for Risk Management Programs for a
discussion of what constitutes a major change.) If the operating procedures were not reviewed or
revised since the previous RMP was submitted, retain the date provided in the previous RMP.
| 8.6. Training
B 6 a Date of most recent review or revision of training programs: *
8 6 b Type of training provided (must select at least one) *
8 6.b.1. Classroom: S 8.6.b 2 On the job:
8-6 b.3 Other (specify):
02/28/2014
8.6.C. Type of competency testing used (must select at least one) *
8 6 c 1 Written test 8.6 c 2- Oral test
8.6.C.4. Observation S) 8.6.C.5. Other (specify):
8.7. Maintenance
8 7 a Date of most recent review or revision of maintenance procedures *
8 7 b Date of most recent equipment inspection or test *
8.7.C. Equipment most recently inspected or tested (equipment list): *
8.8. Compliance audits
8 8 a Date of most recent compliance audits
8.8 b Expected or actual date of completion of all changes resulting from the most recent compliance
audits:
8.9. Incident investigation
8 9 a Date of most recent incident investigation (if any)
8 9.b. Expected or actual date of completion of all changes resulting from the incident investigation.
8.10. Date of most recent change that triggered a review or a revision of safety information, the
hazard review, operating or maintenance procedures, or training:
8-6 c 3- Demonstration
03/03/2014
03/03/2014
see equipment list for process
'02/06/2014
•03/31/2014
An •"denotes critical or mandatory information.
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8.6 Training:
Training requirements for Program 2 processes can be found at 40 CFR 68.54.
a. Date of most recent review or revision of training programs:
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For your first RMP, provide the date by which you ensured that the training you provide
the employees operating the process meets the requirements of Section 68.54 (a). For
subsequent RMPs, provide the date of the most recent review or revision of the training
you provide. Training programs may be reviewed or revised as a result of, among other
things, a change to the process (see 40 CFR 68.54 (d) (c)) or a periodic audit of the
prevention program (see 40 CFR 68.58 (a)). If the training was not reviewed or revised
since the previous RMP was submitted, retain the date provided in the previous RMP.
b. Type of training provided:
Select the type of training provided (select all that apply).
1. Classroom
2. On the job
3. Other (specify)
c. Type of competency testing used:
Indicate the type of competency test used. Competency tests are used to determine and
evaluate comprehension of the training materials. Training information can be found in
the RMP regulation at 40 CFR 68.54 and 68.71.
1. Written test
2. Oral test
3. Demonstration
4. Observation
5. Other (specify)
8.7 Main ten an ce:
a. The date that you most recently reviewed or revised the maintenance procedures:
For your first RMP, provide the date by which you complied with the requirements of
Section 68.56 (a) (establish and implement written maintenance procedures) for the
process. For subsequent RMPs, provide the date of the most recent review or revision of
the maintenance procedures. Maintenance procedures may be reviewed or revised as a
result of, among other things, a change to the process (see Section 68.56(a)) or a
periodic audit of the prevention program (see Section 68.58(a)). If the procedures were
not reviewed or revised since the previous RMP was submitted, retain the date provided
in the previous RMP.
b. The date of the most recent equipment inspection or test:
Provide the appropriate date. Maintenance information can be found in the RMP
regulation at 40 CFR 68.56 and 68.73.
c. The equipment most recently inspected or tested (list equipment):
Specify the equipment inspected or tested. Maintenance information can be found in
the RMP regulation at 40 CFR 68.56 and 68.73.
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8.8 Compliance audits:
Maintenance requirements for Program 2 processes can be found at 40 CFR 68.58. If you have
not conducted a compliance audit prior to your first submission, leave these fields blank.
a. The date of your most recent compliance audit:
Provide the date of your most recent compliance audit.
NOTE: A compliance audit is required every three years. Compliance audit information
can be found in the RMP regulation at 40 CFR 68.58 and 68.79.
b. The expected or actual date of completion of all changes resulting from the
compliance audit:
Provide the expected or actual date of completion of all changes resulting from
compliance audit. This may be left blank if there were no changes or all changes are
complete. Incident Investigation information can be found in the RMP regulation at 40
CFR 68.60 and 68.81.
8.9 Incident investigation:
Maintenance requirements for Program 2 processes can be found at 40 CFR 68.60.
a. The date of your most recent incident investigation (if any):
Provide the date of your most recent incident investigation. Incident investigation (if
any) can be found in the RMP regulation at 40 CFR 68.60. If you have not had an
incident investigation, leave this field blank.
b. The expected or actual date of completion of all changes resulting from the
incident investigation:
Provide the expected or actual date or completion of all changes resulting from the
incident investigation. This may be left blank if there were no changes or all changes are
complete. Incident Investigation information can be found in the RMP regulation at 40
CFR 68.60 and 68.81.
8.10 Date of most recent change that triggered review or revision:
Provide the date of most recent change that triggered review or revision of safety information,
the operating or maintenance procedures, or training. This may be left blank if there were no
changes.
Section 9: Emergency Response
The extent to which you need to fill out this portion of the RMP depends on whether your
employees will respond to releases of regulated substances at your facility. Under Section
68.90(b), if your employees will not respond to releases, you are not required to comply with
the requirements for an emergency response program provided you meet the following
criteria:
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1. If you hold one or more regulated toxic substances over threshold quantities, your
facility must be included in the community emergency response plan developed
under the Emergency Planning and Community Right-to-Know Act (EPCRA);
2. If you hold only one or more regulated flammable substances over threshold
quantities, you must have coordinated response actions with the local fire
department; and
3. You must have appropriate mechanisms in place to notify emergency responders
when there is a need for a response.
If your employees will respond to releases of regulated substances at your facility, you
are subject to Section 68.95 and must fill out all the data items in this section of the
RMP. If your employees do not respond to releases of regulated substances at your
facility, you need only respond to the first two (9.1 a and 9.1 b) and last three (9.7 a, 9.7
b and 9.8) emergency response data elements.
Complete this section once for all covered processes.
The following is a discussion of each element in Section 9. Emergency Response.
EPA Facility ID: 100000215689
Transaction Type: Resubmission
9.1. Written emergency response (ER) plan
9.1.a. Is your facility included in the written community emergency response plan? "
9 1 b Does your facility have its own written emergency response plan? *
9.2. Does your facility's ER plan include specific actions to be taken in response to accidental releases of regulated
substances? "
9.3. Does your facility's ER plan include procedures for informing the public and local agencies responding to accidental
releases? "
9.4. Does your facility s ER plan include information on emergency health care?
9.5. Date of most recent review or update of your facility's ER plan? *
9.6. Date of most recent ER training for your facility's employees? *
9.7. Local agency with which your facility's ER plan or response activities are coordinated:
9 7 a. Name of agency: *
9.7 b. Phone Number "
9.8. Subject to (select all that apply): '
9 8.a. OSHA Regulations at 29 CFR 1910.38:
9.8.b. OSHA Regulations at 29 CFR 1910.120.
9 8.C Clean Water Act Regulations at 40 CFR 112:
9.8.d RCRA Regulations at 40 CFR 264. 265. 279 52:
9 8 e OPA-90 Regulations at 40 CFR 112. 33 CFR 154 49 CFR 194. 30 CFR 254:
9 3 f. State EPCRA Rules or Laws:
Ch.ail~ston Co. Environmental Health
843 - 567 - 8901
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A icon denotes a f eld that can ce claimed as Confidential Business Information (CBI:. Click H~f? for more information on how to submit CB claims
9.1 Written emergency response (ER) plan:
a. Is your facility included in the community emergency response plan?
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If your facility is subject to part 68 because it has one or more regulated toxic
substances above threshold quantities, it is probably included in a local emergency
response plan under the Emergency Planning and Community Right-to-Know Act
(EPCRA). Under Section 303 of EPCRA, local emergency planning committees (LEPCs)
must prepare an emergency response plan for facilities in their planning district having
toxic substances listed under EPCRA 302 in excess of the threshold planning quantity
established under that section. Most of the toxic substances listed in Part 68 are also
listed under EPCRA 302, and the EPCRA thresholds for those substances are generally
the same or lower than the Part 68 thresholds for the same substances. Consequently,
Part 68 facilities with toxic substances listed under both EPCRA and Part 68 should be
included in community emergency response plans.
In addition, facilities subject to Part 68 as a result of flammable substances may also be
covered by community emergency response plans, since LEPCs can, and sometimes do,
include other hazardous substances, including flammables, in their plans. If you are not
sure whether your facility is included in your community's local emergency plan, check
with your LEPC.
As noted above, if your employees are not going to respond to releases of regulated
substances at your facility and you have one or more Part 68 regulated toxic substances
over threshold quantities, your facility must be included in the local emergency
response place under EPCRA. Click the check box for this question if your facility is
included in the community's emergency response plan.
b. Does your facility have its own written emergency response plan?
Click the check box for this question if you have a response plan (not just an emergency
action plan as required by OSHA under 29 CFR 1910.38).
9.2 Does your facility's ER plan include specific actions to be taken in response to
accidental releases of regulated substances?
These data elements (9.2, 9.3, 9.4) reflect the three mandatory components of the emergency
response plan required under Section 68.95(a)(l). For an emergency response plan to be in
compliance with this requirement, you must be able to answer "yes" to each of these
questions. Click the check box for this question if your facility's ER plan includes specific actions
to be taken in response to accidental releases of regulated substance(s).
9.3 Does your facility's ER plan include procedures for informing the public and local
agencies responding to accidental releases?
Click the check box for this question if your facility's ER plan includes procedures for informing
the public and local agencies responding to accidental releases.
9.4 Does your facility's ER plan include information on emergency health care?
Click the check box for this field to respond with "yes" to each of this question.
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9.5 Date of most recent review or update of your facility's ER plan:
Provide the date on which you most recently reviewed or updated your plan. Section
68.95(a)(4) requires that ER plans be reviewed and updated "as appropriate" to reflect changes
at the facility and to ensure that employees are informed of changes.
9.6 Date of the most recent ER training for your facility's employees:
Provide the date of the most recent emergency response training at your facility. Emergency
response training includes drills involving your personnel with or without outside emergency
response agencies and tabletop exercises of your emergency response plan. Single purpose
drills (e.g., alarm system drills) may be listed, but exercises that test more aspects of the plan
are preferable.
Part 68 does not specify a schedule for conducting employee response training. You should not,
however, that other planning requirements (e.g., HAZWOPER) may establish a more formal
schedule for conducting training (e.g., eight hours of annual refresher training.)
9.7 Local agency with which your facility's ER plan or response actions are
coordinated:
If you have an ER plan, indicate the name and phone number of the agency with whom you
have coordinated your plan. Section 68.95(c) requires that a facility's ER plan be coordinated
with the community emergency response plan under EPCRA for the facility's community. The
LEPC for the facility's community will typically be the agency with which ER plans are
coordinated.
If you do not have an ER plan, indicate the agency with which you have coordinated response
activities. As noted above, section 68.90(b) provides that if you have regulated toxic substances
and your employees will not be responding to releases of those substances, your facility must
be included in the community emergency response plan developed by the LEPC for your
community. If that is the case for your facility, indicate the name and phone number of your
LEPC here. If you have only regulated flammable substances and your employees will not be
responding to releases of those substances, you must have coordinated response actions with
the local fire department. If that is case for your facility, indicate the name and phone number
of your local fire department here.
a. Name of agency:
If you have an ER plan, provide the name of the agency with whom you have
coordinated your plan.
b. Phone number:
If you have an ER plan, provide the phone number of the agency with whom you have
coordinated your plan.
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9.8 Subject to (select all that apply):
Indicate all of the federal and state emergency response regulations or statutes to which your
facility is subject. Select at least one. All RMP facilities are subject to OSHA emergency planning
requirements at 29 CFR 1910.38 or 29 CFR 1910.120.
a. OSHA Regulations at 29 CFR 1910.38. These are OSHA's Emergency Action Plan
regulations. All RMP facilities are subject to either these OSHA regulations or OSHA
regulations at 29 CFR 1910.120.
b. OSHA Regulations at 29 CFR 1910.120. These are OSHA's Hazardous Waste
Operations and Emergency Response (HAZWOPER) Plan regulations. All RMP
facilities are subject to either these OSHA regulations or OSHA regulations at 29 CFR
1910.38.
c. Clean Water Act Regulations at 40 CFR 112. These are EPA's Oil Spill Prevention
Control and Countermeasures (SPCC) regulations under the Clean Water Act.
d. RCRA Regulations at 40 CFR 264, 265, and 279.52. These are EPA's permitting
regulations for solid waste under the Resource Conservation and Recovery Act
(RCRA).
e. OPA 90 Regulations at 40 CFR 112, 33 CFR 154, 49 CFR 194, or 30 CFR 254. These
are EPA, U.S. Coast Guard, Department of Transportation, and Department of the
Interior facility response plan regulations under the Oil Pollution Act of 1990 (OPA
90).
f. State EPCRA Rules or Laws. These are state emergency planning and community
right-to-know (EPCRA) laws. Federal EPCRA does not require facility response plans,
but some state laws may.
g. Other. Specify any other emergency response regulations or laws to which your
facility is subject.
Executive Summary
The Executive Summary must include a brief description of your facility's risk management
program. You determine the length; it may be as short as two or three pages or, if you have
many processes, it may need to be longer. You should view the Executive Summary as an
opportunity to communicate in your own words the nature of the risks posed by your facility to
your community and to explain what you have done to minimize those risks. The summary can
be an excellent vehicle to display the effort and resources your facility has put into its accident
prevention program. Your Executive Summary cannot be claimed as CBI. Do not include any CBI
data in your Executive Summary.
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Section 9. Emergency Response
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The following is a discussion of each element in Executive Summary.
The Executive Summary must briefly describe the following elements:
The accidental release prevention and emergency response policies at your facility
Describe your facility's overall approach to chemical safety. You may want to include any
corporate policies (if applicable) and an overview of senior management commitment to safety
and implementation of safe procedures.
Your facility and the regulated substances handled
Provide a description of your facility so that the public has a clear picture of the facility, its
processes, and products. Describe the primary activities at the facility (e.g., manufacturer of
polyethylene, pulp mill, etc.) and the regulated substances used. In addition, you may want to
mention the quantities of these substances handled or stored at your facility.
The general accidental release prevention program and chemical-specific prevention steps
You may wish to mention the rules and regulations with which your facility complies, such as
the OSHA PSM rule. You should also highlight practices that you believe are important to your
prevention program. The steps you list may be either technological (e.g., backup systems) or
procedural/managerial (e.g., improved maintenance or training).
The five-year accident history
Do not present accident history information in table form here; more details will be provided in
the data elements. This should be a written summary; for example,
"We have had five accidental releases of chlorine in the past five years; the largest
release was 1,500 pounds. No one offsite was injured, but several houses were
evacuated as a precautionary measure during the October 2005 and May 2006
releases."
The emergency response program
Briefly describe the elements of your response program. These may include coordination with
local emergency responders, training received by personnel, drills conducted by your facility,
public notification and alert systems, as appropriate.
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Planned changes to improve safety
List any upcoming events, such as training, installation of new mitigation or control equipment
or technology, organizational changes, etc., that will improve safety at your facility.
NOTE: A summary of the off-site consequence analysis (OCA) for the worst-case and
alternative release scenarios(s) is no longer required to be included in the Executive
Summary. While the RMP rule originally required that the Executive Summary briefly
describe the OCA for worst-case and alternative release scenario(s), EPA amended the
RMP rule in 2004 to remove this requirement because of security concerns. Your
Executive Summary should not describe nor include information concerning your worst
case or alternative release scenarios.
After you have finished entering your Executive Summary, click the Save and Return button.
This will take you back to the RMP*eSubmit Section Selection page.
View RMP. Validate. Submit to Certify
At the bottom of the RMP*eSubmit Section Selection page, click the Validate button to view
and adjust errors to your RMP before submitting it for the Certifying Official for review. Once
any errors have been addressed, you can click the Submit to Certify button to send the RMP to
the Certifying Official. Your next page should be similar to the screen shot below.
U.S. Environmental Protection Agency
RMP*eSubmit Submit to Certify
•?• Recent Announcements Contact Us
Legged in as. GEFION1:
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I EPA Facility ID:
1100000215689
Loki Chemicals
Transaction Type: First
Time Submission
I Thank you for using RMP'eSubmit Your RMP is submitted for certification Shortly an e-mail '//ill be sent to your Certifiers mailbox that your RMP
I is ready for certification
Facility ID
Facility Name
Submission Type
Reference Transaction ID
Document Name
User ID
Submit Date
100000215689
Loki Chemicals
First Time Submission
_1561aac2-ed704ad9-a9e7-dGOG5d3e8504
RMP000120130801171255GEFION13.zip
GEFION13
03/01/2013 17 13 05
Return to RHP*eSubmit Home
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CHAPTER 3 HOW TO SUBMIT YOUR RMP
Certifying a Submission in RMP*eSubmit
After the Preparer has prepared and submitted the RMP to the Certifying Official, the Certifying
Official (Certifier) approves the RMP by certifying and submitting to EPA.
WARNING! Your RMP has not been officially submitted to EPA until it has been
certified and submitted by the Certifying Official. Please be sure to take the step of
certifying your RMP. A confirmation email will be sent to acknowledge the
submission.
Note to Preparer/Certifier: If you have the roles of both Preparer and Certifier,
please be sure to take the step beyond submitting to Certifier. You, as the
Certifying Official, must certify the submission.
The Certifier may reject and send the RMP back to the Preparer for possible corrections.
An automated email will be sent to the Certifier and the Preparer. This email is a notification
that a submission has been made by the Preparer and is ready for review and submission to
EPA by the Certifier. The Certifier's MyCDX "Certify Submission" link will show a list of Pending
Submissions to be certified.
U.S, Environmental Protection Agency
Logged in as. JF'NRI.IPESUBI.IIT
:_ _ > Submissions
Pending Submissions
Here is a list of RMP submissions that nave been prepared tor you to certify and send to EP+. Please review the information in these
submissions, by clicking a File ID link, and certify the submissions.
Submitter
Jacob Noble
(JPNRMPESUBMIT;
Facility ID COX ID/File ID
Calhoun County Water Filtration RMP00012009fJ306174840JPNRI.IPESUBI.IIT
Plant (1000 0003 29751
Non-Pending Submissions
Here is a list of RI.IP submissions that have been acted on by you. Click a File ID link to see the PDF of the submission. Click a Status link to
see the receipt page of a submission.
Submitter
Jacob Noble
1JPNRMPESUBMIT]
Facility ID CDX ID/File ID Status
Calhoun County Water Filtration RMP000120030306173146JPNRI.IPESUBMIT certified
Plant (1000 00032975!
i our C D • account is associated /:ith ons o rncrs Facilities 1C E
Facility ID
1000 00032976
1000 00139094
Facility Name
Calhoun County Water Filtration Plant
Woodland Biomass Power Ltd
View Currently Approved RMP
evv Current RLIP
/ieiv Current RI.IF
The Certifier can login to/WyCDXand either (a) Certify or (b) Reject a submitted RMP. The
Certifier may also review a previously submitted, certified, and approved RMP for which the
Certifier has authorized access.
If the submission is rejected, an email will be sent to the Preparer to make necessary
corrections before they submit the RMP again to the Certifier for certification and submission.
The Certifier has the option to select and review a copy of the previously submitted approved
RMP for a facility by clicking the "View Current RMP" on the list of associated RMPs.
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About CDX
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Here is a list of RMP submissions that have been prepared for you to certify and send to EPA. Please review the information in these
submissions, by clicking a File ID link, and certify the submissions.
Submitter Facility ID CDX ID/File ID
Jacob Noble Calhoun County Water Filtration RMPu0012009030'51748^0JPMRMPESUBMIT Certify | Reject
i.JPNRMPESUBMIT: Plant (1000 0003 2975)
Non-Pending Submissions
Here is a list of RHP submissions that have been acted on by you. Click a File ID link to see the PDF of the submission. Click a Status link to
seethe receipt page of a submission.
Jacob Noble Calhoun County Water Filtration RMP000120090306173146JPMRI.IPESUBMIT Certified
gPMRMPESUBMIT) Plant (1000 0003 2975)
Facilities
Your CDX account is associated with one or more Facilities IDs:
Facility ID
1000 0003 2975
1000 0013 9094
Facility Name
Calhoun County Water Filtration Plant
Woodland Biomass Power Ltd
View Currently Approved RMP
view Current RMP
view Current RMP
The RMP selected to be viewed will be in PDF format. See the example below.
Section 1. Registration Information
1.1 Source Identification
1.1. a. Facility Name
l.l.b. Parent Company #1 Name
l.l.e. Parent Company #2 Name
1.2 EPA Facility Identifier
1.3 Other EPA Systems Facility Identifier
Calhoun County Water Filtration Plant
Calhoun County Water Authority
100000032975
1.4 Dun and Bradstreet Numbers (DUNS)
1.4.a. Facility DUNS
1.4.b. Parent Company #1 DUNS
1.4.e. Parent Company #2 DUNS
1.5 Facility Location
l.S.a. Street • Line 1
l.S.b. Street -Line 2
l.S.c. City
l.S.d. State
l.S.e. Zip Code • Zip +4 Code
l.S.f. County
l.S.g. Facility Latitude (in decimal degrees)
l.S.h. Facility Longitude [in decimal degrees)
l.S.i. Method for determining Lat/Long
l.S.j. Description of location identified by Lat/Long
1.5, k. Horizontal Accuracy Measure (meters)
1.5.1. Horizontal Reference Datum Code
l.S.m. Source Map Scale Number
630 Smith Boozer Road
Well in? ton
AL
36279-5829
CALHOUN
33.864630
-085.883850
Interpolation - Map
Center of Facility
25
World Geodetic System of 1984
1
1.6 Owner or Operator
If the Certifier accepts and proceeds with the submission, the Certifier will follow the next
process to electronically sign the certification statement.
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Certification Statement (Part 1)
Certification Statement for Program 1 Processes):
Based on the criteria in 40 CFR S3 10 the distance to the specified endpoint for the
worst-case accidental release scenario for the following processies; is less than the
distance to the nearest public receptor
Within the past five years the process (es; has [have; had no accidental release
that caused offsite impacts provided in the risk management program rule (40 CFR
1Q(b){1]j No additional measures are necessary to prevent offsite impacts from
accidental releases In the event of fire explosion or a release of a regulated
substance from the process(es). entry within the distance to the specified endpoints
ay pose a danger to public emergency responders Therefore public emergency
Certification Statement (Part 2)
Certmers name and title
Mr Jacob Noble
Business Manager
Facility Name with complete location address
Calhoun County Water Filtration Plant
630 Smith Boozer Road
igtonAL 36279
EPA Facility ID 100000032975
Certification signed date 3/6/2009
Certifiers E-mail jnoble2@csc.com
Click the "Accept" button to complete certification, or click the "Decline" button.
Authentication of CDX Credentials
Enter your CDX password to authenticate the submission and click "Login".
1. Login into CDX
User:
3PNRMPESUBMIT
Password:
Re-authentication of CDX Credentials
Now the user will be challenged with 1 of the 5 questions and answers in the registration
process. This step will re-authenticate your CDX credentials. Answer the question, then click the
"Answer" button.
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1. Login into CDX
User:
JPNRMPESUBMIT
Password:
2. Answer Secret Question
Question:
Where did you first meet your spouse?
Answer:
Electronic Signature
Click the "Sign" button to submit your RMP.
eSignature
1. Login into CDX
User:
JPNRMPESUBMIT
Password:
Welcome Jacob Noble
2. Answer Secret Question
Question;
Where did you first meet your spouse?
Answer:
3. Sign File
I Sign I
church
Correct Answer
The Certifier will see the following screen as an acknowledgement for the submission.
About CDX
MyCDX
Inbox
Change Password
Frequently Asked
Questions
Help & Support
CDX Home
Terms & Conditions
Logout
Logged in as. JPNRI.IPESUBMIT.
| I.I.CD.-. > oil I: missions > Confirm and Sign Submission > Submission Certified
Submission Certified
Shown below is the RMP submission that you have certified. To view the submission, please select the File ID link. To view a submission
receipt clickthe Receipt link. Your submission has been digitally signed and certified.
Submitter Facility ID CDX ID/File ID
Jacob Noble (JPNRMPESUBHITj Calhoun County Water Filtration Plant (1000 RMP00012009030'5173U6JPNRI.IPESUBI.IITReceipt
0003 2975)
Return I
You are En an encrypted secure session.
Help Desk: (888; 890-1995
EPA Home I Pri.ac. an;! Sicunt, notice I Contact Us
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CHAPTER 4 SUBMITTING CONFIDENTIAL BUSINESS
INFORMATION AND PAPER RMPS
Confidential Business Information
On January 6,1999, EPA published a final rule in the Federal Register specifying which RMP
data elements may not be claimed as confidential business information (CBI) and the
procedures which must be followed to claim information as CBI. The regulatory provisions
(Sections 68.151 and 68.152), provide that if you claim any RMP information as CBI, you must
submit to EPA a sanitized RMP, a Substantiation Form (for explaining why you believe the
information meets the criteria for CBI), and an Unsanitized Data Elements Form (on paper only)
(see Appendices C and D for forms). The sanitized (also known as redacted) RMP should not
include any confidential business information. If you must claim any CBI in your RMP, click the
button after the question "Are you claiming Confidential Business Information (CBI) in this
Section?" at the top of each section. Please read the pop-up Warning Message.
U.S. Environmental Protection Agency
RMP*eSubmit Section 2. Toxics: Worst Case
lEPA Facility ID: 100000215689
Loki Chemicals
Transaction Type: Resubmission
Are you claiming Confidential Business Information (CBI) in this Section? [v]
2.1. Chemical
Process Name
2.2. Physical state: " ^
2.3. Model Used: *
2.3.a. EPA's OCA Guidance Reference T;
2.3. b. EPA's RMP Guidance for Ammonic
2.3.c EPAs RMP Guidance for Waste W
2.3-d. EPA's RMP Guidance for Warehou
2.3.e. EPA's RMP Guidance for Chemica
2.3 f. EPA's RMP*Comp(TM)
2.3.g Areal Locations of Hazardous Atmc
2.3-h. Other model name (Specify}
ModeJ Used Text (if Other):
2.4. Scenario: *
2.5. Quantity released (Ibs): * ^
Message from web page
® WARNING!!
You have chosen to submit Confidential Business Information (CBI).
If this is correct you are required to submit the following with your
RMP:
Claiming CBI does not indicate or imply that all data in this section is
CBI data.
Are you sure want to claim CBI in this section?
IMPORTANT: If you want to claim a field as CBI, you must leave the CBI
field blank.
If you enter data in the CBI field then that field will not be claimed as
CBI and the
OK Cancel
Refridge ration
Ammonia (anhydrous)
Gas liquified by pressure T
•:
•
.«
.
Liquid spill and vaporization •*
160DO
I 2.6. Release rate (Ibs/minute):
.am
For additional information, contact the RMP Reporting Center.
Submitting Paper RMPs
If you are unable to submit your RMP online, use Appendix A: Risk Management Plan Form in
this manual or call the RMP Reporting Center for assistance.
ill
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
CHAPTER 5 NOTIFYING EPA THAT YOUR FACILITY IS NO
LONGER COVERED BY RMP: DE-REGISTRATION
How to De-register Your Facility
Changes may occur at your facility that make it no longer subject to the RMP regulations at 40
CFR Part 68 (e.g., you replace the regulated substances in your process with unregulated
substances.) If your facility is no longer covered by RMP, you must notify EPA as specified in
Section 68.190(c) (see box below). Note that the regulation uses the term "stationary source"
to refer to a facility.
68.190 Updates
(c) If a stationary source is no longer subject to this part, the owner or operator shall submit
a de-registration to EPA within six months indicating that the stationary source is no longer
covered.
To de-register, submit a letter to the RMP Reporting Center within six months and include the
effective date of the de-registration (the date on which your facility was no longer covered by
part 68). The letter is to be signed by the owner or operator and include your RMP ID number
(the 12-digit ID number assigned by EPA).
Use the Risk Management Program De-registration Form (Appendix E) of this manual.
If you de-register your facility and it later again becomes subject to the RMP regulation, you will
resubmit an RMP following the resubmission process. You must use the original EPA Facility ID
# to resubmit. Keep a record of your Facility ID # upon de-registering. If you have de-registered
and do not have your Facility ID #, contact the RMP Reporting Center.
Important Reminder: Remember to include the 12-digit EPA Facility Identification
number (usually beginning with 1000) that was originally assigned to your facility. The
EPA Facility ID was given to you in the notification letter you received from the RMP
Reporting Center regarding the submission status of your RMP.
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CHAPTER 6 PROPANE WITHDRAWAL FORM AND REQUEST TO
CONSOLIDATE EPA FACILITY IDS FORM
When to Uses these Forms
If you have submitted an RMP and your facility is no longer covered under 40 CFR part 68
because the facility does not have more than a threshold quantity of any regulated substance
listed at 40 CFR 68.130 other than propane (or another listed flammable substance) that is used
on site as fuel or held for sale as fuel at a retail facility (see 40 CFR 68.126), use the Propane
Facility Withdrawal Form, Appendix F.
If your facility has inadvertently been assigned more than one EPA Facility ID number, use the
Request to Consolidate EPA Facility IDs Form, Appendix G, to request the EPA Facility ID
numbers be consolidated into a single ID number. This form can also be used to de-activate
additional/incorrect EPA Facility ID numbers.
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CHAPTER 7 REPORTING CENTER CONTACT INFORMATION
ACRONYMS OF TERMS
RMP Reporting Center Contact Information
U.S. Environmental Protection Agency
Attention: RMP Reporting Center
P.O. Box 10162
Fairfax, VA 22038
For courier and overnight delivery packages, use the address below:
RMP Reporting Center
c/o CGI Federal, Inc.
12601 Fair Lakes Circle
Fairfax, VA 22033
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Acronyms of Terms
ANSI American National Standards Institute Standards
ASTM American Society of Testing Materials Standards
AUTHCODE Authorization Code
BLEVE Boiling Liquid Expanding Vapor
CAA Clean Air Act
CAS Chemical Abstracts Service Registry Number
CBI Confidential Business Information
CDX Central Data Exchange
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
DUNS Data Universal Numbering System
EHS Extremely Hazardous Substance
EPA Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
ESA Electronic Signature Agreement
Fll Facility Identification Number
CIS Geographic Information System
GPS Global Positioning System
HAZWOPER Hazardous Waste Operations and Emergency Response
LEPC Local Emergency Planning Committee
MSDS Material Safety Data Sheet
NAD North American Datum
NAICS North American Industrial Classification System
NCDC National Climatic Data Center
NFPA National Fire Protection Association
OCA Offsite Consequence Analysis
OPA Oil Pollution Act
OSHA Occupational Safety and Health Administration
PHA Process Hazard Analysis
PIN Personal Identification Number
POTWs Publicly Owner Treatment Works
PSM Process Safety Management
RCRA Resource Conservation and Recovery Act
RMP Risk Management Plan
TRI Toxic Release Act
UIN Unique Identification Number
WGS World Geodetic System
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APPENDICES
Appendix A. Risk Management Plan Form A-l
Appendix B. Sample Certification Letters B-l
Appendix C. CBI Substantiation Form C-l
Appendix D. CBI Unsanitized Data Element Form D-l
Appendix E. Risk Management Program De-registration Form E-l
Appendix F. Risk Management Program Propane Withdrawal Form F-l
Appendix G. Risk Management Program Request to Consolidate EPA Facility ID Numbers G-l
Appendices A-l
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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APPENDIX A. RISK MANAGEMENT PLAN FORM
Risk Management Plan Form
Section 112(r) of the Clean Air Act
Control Number 2050-0144
IMPORTANT: Type or print; read instructions before completing form.
Submission Type:
LI First-Time RMP Submission
Q Correction to the Current RMP
(Submission Type = "C")
C01 Clerical error corrected
C02 Additional information supplied
COS Minor administrative change
C04 Notification of facility ownership change
C05 New accident history information
C06 Change in emergency contact information
C07 New data element required by EPA
COS Optional data element requested by EPA
C09 Removed OCA description from executive
summary
Q Re-Submission (all 9 sections are updated and certified)
(Submission Type = "R")
R01 Newly regulated substance listed by EPA (40
CFR68.190(b)(2))
R02 Newly regulated substance above TQ in already
covered process (40 CFR 68.190(b)(3))
R03 Regulated substance present above TQ in new
(or previously not covered) process (40 CFR
68.190(b)(4))
R04 Revised PHA / Hazard Review due to process
change (40 CFR 68 190(b)(5))
R05 Revised OCA due to change (40 CFR
68.190(b)(6))
R06 Change in program level of covered process (40
CFR 68.190(b)(7))
R07 5-year update (40 CFR 68 190(b)(1))
R08 Process no longer covered (source has other
processes that remain covered) (40 CFR
68190(b)(7))
R09 Voluntary update (not described by any of the
above reasons)
Whereto Send Completed Forms:
U.S. Environmental Protection Agency
Attention :RMP Reporting Center
P.O. Box 10162
Fairfax, VA 22038
If you prefer to send this Risk Management Plan
Form by certified mail, courier or overnight mail
(e.g Fed Ex, UPS, Etc.), please address it to:
RMP Reporting Center
c/oCGI Federal, Inc.
12S01 Fairlakes Circle
Fairfax, VA 22033
EPA Form 8700-25
-1-
Appendix A: Risk Management Plan Form
A-l
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
Facility Name:
Executive Summary KPA Facility 1D# (leave blank for first submission only)
(attach a separate piece of paper if you need additional space)
EPA Form 8700-25 -2-
Appendix A: Risk Management Plan Form A-2
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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Facility Name:
Section 1. Registration
EPA Facility H)# (leave blank ibr first submission only)
1.1 Source Identification
1.1. a. Facility Name (maximum 50 characters)
1.1. b- Parent Company #1 Name (maximum 50 characters)
1 .1 .c. Parent Company #2 Name (maximum 50 characters)
1 .2 EPA Facility Identifier (12 characters)
(leave blank for first submission only)
1.3 Other EPA Systems Facility Identifier (15 characters)
1.4 Dun and Broadcast Numbers (DUNS) (9 characters)
1.4.a. Facility DUNS 1. 4. b Parent Compan
1 #1 DUNS 1 .4.0. Parent Company #2 DUNS
1.5 Facility Location
1.5. a. Street - Line 1 (maximum 35 characters)
1 ,5.b. Street - Line 2 (maximum 35 characters)
1.5.C. City (maximum 19 Characters)
1 .5.e. Zip Code Zip +4 Code
1.5.g. Facility Latitude (report in decimal degrees)
+/-DDD DDDDD D
1 .5.i. Method for determining Lat/Long ISM User Manual for Codes)
1.5.k. Horizontal accuracy measure (meters)
1.5.d. State
1 .5.f . County (maximum 20 characters)
1.5.h. Facility Longitude (report in decimal degrees)
+/-DDD DDDDD D
1.5.J. Description of location identified by Lat/Long
(see User Manual for Codes)
1.5.1. Horizontal reference datum code
1.5.m. Source Map Scale Number
EPA Form 8700-25
-3-
Appendix A: Risk Management Plan Form
A-3
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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Facilitv Name:
1 Section 1. Registration
1.6 Owner or Operator
1.6.a. Name (maximum 35 characters)
1.6b. Phone (----) - - - - - - - - -
Owner or Operator Mailing Address
1.6.C. Street- Line 1 (maximum 35 characters)
1 .6.d. Street - Line 2 (maximum 35 characters)
1.6.e. City (maximum 19 characters)
1.6.g. Zip Code Zip +4 Code
— ^
EPA Facility H)# (leave blank for first submission only)
rf
1.6.f. State
1.7 Name, title, and email address of person or position responsible for RMP (part 68) implementation
1 J.a. Name of person (maximum 35 characters)
1.7.b. Title of person or position (maximum 35 characters)
1 ,7.c. Email address of person or position (maximum 35 characters)
1.8.3 Emergency Contact
1
1
1
1
8 a. Name (maximum 35 characters)
8.c. Phone (•— *-
-•—i/ t— *-
*--^**-
1.8.b, Title of person or position (maximum 35 characters)
LS.d.^-Hour Phone (.— ) .— - _~
8.e. 24-Hour Phone Extension/PIN # (maximum 10 characters)
8.f. Email address for emergency contact (maximum 100 characters) EmerN/A if not applicable
EPA Form 8700-25
-4-
Appendix A: Risk Management Plan Form
A-4
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Facility Name:
Section 1. Registration
1.9. Other Points of Contact (Optional)
EPA Facility 1D# (leave blank for first submission only)
1.9.8.
1.9.C.
Facility or Parent Company E-mail Address
(maximum 1 00 characters)
1 .9.b. Facility Public Contact Phone Number
\ / l-^l-^tj
Facility or Parent Company VWVW Homepage Address (maximum 1 00 characters)
1.10 Local Emergency Planning Committee (LEPC) (optional) (maximum 30 characters)
1.11 Number of full-time equivalent (FTEs) employees on site
1.12. Covered by (select all that apply)
U 1.12.a. OSHAPSM
Q1.12.b. EPCRA section 302
LJ1.12.C. CAA Title V Air Operating Permit Program. If covered, specify permit ID# below.
1.13. OSHA Star or Merit Ranking (optional)
DYES
QNO
1.14. Last Safety Inspection (by an External Agency) Date
MM DD YYYY
1.15. Last Safety Inspection Performed by an External Agency (select one)
a 1.15.a. OSHA
LJ 1.15.b. State occupational safety agency
LM.15.C. EPA
Q1.15.d State Environmental Agency
LJ 1.15.6. Fire Department
Q1.15.f. Never had one
J 1.15.g. Other (specify) (maximum 50 characters)
1.16. Will this RMP involve Predictive Filing? (Optional)
DYES
JNO
EPA Form 8700-25
-5-
Appendix A: Risk Management Plan Form
A-5
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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Facility Name:
— ^
DEPA Facility H)# (leave blank for firsl submission only)
Section 1. Registration
1.17 Process Specific Information. For each covered process, fill in this page. If you are reporting more than one process, make a
photocopy of this page and report each process on a separate sheet.
Process IDS (optional - for your reference only)
Process Description (optional - for your reference only)
1.1 7.a. Program Level (select one)
ai 02 as
1.17.b. NAICS Code(s) (five or six digits)
1.17.C. Chemical(s) (regulated substance(s))
1.17.C.1. Name (maximum 100 characters)
1.17.C.2. CAS Number (10 characters)
1.17.C.3.
Quantity (Ibs)
(max. 12 chars.)
If you need more space to list NAICS codes or chemicals, please make a photocopy of this sheet.
EPA Form 8700-25
-6-
Appendix A: Risk Management Plan Form
A-6
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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Facility Name:
EPA Facility ID# (leave blank for first submission only)
Section 1. Registration
If an outside contractor prepared this risk management plan,
please enter information concerning this contractor in the fields below.
1.18 RMP Preparer Information
1
1
1
1
1
18.a. Name
18.b Phone
18.c. Street
18.d. Street
(maximum 70 characters)
- Line 1 (maximum 35 characters)
- Line 2 (maximum 35 characters)
18.e. City (Maximum 30 characters)
1.18.f. State • - • or
Foreign State or Province (Maximum 35 characters)
1
18.h. RMP Preparer Foreign Zip Code
118 q. Zip Code Zlp+4Code Of Foreign Country
(Max 2 characters)
EPA Form 8700-25
-7-
Appendix A: Risk Management Plan Form
A-7
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Facility Name:.
Section 2. Toxics: Worst Case EPA Kacilit>ln*(leave hlank for first suhm ission onl>'}
(If you need to report more than one worst case scenario, make a photocopy of pages in this section and report each scenario separately)
2.1. Chemical
2.1 .a. Name (maximum 100 characters)
2.1 b. Percent weight of chemicals (if in a mixture)
2.2. Physical state (select one)
a 2.2 a. Gas
Q2.2b. Liquid
J 2 2.c. Gas liquified by pressure
_l 2.2-d Gas liquified by refrigeration
2.3. Model Used (select one or enter another model name in Other below)
U 2.3,a. EPA's OCA Guidance Reference Tables or Equations
Q 2.3,b. EPA's RMP Guidance for Ammonia Refrigeration Reference Tables or Equations
LJ 2.3.d. EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
J 2.3.e. EPA's RMP Guidance for Warehouses Reference Tables or Equations
Q 2.3,f. EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
LJ2.3.g. EPA's RMP* Comp™
LJ 2.3,h. Areal Locations of Hazardous Atmospheres (ALOHA®)
J 2.3.Z. Other model (specify) (maximum 255 characters)
2.4. Scenario (select one)
U2.4.a. Gas Release U 2.4 b. Liquid Spill and Vaporization
2.5. Quantity released (Ibs)
2.7. Release duration (minutes) - - - - - . i_i
2.9. Atmospheric stability class (A-F)
2.6. Release rate (Ibs/minute)
T
2.8. Wind speed (meters/second) i_i
2.10. Topography (select one)
Q 2.10.a. Urban
H2.10.b. Rural
2.11. Distance to endpoint (miles)
EPA Form 8700-25
Appendix A: Risk Management Plan Form
A-8
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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Facility Name:
Section 2. Toxics: Worst Case
EPA Facility 1D# (leave blank for first submission only)
2.12. Estimated residential population within distance to endpoint (numeric)
2.13. Public receptors within distance to endpoint (select all that apply)
LI 2.13.3. Schools -I2.13.g
D 713b Rf.ftirfe.nces
Other (specify) (msximum 200 characters)
Q 2.13.0. Hospitals
Q 213.d Prison/Correctional Facilities
LI 2.13.f. Major commercial, office, or industrial areas
2.14. Environmental receptors within distance to endpoint (select all that apply)
Q 2.14.3. National or State Parks, Forests, or n 2.l4.d. Other (specify) (maximum 200 characters)
Monuments
LI 214b Officially Designated Wildlife Sanctuaries,
Preserves, or Refuges
Q ° 1 1 c Federal Wilderness Area
2.15. Passive mitigation considered (select all that apply)
U 2.15.a. Dikes J2.15.f.
Q 2.15.b. Enclosures
Q 2.15.0. Berms
Q ° 15 d Drain"
Q 2.15.6. Sumps
Other (specify) (maximum 200 characters)
2.16. Graphics file name (optional) (maximum 12 characters)
EPA Form 8700-25
-9-
Appendix A: Risk Management Plan Form
A-9
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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Facility Name:
Section 3. Toxics: Alternative Release EPA Facility ID# (leave blank for first submission only)
(If you need to report more than one alternative release scenario, make a copy of pages in this section and report each scenario separately)
3.1. Chemical
3.1 .a. Name (maximum 100 characters)
3.1.b- Percent weight of chemical (if in a mixture)
3.2. Physical State (select one)
U 3.2 a. Gas
Q 3.2 b Liquid
U 3.2 c Gas liquified by pressure
-I 3.2.d. Gas liquified by refrigeration
3.3. Model Used (select one or enter another model name in Other below)
U 3.3.a. EPA's OCA Guidance Reference Tables or Equations
Q 3.3. b. EPA's RMP Guidance for Ammonia Refrigeration Reference Tables or Equations
Q 3.3.d. EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
LI 3.3,e. EPA's RMP Guidance for Warehouse Reference Tables or Equations
Q 3.3 f. EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
Q3.3.g EPA's RMP'Comp™
J 3.3.h. Areal Locations of Hazardous Atmospheres (ALOHA®)
LJ 3.3.Z. Other model (specify) (maximum 200 characters)
3.4. Scenario (select one)
J 3.4.a. Transfer hose failure
Q 3.4 b. Pipe Leak
Q 3.5.C. Vessel Leak
LI 3.4.d. Overfilling
Q 3.4.e. Rupture disk/relief valve failure
_J 3.4.f. Excess Flow Device Failure
LI 3.4.g. Other (specify) (maximum 35 characters)
3.5. Released (Ibs)
3.7. Release Duration (minutes) • - - - • . , i
3.9. Atmospheric stability class (A-F) i_i
3.6. Release Rate (Ibs/minute)
3.8. Wind Speed (meters/second) • - - - • . , i
EPA Form 8700-25
-10-
Appendix A: Risk Management Plan Form
A-10
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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Facility Name:
Section 3. Toxics: Alternative Release EPA Facility H» (leave blank for first submission only)
(If you need to report more than one alternative release scenario, make a copy of pages in this section and report each scenario separately}
3.10. Topology (select one)
L! 3.10.3. Urban
J310b Rural
3.11. Distance to endpoint (miles) • - - - . • - •
3.12. Estimated residential population within distance to endpoint
. . . , . . - . J . . . .
3.13. Public receptors within distance to endpoint (select all that apply)
LJ 3.13.a. Schools Q 3.13.6.
a 3.1 3. b. Residences LI 3.1 3.f.
U 3.1 3.c Hospitals Q 3.1 3 g
LI 3.13.d. Prisons/Correctional facilities
Recreation Areas
Major commercial, office, or industrial areas
Other (specify) (maximum 200 characters)
3.14. Environmental receptors within distance to endpoint
l_l 3.14.a. National or State Parks. Forests, or
Monuments
LI 3.14. b. Officially Designated Wildlife Sanctuaries,
Preserves, or Refuges
LJ 3.14.C. Federal Wilderness Area
(select all that apply)
LJ 3.14.d. Other (specify) (maximum 200 characters)
3.15. Passive mitigation considered (select all that apply)
U 3.15.a. Dikes
LI 3.15.b. Enclosures
Q 3.15.C. Berms
LI 3.1 5. d. Drains
J 3 15.e. Sumps
LI 3.15.f. Other (specify) (maximum 200 characters)
3.16. Active mitigation considered (select all that apply)
LJ 3.16.3. Sprinkler systems
Q 3.1 6. b. Deluge systems
Q 3.16.C. Water curtain
Q 3.1 6.d. Neutralization
Q 3.16.e. Excess flow valve
LJ 3.1 6.f. Flares
LI3.16.g. Scrubbers
LI 3.1 6.h. Emergency shutdown systems
LI 3.16.1. Other (specify) (maximum 200 characters)
3.17. Graphics file name (optional) (maximum 12 characters)
EPA Form 8700-25
-11-
Appendix A: Risk Management Plan Form
A-ll
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Facility Name:
Section 4. Flammables: Worst Case EPA Facility m# (leave blank for first submission only)
(If you need to report more than one worst-case scenario, make a photocopy of pages in this section and report each scenario separately)
4.1 .a. Chemical Name (maximum 100 characters)
4.2. Model Used (select one or enter another model name in Other below)
LI 4.2. a. EPA's OCA Guidance Reference Tables or Equations
Li 4.2.C, EPA!s RMP Guidance for Ammonia Refrigeration Reference Tables or Equations
Q 4.2 d. EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
LI 4.2.e. EPA's RMP Guidance for Warehouse Reference Tables or Equations
LI 42 f EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
U4.2.g. EPA's RMP'Comp™
L) 4.2.Z. Other model (specify) (maximum 235 characters)
4.3. Scenario (only one option)
Vapor Cloud Explosion
4.4. Quantity released (Ibs)
4.6. Distance to endpoint (miles)
4.8. Public Receptors within distance to endpoint (select all th
LI 4.8.a. Schools
Q 4.8.b. Residences
LI 4.8.C Hospitals
LI 4.8.d. Prisons/Correctional facilities
LI 4.8. e. Recreation Areas
4.5. Endpoint Used (only one option)
1PSI
4.7. Estimated residential population within distance to
endpoint
st apply)
J 4.8.f. Major commercial, office, or industrial areas
Q 4,8,g. Other (specify) (maximum 200 characters)
4.9. Environmental receptors within distance to endpoint (sele
LJ 4. 9. a. National or State Parks, Forests, or
Monuments
LJ 4.9.b. Officially Designated Wildlife Sanctuaries,
Preserves, or Refuges
LJ 4.9.C. Federal Wilderness Area
:t all that apply)
J 4.9.d. Other (specify) (maximum 200 characters)
EPA Form 8700-25
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Appendix A: Risk Management Plan Form
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
Facility Name:
EPA Facility H># (leave blank for first submission only)
Section 4. Flammables: Worst Case
4.10. Passive mitigation considered (select all that were considered in defining the release quantity or rate for the worst-case
scenario)
LJ 4.10.a. Blast walls U 4.10.b. Other (specify) (maximum 200 characters)
4.11. Graphics file name (optional) (maximum 12 characters)
EPA Form 8700-25 -13-
Appendix A: Risk Management Plan Form A-13
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Facility Name:
Section 5. Flammables: Alternative Release
EPA Facility 1D# (leave blank for first submission only)
(If you need to report more than one alternative release scenario, make a photocopy of pages in this section and report each
scenario separately)
5.1. Chemical Name (maximum 100 characters)
5.2. Model Used (select one or enter another model name in Other below)
U 5.2.a. EPA's OCA Guidance Reference Tables or Equations
Q 5.2.C. EPA's RMP Guidance for Propane Storage Reference Tables or Equations
Q 5.2 d. EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
Q 5.2.e. EPA's RMP Guidance for Warehouse Reference Tables or Equations
LJ 5.2.f. EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
U5.2.g. EPA's RMP*Comp™
Q 5.2.2. Other model (specify) (maximum 235 characters)
5.3. Scenario (select one)
Q 5.3.a. Vapor cloud explosion
LI 5.3.b. Fireball
LI 5.3.C. BLEVE
Q 5.3.d. Pool fire
Q 5.3.e. Jet fire
D 5.3.f. Vapor cloud fire
_l 3.4.g Other (specify) (maximum 30 characters)
5.4. Quantity released (Ibs)
5.5 Endpoint used (select one)
Q 5.5.a. 1 PSI
a 5.5.b. 5 kw/m2 for 40 seconds
L) 5 5.c. Lower flammability limit (specify percent volume)
5.6. Distance to endpoint (miles)
5.7. Estimated residential population within distance to
endpoint
EPA Form 8700-25
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Appendix A: Risk Management Plan Form
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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Facility Name:
Section 5. Flammables: Alternative Release
El" A facility 1D# (leave blank for first submission only)
5.8. Public Receptors within distance to endpoint (select all
that apply)
Q 5.8.a. Schools
Q 5.8.b. Residences
Q 5.8.C Hospitals
J 5.8. ct. Prisons/Correctional facilities
LJ 5.8.6. Recreation Areas
_) 5.8. f. Major commercial, office, or industrial areas
Q 5.8 g Other (specify) (maximum 200 characters)
5.9. Environmental receptors within distance to endpoint
(select all that apply)
LJ 5. 9. a. National or State Parks. Forests, or
Monuments
Q 5.9.b. Officially Designated Wildlife Sanctuaries,
Preserves, or Refuges
LJ 5.9 c Federal Wilderness Area
-1 5.9.d. Other (specify) (maximum 200 characters)
5.10. Passive mitigation considered (select all that apply)
LJ 5.10.a. Dikes
a 5.10.b. Firewalls
LJ 5.10.C. Blast walls
LJ 5.10.d Enclosures
Q 5.10.e. Other (specify) (maximum 200 characters)
5.11. Active mitigation considered (select all that apply)
Q 5. 11. a. Sprinkler systems
LJ 5.11.D. Deluge systems
LJ 5.11.C. Water curtain
Q 5.1 Id. Excess flow valve
J 5.11.e. Other (specify) (maximum 200 characters)
5.12. Graphics file name (optional) (maximum 1 2 characters)
EPA Form 8700-25
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Appendix A: Risk Management Plan Form
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Facility Name:
Section 6. Five-Year Accident History EPA Facility m# (leave blank for firsl submission only)
(If you need to report more than one accident history, make a photocopy of pages in this section and report each scenario separately)
Would you like to certify that your facility did not have any reportable accidents in the last 5 years?
Q Yes; leave the rest of this section blank Zl No, fill out this section for each accident
6.1. Date of accident (day, month, and year)
MM DD YYYY
6. .3. NAICS code of process involved
S.S.a.i. Chemical name (maximum 100 characters)
6.2. Time accident began (hours and minutes)
- - • • - • Qa.m.
H H MM Jp.m.
6.4. Release duration (hours and minutes)
H H - [v" M
6.5.a.ii. CAS Number
S.S.b. Quantity
released (Ibs.)
8.5.C. Percent
weight of chemical if
in a mixture {toxics
only)
6.6. Release event (select at least one)
U a. Gas release
J b. Liquid spills/evaporation
Qc. Fire
_) d Explosion
Q e. Uncontrolled/Runaway Reaction
6.7. Release Source (select at least one)
Q a. Storage vessel
LJ b. Piping
U c. Process vessel
LI d. Transfer hose
Q e. Valve
LJ f. Pump
LJg. Joint
J h. Other (specify) (maximum 200 characters)
EPA Form 8700-25
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Appendix A: Risk Management Plan Form
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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Facility Name:
Section 6. Five-Year Accident History EPA Facility ID» (leave blank for first submission only)
6.8. Weather conditions at time of event
a.i. Wind speed (numerical)
b. Temperature (F)
Wind speed unit
Jl miles/hr. rj knots 3 meters/sec.
c. Atmospheric stability class (A-F)
a.ii. Wind direction
J d. Precipitation present
J e. Unknown weather conditions (check if a-d are all unknown)
6.9 On-site Impacts
a
c
6.
(-1
Deaths (enter numbers)
a.ii. Public responders > — > — • — «
Property damage
i__^_^^_^ j ^_^_^
10. Known off-site impacts (enter numbers)
b Injuries (enter numbers)
b.ii. Public responders • — • — > — •
-,__
6.10.g. Environmental damage (select all that apply)
O g.1. Fish or animal kills
LJ g.2. Tree, lawn, shrub, or crop damage
Q g.3. Water contamination
J g.4. Soil contamination
Q g.5. Other (specify) (maximum 200 characters)
EPA Form 8700-25
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Appendix A: Risk Management Plan Form
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Facility Name:
Section 6. Five-Year Accident History
EPA Facility 1D# (leave blank for first submission only)
6.11. Initiating event (select one)
Q a. Equipment failure
Q b. Human error
Q c. Natural (weather conditions, earthquake)
U d. Unknown
6.12. Contributing factors (select all that apply)
J a. Equipment failure
LI b. Human error
U o. Improper procedure
U d. Over pressurization
Q e. Upset condition
LI f. By-pass condition
LI g. Maintenance activity/inactivity
LI h. Process design failure
Q i. Unsuitable equipment
J j. Unusual weather conditions
J k. Management error
D I. uncontrolled/runaway reaction
U m. Other (specify) (maximum 200 characters)
6.13. Off-site responders notified (select one)
Q a. Notified only
U b. Notified and responded
LI c. No, not notified
J d. Unknown
6.14. Changes introduced as a result of the accident
(select at least one)
Q a. Improved/upgraded equipment
LJ b. Revised maintenance
LI c. Revised training
LI d Revised operating procedures
LI e. New process controls
Q f. New mitigation systems
LJ g. Revised emergency response plan
J h. Changed process
[J i. Reduced inventory
J j None
_1 k. Other (specify) (maximum 200 characters)
EPA Form 8700-25
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Appendix A: Risk Management Plan Form
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Facility Name:
Section 7. Prevention Program: Program 3 UFA facility 1I)# (leave blank for first submission only)
(If you need to report more than one prevention program, make a photocopy of pages in this section and report each scenario separately)
Prevention Program description:
7.2. Chemical name(s)
(maximum 100 characters)
If you need more space to list chemicals, please make a photocopy of this sheet.
7.3. Date on which the safety information was last reviewed or revised
MM DD YYYY
7.4. Process Hazards Analysis (PHA)
7.4.a. Date of last PHA or PHA update
MM DD YYYY
7.4.b. Technique used (select at least one)
Q 7.4.b.1. What If
LJ 7.4.b.2. Checklist
Q 7.4.b.3. What if/Checklist combined
LJ 7.4.b.4. HAZOP
Q 7.4.b.5. Failure Mode & Effects Analysis
LJ7.4.t>.6, Fault Tree Analysis
-17.4.b.7. Other (specify) (maximum 200 characters)
EPA Form 8700-25
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Appendix A: Risk Management Plan Form
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
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Facility Name:
Section 7. Prevention Program: Program 3 EPA Facility 1D# (leave blank for first submission only)
7.4.C. Expected or actual date of completion of all changes resulting from last PHA or PHA update
M M
D D Y Y Y Y
7.4.d. Major hazards identified (select at least one)
LI 7.4.d.1. Toxic release
LI 7.4.d.2. Fire
Q 7.4.d.3. Explosion
LI 7.4.d.4. Runaway reaction
Q 7.4.d.5, Polymerization
LI 7.4.d.6. Over pressurization
LI 7.4.d.7. Corrosion
D 7.4.d8 Overfilling
U 7.4.d.9. Contamination
Q 7.4.d.10,
Q 7.4.d.11.
Q 7.4.d.12.
Q 7.4.d.13.
LI 7.4.d.14.
J 7.4.d.15.
U 7.4.d.16.
Equipment failure
Loss of cooling, heating, electricity,
Instrument air
Earthquake
Floods (flood pain)
Tornado
Hurricanes
Other (specify) (maximum 200 characters)
7.4.e. Process controls in use (select at least one)
a 7.4.6.1. Vents
LI 7.4.e.2. Relief valves
LI 7.4.e.3. Check valves
Q 7.4.e.4. Scrubbers
LI 7.4.e.5. Flares
Q 7.4.e.6. Manual shutoffs
LI 7.4.e.7. Automatic shutoffs
Q 7 4.e.8. Interlocks
—I 7.4.6.9. Alarms and procedures
LI 7.4.e.10. Keyed bypass
Q 7.4.6.11. Emergency air supply
a 7.4.6.12.
Q 7.4.6.13.
LI 7.4.6.14.
U 7.4.6.15.
Q 7.4.6.16.
Q 7.4.6.17.
a 7.4.6.18.
_l 7.4.6.19.
U 7.4.e.20.
Q 7.4.6.21.
Emergency power
Backup pump
Grounding equipment
Inhibitor addition
Rupture disks
Excess flow device
Quench system
Purge system
None
Other (specify) (maximum 200 characters)
7.4.f. Mitigation systems in use (select at least one)
Q 7.4.M. Sprinkler system
U 7.4.f.2. Dikes
LI 7.4.f,3. Firewalls
Q 7.4T.4. Blast walls
LI 7.4.f.5. Deluge system
Q 7.4.f.6. Water curtain
J 7.4T.7. Enclosure
J 7.4.f.8. Neutralization
Q 7.4.f.9. None
J 7.4.f.10. Other (specify)(maximum 200 characters)
7.4.g. Monitoring/detection systems in use (select at least
one)
Q 7.4.g.1. Process area detectors
LI 7.4.g.2. Perimeter monitors
LJ 7.4.g.3. None
Q 7.4.g.4. Other (specify)(maximum 200 characters)
EPA Form 8700-25
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Appendix A: Risk Management Plan Form
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
Facility Name:
Section 7. Prevention Program: Program 3 EPA Facility 1D# (leave blank for first submission only)
7.4.h. Changes since last PHA update (select at least
one)
Q 7.4.h.8. None recommended
Q 7.4.h.1. Reduction in chemical inventory U 7.4.h.9. None
G 7.4.h.2. Increase in chemical inventory -I 7.4.h.10. Other (specify) (maximum 200 characters)
U 7.4.h.3. Change in process parameters
LJ 7.4.h.4. Installation of process controls
Q 7.4.h.5. Installation of process detection systems
LI 7 4 h 6 Installation of perimeter monitoring systems
Q 7.4.h.7. Installation of mitigation systems
7.5. Date of most recent review or revision of operating procedures • • . • . .
MM DD YYYY
7.6. Training
7.7. Maintenance
7.7.a. Date of most recent reviewer revision of maintenance procedures . - . . - .
MM DD YYYY
7.7.b. Date of most recent equipment inspection or test • - • • - •
MM DD YYYY
7,7.c. Equipment most recently inspected or tested (list equipment) (maximum 2QQ characters)
EPA Form 8700-25 -21-
7.6.a. Date of most recent review or review of operating procedures
MM DD YYYY
7.6.b. Type of training provided (select at one)
Q 7.6.b.1. Classroom
Q 7.6.0.2. On the job
U 7.6-b.3. Other (specify! (maximum 200 characters)
7.6.C. Type of competency testing used (select at least one)
LI 7.6.C.1. Written test
Q 7.6.C.2. Oral Test
LI 7.6.C.3. Demonstration
LI 7.6. c. 4. Observation
^ 7.6 c. 5. Other (specrfy)(maximum 200 characters)
Appendix A: Risk Management Plan Form A-21
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
Facility Name:
Section 7. Prevention Program: Program 3 EPA Facility 1D# (leave blank for first submission only)
7.8 Management of Change
7.8 a Date of most recent changes that triggered management of change procedures.
7.8.b. Date of most recent changes that triggered management of change procedures.
7.9. Date of most recent pre-startup review
MM DO YYYY
MM DD YYYY
MM DD YYYY
7.10. Compliance audits
7.1 0. a Date of most recent compliant audit
7.1 0.b. Expected or actual date of completion of all changes resulting from the compliance
audit
MM DD YYYY
MM DD YYYY
7.11. Incident investigation
7.11 .a Date of most recent incident investigation (if any)
71 1 b. Expected or actual date of completion of all changes resulting from the incident
investigation
MM DD YYYY
MM DD YYYY
7.12. Date of most recent review or revision of employee participation plans
MM DD YYYY
EPA Form 8700-25 -22-
7.13.
Date of most recent review or revision of hot work permit procedures
MM DD YYYY
7.14.
Date of most recent review or revision of contractor safety procedures
MM DD YYYY
7.15.
Date of most recent review or revision of contractor safety performance
MM DD YYYY
Appendix A: Risk Management Plan Form A-22
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Facility Name:
Section 8. Prevention Program: Program 2 EPA Facility m# (leave blank far first submission only)
(If you need to report more than one prevention program, make a photocopy of pages in this section and report each scenario separately)
Prevention Program description:
8.2. Chemical name(s)
(maximum 100 characters)
If you need more space to list chemicals, please make a photo copy of this sheet.
8.3 Safety Information
83. Date of most recent review or revision of safety information
MM DD YYYY
8.3.b. Federal/state regulations or industry-specific design
codes and standards used to demonstrate compliance with
safety information requirement (select at least one)
Q 8.3.b.1. NFPA 58 (or state law based on NFPA 58)
LI 8.3.b.2. OSHA (29 CFR 1910.111)
LI 8.3.b.3. ASTM Standards
Q 8.3.b.4. ANSI Standards
Q 8.3.b.5. ANSME Standards
Q 8.3.b.6. None
LJ 8.3..b.8. Comments (100 characters)
_l 8.3..b.7. Other (specify) (maximum 200 characters)
EPA Form 8700-25
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Appendix A: Risk Management Plan Form
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Facility Name:
Section 8. Prevention Program: Program 2 EPA Facility ID» (leave blank for first submission only)
8.4
. Hazard review
8 4 a. Date of completion of most recent hazard reviewer update
8.4.b. Expected or actual date of completion of all changes resulting fron
M M D D Y Y
- •
Y Y
1 the hazard review • - • • - • • - - - •
MM DD YYYY
8.4.C. Major hazards identified (select at least one)
a
LI
a
u
a
a
LI
a
a
a
8.4.0.1.
8.4.C.2.
8.4.C.3.
8.4.C.4.
8.4.0.5.
8.4.0.6.
8.4.C.7.
8.4.0.8.
8.4.C.9.
8.40.10
Toxic release
Fire
Explosion
Runaway reaction
Polymerization
Over pressurization
Corrosion
Overfilling
Contamination
Equipment failure
n
LI
u
j
a
u
8.4.0.11.
8.4.C.12.
8.4.C.13.
8.4.C.14.
8.4.C.15.
8.4.C.16.
Loss of cooling, heating, electricity,
instrument air
Earthquake
Floods (flood pain)
Tornado
Hurricanes
Other (specify) (maximum 200
characters)
8.4.d. Process controls in use (select at least one)
a
a
u
a
j
u
a
_j
a
a
LI
_i
8.4 d.1.
8.4.d.2.
8.4.d.3
8.4.d.4.
84d.5
8.4.d.6.
8.4.d.7.
8.4.d.8,
8.4d.9
8.4.d.10
84.d11
8.4.d.12
Vents
Relief valves
Check valves
Scrubbers
Flares
Manual shutoffs
Automatic shutoffs
Interlocks
Alarms and procedures
Keyed bypass
Emergency air supply
Emergency power
j
a
u
j
LI
LI
a
u
_i
8.4d.13.
8.4.d.14.
84.d.15.
8.4.d.16.
8.4.d.17
8.4.d.18
8.4.d.19.
8.4.d.20
8.4.d.21.
Backup pump
Grounding equipment
Inhibitor addition
Rupture disks
Excess flow device
Quench system
Purge system
None
Other (specify) (maximum 200 characters)
EPA Form 8700-25
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Appendix A: Risk Management Plan Form
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL
MARCH 2014
Facility Name:
Section 8. Prevention Program: Program 2
F.PA Facility ID# (leave blank for firsl submission only)
8.4.e. Mitigation systems in use (select at least one)
Q 8.4.6.1, Sprinkler system
LI 8.4.6.2. Dikes
Q 8.4.e.3. Firewalls
LI 8.4.e.4. Blast walls
Q 8.4.e.5, Deluge system
_l 8.4.e.6. Water curtain
J 8.4.e.7 Enclosure
LI 8.4.e.8. Neutralization
a 8.4.e.9. None
U 8.4.6.10. Other (specify)(maximum 200 characters)
8.4.f. Monitoring/detection systems in use (select at least one)
L) 8.4.T.1. Process area detectors
LI 8.4. f.2. Perimeter monitors
Q 8.4.f.3. None
Q 8.4.f.4 . Other (specify)(maximum 200 characters)
8.4.g Changes since last hazard review or hazard review
update (select at least one)
Q 8.4.g.1. Reduction in chemical inventory
LI 8 4.g 2 Increase in chemical inventory
Q 8.4.g.3. Change in process parameters
LI 8 4.g.4 Installation of process controls
Q 8.4.g.5, Installation of process detection systems
Q 8.4.g.6. Installation of perimeter monitoring systems
Q 8.4.g.7 Installation of mitigation systems
LI 8.4.g.8. None recommended
Q 8.4.g.9. None
LI 8.4g.10. Other (specify) (maximum 200 characters)
8.5. Date of most recent review or revision of safety information
MM DD YYYY
8.6. Training
8.6.a. Date of most recent review or revision of training programs
MM DD YYYY
8.6.b. Type of training provided (select at one)
Q8.6.D.1. Classroom
LJ8.6.D.2. On the job
Q 8.6.D.3. Other (specify) (maximum 200 characters)
EPA Form 8700-25
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Appendix A: Risk Management Plan Form
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
Facility Name:
EPA Facility TD# (leave blank for firsl submission only)
Section 8. Prevention Program: Program 2
8.6.C. Type of competency testing used (select at least one) Q 8.6.c5 Other (specify)(maximum 200 characters)
LI 8.6.C.1. Written test
LI ae.c.2. Oral Test
Q 8.6.C.3. Demonstration
LI 8.6.C.4. Observation
8.7. Maintenance
8.7.a. Date of most recent review or revision of maintenance procedures •_•—i .—•—i
MM DD YYYY
8.7.b. Date of most recent equipment inspection or test • - • • - •
MM DD YYYY
8.7.C. Equipment most recently inspected or tested (list equipment) (maximum 200 characters)
8.8. Compliance audits
8.8.a. Date of most recent compliant audit
MM DD YYYY
8.8.b. Expected or actual date of completion of all changes resulting from the compliance
MM DD YYYY
8.9. Incident investigation
8.9 a. Date of most recent incident investigation (if any) • - • • - • • - - - •
MM DD YYYY
8.9.b- Expected or actual date of completion of all changes resulting from the incident
MM DD YYYY
8.10. Date of most recent change that triggered a review or a revision of safety
information, the hazard review, operating or maintenance procedures, or training i—•—• •—*—'
MM DD YYYY
EPA Form 8700-25 -26-
Appendix A: Risk Management Plan Form A-26
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
Facility Name:
EPA Facility H)# (leave blank for firsl submission only)
Section 9. Emergency Response
9.1 Written emergency response (ER) plan
9.1.a, Q Is your facility included in the written community emergency response plan?
9.1.b. Q Does your facility have its own written emergency response plan?
9.2. Q Does your facility's ER plan include specific actions to betaken in response to accidental releases of regulated
substance(s)?
9.3. Q Does your facility's ER plan include procedures for informing the public and local agencies responding to accidental
releases?
9.4. Q Does your facility's ER plan include information on emergency health care?
9.5. Date of most recent review or update of your facility's ER plan
MM DD YYYY
9.6. Date of most recent ER training for your facility's employees
MM DD YYYY
9.7. Local agency with which your facility's ER plan or response activities are coordinated
9.7.a. Name of agency (maximum 35 characters)
9.7.b- Phone number (•
9.8 Subject to (select all that apply)
L)9.8.a. OSHA Regulations at 29 CFR 1910.38
Q 9.8.b. OSHA Regulations at 29 CFR 1910.120
Q9.8.C Clean Water Act Regulations at 40 CFR 112
LI 9.8.d. RCRA Regulations at 40 CFR 264, 265, 279.52
Q 9.8.e. OPA-90 Regulations at 40 CFR 112, 33 CFR 154, 49 CFR 194, 30 CFR 254
LI 9.8.f. State EPCRA Rules or Laws
LI 9.8.g. Other (specify)(maximum 200 characters)
EPA Form 8700-25 -27- Return to Index
Appendix A: Risk Management Plan Form A-27
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RISK MANAGEMENT PLAN - RMP ESUBMIT USER'S MANUAL MARCH 2014
APPENDIX B. SAMPLE CERTIFICATION LETTERS
SAMPLE CERTIFICATION LETTERS
Certification Statement for Program 1 Process(es):
Based on the criteria in 40 CKR 68.10, the distance to the specified endpoint for the worst-case accidental release
scenario for the following processes) is less than the distance to the nearest public receptor:
• [insert description for first program 1 process from executive summary]
• [insert description for second program 1 process from executive summary]
etc.
Within the past five years, the process(es) has (have) had no accidental release that caused offsite impacts provided
in the risk management program rule (40 CFR 68.10(b)(l)). No additional measures are necessary to prevent
olTsite impacts from accidental releases. In the event of fire, explosion, or a release of a regulated substance from
the process(es), entry within the distance to the specified endpoints may pose a danger to public emergency
responders. Therefore, public emergency responders should not enter this area except as arranged with the
emergency contact indicated in the RMP. The undersigned certifies that, to the best of my knowledge,
information, and belief, formed after reasonable inquiry, the information submitted is true, accurate, and
complete.
Signature Print Name
Title Date
Certification Statement for Program Level 2 & 3 Processes:
To the best of the undersigned's knowledge, information, and belief formed alter reasonable inquiry, the
information submitted is true, accurate, and complete.
Signature Print Name
Title Date
B-l
Appendix B: Sample Certification Letters B-l
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Certification Statement for a Correction:
To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, these
corrections and/or administrative changes arc true, accurate, and complete.
Signature Print Name
Title Date
EPA Facility ID #
nnnn-nnnn-nnnn
R-2 Return to Index
Appendix B: Sample Certification Letters B-2
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APPENDIX C. CBI SUBSTANTIATION FORM
OM B Control Number 2050-0144
CBI SUBSTANTIATION FORM
If you are claiming Confidential Business Information (CBI) in your Risk Management plan
(RMP), you must substantiate your claim at the same time that you submit your RMP. To qualify for CBI
protection, the substantive criteria in 40 CFR 2.301 must be met. Certain RMP data elements cannot be
claimed CBI, as stated in 40 CFR 68.151.
Fill out this form for each data element or set of data elements that have a discrete substantiation. You
may use one CBI Substantiation Form to report multiple data elements as CBI if the basis for
substantiation is the same. That means the answers to the questions in Part IV must be the same for all
the data elements. If you need more space in Part III, please attach a separate piece of paper.
Burden Statement
The public reporting and recordkeeping burden for this collection of information is estimated to
average 8.5 hours per claim. Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency.
This includes the time needed to review instructions; develop, acquire, install, and utilize technology
and systems for the purposes of collecting, validating, and verifying information, processing and
maintaining information, and disclosing and providing information; adjust the existing requirements;
train personnel to be able to respond to a collection of information; search data sources; complete and
review the collection of information; and transmit or otherwise disclose the information. An agency
may not conduct or sponsor, and a person is not required to respond to, a collection of information
unless it displays a currently valid OMB control number.
Send comments on the Agency's need for this information, the accuracy of the provided burden
estimates, and any suggested methods for minimizing respondent burden, including through the use
of automated collection techniques to the Director, OPPE Regulatory Information Division, U.S.
Environmental Protection Agency (2137), 401 M St., S.W., Washington D.C. 20460. Include the OMB
control number in any correspondence. Do not send the completed CBI substantiation to this address.
Part I - Facility Identification Information
The information given here must correspond to the information that you provided in the
registration section of your RMP. If you have an EPA Facility ID #, please include this information. If
you are resubmitting, updating or correcting your RMP, you should already have received an EPA
Facility ID#.
a. Facility Name:
b. EPA Facility ID # (if assigned):
nnnn-nnnn-nnnn
c. Facility Location Address:
d. City, State and Zip Code:
EPA Form 8700-27 C-1
Appendix C: CBI Substantiation Form C-1
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e. Dun and Bradstreet Number:
Part If - Is this substantiation a sanitized or an unsanitized version?
If this substantiation contains any CBI, you must also submit a sanitized substantiation (without CBI
data) as stated in 40 CFR 68.1 52. In this case, submit 2 copies of this form, one sanitized and one
unsanitized. Please indicate here whether this form is sanitized or unsanitized.
C Sanitized D Unsanitized
Part III - List the RMP Data Elements which you are claiming CBI that are covered in this substantiation
form. List the data element number and its descriptive name, but NOT the actual CBI data. Please note
that you may use one substantiation form for more than one data element only if the answers to all of
the questions in Part IV are the same for those data elements.
Data Element #
Data Element Name
EPA Form 8700-27
C-2
Appendix C: CBI Substantiation Form
C-2
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Part IV-The following are criteria set forth in 40 CFR 2.204, 2.208 and 2.301 for substantiating CBI
claims. Provide answers to each of the following questions to substantiate your claim. If you need
additional space, use separate sheets of paper.
(a) For any data elements that you wish to claim CBI that are listed in Part III, please indicate
whether your business has previously submitted a CBI claim for this data element to EPA and
whether that claim has expired, been waived, or been withdrawn.
(b) What reasonable measures have you taken to protect the confidentiality of the information and
do you intend to continue to take these measures?
EPA Form 8700-27 C-3
Appendix C: CBI Substantiation Form C-3
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(c) Have you disclosed the information to anyone other than a governmental body? If so, why
should the information still be considered confidential? If not, is the information reasonably
obtainable without your consent? Has EPA or another Federal agency made a determination as
to the confidentiality of the information? If so, please attach a copy of the determination.
(d) Does any statute require public disclosure of the information for which you are claiming CBI? If
so, identify the law.
EPA Form 8700-27 C-4
Appendix C: CBI Substantiation Form C-4
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(1) For each data element claimed as CBI in Part III, discuss with specificity why release of the
information is likely to cause substantial harm to your competitive position. Explain the nature
of those harmful effects, why they should be viewed as substantial, and the causal relationship
between disclosure and such harmful effects. For example, how could your competitors make
use of this information to your detriment?
(2) Do you assert that the information is "voluntarily submitted" as defined at 40 CFR 2.201(i)? If
so, explain why, and how disclosure would tend to lessen the Governments's ability to obtain
necessary information in the future.
Part V - Certification (Read and sign after completing all sections)
To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry,
the information submitted is true, accurate, and complete.
Name and official title of owner or operator or senior management official
Signature (All signatures must be original)
Official Title
Print Name
Date Signed
EPA Form 8700-27
C-5
Return to Index
Appendix C: CBI Substantiation Form
C-5
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APPENDIX D. CBI UNSANITIZED DATA ELEMENT FORM
OMB Control Number: 2050-0144
CBI UNSANITIZED DATA ELEMENT FORM
If you are claiming Confidential Business Information (CBI) in your RMP, you must submit in paper form
both the information being claimed CBI and a substantiation for your claim at the time you submit your
redacted or "sanitized" RMP , This form should be used to submit the confidential information. The
redacted RMP will be made available to the public in RMP*lnfo.
If you need additional space, make a copy of page 2 of this form.
Part I. Facility Identification Information
The information given here should correspond to the information that you filled out in the registration
section of your RMP. If you have an EPA Facili ty ID#, please include this information. You will have
received the number after your first submission.
a. Facility Name:
b.EPAFaci,ity.D#(ifassigned): 0000 - DODO - DODO
c. Facility Location Address:
d. City, State and Zip Code:
e. Dun and Bradstreet Number:
Part II - Information claimed as CBI
Please list the data element number(s) from the RMP form (paper form or electronic form), the name(s)
of the element(s) you are claiming CBI, and the actual CBI data.
Data Element
Number
Name of Data Element
RMP Data Claimed as CBI
EPA Form 8700-28
D-1
Appendix D: CBI Unsanitized Data Element Form
D-1
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Data Element
Number
Name of Data Element
RMP Data Claimed as CBI
EPA Form 8700-28
Return lo Index
Appendix D: CBI Unsanitized Data Element Form
D-2
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APPENDIX E. RISK MANAGEMENT PROGRAM DE-REGISTRATION FORM
Today's Date:
EPA Facility Identifier:
Effective Date of De-registration:
Facility Name:
Facility Address:.
City: State: Zip Code:
Select (Check) Reason for De-registration:
n Source reduced inventory of all regulated substances below TQs
n Source no longer uses any regulated substance
n Source terminated operations
n Other:
I, , certify the above stationary source as of the above
(Name of Facility Owner or Operator)
effective date is no longer covered by the Accidental Release Prevention Regulations, 40 CFR Part 68.
Signature of Owner or Operator Date
Official Title
PLEASE MAIL THE COMPLETED DE-REGISTRATION FORM PROMPTLY TO:
U.S. Environmental Protection Agency
Attention: RMP Reporting Center
P.O Box 10162
Fairfax, VA 22038
If you prefer to send your De-registration Form by certified mail, courier or overnight mail (e.g., Fed Ex,
UPS, etc.), please address it to:
RMP Reporting Center
c/o CGI Federal, Inc.
12601 Fair Lakes Circle
Fairfax, VA 22033
Appendix E: Risk Management Program De-Registration Form E-l
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APPENDIX F. RISK MANAGEMENT PROGRAM PROPANE WITHDRAWAL FORM
EPA Facility Identification #:
Facility Name:
Facility Location Address:
City: State: Zip Code:
The facility listed above is withdrawing its RMP submission per 40 CFR 68.126 because the facility does
not have more than a threshold quantity of any regulated substance listed at 40 CFR 68.130 other than
propane (or another listed flammable substance):
n that the facility uses on site as a fuel,
or
n that the facility holds for retail sale as fuel. More than one-half of the income of this facility
is obtained from direct sales of the fuel to end users or more than one-half of the fuel sold,
by volume, is sold through a cylinder exchange program.
Operator/Owner Name Official Title Date
PLEASE MAIL THIS COMPLETED PROPANE WITHDRAWAL FORM PROMPTLY TO:
U.S. Environmental Protection Agency
Attention: RMP Reporting Center
P.O Box 10162
Fairfax, VA 22038
If you prefer to send this Propane Withdrawal Form by certified mail, courier or overnight mail (e.g.,
Fed Ex, UPS, etc.), please address it to:
RMP Reporting Center
c/o CGI Federal, Inc.
12601 Fair Lakes Circle
Fairfax, VA 22033
Appendix F: Risk Management Program Propane Withdrawal Form F-l
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APPENDIX G. RISK MANAGEMENT PROGRAM REQUEST TO CONSOLIDATE EPA
FACILITY ID NUMBERS
EPA Facility Identification #:
EPA Facility Identification #:
EPA Facility Identification #:
Facility Name:
Facility Location Address:
City: State: Zip Code:
The facility listed above has been assigned more than one EPA Facility ID Number. This form requests
the EPA Facility ID Numbers to be consolidated to a single ID Number. Please de-activate
additional/incorrect Facility IDs Numbers.
Operator/Owner Name Official Title Date
PLEASE MAIL THIS REQUEST TO CONSOLIDATE EPA FACILITY ID NUMBERS FORM PROMPTLY TO:
U.S. Environmental Protection Agency
Attention: RMP Reporting Center
P.O. Box 10162
Fairfax, VA 22038
If you prefer to send this Request to Consolidate EPA Facility ID Numbers Form by certified mail,
courier or overnight mail (e.g., Fed Ex, UPS, etc.), please address it to:
RMP Reporting Center
c/o CGI Federal, Inc.
12601 Fair Lakes Circle
Fairfax, VA 22033
Appendix G: Risk Management Program Request to Consolidate EPA Facility ID Numbers G-l
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