Risk Management Plan RMP eSubmit Manual


United States
rTp«A Environmental Protection
&¦¦¦ M Agency
Office of Land and Emergency Management
March 2019
www.epa.qov/rmp
RISK MANAGEMENT PLAN
RMP*eSUBMIT USER'S MANUAL

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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, 2009, and 2014, 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 any time online.
RMP*eSubmit replaced RMP*Submit 2004. EPA no longer supports the RMP*Submit 2004
software.
CBI submissions via RMP*eSubmit beginning January 2013.
NAICS Codes update. The 2012 version of the North American Industry Classification System
(NAICS) codes has been integrated into RMP*eSubmit in March 2014.
NAICS Codes update. The 2017 version of the North American Industry Classification System
(NAICS) codes has been integrated into RMP*eSubmit in March 2019.

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TABLE OF CONTENTS
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	16
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	62
Section 6: Five-Year Accident History	68
Section 7: Prevention Program: Program Level 3	80
Section 8: Prevention Program: Program Level 2	92
Section 9: Emergency Response	101
Executive Summary	105
Chapter 3 How to Submit Your RMP	107
Certifying a Submission in RMP*eSubmit	107
Certification Statement	109
Chapter 4 Submitting Confidential Business Information and Paper RMPs	Ill
Confidential Business Information	Ill
Submitting Paper RMPs	Ill
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 Use these Forms	113
Chapter 7 Reporting Center Contact Information	114
RMP Reporting Center Contact Information	114
Acronyms of Terms	115

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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
WHERE TO GO FOR HELP
RMP Reporting Materials
EPA RMP Website: Includes the Risk Management Program rule, Off-Site Consequence Analysis
specific guidance and calculator, 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.
RMP Regulatory Questions
Contact the 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
Contact the RMP Reporting at 703-227-7650 / RMPRC@epacdx.net
Monday - Friday: 8:00 AM to 5:30 PM Eastern time
(Closed on Federal Holidays)

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CHAPTER 1- GETTING STARTED
Introduction
The RMP*eSubmit Users' Manual provides assistance in preparing and submitting Risk
Management Plans (RMPs). RMP*eSubmit application is a Web-based free tool EPA developed
to facilitate electronic submissions and is designed to significantly reduce errors in submissions
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:
• Create a new RMP online (if this is a first-time submission)
• Make corrections to, or perform a complete resubmission of, your RMP
• Identify and correct any validation errors in your RMP prior to submission
• Create CBI-claimed RMP submissions
• View/print a copy of your current 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 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 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
certify/submit an RMP.
Before You Start
Are you subject to the RMP reporting requirements? Check the requirements on EPA's RMP
Website or call the appropriate contact on "Where to Go for Help" page at the beginning of this
manual. For updates and resubmissions, check your five-year anniversary date if you already
have an RMP in the system.
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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 an email sent to the certifier/s 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 Program Levels. This 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 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
five 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 theirfacility.
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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 will take you step-by-step through the CDX registration process and 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, go to
the CDX website read the Warning Notice and Privacy Policy, then click "Register with CDX."
^53^ EP/K United Sta
tes Environmental Protection Agency

Hoove About
Recent Announcements Terms and Conditions
Help
CDXir Central Data Exchange
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 central 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.
Warning Notice and Privacy Policy
Warning Notice
In proceeding and accessing U.S. Government information and information systems, you acknowledge that you fully understand and consent to
all of the following:
1. you are accessing U.S. Government information and information systems that are provided for official U.S. Government purposes only;
2. unauthorized access to or unauthorized use of U.S. Government information or information systems is subject to criminal, civil,
administrative, or other lawful action;
3. the term U.S. Government information system includes systems operated on behalf of the U.S. Government;
4. you have no reasonable expectation of privacy regarding any communications or information used, transmitted, or stored on U.S.
Government information systems;
Read the Terms and Conditions. Then select the checkbox to accept the terms and conditions and
click on "Proceed."
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United States Environmental Protection Agency
Home About Recent Announcements Terms and Conditions Help
SEPA
CDX- Terms and Conditions B
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
In proceeding and accessing U.S. Government information and information systems, you acknowledge that you fully
understand and consent to all of the following:
1. you are accessing U.S. Government information and information systems that are provided for official U.S. Government
purposes only;
2. unauthorized access to or unauthorized use of U.S. Government information or information systems is subject to criminal,
civil, administrative, or other lawful action;
3. the term U.S. Government information system includes systems operated on behalf of the U.S. Government;
4. you have no reasonable expectation of privacy regarding any communications or information used, transmitted, or stored
on U.S. Government information systems;
I am this registrant. I will not share my account, and I accept the terms and conditions, above
Cance

CDX Help Desk: 888-890-1995 | (970) 494-5500 for International callers
EPA Home Privacy and Security Notice Accessibility About CDX | Frequently Asked Questions | Terms and Conditions | Contact Us
The Core CDX Registration page contains the Active Program Services List. You may
either search for the RMPESUBMIT program or scroll down the list and select
"RMPESUBMIT: Risk Management Plan."
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v>Em
Ho»iw AbowK Rmflt AnnouiK«m«ib
CD)^ Core CDX Registration
Ba
Terms md Condibom Help
ZB
Begin typing a program senrtce 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
|EntGf search criteria
ACRES: Assessment Cleanup and Redevelopment Exchange System
ARCS: Aircraft Reporting and Compliance System
BaSR: Burial at Sea
CDRS: Consent Decree Reporting System
CEDRI: Compliance and Emissions Data Reporting Interface
CROMERRS: CROss-Media Electronic Reporting Rule Services
CSPP: Submissions for Chemical Safety and Pesticide Programs
eDisclosure: Voluntary Disclosure System
EEP: General E-Enterprise Use
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 the CDX
website 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, see page 18 for more details)
&EPA
CO)t, Core CDX Registration
US
RpqtMralion information
Program Service
Rose
Risk Management Plan
wet wSectix*
Se*«t a role from the drop down list and prOvkfe any required addfconaJ	tf dflplkatole.
Select ftole	* 1
"•'•"•'-J"'
Certifying Official
Preparer
AfcnrtCBH i	.In in
M
T/2 3
5

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This brings us to the Core CDX Registration page. Provide the required information for
"Part 1: User Information" to create your CDX account.
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vycm Unted States Environmental Prate cOcn Agency
Home About Recent Announcements Terms and Conditions Hel p
CDX; Core CDX Registration
r \
1. Program Service v ^
y 2. Role Access V ^
3. User and Organization ^
g
Registration Information
Program Service
Role
Risk Management P a"
Cert->'ing Official
Please fill out all required fields marked with an asteriskf)
Part 1: User Information
User ID *
Title *
First Name *
Middle Initial
Last Name *
Suffix
Password *
Re-type Password *
Security Question 1 *
Security Answer 1 *
Security Question 2 *
Security Answer 2 *
Security Question 3 *
Security Answer 3 *
~
Mr
-Please Select-
-Pleass Seiect-
-Pleass Sslect-
-Pleasa 5e!sct-
Part 2: Organization Info
Zll
Enter orgariizsticr or organization ID
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Once completed, move on to "Part 2: Organization Information."
Use the search function to find your organization or you can request to add your organization.
To add your organization, click on the "request that we add your organization" link. Then,
enter your organization information and select "Submit Request for Access."
Part 2: Organization Info
Search
Enter organization or organization ID
Part 2: Organization Info
Organization Name *
Country *
Mailing Address *
Mailing Address 2
City *
State *
ZIP/Postal Code *
Email *
Re-enter Email *
Phone Number *
Phone Number Ext
Fax Number
Back to Search Results I Submit Request for Access
Cancel
UNITED STATES
-Please Select-
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Find your organization using the search function either by "Organization Name" or
"Organization ID." Click on your organization's corresponding "Organization ID" link.
Note: For illustration purpose we are displaying a search for "CGI"
Part 2: Organization Info
iaa
Enter organization or organization ID
Organization
ID
Organization Name
Address
City
State
ZIP
Code
16554
CGI FEDERAL GROUP INC
12601 FAIR
LAKES CIRCLE
FAIRFAX
VA
22033
19672
CGI GROUPO DE FEDERAL
12601 FAIR
LAKES CIRCLE
FAIRFAX
VA
22033
19673
CGI GROUPO DE FEDERAL2
12601 FAIR
LAKES CIRCLE
FAIRFAX
VA
22033
15091
CGI
8400
NEW
CARROLLTON
MD
20785
19860
CGI
ABC
ABC
AL
20987
16819
CGI
12601
FAIRFAX
AL
22015
Complete the additional contact information and select "Submit Request for Access."
Part 2: Organization Info
CGI FEDERAL GROUP INC
12601 FAIR LAKES CIRCLE
FAIRFAX, VA, US
22033
Email *
Re-enter Email *
Phone Number *
Phone Number Ext
Fax Number
Wrong organization information? Back to Search Results, Use advanced search or request that we add your organization.
Submit Request for Access
You will be directed to a Confirmation page and also receive an email confirmation.
&FPA
Lai m * United States Environmental Protection Agency
Home About Recent Announcements Terms and Conditions Help
CDXr Confirmation
3. User and Organization <~
A few more steps...
You will soon receive an email confirmation message (atjacob.noble@cgifederal.com) asking you to follow a link to activate your
user account. Follow that link to complete your registration. Please contact the help desk if you have any issues at 888-890-1995
or (970) 494-5500 for International callers.
Return to CDX Home
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Click on the link in the email to activate vour account.
Subject Core Registration Email Verification Request
You have successfully created an account with the EPA Central Data Exchange (CDX).
In order to complete your registration and begin using the system, you will need to confirm your account by clicking the hyperlink below and successfully logging in. You will need to enter the UserlD
(NOBLE2018) and Password that were selected during the
registration process.
https://test.epacdx.net/Registration/EmailValidation?code=9Q15251e-fe69-4a3e-9fd2-09b2d7e 78077
If you click the link and it appears to be broken, please copy and paste it into a new browser window.
Once you have successfully logged into your account, you may be required to provide additional information. Any additional information will need to be completed before you are able to access your
Program Service.
Please do not respond to this message. If you have questions concerning this request, you may contact us by email at helpdesk@epacdx.net or by calling the CDX Technical Support Staff through our toll
free telephone support on 888-890-1995 between Monday through Friday from 8:00 am to 6:00 pm EST/EDT. For International callers, the CDX Help Desk can also be reached at (970} 494-5500.
Sincerely
CDX Help Desk
United States Environmental Protection Agency - Central Data Exchange
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.
A
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E
PA
1 m * Unrted States Environmental Protection Agency
Home
About
Recent Announcements Terms and Conditions Help
CDX? Central Data Exchange
Log In
User ID
Password
Show Password
Log In to CDX
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Select and answer five Challenge Questions and click the "Save Answers" button.
WCrM United States Environmental Protection Agency
Home About Recent Announcements Terms and Conditions FAQ Help
CDX- Central Data Exchange
CDX Registration: Additional Verification
You are registered for a program that requires signature question verification. Please select five (5) signature questions and
answers. The questions that you select should be questions that you can remember, but difficult for anyone else to guess.
a Contact Us
Logged in as NOBLE201B (Log out)
Select 5 Signature Questions and Answers
Show Answers
Save Answers
This takes us to the Central Data Exchange page. Select the MyCDX tab and click the
"Certify Submission" link to add RMP facilities.
C CPA
United States Environmental Protection Agency
Home About Recent Announcements Terms and Conditions FAQ Help
CDXr Central Data Exchange
SS Contact Us
Logged in as NOBLE2018 (Loq out)
MyCDX
Inbox
My Profile Submission History E-Enterprise Portal
Services <$ Manage
| CDX Service Availability
Status ' Proaram Service Name » Role »
& RMPESllBMIT: Risk Manaaement Plan CeitifV Submission
See the status for all croaram sen/ices


News and Updates
No news/updates.
Add Program Service H Manage Your Program Services
NOTE : The Certify Submission design has been changedthough the functionality remains
same,
Note- By default, you will be directed to the "Pending Submissions" page, when you select
"Certify Submission" link.

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v>EPA
United Slates
Environmental Protection
Agency
Environmental Topics Laws & Regulations About EPA
RMP*eSubmit: Certify Submission
j Pending Submissions Pending Submissions
Non-Pending Submissions
Approved Facilities
Pending Facilities
Add Facilities
MyCDX
Inbox
Change Password
FAQs
Search EPA.gov
Contact Us Logged in as NOCHASSA {Logout}
New Page Layout
Certify Submission flow has been
modernized. White the design has
changed, available functionality remains
the same. Please refer to the User Guide
for further assistance.
You are currently unable to certify submissions for RMP
Facilities.
• Ifyou have prepared and submitted an Electronic
Signature Agreement (ESA) for a new facility, an RMP
Facility ID will be assigned to the facility and added to
your role upon approval.
• Ifyou have not prepared and submitted an ESA, click
the "Add Facilities" link on the left and submit an ESA by following the instructions.
Submitter Name (User ID) Facility Name (Facility ID) CDX ID/File ID
Click the "Add Facilities" link to create your Electronic Signature Agreement (ESA) for each
facility for which you plan to be the certifier. 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."
Note: For an Existing facility, you will enter the 12-digit EPA Facility ID number and for any New
facility you will be required to enter the complete Facility name and address.
&EPA
United States
Environmental Protection
Agency
Search EPA.gov
Environmental Topics Laws & Regulations About EPA
RMP*eSubmit: Certify Submission
Pending Submissions Add Facilities
Contact Us Logged in as NOCHASSA (Logout)
Non-Pending Submissions
Approved Facilities
Pending Facilities
Add Facilities
MyCDX
Change Password
FAQs
To add an existing facility, ensure that the 'Existing' radio button is selected and enter the EPA Facility ID
of the facility. To add a new facility, select the 'New' radio button and enter the facility name and facility
location address. After facility information is provided, click either the 'Save' button to view and print the
Electronic Signature Agreement (ESA) or the "Add Another Facility' button (as many facilities as necessary
may be added to the ESA).
Facility 1
0 Existing O New
EPA Facility ID
Add Another Facility I Save
Once you click the "Save" button, the ESA (with relevant facility information) will be displayed. A
copy of the ESA will also be stored in the MyCDX Inbox.
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Upon completion, CDX will prompt you to print the ESA. Print all ESA pages
Rlslc Management Plan (RMP)
Electronic Signature Agreement
This Electronic Signature Agreement |ESA| must be printed*, signedr and mailed to EPA (see
instructions fee low). Upon approval, privileges to certify submissions for the specified facilities
wilt toe added to your account.
m accepting the electron-c
Protection Agency |EPA) ~o sign
(CDXon behalf of:
Certifying Official:
Registrant Organization:
Registrant's Mailing Address 1:
Registrant's Mailing Address 2:
C1 z\t;
Stats:
Phone Number:
Email Address:
CDX User ID:
:r . ¦ t " r:
: =: *	: t-;1:
-a:" v,	-li as I:
Or.,v:
S+='a
Jacob Noble,.
iNsms of Cenpfymg
(If- A.gree to prat*:: - r 7	i f"" -e:e-e-~s	i ¦=¦	I ='" 17
password from use by anyone except me. I will not divulge or delegate my CDa user name
:• ; - =: : r - _ = ¦ : - - t ': „ . =	¦ : =.' : - = ¦ . ¦ J : i- :: - '
location; and 1 will not allow my password to be written into computer scripts to achieve
f ¦;	;
(2} Agree to contact the Central Data Exchange (CDX) Help Desk at 1-SSS-S90-1.935 as soon as
possibly but: no later than 2* no-urs, after suspecting or determining that my CDX user name
and password ano/or	: : signature creaermas na*e become iasi, stolen or tfinerwsse
compromised:
(3f	:• .	~ if	r r.' . - * a = ::;¦=£
whenever my user identification or password have he-en modified;
(41 Understand that CDX .reports the last date rny CDX user name and password were used
immediately after successfully logging into CDX;
„ if ftgree that 1 will review the consents of all RMP electronic submissions prior to subrrassion;
f jmderstarsd and agree that I will be held as legally bound, obligated, or responsible by my use
a-- my electronic signature as I would be using my hand-written signature;
= . -	_ ?ted states tnvironmentai
viz*'*- z : !>'z' '1 "2	to £PA's Centra! Data Exchange
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Two Uck Creek Water Treatment Plant
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15701
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COX USER ID for CERTIFYING OFFICIAL! NOBLE0125
Owner or Operator Authorization
¦ the necessary signs':
Q Oiptioiri m: Owner or Operator as C^rfi^ytas C" ff1 c. ? \
i(					t as t'hs owner or operator of this facHity wiH be t*r&
item! of Fsc-.t/ Cv¦ . * «—» ?—: s ,
behalf.
if%arrre of p'sc-'i't* 1
i Signature c-f Owner w Opera-tar'!
, as tfss> owner or operator of Shis fsciilty authorize
f zd be the- certifying of^dsri for
, with perrnissi-cm to submit docy.msnts on the faduty's
. i*s*, zy . s~~-	» i
t'D'Stef
(Official
-JRE AGREEMENT PROMPTLY TO;
Tie-r^c toy ce-ntrfieci msiJ, courier or a
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Once you have printed a!| 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 a][ 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 the AuthCode for each approved facility (sample shown below) will be
sent to the registered email address of the Certifying Official.
Ct
Subject Electronic Signature Agreement iESAj TESTi
This was sent from the test envlronnentl
Vour Electronic Sijiatuu-e Agreenent {ESA) has fflceived and APPROVES fo-r the t'aci 1 ity/faciliti»» sngten belou.
following are the fcithonizatlon Cooes assigned to each -facility that you have requested access -for*.
Please provide the appropriate Authorization Cade to the preparer that y&u assign for each facility/facilities. These
Authorization Codes a-e unique anci are associated to each Facility {EPA Facility id), preparers nust use the correct
Authorize*ion Code far each facility to prepare a subnliiiOfi using RMP*eSubmi£. For nore Snfornalion. please follow the
instructions in the SMP'eSubnlt - user guidelines.
Authorjiation Code: 9(ffS<>f:30-6e43-443$-5'341-8$f8;i(li391e6
EPA Facility 10: 18OT 0021 5689
facility: LoU Clericals
13:14 Warehouse Way
Charleston SC, 29dM
Unitecs States Environmental Protection Agency Central 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 (if other than the certifier)
so that he or she 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, he or she 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 also want to be a Preparer, you can
access this screen by returning to MyCDX. On the MyCDX page, choose "Add Program
Service."
14

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Enter RMP*eSubmit to perform a search arid select "RMPESUBMIT: Risk Management Plan"
EPA tinted States
Envwonmertal Protection Agency

Home About Rc
'cent Announcements Te
rms and Conditions FAQ Help
CDX~ Edit Account Profile
g Contact Us
Logged in as NOCHAS5A (Log outl
be
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
rmpesubmitj
RMPESUBMIT: Risk Management Plan
Select "Preparer" from the drop-down menu and click "Request Role Access."
v>EPA United States Envwwwnertal Protection Agency
Home About Recent Announcement Terms and Conditions FAQ Help
CD)fc Edit Account Profile
B Contact Us
Logged in as NOCHASSA (Log outl
mmmmhi
Registration Information
Program Service
Role
Risk Management Plan
Not selected
Select a role from the drop down list and provide any required additional information, if applicable.
Select Role	Preparer	T
Request Role Access
Enter your AuthCode and click the "Save" button.
aFPA
w \ United States Enwronmertal Protection Agency
Home About Recent Announcements Terms and Conditions FAQ Help
CDXr Core CDX Registration
.IMMMHIilWI
Registration Information
Program Service
Role
Risk Management Plan
Preparer
2 Contact Us
Logged in as NOCHASSA (Log out]
Authorization Code *
15

-------
Your MyCDX page will now display the roles that you have added to your profile (i.e., For
Certifying Official - Certify Submission and for Preparer - Prepare Submission),
NOTE: If the user has the "Preparer" role only, MyCDX page will show "Prepare Submission"
only.
v=/EPA
¦ n United State Environmental Protection Agency
Home About Recent Announcements Terms and Conditions FAQ Help
CDX: Central Data Exchange
S Contact Us
Legged in as NOCHASSA flog out']
MyCDX
Inbox
My Profile Submission History E-Enterprise Portal
Services c: Manage I
COX Service Availability
Status ' Prooram Service Name » Role »
See the status for all orraram services
RMPESUBMIT: Risk Manaaement Plan Certifv Submission
RMPESUBMIT: Risk Manaaement Plan PreDare Submission

News and Updates

No news/updates.
Add Program Service H Manage Your Program Services
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.
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
MyCDX
Application Profile Settings
Status Progran
& CEDRI1:
S
eNOI: El a
and VCP
iBoard
Employer i Organization
Name :
Program Client ID !
Program :
Proceed I Cancel
& ODS: Ozd
epieuriy juustcirrces
ODS: Ozone Depleting Substances
CGI FEDERAL INC0|
Preparer: 100000000571
Substances Review
Ozone Depleting
Substances
E3 Contact Us
Last Login 1 , 7 2014 12:05:1 0 PM
o news updates
From the RMP*eSubmit Home page you'll prepare your facility's Risk Management Plan (First-
16

-------
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 Preparer for one facility, you'll be directed to the
RMP*eSubmit Home page. If you have more than one facility, you'll see a dropdown list
from which you can choose the facility that needs to be updated (as shown above).
For a first-time submission, the RMP*eSubmit home page will resemble the screenshot below.
U.S. Environmental Protection Agency
RMP*eSubmit Home
Recent Announcements I Contact Us
Loggec in as. MOBL.E231S

About CDX
MyCDX
Inbox
Change Password
Frequently Asked
Questions
Help & Support
CDX Home
Terms & Conditions
Logout
Welcome to RMP'eSubmit. This is a tool developed by the U S. Environmental Protection Agency (EPA) to assist you in entering and submitting your Risk Management Plan (RMP)
Your facility will have submitted an electronic signature agreement (ESA) and named both a certifier and preparer(s) for your facility. You should find the name of your facility below.
If you would like to view your facility's most current RMP select the View Current RMP button.
A First-time submission requires that you enter information for all nine sections of the RMP A Section Selection function will appear on the next page
If you have previously submitted an RMP, your facility information will be pre-populated. In order to make a Correction to your existing RMP or a Resubmission, please click on the appropriate button for further
action.
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 submitted an RMP Resubmission by its anniversary date, you will not be able to
make an RMP Correction. You must submit an RMP Resubmission in this instance. The Correction button enables you enter the data for your facility and update the RMP as a correction.
A Resubmission is an update of all nine sections of your RMP. Revising your previous RMP appropriately and submitting the updated RMP Resubmission will re-set your five-year anniversary date. The
Resubmission button enables you enter the data for your facility and update the RMP as a Resubmission.
You can use RMP'eSubmit to claim Confidential Business Information (CBI) for First-time submission and Resubmission. Please contact the RMP Reporting Center at (703) 227-7650 for questions regarding CBI
reporting.
Selected Facility:
Facility ID
Facility Name
Anniversary
Date
Transaction
Type
Status
100000231956
RMP Test
Facility

For a Correction or Resubmission, the screen will resemble the screenshot below.
RMP'eSubmit Home
Recent Announcements | Contact Us Logged in as. NOBLE0125
Welcome to RMP'eSubmit. This is a tool developed by the U.S. Environmental Protection Agency (EPA) to assist you in entering and submitting your Risk Management Plan (RMP).
Your facility will have submitted an electronic signature agreement (ESA) and named both a certifier and preparer(s) for your facility. You should find the name of your facility below.
If you would like to view your facility's most current RMP, select the View Current RMP button.
A First-time submission requires that you enter information for all nine sections of the RMP. A Section Selection function will appear on the next page.
If you have previously submitted an RMP. your facility information will be pre-populated. In order to make a Correction to your existing RMP or a Resubmission, please click on the
appropriate button for further action.
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 submitted an RMP Resubmission by
its anniversary date, you will not be able to make an RMP Correction. You must submit an RMP Resubmission in this instance. The Correction button enables you enter the data for your
facility and update the RMP as a correction.
A Resubmission is an update of all nine sections of your RMP. Revising your previous RMP appropriately and submitting the updated RMP Resubmission will re-set your five-year
anniversary date. The Resubmission button enables you enter the data for your facility and update the RMP as a Resubmission.
You can use RMP'eSubmit to claim Confidential Business Information (CBI) for First-time submission and Resubmission. Please contact the RMP Reporting Center at (703) 227-7650 for
questions regarding CBI reporting.
Selected Facility:
Facility ID
Facility Name
Anniversary Date
Transaction Type
Status
100000026483
Indiana American Water-Muncie
06/10/2019

BHB33 E3B31
Select the appropriate button (Correction or Resubmission) and you will have access to the
RMP*eSubmit program to update your RMP.
17

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Adding the Preparer Role
Access the page CDX Terms and Conditions arid check the box to accept the terms and
conditions.
vvEPA
Un*«d jtntes Lm«wm«rital Protection Agency
Hurra* About RiumiI Aiiiiiiiiiii inuiil*. Tmn% .mil CmwIilicHK llirlp
CD)^ Terms arid Conditions somas*
The access and use of CDX Registration for the electronic submittal of environmental Information require the creation of a user
ID arid |>assword 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
In proceeding and accessing U.S. Government Information and Information systems, you acknowledge that you fully
understand and consent to all of the following:
1. you are accessing U.S. Government information and Information systems thar are provided for official U.S. Government
purposes only;
2. unauthorized access to or unauthorized use of U.S. Government Information or Information systems Is subject to criminal,
civil, administrative, or other lawful action;
3. the term U.S. Government information system Includes systems operated on behalf of the U.S. Government;
4. you have no reasonable expectation of privacy regarding any communications or Information used, transmitted, or stored
on U.S. Government information systems;
I am this registrant. I will not share my account, and I accept the terms and conditions, above.
Cancel
On the Core CDX Registration page, scroll to the "RMPESUBMiT: Risk Management Plan" link
and click.
SEPA
United Stales Environmental Protection Agency
CDX,
CDX Home About COX Recent Announcements Terms and Conditions Help
Core CDX Registration HContaaus
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).
1. Request Program Service
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
18

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This brings us to the Request Role Access section. From the drop-down menu, select
"Preparer" and click the "Request Role Access" button.
q,i=pA
^^^—1	United States Environmental Protection Agency
CDXHome About CDX Recent Announcements Terms and Conditions Help
CDX*
Core CDX Registration
[S3Contact Us
1. Request Program Service ©
3. Provide User and Organization Information 4. Confirmation
1
Registration Information I
Program Service Risk Management Plan

Role Not selected


Select a role from the drop down list and provide any required additional information, if applicable.
Certifying Official
Preparer
Request Role Access I Cancel
Enter (copy/paste) the AuthCode in the box provided and click "Save." The AuthCode will be
provided by your Certifying Official.
United States Environmental Protection Agency
Home About Recent Announcements Terms and Conditions FAQ Help
CDX. Core CDX Registration
1. Program Service ~
Registration Information
3 Contact Us
Logged in as RMPRC2G1Q fLoq oufcl
3. Organization Information
Program Service
Role
Risk Management Plan
Preparer
Authorization Code *
19

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For a first-time submission, the Welcome page will resemble the screenshot below.

About CDX
MyCDX
Inbox
Change Password
Frequently Asked
Questions
Help & Support
CDX Home
Terms «. Conditions
Logout
Welcome to RMP*eSubmit. ihis is a tool developed bv the U.S. Environmental Protection Agency (EPA") to assist you in entering and submitting your Risk Management
Plan (RMP).
Your facility will have submitted an electronic signature agreement (ESA) and named both a certifier and preparers) for your facility7. You should find the name of your
facility below.
If you would like to view your facility's most current RMP. select the Mew Current RMP button.
A First-time submission requires that you enter information for all nine sections of the RMP. A Section Selection function will appear on the next page.
If you have previously submitted an RMP. your facility information will be pre-pcpuiated. In order to make a Correction to your existing RMP or a Resubmission,
please click on the appropriate button for further action.
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
submitted an RMP Resubmission by its anniversary date, you will not be able to make an RAIP Correction. You must submit an RMP Resubmission in this instance. The
Correction button enables you enter the data for your facility and update the FA IP as a correction.
A Resubmission is an update of all nine sections of your PAIP. Revising your previous RMP appropriately and submitting the updated RAIP Resubmission will re-set
your five-year anniversary date. The Resubmission button enables you enter the data for your facility and update the RMP as a Resubmission.
WARNING! You can not use this system if you are reporting Confidential Business Information (CBI). Please contact the RMP R.eporting Center at 301-429-501S for
questions regarding CBI reporting.
Selected Facility:
Facility ID
Facility Name
maBmtmmm
Status
100000200702 |
| Jacob's Fertilizers
1 1

he
20

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For a Correction or Resubmission, the screen will resemble the screenshot below.
U.S, Environment*! Protection Agtncy
RMP'eSubmlt Home
HWCIM la RUP'KSuSm* ffc* «a KM tie By pia U S Inwewnaot* PnlNbgn Agon; v ifcPA) to Mti« v*u in *et*rrg «U suiwo/our »** Managunant PU»-. (RMP)
y.>ii f«i6r, »i« tia.s fcjarjwcafi Mattanc *yj(ia» agrnamorc, f;5A) ard nomad ^ tmfm *f»5 pnpafWO ta your UciMy fan WnjjS ffi« ti»-» of ,cur txM, bafeta
If HOW •rook) ton to oaw jtt* '-acte/s «wi cun*m HUP wMl thr Vtow Ciutant RMP
A FirM •&»* Mbmif tfon f»^u/W Wt you vtc ifDtnaton for al nX	o4 »« RMP A S««m hau* pr*,«ously iuMM an RMP you" (ac*ty ifAymtton a* bo p># populaaad In osto 10 mate a CwiKtioo to jw ••ntrg RMP o- a R«*«tjmi»»ion p*ase etc* an »» appfoprjje MM to futh# acDan
A Correction sfxxjW be uvkJ lo » change» at >oui !ac*ty (~ g cftB-qas t •margero ctrftacl ttfamatort faciMy addratt o> changa « K'.drl hotoru Ttn don not raoa** an uoiate Of yew antra RVtP Sutmfflr-g ¦ toceclBd RMP does not tkanga ,co' ft
annrcwiafy Bam d ycvr ftU? Ranting your rx*"CU» RMP txrofj**1, and Ju&mtbTj Ore x-ijted RMP Resuir-mon ¦« re-»«l your fve->*ai nvunFi date Th« Rctobmgtion
f» joa enlF Itw iifci (of yoi* anj '-p2a!» P* R>
m Coffibtfted 8u»m«i Wwraaaon (C®) fc* tntama (ubnaxicri and RHJansJ/Mi F^sm* certaci tne RliW Rftpanrij Cwiw 3t |?03)	au r»jariifig CBI rapanng
Satecnd Facility:
06.'1&2010
Select the appropriate button ("Correction" or "Resubmission") and you will be able to update
the RMP.
MOTE - You will be able to perform only a resubmission if:
•	your facility was deregistered or
•	the previous RMP submission had CBI claim.
21

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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, including if they
have a Program 1 process. The registration section requires facility identification
information. You cannot enter data for Sections 2, 3, 4, 5, 7, and 8 until you have entered
process-specific information.
' ST
Sim
U.S. Environmental Protection Agency
RMP*eSubmit Section Selection
Recent Announcements Contact Us
I EPA Facility ID:
100000215689
About CDX
MyCDX
Inbox
Change Password
Frequently Asked
Questions
Help & Support
CDX Home
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Loki Chemicals
Introduction to RMP*e Submit
Logged in as, GEFION1?
Transaction Type: First
Time Submission
Section 1. Registration

Enter Registration Information
Add Process

Section 2. Toxics: Worst Case
o
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.
22

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U.S. Environmental Protection Agency
fi A %
RMP*eSubmit Section 1.
Registration Information J
Iwjl
Recent Announcements Contact Us
Logged in as, GEFION13

EPA Facility ID:
100000215689
. , Transaction Type: First
Loki Chemicals T. ~ J.r .
Time Submission
About CDX
MyCDX
Inbox
Change Password
Frequently Asked
Questions
Help & Support
CDX Home
Terms & Conditions
Logout
1.1. Source Identification:
1.1.a. Facility name: *
1.1.b. Parent company #1 name:
1.1.c. Parent company #2 name:
| Loki Chemicals
| Norse Chemical Manufacturers
I I

1.2. EPA facility identifier:
100000215689

1.3. Other EPA systems facility ID:
I I

1.4. Dun and Brad Street numbers (DUNS):

1.4.a. Facility DUNS:
1 4 b- Parent company #1 DUNS:
1.4.C. Parent company #2 DUNS:
1.5. Facility location address:
1.5.a. Street 1: *
I I
11234 Warehouse Way
1.1 Source identification
1.1a. 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.
1.1 c. Parent company ft2 name:
If your facility is owned by a joint venture, enter the name of the second major owner here.
1.2 EPA facility identifier (display only):
The facility ID number for your facility is displayed. This is a pre-populated field that can't be
edited. If you need a new facility ID number, contact the RMP Reporting Center at 703-227-
23

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7650.
13 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 below facility identification numbers in the following priority order:
1.3.1 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, or by calling EPA's EPCRA, RMP & Oil
Information Center (also known as the Info Center), 1-800-424-9346.
1.3.2 Second, if your facility does not have a TRI ID, use the FRS query page and perform a
search under the facility selection. Enter your facility name on the Facility Identification
Option Value field and select the "Containing" option. Scroll down and check the "RMP"
box to perform a search. The result page will display the list of facilities that match your
search. You may zoom in to the map to obtain information about a specific facility by
hovering over the facility.
1.3.3 Third, use any one of the following numbers:
1.3.3.1 If your facility is covered by hazardous waste regulations under the Resource
Conservation and Recovery Act (RCRA), enter your RCRA Handler ID (12
characters). You can find your RCRA ID via Envirofacts RCRAInfo website.
1.3.3.2 If your facility is covered by regulations under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), enter your CERCLIS Site ID
(seven characters). You can find your CERCLIS ID via Envirofacts SEMS.
1.3.3.3 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 this
number from your local Dun and Bradstreet office (check the telephone book White Pages) or
look it up online: https://www.dnb.com/duns-number/lookup.html. If you do not have a DUNS
number, leave this field blank.
1.4b. Parent company ft1 DUNS:
Provide DUNS number of your parent company, 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.
24

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1.4c. Parent company ft2 DUNS:
Provide DUNS number of your second parent company if your facility is owned by a joint
1234 Warehouse Way
Charleston
SOUTH CAROLINA
29401 _
CHARLESTON vl
|32.738483
|-79.869919 |
| A2 Address Matching - Block Face	v |
| AB Administrative Building	v
1C ^
World Geodetic System of 1984~ v
| Required only if 1_5i is selected as Interpolation-Map or
Interpolation-Photo
| Erik Snorri	|
1843 | - fl23 | -14567 |
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.
1.5a. Street 1:
Provide your facility location address.
1.5b. Street 2:
Provide any additional facility location address information.
1.5c. City:
Provide the city name from your facility location address.
1.5d. State:
This is a pre-populated field and can't be edited.
venture. Otherwise, leave this field blank.
| 1.5. 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: *
I Facility latitude and longitude (decimal degrees):
1.5.g. Latitude (dd dddddd): *
1.5-h. Longitude (ddd dddddd): *
1.5.i. Lat/Long method: *
1.5.j. Lat/Long description: *
1.5-k. Horizontal accuracy measure (m): *
1.5.1. Horizontal reference datum code: *
1.5.m.	Source map scale number:
I 1.6. Owner or operator:
1.6.a.	Name: *
1.6.b Phone: *
25

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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 on 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):
1.5g. 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 lat/long
(latitude/longitude) boundary for your facility's address, or it will be rejected by
RMP*eSubmit.
1.5h. Longitude (dd.dddddd):
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 lat/long
boundary for your facility's address, or it will be rejected by RMP*eSubmit.
1.51 Lat/Long method:
You also must indicate the method that you used to determine your facility's latitude and
longitude data. Select the method by which you obtained your lat/long coordinates from the
drop-down list.
1.5j. Lat/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 (GIS).
26

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Code Abbreviation Description
AB
Administrative Building
A building, structure, or portion thereof that houses the administrative
functions of a facility as opposed to production or manufacturing
activities
AE
Atmospheric Emissions
Treatment Unit
Equipment installed for the express purpose of treating chemical
emissions prior to their release into the atmosphere
AM
Air Monitoring Station
Equipment installed at a predetermined location for the automatic,
manual, or periodic collection of environmental air samples
AS
Air Release Stack
A free-standing vertical structure constructed for the conveyance and
release of chemical emissions into the air
AV
Air Release Vent
A horizontal structure constructed for the release of chemical
emissions into the air, typically from the side or roof of a building
CE
Center of Facility
A representative center point within the boundary of a facility
FC
Facility Centroid
The calculated center of a contiguous facility
IP
Intake Pipe
A pipe or intake opening constructed for the collection and
conveyance of water
LC
Loading Area Centroid
The calculated center of a portion of a facility associated with loading
activities
LF
Loading Facility
The portion of a facility associated with loading and/or transshipment
activities
LW
Liquid Waste Treatment
Unit
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
NE
NE Corner of Land Parcel
The northeast most corner or boundary of a land parcel
27

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Code Abbreviation Description
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
The portion of a facility associated with the treatment and/or disposal
of solid waste
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
information, please contact the EPA's Superfund TRI, EPCRA, RMP & Oil Information Center at 1-
800-424-9346 for additional guidance.
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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 1.5g and 1.5h,
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 MeadesRanch
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 S a. Name
Erik Snorri
1.6.b Phone: *
1.6.C. Street 1: *
1.6 d Street2:
1.6_e_ City: *
1 6 f State: *
1-6 g Zip: *
1.6.g Foreign country address: Country: :
1.6 f State/Province: *
1 6 h Zip/PostalCode
343
123
4567
1234 Warehouse Way
Charleston
SOUTH CAROLINA
29401
Edda Prose
1.7. Name and title of person or position responsible for Part 68 (RMP) implementation:
1.7.a. Name of person:
1.7.b. Title of person or position: *
1.7.C E-Mail address:
1.6 Owner or operator:
1.6a. 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.
30

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l.Se. City:
Provide the facility owner or operator's business mailing address, city. The city should be the
local legal community, such as 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.
l.Sg. 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.
1.6 g. Foreign country address (if applicable):
Country:
Provide the owner or operator's foreign business mailing address country.
1.6.}. 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: *
1.8 b Title *
1.8 c. Phone: *
1.8 d. 24-hour phone: *
1.8 e Ext or PIN:
1.8 f E-Mail address: *
I 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 www homepage address
| 1.10. LEPC:
Specify if Other selected:
1.11. Number of fulltime equivalent employees on site: *
PHI
| 1.12. Covered by:
1.12 a. OSHAPSM:
1.12 b EPCRA section 302:
1.12.C. CAA Title V:
(enter'N/A' if not applicable)
Other/Unknown
or Claim as CBI? ~
~
~
~
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. Even 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.
13 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 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 LEPC's name from a drop-down list
based on the facility county information you 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.
NOTE: If you do not know your LEPC's name, you can contact your local fire department or
State Emergency Response Commission (SERC).
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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.
| 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
I 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:
I 1.16. Will this RHP involve Predictive Filing?:
1.17. Processes
~
~
~
~
Other
~
To register covered processes return to Section Selection page.
Section 1: Add Process button
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 | -1 |
1.18.C. Street 1: * | |
1.18-d. Street2: | |
1.18.e. City: *
1.12 Covered by:
1.12a. OSHA's PSM:
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 refer to OSHA's PSM standard website.
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 LEPC that
states your facility has one of the listed EHSs 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:
34

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• 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 due to 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 name of 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 on the dropdown 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 can 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
35

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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. This
information can't be edited for an RMP Correction.
1.17 Processes
The following information includes a description of all elements in Section 1.17 Registration:
Processes.
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.
36

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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.
EPA Facility ID: 10QGOOOQ2M2
Farmers Coop Association ( Abilene )
Are you claiming Confidential Business Information (CBI) in this Section?
1QOW30515
Process ID:
Process Descriflfon
Anhydrous Ammonia
117 a Program lev*l *
42241 OBSOLETE COOE Fstm Supolits WMmiIwi [3
11T b-fWCS Codes '
Ammonia {anhydrous) (7664-41*7) (!")[~]
1 17 c Chemicals (regulated substances) *
RMP*eSubmit Section 1. Processes
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:
Program level 1
Program level 2
Program level 3
(unless eligible for Program 1)
Process has experienced no accident
in past 5 years that resulted in
significant off-site impacts,
No public receptors in worst-case
scenario, and
Emergency response coordinated
with local responders.
Process is not eligible for Program 1
or subject to Program 3.
Process is subject to OSHA PSM, or
process is in NAICS code 32211,
32411, 32511, 32518, 32518, 32519,
325199, 325211, 325311, or 32532.
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 interest 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
37

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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 Program Level cannot be edited for an RMP Correction.
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.
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. Che mica jlated 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.
1.17c.l Chemical name:
The chemical name field cannot be edited.
1,17c.2 CAS number:
The CAS number field cannot be edited.
Chemical type:
The chemical type field cannot be edited.
38

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Chemical threshold quantity:
The chemical threshold quantity cannot be edited.
l,17c.3 Chemical quantity (lbs):
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 2 'rth American Industry Classification System Manual.
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.
39

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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. Streetl: *
1 18.d. Street2:
1 18.e. City: *
1 18.f. State: *
1 18.g. Zip: *
1 18.g. If foreign country address: Country:
1.18.f. State/Province: *
1.18.h. Zip/Postal Code:
Discard Changes
Save and Return
An denotes critical or mandatory information.
A S3) 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. Streetl:
Provide the street address of the person who prepared the RMP for the facility.
1.18d. Street 2:
Provide any additional street address information for the person who prepared the
RMP for the facility.
1.18e. City:
Provide the city of the person who prepared the RMP for the facility.
1.18f. State:
Select the state of the person who prepared the RMP for the facility from the drop-down list.
1.18g. ZIP code:
Provide the ZIP code of the person who prepared the RMP for the facility.
1.18g. If Foreign country address: Country:
If the RMP Preparer is located in a foreign country, select the appropriate country from the
drop-down list.
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t.lSf. State/Province:
If the RMP Preparer is located in a foreign country, provide the appropriate country
state/province.
1.18h. HP/Postal code:
If the RMP Preparer is located in a foreign country, provide the appropriate country ZIP/postal
code.
41

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Section 2. Toxics: Worst-Case
The worst-case release scenario analysis of covered processes is 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.
Q
Mm
U.S. Environmental Protection Agency
RMP*eSubmit Section Selection
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Section 1. Registration
Loki Chemicals
Introduction to RMP*e Submit
Enter Registration Information 1
| Add Process |

Logged in as, GEFION13
Transaction Type: First
Time Submission
Section 2. Toxics: Worst Case
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. If you do
not wish to keep the information you've entered, click the "Discard Changes" button.
42

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M
a
PROl^
U.S. Environmental Protection Agency
RMP*eSubmit Section 2. Add Scenario
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Select a Chemical from the following list:
1000030114
Arsine (7784-42-1
Cancel ¦ Continue Add Scenario
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Select the "Continue Add Scenario" button.
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2.1. Chemical
Process Name: 1000030114
2.1.a. Chemical Name: Arsine
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. EPA's RMP Guidance for Ammonia Refrigeration Reference Tables or Equations
2.3.c EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
2.3.d EPA's RMP Guidance for Warehouses Reference Tables or Equations
2.3 e. EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
2.3.f. EPA's RMP*Comp(TM)
2.3 g Are a I Locations of Hazardous Atmospheres [ALOHA(R)]
o
o
o
o
o
o
o
If your facility is claiming Confidential Business Information (CBI) in this section, check the box.
If you're claiming CBI and have checked the box, a pop-up message will appear describing the
steps that must be taken by the Preparer.
2.1 Chemical
a. Process name:
This field contains the process description from when 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.
43

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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 dropdown
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
2.3.	Model Used: *
2.3.a. EPA's OCA Guidance Reference Tables or Equations
2.3.b. EPA's RMP Guidance for Ammonia Refrigeration Reference Tables or Equations
2.3.c. EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
2.3.d. EPA's RMP Guidance for Warehouses Reference Tables or Equations
2.3.e. EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
2.3.f. EPA's RMP*Comp(TM)
2.3.g. Areal Locations of Hazardous Atmospheres [ALOHA(R}]
2.3.h. Other model name (Specify)
Model Used Text (if Other): |
2.4.	Scenario:
o
o
o
o
o
o
o
®
. Em
2.5.	Quantity released (lbs):
2.6.	Release rate (lbs/minute):
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):
S3)
S3)
S3)
~a
Launch EPA's RMP*Compti?
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)
44

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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.
• Liquid Spill and Vaporization: A release of the substance in a liquid state with
subsequent vaporization.
2.5 Quantity released (lbs):
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 (lbs/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
For detailed information refer to the General Risk Management Program Guidance.
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.
45

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2.8 Wind speed (meters/second):
If you used the OCA guidance or one of EPA's model program guidance documents, enter or
edit to say 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, select F stability from the drop-down list. If you modeled yourscenario
separately, select the appropriate stability class used from the drop-down list.
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 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
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

~
2.13.b. Residences

~
2.13.c. Hospitals

~
2.13 d. Prison/Correctional facilities

~
2.13.e. Recreational areas

~
2.13.f. Major commercial, office or industrial areas

~
2.13.g. Other \_
2.14. Environmental receptors within distance to endpoint
2.14.a. National or State parks, forests, monuments
2.14.b. Officially designated wildlife sanctuaries, preserves or refuges
2.14.C. Federal wilderness area
2.14 d. Other r
~
~
~
46

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2.13	Public receptors within distance to endpoint:
Select one or more of the public receptors within the 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.
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 the 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. Passive mitigation considered
2.15.a. Dikes
2.15.b. Enclosures
2.15-C- Berms
2.15-d. Drains
2.15.e. Sumps
2.15.f. Other |
I 2.16. Graphic file
Load/Unload File
~
~
~
~
~
Save and Return
An denotes critical or mandatory information.
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You are in an encrypted secure session.
Select one or more of the passive mitigation measures 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
47

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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.
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 ordisposal.
f.	Other: List other types of passive mitigation.
2.16 Graphic file:
You may load one graphic file to illustrate each release scenario by clicking the "Load/Unload
File" button. Entering a graphic 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 graphic file in your RMP that you would like to remove, you can also
delete it 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."
48

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Section 3. Toxics: Alternative Release
The Alternative release scenario analysis process of Program 2 and Program 3 processes is as
follows:
Present one alternative release scenario for each regulated toxic substance held above
the threshold quantity in a Program 2 or 3 process, including the substance considered
in the worst-case analysis.
Present one alternative release scenario to represent aM flammable substances held
above the threshold quantity in a Program 2 or 3 process.
Note that alternative release scenarios should 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
o
Section 4. Flammables: Worst Case

Section 5. Flammables: Alternative Release
Section 6. Five-Year Accident History
Select the "Add Scenario" button under Section 3. 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 button to enter more data.
If you do not wish to keep the information you've entered, click the "Discard
Changes" button.
49

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The following is a discussion of each element in Section 3. Toxics: Alternative Release.
RMP*eSubmit Section 3. Toxics: Alternate Release
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EPA Facility ID:
100000215689
3.1. Chemical
3.1 b Percent weight of chemical:
3.2. Physical state: *
3.3. Model Used: *
3.3.a. EPA's OCA Guidance Reference Tables or Equations
3.3 b EPA's RMP Guidance for Ammonia Refrigeration Reference Tables or Equations
3.3 d EPA's RMP Guidance for Warehouses Reference Tables or Equations
3.3.e EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
3.3 f. EPA's RMP*Comp(TM)
3 3 g Areal Locations of Hazardous Atmospheres [ALOHA(R)]
3.1 a Chemical Name
3.3.c EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations O
Process Name:
Are you claiming Confidential Business Information (CBI) in this Section? ~
Loki Chemicals
Arsine
1000030114
o
o
o
o
o
o
Transaction Type: First
Time Submission
3
m
3.1 Chemical
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.
a. 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.
b. 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
50

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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 listed 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
/. EPA's RMP*Comp™
g. EPA's Areal Locations of Hazardous Atmospheres (ALOHA ®)
Other	^
G3
I 3
1 aunch FPA's RMP*Comnd^
~
~
~
~
~
~
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 itscapacity
•	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
h. Other model name (specify)
3.4.	Scenario: *
Scenario Text (if Other selected):
3.5.	Quantity released (lbs): *
3.6.	Release rate (lbs/minute): * ***
fSHTl
3.7.	Release duration (minutes): *
3.8.	Wind speed (meters/second): *
3.9.	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
313 b. Residences
3.13-C. Hospitals
3.13-d. Prison/Correctional facilities
3.13.e. Recreational areas
3.13.f. Major commercial, office or industrial areas
3.13.g. Other |
51

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• Other (specify): Specify your scenario if not described in the drop-down menu
3.5 Quantity released (lbs):
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 (lbs/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
For detailed information refer to the General Risk Management Program Guidance.
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 liquefied by pressurization alone, or a gas liquefied 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 liquefied 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.
For detailed information refer to the General Risk Management Program Guidance.
3.8 Wind speed (meters/second):
If you used the OCA guidance or one of EPA's model program guidance documents, indicate
three 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
52

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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 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:
9.345 miles should be reported as 9.3 miles
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.
53

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3.15. Passive mitigation considered
3 15 a Dikes
3.14. Environmental receptors within distance to endpoint
3.14 a National or State parks forests, monuments
3 14 b Officially designated wildlife sanctuaries, preserves or refuges
3 14 c. Federal wilderness area
3.15 f Other
3.14.d. Other
3.15.e. Sumps
3.15 b Enclosures
3.15.C. Berms
3.15 d Drains
~
~
~
~
~
~
~
~
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, orareas
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 of 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 ordisposal.
f. Other: (specify)
54

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I 3.16. Active mitigation considered
3.16.a. Sprinkler systems
~
3.16.b. Deluge systems
~
3.16.c. Water curtain
~
3.16 d Neutralization
~
3.16.e. Excess flow valve
~
3.16-f. Flares
~
3.16.g. Scrubbers
~
3.16 h Emergency shutdown systems
~
3.16.i. Other Q
~
I 3.17. Graphic file
Load/Unload File
Discard Changes
Delete Scenario
None
Save and Return
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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 of 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 Graphic file:
You may load one graphic file to illustrate each release scenario by clicking on the
"Load/Unload File" button. Entering a graphic file name in this field will not automatically cause
that file to be included in your RMP submission. Graphics will be accepted in either GIFor
55

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JPEG file format. If you have a graphic file present in your RMP that you would like to remove,
you can use the "Load/Unload File" button to do so.
56

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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
Add Scenario
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
U.S. Environmental Protection Agency
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No 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 117 in Correction mode.
An denotes critical or mandator)1 information.
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
57

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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.
NOTE: If you do not wish to keep the information you've enteredclick the "Discard
Changes" button.
I Am • mlv
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4.1. Chemical
Process Name:
Grain Drying
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4.1.a. Chemical Name:
4.2. Model Used: *
Propane
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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 Distributors Reference Tables or Equations
©

4.2.f. EPA's RMP*Comp(TM)
©

4.2.g. Other model name (Specify)

Model Used Text (if Other):

4.3. Scenario: *
Vapor Cloud Explosion

M:?l
4.4. Quantity released (lbs): *
I

4.5. End Point Used: *
1PS1

4.6. Distance to endpoint (miles): *
Launch EPA's RMP'Compt?'

4.7. Estimated residential population within distance to endpoint (numbers): *

4.1 Chemical
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.
a. 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
/. EPA's RMP* Comp ™
g. Other model name (specify)
58

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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 (lbs):
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
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 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.
59

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I 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.e. Recreational areas
4.8-f. Major commercial, office or industrial areas
4.8.g.	Other
I 4.9. Environmental receptors within distance to endpoint
4.9.a.	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
4.10.b. Other
I 4.11. Graphic file
Load/Unload File
~
~
~
~
~
~
~
~
~
~
None
Discard Changes
Delete Scenario
Save and Return
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.
b.
c.
d.
e.
f.
g-
Schools: Public and private elementary, secondary, or post-secondary educational
institutions (e.g., colleges).
Residences: Public and private residences and dwellings wherever people live.
Hospitals: Public and private hospitals. Places that provide emergency care and/or
long- term care for the sick and elderly.
Prisons/Correctional facilities: Prisons where men or women are incarcerated. Holding
places or state of confinement for criminals.
Recreation areas: Recreation areas include stadiums, parks, and public pools.
Major commercial, office, or industrial areas: Commercial, office, or industrial areas
include industrial parks, office buildings, shopping malls, commercial areas, and
commercial farms.
Other: Include any other additional information here
60

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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 are
defined as 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.
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 of the worst-case scenario or alternative release scenario. If the
option for field 4.10.a. do 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 name:
You may load one graphic file to illustrate each release scenario by clicking on the
"Load/Unload File" button. Entering a graphic 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 graphic file present in your RMP that you would like to remove, you
can also use the "Load/Unload File" button to do so.
61

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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
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

1
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.
NOTE: If you do not wish to keep the information you've enteredclick the "Discard
Changes" button.
W$ A '-M
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5.1. Chemical
Process Name:
5.1.3- Chemical Name:
5.2. Model Used: *
Grain Drying
Propane
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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
(0)

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):

5.3. Scenario: *
Vapor Cloud Explosion T

Scenario Text (if Other selected):

PHD
5.4. Quantity released (lbs): *

5.5. Endpoint used: *
1 PS! * LFL value: " % Volume

5.6. Distance to endpoint (miles): *
5 Launch EPA's RMP'CompCP
62

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5.1 Chemical
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.
a. Chemical name:
The regulated flammable chemical you evaluated in the worst-case scenario.
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)
63

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5.4 Quantity released (lbs):
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.
64

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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
I 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
I 5.10. Passive mitigation considered
5.10.a.	Dikes
5.10.b. Fire walls
5.10.C. Blast walls
5.10.d. Enclosures
5.10.(
. Other
I 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
n
0
D
~
m
~
~
0
B
s
n
~
~
~
o
~
0
5.11.e. Other
I 5.12. Graphic file
Load/Unload File
Discard Changes
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.
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)
65

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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 of 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 from 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. Excess Flow Valve: A system for diverting overflow.
e. Other (specify):
5.12 Graphic file name:
You may load one graphic file to illustrate each release scenario by clicking on the
66

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"Load/Unload File" button. Entering a graphic 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 graphic file present in your RMP that you would like to remove, you
can use the "Load/Unload" File button to do so.
67

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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:
11000025829 (111339) Loki Chemicals has prepared a unified Ri v
Add Program ¦ Update/Delete Program
Section 8. Prevention Program: Program Level 2
Section 9. Emergency Response
Enter Emergency Response
Executive Summary
m
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.
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 and enter data in Section 6. Five-Year Accident
History.
68

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6.4.	Release duration:
6.5.	Chemicals involved:
Loki Chemicals
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: *
ED
E3J
6.6. Release event (must select at least one): *
6.6.a. Gas release:
6.6.d. Explosion:
~
6.6.b. Liquid
spills/evaporation:
6.6.e.
Uncontrolled/Runaway
reaction:
~
~
e AM «§! PM
Select NAICS code
Hours(HHH)
Minutes(MM)
~
6.7. Release source (must select at least one): *
6.7.a. Storage vessel:
6.7.d. Transfer hose:
6.7.g. Joint:	~
6.7.b. Piping:
6.7.e. Valve:
6.7.h. Other (specify):
~
~
6.7.c. Process vessel:
6.7.f. Pump:
6.8. Weather conditions at time of event: *
6.8.a. Wind speed:
6.8.b. Temperature (°F):
6.8.e. Unknown weather conditions (check if a-d are all unknown): 0
Units:
6.8.c. Atmospheric stability
Wind direction:
6.8.d. Precipitation present: 0
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 steps
that must be taken by the Preparer,
6.1	Date of acciden t:
Enter the date 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.
6.3	NAICS Code of process involved:
Provide a NAICS code by using the NAICS Code Selector field to select the North American
Industry Classification System (NAICS) codes associated with your covered processes.
69

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Transact
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
Please select...
To cancel your selection click the "Discard Selection" button. To populate your selection click the "Populate Selection" button.
Discard Selection
Populate Selection
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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 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 2017 North American Industry Classification System Manual.
Once you've selected the sector that most appropriately reflects 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 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 without
saving and returns you to the previous screen, Section 6. Five-Year Accident History.
70

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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:
EHT1
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)] (624-64-6) (F)
2-Methyl-1-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)
Acrylonitrile [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 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 (lbs): 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.1, report the maximum quantity (in pounds) held in the covered process at
any one time during the calendar year to two significant digits. Forexample:
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.
b.	Liquid spills/evaporation: A liquid spill/evaporation is a release of the substance in
a liquid state with subsequent vaporization. Fire: A product (e.g., fuel) in a state of
71

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combustion.
C. Explosion: A rapid chemical reaction with the production of noise, heat, and
violent expansion of gasses.
d. 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 orgas.
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, 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,
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:
72

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a. Wind
i.	Wind speed: Wind speed is an estimate of how fast the wind istraveling.
ii.	Wind speed units: Indicate the units in which the speed is expressed as 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 forsouth-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 (fordaytime
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 and 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.
SURFACE WIND SPEED AT 10
METERS ABOVE GROUND
DAY
NIGHT*
Meters per
second
Miles per hour
Incoming Solar Radiation
Thinly Overcast
or > 4/8
low cloud
<3/8
Cloud
Strong**
Moderate
Slight***
< 2
<4.5
A
A-B
B


2-3
4.5-7
A-B
B
C
E
F
3-5
7-11
B
B-C
C
D
E
5-6
11-13
C
C-D
D
D
D
>6
>13
C
D
D
D
D
d. Precipitation present: Precipitation may take the form of hail, mist, rain, sleet,
73

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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: *
Public responders
Public
6.9-b. Injuries: *
6.9.C. Property damage ($): *
6.10. Known off-site impacts (enter numbers only):
S3)
6.10.a.
Deaths: '
6.10.d.
Evacuated: '
6.10.g. Environmental damage
6.10.g.1. Fish
or animal kills
6.IO.9.4. Soil
contamination
El
6.10 b
Hospitalizations:
6.10.e.
Sheltered-in-
place: *
6.10.g.2. Tree,
lawn, shrub or ~
crop damage
6.10.C. Other medical
treatments: *
6.10.f. Property
damage ($): *
6.10.g.3. Water
contamination
~
~
6.10.g.5. Other
(specify)
On-site impacts:
Complete each of the following regarding 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), 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:
. Employees or contractors
i. Public responders (example: fire department personnel)
ii. Public (example: visitors)
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 under standing
74

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orders from a physician (OSHA Oil 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 injuriesas:
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, enterO.
6.10 Known offsite impacts:
These are impacts you should be aware of (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 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., 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 require hospitalization (i.e.,
admittance to the hospital). If there were no known off-site hospitalizations, enterO.
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 require
medical treatment. If there was no known medical treatment, enterO.
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)
to prevent potentially harmful exposure should be considered evacuated. If there
75

-------
were no evacuations, enter 0.
e. Sheltered-in-place: Estimate the number of people who sheltered-in-place during
the accident. Sheltering-in-place occurs when the incident commanderorders
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.
1. Fish or animal kills
2. Tree, lawn, shrub, or crop damage
3. Water contamination
4. Soil contamination
5. Other (specify)
.QUI
6.11. Initiating event:
6.11.a. Equipment
failure:
6.11 .d. Unknown:
6.12. Contributing factors:

6.12.a. Equipment
failure
6.12.d.
Overpressurization
~
~
S.12.g.
Maintenance
activity/inactivity
¦
6.11.b. Human
error:
6.12-b. Human
error
6.12.e. Upset
condition
6.12.h Process
design failure
6.12.k.
Management error
~
~
~
~
6.11.C. Natural
(weather
conditions,
earthquake):
6.12.C. Improper
procedures
6.12.f. By-pass
condition
6.12.i. Unsuitable
equipment
~
~
~
6-12.j. Unusual
weather
conditions
6.12.1. Other
(specify)
6.11 Initiating event:
Select the check box for the one initiating event that best describes the immediate cause of the
accident.
76

-------
a. Equipment failure: A device or piece of equipment failed or did not function as
designed. For example, the vessel wall corroded orcracked.
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 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 a 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.
C. Improper procedures: The procedure did not reflect the proper method of
operation, omitted steps that affected the accident, or 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 exceeded 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, or earthquakes 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
77

-------
include inadequate training, inadequate oversight, inadequate hazard analysis, or
other management-related factors.
I. Other (specify).
6.13. Off-site responders notified: *
6.13.a- Notified
only:
6.13.d. Unknown: ©
6.13-b. Notified
and responded:
6.13.e. Other
(specify):
©
©
6.13.C. No, not
notified:
6.14. Changes introduced as a result of the accident: '
6.14.a.
Improved/upgraded Irl
equipment
6.14-d. Revised
operating
procedures
6.14.g. Revised
emergency
response plan
6.14.j. None
o
~
~
6 14 b
Revised Inl
maintenance
6.14.e. New
process O
controls
6.14.h.
Changed
process
6.14.k. Other
(specify)
o
6.14.C. Revised
training
6-14-f. New mitigation
systems
6.14-i. Reduced
inventory
o
n
Q
Discard Changes
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 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.
e. New process controls: New process designs and controls were installed tocorrect
problems and prevent recurrence of an accidental release.
78

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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).
79

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Section 7: Prevention Program: Program Level 3
Complete this section for each prevention program you report for a Program 3 process. You wil
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 Q
Select a Prevention Program from the following list to update or delete:
P1000025829 (111339) Loki Chemicals has prepared a unified Ri v
Update/Delete Program
Section 8. Prevention Program: Program Level 2
Section 9. Emergency Response
Enter Emergency Response
Executive Summary
Enter Executive Summary
Return to RMP*e Submit 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.
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.
1. 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).
80

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2. 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 completed or submitted 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 those 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 to comply 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 (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,
81

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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.
The following is a discussion of each element in Section 7. Prevention Program: Program Level 3.
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 unite."
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
that is unique to each.
U.S. Environmental Protection Agency
RMP*eSubmit Section 7. Add Process NAICS Code
Recent Announcements Contact Us
EPA Facility ID:
100000215689
7.1. Select NAICS code for process: *
Loki Chemicals
Logged in as, GEFI0N13
Transaction Type: First
Time Submission
1000030165Refridgeration

| 111339
1
Cancel
1
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 for 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.
U.S. Environmental Protection Agency
i RMP*eSubmit Section 7. Add Chemical ]
"1

Logged in as, GEFION13
HI EPA Facility ID: 100000215689
Loki Chemicals
Transaction Type: Resubmission
Program 3 ID:
Process:
NAICS:
1000026202
1000030676 Fertilizer
11511
I 7.2. Select Chemical:
Nitric acid (cone 80% or greater) (7697-37-2) (T) *
Continue Add Chemical
82

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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.
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.
d. 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:
83

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7.4.D. MAJOR HAZARD
DESCRIPTION
1. Toxic release
If an accidental release occurred, a regulated toxic substance could be released.
For listed toxics, a toxic release will always be a major hazard.
2. Fire process
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.
3. Explosion
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.
4. Runaway reaction
An uncontrolled reaction that proceeds at an increasing rate.
5. Polymerization
A chemical reaction that produces the bonding of two or more monomers.
6. Over pressurization
Instantaneous energy release or detonation.
7. Corrosion
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.
8. Overfilling
Filling a tank or vessel beyond its maximum safe capacity.
9. Contamination
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., H20) is difficult.
10. Equipment failure
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.
11. Loss of cooling, heating,
electricity, instrument air
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.
12. Earthquake
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.
13. Floods (Flood Plain)
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.
14. Tornadoes
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.
15. Hurricanes
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.
16. Other
Specify any other major hazards not listed above.
84

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e. Process controls in use: Select all 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
Control 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 can stop or retard 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.
85

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7.4.E. PROCESS CONTROL DESCRIPTION
19. Purge System
A system that replaces the atmosphere in a container with an inert substance to
prevent the formation of an explosive mixture.
20. None
None are applicable.
21. Other
Specify any other process controls that you may use on your process and that are
not specified above.
f. Mitigation systems in use: Select all 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, checkNone.
7.4.F. MITIGATION
SYSTEMS
1. Sprinkler systems
A system for protecting a building against a fire by means of overhead pipes that
release an extinguishing material through heat activated outlets.
2. Dikes
An embankment for controlling or holding back water
3. Fire walls
A wall constructed to prevent the spread of fire.
4. Blast walls
A heavy wall used to isolate buildings or areas that contain highly combustible or
explosive materials.
5. Deluge system
A system to overflow an area with a release of water or other extinguishing fluid.
6. Water curtain
A spray of water from a horizontal pipe through nozzles. The curtain may be activated
manually or automatically.
7. Enclosure
Something that facilitates the physical containment of a release within a structure
(e.g., a building).
8. Neutralization
Controlling a release by neutralizing the released chemical.
9. None
None are applicable.
10. Other
Specify any other mitigation systems you may have in place on your process that are
not listed above.
g. Monitoring/detection systems in use: Select all 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, checkNone.
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7.4.G. MONITORING &
DETECTION SYSTEMS DESCRIPTION
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 S02 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 that are not
listed above.
h. Changes since last PHA or PHA update: Select all changes made to the process or
part of the process since the last PHA. If none are applicable, check None.
7.4.H. CHANGES SINCE LAST PHA / PHA
UPDATE
DESCRIPTION
1. Reduction in chemical inventory
A decrease in the quantity of regulated substances stored on-
site.
2. Increase in chemical inventory
An increase in the quantity of regulated substances stored on-
site.
3. Change in process parameters
Examples of changes in process parameters include an increase
or decrease in temperature, pressure, flow rates, etc.
4. Installation of process controls
The addition of controls such as those described in 7.4 e. or 8.4
d.
5. Installation of process detection systems
The addition of systems such as those described in 7.4 g. or 8.4 f.
6. Installation of perimeter monitoring
systems
The addition of systems such as those described in 7.4 g. or 8.4 f.
7. Installation of mitigation systems
The addition of systems such as those described in 7.4 f. or 8.4 e.
8. None recommended
Select None recommended if the PHA team did not recommend
any changes to the process.
9. None
None are applicable.
10. Other (specify)
Specify any other changes made to the process since the last PHA
that are not listed above.
87

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7.5.	Date of most recent review or revision of operating procedures: *	!H
7.6.	Training
7.6.a. Date of most recent review or revision of training programs: *	!H
7.6.b.	Type of training provided (must select at least one) *
7.6.b.1. Classroom:	O	7.6.b.2. On the job:	O
7.6.b.3. Other (specify):
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.3. Demonstration:
7.6.C.4. Observation:	[7]	7.6.C.5. Other (specify):
7.7.	Maintenance
7_7.a. Date of most recent review or revision of maintenance procedures: *	ffl
7.7.b.	Date of most recent equipment inspection or test: *	iH
7.7.C.	Equipment most recently inspected or tested (equipment list): *
7.8.	Management of change
7.8.a.	Date of most recent changes that triggered management of change procedures:	HI
7.8.b. Date of most recent review or revision of management of change procedures: * IH
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 68.7.
88

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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.a. 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
7.11.a. Date of most recent incident investigation (if any):
7.11.b. 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 most
recent compliance audits: This may be left blank if there were no changes.
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 there is one. 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.
91

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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
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.
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.
1. 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).
2. 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,
92

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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
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,
93

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you have reviewed or revised one or more prevention program elements as a result of a change
or art 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 unite."
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
that is unique to each.
RMP*eSubmit Section 8. Prevention Program: Program Level 2

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Transaction Type: Resubmissio

Prevention Program Description:
I 8.1. NAICS Code for process: *
I 8.2. Chemicals: *
8.3. Safety information
8.3.a. Date on which the safety information was last reviewed or revised: *
Are you claiming Confidential Business Information (CBI) in this Section? ~
[111992
View/Edit Description

8.3.b. Federal/State regulations or industry-specific design codes and standards used to demonstrate compliance with safety information requirement (must select at least one
8.3.b.1. NFPA 58 (or state law based on .
NFPA 58):
8.3.b.4. ANSI Standards: 0
8 3.b.7. Other (specify):
8.3.b.8. Comments
3.3 b.2. OSHA (29 CFR 1910.111):
3.3.b.5. ANSME Standards:
8.3.b.3. ASTM Standards
8 3.b 6 None
~
~
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.
94

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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 safetyinformation:
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.l 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 J. AST! 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
95

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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 adhere to any national standards such as those noted
above the Program 2 process 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.
,4. Hazard review
8.4.a. Date of completion of most recent hazard review or update *	|01/31/2014	| Iffl
4.b. Expected or actual date of completion of all changes resulting from the hazard review:	03/31/2014	Hi
4.c. Major hazards identified (must select at least one)
8.4.C.1. Toxic release:	0
8.4.C.4. Runaway reaction:
8.4.c.7. Corrosion:
8.4.C. 10. Equipment failure:	0
8.4.c.13. Floods:	0
8.4.c. 16. Other (specify):	|
S3)
8.4.C.2. Fire:
8.4.C.5. Polymerization:
8.4.c.8. Overfilling:
8.4.c.11. Loss of cooling, heating,
electricity, instrument air:
8.4.c. 14. Tornado:
~
~
0
0
~
,4.d. Process controls in use (must select at least one)
, QH)
8.4.d.1. Vents:
8.4.d.4. Scrubbers:
8.4.d.7. Automatic shutofFs:
8.4.d. 10. Keyed bypass:
8.4.d. 13. Backup pump:
8.4.d.16. Rupture disks:
8.4.d.19. Purge system:
8.4.d.21. Other (specify):
y
~
~
y
0
~
0
8.4.d.2. Relief valves:
8.4.d.5. Flares:
8.4.d.8. Interlocks:
8.4.d.11. Emergency air supply:
8.4.d.14. Grounding equipment:
8.4.d.17. Excess flow device:
8.4.d.20. None:
0
~
~
0
~
~
y
B.4.C.3. Explosion:
B.4.C.6. Over pressurization:
B.4.C.9. Contamination:
B.4.C.12. Earthquake:
B.4.C.15. Hurricanes:
B.4.d.3. Check valves:
B.4.d.6. Manual shutofFs:
B.4.d.9. Alarms and procedures:
B.4.d.12. Emergency power:
B.4.d.15. Inhibitor additions:
B.4.d.18. Quench system:
~
~
~
~
0
~
0
0
0
~
~
8.4 Hazard review:
The hazard review requirements for Program 2 processes can be found at 40 CFR 68.50.
96

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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.3. Fire walls:	~
8.4.e.6. Water curtain:	~
8.4.e.9. None:	~
8.4.f.3. None:
8.4.g.3. Change in process parameters: ~
8.4.g.6. Installation of perimeter	^
monitoring systems:
8.4.g.9. None:
1 HTTffl
[¦	|
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.
8.4.e. Mitigation systems in use (must select at least one) *
8.4.e.1. Sprinkler system:
8.4.e.4. Blast walls:
8.4.e.7. Enclosure:
8.4.e .10. Other (specify):
~
0
1
8.4.e.2. Dikes:
8.4.e.5. Deluge system:
8.4.e.8. Neutralization:
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:
8.4.f.4. Other (specify):	|
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:
8.4.g.4. Installation of process controls: 0
8.4.g.8. None recommended
8.4.g. 10. Other (specify):	|
8.4.g.5. Installation of process detection
systems:
8.4.g.7. Installation of mitigation
systems:
0
~
~
~
0
8.5. Date of most recent review or revision of operating procedures: *
97

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g. Changes since last hazard review or hazard review update:
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 review or 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
8.6. 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: @ 8.6.b.2. On the job:
8.6.b.3. Other (specify): I
[02/28/2014

8.6.C.3. Demonstration:
see equipment list for process
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: Ij£J 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:
Discard Changes ¦ Delete Program ¦ Save and Return
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03/31/2014
8.6 Training:
Training requirements for Program 2 processes can be found at 40 CFR 68.54.
98

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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 68.54 (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)) 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)
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 68.56 (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 ortest:
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.
99

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8.8 Compliance audits:
Compliance audit 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 the
compliance audit. This may be left blank if there were no changes or all changes are
complete.
8.9 Incident investigation:
a. Incident Investigation information can be found in the RMP regulation at 40 CFR
68.60 and 68.81. 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.
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.
100

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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:
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.
RMP*eSubmit Section 9. Emergency Response
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| 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:
9.8.f. State EPCRA Rules or Laws:
~
H
Charleston Co, Environmental Health
843 - 567 - 8901
H
~
n
B
O
n
9.8.g. Other:(specify)
Discard Changes
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101

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9.1	Written emergency response (ER) plan:
a.	Is your facility included in the community emergency response plan?
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 (ER) plan 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)(1). 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.
102

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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" if your ER plan includes information on
emergency health care.
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
note, 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.
103

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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 Countermeasure (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.
104

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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.

Section 9. Emergency Response
r

Executive Summary
r

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The following is a discussion of each element in the 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,
105

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"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,
and public notification and alert systems, as appropriate.
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 correct 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. This is the
confirmation that the submission has been sent to be certified OR rejected.

U.S. Environmental Protection Agency

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EPA Facility ID: 100000036392
North Regional Wastewater Treatment Plant Transaction Type: Resubmission
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Thank you for using RMP'eSubmit. Your RMP is submitted for certification. Shortly, an e-mail will be sent to your Certifier's mailbox that your RMP is ready for certification.
Facility ID 100000036392
Facility Name North Regional Wastewater Treatment Plant
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Submission Type
Resubmission

Reference Transaction ID
_e226d9e3-1742-441 f-b67f-e0954dc53dfe

Document Name
RMP000120180202114005NOBLE0125.zip

User ID
NOBLE0125

Submit Date
02/02/201811:40:10

106

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CHAPTER 3 - HOW TO SUBMIT YOUR RMP
Certifying a Submission in RMP*eSubmit
After the Preparer has prepared arid 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 "Submit to Certify." 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.
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RMP*eSubmit: Certify Submission
j Pending Submissions Pending Submissions
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Approved Facilities
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Here is a list of RMP submissions that have been prepared
and are awaiting review. Select the associated CDX ID/File
ID link to view the submission. After the submission has
been reviewed, you may select "Certify"or "Reject" to
initiate the final processing of the submission.
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Submitter Name (User ID)
Facility Name (Facility ID)
CDX ID/File ID
Action
Keith Graham (KEYEASY3)
Goodwine, IL (1000 0000 8715)
RM P0001201800181133
01KEYEASY3
Certify |
Reject
Charles Sforza (CSFORZA5)
Rinchem Company, Inc. CSC 37
Bensalem Warehouse (1000 0021
5322)
RM P0001201800111015
48CSFORZA5
Certify |
Reject
Lourdes Carrion (LYCARRION)
VanDeMark Chemical Inc. (1000
0013 3358)
RM P0001201710301133
03LYCARRION
Certify |
Reject
The Certifier can either (a) Certify or (b) Reject a submitted RMP. The Certifier may also
review the RMP before taking action, by selecting the link in the CDX ID/File ID column.
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 Approved Facilities Menu.
107

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<»EPA
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Facility ID
Facility Name
View Current
RMP
1000 0012 2967
ADM Test 01122019
16
1000 0014 8592
APS RESUBMISSION TEST JANUARY 16 2018
16
1000 0004 3623
AgVantage FS - Aplington
16
1000 00215518
Alloy Resource Corporation
16
1000 0010 1711
Alpharma Inc.
16
1000 0019 8476
Anchor Warehouse Services - PorterviUe Plant
16
1000 0017 7701
Arizona Public Service Company Redhawk Power Plant
16
1000 0015 4502
Arm-Eck Acquisition LLC - BNS
16
1000 0021 5509
Avanzar Interior Technologies, Ltd
16
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
Calhoun County Water Filtration Plant
1.1.b. Parent Company #1 Name
Calhoun County Water Authority
l.l.c. Parent Company #2 Name

1.2 EPA Facility Identifier
100000032975
1.3 Other EPA Systems Facility Identifier

1,4 Dun and Bradstreet Numbers (DUNS)
1.4.a. Facility DUNS

1.4.b, Parent Company #1 DUNS

1.4.c. Parent Company #2 DUNS

1.5 Facility Location
1.5.a. Street - Line 1
630 Smith Boozer Road
1.5.b. Street - Line 2

1.5.c. City
Wellington
1.5.d, State
AL
1.5.e. Zip Code - Zip +4 Code
36279-5829
1.5.f. County
CALHOUN
1.5,g. Facility Latitude [in decimal degrees)
33.864630
1.5.h. Facility Longitude {in decimal degrees)
-085.883850
1.5.i. Method for determining Lat/Long
interpolation - Map
l.S.j. Description of location identified by Lat/Long
Center of Facility
1.5.k. Horizontal Accuracy Measure (meters)
25
1.5.1. Horizontal Reference Datum Code
World Geodetic System of 1984
1.5.m. Source Map Scale Number
1
1.6 Owner or Operator
If the Certifier accepts arid proceeds with the submission, the Certifier will follow the next
process to electronically sign the certification statement.
108

-------
Certification Statement for a Correction
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 are true, accurate, and complete.
Click the "Accept" button to complete certification or click the "Decline" button to cancel the
certification process.
Authentication of CDX Credentials
Enter your CDX password to authenticate the submission and click "Login."
eSig nature Widget
1. Authentication
Log into CDX
User:
NOBLE0125
Password:
I	~)
Show Password
Login
Re-authentication of CDX Credentials
Now the user will be challenged with 1 of the 5 questions and answers from the registration
process. This step will re-authenticate your CDX credentials. Answer the question, then click the
"Answer" button.
Certifier's Name
Facility Name and Location Address
Jacob Noble
North Regional Wastewater Treatment Plant
2401 N. Powerline Rd.
Pompano Beach, FL 33069
1000 0003 6392
01/30/2018
jacob.noble@cgifederal.com
EPA Facility ID
Certification Signed Date
Certifier's Email
Decline
109

-------
eSignature Widget
1. Authentication
Log into CDX
User:
NOBLEQ125
Password:
••••••••
Show Password
Welcome Jacob Noble
2. Verification
Question:
Where did you first meet your
spouse?
Answer:
Show Answer
Answer
Electronic Signature
Click the "Sign" button to submit your RMP.
©Signature Widget
1. Authentication 2. Verification 3. Sign File
Log into CDX
Question:
User: Where did you first meet your
NOBLEQ125 spouse?
Password: Answer:
•"•**
Show Password Show Answer
Welcome Jacob Noble Answer
NOTE - Email notifications will be sent to the Preparer as well as the Certifier/s that the RMP has
been certified and submitted.
The Certifier wili see the following screen as an acknowledgement of the submission. The user
can select "Non-Pending Submissions" menu to get more details on the submission.
v>EPA
United Slates
Environmental ProtecEio
Search EPA.gov
Environmental Topics
Laws & Regulations
About EPA
RMP*eSubmit: Certify Submission
j Pending Submissions Pending Submissions
ogged in as N03LE0125 (Logoi
Non-Pending Submissions
Approved Facilities
Pending Facilities
The RMP submission has been digitally signed and
certified. To view additional information about the
submission, please go to the Non-Pending Submissions
I page.
Add Facilities
My CDX
New Page Layout
Certify Submission flow has been
modernized. While the design has
changed, available functionality remains
the same. Please refer to the User Guide
for further assistance.
Here is a list of RMP submissions that have been prepared
and are awaiting review. Select the associated CDX ID/File
ID link to view the submission. After the submission has
been reviewed, you may select "Certify"or "Reject" to initiate the final processing of the submission.
Change Password
Submitter Name (User ID)
Facility Name (Facility ID)
CDX ID/File ID
Action
Keith Graham (KEYEASY3)
Goodwine, IL {1000 0000 8715)
RM P0001201800181133
01KEYEASY3
Certify |
Reject
Charles Sforza (CSFORZA5)
Rinchem Company, Inc. CSC 37
Bensalem Warehouse (1000 0021
5322)
RMP0001201800111015
48CSFORZA5
Certify |
Reject
Lourdes Carrion (LYCARRION)
VanDeMark Chemical Inc. (1000
0013 3358)
RM P0001201710301133
03LYCARRION
Certify |
Reject
110

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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 that 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 j
Recent Announcements 1 Contact Us
Logged in as, GEFI0N13
EPA Facility ID: 100000215689 Loki Chemicals
Transaction Type: Resubmission
AbOUt CDX
MyCDX
Inbox
Change Password
Frequently Asked
Questions
Help & Support
CDX Home
Terms & Conditions
Logout

Are you claiming Confidential Business Information (CBI) in this Section? 19
| 2.1. Chemical
Process Name:
2.1.a. Chemical Name:
2.1.b. Percent weight of chemical:
I 2.2. Physical state: *L
2.3. Model Used: *
2.3.a. EPA's OCA Guidance Reference T:
2.3.b EPA's RMP Guidance for Ammonia
2.3.c. EPA's RMP Guidance for Waste
2.3.d. EPA's RMP Guidance for Warehoui
2.3.e. EPA's RMP Guidance for Chemical
2.3.f. EPA's RMP*Comp(TM)
2.3.g. Areal Locations of Hazardous Atmcj
2.3-h. Other model name (Specify)
Model Used Text (if Other):
PHT1
v\
I 2.4. Scenario: *
2.5. Quantity released (lbs):
a rate (lbs/minute):
mi
, .ED
Message from webpage
m
WARNING!!
You have chosen to submit Confidential Business Information (CBI).
If this is correct you are required to submit the following with your
RMP:
1) a paper copy of the substantiation for why this data element is CBI;
and
2) a paper copy of the unsanitized version
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
data will be reported to EPA as non-CBI data.
Refridgeration
Ammonia (anhydrous)
100 %
Gas liquified by pressure
©
©
©
©
©
%
©
©
Liquid spill and vaporization
16000
1600
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

-------
CHAPTER 5 - NOTIFYING EPA THAT YOUR FACILITY IS NO
LONGER COVERED BY RMP
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 must 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
number to resubmit. Keep a record of your Facility ID number upon de-registering. If you have
de-registered and do not have your Facility ID number, 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.
112

-------
CHAPTER 6 - PROPANE WITHDRAWAL FORM AND REQUEST TO
CONSOLIDATE EPA FACILITY IDS FORM
When to Use 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.
113

-------
CHAPTER 7 - REPORTING CENTER CONTACT INFORMATION
RMP Reporting Center Contact Information
i mprcgepacdx.net
703-227-7650
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
114

-------
Acronyms
ANSI	American National Standards Institute
ASTM	American Society of Testing Materials
AUTHCODE	Authorization Code
BLEVE	Boiling Liquid Expanding Vapor Explosion
CAA	Clean Air Act
CAS	Chemical Abstracts Service
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
FN	Facility Identification Number
GIS	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 Owned Treatment Works
PSM	Process Safety Management
RCRA	Resource Conservation and Recovery Act
RMP	Risk Management Plan
SDS	Safety Data Sheet
TRI	Toxic Release Inventory
UIN	Unique Identification Number
WGS	World Geodetic System
115

-------
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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APPENDIX A. RISK MANGEMENT 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:
Where to Send Completed Forms:
LI First-Time RMP Submission
U.S. Environmental Protection Agency


Attention :RMP Reporting Center
~ Correction to the Current RMP
P.O. Box 10162


Fairfax, VA 22038
(Submission Type = "C")



If you prefer to send this Risk Management Plan
C01
Clerical error corrected
Form by certified mail, courier or overnight mail
C02
Additional information supplied
(e.g. Fed Ex, UPS. Etc.), please address it to;
C03
Minor administrative change

C04
Notification of facility ownership change
RMP Reporting Center
C05
New accident history information
c/oCGI Federal, Inc.
C06
Change in emergency contact information
12601 Fairlakes Circle
C07
New data element required by EPA
Fairfax, VA 22033
C08
Optional data element requested by EPA

C09
Removed OCA description from executive


summary

~ Re-Submission (all 9 sections are updated and certified)

(Submission Type = "R")

R01
Newly regulated substance listed fcy EPA (40


CFR 68.190(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


68.190(b)(7))

R09
Voluntary update (not described by any of the


above reasons)

EPA Form 8700-25	-1-
Appendix A: Risk Management Plan Form	A-l

-------
Facility Name:
Executive S umma ry	KHA Facility ID# (leave blank for first submission only)
(attach a separate piece of paper if you need additional space)
ES
EPA Form 8700-25
Appendix A: Risk Management Plan Form
2-
A-2

-------
EPA Facility ID# (leave blank for 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 lor first submission only)
1.3 Other EPA Systems Facility Identifier (15 characters)
1.4 Dun and Broadcast Numbers (DUNS) (9 characters)
1.4a. Facility DUNS
1.4 b Parent Company #1 DUNS
1.4.c. 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.d. State
1 5.e. Zip Code Zip +4 Code
1.5.f. County (maximum 20 characters)
1,5.g Facility Latitude (report in decimal degrees)
1.5. h. Facility Longitude (report in decimal degrees)
+ADDD DDDDD D
+/- ODD D DDDD D
1.5.i. Method for determining Lat/Long (see User Manual for Codes)
1.5.j. Description of location identified by Lat/Long
(see User Manual for Codes)
1.5.k. Horizontal accuracy measure (meters)
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

-------
Facility Name:
EPA Facility ID# (leave blank for first submission only)
I Section 1. Registration
1.6 Owner or Operator	
1.6.a. Name (maximum 35 characters)
1.6.b. Phone
	
-----	
Owner or Operator Mailing Address	
1.S.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.f. State
1.6.g. Zip Code Zip+4 Code

1.7 Name, title, and email address of person or position responsible for RMP (part S8) implementation
1.7.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 6.a Emergency Contact
1 8 r) Name (maximum 35 characters)
1.8 b- Title of person or position (maximum 35 characters)








1.8.e 24-Hour Phone Extension/PIN # (maximum 10 characters)
1 e.f. Email address for emergency contact (maximum 100 characters) Enter N/A if not applicable
EPA Form 8700-25	-4-
Appendix A: Risk Management Plan Form

-------
Facility Name:
1
EPA Facility ID# (leave blank for first submission only)
1 Section 1. Registration
9. Other Points of Contact (Optional)
1,9.a. Facility or Parent Company E-mail Address
(maximum 100 characters)
1.9,b. Facility Public Contact Phone Number
1,9.c. Facility or Parent Company WVWV Homepage Address (maximum 100 characters)
1.10 Local Emergency Planning Committee (LEPC) (optional) (maximum30 characters)
1.11 Number of full-time equivalent (FTEs) employees on site
1.12, Covered by (select all that apply)
~	1.12.a. OSHAPSM
~	1.12 b. EPCRA section 302
L11,12.c. CAA Title V Air Operating Permit Program. If covered, specify permit ID# below.
1.13. OSHA Star or Merit Ranking (optional)
~ YES	~ NO
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)
~	1.15.a. OSHA	Ql.lS.f. Never had one
Ul1.15.b. State occupational safety agency	i_l1.15.g- Other (specify) (maximum 50 characters)
U 1.15.C. EPA
~	1,15.d. State Environmental Agency		
U1,15.e. Fire Department

1.16. Will this RMP involve Predictive Filing? (Optional)
~ YES
~ No
EPA Form 8700-25	-5-
Appendix A: Risk Management Plan Form
A-5

-------
Facility Name:
EPA Facility ID# (leave blank for first 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
jhotocopy of this page and report each process on a separate sheet.	
Process ID# (optional - for your reference only)
Process Description (optional -foryour reference only)
1.17.a. Program Level (select one)
~1	Q2	Q3
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 (lbs)
(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

-------
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
1.18.a. Name (maximum 70 characters)
1.18.b. Phone («
¦)>
1.18 c. Street - Line 1 (maximum 35 characters)
1 18 d Street - Line 2 (maximum 35 characters)
1.18.e. City (Maximum 30 characters)
1.18.f. State i	¦	i or
Foreign State or Province (Maximum 35 characters)
1.18.g. Zip Code Zip+4 Code
or Foreign Country
(Max 2 characters)
1.18.h. RMP Preparer Foreign Zip Code
EPA Form 8700-25
-7-
Appendix A: Risk Management Plan Form
A-7

-------
Facility Name:		.	_	_	_
¦¦ Section 2. Toxics: Worst Case	EPA	ll)# (leave blank for first subm ission "W
¦ ( 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.sl Name (maximum 100 characters)
2.1.b- Percent weight of chemicals (if in a mixture)
2.2. Physical state (select one)


~	2.2.a. Gas
~	2.2. b. Liquid
~ 2 2 c
LI2.2.d.
Gas liquified by pressure
Gas liquified by refrigeration
2.3. Model Used (select one or enter another model name in Other below)
~	2.3.a.	EPA's OCA Guidance Reference Tables or Equations
~	2.3.b.	EPA's RMP Guidance for Ammonia Refrigeration Reference Tables or Equations
~	2.3.d. EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
~	2 3.e	EPA's RMP Guidance for Warehouses Reference Tables or Equations
~	2.3.f.	EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
~	2.3.g.	EPA's RMP* Comp™
~	2.3.h.	Areal Locations of Hazardous Atmospheres (ALOHA®)
~	2.3.Z.	Other model (specify) (maximum 255 characters)
2.4. Scenario (select one)

~ 2.4,a. Gas Release
LI 2.4.b- Liquid Spill and Vaporization
2.5. Quantity released (lbs)
2.6. Release rate (lbs/minute)


2.7. Release duration (minutes)
2.8. Wind speed (meters/second)
2.9. Atmospheric stability class (A-F)
2.10. Topography (select one)

~ 2 10 a. Urban
~ 2.10.b. Rural
2.11. Distance to endpomt (miles)
EPA Form 8700-25	-8-
Appendix A: Risk Management Plan Form	A-8

-------
Facility Name:	
I Section 2. Toxics: Worst Case
2
EPA Facility ID# (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)
~	2.13.a. Schools	LI 213.g, Other (specify) (maximum 200 characters)
~	2.13. b. Residences		
~	213 c. Hospitals
~	2.13 d. Prison/Correctional Facilities
~	2.13. e. Recreation Areas		
U 2.13.f. Major commercial, office, or industrial areas
2.14. Environmental receptors within distance to endpoint (select all that apply)
~	2.14.a. National or State Parks, Forests, or	02.l4.d. Other (specify) (maximum 200 characters)
Monuments
~	2.14. b. Officially Designated Wildlife Sanctuaries,		
Preserves, or Refuges
~	2.14,c. Federal Wilderness Area		
2.15. Passive mitigation considered (select all that apply)

~ 2.15.a- Dikes
J 2 15.f Other (specify) (maximum 200 characters)
~ 2.15. b. Enclosures

~ 2.15.0. Berms

~ 2.15.d. Drains

~ 2.15,e. Sumps

2.1 S. Graphicsfile name (optional) (maximum 12 characters)
EPA Form 8700-25	-9-
Appendix A: Risk Management Plan Form
A-9

-------
Facility Name:	
I Section 3. Toxics: Alternative Release EPA Facility ID# (leave blank for first submission only)
I (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)
. J>/o
3.2. Physical State (select one)
~ 3.2.a. Gas
~ 3.2.c. Gas liquified by pressure
~ 3.2.b Liquid
_l 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
~	3.3,b. EPA's RMP Guidance for Ammonia Refrigeration Reference Tables or Equations
~	3.3.d. EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
~	3.3.e. EPA's RMP Guidance for Warehouse Reference Tables or Equations
~	3.3.f. EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
~	3.3 g EPA's RMP*Comp™
~	3.3.h. Areal Locations of Hazardous Atmospheres (ALOHA®)
~	3.3.Z. Other model (specify) (maximum 200 characters)
3.4. Scenario (select one)
~	3.4.a. Transfer hose failure	~ 3.4.f. Excess Flow Device Failure
~	3.4.b. Pipe Leak	~ 3.4.g. Other (specify) (maximum 35 characters)
~	3.5.C. Vessel Leak
~	3.4.d. Overfilling		
~	3.4.e. Rupture disk/relief valve failure
3.5. Released (lbs)
3,6. Release Rate (lbs/minute)


" Poloaco nuratinn (miniitoc) .....
1 a Wmrt 5|W»H (motoi-c(coi-nn/H) .....
3.9. Atmospheric stability class (A-F) i	i

EPA Form 8700-25	-10-
Appendix A: Risk Management Plan Form	A-10

-------
EPA Facility ID# (leave blank for first submission only)
make a copy of pages in this section and report each scenario separately)
3.10. Topology (select one)

~ 3.10.a. Urban
~ 3.10.b. Rural
3.11. Distance to endpoint (miles)
3.12. Estimated residential population within distance to endpoint
3.13. Public receptors within distance to endpoint (select all that apply)
~	3.13. a.	Schools
~	3.13. b.	Residences
~	3.13,c	Hospitals
~	3.13.d.	Prisons/Correctional facilities
LI 3,13 e. Recreation Areas
~	3,13.f, Major commercial, office, or industrial areas
~	3,13,g, Other (specify) (maximum 200 characters)
3.14. Environmental receptors within distance to endpoint (select all that apply)
~ 3.14. a. National or State Parks, Forests, or	~ 3.14.d. Other (specify) (maximum 200 characters)
Monuments
U 3.14, b. Officially Designated Wildlife Sanctuaries,		
Preserves, or Refuges
U 3,14 c. Federal Wilderness Area		
3.15. Passive mitigation considered (select all that apply)

~ 3.15.a. Dikes
~ 3.15.e. Sumps
~ 3.15. b. Enclosures
~ 3.15.f. Other (specify) (maximum 200 characters)
~ 3.15 c. Berrns

~ 3.15,d. Drains

3.16. Active mitigation considered (select all that apply)
~	3.16. a. Sprinkler systems
~	3.16. b. Deluge systems
~	3.16.0. Water curtain
~	3.16.d. Neutralization
~	3.16. e. Excess flow valve
~	3.16.f. Flares
LI 3.16. g. Scrubbers
~	3.16.h. Emergency shutdown systems
~	3.16.i. 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

-------
Facility Name:.
Section 4. Flammables: Worst Case	EPA Facility ID# (leave blank for first submission only)
(If you need to report more than one worst-ca se 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)
~	4 2.a	EPA's OCA Guidance Reference Tables or Equations
~	4.2.c.	EPA's RMP Guidance for Ammonia Refrigeration Reference Tables or Equations
~	4.2.6.	EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
~	4.2.e.	EPA's RMP Guidance for Warehouse Reference Tables or Equations
~	4.2.f.	EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
~	4.2.g.	EPA's RMP'Comp™
~	4.2.2.	Other model (specify) (maximum 235 characters)
4.3. Scenario (only one option)
Vapor Cloud Explosion
4.4. Quantity released (lbs)
4.5. Eridpoirit Used (only one option)
1 PSI
4.6. Distance to endpoint (miles)
4,7. Estimated residential population within distance to
endpoint


4.8. Public Receptors within distance to endpoint (select all that apply)
a
48 a
Schools
~
4.8.b.
Residences
u
4.8.0
Hospitals

4.8.d.
Prisons/Correctional facilities
u
4.8.e.
Recreation Areas
~	4.8.f. Major commercial, office, or industrial areas
~	4.8.g. Other (specify) (maximum 200 characters)
4.9. Environmental receptors within distance to endpoint (select all that apply)
U 4.9.a. National or State Parks, Forests, or	~ 4.9.d. Other (specify) (maximum 200 characters)
Monuments
U 4.9.b. Officially Designated Wildlife Sanctuaries,		
Preserves, or Refuges
~ 4.9.C. Federal Wilderness Area		
EPA Form 8700-25
-12-
Appendix A: Risk Management Plan Form
A-12

-------
Facility Name:
EPA Facility ID# (leave blank for first submission only)
SHSection 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)
~ 4.1G.a. Blast walls	(J 4.10.b. Other (specify) (maximum 200 characters)
4.11. Graphicsfile name (optional) (maximum 12 characters)
EPA Form 8700-25	-13-
Appendix A: Risk Management Plan Form
A-13

-------
Facility Name:.
Section 5. Flammables: Alternative Release
EPA Facility ID# (leave blank for first submission only)
(It 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 nam e in Other below)
~	5.2.a.	EPA's OCA Guidance Reference Tables or Equations
~	5.2.c.	EPA's RMP Guidance for Propane Storage Reference Tables or Equations
~	5.2.&	EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
~	5.2.e.	EPA's RMP Guidance for Warehouse Reference Tables or Equations
~	5.2.f.	EPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
~	5.2.g.	EPA's RMP'Comp™
~	5.2.Z.	Other model (specify) (maximum 235 characters)
5.3. Scenario (select one)

~ 5.3.a Vapor cloud explosion
LI 5.3.f. Vapor cloud fire
~ 5.3.b. Fireball
J 3.4.g. Other (specify) (maximum 30 characters)
U 5.3.C. BLEVE

~ 5.3 d. Pool fire

~ 5.3.e Jet fire

5.4. Quantity released (lbs)
5.5 End point used (select one)
~	5.5.a. 1 PSI
~	5.5.b. 5 kw/m1 for 40 seconds
~	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
-14-
Appendix A: Risk Management Plan Form
A-14

-------
Facility Name:
EPA Facility ID# (leave blank for first submission only)
Section 5. Flammables: Alternative Release
5.8. Public Receptors within distance to endpoint (select all
that apply)
~	5.8.a	Schools
~	5.8.b, Residences
~	5.8.C	Hospitals
~	5.8.(1 Prisons/Correctional facilities
~	5.8.e	Recreation Areas
~	5,8.f. Major commercial, office, or industrial areas
~	5.8.g. Other (specify) (maximum 200 characters)
5.9, Environmental receptors within distance to endpoint
(select all that apply)
~	5.9.a. National or State Parks. Forests, or
Monuments
~	5.9.b. Officially Designated Wildlife Sanctuaries,
Preserves, or Refuges
~	5.9.0. Federal Wilderness Area
~ 5.9.d. Other (specify) (maximum 200 characters)
5.10. Passive mitigation considered (select all that apply)

~ 5.10.a. Dikes
~ 5.10.e. Other (specify) (maximum 200 characters)
~ 5.10.b. Firewalls

~ 5.10.c. Blast walls

~ 5.10.d. Enclosures

5.11. Active mitigation considered (select all that apply)
~	5.11. a. Sprinkler systems
~	5.11.b. Deluge systems
~	5.11,0. Water curtain
~	5.11.d. Excess flow valve
LI 5.1 I.e. Other (specify) (maximum 200 characters)



5.12. Graphics file name (optional) (maximum 12 characters)
EPA Form 8700-25
-15-
Appendix A: Risk Management Plan Form
A-15

-------
Facility Name:
Section 6. Five-Year Accident History	FPA Facility ID# (leave blank lor first submission only)
(If you need fo 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?
~ Yes: leave the rest of this section blank	~ No; fill out this section for each accident
6.1, Date of accident (day, month, and year)
MM DD Y Y Y Y
6,2. Time accident began (hours and minutes)
H H MM
~	a.m.
~	p.m.
6..3, NAICS code of process involved
6,4. Release duration (hours and minutes)

H H H MM
6.5.a,i. Chemical name (maximum 100 characters)
6.5.a.ii, CAS Number
8.5.b. Quantity
released (lbs.)
6.5.C. Percent
weight of chemical if
in a mixture (toxics
only)
iiiiiiiaai
6.6.
Release event (select at least one)


Ua.
Gas release
~ d.
Explosion
Lib
Liquid spills/evaporation
Je
Uncontrolled/Runaway Reaction
Lie.
Fire


6.7. Release Source (select at least one)
~	a. Storage vessel
~	b. Piping
~	c. Process vessel
U d. Transfer hose
~	e. Valve
~	f. Pump
~	g. Joint
~	h. Other (specify) (maximum 200 characters)
EPA Form 8700-25
-16-
Appendix A: Risk Management Plan Form
A-16

-------
EPA Facility ID# (leave blank for first submission only)
6.8. Weather conditions at time of event
a.i. Wind speed (numerical) Wind speed unit
...... Ft miloc/hr 1 1 lenntc [~1 mptorcIcar
a.ii. Wind direction
b. Temperature fF}
c. Atmospheric stability class (A-F)
J d. Precipitation present
~ e. Unknown weather conditions (check if a-d are all unknown)
6.9 On-site Impacts
a. Deaths (enter numbers)
a i pmj-ilnywsQ nr .-nntraH-nrc ......
a li Pi jhiin rocpnnricrc; . - - •
a.iii. Public ......
b. Injuries (enter numbers)
h i Fmplnyp^s nr rr»ntrartr»r	•	•	>	<	i	e. Sheltered-in-place
c.	Other medical treatments i	¦	¦	¦	¦	¦	¦	¦	i	f. Property damage ($)
6.10.g, Environmental damage (select all that apply)
9-1
92
fl-3
g-4
g-5
Fish or animal kills
Tree, lawn, shrub, or crop damage
Water contamination
Soil contamination
Other (specify) (maximum 200 characters)
EPA Form 8700-25
-17-
Appendix A: Risk Management Plan Form
A-17

-------
Facility Name:.
Section 6. Five-Year Accident History
EPA Facility ID# (leave blank for first submission only)
6.11. Initiating event (select one)


~ a. Equipment failure
~
c. Natural (weather conditions, earthquake)
~ b Human error
_1
d. Unknown
6.12. Contributing factors (select all that apply)


~ a. Equipment failure
~
i. Unsuitable equipment
~ b. Human error
_l
j. Unusual weather conditions
~ c. Improper procedure
~
k. Management error
U d. Over pressurization
~
I. uncontrolled/runaway reaction
~ e. Upset condition
~
m. Other (specify) (maximum 200 characters)
U f. By-pass condition


U g. Maintenance activity/inactivity


U h. Process design failure


6.13. Off-site responders notified (select one)

~ a. Notified only
~ c. No, not notified
~ b. Notified and responded
~ d. Unknown
6.14. Changes introduced as a result of the accident


(select at least one)



J
j. None
~ a. Improved/upgraded equipment
~
k. Other (specify) (maximum 200 characters)
U b. Revised maintenance


~ c. Revised training


~ d. Revised operating procedures


~ e. New process controls


~ f. New mitigation systems


U g. Revised emergency response plan


~ h. Changed process


~ i. Reduced inventory


EPA Form 8700-25	-18-
Appendix A: Risk Management Plan Form

-------
Facility Name:
Section 7. Prevention Program: Program 3 epa Facility 111#(leave blank for fust 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 chem icals, please make a photo copy 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)
7.4.3. Date of last PHA or PHA update


MM DD YYYY
7.4.b. Technique used (select at least one)



~ 7.4b.6.
Fault Tree Analysis
~ 7.4.b,1. What if
~ 7.4.b,7.
Other (specify) (maximum 200 characters)
~ 7.4.b,2. Checklist


~ 7.4.b.3. What if/Checklist combined


~ 7.4.b.4. HAZOP


~ 7.4.b.5, Failure Mode & Effects Analysis


EPA Form 8700-25	-19-
Appendix A: Risk Management Plan Form
A-19

-------
Facility Name:.
Section 7. Prevention Program: Program 3 El'A Facility id# (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)
~
7.4,d.1Q.
Equipment failure

~
7.4.d.11.
Loss of cooling, heating, electricity,
~ 7.4.d.1. Toxic release


Instrument air
U 7.4.d.2. Fire
~
7.4.d.12.
Earthquake
~ 7.4.d.3. Explosion
~
7.4.d.13.
Floods (flood pain)
~ 7.4.d.4. Runaway reaction
~
7.4.d.14.
Tornado
~ 7.4.d.5. Polymerization
LI
7.4.d.15.
Hurricanes
U 7.4.d.6. Over pressurization
J
7.4. d. 16,
Other (specify) (maximum 200 characters)
~ 7.4.d.7. Corrosion



~	7.4.d.8. Overfilling
~	7.4.d.9. Contamination










7.4.e. Process controls in use (select at least one)
~
7.4.e.1.
Vents
~
7.4.e.12.
Emergency power
~
7.4.e.2.
Relief valves
~
7.4.e.13.
Backup pump
~
7.4.e.3,
Check valves
~
7.4.e.14,
Grounding equipment
~
7.4.e.4.
Scrubbers
J
7.4.e.15
Inhibitor addition
U
7.4.e.5.
Flares
~
7.4.e.16.
Rupture disks
~
7.4.e.6.
Manual shutoffs
~
7.4.e.17.
Excess flow device
~
7.4.e.7.
Automatic shutoffs
~
7.4.e.18.
Quench system
J
7.4.e.8.
Interlocks
~
7.4.e,19.
Purge system
~
7.4.6.9
Alarms and procedures
J
7.4.e.20.
None
LI
7.4.e,10
Keyed bypass
~
7.4.e.21.
Other (specify) (maximum 200 characters)
~
7.4 e 11
Emergency air supply



7.4.f. Mitigation systems in use (select at least one)


~ 7.4.f.1. Sprinkler system
J
7.4.f.7. Enclosure
~ 7.4.f.2. Dikes
_l
7.4.f.8, Neutralization
~ 7.4.f.3. Fire walls
~
7.4.f.9. None
~ 7.4,f.4. Blast walls
~
7.4.f.10. Other (specify)(maximum 200 characters)
J 7.4.f.5. Deluge system


~ 7.4.f.6. Water curtain





7.4.g. Monitoring/detection systems in use (select at least

one)
~ 7.4.g.4. Other (specify)( maximum 200 characters)
~ 7.4.g.1. Process area detectors

~ 7.4.g.2. Perimeter monitors

~ 7.4.g.3. None

EPA Form 8700-25
-20-
Appendix A: Risk Management Plan Form
A-20

-------
Facility Name:
Section 7. Prevention Program: Program 3 El'A Facility id# (leave blank for first submission only)
7.4.h. Changes since last PHA update (select at least
one)
~	7.4.11.1.	Reduction in chemical inventory
~	7.4.h.2.	Increase in chemical inventory
~	7 4 h 3.	Change in process parameters
U 7.4,h.4.	Installation of process controls
~	7.4.h.5.	Installation of process detection systems
~	7.4.h.6.	Installation of perimeter monitoring systems
~	7.4.h.7.	Installation of mitigation systems
~	7.4.h.8. None recommended
~	7.4.h.9. None
~	7.4.h.10. Other (specify) (maximum 200 characters)
7.5. Date of most recent review or revision of operating procedures	¦ - ¦ • - ¦ ¦ - - - ¦
MM DD YYYY
7.6. Training	
7.6.a. Date of most recent review or review of operating procedures	i	¦	, ,	.	, .	¦	¦	¦	¦
MM DD YYYY
7.6.b. Type of training provided (select atone)
~	7.6.b.1, Classroom
~	7.6.b.2 On the job
~	7.6.b.3. Other (specify) (maximum 200 characters)
7.6.c. Type of competency testing used (select at least one) ~ 7.6.c.4 Observation
U 7.6.C.5. Other (specify)(maxirnum 200 characters)
~	7.6.C.1. Written test
~	7.6.C.2. Oral Test		
U 7.6.C.3. Demonstration
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
MM DD YYYY
MM DD YYYY
7.7.c. Equipment most recently inspected or tested (list equipment) (maximum 200 characters)
EPA Form 8700-25
-21-
Appendix A: Risk Management Plan Form
A-21

-------
Facility Name:
Section 7. Prevention Program: Program 3 EPA Facility id# (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.
MM DD YYYY
7,8.b.
Date of most recent changes that triggered management of change procedures.
MM DD YYYY
79.
Date of most recent pre-startup review
... . _ . . . . _ .
MM DD YYYY
7.10. Compliance audits
710.s Date of most recent compliant audit
MM DD YYYY
7.10.b. Expected or actual date of completion of all changes resulting from the compliance
audit
MM DD YYYY
7.11. Incident investigation
7,11.a. Date of most recent incident investigation (if any)
MM DD YYYY
7.11 b. Expected or actual date of completion of all changes resulting from the incident
investigation
MM DD YYYY
7.12. Date of most recent review or revision of employee participation plans
MM DD YYYY
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
EPA Form 8700-25
-22-
Appendix A: Risk Management Plan Form
A-22

-------
Facility Name:
Section 8. Prevention Program: Program 2 EPA Facility TD# (leave blank lor 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
8,3. 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)
~	8.3. b.1. NFPA 58 (or state law based on NFPA 58)
~	8.3 b 2. OSHA (29 CFR 1910.111)
(J 8.3.b,3. ASTM Standards
~	8.3.b.4. ANSI Standards
~	8.3.b.5. ANSME Standards
~	8.3.b 6. None
~	8.3. b. 8. Comments (100 characters)
~ 8.3. b.7. Other (specify) (maximum 200 characters)
EPA Form 8700-25
-23-
Appendix A: Risk Management Plan Form
A-23

-------
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 oompletion of most recent hazard reviewor update
MM DD YYYY
8 4b Expected or actual date of completion of all changes resulting from the hazard review
MM D D
YYYY
8.4.C. Major hazards identified (select at least one)
~
8.4.0.1.
Toxic release
~
8.4.0.11.
Loss of cooling, heating, electricity,
~
8.4.C.2.
Fire


instrument air
~
8.4,0.3.
Explosion
LI
8.4.0.12.
Earthquake
~
8.4.0.4.
Runaway reaction
LI
8.4.0.13.
Floods (flood pain)
~
8.4.0.5.
Polymerization
~
8.4.0.14.
Tornado
~
8.4,0.6.
Over pressurization
~
8.4.C.15.
Hurricanes
~
8.4.0.7.
Corrosion
~
8.4.&16
Other (specify) (maximum 200 characters)
~
8.4.0.8.
Overfilling



~
8.4.0.9,
Contamination



~
8.4.0.10
. Equipment failure



8.4,d. Process controls in use (select at least one)
~
8.4.d.1. Vents
~
8.4.d.13.
Backup pump
~
8.4.d.2. Relief valves
~
8.4.d.14.
Grounding equipment
~
8.4.d.3. Check valves
~
8.4.d.15.
Inhibitor addition
J
8.4.d.4. Scrubbers
~
8.4.d.16.
Rupture disks
~
8.4.d 5. Flares
~
8.4.d.17.
Excess flow device
~
8.4.d,6. Manual shutoffs
~
8.4.d.18.
Quench system
~
8.4.d.7. Automatic shutoffs
~
8.4.d,19.
Purge system
U
8.4.d.8. interlocks
~
84-d.20.
None
a
8.4.d.9. Alarms and procedures
~
8.4.d.21.
Other (specify) (maximum 200 characters)
j
8 4.d.10. Keyed bypass



~
8.4.d.11. Emergency air supply



~
8.4.d.12. Emergency power



EPA Form 8700-25
-24-
Appendix A: Risk Management Plan Form
A-24

-------
Facility Name:
Section 8. Prevention Program: Program 2
FPA Facility ID# (leave blank lor first submission only)
3 4 e Mitigation systems in use (select at least one)
~
8.4.e.1.
Sprinkler system
u
8.4.e.2.
Dikes
~
8.4.e.3.
Fire walls
u
8.4.e.4
Blast walls
~
8.4.e.5.
Deluge system
u
8.4.a6.
Water curtain
~
8.4.e.7.
Enclosure
U 8.4.e.8. Neutralization
~	8.4.e.9. None
~	8.4.e.10. Other (specify)(maximum 200 characters)
8.4 f. Monitoring/detection systems in use (select at least one)
~	8.4,f.1. Process area detectors
~	8.4,f.2. Perimeter monitors
~	8.4.f.3. None
~ 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)
Reduction in chemical inventory
Increase in chemical inventory
Change in process parameters
Installation of process controls
Installation of process detection systems
Installation of perimeter monitoring systems
Installation of mitigation systems
U
8.4 g.1
~
8.4.g.2
~
8.4.g.3
u
8.4.g.4
~
8.4.g.5
~
8.4.g.6
~
8.4.g.7
U 8.4.g.8, None recommended
~	8.4.g.9. None
~	8.4.g.10. Other (specify) (maximum 200 characters)
8.S. 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)
~	8.6.b.1. Classroom
U8.6.b.2. On the job
~	8,6.b.3. Other (specify) (maximum 200 characters)
EPA Form 8700-25
-25-
Appendix A: Risk Management Plan Form
A-25

-------
Facility Name:
Section 8. Prevention Program: Program 2
FPA Facility ID# (leave blank lor first submission only)
8.6.C. Type of competency testing used (select at least one)	~ 8.6.C.5. Other (specify)(maximum 200 characters)
~	8.6.C.1.	Written test		
~	8.6.C.2.	Oral Test
~	8 6 c.3	Demonstration		
~	8.6.C.4.	Observation
8.7. Maintenance
8.7 a. Date of most recent review or revision of maintenance procedures
MM DD	YYYY
8.7.b. Date of most recent equipment inspection or test	.	»	i i	¦	i i	>	>	¦	.
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



M M
D D YYYY
8.8.b. Expected or actual date of completion of all changes resulting from the compliance
audit



M M
D D YYYY
3.9. 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
investigation
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
M M
D D
YYYY
EPA Form 8700-25
-26-
Appendix A: Risk Management Plan Form
A-26

-------
Facility Name:.
Section 9. Emergency Response
EPA Facility ID# (leave blank for first submission only)
9.1 Written emergency response (ER) plan
9.1.a. ~ 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. ~ Does your facility's ER plan include specific actions to be taken in response to accidental releases of regulated
substance(s)?
9.3. ~ Doesyourfacility's ER plan include procedures for informing the public and local agencies responding to accidental
releases?
9.4. ~ Doesyourfacility'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)
~	9.8.a. OS HA 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
U 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
(J 9.8.f.	State EPCRA Rules or Laws
~	9.8.g.	Other (specify)(maximum 200 characters)
EPA Form 8700-25
-27-
Retum to I ndex
Appendix A: Risk Management Plan Form
A-27

-------
APPENDIX B. SAMPLE CERTIFICATION LETTERS
Sample Certification Letters
Certificnthtn Statement lor IVngrmn 1 i'rncess(es):
1 fciSL'il on (hi- irileria in 40 CKR 68.10. the (listunci' t accidental release that caused iti'lsite impacts prin ided
in the risk inuiiauement program rule (40 CFR 6X. lotbwl)). Sit xddilirniat measures lire neiessur> to prr\ ent
olTsiti- impacts SVom accidentii! releases, III the cuwit itf til l'. r\pliisiuli, ci a release nl'a I emilaled substance fn.ni
1 hv pi missies), entri within the distance In the specified Midpoints ma} pitse y dan»ei in public emeiuencj
ri'sponilerv ! bui'lure. public eimrmiio respdiukt s should in>( enter tins area except a-. arranged «itii liie
rmiTtiincj contact indicated in tin- R\1P. The undc¦ rsi-.;sutJ certifies that, to (lie best »f lii> kixmlril;>(-.
inronnalicut, am! hcliel'. (iirnnd after reasonable inquiry. I In1 inlr.r niiiliiin submitted is true, accurate. and
mm plete.
Signature	I'rinl .Name
I iltc	Date
('i-rtiluminn Statement for Program Level 2 «& 3 Pr messes;
To the best of the uiKlersimiud's knowledge, information, and belief formed after reasonable inquiry, the
information submitted I* true, accurate, and complete.
Signature	Print Name
i illir	l>ate
R-i
Appendix B: Sample Certification Letters

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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.
kpaFauitivTD«nnnD - enlzjczhcm - dddd
R-2	Return to Index
Appendix B: Sample Certification Letters

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APPENDIX C. CB1 SUBSTANTIATION FORM
OM B Control Number 2050-0144
CBI Substantiation Form
If you are claiming Confidential Business Information fCBI) 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 ill, 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}: Q
c. Facility Location Address:
d. City, State and Zip Code:
EPA Form 8700-27 C-1

Appendix C: CBI Substantiation Form

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e. Dun and Brad street Number;
Part 1! - 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 68,152, In this case, submit 2 copies of this form, one sanitized and one
unsanitized. Please indicate here whether this form is sanitized or unsanitized,
~ Sanitized ~ Unsanitized
Part 111 - 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 Wame


















EPA Form 8700-2?	C-2
Appendix C: CBI Substantiation Form

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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. !f you need
additional space, use separate sheets of paper.
(a} For any data elements thai 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.
fb) 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 8700-2?
C-3
Appendix C: CBI Substantiation Form

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fe) 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? )f 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 8700-2?
C-4
Appendix C: CBI Substantiation Form

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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)
Print Name
Official Title
Date Signed
EPA Form 8700-2?
C-5
Return to Index
Appendix C: CBI Substantiation Form

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APPENDIX D. CB1 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 (he infoimation 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 RMPNnfo.
If you need additional space, make a copy of page 2 of this form.
Parti. 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. EPA Facility 10 # (if assigned):
~~~~-~~~~-~~~~
c. Facility Location Address:
d. City, State and Zip Code:
e. Dun and Brad street Number:
Part II - Information claimed as CBI
Please list the data element mimber(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
RHP Data Claimed as CBI
EPA Form 8700-28
CV1
Appendix D: CBI Unsanitized Data Element Form

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Data Element
Number
Name of Data Element
RMP Data Claimed as CBI







































EPA Form 8700-28	D-2	Return to 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:
~	Source reduced inventory of all regulated substances belowTQs
~	Source no longer uses any regulated substance
~	Source terminated operations
~	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):
~	that the facility uses on site as a fuel,
or
~	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
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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