Using RMP

Prepare and Stay Aware!

Using RMP*SUBMIT

Facilities which use, store, process, or manufacture any one of 140 regulated substances in the 112(r) program above its threshold quantity, at any one time and in any one process, must develop and implement a risk management program and submit a plan summarizing this program to the U.S. Environmental Protection Agency (EPA). The risk management program must include the following elements: a hazard assessment of potential chemical releases, a prevention program to minimize the occurrence of a release, and an emergency response program to address the consequences of any releases which do occur. Once you make the determination that your facility is indeed subject to this program, you must begin to implement the program on-site and develop the summary plan.

EPA has developed an computer system for risk management plans called RMP*SUBMIT. This database contains all the information needed to complete a summary plan, organized into nine sections: registration, toxics worst-case release scenario(s), toxics alternative release scenario(s), flammables worst-case release scenario(s), flammables alternative release scenario(s), accident history, prevention program - Level 2, prevention program - Level 3, and emergency response. You must also complete an executive summary narrative section. The nine sections reflect the requirements of the EPA Risk Management Program Rule in 40 CFR Part 68.

Obtaining and Installing

EPA released the official version of RMP*SUBMIT (v. 1.07) on February 22, 1999. To obtain a copy of the database, you can request it (free of charge) from the National Center for Environmental Publications and Information at (800) 490-9198, facsimile (513) 489-8695. You may request diskettes or a CD-ROM package. You can also download it as a single executable file or as four smaller files directly from the Internet at:

http://www.epa.gov/swercepp/rmpsubmt.html.

In order to install and run this database on a personal computer, you will need 6 to 10 megabytes (MB) of available hard disk space and a minimum of 16 MB of Random Access Memory (RAM), an IBM-compatible personal computer with a 486 DX2 or higher Central Processing Unit (Pentium is recommended), a Video Graphics Adapter (VGA) monitor, and an operating environment such as Microsoft Windows Version 3.1 or Windows 95. You should also request a copy of the RMP*SUBMIT User=s Manual (February 1999). If downloading from the Internet, you should also print out the readme.txt file. It contains instructions on loading and running the program in Windows 3.1 and Windows 95 systems. Both the RMP*SUBMIT database and the User=s Manual have errata sheets available to identify any errors found by EPA or users. These are updated periodically on the CEPPO website listed above.

For answers to software questions or solutions to installation problems, contact the RMP Reporting Center at (703) 816-4434 from 8:00 a.m. - 4:30 p.m. on Mondays - Fridays, or via e-mail at: userrmp.usersupport@epcra.org. If you have questions on the regulation and applicability issues, please contact the Bureau of Compliance Planning and Support, Division of Emergency Management, Division of Emergency Management at (800) 635-7179 (Florida only) or at (850) 413-9970, facsimile (850) 488-1739.

Submitting Your RMP

You must submit a single summary Risk Management Plan covering ALL affected processes on-site electronically (on diskette) along with a signed and dated copy of the certification statement by June 21, 1999 (postmark date) to:

RMP Reporting Center

P.O. Box 3346

Merrifield, VA 22116-3346

A sample certification statement is available in Appendix C of the User=s Manual. You can use RMP*SUBMIT to provide this information to EPA or other proprietary submittal systems as long as they are compatible with RMP*Submit (EPA has released a compatibility document for ASCII files on the CEPPO website). If you have Classified Business Information in your RMP, you must also complete and send in Appendices D and E of the User=s Manual, and each item classified as CBI must be identified in each section of your RMP. EPA published rulemaking on January 6, 1999 in the Federal Register (64 FR 964) on criteria for CBI claims. If you cannot provide this information electronically, you may petition EPA for an electronic waiver to submit the required information on paper. In this case, you must complete and submit Appendix A (the print-out version of the RMP*SUBMIT screens), Appendix B (Electronic Waiver Form), and Appendix C (certification statement).

If a facility has multiple affected processes, then the plan should reflect this. In Section 1.17, you will provide information on each affected substance in that process. RMP*SUBMIT allows you to create additional process records for as many as needed to fully characterize the facility=s regulatory status. Your facility needs to have and maintain back-up documentation on-site to verify that the program continues to be implemented. The Risk Management Plan is only a summary of the RMP program at your facility. Types of records and documentation to be kept on-site include: hazard assessment calculations, prevention program records (employee training lists, training materials, management of change procedures), and emergency response records (coordination with local response agencies, MSDS, evacuation routes, personnel protective equipment inspection and maintenance records). Remember to keep a copy of the completed plan and all needed documentation on-site for your files!

Note:_ There is no requirement to submit a separate version of the RMP to state or local officials or local libraries. Implementation agencies will have full access to the national database and will be able to retrieve documents from the system -- Please do not send a copy of the Risk Management Plan to the Division of Emergency Management.

After You Submit

Once your RMP has been processed at the national center, you will be notified regarding its submission status. EPA expects that the majority of facilities subject to this program will submit their plans just prior to the June 21, 1999 deadline. Therefore, it may take until the end of August for all plans to be processed into the national database. You should receive a notification letter at that time stating that your plan was either:

-Complete upon submittal,

-Received and found to be incomplete according to EPA=s checking system (error form attached for your review), or

-Unable to be processed (reason indicated on attached form).

The notification letter will also include your facility=s new RMP Facility ID number, which should be used for all future correspondence with EPA on this program