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                                  United States              Office of Solid Waste    EPA 550-B99-003
Environmental Protection and Emergency Response November 1999
Agency (5104) www.epa.gov/ceppo/



RMPs Are on the Way!
How LEPCs and Other Local
Agencies Can Include Information
from Risk Management Plans in
Their Ongoing Work
RMP SERIES




Chemical Emergency Preparedness and Prevention Office Printed on recycled paper
ABOUT THIS BOOKLET...
he Emergency Planning and Community Right-to-Know Act of 1986
T (EPCRA) calls for the establishment of local emergency planning
committees (LEPCs). LEPCs are to have broad-based membership whose
primary work is to receive information from local facilities about chemi
cals in the community, use that information to develop a comprehensive
emergency plan for the community, and respond to public inquiries about
local chemical hazards and releases. There are now more than 3,500
LEPCs, and they reflect the diversity of our country. Most LEPCs are orga
nized to serve a county; some are for a single large city; others cover the
better part of an entire state.

We are publishing this booklet in anticipation of the impact a new regula
tion will have on LEPCs. The regulation implementing section 112(r) of
the Clean Air Act requires facilities to develop a risk management pro
gram to prevent and mitigate the effects of chemical accidents, and to
document the program in a Risk Management Plan (RMP). These RMPs
will be available to state and local agencies and to the public. Therefore,
LEPCs will have access to more detailed information about chemical haz
ards in their communities. LEPCs can use this information to improve
emergency response plans, inform the public about chemical accident
hazards and risks, and work with industry and the public to reduce risks
and improve chemical safety.

This booklet will not teach you everything about the RMP regulation.
Rather, the purpose of this booklet is to describe how LEPCs and similar
local agencies can take advantage of the risk management program to
build on their existing planning and right-to-know activities under EPCRA.
We intend this booklet to follow the style of and replace It's Not Over in
October, a document that EPA and other groups published in 1988 to
encourage new LEPCs not to stop working once they had completed their
emergency plans by the October 1988 deadline. For more detailed infor
mation about the RMP regulation, consult EPA's General Guidance for Risk
Management Programs (http://www.epa.gov/ceppo).

The RMP regulation contains a deadline for industry: June 21, 1999. By
that date, covered facilities were required to have in place a risk manage
ment program and must have submitted an RMP to EPA. This deadline for
industry is an opportunity for LEPCs. June 1999 can be a beginning, a
time to update existing emergency plans with the new RMP information, a
time to better understand chemical hazards in your community and share
your understanding with the public, a time to declare in word and deed
that you will promote chemical safety in your community by focusing on
preventing accidents.

RMPs are on the way! We hope that this booklet helps you and your LEPC
in your important work of protecting human life and the environment
where you live.
WHAT'S INSIDE?

New Information Is Becoming Available

about Chemicals in Your Community . . . . . . . . . . .1

Information You Already Have . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

New Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2

Information Sources and Contacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3


A Role for Everyone in Chemical Safety . . . . . .3


What Is the RMP Regulation? . . . . . . . . . . . . . . . . . . . . . . .5

What Chemicals Are Covered? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5

What Facilities Are Covered? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

What Must a Facility Do? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

Hazard Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

Management System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8

Prevention Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8

Emergency Response Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8

Different Requirements for Different Kinds of Facilities . . . . . . . . . . . . . . . .9


RMPs Are Coming! . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

What Information Is in an RMP? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

Registration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

Offsite Consequence Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11

Five-Year Accident History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11

Prevention Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12

Emergency Response Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12

Confidential Business Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13

How Can LEPCs Access RMPs? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13


More on Offsite Consequence Analysis . . . . . . .14


LEPCs Coordinate Chemical Safety

Activities in the Community . . . . . . . . . . . . . . . . . . . . . . . .17

Get Everyone Involved . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17

Enhancing LEPC-Industry Relations; Encouraging Compliance . . . . . . . . .18

Release Modeling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18

Working with Small Businesses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19

Response Coordination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19

Industry Outreach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19

New Partnerships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20

Talk with Neighboring Communities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21

RMPs Are on the Way!
Risk Communication: LEPCs Are a Bridge

between the Public and Local Industry . . . . . .22

Basic Rules of Risk Communication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23

Hazards Versus Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23

Three Scenarios . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24

A Special Case: Dealing with Worst-Case Scenarios . . . . . . . . . . . . . . . . . . .26

Respond to Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27


Improving Your Emergency Plans . . . . . . . . . . . . . . .28


Working with Industry to Prevent

Accidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .29


A Few More Suggestions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31

Funding Your Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31

Liability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31

Handy Reference . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .32




Appendices and Attachments
Appendix A: Checklist ?Ideas for Action
Appendix B: EPA Regional Office Contacts for EPCRA and RMP Programs
Appendix C: Some Background Information: Comparison of Green Book
and RMP Offsite Consequence Analysis (OCA) Guidance
Methodology
Appendix D: Regulated Substances: Chemicals Covered by the RMP
Regulation and Their Threshold Quantities
Y2K Alert
Customer Satisfaction Survey: RMPs Are on the Way!
NEW INFORMATION IS BECOMING
AVAILABLE ABOUT CHEMICALS IN
YOUR COMMUNITY
In 1990, section 112(r) was added to the Clean Air Act (CAA).
Section 112(r) calls on EPA to establish requirements for facilities to
reduce the likelihood and severity of accidental chemical releases,
using hazard assessments, prevention programs, and emergency
response planning. EPA implemented section 112(r) in its Risk
Management Program regulation. Facilities that are covered by the
Risk Management Program will summarize their program activities
in Risk Management Plans (RMPs). Facilities were required to sub
mit their RMPs to EPA by June 21, 1999, and EPA has made the RMPs
available to the public. A host of new information is now available
to you!

The provisions for accidental release prevention in CAA section CAA section 112(r) is enti
tled Prevention of Accidental
112(r) and the Risk Management Program regulation build on the Releases. This booklet
planning and preparedness foundation laid by the Emergency speaks about the Risk
Management Program rule
Planning and Community Right-to-Know Act of 1986 (EPCRA--also
(40 CFR part 68) that EPA
known as SARA Title III). EPCRA is intended to encourage emer published to implement sec
gency planning efforts at state and local levels and to increase pub tion 112(r). The rule estab
lished the requirements of
lic awareness and understanding of potential chemical hazards pre the Risk Management
sent in the community. EPCRA sets up a framework for emergency Program.
planning at the state and local levels and provides the authority to Another term you will want
collect chemical information that is important to communities. The to become familiar with is
"Risk Management Plan,"
CAA section 112(r) program provides a complementary approach to
which refers to the document
chemical safety--it requires that facilities take steps to identify a facility must prepare to
and control on-site hazards. It also provides for public access to summarize its risk manage
ment program. In this book
information about the actions facilities are taking to prevent and let, we use "RMP" to refer
mitigate the potential offsite effects of these hazards. to the Risk Management
Plan.

Information You Already Have

Under EPCRA, you currently receive information from covered facil
ities on the chemicals they have, the quantities of chemicals stored,
the hazards associated with those chemicals, and information on
storage locations and conditions. Specifically, the EPCRA program
provides you with the following information:
? Notification from facilities that have extremely hazardous sub
stances (EHSs) in excess of threshold planning quantity
amounts. This information is reported directly to the local
emergency planning committee (LEPC). (EPCRA sections 302
and 303)


page 1
RMPs Are on the Way!
? Notification of emergency information about accidental releas
es of reportable quantities of EHSs and substances regulated
under CERCLA (CERCLA hazardous substances). This informa
tion is reported to the LEPC's community emergency coordina
tor. (EPCRA section 304)

? Material Safety Data Sheets (MSDSs) ?or lists of hazardous
chemicals ?from facilities that have threshold quantities of
hazardous chemicals and that must have an MSDS under the
Occupational Safety and Health Act, and annual inventory
information on the quantity, hazard category, and location and
storage conditions of hazardous chemicals at facilities at
threshold levels. This information is reported directly to the
LEPC. (EPCRA sections 311 and 312)

? Annual reports on total yearly releases of toxic chemicals from
regulated facilities. This information is reported to EPA. EPA
compiles this information in a database called the Toxics
Release Inventory (TRI) and makes the information available to
the public. (EPCRA section 313)


New Information

Under the CAA section 112(r) Risk Management Program, additional
information is now available to you ?in the RMPs that facilities
submitted to EPA.
? Facility hazard assessments, including worst-case release and
alternative release scenarios;

? Facility accident prevention activities, such as use of special
safety equipment, employee safety training programs, and
process hazards analyses conducted by the facility;

? Past chemical accidents at a facility; and

? Facility emergency response programs and plans.

Both EPCRA and the CAA section 112(r) Risk Management Program
encourage communication between facilities and the surrounding
communities about chemical safety and chemical risks. Regulatory
requirements, by themselves, will not guarantee safety from chemi
cal accidents. Information about hazards in a community will allow
local emergency officials and the public to work with industry to
prevent accidents.




page 2
For example, facilities are required to provide information about
possible worst-case scenarios under the Risk Management Program
?and officials and the public can use the information to under
stand the chemical hazards in the community and then engage in a
dialogue with industry to reduce risk. In this way, accident preven
tion is focused primarily at the local level where the risk is found.
Tips &
Hints
Information Sources and Contacts
By combining RMP informa
Q: Where can I get updates on the latest EPCRA and RMP guidance tion with EPCRA data, your
and program information? LEPC can enhance its role as
a key player on issues that
relate to the use of haz
A: EPA's Chemical Emergency Preparedness and Prevention
ardous chemicals in the com
Internet Homepage at http://www.epa.gov/ceppo/ munity. You can:

(1) Use accidental release
Q: Where can I order copies of documents?
scenarios to set realistic pri
orities among your local
A: National Service Center for Environmental Publications (NSCEP) emergency preparedness
Toll-Free: (800) 490-9198 activities.

(2) Serve as a resource for
Q: Where can I get answers to my questions and order single facilities and the public in
copies of documents? promoting risk communica
tion.
A: The RCRA, Superfund and EPCRA Hotline (3) Use accident histories
Toll-Free: (800) 424-9346 and summaries of prevention
activities to help you talk
TDD: (800) 553-7672
with facilities about steps to
DC Area: (703) 412-9810 reduce risk.
Fax: (202) 651-2061
(4) Provide compliance assis
Monday-Friday, 9:00 a.m. - 6:00 p.m. EST tance to facilities on emer
gency response, accidental
release scenarios, and other
A ROLE FOR EVERYONE IN CHEMICAL issues.
SAFETY (5) Reach out to other com
munity groups (for example,
Industry complies with EPCRA and RMP reporting requirements the local zoning board, envi
ronmental groups) who may
and participates actively with LEPCs and State Emergency be interested in elements of
Response Commissions (SERCs) to ensure that the public under the RMP and help them
understand the data and how
stands chemical hazards in the community and that community
the data could assist them.
responders are prepared to take appropriate steps if an accident
happens. In addition to the reporting requirements, the RMP regu
lation requires facilities to develop a risk management program to
ensure that the facility has implemented accident prevention and
emergency response programs that fit the chemical hazards at the
facility. In addition to these specific requirements, CAA section
112(r)(1) establishes a general duty for industry to operate safely.

EPA's federal role is to provide national leadership, guidance, and
technical assistance for implementing both EPCRA and the RMP reg-

page 3
RMPs Are on the Way!

CAA Section 112(r) Implementing Agencies

Agencies charged with implementing the RMP regulation will
conduct outreach, technical assistance, training, reviews of
RMPs, audits of RMPs, and inspection of risk management pro
grams at facilities. In its Guidance for Implementing Agencies
(see table of resources for how to obtain a copy), EPA notes that
each state and locality will have its own approach to encourag-
ing chemical safety. EPA will work with each interested state
and/or local agency to develop an appropriate RMP implemen
tation program.

To learn which agency is implementing the RMP regulation in

your area, you can call your EPA Regional Office (see contact

list at the back of this booklet), or visit the CEPPO website at

http://www.epa.gov/ceppo.


Did you
ulation; provide access to TRI data about chemical releases (under
know?
EPCRA section 313); and receive risk management plans from indus
try and then make them available to state and local agencies and
According to EPA's
the general public. Additionally, EPA Regional offices will imple
Emergency Response
Notification System (ERNS),
ment all or part of the risk management program in states that have
more than 402,000 accidents
chosen not to seek formal delegation from EPA to implement the
involving hazardous chemi
cals were reported in the RMP program.
United States in the 12 years
from 1987 to 1998. These
The states, through the SERCs, provide EPCRA leadership to ensure
accidents resulted in nearly
that an emergency planning and EPCRA implementation structure is
4,000 deaths, 25,300
injuries, and 1,400 evacua
developed and to provide training and technical assistance to com
tions affecting 147,000 indi
munities. Under the Clean Air Act, state (as well as local and
viduals. Eighty percent of
these reported accidents regional) air permitting agencies issue permits to some facilities
occurred at industrial and
that are also covered by the RMP regulation. In addition, EPA will
commercial facilities.
delegate to interested states and local agencies the authority to
implement the RMP program ?this is already happening in
Georgia, Florida, North Carolina, South Carolina, New Jersey,
California, Puerto Rico, and the Virgin Islands. Some SERCs are
involved in implementing the RMP program.

At the local level, LEPCs carry out the emergency planning and
community right-to-know requirements of EPCRA. First responders
(who are typically represented on LEPCs) implement contingency
plans when response to a chemical accident is necessary. LEPCs
will increasingly be a source of information about chemical risks in
the community, as information under the RMP regulation becomes
available to the public.


page 4
A major role for LEPCs is to work with industry and the inter
ested public to encourage continuous attention to chemical
safety, risk reduction, and accident prevention by each local
Take Note
stakeholder.

The public can get involved by increasing its awareness and
understanding of chemical hazards and supporting actions to
ensure public safety and protection of the environment.


WHAT IS THE RMP REGULATION?
The RMP regulation (40 CFR part 68) is designed to prevent acci
dental releases to the air of substances that may cause immediate,
serious harm to public health and the environment and to mitigate
the effects of releases that do occur. The regulation is available
from EPA. Call the RCRA, Superfund and EPCRA Hotline at (800)
424-9346 or visit EPA's website at http://www.epa.gov/ceppo .

What Chemicals Are Covered? A facility (called a "station
ary source" in the regula
The RMP regulation applies to processes at facilities that have more tion) is covered by the RMP
regulation if:
than a threshold quantity of any of 77 acutely toxic substances,
such as chlorine and ammonia, and 63 highly volatile flammable (1) It has a regulated sub
stance...
substances, including propane. These substances are called "regu
(2) ...over the threshold
lated substances" in this booklet to distinguish them from chemi
quantity...
cals on other lists.
(3) ...in a process.
A new law excludes regulated flammable substances from the RMP
program when those substances are used as fuel or held for sale as
a fuel at a retail facility. The law defines retail facility as a facility at
which more than one-half of the income is obtained from direct
sales to end users or at which more than one-half of the fuel sold,
by volume, is sold through a cylinder exchange program. The main
effect of this provision is to exempt from RMP coverage all facilities
that had previously been covered solely because they used flam
mable substances, particularly propane, for fuel (e.g., for heating,
drying, etc.), and to exempt most propane distribution facilities.
Propane distribution facilities that do not meet the criteria for
"retail facility" are still covered by the RMP rule. Facilities such as
oil refineries that manufacture listed flammable substances are still
covered, as are facilities that use listed flammable substances for
non-fuel purposes (e.g., as a chemical feedstock).

Most of the acutely toxic regulated substances are also extremely
hazardous substances (EHSs) under EPCRA section 302. The flam
mable regulated substances are all subject to reporting under

page 5
RMPs Are on the Way!
EPCRA sections 311 and 312. Each toxic regulated substance is
assigned a threshold quantity under the RMP regulation that is
generally higher than the threshold planning quantity for the same
substance under EPCRA. All flammable regulated substances have
a threshold quantity of 10,000 pounds under the RMP regulation,
the same as the threshold for these substances under EPCRA sec
tions 311 and 312. The list of RMP regulated substances and thresh
olds is provided at the back of this booklet.

The RMP thresholds are applied to individual "processes" at a reg
ulated facility, while EPCRA thresholds are applied to the site as a
whole. A process, as defined by the RMP regulation, means any
activity involving a regulated substance, including any use, storage,
manufacturing, handling, or on-site movement of such substances,
or combination of these activities. Any group of vessels that are
interconnected, or separate vessels that are located such that a reg
ulated substance could be involved in a potential release, is consid
ered a single process. Consequently, there may be some facilities in
Tips & your community that report under EPCRA for a specific substance
Hints and might appear to meet the threshold quantity under the RMP
regulation as well, but in fact are not subject to the RMP rule
EPCRA section 312 reports
because they do not have a threshold quantity in a single process.
will provide you with a list
of local facilities potentially
subject to the RMP regula
tion. However, remember
that the EPCRA thresholds
Examples of specific operations that may be regulated
apply to the facility as a
whole, rather than to an
under the RMP rule:
individual process, and thus
the list of EPCRA facilities
may include facilities not
? Manufacturers of inorgan ? Pulp and paper mills
covered by the RMP regula
ic chemicals and industri
tion. In addition, the RMP ? Larger industrial facilities
al gases
thresholds for toxics are gen
and institutions that store
? Manufacturers of plastics,
erally higher than the
propane for use as fuel
EPCRA thresholds. resins, and organic chemi
? Agricultural retailers who
cals
sell ammonia fertilizer
? Manufacturers of agricul
? Larger water treatment
tural chemicals
and wastewater treatment
? Petroleum refineries and systems
gas processing plants
? Refrigerated warehouses,
? Metal and equipment warehouses that handle
manufacturers chemicals, and chemical
distributors
? Food businesses with
large ammonia refrigera ? Electric companies
tion systems
? Large U.S. military and
? Propane retailers and dis Department of Energy
tributors installations
page 6
What Facilities Are Covered?

EPA has estimated that thousands of facilities are potentially sub
ject to the regulation, including manufacturers, warehouses, retail
businesses, and public facilities. The rule does not apply to trans
portation, including pipelines. Regulated substances present in
gasoline, when in distribution or related storage for use as fuel for
internal combustion engines, also are not covered. In addition, the
rule provides an exemption for the use of ammonia by farmers as a
fertilizer (although not for those businesses that produce or sell
ammonia to those farmers).

What Must a Facility Do?

There are five main elements of facility compliance with the RMP
regulation:
(1) A hazard assessment;

(2) A management system;

(3) A prevention program;

(4) An emergency response program; and

(5) A Risk Management Plan (RMP) that describes these activities.

The first four elements are described here. The Risk Management
Plan is described in more detail in the next chapter.

Hazard Assessment
The hazard assessment consists of two components:
(a) A five-year history of serious accidents involving the regulated
substances. Every covered facility must provide detailed infor
mation on any serious accident that occurred in the previous
five years and had specific impacts either on the site or in the
surrounding community.

(b) Descriptions of one or more potential accidental release sce
narios involving the regulated substances. Every facility must
analyze the potential offsite consequences of a worst-case (cat
astrophic) release.

EPA has defined the parameters of a worst-case scenario (such as
atmospheric conditions, endpoints, and release criteria) for this
analysis. In addition, if the worst-case scenario could impact the
public, one or more alternative releases that are more likely to

page 7
RMPs Are on the Way!
occur must be examined. (Some of these special terms are
explained in the section of this booklet called "More on Offsite
Consequence Analysis.")

For each release scenario, the facility must estimate the greatest
distance from the facility to a point beyond which no serious acute
effects are anticipated. The facility must also identify the popula
tions and environments potentially affected.

Management System
Every facility that has a worst-case analysis showing potential off-
Tips & site impacts is required to develop a management system to over
see the implementation of the Risk Management Program elements.
Hints
The management system provision also requires the facility to des
ignate a qualified person or position with overall responsibility for
The RMP regulation requires
every facility subject to the
the development and implementation of the risk management pro
regulation to coordinate its
gram elements and to document the names of people or positions
response activities with the
LEPC for its area or with and define lines of authority.
local responders. This is an
opportunity for you to:
Prevention Program
?Ensure that you have in
place a clear and quick
The main objective of the Risk Management Program regulation is
method to notify neighbors
when an accident happens to prevent accidents from occurring, and this is done by ensuring
that every covered facility implements a chemical accident preven
?Ensure that all call-down
lists are consistent
tion program. To do this, the facility must understand its hazards
and integrate safety into all aspects of its processes and business.
?Coordinate operating proce
dures among community
The facility must make safety a way of life so that the risk from
first responders and facility
chemical accidents to employees and the public is minimal. The
employees
prevention program must be implemented on a daily basis if it is to
?Review equipment lists to
achieve its goal--no chemical accidents.
ensure you have the right
equipment and that you
know where it is when an
The prevention program is intended to formalize a series of man
accident happens
agement practices for identifying hazards and managing the risk of
?Practice evacuation and
a chemical accident. A good prevention program focuses on hazard
shelter-in-place procedures
analysis, process controls, operating procedures, employee training,
with neighbors
and maintenance activities. Not all facilities are required to devel
op a prevention program. A facility with only Program 1 processes
(see box on next page) is not subject to prevention program
requirements and will provide no data on its prevention activities.

Emergency Response Program
At a minimum, every facility subject to the regulation must coordi
nate its response activities with the LEPC for its area or with local
responders.

page 8
Facilities May Have Processes Subject to Different Risk
Management Requirements Based on the Different
Risks They Present
Program 1 Processes

No accidental releases resulting in offsite impacts within

five years of RMP submittal

No public receptors in worst-case scenario zone and
Emergency response procedures coordinated with local
emergency organizations
Program 2 Processes

Not eligible for Program 1 or subject to Program 3

Program 3 Processes

Not eligible for Program 1 and

Subject to OSHA process safety management standard
or in NAICS code 32211, 32411, 32511, 325181, 325188,
325192, 325199, 325211, 325311, or 32532


In addition, if a facility will use its own employees to respond to
releases (for example, with a facility hazmat team), the facility must
implement a full emergency response program that includes a plan,
training, and plan review and updates. The facility may choose to
develop one plan following National Response Team guidance
(available at http://www.epa.gov/ceppo) as described on page 19.
The facility must coordinate its plan with its LEPC plan.

Different Requirements for Different Kinds of
Facilities

Facility risk management programs will vary. The RMP regulation
requires facilities to develop a program that reflects the different
levels of risk and complexity that different processes pose. A
process falls into one of three categories--Program 1, Program 2, or
Program 3--based on accident history, worst-case scenario results,
and industrial sector. In general, Program 1 processes are less com
plex, pose less risk to the public, and have had no accidents with
offsite consequences. Program 2 and 3 processes are more complex
and have worst-case scenarios that would impact the public. The
compliance requirements for Program 1 processes are less stringent
than are the requirements for Program 2 and 3 processes, which are
also more formal.




page 9
RMPs Are on the Way!
RMPS ARE COMING!
The Risk Management Plan describes the activities that each facility
is conducting to comply with the regulation, its "risk management
program." Initial RMPs were submitted to EPA by June 21, 1999. The
information in the RMP will be updated every five years or sooner
under certain circumstances, including major changes to the facility
or its covered processes. In addition, facilities will keep additional
Tips & supporting documentation on their risk management program on
Hints site.
?The executive summary
What Information Is in an RMP?
can be used by the communi
ty as a background piece for
events involving the facility, An RMP consists of an executive summary in text form as well as
such as developing exercises
answers to a series of questions focusing on individual elements of
and contingency plans. In
the risk management program. The latter information is reported
the Kanawha Valley in West
Virginia and in Augusta,
as data, such as names, dates, multiple choice selections, and "yes"
Georgia, the executive sum
or "no" answers.
maries have been used as a
tool to provide information to
the public. Each RMP will contain information on the identity of the facility, its
offsite consequence analysis, five-year accident history, prevention
?NAICS codes are a new
industrial classification sys program, and emergency response program.
tem that is replacing the
Standard Industrial Codes
The RMP is not like a contingency plan--even though we call it a
(SIC).
"plan." The RMP is primarily a series of data fields with numbers,
?LEPCs can compare the
words and phrases, and yes/no answers to specific questions. You
new RMP registration infor
mation with existing EPCRA can use information in the data fields to understand steps the facili
data about the facility. This
ty is taking to prevent or respond to a possible accident; for example,
is an opportunity to update
there will be information about employee safety training, inspec
"Facility" data in CAMEO.
tions by non-facility personnel, equipment maintenance, and man
?For alternative release sce
agement oversight.
narios, the facility can
choose modeling parameters
(e.g., typical weather and
Executive Summary
atmospheric stability infor
mation) that fit the local sit
uation. The executive summary in the RMP is your introduction to the facil
ity. This section includes a brief description of the facility, its pri
mary operations and processes, and the regulated substance(s)
handled. The executive summary also reviews the release scenar
ios from the offsite consequence analysis; general and chemical-
specific release prevention activities; the five-year accident history;
the emergency response program; relevant facility response and
prevention policies; and any planned changes to improve safety.

Registration
The registration section in the RMP provides information about the
facility (e.g., street address and emergency contacts) and the
processes in which regulated substances are found. The facility
page 10
specific data include points of contact for emergencies and risk
management program questions as well as standard address infor
mation.

For each covered process, the registration section lists the regulated
Tips &
substances (and quantities) in the process, the program level of the
process, and the North American Industry Classification System Hints
(NAICS) code for the process. The NAICS code identifies what the
process does (for example, water treatment or metal plating). ?As you review the data
about potential offsite conse
These data will help you identify specific operations at a facility or quences that facilities report
compare them with similar operations elsewhere. in their RMPs, keep in mind
that air modeling uncertain
ties are significant and dif
Offsite Consequence Analysis ferent models are likely to
produce different results.
(For more information,
Facilities with any Program 1 processes must include at least one
including explanations of
worst-case release scenario in their RMPs. Facilities with Program 2 some of the special terms
or Program 3 processes must include in their RMPs information used when discussing offsite
consequence analysis, see
about both worst-case release and alternative release scenarios.
"More on Offsite
The number of scenarios depends in part on the type and number Consequence Analysis" on
of regulated substances in covered processes. EPA has defined page 13.)
many of the release modeling parameters for the scenarios, ?Workers at the facility and
local residents may consult
although some facility-specific data (for example, certain weather
the accident history informa
conditions) can be used. tion as they try to under
stand previously unexplained
In the RMP, facilities report the modeling parameters and disper odors and gas clouds coming
from the facility. However,
sion model(s) that they used to do their offsite consequence analy
such events will only be
ses. You can use this information to "re-create" a facility's results, included in the accident his
tory if they meet the RMP
using CAMEO and ALOHA, EPA's Offsite Consequence Analysis
rule's criteria for reporting
Guidance, or RMP*Comp (available at http://www.epa.gov/ceppo). an accident.
For each release scenario, facilities report in the RMP the distance
?LEPCs may want to com
beyond which no serious, acute effects are anticipated; the residen pare the prevention program
tial population within that distance (in all directions from the point information for a local facili
ty with that of a similar
of release); and which categories of public receptors (for example, facility in the community, the
schools, residences, hospitals, commercial/industrial areas) or envi state or even the nation.
The LEPC might be able to
ronmental receptors (national/state parks, wildlife sanctuaries, and
work with facilities (private
federal wilderness areas) are located within that distance. Facilities ly, or through discussion at
may choose to submit a graphic file to illustrate each scenario on a open meetings) to introduce
safety practices that are
local map.
effective at another facility.

Five-Year Accident History
The accident history that facilities report in their RMPs provides
information on each accidental release from a regulated process
that resulted in specific on-site or offsite impacts during the pre
ceding five years, in greater detail than the EPCRA section 304
reports that you have received in the past. Releases from non-cov

page 11
RMPs Are on the Way!
ered processes, even if they involved regulated substances, or
releases of non-listed substances from covered processes, are not
included.

For each accidental release reported in the accident history section
of the RMP, facilities report standard descriptive information, as
well as some new information such as the weather conditions, on-
site and known offsite impacts, the initiating event and contributing
factors, whether offsite responders were notified, and any changes
made at the facility as a result of the accident.

Prevention Program
In the RMP, facilities report prevention program information sepa
rately for each covered process. This section of the RMP identifies
the major hazards for the process; the relevant process controls,
mitigation systems, and detection and monitoring systems; and any
changes made to the process since the last hazard evaluation. This
section also provides dates indicating when specific prevention
activities (for example, updates of procedures) were last conduct
ed. This information provides a basis for comparing similar opera
tions at different facilities.

Facilities must retain a substantial amount of supporting documen
tation to comply with program requirements of the RMP regulation.
While facilities are required to make this documentation available
to EPA or the state implementing agency, they are not required to
make it available to the public. If certain items are of interest to you
or to members of the public, you may want to talk to facilities about
making this information available. Much prevention program docu
mentation will relate to internal tracking or standard work records,
but there will also be hazard review or PHA (process hazards analy
sis) recommendations, compliance audit reports, and accident
investigation reports. EPA is encouraging facilities to make as much
of this information as possible (or some form of summary) avail
able to the public if requested. Because the RMP regulations
expand the information collection authority granted to LEPCs under
EPCRA section 303(d)(3) to apply to facilities with flammable regu
lated substances, the LEPC can get any of this information that is
necessary to develop an emergency plan.

Emergency Response Program
The RMP does not provide detailed information on the facility
emergency response program. There is a series of yes/no ques
tions indicating whether the facility has a response program and

page 12
also some dates indicating when specific activities (for example,
drills or exercises, plan review) were last conducted. Facilities that
have chosen to develop their own response capability will keep an
emergency response plan and procedures on site. As noted above,
the LEPC can request this information from all facilities subject to
CAA section 112(r) in developing an emergency plan.

Confidential Business Information

Facilities can claim some RMP data as confidential business infor
mation (CBI). An LEPC interested in obtaining data claimed CBI may
request that EPA determine whether the claim is valid. If EPA deter
mines that the information is not CBI, and after EPA has notified the
facility claiming CBI, the information may be released. If EPA deter
mines that the information is CBI, an LEPC may nonetheless be able
to obtain the information under 40 CFR 2.301(h)(3), which provides
for sharing of CBI with state and local governmental agencies hav
ing responsibilities under the CAA or its implementing regulations.
However, LEPCs can gain access to CBI data under this rule only if
they can protect its confidentiality.

Under EPCRA section 303(d)(3), LEPCs may compel an EPCRA sec
tion 302 facility to provide any information necessary to enable the
LEPC to develop and implement an emergency plan. An EPCRA sec
tion 302 facility must comply with such LEPC requests for informa
tion even if the facility has made a valid CBI claim under the RMP
regulation.

How Can LEPCs Access RMPs?

EPA has placed RMPs, except for the offsite consequence analysis
information, on the Internet in a format that allows the public to
search them and download any that are of interest. This database,
called RMP*Info, is located with other EPA data in Envirofacts on
the Internet at http://www.epa.gov/enviro.

To simplify access by state and local governments, EPA will set up
separate databases containing the full RMPs for all of the facilities
in each state. Additionally, EPA will provide software, called
RMP*Review, for use by implementing agencies, LEPCs, and others
to manage their databases. Please contact your EPA Regional Office
CEPP contact for details (see Appendix B).




page 13
RMPs Are on the Way!
MORE ON OFFSITE CONSEQUENCE
ANALYSIS
Not all LEPC members may have an extensive technical background,
but you will want to (1) understand how a facility derives its worst-
case and alternative release scenarios and (2) be familiar with the
underlying terminology. The following are answers to some of
EPA's most frequently asked questions.
Q: What Is Meant by a Worst-case Release Scenario?
Worst-Case Modeling
Parameters
EPA has defined a worst-case release as the release of the
largest quantity of a regulated substance from a single vessel or
Toxic endpoints: as speci
fied in the regulation for
process line that results in the greatest distance from the point
each regulated toxic sub
of release to a specified endpoint.
stance

Flammable endpoints: 1 psi
EPA requires that the worst-case release scenario incorporate
for all flammable substances
certain parameters related to the chemical released, conditions
Wind speed: 1.5 meters/sec
of the release, atmospheric conditions, and health effects of
(unless the facility can prove
concern ("toxic or flammable endpoints"). Facilities use these
this has not occurred in the
parameters to estimate the distance away from the location of a
last 3 years)
release beyond which no serious, acute effects are anticipated.
Stability class: F (unless
These parameters are discussed in more detail below.
facilities can prove this has
not occurred in the last 3
years)
Q: What Is Meant by an Alternative Release Scenario?
Ambient temperature: high
The RMP regulation requires Program 2 and 3 facilities to pro
est daily maximum tempera
ture in past three years
ject potential releases of regulated substances that are more
likely to occur than worst-case scenarios and to predict the con
Humidity: average humidity
for the site
sequences of such releases. These are called alternative
release scenarios. The RMP regulation provides information
Height of release: ground
level
that facilities must use for such predictions as part of doing the
offsite consequence analysis required for the risk management
Surface roughness: urban or
rural
program at the facility.
Gas density: model must
Q: What Is a Toxic Endpoint?
account for whether or not
gases are heavier than air
A toxic endpoint is the endpoint for a regulated toxic substance.
Temperature of substance:
For a particular regulated substance, it is the concentration of
highest daily maximum for
past three years or process
that substance in air below which it is believed that most peo
temperature, whichever is
ple could be exposed for up to one hour without serious health
higher (for liquids only)
effects. EPA has determined toxic endpoints for each of the
regulated toxic substances. The toxic endpoints are listed in
the RMP regulation.

Q: What Is a Flammable Endpoint?

A flammable endpoint is the endpoint for a regulated flamma
ble substance. How it is measured depends on the type of
release considered. For example, the flammable endpoint for a
page 14
vapor cloud explosion is based on the pressure from the result
ing blast wave. The flammable endpoints to use for different
types of releases are provided in the RMP regulation.

Q: What Is a Stability Class?

Pasquill stability classes (ranging from "A" to "F") are meteoro
logical categories of atmospheric conditions. Pasquill stability
class A represents unstable conditions under which there are
strong sunlight, clear skies, and high levels of turbulence in the
What about the Approach in
atmosphere, conditions that promote rapid mixing and disper
the "Green Book"?
sal of airborne contaminants. At the other extreme, class F rep
EPA, DOT, and FEMA pub
resents light, steady winds, fairly clear nighttime skies, and low
lished Technical Guidance for
levels of turbulence. Airborne contaminants mix and disperse Hazards Analysis (commonly
far more slowly with air under these conditions, and may travel known as the Green Book) in
1987. Many LEPCs have
further downwind at hazardous concentrations than in other
been using the Green Book to
cases. Stability class D, midway between A and F, is used for estimate vulnerable zones for
neutral conditions, applicable to heavy overcast, daytime or chemicals in the community.
The release modeling done
nighttime.
for the RMPs will be based
on parameters similar to
Q: What Is the Distance that Facilities Must Estimate for Their those in the Green Book, but
Release Scenarios? with some differences. (For
example, the RMP regulation
specifies parameters not
Facilities must estimate the distance from the location of a
used in the Green Book
release to the endpoint that could result from the accidental approach. Also, in recent
release of a regulated substance. They must estimate this dis years toxicologists have
refined the toxic endpoints
tance for each release scenario in their RMP. To understand
for some chemicals.) EPA
what populations could be at risk from an accidental release, encourages LEPCs to use the
the facility is to draw a circle with the facility at the center. The Offsite Consequence Analysis
Guidance approach to model
radius of the circle is the distance to the endpoint.
ing releases for any subse
quent planning, so the
Q: How Is The Distance to an Endpoint Estimated? results reported by industry
in their RMPs will be compa
Facilities estimate the distance to an endpoint by first estimat rable to those the LEPC cal
culates.
ing the amount of a regulated substance that would be released
in an incident (either a worst-case release scenario or an alter Appendix C of this booklet is
a detailed comparison of the
native release scenario), and then using air dispersion model
Green Book methodology and
ing techniques (or a tool that incorporates such techniques) to the methodology in EPA's
estimate the distance to an endpoint for that amount of the reg Offsite Consequence Analysis
Guidance.
ulated substance. Note that the distances that facilities report
in their RMPs are estimates. EPA has guidance documents
(Offsite Consequence Analysis Guidance as well as industry-
specific guidance for developing RMPs) and software
(RMP*Comp) to help facilities estimate the distances. Facilities
may use EPA's guidance or any other air dispersion modeling
techniques provided that the techniques meet certain condi
tions as outlined in the RMP regulation.



page 15
RMPs Are on the Way!
Q: What Is Meant by Air Dispersion Modeling Techniques?

Air dispersion modeling techniques are mathematical models
that are used to estimate the distance that a released substance
would travel from the location of the release to the endpoint,
given the amount of the substance released and certain condi
tions of the release. The estimated distance will vary depend
ing on the air dispersion model used.

Q: How Certain Is The Distance to The Endpoint?

For a given scenario, people can use different release models
and obtain predictions of the distance to an endpoint that may
vary significantly. Even using the same model, different input
assumptions can cause wide variations in the predictions.

LEPCs need to recognize that the predicted distances lie within
a considerable band of uncertainty and communicate this fact
to the public when they discuss the scenario results.
Differences in models may explain why two facilities handling
the same covered substances in the same amounts may have
come up with different results. (Of course, differences in pre
vention programs may also account for different results, partic
ularly in the case of alternative release scenarios.) EPA's
approaches are generally intended to produce conservative
results--they are more likely to overestimate distances. For
other models, you may want to ask the facility for an assess
ment of where its distance prediction lies within the plausible
range of uncertainties.

Q: If There Is an Accident, Will Everyone Within the Distance to the
Endpoint Be Hurt?

In general, no. For an explosion, however, everyone within the
circle would certainly feel the blast wave because it would
move in all directions at once. However, while some people
within the circle could be hurt, it is unlikely that everyone
would be. But releases usually do not lead to explosions. A fire
is more likely than an explosion, and fires are usually concen
trated at the facility.

For toxic chemicals, the released chemicals would usually move
in the direction of the wind. Only people in a small fraction of
the circle would be exposed if a release occurred. Whether
someone is hurt depends on many factors, such as whether the
chemical is dispersed by the wind, or if the release is stopped
quickly.

Generally, it is the people who are closest to the facility who
face the greatest danger. Although it is not impossible for peo
page 16
ple beyond the distance to the endpoint to be hurt, it is much
less likely. However, the risk should not be dismissed. The
RMP regulation assumes that a worst-case release involves the
failure of the single largest vessel containing a regulated sub
stance at the facility. It is conceivable, although highly unlikely,
that more than one vessel could fail at the same time, resulting
in a larger release than the worst-case scenario predicts. In
such a case, people beyond the distance to endpoint could be
affected.

Q: How Likely Are the Worst-case and Alternative Release
Scenarios?

It is generally not possible to provide accurate numerical esti
Tips &
mates of how likely it is that these scenarios will actually hap
Hints
pen. Quantifying risk for accident scenarios is rarely feasible
because there are few data related to rates for equipment fail
Ideas for LEPC Effectiveness
ure and human error.
Have you tried to revitalize
your membership recently?
In general, the risk of a worst-case scenario occurring is low.
In some cases, a new SERC
Although catastrophic vessel failures have occurred, they are chair or a new LEPC chair is
rare events. Combining them with worst-case weather condi able to recruit new members
for the LEPC.
tions (as required by the RMP regulation) makes the overall
scenario even less likely. This does not mean that such events As with every committee,
one or two active new mem
cannot or will not happen, but they are very unlikely to happen.
bers can energize the entire
For the alternative scenario, the likelihood of the release is LEPC.
greater and will depend, in part, on the scenario chosen.
Have a clear agenda. Start
(and end!) your meetings on
time.
LEPCS COORDINATE CHEMICAL SAFETY If you have subcommittees,
ACTIVITIES IN THE COMMUNITY check with them a few weeks
before the full LEPC meets.
Be sure that the subcommit
tees do their work in
Get Everyone Involved advance.

LEPCs should have broad-based membership that includes, at a
minimum, representatives of elected officials, law enforcement,
emergency management, fire service, emergency medical services,
healthcare professionals, local environmental and transportation
groups, hospitals, the media, community groups, and owners and
operators of the facilities covered under EPCRA.

Wide-ranging community involvement will increase the credibility
of the LEPC plan and improve community cooperation in an emer
gency. Both EPCRA and the RMP regulation assume that citizens
want chemical safety in the community. Including concerned citi
zens on the LEPC and inviting them to your meetings will promote
communication between industry and the public, foster under
standing of chemical hazards, and help quell rumors.
page 17
RMPs Are on the Way!
Enhancing LEPC-Industry Relations;
Encouraging Compliance

Since EPCRA passed in 1986, a rule of thumb is that effective LEPCs
include active and committed industry representatives. Industry
representatives bring expert understanding of chemicals and chem
ical processes. Numerous facilities have provided financial and
other support to make LEPCs successful.

The RMP regulation provides specific opportunities for you to work
more closely with the facilities in your community on risk commu
nication, accident prevention and risk reduction, and compliance
assistance. (See the later sections for discussions of risk communi
cation and accident prevention.) As you work with facilities
through these and other issues, you may become the organization
they turn to when they need to understand community concerns
and help in providing constructive answers to questions from the
public. In helping them, you can work to ensure that they address
community issues related to chemical safety quickly and accurately,
which will, in turn, make your LEPC the group on which the commu
nity relies.

Depending on the skills of your membership, the LEPC may be able
to serve as a local source of RMP compliance assistance. Although
you may not want to become involved with more technical issues,
almost all of the RMP program elements are well-suited to your
involvement.

Release Modeling
EPA has provided free copies of CAMEO (a software program that
helps LEPCs manage and interpret information about a facility and
its chemical inventory) to more than 2,000 LEPCs. Using ALOHA
and LandView (a software program that provides Census Bureau
data and helps users map facilities and nearby populations), LEPCs
can now assist facilities in conducting the offsite consequence
analysis required by the RMP regulation. Small businesses will
appreciate help in collecting and entering their release modeling
data and identifying public and environmental receptors that could
be impacted by a release. LEPCs can then incorporate this updated
facility information into the community plan.

Users should be aware, however, that ALOHA has some limitations
which may make it unsuitable for RMP offsite consequence analysis
modeling in certain situations. For example, ALOHA does not have
the capability to model the offsite consequences of flammable sub
stance releases, and for toxic substances, ALOHA only provides
endpoint distances out to a maximum of 6 miles from the source
page 18
(large releases of certain chemicals, such as chlorine, will exceed
this distance under worst-case conditions). If you desire to conduct
RMP OCA modeling in these and other situations for which ALOHA
is unsuitable, you should use a different model.

One such model is RMP*Comp. RMP*Comp is a software program
designed by EPA and the National Oceanic and Atmospheric
Administration (NOAA) specifically for the purpose of conducting
RMP OCA modeling. It follows the methods and techniques
described in EPA's RMP Offsite Consequence Analysis Guidance.
RMP*Comp is capable of providing OCA modeling results for all 140 Tips &
RMP regulated substances and provides endpoint distances out to a Hints
maximum of 25 miles. RMP*Comp is available for free--you can
download it from the Internet (http://www.epa.gov/ceppo) or order In June 1996, EPA and the
other National Response
a copy from the National Service Center for Environmental
Team (NRT) agencies pub
Publications (NSCEP) at 1-800-490-9198. lished integrated contingency
planning ("One-Plan") guid
ance. The NRT encourages
Working with Small Businesses facilities to develop one plan
to comply with all federal
Local planning and response officials can help small businesses contingency planning
requirements (rather than
sort out facility-specific preparedness issues, identify response
develop separate plans for
resources, and formalize their emergency response program. The each regulation). EPA, the
RMP regulation also may serve as an incentive for facilities to adopt Coast Guard, the Office of
Pipeline Safety at the U.S.
the "One Plan" approach and formalize incident command issues. Department of Transporta
This provides a perfect opportunity to discuss mutual aid agree tion, OSHA, and the Minerals
Management Service
ments and joint training and exercise programs.
promised to accept the one-
plan format whenever a
Response Coordination facility must submit a contin
gency plan to them for
review and approval. To
Facilities that do not have their own response team must coordinate obtain copies of the one-plan
with the LEPC concerning listed toxic chemicals, and with the fire guidance, contact EPA's
Hotline at (800) 424-9346.
department about listed flammable chemicals. Local fire officials,
in conjunction with the building inspector, can work with facilities
to improve fire prevention practices, including compliance with
NFPA standards or other fire and related codes.

Industry Outreach
LEPC industry representatives can provide other facilities with
technical assistance or contacts for further information on a variety
of prevention program issues. Assistance could include explaining
issues related to the OSHA Process Safety Management (PSM)
Standard (a regulation requiring certain facilities to implement acci
dent prevention activities similar to those described on page 8) or
help in collecting and understanding safety information, industry
safety standards, or approaches to employee training and equip
ment maintenance.
page 19
RMPs Are on the Way!
New Partnerships

The availability of RMP information also provides LEPCs with an
opportunity to develop new partnerships with other organizations
in the community. People and groups may need to be reminded
that you have available much specific information about chemicals
in your community. Although they may not be interested in the
entire RMP, medical professionals, the news media, planning/zon
ing officials, and researchers will likely find specific sections of the
RMPs from local facilities of particular interest. Working with them
will further extend the reach of the LEPC into the community, creat
ing a stronger constituency for the LEPC that enables you to take
advantage of a wider base of skills and experience.

Medical professionals (including emergency medical technicians,
doctors in private practice, health clinics, and hospitals) will appre
ciate information on potential acute health hazards as well as the
recommended treatment for exposures. Distributing a list of nearby
facilities and their regulated substances can assist in the first step; if
the medical professionals are interested, you can request a copy of
the emergency response plan and then selectively send out the first
aid and emergency medical treatment information. At the same
time, keep in mind that clinics and hospitals will want to know if
they are potentially vulnerable to an air release.

The news media can play an effective role in risk communication.
If you do not already have regular representation from local news
papers and radio and television stations on your LEPC, this is a
great time to get them involved. Now that the RMPs are available,
you are in a position to work with the news media to spread the
risk reduction message in your community.

You might consider producing press packets to help the local news
media understand and use RMP information. At the same time, you
can describe the other related activities of the LEPC and get addi
tional exposure for efforts such as commodity flow studies and
field exercises.

You may have multiple audiences within the news media. While
news reporters with an interest in environmental, public safety, and
health issues will likely find RMP information intriguing, broadcast
meteorologists may actually be the best people for discussing the
dispersion of air releases with the public.

The accidental release scenarios in the offsite consequence analy
sis will provide local planning and zoning officials with more
information when they address development issues. Being aware

page 20
that a new school, hospital, residential area, or shopping center
could be directly affected by a facility using an acutely toxic or
highly flammable substance can only improve the decision-making
process.

Engineering and environmental professionals, and researchers
at local colleges and universities, are likely to find RMP information
of even greater interest than EPCRA and other environmental data.
If there are specific operations or types of facilities of significant
concern to the community, these individuals may be willing to share
with you the burden of analyzing the relevant data and communi
cating it to the public.

Talk with Neighboring Communities

Consult with your neighboring LEPCs, especially if you have com
mon chemical risks and concerns. If two or more adjacent localities
have similar facilities or facilities affecting more than one LEPC, you
can split up the work of collecting and comparing RMP information.
Using fewer resources, you will be able to produce results and
share them with others. Such efforts can also serve as the basis for
risk reduction and further coordination, including joint training and
field exercises, mutual aid agreements, and pooling of financial
resources to accomplish larger-scale initiatives.

In an emergency, you may have to call on neighboring communities
for help or they may call you. In many cases, contingency plans
must include several communities to be effective. Consider the
need to:
(1) Identify whom to call in other planning districts if you need
help in an emergency;
(2) Ask them how they are funding their activities;
(3) Identify available response equipment and personnel;
(4) Negotiate procedures for mutual assistance for emergencies
that cross boundary lines;
(5) Coordinate your hazards analyses;
(6) Coordinate your review of transportation routes; and
(7) Investigate sharing computers or other resources.

In addition to these planning and response activities, talk to your
neighbors about steps you can take together to prevent chemical
accidents. You might go together to visit a facility that has a note-

page 21
worthy safety record. You might invite an expert in process safety
management to speak to a joint meeting of your LEPCs (and invite
the public to attend!).

Each LEPC should consider its neighboring LEPCs as partners
and sources of help. Other LEPCs share your problems;
working with them may help you find common solutions.
Take Note

RISK COMMUNICATION: LEPCS ARE A
BRIDGE BETWEEN THE PUBLIC AND
LOCAL INDUSTRY
Both the EPCRA and RMP regulations provide an opportunity to
promote and strengthen dialogue between the community and
industry on accident prevention and chemical emergency pre
paredness issues. Risk communication is an opportunity to build a
level of trust among the LEPC, companies with hazardous chemi
cals, and the community at large.

One of the most important factors that affects people's per
ceptions about risk is whether they feel in control. Offer
people a means to participate in decision-making about
chemicals in the community. Because LEPCs include repre
Take Note sentatives from government, industry, and citizen groups,
they offer a good setting for encouraging the different inter
ests to work together.

Keep in mind the importance and legitimacy of public concerns
about chemicals in the community. People generally are less toler
ant of risks they cannot control than of those they can. For example,
most people are willing to accept the risks of driving because they
have some control over what happens to them. However, they are
generally less comfortable accepting the risks of living near a facili
ty that handles hazardous chemicals if they feel that they have no
control over whether the facility has an accident. The Clean Air
Act's provision for public availability of RMPs, along with EPCRA's
requirements for providing annual reports on hazardous chemicals,
gives the public an opportunity to take part in reducing the risk of
chemical accidents that might occur in your community.

Interested citizens may independently obtain RMPs (except for
CBI). These citizens might then ask LEPCs to explain the informa
tion in the RMPs. Although it often is left to technical experts, edu
cating the public about risks and involving them in decisions about
what is an "acceptable" level of risk are important challenges for
LEPCs.

page 22
Basic Rules of Risk Communication

Risk communication means establishing and maintaining a dia
logue with the public about the chemical hazards in your communi
ty and discussing the steps that have been or can be taken to
reduce the risk posed by these hazards. There are seven "rules" of
risk communication that have been developed based on many
experiences of dealing with the public about risks.
(1) Accept and involve the public as a legitimate partner

(2) Plan carefully and evaluate your efforts

(3) Listen to the public's specific concerns

(4) Be honest, frank, and open

(5) Coordinate and collaborate with other credible sources

(6) Meet the needs of the media

(7) Speak clearly and with compassion

There is an informal eighth rule for risk communication:
Know what you are talking about. Not everyone on the LEPC
will know everything about hazardous chemicals. Call on
chemical engineers, health professionals, scientists, and
Take Note
school teachers (e.g., science, chemistry) to help you. Retired
professionals are frequently helpful.

Hazards Versus Risks

Hazards are inherent properties that cannot be changed. Chlorine
is toxic when inhaled or ingested; propane is flammable. There is
little that you can do with these chemicals to change their toxicity
or flammability. If you are in an earthquake zone or an area affect
ed by hurricanes, earthquakes and hurricanes are hazards. When a
facility conducts its hazard review or process hazards analysis, it
will identify hazards and determine whether the potential expo
sure to the hazard can be reduced in any way (e.g., by limiting the
quantity of chlorine stored on-site).

Risk is usually evaluated based on several variables, including the
likelihood of a release occurring, the inherent hazards of the chem
icals combined with the quantity released, and the potential impact
of the release on the public and the environment. For example, if a
release during loading occurs frequently, but the quantity of chemi
cal released is typically small and does not generally migrate offsite,
the overall risk to the public is low (even though workers may be at
page 23
RMPs Are on the Way!
risk). If the likelihood of a catastrophic release occurring is
extremely low, but the number of people who could be affected if it
occurred is large, the overall risk may still be low because of the low
probability that a release will occur. On the other hand, if a release
occurs relatively frequently and a large number of people could be
affected, the overall risk to the public is high.

The RMP regulation does not require facilities to assess risk in a
quantitative way because, in most cases, the data needed to esti
mate risk levels (for example, one in 100 years) are not available.
Even in cases where data such as equipment failure rates are avail
able, there are large uncertainties in using those data to determine
a numerical risk level for any given facility. Therefore, you may
want to assign qualitative values (high, medium, low) to the risks
that you have identified at facilities in your community, but you
Tips & should be prepared to explain the terms if you do. For example, if
you believe that the worst-case release is very unlikely to occur,
Hints
you must give good reasons; you must be able to provide specific
examples of measures taken to prevent such a release, such as
Who Will Ask Questions?
installation of new equipment, careful training of workers, and rig
?Persons living near the
facility or working at a orous preventive maintenance. You can ask facilities to provide
neighboring facility
documentation to support claims about the level of risk.
?Special interest groups
including environmental
Three Scenarios When You May Need to
organizations, police depart
ments, zoning and planning
Communicate with the Public about Chemical
boards, chambers of com
Risk
merce, unions, and various
civic organizations

?Journalists, reporters, and Scenario A: During or immediately after an accidental
other news media organiza
chemical release
tions

?Medical professionals, edu
When there is an accident, the news media and the public always
cators, and consultants
have questions. First they might ask:
? What is going on?

? Am I or my children at risk?

? Should we evacuate or shelter in place?

? What are you doing to stop this accident from spreading?

A little while later, they might ask:
? How did this happen?

? How long will we feel "short-term" health effects?

? Are there any hidden health effects?

? What are you doing to prevent this from happening again?
page 24
To answer questions like these, you will need to have a community
emergency plan and know the contents of that plan. Do you have a
record of chemicals in the community and what their potential
health effects are? Do you identify an emergency contact for each
facility in the community? Does your emergency plan include clear
provisions for determining whether evacuation and/or sheltering
in-place might be necessary? Has one person (or office) been
assigned to provide information to the public? Have you prepared
sample press releases so that you can quickly provide helpful
information to the public? Do you have procedures for telling the
public about upcoming LEPC meetings so that the public can attend
and ask questions? Have you worked with the mayor's office and
local response agencies to ensure that the LEPC is the focal point
for risk communication?

Scenario B: Routine or past accidental releases of chemi
cals
After accidental releases, the news media and the pubic may
become more interested in chemical hazards in the community.
They may search the Toxic Release Inventory (TRI) available under
EPCRA section 313 for more information about chemical releases.
They may search for information provided under the RMP regula
tion about accidental releases during the past five years. This
search could lead to newspaper articles and television reports
about chemicals being released in the community. You may then
hear questions like these:
? What risk do these exposures pose for my family?

? Do these emissions affect our health?

? Why are facilities allowed to release these chemicals?

? Is the facility in compliance with federal, state, and local laws?

? Are there other facilities that should be reporting similar
events?

The LEPC might take several actions. Invite a toxicologist or a doc
tor to an LEPC meeting to discuss specific chemical hazards with
the public. Share your information about other facilities in the
community. Share information on the risk management program
regulation and EPCRA. Invite the facility emergency coordinator to
explain steps the facility takes to prevent serious accidents even
though there are routine releases. Work with facilities to take
action to reduce risk.

page 25
RMPs Are on the Way!
Scenario C: Chemicals Stored in the Community
The search of TRI and RMP databases could eventually lead to sto
ries about all the chemicals stored in the community. The public
and the news media may then ask questions like these:
? Are the chemicals stored properly?

? What are the chances of dangerous chemicals leaking?

? Can these stored chemicals lead to an accident?

? If these chemicals are released, what could be the health
effects?

? Can we reduce the amount of chemicals stored in the com
munity, and use less hazardous chemicals and inherently safe
technologies?

? What else can we do to reduce the risk of accidents?

In this instance, the LEPC can turn to all the data it has collected
from EPCRA and RMP reports. These questions can be more easily
addressed if you have one software program like CAMEO to man
age data. You may also want to hold a meeting that includes facility
representatives so that everyone can discuss realistic steps to pre
vent accidental chemical releases in the community.

A Special Case: Dealing with Worst-Case
Scenarios

In the beginning, public interest might focus on the worst-case sce
nario, rather than on prevention and preparedness. Worst-case
scenario information must be explained to the public in a way that
promotes perspective and understanding, rather than confusion.
The experience of the heavily industrialized Kanawha Valley of
West Virginia illustrates how worst-case scenario data can open
lines of communication between industry and the public. Despite
fears that information on worst-case scenarios would produce
strong negative reactions toward local industry, the chemical indus
try worked with EPA and state and local officials to release worst-
case data well ahead of the RMP rule schedule. The Safety Street
demonstration proved that the public could understand informa
tion on potential accidents and risks and act constructively. Due in
part to a pro-active approach by industry, and with the sponsorship
of the LEPC, the public evaluated the information presented to the
community and was able to take part in a constructive dialogue
with industry and public officials.

page 26
Potential Risk Communication Activities

1. Open a risk management dialogue 5. Schedule follow-up meetings or
with facility owners/operators, com presentations at other public gath
munity leaders, and the public to erings to allow LEPC and industry
focus on risk reduction activities. representatives to respond to these
issues.
2. Understand how the public will
access information and what impact 6. Draw upon sample questions and
this will have. answers contained in the Risk
Communication chapter of EPA's
3. Reach out to the small business General Guidance on Risk
community. Many small facilities Management Programs. Work with
will not have the expertise or industry to understand the underly
resources to respond effectively to ing issues and develop answers to
the technical questions that their specific questions, focusing on actu
RMPs may produce. By reaching out al or potential risk reduction
to them, you can help develop a actions.
more community-wide approach to
addressing risk management ques 7. Plan a special meeting to unveil
tions. local RMPs.

4. Identify key issues of concern in 8. Work with the news media to
your community. Use LEPC meetings reach a wider audience.
as a forum to collect and document
9. Explore using community bulletin
concerns, which then can be for
boards on local access cable televi
warded to individual facilities, as
sion stations and community
appropriate.
Internet sites.


Respond to Concerns

LEPC involvement creates a process through which people, who
otherwise might be mistrustful or even adversarial, can work
together to understand, address, and prepare for chemical risks in
the community. Sometimes, anger about what the public perceives
as risky situations arises not so much from the actual risk but from
people's feeling that they have no control over what is happening to
them. You can reduce this by including the public as a partner in
discussions about what is an acceptable risk in your community
and how to reduce risks.

An LEPC that arms itself with basic information about the RMP pro
gram, makes an effort to look at the RMPs for facilities in the com
munity, and encourages facilities to involve the LEPC, response


page 27
RMPs Are on the Way!
agencies, and the public in a discussion of these plans and the risks
they disclose will do a great service to the community.


IMPROVING YOUR EMERGENCY PLANS
Several elements of the RMP regulation requirements support your
local emergency planning process. The offsite consequence analy
sis can provide you with detailed information to continue prioritiz
ing and planning for chemical hazards in the community. While
Tips &
EPA does not consider the worst-case release scenario to be the
Hints most realistic basis for response planning, you may be able to use
the distances or the population potentially affected to set priorities.
Setting Priorities

Let us say there are six The alternative release scenarios, which may be based on actual
facilities in your community
incidents (either at the facility or within the industry as a whole) or
submitting worst-case releas
the results of the facility hazard evaluation, are intended to repre
es scenarios for toxic regu
lated substances: two have
sent realistic events for planning purposes. You will want to meet
worst-case distances greater
with facility officials to discuss the details in the alternative sce
than six miles, two have
worst-case distances of nario(s) and work together to ensure that the community response
approximately three miles,
plan realistically addresses the alternative scenarios. This activity
and two report distances of
will help you meet the EPCRA requirement to update your commu
less than one mile. As a
first step, you might rank
nity plan annually. The alternative scenarios can also provide a
them into three categories by
useful basis for an exercise.
distance. A further look at
the RMP data may reveal
that the two facilities with The RMP regulation supplements the information-gathering author
the greatest distances are
ity granted under EPCRA section 303(d)(3) to local planning and
located more remotely from
response officials. Now, in addition to EPCRA section 302 facilities,
populated areas than the two
with the smallest distances. facilities with flammable regulated substances must provide LEPCs
As a result, the former may
and emergency planners, upon request, any information necessary
have estimated that their
for developing and implementing the community emergency
worst case would impact a
much smaller residential
response plan.
population, and the latter
may have reported that
The emergency response program provisions of the RMP regulation
there also are schools and a
ensure that all facilities with a substantial inventory of highly
hospital within their worst-
case distance. The RMP will
volatile flammable substances work with the fire department or the
provide a straightforward
LEPC if they also have highly toxic substances, as was done for
way of considering these fac
tors without having to acutely toxic substances under EPCRA section 302. Even if the facil
research or analyze the data
ity will not respond to a release (for example, with its own hazmat
on your own.
team), it still must coordinate with you or the fire department on
response actions and ensure that a system for emergency notifica
tion is in place. This requirement means that the facility must be
certain that local responders can handle potential releases. If
responders do not have the training or equipment to respond to a
particular type of chemical release, the facility must arrange for an
appropriate response (for example, by establishing a mutual aid
agreement with an industry response team).

page 28
What You'll Find in the RMP

Based on a hazard review or process hazard analysis for each
covered process, a facility will list in the RMP:
? The regulated substances in the process;

? The NAICS code for the process;

Tips &
? The major hazards of the chemicals (toxic release, fire,
explosion) and of the process (for example, overfilling, Hints
overpressurization, runaway reaction);
With RMP data from other
? The process controls in use; facilities, you can make com
parisons with a local facility
by asking the following the
? Any mitigation systems; and
questions:

? Information on whether the facility has monitoring or ?Is the quantity of the
chemical the facility is using
detection systems.
or storing unusual?

For Program 2 processes, the RMP will also include a list of ?Has your facility identified
the same major hazards as
industry codes and standards that the facility complies with for similar facilities?
the process.
?Does your facility have the
same kinds of process con
trols as similar facilities?
WORKING WITH INDUSTRY TO
PREVENT ACCIDENTS ?Does your facility use the
same kind of mitigation sys
tems as similar facilities?
The RMP regulation is intended to prevent chemical accidents and
mitigate the consequences of the accidents that do occur. Facilities ?Do facilities in this indus
try generally have detection
will take the first step in achieving this goal when they develop and systems?
implement their risk management program, especially in the formal
If the facility you are
elements of the prevention program. However, the availability of reviewing has not listed
RMP information (particularly the offsite consequence analysis and major hazards that similar
facilities have identified, this
the results of the hazard evaluation) is expected to encourage the may indicate a problem with
second step of this process: an ongoing dialogue between the com the facility's hazard review
or PHA. If it has fewer con
munity and industry leading to practical changes that can reduce
trols, mitigation systems, or
the risk of a chemical accident. detection systems than simi
lar facilities have, you may
As with emergency preparedness, the LEPC should serve as the want to talk to the facility
about possible changes that
forum for the community and industry on accident prevention. You
could reduce risk.
will want to meet with facility officials to discuss the offsite conse
quence analysis, understand the facility's prevention program, and
perhaps suggest additional steps to prevent accidental chemical
releases.

Using RMP*Info, the national RMP database, you will be able to
gather the information necessary to compare practices at local facil
ities with other facilities in the same industry in your state or even

page 29
RMPs Are on the Way!
in other parts of the country. RMP*Info will let you search on a par
ticular chemical and NAICS code to identify other facilities that use
the same regulated substance in the same type of process as the
Tips & local facility of interest to you (for example, chlorine for water treat
ment). Information on the number of employees will help you
Hints
focus on facilities of similar size, which will make the comparisons
You might set up a public more appropriate.
recognition program to draw
attention to local facilities
If you ask local facility officials in advance, they may be willing to
that have especially good
provide technical or other forms of assistance to help you under
accident prevention pro
grams. stand accident prevention techniques in specific industries.

Once you have a list of other similar facilities, you can print out the
RMPs or parts of the RMPs for these facilities and compare them to
the RMP for your local facility. (This could even be a good research
project for students at the local high school!)

You may be pleasantly surprised by the results of your work; you
may find that your local facility is among the best in the nation. On
the other hand, if the local facility does not have certain process
controls or a detection system typically used by similar facilities, or
if it stores ten times as much of the regulated substance as anyone
else, you have some solid information with which to start a dia
logue on risk reduction.

In addition, keep in mind this is the first time that these types of
data have ever been collected on a national basis. In some cases,
local facilities may be very interested in what you find. Based on
the prevention programs of similar facilities in other parts of the
country, local facilities may initiate state-of-the-art accident preven
tion practices.




page 30
A FEW MORE SUGGESTIONS
Now that you have an idea of how you can become involved in the
Risk Management Program and accident prevention, you may have
a few questions about how to proceed. The following are sugges
tions to help you identify resources for information, funding, and
legal issues.

Funding Your Activities

Some states and communities have appropriated general revenue
funds for LEPC activities; others are relying on implementation fees
and existing state agency budgets. Because states have limited
resources, each LEPC must find the means for achieving its goals.
Some LEPCs will do their work with little funding. Your LEPC mem
bers may already be donating their time.
Tips &
EPA's Chemical Emergency Preparedness and Prevention (CEPP) Hints
Technical Assistance Project Grants offer funding for state, local, and
Tribal agencies for implementing the Risk Management Program If you anticipate implement
and for developing the underlying support system. Awards are ing the RMP regulation in
your community, check
made using the Clean Air Act Section 112(1)(4) and Section EPA's Factsheet, "Funding
103(b)(3) authorities. These authorities allow EPA to award grants Sources for Implementing the
Risk Management Program",
related to the Risk Management Program directly to local govern
or the National Governors'
ments. The grantee must provide matching funds equal to 25 per Association December 1997
cent of the total project cost. To obtain further information on the report, State Strategies and
Considerations for Implement
CEPP grants, contact CEPPO. ing the Chemical Accidental
Release Prevention Program.
Liability

Some LEPCs and individual LEPC members have expressed concern
that they might be held legally liable if they approve an emergency
response plan that proves to be inadequate during an accident.
Check with your SERC about your state law and ask about liability
considerations and protection. Some LEPC members have asked
whether they invite liability issues by reviewing facility RMPs.
SERCs are generally considered state agencies and are, therefore,
covered by the state's immunity provisions. Some states have
extended this immunity to LEPCs through laws or through legal
decisions. Others have provided liability coverage for LEPCs.
LEPCs may also be able to address liability concerns by clearly stat
ing (1) the limitations of any review they conduct of RMPs, and (2)
that they neither have nor assume any legal obligations for review
ing RMPs.



page 31
RMPs Are on the Way!
Risk Management Program Resources
Source of Information Location and Telephone Number
My SERC




My LEPC




RMP Implementing Agency for my state




EPA Regional Contact
for EPCRA and RMP



EPA's Chemical Emergency Preparedness http://www.epa.gov/ceppo
and Prevention Office website

The RCRA, Superfund and Toll free: (800) 424-9346
EPCRA Hotline TDD: (800) 553-7672
Washington, DC area:
703-412-9810
Fax: 202-651-2061

Other hotlines




Handy Reference

Using the table above, fill out the information that applies in your
case, clip, and save for your use. For information about the EPA
Regional Contact, see Appendix B.




page 32
Contents of this Section:
Appendices:
A: Checklist璉deas for Action
B: EPA Regional Office Contacts for EPCRA
and RMP Programs
C: Some Background Information?br> Comparison of Green Book and RMP
Offsite Consequence
Analysis (OCA) Guidance Methodology
D: Regulated Substances瑿hemicals
Covered by the RMP Regulation and
Their Threshold Quantities

Attachments:
?Y2K Alert
?Customer Satisfaction Survey




page A-1
RMPs Are on the Way!




page A-2


APPENDIX A:



CHECKLIST璉DEAS FOR ACTION

Visit EPA's chemical emergency preparedness and prevention
website at http://www.epa.gov/ceppo. This site contains all the up-to
date information about both EPCRA and the RMP regulation, including
electronic copies of relevant documents.

Call the RCRA, Superfund and EPCRA Hotline at 1-800-424-9346 for
answers to your questions and for help in getting copies of documents.

Identify facilities. Use the list of regulated substances at the back of
this booklet and your EPCRA section 312 reports (Tier II) to identify facili
ties that may be covered by the new RMP regulation. Remember, though,
that EPCRA reports provide information on chemicals for the facility as a
whole, while the RMP rule applies to a facility based on how much of a
chemical it has in a single process.

Contact these facilities and see if they want to work with you in shar
ing RMP information in your community.

Arrange public information-sharing events with interested facilities.
Consider:
? Having special LEPC meetings for this purpose;
? Having local facilities host meetings that include the LEPC
and members of the public; and
? Organizing an event at a shopping mall or auditorium at
which several facilities can discuss their RMP information
with interested local citizens.
Work with facilities to: reduce chemical inventories; substitute less
hazardous chemicals; use inherently safe technologies; and add new pre
vention measures.

Develop a public recognition program to honor your firefighters,
police department, and other first responders for their expertise in
responding to hazmat incidents. Honor facilities who have a noteworthy
accident prevention program. Honor volunteer groups like the Red Cross.

Recruit effective LEPC members. Check to see if inactive members
want to continue on the LEPC. If not, take this opportunity to recruit inter
ested and effective new members. Check with your SERC and/or neigh
boring LEPCs for ideas about new members.

Ensure a representative LEPC. Make sure your LEPC membership is
broad-based and representative of your community.

Leverage Resources. Organize your LEPC to use available resources
such as students, retired chemical engineers, chemists, health profession
als, and trade and volunteer organizations.


page A-3
RMPs Are on the Way!



Include small business representatives in your membership and
invite them to meetings.

Publicize the LEPC. Form a subcommittee with the assignment to make
the LEPC better known in the community. Advertise your meetings in the
newspapers and on TV and radio. Invite the news media to attend your
meetings and report on them. Tell your citizens about the information
you have about chemicals in the community.

Educate the community. Form a subcommittee on public education
and information to help the public understand chemical risks in the com
munity, to respond to requests for information about chemicals in the
community, and to involve the public in the emergency planning process
as well as chemical accident prevention activities.

Review this booklet's section on New Partnerships. Who in your
community might be interested in the LEPC and its work?

Review your current community response plan. How can it be
improved using new RMP information?

Coordinate plans. Ensure that your community response plan is coor
dinated with the emergency response programs of facilities in the com
munity.

Develop an up-to-date list of response and mitigation equipment
in the community. Where is the equipment stored? The new RMP infor
mation should be of help to you on this task.

Get training and technical assistance. Contact your SERC and/or
your EPA regional office to find out about training and other sources of
technical assistance in your area.

Find the contact person. Contact your SERC and/or your EPA regional
office to find out who will be the official implementing agency for the
RMP program in your area as well as what RMP initiatives are underway
in your state.

Get a copy of EPA's Guidance for Implementing Agencies to learn
how you can get more involved in the workings of the program. You may
even decide to be the RMP implementing agency in your area.

Obtain the Toxic Release Inventory (TRI) data for facilities in your
area to ensure that you have all available information about chemicals in
your community.




page A-4
APPENDIX B:
EPA REGIONAL OFFICE CONTACTS FOR EPCRA AND RMP
PROGRAMS
You can also consult EPA's CEPPO website (http://www.epa.gov/ceppo) for information about Regional and state
contacts.


EPA Region Point of Contact and Telephone Number


1 Maine, Vermont, New Hampshire, Massachusetts, Ray DiNardo
Connecticut, Rhode Island US EPA Region 1 New England (Mail Code: SPP)
JFK Federal Building
One Congress Street
Boston, MA 02114-2023
(617) 918-1804



2 New York, New Jersey, Puerto Rico, Virgin John Higgins
Islands US EPA Region 2 (Mail Code: 211)
2890 Woodbridge Avenue
Edison, NJ 08837-3679
(732) 906-6194



3 Delaware, Virginia, Pennsylvania, District of David Wright
Columbia, West Virginia, Maryland US EPA Region 3 (Mail Code: 3HW33)
1650 Arch Street
Philadelphia, PA 19103-2029
(215) 814-3293



4 North Carolina, South Carolina, Kentucky, Bill Taylor
Tennessee, Georgia, Florida, Alabama, Mississippi US EPA Region 4
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, GA 30303
(404) 562-9167



5 Ohio, Indiana, Illinois, Michigan, Minnesota, Mark Horwitz
Wisconsin US EPA Region 5 (Mail Code: SC-9J)
77 West Jackson Blvd.
Chicago, IL 60604
(312) 353-9045



Continued on next page




page A-5
RMPs Are on the Way!



EPA Region Point of Contact and Telephone Number





6 Texas, Louisiana, Arkansas, Oklahoma, New Steve Mason
Mexico US EPA Region 6 (Mail Code: 6E-E)
Allied Bank Tower
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 665-2292



7 Iowa, Kansas, Missouri, Nebraska Mark Smith
US EPA Region 7 (ARTD/CRTB)
901 N. 5th Street
Kansas City, KS 66101
(913) 551-7876



8 Colorado, Utah, North Dakota, South Dakota, Eric Steinhaus
Montana, Wyoming US EPA Region 8 (Mail Code: EPR-ER)
One Denver Place
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 312-6837



9 Arizona, Nevada, California, Hawaii, Guam, Nate Lau
America Samoa US EPA Region 9 (Mail Code: SFD-5)
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-2337



10 Oregon, Washington, Idaho, Alaska Lisa McArthur
US EPA Region 10 (Mail Code: HW-093)
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-0383




page A-6
APPENDIX C:
SOME BACKGROUND INFORMATION瑿OMPARISON OF
GREEN BOOK AND RMP OFFSITE CONSEQUENCE
ANALYSIS (OCA) GUIDANCE METHODOLOGY

Green Book OCA Guidance
Purpose

Help LEPCs conduct site-specific hazards analysis for Help owners or operators of regulated sources to con
airborne releases of extremely hazardous substances duct offsite consequence analysis required under
(EHSs) regulated under EPCRA section 302. CAA section 112(r).

Chemicals Covered
About 390 toxic gases, liquids, and solids. 77 toxic gases and liquids and 63 flammable gases
and volatile, flammable liquids.
Chemicals listed based on toxicity alone; volatility not Toxic liquids (with a few exceptions) have vapor pres
considered. sure at ambient temperature of at least 10 millimeters
of mercury.

Endpoints
Levels of concern (LOC) set for EHSs based on (1) one- Toxics:
tenth of the NIOSH IDLH or (2) one-tenth of an esti- Endpoints set by rule as (1) Emergency Response
mated IDLH based on mammalian toxicity data. Planning Guideline Level 2 (ERPG-2) set by AIHA or (2)
EHS LOC. Many endpoints are different from EHS
LOCs.
Flammables:
Endpoints set by rule for blast overpressure from
vapor cloud explosions, heat radiation from fires, and
dispersion to the flammability limit.
Use of endpoints: Use of endpoints:
Use of the LOC is not required - other endpoints are Specified endpoints must be used for consequence
also suggested. analysis.



continued on next page




page A-7
RMPs Are on the Way!

Green Book OCA Guidance

Initial Screening (Green Book)/Worst-Case Releases (OCA Guidance)
Quantity Released
Maximum quantity that could be released from largest Greatest quantity in a single vessel or in a pipe, con
vessel or interconnected vessels. sidering administrative controls.

Release Rate
For Toxic Gases
Gases under ambient conditions: Gases under ambient conditions:
Substances that are gases under ambient conditions Substances that are gases under ambient conditions
are assumed to be released over 10 minutes. and are handled as gases, as liquids under pressure,
or refrigerated liquids that would form pools with a
depth of 1 cm or less upon release are assumed to be
released over 10 minutes.
Liquefied refrigerated gases: Liquefied refrigerated gases:
No provision for gases liquefied by refrigeration Gases handled as refrigerated liquids at ambient
under ambient pressure. pressure that would form pools with depth greater
than 1 cm are treated as liquids.
Mitigation: Mitigation:
No method provided. Method provided for reducing the release rate for
gases released in enclosures.

For Toxic Liquids
Liquid release: Liquid release:
Assumed to be instantaneous. Assumed to be instantaneous.
Release to air: Release to air:
Pool evaporation; equation for pool evaporation uses Pool evaporation; equation for pool evaporation uses
a mass transfer coefficient for water of 0.24 cm/sec. a mass transfer coefficient for water of 0.67 cm/sec
(i.e., evaporation rate increased by factor of about 3
over Green Book rate).
Liquid density: Liquid density:
All liquids assumed to have the same density as water Chemical-specific density factors provided for estima

for estimation of pool size. tion of pool size.

Solutions: Solutions:

No method provided for solutions. Method and data provided for estimating release

rates for common water solutions and oleum.

Mitigation: Mitigation:
Method provided for estimating release rate from Method provided for estimating release rate from

diked area. diked area.

No method provided for mitigation of release rate for Method provided for reducing the release rate for liq

liquids released in buildings uids released in buildings.

Temperature: Temperature:
Factors provided for estimation of release rate at 25oC Factors provided for estimation of release rate at 25oC
and the boiling point. and the boiling point. Factors generally significantly
larger than Green Book factors because of revised
mass transfer coefficient and revised chemical-specific
data.
Temperature correction factors provided for tempera
tures between 25 and 50oC.


page A-8
Green Book OCA Guidance

Initial Screening (Green Book)/Worst-Case Releases (OCA Guidance)璫ontinued
For Toxic Solids
Solids with particle size 100 microns or less or solids None regulated.
in solution assumed released in 10 minutes; factors
provided for release rate estimation for molten solids.
Flammable Substances
Not covered. Vapor cloud explosion of entire quantity assumed,
with yield factor of 10%.
Meteorological Conditions
F stability, wind speed 3.4 miles per hour (1.5 meters F stability, wind speed 1.5 meters per second.
per second).
Modeling Conducted
Neutrally buoyant gases and vapors: Neutrally buoyant gases and vapors:
Gaussian model used for neutrally buoyant plumes. Gaussian model used for neutrally buoyant plumes.
?Continuous releases assumed, even for 10-minute ?10-minute releases; i.e., release assumed to stop
releases. after 10 minutes (with 10-minute averaging time).
?60-minute releases (with 30-minute averaging
time).
Dense gases and vapors: Dense gases and vapors:
No dense gas modeling. SLAB model used for dense gases.
(Note: The RMP Rule requires consideration of gas ?10-minute releases (with 10-minute averaging
density for offsite consequence analysis) time).
?60-minute releases (with 30-minute averaging
time).
Vapor cloud explosions:
TNT-equivalent model used for vapor cloud explo
sions.

Distance Tables Provided
Neutrally buoyant plume table only: Toxics:
Rural conditions only for screening. Neutrally buoyant plume tables:
Generally gives significantly greater distances for the ?Rural - 10 minute and 60 minute.
same release rate and toxic endpoint than the OCA ?Urban - 10 minute and 60 minute.
Guidance tables. Dense gas tables:
?Rural - 10 minute and 60 minute.
(Note: The RMP Rule requires that rural or urban ?Urban - 10 minute and 60 minute.
topography be used, as appropriate.) Chemical-specific tables:
?Ammonia liquefied under pressure.
?Ammonia solution.
?Chlorine.
?Sulfur dioxide.
Flammables:
Vapor cloud explosion distance table.
Maximum Distance in Tables
10 miles 25 miles


page A-9

RMPs Are on the Way!

Green Book OCA Guidance

Reevaluation (Green Book)/Alternative Scenario Analysis (OCA Guidance)
Quantity Released
Estimate quantity based on site-specific information. Estimate quantity based on site-specific information.
Release Rate
For Toxic Gases
Estimate release rate based on site-specific informa Gases under pressure:
tion. Estimation methods for:
Specific methods not provided. ?Gaseous release from tank (based on hole size and
tank pressure.
?Gaseous release from pipe.
?Release of gas liquefied under pressure:
- from vapor space,
- from liquid space.
Liquefied refrigerated gases:
Gases handled as refrigerated liquids at ambient
pressure are treated as liquids.
Mitigation: Mitigation:
No method provided. Method provided for reducing the release rate for

gases released in enclosures.

Active mitigation measures also discussed.


For Toxic Liquids
Liquid release: Liquid release:
Estimate release rate based on site-specific informa Estimation methods for:
tion. ?Release from tank under atmospheric pressure.
?Release from pressurized tank.
?Release from pipe.
Liquid density: Liquid density:
Not considered. Considered as for worst case.
Solutions: Solutions:
No method provided for solutions. Considered as for worst case.
Release to air: Release to air:
Pool evaporation, as for screening Pool evaporation, as for worst case
Mitigation: Mitigation:
Same as for screening. Same methods for passive mitigation as for worst

case.

Active mitigation for liquid release and for release to

air discussed.

Temperature: Temperature:
Same as for screening. Same as for worst case.

For Toxic Solids
Estimate release rate based on site-specific informa None regulated.
tion.




page A-10
Green Book OCA Guidance

Reevaluation (Green Book)/Alternative Scenario Analysis (OCA Guidance)璫ont.
Flammable Substances
Not covered Methods provided for:
?Vapor cloud fires.
?Pool fires.
?BLEVEs.
?Vapor cloud explosions, based on less conservative
assumptions than the worst case.

Meteorological Conditions
D stability, wind speed 11.9 miles per hour (5.3 meters D stability, wind speed 3 meters per second.
per second) or same conditions as for screening.

Distance Tables Provided
Neutrally buoyant plume tables only: Toxics:
Rural (screening conditions and D stability, higher Neutrally buoyant plume tables:
wind speed). ?Rural - 10 minute and 60 minute.
Urban (screening conditions and D stability, higher ?Urban - 10 minute and 60 minute.
wind speed). Dense gases:
?Rural - 10 minute and 60 minute.
?Urban - 10 minute and 60 minute.
Chemical-specific tables:
?Ammonia liquefied under pressure.
?Ammonia solution.
?Chlorine.
?Sulfur dioxide.
Flammables:
Vapor cloud explosion distance table.
Vapor cloud fire distance tables:
?Neutrally buoyant plumes.
?Dense gases.
BLEVE (fireball) distance table.

Maximum Distance in Tables
10 miles 25 miles




page A-11

RMPs Are on the Way!




page A-12

APPENDIX D:
REGULATED SUBSTANCES瑿HEMICALS COVERED BY
THE RMP REGULATION AND THEIR THRESHOLD
QUANTITIES
This list is current at the time of publication of this booklet. For an up-to-date list at any time, consult EPA's CEPPO
website at www.epa.gov/ceppo.
Toxics
Regulated Substance CAS # TQ Regulated Substance CAS # TQ
Acrolein 107-02-8 5,000 Hydrogen selenide 7783-07-5 500
Acrylonitrile 107-13-1 20,000 Hydrogen sulfide 7783-06-4 10,000
Acrylyl chloride 814-68-6 5,000 Iron, pentacarbonyl 13463-40-6 2,500
Allyl alcohol 107-18-6 15,000 Isobutyronitrile 78-82-0 20,000
Allylamine 107-11-9 10,000 Isopropyl chloroformate 108-23-6 15,000
Ammonia (anhydrous) 7664-41-7 10,000 Methacrylonitrile 126-98-7 10,000
Ammonia (conc. 20% or greater) 7664-41-7 20,000 Methyl chloride 74-87-3 10,000
Arsenous trichloride 7784-34-1 15,000 Methyl chloroformate 79-22-1 5,000
Arsine 7784-42-1 1,000 Methyl hydrazine 60-34-4 15,000
Boron trichloride 10294-34-5 5,000 Methyl isocyanate 624-83-9 10,000
Boron trifluoride 7637-07-2 5,000 Methyl mercaptan 74-93-1 10,000
Boron trifluoride compound Methyl thiocyanate 556-64-9 20,000
with methyl ether (1:1) 353-42-4 15,000 Methyltrichlorosilane 75-79-6 5,000
Bromine 7726-95-6 10,000 Nickel carbonyl 13463-39-3 1,000
Carbon disulfide 75-15-0 20,000 Nitric acid (conc. 80% or greater) 7697-37-2 15,000
Chlorine 7782-50-5 2,500 Nitric oxide 10102-43-9 10,000
Chlorine dioxide 10049-04-4 1,000 Oleum (fuming sulfuric acid) 8014-95-7 10,000
Chloroform 67-66-3 20,000 Peracetic acid 79-21-0 10,000
Chloromethyl ether 542-88-1 1,000 Perchloromethyl mercaptan 594-42-3 10,000
Chloromethyl methyl ether 107-30-2 5,000 Phosgene 75-44-5 500
Crotonaldehyde 4170-30-3 20,000 Phosphine 7803-51-2 5,000
Crotonaldehyde, (E) 123-73-9 20,000 Phosphorus oxychloride 10025-87-3 5,000
Cyanogen chloride ((CN)Cl) 506-77-4 10,000 Phosphorus trichloride 7719-12-2 15,000
Cyclohexylamine 108-91-8 15,000 Piperidine 110-89-4 15,000
Diborane 19287-45-7 2,500 Propionitrile 107-12-0 10,000
Dimethyldichlorosilane 75-78-5 5,000 Propyl chloroformate 109-61-5 15,000
1,1-Dimethylhydrazine 57-14-7 15,000 Propyleneimine 75-55-8 10,000
Epichlorohydrin 106-89-8 20,000 Propylene oxide 75-56-9 10,000
Ethylenediamine 107-15-3 20,000 Sulfur dioxide (anhydrous) 7446-09-5 5,000
Ethyleneimine 151-56-4 10,000 Sulfur tetrafluoride 7783-60-0 2,500
Ethylene oxide 75-21-8 10,000 Sulfur trioxide 7446-11-9 10,000
Fluorine 7782-41-4 1,000 Tetramethyllead 75-74-1 10,000
Formaldehyde (solution) 50-00-0 15,000 Tetranitromethane 509-14-8 10,000
Furan 110-00-9 5,000 Titanium tetrachloride 7550-45-0 2,500
Hydrazine 302-01-2 15,000 Toluene 2,4-diisocyanate 584-84-9 10,000
Hydrochloric acid Toluene 2,6-diisocyanate 91-08-7 10,000
(conc. 30% or greater) 7647-01-0 15,000 Toluene diisocyanate
Hydrocyanic acid 74-90-8 2,500 (unspecified isomer) 26471-62-5 10,000
Hydrogen chloride (anhydrous) 7647-01-0 5,000 Trimethylchlorosilane 75-77-4 10,000
Hydrogen fluoride/Hydrofluoric acid Vinyl acetate monomer 108-05-4 15,000
(conc. 50% or greater) 7664-39-3 1,000
continued on next page


page A-13
RMPs Are on the Way!

Flammables
Regulated Substance CAS # TQ Regulated Substance CAS # TQ
Acetaldehyde 75-07-0 10,000 Propyne 74-99-7 10,000
Acetylene 74-86-2 10,000 Silane 7803-62-5 10,000
Bromotrifluoroethylene 598-73-2 10,000 Tetrafluoroethylene 116-14-3 10,000
1,3-Butadiene 106-99-0 10,000 Tetramethylsilane 75-76-3 10,000
Butane 106-97-8 10,000 Trichlorosilane 10025-78-2 10,000
1-Butene 106-98-9 10,000 Trifluorochloroethylene 79-38-9 10,000
2-Butene 107-01-7 10,000 Trimethylamine 75-50-3 10,000
Butene 25167-67-3 10,000 Vinyl acetylene 689-97-4 10,000
2-Butene-cis 590-18-1 10,000 Vinyl chloride 75-01-4 10,000
2-Butene-trans 624-64-6 10,000 Vinyl ethyl ether 109-92-2 10,000
Carbon oxysulfide 463-58-1 10,000 Vinyl fluoride 75-02-5 10,000
Chlorine monoxide 7791-21-1 10,000 Vinylidene chloride 75-35-4 10,000
2-Chloropropylene 557-98-2 10,000 Vinylidene fluoride 75-38-7 10,000
1-Chloropropylene 590-21-6 10,000 Vinyl methyl ether 107-25-5 10,000
Cyanogen 460-19-5 10,000
Cyclopropane 75-19-4 10,000
Dichlorosilane 4109-96-0 10,000
Difluoroethane 75-37-6 10,000
Dimethylamine 124-40-3 10,000
2,2-Dimethylpropane 463-82-1 10,000
Ethane 74-84-0 10,000
Ethyl acetylene 107-00-6 10,000
Ethylamine 75-04-7 10,000
Ethyl chloride 75-00-3 10,000
Ethylene 74-85-1 10,000
Ethyl ether 60-29-7 10,000
Ethyl mercaptan 75-08-1 10,000
Ethyl nitrite 109-95-5 10,000
Hydrogen 1333-74-0 10,000
Isobutane 75-28-5 10,000
Isopentane 78-78-4 10,000
Isoprene 78-79-5 10,000
Isopropylamine 75-31-0 10,000
Isopropyl chloride 75-29-6 10,000
Methane 74-82-8 10,000
Methylamine 74-89-5 10,000
3-Methyl-1-butene 563-45-1 10,000
2-Methyl-1-butene 563-46-2 10,000
Methyl ether 115-10-6 10,000
Methyl formate 107-31-3 10,000
2-Methylpropene 115-11-7 10,000
1,3-Pentadiene 504-60-9 10,000
Pentane 109-66-0 10,000
1-Pentene 109-67-1 10,000
2-Pentene, (E) 646-04-8 10,000
2-Pentene, (Z)- 627-20-3 10,000
Propadiene 63-49-0 10,000
Propane 74-98-6 10,000
Propylene 115-07-1 10,000



page A-14
United States Office of Solid Waste EPA 550-F-99-003
Environmental Protection and Emergency Response February 1999
Agency (5104) www.epa.gov/ceppo




PREVENT YEAR 2000 CHEMICAL
EMERGENCIES
The Environmental Protection Agency (EPA) is issuing this Alert as part of its ongoing effort
to protect human health and the environment by preventing chemical accidents. Alerts are
issued when EPA becomes aware of a significant hazard. It is important that facilities, State
Emergency Response Commissions (SERCs), Local Emergency Planning Committees
(LEPCs), emergency responders and others review this information and take appropriate
steps to minimize risk. The Alert is targeted at the chemical process industry to increase
awareness of the potential for chemical safety problems due to upcoming date changes.




THE YEAR 2000 This alert raises awareness about the Y2K
problem and offers a strategy to address the
(Y2K) PROBLEM problem. However, given that the Year
2000 is approaching soon, facilities should
dedicate increasingly more efforts on

I
t is 11:59 p.m. on December 31, 1999.
developing contingency plans to prepare
The Year 2000 problem (also known as
for unanticipated events like those above.
the --millennium bug") could disrupt
Contingency planning is especially impor-
your chemical process and storage opera-
tant for facilities that have not started or
tions. Is your facility prepared? Here are
have made little progress in assessing and
some examples of what could happen.
remediating the Y2K problem.
A safety system, designed to detect

In addition to administrative and manage-
emissions of deadly hydrogen sulfide
ment systems, (payroll, financial records,
gas, shut down during a Y2K test on an
inventory), the Y2K problem could affect
oil rig in the North Sea.
three parts of your facility - your software,
your control/process equipment, and criti-
At a smelter in New Zealand, all the

cal services provided to you by others such
process controls stopped working at mid-
as utilities and feedstock suppliers.
night on December 31, 1996, because
programmers had failed to take into
YOUR SOFTWARE
account that 1996 was a leap year. The
loss of process control damaged equip- The Y2K dilemma is the result of a stan-
ment valued approximately at $600,000. dard practice used in software program-
ming. To save memory space and keep
A utility company in Hawaii ran tests on

costs down, computer programs and
its system to see if it would be affected by
ALERT




microchips were traditionally designed to
the Y2K bug. The entire system shut
recognize only the last two digits of a year.
down.
This means that when the year 2000 rolls
around, computers may not be able to dis-
At any size company, the Y2K issue could
tinguish whether 00 means 1900 or 2000.
threaten worker and community safety and
CHEMICAL SAFETY




This could cause computer programs to
health. It could cause complete shutdowns
crash and systems to shut down. For exam-
of machinery or safety-related systems or
ple, if you rely on computer systems to
could generate erroneous information (e.g.,
notify you to schedule maintenance or
wrong temperature) which could lead an
retire equipment, the system may not prop-
operator to take unsafe or improper steps.
erly notify you because the computer can-
For chemical process industries, the Y2K
not recognize dates after December 31,
problem could increase the potential for
1999. See the --Dates to Watch" box for a
process shutdowns and accidental chemi-
few other dates that might cause problems.
cal releases.
Chemical Emergency Preparedness and Prevention Office Printed on recycled paper
February 1999
2 Prevent Year 2000 Chemical Emergencies




YOUR CONTROL/PROCESS SOME DATES TO WATCH
EQUIPMENT
Sept. 9, 1999: Many computer systems
Even if your operations do not directly use comput-
use 9/9/99 as file purge date
ers, some of your control machinery, process equip-
ment, automation equipment (e.g., valves, pumps), Jan. 1, 2000: Rollover may halt, confuse,
and emergency protection equipment (e.g., fire and or otherwise disrupt many systems and
gas detectors), may be embedded with computer devices
chips that are date-sensitive. If these chips misun-
Feb. 29, 2000: Many systems may not
derstand the date change, the equipment could fail
recognize 2000 as a leap year
or malfunction, causing process upsets that lead to
accidents. For example, an automatic valve with an Oct. 10, 2000: First time date field uses
embedded chip could fail in such a way that the maximum length
valve turns off the feedstock supply. Because Y2K
Dec. 31, 2000: Some systems may not
problems can affect so many devices, cascading
recognize the 366th day
failures are possible.

STEPS TO ADDRESS THE PROBLEM
YOUR SERVICE PROVIDERS
There are several steps you can take to identify and
The Y2K problem can affect manufacturing, elec-
address the Y2K problem. Throughout this step
tric utilities and energy suppliers, water utilities,
process, you should be sure to document what you
telecommunications, transportation, and other sec-
have done. For additional help in performing these
tors that are critical to your facility operations.
steps, you could contact an appropriate association,
Disruption of these services can become your prob-
trade group, or industry colleague for particular sug-
lem. For example, a water supply utility could shut
gestions and best practices for your industry. If you
down, causing loss of critical cooling water to
are unable to implement these steps in-house, con-
chemical reactor systems. Most plants also have
sider using an outside consultant. There is also a
suppliers that produce raw and in-process materials
wealth of information on how to follow these steps
that are vital to running their processes. Many
(See the --Information Resources" at end of Alert).
plants have customers who accept products through
--just-in-time" delivery schedules. Failure to
1. Identify and check systems for Y2K compliancy.
receive these materials could result in safety haz-
Each company should check its systems to deter-
ards at your plant.
mine if they are Y2K compliant. Make a list of the
date-dependent components of your systems that
HAZARD AWARENESS are likely to be affected by the --millennium bug."
(See box on --Examples of Equipment to Check").
AND REDUCTION Focus on software and equipment with embedded
chips, and ask yourself if your equipment or sys-
tems use or depend on date information, for exam-

T
he Y2K concern is real, and the solution may
ple, does the system order/retrieve information by
not be easy. However, the effort now to
date, or perform date-based calculations? Prioritize
identify and fix the problem will reduce the
the items on your list based on their potential for
risk of more costly impacts of business disruptions,
causing health, safety, and environmental concerns
safety failures, and accidental chemical releases.
and how critical they are to business production.
While many large companies in the chemical indus-
You should review your risk assessments or hazard
try already have started addressing the Y2K prob-
analyses (e.g., HAZOP) to be certain that Y2K vul-
lem, many small businesses are just beginning to
nerable equipment and devices are inventoried and
realize the impact that the Y2K problem may have
addressed. Starting with the most critical equip-
on their operations.
ment, check with your supplier, installer, or manu-
facturer to determine if the system component is
February 1999
3 Prevent Year 2000 Chemical Emergencies




Y2K compliant (see section on --Information EXAMPLES OF EQUIPMENT TO CHECK
Resources" for some vendor web sites).
Controllers

Alarms

2. Remedy problem. If critical equipment can be
affected by the Y2K problem, you have several Lighting

options including repairing, modifying, or replacing Robots

the equipment. Where mission-critical systems
Air monitoring/leak detection devices

cannot be assessed, remediated, and corrected, you
Hazard communication databases

could consider operating the system in a manual
Underground storage tank monitors

over-ride mode. Staff would need training on new
equipment or refresher training on procedures for Security systems

manual operation. Additional staff may be needed Generators

when automated processes are switched to manual. Lab instruments

Environmental control systems

3. Test systems. Your systems and equipment should
Controllers for refrigeration, valves,

be tested to make sure the Y2K malfunction is reme-
pumps, sensors and analyzers
died. Do not forget to test dates other than January 1,
Programmable control systems

2000 (see the --Dates to Watch" box). Before you test,
Safety shutdown systems

alert local emergency officials and make sure your
employees and community are prepared for any possi- Fire detection systems

ble failures that may have an adverse effect on health Explosion suppression systems

and safety or the environment. (See EPA`s new
Elevators

enforcement policy on Y2K testing in section --It`s Your
Conveyors

Duty").
Vehicles

4. Develop and implement contingency plans.
Contingency plans are essential in your strategy to that they, too, are addressing the Y2K issue.
address the Y2K problem. Even if you believe your Work with your SERC, LEPC, and other off-site
system is Y2K compliant, you should develop a emergency management support to review
Y2K contingency plan to prepare for unanticipated emergency response procedures and ensure that
problems. Your contingency plan should not depend the procedures and resources available cover
on backup equipment and systems that could also possible Y2K consequences.
fail because of the Y2K complication (e.g., backup
Make sure employees are trained and prepared
generator, automatic shutdown system). Also, you
may need to address staffing and training for meet- to shut down the process manually, if necessary.
ing Y2K contingency plans and to handle disrup-
Consider scheduling downtime and mainte-

tions to transportation infrastructure and telecom-
nance over the end of 1999 and beginning of
munications. Facilities should not overlook the pos-
2000. During shutdowns, systems can be iso-
sibility that non-Y2K compliant computers and
lated and Y2K tested. However, before you
chips in telecommunications and radio may prevent
schedule downtime, recognize that startups and
police, fire, and mutual aid assistance from arriving
shutdowns have their own risks which must be
promptly or at all. Inform local officials concerned
balanced against the potential risks from Y2K
with emergency situations when testing equipment,
problems. Also, if you are a large power user,
and involve employees in planning for testing and in
notify your utility if you plan to have a shut-
responding to unexpected system changes. As part
down. Utilities could have operating problems
of your contingency planning you could:
if power demands unexpectedly drop, particu-
Work with and share solutions and lessons
larly if many facilities shut down.
learned with your partners, suppliers, neighbor
Have a full staff available for a number of hours

facilities, associations, and customers to ensure
just before and after critical date changes for
February 1999
4 Prevent Year 2000 Chemical Emergencies




INFORMATION RESOURCES
unanticipated emergencies.
Consider conducting an exercise using a Y2K

scenario to improve emergency response capa-

B
elow are some resources that will help you to
bilities. One community, Lubbock, Texas, get started to address the Y2K problem at
already has successfully conducted such an your facility. Future updates of this resource
exercise and learned a number of important list can be found at the EPA CEPPO Website below.
lessons, including the need to prevent emer-
gency communications failure. Environmental Protection Agency (EPA)
Provides information on EPA`s efforts to address the Year
Remember, in terms of contingency planning, facil- 2000 problem. This includes EPA`s Y2K enforcement policy,
and under the heading --Environmental Y2K Sectors," the
ities should take advantage of the one positive piece
Office of Water guidance for wastewater systems (including a
of information that the Y2K problem offers us: the
checklist of basic systems) and the Office of Solid Waste flyer
ability to know when it will occur. on waste management and the Y2K problem.
http://www.epa.gov/year2000/
IT'S YOUR DUTY EPA`s Office of Solid Waste and Emergency Response Y2K



U
information.
nder the General Duty Clause of the Clean
Air Act (CAA section 112(r)(1)), owners and http://clu-in.com/y2k.htm
operators of facilities with hazardous sub-
EPA`s Chemical Emergency Preparedness and Prevention
stances have a general duty to prevent and mitigate
Office (CEPPO) has this Y2K alert and updates.
accidental releases, including those caused by Y2K
http://www.epa.gov/ceppo
failures. Also, under EPA`s Risk Management
Program (RMP) Rules (CAA section 112(r)(7)), acci- Occupational Safety and Health Administration (OSHA)
dental release scenarios related to Y2K problems The OSHA web site has a bulletin on Y2K.
(e.g., loss of utilities, interruption of raw material http://www.osha.gov/Y2knews.pdf
deliveries, failure of monitoring devices) would be
Chemical Safety and Hazard Investigation Board (CSB)
reasonable alternative scenarios to consider. The
The CSB has sponsored a conference and report on the Y2K
public may view any Y2K-related operating prob-
problem and the potential for accidental chemical releases.
lems that occur in January 2000 as a test of the qual- Relevant Year 2000 sites can be found on the CSB Web site by
ity and reliability of your RMP. In addition, EPA has clicking on Chem Links and then searching on --Year 2000."
initiated an enforcement policy designed to encour- http://www.chemsafety.gov
age prompt testing of computer-related equipment to
ensure that environmental compliance is not impaired U.S. Small Business Administration (SBA)
This web site offers information specific to helping small

by the Y2K computer bug. Under this policy, EPA
businesses address the Y2K problem. It provides a list of

intends to waive 100% of the civil penalties and rec- questions to help identify date-sensitive equipment. SBA also

ommend against criminal prosecution for environ- has an extensive list of links to major corporations that post

mental violations caused by tests designed to identify their Y2K status online.

and eliminate the Y2K-related malfunctions. This http://www.sba.gov/y2k/

policy is limited and subject to certain conditions. Hotline: 1-800-U-ASK-SBA (1-800-827-5722)

(See complete policy on EPA`s Year 2000 web site
General Accounting Office
listed in --Information Resources.")
Guide: --Year 2000 Computing Crisis: Business Continuity
and Contingency Planning" has general principles for use by
The Occupational Safety and Health Act (OSHA) businesses as well as government agencies.
has a similar General Duty Clause (section 5(a)(1))
http://www.gao.gov/special.pubs/bcpguide.pdf
for protection of employees from hazardous situa-
tions involving the use of highly hazardous sub- National Institute of Occupational Safety & Health (NIOSH)
stances. Also, OSHA`s Process Safety Management NIOSH has Y2K case studies, a web forum, vendor list, and
an equipment manufacturer directory.
(PSM) Standard is intended to prevent or minimize
injury to employees from accidents (including http://www.cdc.gov/niosh/y2k/y2k-hmpg.html
those caused by Y2K problems) involving highly
hazardous chemicals.
February 1999
5 Prevent Year 2000 Chemical Emergencies




Health & Safety Executive (UK) Case Study of One Chemical Manufacturer`s Approach to
The British Health and Safety Executive web site offers sev- Y2K Problem
eral reports on the Y2K problem. Of particular interest to the http://www.dell.com/smallbiz/y2k/studies.htm#merisol
chemical industry is --Health and Safety and the Year 2000
Problem - Guidance on Year 2000 Issues As They Affect American Petroleum Institute
Safety-Related Control Systems" and --Contingency Planning The site provides industry activities, company status reports,
for a Safe Year 2000." Y2K database, and technical links.
http://www.open.gov.uk/hse/dst/2000indx.htm http://www.api.org/ecity/y2k/index.html
National Fire Data Center Year 2000
A basic system check that can help you determine if your The site has a list of Year2000 vendors and consultants.
organization`s computer system is Y2K compliant is available
http://www.year2000.com
on this website.
http://www.usfa.fema.gov/y2k/y2kcom.htm National Bulletin Board for Year 2000
Provides tools for analysis, conversion, and testing for Y2K
Electronic Systems Center of the Air Force Materiel problems.
Command (site maintained by Mitre Corporation)
http://it2000.com/solutions/index.html
The site provides information on Y2K certification, compli-
ance, solutions, testing and evaluations, contingency plans,
Y2K Freeware and Shareware
cost estimation, tools and services.
http://www.aphis.usda.gov/y2k/wares.html
http://www.mitre.org/technology/y2k

Year 2000 Embedded Systems Vendors, Associations, and
National Institute of Standards and Technology
Manufacturers
The site has links to free software tests, self-help tools and
product compliance status databases for use in Y2K assess- http://ourworld.compuserve.com/homepages/roleigh_martin/y
ment, testing, contingency planning and remediation. 2k_com.htm
Information is provided for smaller manufacturers through the
Manufacturing Extension Partnership, a nationwide network Some PC Test Results for Y2K Problems
of centers providing technical and business assistance to
http://www.hqisec.army.mil/y2kweb/y2kresults.html
smaller manufacturers. Small manufacturing firms can call 1-
800-MEP-4MFG. http://www.nim.com.au/year2000/ye02001.htm
http://www.nist.gov/y2k

FOR MORE INFORMATION...
President`s Council on Year 2000 Conversion-Product
Compliance Information
The site has a list of computer manufacturers` Y2K sites. CONTACT THE EMERGENCY PLANNING AND COMMUNITY

http://www.y2k.gov/java/product_compliance.html RIGHT-TO-KNOW HOTLINE

800 424-9346 OR (703) 412-9810

Mary Kay O`Connor Process Safety Center
TDD (800) 553-7672

The site has links to compliance status of some manufactur-
ers` control systems. Click on Y2K information. MONDAY-FRIDAY, 9 AM TO 6 PM, EASTERN TIME
http://process-safety.tamu.edu/y2k/y2k.htm

TO OBTAIN COPIES OF THIS PUBLICATION, CONTACT NATIONAL
Chemical Manufacturers Association (CMA) Survey
SERVICE CENTER FOR ENVIRONMENTAL PUBLICATIONS
CMA has developed a standard survey form for the use of its
(NSCEP) PHONE: 800-490-9198 FAX: 513-489-8695
members. This survey package is designed to help companies
assess Y2K efforts of critical suppliers and customers and http://www.epa.gov/ncepihom
minimize the risk of service interruption. The survey (posted
on 12/14/98) can be found in the --What`s New" section of the VISIT THE CEPPO HOME PAGE ON THE WORLD WIDE WEB AT:
CMA website.
http://www.epa.gov/ceppo
http://www.cmahq.com




NOTICE
The statements in this document are intended solely as guidance. This document does not substitute for EPA's or other agency regula
tions, nor is it a regulation itself. Site-specific application of the guidance may vary depending on process activities, and may not apply
to a given situation. EPA may revoke, modify, or suspend this guidance in the future, as appropriate.
February 1999
6 Prevent Year 2000 Chemical Emergencies




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Washington, DC 20460

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CUSTOMER SATISFACTION SURVEY瑿EPPO PUBLICATION

RMPS ARE ON THE WAY!
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a few minutes to give us some feedback. The responses will be confidential, and the information you provide will
enable us to better meet your future needs. We at CEPPO want to be sure that we are developing the products
and providing the information you require.

Responding to this customer satisfaction survey is voluntary. Upon completion please remove the survey card
from the Guidance Document, fold, and mail to the address shown on the back of this page.

6. The sections on "opportunities" that the RMP
Language and Format
information provides for you and your LEPC to
1. Please rate the readability of the LEPC Guidance: assess and enhance preparedness and prevention
very easy to understand in your community are:
easy to understand very useful
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2. The format/layout of the LEPC guidance is:
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7a. If dissatisfied, what information would you add
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no opinion tions or need more information?
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4. What is your level of satisfaction with the
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5. What is your reaction to the descriptions of the Please provide any additional comments you may
various roles and responsibilities involved in the have about the LEPC Guidance to:
RMP program (e.g., LEPC, state, region, HQ, facilities,
Bill Finan, CEPPO (MC 5104)
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USEPA
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ATTN: Chemical Emergency Preparedness and Prevention Office
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