Risk Management Plan Data Elements

              RISK MANAGEMENT PLAN DATA ELEMENTS
The owner or operator of a stationary source subject to the risk management program rule shall
submit a single Risk Management Plan (RMP) that includes the information required in §§ 68.155
through 68.185 for all covered processes. A covered process is defined as a process that has a regulated
substance present in more than a threshold quantity as determined under § 68.115 of the rule. The
following elements should be submitted to EPA as specified in § 68.150.
EXECUTIVE SUMMARY: As specified in §68.155, the owner or operator must provide an executive
summary in the RMP. The executive summary should be brief and concise, no more than four pages in
length for sources with one or two regulated substances. Your executive summary should include
descriptions of:
1. The accidental release prevention and emergency response policies at the stationary source.
2. The stationary source and regulated substances handled. This information may be presented in a
paragraph or as bullets. The information should include the following:
C Primary activities (e.g., manufacturer of polyethylene, pulp mill, chlorine wholesaler);
C Use of regulated substances (e.g., chlorine used to produce bleach, treat wastewater,
repackage for sale);
C Quantities handled or stored.
3. The worst-case release scenario(s) and the alternative release scenario(s), including
administrative controls and mitigation measures to limit the distances for each reported scenario.
The information should include the following:
C The scenario (e.g., failure of the storage tank containing 40,000 pounds of chlorine,
storage quantity limited to 60 percent of tank's capacity by company procedures; 10
minute release);
C Distance to endpoint (e.g., under worst-case weather, the substance could travel x miles
before dispersing enough to no longer pose a hazard to the public).
4. The general accidental release prevention program and chemical-specific prevention steps. For
example, you may state that you are in compliance with the OSHA PSM rule and this rule. You
may want to highlight general or specific steps that you believe are key to your prevention
program. These steps may be either technological (e.g., backup systems) or
procedural/managerial (e.g., improved maintenance or training).
5. The five-year accident history. This should be a summary (e.g., we have had five accidental
releases of chlorine in the past five years; the largest release was 1500 pounds. No one offsite
was injured, but several houses were evacuated as a precautionary measure during the 10/25/95
and 5/1/96 releases). Do not present the information in a table format.