112(r) Risk Management Program
US EPA has published the Section 112(r) RMP rule change and it has been posted in the Federal Register. The compliance date for ALL facilities is June 21, 2004.
- For those of you who are required to file a five-year update, your submission must be post-marked no later than June 21, 2004 (if your anniversary date is on or before June 21, 2004).
- All other RMP facilities are required to file an update for the NEW added data elements as prescribed by US EPA no later that June 21, 2004.
- For facilities with an anniversary date after June 21, 2004, you must submit at minimum the new data elements by June 21, 2004. The anniversary date applies to the five-year update requirements only.
You will find reporting software (RMP*Submit 2004 for the five-year update that includes new data elements), general information, Questions and Answers, plus reporting instructions at: http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/RMPsubmission.htm#Re-submitting
RMP*Submit 2004 SOFTWARE
How do I download and install RMP*Submit 2004?
Either go to the below website and scroll ¼ way down the page: http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/ap-rmsb.htm
OR:
Download the RMP*Submit installation file rmpsubmit.exe to your hard disk. This is a small file that will initiate further downloads to complete the installation. Save this file to your hard drive, and run it. This install process will download only the files that are needed for your computer. If your computer already has some of the necessary files, the download/install process will be quicker. If you have a slow internet connection, it may take several hours for the download process to complete, as there are a total of 46 MB to download. If your internet connection is interrupted, re-establish the connection, and run rmpsubmit.exe again. It will pick up the download/install process where it left off.
As an alternative, there is a single file installer (46 MB) that you can download and run to install the system.
Also download or print the RMP*Submit 2004 User's Manual and Appendices.
After you install the program, import your 1999 data and update, or type in the current information.
ERROR MESSAGE
Most of you that import data from a previous submission or a diskette that we provided as part of our compliance assistance seminars will receive a Latitude / Longitude error message when import is complete. This is not an error with the data import process. It indicates a conversion of Latitude & Longitude from degrees to decimal.
DATA ELEMENTS
There are new critical data elements in Section 1 - Registration Information, dealing with accuracy of the reported Latitude & Longitude. They are:
- Item # 1.5 k - Horizontal Accuracy Measure
- Item # 1.5 l - Horizontal Reference Datum Code
- Item # 1.5 m - Source Map Scale Number (If you use map or photo interpolation)
If the information for the above entries is readily available enter what you understand and/or can easily find. If you have any doubt or the required information is not readily available use the following default entries.
- Item # 1.5 m - Enter 1
- Item # 1.5 k - Enter 1
- Item # 1.5 l - Enter the first choice from the drop-down box - 001
NOTE: Be sure you download and use the RMP*Submit 2004 version of the software.
SUBMISSIONS
After your submission is updated/complete, submit your completed RMP on diskette to EPA (Do NOT send a copy to the State of Georgia EPD) by using the instructions in Chapter 5 of the User Manual.
Send them to:
Risk Management Plan (RMP) Reporting Center
P.O. Box 1515
Lanham-Seabrook, Maryland 20703-1515
For courier and fedex packages, the address is:
Risk Management Plan (RMP) Reporting Center c/o CSC
Suite 300
8400 Corporate Drive
New Carrollton, MD 20785
IMPORTANT REMINDERS
- Don't forget the certification letter. Of the RMPs received, many were incomplete simply because a certification letter was not attached. A certification letter is REQUIRED for all RMP submissions. See Chapter 3, Section F of the RMP*Submit User's Manual for more information about the certification letter.
- Protect your diskettes against damage. We've also received a handful of damaged disks that could not be processed. Please put some padding around your diskette - or use a cardboard diskette mailer.
- Make sure your Executive Summary is in ASCII DOS Text format and that it is actually on the diskette being submitted. If your Executive Summary is too long to fit in the text box (more than 32 KB), you will need to save it as a text file and identify the name of the text file in RMP*Submit. If you developed your Executive Summary in Word or Word Perfect or some other word processing program, you MUST SAVE THE FILE IN ASCII TEXT. To save in ASCII: choose "SAVE AS..." and choose ASCII DOS Text, or Text (MS-DOS) format as the File Type. Make sure this file is then saved to the diskette you will submit to EPA and the file name is indicated in the RMP Executive Summary section. Your best bet is to save it in the text box within RMP*Submit - as long as it will fit - so that no converting will be necessary. You can do this by "cutting and pasting" from your word processor.
- If you submit graphics, make sure they are identified in the RMP with a specific worst case or alternative release scenario and that they are actually stored on the diskette being submitted.
- If you submit in paper, be sure to use the official form. If you do not use the official form, your RMP will not be processed.
Facilities not filing a five-year update are required to submit an update for the new data elements. EPA is developing on-line software for transfer of update information. This is for updates to information within the registration information only, (i.e., company name, telephone number, emergency contact information). A letter describing the process is scheduled to be mailed from EPA in late May 2004. If you do not receive this letter (and this is not the year you must resubmit), please contact EPA's reporting center for further information.
QUESTIONS?
If you have further questions, or need assistance, you may call 404-656-6905, or write Georgia Environmental Protection Division, Risk Management Program, 7 MLK Jr. Drive-Room 643, Atlanta, Georgia 30334. We can also be reached at the following e-mail addresses.
Kent Howell, Program Manager Kent_Howell@mail.dnr.state.ga.us
Christina Walls, Environmental Specialist Christina_Walls@mail.dnr.state.ga.us
Christina Butler, Environmental Specialist Christina_Butler@mail.dnr.state.ga.us
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