RMP Facilities in the United States as of May 2005
Memorandum
June 27, 2005
TO:
Honorable Edward Markey
Attention: Michal Freedhoff
FROM:
Dana A. Shea
Analyst in Science and Technology Policy
Resources, Science, and Industry Division
SUBJECT: RMP Facilities in the United States as of May 2005
This memorandum responds to your request regarding facilities submitting Risk
Management Plans (RMPs) to the U.S. Environmental Protection Agency (EPA). You
requested an analysis of RMP facilities within the United States by potentially affected
population.
Under the Clean Air Act, Section 112(r), the EPA established a program requiring risk
management plans to be provided to the EPA by facilities possessing greater than certain
threshold quantities of 140 chemicals.1 As part of this reporting requirement, facilities are
required to determine the worst-case scenario release from a single chemical process, using
EPA criteria and guidelines.2 Facilities are also required to estimate the population
potentially at risk from this worst-case scenario release by calculating the population that
resides within a circle surrounding the facility, with the radius of the circle determined by the
distance the worst-case scenario release might travel.3
Since the population potentially affected under an EPA worst-case scenario release is
calculated in a circle around the facility, it is unlikely that this entire population would be
affected by any single chemical release, even if it is a result of a worst-case accident. In the
event of an actual catastrophic chemical release, meteorologic effects will determine the
direction of the release, and therefore those potentially affected, and effects on the health of
those individuals affected would vary, depending on many factors. In addition, worst-case
1 The list of 140 chemicals, 77 toxic chemicals and 63 flammable chemicals, and their threshold
quantities are found at 40 CFR 68.130.
2 The criteria and guidelines for determining the worst-case scenario release are found at 40 CFR
68.25.
3 This requirement is found at 40 CFR 68.30. The criteria for determining the distance a worst-case
scenario release might travel are found at 40 CFR 68.22.
Congressional Research Service Washington, D.C. 20540-7000
CRS-2
scenarios do not take into account emergency response measures that might be taken by
operators of the facilities or others to mitigate harm.
Facilities may register and deregister from the RMP program as their chemical
processes and the amounts of chemicals they store and use change. Facilities are required
to review and update the RMP plan filed with the EPA at least once every five years.4
Possible reasons that facilities might not review and update the filed RMP plan include: the
facility is out of compliance; the facility is no longer in business; the facility has reduced the
amount of reportable chemical to below threshold levels, but neglected to inform the EPA;
or the facility fell under the Chemical Safety Information, Site Security and Fuels Regulatory
Relief Act (CSISSFRA) and is no longer covered by the RMP requirement.
In 1999, Congress passed the Chemical Safety Information, Site Security and Fuels
Regulatory Relief Act.5 This act removes from coverage by the RMP program any
flammable fuel when used as fuel or held for sale as fuel by a retail facility. In implementing
this Act, the EPA allowed facilities that had previously filed under the RMP program the
options of withdrawing from the program, which would delete the information from the EPA
database, or taking no further action, which would leave the information in the EPA database
as a voluntary submission.6 As a result, some entries in the EPA database which have not
been updated within the five year requirement are likely to be facilities falling under
CSISSFRA that opted to take no action.
At your request, I searched the May 2005 update of the EPA RMP*National Database
(with off-site consequence analysis (OCA) data) for facilities that have registered under the
RMP program. Facilities that have deregistered from the RMP program were excluded. You
requested that these facilities be classified by state according to the population potentially
affected by a worst-case release, according to the EPA worst-case scenario criteria, using
thresholds of 1,000 people, 10,000 people, 100,000 people, and 1,000,000 people.
Additionally, you requested that facilities with out-dated RMP filings be identified and
subtracted from each population category. Facilities required to update their RMP filing by
April 1, 2005 that had not done so were considered out of date for the purposes of this
analysis and were excluded. Therefore, each category is described by a range of values, with
the lower value being current, compliant RMP facilities and the upper value being all
registered RMP facilities.
Facilities may register and deregister from the RMP program as chemical processes and
amounts of chemicals stored and used change. Therefore, the number of facilities listed
above should be considered as illustrative of the current industry profile, rather than absolute.
If you have any further questions regarding this topic or questions regarding the
information in this memorandum, please contact me at 7-6844.
4 This requirement is found at 40 CFR 68.36. Facilities not excluded by CSISSFRA that do not
review and update the RMP plan are not in compliance with the RMP regulation. They may be
subject to enforcement actions by EPA under the Clean Air Act, Section 113.
5 P.L. 106-40.
6 See 65 Fed. Reg. March 13, 2000, p. 13,247.
CRS-3
Table 1. Compliant and Total RMP Facilities in Each State, by
Potential Affected Population (Parameters Designated by Requester)
Compliant and Total Number of Facilities with a Worst-Case Release
Potentially Affecting a Population of:
State
0 - 999
1,000 - 9,999
10,000 - 99,999
100,000 - 999,999
1,000,000+
AK
14 - 18
10 - 11
0
0
0
AL
78 - 103
65 - 86
35 - 42
12 - 13
0
AR
49 - 59
66 - 80
44 - 51
3
0
AS
0
0
0 - 1
0
0
AZ
26 - 42
40 - 46
28 - 37
4 - 5
2
CA
274 - 339
230 - 298
258 - 294
52 - 58
11 - 13
CO
119 - 128
63 - 67
24
1
1
CT
8 - 11
19 - 24
7 - 12
1
0
DC
0
1
1
0
0
DE
11
15
4
3
2
FL
81 - 90
156 - 176
112 - 125
21 - 22
7
GA
119 - 132
134 - 143
48 - 48
7
1
GU
2 - 4
0
0
0
0
HI
5 - 6
8 - 9
2
0
0
IA
476 - 527
380 - 395
55 - 60
3
0
ID
24 - 29
23 - 25
14 - 16
0
0
IL
530 - 630
290 - 317
60 - 70
20 - 25
12 - 13
IN
213 - 265
140 - 160
50 - 62
13 - 14
3 - 4
KS
493 - 540
199 - 217
31 - 35
4 - 5
0
KY
78 - 86
74 - 81
32 - 36
16
0
LA
121 - 138
88 - 106
50 - 57
47 - 50
2
MA
22 - 27
24 - 34
22 - 27
1
1
MD
37 - 38
21 - 26
42 - 73
7
3
ME
10 - 13
12 - 14
4 - 5
1 - 2
0
MI
79 - 92
78 - 91
38 - 47
11 - 12
5
MN
193 - 281
154 - 196
45 - 54
8
3
MO
164 - 214
126 - 151
37 - 40
6 - 8
0
CRS-4
MS
49 - 54
60 - 69
42 - 45
2
0
MT
45 - 56
20 - 22
7
3
0
NC
106 - 138
90 - 108
42 - 46
7 - 8
1
ND
232 - 266
71 - 78
11
0
0
NE
303 - 339
192 - 207
35 - 36
2 - 3
0
NH
5 - 7
5 - 8
1
1
1
NJ
44 - 46
20
19 - 20
6 - 7
7
NM
40 - 46
12
6 - 7
2
0
NV
23 - 29
6 - 7
4 - 5
3 - 4
1
NY
53 - 60
66 - 70
32 - 35
15 - 16
3
OH
158 - 167
151 - 169
88 - 95
16 - 17
8
OK
158 - 214
79 - 103
23 - 25
7
0
OR
50 - 55
39 - 40
25
4
0
PA
101 - 111
144 - 159
80 - 82
16 - 18
2
PR
9 - 16
38 - 58
38 - 53
1
0
RI
1 - 5
4 - 6
6 - 7
4
0
SC
66 - 73
107 - 109
20 - 21
9
0
SD
44 - 46
29 - 32
5
0
0
TN
62 - 69
92 - 101
31 - 34
19 - 20
0
TX
466 - 598
321 - 423
260 - 311
59 - 67
28 - 29
UT
41 - 43
18 - 20
11
5
1
VA
56 - 64
67 - 70
21 - 21
9
0
VI
0
0
1
0
0
VT
2 - 4
4 - 6
0
0
0
WA
125 - 135
79 - 82
30 - 33
8
1
WI
89 - 124
94 - 116
50 - 54
6
0
WV
24 - 27
27
18 - 20
8
0
WY
53 - 57
9
3
0
0
Source: CRS analysis of the EPA RMP*National Database (with off-site consequence analysis (OCA) data),
updated May 2005.
Note: Facilities required to update their RMP filing by April 1, 2005 that had not done so were considered out
of compliance and excluded when considering the compliant facility universe. In cases where facilities report
multiple worst-case scenario releases, the worst-case scenario potentially affecting the most people has been
considered. When all facilities in a given category are compliant, only a single value is reported.