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Frequently Asked Questions about the TCPA Program
1. What is a Risk Management Plan?
Risk management plans (RMPs) are designed to protect the community around a site by preventing catastrophic accidental releases of the most hazardous substances used in industrial processes. The RMP includes many common-sense provisions that are part of accepted engineering practice: standard operating procedures, safety reviews, preventative maintenance, operator training, accident investigation, risk assessment, emergency response, and management of change. The RMP is a written plan that summarizes the implementation of the risk management program and contains elements such as an executive summary, registration information, an off-site consequence analysis, the five-year accident history, prevention program information, emergency response program information, a certification, information on persons involved with the risk management program, a profile of the neighborhood, insurance carrier data, and characterization of the EHS inventory.
2. Who must prepare a Risk Management Plan?
Owners and operators of stationary sources that use, store, manufacture or handle threshold quantities of EHS's are required to prepare and submit RMP's for their covered processes. Threshold quantities are listed in the TCPA regulation, available from our download page.
3. How do I submit a Risk Management Plan?
Copies of risk management plans should be submitted to the USEPA and the NJDEP's Bureau of Release Prevention. The USEPA has developed a computer program called RMP*Submit that assists in this process. Owners and operators input data about their facility into the RMP*Submit program, and necessary calculations are automatically performed. Results are then loaded onto a diskette for submission. The RMP*Submit program can be downloaded from the USEPA Chemical Emergency Preparedness and Prevention Office using the link on our TCPA Links web page. New Jersey also requires additional registration information, and there is a special New Jersey RMP*Submit program that prepares the extra data. The New Jersey RMP*Submit program can be downloaded from the TCPA Downloads web page. The two computer programs work together, and both are needed to complete the registration process.
4. Questions About Specific Situations
Q – I have a newer PC, and the New Jersey RMP*Submit program will not install. How do I proceed?
A – The New Jersey RMP*Submit program is not compatible with certain new computers. The software still installs and runs on older computers, however. If you are completely unable to use the NJ RMP*Submit program, contact TCPA program staff and discuss your situation. Staff may instruct you to download the paper version of the supplemental information form and submit that. Only use this option after consulting with TCPA program staff.Q – I have a storage area of shipping containers. Each container holds more than the threshold quantity of an extraordinarily hazardous substance (EHS). A single container is removed from storage and connected to process equipment where the EHS is consumed. Am I allowed to consider the storage area and the process equipment to be a single covered process?
A – Yes, but only if the two areas together meet USEPA’s definition of a covered process. Under USEPA’s definition of "process," separated vessels at two locations may be one process if regulated substances could be released at both locations during a single release event, including an event that is external to both vessels. The owner/operator should be able to document the basis for the decision that individual vessels at separate locations do or do not constitute a single process.Q – If a container holding a threshold quantity is moved from a covered process storage area to process equipment where it is consumed, is the EHS counted as inventory in both processes?
A – Yes, N.J.A.C. 7:31 requires registration based on the maximum quantity of the EHS present at each covered process.Q – How should an owner/operator with a covered process that qualifies for Program 1 status under the federal program register that process with DEP and EPA?
A – Since New Jersey did not incorporate Program 1 requirements into the TCPA rule, the owner/operator must submit two versions of the RMP for this covered process: one to EPA claiming Program 1 status and a second to DEP claiming Program 2 or Program 3 status in accordance with the criteria for determining program status specified at 40 CFR68.10(d).Q – My facility has substances that fall into three categories:
Substances that are regulated by the USEPA but not by TCPA, for example components of liquefied petroleum gas such as propane;
Substances that are not regulated by USEPA but are regulated by TCPA, for example because the New Jersey threshold is lower; and
Substances that are regulated by both USEPA and TCPA.
How do I register with the USEPA and the New Jersey Department of Environmental Protection?
A – You must submit two risk management plans: One plan for USEPA for all federally regulated substances, and a second plan for the New Jersey DEP for those substances regulated by TCPA.Additional information is available from the USEPA Chemical Emergency Preparedness and Prevention Office. You can access their web site from our TCPA Links page.
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