This is an EXCELLENT presentation from EPA (4/2013) on doing RMP Inspections @ Ethanol Facilities. Although the presentation appears to be specifically for Ethanol facilities, it’s “suggestions and tips” WILL apply to any RMP covered facility (and for PSM-covered facilities as well). Some of the interesting revelations are:
1) EPA uses Google and Bing Satellite images in their screening process for who gets inspected
2) A LATE resubmission is #1 on their list to inspect
3) If your process has a Hazard Index >25 you get extra scrutiny
4) EPA will request to see documents “referenced” such as copies of the actual RAGAGEPs that are listed in the process safety documentation
5) EPA will contact the LEPC (RMP toxics)/Fire department (RMP flammables) related to ER planning
See more below…