EPA can improve its program management and oversight to better assure that facilities covered by the Clean Air Act’s Risk Management Program submit or re-submit an RMP. EPA had not established national procedures for identifying covered facilities that had not submitted RMPs. For the 5 States reviewed, we identified 48 facilities in 3 States that reported large amounts of covered chemicals stored on-site that had not filed RMPs. These facilities are potential RMP non-filers. For example, 10 such facilities reported having over 100,000 pounds of ammonia on-site at one time, which is 10 times greater than the regulatory threshold. Further, the status of nearly one-third (452 of 1,516) of the facilities EPA identified in 2005 as being past their due date for re-submitting an RMP had not been resolved and updated in the RMP National Database as of March 2008. Also, State permitting agencies did not properly include program requirements as a condition of facilities’ Title V operating permits. When properly administered, the Title V process can help ensure that covered facilities submit RMPs to EPA and comply with program requirements.
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