Could a fire in my “covered process” that did not cause a release trigger two (2) RMP requirements?

I have asked for an official interpretation on this question, but until that arrives I will answer this question as I did for a client this week.  Here is the scenario:

There is a significant fire in the RMP covered.  The fire does NOT cause a release of the EHS, much less get off-site. 

However, out of an abundance of caution, the local emergency response agency (Police, Fire, Sherriff, EMA Director) decides, against your input, to issue a shelter-in-place order for several residences.  Or let’s say they ask a single homeowner to evacuate their home for an hour until “we are certain it’s safe”…

Do this fire event trigger the following:

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