I recently came across a client who for whatever reasons had two (2) Risk Management Plans submitted for the same group of buildings, structures, equipment, installations and substance emitting stationary activities which belong to the same industrial group, which are located on one contiguous property, which are under the control of the same person (or persons under common control), and from which an accidental release may occur.
The wording above is NOT mine, but how EPA defines the term “facility”. So the client rightfully wanted to reduce their paperwork burden and when I suggested consolidating the two (2) plans into a single plan with a single renewal date they were all for it. So this is how we did it…