DRAFT

RMP PROGRAM LEVEL 2 CHECKLIST

NORTH DAKOTA DEPARTMENT OF AGRICULTURE

PESTICIDE AND FERTILIZER DIVISION

SFN 60326 (1-2013)

Facility Name

Section A: MANAGEMENT [68.15]

Management system developed and implemented as provided in 40 CFR 68.15? S M U N/A

Comments

Has the owner or operator:

Developed a management system to oversee the implementation of the risk management program elements? 

[68.15(a)]

Yes No N/A

1.

2. Assigned a qualified person or position that has the overall responsibility for the development, 

implementation, and integration of the risk management program elements? [68.15(b)]

Documented other persons responsible for implementing individual requirements of the risk management 

program and defined the lines of authority through an organization chart or similar document? [68.15(c)]

3.

Section B: HAZARD ASSESSMENT [68.20-68.42]

Hazard assessment conducted and documented as provided in 40 CFR 68.20-68.42? S M U N/A

Comments

Hazard Assessment: Offsite consequence analysis parameters [68.22]

3.

4.

5.

Used appropriate wind speeds and stability classes for the release analysis? [68.22(b)]

Used appropriate ambient temperature and humidity values for the release analysis? [68.22(c)]

Used appropriate values for the height of the release for the release analysis? [68.22(d)]

Yes No N/A

6.

7.

Used appropriate surface roughness values for release analysis? [68.22(e)]

Do tables and models, used for dispersion analysis of toxic substances, appropriately account for dense or 

neutrally buoyant gases? [68.22(f)]

Hazard Assessment: Worst-case release scenario analysis [68.25]

8.

9.

10.

Analyzed and reported in the RMP one worst-case release scenario estimated to create the greatest distance 

to an endpoint resulting from an accidental release of a regulated toxic substance from covered processes 

under worst-case conditions? [68.25(a)(2)(ii)]

Analyzed and reported in the RMP additional worst-case scenarios for a hazard class if the worst-case release 

from another covered process at the stationary source potentially affects public receptors different from those 

potentially affected by the worst-case release scenario under 68.25(a)(2)(ii)? [68.25(a)(2)(iii)]

Has the owner or operator determined the worst-case release quantity to be the greater of the following: 

[68.25(b)]

11.

Yes

Has the owner or operator of the anhydrous ammonia facility:

No N/A

Used for toxics the following endpoints for offsite consequence analysis for a worst-case scenario provided in 

Appendix A of 40 CFR Part 68

1.

2. Used for toxics the following endpoints for offsite consequence analysis for an alternative release scenario 

[68.22(a)] provided in Appendix A of 40 CFR Part 68

If released from a vessel, the greatest amount held in a single vessel, taking into account administrative 

controls the limit the maximum quantity?

If released from a pipe, the greatest amount held in the pipe, taking into account administrative controls 

that limit the maximum quantity? 

Assumed the whole quantity in the vessel or pipe would be release as a gas over 10 minutes? [68.25(c)(1)]

Assumed the release rate to be the total quantity divided by 10, if there are no passive mitigation systems 

in place? [68.25(c)(1)]

12. Used the parameters defined in 68.22 to determine distance to the endpoints? [68.25(g)]
DRAFT

SFN 60326 (1-2013)

Page 2 of 6

13. Determined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis 

Guidance, any other publicly available techniques that account for the modeling conditions and are recognized 

by industry as applicable as part of current practices, or propriety models that account for the modeling 

conditions may be used provided the owner or operator allows the implementing agency access to the model 

and describes model features and differences from publicly available models to local emergency planners 

upon request? [68.25(g)]

Yes No N/A

What modeling technique did the owner or operator use? [68.25(g)]

14. Ensured that the passive mitigation system, if considered, is capable of withstanding the release event triggering 

the scenario and still function as intended? [68.25(h)]

15. Considered also the following factors in selecting the worst-case release scenario: [68.25(i)]

Smaller quantities handled at higher process temperature or pressure?

Proximity to the boundary of the stationary source?

16.

17.

Hazard Assessment: Alternative release scenario analysis [68.28]

Identified and analyzed at least one alternative release scenario for each stationary source in a covered 

process (es)? [68.28(a)]

Yes No

Selected a scenario: [68.28(b)]

N/A

That is more likely to occur than the worst-case scenario under 68.25? 

That will reach an endpoint off-site, unless no such scenario exists?

18. Considered release scenarios which included, but are not limited to, the following: [68.28(b)(2)]

Transfer hose release due to splits or sudden hose uncoupling?

Process piping releases from failures at flanges, joints, welds, valves and valve seals, and drains or bleeds?

Process vessel or pump releases due to cracks, seal failure, or drain, bleed, or plug failure?

Vessel overfilling and spill, or over pressurization and venting through relief valves or rupture disks?

Shipping container mishandling and breakage or puncturing leading to a spill?

19. Used the parameters defined in 68.22 to determine distance to the endpoints? [68.28(c)]

20. Determined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis 

Guidance, any other publicly available techniques that account for the modeling conditions and are recognized 

by industry as applicable as part of current practices, or proprietary models that account for the modeling 

conditions may be used provided the owner or operator allows the implementing agency access to the model 

and describes model features and differences from publicly available models to local emergency planners 

upon request? [68.28(c)]

What modeling technique did the owner or operator use? [68.25(g)]

21. Ensured that the passive and active mitigation systems, if considered, are capable of withstanding the release 

event triggering the scenario and will be functional? [68.28(d)]

22. Considered the following factors in selecting the alternative release scenarios: [68.28(e)]

The five-year accident history provided in 68.42? 

Failure scenarios identified under 68.50?

23.

Hazard Assessment: Defining off-site impacts-Population [68.30]

Estimated population that would be included in the distance to the endpoint in the RMP based on a circle with 

the point of release at the center? [68.30(a)]

Yes No N/A

24. Identified the presence of institutions, parks and recreational areas, major commercial, office, and industrial 

buildings in the RMP? [68.30(b)]

25. Used the most recent Census data, or other updated information to estimate the population? [68.30(c)]

26. Estimated the population to two significant digits? [68.30(d)]

27.

Hazard Assessment: Defining off-site impacts-Environment [68.33]

Identified environmental receptors that would be included in the distance to the endpoint based on a circle with 

the point of release at the center? [68.33(a)]

28.

Yes

Relied on information provided on local U.S.G.S. maps, or on any data source containing U.S.G.S. data to 

identify environmental receptors? [68.33(b)]

No N/A
DRAFT

Hazard Assessment: Review and update [68.36]

29. Reviewed and updated the off-site consequence analyses at least once every five years? [68.36(a)]

Yes

30. Completed a revised analysis and submit a revised RMP within six months of a change in processes, 

quantities stored or handled, or any other aspect that might reasonably be expected to increase or decrease 

the distance to the endpoint by a factor of two or more? [68.36(b)]

No N/A

SFN 60326 (1-2013)

Page 3 of 6

31.

Hazard Assessment: Documentation [68.39]

For worst case scenarios: a description of the vessel or pipeline and substance selected, assumption and 

parameters used, the rationale for selection, and anticipated effect of the administrative controls and passives 

mitigation on the release quantity and rate? [68.39(a)]

Yes

32.

No

For alternative release scenarios: a description of the scenarios identified, assumption and parameters used, 

the rationale of specific scenarios, and anticipated effect of the administrative controls and mitigation on the 

release quantity and rate? [68.39(b)]

N/A

33. Documentation of estimated quantity released, release rate, and duration of release? [68.39(c)]

34. Methodology used to determine distance to endpoints? [68.39(d)]

35. Data used to estimate population and environmental receptors potentially affected? [68.39(e)]

Hazard Assessment: Five-year accident history [68.42] Yes No

36. Has the owner or operator included all accidental releases from covered processes that resulted in deaths, 

injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in 

place, property damage, or environmental damage? [68.42(a)]

N/A

37. Has the owner or operator reported the following information for each accidental release: [68.42(b)]

Date, time, and approximate duration of the release?

Chemical(s) released?

Estimated quantity release in pounds?

NAICS code for the process?

The type of release event and its source?

Weather conditions (if known)?

On-site impacts?

Known offsite impacts?

Initiating event and contributing factors (if known)?

Whether offsite responders were notified?

Operational or process changes that resulted from investigation of the release? 

Section C: PREVENTION PROGRAM

Implemented the Program 2 prevention requirements as provided in 40 CFR 68.48-68.60? S M U N/A

Comments

1.

Prevention Program- Safety information [68.48]

Compiled and maintained the following up-to-date safety information, related to the regulated substances, 

processes, and equipment: [68.48(a)]

Yes No N/A

Material Safety Data Sheets (MSDS) that meet the requirements of the OSHA Hazard Communication 

Standard [29 CFR 1910.1200(g)]?

Maximum intended inventory of equipment in which the regulated substances are stored or processed?

Safe upper and lower temperature, pressure, flows, and compositions?

Equipment specifications?

Codes and standards used to design, build, and operate the process?

2. Ensured the process is designed in compliance with recognized and generally accepted good engineering 

practices? [68.48(b)]

3. Updated information if a major change occurred that made the information inaccurate?
DRAFT

4.

Prevention Program- Hazard review [68.50]

Has the owner or operator conducted a review of the hazards associated with the regulated substances, 

processes, and procedures? [68.50(a)]

Yes No N/A

The hazards associated with the process and regulated substances?

SFN 60326 (1-2013)

Page 4 of 6

5. Did the review identify:

Opportunities for equipment malfunctions or human errors that could cause an accidental release?

The safeguards used or needed to control the hazards or prevent equipment malfunctions or human error?

Any steps used or needed to detect or monitor releases?

6. Determined by inspecting all equipment that the processes are designed, fabricated, and operated in 

accordance with applicable standards or rules, if designed to meet industry standards or Federal or State 

design rules? [68.50(b)]

7. Documented the results of the review? [68.50(c)]

8. Ensured that problems identified were resolved in a timely manner? [68.50(c)]

9.

10.

Updated the review at least once every five years or whenever a major change in the processes occurred? 

[68.50(d)]

Resolved all issues identified in the review before startup of the changed process? [68.50(d)]

Prevention Program- Operating procedures [68.52]

11.

Yes No

Has the owner or operator prepared written operating procedures that provide clear instructions or steps for 

safely conducting activities associated with each covered process consistent with the safety information for 

that process? (Operating procedures may be provided by equipment manufacturers or by persons or 

organizations with knowledge about the process) [68.52(a)]

N/A

12. Do the procedures address the following: [68.52(b)]

Initial startup?

Normal operations?

Temporary operations?

Emergency shutdown and operations?

Normal shutdown?

Startup following a normal or emergency shutdown or a major change that requires a hazard review?

Consequences of deviations and steps required to correct or avoid deviations?

Equipment inspections?

13. Has the owner or operator ensured that the operating procedures have been updated, if necessary, whenever 

a major change occurred and prior to startup of the changed process? [68.52(c)]

Prevention Program- Training [68.54]

Certified that each employee presently operating a process, and each employee newly assigned to a covered 

process have been trained or tested competent in the operating procedures provided in 68.52 that pertain to 

their duties? [68.54(a)]

14.

Yes No N/A

15. Provided refresher training at least every three years, or more often if necessary, to each employee operating a 

process, to ensure that the employee understands and adheres to the current operating procedures of the 

process? [68.54(b)]

16. Determined, in consultation with the employees operating the process, the appropriate frequency of refresher 

training? [68.54(b)]

17. Certified that each employee was trained in any updated or new procedures prior to startup of a process after 

a major change? [68.54(d)]

18.

Prevention Program- Maintenance [68.56]

19.

20.

Prepared and implemented procedures to maintain the on-going mechanical integrity of the process 

equipment? [68.56(a)]

Trained or caused to be trained each employee, involved in maintaining the on-going mechanical integrity of 

the process, in the hazards of the process, in how to avoid or correct unsafe conditions, and in the procedures 

applicable to the employees job tasks? [68.56(b)]

Has every maintenance contractor ensured that each contract maintenance employee is trained to perform the 

maintenance procedures developed? [68.56(c)]

21. Has the owner or operator performed or caused to be performed inspections and tests on process equipment 

that follow recognized and generally accepted engineering practices? [68.56(d)]

Yes No N/A
DRAFT

SFN 60326 (1-2013)

Page 5 of 6

Prevention Program- Compliance audits [68.58] Yes No

22. Has the owner or operator certified that compliance audits are conducted at least every three years to verify 

that the procedures and practices are adequate and are being followed? [68.58(a)]

N/A

23. Has compliance audits been conducted by at least one person knowledgeable in the process? [68.58(b)]

24. Has the owner or operator developed a report of the audits findings? [68.58(c)]

25. Has the owner or operator promptly determined and documented an appropriate response to each of the 

findings of the audit and documented that deficiencies has been corrected? [68.58(d)]

26. Has the owner or operator retained the two most recent compliance audit reports, unless more than five years 

old? [68.58(e)]

Prevention Program- Incident investigation [68.60] Yes No

27. Has the owner or operator investigated each incident that resulted in, or could reasonably have resulted in a 

catastrophic release? [68.60(a)]

28. Were all incident investigations initiated not later than 48 hours following the incident? [68.60(b)]

N/A

29. Was a summary prepared at the conclusion of every investigation, which included: [68.60(c)]

Date of incident?

Date investigation began?

A description of incident?

The factors that contributed to the incident?

Any recommendations resulting from the investigation?

30. Has the owner or operator promptly addressed the resolved the investigation findings and recommendations, 

and are the resolutions and correct actions documented? [68.60(d)]

Has the owner or operator reviewed the finding with all affected personnel whose jobs tasks are affected by the 

findings? [68.60(e)]

31.

32. Has the owner or operator retained investigation summaries for five years? [68.60(f)]

Section D: EMERGENCY RESPONSE [68.90-68.95]

Developed and implemented an emergency response program as provided in 40 CFR 

68.90-68.95? S M U N/A

Comments

Yes No N/A

1. Is the facility designated as a “first responder” in case of an accidental release of regulated substances?

2. If the facility is not a first responder:

For stationary sources with any regulated substance held in a process above threshold quantities, is the 

source included in the community emergency plan developed under 42 U.S.C. 11003? [68.90(b)(1)]

Are appropriate mechanisms in place to notify emergency responders when there is need for a response? 

[68.90(b)(3)]

3. An emergency response plan is maintained at the stationary source and contains the following? [68.95(a)(1)]

Procedures for informing the public and local emergency response agencies about accidental releases?

Documentation of proper first-aid and emergency medical treatment necessary to treat accidental 

human exposures? 

Procedures and measures for emergency response after an accidental release of regulated substance?

4. The emergency response plan contains procedures for the use of emergency response equipment and for its 

inspection, testing, and maintenance? [68.95(a)(2)]

The emergency response plan requires, and there is documentation of, training all employees in relevant 

procedures? [68.95(a)(3)]

5.

6. The owner or operator has developed and implemented procedures to review and update, as appropriate, the 

emergency response plan to reflect changes at the stationary source and ensure that employees are informed 

of changes? [68.95(a)(4)]

7. Did the owner or operator use a written plan that complies with other Federal contingency plan regulations or is 

consistent with the approach in the National Response Teams Integrated Plan Guidance? If so, does the plan 

include the elements provided in paragraph (a) of 68.95, and also complies with paragraph (c) of 68.95? [68.95

(b)]

8. Has the emergency response plan been coordinated with the community emergency response plan developed 

under EPCRA? [68.95(c)]
DRAFT

Yes No

1.

N/A

Does the single registration form include, for each covered process, the name and CAS number of each 

regulated substance held above the threshold quantity in the process, the maximum quantity of each regulated 

substance or mixture in the process (in pounds) to two significant digits, the five or six digit NAICS code that 

most closely corresponds to the process and the Program Level of the process? [68.160(b)(7)]

2. Has the owner or operator reviewed and updated the RMP and submitted it to EPA? [68.190(a)] Reason for 

update:

Five-year update.

SFN 60326 (1-2013)

Page 6 of 6

Section E: RISK MANAGEMENT PLAN [40 CFR 68.190-68.195]

Within three years of newly regulated substance listing.

At the time a new substance is first present in an already regulated process above threshold quantities.

At the time a regulated substance is first present in a new process above threshold quantities.

Within six months of a change requiring PHA or hazard review.

Within six months of a change requiring OCA as provided in 68.36.

Within six months of a change that alters the Program Level that applies to any covered process.

If the owner or operator experience and accidental release that met the five-year accident history reporting 

criteria (68.42) subsequent to April 9, 2004, did the owner or operator submit the information required at 

68.168, 68.170(j) and 68.175(l) within six months of the release or by the time the RMP was updated as 

required at 68.190, whichever was earlier. [68.195(a)]

3.

4. If the emergency contact information required (68.160(b)(6) has changed since June 21, 2004, did the owner 

or operator submit corrected information within thirty days of the change? [68.195(b)]