What kinds of changes were made to the RMP General Guidance?
A. The April, 2004 General Guidance incorporates the latest rule changes (accident history, uncontrolled chemical reaction language, RMP updates and corrections); adds new Q&As to address these issues; modifies the examples that relied on fuel use; and adds some new examples. The Guidance also incorporates updates for the appendices (NAICS codes, technical assistance) and current information on how to obtain Census data, Landview, USGS maps, and RMP*Submit 2004. The Guidance also clarifies several issues. For example, the section that used to be titled “Requirements are Performance-Based” is now titled “Flexible Nature of Requirements.” We added language in the compliance audit section to inform facilities that we expect facility operators to be familiar with implementing the prevention program described in the facility’s RMP. And, in chapter 9 (RMP submission chapter), we emphasize the importance of evaluating the recurring prevention program requirements. A pending change is to incor
