Are bulk storage terminals exempt from filing a Risk Management Plan?
There is no general exemption for bulk storage terminals. However, the threshold exemption for "regulated substances in naturally occurring hydrocarbon mixtures prior to entry into a natural gas processing plant or a petroleum refining processing unit" would exempt certain storage terminals, such as crude oil storage terminals where the regulated substances in the crude oil meet the listing criteria for flammable mixtures (i.e., NFPA 4, >1% concentration of listed flammable substance), provided the mixture has not undergone processing in a refinery. Additionally, flammable substances used as fuel or held for sale as fuel at a retail facility are not covered under the Risk Management Program. For flammable mixtures not eligible for either of these exemptions, you need to evaluate on a case-by-case basis whether they trigger the NFPA-4 and >1% criteria. Keep in mind that regulated substances in gasoline, when in distribution or related storage for use as fuel for internal combustion engines, also are exempt from threshold determination.