Inclusion of release scenarios in executive summary
Do I have to include a description of my worst-case and alternative release scenario in my executive summary? I'm concerned that the description contains sensitive information, which if included in the executive summary will be available to the public without restriction.
No, facilities are not required to include a description of their worst-case and alternative release scenarios in the executive summary of their RMP. Although section 68.155 of the RMP rule as originally drafted required sources to briefly describe in their RMP executive summary "the worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario," EPA, along with federal law enforcement agencies, now believes that due to its sensitive nature, this information should no longer be included in executive summaries. Therefore, this requirement has been removed from the rule (69 FR 18819, April 2004).