In section 2, element 2.5, of an RMP, facilities must report the quantity of toxic chemical that the facility used for the worst-case analysis. When reporting this data element in RMP*eSubmit for a mixture, should facilities report the entire weight of the toxic mixture potentially being released or only the amount of the regulated toxic substance in the mixture?

When reporting “Quantity Released” in section 2, element 2.5, of RMP*eSubmit, facilities are only required to include the amount of the regulated toxic substance in the mixture. This determination is consistent with the method for determining whether a threshold has been exceeded for a toxic substance in a mixture, whereby facilities need only consider the weight of the toxic substance in the mixture.

For additional information on quantifying toxic substances in mixtures, please see the Risk Management Program Guidance for Offsite Consequence Analysis (EPA 550-B-99-009) document located at:

https://19january2021snapshot.epa.gov/rmp/guidance-facilities-risk-management-programs-rmp#OCA