Will risk management plan (RMP) submissions be subject to audits? If so, who will conduct the audits?
Yes. According to 40 CFR §68.220(a), the implementing agency will periodically audit RMPs in order to review their adequacy, and may require revisions of RMPs as necessary to ensure compliance. The implementing agency is the state or local agency that obtains delegation for an accidental release prevention program under 40 CFR Part 63, Subpart E. If no state or local agency is granted delegation, EPA will be the implementing agency (40 CFR §68.3).