RMP Field Exercise Deadline
40 CFR 68.96(b)(2) requires Program 2 and Program 3 stationary sources to conduct a field exercise before March 15, 2027, then at minimum once every ten years thereafter. Both functional and full-scale exercises satisfy the requirement.
What the Rule Requires
Coordinate with local emergency response officials. Design a field exercise (functional or full-scale) appropriate to the facility emergency response program. Conduct the exercise. Document the AAR, the participant roster, the scenario design, and corrective actions.
Functional or Full-Scale
Both options satisfy 68.96(b)(2). Functional: operations-based, EOC activates, sections operate, no field deployment, lower cost. Full-Scale: boots on the ground, real evacuation, real mutual aid. Northline full-scales produce a 3D time-stamped replayable AAR.
Why Northline
Field exercises fail at multi-agency coordination and documentation. Northline is led by operators who have worked real incidents and real interop. Our full-scale AAR is a 3D time-stamped replay, not a PDF reconstructed from observer notes.