Learn the Issues
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Are Mechanical Controls Considered Administrative Controls?
For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity…
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Administrative controls considered when determining worst-case release quantity
For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity…
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Worst-case release from smaller process with larger distance to endpoint
The owner or operator of a stationary source covered by the risk management program regulations must conduct a worst-case release scenario analysis as part of the required hazard assessment (40 CFR §68.25). The worst-case release is defined as the release of the largest quantity of a regulated substance from a…
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Underground storage tank off-site impacts to groundwater, drinking water, or soil
For the worst-case and alternative release scenarios of an underground storage tank, should I consider any impact on groundwater, drinking water, or soil? No. As part of the worst-case and alternative release scenarios, you need to define the offsite impacts to the environment (40 CFR §68.33) by listing the environmental…
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RMP Contractor Related Requirements
Facilities subject to the Program 3 Prevention Program requirements in 40 CFR Part 68 must include in their Risk Management Plan the date of the most recent review or revision of contractor safety procedures in Section 7.14 and the date of the most recent review or revision of contractor safety…
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How did EPA select the list of regulated substances?
The list of regulated substances under the chemical accident prevention provisions is found in 40 CFR Part 68. How did EPA select the substances to be included in this list? The chemical accident prevention provisions promulgated pursuant to Section 112(r) of the Clean Air Act (CAA) are designed to focus…
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What is the content of Part 68, Subpart F and when was it promulgated?
The regulatory text of the June 20, 1996, Risk Management Program Rule ( 61 FR 31668 ) does not include Subpart F. What is the content of Subpart F and when was it promulgated? Subpart F of 40 CFR Part 68 consists of the regulations concerning the list of regulated…
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How are thresholds for regulated toxic substances in mixtures determined?
Formaldehyde is listed as a regulated substance under 40 CFR 68.130 with the qualifier "(solution)." When determining whether a threshold amount of this substance exists in a process, should a person consider the weight of the entire solution, or simply the amount of formaldehyde in the solution? How are thresholds…
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Why are industries exempt under OSHA's PSM subject to RMP?
The Program 3 prevention program requirements under 40 CFR Part 68 are almost identical to the requirements of OSHA's process safety management (PSM) standard. OSHA exempts certain industries from the PSM standard. Why does EPA not exempt those same industries from the CAA §112(r) risk management program requirements? EPA and…
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What if the quantity in the process fluctuates?
What if the quantity in the process fluctuates? I may not have a threshold quantity now, but I will intermittently exceed the threshold quantity. You do not need to comply with the rule and file an RMP unless you have more than threshold quantity in a process; however, once you…
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Program 1 Five-year Accident History and Hazard Assessment Differences
Pursuant to the risk management program regulations under 40 CFR §68.10(b), Program 1 eligibility requires that the process has not had an accidental release of a regulated substance that led to off-site death, injury, or response and restoration activities at an environmental receptor within five years prior to the risk…
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Differences in accident history between Program 1 eligibility and the hazard assessment
Program 1 eligibility under 40 CFR §68.10(b) is contingent upon the process not having had an accidental release of a regulated substance that led to offsite death, injury, or response and restoration activities at an environmental receptor within five years prior to the risk management plan submission. Additionally, as part…
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Five-Year Accident History for Non-Gas Releases
Pursuant to 40 CFR §68.42(a), the owner or operator of a stationary source subject to the risk management program regulations must document significant accidental releases of regulated substances from a covered process in the five years prior to the submission of an initial or updated risk management plan (RMP). For…
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What is the definition of "offsite property damage?"
I am working on the five-year accident history portion of the hazard assessment under the RMP. Section 68.42(a) tells me to include "all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage…
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Accidental releases from non-covered processes
Should the owner or operator include accidental releases from processes containing listed substances below the threshold quantity in the five-year accident history required under the hazard assessment provisions of 40 CFR Part 68, Subpart B, and in the incident investigation requirements under 40 CFR Part 68, Subparts C and D…
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Local meteorological data for alternative release scenarios
For alternate release scenarios, RMP*Comp uses set values for meteorological conditions like humidity, wind speed, temperature, stability class, and so on. Is there a way to change those values? I want to use meteorology data from my own location. RMP*Comp indeed uses fixed values for certain atmospheric parameters, and does…
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Minimum and Maximum Distance to Endpoint
The Chemical Accident Prevention Provisions require the completion of a worst-case release scenario analysis (40 CFR §68.25). This analysis includes estimating the greatest distance to endpoint as defined by the parameters in §68.22. Is there a required minimum or maximum distance for the distance to endpoint in the worst case…
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RMP*Comp and emergency response
Can I use RMP*Comp for emergency response? No. It's a planning tool. Many other tools are available for response, including ALOHA . You can learn more by reading CAMEO tools for RMP .
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Different distances to toxic endpoints with different versions of RMP*Comp
I've noticed that for certain chemicals, RMP*Comp gives substantially different distances to the toxic endpoint than previous versions. Why? In the current version of RMP*Comp, we have incorporated new chemical-specific distance tables for ammonia, chlorine, and sulfur dioxide. The generic tables are still used for other chemicals (you can see…
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Redoing calculations if RMP*Comp is updated
Will RMP*Comp be updated? If so, would I have to redo calculations I might already have made with an earlier version? No, you do not have to redo your work if you have already completed your consequence analyses. RMP*Comp is based on the EPA's Offsite Consequence Analysis Guidance (OCA Guidance)…