Learn the Issues
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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)…
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Distance to endpoint calculations used by RMP*Comp
Does RMP*Comp perform some math or modelling in order to arrive at an endpoint distance, or is it simply interpolating from the tables in the EPA's Offsite Consequence Analysis Guidance (OCA Guidance)? RMP*Comp follows the procedures set out in the OCA Guidance . This means that for some scenarios, the…
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Worst-case release scenarios for salt domes
Would all of the regulated substances stored in a salt dome be assumed to be released in the worst-case scenario? The worst case scenario for salt domes would be examined in a manner similar to that for underground storage tanks. Reservoirs or vessels sufficiently buried underground are passively mitigated or…
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Worst-case release scenarios with gases liquified by refrigeration
When evaluating the worst-case release scenario for spills of liquid toxic substances, the owner or operator should assume that the maximum quantity within the vessel or pipe was released instantaneously to form a liquid pool (40 CFR §68.25(d)(1)). For regulated toxic substances that are normally gases at ambient temperature, the…
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Using meteorological station data for off-site consequence analyses
For the purpose of the offsite consequence analyses required under 40 CFR Part 68, Subpart B, there are several instances in which data gathered at a local meteorological station may be used to establish the modeling parameters of wind speed, atmospheric stability, temperature, and humidity for the stationary source. How…
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Quantity of a regulated substance in an aqueous solution
When using RMP*Comp to conduct an offsite consequence analysis (OCA), a facility must specify the quantity released. What quantity should be entered for a regulated toxic substance in an aqueous solution, the total quantity of the aqueous solution or just the quantity of the toxic substance? The entire quantity of…
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Release scenarios for substances exhibiting flammability and toxicity
Under the hazard assessment requirements in 40 CFR Part 68, Subpart B, an owner or operator must analyze worst-case release scenarios and more likely alternative release scenarios, and must document a five-year accident history. If a regulated substance exhibits characteristics of both toxicity and flammability, should owners and operators consider…
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No trespassing signs restricted access onsite or offsite public receptor
The definition of public receptor is "offsite residences, institutions (e.g., schools, hospitals), industrial, commercial, and office buildings, parks, or recreational areas inhabited or occupied by the public at any time without restriction by the stationary source ..." Offsite is further defined to include "areas within the property boundary [of the…
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Must I anticipate a specific cause for the worst-case scenario for a toxic substance?
When analyzing the worst-case scenario for regulated toxic substances, must I anticipate a specific cause (e.g., fire, explosion, etc.) of the scenario? No. The worst-case analysis for a release of regulated toxic substances must conform to specific assumptions as identified in § 68.25(c) and (d). Anticipated causes of the release…
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Identifying public receptors and property with restricted access
Does public receptor cover only buildings on a property or the entire property? If the owner of the land next to my site restricts access to the land, is it still a public receptor? Public receptors are not limited to buildings. For example, if there are houses near your property…