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  • PHA revisions to consider offsite consequences

    If I need to revise a PHA to consider off-site consequences, when do I have to do that? In general, for a PHA originally completed to meet the requirements of OSHA PSM that did not consider offsite consequences, you should revise the PHA to consider offsite consequences when you update that PHA. Any

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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 substances, threshold quantities

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  • Do I need to report releases for processes that have shut down?

    A process involving a regulated substance had an accidental release with off-site consequences two years ago. The process has been shut down. Do I have to report anyway? No. The release does not have to be reported in your accident history. Your Risk Management Plan only needs to address operating

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  • Is the off-site death of livestock considered environmental damage?

    Under the hazard assessment requirements of 40 CFR Part 68, Subpart B, an owner or operator must document a five-year accident history including all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries

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  • What constitutes "significant property damage on site?"

    Under the hazard assessment requirements at 40 CFR Part 68, Subpart B, the owner or operator of a covered stationary source must document a five-year accident history that includes all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on

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  • What level of off-site property damage triggers five-year accident history reporting?

    What level of off-site property damage triggers reporting? Any level of known offsite property damage triggers inclusion of the accident in the five-year accident history. You are not required to conduct a survey to determine if such damage occurred, but if you know, or could reasonably be expected

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  • Acid aerosol reducing additive as passive mitigation

    A refinery uses a special proprietary additive to their hydrofluoric acid (HF) alkylation process. This HF additive has shown in tests to significantly reduce aerosol forms of HF during accidental releases, and therefore reduce the distance traveled by HF releases. The additive is present at all

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  • Air dispersion models for release scenarios

    Under the hazard assessment requirements of 40 CFR Part 68, Subpart B, an owner or operator is required to analyze a worst-case release scenario and more likely alternative release scenarios. Has EPA developed any air dispersion models for conducting these evaluations? Is EPA's TScreen model an

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  • Air dispersion models and accounting for multiple vessels

    Must air dispersion models that are used to analyze worst-case release scenarios under 40 CFR §68.25 be able to account for multiple vessels and how those vessels could impact one another in the event of an accidental release? No. Models used for worst-case release scenario analysis do not need to

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  • Are valves in piping considered administrative controls?

    No, administrative controls are written procedures that limit the quantity stored or flowing through the pipes. Valves are considered active mitigation systems.

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  • Calculating release rates and quantities for alternative release scenarios

    I am working on the alternative release scenario portion of my risk management plan (RMP), as required by 40 CFR §68.28. Specifically, I am trying to calculate my release rate and release quantity values. The final rule does not specify exactly how to calculate these values for the alternative

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  • Can positive buoyancy models be used?

    Yes, provided there is a basis for use and the owner or operator explains the rationale for use of positive buoyancy models.

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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

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  • Why were ERPG-2 values selected as toxic endpoints instead of ERPG-3?

    An endpoint is needed for analysis of offsite consequences of potential accidental releases of regulated substances. The endpoint to be used for each regulated toxic substance is provided in Part 68, Appendix A, and is the Emergency Response Planning Guideline level 2 (ERPG-2) developed for the

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  • Worst-case release scenarios for toxics and flammables in same process

    The owner or operator of a stationary source subject to the risk management program regulations must analyze the worst-case release scenario involving a Program 2 or 3 process containing a regulated flammable substance and the worst-case release scenario involving a Program 2 or 3 process containing

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