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  • CFAT Impacts on EPCRA and RMP

    The Department of Homeland Security’s Chemical Facility Anti-Terrorism Standards (CFATS) impose comprehensive federal security regulations for high-risk chemical facilities. Do the CFATS alter the requirements that apply to a facility covered under both CFATS and either the Emergency Planning and Community Right-to-Know Act (EPCRA) or the Clean Air Act section…

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  • EPCRA Reporting Mechanisms for Protecting Sensitive Business Information

    Does EPCRA provide any mechanisms for facilities that must submit Tier II inventory information to protect sensitive business information? Trade secret and confidential location information (CLI) are two separate confidentiality provisions under EPCRA. Trade secret claims made under EPCRA Sections 303, 311, 312, or 313 allow facilities to claim the…

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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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  • 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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  • 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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  • 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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  • Do I have to report accidents that resulted in medical treatment?

    I had a release where several people were treated at the hospital and released; they attributed their symptoms to exposure. We do not believe that their symptoms were in fact the result of exposure to the released substance. Do we have to report these as offsite impacts? Yes, you should…

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  • Are landfills covered under Title III of SARA since they are covered by RCRA?

    Yes, landfills are subject to certain Title III requirements. Subtitle A of Title III is intended to identify facilities which present a potential hazard for a chemical emergency and to provide a process for local emergency planning committees to engage with such facilities in determining the significance of the release…

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  • Are mobile boosters eligible for the transportation exemption?

    An oil company owns many wells on an oil field. Each well is on its own plot of land. These plots are not adjacent or contiguous and, therefore, each well is its own facility. When operating these wells, it is sometimes necessary to inject air or gas into the well…

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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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  • When does the accident history's five-year period begin?

    The hazard assessment requirements under 40 CFR Part 68, Subpart B include provision of a five-year accident history, as specified at §68.42. When does the five-year period to be reported in the accident history begin? The five-year accident history must include information on all accidental releases from covered processes meeting…

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  • What is the definition of injury?

    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, evacuations, sheltering in place, property…

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  • Do Program Level 1 processes need to do five-year accident histories?

    What is the relationship between the accident history criteria for Program 1 and the five-year accident history? If my process is eligible for Program 1, do I still need to do a five-year accident history? The five-year accident history is an information collection requirement that is designed to provide data…

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  • Pipeline tanks and the transportation exemption in Title III

    An oil corporation's pipeline facility contains three kinds of tanks. One type is a breakout tank used to receive and store hazardous liquids transported by a pipeline for reinjection and continued transportation by the corporation's pipeline. Another type is used to receive and store hazardous liquid for delivery to pipelines…

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  • Chemicals in facility pipelines and the EPCRA transportation exemption

    Section 327 of the Emergency Planning and Community Right-to-Know Act (EPCRA) exempts from any Title III reporting requirement (other than the §304 notification obligation) substances or chemicals in transportation and/or being stored incident to transportation. In a final rule promulgated April 22, 1987 ( 52 FR 13378 ), the Agency…

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