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Criteria for selecting alternative release scenarios
As part of the hazard assessment, owners and operators of Program 2 and Program 3 covered processes must identify and analyze alternative release scenarios (40 CFR §68.28). What criteria should be used when selecting an alternative release scenario? The owner or operator of a stationary source subject to the risk…
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How does EPA oversee cleanup at the derailment site?
EPA leads the Unified Command consisting of different agencies to approve Norfolk Southern’s workplans and weekly activities. EPA also coordinates with other agencies to perform oversight, such as with Ohio EPA, the Columbiana County Health District, and the Pennsylvania Department of Environmental Protection. EPA and Ohio EPA personnel oversee safety…
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What are the health agencies doing?
The Centers for Disease Control and Prevention and Agency for Toxic Substances and Disease Registry (ATSDR) are analyzing their Assessment of Chemical Exposure (ACE) survey results to assess the health impacts of the train derailment. CDC and ATSDR continue to support the Ohio and Pennsylvania health departments and will be…
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Does the distance to endpoint start at the process or stationary source boundary?
When selecting the worst-case release scenario for Program 2 and 3 processes as required by 40 CFR §68.25, a stationary source owner or operator must analyze the release scenario that results in the greatest distance to an endpoint. Does the "greatest distance to an endpoint" refer to the greatest total…
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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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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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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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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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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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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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Can I use any previous three year meteorological data for worst case scenario?
I am trying to complete my worst case release scenario for the Risk Management Plan under §68.25. I understand that I am required to use a wind speed of 1.5 m/s and F atmospheric stability class as specified in §68.22(b), unless I can prove that at no time over the…
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Now that the track is rebuilt, what else needs to be done and how long will it take?
There is still a lot of work to do. Contaminated soil to the north and south of the tracks need to be removed. A full site assessment, including extensive sampling, of areas and properties near the derailment site needs to be conducted. A full assessment of impacted creeks will be…
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If there is a government shutdown, will work continue on the cleanup?
A 45-day continuing resolution was recently passed to avoid a shutdown. EPA’s emergency response efforts, such as in East Palestine, would move forward under a lapse in appropriation. As a result, EPA personnel would continue to fully support those efforts during a lapse.
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