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  • Worst case release scenario for toxic and flammable substances in same Program 1 process

    Under the risk management program regulations in 40 CFR Part 68, if a Program 1 process contains a threshold amount of both a regulated toxic substance and a regulated flammable substance, should a worst case release scenario be analyzed for each of the substances in the process? Yes, a worst…

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  • Definition of off-site for identifying public receptors

    My processes are fenced, but my offices and parking lot for customers are not restricted. What is considered offsite? What is considered a public receptor? The unrestricted areas would be considered offsite. However, they would not be public receptors because you are responsible for the safety of those who work…

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  • What measures qualify as "passive mitigation"?

    Passive mitigation is defined in § 68.3 as "equipment, devices, or technologies that function without human, mechanical, or other energy input." Passive mitigation systems include building enclosures, dikes, and containment walls. Measures such as fire sprinkler systems, water curtains, valves, scrubbers, or flares would not be considered passive mitigation because…

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  • What do I need to submit to EPA if I have an oil discharge?

    The owner/operator must provide the following: Name and location of the facility Owner/operator name Maximum storage/handling capacity of the facility and normal daily throughput Corrective actions and countermeasures taken, including descriptions of equipment repairs and replacements Adequate description of the facility, including maps, flow diagrams, and topographical maps, as necessary…

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  • What information do I need to report for an oil discharge?

    The National Response Center (NRC) will ask a caller to provide as much information about the incident as possible including: • Name, organization, and telephone number • Name and address of the party responsible for the incident • Date and time of the incident • Location of the incident •…

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  • Ammonia (concentration 20% or greater) and Ammonia (anhydrous) Alternative Release Scenarios

    Pursuant to the Risk Management Program regulations, the owner or operator shall identify and analyze at least one alternative release scenario for each regulated toxic substance held in a Program 2 or Program 3 process above its threshold (40 CFR §68.28). If a facility has both ammonia and ammonia (anhydrous)…

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  • Are rivers used for recreation considered "public receptors"?

    A process covered under 40 CFR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed in 40 CFR §68.10(b). One of those criteria is that the distance to a toxic or flammable endpoint for a worst-case release assessment is less than the distance…

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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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  • Do environmental receptors include areas that are not Federal Class I areas?

    Do environmental receptors include areas that are not Federal Class I areas under the CAA? Yes. The list of environmental receptors in Part 68 includes areas in addition to those that qualify as Federal Class I areas under CAA section 162. Under Part 68, national parks, monuments, wilderness areas, and…

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  • Double wall tanks and "passive mitigation"

    Performance of the hazard assessment required under 40 CFR Part 68, Subpart B, includes analysis of both worst-case release scenarios (40 CFR §68.25) and alternative release scenarios (40 CFR §68.28). In each of these analyses, passive mitigation systems may be taken into consideration. If a tank has a "double wall,"…

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  • How must an owner estimate the population when defining off-site impacts?

    How must an owner or operator estimate the population when defining off-site impacts as part of the facility’s risk management plan (RMP)? The owner or operator must estimate the residential population within a circle with its center at the point of the release and a radius determined by the distance…

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

    At my facility, if the worst-case release scenarios for regulated toxic substances and the worst-case scenario for regulated flammable substances involve the same process, must I analyze both? Yes. If the worst-case release scenarios for regulated toxic substances and regulated flammable substances in Program 2 and 3 processes are associated…

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  • Are roads considered public receptors?

    A process covered under 40 CFR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed at 40 CFR §68.10(b). One of those criteria is that the distance to a toxic or flammable endpoint for a worst-case release assessment is less than the distance…

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  • Does "consider off-site consequences" mean perform an environmental impact assessment?

    What does EPA mean by “consider offsite consequences”? Do we have to do an environmental impact assessment (EIA)? EPA does not expect you to do an EIA. Potential consequences to the public and the environment are already analyzed in the offsite consequence analysis. In the PHA, EPA only expects you…

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  • Are wetlands included in the definition of "environmental receptors"?

    No. EPA has defined environmental receptors as natural or state parks, forests, or monuments; officially designated wildlife sanctuaries, preserves, refuges, or areas; and Federal wilderness areas, that are easily identified on local U.S. Geological survey maps (40 CFR §68.3). Therefore, wetlands would not be reported in the hazard assessment under…

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