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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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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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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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Secondary containment for oil-filled operation equipment under SPCC
On December 26, 2006, EPA provided an optional alternative to the general secondary containment requirements in 40 CFR §112.7(c) for qualified oil-filled operational equipment ( 71 FR 77266 ). Because the alternative is optional, an owner or operator could choose to comply with the existing SPCC requirements to provide general…
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How long will it take?
The expectation is for cleaning to take less than one day. The duration will be dependent on the size of the structure and the scope of work.
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Do I need to leave my structure during the cleaning?
While it is strongly recommended that you leave the property during the cleaning, you are not required to do so.
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What about cleaning basements or attics?
Basements or attics will be considered for cleaning if they are finished and habitable areas.
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How many worst-case release scenarios must be analyzed and documented in the RMP?
As a part of the hazard assessment requirements in 40 CFR Part 68, Subpart B, I must analyze worst-case release scenarios and document certain analyses in my risk management plan (RMP). How many worst-case release scenarios must be analyzed, and how many analyses must be specifically documented in the RMP…
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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…
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