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  • When part of a site is sold, what facility ID number is used?

    If a site is divided up as part of a sale and part of the site is kept by the original owner and the remainder is sold or leased, what facility ID is used? The section of the site that is retained by the original owner will keep the original…

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  • Who should sign the certification statement?

    The owner or operator of a stationary source must submit in the RMP a statement certifying that the RMP is accurate and complete (40 CFR §68.185). Who should sign this certification statement? EPA has not promulgated regulations under 40 CFR Part 68 specifying who must sign the certification statement nor…

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  • Would change in population data require an RMP update?

    As part of the hazard assessment under 40 CFR Part 68, Subpart B, a source is required to estimate in its risk management plan (RMP) the population within a circle that has its center at the process and its radius equal to the distance to the endpoint concentration (40 CFR…

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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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  • 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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  • 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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  • Active mitigation systems (e.g., scrubbers) and alternative release scenarios

    I run a wastewater treatment plant that is subject to the risk management program regulations in 40 CFR Part 68 for a covered process containing chlorine. A chlorine scrubber system at the plant is designed to prevent any possible releases from reaching a toxic endpoint offsite. How does this active…

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  • Are areas occupied solely by employees considered public receptors?

    When analyzing off-site consequences for the purpose of a worst-case or alternative release scenario under the risk management program regulations (40 CFR Part 68), are areas occupied solely by employees at the source considered to be public receptors? No. Such areas at the stationary source are not to be included…

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  • Are barracks and family housing units on military bases considered public receptors?

    Barracks are not considered public receptors, family housing units are. Public receptors include any "offsite residences ... inhabited or occupied by the public at any time without restriction by the stationary source where members of the public could be exposed to toxic concentrations, radiant heat, or overpressure, as a result…

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  • Are on-site areas with unrestricted access 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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  • Definition and data sources of "environmental receptor"

    The Risk Management Program rule requires owners or operators of covered processes to define in the risk management plan (RMP) the potential offsite public and environmental receptors within the impact range of identified worst case and alternative release scenarios. What is the definition of "environmental receptor"? What data sources are…

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  • Do the quantities of interconnected vessels need to be aggregated for the worst-case release scenario analysis?

    Pursuant to the risk management program regulations, facilities must perform an offsite consequence analysis for the worst-case release scenario. Do the quantities of two separate vessels that are interconnected with a closed valve need to be aggregated for the worst-case release scenario analysis? No. Worst-case release is defined as the…

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  • Flammable event with different time duration

    What if a flammable event has a different time duration than the 5 kw/m2 for 40 seconds? EPA recognizes that flammable events may occur for a different amount of exposure time. Therefore, the owner or operator should determine the distance to an equivalent exposure - e.g. if the flammable event…

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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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