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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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  • 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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  • 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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  • 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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  • 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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  • Can I use clothes, towels, and bedding that I left behind in my structure?

    Yes. However, it is recommended the occupant launder clothes, towels and bedding as normal.

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  • Non-residential population in off-site consequence analyses

    Must an owner or operator include in their risk management plan (RMP) estimates of the non-residential population when defining off-site impacts for the off-site consequence analysis? Owners or operators are required to note in the RMP the presence of any major institutions (i.e., schools, hospitals, or prisons), public recreational areas…

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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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