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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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  • What does "control of the same person" mean?

    Control of the same person refers to corporate control, not site management. If two divisions of a corporation operate at the same site, even if each operation is managed separately, they will count as one source provided the other criteria are met because they are under control of the same…

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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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  • 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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  • When to Revise OCA

    The risk management program in 40 CFR Part 68 requires facilities to conduct an off-site consequence analysis (OCA) to provide information to state, local, and federal governments and the public about the potential consequences of an accidental chemical release. When does a facility need to revise its OCA? The owner…

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  • No trespassing signs restricted access onsite or offsite public receptor

    The definition of public receptor is "offsite residences, institutions (e.g., schools, hospitals), industrial, commercial, and office buildings, parks, or recreational areas inhabited or occupied by the public at any time without restriction by the stationary source ..." Offsite is further defined to include "areas within the property boundary [of the…

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  • How are thresholds for regulated toxic substances in mixtures determined?

    Formaldehyde is listed as a regulated substance under 40 CFR 68.130 with the qualifier "(solution)." When determining whether a threshold amount of this substance exists in a process, should a person consider the weight of the entire solution, or simply the amount of formaldehyde in the solution? How are thresholds…

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  • Quantity of a regulated substance in an aqueous solution

    When using RMP*Comp to conduct an offsite consequence analysis (OCA), a facility must specify the quantity released. What quantity should be entered for a regulated toxic substance in an aqueous solution, the total quantity of the aqueous solution or just the quantity of the toxic substance? The entire quantity of…

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  • Must I anticipate a specific cause for the worst-case scenario for a toxic substance?

    When analyzing the worst-case scenario for regulated toxic substances, must I anticipate a specific cause (e.g., fire, explosion, etc.) of the scenario? No. The worst-case analysis for a release of regulated toxic substances must conform to specific assumptions as identified in § 68.25(c) and (d). Anticipated causes of the release…

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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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  • 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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  • Worst-case Release Scenario for Separate, Interconnected Vessels

    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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  • If a facility changes owners and significant changes have been made to plant operations is the facility required to update all sections of the RMP and resubmit it to EPA?

    Yes. If the facility has new ownership and plant operations have changed significantly, the new facility owner/operator needs to do a resubmission. For details on how to resubmit, see the Web page for RMP*eSubmit .

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  • Worst-case release scenarios for toxics and flammables represented by Program 2 or 3 processes

    A stationary source subject to the risk management program regulations at 40 CFR Part 68 comprises multiple Program 2 and Program 3 covered processes. The owner or operator must do a single worst-case release analysis to represent toxic regulated substances and a single worst-case release analysis to represent flammable regulated…

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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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