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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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  • Change of owner and RMP facility ID number

    If a facility is sold to a new owner, does it keep its' original RMP Facility ID number? Yes. The facility will keep the ID number assigned by EPA.

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  • Facility ID number and re-registering a facility

    If a facility deregisters, then reregisters, should the facility use the original RMP Facility ID or will it be assigned a new ID? The facility should use the original ID assigned by EPA.

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  • Resubmission of RMP for a facility that previously deregistered

    A covered facility deregisters its RMP because it no longer has more than a threshold quantity of a regulated substance in a covered process. If the facility becomes subject to the CAA §112(r) risk management program regulations at a later date and submits a new RMP, should the facility submit…

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  • RMP Records Maintained Onsite

    Pursuant to 40 CFR Part 68, Subpart G, the owner or operator of a stationary source subject to the risk management program regulations in Part 68 must develop and submit a risk management plan (RMP). Does the owner or operator have to maintain a written copy of the RMP on…

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  • Underground Storage Tanks in SPCC Plans

    If a gas station that has less than 42,000 gallons completely buried oil storage capacity and no aboveground oil storage capacity installs a new aboveground tank with a capacity greater than 1,320 gallons, must the facility’s Spill Prevention, Control, and Countermeasure (SPCC) Plan address the underground storage tanks (USTs) in…

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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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  • Container capacity less than 55 gallons

    Do facilities need to consider containers that are less than 55 gallons for applicability under 40 CFR Part 112? No. The third column of page 47066 of the July 17, 2002 Preamble states that "You need only count containers of 55 gallons or greater in the calculation of the regulatory…

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  • Oil-filled equipment capacity

    When counting against the 1,320 aboveground storage capacity threshold, would operational storage of oil (such as in a hydraulic press) be used? Oil which is contained in equipment is required to be factored into the storage capacity for the facility even though the oil may be only used for ancillary…

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  • If your farm does not have fuel storage that will flow into US waters by a ditch, river, stream, or lake, do you have to prepare a SPCC Plan?

    No. EPA suggests you use a common sense approach. If one of your oil storage tanks leaks, and the spilled oil would not flow into navigable waters or adjoining shorelines, you do not have to prepare a Plan. Remember that you still have the responsibility to clean up any spilled…

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