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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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Redoing calculations if RMP*Comp is updated
Will RMP*Comp be updated? If so, would I have to redo calculations I might already have made with an earlier version? No, you do not have to redo your work if you have already completed your consequence analyses. RMP*Comp is based on the EPA's Offsite Consequence Analysis Guidance (OCA Guidance)…
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Different distances to toxic endpoints with different versions of RMP*Comp
I've noticed that for certain chemicals, RMP*Comp gives substantially different distances to the toxic endpoint than previous versions. Why? In the current version of RMP*Comp, we have incorporated new chemical-specific distance tables for ammonia, chlorine, and sulfur dioxide. The generic tables are still used for other chemicals (you can see…
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Distance to endpoint calculations used by RMP*Comp
Does RMP*Comp perform some math or modelling in order to arrive at an endpoint distance, or is it simply interpolating from the tables in the EPA's Offsite Consequence Analysis Guidance (OCA Guidance)? RMP*Comp follows the procedures set out in the OCA Guidance . This means that for some scenarios, the…
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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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Is it required that the professional engineer conducting the engineering review must be licensed in the state in which the renewable fuel facility is located?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The licensed professional engineer should comply with the state laws where the renewable fuel facility is located to determine whether or not their license allows them to conduct business in that state.
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I have not seen a reference to the EPA CDX system. Is the CDX system already established or can we submit reports in our choice of electronic formats?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The Central Data Exchange (CDX) is an established portal through which electronic data are submitted. All registered parties will have to first register with CDX in order to receive a CDX registration number. More information may be found…
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May I generate RINs that I produced and sold for non-road use in the past so that I can reinstate those RINs under RFS2?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.1426(c)(2) provides that RINs are assigned to a volume of renewable fuel when ownership of the RIN is transferred along with ownership of the volume of renewable fuel. A comparable provision appear in the RFS1 regulations, at…
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Do I have to register to use CDX and is this a separate registration process?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . You will have to register with CDX. (Registering with CDX is not the same as registering under regulation Section 80.1150.) Instructions are available via our Reporting for Fuel Programs web site. Question and Answer was originally posted at…
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How will the volume of corn ethanol produced above the grandfathering threshold be treated?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . For grandfathered facilities, only the baseline volumes are exempt from the 20 percent GHG reduction requirement Thus, RINs may be generated for baseline volumes of fuel regardless of lifecycle greenhouse gas emissions performance. Volumes of fuel produced above…
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