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  • How do I determine if my farm could reasonably discharge oil into or upon navigable waters or adjoining shorelines?

    You can determine this by considering the geography and location of your farm relative to nearby navigable waters (such as streams, creeks and other waterways). You should consider if ditches, gullies, storm sewers or other drainage systems may transport an oil spill to nearby streams. Estimate the volume of oil…

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  • Mixture with oil as an additive (e.g., oil-based paint)

    SPCC applicability thresholds for aboveground and completely buried oil storage capacities are established in 40 CFR §112.1(d)(2). If a facility has a tank that contains a mixture with oil as an additive, such as oil-based paint, should the entire mixture be counted towards a facility’s threshold capacity? Yes; if a…

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  • Do service tanks on service trucks or pickups count in the calculation of the total storage on the farm?

    Yes, you should include fuel tanks mounted on trailers, fuel trucks used exclusively on the farm and tanks in pickups toward the overall threshold of 1,320 gallons. Also, count 55-gallon drums, but don’t count any container smaller than that.

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  • Is my farm covered by SPCC?

    For updated information on the WRRDA changes to farm applicability see the new farm fact sheet (PDF) .

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  • Identification of Industrial Buildings, Commercial Buildings, and Recreational Areas

    Pursuant to the hazard assessment requirements in 40 CFR Part 68, Subpart B, an owner or operator is required to conduct an offsite consequence analysis and analyze a worst-case release scenario and alternative release scenarios as part of a risk management plan (RMP). When completing these scenarios, public receptors need…

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  • Why were ERPG-2 values selected as toxic endpoints instead of ERPG-3?

    An endpoint is needed for analysis of offsite consequences of potential accidental releases of regulated substances. The endpoint to be used for each regulated toxic substance is provided in Part 68, Appendix A, and is the Emergency Response Planning Guideline level 2 (ERPG-2) developed for the substance by the American…

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  • Release scenarios for substances exhibiting flammability and toxicity

    Under the hazard assessment requirements in 40 CFR Part 68, Subpart B, an owner or operator must analyze worst-case release scenarios and more likely alternative release scenarios, and must document a five-year accident history. If a regulated substance exhibits characteristics of both toxicity and flammability, should owners and operators consider…

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  • Worst-case “quantity released” reporting for a mixture

    In section 2, element 2.5, of an RMP, facilities must report the quantity of toxic chemical that the facility used for the worst-case analysis. When reporting this data element in RMP*eSubmit for a mixture, should facilities report the entire weight of the toxic mixture potentially being released or only the…

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  • Worst-case release scenarios for salt domes

    Would all of the regulated substances stored in a salt dome be assumed to be released in the worst-case scenario? The worst case scenario for salt domes would be examined in a manner similar to that for underground storage tanks. Reservoirs or vessels sufficiently buried underground are passively mitigated or…

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  • Air dispersion models for release scenarios

    Under the hazard assessment requirements of 40 CFR Part 68, Subpart B, an owner or operator is required to analyze a worst-case release scenario and more likely alternative release scenarios. Has EPA developed any air dispersion models for conducting these evaluations? Is EPA's TScreen model an appropriate technique? EPA has…

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  • Worst-case release scenarios for toxics and flammables in same process

    The owner or operator of a stationary source subject to the risk management program regulations must analyze the worst-case release scenario involving a Program 2 or 3 process containing a regulated flammable substance and the worst-case release scenario involving a Program 2 or 3 process containing a regulated toxic substance…

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  • Air dispersion models and accounting for multiple vessels

    Must air dispersion models that are used to analyze worst-case release scenarios under 40 CFR §68.25 be able to account for multiple vessels and how those vessels could impact one another in the event of an accidental release? No. Models used for worst-case release scenario analysis do not need to…

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  • Calculating release rates and quantities for alternative release scenarios

    I am working on the alternative release scenario portion of my risk management plan (RMP), as required by 40 CFR §68.28. Specifically, I am trying to calculate my release rate and release quantity values. The final rule does not specify exactly how to calculate these values for the alternative release…

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  • Acid aerosol reducing additive as passive mitigation

    A refinery uses a special proprietary additive to their hydrofluoric acid (HF) alkylation process. This HF additive has shown in tests to significantly reduce aerosol forms of HF during accidental releases, and therefore reduce the distance traveled by HF releases. The additive is present at all times during the alkylation…

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  • Can positive buoyancy models be used?

    Yes, provided there is a basis for use and the owner or operator explains the rationale for use of positive buoyancy models.

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