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  • Double wall tanks and "passive mitigation"

    Performance of the hazard assessment required under 40 CFR Part 68, Subpart B, includes analysis of both worst-case release scenarios (40 CFR §68.25) and alternative release scenarios (40 CFR §68.28). In each of these analyses, passive mitigation systems may be taken into consideration. If a tank has a "double wall,"…

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  • How must an owner estimate the population when defining off-site impacts?

    How must an owner or operator estimate the population when defining off-site impacts as part of the facility’s risk management plan (RMP)? The owner or operator must estimate the residential population within a circle with its center at the point of the release and a radius determined by the distance…

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

    At my facility, if the worst-case release scenarios for regulated toxic substances and the worst-case scenario for regulated flammable substances involve the same process, must I analyze both? Yes. If the worst-case release scenarios for regulated toxic substances and regulated flammable substances in Program 2 and 3 processes are associated…

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  • Are roads 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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  • Does "consider off-site consequences" mean perform an environmental impact assessment?

    What does EPA mean by “consider offsite consequences”? Do we have to do an environmental impact assessment (EIA)? EPA does not expect you to do an EIA. Potential consequences to the public and the environment are already analyzed in the offsite consequence analysis. In the PHA, EPA only expects you…

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  • Are wetlands included in the definition of "environmental receptors"?

    No. EPA has defined environmental receptors as natural or state parks, forests, or monuments; officially designated wildlife sanctuaries, preserves, refuges, or areas; and Federal wilderness areas, that are easily identified on local U.S. Geological survey maps (40 CFR §68.3). Therefore, wetlands would not be reported in the hazard assessment under…

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  • Does a product or substance have to create a sheen to be subject to SPCC?

    The SPCC general applicability in 40 CFR §112.1(b) refers to a discharge of oil in quantities that may be harmful, as described in Part 110. Part 110 is often referred to as the sheen rule. Does a product or substance have to create a sheen to be subject to SPCC…

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  • Who is regulated by the SPCC Rule?

    Before a facility is subject to the SPCC Rule, it must meet three criteria: 1) it must be non-transportation-related; 2) it must have an aggregate aboveground storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons; and 3) there must be a reasonable expectation…

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  • Oil-filled equipment capacity less than 55 gallons

    Do the revised SPCC requirements apply to electrical substations that have transformers larger than 55 gallons and a total storage of 1,320 gallons? An owner/operator must prepare an SPCC Plan if the facility, due to its location could reasonable be expected to discharge oil into or upon a navigable water…

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  • Worst-case Scenario for Flammable Mixtures

    For the risk management program, where the concentration of the regulated flammable substance in the mixture is one percent or more by weight of the mixture, the entire weight of the mixture must be applied toward the 10,000 pound threshold quantity for the flammable substance unless the owner or operator…

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  • Do quantities in co-located vessels have to be aggregated for worst-case release scenarios?

    Pursuant to the risk management program (RMP) regulations, a facility owner or operator must conduct an off-site consequence analysis that includes modeling of a worst-case release. If a single process is comprised of several co-located vessels, must the total quantity in all the vessels be aggregated to determine the worst-case…

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  • For toxic endpoints, are milligrams per liter (mg / L) equivalent to parts per million (ppm)?

    The endpoint concentrations for regulated toxic substances under the risk management program rule (40 CFR Part 68 Appendix A) are listed in units of milligrams per liter (mg/L). Is this equivalent to parts per million (ppm)? No, mg/L is not always equivalent to ppm. Whereas ppm is a volume-to-volume or…

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  • Are all milk farms and milk producers exempt from the SPCC Rule?

    The exemption is for all milk and milk product containers, piping and appurtenances, but does not exempt containers that store other oils, such as petroleum oil at dairies, milk producers and milk product manufacturing facilities. These facilities will not have to account for, or address the exempt milk and milk…

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  • What does "relief system design basis" mean?

    Relief systems include, but are not limited to, relief valves, relief headers, relief drums, and rupture disks. Design basis means documenting how the loads and sizes of the relief system, as well as inlet and outlet sizes, were determined. This includes a description of overpressure scenarios considered, the scenario that…

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  • What milk and milk products are covered by the Milk and Milk Product Containers, Associated Piping and Appurtenances Exemption?

    The exemption will cover all containers, piping and appurtenances of milk and milk products. For example, milk products include cheeses, yogurts and ice cream. Additionally, transfers and milk handling associated with these containers and appurtenances are exempt from the SPCC requirements.

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