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• Criteria for selecting alternative release scenarios

  As part of the hazard assessment, owners and operators of Program 2 and Program 3 covered processes must identify and analyze alternative release scenarios (40 CFR §68.28). What criteria should be used when selecting an alternative release scenario? The owner or operator of a stationary source subject to the risk…

  • Last published: March 12, 2024

• If an Asbestos Hazard Emergency Response Act (AHERA) accredited-training course is taught by someone other than instructors certified by the state or the Environmental Protection Agency (EPA), can an approved contractor/instructor sign certificates?

  No. An EPA Asbestos Hazard Emergency Response Act (AHERA) accredited training course must be taught by EPA/state approved instructors and only those approved instructors may issue AHERA approved training course certificates. Other Frequent Questions about Asbestos Learn About Asbestos Asbestos and School Buildings Information for Owners and Managers of Buildings…

  • Last published: May 1, 2024

• Is there a formal requirement that an Asbestos Model Accreditation Plan (MAP) asbestos training course must have a training manual?

  Accredited trainers are not required to have a formal training manual, per se. According to the Asbestos Model Accreditation Plan (MAP), at Unit III, (A)(3), (A)(4)(d) and (A)(5) of appendix C to 40 CFR part 763, subpart E, a trainer’s application for course approval must include the course curriculum, a…

  • Last published: May 14, 2024

• 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…

  • Last published: May 22, 2024

• 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…

  • Last published: May 22, 2024

• 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…

  • Last published: May 22, 2024

• 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…

  • Last published: May 22, 2024

• 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…

  • Last published: May 22, 2024

• 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…

  • Last published: May 22, 2024

• What are the requirements under the Asbestos Hazard Emergency Response Act (AHERA) for refresher training for a person who wants to "step down" his/her certification from contractor/supervisor status to worker status?

  If such a person takes contractor/supervisor refresher courses on an annual basis, that person may perform in both the contractor/supervisor and worker roles. If, however, the person chooses only to take annual worker refresher courses, that person may continue to act in the role of an accredited worker but loses…

  • Last published: May 24, 2024

• What is the applicability of Federal asbestos inspector accreditation requirements under the Asbestos Hazard Emergency Response Act (AHERA) to real estate appraisers?

  Real estate appraisers may not assess the suspected presence, location, or condition of asbestos in a school building or a public and commercial building during an appraisal unless they are accredited pursuant to the Toxic Substances Control Act (TSCA) and the Asbestos Model Accreditation Plan (MAP), as conducting an examination…

  • Last published: May 24, 2024

• When would a conflict of interest exist among Asbestos Model Accreditation Plan (MAP)-accredited personnel?

  A conflict of interest with respect to Asbestos Model Accreditation Plan (MAP)-accredited personnel would exist if, for example, the management planner and abatement contractor worked for the same firm. The planner might recommend to the LEA more expensive response actions than are necessary in the management plan. Other Frequent Questions…

  • Last published: May 24, 2024

• The training requirements specified in 40 CFR part 763 appear to apply to projects (excluding small-scale, short-duration projects) involving interior building components. Specifically, is roofing work and other exterior work covered?

  Worker training requirements specified in 40 CFR part 763, including those for accreditation under the Asbestos Model Accreditation Plan (MAP), apply to interior building projects done in schools and public and commercial buildings. Additionally, the asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP), Occupational Safety and Health Administration (OSHA)…

  • Last published: May 30, 2024

• 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…

  • Last published: May 29, 2024

• How often does a facility need to complete an oil spill response training under the FRP requirements?

  Facilities subject to the Facility Response Plan (FRP) regulations in 40 CFR Part 112, Subpart D are required to develop a facility response training program to train those personnel involved in oil spill response activities (§112.21(b)). How often does a facility need to complete an oil spill response training under…

  • Last published: May 31, 2024