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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

• 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

• 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

• If RFG is shipped from a refinery to a terminal through a proprietary pipeline system, may the pipeline rely on the refinery and terminal test results to satisfy the quality assurance defense element?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In a case where EPA documents a downstream standard violation at a proprietary terminal that is served only by a proprietary pipeline that receives gasoline only from a proprietary refinery, the company that owns the refinery, pipeline and…

  • Last published: July 10, 2024

• If, due to piping constraints, a refiner must put a purchased or inter-refinery transferred batch of finished gasoline through the refinery blendstock system, but does so without the batch losing integrity, must the refiner include the batch in his compli

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. As per § 80.65(i) of the regulations, any refiner, importer, or oxygenate blender shall exclude from all compliance calculations, the volume and properties of any RFG that is produced at another refinery or oxygenate blending facility, or…

  • Last published: July 10, 2024

• In areas where an oxy fuels program is in effect, how do these requirements coincide with RFG requirements? In areas where there is an overlap, are any regulatory changes necessary by the state?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In areas that are covered by both a state's winter oxy fuels and the federal RFG programs, the fuel must comply with both program requirements. Therefore, the more stringent 2.7 wt% minimum requirement of the winter oxy fuels…

  • Last published: July 10, 2024

• If foreign product is acquired by an importer through an exchange agreement instead of a sale, does it change identification of the importer for RFG reporting purposes?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. The person who is the importer of record for Customs purposes should be the importer for RFG purposes, and this is usually the gasoline owner, regardless of how that ownership was acquired.(7/1/94) This question and answer was…

  • Last published: July 10, 2024

• If terminals utilize the services of outside laboratories for periodic sampling and testing, how can the terminal limit exposure to liability in the event non-complying product from the tested tank(s) leaves the terminal during the three or four days befo

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . A terminal-distributor's release of RFG that does not meet applicable standards would constitute a violation of § 80.78(a)(1) for which the distributor would be liable, and it would not be a defense if the violation was caused by…

  • Last published: July 10, 2024

• If a pipeline must be classified as a refiner, how would that be handled administratively by EPA? Since pipelines don't own the product, would pipeline have to become buyers and sellers for regulatory purposes?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Refiners must be registered with EPA. The pipeline need not be an owner of the gasoline to be a refiner.(7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July…

  • Last published: July 11, 2024

• What are the sampling and testing requirements for terminal blenders (barges, trucks and pipelines)?

  See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . If the facility's activities fit the definition of a refiner, it would have to sample and test each batch of gasoline as required under § 80.65(e). If its activities fit the definition of an oxygenate blender, it would…

  • Last published: July 11, 2024