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 (40 CFR §68.25). If the worst-case release scenarios for a regulated toxic substance and for a regulated flammable substance involve the same process, must both scenarios be analyzed?

Yes. If the worst-case release scenarios for a regulated toxic substance and for a regulated flammable substance in Program 2 and 3 processes are associated with the same process, the two worst-case release scenarios must be analyzed separately.