United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
(5104)
EPA 550-B-00-007
May 2000
www.epa.gov/ceppo/
x-xEPA
RISK MANAGEMENT
PROGRAM GUIDANCE
FOR
WASTEWATER
TREATMENT PLANTS
(40 CFR PART 68)
Chemical Emergency Preparedness and Prevention Office
Printed on recycled paper
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at provides guidance to help owners and operators of wastewater treatment plants to
•processes are subject to chemical accident^eventipn regjulation under section
;,Clean .Alr.Act and,40 CFR part 68 and" to comply with regulations. This document
; n(rt subgEti&eiprBPA's regulations, nor is it a regulation itself. Thus, it cannot impose
jy_ binding requirements on EPA, states, or the regulated community, and may not apply to a
• situation based upon circumstances. EPA may change this guidance in the future, as
Dfopriatlr™
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THIS EDITION
This document is a revision of the October 1998 Risk Management Program Guidance for Wastewater
Treatment Plants. The revisions are needed to reflect several amendments to 40 CFR part 68 as well as
to reflect the availability of the software for submission of RMPs. The specific regulatory changes
include the following:
+ The change from SIC codes to NAICS codes to define the industrial sectors subject to
Program 3; and
+ Changes to coverage for flammable fuels.
The revisions also update items, such as web page addresses, where needed. Pages that include
substantive revisions to the previous text are noted by a new date in the footer. Appendices C and D in
the July 1998 document, which provided EPA and OSHA contacts, have been eliminated; addresses for
websites that provide this information and are updated frequently are included in the Technical
Assistance appendix.
The major changes to this document involve the removal of information related to propane. Because
propane is used at WWTPs only as a fuel, it is no longer covered under part 68 at these facilities. Tables
and checklists that related to propane have been removed. Remaining tables have been renumbered,
where necessary; the content of the remaining tables has not been changed. The text also clarifies when
digester gas is subject to part 68.
FOR UPDATES
To keep up to date on changes to this document and to the risk management program rule, and to
find other information related to part 68 and accident prevention, visit EPA's Chemical Emergency
Preparedness and Prevention Office website at:
www.epa.gov/ceppo/
May 26,2000
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TABLE OF CONTENTS
INTRODUCTION
CHAPTER 1 GENERAL APPLICABILITY
1.1 Introduction
1.2 General Provisions
1.3 Regulated Substances and Thresholds
1.4 What is a Process
1.5 Threshold Quantity in a Process
1.6 Stationary Source
1.7 When You Must Comply
CHAPTER 2 APPLICABILITY OF PROGRAM LEVELS
2.1 What Are Program Levels
2.2 POTW Program Levels
2.3 Program 1
2.4 Quick Rules for Determining Program 1 Eligibility
2.5 Program 3
2.6 Program 2
2.7 Dealing with Program Levels
2.8 Summary of Program Requirements
CHAPTER 3 FIVE-YEAR ACCIDENT HISTORY
3.1 What Accidents Must Be Reported
3.2 What Data Must Be Provided
3.3 Other Accident Reporting Requirements
CHAPTER 4 OFFSITE CONSEQUENCE ANALYSIS
4.1 Worst-Case Release Scenarios
4.2 Alternative Release Scenarios
4.3 Buildings
4.4 Estimating Offsite Receptors
4.5 Documentation
4.8 Symbols for Chapter 4
Appendix 4A Equations
Appendix 4B Limitations of Results
CHAPTERS MANAGEMENT SYSTEM
5.1 General Information
5.2 How to Meet the Management System Requirements
CHAPTER 6 PREVENTION PROGRAM (PROGRAM 2)
6.1 About the Program 2 Prevention Program
6.2 Safety Information (§ 68.48)
6.3 Hazard Review (§ 68.50)
1-1
1-3
1-5
1-5
1-10
1-17
1-18
2-1
2-3
2-5
2-11
2-13
2-14
2-15
2-18
3-1
3-1
3-9
4-3
4-18
4-36
4-41
4-43
4-44
4-55
4-60
5-1
5-1
6-1
6-1
6-9
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n
6.4 Operating Procedures (§ 68.52)
6.5 Training (§ 68.54)
6.6 Maintenance (§ 68.56)
6.7 Compliance Audits (§ 68.58)
6.8 Incident Investigation (§ 68.60)
6.9 Conclusion
Appendix 6A Hazard Review Checklists, What If Questions, and HAZOP Procedures
CHAPTER? PREVENTION PROGRAM (PROGRAM 3)
7.1 Prevention Program 3 and OSHAPSM
7.2 Process Safety Information (§ 68.65)
7.3 Process Hazard Analysis (§ 68.67)
7.4 Operating Procedures (§ 68.69)
7.5 Training (§ 68.71)
7.6 Mechanical Integrity (§ 68.73)
7.7 Management of Change (§ 68.75)
7,8 Pre-Startup Review (§ 68.77)
7.9 Compliance Audits (§ 68.79)
7.10 Incident Investigation (§ 68.81)
7.11 Employee Participation (§ 68.83)
7.12 Hot Work Permits (§ 68.85)
7.13 Contractors (§ 68.87)
Appendix 7-A PHA Techniques
CHAPTERS EMERGENCY RESPONSE
8.1 Non-Responding Sources
8.2 Elements of an Emergency Response Program
8.3 Developing an Emergency Response Program
8.4 Integration of Existing Program
8.5 Have I Met Part 68 Requirements?
8.6 Coordination with Local Emergency Planning Entities
CHAPTER 9 RISK MANAGEMENT PLAN
9.1 Elements of the RMP
9.2 RMP Submission
9.3 Resubmission and Updates
CHAPTER 10 IMPLEMENTATION ;
10.1 Implementing Agency
10.2 Reviews/Audits/Inspections
10.3 Relationship with Titie V Permit Programs
10.4 Penalties for Non-Compliance
CHAPTER 11 COMMUNICATION WITH THE PUBLIC
11.1 Basic Rules of Risk Communication
11.2 Sample Questions for Communicating with the Public
6-13
6-17
6-20
6-24
6-27
6-29
6-31
7-1
7-3
7-6
7-10
7-12
7-13
7-16
7-18
7-19
7-19
7-21
7-21
7-22
7-24
8-1
8-3
8-6
8-9
8-10
8-14
9-1
9-2
9-3
10-1
10-2
10-3
10-4
11-1
11-4
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Ill
11.3 Communication Activities and Techniques
11.4 For More Information
11-13
11-19
APPENDICES
APPENDIX A
APPENDIX B
APPENDKC
APPENDIX D
PART 68
Reserved
TECHNICAL ASSISTANCE
OSHA OUTDANCE ON PSM
May 26, 2000
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IV
LIST OF BOXES AND EXHIBITS
IN RMP GUIDANCE
LIST OF EXHIBITS
CHAPTER 1
Exhibit 1-1
Exhibit 1-2
Exhibit 1-3
CHAPTER 2
Exhibit 2-1
Exhibit 2-2
Exhibit 2-3
Exhibit 2-4
Exhibit 2-5
Exhibit 2-6
CHAPTERS
Exhibit 3-1
CHAPTER 4
Exhibit 4-1
Exhibit 4-2
Exhibit 4-3
Exhibit 4-4
Exhibit 4-5
Exhibit 4-6
Exhibit 4-7
Exhibit 4-8
Exhibit 4-9
Exhibit 4-10
Exhibit 4-11
Exhibit 4-12
Exhibit 4-13
Exhibit 4-14
Exhibit 4-15
Exhibit 4-16
Exhibit 4-17
Exhibit 4-18
Exhibit 4-19
Exhibit 4-20
Exhibit 4-21
Exhibit 4-22
Exhibit 4-23
Evaluate Facility to Identify Covered Processes
Process
Stationary Source
Evaluate Program Levels for Covered Processes
Federal OSHA States
States with Delegated OSHA Programs
Program Level Criteria
Develop Risk Management Program and RMP
Comparison of Program Requirements
Atmospheric Stability Classes
Steps for an Offsite Consequence Analysis
Required Parameters for Modeling
Distances to Toxic Endpoint — Chlorine
Distances to Toxic Endpoint for Chlorine
Distances to Toxic Endpoint — Sulfur Dioxide
Distances to Toxic Endpoint for Sulfur Dioxide
Distances to Toxic Endpoint for Anhydrous Ammonia Liquefied Under Pressure
Ratio of Vapor Pressure of Ammonia in 30% Aqueous Ammonia
Distances to Toxic Endpoint for Aqueous Ammonia
Distance to Overpressure Endpoint of 1 psi for Vapor Cloud Explosions of Methane
Distances to Toxic Endpoint for Chlorine
Release Rates and Distance to the Endpoint for Liquid Chlorine Releases
Release Rates for Two-Phase Releases from Pipes Carrying Liquid Chlorine
Release Rates and Distance to the Endpoint for Chlorine Vapor Releases
Release Rates and Distance to the Endpoint for Liquid Sulfur Dioxide Releases
Distances to Toxic Endpoints for Sulfur Dioxide
Release Rates for Two-Phase Releases from Pipes Carrying Liquid Sulfur Dioxide
Release Rates and Distance to the Endpoint for Sulfur Dioxide Vapor Releases
Release Rates and Distance to the Endpoint for Liquid Ammonia Releases
Distances to Toxic Endpoint for Anhydrous Ammonia
Distances to Toxic Endpoint for Aqueous Ammonia
Neutrally Buoyant Plume Distances to LFL (rural)
Neutrally Buoyant Plume Distances to LFL (urban)
May 26,2000
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Exhibit 4-24
Exhibit 4-25
Figure 4-1
Figure 4-2
Figure 4-3
Figure 4-4
Figure 4-5
Figure 4-6
Figure 4-7
Figure 4-8
Figure 4-9
Figure 4-10
CHAPTERS
Exhibit 5-1
CHAPTER 6
Exhibit 6-1
Exhibit 6-2
Exhibit 6-3
Exhibit 6-4
Exhibit 6-5
Exhibit 6-6
Exhibit 6-7
Exhibit 6-8
Exhibit 6-9
Exhibit 6-10
Exhibit 6-11
CHAPTER 7
Exhibit 7-1
Exhibit 7-2
Exhibit 7-3
Exhibit 7-4
Exhibit 7-5
Exhibit 7-6
Exhibit 7-7
Exhibit 7-8
Exhibit 7-9
Exhibit 7-10
Exhibit 7-11
Exhibit 7-12
Ten-Minute Building Release Attenuation Factors for Prolonged Releases of Anhydrous
Ammonia
Ten-Minute Building Release Attenuation Factors for Prolonged Releases of Chlorine
and Sulfur Dioxide
Worst-Case Scenario — Predicted Distances to Toxic Endpoint for Chlorine
Worst-Case Scenario — Predicted Distances to Toxic Endpoint for Sulfur Dioxide
Worst-Case Scenario — Predicted Distances to Toxic Endpoint for Anhydrous Ammonia
Worst-Case Scenario — Predicted Distances to Toxic Endpoint for Aqueous Ammonia
Alternative Case Scenario — Predicted Distances to Toxic Endpoint for Chlorine
Alternative Case Scenario — Predicted Distances to Toxic Endpoint for Sulfur Dioxide
Alternative Case Scenario — Predicted Distances to Toxic Endpoint for Anhydrous
Ammonia
Alternative Case Scenario — Predicted Distances to Toxic Endpoint for Aqueous
Ammonia
Guidance on Effectiveness of Building Mitigation for Alternative Scenarios
Simplified Presentation of Worst Case and Alternative Scenario on a Local Map
Sample Management Documentation
Summary of Program 2 Prevention Program
Safety Information Requirements
Codes and Standards
Sample Safety Information Sheet
Hazard Review Requirements
Operating Procedures Requirements
Training Chart
Maintenance Guidelines
Sample Audit Checklist for Safety Information and Hazard Review
Incident Investigation Requirements
Sample Incident Investigation Format
Comparable EPA and OSHA Terms
Summary of Program 3 Prevention Program
Process Safety Information Requirements
Process Hazard Analysis Requirements
Operating Procedures Requirements
Mechanical Integrity Chart
Management of Change Requirements
Pre-startup Review Requirements
Incident Investigation Requirements
Employee Participation Requirements
Hpt Work Permits Requirements
Contractors Chart
May 26,2000
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VI
Exhibit 7a-l Applicability of PHA Techniques
Exhibit 7a-2 Time and Staffing for PHA Techniques
CHAPTER 8
Exhibit 8-1 Federal Guidance on Emergency Planning and Response
Exhibit 8-2 Federal Emergency Planning Regulations
Exhibit 8-3 Integrated Contingency Plan Outline
CHAPTER 9
Exhibit 9-1 RMP Updates
CHAPTER 11
Exhibit 11-1 Seven Cardinal Rules of Risk Communication
May 26, 2000
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Vll
LIST OF BOXES
INTRODUCTION
State Programs
Part 68 Regulatory Terms
What Is a Local Emergency Planning Committee?
CHAPTER 1
State Programs
Qs and As: Stationary Source
Qs and As: Process
Aggregation of Substances
Q and A: Changing Inventories
Qs and As: Compliance Dates
CHAPTER 2
Q and A: Process and Program Level
Qs and As: Public Receptors
Q and A: Determining Distances
Q and A: Environmental Receptors
Qs and As: Accident History
QsandAs:OSHA
CHAPTERS
Qs and As: Property Damage
Qs and As: Accident History
CHAPTER 4
RMP*Comp
How to Obtain Census Data and LandView
How to Obtain USGS Maps
CHAPTER 6
Q and A: Maintenance
Q and A: Audits
CHAPTER 7
Qs and As: Implementation and Process
Qs and As: Process Safety Information
Qs and As: Offsite Consequences
CHAPTER 8
What Is a Response
What Is a Local Emergency Planning Committee?
How Does the Emergency Response Program Apply?
Planning for Flammable Substances
May 26, 2000
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V1U
CHAPTER 9
Q and A: Revising a PHA
Qs and As: RMP Updates
CHAPTER 10
Qs and As: Delegation
Qs and As: Audits
CHAPTER 11
What Does Your Worst-case Distance Mean?
What Does It Mean That We Could Be Exposed If We Live/Work/Shop/Go to School X Miles Away?
If There Is An Accident, Will Everyone Within That Distance Be Hurt? What About Property Damage?
How Sure Are You of Your Distances?
Why Do You Need to Store So Much on Site?
What Are You Doing to Prevent Releases?
What Are You Doing to Prepare for Releases?
Do You Need to Use this Chemical?
Why Are Your Distances Different from the Distances in the EPA Lookup Tables?
How Likely Are the Worst-case and Alternative Release Scenarios?
Is the Worst-case Release You Reported Really the Worst Accident You Can Have?
What about the Accident at the [Name of Similar Facility] That Happened Last Month?
What Actions Have You Taken to Involve the Community in Your Accident Prevention and Emergency
Planning Efforts?
Can We See the Documentation You Keep on Site?
May 26,2000
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IX
TABLE OF POTENTIALLY REGULATED ENTITIES
This table is not intended to be exhaustive, but rather provides a guide for readers regarding
entities likely to be regulated under 40 CFR part 68. This table lists the types of entities that
EPA is now aware could potentially be regulated by this rule and covered by this document.
Other types of entities not listed in this table could also be affected. To determine whether your
facility is covered by the risk management program rules in part 68, you should carefully
examine the applicability criteria discussed in Chapter 1 of this guidance and in 40 CFR 68.10.
If you have questions regarding the applicability of this rule to a particular entity, call the
EPCRA/CAA Hotline at (800) 424-9346 (TDD: (800) 553-7672).
Category
Wastewater
Treatment Plants
NAICS
Codes
22132
SIC
Codes
4952
Examples of Potentially Regulated
Entities
Public and private wastewater treatment
plants
May 26, 2000
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INTRODUCTION
WHY SHOULD I READ THIS GUIDANCE?
If you handle, manufacture, use, or store any of the toxic and flammable substances
listed in 40 CFR 68.130 (see Appendix A of this document) above the specified
threshold quantities in a process, you are required to develop and implement a risk
management program under a rule issued by the U.S. Environmental Protection
Agency (EPA). This rule, "Chemical Accident Prevention Provisions" (part 68 of
Title 40 of the Code of Federal Regulations (CFR)), applies to a wide variety of
facilities that handle, manufacture, store, or use toxic substances, including chlorine
and ammonia and highly flammable substances such as propane. This document
provides guidance on how to determine if you are subject to part 68 and how to
comply with part 68. If you are subject to part 68, you must be in compliance no
later than June 21,1999, or the date on which you first have more than a threshold
quantity of a regulated substance in a process, whichever is later.
This model risk management program is intended for wastewater treatment plants
(WWTPs), including publicly owned treatment works (POTWs) and other industrial
treatment systems. It provides guidance on how to comply with part 68 with respect
to chlorine, ammonia (anhydrous and aqueous), sulfur dioxide, and digester gas, the
substances WWTPs usually use for treatment or produce as a result of treatment.
We expect that any regulated substances present in your wastestreams will be in
concentrations too low to require compliance.
The goal of part 68 — the risk management program — is to prevent accidental
releases of substances that can cause serious harm to the public and the environment
from short-term exposures and to mitigate the severity of releases that do occur. The
1990 Amendments to the Clean Air Act (CAA) require EPA to issue a rule
specifying the type of actions to be taken by facilities (referred to in the statute as
stationary sources) to prevent accidental releases of such hazardous chemicals into
the atmosphere and reduce their potential impact on the public and the environment.
Part 68 is that rule.
In general, part 68 requires that:
+ Covered facilities must develop and implement a risk management program
and maintain documentation of the program at the site. The risk
management program will include an analysis of the potential offsite
consequences of an accidental release, a five-year accident history, a release
prevention program, and an emergency response program.
+ Covered facilities also must develop and submit a risk management plan
(RMP), which includes registration information, to EPA no later than June
21, 1999, or the date on which the facility first has more than a threshold
quantity in a process, whichever is later. The RMP provides a summary of
the risk management program. The RMP will be available to federal, state,
and local government agencies and the public.
April 19, 2000
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Introduction
-u-
+ Covered facilities also must continue to implement the risk management
program and update their RMPs periodically or when processes change, as
required by the rule.
1 I
The phrase "risk management program" refers to all of the requirements of part 68,
which must be implemented on an on-going basis. The phrase "risk management
plan (RMP)" refers to the document summarizing the risk management program that
you must submit to EPA.
HOW DO I USE THIS DOCUMENT?
i i
: , " ' ""' : i "
This is a technical guidance document designed for owners and operators of WWTPs
covered by part 68. It will help you to:
+ Determine if you are covered by the rule;
i
i i
+ Determine what level of requirements is applicable to your covered
processes); ;
+ Understand which specific risk management program activities must be
conducted;
n . i
+ Select a strategy for implementing a risk management program, based on
your current state of compliance with other government rules and industry
standards and the potential offsite impact of releases from your process(es);
and
•' i
+ Understand the reporting, documentation, and risk communication
components of the rule.
', ' It
This document provides guidance and reference materials to help you comply with
EPA's risk management program regulations. You should view and retain this
guidance as a reference document for use when you are unsure about what a
requirement means. This document does not provide guidance on any other rule or
part of the CAA. Even if you are not covered by this rule, you should be aware that
under the General Duty Clause of CAA section 112(r)(l), you are required to design
and maintain a safe facility.
!
WHAT DO I DO FIRST?
i
Before developing a risk management program, you should do five things:
1
(1) Determine which, if any, of your processes are covered by this program
l
Only WWTPs having one or more processes with a threshold quantity of a
regulated substance (see 40 CFR 68.130 in Appendix A) in a "process" need
to comply with part 68. "Process" is defined by the rule in § 68.3 and does
not necessarily correspond with an engineering concept of process. The
October 27,1998
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-ill-
Introduction
STATE PROGRAMS
This guidance applies to 40 CFR part 68. You should check with your state government to determine
if the state has its own accidental release prevention rules or has obtained delegation from EPA to
implement and enforce part 68 in your state. State rules may be more stringent than EPA's rules.
They may cover more substances or cover the same substances at lower thresholds. They may also
impose additional requirements. For example, California's state program requires a seismic study.
See Chapter 10 for information on state implementation of part 68. "Unless your state has been
granted delegation, you must comply with part 68 as described in this document even if your state has
different rules under state law.
requirements apply only to covered processes. See Chapter 1 for more
information on how to define your processes and determine if they are
subject to the rule.
(2) Determine the appropriate program level for each covered process
Depending on the specific characteristics of a covered process, the results of
the offsite consequence analysis for that process, and whether your state
implements OSHA programs, it may be subject to one of three different sets
of requirements (called program levels). See Chapter 2 for more
information.
(3) Determine EPA's requirements for the facility and each covered process
Certain requirements apply to the facility as a whole, while others are
process-specific. See Chapter 2 for more information.
(4) Assess your operations to identify current risk management activities
Because you probably conduct some risk management activities already
(e.g., employee training, equipment maintenance, and emergency planning),
you should review your current operations to determine the extent to which
they meet the provisions of this rule. EPA does not expect you to redo these
activities if they already meet the rule's requirements. See Chapters 5 to 8
individually for guidance on how to tell if your existing practices can meet
those required by EPA. '
(5) Review the regulations and this guidance to develop a strategy for
conducting the additional actions you need to take for each covered
process. Discuss the requirements with management and staff.
The risk management program takes an integrated approach to assessing and
managing risks and will involve most of the operations of covered processes.
Early involvement of both management and staff will help develop an
effective program.
October 27, 1998
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Introduction
-IV-
REQUIREMENTS ARE PERFORMANCE BASED
•i. ' . ,,
FinaUy, keep m mind that many of these reqiiirements are performance-based; for
example, part 68 does not specify how often you must inspect storage tanks, only
that you do so in a manner that minimizes the risk of a release. This allows you to
tailor your program to fit the particular conditions at your facility. The degree of
complexity required in a risk management program will depend on the complexity of
the facility. To illustrate, the operating procedures for a WWTP that does only
primary treatment are likely to be less complex than those of WWTP that does
secondary or tertiary treatment. Similarly, the length of training necessary to educate
employees on such procedures will be proportional to the complexity of your
operating procedures. And while a large WWTP with multiple processes may
benefit from a computerized maintenance tracking system, a small WWTP with a
simpler process may be able to track maintenance activities using a logbook.
There is no one "right" way to develop and implement a risk management program.
Even for the same rule elements, your program will be different from everyone else's
program (even those in the same industry) because it will be designed for your
specific situation and hazards — it will reflect whether your facility is near the
public and sensitive environmental areas, the specific equipment you have installed,
the managerial decisions that you have made previously, and other relevant factors.
WHERE DO I GO FOR MORE INFORMATION?
EPA's risk management program requirements may be found in Part 68 of Volume
40 of the Code of Federal Regulations. The relevant sections were published hi the
Federal Register on January 31, 1994 (59 FR 4478) and June 20, 1996 (61 FR
31667). EPA has amended the rules several times. A consolidated copy of these
regulations, including amendments through June 30, 1999, is available in Appendix
A. On March 13, 2000, EPA finalized regulations to implement new rules excluding
flammable substances when used as fuels or held for sale as fuel by retailers (65 FR
13,243); a copy of this final rule is also available in Appendix A.
• i
EPA has worked with industry and local, state, and federal government agencies to
assist sources in complying with these requirements. For more information, refer to
Appendix C (Technical Assistance). Your local emergency planning committee
(LEPC) also can be a valuable resource and can help you discuss issues with the
public.
] .
Finally, if you have access to the Internet, EPA has made copies of the rules, fact
sheets, and other related materials available at the home page of EPA's Chemical
Emergency Preparedness and Prevention Office (http://www.epa.gov/ceppo/).
Please check the site regularly as additional materials are posted.
April 19,2000
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-V-
Introduction
PART 68 REGULATORY TERMS
A few words and phrases have very specific meanings within the regulation. Some of these are
unusual, which is to say they are not used in everyday language. Others are defined by the rule in
ways that vary to some degree from their everyday meaning. The following are the major regulatory
terms used in this document and a brief introduction to their meaning within the context of part 68.
They are defined in § 68.3 of the rule.
"Stationary source " basically means facility. The CAA and, thus Part 68 use the term "stationary
source" and we explain it in Chapter 1. Generally, we use "facility" in its place in this document.
"Process " is given a broad meaning in this rule and document. Most people think of a process as the
mixing or reacting of chemicals. Its meaning under this rule is much broader. It basically means any
equipment, including storage vessels, and activities, such as loading, that involve a regulated
substance and could lead to an accidental release. Chapter 1 discusses the definition of process
under this rule in detail.
"Regulated substance " means one of the 140 chemicals listed in part 68.
"Threshold quantity" means the quantity, in pounds, of a regulated substance which, if exceeded,
triggers coverage by this rule. Each regulated substance has its own threshold quantity. If you have
more than a threshold quantity of a regulated substance in a process,; you must comply with the rule.
Chapter 1 explains how to determine whether you have a threshold quantity.
"Vessel" means any container, from a single drum or pipe to a large storage tank or sphere.
"Public receptor" generally means any place where people live, work, or gather, with the exception
of roads. Buildings, such as houses, shops, office buildings, industrial facilities, the areas
surrounding buildings where people are likely to be present, such as yards and parking lots, and
recreational areas, such as parks, sports arenas, rivers, lakes, beaches, are considered public
receptors. Chapter 2 discusses public receptors.
"Environmental receptor" means a limited number of natural areas that are officially designated by
the state or federal government. Chapter 2 discusses this definition.
October 27, 1998
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Introduction
-VI-
WHAT IS A LOCAL EMERGENCY PLANNING COMMITTEE?
Local emergency planning committees (LEPCs) were formed under the federal Emergency Planning
and Community Right-to-Know Act (EPCRA) in 1986. The committees are designed to serve as a
community forum for issues relating to preparedness for emergencies involving hazardous
substances. They consist of representatives from local government, local industry, transportation
groups, health and medical organizations, community groups, and the media. LEPCs:
+ Collect information from facilities on hazardous substances that pose a risk to the
community;
+ Develop a contingency plan for the community based on this information; and
+ Make information on hazardous substances available to the general public.
Contact the mayor's office or the county emergency management office for more information on your
LEPC.
October 27,1998
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CHAPTER 1: GENERAL APPLICABILITY
1.1 INTRODUCTION
The purpose of this chapter is to help you determine if you are subject to Part 68, the
risk management program rule. Part 68 covers you if you are:
4- The owner or operator of a stationary source (facility)
4- That has more than a threshold quantity
4-. Of a regulated substance
4- In a process.
The goal of this chapter is to make it easy for you to identify processes that are
covered by this rule so you can focus on them.
This chapter walks you through the key decision points (rather than the definition
items above), starting with those provisions that may tell you that you are not subject
to the rule. We first outline the general applicability provisions and the few
exemptions and exclusions, then discuss which chemicals are "regulated substances."
If you do not have a "regulated substance" at your site, you are not covered by this
rule. The exemptions may exclude you from the rule or simply exclude certain
activities from consideration. (Throughout this document, when we say "rule" we
mean the regulations in part 68.)
We then describe what is considered a "process," jwhich is critical because you are
subject to the rule only if you have more than a threshold quantity in a process. The
chapter next describes how to determine whether you have more than a threshold
quantity.
Finally, we discuss how you define your overall stationary source and when you
must comply. These questions are important once you have decided that you are
covered. For most WWTPs covered by this rule, the stationary source is basically all
covered processes at your site. Exhibit 1-1 presents the decision process for
determining applicability.
STATE PROGRAMS
This guidance applies to only 40 CFR part 68. You should check with your state government to
determine if the state has its own accidental release prevention rules or has obtained delegation from
EPA to implement and enforce part 68 in your state. State rules may be more stringent than EPA's
rules. Unless your state has been granted delegation, you must comply with part 68 as described in
this document even if your state has different rules under state law. See Chapter 10 for a discussion
of state implementation of part 68.
October 27, 1998 '
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EXHIBIT 1-1
EVALUATE FACILITY TO IDENTIFY COVERED PROCESSES
Is your facility
a stationary
source?
Do you have
any regulated
substances?
STOP!
You are not covered
by the rule.
Define your
processes
Do you have any
regulated substances
above a threshold quantity
in a process?
You are subject
to the rule.
Assign Program levels to
covered processes
(see Exhibit 2-1)
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Chapter 1
General Applicability
1.2 GENERAL PROVISIONS
The CAA applies this rule to any person who owns or operates a stationary source.
"Person" is defined to include :
"An individual, corporation, partnership, association, State, municipalityj political
subdivision of a state, and any agency, department, or instrumentality of the United
States and any officer, agency, or employee thereof."
The rule, therefore, applies to all levels of government as well as private businesses.
CAA section 112(r)(2)(c) defines "stationary sources" as:
"Any buildings, structures, equipment, installations, or substance emitting stationary
activities
+ Which belong to the same industrial groiiip,
+ Which are located on one or more contiguous properties,
+ Which are under the control of the same person (or persons under common
control), and
+ From which an accidental release may occur."
EPA has added some language in the rule to clarify issues related to transportation
(see below).
FLAMMABLE FUELS (§ 68.126)
The flammable substances listed in § 68.130, which include propane and methane,
are excluded from coverage under part 68 when they are used as a fuel or held for
sale as a fuel at a retail facility. If you store propane on site for use as a fuel or if
you generate digester gas that you collect and use as a fuel, neither the propane nor
the methane in the digester gas is subject to part 68. If you produce a threshold
quantity of digester gas and you do not use it as a fuel, it is subject to the rule.
TRANSPORTATION ACTIVITIES
The rule applies only to stationary sources. Pipelines covered by DOT or under a
state natural gas or hazardous liquid program for .which the state has in effect a
certification to DOT under 49 U.S.C. 6010.5 are not covered. WWTPs are unlikely
to have such pipelines on their property. Piping at your source, however, is covered.
Transportation containers used for storage riot incident to transportation and
transportation containers connected to equipment at a stationary source are
considered part of the stationary source. Transportation containers that have been
unhooked from the motive power that delivered them to the site (e.g., truck or
locomotive) and left on your site for short-term or long-term storage are part of your
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General Applicability
1-4
stationary source. For example, if you have railcars on a private siding that you use
as storage tanks until you are ready to hook them to your process, these railcars
should be considered to be part of your source. If a tank truck is being unloaded and
the motive power is still attached, the track and its contents are considered to be in
transportation and not covered by the rule. You should count only the substances in
the piping or hosing as well as the quantity unloaded. Some issues related to
transportation are still under discussion with DOT.
QS&As
STATIONARY SOURCE
Q. What does "same industrial group" mean?
A. Operations at a site that belong to the same three-digit North American Industry Classification
System (NAICS) code (which has replaced the old two-digit SIC codes) belong to the "same
industrial group. In addition, where one or more operations at the site serve primarily as support
facilities for the main operation at the site, the supporting operations are part of the "same industrial
group" as the main operation. For example, if you manufacture chemicals (NAICS 325) and operate
a waste treatment facility (NAICS 562) that handles primarily wastes generated by your chemical
operations, the waste operation would be considered a support operation. POTWs are unlikely to
share a site with any operation that that is not in the same industrial group; both water and wastewater
(sewage) treatment are in NAICS code 221.
Q. What does "contiguous property" mean?
A. Property that is adjoining. Public rights-of-way (e.g., railroads, highways) do not prevent property
from being considered contiguous. Property connected only by rights-of-way are not considered
contiguous (e.g., two plants with a connecting pipeline).
Q. What does "control of the same person" mean?
A. Control of the same person refers to corporate control, not site management. If two divisions of a
corporation operate at the same site, even if each operation is managed separately, they will count as
one source provided the other criteria are met because they are under control of the same company.
RELATIONSHIP TO OSHA PROCESS SAFETY MANAGEMENT STANDARD EXEMPTIONS
i: | • •
The OSHA Process Safety Management (PSM) standard (29 CFR 1910.119)
exempts flammable liquids stored in atmospheric storage tanks. In addition, state
and local governments are not subject to federal OSHA standards, but are subject to
OSHA rules if their state has a delegated OSHA program (see Chapter 2). The
OSHA exemptions do not apply or extend to EPA's Risk Management Program Rule.
Your processes are not exempt from the Risk Management Program simply because
they qualify for one of the OSHA exemptions. EPA's rule covers substances stored
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1-5
Chapter 1
General Applicability
in atmospheric storage tanks and state and local governments if they own or operate
a facility where there is more than a threshold quantity in a process.
1.3 REGULATED SUBSTANCES AND THRESHOLDS (§ 68.130)
The list of substances regulated under § 68.130 is in Appendix A. Check the list
carefully. If you do not have any of these substances (either as pure substances or in
mixtures above 1 percent concentration) or do not have them above their listed
threshold quantities, you do not need to read any further because you are not
covered.
The list includes the following chemicals that are commonly used at WWTPs:
Chlorine
Anhydrous Ammonia
Aqueous Ammonia
(concentration 20% or greater)
Anhydrous Sulfur Dioxide
Methane
EPA ;
Threshold Quantity
2,500 pounds
10,000 pounds
20,000 pounds
5,000 pounds
10,000 pounds
OSHA
Threshold Quantity
1,500 pounds
10,000 pounds
15,000 pounds
1,000 pounds
(Liquid)
10,000 pounds
For methane, the 10,000-pound threshold applies to the total weight of the
flammable mixture of digester gases, not just the weight of methane or flammables in
the mixture. For aqueous ammonia, the threshold applies only to the weight of
ammonia in the mixture.
In general, regulated chemicals in a wastestream at a POTW will not exceed one
percent of a mixture and thus will not be covered by part 68. If an industrial WWTP
has more than 1 percent of a regulated substance in the wastestream, the quantity of
the substance in the wastestream will have to be determined and compared to the
threshold quantity. Oxygen is not subject to either part 68 or OSHA PSM. Ozone is
also not subject to part 68, although it is covered by OSHA PSM.
1.4 WHAT IS A PROCESS
The concept of "process" is key to whether you are subject to this rule. Process is
defined in 40 CFR § 68.3 as:
"Any activity involving a regulated substance, including any use, storage,
manufacturing, handling, or on-site movement of such substances, or combination of
these activities. For the purposes of this definition, any group of vessels that are
interconnected, or separate vessels that are located such that a regulated substance
could be involved in a potential release, shall be considered a single process."
"Vessel" in § 68.3 means any reactor, tank, drum,ibarrel, cylinder, vat, kettle, boiler,
pipe, hose, or other container.
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General Applicability
1-6
EPA's definition of process is identical to the definition of process under the OSHA
PSM standard. Understanding the definition of process is important in determining
•whether you have a threshold quantity of a regulated substance and what level of
requirements you must meet if the process is covered.
What does this mean to you?
+ If you store a regulated substance in a single vessel in quantities above the
threshold quantity, you are covered.
4- If you have interconnected vessels that altogether hold more than a threshold
quantity, you are covered. The connections need not be permanent. If two
or more vessels are connected occasionally, they are considered a single
process for the purposes of determining whether a threshold quantity is
present.
+ If you have multiple unconnected vessels, containing the same substance,
you will have to determine whether they need to be considered together as
co-located.
A process can be as simple as a single storage vessel or a group of drums or
cylinders in one location or as complicated as a system of interconnected vessels,
pumps, piping, and storage vessels.
SINGLE VESSELS
If you have only a single vessel containing regulated substances, you need not worry
about the other possibilities for defining a process and can skip to section 1.5. For
the purposes of defining a threshold quantity, you need only consider the quantity in
this vessel.
i
INTERCONNECTED VESSELS
In general, if you have two or more vessels containing a regulated substance that are
connected through piping or hoses for the transfer of the regulated substance, you
must consider the total quantity of a regulated substance in all the connected vessels
and piping when deterrnining if you have a threshold quantity in a process. If the
vessels are connected for transfer of the substance using hoses that are sometimes
disconnected, you still have to consider the contents of the vessels as one process,
because if one vessel were to rupture while the hose was attached or the hose were to
break during the transfer, both tanks could be affected. Therefore, you must count
the quantities in both tanks and in any connecting piping or hoses. You cannot
consider the presence of automatic shutoff valves or other devices that can limit
flow, because these are assumed to fail for the purpose of deterrnining the total
quantity in a process.
Once you have determined that a process is covered (the quantity of a regulated
substance exceeds its threshold), you must also consider equipment, piping, hoses, or
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1-7
Chapter 1
General Applicability
other interconnections that do not carry or contain the regulated substance, but that
are important for accidental release prevention. Equipment or connections which
contain utility services, process cooling water, steam, electricity, or other non-
regulated substances may be considered part of a process if such equipment could
cause a regulated substance release or interfere with mitigating the consequences of
an accidental release. Your prevention program for this process (e.g., PSM program)
will need to cover such equipment. If, based on your analysis, it is determined that
interconnected equipment or connections not containing the regulated substance
cannot cause a regulated substance release or interfere with mitigation of the
consequences of such a release, then such equipment or connections could safely be
considered outside the limits or boundaries of the covered process.
In some cases, determining the boundaries of a process for purposes of the RMP rule
may be complicated. In the preamble to the June 20, 1996 rule (61 FR 31668), EPA
clearly stated its intent to be consistent with OSHA's interpretation of "process" as
that term is used in OSHA's PSM rule. Therefore, if your facility is subject to the
PSM rule, the limits of your processes) for purposes of OSHA PSM will be the
limits of your process(es) for purposes of RMP (except in cases involving
atmospheric storage tanks containing flammable regulated substances, which are
exempt from PSM but not RMP). If your facility is not covered by OSHA PSM and
is complicated from an engineering perspective, you should consider contacting your
implementing agency for advice on determining process boundaries.
CO-LOCATION
The third possibility you must consider is whether you have separate vessels that
contain the same regulated substance mat are located such that they could be
involved in a single release. If so, you must add together the total quantity in all
such vessels to determine if you have more than a threshold quantity. This
possibility will be particularly important if you store a regulated substance in
cylinders or barrels or other containers in a warehouse or outside in a rack. In some
cases, you may have two vessels or systems that are in the same building or room.
For each of these cases, you should ask yourself:
+ Could a release from one of the containers lead to a release from the other?
For example, if a cylinder of propane were to rupture and burn, would the
fire spread to other cylinders?
+ Could an event external to the containers, such as a fire or explosion or
collapse of collision (e.g., a vehicle collides with several stored containers),
have the potential to release the regulated substance from multiple
containers? •
You must detennine whether there is a credible scenario that could lead to a release
of a threshold quantity.
For flammables, you should consider the distance between vessels. If a fire could
spread from one vessel to others or an explosion could rupture multiple vessels, you
must count all of them. For toxics, a release from a single vessel will not normally
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General Applicability
1-8
: •' ,',
lead to a release from others unless the vessel fails catastrophically and explodes,
sending metal fragments into other vessels. Co-located vessels containing toxic
substances, however, may well be involved in a release caused by a fire or explosion
that occurs from another source. The definition of process is predicated on the
assumption that explosion will take place. In addition, a collapse of storage racks
could lead to multiple vessels breaking open.
i
If the vessels are separated by fire walls or barricades that will contain the blast
waves from explosions of the substances, you will not need to count the separated
vessels, but you would count any that are in the same room.
I
You may not dismiss the possibility of a fire spreading based on an assumption that
your fire brigade will be able to prevent any spread. You should ask yourself how
far the fire would spread if the worst happens — the fire brigade is slow to arrive,
the water supply fails, or the local fire department decides it is safer to let the fire
burn itself out. If you have separate vessels containing a regulated substance that
could be affected by the same accident, you should count them as a single process.
PROCESSES WITH MULTIPLE CHEMICALS
When you are determining whether you have a covered process, you should not limit
your consideration to vessels mat have the same regulated substance. A covered
process includes any vessels that altogether hold more than a threshold quantity of
regulated substances and that are interconnected or co-located. Therefore, if you
have four storage or reactor vessels holding four different regulated substances
above their individual thresholds and they are located close enough to be involved in
a single event, they are considered a single process. One implication of this
approach is that if you have two vessels, each containing slightly less than a
threshold quantity of the same regulated substance and located a considerable
distance apart, and you have other storage or process vessels in between with other
regulated substances above their thresholds, the two vessels with the first substance
may be considered to be part of a larger process involving the other intervening
vessels and other regulated substances, based on co-location.
I
Exhibit 1-2 provides illustrations of what may be defined as a process.
,M ' ,|
DIFFERENCES WITH OSHA
i
OSHA aggregates different flammable liquids across vessels in making threshold
determinations; OSHA also aggregates different flammable gases (but does not
aggregate flammable liquids with flammable gases); EPA aggregates neither.
Therefore, if you have three co-located or connected reactor vessels each containing
5,000 pounds of a different flammable liquid, OSHA considers that you have 15,000
pounds of flammable liquids and are covered by the PSM standard. Under EPA's
rule, you would not have a covered process because you do not meet the threshold
quantity for any one of the three substances. OSHA, like EPA, does not aggregate
quantities for toxics as a class (i.e., each toxic substance must meet its own threshold
quantity).
October 27,1998
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EXHIBIT 1-2: PROCESS
Schematic Representation
Description
Interpretation
1 vessel
1 regulated substance above TQ
1 process
2 or more connected vessels
same regulated substance
above TQ
1 process
2 or more connected vessels
different regulated substances
each above TQ
1 process
pipeline feeding multiple vessels
total above TQ
1 process
2 or more vessels co-located
same substance
total above TQ
1 process
2 or more vessels co-located
different substances
each above TQ
1 process
2 vessels, located so they won't be
involved in a single release
same or different substances
each above TQ
2 processes
C
2 locations with regulated substances
each above TQ
1 or 2 processes
depending on distance
Flammable
1 series of interconnected vessels
same or different substances above TQs
plus a co-located storage vessel
containing flammables
1 process
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Chapter 1
General Applicability
1-10
Qs&As
PROCESS
Q. How far apart do separate vessels have to be to be considered different processes?
A. There is no hard and fast rule for how great this distance should be before you do not need to
consider the vessels as part of one process. Two vessels at opposite ends of a large warehouse room
might have to be considered as one process if the entire warehouse or room could be engulfed in a
fire. Two vessels separated by the same distance out of doors might be far enough apart that a fire
affecting one would be unlikely to spread to the other. You may want to consult with your local fire
department. You should then use your best professional judgment. Ask yourself how much of the
regulated substance could be released if the worst happens (you have a major fire, an explosion, a
natural disaster).
Q. We add chlorine to a wastestream which dilutes it. At what point does the process end?
A. The process ends when the concentration of chlorine in the wastestream is no longer above one
percent, unless other regulated substances are present above their threshold quantities or the vessel is
otherwise considered part of the process because it could cause a release of the covered vessels
holding regulated substances or hinder a response to such a release.
1.5 THRESHOLD QUANTITY IN A PROCESS
The threshold quantity for each regulated substance is listed in 40 CFR 68.30, in
Appendix A. You should determine whether the maximum quantity of each
substance in a process is greater than the threshold quantity listed. If it is, you must
comply with this rule for that process. Even if you are not covered by this rule, you
may still be subject to reporting requirements under the Emergency Planning and
Community Right to Know Act (EPCRA) because EPCRA section 312 requires
reporting at lower thresholds for toxics and counts for threshold determination
purposes the maximum quantity of each substance on the site as a whole rather than
in a single process.
QUANTITY IN A VESSEL
To determine if you have the threshold quantity of a regulated substance in a vessel
involved in a single process, you need to consider the maximum quantity in that
vessel at any one time. You do not need to consider the vessel's maximum capacity if
you never fill it to that level. Base your decision on the actual maximum quantity
that you may have in the vessel. Your maximum quantity may be more than your
normal operating maximum quantity; for example, if you may use a vessel for
emergency storage, the maximum quantity should be based on the quantity that
might be stored.
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Chapter 1
General Applicability
AGGREGATION OF SUBSTANCES
A toxic substance is never aggregated with a different toxic substance to determine whether a
threshold quantity is present. If your process consists of co-located vessels with different toxic
substances, you must determine whether each substance exceeds its threshold quantity.
A flammable substance in one vessel is never aggregated with a different flammable substance in
another vessel to determine whether a threshold quantity is present. However, if a flammable
mixture meets the criteria for NFPA-4 and contains different regulated flammables, it is the mixture,
not the individual substances, that is considered in determining if a threshold quantity is present.
"At any one time" means you need to consider the largest quantity that you ever have
in the vessel. If you fill a tank with 50,000 pounds and immediately begin using the
substance and depleting the contents, your maximum is 50,000 pounds.
If you fill the vessel four times a year, your maximum is still 50,000 pounds.
Throughput is not considered because the rule is concerned about the maximum
quantity you could release in a single event. •
For tanks, the maximum capacity can usually be found from "Ul A"certificates for
the vessels. The Ul A certificates on all vessels constructed under the ASME Boiler
and Pressure Vessel Code are kept on file by the National Board of Boiler and
Pressure Vessel Inspectors.1 The nominal nameplate capacity can also be found on
the permanently attached nameplate for your storage tank. The nameplate will also
have the National Board Number for your vessel, which is the key to retrieving your
U1A form from the Board. These nameplates may be located on one of the
hemispherical heads, the manway, or the manway cover of the tank. The nominal
capacity will usually be the water capacity, and you may want to convert it to
pounds.
If you use transportation containers (railcars or tank trucks) as storage vessels, you
can obtain the capacity from the required DOT nameplate, identification plate, or
specification plate or from the owner of the containers. Smaller shipping containers
are also marked.
In calculating the quantity in a tank, you may take into account industry
recommendations or regulatory limits on the percentage of the tank's total capacity
that can be used, provided you comply with these limits. The Chlorine Institute
recommends that chlorine tanks not be filled beyond 95 percent at a maximum
temperature of 122°F. OSHA regulations (29 CFR 1910.111) limit liquid volumes
of anhydrous ammonia. Aqueous ammonia may be held in various concentrations;
your supplier can provide the density and weight. You can use this information, with
your tank capacity, to estimate the quantity of ammonia being stored. The
1 National Board of Boiler and Pressure Vessel Inspectors, 1055 Crupper Ave., Columbus, OH 43229;
http ://www.nationalboard.org.
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General Applicability
1-12
Compressed Gas Association provides recommendations on filling sulfur dioxide
tanks at varying temperatures (CGA pamphlet G-3).
!"
Methane, a regulated flammable substance, is a component of digester gas,
commonly making up about 65 to 70 percent by volume of the total. Digester gas
usually meets the NFPA-4 criteria that determine whether flammable mixtures are
subject to part 68. You are more likely to have a threshold quantity of methane if
you compress and store it, but you may also have a threshold quantity in the head
space of the digester(s) and associated piping. To determine whether more than the
threshold quantity of 10,000 pounds is present in the head space and connected
piping, you must consider the total quantity of a flammable mixture containing a
regulated flammable substance, so you must estimate the total quantity of digester
gas, not just the quantity of methane in the gas, to determine whether you have a
threshold quantity. For digester gas that is about 70 percent methane, at pressures
not much above atmospheric pressure and temperatures of about 95 ° to 105 °F, you
may assume a density of approximately 0.06 pounds per cubic foot. The quantity of
digester gas can be estimated from the volume of the digester in cubic feet (the
overhead space and pipeline volume) as follows:
1
Quantity (pounds) = 0.06 pounds per cubic foot x Digester Volume (cubic feet)
]
j
For example, if the volume of digester gases in the head space and piping is 200,000
cubic feet, you would multiple 200,000 by 0.06; the quantity of digester gas is,
therefore, 12,000 pounds. The digester volume must be about 167,000 cubic feet or
more to contain a threshold quantity of flammable gas. At a methane percentage by
volume of 64 percent, the density would be 0.062 pounds per cubic foot.
If you have compressed digester gas, you may estimate the density by applying a
pressure factor as follows:
Density at pressure Y = 0.06 x Y (absolute pressure)/atmospheric pressure
If you have more accurate information about the composition and properties of the
digester gas, you may use this to develop a better estimate of the density of the gas
and the quantity. If you are not sure of the concentration of methane, you should use
70 percent as a conservative estimate.
j •
If the above calculations result in quantities close to the 10,000 pound threshold
quantity, you may use the following general equation:
M, =Vol x MW/379.5 x 520/(460+T) x (P)/14.7
j ,
where M, = total mass
MW = average molecular weight (Ibs/mole) including water vapor
T = operating .temperature (°F)
P = operating gauge pressure (psi)
1 psi = 27.7 inches water column
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Chapter 1
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Q&A
CHANGING INVENTORIES
Q. I am considering changing from 2 one-ton tanks of chlorine to ten 150-pound cylinders to reduce
my chlorine inventory below the RMP threshold quantity. Are there any reasons not to do this?
A. Reducing the inventory of regulated substances can be a sensible and appropriate risk-reduction
option in some circumstances, but before you decide to switch to multiple smaller chlorine
containers, you should carefully evaluate whether you might actually be increasing the risks to your
workers and potentially the public. Using smaller containers or using the same one-ton chlorine
tanks with a smaller quantity in each tank will require more frequent equipment connections and
handling of chlorine containers. Each time workers must unload, move, and connect tanks or
cylinders, there is an increased risk of a release. Also, 150-pound cylinder systems generally feed
gaseous chlorine under pressure, while one-ton tanks use a safer vacuum-feed system. It may be
easier, safer, and less costly in the long run to continue to use the larger containers that require less
frequent handling, while implementing the appropriate accident prevention measures required by the
rule. :
Sources are advised that their standing in relation to the thresholds set under part 68 does not affect
the applicability of the general duty clause under section 112(r)(l) of the Clean Air Act, which
applies to all facilities that handle extremely hazardous substances. • This clause creates a duty for the
owner or operator of a stationary source having extremely hazardous substances, which include
chlorine, "to identify hazards which may result from [accidental] releases..., to design and maintain a
safe facility, and to minimize the consequences of accidental releases which do occur." In view of
the increased potential for accidental releases that 150-pound cylinders may pose in some
circumstances, switching to such cylinders from safer one-ton tanks may raise questions as to
whether you have fulfilled your obligations under the general duty clause. The general duty clause is
already in effect, and EPA may take action to enforce it.
QUANTITY IN A PIPELINE
The maximum quantity in a pipeline will generally be the capacity of the pipeline
(volume). In most cases, pipeline quantity will be calculated and added to the
interconnected vessels. The quantity in a pipe can be calculated using the following
general equation:
V= TO2!,
Where V
r
L
Volume
Radius of the pipe
Length of the pipe.
INTERCONNECTED/CO-LOCATED VESSELS
If your process consists of two or more interconnected vessels, you must determine
the maximum quantity for each vessel and the connecting pipes or hoses. The
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General Applicability
1-14
maximum for each individual vessel and pipe is added together to determine the
maximum for the process.
!" ' |
<| „
If you have determined that you must consider co-located vessels as one process, you
must determine the maximum quantity for each vessel and sum up the quantities of
all such vessels.
•i - j
QUANTITY OF A SUBSTANCE IN A MIXTURE
TOXICS WITH LISTED CONCENTRATION
\
Four toxic substances have listed concentrations in the rule: hydrochloric acid -
percent or greater; hydrofluoric acid — 50 percent or greater; nitric acid — 80
percent or greater; and ammonia — 20 percent or greater.
•37
+ If you have these substances in solution and then- concentration is less than
the listed concentration, you do not need to consider them at all.
I
I '
4- If you have one of these four above their listed concentration, you must
determine the weight of the substance in the solution and use that to
calculate the quantity present. If that quantity is greater than the threshold,
the process is covered. For example, aqueous ammonia is covered at
concentrations above 20 percent, with a threshold quantity of 20,000 pounds.
If the solution is 25 percent ammonia, you would need 80,000 pounds of the
solution to meet the threshold quantity; if the solution is 44 percent
ammonia, you would need 45,455 pounds to meet the threshold quantity
(quantity of mixture x percentage of regulated substance = quantity of
regulated substance).
" 1 ', I " . !
Note that in a revision to part 68, EPA changed the concentration for hydrochloric
acid to 37 percent or greater (see Appendix A).
TOXICS WITHOUT A LISTED CONCENTRATION
I
For toxics without a listed concentration, if the concentration is less than one percent
you need not consider the quantity in your threshold determination. If the
concentration in a mixture is above one percent, you must calculate the weight of the
regulated substance in the mixture and use that weight to determine whether a
threshold quantity is present. However, if you can measure or estimate (and
document) that the partial pressure of the regulated substance in the mixture is less
than 10 mm Hg, you do not need to consider the mixture.
EPA treats toxic mixtures differently from OSHA. Under the OSHA PSM standard,
the entire weight of the mixture is counted toward the threshold quantity; under part
68, only the weight of the toxic substance is counted.
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1-15 General Applicability
FLAMMABLES
Flammable mixtures are subject to the rule only if there is a regulated substance in
the mixture above one percent and the entire mixture meets the NFPA-4 criteria. If
the mixture meets both of these criteria, you must use the weight of the entire
mixture (not just the listed substance) to determine if you exceed the threshold
quantity. The NFPA-4 definition is as follows:
"Materials that will rapidly or completely vaporize at atmospheric pressure and
normal ambient temperature or that are readily dispersed in air, and that will bum
readily. This degree usually includes: ',
4- Flammable gases ;
4- Flammable cryogenic materials
4- Any liquid or gaseous material that is liquid while under pressure and has a
flash point below 73 F (22.8 C) and a boiling point below 100 F (37.8 C)
(i.e., Class 1A flammable liquids)
4- Materials that will spontaneously ignite when exposed to air."
You do not need to consider gasoline, when in storage for use as fuel for internal
combustion engines when you determine the applicability of the rule.
EXCLUSIONS (§ 68.115)
The rule has a number of exclusions that allow you to ignore certain items that
contain a regulated substance when you determine whether a threshold quantity is
present. Most of these exclusions will not be relevant to WWTPs.
ARTICLES (§68.115(b)(4))
You do not need to include in your threshold calculations any manufactured item
defined at § 68.3 (as defined under 29 CFR 1910.1200(b)) that:
4- Is formed to a specific shape or design during manufacture,
4- Has end use functions dependent in whole or in part upon the shape or
design during end use, and
4- Does not release or otherwise result in exposure to a regulated substance
under normal conditions of processing and use.
This exclusion is unlikely to apply to WWTPs.
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Chapter 1
General Applicability
1-16
USES(§ 68.115(b)(5))
You also do not need to include regulated substances in your calculation when in use
for the following purposes:
l :.
+ Use as a structural component of the stationary source;
I
+ Use of products for routine janitorial maintenance;
+ Use by employees of foods, drugs, cosmetics, or other personal items
containing the regulated substances; and
Use of regulated substances present in process water or non-contact cooling
water as drawn from the environment or municipal sources, or use of
regulated substances present in air used either as compressed air or as part of
combustion.
ACTIVITIES IN LABORATORIES (§ 68.11 5(b)(6))
: ;•••••: : !
If a regulated substance is manufactured, processed, or used in a laboratory at a
stationary source under the supervision of a technically qualified individual (as
defined by § 720.3 (ee) of 40 CFR), the quantity of the substance need not be
considered in determining whether a threshold quantity is present. This exclusion
does not extend to:
October 27,1998
. ,
4- Specialty chemical production;
,!
4- Manufacture, processing, or use of siibstances in pilot plant scale operations;
and
+ Activities conducted outside the laboratory.
A technically qualified individual is "a person or persons (1) who, because of
education, training, or experience, or a combination of these factors, is capable of
understanding the health and environmental risks associated with the chemical
substance which is used under his or her supervision, (2) who is responsible for
enforcing appropriate methods of conducting scientific experimentation, analysis, or
chemical research to minimize such risks, and (3) who is responsible for the safety
assessments and clearances related to the procurement, storage, use, and disposal of
the chemical substance as may be appropriate or required within the scope of
conducting a research and development activity."
|
This exclusion is unlikely to apply to WWTPs because you probably will not have
more than a threshold quantity of a regulated substance in a lab.
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1-17
Chapter 1
General Applicability
1.6 STATIONARY SOURCE
The rule applies to "stationary sources" and each stationary source with one or more
covered processes must file an RMP that includes all covered processes.
SIMPLE SOURCES
For most WWTPs covered by this rule, determining what constitutes a "stationary
source" is simple. If you own or lease a property, your processes are contained
within the property boundary, and no other companies (or agencies) operate on the
property, then your stationary source is defined by the property boundary and covers
any process within the boundaries that has more than a threshold quantity of a
regulated substance. You must comply with the rule and file a single RMP for all
covered processes. If this description applies to you, you may skip the rest of this
section.
To belong to the same industrial group, either the operations at the site must be in the
same three-digit North American Industry Classification System (NAICS) code (the
equivalent of the old two-digit SIC codes), or one or more operations must be
considered support activities for the main operation. POTWs are in NAICS code
22132 (sewage treatment); other WWTPs may be in NAICS code 56221 (waste
treatment and disposal).
MULTIPLE OPERATIONS OWNED BY A SINGLE COMPANY
If the property is owned or leased by your company, but several separate operating
divisions of the company have processes at the site, the divisions' processes may be
considered a single stationary source because they are controlled by a single
company. Two factors will determine if the processes are to be considered a single
source: Are the processes located on one or more contiguous properties? Are all of
the operations in the same industrial group?
If your company does have multiple operations that are on the same property and are
in the same industrial group, each operating division may develop its prevention
program separately for its covered processes, but you must file a single RMP for all
covered processes at the site. You should note that this is different from the
requirements for filing under CAA Title V, and EPCRA section 313 (the annual
toxic release inventory), where each division could file separately if your company
chose to do so. '
OTHER SOURCES
There are situations where two or more separate companies occupy the same site.
The simplest of these cases is if multiple companies lease land at a site (e.g., an
industrial park). Each company that has covered processes must file an RMP that
includes information on its own covered processes at the site. You are responsible
for filing an RMP for any operations that you own or operate.
October 27,1998
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Chapter 1
General Applicability
1-18
Another possibility is that one company owns the land and operates there while
leasing part of the site to a second company. If both companies have covered
processes, each is considered a separate stationary source and must file separate
RMPs even if they have contractual relationships, such as supplying product to each
other or sharing emergency response functions.
,| '' ' ' " '
If you and another company jointly own a site, but have separate operations at the
site, you each must file separate RMPs for your covered processes. Ownership of
the land is not relevant; a stationary source consists of covered processes located on
the same property and controlled by a single owner.
MULTIPLE LOCATIONS
i
If you have multiple operations in the same area, but they are not on physically
connected land, you must consider them separate stationary sources and file separate
RMPs for each, even if the sites are connected by pipelines that move chemicals
among the sites. Remember, the rule applies to covered processes at a single
location.
> !
Exhibit 1-3 provides examples of stationary source decisions.
i
1.7 WHEN YOU MUST COMPLY
111 !J
' ' i
If you had a covered process prior to June 21,1999, you must comply with the
requirements of part 68 no later than June 21, 1999. This means that whenever a
process starts prior to June 21,1999, you must be in compliance with the rule on
June 21,1999. You must have developed and implemented all of the elements of the
rule that apply to each of your covered processes, and you must have submitted an
RMPtoEPA:
If the first time you have a covered process is after June 21, 1999, or you bring a new
process on line after that date, you must comply with part 68 no later than the date on
which you first have more than a threshold quantity of a regulated substance in a
process.
April 19,2000
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EXHIBIT 1-3: STATIONARY SOURCE
Schematic Representation
Description
interpretation
ABC Chemicals
General Chemicals Division
ABC Chemicals
Plastics Division
same owner
same industrial group
ABC Chemicals
Agricultural Chemicals Division
1 stationary source
1 RMP
ABC Chemicals
ABC Chemicals
two owners
XYZ Gases
2 stationary sources
2RMPs
1 ABC
1XYZ
ABC Chemicals
ABC Refinery
two owners
three industrial groups
XYZ Gases
3 stationary sources
1 ABC Chemicals
1 ABC Refinery
1 XYZ Gases
ABC Chemicals
two owners
ABC-MNO Joint-Venture
2 stationary sources
2RMPs
same owner
same industrial group
contiguous property
1 stationary source
1 RMP
Building owned by Brown Properties
Farm Chemicals Inc.
ABC
Chemicals
Brown Property offices
two owners
Pet Supply Storage
(no regulated substances)
2 stationary sources
2RMPs
1 ABC Chemicals
1 Farm Chemicals
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Chapter 1
General Applicability
1-20
QS & AS
COMPLIANCE DATES
Q. What happens if I bring a new covered process on line (e.g., install a second storage tank) after
June 21, 1999?
A. For a new covered process added after the initial compliance date, you must be in compliance on
the date you first have a regulated substance above the threshold quantity. There is no grace period.
You must develop and implement all the applicable rule elements and update your RMP before you
start operating the new process.
Q. What if EPA lists a new substance?
A. You will have three years from the date on which the new listing is effective to come into
compliance for any process that is covered because EPA has listed a new substance.
Q. What if I change a Program 2 process by adding new digester vessels, but do not change the
substances?
A. Because increasing the number of digester vessels is a major change to your Program 2 process,
you will have six months to come into compliance and update your RMP to reflect changes in your
prevention program elements and report any other changes.
Q. What if the quantity in the process fluctuates? I may not have a threshold quantity on June 21,
1999, but I will before then and after then.
A. You do not need to comply with the rule and file an RMP until you have more than threshold
quantity in a process; however, once you have more than threshold quantity in a process after June 21,
1999, you must be in compliance immediately. In this situation, with fluctuating quantities, it may be
prudent to file by June 21, 1999, so you will be in compliance when your quantity exceeds the
threshold.
Q. If we plan to switch chemicals in two years to non-regulated substances, do we have to comply by
June 1999 if we are still using chlorine.
A. Yes, if you have more than a threshold quantity of a regulated substance in a process on June 21,
1999, you must comply with the rule and file your RMP by to that date. When you make the switch,
if your facility as a whole is no longer covered, you should revise the registration on your RMP
within six months to notify EPA that your facility is not subject to the rule. If only the chlorine
process is no longer covered, you still must revise the RMP within six months.
October 27,1998
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CHAPTER 2: APPLICABILITY OF PROGRAM LEVELS
2.1 WHAT ARE PROGRAM LEVELS?
Once you have decided that you have one or more processes subject to this rule (see
Chapter 1), you need to identify what actions you must take to comply. The rule
defines three Program levels based on processes' relative potential for public
impacts, the level of effort needed to prevent accidents, and coverage by other
regulations. The Program levels are as follows: ;
Program 1: Processes with no public receptors within the distance to an
endpoint from a worst-case release and with no accidents with specific
offsite consequences within the past five years are eligible for Program 1,
which imposes limited hazard assessment requirements and minimal
prevention and emergency response requirements.
Program 2: Processes not eligible for Program 1 or subject to Program 3
are placed in Program 2, which imposes streamlined prevention program
requirements, as well as additional hazard assessment, management, and
emergency response requirements.
Program 3: Any process not eligible for Program 1 and subject to OSHA's
PSM standard under federal or state OSHA programs is subject to Program
3, which imposes OSHA's PSM standard (see section 2.5) as the prevention
program as well as additional hazard assessment, management, and
emergency response requirements.
If you can qualify a process for Program 1, it is in your best interests to do so, even if
the process is already subject to OSHA PSM. For Program 1 processes, the
implementing agency will enforce only the minimal Program 1 requirements. If you
assign a process to Program 2 or 3 when it might qualify for Program 1, the
implementing agency will enforce all the requirements of the higher program levels.
If, however, you are already in compliance with the prevention elements of Program
2 or Program 3, you may want to use the RMP to inform the community of your
prevention efforts.
See Exhibit 2-1 for a diagram of the decision rules on Program level.
KEY POINTS TO REMEMBER
In determining program level(s) for your process(es), keep in mind the following:
(1) Each process is assigned to a program level, which indicates the risk
management measures necessary to comply with this regulation for that
process, not the facility as a whole. The eligibility of one process for a
program level does not influence the eligibility of other covered processes
for other program levels.
October 26, 1998
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EXHIBIT 2-1
EVALUATE PROGRAM LEVELS FOR COVERED PROCESSES
Are public receptors
within the distance to
the endpoint for a
worst-case release?
Is the process
classified in one of the
listed NAICS codes?
Is the process
subject to the OSHA
PSM Standard?
Have offsite
impacts occurred due
to a release of a
regulated substance
from the process?
No->
Process
Subject to
Program
Level 2
No
1
Process
Eligible for
Program
Level 1
Process
Subject to
Program
Level 3
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2-3
Chapter 2
Applicability of Program Levels
(2) Any process that meets the criteria for Program 1 can be assigned to
Program 1, even, if it is subject to OSHA PSM or is in one of the NAICS
codes listed for Program 3.
(3) Program 2 is the default program level. There are no "standard criteria"
for Program 2. Any process that does not meet the criteria for either
Programs 1 or 3 is subject to the requirements for Program 2.
(4) Only one Program level can apply to a process. If a process consists of
multiple production or operating units or storage vessels, the highest
Program level that applies to any segment of the process applies to all parts.
Q&A
PROCESS AND PROGRAM LEVEL
Q. My process includes a series of interconnected units, as well as; several storage vessels that are
co-located. Several sections of the process could qualify for Program 1. Can I divide my process
into sections for the purpose of assigning Program levels?
A. No, you cannot subdivide a process for this purpose. The highest Program level that applies to
any section of the process is the Program level for the whole process. If the entire process is not
eligible for Program 1, then the entire process must be assigned to Program 2 or Program 3.
2.2 POTW PROGRAM LEVELS
Unlike private WWTPs, a POTW will determine its Program levels based, in part, on
the state in which it is located. If OSHA has delegated its programs to the state in
which your POTW is located, you are covered by OSHA standards under state law
(it is a condition of gaining delegation that the state apply OSHA rules to state and
local governments). Several states have not been granted delegation by federal
OSHA (listed in Exhibit 2-2). Some of these states have enacted legislation or
promulgated regulations that adopt the federal OSHA PSM standard and applied
them to state and local governments. If you are in one of these states, your process
will be in either Program 1 or Program 3. Alternatively, if you are in one of the
states without a delegated OSHA program and the state has not incorporated the
federal OSHA PSM standard by reference into state law or code, your processes will
be in either Program 1 or Program 2.
If you are in one of the states or territories with a delegated OSHA program (listed in
Exhibit 2-3), your processes will be in Program 1, if eligible; otherwise, processes
involving regulated toxics substances or digester gas production not used for fuel
will be in Program 3 because they are subject to OSHA PSM.
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Chapter 2
Applicability of Program Levels
2-4
EXHIBIT 2-2
FEDERAL OSHA STATES
Alabama
Arkansas
Colorado
Delaware
DC
Florida
Georgia
Idaho
Illinois
Kansas
Louisiana
Maine
Massachusetts
Missouri
Mississippi
Montana
Nebraska
New Hampshire
New Jersey
North Dakota
Ohio
Oklahoma
Pennsylvania
Rhode Island
South Dakota
Texas
West Virginia
Wisconsin
Some of these states may have incorporated OSHA PSM into state law or code and applied them to state
and local government.
,' ' i;<; • ^ . ! i|
EXHIBIT 2-3
STATES WITH DELEGATED OSHA PROGRAMS
Alaska
Arizona
California
Connecticut
Hawaii
Indiana
Iowa
Kentucky
Maryland
Michigan
Minnesota
Nevada
New Mexico
New York
North Carolina
Oregon
Puerto Rico
South Carolina
Tennessee
Utah
Vermont
Virginia
Virgin Islands
Washington
Wyoming
October 27,1998
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2-5
Chapter 2
Applicability of Program Levels
2.3 PROGRAM 1
WHAT ARE THE ELIGIBILITY REQUIREMENTS?
Your process is eligible for Program 1 if:
(1) There are no public receptors within a distance to an endpoint from a
worst-case release;
(2) The process has had no release of a regulated substance in the past five years
where exposure to the substance, its reaction products, overpressures
generated by explosion involving the substance, or radiant heat from a fire
involving the substance resulted in one or more offsite deaths, injuries, or
response or restoration activities for exposure of an environmental receptor;
and
(3) You have coordinated your emergency response activities with the local
responders. (This requirement applies to any covered process, regardless of
program level.)
See Exhibit 2-6 for the requirements for Program 1.
WHAT Is A PUBLIC RECEPTOR?
The rule (§ 68.3) defines public as "any person except an employee or contractor of
the stationary source." Consequently, employees of other facilities that may share
your site are considered members of the public even if they share the same physical
location. Being "the public," however, is not the same as being a public receptor.
Public receptors include "offsite residences, institutions (e.g., schools and
hospitals), industrial, commercial, and office buildings, parks, or recreational areas
inhabited or occupied by the public at any time without restriction by the stationary
source where members of the public could be exposed to toxic concentrations,
radiant heat, or overpressure, as a result of an accidental release." Offsite means
areas beyond your property boundary and "areas within the property boundary to
which the public has routine and unrestricted access during or outside business
hours."
The first step in identifying public receptors is determining what is "offsite." For
most facilities, that determination will be straightforward. If you restrict access to all
of your property all of the time, "offsite" is anything beyond your property
boundaries. Ways of restricting access include fully fencing the property, placing
security guards at a reception area or using ID badges to permit entry.
If you do not restrict access to a section of your property and the public has routine
and unrestricted access to it during or after business hours, that section would be
"offsite." For example, if your operations are fenced but the public has unrestricted
access to your'parking lot during or after business hours, the parking lot is "offsite."
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Chapter 2
Applicability of Program Levels
2-6
In the case of facilities such as hospitals, schools, and hotels that shelter members of
the public as part of their function or business, the parts of the facility that are used
to shelter the public would be "offsite."
11 • I '
Not all areas offsite are potential public receptors. The point of identifying public
receptors is to locate those places where there are likely to be, at least some of the
time, members of the public whose health could be harmed by short-term exposure to
an accidental release at your site. The basic test for identifying a public receptor is
thus whether an area is a place where it is reasonable to expect that members of the
public will routinely gather at least some of the time.
The definition of "public receptor" itself specifies the types of areas where members
of the public may routinely gather at least some of the time: residences, institutions
such as hospitals and schools, buildings in general, parks and recreational areas.
There should be little difficulty in identifying residences, institutions and businesses
as such, and virtually any residence, institution and business will qualify as a public
receptor, even when the properly is used only seasonally (as in a vacation home).
Notably, a residence includes its yard, if any, and an institution or business includes
its grounds to the extent that employees or other members of the public are likely to
routinely gather there at least some of the time for business or other purposes (see
discussion of recreational areas below). The only circumstances that would justify
not considering such a property a public receptor would be where your facility owns
or controls the property and restricts access to it, or no member of the public inhabits
or occupies it at any time. Where a hospital, school, or other entity that provides
public shelter is itself subject to the part 68 rule, it will be its own public receptor
except for those areas where members of the public are not allowed to go at any
time.
Buildings other than residences, institutions or businesses are also highly likely to
qualify as public receptors since the function of most buildings is at least in part to
shelter people. Accordingly, toll booth plazas, transit stations, and airport terminals
would qualify as public receptors. For a building not to qualify as a public receptor,
one of the circumstances mentioned above would have to apply.
, !'" ' !j '
". ,, '."',"]
Every designated park or recreational area, or at least some portion thereof, is apt to
be a public gathering place by virtue of facilities made available to the public (e.g.,
visitors' center, playground, golf course, camping or picnic area, marina or ball field)
or attributes that members of the public routinely seek to use (e.g., beach). It does not
matter whether use of such facilities is seasonal; routine use for at least part of the
year would qualify the area as a public receptor.
At the same time, some portion of a designated park or recreational area may not be
a public receptor. For instance, a large state or national park may include relatively
inaccessible tracts of land that do not contain public facilities or receive routine use.
Occasional hiking, camping or hunting in such areas would not qualify the areas as
public receptors.
October 26,1998
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2-7
Chapter 2
Applicability of Program Levels
Qs & As
PUBLIC RECEPTORS
Q. My processes are fenced, but my offices and parking lot for customers are not restricted. What is
considered offsite? What is considered a public receptor? ;
A. The unrestricted areas would be considered offsite. However, they would not be public receptors
because you are responsible for the safety of those who work in or visit your offices and because
parking lots are not generally public receptors.
Q. What is considered a recreational area?
A. Recreational areas would include land that is designed, constructed, designated, or used for
recreational activities. Examples are national, state, county, or city parks, other outdoor recreational
areas such as golf courses or swimming pools and bodies of waters (oceans, lakes, rivers, and
streams) when used by the public for fishing, swimming, or boating. Public and private areas that are
predictably used for hunting, fishing, bird watching, bike riding, hiking, or camping or other
recreational use also would be considered recreational areas. EPA encourages you to consult with
land owners, local officials, and the community to reach an agreement on an area's status; your local
emergency planning committee (LEPC) can help you with these consultations. EPA recognizes that
some judgment is involved in determining whether an area should be considered a recreational area.
Q. Does public receptor cover only buildings on a property or the entire property? If the owner of
the land next to my site restricts access to the land, is it still a public receptor?
A. Public receptors are not limited to buildings. For example, if there are houses near your property,
both the houses and their yards are considered public receptors because it is likely that residents will
be present in one or the otter at least some of the time, and, in fact, people are likely to be in more
danger if they are outside when a release occurred. The ability of others to restrict access to an area
does not change its status as a public receptor. You need to consider whether that land is generally
unoccupied. If the land is undeveloped or rarely has anyone on it, it is not a public receptor. If you
are not sure of the land's use of occupancy, you should talk with the landowner and the community
about its status. Because it is the landowner and members of the local community who are likely to
be affected by your decision, you should involve them in the decision is you have doubts.
An area need not be designated a recreational area to be one in fact. If an area is
routinely used for recreational purposes, even if only seasonally, it is a recreational
area for purposes of the part 68 rule. For example, a marina may not bill itself as a
"recreational area," but if a marina houses recreational boats, it qualifies as a public
receptor. Further, if your facility or a neighboring property owner allows the public
to make routine recreational use of some portion of land (e.g., a ball field or fishing
pond), that portion of land would qualify as a public receptor.
Roads and parking lots are not included as such in the definition of "public
receptor." Neither are places where people typically gather; instead they are used to
October 26, 1998
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Chapter 2
Applicability of Program Levels
2-8
travel from one place to another or to park a vehicle while attending an activity
elsewhere. However, if a parking lot is predictably and routinely used as a place of
business (e.g., a farmer's market) or for a recreational purpose (e.g., a county fair), it
would qualify as a public receptor.
In general, farm land would not be considered a public receptor. However, if farm
land, or a portion thereof, is predictably and routinely occupied by farm workers or
other members of public, even if only on a seasonal basis, that portion of the land
would be a public receptor.
If you are in doubt about whether to consider certain areas around your facility as
public receptors, you should consult with the relevant local officials and land owners
and your implementing agency for guidance.
.. . i . .
WHAT IS A DISTANCE TO AN ENDPOINT FROM A WORST-CASE RELEASE?
'!' , , ", ' , ,!! !| " „' ' '! '
In broad terms, the distance to an endpoint is the distance a toxic vapor cloud, fire, or
explosion from an accidental release will travel before dissipating to the point that
serious injuries from short-term exposures will no longer occur. The rule establishes
"endpoints" for each regulated substance and defines the circumstances of a
worst-case release scenario (e.g., scenario, weather, release rate and duration) (see
Chapter 4 or the RMP Offsite Consequence Analysis Guidance for more
information). You will have to define a worst-case release (usually the loss of the
total contents of your largest vessel) for each Program 1 process and either use EPA's
guidance or conduct modeling on your own to determine the distance to the endpoint
for that worst-case release. Beyond that endpoint, the effects on people are not
considered to be severe enough to merit the need for additional action under this
rule. ' ......
, , .. • | , .
;i
To define the area of potential impact from the worst-case release, draw a circle on a
map, using the process as the center and the distance to the endpoint as the radius. If
there are public receptors within that area, your process is not eligible for Program 1.
ACCIDENT HISTORY
To be eligible for Program 1, no release of the regulated substance from the process
can have resulted in one or more offsite deaths, injuries, or response or restoration
activities at an environmental receptor during the five years prior to submission of
your RMP. A release of the regulated substance from another process has no bearing
on whether the first process is eligible for Program 1.
October 26,1998
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2-9
Chapter 2
Applicability of Program Levels
Q and A
Determining Distances
Q. Our distance to the endpoint for the worst-case release is 0.3 miles. The nearest public receptor
is 0.32 miles away. What tools are available to document that the public receptor is beyond the
distance to the endpoint so we can qualify for Program 1 ?
A. The results of any air dispersion model (from EPA's guidance documents or other models) are
not precise predictions. They represent an estimate, but the actual distances to the endpoint could be
closer to or farther from the point of release. If your distance to the endpoint and distance to a public
receptor are so close that you cannot document, using a USGS map, that the two points are different,
it would be advisable to comply with the higher Program level. (The most detailed maps available
from the US Geological Survey (scale of 1:24,000) are not accurate enough to map the distances you
cite and document that the two points (which are about 100 feet apart) differ. GPS systems now have
a margin of error of 22 meters (about 0.014 miles or 72 feet); if you are using a GPS system, you
may be able to document that these points are different.)
WHAT is AN INJURY?
An injury is defined as "any effect on a human that results either from direct
exposure to toxic concentrations; radiant heat; or overpressures from accidental
releases or from the direct consequences of a vapor cloud explosion (such as flying
glass, debris, and other projectiles) from an accidental release." The effect must
"require medical treatment or hospitalization." This definition is taken from the
OSHA regulations for keeping employee injury and illness logs and should be
familiar to most employers. Medical treatment is further defined as "treatment,
other than first aid, administered by a physician or registered professional personnel
under standing orders from a physician." The definition of medical treatment will
likely capture most instances of hospitalization. However, if someone goes to the
hospital following direct exposure to a release and is kept overnight for observation
(even if no specific injury or illness is found), that would qualify as hospitalization
and so would be considered an injury.
WHAT is AN ENVIRONMENTAL RECEPTOR?
The environmental receptors you need to consider are limited to natural areas such as
national or state parks, forests, or monuments; officially designated wildlife
sanctuaries, preserves, refuges, or areas; and Federal wilderness areas. All of these
areas can be identified on local U.S. Geological Survey maps.
WHAT ARE RESTORATION AND RESPONSE ACTIVITIES?
The type of restoration and response activity conducted to address the impact of an
accidental release will depend on the type of release (volatilized spill, vapor cloud,
fire, or explosion), but may include such activities as:
October 26, 1998
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Chapter 2
Applicability of Program Levels
2-10
ilantlife;
Collection and disposal of dead animals and contaminated p.
4- Collection, treatment, and disposal of soil;
4- Shutoff of drinking water;
4- Replacement of damaged vegetation; or
4- Isolation of a natural area due to contamination associated with an accidental
release.
Q&A
ENVIRONMENTAL RECEPTORS
Q. Do environmental receptors include areas that are not Federal Class I areas under the CAA?
A. Yes. The list of environmental receptors in Part 68 includes areas in addition to those that qualify
as Federal Class I areas under CAA section 162. Under Part 68, national parks, monuments,
wilderness areas, and forests are environmental receptors regardless of size. State parks, monuments,
and forests are also environmental receptors.
DOCUMENTING PROGRAM 1 ELIGIBILITY
For every Program 1 process at your facility, you must keep records documenting the
eligibility of the process for Program 1. For each Program 1 process, your records
should include the following:
4- A description of the worst-case release scenario, which must specify the
vessel or pipeline and substance selected as worst case, assumptions and
parameters used, and the rationale for selection. Assumptions may include
use of any administrative controls and any passive mitigation that were
assumed to limit the quantity that could be released;
.I
4- Documentation of the estimated quantity of the worst-case release, release
rate, and duration of release;
•I
4- The methodology used to determine distance to endpoints;
I
4- Data used to determine that no public receptor would be affected; and
r ,. i
4- Information on your coordination with public responders.
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2-11
Chapter 2
Applicability of Program Levels
Qs&As
ACCIDENT HISTORY
Q. What is the relationship between the accident history criteria for Program 1 and the five-year
accident history? If my process is eligible for Program 1, do I still need to do a five-year accident
history?
A. The five-year accident history is an information collection requirement that is designed to
provide data on all serious accidents from a covered process involving a regulated substance held
above the threshold quantity.
In contrast, the Program 1 accident history criteria focus on whether the process in question has
the potential to experience a release of the regulated substance that results in harm to the public
based on past events. Onsite effects, shelterings-in-place, and evacuations that have occurred must
be reported in the five-year accident history, but they are not considered in determining Program 1
eligibility. Therefore, it is possible for process to be eligible for Program 1 and still have
experienced a release that must be reported in the accident history for the source.
Q. A process with more than a threshold quantity of a regulated substance had an accident with
offsite consequences three years ago. After the accident, we altered the process to reduce the
quantity stored on site. Now the worst-case release scenario indicates that there are no public
receptors within the distance to an endpoint. Can this process qualify for Program 1 ?
A. No, the process cannot qualify for Program 1 until five years have passed since any accident
with consequences that disqualify a process for Program 1.
Q. A process involving a regulated substance had an accidental release with offsite consequences
two years ago. The process has been shut down. Do I have to report anyway?
A. No. The release does not have to be included in your accident history. Your risk management
plan only needs to address operating processes that have more "than a threshold quantity of a
regulated substance.
2.4 QUICK RULES FOR DETERMINING PROGRAM 1 ELIGIBILITY
You generally will not be able to predict with certainty that the worst-case scenario
for a particular process will meet the criteria for Program 1. Processes containing
certain substances, however, may be more likely than others to be eligible for
Program 1, and processes containing certain other substances may be very unlikely
to be eligible for Program 1 because of the toxiciry and physical properties of the
substances. The information presented below may be useful in identifying processes
that may be eligible for Program 1.
October 26,1998
-------
'Mil1'!"'"T
Ell .'•
HI
Chapter 2
Applicability of Program Levels
2-12
Toxic GASES
If you have a process containing more than a threshold quantity of chlorine,
ammonia, or sulfur dioxide or any other regulated toxic gas that is not liquefied by
refrigeration alone (i.e., you hold it as a gas or liquefied under pressure), the distance
to the endpoint estimated for a worst-case release of the toxic gas will generally be
several miles. As a result, the distance to endpoint is unlikely to be less than the
distance to public receptors, unless the process is very remote. In some cases,
however, toxic gases in processes in enclosed areas may be eligible for Program 1.
REFRIGERATED Toxic GASES
If you have a process containing anhydrous ammonia liquefied by refrigeration
alone, and your worst-case release would take place into a diked area, the chances
are good that the process may be eligible for Program 1, unless there are public
receptors very close to the process. Even if you have many times the threshold
quantity of ammonia., the process may still be eligible for Program 1.
„ ]|
The worst-case analysis for a process containing chlorine liquefied by refrigeration is
unlikely to show eligibility for Program 1, unless your site is extremely remote from
the public or the release would occur within an enclosure.
Toxic LIQUIDS
The distance to an endpoint for a worst-case release involving toxic liquids kept
under ambient conditions may be smaller than the distance to public receptors in a
number of cases. If public receptors are not found very close to me process (within
5^ mile), the process may be eligible for Program 1. However, facilities on small
acreage sites are highly unlikely to meet to be eligible for Program 1 if they are in a
developed area. Remotely located facilities or processes found near the center of
large (acreage) sites are more likely to be eligible.
l
WATER SOLUTIONS OF TOXIC SUBSTANCES
j
The list of regulated substances includes several common water solutions of toxic
substances. Processes containing such solutions (e.g., aqueous ammonia) at ambient
temperatures may be eligible for Program 1 (depending hi some cases on the
concentration of the solution), if spills would be contained in diked areas and public
receptors are not located close to the process (within Vz mile). As noted above,
facilities on small acreage sites in developed areas are highly unlikely to be eligible
for Program 1; remotely located facilities or processes found near the center of large
acreage sites are more likely to be eligible.
.I
FLAMMABLE SUBSTANCES
Many processes containing regulated flammable substances are likely to be eligible
for Program 1, unless there are public receptors within a very short distance. If you
have a process containing up to about 20,000 pounds (twice the threshold quantity)
October 26,1998
_
-------
2-13
Chapter 2
Applicability of Program Levels
of methane, your process is likely to be eligible for Program 1 if you have no public
receptors within about 400 yards (1,200 feet) of the process. If you have up to
100,000 pounds in a process (ten times the threshold quantity), the process may be
eligible for Program 1 if there are no public receptors within about 700 yards (2,000
feet). In general, it would be worthwhile to conduct a worst-case analysis for any
processes containing only flammables to determine Program 1 eligibility, unless you
have public receptors very close to the process. Consequently, you may have to
conduct more worst-case analyses if you want to qualify processes for Program 1; for
Program 2 and 3 processes, you need analyze only one worst-case release scenario to
cover all flammables. For Program 1, you must be able to demonstrate, through your
worst-case analysis, that every process you claim.is Program 1 meets the criteria.
Remember that the Program level designation for a process is based on the regulated
substance that has the greatest distance to an endpoint. If your digesters are
considered part of a process that includes chlorine, ammonia, or sulfur dioxide, the
toxics will determine whether the process is eligible for Program 1 because the
distances to an endpoint will be greater for the toxics.
2.5 PROGRAM 3
Any covered process that is not eligible for Program 1 and is subject to OSHA PSM
under federal or state law is subject to Program 3 requirements, which include risk
management measures and requirements virtually identical to the OSHA PSM
Standard. (The other criterion for Program 3 (§ 68.10(d)(l)) does not apply to
WWTPs.)
WHAT is THE OSHA PSM STANDARD?
The OSHA Process Safety Management standard (codified at 29 CFR 1910.119) is a
set of procedures in thirteen management areas designed to protect worker health and
safety in case of accidental releases. Similar to EPA's rule, OSHA PSM applies to a
range of facilities that have more than a threshold quantity of a listed substance in a
process. All processes subject to this rule and the OSHA PSM standard (federal or
state) and not eligible for Program 1 are assigned to Program 3 because the Program
3 prevention program is virtually identical to the elements of the PSM standard. If
you are already complying with OSHA PSM for a process, you probably will need to
take few, if any, additional steps and develop little, if any, additional documentation
to meet the requirements of the Program 3 prevention elements (see Chapter 7 for a
discussion of differences between Program 3 prevention and OSHA PSM). EPA
placed all covered OSHA PSM processes in Program 3 to eliminate the possibility of
imposing overlapping, inconsistent requirements on the same process.
Private WWTPs are likely to be subject to OSHA PSM for processes containing
more than a threshold quantity of chlorine, anhydrous ammonia, or sulfur dioxide.
POTWs in states with delegated OSHA programs or in non-state-plan states that
have adopted the PSM standard to cover state and local governments are subject to
the PSM standard if they have more than a threshold quantity of these substances.
March 22, 1999
-------
I" , II 'ill.""1! ,1"! Will!!;!!!!1 ri'l'lll
ISvUlli!1 l|i>, PH1 '' II!!! ." .U",
Chapter 2
Applicability of Program Levels
2-14
OSHA's thresholds are generally lower than EPA's so it is possible that you may
have a process that is subject to OSHA PSM and is not covered by part 68. For
example, if you store a single, one-ton cylinder of chlorine, OSHA PSM will cover it
because it has a 1,500 pound threshold for chlorine, but EPA's part 68 will not
because its threshold quantity for chlorine is 2,500 pounds.
OSHA PSM covers aqueous ammonia at a concentration of greater than 44 percent
(as opposed to EPA's 20 percent or greater); therefore, your aqueous ammonia
process may not be subject to OSHA PSM.
i
2.6 PROGRAM 2
Program 2 is considered a default program level because any covered process that is
not eligible for Program 1 or assigned to Program 3 is, by default, subject to Program
2 requirements, including a streamlined accident prevention program. One or more
processes at your facility are likely to be in Program 2 if:
4- You are a publicly owned facility in a state that does not have a delegated
OSHA program, and the state has not incorporated the OSHA PSM standard
by reference into state law or code.
. . • • |
+ You use aqueous ammonia in solutions with greater than 20 percent
concentration but less than 44 percent concentration.
+ You use regulated acids in solution in activities.
4- You store regulated liquid flammable substances in atmospheric storage
tanks.
1
The last two of these conditions are unlikely to apply to WWTPs.
WHAT ARE THE ELIGIBILITY CRITERIA FOR PROGRAM 2?
Your process is subject to Program 2 if:
+ Your process does not meet the eligibility requirements for Program 1; and
" ! , II!!'' '
+ Your process is not subject to OSHA PSM (state or federal).
'• . I..
When determining what program level is appropriate for your covered process, keep
in mind that if it does not meet the Program 1 criteria and it is not covered by OSHA
PSM, the process automatically is subject to Program 2 requirements.
Exhibit 2-4 provides a summary of the criteria for determining Program level.
,11
April 19,2000
-------
2-15
Chapter 2
Applicability of Program Levels
EXHIBIT 2-4
PROGRAM LEVEL CRITERIA
Program 1
No accidents in the previous five
years that resulted in any offsite:
Death
Injury
Response or restoration
activities at an
environmental receptor
" '- * ,"-* AND ' v \
No public receptors in worst-case
circle.
- ,. * *, AND * > ~
Emergency response coordinated
with local responders.
Program 2
The process is not eligible for
Program 1 or subject to Program 3.
' -> *•"•' <•
0 * "~ *, *"
Program 3
Process is not eligible for Program
1.
' - \ AND1''* '" '« •"
Process is subject to OSHA PSM.
-••• * ~V$C "' » '
Process is classified in NAICS code
32211 Pulp mills
3241 1 Petroleum refineries
32511 Petrochemical
manufacturers*
325181 Alkalies and chlorine
325188 Industrial inorganic
chemicals (not elsewhere
classified)*
325192 Other cyclic crudes and
intermediates*
325199 Industrial organic
chemicals (not elsewhere
classified)*
32521 1 Plastics materials and resins
3253 1 1 Nitrogenous fertilizers
32532 Agricultural chemicals (not
elsewhere classified)
2.7 DEALING WITH PROGRAM LEVELS
WHAT IF I HAVE MULTIPLE PROGRAM LEVELS?
If you have more than one covered process, you may be dealing with multiple
program levels in your risk management program.
If your facility has processes subject to different program levels, you will need to
comply with different program requirements for different processes. Nevertheless,
you must submit a single RMP for all covered processes.
March 22, 1999
-------
Chapter 2
Applicability of Program Levels
2-16
If you prefer, you may choose to adopt the most stringent applicable program level
requirements for all covered processes. For example, if you have three covered
processes, one eligible for Program 1 and two subject to Program 3, you may find it
administratively easier to follow the Program 3 requirements for all three covered
processes. Remember, though, that this is only an option; we expect that most
sources will comply with the set of program level requirements for which each
process is eligible.
QS&AS
OSHA
Q. If my state administers the OSHA program under a delegation from the federal OSHA, does that
mean that my processes that are subject to OSHA PSM under the state rules are in Program 3?
A. Yes, as long as the process does not qualify for Program 1. Any process subject to PSM, under
federal or state rules, is considered to be in Program 3 unless it qualifies for Program 1.
Q. I am a publicly owned facility in a state with a delegated OSHA program. Why are my processes
considered to be in Program 3 when the same processes in a state where federal OSHA runs the
program are in Program 2?
A. Federal OSHA cannot impose its rules on state or local governments, but when OSHA delegates
its program to a state for implementation, the state imposes the rules on itself and local governments.
Because these governments are complying with the identical OSHA PSM rules imposed by federal
OSHA, they are subject to Program 3. In meeting their obligations under state OSHA rules, they are
already substantially in compliance with the Program 3 prevention program requirements. In several
non-state-plan states, the states have adopted the federal OSHA PSM standard through legislation or
regulation and have applied the standard to state and local governments. Again, because these
governments are complying with the identical OSHA PSM rules imposed by federal OSHA, facilities
will be subject to Program 3. Finally, in non-state-plan states in. which the state has not incorporated
federal OSHA standards by reference in state law or code, state and local governments are not subject
to any OSHA PSM rules and must comply with Program 2.
CAN THE PROGRAM LEVEL FOR A PROCESS CHANGE?
i
A change in a covered process or in the surrounding community can result in a
change in the Program level of the process. If this occurs, you must submit an
updated RMP within six months of the change that altered the program level for the
covered process. If the process no longer qualifies as a covered process (e.g., as a
result of a change in the quantity of the regulated substance in the process), then you
will need to amend your RMP registration within six months (see Chapter 9 for more
information). Typical examples of switching program levels include:
-------
2-17
Chapter 2
Applicability of Program Levels
MOVING UP
From Program 1 to Program 2 or 3. You have a covered process subject to
Program 1 requirements. A new residential development results in public receptors
being located within the distance to the endpoint for a worst-case release for that
process. The process is, thus, no longer eligible for Program 1 and must be
evaluated to determine whether Program 2 or Program 3 applies. You must submit a
revised RMP within six months of the program level change, indicating and
documenting that your process is now in compliance with the new program level
requirements.
From Not Covered to Program 1,2 or 3. You have a process that was not
originally covered by part 68, but, due to an expansion in production, the process
holds an amount of regulated substance that now exceeds the threshold quantity.
You must determine which Program level applies and come into compliance with the
rule by June 21, 1999, or by the time you exceed the threshold quantity, whichever is
later.
From Program 2 to Program 3. You have a process that involves a regulated
substance above the threshold that had not been subject to OSHA PSM. However,
due to one of the following OSHA regulatory changes, the process is now subject to
the OSHA PSM standard:
+ Your state is granted delegation by federal OSHA to implement OSHA
standards in your state;
+ Your state enacts legislation or promulgates regulations adopting the federal
OSHA PSM standard by reference and they are applicable to you; or.
4- The regulated substance has been added to OSHA's list of highly hazardous
substances (this is unlikely for WWTPs because the chemicals you use are
already subject to PSM).
As a result, the process becomes subject to Program 3 requirements and you must
submit a revised RMP to EPA within six months, indicating and documenting that
your process is now in compliance with the Program 3 requirements.
SWITCHING DOWN
From Program 2 or 3 to Program 1. At the time you submit your RMP, you have a
covered process subject to Program 2/3 requirements because it experienced an
accidental release of a regulated substance with offsite impacts four years ago.
Subsequent process changes have made such an event unlikely (as demonstrated by
the worst-case release analysis). One year after you submit your RMP, the accident
will no longer be included in the five-year accident report for the process, so the
process is eligible for Program 1. If you elect to qualify the process for Program 1,
you must submit a revised RMP within six months of the program level change,
April 19, 2000
-------
Chapter 2
Applicability of Program Levels
2-18
indicating and documenting that the process is now in compliance with the new
program level requirements.
From Program 2 or 3 to Not Covered. You have a covered process that has been
subject to Program 2 or 3 requirements, but due to a reduction in production, the
amount of a regulated substance it holds no longer exceeds the threshold. Therefore,
the process is no longer a covered process. You must submit a revised RMP within
six months indicating that your process is no longer subject to any program level
requirements.
•' ! • - i • • ' ' • ' . .: ••' i'' ' •' : . :..!
2.8 SUMMARY OF PROGRAM REQUIREMENTS
Regardless of the program levels of your processes, you must complete a five-year
accident history for each process (see Chapter 3) and submit an RMP that covers all
processes (see Chapter 9). Depending on the Program level of each of your
processes, you must comply with the additional requirements described below.
Exhibit 2-5 diagrams the requirements in general and Exhibit 2-6 lists them in more
detail.
PROGRAM 1
For each Program 1 process, you must conduct and document a worst-case release
analysis. You must coordinate your emergency response activities with local
responders and sign the Program 1 certification as part of your RMP submission.
PROGRAMS 2 AND 3
For all Program 2 and 3 processes, you must conduct and document at least one
worst-case release analysis to cover all toxics and one to cover all flammables. You
may need to conduct additional worst-case release analyses if worst-case releases
from different parts of your facility would affect different public receptors. You
must also conduct one alternative release scenario analysis for each toxic and one for
all flammables. See Chapter 4 or the RMP Offsite Consequence Analysis Guidance
for specific requirements. You must coordinate your emergency response activities
with local responders and, if you use your own employees to respond to releases, you
must develop and implement an emergency response program. See Chapter 8 for
more details.
i'
For each Program 2 process, you must implement all of the elements of the Program
2 prevention program: safety information, hazard review, operating procedures,
training, maintenance, compliance audits, and incident investigations. See Chapter 6
for more details.
For each Program 3 process, you must implement all of the elements of the Program
3 prevention program: process safety information, process hazard analysis, standard
operating procedures, training, mechanical integrity, compliance audits, incident
investigations, management of change, pre-startup reviews, contractors, employee
participation, and hot work permits. See Chapter 7 for more details.
April 19,2000
I if,,', n',1 ,)!.!!»
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-------
EXHIBIT 2-5
DEVELOP RISK MANAGEMENT PROGRAM AND RMP
Program Level 1
Process
Program Level 2
Process
Program Level 3
Process
Conduct and document
worst-case release
analysis
Conduct and document
worst-case release
analysis
Conduct and document
alternative release
analysis
Prepare Five-Year
Accident History
Prepare Five-Year
Accident History
Implement
Management System
Implement Program
Level 2 Prevention
Program
Implement Program
Level 3 Prevention
Program
Implement Emergency
Response Program
(if applicable)
Coordinate with Local Responders
Prepare and Submit One Risk Management Plan for all Covered Processes
-------
Chapter 2
Applicability of Program Levels
2-20
EXHIBIT 2-6
COMPARISON OF PROGRAM REQUIREMENTS
Program 1
Worst-case release analysis
5-year accident history
Program 2
Worst-case release analysis
Alternative release analysis
5-year accident history
Document management system
Program 3
Worst-case release analysis
Alternative release analysis
5-year accident history
Document management system
Prevention Program
Certify no additional prevention
steps needed
Safety Information
Hazard Review
Operating Procedures
Training
Maintenance
Incident Investigation
Compliance Audit
Process Safely Information
Process Hazard Analysis.
Operating Procedures
Training
Mechanical Integrity
Incident Investigation
Compliance Audit
Management of Change
Pre-Startup Review
Contractors
Employee Participation
Hot Work Permits
Emergency Response Program
Coordinate with local
responders
Develop plan and program (if
applicable) and coordinate with
local responders
Develop plan and program (if
applicable) and coordinate with
local responders
Submit One Risk Management Plan for All Covered Processes
October 27,1998
-------
CHAPTER 3: FIVE-YEAR ACCIDENT HISTORY
The five-year accident history involves an examination of the effects of any
accidental releases of one or more of the regulated substances from a covered
process in the five years prior to the submission of a Risk Management Plan (RMP).
A five-year accident history must be completed for each covered process, including
the processes in Program 1, and all accidental releases meeting specified criteria
must be reported in the RMP for the process.
Note that a Program 1 process may have had an accidental release that must be
included in the five-year accident history, even though the release does not disqualify
the process from Program 1. The accident history criteria mat make a process
ineligible for Program 1 (certain offsite impacts) do not include other types of effects
that require inclusion of a release in the five-year accident history (on-site impacts
and more inclusive offsite impacts). For example, an accidental release may have
led to worker injuries, but no other effects. This release would not bar the process
from Program 1 (because the injuries were not offsite), but would need to be
reported in the five-year accident history. Similarly, a release may have resulted in
damage to foliage offsite (environmental damage), triggering reporting, but because
the foliage was not part of an environmental receptor (e.g., national park or forest) it
would not make the process ineligible for Program 1.
3.1 WHAT ACCIDENTS MUST BE REPORTED?
The five-year accident history covers only certain releases:
4- The release must be from a covered process and involve a regulated
substance held above its threshold quantity in the process.
+ The release must have caused at least one of the following:
> On-site deaths, injuries, or significant property damage (§68.42(a));
or
> Known offsite deaths, injuries, property damage, environmental
damage, evacuations, or sheltering in place (§68.42(a)).
If you have had a release of a regulated substance from a process where the regulated
substance is held below its threshold quantity, you do not need to report that release
even if the release caused one of the listed impacts or if the process is covered for
some other substance. You may choose to report the release in the five-year accident
history, but you are not required to do so.
3.2 WHAT DATA MUST BE PROVIDED?
The following information should be included in your .accident history for every
reported release. The descriptions below correspond to the RMP* Submit system
being developed and to data element instructions for the system:
January 22,1999
-------
Chapters
Five-Year Accident History
3-2
Date. Indicate the date on which the accidental release began.
Time. Indicate the time the release began.
, ':,!':" ! il' "
Release duration. Indicate the approximate length of time of the release in
minutes.
Chemical(s). Indicate the regulated substance(s) released. Use the name of the
substance as listed in § 68.130 rather than a synonym (e.g., propane rather than
LPG). If the release was of a flammable mixture, list the primary regulated
substances in the mixture if feasible; if the contents of the mixture are uncertain, list
it as a flammable mixture. If non-regulated substances were also released and
contributed to the impacts, you may want to list them as well, but you are not
required to do so.
•. . - |
Quantity released. Estimate the amount of each substance released in pounds. The
amount should be estimated to two significant digits, or as close to that as possible.
For example, if you estimate that the release was between 850 and 900 pounds,
provide a best guess. We realize that you may not know precise quantities. For
flammable mixtures, you may report the quantity of the mixture, rather than that of
the individual regulated substances.
!
Release event. Indicate which of the following release events best describes your
accident. Check all that apply:
4- Gas Release. A gas release is a release of the substance as a gas (rather than
vaporized from a liquid). If you hold a gas liquefied under refrigeration,
report the release as a liquid spill.
I , :"
4- Liquid Spill/ Evaporation. A liquid, spill/evaporation is a release of the
substance in a liquid state with subsequent vaporization.
',.]', • ', .
4- Fire. A fire is combustion producing light, flames, and heat.
4- Explosion. An explosion is a rapid chemical reaction with the production of
noise, heat, and violent expansion of gases.
!! ' '• '•
Release source. Indicate all that apply.
I
4- Storage Vessel. A storage vessel is a container for storing or holding gas or
liquid. Storage vessels include transportation containers being used for
on-site storage.
, j , , ,
4- Piping. Piping refers to a system of tubular structures or pipes used to carry
a fluid or gas.
4- Process Vessel. A process vessel is a container in which substances under
certain conditions (e.g., temperature, pressure) participate in a process (e.g.,
January 22,1999
-------
3-3
Chapter 3
Five-Year Accident History
substances are manufactured, blended to form a mixture, reacted to convert
them into some other final product or form, or heated to purify).
>• Transfer Hose. A transfer hose is a tubular structure used to connect, often
temporarily, two or more vessels.
+ Valve. A valve is a device used to regulate the flow in piping systems or
machinery. Relief valves and rupture disks open to release pressure in
vessels.
+ Pump. A pump is a device that raises, transfers, or compresses fluids or that
attenuates gases by suction or pressure or both.
+ Joint. The surface at which two or more mechanical components are united.
+ Other. Specify other source of the release.
Weather conditions at time of event (if known). This information is important to
those concerned with assessing and modeling the effects of accidents. Reliable
information from those involved in the incident or from an on-site weather station is
ideal. However, this rule does not require your facility to have a weather station. If
you do not have an onsite weather station, use information from your local weather
station, airport, or other source of meteorological data. Historical wind speed and
temperature data (but not stability data) can be obtained from the National Climatic
Data Center (NCDC) at (828) 271-4800; NCDC staff can also provide information
on the nearest weather station. To the extent possible, complete the following:
+ Wind Speed and Direction. Wind speed is an estimate of how fast the wind
is traveling. Indicate the speed in miles per hour. Wind direction is the
direction from which the wind comes. For example, a wind that blows from
east to west would be described as having an eastern wind direction. You
may describe wind direction as a standard compass reading such as
"Northeast" or "South-southwest."
You may also describe wind direction in degrees—with North as zero degrees
and East as 90 degrees. Thus, northeast would represent 45 degrees and
south-southwest would represent 202.5 degrees. Abbreviations for the wind
direction such as NE (for northeast) and SSW (for south-southwest) are also
acceptable.
+ Temperature. The ambient temperature at the scene of the accident in
degrees Fahrenheit. If you did not keep a record, you can use the high (for
daytime releases) or low (for nighttime releases) for the day of the release.
Local papers publish these data.
4- Stability Class. Depending on the amount of incoming solar radiation as
well as other factors, the atmosphere may be more or less turbulent at any
given time. Meteorologists have defined six atmospheric stability classes,
January 22, 1999
-------
Chapters
Fiye-Year Accident History
3-4
each representing a different degree of turbulence in the atmosphere. When
moderate to strong incoming solar radiation heats air near the ground,
causing it to rise and generating large eddies, the atmosphere is considered
unstable, or relatively turbulent. Unstable conditions are associated with
stability classes A and B. When solar radiation is relatively weak, air near
the surface has less of a tendency to rise and less turbulence develops. In
this case, the atmosphere is considered stable or less turbulent with weak
winds. The stability class is E or F. Stability classes D and C represent
conditions of neutral stability or moderate turbulence respectively. Neutral
conditions are associated with relatively strong wind speeds and moderate
solar radiation. The neutral category D should be used, regardless of wind
speed, for overcast conditions day or night, and for any conditions during the
hour preceding or following the night (one hour before sunset to one hour
after dawn). Exhibit 3-1 presents the stability classes associated with wind
speeds, time of day, and cloud cover.
Precipitation Present. Precipitation may take the form of hail, mist, rain,
sleet, or snow. Indicate "yes" or "no" based on whether there was any
precipitation at the time of the accident.
+ Unknown. If you have no record for some or all of the weather data, indicate
"unknown" for any missing item. We realize that you may not have weather
data for accidents that occurred in the past. You should, however, collect
these data for any future accidents.
"1
On-site impacts. Complete the following about on-site effects.
••• ' :\ •;; |
+ Deaths. Indicate the number of on-site deaths that are attributed to the
accident or mitigation activities. On-site deaths means the number of
employees, contract employees, offsite responders, or others (e.g., visitors)
who were killed by direct exposure to toxic concentrations, radiant heat, or
overpressures from accidental releases or from indirect consequences of a
vapor cloud explosion from an accidental release (e.g., flying glass, debris,
other projectiles). You should list employee/contractor, offsite responder,
and other on-site deaths separately.
+ Injuries. An injury is any effect that results either from direct exposure to
toxic concentrations, radiant heat, or overpressures from accidental releases
or from indirect consequences of a vapor cloud explosion (e.g., flying glass,
debris, other projectiles) from an accidental release and that requires medical
treatment or hospitalization. You should list injuries to employees and
contractors, offsite responders, and others separately.
January 22, 1999
-------
3-5
Chapter 3
Five-Year Accident History
EXHIBIT 3-1
ATMOSPHERIC STABILITY CLASSES
SUBKAO; WMD SPIED J-i
AT 10 METSEt&^BOVE ' ;;
- " " ' .QK09IKD 1
Meters per
second
<2
2-3
3-5
5-6
>6
Miles per
hour
<4.5
4.5-7
7-11
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Medical treatment means treatment, other than first aid, administered by a
physician or registered professional personnel under standing orders from a
physician.
Your OSHA occupational injury and illness log (200 Log) will help
complete these items for employees.
+ Property Damage. Estimate the value of the equipment or business
structures (for your business alone) that were damaged by the accident or
mitigation activities. Record the value in American dollars. Insurance
claims may provide this information. Do not include any losses that you
may have incurred as a result of business interruption.
Known offsite impacts. These are impacts that you know or could reasonably be
expected to know of (e.g., from media reports or from reports to your facility) that
occurred as a result of the accidental release. You are not required to conduct an
additional investigation to determine offsite impacts.
January 22, 1999
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Chapter 3
Five-Year Accident History
3-6
Q&A
PROPERTY DAMAGE
Q. What level of offsite property damage triggers reporting?
A. Any level of known offsite property damage triggers inclusion of the accident in the five-year
accident history. You are not required to conduct a survey to determine if such damage occurred, but
if you know, or could reasonably be expected to know (e.g., because of reporting in the newspapers),
that damage occurred, you must include the accident.
Deaths. Indicate the number of offsite deaths that are attributable to the
accident or mitigation activities. Offsite deaths means the number of people
offsite who were killed by direct exposure to toxic concentrations, radiant
heat, or overpressures from accidental releases or from indirect
consequences of a vapor cloud explosion from an accidental release (e.g.,
flying glass, debris, other projectiles).
Injuries. Indicate the number of injuries among people offsite. Injury means
any effect that results either from direct exposure to toxic concentrations,
radiant heat, or overpressures from accidental releases or from indirect
consequences of a vapor cloud explosion from an accidental release (e.g.,
flying glass, debris, other projectiles) and that requires medical treatment or
hospitalization.
Evacuated. Estimate the number of people offsite who were evacuated to
reduce exposure that might have resulted from the accident. A total count of
the number of people evacuated is preferable to the number of houses
evacuated. People who were ordered to move simply to improve access to
the site for emergency vehicles are not considered to have been evacuated.
Sheltered. Estimate the number of people offsite who were
sheltered-in-place during the accident Sheltering-in-place occurs when
community members are ordered to remain inside their residence or place of
work until the emergency is over to reduce exposure to the effects of the
accidental release. Usually these orders are communicated by an emergency
broadcast or similar method of mass notification by response agencies.
• 11 •. ,, • : ,! lit I1 .; '• i!1 • .i 'i . i I in,1 ' : '',!'!!
Environmental Damage. Indicate whether any environmental damage
occurred and specify the type. The damage to be reported is not limited to
environmental receptors listed in the rule. Any damage to the environment
(e.g., dead or injured animals, defoliation, water contamination) should be
identified. You are not, however, required to conduct surveys to determine
whether such impact occurred. Types of environmental damage include:
ij
' ' . ' . " i ''
> Fish or animal kills.
January 22,1999
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3-7
Chapter 3
Five-Year Accident History
> Lawn, shrub, or crop damage minor defoliation.
> Lawn, shrub, or crop damage major defoliation.
> Water contamination.
> Other (specify).
Initiating event. Indicate the initiating event that was the immediate cause of the
accident, if known. If you conducted an investigation of the release, you should have
identified the initiating event.
4- Equipment Failure. A device or piece of equipment failed or did not
function as designed. For example, the vessel wall corroded or cracked.
4- Human Error. An operator performed a task improperly, either by failing to
take the necessary steps or by taking the wrong steps.
4- Weather Conditions. Weather conditions, such as lightning, hail, ice storms,
tornados, hurricanes, floods, earthquakes, or high winds, caused the
accident.
4- Unknown.
Contributing factors. These are factors that contributed to the accident, but were
not the initiating event. If you conducted an investigation of the release, you may
have identified factors that led to the initiating event or contributed to the severity of
the release. Indicate all that apply. ;
4 Equipment Failure. A device or piece of equipment failed to function as
designed, thereby allowing a substance leading to or worsening the
accidental release.
4 Human error. An operator performed an operation improperly or made a
mistake lead to or worsened the accident.
4 Improper Procedures. The procedure did not reflect the proper method of
operation, the procedure omitted steps that affected the accident, or the
procedure was written in a manner that allowed for misinterpretation of the
instructions.
4 Overpressurization. The process was operated at pressures exceeding the
design working pressure.
4 Upset Condition. Incorrect process conditions (e.g., increased temperature
or pressure) contributed to the release.
January 22, 1999
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Chapter 3
Five-Year Accident History
3-8
By-pass Condition. A failure occurred in a pipe, channel, or valve that
diverts fluid flow from the main pathway when design process or storage
conditions are exceeded (e.g., overpressure). By-pass conditions may be
designed to release the substance to restore acceptable process or storage
conditions and prevent more severe consequences (e.g., explosion).
Maintenance Activity/Inactivity. A failure occurred because of maintenance
activity or inactivity. For example, the storage racks remained unpainted for
so long that corrosion caused the metal to fail.
Process Design. A failure resulted from an inherent flaw in the design of the
process (e.g., pressure needed to make product 'exceeds the design pressure
of the vessel).
Unsuitable Equipment. The equipment used was incorrect for the process.
For example, the forklift was too large for the corridors.
Unusual Weather Conditions. Weather conditions, such as lightning, hail,
ice storms, tornados, hurricanes, floods, earthquakes, or high winds
contributed to the accident.
Management Error. A failure occurred because management did not
exercise its managerial control to prevent the accident from occurring. This
is usually used to describe faulty procedures, inadequate training, inadequate
oversight, or failure to follow existing administrative procedures.
Whether offsite responders were notified. If known, indicate whether response
agencies (e.g., police, fire, medical services) were contacted.
Changes introduced as a result of the accident. Indicate any measures that you
have taken at the facility to prevent recurrence of the accident. Indicate all that
apply.
Improved/ Upgraded Equipment. A device or piece of equipment that did
not function as designed was repaired or replaced.
Revised Maintenance. Maintenance procedures were clarified or changed to
ensure appropriate and timely maintenance including inspection and testing
(e.g., increasing the frequency of inspection or adding a testing method).
Revised Training. Training programs were clarified or changed to ensure
that employees and contract employees are aware of and are practicing
correct safety and administrative procedures.
Revised Operating Procedures. Operating procedures were clarified or
changed to ensure that employees and contract employees are trained on
appropriate operating procedures.
January 22,1999
*
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3-9
Chapter 3
Five-Year Accident History
4- New Process Controls. New process designs and controls were installed to
correct problems and prevent recurrence of an accidental release.
4- New Mitigation Systems. New mitigation systems were initiated to limit the
severity of accidental releases.
4- Revised Emergency Response Plan. The emergency response plan was
revised.
4- Changed Process. Process was altered to reduce the risk (e.g., process
chemistry was changed).
4- Reduced Inventory. Inventory was reduced at the facility to reduce the
potential release quantities and the magnitude of the hazard.
4- Other.
4- None. No changes initiated at facility as a result of the accident (e.g.,
because none were necessary or technically feasible). There may be some
accidents that could not have been prevented because they were caused by
events that are too rare to merit additional steps. For example, if a tornado
hit your facility and you are located in an area where tornados are very rare,
it may not be reasonable to design a "tornado proof process even if it is
technically feasible.
3.3 OTHER ACCIDENT REPORTING REQUIREMENTS
You should already have much of the data required for the five-year accident history
because of the reporting requirements under the Comprehensive Emergency
Response, Compensation, and Liability Act (CERCLA), EPCRA, and OSHA (e.g.,
log of occupational injuries and illnesses). This information should minimise the
effort necessary to complete the accident history.
At the same time, some of the information originally reported to response agencies
may have been inaccurate because it was reported during the release when a full
assessment was not possible. It is imperative that you include the most accurate,
up-to-date information possible in the five-year accident history. This information
may not always match the original estimates from the initial reporting of the
accident's effects.
CERCLA Section 103(V) requires you to immediately notify the National Response
Center if your facility releases a hazardous substance to the environment in greater
than a reportable quantity (see 40 CFR part 302). Toxic substances regulated under
part 68 are also CERCLA hazardous substances, but most of the flammable
substances regulated under part 68 are not subject to CERCLA reporting. Notice
required under CERCLA includes the following information:
The chemical name or identity of any substance involved in the release
January 22, 1999
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Chapters
Five-Year Accident History
3-10
i .11
An indication of whether the substance is on the list referred to in Section
302(a)
An estimate of the quantity of substance that was released into the
environment
The time and duration of the release
The medium or media into which the release occurred.
Releases reported to the National Response Center are collected into a database, the
Emergency Response Notification System (ERNS). ERNS data are available on
EPA's web site: http://www.epa.gov.
EPCRA Section 304 requires facilities to report to the community emergency
coordinator of the appropriate local emergency planning committee (LEPC) and state
emergency response commission (SERC) releases of extremely hazardous substances
to the environment in excess of reportable quantities (as set forth in 40 CFR part
302). All toxic substances regulated under part 68 are subject to EPCRA reporting;
flammables regulated under part 68 are generally not subject to EPCRA reporting.
The report required by EPCRA is to include:
;. i , , .. ..... i
i • - ,:i- , ' i" - r. . ' . .' I
+ Chemical name or identity of all substances involved in the accident
+ An estimate of the quantity of substances released to the environment
4- The time and duration of the release.
The owner or operator is also required to release a Follow-up Emergency Notice as
soon as possible after a release which requires notification. This notice should
update the previously released information and include additional information
regarding actions taken to respond to the release, any known or anticipated acute or
chronic health risks associated with the release, and where appropriate, advice
regarding medical attention necessary for exposed individuals.
OSHA's log of occupational injuries and illnesses. OSHA No. 200, is used for
recording and classifying recordable occupational injuries and illnesses, and for
noting the extent and outcome of each case. The log shows when the occupational
injury or illness occurred, to whom, what the injured or ill person's regular job was at
the time of the injury or illness exposure, the department in which the person was
employed, the kind of injury or illness, how much time was lost, and whether the
case resulted in a fatality, etc. The following are the sections of the illness/ injury log
that are useful in completing the accident history.
Descriptive section of the log:
Column B: date of work accident which resulted in injury
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Chapter 3
3-11 Five-Year Accident History
4- Column C: name of injured person
4- Column F: description of nature of injury or illness
Injury portion of the log:
4- Column 1: date of death is entered if an occupational injury results in a
fatality
4- Column 6: an injury occurred, but did not result in lost workdays
Dlness portion of the log:
4- Column 7: for occupational illnesses, an, entry is placed in one of the
columns 7a-7g, depending upon which column is applicable.
PART 68 INCIDENT INVESTIGATION
An incident investigation is a requirement of the rule (§68.60 and 68.81). These
requirements are virtually identical to the requirements under OSHA PSM. For
accidents involving processes categorized in Program 2 or Program 3, you must
investigate each incident which resulted in, or could reasonably have resulted in, a
catastrophic release of a regulated substance. A report, which includes the following
information, should be prepared at the conclusion of the investigation:
4- Date of incident
4- Date investigation began
4- Description of the incident
4- Factors that contributed to the incident !
4- Any recommendations resulting from the investigation.
Because the incident investigation report must be retained for five years, you will
have a record for completing the five-year accident history for updates of the RMP.
January 22, 1999
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Chapters
Five-Year Accident History
3-12
QS&AS
ACCIDENT HISTORY
Q. When does the five-year period to be reported in the accident history begin?
A. The five-year accident history must include all accidental releases from covered processes
meeting the specified criteria that occurred in five years preceding the date the RMP for the
processes was submitted. For example, if an RMP is submitted on June 1, 1999, the five-year
accident history must cover the period between June 1, 1994 and June 1, 1999.
Q. If a facility has recently changed ownership, is the new facility owner required to include
accidents which occurred prior to the transfer of ownership in the accident history portion of the
RMP submitted for the facility?
A. Yes, accidents involving covered processes that occurred prior to the transfer of ownership
should be included in the five-year accident history. You may want to explain that the ownership has
changed in your Executive Summary.
Q. If I have a large on-site incident, but no offsite impact, would I have to report it in the five-year
accident history?
A. It would depend on whether you have onsite deaths, injuries, or significant property damage.
You could have a large accident without any of these consequences (e.g., a large spill that was
contained); this type of release would not have to be included in the five-year accident history.
Q. I had a release where several people were treated at the hospital and released; they attributed their
symptoms to exposure. We do not believe that their symptoms were in fact the result of exposure to
the released substance. Do we have to report these as offsite impacts?
A. Yes, you should report them in your five-year accident history. You may want to use the
executive summary to state that you do not believe that the impacts can be legitimately attributed to
the release and explain why.
January 22,1999
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CHAPTER 4: OFFSITE CONSEQUENCE ANALYSIS
You are required to conduct an offsite consequence analysis to provide information
to the government and the public about the potential consequences of an accidental
chemical release at your facility. The offsite consequence analysis (OCA) consists
of two elements:
4 A worst-case release scenario and
4 Alternative release scenarios.
To simplify the analysis and ensure a common basis for comparisons, EPA has
defined the worst-case scenario as the release of the largest quantity of a regulated
substance from a single vessel or process line failure that results in the greatest
distance to an endpoint. In broad terms, the distance to the endpoint is the distance a
toxic vapor cloud, heat from a fire, or blast waves from an explosion will travel
before dissipating to the point that serious injuries from short-term exposures will no
longer occur. '.
This chapter gives guidance on how to perform the OCA for the six regulated
substances that are used or produced at WWTPs:
4- Chlorine (toxic)
4- Sulfur dioxide (toxic)
4 Anhydrous ammonia (toxic) :
4 Aqueous ammonia (20 percent or greater, toxic)
4 Methane (digester gas, flammable)
Exhibit 4-1 shows the basic steps used to conduct the OCA.
RMP*Comp™
To assist those using this guidance, the National Oceanic and Atmospheric Administration (NOAA)
and EPA have developed a software program, RMP*Comp™, that performs the calculations
described in this document. This software can be downloaded from the EPA website at
http://www.epa.gov/swercepp/tools/nnp-comp/rmp-comp.html.
The methodology and reference tables of distances presented here are optional.
You are not required to use this guidance. You may use publicly available or
proprietary air dispersion models to do your offsite consequence analysis, subject to
certain conditions. If you choose to use other models, you should review the rule
and Chapter 4 of the General Guidance for Risk Management Programs, which
outline required conditions for use of other models.
April 19,2000
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EXHIBIT 4-1
STEPS FOR OFFSITE CONSEQUENCE ANALYSIS
Gather Basic Data
(quantities and process conditions)
Select Scenario
toxics
Worst-case and Alternative Release
Flammabies
Alternative Release
Flammabies
Worst-case Release
Estimate Rate of
Release
Define Distance to Endpoint of Concern
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4-3
Chapter 4
OfFsite Consequence Analysis
Some of the results obtained using the methods in this document may be
conservative (i.e., they may overestimate the distance to endpoints). Complex
models that can account for many site-specific factors may give less conservative
estimates of offsite consequences than the simple methods used in this guidance.
This is particularly true for alternative scenarios, for which EPA has not specified
many assumptions. However, complex models may be expensive and require
considerable expertise to use; this guidance is designed to be simple and
straightforward. You will need to consider these tradeoffs in deciding how to carry
out your required consequence analyses.
This chapter presents discussions and tables for the worst-case scenario for all six
substances listed above (section 4.1), followed by discussions and tables for
alternative scenarios for the six substances (section 4.2). Because many WWTPs
store chlorine and sulfur dioxide in buildings, section 4.3 discusses methods for
estimating the mitigating effects of buildings. The remaining sections provide
guidance on defining offsite impacts (section 4.4), documentation (section 4.5), and
the symbols used in the chapter (section 4.6).
The guidance presented in this chapter is intended for users — that is, it does not
contain any explanations of how the guidance was derived. Those readers who are
interested in obtaining an explanation can obtain from EPA a document entitled
Backup Information for the Hazard Assessments in the RMP Offsite Consequence
Analysis Guidance, the Guidance for Wastewater Treatment Facilities and the
Guidance for Ammonia Refrigeration—Anhydrous Ammonia, Aqueous Ammonia,
Chlorine and Sulfur Dioxide.
4.1 WORST-CASE RELEASE SCENARIOS
This section provides guidance on how to analyze worst-case scenarios. Information
is provided on the general requirements of the regulations, followed by specific
sections on chlorine, sulfur dioxide, anhydrous ammonia, aqueous ammonia, and
methane. Exhibit 4-2 presents the parameters that must be used in worst-case and
alternative release scenarios.
GENERAL REQUIREMENTS FOR Toxic SUBSTANCES
The following information is required for worst-case release analysis of toxic
substances:
The worst-case release quantity Q (Ib) is the greater of the following:
+ For substances in vessels, the greatest amount held in a single vessel, taking
into account administrative controls that limit the maximum quantity; or
+ For substances in pipes, the greatest amount in a pipe, taking into account
administrative controls that limit the maximum quantity.
For vessels, you need only consider the largest amount in the vessel, regardless of
interconnections with pipes and other vessels. Similarly, if the largest quantity is
contained in a pipe, you need not add the quantity in vessels at the end of the
October 27, 1998 '
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; Chapter 4
Offsite Consequence Analysis
4-4
October 27,1998
jf'
, .'sill
pipelines. You may be able to think of scenarios in which a quantity greater than Q
as defined above can be released, but EPA does not require you to model such
scenarios as worst-case (you may want to consider modeling them as alternative
scenarios).
Weather conditions. The rule allows anyone who conducts his or her OCA based on
this guidance to use specific default weather conditions for wind speed, stability
class, average temperature, and humidity. Liquids other than gases liquefied by
refrigeration should be considered to be released at the highest daily maximum
temperature, based on local data for the previous three years, or at process
temperature, whichever is the higher. You can obtain weather data from local
weather stations. You can also obtain temperature and wind speed data from the
National Climatic Data Center at (828) 271-4800.
For the worst-case scenario, the release must be assumed to take place at ground
level.
The toxic endpoints are:
Ammonia
Chlorine
Sulfur Dioxide
0.14 mg/L (200 ppm)
0.0087 mg/L (3 ppm)
0.0078 mg/L (3 ppm)
These airborne concentrations are the maximum airborne concentrations below
which it is believed that nearly all individuals can be exposed for up to one hour
without experiencing or developing irreversible or other serious health effects or
symptoms which could impair an individual's ability to take protective action.
The regulations require you to take account of whether your site is rural or urban.
The regulations state that "urban means that there are many obstacles in the
immediate area; obstacles include buildings or trees. Rural means that there are no
buildings in the immediate area and the terrain is generally flat or unobstructed."
Some areas outside of cities may still be considered urban if they are forested.
The regulations require you to use tables or models for atmospheric dispersion
analysis that appropriately account for gas density. For the specific case of WWTPs,
chlorine and sulfur dioxide are always dense gases (that is, denser than air).
Anhydrous ammonia, if released from the liquid space of a container in which it is
liquefied under pressure, forms a denser-than-air vapor cloud. Ammonia evaporating
from a pool of aqueous ammonia is treated as neutrally buoyant (that is, it has about
the same density as air).
You are only allowed to take account of passive mitigation systems, not active ones.
Passive mitigation systems could include:
4- Diked areas that confine a liquid pool and reduce the surface area available
for evaporation
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4-5
Chapter 4
Offsite Consequence Analysis
EXHIBIT 4-2
REQUIRED PARAMETERS FOR MODELING (40 CFR 68.22)
WORST CASE
ALTERNATIVE SCENARIO
Endpoints (§68.22(a))
Toxic endpoints are listed in part 68 Appendix A.
For flammable substances, endpoint is overpressure of 1
pound per square inch (psi) for vapor cloud explosions.
Toxic endpoints are listed in part 68 Appendix A.
+For flammable substances, endpoint is overpressure of 1 psi for
vapor cloud explosions
4-Radiant heat level of 5 kilowatts per square meter (kW/m2) for
40 seconds for heat from fires (or equivalent dose)
4-Lower flammability limit (LFL) as specified in NFPA
documents or other generally recognized sources for vapor cloud
fires.
Wind speed/stability (§68.22(b))
This guidance assumes 1.5 meters per second and F
stability. For other models, use wind speed of 1.5
meters per second and F stability class unless you can
demonstrate that local meteorological data applicable to
the site show a higher minimum wind speed or less
stable atmosphere at all times during the previous three
years. If you can so demonstrate, these minimums may
be used for site-specific modeling.
This guidance assumes wind speed of 3 meters per second and D
stability. For other models, you may use typical meteorological
conditions for your site.
Ambient temperature/humidity (§68.22(c))
This guidance assumes 25 °C (77 °F) and 50 percent
humidity. For other models for toxic substances, you
must use the highest daily maximum temperature and
average humidity for the site during the past three years.
This guidance assumes 25 °C and 50 percent humidity. For other
models, you may use average temperature/humidity data gathered
at the site or at a local meteorological station.
Height of release (§68.22(d))
For toxic substances, you must assume a ground level
release.
This guidance assumes a ground-level release. For other models,
release height may be determined by the release scenario.
Surface roughness (§68.22(e))
Use urban (obstructed terrain) or rural (flat terrain)
topography, as appropriate.
Dense or neutrally buoyant gases (§68.22(f))
Tables or models used for dispersion of regulated toxic
substances must appropriately account for gas density.
Use urban (obstructed terrain) or rural (flat terrain) topography, as
appropriate.
Tables or models used for dispersion must appropriately account
for gas density.
Temperature of released substance (§68.22(g))
You must consider liquids (other than gases liquefied by
refrigeration) to be released at the highest daily
maximum temperature, from data for the previous three
years, or at process temperature, whichever is higher.
Assume gases liquefied by refrigeration at atmospheric
pressure to be released at their boiling points.
Substances may be considered to be released at a process or
ambient temperature that is appropriate for the scenario.
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Chapter 4
Offsite Consequence Analysis
4-6
4- Buildings, provided that the building can be shown to withstand the events
that caused the release (see Section 4.3 for more information)
Active mitigation systems include:
4- Automatically closing or remotely operated valves
„' 4- Sprays and deluge systems
4- Relief valves
4- Check valves
4- Excess flow valves
4- Scrubbers
The predicted frequency of occurrence of the worst-case scenario is not an allowable
consideration. You are not required to determine a possible cause of the failure of
the vessel or pipe.
GENERAL REQUIREMENTS FOR FLAMMABLE SUBSTANCES
As for toxic substances, the worst-case release quantity Q is either the greatest
amount held in a single vessel or the greatest amount in a pipe. In both cases, you
may take into account administrative controls that limit the maximum capacity. In
the case of the vessel, you need only take into account the quantity in the vessel,
regardless of any connections with other vessels.
j
The worst-case analysis assumes the quantity vaporizes. There is a vapor cloud
explosion. If you use a TNT-equivalent model to determine the distance to the
endpoint, you must assume that 10 percent of the total quantity is involved in the
explosion (that is, the yield factor is 10 percent).
You must determine the distance to the explosion endpoint; that is, the distance at
which there is an overpressure of 1 psi (the farthest distance from the point of release
at which the explosion causes the pressure on a person or building to exceed
atmospheric pressure by 1 psi).
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Chapter 4
Offsite Consequence Analysis
CHLORINE
At WWTPs, chlorine is most likely to be present in 150-lb cylinders, in one-ton
(2,000-lb) cylinders, in 17-ton tank trucks, or in 90-ton railcars. The worst-case
scenario assumes that these quantities are completely released over a period of 10
minutes (e.g., a 150-lb worst case corresponds to a 15-lb/minrate of release). The
predicted distances to the toxic endpoint for each of these scenarios is given in
Exhibit 4-3. These distances are for releases that are assumed to take place outdoors.
See Section 4.3 for a discussion on buildings.
EXHIBIT 4-3
DISTANCES TO TOXIC ENDPOINTS - CHLORINE
F Stability, Wind Speed 1.5 Meters per Second
Scenario
150-lb cylinder
1-ton cylinder
17-ton tank trucks
90-ton railcar
Release Rate
(Ib/min)
15
200
3,400
18,000
Distance to Toxic Endpoint (miles)
Rural
0.8
3.0
12
>25
Urban
0.4
1.3
5.8
14
If your facility does not fit into the standard pattern of 150-lb cylinders, one-ton
cylinders, 17-ton tank trucks, or 90-ton railcars, you should use Figure 4-1 or
Exhibit 4-4. Identify the chlorine vessel that contains the largest quantity of any in
your facility and divide that mass by 10 to obtain the release rate in Ib/min. Look for
that release rate, or the rate nearest to it, hi Exhibit 4-4. Then read across to the rural
or urban distances.
Alternatively, look along the bottom axis of Figure 4-1, read up to the curve(s) and
then across to the corresponding distances on the vertical axis.
As noted above, the results presented hi Exhibit 4-3 and 4-4 are for a release that is
outside. Many of you will keep your chlorine vessels inside buildings. Some will
even have specially designed, leak-tight buildings with chlorine or sulfur dioxide
scrubbers. However, the intention of this section is to provide information on the
worst-case scenario. There are times when you will be handling the cylinders
outside. Nevertheless, in discussions with local agencies and local communities you
may well want to explain how your facility is designed to prevent or mitigate worst-
case scenarios.
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Chapter 4
OffsJte Consequence Analysis
4-8
EXHIBIT 4-4
DISTANCES TO TOXIC ENDPOINT FOR CHLORINE
F Stability, Wind Speed 1.5 Meters per Second
Release Rate
(Ibs/min)
1
2
5
10
15
20
30
40
50
60
70
80
90
100
150
200
250
300
400
500
600
700
Distance to Endpoint (miles)
Rural
0.2
0.3
0.5
0.7
0.8
1.0
1.2
1.4
1.5
1.7
1.8
1.9
2.0
2.2
2.6
3.0
3.4
3.7
4.2
4.7
5.2
5.6
Urban
0.1
0.1
0.2
0.3
0.4
0.4
0.5
0.6
0.6
0.7
0.8
0.8
0.9
0.9
1.2
1.3
1.5
1.6
1.9
2.1
2.3
2.5
Release Rate
(Ibs/miii)
750
800
900
1,000
1,500
2,000
2,500
3,000
4,000
5,000
6,000
7,000
7,500
8,000
9,000
10,000
15,000
20,000
25,000
30,000
40,000
50,000
Distance to Endpoint (miles)
Rural
5.8
5.9
6.3
6.6
8.1
9.3
10
11
13
14
16
17
18
18
19
20
25
*
*
*
*
*
Urban
2.6
2.7
2.9
3.0
3.8
4.4
4.9
5.4
6.2
7.0
7.6
8.3
8.6
8.9
9.4
9.9
12
14
16
18
20
*
* Ivlore than 25 miles (report distance as 25 miles)
These are results that you can simply quote when you submit your RMP.
October 27,1998
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l
-------
4-9
Chapter 4
Offsite Consequence Analysis
SULFUR DIOXIDE
Sulfur dioxide, if present at a WWTP, is also likely to be in 150-lb cylinders, one-ton
cylinders, 17-ton tank cars, or 90-ton railcars. The worst-case scenario assumes that
these quantities are completely released over a period of 10 minutes. The predicted
distances to the toxic endpoint for each of these scenarios is given in Exhibit 4-5.
EXHIBIT 4-5
DISTANCES TO TOXIC ENDPOINT - SULFUR DIOXIDE
F Stability, Wind Speed 1.5 Meters per Second
Scenario
150-lb cylinder
1-ton cylinder
1 7-ton tank tracks
90-ton railcar
Release Rate
Ob/min)
15
200
3,400
18,000
Distance to Toxic Endpoint (miles)
Rural
0.7
3.1
15
>25
Urban
0.3
1.3
6.0
15
These are results that you can simply quote when you submit your RMP.
If your facility does not fit into the standard pattern of 150-lb cylinders, one-ton
cylinders, or 90-ton railcars, you should use Figure 4-2 or Exhibit 4-6. Identify the
sulfur dioxide vessel that contains the largest quantity of any in your facility. Divide
that quantity by 10 to obtain the release rate in Ib/min and look for that rate, or the
rate nearest to it, on Exhibit 4-6. Then read across to the rural or urban distances.
Alternatively, use Figure 4-2.
October 27, 1998
-------
Chapter 4
Qffsite Consequence Analysis
4-10
EXHIBIT 4-6
DISTANCES TO TOXIC:ENDPOINT FOR SULFUR DIOXIDE
F Stability, Wind Speed 1.5 Meters per Second
Release Rate
(Ibs/min)
1
2
5
10
15
20
30
40
50
60
70
80
90
100
150
200
250
300
400
500
600
700
Distance to Endpoint (miles)
Rural
0.2
0.2
0.4
0.6
0.7
0.9
1.1
1.3
1.4
1.6
1.8
1.9
2.0
2.1
2.7
3.1
3.6
3.9
4.6
5.2
5.8
6.3
Urban
0.1
0.1
0.2
0.2
0.3
0.4
0.5
0.5
0.6
0.7
0.7
0.8
0.8
0.9
1.1
1.3
1.4
1.6
1.9
2.1
2.3
2.5
* More than 25 miles (report distance as 25 miles)
Release Rate
(Ibs/min)
750
800
900
1,000
1,500
2,000
2,500
3,000
4,000
5,000
6,000
7,000
7,500
8,000
9,000
10,000
15,000
20,000
25,000
30,000
40,000
50,000
Distance to Endpoint (miles)
Rural
6.6
6.8
7.2
7.7
9.6
11
13
14
17
19
21
23
24
25
*
*
*
*
*
*
*
*
Urban
2.6
2.7
2.9
3.1
3.8
4.5
5.0
5.6
6.5
7.3
8.1
8.8
9.1
9.5
10
11
13
16
18
19
23
*
October 27,1998
-------
4-11
Chapter 4
Offsite Consequence Analysis
ANHYDROUS AMMONIA
In WWTPs, anhydrous ammonia is generally stored as a liquid under pressure in
vessels that are kept outdoors. These vessels are;relatively large (e.g., 10,000 gallons
or ~ 56,000 Ib) . Identify the quantity of ammonia in your storage vessel and divide
by 10 to obtain the release rate in Ib/min. Look for that release rate, or the release
rate nearest to it, on Exhibit 4-7. Then read across to the rural or urban distances.
Alternatively, use Figure 4-3.
The 10,000-gallon vessel mentioned above contains 56,000 Ib when full. (You may
take into account any administrative controls that limit the quantity of the ammonia
in the vessel. For example, you will generally require that the vessel never be filled
above 85 percent of its total volume to allow for the high coefficient of volumetric
expansion of ammonia.) Assuming for the sake of the present example that 56,000
Ib is the greatest quantity of ammonia that will eyer be in the vessel, the release rate
is 5,600 Ib/min. The closest release rate on Exhibit 4-7 is 6,000 Ib/min. The
corresponding rural distance is approximately 4.4 miles and the corresponding urban
distance is approximately 2.8 miles.
October 27, 1998
-------
Chapter 4
Offsite Consequence Analysis
4-12
EXHIBIT 4-7
i; ''i ; ' DISTANCES TO TOXlC ENDPdlNT '!' "
FQR ANHYDROUS AMMONIA LIQUEFIED UNDER PRESSURE
F Stability, Wind Speed 1.5 Meters per Second
Release Rate
(Ibs/min)
1
2
5
10
15
20
30
40
50
60
70
80
90
100
150
200
250
300
400
500
600
700
750
800
900
Distance to Endpoint (miles)
Rural
0.1
0.1
0.1
0.2
0.2
0.3
0.3
0.4
0.4
0.5
0.5
0.5
0.6
0.6
0.7
0.8
0.9
1.0
1.2
1.3
1.4
1.5
1.6
1.6
1.7
Urban
0.1
0.1
0.1
0.1
0.2
0.2
0.2
0.3
0.3
0.3
0.3
0.4
0.4
0.4
0.5
0.6
0.6
0.7
0.8
0.9
0.9
1.0
1.0
1.1
1.2
* More than 25 miles (report distance as 25 miles)
Release Rate
(Ibs/min)
1,000
1,500
2,000
2,500
3,000
4,000
5,000
6,000
7,000
7,500
8,000
9,000
10,000
15,000
20,000
25,000
30,000
40,000
50,000
75,000
100,000
150,000
200,000
250,000
750,000
Distance to Endpoint (miles)
Rural
1.8
2.2
2.6
2.9
3.1
3.6
4.0
4.4
4.7
4.9
5.1
5.4
5.6
6.9
8.0
8.9
9.7
11
12
15
18
22
*
*
*
Urban
1.2
1.5
1.7
1.9
2.0
2.3
2.6
2.8
3.1
3.2
3.3
3.4
3.6
4.4
5.0
5.6
6.1
7.0
7.8
9.5
10
13
15
17
*
October 27,1998'
-------
4-13
Chapter 4
Offsite Consequence Analysis
AQUEOUS AMMONIA
Some WWTPs keep aqueous ammonia in outside storage tanks at atmospheric
pressure. The tanks usually stand in a diked area. Commercial grades of aqueous
ammonia vary from less than 20 weight percent to about 30 weight percent. For ease
of presentation, the ammonia is assumed to be in a 30 weight percent solution.
Because this has the highest vapor pressure of any of the commercial grades used in
wastewater treatment facilities, its use is conservative if you have aqueous ammonia
in a less than 30 weight percent solution.
If there is a catastrophic failure, the aqueous ammonia will spill into the diked area.
You are allowed to consider the dike, which is a passive mitigation feature.
However, if you have any reason to believe that the dike will not withstand the event
that leads to the spill, or if your tank does not stand in a diked area, then you should
assume, as required by the rule, that the spill spreads out until its depth is only 1 cm
(0.39 inch). The first step is to calculate the rate of evaporation from the pool.
UNDIKEDAREA
For an undiked area, the rate of release of ammonia from the pool (QR) (Ib/min) is
given by:
QR = 0.020QS (1)
where QS is the total quantity (Ib) of the spill of aqueous ammonia. For example, if
there is a spillage of 80,000 Ib, the rate of evaporation is 0.02 x 80,000 = 1,600
Ib/min. The present guidance assumes that this is, the average rate of release over 10
minutes, after which the pool will be more dilute than it was initially and will be
evaporating much less rapidly.
DIKED ARE A
For a diked area, the rate of evaporation is:
= 0.036Ap
(2)
where A,, is the diked area in square feet. For example, if the vessel stands in a diked
area that is 40 feet x 40 feet = 1,600 ft2, the predicted rate of evaporation is 0.036 x
1,600 = 58 Ib/min.
The maximum area of the pool that would be formed by the spilled liquid can be
estimated as 0.55QS. If you have a diked area that is larger than the maximum area,
use Equation 1 for an undiked area to estimate the release rate to air.
RATES OF RELEASE AT TEMPERATURES OTHER THAN 25 °C
The actual temperature of stored aqueous ammonia varies with the ambient
temperature. The rule requires you to consider the release temperature to be the
October 27, 1998
-------
Chapter 4
Offsite Consequence Analysis
4-14
'I!
highest daily temperature observed during the last three years, or the operating
temperature, whichever is highest. The ratio R^CT) represents the ratio of the partial
pressure of ammonia at temperature T °C to the partial pressure at 25 °C.
Exhibit 4-8 gives values of Rvp(T) for 30 percent aqueous ammonia in 1 °C
incrementg.from 15 °C to '4(3i't °^ ^59 ^ to 104 ^.~The rates of evaporation in
Equations 1 and 2 are proportional to the vapor pressure, so to obtain a rate of
evaporation for a temperature T °C other than 25 °C, simply multiply the right-hand
side of Equation 1 or 2 by the corresponding value of Rvp(T). For example, for an
undiked release of 80,000 Ibs of ammonia at 35 °C, the calculation is
(0.020)(80,000)(1.45) = 2,300 Ibs/min.
The vapor pressure of ammonia at other temperatures can be obtained from the
Handbook ofChemistry and Physics, CRC Press, 1998.
;,; .: ),„..,,, , , :,
DISTANCES TO Toxic ENDPOINT
Take the evaporation rate and look for that rate, or the rate nearest to it, on Exhibit 4-
9. Then read across to theCruralor urban distances. For; example, for the 58 Ib/min
release rate derived above, the closest release rate on Exhibit 4-9 is 60 Ib/min. The
':' I' " I "| ' ' '', ' l! „ nil n!'"1 ' , '' ,i "i •'' '"li'i'1 i !" ",,!!,» 'i ' .i11' . I". ''! nil i1'I' i. I1'. ! i\',,\ ,11 IP1 liil'1,. II i1 .IM I! I!' M i',.!' "' 'It HIM • . •!', i, '• ' ili'''', „ • i| Vlll
predicted rural distance is approximately 0.4 mile and the predicted urban distance is
approximately 0.2 mile. Alternatively, use Figure 4-4.
EXHIBIT 4-8
RATIO OF VAPOR PRESSURE OF AMMONIA IN 30% AQUEOUS AMMONIA
(Ratio is Unity at 25 °C)
f.4
II
Temperature T (°C)
15
16
17
18
19
20
21
22
23
24
25
26
27
Ratio
Rvp(T)
0.67
0.70
0.73
0.76
0.79
0.82
0.86
0.89
0.93
0.96
1.00
1.04
1.08
Temperature T (°C)
28
29
30
31
32
33
34
35
36
37
38
39
40
Ratio R^
(T)
1.12
1.16
1.21
1.25
1.30
1.35
1.40
1.45
1.50
1.55
1.61
1.66
1.72
"! f
Vt;
, 1998
'
-------
4-15
Chapter 4
Offsite Consequence Analysis
EXHIBIT 4-9
DISTANCES TO TOXIC ENDPOINT FOR AQUEOUS AMMONIA
F Stability, Wind Speed 1.5 Meters per Second
Release Rate
Gbs/min)
1
2
5
10
15
20
30
40
50
60
70
80
90
100
150
200
250
300
400
500
600
700
750
800
900
Distance to Endpoint (miles)
Rural
0.1
0.1
0.1
0.2
0.2
0.3
0.3
0.4
0.4
0.4
0.5
0.5
0.5
0.6
0.7
0.8
0.8
0.9
1.1
1.2
1.3
1.4
1.4
1.5
1.5
Urban
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.2
0.2
0.3
0.3
0.3
0.4
0.4
0.4
0.5
0.5
0.5
0.6
Release Rate
(Ibs/min)
1,000
1,500
2,000
2,500
3,000
4,000
5,000
6,000
7,000
7,500
8,000
9,000
10,000
15,000
20,000
25,000
30,000
40,000
50,000
75,000
100,000
150,000
200,000
250,000
750,000 !
Distance to Endpoint (miles)
Rural
1.6
2.0
2.2
2.5
2.7
3.1
3.4
3.7
4.0
4.1
4.2
4.5
4.7
5.6
6.5
7.2
7.8
8.9
9.8
12
14
16
19
21
*
Urban
0.6
0.7
0.8
0.9
1.0
1.1
1.2
1.3
1.4
1.5
1.5
1.6
1.7
2.0
2.4
2.6
2.8
3.3
3.6
4.4
5.0
6.1
7.0
7.8
13
* More than 25 miles (report distance as 25 miles)
October 27, 1998 '
-------
••'Chapter4 "
Offsite Consequence Analysis
4-16
METHANE
Methane is present at some wastewater treatment facilities as a component of
digester gas. Typical constituents of digester gas are 55 to 70 percent methane by
volume, 25 to 30 percent carbon dioxide by volume, and small amounts of nitrogen
and hydrogen. Modern facilities may well have processes containing more than
10,000 Ib of digester gas at any one time (the entire quantity of the flammable
mixture in a process must be compared with the threshold quantity (TQ) of 10,000 Ib
to determine whether the facility is covered). Proceed as follows:
1.
2.
3.
October 27,1998
Determine the density p,,, of the methane in the digester at operating
temperature T (°F), assuming mat there is X vol percent of methane and 100
-Xvol percent of carbon dioxide and other materials. You should
determine X by analysis of your digester gas; if you do not know the
percentage of methane, you may use 70 percent as a conservative
assumption. If X varies over time, you should use the largest value of X that
is seen in your facility.
pm = 0.22X/(460+T)
(3)
As an example, if X = 65, and the operating temperature is 95 °F, pm = 0.026
Ib/ft3.
Calculate the total volume V (ft3) occupied by digester gas in one digester
(the largest). Associated pipework can be neglected.
(4)
Here, r is the digester radius and H'.is the maximum digester head space. As
an example, if H = 8 ft and r = 40 ft, then V = Ttr^H = (3.14)(40)i(8) *
40,200 ft3.
Calculate the quantity Q of methane contained in V:
(5)
In the current example, Q = (0.026X40,200) = 1,045 Ib
Note that this quantity of methane itself, as well as the total quantity of
digester gas, is less than the 10,0b6-lb TQ for flammable materials. This is
because the total amount of digester gas (i.e., not just methane) in a process
is used to determine whether that process is covered by the regulation. It
may be the case that no single digester contains more than the TQ of digester
gas, but you are covered because there are several digesters in your process.
However, you are required to consider only the quantity of methane in a
single vessel when calculating the results of a worst-case vapor cloud
explosion.
-------
4-17
Chapter 4
OfFsite Consequence Analysis
4. Use the TNT-equivalency model to calculate the distance D (miles) to the 1
psi overpressure endpoint:
D = 0.0082 (Q)
1/3
(6)
Equation 6 has been customized for methane. In the present example, D =
0,0082(1,045)1/3 * 0.08 mile. Alternatively, you can use Exhibit 4-10 to
estimate the distance to the endpoint for a range of quantities of methane.
EXHIBIT 4-10
DISTANCE TO OVERPRESSURE ENDPOINT OF 1.0 PSI FOR VAPOR CLOUD EXPLOSIONS
OF METHANE
Based on TNT Equivalent Method, 10 Percent Yield Factor
Quantity in Cloud
(pounds)
500
2,000
5,000
10,000
20,000
Distance to
Endpoint
(miles)
0.07
0.1
0.1
0.2
0.2
Quantity in Cloud
(pounds)
50,000
100,000
200,000
500,000
1,000,000
Distance to
Endpoint
(miles)
0.3
0.4
0.5
0.7
0.8
Some facilities have an intermediate storage vessel for digester gas, at a pressure that
may be typically 45-50 psig. You should use the quantity of methane in such a
vessel in Equation 6 or Exhibit 4-10 if it contains the largest quantity of digester gas
on site.
October 27, 1998 '
-------
Chapter 4
Offsite Consequence Analysis
4-18
4.2 ALTERNATIVE SCENARIOS
This section provides guidance on how to choose and model alternative scenarios.
Information is provided on the general requirements of the regulations, followed by
specific sections on chlorine, sulfur dioxide, anhydrous ammonia, aqueous ammonia,
and methane.
GENERAL REQUIREMENTS
The requirements that differ from those for worst-case scenarios are as follows:
You can take into account active as well as passive mitigation systems, as
long as these systems are expected to withstand the causes of the accident.
The alternative scenario should reach an endpoint offsite. unless no such
scenario exists.
If you are doing your own modeling, you should use "typical meteorological
conditions for the stationary source." You may obtain these data from local
weather stations. You can obtain wind speed and temperature data from the
National Climatic Data Center at (828) 271-4800. This guidance uses an
"average" weather condition of wind speed 3 m/s and D stability class with
an ambient temperature of 25 °C.
The number of alternative scenarios you are required to develop is as
follows:
> At least one scenario for each regelated toxic substance held in
Program 2 and Program 3 processes.
> At least one scenario to represent all flammables held in Program 2
and Program 3 processes.
Thus, if you have anhydrous ammonia, chlorine, sulfur dioxide, and digester gas on
your site in Program 2 and Program 3 processes, you will need, at a minimum, three
alternative toxic scenarios, one each for ammonia, chlorine and sulfur dioxide, but
only one alternative flammable scenario, for digester gas.
CHOICE OF ALTERNATIVE SCENARIOS
Your alternative scenario for a covered process must be one that is more likely to
occur than the worst-case scenario and that reaches an endpoint offsite, unless no
such scenario exists. You do not need to demonstrate greater likelihood of
occurrence or carry out any analysis of probability of occurrence; you only need to
use reasonable judgement and knowledge of the process. If, using a combination of
reasonable assumptions, modeling of a release of a regulated substance from a
process shows that the relevant endpoint is not reached offsite, you can use the
modeling results to demonstrate that a scenario does not exist for the process that
will give an endpoint offsite. You must report an alternative scenario, however.
October 27,1998
-------
4-19
Chapter 4
Offsite Consequence Analysis
Release scenarios you should consider include, but are not limited to, the following,
where applicable:
+ Transfer hose releases due to splits or sudden uncoupling;
+ Process piping releases from failures at flanges, joints, welds, valves and
valve seals, and drains or bleeds;
+ Process vessel or pump releases due to cracks, seal failure, drain bleed, or
plug failure;
+ Vessel overfilling and spill, or overpressurization and venting through relief
valves or rupture disks; and
+ Shipping container mishandling and breakage or puncturing leading to a
spill.
For alternative release scenarios, you may consider active mitigation systems, such
as interlocks, shutdown systems, pressure relieving devices, flares, emergency
isolation systems, and fire water and deluge systems, as well as passive mitigation
systems. Mitigation systems considered must be capable of withstanding the event
that triggers the release while remaining functional.
You must consider your five-year accident history and failure scenarios identified in
your hazard review or process hazards analysis in selecting alternative release
scenarios for regulated toxic or flammable substances (e.g., you might choose an
actual event from your accident history as the basis of your scenario). You also may
consider any other reasonable scenarios.
The alternative scenarios you choose to analyze should be scenarios that you
consider possible at your site. Although EPA requires no explanation of your choice
of scenario, you should choose a scenario that you think you can explain to
emergency responders and the public as a reasonable alternative to the worst-case
scenario. For example, you could pick a scenario based on an actual event, or you
could choose a scenario that you worry about, because circumstances at your site
might make it a possibility. If you believe that there is no reasonable scenario that
could lead to offsite consequences, you may use a scenario that has no offsite
impacts for your alternative analysis. You should be prepared to explain your choice
of such a scenario to the public, should questions arise.
WWTP SCENARIOS
A number of scenarios other than those listed in the rule may be worth considering
for WTTPs. Many WWTPs have single-stage, pass-through chemical scrubbers to
neutralize compounds such as sulfur dioxide. Failure of the neutralizing solution's
recirculation pump and continued operation of the blower fan could not only allow a
release, but also exacerbate it by mechanically evacuating the substance from the
room.
Accidents reported to EPA involving chlorine systems have been caused by "rust
holes," failure of a diaphragm, leak during hookup to a tank, a packing nut leak,
faulty cylinders, removal of a valve in error, faulty valves, leaking gaskets, and a
blown pressure gauge. Similar accidents involving sulfur dioxide systems have been
October 27, 1998
-------
">( f'V'i 1't'; : i"i
Chapter 4
QjEFsite Consequence Analysis
4-20
reported. In addition, natural events, such as floods, tornados, earthquakes, and
hurricanes could cause several releases to occur simultaneously. You may want to
consider these types of scenarios when you select your alternative release scenarios.
CHLORINE
October 27,1998
FLASHING LIQUID RELEASES
Many of the potential alternative scenarios could involve the release of liquid
chlorine from a small hole. The liquid chlorine flashes immediately to vapor and
fine liquid droplets and is carried downwind.
The rate of release of a liquid through an hole is given by Bernoulli's formula for
liquid releases (see Appendix 4A). Using chemical-specific data for chlorine, the
formula becomes:
QR= 3,140 x
(8)
where:
3,140 =
the area of the hole (in2 - for example, the area of a hole of
diameter 1 inch is 0.785 in2)
factor applicable to chlorine liquefied under a pressure of
98.5 psig (see Appendix 4A)
ii
Note that this is the formula for the release of a pure liquid and would apply to a
breach in the wall of a vessel or to the rupture of a very short pipe. For long pipes,
there is a pressure drop between the vessel and the hole, and there will be flashing in
the pipe and a reduced rate of release. Therefore, Equation 8 may be conservative.
; "•>. - , ' !,+•• . •> f •>•: • •': ..''i1, . &•••:' • > U^fi,i!r,: :;:. ":'•• " '.'''• t-.\-:
If there is a small leak from the liquid space of a large storage vessel, the reservoir
can essentially be considered as infinite, and the chlorine will be steadily emitted at a
constant rate for a relatively long period. Such leaks may occur because of a gasket
failure, a pump seal leak, or a corrosion hole, for example. You can use Equation 8
and the estimated area of the hole to calculate the release rate (QR).
To predict the distance to the toxic endpoint, take the calculated value of QR and
identify the closest value on Exhibit 4-11 (150 lb/min). Read off the corresponding
distance, in this case, 0.6 mile for a rural site and 0.2 mile for an urban site.
Alternatively, use Figure 4-5.
'; . •• ' •..' "isfV; ,; (li i • " '•:•,' ; '• ;
Exhibit 4-12 provides release rate estimates for releases of liquid chlorine through
holes of diameter 1/16 inch to 5 inches and the distances to the endpoint
corresponding to these release rates. You can use this table instead of Equation 8
and Exhibit 4-11 to estimate the distance to the endpoint.
-------
4-21
Chapter 4
Offsite Consequence Analysis
EXHIBIT 4-11
DISTANCES TO TOXIC ENDPOINT FOR CHLORINE
D Stability, Wind Speed 3 Meters per Second
Release Rate
(Ibs/min)
1
2
5
10
15
20
30
40
50
60
70
80
90
100
150
200
250
300
400
500
600
700
Distance to Endpoint (miles)
Rural
0.1
0.1
0.1
0.2
0.2
0.2
0.3
0.3
0.3
0.4
0.4
0.4
0.4
0.5
0.6
0.6
0.7
0.8
0.8
1.0
1.0
1.1
Urban
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.2
0.2
0.3
0.3
0.3
0.4
0.4
0.4
0.4
Release Rate
(Ibs/min)
750
800
900
1,000
1,500
2,000
2,500
3,000
4,000
5,000
7,500
10,000
15,000
20,000
25,000
30,000 .
40,000
50,000
75,000
100,000
150,000
200,000
Distance to Endpoint (miles)
Rural
1.2
1.2
1.2
1.3
1.6
1.8
2.0
2.2
2.5
2.8
3.4
3.9
4.6
5.3
5.9
6.4
7.3
8.1
9.8
11
13
15
Urban
0.4
0.5
0.5
0.5
0.6
0.6
0.7
0.8
0.8
0.9
1.2
1.3
1.6
1.8
2.0
2.1
2.4
2.7
3.2
3.6
4.2
4.8
October 27, 1998
-------
Chapter 4
Ojfsite Consequence Analysis
4-22
-. •• :" ;';:'! / •• •' EXHIBIT 4-12 ' "." '.' '.. ,, ''''," '. ",
RELEASE RATES AND DISTANCE TO THE ENDPOINT FOR LIQUID CHLORINE RELEASES
D Stability, Wind Speed 3 Meters per Second
Hole
Diameter
(inches)
1/16
3/16
1/4
5/16
Y*
1
2
3
4
5
Release Rate
(Ib/min)
10
87
150
240
620
2,500
9,900
22,200
39,500
61.700
Distance (miles)
Rural
0.2
0.4
0.6
0.7
1.0
2.0
3.9
5.3
7.3
8.1
Urban
0.1
0.2
0.2
0.3
0.4
0.7
1.3
1.8
2.4
2.7
TWO-PHASE RELEASES
In case of a release from a long pipe carrying liquid chlorine (L/dh » 1, where L is
the length of the pipe between the reservoir of chlorine and the atmosphere and dh is
the diameter of the pipe), there can be flashing in the discharge pipe, resulting in a
two-phase mixture emerging to the atmosphere. In this case, the rate of release in
Ib/min for chlorine is given by:
QR = 1,100 x Ah
(9)
where:
1,100= chemical-specific factor applicable to chlorine at 25 °C (see
Appendix 4A)
^ = hole area (in2) = area of pipe opening
F = frictionai loss factor (dimensionless) with values as follows:
• X ' ' ' L/dh "'
1 10
0.85 50
'• 0.75 100 " ' ' !" "
0.65 200
0.55 400
Exhibit 4-13 presents release rates for a range of pipe diameters and length-diameter
ratios for two-phase releases of chlorine from a pipe. You can read the release rate
from the exhibit or calculate the release rate from Equation 10, then find the distance
to the endpoint corresponding to the release rate by referring to Exhibit 4-11.
October 27,1998
-------
4-23
Chapter 4
Offsite Consequence Analysis
EXHIBIT 4-13
RELEASE RATES FOR TWO-PHASE RELEASES FROM PIPES CARRYING LIQUID
CHLORINE
Pipe
Diameter
(inches)
1/4
5/16
'/2
3/4
1
2
3
Pipe Length/Diameter (L/d^)
10 (F=l)
50 (F=0.85)
100 (F=0.75)
200 (F=0.65)
400 (F=0.55)
Chlorine Release Rate (Ibs/min)
54
84
220
490
860
3,500
7,800
46
72
180
410
730
2,900
6,600
40
63
160
360
650
2,600
5,800
35
55
85,800
320
560
2,200
5,100
30
46
120
270
480
1,900
4,300
VAPOR RELEASES
For a choked release of vapor (i.e., emerging at the speed of sound from the hole,
which will invariably be the case for chlorine at atmospheric temperatures), the
release rate for chlorine is given by:
QR=190xAh
(10)
where:
190 = chemical-specific factor for chlorine at a tank pressure of
113 psia and temperature 25 °C (see Appendix 4A)
Ah = hole area (in2)
You can use Equation 10 to estimate the release fate of chlorine from a hole in the
vapor space of a tank. For example, such a hole could result from shearing off a
valve at the top of a tank. The distance to the endpoint can be estimated from the
release rate, using Exhibit 4-11 or 4-5.
As an alternative to Equation 10, for releases from holes ranging from 1/16-inch to 5
inches in diameter, you can read the release rate and the corresponding distance from
Exhibit 4-14.
October 27, 1998
-------
Chapter 4
Offsite Consequence Analysis
4-24
;: •'•: • • •"• EXHIBIT4-14
i|RELEASE|RATES,AND DISTANCE,T^p,THE ENDPOINTf OR CHLORINE VAPOR
,'„,; 1' II ." ;,'RELEASES ' ' ' "
D Stability, Wind Speed 3 Meters per Second
•J.'K1 '"Iti"!1
Hole
Diameter
(inches)
1/16
3/16
1/4
5/16
1A
1
2
3
4
5
Release Rate
(Ibs/min)
0.6
5
9
15
37
150
600
1,300
2,400
3,700
Distance (miles)
Rural
0.1
0.1
0.2
0.2
0.3
0.6
1.0
1.6
2.0
2.5
Urban
0.1
0.1
0.1
0.1
0.1
0.2
0.4
0.6
0.7
0.8
- ,; , , ;„ , ,. '-, "- .'. [„ ;,, :,,.. , ; ,i ,j :
!•; • If, ;:|f M,, ,
Note that the release rate estimated by the method above is conservative. As the
release proceeds, chlorine continuously evaporates from the liquid surface in the
cylinder. This causes the liquid to cool, the vapor pressure to decrease, and the rate
of release to decline. However, the equations for calculating this effect are rather
complex and not included in this guidance.
1 ' . • It ', M,,"!' ' ' "' i I1 i „ ' i' ,;"... in,', ,i ,i || | j, ; n,,,,, , , , , .'|
:: ';: OTHER CHLORINE SCENARIOS , , ' ", \'
If you wish to do so, you can simply quote any of the results above, if they are
applicable to your site, when you submit your Risk Management Plan. However,
you may also choose to develop other scenarios, using Equations 8, 9, or 10, and
, " ;« Exhibit 4-11 or Figure 4-5.
1 Ji'j1 i;;;:!!!"!'.1 •: ',, " ". -i •' '• ; , ' ' •>•: • "'»,' .• s,:' i ; ;: i „• ; , j
DURATION OF RELEASE
You may calculate the maximum duration by dividing the quantity in the tank or the
quantity that wouldbe released from a pipe by the release rate. Youmayuse60
minutes as a default value for maximum release duration. If you know, and can
substantiate, how long it is likely to take to stop the release, you may use that time as
the release duration.
April 27,1999
-------
4-25
Chapter 4
Offsite Consequence Analysis
SULFUR DIOXIDE
FLASHING LIQUID RELEASES
Sulfur dioxide is similar to chlorine in the way that it would be released, so
Bernoulli's formula is applicable. Using Bernoulli's formula, incorporating
chemical-specific data for sulfur dioxide, you can estimate the release rate from a
hole in the liquid space of a tank from the following equation:
QR = 2,020 xAh
(11)
where:
Ah = the area of the hole (in2)
2,020 = factor applicable to sulfur dioxide liquefied under a pressure
of 43 psig (see Appendix 4A)
After you have estimated me release rate, you can find the predicted distance to the
toxic endpoint for sulfur dioxide from Exhibit 4-16 (next page) or Figure 4-6.
Alternatively, you can use Exhibit 4-15. This exhibit gives release rates and
distances to the endpoint for flashing liquid releases through holes of diameter 1/16
inch to 5 inches.
EXHIBIT 4-15
RELEASE RATES AND DISTANCE TO THE ENDPOINT FOR LIQUID SULFUR DIOXIDE
RELEASES
D Stability, Wind Speed 3 Meters per Second
Hole
Diameter
(inches)
1/16
3/16
1/4
5/16
Vl
1
2
3
4
5
Release Rate
(lb/min)
6
56
99
160
400
1,600
6,300
14,300
25,300
39,600
Distance (miles)
Rural
0.1
0.4
0.5
0.6
0.9
1.9
3.3
5.6 !
7.3
9.2
Urban
0.1
0.2
0.2
0.2
0.4
0.6
1.1
1.7
2.1
2.6
October 27, 1998
-------
Ill
fj
Mr '. f'i 3
Chapter 4
OfTsite Consequence Analysis
4-26
.I! ',' , , , , EXHIBIT4-16 ' , '.T ,' ''. ,,r
DISTANCES TO TOXIC ENDPOINT FOR SULFUR DIOXIDE
D Stability, Wind Speed 3 Meters per Second
Release Rate
(Ibs/min)
1
2
5
10
15
20
30
40
50
60
70
80
90
100
150
200
250
300
400
500
600
700
Distance to Endpoint (miles)
Rural
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.3
0.3
0.4
0.4
0.4
0.4
0.5
0.6
0.6
0.7
0.8
0.9
1.0
1.1
1.2
Urban
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.3
0.3
0.4
0.4
0.4
0.4
Release Rate
(Ibs/min)
750
800
900
1,000
1,500
2,000
2,500
3,000
4,000
5,000
7,500
10,000
15,000
20,000
25,000
30,000
40,000
50,000
75,000
100,000
150,000
200,000
Distance to Endpoint (miles)
Rural
1.3
1.3
1.4
1.5
1.9
2.2
2.3
2.7
3.1
3.3
4.0
4.6
5.6
6.5
7.3
8.0
9.2
10
13
14
18
20
Urban
0.5
0.5
0.5
0.5
0.6
0.7
0.8
0.8
1.0
1.1
1.3
1.4
1.7
1.9
2.1
2.3
2.6
2.9
3.5
4.0
4.7
5.4
TWO-PHASE RELEASES
i
A. break in a long pipe (whose length is much greater than its diameter) carrying
liquid sulfur dioxide can result in the release of a two-phase mixture, as discussed
above for chlorine. The release rate can be estimated frorn the following equation:
= 252x AhxF
(12)
Q !!;"K where:
October 27,1998
-------
4-27
Chapter 4
Offsite Consequence Analysis
252
Ah
F
chemical-specific factor applicable to sulfur dioxide at 25 °C
(see Appendix 4A)
hole area (in2) = area of pipe opening
factional loss factor (dimensionless) with values as shown
in the section on chlorine
You can estimate the release rate from Equation 12, then find the distance to the
endpoint corresponding to the release rate by referring to Exhibit 4-11. You also can
find the release rate for a range of pipe diameters and L/dh values in Exhibit 4-17.
EXHIBIT 4-17
RELEASE RATES FOR TWO-PHASE RELEASES FROM PIPES CARRYING LIQUID
SULFUR DIOXIDE
Pipe
Diameter
(inches)
1/4
5/16
'/2
3/4
1
2
3
Pipe Length/Diameter (L/d,,)
10 (F=l)
SO (F=0.85)
100 (F=0.75)
200 (F=0.65)
400 (F=0.55)
Sulfur Dioxide Release Rate (Ibs/min)
12
19
49
110
200
800
1,800
11
16
42
95
170
670
1,500
9
14
37
83
150
600
1,300
8
13
32
72
130
520
: 1,200
7
11
27
61
110
440
980
VAPOR RELEASES
For a choked release of sulfur dioxide vapor, the release rate is given:
QR = 91 xAh
where:
91
(13)
chemical-specific factor for sulfur dioxide at a tank pressure
of 58 psia and temperature 25 °C (see Appendix 4A)
hole area (in2)
The distance to the endpoint can be estimated from the release rate, using Exhibit 4-
16 or Figure 4-6.
As an alternative to Equation 13 and Exhibit 4-16, for releases from holes ranging
from 1/4 inch to 5 inches in diameter, you can read the release rate and the
corresponding distance from. Exhibit 4-18.
October 27, 1998'
-------
1;,! Chapter 4
biftsite Consequence Analysis
4-28
EXHIBIT 4-18
RELEASE RATES AND DISTANCE TO THE ENDPOINT FOR SULFUR DIOXIDE VAPOR
.. , • ••. , . T- .• • • • RELEASES "
D Stability, Wind Speed 3 Meters per Second
Hole
Diameter
(inches)
1/4
5/16
'/2
1
2
3
4
5
Release
Rate
(Ibs/min)
4
7
18
71
280
640
1,100
1,800
Distance (miles)
Rural
0.1
0.1
0.2
0.4
0.8
1.1
1.5
2.2
Urban
0.1
0.1
0.1
0.2
0.3
0.4
0.5
0.7
OTHER SULFUR DIOXIDE SCENARIOS
If you wish to do so, you can simply quote any of the results above, if they are
applicable to your site, when you submit your Risk Management Plan. However,
you may also choose to develop other scenarios, using Equations 11, 12, or 13, and
Exhibit 4-16 or Figure 4-6.
October 27,1998
-------
4-29
Chapter 4
Offsite Consequence Analysis
ANHYDROUS AMMONIA
FLASHING LIQUID RELEASES
Like chlorine and sulfur dioxide, ammonia will be liquefied under pressure in its
own storage vessel. Bernoulli's equation is applicable for flashing liquid releases
(see Appendix 4A). The equation for ammonia liquefied under a pressure of 130
psig is:
QR= 2,380
(14)
where:
Ah
2,380 =
hole area (in2)
chemical-specific factor for ammonia liquefied under
pressure
After you have estimated the release rate, you can find the predicted distance to the
toxic endpoint for ammonia from Exhibit 4-20 (next page) or Figure 4-7.
Alternatively, you can use Exhibit 4-19. This exhibit gives release rates and
distances to the endpoint for flashing liquid releases through holes of diameter 1/16
inch to 5 inches.
EXHIBIT 4-19
RELEASE RATES AND DISTANCE TO THE ENDPOINT FOR LIQUID AMMONIA
RELEASES
D Stability, Wind Speed 3 Meters per Second
Hole
Diameter
(inches)
1/16
3/16
1/4
5/16
'/2
1
2
3
4
5
Release Rate
(Ibs/min)
7
66
120
180
470
1,900
7,500
16,800
30,000
46,800
Distance (miles)
Rural
0.1
0.2
0.2
0.4
0.4
0.8
1.6
2.2
3.1
3.9
Urban
0.1
0.1
0.1
0.2
0.2
0.3
0.5
0.7
1.0
1.2
October 27, 1998
-------
Chapter 4
Offsite Consequence Analysis
4-30
EXHIBIT 4-20
DISTANCES TO TOXIC ENDPOINT FOR ANHYDROUS AMMONIA
.-:: :' " ' D Stability, Wind Speed 3 Meters per Second
Release Rate
(Ibs/min)
<10
10
15
20
30
40
50
60
70
80
90
100
150
200
250
300
400
500
600
700
750
800
Distance to Endpoint (miles)
Rural
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.2
0.2
0.3
0.3
0.3
0.4
0.4
0.5
0.5
0.5
0.5
Urban
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.2
0.2
Release Rate
(Ibs/niin)
900
1,000
1,500
2,000
2,500
3,000
4,000
5,000
7,500
10,000
15,000
20,000
25,000
30,000
40,000
50,000
75,000
100,000
150,000
200,000
250,000
Distance to Endpoint (miles)
Rural
0.6
0.6
0.7
0.8
0.9
1.0
1.2
1.3
1.6
1.8
2.2
2.5
2.8
3.1
3.5
3.9
4.8
5.4
6.6
7.6
8.4
Urban
0.2
0.2
0.3
0.3
0.3
0.4
0.4
0.5
0.5
0.6
0.7
0.8
0.9
1.0
1.1
1.2
1.4
1.6
1.9
2.1
2.3
October 27,1998
-------
4-31
Chapter 4
Offsite Consequence Analysis
AQUEOUS AMMONIA
Alternative scenario spills of aqueous ammonia are going to be similar to worst-case
scenario spills in that there will be a leak of some kind and the liquid will either
spread across a diked area or spread out until its depth is only 1 cm (0.39 inch). The
principal difference will be in the amount spilled.
The calculation of the rate of spillage is again performed using Bernoulli's formula
see Appendix A4). The density of 30 percent aqueous ammonia is 57.33 Ib/ft3, so
the equation becomes:
QRL = 153 x Ah x (h)1
,0.5
(15)
where:
QRL =
Ah
h
rate of spillage of ammonia solution onto the ground
(Ibs/min), not the rate of evaporation
hole area (in2)
static head
For example, for a /4-inch diameter opening with a static head h of 10 ft:
QRL = 153 x -K x (i/2xi/2)2 x /10 = 153 x 3.142 x 1/16 x 3.16 = 95 Ib/min
This is the rate of spillage of the total solution of water plus ammonia as a liquid
onto the ground.
If you know, and can document, how long it will take to stop the release, you should
estimate the total quantity of solution spilled to the ground (QS) by multiplying the
estimated rate of liquid spillage by the estimated duration of the release (in minutes).
Then you can estimate the release rate to air (QR) as the evaporation rate of
ammonia from the pool. For an undiked area (pool depth 1 cm):
QR = 0.025QS
For a diked pool (pool depth greater than 1 cm) of area Ap square feet:
QR = 0.046Ap
(16)
(17)
The maximum area of the pool that would be formed by the spilled liquid is 0.55QS.
If you have a diked area that is larger than the maximum area, use the equation for an
undiked area to estimate the release rate to air.
It is possible that you may estimate a rate of evaporation of ammonia from the pool
that exceeds the spill rate of the liquid solution, particularly if the liquid spill rate is
small and the spill of the liquid may last for a fairly long time. In such a case, under
the assumptions used in this estimation method, no pool would be formed. Instead of
the evaporation rate, in this case, you should use the liquid spill rate (QRL) as the
release rate to air.
October 27, 1998
-------
^Qhapter 4
Offsite Consequence Analysis
4-32
You also can determine how far the pool will spread until the rate of spillage is
matched by the rate of evaporation of ammonia. For aqueous ammonia at 77 °F (25
°C), the rate of evaporation is 0.046 Ap (from Equation 17).
The area that will cause the rate of evaporation to exactly balance the rate of spillage
is given by:
i ',1
j "', f 11
October 27,1998
= QR/0.046 = 22QRL
(18)
In the example given above, QRL = 95 Ib/min, so Ap = 2,100 ft2. This value should
be compared with the available diked area and the smaller of the two values chosen.
Thus, if the diked area happens to be 50 ft x 50 ft = 2,500 ft2, the area chosen for
subsequent calculation is Ap = 2,100 ft2 and QR = 95 Ib/min. (If the diked area
happened to be smaller — say 20 ft x 20 ft = 400 ft2 — then the spilled ammonia
would coyer the diked area, and, using Equation 17, the rate of evaporation QR
would.be'(0.046X400) = 18i Ib/min.)
To predict the distance to the toxic endpoint in typical weather conditions, take the
value of QR calculated above and identify the closest value on Exhibit 4-21. Read
off the corresponding distance. For the 95 Ib/min case, the result is 0.2 mile for a
rural site and 0.1 mile for an urban site. Alternatively, use Figure 4-8.
f , I
, ''s'"l 'fill
-------
4-33
Chapter 4
Offsite Consequence Analysis
EXHIBIT 4-21
DISTANCES TO TOXIC ENDPOINT FOR AQUEOUS AMMONIA
D Stability, Wind Speed 3 Meters per Second
Release Rate
(Ibs/min)
8
10
15
20
30
40
50
60
70
80
90
100
150
200
250
300
400
500
600
700
750
Distance to Endpoint (miles)
Rural
0.1
0.1
0.1
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.2
0.2
0.3
0.3
0.4
0.4
0.4
0.5
0.6
0.6
0.6
Urban
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.2
0.2
0.2
Release Rate
(Ibs/min)
800
900
1,000
1,500
2,000
2,500
3,000
4,000
5,000
7,500
10,000
15,000
20,000
25,000
30,000
40,000
50,000
75,000
100,000
150,000
200,000
Distance to Endpoint (miles)
Rural
0.7
0.7
0.8
1.0
1.2
1.2
1.5
1.8
2.0
2.2
2.5
3.1
3.6
4.1
4.4
5.1
5.8
7.1
8.2
10
12
Urban
0.2
0.3
0.3
0.4
0.4
0.4
0.5
0.6
0.7
0.7
0.8
1.0
1.2
1.3
1.4
1.6
1.8
2.2
2.5
3.1
3.5
October 27, 1998
-------
Chapter 4
Offsite Consequence Analysis
4-34
METHANE
'if!,1!
Consider the case of methane released from a digester. Assuming that the full
contents of a digester were released over a few minutes (say 10 minutes), in the
example given in Section 4.1, the release rate would be 105 Ib/min (total quantity of
methane in the digester, 1,053 Ib). The LFL for methane is 33 mg/L. Conservatively
taking digester gas/methane as a neutrally buoyant gas (it will actually rise from the
ground), you need to use Exhibit 4-22 (for a rural site) or Exhibit 4-23 (for an urban
site) to estimate the distance to the LFL. From Exhibit 4-22, the predicted distance
for a release rate of 105 Ib/min is 0.1 mile at a rural site and from Exhibit 4-23, it is
0.1 mile at an urban site.
It is unlikely that a BLEVE would occur. They are not known to take place in low
pressure containment such as that of a digester A pool fire does not need to be
considered, because the methane is not liquefied.
EXHpIT4-22
PLUME DISTANCES Tb"L6wER FLAMM^itlTY LIMIT "(LFL)''" '"
Rural Conditions, D Stability, Wind Speed 3.0 Meters per Second
-I?
Release Rate
(Ibs/min)
0 - 1,980
1,980-7,260
7,260-17,490
17,490-28,380
28,380-42,900
42,900-56,100
56,100-72,600
72,600-89,100
89,100- 108,900
Distance to
Endpoint
(miles)
0.1
0.2
0.3
0.4
0.5
0.6
0.7
0.8
0.9
Release Rate
(Ibs/min)
108,900-128,700
128,700-148,500
148,500-171,600
171,600-191,400
191,400-224,400
224,400-270,600
270,600-320,100
320,100-363,000
363,000-429,000
Distance to
Endpoint
(miles)
1.0
1.1
1.2
1.3
1.4
1.6
1.8
2.0
2.2
'1 October 27,1998"' "."'
- '": .•'>; •: ..: I "f
-------
4-35
Chapter 4
Offsite Consequence. Analysis
EXHIBIT 4-23
NEUTRALLY BUOYANT PLUME DISTANCES TO LOWER FLAMMABILITY LIMIT (LFL)
Urban Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release Rate
(Ibs/min)
0 - 4,950
4,950-23,430
23,430-49,500
49,500-85,800
85,800-132,000
132,000-181,500
181,500-240,900
Distance to
Endpoint
(miles)
0.1
0.2
0.3
0.4
0.5
0.6
0.7
Release Rate
(Ibs/min)
240,900-303,600
303,600-363,000
363,000-462,000
462,000-594,000
594,000-858,000
858,000-1,023,000
1,023,000-1,254,000
Distance to
Endpoint
(miles)
0.8
0.9
1.0
1.2
1.4
1.6
1.8
October 27, 1998
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I
Chapter 4
Offsite Consequence Analysis
4-36
4,3 BUILDINGS
In many WWTPs, chlorine and sulfur dioxide cylinders or other vessels are kept
indoors. Unless your cylinders are delivered directly into the building (i.e., they are
not unloaded outdoors and moved inside later), you should not consider buildings in
your worst-case scenario, even though they are passive mitigation systems, because
there will be some time when the vessels are outdoors. If your cylinders are delivered
indoors or if your largest vessel is indoors, you may want to analyze the mitigating
effects of the building when you do your worst-case analysis. You may also want to
consider alternative scenarios that consider buildings as mitigation systems. Some
buildings are strong, leak-tight buildings that are designed to contain the release of
the contents of a one-ton cylinder or other vessel. Some of them contain scrubbers
that activate upon release of chlorine or sulfur dioxide; if these scrubbers function as
designed, they can ensure that any release to the external atmosphere would be small.
(Scrubbers are active mitigation features that cannot be considered to work for a
worst-case scenario.) At the other end .of 'the spectrum, some buildings are intended
to do no more than keep the rain off.
MITIGATION OF RELEASES OF ANHYDROUS AMMONIA, CHLORINE, OR SULFUR DIOXIDE
1111 1 ........ '•' 'I1 • ' . ', ..... V > . '". ' I, 1 '•• ...... •. * ..... « !.«!,.' IliiiHii' ; !', I 1111,,! ''!|! I f " •• ;."•.• ,.! , •: ..... [V '>»'!«!
INTO BUILDINGS
i i i ^ " ' ; •. ' • •:..•'• ..:,, ;, :»: . f1,' ',.• •\^'Av\- :,-, !i • '. • ,1; lr. M :'"§
EPA's RMP Offsite Consequence Analysis Guidance provides a simple building
release-rate-multipkcative factor of 55 percent for toxic gases in both worst-case and
alternative scenarios (i.e., the predicted rate of release is 55 percent of that for the
same accident if it should occur outdoors).
Example: Assume that there is a liquid chlorine release through a 5/1 6-inch
opening as described in the discussion of chlorine alternative
scenarios (see Exhibit 4-12). This release takes place indoors and,
per the discussion above, is reduced to 55 percent of the release rate
of 240 Ib/mux, i.e., to = 'iM'lb/mttu' From Exhibit 4- 11, the
predicted distance to the toxic endpoint is » 0.6 mile for a rural site
and » 0.2 mile for an urban site, compared to 0.7 mile (rural) and
0.3 mile (urban) for an outdoor release.
The RMP Offsite Consequence Analysis Guidance also provides factors for toxic
liquids of 10 percent for worst-case scenarios and 5 percent for alternative scenarios.
These factors may be used for releases of aqueous ammonia that take place inside
buildings.
The following discussion provides a more sophisticated approach for considering
effects of building mitigation for worst-case (if appropriate) and alternative scenarios
involving release of gases and mixtures of gases and entrained liquid. Analysis of
release scenarios inside buildings involves consideration of the structure of the
building, liquid rain-out, and release containment issues. The procedure addressing
these issues which is recommended for developing release rate estimates for both
worst-case (if appropriate) and alternative scenarios is presented in Figure 4-9.
October 27,1998
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4-37
Chapter 4
Offsite Consequence Analysis
The release into the building is assumed to occur over a 10-minute period. For the
worst-case scenario, the quantity released into the building equals the total quantity
in the largest vessel or pipeline. For alternative scenarios, you must estimate the
total quantity of ammonia, chlorine, or sulfur dioxide released from the equipment
over a 10-minute period. This 10-minute assumption is made to keep this guidance
simple.
Calculations of the likely rise in pressure show that, for a release distributed over 10
minutes, building failure is unlikely to occur unless you have a very large vessel in a
very small room. However, if the ratio of room volume to quantity in the vessel is <
0.1 fWlb for ammonia and < 0.05 fWlb for chlorine or sulfur dioxide, you should
look at the possibility that the room will fail by windows blowing out or doors
blowing open.
If the release is indoors directed towards a door or window that is potentially open,
the release rate to the outside is the total quantity, uniformly distributed over 10
minutes. If the release is indoors and not directed towards a door or window,
mitigation of the release by scrubbing, rain-out, or ventilation dilution may occur. If
there is a scrubber, the release of material to the environment may be low. If there is
no scrubber, the ventilation rate Nv, expressed as room volumes exchanged per hour,
is identified, and the room volume per unit quantity of either ammonia, chlorine, or
sulfur dioxide vapor released to the room (0) and the quantity airborne hi the room
(QJ are calculated for either a vapor or a vapor/liquid release.
For vapor releases, the amount of vapor released into the room is clearly Q, so 0 =
V/Q. For a flashing liquid release, ~ 20 percent of the release typically flashes to
vapor, so ® = V/(0.2Q). The quantity airborne in the room is the total quantity
released from the equipment to the room in 10 minutes for vapor releases and four-
tenths of the total quantity released from the equipment to the room in 10 minutes for
vapor/liquid releases. The basis for this four-tenths assumption is that, in a room, a
flashing liquid jet will encounter obstacles that will cause 60 percent of the release to
collect as a relatively slowly evaporating pool on the ground. The release over the
initial ten minutes leads to predictions of higher concentrations downwind than does
the slowly evaporating pool; therefore, you can consider only the release rate of the
airborne material (0.4Q/10) and ignore the evaporating pool in estimating the
distance to the toxic endpoint.
Given the values of Nv and 0, the building mitigation factor (FR10) is identified for
10-minute releases of ammonia in Exhibit 4-24, and for 10-minute releases of either
chlorine or sulfur dioxide in Exhibit 4-25, respectively. The release rate to the
environment is the total quantity airborne in the room, reduced by the building
mitigation factor, distributed uniformly over 10 minutes.
Example: A 25-ton (50,000 Ib) chlorine storage vessel is in a room of
dimensions 40 feet x 40 feet x 30 feet = 48,000 ft3. There is a worst-
case release, so that the 50,000 Ib is released into the building over a
period of 10 minutes. The release is not adjacent to a potentially
open door or window. Because it is a worst-case scenario, the
scrubber (if there is one) is not operating. The ventilation rate Nv =
October 27, 1998
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I I
~ Chapter 4
Offsite Consequence Analysis
4-38
if,,
[iCi, i
I , Illi" l/fii
i "III I''
'•"'!' Jl! ;i'i '-'Example:
4. The release is a mixture of vapor and liquid droplets, so that 0 =
y/(9.2Q) = 48,000/10,600 = 4.8 'fP/lb, and the airborne quantity Qa =
0.4Q = 20,000 lb. From Exhibit 4-24, with Nv = 4 and © = 4.8 (the
closest entries on Exhibit 4-25 are Nv = 5 aiid 0 = 4.0), FR,0 = 0.46.
Therefore, the predicted worst-case scenario release rate from the
building is:
0.46x((0.4x50,000)/10) = 920 Ib/niin
Compare this value with 5,000 Ib/min from an open-air release.
From Exhibit 4-4, the predicted distance for a 920 Ib/min release at a
rural site is 6.3 miles and, at an urban site, is 2.9 miles. By
comparison, the 5,000 Ib/min release would lead to corresponding
distances of 15 miles and 7 miles, respectively.
' : • ••' ;t:?f >rr.::*; i :.:, :; .; ^:^ "'fs '.,••••. i,r. *!*•"•.:••• ;. • •, i,:;
Take a chlorine alternative scenario for a flashing liquid release
through a 1/4-incn hole (see Section 4.2). Exhibit 4-13 shows a
release rate of 150 Ibs/min for this release. Assume this release
''! ' .' '"I!!'.:, ''i!:'" : ":,-'•',', •HU V "IB i/.'i ''Hit!! 'if I III'"! : <'Ci: ,i '/'t .''• I! 'lill-1
takes place in a building with no scrubber for 10 minutes at a release
rate of 150 Ib/min for a. totel release of 13500 Ib. Assume that the
building has dimensions of 50 feet x 25 feet x 20 feet = 25,000 ft?.
The release is a flashing liquid and, therefore, consists of a mixture
of vapor and liquid. Qa, the quantity that becomes airborne, is
(b.4)(l,566) = 600 Ib. the quantity of vapor is (6.2)(l3ob) = 300
lb. Then © = 25,000/300 = 83 « 80. You will have to determine Nv
from the characteristics of your building. For this example, assume
that the building is being ventilated with Nv = 5. From Exhibit 4-25,
FR10 = 0.32, so that the rate of release to the external atmosphere is
(0.1)(0.32)(600) = 19 Ib/min. From Exhibit 4-11, the predicted
distance to the endpoint is 6.2 mile for a rural site and 0.1 mile for
an urban site. For the original release rate of 150 Ib/min, the
distances to the endpoint are 0.6 mile for a rural site and 0.2 mile for
an urban site.
Will ':i 1 II
Apnl27,1999
-------
4-39
Chapter 4
OfFsite Consequence Analysis
EXHIBIT 4-24
TEN-MINUTE BUILDING RELEASE ATTENUATION FACTORS FOR PROLONGED
RELEASES OF ANHYDROUS AMMONIA
e
(tf/lb)
160
80
32
16
Nv
(hr-1)
0
1
5
10
20
30
40
0
1
5
10
20
30
40
0
1
5
10
20
30
40
0
1
5
10
20
30
40
FR,»
(dim)
0.07
0.08
0.32
0.51
0.71
0.80
0.85
0.13
0.13
0.32
0.51
0.71
0.80
0.85
0.29
0.29
0.32
0.51
0.7L
0.80
0.85
0.47
0.47
0.47
0.51
0.71
0.80
0.85
e
(tf/lb)
8.0
4.0
0.80
0.32
Nv
(hrj)
0
1
5
10
20
30
40
0
1
5
10
20
30
40
0
1
5
10
20
30
40
0
1
5
10
20
30
40
FR,o
(dim)
0.67
0.67
0.67
0.67
0.71
0.80
0.85
0.83
0.83
0.83
0.83
0.83
0.83
0.85
0.97
0.97
0.97
0.97
0.97
0.97
0.97
0.99
0.99
0.99
0.99
0.99
0.99
0.99
April 27, 1999
-------
Chapter 4
Offsite Consequence Analysis
4-40
, , EXHIBIT 4-25
TEN-MINUTE BUILDING RELEASE ATTENUATION FACTORS FORPROLONGED
RELEASES OF CHLORINE AND SULFUR DIOXIDE
lit \ , I i;"!1,1.
! 'i 1 ,->
e
(fP/lb)
160
80
32
16
Nv
(hr-1)
0
1
5
10
20
30
40
0
1
5
10
20
30
40
0
1
5
10
20
30
40
0
1
5
10
20
30
40
FR,»
(dim)
0.02
0.08
0.32
0.51
0.71
0.80
0.85
0.03
0.08
0.32
0.51
0.71
0.80
0.85
0.08
0.08
0.32
0.51
0.71
0.80
0.85
0.15
0.15
0.32
0.51
0.71
0.80
0.85
e
(tfVlb)
8.05
4.0
0.80
0.32
- ; * \
Nv
(hr1)
0
1
5
10
20
30
40
0
1
5
10
20
30
40
0
1
5
10
20
30
40
0
1
5
10
20
30
40
. :; ,| - •
'!'
FR10
(dim)
0.28
0.28
0.32
0.51
0.71
0.80
0.85
0.46
0.46
0.46
0.51
0.71
0.80
0.85
0.85
0.86
0.86
0.86
0.86
0.86
0.86
0.94
0.94
0.94
0.94
0.94
0.94
0.94
April 27, 1999
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4-41
Chapter 4
OfFsite Consequence Analysis
4.4 ESTIMATING OFFSITE RECEPTORS
The rule requires that you estimate in the RMP residential populations within the
circle defined by the endpoint for your worst-case and alternative release scenarios
(i.e., the center of the circle is the point of release and the radius is the distance to the
endpoint). In addition, you must report in the RMP whether certain types of public
receptors and environmental receptors are within the circles.
RESIDENTIAL POPULATIONS
To estimate residential populations, you may use the most recent Census data or any
other source of data that you believe is more accurate. You are not required to
update Census data or conduct any surveys to develop your estimates. Census data
are available in public libraries and in the LandView system, which is available on
CD-ROM (see box below). The rule requires that you estimate populations to
two-significant digits. For example, if there are 1,260 people within the circle, you
may report 1,300 people. If the number of people is between 10 and 100, estimate to
the nearest 10. If the number of people is less than 10, provide the actual number.
Census data are presented by Census tract. If your circle covers only a portion of the
tract, you should develop an estimate for that portion. The easiest way to do this is
to determine the population density per square mile (total population of the Census
tract divided by the number of square miles in the tract) and apply that density figure
to the number of square miles within your circle. Because there is likely to be
considerable variation in actual densities within a Census tract, this number will be
approximate. The rule, however, does not require you to correct the number.
OTHER PUBLIC RECEPTORS
Other public receptors must be noted in the RMP, (see the discussion of public
receptors in Chapter 2). If there are any schools, residences, hospitals, prisons,
public recreational areas or arenas, or commercial or industrial areas within the
circle, you must report that. You are not required to identify the specific public
receptors; you must simply check off the categories of such areas within the circle.
Most receptors can be identified from local street maps.
ENVIRONMENTAL RECEPTORS
Environmental receptors are defined as natural areas such as national or state parks,
forests, or monuments; officially designated wildlife sanctuaries, preserves, refuges,
or areas; and Federal wilderness areas. Only environmental receptors that can be
identified on local U.S. Geological Survey (USGS) maps (see box below) need to be
considered. You are not required to locate each of these specifically. You are only
required to check off in the RMP which specific types of areas are within the circle.
If any part of one of these receptors is within your circle, you must note that in the
RMP.
October 27,1998
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I Ilk!!!'" "' .'li,'11!!1'1!1 I 'inH!
,
ii;Chapter4
Offsite Consequence Analysis
4-42
Important: The rule does not require you to assess the likeHhood, type, or severity
of potential impacts on either public or environmental receptors. Identifying them as
within the circle simply indicates that they could be adversely affected by the
release.
Besides the results you are required to report in the RMP, you may want to consider
submitting to EPA or providing your local community with a map showing the
distances, to tKe endpoint. Figure 4-10 is one suggested example of how the
consequences of worst-case and alternative scenarios might be presented. It is a
simplified map that shows the radius to which the vapor cloud might extend, given
the worst-case release in worst-case weather conditions (the owner or operator
' 'i ' "...'!' i'!'!!"" •"' !!!"'!.!.... ' : !' " • ' . ! » !' « "!' • .'...»i i,'1 !! :"',„.' i. ! l:"'!ili1 "IB! :!!!!' i,!' '!"!!'! '"!,!!:!">« |" ,i'! !,„'":" ,,i'!,',, : "' :i,!",, •*• , , ,
should use a real map of the area surrounding the site). Organizations that have
prepared Risk Management Programs and Plans have used this form of presentation
(for example, in the Kanawha Valley or in Tampa Bay).
How TO OBTAIN CENSUS DATA AND LANDVEEW®
Census data can be found in publications of the Bureau of the Census, available in public libraries,
including County and City Data Book.
LandView ®m is a desktop mapping system that includes database extracts from EPA, the Bureau of
the Census, the U.S. Geological Survey, the Nuclear Regulatory Commission, the Department of
Transportation, and the Federal Emergency Management Agency. These databases are presented in a
geographic context on maps that show jurisdictional boundaries, detailed networks of roads, rivers,
and railroads, census block group and tract polygons, schools, hospitals, churches, cemeteries,
airports, dams, and other landmark features.
CD-ROM for IBM-compatible PCS
CD-TGR95-LV3-KTT S99 per disc (by region) or $549 for 11 disc set
U.S. Department of Commerce
Bureau of the Census
P.O. Box 277943
Atlanta, GA 30384-7943
Phone: 301-457-4100 (Customer Services—orders)
Fax: (888) 249-7295 (toll-free)
Fax: (301) 457-3842 (local)
Phone: (301) 457-1128 (Geography Staff—content)
http://www.census.gov/fip/pub/geo/www/tiger/
Further information on LandView and other sources of Census data is available at the Bureau of the
Census web site at www.census.gov.
October 27,1998
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4-43
Chapter 4
Offsite Consequence Analysis
How TO OBTAIN USGS MAPS
The production of digital cartographic data and graphic maps comprises the largest component of the
USGS National Mapping Program. The USGS's most familiar product is the 1:24,000-scale
Topographic Quadrangle Map. This is the primary scale of date produced, and depicts greater detail
for a smaller area than intermediate-scale (1:50,000 and 1:100,000) and small-scale (1:250,000,
1:2,000,000 or smaller) products, which show selectively less detail-for larger areas.
U.S. Geological Survey
508 National Center
12201 Sunrise Valley Drive
Reston, VA 20192
www.mapping.usgs.gov/
To order USGS maps by fax, select, print, and complete one of the online forms and fax to
303-202-4693. A list of commercial dealers also is available at
www.mapping.usgs.gov/esic/usimage/dealers.html/. For more information or ordering assistance,
call 1-800-HELP-MAP, or write:
USGS Information Services
Box 25286
Denver, CO 80225
For additional information, contact any USGS Earth Science Information Center or call
1-800-USA-MAPS.
4.5 DOCUMENTATION
You need to maintain onsite the following records on the offsite consequence
analyses:
For the worst-case scenario, a description of the vessel or pipeline selected as worst-
case, assumptions and parameters used and the rationale for selection; assumptions
include use of any administrative controls and any passive mitigation systems that
you assumed to limit the quantity that could be released.
For alternative release scenarios, a description of the scenarios identified,
assumptions and parameters used and the rationale for the selection of specific
scenarios; assumptions include use of any administrative controls and any mitigation
that were assumed to limit the quantity that could be released. Documentation
includes the effect of the controls and mitigation on the release quantity and rate.
You can reference this guidance if you use any of the "canned" scenarios described
herein.
Other data that you should maintain includes:
October 27, 1998
-------
!»>: < ' 1
Chapter 4
QfFsite Consgguence Analysis
4-44
.......... Ah,
......... g
h
....... H
...... L
fN-
•PS
:Pa
-.9
QR
Is
•JV
Po
e
Documentation of estimated quantity released, release rate and duration of
release. , | ]
Methodology used to determine distance to endpoints (it will be sufficient to
reference this guidance if you used it for that purpose).
Data used to identify potentially affected population and environmental
receptors1!"1 " '
4.6 SYMBOLS FOR CHAPTER 4
area of hole in pipe, in2
area of pool or diked area, ft2
specific heat of gas at constant pressure, Bru/lb/°F
specific heat of liquid, Btu/lb/°F
specific heat of gas at constant volume, Btu/lb/°F
distance to toxic or explosive endpoint, mi
diameter of hole in pipe or tank, fit2
Jncjlona! loss factor in equation for calculating the rate of discharge of liquid chlorine, sulfur
dioxide, or ammonia from a pipe, dimensionless
acceleratipn due to gravity, 32ft/s2
static head in a vessel, ft
latent heat of vaporization of a liquid, Btu/lb
maximum head space in a digester, ft
length of pipework, ft
venSlatiqn rate, room volumes/hr
gauge pressure, pounds per square inch gauge (psig)
absolute pressure, pounds per square inch absolute (psia)
mass released, Ib
mass that remains airborne for the case of a release of chlorine, sulfur dioxide, or anhydrous
firriTfirtnfa into a building, Ib
rate of release, Ib/min
mass spilled into a pool, Ib
radius o|"a 'digester, ft1 ' ' '
ratio of vapor pressure of ammonia over a pool of aqueous ammonia at temperature T to the
vapof pressure at 25 °C, dimensionless
temperature, °F or °C, depending on context
volume of a digester in a room, ft3
rri! ^Ljllill : ' ! J',,,1, ,j ,' & ... ,„ ', , „ ,„
difference in specific volume between gas and liquid, ftVlb
percent of methane in digester gas, dimensionless
ratio of specific heats, €,/€„ dimensionless
density of liquid, Ib/ft3
density of methane in digester gas, Ib/ft3
density of gas at pressure pa, Ib/ft3
room volume per unit mass of chlorine, sulfur dioxide, or anhydrous ammonia, fP/lb
approximately equal to
approximately
October 27, 1998
-------
Figure 4-1 Worst-Case Scenario-Predicted Distances to Toxic Endpoint
For Chlorine @ Atmospheric Stability Class F with Windspeed 1.5 m/s
10
100
Rate of Release (Ibs/min)
2000 5000 20000 50000
1000 10000 100000
rural
urban
Model Limit
-------
Figure 4-2 Worst-Case Scenario - Predicted Distances to Toxic Endpoint
For SO2 @ Atmospheric Sability Class F with Windspeed 1.5 mis
0.01 !
10
500 1000 200°
100
Rate of Release (Ibs/min)
5000 ' j 20000 50000 ! I !
10000 100000
•rural
•urban
-Model Limit
-------
Figure 4-3 Worst-Case Scenario - Predicted Distances to Toxic Endpoint
Anhydrous Ammonia @ Atmospheric Stability Class F with Windspeed 1.5 mis
100.00
10
50
' I ' M I I i
100 20° 50° looo
Rate of Release (Ibs/min)
\ ! '! ! i i Ij
2000 500° 10000 2000° 5000° 100000
I rural
urban
Model Limit
Power (rural)
-------
Distance To Toxic Endpoint (miles)
•£ 31
§c tp
,„«=
II
© i
CD
3; w
3 o
O CD
W 3
T3 fi)
CD 5'
!*
g|
SM O '"'
«P»« rf*
^ o
^« Q^»
Q b'
II
- I
If
Is1
l"_i ;
3
-------
10.00 i
0.01
Figure 4-5 Alternative Case Scenario - Predicted Distances To Toxic Endpoint
For Chlorine @ Atmospheric Stability Class D with Windspeed 1.5 m/s
, i
10
;-H- RURAL
i-*~ URBAN
100 20°. 50° 1000 200°
Rate Of Release (Ibs/min)
5000
10000
20000
50000
100000
-------
MOM
5 4-
Figure 4-6 jAiternative Case Scenario - Predicted Distances To Toxic Endpoint
For SO2 @ Atmospheric Stability Class D with Windspeed 1.5 m/s
Rate Of Release (Ibs/min)
?-
-------
10.0000
5 _
0.0100 •
1
Figure 4-7 Alternative Case Scenario - Predicted Distances To Toxic Endpoint
For Anhydrous Ammonia @ Atmospheric Stability Class D with Windspeed 1.5 m/s
100
Rate Of Release (Ibs/min)
5000 1QOO() 20000 50000
i -4- RURAL
I-*-URBAN
-------
5 " M!
==- rt= =:--* =
j
1:0.00
Figure 4-8 Alternative Case Scenario - Predicted Distances To Toxic Endpoint
For Aqueous Ammonia© Atmospheric Stability Class D with Windspeed 1.5 mis
0.01
10
20
50
100
Rate Of Release (Ibs/min)
-4-RURAL I
-Hi-URBAN
-------
Yes
Release
Rate
O.lMlb/min
ease\ Yes Calculate
»ely > e = V/M
nor /
Nn
Calculate
e = V/(0.2M)
Airborne
Mass
M -M
a
Airborne
Mass
Ma = 0.4M
Calculate FR10
Table 4- 17 or 4- 18
Release Rate
to outside
0.1FR10Ma
Ib/min
Figure 4-9. Guidance on Effectiveness of Building Mitigation for Alternative Scenarios
-------
Fitjure 4-10 Simplified Presentation ofWorst-Case
::;E ~ ^ ' and Alternative Scenario on a Local Map
Facility Boundary
Radius for
Alternative
Scenario
Radius for
Worst-case Scenario
-------
4-55
Chapter 4
Offsite Consequence Analysis
APPENDIX 4A
EQUATIONS
AMMONIA PARTIAL PRESSURE
The ratio R^CD of the partial pressure of ammonia at temperature T °C to the partial pressure at 25 °C is
given by the empirical formula:
= exptlO.438 - 717.4/(T + 273.4) - 2132.5/(T + 240.25)]
DENSITY OF METHANE IN DIGESTER
pm = (X/100)(0.0409)(537/(460+T)) = 0.22 X/(460+T)
where 0.0409 Ib/ft3 is the density of pure methane at 77 °F (25 °C) and the factor 537/(460+T) represents
how the density changes with temperature, assuming that methane obeys the perfect gas law. The effect
of the small operating pressure in compressing the gas has been ignored.
ALTERNATIVE RELEASE EQUATIONS
Bernoulli's Formula
The rate of release of a liquid through an hole is given by Bernoulli's formula for predicting the rate of
release QR (Ib/min) of liquid from a vessel:
=Ah C/Pl[2g p,(/4 -
where: m
g
Pi
PO
Pa
HL
2(P0 - PJ}?
Discharge rate (kilograms per second)
Opening area (square meters)
Discharge coefficient (unitless)
Gravitational constant (9.8 meters per second squared)
Liquid density (kilograms per cubic meter)
Storage pressure (Pascals)
Ambient pressure (Pascals)
Liquid height above bottom of container (meters)
Height of opening (meters)
(A-l)
To create the equations in the text, this equation was converted to English units.
Gases Liquefied under Pressure
For gases liquefied under high pressure, the term containing the liquid height in Equation A-l can be
neglected. The equation for the release rate for gases liquefied under pressure becomes:
QR = 32.07x^xplx(p /p,)'
,0.5
(A-2)
October 27, 1998
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» t:::,,!',!, I" 'til1'" i,!1!!!'1
li %
Chapter 4
Offsite Consequence Analysis
4-56
To derive the chemical specific factors presented in the text for gases liquefied under their vapor pressure
at 25 °C, the following data were substituted into Equation A-3:
i;.];.;^1:"]!!11';; ^ rir •$•.';,' ; ' '-'.^ Fi^K •';:!'' ••On^ilMt *•$•. •!& ^ "•: IJ
Liquefied Gas Liquid Density (p,). Ibs/ft* Tank Vapor Pressure (P£). psig
CMprine
,
Sulfur dioxide
•ilil1' '! III1 . ' i V T'li'll;1 !
97.5
', ' ' 91.3
^Ammonia 42.5
Liquid at Ambient Pressure
98.5
„!,!, „', i , i I'j1,,1; , I ; j, j, •; , ';;„„'
'':!!: ' :• "'I l!l!ii " III fllf , , ;•, >i1
43.3
,"3" •',• ' ! „:"• I !:"i,;'I tf1'" , i!;'1'
"'"130"'
iJ ,|!lii||||||||!l' -fin vv ;•
1"' I'1 MI B1 '"..Ml1 /li!'1"!
For liquids stored at ambient pressure, the difference between storage pressure and ambient pressure is
zero, and the pressure term drops out of Equation A-l above. The equation can be rewritten and
converted to English units as follows:
QR=132.2x^Ax6.4516xlO-4x(^;0-5x0.5521x0.8x(2x9.8)°-5xpLxl6.018
(A-3)
where: QR
132.2
Hi
6.4516 xlO-4
0.5521
i| >/; " ''
0.8
9.8
PL
1 6.0l 8
Release rate (pounds per minute)
Conversion factor for kilograms per second to pounds per
minute ^ _ .
liole area (square inches)
Conversion factor for square inches to square meters (H/i)
Conversion factor for square root of feet to square root of meters
Discharge coefficient (0.8)
Gravitational constant (metersiper second squared)
Liquid density (pounds per cubic foot)
Conversion factor for pounds per cubic foot to kilograms per
cubic meter
For ammonia solution, the factor presented in the text was derived assuming a density of 57.33 Ib/ft3.
Two-Phase Release
For long pipes (L/dh » 1, where L is the length of the pipe between the reservoir of chlorine and the
atmosphere and dh is the pipe diameter), there can be flashing in the discharge pipe, and a two-phase
mixture emerges to the atmosphere. In this case, the rate of release in Ib/min is given by:
QR = 9,490(Ah)(F)(hL)/[vlg([T + 460]Cpl)*]
where those symbols not already defined are:
(A-4)
October 27,1998
I II |l| |lll
-------
4-57
Chapter 4
Offsite Consequence Analysis
F a frictional loss factor, which is dimensionless and takes on a value of 1 for L/dh= 10,
0.85 for L/dh * 50, 0.75 for L/dh * 100, 0.65 for L/dh =200, and 0.55 for L/dh * 400.
hL the latent heat of vaporization (Btu/lb)
Vjg the difference in specific volume between the gas and liquid (Ib/ft3)
T the reservoir temperature (°F), and
Cpi the liquid heat capacity (Btu/lb/°F)
For chlorine, hL is 124 Btu/lb, vlg = 0.68 Ib/ft3, T = 77 °F (25 °C), and Cpl = 0.222 Bru/lb/°F.
For sulfur dioxide, v,g = 1.55 fWlb, hL = 80 Btu/lb, cpl = 0.34 Btu/lb/°F.
Vapor Releases
For a gas release under choked flow conditions (i.e., emerging at the speed of sound from the hole, the
maximum flow rate), the following equation can be used to estimate the release rate:
m = CdAh(jp0
(A-5)
where: m
Cd
Ah
Y
Po
Po
Discharge rate (kg/s)
Discharge coefficient
Opening area (m2)
Ratio of specific heats
Tank pressure (Pascals)
Density (kg/m3)
Density (p0) can be rewritten as a function of pressure and molecular weight, based on the ideal gas law:
Po = (p0*MW)/R T, (A-6)
where: MW =
R =
Tt =
Molecular weight (kilograms per kilomole)
Gas constant (8,314 Joules per degree-kilomole)
Tank temperature (K.)
The choked flow equation can be rewritten and converted to English units as follows:
QR = 752.2xAhx6.4516xl0^xpax6895x0.8(Y[2/(Y+l)](^1)/(Y-1))°-5x(Jl^7537¥x7;)0-5
(A-7)
where: 0.8 =
1 32.2 =
6,895 =
6.4516x10^ =
Pa =
Ah =
Discharge coefficient
Conversion factor for Ibs/min to kg/s
Conversion factor for psi to Pascals (p0)
Conversion factor for square inches to square meters
Absolute pressure in the reservoir/tank (psia)
Hole area (inches)
To derive the chemical-specific factors for gas releases presented in the text, the temperature (T,) was
assumed to be 298 K, and the following chemical-specific data were substituted into Equation A-2:
October 27, 1998
-------
mi „'!, t ' r
I ill. „,'!';in.:! /I'
it"! .It, 1", ,'i
Chapter 4
Offsite Consequence Analysis
4-58
ii i i 11 fail" irii; H'l-p.1.;:? : ; ''•''. i i
Gas Molecular Weight CMW) Tank Pressure (T.) (psial
['chlorine ' ""'!":!l" ^ " 70.91 ' ' 113
Sulfur dioxide 64.07 58
LOG-LOG TABLE EQUATIONS
'.I ' ' '
Ratio of Specific Heats (V)
1.32
1.26
|tllus'section'presents formulas for estimating the distance to the endpoint fix»m the rate of release for
each ofthe toxicsubstances addressed in this document. The formulas are given in the form:
D = a (QR)b
I1,'! , '' . ' ' 'si "'
where: D
,,;f . i t , ,u (A-*)
i".ll,' ' ,'-' I: '? 'j, ;' i /! 'I l'|; ' Jl , i ij"'!;!;'!: , ' "1,'ii'S, i'i;:,; »"'"i1: V'l'li*
distance to the endpoint (miles)
a and b = chemical-specific factors
QR = release rate (Ibs/min)
The formulas for each chemical were developed based on the best straight-line fits to the log-log graphs
of release rate versus distance (Figures 4-1 to 4-8). The formulas are easy to use with a scientific
calculator and may be used instead of the distance tables or figures. Since the equations are best fits to
the curves on Figures 4-1 to 4^8, they may not give exactly the same predictions as appear in the
corresponding exhibits.
Chlorine
Worst Case. The guidance on Figure 4-1 is essentially in the form of a straight line on a log-log plot:
D = 0.2273(QR)°'4879 for a rural site, and
D = 0.0878(QR)°-5134 for an urban site
f Alternative., Figure 4-5 is roughly a straight line on a log-log plot:
::::!;" „', ';..=: j™ g = 0,053(QR)°-4647 for a rural site, and
D = 0.026(QR)°-4263 for an urban site.
';,„ \\: f j: , •"" | "Si jji; i pfiii;;11 i " i • i i,' , i • . ' i. - " " * i M
i, 'i ' !! r i' J,,!,,, |l!'! J1 IB,!! Iliii'l! ' lii , :. • ,"' . ' .',i'., '
Sulfur Dioxide
Worst Case. The guidance on Figure 4-2 is essentially in the form of a straight line on a log-log plot:
D = 0.165(QR)0'5562 for a rural site, and
D = 0.0726(QR)a5419 for an urban site.
^Alternative. The curves on Figure 4-6 are approximately straight lines on a log-log plot:
D = d.047(QR)°-4961 for a rural site, and
October 27,
ill ' ' , 1 ', li||£ II4T
''iliii1,,1!,. • I njiiiliii1;: „£.',
•Eli;
-------
Chapter 4
4-59 Offsite Consequence Analysis
D = 0.025(QR)°-4407 for an urban site.
Anhydrous Ammonia
Worst Case. The guidance on Figure 4-3 is essentially in the form of a straight line on a log-log plot:
D = 0.0607(QR)°-4923 for a rural site, and
D = 0.0443(QR)°-4782 for an urban site.
Alternative. The curves.on Figure 4-7 are approximately straight lines on a log-log plot:
D = 0.0222(QR)°-4780 at a rural site, and
D = 0.0130(QR)°-4164 at an urban site.
Aqueous Ammonia
Worst Case. The guidance on Figure 4-4 is essentially in the form of a straight line on a log-log plot:
D = 0.0667(QR)°-4617 for a rural site, and
D = 0.0221(QR)°-4712 for an urban site.
Alternative. The curves on Figure 4-8 are roughly straight lines on a log-log plot:
D = 0.02(QR)°-5174 for a rural site, and
D = 0.0107(QR)°-4748 for an urban site.
October 27, 1998
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Chapter 4
Offsite Consequence Analysis
4-60
':'•• APPENDIX 4B
LIMITATIONS OF RESULTS
The guidance in the present document is summarized in the form of various tables and plots giving the
predicted distance to the toxic endpoint as a function of the rate of release. There are upper and lower
limits on the validity of these tables and plots—the models used are not valid beyond 25 miles, nor at less
than 6.06 mile (100 m~ 300 feet}. It should be noted mat the guidance presented in this chapter in the
form of plots and tables yield predictions that are among many possible. There is, in fact, a wide range
»;; of uncertainty, partly due to the still incomplete theoretical understanding of the atmospheric dispersion
of large-scale accidental releases of hazardous vapors in the industrial environment, partly due to the
need to specify the values of a number of parameters, the values of which may not be well known, and
partly because there are relatively few large-scale experimental data sets with which to "tune" the
models, especially for the conditions applicable to the worst-case scenario. Therefore, for any given rate
of release of a specific material, such as chlorine, there may be a wide variety of predictions by analysts
using different models, or using the same model with different input parametersi The potential range of
• uncertainty is addressed in the Backup Document.
MI 14 , . . ,, '»' , "i "i, iJK. .1, lOEili' I1"" . ', i,,, I: ,i; ,'.'"'• "'• '«: ,,' • ,,, . :• ,,i;f ,, ' . " , i\\'"\t\\i |i' > i ,, , ',' ,; '"r • .'i1!,: , ' i.llifi,1' iKusi «,,!!llL iljft,,', "I,,, I,,,» i: •, • • • , V.:." T «i i: J'r 1 !'"' II ,„
An attempt has been made to develop guidance in the mid-range of possibilities, with the hope that the
most extreme conservatisms have been removed, but which is still modestly conservative. As a general
^'([anSmulcSllMmplified) rule, you should nofbe surprised if, for worst-case' scenarios!, offier analysts and
models produce predictions that may be up to a factor of three higher or a factor of three lower than those
presented here.
The predictions in the distance tables in the exhibits and all other predictions in this report for regulated
toxic chemicals are based upon the methods described in the Backup Document. That method consisted
of performing a range of sensitivity studies and then choosing guidance that lies within that range.
There are a number of caveats of which you should be aware.
•""The results given in the exhibits and figures are not in any absolute sense the "right" or "correct" ones.
Pn the cpn&ary, the Backup Document contains predictions from many sources. The intention there is to
rFfcgtabiish a rangeof uncertainties that might be regarded as reasonable by practitioners in the field of
atrnQspheric dispersion modeling, and then to locate a reasonable guidance curve (such as Figure 4-1)
within that range of uncertainty. In this way, it is hoped that the following objectives will be achieved:
i K
.facts that the results are uncertam and mat mere is no uniquely "right" result are not
disguised.
•f- Nevertheless, there is a reasonable solution that is easy to use, and users of this guidance
do not have to understand its derivation.
As noted above, the further downwind, the more likely it is that you are beyond the range of applicability
of any atmospheric dispersion model. That is why, for the 90-ton railcar release of chlorine, the result is
stated as '^ 25 miles." For such a large release of chlorine, it is unlikely that you will find any model
that will predict any less than this distance, and some will predict considerably more. There is no way to
avoid the conclusion that the distance to the toxic endpoint for a worst-case release from a 90-ton
chlorine railcar is very large, even though the current state of the models does not allow us to say exactly
how far "large" is. Note that the discussion in this paragraph applies to railcars that are in the open air.
October 27,1998
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4-61
Chapter 4
Offsite Consequence Analysis
For the 150-lb and one-ton cylinder case, the results are uncertain to within perhaps a factor of 5-10. The
Backup Document shows that, under certain modeling assumptions, the predicted distances could be
perhaps a factor of three larger than those stated above or a factor of three smaller. You will also ahnost
certainly be able to find a computer model that can be run to produce even smaller predicted distances. If
you opt to do that, you will have to produce justification that the modeling is reasonable. [Note,
however, that you are not obliged to use the guidance presented here; you can use whatever model you
want provided that you have a solid scientific basis for doing so]. The fact that these large uncertainties
exist explains why it is so difficult to develop a single guidance curve that everyone accepts. Many
different choices for the guidance could fit comfortably within the range of uncertainties.
October 27, 1998
-------
iij;!!lf i'
II
t'H'!',: :!,.;:' •"•!!• ^"il
iiliih ti -;:!: .•' "i! . ;,i!
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(1
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THIS PAGE INTENTIONALLY LEFT BLANK
-------
CHAPTER 5: MANAGEMENT SYSTEM
5.1 GENERAL INFORMATION (§68.15)
If you have at least one Program 2 or Program 3 process (see Chapter 2 for guidance
on determining the Program levels of your processes), the management system
provision in § 68.15 requires you to:
Develop a management system to oversee the implementation of the risk
management program elements;
Designate a qualified person or position with the overall responsibility for the
development, implementation, and integration of the risk management program
elements; and
Document the names of people or positions and define the lines of authority through
an organizational chart or other similar document, if you assign responsibility for
implementing individual requirements of the risk management program to people or
positions other than the person or position with overall responsibility for the risk
management program.
ABOUT THE MANAGEMENT SYSTEM PROVISION
Management commitment to process safety is a critical element of your facility's risk
management program. Management commitment should not end when the last word
of the risk management plan is composed. For process safety to be a constant
priority, your facility must remain committed to every element of the risk
management program.
This rule takes an integrated approach to managing risks. Each element must be
implemented on an ongoing, daily basis and become a part of the way you operate.
Therefore, your commitment and oversight should be continuous.
By satisfying the requirements of this provision, you are ensuring that:
+ The risk management program elements are integrated and implemented on
an ongoing basis; and
+ All groups within a source understand the lines of responsibility and
communication.
5.2 HOW TO MEET THE MANAGEMENT SYSTEM REQUIREMENTS
We understand that the sources covered by this rule are diverse and that you are in
the best position to decide how to appropriately implement and incorporate the risk
management program elements at your facility; therefore, we sought to maximize
your flexibility in complying with this program.
July 1998
-------
Chapters
" Management System
I"! n ;;i '. I !"';., iij.j'lllB1' "iSllBI1' "
5-2
m 1 H Ullll, H ..... ,: ',
DOES THIS MEAN FOR ME AS A SMALL FACILITY?
Ji.Si.'.pi'll ,.•!' . "», . i ' ,! I ' 1! in1 i, i,..'' . ' P. I f! 'Si I!, !, '' ' ..i, "'I! . ' .M , !" ' .'.Ifi'li1!1 In'
,.!;-, in t
<
1;
l!i ....... li'ih .....
EWF3
'lif
"
]' Ill B'
As a small facility that must comply with this provision, you most likely have one or
two Program 2 or 3 processes. To begin, you may identify either the qualified
person or position with overall responsibility for implementing the risk management
program elements at your facility. As a small facility, it may make sense and be
practical to identify the name of the qualified person, rather than the position.
^Recognize that the only element of your management system that you must report in
the RMP is the name of the qualified person or position with overall responsibility.
Further, changes to this data element in your RMP do not require that you update
'your "RMP.'1
Identification of a qualified individual or position with overall responsibility
may be all you need to do if the person or position named directly oversees the
, .'^'employees operating; and maintaining the processes. You must define the lines of
au&prity with an organizational chart or similar document only if you choose to
assign responsibility for specific elements of the risk management program to
persons of positions btfier than the person with overall responsibility. For a small
facility, with few employees, it is likely that'you will meet the requirements of this
provision by identifying the one person or position with the overall responsibility of
implementing the risk management program elements. If this is the case, you need
not develop an organisational chart. For this reason, this chapter does not provide an
example organisational chart for a small facility.
vjihifiM ,': I
tJhes
lei:
Even if you meet the requirements of this section by naming a single person or
'.' ;ii/ifi SjK 'position," it is important to recognize that the person or position' assigned the
, .,,,,„ UM. ^S:jj0'^kilityofoverseerngim^
ensure that your facility and employees carry out the risk management program,
,_" '"^|.. ;!!/ particularly Ine prevention dements, on an cpntinui^ Key to the
effectiveness of the rule is: integrated management of'the program elements.
i i1, nilllllll HIIIHII!" , Sinn • .Hi. ' ivli,1" •'' i":111!1 .:,!'.I1 „ 'i.| 'ip, ' • i"1, ' , W B"1,'",,1!*,,!!!!!!, niii.PhiP'liPil.iilT Pil'id'J ,.»! h'1." hi,„."..! I1": !,' •,: ",'" I1!"
WHAT DOES THIS MEAN FOR ME AS A MEDIUM OR LARGE FACILITY?
As a medium or large facility you may have more managerial turnover than smaller
sites, For this reason, it may make more sense at your facility to identify a position,
rather than the name of the specific person, with overall responsibility for the risk
management program elements. Remember that the only element of your
management system that you must report in the RMP is the name of the qualified
person or position with overall responsibility. Also note that changes to this data
element in your RMP do not require you to update your RMP.
of Authority
Rat
J_
;E$iOTnnJ3i"I Process
As a relatively large or complex facility, you will likely choose to identify several
people or positions to supervise the implementation of the various elements of the
program; therefore, you must define the lines of authority through an organizational
chart or similar document. Further, we expect that most facilities your size already
have an interest in formalizing internal communication and have likely developed
™ and maintained some type of documentation defining positions and responsibilities.
Any internal documents you currently have should be the starting point for defining
July 1998
-------
5-3
Chapter 5
Management System
the lines of authority at your facility. You may find that you can simply use or
update current documents to satisfy this part of the management system provision.
Exhibit 5-1 provides a sample of another type of documentation you may use in
addition to or as a replacement for an organization chart.
Defining the lines of authority and roles and responsibilities of staff that oversee the
risk management program elements will help to:
4- Ensure effective communication about process changes between divisions;
4- Clarify the roles and responsibilities related to process safety issues at your
facility;
4- Avoid problems or conflicts among the various people responsible for
implementing elements of the risk management program;
4- Avoid confusion and allow those responsible for implementation to work
together as a team; and
4- Ensure that the program elements are integrated into an ongoing approach to
identifying hazards and managing risks.
Remember that all of the positions you identify in your documentation will report
their progress to the person with overall responsibility for the program. However,
nothing in the risk management program rule prohibits you from satisfying the
management provision by assigning process safety committees with management
responsibility, provided that an organizational chart or similar document identifies
the names or positions and lines of authority.
July 1998
-------
Chapter 5
Management System
I ii ci
• ^» --*- i^Jf
EL
™ -
5-4
Jl!
= t = _-_-: f =. - - =„ .- = =•==-_•=,==
»>t n: i*
« «
'
^ N,i:
i. i= -^tt -ii*
Position
Operations Manager
Training Supervisor
Maintenance Supervisor
Hazmat Team Chief
EXHIBIT 5-1
SAMPLE MANAGEMENT DOCUMENTATION
Primary Responsibility
Developing OPs
Oversight of operation
On-the-job training
On-the-job competency testing
Process Safety Information
Selecting participants for PHAs,
incident investigations
Develop management of change and
pre-startup procedures
Develop, track, oversee operator
training program
Track competency testing
Set up and track operator refresher
training
Set up training for maintenance
Work with contractors
Develop maintenance schedules
Oversee and document maintenance
Revise schedules as needed
Develop and exercise ER plan
Train responders
Test and maintain ER equipment
Coordinate with public responders
Select participants in accident
investigations
Changes
New Equipment
New Process Chemistry
New Process Parameters
New Procedures
Change in Process Utilization
New Equipment
New Process Chemistry
New Process Parameters
New Procedures
Change in Process Utilization
New regulatory requirements
New Equipment
New Process Chemistry
New Process Parameters
New Procedures
Change in Process Utilization
New Equipment
New Process Chemistry
New Process Parameters
New Procedures
Change in Process Utilization
New regulatory requirements
Responsibility re: Changes
Inform head of training
Inform head of maintenance
Inform lead for PHAs
Inform hazmat team as needed
Inform contractors
Revise training and refresher training
courses
Revise maintenance courses, as needed
Inform other leads of need for
additional training
Inform operations manager of potential
problem areas
Inform training supervisor of any
training revisions
Inform contractors
Revise schedules
Revise the ER plan as needed
Inform operations manager of problems
created by changes
Work with training supervisor to revise
training of team and others
Tie
Jii i
in;
1: . •
July 1998
-------
5-5
Chapter 5
Management System
EXHIBIT 5-1
SAMPLE MANAGEMENT DOCUMENTATION
Position
Primary Responsibility
Changes
Responsibility re: Changes
Health and Safety Officer
Oversee implementation of RMP
Develop accident investigation
procedures
Oversee compliance audits
Develop employee participation
plans
Conduct contractor evaluations
Track regulations
New Equipment
New Process Chemistry
New Process Parameters
New Procedures
Change in Process Utilization
New regulatory requirements
Inform all leads of new requirements
and assign responsibilities
Ensure that everyone is informed of
changes and that changes are
incorporated in programs as needed
July 1998
-------
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-------
CHAPTER 6: PREVENTION PROGRAM (PROGRAM 2)
6.1 ABOUT THE PROGRAM 2 PREVENTION PROGRAM
EPA developed the Program 2 prevention program by identifying the basic elements
that are the foundation of sound prevention practices — safety information, hazard
review, operating procedures, training, maintenance, compliance audits, and accident
investigation. By meeting other Federal regulations, state laws, industry codes and
standards, and good engineering practices, you probably have already met most of
the Program 2 prevention elements requirements.
As important as each of the elements is, you will not gain the full benefit from them
unless you integrate them into a risk management system that you implement on an
on-going basis. For example, the hazard review must be built on the safety
information; the results of the hazard review should be used to revise and update
operating and maintenance procedures. Workers must be trained in these procedures
and must use them every day.
You will have substantially less documentation and recordkeeprng responsibilities
for a Program 2 process than you will for a Program 3 process. There are seven
elements in the Program 2 prevention program, which is set forth Subpart C of part
68. Exhibit 6-1 sets out each of the seven elements and corresponding section
numbers.
You must integrate these seven elements into a risk management program that you
and your staff implement on a daily basis. Understanding and managing risks must
be part of the way you operate. Doing so will provide benefits beyond accident
prevention. Preventive maintenance and routine inspections will reduce the number
of equipment failures and down time; well-trained workers, aware of optimum
operating parameters, will allow you to gain the most efficient use of your processes
and raw materials.
6.2 SAFETY INFORMATION (§ 68.48)
The purpose of this requirement is to ensure that you understand the safety-related
aspects of the equipment and processes you have, know what limits they place on
your operations, and adopt accepted standards and codes where they apply. Having
up-to-date safety information about your process is the foundation of an effective
prevention program. Many elements (especially the hazard review) depend on the
accuracy and thoroughness of the information this element requires you to provide.
October 27, 1998
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Chapter 6
Prevention Pipgram (Program 2)
6-2
EXHIBIT 6-1
SUMMARY OF PROGRAM 2 PREVENTION PROGRAM
ill
i»E 'SB;«!?«
•Number
§ 68.48
§ 68.50
§ 68.52
§ 68.54
§ 68.56
§ 68.58
§ 68.60
Section Title
Safely Information
Hazard Review
Operating Procedures
Training
Maintenance
Compliance Audits
Incident Investigation
WHAT Do I NEED To Do?
You must compile and maintain safety information related to the regulated
substances and process equipment for each Program 2 process. You probably have
much of this informationalready as a result of complying with OSHA standards or
other rules. EPA has limited the information to what is likely to apply to the
processes covered under the Program 2 program. Exhibit 6-2 gives a brief summary
of the safety information requirements for Program 2.
How Do I START?
MSDSs. If you are subject to this rule, you may also be subject to the requirements
to maintain Material Safety Data Sheets under the OSHA Hazard Communication
Stand^(HCiS)(29CFRi9ioll200)."POTWsin states 'with'"delegatedbSHA
programs and all private WWTPs are subject to OSHA's HCS.
If you do not have an MSDS for a regulated substance, you should contact your
supplier or the manufacturer for a copy. Because methane (CH4) is generated in your
plant, you will have to find an MSDS elsewhere. A local utility supplying natural
gas may have one. You may, however, have to add the potential for inclusion of
carbon dioxide, hydrogen sulfide, and water in the methane stream. If these are
present, then the corrosivity information about that stream will be needed. You may
wish to ask assistance from a process engineer.
Because the rule states that you must have an MSDS that meets OSHA requirements,
you may want to review tKe MSDS to ensure that it is, in fac£ complete. Besides
providing the chemical name, the MSDS for a regulated substance (or a mixture
containing the regulated substance) must describe the substance's physical and
October 27,1998
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6-3
Chapter 6
Prevention Program (Program 2)
chemical characteristics (e.g., flashpoint, vapor pressure), physical hazards (e.g.,
flammability, reactivity), health hazards, routes of entry, exposure limits (e.g., the
OSHA permissible exposure level), precautions for safe handling, generally
applicable control measures, and emergency and first aid procedures. (See 29 CFR
1910.1200(g) for the complete set of requirements for an MSDS.)
EXHIBIT 6-2
SAFETY INFORMATION REQUIREMENTS
You must compile and
maintain this safety
information;
•Material Safety Data
Sheets
•Maximum intended
inventory
•Safe upper and lower
parameters
•Equipment specifications
•Codes & standards used to
design, build, and operate
the process
You must ensure:
•That the process is designed
in compliance with
recognized codes and
standards
You must update the safety
information if;
•There is a major change at
your business that makes the
safety information inaccurate
Maximum Inventory. You must document the maximum intended inventory of any
vessel in which you store or process a regulated substance above its threshold
quantity. The U1A certificates on all vessels constructed under the ASME Boiler
and Pressure Vessel Code are kept on file by the National Board (see chapter 1).
The nominal nameplate capacity can also be found on the permanently attached
nameplate for your storage tank. The nameplate will also have the National Board
Number for your vessel, which is the key to retrieving your JJ1A form from the
Board. These nameplates may be located on one of the hemispherical heads, the
manway, or the manway cover. The nominal capacity will usually be the water
capacity, and you may want to convert it to pounds.
If you use transportation containers (railcars or tank trucks) as storage vessels, you
can obtain the capacity from the required DOT nameplate, identification plate, or
specification plate or from the owner of the containers. Smaller shipping containers
are also marked. If you are not sure of the capacity of the vessel, you can obtain this
information from the manufacturer of the vessel or tank.
The Chlorine Institute recommends that chlorine tanks not be filled beyond 95
percent at a maximum temperature of 122 °F. OSHA regulations limit liquid
volumes of unrefrigerated anhydrous ammonia to the following:
October 27, 1998
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ii>iHii
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Chapter 6
faeyention Program (Program 2)
6-4
Type of Container
Aboveground-Uninsulated
Aboveground-Uninsulated*
Aboveground-Insulated
Underground-Uninsulated
Percent by Weight
56%
57%
58%
Percent by Volume
82%
87.5%
83.5%
85%
Eli
ill.!'*
*Aboveground uninsulatedcontainers may becharged to 87.5 percent by volume if
the temperature of* the anhydrous ammonia being charged is determined to be not
'i'fji' i ijljjj lower than|i3p0F or.if the ..charging container is stooged at the first indication of frost
or ice formation on its outside surface and is not resumed until such frost or ice has
disappeared. (29 CFR 1910.111(b)(ll))
Aqueous ammonia may be held in various concentrations; your supplier can provide
the density and weight. You can use this information, with your tank capacity, to
estimate the quantity of ammonia being stored.
The Compressed Gas Association provides the following recommendations for
''* ' t'tLr i::|i!! filling sulfur dioxide tanks at varying temperatoes (CGApampmetG-3):
IM:'l!: iMf a-.^!''':';''T;..:i:i 1 <>:•:
Temperature of Liquid SO2 in Tank °F
30
40
50
60
70
80
90
100
IK" i f.\ i iiinr " 'ii. ',•!• i.: ' 'iiVLill, ' ' J '
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6-5
Chapter 6
Prevention Program (Program 2)
vendor, the substance manufacturer, or your trade association. They will be able to
provide the data you need. Some of this information (e.g., maximum pressure) may
be marked on the nameplate or container. It is important that you know these limits
so you can take action to avoid situations where these limits may be exceeded. Many
people are aware of the dangers of overheating their vessels, but extreme low
temperatures also may pose hazards you should know about.
If you are moving substances through pipes or hoses, you need to define safe
temperatures and pressures for that movement; again, these limits will be determined
by both the substance and the piping. For example, the substance may tolerate high
pressures, but the pipes may have structural limits. To operate safely, you must have
this information. The pipe manufacturer will be able to provide these data.
The requirement to compile and maintain information on process flows and
compositions will apply to you if you transfer substances through piping or hoses
and if you mix or react the substance. It is important in these cases that you
understand the safe limits for flow and composition. The pipe or hose vendors will
be able to provide you with the maximum flow rates that their products are designed
to handle. You must also be aware of any hazards that could be created if your
processes are contaminated; for example, if your substance or equipment could be
contaminated by water, you must know whether that creates different hazards, such
as corrosion. Chlorine and SO2 become very corrosive if mixed with water. In
addition, corrosion can occur in digester gas systems if attention is not paid to the
corrosive effects of hydrogen sulfide and water that are found in digester gas.
Equipment Specifications. You must document the specifications of any
equipment you use to store or move regulated substances in a covered process.
Equipment specifications will usually include information on the materials of
construction, actual design, and tolerances. The vendor should be able to provide
this information; you may have the specifications in your files from the time of
purchase. Some of this information (e.g., wall thickness) may be marked on the
nameplate or container. You are not expected to develop engineering drawings of
your equipment to meet this requirement, but you must be able to document that your
equipment is appropriate for the substances and activities for which it is used, and
you must know what the limits of the equipment are.
Specifications are particularly important if your vessels or pipes are not specifically
designed for your type of operation. Substances may react with certain metals or
corrode them if water is introduced. You should be sure that the vessels you
purchase or lease are appropriate for your operations. Understanding equipment
specifications will help you when you need to buy replacement parts. Any such parts
must be appropriate for your existing equipment and your use of that equipment. It
is not sufficient to replace parts with something that "fits" unless the new part meets
the specifications; substitution of inappropriate parts may create serious hazards.
Codes and Standards. You must document the codes and standards you used to
design and build your facility and that you follow to operate. These codes will
probably include the electrical and building codes that you must comply with under
October 27, 1998
-------
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!":':"/;;::ijii:!{;: iill miA
« infi)imation. Your'MS^ You only have to
keep them on file, as you already do for OSHA if you are subj ect to the OSHA
" '] '' :|M Nl1 AH"1! !i !ilil'
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-------
6-7
Chapter 6
Prevention Program (Program 2)
hazard communication standard (29 CFR 1910.1200). Equipment specifications are
usually on a few sheets or in a booklet provided by the vendor; you need only keep
these on file. You can probably document the other information on a single sheet that
simply lists each of the required items and any codes or standards that apply. See
Exhibit 6-4 for a sample developed for EPA's guidance for propane storage facilities.
Maintain that sheet in a file and update it whenever any item changes or new
equipment is added. Although the rule does not require you to create a process flow
diagram, you may want to do this as another way of documenting much of this
information.
EXHIBIT 6-4
SAMPLE SAFETY INFORMATION SHEET
-'.,'. N : ,-- ,.>_.,- <. •
MSDS Propane
Maximum Intended Inventory
Temperature
Pressure
Flow Rate
Vapor Piping
Liquid Piping and Compressor
Discharge
Safety Relief Valves
Excess Flow Valve
Emergency Shutoff Valve
Codes and Standards
Piping Design
Tank Design
„ PROPANE STORAGE ^
On file (1994)
400,000 pounds
Upper: max 110°F
Lower: min-15°F
Upper: 240 psi@110°F .
Lower:35psi@-15°F
Loading: 100 GPM (max)
Unloading: 265 GPM (max)
250PSIG '.
350 PSIG
Each relieves 9,250 SCFM/air
RV 1 replaced 9/96
RV 2 replaced 6/97
RV 3 replaced 8/98
3", closes at 225 GPM with 100 PSIG inlet
2", closes at 100 GPM with 100 PSIG inlet
2", closes at 34,500 SCFH with 100 PSIG inlet
ESV 1 1/4", closes at 26,000 SCFH with 100 PSIG inlet
ESV 2", closes at 225 GPM with 100 PSIG inlet
Designed under NFPA-58-1985
ASMEB31-3
ASMENB#0012
October27, 1998
-------
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Chapter 6
IPreventibn Program (Program 2)
6-8
" liiliiiiiii": i
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The equipment specifications and list of standards and codes will probably meet the
requirement that you ensure that your process is designed in compliance with
recognized and generally good engineering practices. I? you have any doubt that you
are niseting this requirement, your trade association may be helpful in determining if
there are practices or standards tnat you are not aware of that may be useful in your
,» '"":•" ;,;:-"'•• sss operation.
,|...|i , .j"1''1!!1 Mil "I|L; IM , ' 'I;:1''';..! -"'..i1", ;;;"", 'i' "' i i in i i | !,„ ' ..^.L ' ,'""M », , ni ; ,,in" ...Z
'"'?;j ;•"-. ''S;|;i; • _ ™ i ^fter you have documented your safety information, you should double check it to
be sure that the files you have reflect the equipment you are currently using. It is
important to keep this information up to date. Whenever you replace equipment, be
sure that you put the new equipment specifications in the file and consider whether
any of your other prevention elements need to Be reviewed to reflect the new
equipment.
WHERE To Go FOR MORE INFORMATION
.-=, MSDSs. MSDSs are available from a number of websites. The University of
"i,;*1 .• ,','i.ni':; jii'i"' "/;:,"!!!' g j; j.gn. : 11|"i*1il Tr !' . .'i: ',>! initnii; u":' "i1'." v "ill1'1 illllii'Wiili inv... ":in. "I1: ,!i,;....'"HHH1' .. IMI I'Msim. „ n ..rui1 wi .^I't'imihiliii'ii''''!!*!!1" I H'Sii 'imiilii't. 111.1; nil; ' /; .... i1:::^! 'r-.1 .,,i ', •;
: J.:':; '^"f ':;^"f, JJJ i-iYOTnont provides access to three university-maintained MSDS collections through
its website, http://www.hazard.com. The on-line databases usually have multiple
'";""''":i'!""ivi"'""; ~ :! ™" ' copies of MSDSs for eacn substance 'and"can"help you find an'^§nS''mat is well
; ]:'f: ..;• , :j iijij; ^. ,:(pfganized 'and easy to read. EPA has not verified the accuracy or completeness of
MSbSs on any of these sites nor does it endorse any particular version of an MSDiS.
You should review any MSDS you use to ensure that it rneets the requirements of
"'':: •';•;'• .•' \ j^ l|: OSHA's'j^^_(xmnDD^tion standard J29 CFR 1910.120V>.
Guidance and Reports. Although the reports below target tiie chemical industry,
:."ti :i 'Hi I! '-ii1*'i'; f1' iir,, is, oil, ",: IT,,, .„• - ,-...• •SST. • .„, ..* „ r,., ,, • ..»,,' „ ,
you may find useful information in them:
:;':,,: i:
:> $ u, ''Hill"
•")''!• I1«'..(! '".WJ I. flf"1 I"11*' '!'"
iiiji! Utiit I 111
4- Guidelines for Process Safety Documentation, Center for Chemical Process
> , iii ii;:|| , i • " ; ••, ; .; , Sa|ety of the American Institute of Chemical Engineers 1 995.
+ Loss Prevention in the Process Industries, Volumes I, II, and III, Frank P.
I' , Ii"! ' I'ifS ...... ;." Mi""" ...... i ...... ; " . '; •;. ..... I i i i " i ' .... ..... . . ..... i ...... ..... •
'
,
": .......... Hi"
.
' i -; Lees, Butterworths: London 1996.
,';i Fill1
The Chlorine Institute publishes a number of documents on chlorine handling,
::"== 'I1!! inchiding:
4- Chlorine Vaporizing Systems, Pamphlet # 9.
4- Cylinder and Ton Container Procedures for Chlorine Packaging, Pamphlet #
4- Water and Wastewater Operators Chlorine Handbook, Pamphlet # 155.
II'' 11 I i •" > j';11" ^ ™; -';' I, I: '•. '•,: ^ '$, ;r | h} ^, $ , ^ y ^ f if; JS \
*'''M: ;''!!'! The Compressed Gas Association publishes: "
' i "iili: f II, lit „ ' ' • , ",: '• ", „ !•• if S : '• , " ' ' :t'S' i '" ! ''• '" ." '" ',>' < , :, vj ! ttM K.-J': >~> .'I, Mil HlJ ' K,K .„ - '.. ,, ,' && ', " • A Jl , \ • I
iirAin.!;, iiiniiv"! i :r';"..":.... IP h1 -I , , ','..; n.", , ,/ , „ >. ' .i,*1:,,11 .ijiniiiL"! ; '„ v n "I'l,!.1!!. -, ' ; „ iiiii.in,,,,rl ', 'vtfi ' ,"} ..ni! ,i
4- Sulfur Dioxide on properties, storage, handling, and use of sulfur dioxide
:::; :: :'::: ' •' ' ' (Order #G-3). \
4; ANSI K61.1 on the storage and handling of anhydrous ammonia (Order #G
•
April 19,2000
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-------
6-9
Chapter 6
Prevention Program (Program 2)
+ Anhydrous Ammonia on properties, storage, handling, and use of anhydrous
ammonia (Order # G-2).
i
The Water Environment Federations publishes the following:
4- Operation and Maintenance of Municipal Wastewater Treatment Plants
(MOP-11), Water Environment Federation.
6.3 HAZARD REVIEW (§ 68.50)
For a Program 2 process, you must conduct a hazard review. EPA has streamlined
the process hazard analysis (PHA) requirement of OSHA's PSM standard to create a
requirement that will detect process hazards for processes in Program 2. The hazard
review will help you determine whether you are meeting applicable codes and
standards, identify and evaluate the types of potential failures, and focus your
emergency response planning efforts.
WHAT DO I NEED TO DO?
The hazard review is key to understanding how to operate safely on a continuous
basis. You must identify and review specific hazards and safeguards for your
Program 2 processes. EPA lists the types of hazards and safeguards in the rule.
Exhibit 6-5 summarizes things you must do for a hazard review.
EXHIBIT 6-5
HAZARD REVIEW REQUIREMENTS
Conduct a review &
identify...
Use.a guide for
conducting the
review, ~ " - *,
Document results &
resolve problems.' ,
Update your hazard
review. „ r
•The hazards
associated with the
Program 2 process &
regulated substances.
•Opportunities for
equipment malfunction
or human error that
could cause a release.
•Safeguards that will
control the hazards or
prevent the
malfunction or error.
•Steps to detect or
monitor releases.
•You may use a
checklist.
•For a process
designed to industry
standards like NFPA-
58 or Federal /state
design rules, check the
equipment to make
sure that it's fabricated,
installed, and operated
properly.
•Your hazard review
must be documented
and you must show that
you have addressed
problems.
•You must update
your review at least
once every five years
or whenever there is a
major change in the
process.
•You must resolve
problems identified in
the new review before
you startup the
changed process.
October 27,1998
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Chapter 6
Prevention Program (Program 2)
6-10
WHAT METHOD SHOULD I USE?
ill
Hill
t ':
October 27,1998
This guidance provides information on three hazard evaluation methods:
i , - ., 'n ,'"!i "|l ', M „ II I III III
II' ' ' '!'' .i', I I III
+ Checklist
+ What-If/Checklist j
+ Hazard and Operability (HAZOP) Review
Checklist When your facility has been designed and built to comply with a federal
or state standard or an industry-specific design code, it may be possible to develop a
Checklist that, in and of itself, will be sufficient to conduct the hazard review.
Some sample checklists for chemicals at wastewater treatment facilities are provided
in the appendix to this chapter as follows:
Exhibit 6A-1
Exhibit 6A-2
Exhibit 6A-3
Exhibit 6A-4
Exhibit 6A-5
"
General Conditions, Operation and Maintenance
Human Factors
Checklists for Chlorine and Sulfur Dioxide
Checklist for Anhydrous Ainmonia Systems
Checklist for Aqueous Ammonia Systems
;::.;:".; • i i;;,,;™;^;'; .............. ;;„ ..... ,,;;; ...... ; ...... ,.,..:;.;,::;; ....... ;. , .,,4;,, ..... .,,, ..... ;;,:.. , „;. ; ,...:,;
mi t~ ,;•-. iii i1 ikfiV^iiii!!/! * -I," .•%•:.•'. i" ...... i:"1,'1'".; S'&s.'ii'i'iSrCifcii '?«,;: rijJrwi'iir!.! ......... : 'i. 'j'" i-""l»--" "• ' ' '•'.•' • ',•''.«' ....... '
Finally, you may also develop your own checklist or supplement those given in this
guidance to make sure they are appropriate for your site. The review must identify
the following:
1 " > ........ ' M:;!"!1:,:! = ' ..... ; .... • ...... == „. ..... i i i i i -'. .ri-i..';. • • •;.;.(
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6-11
Chapter 6
Prevention Program (Program 2)
process. The team uses the What-If Analysis technique to brainstorm the various
types of accidents that can occur within the process. The team then uses one or more
checklists to help fill in any gaps they may have missed.
The examples of What-If questions in Exhibit 6A-6 are derived from a variety of
sources, including:
+ "Guidelines for Hazard Evaluation Procedures - Second Edition with
Worked Examples," published by the Center for Chemical Process Safety
(CCPS), New York, 1992
+ Information collected from various wastewater treatment facilities during the
development of this guidance
+ Information from industry associations such as the Chlorine Institute and the
International Institute of Ammonia Refrigeration (IIAR), and
+ The American Water Works Association (AWWA).
Hazard and Operability Analysis. The Hazard and Operability (HAZOP) Analysis
technique is based on the principle that several experts with different backgrounds
can interact in a creative, systematic fashion and identify more problems when
working together than when working separately and combining their results.
Although the HAZOP Analysis technique was originally developed for evaluation of
a new design or technology, it is applicable to almost all phases of a process'
lifetime.
The essence of the HAZOP Analysis approach is to review process drawings and/or
procedures in a series of meetings, during which a multi disciplinary team uses a
prescribed protocol to methodically evaluate the significance of deviations from the
normal design intention.
The primary advantage of the brainstorming associated with HAZOP Analysis is that
it stimulates creativity and generates new ideas. This creativity results from the
interaction of a team with diverse backgrounds. Consequently, the success of the
study requires that all participants freely express their views, but participants should
refrain from criticizing each other to avoid stifling the creative process. This
creative approach, combined with the use of a systematic protocol for examining
hazardous situations, helps improve the thoroughness of the study.
The HAZOP study focuses on specific points of the process or operation called
"study nodes," process sections, or operating steps. One at a time, the HAZOP team
examines each section or step for potentially hazardous process deviations that are
derived from a set of established guide words. One purpose of the guide words is to
ensure that all relevant deviations of process parameters are evaluated. Sometimes
teams consider a fairly large number of deviations (i.e., up to 10 to 20) for each
section or step and identify their potential causes and consequences. Normally, all of
the deviations for a given section or step are analyzed by the team before it proceeds
further. Exhibit 6A-8 shows how deviations are determined by combining guide
words and process parameters.
October 27, 1998
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Chapter 6
Prevention Program (Program 2)
6-12
CAUTION
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Whichever approach you use, you should consider reasonably anticipated external
ii "111! events as well as intemal^failures^ If you are in an area suSject to earliquakes,
j! i 1111 hurricanes, or' floods', you should examine 'whetfier yOU^ process would survive these
natural events without releasing the substance. In your hazard review, you should
consider the potential impacts of Ughtning; strikesand power failures. If your
process could be hit by vehicles, you should examine tne consequences of that. If
you have anything near the process that c6ui3'b"u""^*a"s1'':lybursle^rwnat would happen
if the fire affected the process. For example, if you have a propane tank and an
ammonia taijk at your facility and they are close to each other, when you look at tie
ammonia tank you should consider what a fire in the propane tank would do to the
ammonia. These considerations may not be part ofstandard checklists. If you use
f,|t j!!1 i"y^es^eii|cl^cjslists,'youmay h'ayeytb'mod^'mem'toaddresstnese site-specific
::;:":;' '" ™ v concern!. Never use someone else's checklist blindly. You must be sure that it
1 / "i Jill! frtiHn:!!!"" ! .'It'I!1"!1 ii'ii""!'1!1" :,"',i'|!|,!'ii'!|h , i!""11 la'jl',,1'* .- I!1:, i: " ' ''• 'if I" iI'M11'1!,!1;":"!!™!!*!,:,!''IP i!",1"1"1 i! tllP"" 'HI"'1"!: J'jrUhi, ', i1 IK1 U!,, "!.l!,',' ,¥ i ,:,• , MJ, \ n , I'-fi.,' ,••••• v •« ,r .m • . • " .i»np •" ':in,,i:ii
addresses all of your potential problems.
In addition, you may want to check with vendors, trade associations, or professional
!' '' IIL ! ' " brgamza&ns to detemm
or if there are detection or mitigation systems that may be applicable to your process
that you should consider when you evaluate your existing equipment. If your
equipment is designed and built to an earlier version of a standard, you should
' ••'•*i* • «» • ;.,;>. consider whether upgrades are needed.
RESPONDING TO FINDINGS
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The person or persons who conduct the review should develop a list of findings and
recommendations.. You "must, ensure "fiat proBTems identified are addressed in a
timely manner. EPA does; not require "that youimplement every recommendation. It
is up to you to decide which recommendations are necessary and feasible. You may
decide that other steps are as effective as the recommended actions or that the risk is
too low to merit the expense. You must, however, document your decision on each
recommendation. If you are implementing a recommendation, you should document
the schedule for implementation. If you are taking other steps to address the problem
or decide me problem does not merit action, you should document the basis for your
decision.
UPDATES
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You must update the review every five years or whenever a major change in a
process occurs. For most Program 2 processes, major clianges are likely to occur
infrequently. If you install a new tank next to an existing one, you would want to
"H J/'i". '!' ,', jiiij i|MJij|jj|i|' L ' ""'f'l jf, ' i ''' """i' ' '"• i" ' 'i" '< ' i'i' "i1'1" i" 'i "' ' ''i' "i' V' S SS •• . ^'
;r , ,„„ consider whether the closeness of the two creates any new hazards. Replacing a tank
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you should examine the process carefully before starting. Combining old and new
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6-13
Chapter 6
Prevention Program (Program 2)
equipment can sometimes create unexpected hazards. You will operate more safely
if you take the time to evaluate the hazards before proceeding.
WHERE To Go FOR MORE INFORMATION
Although the reports below target the chemical industry, you may find useful
information in them:
+ Guidelines for Hazard Evaluation Procedures, 2nd Ed. -with Worked
examples, Center for Chemical Process Safely of the American Institute of
Chemical Engineers 1992.
+ Evaluating Process Safety in the Chemical Industry, Chemical
Manufacturers Association.
+ Loss Prevention in the Process Industries, Volumes I, II, and HI Frank P.
Lees, Butterworths: London 1996.
+ Management of Process Hazards (R.P. 750), American Petroleum Institute.
+ Risk-Based Decision Making (Publication 16288), American Petroleum
Institute.
Among the information you will find in Guidelines for Hazard Evaluation
Procedures are descriptions of other PHA techniques, including Failure Modes and
Effects Analysis and Fault Tree Analysis. The regulations allow you to make use of
these if you wish to do so.
6.4 OPERATING PROCEDURES (§ 68.52)
Written operating procedures describe in detail what tasks a process operator must
perform, set safe process operating parameters that must be maintained, and set
safely precautions for operations and maintenance activities. These procedures are
the guide for telling your employees how to work safely everyday, giving everyone a
quick source of information that can prevent or mitigate the effects of an accident,
and providing workers and management with a standard against which to assess
performance.
WHAT Do I NEED TO Do?
You must prepare written operating procedures that give workers clear instruction
for safely conducting activities involving a covered process. You may use
standardized procedures developed by industry groups or provided in
industry-specific risk management program guidances as the basis for your operating
procedures, but be sure to check that these standard procedures are appropriate for
your activities. If necessary, you must update your Program 2 operating procedures
whenever there is a major change and before you startup the changed process.
Exhibit 6-6 briefly summarizes what your operating procedures must address.
October27,1998
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Chapter 6
Prevention Program (Program 2)
6-14
EXHIBIT 6-6
OPERATING PROCEDURES REQUIREMENTS
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Steps for each operating phase
•Initial startup
•Normal operations
•Temporary operations
•Emergency shutdown
•Emergency operations
•Normal shutdown
•Startup following a normal or emergency shutdown or
a major change .
Other Procedures
•Consequences of deviating
•Steps to avoid, correct deviations
•Equipment inspections
»!lj" I
Your operating procedures must be:
+ Appropriate for your equipment and operations;
+ Complete;
1 I. " , i III', " ', ' . . ' 111' .' ' i ' | ! ,' . •' .I!""
+ Written in language that is easily understood by your operators; and
4- Arranged and organized to be easy for operators to use.
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The procedures do not have to be long. If you have simple equipment that requires a
few basic steps, that is all you have to cover.
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How Do I START?
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If you already have written procedures, you may not have to do anything more.
Review the procedures. You may want to watch operators performing the steps to be
"sure that the procedures are being used and are appropriate. Talk with the operators
to identify any problems they have identified and any improvements they may have
made. When you are satisfied that they meet the criteria listed above, you are
finished. You may want to check them against any recommended procedures
provided by equipment manufacturers, trade associations, or standard setting
organizations, but you are not required to do so. You are responsible for ensuring
that the procedures explain how to operate your equipment and processes safely.
If you do not have written procedures, you may be able to review your standard
procedures with your operators and write them down. You also may want to check
with equipment manufacturers, trade associations, or standard setting organizations.
They may have recommended practices and procedures that you can adapt. Do not
accept anyone else's procedures without checking to be sure that they are adequate
$$&d appropriate for your particular equipment and uses and are written in langjuage
."^mat your operators will understand. You may also want to review any requirements
imposed under state or federal rules. For example, if you are subject to federal rules
October 27, 1998
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-------
6-15
Chapter 6
Prevention Program (Program 2)
for loading and unloading of hazardous materials, those rules may dictate some
procedures. Copies of these rules are sufficient for those operations if your operators
can understand and use them.
WHAT Do THESE PROCEDURES MEAN?
The rule lists eight procedures. Not all of them may be applicable to you. The
following is a brief description to help you decide whether you need to develop
procedures for each item. If a particular element does not apply, do not spend any
time on it. We do not expect you to create a document that is meaningless to you.
You should spend your time on items that will be useful to you.
Initial Startup. This item applies primarily to facilities that process or use
substances and covers all the steps you need to take before you start a process for the
first time. You should include all the steps needed to check out equipment as well as
the steps needed to start the process itself.
Normal Operations. These procedures should cover your basic operations. The
procedures would include all the steps operators take to check the process and ensure
that equipment is functioning properly and substances are flowing or mixing
appropriately. These are your core procedures that you expect your operators to
follow on a daily basis to run your processes safely.
At a WWTP, it will be especially important to detail, very specifically, the
procedures and safeguards for connecting and disconnecting cylinders, tank trucks,
or rail cars containing regulated substances. These procedures should also detail the
required precautions, e.g., having an emergency respirator readily available. Also,
assuring that emergency equipment is functional and readily available should be part
of the instructions. For example, an inspection of the air tank on the self-contained
breathing apparatus prior to making or breaking connections should be considered.
Temporary Operations. These operations are short-term; they will usually occur
either when your regular process is down or when additional capacity is needed for a
limited period. The procedures should cover the steps you need to take to ensure that
these operations will function safely. The procedures will generally cover
pre-startup checks and determinations (e.g., have you determined what the maximum
flow rate will be). The actual operating procedures for running the temporary
process must be written before the operation is put into place.
Emergency Shutdowns and Operations. These procedures cover the steps you
need to take if you must shutdown your process quickly. For most Program 2
facilities, these procedures will be brief because shutting a process down will be
little different in an emergency than in ordinary circumstances; you will simply shut
off the flow or stop any unloading or loading.
Normal Shutdown. These procedures should provide all the steps needed to stop a
process safely. The procedures should set out the time that should be taken and the
checks that must be made before proceeding to the next steps.
October 27, 1998
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Startup following a normal or emergency shutdown or a major change. These
procedures may be similar to those for initial startup. Startup procedures following
normal shutdown may include fewer equipment checks because you may not need to
check equipment on a frequent basis. You should include all the steps your workers
should take to ensure that the process can operate safely. Startup after an emergency
shutdown will generally require more checks to ensure that valves that were closed
are open and that they and other equipment are still functioning properly.
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Consequences of Deviations. Your operating procedures should tell the workers
\vhat will happen if something starts to go wrong. For example, if the pressure or
temperature begins to rise or fall unexpectedly or the flow rate from one feed
suddenly drops sharply, the operator must know (1) whether this poses a problem
••I that'musfbe addressed^ anil'(2)' what s'teps" tblake to correct'the problem or otherwise
respond to it. Your safety information will have defined the safe operating limits for
i i' ;'your' substances "and processes; ffie ha^aH revl£w"w]Utt'nave" cie'fnied' th"e possible
consequences arid the steps needed to prevent a deviation from causing serious
problems. You should include this information in each of the other procedures
j!'Sj-(starn^ ramer'man'ias" separate "documents.
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i!1 i" If your substance is one that has a distinctive odor, color, or other characteristic that
•''^''--^' " able'to" sehsei "you sho u!3' jhc'|u"ge" ..... m"your procedures 'information
s'" i' about what to do if they notice leaks.' Frequently^1' people" are"'flie most sensitive leak"
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detectors. Take advantage of their abilities to catch leaks before they become
serious.
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-------
6-17
Chapter 6
Prevention Program (Program 2)
WHAT KIND OF DOCUMENTS Do I HAVE TO KEEP?
You must maintain your current set of operating procedures. You are not required to
keep old versions; in fact, you should avoid doing so because keeping copies of
outdated procedures may cause confusion. You should date all procedures so you
will know when they were last updated.
WHERE To Go FOR MORE INFORMATION
The Chlorine Institute (http://www.cl2.com) publishes information on safe use and
handling of chlorine. Its Water and Wastewater Operators Chlorine Handbook
(Pamphlet # 155) provides general training and procedures.
The Water Environment Federation (601 Wythe Street, Alexandria, VA 22134, (703)
684-2470) provides general procedures as part of its training programs on
wastewater treatment operation and maintenance.
Although the reports below target the chemical industry, you may find useful
information in them:
4- Guidelines for Process Safety Fundamentals for General Plant Operations,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1995.
+ Guidelines for Safe Process Operations and Maintenance, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1995
+ Guidelines for Writing Effective Operating and Maintenance Procedures,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1996.
6.5 TRAINING (§ 68.54)
Training programs often provide immediate benefits because trained workers have
fewer accidents, damage less equipment, and improve operational efficiency.
Training gives workers the information they need to understand how to operate
safely and why safe operations are necessary. A training program, including
refresher training, is the key to ensuring that the rest of your prevention program is
effective. You may already have some type of training program if you must conduct
training to comply with OSHA's Hazard Communication Standard (29 CFR
1910.1200).
WHAT Do I NEED TO Do?
You must train all new workers in your operating'procedures developed under the
previous prevention program element; if any of ypur more experienced workers need
training on these procedures, you should also train them. Any time the procedures
October 27,1998
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Prevention Program (Program 2)
6-18
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4- Connecting, and disconnecting, cylinders of Chlorine and^Sulfur Dioxide.
Training should cover inspection of the fittings and tubing to assure that they
are in good condition and inspection (and discard if necessary) of tools used
for the job. Training should also include identification of vapor and liquid
connections on the cylinders and identification of the operating conditions
that will show that the connections are hooked up in reverse.
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+ Material handling of cylinders. Training should cover inspection of material
handling equipment, including hoists, cylinder carriers and hooks, and
cylinder chocks. Also, inspection for and removal of combustibles or
flammables in storage areas should Sea part of training.
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6-19
Chapter 6
Prevention Program (Program 2)
EXHIBIT 6-7
TRAINING CHART
•Who needs training?
Clearly identify the employees who need to be trained and the subjects to be
covered.
•What are the
objectives?
Specify learning objectives, and write them in clear, measurable terms before
training begins. Remember that training must address the process operating
procedures.
•How will you meet the
training objectives?
Tailor the specific training modules or segments to the training objectives.
Enhance learning by including hands-on training like using simulators whenever
appropriate. Make the training environment as much like the working
environment as you can, consistent with safety. Allow your employees to
practice their skills and demonstrate what they know.
•Is your training
program working?
Evaluate your training program periodically to see if your employees have the
skills and know the routines required under your operating procedures. Make
sure that language or presentation are not barriers to learning. Decide how you
will measure your employees' competence.
•How will your
program work for new
hires and refresher
training?
Make sure all workers - including maintenance and contract employees - receive
initial and refresher training. If you make changes to process chemicals,
equipment, or technology, make sure tiiat involved workers understand the
changes and the effects on their jobs.
How DOES THIS TRAINING FIT WITH OTHER REQUIRED TRAINING?
You are required by OSHA to provide training under the Hazard Communication
Standard (29 CFR 1910.1200); this training covers the hazards of the chemicals and
steps to take to prevent exposures. DOT has required training for loading and
unloading of hazardous materials (49 CFR part 172, subpart H). Some of that
training will cover items in your operating procedures. You do not need to repeat
that training to meet EPA's requirements. You may want to integrate the training
programs, but you do not have to do so.
WHAT KIND OF DOCUMENTATION Do I NEED TO KEEP?
In the RMP, you are required to report on the date of the most recent review or
revision of your training program. You are also required to report on the type of
training required (e.g., classroom or on-the-job) and the type of competency testing
used. You should keep on site any current training materials or schedules used. The
rule does not require you to keep particular records of your training program. It is
enough for you to have on site information that supports what is reported in the RMP
and your implementation of the training program overall. You may want to keep an
attendance log for any formal training courses and refresher training to ensure that
everyone who needs to be trained is trained. Such logs will help you perform a
October 27, 1998
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greyentjQngrpgram (Program 2)
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6-20
compliance audit or demonstrate compliance with the rule although you are not
required to keep logs for this rule.
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WHERE To Go FOR MORE INFORMATION
ides several training programs iacluding the
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'"" i' ••;:• "• ~=" following:
Ifl .i1;,, I!:1'"1 -Sill! 1 "ii'UB •,> t"1'1"; a ;l rv sir ii : '•>! .'I i1"::1!. "'.i'ii": • -, : in1 r>,», ,. • ''„! jaHii:::r, ...is MJ
,::,:; ,4" Basic Course for Wastewater Treatment Plant Operators, Instructor Set
Order No. EOIOOGB, Student Workbook Order No. EO 110GB.
4- Intermediate Course for Wastewater Treatment Plant Operators, Instructor
Set Order No. E0295GB, Student Workbook Order No. E0296GB.
i ;!•.:?
ii" •• tei., •> ..:' ',; IB • JIB 4-': "-"' Chlorination Skill Training Course, Order No. E0312GB. Self''instruction
" . _ . Course.
In addition, the following may be useful:
4- Operation and Maintenance of Municipal Wastewater Treatment Plants
v , .I'" ;3 i' iiaiii, :!,iii . (MOP-11), Water Enyironment Federation.
:• - i ,, \ p .iiji •:] "t" ^PA~?20, Standard for Fire Protection in Wastewater T^
•;L' ' . H"; ''"S ' ' Collection Facilities. , ^ ^
4- Guidelines for Process Safety Fundamentals for General Plant Operations,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1995.
4 Guidelines for Technical Planning for pn-Site Emergencies, Center for
Chemical Process Safety of the American institute of Chemical Engineers
1995.
4- Federally Mandated Training and Information (Publication 12000),
American Petroleum institute.
, . , . . . ,. , ,. ,. , j.,, , , ,
6.6 MAINTENANCE (§ 68.56)
Preventive maintenance, inspection, and testing of equipment is critical to safe
operations. Waiting for equipment to fail often means waiting for an accident that
could harm people and the environment Further, a thorough maintenance program
Will save you money by cutting down-time caused by equipment failures. Your
hazard review and safety information will have identified equipment that is critical to
safe operations. You should use that information you develop while putting together
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6-21
Chapter 6
Prevention Program (Program 2)
EXHIBIT 6-8
MAINTENANCE GUIDELINES
Written procedures
•You may use
procedures provided
. by the vendor or trade
association, etc., as the
basis for your
program. If you
choose to develop
your own, you must
write them down.
Training
•Train process maintenance
employees in process hazards
and how to avoid or correct
an unsafe condition.
•Make sure this training
covers the procedures
applicable to safe job
performance.
Inspection & testing
•inspect & test process
equipment.
•Use recognized and generally
accepted good engineering
practices.
•Follow a schedule that matches
the manufacturer's
recommendations or that prior
operating experience indicates
is necessary.
WHAT Do I NEED TO Do?
You must prepare and implement procedures for maintaining the mechanical
integrity of process equipment, and train your workers in the maintenance
procedures. For most of the equipment in a WWTP, the manufacturer will have
supplied maintenance instructions. These can be used to fulfill the requirements for
maintenance procedures. Where such instructions are not available, you will need to
develop them. In addition to the major pieces of equipment, you will need to
develop inspection procedures that consider both repair or replacement requirements
for the following items:
4- Fittings
4- Tubing
4- Pressure relief devices
4- Gauges, pressure switches, and other instrumentation.
4- Rotameters
+ Pressure regulators, and pressure gauges
4- Leak detectors
4- Eductors, vacuum mixers, or other devices used to mix chlorine, sulfur
dioxide, and other regulated substances into waste water streams
4- Material handing equipment
4- Tools
4- All other equipment used to handle, transfer, or use the regulated substances.
Where there is the possibility of corrosion, these inspections are especially
important. The regulated substances used are normally not corrosive, when they are
dry. However, all of them can become highly corrosive if the equipment using them
is wet. Attention to this aspect can be vital.
In larger plants, where there are storage tanks for chorine, sulfur dioxide or
ammonia, the tanks and associated piping should be inspected regularly. Suppliers
October 27, 1998
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Chapter 6
Prevention Program (Program 2)
6-22
j- ;. In i- 51
]g I ;
are likely to be able to provide recommendations for this inspection and preventive
maintenance.
You should develop a schedule for inspecting and testing your equipment based on
manufacturers' recommendations or your own experience if that suggests more
frequent inspection or testing is warranted.
How Do I START?
Ypur first step will probably be to determme whemer you already meet all these
requirements. If you review your existing written procedures and determine that
, :;";i tb^ey are appropriate, you do not need to revise or rewrite them. If your workers are
; .Already trained in the procedures and carry them put, you may; not need to do
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If you do not have written procedures, you will need to develop them. Your
r'-,.P
-------
6-23
Chapter 6
Prevention Program (Program 2)
providing training or by developing agreements with the contractor that give you the
assurance that only trained workers will be sent to your site. For any outside worker,
you must ensure that they are informed of the hazards of your particular process. If
you have standard equipment and hire contractors that specialize in servicing your
types of processes, you can ensure their knowledge through agreements with the
contractor.
INSPECTION AND TESTING
You must establish a schedule for inspecting and testing equipment associated with
covered processes. The frequency of inspections 'and tests must be consistent with
manufacturer's recommendations, industry standards or codes, good engineering
practices, and your prior operating experience. In particular, you should use your
own experience as a basis for examining any schedules recommended by others.
Many things may affect whether a schedule is appropriate. The manufacturer may
assume a constant rate of use (e.g., the amount of substance pumped per hour). If
your use varies considerably, the variations may affect the wear on the equipment.
Extreme weather conditions may also impact wear on equipment.
Talk with your operators and maintenance personnel as you prepare or adopt these
procedures and schedules. If their experience indicates that equipment fails more
frequently than the manufacturer expects, you should adjust the inspection schedule
to reflect that experience. Your hazard review will have identified these potential
problem areas as well and should be used as you develop schedules. For example, if
you determine that corrosion is one of the hazards of the process, your schedule must
address inspections for corrosion and replacement before failure. Your trade
association may also be able to provide advice on these issues.
WHAT KIND OF DOCUMENTATION MUST I KEEP?
In the RMP, you are required to report on the date of the most recent review or
revision of your maintenance procedures and the date of the most recent equipment
inspection or test and equipment inspected or tested. You must keep on site your
written procedures and schedules as well as any agreements you have with
contractors. The rule does not require that you keep particular records of your
maintenance program. It is enough for you to have on site information that supports
what is reported in the RMP and your implementation of the maintenance program
overall. For example, you may want to keep maintenance logs to keep track of when
inspections and tests were done.
WHERE To Go FOR MORE INFORMATION
Codes and Standards: The following groups develop codes and standards that may
help you determine the appropriate frequency and methods to use for testing and
inspection: National Board Inspection Code, the American Society for Testing and
Material, American Petroleum Institute, National Fire Protection Association,
American National Standards Institute, American Society of Mechanical Engineers.
October 27, 1998
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Chapters
Prevention Program (Program 2)
6-24
Guidance and Reports. The documents listed under Safety Information may be
useful for maintenance procedures as well. La addition, the Chlorine Institute
publishes pamphlets on chlorine system maintenance, including the following:
l| I ! I | | |HI II ||ll || j
+ Maintenance Instructions for Chlorine Institute Standard Safety Valves,
Type 1-1/2 JQ(#39).
+ Maintenance Instructions for Chlorine Institute Standard Angle Valve (#40).
+ Maintenance instructions for Chlorine Institute Standard Safety Valve, Type
4/2 (#41). ".'„'".'.'.." , 1.".'" 77! [
+ Maintenance Instructions for Chlorine Institute Standard Excess Flow
Valves (#42). " ;' 7 '""" 777! """,!! "" 77! '""
Although the reports below target the chemical' industry, you may find useful
information in them:
Guidelines for Equipment Reliability Data with Data Tables, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1989. 7 j ; .,; ; 7 , 7
; - ,,,i, i in ' I '||"""1"'' '" ' ji n"
Guidelines for Process Safety Documentation, Center for Chemical Process
Safety of the American Institute of Chemical Engineers 1995.
Pressure Vessel Inspection Code: Maintenance Inspection, Rating, Repair,
and Alteration (API 510), American Petroleum Institute.
Tank Inspection, Repair, Alteration, and Reconstruction (Sta 653), American
Petroleum Institute.
:";»'*
hiitrii.
„:;:',» III
I
111 !!''
i, ir
Q&A
MAINTENANCE
Q. I have a chlorine tank. I lease the tank from the supplier. The supplier does all the maintenance.
My staff never work on the equipment. How I do meet this requirement?
A. As part of your contract with the supplier, you should gain an agreement, in writing, that the
supplier will provide maintenance and trained maintenance workers that meet the requirements of 40
CFR 68.56.
|.7" ° i ^'" COMPLIANCE AUDITS (§ 68.58)""
ill!
ill:,:
Agril 19,2000
ny risk management program should be reviewed periodically to ensure that
employees and contractors are implementing it prpgerly. A compliance audit is a
way for you to evaluate and measure the effectiveness of your risk management
rifogram;'1 ''Xn audit reviews 'each of the" prevention program elements to ensure"" that
they are up-to-date and are being implemented and will help you identify problem
Mii«»i. >s^^ +^i,= corrective actions. As a result, you'll be running a safer operation.
areas
,:,„! ,! ! 'linn,
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6-25
Chapter 6
Prevention Program (Program 2)
WHAT Do 1 NEED TO Do?
At least every three years, you must certify that you have evaluated compliance with
for the prevention program requirements for each covered process. At least one
person on your audit team must be knowledgeable about the covered process. You
must develop a report of your findings, determine and document an appropriate
response to each finding, and document that you have corrected any deficiency.
You must review compliance with each of the required elements of the prevention
program. Because Program 2 processes are generally simple, the audit should not
take a long time. You may want to develop a simple checklist; Exhibit 6-9 provides
a sample format.
Once you have the checklist, you, your chief operator, or some other person who is
knowledgeable about your process, singly or as a team, should walk through the
facility and check on relevant items, writing down comments and recommendations.
For example, you may want to talk with employees to determine if they have been
trained and are familiar with the procedures.
You must respond to each of the findings and document what actions, if any, you
take to address problems. You should take steps to correct any deficiencies you find.
You may choose to have the audit conducted by a qualified outside party. For
example, you may have someone from another part of your company do the audit or
hire an expert in your process. If you do either of these, you should have an
employee who works with or is responsible for the process accompany the auditor,
both to understand the findings and answer questions.
Again, the purpose of the compliance audit is to ensure that you are continuing to
implement the risk management program as required. Remember, the risk
management program is an on-going process; it is not a set of documents that you
develop and put on a shelf in case the government inspects your site. To be in
compliance with (and gain the benefits of) the rule, procedures must be followed on
a daily basis; documents must be kept up to date. The audit will check compliance
with each prevention program element and indicate areas that need to be improved.
You may choose to expand the scope to cover your compliance with other parts of
the rule and the overall safety of your operation, but you are not required to do so.
October 27,1998
-------
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IT 6-?
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!i;]FOR JSA]FEfV'1'MFl)Rl^^ AND HAZARD REVIEW
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-------
6-27
Chapter 6
Prevention Program (Program 2)
WHERE To Go FOR MORE INFORMATION
Guidelines for Auditing Process Safety Management Systems, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1993.
Q&A
AUDITS
Q. Does the compliance audit requirement cover all of the Part 68 requirements or just the
prevention program requirements?
A. The compliance audit requirement applies only to the prevention programs under Subpart C.
If you have a Program 2 process, you must certify that you have evaluated compliance with the
Program 2 prevention program provisions at least every three years to verify that the procedures
and practices developed under the rule are adequate and are being followed. You may want to
expand your audit to check other part 68 elements, but you are not required to do so.
6.8 INCIDENT INVESTIGATION (§ 68.60)
Incidents can provide valuable information about site hazards and the steps you need
to take to prevent accidental releases. Often, the immediate cause of an incident is
the result of a series of other problems that need to be addressed to prevent
recurrences. For example, an operator's mistake may be the result of poor training.
Equipment failure may result from improper maintenance or misuse. Without a
thorough investigation, you may miss the opportunity to identify and solve these
problems.
WHAT Do I NEED TO Do?
You must investigate each incident which resulted in, or could have resulted in, a
catastrophic release of a regulated substance. A catastrophic release is one that
presents an imminent and substantial endangerment to public health and the
environment. Exhibit 6-10 briefly summarizes the steps you must take for
investigating incidents. You should also consider investigating minor accidents or
near misses because they may help you identify problems that could lead to more
serious accidents; however, you are not required to do so under part 68.
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Illl I ,
Chapter 6
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ill III
6-28
EXHIBIT 6-10
INCIDENT INVESTIGATION REQUIREMENTS
i,1! i ! P
•Initiate an investigation promptly.
•Summarize the investigation in a report.
•Address the report's findings and
recommendations.
•Review the report with your staff and
contractors.
•Retain the report.
Begin investigating no later than 48 hours
following the incident.
Among other things, the report must identify the
factors contributing to the incident. Remember
that identifying the root cause may be more
important than identifying the initiating event.
The report must also include any
recommendations for corrective actions.
Remember that the purpose of the report is to
help management take corrective action.
Establish a system to address promptly and
resolve the incident report findings and
recommendations and document resolutions and
corrective actions.
You must share the report - its findings and
recommendations - with affected workers whose
job tasks are relevant to the incident.
Keep incident investigation summaries for five
years.
II 111
How Do I START?
You should start with a simple set of procedures that you will use to begin an
I P? 'Si! !:'":, »,..„.'.: 5!' tltnf. ... ,1,.:.,.,.. *J .,, , J, .1. ... ft,: Sfi i,
investigation. You may want to assign someone to be responsible for compiling the
initial incident data and putting together the investigation team. If you have a small
facility, your "team" may be one person who works with the local responders, if they
were involved.
The purpose of the investigation is to find out what went wrong and why, so you can
prevent it from happening again. Do not stop at the obvious failure or "initiating
event" (e.g., the hose was clogged, the operator forgot to check the connection); try
to determine why the failure occurred. In many cases, the underlying cause will be
what matters (e.g., the operator did not check the connection because the operating
procedures and training did not include this step). If the accident occurred because
of operator error, you should determine if the operator made the mistake because lie
or she had been trained inadequately or trained in the wrong procedures or because
design flaws made mistakes likely. If you write off the accident as operator error
alone, you miss the chance to take the steps needed to prevent such errors the next
time. Similarly, if equipment fails, you should try to decide whether it had been used
or maintained improperly.
October 27,1998
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6-29
Chapter 6
Prevention Program (Program 2)
Remember, your goals are to prevent accidents, not to blame someone, and correct
any problems in your prevention program. In this way, you can prevent recurrences.
In some cases, an investigation will not take long. In other cases, if you have a
complex facility, equipment has been severely damaged, or the workers seriously
hurt, an investigation may take several days. You should talk with the operators who
were in the area at the time and check records on maintenance (another reason for
keeping logs). If equipment has failed in an unusual way, you may need to talk to
the manufacturer and your trade association to determine if similar equipment has
suffered similar failures.
You must develop a summary of the accident and its causes and make
recommendations to prevent recurrences. You must address each recommendation
and document the resolution and any actions taken. Finally, you must review the
findings with operators affected by the findings.
WHAT KIND OF DOCUMENTATION MUST I KEEP?
You must maintain the summary of the accident investigation and recommendations
and document resolutions and corrective actions.* A sample format is shown in
Exhibit 6-11 that combines all of these in a single form. Note that the form also
includes accident data that you will need for the five-year accident history. These
data are not necessarily part of the incident investigation report, but including them
will create a record you can use later to create the accident history.
WHERE To Go FOR MORE INFORMATION
Although the reports below target the chemical industry, you may find useful
information in them:
4- Guidelines for Investigating Chemical Process Incidents, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1992.
+ Guide for Fire and Explosion Investigations (NFPA 921), National Fire
Protection Association.
6.9 CONCLUSION
Many of you will need to do little that's new to comply with the Program 2
prevention program, because complying with other Federal rules, state requirements,
and industry-specific codes and standards results'in compliance with many Program
2 elements. And if you've voluntarily implemented OSHA's PSM standard for your
Program 2 process, you'll meet the lesser Program 2 prevention program
requirements. No matter what choices you make in complying with the Program 2
prevention program, keep these things in mind:
October 27, 1998
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1 111
111 111 111
Chapter 6
-^Prevention Program (Program 2)
6-30
EXHIBIT 6-11
SAMPLE INCIDENT
INVESTIGATION FORMA!
11 , 11 I1 ,11,1 I1! | 'fill 1,1 ill, I I'l ' | | Ifl1 I |
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Ammonia Tank Release
Date: May 15, 1998; 3 pm
Duration: 2 hours
Description:
Findings
Hose split because the pressure
rating was too low; design
pressure requirement was
overlooked
Operator failed to stay at the
tank during loading
Tank required manual shutoff
Substance: Ammonia
Weather: 82 F, 8 mph winds
Quantity: 2 tons
Date Investigation Started:
May 16, 1998
Unloading hose split open and spilled substance; operator was in
the main building and failed to notice spill for several minutes
Recommendations
Replace hose with correctly
rated pressure hose;
compare all pressure ratings to
actual, including deadhead
pump pressure, and make any
needed upgrades
Conduct refresher training to
stress necessity of remaining at
the tank during loading
Determine if automatic shutoff
valve is feasible
Actions
Replaced hose as
recommended; checked all
pressure ratings
Refresher training provided;
safety meetings added and held
on a monthly basis to review
safety issues
Automatic shutoff valve
installed
Integrate the elements of your prevention program. For Program 2 owners
and operators, a niajor change in any single element of your program should
lead to a review of other elements to j^eng|y ^y effect caused by the
change.
Make accident prevention an institution at your site. Like the entire risk
management program, a prevention program is more than a collection of
Written documents. It is a way to make safe operations and accident
prevention the way you do business everyday.
Check your operations on a continuing basis and ask if you can improve
them to make them safer as well as more efficient.
October 27,1998
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6-31
Chapter 6
Prevention Program (Program 2)
APPENDIX 6A
HAZARD REVIEW CHECKLISTS, WHAT IF QUESTIONS,
AND HAZOP PROCEDURES
October 27,1998
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Chapter 6
Prevention Program (Program 2)
6-32
EXHIBIT 6A-1
GENERAL, CONDITIONS, OPERATION AND MAINTENANCE
" "', " l"il ', (FORANYWWTP)
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General Conditions, Operation and Maintenance
Are work areas clean?
Are adequate warning signs posted?
Is ambient temperature normally comfortable?
Is lighting sufficient for all operations?
Are the right tools provided and used?
Is personal protective equipment (PPE) provided and adequate?
Are containers and tanks protected from vehicular traffic?
Are all flammable and combustible materials kept away from
containers, tanks, and feed lines?
Are containers, tanks, and feed line areas kept free of any objects
that can fall on them (e.g., ladders, shelves?)
Are leak detectors with local and remote audible and visible
alarms present, operable, and tested?
Are windsocks provided in a visible location?
Are emergency repair kits available for each type of supply
present?
Are appropriate emergency supplies and equipment present,
including PPE and self-contained breathing apparatus (SCBA)?
Are emergency numbers posted in an appropriate spot?
Are equipment, containers, and railcars inspected daily?
Are written operating procedures available to the operators?
Are preventative maintenance, inspections, and testing performed
as recommended by the manufacturer and industry groups and
documented?
Yes/No/NA
Comments ,
III! Mlb1 IS .„' ,1171,1 ill 1!|. '
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October 27,1998
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6-33
Chapter 6
Prevention Program (Program 2)
EXHIBIT 6A-2
HUMAN FACTORS
(GENERAL)
: • •;- . Human Factors. ->..
Have operators been trained on the written operating procedures
and the use of PPE in normal operations (or for operators on the
job before June 21, 1999, have you certified that they have the
required knowledge, skills, and ability to do their duties safely)?
Do the operators follow the written operating procedures?
Do the operators understand the applicable operating limits on
temperature, pressure, flow, and level?
Do the operators understand the consequences of deviations above
or below applicable operating limits?
Have operators been trained on the correct response to alarms and
conditions that exceed the operating limits of the system?
Are operators provided with enough information to diagnose
alarms?
Are controls accessible and easily understood?
Are labels adequate on instruments and controls?
Are all major components, valves, and piping clearly and
unambiguously labeled?
Are all components mentioned in the procedures adequately
labeled?
Are safe work practices, such as lockout/tagout, hot work, and line
opening procedures followed?
Are personnel trained in the emergency response plan and the use
of emergency kits, PPE, and SCBAs?
Are contractors used at the facility?
Are contractors trained to work as safely as your own employees?
Do you have programs to monitor that contractors are working
safely?
YesTNo/NA,
\ 4« •>•
, Comments
October 27, 1998
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"It i : |; ' I
Chapter 6
Prevention Program (Program 2)
6-34
EXHIBIT 6A-3
CHECKLISTS FOR CHLORINE AJTO SULFUR DIOXIDE
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Chlorine and Sulfur Dioxide - Siting
Are storage, use, and transfer areas not located uphill from
adjacent operations?
Are storage, use, and transfer areas located away from sewer
openings and other underground structures?
Do storage, use, and transfer areas have easy access for emergency
response?
Are storage, use, and transfer areas free of combustible or
incompatible materials and isolated from hydrocarbons in
accordance withNFPA Standard No. 49, Hazardous Chemicals
Data?
Are storage, use and transfer areas downwind of or separated from
most operations and support areas and ventilation intakes based on
prevailing wind direction?
Are storage, use, and transfer areas isolated from sources of
corrosion, fire, and explosion and protected from vehicle impact?
Are storage, use, and transfer areas located away from residences
and facility boundaries?
If cylinders are stored outside, are they protected from impact by
vehicular traffic?
Chlorine and Sulfur Dioxide - Hazard Recognition
Are material safety data sheets (MSDSs) readily available to those
operating and maintaining the system?
Do employees understand that there are certain materials with
which C12 (SO-,) must not be mixed?
Do employees understand the toxicity, mobility, and ability of C12
(SO2) to sustain combustion?
Do employees understand the consequences of confining liquid C12
(SO^ without a thermal expansion device?
Do employees understand the effect of moisture on the corrosive
potential of C12 (SOj)?
y«s/N:o/NA -
'
Comments
s
5
October 27,1998
"11
I"
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6-35
Chapter 6
Prevention Program (Program 2)
' \ ** " - "': '•~*-~*t . ' v.' "; „- ~;: I *-" ~
Do employees understand the effects of fire and elevated
temperature on the pressure of confined chlorine (SO2) and the
potential for release?
CJdoiine aad Sulfur Dioxide - Container Shipment Unloading
Is the truck inspected for wheel chocks, proper position, and
condition of crane?
Are adequate warning signs posted? Are there "stops"?
Is the shipment inspected for leakage, general condition, currency
of hydrostatic test, and valve protective housing before accepting?
Are containers placed in the 6 o'clock/12 o'clock position for
storage to reduce the chance of a liquid leak through the valve?
, jCMorine and Sulfur Dioxide - Bulk Shipment Unloading .
5 " ^, * •* v- ^ -O -s
Do procedures call for hand brakes to be set and wheels chocked
before unloading?
Do procedures call for safety systems to be inspected prior to
making connections for unloading or between storage tanks and
transfer or distribution systems?
For railcars, are derails to protect the open end located at least 50
feet from the car being protected?
Are railcars staged at dead-end tracks and guarded against damage '
from other railcars and motor vehicles?
Are caution signs placed at each derail and as appropriate in the
vicinity of C12 (SO2) storage, use, and transfer areas?
Does the transfer operation incorporate an emergency shutoff
system?
Is a suitable operating platform provided at the transfer station for
easy access and rapid escape?
Is padding air for railcars from a dedicated, flow-limited, dry (to -
40 °F or below), and oil-free source?
Is tank car attended as long as the car is connected, in accordance
with DOT regulations?
~ Building .and Housing C12(SOZ) Systems
Does the building conform with local building and fire codes and
NFPA-820?
msMoMAr
\
s
"Yes/No/NA
Comments
**" » >
s"
Comments •
October 27, 1998
-------
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6-36
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Is the building constructed of non-combustible materials?
If flammable materials are stored or used in the same building, are
they separated from the C12 (SO2) areas by a fire wall?
Is continuous leak detection, using area C12 (SO^) monitors,
provided in storage and process areas?
Are two or more exits provided from each C12 (SO2) storage and.
process area and building?
Is the ventilation system appropriately designed for indoor
operations (and scrubbing, if required) by local codes in effect at
the time of construction or major modification?
Are the exhaust ducts near floor level and the intake elevated?
Can the exhaust fan be remotely started and stopped?
If C12 and SO2 are stored in the same building, are storage rooms
separated as required?
Chlorine and Sulfur Dioxide - Piping and Appurtenances
Do piping specifications meet C12 (SO2) requirements for the
service?
Do you require suppliers to provide documentation that all piping
and appurtenances are certified "for chlorine service" or "for
sulfur dioxide service" by the manufacturer?
Are piping systems properly supported, adequately sloped to allow
drainage, and with a minimum of low spots?
Is all piping protected from all risks of excessive fire or heat?
Is an appropriate liquid expansion device or vapor pressure relief
provided on every line segment or device that can be isolated?
Chlorine and Sulfur Dioxide - Design Stage Review of
New/Modified Process
Is the system designed to operate at lowest practical temperatures
and pressures?
If C12 (SO;,) demand is low enough, is the system designed to feed
gaseous chlorine (SO2) from the storage container, rather than
liquid?
Have the lengths of liquid C12 (SO2) lines been minimized (reduces
quantity of chlorine in lines available for release)?
Yes/No/NA
,
Comments
October 27,1998
i ill i (
I 11';,;, lii ,, • • 1
:Mf I ,11" i1,, I !!,, 'I
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6-37
Chapter 6
Prevention Program (Program 2)
",.".' ° ** * ' ->'-, " -, - '-""1 '* ' ^-' ,"
Are low-pressure alarms and automatic shutoff valves provided on
C12 (SO2) feed lines?
Are vent-controlled spill collection sumps provided and floors
sloped toward sumps for stationary tanks and railcars?
Are vaporizers provided with automatic gas line shutoff valve,
downstream pressure reducing valve, gas flow control valve,
temperature control system and interlocks to shut down gas flow
on low vaporizer temperature, and appropriate alarms in a
continuously manned control room?
Do vaporizers have a limited heat input capacity?
Are curbs, sumps, and diking that minimize the surface of
potential spills provided for stationary tanks and railcars?
•YesMo/NA
Comments
October 27,1998
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Chapter 6
Prevention Program (Program 2)
6-38
I 'III,,' Hill!',11 'I'll h1
CHECKLIST FOR ANHYDROUS AMMONIA SYSTEMS
'• I1 ' •
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October 27,1998
i11 n i iiiLi1 in i
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6-39
Chapter 6
Prevention Program (Program 2)
f S ~ ^ v- ^ ^ ^ ^
Is it 350 psig working, 1750 psig - burst?
Is it marked every 5 feet with "Anhydrous Ammonia, xxx psig
(maximum working pressure), manufacturer's name or trademark,
year of manufacture?
" V AiAydroBsj\inaionia-Safe" ' -i-j J
" ~ 1 '
October 27, 1998
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iin1;: i i " i;':>
lir ' i,, ;'' i rfii iii'11
.••••' ;;':J: r .' ;•• -'
Are containers fitted with a fixed tube liquid level gauge at 85% of
water capacity?
Anhydrous Ammonia - Stationary Tank
Are non-refrigerated containers) designed for a minimum 250
(265 psig in CA) psig pressure?
Are all liquid and vapor connections to container(s) except safety
relief valves, liquid gauging and pressure gauge connections fitted
with, orifices not larger than No. 54 drill size equipped with
excess-flow valves?
Are storage containers fitted with a 0-400 psi ammonia gauge?
Are they equipped with vapor return valves(s)?
Are containers marked on at least two sides with "Anhydrous
Ammonia" or "Caution - Ammonia" in contrasting colors and
minimum 4 inch Weh letters?
*^
Is a sign displayed stating name, address and phone number of
nearest representative, agent or owner?
Are containers installed on substantial concrete, masonry or
structural steel supports?
Are ammonia systems protected from possible damage by moving
vehicles?
Yes/No/NA
.,
Comments
" " * ,
'iilif i , ll!!,t I' .I!1,4
IB
i in
il'il 'I
October 27, 1998
111 Ih,"!'?1 '! VS!!!!1 'if'i'iii'"1
', :|i' ,,„' 'il 'illlllf I'l'l,'"1:1
iim '' '-niiii I
-------
6-41
Chapter 6
Prevention Program (Program 2)
EXHIBIT 6A-5
CHECKLIST FOR AQUEOUS AMMONIA SYSTEMS
,„ - X
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
' „,' Aqueous Ammonia Vfc * ' ^
Are storage tank(s) painted white or other light
reflecting colors and maintained in good order?
Is storage area free of readily ignitable materials?
Are storage tank(s) kept away from wells or other
sources of potable water supply?
Are storage tank(s) located with ample working space
all around?
Are storage tank(s) properly vented and away from
areas where operators are likely to be?
Does receiving system include a vapor return?
Is storage capacity adequate to receive full volume of
delivery vehicle?
Are storage tank(s) secured against overturn by wind,
earthquake and/or floatation?
Are tank bottom(s) protected from external corrosion?
Is aqua ammonia system protected from possible
damage from moving vehicles?
Are storage tank(s) labeled as to content?
Are all appurtenances suitable for aqua ammonia
service?
Are all storage tank(s) fitted with liquid level gauges?
Are liquid level gauge(s) adequately protected from
physical damage?
If tubing is used, is it fitted with a fail closed valve?
Are all storage tank(s) fitted with overfill fittings or
high level alarms?
Are tank(s) fitted with pressure/vacuum valves?
Is an ammonia gas scrubber system used?
Are piping and hose materials suitable for aqua
ammonia service?
Yes/Mo/NA
Comments •>-
October 27,1998
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Chapter 6
Prevention Program (Program 2)
6-42
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
Aqueous Ammonia
Is piping free of strain and provision made for
expansion, contraction, jarring, vibration and settling?
Is all exposed piping protected from physical damage
from moving vehicles and other undue strain?
Are hoses securely clamped to hose barbs?
Are hoses inspected and renewed periodically to avoid
breakage?
Are pump(s) designed for aqua ammonia service?
Are pump(s) fitted with splash guard around seals?
Are pump(s) fitted with coupling guard(s)?
Do pump(s) have local start/stop stations?
Are two (2) suitable full face masks with ammonia
canisters as approved by the Bureau of Mines available?
Self-contained breathing air apparatus required in
concentrated atmospheres.
Is an easily accessible quick acting shower with bubble
fountain or 250-gallon drum of clean water available?
Is an extra pair of chemical splash proof goggles and/or
full face shields available?
Is an extra set of ammonia resistant gloves, boots, coat
and apron available?
Are fire extinguishers and a first aid kit available?
Are handlers/operators wearing their goggles and gloves
when working with aqua ammonia?
Are safety and first aid information posted?
Are emergency phone numbers and individuals to
contact posted?
Yes/No/NA ' - !
Comments ','• *
October 27, 1998
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6-43
Chapter 6
Prevention Program (Program 2)
EXHIBIT 6A-6
SAMPLE WHAT-IF ANALYSIS PROCEDURE AND QUESTIONS
Analysis Procedure. The steps in a What-If/Checklist analysis are as follows:
1. Select the team (personnel experienced in the process)
2. Assemble information (piping and instrumentation drawings (P&IDs), process flow diagrams
(PFDs), operating procedures, equipment drawings, etc.)
3. Develop a list of What-If questions (use the ones in Exhibit 6A-6 if you want)
4. Assemble your team in a room where each team member can view the information
5. Ask each What-If question in turn and determine:
+ What can cause the deviation from design intent that is expressed by the question?
+ What adverse consequences might follow ?
+ What are the existing design and procedural safeguards?
+ Are these safeguards adequate?
+ If tibiese safeguards are not adequate, what additional safeguards does the team
recommend?
6. As the discussion proceeds, record the answers to these questions in tabular format. Exhibit 6A-
8 provides an example.
7. Do not restrict yourself to the list of questions that you developed before the project started. The
team is free to ask additional questions at any time.
8. When you have finished the What-If questions, proceed to examine the checklist. The purpose of
this checklist is to ensure that the team has not forgotten anything. While you are reviewing the
checklist, other What-If questions may occur to you.
9. Make sure that you follow up all recommendations and action items that arise from the hazards
evaluation.
October 27, 1998
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1
Chapter 6
Prevention Program (Program 2)
6-44
A. What -If Questions for Chlorine and Sulfur Dioxide Systems
Movement of 1-Ton C12 (SO2) Cylinders
What if the cylinder is dropped from the lifting apparatus?
What if the truck rolls forward or backward?
What if a cylinder rolls and drops from the truck?
i i i Mini iinn i i i in
What if the cylinder swings while being lifted?
What if the C12 (SOa) container is not empty when removed from service?
What if the automatic container switchover system fails?
11 in i i ill in Hi i
What if a C12 (SOj) cylinder is delivered instead of SO2 (C12 )
i ill i i mill in 11 in i
What if the cylinder is not in good condition?
Ton Cylinders on Trunnion, including pigtails, (subheader lines) to Main Header Lines
What if pigtails rupture while connected on-line?
What if pigtail connections open or leak when pressure is applied?
i i ii in ii ill i HI ii
What if something is dropped onto cylinder or connection?
i i i iiiiiiii ii1 i ' i i'i i
What if cracks develop in the ton cylinder flexible connection?
I'1' HI ,'l ,
What if liquid C12 (SO2) is withdrawn through the vapor lines from the ton cylinder?
What if the cylinder valve cannot be closed during an emergency?
in iiiiii iiiii ii i i
What if there are pinholes or small leaks at the fusible plugs?
JVhat if ton cylinder ends change shape from concave to convex?
What if liquid is trapped between two closed valves and the temperature rises?
What if there is a fire near the cylinders?
What if the operator leaves the valve open and disconnects the pigtail?
What if water enters the system?
October 27,1998
i 111 i
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Chapter 6
6-45 Prevention Program (Program 2)
C12 (SO2) Headers in the Chlorination (Sulfonation) Room
What if the pressure relief valve sticks open?
What if a valve leaks?
What if there is inadequate flow in the gas line (e.g., filter clogged)?
Evaporators
What if there is overpressure in the evaporator?
What if there is high temperature in the evaporator?
What if there is low temperature in the evaporator?
What if rupture disks leak?
What if the vacuum regulator valve fails?
What if there is a gas pressure gauge leak?
What if the vacuum regulator check unit fails?
What if there is liquid C12 (SO2) carryover to the vacuum regulating valve downstream of the evaporator?
Chlorination (Sulfonation) and Pipes to Injectors
What if there are leaks in the chlorinator (sulfinator) unit?
What if there is rupture of the pipe from the chlorinator to the injector?
What if there is backflow of water into the C12 (SO2) line?
What if the water pump is not working?
General
What if there is a power failure?
What if C12 (SO2) is released during maintenance?
What if a C12 (SO2) leak is not detected?
What if there is moisture in the C12 (SO2) system?
October 27, 1998
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Chapter 6
Prevention Program (Program 2)
6-46
Scrubbers
i
What if the system loses scrubber draft?
What if the system loses scrubber solution?
: ; I
What if the manual vent to the scrubber is opened during operation?
i
• i
What if the leak tightness of the building is compromised during emergency operation of the scrubbers?
Tank Trucks
i • I
What if the liquid hose leaks or ruptures?
What if the vapor return hose leaks or ruptures?
•• ii
What if the truck moves?
,'i , I
What if the mass of C12 (SO2) in the truck exceeds the capacity of the tank?
",< , . ' i
What if the C12 tank truck is connected to an SO2 vessel (or vice versa)?
What if there is something other than C12 (or SO^ in the truck?
What if there is a fire under or near the truck?
'.i J! :' : ! .
What if the truck collides with pipework or a building housing C12 (SO^ storage vessels?
Railcars
What if the liquid hose leaks or ruptures?
What if the padding air is moist?
What if the padding air hose ruptures?
What if the railcar moves?
I
What if the relief valve lifts below the set pressure?
I
What if there is a fire under or near the truck?
What if there is a fire on or near the railcar?
October 27,1998
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6-47
Chapter 6
Prevention Program (Program 2)
B. What-If Questions for Ammonia Systems
Storage Vessel
What if the vessel is overfilled?
What if there is fire under or near the vessel?
What if the relief valve fails to lift on demand?
What if the relief valve opens below its set pressure?
What if the deluge system fails to work on demand?
Tank Truck Unloading
What if the liquid unloading hose partially ruptures?
What if the liquid unloading hose completely ruptures?
What if the tank truck moves?
What if the tank truck drives away before the hose is disconnected?
What if the vapor return hose partially or completely ruptures?
What if valves are not completely closed before disconnecting the hoses?
What if the tank truck contains something other than ammonia?
What if the ammonia in the tank truck contains excess oxygen?
C. What-If Questions for Digester Systems
What if something falls onto a digester cover?
What if relief valves on a digester open?
What if an intermediate digester gas storage vessel fails?
What if air is introduced into the gas collection system?
What if the flare fails to operate?
What if the gas collection header leaks or ruptures or becomes blocked?
What if a digester gas compressor fails catastrophically?
October 27, 1998
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Chapter 6
Prevention Program (Program 2)
6-48
What if there is a digester gas leak into a building (digester building, compressor room, boiler room)?
What if the digester gas pressure exceeds the cover pressure rating?
What if the floating digester gas cover jams or tilts?
D. General Questions
ii
What if the ambient temperature is abnormally high?
What if the ambient temperature is abnormally low?
What if there is a hurricane?
What if there is a tornado?
What if there is flooding?
What if there is a heavy snowfall?
What if there is an earthquake?
What if there is a tidal wave?
What if there is a failure of electric power?
I
il
October 27,1998
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6-49
Chapter 6
Prevention Program (Program 2)
Exhibit 6A-7
EXAMPLE WHAT-IF/CHECKLIST LOG SHEET
Company: Sheet Name:
Facility: Reference:
PHA Date: Unit:
Leader/Secretary: Drawing Number:
Process: Print Date/Time:
Team Members: Description:
Item
4.1
4.2
4.3
4.4
Equipment/Activity
Generic Pressure Vessel
Generic Pressure Vessel
Generic Pressure Vessel
Generic Pressure Vessel
Questions
What if the set pressure of
the equipment SRV is more
than the design pressure of
the equipment?
What if the SRV is
incorrectly sized?
What if the SRV opens below
its set-pressure?
What if there is a fire near or
under the vessel?
Causes
Incorrectly set valve purchased
or returned after maintenance at
contractor's shop
Design basis for SRV
incorrectly chosen or SRV
sized for vapor flow when two-
phase or liquid flow is possible
Vibration, incorrect design,
weakened SRV spring, failure
due to inadequate PM program
Spillage of flammable-liquid
from nearby vessel
Consequence/Hazards
Potential for rupture and
release of contents of
vessel
SRV cannot relieve
pressure, potential
rupture
Release of vapor at
relatively low pressure
High pressure in vessel,
potential rupture.
Safeguards
Manufacturer
or repair
shop's QA
Valves
purchased for
specific
service
PM program
SRVs:
Deluge
system:
Separation
distances:
Keep
flatnmables
away from
vessel
Safeguards
adequate?
Y
Y
N
Y
Recommendations
None
None
Develop PM
program for SRVs
None
October 27,1998
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Chapter 6
Prevention Program (Program 2)
6-50
EXHIBIT 6A-8
HAZOP ANALYSIS GUIDE WORDS AND MEANINGS
I ! ! !.
In the approach, each guide word is combined with relevant process parameters and applied at each point
(study node, process section, or operating step) in the process that is being examined.
Guide Words
No
Less
More
Part Of
As Well As
Reverse
Other Than
Meaning
Negation of the Design Intent
Quantitative Decrease
Quantitative Increase
Other Material Present by Intent
Other Materials Present unintentionally
Logical Opposite of the Intent
Complete Substitution
COMMON HAZOP ANALYSIS PROCESS PARAMETERS
Flow
Pressure
Temperature
Level
Time
Composition
pH
Speed
Frequency
Viscosity
Voltage
Information
Mixing
Addition
Separation
Reaction
The following is an example of creating deviations using guide words and process parameters:
Guide Words
NO +
MORE +
AS WELL AS +
OTHER THAN +
Parameter
FLOW
PRESSURE
ONE PHASE
OPERATION
Deviation
NO FLOW
!
HIGH PRESSURE
TWO PHASE
' ! I
,|
MAINTENANCE
October 27, 1998
-------
MORE
LEVEL
6-51
HIGH LEVEL
Guide words are applied to both the more general parameters (e.g., react, mix) and the more specific
parameters (e.g., pressure, temperature). With the general parameters, it is not unusual to have more than
one deviation from the application of one guide word. For example, "more reaction" could mean either
that a reaction takes place at a faster rate, or that a greater quantity of product results. On the other hand,
some combinations of guide words and parameters will yield no sensible deviation (e.g., "as well as"
with "pressure").
How to Perform a Hazard and Operability (HAZOP) Review
1. Select the team.
2. Assemble information (P&EDs, PFDs, operating procedures, equipment drawings, etc.).
3. Assemble your team in a room where each team member can view P&IDs.
4. Divide the system you are reviewing into nodes (you can preset the nodes, or the team can
choose them as you go along).
5. Apply appropriate deviations to each node. For each deviation, address the following questions:
+ What can cause the deviation from design intent?
+ What adverse consequences might follow ?
+ What are the existing design and procedural safeguards?
+ Are these safeguards adequate?
4- If these safeguards are not adequate, what does the team recommend?
6. As the discussion proceeds, record the answers to these questions in tabular format as shown
below.
October 27, 1998
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Chapter 6
Prevention Program (Program 2)
6-52
EXAMPLES OF LINE-BY-LINE TABLES USE IN A HAZOP
Node No:
From:
To:
Drawing No:
Line ID:
Date:
Node Description:
Keyword
Flow
Flow
Flow
Flow
Deviation
High
Low
No
Reverse
1
Tanker Truck
Ammonia Storage Vessel
Liquid loading line from tanker truck to ammonia vessel.
Causes
None identified
Malfunction of truck equipment,
blockage in line, excess pressure
in tank or check valve failure
Malfunction on truck, or vapor
line excess flow valve snaps shut
Hose Rupture
Check valve and excess flow
valve failure with hose rupture
Block valves not closed when
hose disconnected
Consequences
None
Operational
problems
Operational
problems
Ammonia Leak
Vapor release from
vessel
Vapor release from
vessel
Safeguard
N/A
N/A
N/A
Emergency
shutdown features
Check valve,
excess flow value
and hose
inspections
Operator training
Adequate?
N
Y
Y
Recom-
mendation
N
N
N
Y1
N
N
'Arbitrary example of recommendation: Currently, the truck must park so far away from the tank that it is necessary to connect two lengths of hose.
Investigate the ways in which truck unloading can be accomplished using only one length of hose.
October 27,1998
-------
6-53
Chapter 6
Prevention Program (Program 2)
Notte Not >
From: - t v > i
to: ^ f ' ;
Drawing No?
Line ID:
Date: , ; '
Node Description:
"• i
•i
Keyword
Flow
Flow
Pressure
Deviation
Wrong
Type
In addition
High
Tanker Triick / ', > r* ' *' * , . V' V '•'?*' • . • r ' <": , -. / ' /•! '*» •
Ammonia Storage Vessel .; ^ \ ^ * ' "1 • ° * , ^ 1 d 2 • ^ °^' •, " , ,*, t A _
' ' ' ' ' ' " •• ' v ' "' ' ^ ' '' <"*•>' '.'"*''' ^ ' '<•" ' ^' " "x -" V **
" "' , * ' ' »*'<-" *""-'* , ">•!,' ° l''
Liquid loading line from tanker truck to ammonia vessel. '" -5- . , ^^ >..'.*
' ,'" ; .- / { '--,
k 4 Causer „ s .
Delivery of wrong material
Water, oxygen, oil
Valve closed, blockage, overfill
vessel
"
£ J "* ^ , * J
Consequences "
Unknown
Contamination,
corrosion
Ammonia overflow
or rupture
, * Safeguard '^ '.
Operational
safeguards
Manufacturer's
quality control
Relief valves, level
gauges
Adequate?
Y
Y
Y
JBUjcom-
: mendation
N
N
N
October 27,1998
-------
Chapter 6
Prevention Program (Program 2)
6-54
EXAMPLES OF LINE-BY-LINE TABLES (CONTINUED)
Node No:
From!
To:
Drawing No:
Line ID:
Date:
Node Description:
Keyword
Pressure
Pressure
Temp
Temp
Level
Level
Deviation
High
Low
High
Low
High
Low
2
Ammonia Storage Vessel
Ammonia storage vessel's design pressure is 265 psig at 250 degrees F. Working capacity is 15,000 gallons.
Maximum level allowed in the tank is 85%, but normal operating procedure is 75%.
Causes
Fire
Vaporizer malfunction
See High Pressure
See Low Pressure
Overfilling
Failure to order
Consequences
Relief valve opens
None
Relieve valve opens
None
Safeguard
Deluge system
N/A
Procedural
N/A
Adequate?
Y
N/A
N/A
N/A
Y
N/A
Recom-
mendation
N
N
N
N
N
N
October 27,1998
-------
CHAPTER 7: PREVENTION PROGRAM (PROGRAM 3)
Many of you will need to do little that is new to comply with the Program 3
prevention program, because you already have the OSHA PSM program in place.
Whether you're building on the PSM standard or creating a new program, keep these
things in mind.
+ EPA and OSHA have different legal authority — EPA for offsite
consequences, OSHA for on-site consequences. If you are already
complying with the PSM standard, your process hazard analysis (PHA) team
may have to assess new hazards that could affect the public or the
environment offsite. Protection measures that are suitable for workers (e.g.,
venting releases to the outdoors) may be the very kind of thing that could
expose the public to toxic substances.
+ Integrate the elements of your prevention program. You must ensure that a
change in any single element of your program leads to a review of other
elements to identify any effect caused by the change.
+ Most importantly, make accident prevention an institution at your site. Like
the entire risk management program, a prevention program is more than a
collection of written documents. It is a way to make safe operations and
accident prevention the way you do business everyday.
7.1 PROGRAM 3 PREVENTION PROGRAM AND OSHA PSM
The Program 3 prevention program includes the requirements of the OSHA PSM
standard. Whenever we could, EPA used OSHA's language verbatim. However,
there were a few terms that EPA had to change to reflect the differences between its
authority and OSHA's. For example, OSHA regulates to protect workers; EPA's
responsibility is to protect public health and safety and the environment. Therefore,
an "owner or operator" subject to EPA's rule must investigate catastrophic releases
"that present(s) (an) imminent and substantial endangerment to public health and the
environment," but an OSHA "employer" would focus its concerns on the workplace.
To clarify these distinctions, we deleted specific references to workplace impacts
and "safety and health" contained in OSHA's PSM standards. We also used different
schedule dates and references where appropriate. Exhibit 7-1 compares terms in
EPA's rule with their counterparts in the OSHA PSM standard.
October 27, 1998
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Chapter 7
Prevention Program (Program 3)
7-2
EXHIBIT 7-1
COMPARABLE EPA AND OSHA TERMS
1 ll 'l, 1 1 ** -*
OSHA TERM
Highly hazardous substance
Employer
Facility
Standard
EPATJEHM^ ' . - /' ' •';'„'/"
Regulated substance
Owner or operator
Stationary source
Rule or part
I II I '
There are twelve elements in the Program 3 prevention program. Each element
corresponds with a section of subpart D of part 68. Exhibit 7-2 sets out each of the
twelve elements, the corresponding section numbers, and OSHA references. Two
OSHA elements are not included. Emergency response is dealt with separately in
part 68; the OSHA trade secrets requirement (provision of trade secret information to
employees) is beyond EPA's statutory authority.
I
EXHIBIT 7-2
SUMMARY OF PROGRAM 3 PREVENTION PROGRAM
(40 CFR PART 68, SUBPART D)
feSSK^*
§ 68.65
§ 68.67
§ 68.69
§ 68.71
§ 68.73
§ 68.75
§ 68.77
§ 68.79
§ 68.81
§ 68.83
§ 68.85
§ 68.87
TITLE ^
Process Safety Information
Process Hazard Analysis (PHA)
Operating Procedures
Training
Mechanical Integrity
Management of Change
Pre-Startup Review
Compliance Audits
Incident Investigation
Employee Participation
Hot Work Permit
Contractors
OSHA PSM REFERENCE, .
PSM standard § 1910.119(d).
PSM standard § 1910.1 19(e).
PSM standard § 1910.119(f).
PSM standard § 1910.119(g).
PSM standard § 1910.119Q).
PSM standard § 1910.119(1).
PSM standard § 1910.119(1).
PSM standard § 1910.119(o).
PSM standard § 1910.1 19(m)
PSM standard § 1910.119(c).
PSM standard § 1910.119(k).
PSM standard § 1910.119(h).
OSHA provided guidance on PSM in non-mandatory appendix C to the standard.
OSHA has reprinted this appendix as PSM Guidelines for Compliance (OSHA
3133). The OSHA guidance is reproduced, reordered to track part 68, in Appendix
October 27,1998
-------
7-3
Chapter 7
Prevention Program (Program 3)
D. The remainder of this chapter briefly outlines the major requirements and
provides a discussion of any differences between EPA and OSHA. In some cases,
further guidance specific to WWTPs is provided. For more detailed guidance, you
should refer to the OSHA guidance in Appendix D.
QS &AS
IMPLEMENTATION AND PROCESS
Q. My process is a series of storage and process vessels, connected by piping, containing several
regulated substances, with a few co-located tanks of other substances. Do I have to implement one
prevention program to cover all aspects of the process even if different operators, different process
chemistry, and different hazards are involved in various parts of the process?
A. You should implement the program in the way that makes sense to you. For a complex process
such as yours, you may need to divide the process into sections (e.g., production units for particular
products, storage units) for the PHA and compliance audits, to keep the analyses manageable.
Operating and maintenance procedures (and the training in these procedures) should be developed for
operating units; combining procedures for different types of units into a single document may make
them harder to use; training operators in procedures they do not need would waste time and perhaps
confuse operators. You may want to collect and store process safety information by individual units
to make it easier to use. Other parts of the program (contractors, employee participation, procedures
for pre-startup, management of change, and hot work) are likely to be common to all parts of the
process.
Q. I have a tank with more than 10,000 pounds of propane. I use the propane to heat the offices. The
propane is not subject to PSM or the risk management program rule. The tank, however, is close to
equipment that has chlorine above the applicable threshold and is subject to OSHA PSM and Program
3. Is the tank considered part of the chlorine process?
A. If a fire or explosion in the propane tank could cause a release of chlorine or other regulated
substances or interfere with mitigation of such a release, the tank is considered part of the process.
When you do your PHA for the process, you must evaluate how the propane tank could cause a
release of chlorine and determine what steps may be needed to prevent such releases.
7.2 PROCESS SAFETY INFORMATION (§68.65)
Exhibit 7-3 briefly summarizes the process safety information requirements.
MSDSs will provide information on chemicals, except for inadvertent mixing with
other chemicals. Information on the hazardous effects of inadvertent mixing can
come from the PHA checklist (see the following section on process hazard analyses.)
MSDSs are available from your supplier of chemicals. But, because methane (CH4)
is generated in your plant, you will have to find an MSDS for methane elsewhere. A
local utility supplying natural gas may have one. You may, however, have to add the
potential for inclusion of carbon dioxide, hydrogen sulfide, and water in the methane
April 19, 2000
-------
Chapter?
Prevention Program (Program 3)
7-4
stream. If these are present, then corrosivity information about that stream will be
needed. You may wish to ask for assistance from a process engineer.
The information listed in the second column of Exhibit 7-3 is needed for that part of
your plant where the regulated substances are used. It should be available from the
engineering firm that designed the plant. If not, you will have to develop it to meet
this rule. The last item, consequences of deviation, means that you need to know
what will happen if the process (including any safety controls) does not work the
way it was designed to. If you do not have this information, or it cannot be obtained
from the engineering firm that designed the plant, it can be developed during the
process hazard analysis.
EXHIBIT 7-3
PROCESS SAFETY INFORMATION REQUIREMENTS
For chemicals, you must
complete information on;
•Toxicity
•Permissible exposure limits
•Physical data
•Reactivity
•Corrosivity
•Thermal & chemical
stability
•Hazardous effects of
inadvertent mixing of
materials that could
foreseeably occur
For process technology, you
must provide;
•A block flow diagram or
simplified process flow
diagram
•Information on process
chemistry
•Maximum intended inventory
of the EPA-regulated
chemical
•Safe upper & lower limits for
such items as temperature,
pressure, flows, or
composition
•An evaluation of the
consequences of deviation
For equipment in the
process, you must include
information on;
•Materials of construction
•Piping & instrument
diagrams (P&IDs)
•Electrical classification
•Relief system design &
design basis
•Ventilation system design
•Design codes & standards
employed
•Safety systems
•Material and energy balances
for processes built after June
21,1999
You must maintain equipment information for your plant. Such information is
ordinarily supplied with the construction of the plant, and with major replacements
and revisions to the plant. Generally, equipment information is found in operations
and maintenance (O&M) manuals or equipment submittals. The rule only requires
that you have information for that part of your plant that handles, or could cause a
release of, the regulated substances you have.
i
WHERE To Go FOR MORE INFORMATION
Diagrams. You may find it useful to consult Appendix B of OSHA's PSM final rule,
computer software programs that do P&IDs, or other diagrams.
Guidance and Reports. Various engineering societies issue technical reports
relating to process design. Other sources you may find useful include:
October 27,1998
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+ Guidelines for Process Safety Documentation, Center for Chemical Process
Safety of the American Institute of Chemical Engineers 1995.
4- Emergency Relief System Design Using DIERS Technology, American
Institute of Chemical Engineers, 1992.
4- Emergency Relief Systems for Runaway Chemical Reactions and Storage
Vessels: A Summary of Multiphase Flow Methods, American Institute of
Chemical Engineers, 1986.
4- Guidelines for Pressure Relief and Emergency Handling Systems, Center for
Chemical Process Safety of the American Institute of Chemical Engineers,
1998.
4- Loss Prevention in the Process Industries, Volumes I, II, and HI, Frank P.
Lees, Butterworths: London 1996.
The Chlorine Institute publishes a number of documents on chlorine handling
including:
4- Chlorine Vaporizing Systems, Pamphlet # 9.
4- Cylinder and Ton Container Procedures for Chlorine Packaging, Pamphlet #
17.
4- Water and Wastewater Operators Chlorine Handbook, Pamphlet # 155.
The Compressed Gas Association publishes:
4- Sulfur Dioxide on properties, storage, handling, and use of sulfur dioxide
(Order #G-3).
4- ANSI K61.1 on the storage and handling of anhydrous ammonia (Order # G
2.1).
4- Anhydrous Ammonia on properties, storage, handling, and use of anhydrous
ammonia (Order # G-2).
NFPA-820 (Standard for Fire Protection in Wastewater Treatment and Collection
Facilities) provides guidance on design issues.
MSDSs. MSDSs are available from a number of websites. The University of
Vermont provides access to three university-maintained MSDS collections on its
website: http://www.hazard.com. The on-line databases usually have multiple copies
of MSDSs for each substance and can help you find an MSDS that is well organized
and easy to read. EPA has not verified the accuracy or completeness of MSDSs on
any of these sites nor does it endorse any particular version of an MSDS. You
should review any MSDS you use to ensure that it meets the requirements of the
hazard comrnunication standard (29 CFR 1910.1200).
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Chapter 7
Prevention, Program (Program 3)
7-6
QS&AS
PROCESS SAFETY INFORMATION
Q. What does "materials of construction" apply to and how do I find this information?
A. You must document the materials of construction for all process equipment in a covered process.
For example, you need to know the materials of construction for process vessels, storage vessels,
piping, hoses, valves, and flanges. Equipment specifications should provide this information.
Q. What does "electrical classification" mean?
A. Equipment and wiring for locations where fire and explosion hazards may exist must meet
requirements based on the hazards. Each room, section, or area must be considered separately.
Equipment should be marked to show Class, Group, and operating temperature or temperature range.
You must determine the appropriate classification for each area and ensure that the equipment used is
suitable format classification. The equipment covered includes transformers, capacitors, motors,
instruments, relays, wiring, switches, fuses, generators, lighting, alarms, remote controls,
communication, and grounding. Electrical classification will be included in equipment specifications.
Q. What does "relief system design basis" mean?
A. 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 creates the largest load to be relieved, the assumptions used, and if the
device meets a certain code. Relief devices on pressure vessels must conform to ASME codes.
Industry codes (e.g., API RP 520) also provide guidance on scenarios that should be considered and
on equations for sizing of devices. Scenarios you may need to consider include fire, blocked flow,
control valve failure, overheating, power outage, tube rupture, and cooling water failure. For two-
phase flow, you should review AIChE publications from the Design Institute for Emergency Relief
Systems (DIERS).
Q. What do I have to do for material and energy balances?
A. For new processes, you must document both material and energy inputs and outputs of a process.
For example, you would document the quantity of a regulated substance added to the process, the
quantity consumed during the process, and the quantity that remains in the output. This requirement
will not generally apply to storage processes.
7.3 PROCESS HAZARD ANALYSIS (§68.67)
Exhibit 7-4 provides a summary of the requirements for process hazard analyses
(PHAs).
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Chapter 7
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EXHIBIT 7-4
PROCESS HAZARD ANALYSIS REQUIREMENTS
The PHA must cover::
•Hazards of the process
•Identification of previous,
potentially catastrophic
incidents
•Engineering and
administrative controls
applicable to the hazards
•Consequence of failure of
controls
•Siting
•Human factors
•Qualitative evaluation of
health and safety impacts of
control failure
Techniques must be one or
more of;
•What If "
•Checklist
•What If/Checklist
•Hazard and Operability Study
(HAZOP)
•Failure Mode and Effects
Analysis (FMEA)
•Fault Tree Analysis
•Appropriate equivalent
methodology
Other requirements;
•Analysis must be done by a
team, one member of which
has experience in the process,
one member of which is
knowledgeable in the PHA
technique
•A system must be developed
for addressing the team's
recommendations and
documenting resolution and
corrective actions taken
•The PHA must be updated at
least once every five years
•PHAs and documentation of
actions must be kept for the
life of the process
EPA/OSHA DIFFERENCES
You can use a PHA conducted under the OSHA PSM standard as your initial process
hazard analysis. All OSHA PHAs must have been completed by May 1997.
Therefore, the only "new" PHAs will be for non-OSHA Program 3 processes. If the
process is subject to OSHA PSM, you can update and revalidate your PHA on
OSHA's schedule.
Offsite impacts. You should consider offsite impacts when you conduct a PHA
under EPA's rule (except for an initial PHA where are using the PHA conducted for
OSHA PSM). If you are in the Program 3 prevention program because you must
comply with the PSM standard, you may not have fully considered offsite
consequence because the focus of PSM is worker protection. Practically speaking,
however, there should be few instances where the scenarios considered for OSHA
fail to address offsite impacts. A well-done PHA should identify all failure scenarios
that could lead to significant exposure of workers, the public, or the environment. •
The only issue that may require further consideration for part 68 processes is
whether any protection measures that were adequate for worker safety are inadequate
for public and environmental safety.
Consider two circumstances — one where OSHA's PSM standard and EPA's risk
management program rule lead to the same result, and another where protecting
workers could mean endangering the public and the environment. For flammables,
any scenario that could affect the public almost certainly would have the potential to
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7-8
affect workers; measures taken to protect your employees likely will protect the
public and the environment. For toxics under PSM, however, you may plan to
address a loss of containment by venting toxic vapors to the outside air. In each
circumstance, a PHA should define how the loss of containment could occur.
However, for EPA, the PHA team should reassess venting as an appropriate
mitigation measure.
Updating and revalidating your PHA. For EPA, you must complete the initial
PHA for each Program 3 process not later than June 21, 1909, and update it at least
once every five years. You may complete an initial PHA before that date. You may
use an OSHA PHA as your initial PHA, and update and revalidate it every five years
on the OSHA schedule. A PHA completed after August 19, 1996 (the effective date
of part 68) should consider offsite impacts.
METHODS
Unless your WWTP is uncommonly complex, the checklist method is likely to be
sufficient to meet the need in smaller plants. Operators might find it practical to add
what-if questions to supplement the checklist, or use the what-if/checklist method.
See the guidance provided in Program 2, section 6-3 and Appendix A to Chapter 6,
for examples of checklists and what-if questions. Guidance on how to use these
methods, or HAZOPs, is included in that chapter.
If the chlorine, sulfur dioxide, or ammonia receiving and storage facilities are
designed to receive tank truck or rail car quantities, then the Hazard and Operability
(HAZOP) method is likely to be best. If you do not have anyone on staff who has
taken part in a HAZOP or taken HAZOP training, you may want to engage a skilled
study leader.
" ;l
REJECTING TEAM RECOMMENDATIONS
You may not always agree with your PHA team's recommendations and may wish to
reject a recommendation. OSHA's compliance directive CPL 2-2.45A-revised states
that you may decline a team recommendation if you can document one of the
following: (1) the analysis upon which the recommendation is based contains factual
errors; (2) the recommendation is not necessary to protect lie health of employees or
contractors; (3) an alternative measure would provide a sufficient level of protection;
or (4) the recommendation is infeasible. For part 68, you should also consider
whether recommendations are not necessary to protect public health and the
environment.
UPDATING YOUR PHA
You should update or revalidate your PHA whenever there is a new hazard or risk
created by changes to your process. Such changes might include introducing a new
process, process equipment, or regulated substance; altering process chemistry that
results in any change to safe operating limits; or other alteration that introduces a
new hazard. You might, for example, introduce a new hazard if you installed a gas
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Chapter 7
Prevention Program (Program 3)
pipeline next to a storage tank containing a regulated substance. Other candidates
could be making changes in process constituents that increase the possibility of
runaway reactions or polymerization. EPA recommends that you consider
revalidating your PHA whenever adjoining processes create a hazard. Remember
that you have a general duty to prevent accidents and ensure safety at your source,
which may require you to take steps beyond those specified in the risk management
program rule.
Qs & As
OFFSITE CONSEQUENCES
Q. What does EPA mean by "consider offsite consequences"? Do we have to do an environmental
impact assessment (EIA)?
A. 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 to
identify any failure scenarios that could lead to public exposures and to examine whether your
strategies are adequate to reduce the risk of such exposures.
Q. If I need to revise a PHA to consider offsite consequences, when do I have to do that?
A. hi general, for a PHA completed to meet the requirements of OSHA PSM, you should revise the
PHA to consider offsite consequences when you update that PHA. Any PHA for a covered process
completed or updated for OSHA PSM after August 19, 1996, when part 68 was effective, should
examine offsite consequences. For example, if you completed an initial PHA for OSHA PSM in May
1993, OSHA requires that you update that PHA by May 1998. In that update, you should consider
offsite consequences. If you complete your initial PHA for OSHA in May 1995, you must update it
by May 2000; PHAs conducted for part 68 must include consideration of offsite consequences at that
time.
WHERE To Go FOR MORE INFORMATION
Appendix 7-A of this chapter provides a summary of each of the techniques, a
description of the types of processes for which they may be appropriate, and
estimates about the time and staff required for each.
Part 68 and OSHA PSM require that whichever technique or techniques you use, you
must have at least one person on the PHA team who is trained in the use of the
technique. Training on such techniques is available from a number of professional
organizations as well as private companies. You may have staff members who are
capable of providing this training as well. Many trade associations publish detailed
guidance on methods for conducting a process hazard analysis. You might find the
following documents useful.
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7-10
Guidelines for Hazard Evaluation Procedures, 2nd Ed. with Worked
examples, Center for Chemical Process Safety of the American Institute of
Chemical Engineers 1992.
Evaluating Process Safety in the Chemical Industry, Chemical
Manufacturers Association.
+ Loss Prevention in the Process Industries, Volumes I, II, and III, Frank P.
Lees, Butterworths: London 1996.
'" ' '! , '. ' !
!i • I! •' . . I "
+ Management of Process Hazards (RP 750), American Petroleum Institute.
- • ; ,- . i: i . ., ,
+ Risk-Based Decision Making (Publication 16288), American Petroleum
Institute.
7.4 OPERATING PROCEDURES (§68.69)
:, ! • i • i
Exhibit 7-5 summarizes what your operating procedures must address. Operating
procedures must be readily accessible to workers who operate or maintain the
process. You must review operating procedures as often as necessary to assure that
they reflect current practices and any changes to the process or facility. You must
certify annually that the operating procedures are current and accurate.
In a WWTP, it will be especially important to detail, very specifically, the
procedures and safeguards for connecting and disconnecting cylinders, tank trucks or
rail cars of regulated substances. These procedures should also detail the required
precautions, e.g., having an emergency respirator readily available. Also, assuring
that emergency equipment is functional and readily available should be part of the
instructions. For example, an inspection of the air tank on self-contained breathing
apparatus prior to making or breaking connections should be considered.
i
I
In WWTPs, it is likely that regular operating procedures will include startup, normal
operations, and normal shutdown. Provision for emergency shutdown and startup
following a turnaround or emergency shutdown need to be included only to the
extent that they differ from your regular procedures. These procedures should also
detail what to do in the event of an emergency. In particular, they must include the
shutdown actions operators should take, without reference to supervisors, to avoid
more serious consequences and the conditions requiring them.
!' ' I
The operating limits section should detail what would happen if the actual operating
parameters (pressure, flow, temperature) were higher or lower than intended. Then
the procedures should tell operators what to do to correct them.
i
The safety system section should explain all about your safety systems. These are
alarms, shutdown devices, relief systems, remote telephone alerting systems, and the
like. The procedures should show:
!|
+ What the system or device is.
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Chapter 7
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What it is supposed to do.
How it works.
How to operate it, if operators must initiate action.
EXHIBIT 7-5
OPERATING PROCEDURES REQUIREMENTS
Steps for each
operating phase
•Initial startup
•Normal operations
•Temporary operations
•Emergency shutdown
•Emergency operations
• Normal shutdown
•Startup following a
turnaround or
emergency shutdown
•Lockout/tagout
•Confined space entry
•Opening process
equipment or piping
•Entrance into the facility
Operating limits
•Consequences of
deviations
•Steps to avoid,
correct deviations
Safety & health
considerations
•Chemical properties & hazards
•Precautions for preventing
chemical exposure
•Control measures for exposure
•QC for raw materials and
chemical inventory
•Special or unique hazards
Safety
systems &
their
functions
•Address
whatever is
applicable
Operating procedures, especially for plants that run unattended
overnight or on weekends, should include provisions to prevent
vandalism or sabotage by use of locks, fences, police patrol, or other
secure means.
WHERE To Go FOR MORE INFORMATION
Chapter 6 of this document provides descriptions of each operating phase and when
these phases may not apply to certain operations.
The Chlorine Institute (http://www.cl2.com) publishes information on safe use and
handling of chlorine. Its Water and Wastewater Operators Chlorine Handbook
(Pamphlet # 155) provides general training and procedures.
The Water Environment Federation (601 Wythe Street, Alexandria, VA 22134, (703)
684-2470) provides general procedures as part of its training programs for
wastewater treatment.
Although the reports below target the chemical industry, you may find useful
information in them:
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7-12
+ Guidelines for Process Safety Fundamentals for General Plant Operations,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1995.
,1 ! l|
+ Guidelines for Safe Process Operations and Maintenance, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1995. '
+ Guidelines for Writing Effective Operating and Maintenance Procedures,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1996.
7.5 TRAINING (§68.71)
i ,
i
You are required to train new operators on the operating procedures and cover health
and safety hazards, emergency operations, and safe work practices applicable to the
employee's tasks. For workers involved in operating the process before June 21,
1999, you may certify in writing that they are competent to operate the process
safely, in accordance with the operating procedures. At least every three years you
must provide refresher training (you must consult with employees involved in
operating the process to determine the appropriate frequenc^). Finally, you are
required to determine that each operator has received and understood the training
and keep a record for each employee with the date of the training and the method
used to verify that the employee understood the training.
For WWTPs, training should cover the activities that could lead to releases of the
toxic gases and flammables that are used in WWTPs. These activities should be
identified in the process hazard analysis and bear particular attention:
+ Connecting, and disconnecting, cylinders of Chlorine and Sulfur Dioxide.
Training should cover inspection of the fittings and tubing to assure that they
are in good condition and inspection (and discard if necessary) of tools used
for the job. Training should also include identification of vapor and liquid
connections on the cylinders and identification of the operating conditions
that will show that the connections are hooked up in reverse.
+ Material handling of cylinders. Training should cover inspection of material
handling equipment, including hoists, cylinder carriers and hooks, and
cylinder chocks. Also, inspection for and removal of combustibles or
flammables in storage areas should be a part of training.
,',• • " I
WHERE To Go FOR MORE INFORMATION
The Water Environment Federation provides several training programs including the
following:
:.• • . I
i ' . .' ;
+ Basic Course for Wastewater Treatment Plant Operators, Instructor Set
Order No. E0100GB, Student Workbook Order No. E0110GB.
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Chapter 7
Prevention Program (Program 3)
4- Intermediate Course for Wastewater Treatment Plant Operators, Instructor
Set Order No. E0295GB, Student Workbook Order No. E0296GB.
4- Chlorination Skill Training Course, Order No. EOS 12GB. Self Instruction
Course.
In addition, the following may be useful.
4- Guidelines for Process Safety Fundamentals for General Plant Operations,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1995.
4- Guidelines for Technical Planning for On-Site Emergencies, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1995.
4- Federally Mandated Training and Information (Publication 12000),
American Petroleum Institute.
7.6 MECHANICAL INTEGRITY (§68.73)
You must have a mechanical integrity program for pressure vessels and storage
tanks, piping systems, relief and vent systems and devices, emergency shutdown
systems, controls, and pumps. Exhibit 7-6 briefly summarizes the other requirements
for your mechanical integrity program. The mechanic integrity requirement is
similar to the maintenance requirement under Program 2, but covers additional areas,
such as quality assurance.
For most of the equipment in a WWTP, the manufacturer will have supplied
maintenance instructions. These can be used to fulfill the requirements for
maintenance procedures. Where such instructions are not available, you will need to
develop them. In addition to the major pieces of equipment, you will need to
develop inspection procedures that consider both repair or replacement requirements
for the following items:
4- Fittings
4- Tubing
4- Pressure relief devices
4- Gauges, pressure switches, and other instrumentation
4- Rotameters
4- Pressure regulators, and pressure gauges
4- Leak detectors
4- Eductors, vacuum mixers, or other devices used to mix chlorine, sulfur
dioxide, and other regulated substances into waste water streams
4- Material handing equipment
4- Tools
4- All other equipment used to handle, transfer, or use the regulated substances.
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Chapter 7
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7-14
EXHIBIT 7-6
MECHANICAL INTEGRITY CHART
Written
procedures
•Establish &
implement
written
procedures to
maintain the
integrity of
process
equipment.
Training
•— ^^-^^— MMIM^^^^ i n.
•Train process
maintenance
employees in an
overview of the
process and its
hazards.
•Make sure this
training covers
the procedures
applicable to
safe job
performance.
Inspection &
testing
•Inspect & test
process equipment.
•Use recognized and
generally accepted
good engineering
practices.
•Follow a schedule
that matches the
manufacturer's
recommendations or
more frequently if
prior operating
experience indicates
is necessary.
•Document each
inspection & test
with: Date,
inspector name,
equipment identifier,
test or inspection
performed, results.
Equipment
deficiencies
•Correct
equipment
deficiencies
before further
use of process
equipment or
whenever
necessary to
ensure safety.
Quality
assurance
•Establish a QA
program for new
construction &
equipment, newly
installed
equipment,
maintenance
materials, and
spare parts &
equipment.
Where there is the possibility of corrosion, these inspections are especially
important. The regulated substances used are normally not corrosive, when they are
dry. However, all of them can become highly corrosive if the equipment using them
is wet. Attention to this aspect can be vital.
In larger plants, where there are storage tanks for chorine, sulfur dioxide or
ammonia, the tanks and associated piping should be inspected regularly. Suppliers
are likely to be able to provide recommendations for this inspection and preventive
maintenance.
You may need to cover a number of the maintenance procedures. The value in these
procedures comes from the use of permits as a communication device. They are
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Chapter 7
Prevention Program (Program 3)
intended to communicate the hazards, and needed precautions, to the workers
performing work under the permits. Also, the provision of the permit to operators
will inform them of the nature of the work in progress, so that they can govern their
activity so as not to interfere with or provide additional hazard to the job in progress.
The maintenance procedures you need are the following:
4- Confined space entry. For guidance see the OSHA standard, 29 CFR
1910.146
+ Lockout-tagout. For guidance, see the OSHA standard 29 CFR 1910.146.
+ Pipeline breaking. Operators should prepare their own procedure that:
> Provide a means to communicate the hazards that might be presented
to those who will encounter them.
i> Provide a list the precautions needed to safely control these hazards.
> Provide a means to communicate these precautions, and insure that
they are understood by those who must take the precautions.
t> Provide a requirement that these precautions are effectively taken
and remain in place until the work is complete.
+ Control of entry into hazardous areas. Operators should provide a procedure
that controls the access of individuals to places where regulated materials are
stored, handled or used. There are three objectives to this control:
> Limit potential exposure to hazardous materials to only the essential
requirements.
> Insure that only properly trained or informed persons have access to
hazardous material locations.
> Ensure that the hazardous areas are secure.
Operators are expected to provide spare parts store where needed. Spare parts kept
on hand, are an important part of Mechanical Integrity. There is some plant
equipment, like cylinder connection tubing and connecting devices, that must not be
used when they are worn. Prompt replacement is a valuable preventive action. The
operator must assure that critical parts are readily available. As part of the Quality
Assurance (see column 5 of Exhibit 7-6) needs, operators are expected to assure that
these are the right spare parts. Substitution of parts of the wrong specification can
lead to a catastrophic release of these hazardous materials.
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7-16
WHERE To Go FOR MORE INFORMATION
Guidance and Reports. The documents listed under Process Safety Information
may be useful for maintenance procedures as well. In addition, the Chlorine Institute
publishes pamphlets on chlorine system maintenance, including the following:
,i
4- Maintenance Instructions for Chlorine Institute Standard Safety Valves,
Type 1-1/2 JQ(# 39).
4- Maintenance Instructions for Chlorine Institute Standard Angle Valve (#40).
1 il
4- Maintenance Instructions for Chlorine Institute Standard Safety Valve, Type
4JQ (#41).
4 Maintenance Instructions for Chlorine Institute Standard Excess Flow
Valves (#42).
Other sources of guidance and reports you may find useful include:
4 Guidelines for Process Equipment Reliability Data with Data Tables, Center
for Chemical Process Safety of the American Institute of Chemical
Engineers 1989.
4 Guidelines for Process Safety Documentation, Center for Chemical Process
Safety of the American Institute of Chemical Engineers 1995.
4 Pressure Vessel Inspection Code: Maintenance Inspection, Rating, Repair,
and Alteration (API 510), American Petroleum Institute.
i
4 Tank Inspection, Repair, Alteration, and Reconstruction (Std 653), American
Petroleum Institute.
7.7 MANAGEMENT OF CHANGE (§68.75)
Exhibits 7-7 briefly summarizes EPA's MOC requirements.
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Chapter 7
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EXHIBIT 7-7
MANAGEMENT OF CHANGE REQUIREMENTS
MOC procedures
must address:
•Technical basis
for the change
•Impact on safety
and health
•Modifications to
operating
procedures
•Necessary time
period for the
change
• Authorization
requirements for
proposed change
Employees
affected by the
change must:
•Be informed of the
change before
startup
•Trained in the
change before
startup
Update process safety
information if:
•A change covered by
MOC procedures results
in a change in any PSI
required under EPA's
rule (see § 67.65)
Update operating
procedures if:
•A change covered
by MOC procedures
results in a change
in any operating
procedure required
under EPA's rule
(see § 67.69)
The purpose of this element of the RMP rule, and the next element, pre-startup
review, is to make sure that, if you make a change to your covered process or your
facility in a way that affects a covered process, that you do so safely.
The management of change provision will apply when you make a change that can
affect a regulated substance, (for example, by adding chorine directly to the
contactor instead of dissolving it in water first). Or it will apply if you add a
regulated substance (for example, by adding a new digester that runs your total mass
of digester gas over the 10,000 pound threshold). Or you may change tubing from
steel to plastic. Or you may build a new chemical storage building that houses C12
and SO2 in the same place, where you had separate buildings previously.
Any change that affects the regulated substances, whether in storage, use, or
processing, is subject to Management of Change. It does not apply to repairs or
maintenance or in-kind replacements. Also, it does not apply when you make a
change in processing conditions that are within the normal bounds of operation, like
a change in C12 addition rate.
Method of review. The first column of Exhibit 7-7 calls for understanding the
impact of the change on safety and health. This usually means that some study is
needed. If the change is a major one (e.g., a new chlorine storage building for bulk
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Chapter?
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7-18
chlorine), you might choose to run a full-blown Hazard and Operability study
(HAZOP). Your engineering firm, or engineer, is likely to organize it For a small
change (e.g., a not-in-kind replacement of a chlorine eductor), the checklist questions
(see Chapter 6) that apply to the equipment being changed are likely to be sufficient.
Or your supplier could possibly refer you to other WWTPs that use it, and you could
check with them to see if any problems have come up that are worth further check or
study.
The objective is to be very sure that after the change has been made, the process or
plant is safe to operate before you start to use it Take the time to analyze the
change and check the system carefully.
!'. 1 i.
WHERE To Go FOR MORE INFORMATION
+ Management of Change in Chemical Plants: Learning from Case Histories,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1993.
:,", 'i ,'
+ Plant Guidelines for Technical Management of"Chemical Process Safety,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1992.
• l , ' i •:
i n i
+ Management of Process Hazards (RP 750), American Petroleum Institute.
4- Guidelines for Engineering Design for Process Safety, Center for Chemical
Process Safety of the American Institute of Chemical Engineers 1993.
7.8 PRE-STARTUP REVIEW (§68.77)
You must conduct your pre-startup safety review for new stationary sources or
modified stationary sources when the modification is significant enough to require a
change in safety information under the management of change element. You must
conduct your pre-startup review before you introduce a regulated substance to a
process, and you must address the items listed in Exhibit 7-8.
EXHIBIT 7-8
PRE-STARTUP REVIEW REQUIREMENTS
Design Specifications
•Confirm that new or
modified construction
and equipment meet
design specifications.
Adequate Procedures
•Ensure that
procedures for safety,
operating, maintenance,
and emergencies are
adequate and in place.
PHA/MOC
Perform a PHA and
resolve or implement any
recommendations for new
process. Meet
management of change
requirements for modified
process.
Training
•Confirm that
each employee
involved in the
process has been
trained completely.
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Like Management of Change, in the preceding section, this element of the RMP rule
is to make sure that changes you intend to make are safe to operate before you put
them into operation. It places the responsibility squarely on the operator to check that
persons making the change (e.g., the maintenance people, or the engineering firm.)
have properly completed the job before start up. If it is not properly completed, it is
not acceptable to start the process.
If you do not have the expertise to do conduct a pre-startup review, you will need to
arrange for someone with the necessary expertise to conduct it. Pre-startup safety
review is an intended redundancy to the Management of Change requirements.
Again, the principle is take the time to analyze the change and check the system
carefully before operating it.
7.9 COMPLIANCE AUDITS (§68.79)
You must conduct an audit of the process to evaluate compliance with the prevention
program requirements at least once every three years. At least one person involved
in the audit must be knowledgeable in the process. You must develop a report of the
findings and document appropriate responses to each finding and document that
deficiencies have been addressed. The two most recent audit reports must be kept
on-site.
The OSHA compliance guideline, CPL 2-2.34a, is a good starting point for an audit
of the prevention program for a WWTP. Operators should apply the questions to
that portion of their facility that uses or handles the regulated substances present on
the plant. It is critical that you resolve any questions raised by, or findings of, the
audit. These are likely to describe flaws in the management of process safety that
could lead to a release of highly toxic or flammable gases. Continued operation with
such flaws should not be permitted.
WHERE To Go FOR MORE INFORMATION
+ Guidelines for Auditing Process Safety Management Systems, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1993.
7.10 INCIDENT INVESTIGATION (§68.81)
Exhibit 7-9 briefly summarizes the steps you must take for investigating incidents.
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EXHIBIT 7-9
INCIDENT INVESTIGATION REQUIREMENTS
•Initiate an investigation
promptly.
Begin investigating no later than 48 hours following the
incident.
•Establish a knowledgeable
investigation team.
Establish an investigation team to gather the facts, analyze the
event, and develop the how and why of what went wrong. At
least one team member must have knowledge of the process
involved. Consider adding other workers in the process area
where the incident occurred. Their knowledge will be
significant and should give you the fullest insight into the
incident.
•Summarize the investigation in a
report.
Among other things, the report must identify the factors
contributing to the incident Remember that identifying the root
cause may be more important than identifying the initiating
event. The report must also include any recommendations for
corrective actions. Remember that the purpose of the report is to
help management take corrective action.
•Address the team's findings and
recommendations.
Establish a system to address promptly and resolve the incident
report findings and recommendations; document resolutions and
corrective actions.
•Review the report with your
staff and contractors.
You must share the report - its findings and recommendations
with affected workers whose job tasks are relevant to the
incident.
•Retain the report.
Keep incident investigation reports for five years.
You must investigate each incident which resulted in, or could have resulted in, a
"catastrophic release of a regulated substance." A catastrophic release is one that
"presents an imminent and substantial endangerment to public health and the
environment." Although the rule requires you to investigate only those incidents
which resulted in, or could reasonably have resulted in a catastrophic release, EPA
encourages you to investigate all accidental releases. Investigating minor accidents
or near misses can help you identify problems that could result in major releases if
left unaddressed.
WHERE To Go FOR MORE INFORMATION
+ Guidelines for Investigating Chemical Process Incidents, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1992.
+ Guide for Fire and Explosion Investigations (NFPA 921), National Fire
Protection Association.
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7.11 EMPLOYEE PARTICIPATION (§68.83)
Exhibit 7-10 briefly summarizes what you must do.
EXHIBIT 7-10
EMPLOYEE PARTICIPATION REQUIREMENTS
•Write a plan.
•Consult with
employees.
•Provide access to
information.
Develop a written plan of action regarding how you will implement
employee participation.
Consult your employees and their representatives regarding conducting
and developing PHAs and other elements of process safety management
in the risk management program rule.
Ensure that your employees and their representatives have access to PHAs
and all other information required to be developed under the rule.
7.12 HOT WORK PERMITS (§68.85)
Exhibit 7-11 briefly summarizes how to meet the hot work permit requirement.
EXHIBIT 7-11
HOT WORK PERMITS REQUIREMENTS
•Issue a hot work permit.
•Implement fire prevention and
protection.
•Indicate the appropriate dates.
•Identify the work.
•Maintain the permit on file.
You must issue this permit for hot work conducted on or near a
covered process.
You must ensure that the fire prevention and protection
requirements in 29 CFR 1910.252(a) are implemented before the
hot work begins. The permit must document this.
The permit should indicate the dates authorized for hot work.
The permit must identify the object on which hot work is to be
performed.
You must keep the permit on file until workers have completed the
hot work operations.
Welding, cutting, brazing, grinding, sandblasting, and other spark-producing work is
subject to this element of the standard. Because there is likely to be flammable gas
present, you should consider that fire or explosion hazards exist.
The value in hot work procedures comes from the use of permits as a communication
device. They are intended to communicate the hazards, and needed precautions, to
the workers performing -work under the permits. Also, the provision of the permit to
operators will inform them of the nature of the work in progress, so that they can
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7-22
govern their activity so as not to interfere with or provide additional hazard to the job
in progress.
WHERE To Go FOR MORE INFORMATION
•f Standard for Fire Prevention in Use of Cutting and Welding Processes
(NFPA 518), National Fire Protection Association.
;> ''•'! ' . : '" *: :i • j • ' • " ' •' ! i ;
+ Standard for Welding, Cutting and Brazing, 29 CFR 1910 SubpartQ.
7.13 CONTRACTORS (§68.87)
;l
Exhibit 7-12 summarizes both yours and the contractors' responsibilities where
contractors perform maintenance or repair, turnaround, major renovation, or
specialty work on or adjacent to a covered process.
EXHIBIT 7-12
CONTRACTORS CHART
You must...
•Check safety performance. When selecting a
contractor, you must obtain and evaluate
information regarding the safety performance
of the contractor.
•Provide safety and hazards information.
You must inform the contractor of potential
fire, explosion, or toxic release hazards; and of
your emergency response activities as they
relate to the contractor's work and the process.
•Ensure safe practices. You must ensure that
you have safe work practices to control the
entrance, presence, and exit of contract
employees in covered process areas.
•Verify that the contractor acts responsibly.
You must verify that the contractor is fulfilling
its responsibilities.
Your contractor must...
•Ensure training for its employees. The
contractor must train its employees to ensure
that they perform their jobs safely and in
accordance with your source's safety
procedures.
•Ensure its employees know process hazards
and applicable emergency actions. The
contractor must assure that contract employees
are aware of hazards and emergency
procedures relating to me employees' work.
•Document training. The contractor must
prepare a record documenting and verifying
adequate employee training.
•Ensure its employees are following your
safety procedures.
•Inform you of hazards. The contractor must
tell you of any unique hazards presented by its
work or of any hazards it finds during
performance.
I
EPA/OSHA DIFFERENCES
EPA has no authority to require that you maintain an occupational injury and illness
log for contract employees. Be aware, however, that OSHA does have this authority,
and that the PSM standard does set this requirement. (See 29 CFR
1910.119(h)(2)(vi)).
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7-23 Prevention Program (Program 3)
WHERE To Go FOR MORE INFORMATION
Contractor and Client Relations to Assure Process Safety, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1996.
API/CMA Managers Guide to Implementing a Contractor Safety Program
(RP 2221), American Petroleum Institute.
Improving Owner and Contractor Safety Performance (RP 2220), American
Petroleum Institute.
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7-24
APPENDIX 7-A
PHA TECHNIQUES
This appendix provides descriptions of each of the PHA techniques listed in the OSHA PSM
standard and § 68.67. These descriptions include information on what each technique is, which types of
processes they may be appropriate for, what their limitations are, and what level of effort is typically
associated with each. This information is based on Guidelines for Hazard Evaluation Procedures, 2nd
Ed., published by AIChE/CCPS. If you are interested in more detailed discussion and worked examples,
you should refer to the AIChE/CCPS volume.
ii
Neither the information below nor the full AIChE/CCPS volume will provide you with enough
information to conduct a PHA. The rule requires that your PHA team include at least one person trained
in the technique you use. Training in PHA techniques is available from a number of organizations. If
you must conduct multiple PHAs, you are likely to need to update your PHAs frequently, or you have a
complex process that will take several weeks to analyze, you may want to consider training one or more
of your employees! If you have a single process that is unlikely to change more than once every five
years, you may find it more cost-effective to hire a trained PHA leader.
DESCRIPTIONS OF TECHNIQUES
I
CHECKLISTS
i, • i
Checklists are primarily used for processes that are covered by standards, codes, and industry
practices — for example, storage tanks designed to ASME standards or ammonia handling covered by
OSHA (29 CFR 1910.111).. Checklists are easy to use and can help familiarize new staff with the
process equipment. AIChE/CCPS states that checklists are a highly cost-effective way to identify
customarily recognized hazards. Checklists are dependent on the experience of the people who develop
them; if the checklist is not complete, the analysis may not identify hazardous situations.
Checklists are created by taking the applicable standards and practices and using them to
generate a list of questions that seek to identify any differences or deficiencies. If a checklist for a
process does not exist, an experienced person must develop one based on standards, practices, and
facility or equipment experience. A completed checklist usually provides "yes," "no," "not applicable,"
and "need more information" answers to each item. A checklist analysis involves touring the process
area and comparing equipment to the list.
. i '
AIChE/CCPS estimates that for a small or simple system a checklist will take 2 to 4 hours to
prepare, 4 to 8 hours to evaluate the process, and 4 to 8 hours to document the results. For larger or more
complex processes, a checklist will take 1 to 3 days to prepare, 3 to 5 days to evaluate, and 2 to 4 days to
document.
Examples of checklists are given in Chapter 6, Appendix 6-A.
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WHAT-IF
A What-If is a brainstorming approach in which a group of people familiar with the process ask
questions about possible deviations or failures. These questions may be framed as What-If, as in "What
if the pump fails?" or may be expressions of more general concern, as in "I worry about contamination
during unloading." A scribe or recorder takes down all of the questions on flip charts or a computer. The
questions are then divided into specific areas of investigation, usually related to consequences of interest.
Each area is then addressed by one or more team members.
What-If analyses are intended to identify hazards, hazardous situations, or accident scenarios.
The team of experienced people identifies accident scenarios, consequences, and existing safeguards,
then suggest possible risk reduction alternatives. The method can be used to examine deviations from
design, construction, modification, or operating intent. It requires a basic understanding of the process
and an ability to combine possible deviations from design intent with outcomes. AIChE describes this as
a powerful procedure if the staff are experienced; "otherwise, the results are likely to be incomplete."
A What-If usually reviews the entire process, from the introduction of the chemicals to the end.
The analysis may focus on particular consequences of concern. AIChE provides the following example
of a What-If question: "What if the raw material is the wrong concentration?" The team would then try
to determine how the process would respond: "If the concentration of acid were doubled, the reaction
could not be controlled and a rapid exotherm would result." The team might then recommend steps to
prevent feeding wrong concentrations or to stop the feed if the reaction could riot be controlled.
A What-If of simple systems can be done by one or two people; a more complex process requires
a larger team and longer meetings. AIChE/CCPS estimates that for a small or simple system a What-If
analysis will take 4 to 8 hours to prepare, 1 to 3 days to evaluate the process, and 1 to 2 days to document
the results. For larger or more complex processes, a What-If will take 1 to 3 days to prepare, 4 to 7 days
to evaluate, and 4 to 7 days to document.
Examples of What If questions are given in Chapter 6, Appendix 6-A.
WHAT-IF/CHECKLIST
A What-If/Checklist combines the creative, brainstorming aspects of the What-If with the
systematic approach of the Checklist. The combination of techniques can compensate for the weaknesses
of each. The What-If part of the process can help the team identify hazards and accident scenarios that
are beyond the experience of the team members. The checklist provides a more detailed systematic
approach that can fill in gaps in the brainstorming process. The technique is generally used to identify
the most common hazards that exist in a process. AIChE states that it is often the first PHA conducted
on a process, with subsequent analyses using more detailed approaches.
The purpose of a What-If/Checklist is to identify hazards and the general types of accidents that
could occur, evaluate qualitatively the effects of the effects, and determine whether safeguards are
adequate. Usually the What-If brainstorming precedes the use of the checklist, although the order can be
reversed.
The technique usually is performed by a team experienced in the design, operation, and
maintenance of the process. The number of people required depends on the complexity of the process.
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( i" "in
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AICbE/CCPS estimates that for a small or simple system a What-If/Checklist analysis will take 6 to 12
hours to prepare, 6 to 12 hours to evaluate the process, and 4 to 8 hours to document the results. For
larger or more complex processes, a What-If/Checklist will take 1 to 3 days to prepare, 4 to 7 days to
evaluate, and 1 to 3 weeks to document.
,;i" Hi ' , • ' ' i •'
See Chapter 6 for a further discussion of What If/Checklists.
HAZOP
" ,,r • , .1 . • . ' I ,
The Hazard and Operability Analysis (HAZOP) was originally developed to identify both
hazards and operability problems at chemical process plants, particularly for processes using
technologies with which the plant was not familiar. The technique has been found to be useful for
existing processes as well. A HAZOP requires an interdisciplinary team and an experienced team leader.
The purpose of a HAZOP is to review a process or operation systematically to identify whether
process deviations could lead to undesirable consequences. AIChE states that the technique can be used
for continuous or batch processes and can be adapted to evaluate written procedures. It can be used at
any stage in the life of a process.
HAZOPs usually require a series of meetings in which, using process drawings, the team
systematically evaluates the impact of deviations. The team leader uses a fixed set of guide words and
applies them to process parameters at each point in the process. Guide words include "No," "More,"
"Less," "Part of," "As well as," Reverse," and "Other than." Process parameters considered include flow,
pressure, temperature, level, composition, pH, frequency, and voltage. As the team applies the guide
words to each process step, they record the deviation, with its causes, consequences, safeguards, and
actions needed, or the need for more information to evaluate the deviation.
,..,:';• ' " : ••", \ •"• " ' ' ' • "
HAZOPs require more resources than simpler techniques. AIChE states that a simple process or
a review with a narrow scope may be done by as few as three or four people, if they have the technical
skills and experience. A large or complex process usually requires a team of five to seven people.
AIChE/CCPS estimates that for a small or simple system a HAZOP analysis will take 8 to 12 hours to
prepare, 1 to 3 days to evaluate the process, and 2 to 6 days to document the results. For larger or more
complex processes, a HAZOP will take 2 to 4 days to prepare, 1 to 3 weeks to evaluate, and 2 to 6 weeks
to document.
, s , . • • ,: |
See Chapter 6 for a further discussion of HAZOPs.
: , , , • . . I . i
FAILURE MODE AND EFFECTS ANALYSIS (FMEA)
'" ' : TI.;,, ' ! ' ' i " i
'• 1 >'.' , • " , '" : L. ! ' :
A Failure Mode and Effects Analysis (FMEA) evaluates the ways in which equipment fails and
the system's response to the failure. The focus of the FMEA is on single equipment failures and system
failures. An FMEA usually generates recommendations for increasing equipment reliability. FMEA
does not examine human errors directly, but will consider the impact on equipment of human error.
AIChE states that FMEA is "not efficient for identifying an exhaustive list of combinations of equipment
failures that lead to accidents."
An FMEA produces a qualitative, systematic list of equipment, failure modes, and effects. The
analysis can easily be updated for design or systems changes. The FMEA usually produces a table that,
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Chapter 7
Prevention Program (Program 3)
for each item of equipment, includes a description, a list of failure modes, the effects of each failure,
safeguards that exist, and actions recommended to address the failure. For example, for pump operating
normal, the failure modes would include fails to stop when required, stops when required to run, seal
leaks or ruptures, and pump case leaks or ruptures. The effects would detail both the immediate effect
and the impact on other equipment. Generally, when analyzing impacts, analysts assume that existing
safeguards do not work.
An FMEA requires an equipment list or P&ID, knowledge of the equipment, knowledge of the
system, and responses to equipment failure. AIChE states that on average, an hour is sufficient to
analyze two to four pieces of equipment. AIChE/CCPS estimates that for a small or simple system an
FMEA will take 2 to 6 hours to prepare, 1 to 3 days to evaluate the process, and 1 to 3 days to document
the results. For larger or more complex processes, an FMEA will take 1 to 3 days to prepare, 1 to 3
weeks to evaluate, and 2 to 4 weeks to document.
FAULT TREE ANALYSIS (FTA)
A Fault Tree Analysis (FTA) is a deductive technique that focuses on a particular accident or
main system failure and provides a method for determining causes of the event. The fault tree is a
graphic that displays the combinations of equipment failures and human errors that can result in the
accident. The FTA starts with the accident and identifies the immediate causes. Each immediate cause
is examined to determine its causes until the basic causes of each are identified. AIChE states that the
strength of FTA is its ability to identify combinations of basic equipment and human failures that can
lead to an accident, allowing the analyst to focus preventive measures on significant basic causes.
AIChE states that FTA is well suited for analyses of highly redundant systems. For systems
vulnerable to single failures that can lead to accidents, FMEA or HAZOP are better techniques to use.
FTA is often used when another technique has identified an accident that requires more detailed analysis.
The FTA looks at component failures (malfunctions that require that the component be repaired) and
faults (malfunctions that will remedy themselves once the conditions change). Failures and faults are
divided into three groups: primary failures and faults occur when the equipment is operating hi the
environment for which it was intended; secondary failures and faults occur when the system is operating
outside of intended environment; and command faults and failures are malfunctions where the equipment
performed as designed but the system that commanded it malfunctioned.
An FTA requires a detailed knowledge of how the plant or system works, detailed process
drawings and procedures, and knowledge of component failure modes and effects. AIChE states that
FTAs need well trained and experienced analysts. Although a single analyst can develop a fault tree,
input and review from others is needed
AIChE/CCPS estimates that for a small or simple system an FTA will take 1 to 3 days to prepare,
3 to 6 days for model construction, 2 to 4 days to evaluate the process, and 3 to 5 days to document the
results. For larger or more complex processes, an FTA will take 4 to 6 days to prepare, 2 to 3 weeks for
model constructions, 1 to 4 weeks to evaluate, and 3 to 5 weeks to document.
Other Techniques
The rule allows you to use other techniques if they are functionally equivalent. The AIChE
Guidelines includes descriptions of a number of other techniques including Preliminary Hazard Review,
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7-28
Cause-Consequence Analysis, Event Tree Analysis, and Human Reliability Analysis. You may also
develop a hybrid technique that combines features of several techniques or apply more than one
technique.
Selecting a Technique
Exhibit 7A-1 is adapted from the AIChE Guidelines and indicates which techniques are
appropriate for particular phases in a process's design and operation.
EXHIBIT 7A-1
APPLICABILITY OF PHA TECHNIQUES
R&D
Design
Pilot Plant Operation
Detailed Engineering
Construction/Start-Up
Routine Operation
Modification
Incident Investigation
Decommissioning
Checklist
^
/
/
^
/
/
S
What-If
/
/
/
/
/
/
/
/
/
What-If-
Checklist
S
/
S
/
/
/
S
HAZOP
/
/
^
/
/
,i „' '' ' :" i11
FMEA
/
/
/
/
/
FTA
/
^
/
/
/
Factors in Selecting a Technique
.:'!•:• ! I
Type of process will affect your selection of a technique. AIChE states that most of the
techniques can be used for any process, but some are better suited for certain processes than others.
FMEA efficiently analyzes the hazards associated with computer and electronic systems; HAZOPs do not
work as well with these. Processes or storage units designed to industry or government standards can be
handled with checklists.
'' ! ,j
i
Analysis of multiple failure situations is best handled by FTA. Single-failure techniques, such as
HAZOP and FMEA, are not normally used to handle these although they can be extended to evaluate a
few simple accident situations involving more than one event.
, " ., , . : !
AIChE states that when a process has operated relatively free of accidents for a long time, the
potential for high consequence events is low, and there have been few changes to invalidate the
experience base, the less exhaustive techniques, such as a Checklist, can be used. When the opposite is
true, the more rigorous techniques are more appropriate.
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A final factor in selecting a technique is time required for various techniques. Exhibit 7A-2
summarizes AIChE's estimates of the time required for various steps. The full team is usually involved in
the evaluation step; for some techniques, only the team leader and scribe are involved in the preparation
and documentation steps.
EXHIBIT 7A-2
TIME AND STAFFING FOR PHA TECHNIQUES
Checklist
What-
If
What-If
Checklist
HAZOP
FMEA
FTA
Simple/Small System
# Staff
Preparation
Modeling
Evaluation
Documentation
1-2
2-4 h
4-8 h
4-8 h
2-3
4-8 h
1-3 d
1-2 d
Large/Complex Process
# Staff
Preparation
Modeling
Evaluation
Documentation
1-2
1-3 d
3-5 d
2-4 d
3-5
1-3 d
4-7 d
4-7 d
2-3
6-12 h
6-12 h
4-8 h
3-4
8-12 h
1-3 d
2-6 d
1-2
2-6 h
1-3 d
1-3 d
2-3
1-3 d
3-6 d
2-4 d
3-5 d
3-5
1-3 d
4-7 d
1-3 w
5-7
2-4 d
1-3 w
2-6 w
2-4
1-3 d
1-3 w
2-4 w
2-5
4-6 d
2-3 w
1-4 w
3-5 w
h = hours d = days (8 hours) w = weeks (40 hours)
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7-30
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CHAPTER 8: EMERGENCY RESPONSE PROGRAM
If you have at least one Program 2 or Program 3 process at your facility, then part 68
may require you to implement an emergency response program, consisting of an
emergency response plan, emergency response equipment procedures, employee
training, and procedures to ensure the program is up-to-date. This requirement
applies if your employees will respond to some releases involving regulated
substances. (See the box on the next page for more information on What is
Response?)
EPA recognizes that, in some cases (particularly for small operations with few
employees), it may not be appropriate for employees to conduct response operations
for releases of regulated substances. For example, it would be inappropriate, and
probably unsafe, for a WWTP with only one full-time employee at a site to expect
that a tank fire could be handled without the help of the local fire department or
other emergency responder. EPA does not intend to force such facilities to develop
emergency response capabilities. At the same time, you are responsible for ensuring
effective emergency response to any releases at your facility. If your local public
responders are not capable of providing such response, you must take steps to ensure
that effective response is available (e.g., by hiring response contractors).
8.1 NON-RESPONDING FACILITIES (§ 68.90(b))
EPA has adopted a policy for non-responding facilities similar to that adopted by
OSHA in its Hazardous Waste Operations and Emergency Response (HAZWOPER)
Standard (29 CFR 1910.120), which allows certain facilities to develop an
emergency action plan (29 CFR 1910.38(a)) to ensure employee safety, rather than a
full-fledged emergency response plan. (Note that EPA adopted HAZWOPER by
reference for any state or local facility not subject to OSHA rules (40 CFR part
311).) If your employees will not respond to accidental releases of regulated
substances, then you need not comply with the emergency response plan and
program requirements. Instead, you are simply required to coordinate with local
response agencies to ensure that they will be prepared to respond to an emergency at
your facility. (You may want to briefly review the program design issues discussed
in 8.2 prior to making this decision.) This will help to ensure that your community
has a strategy for responding to and mitigating the threat posed by a release of a
regulated substance from your facility. Coordination with local responders entails the
following steps:
+ Ensure that you have set up a way to notify emergency responders when
there is need for a response.
+ If you have a covered process with a regulated toxic, work with the local
emergency planning entity to ensure that the facility is included in the
community emergency response plan prepared under EPCRA regarding a
response to a potential release.
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+ If you have a covered process with a regulated flammable (e.g., methane),
work with the local fire department regarding a response to a potential
release.
' ' •' •''• '• ;. j' • / '.:
Although you do not need to describe these activities in your risk management plan,
to document your efforts you should keep a record of:
,1
+ The emergency contact (i.e., name or organization and number) that you will
call for a toxic or flammable release, and
What is "Response"?
EPA interprets "response" to be consistent with the definition of response specified under OSHA's
HAZWOPER Standard. OSHA defines emergency response as "a response effort by employees from
outside the immediate release area or by other designated responders ... to an occurrence which
results, or is likely to result, in an uncontrolled release of a hazardous substance." The key factor
here is that responders are designated for such tasks by their employer. This definition excludes
"responses to incidental releases of hazardous substances where the substance can be absorbed,
neutralized, or otherwise controlled at the time of release by employees in the immediate release area,
or by maintenance personnel" as well as "responses to releases of hazardous substances where there
is no potential safety or health hazard (i.e., fire, explosion, or chemical exposure)." Thus, if you
expect your employees to take action to end a small leak (e.g., shutting a valve) or clean up a spill that
does not pose an immediate safety or health hazard, this action could be considered an incidental
response and you would not need to develop an emergency response program if your employees are
limited to such activities.
However, due to the nature of the regulated substances subject to EPA's rule, only the most minor
incidents would be included in this exception. In general, most activities will qualify as a response
due to the immediacy of the dispersion of a toxic plume or spread of a fire, the volatilization of a
spill, and the threat to people on and off site. As a result, if you will have your employees involved in
any substantial way in responding to releases, you will need to develop an emergency response
program. Your emergency response procedures need only apply to "response" actions; other
activities will be described in your maintenance and operating procedures.
+ The organization that you worked with on response procedures.
j . . ,
The remainder of this chapter is applicable only to those WWTPs that will conduct a
more extensive level of response operations. As noted above, you may want to
review the next section before making a decision on whether the facility will take
responsibility for conducting any response activities.
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8.2 ELEMENTS OF AN EMERGENCY RESPONSE PROGRAM (§ 68.95)
If you will respond to releases of regulated substances with your own employees,
your emergency response program must consist of the following elements:
4- An emergency response plan (maintained at the facility) that includes:
> Procedures for informing the public and emergency response
agencies about releases,
> Documentation of proper first aid and emergency medical treatment
necessary to treat human exposures, and
> Procedures and measures for emergency response.
What is a Local Emergency Planning Committee?
Local emergency planning committees (LEPCs) were formed under the Emergency Planning and
Community Right-to-Rnow Act (EPCRA) of 1986. The committees are designed to serve as a
community forum for issues relating to preparedness for emergencies involving releases of
hazardous substances in their jurisdictions. They consist of representatives from local government
(including law enforcement and firefighting), local industry, transportation groups, health and
medical organizations, community groups, and the media. LEPCs:
4- Collect information from facilities on hazardous substances that pose a risk to the
community;
4- Develop a contingency plan for the community based on this information; and
4- Make information on hazardous substances available to the general public.
Contact the mayor's office or the county emergency management office for more information on
your LEPC.
4- Procedures for using, inspecting, testing, and maintaining your emergency
response equipment;
4- Training for all employees in relevant procedures; and
4- Procedures to review and update, as appropriate, the emergency response
plan to reflect changes at the facility and ensure that employees are informed
of changes.
Finally, your plan must be coordinated with the community plan developed under the
Emergency Planning and Community Right-to-Know Act (EPCRA, also known as
SARA Title HI). In addition, at the request of local emergency planning or response
officials, you must provide any information necessary for developing and
implementing the community plan.
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"iilll! I III HIT- II
IP'Ml"i»»B 'I lisa *iTW
niiM" I UK "I I"? JITS I
Chapter 8
Emergency Response Program.
8-4
In keeping with the approach outlined in Chapter 6, EPA is not requiring facilities to
document training and maintenance activities. However, as noted above, facilities
must maintain an on-site emergency response plan as well as emergency response
equipment maintenance and program evaluation procedures.
1 i i i • . • . . . i
Although EPA's required elements are essential to any emergency response program,
they are not comprehensive guidelines for creating an adequate response capability.
Rather than establish another set of federal requirements for an emergency response
program, EPA has limited the provisions of its rule to those the CAA mandates. If
you have a regulated substance on site, you are already subject to at least one
emergency response rule: OSHA's and EPA's HAZWOPER requirements, which
are identical. Under HAZWOPER, any facility that handles "hazardous substances"
(a broad term that includes all of the CAA section 112(r) regulated substances and
thus applies to all facilities with covered processes) must comply with either 29 CFR
1910.38(a) (emergency action plan) or 1910.119(q) (HAZWOPER). If you have a
hazmat team, you are subject to the 29 CFR 1910.119(q) requirements. If you
determine that the emergency response programs you have developed to comply with
these other rules satisfy the elements listed at the beginning of this section, you will
not have to do anything additional to comply with these elements. Additional
guidance on making this decision is provided in section 8.5.
, • :' ', •' •• • i'' • • i
In addition, be careful not to confuse writing a set of emergency response procedures
in a plan with developing an emergency response program. An emergency response
plan is only one element of the integrated effort that makes an emergency response
program. Although the plan outlines the actions and equipment necessary to respond
effectively, training, program evaluation, equipment maintenance, and coordination
with local agencies must occur regularly if your plan is to be useful in an emergency:
The goal of the program is to enable you to respond quickly and effectively to any
emergency; The documents listed in Exhibit 8-1 may be helpful in developing
specific elements of your emergency response program.
:•• •$ • "; : • ' ':''v. .•'•; .'-"• 'H I , •... • • .-H
Finally, remember that under the General Duty Clause of CAA section 112(r)(l) you
are responsible for ensuring that any release from your processes can be handled
effectively. If you plan to rely on local responders for some or all of the response,
you must determine that those responders have both the equipment and training
needed to do so. If they do not, you must take steps to meet any needs, either by
developing your own response capabilities, developing mutual aid agreements with
other facilities, hiring response contractors, or providing support to local responders
so they can acquire equipment or training.
, '. . . • i . . . . •• i
RELATIONSHIP TO HAZWOPER
'' .i ' ' ': " •'.;.",'.',: \ : : ;" i
If you choose to establish and maintain onsite emergency response capabilities, then
you will be subject to the detailed provisions of the OSHA or EPA HAZWOPER
Standard. HAZWOPER covers preparing an. emergency response plan, employee
training, medical monitoring of employees, recordkeeping, and other issues. Call
your state or federal district OSHA office (see Appendix C) for more information on
complying with the HAZWOPER Standard. State and local governments in states
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Chapter 8
8-5 Emergency Response Program
without a delegated OSHA program are subject to HAZWOPER under EPA's 40
CFR part 311.
Exhibit 8-1
Federal Guidance on Emergency Planning and Response
Hazardous Materials Emergency Planning Guide (NRT-1), National Response Team, March 1987.
Although designed to assist communities in planning for hazmat incidents, this guide provides useful
information on developing a response plan, including planning teams, plan review, and ongoing
planning efforts.
Criteria for Review of Hazardous Materials Emergency Plans (NRT-1 A), National Response Team,
May 1988. This guide provides criteria for evaluating response plans.
Integrated Contingency Plan, National Response Team, (61 FR 28642, June 5, 1996). This provides
guidance on how to consolidate multiple plans developed to comply with various federal regulations
into a single, functional emergency response plan..
Emergency Response Guidebook, U.S. Department of Transportation, 2000. This guidebook lists
over 1,000 hazardous materials and provides information on their general hazards and recommended
isolation distances.
Response Information Data Sheets (RIDS), US EPA and National Oceanic and Atmospheric
Administration. Developed for use with the Computer-Aided Management of Emergency Operations
(CAMEO) software, these documents outline the properties, hazards, and basic safety and response
practices for thousands of hazardous chemicals.
How Does the Emergency Response Program Apply?
The requirements for the emergency response program are intended to apply across all covered
processes at a facility. Although certain elements of the program (e.g., how to use specific items of
response equipment) may differ from one process to another, EPA does not intend or expect you to
develop a separate emergency response program for each covered process. With this in mind, you
should realize that your emergency response program will probably apply to your entire facility,
although technically it need only apply to covered processes.
For example, a facility may have two storage tanks, one containing slightly more than a threshold
quantity of a regulated substance and one with slightly less. The facility is likely to adopt the same
response approach (e.g., procedures, equipment, and training) for releases whether or not the process
is "covered." Similarly, a facility may have two adjacent flammables storage tanks, one containing a
regulated substance above the threshold and the other containing another, unlisted flammable. The
facility is likely to adopt the same approach for releases whether or not the process is "covered."
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8-6
8.3 DEVELOPING AN EMERGENCY RESPONSE PROGRAM
The development of an emergency response program should be approached
systematically. As described in section 8.2, all facilities complying with these
emergency response program provisions will already be subject to OSHA
HAZWOPER. As a result, you are likely to fall mto one of two groups:
i, H • i| 'i
4- You have already met several federal requirements for emergency planning
and are interested in developing an integrated program to minimize
duplication (section 8.4).
4- You have a pre-existing emergency response program (perhaps based on an
internal policy decision) and need to determine what additional activities you
will need to conduct (section 8.5).
STEPS FOR GETTING STARTED
, .:;;,: ' . . • : ' I
!, i- , , 'I , ] • , '
The following steps outline a systematic approach that can serve as the framework
for the program development process in each of these cases. Following these initial
steps will allow you to conduct the rest of the process more efficiently.
Form an emergency response program team. The team should consist of
, employees with varying degrees of emergency response responsibilities, as well as
personnel with expertise from each functional area of your facility. You should
consider including persons from the following departments or areas:
4- Maintenance;
4- Operations or line personnel;
4- Upper and line management (for POTWs this may include governing
boards);
4- Legal;
4- Fire and hazmat response;
4- Environmental, health, and safety affairs;
4- Training;
4- Security;
4- EPCRA section 302 emergency coordinator (if one exists);
4- Public relations; and
4- Human resources.
Of course, the membership of the team will need to be more or less extensive
depending on the scope of the emergency response program. A three-member team
may be appropriate for a small facility with a couple of process operators
cross-trained as fire responders, while a facility with its own hazmat team and
environmental affairs department may need a dozen representatives.
Collect relevant facility documents. Members of the development team should
collect and review all of the following:
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Chapter 8
Emergency Response Program
4- Site plans;
4- Existing emergency response plans and procedures;
4- Submissions to the LEPC under EPCRA sections 302 and 303;
4 Hazard evaluation and release modeling information;
4- Hazard communication and emergency response training;
4 Emergency drill and exercise programs;
4- After-action reports and response critiques; and
4 Mutual aid agreements.
Identify existing programs to coordinate efforts. The team should identify any
related programs from the following sources:
4 Corporate- and industry-sponsored safety, training, and planning efforts; and
4 Federal, state, and local government safety, training, and planning efforts
(see Exhibit 8-2).
Exhibit 8-2
Federal Emergency Planning Regulations
The following is a list of some of the federal emergency planning regulations:
4- EPA's Oil Pollution Prevention Regulation (SPCC and Facility Response Plan Requirements)
- 40 CFR part 112.7(6) and 112.20-.21;
4- EPA's Risk Management Programs Regulation - 40 CFR part 68;
4- OSHA's Emergency Action Plan Regulation - 29 CFR 1910.38(a);
4- OSHA's Process Safety Standard - 29 CFR 1910.119;
4- OSHA's HAZWOPER Regulation - 29 CFR 1910.120;
4- OSHA's Fire Brigade Regulation - 29 CFR 1910.156;
4- EPA's Resource Conservation and Recovery Act Contingency Planning Requirements - 40
CFR part 264, Subpart D, 40 CFR part 265, Subpart D, and 40 CFR 279.52.
4- EPA's Emergency Planning and Community Right-to-Know Act Requirements - 40 CFR part
355. (These planning requirements apply to communities, rather than facilities, but will be
relevant when facilities are coordinating with local planning and response entities).
4- EPA's Storm water Regulations - 40 CFR 122.26.
Facilities may also be subject to state and local planning requirements.
Determine the status of each required program element. Using the information
collected, you should assess whether each required program element (see section
8.2) is:
4- In place and sufficient to meet the requirements of part 68;
4 In place, but not sufficient to meet the requirements of Part 68; or
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Emergency Response Program
8-8
+ Not in place.
'• •: • ; , • ;i -.. , ; i • ' :!
This examination will shape the nature of your efforts to complete the emergency
response program required under the risk management program. For example, if you
are already in compliance with OSHA's HAZWOPER Standard, you have probably
satisfied most, if not all, of the requirements for an emergency response program.
Section 8.6 explains the intent of each of EPA's requirements to help you determine
whether you are already in compliance.
Take additional actions as necessary.
» , .I ' ' ,; ' i 'i
TAILORING YOUR PROGRAM TO YOUR HAZARDS
„"" ,„ ' ;. :, :i::, .•„,'. i , ' . ' " :
If your processes and chemicals pose a variety of hazards, it may be necessary to
tailor some elements of your emergency response program to these specific hazards.
Unless each part of your program element is appropriate to the release scenarios that
may occur, your emergency response program cannot be fully effective. Your
program should include core elements that are appropriate to most of the scenarios,
supplemented with more specific response information for individual scenarios.
This distinction should be reflected in your emergency response plan, which should
explain when to access Hie general and specific response information. To do this,
you will need to consider the following four steps:
4 Identify and characterize the hazards for each covered process. Most
WWTPs will have the potential for toxic releases, fires, and explosions.
4 For each program element, compare the activities involved in responding to
each type of accident scenario and decide if they are different enough to
require separate approaches. For example, response equipment and training
will likely be different for releases of toxic versus flammable gases.
i
4 For those program elements that may be chemical- or process-specific,
identify what and how systems and procedures need to be modified. For
example, if existing mitigation systems are inadequate for responding to
certain types of releases, you will need to consider what additional types of
equipment are needed.
4 Consider possible causes of emergencies in developing your emergency
response program. You should consider both the hazards at your facility and
in the surrounding environment. In making this determination, you should
consider your susceptibility to:
Fires, spills, and vapor releases;
Floods, temperature extremes, tornadoes, earthquakes, and
hurricanes;
Loss of utilities, including power failures; and
Train derailments, bomb threats, and other man-made disasters.
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Chapter 8
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8.4 INTEGRATION OF EXISTING PROGRAMS
A number of other federal statutes and regulations require emergency response
planning (see Exhibit 8-2). On June 5,1996, the National Response Team (NRT), a
multi-agency group chaired by EPA, published the Integrated Contingency Plan
Guidance in the Federal Register (61 FR 28642). This guidance is intended to be
used by facilities to prepare emergency response plans for responding to releases of
oil and hazardous substances. The guidance provides a mechanism for consolidating
multiple plans that you prepared to comply with various regulations into a single,
functional emergency response plan or integrated contingency plan (ICP).
The ICP guidance does not change existing regulatory requirements; rather, it
provides a format for organizing and presenting material currently required by
regulations. Individual regulations are often more detailed than the ICP guidance.
To ensure full compliance, you will still need to read and comply with all of the
federal regulations that apply. The guidance contains a series of matrices designed
to assist you in consolidating various plans while documenting compliance with
these federal requirements.
The NRT and the agencies responsible for reviewing and approving plans to which
the ICP option applies have agreed that integrated response plans prepared according
to the guidance will be acceptable and the federally preferred method of response
planning. The NRT anticipates that future development of all federal regulations
addressing emergency response planning will incorporate use of the ICP guidance.
As shown in Exhibit 8-3, the ICP format is organized into three main sections: an
introductory section, a core plan, and a series of supporting annexes. The notice
. published in the Federal Register explains the intended structure of the ICP and
provides detailed annotation. EPA's EPCRA/RCRA/Superfund Hotline can supply
you with a copy and answer general questions about the guidance; for further
information and guidance on complying with specific regulations, you should contact
the appropriate federal agencies.
AN APPROACH TO INTEGRATION
Like many other facilities, you may have opted to develop and maintain separate
documents and procedures for each federal emergency planning requirement.
However, meeting the Clean Air Act emergency response requirements provides you
with the opportunity to integrate several existing programs. Integrating the various
emergency response efforts you conduct (both those mandated by management and
by government) will increase the usefulness of your emergency preparedness
activities and decrease the burden associated with maintaining multiple programs.
Integration will improve your chances to respond effectively to a release by
streamlining your training and eliminating overlaps and conflicts in the roles and
responsibilities of your employees under different programs. However, it is
important to note that, although you are encouraged to integrate your emergency
response efforts, it is not a requirement of the Clean Air Act.
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8-10
If you have multiple emergency response programs, you should consider integrating
them into a single program with procedures for responding to your most likely
release scenarios. The ICP Guidance discussed above provides comparison matrices
for a number of federal programs that will help you accomplish the following:
+ Distinguish the individual regulatory provisions with which you must
comply, and
'• • • • , I • • ' ' !
+ Identify where an integrated effort can meet the requirements of two or more
regulations.
The requirements of various emergency response programs may be similar, but the
subtle differences between requirements will likely determine the degree to which
integration is a feasible and beneficial undertaking. To help you identify the relevant
rules and regulations, the ICP Guidance provides section-by-section regulatory
citations for each emergency response program element for each of the regulatory
programs listed in Exhibit 8-2.
i
8.5 HAVE I MET PART 68 REQUIREMENTS?
i
EPA believes that the creation of multiple response plans to meet slightly different
federal or state standards is counterproductive, diverting resources that could be used
to develop better response capabilities. Therefore, as part of the overall effort to
reduce the imposition of potentially duplicative or redundant federal requirements,
EPA has limited its requirements for the emergency response program to the general
provisions mandated by Congress, as described in Section 8.2.
..... ii
As a result, EPA believes that facilities subject to> other federal emergency planning
requirements may have already met the requirements of these regulations. For
example, plans developed to comply with other EPA contingency planning
requirements and the HAZWOPER rule (29 CFR 1910.120) will likely meet the
requirements for the emergency response plan (and most of the requirements for the
emergency response program). The following discussion presents some general
guidance on what actions you need to take for each of the required elements.
EMERGENCY RESPONSE PLAN
\i ...i " ' ,,''1" " •• ; •'•','... . •• : ' | ..
If you already have a written plan to comply with another planning regulation, you
do not need to write another plan, but only add to it as necessary to cover the
elements listed below.
Keep in mind: At a minimum., your plan must describe:
+ Your procedures for informing the public and offsite emergency response
agencies of a release. This must include the groups and individuals that will
be contacted and why, the means by which they will be contacted, the time
frame for notification, and the information that will be provided.
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Chapter 8
Emergency Response Program.
Exhibit 8-3
Integrated Contingency Plan Outline
Section I - Plan Introduction Elements
1. Purpose and Scope of Plan Coverage
2. Table of Contents
3. Current Revision Date
4. General Facility Identification Information
a.
b.
c.
d.
e.
f.
g-
h.
I.
Facility name
Owner/operator/agent (include physical and mailing address and phone number)
Physical address of the facility (include county/parish/borough, latitude/longitude, and directions)
Mailing address of the facility (correspondence contact)
Other identifying information (e.g., ID numbers, SIC Code, oil storage start-up date)
Key contact(s) for plan development and maintenance
Phone number for key contact(s)
Facility phone number
Facility fax number
Section n - Core Plan Elements
1. Discovery
2. Initial Response
Procedures for internal and external notifications (i.e., contact, organization name, and phone number
of facility emergency response coordinator, facility response team personnel, federal, state, and local
officials)
Establishment of a response management system
Procedures for preliminary assessment of the situation, including an identification of incident type,
hazards involved, magnitude of the problem, and resources threatened
Procedures for establishment of objectives and priorities for response to the specific incident,
including:
(1) Immediate goals/tactical planning (e.g., protection of workers and public as priorities)
(2) Mitigating actions (e.g., discharge/release control, containment, and recovery, as appropriate)
(3) Identification of resources required for response
e. Procedures for implementation of tactical plan
f. Procedure for mobilization of resources
3. Sustained Actions
4. Termination and Follow-Up Actions
Section in - Annexes
a.
d.
Annex 1. Facility and Locality Information
a. Facility maps
b. Facility drawings
Facility description/layout, including identification of facility hazards and vulnerable resources and
populations on and off the facility which may be impacted by an incident
c.
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8-12
Exhibit 8-3 (continued)
Annex 2. Notification
a. Internal notifications
b. Community notifications
c. Federal and state agency notifications
Annex 3. Response Management System
a. General
b. Command
c. Operations
d. Planning
e. Logistics
f. Frnance/procurement/administration
Annex 4. Incident Documentation
a. Post accident investigation
b. Incident history
Annex 5. Training and Exercises/Drills
Annex 6. Response Critique and Plan Review and Modification Process
Annex 7. Prevention
Annex 8. Regulatory Compliance and Cross-Reference Matrices
ii
The proper first aid and emergency medical treatment for employees, first
responders, and members of the public who may have been exposed to a
release of a regulated substance. This must include standard safety
precautions for victims (e.g., apply water to exposed skin immediately) as
well as more detailed information for medical professionals. You must also
indicate who is likely to be responsible for providing the appropriate
treatment: an employee, an employee with specialized training, or a medical
professional.
••' ' ' ' !'
Your procedures for emergency response in the event of a release of a
regulated substance. This must include descriptions of the actions to be
taken by employees and other individuals on-site over the entire course of
the release event:
Activation of alarm systems and interpretation of signals;
Safe evacuation, assembly, and return;
Selection of response strategies and incident command structure;
Use of response equipment and other release mitigation activities;
and
Post-release equipment and personnel cleanup and decontamination.
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Chapter 8
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PLANNING COORDINATION
One of the most important issues in an emergency response program is deciding
which response actions will be assigned to employees and which will be handled by
offsite personnel. As a result, talking to public response organizations will be
critical when you develop your emergency response procedures. Although EPA is
not requiring you to be able to respond to a release alone, you should not simply
assume that local responders will be able to manage an emergency. You must work
with them to determine what they can do, and then expand your own abilities or
establish mutual aid agreements or contracts to handle those situations for which you
lack the appropriate training or equipment.
If you have already coordinated with local response agencies on how to respond to
potential releases of regulated substances and you have ensured an effective
response, you do not need to take any further action.
Keep in mind: Your coordination must involve planning for releases of regulated
substances from all covered processes and must cover:
4- What offsite response assistance you will require for potential release
scenarios, including fire-fighting, security, and notification of the public;
4 How you will request offsite response assistance; and
4 Who will be in charge of the response operation and how will authority be
delegated down the internal and offsite chain of command.
Coordination equivalent to that required for planning for extremely hazardous
substances under EPCRA sections 302-303 will be considered sufficient to meet this
requirement. A more detailed discussion of this element is provided in 8.6.
EMERGENCY EQUIPMENT
If you already have written procedures for using and maintaining your emergency
response equipment, you do not need to write new procedures.
Keep in mind: Your procedures must apply to any emergency equipment relevant to
a response involving a covered process, including all detection and monitoring
equipment, alarms and communications systems, and personal protective equipment
not used as part of normal operations (and thus not subject to the prevention program
requirements related to operating procedures and maintenance). The procedures
must describe:
4 How and when to use the equipment properly;
4- How and when the equipment should receive routine maintenance; and
4 How and when the equipment should be inspected and tested for readiness.
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Chapter 8
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8-14
Written procedures comparable to those necessary for process-related equipment
under the OSHA PSM Standard and EPA's Program 2 and 3 Prevention Programs
will be considered sufficient to meet this requirement.
EMPLOYEE TRAINING
,: ' • , .;„ . . •, , , ... . ;, I .. . i.
If you already train your employees in how to respond to (or evacuate from) releases
of regulated substances, then you do not need a new training program.
i , ;.l!! • •• . ,',"'.. " • . ' - | 'i' I ,T- .' i, •< . '• ' ... j/
' ' '" " ' . . . • :. • i : j'.
Keep in mind: Your training must address the actions to take in response to releases
of regulated substances from all covered processes. The training should be based
directly on the procedures that you have included in your emergency response plan
and must be given to all employees and contractors on site. Individuals should
receive training appropriate to their responsibilities:
." ' : . . " ' .. :' I..: '
+ If they will only need to evacuate, then their training should cover when and
how to evacuate their location.
i
+ If they may need to activate an alarm system in response to a release event,
then their training should cover when and how to use the alarm system.
+ If they will serve on an emergency response team, then their training should
cover how to use emergency equipment and how the incident command
system works.
|
i
Emergency response training conducted in compliance with the HAZWOPER
Standard and 29 CFR 1910.38 will be considered sufficient to meet this requirement.
RESPONSE PLAN EVALUATION
If you akeady have a formal practice for regular review and updates of your plan
based on changes at the facility, you do not need to develop additional procedures.
Keep in mind: You must also identify the types of changes to the facility that would
cause the plan to be updated (e.g., a new covered process) and include a method of
communicating any changes to the plan to your employees (e.g., through training or
safety meetings). You may want to set up a regular schedule on which you review
your entire emergency response plan and identify any special conditions (e.g., a drill
or exercise) that could result in an interim review.
8.6 COORDINATION WITH LOCAL EMERGENCY PLANNING ENTITIES
(§ 68.95(c))
-,i , - , T " :„ , ' , , I .
Once you determine that you have at least one covered process, you should open
communications with local emergency planning and response officials, including
your local emergency planning committee if one exists. Because your LEPC consists
of representatives from many local emergency planning and response agencies, it is
likely to be the best source of information on the critical emergency response issues
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Chapter 8
Emergency Response Program
in your community. However, in some cases, there may not be an active LEPC in
your community. If so, or if your state has not designated your community as an
emergency planning district under EPCRA, you will likely need to contact local
agencies individually to determine which entities (e.g., fire department, emergency
management agency, police department, civil defense office, public health agency)
have jurisdiction for your facility.
KEY COORDINATION ISSUES
If you have any of the toxic regulated substances above the threshold quantity, you
must have already designated an emergency coordinator to work with the LEPC on
chemical emergency preparedness issues (a requirement for certain facilities
regulated under EPCRA). If you have not (e.g., if your facility has only regulated
flammable substances), you may want to do so at this time. The emergency
coordinator should be the individual most familiar with your emergency response
program (e.g., the person designated as having overall responsibility for this program
in your management system — see Chapter 5).
Involvement in the activities of your LEPC can have a dramatically positive effect on
your emergency response program, as well as on your relationship with the
surrounding community. Your LEPC can provide technical assistance and guidance
on a number of topics, such as conducting response training and exercises,
developing mutual aid agreements, and evaluating public alert systems. The
coordination process will help both the community and the facility prepare for an
emergency, reducing expenditures of time and money, as well as helping eliminate
redundant efforts.
You should consider providing the LEPC with draft versions of any emergency
response program elements related to local emergency planning efforts. This
submission can initiate a dialogue with the community on potential program
improvements and lead to coordinated training and exercise efforts. In return, your
LEPC can support your emergency response program by providing information from
its own emergency planning efforts, including:
+ Data on wind direction and weather conditions, or access to local
meteorological data, to help you make decisions related to the evacuation of
employees and public alert notification;
+ Lists of emergency response training programs available in the area for
training police, medical, and fire department personnel, to help you identify
what training is already available;
+ Schedules of emergency exercises designed to test the community response
plan to spur coordinated community-facility exercises;
Lists of emergency response resources available from both public and
private sources to help you determine whether and how a mutual aid
agreement could support your program; and
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8-16
+ Details on incident command structure, emergency points of contact,
availability of emergency medical services, and public alert and notification
systems.
.. " '-, : ''I H . i i j ' ' ' '" i 'i iiiiiiii
Upon completion of your emergency response plan, you should coordinate with the
LEPC, local response organizations, local hospitals, and other response organizations
(e.g., state hazmat team) and offer them a copy of the plan. In some instances, only a
portion of the plan may be of use to individuals or organizations; in such cases, you
should consider making only that portion of the plan available. For instance, it may
be appropriate to send a hospital only the sections of your plan that address
emergency medical procedures and decontamination.
You may also want to provide your LEPC and local response entities with a
description of your emergency response program elements, as well as any important
subsequent amendments or updates, to ensure that the community is aware of the
scope of your facility response efforts prior to an emergency. Although the summary
of your emergency response program will be publicly available as part of your RMP,
this information may not be as up-to-date or as comprehensive. Remember, the
LEPC has been given the authority under EPCRA and Clean Air Act regulations to
request any information necessary for preparing the community response plan.
Planning for Flammable Substances
In the case of regulated flammable substances, the fire department with jurisdiction over your facility
may already be conducting fire prevention inspections and pre-planning activities under its own
authority. Your participation hi these efforts (as requested) will allow local responders to gather the
information they need and prepare for an emergency. If there is no local fire department, or if there
is only a volunteer fire department in your area, you may need to contact other local response or
planning officials (e.g., police) to determine how you can work with the community.
October 26,1998
i,in:,1l, a __.. P_,i!|iii iiKlfiilillHilikl"..!!!!'.! 111,!,' 'I
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CHAPTER 9: RISK MANAGEMENT PLAN (PART 68, SUBPART G)
You must submit one risk management plan (RMP) to EPA for all of your covered
processes (§ 68.150). EPA is developing an electronic submission program for your
use. If you cannot submit electronically, you may request a hardship waiver and
submit your RMP on paper. In either case, your RMP is due no later than the latest
of the following dates:
4- June 21,1999;
4- The date on which a regulated substance is first present above a threshold
quantity in a process; or
4- Three years after the date on which a regulated substance is first listed by
EPA.
EPA's automated tool for submitting RMPs, RMP*Submit™, discussed below, is
available free from the EPCRA hotline (on disk) or can be downloaded from
www.epa.gov/ceppo/.
9.1 ELEMENTS OF THE RMP
The length and content of your RMP will vary depending on the number and
program level of the covered processes at your facility. See Chapter 2 for detailed
guidance on how to determine the program levels of each of the covered processes at
your facility.
Any facility with one or more covered processes must include in its RMP:
4 An executive summary (§ 68.155);
4 The registration for the facility (§ 68.160);
4- The certification statement (§ 68.185);
4- A worst-case scenario for each Program 1 process; at least one worst-case
scenario to cover all Program 2 and 3 processes involving regulated toxic
substances; at least one worst-case scenario to cover all Program 2 and 3
processes involving regulated flammables (§ 68.165(a));
4 The five-year accident history for each process (§ 68.168); and
4 A summary of the emergency response program for the facility (§ 68.180).
Any facility with at least one covered process in Program 2 or 3 must also include in
its RMP:
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Ill II" ,1'HSSIillli'liJi'ili""1 'SUM'
,' T'l:1'!!'!!1 I'Wf ' IP!'"!!11
Chapter 9
Risk Management Plan
9-2
+ At least one alternative release scenario for each regulated toxic substance in
Program 2 or 3 processes and at least one alternative release scenario to
cover all regulated flammables in Program 2 or 3 processes (§ 68.165(b));
+ A summary of the prevention program for each Program 2 process (§
68.170); and
,, j.,
+ A summary of the prevention program for each Program 3 process (§ 68.
175). " ' ' " ! !'"
i
Subpart G of part 68 (see Appendix A) provides more detail on the data required for
each of the elements. The actual RMP form, however, contains more detailed
guidance to makesit possible to limit the number of text entries. For example, the
rule requires you to report on the major hazards identified during a PHA or hazard
review and on public receptors affected by worst-case and alternative case scenarios.
The RMP provides a list of options for you to check for these elements. Except for
Hie executive summary, the RMP consists primarily of yes/no answers, numerical
information (e.g., dates, quantities, distances), and a few text answers (e.g., names,
addresses, chemical identity). Where possible, RMP*Submit™ provides "pick lists"
to help you complete the form. For example, RMP*Submit™ provides a list of
regulated substances and automatically fills in the CAS numbers when you select a
substance.
i
EPA provides instructions for each of the data elements to be reported in the RMP
with RMP*Submit™. The instructions explain each data element and help you
understand what acceptable data are for each. The instructions are available with the
software and are posted on EPA's web site.
j
9.2 RMP SUBMISSION
i!
i
RMPs must be sent to:
The RMP Reporting Center
P.O. Box 3346
Merrifield, VA 22116-3346
ELECTRONIC SUBMISSION
ii
EPA has made RMP*Submit'rM available to complete and file your RMP.
RMP*Submit™ does the following:
' . ' ', :.. I ' '
+ Provides a user-friendly, PC-based RMP Submission System available on
diskettes and via the internet;
i ' " ' " , •, j „, ' . i J
+ Uses a standards-based, open systems architecture so private companies can
, create compatible software; and
+ Performs data quality checks, accept limited graphics, and provide on-line
help including defining data elements and providing instructions.
i! i
April 19,2000
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Chapter 9
Risk Management Plan
The software runs on Windows 3.1 and above. There will not be a DOS or MAC
version.
HARD COPY SUBMISSION
If you are unable to submit electronically for any reason, just fill out the Electronic
Waiver form available in the RMP* Submit™ manual and send it in with your RMP.
See the RMP*Submit manual for more information on the Electronic Waiver. The
forms are also available from http://www.epa.gov/swercepp/nnpsubmt.htmKsteps
and from the EPCRA hotline (see Appendix C). If you submit on paper, you must
use the official form. If you do not use the official form, your RMP can not be
processed.
IMPORTANT REMINDERS
Do not forget your certification letter. A certification letter is required for all RMP
submissions. See Chapter 3, Section F of the RMP*Submit User's Manual for more
information on the certification letter
Protect your diskette against damage. Mail you diskette in a cardboard diskette
mailer or put some padding around it
Make sure your Executive Summary is in ASCII DOS Text format and that it is
actually on the diskette submitted. If the-Executive Summary is more than 32 KB,
you need to save it as a text file and identify the name of the text file in
RMP*Submit™. If you use a word processing program to develop the summary, you
must save it as ASCII text.
9.3 RESUBMISSION AND UPDATES (§ 68.190)
When you are required to update and resubmit your RMP is based on whether and
what changes occur at your facility. Please refer to the Exhibit 9-1 and note that you
are required to update and resubmit your RMP on the earliest of the dates that apply
to your facility:
WHEN DOES THE OFFSITE CONSEQUENCE ANALYSIS (OCA) NEED TO BE REVISED?
You'll need to revise your OCA when a change at your facility results in the distance
to an endpoint from a worst-case release rising or falling by at least a factor of two.
For example, if you increase your inventory substantially or install passive
mitigation to limit the potential release rate, you should re-estimate the distance at an
endpoint. If the distance is at least doubled or halved, you must revise the RMP. For
most substances, the quantity that would be released would have to increase by more
than a factor of five to double the distance to an endpoint.
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How Do I DE-REGISTER?
If your facility is no longer covered by this rule, you must submit a letter to the RMP
Record Center within six months indicating that your stationary source is no longer
covered.
EXHIBIT 9-1
RMP UPDATES
Change That Occurs at Your Facility
No changes occur
A newly regulated substance is first listed by
EPA
A regulated substance is first present above its
threshold quantity in:
— A process already covered; or
— A new process.
A change occurs that results in a revised PHA or
hazard review
A change occurs that requires a revised offsite
consequence analysis
A change occurs that alters the Program level that
previously applied to any covered process
A change occurs that makes the facility no longer
subject to the requirements to submit a Risk
Management Plan
Date by Which You Must Update aad Submit
your RMP
Within 5 years of initial submission
Within 3 years of the date EPA listed the newly
regulated substance
On or before the date the quantity of the regulated
substance exceeds the threshold in the process.
Within 6 months of the change
Within 6 months of the change
Within 6 months of the change
Submit a revised registration (indicating that the
RMP is no longer required) to EPA within 6
months of the change
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Q&A
"REVISING" A PHA
Q. The rule states that I have to update my RMP whenever I revise a PHA. What constitutes a
revised PHA? Every time I go through management of change procedures I make a notation in the
PHA file for the process, but would that constitute a revised PHA if the change did not affect the
validity of the PHA?
A. All changes (except replacement in kind) are subject to the management of change of procedures.
When processes undergo minor changes (e.g., minor rerouting of a piping run), information is
typically added to a PHA file to reflect the change, even though the validity of the PHA is not
affected by the modification. These minor changes and the addition of information about the change
to the PHA file are not considered a 'revision' of the PHA under the part 68. Major changes that
invalidate' a PHA, leading you to 'update' or 'revalidate' the PHA so that it accurately reflects the
hazards of the process, are considered a revision of the PHA under part 68.
Qs&As
RMP UPDATES
Q. If a facility changes owners, but the manufacturing operations have not changed, are they required
to update their RMP?
A. Yes. If the owner of a facility changes, the RMP on record with EPA should reflect the current
owner by the date ownership changes or responsibility for operation of the facility is transferred.
You do not have to update each section of your RMP if the only thing that has changed is the name
of the owner. If the original RMP was submitted electronically, you must revise the original RMP as
needed and submit the revised RMP on diskette. Since EPA will not alter your submission for you,
sending EPA a letter about the change is not sufficient. Be sure to check the corrections box when
RMP*SUBMIT prompts you for submission type. If the original submission was on paper, make the
changes in red ink on the printout of your RMP submission that the RMP Reporting Center mailed
back to you to retain for your records. Whether you submitted on paper or diskette, you also must
submit a new certification letter reflecting the new facility owner name.
Q. If a facility changes owners and significant changes have been made to plant operations is the
facility required to update all sections of the RMP and resubmit it to EPA?
A. Yes. If the facility has new ownership and plant operations have changed significantly, the new
facility owner/operator needs to send EPA a new diskette with all sections of the RMP updated. You
will receive a recalculated anniversary date based on this new submission. Be sure to check Re-
submission when RMP*SUBMIT prompts you for submission type.
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9-6
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CHAPTER 10: IMPLEMENTATION
10.1 IMPLEMENTING AGENCY
The implementing agency is the federal, state, or local agency that is taking the lead
for implementation and enforcement of part 68. The implementing agency will
review RMPs, select some RMPs for audits, and conduct on-site inspections. The
implementing agency should be your primary contact for information and assistance.
WHO Is MY IMPLEMENTING AGENCY?
Under the CAA, EPA will serve as the implementing agency until a state or local
agency seeks and is granted delegation under CAA section 112(1) and 40 CFR part
63, subpart E. You should check with the EPA Regional Office to determine if your
state has been granted delegation or is in the process of seeking delegation. The
Regional Office will be able to provide contact names at the state or local level. See
http://www.epa.gOV/swercepp/pubs/112r-sts/l 12r-sts.html for addresses and contact
information for EPA Regions and state implementing agencies.
IF THE PROGRAM Is DELEGATED, WHAT DOES THAT MEAN?
To gain delegation, a state or local agency must demonstrate that it has the authority
and resources to implement and enforce part 68 for all covered processes in the state
or local area. Some states may, however, elect to seek delegation to implement and
enforce the rule for only sources covered by an operating permit program under Title
V of the CAA. When EPA determines that a state or local agency has the required
authority and resources, EPA may delegate the program. If the state's rules differ
from part 68 (a state's rules are allowed to differ in certain specified respects, as
discussed below), EPA will adopt, through rulemaking, the state program as a
substitute for part 68 in the state, making the state program federally enforceable. In
most cases, the state will take the lead in implementation and enforcement, but EPA
maintains the ability to enforce part 68 hi states in which EPA has delegated part 68.
Should EPA decide that it is necessary to take an enforcement action in the state, the
action would be based on the state rule that EPA has adopted as a substitute for part
68. Similarly, citizen actions under the CAA would be based on the state rules that
EPA has adopted.
Under 40 CFR 63.90, EPA will not delegate the authority to add or delete substances
from § 68.130. EPA has proposed, in revisions to part 63, that the authority to revise
Subpart G (relating to RMPs) will not be delegated. Even if your state or local
authority is the implementing agency, you must file your RMP with EPA (see
Chapter 9). You should check with your state to determine whether you need to file
additional data for state use or submit amended copies of the RMP with the state to
cover state elements or substances.
If your state has been granted delegation, it is important that you contact them to
determine if the state has requirements in addition to those in part 68. State rules
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10-2
may be more stringent than part 68. This document does not cover state
requirements.
Qs&As
DELEGATION
Q. In what ways may state rules be more stringent? Does this document provide guidance on state
differences?
A. States may impose more detailed requirements, such as requiring more documentation or more
frequent reporting, specifying hours of training or maintenance schedules, imposing equipment
requirements or call for additional analyses. Some states are likely to cover at least some additional
chemicals and may use lower thresholds. This document does not cover state differences.
Q. Will the general duty clause be delegated?
A. The general duty clause (CAA section 112(r)(l)) is not included in part 68 and, therefore, will not
be delegated. States, however, may adopt their own general duty clause under state law.
10.2 REVIEWS/AUDITS/INSPECTIONS (§ 68.220)
The implementing agency is required under part 68 to review and conduct audits of
RMPs. Reviews are relatively quick checks of the RMPs to determine whether they
are complete and whether they contain any information that is clearly problematic.
For example, if an RMP for a process containing flammables fails to list fire and
explosion as a hazard in the prevention program, the implementing agency may flag
that as a problem. The RMP date system will perform some of the reviews
automatically by flagging RMPs submitted without necessary data elements
completed.
Facilities may be selected for audits based on any of the following criteria, set out in
§ 68.220:
+ Accident history of the facility
+ Accident history of other facilities in the same industry
+ Quantity of regulated substances handled at the site
+ Location of the facility and its proximity to public and environmental
receptors
+ The presence of specific regulated substances
+ The hazards identified in the RMP
+ A plan providing for random, neutral oversight
WHAT ARE AUDITS AND How MANY WILL BE CONDUCTED?
Under the CAA and part 68, audits are conducted on the RMP. Audits will generally
be reviews of the RMP to review its adequacy and require revisions when necessary
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Implementation
to ensure compliance with part 68. Audits will help identify whether the underlying
risk management program is being implemented properly. The implementing agency
will look for any inconsistencies in the dates reported for compliance with
prevention program elements. For example, if you report that the date of your last
revision of operating procedures was in June 1998 but your training program was last
reviewed or revised in December 1994, the implementing agency will ask why the
training program was not reviewed to reflect new operating procedures.
The agency will also look at other items that may indicate problems with
implementation. For example, if you fail to list an appropriate set of process hazards
for the process chemicals, the agency may seek further explanations as to why you
reported in the way you did. The implementing agency may compare your data with
that of other facilities in the same industrial sector using the same chemicals to
identify differences that may indicate compliance problems.
If audits indicate potential problems, they may lead to requests for more information
or to on-site inspections. If the implementing agency determines that problems exist,
it will issue a preliminary determination listing the necessary revisions to the RMP,
an explanation of the reasons for the revisions, and a timetable. Section 68.220
provides details of the administrative procedures for responding to a preliminary
determination.
The number of audits conducted will vary from state to state and from year to year.
Neither the CAA nor part 68 sets a number or percentage of facilities that must be
audited during a year. Implementing agencies will set their own goals, based on their
resources and particular concerns.
WHAT ARE INSPECTIONS?
Inspections are site visits to check on the accuracy of the RMP data and on the
implementation of all part 68 elements. During inspections, the implementing
agency will probably review the documentation for rule elements, such as the PHA
reports, operating procedures, maintenance schedules, process safety information,
and training. Unlike audits, which focus on the RMP but may lead to determinations
concerning needed improvements to the risk management program, inspections will
focus on the underlying risk management program itself.
Implementing agencies will determine how many inspections they need to conduct.
Audits may lead to inspections or inspections may be done separately. Depending on
the focus of the inspection (all covered processes, a single process, or particular part
of the risk management program) and the size of the facility, inspections may take
several hours to several weeks.
10.3 RELATIONSHIP WITH TITLE V PERMIT PROGRAMS
Part 68 is an applicable requirement under Hie CAA Title V permit program and
must be listed in a Title V air permit. You do not need a Title V air permit solely
because you are subject to part 68. If you are required to apply for a Title V permit
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10-4
because you are subject to requirements under some other part of the CAA, you
must:
+ List part 68 as an applicable requirement in your permit
in , , ,, i i . ii , „ ,,, i
+ Include conditions that require you to either submit a compliance schedule
for meeting the requirements of part 68 by the applicable deadlines or
include compliance with part 68 as part of your certification statement.
" , • ' ' '•',,'" • ,' : 1 ." . .' ,i I'! II1 I I " , . ,. ' ' ' ,1
I' i'1]!1 , ' : ' ' „,,'" , : I ! If , ' !, i. '" ' , :!•,!'
You must also provide the permitting agency with any other relevant information it
requests. WWTPs may require air permits; check with the environmental
compliance officer for your facility.
The RMP and supporting documentation are not part of the permit and should not be
submitted to the permitting authority. The permitting authority is only required to
ensure that you have submitted the RMP and that it is complete. The permitting
authority may delegate this review of the RMP to other agencies.
„•.' • ; •!-:.' . • .. , ;.., : •...,'. ... ,, ;„ , , ,i jl, i-, ... - , i
If you have a Title V permit and it does not address the part 68 requirement, you
should contact your permitting authority and determine whether your permit needs to
be amended to reflect part 68.
10.4 PENALTIES FOR NON-COMPLIANCE
Penalties for violating the requirements or prohibitions of part 68 are set forth in
CAA section 113. This section provides for both civil and criminal penalties. EPA
may assess civil penalties of not more than $27,500 per day per violation. Anyone
convicted of knowingly violating part 68 may also be punished by a fine pursuant to
Title 18 of the U.S. Code or by imprisonment for no more than five years, or both;
anyone convicted of knowingly filing false information may be punished by a fine
pursuant to Title 18 or by imprisonment for no more than two years.
October 26,1998
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Chapter 10
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Qs&As
AUDITS
Q. If we are a Voluntary Protection Program (VPP) facility under OSHA's VPP program, are we
exempt from audits?
A. You are exempt from audits based on accident history of your industry sector or on random,
neutral oversight. An implementing agency that is basing its auditing strategy on other factors may
include your facility although EPA expects that VPP facilities will generally not be a high priority for
audits unless they have a serious accident. .
Q. If we have been audited by a qualified third party, for ISO 14001 certification or for other
programs, are we exempt from audits?
A. No, but you may want to inform your implementing agency that you have gained such
certification and indicate whether the third party reviewed part 68 compliance as part of its audit
The implementing agency has the discretion to determine whether you should be audited.
Q. Will we be audited if a member of the public requests an audit of our facility?
A. The implementing agency will have to decide whether to respond to such public requests. EPA's
intention is that part 68 implementation reflect that hazards are primarily a local concern.
October 26, 1998
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10-6
October 26,1998
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CHAPTER 11: COMMUNICATION WITH THE PUBLIC
Once you have prepared and submitted your RMP, EPA will make it available to the
public. Public availability of the RMP is a requirement under section 114(c) of the
Clean Air Act (the Act provides for protection of trade secrets, and EPA will
accordingly protect any portion of the RMP that contains Confidential Business
Information). Therefore, you can expect that your community will discuss the
hazards and risks associated with your facility as indicated in your RMP. You will
necessarily be part of such discussions. The public and the press are likely to ask you
questions because only you can provide specific answers about your facility and your
accident prevention program. This dialogue is a most important step in preventing
chemical accidents and should be encouraged. You should respond to these
questions honestly and candidly. Refusing to answer, reacting defensively, or
attacking the regulation as unnecessary are likely to make people suspicious and
willing to assume the worst. A basic fact of risk communication is that trust, once
lost, is very hard to regain. As a result, you should prepare as early as possible to
begin talking about these issues with the community, Local Emergency Planning
Committees (LEPCs), State Emergency Response Commissions (SERCs), other local
and state officials, and other interested parties.
Communication with the public can be an opportunity to develop your relationship
with the community and build a level of trust among you, your neighbors, and the
community at large. By complying with the RMP rule, you are taking a number of
steps to prevent accidents and protect the community. These steps are the individual
elements of your risk management program. A well-designed and properly
implemented risk management program will set the stage for informative and
productive dialogue between you and your community. The purpose of this chapter
is to suggest how this dialogue may occur. In addition, note that some industries
have developed guidance and other materials to assist in this process; contact your
trade association for more information.
11.1 BASIC RULES OF RISK COMMUNICATION
Risk communication means establishing and maintaining a dialogue with the public
about the hazards at your operation and discussing the steps that have been or can be
taken to reduce the risk posed by these hazards. Of particular concern under this rule
are the hazards related to the chemicals you use and what would happen if you had
an accidental release.
Many companies, government agencies, and other entities have confronted the same
issue you may face: how to discuss with the public the risks the community is
subject to. Exhibit 11-1 outlines seven "rules" of risk communication that have been
developed based on many experiences of dealing with the public about risks.
A key message of these "rules" is the importance and legitimacy of public concerns.
People generally are less tolerant of risks they cannot control than those they can.
For example, most people are willing to accept the risks of driving because they have
some control over what happens to them. However, they are generally more
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11
Communication with the Public
11-2
uncomfortable accepting the risks of living near a facility that handles hazardous
chemicals if they feel that they have no control over whether the facility has an
accident. The Clean Air Act's provision for public availability of RMPs gives public
an opportunity to take part in reducing the risk of chemical accidents that might
occur in their community.
Exhibit 11-1: Seven Cardinal Rules of Risk Communication
1. Accept and involve the public as a legitimate partner
2. Plan carefully and evaluate your efforts
3. Listen to the public's specific concerns
4. Be honest, frank, and open
5. Coordinate and collaborate with other credible sources
6. Meet the needs of the media
7. Speak clearly and with compassion
HAZARDS VERSUS RISKS
H1':?
Dialogue in the community will be concerned with both hazards and risks; it is
useful to be clear about the difference between them.
'„,,', i ' „.'" . N;IIU,,J "- I :!il I i , , " ' M Ih 1 'nillljl1
Hazards are inherent properties that cannot be changed. Chlorine is toxic when
inhaled or ingested; propane is flammable. There is little that you can do with these
chemicals to change their toxicity or flammability. If you are in an earthquake zone
or an area affected by hurricanes., earthquakes and hurricanes are hazards. When you
conduct your hazard review or process hazards analysis, you will be identifying your
hazards and determining whether the potential exposure to the hazard can be reduced
in any way (e.g., by limiting the quantity of chlorine stored on-site).
" 'I'. '! ;,,''" "i'PI'i1 ' li'iv:,,v>: '. i 1 I i I 'l' :»> ' 'V '"^ " . I Jill'
Risk is usually evaluated based on several variables, including the likelihood of a
release occurring, the inherent hazards of the chemicals combined with the quantity
released, and the potential impact of the release on the public and the environment.
For example, if a release during loading occurs frequently, but the quantity of
chemical released is typically small and does not generally migrate off site, the
overall risk to the public is low. If the likelihood of a catastrophic release occurring
is extremely low, but the number of people who could be affected if it occurred is
large, the overall risk may still be low because of the low probability that a release
will occur. On the other hand, if a release occurs relatively frequently and a large
number of people could be affected, the overall risk to the public is high.
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Communication with the Public
The rule does not require you to assess risk in a quantitative way because, in most
cases, the data you would need to estimate risk levels (e.g., one in 100 years) are not
available. Even in cases where data such as equipment failure rates are available,
there are large uncertainties in using that data to determine a numerical risk level for
your facility, because your facility is probably not the same as other facilities, and
your situation may be dynamic. Therefore, you may want to assign qualitative
values (high, medium, low) to the risks that you have identified at your facility, but
you should be prepared to explain the terms if you do. For example, if you believe
that the worst-case release is very unlikely to occur, you must give good reasons;
you must be able to provide specific examples of measures that you have taken to
prevent such a release, such as installation of new equipment, careful training of
your workers, rigorous preventive maintenance, etc. You should also be able to
show documentation to support your claim.
WHO WILL ASK QUESTIONS?
Your Local Emergency Planning Committee (LEPC) and other facilities can help
you identify individuals in the following groups who may be reviewing RMP data
and asking questions. Interested parties may include:
(1) Persons living near the facility and elsewhere in the community or working
at a neighboring facility
(2) Local officials from zoning and planning boards, fire and police
departments, health and building code officials, elected officials, and various
county and state officials
(3) Your employees
(4) Special interest groups including environmental organizations, chambers of
commerce, unions, and various civic organizations
(5) Journalists, reporters, and other media representatives
(6) Medical professionals, educators, consultants, neighboring companies and
others with special expertise or interests
In general, people will be concerned about accident risks at your facility, how you
manage the risks, and potential impacts of an accident on health, safely, property,
natural resources, community infrastructure, community image, property values, and
other matters. Those individuals in the public and private sector who are responsible
for dealing with these impacts and the associated risks also will have an interest in
working with you to address these risks.
WHAT INFORMATION ABOUT YOUR FACILITY is AVAILABLE TO THE PUBLIC?
Even though the non-confidential information you provide in your RMP is available
to the public, it is likely that people will want additional information. Interested
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Communication with the Public
11-4
parties will know that you retain additional information at your facility (e.g.,
documentation of the results of the offsite consequence analysis reported in your
RMP) and are required to make it available to EPA or its implementing agency
during inspections or compliance audits. Therefore, they may request such
information. EPA encourages you to provide public access to this information. If
EPA or its implementing agency were to request this information, it would be
available to the public under section 114(c) of the CAA.
The public may also be interested in other information relevant to risk management
at your facility, such as:
•f Submissions under sections 3Q2, 304, 311-312, and 313 of the Emergency
Planning and Community Ri^ht to Know Act (JEPCRA) reporting on
chemical storage and releases, as well as the community emergency response
plan prepared under EPCRA section 303.
+ Other reports on hazardous materials made, used, generated, stored, spilled,
released and transported, that you submitted to federal, state, and local
agencies.
" I
+ Reports on workplace safety and accidents developed under the
Occupational Safety and Health Act that you provide to employees, who may
choose to make the information publicly available, such as medical and
exposure records, chemical data sheets, and training materials.
+ Any other information you have provided to public agencies that can be
accessed by members of the public under the federal Freedom of Information
Act and similar state laws (and that may have been made widely available
over the Internet).
'i ,'•',' i j • ::
+ Any published materials on facility safety (either industry- or site-specific),
such as agency reports on facility accidents, safety engineering manuals and
textbooks, and professional journal articles on facility risk management.
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11.2 SAMPLE QUESTIONS FOR COMMUNICATING WITH THE PUBLIC
Smaller businesses may not have the resources or time to develop the types of
outreach programs, described later in this chapter, that many larger chemical
companies have used to handle public questions and community relations. For many
small businesses, communication with the public will usually occur when you are
asked.questions about information in your Rlvff. It is important that you respond to
these questions constructively. Go beyond just answering questions; discuss what
you have done to prevent accidents and work with the community to reduce risks.
The people in your community will be looking to you to provide answers.
To help you establish a productive dialogue with the community, the rest of this
section presents questions you are likely to be asked and a framework for answering
them. These are elements of the public dialogue that you may anticipate. The person
July 1998
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from your facility designated as responsible for cornmunicating with the public
should review the following and talk to other community organizations to determine
which questions are most likely to be raised and identify other foreseeable issues.
Remember that others in the community, notably LEPCs and other emergency
management organizations are also likely to be asked these and other similar
questions. You should considerthe unique features of your facility, your RMP, and
your historical relationship with the community (e.g., prior accidents, breakdowns in
the coordination of emergency response efforts, and management-labor disputes),
and work together with these other organizations to answer these questions for your
situation and to resolve the issues associated with them.
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11-6
What does your worst-case release distance mean?
The distance is intended to provide an estimate of the maximum, possible area that might be affected
under catastrophic conditions. It is intended to ensure that no potential risks to public health are
overlooked, but the distance to an endpoint estimated under worst-case conditions should not be
considered a "public danger zone."
In most cases, the mathematical models used to analyze the worst-case release scenario as defined in
the rule may overestimate the area that would be impacted by a release. In other cases, the models
may underestimate the area. For distances greater than approximately six miles, the results of toxic
gas dispersion models are especially uncertain, and you should be prepared to discuss such
possibilities in an open, honest manner.
Reasons that modeling may underestimate the distance generally relate to the inability of some
models to account for site-specific factors that might tend to increase the actual endpoint distance.
For example, assume a facility is located in a river valley and handles dense toxic gases such as
chlorine. If a release were to occur, the river valley could channel the toxic cloud much farther than
it might travel if it were to disperse hi a location with generally flat terrain. In such cases, the actual
endpoint distance might be longer than that predicted using generic lookup tables.
Reasons that the area may be overestimated include:
• For toxics, the weather conditions (very low wind speed, calm conditions) assumed for a
worst-case release scenario are uncommon and probably would not last as long as the time
the release would take to travel the distance estimated. If weather conditions are different,
the distance would be much shorter.
• For flammables, although explosions can occur, a release of a flammable is more likely to
disperse harmlessly or burn. If an explosion does occur, however, this area could be
affected by the blast; debris from the blast could affect an even broader area.
• In general, some models cannot take into account other site-specific factors that might tend
to disperse the chemicals more quickly and limit the distance.
Note: When estimating worst case release distances, the rule does not allow facilities to take into
account active mitigation systems and practices that could limit the scope of a release. Specific
systems (e.g., monitoring, detection, control, pressure relief, alarms, mitigation) may limit a release
or prevent the failure from occurring. Also, if you are required to analyze alternative release
scenarios (i.e., if your facility is in Program 2 or Program 3), these scenarios are generally more
realistic than the worst case, and you can offer to provide additional information on those scenarios.
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What does it mean that we could be exposed if we live/work/shop/go to school
X miles away?
(For an accident involving a flammable substance):
The distance means that people who are in that area around the facility could be hurt if the contents
of a tank or other vessel exploded. The blast of the explosion could shatter windows and damage
buildings. Injuries would be the result of the force of the explosion and of flying glass or falling
debris.
(For an accident involving a toxic substance):
The distance is based on a concentration of the chemical that you could be exposed to for an hour
without suffering irreversible health effects or other symptoms that would make it difficult for you to
escape. If you are within that distance, you could be exposed to a greater concentration of the
chemical. If you were exposed to higher levels for an extended period of time (10 minutes, 30
minutes, or longer), you could be seriously hurt. However, that does not mean that you would be.
Remember, for worst case scenarios, the rule requires you to make certain conservative assumptions
with respect to, for example, wind speed and atmospheric stability. If the wind speed is higher than
that used in the modeling, or if the atmosphere is more unstable, a chemical release would be
dispersed more quickly, and the distances would be much smaller and the exposure times would be
shorter. If the question pertains to an alternative release scenario, you probably assumed typical
weather conditions in the modeling. Therefore, the actual impact distance could be shorter or longer,
and you should be prepared to acknowledge this and clearly explain how you chose the conditions
for your release scenario.
In general, the possibility of harm depends on the concentration of the chemical you are exposed to
and the length of time you are exposed.
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11-8
IF THERE IS AN ACCIDENT, WILL EVERYONE WITHIN THA T DISTANCE BE HURT? WHA T
ABOUT PROPERTY DAMAGE?
In general, no. For an explosion, everyone within the circle would certainly feel the blast wave since
it would move in all directions at once. However, while some people within the circle could be hurt,
it is unlikely that everyone would be since some people would probably be in less vulnerable
locations. Most injuries would probably be due to the effects of flying glass, falling debris, or
impact with nearby objects.
Two types of chemicals may be modeled - toxics and flammables. Releases of flammables do not
usually lead to explosions; released flammables are more likely to disperse without igniting. If the
released flammable does ignite, a fire is more likely than an explosion, and fires are usually
concentrated at the facility.
For toxic chemicals, whether someone is hurt by a release depends on many factors. First, the
released chemicals would usually move in the direction of the wind (except for some dense gases,
which may be constrained by terrain features to flow in a different direction). Generally, only
people downwind from the facility would be at risk of exposure if a release occurred, and this is
normally only a part of the population inside the circle. If the wind speed is moderate, the
chemicals would disperse quickly, and people would be exposed to lower levels of the chemical. If
the release is stopped quickly, they might be exposed for a very short period time, which is less
likely to cause injury. However, if the wind speed is low or the release continues for a long time,
exposure levels will be higher and more dangerous. The population at risk would be a larger
proportion of the total population inside the circle. You should be prepared to discuss both
possibilities.
Generally, it is the people who are closest to the facility — within a half mile or less — who would
face the greatest danger if an accident occurred.
Damage to property and the environment will depend on the type of chemical released. In an
explosion, environmental impacts and property damage may extend beyond the distance at which
injuries could occur. For a vapor release, environmental effects and property damage may occur as a
result of the reactivity or corrosivity of the chemical or toxic contamination.
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How SURE ARE You OF YOUR DISTANCES?
Perhaps the largest single difficulty associated with hazard assessment is that different models and
modeling assumptions will yield somewhat different results. There is no one model or set of
assumptions that will yield "certain" results. Models represent scientists' best efforts to account for
all the variables involved in an accidental release. While all models are generally based on the same
physical principles, dispersion modeling is not an exact science due to the limited opportunity for
real-world validation of results. No model is perfect, and every model represents a somewhat
different analytical approach. As a result, for a given scenario, people can use different consequence
models and obtain predictions of the distance to the toxic endpoint that in some situations might vary
by a factor often. Even using the same model, different input assumptions can cause wide variations
in the predictions. It follows that, when you present a single predicted value as your best estimate of
the predicted distance, others will be able to claim that the answer ought to be different, perhaps
greater, perhaps smaller, depending on the assumptions used in modeling and the choice of model
itself.
You therefore need to recognize that your predicted distance lies within a considerable band of
uncertainty, and to communicate this fact to those who have an interest in your results. A
neighboring facility handling the same covered substances as you do may have come up with a
different result for the same scenario for these reasons.
If you use EPA's RMP Offsite Consequence Analysis Guidance or one of the industry-specific
guidance documents that EPA has developed, you will be able to address the issue of uncertainty by
stating that the results you have generated are conservative (that is they are likely to overestimate
distances). However, if you use other models, you will have to provide your own assessment of
where your specific prediction lies within the plausible range of uncertainties.
WHY DO YOU NEED TO STORE SO MUCH ON-SITE?
If you have not previously considered the feasibility of reducing the quantity, you should do so when
you develop your risk management program. Many companies have cited public safety concerns as
a reason for reducing the quantities of hazardous chemicals stored on-site or for switching to non-
hazardous substitutes. If you have evaluated your process and determined that you need a certain
volume to maintain your operations, you should explain this fact to the public in a forthright manner.
As appropriate, you should also discuss any alternatives, such as reducing storage quantities and
scheduling more frequent deliveries. Perhaps these options are feasible - if so, you should consider
implementing them; if not, explain why you consider these alternatives to be unacceptable. For
example, in some situations, more frequent deliveries would mean more trucks carrying the
substance through the community on a regular basis and a greater opportunity for smaller-scale
releases because of more frequent loading and unloading.
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11-10
WHAT ARE YOU DOING TO PREVENT RELEASES?
If you have rigorously implemented your risk management program, this question will be your
chance, if you have not already done so, to tell the community about your prevention activities, the
safe design features of your operations, the specific activities that you are performing such as
training., operating procedures, maintenance, etc., and any industry codes or standards you use to
operate safely. If you have installed new equipment or safety systems, upgraded training, or had
outside experts review your site for safety (e.g., insurance inspectors), you could offer to share the
results. You may also want to mention state or federal rules you comply with.
WHAT ARE You DOING To PREPARE FOR RELEASES?
For such questions, you will need to talk about any coordination that you have done with the local
fire department, LEPC, or mutual aid groups. Such coordination may include activities such as
defining an incident command structure, developing notification protocols, conducting response
training and exercises, developing mutual aid agreements, and evaluating public alert systems. This
description is particularly important if your employees are not designated or trained to respond to
releases of regulated substances.
If your employees will be involved in a response, you should describe your emergency response plan
and the emergency response resources available at the facility (e.g., equipment, personnel), as well
as through response contractors, if appropriate. You also may want to indicate the types of events
for which such resources are applicable. Finally, indicate your schedule for internal emergency
response training and drills and exercises and discuss the results of the latest relevant drill or
exercise, including problems found and actions taken to address them.
DO YOU NEED TO USE THIS CHEMICAL?
Again, if you have not yet considered the feasibility of switching to a non-hazardous substitute, you
should do so when you develop your risk management program. Assuming that there is no
substitute, you should describe why the chemical is critical to what you produce and explain what
you do to handle it safely. If there are substitutes available, you should describe how you have
evaluated such options.
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WHY ARE YOUR DISTANCES DIFFERENT FROM THE DISTANCES IN THE EPA LOOKUP TABLES?
If you did your own modeling, this question may come up. You should be ready to explain in a
general way how your model works and why it produces different results. EPA allows using other
models (as long as certain parameters and conditions specified by the rule are met) because it
realizes that EPA lookup table results will not necessarily reflect all site-specific conditions.
In addition, although all models are generally based on the same physical principles, dispersion
modeling is not an exact science due to the limited opportunity for real-world validation of the
results. Thus, the method by which different models combine the basic factors such as wind speed
and atmospheric stability can result in distances that readily vary by a factor of two (e.g., five miles
versus ten miles). The introduction of site-specific factors can produce additional differences.
EPA recognizes that different models will produce differing predictions of the distance to an
endpoint, especially for releases of toxic substances. The Agency has provided a discussion of the
uncertainties associated with the model it has adopted for the OCA Guidance. You need to
understand that the distances produced by another model lie within a band of uncertainty and be able
to demonstrate and communicate this fact to those who are reviewing your results.
HOW LIKELY ARE THE WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS?
It is generally not possible to provide accurate numerical estimates of how likely these scenarios are.
EPA has stated that providing such numbers for accident scenarios rarely is feasible because the data
needed (e.g., on rates for equipment failure and human error) are not usually available. Even when
data are available, there are large uncertainties in applying the data because each facility's situation
is unique.
In general, the risk of the worst-case scenario is low. Although catastrophic vessel failures have
occurred, they are rare events. Combining them with worst-case weather conditions makes the
overall scenario even less likely. This does not mean that such events cannot or will not happen,
however.
For the alternative scenario, the likelihood of the release is greater and will depend, in part, on the
scenario you chose. If you selected a scenario based on your accident history or industry accident
history, you should explain this to the public. You should also discuss any steps you are taking to
prevent such an accident from recurring.
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11-12
IS THE WORST-CASE RELEASE YOU REPORTED REALLY THE WORST ACCIDENT YOU CAN HAVE?
The answer to this question will depend on the type of facility you have and how you handle
chemicals. EPA defined a specific scenario (failure of the single largest vessel) to provide a
common basis of comparison among facilities nationwide. So, if you have only one vessel, EPA's
worst case is likely to be the worst event you could have.
On the other hand, if you have a process which involves multiple co-located or interconnected
vessels, it is possible that you could have an accident more severe than EPA's worst case scenario.
If credible scenarios exist that could be more serious (in terms of quantities released or
consequences) than the EPA worst case scenario, you should be ready to discuss them. For example,
if you store chemicals in small containers such as 55-gallon drums, the EPA-defined worst-case
release scenario may involve a limited quantity, but a fire or explosion at the facility could release
larger quantities if multiple containers are involved. In this case, you should be ready to frankly
discuss such a scenario with the public. If you take precautions to prevent such scenarios from
occurring, you should explain these precautions also. If an accidental release is more likely to
involve multiple drums than a single drum as a result, for example, of the drums being stored closely
together, then you must select such a scenario as your alternative release scenario so that information
on this scenario is available in your RMP.
Chemical manufacturers may want to talk about releases that could result from runaway reactions
that could continue for several hours. This type of event could result in longer exposure times.
WHAT ABOUT THE ACCIDENT AT THE [NAME OF SIMILAR FACILITY] THAT HAPPENED LAST MONTH?
This question highlights an important point: you need to be aware of events in your industry (e.g.,
accidents, new safety measures) for two reasons. First, your performance likely will be compared to
that of your competitors. Second, learning about the circumstances and causes of accidents at other
faculties like yours can help you prevent such accidents from occurring at your facility.
You should be familiar with accidents that happen at facilities similar to yours, and you should have
evaluated whether your facility is at risk for similar accidents. You should take the appropriate
measures to prevent the accident from occurring and be prepared to describe these actions. If your
faculty has experienced a similar release in the past, this information may be documented in your
accident history or other publicly available records, depending on the date and nature of the incident,
the quantity released, and other factors. If you have already taken steps specifically designed to
address this type of accident, whether as a result of this accident, a prior accident at your facility, or
other internal decision-making, you should describe these efforts. If, based on your evaluation, you
determine that the accident could not occur at your facility, you should discuss the pertinent
differences between the two facilities and explain why you believe those differences should prevent
the accident from occurring at your facility.
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WHAT ACTIONS HAVE YOU TAKEN TO INVOLVE THE COMMUNITY IN YOUR ACCIDENT PREVENTION
AND EMERGENCY PLANNING EFFORTS?
If you have not actively involved the community in accident prevention and emergency planning in
the past, you should acknowledge this as an area where you could improve and start doing so as you
develop your risk management program. Fkst, you may want to begin participating in the LEPC and
regional mutual aid organizations if you aren't doing so already. Other opportunities for community
involvement are fire safety coordination activities with the local fire department, joint training and
exercises with local public and private sector response personnel, the establishment of green fields
between the facility and the community, and similar efforts.
When discussing accident prevention and emergency planning with the community, you should
indicate any national programs in which you participate, such as the Chemical Manufacturers
Association's Responsible Care program or Community Awareness and Emergency Response
program or OSHA's Voluntary Protection Program. If fully implemented, these programs can help
improve the safety of the facility and the community. You may have future plans to participate in
areas described previously or have new initiatives associated with the risk management program. Be
sure you ask what else the community would like you to do and explain how you will do it.
CAN WE SEE THE DOCUMENTATION YOU KEEP ON SITE?
If the requested information is not confidential business information, EPA encourages you to make it
available to the public. Although you are not required to provide this information to the public,
refusing to provide it simply because you are not compelled to is not the best approach. If you
decide not to provide any or most of this material, you should have good reasons for not doing so
and be prepared to explain these reasons to the public. Simply taking a defensive position or
referring to the extent of your legal obligations is likely to threaten the effectiveness of your
interaction with the community. Offer as much information as possible to the public; if particular
documents would reveal proprietary information, try to provide a redacted copy, summary, or some
other form that answers the community's concerns. You may want to work with your LEPC on this
issue. You should also be aware that information that EPA or the implementing agency obtains as
part of an inspection or investigation conducted under section 114 of the Clean Air Act would be
available to the public under section 114(c) of the Act to the extent it does not reveal confidential
business information.
11.3 COMMUNICATION ACTIVITIES AND TECHNIQUES
Although this section is most applicable to larger companies, small businesses may
want to review it and use some of the ideas to expand their communications with the
public. To prepare for effective communication with the community, you should:
(1) Adopt an organizational policy that includes basic risk communication
principles (see exhibit 11-1).
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11-14
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(2) Assign responsibilities and resources to implement the policy.
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Communicatipns staff will need work time and resources to prepare presentation
materials, hold meetings with interested persons in the community, and do other
work necessary to respond to questions and concerns and maintain ongoing dialogue.
A training program in communication skills and incentives for good performance
also may be advisable.
Organizations have a legitimate interest in preventing disclosure of confidential
business information or statements that inadvertently and unfairly harm the
July 1998
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organization or its employees. Thus, you should assure that your risk communication
staff is instructed on how to deal with situations that pose these problems. This may
mean that you have an internal procedure enabling your staff to bring such situations
to top management and legal counsel for quick resolution, keeping in mind that
unduly defensive or legalistic responses that result in restricting the amount of
information that is provided can damage or destroy the risk communication process.
Your communication staff may find the following steps helpful in addressing the
priority issues in the communication process:
Prior to RMP Submittal
+ Enlist employee support for, and involvement in, the communication
process.
+ Build on work you have done with your LEPC, fire department, and local
officials, and gain their insights.
+ Incorporate technical expertise, management commitment, and employee
involvement in the risk communication process.
+ Use your RMP's executive summary to begin the dialogue with the
comrnunity; be sure you have taken all of the steps you present.
•4- Taking a community perspective, identify which data elements need to be
clarified, interpreted, or amplified, and which are most likely to raise
community concerns; then compile the information needed to respond and
determine the most understandable methods (e.g., use of graphics) for
presenting the information.
At Submittal
+ Review the RMP to assure that you are familiar with its data elements and
how they were developed. In particular, review the hazard assessment,
prevention, and response program features, as well as documentation of the
methods, data, and assumptions used, especially if an outside consultant
performed the analyses and developed these materials. You have certified
their accuracy and your spokesperson should know them intimately, as they
reflect your plan.
+ Review your performance in implementing the prevention and response
programs and prepare to discuss problems identified and actions taken.
4- Review your performance in investigating accidents and prepare to discuss
any corrective actions that followed.
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11-16
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while it is advisable for you to review such experience to identify "best
communication practices," you should carefully evaluate such practices to determine
if they can be adapted to fit your unique circumstances. For example, if your facility
is in the middle of an urban area, you probably will use different approaches than
you would use if it were located in an industrial area far from any residential
populations. These practices are complementary approaches to delivering your risk
management message and responding to the concerns of the community.
With these cautions in mind, a number of "best" practices are outlined below for
consideration. First, you will want to establish formal channels for
information-sharing and communication with stakeholders. The most basic
approaches include the following:
+ Convene public meetings for discussion and dialogue regarding your risk
management program and RMP and take steps to have the facility owner or
manager and all sectors of the community participate, including minorities
and low-income residents.
+ Arrange meetings with local media representatives to facilitate their
understanding of your risk management program and the program summary
presented in your RMP.
+ Establish a repository of information on safety matters for the LEPC and the
public and, if electronic, provide software for public use. Some
organizations also have provided computer terminals for public use in the
community library or fire department.
Other, more resource-intensive activities of this type to consider include the
following:
+ Create and convene focus groups (small working groups) to facilitate
dialogue and action on specific concerns, including technical matters, and
take steps to assure that membership in each group reflects a cross section of
the community and includes technically trained persons (e.g., engineers,
medical professionals).
+ Hold seminars on hypothetical release scenarios, prevention and response
programs, applicable standards and industry practices, analytic methods and
models (e.g., on dispersion of airborne releases, health effects of airborne
concentrations), and other matters of special concern or complexity.
+ Convene special meetings to foster dialogue and collaborations with the
LEPC and the fire department and to establish a mutual assistance network
with other facility managers in the community or region.
+ Establish hot lines for telephone and e-mail communications between
interested parties and your designated risk communication staff and, if
feasible, a web site for posting useful information.
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11-18
In all of these efforts, remember to use plain language and commonly understood
terms; avoid the use of acronyms and technical and legal jargon. In addition,
depending on your audience, keep in mind that the preparation of multilingual
materials may be useful or even necessary.
Secondly, you may want to initiate or expand programs that more directly involve
the community in your operations and safety programs. Traditional approaches
include the following:
Arrange facility tours so that members of the public can view operations and
discuss safety procedures with supervisors and employees.
Schedule drills and simulations of incidents to demonstrate how prevention
and response programs work, with participation by community responders
and other organizations (e.g., neighboring companies).
Conduct a "Safety Street" - a community forum generally sponsored by
several industries in a locality, where your representatives present facility
safety information, explain risks, and respond to public questions (see
Section 11.4 for a reference to more information on this program).
4- Periodically reaffirm and demonstrate your commitment to safety in
accordance with and beyond regulatory requirements and present data on
your safety performance, using appropriate benchmarks or measures, in
newsletters and by posting the information at your web site.
4- Publicly honor and reward managers and employees who have performed
safety responsibilities in superior fashion and citizens who have made
important contributions to the dialogue on safety.
If community interest is significant, you may also want to consider the following
activities:
4- Invite public participation in monitoring implementation of your risk
management program elements.
jj
4- Invite public participation in auditing your performance in safety
responsibilities, such as chemical handling and tracking procedures and
analysis and follow-up on accidents and near misses.
Organize a committee comprised of representatives from the facility, other
industry, emergency planning and response organizations, and community
groups and chaired by a community leader to independently evaluate your
safety and communication efforts (e.g., a Community Advisory Panel). You
may also want to finance the committee to pay for an independent
engineering consultant to assist with technical issues and learn what can be
done to improve safety, and thereby share control with the community.
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Your communication staff should review these examples, consider designing their
own activities as well as joint efforts with other local organizations, and ultimately
decide with the community on which set of practices are feasible and can best create
a healthy risk communication process in your community. Once these decisions are
made, you may want to integrate the chosen set of practices in an overall
communication program for your facility, transform some into standard procedures,
and monitor and evaluate them for continuous improvement.
OTHER COMMUNICATION OPPORTUNITIES
By complying with the RMP rule and participating in the communications process
with the community, you should have developed a comprehensive system for
preventing, mitigating, and responding to chemical accidents at your facility. Why
not share this knowledge with your staff, others you do business with (e.g.,
customers, distributors, contractors), and, perhaps through industry groups, others in
your industry? If you transfer this knowledge to others, you can help improve their
chemical safety management capabilities, enhance public safety beyond your
community, and possibly gain economic benefits for your organization.
11.4 FOR MORE INFORMATION
Among the numerous publications on risk communication, the following may be
particularly helpful:
4- Improving Risk Communication, National Academy Press, Washington,
D.C., 1989
4- "Safety Street" and other materials on the Kanawha Valley Demonstration
Program, Chemical Manufacturers Association, Arlington, VA
4- Community Awareness and Emergency Response Code of Management
Practices and various Guidance, Chemical Manufacturers Association,
Arlington, VA
4- Communicating Risks to the Public, R. Kasperson and P. Stallen, eds.,
Kluwer Publishing Co., 1991
4- "Challenges in Risk and Safety Communication with the Public," S. Maher,
Risk Management Professionals, Mission Viejo, CA, April 1996
4- Primer on Health Risk Communication Principles and Practices, Agency for
Toxic Substances and Disease Registry, on the World Wide Web at
atsdrl.atsdr.cdc.gov:8080
4- Risk Communication about Chemicals in Your Community: A Manual for
Local Officials, US Environmental Protection Agency, EPA
EPCRA/Superfund/RCRA/CAA Hotline
July 1998
-------
Chapter 11
Communication with the Public
11-20
Risk Communication about Chemicals in Your Community: Facilitator's
Manual and Guide, US Environmental Protection Agency, EPA
EPCRA/Superfimd/RCRA/CAA Hotline
Chemicals, the Press, and the Public: A Journalist's Guide to Reporting on
Chemicals in the Community, US Environmental Protection Agency, EPA
EPCRA/Superfund/RCRA/CAA Hotline
» ' ' . 1 "31!
July 1998
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Appendix A
40 CFR part 68
-------
-------
Pt. 67, App. A
40 CFR Ch. I (7-1-99 Edition)
local agent, any noncompliance pen-
alties owed by the source owner or op-
erator shall be paid to the State or
local agent.
APPENDIX A TO PART 67—TECHNICAL
SUPPORT DOCUMENT
NOTE: EPA will make copies of appendix A
available from: Director, Stationary Source
Compliance Division, EN-341, 401 M Street,
SW., Washington, DC 20460.
[54 FR 25259, June 20, 1989]
APPENDIX B TO PART 67—INSTRUCTION
MANUAL
NOTE: EPA will make copies of appendix B
available from: Director, Stationary Source
Compliance Division, EN-341, 401 M Street,
SW., Washington, DC 20460.
[54 FR 25259, June 20, 1989]
APPENDIX C TO PART 67—COMPUTER
PROGRAM
NOTE: EPA will make copies of appendix C
available from: Director, Stationary Source
Compliance Division, EN-341, 401 M Street,
SW., Washington, DC 20460.
[54 FR 25259, June 20, 1989]
PART 68—CHEMICAL ACCIDENT
PREVENTION PROVISIONS
Subpart A—General
Sec.
68.1 Scope.
68.2 Stayed provisions.
68.3 Definitions.
68.10 Applicability.
68.12 General requirements.
68.15 Management.
Subpart B—Hazard Assessment
68.20 Applicability.
68.22 Offsite consequence analysis param-
eters.
68.25 Worst-case release scenario analysis.
68.28 Alternative release scenario analysis.
68.30 Defining offsite impacts—population.
68.33 Defining offsite impacts—environ-
ment.
68.36 Review and update.
68.39 Documentation.
68.42 Five-year accident history.
Subpart C—Program 2 Prevention Program
68.48 Safety information.
68.50 Hazard review.
68.52 Operating procedures.
68.54 Training.
68.56 Maintenance.
68.58 Compliance audits.
68.60 Incident investigation.
Subpart D—Program 3 Prevention Program
68.65 Process safety information.
68.67 Process hazard analysis.
68.69 Operating procedures.
68.71 Training.
68.73 Mechanical integrity.
68.75 Management of change.
68.77 Pre-startup review.
68.79 Compliance audits.
68.81 Incident investigation.
68.83 Employee participation.
68.85 Hot work permit.
68.87 Contractors.
Subpart E—Emergency Response
68.90 Applicability.
68.95 Emergency response program.
Subpart F—Regulated Substances for
Accidental Release Prevention
68.100 Purpose.
68.115 Threshold determination.
68.120 Petition process.
68.125 Exemptions.
68.130 List of substances.
Subpart G—Risk Management Plan
150 Submission.
151 Assertion of claims of confidential
business information.
152 Substantiating claims of confidential
business information.
155 Executive summary.
160 Registration.
165 Offsite consequence analysis.
168 Five-year accident history.
170 Prevention program/Program 2.
175 Prevention program/Program 3.
180 Emergency response program.
185 Certification.
190 Updates.
Subpart H—Other Requirements
68.200 Recordkeeping.
68.210 Availability of information to the
public.
68.215 Permit content and air permitting
authority or designated agency require-
ments.
68.220 Audits.
APPENDIX A TO PART 68—TABLE OF Toxic
ENDPOINTS
AUTHORITY: 42 U.S.C. 7412(r), 7601 (a) (1),
7661-7661f.
SOURCE: 59 FR 4493, Jan. 31, 1994, unless
otherwise noted.
36
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Environmental Protection Agency
§68.2
Subpart A—General
§68.1 Scope.
This part sets forth the list of regu-
lated substances and thresholds, the
petition process for adding or deleting
substances to the list of regulated sub-
stances, the requirements for owners or
operators of stationary sources con-
cerning the prevention of accidental
releases, and the:jv State accidental re;
'""""lease" prevention"" programs "approved
-:;:"pider section, 112(r). The list of sub-
stances, threshold quantities, and acci-
dent; prevention regulations promul-
~"jga£ed under this part do not limit in
Shy way the general duty provisions
under section 112(r)(l).
§68.2 Stayed'provisions.
(a) Notwithstanding any other provi-
sionof this part, the effectiveness of
the following provisions is stayed from
March 2, 1994 to December 22, 1997.
(1) In Sec. 68.3, the definition of "sta-
tionary source," to the extent that
such definition includes naturally oc-
curring hydrocarbon reservoirs or
transportation subject to oversight or
regulation under a state natural gas or
hazardous liquid program for which the
state has in effect a certification to
DOT under 49 U.S.C. 60105;
(2) Section 68.115(b)(2) of this part, to
the extent that such provision requires
an owner or operator to treat as a regu-
lated flammable substance:
(i) Gasoline, when in distribution or
related storage for use as fuel for inter-
nal combustion engines;
(ii) Naturally occurring hydrocarbon
mixtures prior to entry into a petro-
leum refining process unit or a natural
gas processing plant. Naturally occur-
ring hydrocarbon mixtures include any
of the following: condensate, crude oil,
field gas, and produced water, each as
defined in paragraph (b) of this section;
(iii) Other mixtures that contain a
regulated flammable substance and
:ltha£ do not have a National Fire,,,,Pro-
tection Association flammability haz-
ard rating of 4, the definition of which
is in the NFPA 704, Standard System
for the Identification of the Fire Haz-
, ards of Materials, National Fire Pro-
tection Association, Quincy, MA, 1990,
i available from the National Fire Pro-
tection Association, 1 Batterymarch
Park, Quincy, MA 02269-9101; and
(3) Section 68.130(a).
(b) From March 2, 1994 to December
22, 1997, the following definitions shall
apply to the stayed provisions de-
scribed in paragraph (a) of this section:
Condensate means hydrocarbon liquid
separated from natural gas that con-
denses because of changes in tempera-
ture, pressure, or both, and remains
liquid at standard conditions.
Crude oil means any naturally occur-
ring, unrefined petroleum liquid.
Field gas means gas extracted from a
production well before the gas enters a
natural gas processing plant.
Natural gas processing plant means
any processing site engaged in the ex-
traction of natural gas liquids from
field gas, fractionation of natural gas
liquids to natural gas products, or
both. A separator, dehydration unit,
heater treater, sweetening unit, com-
pressor, or similar equipment shall not
be considered a "processing site" un-
less such equipment is physically lo-
cated within a natural gas processing
plant (gas plant) site.
Petroleum refining process unit means
a process unit used in an establishment
primarily engaged in petroleum refin-
ing as defined in the Standard Indus-
trial Classification code for petroleum
refining (2911) and used for the fol-
lowing: Producing transportation fuels
(such as gasoline, diesel fuels, and jet
fuels), heating fuels (such as kerosene,
fuel gas distillate, and fuel oils), or lu-
bricants; separating petroleum; or sep-
arating, cracking, reacting, or reform-
ing intermediate petroleum streams.
Examples of such units include, but are
not limited to, petroleum based solvent
units, alkylation units, catalytic
hydrotreating, catalytic hydrorefining,
catalytic hydrocracking, catalytic re-
forming, catalytic cracking, crude dis-
tillation, lube oil processing, hydrogen
production, isomerization, polymeriza-
tion, thermal processes, and blending,
sweetening, and treating processes. Pe-
troleum refining process units include
sulfur plants.
Produced water means water ex-
tracted from the earth from an oil or
natural gas production well, or that is
separated from oil or natural gas after
extraction.
37
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§68.3
40 CFR Ch. I (7-1-99 Edition)
(c) Notwithstanding any other provi-
sion of this part, the effectiveness of
part 68 is stayed from June 21, 1999 to
December 21, 1999 with respect to regu-
lated flammable hydrocarbon sub-
stances when the substance is intended
for use as a fuel and does not exceed
67,000 pounds in a process that is not
manufacturing the fuel, does not con-
tain greater than a threshold quantity
of another regulated substance, and is
not collocated or interconnected to an-
other covered process.
[59 FR 4493, Jan. 31, 1994, as amended at 61
FR 31731, June 20, 1996; 64 FR 29170, May 28,
1999]
§68.3 Definitions.
For the purposes of this part:
Accidental release means an unantici-
pated emission of a regulated sub-
stance or other extremely hazardous
substance into the ambient air from a
stationary source.
Act means the Clean Air Act as
amended (42 U.S.C. 7401 etseq.)
Administrative controls mean written
procedural mechanisms used for hazard
control.
Administrator means the adminis-
trator of the U.S. Environmental Pro-
tection Agency.
AIChB/CCPS means the American In-
stitute of Chemical Engineers/Center
for Chemical Process Safety.
API means the American Petroleum
Institute.
Article means a manufactured item,
as defined under 29 CFR 1910.1200(b),
that is formed to a specific shape or de-
sign during manufacture, that has end
use functions dependent in whole or in
part upon the shape or design during
end use, and that does not release or
otherwise result in exposure to a regu-
lated substance under normal condi-
tions of processing and use.
ASME means the American Society
of Mechanical Engineers.
CAS means the Chemical Abstracts
Service.
Catastrophic release means a major
uncontrolled emission, fire, or explo-
sion, involving one or more regulated
substances that presents imminent and
substantial endangerment to public
health and the environment.
Classified information means "classi-
fied information" as defined in the
Classified Information Procedures Act,
18 U.S.C. App. 3, section l(a) as "any
information or material that has been
determined by the United States Gov-
ernment pursuant to an executive
order, statute, or regulation, to require
protection against unauthorized disclo-
sure for reasons of national security."
Condensate means hydrocarbon liquid
separated from natural gas that con-
denses due to changes in temperature,
pressure, or both, and remains liquid at
standard conditions.
Covered process means a process that
has a regulated substance present in
more than a threshold quantity as de-
termined under §68.115.
Crude oil means any naturally occur-
ring, unrefined petroleum liquid.
Designated agency means the state,
local, or Federal agency designated by
the state under the provisions of
§ 68.215 (d) .
DOT means the United States De-
partment of Transportation.
Environmental receptor means natural
areas such as national or state parks,
forests, or monuments; officially des-
ignated wildlife sanctuaries, preserves,
refuges, or areas; and Federal wilder-
ness areas, that could be exposed at
any time to toxic concentrations, radi-
ant heat, or overpressure greater than
or equal to the endpoints provided in
§68.22(a) , as a result of an accidental
release and that can be identified on
local U. S. Geological Survey maps.
Field gas means gas extracted from a
production well before the gas enters a
natural gas processing plant.
Hot work means work involving elec-
tric or gas welding, cutting, brazing, or
similar flame or spark-producing oper-
ations.
Implementing agency means the state
or local agency that obtains delegation
for an accidental release prevention
program under subpart E, 40 CFR part
63. The implementing agency may, but
is not required to, be the state or local
air permitting agency. If no state or
local agency is granted delegation,
EPA will be the implementing agency
for that state.
Injury means any effect on a human
that results either from direct expo-
sure to toxic concentrations; radiant
heat; or overpressures from accidental
38
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I?;! J
Environmental Protection Agency
Mllli El l. • • ' . '.' • ,'- ' ' V I,';"''...
releases or from the direct con-
sequences of a vapor cloud explosion
(such as flying glass, debris, and other
projectiles) from an accidental release
and that requires medical treatment or
, F 'hospltalization.
^""tifijfor change means introduction of a
^^"fleW'prdcess"; process equipment, or reg-
!|"|ilated substance, ^E^ alteration of proc-
l|l'li';"essli'll|l|ii'chemistry 'that results in any
It'jiiiarige to safe operating limits, or
other alteration that introduces a new
hazard.
Mechanical integrity means the proc-
essof ensuring that process equipment
is fabricated from the proper materials
of construction and is properly in-
stalled, maintained, and replaced to
prevent failures and accidental re-
, leases, ,,., , , ,„ _
Medical treatment means treatment,
other than first aid, administered by a
physician or registered professional
personnel under standing orders from a
;.] ''physician.
Mitigation or mitigation system means
specific activities, technologies, or
equipment designed or deployed to cap-
tureor control substances upon loss of
containment to minimize exposure of
the public or the environment. Passive
mitigation means equipment, devices,
or technologies that function without
human, mechanical, or other energy
Input. Active mitigation means equip-
ment, devices, or technologies that
need human, mechanical, or other en-
ergy input to function.
N^fCS means North American Indus-
jry Classification System.
AQF!RA means the National Fire Pro-
tection Association.
Natural gas processing plant (gas plant)
Means any processing site engaged in
•Hie""extraction of natural gas liquids
from field gas, fractionation of mixed
natural gas liquids to natural gas prod-
ucts; or both, classified as North Amer-
^ican Industrial Classification System
(NAICSJ code" 211112 (previously Stand-
ard Industrial Classification (SIC) code
1321).
Offsite means areas beyond the prop-
erty boundary of the stationary source,
and areas within the property bound-
ary to which the public has routine and
Unrestricted access during or outside
business hours.
§68.3
i '! • : ••.. : I H ;.', ,.".'l ,1 -.\ " • > < : ;;,
OSHA means the U.S. Occupational
Safety and Health Administration.
Owner or operator means any person
who owns, leases, operates, controls, or
supervises a stationary source.
Petroleum refining process unit means
a process unit used in an establishment
primarily engaged in petroleum refin-
ing as defined in NAICS code 32411 for
petroleum refining (formerly SIC code
2911) and used for the following: Pro-
ducing transportation fuels (such as
gasoline, diesel fuels, and jet fuels),
heating fuels (such as kerosene, fuel
gas distillate, and fuel oils), or lubri-
cants; Separating petroleum; or Sepa-
rating, cracking, reacting, or reform-
ing intermediate petroleum streams.
Examples of such units include, but are
not limited to, petroleum based solvent
units, alkylation units, catalytic
hydrotreating, catalytic hydrorefining,
catalytic hydrocracking, catalytic re-
forming, catalytic cracking, crude dis-
tillation, lube oil processing, hydrogen
production, isomerization, polymeriza-
tion, thermal processes, and blending,
sweetening, and treating processes. Pe-
troleum refining process units include
sulfur plants.
Population means the public.
Process means any activity involving
a regulated substance including any
use, storage, manufacturing, handling,
or on-site movement of such sub-
stances, or combination of these activi-
ties. For the purposes of this defini-
tion, any group of vessels that are
interconnected, or separate vessels
that are located such that a regulated
substance could be involved in a poten-
tial release, shall be considered a sin-
gle process.
Produced water means water ex-
tracted from the earth from an oil or
natural gas production well, or that is
separated from oil or natural gas after
extraction.
Public means any person except em-
ployees or contractors at the sta-
tionary source.
Public receptor means pffsite resi-
dences, institutions (e.g., schools, hos-
pitals), industrial, commercial, and of-
fice buildings, parks, or recreational
areas inhabited or occupied by the pub-
lic at any time without restriction by
the stationary source where members
of the public could be exposed to toxic
39
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§68.10
40 CFR Ch. I (7-1-99 Edition)
concentrations, radiant heat, or over-
pressure, as a result of an accidental
release.
Regulated substance is any substance
listed pursuant to section 112(r)(3) of
the Clean Air Act as amended, in
§68.130.
Replacement in kind means a replace-
ment that satisfies the design speci-
fications.
RMP means the risk management
plan required under subpart G of this
part.
Stationary source means any build-
ings, structures, equipment, installa-
tions, or substance emitting stationary
activities which belong to the same in-
dustrial group, which are located on
one or more contiguous properties,
which are under the control of the
same person (or persons under common
control), and from which an accidental
release may occur. The term sta-
tionary source does not apply to trans-
portation, including storage incident
to transportation, of any regulated
substance or any other extremely haz-
ardous substance under the provisions
of this part. A stationary source in-
cludes transportation containers used
for storage not incident to transpor-
tation and transportation containers
connected to equipment at a stationary
source for loading or unloading. Trans-
portation includes, but is not limited
to, transportation subject to oversight
or regulation under 49 CFR parts 192,
193, or 195, or a state natural gas or
hazardous liquid program for which the
state has in effect a certification to
DOT under 49 U.S.C. section 60105. A
stationary source does not include nat-
urally occurring hydrocarbon res-
ervoirs. Properties shall not be consid-
ered contiguous solely because of a
railroad or pipeline right-of-way.
Threshold quantity means the quan-
tity specified for regulated substances
pursuant to section 112(r)(5)- of the
Clean Air Act as amended, listed in
§68.130 and determined to be present at
a stationary source as specified in
§68.115 of this part.
Typical meteorological conditions
means the temperature, wind speed,
cloud cover, and atmospheric stability
class, prevailing at the site based on
data gathered at or near the site or
from a local meteorological station.
Vessel means any reactor, tank,
drum, barrel, cylinder, vat, kettle,
boiler, pipe, hose, or other container.
Worst-case release means the release
of the largest quantity of a regulated
substance from a vessel or process line
failure that results in the greatest dis-
tance to an endpoint defined in
§68.22(a).
[59 FR 4493, Jan. 31, 1994, as amended at 61
FR 31717, June 20, 1996; 63 FR 644, Jan. 6, 1998;
64 FR 979, Jan. 6, 1999]
§68.10 Applicability.
(a) An owner or operator of a sta-
tionary source that has more than a
threshold quantity of a regulated sub-
stance in a process, as determined
under §68.115, shall comply with the re-
quirements of this part no later than
the latest of the following dates:
(1) June 21, 1999;
(2) Three years after the date on
which a regulated substance is first
listed under §68.130; or
(3) The date on which a regulated
substance is first present above a
threshold quantity in a process.
(b) Program 1 eligibility require-
ments. A covered process is eligible for
Program 1 requirements as provided in
§68.12(b) if it meets all of the following
requirements:
(1) For the five years prior to the
submission of an RMP, the process has
not had an accidental release of a regu-
lated substance where exposure to the
substance, its reaction products, over-
pressure generated by an explosion in-
volving the substance, or radiant heat
generated by a fire involving the sub-
stance led to any of the following off-
site:
(i) Death;
(ii) Injury; or
(iii) Response or restoration activi-
ties for an exposure of an environ-
mental receptor;
(2) The distance to a toxic or flam-
mable endpoint for a worst-case release
assessment conducted under Subpart B
and §68.25 is less than the distance to
any public receptor, as defined in
§68.30; and
(3) Emergency response procedures
have been coordinated between the sta-
tionary source and local emergency
planning and response organizations.
40
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ill!
i in
ill?'!,! i , t >' .'
IL1'
I"":,
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Environmental Protection Agency
(c) Program 2 eligibility require-
ments. A covered process is subject to
Program 2 requirements if it does not
meet the eligibility requirements of ei-
ther paragraph (b) or paragraph (d) of
this section.
(d) Program 3 eligibility require-
ments. A covered process is subject to
Program 3 if the process does not meet
the requirements of paragraph (b) of
this section, and if either of the fol-
Ipwing conditions is met:
(1) The process is in NAICS code
32211, 32411, 32511, 325181, 325188, 325192,
325199, 325211, 325311, or 32532; or
(2) The process is subject to the
OSHA process safety management
Standard, 29 CFR 1910.119.
(e) If at any time a covered process
no longer meets the eligibility criteria
of its Program level, the owner or oper-
ator shall comply with the require-
ments of the new Program level that
applies to the process and update the
RMP as provided in §68.190.
(f) The provisions of this part shall
not apply to an Outer Continental
Shelf ("OCS") source, as defined in 40
CFR 55.2.
(61 PR 31717, June 20, 1996. as amended at 63
PR 64§. Jan. 6, 1998: 64 FR 979, Jan. 6, 1999]
§68.12 General requirements.
:; (a) General requirements. The owner
or operator of a stationary source sub-
ject to this part shall submit a single
RMP, as provided in §§68.150 to 68.185.
The RMP shall include a registration
that reflects all covered processes.
(b) Program 1 requirements. In addi-
tion to meeting the requirements of
paragraph (a) of this section, the owner
~"or pjperaifbr of a stationary source with
a process eligible for Program 1, as pro-
vided in §68.1Q(b), shall:
(1) Analyze the worst-case release
scenario for the process(es), as provided
in §68.25; document that the nearest
public receptor is beyond the distance
to a toxic of flammable endpoint de-
fined in §68.22(a); and submit in the
RMP the worst-case release scenario as
provided in §68.165;
(2) Complete the five-year accident
history for the process as provided in
§68ll2 of this part and submit it in the
RMP as provided in §68.168;
§68.12
(3) Ensure that response actions have
been coordinated with local emergency
planning and response agencies; and
(4) Certify in the RMP the following:
"Based on the criteria in 40 CFR 68.10,
the distance to the specified endpoint
for the worst-case accidental release
scenario for the following process (es) is
less than the distance to the nearest
public receptor: [list process(es)]. With-
in the past five years, the processes)
has (have) had no accidental release
that caused offsite impacts provided in
the risk management program rule (40
CFR 68.10(bj(l)). No additional meas-
ures are necessary to prevent offsite
impacts from accidental releases. In
the event of fire, explosion, or a release
of a regulated substance from the proc-
ess(es), entry within the distance to
the specified endpoints may pose a dan-
ger to public emergency responders.
Therefore, public emergency respond-
ers should not enter this area except as
arranged with the emergency contact
indicated in the RMP. The undersigned
certifies that, to the best of my knowl-
edge, information, and belief, formed
after reasonable inquiry, the informa-
tion .submitted is true, accurate, and
complete. [Signature, title, date
signed]."
(c) Program 2 requirements. In addi-
tion to meeting the requirements of
paragraph (a) of this section, the owner
or operator of a stationary source with
a process subject to Program 2, as pro-
vided in §68.10(c), shall:
(1) Develop and implement a manage-
ment system as provided in §68.15;
(2) Conduct a hazard assessment as
provided in §§68.20 through 68.42;
(3) Implement the Program 2 preven-
tion steps provided in §§68.48 through
68.60 or implement the Program 3 pre-
vention steps provided in §§68.65
through 68.87;
(4) Develop and implement an emer-
gency response program as provided in
§§68.90 to 68.95; and
(5) Submit as part of the RMP the
data on prevention program elements
for Program 2 processes as provided in
§68.170.
(d) Program 3 requirements. In addi-
tion to meeting the requirements of
paragraph (a) of this section, the owner
or operator of a stationary source with
41
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§68.15
40 CFR Ch. I (7-1-99 Edition)
a process subject to Program 3, as pro-
vided in §68.10(d) shall:
(1) Develop and implement a manage-
ment system as provided in §68.15;
(2) Conduct a hazard assessment as
provided in §§68.20 through 68.42;
(3) Implement the prevention re-
quirements of §§68.65 through 68.87;
(4) Develop and implement an emer-
gency response program as provided in
§§68.90 to 68.95 of this part; and
(5) Submit as part of the RMP the
data on prevention program elements
for Program 3 processes as provided in
§68.175.
[61 FR 31718, June 20, 1996]
§ 68.15 Management.
(a) The owner or operator of a sta-
tionary source with processes subject
to Program 2 or Program 3 shall de-
velop a management system to oversee
the implementation of the risk man-
agement program elements.
(b) The owner or operator shall as-
sign a qualified person or position that
has the overall responsibility for the
development, implementation, and in-
tegration of the risk management pro-
gram elements.
(c) When responsibility for imple-
menting individual requirements of
this part is assigned to persons other
than the person identified under para-
graph (b) of this section, the names or
positions of these people shall be docu-
mented and the lines of authority de-
fined through an organization chart or
similar document.
[61 FR 31718, June 20, 1996]
Subpart B—Hazard Assessment
SOURCE: 61 FR 31718, June 20, 1996, unless
otherwise noted.
§68.20 Applicability.
The owner or operator of a sta-
tionary source subject to this part
shall prepare a worst-case release sce-
nario analysis as provided in §68.25 of
this part and complete the five-year
accident history as provided in §68.42.
The owner or operator of a Program 2
and 3 process must comply with all sec-
tions in this subpart for these proc-
§68.22 Offsite consequence analysis
parameters.
(a) Endpoints. For analyses of offsite
consequences, the following endpoints
shall be used:
(1) Toxics. The toxic endpoints pro-
vided in appendix A of this part.
(2) Flammables. The endpoints for
flammables vary according to the sce-
narios studied:
(i) Explosion. An overpressure of 1
psi.
(ii) Radiant heat/exposure time. A ra-
diant heat of 5 kw/m2 for 40 seconds.
(iii) Lower flammability limit. A
lower flammability limit as provided in
NFPA documents or other generally
recognized sources.
(b) Wind speed/atmospheric stability
class. For the worst-case release anal-
ysis, the owner or operator shall use a
wind speed of 1.5 meters per second and
F atmospheric stability class. If the
owner or operator can demonstrate
that local meteorological data applica-
ble to the stationary source show a
higher minimum wind speed or less sta-
ble atmosphere at all times during the
previous three years, these minimums
may be used. For analysis of alter-
native scenarios, the owner or operator
may use the typical meteorological
conditions for the stationary source.
(c) Ambient temperature/humidity.
For worst-case release analysis of a
regulated toxic substance, the owner or
operator shall use the highest daily
maximum temperature in the previous
three years and average humidity for
the site, based on temperature/humid-
ity data gathered at the stationary
source or at a local meteorological sta-
tion; an owner or operator using the
RMP Offsite Consequence Analysis
Guidance may use 25 °C and 50 percent
humidity as values for these variables.
For analysis of alternative scenarios,
the owner or operator may use typical
temperature/humidity data gathered at
the stationary source or at a local me-
teorological station.
(d) Height of release. The worst-case
release of a regulated toxic substance
shall be analyzed assuming a ground
level (0 feet) release. For an alternative
scenario analysis of a regulated toxic
substance, release height may be deter-
mined by the release scenario.
42
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"I f •! •!'
Environmental Protection Agency
(e) Surface roughness. The owner or
operator shall use either urban or rural
topography, as appropriate. Urban
j-rieafis that there are many obstacles in
the immediate area; obstacles include
buildings or trees. Rural means there
are no buildings in the immediate area
and the terrain is generally flat and
unobstructed.
(f) Dense or neutrally buoyant gases.
The, owner or operator shall ensure
that tables or models used for disper-
sion analysis of regulated toxic sub-
stances appropriately account for gas
density.
(g) Temperature of released sub-
stance. For worst case, liquids other
than gases liquified by refrigeration
only shall be considered to be released
at the highest daily maximum tem-
perature, based on data for the pre-
vious three years appropriate for the
stationary source, or at process tem-
perature, whichever is higher. For al-
ternative scenarios, substances may be
considered to be released at a process
or ambient temperature that is appro-
priate for the scenario.
§68.25 Worst-case release scenario
analysis.
(a) The owner or operator shall ana-
lyze and report in the RMP:
11 :::(!)' For Program 1 processes, one
worst-case release scenario for each
Program 1 process;
(2) For Program 2 and 3 processes:
(i) One worst-case release scenario
that is estimated to create the greatest
distance in any direction to an end-
jpoint provided in appendix A of this
part resulting from an accidental re-
lease of regulated toxic substances
from covered processes under worst-
case conditions defined in §68.22;
(ii) One worst-case release scenario
that is estimated to create the greatest
distance in any direction to an end-
point defined in §68.22 (a) resulting from
Iri accidental release of regulated flam-
mable substances from covered proc-
esses under worst-case conditions de-
fined" in §68.22; and
(iii) Additional worst-case release
scenarios for a hazard class if a worst-
case release from another covered proc-
ess at the stationary source potentially
affects public receptors different from
those potentially affected by the worst-
§68.25
case release scenario developed under
paragraphs (a)(2)(i) or (a)(2)(ii) of this
section.
(b) Determination of worst-case release
quantity. The worst-case release quan-
tity shall be the greater of the fol-
lowing:
(1) For substances in a vessel, the
greatest amount held in a single vessel,
taking into account administrative
controls that limit the maximum quan-
tity; or
(2) For substances in pipes, the great-
est amount in a pipe, taking into ac-
count administrative controls that
limit the maximum quantity.
(c) Worst-case release scenario—toxic
gases. (1) For regulated toxic sub-
stances that are normally gases at am-
bient temperature and handled as a gas
or as a liquid under pressure, the owner
or operator shall assume that the
quantity in the vessel or pipe, as deter-
mined under paragraph (b) of this sec-
tion, is released as a gas over 10 min-
utes. The release rate shall be assumed
to be the total quantity divided by 10
unless passive mitigation systems are
in place.
(2) For gases handled as refrigerated
liquids at ambient pressure:
(i) If the released substance is not
contained by passive mitigation sys-
tems or if the contained pool would
have a depth of 1 cm or less, the owner
or operator shall assume that the sub-
stance is released as a gas in 10 min-
utes;
(ii) If the released substance is con-
tained by passive mitigation systems
in a pool with a depth greater than 1
cm, the owner or operator may assume
that the quantity in the vessel or pipe,
as determined under paragraph (b) of
this section, is spilled instantaneously
to form a liquid pool. The volatiliza-
tion rate (release rate) shall be cal-
culated at the boiling point of the sub-
stance and at the conditions specified
in paragraph (d) of this section.
(d) Worst-case release scenario—toxic
liquids. (I) For regulated toxic sub-
stances that are normally liquids at
ambient temperature, the owner or op-
erator shall assume that the quantity
in the vessel or pipe, as determined
under paragraph (b) of this section, is
spilled instantaneously to form a liquid
pool.
43
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; ,!' ' , ,' , :*! .' <, A: 11! |: i"
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§68.25
40 CFR Ch. I (7-1-99 Edition)
(i) The surface area of the pool shall
be determined by assuming that the
liquid spreads to 1 centimeter deep un-
less passive mitigation systems are in
place that serve to contain the spill
and limit the surface area. Where pas-
sive mitigation is in place, the surface
area of the contained liquid shall be
used to calculate the volatilization
rate.
(ii) If the release would occur onto a
surface that is not paved or smooth,
the owner or operator may take into
account the actual surface characteris-
tics.
(2) The volatilization rate shall ac-
count for the highest daily maximum
temperature occurring in the past
three years, the temperature of the
substance in the vessel, and the con-
centration of the substance if the liq-
uid spilled is a mixture or solution.
(3) The rate of release to air shall be
determined from the volatilization rate
of the liquid pool. The owner or oper-
ator may use the methodology in the
RMP Offsite Consequence Analysis
Guidance or any other publicly avail-
able techniques that account for the
modeling conditions and are recognized
by industry as applicable as part of
current practices. Proprietary models
that account for the modeling condi-
tions may be used provided the owner
or operator allows the implementing
agency access to the model and de-
scribes model features and differences
from publicly available models to local
emergency planners upon request.
(e) Worst-case release scenario—flam-
mable gases. The owner or operator
shall assume that the quantity of the
substance, as determined under para-
graph (b) of this section and the provi-
sions below, vaporizes resulting in a
vapor cloud explosion. A yield factor of
10 percent of the available energy re-
leased in the explosion shall be used to
determine the distance to the- explosion
endpoint if the model used is based on
TNT equivalent methods.
(1) For regulated flammable sub-
stances that are normally gases at am-
bient temperature and handled as a gas
or as a liquid under pressure, the owner
or operator shall assume that the
quantity in the vessel or pipe, as deter-
mined under paragraph (b) of this sec-
tion, is released as a gas over 10 min-
utes. The total quantity shall be as-
sumed to be involved in the vapor
cloud explosion.
(2) For flammable gases handled as
refrigerated liquids at ambient pres-
sure:
(i) If the released substance is not
contained by passive mitigation sys-
tems or if the contained pool would
have a depth of one centimeter or less,
the owner or operator shall assume
that the total quantity of the sub-
stance is released as a gas in 10 min-
utes, and the total quantity will be in-
volved in the vapor cloud explosion.
(ii) If the released substance is con-
tained by passive mitigation systems
in a pool with a depth greater than 1
centimeter, the owner or operator may
assume that the quantity in the vessel
or pipe, as determined under paragraph
(b) of this section, is spilled instanta-
neously to form a liquid pool. The vola-
tilization rate (release rate) shall be
calculated at the boiling point of the
substance and at the conditions speci-
fied in paragraph (d) of this section.
The owner or operator shall assume
that the quantity which becomes vapor
in the first 10 minutes is involved in
the vapor cloud explosion.
(f) Worst-case release scenario—flam-
mable liquids. The owner or operator
shall assume that the quantity of the
substance, as determined under para-
graph (b) of this section and the provi-
sions below, vaporizes resulting in a
vapor cloud explosion. A yield factor of
10 percent of the available energy re-
leased in the explosion shall be used to
determine the distance to the explosion
endpoint if the model used is based on
TNT equivalent methods.
(1) For regulated flammable sub-
stances that are normally liquids at
ambient temperature, the owner or op-
erator shall assume that the entire
quantity in the vessel or pipe, as deter-
mined under paragraph (b) of this sec-
tion, is spilled instantaneously to form
a liquid pool. For liquids at tempera-
tures below their atmospheric boiling
point, the volatilization rate shall be
calculated at the conditions specified
in paragraph (d) of this section.
(2) The owner or operator shall as-
sume that the quantity which becomes
vapor in the first 10 minutes is in-
volved in the vapor cloud explosion.
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Environmental Protection Agency
§68.28
I.T »i.
I if'!,'
(g) Parameters to be applied. The
owner or operator shall use the param-
eters defined in §68.22 to determine dis-
^ance to the endpoints. The owner or
operator may use the methodology pro-
vided in the RMP Offsite Consequence
Analysis Guidance or any commer-
cially or publicly available air disper-
sion modeling techniques, provided the
techniques account for the modeling
conditions and are recognized by indus-
tryas applicable as part of current
practices. Proprietary models that ac-
count for the modeling conditions may
be used provided the owner or operator
allows the implementing agency access
to the model and describes model fea-
tures and differences from publicly
.available models ^tp local emergency
planners upon request.
(h) Consideration of passive mitigation.
Passive mitigation systems may be
considered for the analysis of worst
case provided that the mitigation sys-
tem is capable of withstanding the re-
lease event triggering the scenario and
would still function as intended.
(i) Factors in selecting a worst-case sce-
nario. Notwithstanding the provisions
of paragraph (b) of this section, the
owner or operator shall select as the
worst case for flammable regulated
ij i-isufistanqes or ,tfie" worst case for regu-
!;iiij|i!late"d toxic substances, a scenario based
on the following factors if such a sce-
nario would result in a greater distance
to an eridpoint defined in §68.22(a) be-
yond the stationary source boundary
11 than the scenario provided under para-
graph (b) of this section:
Smaller quantities handled at
ligher process temperature or pres-
sure; and
(2) Proximity to the boundary of the
stationary source.
161 FR 31718. June 20, 1996, as amended at 64
FR 28700, May 26, 1999]
§68.28 Alternative release scenario
analysis.
(a) The number of scenarios. The
owner or operator shall identify and
analyze at least one alternative release
scenario for each regulated toxic sub-
stance held in a covered process (es) and
at least one alternative release sce-
nario to represent all flammable sub-
stances held in covered processes.
(b) Scenarios to consider. (1) For each
scenario required under paragraph (a)
of this section, the owner or operator
shall select a scenario:
(i) That is more likely to occur than
the worst-case release scenario under
§68.25; and
(ii) That will reach an endpoint off-
site, unless no such scenario exists.
(2) Release scenarios considered
should include, but are not limited to,
the following, where applicable:
(i) Transfer hose releases due to
splits or sudden hose uncoupling;
(ii) Process piping releases from fail-
ures at flanges, joints, welds, valves
and valve seals, and drains or bleeds;
(iii) Process vessel or pump releases
due to cracks, seal failure, or drain,
bleed, or plug failure;
(iv) Vessel overfilling and spill, or
overpressurization and venting through
relief valves or rupture disks; and
(v) Shipping container mishandling
and breakage or puncturing leading to
a spill.
(c) Parameters to be applied. The
owner or operator shall use the appro-
priate parameters defined in §68.22 to
determine distance to the endpoints.
The owner or operator may use either
the methodology provided in the RMP
Offsite Consequence Analysis Guidance
or any commercially or publicly avail-
able air dispersion modeling tech-
niques, provided the techniques ac-
count for the specified modeling condi-
tions and are recognized by industry as
applicable as part of current practices.
Proprietary models that account for
the modeling conditions may be used
provided the owner or operator allows
the implementing agency access to the
model and describes model features and
differences from publicly available
models to local emergency planners
upon request.
(d) Consideration of mitigation. Ac-
tive and passive mitigation systems
may be considered provided they are
capable of withstanding the event that
triggered the release and would still be
functional.
(e) Factors in selecting scenarios.
The owner or operator shall consider
the following in selecting alternative
release scenarios:
(1) The five-year accident history
provided in §68.42; and
45
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§68.30
40 CFR Ch. I (7-1-99 Edition)
(2) Failure scenarios identified under
§68.50 or §68.67.
§68.30 Defining offsite impacts—popu-
lation.
(a) The owner or operator shall esti-
mate in the RMP the population within
a circle with its center at the point of
the release and a radius determined by
the distance to the endpoint defined in
§68.22(a).
(b) Population to be defined. Popu-
lation shall include residential popu-
lation. The presence of institutions
(schools, hospitals, prisons), parks and
recreational areas, and major commer-
cial, office, and industrial buildings
shall be noted in the RMP.
(c) Data sources acceptable. The owner
or operator may use the most recent
Census data, or other updated informa-
tion, to estimate the population poten-
tially affected.
(d) Level of accuracy. Population shall
be estimated to two significant digits.
§68.33 Defining offsite impacts—envi-
ronment.
(a) The owner or operator shall list in
the RMP environmental receptors
within a circle with its center at the
point of the release and a radius deter-
mined by the distance to the endpoint
defined in §68.22(a) of this part.
(b) Data sources acceptable. The
owner or operator may rely on infor-
mation provided on local U.S. Geologi-
cal Survey maps or on any data source
containing U.S.G.S. data to identify
environmental receptors.
68.36 Review and update.
(a) The owner or operator shall re-
view and update the offsite con-
sequence analyses at least once every
five years.
(b) If changes in processes, quantities
stored or handled, or any other aspect
of the stationary source might reason-
ably be expected to increase or de-
crease the distance to the endpoint by
a factor of two or more, the owner or
operator shall complete a revised anal-
ysis within six months of the change
and submit a revised risk management
plan as provided in §68.190.
§ 68.39 Documentation.
The owner or operator shall maintain
the following records on the offsite
consequence analyses:
(a) For worst-case scenarios, a de-
scription of the vessel or pipeline and
substance selected as worst case, as-
sumptions and parameters used, and
the rationale for selection; assump-
tions shall include use of any adminis-
trative controls and any passive miti-
gation that were assumed to limit the
quantity that could be released. Docu-
mentation shall include the antici-
pated effect of the controls and mitiga-
tion on the release quantity and rate.
(b) For alternative release scenarios,
a description of the scenarios identi-
fied, assumptions and parameters used,
and the rationale for the selection of
specific scenarios; assumptions shall
include use of any administrative con-
trols and any mitigation that were as-
sumed to limit the quantity that could
be released. Documentation shall in-
clude the effect of the controls and
mitigation on the release quantity and
rate.
(c) Documentation of estimated
quantity released, release rate, and du-
ration of release.
(d) Methodology used to determine
distance to endpoints.
(e) Data used to estimate population
and environmental receptors poten-
tially affected.
§ 68.42 Five-year accident history.
(a) The owner or operator shall in-
clude in the five-year accident history
all accidental releases from covered
processes that resulted in deaths, inju-
ries, or significant property damage on
site, or known offsite deaths, injuries,
evacuations, sheltering in place, prop-
erty damage, or environmental dam-
age.
(b) Data required. For each accidental
release included, the owner or operator
shall report the following information:
(1) Date, time, and approximate dura-
tion of the release;
(2) Chemical (s) released;
(3) Estimated quantity released in
pounds and, for mixtures containing
regulated toxic substances, percentage
concentration by weight of the released
regulated toxic substance in the liquid
mixture;
46
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Environmental Protection Agency
(4) Five- or six-digit NAICS code that
most closely corresponds to the proc-
ess;
(5) The type of release event and its
source; i _ " / " \ '_'\ " ~^'
(6) Weather conditions, if known;
(7) On-site impacts;
(8) Known offsite impacts;
(9) Initiating event and contributing
factors if known;
(10) Whether offsite responders were
notified if known; and
(11) Operational or process changes
that resulted from investigation of the
"ll "release.'" _ i ' _" '
(cjLevel of accuracy. Numerical esti-
mates may be provided to two signifi-
cant digits.
[61 FR 31718, June 20, 1996, as amended at 64
FR 979. Jan. 6. 1999]
Subpart C—Program 2 Prevention
Program
SOURCE: 61 FR 31721, June 20, 1996, unless
otherwise noted.
§68.48 Safety information.
(a) The owner or operator shall com-
pile and maintain the following up-to-
date safety information related to the
regulated substances, processes, and
equipment:
(1) Material Safety Data Sheets that
meet the requirements of 29 CFR
1910.1200(g);
(2] Maximum intended inventory of
equipment in which the regulated sub-
stances are stored or processed;
(3) Safe upper and lower tempera-
tures, pressures, flows, and composi-
tions; ~ " \ ni ]" ii^iii'_l
(4) Equipment specifications; and
(5) Codes and standards used to de-
sign, build, and operate the process.
(b) The owner or operator shall en-
sure that the process is designed in
compliance with recognized and gen-
erally accepted good engineering prac-
: "Hces. Compliance with Federal or state
! regulations that address industry-spe-
cific safe design or with industry-spe-
cific design codes and standards may be
used to demonstrate compliance with
this paragraph.
(cj The owner or operator shall up-
date the safety information if a major
§68.52
change occurs that makes the informa-
tion inaccurate.
§68.50 Hazard review.
(a) The owner or operator shall con-
duct a review of the hazards associated
with the regulated substances, process,
and procedures. The review shall iden-
tify the following:
(1) The hazards associated with the
process" and regulated substances;
(2) Opportunities for equipment mal-
functions or human errors that could
cause an accidental release;
(3) The safeguards used or needed to
control the hazards or prevent equip-
ment malfunction or human error; and
(4) Any steps used or needed to detect
or monitor releases.
(b) The owner or operator may use
checklists developed by persons or or-
ganizations knowledgeable about the
process and equipment as a guide to
conducting the review. For processes
designed to meet industry standards or
Federal or state design rules, the haz-
ard review shall, by inspecting all
equipment, determine whether the
process is designed, fabricated, and op-
erated in accordance with the applica-
ble standards or rules.
(c) The owner or operator shall docu-
ment the results of the review and en-
sure that problems identified are re-
solved in a timely manner.
(d) The review shall be updated at
least once every five years. The owner
or operator shall also conduct reviews
whenever a major change in the proc-
ess occurs; all issues identified in the
review shall be resolved before startup
of the changed process.
§68.52 Operating procedures.
(a) The owner or operator shall pre-
pare written operating procedures that
provide clear instructions or steps for
safely conducting activities associated
with each covered process consistent
with the safety information for that
process. Operating procedures or in-
structions provided by equipment man-
ufacturers or developed by persons or
organizations knowledgeable about the
process and equipment may be used as
a basis for a stationary source's oper-
ating procedures.
(b) The procedures shall address the
following:
47
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§68.54
40 CFR Ch. I (7-1-99 Edition)
(1) Initial startup;
(2) Normal operations;
(3) Temporary operations;
(4) Emergency shutdown and oper-
ations;
(5) Normal shutdown;
(6) Startup following a normal or
emergency shutdown or a major change
that requires a hazard review;
(7) Consequences of deviations and
steps required to correct or avoid devi-
ations; and
(8) Equipment inspections.
(c) The owner or operator shall en-
sure that the operating procedures are
updated, if necessary, whenever a
major change occurs and prior to start-
up of the changed process.
§68.54 Training.
(a) The owner or operator shall en-
sure that each employee presently op-
erating a process, and each employee
newly assigned to a covered process
have been trained or tested competent
in the operating procedures provided in
§68.52 that pertain to their duties. For
those employees already operating a
process on June 21, 1999, the owner or
operator may certify in writing that
the employee has the required knowl-
edge, skills, and abilities to safely
carry out the duties and responsibil-
ities as provided in the operating pro-
cedures.
(b) Refresher training. Refresher
training shall be provided at least
every three years, and more often if
necessary, to each employee operating
a process to ensure that the employee
understands and adheres to the current
operating procedures of the process.
The owner or operator, in consultation
with the employees operating the proc-
ess, shall determine the appropriate
frequency of refresher training.
(c) The owner or operator may use
training conducted under Federal or
state regulations or under industry-
specific standards or codes or training
conducted by covered process equip-
ment vendors to demonstrate compli-
ance with this section to the extent
that the training meets the require-
ments of this section.
(d) The owner or operator shall en-
sure that operators are trained in any
updated or new procedures prior to
startup of a process after a major
change.
§68.56 Maintenance.
(a) The owner or operator shall pre-
pare and implement procedures to
maintain the on-going mechanical in-
tegrity of the process equipment. The
owner or operator may use procedures
or instructions provided by covered
process equipment vendors or proce-
dures in Federal or state regulations or
industry codes as the basis for sta-
tionary source maintenance proce-
dures.
(b) The owner or operator shall train
or cause to be trained each employee
involved in maintaining the on-going
mechanical integrity of the process. To
ensure that the employee can perform
the job tasks in a safe manner, each
such employee shall be trained in the
hazards of the process, in how to avoid
or correct unsafe conditions, and in the
procedures applicable to the employ-
ee's job tasks.
(c) Any maintenance contractor shall
ensure that each contract maintenance
employee is trained to perform the
maintenance procedures developed
under paragraph (a) of this section.
(d) The owner or operator shall per-
form or cause to be performed inspec-
tions and tests on process equipment.
Inspection and testing procedures shall
follow recognized and generally accept-
ed good engineering practices. The fre-
quency of inspections and tests of proc-
ess equipment shall be consistent with
applicable manufacturers' rec-
ommendations, industry standards or
codes, good engineering practices, and
prior operating experience.
§68.58 Compliance audits.
(a) The owner or operator shall cer-
tify that they have evaluated compli-
ance with the provisions of this sub-
part at least every three years to
verify that the procedures and prac-
tices developed under the rule are ade-
quate and are being followed.
(b) The compliance audit shall be
conducted by at least one person
knowledgeable in the process.
(c) The owner or operator shall de-
velop a report of the audit findings.
(d) The owner or operator shall
promptly determine and document an
48
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.1 " 1. I1,1 I'1',* '!!"
Environmental Protection Agency
Appropriate response to each of the
findings of the compliance audit and
document that deficiencies have been
....... ' ' ' ....... ' ......... ''"'"'"'
,, _ .......... ...... _ ........,.
(e) The owner or operator shall retain
the two (2) most recent compliance
audit reports. This requirement does
not apply to any compliance audit re-
port that is more than five years old.
§68.60 Incident investigation.
(a) The owner or operator shall inves-
tigate each incident which resulted in,
"ir'o'r'c'Suld reasonably have resulted in a
catastrophic release.
, .li/ill.Cb) An incident investigation shall be
^^•'"IniHated as promptly as possible, but
'" than 1 48 1 hours following the
............................................
*;' , ' P",
i ;
(Hi, i » • , 1 I
.!:~iSi, (c) A summary shall be prepared at
the conclusion of the investigation
.. 'j, •• ..... which includes at a minimum:
......... : ......... -'"(I) ..... b'ate'of incident; ........... ........
,,,::;;,:, (2) Date investigation began;
(3) A description of the incident;
(4) The factors that contributed to
iiShe ..... iBPtdent; and, .............................................
!1|i™*11 (5) Any recommendations resulting
from the investigation.
(d) The owner or operator shall
promptly address and resolve the inves-
tigation findings and recommenda-
^tiqns. Resolutions ...... and corrective ac-,
J 'Sons' sriali b'e documented. '" ' ".'.... ' '"..'
(e) The findings shall be reviewed
with all affected personnel whose job
tasks are affected by the findings.
(f) Investigation summaries shall be
, ^..retained for five years.
Subpart D — Program 3 Prevention
' ;;" ;,;;"""' „; • Program
SOURCE: 61 FR .31722,, June, 2,0, 1996, unless ,„
''""otherwise noted.
§68.65 Process safety information.
(a) In accordance with the schedule
set forth in §68.67, the owner or oper-
ator shall complete a compilation of
written process safety information be-
fore conducting any process hazard
analysis required by the rule. The com-
pilation of written process safety infor-
mation is to enable the owner or oper-
ator and the employees involved in op-
.......... eratlng'the ..... process to "identify and un-
dersE&nd the hazards posed by those
processes involving regulated sub-
§68.65
stances. This process safety informa-
tion shall include information per-
taining to the hazards of the regulated
substances used or, produced by the
process, information pertaining to the
technology of 'the process, and informa-
tion pertaining to the equipment in the
process.
(b) Information pertaining to the
hazards of the regulated substances in
the process. This information shall
consist of at least the following:
(1) Toxicity information;
(2) Permissible exposure limits;
(3) Physical data;
(4) Reactivity data:
(5) Corrosivity data;
(6) Thermal and chemical stability
data; and
(7) Hazardous effects of inadvertent
mixing of different materials that
could foreseeably occur.
NOTE TO PARAGRAPH (b): Material Safety
Data Sheets meeting the requirements of 29
CFR 1910.1200(g) may be used to comply with
this requirement to the extent they contain
the information required by this subpara-
graph.
(c) Information pertaining to the
technology of the process.
(1) Information concerning the tech-
nology of the process shall include at
least,,1:he,,follovving:
(i) A block flow diagram or simplified
process flow diagram;
(ii) Process chemistry;
(iii) Maximum intended inventory;
(iv) Safe upper and lower limits for
such items as temperatures, pressures,
flows or compositions; and,
(v) An evaluation of the consequences
of deviations.
(2) Where the original technical in-
formation no longer exists, such infor-
mation may be developed in conjunc-
tion with the process hazard, analysis
in sufficient detail to support the anal-
ysis.
(d) Information pertaining to the
equipment in the process.
(1) Information pertaining to the
equipment in the process shall include:
(i) Materials of construction;
(ii) Piping and instrument diagrams
(P&ID's);
(iii) Electrical classification;
(iv) Relief system design and design
basis;
(v) Ventilation system design;
49
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§68.67
40 CFR Ch. I (7-1-99 Edition)
(vi) Design codes and standards em-
ployed;
(vii) Material and energy balances for
processes built after June 21, 1999; and
(viii) Safety systems (e.g. interlocks,
detection or suppression systems).
(2) The owner or operator shall docu-
ment that equipment complies with
recognized and generally accepted good
engineering practices.
(3) For existing equipment designed
and constructed in accordance with
codes, standards, or practices that are
no longer in general use, the owner or
operator shall determine and document
that the equipment is designed, main-
tained, inspected, tested, and operating
in a safe manner.
§ 68.67 Process hazard analysis.
(a) The owner or operator shall per-
form an initial process hazard analysis
(hazard evaluation) on processes cov-
ered by this part. The process hazard
analysis shall be appropriate to the
complexity of the process and shall
identify, evaluate, and control the haz-
ards involved in the process. The owner
or operator shall determine and docu-
ment the priority order for conducting
process hazard analyses based on a ra-
tionale which includes such consider-
ations as extent of the process hazards,
number of potentially affected employ-
ees, age of the process, and operating
history of the process. The process haz-
ard analysis shall be conducted as soon
as possible, but not later than June 21,.
1999. Process hazards analyses com-
pleted to comply with 29 CFR
1910.119(e) are acceptable as initial
process hazards analyses. These process
hazard analyses shall be updated and
revalidated, based on their completion
date.
(b) The owner or operator shall use
one or more of the following meth-
odologies that are appropriate to deter-
mine and evaluate the hazards of the
process being analyzed.
(1) What-If;
(2) Checklist;
(3) What-If/Checklist;
(4) Hazard and Operability Study
(HAZOP);
(5) Failure Mode and Effects Analysis
(FMEA);
(6) Fault Tree Analysis; or
(7) An appropriate equivalent meth-
odology.
(c) The process hazard analysis shall
address:
(1) The hazards of the process;
(2) The identification of any previous
incident which had a likely potential
for catastrophic consequences.
(3) Engineering and administrative
controls applicable to the hazards and
their interrelationships such as appro-
priate application of detection meth-
odologies to provide early warning of
releases. (Acceptable detection meth-
ods might include process monitoring
and control instrumentation with
alarms, and detection hardware such as
hydrocarbon sensors.);
(4) Consequences of failure of engi-
neering and administrative controls;
(5) Stationary source siting;
(6) Human factors; and
(7) A qualitative evaluation of a
range of the possible safety and health
effects of failure of controls.
(d) The process hazard analysis shall
be performed by a team with expertise
in engineering and process operations,
and the team shall include at least one
employee who has experience and
knowledge specific to the process being
evaluated. Also, one member of the
team must be 'knowledgeable in the
specific process hazard analysis meth-
odology being used.
(e) The owner or operator shall estab-
lish a system to promptly address the
team's findings and recommendations;
assure that the recommendations are
resolved in a timely manner and that
the resolution is documented; docu-
ment what actions are to be taken;
complete actions as soon as possible;
develop a written schedule of when
these actions are to be completed; com-
municate the actions to operating,
maintenance and other employees
whose work assignments are in the
process and who may be affected by the
recommendations or actions.
(f) At least every five (5) years after
the completion of the initial process
hazard analysis, the process hazard
analysis shall be updated and revali-
dated by a team meeting the require-
ments in paragraph (d) of this section,
to assure that the process hazard anal-
ysis is consistent with the current
50
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process. Updated and revalidated proc-
ess hazard analyses completed to com-
ply with 29 CFR 1910.119(e) are accept-
able to meet the requirements of this
paragraph.
(g) The owner or operator shall re-
tainprocess hazards analyses and up-
v; '{.datgs or reyalidatipns for each process
ltt:i covered^ by this section, as well as the
Documented r.esoiu,CiC)n Of recommenda-
tions described in paragraph (e) of this
section for the life of the process.
§ 68.69 Operating procedures.
(a) The owner or operator shall de-
velop and implement written operating
procedures that provide clear instruc-
tions for safely conducting activities
involved in each coyered process con-
l sister^'witii tlie process safety infor-
I, mation anil .shall, address at least .the.
following elements. ''
(1) Steps for each operating phase:
(i) Initial startup;
(ii) Normal operations;
(iii) Temporary operations;
(iv) Emergency shutdown including
„ .the, conditions under which emergency
shutdpwn is required, and the assign-
Hji'ment of shutdown responsibility to
;; .^Qualified operators to ensure that
ij" gjjjgpggfjj.y "shutdown is executed in a
safe and timely manner.
(v) Emergency operations;
(vi) Normal shutdown; and,
(vii) Startup following a turnaround,
or after an emergency shutdown.
(2) Operating limits:
(i) Consequences of deviation; and
(ii) Steps required to correct or avoid
deviation.
(3} Safety and health considerations:
(i) Properties of, and hazards pre-
sented by, the chemicals used in the
process;
(ii) Precautions necessary to prevent
exposure, including engineering con-
trols, administrative controls, and per-
sonal protective equipment;
(iii) Control measures to be taken if
physical contact or airborne exposure
occurs;
(iv) Quality control for raw materials
and control of hazardous chemical in-
ventory levels; and,
(v) Any special or unique hazards.
(4) Safety systems and their func-
tions.
§68:71
(b) Operating procedures shall be
readily accessible to employees who
work in or maintain a process.
(c) The operating procedures shall be
reviewed as often as necessary to as-
sure that they reflect current oper-
ating practice, including changes that
result from changes in process chemi-
cals, technology, and equipment, and
changes to stationary sources. The
owner or operator shall certify annu-
ally that these operating procedures
are current and accurate.
(d) The owner or operator shall de-
velop and implement safe work prac-
tices to provide for the control of haz-
ards during operations such as lockout/
tagout; confined space entry; opening
process equipment or piping; and con-
trol over entrance into a stationary
source by maintenance, contractor,
laboratory, or other support personnel.
These safe work practices shall apply
to employees and contractor employ-
§68.71 Training.
(a) Initial training. (1) Each employee
presently involved in operating a proc-
ess, and each employee before being in-
volved in operating a newly assigned
process, shall be trained in an overview
of the process and in the operating pro-
cedures as specified in §68.69. The
training shall include emphasis on the
specific safety and health hazards,
emergency operations including shut-
down, and safe work practices applica-
ble to the employee's job tasks.
(2) In lieu of initial training for those
employees already involved in oper-
ating a process on June 21, 1999 an
owner or operator may certify in writ-
ing that the employee has the required
knowledge, skills, and abilities to safe-
ly carry out the duties and responsibil-
ities as specified in the operating pro-
cedures.
(b) Refresher training. Refresher train-
ing shall be provided at least every
three years, and more often if nec-
essary, to each employee involved in
operating a process to assure that the
employee understands and adheres to
the current operating procedures of the
process. The owner or operator, in con-
sultation with the employees involved
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§68.73
in operating the process, shall deter-
mine the appropriate frequency of re-.
fresher training.
(c) Training documentation. The owner
or operator shall ascertain that each
employee involved in operating a proc-
ess has received and understood the
training required by this paragraph.
The owner or operator shall prepare a
record which contains the identity of
the employee, the date of training, and
the means used to verify that the em-
ployee understood the training.
§68.73 Mechanical integrity.
(a) Application. Paragraphs (b)
through (f) of this section apply to the
following process equipment:
(1) Pressure vessels and storage
tanks;
(2) Piping systems (including piping
components such as valves);
(3) Relief and vent systems and de-
vices;
(4) Emergency shutdown systems;
(5) Controls (including monitoring
devices and sensors, alarms, and inter-
locks) and,
(6) Pumps.
(b) Written procedures. The owner or
operator shall establish and implement
written procedures to maintain the on-
going integrity of process equipment.
(c) Training for process maintenance
activities. The owner or operator shall
train each employee involved in main-
taining the on-going integrity of proc-
ess equipment in an overview of that
process and its hazards and in the pro-
cedures applicable to the employee's
job tasks to assure that the employee
can perform the job tasks in a safe
manner.
(d) Inspection and testing. (1) Inspec-
tions and tests shall be performed on
process equipment.
(2) Inspection and testing procedures
shall follow recognized and generally
accepted good engineering practices.
(3) The frequency of inspections and
tests of process equipment shall be con-
sistent with applicable manufacturers'
recommendations and good engineering
practices, and more frequently if deter-
mined to be necessary by prior oper-
ating experience.
(4) The owner or operator shall docu-
ment each inspection and test that has
been performed on process equipment.
40 CFR Ch. I (7-1-99 Edition)
The documentation shall identify the
date of the inspection or test, the name
of the person who performed the in-
spection or test, the serial number or
other identifier of the equipment on
which the inspection or test was per-
formed, a description of the inspection
or test performed, and the results of
the inspection or test.
(e) Equipment deficiencies. The owner
or operator shall correct deficiencies in
equipment that are outside acceptable
limits (defined by the process safety in-
formation in §68.65) before further use
or in a safe and timely manner when
necessary means are taken to assure
safe operation.
(f) Quality assurance. (1) In the con-
struction of new plants and equipment,
the owner or operator shall assure that
equipment as it is fabricated is suit-
able for the process application for
which they will be used.
(2) Appropriate checks and inspec-
tions shall be performed to assure that
equipment is installed properly and
consistent with design specifications
and the manufacturer's instructions.
(3) The owner or operator shall as-
sure that maintenance materials, spare
parts and equipment are suitable for
the process application for which they
will be used.
§ 68.75 Management of change.
(a) The owner or operator shall estab-
lish and implement written procedures
to manage changes (except for "re-
placements in kind") to process chemi-
cals, technology, equipment, and proce-
dures; and, changes to stationary
sources that affect a covered process.
(b) The procedures shall assure that
the following considerations are ad-
dressed prior to any change:
(1) The technical basis for the pro-
posed change;
(2) Impact of change on safety and
health;
(3) Modifications to operating proce-
dures;
(4) Necessary time period for the
change; and,
(5) Authorization requirements for
the proposed change.
(c) Employees involved in operating a
process and maintenance and contract
employees whose job tasks will be af-
fected by a change in the process shall
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:i;;-! Environmental Protection Agency
be informed of, and trained in, the
change prior to start-up of the process
or affected part of the process.
(3) If a change covered by this para-
graph results in a change in the process
safety information required by §68.65 of
this part, such information shall be up-
dated accordingly.
(e) If a change covered by this para-
graph results in a change in the oper-
ating procedures or practices required
by §68.69, such procedures or practices
shall be updated accordingly.
§68.77 Pre-startup review.
(a) The owner or operator shall per-
form a pre-startup safety review for
new stationary sources and for modi-
fied stationary sources when the modi-
fication is significant enough to re-
quire a change in the process safety in-
formation.
(b) The pre-startup safety review
shall confirm that prior to the intro-
duction of regulated substances to a
'"process: ............. ..........................
(1) Construction and equipment is in
accordance with design specifications;
(2) Safety, operating, maintenance,
and emergency procedures are in place
and are adequate;
(3) For new stationary sources, a
process hazard analysis has been per-
formed and recommendations have
been resolved or implemented before
startup; and modified stationary
sources meet the requirements con-
tained in management of change,
§68.75. ....... ......... ; .......
(4) Training of each employee in-
volved in operating a process has been
completed.
§68.79 Compliance audits.
(a) The owner or operator shall cer-
tify that they have evaluated compli-
ance with the provisions of this sub-
part at least every three years to
verify that procedures and practices
developed under this subpart are ade-
^MquSte'Shd are being followed.
(b) The compliance audit shall be
conducted by at least one person
knowledgeable in the process.
(c) A report of the findings of the
audit shall be developed.
''''•«»- "(d) The owner or operator shall
M'l'pro'rnptly11 determine " and document an
appropriate response to each of the
§68.63
findings of the compliance audit, and
document that deficiencies have been
corrected.
(e) The owner or operator shall retain
the two (2) most recent compliance
audit reports.
[61 FR 31722, June 20, 1996, as amended at 64
FR 979, Jan. 6, 1999]
§ 68.81 Incident investigation.
(a) The owner or operator shall inves-
tigate each incident which resulted in,
or could reasonably have resulted in a
catastrophic release of a regulated sub-
stance.
(b) An incident investigation shall be
initiated as promptly as possible, but
not later than 48 hours following the
incident.
(c) An incident investigation team
shall be established and consist of at
least one person knowledgeable in the
process involved, including a contract
employee if the incident involved work
of the contractor, and other persons
with appropriate knowledge and experi-
ence to thoroughly investigate and
analyze the incident.
(d) A report shall be prepared at the
conclusion of the investigation which
includes at a minimum:
(1) Date of incident;
(2) Date investigation began;
(3) A description of the incident;
(4) The factors that contributed to
the incident; and,
(5) Any recommendations resulting
from the investigation.
(e) The owner or operator shall estab-
lish a system to promptly address and
resolve the incident report findings and
recommendations. Resolutions and cor-
rective actions shall be documented.
(f) The report shall be reviewed with
all affected personnel whose job tasks
are relevant to the incident findings in-
cluding contract employees where ap-
plicable.
(g) Incident investigation reports
shall be retained for five years.
§68.83 Employee participation.
(a) The owner or operator shall de-
velop a written plan of action regard-
ing the implementation of the em-
ployee participation required by this
section.
53
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§68.85
(b) The owner or operator shall con-
sult with employees and their rep-
resentatives on the conduct and devel-
opment of process hazards analyses and
on the development of the other ele-
ments of process safety management in
this rule.
(c) The owner or operator shall pro-
vide to employees and their representa-
tives access to process hazard analyses
and to all other information required
to be developed under this rule.
§ 68.85 Hot work permit.
(a) The owner or operator shall issue
a hot work permit for hot work oper-
ations conducted on or near a covered
process.
(b) The permit shall document that
the fire prevention and protection re-
quirements in 29 CFR 1910.252(a) have
been implemented prior to beginning
the hot work operations; it shall indi-
cate the date(s) authorized for hot
work; and identify the object on which
hot work is to be performed. The per-
mit shall be kept on file until comple-
tion of the hot work operations.
§68.87 Contractors.
(a) Application. This section applies
to contractors performing maintenance
or repair, turnaround, major renova-
tion, or specialty work on or adjacent
to a covered process. It does not apply
to contractors providing incidental
services which do not influence process
safety, such as janitorial work, food
and drink services, laundry, delivery or
other supply services.
(b) Owner or operator responsibilities.
(1) The owner or operator, when select-
ing a contractor, shall obtain and
evaluate information regarding the
contract owner or operator's safety
performance and programs.
(2) The owner or operator shall in-
form contract owner or operator of the
known potential fire, explosion, or
toxic release hazards related to the
contractor's work and the process.
(3) The owner or operator shall ex-
plain to the contract owner or operator
the applicable provisions of subpart E
of this part.
(4) The owner or operator shall de-
velop and implement safe work prac-
tices consistent with §68.69(d), to con-
trol the entrance, presence, and exit of
40 CFR Ch. I (7-1-99 Edition)
the contract owner or operator and
contract employees in covered process
areas.
(5) The owner or operator shall peri-
odically evaluate the performance of
the contract owner or operator in ful-
filling their obligations as specified in
paragraph (c) of this section.
(c) Contract owner or operator respon-
sibilities. (1) The contract owner or op-
erator shall assure that each contract
employee is trained in the work prac-
tices necessary to safely perform his/
her job.
(2) The contract owner or operator
shall assure that each contract em-
ployee is instructed in the known po-
tential fire, explosion, or toxic release
hazards related to his/her job and the
process, and the applicable provisions
of the emergency action plan.
(3) The contract owner or operator
shall document that each contract em-
ployee has received and understood the
training required by this section. The
contract owner or operator shall pre-
pare a record which contains the iden-
tity of the contract employee, the date
of training, and the means used to
verify that the employee understood
the training.
(4) The contract owner or operator
shall assure that each contract em-
ployee follows the safety rules of the
stationary source including the safe
work practices required by §68.69(d).
(5) The contract owner or operator
shall advise the owner or operator of
any unique hazards presented by the
contract owner or operator's work, or
of any hazards found by the contract
owner or operator's work.
Subpart E—Emergency Response
SOURCE: 61 FR 31725, June 20, 1996, unless
otherwise noted.
§68.90 Applicability.
(a) Except as provided in paragraph
(b) of this section, the owner or oper-
ator of a stationary source with Pro-
gram 2 and Program 3 processes shall
comply with the requirements of §68.95.
(b) The owner or operator of sta-
tionary source whose employees will
not respond to accidental releases of
regulated substances need not comply
54
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Environmental Protection Agency
§68. 11 5
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with §68.95 of this part provided that
they meet the following:
(1) For stationary sources with any
regulated toxic substance held in a
process above the threshold quantity,
the stationary source is included in the
community emergency response plan
developed under 42 U.S.C. 11003;
(2) For stationary sources with only
regulated flammable substances held in
a process above the threshold quantity,
the owner or operator has coordinated
response actions with the local fire de-
partment; and
(3) Appropriate mechanisms are in
place to notify emergency responders
when there is a need for a response.
§68.95 Emergency response program.
(a) The owner or operator shall de-
velop and implement an emergency re-
sponse program for the purpose of pro-
tecting public health and the environ-
ment, Such program shall include the
following elements:
(1) An emergency response plan,
1 1 which ..... shall ', be. . maintained at .the,, sta-
tionary source and contain at least the
following elements:
(i) Procedures for informing the pub-
lic and local emergency response agen-
cies about accidental releases;
(ii) Documentation of proper first-aid
and emergency medical treatment nec-
essary to treat accidental human expo-
sures; arid
(iii) Procedures and measures for
emergency response after an accidental
release of a regulated substance;
(2) Procedures .......... for the use of emer-
gency response equipment an9 for its
inspection, testing, and maintenance;
(3) Training for all employees in rel-
evant procedures; and
(4) Procedures to review and update,
as appropriate, the emergency response
plan to reflect changes at the sta-
tionary source and ensure that employ-
ees are informed of changes.
(b) A. written plan that complies with
other Federal contingency plan regula-
Kstions or is consistent with the ap-
proach in the National Response
Team's Integrated Contingency Plan
Guidance ("One Plan") and that,
among other matters, includes the ele-
ments provided in paragraph (a) of this
...... lisecfiori, "shall satisfy the requirements
of this section if the owner or operator
also complies with paragraph (c) of this
section.
(c) The emergency response plan de-
veloped under paragraph (a)(l) of this
section shall be coordinated with the
community emergency response plan
developed under 42 U.S.C. 11003. Upon
request of the local emergency plan-
ning committee or emergency response
officials, the owner or operator shall
promptly provide to the local emer-
gency response officials information
necessary for developing and imple-
menting the community emergency re-
sponse plan.
Subpart F— Regulated Substances
for Accidental Release Prevention
SOURCE: 59 FR 4493, Jan. 31, 1994, unless
otherwise noted. Redesignated at 61 FR 31717,
June 20, 1996.
§ 68.100 Purpose.
This subpart designates substances
to be listed under section 112(r)(3), (4),
and (5) of the Clean Air Act, as amend-
ed, identifies their threshold quan-
tities, and establishes the requirements
for petitioning to add or delete sub-
stances from the list.
§ 68.115 Threshold, determination.
(a) A threshold quantity of a regu-
lated substance listed in §68.130 is
present at a stationary source if the
total quantity of the regulated sub-
stance contained in a process exceeds
the threshold.
(b) For the purposes of determining
whether more than a threshold quan-
tity of a regulated substance is present
at the stationary source, the following
exemptions apply:
(1) Concentrations of a regulated toxic
substance in a mixture. If a regulated
substance is present in a mixture and
the concentration of the substance is
below one percent by weight of the
mixture, the amount of the substance
in the mixture need not be considered
when determining whether more than a
threshold quantity is present at the
stationary source. Except for oleum,
toluene 2,4-diisocyanate, toluene 2,6-
diisocyanate, and toluene diisocyanate
(unspecified isomer), if the concentra-
tion of the regulated substance in the
mixture is one percent or greater by
55
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§68.115
weight, but the owner or operator can
demonstrate that the partial pressure
of the regulated substance in the mix-
ture (solution) under handling or stor-
age conditions in any portion of the
process is less than 10 millimeters of
mercury (mm Hg), the amount of the
substance in the mixture in that por-
tion of the process need not be consid-
ered when determining whether more
than a threshold quantity is present at
the stationary source. The owner or op-
erator shall document this partial pres-
sure measurement or estimate.
(2) Concentrations of a regulated flam-
mable substance in a mixture, (i) General
provision. If a regulated substance is
present in a mixture and the con-
centration of the substance is below
one percent by weight of the mixture,
the mixture need not be considered
when determining whether more than a
threshold quantity of the regulated
substance is present at the stationary
source. Except as provided in para-
graph (b) (2) (ii) and (iii) of this section,
if the concentration of the substance is
one percent or greater by weight of the
mixture, then, for purposes of deter-
mining whether a threshold quantity is
present at the stationary source, the
entire weight of the mixture shall be
treated as the regulated substance un-
less the owner or operator can dem-
onstrate that the mixture itself does
not have a National Fire Protection
Association flammability hazard rat-
ing of 4. The demonstration shall be in
accordance with the definition of flam-
mability hazard rating 4 in the NFPA
704, Standard System for the Identi-
fication of the Hazards of Materials for
Emergency Response, National Fire
Protection Association, Quincy, MA,
1996. Available from the National Fire
Protection Association, 1
Batterymarch Park, Quincy, MA 02269-
9101. This incorporation by reference
was approved by the Director of the
Federal Register in accordance with 5
U.S.C. 552(a) and 1 CFR part 51. Copies
may be inspected at the Environmental
Protection Agency Air Docket (6102),
Attn: Docket No. A-96-O8, Waterside
Mall, 401 M. St. SW., Washington DC;
or at the Office of Federal Register at
800 North Capitol St., NW, Suite 700,
Washington, DC. Boiling point and
flash point shall be defined and deter-
40 CFR Ch. I (7-1-99 Edition)
mined in accordance with NFPA 30,
Flammable and Combustible Liquids
Code, National Fire Protection Asso-
ciation, Quincy, MA, 1996. Available
from the National Fire Protection As-
sociation, 1 Batterymarch Park, Quin-
cy, MA 02269-9101. This incorporation
by reference was approved by the Di-
rector of the Federal Register in ac-
cordance with 5 U.S.C. 552(a) and 1 CFR
part 51. Copies may be inspected at the
Environmental Protection Agency Air
Docket (6102), Attn: Docket No. A-96-
O8, Waterside Mall, 401 M. St. SW.,
Washington DC; or at the Office of Fed-
eral Register at 800 North Capitol St.,
NW., Suite 700, Washington, DC. The
owner or operator shall document the
National Fire Protection Association
flammability hazard rating.
(ii) Gasoline. Regulated substances in
gasoline, when in distribution or re-
lated storage for use as fuel for inter-
nal combustion engines, need not be
considered when determining whether
more than a threshold quantity is
present at a stationary source.
(iii) Naturally occurring hydrocarbon
mixtures. Prior to entry into a natural
gas processing plant or a petroleum re-
fining process unit, regulated sub-
stances in naturally occurring hydro-
carbon mixtures need not be considered
when determining whether more than a
threshold quantity is present at a sta-
tionary source. Naturally occurring
hydrocarbon mixtures include any
combination of the following: conden-
sate, crude oil, field gas, and produced
water, each as defined in §68.3 of this
part.
(3) Articles. Regulated substances con-
tained in articles need not be consid-
ered when determining whether more
than a threshold quantity is present at
the stationary source.
(4) Uses. Regulated substances, when
in use for the following purposes, need
not be included in determining whether
more than a threshold . quantity is
present at the stationary source:
(i) Use as a structural component of
the stationary source;
(ii) Use of products for routine jani-
torial maintenance;
(iii) Use by employees of foods, drugs,
cosmetics, or other personal items con-
taining the regulated substance; and
56
-------
niiiiiiniiniiiiiiiniinnln in in in inn i linn mi in n in iininii n iiiiili in inn
:!! i,il • US 'HI1'!I!
I,'.;!!!,'"
11;!"
Environmental Protection Agency
(iy) Use of regulated substances
present in process water or non-contact
cooling water as drawn from the envi-
_,,, '^jfoiBfiefiii*1 ..... of ' municipal sources, or use
' 'i(i .'ij/j'of regulated substances present in air
. si '", ll"l|jj "iis4§ ..... either .as, Compressed air or as part
l!l :' ..... of" combustion'.
• ..... —I ;;,,=,,, (§]„, Activities^ in laboratories. If a regu-
..... ,, ,'j -.:: ,"''!;- I,ate3 ' substance" Is manufactured, proc-
" vt ' ' 1|"1 "m ..... IsSS^ ...... or 'used' in a laboratory "at "a 'sta-
tionary source under the supervision of
a technically qualified individual as de-
fined in §720.3(ee) of this chapter, the
quantity of the substance need not be
..... considered, in determining whether a
........... threshold "quantity" "is ..... present. This ex-
emption does not apply to:
(i) Specialty chemical production;
(ii) Manufacture, processing, or use
of substances in pilot plant scale oper-
; • , , • , ..... , • viiations; and
(Mi) Activities conducted outside the
laboratory.
J59 FR 4493, Jan. 31. 1994. Redesignated at 61
FR, 31717, June 20, 1996, as amended at 63 FR
"645, ..... Jan. 6, ..... 1998] ....................................
§ 68.120 Petition process.
(a) Any person may petition the Ad-
ministrator to modify, by addition or
deletion; the list of regulated sub-
stances identified in §68.130. Based on
the information presented by the peti-
' tioner, the Administrator .may grant or
deny a petition.
(b) A substance may be added to the
list if, in the case of an accidental re-
lease, it is known to cause^or may be
,„ ..... | „ .i/^^eaggpably anticipated to cause death,
..... ";1 '•""•" |njury,' or ......... serious ......... adverse effects to
human health or the environment.
(c) A substance may be deleted from
the list if adequate data on the health
and environmental effects of the sub-
i 1 1 stance are available to Determine that
the substance*, in 't£e'case"ofl "an" ac&-'
dental release, is not known to cause
and may not be reasonably anticipated
j| | ||||| to cause ", death, ,„ injury, or serious ad-
i verse effects to "human , health ........ or the,,
environment.
(d) No substance for which a national
primary ambient air quality standard
has been established shall be added to
the list. No substance regulated under
..... titie VI of.tite Ctean Air Acttias.iamen<]Uii
ed, shall be added to the list.
(e) The burden of proof is on the peti-
•' tioner to demonstrate that the criteria
§68.120
for addition and deletion are met. A pe-
tition will be denied if this demonstra-
tion is not made.
(f) The Administrator will not accept
additional petitions on the same sub-
stance following publication of a final
notice of the decision to grant or deny
a petition, unless new data becomes
available that could significantly af-
fect the basis for the decision.
(g) Petitions to modify the list of
regulated substances must contain the
following:
(1) Name and address of the peti-
tioner and a brief description of the or-
ganization® that the petitioner rep-
resents, if applicable;
(2) Name, address, and telephone
number of a contact person for the pe-
tition;
(3) Common chemical name(s), com-
mon synonym(s), Chemical Abstracts
Service number, and chemical formula
and,, structure;
(4) Action requested (add or delete a
substance);
(5) Rationale supporting the peti-
tioner's position; that is, how the sub-
stance meets the criteria for addition
and deletion. A short summary of the
rationale must be submitted along
with a more detailed narrative; and
(6) Supporting data; that is, the peti-
tion must include sufficient informa-
tion to scientifically support the re-
quest to modify the list. Such informa-
tion shall include:
(i) A list of all support documents;
(ii) Documentation of literature
searches conducted, including, but not
limited to, identification of the data-
base (s) searched, the search strategy,
, dates covered, and printed results;
(iii) Effects data (animal, human, and
environmental test data) indicating
the potential for death, injury, or seri-
ous adverse human and environmental
impacts from acute exposure following
an accidental release; printed copies of
the data sources, in English, should be
provided; and
(iv) Exposure data or previous acci-
dent history data, indicating the po-
tential for serious adverse human
health or environmental effects from
an accidental release. These data may
57
-------
§68.125
40 CFR Ch. I (7-1-99 Edition)
include, but are not limited to, phys-
ical and chemical properties of the sub-
stance, such as vapor pressure; mod-
eling results, including data and as-
sumptions used and model documenta-
tion; and historical accident data, cit-
ing data sources.
(h) Within 18 months of receipt of a
petition, the Administrator shall pub-
lish in the FEDERAL REGISTER a notice
either denying the petition or granting
the petition and proposing a listing.
§68.125 Exemptions.
Agricultural nutrients. Ammonia used
as an agricultural nutrient, when held
by farmers, is exempt from all provi-
sions of this part.
§ 68.130 List of substances.
(a) Regulated toxic and flammable
substances under section 112(r) of the
Clean Air Act are the substances listed
in Tables 1, 2, 3, and 4. Threshold quan-
tities for listed toxic and flammable
substances are specified in the tables.
(b) The basis for placing toxic and
flammable substances on the list of
regulated substances are explained in
the notes to the list.
TABLE 1 TO §68.130.—LIST OF REGULATED
Toxic SUBSTANCES AND THRESHOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE PREVENTION
[Alphabetical Order—77 Substances]
TABLE 1 TO §68.130.—LIST OF REGULATED
Toxic SUBSTANCES AND THRESHOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE PREVEN-
TION—Continued
[Alphabetical Order—77 Substances]
Chemical name
Acrolein [2-
Fropenal].
Acrylonitrile [2-
Propenenitrile].
Acrylyl chloride
[2-Propenoyl
chloride].
Allyl alcohol [2-
Propen-l-ol].
Allylamine [2-
Propen-l-
amine].
Ammonia (anhy-
drous).
Ammonia (cone
20% or greater).
Arsenous tri-
chloride.
Arsine
Boron trichloride
[Borane,
trichioro-].
Boron trifluoride
[Borane,
trifluoro-].
CAS No.
107-02-8
107-13-1
814-68-6
107-18-61
107-11-9
7664-41-7
7664-41-7
7784-34-1
7784-42-1
10294-34-5
7637-07-2
Threshold
quantity
(Ibs)
5,000
20,000
5,000
15,000
10,000
10,000
20,000
15,000
1,000
5,000
5,000
Basis for
listing
b
b
b
b
b
a, b
a, b
b
b
b
b
Chemical name
Boron trifluoride
compound with
methyl ether
(1:1) [Boron,
trifluoro [oxybis
[metane]]-, T-4-.
Bromine
Carbon disulfide
Chlorine
Chlorine dioxide
[Chlorine oxide
-------
Jit I «!!:!
lnl'Si''!1. , ' >ii'i Ml
IB
flU
if
111
I!
Environmental Protection Agency
TABLE i TO §68.130.^LIST OF REGULATED
, Toxic SUBSTANCES AND THRESHOLD QUAN-
, TIDES FOR ACCIDENTAL RELEASE PREVEN-
TION—Continued
[Alphabetical Order—77 Substances]
li, ,
"''"iii'tli
Chemical name
Hydrogen chlo-
ride (anhy-
drous) [Hydro-
chloric acid].
Hydrogen fluo-
ride/
Hydrofluoric
moid (cone 50%
or greater)
[Hydrofluoric
add].
Hydrogen sele-
rid*.
Hydrogen sulfida
Iron,
pentacarbonyt-
[Iron carbonyl
(Fe(CO)5),
rTB-5-11)-].
Isobutyronilrilo
'--*' [Propanenitrile,
2-methyl-].
i™'"" Isopropyl
"' " '•'** cfiforoformate
[Csrbonochlori-
'IfSt' .methyietnyl
"'"'MctHacrylonftrite
•• ' • P-
'Mi'i-iiiii1!:1 Propenenitrlle,
~" SSethyi-J. '
Methyl chloride
[Mtthane,
;"":; chlO;ro-].
Methyl
1 inilinti1 d-ioroforrhate
,i;r;":- [CarbonocBori-""
=::,' dfeacld, •.:
mathylestef].
,,,, Methy! hydrazine
:• is [Hydiazlne,
" '"'"""M'eSp'Isocyanate
[MeMiane,
teocyanato-].
Methyl rnercaplan
[Methanethlol].
""' ' Methyl
thiocyanate
fThiocyanlc
•S* IS3, methyl
;;'- • ™M«iykrichloros!l-
'" " aneJSilane,
" "" tricWoromethyl-
,. Lflli, J"
Nfcket carbonyl ...
Nitnc add (cono "
:'< ';t||ii 80% or greater).
•; i'i I] , Nitric oxids [Nitro-
CAS No.
7647-01-0
7664-39-3
7783-07^5
7783-06-4
13463-40-6
78-82-0
108-23-6
126-98-7
74-87-3
79-22-1
60-34-4
624-83-9
74-93-1
' 5S6-64-9
75-79-6
13463-39-3
7697-37-2
10102-43-9
Threshold
quantity
(IDS)*
5,000
1,000
500
10,000
2,500
20,000
15,000
10,000
10,000
5,000
15,000
10,000
10,000
20,000
5,000
1,000
15,000
10,000
Basis for
listing
a
a,b
b
a,b
b
b
b
b
a
b
b
a, b
b
b
b
b
b
b
','.'.'( ' , '.JfT.^'m.' " }'"!t'; fi'1 '•' >*&. ,-M^*.1
•; „.• • • , :,;: i ,• ,' -,:": iir m1' i n.1.^ \\ iv •• 'i* • •.• •:,,liiin.'»••
' ' §68.130
'••.I»j! •' ''S'-.'.tii&t ';itMiii.t'ill"i,;'-nv.:"!":'1(fl5i:''.
TABLE 1 TO §68.130.—LIST OF REGULATED
Toxic SUBSTANCES AND THRESHOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE PREVEN-
TION—Continued
[Alphabetical Order—77 Substances]
• '' 4; "*•'••''
':;,: till'" I !!«• .ill
Chemical name
Oleum (Fuming
Sulfuric acid)
[Sulfuric acid,
mixture with
sulfur trioxide]1.
Peraoetic acid
[Ethaneperoxoi-
c acid].
Perchloromethyl-
mercaptan
[Metnanesuffe-
nyl chloride,
trichloro-].
Phosgene [Car-
bonic dichlo-
ride].
Phosphlne
Phosphorus
oxychloride
[Phosphoryl
chloride].
Phosphorus tri-
chloride [Phos-
phorous tri-
chloride].
Piperidine
Propionitrile
[Propanenitrile].
Propyl
chloroformate
[Carbonochlori-
dic acid,
propylester].
Propyleneimine
,. [Aziridine, 2-
methyl-].
Propylene oxide
[Oxirane, meth-
yl-].
Sulfur dioxide
(anhydrous).
Sulfur tetra-
fluoride [Sulfur
fluoride (SF4),
(T-4)-].
Sulfur trioxtde
Tetramethyllead
[Plumbane,
tetramethyl-].
Tetranitro-
methane [Meth-
ane, tetranitro-].
Titanium tetra-
chloride [Tita-
nium chloride
(TiCI4) (T-4)-].
Toluene 2,4-
diisocyanate
[Benzene, 2,4-
diisocyanato-1-
methyl-]1.
CAS No.
8014-95-7
79-21-0
594-42-3
75-44-5
7803-51-2
10025-87-3
7719-12-2
110-89-4
107-12-0
109-61-5
75-55-8
75-56-9
7446-09-5
7783-60-0
7446-11-9
75-74-1
509-14-8
'" 7§§8t454>
584-84-9
fhVes'hoid
quantity
W?s)
' ' 10,000
ii
10,000
!
10,000
" 500
5,000
;s,ooo
15,000
15,000
10,000
15,000
•i 0,000
10,000
" nl
; s.ooo
2,500
I
f
f 0,000
•j 0,000
10,000
l.li
2,500
i"
. . j
10,000
Basis for
listing
e
b
b
a; 'fa
ill;lli|li(;;,1j ,
b
b
b
b
b
b
b
ill, "-!""
b
a, b
b
a,b
b
b
1 'r ,'
b
a
59
-; :Ji:;:;l ii
" "'Mi'j! 'pi hill'"
' I'lfl"'", Illi'llllil I I'll
,, * M. I iUJiS,, J
-------
§68.130
40 CFR Ch. I (7-1-99 Edition)
TABLE 1 TO §68.130.—LIST OF REGULATED
Toxic SUBSTANCES AND THRESHOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE PREVEN-
TION—Continued
[Alphabetical Order—77 Substances]
TABLE 1 TO §68.130.—LIST OF REGULATED
Toxic SUBSTANCES AND THRESHOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE PREVEN-
TION—Continued
[Alphabetical Order—77 Substances]
Chemical name
Toluene 2,6-
diisocyanate
[Benzene, 1,3-
diisocyanato-2-
methyl-]i.
Toluene
diisocyanate
(unspecified
isomer) [Ben-
zene, 1 ,3-
diisocyanatom-
ethy!-]1.
Trimethyichlorosi-
lane [Silane,
chlorotrimethyl-
CASNo.
91-08-7
26471-62-5
75-77-4
Threshold
quantity
(Ibs)'
10,000
10,000
10,000
Basis for
listing
a
a
b
Chemical name
Vinyl acetate
monomer [Ace-
tic acid ethenyl
ester].
CAS No.
108-05-4
Threshold
quantity
(Ibs)
15,000
Basis for
listing
b
1The mixture exemption in §6B.1l5(b)(1) does not apply to
the substance.
NOTE: Basis for Listing:
a Mandated for listing by Congress.
b On EHS list, vapor pressure 10 mmHg or greater.
c Toxic gas.
d Toxicity of hydrogen chloride, potential to release hydro-
gen chloride, and history of accidents,
e Toxicity of sulfur trioxide and sutfuric acid, potential to
release sulfur trioxide, and history of accidents.
TABLE 2 TO §68.130.—LIST OF REGULATED Toxic SUBSTANCES AND THRESHOLD QUANTITIES FOR
ACCIDENTAL RELEASE PREVENTION
[CAS Number Order—77 Substances]
CAS No.
55-00-0
57-14-7
60-34-4
67-66-3
74-87-3
74-90-8
74-93-1
75-15-0
75-21-8
75-44-5
75-55-8
75_56-9
75_74_1
75_77_4
75-78-s
75-79-6
78-82-0
79-21-0
79-22-1
91-08-7
106-89-8
107-02-8
107-11-9
107-12-0
107-13-1
107-15-3
107-18-6
107-30-2 .
108-05-4
108-23-6 .....
108-91-8
109-61-5
110-00-9
110-89-4
123-73-9
126-98-7
151-56-4
302-01-2
353-42-4
Chemical name
Carbon disuffide ....
Vinyl acetate monomer {Acetic acid ethenyl ester]
Crotonaldehyde, (E)- [2-Butenal, (E)-]
trifluoro[oxybis[methane]>, T-4-.
Threshold
quantity
(ibs)
15000
15000
15000
20 000
10 000
2 500
10000
20000
10000
500
10 000
10 000
10 000
10,000
5 000
5 000
20 000
10,000
5 000
10 000
20000
5 000
10 000
10 000
20000
20 000
15 ooo
5 000
15,000
15 000
15 000
15 000
5 000
15000
20000
10000
10 000
15 000
15 000
Basis for
listing
b
b
b
b
a b
b
b
a b
a b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
60
-------
Ill I III
lii IN
Environmental Protection Agency
§68.130
(|M'"f,! .,*" ,lr
li, ••! . i: ' '»!v!
TABLE 2 TO §68.130.—LIST OF REGULATED Toxic SUBSTANCES AND THRESHOLD QUANTITIES FOR
: -a is •'•,.'•,,.;':.•,;.!. ACCIDENTAL RELEASE PREVENTION—Continued
'••? ~— " ."'.i1 . ,"" ' ' [CAS Number Order—77 Substances]
!;! Iti *
506-77-4
503-14-8
542-88-1 ...................
556-64-9
, 584-64-9 .. , ,,,..
l^H":::::::::::::::;
IS^S "!™" "~
^u^^ 30^3
7446-09-5 .„„
7446-11-9 ...
7S50-45-0
7637-07-2 .....
7647-01-0 „....
7647-01-0 ..._. ,.
7664-39-3
7664-41-7 .....
7664-41-7 ........... .
7697-37-2
7719-12-2 ,....
"7726^95^6 '..I ....!"....
7782-41-4
7782-50-5 „ ..
7783-06-4 ................
7783-07-5 . ..... ..
7783-60-0 ....... ...
7784-34-1 _.„.. ..
7784-42-1
7803-51-2
8014-95-7
10049-04-4 , „ .
10102-43-9
10294-34-5
13463-39-3
13463—40-6
19287-45-7 ....
26471-62-5
Chemical name
Toluene 2,4-dlisocyanate [Benzene, 2,4-diisocyanato-l -methyl-]1
Perchloromethylmercaptan [Methanesulfenyl chloride, trichloro-j
Acrylyl chloride [2-Propenoyl chloride]
Sulfur trioxide
Hydrogen fluoride/Hydrofluoric acid (cone 50% or greater) [Hydrofluoric acid]
Phosphorus trichloride [Phosphorous trichloride]
Chlorine
Sulfur tetrafluoride [Sulfur fluoride (SF4) (T-4)-] ;
Arsine
Phosphine
Oleum (Fuming Sulfunc acid) [SuHuric acid, mixture with sulfur trioxide]1
Chlorine dioxide [Chlorine oxide (CIOz)]
Nitric oxide [Nitrogen oxide (NO)]
Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyI-
I)1-
Threshold
quantity
(ibs)
10 000
10,000
1,000
20000
10,000
10,000
10,000
5,000
20,000
5,000
10,000
2,500
5,000
15,000
5,000
1,000
10,000
20,000
15,000
15,000
10,000
1,000
2,500
10,000
" 500
2,500
15,000
!l,000
5,000
10,000
5,000
1 000
ib.ooo
5,000
1,000
2500
2,500
10,000
Basis for
listing
b
b
b
a
b
a, b
b
b
a, b
a, b
b
b
d
a, b
a, b
a b
b
b
a, b
b
a, b
a, b
b
b
b
b
b
e
b
b
b
b
b
b
a
HI
If I ,,,:,
if: i
SI:!
.. ........ ,
...... ' "
,: ft
'The mixture exemption in §68.115(b)(1) does not apply to the substance.
NOTE: Basis for Listing:
a Mandated for listing by Congress.
b On EHS list, vapor pressure 10 mmHg or greater.
c Toxic gas.
d Toxfcity of hydrogen chloride, potential to release hydrogen chloride, and history of accidents.
o Toiecity of sulfur trioxide and sulfuric acid, potential to release sulfur trioxide, and history of accidents.
, : ill! : ; 5 •-, n ! s. ..... '"• '•••••.• n* < ••!. "-i; • ' ,: !i: •: . k,", :•; \\ XK ' : • •,: :j "( • '
BLE 3 TO §68.130.—LIST OF REGULATED FLAMMABLE SUBST
II! .•&••:'" Ic • -'I''" -'» ' FOR ^c'c-|D-g^[_ RELEASE"PREVE
•HBU" is :,,"fll!!i!':im.fC1!1'
SUBSTANCES AND THRESHOLD QUANTITIES
[Alphabetical Order—63 Substances]
Chemical name
Acataldehyda
, Acetylene [Ethyne] «...«.„
1,3-Butadiene . ,
2-Butena
Butene
2-Butene-trans [2-Birtene (E)]
2-ChicroDfoovEen6 n-Prooene. 2-chloro-l
i • ' iiis1*:,,,*1'!! "v,
CAS No.
75-07-0
74_g6_2
598-73-2
106-9&-0
106-97-5
•J06-98-9
107-01—7
25167-67-3
590_1 8-1
I24_64_e
463-58-1
7791-21-1
557-98-2
Threshold
quantity
(Ibs)
10,000
10,000
1 0,000
10,000
io.ooo
10,000
10 000
10,000
10000
ib ooo
10,000
10,000
10.000
Basis for
listing
f
f
f
f
f
f
f
f
f
f
a
61
-------
§68.130
40 CFR Ch. I (7-1-99 Edition)
TABLE 3 TO §68.130.—LIST OF REGULATED FLAMMABLE SUBSTANCES AND THRESHOLD QUANTITIES
FOR ACCIDENTAL RELEASE PREVENTION—Continued
[Alphabetical Order—63 Substances]
Chemical name
Ethylene [Ethene]
Ethyl ether [Ethane 1 1'-oxybis-]
3-Methyl-1 -butane
2-Methyl-1-butene
Vinyl methyl ether [Ethene, methoxy-]
CAS No.
590-21-6
460-19-5
75-19-4
4109-96-0
75-37-6
124-40-3
463-82-1
74-84-0
107-00-6
75-04-7
75-00-3
74-85-1
60-29-7
75-08-1
109-95-5
1333-74-0
75-28-5
78-78-4
78-79-5
75-31-0
75-29-6
74-82-8
74-89-5
563-45-1
563-46-2
115-10-6
107-31-3
115_f|_7
504-60-9
109-66-0
109-67 1
646-04-8
627-20-3
463-49-0
74-98-6
115-07-1
74_gg_7
7803-62-5
116-14-3
75-76-3
1 0025-78-2
79-38-9
75-50-3
689-97-4
75-01-4
109-92-2
75-02-5
75-35-4
75-38-7
107-25-5
Threshold
quantity
(lbs)y
10,000
10,000
10,000
10,000
10,000
10000
10,000
10,000
10,000
10000
10 000
10,000
10000
10000
10000
10,000
10,000
10,000
10,000
10000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10000
10,000
10,000
10,000
10000
10000
10,000
10,000
10,000
10000
10,000
10 000
10,000
10000
10000
10,000
10000
10,000
10,000
10,000
10,000
Basis for
listing
f
f
f
f
f
f
f
f
f
f
f
f
f
f
g
f
f
f
f
f
f
f
g
f
f
f
a, f
f
f
f
NOTE: Basis for Listing:
a Mandated for listing by Congress.
f Flammable gas.
g Volatile flammable liquid.
TABLE 4 TO §68.130.—LIST OF REGULATED FLAMMABLE SUBSTANCES AND THRESHOLD QUANTITIES
FOR ACCIDENTAL RELEASE PREVENTION
[CAS Number Order—63 Substances]
CAS No.
60-29-7
74-S2-8
74-04-0
74-85-1
Methane . .
Ethvlene FEthenel ..
Chemical name
CAS No.
60-29-7
74-82-8
74-84-0
74-85-1
Threshold
quantity
(Ibs)
10000
10,000
10 000
10,000
Basis for
listing
f
f
f
62
-------
Environmental Protection Agency
„! .; , «,», •: '.!,:, , , > f,,:,=e • .i/ t >"
§68.130
TABLE 4 TO §6&130.—LIST OF REGULATED FLAMMABLE SUBSTANCES AND THRESHOLD QUANTITIES
! ' FOR ACCIDENTAL RELEASE PREVENTION—Continued
:;: : [CAS Number Order—63 Substances]
III, I1 ' I!!!1 VII1'III
I, < il«: ,' lit- Illlllinvi i'
"il;,I'f'..l' f ' [!(!',
CAS No, .'
III :::,"\ .:'
74-86-2 .„„!..„„
74-89-5 ...„.
74-98-6
74-99-7 "...~,,... .
75-00-3
75-O1-4 _
7S-02-5
75-04-7 „...
75-07-0
•i 75-08-1 _
75-19-4
75-28-5 ....„„...„„ .
• ;j 75-39-6 .
"i;;;, 75-31-0 — ..-
"I I" i^j_g7~| • ." i.
75-38-7 .
«£ia"-
75-76-3 ..._.
-••78-7$3 ..........
78-79-5
:n 79-38-9
• i 106-97-8
106-98-9 .... .
196-99-0
••- 107-00-6
,1,107-01-7 ....
'iiiiiii*"'^™™
107-31^3,,...
109-67-1
109-92-2 .........
109-95-5 .„
115-07-1
115-10-6 ....... .... ...
'|^gj|^^
116-14-3 ...............
W'^gO-ig-S '
463-49-0 . .. .
483-58-1 „._ .„„
504-6&-9
563-45-1 .
5g£^4"£l2 ' '
sao-18-1 „
590-21-6 . ...._._...
598-73-2 .... . .
624-64-6 „
627-20-3
646-04-8
689-97-4 ...................
1333-74-0 ™.
4109-36-0
7791-21-1 .
10025-78-2
,, 25167-67-3 , „„
Chemical name
Acetylene [Ethyne] «
Ethyl chloride [Ethane chloro-]
Vinyl fluoride [Ethene, fluoro-]
Vmylidene chloride [Ethene 1 1-dichloro-]
Drfluoroethane [Ethane, 1,1-difluoro-]
Vinylldene fluoride [Ethene, 1,1-drfluoro-]
Butane
1»3-Butad(ene ,
Ethyl acetylene [1-Butyne] ....„....„ ..'. I™.....'...™.'
2-Butene
Methyl formate [Formic acid, methyl ester]
1-Pentene
Vinyl ethyl ether [Ethene ethoxy-]
1 ,3-Pontadiene w ,
3-MethyM-butene „
2-MethyM-butene .. .
2-Pentene, (Z)-
2-Pentene, (Ej-
Trichlorosilano [Silane.trichloro-]
Butane
CAS No.
74-86-2
74-89-5
74_gg—7
75-00-3
75-01-4
75-02-5
75-04-7
75-07-0
75-08-1
75—19-4
75-28-5
75-29-6
75-31-0
75-35-4
75-37-6
75-38-7
75-50-3
75-76-3
7B-78-4
78-79-5
79-38-9
106-97-8
106-98-9
106-99-0
107-OO-6
107-01-7
107-25-5
107-31-3
109-66-0
109-67-1
109-92-2
109-95-5
115-07-1
115-10-6
115-11-7
116-14-3
124-40-3
460-19-5
463-49-0
463-58—1
463-82-1
504-60-9
557-98-2
563-45-1
563-46-2
590-18-1
590121-6
598-73-2
624-64-6
627-20^3
689-97-4
1333-74-0
4109-96-0
7791-21—1
7803-62-5
10025-78-2
25167-67-3
Threshold
quantity
(IDS)
10,000
10,000
10 000
10 000
10 ooo
10 000
10,000
10 000
10000
10 000
10 000
10 000
10 000
10 000
10 000
10,000
10,000
10 000
10,000
10000
10 000
10 000
10,000
10,000
16,000
16,000
10,000
10 000
10,000
10,000
10,000
16,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10 000
10,000
10,000
10,000
16000
10000
10000
10000
idooo
10,000
16,000
i6.,ooo
10 000
10 000
19,000
10000
10 060
10,000
10,000
Basis for
listing
f
f
f
f
f
a f
f
f
f
f "
f
f
f
f
f
f
f
f
f
f
g
g
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
g
g
f
f
f
f
g
1:1
Ji
, _ Mandated .for listing by Congress. f Flammable gas. g Volatile flammable liquid.
I FR 4493. Jan 31, 1994 Redesignated at 61 FR 31717, June 20, 1996, as amended at 62 FR 45132,
ig. 25, 1997: 63 FR 645. Jan. 6, 1998]
««: " _ :,. •. i1'"; ; - ,(fli; i i II i i I
I-'I'S I1" . ,' ;(l, .1' " '' I i ll|
"K i ',t"i"; '
..ilii
-------
§68.150
40 CFR Ch. I (7-1-99 Edition)
Subpart G—Risk Management
Plan
SOURCE: 61 FR 31726, June 20, 1996, unless
otherwise noted.
§68.150 Submission.
(a) The owner or operator shall sub-
mit a single RMP that includes the in-
formation required by §§68.155 through
68.185 for all covered processes. The
RMP shall be submitted in a method
and format to a central point as speci-
fied by EPA prior to June 21, 1999.
(b) The owner or operator shall sub-
mit the first RMP no later than the
latest of the following dates:
(1) June 21, 1999;
(2) Three years after the date on
which a regulated substance is first
listed under §68.130; or
(3) The date on which a regulated
substance is first present above a
threshold quantity in a process.
(c) Subsequent submissions of RMPs
shall be in accordance with §68.190.
(d) Notwithstanding the provisions of
§§68.155 to 68.190, the RMP shall ex-
clude classified information. Subject to
appropriate procedures to protect such
information from public disclosure,
classified data or information excluded
from the RMP may be made available
in a classified annex to the RMP for re-
view by Federal and state representa-
tives who have received the appro-
priate security clearances.
(e) Procedures for asserting that in-
formation submitted in the RMP is en-
titled to protection as confidential
business information are set forth in
§§68.151 and 68.152.
[61 FR 31726, June 20, 1996, as amended at 64
FR 979, Jan. 6, 1999]
§68.151 Assertion of claims of con-
fidential business information.
(a) Except as provided in paragraph
(b) of this section, an owner or oper-
ator of a stationary source required to
report or otherwise provide informa-
tion under this part may make a claim
of confidential business information
for any such information that meets
the criteria set forth in 40 CFR 2.301.
(b) Notwithstanding the provisions of
40 CFR part 2, an owner or operator of
a stationary source subject to this part
may not claim as confidential business
information the following information:
(1) Registration data required by
§68.160(b)(l) through (b)(6) and (b)(8),
(b)(10) through (b)(13) and NAICS code
and Program level of the process set
forthin§68.160(b)(7);
(2) Offsite consequence analysis data
required by § 68.165 (b) (4), (b)(9), (b)(10),
(b)(ll), and (b)(12).
(3) Accident history data required by
§68.168;
(4) Prevention program data required
by §68.170(b), (d), (e)(l), (f) through (k);
(5) Prevention program data required
by §68.175(b), (d), (e)(l), (f) through (p);
and
(6) Emergency response program data
required by §68.180.
(c) Notwithstanding the procedures
specified in 40 CFR part 2, an owner or
operator asserting a claim of CBI with
respect to information contained in its
RMP, shall submit to EPA at the time
it submits the RMP the following:
(1) The information claimed con-
fidential, provided in a format to be
specified by EPA;
(2) A sanitized (redacted) copy of the
RMP, with the notation "CBI" sub-
stituted for the information claimed
confidential, except that a generic cat-
egory or class name shall be sub-
stituted for any chemical name or
identity claimed confidential; and
(3) The document or documents sub-
stantiating each claim of confidential
business information, as described in
§68.152.
[64 FR 979, Jan. 6, 1999]
§68.152 Substantiating claims of con-
fidential business information.
(a) An owner or operator claiming
that information is confidential busi-
ness information must substantiate
that claim by providing documentation
that demonstrates that the claim
meets the substantive criteria set forth
in 40 CFR 2.301.
(b) Information that is submitted as
part of the substantiation may be
claimed confidential by marking it as
confidential business information. In-
formation not so marked will be treat-
ed as public and may be disclosed with-
out notice to the submitter. If informa-
tion that is submitted as part of the
substantiation is claimed confidential,
64
-------
its I
Environmental Protection Agency
"the owner or operator must provide a
sanitized and unsanitized version of the
substantiation.
(c) The owner, operator, or senior of-
ficial with management responsibility
I of the stationary source shall sign a
"certification that the signer has per-
sonally examined the information sub-
Snitted and that based on inquiry of the
persons who compiled the information,
"the information is true, accurate, and
complete, and that those portions of
the substantiation claimed as confiden-
tial business information would, if dis-
closed, reveal trade secrets or other
confidential business information.
III! ilitf ' , : ,1'; •", • : . • -
[64 FR 980. Jan. 6, 1999]
l|||l'l 11 ||l 11 | ,;,;,' :,V '
§68.155 Executive summary.
The owner or operator shall provide
in the RMP an executive summary that
includes a brief description of the fol-
lowing elements:
(a) The accidental release prevention
and emgrgency response policies at the
i;' stationary source;
(b) The stationary source and regu-
j^ted^substances handled;
(cj 'The worst-case release scenario(s)
and the alternative release scenario(s),
including administrative controls and
mitigation measures to limit the dis-
tances for each reported scenario;
(d) The general accidental release
prevention program and chemical-spe-
cific prevention steps;
(e) The five-year accident history;
(f) The emergency response program;
and
(g) Planned changes to improve safe-
ty.
§68.160 Registration.
(a) The owner or operator shall com-
plete a single registration form and in-
clude it in the RMP. The form shall
cover all regulated substances handled
in covered processes.
(b) The registration shall include the
,' ripllowing data:
(1) Stationary source name, street,
city, county, state, zip code, latitude
arid longitude, method for obtaining
latitude and longitude, and description
of location that latitude and longitude
represent;
(2) The stationary source Dun and
Bradstreet number;
§68.165
(3) Name and Dun and Bradstreet
number of the corporate parent com-
pany;
(4) The name, telephone number, and
mailing address of the owner or oper-
ator;
(5) The name and title of the person
or position with overall responsibility
for RMP elements and implementation;
(6) The name, title, telephone num-
ber, and 24-hour telephone number of
the emergency contact;
(7) For each covered process, the
name arid CAS number of each regu-
lated substance held above the i thresh-
old quantity' in the" process,"the"max-
imum quantity of each regulated sub-
stanqg, or iirniiixtureiiiiiin the, process (in
pounds) "to two' ^gnifi'carit digits, the
five- or six-digit NAICS code that most
closely corresponds to the process, and
the Program level of the process;
(8) The stationary source EPA identi-
fier;
(9) The number of full-time employ-
ees at the stationary source;
(10) Whether the stationary source is
subject to 29 CFR 1910.119;
(11) Whether the stationary source is
subject to 40 CFR part 355;
(12) If the stationary source has a
CAA Title V operating permit, the per-
mit number; and
(13) The date of the last safety in-
spection of the stationary source by a
Federal, state, or local government
agency and the identity of the inspect-
ing entity.
(14) Source or Parent Company E-
Mail Address (Optional);
(15) Source Homepage address (Op-
tional)
(16) Phone number at the source for
public inquiries (Optional);
(17) Local Emergency Planning Com-
mittee (Optional);
(18) OSHA Voluntary Protection Pro-
gram status (Optional);
[61 FR 31726, June 20, 1996, as amended at 64
FR 980, Jan. 6, 1999]
§68.165 Offsite consequence analysis.
(a) The owner or operator shall sub-
mit in the RMP information:
(1) One worst-case release scenario
for each Program 1 process; and
(2) For Program 2 and 3 processes,
one worst-case release scenario to rep-
resent all regulated toxic substances
65
-------
§68.168
40 CFR Ch. I (7-1-99 Edition)
held above the threshold quantity and
one worst-case release scenario to rep-
resent all regulated flammable sub-
stances held above the threshold quan-
tity. If additional worst-case scenarios
for toxics or flammables are required
by §68.25(a)(2)(iii), the owner or oper-
ator shall submit the same information
on the additional scenario (s). The
owner or operator of Program 2 and 3
processes shall also submit information
on one alternative release scenario for
each regulated toxic substance held
above the threshold quantity and one
alternative release scenario to rep-
resent all regulated flammable sub-
stances held above the threshold quan-
tity.
(b) The owner or operator shall sub-
mit the following data:
(1) Chemical name;
(2) Percentage weight of the chemical
in a liquid mixture (toxics only);
(3) Physical state (toxics only);
(4) Basis of results (give model name
if used);
(5) Scenario (explosion, fire, toxic gas
release, or liquid spill and evapo-
ration);
(6) Quantity released in pounds;
(7) Release rate;
(8) Release duration;
(9) Wind speed and atmospheric sta-
bility class (toxics only);
(10) Topography (toxics only);
(11) Distance to endpoint;
(12) Public and environmental recep-
tors within the distance;
(13) Passive mitigation considered;
and
(14) Active mitigation considered (al-
ternative releases only);
[61 FR 31726, June 20, 1996, as amended at 64
FR 980, Jan. 6, 1999]
§68.168 Five-year accident history.
The owner or operator shall submit
in the RMP the information provided
in §68.42(b) on each accident covered by
§68.42(a).
§ 68.170 Prevention program/Program
2.
(a) For each Program 2 process, the
owner or operator shall provide in the
RMP the information indicated in
paragraphs (b) through (k) of this sec-
tion. If the same information applies to
more than one covered process, the
owner or operator may provide the in-
formation only once, but shall indicate
to which processes the information ap-
plies.
(b) The five- or six-digit NAICS code
that most closely corresponds to the
process.
(c) The name(s) of the chemical (s)
covered.
(d) The date of the most recent re-
view or revision of the safety informa-
tion and a list of Federal or state regu-
lations or industry-specific design
codes and standards used to dem-
onstrate compliance with the safety in-
formation requirement.
(e) The date of completion of the
most recent hazard review or update.
(1) The expected date of completion
of any changes resulting from the haz-
ard review;
(2) Major hazards identified;
(3) Process controls in use;
(4) Mitigation systems in use;
(5) Monitoring and detection systems
in use; and
(6) Changes since the last hazard re-
view.
(f) The date of the most recent review
or revision of operating procedures.
(g) The date of the most recent re-
view or revision of training programs;
(1) The type of training provided—
classroom, classroom plus on the job,
on the job; and
(2) The type of competency testing
used.
(h) The date of the most recent re-
view or revision of maintenance proce-
dures and the date of the most recent
equipment inspection or test and the
equipment inspected or tested.
(i) The date of the most recent com-
pliance audit and the expected date of
completion of any changes resulting
from the compliance audit.
(j) The date of the most recent inci-
dent investigation and the expected
date of completion of any changes re-
sulting from the investigation.
(k) The date of the most recent
change that triggered a review or revi-
sion of safety information, the hazard
review, operating or maintenance pro-
cedures, or training.
[61 FR 31726, June 20, 1996, as amended at 64
FR 980, Jan. 6, 1999]
66
-------
tm ""'i m W?FI i -TINE !ii iiiti ™*st mmm]
!.*!' If '!,?"«
'•: a*.
'?!&»,•,.**.,''' a .
I! 11 Tii'f'if. s, f!V
" ' n1,1!" <<> jlllhililL'ii' i :!,'!'",,U1
••'li! ili!i ."iiilili
itll
! ;;;
i lii:
Hill! ,
Environmental Protection Agency
§ 68.175 Prevention program/Program
"III- "(a) For each Program 3 process, the
owner or operator shall provide the in-
jlfornjation ^indicated in paragraphs (b)
ligirojigh (p)' of "this section. If the same
;|;;Jnfgrmatipn i applies to more than one
covered process, the owner or operator
l; isp'inay ' provide the information only
once, but shall indicate tp which proc-
"^ses^the iriformation applies.
(b) The five- or six-digit NAICS code
""ijrthat most closely corresponds to the
process.
•" ~' (c| "The name(s) of "'the substance(s)
'"'"« covered.
(d) The date on which the safety in-
formation was last reviewed or revised.
(e) The date of completion of the
!!!'!'!: mosE recent PHA or update and the
"" ••"lechnique used.
(1) The expected date of completion
of any changes resulting from the PHA;
(2) Major hazards identified;
(3) Process controls in use;
(4) Mitigation systems in use;
(5) Monitoring and detection systems
in use; and
(6) Changes since the last PHA.
(f) The date of the most recent review
or revision of operating procedures.
(g) The date of the most recent re-
vieWbrrevision of training programs;
(1) The type of training provided—
classroom, classroom plus on the job,
on the job; and
(2) The type of competency testing
used.
(h) The date of the most recent re-
view or revision of maintenance proce-
..', " dures and the date of the most recent
equipment inspection or test and the
equipment inspected or tested.
":"::,"'(i) The date of the most recent
.:"„;,„ change that triggered management of
' change procedures and the date of the
most1 recent'"review"'or revision of man-
agement of change procedures.
Q) The date of the most recent pre-
startup review.
(k) The date of the most recent com-
pliance audit and the expected date of
completion of any changes resulting
from the compliance audit;
(1) The date of the most recent inci-
dentinvestigation and the expected
date of completion of any changes re-
sulting from the investigation;
§68.185
(m) The date of the most recent re-'
view or revision of employee participa-
tion plans;
(n) The date of the most recent re-
view or revision of hot work permit
procedures;
(o) The date of the most recent re-
view or revision of contractor safety
procedures; and
(p) The date of the most recent eval-
uation of contractor safety perform-
ance.
[61 FR 31726, June 20. 1996, as amended at 64
FR 980, Jan. 6, 1999]
§ 68.180 Emergency response program.
(a) The owner or operator shall pro-
vide in the RMP the following informa-
tion:
(1) Do you have a written emergency
response plan?
(2) Does the plan include specific ac-
tions to be taken in response to an ac-
cidental releases of a regulated sub-
stance?
(3) Does the plan include procedures
for informing the public and local
agencies responsible for responding to
accidental releases?
(4) Does the plan include information
on emergency health care?
(5) The date of the most recent re-
view or update of the emergency re-
sponse plan;
(6) The date of the most recent emer-
gency response training for employees.
(b) The owner or operator shall pro-
vide the name and telephone number of
the local agency with which emergency
response activities and the emergency
response plan is coordinated.
(c) The owner or operator shall list
other Federal or state emergency plan
requirements to which the stationary
source is subject.
[61 FR 31726, June 20. 1996, as amended at 64
FR 980, Jan. 6, 1999]
§ 68.185 Certification.
(a) For Program 1 processes, the
owner or operator shall submit in the
RMP the certification statement pro-
vided in §68.12(b) (4).
(b) For all other covered processes,
the owner or operator shall submit in
the RMP a single certification that, to
67
ilia;: 1 , ,'j'MI1 IK'S ,. .. i
•: •; !«"r S-WM • -""lit! i
iihii ' 'fl1; ' i i,' ,,'s" „!' r ,11:
i! I Stiii; '¥*
i"1," " 1 "lillllllll .1.
-------
§68.190
40 CFR Ch. I (7-1-99 Edition)
the best of the signer's knowledge, in-
formation, and belief formed after rea-
sonable inquiry, the information sub-
mitted is true, accurate, and complete.
§68.190 Updates.
(a) The owner or operator shall re-
view and update the RMP as specified
in paragraph (b) of this section and
submit it in a method and format to a
central point specified by EPA prior to
June 21, 1999.
(b) The owner or operator of a sta-
tionary source .shall revise and update
the RMP submitted under §68.150 as
follows:
(1) Within five years of its initial sub-
mission or most recent update required
by paragraphs (b)(2) through (b)(7) of
this section, whichever is later.
(2) No later than three years after a
newly regulated substance is first list-
ed by EPA;
(3) No later than the date on which a
new regulated substance is first
present in an already covered process
above a threshold quantity;
(4) No later than the date on which a
regulated substance is first present
above a threshold quantity in a new
process;
(5) Within six months of a change
that requires a revised PHA or hazard
review;
(6) Within six months of a change
that requires a revised offsite con-
sequence analysis as provided in §68.36;
and
(7) Within six months of a change
that alters the Program level that ap-
plied to any covered process.
(c) If a stationary source is no longer
subject to this part, the owner or oper-
ator shall submit a revised registration
to EPA within six months indicating
that the stationary source is no longer
covered.
Subpart H—Other Requirements
SOURCE: 61 FR 31728, June 20, 1996, unless
otherwise noted.
§ 68.200 Recordkeeping.
The owner or operator shall maintain
records supporting the implementation
of this part for five years unless other-
wise provided in subpart D of this part.
§68.210 Availability of information to
the public.
(a) The RMP required under subpart
G of this part shall be available to the
public under 42 U.S.C. 7414(c).
(b) 'The disclosure of classified infor-
mation by the Department of Defense
or other Federal agencies or contrac-
tors of such agencies shall be con-
trolled by applicable laws, regulations,
or executive orders concerning the re-
lease of classified information.
§68.215 Permit content and air per-
mitting authority or designated
agency requirements.
(a) These requirements apply to any
stationary source subject to this part
68 and parts 70 or 71 of this chapter.
The 40 CFR part 70 or part 71 permit for
the stationary source shall contain:
(1) A statement listing this part as
an applicable requirement;
(2) Conditions that require the source
owner or operator to submit:
(i) A compliance schedule for meet-
ing the requirements of this part by
the date provided in §68.10(a) or;
(ii) As part of the compliance certifi-
cation submitted under 40 CFR
70.6(c)(5), a certification statement
that the source is in compliance with
all requirements of this part, including
the registration and submission of the
RMP.
(b) The owner or operator shall sub-
mit any additional relevant informa-
tion requested by the air permitting
authority or designated agency.
(c) For 40 CFR part 70 or part 71 per-
mits issued prior to the deadline for
registering and submitting the RMP
and which do not contain permit condi-
tions described in paragraph (a) of this
section, the owner or operator or air
permitting authority shall initiate per-
mit revision or reopening according to
the procedures of 40 CFR 70.7 or 71.7 to
incorporate the terms and conditions
consistent with paragraph (a) of this
section.
(d) The state may delegate the au-
thority to implement and enforce the
requirements of paragraph (e) of this
section to a state or local agency or
agencies other than the air permitting
authority. An up-to-date copy of any
delegation instrument shall be main-
tained by the air permitting authority.
68
-------
"! U'lU'I.' > ;|||||||||||||!il"li "lip'ii", I\\"HK ll
"ii iff'ML <„,
"!iHi, •!, ,,!!i!"i"i.,,
'Ki,:.(j5) The presence of specific regulated
substances;
• (6) The hazards identified in the
RMP; and
(7) A plan providing for neutral, ran-
dom oversight.
I
(c) Exemption from audits. A sta-
tionary source with a Star or Merit
ranking under OSHA's voluntary pro-
tection program shall be exempt from
audits under paragraph (b) (2) and (b) (7)
of this section.
(d) The implementing agency shall
have access to the stationary source,
supporting documentation, and any
area where an accidental release could
occur.
(e) Based on the audit, the imple-
menting agency may issue the owner
or operator of a stationary source a
written preliminary determination of
necessary revisions to the stationary
source's RMP to ensure that the RMP
meets the criteria of subpart G of this
part. The preliminary determination
shall include an explanation for the
basis for the revisions, reflecting indus-
try standards and guidelines (such as
AIChE/CCPS guidelines and ASME and
API standards) to the extent that such
standards and guidelines are applica-
ble, and shall include a timetable for
their implementation.
(f) Written response to a preliminary de-
termination. (1) The owner or operator
shall respond in writing to a prelimi-
nary determination made in accord-
ance with paragraph (e) of this section.
The response shall state the owner or
operator will implement the revisions
contained in the preliminary deter-
mination in accordance with the time-
table included in the preliminary de-
termination or shall state that the
owner or operator rejects the revisions
in whole or in part. For each rejected
revision, the owner or operator shall
explain the basis for rejecting such re-
vision. Such explanation may include
substitute revisions.
(2) The written response under para-
graph (f)(l) of this section shall be re-
ceived by the implementing agency
within 90 days of the issue of the pre-
liminary determination or a shorter
period of time as the implementing
agency specifies in the preliminary de-
termination as necessary to protect
public health and the environment.
Prior to the written response being due
and upon written request from the
owner or operator, the implementing
agency may provide in writing addi-
tional time for the response to be re-
ceived.
69
11 i i i
III I
ill
11
ni
-------
§68.220
(g) After providing the owner or oper-
ator an opportunity to respond under
paragraph (f) of this section, the imple-
menting agency may issue the owner
or operator a written final determina-
tion of necessary revisions to the sta-
tionary source's RMP. The final deter-
mination may adopt or modify the re-
visions contained in the preliminary
determination under paragraph (e) of
this section or may adopt or modify
the substitute revisions provided in the
response under paragraph (f) of this
section. A final determination that
adopts a revision rejected by the owner
or operator shall include an expla-
nation of the basis for the revision. A
final determination that fails to adopt
a substitute revision provided under
paragraph (f) of this section shall in-
clude an explanation of the basis for
finding such substitute revision unrea-
sonable.
40 CFR Ch. I (7-1-99 Edition)
(h) Thirty days after completion of
the actions detailed in the implemen-
tation schedule set in the final deter-
mination under paragraph (g) of this
section, the owner or operator shall be
in violation of subpart G of this part
and this section unless the owner or
operator revises the RMP prepared
under subpart G of this part as required
by the final determination, and sub-
mits the revised RMP as required
under §68.150.
(i) The public shall have access to the
preliminary determinations, responses,
and final determinations under this
section in a manner consistent with
§68.210.
(j) Nothing in this section shall pre-
clude, limit, or interfere in any way
with the authority of EPA or the state
to exercise its enforcement, investiga-
tory, and information gathering au-
thorities concerning this part under
the Act.
70
-------
jlf'lili1:!! 'I1:. I
Environmental Protection Agency
Pt.68,App.A
iliJ'!"!' 'I . 'Ill'•'
• WllWItt '1 •• lii,:
-------
APPENDIX A TO PART 68—TABLE OF Toxic ENDPOINTS—Continued
[As defined In §68.22 of this part]
CAS No.
74-87-3
79-22-1
60-34-4
624-83-9 .
74_93_1
556-64-9
75-79-6
13463-39-3
7697-37-2
10102-43-9
8014-95-7
79-21-0
594_42-3
75-44-5
7803-51-2
10025-87-3
7719-12-2
110-89-4
107-12-0
109-61-5
75-55-8
75-56-9 ,
7446-09-5
7783-60-0
7446-11-9
75-74-1
509-14-8
7750-45-0
584-84-9
91-08-7 ;.......„...
26471-62-5
75-77-4 . ...
108-05-4
Chemical name
Methyl chloride [Methane, chloro-]
Methyl chloroformate [Carbonochloridic acid, methylester]
Methyl hydrazlna [Hydrazlne, methyl-]
Methyl isocyanate [Methane, isocyanato-]
Methyl mercaptan [Methanethio!] .
Methyl thlocyanate [Thlocyanlc acid, methyl ester]
Methyltrichlorosilane [Silane, trichloromethyl-]
Nickel carbonyl
Nitric acid (cone 80% or greater)
Nitric oxide [Nitrogen oxide (NO)]
Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide]
Peracetic add [Ethaneperoxoic acfdj
Perchforomethylmercaptan [Methanesuifenyl chloride, triehloro-J
Phosgene [Carbonic dichloride]
Phosphine ....
Phosphorus oxychloride [Phosphoryl chloride]
Phosphorus trichloride [Phosphorous trichloride]
Piperidine ;
Propionltrile [Propanenitrile] . .
Propyl chloroformate [Carbonochloridic acid, propylester]
Propyleneimine [Aziridlne, 2-methyl-]
Propylene oxide [Oxlrane, methyl-]
Sulfur dioxide (anhydrous)
Sulfur tetrafluoride [Sulfur fluoride (SF4), (T-4)-]
Sulfur trioxide
Tetramethyllead [Plumbane, tetramethyl-] . .
Tetranitromethane [Methane, tetranitro-]
Titanium tetrachloride [Titanium chloride (TiCI4) (T-4)-] , . .,
Toluene 2,4-dilsocyanate [Benzene, 2,4-diisocyanato-1 -methyl-] . , .
Toluene 2,6-dBsocyanate [Benzene, "1,3-diisocyanato-2-methyl-]
Toluene dllsocyanate (unspecified isomer) [Benzene, 1,3-dlIsocyanatomethyl-]
Trimethylchlorosllane [Silane, chlorotrimethyl-] ,
Vinyl acetate monomer [Acetic acid ethenyl ester]
Toxic end-
point (mg/L)
0.26
0»
00
O
•n
JO
O
•O
[61 FR 31T29, June 20, 1996, as amended at 62 FR 45132, Aug. 25, 1997]
I
-------
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JII
-------
Federal Register/Vol. 65, No. 49/Monday, March 13, 2000/Rules and Regulations
13243
finding that notice and public procedure
is impracticable, unnecessary or
contrary to the public interest. This
determination must be supported by a
brief statement (5 U.S.C. 808(2)).
As stated previously, we have made
such a good cause finding, including the
reasons therefore, and established an
effective date of March 13, 2000. The
EPA will submit a report containing this
rule and other required information to
the U.S. Senate, the U.S. House of
Representatives, and the Comptroller
General of the United States prior to
publication of the rule in the Federal
Register. This action is not a "major
rule" as defined by 5 U.S.C. 804(2).
List of Subjects in 40 CFR Part 60
Environmental protection,
Administrative practice and procedure,
Air pollution control, Intergovernmental
relations, Nitrogen oxides,
Recordkeeping and reporting
requirements.
Dated: March 2, 2000.
Robert Perciasepe,
Assistant Administrator, Office of Air and
Radiation.
For the reasons set out in the
preamble, title 40, chapter I, part 60, of
the Code of Federal Regulations is
amended as follows:
PART 60—[AMENDED]
1. The authority citation for part 60
continues to read as follows:
Authority: 42 U.S.C. 7401-7601.
Subpart Db—Standards of
Performance for Industrial-
Commercial-lnstitutional Steam
Generating Units
2. Section 60.49b is amended by
revising paragraph (s) and adding
paragraph (w) to read as follows:
§ 60.49b Reporting and recordkeeping
requirements.
*****
(s) Facility specific nitrogen oxides
standard for Cytec Industries Fortier
Plant's C.AOG incinerator located in
Westwego, Louisiana:
(1) Definitions.
Oxidation zone is defined as the
portion of the C.AOG incinerator that
extends from the inlet of the oxidizing
zone combustion air to the outlet gas
stack.
Reducing zone is defined as the
portion of the C.AOG incinerator that
extends from the burner section to the
inlet of the oxidizing zone combustion
air.
Total inlet air is defined as the total
amount of air introduced into the
C.AOG incinerator for combustion of
natural gas and chemical by-product
waste and is equal to the sum of the air
flow into the reducing zone and the air
flow into the oxidation zone.
(2) Standard for nitrogen oxides, (i)
When fossil fuel alone is combusted, the
nitrogen oxides emission limit for fossil
fuel in § 60.44b(a) applies.
(ii) When natural gas and chemical
by-product waste are simultaneously
combusted, the nitrogen oxides
emission limit is 289 ng/J (0.67 lb/
million Btu) and a maximum of 81
percent of the total inlet air provided for
combustion shall be provided to the
reducing zone of the C.AOG incinerator.
(3) Emission monitoring, (i) The
percent of total inlet air provided to the
reducing zone shall be determined at
least every 15 minutes by measuring the
air flow of all the air entering the
reducing zone and the air flow of all the
air entering the oxidation zone, and
compliance with the percentage of total
inlet air that is provided to the reducing
zone shall be determined on a 3-hour
average basis.
(ii) The nitrogen oxides emission limit
shall be determined by the compliance
and performance test methods and
procedures for nitrogen oxides in
§60.46b(i).
(iii) The monitoring of the nitrogen
oxides emission limit shall be
performed in accordance with § 60.48b.
(4) Reporting and recordkeeping
requirements, (i) The owner or operator
of the C.AOG incinerator shall submit a
report on any excursions from the limits
required by paragraph (a)(2) of this
section to the Administrator with the
quarterly report required by paragraph
(i) of this section.
(ii) The owner or operator of the
C.AOG incinerator shall keep records of
the monitoring required by paragraph
(a)(3) of this section for a period of 2
years following the date of such record.
(iii) The owner of operator of the
C.AOG incinerator shall perform all the
applicable reporting and recordkeeping
requirements of this section.
*****
(w) The reporting period for the
reports required under this subpart is
each 6 month period. All reports shall
be submitted to the Administrator and
shall be postmarked by the 30th day
following the end of the reporting
period.
[FR Doc. 00-5797 Filed 3-10-00; 8:45 am]
BILLING CODE 656O-50-P
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 68
[FRL-6550-1]
RIN 2050-AE74
Amendments to the List of Regulated
Substances and Thresholds for
Accidental Release Prevention;
Flammable Substances Used as Fuel
or Held for Sale as Fuel at Retail
Facilities
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Final rule.
SUMMARY: EPA is modifying its chemical
accident prevention regulations to
conform to the fuels provision of the
recently enacted Chemical Safety
Information, Site Security and Fuels
Regulatory Relief Act (Pub. L. 106-40).
In accordance with the new law, today's
rule revises the list of regulated
flammable substances to exclude those
substances when used as a fuel or held
for sale as a fuel at a retail facility. EPA
is also announcing there will be no
further action on a previous proposal
concerning flammable substances, since
the new law resolves the issue
addressed by the proposal.
DATES: Effective March 13, 2000.
ADDRESSES: Docket. Supporting material
used in developing the final rule is
contained in Docket No. A-99-36. The
docket is available for public inspection
and copying between 8:00 am and 5:30
pm, Monday through Friday (except
government holidays) at EPA's Air
Docket, Room 1500, Waterside Mall, 401
M Street, SW, Washington, DC 20460;
phone number: 202-260-7548. A
reasonable fee may be charged for
copying.
FOR FURTHER INFORMATION CONTACT:
Breeda Reilly, Chemical Emergency
Preparedness and Prevention Office,
Environmental Protection Agency, Ariel
Rios Building, 1200 Pennsylvania Ave,
NW (5104), Washington, DC 20460,
(202) 260-0716.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction and Background
A. Statutory Authority
B. Background on Chemical Accident
Prevention Regulations
II. Discussion of Modification
A. Affected Substances
B. Use or Sale as a Fuel
ffl. Previous Actions Related to Fuels
A. Previous Proposed Rule and
Administrative Stay
B. Litigation and Court Stay
IV. RMP's Submitted Prior to Today's Action
-------
IH^^^^^^^^ 'sum !• "' IB f PI ' ri'i ' if'! i^iF1 ii w
13244
IIP ii ""
FederalRegister/Vol. 65, No. 49/Monday, March 13, 2000/Rules and Regulations
fiiiiri '}
, Rationale for Issuance of Rule Without
"""" Prior Notice
VI, Summary of Revisions to Rule
VH. Administrative Requirements
A. Docket
B, Executive Order 12866
C. Executive Order 13045
D. Executive Order 13084
E. Executive Order 13132
F. Regulatory Flexibility Act (RFA), as
amended by the Small Business
Regulatory Enforcement Fairness Act of
1986 (SBREFA) 5 U.S.C. 601 etseq.
G. Paperwork Reduction Act
H. Unfunded Mandates Reform Act
I, National Technology Transfer and
if
IM.
J. Congressional Review Act
I. Introduction and Background
A. Statutory Authority
This rule is being issued under
section 112(r) of the Clean Air Act
(CAA) as amended by the Chemical
Safety Information, Site Security and
Fuels Regulatory Relief Act (the Act),
•which President Clinton signed into law
^XugSiu^m1 ..... SScSoak of the Act
immediately removed EPA's authority
IRlli' ': '! ''1:
used as a fuel or held for sale as a fuel
ata.refill.facility * * * solely because
pf the explosive or flammable properties
of the substance, unless a fire or
Explosion caused by the substance will
result in acute adverse health effects
- 'Trqm Siiman' e^osure'tb1 the substance,
including the unburned fuel or its
iMl; jbojmbu^oj^yproducts, other than
Jhose casUsed by the heat of the fire or
'^jmpact of the explosion."
MIL The Act defines "^tail facility" as "a
1 ^[stationary source at which more than
rJLbA^b^f_Qlthe.}npo.mgis obtained from
I!'1::'Us* ,1 '' , I
111
-^i-^,, end users or at which
icife "Sign pne:half of the fuel sold, by
" [;|lro]iiunej "js'sbld'through a cylinder
|f''gxchange program."
B, Background on Chemical Accident
Prevention Regulations
CAA section 112(r) contains
requirements for the prevention and
mitigation of accidental chemical
releases. The focus is on those
chemicals feftt P°se the greatest risk to
public health" and the environment in
I the evgnto^an agcidentaljelease.
identify at least 100 such chemicals and
promulgate a list of "regulated
substances" with threshold quantities.
Section 112(r)(7) directs EPA to issue
regulations requiring stationary sources
that contain more than a threshold
quantity of a regulated substance to
develop and implement a risk
management program arid submit a risk
management plan (RMP).
EPA promulgated the initial list of
regulated substances on January 31,
1994 (59 FR 4478) (the "List Rule"). The
Agency identified two categories of
regulated substances—toxic and
flammable—and listed substances
accordingly. EPA included 77 chemicals
"oil the toxic substances list based on
each chemical's acute toxicity and
several other factors—the chemical's
physical state, physical/chemical
properties and accident history—
relevant to the likelihood that an
accidental release of the chemical
would lead to significant offsite
consequences. The Agency also placed
63 substances on the flammable
substances list, including vinyl
chloride, a substance mandated for
listing by Congress. EPA selected
chemicals for the flammable substances
list based on their flam inability rating
and the other factors related to
likelihood of significant offsite
consequences.
Of the originally listed substances, 14
met the criteria for both toxic and
flammable substances (arsine, cyanogen
chloride, diborane, ethylene oxide,
formaldehyde, furan, hydrocyanic acid,
hydrogen selenide, hydrogen sulfide,
methyl chloride, methyl mercaptan,
phosphine, propyleneimine, and
propylene oxide). EPA placed these 14
substances on only the toxic substances
list, because their toxicity poses the
greater threat to human health and 'the
environment.
Following promulgation of the List
Rule, EPA issued a rule establishing the
accidental release prevention
requirements on June 20,1996 (61 FR
31668) ("the RMP Rule"). Together
these rules are codified at 40 CFR part
68.
In accordance with section 112(r)(7),
the RMP rule requires that any
stationary source with more than a
threshold quantity of a regulated
substance in a process develop and
implement a risk management program
and submit an RMP describing the
source's program as well as its five-year
accident history and potential offsite
consequences. The rule further provides
that RMPs be submitted by June 21,
1999 for sources with more than a
threshold quantity of a regulated
substance in a process by that date, or
within a specified time of the source
first exceeding the applicable threshold.
EPA has amended lie List and RMP
Rules several times. On August 25,1997
(62 FR 45132), EPA amended the List
Rule to change the listed concentration
of hydrochloric acid. On January 6,1998
(63 FR 640), EPA again amended the
List Rule to delist Division 1.1
explosives (classified by the Department
of Transportation (DOT)), to clarify
certain provisions related to regulated
flammable substances, and to clarify the
transportation exemption. EPA
amended the RMP Rule on January 6,
1999 (64 FR 964) to add several
mandatory and optional RMP data
elements, to establish procedures for
protecting confidential business
information, to adopt a new industry
classification system and to make
technical corrections and clarifications.
EPA also amended the RMP Rule on
May 26,1999 (64 FR 28696) to modify
the requirements for conducting worst
case release scenario analyses for
flammable substances and to clarify its
interpretation of CAA sections 112(1)
and 112(r)(ll) as they relate to DOT
requirements under the Federal
Hazardous Transportation Law.
n. Discussion of Modification
A. Affected Substances
The new Act provides that EPA shall
not list a flammable substance when
used as a fuel,1 or held for sale as a fuel
at a retail facility solely because of its
explosive or flammable properties,
except under certain circumstances. The
purpose of today's rule is to revise the
List Rule as needed to conform to the
Act.
As described above, the List Rule
currently contains two lists—one of
toxic substances and one of flammable
substances. The toxic substances list
contains those chemicals that meet the
criteria listing as toxic substances, even
if they also meet the criteria for listing
as flammable substances. Accordingly,
every chemical on the toxic substances
list was listed for its toxicity at least and
not solely because of its explosive or
flammable properties. The substances
on the toxics list are thus not affected
by the new Act.
The substances on the flammables
list, on the other hand, are listed
"solely" because they meet a certain
flammability rating, taking other risk
factors into account. In deciding what
flammable substances to list, EPA
concentrated on those substances that
have the potential to result in significant
offsite consequences. Accidents
involving flammable substances may
lead to vapor cloud explosions, vapor
cloud fires, boiling liquid expanding
vapor explosions (BLEVEs), pool fires,
and jet fires, depending on the type of
substance involved and the
1 EPA has received a number of questions as to
whether the fuel use exclusion is available only to
retail facilities. EPA believes that the statute and
legislative history are clear that the fuel use
exclusion is available to any facility that uses a
flammable substance as a fuel.
: 1:
Hii
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111 I1
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Federal Register/Vol. 65, No. 49/Monday, March. 13, 2000/Rules and Regulations
13245
circumstances of the accident.
Historically, flammable substance
accidents having significant offsite
impacts involved either vapor cloud
explosions at refineries and chemical
plants, or BLEVEs at sources storing
large quantities of flammable
substances. Vapor cloud explosions
produce blast waves that potentially can
cause offsite damage and kill or injure
people. High overpressure levels can
cause death or injury as a direct result
of an a explosion; such effects generally
occur close to the site of an explosion.
People can also be killed or injured
because of indirect effects of the blast
(e.g., collapse of buildings, flying glass
or debris); these effects can occur farther
from the site of the blast.
By contrast, the effects of vapor cloud
fires, in which the vapor cloud burns
but does not explode, are limited
primarily to the area covered by the
burning cloud. BLEVEs, which generally
involve the rupture of a container, can
cause container fragments to be thrown
substantial distances; such fragments
have the potential to cause damage and
injury.
Thermal radiation is the primary
hazard of pool and jet fires. The
potential effects of thermal radiation
generally do not extend for as great a
distance as those of blast waves and are
related to the duration of exposure;
people at some distance from a fire
would likely be able to escape.
Based on this analysis and available
accident history data, the Agency
concluded that vapor cloud explosions
and BLEVEs pose the greatest potential
hazard from flammable substances to
the public and environment. For
purposes of the List Rule, EPA
consequently focused on those
chemicals with the potential to result in
vapor cloud explosions or BLEVEs in
the event of an accidental release. The
Agency determined that chemicals
meeting the highest flammability rating
of the National Fire Protection Agency
(NFPA) had this potential and used that
rating as the principal criterion for
including chemicals on the flammable
substances list.
The other factors EPA considered in
listing flammable substances—physical,
state, physical/chemical properties and
accident history—all relate to a
chemical's potential to be accidentally
released in a way that could lead to a
vapor cloud explosion or BLEVE. In
short, the Agency included chemicals
on the flammable substances list
"solely" because of their explosive
potential, a basis now disallowed by the
new Act for flammable substances when
used as a fuel or held for sale as a fuel
at a retail facility.
The new Act nevertheless allows EPA
to list a flammable substance when used
as a fuel, or held for sale as a fuel where
a fire or explosion caused by the
substance will result in acute adverse
health effects from human exposure to
the substance or its combustion
byproducts. EPA believes, however, that
no listed substances on the flammable
substances list is a candidate for this
exception. As noted above, flammable
substances that meet the listing criteria
for toxic substances are on the toxic
substances list only. Therefore, none of
the chemicals on the flammable
substances list will qualify for the
exception based on acute health effects
from exposure to the substance itself.
Further, combustion byproducts are
generally not relevant to listing
flammable substances. For
hydrocarbons, including the listed
flammable substances commonly used
as fuels, typical combustion products
include water vapor, carbon dioxide,
carbon monoxide, and relatively small
amounts of other oxidized inorganic
substances and do not meet the listing
criteria for toxic substances. Several
other listed flammable substances may
result in combustion byproducts that
meet the listing criteria for toxic
substances, but these substances are not
commonly used as fuels. Further, any
toxic combustion byproducts will be a
fraction of the total mass and not likely
to exceed the applicable threshold for
coverage by the RMP rule. Quantities
below the threshold are unlikely to have
significant offsite consequences.
For these reasons, EPA believes that
none of the listed flammable substances
meet the new statute's test for listing
fuels. Consequently, all of the listed
flammable substances are potentially
affected by the Act.
B. Use or Sale as a Fuel
The Act prohibits the listing of
flammable substances "when used as a
fuel or held for sale as a fuel at a retail
facility." In limiting EPA's authority to
list flammable substances used as a fuel,
or sold as a fuel at retail facilities,
Congress sought greater consistency
between the RMP program and the
Process Safety Management (PSM)
Standard implemented by the
Occupational Health and Safety
Administration (OSHA). OSHA's PSM
Standard is the workplace counterpart
of EPA's RMP program. PSM
requirements protect workers from
accidental releases of highly hazardous
substances in the workplace, while the
RMP rule protects the public and
environment from the offsite
consequences of those releases.
The PSM and RMP programs are
similar in many ways, covering mostly
the same chemicals. Establishments
subject to the PSM Standard must
comply with the prevention program
requirements which are the same as the
RMP rule's Program 3 requirements
(subpartD of the Part 68 regulations).
However, OSHA provides an exemption
from the PSM Standard for hydrocarbon
fuels used solely for workplace
consumption as a fuel (e.g., propane
used for comfort heating), if such fuels
are not part of a process containing
another highly hazardous chemical
covered by the standard. It also exempts
such substances when sold by retail
facilities.
The two prongs of the limitation on
EPA's authority to list flammable
substances (i.e., use as a fuel or held for
sale as a fuel by a retail facility) largely
follow the OSHA exemptions relating to
fuel. EPA will therefore look to OSHA
precedent and coordinate with OSHA in
interpreting and applying the
limitations to the extent they parallel
OSHA's exemptions. For example, the
new Act does not define the term
"fuel," but OSHA has given "fuel" its
ordinary meaning in applying the PSM
fuel-related exemptions. Webster's
Ninth New Collegiate Dictionary (1990)
defines fuel as "a material used to
produce heat or power by burning," and
EPA has no reason to believe that "fuel"
as used by the new Act should be
defined differently.
Using the ordinary meaning of fuel,
EPA reviewed the chemicals on its
flammable substances list to determine
which are used as fuel. Several of the
listed substances are typically used as
fuel, including propane, liquified
petroleum gas (propane and/or butane
often with small amounts of propylene
and butylene); hydrogen; and gaseous
natural gas (methane). EPA is aware of
the possibility of other flammable
substances being used as a fuel in
particular circumstances. The following
is a list of regulated flammable
substances that EPA believes have been
used as a fuel.
TABLE 1.—LIST OF COMMON FUELS
Chemical name
Acetylene [Ethyne]
Butane
1-Butene
2-Butene
ButenG
2-Butene-cis
2-Butene-trans [2-Butene, (E)]
Ethane
Ethylene [Ethene]
Hvdroaen
CAS No.
74_86-2
106-97-8
106-98-9
107-01-7
25167-67-3
590-1 8-1
624-64-6
74_84-0
74-85-1
1333-74-0
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Federal Register/Vol. 65, No. 49/Monday, March 13, 2000/Rules and Regulations
TABLE "(.—LIST OF COMMON FUELS—
Continued
lllll 1 il 1 !
Chemical name
III i ((lllll r 1 1 ill ii ill 1 mil I 11111
Isobutarvs propane,
2-mathyl-] ,
Isopentane [Butane,
2-matnyf-]
Methane
penians ........ ....... .l...lin....."Z'"
1-Pentene
2-Psntone, (E)-
2-Pentone, (Z)-
Propane
Pfopyfons ,......,..
CAS No.
I L" If 'ii!,"!!,1 Hm! [liiij,
75^28-5
78-78-4
74-62-8
109-66-0
109-67-1
646-04-8
627-20-3
74_Q8-6
115-07-1
At the same time, all of the substances
" '"^ ^ listed above, are,s,pmetim_es,,,,usedas
'"••'! !*'?• feedstock chemical's instead of fuel.
Further,, every listed flammable
substance has the potential to be used
Is fuel, since.itmay be burned to create
.wi.'"r5i^ejit.Mpower. Consequently, the List
HuA'Kft; f i
BI iif
MI. nt:
I::".:,!>
..............
iw y eeting particular chemicals
:!i from tiie,, flammable ..... substances list.
'ToJf isi,SE4.1J§i,M2gS .% provision to
part el, Sub' part F {fisting regulated
lti that exdudes flammable
. eci as a fuel,,,, or held
'iii i for sale as a fuel at a retail facility from
the JJs|,of regulated substances. The
! Agoncy has also annotated both versions
f1^.!?f.1tfeB flffiffiable ..... substances, list (one
, , ^ „ sfoil'Iists tEe 'suDStances
mi,, ill:!.,:;1;. "v j ........ ......... ; .......... *i ....... ;5 " '" ' ........ 71;1 ..................... **' ............... «i ....... . ............ i
alphabetically, the other by Chemical
Abstract Service (CAS) number) to
indicate that any flammable substance,
when used as a fuel, or held for sale as
a fuel at a retail facility, is excluded
.
As previously mentioned, the Act
-iiifihe Income" is obtained from direct sales
to end users or at which more than one-
i ,„ T : .1- * " wy M» ' i .......... ^. t . , i^ .......... » ................... .. j ......... ™ .................. ....................... . ....... • ............ ................ ..... • .................... .......... ..... ^
half of the fuel sold, by volume, is sold
through a cylinder exchange program.
! '..The income test portion of the
j, ',' .' Definition follows the, definition of
:lfnfessifflB its PSM Standard (OSHA
Directive CPL2-2.45A CH-1-Process
Safety Management of Highly
Hazardous Chemicals— Compliance
Guidelines and Enforcement
Procedures): "an establishment that
would otherwise be subject to the PSM
.,
income ..... ls,,,,obtaine,d,,,from,,,,d|rec,t sales to
The effect of the income test portion
of |hes £S&Aj^'sjgta£yncttjty definition
is {g'pr^dde'relie'Fto ^te'same facilities
that qualify for OSHA's retail facility
exemption, and conversely, to require
^aq^i^ejg jhatjio joo^guaiity for OSHA's
^^p|~.,.-.j||— ^^ su-bject to the
PSM program, to also be subject to the
RMP program, provided no other
exemption applies. EPA will
consequently coordinate its
interpretation and application of the
income test portion of the retail facility
definition."with OSHA.
The second portion of the retail
facility definition—concerning cylinder
exchange programs—goes beyond that
developed by OSHA and so provides
greater relief than the OSHA retail
facility exemption. In general, cylinder
exchange programs represent a link
between major retailers (for example,
hardware stores, home centers and
convenience stores) and propane
distributors. The retailer typically
provides space outdoors and manages
transactions with end users such as
homeowners; the propane distributor
typically provides racks, filled
cylinders, promotional materials, and
training to the retailer's employees.
Propane distributors may have several
markets, including cylinder exchange;
temporary heat during construction;
commercial cooking, heating, and water
heating; fuel to power vehicles, forklifts,
and tractors; agricultural drying and
heating; and others.
For propane or other fuel distributors
which meet the definition of retail
facility through either direct sales to end
users or a cylinder exchange program,
the fuel they hold is no longer covered
by the RMP rule. For propane or other
fuel distributors that do not meet the
definition, the fuel they hold is not
exempted from the RMP rule by the new
law or today's action. EPA has added to
part 68 a definition of "retail facility"
that mirrors the statutory definition.
m. Previous Actions Related to Fuels
A. Previous Proposed Rule and
Administrative Stay
After promulgating the RMP rule, EPA
became aware that a significant number
,, pfiiismialljiiic,ommercial,,spurces use
regulated flammable substances,
particularly propane, as fuel in
quantities in excess of the applicable
threshold quantity (10,000 Ibs in a
process). As a result, these small
sources, including farms, restaurants,
hotels, and other commercial
operations, were covered by the RMP
requirements. Many of these sources are
in rural locations where accidental
releases.areless..;Keiy to have
significant offsite consequences. In light
of the purpose of section 112(r)—to
focus comprehensive accident
prevention requirements on the most
potentially dangerous sources—EPA
reexamined whether farms and other
small fuel users should be covered by
the RMP rule.
On May 28,1999, EPA issued a
proposed amendment to the List Rule to
create an exemption from threshold
quantity determinations for processes
containing 67,000 pounds or less of a
listed flammable hydrocarbon fuel (64
FR 29171). EPA estimated that the
proposed amendment, if promulgated,
would reduce the universe of regulated
sources from 69,485 to 50,300. At the
same time (64 FR 29167), EPA
published a temporary stay of the
effectiveness of the RMP rule for those
sources that would be exempted under
the proposal. This stay, which expired
on December 21,1999, was in addition
to, and did not affect, a stay of the rule
for propane processes entered by the
U.S. Court of Appeals for the D.C.
Circuit (See Litigation and Court Stay).
While EPA was seeking comment on
the proposed rule, Congress also studied
the fuel issue and considered ways to
provide regulatory relief to fuel users
and retailers. Congress was concerned
that the RMP rule placed a significant
regulatory burden on facilities that were
not previously covered by the OSHA
PSM Standard. Congress decided to
amend section 112(r) of the CAA to
remove EPA's authority to list any
flammable substance when used as a
fuel, or held for sale as a fuel at a retail
facility, except under specified
circumstances.
While the new law and EPA's
proposed rule and temporary stay all
offer regulatory relief with respect to
fuels, the new law reaches farther than
EPA's actions. The new law provides
relief for all fuels, not just hydrocarbon
fuels. It also removes fuels from the
RMP program regardless of the amount
a stationary source uses or holds for
retail sale, whereas EPA's proposal and
stay only affects sources having no more
than 67,000 Ibs of fuel in a process. The
new law does limit relief for fuel sellers
to fuel retailers, whereas EPA's stay
does not distinguish between types of
fuel sellers. However, EPA believes that
virtually no fuel wholesaler qualifies for
the Agency's stay because wholesalers
typically hold fuel in quantities far
greater than 67,000 Ibs. Even if a few
wholesalers would have benefitted from
EPA's proposed rule, the Agency
believes that Congress has addressed the
issue of how to provide regulatory relief
lo,,,,fuel.users .and sellers, and that EPA
should thus implement Congress'
approach without making exceptions to
it.
Therefore, EPA is today withdrawing
the proposed rule as it takes final action
to amend the List Rule to conform to the
new law. As previously mentioned,
EPA's temporary stay of effectiveness
expired on December 21,1999.
II II
i in i iiiii i
111
fill il Illlill
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Federal Register/Vol. 65, No. 49/Monday, March 13, 2000/Rules and Regulations 13247
B. Litigation and Court Stay
Following promulgation of the RMP
rule in 1996, several petitions for
judicial review of the rule were filed,
including one by the National Propane
Gas Association (NPGA). At NPGA's
request, the U.S. Court of Appeals for
the District of Columbia Circuit entered
a temporary stay of the RMP rule as it
applies to propane (Chlorine Institute v.
Environmental Protection Agency, No.
96—1279, and consolidated cases (Nos.
96-1284, 96-1288, and 96-1290), Order
of April 27,1999). The judicial stay
meant that any stationary source, or
process at a stationary source, subject to
the RMP rule only by virtue of propane
was not subject to the RMP rule
requirements, including those calling
for a hazard assessment, accident
prevention program, emergency
response planning, and submission of
(or inclusion in) an RMP by June 21,
1999.
On Jan. 5, 2000, the Court lifted its
temporary stay in response to a joint
motion by EPA and NPGA to dismiss
the case and lift the stay. As of that date,
part 68, as revised by the Act, is in effect
with respect to any facility having more
than the 10,000 pounds of propane in a
process unless the facility uses the
propane as a fuel or sells the propane
as a retail facility. Facilities that use
propane in their manufacturing
processes or hold propane for purposes
other than on-site fuel use at a non-retail
facility must immediately come into
compliance with Section 112(r) of the
CAA.
IV. RMP's Submitted Prior to Today's
Action
EPA has received about 1,966 RMP's
that address one or more of the 19 listed
flammable substances that EPA has
identified as likely to be used as a fuel.
EPA cannot unilaterally delete any of
the RMP's submitted for flammable
substances from the RMP database,
however, because the determination of
whether a facility is eligible for the
exclusion is based on information
which is not reported to EPA, namely,
whether a facility uses the flammable
substance as a fuel or holds it for retail
sale. Instead, EPA plans to send a letter
to each of the 1,966 facilities to notify
them of the exclusion, to ask them to
evaluate their eligibility for the
exclusion, and to describe the process
the facilities should use to request a
withdrawal of or to update these RMP's.
For about 950 of the 1,966 RMP's that
reported a potential flammable fuel,
only one chemical is reported. For these
cases, the facilities will be asked to
evaluate whether they qualify for the
exclusion based on use or retail sales. If
they determine that they do not qualify,
no further action is required. If they
determine that they do qualify, they
may request that EPA withdraw their
submission and EPA will delete it from
the RMP database. Facilities will have
the option of using the form that EPA
developed to facilitate the withdrawal
or simply stating their request in a
letter. Alternatively, facilities can leave
the RMP as a voluntary submission in
the database and need not take further
action.
The balance of the RMP's reported
more than one substance. About 200
RMP's reported a toxic chemical
substance in addition to the potential
flammable fuel. For these cases, the
facilities will be asked to evaluate
whether their flammable substance
qualifies for the exclusion based on use
or retail sales. If they determine that
they do not qualify, no further action is
required. If they determine that they do
qualify, they may resubmit their RMP,
reporting only on the toxic substances.
Alternatively, facilities can leave the
original RMP including the flammable
fuel submission in the database and
need not take further action.
About 745 RMP's reported multiple
flammable substances. For these cases,
the facilities will be asked to evaluate
whether each reported flammable
substance qualifies for the exclusion
based on use or retail sales. If they
determine that none of their reported
flammable substances qualify, no .
further action is required. If they
determine that all of the reported
substances qualify, they may request
that EPA withdraw their submission
and EPA will delete it from the RMP
database. Facilities will have the option
of using the formal withdrawal process
or simply sending a letter. Alternatively,
facilities can leave the RMP as a
voluntary submission in the database
and need not take further action. If they
determine that only some of the
flammable substances reported qualify,
they will need to check their flammable
worst case scenario and off-site
consequence analysis (OCA). If their
original worst case analysis is based on
a flammable substance that is excluded,
the facility should revise their RMP to
provide appropriate OCA. Within its
enforcement discretion, EPA plans to
treat this similarly to the existing
requirement to revise RMP's within 6
months of a process change, giving
facilities 6 months to revise their RMP's.
If their original worst case analysis is
based on a flammable substance that is
not excluded, the facility won't need to
update their RMP, except as part of the
regular reporting cycle.
V. Rationale for Issuance of Rule
Without Prior Notice
Section 553 of the Administrative
Procedure Act, 5 U.S.C. 553(b)(B),
provides that, when an agency for good
cause finds that notice and public
procedure are impracticable,
unnecessary or contrary to the public
interest, the agency may issue a rule
without providing notice and an '
opportunity for public comment.
EPA is taking this action without
prior notice and opportunity to
comment. As previously mentioned,
section 2 of the new Act, which took
effect on August 5,1999, immediately
removed EPA's authority to list
flammable substances when used as a
fuel, or held for sale as a fuel at a retail
facility. Consequently, EPA's regulation
containing the list of regulated
substances subject to the RMP rule
needs to be modified to reflect the new
law.
EPA has determined that there is good
cause for making today's rule final
without prior proposal and opportunity
for comment because the Agency is
codifying legislation which focuses
clearly on a particular set of regulations
and requires little interpretation by the
Agency. In addition, EPA believes it is
in the public interest to issue the
revised list as soon as possible, to avoid
confusion about the coverage of the
RMP rule. As of August 5,1999, there
is no statutory basis for extending the
RMP rule to listed flammable substances
when used as a fuel, or held for sale as
a fuel at a retail facility, except under
certain circumstances. The Agency's
rule should therefore be revised to
reflect the change in authority as soon
as possible. A comment period is
unnecessary because today's action is
nondiscretionary. A comment period
would also be contrary to the public
interest because the resulting delay
would contribute to confusion about the
coverage of the RMP rule. Thus, notice
and public procedure are unnecessary
and contrary to the public interest. EPA
finds that this constitutes good cause
under 5 U.S.C. 553(b)(B).
The Agency is also issuing this rule
with an immediate effective date. Since
its effect is to relieve a restriction (i.e.,
the requirement to comply with the
RMP rule), EPA may make it effective
upon promulgation. Further, EPA
believes it is in the public interest to
make it immediately effective, for the
same reasons given above for dispensing
with prior notice and comment.
VI. Summary of Revisions to Rule
This section summarizes the changes
to the rule.
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!••;; ro
ms*. isiuMK" mm i i ' i ", 11' in
< <:»:'" I III ill ll I I I ill ill II
Federal Register/Vol. 65, No. 49/Monday, March. 13, 2000/Rules and Regulations
m ("N'iif
M.JIM '/,Seclpn68,3, Definitions, has been
[•T^'Mvised to add a definition of retail
facility, as defined in the new law.
Section 68.126 has been added to
f; create aji exclusion 19? regulated
• he!3 for sale as fuel at retail facilities.
litH||:;|IilipThe exclusionjs,derived from the new
IllniWIiUli1:,, ''I'-1 ::ll i!:i!W HllOllilllii JIHIIIIIP" : ,„ !' !»! ' :,:"l|i 'U'ji •!„' J:H|I;I!
In Section 68.130, footnotes have been
ll|
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Federal Register/Vol. 65. No. 49/Monday, March 13, 2000/Rules and Regulations
13249
or tribal governments that may own or
operate sources that use flammable
fuels. Thus, the requirements of section
6 of the Executive Order do not apply
to this rule.
F. Regulatory Flexibility Act (UFA), as
Amended by the Small Business
Regulatory Enforcement Fairness Act of
1996 (SBREFA), 5 U.S.C. 601 etseq.
Under the Regulatory Flexibility Act
(RFA) of 1980 (5 U.S.C. 601, et seq.], as
amended by the Small Business
Regulatory Enforcement Fairness Act of
1996 (SBREFA), the Agency is required
to give special consideration to the
effect of Federal regulations on small
entities and to consider regulatory
options that might mitigate any such
impacts. Small entities include small
businesses, small not-for-profit
enterprises, and small governmental
jurisdictions.
Today's final rule is not subject to
RFA, which generally requires an
agency to prepare a regulatory flexibility
analysis for any rule that will have a
significant economic impact on a
substantial number of small entities.
The RFA applies only to rules subject to
notice-and-comment rulemaking
requirements under the Administrative
Procedure Act (APA) or any other
statute. The rule is subject to the APA,
but as described in Section IV of this
preamble, the Agency has invoked the
"good cause" exemption under APA
Section 553(b), which does not require
notice and comment. Although this final
rule is not subject to the RFA, EPA
nonetheless has assessed the potential
of this rule to adversely impact small
entities subject to the rule. EPA does not
believe the rule will adversely impact
small entities. This action excludes
flammable substances when used as a
fuel, or held for sale as a fuel at a retail
facility from the list of substances
regulated by 40 CFR part 68, which will
reduce burden on many small entities
that otherwise would be covered by
these requirements.
G. Paperwork Reduction Act
This action does not impose any new
information collection burden. The
Office of Management and Budget
(OMB) has previously approved the
information collection requirements
contained in the existing regulations 40
CFR part 68 under the provisions of the
Paperwork Reduction Act, 44 U.S.C.
3501 et seq. and has assigned OMB
control number 2050-0144 (EPA ICR
No.1656.06). EPA estimates a burden
hour reduction of 70,400 hours.
Burden means the total time, effort, or
financial resources expended by persons
to generate, maintain, retain, or disclose
or provide information to or for a
Federal agency. This includes the time
needed to review instructions; develop,
acquire, install, and utilize technology
and systems for the purposes of
collecting, validating, and verifying
information, processing and
maintaining information, and disclosing
and providing information; adjust the
existing ways to comply with any
previously applicable instructions and
requirements; train personnel to be able
to respond to a collection of
information; search data sources;
complete and review the collection of
information; and transmit or otherwise
disclose the information. An Agency
may not conduct or sponsor, and a
person is not required to respond to a
collection of information unless it
displays a currently valid OMB control
number. The OMB control numbers for
EPA's regulations are listed in 40 CFR
part 9 and 48 CFR Chapter 15.
H. Unfunded Mandates Reform Act
Title E of the Unfunded Mandates
Reform Act of 1995 (UMRA), Public
Law 104-4, establishes requirements for
Federal agencies to assess the effects of
their regulatory actions on State, local,
and tribal governments and the private
sector. Under section 202 of the UMRA,
EPA generally must prepare a written
statement, including a cost-benefit
analysis, for proposed and final rules
with "Federal mandates" that may
result in expenditures to State, local,
and tribal governments, in the aggregate,
or to the private sector, of $100 million
or more in any one year. Before
promulgating an EPA rule for which a
written statement is needed, section 205
of the UMRA generally requires EPA to
identify and consider a reasonable
number of regulatory alternatives and
adopt the least costly, most cost-
effective or least burdensome alternative
that achieves the objectives of the rule.
The provisions of section 205 do not
apply when they are inconsistent with
applicable law. Moreover, section 205
allows EPA to adopt an alternative other
than the least costly, most cost-effective
or least burdensome alternative if the
Administrator publishes with the final
rule an explanation why that alternative
was not adopted.
Before EPA establishes any regulatory
requirements that may significantly or
uniquely affect small governments,
including tribal governments, it must
have developed under section 203 of the
UMRA a small government agency plan.
The plan must provide for notifying
potentially affected small governments,
enabling officials of affected small
governments to have meaningful and
timely input in the development of EPA
regulatory proposals with significant
Federal intergovernmental mandates,
and informing, educating, and advising
small governments on compliance with
the regulatory requirements.
Because the Agency has made a "good
cause" finding that this action is not
subject to notice-and-comment
requirements under the Administrative
Procedures Act or any or any other
statute (see Section IV of this preamble),
it is not subject to sections 202 and 205
of the Unfunded Mandates Reform Act
of 1995 (UMRA) (Public Law 104-4).
Pursuant to Section 203 of UMRA,
EPA has determined that this rule
contains no regulatory requirements that
might significantly or uniquely affect
small governments. This rule does not
contain any additional requirements,
rather it reduces the burden on small
governement sources that use flammable
substances as fuel.
I. National Technology Transfer and
Advancement Act
Section 12(d) of the National
Technology Transfer and Advancement
Act of 1995 ("NTTAA"), Public Law
104-113, section 12(d) (15 U.S.C. 272
note) directs EPA to use voluntary
consensus standards in its regulatory
activities unless to do so would be
inconsistent with applicable law or
otherwise impractical. Voluntary
consensus standards are technical
standards (e.g., materials specifications,
test methods, sampling procedures, and
business practices) that are developed or
adopted by voluntary consensus
standards bodies. The NTTAA directs
EPA to provide Congress, through OMB,
explanations when the Agency decides
not to use available and applicable
voluntary consensus standards.
This action does not involve technical
standards. Therefore, EPA did not
consider the use of any voluntary
consensus standards.
/. Congressional Review Act
The Congressional Review Act, 5
U.S.C. 801 et seq., as added by the Small
Business Regulatory Enforcement
Fairness Act of 1996, generally provides
that before a rule may take effect, the
agency promulgating the rule must
submit a rule report, which includes a
copy of the rule, to each House of the
Congress and to the Comptroller General
of the United States. EPA will submit a
report containing this rule and other
required information to the U.S. Senate,
the U.S. House of Representatives, and
the Comptroller General of the United
States prior to publication of the rule in
the Federal Register. A "major rule"
cannot take effect until 60 days after it
is published in the Federal Register.
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Federal Register/Vol. 65, No. 49/Monday, March 13, 2000/Rules and Regulations
This, SSSPS, ?§ 1°I S, *<:H?Jor rule" as
deflned'BySUls'IcI 804(2). It takes effect
today.
Environmental protection, Chemicals,
Chemical accident prevention.
Dated: March 3,2000.
'"I'M,,! ': milli iiiiniQ'"'"t'j'illJliiii11'11 jii^iiiiK!:1 , «m: 'I'i'",1;: ::,/: ',•',,''«,<'
Carol M. Browner,
Administrator.
For the reasons stated in the
preamble, EPA amends 40 CFR part 68
as follows:
'„ PARI68—[AMENDED]
I lull"! . I ' ill :l "It
StflI'!;! i
'. "l.'lliejauffiprity section for part 68 is
revised to read as follows:
'Authority: 42 U.S^7412fr), 7601 (a) (1JV
SuJjpartA-^menSedi
2. Section 68.3 is amended to add the
following definition in alphabetical
order:
Illf lit
ESiil
!'i
'"('i.r.rif': Iff I
" 8 ' * ' • •'-•" •' '
r means a stationary
source" at which, more than one-half of
the income is obtained from direct sales
tp" indusers or at , wjrfchjtnore Jian one-
through a cylinder exchange program.
„ ' '"! it ' • * i 4
;•:•'!!•. I inn i
Subpart F—[Amended]
1 '(,3.faction 68.12jjsadded to subpart
F to read" as follows:
§68.130 List of substances."
TABLE 3 TO §68.130.—LIST OF REGU-
LATED FLAMMABLE SUBSTANCES 1
AND THRESHOLD QUANTITIES FOR
ACCIDENTAL RELEASE PREVENTION
i [Alphabetical Order-63 Substances]
1A flammable substance when used as a
fuel or held for sale as a fuel at a retail facility
is excluded from all provisions of this part (see
§68.126).
" 'Note:'Basis for "Listing:
a Mandated for listing by Congress.
fF|arnmable gas.
s Volatile flammable liquid.
"•• S'V r';':,« [k4i'.:ifl m'KUWfc,*'<'«rs.*FIi
TABLE 4 TO §68.130.—LIST OF REGU-
LATED FLAMMABLE SUBSTANCES1
AND THRESHOLD QUANTITIES FOR
ACCIDENTAL RELEASE PREVENTION
[CAS Number Order-63 Substances]
1A flammable substance when used as a
fuel or held for sale as a fuel at a retail facility
is excluded from all provisions of this part (see
§68.126).
Note: Basis for Listing:
a Mandated for listing by Congress.
f Flammable gas.
eVolatile flammable liquid.
[FR Doc. 00-5935 Filed 3-10-00; 8:45 am]
BILLING CODE 656O-50-P
§68.126 Excjuslon^
: '^FlgiimaUe.SuWstgiices Used as "Fuel_
Facilities. A flammable substance listed
in Tables 3 and 4 of § 68.130 is
., , ,.,,T provisions of Siis part wEen the
llliii!L:; v"!,1 i;!?!'! 'iliif ^ ^ , ^^ ri ill*.
i, , -I, ,i ••• substance is used as a mel or held for
!||Kff! !•.E'|:|'Me&"£$eTjA&J&a!^ffityi " M^ "'''"
;;'•=„ , i ^...igctipja §§.130 is amended by:
'" " ' ' '"'* J "" "TableS;
joifTabli
|:H!!1'|!'ti: ^J.'levising the notes to Table 3 and
SlrlS.ii iiiir;''Adding a new footaote 1;
C. Re vising the heading to Table 4;
and
D. Revising the notes to Table 4 and
. .^... _.^ ^jjjj^g-- Jiew footnote i.
. '"";J j' r"T y'iThJeii|svisjpjisiandiiadditionsireadas
follows:
FEDERAL COMMUNICATIONS
COMMISSION
47 CFR Part 73
[DA No. 00-494, MM Docket No. 99-256;
RM-9527]
Radio Broadcasting Services; Ref ugio
an_d.Taft,TX
AGENCY: Federal Comnrunications
Commission.
ACTION: Final rule.
SUMMARY: This document substitutes
Channel 293C2 for Channel 291C3 at
Refugio, Texas, reallots Channel 293C2
from Refugio, Texas, to Taft, Texas, and
modifies the license for Station
Channel 293C2 at Taft in response to a
petition filed by Pacific Broadcasting of
Missouri, L.L.C. See 64 FR 39963, July
23, 1999. The coordinates for Channel
293C2 at Taft are 27-52-00 and 97-13-
08. We shall also allot Channel 291A to
Refugio, Texas, at coordinates 28-21-58
and 97—19—11. Mexican concurrence
has been received for the allotments at
Refugio and Taft, Texas. With this
action, this proceeding is terminated.
EFFECTIVE DATE: April 17, 2000.
FOR FURTHER INFORMATION CONTACT:
Kathleen Scheuerlej Mass Media
' 418-2180'.
SUPPLEMENTARY INFORMATION: This is a
summary of the Commission's Report
and Order, MM,Dgcket No. 99-256,
adopted February 23, 2000, and released
March 3, 2000. The full text of this
Commission decision is available for
inspection and copying during normal
business hours in the Commission's
Reference Center, 445 12th Street, SW,
Washington, DC. The complete text of
this decision may also be purchased
from the Commission's copy
contractors, International Transcription
Services, Inc., 1231 20th Street, NW.,
Washington, DC 20036, (202) 857-3800,
facsimile (202) 857-3805.
List of Subjects in 47 CFR Part 73
Radio broadcasting.
Part 73 of title 47 of the Code of
Federal Regulations is amended as
follows:
• :"
-------
Appendix B
Selected NAICS Codes
-------
' VII I,,' I' J!1!' I i '!l'"ll
111 fill!,1 I'll,,! 'I '• It
I'll!1 if1,,,!.! J '':O'!'
'IlU'i*'!' '„,: I, i,,','i I1 '.
'•• 1:11111' nn
HMii ' lllii'l'ii'l!,!
,,!i'fciK i •.;.! ni „
|5i:;;""!< I!1,I;:I ! '"
P'1
IB:
• "11 ' ' LslD
'.: it"
'!' 'i,,!1'.* HI1' ii'iilLiill
11 /'''"ill' mi" • i1 ,
'!'• , i ,,'ib
' '• u::!,'*
Illl III ill II I Illl Kill I II II |l|l|l(l II 111
Illl IIII 111 I II 111 1111 I Illllllll I 1111 III 111 I 111 III III Illl 111 111 I 111 111
"!'lp l
-------
SELECTED 1997 NAICS CODES
11 Agriculture
11111 Soybean Farming
11113 Dry Pea and Bean Farming
11114 Wheat Farming
11115 Corn Farming
111191 Oilseed and Grain Farming
111199 All Other Grain Farming
111211 Potato Farming
111219 Other Vegetable and Melon Farming
11131 Orange Groves
11132 Other Citrus
111331 Apple Orchards
111332 Grape Vineyards
111339 Other Non Citrus Fruit Farming
111422 Floriculture Production
11191 Tobacco Farming
11192 Cotton Farming
11199 All Other Crop Farming
11211 Beef Cattle Ranching and Farming
11213 Dual Purpose Cattle Ranching and Farming
11221 Hog and Pig Farming
11231 Chicken Egg Production
11232 Broilers and Other Chicken Production
11233 Turkey Production
11234 Poultry Hatcheries
11239 Other Poultry Production
112511 Finfish Farming and Fish Hatcheries
11291 Apiculture
11299 All Other Animal Production
115111 Cotton Ginning
115112 Soil Preparation
115114 Post Harvest Crop Activities
11521 Support for Animal Production
21 Mining
211 Oil and Gas Extraction
211111 Crude Petroleum and Natural Gas Extraction
211112 Natural Gas Liquid Extraction
21211 Coal Mining
21221 Iron Ore Mining
21222 Gold and Silver Ore Mining
21223 Copper, Nickel, Lead, and Zinc Mining
21229 Other Metal Ore Mining
21231 Stone Mining and Quarrying
212322 Industrial Sand Mining
212324 Kaolin and Bal Clay Mining
21239 Other Non-Metallic Mineral Mining
21311 Support Activities for Mining
22 Utilities
22111 Electric Power Generation
221111 Hydroelectric Power Generation
221112 Fossil Fuel Electric Power Generation
221113 Nuclear Electric Power Generation
221119 Other Electric Power Generation
2213 Water, Sewage and Other Systems
22131 Water Supply and Irrigation Systems
22132 Sewage Treatment Facilities
22133 Steam and Air Conditioning Supply
23 Constuction
2333 Nonresidential Building Construction
31-33 Manufacturing
311 Food Manufacturing
3111 Animal Food Manufacturing
311111 Dog and Cat Food Manufacturing
311119 Other Animal Food Manufacturing
31121 Flour Milling and Malt Manufacturing
311211 Flour Milling
31122 Starch and Vegetable Fats and Oils Manufacturing
311221 Wet Com Milling
311222 Soybean Processing
311223 Other Oilseed Processing
311225 Fats and Oils Refining and Blending
31123 Breakfast Cereal Manufacturing
311313 Beet Sugar Manufacturing
31132 Chocolate and Confectionery Manufacturing from
Cacao Beans
31133 Confectionery Manufacturing from Purchased
Chocolate
311411 Frozen Fruit, Juice and Vegetable Manufacturing
311412 Frozen Specialty Food Manufacturing
311421 Fruit and Vegetable Canning
311422 Specialty Canning
311423 Dried and Dehydrated Food Manufacturing
311511 Fluid Milk Manufacturing
311512 Creamery Butter Manufacturing
311513 Cheese Manufacturing
311514 Dry, Condensed, and Evaporated Dairy
Product Manufacturing
31152 Ice Cream and Frozen Dessert Manufacturing
311611 Animal (except Poultry) Slaughtering
311612 Meat Processed from Carcasses
311613 Rendering and Meat By-product Processing
311615 Poultry Processing
311711 Seafood Canning
311712 Fresh and Frozen Seafood Processing
311811 Retail Bakeries
311812 Commercial Bakeries
311813 Frozen Cakes, Pies, and Other Pastries
Manufacturing
311821 Cookie and Cracker Manufacturing
311822 Flour Mixes and Dough Manufacturing from
Purchased Flour
311823 Dry Pasta Manufacturing
31191 Snack Food Manufacturing
-------
Ill 111" 111
ii in linn iinninin nn nil
i 'ill
ii iiiliniinnnnni in in nil in in in
lid1! h
liilltl
in ii ill i ii i ii ii i i 111 i i i i 1 i i 111 i i 1 i ii nn i n
ill II H i ' I K
III 1 II
li|
III III III Mill II
ill i| I11 '
1 1 I Mill III IIIIIIIIIIIIIIIIIIIIIIIIll
In Hi ''111 111 •111
ill
Appendix B
Codes
B-2
ill II
LI , |.
lill*'"!!,. J
; Ll'I, '!..
iji!!,11'"1!!!1 ! i in -
IIElT '.In i
Ifflil Ill"
311911 Roasted Nuts and Peanut Butter Manufacturing
311919 Other Snack Food Manufacturing
31192 Coffee and Tea Manufacturing
31193 Flavoring Syrup and Concentrate Manufacturing
311941 Mayonnaise, Dressing and Other Prepared
Sauce Manufacturing
311991 Perishable Prepared Food Manufacturing
311999 All Other Miscellaneous Food Manufacturing
312 Beverage and Tobacco Product Manufacturing
312111 Soft Drink Manufacturing
312113 Ice Manufacturing
31212 Breweries
31213 Wineries
31214 Distilleries
31222 Tobacco Product Manufacturing
(l(iI I I ill ii'iii i ' '•! 'Mi, "'"::':¥•
313 Textile Mffls
313111 Yam Spinning Mills
3i323 Nonwoven Fabric Mills
31324 Knit Fabric Mills
•':;313241 Weft Knit Fabric Mills
31331 Textile and Fabric Finishing Mills
3J3311 jBroadwpven Fabric Finishing Mills
314 Textile Product Mills
• limilliillljilill' '..liilin '•„ aiiWiiniii1 i: mill iiiiiki jiiir'Jiiiniiiiiiiiiiiiri ,'i iiii;iiiiiiiini|i : yiui i.r'.iiM :: , < : ii • •',:,
3l4ll Cf^t and Rug Mills
1M9"9 JjI"Cjjgr Textile Product Mills n ' . ";
9*2 ""Tire "Cord and Tire Fabric Mills
314999 All cither Miscellaneous Textile Product Mills
IHt'ii IJIIM liir^/Ullllllll1 llllllllllll III II I I 'it I1'1 "': "III 1
315 Apparel Manufacturing
315111 Sheer Hosiery Mills
31522 Men's and Boys' Cut and Sew Apparel
321 Wood Product Manufacturing
321219 Reconstituted Wood Product Manufacturing
322 Paper Manufacturing
32211 Pulp Mills
32212 Paper Mills
322121 Paper (except Newsprint) Mills
322122 "New^Qtlfflis "_ '[" ' ^
32213" Paper)>oard'MTUs
323 Printing and Related Support Activities
323 111 Commercial Gravure Printing
323117 Book Printing
323119 Other Commercial Printing
324 Petroleum and Coal Products Manufacturing
32411 Petroleum Refineries
324121 Asphalt Paving Mixture and Block
Manufacturing
324191 Petroleum Lubricating Oil and Grease
Manufacturing
324199 All Other Petroleum and Coal Products
• Manufacturing
325 Chemical Manufacturing
3251 Basic Chemical Manufacturing
32511 Petrochemical Manufacturing
"32512 InoTratn^'G^'Manu^niifog
32513 Synthetic Dye and Pigment Manufacturing
325131 Inorganic Dye and Pigment Manufacturing
325132 Synthetic Organic Dye and Pigment
Manufacturing
32518 Other Basic Inorganic Chemical Manufacturing
325181 Alkalies and Chlorine Manufacturing
325182 Carbon Black Manufacturing
325188 All Other Basic Inorganic Chemical
Manufacturing
32519 Other Basic Organic Chemical Manufacturing
325191 Giim aid Wood Chemical Manufacturing
325192 Cyclic Crude and Intermediate Manufacturing
325193 Ethyl Alcohol Manufacturing
325199 All other Basic'jOrganic Chemical
Manufacturing
3252 Resin, Synthetic Rubber, and Artificial and
Synthetic Fibers and Filaments Manufacturing
32521""" ''''
325211
"325212
32522 Artificial and Synthetic Fibers and Filaments
"••-i' !!• : *" «• «'' I" Manufacturing
325221 CeliuTosic' Qrgamc Fiber' Manufacturing
325222 Noncellulosic Organic Fiber Manufacturing
3253 Pesticide, Fertilizer and Other Agricultural
Chemical Manufacturing
32531 Fertilizer Manufacturing
325311 Nitrogenous Fertilizer Manufacturing
325312 Phosphatic Fertilizer Manufacturing
325314 Fertilizer (Mixing Only) Manufacturing
32532 Pesticide and Other Agricultural Chemical
Manufacturing
3254 Pharmaceutical and Medicine Manufacturing
32541 PEaninaceuticaf and Medicine Manufacturing
32"54"l1 Medicinal and' Botamcaf Manufacturing
325412 Pharmaceutical Preparation Manufacturing
325413 In-Vitro Diagnostic Substance Manufacturing
325414 Biological Product (except Diagnostic)
Manufacturing
3255 Paint, Coating, and Adhesive Manufacturing
32551 Paint and .Coating Manufacturing
32552 Adhesive Manufacturing
3256 Soap, Cleaning Compound and Toilet Preparation
Manufacturing
32561 Soap and Cleaning Compound Manufacturing
325611 Soap and Other Detergent Manufacturing
-------
B-3
Appendix B
NAICS Codes
325612 Polish and Other Sanitation Good Manufacturing
325613 Surface Active Agent Manufacturing
32562 Toilet Preparation Manufacturing
3259 Other Chemical Product Manufacturing
32591 Printing Ink Manufacturing
32592 Explosives Manufacturing
32599 All Other Chemical Product and Preparation
Manufacturing
325991 Custom Compounding of Purchased Resin
325992 Photographic Film, Paper, Plate and Chemical
Manufacturing
325998 All Other Miscellaneous Chemical Product
and Preparation Manufacturing
326 Plastics and Rubber Products Manufacturing
32611 Unsupported Plastics Film, Sheet and Bag
Manufacturing
326113 Unsupported Plastics Finn and Sheet (except
Packaging) Manufacturing
326121 Unsupported Plastics Profile Shape
Manufacturing
32613 Laminated Plastics Plate, Sheet and Shape
Manufacturing
32614 Polystyrene Foam Product Manufacturing
32615 Urethane and Other Foam Product (except
Polystyrene) Manufacturing
32616 Plastics Bottle Manufacturing
32619 Other Plastics Product Manufacturing
326192 Resilient Floor Covering Manufacturing
326199 All Other Plastics Product Manufacturing
3262 Rubber Product Manufacturing
326211 Tire Manufacturing (except Retreading)
32629 Other Rubber Product Manufacturing
326299 All Other Rubber Product Manufacturing
327 Nonmetallic Mineral Product Manufacturing
32711 Pottery, Ceramics, and Plumbing Fixture
Manufacturing
327 111 Vitreous China Plumbing Fixtures and China
and Earthenware Bathroom Accessories
Manufacturing
327125 Nonclay Refractory Manufacturing
32721 Glass and Glass Product Manufacturing
327211 Flat Glass Manufacturing
327212 Other Pressed and Blown Glass and Glassware
Manufacturing
327213 Glass Container Manufacturing
327215 Glass Product Manufacturing Made of
Purchased Glass
32731 Cement Manufacturing
32732 Ready-Mix Concrete Manufacturing
32739 Other Concrete Product Manufacturing
32742 Gypsum Product Manufacturing
32791 Abrasive Product Manufacturing
327992 Ground or Treated Mineral and Earth
Manufacturing
327993 Mineral Wool Manufacturing
327999 All Other Miscellaneous Nonmetallic Mineral
Product Manufacturing
331 Primary Metal Manufacturing
33111 Iron and Steel Mills and Ferroalloy Manufacturing
331111 Iron and Steel Mills
331312 Primary Aluminum Production
331314 Secondary Smelting and Alloying of Aluminum
331315 Aluminum Sheet, Plate and Foil Manufacturing
331316 Aluminum Extruded Product Manufacturing
331319 Other Aluminum Rolling and Drawing
33141 Nonferrous Metal (except Aluminum) Smelting
and Refining
331411 Primary Smelting and Refining of Copper
331419 Primary Smelting and Refining of Nonferrous
Metal (except Copper and Aluminum)
331421 Copper Rolling, Drawing and Extruding
331423 Secondary Smelting, Refining, and Alloying of
Copper
33149 Nonferrous Metal (except Copper and
Aluminum) Rolling, Drawing, Extruding and
Alloying
3 31491 Nonferrous Metal (except Copper and
Aluminum) Rolling, Drawing and Extruding
331492 Secondary Smelting, Refining, and Alloying of
Nonferrous Metal (except Copper and
Aluminum)
33151 Ferrous Metal Foundries
331511 Iron Foundries
331513 Steel Foundries, (except Investment)
33152 Nonferrous Metal Foundries
331521 Aluminum Die-Casting Foundries
331522 Nonferrous (except Aluminum) Die-Casting
Foundries
331524 Aluminum Foundries (except Die-Casting)
331525 Copper Foundries (except Die-Casting)
331528 Other Nonferrous Foundries (except Die-
Casting)
332 Fabricated Metal Product Manufacturing
33211 Forging and Stamping
332111 Iron and Steel Forging
332112 Nonferrous Forging
332116 Metal Stamping
332117 Powder Metallurgy Part Manufacturing
33221 Cutlery and Hand Tool Manufacturing
332211 Cutlery and Flatware (except Precious)
Manufacturing
332321 Metal Window and Door Manufacturing
332322 Sheet Metal Work Manufacturing
33243 Metal Can, Box, and Other Metal Container
(Light Gauge) Manufacturing
33251 Hardware Manufacturing
-------
liili''!;!!:tl
liiiill''!!!'!-!1
I I' III (I
i!!!1'
iiiiil.
..I f
M'. "t
4 itji t-iij.
'S'l;!' ;: i
'i'i. "i. i,
Liis:F"ii'i
Appendix B
NAICS Codes
B-4
332612 Spring (Light Gauge) Manufacturing
33281 Coating, Engraving, Heat Treating, and Allied
Activities
332811 Metal Heat Treating
332812 Metal Coating, Engraving (except Jewelry and
Silverware), and Allied Services to
~ ~ ;„;;', " ; ~ Manufacturers
J332813 :: Electroplating, Plating, Polishing, Anodizing
and Coloring
132912 Fluid Power Valve and Hose Fitting
iiiiiiR M'irtsss&as^g
332919 dffier'Mdai' Valve and Pipe Fitting
''i1:,! Illlll I mill |ii|i|i i«j - -"i j r i
:=:=:;:: Manufacturing
33299 All Other Fabricated Metal Product Manufacturing
332991 Ball and Roller Bearing Manufacturing
332992 Small Arms Ammunition Manufacturing
332999 All Other Miscellaneous Fabricated Metal
Product Manufacturing
333 Machinery Manufacturing
33311 Agricultural Implement Manufacturing
333111 Farm Machinery and Equipment Manufacturing
333112 Lawn and Garden Tractor and Home Lawn and
Garden Equipment Manufacturing
33312 Construction Machinery Manufacturing
333295 Semiconductor Machinery Manufacturing
333298 All Other Industrial Machinery Manufacturing
333311 Automatic Vending Machine Manufacturing
333314 Optical Instrument and Lens Manufacturing
333315 Photographic and Photocopying Equipment
Manufacturing
, ^S|f j 7^p^^g1^^™^(ai|an^^e^c^ Industry
M. , ;••;;:;i;"';' ;';;, I;.1. Machingry Manufacturing
arm Air Heating
Ipment and Commercial and Industrial
!g_era3pn Equigment ft^ffactujirig
iiaii 'a1 ,',;•* rill!;":
;!,. 33351 Mejalworking_ Machinery Manufacturing
; ! ; 333511 ' IndustrialiMpl«;u,, • < i < «< ,
Inductor Manufacturing
334417 Electronic Connector Manufacturing
334418 Printed Circuit Assembly (Electronic
Assembly) Manufacturing
334419 Other Electronic Component Manufacturing
334519 OlierMeisuririg arid Controlling Device
Manufacturing
334613 Magnetic and Optical Recording Media
Manufacturing
335 Electrical Equipment, Appliance and
Component Manufacturing
33511 Electric Lamp Bulb and Part Manufacturing
335122 Commercial, Industrial and Institutional
Electric Lighting Fixture Manufacturing
335129 Other Lighting Equipment Manufacturing
33522 Major Appliance Manufacturing
335222 Household Refrigerator and Home Freezer
Manufacturing
33"53 i !Ellecn^c:Q'E\]mpHent' Manufacturing
335311 Power, Distribution arid Specialty Transformer
Manufacturing
335312 Motor and Generator Manufacturing
33591 Battery Manufacturing
335911 Storage Battery Manufacturing
335912 Primary Battery Manufacturing
335921 FibierOptic Cable Maniifacturirig
33599
.
',333996 HuidPpwer,Puinp and Motor Manufacturing
333999 All Other Miscellaneous General Purpose
Machinery Manufacturing
All Other Electrical Equipment and
Component Manufacturing
" llll-ollgu'cl t Mariufacturing
TETecffi
and Component Manufacturing
336 Transportation Equipment Manufacturing
3361 1 A'utb'mo&Ue and Light Duty Motor Vehicle
'"'i"1'!!*'*!11 Klllll f'hi1,
"n iliiiii1 in: |: ' ,11 I'l
; ; 1
-------
B-5
Appendix B
NAICS Codes
Manufacturing
336111 Automobile Manufacturing
336112 Light Truck and Utility Vehicle Manufacturing
33612 Heavy Duty Truck Manufacturing
33 621 Motor Vehicle Body and Trailer Manufacturing
336211 Motor Vehicle Body Manufacturing
336212 Track Trailer Manufacturing
336213 Motor Home Manufacturing
336214 Travel Trailer and Camper Manufacturing
33631 Motor Vehicle Gasoline Engine and Engine Parts
Manufacturing
336311 Carburetor, Piston, Piston Ring and Valve
Manufacturing
336312 Gasoline Engine and Engine Parts Manufacturing
33632 Motor Vehicle Electrical and Electronic
Equipment Manufacturing
33 6321 Vehicular Lighting Equipment Manufacturing
336322 Other Motor Vehicle Electrical and Electronic
Equipment Manufacturing
33633 Motor Vehicle Steering and Suspension
Components (except Spring) Manufacturing
33634 Motor Vehicle Brake System Manufacturing
33635 Motor Vehicle Transmission and Power Train
Parts Manufacturing
33636 Motor Vehicle Seating and Interior Trim
Manufacturing
33637 Motor Vehicle Metal Stamping
33639 Other Motor Vehicle Parts Manufacturing
336391 Motor Vehicle Air-Conditioning Manufacturing
336399 All Other Motor Vehicle Parts Manufacturing
33641 Aerospace Product and Parts Manufacturing
336411 Aircraft Manufacturing
336412 Aircraft Engine and Engine Parts Manufacturing
336413 Other Aircraft Part and Auxiliary Equipment
Manufacturing
336414 Guided Missile and Space Vehicle
Manufacturing
336415 Guided Missile and Space Vehicle Propulsion
Unit and Propulsion Unit Parts Manufacturing
336419 Other Guided Missile and Space Vehicle Parts
and Auxiliary Equipment Manufacturing
33651 Railroad Rolling Stock Manufacturing
33661 Ship and Boat Building
336611 Ship Building and Repairing
336612 Boat Building
33699 Other Transportation Equipment Manufacturing
336991 Motorcycle, Bicycle and Parts Manufacturing
336992 Military Armored Vehicle, Tank and Tank .
Component Manufacturing
336999 All Other Transportation Equipment
Manufacturing
337 Furniture and Related Product Manufacturing
33712 Household and Institutional Furniture
Manufacturing
337211 Wood Office Furniture Manufacturing
339 Miscellaneous Manufacturing
33911 Medical Equipment and Supplies Manufacturing
339112 Surgical and Medical Instrument Manufacturing
33 9113 Surgical Appliance and Supplies Manufacturing
339114 Dental Equipment and Supplies Manufacturing
3399 Other Miscellaneous Manufacturing
33991 Jewelry and Silverware Manufacturing
339911 Jewelry (except Costume) Manufacturing
339912 Silverware and Plated Ware Manufacturing
339913 Jewelers' Material and Lapidary Work
Manufacturing
339914 Costume Jewelry and Novelty Manufacturing
339991 Gasket, Packing, and Sealing Device
Manufacturing
339994 Broom, Brush and Mop Manufacturing
339999 All Other Miscellaneous Manufacturing
42 Wholesale Trade
421 Wholesale Trade, Durable Goods
42149 Other Professional Equipment and Supplies
42171 Hardware Wholesalers
42181 Construction and Mining Machinery
42184 Industrial Supplies
422 Wholesale Trade, Nondurable Goods
42211 Printing and Writing Paper Wholesalers
4224 Grocery and Related Product Wholesalers
42241 General Line Grocery Wholesalers
42242 Packaged Frozen Food Wholesalers
42243 Dairy Product (except Dried or Canned)
Wholesalers
42244 Poultry and Poultry Product Wholesalers
42246 Fish and Seafood Wholesalers
42247 Meat and Meat Product Wholesalers
42248 Fresh Fruit and Vegetable Wholesalers
42249 Other Grocery and Related Products Wholesalers
4225 Farm Product Raw Material Wholesalers
42251 Grain and Field Bean Wholesalers
42252 Livestock Wholesalers
42259 Other Farm Product Raw Material Wholesalers
4226 Chemical and Allied Products Wholesalers
42261 Plastics Materials and Basic Forms and Shapes
Wholesalers
42269 Other Chemical and Allied Products Wholesalers
42271 Petroleum Bulk Stations and Terminals
42272 Petroleum and Petroleum Products Wholesalers
(except Bulk Stations and Terminals)
42281 Beer and Ale Wholesalers
42282 Wine and Distilled Alcoholic Beverage
Wholesalers
4229 Miscellaneous Nondurable Goods Wholesalers
42291 Farm Supplies Wholesalers
42299 Other Miscellaneous Nondurable Goods
-------
Ill II 111 I IIIII
III ill II 1111
Appendix B
NAICS Codes
B-6
in:::'n::niniiniiiiiiiii ","n n.. 'n::ii:, r. r *
I ' :'!" 'I'll! 111!!:'!1
II riii*:!1
44-45 Retail Trade
4441 Building Material and Supplies Dealers
44422 Nursery and" Garden Centers
-"! - i'"!' :!!445"j i Grocery Stores
44523 Fruit and Vegetable Markets
44711 Gasoline Stations
vl,,"' ','' | 45291 WarehouseClubsandSuperstores
"I ! 45399 All "5" therffiscelianeous Store Retailers'
Hif iftffii* 81! J 'V;: i' I3&49 Transportation and Warehousing
488 Support Activities for Transportation
48311 Water Transportation
4842 Specialized Freight Trucking
" ' =,48511 Urban Transit Systems
/I;™ 'ii;"!:i, i-1™' ;;- i ":' 1486 Pipeline Transportation
""' 'MMKrl'-SSSli AS^artQpMations
488119 Other Airport Operations
48819 Other Support Activities for Air Transportation
48821 Support Activities for Rail Transportation
j^^, ,,,i' i;».jis'4;8832 Marine.Cargo Handling
'48839 6Ser Support Activities for Water Transportation
! "i: i' !iin| Ill I
493 Warehousing and Storage
',, is49311 General Warehousing and Storage
49312 Refrigerated Warehousing and Storage
49313 Farm Product Warehousing and Storage
19319 Other Warehousing and Storage
54 Professional, Scientific, and Technical Services
- 54138 Testing Labs
54171 Research"and" Development inftfie Physical,
Engineering, and Life Sciences
ll 11 iiiiiiiiiiiiiiiiiiiiiiii1 i kii'itfi 'owJjf.ijP .:!!< riil; i'!!'1'1';^''
56 Administrative and Support, Waste Management
and Remediation Services
561431 Private Mail Centers
56179 Other Services to Buildings
56221 Waste Treatment and Disposal
562211 Hazardous Waste Treatment and Disposal
562212 Solid Waste Landfill
562213 Solid Waste Combustors and Incinerators
ll'lil,!1 m ', In, II nil 111111111 ' 1. i Illlllllllllll IT] III ill linn II I i 111 II in III! 1 IIIIIIIIIIIIIIIIIIIIIIII III! I 1111 ll I IIIII I III I IIIII ill II ll III I II .'ill 11 :
562219 Other Nonhazardous Waste Treatment and
I, IK nil ."'hi' 'I ,[„ nl1' 'Ii:! .11 1!:. Mi. liiiini i in i ii in I iin|iiininin iiiii 11111 nil 11111 ill ii 1 i i V '.::..:', n J /
i in Disposal
Iiiiit I !Tj S'lilr, :J •!;;'!'' 15629 Remediation and Other Waste Management
IWii'.'i'i. K'!«,,! ^SS5
K I;; ^^:,\$&i M&<&ti°z§^^ ., .:.;;
!!,!;' '."!*:!:"* ::"!f' "ld i" 5^292 Materials Recovery Faculties
—;':; -;';':'':"-;:'; ' ' - 56299 All OAer Waste Management Services
562998 All Other Miscellaneous Waste Management
Services
iiiii'illl'H ir i n ',11:;; LI,,',
I'iKilP t KT ,:J!$t¥
I1',11! llii'S'i''^!'!:!''! ill 1W1!',
ill"! M: F nil.)1"" FJiIIIhll'i , 'iinillillllllT •: is il» "
»' n "'i' iii!! ill'. , ' ii'i'lli!1 II i'ulFliiirnii !«' " ' n,
N* i,' ''» IIPII; ' ,1':? I'm' i1 HiiiM ' ;,< v ,
61 Educational Services
6111 Elementary and Secondary Schools
. .,,,_^,_,,__ J____ M __,
62 Health Care and Social Assistance
62151 Medical and Diagnostic Laboratories
621511 •^~gjg2[llllLab"b'ra'tories
62211 General Medical and Surgical Hospitals
6222 Psychiatric and Substance Abuse Hospitals
62221 Psychiatric and Substance Abuse Hospitals
6223 S"pecia!ry"(excejrt¥^nhn:ic and Substance
Abuse) Hospitals
62231 Specialty (except Psychiatric and Substance
Abuse) Hospitals
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-------
APPENDIX C
TECHNICAL ASSISTANCE
May 12,2000
-------
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-------
C-l
Appendix C
Technical Assistance
APPENDIX C: TECHNICAL ASSISTANCE
WHERE CAN I GET HELP?
This appendix provides points of contact for the resources that are available to facilities
in complying with 40 CFR part 68 from EPA, OSHA, and several other entities involved
in process safety and risk management issues. For specific points of contact for EPA
regional offices, RMP implementing agencies, and Clean Air Act small business
assistance programs, refer to Appendix C. For specific points of contact for OSHA
regional offices, OSHA state consultative programs, and OSHA state plan states, refer to
Appendix D.
U.S. ENVIRONMENTAL PROTECTION AGENCY
+ Chemical Emergency Preparedness and Prevention Office
1200 Pennsylvania Ave, NW (Mailcode 5104)
Washington, DC 20460
(202) 260-8600
www.epa.gov/ceppo/
CEPPO administers the RMP program at the national level. The CEPPO
homepage on the Internet provides access to downloadable versions of numerous
risk management program documents, many of which are also available upon
request from the National Center for Environmental Publications and
Information, see below. For specific points of contact for EPA regional offices,
RMP implementing agencies, and Clean Air Act small business assistance
programs, check the CEPPO web site.
+ EPCRA/Superfund/RCRA/CAA Hotline
Toll-Free: (800) 424-9346
Local: (703)412-9810
TDD: (800)553-7672
TDD Local: (703)412-3323
Monday - Friday, 9:00 am - 6:00 pm EST
www.epa.gov/epaoswer/hotline/index.htm
Questions or comments: epahotline@bah.com
EPA's RCRA, Superfund, and EPCRA Hotline is a publicly accessible service
that provides up-to-date information on EPA programs. The Hotline responds to
factual questions on a variety of federal EPA regulations, including those
developed under Clean Air Act section 112(r). The Hotline also responds to
requests for individual copies of documents.
May 12, 2000
-------
Appendix C
Technical Assistance
C-2
iilS.K M'
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4- National Service Center for Environmental Publications
„,-. ;,' , ,,;' H .-. .,E,O. Box42419 '
±i'::siff: mm ',"«" Cincmnati, OH 45242
Phone: (800)490-9198
;•-.•;';£;; ;"=. .".' Fax: (513) 489-8695
www.epa.gov/ncepihom/
i"1' .: jiiii ji liiHiiniinii, ii>,, ' \ " 'i i i
,.-.: ... ,!!'•',, :'iBiiiiii'' si'T '"'i' :::"i i i i i i i i i m i i i HI mi inn
•Si i;" ;;' ii : : «i| iiSm, -I, i Y;.^ ^Orders must be Umited to five titles per two-week period, one complimentary
copy of each in-stock publication. As supplies are depleted you will be referred
•it J1, ' '": is '*:;S'i' sf§r$ '• !'tQ the National Technical Information Service (NTIS), the Government Printing
Office (GPO), or the Educational Resource Information Center (ERIC) to obtain
your documents at cost.
Ii'+r1!11!''!1;]!1
•lUr :,illi
'in, i"
National Technical Information Service
Technology Administration
U.S. Department of Commerce
II I II IN 111 ^ I, .,, ,1, , , ,p ,; , ,,... ,1, , .
' :
Springfield, VA 22161
Phone: (800) 553-6847 (toll-free)
liiiii!"! !!'„.:!;' llf'ii'li'iiilli ', ' '
, 8:00 -8:00 pmEST
Fax: |703) 321-8547 (verify receipt at (703) 487-4679)
..--'. —".' wwwiitis.gov/
i'iii ..... » \iiiiii i1;.! ..... ,i» ...... \m ........ » ....... n ...... « .................. =v • ^. A. - , tj
E-Mail: orders@ntis.fedworld.gov
•
:;'; '
..... M 4" .: m ' :'*!"
;: 'the ..... !?&lonal Technical Information Service is the official resource for
;;:io^
! • "and business-related information. Documents not available through the EPA
f ; i HoflSe "aye pften'^^HliBle i fro
mail, fax, or e-mail. NTIS also offers online ordering for products added to the
NTIS collection within the last 90 days using NTIS OrderNow.
i'liiTJili . i1 "iliil An.
" ' iiiiri,,,i w " .iii1' ; « nin.;. iii.Ji.:!.:1'" mi iumniiiJiiiiii'iuiiti „ ,i iniii'1 :, nmr. I'.Niii.LhiiiJiiiiiiihJin /r-i* iiinunni':! iimuu
EPA Small Business Assistance Program
.>!,' "nlM iJ'BHlf'l
! B'i! ..in IT'S i i;: ;
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';"»" i 'II?' - III 'i :'!•„:'::: TJje"Cleani Aiir Act iA^endmeitits oFl990 "requires '&at'all" States' develop a
' "
,wn
p^ro:gf anl to assist small businesses in meeting the requirements of the Act. EPA
!!!!ii',;!;;,'« iias""estat)Ssh'ed its own Small Business Assistance Program 7§g_^|K ^o prOvicie
i fi|;|i||i|i. i <'t iii': jn'w^ liiiii' (iiiiin:'!' "ii in" i']ii:Hii!i i; ' 'iiiiii,'j|gvg|pped to allow State and EPA programs to share information about their
"I. jilii1:, 'liii'iisi'";!'', ;,,""smali business assistance materials and activities.
i;""
IIP |M|JI.I ;;l|iii'::" j iiKi {ii> I'l:: »r •* iii} >• EPA Small Business Hotline
I? I? in |. ""I'll1! 1 'I'11 II "iii I'.r '"'P llllH'i|.lJ*l|l.; J'. H ' ' I;1' !*i,uiHlf I. JlJIIIili ,|l" ' Ill, I1 »h I "IIIII Ill BKiiU'lilllil. 'Ill "TH| ill' H;,.,.',»| illllU JIR ,nll illHilliNiiiini"!! lu.ln ! Ill !,•;, > , .. '"'Mill, il
Small Business Ombudsman Office
i,;;;;;;,;;;:; ;;;;;;";;-", '£ ;„;;;' :;,Mty 12,2000
1***. ':'• IIIIIF1!1 'I'1"'! ''i,,!1 ; iii ,I!1!
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-------
C-3
Appendix C
Technical Assistance
+ Office of Air Quality Planning and Standards
www.epa.gov/oar/oaqps/
The Office of Air Quality Planning and Standards administers EPA's operating
permit program. Permits incorporate terms and conditions to assure that the
source complies with all applicable requirements. The RMP regulations are
considered to be an applicable requirement.
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA)
OSHA administers the Process Safety Management Standard (29 CFR 1910.119), which
mandates actions similar to that of EPA's prevention program. For specific points of
contact for OSHA regional offices, OSHA state consultative programs, and OSHA state
plan states, see the OSHA web site.
+ Office of Information and Consumer Affairs
U.S. Department of Labor
RoomN3647
200 Constitution Avenue, NW
Washington, DC 20210
(202) 523-8151
www.osha.gov
+ OSHA Process Safety Management Homepage
www.osha-slc.gov/SLTC/processsafetymanagement/index.hmil
The PSM homepage on the Internet provides access to downloadable versions of
numerous process safety management documents.
+ OSHA Consultation Services
www.osha.gov/oshprogs/consult.html
Using a free consultation service largely funded by OSHA, employers can find
out about potential hazards at their worksites, improve their occupational safety
and health management systems, and even qualify for a one-year exemption from
routine OSHA inspections. Primarily targeted for smaller businesses, this safety
and health consultation program is completely separate from the OSHA
inspection effort.
+ OSHA Office of Training & Education
Head Registrar
OSHA Training Institute
Des Plaines, Illinois
(847) 297-4913
www.osha-slc.gov/Training/index.html
May 12, 2000
-------
WSItMI»* I
III IE "m *i m ill »'.•,::•" :^:V^:/^';V;^!^^.:jiv. *:&m.*i$'' !J«*tt.-i 1.3 iHO»
I
Appendix C
Technical Assistance C-4
The OSHA Office of Training and Educatibn offers short-term training through
the OSHA Training Institute. The Office also administers the OSHA Training
1 11 PI i i ' V ll II I1 I "I nil Institute Education Centers prograin7 in which clesignated1 nonprofit
organizations in each federal region offer the most frequently requested courses
for the private sector and other Federal agency staff.
I! ;s
+ OSHA Voluntary Protection Program (VPP)
Division of Voluntary Programs
(202) 219-7266
www.osha.gov/oshprogs/vpp/osha2.html
I || i 1111 in in LI I HI ill I ecXj i ..ML: fa' !« »•' j- " <•• "•'•
OSHA Voluntary Protection Programs are designed to recognize and promote
effective safety and health management. In the VPP, management, labor, and
OSHA establish a cooperative relationship at a workplace that has implemented
i,!lr 1!. in si.' ' IK1"! I,, ,:,•!" ,|. i "ijfi 'IJ Jim.m hflilli: ,•» ! »'",:.'•" P^^'ili!11!11 lii.irilliiD,'''^ 1IIIIM!!! '» "Hi"HI Jill'1 :""i I'l'iB in Irv'ln , li1 ffnir"11" in h'VH il ; IVIIL. i 'iiiiiiiXW.!,'., nil1;,,,'h lillilifj, jI'Miniiri,,,! in 41 < ||, , ,..,| ' iii;,,,!!, , ||| |||||||| III
a strong program.
Ill
t
ill II'lull
hi 111 ' iliiill
I'll l il "ill
OSHA Publications Office
H inn HI in i mi in i i n n n 1 1 ii
Room N3 101
Washington, DC 20210
(202) 523-9667
II i II I i I II i i I II1 I I i
The Publications Office provides single copies of various documents.
ion System
www.bsha.gov/
This site provides links to OSHA Standards and related documents, including
OSHA Regulations, Federal Register notices, Interpretations and Compliance
letters, OSHA Regulations '(pre^bleilo'rfiiarrule's), Review Commission
decisiOTi^'Con^ssibrM'Testimonj^1 OSHA Directives and Fact Sheets,
Memorandums of Understanding.
IJTJ;,!!1 III;1,;!!1,!'" ........ !«: ....... '" ',,!,;, 'iJ!1!11! {i'.iiiil :" ''I'11"! ....... ' ;' »!.'". , .v, ...... •• .......... "R, 'i,, ...... likMSMl ............... »,. ....... ....... ....... ||tr '' ...... i'. ' ', 'i !• -Ti1
1
OSHA CD-ROM
Windows and Macintosh dual platform
U.S. (jovernment jpjj^gig office
Stock| 729-013-00000-5
Phone: (202)512-1866
Fax: (202)512-2250
Price: $38/year (four quarterly releases), $15 (single copy)
This CD-ROM contains electronic copy of the text of all OSHA regulations,
selected documents, and technical information from the OSHA Computerized
Information System.
May 12,2000
-------
C-5
Appendix C
Technical Assistance
OTHER ORGANIZATIONS
Association of Metropolitan Sewerage Agencies
1000 Connecticut Avenue, NW, Suite 410
Washington D.C. 20036-5302
Phone: (202) 833-AMSA
Fax: (202) 833-4657
http://www.amsa-cleanwater.org/
American Water Works Association
6666 Quincy Ave.
Denver, CO 80235
(303)794-7711
www.awwa.org/
AWWA has prepared a model risk management program for its members.
Chlorine Institute
Publications Coordinator
2001 L St. NW, Suite 506
Washington, DC 20005
(202) 223-7225
www.cl2.com
The Chlorine Institute has developed a model risk management program for
chlorine handlers. It also publishes guidance documents related to chlorine
handling and storage.
Compressed Gas Association
Publications Department
1725 Jefferson Davis Highway, Suite 1004
Arlington, VA 22202-4102
(703) 412-0900
www.cganet.com/
The Compressed Gas Association publishes a number of documents on the
handling of compressed gases, including ammonia and sulfur dioxide.
Water Environment Federation
601 Wythe St.
Alexandria, VA
(703) 684-2400
www.wef.org
May 12, 2000
-------
Appendix C
Technical Assistance
C-6
The Water Environment Federation publishes a number of documents on water
treatment, including operating and maintenance manuals for WWTPs.
+ American Institute of Chemical Engineers
345 E. 47th St.
New York, NY 10017-2395 '
(212)705-7338 '""
www.aiche.org/
Center for Chemical Process Safety
'; 345 E. 47th St., 12th EL '
New York, NY 10017-2395
(212)705-7319
www.aiche.org/ccps/
AIChExpress Service Center
(800) AIC-HEME p42^363)
Monday - Friday, 9:00 am - 5:00 pmEST
. E-Mail: xpress@aiche.org
AIChE prints a Continuing Education catalog for its educational and training
programs and an annual Publications Catalog from which documents can be
purchased.
1 ||i 111 , , 1,11 i|l 11 II ii III 1 i i ill | i (I i;',:! 'I':,1:.;,,; • ffaisHf' .1 "I1; i':. !•: Si1';;' •"'• i<::i' It;!* ini:!:** 1 Ifi I • ill! "I ';ii! •"!'! » I' 11, 'it i H" 1 !«'• i A ', i i «::'M'.! • •.," i1''.; •?': inf" HBI'I "BI : IIU
4- Small Business Administration (SBA)
409 Third Street, SW
Washington, DC 20416 '
(800)827-5722 |
www.sba.gov/
I 111 111 II11 I I II III I I II I i i ii i i ii i ii i ii i 111 ii i i i nil ii i n n mi in n in
SBA was created to help America's entrepreneurs form successful small
enterprises. SBA's program offices in every state offer financing, training and
advocacy for small firms. In addition, the SBA works with thousands of lending,
educational, and training institutions nationwide.
i
+ U.S. Government Printing Office
Superintendent of Documents
Washington, D'C"""2(MO"2
(202) 783-3238
1 ll" ' ||'Jill VN 'I' www.gpo.gov/su_docs/index.html
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i GPO Access User ..... Support Team
in E-mail: gpoaccess^olgov
I Phone: (202) 512-1530 (local)
I II III v ' ......... ...... ...... ...... ............. , ..... •• ...... > ............... it ...... ...... ' ..... 'i
il Phone: (888) 293-6498 (toll-free)
"Fax: :;"":l::";" : :': ""
i ;,.'.„;. jr. "i.~" .......... '."''",. ' '.'.'
,''., ij,:11 .'ifi.; i iiiHii'i1,,. ; "JIB1' iw:1'!,,, V: ""' 'I1' ',!' ':,,!' T!11'1! «,,lli!!1!',,11'11 "I1!1'1!!11!
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-------
APPENDIX D
OSHA GUIDANCE ON PSM
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-------
APPENDIX D
OSHA GUIDANCE ON PSM
The following text is taken directly from OSHA's non-mandatory appendix C to the PSM
standard (29 CFR 1910.119). The only change has been to rearrange the sections to track the order of
part 68.
PROCESS SAFETY INFORMATION
Complete and accurate written information concerning process chemicals, process technology, and
process equipment is essential to an effective process safety management program and to a process
hazards analysis. The compiled information will be a necessary resource to a variety of users including
the team that will perform the process hazards analysis; those developing the training programs and the
operating procedures; contractors whose employees will be working with the process; those conducting
the pre-startup reviews; local emergency preparedness planners; and insurance and enforcement officials.
The information to be compiled about the chemicals, including process intermediates, needs to be
comprehensive enough for an accurate assessment of the fire and explosion characteristics, reactivity
hazards, the safety and health hazards to workers, and the corrosion and erosion effects on the process
equipment and monitoring tools. Current material safety data sheet (MSDS) information can be used to
help meet this requirement, which must be supplemented with process chemistry information including
runaway reaction and over pressure hazards if applicable.
Process technology information will be a part of the process safety information package and it is
expected that it will include diagrams as well as employer established criteria for maximum inventory
levels for process chemicals; limits beyond which would be considered upset conditions; and a
qualitative estimate of the consequences or results of deviation that could occur if operating beyond the
established process limits. Employers are encouraged to use diagrams which will help users understand
the process.
A block flow diagram is used to show the major process equipment and interconnecting process flow
lines and show flow rates, stream composition, temperatures, and pressures when necessary for clarity.
The block flow diagram is a simplified diagram.
Process flow diagrams are more complex and will show all main flow streams including valves to
enhance the understanding of the process, as well as pressures and temperatures on all feed and product
lines within all major vessels, in and out of headers and heat exchangers, and points of pressure and
temperature control. Also, materials of construction information, pump capacities and pressure heads,
compressor horsepower and vessel design pressures and temperatures are shown when necessary for
clarity. In addition, major components of control loops are usually shown along with key utilities on
process flow diagrams. ;
Piping and instrument diagrams (P&IDS) may be the more appropriate type of diagrams to show some of
the above details and to display the information for the piping designer and engineering staff. The
P&IDS are to be used to describe the relationships between equipment and instrumentation as well as
other relevant information that will enhance clarity. Computer software programs which do P&IDS or
other diagrams useful to the information package, may be used to help meet this requirement.
-------
Appendix D
OSHA Guidance on PSM
D-2
I nil
The information pertaining to process equipment design must be documented. In other words, what were
the co i iiil|; ''iii ni 3i' Hiar !liiii; ^ jli ill b;: I'liii,1 '"",; si uSIii ^ iiii :' i,,' ,nii" iiii1,, <',5:, I » 1:, :'i iiii' ' iiiini ill' ;i • i Si |
A process hazard analysis £pj|^ sometimes called a process hazard evaluation, is one of the most
important elements of the process safety management program. A PHA is an organized and systematic
effort to identify and analyze the significance of potential hazards associated with the processing or
handling of highly hazardous chemicals. A PHA provides information which will assist employers and
employees hi making decisions for improving safety and reducing the consequences of unwanted or
unplanned releases of hazardous chemicals.
A PHATis directed toward analyzing potential causes and consequences of fires, explosions, releases of
toxic or flammable chemicals and major spills of hazardous chemicals. The PHA focuses on equipment,
instrumentation, utilities, human actions (routine and^non-routine), and[external factors mat rmght impact
the process. These considerations assist hi determining the hazards and potential failure points or failure
modes hi a process.
The selection of a PHA methodology or technique will be influenced by many factors including the
amount of existing knowledge about the process. Is it a process that has been operated for a long period
of time with little or no innovation and extensive experience has been generated with its use? Or, is it a
pew process or one which has been changed frequently by the inclusion of innovative features? Also, the
size and complexity of the process will influence the"decisibn"ai'fo"me-ppr-p^a'tebpjj^ 'meBtodology to"
use. All PHA methodologies are subject to certain limitations. For example, the checklist methodology
works well when the process is very stable and no changes are ma3e, but it is not as effective when the
process has undergone extensive change. The checklist may miss the most recent changes and
consequently the changes would not be evaluated. Another limitation to be considered concerns the
assumptions made by the team or analyst The p'jJA is dependent on good judgment and the assumptions
made during the study need to be documented and understood by the team and reviewer and kept for a
future PHA.
-------
D-3
Appendix D
OSHA Guidance on PSM
The team conducting the PHA need to understand the methodology that is going to be used. A PHA team
can vary in size from two people to a number of people with varied operational and technical
backgrounds. Some team members may only be a part of the team for a limited time. The team leader
needs to be fully knowledgeable in the proper implementation of the PHA methodology that is to be used
and should be impartial in the evaluation. The other full or part time team members need to provide the
team with expertise in areas such as process technology, process design, operating procedures and
practices, including how the work is actually performed, alarms, emergency procedures, instrumentation,
maintenance procedures, both routine and non-routine tasks, including how the tasks are authorized,
procurement of parts and supplies, safety and health, and any other relevant subject as the need dictates.
At least one team member must be familiar with the process.
The ideal team will have an intimate knowledge of the standards, codes, specifications and regulations
applicable to the process being studied. The selected team members need to be compatible and the team
leader needs to be able to manage the team and the PHA study. The team needs to be able to work
together while benefiting from the expertise of others on the team or outside the team, to resolve issues,
and to forge a consensus on the findings of the study and the recommendations.
The application of a PHA to a process may involve the use of different methodologies for various parts of
the process. For example, a process involving a series of unit operations of varying sizes, complexities,
and ages may use different methodologies and team members for each operation. Then the conclusions
can be integrated into one final study and evaluation.
A more specific example is the use of a checklist PHA for a standard boiler or heat exchanger and the use
of a Hazard and Operability PHA for the overall process. Also, for batch type processes like custom
batch operations, a generic PHA of a representative batch may be used where there are only small
changes of monomer or other ingredient ratios and the chemistry is documented for the full range and
ratio of batch ingredients. Another process that might consider using a generic type of PHA is a gas
plant. Often these plants are simply moved from site to site and therefore, a generic PHA may be used
for these movable plants. Also, when an employer has several similar size gas plants and no sour gas is
being processed at the site, then a generic PHA is feasible as long as the variations of the individual sites
are accounted for in the PHA.
Finally, when an employer has a large continuous process which has several control rooms for different
portions of the process such as for a distillation tower and a blending operation, the employer may wish
to do each segment separately and then integrate the final results.
Additionally, small businesses which are covered by this rule, will often have processes that have less
storage volume, less capacity, and less complicated than processes at a large facility. Therefore, OSHA
would anticipate that the less complex methodologies would be used to meet the process hazard analysis
criteria in the standard. These process hazard analyses can be done in less time and with a few people
being involved. A less complex process generally means that less data, P&EDS, and process information
is needed to perform a process hazard analysis.
Many small businesses have processes that are not unique, such as cold storage lockers or water
treatment facilities. Where employer associations have a number of members with such facilities, a
generic PHA, evolved from a checklist or what-if questions, could be developed and used by each
employer effectively to reflect his/her particular process; this would simplify compliance for them.
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Appendix D
OSHA Guidance on PSM D-4 _^
When the employer has a number of processes which require a PHA, the employer must set up a priority
system of which pjjAs to conduct first. A preliminary or gross hazard analysis may be useful in
prioritizing the processes that the employer has determined are subject to coverage by the process safety
management standard. Consideration should first be given to those processes with the potential of
adversely affecting the largest number of employees. This prioritizing should consider the potential
seventy of a chemical release, the number of potentially affected employees, the operating history of the
process such as the frequency of chemical releases, the age of the process and any other relevant factors.
These factors would suggest a ranking order and would suggest either using a weighing factor system or
gsysternatic ranking method. The use of a preliminary hazard analysis would assist an employer in
determining wn|cJJ process sHouTc! ge of the gj^gg^ priority and thereby the employer would obtain the
i 11f:!lj| ,!v!";f.^^e^'Sp^ren^flunL saYeity at me fecility.
II il 4'! ^i^B'Plfliiilvlli 3?:j 'Ill s^'M^fflflfli 'i( & '
OPERATING PROCEDURES
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Operating procedures describe tasks to be performed, data to be recorded, operating conditions to be
rflamtained^ samples to be collected^ and! safety and j^galth precautions to be taken. The procedures need
to be technically accurate, understandable to employees, and revised periodically to ensure that they
,; ^reflect current operations. The process safety information package is to be used as a resource to better
assure that the operating procedures and practices are consistent with the known hazards of the chemicals
;in the process and that the operating parameters are accurate. Operating procedures should be reviewed
j,|jll,|j| j|i i^'|'!);'^lKa£Jmeenn^1sialf and operating personnel to ensure that th'ey are accurate and provide practical
,L j, ,,, ,,,_,,, ^_^j|^ onhow |o actually"rarry'out job duties safely.
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Operating procedures will include specific instructions or details on what steps are to be taken or
followed in carrying out the stated procedures. These operating instructions for each procedure should
include the applicable safety precautions and should contain appropriate information on safety
i"|^ JIT ".!,[vp i, implications. For examplej me operating procedures addressing operating parameters will contain
•>:;M ',,,,; '-;1;'" operating mstmctioS^puTpreisufe h!mts,""temperatijre ranges, fI6w"rates, ^^ to ^o wnen an upset
subjects. Another example of'using operating instructions to properly implement operating procedures is
in starting up or shutting down the process. In these cases, different parameters will be required from
tnbsG of normal operation. These operating instructions need to clearly indicate the distinctions between
Startup and normal operations such as the appropriate allowances for heating up a unit to reach the
normal operating parameters. Also the operating instructions need to describe the proper method for
increasing the temperature of the unit until the normal operating temperature parameters are achieved.
liil'llin''!!!'! i'li' I'1!1 'ii I,, "il Illllllllll II 111 llllllllllllllllllll Illllllill II I I I I I III I II I II I Illlllll II III 11 Illlllll I I I II III l| Illlll I II III I I III III |l II
Computerized process control systems add complexity to operating instructions. These operating
•at i I'tsr^: ' \, Insfructipns neeif'Jg Describe the logic of the software as well as the relationship between trie equipment
iiil fifli'itri'ii ii ;!!,,; "i. Sad the control system; oth'erwise, it may not b"e apparent to the operator.
II';!"1!'' I!:! :ii|| V Operating procedures''^^ mstructions are J^QJ^J fQT Raining operating personnel. The operating
t^l^p. ,,;;;|ii;j|-f ,. ^ ^ p^c^ures'ai^f^en'view'eH'as'me"^^^ Oonirbl room
personnel and operating staff, in general, need to have a full understanding of operating procedures. If
workers are nol fluent in English then procedures and instructions need to be prepared in a second
language understood by the workers. In addition, operating procedures need to be changed when there is
a change in the p"rocessas;'a 'result of the management of change procedures. The consequences of
operating procedure changes need to be fully evaluated and the information conveyed to the personnel.
in ID i
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i
Nil 1
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D-5
Appendix D
OSHA Guidance on PSM
For example, mechanical changes to the process made by the maintenance department (like changing a
valve from steel to brass or other subtle changes) need to be evaluated to determine if operating
procedures and practices also need to be changed. All management of change actions must be
coordinated and integrated with current operating procedures and operating personnel must be oriented to
the changes in procedures before the change is made. When the process is shutdown to make a change,
then the operating procedures must be updated before startup of the process.
Training in how to handle upset conditions must be accomplished as well as what operating personnel are
to do in emergencies such as when a pump seal fails or a pipeline ruptures. Communication between
operating personnel and workers performing work within the process area, such as non-routine tasks, also
must be maintained. The hazards of the tasks are to be conveyed to operating personnel hi accordance
with established procedures and to those performing the actual tasks. When the work is completed,
operating personnel should be informed to provide closure on the job.
TRAINING
All employees, including maintenance and contractor employees, involved with highly hazardous
chemicals need to fully understand the safety and health hazards of the chemicals and processes they
work with for the protection of themselves, their fellow employees and the citizens of nearby
communities. Training conducted in compliance with 1910.1200, the Hazard Communication standard,
will help employees to be more knowledgeable about the chemicals they work with as well as familiarise-
them with reading and understanding MSDS. However, additional training in subjects such as operating
procedures and safety work practices, emergency evacuation and response, safety procedures, routine and
non-routine work authorization activities, and other areas pertinent to process safety and health will need
to be covered by an employer's training program.
In establishing their training programs, employers must clearly define the employees to be trained and
what subjects are to be covered in their training. Employers in setting up their training program will need
to clearly establish the goals and objectives they wish to achieve with the training that they provide to
their employees. The learning goals or objectives should be written hi clear measurable terms before the
training begins. These goals and objectives need to be tailored to each of the specific training modules or
segments. Employers should describe the important actions and conditions under which the employee
will demonstrate competence or knowledge as well as what is acceptable performance.
Hands-on-training where employees are able to use their senses beyond listening, will enhance learning.
For example, operating personnel, who will work in a control room or at control panels, would benefit by
being trained at a simulated control panel or panels. Upset conditions of various types could be
displayed on the simulator, and then the employee could go through the proper operating procedures to
bring the simulator panel back to the normal operating parameters. A training environment could be
created to help the trainee feel the full reality of the situation but, of course, under controlled conditions.
This realistic type of training can be very effective in teaching employees correct procedures while
allowing them to also see the consequences of what might happens if they do not follow established
operating procedures. Other training techniques using videos or on-the-job training can also be very
effective for teaching other job tasks, duties, or other important information. An effective training
program will allow the employee to fully participate in the training process and to practice their skill or
knowledge.
-------
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Appendix D
OSHA Guidance on PSM D-6
Employers need to periodically evaluate their training programs to see if the necessary skills, knowledge,
and routines are being properly understood and implemented by their trained employees. The means or
methods for evaluating the training should be developed §^onl ,T!?^^-e tr?!1pnl Proiram Ioa^s an(^
objectives. Training program evaluation will help employers to determine trie amount of training their
employees understood, and whether the desired results were obtained. If, after the evaluation, it appears
that the trained employees are not at the level of knowledge and skill that was expected, the employer
I will need to revise the training program, provide retraining, or provide more frequent refresher training
sessions until the deficiency is resolved. Those who conducted the training and fEose"who received the
training should also be consulted as to how best to improve the training process. If there is a language
"*"• ' ' ' ' ;i: l!l";"" Earner^ tHe l^^-^e known'to tne" trainees 'should" Ee'used. to"reinibrce"tEe training messages and
information.
Careful consideration must be given to assure that employees including maintenance and contract
employees receive current and updated training. For example, if changes are made to a process, impacted
employees must be trained in the changes and understand the effects of the changes on their job tasks
^e".g., any new operating procedures perSaent to mek tasks). Additionally, as already discussed the
evaluation of the employee's absorption of training will certainly influence the need for training.
MECHANICAL INTEGRITY
Employers will need to review their maintenance programs and schedules to see if there are areas where
"breakdown" maintenance is used rather than an on-going mechanical integrity program. Equipment
used to process, store, or handle highly hazardous chemicals needs to be designed, constructed, installed
and maintained to minimize the risk of releases of such chemicals. This requires that a mechanical
integrity program be in place to assure the continued integrity of process equipment.
IM,'!,,] 'IK , , (III if |f ||'i pi,,1 lllllliilf 1111 i llj ' i I," ,1 1 1 ,1 1 hi, l I i I,I'lJi1111 ' . If] I
Elements of a mechanical integrity program include the identification and categorization of equipment
and instrumentation, inspections and tests, testing and inspection frequencies, development of
maintenance procedures, training of maintenance personnel, the establishment of criteria for acceptable
test results, documentation of test and inspection results, and documentation of manufacturer
recommendations as to meantime to failure for equipment and instrumentation.
The first line of defense an employer has available is to operate and maintain the process as designed,
and to keep the chemicals contained. This line of defense is backed up by the next line of defense which
liliillliii I II11
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defense or means to prevent unwanted releases. The secondary lines of defense would include fixed fire
protection systems like sprinklers, water spray, or deluge systems, monitor guns, etc., dikes, designed
drainage systems, and other systems which would control or mitigate hazardous chemicals once an
unwanted release occurs. These primary and secondary lines of defense are what the mechanical
integrity program needs to protect and strengthen these primary and secondary lines of defenses where
appropriate.
Tjie first step of an effective mechanical integrity program is to compile and categorize a list of process
"S^uipment and mstnunentation'for'inclusion irTiEe program^ This list would^mclucCe'pressure"vessels,
!:: gorage tanks, process piping, relief and vent '"systems', fire' protection system'compb'nents, "emergency
shutdown systems and alarms and interlocks and pumps. For the categorization of mstrumentation and
-------
D-7
Appendix D
OSHA Guidance on PSM
the listed equipment the employer would prioritize which pieces of equipment require closer scrutiny
than others.
Meantime to failure of various instrumentation and equipment parts would be known from the
manufacturer's data or the employer's experience with the parts, which would then influence the
inspection and testing frequency and associated procedures. Also, applicable codes and standards such as
the National Board Inspection Code, or those from the American Society for Testing and Material,
American Petroleum Institute, National Fire Protection Association, American National Standards
Institute, American Society of Mechanical Engineers, and other groups, provide information to help
establish an effective testing and inspection frequency, as well as appropriate methodologies.
The applicable codes and standards provide criteria for external inspections for such items as foundation
and supports, anchor bolts, concrete or steel supports, guy wires, nozzles and sprinklers, pipe hangers,
grounding connections, protective coatings and insulation, and external metal surfaces of piping and
vessels, etc. These codes and standards also provide information on methodologies for internal
inspection, and a frequency formula based on the corrosion rate of the materials of construction. Also,
erosion both internal and external needs to be considered along with corrosion effects for piping and
valves. Where the corrosion rate is not known, a maximum inspection frequency is recommended, and
methods of developing the corrosion rate are available in the codes. Internal inspections need to cover
items such as vessel shell, bottom and head; metallic linings; nonmetallic linings; thickness
measurements for vessels and piping; inspection for erosion, corrosion, cracking and bulges; internal
equipment like trays, baffles, sensors and screens for erosion, corrosion or cracking and other
deficiencies. Some of these inspections may be performed by state or local government inspectors under
state and local statutes. However, each employer needs to develop procedures to ensure that tests and
inspections are conducted properly and that consistency is maintained even where different employees
may be involved. Appropriate training is to be provided to maintenance personnel to ensure that they
understand the preventive maintenance program procedures, safe practices, and the proper use and
application of special equipment or unique tools that may be required. This training is part of the overall
training program called for in the standard.
A quality assurance system is needed to help ensure that the proper materials of construction are used,
that fabrication and inspection procedures are proper, and that installation procedures recognize field
installation concerns. The quality assurance program is an essential part of the mechanical integrity
program and will help to maintain the primary and secondary lines of defense that have been designed
into the process to prevent unwanted chemical releases or those which control or mitigate a release. "As
built" drawings, together with certifications of coded vessels and other equipment, and materials of
construction need to be verified and retained in the quality assurance documentation.
Equipment installation jobs need to be properly inspected in the field for use of proper materials and
procedures and to assure that qualified craftsmen are used to do the job. The use of appropriate gaskets,
packing, bolts, valves, lubricants and welding rods need to be verified in the field. Also, procedures for
installation of safety devices need to be verified, such as the torque on the bolts on ruptured disc
installations, uniform torque on flange bolts, proper installation of pump seals, etc. If the quality of parts
is a problem, it may be appropriate to conduct audits of the equipment supplier's facilities to better assure
proper purchases of required equipment which is suitable for its intended service. Any changes in
equipment that may become necessary will need to go through the management of change procedures.
-------
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time limit for temporary changes be established and monitored since, without control, these changes may
tend to become permanent Temporary changes are subject to the management of change provisions. In
iddition, the management of change procedures are used to insure that the equipment and procedures are
returned1 to Ujgjj- original or designed conditions at the end of the temporary change. Proper
documentation and review of these changes is invaluable in assuring that the safety and health
considerations are being incorporated into the operating procedures and the process.
f&Jsli to, develop a form or clearance sheet to facilitate the processing of changes through the management
5f change procedures. A typical change form may include a description an3 the purpose of the change,
the technical basis for the change, safety and health considerations, documentation of changes for the
operating procedures, maintenance procedures, inspection and testing, p^Jpg^ electrical classification,
t@ipingand cQmmun!caliolas7pli:e~sto duration if a temporary change, approvals and
authorization. Where the impact of the change is minor and well understood, a check list reviewed by an
_j__ —k0"•—affectecj jjjay be sufficient.
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fi ^ icant design change, a hazard evaluation procedure with approvals
by operations, maintenance, an"3 safety departments may be appropriate. Changes in documents such as
f>&15§" raw materials, operating procedures, mechanical integrity programs, electrical classifications,
I' 'liilVKlllli' '"'IllliP 'in |!!j|||i|PW^^^ ''I Illlllllllll""1 IlliBnii'lilinHIII1' .lllllllllllilillllillillllllllll'lllill.iiiillllllllll ll«"!illll|i|iillllllll, ' ' '• |l,l jiJIliMl ih.lii'll JliilNinilii illllllll|l|lllll|!l»IIIIM '», Illllllii! Jllli.i.l lllI'Mllllll'll1 'll» , 'IIIIIINII'lJIIII'i'JIIIIillllllllll'll'lllllllnllillll'llllllllllllllllllUlllnlll.l' ' i • 'i»IJ B111'1"' 'S 9 '' «
ef£j'lieea to p;e_ noted so mat uese revisions can be made permanent when the drawings and procedure
• gjigggij-""^~^|^™- gopjgg 5f process changes need to be kept in an accessible location to ensure mat
design changes are available to operating personnel as well as to PHA team members when a PHA is
being done or one is being updated.
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PRE-STARTUP REVIEW
iluii.'J.iJJ'S.jI.j! .
cesses, the employer will find a PHA helpful in improving the design and construction of the
ii j'^^.rJ^1 ih: • ptocess '&pl^ar^^S^^^&^^^^y point oFview. Tfie safe operaSon oFthe new process will be
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D-9
Appendix D
OSHA Guidance on PSM
are to be completed along with having the operating procedures in place and the operating staff trained to
run the process before startup. The initial startup procedures and normal operating procedures need to be
fully evaluated as part of the pre-startup review to assure a safe transfer into the normal operating mode
for meeting the process parameters.
For existing processes that have been shutdown for turnaround, or modification, etc., the employer must
assure that any changes other than "replacement in kind" made to the process during shutdown go
through the management of change procedures. P&IDS will need to be updated as necessary, as well as
operating procedures and instructions. If the changes made to the process during shutdown are significant
and impact the training program, then operating personnel as well as employees engaged in routine and
non-routine work in the process area may need some refresher or additional training hi light of the
changes. Any incident investigation recommendations, compliance audits or PHA recommendations need
to be reviewed as well to see what impacts they may have on the process before beginning the startup.
COMPLIANCE AUDITS
Employers need to select a trained individual or assemble a trained team of people to audit the process
safety management system and program. A small process or plant may need only one knowledgeable
person to conduct an audit. The audit is to include an evaluation of the design and effectiveness of the
process safety management system and a field inspection of the safety and health conditions and
practices to verify that the employer's systems are effectively implemented. The audit should be
conducted or led by a person knowledgeable in audit techniques and who is impartial towards the facility
or area being audited. The essential elements of an audit program include planning., staffing, conducting
the audit, evaluation and corrective action, follow-up and documentation.
Planning in advance is essential to the success of the auditing process. Each employer needs to establish
the format, staffing, scheduling and verification methods prior to conducting the audit. The format should
be designed to provide the lead auditor with a procedure or checklist which details the requirements of
each section of the standard. The names of the audit team members should be listed as part of the format
as well. The checklist, if properly designed, could serve as the verification sheet which provides the
auditor with the necessary information to expedite the review and assure that no requirements of the
standard are omitted. This verification sheet format could also identify those elements that will require
evaluation or a response to correct deficiencies. This sheet could also be used for developing the
follow-up and documentation requirements.
The selection of effective audit team members is critical to the success of the program. Team members
should be chosen for their experience, knowledge, and training and should be familiar with the processes
and with auditing techniques, practices and procedures. The size of the team will vary depending on the
size and complexity of the process under consideration. For a large, complex, highly instrumented plant,
it may be desirable to have team members with expertise in process engineering and design, process
chemistry, instrumentation and computer controls, electrical hazards and classifications, safety and health
disciplines, maintenance, emergency preparedness, warehousing or shipping, and process safety auditing.
The team may use part-time members to provide for the depth of expertise required as well as for what is
actually done or followed, compared to what is written.
An effective audit includes a review of the relevant documentation and process safety information,
inspection of the physical facilities, and interviews with all levels of plant personnel. Using the audit
-------
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••;, %-i; »: •• ••'•: Appendix D
OSHA Guidance on PSM D-10
i;i:!i|i)sf |||; ;. I 'Sij'procedure and checkh'st developed in the preplanning stage, the audit team can systematically analyze
compliance with the provisions of the standard and any other corporate policies that are relevant. For
example, the audit team will review all aspects of the training program as part of the overall audit. The
team will review the written training program for adequacy of content, frequency of training,
effectiveness of training in terms of its goals and objectives as well as to how it fits into meeting the
glandardls requirements, documentation, etc. Through interviews, the team can determine the employee's
knowledge and awareness of the safety procedures, duties, rules, emergency response assignments, etc.
"': ^'t "j ~~ri""" " .During the inspection, the team can observe actual practices such as safety' and health policies,
procedures, and work authorization practices. This approach enables the team to identify deficiencies
and determine where corrective actions or improvements are necessary.
An audit is a technique used to gather sufficient facts and information, including statistical information,
lo" verify compliance with' standards. Auditors snoulS select as p_art pFIEeir pjepjanning a sample size
sufficient to give a degree of confidence that the audit reflects the level of compliance with the standard.
The audjt team, through this systematic analysis, should document areas which require corrective action
as Well as those areas where the process safety management system is effective and working in an
effective manner. This provides a record of the audit procedures and findings, and serves as a baseline of
operation data for future audits. It will assist future auditors in determining changes or trends from
previous audits.
Corrective action is one of the most important parts of the audit. It includes not only addressing the
identified deficiencies, but also planning, follow up, and documentation. The corrective action process
JiSrmally begins with a management review of the audit findings. The purpose of this review is to
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procedure or minor maintenance effort to remedy the concern. Management of change procedures need
to be us^d^ as appropriate, even for what may seem to be a minor change. Many of the deficiencies can be
acted on promptly, while some may require engineering studies or in-depth review of actual procedures
and practices. There may be instances where no action is necessary and this is a valid response to an
audit finding. All actions taken, including an explanation where no action is taken on a finding, needs to
be documented as to what was done and why.
It is important to assure that each deficiency identified is addressed, the corrective action to be taken
noted, and the audit person or team responsible be properly documented by the employer.
TO contro^ the correctives, action process, the employer should consider the use of a tracking system. This
tracking system might include periodic status reports shared with affected levels of management, specific
Reports such as completion of an engineering study, and a final implementation report to provide closure
for audit findings that have been through management of change, if appropriate, and then shared with
ilil I I Mil I IIIII11III Illiyiil: Lf iMIIilllilill tTT i, , ii , „ u i' T^ , i JII^MLI , i, 'i S^ ' i,' ,i, [Lib j £ ii. h, j Lull 1111 'i ii • ii" ii . ., i, ' i ,i mi
affected employees and management. This type of tracking system provides the employer with the status
of the corrective action. It also provides the documentation required to verify that appropriate corrective
actions were taken on deficiencies identified in the audit.
INCIDENT INVESTIGATION
Incident investigation is the process of identifying the underlying causes of incidents and implementing
steps to prevent similar events from occurring. The intent of an incident investigation is for employers to
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D-ll
Appendix D
OSHA Guidance on PSM
learn from past experiences and thus avoid repeating past mistakes. Some of the events are sometimes
referred to as "near misses," meaning that a serious consequence did not occur, but could have.
Employers need to develop in-house capability to investigate incidents that occur in their facilities. A
team needs to be assembled by the employer and trained in the techniques of investigation including how
to conduct interviews of witnesses, needed documentation and report writing. A multi-disciplinary team
is better able to gather the facts of the event and to analyze them and develop plausible scenarios as to
what happened, and why. Team members should be selected on the basis of their training, knowledge
and ability to contribute to a team effort to fully investigate the incident.
Employees in the process area where the incident occurred should be consulted, interviewed or made a
member of the team. Their knowledge of the events form a significant set of facts about the incident
which occurred. The report, its findings and recommendations are to be shared with those who can
benefit from the information. The cooperation of employees is essential to an effective incident
investigation. The focus of the investigation should be to obtain facts, and not to place blame. The team
and the investigation process should clearly deal with all involved individuals in a fair, open and
consistent manner.
EMPLOYEE PARTICIPATION
Section 304 of the Clean Air Act Amendments states that employers are to consult with their employees
and their representatives regarding the employers efforts in the development and implementation of the
process safety management program elements and hazard assessments. Section 304 also requires
employers to train and educate their employees and to inform affected employees of the findings from
incident investigations required by the process safety management program. Many employers, under their
safety and health programs, have already established means and methods to keep employees and then-
representatives informed about relevant safety and health issues and employers may be able to adapt
these practices and procedures to meet their obligations under this standard. Employers who have not
implemented an occupational safety and health program may wish to form a safety and health committee
of employees and management representatives to help the employer meet the obligations specified by this
standard. These committees can become a significant ally in helping the employer to implement and
maintain an effective process safety management program for all employees.
HOT WORK PERMIT
Non-routine work which is conducted in process areas needs to be controlled by the employer in a
consistent manner. The hazards identified involving the work that is to be accomplished must be
communicated to those doing the work, but also to those operating personnel whose work could affect
the safety of the process. A work authorization notice or permit must have a procedure that describes the
steps the maintenance supervisor, contractor representative or other person needs to follow to obtain the
necessary clearance to get the job started. The work authorization procedures need to reference and
coordinate, as applicable, lockout/tagout procedures, line breaking procedures, confined space entry
procedures and hot work authorizations. This procedure also needs to provide clear steps to follow once
the job is completed to provide closure for those that need to know the job is now completed and
equipment can be returned to normal.
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Appendix D
OSHA Guidance on PSM
D-12
CONTRACTORS
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Employers who use contractors to perform work in and around processes that involve highly hazardous
chemicals, will need to establish a screening process so that they hire and use contractors who
accomplish the desired job tasks without compromising the safety and health of employees at a facility.
For contractors, whose safety performance on the job is not known to the hiring employer, the employer
will need to obtain information on injury and illness rates and experience and should obtain contractor
references. Additionally, the employer must assure that the contractor has the appropriate job skills,
knowledge and certifications (such as for pressure vessel welders). Contractor work methods and
experiences should be evaluated. For example, does the contractor conducting demolition work swing
loads over operating processes or does the contractor avoid such hazards?
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Contract employees must perform their work safely. Considering that contractors often perform very
specialized and potentially hazardous tasks such as confined space entry activities and non-routine repair
actryjtiesjt.is quite important that their activities be controlled while they are working on or near a
covered process. A permit system or work authorization system for these activities would also be helpful
io all arrected^^pToyers!' 'l^'uie~6Ta work'aufEonzatibn1 sylstem'JEieeps an einplbyer fanned of
contract employee activities, and as a benefit the employer will have better coordination and more
management control over the work being performed in the process area. A well run and well maintained
process where employee safety is fully recognized will benefit all of those who work in the facility
whether they be contract employees or employees of the owner.
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