United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
(5104)
EPA 550-B-00-009
May 2000
www.epa.gov/ceppo/
SEPA
RISK MANAGEMENT
PROGRAM GUIDANCE
FOR
WAREHOUSES
(40 CFR PART 68)
Chemical Emergency Preparedness and Prevention Office
Printed on recycled pa
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This document provides guidance to help owners and operators of stationary sources to
determine if their processes are subject to chemical accident prevention regulation under section
112(r) of the Clean Air Act and 40 CFR part 68 and to comply with regulations. This document
does not substitute for EPA's regulations, nor is it a regulation itself. Thus, it cannot impose
legally binding requirements on EPA, states, or the regulated community, and may not apply to a
particular situation based upon circumstances. The guidance does not represent final agency
action, and EPA may change it in the future, as appropriate.
May 26,2000
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THIS EDITION
This document is a revision of the January 1999 Risk Management Program Guidance for Warehouses.
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;
+ The adoption of rules for confidential business information;
+ Changes to the way in which flammable liquids and refrigerated flammable gases may be
modeled for the offsite consequence analysis; 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 1999 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.
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 Must You Comply
1.8 Varying Inventories and Predictive Filing
CHAPTER 2 APPLICABILITY OF PROGRAM LEVELS
2.1 What Are Program Levels
2.2 Program 1
2.3 Quick Rules for Determining Program 1 Eligibility
2.4 Program 3
2.5 Program 2
2.6 Dealing with Program Levels
2.7 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 Scenarios
4.3 Buildings
4.4 Estimating Offsite Receptors
4.5 Documentation
1-1
1-3
1-5
1-5
1-8
1-14
1-15
1-17
2-1
2-3
2-9
2-10
2-11
2-12
2-15
3-1
3-1
3-9
4-4
4-13
4-20
4-21
4-24
Appendix 4A Reference Tables of Distances and Tables of Data from the Offsite Consequence Analysis
Guidance 4_27
CHAPTERS MANAGEMENT SYSTEM
5.1 General Information (§ 68.15)
5.2 How to Meet the Management System Requirements
5-1
5-1
May 26, 2000
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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)
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
CHAPTER 7 PREVENTION PROGRAM (PROGRAM 3)
7.1 Prevention Program 3 and OSHA PSM
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-Starrup 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
CHAPTER 9 EMERGENCY RESPONSE
K. 1 Non-Responding Sources (§ 68.90(b))
K.2 Elements of an Emergency Response Program (§68.95)
8.3 Developing an Emergency Response Program
8.4 Integration of Existing Program
8.5 Am I Already in Compliance
8.6 Coordination with Local Emergency Planning Committees
CHAPTER 9 RISK MANAGEMENT PLAN (Part 68, Subpart G)
6-1
6-2
6-7
6-11
6-15
6-17
6-20
6-21
6-25
7-1
7-3
7-5
7-9
7-10
7-10
7-11
7-13
7-13
7-13
7-14
7-15
7-15'
7-18
8-1
8-2
8-6
8-9
8-9
8-12
9.1 Elements of the RMP 9-1
9.2 RMP Submission 9-2
9.3 Issues Pertaining to Submission of and Access to Confidential Business Information and Trade
Secrets 9-3
9.4 Resubmission and Updates 9-4
May 26,2000
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CHAPTER 10 IMPLEMENTATION
10.1 Implementing Agency
10.2 Reviews/Audits/Inspections (§ 68.220)
10.3 Relationship with Title 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
11.3 Communication Activities and Techniques
11.4 For More Information
APPENDICES
APPENDIX A PART 68
APPENDIX B SELECTED NAICS CODES
APPENDIX C TECHNICAL ASSISTANCE
APPENDIX D OSHA GUIDANCE ON PSM
in
10-1
10-2
10-4
10-4
11-1
11-4
11-13
11-19
May 26, 2000
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IV
LIST OF BOXES AND EXHIBITS
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
CHAPTERS
Exhibit 3-1
CHAPTER 4
Exhibit 4-1
Exhibit 4-2
.Exhibit 4-3
Exhibit 4-4
Exhibit 4-5
Exhibit 4-6
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
Exhibit 6-12
Evaluate Facility to Identify Covered Processes
Process
Stationary Source
Evaluate Program Levels for Covered Processes
Program Level Criteria
Develop Risk Management Program and RMP
Comparison of Program Requirements
Atmospheric Stability Classes
Examples of Regulated Toxic Substances in Warehouses
Examples of Regulated Flammable Substances in Warehouses
Required Parameters for Modeling
Predicted Distances to Toxic Endpoints for Regulated Toxic Materials
Predicted Distances to Toxic Endpoints for Regulated Toxic Materials
Predicted Distances to Toxic Endpoints for Regulated Toxic Materials
Sample Management Documentation
Summary of Program 2 Prevention Program
Safety Information Requirements ;
Codes and Standards :
Sample Safety Information Sheet
Hazard Review Requirements
Sample Checklist
Operating Procedures Requirements :
Training Chart
Maintenance Guidelines
Sample Audit Checklist for Safety Information and Hazard Review
Incident Investigation Requirements
Sample Incident Investigation Format
May 26,2000
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CHAPTER?
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
Exhibit 7A-1
Exhibit 7A-2
CHAPTERS
Exhibit 8-1
Exhibit 8-2
CHAPTER 9
Exhibit 9-1
CHAPTER 11
Exhibit 11-1
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
Hot Work Permits Requirements
Contractors Chart
Applicability of PHA Techniques
Time and Staffing for PHA Techniques
Federal Guidance on Emergency Planning and Response
Federal Emergency Planning Regulations
RMP Updates
Seven Cardinal Rules of Risk Communication
LIST OF BOXES
INTRODUCTION
State Programs
If You Are New to Regulations
What Is a Local Emergency Planning Committee?
CHAPTER 1
State Programs
Qs and As: Stationary Source
Aggregation of Substances
Qs and As: Threshold Determinations
Qs and As: Consideration of Products
Qs and As: Stationary Source
Qs and As: Compliance Dates
CHAPTER 2
Q and A: Process and Program Level
Qs and As: Public Receptors
May 26,2000
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VI
Q and A: Determining Distances
Q and A: Environmental Receptors
Qs and As: Accident History
QsandAs:OSHA
CHAPTER 3 :
Q and A: 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: Audits
CHAPTER 7
Q and A: Implementation and Program Level
Qs and As: Process Safety Information
Qs and As: Offsite Consequences
CHAPTER 8
What Is a Response
What Is a Local Emergency Planning Committee?
Qs and As: Emergency Response and Warehouses
Planning for Flammable Substances
CHAPTER9
Qs and As: RMP Updates
Q and A: Revising a PHA ;
CHAPTER 10
Qs and As: Delegation
Qs and As: Audits ;
CHAPTER 11
What Does Your Worst-case Release 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?
What Are You Doing to Prevent Releases? ;
What Are You Doing to Prepare for Releases?
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?
May 26, 2000
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vu
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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vm
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 CFRpart 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, which is available in Appendix A of this document.
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)(see Appendix C,
Technical Assistance, for other sources of information).
Category
Warehouses
NAICS
Codes
49311
49312
49319
SIC
Codes
4225
4222
4226
Examples of Potentially Regulated Entities
General warehousing and storage
Refrigerated warehousing
Other warehousing and storage
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 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 guidance is intended for warehouses that handle or store chemicals; some of
these warehouses may repackage chemicals, but most limit their activities to storing
substances in containers designed to meet DOT transportation regulations.
Information that is not applicable to warehouses has been omitted. If your
warehouse is part of a larger facility that processes or uses chemicals or stores large
quantities of chemicals for its own use, there will be information that is applicable to
those other operations that is not presented in this document. For those operations,
you should consult the General Guidance of Risk Management Programs or EPA's
other industry-specific guidance documents, as appropriate.
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 t\pe 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 6fc is that rule.
In general, pan 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.
January 25, 1999
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Introduction -ii-
+ 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.
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?
This is a technical guidance document designed for owners and operators of sources
covered by part 68. It will help you to:
+ Determine if you are covered by the rule;
+ Determine what level of requirements is applicable to your covered
process(es);
+ Understand which specific risk management program activities must be
conducted;
4- 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
+ Understand the reporting, documentation, and risk communication
components of the rule.
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.
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.
January 25,1999
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-ui-
Introduction
WHAT DO I DO FIRST?
Before developing a risk management program, you should do five things:
(1) Determine which, if any, of your processes are covered by this program
Only sources 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 hi § 68.3 and does not necessarily
correspond with an engineering concept of process. The 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 and the
results of the offsite consequence analysis for that process, 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 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.
REQUIREMENTS ARE PERFORMANCE BASED
Finally, keep in mind that many of these requirements are performance-based; that is,
EPA is not specifying 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
January 25, 1999
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Introduction
-IV-
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.
For example, the operating procedures for a chemical distributor are likely to be
relatively brief, while those for a chemical manufacturer will be extensive.
Similarly, the length of training necessary to educate employees on such procedures
would be proportional to the complexity of your operating procedures. And while a
facility with complex processes may benefit from a computerized maintenance
tracking system, a small facility 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 in 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.
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 25,2000
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-V-
Introduction
IF YOU ARE NEW TO REGULATIONS
We have tried to make this document as clear and readable as possible, but if you have rarely dealt
with regulations before, some of the language may seem initially odd and confusing. All regulations
have their own vocabulary. 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.
January 25, 1999
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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:
•4- Collect information from facilities on hazardous substances that pose a risk to Hie
community;
+ 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.
January 25,1999
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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:
+ The owner or operator of a stationary source
+ That has more than a threshold quantity
+ Of a regulated substance
+ 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," which 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 facilities covered by this rule, the stationary source is basically all
covered processes at your site. If your facility is part of a site with other divisions of
your company or other companies, the discussion of stationary source will help you
understand what you are responsible for in your compliance and reporting. 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.
January 25, 1999
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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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1-3
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, municipality, political
subdivision of a state, and any agency, department, or instrurnentality 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 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."
EPA has added some language in the rule to clarify issues related to transportation
(see below). |
FARMS
The rule has only one exemption: for ammonia when held by a farmer for use on a
farm. This exemption applies to ammonia only when used as a fertilizer by a farmer.
It does not apply to agricultural suppliers or the fertilizer manufacturer.
FLAMMABLE FUELS (§ 68.126)
The flammable substances listed in § 68.130 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. A retail
facility is defined as a stationary source at which more than half of the income is
obtained from direct sales to end users or at which more than one-half of the fuel
sold, by volume, is sold through a cylinder exchange program.
Unless your facility meets the definition of a "retail facility," if you store a listed
flammable substance for purposes other than on-site use as fuel, you are potentially
covered by part 68. If you store a listed flammable substance for purposes other than
on-site use as fuel and also use it as a fuel, .the quantity used as fuel is not covered;
the quantity stored for purposes other than on-site use as fuel is potentially subject to
the rule. :
April 25,2000
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Chapter 1
General Applicability
1-4
TRANSPORTATION ACTIVITIES
Transportation containers used for storage not 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
stationary source. For example, if you have railcars on a private siding that you use
as storage tanks, 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 truck 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 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.
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
The OSHA Process Safety Management (PSM) standard exempts flammable
substances stored in atmospheric storage tanks. (Other OSHA exemptions are not
relevant to warehouses.) The OSHA exemptions do not apply or extend to EPA's
Risk Management Program Rule. Your processes are not exempt from the Risk
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Management Program simply because they qualify for one of the OSHA exemptions.
Consequently, EPA covers substances stored in atmospheric storage tanks if there is
more than a threshold quantity in a process.
1.3 REGULATED SUBSTANCES AND THRESHOLDS
The list of substances regulated under § 68.130 is in Appendix A. Checkthelist
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.
The list includes 77 chemicals that were listed because they are acutely toxic; they
can cause serious health effects or death from short-term exposures. The list also
covers 63 flammable gases and highly volatile flammable liquids. The flammable
chemicals have the potential to form vapor clouds and explode or burn if released.
The rule also covers flammable mixtures that include any of the listed flammables if
the mixture meets the criteria for the National Fire Protection Association's (NFPA)
4 rating. ,
1.4 WHAT IS A PROCESS
The concept of "process" is key to whether you are subject to this rule. Process is
defined as:
"Any activity involving a regulated substance, including any use, storage,
manufacturing, handling or on-site movement of such substances or any 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" means a reactor, tank, drum, barrel, cylinder, vat, kettle, boiler, pipe, hose,
or other container. ;
The definition of process is identical to the definition of process under the OSHA
PSM standard. It is important in determining whether you have a threshold quantity
of a regulated substance and what the 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.
+ 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.
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+ If you have multiple unconnected vessels, containing the same substance,
you will have to determine whether they need to be considered together.
WAREHOUSES AS A SINGLE PROCESS
Because warehouses usually consist of one large storage area, even if subdivided,
and because you are likely to have the same prevention practices for the entire
warehouse, you may want to consider the warehouse building a single process. You
are not required to treat the warehouse as a single process; if the storage areas for
regulated substances are widely separated and do not meet the criteria for co-location
discussed below, you may treat each area separately. If you store chemicals outside
the warehouse, they may be considered a separate process. The issue you will have
to decide is whether you have more than a threshold quantity of a regulated
substance to determine whether your warehouse building is a covered process. Co-
location, discussed below, will probably be the key issue in determining whether
your warehouse is a covered process and, if so, which chemicals must be included in
your risk management program.
SINGLE VESSELS
As a warehouse, you are unlikely to have a single storage tank of any regulated
substance holding more than a threshold quantity unless you repackage chemicals. If
you have a tank and it is the only place you have a regulated substance, you need not
worry about the other possibilities for defining a process and can skip to the next
section.
CO-LOCATION
You must consider whether you have separate vessels that contain the same
regulated substance that 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:
+ Would a release from one of the containers lead to a release from the other?
For example, if a cylinder of a flammable substance were to rupture and
bum, would the fire spread to other cylinders?
+ Would an event external to the containers, such as a fire or explosion, have
the potential to release the regulated substance from multiple containers?
You must determine 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
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must count all of them. For toxics, a release from a single vessel will not normally
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.
If the vessels are separated by fire walls or barricades or by group occupancy rooms
that will contain the blast waves from explosions of the substances, you will not need
to count the separated vessels, but you may have to count any that are in the same
room if a fire could spread to involve all of the containers.
You may not dismiss the possibility of a fire spreading based on an assumption that
your fire department will be able to prevent any'spread. You should ask yourself
how far the fire would spread if the worst happens — the fire department is slow to
arrive, the water supply fails, or the fire department decides it is safer to let the fire
burn itself out. If you have vessels that, when taken together, could release more
than a threshold quantity in such worst-case circumstances, you should count them as
a single process. At a warehouse, you will probably want to consider the nature of
the other material stored. If the other materials are flammable or combustible and
likely to feed a fire, you may need to be conservative in estimating how far a fire
could spread. If the other materials are not combustible, a fire may be confined to
part of a room.
INTERCONNECTED VESSELS
Interconnection is unlikely to be applicable to warehouses. In general, if you have
two or more vessels that contain a regulated substance and are connected through
piping or hoses for the transfer of the regulated substance, you must consider the
total quantn> in all the connected vessels and piping when determining if you have a
threshold quantity m a process. If the vessels are connected for transfer of the
substance uMng hoses that are then removed, you still have to consider the contents
of the \ excels as one process, because if one vessel were to rupture while the hose
was attached or the hose were to break during the transfer, you could lose the total
quantit> in both tanks. 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 determining the total quantity in a process.
PROCESSES WITH MULTIPLE CHEMICALS
When you are determining whether you have a covered process, you should not limit
your consideration to units that have the same regulated substance. A covered
process includes any units that hold more than a threshold quantity of regulated
substances and that are interconnected or co-located. Therefore, if you have four
storage 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
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1-8
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 vessels with the first substance may be part of the process involving
the other vessels and other regulated substances, based on co-location.
Exhibit 1-2 provides illustrations of what may be defined as a process.
DIFFERENCES WITH OSHA
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).
1.5 THRESHOLD QUANTITY IN A PROCESS
The threshold quantity for each regulated substance is listed 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).
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.
I
"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.
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EXHIBIT 1-2: PROCESS
Schematic Representation
Description
Interpretation
1 vessel
1 regulated substeince 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
Q
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
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 flammabfes
1 process
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1-10
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.
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.
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.
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
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 containers as one process,
you must determine the maximum quantity for each container and sum the quantities
of all such containers.
QUANTITY OF A SUBSTANCE IN A MIXTURE
Toxics mm LISTED CONCENTRATION
Four toxic substances have listed concentrations in the rule: hydrochloric acid — 37
percent or greater; hydrofluoric acid — 50 percent or greater; nitric acid — 80
percent or greater; and ammonia — 20 percent or greater.
+ If you have these substances in solution and their concentration is less that
the listed concentration, you do not need to consider them at all.
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Qs and As
THRESHOLD DETERMINATIONS
Q. I store several different flammable liquids and products that contain flammable liquids. Do I
combine them or consider each separately?
A. You must estimate the quantity of each, separate listed flammable liquid.
Q. How far apart do containers 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 containers 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 containers 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. At a warehouse, the nature of the other
materials stored should be considered; if containers are widely separated by other materials that
could slow a fire's spread, the distance required to consider the containers separate processes will be
much shorter than if most of the warehouse's contents are combustible. 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).
+ 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, aq'ueous 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).
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
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. Note that the partial
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1-12
pressure rule does not apply to toluene diisocyanate (2,4-, 2,6-, or mixed isomers) or
oleum.
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.
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:
FLAMMABLE GASES
Flammable cryogenic materials
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)
Materials that will spontaneously ignite when exposed to air."
You do not need to consider gasoline, when in distribution or related 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 sources that
contain a regulated substance when you determine whether a threshold quantity is
present. Note that these same exclusions apply to EPCRA section 313; you may be
familiar with them if you comply with that provision.
ARTICLES (§ 68.115(B)(4))
You do not need to include in your threshold calculations any manufactured item (as
defined under 29 CFR 1910.1200(b)) that:
+ Is formed to a specific shape or design during manufacture,
+ Has end use functions dependent in whole or in part upon the shape or
design during end use, and
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Qs and As
CONSIDERATION OF PRODUCTS
Q. We frequently store large numbers of bottles of household ammonia and bleach. Do I have to
figure out the percentage of ammonia or chlorine in each bottle?
A. No. Household ammonia (as a consumer product) does not meet the concentration threshold of
20 percent. Unless the concentration of ammonia in solution is 20 percent or greater, you do not
need to consider the solution in your threshold determinations. Household bleach is usually a
solution of water and sodium hypochlorite. Because the latter is not a listed substance, you do not
need to consider it. \ .
Q. We store consumer products that use butane as a propellant. Each product only has a few
ounces of butane. Do we need to estimate the total amount of butane in all the products?
A. Listed flammable substances are excluded from coverage only if they are used as a fuel. In this
case, butane is not being used as a fuel (i.e., it is not being burned to produce heat or power). As
long as the butane is released from the product in normal use, you must estimate the amount of the
regulated substance present. If the butane is mixed with the product, you should determine whether
the product itself meets the criteria for NFPA 4. If the mixture does not meet the NFPA 4 criteria,
the butane in the mixture is not counted toward the threshold.
4- Does not release or otherwise result in exposure to a regulated substance
under normal conditions of processing and use.
USES (§68.115(b)(5))
You also do not need to include regulated substances in your calculation when in use
for the following purposes:
4- Use as a structural component of the stationary source;
4- Use of products for routine janitorial maintenance;
4- Use by employees of foods, drugs, cosmetics, or other personal items
containing the regulated substances; and
4- 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.
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1-14
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 facilities 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 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.
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 arc 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.
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
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Chapter 1
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the land is not relevant; a stationary source consists of covered processes located on
the same property and controlled by a single owner.
JOINT VENTURES
1.7
You and another company may jointly own covered processes. In this case, the legal
entity you have established to operate these processes should file the RMP. If you
consider this entity a subsidiary, you should be listed as the parent company in the
RMP.
MULTIPLE LOCATIONS
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.
WHEN MUST YOU COMPLY
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 aad implemented all of the elements of the
rule that apply to each of your covered processes, and you must have submitted an
RMP to EPA. ! ;
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 a more than a threshold quantity of a regulated substance in a
process.
Q and A
STATIONARY SOURCE
Q. If I lease space in another building and store regulated substances above their thresholds there,
must I file a separate RMP for them?
A. Yes, if the other building is a separate stationary source (i.e., it is not contiguous to the property
where your warehouse is) you must file a separate RMP.
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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
ABC Products
ABC Products
same owner
same industrial group
contiguous property
1 stationary source
1 RMP
Building owned by Brown Properties
Farm Chemicals Inc.
Mill
Brown Property offices
ABC
Chemicals
two owners
Pet Supply Storage
(no regulated substances)
2 stationary sources
2RMPs
1 ABC Chemicals
1 Farm Chemicals
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1.8 VARYING INVENTORIES AND PREDICTIVE FILING
As a warehouse owner, the main problem you are likely to face as you determine
whether you are covered by this rule is that your inventory changes frequently.
There may be periods when you have no regulated substances and other periods
when you have several. Deterrnining your applicability under this rule on a day-to-
day basis may be difficult, and in some cases, impossible. One way to deal with this
difficulty is to use predictive filing.
Predictive filing is an option that allows you to submit an RMP that includes
regulated substances that may not be held at the facility at the time of submission.
This option is intended to assist facilities such as chemical warehouses, chemical
distributors, and batch processors whose operations involve highly variable types
and quantities of regulated substances, but who are able to forecast their inventory
with some degree of accuracy. Under § 68.190, you are required to update and re-
submit your RMP no later than the date on which a new regulated substance is first
present in a covered process above a threshold quantity. By using predictive filing,
you will not be required to update and re-submit your RMP when you receive a new
regulated substance if that substance was included in your latest RMP submission (as
long as you receive it in a quantity that does not trigger a revised offsite consequence
analysis as provided in § 68.36).
To use predictive filing, review your inventories over the past several years and talk
with your main customers to determine, to the extent possible, the kinds of materials
they are planning to store at your facility. If at some point during a year you
normally receive enough vessels (drums, barrels, cylinders) to exceed a threshold
quantity of a particular substance, list it on your registration in June 1999 even if you
do not have it on the day you submit. If it appears, over time, that your customers
will not be using your warehouse to store the substance again, you can deregister it
later. In the short run, you will be safer listing too many substances, than too few,
because this approach will limit the need to resubmit your RMP every time your
inventory changes.
If you have flammable mixtures at your warehouse, you may want to register them as
a class rather than listing each covered flammable substance. This approach will
assure that you are in compliance with the registration requirements while limiting
the effort you need to make to identify the specific substances.
If you use predictive filing, you must implement your Risk Management Program
and prepare your RMP exactly as you would if you actually held all of the substances
included in the RMP. This means that you must meet all rule requirements for each
regulated substance for which you file, whether or not that substance is actually held
on site at the time you submit your RMP. Depending on the substances for which
you file, this may require you to perform additional worst-case and alternative-case
scenarios and to implement additional prevention program elements. If you use this
option, you must still update and resubmit your RMP if you receive a regulated
substance that was not included in your latest RMP. This approach will not
completely eliminate the need to update your RMP, but should limit the frequency of
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1-18
updates. If you use this option, you must still comply with the other update
requirements stated in § 68.190. RMPs must be updated when you:
4- Add a new regulated substance above its threshold (i.e., one not already
reported in your latest predictive RMP submission);
4- Add a new covered process;
4- Have the program level of the process change (see Chapter 2);
4- Make a major change that requires a revised PHA or hazard review (see
Chapters 6 and 7); or
4- Make a change that changes the distance to endpoint for a worst-case release
by a factor of two or more.
Listing all the regulated substances you think you are likely to handle will mean
more work initially (primarily more alternative release scenarios), but will limit the
need for updates. As a rule of thumb, you will need to increase or decrease the
quantity of a chemical in the single largest vessel by a factor of five or more to
change the distance to an endpoint by a factor of two.
Predictive filing will work best when you simply store chemicals. If you repackage
chemicals, you will need to complete prevention program information for each
repackaging process. If you can predict which regulated substances you will
repackage and can establish your prevention program, you can file predictively for
that process. If, however, you have listed a regulated substance in your RMP based
on expected storage, but you subsequently begin to repackage as well as store the
chemical, you will need to update the RMP to reflect the new process.
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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 new covered process after the initial compliance date, you must be in compliance on the
date you first have a regulated substance above the threshold quantity in that process. There is no
grace period. You must develop and implement all the applicable rule elements 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. I store 1-ton cylinders of chlorine. If I normally have 20 cylinders located together on site and
register that quantity, do I need to update my RMP if I increase the number of cylinders to 200?
How does this affect my worst-case scenario?
A. You do not necessarily need to update the RMP simply to reflect the higher quantity of chlorine.
In this case, because you have not changed the size of your single: largest vessel, your worst-case
release scenario will not change. You will update the quantity information on your next scheduled
update.
Q. I have stored 1-ton cylinders of chlorine together. Because of customer demand, I have started
repackaging and have a tank with 40,000 pounds of chlorine. Do I need to update the RMP?
A. Yes, for two reasons. First, if the tank is a new process, you must update your RMP
immediately; if it is pan of an existing process, you must update within 6 months. Second, the
40.000-pound tank may result in the distance to endpoint for your worst-case release increasing by
more than a factor of 2. If this is the case, you will need to update that change as well.
January 25, 1999
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Chapter 1
General Applicability
1-20
January 25,1999
-------
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
imposes different requirements on processes based on the potential for public
impacts and the level of effort needed to prevent accidents. EPA has set three levels
of requirements that apply to covered processes:
Program 1: Processes with no public receptors within the distance to the
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 minimal requirements on the process.
Program 2: Processes not eligible for Program 1 or subject to Program 3
are placed in Program 2, which imposes a streamlined prevention program.
Program 3: Processes not eligible for Program 1 and either subject to
OSHA's PSM standard under federal or state OSHA programs or in ten
specified North American Industry Classification System (NAICS) codes are
placed in Program 3, which imposes the OSHA PSM program as the
prevention program.
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 inspect and enforce only on compliance with 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 inspect or enforce for
compliance with 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 levels for your process(es), keep in mind the following:
(1) The program levels apply to individual processes and generally indicate
the risk management measures necessary to comply with this regulation for
the 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.
(2) Any process can be eligible for Program 1, even if it is subject to OSHA
PSM or is in one of the NAICS codes.
January 26, 1999
-------
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
subject to the OSHA
PSM Standard?
Have offsite
impacts occurred due
to a release of a
regulated substance
from the process?
No
Is the process
classified in one of the
listed NAICS codes?
No-*
Process
Subject to
Program
Level 2
Yes
Yes
Process
Eligible for
Program
Level 1
Process
Subject to
Program
Level 3
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2-3
Chapter 2
Applicability of Program Levels
(3) Program 2 is the default program level. There are no "standard criteria"
for Program 2. Any process that does not meet the eligibility 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 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 endpomt 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 reaption products, overpressures
generated by explosion involving the substance, or radiant heat from a fire
involving the substance resulted in 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.)
WHAT Is A PUBLIC RECEPTOR?
The rule defines public as "any person who is not 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.
January 26, 1999
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Chapter 2
Applicability of Program Levels
2-4
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.
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 of
business hours."
For most facilities, the meaning of the definition of public receptor is
straightforward. If you restrict access to your property at all times, public receptors
are any occupied buildings or public gathering areas beyond your boundaries.
Access restrictions include precautions such as a fully fenced site, security guards on
duty at a reception area, or ID badges necessary to gain entry.
j
If you have unrestricted sections of your site that are predictably used by the public
(e.g., ball fields or picnic areas), then these sections would also be considered public
receptors. Neighboring businesses, whether commercial or industrial, are considered
public receptors, as are residences, institutions such as hospitals, schools, prisons,
marinas and airport terminals, public and private parking lots, golf courses, transit
stations, and toll booth plazas for roads and bridges. The ability of others to restrict
access to an area does not change its status as a public receptor.
i
Not all areas offsite are public receptors. Public roads and bridges are not
considered public receptors. For other areas, you need to make a reasonable
determination as to whether the public is likely to inhabit or occupy an offsite area.
For example, a facility located in a remote mountainous area surrounded by
unimproved forest might reasonably determine that the surrounding land is not a
public receptor, even if it is infrequently traversed by hunters or fishermen. If a
remote facility borders a park or wilderness area, the parts of the park, such as the
campground, picnic area, or hiking trails that are likely to be occupied by the public,
even if only seasonally, would be considered public receptors. Farm land may or
may not be a public receptor. If farm workers are usually present, the farm land is a
public receptor. If, however, the farm or ranch land is rarely occupied by workers, it
may not 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 local ;
emergency planning officials, local or state authorities, the land owners, and your
implementing agency for guidance on whether such areas should be considered as
public receptors. '
WHAT Is A DISTANCE TO AN ENDPOINT FROM A WORST-CASE RELEASE?
The rule establishes "endpoints" for each substance and defines a worst-case release
scenario (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) and either use EPA's guidance or conduct
modeling on your own to determine the distance to the endpoint. Beyond that point,
the effects on people are not considered to be severe enough to merit the need for
additional action under this rale.
January 26,1999
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2-5
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? '
A. The unrestricted areas would be considered potential public receptors.
Q. What is considered a recreational area?
A. Recreational areas would include most bodies of waters (oceans, lakes, rivers, and streams)
because they are used for fishing, swimming, or boating. Areas that are predictably used by hunters,
fishermen, bird watchers, children, bike riders, or hikers would be considered recreational areas.
Areas where there are places for public to gather (e.g., ball fields, picnic tables, jungle gyms, hiking
paths, campsites) would be considered recreational areas. Even if an area is only used during certain
parts of the year for recreation, it would still be considered a recreational area. EPA recognizes that
some judgment is involved in determining whether an area should be considered a public receptor.
You are responsible for making a reasonable judgment. If you have doubts about whether an area
can be legitimately excluded from consideration as a public receptor, EPA encourages you to consult
with 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. If your facility is
surrounded by undeveloped land, you may also want to consult with the land owner.
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 the people will be
present in both at times and would be in more danger if they were outside when a release occurred.
If the owner of a neighboring property restricts access to the land, the question you will need to
consider is whether that land is generally unoccupied. If your site abuts farm land where farm
workers are generally present, it is considered a public receptor. If the land is undeveloped or rarely
has anyone on it, but you are uncertain about whether to consider it a public receptor, you should talk
with the landowner and the community to reach an agreement on 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.
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 any public receptors within that area, your process is not eligible for
Program 1.
January 26, 1999
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Chapter 2
Applicability of Program Levels
2-6
QandA
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.)
ACCIDENT HISTORY
To be eligible for Program 1, no release of the regulated substance from the process
can have resulted in 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.
WHAT is AN INJURY?
An injury is defined as "any effect on a human that results 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
the keeping of the employee injury and illness logs and should be familiar to most
employers. Medical treatment is further defined as treatment, other that 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.
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.
January 26,1999
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2-7
Chapter 2
Applicability of Program Levels
WHA TARE RESTORA TIONAND RESPONSE A CTIVJTIES?
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:
4 Collection and disposal of dead animals and contaminated plant life;
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.
If an impact occurs, such damaged vegetation, and no steps are taken to replace the
vegetation, the process remains eligible for Program 1.
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 is not related to the Federal Class I areas
under CAA section 162. Under Part 68, national parks, monuments, and wilderness areas are not
limited by size criteria. In addition, other areas are covered; for example, national forests and state
parks, monuments, and forests are environmental receptors.
DOCUMENTING PROGRAM 1 ELIGIBILITY
As part of your risk management program., you must keep records of your
compliance with this requirement. For each Program 1 process, your records should
include the following:
4 The worst-case release scenario, which shall include a description of the
vessel or pipeline and substance selected as worst case, assumptions and
parameters used, and the rationale for selection.
January 26, 1999
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Chapter 2
Applicability of Program Levels
2-8
QS&AS
ACCIDENT HISTORY
Q. What is the relationship between the accident history 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. Although both cover the previous five years, the accidental release criteria for Program 1 and
the general accident history for the source are different.
+ 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 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, sheltering-in-place, and evacuations are not relevant. Therefore, it is
possible that a process eligible for Program 1 may 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 the specified consequences.
Q. A process involving a regulated substance had an accidental release with offsite consequences
two years ago. The process has been shutdown. 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 processes that have more than a threshold quantity of a regulated
substance on the date you file your RMP.
Assumptions shall include use of any administrative controls and any passive
mitigation that were assumed to limit the quantity that could be released;
Documentation of estimated quantity released, release rate, and duration of
release;
The methodology used to determine distance to endpoints;
Data used to determine that no public receptor would be affected;
Information on your coordination with public responders.
January 26,1999
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2-9
Chapter 2
Applicability of Program Levels
2.3 QUICK RULES FOR DETERMINING PROGRAM 1 ELIGIBILITY
You generally will not be able to predict with certainty that the worst-case analysis
for a particular process will be eligible 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 toxicity and physical properties of the substances. The
information presented below may be useful in helping you to decide whether to carry
out analyses of processes to determine Program 1 eligibility (accident history criteria
must be met separately).
Toxic GASES
If you have a process containing more than a threshold quantity of any 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 using EPA's
required worst-case assumptions is unlikely to be less than the distance to public
receptors, unless your site is very remote; these distances will generally be several
miles. In some cases, however, toxic gases in processes in enclosed areas may be
eligible for Program 1.
Toxic LIQUIDS
The distance to the endpoint from the worst-case :analysis for 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 the process (within Vz mile),
such processes may be eligible for Program 1. Warehouses in highly developed
areas are unlikely to meet this criterion for most toxic liquids; it will be more
relevant to remotely located warehouses or warehouses found near the center of large
acreage sites. Substances that are potential candidates to be in processes that are
eligible for-Program 1 are noted below. '••
For processes containing toluene diisocyanate (including toluene 2,4-diisocyanate,
toluene 2,6-diisocyanate, and unspecified isomers) or ethylene diamine, the analysis
of a spill of more than a threshold quantity into an undiked area under ambient
conditions is likely to demonstrate eligibility for Program 1. If the area of the spill is
diked, processes containing very large quantities Of these substances may be eligible
for Program 1. In addition, processes containing the following toxic liquids under
ambient conditions are likely to be eligible for Program 1 if a spill would take place
in a diked area and public receptors are not close to the process:
4- Chloroform
4- Cyclohexylamine
4 Hydrazine
4- Isobutyronitrile
4- Isopropyl chloroformate
4 Oleum
4 Propylene oxide
4 Titanium tetrachloride
January 26, 1999
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Chapter 2
Applicability of Program Levels
2-10
4- Vinyl acetate monomer
WATER SOLUTIONS OF Toxic SUBSTANCES
The list of regulated substances includes several common water solutions of toxic
substances. Processes containing such solutions at ambient temperatures may be
eligible for Program 1 (depending in 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 1A mile). As noted above, warehouse in
developed areas are highly unlikely to meet this criterion; it will be more relevant to
remotely located facilities or processes found near the center of large acreage sites.
Processes containing the following water solutions may be eligible for Program 1,
assuming diked areas that would contain the spill and ambient temperatures:
4- Ammonia in solution
4- Formaldehyde (commercial concentrations)
4- Hydrofluoric acid (concentration 50 to 70 percent)
4- Nitric acid (commercial concentrations)
FLAMMABLE SUBSTANCES
Warehouses that handle only 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)
of a regulated flammable substance (other than hydrogen), 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
flammables to determine Program 1 eligibility, unless you have public receptors very
close to the process. You must be able to demonstrate, through your worst-case
analysis, that every process you claim as Program 1 meets the criteria.
2.4 PROGRAM 3
Any covered process that is not eligible for Program 1 and meets one of the two
criteria specified below is covered by Program 3 requirements. Program 3 sets risk
management measures, including compliance with the OSHA PSM Standard, for an
eligible covered process.
WHAT ARE THE ELIGIBILITY CRITERIA FOR PROGRAM 3?
Your process qualifies for Program 3 if:
4- Your process does not meet the eligibility requirements for Program 1, and
January 26, 1999
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2-11
Chapter 2
Applicability of Program Levels
+ Either
> Your process is subject to OSBA PSM (federal or state); or
> Your process is in one often NAICS codes specified by EPA.
WHAT is THE OSHA PSM STANDARD?
The OSHA Process Safety Management standard (codified at 29 CFR 1910.119) is a
formal set of procedures in thirteen management areas designed to protect worker
health and safely from accidental releases. As with EPA's rule, they apply 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 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 ia Program 3 to eliminate the possibility of
imposing overlapping, inconsistent requirements on the same process.
Processes covered by OSHA PSM may include equipment, activities, and regulated
substances, particularly flammables used as fuels, that in other circumstances are
exempted under the OSHA PSM standard. !
WHAT ARE THE TEN NAICS CODES?
Program 3 requirements are applicable to a covered process if the process involves
an activity in one often manufacturing NAICS codes: 32211 (pulp mills), 32411
(petroleum refineries), 32511 (petrochemical manufacturers), 325181 (chlor-alkali
manufacturers), 325188 (al other inorganic chemicals manufacturers), 325192 (other
cyclic crude and intermediate manufacturers), 325199 (all other basic organic
chemical manufacturers), 325211 (plastics and resins manufacturers), 325311
(nitrogen fertilizer manufacturers), and 32532 (pesticide and other agricultural
chemicals manufacturers). These codes are all for manufacturing and, therefore, are
not relevant to warehouses. Even if your warehouse is a support activity for a
chemical manufacturer, it is not considered to be in a manufacturing NAICS code for
the purposes of determining program level. Appendix B provides a list of NAICS
codes for industries that may be subject to part 68.
2.5 PROGRAM 2
Program 2 is considered a default program level because any covered process that is
not eligible for Program 1 and Program 3 requirements is, by default, covered by
Program 2 requirements. Program 2 sets risk management measures, including a
streamlined accident prevention program, for an eligible covered process. Your
process(es) are likely to be in Program 2 if:
January 26, 1999
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Chapter 2
Applicability of Program Levels
2-12
+ You are a publicly owned facility in a state that does not have a delegated
OSHA program.
+ You use or store the regulated acids in solution, and your activities do not
fall into one of the ten specified NAICS codes.
+ You store regulated liquid flammable substances in atmospheric storage
tanks and they are not being used as a fuel.
WHAT ARE THE ELIGIBILITY CRITERIA FOR PROGRAM 2?
i
Your process is eligible for Program 2 if:
+ Your process does not meet the eligibility requirements for Program 1;
+ Your process is not subject to OSHA PSM (federal or state).
Exhibit 2-2 provides a summary of the criteria for determining Program level.
2.6 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 multiple processes subject to different program requirements, you
will need to treat each group of processes in the same program level (and potentially
each process) separately from the other processes and program level requirements.
Nevertheless, you must submit a single RMP for all covered processes. At the same
time, if you prefer, you may choose to adopt the most stringent applicable program
level requirements for all covered processes. For example, 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 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.
CAN THE PROGRAM LEVEL FOR A PROCESS CHANGE?
i i
If a covered process meets the requirements for a new program level, you must
re-evaluate the requirements for the process. If you are switching to another program
level, tibis change must be reflected in an updated RMP that must be submitted
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 "deregister" the process; see Chapter 9 for more information. Typical examples of
switching program levels include:
April 25,2000
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2-13
Chapter 2
Applicability of Program Levels
EXHIBIT 2-2
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
» •* * ,
- ' ' -AMD * . ' > '
No public receptors in worst-
case circle.
' < > - 5AND - "^ , '"
Emergency response
coordinated with local
responders.
Program 2
The process is not eligible for
Program 1 or subject to
Program 3,
c f
^ * **>. «* &• "" f
1
Program 3
Process is not eligible for
Program 1.
:' ".AND . '
Process is subject to OSHA
PSM.
-*<" ;* . "• OR ; ^ ,
Process is classified in NAICS
code
32211 (pulp mills)
32411 (petroleum refineries)
32511 (petrochemical
manufacturers)
325181 (chlor-alkali
manufacturers)
325188 (all other inorganic
chemicals manufacturers)
325192 (other cyclic crude and
intermediate manufacturers)
325199 (all other basic organic
chemical manufacturers)
32521 1 (plastics and resins
manufacturers)
325311 (nitrogen fertilizer
manufacturers)
32532 (pesticide and other
agricultural chemicals
manufacturers)
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Chapter 2
Applicability of Program Levels
2-14
QS&AS
OSHA
Q. If my state administers the OSHA program under a formal delegation from the federal OSHA,
does that mean that my processes subject to OSHA PSM under state rules are in Program 3?
A. Yes (as long as the process does not qualify for Program 1). Any process for which a facility is
complying with PSM, under federal or state rules, is considered to be in Program 3.
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 process 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. They are already substantially in compliance with the Program
3 prevention program to meet their obligations under the state OSHA rules. State and local
governments in non-state-plan states are not subject to any OSHA rules and must comply with
Program 2.
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 is not in one of the ten NAICS codes specified for
Program 3 and 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:
i
+ An OSHA PSM exemption applicable to your process has been eliminated,
January 26,1999
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2-15
Chapter 2
Applicability of Program. Levels
or
i
+ The regulated substance has been added to OSHA's list of highly hazardous
substances.
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,
indicating and documenting that the process is now in compliance with the new
program level requirements.
From Program 1, 2 or 3 to Not Covered. You have a covered process that has
been subject to part 68 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 inust submit a revised RMP within
six months indicating that your process is no longer subject to any program level
requirements.
2.7 SUMMARY OF PROGRAM REQUIREMENTS
Regardless of the program levels you assign to 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). Exhibit 2-3 diagrams the requirements in
general and Exhibit 2-4 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
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
January 26, 1999
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Chapter 2
Applicability of Program Levels
2-16
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.
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.
January 26, 1999
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EXHIBIT 2-3
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)
I
Coordinate with Local Responders
Prepare and Submit One Risk Management Plan for all Covered Processes
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Chapter 2
Applicability of Program Levels
2-18
EXHIBIT 2-4
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 Safety 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
January 26, 1999
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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 that 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:
+ The release must be from a covered procjess 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:
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Chapter 3
Five-Year Accident History
3-2
Date. Indicate the date on which the accidental release began.
I
Time. Indicate the time the release began.
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.
i
i
Release event. Indicate which of the following release events best describes your
accident. Check all that apply:
j
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.
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.
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.
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.,
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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 in1 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.
•4- 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.
+ 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,
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Chapter 3
Five-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.
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.
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3-5
Chapters
Five-Year Accident History
EXHIBIT 3-1
ATMOSPHERIC STABILITY CLASSES
SUBFACK, WMD SPEED ( *
AT 10 MmnmABbvs
* /.GROUND , < ;
Meters per
second
<2
2-3
3-5
5-6
>6
Miles per
hour
<4.5
4.5-7
7-11
11-13
>13
f ,-;-: ;. _ DAY \ / , , '..
'- ' * , -" ",•> . '' ., * , ' ''-*""<'
,% >
Incoming Solar Radiation '
Strong*
A
A-B
B
C
C
Moderate
A-B
B
B-C
C-D
D
Slight**
B;
C
C
D
D:
-_ > . ^NlGHTf * • ~*l"
Thinly
Overcast
or z 4/8
low cloud
E
D
D
D
<3/8
Cloud
F
E
D
D
t Night refers to one hour before sunset to one hour after dawn. •
* Sun high in the sky with no clouds.
** Sun low in the sky with no clouds. '
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.
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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.
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:
> Fish or animal kills.
Januaiy22,1999
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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 mat 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
4- 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).
4- 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).
I
+ Unsuitable Equipment. The equipment used was incorrect for the process.
For example, the forklift was too large for the corridors.
4- Unusual Weather Conditions. Weather conditions, such as lightning, hail,
ice storms, tornados, hurricanes, floods, earthquakes, or high winds
contributed to the accident
4- 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.
4- Improved/ Upgraded Equipment. A device or piece of equipment that did
not function as designed was repaired or replaced.
4- 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).
4- 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.
4- Revised Operating Procedures. Operating procedures were clarified or
changed to ensure that employees and contract employees are trained on
appropriate operating procedures.
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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 minimize 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 fa) 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
+ 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:
j
]
+ Chemical name or identity of all substances involved in the accident
i
+ An estimate of the quantity of substances released to the environment
+ 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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3-11
Chapters
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
Illness portion of the log: :
+ 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
Description of the incident
Factors that contributed to the incident
Any recommendations resulting from the investigation.
4-
4-
4
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.
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Chapter 3
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 off site 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. The offsite consequence analysis (OCA) consists of two elements:
+ A worst-case release scenario and
+ Alternative release scenarios.
To simplify tihe 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 are no
longer likely.
The purpose of this chapter is to give guidance on how to perform the OGA for
regulated substances at warehouses.
Section 68.130 lists 77 toxic substances and 63 flammable substances that are
subject to regulation; however, it is unlikely that they will all be handled at
commercial warehouses. Therefore, during the development of this chapter, EPA
consulted representatives of the American Warehouse Association (AWA) and
obtained a list of regulated chemicals that are commonly handled at warehouses.
These substances are listed in Exhibit 4-1 (toxic substances) and 4-2 (flammable
substances). In addition, generic guidance is given for substances that are not listed
in Exhibit 4-1 or Exhibit 4-2.
This guidance is based on EPA's RMP Offsite Consequence Analysis Guidance
(OCAG). Those parts of the OCAG that you need to use are included in Appendix
4A (which is located at the end of this chapter). See the OCAG (available from
EPA) for more information on the methodology presented here.
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 Internet website at
http://www.epa.gov/swercepp/tools/rmp-comp/rmp-comp.html.
April 25, 2000
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Chapter 4
Offsite Consequence Analysis
4-2
EXHIBIT 4-1
EXAMPLES OF REGULATED TOXIC SUBSTANCES IN WAREHOUSES
Chemical
Boron Trifluoride Compound
with Methyl Ether (1:1)
Cyclohexylamine
Diborane
Epichlorohydrin
Ethylenediamine
Ethylene Oxide
Formaldehyde
Hydrazine
Hydrochloric Acid
Methyl Chloride
Nitric Acid
Propylene Oxide
Sulfur Dioxide
Titanium Tetrachloride
Toluene 2,4- and 2,6-
diisocyanate, plus unspecified
mixtures
Toxic
Endpoint
(mg/L)
0.023
0.16
0.0011
0.076
0.49
0.090
0.012
0.011
0.030
0.82
0.026
0.59
0.0078
0.02
0.007
Typical
Container
55-gallon drum
55-gallon drum
150-lb cylinder
55-gallon drum
55-gallon drum
150-lb cylinder
55-gallon drum and
smaller containers
55-gallon drum
55-gallon drum
150-lb cylinder
55-gallon drum
55-gallon drum
150-lb cylinder
55-gallon drum
55-gallon drum
Potential
Quantity in
Warehouse
Truckload"
1-3 trackloads
10 cylinders
Truckload
2 trackloads
100 cylinders
2 trackloads
3 trackloads
2 trackloads
100-200
cylinders
2 trackloads
2-3 trackloads
100-200
cylinders
#*
1 or more
trackloads
Comments
Pure liquid
Pure liquid
30% cone, in
hydrogen
Pure liquid
80% with other
solvent-type
materials, alcohol
and ethyl acetate
Pressurized gas
10%-50%
solutions in water0
35%, 50%, 85%
solutions in water0
30-38% solutions
in water*
Pressurized gas
80-90% solutions
in water
Pure liquid
Pressurized gas
Pure liquid
Pure liquid11
Buoyant (B)
or Dense (D)
D/Bb
D/B
B/B
D/B
D/B
D/D
B/B
B/B
D/B
D/D
D/B
D/D
D/D
D/B
B/B
See next page for footnotes.
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4-3
Chapter 4
Offsite Consequence Analysis
Footnotes for Exhibit 4-1: •
aA truckload typically contains 78 55-gallon drums
bD/B indicates that the material behaves as a dense gas in worst-case weather conditions and as a neutrally buoyant
(passive) gas in the case of the alternative scenarios, etc.
Tor these solutions in water, the vapor pressures of formaldehyde and hydrazine over the solutions are less than 10
mm Hg. Such mixtures do not fall under the requirements of 40 CFR Part 68 and are not considered further in this
guidance.
dToluene diisocyanate can also be present as ~ 1 to ~ 10 wt% in a mixture of resins, plastics, etc., in 5-gallon pails
up to 350-gallon totes. It is also used as a catalyst in the production of polyurethane foam and may be present in
small quantities in, for example, furniture. These forms of toluene diisocyanate are not considered further in this
guidance.
'Hydrochloric acid in concentrations below 37% is not regulated.
EXHIBIT 4-2
EXAMPLES OF REGULATED FLAMMABLE SUBSTANCES IN WAREHOUSES
Chemical
Acetylene
Dimethylamineb
Isopropyl Chloride
Methylamineb
Pentane
Propane
Trimethylamineb
Vinyl Ethyl Ether
Typical Container
150-lb cylinder
55-gallon drum
55-gallon drum
55-gallon drum
-
33.3-lb steel kegs
or 5,000-7,000-lb
tanks
55-gallon drum
55-gallon drum
Potential
Quantity in
Warehouse
One or two
cylinders
1-2 truckloads
2 truckloads
2+ truckloads
-
Potentially more
than 10,000 Ib
3 truckloads
1 truckload
Comments
Generally not enough to be covered by the
RMPa
40% solution in water
Pure liquid
40% solution in water
Residual pentane in packages of pellets3'0
Used for fueling forklifts and other purposes;
not covered if used as a fuel on site
40% solution in water
Pure liquid
Footnotes for Table 4-2:
"Not considered further in this model guidance.
bAccording to Ullman's Encyclopedia of Industrial Chemistry, the boiling point of 40% monomethylamine is 121 °F
and that of 40% dimethylamiae is 125 °F. Therefore, these mixtures are not regulated under 40 CFR Part 68, which
places an upper limit of 100 °F on the boiling point of regulated flammable isubstances. However, 40%
trimethylamine has a boiling point of 87 °F and is covered.
°Some studies indicate that there is no residual pentane.
April 25, 2000
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Chapter 4
OfTsite Consequence Analysis
4-4
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.
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 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
warehouses in section 4.1, followed by discussions and tables for alternative
scenarios for warehouses in section 4.2. Mitigation provided by buildings is
discussed in section 4.3. Section 4.4 provides information on estimating offsite
receptors, and section 4.5 discusses required documentation.
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
guidance relevant to warehouses. Exhibit 4-3 presents the parameters that must be
used in worst-case and alternative release scenarios.
!
GENERAL REQUIREMENTS FOR Toxic SUBSTANCES
The following input is required for toxic substances:
+ The -worst-case release quantity Q (Ib) is the greater of the following:
> For substances in a vessel, the greatest amount held in that 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 a release from a vessel, you need only consider the largest amotmt in the
vessel. For the specific case of a warehouse, the largest vessels are 350-
gallon totes, 55-gallon drums, 10-gallon pails, 150-lb cylinders, and other
containers that are small relative to typical vessels in a chemical plant.
Therefore, the spillage of the contents of one of these containers constitutes
the worst-case scenario, although you may well be able to think of scenarios
January 26,1999
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4-5
Chapter 4
Offsite Consequence Analysis
EXHIBIT 4-3
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.
4-For flammable substances, endpoint is overpressure of 1 psi for
vapor cloud explosions
+Radiant heat level of 5 kilowatts per square meter (kW/m2) for
40 seconds for heat from fires (or equivalent dose)
+Lower flammability limit (LFL) as specified in NFPA
documents or other generally recognized sources.
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 tunes 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 must 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.
Use urban (obstructed terrain) or rural (flat terrain) topography, as
appropriate .
Dense or neutrally buoyant gases (§68.22(1))
Tables or models used for dispersion of regulated toxic
substances must appropriately account for gas density.
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.
January 26,1999
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Chapter 4
Qffsite Consequence Analysis
4-6
in which a quantity greater than Q as defined above can be released. Other
credible scenarios could involve simultaneous damage to more than one
vessel. EPA recommends that you consider multiple-vessel release
scenarios, if credible and appropriate, as alternative release scenarios (see
Section 4.2).
+ Weather conditions. The rule allows anyone who conducts their 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. For warehouses, the
liquids are assumed to be stored at ambient temperature. 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 for toxic regulated substances are listed 40 CFR Part 68,
Appendix A and in Appendix A of this document. Many of these endpoints
(which are airborne concentrations) have been published by the American
Industrial Hygiene Association (AIHA) as the second level of the Emergency
Response Planning Guidelines (ERPG-2) arid 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. These endpoints should be
applied independent of the exposure time.
+ Rural vs. urban sites. The regulations require you to take account of
whether your site is rural or urban. To decide whether the site is rural or
urban, the rule offers the following: "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.
i
The distinction between urban and rural sites is important because the
atmosphere at urban sites is generally more turbulent than at rural sites,
causing more rapid dilution of the cloud as it travels downwind. Therefore,
for ground-level releases, predicted distances to toxic endpoints are always
smaller at urban sites than at rural sites.
+ Gas density. The regulations require you to use tables or models that
appropriately account for gas density. This guidance provides lookup tables
for dense or neutrally buoyant gases or vapors (i.e., for gases that are denser-
than-air or for gases that have the same density as air, respectively).
January 26, 1999
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4-7
Chapter 4
Offsite Consequence Analysis
Mitigation. You are only allowed to take account of passive mitigation
systems. Passive mitigation systems could include diked areas and buildings
(see Section 4.3 for more information on buildings). You are not allowed to
consider active mitigation systems such, as sprinkler systems or remotely
operated valves.
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.
Toxic LIQUIDS
The worst-case scenario for toxic liquids is a spill of the total quantity in the largest
vessel. The quantity spilled is assumed to spread instantaneously to a depth of one
centimeter in an undiked area or to cover a diked area instantaneously. (This
guidance does not consider diked areas.) The distance to the endpoint is estimated
based on evaporation from the pool and downwind dispersion of the vapor.
For this guidance, the basic assumption is that the container spills and forms an
unconfined pool with a depth of one centimeter. The spill is assumed to be outside,
on or near the loading dock. For discussion of spills inside buildings, see Section
4.3. No credit is taken for drains or other features that might contain the spilled
liquid. For liquids listed in Exhibit 4-1, Exhibit 4-4 provides the distance to the
endpoint for spills from vessels usually found at warehouses. The procedure for
calculating the worst-case distance for liquids is as follows:
1.
2.
For a specific toxic material, identify the largest container and the quantity Q
(Ib) in it.
Use the following equation to calculate the rate of evaporation QR (Ib/min)
from the pool:
QR = 1.4 Q x LFA x DF = aQ ,
(1)
where LFA is the "Liquid Factor Ambient," DF is the "Density Factor," and oc = 1.4
x LFA x DF. LFA and DF have values that depend on the specific liquid that has
been spilled. Their values at 25 "C1 are tabulated in Exhibits B-2 (toxic liquids) and
B-3 (water solutions) in Appendix 4A at the end of this chapter. For the convenience
of the reader, the values of a for the toxic liquids and solutions that are listed in
Exhibit 4-1 are provided in Exhibit 4-4.
^or spills at a temperature greater than 25 °C, see the footnote to Exhibit B-4 in Appendix 4A. Unless
otherwise stated, all spills are assumed to be at 25°C.
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Chapter 4
Offsite Consequence Analysis
4-8
EXHIBIT 4-4
PREDICTED DISTANCES TO TOXIC ENDPOINTS FOR REGULATED TOXIC MATERIALS
Worst Case Scenario, Stability Class F, Wind Speed 1.5 m/s
Chemical/Solution
Name
Boron Trifluoride Compound
with Methyl Ether (1:1)
Cyclohexylamine
Diborane
Epichlorohydrin
Ethylenediamine
Ethylene Oxide
Hydrochloric Acid 30%°
Hydrochloric Acid 34%c
Hydrochloric Acid 36%c
Hydrochloric Acid 37%
Hydrochloric Acid 38%
Methyl Chloride
Nitric Acid 80%
Nitric Acid 85%
Nitric Acid 90%
Propylene Oxide
Sulfur Dioxide
Titanium Tetrachloride
Toluene 2.4-diisocyanate
Toluene 2,6-diisocyanate
a
0.002
0.002
NAa
0.0024
0.0017
NAa
0.0009
0.0028
0.0042
0.0050
0.0060
NAa
0.0009
0.0015
0.0021
0.0770
NAa
0.0020
3.36xlO'6
LOxlO'5
Container
Size
55 gallon
55 gallon
150 Ib
55 gallon
55 gallon
150 Ib
55 gallon
55 gallon
55 gallon
55 gallon
55 gallon
150 Ib
55 gallon
55 gallon
55 gallon
55 gallon
150 Ib
55 gallon
55 gallon
55 gallon
Density
(lb/gallon)b
8.29
7.0
NAa
10.0
8.0
NA"
9.64
9.67
9.69
9.69
9.69
NA"
11.13
11.69
12.55
7.44.
NAa
14.42
10.0
10.0
Quantit
yQ
(ib)
456
385
50
550
440
150
530
532
533
533
533
150
612
643
690
409
150
793
550
550
Rate of
Release
(Ib/min)
0.91
0.780
5
1.32
0.748
15
0.47
1.49
2.23
2.66
3.19
15
0.55
0.96
1.45
31.5
15
1.586
0.0018
0.0055
Distance
Rural Site
(mi)
0.3
<0.1
2.5
0.2
0.1
0.5
0.1
0.3
0.3
0.4
0.5
0.1
0.1
0.3
0.4
0.3
0.7
0.4
<0.1
<0.1
Distance
Urban Site
(mi)
0.2
<0.1
1.3
0.10
<0.1
0.3
<0.1
0.2
0.2
0.2
0.2
<0.1
0.1
0.2
0.2
<0.1
0.3
0.2
0.1
O.I
Footnotes:
"Not applicable—chemical is a gas
bThe density can be obtained from the density factor DF, which is given in Exhibits B-2 and B-3 of Appendix 4A. The density is 1/(DF x 0.033) Ib/ft3. Thus,
for epichlorohydrin, DF = 0.42, so that the density is 1/(0.42 x 0.033) = 72 Ib/ft3. There are 0.134 gallons/ft3, so that the density becomes 0.134 x 72 ~ 10
Ib/gallon.
cHydrochloric acid in concentrations below 37% is not regulated.
January 26,1999
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4-9
Chapter 4
Offsite Consequence Analysis
3. Obtain the toxic endpoint from Exhibit 4-1, together with information on
whether the vapor cloud should be regarded as neutrally buoyant or dense.
For liquids not included in Exhibit 4-1, you can find this information in
Exhibit B-2 (pure liquids) or B-3 (solutions) in Appendix 4A at the end of
this chapter.
4. Determine whether your site is rural or urban.
5. Take the release rate QR and read the predicted distances to the toxic
endpoint from the following tables in Appendix 4A2:
Reference Table 1 (rural site, 10-minute release, neutrally buoyant
vapor cloud)
Reference Table 2 (rural site, 60-minute release, neutrally buoyant
vapor cloud)
Reference Table 3 (urban site, 10-minute release, neutrally buoyant
vapor cloud)
Reference Table 4 (urban site, 60-minute release, neutrally buoyant
vapor cloud)
Reference Table 5 (rural site, 10-minute release, dense vapor cloud)
Reference Table 6 (rural site, 60-minute release, dense vapor cloud)
Reference Table 7 (urban site, 10-minute release, dense vapor cloud)
Reference Table 8 (urban site, 60-minute release, dense vapor
cloud).
Reference Table 10 (specifically for aqueous ammonia).
For the specific case of the toxic liquids and solutions listed on Table 4-1, predicted
distances for the failure of 55-gallon drums are given on Table 4-4 and can simply be
quoted in your Risk Management Plan if the scenario matches your own worst-case
scenario.
Example 1. You have epichlorohydrin above the threshold quantity (TQ) in your
warehouse. The largest container is a 55-gallon drum. You determine that your site
is rural. From Table 4-4, the distance D to the toxic endpoint is 0.2 mi.
Example 2. You have epichlorohydrin in 10-gallon pails, which is a quantity that is
not represented on Exhibit 4-4. Therefore, you need to use both Exhibit 4-4 and the
tables in Appendix 4A, as follows. The density of epichlorohydrin is 10 Ib/gallon
(Exhibit 4-4), so a pail contains 100 Ib. From Exhibit 4-4, a = 0.0024 so that, from
Equation 1, QR = (0.0024)(100) = 0.24 Ib/min. From Exhibit 4-1, the toxic endpoint
of epichlorohydrin is 0.076 mg/L, and it should be treated as a dense vapor. You
2The 60-minute release tables are generally appropriate for spills of toxic liquids because the materials kept
in warehouses usually have low vapor pressures and, hence, low rates of evaporation should they be spilled. For the
examples given in Exhibit 4-4, the time to complete evaporation is greater than 10 minutes for all the liquids. The
time would be several hours for all the liquids except propylene oxide. For solutions of toxic substances in water,
the 10-minute tables should be used.
January 26, 1999
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Chapter 4
Offsite Consequence Analysis
4-10
determine that your site is rural. Therefore, refer to Reference Table 6 in Appendix
4A. ;
The predicted release rate of 0.24 Ib/min is below the lowest release rate of 1 Ib/min
on Reference Table 6. The closest toxic endpoint to 0.076 mg/L is 0.075 mg/L. The
corresponding distance is 0.1 mi3.
Example 3. You have dimethyldichlorosilane in your warehouse in 55-gallon drums
at a rural site. This is an example of a material that is not listed in Exhibit 4-1.
i |
From Exhibit B-2, Appendix 4A, the toxic endpoint of dimethyldichlorosilane is
0.026 mg/L, the LFA is 0.042, and the DF is 0.46. The density p of liquid
dimethyldichlorosilane is 65.9 Ib/ft3 (the density can be calculated from the DF by
using the formula p = 1/(0.033DF), as described in the footnote to Exhibit 4-4). This
converts to 8.83 Ib/gallon (1 gallon is 0.134 ft3). Therefore, a 55-gallon drum
contains Q = 55 x 8.76 = 486 Ib.
The quantity a in Equation 1 is 1.4 x LFA x DF = 0.027. The rate of evaporation is
aQ = 0.027 x 486 = 13 Ib/min.
According to Exhibit B-2 of Appendix 4A, dimethyldichlorosilane should be
modeled as a dense vapor. Turning to Reference Table 6 in Appendix 4A, for a rural
site, look for the closest evaporation rate and toxic endpoint to 13 Ib/min and 0.026
mg/L. The closest release rate is 10 Ib/min, and the closest endpoint is 0.02 mg/L,
giving a distance of 1.4 mi.
Toxic GASES
For toxic gases, the worst-case scenario is release of the contents of the largest vessel
over 10 minutes. For toxic gases listed in Exhibit 4-1, Exhibit 4-4 provides the
distance to the endpoint for the release of a toxic gas from the largest vessel usually
found at a warehouse. The procedure to use for analysis of the worst-case scenario
for toxic cases is as follows.
1. Estimate the quantity Q (Ib) in the largest container
2. Assume that the quantity Q is released over 10 minutes, so that the release
rate is (Q/10) Ib/min.
3. Obtain the toxic endpoint from Exhibit B-l of Appendix 4A, together with
information on whether the vapor cloud should be regarded as neutrally
buoyant or dense.
I
4. Determine whether your site is rural or urban.
In Reference Table 6 and other tables in Appendix 4-A, results are rounded to the nearest tenth of a mile
for distances under ten miles, and to the nearest mile for distances over ten miles. This is a reminder that the results
of atmospheric dispersion modeling are uncertain and that more accurate predictions are not warranted.
January 26,1999
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Chapter 4
Offsite Consequence Analysis
5. Determine the distance to the toxic endpoint by using one of the following
tables:
Reference Table 1 (rural site, 10-minute release, neutrally buoyant
vapor cloud)
Reference Table 3 (urban site, 10-minute release, neutrally buoyant
vapor cloud)
Reference Table 5 (rural site, 10-minute release, dense vapor cloud),
or
Reference Table 7 (urban site, 10-minute release, dense vapor
cloud).
Reference Table 9 - specifically for anhydrous ammonia
Reference Table 11 - specifically for chlorine
Reference Table 12 - specifically for sulfur dioxide
Only 10-minute tables are relevant because the rule mandates that for the
worst-case scenario, gases are released over 10 minutes.
Example 4. Diborane is one of the gaseous materials listed on Exhibit 4-1. The
steps listed above have already been carried out for this material, and the results are
displayed on Exhibit 4-4 —3 mi at a rural site and 2.1 mi at an urban site. (Note that
the diborane is assumed to be in a 150-lb cylinder, but as only about 30 wt% in
hydrogen. Therefore, only 50 Ib of diborane is released and the predicted release
rate is 5 Ib/min, not 15 Ib/min.)
Example 5. You have arsine in 150-lb cylinders at a rural site. This is another
example of a material that is not on Exhibit 4-1. The worst-case release rate is 15
Ib/min. From Exhibit B-l of Appendix 4A, the toxic endpoint is 0.0019 mg/L and
the release should be treated as a dense vapor cloud. Turning to reference Table 5 of
Appendix 4A, the closest tabulated toxic endpoint is 0.002 mg/L. The closest
release rate is 10 Ib/min, for a predicted distance:of 3 mi.
FLAMMABLE SUBSTANCES
For the worst-case scenario involving a release of a regulated flammable substance
(a flammable gas or volatile flammable liquid), you must assume that the quantity of
the flammable substance is released into a vapor cloud. A vapor cloud explosion is
assumed to result from the release. You must estimate the distance D (mi) to an
endpoint to an overpressure level of 1 pound per square inch (psi) from the explosion
of the vapor cloud.
+ If the flammable substance is normally a gas at ambient temperature and
handled as gas or liquid under pressure or if the flammable substance is a gas
handled as a refrigerated liquid and is not contained when released or the
contained pool is one centimeter or less deep, you must assume the total
quantity is released as a gas and is involved in a vapor cloud explosion.
+ If the flammable substance is a liquid or a refrigerated gas released into a
containment area with a depth greater than one centimeter, you may assume
April 25, 2000
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Chapter 4
Offsite Consequence Analysis 4-12
that the quantity that volatilizes in 10 minutes is involved in a vapor cloud
explosion.
A simple method of obtaining an approximate answer is to use the TNT equivalency
method, which states that:
D = 0.0037(Q x H/HTOT)1/3 (2)
where Q (Ib) is the quantity of flammable material released, H is the heat of
combustion of the flammable substance and H^r is the heat of combustion of
trinitrotoluene (TNT). Implicit in Equation 2 is the assumption that the yield factor
is 10%, as required by the rule. The yield factor is the fraction of the material in the
vessel that effectively participates in the explosion. Equation 2 can be rewritten as
i i
D = A (Q)1/3 miles (3)
The values of A for the flammable materials listed in Table 4-2 are given below:
A ;
Ethyl Mercaptan 0.0067
Isopropyl Chloride 0.0063
Propane 0.0080
Trimethylamine 0.0074
Vinyl Ethyl Ether 0.0070
•
i
If you prefer, you can find the distance to 1 psi overpressure for the quantity released
from Reference Table 13 in Appendix 4A, instead of using Equation 3. Reference
Table 13 also includes flammable substances that are not in the above list.
|
Example 6. If 5,000 Ib of propane explodes, Equation 3 gives:
D = 0.0080 (5,000)1/3 = 0.14 mi
For reporting, you would round the distance to 0.1 mile.
i i
Example 7. If a 55-gallon drum of vinyl ethyl ether spills and forms a vapor cloud,
this vapor cloud will contain (55 gallons)(6.36 Ib/gallon) = 350 Ib of vinyl ethyl
ether. If it explodes, then:
D = (0.0070)(350)I/3 = 0.05 mi
Example 8. A 55-gallon drum containing a 40 wt% solution of trimethylamine
spills. The density of this solution is 6 Ib/gallon, so there is a total of (0.4)(55)(6) =
132 Ib of trimethylamine. From Equation 3, D = 0.0074(132)1/3 = 0.038 mi, which
you would round to 0.04 mi.
i
Vapor cloud explosions involving small quantities generally are considered very
unlikely. If you have a flammable chemical above the threshold quantity, however,
January 26,1999
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4-13
Chapter 4
Offsite Consequence Analysis
you must assume a vapor cloud explosion for your worst-case scenario, even if your
largest vessel contains a relatively small quantity.
The explosions discussed above are assumed to take place outside. Many
warehouses keep flammable materials in a room that is specially designed with
explosion venting per NFPA requirements. However, the intention of this section is
to provide information on the worst-case scenario. There are probably times when
you handle the containers of flammable substances outside. Nevertheless, in
discussions with local agencies and local communities you may want to explain how
your facility is designed to ensure that worst-case explosions do not occur or are
effectively mitigated.
4.2 ALTERNATIVE SCENARIOS
The purpose of this section is to give guidance on how to model alternative
scenarios.
GENERAL REQUIREMENTS
The requirements that differ from those for the 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.
For warehouses, the building itself could function as a passive system and
the fire sprinklers could be regarded as an active system.
+ The alternative scenario should reach an endpoint offsite, unless no such
scenario exists.
+ I f 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 regulated 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.
+ The release is not necessarily restricted to ground level. It can be elevated if
appropriate. An elevated release might be appropriate for a warehouse with
several floors (analysis of elevated releases would be site-specific and is not
considered in this guidance).
January 26, 1999
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Chapter 4
OfFsite Consequence Analysis
4-14
CHOICE OF ALTERNATIVE SCENARIOS FOR Toxic LIQUIDS
I
There are some significant issues when it comes to choosing alternative scenarios for
warehouses:
+ As already noted, plausible alternative scenarios could well be larger than
the single-container worst-case scenarios;
+ The alternative scenario should be more probable than the worst-case
scenario, yet spillage from a single container is among the more probable
scenarios.
i 1
The following subsections contain some suggested alternative scenarios.
i I
SINGLE-CONTAINER ALTERNATIVE SCENARIO
One possibility is to take the same scenario as the worst-case (i.e., a spill of the
contents of a single vessel), but to assume that it takes place in typical weather
conditions. Exhibit 4-5 provides distances to the endpoint for this scenario for the
substances listed in Exhibit 4-1. The procedure for calculating the alternative
scenario distance is very similar to that for the worst-case scenario:
+ For a specific toxic material, identify the largest vessel and the quantity Q
(lb) in it.
+ Use Equation 4 below to calculate the rate of evaporation QR (Ib/min.) from
the pool formed by the spill of quantity Q in alternative weather conditions:
QR = 2.4 Q x LFA x DF = PQ
(4)
where LFA is the "Liquid Factor Ambient," DF is the "Density Factor," and
p = 2.4 x LFA x DF. LFA and DF have values that depend on the specific
liquid that has been spilled. Their values are tabulated in Exhibits B-2 (toxic
liquids) and B-3 (water solutions) of Appendix 4A. For the convenience of
the reader, the values of p that are appropriate for alternative scenarios are
provided in Exhibit 4-5.
Determine whether your site is rural or urban.
Read the toxic endpoint from Exhibit B-2 or Exhibit B-3 of Appendix 4A,
together with whether the vapor should be modeled as neutrally buoyant or
dense.
Take the release rate QR and read the predicted distances to the toxic
endpoint from the following tables in Appendix 4A:
> Reference Table 14 (rural site, 10-minute release, neutrally buoyant
vapor cloud)
January 26,1999
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4-15
Chapter 4
Offsite Consequence Analysis
> Reference Table 15 (rural site, 60-minute release, neutrally buoyant
vapor cloud)
> Reference Table 16 (urban site, 10-minute release, neutrally buoyant
vapor cloud)
> .Reference Table 17 (urban site, 60-minute release, neutrally buoyant
vapor cloud)
> Reference Table 18 (rural site, 10-minute release, dense vapor
cloud)
> Reference Table 19 (rural site, 60-minute release, dense vapor
cloud)
> Reference Table 20 (urban site, 60-minute release, dense vapor
cloud)
> Reference Table 21 (urban site, 60-minute release, dense vapor
cloud)
> Reference Table 23 - specifically for aqueous ammonia
For spilled water solutions, you should assume a 10-minute duration of release
because LFA is calculated as a 10-minute average. For the other toxic liquids, the
predicted time to total evaporation of the pool at the rate given by Equation 4 is
generally much more than 10 minutes, so you will need to use the 60-minute tables
unless your alternative scenario has been terminated in 10 minutes or less (e.g., by
some emergency countermeasure).
For the specific case of the toxic liquids and solutions listed on Exhibit 4-1,
predicted distances are given on Exhibit 4-5 and,can simply be quoted in your Risk
Management Plan if the scenario matches one of your own alternative scenarios.
Example 9. You have ethylenediamine above the TQ in your warehouse. The
largest container is a 55-gallon drum. You determine that your site is rural.
Ethylenediamine is on Exhibit 4-5, and the corresponding distance to the toxic
endpoint is < 0.1 mi.
Example 10. You have epichlorohydrin in. 10-gallon pails, which are not
represented on Exhibit 4-5. Therefore, you need to use the tables in Appendix 4A, as
follows. The density of epichlorohydrin is 10 Ib/gallon, so a pail contains Q = 100
Ib. From Exhibit 4-5, P = 0.0040 so that, from Equation 4, QR = (0.0040)(100) =
0.40 Ib/min. From Exhibit 4-1, the toxic endpoint of epichlorohydrin is 0.076 mg/L,
and it should be modeled as a buoyant vapor. You determine that your site is rural.
Turning to Reference Table 15 in Appendix 4A, you need to calculate the ratio
between the release rate and the toxic endpoint, which, for convenience, we call 8.
In this case, 8 = 0.38/0.076 = 5, which lies in the lowest tabulated range for 8 on
Reference Table 15, corresponding to a distance to the toxic endpoint of 0.1 mi.
MULTIPLE CONTAINER ALTERNATIVE SCENARIO
A plausible scenario is that two or more containers could be punctured by a fork lift
truck. The procedure to follow for this scenario;for toxic liquids is the same
procedure presented in the previous subsection; only the quantity spilled is different.
The evaporation rate displayed in Exhibit 4-5 should then be multiplied by the
January 26, 1999
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Chapter 4
OfFsite Consequence Analysis
4-16
number of ruptured containers. The predicted distances to the toxic endpoint are
given on Exhibit 4-6 for the example of two ruptured containers.
Example 11. You have an accident in which four containers of 37% hydrochloric
acid are ruptured in typical weather conditions at a rural site. The predicted rate of
evaporation is then four times that on Exhibit 4-5, i.e., 4 x 4.58 = 18.32 Ib/min.
From Exhibit 4-1, 37% hydrochloric acid is neutrally buoyant in alternative
scenarios, and its toxic endpoint is 0.03 mg/L. Hence, 5 = 18.32/0.03 = 610.
Turning to Reference Table 1 in Appendix 4A, this value of 6 is close to the
tabulated value of 630, corresponding to 0.2 mi.
ALTERNATIVE SCENARIO - Toxic GASES
For alternative scenarios for toxic gases, you may consider the worst-case release
under typical weather conditions or a release involving multiple containers, as
discussed above for liquids. Exhibits 4-5 and 4-6 provide distances to the endpoint
for these alternative scenarios for toxic gases listed in Exhibit 4-1. The procedure to
use is as follows.
1. Estimate the release rate in Ib/min for the alternative scenario.
i
2. Obtain the toxic endpoint from Exhibit B-1 of Appendix 4A, together with
information on whether the vapor cloud should be regarded as neutrally
buoyant or dense.
3. Determine whether your site is rural or urban.
4. Determine the distance to the toxic endpoint by using one of'the following
tables:
> Reference Table 14 (rural site, 10-minute release, neutrally buoyant
vapor cloud)
> Reference Table 15 (rural site, 60-minute release, neutrally buoyant
vapor cloud)
> Reference Table 16 (urban site, 10-minute release, neutrally buoyant
vapor cloud)
> Reference Table 17 (urban site, 60-minute release, neutrally buoyant
vapor cloud)
> Reference Table 18 (rural site, 10-minute release, dense vapor
cloud)
> Reference Table 19 (rural site, 60-minute release, dense vapor
cloud)
> Reference Table 20 (urban site, 10-minute release, dense vapor
cloud)
January 26,1999
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Offsite Consequence Analysis
4-17
EXHIBIT 4-5
PREDICTED DISTANCES TO TOXIC ENDPOINTS FOR REGULATED TOXIC MATERIALS
Alternative Case Scenario No. 1 - Release from Single Container, Stability Class D, Wind Speed 3.0 m/s
Chemical/Solution
Name
Boron Trifluoride Compound
with Methyl Ether (1:1)
Cyclohexylamine
Diborane
Epichlorohydrin
Ethylenediamine
Ethylene Oxide
Hydrochloric Acid 30%b
Hydrochloric Acid 34%b
Hydrochloric Acid 36%b
Hydrochloric Acid 37%
Hydrochloric Acid 38%
Methyl Chloride
Nitric Acid 80%
Nitric Acid 85%
Nitric Acid 90%
Propylene Oxide
. Sulfur Dioxide
Titanium Tetrachloride
Toluene 2,4-diisocyanate
Toluene 2,6-diisocyanate
P
0.0035
0.0034
NAa
0.0040
0.0029
NA"
0.0016
0.0048
0.0073
0.0086
0.0098
NAa
0.0015
0.0025
0.0036
0.13
NAa .
0.0032
5.76X10'6
1.7xlO-5
Container Size
55 gallon
55 gallon
150 Ib
55 gallon
55 gallon
150 Ib
55 gallon
55 gallon
55 gallon
55 gallon
55 gallon
150 Ib
55 gallon
55 gallon
55 gallon
55 gallon
150 Ib
55 gallon
55 gallon
55 gallon
Quantity Q
(Ib)
570
385
50
550
440
150
530
532
533
533
533
150
612
643
690
409
150
793
550
550
Rate of Release
(Ib/min)
1.93
1.30
5
2.20
1.28
15
0.85
2.55
3.89
4.58
5.22
15
0.92
1.61
2.48
53.17
15
2.54
0.0032
0.0095
Distance
Rural Site (mi)
0.2
<0.1
0.
<0.1
0.1
0.1
<0.1
0.1
0.1
0.1
0.1
0.1
O.I
O.I
0.1
0.1
0.4- -
0.1
O.I
0.1
Distance
Urban Site (mi)
O.I
O.I
0.4
O.I
O.I
O.I
0.1
O.I
0.1
O.I
0.1
O.I
O.I
O.I
O.I
O.I
0,3
O.I
O.I
O.I
Footnotes:
"Not applicable—chemical is a gas
bHydrochloric acid in concentrations below 37% is not regulated.
January 26,1999
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Chapter 4
Offsite Consequence Analysis
4-18
Reference Table 21 (urban site, 60-minute release, dense vapor
cloud)
Reference Table 22 - specifically for anhydrous ammonia
Reference Table 24 - specifically for chlorine
Reference Table 25 - specifically for sulfur dioxide
Example 12. Diborane is one of the gaseous materials listed on Exhibit 4-1.
Assuming that the alternative scenario is the same as the worst-case scenario,
Example 4, except that the weather conditions have changed from worst-case to
typical, the steps listed above have already been carried out for this material. The
results are listed on Exhibit 4-5: ~ 0.8 mi at a rural site and ~ 0.4 mi at an urban site.
For an alternative scenario that consists of the release of two cylinders of diborane
over a period of 10 minutes, the results may be read from Exhibit 4-6 and are ~ 1.0
mi at a rural site and ~ 0.6 mi at an urban site.
Example 13. You have arsine in 150-lb cylinders at a rural site. Arsine is not on
Exhibit 4-5. The worst-case release rate is 15 Ib/min for 10 min. Assume that this
release rate is the same for the alternative scenario and that the only difference is in
the weather conditions. From Exhibit B-l of Appendix 4A, the toxic endpoint is
0.0019 mg/L and the release should be treated as a dense vapor cloud. Turning to
Reference Table 18 of Appendix 4A, the closest tabulated toxic endpoint is 0.002
mg/L. The closest release rate is 10 Ib/min, for a predicted distance of 0.9 mi.
ALTERNATIVE SCENARIOS FOR FLAMMABLE SUBSTANCES
For many owners of warehouses, a fire is potentially the most damaging scenario.
However, there are several considerations involved in modeling scenarios for
flammable substances within the context of the RMP.
+ Toxic materials in plumes generated by fires do not have to be considered
under the RMP rule, although toxic combustion products might be generated.
+ Under the RMP rule, endpoints for regulated flammable substances are
specified for explosions, radiant heat, and dispersion to the lower
flammability limit (LFL).
+ Effects such as heat released by unregulated materials are not considered
under the RMP rule; such effects might be a major problem in warehouse
fires.
Alternative scenarios for regulated flammable substances at warehouses could
include pool fires and vapor cloud fires (assuming dispersion to the LFL), as
discussed below.
January 26,1999
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EXHIBIT 4-6
PREDICTED DISTANCES TO TOXIC ENDPOINTS FOR REGULATED TOXIC MATERIALS
Alternative Case Scenario No. 2 - Release from Two Containers, Stability Class D, Wind Speed 3.0 m/s
Chemical/Solution
Name
Boron Trifluoride Compound
with Methyl Ether (1:1)
Cyclohexylamine
Diborane
Epichlorohydrin
Ethylenediaminc
Ethylene Oxide
Hydrochloric Acid 3()%h
Hydrochloric Acid 34%h
Hydrochloric Acid 36%b
Hydrochloric Acid 37%
Hydrochloric Acid 38%
Methyl Chloride
Nitric Acid 80%
Nitric Acid 85%
Nitric Acid 90%
Propylene Oxide
Sulfur Dioxide
Titanium Tetrachloride
Toluene 2,4-diisocyanate
Toluene 2,6-diisocyanate
P
0.0035
0.0034
NA"
000-10
0 002')
NA'
0.00 16
0.00-18
0.0073
0.0086
0.0098
NAa
0.0015
0.0025
0.0036
0.13
NAa
0.0032
5.79xlO'6
. 1.7xlO'5
Container Size
55 gallon
55 gallon
1501b
55 gallon
55 gallon
15()lb
55 gallon
55 gallon
55 gallon
55 gallon
55 gallon
150 Ib
55 gallon
55 gallon
55 gallon
55 gallon
1501b
55 gallon
55 gallon
55 gallon
Quantity Q
(Ib)
1140
770
100
1100
880
300
1060
1064
1066
1066
1066
300
1224
1286
1380
818
300
1586
1100
1100
Rate of Release
(Ib/min)
3.87
2.61
10
4.40
2.55
30
1.7
5.1
7.78
9.16
10.44
30
1.84
3.22
4.96
106
30
5.08
0.0064
0.019
Distance
Rural Site (mi)
<0.1
<0.1
1.0
<0.1
<0.1
0.1
<0.1
<0.1
0.1
0.1
0.1
<0.1
<0.1
<0.1
0.1
0.1
0.6
0.1
<0.1
<0.1
Distance
Urban Site (mi)
<0.1
<0.1
0.6
<0.1
<0.1
<0.1
<0.1
<0.1
<0.1
<0.1
0.1
<0.1
<0.1
<0.1
<0.1
<0.1
0.3
<0.1
<0.1
<0.1
Footnotes:
aNot applicable—chemical is a gas.
"Hydrochloric acid in concentrations below 37% is not regulated.
January 26,1999
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Chapter 4
Offsite Consequence Analysis
4-20
For pool fires involving spillages of flammable liquids, the following equation gives
an estimate for the distance D (ft) from a pool fire at which people could potentially
receive a second-degree burn after 40 seconds:
D = PFF A'
0.5
(5)
where PFF is the "Pool Fire Factor", and A is the area of the pool in ft2. The PFF is
tabulated in Exhibits C-2 and C-3 of Appendix 4A.
Example 14. You have vinyl ethyl ether in a 55-gallon drum (350 Ib). It spreads to
form a pool of depth 1 cm. The area is given by A = 350 * DF, where DF is
tabulated in Exhibit C-3 and is 0.65 for vinyl ethyl ether: A = 350 x 0.65 = 228 ft2
so that A0'5 = 15 ft From Exhibit C-3 of the OCAG, PFF = 4.2 so that D = 4.2 x 15
~ 60 ft. (You also can consider spills from multiple drums. Multiply A for one
drum by the number of drums involved.)
Another alternative flammable scenario is a vapor cloud fire. You would calculate
the distance to the LFL. that is, the distance to which the cloud propagates before
diluting below the lower flammable limit, assuming the vapor cloud then ignites.
You need to determine the release rate, as described for toxic substances. The data
you need for flammable substances, including the LFL, are in Exhibits C-2 (for
flammable gases) and C-3 (for flammable liquids) in Appendix 4A.
The appropriate reference tables for determining the predicted distance to the LFL
are as follows:
Neutrally buoyant plume, rural site, Reference Table 26
Neutrally buoyant plume, urban site, Reference Table 27
Dense plume, rural site, Reference Table 28
Dense plume, urban site, Reference Table 29
Example 15. Vinyl ethyl ether is spilled from a 55-gallon drum (containing 350 Ib)
at an urban site. As shown in Example 14, it forms a pool of depth 1 cm and area
228ft2. The rate of evaporation is given by QR = 2.4Q x LFA x DF. LFAisO.10
and DF is 0.65, from Exhibit C-3 of Appendix 4A. Hence, QR =
(2.4)(350)(0.1 )(0.65) = 55 Ib/min. From Exhibit C-3 of Appendix 4A, the LFL for
vinyl ethyl ether is 50 mg/L, and it should be treated as a dense gas. From Reference
Table 28, the predicted distance to the LFL at a rural site is < 0.1 mi for any release
rate < 1,500 Ib/min.
4.3 BUILDINGS
Buildings may be considered provide passive mitigation in some cases. Unless your
containers of regulated substances 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, because there will be some time when the vessels are
outdoors. If your containers are delivered indoors or if your largest vessel is indoors,
January 26,1999
-------
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. However, warehouses vary over a wide
range in their strength of construction, the surface area of ventilation outlets, and
their purpose. In addition, warehouse doors are often left open for considerable
periods.
For toxic liquids, EPA has provided simple building release rate reduction factors for
indoor releases of 10% for worst-case scenarios and 5% for alternative scenarios
(i.e., the predicted rate of release is 10% or 5% of that for the same accident if it
should occur outdoors). These factors are based on data for a building with a
ventilation rate of 0.5 air changes per hour. The factors are applicable to releases in
a fully enclosed, non-airtight space that is directly adjacent to the outside air. They
do not apply to a space that has doors or window;s that could be open during a
release. (See Appendix D of the OCAG for more discussion of the mitigation
factors.)
For toxic gases, the EPA's reduction factor is 55%, for both worst-case and
alternative scenarios. This factor also is based on 0.5 air changes per hour. It is
applicable to releases in the same type of enclosure as the factors for liquids. (See
Appendix D of the OCAG for more discussion.)
You are at liberty to provide building-specific models of the mitigating effects of
structures. Generally, such modeling requires the use of numerical simulation and
specialized computer programs.
Example 16. Returning to Example 3, you have dimethyldichlorosilane in your
warehouse in 55-gallon drums at a rural site. Assume that the release takes place
inside the warehouse in worst-case weather conditions. The effective release rate is
then reduced by a factor of 10 from 13 Ib/min to; 1.3 Ib/min. From Exhibit B-2 of
Appendix 4A, the toxic endpoint of dimefhyldichlorosilane is 0.026 mg/L, and it
should be modeled as a dense vapor. Turning to,Reference Table 6 of Appendix 4A,
for a rural site, look for the evaporation rate closest to 1.3 Ib/min and the toxic
endpoint closest to 0.026 mg/L. This is 1 Ib/min and 0.02 mg/L, giving a distance of
0.3 mi.
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 arelease 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
January 26, 1999
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Chapter 4
Offsite Consequence Analysis
4-22
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.
i
OTHER PUBLIC RECEPTORS
! ' 1
Other public receptors must be noted in the KMP (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 develop a list of all public
receptors; you must simply check off that one or more such areas is 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.
i
Important: The rule does not require you to assess the likelihood, 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 the endpoint. Figure 4-1 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
should use a real map of the area surrounding the site).
January 26,1999
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Chapter 4
Offsite Consequence Analysis
4-23
Organizations that have already begun to prepare 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 LANDVIEW®
Census data can be found in publications of the Bureau of the Census, available in public libraries,
including County and City Data Book.
LandView ®HI 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-KIT $99 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/ftp/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.
January 26, 1999
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Chapter 4
Offsite Consequence Analysis
4-24
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 data 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
http://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
http://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.
Other data that you should provide includes:
+ Documentation of estimated quantity released, release rate and duration of
release.
January 26,1999
-------
Chapter 4
Offsite Consequence Analysis
4-25
Methodology used to determine distance to endpoints (it will be sufficient to
reference this guidance).
Data used to identify potentially affected population and environmental
receptors.
January 26, 1999
-------
Figure 4-1 Simplified Presentation of Worst-Case
and Alternative Scenario on a Local Map
Radius for
Alternative
Scenario
A Street
Radius for
Worst-case Scenario
1/2
Miles
-------
Chapter 4
Offsite Consequence Analysis
4-27
APPENDIX 4A
REFERENCE TABLES OF DISTANCES AND TABLES OF DATA FROM THE
OFFSITE CONSEQUENCE ANALYSIS GUIDANCE
The following tables from the RMP Offsite Consequence Analysis Guidance are reproduced here for the
convenience of the reader.
Reference Tables of Distances
Reference Table 1—Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided by
Endpoint, 10-Minute Release, Rural Conditions, F Stability, Wind Speed 1.5 Meters per Second
Reference Table 2—Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided by
Endpoint, 60-Minute Release, Rural Conditions, F Stability, Wind Speed 1.5 Meters per Second
Reference Table 3—Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided by
Endpoint, 10-Minute Release, Urban Conditions, F Stability, Wind Speed 1.5 Meters per Second
Reference Table 4—Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided by
Endpoint, 60-Minute Release, Urban Conditions, F Stability, Wind Speed 1.5 Meters per Second
Reference Table 5—Dense Gas Distances to Toxic Endpoint, 10-Minute Release, Rural Conditions, F
Stability, Wind Speed 1.5 Meters per Second
Reference Table 6—Dense Gas Distances to Toxic Endpoint, 60-Minute Release, Rural Conditions, F
Stability, Wind Speed 1.5 Meters per Second
Reference Table 7—Dense Gas Distances to Toxic Endpoint, 10-Minute Release, Urban Conditions, F
Stability, Wind Speed 1.5 Meters per Second
Reference Table 8—Dense Gas Distances to Toxic Endpoint, 60-Minute Release, Urban Conditions, F
Stability, Wind Speed 1.5 Meters per Second
Reference Table 9—Distances to Toxic Endpoint for Anhydrous Ammonia Liquefied Under Pressure, F
Stability, Wind Speed 1.5 Meters per Second ' :
Reference Table 10—Distances to Toxic Endpoint for Aqueous Ammonia, F Stability, Wind Speed 1.5
Meters per Second
Reference Table 11—Distances to Toxic Endpoint for Chlorine, F Stability, Wind Speed 1.5 Meters per
Second
Reference Table 12—Distances to Toxic Endpoint for Sulfur Dioxide, F Stability, Wind Speed 1.5
Meters per Second
Reference Table 13—Distance to Overpressure of 1.0 psi for Vapor Cloud Explosions of 500 -
2,000,000 Pounds of Regulated Flammable Substances Based on TNT Equivalent Method, 10 Percent
Yield Factor
Reference Table 14—Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided
by Endpoint, 10-Minute Release, Rural Conditions, D Stability., Wind Speed 3.0 Meters per Second
Reference Table 15—Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided
by Endpoint, 60-Minute Release, Rural Conditions, D Stability., Wind Speed 3.0 Meters per Second
Reference Table 16—Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided
by Endpoint, 10-Minute Release, Urban Conditions, D Stability, Wind Speed 3.0 Meters per Second
Reference Table 17—Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided
by Endpoint, 60-Minute Release, Urban Conditions, D Stability, Wind Speed 3.0 Meters per Second
Reference Table 18—Dense Gas Distances to Toxic Endpoint, 10-Minute Release, Rural Conditions, D
Stability, Wind Speed 3.0 Meters per Second
January 26, 1999
-------
Chapter 4
Offsite Consequence Analysis
4-28
Reference Table 19—Dense Gas Distances to Toxic Endpoint, 60-Minute Release, Rural Conditions, D
Stability, Wind Speed 3.0 Meters per Second
Reference Table 20—Dense Gas Distances to Toxic Endpoint, 10-Minute Release, Urban Conditions, D
Stability, Wind Speed 3.0 Meters per Second
Reference Table 21—Dense Gas Distances to Toxic Endpoint, 60-Minute Release, Urban Conditions, D
Stability, Wind Speed 3.0 Meters per Second
Reference Table 22—Distances to Toxic Endpoint for Anhydrous Ammonia, D Stability, Wind Speed
3.0 Meters per Second
Reference Table 23—Distances to Toxic Endpoint for Aqueous Ammonia, D Stability, Wind Speed 3.0
Meters per Second
Reference Table 24—Distances to Toxic Endpoint for Chlorine, D Stability, Wind Speed 3.0 Meters per
Second
Reference Table 25—Distances to Toxic Endpoint for Sulfur Dioxide, D Stability, Wind Speed 3.0
Meters per Second
Reference Table 26—Neutrally Buoyant Plume Distances to Lower Flammability Limit (LFL) for
Release Rate Divided by LFL, Rural Conditions, D Stability, Wind Speed 3.0 Meters per Second
Reference Table 27—Neutrally Buoyant Plume Distances to Lower Flammability Limit (LFL) for
Release Rate Divided by LFL, Urban Conditions, D Stability, Wind Speed 3.0 Meters per Second
Reference Table 28—Dense Gas Distances to Lower Flammability Limit Rural Conditions, D Stability,
Wind Speed 3.0 Meters per Second
Reference Table 29—Dense Gas Distances to Lower Flammability Limit Urban Conditions, D Stability,
Wind Speed 3.0 Meters per Second
Tables of Data
Exhibit B-l—Data for Toxic Gases
Exhibit B-2—Data for Toxic Liquids
Exhibit B-3—Data for Water Solutions of Toxic Substances and for Oleum, Average Vapor Pressure
and Liquid Factors over 10 Minutes for Wind Speeds of 1.5 and 3.0 Meters per Second (m/s)
Exhibit B-4—Temperature Correction Factors for Liquids Evaporating from Pools at Temperatures
Between25°C and 50°C (77°F and 122°F)
Exhibit C-l—Heats of Combustion for Flammable Substances
Exhibit C-2—Data for Flammable Gases
Exhibit C-3—Data for Flammable Liquids
January 26,1999
-------
Chapter 4
Offsite Consequence Analysis
4-29
Reference Table 1
Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided by Endpoint
10-Minute Release, Rural Conditions, F Stability, Wind Speed 1.5 Meters per Second
Release
Rate/Endpoint
[(lbs/min)/(mg/L)] (8)
0-4.4
4.4 - 37
37-97
97 - 180
180 - 340
340 - 530
530 - 760
760 - 1,000
1,000 - 1,500
1,500-1,900
1,900 - 2,400
2,400 - 2,900
2,900 - 3,500
3,500 - 4,400
4,400 - 5,100
5,100-5,900
5,900 - 6,800
6,800 - 7,700
7,700 - 9,000
9,000 - 10,000
10,000-11,000
11,000-12,000
12,000 - 14,000
14,000 - 15,000
15,000-16,000
Distance to
Endpoint
(miles)
0.1
0.2
0.3
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
2.2
2.4
2.6
2.8
3.0
3.2
3.4
3.6
3.8
4.0
4.2
4.4
4.6
Release
Rate/Endpoint
[(Ibs/min)/(mg/L)] (8)
16,000-18,000
18,000, -19,000
19,000-21,000
21,000-23,000
23,000-24,000
24,000-26,000
26,000 - 28,000
28,000 - 29,600
29,600 - 35,600
35,600 - 42,000
42,000-48,800
48,800 - 56,000
56,000-63,600
63,600-71,500
71,500-88,500
88,500 - 107,000
107,000 '- 126,000
126,000 - 147,000
147,000 - 169,000
169,000-191,000
191,000 i- 215,000
215,000 - 279,000
279,000 - 347,000
>347,000
Distance to
Endpoint
(miles)
4.8
5.0
5.2
5.4
5.6
5.8
6.0
6.2
6.8
7.5
8.1
8.7
9.3
9.9
11
12
14
15
16
17
19
22
25
>25*
: Report distance as 25 miles
January 26, 1999
-------
Chapter 4
Offsite Consequence Analysis
4-30
Reference Table 2
Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided by Endpoint
60-Minute Release, Rural Conditions, F Stability, Wind Speed 1.5 Meters per Second
Release
Rate/Endpoint
rabs/min)/(mg/L)] (6)
0-5.5
5.5-46
46 - 120
120 - 220
220 - 420
420 - 650
650 - 910
910 - 1,200
1,200 - 1,600
1,600 - 1,900
1,900 - 2,300
2,300 - 2,600
2,600 - 2,900
2,900 - 3,400
3,400 - 3,700
3,700-4,100
4,100-4,400
4,400 - 4,800
4,800 - 5,200
5,200 - 5,600
5,600 - 5,900
5,900 - 6,200
6,200 - 6,700
6,700 - 7,000
7,000 - 7,400
Distance to
Endpoint
(miles)
0.1
0.2
0.3
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
2.2
2.4
2.6
2.8
3.0
3.2
3.4
3.6
3.8
4.0
4.2
4.4
4.6
Release
Rate/Endpoint
rabs/min)/(mg/L)] (5)
7,400 - 7,700
7,700 - 8,100
8,100 - 8,500
8,500 - 8,900
8,900 - 9,200
9,200 - 9,600
9,600 - 10,000
10,000 - 10,400
10,400-11,700
11,700-13,100
13,100 - 14,500
14,500 - 15,900
15,900 - 17,500
17,500 - 19,100
19,100 - 22,600
22,600 - 26,300
26,300 - 30,300
30,300 - 34,500
34,500 - 38,900
38,900 - 43,600
43,600 - 48,400
48,400 - 61,500
61,500-75,600
>75,600
Distance to
Endpoint
(miles)
4.8
5.0
5.2
5.4
5.6
5.8
6.0
6.2
6.8
7.5
8.1
8.7
9.3
9.9
11
12
14
15
16
17
19
22
25
>25*
* Report distance as 25 miles
Januaiy 26,1999
-------
Chapter 4
Offsite Consequence Analysis
4-31
Reference Table 3 ;
Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided by Endpoint
10-minute Release, Urban Conditions, F Stability, Wind Speed 1.5 Meters per Second
Release
Rate/Endpoint
[(lbs/min)/(mg/L)] (5)
0-21
21 - 170
170-420
420 - 760
760 - 1,400
1,400-2,100
2,100-3,100
3,100-4,200
4,200 - 6,100
6,100 - 7,800
7,800 - 9,700
9,700 - 12,000
12,000 - 14,000
14,000-18,000
18,000-22,000
22,000 - 25,000
25,000 - 29,000
29,000 - 33,000
33,000 - 39,000
39,000 - 44,000
44,000 - 49,000
49,000 - 55,000
55,000 - 63,000
63,000 - 69,000
69,000 - 76,000
Distance to
Endpoint
(miles)
0.1
0.2
0.3
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
2.2
2.4
2.6
2.8
3.0
3.2
3.4
3.6
3.8
4.0
4.2
4.4
4.6
Release
Rate/Endpoint
[(lbs/min)/(mg/L) (8)
76,000 - 83,000
83,000-90,000
90,000 - 100,000
100,000-110,000
110,000-120,000
120,000 - 130,000
130,000-140,000
140,000-148,000
148,000-183,000
183,000 - 221,000
221,000 - 264,000
264,000-310,000
310,000-361,000
361,000-415,000
415,000 - 535,000
535,000 ,-671,000
671,000-822,000
822,000-990,000
990,000-1,170,000
1,170,000:- 1,370,000
1,370,000 - 1,590,000
1,590,000;- 2,190,000
2,190,000 - 2,890,000
>2,890,000
Distance to
Endpoint
(miles)
4.8
5.0
5.2
5.4
5.6
5.8
6.0
6.2
6.8
7.5
8.1
8.7
9.3
9.9
11
12
14
15
16
17
19
22
25
>25*
* Report distance as 25 miles
January 26, 1999
-------
Chapter 4
Offsite Consequence Analysis
4-32
Reference Table 4
Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided by Endpoint
60-Minute Release, Urban Conditions, F Stability, Wind Speed 1.5 Meters per Second
Release
Rate/Endpoint
[(lbs/min)/(mg/L)] (8)
0-26
26-210
210-530
530 - 940
940 - 1,700
1,700 - 2,600
2,600 - 3,700
3,700 - 4,800
4,800 - 6,400
6,400 - 7,700
7,700 - 9,100
9,100-11,000
11,000-12,000
12,000 - 14,000
14,000 - 16,000
16,000 - 17,000
17,000 - 19,000
19,000 - 21,000
21,000 - 23,000
23,000 - 24,000
24,000 - 26,000
26,000 - 28,000
28,000 - 30,000
30,000 - 32,000
32,000 - 34,000
Distance to
Endpoint
(miles)
0.1
0.2
0.3
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
2.2
2.4
2.6
2.8
3.0
3.2
3.4
3.6
3.8
4.0
4.2
4.4
4.6
Release
Rate/Endpoint
[(lbs/min)/(mg/L)] (5)
34,000 - 36,000
36,000 - 38,000
38,000-41,000
41,000-43,000
43,000 - 45,000
45,000 - 47,000
47,000 - 50,000
50,000 - 52,200
52,200 - 60,200
60,200 - 68,900
68,900 - 78,300
78,300 - 88,400
88,400 - 99,300
99,300-111,000
111,000-137,000
137,000-165,000
165,000 - 197,000
197,000 - 232,000
232,000 - 271,000
271,000-312,000
312,000 - 357,000
357,000 - 483,000
483,000 - 629,000
>629,000
Distance to
Endpoint
(miles)
4.8
5.0
5.2
5.4
5.6
5.8
6.0
6.2
6.8
7.5
8.1
8.7
9.3
9.9
11
12
14
15
16
17
19
22
25
>25*
: Report distance as 25 miles
January 26, 1999
-------
4-33
Reference Table 5
Dense Gas Distances to Toxic Endpoint, 10-minute Release, Rural Conditions, F Stability, Wind Speed 1.5 Meters per Second
Release
Rate
(Ibs/niin)
1
2
5
10
30
50
100
150
250
500
750
1,000
1,500
2,000
2,500
3,000
4,000
5,000
7,500
10,000
15,000
20,000
50,000
75,000
100,000
150,000
200,000
Toxic Endpoint (mg/L
0.0004
0.0007
??
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11
??
11
??
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
0.001
77
7?
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??
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11
*
*
*
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*
*
*
*
*
*
*
*
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*
*
*
0.002
0.0035
7?
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*
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7?
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77
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11
77
??
??
*
*
*
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*
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*
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*
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0.0075
0.01
0.02
Distance (Miles)
0.5
0.7
??
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7?
??
??
77
??
??
??
??
77
7?
11
??
??
??
*
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0.5
0.7
1.0
7?
7?
??
7?
7?
7?
77
7?
7?
7?
7?
11
7?
7?
7?
7?
7?
*
*
*
*
*
*
*
0.3
0.4
0.7
1.0
77
77
7?
7?
11
11
7?
7?
77
77
7?
7?
7?
7?
77
77
7?
7?
7?
77
7?
7?
7?
0.035
0.2
0.3
0.5
0.7
77
77
77
7?
77
7?
7?
77
??
7?
11
11
11
11
11
11
77
7?
7?
7?
77
7?
77
0.05
0.2
0.3
0.4
0.6
??
11
11
11
11
11
11
11
11
11
??
77
77
7?
7?
7?
7?
11
11
11
11
11
11
0.075
0.1
0.2
0.2
0.3
0.5
0.9
77
7?
77
7?
77
7?
7?
77
7?
7?
??
7?
7?
7?
??
7?
77
77
7?
7?
7?
77
0.1
0.2
0.3
0.4
0.7
0.9
7?
11
n
n
n
n
11
n
77
7?
7?
7?
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77
11
11
11
11
' 11
n
n
0.25
0.1
0.1
0.2
0.2
0.4
0.6
0.8
0.9
77
77
11
11
11
7?
7?
7?
77
7?
11
11
11
11
11
11
n
n
11
0.5
7?
<0.1
0.1
0.2
0.3
0.4
0.5
0.6
0.8
77
7?
7?
7?
7?
7?
7?
??
7?
77
7?
7?
77
??
11
n
n
11
0.75
#
<0.1
0.1
0.1
0.2
0.3
0.4
0.5
0.6
0.9
1.0
77
7?
7?
11
n
11
11
11
11
7?
7?
7?
11
11
11
11
> 25 miles (report distance as 25 miles) # <0. 1 mile (report distance as 0. 1 mill
-------
Reference Table 6
Dense Gas Distances to ToxicEndpoini r.ii-m invite Release, Rural Conditions, F Stabiity, Wind Speed 1.5 Meters per Second
Release
Rate
(Ibs/niln)
1
2
5
10
30
50
100
150
250
500
750
1,000
1,500
2,000
2,500
3,000
4,000
5,000
7,500
10,000
15,000
20,000
50,000
75,000
100,000
150,000
200,000
Toxic Endpoint (niR/L
0.0004
0.0007
0.001
0.002
II null
0.005
0.0075
0.01
0.02
0.035
0.05
0.075
0.1
0.25
0.5
0.75
Distance (Miles)
77
77
77
7?
77
77
77
t
*
*
*
*
*
*
*
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#
*
#
*
*
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*
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*
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2.7
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77
??
7?
7?
7?
77
77
7?
*
*
*
*
*
*
*
*
*
*
*
*
0.3
0.5
0.9
7?
77
77
77
77
7?
7?
7?
7?
7?
7?
7?
7?
7?
77
*
*
*
*
*
*
*
*
*
0.2
0.4
0.6
1.0
77
7?
7?
7?
7?
77
77
??
7?
7?
7?
7?
7?
7?
7?
*
*
*
*
*
*
*
*
0.2
0.3
0.5
0.8
77
7?
??
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
*
*
*
*
*
*
0.1
0.2
0.4
0.6
7?
7?
7?
7?
77
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
77
7?
7?
7?
7?
7?
77
0.1
0.2
0.3
0.5
1.0
77
77
77
7?
7?
7?
7?
7?
7?
7?
77
77
7?
7?
77
77
7?
7?
7?
77
77
77
<0.1
0.1
0.2
0.3
0.5
0.7
77
7?
77
7?
77
7?
7?
7?
77
7?
7?
7?
7?
7?
7?
77
7?
7?
7?
7?
7?
7?
<01
0.1
0.2
0.3
0.4
0.7
0.9
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
77
7?
77
77
It
<0.1
0.1
0.1
0.2
0.3
0.5
0.6
0.9
77
77
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
* > 25 miles (report distance as 25 miles)
# <0.1 mile (report distance as 0.1 mile)
-------
Reference Table 7
Dense Gas Distances to Toxic Endpoint, 10-minute Release, Urban Conditions, F Stability, Wind Speed 1.5 Meters per Second
Release
Rate
(Ibs/min)
1
2
5
10
30
50
100
150
250
500
750
1,000
1,500
2,000
2,500
3,000
- 4,000
5,000
7,500
10,000
15,000
20,000
50,000
75,000
100,000
150,000
200,000
Toxic Endpoint (mg/L)
0.0004
0.0007
0.001
7?
7?
7?
7?
7?
7?
7?
??
??
7?
7?
*
*
*
*
*
*.-. .
*
*
*
*
*
*
*
*
*
*
7?
77
7?
7?
77
7?
77
77
77
77
??
*
*
*
*
*
. . , . # . _
*
*
*
*
#
*
*
*
*
*
7?
7?
77
??
77
7?
??
??
77
7?
7?
??
7?
*
*
*
# .. .
*
*
*
*
*
*
*
*
*
*
0.002
0.0035
0.005
0.0075
0.01
0.02
Distance (Miles)
0.7
7?
??
??
??
77
??
??
??
??
7?
??
??
??
??
*
. . .*
*
#
*
*
*
*
*
*
*
*
0.6
0.8
7?
77
7?
??
??
77
??
??
??
??
??
7?
??
??
77-
*
*
*
*
*
*
*
*
*
*
0.4
0.6
1.0
7?
77
77
??
??
??
7?
??
??
??
??
??
7?
.77 _
??
*
*
*
*
*
*
*
*
*
0.4
0.5
0.8
??
7?
7?
7?
??
7?
??
??
7?
??
??
??
??
- ??
??
??
*
*
*
*
*
*
#
*
0.3
0.4
0.7
1.0
??
??
??
??
??
??
??
??
??
??
??
??
77
??
??
??
??
??
??
??
??
??
??
0.2
0.3
0.5
0.7
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
77
??
??
??
??
??
0.035
0.2
0.2
0.4
0.5
0.9
??
??
??
??
??
??
??
??
7?
??
7?
7?
77
7?
7?
7?
7?
7?
77
7?
77
77
0.05
0.1
0.2
0.3
0.4
0.7
0.9
7?
7?
??
77
7?
7?
77
77
7?
77
7? •
7?
7?
7?
7?
7?
77
7?
7?
7?
7?
0.075
0.1
0.1
0.2
0.3
0.6
0.7
1.0
7?
7?
7?
7?
7?
7?
7?
7?
??
77 . .
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
0.1
0.1
0.1
0.2
0.2
0.4
0.6
0.9
7?
7?
7?
7?
7?
7?
7?
7?
77
- 7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
' >25
0.25
77
<0.1
0.1
0.1
0.2
0.3
0.5
0.6
0.7
7?
77
77
7?
7?
7?
77
•??
7?
7?
77
7?
7?
7?
7?
77
7?
7?
0.5
#
#
<0.1
0.1
0.1
0.2
0.3
0.4
0.5
0.7
0.8
0.9
7?
77
7?
7?
•??•
7?
7?
7?
7?
7?
77
7?
7?
7?
7?
0.75
#
#
#
<0.1
0.1
0.1
0.2
0.2
0.3
0.5
0.6
0.7
0.8
0.9
7?
7?
- •??• -
7?
7?
7?
7?
7?
7?
7?
7?
77
7?
* > 25 miles (report distance as 25 miles)
# <0.1 mile (report distance as 0.1 mile)
-------
4-36
Reference Table 8
Dense Gas Distances to Toxic Endpoint, 60-minute Release. Urban Conditions, F Stability, Wind Speed 1.5 Meters per Second
Release
Rate
(Ibs/mln)
1
2
5
10
30
50
100
ISO
250
500
750
1,000
1,500
2,000
2,500
3,000
4,000
5,000
7,500
10,000
15,000
20,000
50,000
75,000
100,000
150,000
200,000
0.0004
0.0007
0.001
0.002
0.0035
0.005
Toxic Endpoint (mg/L
0.0075
0.01
0.02
0.035
0.05
0.075
0.1
0.25
0.5
0.75
Distance (Miles)
??
??
??
7?
??
??
??
??
*
*
*
*
*
*
*
#
*
*
*
*
*
*
*
*
*
*
*
??
??
??
??
??
??
??
??
*
*
#
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
??
??
??
??
??
??
??
??
??
*
*
*
*
*
*
*
*
*
*
*
*
*
#
*
*
*
*
??
??
??
77
??
??
??
??
??
??
*
* -
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
0.7
??
??
??
??
??
??
??
??
??
??
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
#
0.6
0.9
??
.??
??
??
??
??
??
??
??
??
*
*
*
*
*
*
*
*
*
*
#
*
*
*
*
0.4
0.7
??
??
??
??
??
??
??
??
77
??
??
*
*
*
*
*
*
*
*
*
*
*
*
*
*
0.4
0.6
0.9
??
??
??
??
??
??
??
??
??
??
??
??
??
??
*
*
*
*
*
*
*
*
*
*
0.2
0.4
0.6
0.9
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
*
*
*
*
*
*
*
*
0.2
0.2
0.4
0.7
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
77
??
*
*
*
*
*
#
0.1
0.2
0.3
0.5
1.0
??
??
7?
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
0.1
0.1
0.2
0.4
0.7
??
??
??
??
??
??
??
??
??
??
??
??
??
??
77
??
??
??
??
??
??
??
0.1
0.1
0.2
0.3
0.6
0.9
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
<0.1
0.1
0.2
0.3
0.4
0.7
0.9
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
7?
#
#
<0.1
0.1
0.2
0.2
0.4
0.5
0.7
??
77
??
??
??
??
??
??
77
??
??
??
??
??
??
??
??
??
n
#
#
<0.1
0.1
0.2
0.3
0.3
0.5
0.7
1.0
??
??
77
??
??
??
??
??
??
??
??
??
??
??
??
7?
* > 25 miles (report distance as 25 miles)
# <0.1 mile (report distance as 0.1 mile)
-------
4-37
Chapter 4
Offsite Consequence Analysis
Reference Table 9
Distances to Toxic Endpoint for 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
*Report distance as 0.1 mile
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
*#
** More than 25 miles (report distance as 25 miles)
May 22, 2000
-------
Chapter 4
Offsite Consequence Analysis
4-38
Reference Table 10
Distances to Toxic Endpoint for Aqueous Ammonia
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
0.4
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
0.2
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
*Report distance as 0.1 mile
** More than 25 miles (report distance as 25 miles)
May 22,2000
-------
4-39
Chapter 4
Offsite Consequence Analysis
Reference Table 11
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/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
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
*
* More than 25 miles (report distance as 25 miles)
May 22, 2000
-------
Chapter 4
Offsite Consequence Analysis
4-40
Reference Table 12
Distances to Toxic Endpoint for Anhydrous Sulfur Diioxide
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)
May 22,2000
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
*
-------
4-41
Chapter 4
Offsite Consequence Analysis
Reference Table 13
Distance to Overpressure of 1.0 psi for Vapor Cloud Explosions of 500 - 2,000,000 Pounds of Regulated Flammable Substances Based on
TNT Equivalent Method, 10 Percent Yield Factor
Quantity in Cloud (pounds)
CAS No.
75-07-0
74-86-2
598-73-2
106-99-0
106-97-8
25167-67-3
590-18-1
624-64-6
106-98-9
107-01-7
463-58-1
7791-21-1
590-21-6
557-98-2
460-19-5
75-19-4
4109-96-0
75-37-6
124-40-3
463-82-1
Chemical Name
Acetaldehydc
Acetylene
Bromotrifluoroethylene
1,3-Butadiene
Butane
Butene
2-Butene-cis
2-Butene-trans
1 -Butene
2-Butene
Carbon oxysulfide
Chlorine monoxide
1-Chloropropylene
2-Chloropropylene
Cyanogen
Cyclopropane
Dichlorosilane
Difluoroethane
Dimethylamine
2.2-DimethvlDrooane
500
2,000
5,000
10,000
20,000
50,000
100,000
200,000
500,000
1,000,000
2,000,000
Distance (Miles) to 1 psi Overpressure
0.05
0.07
0.02
0.06
0.06
0.06
0.06
0.06
0.06
0.06
0.04
0.02
0.05
0.05
0.05
0.06
0.04
0.04
0.06
0.06
0.08
O.I
0.04
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.06
0.03
0.08
0.08
0.08
0.1
0.06
0.06
0.09
0.1
O.I
0.1
0.05
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.08
0.04
0.1
0.1
0.1
0.1
0.08
0.09
0.1
0.1
0.1
0.2
0.06
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.1
0.05
0.1
0.1
0.1
0.2
0.1
0.1
0.2
0.2
0.2
0.2
0.08
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.1
0.06
0.2
0.2
0.2
0.2
0.1
0.1
0.2
0.2
0.2
0.3
0.1
0.3
0.3
0.3
0.3
0.3
0.3
0.3
0.2
0.08
0.2
0.2
0.2
0.3
0.2
0.2
0.3
0.3
0.3
0.4
0.1
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.2
0.1
0.3
0.3
0.3
0.4
0.2
0.2
0.3
0.4
0.4
0.5
0.2
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.3
0.1
0.4
0.4
0.4
0.5
0.3
0.3
0.4
0.5
0.5
0.7
0.2
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.4
0.2
0.5
0.5
0.5
0.6
0.4
0.4
0.6
0.6
0.7
0.8
0.3
0.8
0.8
0.8
0.8
0.8
0.8
0.8
0.5
0.2
0.6
0.6
0.6
0.8
0.5
0.5
0.7
0.8
0.8
1.0
0.4
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.6
0.3
0.8
0.8
0.8
1.0
0.6
0.6
0.9
1.0
May 22,2000
-------
Chapter 4
Oflsite Consequence Analysis
4-42
Quantity In Cloud (pounds)
CAS No.
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
115-11-7
504-60-9
109-66-0
109-67-1
Chemical Name
Ethane
Ethyl acetylene
Ethylamine
Ethyl chloride
Ethylene
Ethyl ether
Ethyl mercaptan
Ethyl nitrite
Hydrogen
Isobutane
Isopentane
Isoprene
Isopropylamine
Isopropyl chloride
Methane
Methylamine
3-Methyl-l-butene
2-Methyl-l-butene
Methyl ether
Methyl formate
2-Methylpropene
1,3-Pentadiene
Pentane
1-Pentene
500
0.06
0.06
0.06
0.05
0.06
0.06
0.05
0.05
0.09
0.06
0.06
0.06
0.06
0.05
0.07
0.06
0.06
0.06
0.05
0.04
0.06
0.06
0.06
0.06
2,000
5,000
10,000
0.1
0.1
0.09
0.08
0.1
0.09
0.09
0.07
0.1
0.1
0.1
0.1
0.09
0.08
0.1
0.09
0.1
0.1
0.09
0.07
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.2
O.I
0.1
0.1
0.1
0.1
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
0.1
0.2
0.2
0.2
0.1
0.2
0.2
0.2
0.2
0.2
0.1
0.2
0.2
0.2
0.2
0.1
0.1
0.2
0.2
0.2
0.2
20,000
50,000
100,000
200,000
Distance (Miles) to 1 psi Overpressure
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.3
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0,3
0.3
0.3
0.2
0.3
0.3
0.2
0.2
0.4
0.3
0.3
0.3
0.3
0.2
0.3
0.3
0.3
0.3
0.3
0.2
0.3
0.3
0.3
0.3
0.4
0.4
0.3
0.3
0.4
0.3
0.3
0.3
0.5
0.4
0.4
0.4
0.3
0.3
0.4
0.3
0.4
0.4
0.3
0.3
0.4
0.4
0.4
0.4
0.5
0.5
0.4
0.4
0.5
0.4
0.4
0.3
0.6
0.5
0.5
0.5
0.4
0.4
0.5
0.4
0.5
0.5
0.4
0.3
0.5
. 0.5
0.5
0.5
500,000
1,000,000
0.6
0.6
0.6
0.5
0.7
0.6
0.5
0.5
0.9
0.6
0.6
0.6
0.6
0.5
0.7
0.6
0.6
0.6
0.5
0.4
0.6
0.6
0.6
0.6
0.8
0.8
0.7
0.6
0.8
0.7
0.7
0.6
1.1
0.8
0.8
0.8
0.7
0.6
0.8
0.7
0.8
0.8
0.7
0.6
0.8
0.8
0.8
0.8
2,000,000
1.0
1.0
0.9
0.8
1.0
0.9
0.9
0.7
1.4
1.0
1.0
1.0
0.9
0.8
1.0
0.9
1.0
1.0
0.9
0.7
1.0
1.0
1.0
1.0
May 22, 2000
-------
4-43
Chapter 4
Offsite Consequence Analysis
Quantity in Cloud (pounds)
CAS No.
646-04-8
627-20-3
463-49-0
74-98-6
115-07-1
74-99-7
7803-62-5
116-14-3
75-76-3
10025-78-2
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
Chemical Name
2-Pentene, (E)-
2-Pentene, (Z)-
Propadiene
Propane
Propylene
Silane
Tetrafluoroethylene
Tetramethylsilane
Trichlorosilane
Trifluorochloroethylene
Trimethylamine
Vinyl acetylene
Vinyl chloride
Vinyl ethyl ether
Vinyl fluoride
Vinylidene chloride
Vinylidene fluoride
Vinyl methyl ether
500
2,000
5,000
10,000
20,000
50,000
100,000
200,000
500,000
1,000,000
2,000,000
Distance (Miles) to 1 psi Overpressure
0.06
0.06
0.06
0.06
0.06
0.06
0.06
0.02
0.06
0.03
0.02
0.06
0.06
0.05
0.06
0.02
0.04
0.04
0.06
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.03
0.1
0.04
0.03
0.1
0.1
0.08
0.09
0.04
0.06
0.06
0.09
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.04
0.1
0.06
0.05
0.1
0.1
0.1
0.1
0.05
0.08
0.09
0.1
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.05
0.2
0.08
0.06
0.2
0.2
0.1
0.2
0.06
0.1
0.1
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.07
0.2
0.1
0.07
0.2
0.2
0.2
0.2
0.08
0.1
0.1
0.2
0.3
0.3
0.3
0.3
0.3
0.3
0.3
0.09
0.3
0.1
0.1
0.3
0.3
0.2
0.3
0.1
0.2
0.2
0.3
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.1
0.4
0.2
0.1
0.4
0.4
0.3
0.3
0.1
0.2
0.2
0.3
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.1
0.5
0.2
0.2
0.4
0.5
0.4
0.4
0.2
0.3
0.3
0.4
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.2
0.6
0.3
0.2
0.6
0.6
0.5
0.6
0.2
0.4
0.4
0.6
0.8
0.8
0.8
0.8
0.8
0.8
0.8
0.2
0.8
0.4
0.3
0.8
0.8
0.6
0.7
0.3
0.5
0.5
0.7
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.3
1.0
0.4
0.3
1.0
1.0
0.8
0.9
0.4
0.6
0.6
0.9
May 22,2000
-------
Chapter 4
Offeite Consequence Analysis
4-44
Reference Table 14
Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Raite Divided by Endpoint
10-Minute Release, Rural Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release Rate/Endpoint
[(lbs/min)/(mg/L)] (8)
0-64
64-510
510 - 1,300
1,300-2,300
2,300-4,100
4,100 - 6,300
6,300 - 8,800
8,800 - 12,000
12,000-16,000
16,000-19,000
19,000-22,000
22,000 - 26,000
26,000-30,000
30,000 - 36,000
36,000-42,000
42,000 - 47,000
47,000 - 54,000
54,000 - 60,000
60,000 - 70,000
70,000 - 78,000
78,000 - 87,000
87,000 - 97,000
97,000-110,000
110,000-120,000
120,000 - 130,000
Distance to
Endpoint
(miles)
0.1
0.2
0.3
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
2.2
2.4
2.6
2.8
3.0
3.2
3.4
3.6
3.8
4.0
4.2
4.4
4.6
Release Rate/Endpoint
[(lbs/min)/(mg/L)]
(8)
130,000 - 140,000
140,000 - 160,000
160,000 - 180,000
180,000 - 190,000
190,000-210,000
210,000 - 220,000
220,000 - 240,000
240,000 - 261,000
261,000 - 325,000
325,000 - 397,000
397,000-477,000
477,000 - 566,000
566,000 - 663,000
663,000 - 769,000
769,000 - 1,010,000
1,010,000 - 1,280,000
1,280,000 - 1,600,000
1,600,000 - 1,950,000
1,950,000 - 2,340,000
2,340,000 - 2,770,000
2,770,000 - 3,240,000
3,240,000 - 4,590,000
4,590,000 - 6,190,000
>6,190,000
Distance to
Endpoint
(miles)
4.8
5.0
5.2
5.4
5.6
5.8
6.0
6.2
6.8
7.5
8.1
8.7
9.3
9.9
11
12
14
15
16
17
19
22
25
>25*
: Report distance as 25 miles
May 22,2000
-------
4-45
Chapter 4
Offsite Consequence Analysis
Reference Table 15
Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided by Endpoint
60-Minute Release, Rural Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release Rate/Endpoint
[(lbs/min)/(mg/L)]
(8)
0-79
79 - 630
630 - 1,600
1,600 - 2,800
2,800-5,200
5,200 - 7,900
7,900-11,000
11,000-14,000
14,000 - 19,000
19,000 - 23,000
23,000 - 27,000
27,000 - 32,000
32,000 - 36,000
36,000 - 42,000
42,000 - 47,000
47,000 - 52,000
52,000 - 57,000
57,000-61,000
61,000-68,000
68,000 - 73,000
73,000 - 79,000
79,000 - 84,000
84,000 - 91,000
91,000 - 97,000
97,000 - 100,000
Distance to
Endpoint
(miles)
0.1
0.2
0.3
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
2.2
2.4
2.6
2.8
3.0
3.2
3.4
3.6
3.8
4.0
4.2
4.4
4.6
Release Rate/Endpoint
[01>s/min)/(mg/L)]
(8)
100,000;- 108,000
108,000-113,000
113,000-120,000
120,000 - 126,000
126,000 - 132,000
132,000 - 140,000
140,000 - 150,000
150,000-151,000
151,000 - 171,000
171,000 - 191,000
191,000-212,000
212,000-233,000
233,000 - 256,000
256,000 - 280,000
280,000 - 332,000
332,000-390,000
390,000 - 456,000
456,000-529,000
529,000 - 610,000
610,000-699,000
699,000 - 796,000
796,000 - 1,080,000
1,080,000 - 1,410,000
>1,410,000
Distance to
Endpoint
(miles)
4.8
5.0
5.2
5.4
5.6
5.8
6.0
6.2
6.8
7.5
8.1
8.7
9.3
9.9
11
12
14
15
16
17
19
22
25
>25*
Report distance as 25 miles
May 22, 2000
-------
Chapter 4
Offsite Consequence Analysis
4-46
Reference Table 16
Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided by Endpoint
10-Minute Release, Urban Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release Rate/Endpoint
[(lbs/min)/(mg/L)]
(6)
0-160
160 - 1,400
1,400-3,600
3,600 - 6,900
6,900 - 13,000
13,000-22,000
22,000-31,000
31,000-42,000
42,000 - 59,000
59,000 - 73,000
73,000 - 88,000
88,000 - 100,000
100,000 - 120,000
120,000 - 150,000
150,000 - 170,000
170,000 - 200,000
200,000 - 230,000
230,000-260,000
260,000-310,000
310,000-340,000
340,000-390,000
390,000-430,000
430,000-490,000
490,000 - 540,000
540,000 - 600,000
Distance to
Endpoint
(miles)
0.1
0.2
0.3
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
2.2
2.4
2.6
2.8
3.0
3.2
3.4
3.6
3.8
4.0
4.2
4.4
4.6
Release Rate/Endpoint
[(lbs/min)/(mg/L)l
(6)
600,000 - 660,000
660,000 - 720,000
720,000-810,000
810,000 - 880,000
880,000 - 950,000
950,000 - 1,000,000
1,000,000 - 1,100,000
1,100,000 - 1,220,000
1,220,000 - 1,530,000
1,530,000 - 1,880,000
1,880,000 - 2,280,000
2,280,000-2,710,000
2,710,000 - 3,200,000
3,200,000 - 3,730,000
3,730,000 - 4,920,000
4,920,000-6,310,000
6,310,000-7,890,000
7,890,000 - 9,660,000
9,660,000-11,600,000
11,600,000-13,800,000
13,800,000-16,200,000
16,200,000-23,100,000
23,100,000-31,300,000
>3 1,300,000
Distance to
Endpoint
(miles)
4.8
5.0
5.2
5.4
5.6
5.8
6.0
6.2
6.8
7.5
8.1
8.7
9.3
9.9
11
12
14
15
16
17
19
22
25
>25*
* Report distance as 25 miles
May 22,2000
-------
4-47
Chapter 4
OfFsite Consequence Analysis
Reference Table 17
Neutrally Buoyant Plume Distances to Toxic Endpoint for Release Rate Divided by Endpoint
60-Minute Release, Urban Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release Rate/Endpoint
[(lbs/min)/(mg/L)]
(8)
0-200
200 - 1,700
1,700-4,500
4,500 - 8,600
8,600 - 17,000
17,000 - 27,000
27,000 - 39,000
39,000-53,000
53,000 - 73,000
73,000 - 90,000
90,000-110,000
110,000-130,000
130,000 - 150,000
150,000 - 170,000
170,000 - 200,000
200,000 - 220,000
220,000 - 240,000
240,000 - 270,000
270,000 - 300,000
300,000 - 320,000
320,000 - 350,000
350,000 - 370,000
370,000-410,000
410,000-430,000
430,000-460,000
Distance to
Endpoint
(miles)
0.1
0.2
0.3
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
2.2
2.4
2.6
2.8
3.0
3.2
3.4
3.6
3.8
4.0
4.2
4.4
4.6
Release Rate/Endpoint
[Ofos/min)/(mg/L)]
(6)
460,000 - 490,000
490,000 - 520,000
520,000 - 550,000
550,000 - 580,000
580,000 - 610,000
610,000 - 640,000
640,000'- 680,000
680,000 - 705,000
705,000 - 804,000
804,000 - 905,000
905,000 - 1,010,000
1,010,000-1,120,000
1,120,000 - 1,230,000
1,230,000 - 1,350,000
1,350,000 - 1,620,000
1,620,000 - 1,920,000
1,920,000 - 2,250,000
2,250,000 - 2,620,000
2,620,000; -3,030,000
3,030,000 - 3,490,000
3,490,000 - 3,980,000
3,980,000 - 5,410,000
5,410,000-7,120,000
>7,120,000
Distance to
Endpoint
(miles)
4.8
5.0
5.2
5.4
5.6
5.8
6.0
6.2
6.8
7.5
8.1
8.7
9.3
9.9
11
12
14
15
16
17
19
22
25
>25*
: Report distance as 25 miles
May 22, 2000
-------
Reference Table 18
Dense Gas Distances to Toxic EndpoitU. 10-ininutc Release, Rural Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release
Rale
(Ibs/mln)
1
2
5
10
30
50
100
150
250
500
750
1,000
1,500
2,000
2,500
3,000
4,000
5,000
7,500
10,000
15,000
20,000
50,000
75,000
100,000
150,000
200,000
Toxic Kndpoint (mg/L.)
0.0004
0.0007
0.001
0.002
(UHU5
0.005
0.0075
0.01
0.02
0.035
0.05
0.075
0.1
0.25
0.5
0.75
Distance (Miles)
0.6
0.9
7?
7?
7?
??
7?
??
7?
7?
??
??
??
7?
??
#
*
#
*
*
*
*
*
*
*
*
*
0.4
0.6
7?
7?
7?
77
'??
77
77
7?
77
??
??
??
??
*
*
*
»
*
*
*
*
*
#
*
*
0.4
0.5
0.9
7?
7?
77
77
•»
77
??
??
??
7?
??
??
??
??
*
*
*
*
*
*
*
*
#
*
0.2
0.4
0.6
0.9
??
•>•>
•>')
•>•>
77
77
??
??
7?
77
7?
77
??
77
??
*
*
*
*
*
*
#
*
0.2
0,3
0.4
0.6
??
?''
•>•>
•>•)
•)•>
•)•>
7?
77
7?
7?
7?
7?
7?
77
7?
??
*
*
*
*
*
*
*
O.I
0.2
0.4
0.5
0.9
77
77
77
77
77
77
77
??
77
??
7?
??
7?
??
??
7?
*
*
*
*
*
*
0.1
0.2
0.3
0.4
0.7
1.0
77
??
77
77
7?
??
??
77
7?
7?
7?
7?
7?
??
??
77
7?
??
77
7?
7?
0.1
0.1
0.2
0.4
0.7
0.9
77
??
7?
77
7?
7?
7?
7?
??
??
77
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
<0.1
0.1
0.2
0.2
0.5
0.6
0.9
7?
??
7?
??
7?
7?
7?
7?
??
77
??
77
77
7?
??
??
7?
??
7?
7?
<0.1
0.1
0.1
0.2
0.3
0.4
0.6
0.8
77
7?
??
??
7?
7?
7?
7?
7?
7?
77
77
??
7?
7?
7?
7?
77
7?
??
<0.1
0.1
0.1
0.3
0.4
0.6
0.7
0.9
??
7?
7?
77
7?
7?
77
7?
7?
77
??
7?
7?
77
7?
7?
7?
7?
n
<0.1
0.1
0.1
0.2
0.3
0.4
0.6
0.7
77
77
??
- 77
77
77
77
7?
??
??
7?
7?
7?
??
??
??
7?
7?
#
#
<0.1
0.1
0.2
0.2
0.4
0.5
0.5
0.9
7?
7?
7?
7?
7?
7?
7?
7?
77
7?
7?
7?
7?
7?
7?
7?
77
#
#
#
<0.1
0.1
0.2
0.2
0.3
0.4
0.6
0.7
0.8
1.0
7?
7?
77
77
7?
7?
??'
77
7?
7?
7?
77
77
77
ft
#
1t
<0.1
0.1
0.1
0.2
0.2
0.3
0.4
0.5
0.6
0.7
0.8
0.9
1.0
7?
7?
??
77
??
7?
77
77
77
77
7?
#
ff
#
#
<0.1
0.1
0.1
0.2
0.2
0.3
0.4
0.4
0.6
0.6
0.7
0.8
0.9
7?
7?
7?
??
??
77
7?
77
??
7?
* > 25 miles (report distance as 25 miles)
# <0.1 mile (report distance as 0.1 mile)
-------
Reference Table 19
Dense Gas Distances to Toxic Endpoint, 60-minute Release, Rural Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release
Rate
(Ibs/min)
1
2
5
10
30
50
100
150
250
500
750
1,000
1,500
2,000,
2,500
3,000
4,000
5,000
7,500
10,000
15,000
20,000
50,000
75,000
100,000
150,000
200,000
Toxic Endpoint (mg/L)
0.0004
0.0007
0.001
0.002
0.0035
0.005
0.0075
0.01
0.02
0.035
0.05
0.075
0.1
0.25
0.5
0.75
Distance (Miles)
0.5
0.8
7?
??
??
77
77
7?
7?
7?
7?
7?
*
*
*
*
*
*
*
*
#
*
*
*
*
*
*
0.4
0.6
1.0
7?
7?
??
7?
7?
7?
77
7?
??
*
*
*
*
*
*
*
*
#
*
*
*
#
*
*
0.3
0.5
0.8
??
77
77
7?
7?
77
7?
7?
7?
??
77
*
*
*
*
*
*
*
*
*
#
*
*
*
0.2
0.3
0.5
0.8
??
??
??
??
??
7?
77
77
??
7?
??
7?
*
" #
*
*
*
*
*
*
*
*
*
0.2
0.2
0.4
0.6
7?
7?
??
??
??
7?
??
7?
??
??
??
7?
??
7?
*
*
*
*
*
*
*
*
*
0.1
0.2
0.3
0.5
0.9
7?
??
??
??
77
7?
7?
??
??
??
??
77
7?
77
*
*
*
*
*
*
*
*
0.1
0.2
0.2
0.4
0.7
1.0
??
7?
7?
7?
7?
??
??
??
??
??
??
V?
??
??
*
*
*
*
*
*
*
0.1
0.1
0.2
0.3
0.6
0.8
??
??
??
??
7?
7?
77
??
7?
7?
7?
77
7?
7?
7?
77
7?
77
7?
7?
7?
<0.1
0.1
0.2
0.2
0.4
0.6
0.8
7?
7?
7?
7?
7?
77
7?
77
7?
77
77
7?
7?
7?
7?
7?
7?
7?
7?
??
#
<0.1
0.1
0.2
0.3
0.4
0.6
0.7
7?
7?
??
7?
77
77
7?
7?
7?
7?
7?
7?
7?
??
??
77
7?
7?
7?
#
<0.1
0.1
0.1
0.2
0.3
0.5
0.6
0.9
7?
7?
7?
7?
7?
77
7?
77
77
7?
7?
77
7?
7?
7?
77
7?
7?
#
77
0.1
0.1
0.2
0.3
0.4
0.5
0.7
1.0
7?
7?
77
7?
7?
7?
7?
77
7?
7?
7?
7?
7?
77
7?
77
77
#
#
<0.1
0.1
0.2
0.2
0.3
0.4
0.6
0.9
77
7?
77
77
7?
??
7?
7?
7?
7?
7?
7?
77
7?
7?
7?
77
#
#
#
<0.1
0.1
0.1
0.2
0.3
0.4
0.5
0.6
0.7
1.0
77
7?
7?
77
77
7?
7?
77
7?
7?
7?
7?
77
7?
#
#
#
<0.1
0.1
. 0.1
0.1
0.2
0.2
0.4
0.4
0.5
0.7
0.7
0.9
1.0
7?
7?
7?
7?
77
7?
7?
77
7?
7?
7?
#
#
#
#
<0.1
0.1
0.1
0.1
0.2
0.3
0.4
0.4
0.5
0.6
0.7
0.8
0.9
77
7?
77
7?
77
7?
7?
7?
7?
7?
> 25 miles (report distance as 25 miles) #
-------
Reference Table 20
Dense Gas Distances to Toxic Endpoint. IP-minute Release, Urban Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release
Rate
(Ibs/mfn)
1
2
5
10
30
50
100
150
250
500
750
1,000
1,500
2,000
2,500
3,000
4,000
5,000
7,500
10,000
15,000
20,000
50,000
75,000
100,000
150,000
200,000
Toxic Endpoint (mg/L)
0.0004
0.0007
0.001
0.002
0.0035
0.005
0.0075
0.01
0.02
0.035
0.05
0.075
0.1
0.25
0.5
0.75
Distance (Miles)
0.5
0.7
7?
7?
7?
7?
??
7?
7?
7?
??
7?
??
??
77
??
>c
*
*
*
*
*
*
*
s
*
*
0.3
0.5
0.8
7?
7?
??
7?
77
??
??
??
??
??
??
77
??
*
*
*
*
*
*
*
*
*
*
*
0.2
0.4
0.6
1.0
7?
7?
77
??
7?
??
??
??
7?
??
??
??
??
??
*
*
*
*
*
*
*
*
*
0.2
0.3
0.5
0.7
??
7?
??
77
??
??
??
??
??
??
??
??
??
??
77
??
*
*
*
*
*
*
*
0.1
0.2
0.3
0.5
0.9
??
7?
77
77
77
??
77
7?
7?
7?
77
7?
7?
77
7?
77
*
*
*
*
*
*
O.I
0.2
0.3
0.4
0.8
1.0
7?
7?
7?
??
7?
7?
7?
??
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
7?
0.1
0.1
0.2
0.3
0.6
0.8
7?
77
7?
77
7?
77
77
7?
7?
??
77
77
7?
77
7?
??
??
7?
77
7?
77
0.1
0.1
0.2
0.3
0.6
0.7
1.0
7?
7?
??
7?
??
??
7?
7?
7?
7?
77
7?
7?
7?
7?
7?
??
77
7?
77
<0.1
0.1
0.1
0.2
0.4
0.5
0.7
0.9
??
??
7?
7?
7?
7?
77
7?
7?
77
??
7?
77
7?
7?
7?
7?
7?
7?
a
<0.1
0.1
0.1
0.3
0.3
0.6
0.7
0.9
7?
7?
77
7?
7?
77
7?
7?
??
7?
7?
7?
7?
7?
7?
7?
7?
77
#
<0.1
0.1
0.1
0.2
0.3
0.4
0.6
0.7
1.0
7?
77
77
77
??
77
??
7?
7?
7?
7?
??
??
77
7?
7?
7?
it
it
<0.1
0.1
0.2
0.2
0.4
0.4
0.6
0.8
1.0
7?
7?
7?
??
77
77
7?
7?
7?
7?
77
7?
7?
7?
7?
7?
ti
it
<0.1
0.1
0.1
0.2
0.3
0.4
0.5
0.7
0.9
1.0
7?
??
??
7?
7?
7?
7?
7?
7?
??
7?
7?
77
7?
77
tt
ft
1f
<0.1
0.1
0.1
0.2
0.2
0.3
0.4
0.5
0.6
0.7
0.9
1.0
7?
7?
??
7?
??
77
7?
7?
??
7?
7?
77
n
it
#
#
<0.1
0.1
0.1
0.2
0.2
0.3
0.4
0.4
0.5
0.6
0.7
0.7
0.9
0.9
7?
. ??
7?
??
7?
7?
??
7?
7?
#
#
it
tt
#
<0.1
0.1
0.1
0.1
0.2
0.3
0.3
0.4
0.5
0.6
0.6
0.7
0.7
0.9
7?
77
77
??
77
77
7?
7?
> 25 miles (report distance as 25 miles) # <0-1 mile (report distance as 0.1 mils
-------
Dense Gas Distances to Toxic Endpoint, 60-minute Release, Urban Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release
Rate
(Ibs/min)
1
2
5
10
30
50
100
150
250
500
750
1,000
1,500
2,000
2,500
3,000
4,000
5,000
7,500
10,000
15,000
20,000
50,000
75,000
100,000
150,000
200,000
Toxic Endpoint (mg/L)
0.0004
0.0007
0.001
0.002
0.0035
0.005
0.0075
0.01
0.02
0.035
0.05
0.075
0.1
0.25
0.5
0.75
Distance (Miles)
0.4
0.7
??
??
??
??
??
??
??
??
??
??
??
*
*
*
*
*
*
*
*
*
*
*
*
*
*
0.3
0.5
0.8
??
??
??
??
??
??
??
??
??
??
*
*
*
*
#
*
*
*
*
*
*
*
*
*
0.2
0.4
0.7
1.0
??
??
??
??
??
??
??
??
??
??
??
*
*
*
*
*
*
*
*
*
*
*
*
0.2
0.2
0.4 .
0.7
77
??
??
??
??
??
??
??
??
??
??
??
??
*
*
*
*
*
*
*
*
*
*
0.1
0.2
0.3
0.5
0.9
??
??
77
??
??
77
??
??
??
??
??
V?
??
*
*
*
*
*
*
*
*
*
0.1
0.2
0.2
0.4
0.7
1.0
??
??
??
??
??
??
??
??
??
??
??
??
??
??
*
*
*
*
*
*
*
0.1
0.1
0.2
0.3
0.6
0.8
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
*
*
*
*
*
*
<0.1
0.1
0.2
0.3
0.5
0.7
1.0
??
77
??
??
??
??
7?
??
??
??
??
V?
??
??
??
??
??
??
??
??
#
<0.1
0.1
0.2
0.3
0.4
0.7
0.9
??
??
??
??
??
??
??
??
V?
??
??
??
??
??
??
??
??
??
??
#
<0.1
0.1
0.1
0.2
0.3
0.5
0.6
0.8
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
#
#
<0.1
0.1
0.2
0.3
0.4
0.5
0.7
1.0
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
#
#
<0.1
0.1
0.2
0.2
0.3
0.4
0.5
0.8
1.0
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
#
#
<0.1
0.1
0.1
0.2
0.3
0.3
0.4
0.7
0.9
1.0
??
??
??
??
??
??
??
??
??
??
??
??
??
??
??
#
#
#
<0.1
0.1
0.1
0.2
0.2
0.3
0.4
0.5
0.6
0.7
0.9
1.0
??
??
??
77
??
??
??
??
??
??
??
??
#
#
#
#
<0.1
0.1
0.1
0.1
0.2
0.2
0.3
0.4
0.5
0.6
0.6
0.7
0.9
1.0
??
??
??
??
??
??
??
77
V?
#
#
#
#
#
0.1
0.1
0.1
0.1
0.2
0.3
0.3
0.4
0.4
0.5
0.6
0.7
0.7
0.9
??
77
??
77
??
??
77
??
> 25 miles (report distance as 25 miles)
# <0.1 mile (report distance as 0.1 mile)
-------
Chapter 4
OfFsite Consequence Analysis
4-52
Reference Table 22
Distances to Toxic Endpoint for Anhydrous Ammonia
D Stability, Wind Speed 3.0 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
Obs/min)
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
* Report distance as 0.1 mile
May 22,2000
-------
4-53
Chapter 4
Offsite Consequence Analysis
Reference Table 23
Distances to Toxic Endpoint for Aqueous Ammonia
D Stability, Wind Speed 3.0 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
: Report distance as 0.1 mile
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
May 22, 2000
-------
Chapter 4
Offsite Consequence Analysis
4-54
Reference Table 24
Distances to Toxic Endpoint for Chlorine
D Stability, Wind Speed 3.0 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
' Report distance as 0.1 mile
May 22,2000
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
-------
4-55
Chapter 4
Offsite Consequence Analysis
Reference Table 25
Distances to Toxic Endpoint for Sulfur Dioxide
D Stability, Wind Speed 3.0 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/mm)
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
* Report distance as 0.1 mile
May 22, 2000
-------
Chapter 4
Qffsite Consequence Analysis
4-56
Reference Table 26
Neutrally Buoyant Plume Distances to Lower Flammability Limit (LFL)
For Release Rate Divided by LFL
Rural Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release Rate/Endpoint
[(lbs/min)/(mg/L)]
0-28
28-40
40-60
60-220
220 - 530
530 - 860
860 - 1,300
1,300 - 1,700
1,700 - 2,200
2,200 - 2,700
Distance to
Endpoint
(miles)
0.1
0.1
0.1
0.2
0.3
0.4
0.5
0.6
0.7
0.8
Release Rate/Endpoint
[(Ibs/min)/(mg/L)]
2,700 - 3,300
3,300 - 3,900
3,900 - 4,500
4,500 - 5,200
5,200 - 5,800
5,800 - 6,800
6,800 - 8,200
8,200 - 9,700
9,700-11,000
11,000-13,000
Distance to
Endpoint
(miles)
0.9
1.0
1.1
1.2
1.3
1.4
1.6
1.8
2.0
2.2
Reference Table 27
Neutrally Buoyant Plume Distances to Lower Flammability Limit (LFL)
For Release Rate Divided by LFL
Urban Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release Rate/Endpoint
[Obs/min)/(mg/L)]
0-68
68 - 100
100-150
150-710
710 - 1,500
1,500 - 2,600
2,600-4,000
4,000 - 5,500
Distance to
Endpoint
(miles)
0.1
0.1
0.1
0.2
0.3
0.4
0.5
0.6
Release Rate/Endpoint
[(lbs/min)/(mg/L)]
5,500 - 7,300
7,300 - 9,200
9,200-11,000
11,000-14,000
14,000-18,000
18,000 - 26,000
26,000 - 31,000
31,000-38,000
Distance to
Endpoint
(miles)
0.7
0.8
0.9
1.0
1.2
1.4
1.6
1.8
May 22,2000
-------
4-57
Chapter 4
Offsite Consequence Analysis
Reference Table 28
Dense Gas Distances to Lower Flammability Limit
Rural Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release
Rate
(Ibs min)
<1,500
1,500
2,000
2,500
3,000
4,000
5,000
7,500
10,000
27
??
<().!
0.1
0.1
0.1
0.1
0.1
0.2
0.2
30
ft
<().!
0.1
0.1
0.1
0.1
0.1
0.1
0.2
Lower Flammability Limit (mg/L)
35
it
//
<0.1
0.1
0.1
0.1
0.1
0.1
0.1
40
45
50
60
70
100
Distance (Miles)
//
n
#
<0.1
0.1
0.1
0.1
0.1
0.1
tt
n '
#
#
<0.1
0.1
0.1
0.1
0.1
#
#
#
#
<0.1
0.1
0.1
0.1
0.1
#
#
#
#
#
<0.1
0.1
0.1
0.1
#
#
#
#
#
#
<0.1
0.1
0.1
#
#
#
#
#
#
#
<0.1
0.1
>100
#
#
#
#
#
#
#
#
<0.1
# < 0.1 mile (report distance a 0.1 mile)
May 22,2000
-------
Chapter 4
Offsite Consequence Analysis
4-58
Reference Table 29
Dense Gas Distances to Lower Flammability Limit
Urban Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release
Rate
(Ibs/min)
<5,000
5,000
7,500
10,000
Lower Flammability Limit (mg/L)
27
30
35
40
>40
Distance (Miles)
??
<0.1
0.1
0.1
#
<0.1
0.1
0.1
#
#
<0.1
0.1
#
#
#
<0.1
#
#
#
#
# < 0.1 mile (report distance as 0.1 mile)
May 22,2000
-------
4-59
Chapter 4
Offsite Consequence Analysis
Exhibit B-l
Data for Toxic Gases
CAS
Number
7664-41-7
7784-42-1
10294-34-5
7637-07-2
7782-50-5
10049-04-4
506-77-4
19287-45-7
75-21-8
7782-41-4
50-00-0
74-90-8
7647-01-0
7664-39-3
7783-07-5
7783-06-4
74-87-3
74-93-1
10102-43-9
Chemical Name
Ammonia (anhydrous)0
Arsine
Boron trichloride
Boron trifluoride
Chlorine
Chlorine dioxide
Cyanogen chloride
Diborane
Ethylene oxide
Fluorine
Formaldehyde (anhydrous)0
Hydrocyanic acid
Hydrogen chloride
(anhydrous)0
Hydrogen fluoride
(anhydrous)0
Hydrogen selenide
Hydrogen sulfide
Methyl chloride
Methyl mercaptan
Nitric oxide
Molecular
Weight
17.03
77.95
117.17
67.81
70.91
67.45
61.47
27.67
44.05
38.00
30.03
27.03
36.46
20.01
80.98
34.08
50.49
48.11
30.01
Ratio of
Specific
Heats
1.31
1.28
1.15
1.20
1.32
1.25
1.22
1.17
1.21
1.36
1.31
1.30
1.40
1.40
1.32
1.32
1.26
1.20
1.38
Toxic Endpoint"
mg/L
0.14
0.0019
0.010
0.028
0.0087
0.0028
0.030
0.0011
0.090
0.0039
0.012
0.011
0.030
0.016
0.00066
0.042
0.82
0.049
0.031
ppm
200
0.6
2
10
3
1
12
1
50
2.5
10
10
20
20
0.2
30
400
25
25
Basis
ERPG-2
EHS-LOC(IDLH)
EHS-LOC (Toxc)
EHS-LOC (IDLH)
ERPG-2
EHS-LOC
equivalent (IDLH)8
EHS-LOC
equivalent (Tox)h
ERPG-2
ERPG-2
EHS-LOC (IDLH)
ERPG-2
ERPG-2
ERPG-2
ERPG-2
EHS-LOC (IDLH)
ERPG-2
ERPG-2
ERPG-2
EHS-LOC (TLV>)
Liquid Factor
Boiling
(LFB)
0.073
0.23
0.22
0.25
0.19
0.15
0.14
0.13
0.12
0.35
0.10
0.079
0.15
0.066
0.21
0.13
0.14
0.12
0.21
Density
Factor (DF)
(Boiling)
0.71
0.30
0.36
0.31
0.31
0.30
0.41
1.13
0.55
0.32
0.59
0.72
0.41
0.51
0.25
0.51
0.48
0.55
0.38
Gas
Factor
(GF)k
14
30
36
28
29
28
26
17
22
22
19
18
21
16
31
20
24
23
19
Vapor
Pressure
@25-C (psi)
145
239
22.7
f
113
24.3
23.7
f
25.4
f
75.2
14.8
684
17.7
151
302
83.2
29.2
f
Reference
Table"
Dense
Dense
Dense
Dense
Buoyantd
Dense
Dense
Dense
Buoyant1
Dense
Dense
Dense
Dense
Dense
May 22,2000
-------
Chapter 4
OfFsite Consequence Analysis
4-60
CAS
Number
75-44-5
7803-51-2
7446-09-5
7783-60-0
Chemical Name
Phosphine
Sulfur dioxide (anhydrous)
Sulfur tclnifluoridc
Molecular
Weight
98.92
34.00
6407
IIIHW,
Ufilio nf
Specific
Heals
1.17
1.29
1 26
1 10
Toxic Endpoint"
mg/L
0.00081
0.0035
0.0078
(1 mm
ppm
0.2
2.5
3
2
Basis
ERPG-2
ERPQ-2
ERPG-2
KI!S-LOC(Toxc)
Liquid Factor
Boiling
(LFB)
0.20
0.15
0.16
0.25
Density
Factor (DF)
(Boiling)
0.35
0.66
0.33
0.25
(at -73 °C)
Gas
Factor
(GF)k
33
20
27
36
Vapor
Pressure
@25-C(psi)
27.4
567
58.0
293
Reference
Table"
Dense
Dense
Dense
Dense
Notes:
a Toxic endpoints arc specified in Appendix A to -K) Cl K Part 68 in units of mg/L. To convert from units of mg/L to mg/m3, multiply by 1,000. To convert
mg/L to ppm, use the following equation:
Endpointppra = (Endpoint,^ x 1,000 x 24.5)/Molecular Weight
b "Buoyant" in the Reference Table column refers to the tables for neutrally buoyant gases and vapors; "Dense" refers to the tables for dense gases and vapors.
See OCAG, Appendix D, Section D.4.4, for more information on the choice of reference tables.
0 See Exhibit B-3 of OCAG, Appendix B, for data on water solutions.
d Gases that are lighter than air may behave as dense gases upon release if liquefied under pressure or cold; consider the conditions of release when choosing the
appropriate table.
c LOG is based on the IDLH-equivalent level estimated from toxicity data.
f Cannot be liquefied at 25 °C.
8 Not an EHS; LOC-equivalent value was estimated from one-tenth of the IDLH.
h Not an EHS; LOC-equivalent value was estimated from one-tenth of the IDLH-equivalent level estimated from toxicity data.
1 Hydrogen fluoride is lighter than air, but may behave as a dense gas upon release under some circumstances (e.g., release under pressure, high concentration in
the released cloud) because of hydrogen bonding; consider the conditions of release when choosing the appropriate table.
j LOG based on Threshold Limit Value (TLV) - Time-weighted average (TWA) developed by the American Conference of Governmental Industrial Hygienists
(ACGIH).
k Use GF for gas leaks under choked (maximum) flow conditions.
May 22,2000
-------
4-61
Chapter 4
Offsite Consequence Analysis
Exhibit B-2
Data for Toxic Liquids
CAS
Number
107-02-8
107-13-1
814-68-6
107-18-6
107-11-9
7784-34-1
353-42-4
7726-95-6
75-15-0
67-66-3
542-88-1
107-30-2
4170-30-3
123-73-9
108-91-8
75-78-5
57-14-7
106-89-8
107-15-3
151-56-4
110-00-9
302-01-2
Chemical Name
Acrolein
Acrylonitrile
Acrylyl chloride
Allyl alcohol
Allylamine
Arsenous trichloride
Boron trifluoride compound
with methyl ether (1:1)
Bromine
Carbon disulfide
Chloroform
Chloromethyl ether
Chloromethyl methyl ether
Crotonaldehyde
Crotonaldehyde, (E)-
Cyclohexylamine
Dimethyldichlorosilane
1 , 1 -Dimethylhydrazine
Epichlorohydrin
Ethylenediamine
Ethyleneimine
Furan
Hvdrazine
Molecular
Weight
56.06
53.06
90.51
58.08
57.10
181.28
113.89
159.81
76.14
119.38
114.96
80.51
70.09
70.09
99.18
129.06
60.10
92.53
60.10
43.07
68.08
32.05
Vapor
Pressure
at 25°C
(mm Hg)
274
108
110
26.1
242
10
11
212
359
196
29.4
199
33.1
33.1
10.1
141
157
17.0
12.2
211
600
14.4
Toxic Endpoint"
mg/L
0.0011
0.076
0.00090
0.036
0.0032
0.01
0.023
0.0065
0.16
0.49
0.00025
0.0018
0.029
0.029
0.16
0.026
0.012
0.076
0.49
0.018
0.0012
0.011
ppm
0.5
35
0.2
15
1
1
5
1
50
100
0.05
0.6
10
10
39
5
5
20
200
10
0.4
8
Basis
ERPG-2
ERPG-2
EHS-LOC (Toxc)
EHS-LOC (IDLH)
EHS-LOC (Toxc)
EHS-LOC (Toxc)
EHS-LOC (Tox°)
ERPG-2
ERPG-2
EHS-LOC (IDLH)
EHS-LOC (Toxc)
EHS-LOC (Toxc)
ERPG-2
ERPG-2
EHS-LOC (Toxc)
ERPG-2
EHS-LOC (IDLH)
ERPG-2
EHS-LOC (IDLH)
EHS-LOC (IDLH)
EHS-LOC (Tox0)
EHS-LOC (IDLH)
Liquid Factors
Ambient
(LFA)
0.047
0.018
0.026
0.0046
0.042
0.0037
0.0030
0.073
0.075
0.055
0.0080
0.043
0.0066
0.0066
0.0025
0.042
0.028
0.0040
0.0022
0.030
0.12
0.0017
Boiling
(LFB)
0.12
0.11
0.15
0.11
0.12
0.21
0.16
0.23
0.15
0.19
0.17
0.15
0.12
0.12
0.14
0.20
0.12
0.14
0.10
0.10
0.14
0.069
Density
Factor
(DF)
0.58
0.61
0.44
0.58
0.64
0.23
0.49
0.16
0.39
0.33
0.37
0.46
0.58
,0.58
0.56
0.46
0.62
0.42
0.54
0.58
0.52
0.48
Liquid
Leak
Factor
(LLF)1
40
39
54
41
36
100
48
150
60
71
63
51
41
41
41
51
38
57
43
40
45
48
Reference Tableb
Worst
Case
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Buoyant
Alternative
Case
Dense
Dense
Dense
Buoyantd
Dense
Buoyant"1
Buoyant"1
Dense
Dense
Dense
Dense
Dense
Buoyant"1
Buoyant"1
Buoyant"1
Dense
Dense
Buoyant"1
Buoyant
Dense
Dense
Buoyant
June 23, 1999
-------
Chapter 4
Offsite Consequence Analysis
4-62
CAS
Number
13463-40-6
78-82-0
108-23-6
126-98-7
79-22-1
60-34-4
624-83-9
556-64-9
75-79-6
13463-39-3
7697-37-2
79-21-0
594-42-3
10025-87-3
7719-12-2
110-89-4
107-12-0
109-61-5
75-55-8
75-56-9
7446-11-9
75-74-1
509-14-8
7550-45-0
Chemical Name
Iron, pentacarbonyl-
Isobutyronilrile
Isopropyl chlorofortnate
Mcthacrylonilrile
Methyl clilorofomiiite
Methyl hydrazine
Methyl isocyanate
Methyl thiocyanate
Methyltrichlorosilane
Nickel catbonyl
Nitric acid (100%)f
Peracetic acid
Perchloromethylmercaptan
Phosphorus oxychloride
Phosphorus trichloride
Piperidine
Prooionitrile
Propyl chlorofortnate
Propyleneimine
Propylene oxide
Sulfur trioxide
Tetramethyllead
Tetranitromethane
Titanium tetrachloride
Molecular
Weight
195.90
69.11
122.55
67.09
9-1 50
4ft.l)7
57.05
73.12
149.48
170.73
63.01
76.05
185.87
153.33
137.33
85.15
55.08
122.56
57.10
58.08
80.06
267.33
196.04
189.69
Vapor
Pressure
nt 25'C
(mm Hg)
40
32.7
28
71.2
IOX
49.6
457
10
173
400
63.0
13.9
6
35.8
120
32.1
47.3
20.0
187
533
263
22.5
11.4
12.4
Toxic Endpolnt*
mg/L
0.00044
0.14
0.10
0.0027
0.0019
0.0094
0.0012
0.085
0.018
0.00067
0.026
0.0045
0.0076
0.0030
0.028
0.022
0.0037
0.010
0.12
0.59
0.010
0.0040
0.0040
0.020
ppm
0.05
50
20
1
0.5
5
0.5
29
3
0.1
10
1.5
1
0.5
5
6
1.6
2
50
250
3
0.4
0.5
2.6
Busts
EHS-LOC (Tox0)
ERPa-2
EHS-LOC(Toxc)
EHS-LOC(TLVC)
EHS-LOC (Toxc)
EHS-LOC(IDLH)
ERPG-2
EHS-LOC (Tox°)
ERPG-2
EHS-LOC (Toxc)
EHS-LOC (IDLH)
EHS-LOC (Tox0)
EHS-LOC (IDLH)
EHS-LOC (Tox")
EHS-LOC (IDLH)
EHS-LOC (Tox")
EHS-LOC (Tox0)
EHS-LOC (Tox")
EHS-LOC (IDLH)
ERPG-2
ERPG-2
EHS-LOC (IDLH)
EHS-LOC (IDLH)
ERPG-2
Liquid Factors
Ambient
(LFA)
0.016
0.0064
0.0080
0.014
0.026
0.0074
0.079
0.0020
0.057
0.14
0.012
0.0029
0.0023
0.012
0.037
0.0072
0.0080
0.0058
0.032
0.093
0.057
0.011
0.0045
0.0048
Boiling
(LFB)
0.24
0.12
0.17
0.12
0.16
0.094
0.13
0.11
0.22
0.26
0.12
0.12
0.20
0.20
0.20
0.13
0.10
0.17
0.12
0.13
0.15
0.29
0.22
0.21
Density
Factor
(DF)
0.33
0.63
0.45
0.61
0.40
0.56
0.52
0.45
0.38
0.37
0.32
0.40
0.29
0.29
0.31
0.57
0,63
0.45
0.61
0.59
0.26
0.24
0.30
0.28
Liquid
Leak
Factor
(LLF)1
70
37
52
38
58
42
45
51
61
63
73
58
81
80
75
41
37
52
39
40
91
96
78
82
Reference Table11
Worst
Case
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Alternative
Case
Dense
Buoyant*1
Dense
Dense
Dense
Buoyant*1
Dense
Buoyant1*
Dense
Dense
Dense
Buoyantd
Buoyant*1
Dense
Dense
Buoyant*1
Buoyant*1
Buoyant*1
Dense
Dense
Dense
Dense
Buoyant
June 23,1999
-------
Chapter 4
Offsite Consequence Analysis
4-63
CAS
Number
584-84-9
91-08-7
26471-62-5
75-77-4
108-05-4
Chemical Name
Toluene 2,4-diisocyanate
Toluene 2,6-diisocyanate
Toluene diisocyanate
(unspecified isomer)
Vinyl acetate monomer
Molecular
Weight
174.16
174.16
174.16
108.64
86.09
Vapor
Pressure
at25"C
(mm Hg)
0.017
0.05
0.017
231
113
Toxic Endpoint9
mg/L
0.0070
0.0070
0.0070
0.050
0.26
ppm
1
1
1
11
75
Basis
EHS-LOC(IDLH)
EHS-LOC(IDLH8)
EHS-LOC
equivalent (IDLHh)
EHS-LOC (Tox°)
ERPQ-2
Liquid Factors
Ambient
(LFA)
0.000006
0.000018
0.000006
0.061
0.026
Boiling
(LFB)
0.16
0.16
0.16
0.18
0.15
Density
Factor
(DF)
0.40
0.40
0.40
0.57
0.53
Liquid
Leak
Factor
(LLF)1
59
59
59
41
45
Reference Tableb
Worst
Case
Buoyantd
Buoyantd
Buoyant"1
Dense
Dense
Alternative
Case
Buoyant1*
Buoyantd
Buoyant"1
Dense
Dense
Notes:
a Toxic endpoints are specified in the Appendix A to 40 CFR Part 68 in units of mg/L. To convert from units of mg/L to mg/m3, multiply by 1,000. To convert mg/L to ppm, use
the following equation:
Endpointppm = (Endpoint^i x 1,000 x 24.5)/Molecular Weight
b "Buoyant" in the Reference Table column refers to the tables for neutrally buoyant gases and vapors; "Dense" refers to the tables for dense gases and vapors. See OCAG,
Appendix D, Section D.4.4, for more information on the choice of reference tables.
0 LOG is based on IDLH-equivalent level estimated from toxicity data.
d Use dense gas table if substance is at an elevated temperature.
e LOG based on Threshold Limit Value (TLV) - Time-weighted average (TWA) developed by the American Conference of Governmental Industrial Hygienists (ACGIH).
f See Exhibit B-3 of OCAG, Appendix B, for data on water solutions.
6 LOC for this isomer is based on IDLH for toluene 2,4-diisocyanate.
h Not an EHS; LOC-equivalent value is based on IDLH for toluene 2,4-diisocyanate.
1 Use the LLF only for leaks from tanks at atmospheric pressure.
January 26, 1999
-------
Chapter 4
Offsite Consequence Analysts
4-64
Exhibit B-3
Data for Water Solutions of Toxic Substances and for Oleum
Average Vapor Pressure and Liquid Factors Over 10 Minutes for
Wind Speeds of 1.5 and 3.0 Meters per Second (ra/s)
CAS
Number
7664-41-7
50-00-0
7647-01-0
7664-39-3
7697-37-2
8014-95-7
Regulated
Substance
in Solution
Ammonia
Formaldehyde
Hydrochloric
acid
Hydrofluoric
acid
Nitric acid
Oleum - based
onSOj
Molecular
Weight
17.03
30.027
36.46
20.01
63.01
80.06
(S03)
Toxic Endpoint*
rag/L
0.14
0.012
0.030
0.016
0.026
0.010
ppm
200
10
20
20
10
3
Basis
ERPQ-2
ERPG-2
ERPG-2
ERPG-2
EHS-
LOC
(1DLH)
ERPG-2
Initial
Concen-
tration
(Wt %)
30
24
20
37
38
37
36°
34°
30C
70
50
90
85
80
30 (SO3)
10-min. Average Vapor
Pressure (mm Hg)
1.5 ra/s
332
241
190
1.5
78
67
56
38
13
124
16
25
17
10.2
3.5 (S03)
3.0 m/s
248
184
148
1.4
55
48
42
29
12
107
15
22
16
10
3.4 (S03)
Liquid Factor at 25*
C
(LFA)
1.5 m/s
0.026
0.019
0.015
0.0002
0.010
0.0085
0.0072
0.0048
0.0016
0.011
0.0014
0.0046
0.0032
0.0019
0.0008
3.0 ra/s
0.019
0.014
0.011
0.0002
0.0070
0.0062
0.0053
0.0037
0.0015
0.010
0.0013
0.0040
0.0029
0.0018
0.0007
Density
Factor
(DF)
0.55
0.54
0.53
0.44
0.41
0.42
0.42
0.42
0.42
0.39
0.41
0.33
0.33
0.33
0.25
Liquid
Leak
Factor
(LLF)
43
44
44
53
57
57
57
56
55
61
58
71
70
70
93
Reference Tableb
Worst
Buoyant
Buoyant
Buoyant
Buoyant
Dense
Dense
Dense
Dense
Buoyant
Buoyant
Buoyant
Dense
Dense
Dense
Buoyant
Alternative
Buoyant
Buoyant
Buoyant
Buoyant
Buoyant
Buoyant
Buoyant
Buoyant
Buoyant
Buoyant
Buoyant
Buoyant
Buoyant
Buoyant
Buoyant
Notes:
a
Toxic endpoints are specified in the Appendix A to 40 CFR Part 68 in units of mg/L. See Notes to Exhibit B-l or B-2 for converting to other units.
b "Buoyant" in the Reference Table column refers to the tables for neutrally buoyant gases and vapors; "Dense" refers to the tables for dense gases and vapors. See OCAG,
Appendix D, Section D.4.4, for more information on the choice of reference tables.
0 Hydrochloric acid in concentrations below 37 percent is not regulated.
January 26, 1999
-------
4-65
Chapter 4
Offsite Consequence Analysis
Exhibit B-4
Temperature Correction Factors for Liquids Evaporating from Pools at Temperatures
Between 25°C and 50°C (77°F and 122°F)
CAS
Number
107-02-8
107-13-1
814-68-6
107-18-6
107-11-9
7784-34-1
353-42-4
7726-95-6
75-15-0
67-66-3
542-88-1
107-30-2
4170-30-3
123-73-9
108-91-8
75-78-5
57-14-7
106-89-8
107-15-3
151-56-4
110-00-9
302-01-2
13463-40-6
78-82-0
108-23-6
126-98-7
79-22-1
60-34-4
624-83-9
556-64-9
75-79-6
Chemical Name
Acrolein
Acrylonitrile
Acrylyl chloride
Allyl alcohol
AUylamine
Arsenous trichloride
Boron trifluoride compound with
methyl ether (1:1)
Bromine
Carbon disulfide
Chloroform
Chloromethyl ether
Chloromethyl methyl ether
Crotonaldehyde
Crotonaldehyde, (E)-
Cyclohexylamine
Dimethyldichlorosilane
1 , 1 -Dimethylhydrazine
Epichlorohydrin
Ethylenediamine
Ethyleneimine
Furan
Hydrazine
Iron, pentacarbonyl-
Isobutyronitrile
Isopropyl chlorofonnate
Methacrylonitrile
Methyl chlorofonnate
Methyl hydrazine
Methyl isocyanate
Methyl thiocyanate
Methyltrichlorosilane
Boiling
Point
(°C)
52.69
77.35
75.00
97.08
53.30
130.06
126.85
58.75
46.22
61.18
104.85
59.50
104.10
102.22
134.50
70.20
63.90
118.50
117.40
55.85
31.35
113.50
102.65
103.61
104.60
90.30
70.85
87.50
38.85
130.00
66.40
Temperature Correction Factor (TCF)
308C
(86°F)
1.2
1.2
ND
1.3
1.2
ND
ND
1.2
1.2
1.2
1.3
1.2
1.3
1.3
1.3
1.2
ND
1.3
1.3
1.2
1.2
1.3
ND
1.3
ND
1.2
1.3
ND
1.2
ND
1.2
35°C
(95°F)
1.4
1.5
ND
1.7
1.5
ND
ND
1.5
1.4
1.5
1.6
1.5
1.6
1.6
1.7
1.5
ND
1.7
1.8
1.5
LFB
1.7
ND
1.6
ND
1.5
1.6
ND
1.4
ND
1.4
40°C
(104°F)
1.7
1.8
ND
2.2
1.8
ND
ND
1.7
1.6
1.8
2.0
1.8
2.0
2.0
2.1
1.8
ND
2.1
2.3
1.8
LFB
2.2
ND
2.0
ND
1.8
1.9
ND
LFB
ND
1.7
45°C
(113°F)
2.0
2.1
ND
2.9
2.1
ND
ND
2.1
1.9
2.1
2.5
2.1
2.5
2.5
2.7
2.1
ND
2.7
3.0
2.2
LFB
2.9
ND
2.5
ND
2.2
2.4
ND
LFB
ND
2.0
50°C
(122°F)
2.3
2.5
ND
3.6
2.5
ND
ND
2.5
LFB
2.5
3.1
2.5
3.1
3.1
3.4
2.5
ND
3.4
3.8
2.7
LFB
3.6
ND
3.1
ND
2.6
2.9
ND
LFB
ND
2.4
June 23, 1999
-------
Chapter 4
Offsite Consequence Analysis
4-66
CAS
Number
13463-39-3
7697-37-2
79-21-0
594-42-3
10025-87-3
7719-12-2
110-89-4
107-12-0
109-61-5
75-55-8
75-56-9
7446-11-9
75-74-1
509-14-8
7550-45-0
584-84-9
91-08-7
26471-62-5
75-77-4
108-05-4
Chemical Name
Nickel carbonyl
Nitric acid
Peracetic acid
Perchloromethylmercaptan
Phosphorus oxychloride
Phosphorus trichloride
Piperidine
Propionitrile
Propyl chloroformate
Propyleneimine
Propylene oxide
Sulfur trioxide
Tetramethyllead
Tetranitromethane
Titanium tetrachloride
Toluene 2,4-diisocyanate
Toluene 2,6-diisocyanate
Toluene diisocyanate (unspecified
isomer)
Trimethylchlorosilane
Vinyl acetate monomer
Boiling
Point
(°Q
42.85
83.00
109.85
147.00
105.50
76.10
106.40
97.35
112.40
60.85
33.90
44.75
110.00
125.70
135.85
251.00
244.85
250.00
57.60
72.50
Temperature Correction Factor (TCF)
30°C
(86°F)
ND
1.3
1.3
ND
1.3
1.2
1.3
1.3
ND
1.2
1.2
1.3
ND
1.3
1.3
1.6
ND
1.6
1.2
1.2
35°C
(95°F)
ND
1.6
1.8
ND
1.6
1.5
1.6
1.6
ND
1.5
LFB
1.7
ND
1.7
1.6
2.4
ND
2.4
1.4
1.5
40°C
(104"F)
ND
2.0
2.3
ND
1.9
1.8
2.0
1.9
ND
1.8
LFB
LFB
ND
2.2
2.0
3.6
ND
3.6
1.7
1.9
45°C
(113°F)
ND
2.5
3.0
ND
2.4
2.1
2.4
2.3
ND
2.1
LFB
LFB
ND
2.8
2.6
5.3
ND
5.3
2.0
2.3
50°C
(122°F)
ND
3.1
3.8
ND
2.9
2.5
3.0
2.8
ND
2.5
LFB
LFB
ND
3.5
3.2
7.7
ND
7.7
2.3
2.7
Notes:
ND: No data available
LFB: Chemical above boiling point at this temperature; use LFB for analysis
i • I
: i I
Explanation of Temperature Correction Factors. Temperature correction factors were developed for toxic liquids released at temperatures above
25 *C, the temperature used for development of the LFAs. The factors are based on vapor pressures calculated from the coefficients provided in
Physical and Thermodynamic Properties of Pure Chemicals, Data Compilation, developed by the Design Institute for Physical Property Data
(DIPPR), American Institute of Chemical Engineers. The factors are calculated as follows:
where:
TCFT = (VPT x 298)/(VP298 x T)
TCFT = Temperature Correction Factor at temperature T
VPT = Vapor pressure at temperature T
VP29i = Vapor pressure at 298K
T = Temperature (K)
Factors were developed at intervals of 5°C for temperatures up to 50°C. The above equation is the same as
Equation D-5 in the OCAG.
January 26,1999
-------
4-67
Chapter 4
Offsite Consequence Analysis
For temperatures exceeding 25 °C, the value of LFA in Equation 1 or Equation 4 of Chapter 4 should be multiplied
by the appropriate temperature correction factor (TCP), or, equivalently, the, calculated evaporation rate should be
multiplied by TCP. For example, in Example 3 in Chapter 4, a release rate of 13 Ib/min has been calculated
following an accidental spillage of dimethyldichlorosilane from a SS-gallon-drum at 25°C. If the spill were at
45 ° C, TCP would be 2.1 (from Exhibit B-4), and the predicted rate of evaporation would be 13 x 2.1 = 27.3 Ib/min.
January 26, 1999
-------
Chapter 4
Offsite Consequence Analysis
4-68
Exhibit C-l
Heats of Combustion for Flammable Substances
CAS No.
75-07-0
74-86-2
598-73-2
106-99-0
106-97-8
25167-67-3
590-18-1
624-64-6
106-98-9
107-01-7
463-58-1
7791-21-1
590-21-6
557-98-2
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
Chemical Name
Acetaldehyde
Acetylene [Ethyne]
Bromotrifluoroethylene [Ethene, bromotrifluoro-]
1,3-Butadiene
Butane
Butene
2-Butene-cis
2-Butene-trans [2-Butene, (E)]
1-Butene
2-Butene
Carbon oxysulfide [Carbon oxide sulfide (COS)]
Chlorine monoxide [Chlorine oxide]
1-Chloropropylene [1-Propene, 1-chloro-]
2-Chloropropylene [1-Propene, 2-chloro-]
Cyanogen [Ethanedinitrile]
Cyclopropane
Dichlorosilane [Silane, dichloro-]
Difluoroethane [Ethane, 1,1-difluoro-]
Dimethylamine [Methanamine, N-methyl-]
2,2-Dimethylpropane [Propane, 2,2-dimethyl-]
Ethane
Ethyl acetylene [1-Butyne]
Ethylamine [Ethanamine]
Ethyl chloride [Ethane, chloro-]
Ethylene [Ethene]
Ethyl ether [Ethane, l,l'-oxybis-]
Ethyl mercaptan [Ethanethioll
Physical
State
at 25"C
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Liquid
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Liquid
Liquid
Heat of
Combustion
(kjoule/kg)
25,072
48,222
1,967
44,548
45,719
45,200*
45,171
45,069
45,292
45,100"
9,126
1,011*
23,000*
22,999
21,064
46,560
8,225
11,484
35,813
45,051
47,509
45,565
35,210
19,917
47,145
33,775
27,948
January 26,1999
-------
4-69
Chapter 4
Offsite Consequence Analysis
CAS No.
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
115-11-7
504-60-9
109-66-0
109-67-1
i.j<..04-8
• fC--20-3
463-49-0
74-98-6
115-07-1
74-99-7
7803-62-5
116-14-3
75-76-3
10025-78-2
79-38-9
75-50-3
Chemical Name
Ethyl nitrite [Nitrous acid, ethyl ester]
Hydrogen
Isobutane [Propane, 2-methyl]
Isopentane [Butane, 2-methyl-]
Isoprene [1,3 -Butadiene, 2-methyl-]
Isopropylamine [2-Propanamine]
Isopropyl chloride [Propane, 2-chloro-]
Methane
Methylamine [Methanamine]
3-Methyl-l-butene
2-Methyl-l-butene
Methyl ether [Methane, oxybis-]
Methyl formate [Formic acid, methyl ester]
2-Methylpropcnc [ 1 -Propene, 2-methyl-]
1,3-Pentadiene
Pentane
1-Pentenc
2-Pentcnc. (I >-
2-Pentcnc. i?i
Propadicnc [ ! .2-Pronadicne]
Propane
Propylenc [1-Propcnc]
Propyne [1-Pronvne]
Silane
Tetrafluoroethylene [Ethene, tetrafluoro-]
Tetramethylsilane [Silane, tetramethyl-]
Trichlorosilane [Silane, trichloro-]
Trifluorochloroethylene [Ethene, chlorotrifluoro-]
Trimethylamine [Methanamine, N,N-dimethyl-]
Physical
State
at 25°C
Gas
Gas
Gas
Liquid
Liquid
Liquid
Liquid
Gas
Gas
Gas
Liquid
Gas
Liquid
Gas
Liquid
Liquid
Liquid
Liquid
Liquid
Gas
Gas
Gas
Gas
Gas
Gas
Liquid
Liquid
Gas
Gas
Heat of
Combustion
(kjoule/kg)
18,000
119,950
45,576
44,911
43,809
36,484
23,720
50,029
31,396
44,559
44,414
28,835
15,335
44,985
43,834
44,697
44,625
44,458
44,520
46,332
46,333
45,762
46,165
44,307
1,284
41,712
3,754
1,837
37,978
January 26, 1999
-------
Chapter 4
Offsite Consequence Analysis
4-70
CAS No.
689-97-4
75-01-4
109-92-2
75-02-5
75-35-4
75-38-7
107-25-5
Chemical Name
Vinyl acetylene [l-Buten-3-yne]
Vinyl chloride [Ethene, chloro-]
Vinyl ethyl ether [Ethene, ethoxy-]
Vinyl fluoride [Ethene, fluoro-]
Vinylidene chloride [Ethene, 1,1-dichloro-]
Vinylidene fluoride [Ethene, 1,1-difluoro-]
Vinyl methyl ether [Ethene, methoxy-]
Physical
State
at 25°C
Gas
Gas
Liquid
Gas
Liquid
Gas
Gas
Heat of
Combustion
(kjoule/kg)
45,357
18,848
32,909
2,195
10,354
10,807
30,549
*Estimated heat of combustion
January 26, 1999
-------
4-71
Chapter 4
Offsite Consequence Analysis
Exhibit C-2
Data for Flammable Gases
CAS
Number
75-07-0
74-86-2
598-73-2
106-99-0
106-97-8
25167-67-3
590-18-1
624-64-6
106-98-9
107-01-7
463-58-1
7791-21-1
5"57-98-2
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
Chemical Name
Acetaldehyde
Acetylene
Bromotrifluoroethylene
1,3-Butadiene
Butane
Butene
2-Butene-cis
2-Butene-trans
1 -Butene
2-Butene
Carbon oxysulfide
Chlorine monoxide
2-Chloropropylene
Cyanogen
Cyclopropane
Dichlorosilane
Difluoroethane
Dimethylamine
2,2-Dimethylpropane
Ethane
Ethyl acetylene
Ethvlamine
Molecular
Weight
44.05
26.04
160.92
54.09
58.12
56.11
56.11
56.11
56.11
56.11
60.08
86.91
76.53
52.04
42.08
101.01
66.05
45.08
72.15
30.07
54.09
45.08
Ratio of
Specific
Heats
1.18
1.23
1.11
1.12
1.09
1.10
1.12
1.11
1.11
1.10
1.25
1.21
1.12
1.17
1.18
1.16
1.14
1.14
1.07
1.19
1.11
1.13
Flamn
Limits
Lower
(LFL)
4.0
2.5
C
2.0
1.5
1.7
1.6
1.8
1.6
1.7
12.0
23.5
4.5
6.0
2.4
4.0
3.7
2.8
1.4
2.9
2.0
3.5
lability
rvoi %)
Upper(
UFL)
60.0
80.0
37.0
11.5
9.0
9.5
9.7
9.7
9.3
9.7
29.0
NA
16.0
32.0
10.4
96.0
18.0
14.4
7.5
13.0
32.9
14.0
LFL
(mg/L)
72
27
C
44
36
39
37
41
37
39
290
830
• 140
130
41
160
100
52
41
36
44
64
Gas
Factor
(GF)*
22
17
41°
24
25
24
24
24
24
24
26
31
" 29
24
22
33
27
22
27
18
24
22
Liquid
Factor
Boiling
(LFB)
0.11
0.12
0.25C
0.14
0.14
0.14
0.14
0.14
0.14
0.14
0.18
0.19
0.16
0.15
0.13
0.20
0.17
0.12
0.16
0.14
0.13
0.12
Density
Factor
(Boiling)
(DF)
0.62
0.78
0.29°
0.75
0.81
0.77
0.76
0.77
0.78
0.77
0.41
NA
"0~54
0.51
0.72
0.40
0.48
0.73
0.80
0.89
0.73
0.71
Reference
Table"
Dense
Buoyant1"
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Pool Fire
Factor
(PFF)
2.7
4.8
0.42°
5.5
5.9
5.6
5.6
5.6
5.7
5.6
1.3
0.15
3.3
2.5
5.4
1.3
1.6
3.7
6.4
5.4
5.4
3.6
Flash
Fraction
Factor
(FFF)f
0.018
0.23f
0.1 5C
0.15
0.15
0.14
0.11
0.12
0.17
0.12
0.29
NA
0.011
0.40
0.23
0.084
0.23
0.090
0.11
0.75
0.091
0.040
January 26,1999
-------
Chapter 4
Ofisite Consequence Analysis
4-72
CAS
Number
75-00-3
74-85-1
109-95-5
1333-74-0
75-28-5
74-82-8
74-89-5
563-45-1
115-10-6
115-11-7
463-49-0
74-98-6
. 115-07-1
74-99-7
7803-62-5
116-14-3
79-38-9
75-50-3
689-97-4
75-01-4
75-02-5
75-38-7
107-25-5
Chemical Name
Ethyl chloride
Ethylene
Ethyl nitrite
I lydrogcn
Isobutnnc
Methane
Methylamine
3-Methyl-l-butene
Methyl ether
2-Methylpropene
Propadiene
Propane
Propylene
Propyne
Silane
Tetrafluoroethylene
Trifluorochloroethylene
Trimethylamine
Vinyl acetylene
Vinyl chloride
Vinyl fluoride
Vinylidene fluoride
Vinyl methyl ether
Molecular
Weight
64.51
28.05
75 07
in:
5K 12
Id 111
31.06
70.13
46.07
56.11
40.07
44.10
42.08
40.07
32.12
100.02
116.47
59.11
52.08
62.50
46.04
64.04
58.08
Hnlinnf
Specific
Heals
1.15
1.24
1 10
1 -II
1 ()')
1 10
1.19
1.08
1.15
1.10
1.16
1.13
1.15
1.16
1.24
1.12
1.11
1.10
1.13
1.18
1.20
1.16
1.12
Flamm
Limits (
Lower
(LFL)
3.8
2.7
4.0
4.0
1.8
50
4.9
1.5
3.3
1.8
2.1
2.0
2.0
1.7
c
11.0
8.4
2.0
2.2
3.6
2.6
5.5
2.6
ability
Vol %)
Upper(
UFL)
15.4
36.0
50.0
75.0
8.4
15.0
20.7
9.1
27.3
8.8
2.1
9.5
11.0
39.9
c
60.0
38.7
11.6
31.7
33.0
21.7
21.3
39.0
LFL
(mg/L)
100
31
120
3.3
43
33
62
43
64
41
34
36
34
28
c
450
400
48
47
92
49
140
62
Gas
Factor
(GF)«
27
18
30
5.0
25
14
19
26
22
24
21
22
21
21
19C
33
35
25
24
26
23
27
25
Liquid
Factor
Boiling
(LFB)
0.15
0.14
0.16
e
0.15
0.15
0.10
0.15
0.14
0.14
0.13
0.14
0.14
0.12
e
0.29
0.26
0.14
0.13
0.16
0.17
0.22
0.17
Density
Factor
(Boiling)
(DF)
0.53
0.85
0.54
c
0.82
1.1
0.70
0.77
0.66
0.77
0.73
0.83
0.79
0.72
e
0.32
0.33
0.74
0.69
0.50
0.57
0.42
0.57
Reference
Table"
Dense
Buoyant11
Dense
d
Dense
Buoyant
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Pool Fire
Factor
(PFF)
2.6
5.4
2.0
C
6.0
5.6
2.7
6.0
3.4
5.7
5.2
5.7
5.5
4.9
e
0.25
0.34
4.8
5.4
2.4
0.28
1.8
3.7
Flash
Fraction
Factor
(FFF)f
0.053
0.63f
NA
NA
0.23
0.87f
0.12
0.030
0.22
0.18
0.20
0.38
0.35
0.18
0.41f
0.69
0.27
0.12
0.086
0.14
0.37
0.50
0.093
January 26, 1999
-------
Chapter 4
4-73 ' Offsite Consequence Analysis
Notes:
NA: Data not available
a "Buoyant" in the Reference Table column refers to the tables for neutrally buoyant gases and vapors; "Dense" refers to the tables for dense gases and vapors.
See Appendix D, Section D.4.4, for more information on the choice of reference tables.
Gases that are lighter than air may behave as dense gases upon release if liquefied under pressure or cold; consider the conditions of release when choosing the
appropriate table.
0 Reported to be spontaneously combustible.
Much lighter than air; table of distances for neutrally buoyant gases not appropriate.
c Pool formation unlikely.
f Calculated at 298 K (25°C) with the following exceptions:
Acetylene factor at 250 K as reported in TNO, Methods for the Calculation of the Physical Effects of the Escape of Dangerous Material (1980).
Ethylene factor calculated at critical temperature, 282 K.
Methane factor calculated at critical temperature, 191 K.
Silane factor calculated at critical temperature, 270 K.
8 Use GF for gas leaks under choked (maximum) flow conditions.
January 26, 1999
-------
Chapter 4
OHsite Consequence Analysis
4-74
Exhibit C-3
Data for Flammable Liquids
CAS
Number
590-21-6
60-29-7
75-08-1
78-78-4
78-79-5
75-31-0
75-29-6
563-46-2
107-31-3
504-60-9
109-66-0
109-67-1
646-04-8
627-20-3
75-76-3
10025-78-2
109-92-2
75-35-4
Chemical Name
l-Chloropropylene
Ethyl ether
Ethyl mercaptan
Isopentane
Isoprene
Isopropylamine
Isopropyl chloride
2-Methyl-l-butene
Methyl formate
1,3-Pentadiene
Pentane
1-Pentene
2-Pentene, (E)-
2-Pentene, (Z)-
Tetramethylsilane
Trichlorosilane
Vinyl ethyl ether
Vinylidene chloride
Molecular
Weight
76.53
74.12
62.14
72.15
68.12
59.11
78.54
70.13
60.05
68.12
72.15
70.13
70.13
70.13
88.23
135.45
72.11
96.94
Flammnbility Limit
(Vol%)
Lower
(LFL)
4.5
1.9
2.8
1.4
2.0
2.0
2.8
1.4
5.9
1.6
1.3
1.5
1.4
1.4
1.5
1.2
1.7
7.3
Upper
(UFL)
16.0
48.0
18.0
7.6
9.0
10.4
10.7
9.6
20.0
13.1
8.0
8.7
10.6
10.6
NA
90.5
28.0
NA
LFL
(mg/L)
140
57
71
41
56
48
90
40
140
44
38
43
40
40
54
66
50
290
Liquid Factors
Ambient
(LFA)
0.11
0.11
0.10
0.14
0.11
0.10
0.11
0.12
0.10
0.077
0.10
0.13
0.10
0.10
0.17
0.18
0.10
0.15
Boiling
(LFB)
0.15
0.15
0.13
0.15
0.14
0.13
0.16
0.15
0.13
0.14
0.15
0.15
0.15
0.15
0.17
0.23
0.15
0.18
Density
Factor
0.52
0.69
0.58
0.79
0.72
0.71
0.57
0.75
0.50
0.72
0.78
0.77
0.76
0.75
0.59
0.37
0.65
0.44
Liquid Leak
Factor
(LLF)"
45
34
40
30
32
33
41
31
46
33
30
31
31
31
40
64
36
54
Reference
Tableb
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Dense
Pool Fire
Factor
(PFF)
3.2
4.3
3.3
6.1
5.5
4.1
3.1
5.8
1.8
5.3
5.8
5.8
5.6
5.6
6.3
0.68
4.2
1.6
NA: Data not available
January 26, 1999
-------
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 me 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 safely 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
-------
Chapter 5
Management System
5-2
Lines of Authority
WHAT DOES THIS MEAN FOR ME AS A SMALL FACILITY?
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.
i • i
;
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
authority with an organizational chart or similar document only if you choose to
assign responsibility for specific elements of the risk management program to
persons or positions other 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 organizational chart. For this reason, this chapter does not provide an
example organizational chart for a small facility.
Even if you meet the requirements of this section by naming a single person or
position, it is important to recognize that the person or position assigned the
responsibility of overseeing implementation must have the ability and resources to
ensure that your facility and employees carry out the risk management program,
particularly the prevention elements, on an continuing basis. Key to the
effectiveness of the rule is integrated management of the program elements.
WHAT DOES THIS MEAN FOR ME AS A MEDIUM OR LARGE FACILITY?
i i '
'ii : i
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.
, Efwwwaij teess,
!
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:
+ Ensure effective communication about process changes between divisions;
+ Clarify the roles and responsibilities related to process safety issues at your
facility;
+ Avoid problems or conflicts among the various people responsible for
implementing elements of the risk management program;
+ Avoid confusion and allow those responsible for implementation to work
together as a team; and
+ 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
54
EXHIBIT 5-1
SAMPLE MANAGEMENT DOCUMENTATION
Position
Primary Responsibility
Changes
Responsibility re: Changes
Operations Manager
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
New Equipment
New Process Chemistry
New Process Parameters
New Procedures
Change in Process Utilization
Inform head of training
Inform head of maintenance
Inform lead for PHAs
Inform hazmat team as needed
Inform contractors
Training Supervisor
Develop, track, oversee operator
training program
Track competency testing
Set up and track operator refresher
training
Set up training for maintenance
Work with contractors
New Equipment
New Process Chemistry
New Process Parameters
New Procedures
Change in Process Utilization
New regulatory requirements
Revise training and refresher training
courses
Revise maintenance courses, as needed
Inform other leads of need for
additional training
Maintenance Supervisor
Develop maintenance schedules
Oversee and document maintenance
Revise schedules as needed
New Equipment
New Process Chemistry
New Process Parameters
New Procedures
Change in Process Utilization
Inform operations manager of potential
problem areas
Inform training supervisor of any
training revisions
Inform contractors
Revise schedules
Hazmat Team Chief
Develop and exercise ER plan
Train responders
Test and maintain ER equipment
Coordinate with public responders
Select participants in accident
investigations
New Equipment
New Process Chemistry
New Process Parameters
New Procedures
Change in Process Utilization
New regulatory requirements
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
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
-------
THIS PAGE INTENTIONALLY LEFT BLANK
-------
CHAPTER 6: PREVENTION PROGRAM (PROGRAM 2)
6.1 ABOUT THE PROGRAM 2 PREVENTION PROGRAM
If your warehouse is ineligible for Program 1 and the substances you have above the
threshold are not covered by OSHA's PSM standard, you have a Program 2 process.
For most facilities covered by EPA's rule, the prevention program will be slightly
different for each covered process because the hazards and equipment will be
different and, therefore, the training and procedures will differ. For warehouses that
simply store materials (as opposed to repackaging them), however, the prevention
program is likely to be essentially the same for all covered substances. Procedures
for moving and stacking containers, operating fbrklifts and other equipment, and
segregating substances will be common to all substances stored. If you start storing
a new class of hazardous substances you may have to address segregation issues, but
once you have, your procedures and safety information will mainly be the same.
Because of this common approach to prevention^ you will probably want to treat
your whole building as one process. You should address any differences in the
hazard review and safety information, but yon should develop a single prevention
program that includes all covered substances within a building. If you have more
than one building at your facility, you will need to develop separate prevention
programs for each building with regulated substances above the threshold.
Procedures that are common across buildings need not be duplicated.
The Chemical Manufacturers' Association (CMA), in coordination with the
International Warehouse Logistics Association (IWLA) has developed a Warehouse
Assessment Protocol. The Protocol includes some items that are not covered by the
rule (e.g.. package labeling), but many of the checklists will be useful in developing
your prevention program. Reviewing and adapting applicable parts of the Protocol
to your specific operations can save you time while helping you identify issues of
concern.
There arc seven elements in the Program 2 prevention program, which is Subpart C
of pan 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
become part of the way you operate. Doing so will provide benefits beyond accident
prevention as well. Preventive maintenance and.routine inspections will lessen the
number of equipment failures and down time.
January 26, 1999
-------
Chapter 6
Prevention Program (Program 2)
6-2
SUMMARY OF PROGRAM 2 PREVENTION PROGRAM
Number
§ 68.48
§ 68.50
§ 68.52
§ 68.54
§ 68.56
§ 68.58
§ 68.60
Section Title
Safety Information
Hazard Review
Operating Procedures
Training
Maintenance
Compliance Audits
Incident Investigation
6.2 SAFETY INFORMATION (§ 68.48)
!
The purpose of this requirement is for you to understand the equipment and
chemicals you have, know what limits they place on your operations, and adopt
accepted standards and codes where they apply. Having iip-to-date 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.
WHAT Do I NEED To Do?
! I
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 information already, because you would have developed it to comply
with OSHA 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.
i ! '
How Do I START?
! i '
MSDSs. You are required to maintain Material Safety Data Sheets xinder the OSHA
Hazard Communication Standard (HCS) (29 CFR 1910.1200). If you are a public
warehouse, you should obtain the MSDSs from your customers. If you do not have
an MSDS for a regulated substance, you should contact your customer or the
manufacturer for a copy. Because the rule states that you must have an MSDS that
meets OSHA requirements you may want to review the MSDS to ensure that it is, in
January 26,1999
-------
6-3
Chapter 6
Prevention Program (Program 2)
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 and building
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
fact, complete. Besides the chemical name, the MSDS must have physical and
chemical characteristics (e.g., flash point, vapor pressure), the physical hazards (e.g.,
flammability, reactivity), the health hazards, the 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.)
MSDSs also are available from a number of websites. The University of Vermont
provides access to three university-maintained MSDS collections through 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.
Maximum Inventory. You must document the maximum intended inventory of any
vessel that contains a regulated subject is part of a covered process. This
requirement, when applied to warehouses, means that you must document the sizes
of vessels that you store. Your customers can provide information on the capacity of
the drums, barrels, cylinders, etc., that they store at your facility. You may also want
to consider documenting the maximum storage capacity of areas where you store
regulated substances. If you are doing predictive filing, as described in Chapter 1,
section 1.8, you will want to keep a record of the'sizes of vessels you may be storing.
You may want to check with the trade association or standards groups, such as
NFPA, that develop standards for your industry to determine if there are any
limitations on inventories. For example, fire codes may limit the size of individual
January 26, 1999
-------
Chapter 6
Prevention Program (Program 2)
6-4
flammable storage areas to less than 40,000 square feet. Codes or standards may set
stack height limits. These standards will limit your maximum inventories.
i
Storage and Process Limits. You must document the safe upper and lower
temperatures and pressures, process flows, and compositions (the last three items
will generally not be applicable to warehouses).
• • • . i |
Every substance you store or use will have limits on temperature, which will be
determined by both the properties of the substance and the vessels. If you do not
know these limits, you should contact your customer, the substance manufacturer (if
different), or your trade association. They will be able to provide the data you need.
It is important that you know these limits so you can avoid situations where these
limits may be violated. Many people are aware of the dangers of exposing then-
vessels to high temperatures, but extreme low temperatures also may pose hazards
you should know about.
I . | i.
Equipment Specifications. You must document any equipment you use to store,
repackage, or move regulated substances. 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. You are not expected to
develop engineering drawings of your equipment to meet this requirement. For
warehouses, this requirement will apply mainlv to forklifts and other equipment used
to lift or move drums, barrels, pallets, etc., as well as storage racks. It is important
that you understand the limitations on this equipment so that it can be operated and
used properly.
The actual containers for the regulated substances should be designed to meet DOT
performance oriented packaging rules. You need only enisure that containers you
store meet DOT specifications; you do not need to maintain copies of the DOT
specifications unless you package regulated substances at your warehouse.
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
include the electrical and building codes that you must comply with under state laws.
Besides the construction of the building, you should consider racks that you use for
storage, sprinkler systems, heating and ventilation systems, and any other equipment
or design features that affect the safety of your warehouse. Exhibit 6-3 lists some
codes that may be relevant to your operation.
Note that the National Fire Protection Association (NFPA.) codes may have been
adopted as state or local codes. The American National Standards Institute (ANSI)
is an umbrella, standards-setting organization, which imposes a specific process for
gaining approval of standards and codes. ANSI codes may include codes and
standards also issued by other organizations, which are incorporated by reference.
January 26,1999
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Chapter 6
Prevention Program (Program 2)
The CMA Warehouse Assessment Protocol has a section on loss prevention (section
4 of the protocol) that can help you identify areas of concern on design.
EXHIBIT 6-3
CODES AND STANDARDS
Organization
American National Standards Institute (ANSI)
National Fire Protection Association (NFPA)
American Society for Testing Materials (ASTM)
Subject/Codes
Piping, Electrical, Power wiring, Instrumentation,
Lighting, Product storage and handling, Insulation and
fireproofmg, Painting and coating, Ventilation, Noise
and Vibration, Fire protection equipment, Safety
equipment, Pumps, Compressors, Motors,
Refrigeration equipment, Pneumatic conveying
Fire pumps, Combustible liquid code, Flammable
liquid code, Plant equipment and layout, Electrical
system design, Shutdown systems, Venting
requirements, Gas turbines and engines, Storage tanks,
Gas code
Inspection and testing, Noise and vibration, Materials
of construction, Piping materials and systems,
Instrumentation '
How Do I DOCUMENT ALL THIS?
EPA does not expect you to develop piles of papers to document your safety
information. Your MSDS(s) are usually three or four pages long. You only have to
keep them on file, as you already do for OSHA. Equipment specifications are
usually on a few sheets or 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. Maintain that sheet in a file and update it whenever any
item changes or new equipment is added.
The equipment specifications and list of standards and codes will probably meet the
final requirement, that you ensure that your process is designed in compliance with
recognized and generally good engineering practices. If you have any doubt that you
are meeting this requirement, you should contact your trade association to
determine if there are practices or standards that you are not aware of that may be
useful in your operation.
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6-6
EXHIBIT 6-4
SAMPLE SAFETY INFORMATION SHEET
, , „
REQUIREMENT
MSDSsonfile
Nitric Acid
Hydrochloric Acid
Hydrofluoric Acid
Acrylonitrile
Flammable mixtures
Maximum Intended Inventory
Temperature
Equipment Specifications
Fork lifts
Sprinkler system
Wet system
Foam system
Rack system
Storage racks
Exhaust fans
Fire extinguishers
Alarm system
CURRENT DATA/LIMITS
Data of last update:
1994
1996
1995
1997
5 mixtures (1998, 1997, 1999)
Largest Vessel: 55-gallon idrums
Maximum storage in any section 1,000 drums
Maximum area storage for flammables 30,000 square
feet.
Aerosol (flammable) storage less than 100 cubic feet
Upper:
Lower:
Specifications on file:
Last update, 1992
Construction drawings and specifications
Construction drawings and specifications
Construction drawings and specifications
Manufacturer's specifications (1985)
Manufacturer's specifications (1993)
Manufacturer's specifications (1995)
Manufacturer's specifications (1985)
CODES AND STANDARDS
Building construction
Floor
Interior walls
Ceiling
Fire doors
Electrical
Sprinkler system
Ventilation system
Racks
Stack heights, separations
State building and fire code met
State electrical code met
State building code; NFPA met
State building code met
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Chapter 6
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After 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.
6.3 HAZARD REVIEW (§ 68.50)
The hazard review will help you determine whether you're 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 your .operation and continuing to operate
safely. You must identify and review specific hazards and safeguards of your
Program 2 processes. Exhibit 6-5 summarizes things you must do for a hazard
review.
EXHIBIT 6-5
HAZARD REVIEW REQUIREMENTS
Conduct a review &
identify^ 5 ,
Use a guide for
conducting the
review.
Document results &
resolve problems.
Update your hazard
review. ;•"..»
•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 any
checklist (such as you
might in a model risk
management program)
to conduct the review.
•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.
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6-8
How Do I START?
There are three possible approaches to conducting a hazard review; which you use
will depend on your particular situation.
Processes designed to industry-specific codes. If all or part of your warehouse and
its operation was designed and built to comply with a federal or state standard for
that operation or an industry-specific design code, your hazard review will be
relatively simple. The standard-setting organization has already conducted a hazard
review, identified the hazards, and designed the equipment and operating
requirements to minimize the risks. You can use the code or standard as a checklist.
The purpose of your review is to ensure that your equipment still meets the code and
is being operated in appropriate ways.
.: i |
Industry checklist CMA's Warehouse Assessment Protocol, particularly the
Warehouse Assessment (as opposed to the Management Systems Assessment), can
provide the basis for a hazard review checklist. CMA and IWLA have already
identified what your general hazards are and what types of equipment and
procedures you should be using. Your job is to use the checklist to decide if you
meet the requirements and, if you do not, whether you should. In some cases, your
individual circumstances may make a checklist item unnecessary. You should tailor
this checklist to add chemical-specific concerns. For example, if you handle a wide
range of chemicals across hazard classes, you will want to be sure that these
materials are segregated properly. The segregation criteria you use should be
documented. If you have an operating engineer on staff, he or she may be able to
conduct the review. If you do not have any technical staff, your vendor or trade
association may be able to help you. If you seek outside help, however, work with
them so that you understand what they find.
i ' I' : ' i ' " !
Develop your own checklist. If you do not choose to use the CMA protocol or
industry standards, you will have to conduct your own hazard review. As discussed
in the requirements section, the review must identify:
4- The hazards of the substance and process;
4- Possible equipment failures or human errors that could lead to a release;
4- Safeguards used to prevent failures or errors; and
4- Steps needed to detect or monitor releases.
You will probably be able to define the hazards of the substances using the MSDSs,
which list the hazardous properties of the substances. The hazards of the process (as
opposed to the equipment) will be limited because you may not actually handle the
substance outside of the container. However, if you mix or repackage chemicals, or
if you fail to segregate hazard classes, you may have process hazards that you need
to define. Your safety information should help.
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Chapter 6
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The next step may be to conduct a simplified What If process, where your technical
staff ask for each piece of equipment and procedure, "What if this fails?" and "What
if the operator fails to do this?" Most industry standards and codes have already
considered these questions and developed responses, in terms of design and
operating practices. If you are doing this on your own, the important thing to
remember is that you should not assume that something will not happen. Ask why
something could not happen and whether the safeguards that you think protect the
equipment or operator are really adequate. In many cases, they may be adequate, but
it is useful to ask, to force yourself to examine your own assumptions.
From this exercise, you should develop a checklist of items that you need to check.
For example, you may have decided that your racks can hold a certain weight. The
checklist would then include an item to check procedures to be sure that they reflect
this limit. You may have identified puncturing drums with a forklift as the most
likely operator error. Your checklist might then include both a check of operating
procedures that address proper practices, plus a check of the width of corridors
separating racks or pallets to ensure that forklift operators have enough space to
maneuver.
When you finish the checklist, it is useful to show it to your operators. They are
familiar with the equipment and may be able to point out other areas of concern. A
review with your vendors or trade association may also help; their wider knowledge
of the industry may give them ideas about failures you may not have experienced or
considered.
CAUTION
Whichever approach you use, remember, you should consider external events as well
as internal failures. If you are in an area subject to earthquakes, hurricanes, floods,
or heavy snow you should examine whether your warehouse would survive these
natural events without releasing the substance. You should consider the potential
impacts of h'ghtning strikes and power failures (e.g., if you lost heating in midwinter
would that create dangerous situations?). These considerations may not be part of
standard checklists. If you use these standards, you may have to modify them to
address these site-specific concerns. Never use someone else's checklist blindly.
You must be sure that it addresses all of your potential problems.
DOCUMENTING THE REVIEW
You should maintain a copy of the checklist you used. The easiest way to document
findings is to enter them into the checklist after each item. This approach will give
you a simple, concise way of keeping track of findings and recommendations.
Exhibit 6-6 provides a sample of part of a checklist (adapted from the CMA
Warehouse Assessment Protocol, 1996). You may also want to create a separate
document of recommendations that require implementation or other resolution. EPA
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6-10
does not require that you implement 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 document your decision on each recommendation.
! i
EXHIBIT 6-6
SAMPLE CHECKLIST
Storage and Handling
Are chemicals segregated from foods/consumer goods?
Are chemicals segregated by hazard class?
Are damaged containers marked and segregated?
Are product temperature specifications followed?
Are there floor markings to indicate storage spaces,
aisles, staging areas, and routes?
Are products stacked properly to height specifications in
accordance with fire regulations?
Are there indications of exceeding height requirements,
such as crushed boxes?
Are aisle distances between stacking racks appropriate for
safe access with mechanical handling equipment?
Is aisle distance maintained for safe access for fire
fighting?
Is there at least one meter between the top of the stack
and sprinkler heads?
Are products stored outside of the pathway of forced air
conditioning and heating units?
Are products stored in areas other than on the floor?
Is there a designated area for drums or intermediate bulk
containers stored outside?
Are empty pallets stored in accordance with fire
regulations?
Are container labels visible?
Yes
No
Comments
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UPDATES
You must update the review every five years or whenever a major change occurs.
For most warehouses, major changes will be limited. If you start storing a new
substance, particularly if it is in a hazard class you have not handled before, you
would want to consider whether the new type of hazard requires any additional
actions (e.g., different type of fire suppression system, new segregation patterns). In
most cases, adding new regulated substances in a hazard class you already handle
(flammable liquids, acids) will not be considered a major change. Even if the
changes prove to be minor and do not require an update, you should examine the
process carefully before starting. You will operate more safely if you take the time
to evaluate the hazards before proceeding.
6.4 OPERATING PROCEDURES (§ 68.52)
Written operating procedures describe what tasks a process operator must perform,
set safe process operating parameters that must be maintained, and set safety
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 model risk
management programs 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 6-7 briefly summarizes
what your operating procedures must address.
Your operating procedures must be:
+ Appropriate for your equipment and operations;
+ Complete; and
+ Written in language that is easily understood by your operators.
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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6-12
EXHIBIT 6-7
OPERATING PROCEDURES REQUIREMENTS
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
Operating limits
•Consequences of deviating
•Steps to avoid, correct deviations
WHERE Do I START
If you already have written procedures, you may not have to do anything more.
Review the procedures. If 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 store chemicals
safely.
,
i , i .. , , •
If you do not have written procedures, you 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 appropriate for your
particular equipment and uses and are written in language 'that 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, state, or local rules for
loading and unloading of hazardous materials, those rules may dictate some
procedures. Copies of these rules may be sufficient for those operations.
i • !'
WHAT Do THESE PROCEDURES MEAN?
The rule lists eight procedures. Not all of them will be applicable to you if you only
store substances. 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.
I ! ,;' . I
Initial Startup. This item will only apply to you if you repackage or mix chemicals.
For most warehouses this item is not applicable. If you handle the chemicals outside
January 26,1999
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6-13
Chapter 6
Prevention Program (Program 2)
of the containers, as opposed to simply storing and moving the containers, this item
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. These
are your core procedures that you expect your operators to follow on a daily basis to
run your warehouse safely. For a warehouse, these would include the following:
+ Segregation and storage procedures
+ Useofforklifts
+ Loading and unloading
+ Examination for damage and labeling
+ Stock controls
+ Site security
+ Bracing and stacking
+ Hot work
+ Handling damaged containers
You may also have to cover the HVAC system if failure of this system could lead to
a release.
Some of these operations are covered by federal, state, or local rules (e.g., loading
and unloading may be covered by US DOT; hot work is covered by OSHA). Your
procedures should represent compliance with any applicable rules.
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., can the material be segregated properly?).
The actual operating procedures for running the temporary process will be written as
the operation is put into place.
You may need to consider procedures to ensure that if a new substance or product is
brought into the warehouse for temporary storage, the necessary steps are taken
before that storage to ensure that it is safe (e.g., barrels are not stacked too high, or
located with incompatible substances).
Normal Shutdown. These procedures may not apply to warehouses unless you
repackage. If you do not repackage, you may not need procedures for this step
unless you use automatic equipment for moving containers.
Startup following a normal or emergency shutdown or a major change. For
most warehouses, these procedures are likely to be similar to those for initial startup.
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6-14
Startup procedures following an emergency shutdown or a major change may include
more equipment checks because you may need to check new or repaired equipment
on a more frequent basis. You should include all the steps your workers should take
to ensure that the process can operate safely. These procedures may not apply to
warehouses in most instances.
j. i
1 'i ' !il I i !'
Consequences of Deviations. Your operating procedures should tell the workers
what will happen if something starts to go wrong. For example, if a rack appears to
be sagging inward, the operator must know (1) whether this poses a problem that
must be addressed and (2) what steps to take to correct the problem or otherwise
respond to it. You should include this information in each of the other procedures
(startup, normal operations, shutdowns), rather than as separate documents.
ii' i
1
If you have substances with a distinctive odor, color, or other characteristic that
operators will be able to sense, you should include in your procedures information
about what to do if they notice leaks. Frequently, people are the most sensitive leak
detectors. Take advantage of their abilities to catch leaks before they become
serious.
i
Equipment Inspections. You should include steps for routine inspection of
equipment by operators as part of your other procedures. These inspections cover
the items that operators should look for on a daily basis to be sure that the equipment
is running safely (e.g., vibration checks, leakage, overheating equipment). These
inspections are not the same as those detailed checks that maintenance workers will
perform, but rather are the "eyeball," "sound," and "feel" tests that experienced
operators do often without realizing it. Most likely, your warehouse is already doing
OSHA pre-checks and checks after work shifts. If you neecl further assistance, your
operators, your vendors, and your trade association can help you define the things
that should trigger concern: How much vibration is normal? What does a smoothly
running motor sound hike?
CMA PROTOCOL
The CMA Warehouse Assessment Protocol provides a checklist of operational
practices in its Management Systems Assessment. You may want to review this list;
some of the items on the list are not specifically covered by the rule (e.g., traffic
office procedures), but may be important to efficient running of your warehouse.
For warehouses, more than for many other businesses covered by this rule, the total
operation of the business is relevant to safety. Although many of the substances you
handle will not be subject to this rule, you are likely to use the same procedures that
you use for covered substances for the other chemicals you store.
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Chapter 6
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UPDATING PROCEDURES
You must update your procedures whenever you; change your process in a way that
alters the steps needed to operate safely. A change in the process, for a warehouse,
is likely to involve either the introduction of new equipment or introduction of a new
class of chemicals. If you add new equipment, you will need to expand your
procedures or develop a separate set to cover the.new items. If you store a class of
chemicals you have not handled before, you will need to inform your workers of the
hazards and make sure that these substances are segregated properly. Storing
containers of a chemical you have not handled before, but which is part of the same
class (e.g., flammables) that you already handle, would not be considered a change
unless the chemical had some other hazard of concern that you have not handled
before.
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.
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 already have some type of training program because you must
conduct training to comply with OSHA's Hazard Communication standard (29 CFR
1910.1200) and DOT training requirements.
WHAT Do 1 NEED TO Do?
You must train all new workers hi your operating procedures developed under the
previous element; if any of your more experienced workers need training on these
procedures, you should also train them. Any time the procedures are revised, you
must train everyone using the new procedures. At least once every three years, you
should provide refresher training on the operating procedures even if they have not
changed. The training must cover all parts of the operating procedures, including
information on the consequences of deviations and steps needed to address
deviations. New hires should be trained before being allowed to operate equipment
or handle regulated substances.
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For current workers, you may certify in writing that the employees have the
"required knowledge, skills, and abilities to safely carry out the duties and
responsibilities as provided in the operating procedures." This "grandfather clause"
means that you do not need to conduct additional training for employees who are
employed prior to June 21,1999, and who have the appropriate knowledge and skills
to operate covered processes safely, in accordance with the operating procedures.
This certification should be kept in your files; you do not need to submit it to EPA.
You are not required to provide a specific amount of training or type of training.
You should develop a training approach that works for you. If you are a small
facility, one-on-one training and on-the-job training may work best. Larger facilities
may want to provide classroom training or video courses developed by vendors or
trade associations before moving staff on to supervised work. You may have senior
operators present the training or use trainers provided by vendors or other outside
sources. The form and the length of the training will depend on your resources and
your processes. If you can teach someone the basics in two hours and move them on
to supervised work, that is all right. The important thing is that your workers
understand how to operate safely and can carry out their tasks properly. We are
interested in the results of die training, not the details of how you achieve them.
Find a system that works for you. Exhibit 6-8 lists things that you may find useful in
developing your training program.
How DOES THIS TRAINING FIT WITH OTHER REQUIRED TRAINING?
You are required by OSHA to provide training under the hazard communication
standard: 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. 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?
You are not required to maintain documentation of your training program. You may,
however, 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 when you do a compliance audit; without such logs you will have
to rely on your memory and the memory of your operators. Again, you are not
required to keep them for this rule.
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Chapter 6
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EXHIBIT 6-8
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 wnat 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's 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 that involved workers understand the
changes and the effects on their jobs.
6.6 MAINTENANCE (§ 68.56)
You have several elements you must satisfy: you must develop maintenance
procedures, train your workers in these procedures, and carry out inspections and
tests on your equipment; if you use a contractor for maintenance, you must ensure
that the contractors are able to follow your procedures. Maintenance procedures
should cover routine maintenance, inspection, and testing. For warehouses,
maintenance will apply primarily to equipment used to move storage containers
(lifts, conveyors, ladders, dock equipment). If you repackage regulated substances,
equipment use to repackage will be covered.
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. You may use procedures or instructions from equipment vendors, in
Federal or state regulations, or in industry codes as the basis of your maintenance
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6-18
program. You should develop a schedule for inspecting and testing your equipment
based on manufacturers' recommendations or your own experience. Exhibit 6-9
briefly summarized the elements of a maintenance program that would satisfy EPA's
rule.
How Do I START?
Your first steps will probably be to determine whether you already meet all these
requirements. If you review your existing written procedures and determine that
they are appropriate, you do not need to revise or rewrite them. If your workers are
already trained in the procedures and carry them out, you may not need to do
anything else.
If you do not have written procedures, you will need to develop them. Your
equipment vendors may be able to provide procedures and maintenance schedules.
Using these as the basis of your program is acceptable. Your trade association may
also be able to help you with industry-specific checklists. If there are existing
standards, your trade association can provide you with the references. Copies of
these may form the basis for your maintenance program. If there are federal or state
regulations that require certain maintenance, you should use these as well.
I I |
EXHIBIT 6-9
MAINTENANCE GUIDELINES
Written procedures
•You may use someone
else's procedures 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 hazard
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.
You need to determine if procedures provided by vendors., manufacturers, trade
associations, or others are appropriate for your operation. If you are operating in a
standard way (e.g., using your equipment in the way it was designed for), you may
assume that these other procedures will work for you. If you are using equipment for
purposes other than those for which it was designed, your best option is obtain
appropriate equipment. In the interim, you should consult with the equipment
manufacturer or vendor to decide whether your use is safe and whether you need to
January 26, 1999
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6-19
Chapter 6
Prevention Program (Program 2)
upgrade maintenance practices or increase the frequency and rigor of inspection and
testing.
TRAINING
Once you have written procedures, you must ensure that your maintenance workers
are trained in the procedures and in the hazards of the process. As with the training
discussed in the previous section, how you provide this training is up to you. We
believe that you are in the best position to decide how to train your workers.
Vendors may provide the training or videos; you,may already provide training on
hazards and how to avoid or correct them as part!of Hazard Communication Standard
training. You do not need to repeat this training to comply with this rule. New hires
or temporary workers must be trained before they perform maintenance on covered
equipment.
If you hire contractors to do your maintenance, you must ensure that they are trained
to carry out the procedures. You can do this by providing training or by developing
agreements with the contractor that gives you the assurance that only trained workers
will sent to your site. In some cases, you may be able to rely on licenses (e.g.,
electricians). :
INSPECTION AND TESTING
You must establish a schedule for inspection and testing equipment associated with
covered processes. You may obtain recommendations from manufacturers, vendors,
or trade associations. You should, however, use your own experience as a basis for
examining any schedules you obtain from others. Many things may affect whether a
schedule is appropriate. The manufacturer may assume a certain rate of use. If your
use (e.g., the hours per day a forklift is operated)1 varies considerably, the variations
may affect the wear on the equipment. Extreme weather conditions may also impact
wear on equipment.
Talk with your operators 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
trade association may also be able to provide advice on these issues.
WHAT KIND OF DOCUMENTATION MUST I KEEP?
You must keep your written procedures and schedules as well as any agreements you
have with contractors. You are not required to keep training logs or maintenance
logs to comply with this rule. You may, however, want to maintain such logs for
your own use. Without some record, you will have to rely on workers' memories
about when something was last checked. As workers leave or change jobs at your
company, it can be difficult to keep track of when inspections and tests were done.
January 26, 1999 •
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Chapter 6
Prevention. Program (Program 2)
6-20
Maintaining a record of when something was last done or is scheduled to be done
next can help keep your program working smoothly.
6.7 COMPLIANCE AUDITS (§ 68.58)
" ' j
Any risk management program should be reviewed periodically to ensure that
employees and contractors are implementing it properly. A compliance audit is a
way for you to evaluate and measure the effectiveness of your risk management
program. An 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
areas and take corrective actions. As a result, you'll be running a safer operation.
WHAT Do I NEED TO Do?
At least every three years, you must certify that you have evaluated compliance with
EPA's requirements for the prevention program for each covered process. At least
one person on your audit team must be knowledgeable about the 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.
i
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 (and gain the benefits) procedures must be followed on a daily basis;
documents must be kept up to date. The audit will check these items and provide
you with items that need to be improved.
I i
! ' '
You must check each of the items in the prevention program. Because you have
simple procedures, the audit should not take a long time. You may want to use the
CMA protocol as the basis of your audit or tailor it to fit your operation.
1 ; '!
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 each of the items, writing down comments and
recommendations. 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 warehousing. If you do either of these, you should have someone
work with the person, both to understand the findings and answer questions.
January 26,1999
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6-21
Chapter 6
Prevention Program (Program 2)
Remember, this is an audit of compliance with the prevention program of this rule.
You may choose to expand the scope of the audit ;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.
WHAT KIND OF DOCUMENTATION MUST I KEEP?
You must keep a written record of the findings and actions for five years. You may
also want to keep a record of who conducted the audit, but you are not required to
do this. Exhibit 6-10 provides a sample format for documenting the audit and
subsequent actions.
Q and A !
AUDITS
Q. Do the compliance audits cover all of the Part 68 requirements or just the prevention
program requirements?
A. The compliance audit applies only to the requirements of 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.
January 26,1999
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Chapter 6
Prevention Program (Program 2)
6-22
EXHIBIT 6-10
SAMPLE AUDIT CHECKLIST
FOR SAFETY INFORMATION AND HAZARD REVIEWS
Element
Yes/N6/NA
Action/Completion .Data
Safety Information
MSDSs updated?
Maximum intended inventory determined?
Determined
Safe upper and lower temperature?
Segregation of incompatible substances
Equipment specifications
Forklifts
Fire suppression systems
Ventilation system
Hazard Review
Are incompatible materials appropriately
segregated?
Is the fire suppression system appropriate for
materials stored?
Are stack heights in accordance with industry
standards and codes?
Has equipment been inspected to determine if
it is operated according to industry standards
and codes?
Are the results of the inspections
documented?
Have inspections been conducted after every
major change?
January 26,1999
-I
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Chapter 6
Prevention Program (Program 2)
WHAT Do I NEED TO Do?
You must investigate each incident that 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 The easiest way to understand imminent and substantial endangerment
is to consider whether the release could have exposed the public to levels that exceed
the toxic or flammable endpoints. If a release had that potential, even if no such
exposure occurred (because of favorable weather conditions or because the adjoining
facilities were unoccupied at the time), you should investigate. Most warehouse
accidents will not meet this criterion; minor spill's of toxic substances that are
contained within the warehouse building are unlikely to represent a potential
catastrophic release. Minor fires, however., may represent potential catastrophic
releases if the fire had the potential to spread and release toxic substances. Spills of
toxic regulated substances outside may pose a threat to the public and should be
investigated. Exhibit 6-11 briefly summarizes the steps you must take for
investigating incidents.
EXHIBIT 6-11
INCIDENT INVESTIGATION REQUIREMENTS
•Initiate an investigation promptly.
•Summarize the investigation in a report.
•Address the team'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, this report will include the
factors contributing to the incident. Remember
that identifying the root cause may be more
important than identifying the initiating event.
Remember, also, that the purpose of the report is
to help management take corrective action.
Establish a system to address 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. :
January 26, 1999
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Chapter 6
Prevention Program (Program 2)
6-24
How Do I START?
You should start with a simple set of procedures that you will use to begin an
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.
• • .' . 1 . ' . ! •:• I ' - .. ' !
The purpose of the investigation is to find out what went vwrong 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. 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.
, |
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.
Li many cases, an investigation will not take long. If you have a complex facility, if
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.
I | , ;,
WHAT KIND OF DOCUMENTATION MUST I KEEP?
You must maintain the summary of the accident, recommendations, and actions. A
sample format is shown in Exhibit 6-12 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.
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Chapter 6
Prevention Program (Program 2)
6.9 CONCLUSION
Many of you will need to do little that's new to comply with the Program. 2
prevention program, because you already are complying with many program
elements through other Federal rules, state requirements, and industry-specific codes
and standards. 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:
Integrate the elements of your prevention program. For Program 2 owners and
operators, a major change in any single element of your program should lead to a
review of other elements to identify any 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.
EXHIBIT 6-12
SAMPLE INCIDENT INVESTIGATION REPORT
Hydrofluoric Acid Release
Date: May 15, 1998; 3 pm
Duration: 2 hours
Description:
Findings
The forklift controls stuck.
Substance: Hydrofluoric acid
(70%)
Weather: 82° F, 8 mph winds,
WSW '
Quantity: 1800 pounds
A forklift punctured two 55--gallon drums of HF and severely
damaged two other drums on the pallet, which then split open as
they fell off the loading dock. Five workers and two local
responders were treated for exposure. Neighboring facilities were
notified to shelter in place.
Recommendations
Institute more frequent
inspections and tests of the i
forklifts.
Actions
Changed inspection and testing
intervals; revised procedures;
conducted training on new
procedures
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Chapter 6
Prevention Program (Program 2)
6-26
, , , 1 „„ „
Hydrofluoric Acid Release
Operator and other workers left
the scene to protect themselves.
It took 15 minutes for the
hazmat staff to suit up and
begin responding.
Inadequate quantities of
neutralizerwere available.
Supply had not been
replenished after several minor
spills.
Conduct exercises quarterly for
hazmat staff. Conduct refresher
training for other staff on
evacuation and notification
procedures.
Check and replenish supply
monthly or after each use.
Exercise schedule established.
Refresher training provided;
safety meetings added and held
on a monthly basis to review
safety issues
Routine checks added to work
order schedule.
January 26,1999
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CHAPTER 7: PREVENTION PROGRAM (PROGRAM 3)
Warehouses are subject to Program 3 only if they are subject to the OSHA PSM
standard. 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 hi place.
Whether you're building on the PSM standard or creating a new program, keep these
things hi 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 imperils
the public.
+ Integrate the elements of your prevention program. You must ensure that a
change hi 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 prcsent(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 hi
EPA's rule with their counterparts in the OSHA PSM standard.
January 25, 1999
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Chapter 7
Prevention Program (Program 3)
7-2
EXHIBIT 7-1
COMPARABLE EPA AND OSHA TERMS
[OSHA TERM, ".'
Highly hazardous substance
Employer
Facility
Standard
EPA TERM "* ' .: '
Regulated substance
Owner or operator
Stationary source
Rule or part
There are twelve elements in the Program 3 prevention program. Each element
corresponds with a section of subpartD 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
EXHIBIT7-2
SUMMARY OF PROGRAM 3 PREVENTION PROGRAM
(40 CFR PART 68, SUBPART D)
^iSK^ttN..'./,'
§ 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 ,,• , ,:X
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
'OSJHi'PSM R1EE2EUENCR , "
f f i ^
PSM standard § 1910.119(d).
PSM standard § 1910.119(e).
PSM standard § 1910.119(f).
PSM standard § 1910.119(g).
PSM standard § 1910.1 19(j).
PSM standard § 1910.119(1).
PSM standard § 1910.1 19(1).
PSM standard § 1 9 1 0. 1 1 9(o).
PSM standard § 1910.1 19(m)
PSM standard § 1910.119(c).
PSM standard § 1910.1 19(k).
PSM standard § 1910.119(h).
OSHA provided guidance on PSM in non-:
OSHA has reprinted this appendix as
3133). The OSHA guidance is reproduced,
•mandatory Appendix C to the standard.
PSM Guidelines for Compliance (OSHA
reordered to track part 68, in Appendix
January 25,1999
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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 is provided on the meaning of specific terms. For more detailed
guidance, you should refer to the OSHA guidance in Appendix D.
Q&A
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.
PSM AND WAREHOUSES
As discussed in Chapter 2, you will be subject to OSHA PSM if you have more than
a threshold quantity of most of the regulated toxic substances (OSHA does not cover
the acids in solution, toluene diisocyanate, chloroform, arsenous trichloride,
tetranitromethane, and titanium tetrachloride). If you have regulated flammables
liquids stored in containers at atmospheric conditions, these are not subject to OSHA
PSM under an exemption. Flammables stored under pressure or refrigeration would
be covered by OSHA.
7.2 PROCESS SAFETY INFORMATION (§ 68.65)
Exhibit 7-3 briefly summarizes the process safety information requirements.
PROCESS SAFETY INFORMATION AND WAREHOUSES
If you only store containers of regulated substances, many of the process safety
information requirements will not be applicable to you- Process chemistry, block
flow diagrams, P&IDs, relief systems, and safety systems are unlikely to be
applicable to most warehouses. You will still need to define maximum inventories
(see Chapter 6), safe process limits, and consequences of deviations. Materials of
construction, electrical classification, ventilation system design, and design codes
and standards will also apply.
May 3, 2000
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Chapter 7
Prevention Program (Program 3)
7-4
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 mining 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
WHERE To Go FOR MORE INFORMATION
, '''.'•• 5 ••.'.' I . .
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 isssue technical reports
relating to process design. Other sources you may find useful include:
Guidelines for Process Safety Documentation, Center for Chemical Process
Safety of the American Institute of Chemical Engineers 1995.
Emergency- Relief System Design Using DIERS Technology, American
Institute of Chemical Engineers, 1992.
Emergency Relief Systems for Runaway Chemical Reactions and Storage
I 'essels: A Summary of Multiphase Flow Methods, American Institute of
Chemical Engineers, 1986.
; : ! , , ;
Guidelines for Pressure Relief and Emergency Handling Systems, Center for
Chemical Process Safety of the American Institute of Chemical Engineers,
1998.
! |l ' \
Loss Prevention in ttie Process Industries, Volumes I, II, and HI, Frank P.
Lees, Butterworths: London 1996.
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7-5
Chapter 7
Prevention Program (Program 3)
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 for that 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 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)
PH A AND WAREHOUSES
PHA checklists will generally work well for warehouses. See Chapter 6 for
guidance on identifying or developing a checklist.
Exhibit 7-4 provides a summary of the requirements for process hazard analyses
(PHAs).
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.
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Chapter 7
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7-6
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
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.
. ' ' i ,',.,»' j
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
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 contamment'could occur.
However, for EPA, the PHA team should reassess venting as an appropriate
mitigation measure.
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7-7
Chapter 7
Prevention Program (Program 3)
Updating and revalidating your PHA. For EPA, you must complete the initial
PHA for each Program 3 process not later than June 21, 1999, 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.
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 the 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
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
revak'dating 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.
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
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7-8
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. In 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 hi 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.
guidance on methods for conducting a process hazard analysis. You might find the
following documents useful.
4- Guidelines for Hazard Evaluation Procedures, 2nd Ed. with Worked
examples, Center for Chemical Process Safety of file American Institute of
Chemical Engineers 1992.
,,.[..
+ Evaluating Process Safety in the Chemical Industry, Chemical
Manufacturers Association.
i
4- Loss Prevention in the Process Industries, Volumes I, II, and III, Frank P.
Lees, Butterworths: London 1996.
'''. .:'''. :
4- Management of Process Hazards (RP 750), American Petroleum Institute.
|
4- Risk-Based Decision Making (Publication 16288), American Petroleum
Institute.
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7.4 OPERATING PROCEDURES (§ 68.69)
OPERATING PROCEDURES AND WAREHOUSES
Chapter 6 of this document provides descriptions of what each operating phase and
when these phases may not apply to warehouse operations.
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.
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
WHERE To Go FOR MORE INFORMATION
Chapter 7 of this document provides descriptions of each operating phase and when
these phases may not apply to certain operations.
+ 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. :
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7-10
4- Guidelines for Writing Effective Operating and Maintenance Procedures,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1996.
! I I
7.5 TRAINING (§ 68.71)
: ,! • i . | . • 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 m 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 frequency). 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.
WHERE To Go FOR MORE INFORMATION
4- Guidelines for Process Safety Fundamentals for General Plant Operations,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1995.
' , : I y: i
4- Guidelines for Technical Planning for On-Site Emergencies, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1995.
; • t
4- Federally Mandated Training and Information (Publication 12000),
American Petroleum Institute.
7.6 MECHANICAL INTEGRITY (§ 68.73)
... i . i
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.
WHERE To Go FOR MORE INFORMATION
Guidance and Reports. Other sources of guidance and reports you may find useful
include:
! ' " ' "I " ' '. i
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.
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Chapter 7
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EXHIBIT 7-6
MECHANICAL INTEGRITY CHART
Written
procedures
•Establish &
implement
written
procedures to
maintain the
integrity of
process
equipment.
Training
•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.
7.7
4- Pressure Vessel Inspection Code: Maintenance Inspection, Rating, Repair,
and Alteration (API 510), American Petroleum Institute.
4- Tank Inspection, Repair, Alteration, and Reconstruction (Std 653), American
Petroleum Institute.
MANAGEMENT OF CHANGE (§ 68.75)
Exhibits 7-7 briefly summarizes EPA's MOC requirements.
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7-12
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)
MOC AND WAREHOUSES
If you only store substances at your warehouse, management of change will apply
primarily to the use of new equipment and the handling of a new class of substances.
If your procedures and practices do not change with the introduction of a new
substance or class of substances, you may not need to take any steps under
management of change. These changes will not trigger an RMP update if you have
included the new regulated substance in your existing RMP under predictive filing
(see Chapter 1).
, ,, |
WHERE To Go FOR MORE INFORMATION
i
+ Management of Change in Chemical Plants: Learning from Case Histories,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1993.
i I ' I ' I! '
1 i1 ! i „ , II
+ Plant Guidelines for Technical Management of Chemical Process Safety,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1992.
i ' i • ' i
4- Management of Process Hazards (RP 750), American Petroleum Institute.
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Chapter 7
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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.
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 mostirecent audit reports must be kept
on-site. ;
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.
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 to1 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
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7-14
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.
; ' •'.• , j
Guide for Fire and Explosion Investigations (NFPA 921), National Fire
Protection Association.
EXklBIT7-9
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.
7.11 EMPLOYEE PARTICIPATION (§ 68.83)
Exhibit 7-10 briefly summarizes what you must do.
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Chapter 7
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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.
WHERE To Go FOR MORE INFORMATION
+ Standard for Fire Prevention in Use of Cutting and Welding Processes
(NFPA 518), National Fire Protection Association.
+ Standard for Welding, Cutting and Brazing, 29 CFR 1910 Subpart Q.
7.13 CONTRACTORS (§ 68.87)
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.
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7-16
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 thedr 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 the 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.
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
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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7-18
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 pn 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 me AIChE/CCPS volume.
'. " ' ' i v' i i ' '• • !.'•.
Neither the information below nor the full AIChE/CCPS vohune 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
COrnplex 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.
;•• ' p >'"• ' '! ' '! :", ! • : ;'' ''. •
DESCRIPTIONS OF TECHNIQUES
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, 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.
: ! ' ' , I1
Checklists are created by taking the applicable standards and practices and using them to
generate a list of questions lhat 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.
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.
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WHAT-IF
A What-If is a brainstonning 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 tearn might then recommend steps to
prevent feeding wrong concentrations or to stop the feed if the reaction could not 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.
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.
AIChE/CCPS estimates that for a small or simple system a What-If/Checklist analysis will take 6 to 12
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7-20
l», .. "' »!» ' ' I ,"l 11 , :
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.
HAZOP
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.
Si : '• •! ' ! if-'' ' '! ,' • •
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.
i „ , i i |
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.
FAILURE MODE AND EFFECTS ANALYSIS (FMEA)
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."
"'.! • 'i ' i I , ! ;
i,. i "'! 1,1 i i'
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,
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
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7-21 , Prevention Program (Program 3)
and the impact on other equipment. Generally, when analyzing impacts, analysts assume that existing
safeguards do not work, AIChE states that "more optimistic assumptions may be satisfactory as long as
all equipment failure modes are analyzed on the same basis."
An FMEA requires an equipment list or P&ED, 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 fopuses 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 in 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,
Cause-Consequence Analysis, Event Tree Analysis, and Human Reliability Analysis. You may also
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Prevention Program (Program 3)
7-22
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.
APPLICABILITY OF PHA TECHNIQUES
R&D
Design
Pilot Plant Operation
Detailed Engineering
Construction/Start-Up
Routine Operation
Modification
Incident Investigation
Decommissioning
Checklist
/
/
/
/
^
/
^
What-If
/
^
/
/
^
^
^
/
/
What-If-
Checklist
/
/
S
/
/
/
/
HAZOP
/
/
/
/
^
FMEA
/
/
^
/
/
FTA
/
^
/
^
/
FACTORS IN SELECTING A TECHNIQUE
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.
AIChE lists What-If, What-If/Checklist, and HAZOP as better able to handle batch processes
than FTA or FMEA because the latter do not easily deal with the need to evaluate the time-dependent
nature of batch operations.
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 man one event.
Januaiy 25,1999
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7-23
Chapter 7
Prevention Program (Program 3)
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. ;
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.1 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 j
# 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
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
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
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)
January 25, 1999
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Chapter?
Prevention Program (Program 3)
7-24
rs
I ,'iit!
January 25,1999
-------
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 retailers and other 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 an ammonia retailer with only one full-time
employee to expect that a tank fire could be handled without the help of the local fire
department or other emergency responders. 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 to ensure employee safety, rather than a full-fledged
emergency response plan. 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 pnor 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. To do so, you must ensure that you have set
up a way to notify emergency responders when there is need for a response.
Coordination with local responders also entails the following steps:
4- I f 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. :
+ If you have a covered process with a regulated flammable, work with the
local fire department regarding a response to a potential release.
January 25, 1999
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Emergency Response Program
8-2
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 substan.ce." 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.
Although you do not need to describe these activities in your risk management plan,
to document your efforts you should keep a record of:
+ The emergency contact (i.e., name or organization and number) that you will
call for a toxic or flammable release, and
'" ' ; . ' i !' ' », ' | !" . ... , •; ' ' i 'i , ji I11 ,„, ,',!'i
,": . i ' :„ ' ' i : ' "i ' ' . I „ " • •
+ The organization that you worked with on response procedures.
:i ' , . i , •„ • ' i .j '• ' '<.,| .j 'i!;;' •;: '; •.) ••
The remainder of this chapter is applicable only to those facilities which 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.
8.2 ELEMENTS OF AN EMERGENCY RESPONSE PROGRAM (§ 68.95)
"'• ' ' " ; ' : • ' ' " ''.I. : .': •/! ';;' '•'. :.;i ,,', " , : • •' ' '!• •;
If you will respond to releases of regulated substances with your own employees,
your emergency response prbgram must consist of the following elements:
+ An emergency response plan (maintained at the facility) that includes:
January 25,1999
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8-3
Chapter 8
Emergency Response Program
> Procedures for informing the public and emergency response
agencies about releases,
> Documentation of proper first aid and emergency medical treatment
necessary to treat human closures, and
> Procedures and measures for emergency response.
+ Procedures for using, inspecting, testing,:and maintaining your emergency
response equipment;
+ Training for all employees in relevant procedures; and
+ 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.
Li 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.
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
What is a Local Emergency Planning Committee?
Local emergency planning committees (LEPCs) were formed under the Emergency Planning and
Community Right-to-Know 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:
+ 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.
January 25, 1999
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Chapter 8
Emergency Response Program
8-4
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 emergency action plan requirements (29 CFR
1910.38). Under OSHA HAZWOPER, any facility that handles "hazardous
substances" (a broad term that includes all of the CAA regulated substances and thus
applies to all facilities with covered processes) must comply with either 29 CFR
1910.38(a) or 1910.119(q). 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 of this chapter.
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.
I i (
'i ' " .
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.
RELATIONSHIP TO HAZWOPER
If you choose to establish and maintain onsite emergency response capabilities, then
you will be subject to the detailed provisions of the 9SHA 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.
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8-5
Chapter 8
Emergency Response Program
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 (NRTV1 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.
Qs & As
Emergency Response and Warehouses
Q. Does the emergency response program apply to specific covered processes?
A. 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.
Q. My customers control emergency response for their stored materials. How do I reflect that in my
response program?
A. Your emergency response plan should outline who is responsible' for handling responses and
provide contact numbers for customers who will handle responses at your warehouse. You should be
sure that your local responders understand how you and your customers coordinate responses.
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Chapter 8
Emergency Response Program
8-6
8.3 DEVELOPING AN EMERGENCY RESPONSE PROGRAM
•: ! , , "! ' • 1 !'' • ! :
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 into one of two groups:
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
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.
! ' ' " ' 'i
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:
j i
I
+ Maintenance;
4- Operations or line personnel;
4- Upper and line management;
4- Legal;
4- Fire and hazmat response;
4- Environmental, health, and safety affairs;
4- Training;
4- Security;
4- EPCRA section 3Q2 emergency coordinator (if one exists);
"4- Public relations; and
4- Personnel.
; ' '. " j . •'• , I '.• • : I ':;;;: _ • !
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:
4- Existing emergency response plans and procedures;
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8-7
Chapter 8
Emergency Response Program
4-
4-
4-
4-
4-
4-
Submissions to the LEPC under EPCRA sections 302 and 303;
Hazard evaluation and release modeling1 information;
Hazard communication and emergency response training;
Emergency drill and exercise programs; i
After-action reports and response critiques; and
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:
EPA's Oil Pollution Prevention Regulation (SPCC and Facility Response Plan Requirements)
- 40 CFR part 112.7(d) and 112.20-.2l;
EPA's Risk Management Programs Regulation - 40 CFR part 68;
OSHA's Emergency Action Plan Regulation - 29 CFR 1910r38(a);
OSHA's Process Safety Standard - 29 CFR 1910.119; j
OSHA's HAZWOPER Regulation - 29 CFR 1910.120; !
OSHA's Fire Brigade Regulation - 29 CFR 1910.156;
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.
4-
4-
4-
4-
4-
4-
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
4- Not hi place.
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F
Chapter 8
Emergency Response Program
8-8
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.
•'''•! ' ! ,1 • . • 1 •
TAILORING YOUR PROGRAM TO YOUR HAZARDS
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 the 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. The process
hazards analysis (see Chapter 7) or hazard review (see Chapter 6), and
offsite consequence analysis (see Chapter 4) should provide this information.
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.
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.
January 25,1999
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8-9
Chapter 8
Emergency Response Program
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.
8.5 HAVE I MET PART 68 REQUIREMENTS?
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.
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 OSHA 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
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 on the next page.
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Chapter 8
Emergency Response Program
8-10
Keep in mind: At a minimum., your plan must describe:
11
-, .1 • • • ""I 'I!- ' ' ' ;l , •• . ' ' '••, ' . • ;'• i v
4 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.
4 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.
4 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.
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.
'. " '.'',!, ." ,, ,' . i
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:
January 25,1999
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Chapter 8
8-11 ' Emergency Response Program
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, iand 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.
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
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.
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:
4- If they will only need to evacuate, men their training should cover when and
how to evacuate their location.
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Chapter 8
Emergency Response Program
8-12
+ If they may need to activate an alarm system in response to a release event,
then their training should cover the location of the alarms and when and how
to use the alarm system.
i
+ If they will serve on an emergency response team, then their training should
cover the location of all emergency equipment, how to use it, and how the
incident command system works.
Emergency response training conducted in compliance with the OSHA HAZWOPER
Standard and 29 CFR 1910.38 will be considered sufficient to meet this requirement.
RESPONSE PLAN EVALUATION
.. : -/: . • '• -i ; ::" ' r ::;" . i ^ '. : ;:;: : ': !
If you already 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.
' M' • : i , " I .'• • ' .•- "•• ii'.T". .' ' '• •'•; ."! , .i." ( • v. *•:.!..
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).
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))
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 me best source of information on the critical emergency response issues
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
, . , . . , ., in • • • \
If you have any of the toxic regulated substances above the threshold quantity, you
should 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 (or 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).
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Chapter 8
Emergency Response Program
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: ;
4- 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;
4- 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; :
4 Schedules of emergency exercises designed to test the community response
plan to spur coordinated community-facility exercises;
4 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
4 Details on incident command structure, emergency points of contact,
availability of emergency medical services, and public alert and notification
systems.
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,
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Emergency Response Program
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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 comtnunity 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 in 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 hi 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.
January 25,1999
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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 from http://www.epa.gov/ceppo/ and frpm the EPCRA hotline (see
Appendix C for contact information).
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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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
coyer 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
+ A summary of the prevention program for each Program 3 process
(§ 68.175).
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 make it 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
the 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*Subrrdt™ provides a list of
regulated substances and automatically fills in the CAS numbers when you select a
substance.
EPA has provided 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 posted on EPA's
web site at http://www.epa.gov/ceppo/ and are available from the EPCRA hotline
(see Appendix C for contact information).
9.2 RMP SUBMISSION
RMPs musi be sent to:
The RMP Reporting Center
P.O. Box 3346
! Mem field. YA 22116-3346
ELECTRONIC SUBMISSION
EPA has made RMP* Submit™ available to complete and file your RMP.
RMP*Submit™ does the following:
+ Provides a user-friendly, PC-based RMP Submission System available on
diskettes and via the Internet;
+ Uses a standards-based, open systems architecture so private companies can
create compatible software; and
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Risk Management Plan
+ Performs data quality checks, accept limited graphics, and provide on-line
help including defining data elements and providing instructions.
The software runs on Windows 3.1 and above. Inhere will not be a DOS or MAC
version. '•
RMPs will be submitted to an EPA RMP Record Center on disk.
HARD COPY SUBMISSION
If you are unable to submit electronically for anyTeason, 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.html#steps
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 ISSUES PERTAINING TO SUBMISSIONS OF AND ACCESS TO CONFIDENTIAL
BUSINESS INFORMATION (CBI) AND TRADE SECRETS
WHAT SHOULD I Do ABOUT CONFIDENTIAL BUSINESS INFORMATION (CBI)?
Under CAA section 114(c) and 40 CFR part 2, you may claim information included
in your RMP as CBI. To qualify for CBI protection, you must be able to show that
the information meets the substantive criteria set forth in 40 CFR 2.301. These
criteria generally require that the data be commercial or financial, that they not be
available to the public through other means, that you take appropriate steps to
prevent disclosure, and that disclosure of the data would be likely to cause
substantial harm to your competitive position. Review of any CBI claims will be
handled as provided for hi 40 CFR part 2. However, certain RMP data elements are
not claimable as CBI because they do not conveyiany business-sensitive information.
EPA has developed specific procedures for submission of CBI claims for RMPs.
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See § § 68.151 and 68.152 for details on what data may be claimed as CBI and how
to assert such claims.
9.4 RESUEMISSION 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 earJliest of the dates that apply
to your facility:
I
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 would1 have to increase
(decrease) by more than a factor of five to double (half) the distance to an endpoint.
CAN I FILE PREDICTIVELY?
Predictive filing is an option that allows you to submit an RMP that includes
regulated substances that may not be held at the facility at the time of submission.
This option is intended to assist chemical warehouses and other facilities whose
operations involve highly variable types and quantities of regulated substances, but
who are able to forecast their inventory with some degree of accuracy. Under
§ 68.190, you are required to update and re-submit your RMP no later than the date
on which a new regulated substance is first present in a covered process above a
threshold quantity. By using predictive filing, you will not be required to update and
re-submit your RMP when you receive a new regulated substance if that substance
was included in your latest RMP submission (as long as you receive it in a quantity
that does not trigger a revised offsite consequence analysis as provided in § 68.36).
If you use predictive filing, you must implement your Risk Management Program
and prepare your RMP exactly as you would if you actually held all of the substances
included in the RMP. This means that you must meet all rule requirements for each
regulated substance for which you file, whether or not that substance is actually held
on site at the time you submit your RMP. Depending on the substances for which
you file, this may require you to perform additional worst-case and alternative-case
scenarios and to implement additional prevention program elements. If you use this
option, you must still update and resubmit your RMP if you receive a regulated
substance that was not included in your latest RMP. You must also continue to
comply with the other update requirements stated in § 68.190. Applying predictive
filing to warehouses is described in more detail in Chapter 1, section 1.8.
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Chapter 9
Risk Management Plan
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 and 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
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. RMP* Submit will create this letter for you.
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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.
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 'revision1 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.
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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-sti5/112r-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 in slates 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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may be more stringent than part 68. This
requirements.
document does not cover state
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)
, , I " °
The implementing agency is required under part 68 to review and conduct audits of
RMPs. Reviews are relatively quick checks of me 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 data 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
4- Quantity of regulated substances handled at the site
4- 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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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 title 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 are reporting on a distillation column at a
refinery, but used a checklist as your PHA technique, or 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 then: own goals, based on then-
resources and particular concerns.
WHAT ARE INSPECTIONS? ;
Inspections arc 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 me facility, inspections may take
several hours to several weeks.
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10-4
10.3 RELATIONSHIP WITH TITLE V PERMIT PROGRAMS
Part 68 is an applicable requirement under the 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
because you are subject to requirements under some other part of the CAA, you
• j" , ?, must: ; ' ' ,. ] " , ;,
«.',,', i ' " ! V, ' ' 4 V ' , » i» ' ' 'ii',ii
+ List part 68 as an applicable requirement in your permit
+ Include conditions that require you to either submit a compliance schedule
for meeting the requirements ofpart 68'"by the applicable deadlines or
include compliance with part 68 as part of your certification statement.
You must also provide the permitting agency with any other relevant information it
requests.
i
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.
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 fortti 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. Any one
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.
II, Ai
II win
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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 agenc)r 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.
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January 25,1999
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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 trie risks of driving because they have
some control over what happens to them. However, they are generally more
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11-2
uncomfortable accepting the risks of living near a facility 1hat 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 then: 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
Dialogue in the community will be concerned with both hazards and risks; it is
useful to be clear about the difference between them.
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 .. , ,.
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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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, fee 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, safety, 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 hi your RMP is available
to the public, it is likely that people will want additional information. Interested
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11-4
parties will know that you retain additional information at your facility (e.g.,
documentation of the results of the offsite consequence atklysis 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:
4 Submissions under sections 302, 304, 311-312, arid 313 of the Emergency
Planning and Community Right to Know Act (EPCRA) reporting on
chemical storage and releases, as well as the community emergency response
plan prepared under EPCRA section 303.
4 Other reports on hazardous materials made, used, generated, stored, spilled,
released and transported, that you submittecl to federal, state, and local
agencies.
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4 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.
4 Any other information you have provided to public agencies that can be
accessed by members of the public under me federal Freedom of Information
Act and similar state laws (and that may have been made widely available
over the Internet).
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4 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.
11.2 SAMPLf QUESTIONS FOR COMWIUNJCATING WITH THE PUBLIC
•'»! • , :; i i;: ' "' r . / ' !': i. .. ;:; • \A /'.fj'; K:} •]*•• • \ ' ;- ; ' 'i.1
Smaller businesses may not have the resources of 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 RMP. 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 mat you may anticipate. The person
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from your facility designated as responsible for communicating 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 consider the 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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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 mil.es, 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 in 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. i
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IF THERE IS AN ACCIDENT, WILL EVERYONE WITHIN THAT DISTANCE BE HURT? WHAT
ABOUT PROPERTY DAM A GE?
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 -
face the greatest danger if an accident occurred.
- within a half mile or less — who would
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
fee 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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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
facilities 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
facility 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. First, 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 ithe 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
(2) Assign responsibilities and resources to implement the policy.
(3) Plan to use "best communication practices".
ADOPT AN ORGANIZATIONAL COMMUNICATIONS POLICY
An organizational policy will support communication with the public on your RMP
and make it an integral part of management practices. Otherwise, breakdowns are
likely to occur, which could cause mistrust, hostility and conflicts.
!
A policy helps to establish communication as a normal organizational function and
to present it as an opportunity rather than a burden or threat. The policy can be
incorporated in an organization's policies, an approach taken by many companies
who belong to the Responsible Care program of the Chemical Manufacturers
Association (CMA). These companies have adopted CMA's Codes of Management
Practices, which contain risk communication principles and practices.
"' | ' ' '''!'"
Remember that what you communicate is more important than the type of
communication policy or program you use, and what you actually do to maintain a
safe facility is more important than anything you say. Your company's safety and
prevention steps in your risk management program should serve as the core elements
of any risk communication program.
ASSIGN RESPONSIBILITIES AND RESOURCES
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A policy is only a paper promise until it is regularly and effectively implemented.
Thus, you should follow up your communication policy by (1) having top
management participate at the outset and at key points throughout the
communication process, and (2) assigning communication responsibilities within
your organization and providing the necessary resources.
Experience has demonstrated that assigning responsibility to knowledgeable
managers, plant engineers, and staff and encouraging participation by employees,
(most of whom are likely to be community residents) is a good communications
practice. Delegating communication functions to outside technical consultants,
attorneys, and public relations specialists has repeatedly failed to impress the
community and even tends to incur mistrust. (However, if you hired a firm with
acknowledged expertise in dispersion modeling, you may want them on hand to help
respond to technical questions.)
Communications 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.
,. 't, . : •• „ .] :• <:Yi) i •' . "•• ' " ;,"; :viK *:>£' » iir ,:i> . ' • .,, .•;,"; • • ">.•'• *•'••'' ii.;
Organizations have a legitimate interest hi preventing disclosure of confidential
business information or statements that inadvertently and unfairly harm the
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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
4- Enlist employee support for, and involvement in, the communication
process. ;
4- Build on work you have done with your LEPC, fire department, and local
officials, and gain their insights.
4- Incorporate technical expertise, management commitment., and employee
involvement in the risk communication process.
4- Use your RMP's executive summary to begin the dialogue with the
community; be sure you have taken all oif 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
4- 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.
4- 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
Other Steps
4- Identify the most likely concerns about risks identified in the RMP but not
fully addressed, consult with management and safely engineering, and
determine additional measures the organization will take to resolve these
"••' ": ;•'!: • ,' concerns. . ', . . ,, , 'I ' „ "
4- Avoid misrepresentations and minimize the roles of public relations
specialists.
4- Identify "best communication practices" (as described in the next section)
and plan how to use them.
USE "BEST COMMUNICATION PRACTICES"
Many facilities akeady have gained considerable experience in communicating with
the public. Lessons from their experiences are described below. However, the value
of these best practices and your credibility will depend on your facility's possession
and ongoing demonstration of certain essential qualities:
+ Top management commitment (e.g., owner and facility manager) to
improving safety
4- Honesty, openness, and concern for the community
4- Respect for public concerns and perceptions
4- Commitment to maintaining a dialogue with all sectors of the community, to
learning from this dialogue, and to being prepared to change your practices
to make your facility more safe
4- Commitment to continuous improvement through internal procedures for
evaluating incidents and promoting organizational learning
4 Knowledge of safety issues and safety management methods
a "i v '•.. i, v" ,. ;:;]M :; '•: " ••• ;;i;,;-\ ,,j ;.'&£' .. i;i;,| •;!,; .. ••, •; "% ,,'f '"^
4- Good working relationships with the LEPC, fire department, and other local
officials
4- Active support for the LEPC and related activities
4- Employee support and commitment
4- Continuation of commitment despite potential public hostility or mistrust
Another note: Because each facility and community involves a unique combination
of factors, the practices used to achieve good risk communication in one case do not
necessarily ensure the same quality result when used in another case. Therefore,
,<;':" '!'
July 1998
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11-17
Chapter 11
Communication with the Public
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 hi 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: :
4- 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.
4- Arrange meetings with local media representatives to facilitate their
understanding of your risk management program and the program summary
presented in your RMP.
4- Establish a repository of information on safely 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 hi the
community library or fire department.
Other, more resource-intensive activities of this type to consider include the
following: :
4- 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).
4- 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.
4- 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.
4- 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.
July 1998
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Chapter 11
Communicatioii with the Public
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 mat 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:
4- Arrange facility tours so that members of the public can view operations and
discuss safety procedures with supervisors and employees.
,' •' :", ". '" i : 5 {, •'••' si ..•i."i;'i ' 5 is; ; " '( ! | 'i_ •' i i ' 'P ' - • • j
4- 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).
. "."" " : : v'""^i :v":::' ,;: i; !':'' • :; •" . " • ">
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.
,!' , | - : , - I "'III ........ !'" !' ' II ! L , ,„','.
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.
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.
4 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.
My 1998
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11-19
Chapter 11
Communication with the Public
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,
B.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
My 1998
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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/Superfund/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/SuperfundyRCRA/CAA Hotline
July 1998
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Appendix A
40 CFR part 63
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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-startup1 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
68.150 Submission.
68.151 Assertion !of claims of confidential
business information.
68.152 Substantiating claims of confidential
business information.
68.155 Executive summary.
68.160 Registration.
68.165 Offsite consequence analysis.
68.168 Five-year accident history.
68.170 Prevention program/Program 2.
68.175 Prevention program/Program 3.
68.180 Emergency response program.
68.185 Certification.
68.190 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
-------
I
Environmental Protection Agency
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 State accidental re-
lease prevention programs approved
under section 112(r). The list of sub-
stances, threshold quantities, and acci-
dent prevention regulations promul-
gaiSd under this part do not limit in
any way the general duty provisions
under section 112(r)(l).
r If !', " ';!!' idl " , , 1U lijii ' !' ' , ' ' ' 'I
§68.2 Stayed provisions.
(a) Notwithstanding any other provi-
sion of this part, the effectiveness of
the following provisions is stayed from
March 2, 1994 to December 22, 1997.
(U In Sec. 68.3, the definition of ' 'sta-
tionary source," to the extent that
such" definition includes naturally oc-
curring hydrocarbon reservoirs or
f:» transportation subject to oversight or
regulation under a state natural gas or
hazardous liquid program for which the
E'state has in effect a certificatipn 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-
Jij: lateS 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
that 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
I for the Identification of the Fire Haz-
ards of Materials, National Fire Pro-
tection Association, Quincy, MA, 1990,
available from the National Fire Pro-
§68.2
tection Association, 1 Batterymarch
Park, guincy, 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
hydro-treating, 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
-------
§68.3
(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 et seq.)
Administrative controls mean written
procedural mechanisms used for hazard
control.
Administrator means the adminis-
trator of the U,S Environmental Pro-
tection Agenr\
AIChE/CCPS mean-, the American In-
stitute of Chemical I ripmeers/Center
for Chemical Prcx ess S«»frtv
API means t h, Arni-ncan Petroleum
Institute.
Article means ,< m.iriul«irtured item,
as defined under 2
-------
iff
Environmental Protection Agency
vjll'1, ' ,vi „ ' "" ; ' '' ;|
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
hospitalization.
Major change means introduction of a
new process, process equipment, or reg-
ulated substance, an alteration of proc-
ess chemistry that results in any
change to safe operating limits, or
other alteration that introduces a new
' hazard.
Mechanical integrity means the proc-
ess of 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-
ture or control substances upon loss of
containment to minimize exposure of
the gublic or the environment. Passive
mitigation means equipment, devices,
or technologies that function without
human, mechanical, or other energy
|nput. Active mitigation means equip-
ineni:, devices, or technologies that
need human, mechanical, or other en-
ergy input to function.
NAICS means North American Indus-
try Classification System.
' NFPA means the National Fire Pro-
tection Association.
Natural gas processing plant (gas plant)
means any processing site engaged in
the extraction of natural gas liquids
from field gas, fractionation of mixed
natuf-al gas liquids to natural gas prod-
; ucts," or both, classified as North Amer-
ican Industrial Classification System
(NAJCS) 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
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 Eire
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 offsite 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
-------
§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
-------
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-
lowing conditions is met:
(1) The process is in NAICS code
322il, 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 ("DCS") source, as defined in 40
CFR55.2.
[61 FR 31717. June 20. 1996. as amended at 63
FR 645, 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 pan shall submit a single
RMP, as pro\ided in §$68.150 to 68.185.
The RMP shall include a registration
that reflects all covered processes.
(b) Program 1 requirements. In addi-
i tion to meeting the requirements of
paragraph (a) of this section, the owner
or operator of a stationary source with
a process eligible for Program 1, as pro-
vided in §68,10(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 or flammable endpoint de-
fined in §68.22(a); and submit in the
RMP the worst-case release scenario as
r provided in §68.165;
(2) Complete the five-year accident
history for the process as provided in
§68.42 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 process(es)
has (have) had no accidental release
that caused offsite impacts provided in
the risk management program rule (40
CFR 68.10(b)(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 Prpgram 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-
esses.
§68.22 OiEfsite 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) Flarnmables. 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.
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Environmental Protection Agency
(e) Surface roughness. The owner or
opeirator shall use either urban or rural
topography, as appropriate. Urban
means 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:
(1) 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-
point 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
an 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-
essat the stationary source potentially
affects public receptors different from
; those potentially affected by the worst-
§68.25
• • , ' , I ::",' ;' 'i: :„ , • „ •.'
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. (1) 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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§68.25
40 CFR Ch. 1 (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.
44
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r i -:::1
iiir 'I :
Environmental Protection Agency
(g) Parameters to be applied. The
owner or operator shall use the param-
eters; defined in §68.22 to determine dis-
tance 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-
try as 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 to 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-
jnarfq. Notwithstanding the provisions
of paragraph (b) of this section, the
Swrier"or operator shall select as the
SyorsJ case for flammable regulated
substances or the worst case for regu-
lated toxic substances, a scenario based
on the following factors if such a sce-
nario would result in a greater distance
to an endpoint defined in §68.22(a) be-
yond the stationary source boundary
than the scenario provided under para-
graph (b) of this section:
(1) Smaller quantities handled at
higher process temperature or pres-
spre; and
(2) Proximity to the boundary of the
/stationary source.
[61 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 cpvere.d process(es) and
"at least one alternative release sce-
nario to represent all flammable sub-
stances held in covered processes.
§68.28
(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 seledted 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;
(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 hif known.;, .and
(il) Operational or process changes
that resulted from investigation of the
release.
(c) Level of accuracy. Numerical esti-
mates may be provided to two signifi-
cant digits.
[61 FR 31718, June 20, 1996, as amended at 64
FR979. 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
i 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-
(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-
tices. 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.
(c) 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. j
§ 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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"t I
Environmental Protection Agency
appropriate response to each of the
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. 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,
or could reasonably have resulted in a
catastrophic release.
(b) An incident investigation shall be
Initiated as promptly as possible, but
Hot later than 48 hours following the
incident.
(c) A summary 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
iihe incident; and, , , , '
(5) Any recommendations resulting
from the investigation.
(d) The owner or operator shall
promptly address and resolve the inves-
tigation findings and recommenda-
tions. Resolutions and corrective ac-
;ilons shall be .documented.
(e) The findings shall be reviewed
with all affected personnel whose job
tasks are affected by the findings.
(fj investigation summaries shall be
retained for five years.
Subpart D—Program 3 Prevention
Program
•SOURCE: 61 FR 31722, June 20, 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-
erating the process to identify and un-
derstand 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 the following:
(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;
(via) 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 tx1 conducted as soon
as possible, but no: later than June 21,
1999. Process hazards analyses com-
pleted to comply with 29 CFR
1910.119(e) arc 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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Sif!; ] i ill;! I' • : ! ' " TE 'i •«; ; 'tI i II1;1!1,:1! ill I!',' ' I'll1 '! "'' •' • '."• • i' •'.' ;i" •'"'!
'Fill If I iilll "4 1 " Ir I I!!1. •!, " , :'"f, iijili"1!!1. JUIllil , " ' ',
; i?:1 'Sir" • !'l' "I* ..' •' ' .' •'* g ' Vi "'n ,15 ' I!!;!"11!;':,' ', <: 'I!(" I1 i "ft' ' VS1™,"' •' f ii" if ;
-------
§68.73
40 CFR Ch. I (7-1-99 Edition)
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.
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
52
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.1 ;
Environmental Protection Agency
be informed of, and trained in, the
change prior to start-up of the process
"or affected part of the process.
(d) 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.
1 ,: IB ; P ,•;••' '„,< '. „ , B; '• " : i
§ 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
Ilii .lii i,HI ~ ,', i ,„!, ,i
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 th«- 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-
ancewith the provisions of this sub-
part at least every three years to
verify that procedures and practices
developed under this subpart are ade-
quate and 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
promptly determine and document an
appropriate response to each of the
§68.83
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
I :
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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 requirpd 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.
i
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 source1 whose employees will
not respond to accidental releases of
regulated substances need not comply
54
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Environmental Protection Agency
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,
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; and
(ili) Procedures and measures for
emergency response after an accidental
release of a regulated substance;
(2) Procedures for the use of emer-
gency response equipment and for its
iij! 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-
eesare informed of changes.
^:;;"I (SJ A written plan that "complies with
other Federal contingency plan regula-
tions or is consistent with the ap-
"iproach 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
section, shall satisfy the requirements
of this section if the owner or operator
§68.115
i i ' .
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
40 CFR Ch. I (7-1-99 Edition)
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-
mined in accordance with NFPA 30,
Flammable ai^d 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 prpducts for routine jani-
torial maintenance;
(iii) Use by employees of foods, drugs,
cosmetics, or other personal items con-
taining the regulated substance; and
56
-------
Environmental Protection Agency
(iv) Use of regulated substances
present in process water or non-contact
cooling water as drawn from the envi-
ronment or municipal sources, or use
of regulated substances present in air
used either as compressed air or as part
of combustion.
(5) Activities in laboratories. If a regu-
lated substance is manufactured, proc-
essed, or used in a laboratory at a sta-
tionary source under the supervision of
a technically qualified individual as de-
finep in §720.3(ee) of this chapter, the
quantity of the substance need not be
^considered in determining whether a
'"tiireshpld 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-
ations; and
(iii) Activities conducted outside the
laboratory.
[59 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
reasonably anticipated to cause death,
injury, or serious adverse effects to
: human health or the environment.
(c) A sui5stance may be deleted from
the list if adequate data on the health
and environmental effects of the sub-
stance are available to determine that
the substance, in the case of an acci-
dental release, is not known to cause
-anti may not be reasonably anticipated
to cause death, injury, or serious ad-
verse effects to human health or the
environment.
(d) No substance for which a national
..•L primary ambient air quality standard
has been established shall be added to
the list. No substance regulated under
title VI of the Clean Air Act, as amend-
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 (s) 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^) 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-
Propenal].
Acrylonitrile [2-
Propenenftrile].
Acrylyl chloride
[2-Propenoyl
chloride].
AHyl 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,
trichloro-].
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 disuffide
Chlorine
Chlorine dioxide
[Chlorine oxide
-------
Envirpnrnental Protection Agency
"-'I! i,, 'I',,!!!: • •: :, , i " ' •• .. '. )„ :! i
TABLE 1 TO §68.130.—LIST OF REGULATED
Toxic SUBSTANCES AND THRESHOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE PREVEN-
"2 TION—Continued " i ' i ,
[Alphabetical Order—77 Substances]
§68.130
•'" ' "i /'ii1: 'i'li .•., , ill; I*,/ I,' ,'.<'!,„* ' •:,/.•
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
Hydrogen chlo-
ride (anhy-
drous) [Hydro-
chloric add].
Hydrogen fluo-
11 :" ride/
Hydrofluoric
acid (cone 50%
or greater)
[Hydrofluoric
Hydrogen sele-
nxde.
Hydrogen suffide
Iron,
""' penticarbbhyl-
Pron carbonyi
(Fe(CO)5),
:: (TB-SMI)-).
Isobutyronitrile
: [Propanenitrile,
Isopropyl
chlbrbformate
[Carbonochlori-
dic acid, 1-
methylethyl
ester].
Mothacrylonitrile
> Propenenitrile,
2-methyf-].
, . Methyl chloride
[Methane,
. : chtoro-].
Methyl
" chfbroformate
,! ': [Carbonochlori-
:,; die acid,
: : methylestbr].
. Methyl hydrazine
, [Hydrazine,
methyl-].
Methyl isocyanate
[Methane,
'I.11: isocyanato-].
!l Methyl morcaptan
•< [Methanethiol],
.' i W8"1/!"'",
11 ' thiocyanate
i ! : fThlocyanic
!:•! acid, methyl
ester].
Methytlrichlorosil-
-I ' ano [Silane,
I,,; tricWoromethyl-
Nkkol carbonyi ...
ilNitric acid (cone
"' '"" 80% or greater).
, Nitric oxide [Nitro-
gen oxide
(NO)]-
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
S56-64-9
75-79-6
13463-39-3
7697-37-2
10102-43-9
Threshold
Quantity
(Ibs)'
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
Chemical name
Oleum (Fuming
Sulfuric acid)
[Sulfuric acid,
mixture with
sulfur trioxide]1.
Peracetlc acid
[Ethaneperoxoi-
c acid].
Perchloromethyl-
mercaptan
[Methanesulfe-
nyl chloride,
trichloro-].
Phosgene [Car-
bonic dichlo-
ride).
Phosphine
Phosphorus
oxychloride
[Phosphoryl
chloride].
Phosphorus tri-
chloride [Phos-
phorous tri-
chloride].
Piperidine
Propionitrile
[Propanenitrile].
Propyl
chloroformate
[Carbonochlori-
dic acid,
propylester].
Propyieneimine
[Aziridine, 2-
methyl-].
Propylene oxide
[Oxirane, meth-
yl-].
Sulfur dioxide
(anhydrous).
Sulfur tetra-
fluoride [Sulfur
fluoride (SF4),
(T-4)-].
Sulfur trioxide
Tetramethyllead
[Plumbane,
tetramethyi-].
Tetranitro-
methane [Meth-
ane, tetranitro-].
Titanium tetra-
chloride [Tita-
nium chloride
CTiCM) (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
7550-45-0
584-84-9
Threshold
quantity
(lbs)y
10,000
10,000
10,000
500
5,000
5,000
15,000
15,000
10,000
15,000
10,000
10,000
5,000
2,500
10,000
10,000
10,000
,,„,,. ,^0
10,000
Basis for
listing
e
b
b
a,b
b
b
b
b
b
b
b
b
a, b
b
a,b
b
b
b
a
„!
59
-------
§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-]1.
Toluene
diisocyanate
(unspecified
isomer) [Ben-
zene, 1 ,3-
diisocyanatom-
ethyl-]1.
Trimetnylchlorosi-
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.
;1 08-05-4
Threshold
quantity
(Ibs)
15,000
Basis for
listing
b
•"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 Toxicity of hydrogen chloride, potential to release hydro-
gen chloride, and history of accidents.
e Toxicity of sulfur trioxide and sulfuric 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.
50-00-0
57—14—7
60-34—4
67-66—3
74-87-3
74_gn_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
75-78-5
75-79-6
78-82-0
79-21-0
79-22-1
91-08-7
106-89-8
1 07-02-8
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
Methyl chloride [Methane, chloro-]
Tetramethyllead [Plumbane, tetramethyl-] ,
Methyltrichlorosilane [Silane, trichloromethyl-]
Crotonaldehyde, (E)- [2-Butenal (E)-] '.
trifluoro[oxybis[methane]]-, T-4-. ,
Threshold
quantity
(Ibs)
15,000
15,000
15,000
20,000
10,000
2 500
10,000
20,000
10,000
500
10 000
10,000
10,000
10000
5,000
5,000
20,000
10,000
5,000
10,000
20000
5000
10,000
10,000
20 000
20 000
15,000
5,000
15,000
15,000
15,000
15,000
5 000
15,000
20,000
10,000
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
-------
SB f
Environmental Protection Agency
§68.130
TABLE 2 TO §68.130.—LIST OF REGULATED Toxic SUBSTANCES AND THRESHOLD QUANTITIES FOR
ACCIDENTAL RELEASE PREVENTION—Continued
,'" ", [CAS Number Order—77 Substances] ''
CAS No.
5r^-77_4
509-14-8 ....
542-88-1
556-64-9
584-84-9
594-42-3
624-83-9
814-68-6
4170-30-3
7446-09-5
7446-11-9
7550-^45-0
7637-07-2 "i
7647-01-0 ,.
7647-01-0 ... «
7664-39-3 „..
7664^-41- 7
7664-41 7
7697-37-2
7719-12-2
7726-95-6
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 .
10025-87-3
10049-04-4
10102-43-9
1 10294-34-5 .
13463-39-3
13463-40-6
19287—45-7
26471-62-5 .....
Chemical name
Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1 -methyl-]1
Sulfur trioxide
Hydrogen fluoride/Hydrofluoric acid (cone 50% or greater) [Hydrofluoric acid]
Chlorine - .....
Sulfur tetrafluoride [Sulfur fluoride (SF4) (T-4)-l ,
Oleum (Fuming Su If uric acid) [Sutfuric acid, mixture with sulfur trioxide]1
Chlorine dioxide [Chlorine oxide (CIO2)]
N'rtric oxide [Nitrogen oxide (NO)]
Nickel carbonyl
Toluene diisocyanate (unspecified isomer) [Benzene, 1 ,3-diisocyanatomethyl-
Threshold
quantity
(Ibs)
10000
10,000
1 000
20000
10,000
10,000
10000
5 000
20 000
5 000
10,000
2500
5 000
15000
: s dob
1,000
10 000
20 000
15 000
15,000
10000
1 000
2,500
10 000
500
2500
15,000
1 000
5000
10,000
5000
1 000
10 000
5000
1,000
2500
2500
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
: '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 Toxteity of hydrogen chloride, potential to release hydrogen chloride, and history of accidents.
e Toxicity of sulfur trioxide and sulfuric acid, potential to release sulfur trioxide, and history of accidents.
TABLE 3 TO §68.130.—LIST OF REGULATED FLAMMABLE SUBSTANCES AND THRESHOLD QUANTITIES
FOR ACCIDENTAL RELEASE PREVENTION
[Alphabetical Order—63 Substances]
• Chemicai name
it lilii • • .' - '! „ •
Acataidehyde .
2-Butene-cis
2-ChtoroDroovlene f1-Prooene. 2-chloro-1
CAS No.
75-07-0
74-86-2
598-73-2
106-99-0
106-97-8
106-98-9
107-01-7
25167-67-3
590-18-1
624-64-6
463-58-1
7791-21-1
557-98-2
Threshold
quantity
!
-------
§68.130
40 CFR Ch. 1 (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
Cyanogen [Ethanedln'rtrile]
Dichiorosilane [Silane, dichloro-]
Difiuoroethane [Ethane, 1,1-difluoro-]
Dimethylamine [Methanamine, N-methyl-]
2,2-Dimethylpropane [Propane, 2,2-dimethyI-]
Ethane . ...
Ethyl acetylene [1-Butyne]
Ethylamine [Etnanamine] ..............
Ethyl chloride [Ethane, chloro-] „.
Ethylene [Ethene] .,
Ethyl ether [Ethane, t.V-oxybis-]
Ethyl mercaptan [Ethanethiol] ,,
Ethyl nitrite [Nitrous acid, ethyl ester]
Hydrogen
Isobutane [Propane, 2-methyl]
Isopentane [Butane, 2-methyl-]
Isoprene [1,3-Butadinene, 2-methyl-] ,
Isopropylamine [2-Propanamine]
Isopropyl chloride [Propane, 2-chloro-]
Methane ,
3-MethyM -butene
2-Methyl-l-butene
Methyl ether [Methane, oxybis-]
2-Methylpropene [1-Propene, 2-methyl-]
1 3-Pentadinene
Pentane . .
1-Pentene
2-Perrtene, (E)-
Propadiene [1 ,2-Propadiene]
Propane
Propylene [1-Propene] ,
Silane
Tetrafluoroethylene [Ethene, tetrafluoro-]
Tetramethylsilane [Silane, tetramethyl-] ,
Trichlorosilane [Silane, trichloro-]
Trifluorochloroethylene [Ethene, chlorotrifluoro-]
Trimethylamine [Methanamine, N,N-dimethy!-]
Vinyi acetylene [1-Buten-3-yne]
Vinyl chloride [Ethene, chloro-]
Vinyl ethyl ether [Ethene, ethoxy-] ,
Vinylidene chloride [Ethene, 1,1 -dichloro-]
Vinylidene fluoride [Ethene, 1,1-difluoro-]
Vinyl methyl ether [Ethene, methoxy-] ,
CAS No.
590—21-6
460—-J9-5
75—19-4
4109-96-0
75-37-6
1 124-^40-3
463-82-1
74-84-0
107-00-6
75_04_7
75-00-3
1 74-85-1
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
i 75-29-6
74-82-8
74-89-5
563—45-1
563-46-2
115-10-6
107-31-3
; 115-11-7
504-60-9
. 109-66-0
109-67—1
I 646-04-8
627 20-3
463-49-0
' 74-98-6
115-07-1
74—99-7
7803-62-5
• 116-14-3
1 75-76-3
10025-78-2
79-38-9
75-50-3
, 689-97-4
75-01-4
109-92-2
i 75-02-5
• 75-35-4
i 75-38-7
. 107-25-5
Threshold
quantity
(IDs)
10 000
10 000
10 000
10 000
10 000
10 000
10 000
10000
10000
10,000
10,000
10000
10 000
10000
10000
10000
10000
10000
10000
10000
10000
10000
10 000
10 000
10000
10,000
10 000
10000
10000
10 000
10 000
10000
10,000
10,000
10000
10 000
10 000
10000
10 000
10 000
10000
10 000
10000
10 000
10000
10 000
10 000
10000
10,000
Basis for
listing
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
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
74-82-8
74-84-0
74—85-1
Ethyl ether [Ethane,
Ethane
Ethylene [Ethene] ..
Chemical name
CAS No.
60-29-7
74-85-1
Threshold
quantity
(IDS)
10000
10,000
Basis for
listing
f
f
f
62
-------
I1!1
ilfi
ifc it?
Envir<
ronmental Protection Agency
§68.130
'TABLE 4 TO §68.130.—LIST OF REGULATED FLAMMABLE SUBSTANCES AND THRESHOLD QUANTITIES
':;::;' ! £;j , •'! FOR ACCIDENTAL RELEASE PREVENTION—Continued \ ^
[CAS Number Order—63 Substances]
, , CAS No.
74-86-2
74-89-5
l!''74_g§!!.'(5 '
74-99-7
75-OO-3
1 75-O1-4
* 75-02-5
!!; 1*" *W3 iT •••••-— ••——•"•
, 75-04-7
75-07-0
75-08-i
75-19-4
75-28-5
75-29-6 -
75-31-0 ..... ....
75-35-4
75-37-6 .... „...
75-50-3 .
75-76-3
78-78-4 .« «..
78—79-5
79-38-9 ..„ ,
106-97-8
106-98-9
107^-00-6
107-01—7
107-^5-5
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-^-2
563-45-1
, 563-46-2
590-21-6
598-73-2 ™
624-64-6 .
,. 627-20-3
'"64&-O4-8
689-97-4
: 1333- 74-0"
4109-96-0
7791-21—1
„. 7803-62-5
10025-78-2
;: 25167-67-3
Chemical name
Propyne [1 -Propyne]
Vinyl chloride [Ethene, chloro-] .
Acetaldehyde .
Cyclopropane
Isopropyi chloride [Propane, 2-chloro-]
Isopropylamine [2-Propanamine]
Vinylidene chloride [Ethene 1 1-dichloro-]
Drfluoroethane [Ethane, 1,1-dffluoro-]
Vinytidene fluoride [Ethene, 1,1-difluoro-]
Trimethylamine [Methanamine, N, N-dimethyl-j
Tetramethyteilane [Silane, tetramethyl-]
Trifluorochloroethylene [Ethene, chlorotrifluoro-]
1 -Butane
Ethyl acetylene [1-Butyne]
Methyl ether [Methane oxybis-]
1,3-Pentadiene
3-Methyl-1-butene „..,
2-Methyl-1-butene
2-Butene-cis ...
Bramotrifluorethylene [Ethene, bromotrifluoro-]
2-Butene-trans [2-Butene, (E)]
2-Pentene (E)-
Dichlorosilane [Silane, dichloro-]
Silane .... . ,
Butene
CAS No.
74-86-2
74-89-5
74-98-6
74-99-7
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
78-78-4
78-79-5
79-38-9
106-97-8
106-98-9
106-99-0
107-00-6
107-01-7
107-25-5
107-31-3
109-66-0
109-67-1
109-92-2
109-95-5
i 15-07-1
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
590-21-6
598-73-2
624-64-6
627-20-3
646-04-8
689-97-4
1333-74-0
4109-96-0
7791-21 1
7803-62-5
1 0025-78—2
25167-67-3
Threshold
quantity
10000
10000
10000
10,000
10000
10000
10000
10000
10 000
10000
10,000
1 0 000
10,000
10,000
10 000
10,000
10,000
10,000
10,000
10000
10000
10,000
10000
10000
10000
10000
10000
10 000
10,000
10000
10000
10 000
10 000
10,000
10 000
10 000
10000
10000
10000
10 000
10 000
10000
10 000
10000
10000
10,000
10000
10,000
10,000
10000
10000
10000
10000
10000
10,000
1 0 000
10 000
10000
10.000
Basis for
listing
f
f
f
f
f
a f
f
f
f
f
f
f
g
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
f
Note: Basis for Listing: a Mandated for listing by Congress. f Flammable gas. 9 Volatile flammable liquid.
[59 FR 4493, Jan. 31, 1994. Redesignated at 61 FR 31717, June 20, 1996, as amended at 62 FR 45132,
Aug. 25, 1997; 63 FR 645. Jan. 6, 1998]
63
-------
§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, J999]
§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
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Environmental Protection Agency
/ i
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
of the stationary source shall sign a
certification that the signer has per-
sonally examined the information sub-
mitted 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.
[64 FR 980, Jan. 6, 1999)
§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 emergency response policies at the
stationary source:
(b) The stationary source and regu-
lated substances handled;
(c) The worst-case release scenarip(s)
and |;he alternative release scenarip(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 emerpencN response program;
ii; 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
following data:
(1) Stationary source name, street,
city, county, state, zip code, latitude
and longitude, method for obtaining
latitude and longitude, and description
of location that latitude and longitude
represent;
(2) The stationary source Dun and
;,=Bradstreet number;
"I 'i'1.1
" ''" " §68.165
Jli '! III! ' '", M,i !l!i I ' ' '
(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 thresh-
old quantity in the process, the max-
imum quantity of each regulated sub-
stance or mixture in the process (in
pounds) to two significant 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 cndpoint:
(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. Juno 20. 1996. as amended at 64
FR 980, Jan. 6, 19991
§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 thejob; 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
-------
Environmental Protection Agency
§68.185
t v-
§68.175 Prevention program/Program
i ;_; 3.
(a) For each Program 3 process, the
"owner or operator shall provide the in-
formation indicated in paragraphs (b)
through (p) of this section. If the same
information applies to more than one
covered process, the owner or operator
may provide the information only
once, but shall indicate to which proc-
esses the information applies.
(b) The five- or six-digit NAICS code
that most closely corresponds to the
process.
(c) The name(s) of the substance(s)
"f covered.
(d)The date on which the safety in-
formation was last reviewed or revised.
(e) The date of completion of the
most recent PHA or update and the
technique used.
(1) The expected date of completion
of any changes resulting from the PHA;
(2) Major hazards identified;
(3) Process controls jn 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-
j-yiew^pr revision" of itraining programs;
(1) The type of training provided—
classroom, classroom plus on the job,
11 lli;i;on the job; and
(2) The type of competency testing
':""used".
(h) The date of the most recent re-
',;, j'^iew^pr revision, of maintenance proce-
dures and the date of the most recent
equipment inspection or test and the
equipment inspected or tested.
- ';_,",' (i) The i date of the :, most, , recent
; rchange" that" triggered management of
.""Change procedures and the date of the
^ i;uinostii recentreview or revision of man-
agerrient of change procedures.
(j) The date of the most recent pre-
startup review.
'",1, (%J The date of the most recent cpm-
pliance audit and the expected date of
completion of any changes resulting
from the compliance audit;
0) The date of the most recent inci-
dent investigation and the expected
date of completion of any changes re-
sulting from the investigation;
(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
-------
§68.190
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 sufapart D of this part.
40 CI=R Ch. I (7-1-99 Edition)
§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 source1 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
-------
If I'k" I
Mi!'!
'ii r
Environmental Protection Agency
The state may enter a written agree-
ment with the Administrator under
which EPA will implement and enforce
the requirements of paragraph (e) of
this section.
(e) The air permitting authority or
the agency designated by delegation or
agreement under paragraph (d) of this
section shall, at a minimum:
(1) Verify that the source owner or
operator has registered and submitted
an RMP or a revised plan when re-
quired by this part;
(2) Verify that the source owner or
ppeStbr has submitted a source cer-
tification or in its absence has sub-
mitted a compliance schedule con-
sistent with paragraph (a) (2) of this
section;
(3) For some or all of the sources sub-
ject to this section, use one or more
mechanisms such as, but not limited
to, a completeness check, source au-
dits,record reviews, or facility inspec-
tions to ensure that permitted sources
are" in compliance with the require-
ments of this part; and
(4) Initiate enforcement action based
on paragraphs (e)(l) and (e)(2) of this
section as appropriate.
!'§ 68.220 p Audits. ' ""'"'" ' '' "' ^
(a) In addition to inspections for the
purpose of regulatory development and
enforcement of the Act, the imple-
• jinenting agency shall periodically
;j| audit RMPs submitted under subpart G
"of this part to review the adequacy of
such RMPs and require revisions of
RMPs when necessary to ensure com-
pliance with subpart G of this part.
(b) The implementing agency shall
select stationary sources for audits
based on any of the following criteria:
(ij Accident history of the stationary
source;
(2) Accident history of other sta-
> tionary sources in the same industry;
(3) Quantity of regulated substances
present at the stationary source;
(4) Location of the stationary source
, and its proximity to the public and en-
vironmental receptors;
(S) The presence of specific regulated
substances;
(6) The hazards identified in the
RMP; and
"„, (7} A plan providing for neutral, ran-
dom oversight.
§68.220
'•'• * . ') ' . ' '• ". 'l' .•." •
(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
-------
§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 isubpart 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 jshall 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
-------
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-------
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-------
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-
Corn mercial-lnstitutionai 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 denned 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.
Toted inlet air is denned 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.ithe
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 i
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 the1
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 6560-5O-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
in. 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
-------
13244
Federal Register/Vol. 65, No. 49/Monday, March 13, 2000/Rules and Regulations
V. Rationale for Issuance of Rule Without
Prior Notice
YI. Summary of Revisions to Rule
yn. Administrative Requirements
I' ,« 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
1996 (SBREFA) 5 U.S.C. 601 et seq.
G. Paperwork Reduction Act
H. Unfunded Mandates Reform Act
I. National Technology Transfer and
Advancement Act
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
on August 5,1999. Section 2 of the Act
immediately removed EPA's authority
to "h'st a flammable substance when
used as, a fuel or held for sale as a fuel
at a retail facility * * * solely because
of the explosive or flammable properties
of the substance, unless a fire or
j explosion caused by the substance will
result in acute adverse health effects
from human exposure to the substance,
including the unburned fuel or its
combustion byproducts, other than
those caused by the heat of the fire or
impact of the explosion."
The Act defines "retail facility" as "a
stationary source at which more than
one-half of the income is obtained from
direct sales to end users or at which
more than one-half of the fuel sold, by
Volume, is sold through a cylinder
exchange 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 that pose the greatest risk to
public health and the environment in
the event.of an accidental release.
Section 112{r)(3J mandates that EPA
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 ccglain more .than a threshold i
quantity'of a regulated substance to
develop and implement a risk
management program and 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
on 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 flammability 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 the 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.
-------
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
i onsi-que-ntlv focused on those
t hiTiiiLals. u-ith the potential to result in
\ ,ipor 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 1
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, i
carbon monoxide, and relatively small
amounts of other oxidized inorganic
substances and do not meet the listing
criteria for toxic substances. Several i
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 L'se 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
Butene
2-Butene-cis
2-Butene-trans [2-Butene, (E)]
Ethane
Ethylene [Ethene]
Hydrogen
CAS No.
74-86-2
106-97-8
106-98-9
107-01-7
25167-67-3
590-18-1
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 1.—LIST OF COMMON FUELS—
* ':'". ' ".' C'ohlhuec!"
,,, .. Chemical name
Isobutana [Propane.
Isopentane [Butane,
2-melhyl-]
Pentane
1-Pentene
2-Pantene. (E\-
2-Pentene, (Z)-
Propyione
CAS No.
75-28-5
78-78-4
74-62-8
109-66-0
109-67-1
646-04-8
627-20-3
74_98-6
115-07-1
At the same time, all of the substances
listed aboye are sometimes used as
feedstock chemicals instead of fuel.
Further, every listed flammable
substance has the potential to be used
as fuel, since it may be burned to create
heat or power. Consequently, the List
Rule cannot be conformed to the new
law by deleting particular chemicals
from the flammable substances list.
Instead, EPA has added a provision to
part 68, Subpart F (listing regulated
substances) that excludes flammable
substances when used as a fuel, or held
for sale as a fuel at a retail facility from
the list of regulated substances. The
Agency has also annotated both versions
of the flammable substances list (one
version lists the substances
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
from the .list,
As previously mentioned, the Act
defines a "retail facility" as a stationary
source at which more than one-half of
the income is obtained from direct sales
:r to.end users.or,at which^more than one-.
half of the fuel sold, by volume, is sold
through a cylinder exchange program.
The income test portion of the
definition follows the definition of
"retail facility" used by the OSHA in
enforcing its PSM Standard (OSHA
Directiye.CPL2-2.45ACH-l-Process
Safety Management of Highly
Hazardous Chemicals—Compliance
Guidelines and Enforcement
Procedures): "an establishment that
would otherwise be subject to the PSM
standard at which more than half of the
income is obtained from direct sales to
end users."
The effect of the income test portion
of the new Act's retail facility definition
is to provide relief to the same facilities
that qualify for OSHA's retail facility
exemption, and conversely, to require
facilities that do not quality for OSHA's
exemption, and thus are subject 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
of small, commercial sources 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 are less likely 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
to 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.
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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 plaTming, 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 j
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, faculties 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 theur 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.
VL Summary of Revisions to Rule
This section summarizes the changes
to the rule.
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J3248 Federal Register/Vol. 65, No. 49/Monday, March 13, 2000/Rules and Regulations
I' •;'••': Section 68.3,"pefii4fioiiSji Has been
feviseoto add a definition of retail
facility, as denned in the new law.
Section 68.126 has been added to
create an exclusion for regulated
flammable substances used as fuel or
held for sale as fuel at retail facilities.
The exclusion is derived from the new
law.
In Section 68.130, footnotes have been
added to Tables 3 and 4. These two
tables list the regulated flammable
substances and their threshold
quantities. Table 3 lists the regulated
flammable substances in alphabetical
prder while Table 4 lists them in CAS
kumber order. The footnotes remind the
reader of the exclusion for regulated
flammable substances. The reference to
each footnote appears as an asterisk
follow|ng the term "flammable
substance" in the titles of Tables 3 and
"4. '
VEt. Administrative Requirements
A. Docket
l,il ' !l . lill ' . ,?! Pi.!! III"!!!!! 'II
II ' 'III!,'1 , i"! ' ; Fli' 1" „ itf I1 , . '
The docket is an organized and
complete file of all the information
considered by the EPA in the
development of this rulemaking. The
docket is a dynamic file, because it
allows members of the public and
industries involved to readily identify
and locate documents so that they can
effectively participate in the rulemaking
process. Along with the proposed and
promulgated rules and their preambles,
the contents of the docket serve as the
record in the case of judicial review.
(See section 307(d)(7)(A) of the CAA.)
The official record for this rulemaking
ha- been established under Docket A-
«'» 3<. and i«. available for inspection
truri. h Oil ti.rn. to 5:30 p.m., Monday
Uitoud, Friday, excluding legal
holidays, Jhe official rulemaking record
is. located at the address in ADDRESSES
\ i;*1'1'1 ' • 'B° ' ''' "' V1' ' '
at the beginning of this document.
B. Executive Order 12866
Under Executive Order 12866 (58 FR
51735, October 4,1993), the Agency
must Setermine whether the regulatory
action" is ''significant" arid therefore
subject to OMB review and the
requirements of the Executive Order.
The Order defines "significant
regulatory action" as one that is likely
, j, , , to result in a rule that may:
i (l) Have an annual effect on the
econo'my of S100 million or more or
adversely affect in a material way the
Gcontimy, a sector of the economy,
productivity, competition, jobs, the
environment, public health or safety, or
State, local, or tribal governments or
communities;
(2) Create a serious inconsistency or
otherwise interfere with an action taken
or planned by another agency;
(3) Materially alter the budgetary
impact of entitlements, grants, user fees,
or loan programs or the rights and
obligations of recipients thereof; or
(4J Raise novel legal or policy issues
arising out of legal mandates, the
President's priorities, or the principles
set forth in the Executive Order.
It has been determined that this rule
is not a "significant regulatory action"
under the terms of Executive Order
12866 and is therefore not subject to
OMB review.
C. Executive Order 13045
Executive Order 13045: "Protection of
Children from Environmental Health
Risks and Safety Risks," (62 FR 19885,
April 23,1997), applies to any rule that:
(1) Is determined to be "economically
significant" as defined under E.O.
12866, and (2) concerns an
environmental health or safety risk that
EPA has reason to believe may have a
disproportionate effect on children. If
the regulatory action meets both criteria,
the Agency must evaluate the
environmental health or safety effects of
the planned rule on children, and
explain why the planned regulation is
preferable to other potentially effective
and reasonably feasible alternatives
considered by the Agency.
EPA interprets E.O. 13045 as applying
only to those regulatory actions that are
based on health or safety risks, such that
the analysis required under Section 5—
501 of the Order has the potential to
influence the regulation.
This action is not subject to this
Executive Order because it is not
economically significant as defined in
E.O. 12866, and because it does not
establish an environmental standard
intended to mitigate healtibi or safety
risks.
D, Executive Order 13084
Under Executive Order 13084, EPA
may not issue a regulation that is not
required by statute, that significantly or
uniquely affects the communities of
Indian tribal governments, and that
imposes substantial direct compliance
costs on those communities, unless the
Federal government provides the funds
necessary to pay the direct compliance
costs incurred by the tribal
governments, or EPA consults with
those governments.
If EPA complies by consulting,
Executive Order 13084 requires EPA to
provide to the Office of Management
and Budget, in a separately identified
section of the preamble to the rule, a
description of the extent of EPA's prior
consultation with representatives of
affected tribal governments, a summary
of the nature of their concerns, and a
statement supporting the need to issue
the regulation. In addition, Executive
Order 13084 requires EPA to develop an
effective process permitting elected
officials and other representatives of
Indian tribal governments "to provide
meaningful and timely input in the
development of regulatory policies on
matters that significantly or uniquely
affect their communities."
Today's rule does not significantly or
uniquely affect the communities of
Indian tribal governments. This action
reduces burden on flammable fuel users,
which may include some sources owned
or operated by Indian tribal
governments. Accordingly, the
requirements of section 3(b) of
Executive Order 13084 do not apply to
this rule.
E. Executive Order 13132
Executive Order 13132, entitled
"Federalism" (64 FR 43255, August 10,
1999), requires EPA to develop an
accountable process to ensure
"meaningful and timely input by State
and local officials in the development of
regulatory policies that have federalism
implications." "Policies that have
federalism implications" is defined in
the Executive Order to include
regulations that have "substantial direct
effects on the States, on the relationship
between the national government and
the States, or on the distribution of
power and responsibilities among the
various levels of government."
Under Section 6 of Executive Order
13132, EPA may not issue a regulation
tiiat has federalism implications, that
imposes substantial direct compliance
costs, and that is not required by statute,
unless the Federal government provides
the funds necessary to pay the direct
compliance costs incurred by State and
local governments, or EPA consults with
State and local officials early in the
process of developing the proposed
regulation. EPA also may not issue a
regulation that has federalism
implications and that preempts State
law, unless the Agency consults with
State and local officials early in the
process of developing the proposed
regulation.
This final rule does not have
federalism implications. It will not have
substantial direct effects on the States,
on the relationship between the national
government and the States, or on the
distribution of power and
responsibilities among the various
levels of government, as specified in
Executive Order 13132. Today's rule
reduces the burden for those state, local,
i'jit1'! I
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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 the1
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 H 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 fined, 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 TV 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 etseq., 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.
-------
I ' 'I "i I ' • ;.•.!! t1,, ••:••; ?.*:'.!•$'itf;.1
13250 Federal Register/Vol. 65, No. 49/Monday, March 13, 2000/Rules and Regulations
KTKY(FM) to specify operation on
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 Scheuerle, Mass Media
Bureau, (202) 418-2180.
This action is not a ''major rule" as
defined by 5 U.S.C. 804(2). It takes effect
today.
List of Subjects in 40 CFRPart 68
Environmental protection, Chemicals,
Chemical accident prevention.
Dated: March 3, 2000.
§68.130 List of substances.
*****
TABLE 3 TO §68.130.—LIST OF REGU-
LATED FLAMMABLE SUBSTANCES 1
AND THRESHOLD QUANTITIES FOR
ACCIDENTAL RELEASE PREVENTION
[Alphabetical Order-63 Substances]
Administrator.
For the reasons stated in the
preamble, EPA amends 40 CFR part 68
as follows:
PART 68— lAMENDED]
1. The authority section for part 68 is
revised to read as follows:
Authority: 42 U.S.C 7412(r), 7601 (a) (1).
„ , , , , . , , ,
2. Section 68.3 is amended to add the
following definition in alphabetical
ofden
I:1!1 ": , ' ....... Ill, 'I" ' ,, , "11111,11 ..... I1 I!1,, I HI ..... I : '• 1 1;1
§68.3 Definitions.
'.;* ! ,'!',„: , ':",[, i, 'III .....
' §68.126 'Exclusion." ^ 'l'"\
Flammable Substances tlsed as Fuel
or Uriel for Sale as Fuel at Retail
Fncilitit'H. A flammable substance listed
HI 1 ahii-s a and 4 of § 68.130 is
iii'vcrthi'lt'ss excluded from all
provisions of this part when the
substance is used as a fuel or held for
sale as a fuel at a retail facility.
4. Section 68.130 is amended by:
A. Revising the heading of Table 3:
B, Revising the notes to Table 3 and
adding a new footnote 1;
C. Revising the heading to Table 4 ;
D. Revising the notes to table 4 and
adding a new footnote 1.
The revisions and additions read as
follows:
•
-------
Appendix B
Selected NAICS Codes
-------
-I
"„ "M1:,11!,' lit bill [I'll I" I,.i" Hill, i a,,:*" I:, „,' , ' I llilllF,,];1,, 111 HI1'; :';iiji|", i >th:,: ll: i! ' ,»h[.,. ill!
-------
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 Fanning
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 Fanning
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 $upply 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 Corn 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 Specially 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 Floiir Mixes and Dough Manufacturing from '
Purchased Flour
311823 Dry Pasta Manufacturing
31191 Snack Food Manufacturing
-------
Appendix B
NAICS Codes
B-2
311911 Roasted Nuts and Peanut Butter Manufacturing
31 1919 Other Snack Food Manufacturing
.....
31 193 Flavoring Syrup and Concentrate Manufacturing
311941 Mayonnaise, Dressing and Other Prepared
Sauce Manufacturing
31 1 99 1 Perishable Prepared Food Manufacturing
$1 1999 All Otter Miscellaneous Food Manufacturing
312 Beverage and Tobacco Product Manufacturing
312111 Soft Drink Manufacturing
312113 Ice Manufacturing
31212 Breweries
31213 Wineries
31214 Disffllenes ^ " ...... \
31222 Tobacco Product Manufacturing
313 Textile Mills ....................
313111 Yarn Spinning Mills
31323 Nonwoven Fabric Mills
31324 Knit Fabric Mills
313241 Weft Knit Fabric Mills
31331 Textile and Fabric Finishing Mills
313311 Broadwoven Fabric Finishing Mills
314 Textile Product Mills
31411 Carpet and Rug Mills
31499 All Other Textile Product Mills
314992 Tire Cord and Tire Fabric Mills
3 14999 All Other Miscellaneous Textile Product Mills
315 Apparel Manufacturing
315 111 Sheer Hosiery Mills
3 1 522 Men's and Boys' Cut and Sew Apparel
A ' ' 'I ,. ' '" .' ' !' ' llilMl ,!"'!, I1!1, ,i,| , ' ,'h'il! 1 !'•' , , , • ' i,
321 Wood Product Manufacturing
32 121 9 Reconstituted Wood Product Manufacturing
322 Paper Manufacturing
32211 Pulp Mills
32212 Paper Mills
222121 Paper (except Newsprint) Mills
322122 Newsprint Mills
32213 Paperboard Mills
323 Printing and Related Support Activities
323 1 1 1 Commercial Gravure Printing
'J23117 ' pook Printing ^
''3231 19 ' oth'er Commercial Printing
324 Petroleum and Coal Products Manufacturing
3241 1 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 Industrial Gas Manufacturing
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 Gum and Wood Chemical Manufacturing
325192 Cyclic Crude and Intermediate Manufacturing
325193 Ethyl Alcohol Manufacturing
325199 All Other Basic Organic Chemical
Manufacturing
3252 Resin, Synthetic Rubber, and Artificial and
Synthetic Fibers and Filaments Manufacturing
32521 Resin and Synthetic Rubber Manufacturing
325211 Plastics Material and Resin Manufacturing
325212 Synthetic Rubber Manufacturing
32522 Artificial and Synthetic Fibers and Filaments
Manufacturing
325221 Cellulosic Organic 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 Pharmaceutical and Medicine Manufacturing
325411 Medicinal and Botanical 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 Film 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
327111 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
331491 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 Ndnferrous (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
3 32211 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
-------
Appendix B
NAICS Codes
B-4
I" f\\ : ' ' 1 I', I, I
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
332813 Electroplating, Plating, Polishing, Anodizing
•and Coloring
332912 Fluid Power Valve and Hose Fitting
Ifiii'1'',1 • „ ' " Manufacturing
332919 Other Metal Valve and Pipe Fitting
-;; •. M 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 Lavra 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
333319 Other Commercial and Service Industry
Machinery Manufacturing
333415 Air^Conditioning and Warm Air Heating
Equipment and Commercial and Industrial
in i ' Refrigeration Equipment Manufacturing
33351 Metalworking Machinery Manufacturing
333511 Industrial Mold Manufacturing
333512 Machine Tool (Metal Cutting Types)
; Manufacturing
333515 Cutting Tool and Machine Tool Accessory
!".•• •|l • Manufacturing
333611 Turbine and Turbine Generator Set Unit
•• • M'amrracturing
333613 Mechanical Power Transmission Equipment
„ Manufacturing
333618 Other Engine Equipment Manufacturing
333911 Pump and Pumping Equipment Manufacturing
333924 Industrial Truck, Tractor, Trailer and Stacker
IV , , . '" ! Machinery Manufacturing
333995 Fluid Power Cylinder and Acmator Manufacturing
333996 Fluid Power Pump and Motor Manufacturing
333999 All Other Miscellaneous General Purpose
Machinery Manufacturing
334 Computer and Electronic Product Manufacturing
. ,|
33411
Computer and Peripheral Equipment
Manufacturing
334111 Electronic Computer Manufacturing
334112 Computer Storage Device Manufacturing
334113 Computer Terminal Manufacturing
334119 Other Computer Peripheral Equipment
Manufacturing
33422 Radio and Television Broadcasting and Wireless
Communications Equipment Manufacturing
33441 Semiconductor and Other Electronic Component
Manufacturing
334411 Electron Tube Manufacturing
334412 Bare Printed Circuit Board Manufacturing
334413 Semiconductor and Related Device
Manufacturing
334414 Electronic Capacitor Manufacturing
334415 Electronic Resistor Manufacturing
334416 Electronic Coil, Transformer, and Other
Inductor Manufacturing
334417 Electronic Connector Manufacturing
334418 Printed Circuit Assembly (Electronic
Assembly) Manufacturing
334419 Other Electronic Component Manufacturing
334519 Other Measuring and 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
33531 Electrical Equipment Manufacturing
335311 Power, Distribution and Specialty Transformer
Manufacturing
335312 Motor and Generator Manufacturing
33591 Battery Manufacturing
335911 Storage Battery Manufacturing
335912 Primary Battery Manufacturing
335921 Fiber Optic Cable Manufacturing
33599 All Other Electrical Equipment and
Component Manufacturing
335991 Carbon and Graphite Product Manufacturing
335999 All Other Miscellaneous Electrical Equipment
and Component Manufacturing
336 Transportation Equipment Manufacturing
33611 Automobile and Light Duty Motor Vehicle
• i|ii"i||pin,i,iiiii||iiiiiiiii 'ii'iiilhh,!^
-------
B-5
Appendix B
NAICS Codes
Manufacturing
336111 Automobile Manufacturing
336112 Light Truck and Utility Vehicle Manufacturing
33612 Heavy Duty Track Manufacturing
33621 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
336321 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 Pans Manufacturing
336391 Motor Vehicle Air-Conditioning Manufacturing
336399 All Other Motor Vehicle Pans Manufacturing
33641 Aerospace Product and Pans Manufacturing
336411 Aircraft Manufacturing
336412 Aircraft Engine and Engine Pans Manufacturing
336413 Other Aircraft Pan and Auxiliar> Equipment
Manufacturing
- >t>4 14 Guided Missile and Space \ chick-
Manufacturing
•'— ; - Guided Missile and Space \ chick- Propulsion
Unit and Propulsion I m: f'jrix Manufacturing
.-.M>4 19 Other Guided Missik- and Space \ chicle 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 Pans 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
339914
33999 1
3372 1 1 Wood Office Furniture Manufacturing
339 Miscellaneous Manufacturing
3391 1 Medical Equipment and Supplies Manufacturing
3391 12 Surgical and Medical Instrument Manufacturing
3391 13 Surgical Appliance and Supplies Manufacturing
3391 14 Dental Equipment and Supplies Manufacturing
3399 Other Miscellaneous Manufacturing
33991 Jewelry and Silverware Manufacturing
3399 1 1 Jewelry (except Costume) Manufacturing
3399 12 Silverware and Plated Ware Manufacturing
339913 Jewelers' Material and Lapidary Work
Manufacturing
Costume Jewelry and Novelty Manufacturing
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
42 1 8 1 Construction and Mining Machinery
42184 Industrial Supplies
422 Wholesale Trade, Nondurable Goods
4221 1 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
4225 1 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
4227 1 Petroleum Bulk Stations and Terminals
42272 Petroleum and Petroleum Products Wholesalers
(except Bulk Stations and Terminals)
4228 1 Beer and Ale Wholesalers
42282 Wine and Distilled Alcoholic Beverage
'Wholesalers
4229 Miscellaneous Nondurable Goods Wholesalers
4229 1 Farm Supplies Wholesalers
42299 Other Miscellaneous Nondurable Goods
-------
JCS Codes
B-6
!:•>:
'Hi
44-45 Detail, Trade ........................
4411 Autpmobline Dealers ......
' S229lwln3bw Treatment Stores
4441 Building Material and Supplies Dealers
44422 Nursery and Garden Centers
445 11 Grocery Stores
44523 Fruit and Vegetable Markets
§471 1 Gasoline Stations
45291 Warehouse Clubs and Superstores
45399 All Other Miscellaneous Store Retailers
48-49 Transportation and Warehousing
488 Support Activities for Transportation
4821 1 Rail Transportation
4831 1 Water Transportation
4842 Specialized Freight Trucking
48511 Urban. Transit, Systems
486 Pipeline Transportation
48811 Airport Operations
488 1 1 9 Other Airport Operations
48819 Other Support Activities for Air Transportation
48821 Support Activities for Rail Transportation
48832 Marine Cargo Handling
48839 Other Support Activities for Water Transportation
493 Warehousing and Storage
493 1 1 General Warehousing and Storage
493 1 2 Refrigerated Warehousing and Storage
49313 Farm Product Warehousing and Storage
493 1 9 Other Warehousing and Storage
54 Professional, Scientific, and Technical Services
54138 Testing Labs
54171 Research and Development in the Physical,
Engineering, and Life Sciences
56 Administrative and Support , Waste Management
and Remediation Services
61 Educational Services
6111 Elementary and Secondary Schools
61131 Colleges, Universities, Professional Schools
62 Health Care and Social Assistance
62151 Medical and Diagnostic Laboratories
621511 Medical Laboratories
62211 General Medical and Surgical Hospitals
6222 Psychiatric and Substance Abuse Hospitals
62221 Psychiatric and Substance Abuse Hospitals
6223 Specialty (except Psychiatric and Substance
Abuse) Hospitals
62231 Specialty (except Psychiatric and Substance
Abuse) Hospitals
'§6 ifp'dther Servicestb' Buildings
56221 Waste Treatment and Disposal
5622 1 1 Hazardous Waste Treatment and Disposal
562212 Solid Waste Landfill
562213 Solid Waste Combustors and Incinerators
562219 Other Nonhazardous Waste : Treatment and
::::;: 1' , . „' Disposal
5629 Remediation and Other Waste Management
jji,,, , .. ^Services!' ~' ..... ",| „ ..
•562^1 Remediation Services ..........
36292 ' "Materials Recovery Facilities
"56259 'All' Other Waste Management Services
562998 All Other Miscellaneous Waste Management
" ' '" Services
-------
THIS PAGE INTENTIONALLY LEFT BLANK
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,;,!'!!!" I , :''Hi! / Hi' '
I: -, '
-------
APPENDIX C: TECHNICAL ASSISTANCE
This appendix outlines the resources that are available to warehousing facilities in
complying with 40 CFR part 68, organized by the group providing the assistance.
U.S. ENVIRONMENTAL PROTECTION AGENCY
EPA's Chemical Emergency Preparedness and Prevention Office (CEPPO)
administers the RMP program at the national level.
Street Address:
Phone Number:
WWW Address:
1200 Pennsylvania Ave, NW (Mailcode 5104)
Washington, DC 20460
(202) 260-8600
www.epa.gov/ceppo/
The CEPPO homepage on the Internet provides access to downloadable versions of
numerous risk management program documents, including factsheets, questions and
answer documents, the list of regulated substances and thresholds, the text of the
regulatory requirements, general and industry-specific guidance, risk
communication, and RMP data elements and instructions. It also has links to sources
of Material Safety Data Sheets and other hazardous chemical information, as well as
up-to-date lists of LEPCs and SERCs.
If you do not have Internet access, these documents can be ordered from EPA's
EPCRA/Superfund/RCRA/CAA Hotline. In addition, the Hotline responds to
factual questions on a variety of federal EPA regulations, including those developed
under Clean Air Act section 112(r).
Phone Number:
E-Mail:
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
epahotline@bah.com
i
The Clean Air Act Amendments of 1990 requires that all States develop a program
to assist small businesses in meeting the requirements of the Act. EPA has
established its own Small Business Assistance Program (SBAP) to provide technical
assistance to these State small business programs.'The SBAP Internet site at
www.epa.gov/ttn/sbap was developed to allow State and EPA programs to share
information about their small business assistance materials and activities.
May 8, 2000
-------
Appendix C
Technical Assistance
C-2
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. In about half
of the states, OSHA programs are run by state agencies. For specific points of
contact for OSHA regional offices, OSHA state consultative programs, and OSHA
state plan states, see the OSHA web site.
OSHA Process Safety Management Homepage
www.osha-slc.gov/SLTC/processsafet^^
:% ;|! • ''••VF/iS/::.'•( ^:S;i-'.vv!^''S^ f':, ,' ^''"••"•X' I'll I'
The PSM homepage on the internet provides access to downloadable versions of
numerous process safety management documents.
The OSHA Publications Office provides single copies of various documents related
to risk management, process safety, accident prevention, and emergency planning
and response.
Street Address:
Phone Number:
WWW Address:
U.S. Department of Labor
RqomNSlOl
2QQ Constitution Avenue, NW
Washington, DC 20210
(202) 523-9667
www.osha.gov
The OSHA Computerized Information System at www.osha-slc.gov/ provides
downloadable versions of OSHA Standards and related documents, including OSHA
Regulations, Federal Register notices, Interpretations and Compliance Letters,
OSHA Regulations (preambles to final rules), and OSHA Directives and Fact Sheets.
OSHA also publishes a quarterly CD-ROM with all of this information, available for
Windows and Macintosh computers from:
U.S. Government Printing Office
Stock # 729-013-00000-5
Phpne: (202) 5l2-f 800
Fax: (202)512-2250
Price: $38/year (four quarterly releases), $15 (single copy)
. , i
' • , i • . i, i ,,ii if I. , , n j M , i| ,, i i , i i i I.
OSHA's Small Business Outreach Training Program has prepared an
Instructional Guide on various topics in occupational safety and health, designed to
provide ideas and organizational assistance to an instructor who wishes to present
these topics, which specifically focus on the needs of small business. The text of the
Guide is available at www.osha-slc.gov/SLTC/SmallBusiness.
May 8,2000
-------
C-3
Appendix C
Technical Assistance
Employers who take advantage of OSHA's Consultation Services 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. Targeted for smaller businesses, this safety and health
consultation program is completely separate from the OSHA inspection effort. For
more information, check in at www.osha.gov/oshprogs/consult.html.
AMERICAN INSTITUTE OF CHEMICAL ENGINEERS (AICHE)
Street Address:
Phone Number:
WWW Address:
345 E. 47th St. '•
New York, NY 10017-2395
(212) 705-7338
www.aiche.org/
AIChE and its Center for Chemical Process Safety publish a variety of documents
including a Continuing Education catalog for its educational and training programs
and an annual Publications Catalog from which documents can be purchased. They
are available from: !
AIChExpress Service Center
(800) AIC-HEME (242-4363) :
Monday - Friday, 9:00 am - 5:00 pm EST
E-Mail: xpress@aiche.org
Some of the specific documents available include:
i
Guidelines for Safe Storage and Handling of Highly Toxic Hazardous
Materials (119 pages) ',
Publication G-3
Order No. 0-8169-0400-6
Price: $65
Guidelines for Safe Warehousing of Chemicals (forthcoming)
Publication G-3 3 ;
Order No. 0-8169-0659-9
May 8, 2000
-------
Appendix C
l&* I! J- "- -: s
C-4
CHEMICAL MANUFACTURERS ASSOCIATION (CMA)
Street Address:
Phone Number:
WWW Address:
1300 Wilson Blvd.
Arlington, VA 22209
(703)741-5600
, f!,'!i ' ir . , <. n, • , ' ',,n • :
www.cmahq.com/
CMA documents, including those listed belowj are available from:
1 '" .' ' • 'i . ' . : i1 ' ,M,,, 11 •'., i i • .' . " n .
ii !" , i|. „: ,1" ' „:, '• ' HI!!, , ,ii! i,., " , ' „ • ,,' ' ,| •'.,,' M!'!I in !, 'I,,, i'i:" I ilJi i'."' I, i i" ' ','" ' ,
CMA Publications Fulfillment Office
341, Victory Drive
Herndon,VA 22070
Phone: (703)709-0166
CMA Responsible Care: Handling and Storage: Warehouse Assessment
Protocol
'
Community Awareness and Emergency Response (CAER) Code Resource
Guide
Order No. 024012
Price: $50 members, $75 non-members
Safe Warehousing of Chemicals
Order No. 022003
Price: $10 members, $15 non-members
' '" ' " ' ' ... ,,.„,, „ ... ' i ' ' '
CMA also maintains Chemtrec (Chemical Transportation Emergency Center) to
provide a centralized information and assistance center for individuals responding to
chemical emergencies and carriers of hazardous materials:
if ill ,:.i!v • .' • ':';, ''.••.'• '-,• •• "i;;:;i • ,:<;,•• : 'T|S: »• • ::'.>. as <-, '^;\\-.\ ] • i': • • •••>.'•-,
Emergency: (800) 424-9300
Npn-Emergency: (800) 262-8200
INTERNATIONAL WAREHOUSE LOGISTICS ASSOCIATION
Street Address:
Phone Number:
WWW address
1300 W. Higgins Rd., Ste. Ill
Park Ridge, EL 60068
(847)292-1891
www.warehouselogistics.org/
May 8,2000
I '
-------
C-5
Appendix C
Technical Assistance
NATIONAL ASSOCIATION OF CHEMICAL DISTRIBUTORS
Street Address:
Phone Number:
Fax Number:
WWW Address:
Chemical Educational Foundation
1525 Wilson Blvd., Ste. 750
Arlington, VA 22209
(703) 527-6223
(703) 527-7747 ;
www.nacd.com/
The Chemical Educational Foundation publishes an Educational Aids and
Training Catalog and a Product Stewardship Resource Guide. CEF has published
the following document related to risk management:
Making It Easy: Community Outreach Ideas and Examples
NACD Product Stewardship Bulletin #1: Chemical Use, Handling, Storage,
and Transportation
NACD Product Stewardship Bulletin #5: Employee Hazardous Materials
Safety Training
NACD Product Stewardship Bulletin #8: Risk Management Program
NATIONAL FIRE PROTECTION ASSOCIATION
Street Address: 1 Batterymarch Park
P.O. Box 9101
Quincy, MA 02269-9101
Phone Number:
Fax Number:
E-mail:
WWW Address:
(617) 770-3000
(617) 770-0700
library@NFPA.org.
www.nfpa.org/
NFPA publishes standards related to fire safety, prevention, training, planning, and
response that have been adopted as the official fire code in many states, as well as
guidance on how to implement its standards. The collection of NFPA Standards is
available at many libraries, but NFPA also publishes a bimonthly catalog of its
standards and fire safety products, which are available from:
May 8, 2000
-------
Appendix C
Technical Assistance
C-6
NFPA Fulfillment Center
11 Tracy Drive
Avon, MA 02322-9908
Plpie: (800) 344-3555
Monday - Friday, 8:30 am - 8:00 pm EST
Fax: (800) 593-NFPA (6372)
E-mail: custserv@NFPA.org.
, ,, , , , .. . : , ,, , ,Vii .,., _,. ' .,..,..,, .... „,,„.,I,iin . . ...^ .„, ... J
A listing of these products and subscription service information (as well as a Spanish
version of the catalog) is provided at the NFPA homepage.
SMALL BUSINESS ADMINISTRATION
Street Address:
Phone Number:
WWW Address:
409 Third Street, SW
Washington, DC 20416
(800) 827-5722
1 ,'!'•" r ! l!, i '' » ' '' ' '!'"• 'hull". ,. '
www.sba.gov/
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 mousands of lending, educational, and
training institutions nationwide.
' , »H ihllll i,:. 3
i/'i- till!"-,
I" i nf;i" ',i
i 'ji n ii' mi
May 8,2000
-------
APPENDIX D
OSHA GUIDANCE ON PSM
-------
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!ii.i>:;j IIS IIIIIIIK
-------
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. i
Process technology information will be a part of the process safely 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. i
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 flov^ 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&EDS) 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.
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Appendix D
OSHA Guidance on PSM
D-2
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The information pertaining to process equipment design must be documented. In other words, what were
the codes and standards relied on to establish good engrneering practice. These codes and standards are
published" "by''such''1brgar^ationsllaslltiiellAmericanuSlbciery of Mechanical Engineers, American Petroleum
Institute, American National Standards Institute, National Fire Protection Association, American Society
for Testing and Materials, National Board of Boiler and Pressure Vessel Inspectors, National Association
of Corrosion Engineers, American Society of Exchange Manufacturers Association, and model building
code groups. In addition, various engineering societies issue technical reports which impact process
design. For example, the American Institute of Chemical Engineers has published technical reports on
topics such as two phase flow for venting devices. This type of technically recognized report would
constitute good, engineering practice.
For existing equipment designed and constructed many years ago in accordance with the codes and
standards available at that time and no longer in general use today, the employer must document which
lodes an.d standards were used and that the design and construction along with the testing, inspection and
operation are still suitable for tiie intended use. Where the process technology requires a design which
popartsfrom me applicable codes and standards, the employer must document that the design and
construction is suitable for the intended purpose.
'»•« ' •" " ' " ' I I ' p'. • >•'• ' II .' ' ' t . * • .... , ;
PROCESS HAZARD ANALYSIS
A process hazard analysis (PHA), 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 in making decisions for improving safety and reducing the consequences of unwanted or
Unplanned releases of hazardous chemicals.
. .. . , , , :, I , . . ' .. 1
A PHA is directed toward analyzing potential causes and consequences of fires, explosions, releases of
tpxic 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 that might impact
the process. These considerations assist in determining the hazards and potential failure points or failure
modes in a process.
TJie selection of a PHA methodology or technique will be influenced by many factors including the
Imoiint 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
new 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 decision as to the appropriate PHA methodology to
use. All PHAI meffiodologies are subject to certain limitations. For example, the checklist methodology
Works well when the process is very stable and no changes are made, 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 PHA 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
'iururePHAl' ' ' ' " "" ' ' '"
-------
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 Operabiliry 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&IDS, 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
3/yhen the employer has a number of processes which require a PHA, the employer must set up a priority
system of which PHAs to conduct first. A preliminary or gross hazard analysis may be useful in
firioritizkig 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
^verity "of" a ''chemical release, me number of potentially affected employees, me 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
1 systematic ranking method. The use of a preliminary hazard analysis would assist an employer in
determining which process should be of the highest priority and thereby the employer would obtain the
greatest improvement in safety at the facility.
OPERATING PROCEDURES
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Operating procedures describe tasks to be performed, data to be recorded, operating conditions to be
maintained, samples to be collected, and safety and health precautions to be taken. The procedures need
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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
by engineering staff and operating personnel to ensure that they are accurate and provide practical
instructions on how to actually carry out job duties safely.
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
implications. For example, the operating procedures addressing operating parameters will contain
operating instructions about pressure limits, temperature ranges, flow rates, what to do when an upset
condition occurs, what alarms and instruments are pertinent if an upset condition occurs, and other
Mihiccis. Another example of using operating instructions to properly implement operating procedures is
it. Mjrting iip or shutting dou n the process. In these cases, different parameters will be required from
those of normal operation Those 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
fiprmaj 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.
Computerized process control systems add complexity to operating instructions. These operating
instructions need to describe the logic of the software as well as the relationship between the equipment
and the control system; otherwise, it may not be apparent to the operator.
Operating procedures and instructions are important for training operating personnel. The operating
procedures are often viewed as the standard operating practices (SOPs) for operations. Control room
personnel and operating staff, in general, need to have a full understanding of operating procedures. If
workers are not fluent hi English then procedures and instructions need to be prepared in a second
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language understood by the workers. In addition, operating procedures need to be changed when there is
a change in the process as a result of the management of change procedures. The consequences of
pperating procedure changes need to be fully evaluated and the information conveyed to the personnel.
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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 in 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 safely 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 familiarize
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 in 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-rthe-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 hi the training process and to practice their skill or
knowledge.
-------
Appendix D
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
Igethpds jfor eyaluating the training should be developed along with the training program goals and
gbjectives. Training program evaluation will help employers to determine the amount of training their
e|npioyees understood, and whether the desired results were obtained. If, after the evaluation, it appears
tfiat^e'trained employees "are not at the level of knowledge and skill that was expected, the employer
will need to revise the training program, provide retraining., or provide more frequent refresher training
fissions until thedeficiency is resolved. Those who conducted the training and those who received the
training should also be consulted as to how best to improve the training process. If there is a language
barrier, the language known to the trainees should be used to reinforce the training messages and
information.^ _ i
CJareful cpnsijleratipn must be given to assure that employees including maintenance and contract
Employees receive'cuirent 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 pertinent to their tasks). Additionally, as already discussed the
evaluation of the employee's absorption of training will certainly influence the need for training.
::..: ''"""" :"".' " ' ••••'• — >, •••-;. : •- r •••. .-••:; - • T •)" • - •
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
tised to process, store, or handle highly hazardous chemicals needs to be designed, constructed, installed
and maintained to minimise 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.
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Elements of a mechanical integrity program include the identification and categorization of equipment
"•S'fflll n... '<;':: riiiHl 'JIM1 In'1 , !" ^T, 4.f.. ,°^ , T? „ , i ..
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.
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' • 1 1
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
is the controlled release of chemicals through venting to scrubbers or flares, or to surge or overflow tanks
which are designed to receive such chemicals, etc. These lines of defense are the primary lines of
4efense 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
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Integrity program needs to protect and strengthen these primary and secondary lines of defenses where
appropriate.
• " • ' ' I ' •' '
The first step of an effective mechanical integrity program is to compile and categorize a list of process
equipment and instrumentation for inclusion in the program. This list would include pressure vessels,
Storage tanks, process piping, relief and vent systems, fire protection system components, emergency
shutdown systems and alarms and interlocks and pumps. For the categorization of histrumentation and
-------
; Appendix D
D-7 ; 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 hi 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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Appendix D
OSHA Guidance on PSM
D-8
MANAGEMENT OF CHANGE
To properly manage changes to process chemicals, technology, equipment and facilities, one must define
what is meant by change. In this process safety management standard, change includes all modifications
to equipment, procedures, raw materials and processing conditions other than "replacement in kind."
These changes need to be properly managed by identifying and reviewing them prior to implementation
of the change. For example, the operating procedures contain the operating parameters (pressure limits,
temperature ranges, flow rates, etc.) and the importance of operating within these limits. While the
operator must have the flexibility to maintain safe operation within the established parameters, any
operation outside of these parameters requires review and approval by a written management of change
procedure. Management of change covers changes in process technology and changes to equipment and
instrumentation. Changes in process technology can result from changes in production rates, raw
materials, experimentation, equipment unavailability, new equipment, new product development, change
iS catalyst and changes in operating conditions to improve yield or quality. Equipment changes include
grnpng o&ere'change' in materials' of construction^ equipment specilcafions, piping pre-arrangements,
experimental equipment, computer program revisions and changes in alarms and interlocks. Employers
need to establish means and methods to detect both technical changes and mechanical changes.
Temporary changes have caused a number of catastrophes over the years, and employers need to
establish ways to detect temporary changes as well as those that are permanent. It is important that a
time Hinit 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
addition, the management of change procedures are used to insure that the equipment and procedures are
returned to their 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. Employers may
Wish to develop a form or clearance sheet to facilitate the processing of changes through the management
of change procedures. A typical change form may include a description and the purpose of the change,
the technical basis for the change, safety and health considerations, documentation of changes for the
Derating procedures, maintenance procedures, inspection and testing, P&IDS, electrical classification,
training and communications, pre-startup inspection, 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
authorized person with proper communication to others who are affected may be sufficient.
However, for a more complex or significant design change, a hazard evaluation procedure with approvals
by operations, maintenance, and safety departments may be appropriate. Changes in documents such as
P&IDS, raw materials, operating procedures, mechanical integrity programs, electrical classifications,
etc., need to Be noted so that these revisions can be made permanent wnen the drawings and procedure
manuals are updated. Copies of process changes need to be kept in an accessible location to ensure that
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.
PRE-STARTUP REVIEW
For new processes, the employer will find a PHA helpful in improving the design and construction of the
process from a reliability and quality point of view. The safe operation of the new process will be
enhanced by making use of the PHA recommendations before final installations are completed. P&IDs
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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 in light of the
changes. Any incident investigation recommendations, compliance audits or PBA 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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Appendix D
OSHA Guidance on.PSM.
D-10
procedure and checklist 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
^afflpie, tideaudit team will review aU aspects of me training program as part of the overall audit. The
tiarn 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
standard's 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.
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.
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An audit is a technique used to gather sufficient facts and information, including statistical information,
to verify compliance with standards. Auditors should select as part of their preplanning a sample size
sufficient to give a degree of confidence that the audit reflects the level of compliance with the standard.
file "audit'team, through this systematic analysis, should document areas which require corrective action
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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
Delation ^£ 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
normally begins with a management review of the audit findings. The purpose of this review is to
dgjermine wEat actions are appropriate, and to establish priorities, timetables, resource allocations and
requirements and responsibilities. In some cases, corrective action may involve a simple change in
procedure or minor maintenance effort to remedy the concern. Management of change procedures need
fo be used, 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 control the corrective 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 mat have been through management of change, if appropriate, and then shared with
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
steris to prevent similar events from occurring. The intent of an incident investigation is for employers to
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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 then-
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 breakiag 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
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! ^ajl "affected ..employers. The use of a work authorization system keeps an employer informed 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
fiocess 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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