United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
(5104)
EPA550-B-98-010
October 1998
www.epa.gov/ceppoy
svEPA
RISK MANAGEMENT
PROGRAM GUIDANCE
FOR
WASTEWATER
TREATMENT PLANTS
(40 CFR PART 68)
Chemical Emergency Preparedness and Prevention Office
Printed on recycled paper
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This document provides guidance to help owners and operators of wastewater treatment plants to
determine if their processes are subject to chemical accident prevention regulation under section
112(r) of the Clean Ak 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 ckcumstances. EPA may change this guidance in the future, as
appropriate.
October 27, 1998
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October 27,1998
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TABLE OF CONTENTS
INTRODUCTION
CHAPTER 1 GENERAL APPLICABILITY ..'-. :
1.1 introduction 1-1
1.2 General Provisions 1-3
1.3 Regulated Substances and Thresholds 1-4
1.4 What is a Process • ,1-5
1.5 Threshold Quantity in a Process - 1-1
1.6 Stationary Source 1-17
1.7 When You Must Comply , . • • 1-18
CHAPTER 2 APPLICABILITYOF PROGRAM LEVELS
2.1 What Are Program Levels ' ,2-1
2.2 POTW Program Levels ' - 2-3
2.3 ; Program 1 . , 2-5
2.4 Quick Rules for Determining Program 1 Eligibility 2-11
2.5 Programs : 2-13
2.6 Program 2 2-14
2.7 Dealing with Program Levels 2-16
2.8 • Summary of Program Requirements , 2-18
CHAPTER 3 FIVE-YEAR ACCIDENT,HISTORY
3.1 What Accidents Must Be Reported 3-1
3.2 What Data Must Be Provided » , 3-1
3.3 Other Accident Reporting Requirements , 3-10
CHAPTER 4 OFFSITE CONSEQUENCE ANALYSIS . ''. ?
4.1 Worst-Case Release Scenarios 4-3
4.2 Alternative Release Scenarios 4-20
4.3 Buildings , .. ,_.' 4-40
4.4 Estimating Offsite Receptors 4-45
4.5. Documentation , - , " . < . 4-47
4.8 Symbols for Chapter 4 4-48
Appendix 4A Equations 4-59
Appendix 4B Limitations of Results 4-65
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'Ji
CHAPTERS MANAGEMENT SYSTEM •
'":« ' ! ift'ii!:1! ' j, ! 'Ill '",' ,. ' •„ li'-M !'' K. ! ,' :"!!!' • "I*! , " ">'•' ,•" , - '" »•' • ' ";.' > , ', " " ' *• * • . ,.i',; ,: . f -1!'1 • • ' '• i i "
5.1 General Information 5-1
5.2 How to Meet the Management System Requirements 5-
CHAPTER 6 PREVENTION PROGRAM (PROGRAM 2)
6.1 About the Program 2 Prevention Program 6-1
6.2 Safety Information (§ 68.48) 6-1
6:3 Hazard Review (§ 68.50) 6-9
6.4 Operating Procedures (§ 68.52) 6-14
6.5 ^Tbraipiing^(§ 68.54) 6-18
6.6 Maintenance (§ 68.56) • 6-21
6.7 Compliance Audits (§ 68.58) . 6-26
6.8 Incident Investigation (§ 68.60) 6-28
6,9 Conclusion 6-31
•Appendix 6A Checklists 6-33
> ' " . • ' •" '
CHAPTER? PREVENTION PROGRAM (PROGRAM 3)
7.1 Pjrevention. Prc^am 3 and OSHA PSM 7-1
7.2 Process Safety ^formation (§ 68.65) 7-3
7.3 "'''^c^.fezarS"AMiysis''(§ 68167) 7-7
7.4 Operating Procedures (§ 68.69) 7-10
7.5 "'iiai'niag(§ 68?7i) , 7-12
7.6 Mechanical Integrity (§ 68.73) 7-13
7.7 Management of'Change (§68.75) 7-17
7.8 Pre-Startup Review (§68.77) 7-18
7.9 Compliance Audits (§ 68.79) 7-19
7.10 Incident Investigation (§68.81) 7-20
7.11 Employee Participation (§ 68.83) . 7-21
7.12 Hot Work Permits (§68.85) 7-21
7.13 Contractors (§68.87) 7-2
Appendix 7-APHA Techniques ' 7-24
CHAPTERS EMERGENCY RESPONSE
i||l|" ' ' ' l|»i ! " , ',; ':, ,, i ' ' , , ' ' !
•• • • • • • ' ' • , i • •/ •:•••. ' ' . ,
8.1 Non-Responding Sources 8-1
8.2 Elements of an Emergency Response Program 8-3
8.3 Developing an Emergency Response Program 8-6
8.4 Integration of Existing Program 8-9
8.5 Have I Met Part 68 Requirements 8-11
Mi1'1 1!"!1, ill "' , . i ,:, "li, !' " "i „' „ ' ''.'I!. ' ^i ' , " ' , ' , ' i ' !, , • ' ' : • ' 'i «',',' _ , 'i . i •
October27,1998 , ' , , " .''.".,.', ' ' '.
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Ill
8.6 Coordination with Local Emergency Planning Committees
CHAPTER 9 RISK MANAGEMENT PLAN
\ , - * '''.'.• .... -
9.1 Elements of the RMP
9.2 . RMP Submission ;
9.3 Resubmission and Updates
CHAPTER 10 IMPLEMENTATION
10.1 Implementing Agency
10.2 Reviews/Audits/Inspections
10.3 Relationship with 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
8-16
9-1
9-2
9-3
10-
10-2
10-4
10-4
11-1
11-4
11-13
11-19
APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
APPENDIX F-
PART 68
Reserved
EPA REGIONAL CONTACTS
OSHA CONTACTS
TECHNICAL ASSISTANCE
OSHA GUIDANCE ON PSM
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IV
. . . .
LIST OF BOXES AND EXHIBITS
: " ' . " , .':,,. (I .............. ( ii,.''> '" •• • ' ' ' ' '
.....
• .., ...... „, , . - •
GUIDANCE
LIST OF EXHIBITS
CHAPTER 1
Exhibit 1-1
Exhibit 1-2
Exhibitl-3
Evaluate Facility to Identify Covered Processes
Process
Stationary Source
Exhibit 2-1
Exhibit 2:2
Exhibit2-3
Exhibit 2-4
Exhib!t2-5i
Exhibit 2-6 ........ :;
CHAPTERS
Exhibit 3-1
CHAPTER 4
Exhibit.4-1
^.Exhibit '4-2
Exhibit 4-3
Exhibit 4-4
Exhibit 4-5
al^;:'.ji,i'JExhibit,4r7
USfoJ.; Exhibit 4-8
•Exhibit 4-10
Exhibit 4-11
-;gxhibf4-12
Exhibit 4-13
Exhibit 4-14
Exhibit 4-15
Exhibit 4-16
Exhibit 4-17
Exhibit 4-18
Exhibit 4-19
Exhibit 4-20
Exhibil4-21
gxhibit 4-22
Evaluate Program Levels for Covered Processes
Federal OSHA States , '., ., .;.
States with Delegated OSHA Programs
Program Level Criteria
Develop Risk Management Program and RMP
Comparison of Program Requirements
Atmospheric Stability Classes
Steps for an Offsite Consequence Analysis
Required Parameters for Modeling '
Distances to Toxic Endpoint — Chlorine"
Distances to Toxic Endpoint for Chlorine
Distances to Toxic Endpoint — Sulfur Dioxide
Distances to Toxic Endpoint for Sulfur Dioxide
Distances to Toxic Endpoint for Anhydrous Ammonia Liquefied Under Pressure
Ratio of Vapor Pressure of Ammonia in 30% Aqueous Ammonia
Distances to Toxic Endpoint for Aqueous Ammonia
Distance to Overpressure Endpoint of 1 psi for Vapor Cloud Explosions of Methane
Distance to Overpressure Endpoint of 1 psi for Vapor Cloud Explosions of Propane
Distances to TOXIC 'Endpoint for Chlorine
Release Rates and Distance to the Endpoint for Liquid Chlorine Releases
Release Rates for Two-Phase Releases from Pipes Carrying Liquid Chlorine
Release Rates and Distance to the Endpoint for Chlorine Vapor Releases
Release Rates and Distance to the Endpoint for Liquid Sulfur Dioxide Releases
Distances to Toxic Endpeints for Sulfur Dioxide
Release Rates for Two-Phase Releases from Pipes Carrying Liquid Sulfur Dioxide
Release Rates and Distance to the Endpoint for Sulfur Dioxide Vapor Releases
Release Rates and Distance to the Endpoint for Liquid Ammonia Releases
Distances to Toxic Endpoint for Anhydrous Ammonia
Distances to Toxic Endpoint for Aqueous Ammonia
Exhibit 4-23 Distance to Overpressure Endpoint of 1 psi for Vapor Cloud Explosions of Propane
6«ober2?. 1998
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Exhibit 4-24
Exhibit 4-25
Exhibit 4-26
Exhibit 4-27
Exhibit 4-28
Figure 4-1
Figure 4-2
Figure 4-3
Figure 4-4
Figure 4-5
Figure 4-6
.Figure 4-7
Figure 4-8
Figure 4-9
Figure 4-10
CHAPTER 5
Exhibit 5-1
CHAPTER 6
.Exhibit 6-1
Exhibit 6-2
Exhibit 6-3
Exhibit 6-4
Exhibit 6-5
Exhibit 6-6
Exhibit 6-7 '
Exhibit 6-8
Exhibit 6-9
Exhibit 6-10
Exhibit 6-11
CHAPTER?
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
Distance at Which Exposure to a Propane BLEVE Could Lead to Second-Degree Burns
Neutrally Buoyant Plume Distances to LFL (rural)
Neutrally Buoyant Plume Distances to LFL (urban)
Ten-Minute Building Release Attenuation Factors for Prolonged Releases of Anhydrous
Ammonia v
Ten-Minute Building Release Attenuation Factors for Prolonged Releases of Chlorine and
Sulfur Dioxide -
Worst-Case Scenario — Predicted Distances to Toxic Endpoint for Chlorine
Worst-Case Scenario — Predicted Distances to Toxic Endpoint for Sulfur Dioxide
Worst-Case Scenario — Predicted Distances to Toxic Endpoint for Anhydrous Ammonia
Worst-Case Scenario —: Predicted Distances to Toxic Endpoint for Aqueous Ammonia
Alternative Case Scenario — Predicted Distances to Toxic Endpoint for Chlorine
Alternative Case Scenario — Predicted Distances to Toxic Endpoint for Sulfur Dioxide
Alternative Case Scenario — Predicted Distances to Toxic Endpoint for Anhydrous
Ammonia • ' ',
Alternative Case Scenario — Predicted Distances to Toxic Endpoint for Aqueous
Ammonia . ' ,
Guidance on Effectiveness of Building Mitigation for Alternative Scenarios
Simplified Presentation of Worst Case and Alternative Scenario on a Local Map
Sample Management Documentation
Summary of Program 2 Prevention Program
Safety Information Requirements -
Codes and Standards
Sample Safety Information Sheet
Hazard Review Requirements
Operating Procedures Requirements
Training Chart
Maintenance Guidelines
Sample Audit Checklist for Safety Information and Hazard Review
Incident Investigation Requirements
Sample Incident Investigation Format
Comparable EPA and OSHA Terms
Summary of Program 3 Prevention Program
Process Safety Information Requirements
Process Hazard Analysis Requirements
Operating Procedures Requirements
Mechanical Integrity Chart
Management of Change Requirements
Pre-startup Review Requirements
Incident Investigation Requirements
October 27, 1998 .
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VI
Exhibit 7-10 Employee Participation Requirements
Exhibit 7-11 Hot Work Permits Requirements
Exhibit 7-12 Contractors Chart
Exhibit 7a-l Applicability of PHA Techniques
Exhibit 7a-2 Time arid Staffing for PHA techniques
CHAPTERS i
Exhibit 8-1 Federal Guidance on Emergency Planning and Response
Exhibit 8-2 Federal Emergency Planning Regulations
Exhibit 8-3 Integrated Contingency Plan Outline
CHAPTER 9
Exhibit 9-1 RMP Updates
CHAPTER 11 ™| '; ,,, '.,[
Exhibit 11-1 Seven Cardinal Rules of Risk Communication
October 27,1998
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' • • • . .-••'' . ' . ; • vn
LISTOFBOXES
INTRODUCTION
Guidance for Industry-specific Risk Management Programs - .
State Programs
If You Are New to Regulations
What Is a Local Emergency Planning Committee? .
CHAPTER!
State Programs - '..-,.
Qs and As: Stationary Source -: '" '
Qs and As: Process , ',-;..'..
Aggregation of Substances , ; , •
Q and A: Changing Inventories
QsandAs: Compliance Dates
CHAPTER 2
Q and A: Process and Program Level
Qs and As: Public Receptors
Q and A: Determining Distances
Q and A: Environmental Receptors .
Qs and As: Accident History
Qs and As: OSHA ;•
CHAPTERS
Qs and As: Property Damage
Qs and As: Accident History ,
CHAPTER 4
RMP*Comp
Qs and As: Worst-case and Mitigation
How to Obtain Census Data and LandView
How to Obtain USGS Maps - ,
CHAPTER 6 "
Q and A: Maintenance
Q and A: Audits '
CHAPTER?
Qs and As: Implementation and Program Level .
Qs and As: Process Safety Information
Qs and As: Offsite Consequences
October 27,1998
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viii
, .
What Is a Response
What Is a Local Emergency Planning Committee?
How Does the Emergency Response Program Apply?
Planning for Flammable Substances
'lii , .i "":! ; "' •••••;" :.'l'J >":'>:
CHAPTER 9
QandA: Revising a PHA
Qs and As: Delegation
Qs arid As: Audits
CHAFTER11 ,
What Does It Mean [That WeCouldBeExposedlf We LiveAVork/Shop/Gotx) School X Miles Away?
If There is An Accident, Will Everyone Within That Distance Be Hurt? What About Property Damage?
How Sure Are You of Your Distances?
Why Do You Need to Store So Much on Site? .
What Are You Doing to Prevent Releases?
What Are You Doing to Prepare for Releases?
Do You Need to Use this Chemical?
Why Are Your Distances Different from the Distances in the EPA Lookup Tables?
Hpw Likely Ajre the Worst-case and Alternative Release Scenarios?
Is the Worst-case Release You Reported Really the Worst Accident You Can Have?
What about the Accident at the [Name of Similar Facility] That Happened Last Month?
What Actions Have You Taken to Involve the Community in Your Accident Prevention and Emergency
Planning Efforts? ...... """ '' ....... " ' '" ....... "'"' ........ '"'/ ' '
Can We See the Documentation You Keep on Site?
1 October 47,1998
I " ." .-• .
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INTRODUCTION
WHY SHOULD I READ THIS GUIDANCE?
If you handle, manufacture, use, or store any of the toxic and flammable substances
listed in 40 CFR 68.130 (see Appendix A of this document) above the specified
threshold quantities in a process, you are required to. develop and implement a risk
management program under a rule issued by the U.S. Environmental Protection
Agency (EPA), This rule, "Chemical Accident Prevention Provisions" (part 68 of
Title 40 of the Code of Federal Regulations (CFR)), applies to a wide variety of
facilities that handle, manufacture, store, or use toxic substances, including chlorine
and ammonia and highly flammable substances such as propane. This document
provides guidance on how to determine if you are subject to part 68 and how to
comply-with part 68.- If you are subject to part 68, you must be in compliance no later
than June 21, 1999, or the date on which you first have more than a'threshold quantity
of a regulated substance in a process, whichever is later.
This model risk management program is intended for wastewater treatment plants •
(WWTPs), including publicly owned treatment works (POTWs) and other industrial
treatment systems. It provides guidance on how to comply with part 68 with respect
to chlorine, ammonia (anhydrous and aqueous), sulfur dioxide, digester gas, and
propane, the substances WWTPs usually use for treatment, produce as a result of
treatment, or store as fuel. We expect that any regulated substances present in your
wastestreams will be in concentrations too low to require compliance. The sections on
propane included in this model are taken from the Risk Management Program
Guidance for Propane Storage Facilities. • .
The goal of part 68 — the risk management program — is to prevent accidental
releases of substances that can cause serious harm to the public and the environment
from short-term exposures and to mitigate the severity of releases that do occur. The .
1990 Amendments to the Clean Air Act (CAA) require EPA to issue a rule specifying
the type of actions to be taken by facilities (referred to in the statute as stationary
sources) to prevent accidental releases of such hazardous chemicals into the
atmosphere and reduce their potential impact on the public and the environment.' Part
68 is that rule. .
In general, part 68 requires that:
4- 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
October 27, 1998
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Introduction
-n-
II I, ' lYJI'l! ;: , " .'fj11 ,;";', , •!;;"• ";, ,. " ..../^ !, ,., ' •,. . ;.; ' ,',. '" , ,(,• ', . ' ,"' ' - , •' ; . '
management program. The RMP will be available to federal, state, and local
government agencies and the public.
4; 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 WWTPs
covered by part 68. It will help you to:
+ Determine if you are covered by the rule;
4- Determine what level of requirements is applicable to your covered
process(es);
4 Understand which specific risk management program activities must be
conducted;
+ 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. Even if you are not covered by this rule, you should be aware that
, uriHer me General Duty Clause of CAA section 112(r)(l), you are required to design
and maintain a safe facility. • -...'-.
WHAT DO I DO FIRST?
Before developing a risk management program, you should do five things:
• . •: .• v:,!;! -, •• ;,',;> '"•;!;;• 5;: ," •• ;•;,':,';.| •••,-.-. ',.;:,,; • •-. " ,,',:'/, v:,,," ' '!' , " , ',• .• ;. '
(1) Determine which, if any, of your processes are covered by this program
October 27, 1998
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-iii- Introduction
. Only WWTPs having one or more processes with a threshold quantity of a regulated
substance (see 40 CFR 68.130 in Appendix A) in a "process" need to comply with '
part 68. "Process" is defined by the rule in § 68.3 and does not necessarily correspond
with an engineering concept of process. The - -
STATE PROGRAMS
This guidance applies to 40 CFR part 68. You should check with your state government to determine
if the state has its own accidental release prevention rules or has obtained delegation from EPA to
implement and enforce part 68 in your state. State rules may be more stringent than EPA's rules. They
may cover more substances or cover the same substances at lower thresholds. They may also impose
additional requirements. For example, California's state program requires a seismic study. See
Chapter 10 for information on state implementation of part 68. Unless your state has been granted
delegation, you must comply with part 68 as described in this document even if your state has different
rules under state law. , ,
requirements apply only to' covered processes. /See Chapter 1 for more
information on how to define your processes and determine if they are subject'
to the rule.
(2) Determine the appropriate program level for each covered process
Depending on the specific characteristics of a covered process, the results of
the offsite consequence analysis for that process, and whether your state
implements QSHA programs, it may be subject to one of three different sets
of requirements (called program levels). See Chapter 2 for more information.
(3) Determine EPA's requirements for the facility and each covered process
Certain requirements apply tp the facility as a whole, while others, are
process-specific. See Chapter 2 for more information.
(4) Assess your operations to identify current risk management activities ,
Because you probably conduct some risk management activities already (e.g.,
employee training, equipment maintenance, and emergency planning), you
should.review your current operations to determine the extent to which they
meet the provisions of this rule. EPA does not expect you to redo these
activities if they already meet the rule's requirements. See Chapters 5 to 8
individually for guidance on how to tell if your existing practices can meet
those required by EPA. • ,.
October 27, 1998
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Introduction -iv-
(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 ooth 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; for
example, part 68 does not specify how often you must inspect storage tanks, only that
• yoii do so in a manner that minimizes the risk of a release. This allows you to tailor
your program to fit the particular conditions at your facility. The degree of complexity
required in a risk management program will depend on the complexity of the facility.
To illustrate, the operating procedures for a WWTP that does only primary treatment
are likely to be less complex than those of WWTP that does secondary or tertiary
treatment. Similarly, the length of training necessary to educate employees on such
procedureswill be proportional to the complexity of your operating procedures. And
while a large WWTP with multiple processes may benefit from a computerized
maintenance tracking system, a small WWTP with a simpler process may be able to
track maintenance activities using a logbook.
There is no one "right" way .to develop and implement a risk management program.
Even for the same rule elements, your program will be different from everyone else's
program (even those in the same industry) because it will be designed for your specific
situation and hazards—: it will reflect whether your facility is near the public and
sensitive environmental areas, the specific equipment you have installed, the
managerial decisions that you have made previously, and other relevant factors.
WHERE DO I GO FOR MORE INFORMATION?
EPA's risk management program requirements may be found in Part 68 of Volume 40
of the Code of Federal Regulations. The relevant sections were published in the
Federal Register on January 31,1994 (59 FR 4478) and June 20, 1996 (61 FR
31667). A consolidated copy of these regulations is available in Appendix A. In
,ii!i I: ' „!,.: , . , ;|!!!II| ' " „ ', , ,,l „ rr, ° I rjr
addition, EPA has finalized a rule adopting the provisions covered fay the Stay of
Applicability included in the June 20, 1996, final rule, 40 CFR §68.2 (January 6,
-:: ; •:« ',:- " .!. 199S, 63 FR 640). • ' '" '. ' " , ,
EPA is working wim industry and local, state, and federal government agencies to
as§ist sourdes incomplying with these requirements. For more information, refer to
Appendix E (Technical Assistance). Appendices C and D also provide points of
copfact for EPA and OSHA at the^ state and federal levels for your questions. Your
local emergency planning committee (LEPC) also can be a valuable resource and can
help you discuss issues with the public.
October 27, 1998
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-V-
Introduction
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.
PART 68 REGULATORY TERMS
A few words and phrases have very specific meanings within the regulation. Some of these are
unusual, which is to say they are not used in everyday language. Others are define_d 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 substanc
and could lead to an accidental release. Chapter 1 discusses the definition of process under this rule i
detail. '.'•-.,
"Regulated substance" means one of the 140 chemicals listed in part 68. ,
"Threshold quantity" means the quantity, in pounds, of a regulated substance which; if exceeded,
triggers coverage by this rule. Each regulated substance has its own threshold quantity. If you have
more than a threshold quantity of a regulated substance in a process, you must comply with the, rule.
Chapter 1 explains how to determine whether you have a threshold quantity.
"Vessel" means any container, from a single drum or pipe to a large storage tank or sphere.
"Public receptor" generally means any place where people live, work, or gather, with the exception of
roads. Buildings, such as houses, shops, office buildings, industrial facilities, the areas surrounding
buildings where people are likely to be present, such as yards and parking lots, and recreational areas,
such as parks, sports arenas, rivers, lakes, beaches, are considered public receptors. Chapter 2
discusses public receptors.
"Environmental receptor" means a limited number of natural areas that are officially designated by the
state or federal government. Chapter 2 discusses this definition. .
October 27,1998
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Introduction
-vi-.
WHAT IS A LOCAL EMERGENCY PLANNING COMMITTEE?
Local emergency planning committees (LEPCs) were formed under the federal Emergency Planning
and Community Right-to-Know Act (EPCRA) in 1986. The committees are designed to serve as a
community forum for issues relating to preparedness for emergencies involving hazardous substances.
They consist of representatives from local government, local industry, transportation groups, health and
medical organizations, community groups, and the media. LEPCs:
+ Collect information from facilities on hazardous substances that pose a risk to the community;
4- Develop a contingency plan for the community based on this information; and
+ Make information on hazardous substances available to the general public.
Contact the mayor's office or the county emergency management office for more information on your
LEPC.
October 27,1998
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CHAPTER 1: GENERAL APPLICABILITY
1.1 INTRODUCTION
The purpose of this chapter is to help you determine if you are subject to Part 68, the
risk management program rule. Part 68 covers you if you are:
+ The owner or operator of a stationary source (facility)
4- 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 WWTPs covered by this rule, the stationary source is basically ail covered.
processes at your site. Exhibit 1-1 presents the decision process for determining
applicability. . ,
STATE PROGRAMS
This guidance applies to only 40 CFR part 68. You should check with your state government to
determine if the state has its own accidental release prevention rules or has obtained delegation from
EPA to implement and enforce part 68 in your state. State rule's may be more stringent than EPA's
rules. Unless your state has been granted delegation, you must comply with part 68 as described in
this document even if your state has different rules under state law. See Chapter 10 for a discussion of
state implementation of part 68.
October 27, 1998
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EXHIBIT i-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?
Yes
You" are subject
to the rule.
Assign Program levels to
covered processes
(see Exhibit 2-1)
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. . ' Chapter 1
1-3 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 instrumentality of the United
States and any officer, agency, or employee thereof."
The rule, therefore, applies to all levels of government as well as private businesses.
CAA section 112,;:,.;, ,• ••' ..•.•" :•; ••'. .. *>" . •• . • • •
The OSHA Process Safety Management (PSM) standard (29 CFR 1910.119) exempts
hydrocarbon substances used solely as a fuel if such substances are not part of a
process containing another regulated substance and flammable liquids stored in
atmospheric storage tanks. In addition, state and local governments are not subject to
federal OSHA standards, but are subject to OSHA rules if their state has a delegated
OSHA prrogam (see Chapter 2). The OSHA exemptions do not apply or extend to
EPA'-s Risk Management Program Rule. Your processes are .not exempt from the Risk
Management Program simply because they qualify for one of the OSHA exemptions.
EPA's rule covers substances used as fuel, substances stored in atmospheric storage
tanks, and state and local governments if they own or operate a facility where there is
more than a threshold quantity in a process.
1.3 REGULATED SUBSTANCES AND THRESHOLDS (§68.130)
The list of substances regulated under § 68.130 is in Appendix A. Check the list
carefully. If you do not have any of these substances (either as pure substances or in
October 27,1998
.'..-._. Chapter 1
1-5 . General Applicability
mixtures above 1 percent concentration) or do not have them above their listed
threshold quantities, you do not need to read any further because you are not covered.
The list includes the following chemicals that are commonly used at WWTPs:
EPA , - , OSHA
Threshold Quantity Threshold Quantity
Chlorine 2,500 pounds '1,500 pounds
Anhydrous Ammonia 10,000 pounds , 10,000 pounds
Aqueous Ammonia 20,000 pounds 15,000 pounds
(concentration 20% or greater) . (>44%)
Anhydrous Sulfur Dioxide 5,000 pounds - - 1,000 pounds
, (Liquid)
Methane - 10,000 pounds 10,000 pounds
• .Propane , 10,000 pounds. • 10,000pounds
For methane, the 10,000-pound threshold applies to the total weight of the flammable
mixture of digester gases, .not just the weight of methane or flammables
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Chapter 1
General Applicability 1-6
What does this mean to you?
,! II ' Jill' ,1 ,, , „ .1 i lui'i '" 'I ' ,. , J . ,,. , , . , ,
+ 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.
4v If you have multiple unconnected vessels, containing the same substance, you
will have to determine whether they need to be considered together as co-
" ' '' . ' . • ' • j,,; .-located. ,, . •
A process can be as simple as a single storage vessel or a group of drums or cylinders
in one location or as complicated as a system of interconnected vessels, pumps,
piping, and storage vessels.
SINGLE VESSELS ,
If you have only a single vessel containing regulated substances, you need not worry
about the other possibilities for defining a process and can skip to section 1.5. For the
purposes of defining a threshold quantity, you need only consider the quantity in this
;" vessel. . , . .
'"i • ; ' , ' i1 „ 'i ' , ' • " '' , ' ' i' i •* „ „ .,,.'. . :
INTERCONNECTED VESSELS
In general, if you have two or more vessels containing a regulated substance that are
connected through piping or hoses for the transfer of the regulated substance, you
must consider the total quantity of a regulated substance in all the connected vessels
and piping when determining if you have a threshold quantity in a process. If the
vessels are connected for transfer of the substance using hoses that are sometimes
disconnected, you still have to consider the contents of the vessels as one process,
because if one vessel were to rupture while the hose was attached or the hose were to
break during the transfer, both tanks could be affected. Therefore, you must count
the quantities in both tanks and in any connecting piping or hoses. You cannot
consider the presence of automatic shutoff valves or other devices that can limit flow,
because these are assumed to fail for the purpose of determining the total .quantity in a
s,n i; , . process, , . ' . -
Once you have determined that a process is covered (the quantity of a regulated
substance exceeds its threshold), you must also consider equipment, piping, hoses, or
other interconnections that do not carry or contain the regulated substance, but that are
important for accidental release prevention. Equipment or connections which contain
utility services, process cooling water, steam, electricity, or other non-regulated
substances may be considered part of a process if such equipment could cause a
regulated substance release or interfere with mitigating the consequences
October 27,1998
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Chapter 1
General Applicability
of an accidental release. Your prevention program for this process (e.g., PSM
program) will need to cover such equipment. If, based on your analysis, it is,
determined that interconnected equipment or connections not containing the regulated
substance cannot cause a regulated substance release or interfere with mitigation of
the consequences of such a release, then such equipment or connections could safely
be considered outside the limits or boundaries of the covered process.
In some cases, determining the boundaries of a process for purposes of the RMP rule
may be complicated. In the preamble to the June 20, 1996 rule (61 FR 31668), EPA
clearly stated its intent to be consistent with OSHA's interpretation of "process" as
that term is used in OSHA's PSM rule. Therefore, if your facility is subject to .the
, PSM rule, the limits of your process(es) for purposes of OSHA PSM will be the limits
of your process(es) for purposes of RMP (except in cases involving atmospheric
storage tanks containing flammable regulated substances, which are exempt from
PSM but notRMP). If your facility is not covered by OSHA PSM and is complicated
from an,engineering perspective, you should consider contacting your implementing
agency for advice on determining process boundaries.
COLLOCATION
The third possibility you must consider is 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:
; "' . •
+. Could a release from one of the containers lead to a release from the other?
For example, if a cylinder of propane were to rupture and burn, would the fire
. spread to other propane cylinders? " . •'",.' ' ' _ •
•^ . Could an event external to the containers, such as a fire or explosion or
collapse of collision (e.g., a vehicle collides with several stored containers),
have the potential to release the regulated substance from multiple containers?
You must determine whether there is a credible scenarid that could lead to a release of
a threshold quantity. ,
For flammables, you should consider the distance between vessels. If a fire could
. spread from one vessel to others or an explosion could rupture multiple vessels, you
must count all of them. For toxics, a release from a single vessel will not normally
, 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
October 27, 1998
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Chapter 1
General Applicability 1-8
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 that will contain the blast waves
from explosions of the substances, you will not need to count the separated vessels,
but you would count any that are in the same room.
„ , "il" :i ., , ",',". ' • ' i "', I • , " , ' ' • • ''" i ' '
You may not dismiss the possibility of a fire spreading based on an assumption that
your fire brigade will be able to prevent any spread. You should ask yourself how far
the fire would spread if the worst happens — the fire brigade is" slow to arrive, the
water supply fails, or the local fire department decides it is safer to let the fire burn -
itself out. If you have separate vessels containing a regulated substance that could be
affected by the same accident, you should count them as a single process.
•l '' . ' -'ij? " ,"" '.[;' ''. " i! " '•''.-','. i' '. ' " \, :"-" • '•..'••• •':'• ' " ''• '
PROCESSES WIJH MULTIPLE CHEMICALS
When you are determining whether you have a covered process, you should not limit
your consideration to vessels that have the same regulated substance. A covered
process includes any vessels that altogether hold more than a threshold quantity .of
regulated substances and that are interconnected or co-located. Therefore, if you have
four storage or reactor vessels holding four different regulated substances above their
individual thresholds and they are located close enough to be involved in a single
event, they are considered a single process. One implication of this approach is that if
you have two vessels, each containing slightly less than a threshold quantity of the
same regulated substance and located a considerable distance apart, and you have
othej; storage or process vessels in between with other regulated substances above their
thresholds, the two vessels with the first substance may be considered to be part of a
larger process involving the other intervening vessels and other regulated substances,
based on co-location.
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).
October 27, 1998
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EXHIBIT 1-2: PROCESS
Schematic Representation
Description
Interpretation
1 vessel
1 regulated substance above TQ
1 process
2 or-more connected vessels
same regulated substance
above TQ v
1 process
2 or more connected vess.els
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 su balances
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 flammables
1 process
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Chapter 1
Genera} Applicability
1-10
QS & AS
PROCESS
Q. How far apart do separate vessels have to be to be considered different processes?
A. There is no hard and fast rule for how great this distance should be before you do not need to
consider the vessels as part of one process. Two vessels at opposite ends of a large warehouse room
might have to be considered as one process if the entire warehouse or room could be engulfed in a fire.
Two vessels separated by the same distance out of doors might be far enough apart that a fire affecting
one would be unlikely to spread to the other.' You may want to consult with your local fire department.
You should then use your best professional judgment. Ask yourself how much of the regulated
substance could be released if the worst happens (you have a major fire, an explosion, a natural
disaster).
Q. We add chlorine to a wastestream which dilutes it. At what point does the process end?
A. The process ends when the concentration of chlorine in the wastestream is no longer above one
percent, unless other regulated substances are present above their threshold quantities or the vessel is
otherwise considered part of the process because it could cause a release of the covered vessels holding
regulated substances or hinder a response to such a release.
1.5 THRESHOLD QUANTITY IN A PROCESS
The threshold quantity for each regulated substance is listed in 40 CFR 68.30, in
Appendix A. You should determine whether the maximum quantity of each substance
in a process is greater than the threshold quantity listed. If it is, you must comply with
this rule for that process. Even if you are not covered by this rule, you may still be
subject to reporting requirements under the Emergency Planning and Community
Right to Know Act (EJPCRA) because EPCRA section 312 requires reporting at lower
thresholds for toxics and counts for threshold determination purposes the maximum
quantity of each substance on the site as a whole rather than in, a single process.
11 - , ' '?": • ' ; - '. "• '•'.':• • " "' '. *'• ' ' ''
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.
October 27,1998
'..Jiiiii I,', ,.'.„ inn''! i, '
-------
_ . Chapter 1
1-1.1. General Applicability
AGGREGATION OF SUBSTANCES
A toxic substance is never aggregated with a different toxic substance to determine whether a threshold
quantity is present. If your process consists of co-located vessels with different toxic substances, you
must determine whether each substance exceeds its threshold quantity.
A flammable substance in one vessel is never aggregated with a different flammable substance in _
another vessel to determine whether a threshold quantity is present. However, if a flammable mixture
meets the criteria for NFPA-4 and contains different regulated flammables, it is the mixture, not the
individual substances, that is considered in determining if a threshold quantity is present.,
"At any one time" means you need to consider the largest quantity that you ever have
in the vessel. If you fill a tank with 50,000 pounds and immediately begin using the
substance and depleting the contents, your maximum is 50,000 pounds.
If you fill the vessel four times a year, your maximum is still 50,000 pounds'.
Throughput is not considered because the rule is concerned about the maximum
quantity you could release in a single event.
For tanks, the maximum capacity can usually be found from "Ul A"certificates for the
vessels. The Ul A certificates on all vessels constructed under the ASME Boiler and
Pressure Vessel Code are kept on file by the National Board of Boiler and Pressure
Vessel Inspectors.l The nominal nameplate capacity can also be found on the
permanently attached nameplate for your storage tank. The nameplate will also have
the National Board Number for your vessel, which is the key to retrieving your Ul A
form from the Board. These nameplates may be located on one of the hemispherical
heads, the manway, or the manway cover of the tank. The nominal capacity will
usually be the water capacity, and you may want to convert it to pounds.
If you use transportation containers (railcars or tank trucks) as storage vessels, you can
obtain the capacity from the required DOT nameplate, identification plate, or
specification plate or from the owner of the containers. Smaller shipping containers
are also marked.
In calculating the quantity in a tank, you may take into account.industry
recommendations or regulatory limits on the percentage of the tank's total capacity
that can be used, provided you comply with these limits. The Chlorine Institute
recommends that chlorine tanks not be filled beyond 95 percent at a maximum
temperature of 122 F. OSHA regulations (29 CFR 1910.111) limit liquid volumes of
anhydrous ammonia. NFPA-58 (the National Fire Protection Association's
1 National Board of Boiler and Pressure Vessel Inspectors, 1055 Crupper Ave., Columbus, OH 43229;
http://www.nationalboard.org. ,
October 27, 1998
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Chapter 1
General Applicability 1-12
Standard for Storage and Handling of Liquified Petroleum Gases) recommends that
propane tanks not be filled beyond 88 percent at 60 F. Aqueous ammonia may be
held in various concentrations; your supplier can provide the density and weight. You
can use this information, with your tank capacity, to estimate the quantity of ammonia
being stored. The Compressed Gas Association provides recommendations on filling
sulfur dioxide tanks at varying temperatures (CGA pamphlet G-3).
Methane, a regulated flammable substance, is a component of digester gas, commonly
making up about 65 to 70 percent by volume of the total. Digester gas usually meets
the NFPA-4 criteria that determine whether flammable mixtures are subject to part 68.
You are more likely to have a threshold quantity of methane if you compress and store
it,, but you may also have a threshold quantity in the head space of the digester(s) and
associated piping. To determine whether more than the threshold quantity of 10,000
pounds is present in the head space and connected piping, you must consider the total
quantity of a flammable mixture containing a regulated flammable substance, so you
must estimate the total quantity of digester gas, not just the quantity of methane in the
gas, to determine whether you have a threshold quantity. For digester gas that is about
70 percent methane, at pressures not much above atmospheric pressure and
temperatures of about 95 to 105 F, you may assume a density of approximately 0.06
pounds per cubic foot. The quantity of digester gas can be estimated from the volume
of the digester in cubic feet (the overhead space and pipeline volume) as follows:
Quantity (pounds) = 0.06 pounds per cubic foot x Digester Volume (cubic feet)
For example, if the volume of digester gases in the head space and piping is 200,000
cubic feet, you would multiple 200,000 by 0.06; the quantity of digester gas is,
therefore, 12,000 pounds. The digester volume must be about 167,000 cubic feet or
more to contain a threshold quantity of flammable gas. At a methane percentage by
volume of 64 percent, the density would be 0.062 pounds per cubic foot.
If you have compressed digester gas, you may estimate the density by applying a
pressure factor as follows:
Density at pressure Y = 0.06 x Y (absolute pressure)/atmospheric pressure
1 !*" , ' ' ,' ' " '' ' : i ' '''''," . ' ','! ' I '
"!lil, " ' ''', "' ' • '' Sl ' ' ' " ', ' "- ' . l|"/,, ' ' .
If you have more accurate information about the composition and properties of the
digester gas, you may use this to develop a better estimate of the density of the gas and
the quantity. If you are not sure of the concentration of methane, you should use 70
percent as a conservative estimate. .••_
If the above calculations result in quantities close to the 10,000 pound threshold
quantity, you may use the following general equation:
MI =Vol x MW/379.5 x 520/(460+T) x (P)/14.7
where M, = total mass
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' - . Chapter 1
1-13 General Applicability
MW = average molecular weight (Ibs/mole) including water vapor
T = operating temperature (°F)
P = operating gauge pressure (psi)
1 psi = 27.7 inches water column
Q & A
CHANGING INVENTORIES
Q. I am considering changing from 2 one-ton tanks of chlorine to ten 150-pound cylinders to reduce
my chlorine inventory below the RMP threshold quantity. Are there any reasons not to do this?
A. Reducing the inventory of regulated substances can be a sensible and appropriate risk-reduction
option in some circumstances, but before you decide to switch to multiple smaller chlorine containers,'
you should carefully evaluate whether you might actually be increasing the risks to your workers and
potentially the public. Using smaller containers or using the same one-ton chlorine tanks with a
smaller quantity in each tank will require more frequent equipment connections and handling of
chlorine containers. Each time workers must unload, move, and connect tanks or cylinders, there is an
increased risk of a release. Also, 150-pound cylinder systems generally feed gaseous chlorine under
pressure, while one-ton tanks'use a safer vacuum-feed system. It may be easier, safer, and less costly
in the long run to continue to use the larger containers that require less frequent handling, while
implementing the appropriate accident prevention measures required by the rule.
Sources are advised that their standing in relation to the thresholds set under part 68 does not affect th'
applicability of the general duty clause under section 112(r)(l) of the Clean Air Act, which applies to
all facilities that handle extremely hazardous substances. This clause creates a duty for the owner or
operator of a stationary source having extremely hazardous substances, which include chlorine, "to
identify hazards which may result from [accidental] releases:.., to design and maintain a safe facility ^
and to minimize,the consequences of accidental releases which do occur." In view of the increased
potential for accidental releases that 150-pound cylinders may pose in some circumstances, switching
to such cylinders from safer one-ton tanks may raise questions as to whether you have fulfilled your
obligations under the general duty clause. The general duty clause is already in effect,, and EPA may
take action to enforce it v
I
QUANTITY IN A PIPELINE
The maximum quantity in a pipeline will generally be the capacity of the pipeline
(volume). In most cases, pipeline! quantity will be calculated and added to the
interconnected vessels. The quantity in a'pipe can be calculated using the following
general equation:
V = Pir2L ' • • • '•-.-:••.' . ' ' . .'
Where V = Volume '•'..'"' '. •
r = Radius of the pipe ,
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Chapter 1
General Applicability 1-14
L = Length of the pipe. '
INTERCONNECTID/QO-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 vessels as one process, you
must determine the maximum quantity for each vessel and sum up the quantities of all
such vessels. •
QUANTITY OF A SUBSTANCE IN A MIXTURE
TOXICS WITH 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 than
the listed concentration, you do not need to consider them at all.
4- If you have one of these four above their listed concentration, you must
determine the weight of the substance in the solution and use that to calculate
the quantity present. If that quantity is greater than the threshold, the process
is covered. For example, aqueous ammonia is covered at concentrations
above 20 percent, with a threshold quantity of 20,000 pounds. If the solution
is 25 percent ammonia, you would need 80,000 pounds of the solution to meet
the threshold quantity; if the solution is 44 percent ammonia, you would need
45,455 pounds to meet the threshold quantity (quantity of mixture x
percentage of regulated substance = quantity of regulated substance).
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.
October 27,1998
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' Chapter 1
1-15 ' General Applicability
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 G)
(i.e., Class 1A flammable liquids)
•* Materials that will spontaneously ignite when exposed to air." - .
.You do not need to cpnsider gasoline, when in storage for use as fuel for internal
combustion engines When you determine the applicability of the rule.)
EXCLUSIONS (§68.115)
The rule has a number of exclusions that allow you to ignore certain items that contain
a regulated substance when you determine whether a threshold quantity is present.
Most of these exclusions will not be relevant to WWTPs.
ARTICLES (§ 68.115(b)(4))
You do not need to include in your threshold calculations any manufactured item
defined at § 68.3 (as defined under 29 CFR 1910.1200(b)) that:
4- Is formed to a specific shape or design during manufacture,
+ Has end use functions dependent in whole or in part upon the shape or design
during end use, and
+ Does not release or otherwise result in exposure to a regulated substance
under normal conditions of processing and use.
October 27, 1998
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Chapter 1
General Applicability 1-16
This exclusion is unlikely to apply to WWTPs.
USES (§ 68.115(b)(5))
, I: ' '
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
II ' ,1 ' ', • ' ' • '• | 1, ' Ml ^
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.
11 ! : '. '.!' • •• •••';• : ' ! .•): '• • ','••• •.••:••• ,- •'
; . . . ' ill i I ' ' '• • ' 1 . '
ACTIVITIES IN LABORATORIES (§ 68.115(b)(6))
If a regulated substance is manufactured, processed, or used in a laboratory at a
stationary source under the supervision of a technically qualified individual (as
defined by § 720.3 (ee) of 40 CFR), the quantity of the substance need not be
considered in determining whether a threshold quantity is present. This exclusion
does not extend to:
4- Specialty chemical production;
4 Manufacture, processing, or use of substances in pilot plant scale operations;
;;,.: , •• ' . ;'. and ' .' ' ' . ',. . ' :.'. .'-.- ' -
[.'••>•. • ! , :;••',., :•' ,. . / , .i. • , „: / ;,''•. i ••'•
•4 Activities conducted outside the laboratory.
A technically qualified individual is "a person or persons (1) who, because of
education, training, or experience, or a combination of these factors, is capable of
understanding the health and environmental risks associated with the chemical
substance which is used under his or her supervision, (2) who is responsible for
enforcing appropriate methods of conducting scientific experimentation, analysis, or
chemical research to minimize such risks, and (3) who is responsible for the safety
assessments and clearances related to the procurement, storage, use, and disposal of
the chemical substance as may be appropriate or required within the scope of
conducting a research and development activity."
This exclusion is unlikely to apply to WWTPs because you probably will not have
more than a threshold quantity of a regulated substance in a lab.
October 27.1998
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; • Chapter 1
1-17 General Applicability
1.6 STATIONARY SOURCE
. The rale applies to "stationary sources" and each stationary source with one or more
covered processes must file an RMP that includes all covered processes.
SIMPLE SOURCES
" For most WWTPs covered by this rule, determining what constitutes a "stationary
source" is simple. If you own or lease a property, your processes are contained within
the property boundary, and no other companies (or agencies) operate on the property,
then your stationary source is defined by the property boundary and covers any
process within the boundaries that has more than a threshold quantity of a regulated
substance. You must comply with the rule and file a single RMP for all covered
processes. If this description applies to you, you may skip the rest of this section.
To belong to the same industrial group, either the operations at the site must be in the
same three-digit North American Industy Classification System (NAICS) code (the
equivalent of the old two-digit SIC codes), or one or more operations must be
considered support activities for the main operation. POTWs are in NAICS code
22132 (sewage treatment); other WWTPs may be in NAICS code 56221 (waste
treatment and disposal).
MULTIPLE OPERATIONS OWNED BY A SINGLE COMPANY
If the property is owned or leased;by your company, but several separate operating .
divisions of the company have processes at the site, the divisions' processes may be
considered a single stationary source because they are controlled by a single company.
Two factors will determine if the processes are to be considered a single .source: Are
the processes located on one or moire contiguous properties? Are all of the operations
in the same industrial group?
If your company does have multiple operations that are on the same property and are
in the same industrial group, each operating division may develop its prevention
program separately for its covered processes, but you must file a single RMP for all
covered processes at the site. You should note that this is different from the
requirements for filing under CAA Title V, and EPCRA section 313 (the annual toxic
!-' release inventory), where each division could file separately if your company chose to
. do so. .
OTHER SOURCES
There are situations where two or more separate companies occupy the same site. The
simplest of these cases is if multiple companies lease land at a site (e.g., an industrial
park). Each company that has covered processes must file an RMP that includes
information on its own covered processes at the site.< You are responsible for filing an
RMP for any operations that you own or operate.
October 27,1998
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Chapter 1
General Applicability ' 1-18
Another possibility is that one company owns the land and operates there while
leasing part of the site to a second company. If both companies have covered
processes, each is considered a separate stationary source and must file separate RMPs
even if they have contractual relationships, such as supplying product to each other or
sharing emergency response functions.
If you and another company jointly own a site, but have separate operations at the site,
you each must file separate RMPs for your covered processes. Ownership of the land
is not relevant; a stationary source consists of covered processes located on the same
property and controlled by a single owner.
MULTIPLE LOCATIONS
If you have multiple operations in the same area, but they are not on physically
coriiiected 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
amoing the sites. Remember, the rule applies to covered processes at a single location.
Exhibit 1-3 provides examples of stationary source decisions.
1.7 WHEN YOU MUST COMPLY
Prior to June 21, 1999, if you determine that you have a covered process, you must
comply with the requirements of part 68 no later than June 21, 1999. This means that
if you have the process now or start it on June 1, 1999, you must be in compliance
with the rule on June 21, 1999. By that time you must have developed and
implemented all of the elements of the rule that apply to each of your covered
processes, and you must submit an RMP to EPA in a form and manner that EPA will
specify prior to that time.
If the first time you have a covered process is after June 21, 1999, or you bring a new
process on line after that date, you must comply with part 68 no later than the date on
which you first have more than a threshold quantity of a regulated substance in a
process. ' ' .
October 27,1998
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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 BMP
ABC Chemicals
ABC Chemicals
two owners
XYZ Gases
2 stationary sources
2 RMPs
1 ABC
1 XYZ
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
2 RMPs
same owner
same industrial group
contiguous property.
,1 stationary source
1 RMP
, Building owned by Brown Properties
Farm Chemicals Inc.
1
,ABC
Chemicals
Brown Property offices
11
two owners
Pet Supply Storage
: (no regulated substances)
2 stationary sources
2 RMPs
... 1 ABC Chemicals
1 Farm Chemicals
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Chapter I
General Applicability
1-20
Qs&As
COMPLIANCE DATES
Q. What happens if I bring a new covered process on line (e.g., install a second storage tank) after
June 21,1999?
A. For a new covered process added after the initial compliance date, you must be in compliance on
the date you first have a regulated substance above the threshold quantity. There is no grace period.
You must develop and implement all the applicable rule elements and update your RMP before you
start operating the new process.
Q. What if EPA lists a new substance?
A. You will have three years from the date on which the new listing is effective to come into
compliance for any process that is covered because EPA has listed a new substance.
Q. What if I change a Program 2 process by adding new digester vessels, but do not change the
substances? .
A. Because increasing the number of digester vessels is a major change to your Program 2 process, you
will have six months to come into compliance and update your RMP to reflect changes in your
prevention program elements and report any other changes.
Q. What if the quantity in the process fluctuates? I may not have a threshold quantity on June 21,
1999, but I will before then and after then.
A. You do not need to comply with the rule and file an RMP until you have more than threshold
quantity in a process; however, once you have more than threshold quantity in a process after June 21,
1999, you must be in compliance immediately. In this situation, with fluctuating quantities, it may be
prudent to file by June 21, 1999, so you will be in compliance when your quantity exceeds the
threshold.
f
Q. If we plan to switch chemicals in two years to non-regulated substances, do we have to comply by
June 1999 if we are still using chlorine.
A. Yes, if you have more than a threshold quantity of a regulated substance in a process on June 21,
1999, you must comply with the rule and file your RMP by to that date. When you make the switch, if
your facility as a whole is no longer covered, you should revise the registeration on your RMP within
six months to notify EPA that your facility is not subject to the rule. If only the chlorine process is n
longer covered, you still must revise the RMP within six months.
October 27,1998
,.£•
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CHAPTER 2: APPLICABILITY OF PROGRAM LEVELS
2.1 WHAT ARE PROGRAM LEVELS?
Once you have decided that you have one or more processes subject to this rule (see
Chapter 1), you need to identify what actions you must take to comply. The rule
defines three Program levels based on processes' relative potential for public impacts,
the level of effort needed to prevent accidents, and coverage by other regulations. The
Program levels are as follows: <
Program 1: Processes with no public receptors within the distance to an
• • endpoint from a worst-case release and with no accidents with specific offsite
consequences within the past five years are eligible for Program 1, which
imposes limited hazard assessment requirements an4 minimal prevention and
emergency response requirements.
Program 2: Processes not eligible for Program 1 or subject to Program 3 are
placed in Program 2, which imposes streamlined prevention program.
requirements, as well as additional hazard assessment, management, and
emergency response requirements. '
. Program 3: Any process not eligible for Program 1 and subject to OSHA's
PSM standard under federal or state OSHA programs is subject to Program 3,
which imposes OSHA's PSM standard (see section 2.5) as the prevention .
program as well as additional hazard assessment, management, and
emergency response requirements.
If you can qualify a process for Program 1, it is in your best interests to do so, even if
the process is already subject to OSHA PSM. For Program 1 processes, the
implementing agency will enforce only the minimal Program 1 requirements. If you
assign a process to Program 2 or 3 when it might qualify for Program 1, the
implementing agency will enforce all the requirements of the higher program levels.
If, however^ you are already in compliance with the prevention elements of Program 2
or Program 3, you may want to use the RMP to inform the community of your
prevention efforts.
See Exhibit 2-1 for a diagram of the decision rules on Program level.
KEY POINTS TO REMEMBER
- /
In determining program level(s) for your process(es), keep in mind the following:
'" (1) Each process is assigned to a program level, which indicates the risk
management measures necessary to comply with'this regulation for that
'•- ' process, not the facility as a whole. .The eligibility of one process for a
• . • program level does not influence the eligibility of other covered processes for
other program levels.
October 26,1998
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EXHIBIT 2-1
EVALUATE PROGRAM LEVELS FOR COVERED PROCESSES
Are public receptors
within the distance to
the endpoint for a
worst-case release?
Is the process
classified in one of the
listed NAICS codes?
Is the process
subject to the OSHA
PSM Standard?
Have offsite
impacts occurred due
to a release of a
regulated substance
from the process?
Process
Subject to
Program
Level 2
No
1
Process
Eligible for
Program
Level 1
Process
Subject to
Program
Level 3
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. . Chapter 2
2-3 Applicability of Program Levels
(2) Any process that meets the criteria.for Program 1 can be assigned to
Program 1, even if it is subject to OSHA PSM or is in one of the SIC codes
listed for Program 3.
•'e*
(3) Program 2 is the default program level. There are no "standard criteria"
for Program 2. Any process that does not meet the criteria for either Programs
1 or 3 is subject to the requirements for Program 2.
(4) Only one Program level can apply to a process. If a process consists of
multiple production or operating units or storage vessels, the highest Program
level that applies to any segment of the process applies to all parts., .
, Q&A . .- ' '
PROCESS AND PROGRAM LEVEL /
Q. My process includes a series of interconnected units, as well as several storage vessels that are co-
located. Several sections of the process could qualify for Program 1. Can I divide my process into
sections for the purpose of assigning Program levels? .
A. No, you cannot subdivide a process for this purpose. The highest Program level that applies to any
section of the process is the Program level for the whole process. If the entire process is hot eligible
for Program 1, then the entire process must be assigned to Program 2 or Program 3.
2.2 POTW PROGRAM LEVELS
Unlike private WWTPs, a POTW will determine its Program levels based, in part, on
the state in which it is located. If OSHA has delegated its programs to the state in
which your POTW is located, you are covered by OSHA standards under state law (it
is a condition of gaining delegation that the state apply OSHA rules to state and local
governments). If your state has not been granted delegation by Federal OSHA, you
are not subject to OSHA standards because federal OSHA cannot regulate state and
local governments. If you are in one of the states without a delegated OSHA program
(listed in Exhibit 2-2), your processes will be in either Program 1 or Program 2.
If you are in one of the states or territories with a delegated OSHA program (listed in •
Exhibit 2-3), your processes will be in Program 1, if eligible; otherwise, processes
involving regulated toxics substances or digester gas production will be in Program 3
because they are subject to OSHA PSM. If you store a regulated flammable substance.
as fuel for workplace consumption, that storage may be in Program 2 if it is not
considered part of an otherwise covered process.
October 26, 1998
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Chapter 2
Applicability of Program Levels
2-4
EXHIBIT 2-2
FEDERAL OSHA STATES
Alabama
Arkansas
Colorado
Delaware
DC
Florida
Georgia
Idaho
Illinois
Kansas
Louisiana .
Maine
Massachusetts
Missouri
Mississippi
Montana
Nebraska
New Hampshire
New Jersey
North Dakota
Ohio
Oklahoma
Pennsylvania
Rhode Island
South Dakota
Texas
West Virginia
Wisconsin
EXHIBIT 2-3
STATES WITH DELEGATED OSHA PROGRAMS
Alaska
Arizona
California
Connecticut
Hawaii
Indiana
Iowa
Kentucky
Maryland
Michigan
Minnesota
Nevada
New Mexico
New York
North Carolina
Oregon
Puerto Rico
South Carolina
Tennessee
Utah
Vermont
Virginia
Virgin Islands
Washington
Wyoming
October 26,1998
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• ' , Chapter 2
2-5 Applicability of Program Levels
2.3 PROGRAM 1
WHAT ARE THE ELIGIBILITY REQUIREMENTS?
Your process is eligible for Program 1 if:
' (1) There are no public receptors within a distance to an endpoint from a
worst-case release;
» (2) The process has had no release of a regulated substance in the past five years
...-",. where exposure td the substance, its reaction products, overpressures
generated by explosion involving the substance, or .radiant heat from a fire
involving the substance resulted in one or more offsite deaths, injuries, or
response or restoration activities for exposure of an environmental receptor;
and . .-'•,.-.
. • (3) You have coordinated your emergency response activities with the local
. . responders. (This requirement applies to any covered process, regardless of
progranr level.)
See Exhibit 2-6 for the requirements for Program 1. •
WHAT Is A PUBLIC RECEPTOR?
The rule (§ 68.3) defines public as "any person except an employee or contractor of
the stationary source." Consequently, employees of other facilities that may share
your site are considered members of the public even if they share the same physical
location. Being "the public," however, is not the same as being a public receptor.
Public receptors include "offsite residences, institutions (e.g., schools and hospitals),
industrial, commercial/and office buildings, parks, pr recreational areas inhabited or
occupied by the public at any time without restriction by the stationary source where
members of the public could be exposed to toxic concentrations, radiant heat, or
overpressure, as a result of an accidental release." Offsite means areas beyond your •
property boundary and "areas within the property boundary to which the public has .
routine and unrestricted access during or outside business hours."
The first step in identifying public receptors is determining what is "offsite." For most
, facilities, that determination will be straightforward. If you restrict access to all of your
' property all of the time, "offsite" is anything beyond your property boundaries. Ways
" . of restricting access include fully fencing the property, placing security guards at a
reception area or using ID badges to permit entry.,
If you do not restrict access to a section of your property and the public has routine
. and unrestricted access to it during or after business hours, that section would be
"offsite." For example, if your operations are fenced but the public has unrestricted
access to your parking lot during or after business hours, the parking lot is "offsite."
October 26,1998
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Chapter 2
Applicability of Program Levels 2-6
In the case of facilities such as hospitals, schools, and hotels that shelter members of
the public as part of their function or business, the parts of the facility that are used to
shelter the public would be "offsite."
Not all areas offsite are potential public receptors. The point of identifying public
receptors is to locate those places where there are likely to be, at least some of the
time, members of the public whose health could be harmed by short-term exposure to
an accidental release at your site. The basic test for identifying a public receptor is
thus whether an area is a place where it is reasonable to expect that members of the
public will routinely gather at least some of the time.
The definition of "public receptor" itself specifies the types of areas where members
of the public may routinely gather at least some of the time: residences, institutions
such as hospitals and schools, buildings in general, parks and recreational areas.
There should be little difficulty in identifying residences, institutions and businesses
as such, and virtually any residence, institution and business will qualify as a public
receptor, even when the property is used only seasonally (as in a vacation home).
Notably, a residence includes its yard, if any, and an institution or business includes
its grounds to the extent that employees or other members of the public are likely to
routinely gather there at least some of the time for business or other purposes (see
discussion of recreational areas below). The only circumstances that would justify not
considering such a property a public receptor would be where your facility owns or
controls the property and restricts access to it, or no member of the public inhabits or
occupies it at any time. Where a hospital, school, hotel or other entity that provides
public shelter is itself subject to the part 68 rule (e.g., because of on-site propane
storage tanks), it will be its own public receptor except for those areas where members
of the public are not allowed to go at any time.
Buildings other than residences, institutions or businesses are also highly likely to
qualify as public receptors since the function of most buildings is at least in part to
shelter people. Accordingly, toll booth plazas, transit stations, and airport terminals
would qualify as public receptors. For a building not to qualify as a public receptor,
one of the circumstances mentioned above would have to apply.
Every designated park or recreational area, or at least some portion thereof, is apt to
be a public gathering place by virtue of facilities made available to the public (e.g.,
visitors' center, playground, golf course, camping or picnic area, marina or ball field)
or attributes that members of the public routinely seek to use (e.g., beach). It does not
matter whether use of such facilities is seasonal; routine use for at least part of the year
would qualify the area as a public receptor.
. "•• '•'','' ,-•
At the same time, some portion of a designated park or recreational area may not be a
public receptor. For instance, a large state or national park may include relatively
inaccessible tracts of land that do not contain public facilities or receive routine use.
Occasional hiking, camping or hunting in such areas would not qualify the areas as
public receptors.
October 26,1998
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.';-... .Chapter 2
2-7 Applicability of Program Levels
--.... = . . QS&AS ' •••'-., ..•'•'-."•'."•.
, PUBLIC RECEPTORS
Q. My processes are fenced, but my offices and parking lot for customers are not restricted. What is
considered offsite? What is considered a public receptor?
A. The unrestricted areas would be considered offsite. However, they would not be public receptors
because you are responsible for the safety of those who work in or visit your offices and because
parking lots are not generally public receptors.
Q. What is considered a recreational area?
A. Recreational area's would include land thai is designed, constructed, designated, or used for
recreational activities. Examples are national, state, county, or city parks, other outdoor recreational
areas such as golf courses or swimming pools and bodies of waters (oceans, lakes, rivers, and streams)
when used by the public for fishing, swimming, or boating. Public and private areas that are
predictably used for hunting, fishing; bird watching, bike riding, hiking, or camping of other
recreational use also would be considered recreational areas. EPA encourages you to consult with land
owners, local officials, and the community to reach an agreement on an area's status; your local
emergency planning committee (LEPC) can help, you with these consultations. EPA recognizes that
some judgment is involved in determining whether an area should be considered a recreational area.
Q. Does public receptor cover only buildings on a property or the entire property? If the owner of the
land next to my site restricts access to the land, is it still a public receptor?
A. Public receptors are not limited to buildings. For example, if there are houses near your property,
both the houses and their yards/are considered public receptors because it is likely that residents will b
present in one or the other at least some of the time, and, in fact, people are likely to be in more dange
if they are outside when a release occurred. The ability of others to restrict access to an area does not
change its status as a public receptor. You need to consider whether that land is generally unoccupied.
If the land is undeveloped or rarely has anyone on it,,it is not a public receptor. If you are not sure o
the land's use of .occupancy, you should talk with the landowner and the community about its status.
Because it is the landowner and members of the local community who are likely to be affected by your
decision, you should involve them in the decision is you have doubts.
An area need not be designated a recreational area to be one in fact. If an area is
•, routinely used for recreational purposes, even if only seasonally, it is a recreational
area for purposes of the part 68 rule. For example, a marina may not bill itself as a
"recreational area," but if a marina houses recreational boats, it qualifies as a public
receptor. Further, if your facility or a neighboring property owner allows the public to
make routine recreational use of some portion of land (e.g., a ball field or fishing
pond), that portion of land would qualify as a public receptor.
October 26,1998.
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Chapter 2
Applicability of Program Levels 2-8
Roads and parking lots are not included as such in the definition of "public receptor."
Neither are places where people typically gather; instead they are used to travel from
one place to another or to park a vehicle while attending an activity elsewhere.
However, if a parking lot is predictably and routinely used as a place of business
(e.g., a farmer's market) or for a recreational purpose (e.g., a county fair), it would
qualify as a public receptor.
In general, farm land would not be considered a public receptor. However, if farm
land, or a portion thereof, is predictably and routinely occupied by farm workers or
other members of public, even if only on a seasonal basis, that portion of the land
would be a public receptor.
If you are in doubt about whether to consider certain areas around your facility as
public receptors, you should consult with the relevant local officials and land owners
and your implementing agency for guidance.
WHAT IS A DISTANCE TO AN ENDPOINT FROM A WORST-CASE RELEASE?
In broad terms, the distance to an endpoint is the distance a toxic vapor cloud, fire, or
•explosion from an accidental release v/ill travel before dissipating to the point that
serious injuries from short-term exposures will no longer occur. The rule establishes
"endpoints" for each regulated substance and defines the circumstances of a
worst-case release scenario (e.g., scenario, weather, release rate and duration) (see
Chapter 4 or the RMP Offsite Consequence Analysis Guidance for more information).
You will have to define a worst-case release (usually the loss of the total contents of
your largest vessel) for each Program 1 process and either use EPA's guidance or
conduct modeling on your own to determine the distance to the endpoint for that
worst-case release. Beyond that endpoint, the effects on people are not considered to
be severe enough to merit the need for additional action under this rule.
To define the area of potential impact from the worst-case release, draw a circle on a
map, using the process as the center and the distance to the endpoint as the radius. If
there are public receptors within that area, your process is not eligible for Program 1.
/ - ' . •. '.''••.-•
ACCIDENT HISTORY
To be eligible for Program 1, no release of the regulated substance from the process
can have resulted in one or more offsite deaths, injuries, or response or restoration
activities at an environmental receptor during the five years prior to submission of
your RMP. A release of the regulated substance from another process has no bearing
on whether the first process is eligible for Program 1. " ••*• •
October 26, 1998
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Chapter 2
2-9 . Applicability of Program Levels
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 distance to the endppint 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 document that these two
points (which are about 100 feet apart) differ. Civilian GPS systems generally have a margin of error
of 100 meters (about 0.05 miles).)
WHAT is AN INJURY?
An injury is defined as "any effect on a human that results either from direct exposure
to toxic concentrations; radiant heat; or overpressures from accidental releases or from
the direct consequences of .a vapor cloud explosion (such as flying glass, debris, and
other projectiles) from an accidental release." The effect must "require medical
treatment or hospitalization." This definition is taken from the OSHA regulations for
keeping employee injury and illness logs and should be familiar to most employers.
Medical treatment is further defined as "treatment, other than first aid, administered
by a physician1 or registered professional personnel under standing orders from a
physician." The definition of medical treatment will likely capture most instances of
hospitalization. However, if someone goes to the hospital following direct exposure to
a release and is kept overnight for observation (even if no specific injury or illness is
found), that would qualify as hospitalization and so would be considered an injury.
WHAT is AN ENVIRONMENTAL RECEPTOR? '•'"'.
The environmental receptors you need to consider.are limited to natural areas such as
national or state parks, forests, or monuments; officially designated wildlife
sanctuaries, preserves, refuges, or areas; and Federal wilderness areas. All of these
areas can be identified on local U.S. Geological Survey maps.
WHAT ARE RESTORATION AND RESPONSE ACTIVITIES?
The type of restoration and response activity conducted to address the impact of an
accidental release will depend on the type of release (volatilized spill, vapor cloud,
fire, or explosion), but may include such activities as:
October 26,1998
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Chapter 2
Applicability of Program Levels
2-10
Collection and disposal of dead animals and contaminated plant life;
Collection, treatment, and disposal of soil;
Shutoff of drinking water;
Replacement of damaged vegetation; or
Isolation of a natural area due to contamination associated with an accidental
release.
Q&A
ENVIRONMENTAL RECEPTORS
Q. Do environmental receptors include areas that are not Federal Class I areas under the CAA?
A. Yes. The list of environmental receptors in Part 68 includes areas in addition to those that qualify
as Federal Class I areas under CAA section 162. Under Part 68, national parks, monuments,
wilderness areas, and forests are environmental receptors regardless of size. State parks, monuments,
and forests are also environmental receptors.
DOCUMENTING PROGRAM 1 ELIGIBILITY
For every Program 1 process at your facility, you must keep records documenting the
eligibility of the process for Program 1. For each Program 1 process, your records
should include the following:
+ A description of the worst-case release scenario, which must specify the
vessel or pipeline and substance selected as worst case, assumptions and
parameters used, and the rationale for selection. Assumptions may include
use of any administrative controls and any passive mitigation that were
assumed to limit the quantity that could be released;
4- Documentation of the estimated quantity of the worst-case release, release
rate, and duration of release;
+ The methodology used to determine distance to endpoints;
+ • Data used to determine that no pub-lie receptor would be affected; and
4> Information on your coordination with public responders.
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. Chapter 2
2-11 Applicability of Program Levels
Qs&As
ACCIDENT HISTORY
Q. What is the relationship between the accident history criteria for Program 1 and the five-year
accident history? If my process is eligible for Program 1, do I still need to do a five-year accident
history?
A. The five-year accident history is an information collection requirement that is designed to
provide data on all serious accidents from a covered process involving a regulated substance held
above the threshold quantity. ••'*''. , ,
In contrast, the Program 1 accident history criteria focus on whether the process in question has the
potential to experience a release of the regulated-substance that results in harm to the public based
on past events. Onsite effects, shelterings-in-place, and evacuations that have occurred must be >
reported in the five-year accident history, but they are not considered in determining Program 1
eligibility. Therefore, it is possible for process to be eligible for Program 1 and still have
experienced a release that must be reported in the accident history for the source.
Q. A process with more than a threshold quantity of a regulated substance had an accident with
offsite consequences three years ago. After the accident, we altered the process to reduce, the
quantity stored on site. Now the worst-case.release scenario indicates that there are no public
receptors within the distance to an endpoint. Can this process qualify for Program 1 ?
A. No, the process cannot qualify for Program 1 until five years have passed since any accident
with consequences that disqualify a process for Program 1.
Q. A process involving a regulated substance had an accidental release with offsite consequences
two years ago. The process has been shut down. Do I have to report anyway?
A. No. The release does not have to be included in your accident history. Your risk management
plan only needs to address operating processes that have more than a threshold quantity of a
regulated substance.
2.4 QUICK RULES FOR DETERMINING PROGRAM 1 ELIGIBILITY
You generally will not be able to predict with certainty that the worst-case scenario for
" ' ' a particular process will-meet the criteria for Program L 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 identifying processes, that may be
- eligible for Program 1.
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Chapter 2
Applicability of Program Levels 2-12
Toxic GASES
If you have a process containing more than a threshold quantity of chlorine, ammonia,
or sulfur dioxide or any other regulated toxic gas that is not liquefied by refrigeration
alone (i.e., you hold it as a gas or liquefied under pressure), the distance to the
endpoint estimated for a worst-case release of the toxic gas will generally be several
miles. As a result, the distance to endpoint is unlikely to be less than the distance to
public receptors, unless the process is very remote. In some cases, however, toxic
gases in processes in enclosed areas may be eligible for Program 1.
REFRIGERATED Toxic GASES
If you have a process containing anhydrous ammonia liquefied by refrigeration alone,
and your worst-case release would take place into a diked area, the chances are good
that the process may be eligible for Program 1, unless there are public receptors very
close to the process. Even if you have many times the threshold quantity of ammonia,
the process may still be eligible for Program 1.
The worst-case analysis for a process containing chlorine liquefied by refrigeration is
unlijkely to show eligibility for Program 1, unless your site is extremely remote from
the public or the release would occur within an enclosure.
Toxic LIQUIDS
The distance to an endpoint for a worst-case release involving toxic liquids kept under
ambient conditions may be smaller than the distance to public receptors in a number
of cases. If public receptors are not found very close to the process (within Vz mile),
the process may be eligible for Program 1. However, facilities on small acreage sites
are highly unlikely to meet to be eligible for Program 1 if they are in a developed area-.
Remotely located facilities or processes found near the center of large (acreage) sites
are more likely to be eligible.
WATER SOLUTIONS OF TOXIC SUBSTANCES
The list of regulated substances includes several common water solutions of toxic
substances. Processes containing such solutions (e.g., aqueous ammonia) at ambient
temperatures may be eligible for Program 1 (depending 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,
facilities on small acreage sites in developed areas are highly unlikely to be eligible for
Program 1; remotely located facilities or processes found near the. center of large
acreage sites are more likely to be eligible.
FLAMMABLE SUBSTANCES
Many processes containing regulated flammable substances are likely to be eligible for
Program 1, unless there are public receptors within a very short distance. If you have
a process containing up to about 20,000 pounds (twice the threshold quantity)
October 26,1998
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Chapter 2
2-13 Applicability of Program Levels
of methane or propane, your process is likely, to be eligible for Program 1 if you have
no public receptors within about 400 yards (1,200 feet) of the process. If you have up
to 100,000 pounds in a process (ten times the threshold quantity), the process may be
eligible for Program 1 if there are no public receptors within about 700 yards (2,000
feet). In general, it would be -worthwhile to conduct a worst-case analysis for any
processes containing only flammables to determine Program 1 eligibility, unless you
have public receptors very close to the process. Consequently, you may have to
- conduct more worst-case analyses if you want to qualify processes for Program 1; for
Program 2 and 3_processes,>you need analyze only one worst-case release scenario to
cover all flammables. For Program 1, you must be able to demonstrate, through your
worst-case analysis, that every process you claim is Program 1 meets the criteria.
Remember that the Program level designation for a process is based on the regulated
substance that has 'the greatest distance to an endpoint. If your digesters are
considered part of a process that includes chlorine, ammonia, or sulfur dioxide, the
•< . toxics will .determine whether the process is eligible for Program 1 because the
distances to an endpoint will be greater for the toxics.
2.5 PROGRAMS
Any covered process that is not eligible for Program 1 and is subject to OSHA PSM
under federal or state law is subject to Program 3 requirements, which include risk
' management measures and requirements virtually identical to the OSHA PSM
Standard. (The other criterion for Program 3 (§ 68.10(d)(l)) does not apply to
- WWTPs,) . •
WHAT is THE OSHA PSM STANDARD? "
The OSHA Process Safety Management standard (codified at 29 CFR 1910.119) is a
. set of procedures in thirteen management areas designed to protect worker health and
: safety in case of accidental releases. Similar to EPA's nile, OSHA PSM applies to a
range of facilities that have more than a threshold quantity of a listed substance in a
process. All processes subject to this rule and the OSHA PSM standard (federal or
' " state) and not eligible for Program 1 are assigned to Program 3 because the Program 3
prevention program is virtually identical to the elements of the PSM standard. If you
are already complying with OSHA PSM for a process, you probably will need to take
few, if any, additional steps and develop little, if any, additional documentation to
meet the requirements of the Program 3 prevention elements (see Chapter 7 for a
discussion of differences between Program 3 prevention and OSHA PSM). EPA
placed all covered OSHA PSM processes in Program 3 to eliminate the possibility of
imposing overlapping, inconsistent requirements- on the same process.
Private WWTPs are likely to be subject to OSHA PSM for processes containing more
; man a threshold quantity of chlorine, .anhydrous ammonia, or sulfur dioxide. POTWs
in states with delegated OSHA programs are subject to the PSM standard if they have
, more than a threshold quantity of these substances.
October 26, 1998
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Chapter 2
Applicability of Program Levels 2-14
QSHA's thresholds are generally lower than EPA's so it is possible that you may have
a process that is subject to OSHA PSM and is not covered by part 68. For example, if
you store a single, one-ton cylinder of chlorine, OSHA PSM will coer it because it has
a 1,500 pound threshold for chlorine, but EPA's part 68 will not because its threshold
quantity for chlorine is 2,500 pounds.
OSHA PSM covers the production of methane in digesters, but does not cover
propane or methane when used as a fuel unless the process is otherwise subject to
OSHA PSM. If you capture methane from your digesters, store it, and then pipe it
back to heat the digesters, the methane storage and piping would be subject to OSHA
PSM because the digester (production of methane) is covered by PSM and the storage
and piping are interconnected and considered part of the same process.
OSHA PSM covers aqueous ammonia at a concentration of greater than 44 percent (as
opposed to EPA's 20 percent or greater); therefore, your aqueous ammonia process
may not be subject to OSHA PSM.
2.6 PROGRAM 2
Program 2 is considered a default program level because any covered process that is
not: eligible for Program 1 or assigned to Program 3 is, by default, subject to Program
2 requirements, including a streamlined accident prevention program. One or more
processes at your facility are likely to be in Program 2 if:
•*• You use propane (or other flammable) as a fuel for heating.
+ You are a publicly owned facility in a state that does not have a delegated
OSHA program.
+ You use aqueous ammonia in solutions with greater than 20 percent
concentration but less than 44 percent concentration.
+ You use regulated acids in solution in activities.
•*• • You store regulated liquid flammable substances in atmospheric storage tanks.
The last two of these conditions are unlikely to apply to WWTPs.
WHAT ARE THE ELIGIBILITY CRITERIA FOR PROGRAM 2?
Your process is-subject to Program 2 if: • '•
•*• Your process does not meet the eligibility requirements for Program 1; and
•*• , Your process is not subject to OSHA PSM (state or federal). •
October 26,1998
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2-15
Chapter 2
Applicability of Program Levels
When determining what program level is appropriate for your covered process, keep
in mind that if it does not meet the Program 1 criteria and it is not covered by OSHA
PSM, the process automatically is subject to Program 2 requirements.
Exhibit 2-4 provides a summary of the criteria for determining Program level: '
EXHIBIT 2-4
PROGRAM LEVEL CRITERIA
Program 1
No accidents in the previous five
years that resulted in any bffsite:
Death
Injury- .
Response or restoration
activities at an
environmental receptor
* . *~\. "w>?£^r-'~**« v /*Fn»* 1* **
',."3 ^ *"V 4ND.» ~~ * >
No public receptors in worst-case
circle.
li^^^^'B'S^'^r-^^M-^^^' ''^.-^'^Ai-,^
Emergency response coordinated
with local responders.
Program 2
The process is not eligible for
Program I or subject to Program 3.
\ ^ < ^ ?*
* ^ ^~ ^ ** *^ 4
* ^ '*• I -
- i '
Vf-K^i'.'s "f;'&!SiiJ&i- .&\ ^"jgi'v/.^. _ .. _ J-",, *;-,!
Programs
Process is not eligible for Program
. I." ' '. _'
~: ;."^> *&*>7' ".*»*•"'-*
Process is subject to OSHA PSM.
; ;,:.-^i*-t- AV; ";S;g:%^|':v *^;;>*>' .?;<>'
,: •, "'%&!&>£:'.''} JS^^Wfect^^iiAr '"
Process is classified in SIC code
261 1 -Pulp Mills
2812 - Clor-Alkali Manufacturers
28 1 9 - Industrial Inorganics
282 1 - Plastics and Resins
2865 - Cyclic Crudes and
Intermediates
2869 - Industrial Organics
2873 - Nitrogen Fertilizer
Manufacturers
2879 - Agricultural Chemicals
29 1 1 - Petroleum Refineries
Note: EPA has proposed to revise part 68 to reflect the shift to the new North American Industry
Classification System (NAICS) codes. Check the hotline or the CEPPO web page for up-to-date
information on the changes.
October 26,1998
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Chapter 2
Applicability of Program Levels
2-16
2.7 DEALING WITH PROGRAM LEVELS
WHAT IF I HAVE MULTIPLE PROGRAM LEVELS?
If you have more than one covered process, you may be dealing with multiple program
levels in your risk management program.
If your facility has processes subject to different program levels, you will need to
comply with different program requirements for different processes. Nevertheless,
you must submit a single RMP for all covered processes.
If you prefer, you may choose to adopt the most stringent applicable program level
requirements for all covered processes. For example, if you have three covered
processes, one eligible for Program 1 and two subject to Program 3, you may find it
administratively easier to follow the Program 3 requirements for all three covered
processes. Remember, though, that this is only an option; we expect that most sources
will comply with the set of program level requirements for which each process is
eligible.
QS&AS
OSHA
Q. If my state administers the OSHA program under a delegation from the federal OSHA, does that
mean that my processes that are subject to OSHA PSM under the state rules are in Program 3?
A. Yes, as long as the process does not qualify for Program 1. Any process subject to PSM, under
federal or state rules, is considered to be in Program 3 unless it qualifies for Program 1.
Q. I am a publicly owned facility in a state with a delegated OSHA program. Why are my processes
considered to be in Program 3 when the same processes in a state where federal OSHA runs the
program are in Program 2?
A. Federal OSHA cannot impose its rules on state or local governments, but when OSHA delegates its
program to a state for implementation, the state imposes the rules on itself and local governments.
Because these governments are complying with the identical OSHA PSM rules imposed by federal
OSHA, they are subject to Program 3. In meeting their obligations under state OSHA rules, they are
already substantially in compliance with the Program 3 prevention program requirements. State and
local governments in non-state-plan states are not subject to any OSHA rules and must comply with
Program 2.
CAN THE PROGRAM LEVEL FOR A PROCESS CHANGE?
A change in a covered process or in the surrounding community can result in a change
in the Program level of the process. If this occurs, you must submit an updated RMP
within six months of the change that altered the program level for the
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Chapter 2
2-17 Applicability of Program Levels
covered process. If the process np longer qualifies as a covered process (e.g., as a
result of a change in the quantity of the regulated substance in the process), then you
will need to amend your RMP registration within six months (see Chapter 9 for more
information). Typical examples of switching program levels include:
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 loqated within the distance to the endpoint for a worst-case release for that
process: The process is, thus, no longer eligible for Program 1 and must be evaluated
to determine whether Program 2 or Program 3 applies. You must submit a revised
• RMP within six-months of the program level change, indicating and documenting that
your process is now in compliance with the new program level requirements.
From Not Covered to Program 1,2 or 3. You have a process that was not
originally covered by part 68, but, due to an expansion in production, the process
holds an amount of regulated substance that now exceeds the threshold quantity. You
must determine which Program level applies and come into compliance with the rule
by June 21, 1999, or by the time you exceed the threshold quantity, whichever is later.
, From Program 2 to Program 3. You have a process that involves a regulated
substance above the threshold that had not been subject to OSHA PSM. However,
due to one of the following OSHA regulatory changes, the process is now subject to
the OSHA PSM standard:
*• Your state is granted delegation by federal OSHA to implement OSHA
standards in your state;
+• An OSHA PSM fuel use exemption applicable to your process has been
eliminated, or
+ The regulated substance has been added to OSHA's list of highly hazardous
substances (this is unlikely for WWTPs because the chemicals you use are
already subject to PSM). :
As a result, the process becomes subject to Program 3 requirements and you must
submit a revised RMP to EPA within six months, indicating and documenting that
your process is now in compliance with the Program 3 requirements.'
SWITCHINGDOWN - ,
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
October 26, 1998
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Chapter 2
Applicability of Program Levels 2-18
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 2 or 3 to Not Covered. You have a covered process that has been
subject to Program 2 or 3 requirements, but due to a reduction in production, the
amount of a regulated substance it holds no longer exceeds the threshold. Therefore,
the process is no longer a covered process. You must submit a revised RMP within
six months indicating that your process is no longer subject to any program level
requirements.
2.8 SUMMARY OF PROGRAM REQUIREMENTS
Regardless of the program levels of your processes, you must complete a five-year
accident history for each process (see Chapter 3) and submit an RMP that covers all
processes (see Chapter 9). Depending on the Program level of each of your processes,
you must comply with the additional requirements described below. Exhibit 2-5
diagrams the requirements in general and Exhibit 2-6 lists them in more detail.
PROGRAM 1
For each Program 1 process, you must conduct and document a worst-case release
analysis. You must coordinate your emergency response activities with local
respbnders and sign the Program 1 certification as part of your RMP submission.
PROGRAMS 2 AND 3
For all Program 2 and 3 processes, you must conduct and document at least one
worst-case release analysis to cover all toxics and one to cover all flammables. You
may need to conduct additional worst-case release analyses if worst-case releases from
different parts of your facility would affect different public receptors. You must also
conduct one alternative release scenario analysis for each toxic and one for all
flammables. See Chapter 4 of the RMP Offsite Consequence Analysis Guidance for,
specific requirements. You must coordinate your emergency response activities with
local responders and, if you use your own employees to respond to releases, you must
develop and implement an emergency response program. See Chapter 8 for more
details.
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.
October 26,1998
-------
EXHIBIT 2-2
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-Yea'r
Accident History
Implement
Management System
Implement Program
Level 2 Prevention
Program
Implement Program
Level 3 Prevention
Program
Implement Emergency
Response Program
(if applicable)
Coordinate with Local Responders
Prepare and Submit One Risk Management Plan for all Covered Processes
-------
Chapter 2
Applicability of Program Levels
2-20
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.
EXHIBIT 2-6
COMPARISON OF PROGRAM REQUIREMENTS
Program 1
Worst-case release analysis
5-year accident history
Program 2
Worst-case release analysis
Alternative release analysis
5-year accident history
Document management system
Program 3
Worst-case release analysis
Alternative release analysis
5-year accident history
Document management system
Prevention Program
Certify no additional prevention
steps needed
-
Safety Information
Hazard Review
Operating Procedures
Training
Maintenance
Incident Investigation
Compliance Audit
Process 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
October 26,1998
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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 process and involve a regulated
. substance held above its threshold quantity in the process.
•*• The release must have caused at least one of the following:
> On-site deaths, injuries, or significant property damage (§68.42(a));
, or •:•••' ' . •'•..-•'. "''•'•
> Known offsite deaths, injuries, property damage, environmental
• . damage, evacuations, or sheltering in place (§68.42(a)).
If you have had a release of a regulated substance from a process where the regulated
substance is held below its threshold quantity, you do not need to report that release
even"if the release caused one of the listed impacts or if the process is covered for
some other substance. You-may choose to report the release in the five-year accident
f 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 are those used for the RMP*Submit system
October 26,1998 ' , . . "
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Chapter 3
Five-Year Accident History 3-2
and data element instructions:
Date. Indicate the date on which the accidental release began.
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 clos§ to that as possible.
For example, if you estimate that the release was between 850 and 900 pounds,
provide a best guess. We realize that you may not know precise quantities. For
'flammable mixtures, you may report the quantity of the mixture, rather than that of the
individual regulated substances.
Release event. Indicate which of the following release events best describes your
accident. Check all that apply:
4 Gas Release. A gas release is a release of the substance as a gas
(rather than vaporized from a liquid). If you hold a gas liquefied under
refrigeration, report the release as a liquid spill.
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.
1 *' «'
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.
October 26,1998
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. Chapters
3-3 •_ . Five-Year Accident History
+ Piping. Piping refers to a system of tubular structures or pipes.used to
carry a fluid or gas. . .
+ Process Vessel. A process vessel is a container in which substances
under certain conditions (e.g., temperature, pressure) participate in a
process (e.g., 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 oh-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 tKe following:
+ Wind Speed and Direction. Wind speed is" an estimate of how fast the
wind is traveling. Indicate the speed in miles per hour. Wind direction
" is the direction from which the wind comes. For example, a wind that
blows from east to west would be described as having an eastern wind
direction. You may describe wind direction as a standard compass
reading such as "Northeast" or "South-southwest."
You may also describe wind direction in degrees—with North as zero degrees-
and East as 90 degrees. Thus, northeast would represent 45 degrees and
south-southwest would represent 202.5 degrees. Abbreviations for the wind
October 26, 1998
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Chapter 3
Five-Year Accident History 3-4
direction such as NE (for northeast) and SSW (for south-southwest) are also
acceptable.
Temperature. The ambient, temperature at the scene of the accident in
degrees Fahrenheit. If you did not keep a record, you can use the high
(for daytime releases) or low (for nighttime releases) for the day of the
release. Local papers publish these data.
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, 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 sky conditions during the hour preceding or following the
night. 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.
October 26,1998
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3.5
Chapters
Five-Year Accident History
EXHIBITS-!
ATMOSPHERIC STABILITY CLASSES
, SURFACEvWlND SPEED''
AX 10,MSTERS ABbVJE ,^
; <'^ GROUND " J>^*
Meters per
second -
<2
2-3
3-5 •'
5-6
>6
\
Miles per
hour .
<4.5 '
4.5-7
7-11
11-13
>13
•>"" - '-s DAY //, ~
Jte -^ t «.1 "* •^r-v ^ v * C, f
' •> f - ^ ~J ^ ^ >^ ^
v V;** ' *.-'>'
^ "* r * r , i>
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
**>, ,« NIGHT^ ^ \ - :
,,} v,^ ,v ,-.. -<,„,
v ~ ,-'-V ?'&"* '' *
Thinly
Overcast
or > 4/8
low clou
E
D
D
D
£ 3/8
. Cloud
F
E
D
P
f 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.
On-site impacts. Complete the following about oi)-site effects.
• " • • > • i
~ 4> 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, bffsite 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, off site responder, and other on-site deaths
' -." separately. , "
•^ Injuries. An injury is any effect that result's 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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Chapter 3
Five-Year Accident History 3-6
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.
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 requked 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, pr 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.
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Chapters
3-7 " . . Five-Year Accident History
•*• 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 te
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 envkorimerit (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.
> Lawn, shrub, or-crop damage minor defoliation.
> Lawnv 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.
+ Equipment Failure. A device or piece of equipment failed or did not
function as designed. For example, the vessel wall corroded or
cracked. • ,
+ Human Error. An operator performed a task improperly, either by
failing to take the necessary steps or by taking the wrong steps.
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Chapter 3
Five-Year Accident History 3-8
+ Weather Conditions. Weather conditions, such as lightning, hail, ice
storms, tornados, hurricanes, floods, or high winds, caused the
accident.
+ Unknown.
Contributing factors. These are factors that contributed to the accident, but were not
the initiating event. If you conducted an investigation of the release, you may have
identified factors that led to the initiating event or contributed to the severity of the
release. Indicate all that apply.
+ Equipment Failure. A device or piece of equipment failed to function
as designed, thereby allowing a substance leading to or worsening the
accidental release.
+ Human error. An operator performed an operation improperly or
made a mistake lead to or worsened the accident.
, ''i ",.';: '.''>' ,
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.
Upset Condition. Incorrect process conditions (e.g.,
temperature or pressure) contributed to the release.
increased
By-pass Condition. A failure occurred in a pipe, channel, or valve that
diverts fluid flow from the main pathway when design process or
storage conditions are exceeded (e.g., overpressure). By-pass
conditions may be designed to release the substance to restore
acceptable process or storage conditions and prevent more severe
consequences (e.g., explosion).
\
Maintenance Activity/Inactivity. A failure occurred because of ••••
maintenance activity or inactivity. For example, the storage racks
remained unpainted for so long that corrosion caused the metal to fail.
Process Design. A failure resulted from an inherent flaw in the design
of the process (e.g., pressure needed to make product exceeds the
design pressure of the vessel).
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Chapters
3-9 Five-Year Accident History
+ 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, or high winds contributed
to the acqident.
<* 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 tije 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.
+ 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.
4 New Process Controls. New process designs and controls were
installed to correct problems and prevent recurrence of an accidental
release.
4- Ne\v Mitigation Systems. New mitigation systems were initiated to
limit the severity of accidental releases.
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Chapter 3
Five-Year Accident History 3-10
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 (a) 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:
4; The chemical name or identity of any substance involved in the release
4 An indication of whether the substance is on the list referred to in
Section 302(a)
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Chapter 3
3-11 Five-Year Accident History
4 An estimate of the quantity of substance that was released into the
environment
•* The time and duration of the release
4 The medium or media into which the release Occurred.
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:
4- Chemical name or identity of all substances involved in the accident
4 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 previpusly 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,
+ ' Column C:.name of injured person
+ Column F: description of nature of injury or illness
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Chapter 3
Five-Year Accident History 3-12
Injury portion of the log:
+ Column. 1: date of death is entered if an occupational injury results in
afatality
+ 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 havfe 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
+ Date investigation began
^ Description of the incident
+ Factors that contributed to the incident
4- Any recommendations resulting from the investigation.
Because the incident investigation report must be retained for five years, you will have
a record for completing the five-year accident history for updates, of the RMP.
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: -Chapters
3-13 . Five-Year Accident History
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 facj .-.ty has recently changed- ownership;, is the new facility owner required to include accidents,
which occurred prior to the transfer of ownership in the accident history portion of the RMP submitted
for the facility? ' , / ,
A. Yes, accidents involving covered processes that occurred prior to the transfer of ownership should
be included in the five-year accident history. You may want to explain that the ownership has changed
in your Executive Summary.
Q. If I have a large on-site incident, but no offsite impact, would 1 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. ,
October 26; 1998
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CHAPTER 4: OFFSITE CONSEQUENCE ANALYSIS
You are required to conduct an bffsite consequence analysis to provide information to
the government and the public about the potential consequences of an accidental
chemical release at your facility. The offsite consequence analysis (OCA) consists of
two elements: ,
4- A worst-case release scenario apd
4- Alternative release scenarios.
To simplify the analysis and ensure a common basis for comparisons, EPA has
defined the worst-case scenario as the release of the largest quantity of a regulated
substance from a single vessel or process line failure that results in the greatest
distance to an endpoint. In broad terms^ the distance to the endpoint is the distance a
toxic vapor cloud, heat from a fire, or blast waves from an explosion will travel before
dissipating to the point that serious injuries from short-term exposures will no longer
occur. • .
This chapter gives guidance on how to perform the OCA for the six regulated
substances that are used or produced at WWTPs: "
4- Chlorine (toxic)
4- Sulfur dioxide (toxic) . = ,
4- Anhydrous ammonia (toxic)
'4- Aqueous ammonia (20 percent or greater, toxic)
4- Methane (digester gas, flammable), and .
4- Propane (flammable). '•••..
Exhibit 4-1, shows the'basic steps used to conduct the OCA. :•
RMP*Comp™
To assist those using this guidance, the National Oceanic and Atmospheric Administration (NOAA)
and EPA have developed a software program, RMP*C6mp™, that performs the calculations
described in this document. ThiS software can be downloaded from the NOAA Internet website at
http://response.restoration.noaa.gov/chemaids/rmp/rmp.html.
The methodology and reference tables of distances presented here are optional.
You are not required to use this guidance. You may use publicly available or
proprietary air dispersion models to do your o,ffsite 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.
October 27, 1998
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EXHIBIT. 4-1
STEPS FOR OFFSITE CONSEQUENCE ANALYSIS
Gather Basic Data
(quantities and process conditions)
Select Scenario
Toxics
Worst-case and Alternative Release
Flammables
Alternative Release
Estimate Rate of
Release
Flammables
Worst-case Release
Define Distance to Endpoint of Concern
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Chapter 4
4-3 - Offsite Consequence Analysis
Some of the results obtained using the methods in this document may be conservative
'•. ' (i.e., they may overestimate the distance to endpoints). Complex models that can
account for many site-specific factors may give less conservative estimates of offsite
consequences than the simple methods used in this guidance. This is particularly true
, for alternative scenarios, for which EPA has not specified many assumptions.
However, complex models may be expensive and require considerable expertise to
use; this guidance is designed to be simple and straightforward. You will need to
consider these tradeoffs in deciding how to! carry out your required consequence
analyses.
This chapter presents discussions and tables for the worst-case scenario for all six .
substances listed above (section 4.1), followed by discussions and tables for
alternative scenarios for the six substances (section 4.2). Because many WWTPs store
; chlorine and sulfur dioxide in buildings, section 4.3. discusses methods for estimating
the mitigating effects of buildings. The remaining sections provide guidance on
defining offsite impacts (section 4.4), documentation (section 4.5), and the symbols
used in the chapter (section 4.6).
. ' . . The guidance presented in this chapter is intended for users — that is, it does not
contain'any explanations of how the guidance was derived. Those readers who are
interested in obtaining an explanation can obtain from EPA a document entitled
Backup Information for the Hazard Assessments in the RMP Offsite Consequence
Analysis Guidance, the Guidance for Wastewater Treatment Facilities and the
Guidance for Ammonia Refrigeration—Anhydrous Ammonia, Aqueous Ammonia,
Chlorine and Sulfur Dioxide. ' > •
4.1 WORST-CASE RELEASE SCENARIOS
, This section provides guidance on how to analyze worst-case scenarios. Information
. is provided on the general requirements of the regulations, followed by specific
sections on chlorine, sulfur dioxide, anhydrous ammonia, aqueous ammonia, methane
and propane. Exhibit 4-2 presents the parameters that must be used in worst-case and
alternative release scenarios. , ;
GENERAL REQUIREMENTS FOR Toxic SUBSTANCES - ,
The following information is required for worst-case release analysis of toxic
' substances:
The worst-case release quantity Q (Ib) is the greater of the following:
+ For substances in vessels, the greatest amount held in a single vessel, taking
into account administrative controls that limit the maximum quantity; or
+ For substances in pipes, the greatest amount in a pipe, taking into account •
administrative controls that limit the maximum quantity.
For vessels, you need only consider the largest amount in the vessel, regardless of
interconnections with pipes and other vessels. Similarly, if the largest quantity is
October 27, 1998
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Chapter 4
Offsite Consequence Analysis 4-4
contained in a pipe, you need not add the quantity in vessels at the end of the
pipelines. You may be able to think of scenarios in which a quantity greater than Q as
defined above can be released, but EPA does not require you to model such scenarios
as worst-case (you may want to consider modeling them as alternative scenarios).
Weather conditions. The rule allows anyone who conducts his or her OCA based on
this guidance to use specific default weather conditions for wind speed, stability class,
average temperature, and humidity. Liquids other than gases liquefied by refrigeration
should be considered to be released at the highest daily maximum temperature, based
on local data for the previous three years, or at process temperature, whichever is the
higher. You can obtain weather data from local weather stations. You can also obtain
temperature and wind speed data from the National Climatic Data Center at (828)
271-4800.
For the worst-case scenario, the release must be assumed to take place at ground level.
The toxic endpoints are:
Ammonia 0.14 mg/L (200 ppm)
Chlorine '0.0087 mg/L (3 ppm)
Sulfur Dioxide 0.0078 mg/L (3 ppm)
These airborne concentrations are the maximum airborne concentrations below which
it is believed that nearly all individuals can be exposed for up to one hour without
experiencing or developing irreversible or other serious health effects or symptoms
which could impair an individual's ability to take protective action.
The regulations require you to take account of whether your site is rural or urban. The
regulations state that "urban means that there are many obstacles in the immediate
area; obstacles include buildings or trees. Rural means that there are no buildings in
the immediate area and the terrain is generally flat or-unobstructed." Some areas
outside of cities may still be considered urban if they are forested.
The regulations require you to use tables or models for atmospheric dispersion
analysis that appropriately account for gas density. For the specific case of WWTPs,
chlorine and sulfur dioxide are always dense gases (that is, denser than air).
Anhydrous ammonia, if released from the liquid space of a container in which it is
liquefied under pressure, forms a denser-than-air vapor cloud. Ammonia evaporating
from a pool of aqueous ammonia is treated as neutrally buoyant (that is, it has about
the same density as air). •
You are only allowed to take account of passive mitigation systems, not active ones.
Passive mitigation systems could include:
'+ Diked areas that confine a liquid pool and reduce the surface area available
for evaporation
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4-5
Chapter'4
Offsite Consequence Analysis
EXHIBIT 4-2
REQUIRED PARAMETERS FOR MODELING (40 CFR 68.22)
WORST CASE
ALTERNATIVE SCENARIO
Endpoints (§68.22(a)) . ,
Toxic endpoints are listed in part 68 Appendix A.
For flammable substances, endpoint is overpressure of 1
pound per square inch (psi) for vapor cloud explosions.
Toxic endpoints are listed in part 68 Appendix A.
4-For flammable substances, endpoint is overpressure of 1 psi for
vapor cloud explosions -
4-Radiant heat level of 5 kilowatts per square meter (kW/m2) for
40 seconds for heat from fires (or equivalent dose)
•f Lower flammability limit (LFL) as specified in NFPA
documents or other generally recognized sources for vapor cloud
fires.
Wind speed/stability (§68.22(b))
This guidance assumes 1.5 meters per second and F
stability. For other models, use wind speed of 1.5
meters per second and F stability class unless you can
demonstrate that local meteorological data applicable to
the site show a higher minimum wind speed or less
stable atmosphere at all times during the previous three
years. If you can so demonstrate, these minimums may
be used for site-specific modeling.
This guidance assumes wind speed of 3 meters per second and
stability. For other models, you may use typical meteorologica
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 arid
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, a
appropriate. <
Dense or neutrally buoyant gases (§68.22(f)) . .
Tables or models used for dispersion of regulated toxic
substances must appropriately account for gas density. '
Tables or models used for-dispersion must appropriately account
for gas density.
Temperature of released substance (§68^2(g))
You must consider liquids (other than gases liquefied by
refrigeration) to be released at the highest daily
maximum temperature, from data for the previous three
years, or at process temperature, whichever is higher.
Assume gases liquefied by refrigeration at atmospheric '
pressure to be released at their boiling points.
Substances may be considered to be released at a process or
ambient temperature that is appropriate for the scenario.
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Chapter 4
Offsite Consequence Analysis 4-6
4- Buildings, provided that the building can be shown to withstand the events
that caused the release (see Section 4.3 for more information)
Active mitigation systems include:
4- Automatically closing or remotely operated valves
4- Sprays and deluge systems
4- Relief valves
4- Check valves
4- Excess flow valves
4- Scrubbers
The predicted frequency of occurrence of the worst-case scenario is not an allowable
consideration. You are not required to determine a possible cause of the failure of the
vessel or pipe.
GENERAL REQUIREMENTS FOR FLAMMABLE SUBSTANCES
As for toxic substances, the worst-case release quantity Q is either the greatest amount
held in a single vessel or the greatest amount in a pipe. In both cases, you may take
into account administrative controls that limit the maximum capacity. In the case of
the vessel, you need only take into account the quantity in the vessel, regardless of any
connections with other vessels.
The worst-case analysis assumes the quantity vaporizes. There is a vapor cloud
explosion. If you use a TNT-equivalent model to determine the distance to the
endpoint, you must assume that 10 percent of the total quantity is involved in the
explosion (that is, the yield factor is 10 percent).
You must determine the distance to the explosion endpoint; that is, the distance at
which there is an overpressure of 1 psi (the fartherest distance from the point of
release at which the explosion causes the pressure on a person or building to exceed
atmospheric pressure by 1 psi).
CHLORINE
At WWTPs, chlorine is most likely to be present in 150-lb cylinders, in one-ton
(2,000-lb) cylinders, in 17-ton tank trucks, or in 90-ton railcars. The worst-case
scenario assumes that these quantities are completely released over a period of 10
minutes (e.g., a 150-lb worst case corresponds to a 15-lb/min rate of release). The
predicted distances to the toxic endpoint for each of these scenarios is -given in Exhibit
4-3. These distances are for releases that are assumed to take place outdoors. See
Section 4.3 for a discussion on buildings.
October 27, 1998
-------
4-7
Chapter 4
Offsite Consequence Analysis
EXHIBIT 4-3
DISTANCES TO TOXIC ENDPOINTS - CHLORINE
F Stability, Wind Speed 1.5 Meters per Second
Scenario
150-lb cylinder
1-ton cylinder
17-ton tank trucks
90-ton railcar
Release Rate
(Ib/min)
15
200
3,400
18,000
Distance to Toxic Endpoint (miles)
Rural
: 0.8
3.0
12
' . : > 25
Urban
0.4
1.3
5.8
14
If your facility does not fit into the standard pattern of 150-lb cylinders, one-ton
cylinders, 17-ton tank trucks, or 90-ton railcars, you should use Figure 4-1 or
Exhibit 4-4. Identify the chlorine vessel that contains the largest quantity of any in
your facility and divide that mass by 10 to obtain the release rate in Ib/min. Look for
that release rate, or the rate nearest to it, in Exhibit 4-4. Then read across to the rural
or urban distances.. ' . .
Alternatively, look along the bottom axis of Figure 4-1, read up to the curve(s) and
then across to the corresponding distances on the vertical axis.
As noted above, the results presented in Exhibit 4-3 and 4-4 are for a release that is
outside. Many of you will keep your chlorine vessels inside buildings. Some will
even have specially designed, leak-tight buildings with chlorine or sulfur dioxide
scrubbers. However, the intention of this section is to provide information on the
worst-case scenario. There are times when you will be handling the cylinders outside.
Nevertheless, in discussions with local agencies and local communities you may well
want to explain how your facility is designed to prevent or mitigate worst-case
scenarios. '
October 27, 1998
-------
Chapter 4
Offsite Consequence Analysis
4-8
EXHIBIT 4-4
DISTANCES TO TOXIC ENDPOINT FOR CHLORINE
F Stability, Wind Speed 1.5 Meters per Second
Release Rate
(Ibs/min)
•
1
2
5
10
15
20
30
40
50
60
70
80
90
100
150
200
250
300
400
500
600
700
Distance to Endpoint (miles)
Rural
0.2
0.3
0.5
0.7
0.8
1.0
1.2
1.4
1.5
1.7
1.8
1.9
2.0
2.2
2.6
3.0
3.4
3.7
4.2
4.7
5.2
5.6
Urban
0.1
0.1
0.2
0.3.
0.4
0.4
0.5
0.6
0.6
0.7
0.8
0.8
0.9
0.9
1.2
1.3
1.5
1.6
1.9
2.1
2.3
2.5
Release Rate
(Ibs/min)
750
800
900
1,000
1,500
2,000
2,500
3,000
4,000
5,000
6,000
7,000
7,500
«,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)
These are results that you can simply quote when you submit your RMP.
SULFUR DIOXIDE
Sulfur dioxide, if present at a WWTP, is also likely to be in 150-lb cylinders, one-ton
cylinders, 17-ton tank cars, or 90-ton railcars. The worst-case scenario assumes that
these quantities are completely released over a period of 10 minutes. The predicted
distances to the toxic endpoint for each of these scenarios is given in Exhibit 4-5.
October 27,1998
-------
4-9
Chapter 4
Offsite Consequence Analysis
EXHIBIT 4-5
DISTANCES TO TOXIC ENDPOINT - SULFUR DIOXIDE
F Stability, Wind Speed 1.5 Meters per Second
Scenario
150-lb cylinder
1 -ton cylinder
17-ton tank trucks
90-ton railcar
Release Rate
(Ib/min)
15
200
3,400
18,000
Distance to Toxic Endpoint (miles)
Rural
0.7
3.1 '
•15-' ;
. >25
Urban
0.3
1.3
6.0
15
These are results that you can simply quote when you submit your RMP.
If your facility does not fit into the standard pattern of 150-lb cylinders, one-ton
cylinders, or 90-ton railcars, you should use Figure 4-2 or Exhibit 4-6. Identify the
sulfur dioxide vessel that contains the largest quantity of any in your facility. Divide
that quantity by 10 to obtain the release rate in Ib/min and look for that rate, or the rate
nearest to it, on .Exhibit 4-6. Then read across to the rural or urban distances.
Alternatively, use Figure 4-2.
October 27,1998
-------
Chapter 4
Offsite Consequence Analysis
4-10
EXHIBIT 4-6
DISTANCES TO TOXIC ENDPOINT FOR SULFUR DIOXIDE
F Stability, Wind Speed 1.5 Meters per Second
Release Rate
(Ibs/min)
1
2
5
10
15
20
30
40
50
60
70
80
90
100
150
200
250
300
400
500
600
700
Distance to Endpoint (miles)
Rural
0.2
0.2
0.4
0.6
0.7
0.9
1.1
1.3
1.4
1.6
1.8
1.9
2.0
2.1
2.7
3.1
3.6
3.9
4.6
5.2
5.8
6.3
Urban
0.1
0.1
0.2
0.2
0.3
0.4
0.5
0.5
0.6
0.7
0.7
0.8
0.8
0.9
1.1
1.3
1.4
1.6
1.9
2.1
2.3
2.5
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
*
* More than 25 miles (report distance as 25 miles)
October 27,1998
-------
'.'•';' Chapter 4
4-11 Offsite Consequence Analysis
ANHYDROUS AMMONIA
In WWTPs, anhydrous ammonia is generally stored as a liquid under pressure in •
vessels that are kept outdoors. These vessels are relatively large (e.g., 10,000 gallons
or ~ 56,000 Ib) . Identify the quantity of ammonia in your storage vessel and divide
by 10 to obtain the release rate in,Ib/min. Look for that release rate, or the release rate
nearest to it, on Exhibit 4-7. Then read across to the rural or urban distances.1
Alternatively, use Figure 4-3.
The 10,000-gallori vessel mentioned above contains 56,000 Ib when full. (You may
take into account any administrative controls that limit the quantity of the ammonia in
the vessel.- -For example, you will generally require that the vessel never be filled
above 85 percent of its total, volume to allow for the high coefficient of volumetric
expansion of ammonia.) Assuming for the sake of the present example that 56,000 Ib
is the greatest quantity of ammonia that will ever be in 'the vessel, the release rate is
5,600 Ib/min, The closest release rate on Exhibit 4-7 is 6,000 Ib/min. The
corresponding rural distance is approximately 4.4 miles and the corresponding urban
distance is approximately 2.8 miles.
October 27, 1998
-------
Chapter 4
Offsite Consequence Analysis
4-12
EXHIBIT 4-7
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
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)
October 27,1998
-------
Chapter 4
4-13 ^ Offsite Consequence Analysis
AQUEOUS AMMONIA
Some WWTPs keep aqueous ammonia in outside storage tanks at atmospheric
pressure. The tanks usually stand in a diked area. Commercial grades of aqueous
ammonia vary from less than 20 weight percent to about 30 weight percent. For ease
of presentation, the ammonia is assumed to be in a 30 weight percent solution.
Because this has the highest vapor pressure of any of the commercial grades used in
wastewater treatment facilities, its use is conservative if you have aqueous ammonia in
a less than 30 weight percent solution. ,
If there is a catastrophic failure, the aqueous ammonia will spill into the diked area.
You are allowed to consider the dike, which is a passive mitigation feature. However,
if you have any reason to believe that the dike will not withstand the event that leads
to the, spill, or if your tank does not stand in a diked area, then you should assume, as
required by the rule, that the spill spreads out until its depth is only 1 cm (6.39 inch).
The first step is to calculate the rate of evaporation from the pool.
UNDIKED AREA
For an undiked area, the rate of release of ammonia from the pool (QR) (Ib/min) is
given by: ,
QR = 0.020QS , ..."•' (1)
where QS is the total quantity (Ib) of the spill of aqueous ammonia. For example, if
there is a spillage of 80,000 Ib, the rate of evaporation is 0,02 x 80,000 = 1,600
Ib/min. The present guidance assumes that this is the average rate of release over 10
minutes, after which the pool will be more dilute than it was initially and will be
evaporating much less rapidly. , • .
DIKED AREA
For a diked area, the rate of evaporation is: .
= 0.036Ap .,'.'. (2)
where Ap is the diked area in square feet. For example, if the vessel stands in a diked
area that is 40 feet x 40 feet = 1,600 ft2, the predicted rate of evaporation is 0.036 x
1,600 = 58. Ib/min. . . ;
The maximum area of the pool that would be formed by the spilled liquid can be
estimated as 0.55QS. If you have a diked area that is larger than the maximum area,
use Equation 1 for an undiked area to estimate the release rate to air.
October 27,1998
-------
Chapter 4
Offsite Consequence Analysis 4-14
RATES OF RELEASE AT TEMPERATURES OTHER THAN 25 °C
The actual temperature of stored aqueous ammonia varies with the ambient
temperature. The rule requires you to consider the release temperature to be the
highest daily temperature observed during the last three years, or the operating
temperature, whichever is highest. The ratio RVIj(T) represents the ratio of the partial
pressure of ammonia at temperature T °C to the partial pressure at 25 °C.
Exhibit 4-8 gives values of Rvp(T) for 30 percent aqueous ammonia in 1 °C increments
from 15 °C to 40 °C (59 °F to 104 °F). The rates of evaporation in Equations 1 and 2
are proportional to the vapor pressure, so to obtain a rate of evaporation for a
temperature T °C other than 25 °C, simply multiply the right-hand side of Equation 1
or 2 by the corresponding value of Rvp(T). For example, for an undiked release of
80,000 Ibs of ammonia at 35 °C, the calculation is (0,020)(80,000)(1.45) = 2,300
Ibs/min.
The vapor pressure of ammonia at other temperatures can be obtained from the
Handbook of Chemistry and Physics, CRC Press, 1998.
DISTANCES TO Toxic ENDPOINT
Take the evaporation rate and look for that rate, or the rate nearest to it, on Exhibit 4-
9. Then read across to the rural or urban distances. For exarnple, for the 58 Ib/min
release rate derived above, the closest release rate on Exhibit 4-9 is 60 Ib/min. The
predicted rural distance is approximately 0.4 mile and the predicted urban distance is
approximately 0.2 mile. Alternatively, use Figure 4-4.
October 27.1998
-------
4-15
Chapter 4
Offsite Consequence Analysis
EXHIBIT 4-8
RATIO OF VAPOR PRESSURE OF AMMONIA IN 30% AQUEOUS AMMONIA
(Ratio is Unity at 25 °C)
Temperature T (°C)
15 ,-
16
'17
18
19
20
•21
22
23 . - - .
24
25 '
26
27
Ratio
Rvp(T)
0.67
0.70
0.73
0.76
0.79
. 0.82
0.86
0.89
0.93
0.96
1.00
1.04
1.08'
Temperature T (°C)
28
29
30
;31
32
33
34
35
36
37
38
39
40
Ratio R.P
(T)
1.12
.1:16
1.21
1.25
1.30
1.35
1.40
1.45
1.50
1.55 .
1.61
1.66
1.72
October 27,1998
-------
Chapter 4
Offsite Consequence Analysis
4-16
EXHIBIT 4-9
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
p.l
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
LO -
1.1
1.2
1.3
1.4
1.5
L5
1.6
1.7
2.0
2.4 .
2.6
2.8
3.3
3.6
4.4
5.0
6.1
7.0
7.8
13
* More than 25 miles (report distance as 25 miles)
October 27,1998
-------
, Chapter 4
4-17 ~ Offsite Consequence Analysis
METHANE
Methane is present at some wastewater treatment facilities as a component of digester
gas. Typical constituents of digester gas are 55 to 70,percent methane by volume, 25
to 30 percent carbon dioxide by volume, and small amounts of nitrogen and hydrogen.
Modern facilities may well have processes containing more than 10,000 Ib of digester
gas at any one time (the entire quantity of the flammable mixture in a process must be
compared with the threshold quantity (TQ) of 10,000 Ib to determine whether the
facility is covered). Proceed as follows:
1 . Determine the density pm of the methane in the digester at operating
temperature T (°F), assuming that there is X vol percent of methane and 100 -
X vol percent of carbon dioxide and other materials. You should determine
X by analysis of your digester gas; if you do not know the percentage of
methane, you may use 70 percent as a conservative assumption. If X varies
over time, you should use the largest value of X that is seen in your facility.
pm = 0.22X/(460+T) ; ' ' . (3)
As an example;'if X = 65, and the operating temperature is 95 °F, pm= 0.026
lb/ft3.
2. Calculate the total volume V (ft3) occupied by digester gas in one digester
(the largest). Associated pipework can be neglected.
. (4)
Here, r is the .digester radius and H is the maximum digester head space. As
an example, if H = 8 ft and r = 40 ft, then V = OT%[ = (3 . 14)(40)2(8) = 40,200
ft3. •••'•-. ' '.- '
3. Calculate the quantity Q of methane contained in V:
Q = pmV (5)
In the current example, Q = (0.026)(40,200) = 1,045 Ib
Note that this quantity of methane itself, as well as the total quantity of
digester gas, is less than the 10,000-lb TQ for flammable materials. This is
because the total amount of digester gas (i.e., not just methane) in a process is
used to determine whether that process is covered by the regulation. It may be
the case that no single digester contains more than the TQ of digester, gas, but
you are covered because there are several digesters in your process. However,
you are required to consider only the quantity of methane in a single vessel .
when calculating the results of a worst-case vapor cloud explosion.
October 27, 1998
-------
Chapter 4
Offsite Consequence Analysis
4-18
4. Use the TNT-equivalency model to calculate the distance t> (miles) to the 1
psi overpressure endpoint:
D = 0.0082 (Q)
1/3
(6)
Equation 6 has been customized for methane. In the present example, D =
0.0082(1,045)"3 ~ 0.08 mile. Alternatively, you can use Exhibit 4-10 to
estimate the distance to the endpoint for a range of quantities of methane.
EXHIBIT 4-10
DISTANCE TO OVERPRESSURE ENDPOINT OF 1.0 PSI FOR VAPOR CLOUD EXPLOSIONS
OF METHANE
Based on TNT Equivalent Method, 10 Percent Yield Factor
Quantity in Cloud
(pounds)
500
2,000
5,000
10,000
20,000
Distance to
Endpoint
(miles)
0.07
0.1
0.1
0.2
0.2
Quantity in Cloud
(pounds)
50,000
100,000
200,000
500,000
1,000,000
Distance to
Endpoint
(miles)
•0.3
0.4
0.5
0.7
0.8
Some facilities have an intermediate storage vessel for digester gas, at a pressure that
may be typically 45-50 psig. You should use the quantity of methane in such a vessel
in Equation 6 or Exhibit 4-10 if it contains the largest quantity of digester gas on site.
October 27, 1998
-------
4-19
Chapter 4
Offsite Consequence Analysis
PROPANE
If you keep Q Ib of propane on site, the distance D (ft) to 1 psi overpressure is given
by: .' ' '• .- .. • . • - -• .
D = 0.008(Q)"3 , ;
Thus, for 10,000 Ib of propane, D = 0.008 (10,000)1/3 = 0.2 mile
(7)
Alternatively, you can use Exhibit 4-11 to estimate the distance to the endpoint from
the quantity released for vapor cloud explosions of propane.
EXHIBIT 4-11
DISTANCE TO OVERPRESSURE ENDPOINT OF 1.0 PSI FOR VAPOR CLOUD EXPLOSIONS
OF PROPANE
Based on TNT Equivalent Method, 10 Percent Yield Factor
Quantity in Cloud
(pounds)
500
2,000
5,000
10,000
20,000;
Distance to
Endpoint
(miles)
0.06
0.1
0.1
0.2
0.2
Quantity in Cloud
(pounds)
50,000, -.
100,000
200,000
500,000
1,000,000
Distance to
Endpoint
(miles)
0.3
0.4
0.5
0.6
0.8
October 27,1998
-------
Chapter 4
Offsile Consequence Analysis . 4-20
4.2 ALTERNATIVE SCENARIOS
This section provides guidance on how to choose and'model alternative scenarios.
Information is provided on the general requirements of the regulations, followed by
specific sections on chlorine, sulfur dioxide, anhydrous ammonia, aqueous ammonia,
methane and propane.
GENERAL REQUIREMENTS
The requirements that differ from those for worst-case scenarios are as follows:
•4- You can take into account active as well as passive mitigation systems, as
long as these systems are expected to withstand the causes of the accident.
+ The alternative scenario should reach an endpoint offsite. unless no such
scenario exists. •
+ If you are doing your own modeling, you should use "typical meteorological
conditions for the stationary source." You may obtain these data from local
weather stations. You can obtain wind speed and temperature data from the
National Climatic Data Center at (828) 271-4800. This guidance uses an
. "average" weather condition of wind speed 3 m/s and D stability class with an
ambient temperature of 25 °C.
+ The number of alternative scenarios you are required to develop is as follows:
> At least one scenario for each 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.
Thus, if you have anhydrous ammonia, chlorine, sulfur dioxide, digester gas and
propane on your site in Program 2 and Program 3 processes, you will need, at a
minimum, three alternative toxic scenarios, one each for ammonia, chlorine and sulfur
dioxide, but only one alternative flammable scenario, for either digester gas or
propane.
CHOICE OF ALTERNATIVE SCENARIOS
, Your alternative scenario for a covered process must be one that is more likely to
occur than the worst-case scenario and that reaches an endpoint offsite, unless no such
scenario exists. You do not need to demonstrate greater likelihood of occurrence or
carry out any analysis of probability of occurrence; you only need to use reasonable
judgement and knowledge of the process. If, using a combination of reasonable
assumptions, modeling of a release of a regulated substance from a process shows that
the relevant endpoint is not reached offsite, you can use the modeling results to
demonstrate that a scenario does not exist for the process that will give an endpoint
offsite. You must report an alternative scenario, however.
October 27,1998
-------
Chapter 4
4-21 • Offsite Consequence Analysis
Release scenarios you should consider include, but are not limited to, the following,
where applicable: ."'.'•• • .
+ Transfer hose releases due to splits or sudden uncoupling;
'-'•*• , Process piping releases from failures at flanges, joints, welds, valves and .
- valve seals, and drains or bleeds;
+ Process vessel or pump releases due to cracks, seal failure, drain bleed, or .
plug failure; • ' .' .
- + . Vessel overfilling and spill, or overpressurization and venting through relief
valves or rupture disks; and
+ . Shipping container mishandling and breakage or puncturing leading to a spill.
For alternative release scenarios, you may consider active mitigation systems, such as
: interlocks, shutdown systems, pressure relieving devices, flares, emergency isolation
systems, and fire water and deluge systems, as well as passive mitigation systems. "
Mitigation systems considered must be capable of withstanding the event that triggers
the release while remaining functional. •'•"•.
, You must consider your five-year accident history and failure scenarios identified in
your hazard review or process hazards analysis in selecting alternative release
scenarios for regulated toxic or flammable substances (e.g., you'might choose an
actual event from your accident history as the basis of your scenario). You also may
consider any other reasonable scenarios. -
The alternative scenarios you choose to analyze should be scenarios that you consider
possible at your site. Although EPA requires no explanation of your choice of
scenario, you should choose a scenario that you think you can explain to emergency
responders and the public as a reasonable alternative to the worst-case scenario. For
example, you could pick a scenario based on an actual event, or you could choose a
scenario that you worry about, because circumstances at your site might make it a
possibility. If you believe that there is no reasonable scenario that could lead to offsite
consequences, you may use a scenario that has no offsite impacts for your alternative
analysis. You should be prepared to explain your choice of such a scenario to the
public, should questions arise. '
WWTP SCENARIOS
A number of scenarios other than those listed in the rule may be worth considering for
WTTPs. Many WWTPs have single-stage, pass-through chemical scrubbers to
neutralize compounds such as sulfur dioxide. Failure of the neutralizing solution's
recirculation pump and continued operation of the blower fan could not only allow a
release* but also exacerbate it by mechanically evacuating the substance from the
room. .'.''..
Accidents reported to EPA involving chlorine systems have been caused by "rust
holes," failure of a diaphragm, leak during hookup to a tank, a packing nut leak, faulty
cylinders, removal of a valve in error, faulty valves, leaking gaskets, and a
October 27, 1998
-------
Chapter4
Offsite Consequence Analysis 4-22
blown pressure gauge. Similar accidents involving sulfur dioxide systems have been
reported. In addition, natural events, such as floods, tornados, earthquakes, and
hurricanes could cause several releases to occur simultaneously. You may want to
consider these types of scenarios when you select your alternative release scenarios.
CHLORINE .
FLASHING LIQUID RELEASES
Many of the potential alternative scenarios could involve the release of liquid chlorine
from a small hole. The liquid chlorine flashes immediately to vapor and fine liquid
droplets and is carried downwind.
The rate of release of a liquid through an hole is given by Bernoulli's formula for
liquid releases (see Appendix 4A). Using chemical-specific data for chlorine, the
formula becomes:
= 3,140xAh (8)
where:
Ah = the area of the hole (in2 -for example, the area of a hole of
diameter 1 inch is 0.785 in2)
3,140= factor applicable to chlorine liquefied under a pressure of
98.5 psig (see Appendix 4A)
I
Note that this is the formula for the release of a pure liquid and would apply to a
breach in the wall of a vessel or to the rupture of a very short pipe. For long pipes,
there is a pressure drop between the vessel and the hole, and there will be flashing in
the pipe and a reduced rate of release. Therefore, Equation 8 may be conservative.
If there is a small leak from the liquid space of a large storage vessel, the reservoir can
essentially be considered as infinite, and the chlorine will be steadily emitted at a
constant rate for a relatively long period. Such leaks may occur because of a gasket
failure, a pump seal leak, or a corrosion hole, for example. Yeu can use Equation 8
and the estimated area of the hole to calculate the release rate (QR).
To predict the distance to the toxic endpoint, take the calculated value of QR and
identify the closest value on Exhibit 4-12 (150 Ib/min). Read off the corresponding
distance, in this case, 0.6 mile for a rural site and 0.2 mile for an urban site.
Alternatively, use Figure 4-5.
Exhibit 4-13 provides release rate estimates for releases of liquid chlorine through
holes of diameter 1/16 inch to 5 inches and the distances to .the endpoint
corresponding to these release rates. You can use this table instead of Equation 8 and
Exhibit 4-12 to estimate the distance to the endpoint.
October 27,1998
-------
4-23
Chapter 4
Offsite Consequence Analysis
EXHIBIT 4-12
DISTANCES TO TOXIC ENDPOINT FOR CHLORINE
D Stability, Wind Speed 3 Meters per Second
Release Rate
(Ibs/min)
1 . .
2
5 •
10
15
20
.' 30
40
50
60
70
.- - - 80
90
100
150
200
250
300
400
500
600
700
Distance to Endpoint (miles)
Rural
o.i •-
0.1
0.1
0.2
0.2
0.2
0.3
0.3
0.3
0.4
0.4
0.4
0.4
0.5
0.6
0.6
0.7
0.8
0.8
1.0
.. 1,0
1.1
Urban ,
0.1
0.1
0.1
0.1
0.1
0.1
.0.1
0.2
0.2
0.2 .
0.2
0.2
0.2
0.3
0.3
0.3
0.4
0.4
0.4.
0.4
Release Rate
(Ibs/min)
.: 750
800
900
1,000
1,500
2,000
2,500
. 3,000
4,000
5,000
7,500'
io;ooo
15,000
20,000
25,000
30,000
.40,00.0'
50,000
75,000
100,000
150,000
200,000
Distance to Endpoint (miles)
Rural
1.2
, 1.2
1.2
1.3
1,6
1.8
2.0
. 2.2
2.5
2.8 /
3.4
3.9
4.6
; 5.3
5.9
6.4
7.3
8.1
9.8
11.
13
, 15
Urban
0.4
0.5
0.5
0.5
0.6
0.6
0.7
0.8
0.8
0.9
1.2
1.3
1.6
• 1-8
2.0
2.1
2.4
'2.7
3.2
3.6
4.2
4.8
October 27,1998
-------
Chapter 4
Offsite Consequence Analysis
4-24
EXHIBIT -4-13
RELEASE RATES AND DISTANCE TO THE ENDPOINT FOR LIQUID CHLORINE
': " RELEASES ' '. '
D StabOity, Wind Speed 3 Meters per Second
Hole
Diameter
(inches)
1/16
3/16
. ' 1/4
5/16
1/2'
1
2
3
4
5
Release Rate
(Ib/min)
10
87
150
240
620
2,500
9,900
22,200
39,500
61.700
Distance (miles)
Rural
'. 0.2
0.4
0.6
0.7
1.0
2.0
3.9
5.3
7.3
8.1
Urban
0.1
0.2
0.2
, ' 0.3
0.4
0.7
13
1.8
2.4
2.7
TWO-PHASE RELEASES
i i • •'' , _ • • •-.
In case of a release from a long pipe carrying liquid chlorine (L/dh» 1, where L is
the length of the pipe between the reservoir of chlorine and the atmosphere and dh is
the diameter of the pipe), there can be flashing in the discharge pipe, resulting in a
two-phase mixture emerging to the atmosphere. In this case, the rate of release in
Ib/min for chlorine is given by:
QR= 1,100 xAhxF
(9)
where:
(see
1,100= chemical-specific factor applicable to'chlorine at 25
Appendix 4A)
Ah = hole area (in2) = area of pipe opening
F = factional loss factor (dimensionless) with values as follows:
£. L/d,
1 10
0.85 50
0.75 100
0.65 200
0.55 400
Exhibit 4-14 presents release rates for a range of pipe,diameters and length-diameter
ratios for two-phase releases of chlorine from a pipe. You can read the release rate
October 27,1998
-------
4-25
Chapter 4
Offsite Consequence Analysis
from the exhibit or calculate the release rate from Equation 10, then find the distance
to the endpoint corresponding to the release rate by referring to Exhibit 4-12.
EXHIBIT 4-14
RELEASE RATES FOR TWO-PHASE RELEASES FROM PIPES CARRYING LIQUID
CHLORINE
Pipe
Diameter
(inches)
1/4
5/16
. 1/2
3/4
1
2
3
Pipe Length/Diameter (L/d,,)
10(F=1)
50 (F=0.85) ,
100 (F=0.75)
200 (F=0.65)
400 (F=0.55)
Chlorine Release Rate (Ibs/min)
54
84
220
490
• 860
, 3,500
7,800
46
72
180
410
730
2,900
6,600
40
63
160
360
650
2,600
5,800
35.
55
140
320
'560
2,200
5,100
30
46
120
270
480
1,900
4,300
VAPOR RELEASES
For a choked release of vapor (i.e., emerging at. the speed of sound from the hole,
which will invariably be the case for chlorine at atmospheric temperatures), the
release rate for chlorine is given by:
where:
QR = 190 x Ah
190
Ah =
(10)
chemical-specific factor for chlorine at a tank pressure of 113
psia and temperature 25 °C (see Appendix 4A)
hole area (in2)
You can use Equation 10 to estimate the release rate of chlorine from a hole in the
vapor space of a tank. For example, such a hole could result from shearing off a valve
at the top of a tank. The distance to the endpoint can be estimated from the release
rate, using Exhibit 4-12 or 4-5.
As .an alternative to Equation 10, for releases from holes ranging from 1/16-inch to 5
inches in diameter, you can read the release rate and the corresponding distance from
Exhibit 4-15.
October 27, 1998
-------
Chapter 4
Offsite Consequence Analysis
4-26
EXHIBIT 4-15
RELEASE RATES AND DISTANCE TO THE ENDPOINT FOR CHLORINE VAPOR
RELEASES
D Stability, Wind Speed 3 Meters per Second
Hole
Diameter
(inches)
1/16
3/16
1/4
5/16
V4
1
2
• 3
4
5
Release Rate
(Ibs/min)
0.6
5
9
15
37
150
600
1,300
2,400'
3,700
Distance (miles)
Rural
0.1
0.1
0.2
0.2
0.3
0.6
1.0
1.6
2.0
2.5
Urban
0.1
0.1
0.1
0.1
0.1
0.2
0.4
0.6
0.7
0.8
Note that the release rate estimated by the method above is conservative. As the
release proceeds, chlorine continuously evaporates from the liquid surface in the
cylinder. This causes the liquid to cool, the vapor pressure to decrease, and the rate of
release to decline. However, the equations for calculating this effect are rather
complex and not included in this guidance.
OTHER CHLORINE SCENARIOS
If you wish to do so, you can simply quote any of the results above, if they are
applicable to your site, when you submit your Risk Management Plan. However, you
may also choose to develop other scenarios, using Equations 8, 9, or 10, and Exhibit
4-12 or Figure 4-5.
October 27. 1998
-------
4-27
. Chapter 4
Offsite Consequence Analysis
SULFUR DIOXIDE
FLASHING LIQUID RELEASES
Sulfur dioxide is similar to chlorine in the way that it would be released, so
Bernoulli's formula is applicable. Using Bernoulli's formula, incorporating chemical-
specific data for sulfur dioxide, you can estimate the release rate from a hole in the
liquid space of a tank from the following equation:
QR = 2,020 x Ah
(11)
where:
Ah. =
2,020 =
the area of the hole (in2)
factor applicable to sulfur dioxide liquefied under a pressure
of 43 psig (see Appendix 4A) .
After you have estimated the release rate, you can find the predicted distance to the
toxic endpoint for sulfur dioxide from Exhibit 4-17 (next page) or Figure 4-6.
Alternatively, you can use Exhibit 4-16. This exhibit gives release rates and distances
to the endpoint for flashing liquid releases through holes of diameter 1/16 inch to 5
inches.
EXHIBIT 4-16
RELEASE RATES AND DISTANCE TO THE ENDPOINT FOR LIQUID SULFUR DIOXIDE
RELEASES
D Stability, Wind Speed 3 Meters per Second
Hole
Diameter
(inches)
1/16
3/16
1/4
5/16
1/2
1
2
3
4
5
Release Rate
(Ib/min)
6
56
99
160
400
1,600
6,300 •.
14,300
25,300
39,600
Distance (miles)
Rural
0.1
0.4
0.5
0.6
0.9
. 1.9
3.3
5.6
7.3',
9.2
Urban
0.1
0.2
0.2
0,2
0.4
0.6
1.1
1.7,
2.1
2.6
October 27, 1998
-------
Chapter 4
Offsite Consequence Analysis
4-28
EXHIBIT 4-17
DISTANCES TO TOXIC ENDPOINT FOR SULFUR DIOXIDE
D Stability, Wind Speed 3 Meters per Second
Release Rate
Qbs/min)
1
2
5
10
15
20
30
40
50
60
70
80
90
100
150
200
250
300
400
500
600
700
Distance to Endpoint (miles)
Rural
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.3
0.3
0.4 '
0.4
0.4
0.4
0.5
0.6
0.6
0.7
0.8
0.9
1.0
1.1
1.2
Urban
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.2
0.2
" 0.2
0.3
0.3
0.4
0.4
0.4
0.4
Release Rate
(Ibs/min)
750
800
900
1,000
1,500
2,000
2,500
3,000
4,000
5,000
7,500
10,000
15,000
20,000
25,000
30,000
40,000
50,000
75,000
100,000
150,000
200,000
Distance to Endpoint (miles)
Rural
1.3
1.3
1.4
1.5
1.9
2.2
2.3 .
2.7
3.1
3.3
4.0
4.6
5.6
6.5
7.3
8.0
9.2
10
13
14
18
20
Urban
0.5 , .
0.5
0.5
0.5
0.6
0.7
0.8
0.8
1.0
1.1
1.3
1.4
1.7
1.9
2.1
2.3
2.6
2.9
3.5 ,
4.0
4.7
5.4
TWO-PHASE RELEASES
A break in a long pipe (whose length is much greater than its diameter) carrying liquid
sulfur dioxide can result in the release of a two-phase mixture, as discussed above for
chlorine. The release rate can be estimated from the following equation:
QR = 252 x Ah x F
(12)
October 27,1998
-------
4-29
Chapter 4
Offsite Consequence Analysis
where: ' ? '
252 .= '. chemical-specific factor applicable to sulfur dioxide at 25'C
(see Appendix 4A)
Ah = hole area (in2) = area of pipe opening
F ,, = frictional loss factor (dimensionless) with values as shown in
the section on chlorine ,
.You can estimate the release rate from Equation 12, then find the distance to the
endpoint corresponding to the release rate by referring to Exhibit 4-12. You also can
find the release rate for a range of pipe diameters and L/dh values in Exhibit 4-18.
EXHIBIT 4-18
RELEASE RATES FOR TWO-PHASE RELEASES FROM PIPES CARRYING LIQUID
SULFUR DIOXIDE
Pipe
Diameter
(inches)
1/4
5/16
'/2
3/4
. 1
2
3
Pipe Length/Diameter (L/d^
10 (E=l)
50(F=0.85)
100(F=0.75)
200 (F=0.65)
400 (F=0.55)
Sulfur Dioxide Release Rate Obs/min)
12
19
49
110
200
800
1,800
11
16
42
95
170
670
1,500
9
14
v 37
83
150
600
1;300
8
13
.32
72
130
520
1,200
7
11
27-
61
.' 110
440
980
VAPOR RELEASES
For a choked release of sulfur dioxide vapor, the release rate is given:
QR = 91xAh
where: . '
91
Ah
(13)
= . -. chemical-specific factor for sulfur dioxide at a tank pressure
of 58 psia and temperature 25 °C (see Appendix 4A)
= hole area (in2)
The distance to the endpoint can be estimated from the release rate, using Exhibit 4-17
or Figure 4-6.
October 27, 1998
-------
Chapter 4
OfFsite Consequence Analysis
4-30
As an alternative to Equation 13 and Exhibit 4-17, for releases from holes ranging
from 1/4 inch to 5 inches in diameter, you can read the release rate and the
corresponding distance from Exhibit 4-19.
EXHIBIT 4-19
RELEASE RATES AND DISTANCE TO THE ENDPOINT FOR SULFUR DIOXIDE VAPOR
RELEASES
D Stability, Wind Speed 3 Meters per Second
Hole
Diameter
(inches)
1/4
5/16
1/2
1
2
3
4
5
Release
Rate
(Ibs/min)
4
7
18
71
280
640
1,100
1,800
Distance (miles)
Rural
0.1
0.1
0.2
0.4
0.8
1.1
1.5
2.2
Urban
0.1
0.1
0.1
0.2
0.3
0.4
0.5
0.7
OTHER SULFUR DIOXIDE SCENARIOS
If you wish to do so, you can simply quote any of the results above, if they are .
applicable to your site, when you submit your Risk Management Plan. However, you
may also choose to develop other scenarios, using Equations 11,12, or 13, and
Exhibit 4-17 or Figure 4-6.
October 27,1998
-------
4-31
Chapter 4
Offsite Consequence Analysis
ANHYDROUS AMMONIA
FLASHING LIQUID RELEASES
Like chlorine and sulfur dioxide, ammonia will be liquefied under pressure in its own
storage vessel. Bernoulli's equation is applicable for flashing liquid releases (see
Appendix 4A). The equation for ammonia liquefied under a pressure of 130 psig is:
QR= 2,380 xAh
(14)
where:
Ah = hole area (in2) . ,-, ".
2,380 = chemical-specific factor for ammonia liquefied under
pressure
After you have estimated the release rate, you can find the predicted distance to the
toxic endpoint for ammonia from Exhibit 4-21 (next page) or Figure 4-7.
Alternatively, you can use Exhibit 4-20. This exhibit gives release rates and .distances
to the endpoint for flashing liquid releases through holes of diameter 1/16 inch to 5
inches. •
EXHIBIT 4-20
RELEASE RATES AND DISTANCE TO THE ENDPOINT FOR LIQUID AMMONIA
RELEASES
. D Stability, Wind Speed 3 Meters per Second
Hole
Diameter
(inches)
1/16
3/16
1/4
5/16
1/2
1
2
3
4
5
Release Rate
(Ibs/min)
7
66
120
180
470
1,900
7,500
16,800
30,000
46,800
Distance (miles)
Rural
0.1
0.2
0.2
0.4
0.4
0.8
1.6
, 2.2
3.1
3.9
Urban
0.1
0.1
0.1
0.2
0.2
0.3,
0.5
0.7
1.0
1.2
October 27, 1998
-------
Chapter 4
Offsite Consequence Analysis
4-32
EXHIBIT 4-21
DISTANCES TO TOXIC ENDPOINT FOR ANHYDROUS AMMONIA
D Stability, Wind Speed 3 Meters per Second
Release Rate
(Ibs/rain)
<10
10
15
20
30
40
50
60
70
80
90
100
150
200
250
300
400
500
600
700
750
800
Distance to Endpoint (miles)
Rural
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.2 ,
0.2
0.2
0.2
0.2
0.2
0.3
0.3
0.3
0.4
0.4
0.5
0.5
0.5
0.5
Urban
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.2
0.2
Release Rate
(Ibs/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
October 27,1998
-------
1 Chapter
4-33 Offsite Consequence Analysis
AQUEOUS AMMONIA
Alternative scenario spills of aqueous ammonia are going to be similar to worst-case
scenario spills in that there will be a leak of some kind and the liquid will either
spread across a diked area or spread out until its depth is only 1 cm (0:39 inch). The
principal difference will be in the amount spilled.
The,calculation of the rate of spillage is again performed using Bernoulli's formula
see Appendix A4). The density of 30 percent aqueous ammonia is 57.33 ,lb/ft3, so the
equation becomes:
, QRL =153xAhx (h)as ' . (15).
where: . ' . • , '
QRL = rate of spillage of ammonia solution on to the ground
(Ibs/min), not the rate of evaporation
Ah = hole area (in2)
h = static head .<•'.;
For example, fora %-inch diameter openfrig with a static head h of 10 ft:' :
QRL = 153 x TC'X C*xtt)2.x /10 = 153 x 3.142 x 1/16 x 3.16 = 95 Ib/min,
This is the rate of spillage of the total solution of water plus ammonia as a liquid onto
the ground. -.-',. ,
If you know, and can document, how long it will take to stop the release, you should
estimate the total quantity of solution spilled to the ground (QS) by multiplying the
estimated rate of liquid spillage by the estimated duration of the release (in minutes).
Then you can estimate the release rate to air (QR) as the evaporation rate of ammonia
from the pool. For an undiked area (pool depth 1 cm): '
QR = 0.025QS ;, (16)
For a diked pool (pool depth greater than 1 cm) of area Ap square feet:
QR = .0.046V 07)
The maximum area of the pool that would be formed by the spilled liquid is 0.55QS.
If you have a diked area that is larger than the -maximum area, use the equation for an
undiked area to estimate the release rate to air.
It is possible that you may estimate a rate of evaporation, of ammonia from the pool
that exceeds the spill rate of the liquid solution, particularly if the liquid spill rate is
small and the spill of the liquid may last for a fairly long time. In such a case, under
the assumptions used in this estimation method, no pool would be formed. Instead of
the evaporation rate, in this case, you should use the liquid spill rate (QRJ as the
release rate to air. '
October 27, 1998
-------
Chapter 4
Offsite Consequence Analysis 4-34
You also can determine how far the pool will spread until the rate of spillage is
matched by the rate of evaporation of ammonia. For aqueous ammonia at 77 T (25
^C), the rate of evaporation is 0.046 Ap (from Equation 17).
The area that will cause the rate of evaporation to exactly balance the rate of spillage
is given by:
Ap = QR/0.046 = 22QRL (18)
In the example given above, QRL = 95 Ib/min, so Ap = 2,100 ft2. This value should be
compared with the available diked area and the smaller of the two values chosen.
Thus, if the diked area happens to be 50 ft x 50 ft = 2,500 ft2, the area chosen for
subsequent calculation is Ap = 2,100 ft2 and QR = 95 Ib/min. (If the diked area
happened to be smaller — say 20 ft x 20 ft = 400 ft2 — then the spilled ammonia
would cover the diked area, and, using Equation 17, the rate of evaporation QR would
be (0.046)(400) = 18 Ib/min.)
To predict the distance to the toxic endpoint in typical weather conditions, take the
value of QR calculated above and identify the closest value on Exhibit 4-22. Read off
the corresponding distance. For the 95 Ib/min case, the result is 0.2 mile for a rural
site and 0.1 mile for an urban site. Alternatively, use Figure 4-8.
October 27,1998
-------
4-35
Chapter 4
Offsite Consequence Analysis
EXHIBIT 4-22
DISTANCES TO TOXIC ENDPOINT FOR AQUEOUS AMMONIA
D Stability, Wind Speed 3 Meters per Second
Release Rate
(Ibs/min)
8
10 .
15
20
30
40
50
60
70
.80
90
100
150
200
250
300
400
500
600
700
750
Distance to Endpoint (miles)
Rural
0.1
. 0.1
0.1
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.2
0.2
0.3
0.3
0.4
0.4
0.4
0.5
0.6
0.6
0.6
Urban
0.1 ,
0.1
0.1
0.1
0.1
0.1 .
0.1
0.1
0.1
0.2
0.2
0.2
0.2 .
0.2
0.2
0.2
Release Rate
(Ibs/min)
800
900
1,000
1,500
2,000
2,500
3,000 -
4,000
5,000
7,500
10,000
15,000
20,000
25,000
30,000
40,000
50,000
75,000
100,000
150,000
200,000
Distance to Endpoint (miles)
Rural
, 0.7
, . 0.7
0.8
1.0
1.2
1.2
1.5
.1.8
2.0
2.2
2.5
3.1
3.6
4.1
4.4
5.1
5.8
7.1
8.2
10
12"
Urban
0.2
0.3
0.3
, 0.4
0.4
0.4
0.5
0.6
0.7
0.7
0.8
1.0
1-2
1.3
1.4
1.6
1.8
2.2
2.5
3.1
3.5
October 27,1998
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Chapter 4
Offsite Consequence Analysis 4-36
PROPANE
You must select an alternative release scenario that reaches an endpoint offsite unless
no such scenario exists. If no scenario reaches an endpoint beyond your fenceline,
you must still report an alternative release scenario for flammables unless the process
is in Program 1. .
The potential alternative scenarios for flammable substances include:
Vapor cloud fires (flash fires) that may result from dispersion of a flammable vapor
cknid and subsequent ignition. Such a fire could flash back and present a severe heat
radiation hazard to anyone in the vicinity. The endpoint distance for such a fire is the
predicted distance to which the vapor cloud travels before falling below its lower
flammable limit (LFL).
A pool fire is unlikely to be applicable to propane. In the event of such a fire, the
endpoint distance is that at which radiant heat could cause second degree bums over a
period of 40 seconds.
A boiling liquid, expanding vapor explosion (BLEVE), leading to a fireball that may
produce intense heat, may occur if a vessel containing material such as propane
ruptures as a result of exposure to a fire. The radiant heat from such an event is
generally considered to be the principal hazard, but in addition, portions of the vessel
can be thrown a considerable distance, and there are shock waves generated by the
explosive rupture of the vessel Such an event is unlikely at a wastewater treatment
facility unless a propane storage vessel is near a burning building or if there are
burning weeds under a tank.
A vapor cloud explosion, such as that considered for the worst-case, but presumably
containing a smaller amount of flammable material.
A jet fire from the puncture of a vessel containing a flammable material under
pressure.
The Risk Management Program for Propane Storage Facilities identifies a scenario
in which a driver fails to remove the hoses between the storage tank and the delivery
vehicle before driving away. The result is the failure of an unloading hose. The
active mitigation devices are assumed to work, limiting the release to the quantity of
liquid propane contained in the hose. The volume of the hose is estimated as the
cross-sectional area of the hose times the length. For the example in the guidance for
propane storage facilities, the hose was assumed to have a diameter of 4 inches (0.33
feet) and a length of 25 feet. This hose would have a volume of TC x (0.33/2)2x 25, or
2.18 ft3. The density of liquid propane is 31.4 Ibs/ft?, so the quantity in the hose
woujd be about 69 Ib, Assuming a vapor cloud explosion of the released quantity, the
distance to the 0.1 psi overpressure endpoint can be estimated from Equation 7. For
this example, the distance is calculated as 0.03 mile. Alternatively, distances to the
endpoint for vapor cloud explosions of quantities ranging from 50 to 500 pounds are
provided in Exhibit 4-23; see Exhibit 4-11 for larger quantities.
October 27,1998
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4-37
Chapter 4
Offsite Consequence Analysis
EXHIBIT 4-23
DISTANCE TO OVERPRESSURE ENDPOINT OF 1.0 PSI FOR VAPOR CLOUD EXPLOSIONS
OFPROPANE
Based on TNT Equivalent Method, 10 Percent Yield Factor
Quantity in Cloud
(pounds)
50
60
70
80
90
Distance to
Endpoint
(miles)
0.03
0.03 r
0.03
0.03
0.04
Quantity in Cloud
(pounds)
100
200
300
400 '
500
Distance to
Endpoint
(miles)
0,04
0:05
0.05
0.06
.0.06
A vapor cloud fire also may be an alternative scenario for a propane release. The -
endpoint for this type of event is the lower flammable limit (LFL) (36 mg/L for
propane). To estimate the distance to the endpoint, you need to estimate the release
rate and then estimate the dispersion distance to the LFL, based on dense gas
modeling. For distances to the propane LFL at a rural site:
i' ' . ''
+ All release rates below 2,000 Ibs/min give a distance to the endpoint of less
than 0.1 mile or 520 ft and
4- Release rates from 2,500 to 10,000 Ibs/min give a distance to the endpoint of
0.1 mile.
For an urban site:
+ All release rates less than 7,500 Ibs/min give a distance to the endpoint of less
than 0.1 mile; and
+ Release rates from 7,500 to 10,000 Ibs/min give a distance to the endpoint of
0.1 mile. ' ' • ." '"-.'"
If it is possible that your propane tank could be exposed to fire, resulting in a BLEVE,
then you can use Exhibit 4-24 to estimate the distance at which exposure to heat from
the fireball resulting from the BLEVE could lead to second degree burns.
October 27,1998
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Chapter 4
OfFsite Consequence Analysis
4-38
EXHIBIT 4-24
DISTANCE AT WHICH EXPOSURE TO A PROPANE BLEVE COULD LEAD TO SECOND-
DEGREE BURNS*
Quantity in
Fireball (lb) ,
1,000
5,000
10,000
20,000
, 30,000
50,000
Distance
( miles)
0.1
0.1
0.1
0.2
0.2
0.3
Quantity in
Fireball (lb)
75,000
100,000
200,000
300,000
500,000
Distance
( miles)
0.4
0.4
0.5
0.6
0.8
METHANE
Consider the case of methane released from a digester. Assuming that the full
contents of a digester were released over a few minutes (say 10 minutes), in the
example given in Section 4.1, the release rate would.be 105 Ib/min (total quantity of
methane in the digester, 1,053 lb). The LFL for methane is 33 mg/L. Conservatively
taking digester gas/methane as a neutrally buoyant gas (it will actually rise from the
ground), you need to use Exhibit 4-25 (for a rural site) or Exhibit 4-26 (for an urban
site) to estimate the distance to the LFL. From Exhibit 4-25, the predicted distance for
a release rate of 105 Ib/min is 0.1 mile at a rural site and, from Exhibit 4-26, it is 0.1
mile at an urban site.
It is unlikely that a BLEVE would occur. They are not known to take place in low
pressure containment such as that of a digester. A pool fire does not need to be
considered, because the methane is not liquefied.
October 27.1998
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4-39
Chapter 4
Offsite Consequence Analysis
EXHIBIT 4^25
NEUTRALLY BUOYANT PLUME DISTANCES TO LOWER FLAMMABILITY LIMIT (LFL)
Rural Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release Rate
(Ibs/min)
0-1,980
1,980-7,260
7,260-17,490
' 17,490-28,380
28,380-42,900
42,900-56,100
56,100-72,600
72,600-89,100
89,100- 108,900
Distance to
Endpoint
(miles)
0.1
0.2
.0.3
0.4
0.5
0.6
0.7 ;
0.8
0.9
Release Rate
(Ibs/min)
108,900-128,700
128,700-148,500
148,500-171,600
171,600-191,400
191,400-224,400
224,400-270,600
270,600-320,100
320,100-363,000
363,000-429,000
Distance to
Endpoint
(miles)
1.0
1.1
1.2
1.3 .
1,4
. 1.6
1.8 .
2.0
2.2
EXHIBIT 4-26
NEUTRALLY BUOYANT PLUME DISTANCES TO LOWER FLAMMABILITY LIMIT (LFL)
Urban Conditions, D Stability, Wind Speed 3.0 Meters per Second
Release Rate
(Ibs/min)
0 - 4,950
4,950-23,430
23,430-49,500
49,500-85,800
85,800-132,000
132,000-181,500
181,500-240,900
Distance to
Endpoint
(miles)
0.1
-' 0.2
0.3,
0.4
0.5
0.6
0.7
Release Rate
(Ibs/min)
'240,900-303,600
303,600-363,000
363,000-462,000
462,000-594,000 "
594,000-858,000
,858,000-1,023,000
1,023,000-1,254,000
Distance to
Endpoint
(miles)
0.8
0.9
1.0
1.2
1.4
1.6
1.8
October 27,1998
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Chapter 4
Offsite Consequence Analysis 4-40
4.3 BUILDINGS
In many WWTPs, chlorine and sulfur dioxide cylinders or other vessels are kept
indoors. Unless your cylinders are delivered directly into the building (i.e., they are
not Unloaded outdoors and moved inside later), you should not consider buildings in
your worst-case scenario, even though they are passive mitigation systems, because
there will be some time when the vessels are outdoors. If your cylinders are delivered
indoors or if your largest vessel is indoors, you may want to analyze the mitigating
effects of the building when you do your worst-case analysis. You may also want to
consider alternative scenarios that consider buildings as mitigation systems. Some
buildings are strong, leak-tight buildings that are designed to contain the release of the
contents of a one-ton cylinder or other vessel. Some of them contain scrubbers that
activate upon release of chlorine or sulfur dioxide; if these scrubbers function as
designed, they can ensure that any release to the external atmosphere would be small.
(Scrubbers are active mitigation features that cannot be considered to work for a
worst-case scenario.) At the other end of the spectrum, some buildings are intended to
do no more than keep the rain off.
MITIGATION OF RELEASES OF ANHYDROUS AMMONIA, CHLORINE, OR SULFUR DIOXIDE
INTO BUILDINGS
EPA's RMP Offsite Consequence Analysis Guidance provides a simple building
release-rate-multiplicative factor of 55 percent for toxic gases in both worst-case and
alternative scenarios (i.e., the predicted rate of release is 55 percent of that for the
same accident if it should occur outdoors).
Example: Assume that there is a liquid chlorine release through a 5/16-inch
opening as described in the discussion of chlorine alternative
scenarios (see Exhibit 4-13). .This release takes place indoors and,
per the discussion above, is reduced to 55 percent of the release rate
of 240 Ib/min, i.e., to = 130 Ib/min. From Exhibit 4-12, the predicted
distance to the toxic endpoint is ~ 0.6 mile for a rural site and « 0.2
mile for an urban site, compared to 0.7 mile (rural) and 0.3 mile
(urban) for an outdoor release.
The RMP Offsite Consequence Analysis Guidance also provides factors for toxic
liquids of 10 percent for worst-case scenarios and 5 percent for alternative scenarios.
These factors may be used for releases of aqueous ammonia that take place inside
buildings.
The following discussion provides a more sophisticated approach for considering
effeqts of building mitigation for worst-case (if appropriate) and alternative scenarios
involving release, of gases and mixtures of gases and entrained liquid. Analysis of
release scenarios inside buildings involves consideration of the structure of the
building, liquid rain-out, and release containment issues. The procedure addressing
these issues which is recommended for developing release rate estimates for both
worst-case (if appropriate) and alternative scenarios is presented in Figure 4-9.
October 27,1998
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Chapter 4
•4-41 Offsite Consequence Analysis
The release into the building is assumed to occur over a 10-minute period. For the
worst-case scenario, die quantity released into the building equals the total quantity in
... .. the largest vessel or pipeline. For alternative scenarios, you must estimate the total
quantity of ammonia, chlorine, of sulfur dioxide released from the equipment over a
10-minute period. This 10-minute assumption is made to keep this guidance simple.
Calculations of the likely rise in pressure show that, for a release distributed over 10
minutes, building failure is unlikely to occur unless you have a very large vessel in a
very small room. However, if the ratio of room volume to quantity in the vessel is <
0.1 ftVlb for ammonia and < 0.05 ft?/lb for chlorine or sulfur dioxide, you should look
.at the possibility that the room will fail by windows blowing out or doors blowing
open. ,
If the release is indoors directed towards a door or window that is potentially open, the
release rate to the outside is the total quantity, uniformly distributed over. 10 minutes.
If the release is indoors and not directed towards a door or window, mitigation of the
release by scrubbing, rain-out, or ventilation dilution may occur. If there is a scrubber,
the release of material to the environment may be low. If there is no scrubber, the
ventilation rate Nv, expressed as room volumes exchanged per hour, is identified, and
the room volume per unit quantity of either ammonia, chlorine, or sulfur'dioxide
vapor released to the room (0) and the quantity airborne in the room (QJ are
calculated for either a vapor or a vapor/liquid release.
For vapor releases, the amount of vapor released into the room is clearly Q, so 0 =
V/Q. For a flashing liquid release, = 20 percent of the release typically flashes to
vapor, so 0 = V/(0.2Q). The quantity airborne in the room is the total quantity
released from the equipment to the room in 10 minutes for vapor releases and four-
tenths of the total quantity released from the equipment to the room in 10 minutes for
vapor/liquid releases. The basis for this four-tenths assumption is that, in a room, a
flashing liquid jet will encounter obstacles that will cause 60 percent of the release to,
collect as a relatively slowly evaporating pool on the ground. The release over the
initial ten minutes leads to predictions of higher concentrations downwind than does
the slowly evaporating pool; therefore, you can consider only the release rate of the
airborne material (0.4Q/10) and ignore the evaporating pool in estimating the distance
to the toxic endpoint.
Given the values of Nv and 0, the building mitigation factor (FR,0) is identified for
10-minute releases of ammonia in Exhibit 4-27, and for. 10-minute releases of either
chlorine or sulfur dioxide in Exhibit 4-28, respectively. The release rate to the
environment is the total quantity airborne in the room, reduced by the building
mitigation factor, distributed uniformly over 10 minutes.
Example: A 25-ton (50,000 Ib) chlorine storage vessel is in a room of
. dimensions 40 feet x 40 feet x 30 feet = 48,000 ft3. There is a worst-
case release, so that the 50,000 Ib is released into the building over a
• period of 10 minutes. The release is not adjacent to a potentially
open door or window. Because it is a worst-case scenario, the
scrubber (if there is one) is not operating. The ventilation rate Nv = 4.
The release is a mixture of vapor and liquid droplets, so that 0 =
October 27, 1998 >
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Chapter 4
Offsite Consequence Analysis
4-42
V/(0.2Q) = 48,000/10,000 = 4.8 fP/lb, and the airborne quantity Q, =
Q.4Q = 20,000 Ib. From Exhibit 4-27, with Nv = 4 and0 = 4.8 (the
closest entries on Exhibit 4-27 are Nv = 5 and 0 = 4.0), FR10 = 0.46.
Therefore, the predicted worst-case scenario release rate from the
building is:
0.46x((0.4x50,000)/10) = 920 Ib/min
Compare this value with 5,000 Ib/min from an open-air release. From
Exhibit 4-4, the predicted distance for a 920 Ib/min release at a rural
site is 6.3 miles and, at an urban site, is 2.9 miles. By comparison,
the 5,000 Ib/min release would lead to corresponding distances of 15
miles and 7 miles, respectively.
Example: Take a chlorine alternative scenario for a flashing liquid release
through a 1/4-inch hole (see Section 4.2). Exhibit 4-13 shows a
release rate of 150 Ibs/min for this release. Assume this release takes
place in a building with no scrubber for 10 minutes at a release rate of
150 Ib/min for a total release of 1,500 Ib. Assume that the building
has dimensions of 50 feet x 25 feet x" 20 feet = 25,000 ft3. The
release is a flashing liquid and, therefore, consists of a mixture of
vapor and liquid Q,, the quantity that becomes airborne, is
(6.4)( 1,500) = 600 Ib. The quantity of vapor is (0.2)( 1,500) = 300 Ib.
Then 0 = 25,000/300 = 83 = 80. You will have to determine Nv from
the characteristics of your building. For this example, assume that the
building is being ventilated with Nv = 5. From Exhibit 4-28, FR10 =
0.32, so that the rate of release to the external atmosphere is
(6.1)(0.32)(600) = 19 Ib/min. From Exhibit 4-12, the predicted
distance to the endpoint is 0.2 mile for a rural site and 0.1 mile for an
urban site. For the original release rate of 150 Ib/min, the distances to
the endpoint are 0.6 mile for a rural site and 0-2 mile.for an urban
site.
October 27,1998
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4-43
Chapter4
Offsite Consequence Analysis
EXHIBIT 4-27
TEN-MINUTE BUILDING RELEASE ATTENUATION FACTORS FOR PROLONGED
RELEASES OF ANHYDROUS AMMONIA
e
(nrVkg)
160
' -'
80
32 ,
16
Nv
(hr-1)
0
1
5
10
20
30
'40
0
1
5
10
20
30
40
0
1
5
10
20
30
40
0
. 1
5
10
20
30
40
FR10
(dim)
0.07
0.08
0.32
0.51
0.71
0.80
0.85. '
0.13
0.13
0.32
0.51
0.71
0.80
0.85
0.29 ,
0.29
0.32
0.51
0.71
0.80
0.85
0.47
0.47
0.47
0.51
0.71
0.80
0.85
0
(m3/kg)
8.0
'
4.0
•
0.80
0.32
Nv .
(hr-1)
0
1
5
10
20
30
40
0
1
5
10
20
30
40
0
1
5
10
20
30.
, 40
0
1
5
10
20
30
40
FR10
(dim)
0.67
0.67
0.67
0.67
0.71
0.80
0.85
0.83
0.83
0.83
0.83
0.83
0.83
0.85
0.97
0.97
, 0.97
0.97
0.97
0.97
0.97
0.99
0.99
0.99
0.99
0.99
0.99
0.99
October 27, 1998
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Chapter 4
OfFsite Consequence Analysis
4-44
EXHIBIT 4-28
TEN-MINUTE BUILDING RELEASE ATTENUATION FACTORS FOR PROLONGED
RELEASES OF CHLORINE AND SULFUR DIOXIDE
e
(m3/kg)
160
80
32
16
Nv
Oir'1)
0
1
5
10
20
30
40
0
1
5
10
20
30
40
0
1
5
10
20
30
40
0
1
5
10
20.
30
40
FRJO
(dim)
0.02
0.08
0.32
0.51
0.71
0.80
0.85
0.03
0.08
0.32
0.51
0.71
0.80
0.85
0.08
0.08
0.32
0.51
0.71
0.80
0.85
0.15
0.15
0.32
0.51
0.71
0.80
0.85
e
(m3/kg)
8.05
4.0
0.80
0.32
Nv
(hr-1)
0
1
5
10
20
30
40
0
1
5
10
20
30
40
0
1
5
10
20
30
40
0
1
5
10
20
30
40
FR10
(dim)
0.28
0.28
0.32
0.51
0.71
0.80
0.85
0.46
0.46
0.46
0.51
0.71
0.80
0.85
0.85
0.86
0.86
0.86
0.86
0.86
0.86
0.94
0.94
0.94
•0.94
0.94 .
0.94
0.94
October 27,1998
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Chapter 4
4-45 Offsite Consequence Analysis
4.4 ESTIMATING OFFSITE RECEPTORS
The rule requires that you estimate in the RMP residential populations within the
circle defined by the endpoint for your worst-case and alternative release scenarios
(i.e., the center of the circle is the point of release and the radius is the distance to the
endpoint). In addition, you must report in the RMP whether certain types of public
receptors and environmental receptors are within the circles.
RESIDENTIAL POPULATIONS
i _ ' \ . •
To estimate residential populations, you may use the most recent Census data or any
other source of data that you believe is more accurate. You are not required to update
Census data or conduct any surveys to develop your estimates. Census data are
available in public libraries and in the LandView system, which is available on
CD-ROM (see box below). The rule requires that you estimate populations to
two-significant digits. For example, if there are 1,260 people within the circle, you
may report 1,300 people. If the number of people is between 10 and 100, estimate to
the nearest 10. If the number of people is less than 10, provide the actual number.
Census data are presented by Census tract. If your circle covers only a portion of the
tract, you should develop an estimate for that portion. The easiest way to do this is to
determine the population density per square mile (total population of the Census tract
divided by the number of square miles in the tract) and apply that density figure to the
number of square miles within your circle. Because there is likely to be considerable
variation in actual densities within a Census tract, this number will be approximate.
The rule, however, does not require you to correct the number.
OTHER PUBLIC RECEPTORS
Other public receptors must be noted in the RMP (see the discussion of public
receptors in Chapter 2). If there are any schools, residences, hospitals, prisons, public
recreational areas or arenas, or commercial or industrial areas within the circle, you
must report that. You are not required to identify the specific public receptors; you
.must simply check off the categories of such areas within the circle. Most receptors
can be identified from local street maps. •
ENVIRONMENTAL RECEPTORS
Environmental receptors are defined as natural areas such as national or state parks,
forests, or monuments; officially designated wildlife sanctuaries, preserves-; refuges, or
areas; and Federal wilderness areas. Only environmental receptors that can be
identified on local U.S. Geological Survey (USGS) maps (see box below) need to be
considered. You are not required to locate each of these specifically. You are only
required to check off in the RMP which specific types of areas are within the circle. If
any part of one of these receptors is within your circle, you must note that in the RMP.
October 27,1998
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Chapter 4
OFfsite Consequence Analysis
4-46
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 4-10 is one suggested example of how the
consequences of worst-case and alternative scenarios might be presented. It is a
simplified map that shows the radius to which the vapor cloud might extend, given the
worst-case release in worst-case weather conditions (the owner or operator should use
a real map of the area surrounding the site). 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 ®m is a desktop mapping system that includes database extracts from EPA, the Bureau of
the Census, the U.S. Geological Survey, the Nuclear Regulatory Commission, the Department of
Transportation, and the Federal Emergency Management Agency. These databases are presented in a
geographic context on maps that show jurisdictional boundaries, detailed networks of roads, rivers,
•and railroads, census block group and tract polygons, schools, hospitals, churches, cemeteries, airports,
dams, and other landmark features.
CD-ROM for IBM-compatible PCS
CD-TGR95-LV3-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.
October 27, 1998
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- 4-47
Chapter 4
Offsite Consequence Analysis
How TO OBTAIN u£&S 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 '
www.mapping.usgs.gov/ - '
To order USGS maps by fax, select, print, and complete one of the online forms and fax to
303-202-4693. A list of commercial dealers also is available at
www.mapping.usgs.gov/esic/usimage/dealers.html/. For more information or ordering assistance, call
1-800-HELP-MAP, or write:
USGS Information Services
Box 25286 '
Denver, CO 80225 .
For additional information, contact any USGS Earth Science Information Center or call
,1-800-USA-MAPS.
4.5 DOCUMENTATION
You need to maintain onsite the following records on the offsite consequence ,
analyses:
For the worst-case scenario, a description of the yessel or pipeline selected as worst-
case, assumptions and parameters used and the rationale for selection; assumptions
include use of any administrative controls and any passive mitigation systems that you
assumed to limit the quantity that could be released.
For alternative release scenarios, a description of the scenarios identified, assumptions
and parameters used and the rationale for the selection of specific scenarios;
assumptions include use of any administrative controls and any mitigation that were
assumed to limit the quantity that could be released. Documentation includes the
effect of the controls and mitigation on the release quantity and rate. You can-
reference this guidance if you use any of the "canned" scenarios described herein.
October 27,1998
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Chapter 4
Offsite Consequence Analysis 4-48
Other data that you should maintain includes:
+ ' " Documentation of estimated quantity released, release rate and duration of
release.
4- Methodology used to determine distance to endpoints (it will be sufficient to
reference this guidance if you used it for that purpose).
+ Data used to identify potentially affected population and environmental
receptors.
ii , '
4.6 SYMBOLS FQR CHAPTER 4
Ah area of hole in pipe, in2
Ap area of pool or diked area, ft2
Cp specific heat of gas at constant pressure, Btu/lb/°F
Cp| specific heat of liquid, Btu/lb/TF
Cv specific heat of gas at constant volume, Btu/lb/T
D distance to toxic, or explosive endpoint, mi
dh diameter of hole in pipe or tank, ft2
F frictional loss factor in equation for calculating the rate of discharge of liquid chlorine, sulfur
dioxide, or ammonia from a pipe, dimensionless
g acceleration due to gravity, 32ft/s2
h static head in a vessel, ft
hL latent heat of vaporization of a liquid, Btu/lb
H maximum head space in a digester, ft
L length of pipework, ft
Nv ventilation rate, room volumes/hr
pg gauge pressure, pounds per square inch gauge (psig)
pa absolute pressure, pounds per square inch absolute (psia)
Q mass released, Ib
Q, mass that remains airborne for the case of a release of chlorine, sulfur dioxide, or anhydrous
ammonia into a building, Ib
QR rate of release, Ib/min
QS mass spilled into a pool, Ib
r radius of a digester, ft
Rvp(T) ratio of vapor pressure of ammonia over a pool of aqueous ammonia at temperature T to the vapor
pressure at 25 °C, dimensionless
T temperature, °F or °C, depending on context
V volume of a digester in a room, ft3
vt£ difference in specific volume between gas and liquid, ft3/lb
X percent of methane in digester gas, dimensionless
Y ratio of specific heats, CJC^, dimensionless
pL density of liquid, lb/ft3
pm density of methane in digester gas, lb/ft3
p0 density of gas at pressure pa, lb/ft3
8 room volume per unit mass of chlorine, sulfur dioxide, or anhydrous ammonia, ft3fib
& approximately equal to
approximately
October 27.1998
-------
Figure 4-1 Worst-Case Scenario-Predicted Distances to Toxic Endpoint
For Chlorine @ Atmospheric Stability Class F with Windspeed 1.5 m/s
rural.
urban
Model Limit
0.01
10
100 "" 1000
Rate of Release (Ibs/min)
5000 10000 2000° 5QOO° 100000
-------
Figure 4-2 Worst-Case Scenario - Predicted Distances to Toxic Endpoint
For S02 @ Atmospheric Sability Class F with Windspeed 1.5 m/s
0.01
•rural
•urban
•Model Limit
50° 1000 200°
500° 10000 2000° 5000° 100000
Rate of Release (Ibs/min)
-------
Figure 4-3 Worst-Case Scenario - Predicted Distances to Toxic Endpoint
Anhydrous Ammonia ©Atmospheric Stability Class F with Windspeed 1.5 m/s
» rural
• urban
Model Limit
Power (rural)
10
100 1000
Rate of Release (Ibs/min)
10000 2000° 5000° 100000
-------
Figure 4-4 Worst-Case Scenario - Predicted Distances To Toxic Endpoint
Aqueous Ammonia @ Atmospheric Stability Class F with Windspeed 1.5 mis
10.00
0.01
10
100 1000
Rate of Release (!bs/min)
10000
20000 50000
100000
-------
Figure 4-5 Alternative Case Scenario - Predicted Distances To Toxic Endpoint
For Chlorine @ Atmospheric Stability Class D with Windspeed 1.5 m/s
10.00
I.
! 1.00
¥
'o
% .0-5
ill
o
'I
f:
at
o
0.2
a
0.10-
0.05
0.02
0.01
5 10 20
50
100.
200 500
2000 50001000() 20000 50000
Rate Of Release (Ibs/min)
-------
10.00
£ 1.00
c
'5
•o
£
o
'x
.2
0)
0.5
0.2
0.05
0.02
0.01
Figure 4-6 Alternative Case Scenario - Predicted Distances To Toxic Endpoint
For S02 @ Atmospheric Stability Class D with Windspeed 1.5 m/s
^:
v^
~J*\
25 10 2V M 100 20° 50° 1000 JTO 500I) 10000 200° 5GM 100000
Rate Of Release (Ibs/min)
-------
10.0000
(0
0)
E 1.0000
c
'5
a
•a
in
u
x
8
0.5
0.2
0.1000 -
0.05
0.02
0.0100
Figure 4-7 Alternative Case Scenario - Predicted Distances To Toxic Endpoint
For Anhydrous Ammonia @ Atmospheric Stability Class D with Windspeed 1.5 m/s
1 2 5 10 20 50
200 500 100Q 2000 5000
Rate Of Release (Ibs/min)
20000 50000
-------
10.00
w
E 1.00-
c
'5
t
LU
o
'x
,2
8
0.5
0.2
0.10
0.05
0.02
0.01
Figure 4-8 Alternative Case Scenario - Predicted Distances To Toxic Endpoint
For Aqueous Ammonia @ Atmospheric Stability Class D with Windspeed 1.5 m/s
^T
^1
pr
1Q
20 50 100 20° 50° 1000 200° 500° 10000 20000 50000 100000
Rate Of Release (Ibs/min)
-------
Adjacent
to door or
indow
Minimal
Release to
Environment
No
Choose Ny
(far')
Calculate
e = V/M
Airborne
Mass
Ma = M
Nn
t
Calculate
.4 - V/(0.2M)
Airborne
Mass
M. = 0.4M
Calculate FR,0
Table 4- 17 or 4- 18
Release Rate
to- outside
0.1FR,0Ma
Ib/min
*?;
•*».
Figure 4-9. Guidance on Effectiveness of Building Mitigation for Alternative Scenarios
-------
Figure 4-10 Simplified Presentation of Worst-Case
and Alternative Scenario on a Local Map
Radius for
Alternative
Scenario
Radius for
Worst-case Scenario
-------
Chapter 4
4-59 Offsite Consequence Analysis
APPENDIX4A
EQUATIONS
AMMONIA PARTIAL PRESSURE
The ratio Rvp(T) of the partial pressure of ammonia at temperature T "C to the partial pressure at 25 CC is'
given by the empirical formula:
R^T) = exp[10.438 - 7J7.4/(T + 273.4) - 2132.5/(T + 240.25)] '
DENSITY OF METHANE IN DIGESTER
pm = (X/100)(0.0409)(537/(460+T)) = 0.22 X/(460+T)
where 0.0409 Ib/ft3 is the density of pure methane at 77 °F (25 °C) and the factor (537/(460+T) represents
how the density changes with temperature, assuming that methane obeys the perfect gas law. The effect of
the small operating pressure in compressing the gas has been ignored.
ALTERNATIVE RELEASE EQUATIONS
Bernoulli's Formula
The rate of release of a liquid through an hole is given by Bernoulli's formula for predicting the rate of
release QR (Ib/min) of liquid from a vessel:
m=AhCd(pl[2Spl(HL-Hh) + 2(P0-PaWf (A-l)
where: m = Discharge rate (kilograms per second)
Ah = , Opening area (square meters) . .
Cd = Discharge coefficient (unitless) ,
g. = Gravitational constant (9.8 .meters per second squared)
p, = Liquid density (kilograms per cubic meter)
P0 = Storage pressure (Pascals)
Pa = - Ambient pressure (Pascals)
HL = Liquid height above bottom of container (meters)
Hh = Height of opening (meters)
To create the equations in the text, this equation was converted to English units.'
Gases Liquefied under Pressure
For gases liquefied under high pressure, the term containing the liquid height in Equation A-l can be
"• neglected. The equation for the release rate for gases liquefied under pressure becomes:
• '- ' • '*
= 32.07xAAxp,x(Pg/P!)a5 (A-2)
October 27,1998
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Chapter 4
Offsite Consequence Analysis 4-60
To derive the chemical specific. factors presented in the text for gases liquefied under their vapor pressure
at 25 °C, the following data were substituted into Equation A-3:
Liquefied Gas Liquid Density fpL). Ibs/ft3 Tank Vapor Pressure (P£\ psig
Chlorine 97.5 98.5
Sulfur dioxide 91.3 43.3
Ammonia 42.5 130
Liquid at Ambient Pressure '
For liquids stored at ambient pressure, the difference between storage pressure and ambient pressure is
zero, and the pressure term drops out of Equation A-1 above. The equation can be rewritten and converted
to English units as follows:
QR=132.2xAAx6.4516xlO-4x(/2;°-5x0.5521x0.8x(2x9.8)°-5xpLxl6.018 (A-3)
where: QR = Release rate (pounds per minute)
132.2 = Conversion factor for kilograms per second to pounds per minute
Ah = Hole area (square inches)
6.4516 x 10"4 = Conversion factor for square inches to square meters (HA)
0.552 1 = Conversion factor for square root of feet to square root of meters
(h)
0.8 = Discharge coefficient (0.8)
9.8 = Gravitational constant (meters per second squared)
pL = Liquid density (pounds per cubic foot)
16.018 = Conversion factor for pounds per cubic foot to kilograms per
cubic meter
For ammonia solution, the factor presented in the text was derived assuming a density of 57.33 lb/ft3.
Two-Phase Release
For long pipes (L/dh » 1, where L is the length of the pipe between the reservoir of chlorine and the
atmosphere and dh is the pipe diameter), there can be flashing in the discharge pipe, and a two-phase
mixture emerges to the atmosphere. In this case, the rate of release in Ib/min is given by:
= 9,490(Ah)(F)(hL)/[vlg([T + 460]Cpl)w] (A-4)
where those symbols not already defined are: "
October 27,1998
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Chapter 4
4-61 Offsite Consequence Analysis
F a factional loss factor, which is dimensionless and takes on a value of 1 for L/dh= 10, 0.85
for L/dh = 50, 0.75 for L/dj, = 100, 0.65 for L/4 =200, and 0.55 for L/4,= 400.
hL" the latent heat of vaporization (Btu/lb) •
v,g the difference in specific volume between the gas and liquid (Ib/ft3)
T , the reservoir temperature (°F), and
Cp, the liquid heat capacity (Btu/lb/°F)
For chlorine, hL is 1 24 Btu/lb, vlg = 0.68 Ib/ft3, T = 77 °F (25 °C), and q,, = 0.222 Btu/lb/'F.
For sulfur dioxide, vlg = 1 .55 ftVlb, hL = 80 Btu/lb, c,,, = 0.34 Btu/lb/°F. ' /
~ Vapor Releases
For a gas release under choked flow conditions (i.e., emerging.at the speed of sound from the hole, the
maximum flow rate), the following equation can be used to estimate the release rate:
™=. QA^Y^PoP/CY+l)]^1^0)0'5 (A-5)
where: m = Discharge rate (kg/s)
Cd -=• Discharge coefficient
Ah - Opening area (m?) .
y = Ratio of specific heats
Po = - ' ; Tank pressure (Pascals)
Po " = Density (kg/m3)
Density (p0) can be rewritten as a function of pressure and molecular weight, based on the ideal gas law:
p0 = (PoxMW)/RT, ' (A-6)
where: MW = Molecular, weight (kilograms per kilomole)
R = Gas constant (8,314 Joules per degree-kilomole)
T, - = Tank temperature (K)
The choked flow equation can be rewritten and converted to English units as follows:
(A-7)
where: 0.8 , = Discharge coefficient
132.2 = Conversion factor for Ibs/min to kg/s
6,895 .= Conversion factor for psi to Pascals
6.4516x10^ = Conversion factor for square inches to square meters
Pa = Absolute pressure in the reservoir/tank (psia) .
Ah = Hole area (inches)
To derive the chemical-specific factors for gas releases presented in the text, the temperature (T) was
assumed to be 298 K, and the following chemical-specific data were substituted into Equation A-2:
October 27,1998
-------
Chapter 4
Offsite Consequence Analysis 4-62
Gas Molecular Weight (MW) Tank Pressure (P.,) (psia) Ratio of Specific Heats (y)
'• Chlorine 70.91 113 1.32
Sulfur dioxide 64.07 58 ' 1.26
LOG-LOG TABLE EQUATIONS
This section presents formulas for estimating the distance to the endpoint from the rate of release for each
of the toxic substances addressed in this document. The formulas are given in the form:
D = a (QR)b (A-9)
where: D = distance to the endpoint (miles)
aandb = chemical-specific factors
QR = release rate (Ibs/min)
The formulas for each chemical were developed based on the best straight-line fits to the log-log graphs of
release rate versus distance (Figures 4-1 to 4-8). The formulas are easy to use with a scientific calculator
and may be used instead of the distance tables or figures. Since the equations are best fits to the curves on
Figures 4-1 to 4-8, they may not give exactly the same predictions as appear in the corresponding exhibits-
Chlorine . i
Worst Case. The guidance on Figure 4-1 is essentially in the form of a straight line on a log-log plot:
D = 0.2273(QR)°'4879 for a rural site, and
D = 0.0878(QR)°-5134 for an urban site
Alternative. Figure 4-5 is roughly a straight line on a log-log plot:
D = 0.053(QR)a4647 for a rural site, and
D = 0.0?6(QR)°-4263 for an urban site.
Sulfur Dioxide
Worst Case. The guidance on Figure 4-2 is essentially in the form of a straight line on a log-log plot:
D = 0.1 fi^QR)0-5562 for a rural site, and
D = 0.0726(QR)°'5419 for an urban site.
Alternative. The curves on Figure 4-6 are approximately straight lines on a log-log plot:
D = 0.047(QR)°-4961 for a rural site, and
D = 0.025(QR)°-44(" for an urban site. ,
Ocwbcr27,1998
-------
- . - • Chapter 4
4-63 Offsite Consequence Analysis
Anhydrous Ammonia '
Worst Case. The guidance on Figure 4-3 is essentially in the form of a straight line on a log-log plot:
D = 0.0607(QR)°-4923 for a rural site, and
D = 0.0443(QR)0-4782 for an urban site.
, Alternative. The curves on Figure 4-7 are approximately straight lines on a log-log plot:
D = 0.0222(QR)°-4780ataruralsite,and . ,
• D = 0.0130(QR)°-4164 at an urban site.
Aqueous Ammonia
Worst Case. The guidance on Figure 4-4 is essentially in the form of a straight line on a log-log plot:
D = 0.0667(QR)°-4617 for a rural site, and
, D = 0.0221(QR)°-4712 for an urban site.
Alternative. 'The curves on Figure 4-8 are roughly straight lines on a log-log plot:
D = 0.02(QR)°-5174 for a rural site, and ' '
- D = 0.0107(QR)°-4748 for an urban site. ' • • .
October 27.1998
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Chapter 4
Offsite Consequence Analysis 4-64
APPENDIX 4B
LIMITATIONS OF RESULTS
The guidance in the present document is summarized in the form of various tables and plots giving the
predicted distance to the toxic endpoint as a function of the rate of release. There are upper and lower
limits on the validity of these tables and plots—the models used are not valid beyond 25 miles, nor at less
than 0.06 mile (100 m ~ 300 feet). It should be noted that the guidance presented in this chapter in the
form of plots and tables yield predictions that are among many possible. There is, in fact, a wide range of
uncertainty, partly due to the still incomplete theoretical understanding of the atmospheric dispersion of
large-scale accidental releases of hazardous vapors in the industrial environment, partly due to the need to
specify the values of a number of parameters, the values of which may not be well known, and partly
because there are relatively few large-scale experimental data sets with which to "tune" the models,
especially for the conditions applicable to the worst-case scenario. Therefore, for any given rate of release
of a specific material, such as chlorine, there may be a wide variety of predictions by analysts using
different models, or using the same model with different input parameters. The potential range of
uncertainty is addressed in the Backup Document.
An attempt has been made to develop guidance in the mid-range of possibilities, with the hope that the
most extreme conservatisms have been removed, but which is still modestly conservative. As a general
(and much simplified) rule, you should not be surprised if, for worst-case scenarios, other analysts and
models produce predictions that may be up to a factor of three higher or a factor of three lower than those
presented here.
The predictions in the distance tables in the exhibits and all other predictions in this report for regulated
toxic chemicals are based upon the methods described in the Backup Document. That method consisted of
performing a range of sensitivity studies and then choosing guidance that lies within that range.
There are a number of caveats of which you should be aware.
The results given in the exhibits and figures are not in any absolute sense the "right" or "correct" ones. On
the contrary, the Backup Document contains predictions from many sources. The intention there is to
establish a range of uncertainties that might be regarded as reasonable by practitioners in the field of
atmospheric dispersion modeling, and then to locate a reasonable guidance curve (such as Figure 4-1)
Within that range of uncertainty. In this way, it is hoped that the following objectives will be achieved:
+ The facts that the results are uncertain and that there is no uniquely "right" result are not
disguised.
+ Nevertheless, there is a reasonable solution that is easy to use, and users of this guidance
do not have to understand its derivation.
As noted above, the further downwind, the more likely it is that you are beyond the range of applicability
of any atmospheric dispersion model. That is why, for the 90-ton railcar release of chlorine, the result is
stated as "> 25 miles." For such a large release of chlorine, it is unlikely that you will find any model that
will predict any less than this distance, and some will predict considerably more. There is no way to avoid
the conclusion that the distance to the toxic endpoint for a worst-case release from a 90-ton chlorine railcar
is very large, even though the current state of the models does not allow us to say exactly how far "large"
is. Note that the discussion in this paragraph applies to railcars that are in the open air.
October 27.1998
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Chapter 4
4-65 Offsite Consequence Analysis
For the 150-lb and one-ton cylinder case, the results are uncertain to within perhaps a factor of 5-10. The
Backup Document shows that, under certain modeling assumptions, the predicted distances could be
perhaps a factor of three larger than those stated above or a factor of three smaller. You will also almost
certainly be able to find a computer model that can be run to produce even smaller predicted distances. If
you opt to do that, you will have to produce justification that the modeling is reasonable. [Note, however,
that you are not obliged to use the guidance presented here; you can use whatever model you want
provided that you have a solid scientific basis for doing so]. The fact that these large uncertainties exist
explains why it is so difficult to develop a single guidance curve that everyone accepts. Many different
choices for the guidance could fit comfortably within the range of uncertainties. •
October 27, 1998
-------
-------
CHAPTER 5: MANAGEMENT SYSTEM
5.1 GENERAL INFORMATION (§68.15)
If you have at least one Program 2 or Program 3 process (see Chapter 2 for guidance
on determining the Program levels of your processes), the management system
provision in § 68.15 requires you to: -..'..
Develop a management system to oversee the implementation of the risk management
program elements;
Designate a qualified person or position with the overall responsibility for the
development, implementation, and integration of the risk management program
elements; and -.-.•- •
Document the names of people or positions and define the lines of authority through
an organizational chart or other similar document, if you assign responsibility for
implementing individual requirements of the risk management program to people or
positions other than the person or position with overall responsibility for fee risk
management program.
ABOUT THE MANAGEMENT SYSTEM PROVISION
Management commitment to process safety is a critical element of your facility's risk
management program. Management commitment should not end when the last word
of the risk management plan is composed. For process safety to be a constant priority,
your facility must remain committed to every element of the risk management
program.
This rule takes an integrated approach to managing risks. Each element must be
implemented on an ongoing, daily basis and become a part of the way you operate.
Therefore, your commitment and oversight should be continuous.
By satisfying the requirements of this provision, you are ensuring that:
+ The risk management program elements are integrated and implemented on an
ongoing basis; and
4- 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 p'osition 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.
October 26,1998 '
-------
Chapter 5
Management System
5-2
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. Recognise 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.
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?
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 hi your RMP do not require you to update your RMP.
Unes of Authority
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
October 26.1998
-------
Chapters
• 5-3 . .^, - ' Management System
the lines of authority at your facility. You may find that you can simply use or update
current documents to satisfy this part of the management system provision. Exhibit
5-1 provides a sample of another type of documentation you may use in addition to or
as a replacement for an organization chart. - '
Defining the lines of authority and roles and responsibilities of staff that oversee the
risk management program elements will help to:
4- Ensure effective communication about process changes between divisions;
+ Clarify the roles and responsibilities related to process safety issues at your
! facility; ,
4 Avoid problems or conflicts among the various people responsible for
implementing elements of the risk management program;
4 Avoid confusion and allow those responsible for implementation to work
together as a team; and
•*• 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.
October 26,1998
-------
Chapter 5
Management System
5-4
EXHIBIT 54
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
October 26, 1998
-------
5-5
Chapter5
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 -
October26,1998
-------
-------
CHAPTER 6: PREVENTION PROGRAM (PROGRAM 2)
6.1 ABOUT THE PROGRAM 2 PREVENTION PROGRAM
EPA developed the Program 2 prevention program by identifying the basic elements
that are the foundation of sound prevention practices — safety information, hazard
review, operating procedures, training, maintenance, compliance audits, and accident
investigation. By meeting other Federal regulations, state laws, industry codes and
standards, arid good engineering practices, you probably have already met most of the
Program 2 prevention elements requirements.
As important as each of the elements is, you will not gain the full benefit from them
• unless you integrate them into a risk management system that you implement on an
on-going basis. For example, the hazard review must be built on the safety
information; the results of the hazard review should be used to revise and update
operating and maintenance procedures. Workers must be trained in these procedures
and must use them every day.
You will have substantially less documentation and recordkeeping responsibilities for
a Program 2 process than you will for a Program 3 process. There are seven elements
in the Program 2 prevention program, which is set forth Subpart C of part 68. Exhibit
6-1 sets out each of the seven elements and corresponding section numbers.
You must integrate these seven elements,into a risk management program that you and
"your staff implement on a daily basis. Understanding and managing risks must be part
- of the way you operate. Doing so will provide benefits beyond accident prevention.
Preventive maintenance and routine inspections will reduce the number of equipment
failures and down time; well-trained workers, aware of optimum operating parameters,
will allow you to gain the most efficient use of your processes and raw materials.
6.2 SAFETY INFORMATION (§ 68.48)
The purpose of this requirement is to ensure that you understand the safety-related
aspects of the equipment and processes you have, know what limits they place on your
operations, and adopt accepted standards and codes where they apply. Having
up-to-date safety information about your process is the foundation of an effective
prevention program. Many elements (especially the hazard review) depend on the
accuracy and thoroughness of the information this element requires you to provide.
October 27, 1998
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Chapter 6
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6-2
EXHIBIT 6-1
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
WHAT Do I NEED To Do?
You must compile and maintain safety information related to the regulated substance's
and process equipment for each Program 2 process. You probably have much of this
information already as a result of complying with OSHA standards or other rules.
EPA has limited the information to what is likely to apply to the processes covered
under the Program 2 program. Exhibit 6-2 gives a brief summary of the safety
information requirements for Program 2.
How Do I START?
MSpSs. If you are subject to this rule, you may also be subject to the requirements to
maintain Material Safety Data Sheets under the OSHA Hazard Communication
Standard (HCS) (29 CFR 1910.1200). POTWs in states with delegated OSHA
programs and all private WWTPs are subject to OSHA's HCS.
If you do not have an MSDS for a regulated substance, you should contact your
supplier or the manufacturer for a copy. Because methane (CH^ is generated in your
plant, you will have to find an MSDS elsewhere. A local utility supplying natural gas
niay have one. You may, however, have to add the potential for inclusion of carbon
dioxide, hydrogen sulfide, and water in the methane stream. If these are present, then
the cprrpsivity information about that stream will be needed You may wish to ask
assistance from a process engineer.
Because the rule states that you must have an MSDS that meets OSHA requirements,
you may want to review the MSDS to ensure that it is, in fact, complete. Besides
providing the chemical name, the MSDS for a regulated substance (or a mixture
containing the regulated substance) must describe.the substance's physical
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Chapter 6
Prevention Program (Program 2)
: and chemical characteristics (e.g., flash point, vapor pressure), physical hazards (e.g.,
flammability, reactivity), health hazards, routes of entry, exposure limits (e.g., the
OSHA permissible exposure level), precautions for safe handling, generally, applicable
control measures, and emergency and first aid procedures. (See 29 CFR 1910.1200(g)
for the complete set of requirements.for an MSDS.)
EXHIBIT6-2
SAFETY INFORMATION REQUIREMENTS ,
You must compile and
maintain this safety
information;
•Material Safety Data
Sheets
•Maximum intended
inventory
•Safe upper and lower
parameters
•Equipment specifications
•Codes & standards used to
design, build, and operate the
process
You must ensure:
•That the process is designed
in compliance with recognized
codes and standards
You must update the safety
information if:
•There is a major change at
your business that makes the
safety information inaccurate
Maximum Inventory. You must document the maximum intended inventory of any
vessel in which you store or process a regulated substance above its threshold
quantity. The Ul A certificates on all vessels constructed under the ASME Boiler and
Pressure Vessel Code are kept on file by the National Board (see chapter 1). The
nominal nameplate capacity can also be found on the permanently attached nameplate
, for your storage tank. The nameplate will also have the National Board Number for
your vessel, which is the key to retrieving your Ul A form from the Board. These
nameplates may be located on one of the hemispherical heads, the manway, or the
manway cover. The nominal capacity will usually be the water capacity, and you may
want to convert it to pounds. -
If you use transportation containers (railcars or tank trucks) as storage vessels, you can
obtain the capacity from the required DOT nameplate, identification plate, or
specification plate or from the owner of the containers. Smaller shipping containers
are. also marked. If you are not sure of the capacity of the vessel, you can obtain this
information from the manufacturer of the vessel or tank.
The Chlorine Institute recommends that chlorine tanks not be filled beyond 95 percent
at a maximum temperature of 122°F. OSHA regulations limit liquid volumes of
unrefrigerated anhydrous ammonia to the following:
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Chapter 6
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6-4
Type of Container
Aboveground-Uninsulated
Aboveground-Uninsulated*
Aboveground-Insulated
Underground-Uninsulated
Percent by Weight
56%
57%
58%
Percent by Volume •
82% ,
87.5%
83.5%
85%
*Aboveground uninsulated containers may be charged to 87.5 percent by volume if
the temperature of the anhydrous ammonia being charged is determined to be not
lower than 30°F or if the charging container is stopped at the first indication of frost
or ice formation on its outside surface and is not resumed until such frost or ice has
disappeared. (29CFR 1910.ill(b)(l 1))
NFPA-58 recommends that propane tanks not exceed 88 percent at 60°F. Aqueous
ammonia may be held in various concentrations; your supplier can provide the density
and weight. You can use this information, with your tank capacity, to estimate the
quantity of ammonia being stored.
The Compressed Gas Association provides the following recommendations for filling
sulfur dioxide tanks at varying temperatures (CGA pamphlet G-3):
Temperature of Liquid SO2 in Tank °F
30
40
50
60
70
80
90
100
Maximum Safe Volume Liquid SO2 in %
of Full Volume at 125% Filling Density
86
87
88
89
90
91
92
93
Storage and Process Limits. You must document the safe upper arid lower
temperatures and pressures, process flows (if applicable), and compositions (if
applicable) for your process.
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Chapter 6
6-5 Prevention Program (Program 2)
Every substance has limits on the temperature and pressures at which it can be stored
or used; these limits are determined by both the properties of the substance and the
vessels it which it is kept. If you do not know these limits, you should contact your
vendor, the substance manufacturer, or your trade association. They will be able to
provide the data you need. Some of this information (e.g., maximum pressure) may
be marked on the nameplate or container. It is important that you know these limits so
you can take action to avoid situations where these limits may be exceeded. Many
people are aware of the dangers of overheating their vessels, but extreme low
temperatures also may pose hazards you should know about.
If you are moving substances through pipes or hoses, you need to define safe
temperatures and pressures for that movement; agajn, these limits will be determined
by both the substance and the piping.* For example, the .substance may tolerate high
pressures, but the pipes may have structural limits. To operate safely, you must have
this information. The pipe manufacturer will be able to provide these data.
The requirement to compile and maintain information on process flows and
compositions will apply to you if you transfer substances through piping or hoses and
if you mix or react the substance. It is important in these cases that you understand
the safe limits for flow and composition. The pipe or hose vendors will be.able to
provide you with the maximum flow rates that their products are designed to handle.
You must also be aware of any hazards that could be created if your processes are
contaminated; for example, if your substance or equipment could be contaminated by
water, you must know whether that creates different hazards, such as corrosion.
Chlorine and SO2 become very corrosive if mixed with water. In addition, corrosion
can occur in digester gas systems if attention is not paid to the corrosive effects of
hydrogen sulfide and water that are found in digester gas.
Equipment Specifications. You must document the specifications of any equipment
you use to store or move regulated substances in a covered process. Equipment
specifications will usually include information on the materials of construction, actual
, design, and tolerances. The vendor should be able to provide this information; you
may have the specifications, in your files from the time of purchase. Some of this
information (e.g., wall thickness) may be marked on the nameplate or container. You
are not expected to develop engineering drawings of your equipment to meet this
requirement, but you must be able to document that your equipment is appropriate for
the substances and activities for which it is used, and you must know what the-limits
of the equipment are.
Specifications are particularly important if your vessels or pipes are not specifically
designed for your type of operation. Substances may react with certain metals or
corrode them if water is introduced. You should be sure that the vessels you purchase
or lease are appropriate for your operations. Understanding equipment specifications
will help you when you need to buy replacement parts. Any such parts must be
appropriate for your existing equipment and your use of that equipment. It is not
sufficient to replace parts with something that "fits" unless the new part meets the
specifications; substitution of inappropriate parts may create serious hazards.
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Chapter6
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6-6
Codes and Standards. You must document the codes and standards you used to
design and build your facility and that you follow to operate. These codes will
probably include the electrical and building codes that you must comply with under
state or local laws. Your equipment vendors will be able to provide you with
information on the codes they comply with for their products; the information may
also be listed on your equipment specifications. 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. NFPA-820 (Standard
for Fire Protection in Wastewater Treatment and Collection Facilities) is specific to
your industry and provides references to other applicable NFPA 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.
EXHIBIT 6-3
CODES ANDSTANDARDS
ORGANIZATION
American National
Standards Institute (ANSI)
American Society of
Mechanical Engineers
(ASME)
American Petroleum
Institute (API)
National Fire Protection
Association (NFPA)
American Society for
Testing Materials (ASTM)
American Concrete
Institute
SUBJECT/CODES - -• , -
Piping, Electrical, Power wiring, Instrumentation, Lighting, Product
storage and handling, Insulation and fireproofing, Painting and coating,
Ventilation, Noise and Vibration, Fire protection equipment, Safety
equipment, Pumps, Compressors, Motors, Refrigeration equipment,
Pneumatic conveying; ANSI K6 1 . 1 covers storage and handling of
anhydrous ammonia
Power boilers, Pressure vessels, Compressors, Shell and tube exchangers,
Vessel components, General design and fabrication codes
Welded tanks, Rotating equipment, Bulk liquid storage systems
Wastewater treatment facilities (NFPA-820), Fire pumps, Flammable
liquid code (NFPA-30), LPG storage and handling (NFPA-58), Plant
equipment and layout, Electrical system design, Shutdown systems,
Pressure relief equipment, Venting requirements, Gas turbines and engines,
Cooling towers, Storage tanks
Inspection and testing, Noise and vibration, Materials of construction,
Piping materials and systems, Instrumentation
Construction and inspection of concrete tanks, including' wastewater
treatment plants '
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Chapter
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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 if you are subject to the OSHA hazard
communication standard (29 CFR 1910.1200). Equipment specifications are usually
on a few sheets or in a booklet provided by the vendor; you need only keep these on
file. You can probably document the other information on a single sheet that simply
lists each of the required items and any codes or standards that apply. See Exhibit 6-4
for a sample. Maintain that sheet in a file and update it whenever any item changes or
new equipment is added. Although the rule does not require you to create a process
flow diagram, you may want to do this as another way of documenting much of .this
information.
EXHIBIT 6-4
SAMPLE SAFETY INFORMATION SHEET
— o / " J ""/•'" ' -" '* *••>'* '•*"«_ -*..«< ~i.-« - -- ? <,*"-'*'-•"'.•• *"> .cr »* '-^V-^-HJ
- -a, - •% "** -- -- Jr*"* *• - PROPANElStoRAGE ,'-«•*>• - -- - - - -_-j
"% * #* * - ^ ^ J ^ tv ^ ^ ^ ^..^ ^ ^ qpS ^ TQg v ^j^ ^
MSDS Propane
Maximum Intended Inventory
Temperature
Pressure
Flow Rate
Vapor Piping
Liquid Piping and Compressor
Discharge
Safety Relief Valves
Excess Flow Valve
Emergency Shutoff Valve
Codes and Standards
On file (1994) • .
400,000 pounds -
Upper: max 110°F .
Lower: min ^15 °F
Upper: 240 psi @ 110°F
Lower: 35 psi @ -15°F
Loading: 100 GPM (max)
Unloading: 265 GPM (max)
250PSIG
350 PSIG
Each relieves 9,250 SCFM/air , ,
RV 1 replaced 9/96
RV 2 replaced 6/97
RV 3 replaced 8/98
3", closes at 225 GPM with 100 PSIG inlet -. .
2", closes at 100 GPM with 100 PSIG inlet
2", closes at 34,500 SCFH with 100 PSIG inlet
ESV 1 1/4", closes at 26,000 SCFH with 1 00 PSIG inlet
ESV 2", closes at 225 GPM with 100 PSIG inlet
Designed under NFPA-58- 1985
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Chapter 6
Prevention Program (Program 2)
6-8
1 Piping Design
Tank Design
ASMEB31-3
ASMENB#0012
The equipment specifications and list of standards and codes will probably meet the
requirement that you ensure that your process is designed in compliance with
recognized and generally good engineering practices. If you have any doubt that you
are meeting this requirement, your trade association may be helpful in determining if
there are practices or standards that you are not aware of that may be useful in your
operation.
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.
WHERETO Go FOR MORE INFORMATION
MSDSs. MSDSs are available from a number of websites. The University of
California, San Diego Chemistry and Biochemistry Department maintains some
MSDSs on its website: http://www-ehs.ucsd.edu/msds.htm. This site also links to
other pages with MSDSs, including Vermont Safety and Information Resources on the
Internet, http://siri.org. On-line databases also provide MSDSs. EPA has not verified
the accuracy or completeness of MSDSs on any of these sites nor does it endorse any
particular version of an MSDS. You should review any MSDS you use to ensure that
it meets the requirements of OSHA's hazard communication standard (29 CFR
1910.1200).
Guidance and Reports. Although the reports below target the chemical industry,
you may find useful information in them:
+ Guidelines for Process Safety Documentation, Center_for Chemical Process
Safety of the American Institute of Chemical Engineers 1995.
+ Loss Prevention in the Process Industries, Volumes I, n, and III, Frank P.
Lees, Butterworths: London 1996.
The Chlorine Institute publishes a number of documents on chlorine handling,
including:
.+ Chlorine Vaporizing Systems, Pamphlet # 9.
+ Cylinder and Ton Container Procedures for Chlorine Packaging, Pamphlet #
"•" 17- ' ' ,, - ' • ••
4- Water and Wastewater Operators Chlorine Handbook, Pamphlet # 155.
The Compressed Gas Association publishes:
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Chapter 6
6-9 Prevention Program (Program 2)
•* Sulfur Dioxide on properties, storage, handling, and use of sulfur dioxide ,
(Order #G-3). • •*
*• ANSI K61.1 on the storage and handling of anhydrous ammonia (Order # G
•••'".•- "• 2'1}- '
^ Anhydrous Ammonia on properties, storage, handling, and use of anhydrous
ammonia (Order # G-2). N ;
The Water Environment Federations publishes the "following:
,' - - • , • ••_•'
• •+ Operation and Maintenance of Municipal Wastewater Treatment Plants
(MOP-11), Water Environment Federation.
6,3 HAZARD REVIEW (§ 68.50)
For a Program 2 process, you must conduct a hazard review. EPA has streamlined the
process hazard analysis (PHA) requirement of OSHA's PSM standard to create a
requirement that will detect process hazards for processes in Program 2. The hazard
review will help you determine whether you are meeting applicable codes and
standards, identify and evaluate the types of potential failures, and focus your
emergency response planning efforts.
WHAT DO I NEED TO DO?
The hazard review is key to understanding how to operate safely on a continuous
basis. You must identify and review specific hazards and safeguards for your Program
2 processes. EPA lists the types of hazards and safeguards in the rule. Exhibit 6-5
summarizes things you must do for a hazard review.
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Chapter 6
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6-10
EXHIBIT 6-5
HAZARD REVIEW REQUIREMENTS
Conduct a review &
identify...
Use a guide for
conducting the
review.
Document results &
resolve problems.
Update your hazard1
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 a
checklist
•For a process
designed to industry
standards like NFPA-
58 or Federal /state
design rules, check the
equipment to make sure
that it's fabricated,
installed, and operated
properly.
•Your hazard review
must be documented
and you must show that
you have addressed
problems.
•You must update
your review at least
once every five years or
whenever there is a
major change in the
process.
•You must resolve
problems identified in
the new review before
you startup the changed
process.
WHAT METHOD SHOULD I USE?
This guidance provides information on three hazard evaluation methods:
4- Checklist
4- What-If/Checklist
4- Hazard and Operability (HAZOP) Review
Checklist. When your facility has been designed and built to comply with a federal or
state standard or an industry-specific design code, it may be possible to develop a
checklist that, in and of itself, will be sufficient to conduct the hazard review. A
particularly appropriate example is propane, which some wastewater treatment
facilities store in quantities that exceed the TQ of 10,000 Ib (for example, as backup to
digester gas for electrical power generation, boilers, and heating). A propane-specific
risk management program has already been developed for propane storage facilities.
If you have propane above the TQ, you should obtain this manual, which contains a
propane facility hazards review checklist that is based upon the National Fire
Protection Association's NFPA 58, 1998 Edition. This checklist is reproduced in the
appendix to this chapter as Exhibit 6A-6.
Some sample checklists for chemicals at wastewater treatment facilities are provided
in the appendix to this chapter as follows:
Exhibit 6A-1 General Conditions, Operation and Maintenance
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• Chapter 6
6-11 Prevention Program (Program 2)
Exhibit 6A-2 Human Factors
, Exhibit 6A-3 Checklists for Chloririe and Sulfur Dioxide ;
Exhibit 6A-4 Checklist for Anhydrous Ammonia Systems
•Exhibit 6A-5 Checklist for Aqueous Ammonia Systems
Exhibit 6A-6 Checklist for Propane Storage
Finally, you may also develop your own checklist or supplement those given in this
guidance to make sure they are appropriate for your site. The review must identify the
following: - _
+ The hazards of the substance (e.g., toxicity, flammability, corrosivity) and
process (e.g., overpressurization, overfilling, inadvertent mixing);
+ Possible equipment failures or human errors that could lead to a release;
+ Safeguards used to prevent failures or errors; and
+ , Steps needed to detect or monitor releases. '
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, in the comment section.
This approach will give you a simple, concise way of keeping track of findings and
recommendations. You may also want to create a separate document of
recommendations that require implementation or other resolution. EPA does not
* require that you implement every recommendation. It is up to you to decide which
recommendations are technically feasible and warrant implementation. You may '
decide that other steps are as effective as the recommended actions or that the risk is
too low to merit the expense. You must, however, document your decision on each
recommendation. .
What-ByChecklist Analysis. The success of the checklist approach depends on the
experience of those who fill out the checklist. To ensure that the identification of
hazards is as complete as possible, it is often useful to supplement the checklist with a
What-If analysis." As the name implies, the What-If/Checklist Analysis technique is a
combination of two methods: What-If Analysis and Checklist Analysis. The analysis
is usually performed by a team of personnel experienced with the subject process.
The team uses the What-If Analysis technique to brainstorm the various types of
accidents that can occur within the process. The team then uses one or more
checklists to help fill in any gaps they may have missed.
The examples of What-If questions in Exhibit 6A-7 are derived from a variety of
sources, including: ,
*• "Guidelines for Hazard Evaluation Procedures - Second Edition with Worked
Examples," published by the Center for Chemical Process Safety (CCPS),
New York, 1992
4- Information collected from various wastewater treatment facilities during the
development of this guidance
4- .. Information from industry associations such as the Chlorine Institute and the
International Institute of Ammonia Refrigeration (IIAR), and
4; The American Water Works Association (AWWA).
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Chapter 6
Prevention Program (Program 2) 6-12
iii'i !• II'
Hazard and Operability Analysis. The Hazard and Operability (HAZOP) Analysis
" technique is based on the principle that several experts with different backgrounds can
interact in a creative, systematic fashion and identify more problems when working
together than when working separately and combining their results. Although the
HAZOP Analysis technique was originally developed for evaluation of a new design
or technology, it is applicable to almost all phases of a process' lifetime.
IK n" " " ' I./1 ' ;'" " : ' ,' ';.!"', t \ • ,.'"', ^ ' '' », ' " . ' ' '' , If , '' - ' I'
The essence of the HAZOP Analysis approach is to review process drawings and/or
procedures in a series of meetings, during which a multi disciplinary team uses a '
prescribed protocol to methodically evaluate the significance of deviations from the
normal design intention.
The primary advantage of the brainstorming associated with HAZOP Analysis is that
it stimulates creativity and generates new ideas. This creativity results from the
interaction of a team with diverse backgrounds. Consequently, the success of the
study requires that all participants freely express their views, bu.t participants should
refrain from criticizing each other to avoid stifling the creative process. This creative
approach, combined with the use of a systematic protocol for examining hazardous
situations, helps improve the thoroughness of the study.
The HAZOP study focuses on specific points of the process or operation called "study
nodes," process sections, or operating steps. One at a time, the HAZOP team
examines each section or step for potentially hazardous process deviations that are
derived from a set of established guide words. One purpose of the guide words is to
ensure that all relevant deviations of process parameters are evaluated. Sometimes
teams consider a fairly large number of deviations (i.e., up to 10 to 20) for each
section or step and identify their potential causes and consequences. Normally, all of
the deviations for a given section or step are analyzed by the team before it proceeds
further. Exhibit 6A-9 shows how deviations are determined by combining guide
words and process parameters.
CAUTION
Whichever approach you use, you should consider reasonably anticipated external
events as well as internal failures. If you are in an area subject to earthquakes,
hurricanes, or floods, you should examine whether your process would survive these
natural events without releasing the substance. In your hazard review, you should
consider the potential impacts of lightning strikes and power failures. If your process
could be hh by vehicles, you should examine the consequences of that. If you have
anything near the process that could burn, ask yourself what would happen if the fire
affected the process. For example, if you have a propane tank and an ammonia tank at
your facility and they are close to each other, when you look at the ammonia tank you
should consider what a fire in the propane tank would do to the ammonia. These
considerations may not be part of standard checklists. If you use these checklists, you
may have to modify them to address these site-specific
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Chapter 6
6-13 Prevention Program (Program 2)
concerns. Never use someone else's checklist blindly. You must be sure that it
addresses all of your potential problims^
In addition, you may want to check with vendors, trade associations, or professional
organizations to determine if there are new standards for safety systems or designs, or
if there are detection or mitigation systems that may be applicable to your process that
you should consider when you evaluate your existing equipment. If your equipment is
designed and built to an earlier version of a standard, you should consider whether
upgrades are needed.
RESPONDING TO FINDINGS
The person or persons who conduct the review should develop a .list of findings and
recommendations. You must ensure that problems identified are addressed in a timely
manner. EPA 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, however, document your decision on each
recommendation. If you are implementing a recommendation, you should document
the schedule for implementation. If you are taking other steps to address the problem.
, or decide the problem does not merit action, you should document the basis for your
decision. .
UPDATES
You must update the review every five years or whenever a major change in a process
occurs. For most Program 2 processes, major changes are likely to occur infrequently.
If you install a new tank next to an existing one, you would want to consider whether
the closeness of the two creates any new hazards. Replacing a tank with an identical
tank would not be considered a change. Replacing a tank with a new type of tank
should trigger an update. Changing process composition or safe operating limits is
considered a major change. Even if changes prove to be minor, you should examine
the process carefully before starting. Combining old and new equipment can
sometimes create unexpected hazards. You will operate more safely if you take the
time to evaluate the hazards before proceeding.
WHERETO Go FOR MORE INFORMATION
Although the reports below target the chemical industry, you may find useful
information in them: ,
•* Guidelines for Hazard Evaluation Procedures, 2nd Ed. with Worked
examples, Center for Chemical Process Safety of the American Institute of
Chemical Engineers 1992.
*• Evaluating Process Safety in the Chemical Industry, Chemical Manufacturers
Association.
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Chapter 6
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6-14
+ Loss Prevention in the Process Industries, Volumes I, II, and III Frank P.
; Lees, Butterworths: London 1996.
4- Management of Process Hazards (R.P. 750), American Petroleum Institute.
+ Risk-Based Decision Making (Publication 16288), American Petroleum
Institute,
Among the information you will find in Guidelines for Hazard Evaluation Procedures
are descriptions of other PHA techniques, including Failure Modes and Effects
Analysis and Fault Tree Analysis. The regulations allow you to make use of these if
you wish to do so.
6.4 OPERATING PROCEDURES (§ 68.52)
Written operating procedures describe in detail what tasks a process operator must
perform, set safe process operating parameters that must be maintained, and set 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 industry-specific risk
management program guidances as the basis for your operating procedures, but be
sure to check that these standard procedures are appropriate for your activities. If
necessary, you must update your Program 2 operating procedures whenever there is a
major change and before you startup the changed process. Exhibit 6-6 briefly
summarizes what your operating procedures must address.
EXHIBIT 6-6
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
Other Procedures
•Consequences of deviating
•Steps to avoid, correct deviations
•Equipment inspections
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' Chapter 6
6-15 Prevention Program (Program 2)
Your operating procedures must be:
•."•*• Appropriate for your equipment and operations;
4 Complete;
4- Written in language that is easily understood by your operators; and
•*• Arranged and organized to be easy for operators to use.
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.
How Do I START?
If you already have written procedures, you may not have to do'anything more.
Review the procedures. You may want to watch operators performing the steps to be
sure that the procedures are being used and are appropriate. Talk with the operators to
identify any problems they have identified and any improvements they may have
made. When you are satisfied that they meet the criteria listed above, you are .
finished. You may want to check them against any recommended procedures
provided by equipment manufacturers, trade associations, or standard setting
organizations, but you are not required to do so. You are responsible for ensuring that
'the procedures explain how to operate your equipment and processes safely.
If you do not have written procedures, you may be able to review your standard
procedures with your operators and write them down. You also may want to check
with equipment manufacturers, trade associations, or standard setting organizations.
They may have recommended practices and procedures that you can adapt. Do not
accept anyone else's procedures without checking to be sure that they are adequate and
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 rules
for loading and unloading of hazardous materials, those rules may dictate some
procedures. Copies of these rules are sufficient for those operations if your operators
can understand and use them. -
WHAT Do THESE PROCEDURES MEAN?
. • The rule lists eight procedures. Not all of them may be applicable to you. The
following is a brief description to help you_decide whether you need to develop"
procedures for each item. If a particular element does not apply, do not spend any
time on it. We do not expect you to create a document that is meaningless to you.
You should spend your time on items that will be useful to you.
Initial Startup. This item applies primarily to facilities that process or use substances
and covers all the steps you need to take before you start a process for the
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Chapter 6
Prevention Program (Program 2) 6-16
first time. You should include all the steps needed to check out equipment as well as
the steps needed to start the process itself.
Normal Operations. These procedures should cover your basic operations. The
procedures would include all the steps operators take to check the process and ensure
•that equipment is functioning properly and substances are flowing or mixing
appropriately. These are your core procedures that you expect your operators to
follow on a daily basis to run your processes safely.
In a WWTP, it will be especially important to detail, very specifically, the procedures
and safeguards for connecting and disconnecting cylinders, tank trucks, or rail cars
containing regulated substances. These procedures should also detail the required
precautions, e.g., having an emergency respirator readily available. Also, assuring
that emergency equipment is functional and readily available should be part of the
instructions. For example, an inspection of the air tank on the self-contained
breathing apparatus prior to making or breaking connections should be considered.
Temporary Operations. These operations are short-term; they will usually occur
either when your regular process is down or when additional capacity is needed for a
limited period. The procedures should cover the steps you need to take to ensure that
these operations will function safely. The procedures will generally cover pre-startup
checks and determinations (e.g., have you determined what the maximum flow rate
will be). The actual operating procedures for running the temporary process must be
written before the operation is put into place.
Emergency Shutdowns and Operations. These procedures cover the steps you need
to take if you must shutdown your process quickly. For most Program 2 facilities,
these procedures will be brief because shutting a process down will be little different
in an emergency than in ordinary circumstances; you will simply shut off the flow or
stop any unloading or loading.
Normal Shutdown. These procedures should provide all the steps needed to stop a
process safely. The procedures should set out the time that should be taken and the
checks that must be made before proceeding to the next steps.
Startup following a normal or emergency shutdown or a major change. These
procedures may be similar to those for initial startup. Startup procedures following
normal shutdown may include fewer equipment checks because you may not need to
check equipment on a frequent basis. You should include all the steps your workers
should take to ensure that the process can operate safely. Startup, after an emergency
shutdown will generally require more checks to ensure that valves that were closed are
open and that they and other equipment are still functioning properly.
Consequences of Deviations. Your operating procedures should tell the workers
what will happen if something starts to go wrong. For example, if the pressure or
temperature begins to rise or fall unexpectedly or the flow rate from one feed suddenly
drops sharply, the operator must know (1) whether this poses a problem that must be
addressed, and (2) what steps to take to correct the problem or
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" x • , ' ' . • - Chapter 6
6-17 Prevention Program (Program 2)
otherwise respond to it. Your safety information will have defined the safe operating
limits for your substarices!rand processes; the hazard review will have defined the
possible consequences and the steps needed to prevent a deviation from causing
serious problems. You should include this information in each of the other procedures
(startup, normal operations, shutdowns), rather than as separate documents.
If your substance is one that has 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.
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). 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.
Your operators, your vendors, and your trade association can help you define the -
things that should trigger concern: When is a small leak at a seal normal; when is it a
cause of concern? How much vibration is normal? What does a smoothly running
motor sound like?
UPDATING PROCEDURES
You must update your procedures whenever you change your process in a way that
alters the steps needed to operate safely. If you add new equipment, you will need to
expand your procedures or develop a separate set to cover .the new items. Whenever
you change your safety information you should review your procedures to be sure that
they are still appropriate. Anytime you conduct a hazard review, check your operating
procedures as you implement changes to address hazards.
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.
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Chapter 6
Prevention Program (Program 2) ' 6-18
WHERETO Go FOR MORE INFORMATION
The Chlorine Institute (http://www.cl2.com) publishes information on safe use and
handling of chlorine. Its Water and Waste-water Operators Chlorine Handbook
(Pamphlet # 155) provides general training and procedures.
The Water Environment Federation (601 Wythe Street, Alexandria, VA 22134, (703)
684-2470) provides general procedures as part of its training programs on wastewater
treatment operation and maintenance.
Although the reports below target the chemical industry, you may find useful
information in them:
+ Guidelines for Process Safety Fundamentals.for General Plant Operations,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1995.
• , . • • \, , » j
+ Guidelines for Safe Process Operations and Maintenance, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1995 , .
•*• Guidelines for Writing Effective Operating and Maintenance Procedures,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1996.
6.5 TRAINING (§ 68.54)
Training programs often provide immediate benefits because trained workers have ,
fewer accidents, damage less equipment, and improve operational efficiency.
Training gives workers the information they need to understand how to operate safely
and why safe operations are necessary. A training program, including refresher
training, is the key to ensuring that the rest of your prevention program is effective.
You may already have some type of training program if you must conduct training to
comply with OSHA's Hazard Communication Standard (29 CFR 1910.1200).
WHAT Do I NEED TO Do?
You must train all new workers in your operating procedures developed under the
previous prevention program element; if any of 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 must 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.
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, , Chapter 6
6-19 Prevention Program (Program 2)
You need not provide initial training for workers already operating a process as of
June 21, 1999, if you in Writing that trie employees have the "required knowledge,
skills, and abilities to safely carry out the duties and responsibilities as provided in the
operating procedures" (§.68.54(a)). This certification should 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. For WWTPs, where the
number of staff handling regulated substances is generally small, one-on-one training
and on-the-job training may work best. You may have senior operators present the
training or use trainers provided t>y 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 the training,
not the details of now you achieve them. Find a system that works for you. Exhibit
6-7 lists things that you- may find useful in developing your training program.
You are also required to ensure that each worker trained has understood the training
and is competent to operate the process safely. You may decide what kind or kinds of
competency testing to use. Observation by a senior operator may be appropriate in
many cases. If you provided classroom training, you may want to use both testing and
demonstration or observation. You are required to report in the RMP on the type(s) of
competency testing you use. .
For WWTPs, trainig should cover the activities that could lead to releases of the toxic
gases and flammables that are used in WWTPs. These activities should be identified
in the hazard review and bear particular attention:
+ Connecting, and disconnecting, cylinders of Chlorine and Sulfur Dioxide.
Training should cover inspection of the fittings and tubing to assure that they
• , are in good condition and inspection (and discard if necessary) of tools used
for the job. Training should also include identification of vapor and liquid
connections on the cylinders and identification of the operating conditions
that will show that the connections are hooked up in reverse.
+ Material handling of cylinders. Training should cover inspection of material
handling equipment, including hoists, cylinder carriers and hooks, and
cylinder chocks. Also, inspection for and removal of combustibles or
flammables in storage areas should be a part of training.
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6-20
EXHIBIT 6-7
TRAINING CHART
•Who needs training?
Clearly identify the employees who need to be trained and the subjects to be
covered.
•What are the
objectives?
. Specify learning objectives, and write them in clear, measurable terms before
training begins. Remember that training must address the process operating
procedures.
•How will you meet the
training objectives?
Tailor the specific training modules or segments to the training objectives.
Enhance learning by including hands-on training like using simulators whenever
appropriate. Make the training environment as much like the working
environment as you can, consistent with safety. Allow your employees to practice
their skills and demonstrate what they know.
•Is your training
program working?
Evaluate your training program periodically to see if your employees have the
skills and know the routines required under your operating procedures. Make sure
that language or presentation are not barriers to learning. Decide how you will
measure your employees' competence.
•How will your program
work for new hires and
refresher training?
Make sure all workers — including maintenance and contract employees — receive
initial and refresher training. If you make changes to process chemicals,
equipment, or technology, make sure that involved workers understand the
changes and the effects on their jobs.
How DOES THIS TRAINING FIT WITH OTHER REQUIRED TRAINING?
You are required by OSHA to provide training under the Hazard Communication
Standard (29 CFR 1910.1200); this training covers the hazards of the chemicals and
steps to take to prevent exposures. DOT has required training for loading and
unloading of hazardous materials (49 CFR part 172, subpartH). Some of that training
will cover items in your operating procedures. You do not need to repeat that training
to meet EPA's requirements. You may want to integrate the training programs, but
you do not have to do so.
WHAT KIND OF DOCUMENTATION Do I NEED TO KEEP?
In the RMP, you are required to report on the date of the most recent review or
revision of your training program. You are also required to report on ,the type of
training required (e.g., classroom or on-the-job) and the type of competency testing
usecl. You should keep on site any current training materials or schedules used. The
rule does not require you to keep particular records of your training program. It is
enough for you to have on site information that supports what is reported in the RMP
and your implementation of the training program overall. You may want to keep an
attendance log for any formal training courses and refresher training to ensure that
everyone who needs to be trained is trained. Such logs will help you perform a
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' ' , • Chapter 6
6-21 • Prevention Program (Program 2)
compliance audit or demonstrate compliance with the rule although you are not
required to keep logs for this rule. "7 ~
WHERE To Go FOR MORE INFORMATION
The Water Environment Federation provides several training programs including the
following:
*• Basic Course for Wastewater Treatment Plant Operators, Instructor Set
Order No. E0100GB, Student Workbook Order No. E0110GB.
* Intermediate Course for Wastewater Treatment Plant Operators, Instructor
Set Order No. EQ295GB, Student Workbook Order No. E0296GB.
: •* Chlorination Skill Training Course, Order No. EQ312GB. Self Instruction
Course. . ,
In addition, the following may be useful:
• + Operation and Maintenance of Municipal Wastewater Treatment Plants
(MOP-11), Water Environment Federation.
••'•*• NFPA-820, Standard for Fire Protection in Wastewater Treatment and
Collection Facilities.
•* Guidelines for Process Safety Fundamentals for General Plant Operations,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1995.
> Guidelines for Technical Planning for On-Site Emergencies, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1995.
1 •* Federally Mandated Training and Information (Publication 12000),
American Petroleum Institute.
6.6 MAINTENANCE (§ 68.56)
Preventive maintenance, inspection, and testing of equipment is critical to safe
. operations. Waiting for equipment to fail often means .waiting for an accident that
, could harm people and the environment. Further, a thorough maintenance program
will save you money by cutting down-time caused by equipment failures. Your
hazard review and safety information "will have identified equipment that is critical to
safe operations. You should use that information you develop while putting together
these documents and reviews to build your maintenance program. Exhibit 6-8 briefly
summarizes the elements of a maintenance program that would satisfy EPA's rule.
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6-22
EXHIBIT 6-8
MAINTENANCE GUIDELINES
Written procedures
•You may use
procedures provided
by the vendor or trade
association, etc., as the
basis for your program.
If you choose to
develop your own, you
must write them down.
Training
•Train process maintenance
employees in process
hazards and how to avoid
or correct an unsafe
condition.
•Make sure this training
covers the procedures
applicable to safe job
performance.
Inspection & testing
•Inspect & test process
equipment.
•Use recognized and
generally accepted good
engineering practices.
•Follow a schedule that
matches the manufacturer's
recommendations or that
prior operating experience
indicates is necessary.
WHAT Do I NEED TO Do?
You must prepare and implement procedures for maintaining the mechanical integrity
of process equipment, and train your workers in the maintenance procedures. For
mo|t of the equipment in a WWTP, the manufacturer will have supplied maintenance
instructions. These can be used to fulfill the requirements for maintenance
procedures. Where such instructions are not available, you will need to develop them.
In addition to the major pieces of equipment, you will need to develop inspection
procedures that consider both repair or replacement requirements for the following
items:
4- Fittings
4- Tubing
4- Pressure relief devices
4- Gauges, pressure switches, and other instrumentation.
4- Rotameters
4- Pressure regulators, and pressure gauges
4- Leak detectors
4- Eductors, vacuum mixers, or other devices used to mix chlorine, sulfur
dioxide, and other regulated substances into waste water streams
4- Material handing equipment
4- Tools
4- All other equipment used to handle, transfer, or use the regulated substances.
Where there is the possibility of corrosion, these inspections are especially important.
The regulated substances used are normally not corrosive, when they are dry.
However, all of them can become highly corrosive if the equipment using them is
Attention tp this aspect can be vital.
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6-23 , Prevention Program (Program 2)
Where methane is recovered, compressed, and stored for use in the plant, steel
pipelines and storage vessels should be inspected regularly. If the plant operator is not
familiar with preventive inspection and testing, help should be sought. If the storage
tank is a pressure vessel, the helping person should be very familiar with the ASME
pressure vessel code and with API tank inspection requirements.
In larger plants/where there are storage tanks for chorine, sulfur dioxide or ammonia,
the tanks and associated piping should be inspected regularly. Suppliers are likely to
be able to provide recommendations for this inspection and preventive maintenance.
Propane distributors are likely to be able to supply the same information about
propane vessels and equipment, if these are included in your plant.
You should develop a schedule for inspecting and testing your equipment based on
manufacturers' recommendations or your own experience if that suggests more
frequent inspection or testing is warranted.
How Do I START? _
Your first step 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 unless your use varies from that
contemplated by the vendor or manufacturer (see below). Your trade association may
also be able to help you with industry-specific checklists. If there are existing industry
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.
You need to determine if procedures provided by vendors, manufacturers, trade
associations, or others are appropriate for your operation. If your safety information
indicates that you are operating in a standard way (e.g., using only parts designed for
chlorine service in your chlorination system), 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, you need to decide whether your use changes the
kinds of maintenance required.
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.
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Chapter 6
Prevention Program (Program 2) 6-24
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 under OSHA regulations. You do not need to repeat this training to comply
with this rule.
If you hire contractors to do your maintenance, you should ensure that they are trained
to carry out the procedures. Under trie rule, any maintenance contractor is required to
ensure that each contract maintenance worker is trained to perform the maintenance
procedures developed by the facility. You can help this process by providing training
or by developing agreements with the contractor that give you the assurance that only
trained workers will be sent to your site. For any outside worker, you must ensure that
they are informed of the hazards of your particular process. If you have standard
equipment and hire contractors that specialize in servicing your types of processes,
you can ensure their knowledge through agreements with the contractor.
INSPECTION AND TESTING
„' i', • -,i , • '" ,' •?'",.„ . , • , ! t
You must establish a schedule for inspecting and testing equipment associated with
covered processes. The frequency of inspections and tests must be consistent with
manufacturer's recommendations, industry standards or codes, good engineering
practices, and your prior operating experience. In particular, you should use your own
experience as a basis for examining any schedules recommended by others. Many
things may affect whether a schedule is appropriate. The manufacturer may assume a
constant rate of use (e.g., the amount of substance pumped per hour). If your use
varies considerably, the variations may affect the wear on the equipment. Extreme
weather conditions may also impact wear on equipment.
Talk with your operators and maintenance personnel as you prepare or adopt these
procedures and schedules. If their experience indicates that equipment fails more
frequently than the manufacturer expects, you should adjust the inspection schedule to
reflect that experience. Your hazard review will have identified these potential
problem areas as well and should be used as you develop schedules. For example, if
you determine that corrosion is one of the hazards of the process, your schedule must
address inspections for corrosion and replacement before failure. Your trade
association may also be able to provide advice on these issues.
WHAT KIND OF DOCUMENTATION MUST I KEEP?
In the RMP, you are required to report on the date of the most recent review or •
revision of your maintenance procedures and the date of the most recent equipment
inspection or test and equipment inspected or tested. You must keep on site your
written procedures and schedules as well as any agreements you have with contractors.
The rule does not require that you keep particular records of your maintenance
program. It is enough for you to have on site information that supports what is
reported in the RMP and your implementation of the maintenance program overall.
For example, you may want to keep maintenance logs to keep track of when
inspections and tests were done.
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• Chapter 6
6-25 .Prevention Program (Program 2)
WHERE To Go FOR MORE INFORMATION
Codes and Standards: The following groups develop codes and standards that may
help you determine the appropriate frequency and methods to use for testing and
inspection: National Board Inspection Code, the American Society for Testing and
Material, American Petroleum Institute, National Fire Protection Association,
American National Standards Institute, American Society of Mechanical Engineers.
Guidance and Reports. The documents listed under Safety Information may be
useful for maintenance procedures as well. In addition, the Chlorine Institute
publishes pamphlets on chlorine system maintenance, including the following:
* Maintenance Instructions for Chlorine Institute Standard Safety Valves, Type
1-1/2 JQ (# 39). '
* Maintenance Instructions for Chlorine Institute Standard Angle Valve (#40).
+ • Maintenance Instructions for Chlorine Institute Standard Safety Valve, Type
4/2 (#41). '
•* Maintenance Instructions for Chlorine Institute Standard Excess Flow Valves
, (#42). , :.-'•.-
Although the reports below target the chemical industry, you may find useful
information in them:
+ Guidelines for Equipment Reliability Data with Data Tables, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1989.
4- Guidelines for Process Safety Documentation, Center for Chemical Process
Safety of the American Institute of Chemical Engineers 1995.
+ Pressure Vessel Inspection Code: Maintenance Inspection, Rating, Repair,
and Alteration (API 510), American Petroleum Institute.
+ Tank Inspection, Repair, Alteration, and Reconstruction (Std 653), American
Petroleum Institute.
Q&A
MAINTENANCE
Q. I have a propane tank for fuel use. I lease the tank from the propane supplier.. The'supplier does
all the maintenance. My staff never work on the equipment. How I do meet this requirement?
A. As part of your contract with the supplier; you should gain an agreement, in writing, that the
supplier will provide maintenance and trained maintenance workers that meet the requirements of 40
CFR 68.56.
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6-26
6.7 COMPLIANCE AUDITS (§68.58)
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
for the prevention program requirements for each covered process. At least one
person on your audit team must be knowledgeable about the covered process. You
must develop a report of your findings, determine and document an appropriate
response to each finding, and document that you have corrected any deficiency.
You must review compliance with each of the required elements of the prevention
program. Because Program 2 processes are generally simple, the audit should riot take
a long time. You may want to develop a simple checklist; Exhibit 6-9 provides a
sample format.
Once you have the checklist, you, your chief operator, or some other person who is
knowledgeable about your process, singly or as a team, should walk through the
facility and check on relevant items, writing down comments and recommendations.
For example, you may want to talk with employees to determine if they have been
trained and are familiar with the procedures.
You must respond to each of the findings and document what actions, if any, you take
to address problems. You should take steps to correct any deficiencies you find.
You may choose to have the audit conducted by a qualified outside party. For
example, you may have someone from another part of your company do the audit or
hire an expert in your process. If you do either of these, you should have an employee
who works with or is responsible for the process accompany the auditor, both to
understand the findings and answer questions.
Again, the purpose of the compliance audit is to ensure that you are continuing to
implement the risk management program as required. Remember, the risk
management program is an on-going process; it is not a set of documents that you
-develop and put on a shelf in case the government inspects your site. To be in .
compliance with (and gain the benefits of) the rule, procedures must be followed on a
daily basis; documents must be kept up to date. The audit will check compliance witii
each prevention program element and indicate areas .that need to be improved. You
may choose to expand the scope to cover your compliance with other parts of the rule
and the overall safety of your operation, but you are not required to do so.
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Chapter 6
Prevention Program (Program 2)
EXHIBIT 6-9
SAMPLE AUDIT CHECKLIST
FOR SAFETY INFORMATION AND HAZARD REVIEW
-\ - -, JElement "* -^ , %
Safety Information
MSDSs up-to-date?
Maximum intended inventory "determined?
Determined
Safe upper and lower temperature?
Safe upper and lower pressures?
Safe process flow rates?
Compositions? '.
Equipment specifications
Tanks?
Piping?
Pressure relief valves?
Emergency shutoff valves?
Gauges?
Pumps? ">•'.'
Compressors?
Hoses?
Hazard Review
Has equipment been inspected to determine if
it is designed, manufactured, installed, and
operated according to industry standards and
codes?
Are the results of the inspections documented?
Have inspections been conducted after every
major change?
"^Yes/Noflftfc -x
• -
Action/Completion Data
'.,''•_'
•
•
WHAT KIND OF DOCUMENTATION MUST I KEEP?
' , You must keep a written record of audit findings and your response to those findings
and documents that deficiencies have been corrected. You must keep the two most
recent audit reports, but you need not keep a report that is more than five, years old.
You may also want to keep a record of who conducted the audit, but you are not
required to do this.
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6-28
WHERETO Go FOR MORE INFORMATION
Guidelines for Auditing Process Safety Management Systems, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1993.
Q&A
AUDITS
Q. Does the compliance audit requirement cover all of the Part 68 requirements or just the
prevention program requirements?
A. The compliance audit requirement applies only to the prevention programs under Subpart C.
If you have a Program 2 process, you must certify that you have evaluated compliance with the
Program 2 prevention program provisions at least every three years to verify that the procedures
and practices developed under the rule are adequate and are being followed. You may want to
expand your audit to check other part 68 elements, but you are not required to do so.
6.8 INCIDENT INVESTIGATION (§ 68.60)
Incidents can provide valuable information about site hazards and the steps you need
to take to prevent accidental releases. Often, the immediate cause of an incident is the
result of a series of other problems that need to be addressed to prevent recurrences.
For example, an operator's mistake may be the result of poor training. Equipment
failure may result from improper maintenance or misuse. Without a thorough
investigation, you may miss the opportunity to identify and solve these problems.
WHAT Do I NEED TO Do?
You must investigate each incident which resulted in, or could have resulted in, a
catastrophic release of a regulated substance. A catastrophic .release is one that
presents an imminent and substantial endangerment to public health and the
environment. Exhibit 6-10 briefly summarizes the steps you must take for
investigating incidents. You should also consider investigating minor accidents or
near misses because they may hehryou.identify problems that could lead to more
serious accidents; however, you are not required to do so under part 68.
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Chapter 6
Prevention Program (Program 2)
EXHIBIT 6-10
INCIDENT INVESTIGATION REQUIREMENTS
•Initiate an investigation promptly.
•Summarize the investigation in a report.
•Address the report's findings and
recommendations.
•Review the report with your staff and
contractors.
V
•Retain the report.
Begin investigating no later than 48 hours
following the incident.
Among other things, the report must identify the
factors, contributing to the incident. Remember
that identifying the root cause may be more
important than identifying the initiating event. The
report must also include any recommendations for
corrective actions. Remember that the purpose of
the report is to help management take corrective
action. '
Establish a system to address promptly and resolve
the incident report findings and recommendations
and document resolutions and corrective actions.
You must share the report - its findings and
recommendations - with affected workers whose
job tasks are relevant to the incident.
Keep incident investigation summaries for five
years.
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.
The purpose of the investigation is to find out what went wrong and why, so you can
prevent it from happening again. Do not stop at the obvious failure or "initiating
event" (e^g., the hose was clogged, the operator forgot to check the connection); try to
determine why the failure occurred. In many cases, the underlying cause will be what
'matters (e.g., the operator did not check the connection because the operating
procedures and training did not include this step). If the accident occurred because of
operator error, you should determine if the operator made the mistake because he or
she had been trained inadequately or trained in the wrong procedures or because
design flaws made mistakes likely. If you write off the accident as operator error
alone; you miss the chance to take the steps needed to prevent such errors the next
time. Similarly, if equipment fails, you should try to decide whether it had been used
or maintained improperly. ,
October 27,1998
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Chapter 6
Prevention Program (Program 2) 6-30
Remember, your goals are to prevent accidents, not to blame someone, and correct any
problems in your prevention program. In this way, you can prevent recurrences.
In some cases, an investigation will not take long. In other cases, if you have a
complex facility, equipment has been severely damaged, or the workers seriously hurt,
an investigation may take several days. You should talk with the operators who were
in the area at the time and check records on maintenance (another reason for keeping
logs). If equipment has failed in an unusual way, you may need to talk to the
manufacturer and your trade association to determine if similar equipment has
suffered similar failures.
You must develop a summary of the accident and its causes and make
recommendations to prevent recurrences. You must address each recommendation
and document the resolution and any actions taken. Finally, you must review the
findings with operators affected by the findings.
WHAT KIND OF DOCUMENTATION MUST I KEEP?
You must maintain trie summary of the accident investigation and recommendations
and document resolutions and corrective actions. A sample format is shown in
Exhibit 6-11 that combines all of these in a single form. Note that the form also
includes accident data that you will need for the five-year accident history. These data
are riot necessarily part of the incident investigation report, but including them will
create a record you can use later to create the accident history.
1 "":.,i . ir i ! ' ' . , • • ' \ .
WHERE To Gq fOR MORE INFORMATION
Although the reports below target the chemical industry, you may find useful
information in them:
4- Guidelines for Investigating Chemical Process Incidents, Center for Chemical
Process Safety of the American Institute of Chemical Engineers 1992.
4- Guide for Fire and Explosion Investigations (NFPA 921), National Fire
Protection Association.
October 27,1998
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6-31
Chapter 6
Prevention Program (Program 2)
EXHIBIT 6-11
SAMPLE INCIDENT INVESTIGATION FORMAT
Ammonia Tank Release
Date: May 15, 1998; 3 pm
Duration: 2 hours
Description:
Findings
Hose split because the pressure .'
rating was too low; design
pressure requirement was
overlooked
Operator failed to stay at the tank
during loading
Tank required manual shutoff
Substance: Ammonia
Weather: 82 F, 8 mph winds
Quantity: 2 tons
Date Investigation Started:
May 16, 1998
Unloading hose split open and spilled substance; operator was in
the main building and failed to notice spill for several minutes
Recommendations
Replace hose with correctly
rated pressure hose;
compare all pressure ratings to %
actual, including deadhead"
pump pressure, and make any
needed upgrades .
Conduct refresher training to
stress necessity of remaining at
the tank during loading
Determine if automatic shutoff
valve is feasible
Actions
Replaced hose as recommended;
checked all pressure ratings
Refresher training provided;
safety meetings added and held
on a monthly basis to review
safety issues
Automatic shutoff valve
installed
6.9 CONCLUSION
Many of you will need to do little that's new to comply with the Program 2 prevention
program, because complying with other Federal rules, state requirements, and
industryrspecific codes and standards results in compliance with many Program 2
elements. And if you've voluntarily implemented OSHA's PSM standard for your
Program 2 process, you'll meet the lesser Program 2 prevention program requirements.
No matter what choices you make in complying with the Program 2 prevention
program, keep these things in mind:
+ 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. ' .• ' "
October 27, 1998
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,,, , ..,. - •
Chapter 6
Prevention Program (Program 2) • 6-32
Check your operations on a continuing basis, and ask if you can improve them
to make them safer as well as more efficient.
October 27,1998
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Chapter 6
6-33 Prevention Program (Program 2)
APPENDIX 6A
HAZARD REVIEW CHECKLISTS, WHAT IF QUESTIONS,
AND HAZOP PROCEDURES
October 27, 1998
-------
Chapter 6
Prevention Program (Program 2)
6-34
EXHIBIT 6A-1
GENERAL CONDITIONS, OPERATION AND MAINTENANCE
(FORANYWWTP)
General Conditions, Operation and Maintenance
Are work areas clean?
Are adequate warning signs posted?
Is ambient temperature normally comfortable?
Is lighting sufficient for all.operations?
Are the right tools provided and used?
Is personal protective equipment (PPE) provided and adequate?
Are containers and tanks protected from vehicular traffic?
Are all flammable and combustible materials kept away from
containers, tanks, and feed lines?
Are containers, tanks, and feed line areas kept free of any objects
that can fall on them (e.g., ladders, shelves?)
Are leak detectors with local and remote audible and visible alarms
present, operable, and tested?
Are windsocks provided in a visible location?
Are emergency repair kits available for each type of supply present?
Are appropriate emergency supplies and equipment present,
including PPE and self-contained breathing apparatus (SCBA)?
Are emergency numbers posted in an appropriate spot?
Are equipment, containers, and railcars inspected daily?
Are written operating procedures available to the operators?
Are preventative maintenance, inspections, and testing performed
as recommended by the manufacturer and industry groups and
documented?
Yes/No/NA
,
-
Comments
•
October 27,1998
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6-35 '
• • Chapter 6
Prevention Program (Program 2)
EXHIBIT 6A-2
HUkANFACfo&S
(GENERAL)
v ., -- ~s- - ' ..''Human Factors ^ * ^L_w- 1-* ' „ '**
Have operators been trained on the written operating procedures
and the use of PPE in normal operations (or for operators on .the job
before June 21, 1999, have you certified that they have the required
knowledge, skills, and ability to do their duties safely)?
Do the operators follow the written operating procedures?
Do the operators understand the applicable operating limits on
temperature, pressure, flow, and level?
Do the operators understand the consequences of deviations above
or below applicable operating limits? - - ' ' .
Have operators been trained on the correct response to alarms and
conditions that exceed the operating limits of the system?
Are operators provided with enough information to diagnose
alarms? •
Are controls accessible and easily, understood?
Are labels adequate on instruments and controls?
Are all major components* valves, and piping clearly and
unambiguously labeled?
Are all components mentioned in the procedures adequately
labeled? . ,
Are safe work practices, such as lockout/tagout, hot work, and line
opening procedures followed?
Are personnel trained in the emergency response plan and the use
of emergency kits, PPE, and SCBAs?
Are contractors used at the facility?
Are. contractors trained to work as safely as your own employees?
Do you have programs to monitor that contractors are working
safely? .......
JY&/N6/NA-<
-
_ - '
," Comments^
- s
. - -
October 27,1998
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Chapter 6
Prevention Program (Program 2)
6-36
EXHIBIT 6A-3
CHECKLISTS FOR CHLORINE AND SULFUR DIOXIDE
. ., , , ... ,,; 1 • , .
Chlorine and Sulfur Dioxide - Siting
Are storage, use, and transfer areas not located uphill from adjacent
operations?
Are storage, use, and transfer areas located away from- sewer
openings and other underground structures?
Do storage, use, and transfer areas have easy access for emergency
response?
Are storage, use, and transfer areas free of combustible or
incompatible materials and isolated from hydrocarbons in
accordance with NFPA Standard No. 49, Hazardous Chemicals
Data?
Are storage, use and transfer areas downwind of or separated from
most operations and support areas and ventilation intakes based on
prevailing wind direction?
Are storage, use, and transfer areas isolated from sources of
corrosion, fire, and explosion and protected from vehicle impact?
Are storage, use, and transfer areas located away from residences
and facility boundaries?
If cylinders are stored outside, are they protected from impact by ,
vehicular traffic?
Chlorine and Sulfur Dioxide - Hazard Recognition 'M
Are material safety data sheets (MSDSs) readily available to those
operating and maintaining the system?
Do employees understand that there are certain materials with
which C12 (SO2) must not be mixed?
Do employees understand the toxicity, mobility, and ability of C12
(SO^ to sustain combustion?
Do employees understand the consequences of confining liquid C12
(SOj) without a thermal expansion device?
Do employees understand the effect of moisture on the corrosive
potential of ClzCSOa)?
Yes/No/NA;
s
-
Comments
/
"• s
•
October 27.1998
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6-37
Chapter 6
Prevention Program (Program 2)
* * <* ? * /f / \' *^s ' * ^ &
*';-•" *•*- .-?- ."- •*>••'/ '„,''.* r s-'J-v5
' '50 > -y"~„•*?• }f- „,
/; v
-
: i* ^
--•
•
Comments -
October 27, 1998
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Chapter 6
Prevention Program (Program 2)
6-38
1 . •• • ' ••..:.'• , .: V •":•:-.
Is the building constructed of non-combustible materials?
If flammable materials are stored or used in the same building, are
they separated from the C12 (SO,) areas by a fire wall?
Is continuous leak detection, using area C12 (SOj) monitors,
provided in storage and process areas?
Are two or more exits provided from each C12 (SO^ storage and
process area and building?
Is the ventilation system appropriately designed for indoor
operations (and scrubbing, if required) by local codes in effect at
the time of construction or major modification?
Are the exhaust ducts near floor level and the intake elevated?
Can the exhaust fan be remotely started and stopped?
If C12 and SO2 are stored in the same building, are storage rooms
separated as required?
Chlorine and Sulfur Dioxide - Piping and Appurtenances
Do piping specifications meet C12 (SOj) requirements for the
service?
Do you require suppliers to provide documentation that all piping
and appurtenances are certified "for chlorine service" or "for sulfur
dioxide service" by the manufacturer?
Are piping systems properly supported, adequately sloped to allow
drainage, and with a minimum of low spots?
Is all piping protected from all risks of excessive fire or heat?
Is an appropriate liquid expansion device or vapor pressure relief
provided on every line segment or device that can be isolated?
Chlorine and Sulfur Dioxide - Design Stage Review of
New/Modified Process
[s the system designed to operate at lowest practical temperatures
and pressures?
[f C12 (862) demand is low enough, is the system designed to feed
gaseous chlorine (SO^ from the storage container, rather than
iquid?
Save the lengths of liquid C12 (SOJ lines been minimized (reduces
quantity of chlorine in lines available for release)?
-Yes/No/NA
t ~?
••
-
Comments
,
-,' •
October 27.1998
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6-39
Chapter 6
Prevention Program (Program 2)
„* \ * , ^ / (> •• & -/••*"* N ^ '* „ "£•* ~
A/ ,,,""- ' •- --'" >»"<. '*"'•* ;• i «• •» «
Are low-pressure alarms and automatic shutoff valves provided on
C12 (SO2) feed lines?
Are vent-controlled spill collection sumps provided and floors
sloped toward sumps for stationary tanks and railcars? • •
Are vaporizers provided with automatic gas line shutoff valve,
downstream pressure reducing valve, gas flow control valve,
temperature control system and interlocks to shut down gas flow on
low vaporizer temperature, and appropriate alarms in a
continuously manned control room?
Do vaporizers have a limited heat input capacity?
Are curbs, sumps, and diking .that minimize me surface of potential
spills provided for stationary tanks and railcars?
XesyNo/NA
-> > "
Comments
- • •
-
October 27, 1998
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Chapter 6
Prevention Program (Program 2)
6-40
EXHIBIT 6A-4
CHECKLIST FOR ANHYDROUS AMMONIA SYSTEMS
,„,'„, * *',.
Anhydrous Ammonia -Basic Rules
Does the storage tank have a permanently attached nameplate?
Are containers) at least 50 feet from wells or other sources of
potable water supply?
Are container(s) painted white or other light reflecting colors and
maintained in good condition?
Is the area free of readily ignitable materials?
Are all main operating valves on tanks identified to show liquid or
vapor service?
Anhydrous Ammonia - Appurtenances ; **
Are all appurtenances designed for maximum working pressure and
suitable for ammonia service?
Do all connections to containers have shut-off valves as close to
container as practicable (except safety relief devices and gauging
devices)?
Are the excess flow and/or back pressure check, valves located
inside of the container or at a point outside as close as practicable to
where line enters container?
Are excess flow valves plainly and permanently marked with name
of manufacturer, catalog number, and rated capacity?
Anhydrous Ammonia - Piping
Are piping and tubing suitable for ammonia service?
Are provisions made for expansion, contraction, jarring, vibration
and settling?
Is all exposed piping protected from physical damage from vehicles
and other undue strain (2,000 Ib. pull)?
,L,Ajo&ydroro Ammonia -Hoses 1 ; •-
Does the hose conform to TFI-RMA specifications for anhydrous
ammonia?
Is it 350 psig working, 1750 psig - burst?
Yes/No/NA
-
•'
^.Vf- • ^.i" • . *
Comments
-
sJ
•- ^ '11 •' '^
October 27,1998
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6-41
Chapter 6
Prevention Program (Program 2)
, r , '' --.* -' > ---^^^1^1 i.
*••*-" » ,1 - ~ V * ,i
Is it marked every 5 feet with "Anhydrous Ammonia, xxx psig
(maximum working .pressure), manufacturer's name or trademark,
year of manufacture?
^•i~- "Anhydrpjp^An^^ „. „'"
Are safety relief valves installed?
Are they vented upward and unobstructed to the atmosphere?
Do they have a Rain/Dust Cap?
Are shut-off valves not installed between safety relief valve and
container? •-- - >
Are safety relief valves marked with "NH3" or "AA", psig valve is
set to start-to-discharge, CFM flow at full open, manufacturer's
name, and catalog number?
Is flow capacity restricted on upstream or downstream side?
Are hydrostatic relief valve installed between each pair of valves in
liquid piping or hose?
"^ \ s ' ^~ 0^^ihydro«s4nifooniay-^^E'e^f \ """"-
Are 'there two suitable full face masks with ammonia canisters as
approved by the Bureau of Mines? Are self-contained breathing air
apparatus required in concentrated atmospheres?
[s an easily accessible shower or a 50 gallon drum of water
available?
-' "* " AnhydroWA^paonia^Trauisf^r^ ^ / _
Are pump(s) designed for. ammonia service and at least 250 psig
working pressure?
Does P.D. pump have relief valve installed?
•Is a 0-400 psi pressure gauge installed on pump discharge?
Are loading/unloading lines fitted with back flow check or excess
flow valves? ;
Are caution sign(s) posted when rail car(s) are loading/unloading?
Are containers equipped with an approved liquid level gauging
device (except those filed by weight)?
Are containers fitted with a fixed tube liquid level gauge at 85% of
water capacity?
Yes/No/NA
*y
' /> -"* f **
...
^ ~ * -^ *"-.
"Comments^
•^ <-,,- ;y ',
" ?
,*' *, * ~ •<3t}
-2f <. ^"" ! '
/„; *• *^ "
*
•
October 27, 1998
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Chapter 6
Prevention Program (Program 2)
6-42
- "
Anhydrous Ammonia - Stationary Tank
Are non-refrigerated containers) designed for a minimum 250 (265
psig in CA) psig pressure?
Are all liquid and vapor connections to container(s) except safety
relief valves, liquid gauging and pressure gauge connections fitted
with orifices not larger than No. 54 drill size equipped with excess-
flow valves?
Are storage containers fitted with a 0-400 psi ammonia gauge?
Are they equipped with vapor return valves(s)?
Are containers marked on at least two sides with "Anhydrous
Ammonia" or "Caution - Ammonia" in contrasting colors and
minimum 4 inch high letters?
Is a sign displayed stating name, address and phone number of
nearest representative, agent or owner?
Are containers installed on substantial concrete, masonry or
structural steel supports?
Are ammonia systems protected from possible damage by moving
vehicles?
Yes/No/NA
••-•
.
Comments
October 27,1998
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6-43.
Chapter 6
Prevention Program (Program 2)
EXHIBIT 6A-5
CHECKLIST FOR AQUEOUS AMMONIA SYSTEMS
*>'. -
I.
2.
3.'-
- >
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
"- - ' * - - Aqueous Ammonia "*^ * ~ <* ""** *' -
Are storage tank(s) painted white or other light reflecting
colors and maintained in good order?
Is storage area free of readily ignitable materials?
Are storage tank(s) kept away from wells or other
sources of potable jyater supply?
Are storage tank(s) located with ample working space all
around?
Are storage tank(s) properly vented and away from areas
where operators are likely to be?
Does receiving system include a vapor return?
Is storage capacity adequate to receive full volume of
delivery vehicle? ~:
Are storage tank(s) secured against overturn by wind,
earthquake and/or floatation?
Are tank bottom(s) protected from external corrosion?
Is aqua ammonia system protected from possible damage
from moving vehicles?
Are storage tank(s) labeled as to content?
Are all appurtenances suitable for aqua ammonia
service?
Are all storage tank(s) fitted with liquid level gauges?
Are liquid level gauge(s) adequately protected from
physical damage? ,
If tubing is used,, is it fitted with a fail closed valve?
Are all storage tank(s) fitted with overfill fittings or high
level alarms?
Are tank(s) fitted with pressure/vacuum valves?
Is an ammonia gas scrubber system used?
Are piping and hose materials suitable for aqua ammonia
service?
Yes7No/NA^
•-
' -
Comments ""
•
1
October 27,1998
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Chapter 6
Prevention Program (Program 2)
6-44
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
Aqueous Ammonia
Is piping free of strain and provision made for expansion,
contraction, jarring, vibration and settling?
Is all exposed piping protected from physical damage
from moving vehicles and other undue strain?
Are hoses securely clamped to hose barbs?
Are hoses inspected and renewed periodically to avoid
breakage?
Are pump(s) designed for aqua ammonia service?
Are pump(s) fitted.with splash guard around seals?
Are pump(s) fitted with coupling guard(s)?
Do pump(s) have local start/stop stations?
Are two (2) suitable full face masks with ammonia
canisters as approved by the Bureau of Mines available?
Self-contained breathing air apparatus required in
concentrated atmospheres.
Is an easily accessible quick acting shower with bubble
fountain or 250-gallon drum of clean water available?
Is an extra pair of chemical splash proof goggles and/or
full face shields available?
Is an extra set of ammonia resistant gloves, boots, coat
and apron available?
Are fire extinguishers and a first aid kit available?
Are handlers/operators wearing their goggles and gloves
when working with aqua ammonia?
Are safety and first aid information posted?
Are emergency phone numbers and individuals to
contact posted?
;Yes/Nb/NA
Comments
October 27.1998
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6-45
Chapter 6
Prevention Program (Program 2)
EXHIBIT 6A-6
PROPANE ST(!»RAGE
HAZARD REVIEW CHECKLIST1'2
Answer the questions below by indicating "Yes", "No", or "N/A" (for not applicable). "No"
responses require further comment and a projected completion date for correcting the deficiency.
Comments can be recorded on a separate sheet that you reference in the comments section of this
table. •
' L '-, ^*r"i -#".*'* -l^ •/'— —^ > t;'. "'' - •__,•" ,.
<• ~ x -£ - "., " *"' " ' „ .4 »-*£, " *
_^"f"-.lff " *"'_> /« ** Propaite - Siting ^ ., -w- **f l '
1 . Does the arrangement of your fixed storage tanks conform with the
minimum distances allowed in Table 3-2.2.2 of NFPA 58, 1 998
Edition?
2. Are your fixed storage tanks separated from any oxygen or
hydrogen storage by the minimum distances given in Table 3-2.2/7(f)
of NFPA 58, 1998 Edition?
3. Are your transfer points separated from the exposure points by the
minimum distances given in Table 3-2.3.3 of NFPA 58, 1998
Edition?
^ Propariif-JKjjiog,!^^
1 . Is your storage facility designed according to ASME code for
pressure vessels?
Fixed Storage Tanks ASME?
Vaporizers ASME?
Tfes/Nfo/N^
** ••x '* * '*""' *" * •"
i *• - * »
--
* ,~ it 74 , •*"
+J ""
Comments /
,- * » ~
4 ^
~ *"\
Completing the Propane Storage Hazard Review Checklist does not' guarantee that your facility is in
complete compliance with NFPA 58, 1995 Edition.
e Propane Storage Hazard Review Checklist is based on NFPA 58, 1995 Edition. There may be
differences due to retroactivity between this version and the version adopted by your local authority at the time your
facility was constructed. Changes in NFPA 58 have been made to reduce the possibility of a propane release. You
should carefully review these changes and institute appropriate measures to ensure the safety of your facility. The
differences between the version of NFPA 58 that you used as the basis for constructing your facility and the current
version must be reconciled to the satisfaction of your implementing agency. • .
October,27, 1998
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Chapter 6
Prevention Program (Program 2)
6-46
I1
'
2. Is the pressure rating of your storage tanks appropriate for the
product in service?
Storage Tanks?
Vaporizers?
3. Is the stored product properly identified?
4. On installation with multiple tanks, are the elevations of your
storage tanks arranged to prevent unintentional overfilling of the
lowest container?
5. On installations with stairways or ladders, are they well anchored,
supported and of slip-proof construction?
6, On installations with stairways or ladders, are railings provided
and in good condition?
7. On installations with stairways or ladders, are catwalks provided so
personnel need not walk on any portion of the container?
8. Is your piping designed in accordance with NFPA 58, 1998
Section 3-2.10?
Are your pump and compressor discharge and liquid transfer lines
suitable for a working pressure of 350 psi?
Is your vapor piping suitable for a working pressure of 250 psi?
On installations with vaporizers, are your vaporizers designed
according to 2-5.4.2 or 2-5.4.3 or 2-5.4.4 and 2-5.4.5 or 2-5.4.6 or 2-
5.4.7 of NFPA 58, 1998 Edition?
9. Is the relief capacity of your pressure relief devices designed as
specified in 2-3.2 and 3-2.5 of NFPA 58, 1995 Edition?
1 0. Is the capacity of your pressure relief devices:
For fixed storage tanks, designed according to Sections 2-3.2 and 3-
2.5 or 3-2.6 of NFPA 58, 1998 Edition? •
On installation with vaporizers, are your vaporizers designed
according to 2-5.4.5 or 2-5.4.6 or 2-5.4.7 of NFPA 58, 1998 Edition?
11. Do you have appropriate level gauges, temperature indicators and
pressure gauges installed on your fixed ASME storage tanks as
specified in 2-3.3.2(b), 2-3.3.3, 2.3.4, 2.3.5 of NFPA 58, 1998
Edition?
Yes/No/NA
-
Comments
October 27,1998
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6-47
Chapter 6
Prevention Program (Program 2)
:,,-*.. - ". x;i f ;^v:.;;# ---,r;
12. Do you have the appropriate hydrostatic relief valves installed
between every section of liquid piping which can be blocked by
manual or automatic valves according to 2-4.7 and 3-2.1 1 of NFPA
58, 1998 Edition?
13. Do you have the appropriate corrosion protection required by 3-
2.14 of NFPA 58, 1998 Edition?
14. On installations with pumps, are they installed according to 3-
2.15.1 of NFPA 58, 1998 Edition?
On installations with automatic bypass valves, are they installed on
the discharge of your pump according to 3.2. 15(b) 1 and 2-5.2 of
NFPA 58, 1998 Edition?
15. On installations with compressors, are they installed according to
2-5.3 and 3-2.15.2 of NFPA 58, 1998 Edition?
On installations with compressors, are there either an integral means
of preventing liquid from entering the compressor or a liquid suction
protection trap according, to 3-2.15.2(b) of NFPA 58, 1998 Edition?
1 6. Do your compressor and pump motors conform with 2-5 . 1 .4 of
NFPA 58, 1998 Edition?
17. On installations with liquid strainers, are they installed on the
suction of your pump or meter according to 3-2. 15.2 and 2-5.5 of
NFPA 58, 1998 Edition, and capable of being cleaned?
18. On installations with flexible connections on pumps,
compressors, or loading and unloading bulkheads, are they installed as
specified by 2-4.6- of NFPA 58, 1998 Edition? .
19. Do you have either excess flow valves, backflow check valves, or
internal valves as specified by 2-3.3.3 and 3-3.3.7 of NFPA 58, 1998
Edition?
20. Do you have container appurtenance protection as specified in 2-
3.7 of NFPA 58, 1998 Edition?
21. Do you have manual valves and emergency shutoff valves as
required by 2-4.5.4, 3-2.8.10, 3-3.3.7 and 3-3.3.8 of NFPA 58, 1998
Edition?
22. On installations with vaporizing equipment, is it installed
according to 2-5.4 and 3-6 of NFPA 58, 1998 Edition? '
Have the liquid traps, temperature controls, and interlocks been tested
per the manufacturer's guidelines?
"Yes/No/NA
H
. -
- Comments <•'
-
October 27, 1998
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Chapter 6
Prevention Program (Program 2)
6-48
23. On installations with regulators, are they installed according to 2-
5.7 and 3-2.7 of NFPA 58, 1998 Edition?
24. Do you have a breakaway stanchion as required by 3-9.4.2 of
NFPA 58, 1998 Edition?
25. On installations with swivel-type piping, are they installed as
required by 3-2.10.1 l(a) of NFPA 58, 1998 Edition?
26. Are all above ground lines securely fastened to structural
members of adequate strength and supported at proper intervals?
27. Are pressure gauges located so that they will not be exposed to
physical damage?
28. Are there sufficient lines for all purposes, without improper dual
use or make-shift connections being used for some operations?
29. Are hoses the correct type for each use?
30. Are hose couplings of the correct type and properly attached
(fully seated on the hose)?
3 1 . Is adequate transfer hose storage provided?
32. Are the written transfer, loading and unloading instructions
available?
Propane - Human Factors [ . "
1. Have your operators been trained on the written operating
instructions for this propane distribution facility?
2. For operators on the job on or before June 20, 1996, do they have
the required knowledge, skills and ability to perform their duties
safely?
3. Do operators whose job duties require the use of the above listed
equipment understand the operating limits of the system in regards to:
Capacity?
Pressure?
Temperature?
Adverse Weather or Natural Conditions?
4. Have your operators been trained in the correct response to
conditions which exceed the operating limits of the system?
Yes/No/NA,
j
Yes/No/NA
Comments,,
Comments -
October 27.1998
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6-49
Chapter 6
Prevention Program (Program 2)
* **>v ,-tf ^- ' •//• '' '>-:£', **'? '4,* , *^ \ ,\
*' *"? ! ' { f i " s* X
5. Have your operators been trained in their duties under emergency
conditions?
Fire?
LP Gas Release?
Severe Weather or Natural Conditions?
6. Are the written operating instructions available?
7. Do the written operating instructions reflect current operation of
the facility? • , •
\
8. Have major modifications to your propane distribution facility
taken .place? ' ,
9. Are contractors used at the facility?
10. Are safe work practices, such as lock/tag,; hot work and line '
opening followed at the facility?
11. Is there a written emergency response plan?
Is it current?
Have your operators been trained?
Do you provide emergency response equipment?
Has it been checked? ' • '
^tl-% ^ftopanel^n^^ffl^lai^^?*;
' ,^*,. . j-f ••• *»•*/ , .'•""<''~, "tff-i: •" %*^ ,, ,,,,, *,- , , ', ,^K. .KKfes.* • v , W." JA. , j, , . ^A^^''^S^^^^^)~^^!^^^'^^t^(,'^f»'T^f "•- >'
I/ Does your propane distribution facility have protection against
tampering required under 3-3.6 of NFPA 58, 1998 Edition?
2. Does your propane distribution facility have lighting as specified
in 3-3.7 of NFPA 58, 1998 Edition?
3. Is the area around your containers and transfer piping free of all
combustible material?
4. Has a fire safety analysis been performed for your propane
distribution facility as suggested by 3-10.2.2 and 3-10.2.3 of NFPA
58, 1998 Edition?
Yes/No/NA
',
Comments
,,
v*t ".«%-•• '•:/?,, :jSf»:
' vfe -$$-. '•% ?-$lZ,
October 27, 1998
-------
Chapter 6
Prevention Program (Program 2)
6-50
nil m, muffin™™ """" mmm mm^ ~ mm "™ /~" mmgnmnmgi hw™» ™. "" &H&£Ssi^ ^^o^ferfe*
5. Has your fire safety analysis been reviewed by your local fire
authority?
6. Has your facility been required by your local fire authority to
provide special protection?
Fixed Water Sprays/Monitor Nozzles?
Insulating Coatings?
Mounding/Burial?
Other types?
7. Has a federal, state, or local agency or fire authority required:
Local Gas Detection Monitors?
Perimeter Gas Monitors and Public Alarms?
Yes/No/NA
Comments
October 27, 1998
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Chapter 6
6-51 Prevention Program (Program 2)
EXHIBIT 6A-7
SAMPLE WHAT-IF ANALYSIS PROCEDURE AND QUESTIONS
Analysis Procedure. The steps in a What-If/Checklist analysis are as follows:
1. Select the team (personnel experienced in the process)
2. Assemble information (piping and instrumentation drawings (P&IDs), process flow diagrams
(PFDs), operating procedures, equipment drawings, etc.)
3. Develop a list of What-If questions (use the ones in Exhibit 6A-7 if you want)
4. , Assemble your team in a room where each team member can view the information.
5. Ask each What-If question in turn and determine:
+ What can cause the deviation from design intent that is expressed by the question?
+ What adverse consequences might follow ?
+ What are the existing design.and procedural safeguards?'
4- Are these safeguards adequate?
+ If these safeguards are not adequate, what additional safeguards does the team
recommend?
6. As the discussion proceeds, record the answers to these questions in tabular format. Exhibit 6A-8
provides an example.
7. Do not restrict yourself to the list of questions that you developed before the project started. The
team is free to ask additional questions at any time.
8. When you have finished the What-If questions, proceed to examine the checklist. The purpose of
this checklist is to ensure that the team has not forgotten anything. While you are reviewing the
checklist, other What-If questions may occur to you.
9. Make sure that you follow up all recommendations and action items that arise from the hazards
evaluation. ,
October 27,1998
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Chapterfi
Prevention Program (Program 2) 6-52
A. What -If Questions for Chlorine and Sulfur Dioxide Systems
..' ," ;'v ; • ' ; " ,,; , •• , : I; /' • •,' '/;"•)'/ " ;i :;;' ,' ' , '• l\ • ''•;..• .''•', •'• "', ' '! •• 'I'"- \ '.•'•' , ' .•
Movement ofl-Tonplj (Sdjj Cylinders
What ''if the cylinder is dropped from the lifting apparatus?
What if the truck rolls forward or backward?
What if a cylinder rolls and drops from the truck?
What if the cylinder swings while being lifted?
What if the C12 (SO2) container is not empty when removed from service? .
What if the automatip container switchover system fails?
What if a C12 (SO2) cyUnder is delivered instead of SO2 (C12 )
What if the cylinder is not in good condition?
Ton Cylinders on Trunnion, including pigtails, (subheader lines) to Main Header Lines
What if pigtails rupture while connected on-line?
What jf pigtail connections open or leak when pressure is applied?
What if something is dropped onto cylinder or connection?
What if cracks develop in the ton cylinder flexible connection?
What if liquid C12 (SO^ is withdrawn through the vapor lines from the ton cylinder?
What if the cylinder valve cannot be closed during an emergency?
What if there are pinholes or small leaks at the fusible plugs?
What if ton cylinder ends change shape from concave to convex?
What if liquid is trapped between two closed valves and the temperature rises?
What if there is a fire near the cylinders?
What if the operator leaves the valve open and disconnects the pigtail?
October 27, 1998
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, Chapter 6
6-53 Prevention Program (Program 2)
What if water enters the system? - ', :
C12 (SO2) Headers in the Ghlorination (Sulfonation) Room
What if the pressure relief valve sticks open?
What if a valve leaks?
What if there is inadequate flow in the gas line .(e.g., filter clogged)?
Evaporators .
What if there is overpressure in the evaporator?
What if there is high temperature in the evaporator? •
What if there is low temperature in the evaporator?
What if rupture disks leak?
What if the vacuum regulator valve fails?
What if there is a gas pressure gauge leak?
What if the vacuum regulator check unit fails?
What if there is liquid C12 (SO2) carryover to the vacuum regulating valve downstream of the
evaporator?
Chlorination (Sulfonation) and Pipes to Injectors
What if there are leaks in the chlorinator (sulfinator) unit?
What if there is rupture of the pipe from the chlorinator to the injector? ' • '
What if there is backfiow of water into the C12 (SO^ line?
What if the water pump is not working?
General
What if there is a power failure? __
What if C12 (SO2) is released during maintenance? . ,
October 27,1998
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i! it! ! f i!1-"'." »; •'••
Chapter 6
Prevention Program (Program 2) 6-54
What if a C12 (SOj) leak is not detected?
What if there is moisture in the C12 (SOj) system? '
Scrubbers
What if the system loses scrubber draft?
What if the system loses scrubber solution?
What if the manual vent to the scrubber is opened during operation?
What if the leak tightness of the building is compromised during emergency operation of the
scrubbers?
Tank Trucks
'„ ' '::•"'::'' • ', ,: I • . • 1 '
What if the liquid hose leaks or ruptures?
'•: ' i''':!" I1 i •' , ' '',5'! '' ,'! " ' •, ' ',
"• „!|1 •""" '• 'i "!" •,','•„ .i,,, •,' , , '"'"
What if the vapor return hose leaks or ruptures?
" „ |l': •, : ' ' ,11! I " . ' i
What if the truck moves?
0,; '••> ' , , '.:;!"'' •• ., ', . ' • • I • . .' "I1 , •' . '
What if the mass of Clj (SO^ hi the truck exceeds the capacity of the tank?
What if the Cl, tank truck is connected to an SO, vessel (or vice versa)?
; ™ "^'H' • ' • •'.!'; , • | T" i ; , „' '', ' •'; i
What if there is something other than Cl, (or SOj) in the truck?
" '' ' •. 'i^'i ' J " n ,,, . . ' " ' ' '|i1'1 i '• i J. '" , ' ' „, •, •', • ' , '
What if there is a fire under or near the truck?
What if the truck collides with pipework or a building housing C12 (SOj) storage vessels?
Railcars
What if the liquid hose leaks or ruptures?
What if the padding air is moist?
What if the padding air hose ruptures?
What if the railcar moves?
What if the relief valve lifts below the set pressure?
Ociobcr27,1998
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. Chapter6
6-55 . Prevention Program (Program 2)
What if there is a fire under or near the truck?
What if there is a fire on or near the railcar?
B. What-If Questions for Ammonia Systems
Storage Vessel
What if the vessel is overfilled?
What if there is fire under or near the vessel?
What if the relief valve fails to lift on demand?
What if the relief valve opens below its set pressure?
What if the deluge system fails to work on demand?
Tank Truck Unloading
What if the liquid unloading hose partially ruptures?
•9 . ' . t ' «
What if the liquid unloading hose completely ruptures? .
What if the tank truck moves?
What if the tank truck drives away before the hose is disconnected?
What if the vapor return hose partially or completely ruptures?
What if valves are not completely closed before disconnecting the hoses?
What if the tank truck contains something other than ammonia?
What if the ammonia in the tank truck contains excess oxygen?
G. What-If Questions for Digester Systems
What if something falls onto a digester cover?
What if relief valves on a digester open?.
What if an intermediate digester gas storage vessel fails?
October 27,1998
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Chapter 6
Prevention Program (Program 2) 6-56
What if air is introduced into the gas collection system?
What if the flare fails to operate?
What if the gas collection header leaks or ruptures or becomes blocked?
What if a digester gas compressor fails catastrophically?
What if there is a digester gas leak into a building (digester building, compressor room, boiler
room)?
i,,r i1 • , * ii . ,i • i •• ,i • • i . , i • i
What if the digester gas pressure exceeds the cover pressure rating?
What if the floating digester gas cover jams or 'tilts?
D. General Questions
What if the ambient temperature is abnormally high?
What if the ambient temperature is abnormally low?
What if there is a hurricane?
What if there is a tornado?
What if there is flooding?
What if there is a heavy snowfall?
What if there is an earthquake?
What if there is a tidal wave?
What if there is a failure of electric power? '
* „
October 27,1998
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6-57
Chapter 6
Prevention Program (Program 2)
Exhibit 6A-8
EXAMPLE WHAT-IF/CHECKLIST LOG SHEET
Company: Sheet Name:
Facility: Reference:
PHA Date: Unit:
• Leader/Secretary: Drawing Number:
Process: Print Date/Time:
Team Members: Description:
Hem
4.1
.4.2
4.3
4.4
Equipment/Activity '
Generic Pressure Vessel
Generic Pressure Vessel
Generic Pressure Vessel
Generic Pressure Vessel
• '
Questions
.
What-if the set pressur&of the
equipment SRV is more than
the design pressure of the
equipment?
What if the SRV is incorrectly
sized?
What if the SRV opens below
its set-pressure?
What if there is a fire near or
under the vessel?
" .
Causes
Incorrectly set valve purchased
or returned after maintenance at
contractor's shop
Design basis for SRV
incorrectly chosen or SRV sized
for vapor flow when two-phase
or liquid flow is possible
Vibration, incorrect design,
weakened SRV spring, failure
due to inadequate PM program
Spillage of flammable liquid
from nearby vessel
Consequence/Hazards
Potential for rupture and
release of contents of
vessel
SRV cannot relieve
pressure, potential
rupture
Release of vapor at
relatively low pressure
High pressure in vessel,
potential rupture.
Potential BLEVE if
vessel contains propane.
Safeguards
Manufacturer
or repair
shop's QA
Valves
purchased for
specific
service
PM program
. SRVs:
Deluge
system:
Separation
distances: .
Keep
flammablcs
away from
vessel
Safeguards
adequate?
Y
Y
N
Y
Recommendations
None
None
Develop PM
program for SRVs
None
October 27, 1998
-------
''i'!", I'M1'1' 'h!1"1:!!1'1!'!" l'i
Chapter 6
Prevention Program (Program 2)
6-58
- • I1 " •• " -.'• . EXHIBIT 6A-9
HAZOP ANALYSIS GUIDE WORDS AND MEANINGS
In the approach, each guide word is combined with relevant process parameters and applied at each point
(study node, process section, or operating step) in the process that is being examined.
„ Guide Words"
No
Less
More
Part Of
As Well As
Reverse
Other Than
Meaning
Negation of the Design Intent
Quantitative Decrease
Quantitative Increase
Other Material Present by Intent
Other Materials Present unintentionally
Logical Opposite of the Intent
Complete Substitution
COMMON HAZOP ANALYSIS PROCESS PARAMETERS
Flow
Pressure
Temperature
Level
Time
Composition
PH
Speed
Frequency
Viscosity
Voltage
Information
Mixing
Addition
Separation
Reaction
The following is an example of creating deviations using guide words and process parameters:
Guide Words Parameter Deviation
NO +
MORE +
AS WELL AS +
OTHER THAN +
' in
FLOW
PRESSURE =
ONE PHASE =
OPERATION =
LEVEL
NO FLOW
HIGH PRESSURE
TWO PHASE
MAINTENANCE
HIGH LEVEL
MORE +
Guide words are applied to both the more general parameters (e.g., react, mix) and the more specific
October 27,1998
-------
! - - ' ' 6-59 ' "
parameters (e.g., pressure, temperature). With the general parameters, it is not unusual to have more than
one deviation from the application of one guide word. Fof example, "more reaction" could mean either
that a reaction takes place at a faster rate, or that a greater quantity of product results. .On the other hand,
some combinations of guide words and parameters will yield no sensible deviation (e.g., "as well as" with
"pressure").
How to Perform a Hazard and Operability (HAZOP) Review
1. Select the team. . ,
2. Assemble information (P&IDs, PFDs, operating procedures, equipment drawings, etc.).
3. Assemble your team in a room where each team member can view P&IDs.
4. Divide the system you are reviewing into nodes (you can preset the nodes, or the team can choose
them as you go along). •
• 5. Apply appropriate deviations to each node. For each deviation, address the following questions:
+ What can cause the deviation from design intent? ; '
+ What adverse consequences might follow ?
+ What are the existing design and procedural safeguards?
+ Are these safeguards adequate?
+ If these safeguards are not adequate, what does the team recommend?
6. As the discussion proceeds, record the answers to these questions in tabular format as shown
below. , .
October 27, 1998
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Chapter^ s , ; ;,
Prevention Program (Program 2)
6-60
EXAMPLES OF LINE-BY-LINE TABLES USE IN A HAZOP
Node No:
From:
To;
Drawing No;
Line ID;
Date:
Node Description:
Keyword
Flow
Flow
Flow
Flow
Deviation
High
Low
No
Reverse
1
TankerTruck
Ammonia Storage Vessel
Liquid loading line from tanker truck to ammonia vessel. , ^
Causes
None identified
Malfunction of truck equipment,
blockage in line, excess pressure
in tank or check valve failure
Malfunction on truck, or vapor
line excess flow valve snaps shut
Hose Rupture
Check valve and excess flow valve
failure with hose rupture
Block valves not closed when hose
disconnected
Consequences
None
Operational
problems
Operational
problems
Ammonia Leak
Vapor release from
vessel
Vapor release from
vessel
Safeguard
N/A
N/A
N/A
Emergency
shutdown features
Check valve,
excess flow value
and hose
inspections
Operator training
Adequate?
N
Y
Y
Recom-
mendation
N
N
N
Y3
N
N
Arbitrary example of recommendation: Currently, the truck must park so far away from the tank that it is necessary to connect tvo lengths of hose.
Investigate the ways in which truck unloading can be accomplished using only one length of hose.
October 27, 1998
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6-61
Chapter 6
Prevention Program (Program 2)
Flow
Flow
Pressure
Wrong
Type
In addition
High
Delivery of wrong material
Water, oxygen, oil
Valve closed, blockage, overfill
vessel
Unknown
Contamination,
corrosion
Ammonia overflow
or rupture
Operational
safeguards
Manufacturer's
quality control
Relief valves, level
gauges
Y
Y
Y
N
N
N
October 27, 1998
-------
I n
«
Prevention Program (Program 2)
6-62
EXAMPLES OF LINE-BY-LINE TABLES (CONTINUED)
Node No:
From:
To:
Drawing No:
Line ED:
Date:
Node Description:
Keyword
Pressure
Pressure
Temp
Temp
Level
Level
Deviation
High
Low
High
Low
High
Low
2
Ammonia Storage Vessel
1 :- -•
= = ^ , ! I
; ; ; - : .-:--:| ; - -\
, • - -• i
* - *
-
:
' ' i r - • = •- --
;j ' -! "' ""
lhl \ > ' !
Ammonia storage vessel's design pressureis 265 psig at 250 'degrees F, Working [capacity is 15,tiOO gallons.
Maximum level allowed in the tank is 85%, but normal operating procedure is 75%.
Causes
Fire
Vaporizer malfunction
See High Pressure
See Low Pressure
Overfilling
Failure to order
Consequences
Relief valve opens
None
Relieve valve opens
None
Safeguard
Deluge system
N/A.
Procedural
N/A
Adequate?
Y
N/A
N/A
N/A
Y
N/A
Recom-
mendation
N
N
N
N
N
N
October 27, 1998
-------
CHAPTER 7: PREVENTION PROGRAM (PROGRAM 3)
Many of you will need to do little that is new to comply with the Program 3
prevention program, because you already have me OSHA PSM program in place.
• Whether you're building on the PSM standard or creating a new program, keep these
things in mind.
+ EPA and OSHA. have different legal authority — EPA for offsite
consequences, OSHA for on-site consequences. If you are already complying
with the PSM standard, your process hazard analysis (PHA) team may have to
assess new hazards that could affect the public or the environment offsite.
Protection measures that are suitable for workers (e.g., venting releases to the
outdoors) may be the very kind of thing that could expose the public to toxic
- • - substances.
+ Integrate the elements of your prevention program. You must ensure that a
change in any single element of your program leads to a review of other
elements to identify any effect caused by the change.
+ Most importantly, make accident prevention an institution at your site. Like
the entire risk management program, a prevention program is more than a
collection of written documents. It is a way to make safe operations and
accident prevention the way you do business everyday.
7.1 PROGRAM 3 PREVENTION PROGRAM AND OSHA PSM
The Program 3 prevention program includes the requirements of the OSHA PSM
standard. Whenever we could, EPA used OSHA's language verbatim. However,
there were a few terms that EPA had to change to reflect the differences between its
authority and OSHA's. For example, OSHA regulates to protect workers; EPA's
responsibility is to protect public health and safety and the environment. Therefore,
an "owner or operator" subject to EPA's rule must investigate catastrophic releases
"•that present(s) (an) imminent and substantial endangerment to public health and the
environment," but an OSHA "employer" would focus its concerns on the workplace.
To clarify these distinctions, we deleted specific references to workplace impacts and
"safety and health" contained in OSHA's PSM standards. We -also used different
; schedule dates and references where appropriate. Exhibit 7-1 compares terms in
EPA's rule with their counterparts in the OSHA PSM standard.
October 27) 1998
-------
Chapter?
Prevention Program (Program 3)
7-2
EXHIBIT 7-1
COMPARABLE EPA AND OSHA TERMS
tQSB&3£rik 1' j'.TM !".', r ,.!...•;'; ;
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 subpart D of part 68. Exhibit 7-2 sets out each of the
twelve elements, the corresponding section numbers, and OSHA references. Two
OSHA elements are not included. Emergency response is dealt with separately in part
68; the OSHA trade secrets requirement (provision of trade secret information to
employees) is beyond EPA's statutory authority.
SUMMARY OF PROGRAM 3 PREVENTION PROGRAM
(40 CFR PART 68, SUBPART D)
SSte&noN
§ 68.65
§ 68.67
§ 68.69
§ 68.71
§ 68.73
§ 68.75
§ 68.77
§ 68.79
§ 68.81
§ 68.83
§ 68.85
§ 68.87
TITLE
Process Safety Information
Process Hazard Analysis (PHA)
Operating Procedures
Training
Mechanical Integrity
Management of Change
Pre-Startup Review
Compliance Audits
Incident Investigation
Employee Participation
Hot Work Permit
Contractors
OSHA PSM REFERENCE
PSM standard § 1910.1 19(d).
PSM standard § 1910.1 19(e).
PSM standard § 1910.119®.
PSM standard § 1910.119(g).
PSM standard § 1910.1 190).
PSM standard § 1910.119(1).
PSM standard § 1910.119(1).
PSM standard § 1910.1 19(o).
PSM standard § 1910.119(m)
PSM standard § 1910.1 19(c).
PSM standard § 1910.1 19(k).
PSM standard § 1910.1 19(h).
OSHA provided guidance on PSM in non-mandatory appendix C to the standard.
OSHA has reprinted this appendix as PSM Guidelines for Compliance (OSHA 3133).
The OSHA guidance is reproduced, reordered to track part 68, in Appendix
October 27.1998
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7-3
Chapter 7
Prevention Program (Program 3)
F. The remainder of this chapter briefly outlines the major requirements and provides
a discussion of any differences between' EPA and OSHA. In some cases, further
guidance specific to WWTPs is provided. For more detailed guidance, you should
refer to the OSHA guidance in Appendix F.
Qs&As
IMPLEMENTATION AND PROGRAM LEVEL
Q. My process is a series of storage and process vessels, connected by piping, containing several
regulated substances, with a few co-located tanks of other substances. Do I have to implement one
prevention program to cover all aspects of the process even if different operators, different process
chemistry, and different hazards are involved in various parts of the process?
A. You should implement the program in .the way that makes sense to you. For a complex process
such as yours, you may need to divide the process into sections (e.g., production units for particular
products, storage units) for the PHA and compliance audits, to keep the analyses manageable.
Operating and maintenance procedures (and the training in these procedures) should be developed for
operating units; combining procedures for different types of units into a single document may make
them harder to use; training operators in procedures they do not need would waste time and perhaps
confuse operators. You may want to collect and store process safety information by individual units to
make it easier to use. Other parts of the program (contractors, employee participation, procedures for
pre-startup, management of change, and hot work) are likely to be common to all parts of the process.
Q. I have a tank with more than 10,000 pounds of propane. I use the propane to heat the offices, but
not as a fuel for my covered process, so it is not subject to OSHA PSM and would be Program 2 for
EPA. 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 process? Does this affect the
program level?
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 a single process
and consequently is subject to both OSHA PSM and Program 3.
7.2 PROCESS SAFETY INFORMATION (§68.65) "
' Exhibit 7-3 briefly summarizes the process safety information requirements.
MSDSs will provide information on chemicals, except for inadvertent mixing with
other chemicals. Information on the hazardous effects of inadvertent mixing can come
from the PHA checklist (see the following section on process hazard analyses.)
MSDSs are available from your supplier of chemicals. But, because methane (CH^ is
generated in your plant, you will have to find ah MSDS for methane elsewhere. A
local utility supplying natural gas may have one. You may, however, have to add the
potential for inclusion of carbon dioxide, hydrogen sulfide, and water in the
October 27, 1998
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Chapter 7
Prevention Program (Program 3)
7-4
methane stream. If these are present, then corrosivity information about that stream
will be needed. You may wish to ask for assistance from a process engineer.
The information listed in the second column of Exhibit 7-3 is needed for that part of
your plant where the regulated substances are used. It should be available from the
engineering firm that designed the plant. If not, you will have to develop it to meet
this rule. The last item, consequences of deviation, means that you need to know what
will happen if the process (including any safety controls) does not work the way it was
designed to. If you do not have this information, or it cannot be obtained from the
engineering firm that designed the plant, it can be developed during the process
hazard analysis.
PROCESS SAFETY INFORMATION REQUIREMENTS
For chemicals, you must
complete information on:
•Toxicity
•Permissible exposure limits
•Physical data •
•Reactivity
•Corrosivity
•Thermal & chemical stability
•Hazardous effects of
inadvertent mixing of
materials that could
foreseeably occur
For process technology, you
must provide;
•A block flow diagram or
simplified process flow
diagram
•Information on process
chemistry
•Maximum intended inventory
of the EPA-regulated chemical
•Safe upper & lower limits for
such items as temperature,
pressure, flows, or
composition
•An evaluation of the
consequences of deviation
For equipment in the
process, you must include
information on:
•Materials of construction
•Piping & instrument diagrams
(P&IDs)
•Electrical classification
•Relief system design & design
basis
•Ventilation system design
•Design codes & standards
employed
•Safety systems
•Material and energy balances
for processes built after June
21,1999
You must maintain equipment information for your plant. Such information is
ordinarily supplied with the construction of the plant, and with" major replacements
and revisions to the plant. Generally, equipment information is found in operations
and maintenance (O&M) manuals or equipment submittals. The rule only requires
that you have information for that part of your plant that handles, or could cause a
release of, the regulated substances you have.
WHERETO Go FOR MORE INFORMATION
Diagrams. You may find it useful to consult'Appendix B of OSHA's PSM final rule,
computer software programs that do P&IDs, or other diagrams.
Guidance and Reports. Various engineering societies issue technical reports relating
to process design. Other sources you may find useful include:
O«obcr27,1998
-------
Chapter 7
7-5 - . Prevention Program (Program 3)
* Guidelines for Process Safety Documentation, Center for Chemical Process
Safety of the Amelrican 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
Vessels: 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.
4- Loss Prevention in the Process Industries, Volumes I, II, and III, Frank P.
Lees, Butterworths: London 1996. ,
The Chlorine Institute publishes a number of documents on chlorine handling
including: .
+ Chlorine Vaporizing Systems, Pamphlet # 9. ;
+ Cylinder and Ton Container Procedures for Chlorine Packaging, Pamphlet #
17. ' ' '
+- Water and Wastewater Operators Chlorine Handbook, Pamphlet # 155.
The Compressed Gas Association publishes:
+ Sulfur Dioxide on properties, storage, handling, and use of sulfur dioxide
(Order* G-3). .
+ ANSI K61.1 on the storage and handling of anhydrous ammonia (Order # G
2.1). ' ' ,
+ Anhydrous Ammonia on properties, storage, handling,"and use of anhydrous
ammonia (Order # G-2). '
NFPA-820 (Standard for Fire Protection in Wastewater Treatment and Collection
Facilities) provides guidance On design issues. " . . '
MSDSs. MSDSs are available from a number of websites. The University of
California San Diego, Chemistry and Biochemistry Department, maintains some
'MSDSs on its website: http://www-ehs.ucsd.edu/msds.htnL This site also links to
other pages with MSDSs, including Vermont Safety and Information Resources on the
Internet, http://siri.org. On-line databases also provide MSDSs. EPA has not verified
the accuracy or completeness of MSDSs on any of these sites nor does it endorse any
particular version ofan MSDS. You should review any MSDS you use
October 27, 1998
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Chapter 7
Prevention Program (Program 3)
7-6
to ensure that it meets the requirements of the hazard communication standard (29
dFR 1910.1200).
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 does "relief system design basis" mean?
A. Relief systems include, but are not limited to, relief valves, relief headers, relief drums, and rupture
disks. Design basis means documenting how the loads and sizes of the relief system, as well as inlet
and outlet sizes, were determined. This includes a description of overpressure scenarios considered,
the scenario that creates the largest load to be relieved, the assumptions used, and if the device meets a
certain code. Relief devices on pressure vessels must conform to ASME codes. Industry codes (e.g.,
API RP 520) also provide guidance on scenarios that should be considered and on equations for sizing
of devices. Scenarios you may need to consider include fire, blocked flow, control valve failure,
overheating, power outage, tube rupture, and cooling water failure. For two-phase flow, you should
review AIChE publications from the Design Institute for Emergency Relief. Systems (DIERS).
Q. What do I have to do for material and energy balances?
A. For new processes, you must document both material and energy inputs and outputs of a process.
For example, you would document the quantity of a regulated substance added to the process, the
quantity consumed during the process, and the quantity that remains in the output. ..This requirement
will not generally apply to storage processes. • • •
October 27, 1998
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7-7
Chapter?
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7.3 PROCESS HAZARD ANALYSIS (§68.67)
Exhibit 7-4 provides a summary of the requirements for process hazard analyses
(PHAs).,
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 th
life of the process
EPA/OSHA DIFFERENCES
You can use a PHA conducted under the OSHA PSM standard as your initial process
hazard analysis. All OSHA PHAs must have been completed by May 1997.
Therefore,- the only "new" PHAs will be for non-OSHA Program 3 processes. If the
process is subject to OSHA PSM, you can update and revalidate your PHA on
OSHA's schedule. ' "
Offsite impacts. You should consider offsite impacts when you conduct a PHA
under EPA's rule (except for an initial PHA where are using the PHA conducted for
OSHA PSM). If you are in the Program 3 prevention program because you must
comply with the PSM standard, you may not have fully considered offsite
consequence because the focus of PSM is worker protection. Practically speaking,
however, there should be few instances where the scenarios considered for OSHA fail
to address offsite impacts. A Well-done PHA should identify all failure scenarios that
could lead to significant exposure of workers, the public, or the environment. The
only issue that may require further consideration for part 68 processes is whether any
protection measures that were adequate for worker safety are inadequate for public
and environmental safety.
October27,1998
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Chapter 7
Prevention Program (Program 3) 7-8
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 JK>W the loss of containment could occur. However, for EPA, the
PH4 team should reassess venting as an appropriate mitigation measure.
Updating and reyalidating 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 In OSHA PHA as your initial PHA, and update and revalidate it every five years
on the OSHA schedule. A PHA completed after August 19, 1996 (the effective date
of part 68) should consider offsite impacts.
METHODS
Unless your WWTP is uncommonly complex, the checklist method is likely to be
sufficient to meet the need in smaller plants. Operators might find it practical. to add
what-if questions to supplement the checklist, or use the what-if/checklist method.
See the guidance provided in Program 2, section 6-3 and Appendix A to Chapter 6,
for examples of checklists and what-if questions. Guidance on how to use these
methods, or HAZOPs, is included in that chapter.
If the chlorine, sulfur dioxide, or ammonia receiving and storage facilities are
designed to receive tank truck or rail car quantities, then the Hazard and Operability
(HAZOP) method is likely to be best. It also would be well to use HAZOP for
methane systems where the gas is compressed and stored for use as a fuel. If you do
not have anyone on staff who has taken part in a HAZOP or taken HAZOP training,
you may want to engage a skilled study leader.
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.
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7-9
Chapter?
Prevention Program (Program 3)
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
revalidating your PHA whenever adjoining processes create a hazard. Remember that
you have a general duty to prevent accidents and ensure safety at your source, which
may require you to take steps beyond those specified in the risk management program
rule.
QS & AS
OFFSITE CONSEQUENCES
Q. What does EPA mean by "consider offsite consequences"? Do we have to do an environmental
impact assessment (EIA)? '
A. EPA does not expect you to do an EIA. Potential consequences to the public and the environment
are already analyzed in the offsite consequence analysis. In the PHA, EPA only expects you to identify
any failure scenarios that could lead to public exposures and to examine whether your strategies are
adequate to reduce the risk of such exposures.
Q. If I need to revise a PHA to consider offsite consequences, when do I have to do that?
?r
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 in May
1993, OSHA requires that you update that PHA by May 1998. In that update, you should consider
offsite consequences. If you complete your initial PHA for OSHA in May 1995, jou must update it by
May 2000; PHAs conducted for part 68 must include consideration of offsite-consequences at that
time. •
WHERE To Go FOR MORE INFORMATION
Appendix 7-A of this chapter provides a summary of each of the techniques, a
description of the types of processes for which they may be appropriate, and estimates
about the time and staff required for each.
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Chapter 7
Prevention Program (Program 3) 7-10
Part 68 and QSHA PSM require that whichever technique or techniques you use, you
must have at least one person on the PHA team who is trained in the use of the
technique. Training on such techniques is available from a number of professional
organizations as well as private companies. You may have staff members who are
capable of providing this training as well. Many trade associations publish detailed
guidance on methods for conducting a process hazard analysis. You might find the
following documents useful.
"• + '" Guidelines for Hazard Evaluation Procedures, 2nd Ed. with Worked
examples, Center for Chemical Process Safety of the American Institute of
Chemical Engineers 1992.
^ Evaluating Process Safety in the Chemical Industry, Chemical Manufacturers
Association.
^ Loss Prevention in the Process Industries, Volumes I, II, and III, Frank P.
Lees, Butterworths: London 1996.
+ ' ' Management of Process Hazards (RP 750), American Petroleum Institute.
•*• Risk-Based Decision Making (Publication 16288), American Petroleum
.:. ' '_'•'•' , " ': '•'';' "Institute. ,
7.4 OPERATING PROCEDURES (§68.69)
•: '!",;'? ' ' " , y|!'! • •' v . '""" j": '. •'•> ' • -V: i:'J' ': !•" '; , :.."''' , ,• :. •"; .:'•'• •' '• :
Exhibit 7-5 summarises what your operating procedures must address. Operating
procedures must be readily accessible to workers who operate or maintain the process.
You must review operating procedures as often as necessary to assure that they reflect
current practices and any changes to the process or facility. You must certify annually
that the operating procedures are current and accurate.
In a WWTP, it will be especially important to detail, very specifically, the procedures
and safeguards for connecting and disconnecting cylinders, tank trucks or rail cars of
regulated substances. These procedures should also detail the required precautions,
e.g., having an emergency respirator readily available. Also, assuring that emergency
equipment is functional and readily available should be part of the instructions. For
example, an inspection of the air tank on self-contained breathing apparatus prior to
making or breaking connections should be considered.
In WWTPs, it is likely that regular operating procedures will include startup, normal
operations, and normal shutdown. Provision for emergency shutdown and startup
following a turnaround or emergency shutdown need to be included only to the extent
that they differ from your regular procedures. These procedures should also detail
what to do in the event of an emergency. In particular, they must include the
shutdown actions operators shouid take, without reference to supervisors, to avoid
more serious consequences and the conditions requiring them.
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7-1.1
Chapter?
, Prevention Program (Program 3)
The, operating limits section-should detail what would happen if the actual operating
parameters (pressure, flow, temperatuife) were higher or lower than intended. Then
the procedures should tell operators what to do to correct them.
The safety system section should explain all about your safety systems. These are
alarms, shutdown devices, relief systems, remote telephone alerting systems, and the
like. The procedures should show:
i . . . -%•',. ..
•!*• " What the system or device is.
+ What it is supposed to do. . , .
+ How it works. '
+ How to operate"it, if operators must initiate action.
EXHBBIT7-5
OPERATING PROCEDURES REQUIREMENTS
Steps for each
operating phase
•Initial startup
•Normal Operations
•Temporary operations
•Emergency shutdown
•Emergency operations
• Normal shutdown
•Startup following a
turnaround or emergency
shutdown
•Lockout/tagout
•Confined space entry
•Opening process
equipment or piping
•Entrance into the facility
Operating limits
•Consequences of
deviations
•Steps to avoid,
correct deviations
Safety & health
considerations
•Chemical properties & hazards
•Precautions for preventing
chemical exposure
•Control measures for exposure
•QC for raw materials and
chemical inventory
•Special or unique hazards
Safety
systems &
their
functions
•Address
whatever is
applicable
Operating procedures, especially for plants that run unattended overnight or
on weekends, should include provisions to prevent vandalism or sabotage by
use of locks, fences, police patrol, or other secure means. '
WHERE To Go FOR MORE INFORMATION
^Chapter 6 of this document provides descriptions of each operating phase and when
these phases may not apply to certain operations.
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Chapter?
Prevention Program (Program 3) 7-12
The Chlorine Institute (http://www.cl2.com) publishes information on safe use and
handling of chlorine. Its Water and Waste-water Operators Chlorine Handbook
(Pamphlet # 155) provides general training and procedures.
The Water Environment Federatipn (601 Wythe Street, Alexandria, VA 22134, (703)
684-2470) provides general procedures as part of its training programs for wastewater
treatment.
Although the reports below target the chemical industry, you may find useful
information in them: .
^ Guidelines for Process Safety Fundamentals for General Plant Operations,
Center for Chemical Process Safety of the American Institute of Chemical
/ • .:? " ' . ' ;;'5 , .Engineers 1995.' .
+ Guidelines for Safe Process Operations and Maintenance, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1995.
+ Guidelines for Writing Effective Operating and Maintenance Procedures,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1996.
7.5 TRAINING (§68.71)
You are required to train new operators on the operating procedures and cover health
and safety hazards, emergency operations, and safe work practices applicable to the
employee's tasks. For workers involved in operating the process before June 21, 1999,
you may certify in writing that they are competent to operate the process safely, in
accordance with the operating procedures. At least every three years you must
provide refresher training (you must consult with employees involved in operating the
process to determine the appropriate frequency). Finally, you are required to
, determine that each operator has received and understood the training and keep a
reccjrd for each employee with the date, of the training and the method used to verify
that the employee understood the training.
For WWTPs, training should cover the activities that could lead to releases of the
toxic gases and flammables that are used in WWTPs. These activities should be
identified in the process hazard analysis and bear particular attention:
,;„ ,'"-, • • IIP i . • ',,„'.'. " riiiJ i. »i» I , •' 'i ; 'si1"' „ i'';' , "'','•,'" , ' V1 P., '!""• • • "" • / '"iiJi • 'I " • I v :• • •
* . + Connecting, and disconnecting, cylinders of Chlorine and Sulfur Dioxide.
Training should cover inspection of the fittings and tubing to assure that they
are in good condition and inspection (and discard if necessary) of tools used
for the job. Training should also include identification of vapor and liquid
connections on the cylinders and identification of the operating conditions
that will show that the connections are hooked up in reverse.
October 27,1998
iii.
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Chapter 7
7-13 Prevention Program (Program 3)
+ Material handling of cylinders; Training should cover inspection of material
handling equipment, including hoists, cylinder carriers and hooks, and
cylinder chocks. Also, inspection for and removal of combustibles or
flammables in storage areas should be a part of training.
WHERE To Go FOR MORE INFORMATION
The Water Environment Federation provides several training programs including the
, following:
+ Basic Course for Wastewater Treatment Plant Operators, Instructor Set
Order No. E0100GB, Student Workbook Order No. E0110GB.
. + Intermediate Course for Wastewater Treatment Plant Operators, Instructor
Set Order No. E0295GB, Student Workbook Order No. E0296GB.
+ Chlorination Skill Training Course, Order No. EOS 12GB. Self Instruction
Course. ! '• ' .- ' • ; ' .
In addition, the following may be useful.
^ Guidelines for Process Safety Fundamentals for-General Plant Operations,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1995.
+ Guidelines for Technical Planning for On-Site Emergencies, Center for
Chemical Process Safety of the American Institute of Chemical Engineers
1995.
+ Federally Mandated Training and Information (Publication 12000),
American Petroleum Institute. ,
7.6 MECHANICAL INTEGRITY (§68:73)
You must have a mechanical integrity program for pressure vessels and storage,tanks,
piping systems, relief and vent systems and devices, emergency shutdown systems,
controls, and pumps. Exhibit 7-6 briefly summarizes the other requirements for your
mechanical integrity program. The mechanic integrity requirement is similar to the
maintenance requirement under Program 2, but covers additional areas, such as ,
quality assurance. , ' .
For most of the equipment in a WWTP, the manufacturer will have supplied
maintenance instructions.. These can be used to fulfill the requirements for
maintenance procedures. Where such instructions are not available, you will need to
develop them. In addition to the major pieces of equipment, you will need to develop
inspection procedures that consider both repair or replacement requirements for the
following items:
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Chapter 7
Prevention Program (Program 3)
7-14
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 die
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.
4- Fittings
"4- Tubing
4- Pressure relief devices
4- Gauges, pressure switches, and other instrumentation.
4- Rotameters
4- Pressure regulators, and pressure gauges
+ Leak detectors
4- Eductors, vacuum mixers, or other devices used to mix chlorine, sulfur
dioxide, and other regulated substances into waste water streams
4- . ' Material handing equipment
4- Tools
4- All other equipment used to handle, transfer, or use the regulated substances.
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Chapter 7
7-15 Prevention Program (Program 3)
Where there is the possibility of corrosion, these inspections are especially important.
The regulated substances used are norrhally not corrosive, when they are dry.
However, all of them can become highly corrosive if the equipment using them is
wet. Attention to this aspect can be vital, ,
Where methane is recovered, compressed, and stored for use in the plant, steel
pipelines and storage vessels should be inspected regularly. If the plant operator is not
familiar with preventive inspection and testing, help should be sought. If the storage
tank is a pressure vessel, the helping person should be very familiar with the ASME
pressure vessel code and with API tank inspection requirements.
.In larger plants, where there are storage tanks for chorine, sulfur dioxide or ammonia,
the tanks and associated piping should be inspected regularly.. Suppliers are likely to
be able to provide recommendations for this inspection and preventive maintenance.
Propane distributors are likely to be able to supply the same information about
propane vessels and equipment, if these are included in your plant.
You may need to cover a number of the maintenance procedures. The value in these
procedures comes from the use of permits as a communication device. They are
intended to communicate the hazards, and needed precautions, to the workers
performing work under the permits. Also, the provision of the permit to operators will
inform them of the nature of the work in progress, so that they can govern their
activity so as riot to interfere with or provide additional hazard to the job in progress.
The maintenance procedures you need are the following:
+ Confined space entry. For guidance see the OSHA standard, 29 CFR
1910.146
+ Lockout-tagout. For guidance, see the OSHA standard 29 CFR 1910,146.
+ Pipeline breaking. Operators should prepare their own procedure that:
> Provide a means to communicate the hazards that might be presented
to those who will encounter them.
: > Provide a list the precautions needed to safely control these hazards.
> Provide a means to communicate these precautions, and insure that
they are understood by those who must take the precautions.
t> Provide a requirement that these precautions are effectively taken and
remain in place until the work is complete.
+ Control of entry into hazardous areas. Operators should provide a procedure
that controls the access of individuals to places where regulated materials are
stored, handled or used. There are three objectives to this control:
October 27,1998
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Chapter 7
Prevention Program (Program 3) 7-16
> Limit potential exposure to hazardous materials to only the essential
requirements.
> insure that only properly trained or informed persons have access to
hazardous material locations.
> Ensure that the hazardous areas are secure.
Operators are expected to provide spare parts store where needed. Spare parts kept on
hand, are an important part of Mechanical Integrity. There is some plant equipment,
like cylinder connection tubing and connecting devices, that must not be used when
they are worn. Prompt replacement is a valuable preventive action. The operator
must assure that critical parts are readily available. As part of the Quality Assurance
(see column 5 of Exhibit 7-6) needs, operators are'expected to'assure that these are the
right spare parts. Substitution of parts of the wrong specification can lead to a
catastrophic release of these hazardous materials.
WHERETO Go FOR MORE INFORMATION
Guidance and Reports. The documents listed under Process Safety Information may
be useful for maintenance procedures as well. In addition, the Chlorine Institute
publishes pamphlets on chlorine system maintenance, including the following:
+ Maintenance Instructions for Chlorine Institute Standard Safety Valves, Type
1-1/2 JQ(#39). •
+ Maintenance Instructions for Chlorine Institute Standard Angle Valve (#40).
+ Maintenance Instructions for Chlorine Institute Standard Safety Valve, Type
4JQ(#41).
+ Maintenance Instructions for Chlorine Institute Standard Excess Flow Valves
(#42).
,;,;: ." ' | " , . / I i:i,-': ",.';..;; >,:''<•
Other sources of guidance and reports you may find useful include:
* Guidelines for Process Equipment Reliability Data with Data Tables, Center
for Chemical Process Safety of the American Institute of Chemical Engineers
1989.
^ Guidelines for Process Safety Documentation, Center for Chemical Process
Safety of the American Institute of Chemical Engineers 1995.
^ Pressure Vessel Inspection Code: Maintenance Inspection, Rating, Repair,
and Alteration (API 510), American Petroleum Institute.
October 27,1998
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7-17
Chapter?
Prevention Program (Program 3)
•*• Tank Inspection, Repair, Alteration, and Reconstruction (Std 653), American
( Petroleum Institute. , *
7.7, MANAGEMENT OF CHANGE (§68.75)
, Exhibits 7-7 briefly summarizes EPA's MOC requirements.
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)
V
The purpose of this element of the RMP rule, and the next element, pre-startup
review, is to make sure that, if you make a change to your covered process or your
facility in a way thataffects a covered process, that you do so safely: .
The management of change provision will apply when you make a change that can
affect a regulated substance, (for example, by adding chorine directly to the contactor
instead of dissolving it in water first). Or it will apply if you add a regulated
substance (for example, by adding a new digester that runs your total mass of digester
gas over the lOjOOO pound threshold). Or you may change tubing from steel to
plastic. Or you-may build a new chemical storage building that houses C12 and SO2 in
the same place, where you had separate buildings previously. .
t , • '
Any change that affects the regulated substances, whether in storage, use, or '" '
processing, is subject to Management of Change. It does not apply to repairs or
October 27, 1998
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Chapter 7
Prevention Program (Program 3) 7-18
maintenance or in-kind replacements. Also, it does not apply when you make a
change in processing conditions that are within the normal bounds of operation, like a
change in C12 addition rate.
Method of review. The first column of Exhibit 7-7 calls for understanding the
impact of the change on safety and health. This usually means that some study is
needed. If the change is a major one (e.g., a new chlorine storage building for bulk
chlorine), you might choose to run a full-blown Hazard and Operability study
(HAZOP). Your engineering firm, or engineer, is likely to organize it. For a small
change (e.g., a not-in-kind replacement of a chlorine eductor), the checklist questions
(see Chapter 6) that apply to the equipment being changed are likely to be sufficient.
Or your supplier could possibly refer you to other WWTPs that use it, and you could
check with them to see if any problems have come up that are worth further check or
study. .
. • '
The objective is to be very sure that after the change has been made, the process or
plant is safe to operate before you start to use it. Take the time to analyze the
change and check the system carefully.
WHERE To Go FOR MORE INFORMATION . .
+, Management ofChange in Chemical Plants: Learning from Case Histories,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1993.
+ Plant Guidelines for Technical Management of Chemical Process Safety,
Center for Chemical Process Safety of the American Institute of Chemical
Engineers 1992.
• . , It ' . ;, . |. • , •
+ Management of Process Hazards (RP 750), American Petroleum Institute.
+• Guidelines for Engineering Design for Process Safety, Center for Chemical
Process Safety of the American Institute of Chemical Engineers 1993.
7.8 PRE-STARTUP REVIEW (§68.77)
«
You must conduct your pre-startup safety review for new stationary sources or
modified stationary sources when the modification is significant enough to require a
change in safety information under the management of change element. You must
conduct your pre-startup review before you introduce a regulated substance to a
•process, and you must address the items listed in Exhibit 7-8.
October 27.1998
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7-19
Chapter 7
Prevention Program (Program 3)
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.
Trainin:
•'
•Confirm that each
employee involved
in the process has
been trained
completely.
Like Management of Change, in the preceding section, this element of the RMP rule
is to make sure that changes you intend to make are safe tooperate before you put
them into operation. It places the responsibility squarely on the operator to check that
persons making the change (e.g., the maintenance people, or the engineering firm)
have properly completed the job before start up. If it is not properly completed, it is
not acceptable to start the process. .
If you do not have the expertise to do conduct a pre-startup review, you will need to
arrange for someone with the necessary expertise to conduct it. Pre-startup safety
review is an intended redundancy to the Management of Change requirements.
. Again, the principle is take the time to analyze, the change and check the system
carefully before operating it.
7.9 COMPLIANCE AUDITS (§68.79)
You must conduct an audit of the process to evaluate compliance with the prevention
program requirements at least once every three years. At least one person involved in
the audit must be knowledgeable in the process. You must develop a report of the
• findings and document appropriate responses to each finding and document that
deficiencies have been addressed. The two most recent audit reports must be kept on-
site. •
The OSHA compliance guideline, CPL 2-2.34a, is a good starting point for an audit of
the prevention program for a WWTP. Operators should apply the questions to that
portion of their facility that uses or handles the regulated substances present on the
plant. It is critical that you resolve any questions raised by, or findings of, the audit.
These are likely to describe flaws in the management of process, safety that could lead
to a release of highly toxic or flammable gases. Continued operation with such flaws
should not be permitted.
October 27, 1998
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Prevention Program (Program 3)
7-20
WHERE To Go FOR MORE INFORMATION
, + . Guidelines for Auditing Process Safety Management Systems, Center for
1 Chemical Process Safety of the American Institute of Chemical Engineers
' _ ';;' 1993. ' .'' ' . i ' ; ^ ' :,
7J 0 INCIDENT INVESTIGATION (§68.81)
Exhibit 7-9 briefly summarizes the steps you must take for investigating incidents.
i. '.'. . " ' !,'• .' ' Jl" •' . ,' .', ' ' ii1 ' ' ' , '' '"i;:- ' . '. •..' I, , . . ,
; ' .- • '• ^ ' : , ;': " '\EXBflBIT7-9 , ' ' , ' .'."
INCIDENT INVESTIGATION REQUIREMENTS
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•Initiate an investigation
promptly.
Begin investigating no later than 48 hours following the incident.
•Establish a knowledgeable
investigation team.
Establish an investigation team to gather the facts, analyze the
event, and develop the how and why of what went wrong. At
least one team member must have knowledge of the process
involved. Consider adding other workers in the process area
where the incident occurred. Their knowledge will be significant
and should give you the fullest insight into the incident.
•Summarize the investigation in a
report.
Among other things, the report must identify the factors
contributing to the incident. Remember that identifying the root
cause may be more important than identifying the initiating
event. The report must also include any recommendations for
corrective actions. Remember that the purpose of the report is to
help management take corrective action.
•Address the team's findings and
recommendations.
Establish a system to address promptly and resolve the incident
report findings and recommendations; document resolutions and
corrective actions.
•Review the report with your staff
and contractors.
You must share the report - its findings and recommendations
with affected workers whose job tasks are relevant to the
incident.
•Retain the report.
Keep incident investigation reports for five years.
You must investigate each incident which resulteu in, or could have resulted in, a
"catastrophic release of a regulated substance." A catastrophic release is one that
"presents an imminent and substantial endangerment to public health and the
environment." Although the rule requires you to investigate only those incidents
which resulted in, or could reasonably have resulted in a catastrophic release, EPA
encourages you to investigate all accidental releases, investigating minor accidents
October 27,1998
i! It
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.7-21
Chapter?
Prevention Program (Program 3)
or near misses can help you identify problems that could result in major releases if left
unaddressed.
WHERETO Go FOR MORE INFORMATION
* Guidelines for Investigating Chemical Process Incidents, Center for Chemical
Process Safety of the American Institute of Chemical Engineers 1992.
4- Guide for Fine and Explosion Investigations (NFPA 921), National Fire
Protection Association.
7.11 EMPLOYEE PARTICIPATION (§68.83)
Exhibit 7-10 briefly summarizes what you must do..
EXHIBIT 7-10
EMPLOYEE PARTICIPATION REQUIREMENTS
•Write a plan.
•Consult with
employees.
•Provide access to
information.
Develop a written plan of action regarding how you will implement
employee participation. '
Consult your employees and their representatives regarding conducting and
developing PHAs and other elements of process safety management in the .
risk management program rule.
Ensure that your employees and their representatives have access to PHAs
and all other information required to be developed under the rule.
7.12 HOT WORK PERMITS (§68.85)
Exhibit 7-11 briefly summarizes how to meet the hot work permit requirement.
EXHIBIT 7-11
HOT WORK PERMITS REQUIREMENTS
•Issue a hot work permit.
•Implement fire prevention and
protection.
•Indicate the appropriate dates.
•Identify the work.
•Maintain the permit on file.
You must issue this permit for hot work conducted on or. near a
covered process.
You must ensure that the fire prevention and protection
requirements in 29 CFR 1910.252(a) are implemented before the
hot work begins. The permit must document this;
The permit should indicate the dates authorized for hot work.
The permit must identify the object on which hot work is to be
performed.
You must keep the permit on file until workers have completed the
hot work operations.
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Chapter?
Prevention Program (Program 3) 7-22
•• ', " li "'• " ' "",' !;'"/• .,'•:.'' /'.-"I :>,.•' •, .' •• ':'• ,;V , ';, : ,
Welding, cutting, brazing, grinding, sandblasting, and other spark-producing work is
subject to this element of the standard. Because there is likely to be flammable gas
present, you should consider that fire or explosion hazards exist.
The value in hot wqrk procedures comes from the use of permits as a communication
device. They are intended to communicate the hazards, and needed precautions, to the
wofiers performing work under the permits. Also, the provision of the permit to
operators will inform them of the nature of the work in progress, so that they can
govern their activity so as not to interfere with or provide additional hazard to the job
in progress.
WHERE To Go FOR MORE INFORMATION
¥> Standard forFire Prevention in Use of'Cutting and Welding Processes
(NFPA 518), National Fire Protection Association.
4- Standard for Welding, Cuttingand.'Brazing, 29 CFR 1910 SubpartQ.
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.
October 27,1998
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7-23
Chapter?
Prevention Program (Program 3)
EXHIBIT 7-12
CONTKACTORS CHART
You must...
•Check safety performance. When selecting a
contractor, you must obtain and evaluate
information regarding the safety performance of
the contractor.
•Provide safety and hazards information.
You must inform the contractor of potential
fire, explosion, or toxic release hazards; and of
your emergency response activities as they-
relate to the contractor's work and the process.
•Ensure safe practices; You must ensure that
you have safe work practices to control the
entrance, presence, and exit of contract
employees in covered process areas.
•Verify that the contractor acts responsibly.
You must verify that the contractor is fulfilling
. its responsibilities.
Your contractor must...
•Ensure training for its employees. The
contractor must train its employees to ensure
that they perform their jobs safely and in
accordance with your source's safety
' procedures, ,
•Ensure its employees know process hazards
and applicable emergency actions. The
contractor must assure that contract employees
are aware of hazards and emergency procedures
relating to 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
1910.119(h)(2)(vi)).
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/CM A- Managers Guide to Implementing a Contractor Safety Program
•- (RP 2221),- American Petroleum Institute.
+ Improving Owner and Contractor Safety Performance (RP 2220), American
, Petroleum Institute.
October 27, 1998
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Chapter 7
Prevention Program (Program 3) 7-24
APPENDIX 7-A
PHA TECHNIQUES
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This appendix provides descriptions of each of the PHA techniques listed in the OSHA PSM
standard and § 68.67. These descriptions include information on what each technique is, which types of
processes they may be appropriate for, what their limitations are, and what level of effort is typically
associated with each. This information is based on Guidelines for Hazard Evaluation Procedures, 2nd
Ed., published by AIChE/CCPS. If you are interested in more detailed discussion and worked examples,
you Should refer to the AIChE/CCPS volume. ........
., .=.,., ,..'., „ »,'. , ' „, _ ..; .. :.
Neither the information below nor the full AIChE/CCPS volume will provide you with enough
information to conduct a PHA. The rule requires that your PHA.team include at least one person trained in
the technique you use. Training in PHA techniques is available from a number of organizations. If you
must conduct multiple PHAs, you are likely to need to update your PHAs frequently, or you have a
complex process that will take several weeks to analyze, you may want to consider training one or more of
your employees. If you have a single process that is unlikely to change more than once every five years,
you may find it more cost-effective to hire a trained PHA leader.
DESCRIPTIONS OF TECHNIQUES
'1 il, " ' • , ' , "jjii.! , „,'-•;.'. •,!,,,, • , • , '
CHECKLISTS
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), propane facilities subject to NFPA-58. Checklists are easy to use and can help
familiarize new staff with the process equipment. AIChE/CCPS states that checklists are a highly
cost-effective way to identify customarily recognized hazards. Checklists are dependent on the experience
of the people who develop them; if the checklist is not complete, the analysis may not identify hazardous
situations.
Checklists are created by taking the applicable standards and practices and using them to generate
a list of questions that seek to identify any differences or deficiencies. If a checklist for a process does not
exist, an experienced person must develop one based on standards, practices, and facility or equipment
experience. A completed checklist usually provides "yes," "no," "not applicable," and "need more
information" answers to each item. A checklist analysis involves touring the process area and comparing
equipment to the list.
AIChE/CCPS estimates that for a small or simple system a checklist will take 2 to 4 hours to
prepare, 4 to 8 hours to evaluate the process, and 4 to 8 hours to document the results. For larger or more
complex processes, a checklist will take 1 to 3 days to prepare, 3 to 5 days to evaluate, and 2 to 4 days to
document.
Examples of checklists are given in Chapter 6, Appendix 6-A.
October 27,1998
" .'i, , „ , in ,i mill. i i,"i n > i ,'1. • Hi "'1,,'iiir, ".:'•; lillii ', "'.m M! i ,; •" , ,,,,u. 'I'/iV vfii',!,'1 ,!, ,i,' •• " " ir ' '' ,„''',.,•!', i. ;i ,, i : .in.!1! I1.*' ; ,, „,'„!,
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• Chapter?
7-25 Prevention Program (Program 3)
WHAT-IF
'rfi-V .... '
'- - \ :
A What-If is a brainstorming approach in which a group of people familiar with the process ask
questions about possible deviations or failures. These questions may be framed as What-If, as in "What if
the pump fails?" or may be expressions of more general concern, as in "I worry about contamination during
unloading." A scribe or recorder takes down all of the questions on flip charts or a computer. The
questions are then divided into specific areas of investigation, usually related to consequences of interest.
Each area is then addressed by one or more team members.
What-If analyses are intended to identify hazards, hazardous situations, or accident scenarios. The '
team of experienced people identifies accident scenarios, consequences, and existing safeguards, then
suggest possible risk reduction alternatives. The method can be used to examine deviations from design,
construction, modification, or operating intent. It requires a basic understanding of the process and an
ability to combine possible deviations from design intent with outcomes.. AIChE describes this as a
powerful procedure if the staff are experienced; "otherwise, the results are likely to be incomplete."
A What-If usually reviews the entire process, from the introduction of the chemicals to the end.
The analysis may focus on particular consequences of concern. AIChE provides the following example of .
a What-If question: "What if the raw material is the wrong concentration?" The team would then try to
determine how the process would respond: "If the concentration of acid were doubled, the reaction could
not be controlled and a rapid exotherm would result." The team might then recommend steps to prevent
feeding wrong concentrations or to stop the feed if the reaction could 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. .
Examples of What If questions are given in Chapter 6, Appendix 6-A.
WHAT-IF/CHECKLIST
A What-If/Checklist combines the creative, brainstorming aspects of the What-If with the
systematic approach of the Checklist. The combination of techniques can compensate for the weaknesses -
of each. The What-If part of the process can help the team identify hazards and accident scenarios that are
beyond the experience of the team members. The checklist provides a more detailed systematic approach
that can fill in gaps in the brainstorming process: The technique is generally used to identify the most
common hazards that exist in a process. AIChE states that it is often the first PHA conducted on a process,
with subsequent analyses using more detailed approaches. ,
The purpose of a What-If/Checklist is to identify hazards and the general types of accidents that
could occur, evaluate qualitatively the effects of the effects, and determine whether safeguards are
adequate. Usually the What-If brainstorming precedes the use of the checklist, although the order can be
reversed. . ,
The technique usually is performed by a team experienced in the design, operation, and
maintenance of the process. The number of people required depends on the complexity of the process.
October 27, 1998 " . .
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.Chapter?
Prevention Program (Program 3) 7-26
AIChE/CCPS estimates that for a small or simple system a What-If/Checklist analysis will take 6 to 12
hours to prepare, 6 to 12 hours to evaluate the process, and 4 to 8 hours to document the results. For larger
or rnofe complex processes, a What-lf/Checklist will take 1 to 3 days to prepare, 4 to 7 days to evaluate,
and 1 to 3 weeks to document.
See Chapter 6 for a further discussion of What If/Checklists.
;• , 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.
1 .i/' "' • :> .".'fe!1 V ' :;l- .' y: ' ''.'' i;1. "••;;!.'•'•••'•.;;'.•' • / '•'• :: . v "•• , ' . ••
The purpose of a HAZOP is to review a process or operation systematically to identify whether
process deviations could lead to undesirable consequences. AIChE states that the technique can be used
for continuous or batch processes and can be adapted to evaluate written procedures. It can be used at any
stage in the life of a process.
HAZOPs usually require a series of meetings in which, using process drawings, the team
systematically evaluates the impact of deviations. The team leader uses a fixed set of guide words and
applies them to process parameters at each point in the process. Guide words include "No," "More,"
"Less," "Part of," "As well as," Reverse," and "Other than." Process parameters considered include flow,
pressure, temperature, level, composition, pH, frequency, and voltage. As the team applies the guide
words to each process step, they record the deviation, with its causes, consequences, safeguards, and
actions needed, or the need for more information to evaluate the deviation.
HAZOPs require more resources than simpler techniques. AIChE states that a simple process or a
review with a narrow scope may be done by as few as three or four people, if they have the technical skills
and experience. A large or complex process usually requires a team of five to seven people. AIChE/CCPS
estimates that for a small or simple system a HAZOPf 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 \
See Chapter 6 for a further discussion of HAZOPs.
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."
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,
October 27,1998
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Chapter?
7-27 Prevention Program (Program 3)
•for each item of equipment, includes a description, a list of failure modes, the effects of each failure,
safeguards that exist, and actions recommended to address the failure. For example, for pump operating
normal, the failure modes would include fails to stop when required, stops when required to run, seal leaks
or ruptures, and pump case leaks or ruptures.. The effects would detail both the immediate effect and the
impact on other equipment. Generally, when analyzing impacts, analysts assume that existing safeguards
do not work.
An FMEA requires an equipment list or P&ID, knowledge of the equipment, knowledge of the
system, and responses to equipment failure. AIChE states that on average, an hour is sufficient to analyze
two to four pieces of equipment. AIChE/CCPS estimates that for a small or simple system an FMEA will
take 2 to 6 hours to prepare, 1 to 3 days to evaluate the process, and 1 to 3 days to-document the results.
For larger or more complex processes, an FMEA will take 1 to 3 days to prepare, 1 to 3 weeks to evaluate,
and 2 to 4 weeks to document.
FAULT TREE ANALYSIS (FTA)
, - ' " • • ' ' f ' •
A Fault Tree Analysis (FTA) is a deductive technique, that focuses on a particular accident or main
system failure and provides a method for determining causes of the event. The fault tree is a graphic that
displays the combinations of equipment failures and human errors that can result in the accident. The FTA
starts with the accident and identifies the immediate causes. Each immediate cause is examined to
determine its causes until the basic causes of each are identified. AIChE states that the strength of FTA is
its ability to identify combinations of basic equipment and human failures that can lead to an accident,
allowing the analyst to focus preventive measures on significant basic causes.
AIChE states that FTA is well suited for analyses of highly redundant systems. For systems
vulnerable to single failures that can lead to accidents, FMEA or HAZOP are better techniques to use.
FTA is often used when another technique has identified an accident that requires more detailed analysis.
The FTA looks at component failures (malfunctions that require that the component be repaired) and faults
(malfunctions that will remedy themselves once the conditions change). Failures and faults are divided
into three groups: primary failures and faults occur when the equipment is operating 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, .
'October27, 1998 ' . ' ,
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Chapter 7
Prevention Program (Program 3)
7-28
Cause-Consequence Analysis, Event Tree Analysis, and Human Reliability Analysis. You may also
develop a hybrid technique that combines features of several techniques or apply more than one technique.
Selecting a Technique
Exhibit 7A-1 is adapted from the AIChE Guidelines and indicates which techniques are
appropriate for particular phases in a process's design and operation.
EXHIBIT 7A-1
APPLICABILITY OF PHA TECHNIQUES
R&D
Design
Pilot Plant Operation
Detailed Engineering
Construction/Start-Up
Routine Operation
Modification
Incident Investigation
Decommissioning
Checklist
/
/
/
^
/
^
/
What-If
S
S
s
s
s
s
s
s
s
What-If-
Checklist
S
^
/
/
S
S
s
HAZOP
^
S
^
/
/
FMEA
/
S
S
s
s
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 carf be handled with
checklists,
''••' ' '"'!, . •, '• • ' • • i-< ... , i <" '' •" ; : • • •'• • '• i " • '•
' '.•; 1 '• '• ' . '|! •: •.' ,:!''••. ' •'..'.' '',<•: \-,- ' \\ "•''".• V ''••.'•, , i;;:V. '' '•. • • ', '
Analysis of multiple failure situations is best handled by FTA. Single-failure techniques, such as
HAZOP and FMEA, are not normally used to handle these although they can be extended to evaluate a
few simple accident situations involving more than one event.
•' " 'I!' .'"''''" i „" • ' "'" " '' it "i' ' ' ' • ,,," , 'i ' ,. w1' i "'" " • v"1 .'i./ :: i 'i ',''"' . ,i" , , . •!". , . i . , •
CAlChE 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.
October 27,1998
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7-29
; • Chapter 7
Prevention Program (Program 3)
A final factor in selecting a technique is time required for various techniques. Exhibit 7A-2
summarizes AIChE's estimates of the time required for various steps. The full team is usually involved in
the evaluation step; for some techniques, only the team leader and scribe are involved in the preparation
and documentation steps. •
EXHIBIT7A-2
TIME AND STAFFING FOR PHA TECHNIQUES
• , -
Checklist
What-If
What-If
Checklist
HAZOP
FMEA
FTA
Simple/Small System
# Staff
Preparation
Modeling
Evaluation
Documentation
1-2 .
2-4 h
4-8 h
. 4-8 h
2-3 '.
4-8 h
1-3 d
1-2 d
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.
l-3w
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)
October 27, 1998
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II III
-------
CHAPTER 8: EMERGENCY RESPONSE PROGRAM
If you have at least one Program 2 or Program 3 process at your facility, then part 68
may require you to implement an emergency response program, consisting of an
emergency response plan, emergency response equipment procedures, employee
training, and procedures to ensure the program is up-to-date. This requirement applies
if your employees will respond to some releases involving regulated substances. (See
the box on the next page for more information on What is Response?)
EPA recognizes that, in some cases (particularly for small operations with few
employees), it may not be appropriate for employees to conduct response operations
for releases of regulated substances. For example, it would be inappropriate, arid
probably unsafe, for a WWTP with only one full-time employee at a site to expect that
a tank fire could be handled without the help of the local fire department or other
emergency responder. EPA does not intend to force such facilities to develop
emergency response capabilities. At the same time, you are responsible for ensuring
effective emergency response to any releases at your facility. If your local public
responders are not capable of providing such response, you must take steps to ensure
1 that effective response is available (e.g.; by hiring response contractors).
8.1 NON-RESPONDING FACILITIES (§ 68.90(b))
EPA has adopted a policy for non-responding facilities similar to that adopted by
OSHA in its Hazardous Waste Operations and Emergency Response (HAZWOPER)
Standard (29 CFR 1910.120), which allows certain facilities to develop an emergency
action plan (29 CFR 1910.38(a)) to ensure employee safety, rather than a full-fledged
emergency response plan. (Note that EPA adopted HAZWOPER by reference for any
state or local facility not subject to OSHA rules (40 CFR part 311). If your employees
will not respond to accidental releases of regulated substances, then you need not
comply with the emergency response plan and program requirements. Instead, you are
simply required to coordinate with local response agencies to ensure that they will be
prepared to respond to an emergency at your facility. (You may want to briefly review
the.program design issues discussed in 8.2 prior to making this decision.) This will
help to ensure that, your community has a strategy for responding to and mitigating the '
threat posed by a release of a regulated substance from your facility. Coordination
with local responders entails the following steps: -
Ensure that you have set up a way to notify emergency responders
when there is need for a response.
If you have a covered process with a regulated toxic, work with the
local emergency planning entity to ensure that the facility is included
in the community emergency response plan prepared under EPCRA
regarding a response to a potential release.
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Emergency Response Program
8-2
If you have a covered process with a regulated flammable (e.g.,
methane), work with the local fire department regarding a response to
a potential release.
Although you do not need to describe these activities in your risk management plan, to
document your efforts you should keep a record of:
-Vi" • : ' " .,' •. •' •' "' • - '•']''; . ' •.'',' ", ,'""' :' ' ""' , I -•••.'
The emergency contact (i.e., name or organization and number) that
you will call for a toxic or flammable release, and
What is "Response"?
EPA interprets "response" to be consistent with the definition of response specified under OSHA's
HAZWOPER Standard. OSHA defines emergency response as "a response effort by employees from
outside the immediate release area or by other designated responders ... to an occurrence which results,
or is likely to result, in an uncontrolled release of a hazardous substance." The key factor here is that
responders are designated for such tasks by their employer. This definition excludes "responses to
incidental releases of hazardous substances where the substance can be absorbed, neutralized, or
otherwise controlled at the time of release by employees in the immediate release area, or by
maintenance personnel" as well as "responses to releases of hazardous substances where there is no
potendal safety or health hazard (i.e., fire, explosion, or chemical exposure)." Thus, if you expect your
employees to take action to end a small leak (e.g., shutting a valve) or clean up a spill that does not
pose an immediate safety or health hazard, this action could be considered an incidental response and
you would not need to develop an emergency response program if your employees are limited to such
activities.
However, due to the nature of the regulated substances subject to EPA's rule, only the most minor
incidents would be included in this exception. In general, most activities will qualify as a response due
to the immediacy of the dispersion of a toxic plume or spread of a fire, the volatilization of a spill, and
the threat to people on and off site. As a result, if you will have your employees involved in any
substantial way in responding to releases, you will need to develop an emergency response program.
Your emergency response procedures need only apply to "response" actions; other activities will be
described in your maintenance and operating procedures.
The organization that you worked with on response procedures.
The remainder of this chapter is applicable only to those WWTPs that will conduct a
more extensive level of response operations. As noted above, you may want to review
the next section before making a decision on whether the facility will take
responsibility for conducting any response activities.
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8-3
Chapters
Emergency Response Program
8.2 ELEMENTS OF AN EMERGENCY RESPONSE PROGRAM (§ 68.95)
• ,\-;- • , , ...
If you will respond to releases of regulated substances with your own employees, your
emergency response program must consist of the following elements:
An emergency response plan (maintained at the facility) that includes:
: Procedures for informing the public and emergency response agencies
about releases,
Documentation of proper first aid and emergency medical treatment
necessary to treat human exposures, and
Procedures and measures for emergency response.
What is a Local Emergency Planning Committee?
.' ~ •
Local emergency planning committees (LEPCs) were formed under the Emergency Planning and
Community Right-to-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
yourLEPC. ,
Procedures for usingy 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 III). In addition, at the request of local emergency planning or
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Chapter 8
Emergency Response Program 8-4
response officials, .you must provide any information necessary for developing and
implementing the community plan.
In keeping with the approach outlined in Chapter 6, EPA is not requiring facilities to
document training and maintenance activities. However, as noted above, facilities
must maintain an pn-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
program, EPA has limited the provisions of its rule to those the CAA mandates. If
you have a regulated substance on site, you are already subject to at least one
emergency response rule: OSHA's and EPA's HAZWOPER requirements, which are
identical. Under HAZWOPER, any facility that handles "hazardous substances" (a
broad term that includes all of the CAA section 112(r) regulated substances and thus
applies to all facilities with covered processes) must comply with either 29 CFR
1910.38(a) (emergency action plan) or 1910.119(q) (HAZWOPER). If you have a
hazmat team, you are subject to the 29 CFR 1910.il 9(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.
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. „ ''•'•' f ..... • . . *
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.
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8-5
, • Chapters
Emergency Response Program
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 OSHA or EPA HAZWOPER
Standard. HAZWOPER covers preparing an emergency response plan, employee
training, medical monitoring of employees, recordkeeping, and other issues. Call your
state or federal district OSHA office (see the list in Appendix D) for more information
on complying with the HAZWOPER Standard. State and local governments in states
without a delegated OSHA program are subject to HAZWOPER under EPA's 40 CFR
part 311. ,
Exhibit 8-1
Federal Guidance on Emergency Planning and Response
Hazardous Materials Emergency Planning Guide (NRT-1), National Response Team, March 1987.
Although designed to assist communities in planning for hazmat incidents, this guide provides useful
information on developing a response plan, including planning teams, plan review, and ongoing
planning efforts. ,
Criteria for Review of Hazardous Materials Emergency Plans (NRT-1 A), National Response Team,
May 1988. This guide provides criteria for evaluating response plans.
Integrated Contingency Plan, National Response Team, (61 FR 28642,' June 5, 1996). This provides
guidance on how,to consolidate multiple plans developed to comply with various federal regulations
into a single, functional emergency response plan..
North American Emergency Response Guidebook (NAERG96), UlS. Department of Transportation,
1996. ^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. .
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Emergency Response Program
8-6
How Does the Emergency Response Program Apply?
The requirements for the emergency response program are intended to apply across all covered
processes at a facility. Although certain elements of the program (e.g., how to use specific items of
response equipment) may differ from one process to another, EPA does not intend or expect you to
develop a separate emergency response program for each covered process. With this in mind, you
should realize that your emergency response program will probably apply to your entire facility,
although technically it need only apply to covered processes.
For example, a facility may have two storage tanks, one containing slightly more than a threshold
quantity of a regulated substance and one with slightly less. The facility is likely to adopt the same
response approach (e.g., procedures, equipment, and training) for releases whether or not the process is
"covered." Similarly, a facility may have two adjacent flammables storage tanks, one containing a
regulated substance above the threshold and the other containing another, unlisted flammable. The
facility is likely to adopt the same approach for releases whether or not the process is "covered."
8.3 DEVELOPING AN EMERGENCY RESPONSE PROGRAM
The development of an emergency response program should be approached
systematically. As described in section 8,2, all facilities complying with these
emergency response program provisions will already be subject to OSHA
HAZWOPER. As a result, you are likely to fall into one of two groups:
You have already met several federal requirements for emergency
planning and are interested in developing an integrated program to
minimize duplication (section 8.4).
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.
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:
Maintenance;
Operations or line personnel;
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8-7 Emergency Response Program
- Upper and line management (for POTWs this may include governing
boards);
Legal;
Fire and hazmat response;
Environmental, health, and safety affairs;
Training;
Security;
EPCRA section 302 emergency coordinator (if one exists);
Public relations; and
Human resources. ,
Of course, the membership of the team will need to be more or less extensive
depending on the scope of the emergency response program. A three-member team
. may be appropriate for a small facility with a couple of process operators cross-trained
as fire responders, while a facility with its own hazmat team and environmental affairs
department may need a dozen representatives.
Collect relevant facility documents. Members of the development team should
collect and review all of the following:
. Site plans;
Existing emergency response plans and procedures;
Submissions to the LEPC under EPCRA sections 302 and 303;
Hazard evaluation and release modeling information;
Hazard communication and emergency response training;
Emergency drill and exercise programs;
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: - ' ,
Corporate- and industry-sponsored safety, training, and planning
efforts; and ', " •
Federal, state, and local government safety, training, and planning
efforts (see Exhibit 8-2).
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8-8
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-.21;
EPA's Risk Management Programs Regulation - 40 CFR part 68;
OSHA's Emergency Action Plan Regulation - 29 CFR 1910.38(a);
OSHA's Process Safety Standard - 29 CFR 1910.119;
OSHA's HAZWOPER Regulation - 29 CFR 1910.120;
OSHA's Fire Brigade Regulation - 29 CFR 1910.156;
EPA's Resource Conservation and Recovery Act Contingency Planning Requirements - 40
CFR part 264, Subpart D, 40 CFR part 265, Subpart D, and 40 CFR 279.52.
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).
EPA's Storm water Regulations - 40 CFR 122.26.
Facilities may also be subject to state and local planning requirements.
Determine the status of each required program element. Using the information
collected, you should assess whether each required program element (see section 8.2)
is: ] ., i,
In place and sufficient to meet the requirements of part 68;
In place, but not sufficient to meet the requirements of Part 68; or
i]iii ,i • • , ' i
Not in place.
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.
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8-9 Emergency Response Program
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:
Identify and characterize the hazards for each covered process. Most
. WWTPs will have the potential for toxic-releases, fires, and
explosions.
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.
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.
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.
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
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';!1 ' '!: |; • ' ''
Chapters
Emergency Response Program _ 8-10
usei by facilities to prepare emergency response plans for responding to releases of oil
iand 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 §|e 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.
'" [ ' ' i.' ..... '" " ' ' ""n i ' \ ..... •
As shown in Exhibit 8-3, the ICP format is organized into three main sections: an
introductory section, a core plan, and a series of supporting annexes. The notice
published in the Federal Register explains the intended structure of the ICP and
provides detailed annotation. EPA's EPCRA/RCRA/Superfund Hotline can supply
you with a copy and answer general questions about the guidance; for further
information and guidance on complying with specific regulations, you should contact
the appropriate federal agencies.
AN APPROACH To INTEGRATION
•i ' ....... • . > ' . • r: ....... :' • •• • ' •' ..•,„;...•.'• i ,
Like many other facilities, you may have opted to develop and maintain separate
documents and procedures for each federal emergency planning requirement.
However, meeting the Clean Air Act emergency response requirements provides you
with the opportunity to integrate several existing programs. Integrating the various
emergency response efforts you conduct (both those mandated by management and by
government) will increase the usefulness of your emergency preparedness activities
and decrease the burden associated with maintaining multiple programs. Integration
will improve your chances to respond effectively to a release by streamlining your
training and eliminating overlaps and conflicts in the roles and responsibilities of your
employees under different programs. However, it is important to note that, although
you are encouraged to integrate your emergency response efforts, it is not a
requirement of the Clean Air Act.
If you have multiple emergency response programs,, you should consider integrating
them .into a single program with procedures for responding ;to your most likely release
scenarios. The ICP Guidance discussed above provides comparison matrices for a
number of federal programs that will help you accomplish the following:
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8-11 Emergency Response Program
Distinguish the individual regulatory provisions with which you must
comply, and '• ^
Identify where an integrated effort can meet the requirements of two or
more regulations.
.. The requirements of various emergency jresponse programs may be Similar, but the
subtle differences between requirements will likely determine the degree to which .
integration is a feasible and beneficial undertaking. To help you identify the relevant
rules and regulations, the ICP Guidance provides section-by-section regulatory
citations for each emergency response program element for each of the regulatory
programs listed in Exhibit 8-2.
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 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 below.
Keep in mind: At a minimum, your plan must describe:
Your procedures for informing the public and offsite emergency
. response agencies of a release. This must include the groups and
individuals that will be contacted and why, the means by which they
will be contacted, the time frame for notification, and the information
, that will be provided.
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8-12
Exhibit 8-3
integrated Contingency Plan Outline
Section I - Plan Introduction Elements
1. Purpose and Scope of Plan Coverage
2. Table of Contents
3. Current Revision Date
4. General Facility Identification Information
a. Facility name ' . .
b. Owner/operator/agent (include physical and mailing address and phone number)
c. Physical address of the facility (include county/parish/borough, latitude/longitude, and directions)
d. Mailing address of the facility (correspondence contact)
e. Other identifying information (e.g., ID numbers, SIC Code, oil storage start-up date) .
f. Key contact(s) for plan development and maintenance
g. Phone number for key contact(s)
h. Facility phone number
I. Facility fax number
Section II - Core Plan Elements
1, Discovery
2. Initial Response
a. Procedures for internal and external notifications (i.e., contact, organization name, and phone number
of facility emergency response coordinator, facility response team personnel, federal, state, and local
officials)
b. Establishment of a response management system
c. Procedures for preliminary assessment of the situation, including an identification of incident type,
hazards involved, magnitude of the problem, and resources threatened
d. Procedures for establishment of objectives and priorities for response to the specific incident,
including:
(1) Immediate goals/tactical planning (e.g., protection of workers and public as priorities)
(2) Mitigating actions (e.g., discharge/release control, containment, and recovery, as appropriate)
(3) Identification of resources required for response
e. Procedures for implementation of tactical plan
f. Procedure for mobilization of resources . .
3. Sustained Actions
4. Termination and Follow-Up Actions
Section in - Annexes
Annex 1. Facility and Locality Information
a. Facility maps
b. Facility drawings • '
c. Facility description/layout, including identification of.facility hazards and vulnerable resources and
populations on and off the facility which may be impacted by an incident
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8-13 Emergency Response Program'
Exhibit 8-3 (continued)
Annex 2. Notification
a. Internal notifications
b. Community notifications
c. Federal and state agency notifications
Annex 3..Response Management System
a. General
b. Command
c. Operations •
d. _ Planning
e. Logistics .
f. Finance/procurement/administration
Annex 4. Incident Documentation , '
a. Post accident investigation
b. Incident history
Annex 5. Training and Exercises/Drills
Annex 6. Response Critique and Plan Review and Modification Process
Annex 7. Prevention
Annex 8. Regulatory Compliance and Cross^Reference Matrices
The proper first aid and emergency medical treatment for employees,
first responders, and members of the public who may have been
exposed to a release of a regulated substance. This must include
. standard safety precautions for victims (e.g., apply water to exposed
skin immediately) as well as more detailed information for medical
professionals. You must also indicate who is likely to be responsible
for providing the appropriate treatment: an employee, an employee
with specialized training, or a medical professional.
Your procedures for emergency response in the event of a release of a
regulated substance. This must include descriptions of the actions to
be taken by employees and other individuals on-site over the entire
course of the release event:
Activation of alarm systems and interpretation of signals;
Safe evacuation, assembly, and return;
Selection of response strategies and incident command structure;
Use of response equipment and other release mitigation activities; and
Post-release equipment and personnel cleanup and decontamination.
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Chapter S
Emergency Response Program 8-14
PLANNING COORDINATION
One of the most important issues in an emergency response program is deciding which
response actions will be assigned to employees and which will be handled by offsite
personnel. As a result, talking to public response organizations will be critical when
you develop your emergency response procedures. Although EPA is not requiring you
to be able to respond to a release alone, you should not simply assume that local
responders will be able to manage an emergency. You must work with them to
determine what they can do, and then expand your own abilities or establish mutual
aid agreements or contracts to handle those situations for which you lack the
appropriate training or equipment.
If you have already coordinated with local response agencies on how to respond to
potential releases of regulated substances arid you have ensured an effective response,
you do not need to take any further action.
••*i •,, • •• •"•'•' r..''' ;.' ;.'••,..':•. ! <' „; i:;/.. •/•• ' ' ,v, :• [ ' '•
Keep in mind: Your coordination must involve planning for releases of regulated
substances from all covered processes and must cover:
What offsite response assistance you will require for potential release
scenarios, including fire-fighting, security, and notification of the
public;
- , , ' i. i. ' ,•' '',"", - i
How you will request offsite response assistance; and
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.
, ''',,!;!' ' '''s.i1 , ' . ' ' i.,, ,,,,.!, j1 ' . '„,,-" s ,"', 1, ' •' i ' '
Keep in mind: Your procedures must apply to any emergency equipment relevant to a
response involving a covered process, including all detection and monitoring
equipment, alarms and communications systems, and personal protective equipment
not used as part of normal operations (and thus not subject to the prevention program
requirements related to operating procedures and maintenance). The procedures must
describe:
How and when to use the equipment properly;
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Chapters
8-15 Emergency Response Program
How and when the equipment should receive routine maintenance; and
. How and when the equipment should be inspected and tested for
readiness.
1 / , • ~
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 hew 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:
If they will only need to evacuate, then their training should cover
when and how to evacuate their location.
If they may need to activate an alarm system in response to a release
event, then their training should cover when and how to use the alarm
system. •
If they will serve on an emergency response team, then their training
should cpVer how to use emergency equipment and how the incident
command system works. ,-
Emergency response training conducted in compliance with the HAZWOPER
Standard and 29 CFR 1910.38 will'be considered sufficient to meet this requirement.
RESPONSE PLAN EVALUATION
If you 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.
Keep in mind: You must also identify the types of changes to the facility that would
cause the plan to be updated (e.g., a new covered process) and include a method .of
communicating any changes to the plan to your employees (e.g., through training or
safety meetings). You may want to set up a regular schedule on which you review
your entire emergency response plan and identify any special conditions (e.g., a drill
or exercise) that could result in an interim review.
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Emergency Response Program 8-16
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 the 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
If you have any of the toxic regulated substances above the threshold quantity, you
must have already designated[anemergency coordinator to work with the LEPC on
chemical emergency preparedness issues (a requirement for certain facilities regulated
under EPCRA). If you have not (e.g., if your facility has only regulated flammable
substances), you may want to do so at this time. The emergency coordinator should
be the individual most familiar with your emergency response program (e.g., the
person designated as having overall responsibility for this program in your
management system — see Chapter 5).
Involvement in the activities of your LEPC can have a dramatically positive effect on
.your emergency response program, as well as on your relationship with the
surrounding community. Your LEPC can provide technical assistance and guidance
on a number of topics, such as conducting response training and exercises, developing
, mutual aid agreements, and evaluating public alert systems. The coordination process
will help both the community and the facility prepare for an emergency, reducing
expenditures of time and money, as well as helping eliminate redundant efforts.
You should consider providing the LEPC with draft versions of any emergency
response program elements related to local emergency planning efforts. This
submission can initiate a dialogue with the community on potential program
improvements and lead to coordinated training and exercise efforts. In return, your
LEPC can support your emergency response program by providing information from
its own emergency planning efforts, including:
Data on wind direction and weather cpnditions, or access to local
meteorological data, to help you make decisions related to the
evacuation of employees and public alert notification;
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, Chapters
8-17 Emergency Response Program
Lists of emergency response training programs available in the area for
training police, medical, arid fife department personnel, to help you
identify what training is already available;
Schedules of emergency exercises designed to test the community
response plan to spur coordinated community-facility exercises;
Lists of emergency response resources available from both public and
, private sources to help you determine whether and how a mutual aid
agreement could support your program; and
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,
this information may not be as up-to-date or as comprehensive. Remember, the LEPC
has been given the authority under EPCRA and Clean Air Act regulations to request
any information necessary for preparing the community response plan.
Planning for Flammable Substances
In the case of regulated flammable substances, the fire department with jurisdiction over your facility, '
may already be conducting fire prevention inspections and pre-planning activities under its own
authority. Your participation 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 in your area, you may need to contact other local response or planning
officials (e.g., police) to determine how you can work with the community.
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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: ,-
June 21,1999; '
The date on which a regulated substance is first present above a threshold
quantity in a process; or .
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, will
be available in January 1999.
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:
An executive summary (§ 68.155);
The registration for the facility (§ 68.160);
- The certification statement (§68.185);
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));
The five-year accident history for each process (§ 68.168); and
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 cover
all regulated flammabies 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). • "' , ' , ' '
Suljpait G of part 68 (see Appendix A) provides more detail on the data required for
eacji.of the elements. The actual RMP form, however, will contain 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 will pro vide a list of options for you to check for these elements. Except for the
executive summary, the RMP will consist 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™ will provide "pick
lists" to help yeu complete the form. For example, RMP*Submit™ will provide a list
of regulated substances and automatically fill in the CAS numbers when you select a
substance.
EPA will provide instructions for each of the data elements to be reported in the RMP
with RMP*Submit™. The instructions will explain each data element and help you
understand what acceptable data are for each. The instructions will be made available
with the software and will be posted on EPA's web site.
9.2 RMP SUBMISSION
ELECTRONIC SUBMISSION
By January 1999, EPA will make RMP*Submit™ available to complete and file your .
RMP. RMP*Submit™ will dp the following:
" . ' ' tili , , " " "; !' ' , • ,' ' ii1 " ,^ ,.";,, i '" ," • '" 1 • ' " i
Provide a user-friendly, PC-based RMP Submission System available on
diskettes and via the Internet;
Use a standards-based, open systems architecture so private companies can
create compatible software; and
Perform date.quality checks, accept limited graphics, and provide on-line help
including defining data elements and providing instructions.
The software will run on Windows 3.1 and above. There will not be a DOS or MAC
version.
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9-3 __ Risk Management Plan
Further details on this system will be made available as the system is completed.
RMPs will be submitted td an EPA RMP Record Center on disk.
HARD COPY SUBMISSION
If you are unable to submit electronically for any reason, just fill out the Electronic
Waiver fonn available in me RMP*SubmitTM manual and send it in with your RMP.
See the RMP*Submit manual for more information on the Electronic Waiver. .,
9.3 RESUBMISSION AND UPDATES (§68.190)
When you are required to update and resubmit your RMP is based on whether and
what changes occur at your facility. Please refer to the Exhibit 9-1 and note that you
are required to update and resubmit your RMP on the earliest of the dates that apply
to your facility:
WHEN DOES THE OFFSITE CONSEQUENCE ANALYSIS (OCA) NEED TO BE REVISED?
. f ••.•'.."••,
You'll need to revise your OCA when a change at your facility results in the distance
to an endpoint from a worst-case release rising or falling by at least a factor of two.
For example, if you increase your inventory substantially or install passive mitigation
, to limit the potential release rate, you should re-estimate the distance at an endpoint.
If the distance is at least doubled or halved, you must revise the RMP. For most
substances, the quantity that would be released would have to increase by more than a
factor of five to double the distance to an endpoint.
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.
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9-4
EXHIBIT 9-1
RMP UPDATES
Change That Occurs at Your Faculty
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
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Chapter 9
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Q&A
"REVISING" A PHA
Q. The rule states that I have to update my RMP whenever I revise a PHA. What constitutes a
revised PHA? Every time I go through management of change procedures I make a notation in the
PHA file for the process, but would that constitute a revised PHA if the change did not affect the
validity of the PHA? ,
A. All changes (except replacement in kind) are subject to the management of change of procedures.
.When processes undergo minor changes (e.g., minor rerouting of a piping run), information is
typically added to a PHA file to reflect the change, even though the validity of the PHA is not affected
by the modification. These minor changes and the addition of information about the change to the
PHA file are not considered a 'revision' of the PHA under the part 68. JMajor 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,
subpartE. 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 Appendix
C 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 me state's rules differ
from part 68 (a state's rales 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 states in which EPA has delegated part 68. •-
Should EPA decide that it is necessary to take an enforcement action in the state, the
action would be based on the state rale that EPA has adopted as a substitute for part
68. Similarly, citizen actions under the CAA would be based on the state rales that
EPA has adopted. , . . •,
Under 40 CFR 63.90, EPA will not delegate the authority to add or delete substances
from § 68.130. EPA also plans to propose, in revisions to part 63, that authority to
revise Subpart G (relating to RMPs) will not be delegated. With respect to RMPs, you
, would continue to be required to file your part 68 RMP, in the form .and .manner
specified by EPA, to the central location EPA designates. You should check with
your state to determine whether you need to file additional data for state use or submit
amended copies of the RMP with the state to cover state elements or substances.
If your state has been granted delegation, it is important that you contact them to
determine if the state has requirements in addition to those in part 68. State rules
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10-2
may be more stringent than part 68. This document does not cover state
requirements.
QS&AS
DELEGATION
Q. What states have been granted delegation or are in the process of seeking delegation?
A. Georgia has been granted delegation. The following states have indicated that they are interested
in delegation:
California Delaware Florida
Missouri New Jersey Nevada
South Carolina
Hawaii Louisiana Mississippi
North Carolina Ohio . Rhode Island
Check with your EPA Regional contacts (see Appendix C) for a current list of states granted or seeking
delegation.
Q. In what ways may state rules be more stringent? Does this document provide guidance on state
differences?
A. States may impose more detailed requirements, such as requiring more documentation or more
frequent reporting, specifying hours of training or maintenance schedules, imposing equipment
requirements or call for additional analyses. Some states are likely to cover at least some additional
chemicals and may use lower thresholds. This document does not cover state differences.
Q. Will the general duty clause be delegated?
A. The general duty clause (CAA section 112(r)(l)) is not included in part 68 and, therefore, will not
be delegated. States, however, may adopt their own general duty clause under state law.
10.2 REVIEWS/AUDITS/INSPECTIONS (§68.220)
The implementing agency is required under part 68 to review and conduct audits of
RMPs. Reviews are relatively quick checks of the RMPs to determine whether they
are complete and whether they contain any information that is clearly problematic.
For example, if an RMP for a process containing flammables fails to list fire and
explosion as a hazard in the prevention program, me 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 oh any of the following criteria, set out in §
68.220:
Accident history of the facility
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10-3 Implementation
Accident history of other facilities in the same industry
Quantity of regulated substancis handled at the site
Location of the facility and its proximity to public and environmental
receptors : '
The presence of specific regulated substances
The hazards identified in the RMP
A plan providing for random/neutral oversight
WHAT ARE AUDITS AND How MANY WILL BE CONDUCTED?
**
Under the CAA and part 68, audits are conducted on the RMP. Audits will generally
be reviews of the RMP to review its adequacy and require revisions when necessary to
ensure compliance with part 68. Audits will help identify whether the underlying risk
management program is being implemented properly. The implementing agency will
look for any inconsistencies in the dates reported for compliance with prevention
program elements. For example, if you report that the date of your last revision bf
operating procedures was in June 1998 but your training program was last reviewed or
revised in December 1994, the implementing agency will ask why the training
program was not reviewed to reflect new operating procedures.
The agency will also look at other items that may indicate problems with
implementation. For example, if you fail to list an appropriate set of process hazards
for the process chemicals, the agency may seek further explanations as to why you
reported in the way you did. The implementing agency may compare your data with
that of other facilities in the same industrial sector using the same chemicals to
identify differences that may indicate compliance problems.
If audits indicate potential problems, they may lead to requests for more information
or to on-site inspections. If the implementing agency determines that problems exist,
it will issue a preliminary determination listing the necessary revisions to the RMP, an
explanation of the reasons for the revisions, and a timetable. Section 68.220 provides
details of the administrative procedures for responding to a preliminary determination.
The number of audits conducted will vary from state to state and from year to year.
Neither the CAA nor part 68 sets a number or percentage of facilities that must be
audited during a year. Implementing agencies will set their own goals, based on their
resources and particular concerns.
WHAT ARE INSPECTIONS?
'••••.. ' ' i.
Inspections are site visits to check on the accuracy of the RMP data and on the
implementation of all part 68 elements. During inspections, the implementing agency
will probably review the documentation for rule elements, such as the PHA reports,
operating procedures, maintenance schedules, process safety information, and
training. Unlike audits, which focus on the RMP but may lead to determinations
concerning needed improvements to the risk management program, inspections will
focus on the underlying risk management program itself. . , ' '
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Implementation > 10-4
Implementing agencies will determine how many inspections they need to conduct.
Audits may lead to inspections or inspections may be done separately. Depending on
the focus of the inspection (all covered processes, a single process, or particular part
of the risk management program) and the size of the facility, inspections may take
several hours to several weeks.
10.3 RELATIONSHIP WITH TITLE V PERMIT PROGRAMS
Part 68 is an applicable requirement under 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 must:
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 of part 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. WWTPs may require air permits; check with the environmental compliance
officer for your facility.
The RMP and supporting documentation are not part of the permit and should not be
submitted to the permitting authority. The permitting authority is only required to
ensure that you have submitted the RMP and that it is complete. The permitting
authority may delegate this review of the RMP to other agencies.
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 ,
• « '' ' ' ' - ' - ' , i • '. >
10.4 PENALTIES FOR NON-COMPLIANCE
Penalties for violating the requirements or prohibitions of part 68 are set forth in CAA
section 113. This section provides for both civil and criminal penalties. EPA may
assess civil penalties of not more than $27,500 per day per violation. Any one
convicted of knowingly violating part 6_8 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 ho more than two years.
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Chapter 10
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•,.'•'• ' " . QS&AS • ' ' : /.
AUDITS
Q. If we are a Voluntary Protection Program (VPP) facility under OSHA's VPP program, are we
exempt from audits?
A. You are exempt from audits based on accident history of your industry sector or on random,
neutral oversight. An implementing agency that is basing its auditing strategy on other factors may
include your facility although EPA expects that VPP facilities will generally not be a high priority for
audits unless they have a serious accident.
Q. If we have been audited by a qualified third party, for ISO 14001 certification or for other
programs, are we exempt from audits?
A. No, but you may want to inform your implementing agency that you have gained such certification
and indicate whether the third party reviewed part 68 compliance as part of its audit. The
implementing agency has the discretion to determine whether you should be audited.
Q. Will we be audited if a member of the public requests an audit of our facility?
A. The implementing agency will have to decide whether to respond to such public requests. EPA's
intention is that part 68 implementation reflect that hazards are primarily a local concern.
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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, I^ocal Emergency Planning Committees (LEPCs), State Emergency
Response Commissions (SERCs), other local and state officials, and other interested
parties. . j .
Communication with the public can be an opportunity to develop your relationship
with the community and build a level of trust among you, your neighbors, and the
community at large. By complying with the RMP rule, you are taking a number of
steps to prevent accidents and protect the community. These steps are the individual
elements of your risk management program. A well-designed and properly
implemented risk management program will set the stage for informative and
productive dialogue between you and your community. The purpose of this chapter is
, to suggest how this dialogue may occur. In addition, note that some industries have
developed guidance and other materials to assist in this process;'contact your trade
association for more information.
11.1 BASIC RULES OF RISK COMMUNICATION
Risk communication means establishing and maintaining a dialogue with the public
about the hazards at your operation and discussing the steps that have been or can be
taken to reduce the risk posed by these hazards. Of particular concern under this rule
are the hazards related to the chemicals you use and what would happen if you had an
accidental release. . . _
Many companies, government agencies, and other entities have confronted the same
" • •- . issue you may face: how to discuss with the public the risks the community is subject
to. Exhibit 11-1 outlines seven "rules" of risk communication that have been
developed based on many experiences of dealing with the public about risks.
A key message of these "rules" is the importance and legitimacy of public concerns.
People generally are less tolerant of risks they cannot control than those they can. For
example, most people are willing to accept the risks of driving because they have
some control over what happens to them. However, they are generally more
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Communication with the Public 11-2
uncomfortable accepting the risks of living near a facility that handles hazardous
chemicals if they feel that they have no control over whether the facility has an
accident. The Clean Air Act's provision for public availability of RMPs gives public
an opportunity to take part in reducing the risk of chemical accidents that might occur
in their community.
Exhibit 11-1: Seven Cardinal Rules of Risk Communication
1. Accept and involve the public as a legitimate partner
2. Plan carefully and evaluate your efforts
3. Listen to the public's specific concerns
4. Be honest, frank, and open
5. Coordinate and collaborate with other credible sources
6. Meet the needs of the media
7. Speak clearly and with compassion
HAZARDS VERSUS RISKS
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).
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 offsite, 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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Chapter 11
11-3 Communication with the Public
The rule does not require ypu to assess risk in a quantitative way because, in most
cases, the data you would fieed to estimate risk levels (e.g., one in 100 years) are not
available. Even in cases where data such as equipment failure rates are available,
there are large uncertainties in using that data to determine a numerical risk level for
your facility, because your facility is probably not the same as other facilities, and your
situation may be dynamic. Therefore, you may want to assign qualitative values (high,
-': medium, low) to the risks that you have identified at your facility, but you should be
prepared to explain the terms if you do. For example, if you believe that the
worst-case release is very unlikely to occur, you must give good reasons; you must be
able to provide specific examples of measures that you have taken to prevent such a
release, such as installation of new equipment, careful training of your workers,
rigorous preventive maintenance, etc. You should also be able to show documentation
to support your claim. ,
WHO WILL ASK QUESTIONS?
Your Local Emergency Planning Committee (LEPC) and other facilities can help you
identify individuals in the following groups who may be reviewing RMP data and
asking questions. Interested parties may include:
• (1) Persons living near the facility and elsewhere in the community or working at
a neighboring facility
(2) Local officials from zoning and planning boards, fire and police departments,,
health and building code officials, elected officials, and various county and
state officials
(3) Your employees
(4) Special interest groups including environmental organizations, chambers of
commerce, unions, and various civic organizations
(5) Journalists, reporters, and other media representatives
(6) Medical professionals, educators, consultants, neighboring companies and
others with special .expertise or interests "
In general, people will be concerned about accident risks at your'facility, how you
manage the risks, and potential impacts of an accident on health, 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 in your RMP is available to
the public, it is likely that people will want additional information. Interested
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Communication with the Public 11-4
parties will know that you retain additional information at your facility (e.g.,
documentation of the results of the offsite consequence analysis reported in your
RMP) and are required to make it available to EPA or its implementing agency during
inspections or compliance audits. Therefore, they may request such information.
EPA encourages you to provide public access to this information. If EPA or its
implementing agency were to request this information, it would be available to the
public under section 114(c) of the CAA.
The public may also be interested in other information relevant to risk management at
your facility, such as:
Submissions under sections 302, 304, 311-312, and 313 of the Emergency
Planning and Community Right to Know Act (EPCRA) reporting on chemical
storage arid releases, as well as the community emergency response plan
prepared under EPCRA section 303
Other reports on hazardous materials made, used, generated, stored, spilled,
released and transported, that you submitted to federal, state, and local
agencies
Reports on workplace safety and accidents developed under the Occupational
Safety and Health Act that you provide to employees, who may choose to
make the information publicly available, such as medical and exposure
records, chemical data sheets, and training materials
Any other information you have provided to public agencies that can be
accessed by members of the public under the federal Freedom of Information
Act and similar state laws (and that may have been made widely available
over the Internet)
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, for
- example
11.2 SAMPLE QUESTIONS FOR COMMUNICATING WITH THE PUBLIC
Smaller businesses may not have the resources or time to develop the types of
outreach programs, described later in this chapter, that many larger chemical
companies have used to handle public questions and community relations. For many
small businesses, communication with the public will usually occur when you are
asked questions about information in your 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
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11-5 Communication with the Public
them. These are elements of the public dialogue that you may anticipate. The person
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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Communication with the Public
11-6
What Does Your Worst-case Release Distance Mean?
The distance is intended to provide an estimate of the maximum possible area that might be affected
under catastrophic conditions. It is intended to ensure that no potential risks to public health are
overlooked, but the distance to an endpoint estimated under worst-case conditions should not be
considered a "public danger zone."
In most cases, the mathematical models used to analyze the worst-case release scenario as defined in
the rule may overestimate the area that would be impacted by a release. In other cases, the models
may underestimate the area. For distances greater than approximately six miles, the results of toxic
gas dispersion models are especially uncertain, and you should be prepared to discuss such
possibilities in an open, honest manner.
Reasons that modeling may underestimate the distance generally relate to the inability of some
models to account for site-specific factors that might tend to increase the actual endpoint distance.
For example, assume a facility is located in a river valley and handles dense toxic gases such as
chlorine. If a release were to occur, the river valley could channel the toxic cloud much farther than it
might travel if it were to disperse 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 easel and you can offer to provide additional information or) those scenarios.
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11-7
Chapter 11
Communication with the Public
What does it mean that we could be exposed if we live/work/shop&o to school
X miles away?
\ - ''.-... ' .
(For an accident involving a flammable substance):
The distance means that people who are in that area around the facility could be hurt if the contents of
a tank or other vessel exploded. The blast of the explosion could shatter windows and damage
buildings. Injuries would be the result of the force of the explosion and of flying glass or falling
debris. .
(For an accident involving a toxic substance): , ..: .
The distance is based on-a concentration of the chemical that you could.be exposed to for an hour
without suffering irreversible health effects or other symptoms that would make it difficult for you to
escape. If you are within that distance, you could be exposed to a greater concentration of the
chemical. If you were exposed to higher levels for an extended period of time (10 minutes, 30
minutes, or longer), you could be seriously hurt. However, that does not mean that you would be.
Remember, for worst case scenarios, the rule requires you to make certain conservative assumptions
with respect to, for example, wind speed and atmospheric stability. If the wind speed is higher than
that used in the modeling, or if the atmosphere is more unstable, a chemical release would be •
dispersed more quickly, and the distances would be much smaller and the exposure times would be
shorter. If the question pertains to an alternative release scenario, you probably assumed typical
weather conditions in the modeling. Therefore, the actual impact distance could be shorter or longer,
and you should be prepared to acknowledge this and clearly explain how you chose the conditions for
your release scenario.
In general, the possibility of harm depends on the concentration of the chemical you are exposed to
and the length of time you are exposed. ,
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Communication with the Public
11-8
IF THERE IS AN ACCIDENT, WILL EVERYONE WITHIN THA T DISTANCE BE HURT? WHA T
ABOUT PROPERTY DAMAGE?
In general, no. For an explosion, everyone within the circle would certainly feel the blast wave since
it would move in all directions at once. However, while some people within the circle could be hurt, it
is unlikely that everyone would be since some people would probably be in less vulnerable locations.
Most injuries would probably be due to the'effects of flying glass, falling debris, or impact with .
nearby objects.
Two types of chemicals may be modeled - toxics and flammables. Releases of flammables do not
usually lead to explosions; released flammables are more likely to disperse without igniting. If the
released flammable does ignite, a fire is more likely than an explosion, and fires are usually
concentrated at the facility.
For toxic chemicals, whether someone is hurt by a release depends on many factors. First, the released
chemicals would usually move in the direction of the wind (except for some dense gases, which may
be constrained by terrain features to flow in a different direction). Generally, only people downwind
from the facility would be at risk of exposure if a release occurred, and this is normally only a part of
the population inside the circle. If the wind speed is moderate, the chemicals would disperse quickly,.
and people would be exposed to lower levels of the chemical. If the release is stopped quickly, they
might be exposed for a very short period time, which is less likely to cause injury. However, if the
wind speed is low or the release continues for a long time, exposure levels will be higher and more
dangerous. The population at risk would be a larger proportion of the total population inside the
circle. You should be prepared to discuss both possibilities.
Generally, it is the people who are closest to the facility — within a half mile or less — who would
face the greatest danger if an accident occurred. ,
Damage to property and the environment will depend on the type of chemical released. In an
explosion, environmental impacts and property damage may extend beyond the distance at which
injuries could occur. For a vapor release, environmental effects and property damage may occur as a
result of the reactivity or corrosivity of the chemical or toxic contamination.
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11-9
, ' Chapter 1 i
Communication with the Public
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
assumptipns 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 of ten. 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 this guidance document, 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 pwn 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 onrsite 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 & 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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CotniTiumcatipn with the Public
11-10
WHA TARE YOU DOING TO PREVENT RELEASES?
If you have rigorously implemented your risk management program, this question will be your chance,
if you have not already done so, to tell the community about your prevention activities, the safe design
features of your operations, the specific activities that you are performing such as training, operating
procedures, maintenance, etc., and any industry codes or standards you use to operate safely. If you
have installed new equipment or safety systems, upgraded training, or had outside experts review your
site for safety (e.g., insurance inspectors), you could offer to share the results. You may also want to
mention state or federal rules you comply with.
WHAT ARE You DOING To PREPARE FOR RELEASES?
For such questions, you will need to talk about any coordination that you have done with the local fire
department, LEPC, or mutual aid groups. Such coordination may include activities such as defining
an incident command structure, developing notification protocols, conducting response training and
exercises, developing mutual aid agreements, and evaluating public alert systems. This description is
particularly important if your employees are not designated or trained to respond to releases of
regulated substances.
If your employees will be involved in a response, you should describe your emergency response plan
and the emergency response resources available at the facility (e.g., equipment, personnel), as well as
through response contractors, if appropriate. You also may want to indicate the types of events for
which such resources are applicable. Finally, indicate your schedule for internal emergency response
training and drills and exercises and discuss the results of the latest relevant drill or exercise, including
problems found and actions taken to address them.
DO YOU NEED TO USE THIS CHEMICAL ?
Again, if you have not yet considered the feasibility of switching to a non-hazardous substitute, you
should do so when you develop your risk management program. Assuming that there is no substitute,
you should describe why the chemical is critical to what you produce and explain what you do to
handle it safely. If there are substitutes available, you should describe how you have evaluated such
options:
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•11-11
Chapter 11
Communication with the Public
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.
At normal temperatures, experiments indicate that methane is very unlikely to explode; cold methane
explodes more readily. Digester gas, which is usually at normal temperatures, is .therefore unlikely to
explode.
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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Chapter 11
Communication with the Public
11-12
/S THE WORST-CASE RELEASE YOU REPORTED REALL Y THE WORST ACCIDENT YOU CAN HA VE?
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 chlorine in
small containers such as 150-pound cylinders, 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 cylinders than a
single cylinder as a result, for example, of the cylinders 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.
WHA T ABOUT THE ACCIDENT A T THE [NAME OF SIMILAR FACILITY] THA T 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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11-13
Chapter 11
Communication with the Public
WHA T ACTIONS HA VE YOU TAKEN TO INVOL VE 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,
SERC, and regional mutual aid organizations if you aren't doing so already. Other opportunities for
community involvement are fire safety coordination activities with the local fire department, joint
training and exercises with local public and private sector response personnel, the establishment of
green fields between the facility and the community, and similar efforts.
When discussing accident prevention and emergency planning with the community, you should ~
indicate any national programs in which you participate, such as the Chemical Manufacturers
Association's Responsible Care program or Community Awareness and Emergency Response
program or OSHA's Voluntary Protection Program. If fully implemented, these programs can help
improve the safety of the facility and the community. You may have future plans to participate in
areas described previously or have new initiatives associated with the risk management program. Be
sure you ask what else the community would like you to do and explain how you will do it.
CAN WE SEE THE DOCUMENTATION YOU KEEP ON SITE?
If the requested information is not confidential business information, EPA encourages you to make it
available to the public. Although you are not required to provide this information to the public,
refusing to provide it simply because you are not compelled to is not the best approach. If you decide
not to provide any or most of this material, you should have good reasons for not doing so and be
prepared to explain these reasons to the public. Simply taking a defensive position or referring to the
extent of your legal obligations is.likely to threaten the effectiveness of your interaction with the
community. Offer as much information as possible to the public; if particular documents would reveal
proprietary information, try to provide a redacted copy, summary, or some other form that answers the
community's concerns. You may want to work with your LEPC on this issue. You should also be
aware that information that EPA or the implementing agency obtains as part of an inspection or
investigation conducted under section 114 of the Clean Air Act would be available to the public under
section 114(c) of the Act to the extent it does not reveal confidential business information.
11.3 COMMONiCATION ACTIV5TIES 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
October 27, 1998
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Chapter II
Communication with the Public 11-14
the : public. To prepare for effective communication with ithe community, you should:
i-iiiKj ;; •; ^ ' y'ljji'i1 » ''• ,', j,1!1!'11 ^ ;| '"''; ^ j",,'1:; ','!' ; * „» '. i,,! -., \ ; ' > r ,: ..... ;"',i ^lii,'"1 i , ''"'",• ,, , „<
(1) Adopt an organizational policy that includes basic risk communication
principles (see exhibit 1 1-1)
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(2) Assign responsibilities and resources to implement the policy
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(3) Plan to use "best communication practices"
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ADOPT AN ORqANIZATIONAU CQMMgNICATlQNS
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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
Qf any risk cornmunication'program.
ASSIGN RESPONSIBILITIES AND RESOURCES
A policy is only a paper promise until it is regularly and effectively implemented.
Tlius, you should follow up your communication policy by (1) having top
majkgement participate at the outset arid at key points throughout the communication
process, and (2) assigning communication responsibilities within your organization
ami providing the necessary resources.
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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 anci even tends to incur mistrust. (However, if you hired a firm with
aclqiowledged expertise in dispersion modeling, you may want them on hand to help
respond to technical questions.)
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materials, hold meetings with interested persons in the community, and do other work
necessary to re'spb'hcl to questions and concerns and ^ maintain ongoing dialogue.
October 27,1998
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'•/..' Chapter 11
11-15 Communication with the Public
A training program in communication skills and incentives for good performance also
may be advisable. " :'•
Organizations have a legitimate interest in preventing disclosure of confidential
business information or statements that inadvertently and unfairly harm the
organization or its employees. Thus, you should assure that your risk communication
staff is instructed on how to deal with situations that pose these problems. This may
mean that you have an internal procedure enabling your staff to bring such situations
to top management and legal counsel for quick resolution, keeping in mind that '
unduly defensive or legalistic responses that result in restricting.the amount of
information that is provided can damage or destroy the risk communication process.
Your communication staff may find the following steps helpful in addressing the
priority issues in the communication process:
Prior to RMP Submittal
Enlist employee support for, and involvement in, the communication process
Build on work you have done with your LEPC, fire department, and local
officials, and gain their insights . . .
Incorporate technical expertise, management commitment, and employee
involvement in the risk communication process
Use your RMP's executive summary to begin the dialogue with the
community; be sure you Have taken all of the steps you present
Taking a community perspective, identify which data elements need to be
clarified, interpreted, or amplified, and which are most likely to raise
community concerns; then compile the information needed to respond and
determine the most understandable methods (e.g., use of graphics) for.
presenting the information
At Submittal ;
Review the RMP to assure that you are familiar with its data elements and
how they were developed. In particular, review the hazard assessment,
prevention, and response program features, as well as documentation of the
methods, data, and assumptions used, especially if an outside consultant
- performed the analyses and developed these materials. You have certified
their accuracy and your spokesperson should know them intimately, as they
reflect your plan ..'--.
Review your performance in implementing the prevention and response
programs and prepare to discuss problems identified and actions taken ,
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Chapter 11
Communication with the Public 11-16
Review your performance in investigating accidents and prepare to discuss
any corrective actions that followed
Other Steps
Identify the most likely concerns about risks identified in the RMP but not
fully addressed, consult with management and safety engineering, and
determine additional measures the organization will take to resolve these
concerns
. Avoid misrepresentations and minimize the roles of public relations
specialists
Identify "best communication practices" (as described in the next section) and
plan how to use them
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USE "BEST COMMUNICATION PRACTICES"
Many facilities already have gained considerable experience in communicating with
the gublic.Lessons from their experiences are described below. However, the value
of these best practices arid your credibility will depend on your facility's possession
and ongoing demonstration of certain essential qualities:
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Top management commitment (e.g., owner and facility manager) to
improving safety
Honesty, openness, and concern for the community
Respect for public concerns and perceptions
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
Commitment to continuous improvement through internal procedures for
evaluating incidents and promoting organizational learning
Knowledge of safety issues and safety management methods
Good working relationships with the LEPC, fire department, and other local
officials' -
Active support for the LEPC and related activities
Employee support and commitment
' Continuation of commitment despite potential public hostility or mistrust
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Chapter 11
11-17 Communication with the Public
Another note: Because each facility and community involves a unique combination of
factors, the practices used to achieve food risk communication in one case do not
necessarily ensure the same quality result when used in-another case. Therefore, while
it is advisable for you to review such experience to identify "best communication
practices," you should carefully evaluate such practices to determine if they can be
adapted to fit your unique circumstances. For example, if your facility is in the middle
of an urban area, you probably will use different approaches than you would use if it
were located in an industrial area far from any residential populations. These
practices are complementary approaches to delivering your risk management message
and responding to the concerns of the community.
With these cautions in mind, a number of "best" practices are outlined below for
consideration. First, you will want to establish formal channels for
information-sharing and communication with stakeholders. The most basic
approaches include: ,
Convene public meetings for discussion and dialogue regarding your risk
management program and RMP and take steps to have the facility owner or
manager and all sectors of the community participate, including minorities
and low-income residents
Arrange meetings with local media representatives to facilitate their
understanding of your risk management program and the program summary
presented in your RMP
Establish a repository of information on safety matters for the LEPC and the
public and, if electronic, provide software for public use. Some organizations
also have provided computer terminals for public use in the community
library or fire department .
Other, more resource-intensive activities of this type to consider include:
Create and convene, focus groups (small working groups) to facilitate dialogue
and action on specific concerns, including technical matters, and take steps to
assure that membership in each group reflects a cross section of the
community and includes technically trained persons (e.g., engineers, medical
professionals) , .
Hold seminars on hypothetical release scenarios, prevention and response
programs, applicable standards and industry practices, analytic methods and
models (e.g., on dispersion of airborne releases, health effects of airborne
concentrations), and other matters of special concern or complexity
Convene special meetings to foster dialogue and collaborations with the
LEPC and the fire department and to establish a mutual assistance network
with other facility managers in the community or region
October 27, 1998
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Chapter 11
Communication with the Public 11-18
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
i1 ,'
In all of these efforts, remember to use plain language and commonly understood
terms; avoid the use of acronyms and technical and legal jargon. In addition,
depending on your audience, keep in mind that the preparation of multilingual
materials may be useful or even necessary.
Secondly, you may want to initiate or expand programs that more directly involve the
community in your operations and safety programs. Traditional approaches include:
Arrange facility tours so that members of the public can view operations and
discuss safety procedures with supervisors and employees '
Schedule drills and simulations of incidents to demonstrate how prevention
, and response programs work, with participation by community responders and
other organizations (e.g., neighboring companies)
Conduct a "Safety Street" - a community forum generally sponsored by
several industries in a locality, where your representatives present facility
safety information, explain risks, and respond to public questions (see Section
11.4 for a reference to more information on this program)
Periodically reaffirm and demonstrate your commitment to safety in
accordance with and beyoncl 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
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:
Invite public participation in monitoring implementation of your risk
management program elements
Invite public participation in auditing your performance in safety
responsibilities, such as chemical handling and tracking procedures and
'analysis and follow-up on accidents and near misses
Organize a committee comprised of representatives from the facility, other
industry, emergency planning and response organizations, and community
groups and chaired by a community leader to independently evaluate your
safety and communication efforts (e.g., a Community Advisory Panel). You
may also want to finance the committee to pay for an independent engineering
October 27j 1998
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Chapter 11
11-19 Communication with the Public
consultant to assist with technical issues and learn what can be done to
improve safety, arid thereby share control with the community
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 RJVIP 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:
Improving Risk Communication, National Academy Press, Washington, D.C.
1989
"Safety Street" and other materials on the Kanawha Valley Demonstration
• Program, Chemical Manufacturers Association, Arlington, VA
Community Awareness and Emergency Response Code of Management
Practices and various Guidance, Chemical Manufacturers Association,
Arlington, VA " v
Communicating Risks to the Public, R. Kasperson and P. Stallen, eds.,
Kluwer Publishing Co., 1991 ' • >
. , "Challenges in Risk and Safety Communication with the Public," S. Maher,
Risk Management Professionals, Mission Viejo, CA, April 1996
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
October 27, 1998
-------
Chapter 11
Communication with the Public
11-20
Risk Communication about Chemicals in Your Community: A Manual for
Local Officials, US Environmental Protection Agency, EPA
EPCRA/Superfundy^CRA7CAA Hotline
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/Superfund/RCRA/CAA Hotline
October 27,1998
-------
Appendix A
40CFRpart68
-------
§67.43
40 CFR Ch. I (7-1-96 Edition)
shall be paid to the State or local
agent.
t
§67.43 Procedure where a formal
State hearing was held.
(a) In reviewing a penalty calculation
for which a hearing conforming to
§67.11(b)(4) was held, the Administrator
may invite comment on issues identi-
fied by him as relevant to his review
and shall propose or make findings as
to the correctness of the determination
arid shall evaluate the accuracy and
adequacy of the material transmitted
pursuant to § 67.11 (b) (5).
(b) The Administrator shall notify all
participants in the State hearing of his
findings and conclusions. If the Admin-
istrator finds that the State deter-
mination conformed to the require-
ments of the Act. part 66 (as modified
by §67.11), the Technical Support Docu-
ment, and the Instruction Manual, his
determination shall constitute a final
action pursuant to section 120. If the
Administrator finds that the State de-
termination did not conform to the re-
quirements of the Act or of part 66 "(as
modified by §67.11) or to the Technical
Support Document, or Instruction Man-
ual, the findings shall constitute pro-
posed findings, and the notice shall in-
vite participants to file exceptions to
his proposed findings and, if necessary,
schedule a time for argument.
(c) Within 60 days of receipt of any
briefs or exceptions or after oral argu-
ment,the Administrator shall affirm,
rnbdify, or revoke his proposed findings
that the State or local agent's deter-
mination, cScl not conform to the re-
quirements of the Act or of part 66 (as
modified by §67.11) or the Technical
Support Document or Instruction Man-
ual. TJie decision shall be in writing.
Notice and a copy of the decision,
which shall constitute final .adminis-
trative action by EPA pursuant to sec-
tion 120, shall be provided to the source
owner or 'operator' and to all other par-
ticipants in the State hearing.
(d) If the Administrator finds that
deficiencies in the State or local
agent's hearing record prevent him
from determining whether the State or
local agent's determination conformed
to the requirements of the Act and part
66 (as modified by §67.11) or the Tech-
nical Support Document or Instruction
Manual, he shall notify the State or
local agent of his decision and specify
what dificiencies exist and schedule a
hearing in accordance with subpart F
of part 66. Such notice shall operate to
withdraw EPA's delegation of author-
ity to the State or local agent over the
facility in question unless the State or
local agent within. 15 days schedules a
supplemental hearing to correct the de-
ficiencies.
(e) Unless otherwise provided in the
Administrator's notice to the State or
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.
1212
•^ • .• •( ;
-------
Environmental Protection Agency
§68.2
68.28 Alternative release scenario analysis.
68.30 Defining offsite impacts population.
68.33 Defining offsite impacts environment.
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 pf change.
68.77 Pre-startup review.
68.79 Compliance audits.
68.81 Incident investigation.
68.83 Employee participation.
68.85 Hot work permit.
68.87 Contractors.
Subpart E—Emergency Response
68.90 Applicability.
68.95 Emergency response program.
Subpart F—Regulated Substances for
Accidental Release Prevention
68.100 Purpose.
68.115 Threshold determination.
68.120 Petition process.
68.125 Exemptions.
68.130 List of substances.
Subpart G—Risk Management Plan
68.150 Submission.
68.155 Executive summary.
68.160 Registration.
68.165 Offsite consequence analysis.
68.168 Five-year accident history.
J58.170 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)(l).
7661-7661f.
SOURCE: 59 FR 4493. Jan. 31. 1994. unless
otherwise noted.
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-
gated under this part do not limit in
any way the general duty provisions
under section 112(r)(l).
•§ 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.
(1) In Sec. 68.3, the definition of "sta-
tionary source," to the extent that
such definition includes naturally oc-
curring hydrocarbon reservoirs or
transportation subject to oversight or
regulation under a state natural gas or
hazardous liquid program for which the
state has in effect a certification to
DOT under 49 U.S.C. 60105;
(2) Section 68.115(b)(2) of this part, to
the .extent that such provision requires
an owner or operator to treat as a regu-
lated flammable substance:
(i) Gasoline, when in distribution or
related storage for use as fuel for inter-
nal combustion engines;
(ii) Naturally occurring hydrocarbon
mixtures prior to entry into a petro-
leum refining process unit or a natural
gas processing plant. Naturally occur-
ring hydrocarbon mixtures include any
of the following: cpndensate, 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
1213
-------
§68.3
40 CFR Ch. I (7-1-96 Edition)
s'i if'!!
': iji
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
for the Identification of the Fire Haz-
ards of Materials, National Fire Pro-
tection Association, Quincy, MA, 1990,
available from the National Fire Pro-
tection Association, 1 Batterymarch
Park, Quincy, MA 02269-9101; and
(3) Section 68.130(a).
(b) From March 2, 1994 to December
22, 1997, the following definitions shall
apply to the stayed provisions de-
scribed in paragraph (a) of this section:
Condensate means hydrocarbon liquid
separated from natural gas that con-
denses because of changes in tempera-
ture, pressure, or both, and remains
liquid at standard conditions.
Crude oil means any naturally occur-
ring, unrefined petroleum liquid.
Field gas means gas extracted from a
production well before the gas enters a
natural gas processing plant.
Natural gas processing plant means
any processing site engaged in the ex-
traction of natural gas liquids from
field gas, fractionation of natural gas
liquids to natural gas products, or
both. A separator, dehydration unit,
heater treater, sweetening unit, com-
pressor, or similar equipment shall not
be considered a "processing site" un-
less such equipment is physically lo-
cated within a natural gas processing
plant (gas plant) site.
Petroleum refining process unit means
a process unit used in an establishment
primarily engaged in petroleum refin-
ing as defined in the Standard Indus-
trial Classification code for petroleum
refining (2911) and used for the follow-
ing: Producing transportation fuels
(such as gasoline, diesel fuels, and jet
fuels), heating fuels (such as kerosene,
fuel gas distillate, and fuel oils), or lu-
firicants; 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, alkylatibri units, catalytic
hydrotreating, catalytic hydrorefining,
catalytic hydrocracking, catalytic re-
forming, catalytic cracking, crude dis-
tillation,lube oil processing, hydrogen
production" isbmerization, 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.
[59 FR 4493, Jan. 31, 1994, as amended at 61
FR 31731. June 20. 1996]
§ 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 Agency.
AIChE/CCPS means the American In-
stitute of Chemical Engineers/Center
for Chemical Process Safety.
API means the American Petroleum
Institute.
Article means a manufactured item,
as defined under 29 CFR 1910.1200(b),
that is formed to a specific shape or de-
sign during manufacture, that has end
use functions dependent in whole or in
part upon the shape or design during
end use, and that does not release or
otherwise result in exposure to a regu-
lated substance under normal condi-
tions of processing and use.
ASME means the American Society
of Mechanical Engineers.
CAS means the Chemical Abstracts
Service.
Catastrophic release means a major
uncontrolled emission, fire, or explo-
sion, involving one or more regulated
substances that presents imminent and
substantial endangerment to public
health and the environment.
Classified information means "classi-
fied information" as defined in the
Classified Information Procedures Act,
18 U.S.C. App. 3, section l(a) as "any
information or material that has been
determined by the United States Gov-
ernment pursuant to an executive
order, statute, or regulation, to require
1214
-------
Environmental Protection Agency
§68.3
protection against unauthorized disclo-
sure for reasons of national security."
Covered process means a process that
has a regulated substance present in
more than a threshold quantity as de-
termined under §68.115.
Designated agency means the state,
local, or Federal agency designated by
the state under the provisions of
§ 68.215(d) . .
DOT means the United States De-
partment of Transportation. >
. Environmental receptor means natural
areas such as national or state parks,
forests, or monuments; officially des-
ignated wildlife sanctuaries, preserves,
refuges, or-areas; and Federal wilder-
ness areas, that could be exposed at
any time to toxic concentrations, radi-
ant heat, or overpressure greater than
or equal to the endpoints provided in
§68.22 (a) , as a result of an accidental
release and that can be identified on
local U. S. Geological Survey maps.
Hot work means work involving elec-
tric or gas welding, cutting, brazing, or
similar flame or spark-producing oper-
ations.
Implementing agency means the state
or local agency that obtains delegation
for an accidental release prevention
program under sufapart E, 40 CFR part
63. The implementing agency may, but
is not required to, be the state or local
air permitting agency. If no state or
local agency is granted delegation,
EPA will be the implementing agency
for that state.
Injury means any effect on a human
that results either from direct expo-
sure to toxic concentrations; radiant
heat; or overpressures from accidental
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 public or the environment. Passive
mitigation means equipment, devices,
or technologies that function without
human, mechanical, or other energy
input. Active mitigation means equip-
ment, devices, or technologies that
need human, mechanical, or other en-
ergy input to function.
NFPA means the National Fire Pro-
tection Association. .
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.
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.
Population means the public.
Process means any activity involving
a regulated substance including any
use, storage, manufacturing, handling,
or on-site movement of -such sub-
stances, or combination of these activi-
ties. For the purposes of this defini-
tion, any group of vessels that are
interconnected, or separate vessels
that are located such that a regulated
substance could be involved in a poten-
tial release, shall be considered a sin-
gle process. -
Public means any person except em-
ployees or contractors at the station-
ary 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
1215
-------
§68.10
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., i , •
RMP means the risk management
plan required under subpart G of this
part.
SIC means Standard Industrial Clas-
sification.
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. A stationary source
includes transportation containers
that are no longer under active ship-
ping papers and transportation con-
tainers that are connected to equip-
ment at the stationary source for the
purposes of temporary storage, loading,
or unloading. The term stationary
source does not apply to transpor-
tation, including the storage incident
to transportation, of any regulated
substance or any other extremely haz-
ardous substance under the provisions
of this part, provided that such trans-
portationis regulated under 49 CFR
parts 192. 193. or 195. Properties shall
not be considered contiguous solely be-
cause of a railroad or gas 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 arnended, listed in
§68.130 and determined to be present at
a stationary source as specified in
§68.115 of this part.
Typical meteorological conditions
mea'ns 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.
40 CFR Ch. I (7-1-96 Edition)
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]
EFFECTIVE DATE NOTE: At 61 FR 31717, June
20. 1996. §68.3 was amended by adding the
definitions for Act, Administrative controls,
AIChE/CCPS, API. ASME. Catastrophic release.
Classified information. Covered process. Des-
ignated agency. Environmental receptor, Hot
work, Implementing agency. Injury, Major
change. Mechanical integrity, Medical treat-
ment. Mitigation or mitigation system, NFPA.
Offsite. OSHA, Population, Public, Public re-
ceptor. Replacement in kind, RMP, SIC, Typical
meterological conditions, and Worst-case re-
lease, effective Aug. 19,1996.
§68.10 Applicability. _
(a) An owner or operator of a station-
ary 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
1216
-------
Environmental Protection Agency
§68.12
and §68.25 is less than the distance to
any public receptor, as defined in
§68.30; and
(3) Emergency response pro9edures
have been coordinated between the sta-
tionary source and local emergency
planning and response organizations.
(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 follow-
ing conditions is met:
(1) The process is in SIC code 2611,
2812, 2819, 2821, 2865, 2869, 2873, 2879, or
2911; 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.
[61 FR 31717, June 20. 1996]
, EFFECTIVE DATE NOTE: At 61 FR 31717. June
20. 1996. §68.10 was added, effective Aug. 19,
1996. • •
§ 68.12 General requirements.
(a) General requirements. The, owner
or operator of a stationary source sub-
ject to this part shall submit a'single
RMP, as provided in §§68.150 to 68.185.
The RMP shall include a- registration
that reflects all covered processes.
(b) Program 1 requirements. In addi-
tion to, meeting the requirements of
paragraph (a) of this section, the owner
or 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
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;
(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 jpre-
vention steps provided in §§68.65
through 68.87;
(4) Develop and implement an emer-
gency response program as provided in
§§68.90 to 68.95; and
(5) Submit as:part of the RMP .the
data on prevention program elements
for Program 2 processes as provided in
§68.170.
1217
-------
i'i "liifii
is*''
§68.15
(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
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)
EFFECTIVE DATE NOTE: At 61 FR 31718. June
20. 1996. S 68.12 was added, effective Aug. 19.
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. 1996J
EFFECTIVE DATE NOTE: At 61 FR 31718, June
20. 1996, §68,15 was added, effective Aug. 19.
1996. ' ,
Subpart B—Hazard Assessment
, 11 in «, ' |. , hi; i' i ,< • , " '<',«,
Ijllll'l In ' I" I' ' . Ml ." ' I" '
SOURCE: 61 FR 31718. June 20. 1996, unless
otherwise noted.
EFFECTIVE DATE NOTE: At 61 FR 31718. June
20. 1996, suopart B was added, effective Aug.
19.1996.
40 CFR Ch. I (7-1-96 Edition)
§68.20 Applicability.
The owner or operator of a station-
ary source subject to this part shall
prepare a worst-case release scenario
analysis as provided in §68.25 of this
part and complete the five-year acci-
dent history as provided in §68.42. The
owner or operator of a Program 2 and 3
process must comply with all sections
in this subpart for these processes.
§68.22 Offsite consequence analysis
parameters.
(a) Endpoints. For analyses of offsite
consequences, the following endpoints
shall be used:
(1) Toxics.' The toxic endpoints pro-
vided in appendix A of this part.
(2) Flammables. The endpoints for
flammables vary according to the sce-
narios studied:
(i) Explosion. An overpressure of 1
psi.
1 (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 analy-
sis, 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 tninimums
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
RMF> 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
1218
'"'*
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Environmental Protection Agency
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.
(e) Surface roughness. The owner or
operator 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 refrig'eration
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
endpoint 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
endpoint defined in §68.22(a) resulting
§68.25
from an accidental release of regulated
flammable substances from covered
processes under worst-case conditions
defined in §68.22; and
. (iii) Additional worst-case release
, scenarios for a hazard class if a worst-
case release from another covered proc-
ess at the stationary source potentially
affects public receptors different from
those potentially affected by the worst-
case release scenario developed under
paragraphs (a)(2)(i) or (a)(2)(ii) of this
section.
(fa) Determination of worst-case release
quantity. The worst-case release quan-
tity shall be the greater of the follow-
ing:
(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
1219
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lit
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-
:;' j ' , 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.
(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
thre? 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 opera-
tor 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—
flammables^ The owner or operator shall
assume that the quantity of the sub-
stance^ as Setermined under paragraph
(b) of this" section, vaporizes resulting
in a vapor cloud explosion. A yield fac-
40 CFRCh. I (7-1-96 Edition)
'. !,.' ' : '.' .:'"' •'';,; '.'•"• , • ', ' i'X ''',.•••''•,
tor of 10 percent of the available en-
ergy released in the explosion shall be
used to determine the distance to the
explosion endpoint if the model used is
based on TNT-equivalent methods.
(f) Parameters to be applied. The owner
or operator shall use the parameters
defined in §68.22 to determine distance
to the endpoints. The owner or opera-
tor may use the methodology provided
in the RMP Offsite Consequence Analy-
sis Guidance or any commercially or
publicly available air dispersion model-
ing techniques, provided the techniques
account for the modeling conditions
and are recognized by industry as ap-
plicable 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.
(g) 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.
(h) Factors in selecting a worst-case sce-
nario. Notwithstanding the provisions
of paragraph (b) of this section, the
owner or operator shall select as the
worst case for flammable regulated
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-
sure; and
(2) Proximity to the boundary of the
stationary source.
§68.28 Alternative release scenario
analysis.
(a) The number of scenarios. The
owner or operator shall identify and
analyze at least one alternative release
scenario for each regulated toxic sub-
stance held in a covered process (es) and
1220
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Environmental Protection Agency
at least one alternative release sce-
nario to represent all flammable sub-
stances held in covered processes.
(b) Scenarios to consider. (1) For each
scenario required under paragraph (a)
of this section, the owner or operator
shall select a scenario:
• (i) That is more likely to occur than
the worst-case release scenario under
§68.25; and
(ii) That will reach an endpoint off-
site, unless no such scenario exists.
(2) Release scenarios considered
should include, but are not limited to,
the following, where applicable:
(i) Transfer hose releases due to
splits or sudden hose uncoupling;
(ii) Process piping releases from fail-
ures at flanges, joints, welds, valves
and valve seals, and drains or bleeds;
(iii). Process vessel or pump releases
due to cracks, seal failure, or drain,
bleed, or plug failure;
(iv) Vessel overfilling and spill, or
overpressurization and venting through
relief valves or rupture disks; and
(v) Shipping container mishandling
and breakage or puncturing leading to
a spill.
(c) Parameters to be applied. The
owner or operator shall use the appro-
priate parameters defined in §68.22 to
determine distance to the endpoints.
The owner or operator may use either
the methodology provided in the RMP
Offsite Consequence Analysis Guidance
or any commercially or publicly avail-
able air dispersion modeling tech-
niques, provided the techniques ac-
count for the specified modeling condi-
tions and are recognized by industry as
applicable as part of current practices.
Proprietary models that account for
the modeling conditions may be used
provided the owner or operator allows
the implementing'agency access to the
model and describes model features and
differences from publicly available
models to local emergency planners
upon request. •
(d) Consideration of mitigation. Ac-
tive and passive mitigation systems
may be considered provided they are
capable of withstanding the event that
triggered the release and would still be
functional.
(e) Factors in selecting scenarios.
The owner or operator shall consider
68.36
the following in selecting alternative
release scenarios:
(1) The five-year accident history
provided in §68,42; and
(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 oil 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
1221
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§68.39
40 CFR Ch. I (7-1-96 Edition)
•it I!* ': ! i,;''i
!! I.'. • • I '.
3 , 1 •..;:-
and submit a revised risk management
plan as provided in §68.190.
§68.39 Documentation.
The owner or operator shall maintain
the following records on the offsite
consequence analyses:
(a) For worst-case scenarios, a de-
scription of the vessel or pipeline and
substance selected as worst case, as-
sumptions and parameters used, and
the rationale for selection: assump-
tions shall include use of any adminis-
trative controls and any passive miti-
gation that were assumed to limit the
quantity that could be released. Docu-
mentationshall 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.
§ 68.43 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:
(I) Date, time, and approximate dura-
tion of the release:
(2) Chemical (s) released;
(3) Estimated quantity released in
pounds:
(4) The type of release event and its
source;
(5) Weather conditions, if known;
(6) On-site impacts;
(7) Known offsite impacts;
(8) Initiating event and contributing
factors if known;
(9) Whether offsite responders were
notified if known; and
(10) 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.
Subpart C—Program 2 Prevention
Program
SOURCE: 61 FR 31721, June 20. 1996, unless
otherwise noted.
EFFECTIVE DATE NOTE: At 61 FR 31721, June
20. 1996. subpart C was added, effective Aug.
19, 1996.
§ 68.48 Safety information.
(a) The owner or operator shall com-
pile and maintain the following up-to-
date safety information related to the
regulated substances, processes, and.
equipment:
(1) Material Safety Data Sheets that
meet the requirements of 29 CFR
1910.1200(g);
(2) Maximum intended inventory of
equipment in which the regulated sub-
stances are stored or processed;
(3) Safe upper and lower, tempera-
tures, pressures, flows, and composi-
tions;
(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
change occurs that makes the informa-
tion inaccurate.
1222
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Environmental Protection Agency
§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 operat-
ing procedures.
(b) The procedures shall address -the
following: (
(1) Initial startup; ,
(2) Normal operations;
(3) Temporary operations;
§68.54
(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.
1223
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ll III
II (III
Ill II
§68.56
§68.56 Maintenance.
V I 'I1' '' "p ' , ".iijlillij!! ',', ,„ ,, , ii; i. "' /" '' ' f "
(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 station-
ary source maintenance procedures.
(b) The owner or operator shall train
or cause to be trained each employee
involved in maintaining the on-going
mecj)anica| 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 ver-
ify that the procedures and practices
developed under the rule are adequate
arid 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
appropriate response to each of the
findings of the compliance audit and
document that deficiencies have been
corrected.
40 CFR Ch. I (7-1-96 Edition)
(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
not 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
the 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-
tions shall be documented.
(e) The findings shall be reviewed
with all affected personnel whose job
tasks are affected by the findings.
(f) Investigation summaries shall be
retained for five years.
Subpart D—Program 3 Prevention
Program
SOURCE: 61 FR 31722, June 20, 1996. unless
otherwise noted.
EFFECTIVE DATE NOTE: At 61 FR 31722. June
20, 1996, subpart D was added, effective Aug.
19.1996.
§ 68.65 Process safety information.
(a) In accordance with the schedule
set forth in §68.67, the owner or opera-
tor 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 opera-
tor and the employees involved in oper-
ating the process to identify and under-
stand the hazards posed by those proc-
esses involving regulated substances.
1224
'111, Ii
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Environmental Protection Agency
§68.67
This process safety information shall
include information pertaining to the
• hazards of the regulated substances
used or produced by the process, infor-
mation pertaining to the technology of
the process, and information pertain-
ing 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;
(vi) Design codes and standards em-
ployed;
(vii) Material and energy balances for
processes built after June 21, 1999; and
(viii) Safety systems (e.g. interlocks,
detection or suppression systems).
(2) The owner or operator, shall docu-
ment that equipment complies with
recognized and generally accepted good
engineering practices.
(3) For existing equipment designed
and constructed in accordance with
codes, standards, or practices that are
no longer in general use, the owner or
operator shall determine and document
that the equipment is designed, main-
tained, inspected, tested, and operating
in a safe manner.
§ 68.67 Process hazard analysis.
(a) The owner or operator shall per-
form an initial process hazard analysis
(hazard evaluation) on processes cov-
ered by this part. The'process hazard
analysis shall be appropriate to the
complexity of the process and shall
identify, evaluate, and control the haz-
ards involved in the process. The owner
or operator shall determine and docu-
ment the priority order for conducting
process hazard analyses based on a ra-
tionale which includes such consider-
ations as extent of the process hazards,
number of potentially affected employ-
ees, age of the process, and operating
history of the process. The process haz-
ard analysis shall be conducted as soon ,
as possible, but not later than June 21,
1999. Process hazards analyses com-
pleted to comply with" 29 CFR
1910.119(e) are acceptable as initial
process hazards analyses. These process
hazard analyses sHall be updated and
revalidated, based on their completion
date.
(b) The owner or, operator shall use
one or more of the . following meth-
odologies that are appropriate to deter-
mine and evaluate the hazards of the
process being analyzed.
(l)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
1225
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11''!, "IS1; I': it '•'.»l!l*. 1" I < I;' '""', •. ,!M \ • .'!•;" •
11 Jvl
ftifi
§68.69
(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 incluide 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 th"e 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
process. Updated and revalidated proc-
40 CFR Ch. I (7-1-96 Edition)
ess hazard analyses completed to com-
ply with 29 CFR 1910.119(e) are accept-
able to meet the requirements of this
paragraph.
(g) The owner or operator shall re-
tain process hazards analyses and up-
dates or revalidations for each process
covered by this section, as well as the
documented resolution of recommenda-
tions described in paragraph (e) of this
section for the life of the process.
§ 68.69 Operating procedures.
(a) The owner or operator shall de-
velop and implement written operating
procedures that provide clear instruc-
tions for safely conducting activities
involved in each covered process con-
sistent with the process safety infor-
mation and shall address at least the
following elements.
(1) Steps for each operating phase:
(i) Initial startup;
(ii) Normal operations;
(iii) Temporary operations;
(iv) Emergency shutdown including
the conditions under which emergency
shutdown is required, and the assign-
merit of shutdown responsibility to
qualified operators to ensure that
emergency shutdown is executed in a
safe and timely manner.
(v) Emergency operations;
(vi) Normal shutdown; and,
(vii) Startup following a turnaround,
or after an emergency shutdown.
(2) Operating limits:
(i) Consequences of deviation; and
(ii) Steps required to corrett or avoid
deviation.
(3) Safety and health considerations:
(i) Properties of, and hazards pre-
sented by, the chemicals used in the
process;
(ii) Precautions necessary to prevent .
exposure, including engineering con- "-
trols, administrative controls, and per-
sonal protective equipment;
(iii) Control measures to be taken if
physical contact or airborne exposure
occurs;
(iv) Quality control for raw materials
and control of hazardous chemical in-
ventory levels; and,
(v) Any special or unique hazards.
(4) Safety systems and their func-
tions.
1226
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Environmental Protection Agency
§68.73
(b) Operating procedures shall be
readily accessible to employees who
work in or maintain a process.
(c) The operating procedures shall be
reviewed as often as necessary to as-
sure that they reflect :current operat-
ing practice, including changes that re-
sult from changes in process chemicals,
technology, and, equipment; and
changes to stationary sources. The
owner or operator shall certify annu-
ally that these operating procedures
are current and accurate.
(d) The owner or operator shall de-
velop and implement safe work prac-
tices to provide for the control of haz-
ards during operations such as lockout/
tagout; confined space entry; opening
process' equipment or piping; and con-
trol over entrance into a stationary
source by maintenance, contractor,
laboratory, or other support personnel.
• These safe work practices shall apply
to employees and contractor employ-
ees. . .
§68.71 Training.
(a) Initial training. (1) Each employee
presently involved in operating a proc-
ess, and each employee before being in-
volved in operating a newly assigned
process, shall be trained in an overview
of the process and in the operating pro-
cedures as specified in §68.69. The
training shall include emphasis on the
specific safety and health hazards,
emergency operations including shut-
down, and safe work practices applica-
ble to.the employee's job tasks.
(2) In lieu of initial training for those
employees already involved in operat-
ing a process on June 21, 1999 an 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 specified in the operating pro-
cedures.
(b) Refresher training. Refresher train-
ing shall be provided at least 'every
.three years, and more often if nec-
essary, to each employee involved in
operating a process to assure that the
employee understands and adheres to
the current operating procedures of the
process. The owner or operator, in con-
sultation with the employees involved
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
Straining 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 arid 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 operat-
ing 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
1227
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§68.75
v , " • - ;:i ••••••.•.. "..,t ••.•".?('•:•• : .••..•
date pf 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 Sescription of the inspection
or test performed, and the results of
the inspection or test.
(e) Equipment deficiencies. The owner
pr operator shall correct deficiencies in
equipment that are outside acceptable
limits (defined by the process safety in-
formationin §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 fpr Jhe 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
cpHsistentrijwiA design specifications
and the manufacturer's instructions.
(3) The owner or operator shall as-
sure that maintenance materials, spare
parts arid 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 fpllpwing 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 arid maintenance and contract
ejfriployees whose job tasks will be af-
fected by a change in the process shall
be informed of. and trained in, the
40 CFR Ch. I (7-1-96 Edition)
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 operat-
ing procedures or practices required by
§68.69, such procedures or practices
shall be updated accordingly.
§68.77 Pre-startup review.
(a) The owner or operator shall per-
form a pre-startup safety review for
new stationary sources and for modi-
fied stationary sources when the modi-
fication is significant enough to re-
quire a change in the process safety in-
formation.
(b) The pre-startup safety review
shall confirm that prior to the intro-
duction of regulated substances to a
process:
(1) Construction and equipment is in
accordance with design specifications;
(2) Safety, operating, maintenance,
and emergency procedures are in place
and are adequate;
(3) For new stationary sources, a
process hazard analysis has been per-
' formed and recommendations have
been resolved pr implemented before
Startup; and modified stationary
sources meet the requirements con-
tained in management of change,
§68.75.
(4) Training of each employee in-
volved in operating a process has been
completed.
§ 68.79 Compliance audits.
(a) The owner or operator shall cer-
tify that they have evaluated compli-
ance with the provisions of this section
at least every three years to verify
that the. procedures and practices de-
veloped under the standard 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
findings of the compliance audit, and
1228
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Environmental Protection Agency
document that deficiencies have been
corrected.
(e) The owner or operator shall retain
the two (2) most recent compliance
audit reports.
§ 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. ,
(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-
§68.87
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
the contract owner or operator and
contract employees in covered process
areas.
(5) The owner or operator shall peri-
odically evaluate the performance of
1229
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§68.90
J&e. contrast; owner or operator in ful-
filling their obligations as specified in
paragraph (c) of this section.
(c) Contract owner or operator respon-
sibilities. (1) The contract owner or op-
erator shall assure that each contract
employee is trained in the work prac->
tices necessary to safely perform his/
her job.
(2) The contract owner or operator
shall assure that each contract em-
ployee is instructed in the known po-
tential fire, explosion, or toxic release
hazards related to his/her job and the
process, and" the applicable provisions
of the emergency action plan.
(3) The contract owner or operator
shall document that each contract em-
ployee has received and understood the
training required by this section. The
contract owner or operator'shall pre-
pare a record which contains the iden-
tity of the contract employee, the date
of training, and the means used to ver-
ify that the employee understood the
training.
(4) The contract owner or operator
shall assure that each contract em-
ployee follows the safety rules of the
stationary source including the safe
work practices required by §68.69(d).
(5) The contract owner or operator
shall advise the owner or operator of
any unique hazards presented by the
contract owner or operator's work, or
of any hazards found by the contract
owner or operator's work.
Subpart E—Emergency Response
SOURCE: 61 FR 31725. June 20. 1996. unless
otherwise noted.
EFFECTIVE DATE NOTE: At 61 FR 31725. June
20, 1996. subpart E was added, effective Aug.
19,1996,, ,, , , '.,,,,.
§68.90 Applicability.
(a) Except as provided in paragraph
(b) of this section, the owner or opera-
tor 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 station-
ary source whose employees will not
respond to accidental releases of regu-
lated substances need not comply with
§68.95 of this part provided that they
meet the following:
40 CFR Ch. I (7-1-96 Edition)
!,"; i;,;:.;'.'.:;...' • ;";,:> ;•;•:;, J./..,.'*:. •"' - ;i ', ,
(lj 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
(iii) Procedures and measures for
emergency response after an accidental
release of a regulated substance;
(2) Procedures for the use of emer-
gency response equipment and for its
inspection, testing, and maintenance;
(3) Training for all employees in rel-
evant procedures; and
(4) Procedures to review and update,
as appropriate, the emergency response
plan to reflect changes at the station-
ary source and ensure that employees
are informed of changes.
(b) A written plan that complies with
other Federal contingency plan regula-
tions or is consistent with the ap-
proach in the National Response
Team's Integrated Contingency Plan
Guidance ("One Plan") and that,
among other matters, includes the ele-
ments provided in paragraph (a) of this
section, shall satisfy the requirements
of this section if the owner or operator
also complies with paragraph (c) of this
section.
1230
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Environmental Protection Agency
§68.115
(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. . -
EFFECTIVE DATE NOTE: At 61 FR 31717. June
20. 1996, subpart C was redesignated as sub-
part F, effective Aug. 19,1996.
§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
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)t 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. If a regu-
lated substance is present in a mixture
and the concentration of the substance
is below one percent by weight of the
mixture, the mixture need not be con- •
sidered when determining whether
more than a .threshold quantity of the
regulated substance is present at the
stationary source. If the concentration
of the regulated substance in the mix-
ture is one percent or greater by
weight, then, for purposes of determin-
ing whether more than a threshold
quantity is present at the stationary
source, the entire weight of the mix-
ture shall be treated as the regulated
substance unless the owner or operator
can demonstrate that the mixture it-
self does not meet the criteria for flam^
mability of flash point below 7?F
(22.8°C) and boiling point below 100PF
(37.8°C). The owner or operator shall
document these flash point and boiling
point measurements or estimates.
(3) Concentrations of a regulated explo-
sive substance in a mixture. Mixtures ,of
Division 1.1 explosives listed in 49 CFR
172.101 (Hazardous Materials Table) :and
other explosives need not be included
when determining whether a threshold
quantity is present in a process, when
the mixture is intended to be used on-
site in a non-accidental release in a
manner consistent with. applicable
BATF regulations. Other mixtures of
Division 1.1 explosives listed in 49 CFR
172.101 and other explosives shall be in-
cluded . in determining whether more
than a threshold quantity is present in
a process if such mixtures would be
treated as Division 1.1 explosives under
49 CFR parts 172 and 173.
1231
-------
§68.120
40 CFR Ch. I (7-1-96 Edition)
(4) Articles. Regulated substances con-
tained in articles need not be consid-
ered when determining whether more
than 3.threshold quantity is present at
the stationary source.
(5) Uses. Regulated substances, when
in use for the following purposes, need
not be included in determining whether
rnpre t;ha£L a threshold quantity is'
present at the stationary source:
(i) Use as a structural component of
the stationary source:
(ii) Use of products for routine jani-
torial maintenance;
(iii) Use by employees of foods, drugs,
cosmetics, or other personal items con-
taining the regulated substance; and
(iv) Use of regulated substances
present in process water or non-contact
cooling water as drawn from the envi-
ronment o| municipal sources, or use
of regulated substances present in air
used either as compressed air or as part
of combustion.
(6) Activities in laboratories. If a regu-
lated substance is manufactured, proc-
essed, or uged in a laboratory at a sta-
tionary source under the supervision of
a technically qualified individual as de-
fined in § 720.3 (ee) of this chapter, the
Quantity of the substance need not be
considered in determining whether a
threshold quantity is present. This ex-
ernptioh 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.
§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 substance 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
and 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
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
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 narne(s), com-
mon synonym (s). Chemical Abstracts
Service number, and chemical formula
and structure;
(4) Action requested (add or delete a
substance);
i(5) Rationale supporting the petition-
er'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
database(s) searched, the search strat-
egy, dates covered, and printed results;
(iii) Effects data (animal, human, and
environmental test data) indicating
1232
-------
Environmental Protection Agency
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
include, but are not limited to, phys-
ical and chemical properties of the sub-
stance, such as vapor pressure; model-
ing results, including data and assump-
tions used and model documentation;
and historical accident data, citing
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) Explosives listed by DOT as Divi-
sion 1.1 in 49 CFR 172.101 are covered
under section 112(r) of the Clean Air
Act. The threshold quantity for explo-
sives is 5,000 pounds.
(b) Regulated toxic and flammable
substances .under section 112(r) -of the
Clean Air Act are the substances listed
in Tables 1, Z, 3, and 4. Threshold quan-
tities for listed toxic and flammable
substances are specified in the tables.
(c) 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]
§68.130
TABLE 1 TO §68.130.—LIST OF REGULATED
Toxic SUBSTANCES AND THRESHOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE
PREVENTION—Continued
[Alphabetical Order—77 Substances]
Chemical name
Acrolein[2-
Prapenal].
Acrylonitrile [2-
Propenenilrile].
CAS No.
107-02-8
107-13-1
Threshold
quantity
(Ibs)
5.000
20,000
Basis for
listing
b
b
Chemical name
Acrylyl chloride
[2-Prapenoyl
. chloride].
Ally! alcohol [2-
Propen-l-ol].
Allylamine [2-
Propen-l-amine]
Ammonia (anhy-
drous).
Ammonia (cone
20% or greater).
Arsenoustri-
' chloride.
Arsine
Boron trichloride
[Borane,
trichjoro-J.
Boron trifluoride
[Borane,
trifluoro-].
Boron trifluoride
compound with
methyl ether
(1:1) [Boron,
trifluoro [oxybis
[metane]]-, T-4-.
Bromine ..............
Carbon disulfide
Chlorine
Chlorine dioxide
[Chlorine oxide
(002)].
Chloroform [Meth-
. ane, trichloro-].
Chloromethyl
ether [Methane,
oxybis[chloro-].
Chloromethyl
methyl ether
[Methane,
chloromethoxy-J.
Crotonaldehyde
[2-Butenal].
Crotonaldehyde,
(E)- [2-Butenal,
(EH-
Cyanogen chlo-
ride.
Cydohexytemine
[Cyclohexana-
mme].
Diborane .. «.»..
Dimethyldichloro-
silane [Silane,
dichlorodimeth-
1,1-
Dimethylhydra-
zine [Hydra-
zine, 1,1 -di-
methyl-].
Epichlorohydrin
[Oxirane, -
(Chloromethyl)-].
CAS No.
814^68-6
107-18-61
107-11-9
7664-41-7
7664-41-7
7784-34-1
7784-r«-1
10294-34-5
7637-07-2
353-42-4
*
772B-95-6
75-1 5-K)
7782-50-5
10049-04-4
67-66-3
542-88-1
107-30-2
4170-30-3
123-73-9
506-77-4
108-91-8
19287-45-7
75-78-5
57-14-7
106-89-8
Threshold
quantity
5,000
15,000
10,000
10,000
20,000
15,000
1,000
5,000
5,000
"
15.000
10,000
20,000
2,500
. 1,000
20,000
1,000
5,000
«
20,000
20,000
10,000
15,000
2,500
5,000
15,000
20,000
Basis for
listing
b
b
b
a, b
a,b
b
b
b
b
b
a, b
b
a,b
c
b
b .
b
b
b
c
b
j
b
b
b
1233
-------
§68.130
40 CFR Ch. I (7-1-96 Edition)
TABLE 1 TO §68.130. — LIST OF REGULATED
Toxic SUBSTANCES AND THRESHOLD QUAN-
TITIES FOB ACCIDENTAL RELEASE
PREVENTION— Continued
• '••• ' [Alp|abet)cai Order— 77 Substances]
TABLE 1 TO §68.130. — LIST OF REGULATED
Toxic SUBSTANCES AND THRESTOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE '
PREVENTION— Continued
[Alphabetical Order— 77 Substances]
11 '!i !
'.i"Siil1
•;! if:
lit
Chemical name
Ethytcncdiarnine
lU-
Ethanediamine].
EUiyteoeimine
[AzirMne).
Ethyteno oxida
tOxkim],
Fluorine .«.«.*.«««
Formaldehyde
(solution).
FUrall 1LITTIII-T---T
Hydrairie "I!"
Hydrochloric acid
(cone 30% or
greater).
Hydrocyanic acid
Hydrogen chloride
(anhydrous)
(Hydrochloric
Kid].
Hydrogen fluo-
ride/
Hydrofluoric
acid (cone 50%
or greater)
[Hydrofluoric
addj.
HyoVogen sete-
nide.
Hydrogen sulfide
Iron,
pentacarbonyl-
[Iron carbonyl
(Fe(CO)S). (JB-
5-11B.
Isobutyronitrile
[Propanenitrile,
Z-methyt-].
Isooropyl
chtorolormale
[Carbonochlori-
dic acid, 1-
melhylcttiyl
ester].
Menuctylonilrite
(?-
PropeneniWte,
2-methyl-].
Mettty! cWotfde
* [Methane,
cWoro-1.
Me%l
chlorolormats
[Carbonochiori-
dtcadd.
methytester].
Methyl hydrazine
[Hydrazino,
methyH.
Methyl isocyanale
[Methane,
isocyanale-].
Methyt mercaptan
[Metnanethiori.
CAS No.
107-15-3
151-56-4
75-21-8
7782-41-4
50-00-O
110-00-9
302-01-2
7647-01-0
74-90-8
7647-01-0
7664-39-3
7783-07-5
7783-O6-4
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
Threshold
quantity
(Ibs)
20.000
10,000
10.000
1,000
15,000
5,000
15,000
15,000
2,500
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
Basis for
listing
b
b
a,b
b
b
b
b
d
a,b
a
a,b
b
a, b
b
b
b
b
a
b
b
a.b
b
Chemical name
Methyl
thiocyanate
[Thiocyanic
acid, methyl
ester].
Methyltrichlorosil-
ane [Silane,
trichloromethyl-].
Nickel carbonyl ...
Nitric acid (cone
80% or greater).
Nitric oxide [Nitro-
gen oxide (NO)].
Oleum (Fuming
Sulfuric acid)
[Sulfuric acid,
mixture with
sulfur trioxide]1.
Peracelic acid
[Ethaneperoxoi-
cacid].
Perchloromethyl-
mercaptan
[Methanesulfen-
yl chloride.
trfchloro-].
Phosgene [Car-
bonic dichlc-
ride].
Phosphine
Phosphorus
oxychloride
[Phosphoryl
chloride].
Phosphorus tri-
chloride [Phos-
phorous tri-
chloride].
Piperidine ............
Propionitrile .
[Propanenitrile].
Propyl
chloroformate
[Carbonochlori-
dic acid.
propylester].
Propyleneimine
[Aziridine, 2-
methyl-].
Propylene oxide
[Oxirane, meth-
yl-].
Sulfur dioxide
(anhydrous).
Sulfur tetra-
fluoride [Sulfur
fluoride (SF4),
CT-4H.
Sulfur trioxide —
Tetramethyllead
[Plumbane,
tetramethyl-]. •
Tetranitro-
methane [Meth-
ane, tetranitro-].
CAS No.
556-^64-9
75-79-6
13463-39-3
7697-37-2
10102-43-9
8014-95-7
79-21-0
594-42-3
75-44-5
7803-S1-2
10025-87-3
7719-12-2
110-89-^t
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
Threshold
quantity
(Ibs)
20,000
5,000
1,000
15,000
10,000
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
Basis for
listing
b
b
b
b
b
e
b
b
a,b
b
b
b
b
b
b
b
b .1-
a, b
b
a. b
b .
b
1234
-------
Environmental Protection Agency
§68.130
TABLE 1 TO §68.130.—LIST OF REGULATED
Toxic SUBSTANCES AND THRESHOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE •
PREVENTION—Continued
[Alphabetical Order—77 Substances]
TABLE 1 TO §68.130.—LIST OF REGULATED
Toxic SUBSTANCES AND THRESHOLD QUAN-
TITIES FOR ACCIDENTAL RELEASE
PREVENTION—Continued
[Alphabetical Order—77 Substances]
'Chemical name
Titanium tetra-
chloride [Tita-
nium chloride
-------
§68.130
40 CFR Ch. I (7-1-96 Edition)
TABLE 2 TO §68.130.—LIST OF REGULATED Toxic SUBSTANCES AND THRESHOLD QUANTITIES FOR
i ACCIDENTAL RELEASE PREVENTION—Continued
[CAS Number Order—77 Substances]
CAS No.
. ', i;',,|'ii'i
126-98—7
151-S6-4
302-01-2 . ™«
353-42—4 ..».»««..».«
500-77-4
S09-14-8 „...„.««—
542-88-1
584-84-9 m
£94—42—3 ..,.. ....„.„
624-83-9
814-68-6 .„.,..„„„„„
4170-30-3
7446-09-5 .
7446-11-9 . -
7S50-45-0 .„«.—«,„-
7637-07-2 „-„«„«
7g47_j01-0 ««Z«I™....
7647-Ot-O .ww™.™
7664-39-3 .„«»..«..«
7664-41-7 «mw~.«.™
7£$A~41— 7
7697-37-2 „„,.— .
7719-12-2 .,.-™L.....
7726-95-6
7782-41-4
7782-50-5 „ „„„,
7733-06-4
7783-07-5 „„ „«,
7783-60-0
77@4_34_-|
7784-42-1 «..„«.«««..
3014-95-7 M.w™mm.
10025—87-3
10049-04—4
10102-43-9 .„' .
10294-34-5 , :
13463-39-3
13463-40-6
19287-45-7
26471-62-5 ™...
Chemical name
Boron triflubride compound with methyl ether (1:1) [Boron,
trifluoro[oxybis[methane]]-, T-4-.
Telranttromethane [Methane, tetranitro-]
Toluene 2 4-olisocyanate [Benzene, 2,4-diisocyanato-1-methyl-p
Perchtoromethylmercaptan [Methanesulfenyl chloride, trichloro-]
Acrylyl chkwide [2-Propenoyl chloride]
Suffuf dioxide (anhydrous) „..„.....—.«............»...».» «.......«
Sulfur trioxide
Titanium tetrachtoride [Titanium chtoride (TiCW) (T-4)-]
Boron trifluorkte [Borane trifluoro*!
Hydrochloric acid (cone 30% or greater) [[[
Hydrogen chloride (anhydrous) [Hydrochloric acid] .
Hydrogen fluoride/Hydrofluoric acid (cone 50% or greater) [Hydrofluoric acid]
Ammonia (anhydrous) .._«—.»...«...•..•»....•............«...........••.•.•.......•..................
Nitric acid (cone 80% or greater) ...^
Phosphorus trichloride [Phosphorous trichloride] ... : :....
Chlorine
Suffur tetraftuoride [Sulfur fluoride (SF4) (T-4)-]
ArsJne ..„„..„.....„....„..._»...............«....»«....»
P hosphtne .«..........*, «*.»»•..»..«» ..................... .... .,—................. .......................
Oteum (Fuming Sulfuric acid) (Sulfuric acid, mixture with sulfur trioxidep
Chlorine dioxide [Chlorine oxide (CIO*)]
Nitric oxide [Nitrogen oxide (NO)] . ...:..........
Boron trichloride [Borane* trichtoro-]
Iron pentacarbonyt- [Iron carbonyl (Fe(CO)j), (TB-5-11)-] .„..„.„».„..........»....
Totuene ditsocyanate (unspecified isomer) [Benzene, 1,3*diisocyanatomethyf-
Threshold
quantity
(Ibs)'
10 000
10,000
15,000
15,000
10000
10,000
1 000
20 000
10,000
10,000
10000
5,000
20000
5,000
10,000
2,500
5,000
15,000
5,000
1,000
10,000
20,000
15,000
15,000
10,000
1 000
2,500
10000
500
2500
15,000
1,000
5,000
10,000
5000
1 000
10,000
5,000
1,000
2,500
2,500
10,000
Basis for
listing
b
b
b
b
b
b
b
a
b
a b
b
b
a,b
a, b
b
b
d
a
a, b
a, b
a, b
b
b
a, b
b .
a, b
a b
b
b
b l
b
b
e
b
c
b
b
b
b
b
a
' The mixture exemption in §68.11S(b)(1) does not apply to the substance.
NOTE: Basis for Listing:
a Mandated for listing by Congress.
b On EHS fist, vapor pressure 10 mmHg or greater.
c Toxic gas.
* Toxtety 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 ACCIPENTALRELEASE PREVENTION (
[Alphabetical Order—63 Substances]
; M
Acetaidehyde
Acetylene [Elhyne]
BtomotriHuorethyien
I^S-Butadiene „_..
Butane »»»«»««...,.
1-P«!<»«1^ , ,
2-Butene ..„_...__„
BuSene
Cnemica) name
e [Ethene, bromolrifluoro-] .._
_
CAS No.
75-07-0
74-S6-2
598-73-2
106-99-O
106-97-8
106-98-9
107-01-7
25167-67-3
Threshold
quantity
(Ibs)
10,000
10,000
10,000
10,000
10.000
10,000
10,000
10,000
Basis for
-------
, Environmental Protection Agency
§68.130
TABLE 3 TO § 68.130.—LIST OF REGULATED FLAMMABLE SUBSTANCES AND THRESHOLD QUANTITIES
FOR ACCIDENTAL RELEASE PREVENTION—Continued.
[Alphabetical Order—63 Substances]
Chemical name
2-Butene-cis
2-Butene-trans'[2-Butene, (E)J ;. .. ;~ ,
Carbon oxysulfide' [Carbon oxide sulfide (COS)]
1-Chloropropylene [1-Propene, 1-chlorc-] .................
Cyanogen [Ethanedinitrile]
Cyclopropane ...
Dichlorosilane [Silane, dichloro-] ....................... .. ........ .......;...........
Difluoroethane [Ethane, 1 ,1 -difluoro-]
Dimethylamine [Methanamine, N-methyl-] :.. ... ;
2,2-Dimethylpropane [Propane, 2,2-dimethyl-3 ................... ..............
Ethane . '
Ethyl chloride [Ethane, chloro-] ....... ..... .'.
Ethylene [Ethene] ;.™ ; .
Ethyl ether [Ethane, 1,1'-oxybis-] .
Ethyl mercaptan [Ethanethlol] .................. ..........«»..««„...„.....«...„..........«..
Ethyl nitrite [Nitrous add, ethyl ester] . ...... . ...„
Isoprene [1 ,3-Butadinene, 2-methyl-] . „< ....
Isopropylamine [2-Propanamine] . .... .. ............ ...
, Isopropyl chloride [Propane, 2-chloro-]
3-MethyM-butene ..
2-Methyl-1-butene .,... ".
Methyl ether [Methane oxybis-]
Methyl -formate [Formic acid methyl ester]
2-Methytpropene [1-Propene, 2-methyl-] . ..„
1,3-Pentadinene ............. — .„«.....„„.....„..„.».....„.„„„.„.....„.
1-Pentene '
Propadiene[1,2-Propadiene3 ......
Propyne [1-Propyne] [[[
Silane : . ; .
Tetramethylsilane [Silane, tetrametnyl-] .. .
Trichlorosilane [Silane, trichloro-] .'. .'. .„
Trifluorochloroethylene [Ethene, chiorotrifluoro-] ... .... .
Trimethylamine [Methanamine, N,N-dimethyl-] .
Vinyl acetylene [1-Buten-3-yne] '. ......
Vinyl chloride [Ethene, chloro-] ....... ... « ~. .-..
Vinyl ethyl ether [Ethene, ethoxy-] .
Vinyl fluoride [Ethene, fluoro-] .
Vinylidene chloride [Ethene, 1,1-dichloro-] . . . .
Vinyiidene fluoride [Ethene, 1,1 -difluoro-] ..
Vinvl mfithvl ether FEthene methoxv-1 ...... .. .
CAS No. •:
S90-18-1
624-64-6
463-58-1
7791 21-1
5S7_98_2
590-21-6
460-19-5
75-1 9-4
4109-96-0
75-37-6
124-40-3
463-82-1
74-84-0
107-00-6
75_04_7
75-00-3
74-65-1
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--)5-1
563-46-2
115-10-6
107-31-3
115_11_7
504-60-9
. 1Q9-66-0
109-67-1
646-04-8
627 20-3
463-49-0
74-98-6
1 15-07-1
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
Threshold
quantity
(Ibs)
10,000
10,000
10000
10000
10 000
10,000
10,000
. 10,000
10,000
10.000
10,000
10,000
10000
10000
10000
10,000
10,000
10,000
10,000
10,000
10,000
10000
10,000
10,000
10,000
. 10,000
10000
10000
10,000
10,000
10000
10,000
10,000
10,000
10.000
10,000
10000
loffoo
10,000
10,000
10,000
10,000
10,000
10.000
10,000
10.000
'10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10.000
Basis for
listing
f
f
f
f
9
f '
f
f
g
g
f
f
f
g
g
g
f
f
f
g
f
g
f
f
g
g
f
f
f
f '
f
f
g
g
f
f
f
a,f
g'
f
g
f
f
NOTE: Basis for Listing:
a Mandated for listing by Congress.
-------
§68.130
40 CFR Ch. I (7-1-96 Edition)
TABLE 4 TO §68.130.—UST OF REGULATED FLAMMABLE SUBSTANCES AND THRESHOLD QUANTITIES
FOR ACCIDENTAL RELEASE PREVENTION
[CAS Number Order—63 Substances]
CAS No.
06-29-7 .__™ _..„„
74—82—8
74-84'-Q
74-85-1 „_ .
74-86-2
74-89-5 .._ _.
74-58-5
74-99-7 _____._....
75-00-3 .__ _...._-
,. 75-01-4 „ ___
75-02-5.
75-04-7.
7S-07-0 ,,.„.. .„.,.. ..,.,..
75-06^1 _____ __
7S-19-4
75-28-S
75-29-6 .....,,,,.,
75-31-0 ___„__.._..
75-35-4
75-37-6
75-38-7 .__». .
75-50-3 !___
75-76-3
78-78-4
78179-5
79-39-9 _.„.___..._
106-97-8
106-98-9 _
196-99HS _._„„__.
107-00-6 _
107-01-7 .
107-25-5 . „„„._._
107-31-3 _________
109-66-6 ________
109-67-1 _________
109-92-2 _IL .
109-95-5 __™_^_
115-D7-1 ,
i15-i6-6 — ZI —
115-11-7 ™. .
116-14-3 _____..._
124-40-3
466-19-5 __ '.-.
463— 49-O _______
463-58-1
463-82-1 _..„.
504-60-9
557-98-2 ..__.„...__..
563-45-1 _________
563-46-2 _ __7 _
580-18-1
596-21-6 ________
5S6-73-2
a?4-§4-6
627-20-3 ..................
646-04-8
Rft?_Q7-4 , ,
1333-74-0
4109-96-0
7791-21-1 __
7803-62-5 ._ _
10025-78-2 .
25167-67-3
Chemical name
Ethyl ether [Ethane. 1,1'-oxybis-]
Methane . ^
Ethytene [Ethene] .„
Acetylene [Ethyne] .
Propyne [1-Propyne] _
Ethyl chloride [Ethane, chloro-]
Vkiyt chloride [Ethene, chtoro-] ..„
Vinyl fluoride [Ethene fluoro-]
Ethylamine [Ethanamine] .
Acetaldehyde
Ethyl mercaptan [EthanethioQ _
Cyclopropane .. .
Isopropyl chloride [Propane, 2-chloro-]
Isopropytamine [2-Propanamine]
VmySdene chloride [Ethene, 1,1-dlchloro-)
Difluoroetnane [Ethane. 1,1-difluoro-] -
VEnyfidene fluoride [Ethene, it1-difluoro-J
Trimethylamine [Methanamine. N, N-dimethyt-] .. :..
Tetramethylsilane [Silane. tetramethyl-] .
Isopentane [Butane, 2-methyl-] ........... ........._...................
Isoprene [1,3 -Butadiene 2-melhyl-]
Trifluorochloroethylene [Ethene, chlorotrifluoro-]
Butane ..._„........_ „
l^utene _
2*Butene .»...»...._.. «.........._................ :
Vinyl methyl ether [Ethene, methoxy-]
Methyl formate [Formic ack), methyl ester] . . —
Pentane .. ._„ _
1-Pentene .........._._._
Vinyl ethyl ether [Ethene, ethoxy-J _
Ethyl nitrite [Nitrous acid, ethyl ester] _
Methyl ether [Methane, oxybis-] _.._.
2-Methylpropene [1-Propene, 2-methyl-]
TetralKroroethylene [Ethene, tetrafluoro-J
Dimethylarn'me [Methanamine, N-methyl-J
Cyano^erl [Etiianedinitrite] ....«.......*«.....».........«....
Propadlene [1^2-Propadiene] «....._.._.... ........ ......
Carbon oxysuffide [Carbon oxide sulfide (COS)]
2,2-Dimethylpropane [Propane, 2,2-dimethyl-] ..
1,3-Pentadiene .._
2-Chtoropropylene [1-Propene, 2-chloro-J
3-Methyl-1-butene
2-Methyl-l -butene .
2-Butene-ds ____.._.....__...__..___...»._....i..
1-Chtoropropytene [1-Propene, 1-cMoro-]
Bromotrifluorethylene [Ethene, bromotrifluoro-]
2*Butene-trans [2-Butene, (E)]
2-Pentene, (Z)- ..«_._._...._».«___.....»..«_«....................._.
2-Pentene, (E)- _...._...._..._......._.._.................................
Hydrogen _.._..« _......._ ........._.....
Dfchtorosilane [Silane, dfchtoro-] _ _
Silane
Trichtorosilane [Silane.trichtoro-]
jutene „
CAS No.
6O-29-7
74-32-8
74-85-1
74-86—2
74-83-5
74—98-5
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-J
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
109-9S-5
1 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
10025-78-2
25167-67-3
Threshold
quantity
(Ibs)
10000
10000
10000
10000
10000
10 000
10,000
10,000
10000
10 000
10 000
10,000
10,000
10000
10000
10.000
10,000
10,000
10,000
10000
10,000
10000
10,000
10000
10,000
10.000
10 ooo
10000
10000
10,000
10000
10,000
10,000
10,000
10 000
10,000
10000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10000
10,000
10.000
10,000
10000
10,000
10,000
10000
10,000
10,000
10 000
10000
10,000
10.000
Basis for
listing
f
(
f
a,f
9
9
1
f
g
9
9
f
f
f
g
t
g
g
g
1
f
f
f
f
f
g
f
f
9
f
f
g
g
t
i
f
f
(
Note: Basis (or Listing: a Mandated for listing by Congress. f Flammable gas. g Volatile flammable liquid.
1238
-------
Environmental Protection Agency
§68.160
Subpart G—Risk Management
Plan
SOURCE: 61 FR 31726. June 20, 1996. unless
otherwise noted.
EFFECTIVE DATE NOTE: At 61 FR 31726. June
20, 1996, subpart G was added, effective Aug.
19, 1996.
§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-
Eview by Federal and state representa-
tives who have, received the appro-
priate security clearances.
§ 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 scenario (s)
and the alternative release scenario (s),
including administrative controls and
'mitigation measures to limit the dis-
tances for each reported scenario;
(d) The general accidental release
prevention program and chemical-spe-
cific prevention steps;
, (e) The five-year accident history;
(f) .The emergency response program;
and
(g) Planned changes to improve safe- .
ty- . ;
§68.160 Registration.
(a) The owner or operator shall com-
plete a single registration form and in-
clude it in the RMP. The form shall
cover all regulated substances handled
in covered processes.
(b) The registration shall include the
following data:
(1) Stationary source name, street,
city, county, state, zip code, latitude,
and longitude;
(2) The stationary source Dun and
Bradstreet number;
(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 opera-
tor;
(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 and CAS number of each regu-
lated substance held above the thresh-
old quantity in the process, the maxi--
mum quantity of each regulated sub-
stance or mixture in the process (in
pounds) to two significant digits, the
SIC code, 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) Whether the stationary source
has a CAA Title V operating permit;
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.
1239
-------
§68.165
40 CFR Ch. I (7-1-96 Edition)
i! B
il,1" .IK I!1' "
t JUT"
§ 68.165 Ofisite consequence analysis.
(a) The owner or operator shall sub-
rnlt in the RMJP information:
(l) One worst-case release scenarip
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
held above the threshold quantity and
one worst>case release scenarip 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 opera-
tor shall submit the same information
on the additional scenario(s). The
owner or operator of Program 2 and 3
processes shall also submit informatipn
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) Physical state (toxics only);
(3) Basis of results (give model name
if; used): '" ...... '
(4) Scenario (explosion, fire, toxic gas
release, or liquid spill and vaporiza-
tion);
(5) Quantity released in pounds;
(6) Release rate;
(7) Release duration;
(8) Wind speed and atmospheric sta-
bility class (toxics only);
(9) Topography (toxics only);
(10) Distance to endpoint;
(11)
Public arid environmental recep-
tors within the distance;
(12) Passive mitigation considered;
and
(13) Active mitigation considered (al-
ternative releases only);
§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 SIC code for 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.
1240
-------
Environmental Protection Agency
§68.190
§68.175 Prevention program/Program
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 SIC code for the process.
' (c) The name(s) of the substance (s)
covered.
(d) The date on which the safety in-
formation was last reviewed or revised.
(e) The date of completion of the
most recent PHA or update and tfi'e
technique used.
(1) The expected date of completion
of any changes resulting from the PHA;
(2) Major hazards identified;
(3) Process controls in use;
(4) Mitigation systems in use;
(5) Monitoring and detection systems
in use; and
(6) Changes since the last PHA.
(f) The date of the most recent review
or' revision of operating procedures.
(g) The date of the most recent re-
view or revision of training programs;
(1) The type of training provided—
classroom, classroom plus on the job,
on the job; and
(2) The type of competency testing
used.,
(h) The date of the most recent re-
view or revision of maintenance proce-
dures and the date of the most recent
equipment inspection or test and the
equipment inspected or tested.
(i) The date of the most recent
change that triggered management of
change procedures and the date of the
most recent review or revision of man-
agement of change procedures. •
(3) The date of the most recent pre-
startup review. . , - '
(k) The date of the most recent com-
pliance audit and the expected date of
completion of any changes resulting
from the compliance audit;
(1) The date of the most recent inci-
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-
§ 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 the plan is
coordinated.
(c) The owner or operator shall list
other Federal or state emergency plan
requirements to which the stationary
source is subject.^
§ 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
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
1241
-------
§68.200
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) t*Io 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 ah already covered process
above a threshold quantity;
(4j 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
fihat 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.
EFFECTIVE DATE NOTE: At 61 FR 31728. June
20, 1996, subpart H was added, effective Aug.
19. 19S6.
§68.200 Recordkeepins.
: '•. '•;,<>. . unit1! , Ji':, ,v •. T" •<" ::M , i ., i r i,
The owner or operator shall maintain
records supporting the implementation
of this part for five years unless other-
Wise provided in subpart D of this part.
§68,210 Availability of information to
the public.
(a) The RMP required under subpart
G of this part shall be available to the
public under 42 U.S.C. 7414(c).
40 CFR Ch. I (7-1-96 Edition)
(b) The disclosure of classified infor-
mation by the Department of Defense
or other Federal agencies or contrac-
tors of such agencies shall be con-
trolled by applicable laws, regulations,
or executive orders concerning the re-
lease of classified information.
§68.215 Permit content and air per-
mitting authority or designated
agency requirements.
(a) These requirements apply to any
stationary source subject to this part
68 and parts 70 or 71 of this chapter.
The 40 CFR part 70 or part 71 permit for
the stationary source shall contain:
(1) A statement listing this part as
an applicable requirement;
(2) Conditions that require the source
owner or operator to submit:
(i) A compliance schedule for meet-
ing the requirements of this part by
the date provided in §68.10(a) or;
(ii) As part of the compliance certifi-
cation submitted under 40 CFR
70.6 (c) (5), a certification statement
that the source is in compliance with
all requirements of this part, including
the registration and submission of the
RMP.
(b) The owner or operator shall sub-
mit any additional relevant informa-
tion requested by the air permitting
authority or designated agency.
(c) For 40 CFR part 70 or part 71 per-
mits issued prior to the deadline for
registering and submitting the RMP
and which do not contain permit condi-
tions described in paragraph (a) of this
section, the owner or operator or air
permitting authority shall initiate per-
mit revision or reopening according to
the procedures of 40 CFR 70.7 or 71.7 to
incorporate the terms and conditions
consistent with paragraph (a) of this
section.
(d) The state may delegate the au-
thority to implement and enforce the
requirements of paragraph (e) of this
section to a state or local agency or
agencies other than the air permitting
authority. An up-to-date copy of any
delegation instrument shall be'main-
tained by the air permitting authority.
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.
1242
-------
Environmental Protection Agency
(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
operator has submitted a source cer-
tification or in its absence has submit-
ted a compliance schedule consistent
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 actipn based
on paragraphs (e)(l) and (e)(2) of this
section as appropriate.
§68.220 Audits.
(a) In addition to inspections for the
purpose of regulatory development and
enforcement of the Act, the imple-
menting agency shall periodically
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:
(1) Accident history of the stationary-
source;
(2) Accident history of other station-
ary 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;
(5) The presence of specific regulated
substances;
(6) The hazards identified in the
RMP; and
(7) A plan providing for neutral, ran-
dom oversight. • ' '
(c) Exemption from audits. A station-
ary source with a Star or Merit rank-
ing under OSHA's voluntary protection
program shall be exempt from audits
under paragraph (b)(2) and (b)(7) of this
section. '
§68.220
(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 prer
liminary determination or a shorter
period of time as the implementing
agency specifies in the preliminary de-
termination as necessary to protect
public health rand 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.
(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
1243
-------
§68.220
|ii • • ,, ": • ,:„ iiii"i it •'. -" :•,<;' ' -
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.
(h) Thirty days after completion of
the actions detailed in the implemen-
tation schedule set in the final deter-
40 CFRCh. I (7-1-96 Edition)
mination under paragraph (g) of this
section, the owner or operator shall be
in violation of subpart G of this part
and this section unless the owner or
operator revises the RMP prepared
under subpart G of this part as required
by the final determination, and sub-
mits the revised RMP as required
under §68.150.
(i) The public shall have access to the
preliminary determinations, responses,
and final determinations under this
section in a manner consistent with
§68.210.
(j) Nothing in this section shall pre-
clude, limit, or interfere in any way
with the authority of EPA or the state
to exercise its enforcement, investiga-
tory, and information gathering au-
thorities concerning this part under
the Act.
JIS ' ,
-it ;!""!
1244
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Environmental Protection Agency
Pt. 68, App. A
1245
-------
PL 68, App. A
40 CFR Ch. I (7-1-96 Edition)
co o r- i
O »- CM O> O i_
iSSi5S8§8!
fs g g
fflll ^1
1246
-------
Environmental Protection Agency
§69.11
[61 FR 31729. June 20. 1996]
EFFECTIVE DATE NOTE: At 61 FR 31729, June
20, 1996, appendix A was added to part 68, ef-
fective Aug. 19, 1996.
PART 69—SPECIAL EXEMPTIONS
FROM REQUIREMENTS OF THE
CLEAN AIR ACT
Subpart A— Guam
Sec.
69.11 New exemptions.
69.12 Continuing exemptions.
Subpart B—American Samoa [Reserved]
69.21- New exemptions. [Reserved]
Subpart C—Commonwealth of the
. Northern Mariana Islands [Reserved]
69.31' New exemptions. [Reserved]
AUTHORITY: Sec. 325, Clean Air Act, as
amended (42 U,S.C. 7625-1).
SOURCE: 50 FR 25577. June 20. 1985. unless
otherwise noted.
Subpart A—Guam
§69.11 New exemptions.
(a) Pursuant to section 325 (a) of the
Clean Air Act ("CAA") and a petition
submitted by the Governor of Guam
("Petition"), the Administrator of the
Environmental Protection Agency
("EPA")' conditionally exempts elec-
tric generating units on Guam from
certain CAA requirements.
(1) A waiver of the requirement to ob-
tain a prevention of significant dete-
rioration ("PSD") permit prior to con-
struction is granted for the electric
generating units identified in the Peti-
tion as Cabras-Diesel No. 1, the Tenjo
project, and three 6-megawatt diesel
generators to be constructed at Orote,
with the following conditions:
(i) Each electric generating unit
shall not be operated until a final PSD
permit is issued for that unit;
(ii) Each electric generating unit
shall not be operated until that unit
complies with all requirements of its
PSD permit, including, if necessary,
.retrofitting with the best available
control technology ("BACT");
(iii) The PSD application for each
electric generating unit shall be
deemed complete without the submit-
tal of the required one year of on-site
meteorological data, however, EPA
will not issue a PSD permit to such a
unit prior to submission of, such data
or data which the EPA finds to be an
equivalent and acceptable substitute;
, and
(iv) If any electric generating unit
covered by this paragraph is operated
either prior to the issuance of a final
. PSD permit or without BACT equip-
ment, that electric generating unit
shall be deemed in violation of this
waiver and the CAA beginning on the
date of commencement of construction
of that unit. '
(2) A waiver of the three nonattain-
ment area requirements (a construc-
tion ban, the use of lowest achievable
emission rate control equipment, and
emission offset requirements) cur-
rently applicable to _ the Cabras-Piti
area is granted for electric generating
units with the following conditions:
(i) A tower and meteorological sta-
tion shall be constructed in the Cabras-
Piti area by May 1, 1993;
(ii) Meteorological data shall be col-
lected from the Cabras-Piti station
which is sufficient to run air quality
models both to demonstrate no current
exceedences of the primary national
ambient air quality standard for sulfur
dioxide ("sulfur dioxide NAAQS"), as
set forth at 40 CFR 50.4, and sufficient
to submit a complete request for redes-
ignation of the area to attainment;
(iii) Ambient sulfur dioxide monitors
shall be installed and operated in ac-
cordance with the procedures set forth
at 40 CFR part 58, the PSD air monitor-
ing requirements, and any additional
monitoring requested by EPA to verify
the efficacy of the intermittent control
strategy ("ICS") of fuel switching;
(iv) Within three years from the ef-
"fective date of this waiver, the Gov-
ernor of Guam shall -submit.to the EPA
a complete request that the Cabras-
Piti area be redesignated to attain-
ment for the sulfur dioxide NAAQS;
(v) Electric generating units to be
constructed in the Cabras-Piti area
must submit applications for PSD per-
mits as though the area had been re-
designated to attainment for the sulfur
dioxide NAAQS:
(vi) The Cabras-Piti, area electric
generating units shall comply with the
1247
-------
id ii;;,11"!",:1,
S "I!''
"'•ip
-------
Monday
August 25, 1997
Part VIII
Environmental
Protection Agency
40 CFR Part 68
List of Regulated Substances and
Thresholds for Accidental Release
Prevention; Final Rule
4512
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45130 Federal Register / Vol. 62, No. 164 / Monday, August 25, 1997 / Rules and Regulations
": " '•'•'gNWIK&toME'FJtAt; PROTECTION
AGENCY
4QCFfiPart68 '
"'; j^L-^BSi-a]""" ^ ""I
™ |;:;;!' List of Regulated Substance's and
:|||r )Qiresi]ipld,sifoiri,Accidental Release,
"'" ! ;!!" Prevention"
,;,,_, j,.;,^ AQENCJY,:, Environmental Protection
Category
Chemical
manufactur-
ers.
Petrochemical
Other manu-
facturers.
ACTON':" Final rule.
Eiki
I g i i i i in in i : • .• • '! HIK,!'
SUMMARY: The Environmental Protection
Agency (EPA) is taking final action to
modify the list of regulated substances
and threshold quantities authorized by
section 1 12(r) of the Clean Air Act as
amended. EPA is vacating the listing
and related threshold for hydrochloric
acid solutions with less than 37%
concentrations of hydrogen chloride.
The current listing and threshold for all
other regulated substances, including
hydrochloric acid solutions with 37% or
greater cdhcenlrations and the listing
and threshold for anhydrous hydrogen
chloride, are unaffected by today's
rulemaklng. Today's action implements,
in part, a settlement agreement between
EPA and the General Electric Company
(GE) to resolve GE's petition for review
of the rulemaking listing regulated
substances and establishing thresholds
under .the accidental release prevention
'regulations.
DATES: This rule is effective August 25,
; 19,97. ........................................
ADDRESSES: Docket: The docket for this
; rate making is A-97-28. This rule
Mrien'S a final rule, the docket for
which is A-91-74. The docket may be
inspected between 8:00 a.m. and 5:30
p.rrK, Monday through Friday, at EPA's
Air Docket, Room Ml 500. Waterside
^fvtel'J. ..... I5l M ft. SWl Washington, DC
2<||60; telephone (202) 260-7548. A
r|lsdriable fee may be charged for
' " " ' ' ' '"
ti yyiiplesalers „.
Federal
sources.
Example of regulated entities
Industrial inorganics.
Plastics and resins.
Pulp and paper mills, primary
metal production, fab-
ricated metal products,
electronic and other elec-
tric equipment, transpor-
tation equipment, industrial
machinery and equipment,
food processors.
Chemical distributors.
Defense and energy installa-
tions.
t _
FOR FURTHER INFORMATION CONTACT : Sicy
Jacob, Chemical Engineer, Chemical
, . Emergency Preparedness and
Prevention Office, Environmental
Protection Agency, MC 5104, 401 M St.,
SW. Washington. DC 20460. (202) 260-
7249.
N SUPPLEMENTARY INFORMATION : ''""' ' .....
Regulated Entities
Entities potentially affected by this
action Include the following types of
facilities if the facility has more than the
15,000-pound threshold quantity of
hydrochloric acid solutions with
concentrations of less than 37%
hydrogen chloride.
This table is not intended to be
exhaustive, but rather provides a guide
for readers regarding entities likely to be
affected by this action. This table lists
types of entities that the EPA is now
aware could potentially be affected by
this action. Other types of entities not
listed in the table could be affected. To
determine whether your facility is
affected by this action, you should
carefully examine today's notice. If you
have questions regarding the
applicability of this action to a
particular entity, consult the person
listed in the preceding For Further
Information Contact section.
The following outline is provided to
aid in reading this preamble to the rule:
Table of Contents
I. Introduction and Background
A. Statutory Authority
B. Regulatory History
C. List Rule Litigation
n. Discussion of the Final Rule and Public
Comments
HI. Judicial Review
IV. Required Analyses
A. Executive Order 12866'
B. Regulatory Flexibility
C. Paperwork Reduction
D. Unfunded Mandates Reform Act
E. Submission to Congress and the General
Accounting, Office
I. Introduction and Background
A. Statutory Authority
This final rule is being issued under
sections 112(r) and 301 of the Clean Air
Act (Act) as amended.
B. Regulatory History
The Clean Air Act (CAA or Act),
section 112(r), requires EPA to
prbm'ulgate'ah initial list of at least 100
substances ("regulated substances")
that, in the, event of an accidental
release, are known to cause or may be
reasonably expected to cause death,
injury, or serious adverse effects to
human health and the environment. The
CAA also requires EPA to establish a
threshold quantity for each chemical at
the time of listing. Stationary sources
that have more than a threshold
quantity of a regulated substance are
subject to a'ccident prevention
regulations promulgated under CAA
section 112(r)(7), including the
requirement to develop risk
management plans.
On January 31,1994. EPA
promulgated the list of regulated
substances and thresholds that identify
stationary sources subject to the
accidental release prevention
regulations (59 FR 4478) (the "List
Rule"). This list included hydrochloric
acid solutions with concentrations of
30% or greater. Such solutions were
assigned a threshold quantity of 15,000
. pounds. EPA subsequently promulgated
a rule requiring owners and operators,of
stationary sources with listed
substances above their threshold
quantities to develop programs
addressing accidental releases and to
make publicly available risk
management plans ("RMPs")
summarizing these programs. (61 FR
31668, June 20, 1996) (the "RMP Rule").
For further information on these
regulations, section 112(r), and related
statutory provisions, see these notices.
These rules can be found in 40 CFR part
68, "Chemical Accident Prevention
Provisions," and collectively are
referred to as the accidental release
prevention regulations.
C. List Rule Litigation
The General Electric Company (GE)
filed a petition for judicial review of the
List Rule regarding EPA's listing criteria
under the List Rule, the listing of certain
substances in the List Rule, the setting
Of threshold quantities for certain
substances in particular and all
regulated toxic substances generally,
and the petition process for adding and
deleting regulated substances to the list.
Recognizing that the public's interest
would best be served by settlement of
all issues raised in this litigation, GE
and EPA agreed to a settlement on April
7, 1997. Under the terms of the
settlement agreement, on May 22, 1997
(62 FR 27992), EPA proposed to vacate
the listing and related threshold for
hydrochloric acid solutions with less
than 37% concentrations of hydrogen
chloride. EPA is today taking final
action on this proposal.
n. Discussion of the Final Rule and
Public Comments
Today's final rule adopts without
modification the May 22, 1997 (62 FR
27992), proposal to vacate provisions of
the accidental release prevention
regulations that specifically address
hydrochloric acid solutions with less
than 37% hydrogen chloride. The basis
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Federal Register I Vol.. 62. No. 164 / Monday. August 25. 1997 /Rules and Regulations 45333
and purpose of this rulemaking is set
out in the above referenced proposal. As
discussed in the proposal, this action
addresses the essential element of the
dispute between EPA and GE while
eliminating the collateral uncertainty
that would exist about the regulatory
status of the remaining chemicals if the
litigation proceeded. EPA has
vigorously advocated responsible
accident prevention efforts by industry
even before enactment of section 112(r).
The Agency is concerned that
prolonging this dispute may encourage
owners and operators of sources who
are solely concerned about regulatory
compliance to defer engaging in
responsible accident prevention '
activities. By implementing the
settlement agreement with GE and by
implementing the settlement agreements
reached in the other two challenges to
the List Rule, EPA will be able to retain
on the list of regulated substances
nearly all of the chemicals originally
listed and eliminate uncertainty about
their regulatory status. As also
discussed in the proposal, the general
duty clause of section 112(r)(l) and the
retention on the list of solutions with
concentrations of 37% or greater
ensures that today's rule is protective of
public health in several respects.
EPA received 11 letters commenting
on the proposed rule. All of the
comments were from industry and trade
associations. All commenters supported
vacating the listing of hydrochloric acid
in concentration below 37%. Several of
them specifically supported EPA's
stated position that this proposal is
protective of public health in several
respects and that this action will
eliminate uncertainty in the regulated
community regarding RMP compliance
for hydrochloric acid solutions.
Several commenters brought up
technical issues regarding the basis for
- listing hydrochloric acid in aqueous
solution. EPA stated in the proposed
rule that it was not reopening the
rulemaking record on the listing of
hydrochloric acid within the range of
30% to 37%. Any technical issues
related to the listing of hydrochloric , •
acid solutions will be addressed if EPA
undertakes future regulatory actions
regarding such solutions. In agreeing to
the settlement with GE and in this
related rulemaking, EPA has not
conceded or acknowledged any
technical deficiencies in its original
listing of HC1 solutions with less than
37% concentration.
One commenter said that solutions at
37%, as well as those below 37%,
should be delisted. EPA considers this
issue outside the scope of the current
rulemaking. The listing of solutions, at
37% and above was decided in the
original List Rule and was riot reopened
by this rulemaking; objections to the
listing of 37% solutions should have
been made by seeking review of the
original List Rule and are now untimely.
To the extent that the commenter
wishes to reopen the technical merits of
listing solutions that are precisely 37%
HC1, EPA would address that issue ,
along with other technical issues if EPA
were to take further action on
hydrochloric acid solutions.
Two commenters referred to
comments submitted on the original
proposal to list hydrochloric acid
solution. EPA addressed comments on
the proposed List Rule when it
promulgated the final rule Qanuary 31,
1994).
Several commenters questioned the
accident history of hydrochloric acid
solutions arid stated that EPA's accident
database does not support listing
hydrochloric acid solutions. To the
extent to which it is relevant, EPA will
consider the up-to-date accident history
if it takes any further regulatory actions
on the listing of hydrochloric acid
'solutions.
One commenter stated that EPA
overestimated the number of regulated
sources that would not have to comply
with the List rule as a result of this
vacatur. EPA's estimate of 800 sources
was based on preliminary, conservative
assumptions that EPA used to determine
thata regulatory impact analysis was
not required and was not related to the
basis for the proposal. The number and
type of sources that are affected by a
listing are irrelevant under sections
112(r)(3) and (4). The Agency recognizes
that this estimate may represent a
conservative picture of the effect of the
rule on the regulated community.
One commenter stated his '
understanding that hydrochloric acid
solutions of 36.94% would not be
covered by the RMP rule. EPA confirms
that all solutions that can be accurately
measured at less than 37% are
excluded.
EPA also proposed on May 22, 1997,
to extend the RMP rule compliance
deadline for hydrochloric acid solutions
with concentrations of 30% to 37% if
EPA did not take final action to vacate
the hydrochloric acid listing as
proposed. Because EPA is vacating the
listing of such solutions by the final
action today, no action is necessary on
this alternative proposal. If EPA were to
relist these solutions in the future, then
sources would have three years from the
new listing to comply with the RMP
rule.
Finally, as stated in the proposal, EPA
wishes to clarify that this rule, will not
affect in any way the listing of
anhydrous hydrogen chloride.
Anhydrous hydrogen chloride will
retain its 5000-pound threshold.
Threshold determination provisions for
regulated toxic substances would apply
to anhydrous hydrogen chloride.
Anhydrous mixtures of hydrogen
chloride would be subject to the mixture
provisions for regulated toxic
substances. Aqueous mixtures of
hydrochloric acid would be affected to
the extent that the minimum
concentration cutoff would be revised.
Based on the reasons discussed above,
EPA is vacating the listing in part 68 of
•hydrochloric acid solutions at
concentrations of less than 37% (from
30% up to 37%) hydrogen chloride.
• Solutions of 37% or greater will not be
affected fay today's rule and remain on
the list. In addition, EPA is vacating
other provisions of the accidental
release prevention regulations insofar as
they apply to hydrochloric acid
solutions at concentrations less than
37% hydrogen chloride. For example,
the reference to "hydrochloric acid
(cone 30% or greater)" in the toxic
endpoint table for 40 CFR part 68 will
be revised to refer to concentrations of
37% or greater.
ffl. Judicial Review
Under section 307{b)(l) of the Clean
Air Act (CAA), judicial review of the
actions taken by this final rule is
available only on the filing of a petition'
for review in the U.S. Court of Appeals
for the District of Columbia Circuit
within 60 days of today's publication of
this action. Under section 307 (b) (2) of
the CAA. the requirements that are
subject to today's notice may not be
challenged later in civil or criminal
proceedings brought by EPA to enforce
these requirements.
IV. Required Analyses
A. Executive Order 12866
Under Executive Order 12866 (58 FR
51735, October 4, 1993), the Agency
must judge whether the regulatory
action is "significant," and therefore
subject to OMB review and the
requirements of the Executive Order.
The Order defines "significant
regulatory action" as one that is likely
to result in a rule that may:
(1) Have an annual effect on the
economy of $100 million or more or
adversely affect in a material way the
economy, a sector of the economy,
productivity, competition, jobs, the
environment, public health or safety, or
state, local, or tribal government or
communities;
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I II I' 'HI 1 I | _ i, ,',„,..
4SI32 Federal Register / Vol. 62. No. 164 / Monday, August 25. 1997 / Rules and Regulations
11
(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
(4) Raise novel legal or policy issues
arising out of legal mandates, the
President's priorities, or the principles
set forth in th.e Executive Order.
It has been determined that this rule
is not a "significant regulatory action"
under the terms of Executive Order
12866 and, therefore, is not subject to
OMB review.
B. Regulatory Flexibility
EPA has determined that it is not
necessary to prepare a regulatory
flexibility analysis in connection with
this fjnal rule. EPA has also determined
that this rule will not have a significant
negative economic impact on a
substantial number of small entities.
This final rule will not have a
significant negative impact on a
substantial number of small entities
because it will reduce the range of
hydrochloric acid solutions listed under
part 68 and thus reduce the number of
stationary sources subject to part 68.
C, Paperwork Reduction
This rule does not include any
information collection requirements for
OMB to review under the provisions of
the Paperwork Reduction Act.
D, Unfunded Mandates Reform Act
I'itle II of ,tjjg Unfunded Mandates
Reform Act o? 1995 (UMRA), Pub. L.
104-4, establishes requirements for
Federal agencies to assess the effects of
their regulatory actions on State, local,
arid crjlbal governments and the private
sector, .Under.section 202of the UMRA,
E?A generally must prepare a written
statement, including a cost-benefit
analysis, for proposed and final rules
with "Federal mandates" that may
result in expenditures to State, local,
and tribal governments, in the aggregate,
or to the private sector, of S100 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 of 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.
EPA has determined that this rule
does not contain a Federal mandate that
may result in expenditures of $100
million or more for State, local, and
tribal governments, in the aggregate, or
the private sector in any one year.
Today's rule will reduce the number of
sources subject to part 68. Thus, today's
rule is not subject to the requirements
of sections 202 and 205 of the UMRA.
For the same reason, EPA has
determined that this rule contains no
regulatory requirements that might
significantly or uniquely affect small
governments.
E. Submission to Congress and the
General Accounting Office
Under 5 U.S.C. 801 (a) (1) (A) as added
by the Small Business Regulatory
Enforcement Fairness Act of 1996, EPA
submitted 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 General Accounting
Office prior to publication of the rule in
today's Federal Register. This rule is
not a "major rule" as defined by 5
U.S.C. 804(2).
List of Subjects in 40 CFR Part 68
Environmental protection, Chemicals,
Chemical accident prevention,
Extremely hazardous substances.
Incorporation by reference,
Intergovernmental relations. Hazardous
substances. Reporting and
recordkeeping requirements.
Dated: August 19, 1997.
Carol M. Browner,
Administrator.
For the reasons set out in the
preamble, title 40, chapter I, subchapter
C, part 68 of the Code of Federal
Regulations is amended as follows:
PART 68—CHEMICAL ACCIDENT
PREVENTION PROVISIONS
1. The authority citation for part 68
continues to read as follows:
Authority: 42 U.S.C. 7412(r), 7601(a)(l),
7661-76615.
§ 68.130 Tables 1 and 2 [Amended]
2. In §68.130 List of substances. Table
1 is amended by revising the listing in
the column "Chemical name" from
"Hydrochloric acid (cone 30% or
greater)" to "Hydrochloric acid (cone
37% or greater)."
3. In § 68.130 List of substances. Table
2 is amended by revising the listing in
the column "Chemical name" from
"Hydrochloric acid (cone 30% or
greater)" to "Hydrochloric acid (cone
37% or greater)," and by adding a note
"d" between note "c" and "e" at the
end of the table to read as follows:
"d Toxicity of hydrogen chloride,
potential to release hydrogen chloride,
and history of accidents."
Appendix A of Part 68 [Amended]
4. Appendix A of Part 68 is amended
by revising the listing in the column
"Chemical name" from "Hydrochloric
acid (cone 30% or greater)" to
"Hydrochloric acid (cone 37% or
greater)."
[FR Doc. 97-22511 Filed 8-22-97: 8:45 am]
BILLING CODE 6560-50-P
-------
Tuesday
January 6, 1998
Part IV
Environmental
Protection Agency
40 CFR Part 68
List of Regulated Substances and
Thresholds for Accidental Release
Prevention; Final Rule
63
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640
Federal Register 7 Vol. 63, No. 3 / Tuesday, January 6, 1998 / Rules and Regulations
ENVIRONMENTAL PROTECTION
I ...... it^ENCY, , ......... , ..... ..... „ ,t ...... ,,.
40CFRPart68
: ........ ! ..... fl:RL-S940-4] .........
RIN20SO-AE35
; Ust of Regulated Substances and
" Thresholds for Accidental Release
Prevention; Amendments
AGENCY: Environmental Protection
rt6'N:' Final rule.
~,t Si!|MAf|y: The, irjy^P"!?1 ent^ Pffif6^0!1
''' '""Agency" (EPA)' is modifying the rule
listing regulated substances and
threshold quantities under section
112(r) of the Clean Air Act as amended.
EPA Is deleting the category of Division
1,1 explosives (as listed by DOT) from
the list of regulated substances.
isJ'1 Regulated flammable substances in
pi II gasoline used as fuel and in naturally
jjjjJI J' ' occurring hydrocarbon mixtures prior to
I
initial processing are exempted from
threshold quantity determinations, and
the provision for threshold
determination of flammable substances
in a mixture is clarified. The definition
of stationary source is modified to
clarify the exemption of transportation
and storage incident to transportation
and to clarify that naturally occurring
hydrocarbon reservoirs are not
stationary sources or parts of stationary
sources. In addition, EPA is clarifying
that the Chemical Accident Prevention
Provisions do not apply to sources
located on the Outer Continental Shelf.
EPA believes these changes will better
focus accident prevention activities on
stationary sources with high hazard
operations and reduce duplication with
other similar requirements.
DATES: This rule is effective January 6,
1998.
ADDRESSES: Docket: The docket for this
rulemaking is A-96-O8. This rule
amends a final rule, the docket for
which is A-91-74. The docket may be
inspected between 8:00 a.m. and 5:30
p.m.; Monday through Friday, at EPA's
Air Docket, Room Ml500, Waterside
Mall, 401 M St., SW, Washington, DC
20460; telephone (202) 260-7548. A
reasonable fee may be charged for
copying.
FOR FURTHER INFORMATION CONTACT:
Vanessa Rodriguez, Chemical Engineer,
(202) 260-7913, Chemical Emergency
Preparedness and Prevention Office,
U.S. Environmental Protection Agency,
MCT5101, 401 M St. SW, Washington,
DC 20460, or the Emergency Planning
- and Community Right-to-Know Hotline
at 1-800-424-9346.
SUPPLEMENTARY INFORMATION :
Regulated Entities
Entities potentially affected by this
action are those stationary sources that
have more than a threshold quantity of
a regulated substance in a process.
Regulated categories and entities
include:
K I "I
i!1',: ii'll
- :•::;
, :«:.
,';, ^ ;
Category
Chemical Manufacturers
Petrochemical
Other Manufacturing '.
Agriculture
Public Sources
Utilities
Others
Federal Sources .......
Examples of regulated entities
Industrial organics & inorganics, paints, Pharmaceuticals, adhesives,
sealants, fibers.
Refineries, industrial gases, plastics & resins, synthetic rubber.
Electronics, semiconductors, paper, fabricated metals, industrial ma-
chinery, furniture, textiles.
Fertilizers, pesticides.
Drinking and waste water treatment works.
Electric and Gas Utilities.
Oil and gas exploration and production, natural gas processing, food
and cold storage, propane retail, warehousing and wholesalers.
Military and energy installations.
;;;j;f !|';; "| ;Thi§ table is not intended to be ..
exhaustive, but rather provides a guide
for readers regarding entities likely to be
affected by this action. Other types of
entities not listed in the table also could
be affected. To determine whether a
Stationary source is affected by this
acjion, carefully examine the provisions
.'qf today's notice. If you have questions
'fijfif regarding the applicability of this action
- -""',''toa'particular entity, consult the person
the preceding FOR FURTHER
-"- - - fc'Sftf Afct section.
The following outline is provided to
aid in reading mis preamble:
Table of Contents
1, Introduction and Background
A, Statutory Authority
B, Regulatory History
C. List Rule Litigation
H. Discussion of" the Final Rule and Public
i J "!!;, Pqmments
HI i .A.' Explosives
B, Regulated Flammable Substances in
Gasoline and in Naturally Occurring
l-fydrocarbon Mixtures
C. Clarification of Threshold Determination
of Regulated Flammable Substances in
Mixtures
D. Definition of Stationary Source
E. Applicability to Outer Continental Shelf
HI. Summary of Revisions to the Rule
IV. Judicial Review
V. Required Analyses
A. Executive Order 12866
B. Regulatory Flexibility
C. Paperwork Reduction
D. Unfunded Mandates Reform Act
E. Submission to Congress and the General
Accounting Office
F. National Technology. Transfer and
Advancement Act
I. Introduction and Background •
A. Statutory Authority
This final rule is being issued under
sections 112(r) and 301 of the Clean Air
Act (CAA or Act) as amended.
B. Regulatory History
The CAA, section 112(r), requires EPA
to promulgate ah initial list of at least
100 substances ("regulated substances")
that, in the event of an accidental
release, are known to cause or may be
reasonably expected to cause death,
injury, or serious adverse effects to
human health and the environment. The
CAA also requires EPA to establish a
threshold quantity for each chemical at
the, time of listing. Stationary sources
that have more than a threshold
quantity of a regulated substance are
subject to accident prevention
regulations promulgated under CAA
section 112(r)(7), including the
requirement to develop risk
management plans.
On January 31, 1994, EPA
promulgated the list of regulated
substances and thresholds that identify
stationary sources subject to the
accidental release prevention
regulations (59 FR 4478) (the "List
Rule"). The listed substances included
77 acutely toxic substances, 63
flammable gases and volatile flammable
liquids, and Division 1.1 high explosive
substances as listed by the United States
Department of Transportation (DOT) in
49 CFR 172.101. EPA subsequently
promulgated a rule requiring owners
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Federal Register / Vol. 63. No. 37 Tuesday, January 6, 1,998 / Rules and Regulations 643
and operators of stationary sources with
listed substances above their threshold
quantities to develop programs
addressing accidental releases and to
make publicly available risk
management plans ("RMPs"),
summarizing these programs (61 FR
31668, June 20, 1996) (the "RMP Rule").
For further information on these
regulations, section 112(r). and related
statutory provisions, see these notices.
These rules can be found in 40 CFR part
68, "Chemical Accident Prevention
Provisions." and collectively are
referred to as the accidental release
prevention'regulations.
C. List Rule Litigation
The American Petroleum Institute
(API) and the Institute of Makers of
Explosives (IME) filed petitions for
judicial review of the .List Rule
(American Petroleum Institute v. EPA,
No. 94-1273 (D.C. Cir.) and
consolidated cases). On March 28, 1996,
EPA made available for public comment
under CAA section 113(g) proposed
settlement agreements with API and
IME (61 FR 13858, March 28; 1996).
Consistent with these agreements, EPA
proposed amendments to the List Rule
on April 15, 1996 (61 FR 16598). On
June 20. 1996, EPA promulgated a stay
of certain provisions of the List Rule
that were affected by the proposed
amendments (6.1 FR 31730). EPA is
• today taking final action on the
amendments proposed in April 1996.
n. Discussion of the Final Rule and
Public Comments
In this final rule, EPA is taking the •
following actions to amend the List
Rule: delisting explosives; exempting
from threshold determination regulated
flammable substances in gasoline and in
naturally occurring hydrocarbon
mixtures prior to initial processing;
clarifying the provision for threshold
determination of flammable substances
in mixtures to exempt mixtures that do
not have a National Fire Protection .
Association (NFPA) flammability hazard
rating of 4; modifying the definition of
stationary source to -clarify the
exemption of transportation and storage
incident to transportation and to clarify
that naturally occurring hydrocarbon
reservoirs are not stationary sources or
parts of stationary sources; and
clarifying that the chemical accident
prevention provisions do not apply to
sources located on the Outer,
Continental Shelf ("OCS sources").
These amendments were proposed on
April 15, 1996. EPA received 37 letters
commenting on the proposal. Major
comments are discussed below.
Summaries of all comments and the
Agency's responses can be found in the
summary and response to comments
document in the docket.
A. Explosive^ '"*' "
EPA is amending the List Rule to
delete the category of high explosives
from the iist of regulated substances.
Explosives were initially listed because
of their potential to cause offsite effects
from blast waves. In addition, EPA
believed that there existed potential
gaps in emergency planning and
response communication that made risk
management planning appropriate for
sources with explosives. In accordance
with the Settlement Agreement, IME has
developed and will implement safety
practices that will provide additional
information and enhance the
coordination between explosives
facilities and the emergency planners
and responders. As discussed in the
preamble to the proposed rule of April
15, 1996, EPA concluded that current
regulations and current and
contemplated industry practices
promote safety and accident prevention
in storage, handling, transportation, and
use of explosives. As a result, these
regulations and practices adequately
protect the public and the environment
from the hazards of accidents involving
explosives: The Agency believes these
actions effectively close the remaining
gap, in emergency planning and
response communications. Therefore,
EPA is taking final action to delist
explosives from the list of regulated
substances under section 112 (r).
EPA received six comment letters on
the proposal to delist explosives. All the
commenters supported EPA's proposal,
citing current regulations, current and
contemplated industry practices, and
the regulatory burden imposed by
listing explosives,
B. Regulated Flammable Substances in
Gasoline and in Naturally Occurring
Hydrocarbon Mixtures"
EPA is taking final action to provide
specific exemptions from threshold
determination for regulated flammable
substances in gasoline used as fuel for
internal combustion engines and for
regulated substances in naturally
occurring hydrocarbon mixtures prior to
initial processing in a petroleum
refining process unit or a natural gas
processing plant. These exemptions
reflect EPA's original inte'nt to exempt
.flammable mixtures that do not meet the
criteria for a National Fire Protection
Association (NFPA) flammability hazard
rating of 4 and clarify the regulatory ,
status of gasoline and naturally
occurring hydrocarbon mixtures.
Naturally occurring hydrocarbon
mixtures would include any or any
combination of the following: natural
gas condensate, crude oil. field gas, and
produced water. This rule includes
definitions of these substances as well
as definitions of natural gas processing
plant arid petroleum refining process
unit.
EPA is making minor changes to the
definitions proposed for natural gas ' (
processing plant and petroleum refining
process unit. The North American
Industrial Classification System
(NAICS) code has been added to the
definition for natural gas processing
plant in this final rule. In addition, part
of the proposed definition has been
dropped, because it included the term
being defined and, as a result,
potentially could cause confusion. The
NAICS code also has been added to the
definition of petroleum refining process
unit. The proposed definition of
petroleum refining process unit
included the Standard Industrial
Classification (SIC) code (which is still
cited in the definition); however, SIC
codes have been replaced by NAICS
codes. ' '
EPA received 12 letters in support of
the gasoline exemption. No comments
were submitted opposing this
exemption. Several of the commenters
who supported the exemption also
suggested broadening the exemption to
include blendstocks, natural gasolines,
and other fuels. Several suggestions
were made for clarifying the gasoline
exemption.
EPA does not believe the exemption
should be broadened. Individual
flammable substances that do not meet
the criteria for NFPA 4 for flammability
were not considered for listing as
flammabies in development of the list of
regulated substances. Although
substances such as blendstocks and
natural gasoline are not specifically
exempted, any flammable mixtures,
including blendstocks and natural
gasoline, that do not meet the criteria for
an NFPA rating of 4 for flammability are
exempt from threshold determination
(see Clarification of Threshold
•Determination of Regulated Flammable.,
Substances in Mixtures, discussed
below). EPA believes that substances
and mixtures that meet the criteria for
NFPA 4, including blendstocks and
fuels, should be covered by the rule,
regardless of their use. EPA believes
such substances have the same intrinsic
hazards whether they are used as
gasoline blendstocks, as fuels, or for
other purposes. EPA's analysis indicates
that risks associated with the storage
and handling of flammable substances
are a function of the properties of the
materials, not their end use. EPA is ,
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Federal Register / Vol. 63, No. 3 / Tuesday, January 6, 1998 / Rules and Regulations
'SIB
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ecernpting gasoline because it does not
meet the NFPA 4 criteria, and EPA
believes it does not represent a
significant threat to the public of vapor
cloud explosions.
EPA received 16 letters supporting the
exemption of naturally occurring
hydrocarbons prior to initial processing.
One commenter suggested modifying
die exemption to incorporate site-
specific factors because conditions
fiSnduciye to vapor cloud explosions
might exist at some facilities with
exempted flammable substances,
particularly in the case of oil and gas
production facilities located adjacent to
chemical production facilities. EPA
recognizes "that there may be cases
Where a facility may not be subject to
the RMP requirements because of this
exemption, but where the potential for
vapor cloud explosions may exist.
Neither Congress nor EPA intended the
List Rule to capture every substance that
may pose a hazard in particular
circumstances. Instead, the statute
required EPA to select the chemicals
posing the greatest risk of serious effects
from accidental releases. To implement
'"tijese criteria, EPA focused primarily on
, chemicals'that posed the most
significant hazards because site-specific
factors vary too greatly to be considered
at the listing stage of regulation. EPA
fielieyes the hazards of naturally
occurring hydrocarbon mixtures prior to
entry into a natural gas processing plant
or petroleum refining process unit do
,np'i' vygrraht regulation. The general duty
'clauseipf section112(r)(l) would apply
'when site-specific factors" make an
unlisted chemical extremely hazardous.
^Iso^ the particular risk cited by the
' |<||>i?iip''lnSe'ri probably would be
addressed by the RMP Rule even with
the exemption as promulgated today. In
the case of a chemical facility located
adjacent to an oil and gas production
facility, the owner or operator of the
chemical facility is likely to have
processes covered due to other regulated
substances and would have to consider
site-specific conditions such as the
presence of an adjacent oil and gas
production facility. Therefore, it is
inappropriate to condition this
exemption on site-specific factors.
C. Clarification of Threshold
Determination of Regulated Flammable
Substances in Mixtures
To clarify threshold determination for
regulated flammable substances in
mixtures, EPA is taking final action to
provide that, for mixtures that have one
percent or greater concentration of a
regulated flammable substance, the
entire weight of the mixture shall be
treated as the regulated substance unless
the owner or operator can demonstrate
that the mixture does not have an NFPA
flammability hazard rating of 4, as
defined in the NFPA Standard System
for the Identification of Fire Hazards of
Materials, NFPA 704-1996.
In its proposed rule, to define NFPA
4, EPA cited and proposed to
incorporate by reference NFPA 704,
Standard System for the Identification
of Fire Hazards of Materials (1990
edition). For the definition and
determination of boiling point and flash
point, EPA cited and proposed to
incorporate by reference NFPA 321,
Standard on the Basic Classification of
Flammable and Combustible Liquids
(1991 edition). In this final rule, EPA is
updating these references and
incorporating by reference the 1996
edition of NFPA 704 and the 1996
edition of NFPA 30, Flammable and
Combustible Liquids Code, which
replaces NFPA 321.
Nine comments were submitted
supporting this clarification. No
opposing comments were submitted.
D. Definition of Stationary Source
EPA is promulgating the amendments
to the definition of stationary source
that were proposed on April 15, 1996.
First, EPA is clarifying that the
exe'mption for regulated substances in
transportation, or in storage incident to
such transportation, is not limited to
pipelines. In addition, EPA is modifying
the definition of stationary source to
clarify that naturally occurring
hydrocarbon reservoirs are not
stationary sources or parts of stationary
sources. Finally, EPA is modifying the
definition of stationary source to clarify
that exempt transportation shall
include, but not be limited to,
transportation activities subject to
regulation or oversight under 49 CFR
parts 192,193, or 195, as well as
transportation subject to natural gas or
hazardous liquid programs for which a
state has in effect a certification under
49 U.S.C. section 60105.
EPA considers the transportation
exemption to include storage fields for
natural gas where gas taken from
pipelines is stored during non-peak
periods, to be returned to the pipelines
when needed. Such storage fields
include, but are not limited to, depleted
oil and gas reservoirs, aquifers, mines,
and caverns (e.g., salt caverns). For
purposes of this regulation, this type of
storage is incident to transportation and,
therefore, is not subject to the RMP rule.
The transportation exemption also
applies to liquefied natural gas (LNG)
facilities 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. These
facilities include those used to liquefy
natural or synthetic gas or used to
transfer, store, or vaporize LNG in
conjunction with pipeline
transportation.
EPA believes there still may be
potential for confusion regarding the
jurisdiction and regulatory
responsibility of EPA and DOT for
pipelines and for transportation
containers at stationary sources.
"Transportation in commerce" is
defined by DOT pursuant to Federal
Hazardous Materials Transportation
Law (Federal HAZMAT Law, 49 U.S.C.
sections 5107-5127). As a result of
continued questions regarding the'scope
of Federal HAZMAT Law and the
applicability of the regulations issued
thereunder, the DOT is currently
working to better delineate and more
clearly define the applicability of its
regulations. DOT currently
contemplates clarifying its jurisdiction
through the rulemaking process. As a
result, there may be a future need for
EPA to further amend the definition of
stationary source to better comport with
DOT clarifications or actions. The
Agency will continue to work closely
with DOT to minimize confusion
regarding transportation containers and
will coordinate with DOT to ensure that
compatible interpretations about
regulatory coverage are provided to the
regulated community.
EPA received 15 letters in support of
the exemption of transportation -
activities from the definition of
stationary source. No one opposed this
exemption. A number of commenters,
however, believed the modifications
would not eliminate overlap and
confusion between EPA and DOT rules.
A number of commenters also favored
exempting from the stationary source
definition transportation containers no
longer under active shipping papers and
transportation containers connected to
equipment for purposes of temporary
storage, loading, or unloading. Some
commenters stated that EPA would be
undermining DOT'S-authority by
regulating activities that are under DOT
jurisdiction. Four commenters
recommended exempting all containers
that are suitable for transportation.
EPA'developed the transportation
exemptions discussed'here in
consultation with DOT. EPA's
regulations do not supersede or limit
DOT's authorities and, therefore, are in
compliance with CAA section 310. EPA
believes these provisions are consistent
with other EPA regulations, such as the
Emergency Planning and Community
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Federal. Register / Vol. .63. No. 3 / Tuesday, January 6. 1998 / Rules and Regulations 643
Right-to-Know Act (EPCRA) regulations
under parts 355 and 370. EPA disagrees
that suitability for transportation should
be the criterion for determining whether
a container should be considered part of
the stationary source. For example. EPA
believes that a railroad tank car
containing a regulated substance could
be considered a stationary source or part
of a stationary source, even though the
tank car is "suitable for transportation."
Such a tank car could remain at one
location for a long period of time,
serving as a storage container, and could
pose a hazard to the community. EPA
considers a container to be in
transportation as long as it is attached
to the motive power that delivered it to
the site (e.g., a truck or locomotive). If
a container remains attached to the
motive power that delivered it to the
site, even if a facility accepts delivery,
it would be in transportation, and the
contents would not be subject to
threshold determination. As stated
earlier, EPA will continue to work with
DOT to avoid regulatory confusion.
EPA agrees with commenters who
stated that active shipping papers may
not be a suitable criterion for
determining whether a container is in
transportation. EPA is aware that.
shipping papers are not always
generated, nor are they required under
DOT rules. Therefore, EPA has modified
the definition of stationary source to
remove the reference to active shipping
papers. EPA also has modified the
definition to remove the reference to
temporary storage. This reference may
have been confused with storage
incident to transportation.
EPA has received questions regarding
the statement in the stationary source
definition that properties shall not be
considered contiguous solely because of
a railroad or gas pipeline right-of-way.
In response to these questions, EPA is
clarifying this statement by deleting the
word "gas." EPA always intended that
neither a railroad right-of-way nor any
pipeline right-of-way should cause
properties to be considered contiguous.
E. Applicability to Outer Continental
Shelf
~ EPA is providing an applicability
exception for sources on the outer -
continental shelf (OCS sources) to
clarify that Part 68 does not apply to
these sources. This exception is
consistent with CAA section 328, which
precludes the applicability of EPA CAA
rules to such sources when such rules
are not related to attaining or
maintaining ambient air quality
standards or to the "prevention of
significant deterioration" provisions of
the CAA. Eleven commenters supported
this exception, and no one opposed it.
III. Summary of Revisions to the Rule
EPA is amending several sections of
part 68 of title 40 of the Code of Federal
Regulations.
In §68.3, the definition of stationary
source is revised. The revised definition
specifically states that naturally
occurring hydrocarbon reservoirs are
not stationary sources or parts of
stationary sources. The definition states
that exempt transportation includes, but
is not limited to, transportation
activities subject to oversight or
regulation under 49 CFR parts 192, 193,
or 195, as well as transportation subject
to natural gas or hazardous liquid
programs for which a state has in effect
a certification under 49 U.S..C. section
60105. In addition, the agency has made
non-substantive wording changes to
improve the clarity of this definition.
Several new definitions are added for
§ 68.3, for condensate, crude oil, field
gas, natural gas processing plant,
petroleum refining process unit, and
produced water. .
Section 68.10 is amended to clarify
that part 68 does not apply to OCS
sources.
Several revisions are made to §68.115
on threshold determination. Section
68.115(b)(2) is modified to state that the
entire weight of the mixture containing
a regulated flammable substance shall
be treated as the regulated substance
unless the owner or operator can
demonstrate that the mixture does not
have an NFPA flammability hazard
rating of 4. Another modification to
§ 68.115(b)(2) exempts from threshold
determination regulated flammable
substances in gasoline used as fuel in
internal combustion engines. Regulated
substances in naturally occurring
hydrocarbon mixtures (including
condensate, crude oil, field gas, and
produced water), prior to entry into a
natural gas processing plant or a
petroleum refining process unit, also are
exempt from threshold determination.
Section 68.115(b)(3), on concentrations
of a regulated explosive substance in 'a
mixture, is deleted, and §§68.115(b)(4),
68.115 (b) (5), and 68.115 (b) (6) are
redesignated as §§ 68.115 (b) (3),
68.115(b)(4),and68.115(b)(5), '
respectively.
Section 68.130 is modified by the
deletion of (a), explosiv.es listed by DOT
as Division 1.1. Section 68.130(b) is
redesignated as §§68.130(a), and
§§68.130(c)as68.'l30(b).
IV. Judicial Review
Under section 307 (b) (1) of the Clean
Air Act (CAA), judicial review of the
actions taken by this final rule is
available only on the filing of a petition
for review in the U.S. Court of Appeals
for the District of Columbia Circuit
within 60 days of today's publication of
this action. Under section 307 (b) (2) of
the CAA, the requirements that are
. subject to today's notice may not be
challenged later in civil or criminal
proceedings brought by EPA to enforce
these requirements.
V. Required Analyses
A. Executive Order 12866
Under Executive Order 12866 (58 FR
51735, October 4. 1993),'the Agency
must judge whether the regulatory
action is "significant," and therefore
subject to OMB review and the
requirements of the Executive Order.
The Order defines "significant
regulatory action" as one that is likely •
to result in a rule that may:
• (1) Have an annual effect on the
economy of $100 million or more or
adversely affect in a material way the
economy, a sector of the economy,
productivity, competition, jobs, the
environment, public health or safety, or
state, local, or tribal government 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
(4) 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^ therefore, is not subject to
OMB review.
B. Regulatory Flexibility
, EPA has determined that it is not
necessary to prepare a regulatory
flexibility analysis in connection with
this final rule. EPA has also determined
that this rule will not have a significant
negative economic impact on a
substantial number of small entities.
•This final rule will not have a
significant negative impact on a
substantial number of small entities
because it reduces the number of
substances that would be used to
identify stationary sources for regulation
and provides exemptions that will
reduce the number of stationary sources
subject to the accidental release
prevention requirements.
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Federal Register / Vol. 63, No. 3 / Tuesday, January 6, 1998 / Rules and Regulations
i ,, _ ,
'*' • ..... I
11 !W 'Ijilliiit '
" S
,
-lilt
C. Paperwork Reduction
This rule does not include any
Information collection requirements for
OMB to review under the provisions of
the Paperwork Reduction Act.
D, Unfunded Mandates Reform Act
Title n 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
.'' s||f^iiif rit. including a cost-benefit
analysis, for proposed and final rules
.-, with, "Federal mandates", that may
result In expenditures to State, local,
tUKJi tri&ai governments, in the aggregate,
otr tp tfie private sector, of SI00 million
™ iSJndfi in any one year. Before
jjfrSrnulgating an EPA rule for which a
'";;l
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Federal Register / Vol. 63. No. 3 / Tuesday. January 6. 1998 / Rules and Regulations
645
hydrogen production, isorherization,
polymerization, thermal processes, and
blending, sweetening, and treating
processes. Petroleum refining process .
units include sulfur plants.
******
Produced wafer means water
extracted from the earth from an oil or
natural gas production well, or that is
. separated from oil or natural gas after
extraction.
* * * * * .
Stationary source means 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. The term
stationary source does not apply to
transportation, including storage
incident to transportation, of any
regulated substance or any other
extremely hazardous substance under
the provisions of this part. A stationary
source includes transportation
containers used for storage not incident
to transportation and transportation
containers connected to equipment at a
stationary source for loading or
unloading. Transportation 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 naturally occurring
hydrocarbon reservoirs. Properties shall
not be considered contiguous solely
because of a railroad or pipeline right-
of-way.
* * * * * .
3. Section 68.10 is amended by
adding a paragraph (f) to read as
follows:
§68.10 Applicability.
* *, * * *
(f) The provisions of this part shall
not apply to an Outer Continental Shelf
("OCS") source, as defined in 40 CFR
55.2.
Subpart F—Regulated Substances for
Accidental Release Prevention
4. Section 68.115 is amended by
revising paragraph (b) introductory text
and paragraph (b)(2); removing
paragraph (b)(3); and by redesignating
paragraphs (b)(4) through (b) (6) as (b)(3)
through (b) (5) to read as follows:
§68.115 Threshold determination.
*****
(b) For the purposes of determining
whether more than a threshold quantity
of a regulated substance is present at the
stationary source, the following
exemptions apply:
* * * *' *.
(2) Concentrations of a regulated
flammable substance in a mixture, (i)
General provision. 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. 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
paragraph (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 determining whether a
threshold quantity is present at the
stationary source, the entire weight of
the mixture shall be treated as the
regulated substance unless the owner or
operator can demonstrate that the
mixture itself does not have a National
Fire Protection Association flammability
hazard rating of 4. The demonstration
shall be in accordance with the
definition of flammability hazard rating
4 in the NFPA 704, Standard System for
the Identification 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 D.C.;
or at the Office of Federal Register at
800 North Capitol St., NW. Suite 700,
Washington, D.C. Boiling point and
flash point shall be defined and
determined in accordance with NFPA
30, Flammable and Combustible Liquids
Code, 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 D.C.;
or at the Office of Federal, Register at
800 North Capitol St., NW, Suite 700, '
Washington, D.C. The owner or operator
shall document the National Fire
Protection Association flammability
hazard rating.
(ii) Gasoline. Regulated substances in
gasoline, when in distribution or related
storage for use as fuel for internal
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
refining process unit, regulated •
substances in naturally occurring
hydrocarbon mixtures need not be
considered when determining whether
more than a threshold quantity is
present at a stationary source. Naturally
occurring hydrocarbon'mixtures include
any combination of the following:
condensate, crude oil, field gas, and
produced water, each as defined in
§68.3 of this part. .
* * • * * *
§68.130 [Amended]
5. Section 68.130. is amended by
removing paragraph (a) and
redesignating paragraphs (b) and (c) as
paragrpahs (a) and (b). The tables to the
section remain unchanged.
[FR Doc. 98-267 Filed 1-5-98; 8:45 am]
BILLING CODE 6560-50-P
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Appendix B
(Reserved)
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Appendix C
PART 68 CONTACT INFORMATION
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Is! i;
'!» HOT : i! ;
i is J;MI
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AOPPENDKC C: PART68 CONTACTOQSFOmiMTON !
i'l SIM i r»;;l
Region or State
Region I , ......._".
• -- • " ' ', *- , ,i
f . , . r = J
• ff
"^1 , . - - "_ - - ' 1-
/- -—"-- V.
r^i 5 ? - - s ^ ^ : :f I
Connecticut
Maine
Massachusetts
Regional Office
US EPA Region 1 ',
Oltice of Environmental Stewardship (SFP) •
JFK Federal Building :
One Congress St. >
Boston. MA, 02203-221 1 :
(617)565-9232 ,
(617) 565-4939 FAX i
•Email: dinaido,ray®epa,gov |
Implementing Agency
: i : i '= - - - - m
' - - - - I I • f i =
I ; 1
•
Small Business Assistance
(S) = Slate only «oll free
(N) = National Toll free
. :
Glen Daraskevich
Small Business Assistance Program
Department of Environmental Protection
Environmental Quality Division
79 Elm St.
Hartford, CT 06106
860-424-3545
fax 860-424-4063
(S) 800-760-7036
glen.daraskevich@po.stale.ct.us
Brian Kavanah
Office of Pollution Prevention
Station 17
State House
Augusta, ME 04333
207-287-6188
fax 207-287-7826
(S) 800-789-9802
George Frantz
Office of Technical Assistance
Exec. Office of Environmental. Affairs
100 Cambridge St., Suite 2109
Boston, MA 02202
61 7-727-3260, ext. 631
fax 617-727-3827
george.frantz@state.ma.us
-------
Region or State
Regional Office ,
Implementing Agency
Small Business Assistance
(S) = State only toll free
(N) = National Toll free
New Hampshire
Rudolph Cartier, Jr. .
Air Resources Division
Department of Environmental Services
64 North Main Street
Caller Box 2033
Concord, NH 03302-2033
603-271-1379
FAX 603-271-1 381
(8)800-837-0656
cartier@dcsarsb.nir.com
Rhode Island
Pam Annarummo
Dept. of Environmental Management
Office of Technical & Customer Assistance
235 Promenade Street
Providence, RI 02908
401-277-66822, ext. 7204
fax 40 1-277-38 10
Vermont
Judy Mirro
VT Environmental Assistance Division
Laundry Building
103 S. Main St.
Waterbury.VT 05671
802-241-3745
fax 802-24 1-3273
Region 2*
JU8BPARegion2' ' , } < .'^ ; <;?„
Emergency Response and Renwdia! Division '
(MS2H) , /K— - ' *'>
1-2890 Woodbrldle Avenue ? *J " >
' Edison, Nl'0883W$79 I /• '* <;*,'''
^ (732^321^20 '
New Jersey
Bureau of Chemical Release Information and
Prevention
22 South Clinton Avenue
P.O. Box 424
Trenton, N.J. 08625-0424
609-633-7289 phone
609-633-7031 fax
sschiffman@dep.state.nj.us
Chuck McCarty
Office Permit Information and Assistance
NJDEPE
401 East Slate Street
CN 423 - 3rd Floor
Trenton, NJ 08625-0423
609-292-3600
fax 609-777- 1330
-------
^g-fLt-rf.'.:; i
Region or State
Regional Office
Implementing Agency
Small Business Assistance
(S} = Stale only loll free
(N)* National ToB free
New York
Marian Mudar
Environmenlal Program Manager
NYS Env. Fucil. Corp,
50 Wolf Rd.-Room 598
Albany, NY 12205
518-457-9135
fax 518-485-8494
(S) 800-780-7227
Puerto Rico
Maria L. Rivera
PREQB-SBAP
IIC-9IBox9197
Vega Alia, PR 00692-9607
787-767-8025, exl. 296
fax 787-756-5906
Virgin Islands
Marylyn Slapleton
Suite 231
8000 Nisky Center
Charlotte Amalie
St. Thomas, V.I, 00802
809-777-4577
fax 809-775-5706
Region 3
US EPA Region 3
CEPP and Site Assessment Section (3HS33)
J650ArebS(reel
Philadelphia, PA 19103-2029
{215}-814-3033
{2I5)-814-3254FAX
Email: shabazz.mikul@epamail.epa.gov
Delaware
Bob Banish
DEDNREC
715 OranthamLane
New Castle, DE
19720
302-323-4542
fax 302-323-4561
-------
Region or State
District of Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Regional Office
Implementing Agency
Small Business Assistance
(S) = State only toll free
(N) = National Toll free
Olivia Achuko
ERA/ARMD
2100 M.L. King Ave.,SE
Washington, DC 20020
202-645-6093, ext. 3071
fax 202-645-6102
Linda Moran
Small Business Assistance Program
Air & Radiation Mgmt. Adm.
MD Department of the Environment
2500 Broening Hwy. .
Baltimore, MD 21224
410-631-4158
fax 410-631-3896
(N) 800-433-1247
Cecily Beall
PRC Env. Management Inc.
6th Floor
1800 JFK Blvd.
Philadelphia.PA 19103
215-656-8709
fax 215-972-0484
(S) 800-722-4743
beallc@prcemi.com
Richard Rasmussen
VA DEQ/Air Division
Small Business Assistance Program
PO Box 10009
Richmond, VA 23240
804-698-4394
fax 804-698-4501
(S) 800-592-5482
rgrusmusse@deq.slate.va.us
Fred Durham
WV Office of Air Quality
Air Program Annex
1558 Washington St. East
Charleston, WV 25302
304-558-1217
fax 304-558-1222
(S) 800-982-2472 ,
-------
. !!! !i!! IS 3: „!!:
! !•;: IIN « if ::!i!
Region or State
Regional Office
Implementing Agency
Small Business Assistance
(S)*= Slate only toll free
(N)* National Toll free
Region 4
US EPA Region 4
Air Pesticides JUK! Toxics Maiufemen
Division
sjAUiuwi Federal Center
61 Forsylh Street, SW
AUwita,GA 30303
(404)562-9121
(404) 562-9095 PAX
Email: patmon.michelle@epa.gov
Alabama
James Moore
AL DEM Air Division
PO Box 301463
Montgomery, AL
36130-1463
334-271-7861
fax 334-271-7950
(N) 800-553-2336
Florida
Eve Rainy
State of Florida
Dept. of Community Affairs
Division of Emergency Management
2555 Shumard Oak Boulevard
Tallahassee, Fla. 32399-2100
(850)413-9914 phone
(850) 488-1739 fax
eve.rainey@DCA.STATE.FL.US
BethHardin
Division of Air Resources and Management
Florida Department of Environmental
Regulation
2600 Blair Stone Road
Tallahassee, Fla. 32399-2400
(850)921-9549 phone
(850) 922-6979 fax
Hardin_E@dep.state.fl.us
Elsa Bishop
Division of Air Res. Mgmt.
FL Dept. of Env. Protection
2600 Blair Stone Rd.
MS5500
Tallahassee, FL
32399-2400
904-488-0114
fax 904-922-6979
(S) 800-722-7457
-------
Region or State
Georgia
Kentucky
Mississippi
North Carolina
Regional Office
Implementing Agency
Kent Howell
Georgia Dept. Of Natural Resources
Environmental Protection Division
7 M.L. King Jr. Drive, Suite 139
Atlanta, Ga. 30334
(404) 656-6905 phone
(404) 657-7893 fax
kent_howell@mail.dnr.state.ga.us
Danny Jackson
Mississippi Dept. of Environmental Quality
Office of Pollution Control, Air Division
P.O. Box 10385
Jackson, Ms. 39289-0385
(601)961-5225 phone
(601) 961-5725 fax
Jackson;JDanny@deq.state.ms.us
Mike Chapman
Air Quality Section
North Carolina Dept of Environment, Health
and Resources
P.O. Box 29580
Raleigh, N.C. 27626-0580
(919) 715-3467 phone
(919) 733-1812 fax
micheaLchapman@aq.ehnr.slale.nc.us
Small Business Assistance
(S) = State only toll free
(N) = National Toll free
Anita Dorsey-Word
DNR/EPD/APB
Suite 120
4244 Intl. Parkway
Atlanta, GA 30354
404-362-4842
fax 404-362-2534
anila_dorsey-word@mail.dnr.state.ga.us
Gregory C. Copley
Director, BEAP
University of Kentucky
227 Bus. & Eco. Bldg.
Lexington, KY 40506-0034
606-257-1131 , - '
fax 606-257-1907
(N) 800-562-2327
gccopll@pop.uky.edu
Danny Jackson
Air Quality
Office of Policy Conlrol/DEQ
PO Box 10385
Jackson, MS 39289-0385
601-961-5171
fax 601-961-5742
Fin Johnson
Dept. of Env. Health & Nat. Resources
PO Box 29583
Raleigh, NC 27626 •
919-733-1267
fax 919-715-6794
finjohnson@owr.ehnr.state.nc.us.
-------
S Si m
E: a
*;n
™ 5
Region or State
Regional Office
Implementing Agency
Small Business Assistance
(S)« Slate only loll free
(N)«Nal!owd Toll free
South Carolina
Rhonda B. Thompson
Bureau of Air Quality Control
South Carolina Department of Health and
Environmental Health
2600 Bull Street
Columbia, S.C. 29201
(803) 734-4750 phone
(803) 734-4556 fax
Ihompsrb@columb31 .dhec.slute.sc.us
Chod Pollock
SCDHEC
EQC Administration
2600 Bull Street
Columbia. SC 29201
803-734-2765
fax 803-734-9196
(N) 800-819-9001
pollocrc@columb30.dhec.!>tate,sc.us
Tennessee
Linda Sadler
Small Business Assist. Program
8th Floor
L&C Annex
401 Church St.
Nashville, TN 37243
615-532-0779
fax 615-532-0614
(S) 800-734-3619
Region 5
US EPA Region 5
Superfund Division (SC6J)
77 W.Jackson Blvd.
Chicago, IL 60604 ,
(312)886-4061
(312) 886-6064 PAX
Email; mayhugh.robert@epa.gov
Illinois
Mark Enstrom
III. Dept. of Commerce & Community Affairs
620 East Adams St. S-3
Springfield, IL 62701
217-524-0169
fax 21-7-785-6328
meslrom@nilid084rl.sliile.il.us
Indiana
Cheri Storms
IDEM/OPP&TA/VOC
Room 1320
100 N. Senate
PO Box 6015
Indianapolis, IN 46206-6015
317-233-1041
fax 317-233-5627
cstor@opn.dem.state.in.us
-------
Region or State
Michigan
Minnesota
Ohio
Wisconsin
Region6/
Regional Office
75202-2733
292 '
(2.14)66S,7*t7.FAX
Implementing Agency
Small Business Assistance
(S) = State only toll free
(N) = National Toll free
Dave Fiedler
Environmental Services Division
MIDEQ,
PO Box 30457
Lansing, MI 48909
$17-373-0607
fax- 5 17-335-4729
(S) 800-662-9278
Barbara Conti
MPCA/AQPD/SBAP • .
520 Lafayette Rd.
St. Paul, MN 55 155-4 194
612-297-7767
fax 6 12-297-7709
(N) 800-657-3938
barbara.conti@pca.slale.mn.us
RiskCarleski
OH EPA
Division of Air Pollution Control
1600 Watermark Dr.
Columbus, OH 432 15
614-728-1742.
fax 614-644-3681
richard carleski@central.epa.ohio.gov
Pam Christenson
WI Clean Air Assistance Program
Department of Commerce, 9th Floor
m W. Washington Ave
Madison, WI 53703
608-267-9214
fax 608-267-0436
'(N) 800-435-7287
pchr'iste@mail.state.wi.us
-------
a«,:=; «!. s
El
Region or State
Regional Office
Implementing Agency
Small Business Assistance
(S)» Slate only loll free
(N)» National Toll free
Arkansas
Robert E Graham
ARDPE
PO Box 8913
Little Rock, AR 72219-8913
501-682-0708
fax 501-562-0297
Louisiana
VicTompkins
LA Dept. of Env. Quality (Air)
7290 Bluebonnel
P.O. Box 82135
Baton Rouge, LA 70884-2135
504-765-2453
FAX 504-765-0921
(S) 800-259-2890
vic_t@deq.slate.Ia.us
New Mexico
Ccciliu Williams
Lanny Weaver
NM ED/AQB
Harold Runnels Bldg.
Santa Fe, NM 87502
505-827-0042 (cwilliams)
505-827-0043 (Iweaver)
(S) 800-810-7227
Oklahoma
Alwin Ning
OK DEQ/SBAP
1000N.E. lOthSt.
Oklahoma City, OK 73117-1212
405-271-1400
fax 405-271-1317
Texas
Kerry Drake
Small Business Tech. Asst. Program
PO Box 13087
Austin, TX 78711-3087
512-239-1112
fax 512-239-1065
(S) 800-447-2827
kdrake@tnrcc.slate.tx.us
-------
Region or State
Regional Office
Implementing Agency
Small Business Assistance
(S) = Stale only toll free
(N) = National Toll free
,
, and Toxics Division \ »i ,-'
- '
^ •
726 Mwnes6m>Ave. - , * ,
O^KS 66101 ,^'"
Email: smlth.niaik3@fpa.gov '? ' £
Iowa
Somnath Dasgupta
John Konefes
IA Waste Reduction Center
Unv. Of Northern Iowa
75 Bioi. Res. Comp.
Cedar Falls, IA 50614-0185
319-273-2079 '
fax 3 19-273-2926
(8)800-422-3109.
dasgupta@uni.edu
Kansas
Frank Orzulak
Director of Continuing Education
Continuing Education Bldg.
U. of Kansas
Lawrence, KS 66045-2608
913-864-3978
fax 9 13-864-5827
(S) 800-578-8898
forzulak@falcon.cc,ukans.edu
Missouri
Byron Shaw
DNR Technical Assistance Program
Jefferson State Office Building
PO Box 176
Jefferson City, MS 65 102
314-526-5352
fax 3 14-526-5808
-------
if III :
ft Hi!
s
Implementing Agency
Small Business Assistance
(S) « Slate only toll free
(N) = National Toll free
Dan Eddinger
Public Advocate
Dept. of Environmental Quality
PO Box 98922
Lincoln, NE 68509-8922
402-471-3413
fax 402-441-2909
dcdding@juno.com
Nick Melliadis
Air Pollution Control Division
Dept. of Public Health & the Environment
4300 Cherry Creek Drive - South
Denver, CO 80222-1530
303-692-3175
fax 303-782-5493
(N) 800-333-7798
nick.melliadis@state.co.us
Adel Johnson
Dept. Of Environmental Quality
Air Quality Division
MetcalfBldg.
!520E.6thAve.
Helena, MT 59620-0501
406-444-4194
fax 406-444-5275
(S) 800-433-8773
Region or State
Nebraska
Regions
Colorado
Montana
Regional Office
USEPAReglon? J :
Ecosystems Protection and R$roedi,atj(M
(8EPR-ER)
One Denver Place - ;
999-18th Street. Suite 500
Denver, CO 80202-2405 -
(303)312-6760
(303) 312-6071 FAX
Email: benoy.batbara@epa.gov
-------
Region or State
North Dakota
South Dakota
Utah
Wyoming
Region 9 "7 '
5 ' <
: V
' -
<\/ *
it ^ V
'
Regional Office
Supfrfund Division (SPD4) '5?
"1
San Francisco, CA 94105
(415)7444320 ^, -If
>jC41|}744-1916,PAX''
Implementing Agency
Small Business Assistance
(S) = State only toll free
(N) = National Toll free
Tom Bachman
NDDept. of Health '
Division of Environmental Engineering
1 200 Missouri A ve.
PO Box 5520
Bismark, ND 58506-5520
701-328-5188
fax 701-328-5200
(8)800-755-1625
Bryan Gustafson
Dept. Env. & Nat. Resources
JoeFossBldg. .
523 East Capital Ave.
Pierre, SD 57501
605-773-3351
fax 605-773-6035
Frances Bernards
UTDEQ
Div. of Air Quality
PO Box 144820
Salt Lake City. UT 84 1 1 4-4820
801-536-4056
fax 80 1-536-4099
(S) 800-270^4440
fbernard@dec|.slate.ut.us
Charles Raffelson
Dept. of Env. Quality
Div. of Air Quality
122 W. 25th Street
Cheyenne, WY 82002
307-777-7391
fax 307-777-56 16
craffe@missc.state.wy .us
A •
-------
ii
II ! «J
Region or State
Arizona
California
Guam
Hawaii
Nevada
Region 10
Regional Office
US EPA Region 10 ^
Emergency Response & Site Cleanup Unit
(ECL416) t , * ,\
Office of Environmental Cleanup
U.S. EPA Region 10 , >
I20G Sixth Ave. ^
Seattle, WA 9810!
206-553-0285
Implementing Agency
Small Business Assistance
(S)» State only loll free
(N) = National Toll free
Greg Workman
DEQ/Customer Service
3033 N. Central Ave.
Phoenix, AZ 85012
602-2074337
fax 602-207-4872
(S) 800-234-5677 (x4337)
workman.gregory@ev.siate.az.us
-I
Peter Venturini
CA EPA - Air Resource Board
Stationary Source
2020 L Street
Sacramento CA, 95814-4219
916-445-5023
fax 9 16-445-5023
Robert Tam
HI Department of Health
Clean Air Branch
919AlaMoanaBlvd.
Honolulu, HI 96814
808-586-4200
fax 808-5864370
David Cowperthwaite
Small Business Program Manger
Div. Of Env. Protection
333 West Nye Lane
Carson City, NV 897 10
702-6874670x3118
fax 702-687-5856
(S) 800-992-0900 x4670
-------
Region or State
Alaska
Idaho
Oregon
Washington
Regional Office
Implementing Agency
Small Business Assistance
(S) = State only toll free
(N) = National Toll free
Scott Lytle
Alaska Department of Env. Conservation
555 Cordova St.
Anchorage, AK 99501 -2617
907-269-7571
fax 907-269-7600
(8)800-510-2332
slytle@envircon.state.ak.us
Doug McRoberts
IDEQ/PL&E
Statehouse Mail
1410 North Hilton
Boise, ID 83706-1290
208-373-0497
fax 208-373-0169
dmcrober@deq.state.id.us
Terry Obteshka
ODEQ
Air Quality Division
811S,W.6thAve.
Portland, OR 97204-1390
503-229-6147
fax 503-229-5675
(8)800452-4011
terry .obteshka@state.or.us
Bernard Brady
Department of Ecology
PO Box 47600
Olympia, WA 98504-7600
360-407-6803
fax 360-407-6802
bbra461 @ecy .wa.gov
-------
ii li i
-------
Appendix D
QSHA Contacts
-------
i i is
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:(« s
IN* s
»" — «B^r' »!« [M:V S
APPENDIX D: OSHA CONTACTS
Region or State
Regional Office
Consultive Program
State Plan States
Region 1
JFK Federal Building
RoomE340 ;
Boston,MA02203 . -
phone; (617) 565-9860
fax: (617) 565-9827
Connecticut
Connecticut Department of
Labor
Division of Occupational
Safety & Health
38 Wolcott Hill Road
Wethersfield, Connecticut
06109
(203) 566-4550
(203) 566-6916 FAX
steve. wjeeter@ct-ce-
wethrsfld.osha.gov E-mail
Department of Labor
200 Folly Brook Boulevard
Wethersfield, CT 06109
Program Director's Office
Steven Wheeler
phone: (860) 566-4550 fax:
(860) 566-6916
James P. Butler,
Commissioner
(860) 566-5123 (f) (860) 566-
1520
Maine
Division of Industrial Safety
Maine Bureau of Labor
State House Station #82
Augusta, Maine 04333
(207) 624-6460
(207) 624-6449 FAX
david.e.wacker@state.me.us
E-mail
-------
Region or State
Regional Office
Consultive Program
State Plan States
Massachusetts
Commonwealth of
Massachusetts
Dept. of Labor & Industries
1001 Watertown Street
West Newton, Massachusetts
02165
(617)727-3982
(617) 727-4581 FAX
jlamalva@N218.osha.gov E-
mail
New Hampshire
New. Hampshire Department
of Health
Division of Public Health
Services
6 Hazen Drive
Concord, New Hampshire
03301-6527
(603) 271-2024
(603) 271-2667 FAX
jake@nh7cl.mv.com E-mail
-------
: III! I »!
E
I
Region or State
Regional Office
Consultive Program
State Plan States
Rhode Island
Rhode Island Department of
Health
Division of Occupational
Health
3 Capital Hill
Providence, Rhode Island
02908
(401) 277-2438
(401) 277-6953 FAX
oshacon@ids.net E-mail
Vermont
Division of Occupational
Safety & Health
Vermont Department of Labor
and Industry
National Life Building,
Drawer 20
Montpelier, Vermont
05602-3401
(802) 828-2765
(802) 828-2748 FAX
web@labor.lab.state.vt.us
E-mail
Department of Labor and
Industry
National Life Building -
Drawer 20
120 State Street
Montpelier, VT 05620
Robert McLeod, Project
Manager
phone: (802) 828-2765 fax:
(802) 828-2195
Steve Jansen, Commissioner
(802) 828-2288 (f) (802) 828-
2748
Region 2
201 yarick Street
Room 670
Nqw, York, NY 10014
phone: (212) 337-2378
fax:(212)337-237K,
-------
Region or State
Regional Office
Consultive Program
State Plan States
New Jersey
Department of Labor
Div. of Publi Safety and
Occupational Safety and
Health
225 E. State Street, 8th Floor
West
P.O. Box 953
Trenton, NJ 08625-0953
609-292-3923
609-292-4409 FAX
carol.farley @ nj-c-
trenton.osha.gov E-mail
New York
Division of Safety and Health
State Office Campus
Building 12, Room 130
Albany, New York 12240
(518)457-1169
(518) 457-3454 FAX
j ames .rush @ ny-ce-
albany.osha.gov E-mail
Department of Labor
W. Averell Harriman State
Office Building - 12, Room
500
Albany, NY 12240
Richard Cuculo, Program "
Director
phone: (518) 457-3518 fax:
(518)457-6908
James McGowan,
Commissioner
(518) 457-2741 (f) (518) 457-
6908
-------
ij i ii 15
gj=i: !»
= =1-=:- -* « =- ; -v
Region or State
Regional Office
Consultive Program
State Plan States
Puerto Rico
Occupational. Safety and
Health Office
Dept. of Labor & Human
Resources, 21st Floor
505 Munoz Rivera Avenue
Hato Rey, Puerto Rico 00918
(809) 754-2188
(809) 767-6051 FAX
Department of Labor and
Human Resources
Prudencio Rivera Martinez
Building
505 Munoz Rivera Avenue
Hato Rey, Puerto Rico 00918
Cesar J. Almodovar-
Marchany, Secretary
phone: (787) 754-2119 fax:
(787) 753-9550
Assistant Secretary's Office
Ana Lopez
phone: (787) 754-2119 or
2171
fax:(787)767-6051
Virgin Islands
Division of Occupational
Safety and Health
Virgin Islands Department of
Labor
3021 Golden Rock
Christiansted
St. Croix, Virgin Island 00840
(809)772-1315
(809) 772-4323 FAX
Department of Labor
2131 Hospital Street
Box 890, Christiansted
St. Croix, Virgin Islands
00820-4666
Raymond Williams, Program
Director
phone: (809) 772-1315 fax:
(809) 772-4323
-------
Region or State
Regional Office
Consultive Program
State Plan States
Region 3
' Gateway Building , ; .,«
'•Sjiite.210p ,.
t3535|ilafkpt Street • i
.Philadelphia", PA 19104 J
Hphone: (215) $9�j ; )'
*
<', * •* *" /'*•
• i, ^ ^: *
< -,' * 'j*^ ,<
/
Delaware
Delaware Department of Labor
Division of Industrial Affairs
Occupational Safety and
Health
4425 Market Street
Wilmington, Delaware 19802
(302) 761-8219
(302) 761-6601 FAX
Hrznadel@state.de.us E-mail"
District of Columbia
DC Department of
Employment Services
Office of Occupational Safety
and Health
950 Upshur Street, N.W.
Washington, D.C. 20011
(202) 576-6339 •
(202) 576-7282 FAX
jcates@n217.osha.gov
-------
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Region or State
Regional Office
Consultive Program
State Plan States
Maryland
Division of Labor and Industry
312 Marshall Avenue, Room
600
Laurel, MD 20707
410-880-4970
410-880-6369 FAX
Division of Labor and Industry
Dept. of Licensing and
Regulation
1100 North Eutaw Street,
Room 613
Baltimore, MD 21201-2206
John P. O'Conner,
Commissioner
phone: (410) 767-2215 fax: '
(410) 767-2003
Ileana O'Brien, Deputy
Commissioner
phone: (410) 767-2992 fax:
(410) 767-2003
Pennsylvania
Indiana University of
Pennsylvania
Safety Sciences Department
205 Uhler Hall
Indiana, Pennsylvania
15705-1Q87
(412) 357-2561
(412) 357-2385 FAX
rchriste@grove.iup.edu E-mail
-------
Region or State
Regional Office
Consultive Program
State Plan States
Virginia
Virginia Department of Labor
and Industry
Occupational Safety and
Health
Training and Gonsultation
13 South 13th Street
Richmond, Virginia 23219
(804)786-6359
(804) 786-8418 FAX
nj akubecdoli @ sprintmail.com
E-mail
Department of Labor and
Industry
Powers-Taylor Building
13 South 13th Street
Richmond, VA 23219
Theron Bell, Commissioner
phone: (804) 786-2377 fax:
(804)371-6524
Charles Lahey, Deputy
Commissioner
phone: (804) 786-2383 fax:
(804)371-6524 •
West Virginia
West Virginia Department of
Labor,
Capitol Complex Building #3
1800 East Washington Street,
Room 319
Charleston, West Virginia
25305
(304) 558-7890
(304) 558- 3797 FAX
Region,4c ;
<*"'
.\ft
61,Fqr|yth Street, SW
,tlpa,GA 30303 ^ .
phoW (404)l62-23j)0° ' , K
fax,v(4Q4) §62-2295; , ^- • ^
^ i!
%x-* ' , .*
^ ; %-,< v .vss
-------
I
Region or State
Regional Office
Consultive Program
State Plan States
Alabama
Safe State Program
University of Alabama
432 Martha Parham West
PO Box 870388
Tuscaloosa, Alabama 35487
(205) 348-3033
(205) 348-3049 FAX
bweems@ua.edu E-mail
iil
Florida
Florida Dept. of Labor and
Employment Security
7(c)(l) Onsite Consultation
Prog. Div. of Safety
2002 St. Augustine Road,
Building E, Suite 45
Tallahassee, Florida 32399
(850) 922-8955
(904) 922-4538 FAX
brettcreco@safetyfl.org E-mail
Georgia
Onsite Consultation Program
Georgia Institute of
Technology
O'Keefe Building, Room 22
Atlanta, Georgia 30332
(404) 894-2646
(404) 894-8275 FAX
paul.middendorf@gtri.gatech.e
du E-mail
-------
Region or State
Regional Office
Consultive Program
State Plan States
Kentucky
Division of Education and
Training
Kentucky Labor Cabinet
1049 U.S. Highway 127 South
Frankfort; Kentucky 40601
(502) 564-6895
(502) 564-4769 FAX
arussell@mail.lab.state.ky.gov
E-mail
Labor Cabinet
1047 U.S: Highway 127 So.,
Suite,2
Frankfort, Kentucky 40601
Joe Norsworthy, Secretary
phone (502) 564-3070 fax:
(502)564-5387
Steven A. Forbes, Fed/State
Coordinator
phone: (502) 564-2300 fax:
(502) 564-1682
Mississippi
Mississippi State-University
Center for Safety and Health
2906 North State Street, Suite
201
Jackson, Mississippi 39216
(601)987-3981
(601) 987-3890 FAX
Kelly@nl98.osha.gov E-mail
-------
i
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Region or State
North Carolina
South Carolina
Regional Office
Consultlve Program
Bureau of Consultative
Services
North Carolina Dept. of Labor
319 Chapanoke Road, Suite
105
Raleigh, North Carolina
27603-3432
(919) 662-4644
(919) 662-4671 FAX.
wjoyner@dol.state.nc.us
E-mail
South Carolina Department of
Labor
Licensing and Regulation
3600 Forest Drive
PO Box 11329
Columbia, South Carolina
29204
(803)734-9614
(803) 734-9741 FAX
scoshaovp@infoave.net
E-mail
State Plan States
Department of Labor
319 Chapanoke Road
Raleigh, NC 27603
Harry Payne, Commissioner
phone: (919) 662-4585 fax:
(919) 662-4582
Charles Jefress, Deputy
Commissioner
phone (919) 662-4585 fax:
(919) 662-4582
Department of Labor,
Licensing, and Regulation
Koger Office Park, Kingstree
Building
110 Centerview Drive
PO Box 11329
Columbia, SC 29210
William Lybrand, Program
Director
phone: (803) 734-9594 fax:
(803) 734-9772
Lewis Gossett, Director
(803) 896-4300 (f) (803) 896-
4393
-------
Region or State
Regional Office
Consultive Program
State Plan States
Tennessee
OSHA Consultative Services
Tennessee Department of
Labor
710 James Robertson
Parkway, 3rd Floor
Nashville, Tennessee.
37243-0659
(615)741-7036
(615) 532-2997 FAX
mike.maenza@tn-c-
nashville.osha.gov E-mail
Department of Labor
710 James Robertson Parkway
Nashville, TN 37243
David R. Inman, Program
Director
phone: (615) 741-2793 fax:
(615)741-3325
Alphonso R. Bodie,
Commissioner
(615) 741-2582 (f) (615) 741-
5078
p
Mi^i-- >ft
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^v?S
Illinois
Industrial Service Division
Department of Commerce &
Community Affairs
State of Illinois Center, Suite
3-400 :
100 West Randolph Street
Chicago, Illinois 60601
(312)814-2337
(312) 814/7238 FAX
sfryzel@commerce.state.il.us
E-mail
-------
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Region or State
Regional Office
Consultive Program
State Flan States
Indiana
Bureau of Safety, Education
and Training
Division of Labor, Room
W195
402 West Washington
Indianapolis, Indiana 46204
(317) 232-2688
(317) 232-0748 FAX
Jon.mack@nin-ce-
indianpls.osha.gov E-mail
Department of Labor
State Office Building
402 West Washington Street,
RoomW195
Indianapolis, IN 46204
Timothy Joyce, Commissioner
phone: (317) 232-2378 fax:
(317)233-3790
John Jones, Deputy
Commissioner
phone: (317) 232-3325 fax:
(317) 233-3790
Michigan
Michigan Dept of Public
Health
Division of Occupational
Health
3423 North Martin Luther
King Boulevard
Lansing, Michigan 48909
(517)335-8250
(517) 335-8010 FAX
john.peck@cis.state.mi.us E-
mail
Department of Consumer and
Industry Services North
3423 No. Martin Luther King
Boulevard
PO Box 30649
Lansing, MI 48909
Kathleen M. Wilbur, Director
phone: (517) 373-7230 fax:
(517)373-2129
Douglas E. Earle,
Program Director for Safety
and Health
Phone:(517)322-1814 fax:
(517) 335-8010
-------
Region or State
Regional Office
Consultive Program
State Plan States
Minnesota
Department of Labor and
Industry
443 LaFayette Road
Saint Paul, Minnesota 55155
(612)297-2393
(612) 297-1953 FAX
james.collins@state.mn.us E-
mail
Department of Labor and
Industry
443 Lafayette Road
St. Paul, MN 55155
GretchenB. Maglich,
Commissioner
phone: (612)296-2342 fax:
(612) 282-5405
Roslyn Wade, Assistant
Commissioner
phone: (612) 296-6529 fax:
(612) 282-5405
Ohio
Bureau of Employment
Services
145 S. Front Street
Columbus, Ohio 43216 ,
(614)644-2246
(614) 644-3133 FAX
owen@n222.osha.gov E-mail
-------
I B
Region or State
Regional Office
Consultive Program
State Plan States
Wisconsin
Wisconsin (Health)
Wisconsin Department of
Health and Human Services
Section of Occupational
Health, Room 112
1414 East Washington Avenue
Madison, Wisconsin 53703
(608) 266-8579
(608) 266-9711 FAX
Wisconsin (Safety)
Wisconsin Department of
Industry
Labor and Human Relations -
Bureau of Safety Inspections
401 Pilot Court, Suite C
Waukesha, Wisconsin 53188
(414) 521-5063
(414) 521-8614 FAX
L1163@n215.osha.gov E-mail
Region 6
525 Griffm Street
Room 602 ,N "
Dallas,TX75202, ' /
phone: (214)767-4731 .,
faxf(214) 767-4137
-------
Region or State
Regional Office
Consultive Program
State Plan States
Arkansas
OSHA Consultation
Arkansas Department of Labor
10421 West Markham
Little Rock, Arkansas 72205
(501)682-4522
(501) 682-4532 FAX
clark@n237.osh£Lgov E-mail
Louisiana
7(c)(l) Consultation Program
Louisiana Department of
Labor
Post Office Box 94094
Baton Rouge, Louisiana 70804
(504) 34,2-9601
(504) 342-5158 FAX
oshacons@eatel.net E-mail
New Mexico
New Mexico Environment
Dept
Occupational Health and
Safety Bureau
525 Camino de Los Marquez,
Suite 3
PO Box 26110
Santa Fe, New Mexico 87502
(505) 827-4230;
(505) 827-4422 FAX
deborah@n023.osha.gov E-
mail
Environment Department
1190 St. Francis Drive
PO Box 26110
Santa Fe, New Mexico 87502
MarkE. Weilder, Secretary
phone: (505) 827-2850 fax:
(505) 827-2836
Sam A. Rogers, Chief
phone: (505) 827-4230 fax:
(505) 827-2836
-------
I i
Region or State
Regional Office
Consulfive Program
State Plan States
Oklahoma
Oklahoma Department of
Labor
OSHA Division
4001 North Lincoln Boulevard
Oklahoma City, Oklahoma
73105-5212
(405) 528-1500
(405) 528-5751 FAX
Ieslie@n238.osha.gov E-mail
Texas
Workers' Health and Safety
Division
Workers' Compensation
Commission
Southfield Building
4000 South IH 35
Austin, Texas 78704
(512) 440-3854
(512) 440-3831 FAX
margaret.nugent@mail.capnet.
state.tx.us
Region 7
City Center Square - .
1100 Main Street
Suite 800
Kansas City, Missouri 64V105
plione: (816) 426-5861 'K
fax:(816)426-2750 ~:'"
-------
Region or State
Iowa
Kansas
Missouri
Regional Office
Consultive Program
7(c)(l) Consultation Program
Iowa Bureau of Labor
1000 East Grand Avenue
Des Moines, Iowa 50319
(515)281-5352
(515) 281-4831 FAX
Dept. of Human Resources
512 South West 6th Street
Topeka, Kansas 66603
(913) 296-7476
(913) 296-1775 FAX
rudy.leutzinger@ks-ce-
topeka.gov E-mail
Division of Labor Standards
Dept. of Labor & Industrial
Relations
3315 West Truman Boulevard
P.O. Box 449
Jefferson City, Missouri 65109
(573)751-3403
(573) 751-3721 FAX
rsimmons@services.state.mo.u
s E-mail
State Plan States ,
Division of Labor Services
1000 E. Grand Avenue
Des Moines, Iowa 50319
Mary L. Bryant, Administrator
phone: (515) 281-3469 fax:
(515)281-7995
Byron K. Orton,
Commissioner
(515)281-3447(0(515)242-
5144
-------
iBwut-i I* • t
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Region or State
Nebraska
Region 8
Colorado
Regional Office
1999 Broadway
Suite 1690
Denver, CO 80i202
phone: (303) 844-1600
fax; (303) 844-1616
Consultive Program
Division of Safety Labor &
Safety Standards
Nebraska Department of Labor
State Office Building, Lower
Level
301 Centennial Mall, South
Lincoln, Nebraska 68509-5024
(402)471-4717
(402) 471-5039 FAX
amy@n214.osha.gov E-mail
Colorado State University
Occupational Safety and
Health Section
115 Environmental Health
Building
Fort Collins, Colorado 80523
(303)491-6151
(303) 491-7778 FAX
j dsand @ lamar.colostate.edu
E-mail
s i :
State Plan States
-------
Region or State
Regional Office
Consultive Program
State Plan States
Montana
Montana
Dept. of Labor and Industry
Bureau of Safety
PO Box 1728
Helena, Montana 59624-1728
(406)444-6418
(406) 444-4140 FAX
dfolsom@mt.gov E-mail
North Dakota
Division of Environmental
Engineering
1200 Missouri Avenue, Room
304 - .
Bismarck, North Dakota •
58506-5520'!
(701X328-5188
(701) 328-5200 FAX
ccmail.lhuber@ranch.state.nd.
us E-mail
-------
1 i HP ngiltt=l«M|=Hli= * T rt
M
1 == l:=l ii I == iib * I
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Region or State
Regional Office
Consult ive Program
State Plan States
South Dakota
Engineering Extension
Onsite Technical Division
South Dakota State University
Box 510
West Hall
907 Harvey Dunn Street
Brookings, South Dakota
57007
(605) 688-4101
(605) 688-6290 FAX
scoshaovp@infoave.net
E-mail
Utah
Utah Industrial Commission
Consultation Services
160 East 300 South
Salt Lake City, Utah
84114-6650
(801)530-6868
(801) 530-6992 FAX
icmain.nandetso @ state.ut.us
E-mail
Labor Commission
160 East 300 South, 3rd Floor
PO Box 146650
Salt Lake City, UT 84114-
6650
Jay W. Bagley, Administrator
phone: (801) 530-6898 fax:
(801) 530-7606
R. Lee Ellertson,
Commissioner
(801) 530-6898 (f) (801) 530-
6880
-------
Region or State
Regional Office
Consultive Program
State Plan States
Wyoming
Wyoming Department of
Employment
Workers' Safety and
Compensation Division
Herschler Building, 2 East
122 West 25th Street
Cheyenne, Wyoming 82002
(307)777-7786
(307) 777-3646 FAX
Department of Employment
Worker's Safety and
Compensation Div.
Herschler Building, 2nd Floor
East '
122 West 25th Street
Cheyenne, WY 82002
Stephan R. Foster, Safety
Administrator
phone: (307) 777-7786 fax:
(307) 777-5850
Region 9, ^ .»'
,7j Stevenson Street;., .
R^e&n420'^ ' ' ^:^
.San Pfancisco,
Arizona
Consultation and Training
Industrial Commission of
Arizona
Division of Occupational
Safety & Health
800 West Washington
Phoenix, Arizona 85007
(602)542-5795
(602) 542-1614 FAX
henry@n245.osha.gov E-mail
Industrial Commission
800 W. Washington
Phoenix, AZ 85007
Derek Mullins, Program
Director
phone: (602) 542-5795 fax:
(602)542-1614
Larry Etchechury, Director
(602) 542-5796 (f) (602) 542-
1614
-------
i =to iii
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C-Ef I L Ii^ JL I
Region or State
Regional Office
Consultive Program
Stale Plan States
California
CAL/OSHA Consultation
Service
Department of Industrial
Relations
Room 1260
45 Freemont Street
San Francisco, CA 94105
(415)972-8515
(415) 972-8513 FAX
DCBare@hq.dir.ca.gov E-mail
Department of Industrial
Relations
45 Freemont Street
San Francisco, CA 94105
Dr. John Howard, Chief
phone: (415) 972-8500 fax:
(415)972-8513
John Duncan, Director
(415) 972-8835 (f) (415) 972-
8848
Guam
OSHA Onsite Consultation
Dept. of Labor, Government of
Guam
PO Box 9970
Tamuning, Guam 96931
(671)475-0136
(671) 477-2988 FAX
Hawaii
Consultation & Training
Branch
Dept of Labor and Industrial
Relations
830 Punchbowl Street
Honolulu, Hawaii 96813
(808) 586-9100
(808) 586-9099 FAX
Department of Labor and
Industrial Relations
830 Punchbowl Street
Honolulu, HI 96813
Loraine H Akiba, Director
phone: (808) 586-8844 fax:
(808) 586-9099
Jennifer Shishido,
Administrator
phone: (808) 586-9116 fax:
(808) 586-9104
-------
Region or State
Regional Office
Consultive Program
State Plan States
Nevada
Division of Preventive Safety
Department of Industrial
Relations, Suite 106
2500 West Washington
Las Vegas, Nevada 89106
(702)486-5016
(702) 486-5331 FAX
dalton.hooks @ nv-ce-
lasvegas.osha.gov E-mail
Division of Industrial
Relations
400 West King Street
Carson City, Nevada 97502
Ron Swirczek, Administrator
phone(702) 687-3032 fax:
(702) 687-6305
Danny Evans, Assistant
Administrator
phone: (702) 687-3250 fax:
(702) 687-6150
/Suie 7 i i . /f.
^Seattle, 'Washington
" *
J3212-, .'sv;,4;' $ 'i'Vc^JL
ph%j'(206X55^5930'! # - x?;
ifaxr^Oei'SSS^RP'j1' '
Alaska
ADOL/OSHA Division of
Consultation
3301 Eagle Street
P.O. Box 107022
Anchorage, Alaska 99510
(907)269-4957
(907)-269-4950 FAX
timothybundy ©labor.state.ak.
us E-mail
Department of Labor
1111 W. 8th Street, Room 306
Juneau, AK 99801
Alan W. Dwyer, Program
Director
phone: (907) 465-4855 fax:
(907) 465-3584
Tom Cashen, Commissioner
(907) 465-2700 (f) (907) 465-
2784
-------
i: ill MI
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- „
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Region or State
Regional Office
ConsttlUve Program
State Plan States
Idaho
Boise State University, Dept.
of Health Studies
1910 University Drive,
ET-338A
Boise, Idaho 83725
(208) 385-3283
(208) 385-4411 FAX
lstokes@bsu.idbsu.edu E-mail
Oregon
Department of Consumer and
Business Services
Oregon Occupational Safety
and Health Division
350 Winter Street NE, Room
430
Salem, Oregon 97310
(503) 378-3272
(800) 922-2689 TOLL FREE
(503) 378-5729FAX
steve.g.beech@state.or.us or
consult.web@state.or.us
E-mail
Occupational Safety and
Health Division
Dept. of Consumer & Business
Services
350 Winter Street, NE, Room
430
Salem, OR 97310
Peter Deluca, Administrator
phone: (503) 378-3272 fax:
(503)378-4538
David Sparks, Deputy
Adminsistrator
phone: (503) 378-3272 fax:
(503) 378-4538
-------
Region or State
Washington .
Regional Office
Consultive Program
Washington Dept of Labor and
Industries
Division of Industrial Safety
and Health
PO Box 44643
Olympia, Washington 98504
(360) 902-5443
(360) 902-5459 FAX
jame235@lni.wa.gov E-mail
State Plan States
Department of Labor and
Industries
General Administration
Building
PO Box 44001
Olympia, WA 980504-4001
Gary Moore, Director
phone: (360) 902-4200 fax:
(360)902-4202
Michael Silverstein, Assistant
Director
phone:'(360)902-5495 fax:
(360)902-5529
-------
.if!!1!'1 i"1"1''',.!"", "" i1 ''
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'
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-------
APPENDIX E
TECHNICAL ASSISTANCE
October 27, 1998
-------
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-------
Appendix E
E-l Technical Assistance
APPENDIX E: TECHNICAL ASSISTANCE
WHERE CAN I GET HELP?
.This appendix provides points of contact for the resources that are available to facilities in
complying with 40 CFR part 68 from EPA, OSHA, and several other entities involved in
process safety and risk management issues. For specific points of contact for EPA
.regional offices, RMP implementing agencies, and Clean Air Act small business
assistance programs, refer to Appendix C. For specific points of contact for OSHA
: regional offices, OSHA state consultative programs, and OSHA state plan states, refer to
Appendix D. ....•'
U.S. ENVIRONMENTAL PROTECTION AGENCY
Chemical Emergency Preparedness and Prevention Office
401 M Street, SW
Washington, DC 20460
(202)260-8600
www.epa.gov/swercepp ,
, CEPPO administers the RMP program at the national level. The CEPPO
homepage on the Internet provides access to downloadable versions of numerous
risk management program documents, many of which are also available upon
request from the National Center for Environmental Publications and Information
see below. . .
EPCRA/Superfund/RCRA/CAA Hotline
Toll-Free: (800)424-9346
Local: (703)412-9810.
TDD: (800)553-7672
TDD Local: (703) 412-3323 V
Monday - Friday, 9:00 am - 6:00 pm EST '
www.epa.gov/epaoswer/hotline/index.htm
Questions or comments: epahotline@bahfcom
EPA's RCPvA, Superfund, and EPCRA Hotline is a publicly accessible service
mat provides up-to-date information on EPA programs. The Hotline responds to
. factual questions on a variety of. federal EPA regulations, including those
developed under Clean Air Act section 112(r). The Hotline also responds to
requests for individual copies of documents.
National Center for Environmental Publications and Information
P.O. Box 42419
October 27, 1998
-------
Appendix E
Technical Assistance
E-2
Cincinnati, OH 45242
Phone:(800)490-9198
Fax: (513)489-8695
www.epa.gov/ncepihom/
Orders must be limited to five titles per two-week period, one complimentary
copy of each in-stock publication. As supplies are depleted you will be referred to
i;i; the Rational Technical ^formation Service (NTIS), the Government Printing
Office (GPO), or the Educational Resource Information Center (ERIC) to obtain
your documents at cost. ,
Jnl II I1 ' ,,i ' " ,,'i|l' , " ' !' i. ", r1 !, Ji ' I" " ,!, ' li!1! .,,... | , :• ' • | i1, ?",",„' •;.,,:.',„: , ,' ''.i';!!1," B. , • i | "' , ' * ',
National Technical information Service
Technology Administration
U.S. Department of Commerce
5285 Port Royal Road
Jill*: IM:,, i ;., F
fill! B! i ,;«• ;v , "! Jill,1 .• ' 'M: j
Mlii1 111 111 ' '! i:ii ill ' ;: !'!» ; ;',iiil|!;! ! <
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11111 111 III i ll,,!i i I ' 'I I I'l "i Vli Ill1 i.
if!
Phone: (800) 553-6847 (toll-free)
Phone: (703) 487-4650 (local) . . ' ,
Monday - Friday, 8:00 am - 8:00 pm EST
Fax: (703) 321-8547 (verify receipt at (703) 487-4679)
www.ntis.gov/
E-Mail: prders@ntis.fedworld.gov
The National Technical Information Service is the official resource for
goverhmeht-sporisbred U.S. and worldwide scientific, technical, engineering, and
^.^u^in^^ela^^lPJ^^?^1: R9cWments not available through the EPA Hotline
ate often available from NTIS. You can place your order by telephone, mail, fax,
or e-mail. NTIS also offers online ordering for products added to the NTIS
collection within the last 90 days using NTIS OrderNow.
PA Small Business Assistance Program
www.epa.gov/ttn/sbap/
Air AcxAmendrnents of 1990 requires that all States develop a
prbgfarh to assist small businesses in meeting the requirements of the Act. EPA
has established its own Small Business Assistance Program (SBAP) to provide
lechnical assistance to these State smajl business programs. This site has been
developed to allow State and EPA programs to share information about their small
Business assistance materials and activities.
mn
> li!
ii J1PA Small Business Hotline
Small Business Ombudsman Office
(800)368-5888
li , '
Office of Air Quality Planning and Standards
October 27,1998
-------
Appendix E
E-3 . Technical Assistance
, www.epa.gov/oar/oaqps/
The Office of Air Quality Planning and Standards administers EPA's operating
permit program. Permits incorporate terms and conditions to assure that the
source complies with all applicable requirements. The RMP regulations are
considered to be an applicable requirement.
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA)
OSHA administers the Process Safety Management Standard (29 CFR 1910.119), which
mandates actions similar to that of EPA's prevention program. In about half of the states
(see Appendix D), OSHA programs are run by state agencies.
Office of Information and Consumer Affairs
U.S. Department of Labor
RoomN3647
200 Constitution Avenue, NW
Washington, DC 20210 ''•'',
(202)523-8151 .
www.osha.gov - ,
OSHA Process Safety Management Homepage
www.osha-slc.gov/SLTC/ProcessSafetyManagement/index.html
The PSM homepage on the Internet provides access to downloadable versions of
numerous process safety management documents.
OSHA Consultation Services
www.osha.gov/oshprogs/consult.html
Using a free consultation service largely funded by OSHA, employers can find out
about potential hazards at their worksites, improve their occupational safety and
health management systems, and even qualify for a one-year exemption from '
routine OSHA inspections. Primarily targeted for smaller businesses, this safety
and health consultation program is completely separate from the OSHA inspection
effort.
OSHA Office of Training & Education
Head Registrar
OSHA training Institute ,
Des Plaines, Illinois
(847) 297-4913
www.osha-slc.gov/Training/index.html
October 27, 1998
-------
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••";;, "i"";;;:1;;",, '"...Appendix E
| |j||, •) Ifjij,:, PT^ \ E-4
||ij 'j'1: -f'"';'••'• •;,•;,' i,- s||rhe,bS]^,,Qffice,,of tVaining and Education offers short-term training through
j|j!ii.;>,' .^'jr,'' i":',1";" : ,||^e,QSI^,Training Institute. The Office also administers the OSHA Training
IJ;::!":"> ..ll!,;v.: .';/•' „,.. _ |||Jnstimte;,Education Centers program, in which designated nonprofit organizations
offer the most frequently requested courses for the private
S IP iii!'"'1 ''"SHA, VoJwntary Protection Program (VPP)"
Division of Ypluntary Programs
www.osha.gov/oshprogs/vpp/osha2.html
OSHA Voluntary Protection Programs are designed to recognize and promote
effective safety and health management. In the VPP, management, labor, and
OSHA establish a cooperative relationship at a workplace that has implemented a
strong program. • '
'==':••;"": £':;":';: s1 • i/it' '• '"; -" :•"'•. ; :::;OSHA Publications Office
1'It'f,!!;,':1!!', i"! ,',! • ! illi !, •' ••:••, '"''!:',•',•I'll
*f :r*;i,:i '•• m-''- ••1r,-'*Tv
:» '•'"- Sili't'. „"'' f. |202) 523-9667 ' ' •
ill jig: .-,„ ; iii.)1 i:,!i, ;„ vjii- !i,;,ii, ; , ,,,,;"• '•;•', i'SB "\-\ ••:••,; •••„,;,••!, ,. ,v .s : ,:••;••' 'i"1"1 ••(,",•' „• ''.•.'• •• .:•:•••. s • '• • ••.
| |ii| "', f;;,'! iii-; i>i-:! !;;,:{ i i •, :,i ii'iiiw •;,,"', ,,• ' ;/&• "'„*•> ";, ',,•!(,,' '-1,-,, ,i -ii't •;'••':,;,,•,,„„;, i y. ;,,; ••'( /t i\-, ; «^,. ' n •, ,••'•,
The Publications Office provides single copies of various documents.
OSHA Computerized Information System
www.osha-slc.gov/
This site provides links to OSHA Standards and related documents, including
OSHA Regulations, Federal Register notices, Interpretations and Compliance
Letters, OSHA Regulations (preambles to final rules), Review Commission
decisions, Congressional Testimony, OSHA Directives and Fact Sheets,
Memorandums of Understanding.
Windows and Macintosh dual platform
U.S. Government Printing Office
Stock # 729-013-60000-5
Phone: (202)512-1800
Fax: (202)512-2250 ' , .. ,;
Price: $38/year (four quarterly releases), $ 15 (single copy)
This CD-ROM contains electronic copy of the text of all OSHA regulations,
selected documents, and technical information from the OSHA Computerized
Information System.
0«ober27,1998
-------
w , " Appendix E
E-5 Technical Assistance
OTHER ORGANIZATIONS
Association of Metropolitan Sewerage Agencies
1000 Connecticut Avenue, NW, Suite 410
Washington D.C. 20036-5302
Phone: (202) 833-AMSA
Fax: (202) 833-4657
http://www.amsa-cl6anwater.org/
American Water Works Association
6666 Quincy Ave.
Denver, CO 80235
(303)794--7711
www.awwa.org/ . • '
AWWA has prepared a model risk management program for its members.
Chlorine Institute
Publications Coordinator
2001 L St. NW, Suite 506
Washington, DC 20005
(202)223-7225 .
www.cl2.com
The Chlorine Institute has developed a model risk management program for
chlorine handlers. It also publishes guidance documents related to chlorine
handling, and storage. -
Compressed Gas Association
Publications Department
1725 Jefferson Davis Highway, Suite 1004
Arlington, VA 22202-4102
(703) 412-0900 ,
The Compressed Gas Association publishes a number of documents on the
handling of compressed gases, including ammonia and sulfur dioxide.
Water Environment Federation
601WytheSt.
Alexandria, VA
(703) 684-2400
www.wef.org
The Water Environment Federation publishes a number of documents on water
treatment, including operating and maintenance manuals for WWWs.
October 27, 1998
-------
Appendix fi
Technical Assistance
E-6
Ilii
, i' ?!
ff
Si,*;:
. illll!!
I"*!'
American Institute of Chemical Engineers
345 E. 47th St.
New York, NY 10017-2395
(212)705-7338
www.aiche.org/
Center for Chemical Process Safety
345 E. 47th St., 12th Fl.
New York, NY 10017-2395
(212)705-7319
WWW.aiche.org/docs/research/ccps.htm
AIChExpress Service Center
(800) AIC-HEME (242-4363)
Monday - Friday, 9:00 am - 5:00 pm EST
E-Mail: xpress@aiche.org
prints a Continuing Education catalog for its educational and training
i: 'programs ''and an annual Publications Catalog from which documents can be
purchased.
i:§mall BusmessAdministratipn (SB A)
!lo9 Third Street, SV/
ill jlli! j 'I1.1 ..... . ••• - :"!"• ........ ,', .71 ..... ,i1 "<' ........ <-
l/ashington, DC
'
WWW.sba.gov/
SB A 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 SB A works with thousands of lending,
educational, and training institutions nationwide.
\
U.S. Government Printing Office
Superintendent of Documents
Washington, DC 20402
(202)783-3238 ••' '"
WwW-gpo-gov/su_docs/index.html
•tGPO Access User Support Team
E-mail: gpoaccess@gpo.gov
Phone: (202) 512-1530 (local)
fPhone: (888) 293-6498 (toll-free)
'''Fax: (202)512-1262 '"
October 27,1998
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-------
APPENDIX F
OSHA GUIDANCE ON PSM
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APPENDIX F
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 , ,
i V , ' , • •
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; locaj emergency preparedness planners; and insurance and enforcement officials.
The information to be compiled about the chemicals, including process intermediates, needs to be
comprehensive enough for an accurate assessment of the fire and explosion characteristics, reactivity
hazards, the safety and health hazards to workers, and the corrosion and erosion effects on the process
equipment and monitoring tools. Current material safety data sheet (MSDS) information can be used to
help meet this requirement, which must be supplemented with process chemistry information including
runaway reaction and over pressure hazards if applicable:
Process technology information will be a part of the process safety information package and it is expected
mat it will include diagrams as well as employer established criteria for maximum inventory levels for
process chemicals; limits beyond which would be considered upset conditions; and,a qualitative estimate
of the consequences or results of deviation that could occur if operating beyond the established process
limits. Employers are encouraged to use diagrams which will help users understand the process,
• A block flow diagram is used to show the major process equipment and interconnecting process flow lines
and show flow rates, stream composition, temperatures, and pressures when necessary for clarity. The
block flow diagram is a simplified diagram.
Process flow diagrams are more complex and will show all main flow streams including valves to enhance
the understanding of the process, as: well as pressures and temperatures on all feed and product lines within
all major vessels, in and out of headers and heat exchangers, and points of pressure and temperature
control. Also, materials of construction information, pump capacities and pressure heads, compressor
horsepower and vessel design pressures and temperatures are shown when necessary for clarity. In
addition, major components.of control loops are usually shown along with key utilities on process flow
diagrams. * ; . ; . ..
Piping and instrument diagrams (P&IDS) may be the more appropriate type of diagrams to show some of
the above details and to display the information for the piping designer and engineering staff. The P&EDS
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 orother '
diagrams useful to the information package, may be used to help meet this requirement.
The information pertaining to process equipment design must be documented. In other words, what were
the codes and standards relied on to establish good engineering practice. These codes and standards are
-------
Appendix F
OSHA Guidance on PSM" F-2
published by such organizations as the American Society 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 adcIitionT various engineering societies issue technical reports which impact process
design. For example, me 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
codes aj?d s.^dajcjs were, used and tjiaf the design and construction along with the testing, inspection and
operation are still suitable for the intended use. Where me process technology requires a design which
departs from the applicable codes and standards, the employer must document that the design and
constructipn is suitable for the intended purpose.
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P/ROC^SS HAZARD ANALYSIS , iiv rjii _ , r , , ,
:,::" ' " „ i ,„' ' / ,'":: „"„ „":': ", „'" '„ " , ' ,„' " , ,„ ' „ '"„ ' , ,„'",, ' ' ' '', • ^
* 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.
A PHA is djrected toward analyzing potential causes and consequences of fires, explosions, releases of
toxic or flammable chemicals and major spills,of hazardous chemicals. The PHA focuses on equipment,
instmmgntatipn,utilitieSj human actions (routine and non-routine), and external factors that might impact
tjie process. These considerations assist in determining the hazards and potential failure points or failure
modes in a process.
The selection of a PHA methodology or technique will be influenced by many factors including the
amount of existing knowledge about the process. Is it a process that has been operated for a long period of
time with little or no innovation and extensive experience has been generated with its use? Or, is it a 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 PHA methodologies are subject to certain limitations. For example, the checklist methodology works
\jYe|l wtien the process is very stable and no changes are made, but it is not as effective when the process.
has, uncfergone 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 future PHA.
The team conducting the PHA need to understand me 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
-------
Appendix F
F-3 ' OSHA Guidance on PSM
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, code's, specifications and regulations
applicable to the process being studied. The selected team members need to be compatible and the team
leader needs to be able to manage the team and the PHA study. The team needs to be able to work together
while benefiting from the expertise of others on the team or outside the team, to resolve issues, and to forge
a consensus on the findings of the study and the recommendations.
*>
The application of a PHA to a process may involve the use of different methodologies for various parts of
the process. For example, a process involving a series of unit operations of varying sizes, complexities,-and
ages may use different methodologies and team members for each operation. Then the conclusions can be
integrated into one final study and evaluation.
A more specific example is the use of a checklist PHA for a standard boiler or heat exchanger and the use
of a Hazard and Operability PHA for the overall process. Also, for batch type processes like custom batch
operations, a generic PHA of a representative batch may be used where there are only small changes of
monomer or other ingredient ratios and the chemistry is documented for the full range and ratio of batch
ingredients. Another process that might consider using a generic type of PHA is a gas plant. Often these
plants are simply moved from site to site and therefore, a generic PHA may bemused for these movable
plants. Also, when an employer has several similar size gas plants and no sour gas is being processed at
the site, then a generic PHA is feasible as long as the variations of the individual sites are accounted for in
the PHA. . •••••.•
Finally, when an employer has a large continuous process which has several control rooms for different
portions of the process such as for a distillation tower and a blending operation, the employer may wish to
do each segment separately and then integrate the final results.
Additionally, small businesses which are covered by this rule, will often have processes that have less
storage volume, less capacity, and less complicated than processes at a large facility. Therefore, OSHA
would anticipate that the less complex methodologies would be used to meet the process hazard analysis
criteria in the standard. These process hazard analyses can be done in less time and with a few people
being involved. A less complex process generally means that less data, P&EDS, and prpcess 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. '
When 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
prioritizing the processes that the employer has determined are subject to coverage by the process safety
-------
F
OSHA Guidance on PSM F-4
'"IS1 III::11*;
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
leventy of a chemical release, the number of potentially affected employees, the operating history of the
releases, the age of the process and any other relevant factors.
5 factors would suggest a ranking order and would suggest either using a weighing factor system or a
systematic ranking method. Trie use of a preliminary hazard analysis would assist an employer in
:iL,!';irdeterr^ninjglwhicn'p'roMss11shouid1 be of the highest priority and thereby the employer would obtain the
greatest improvement in safety at the facility.
S a" '| 'I :',:":;' iiiti!: •' 'i',' -:"'" 'ii'lf'' ;i!. ?!; '.•*'",' 'aiiiiii •: •!;'.:' •' •'''" •;, T !: !• •'.:' ti •''."''.:":!' ':'"!""' ?> ,:>: i! .';• -:"1 J: -i; •, >,': i'' '•'"';;.'''' it'? •,]'•':i i i • ''.'"•!••: ..,:.' '•
OPERATING PROCEDURES
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; need to
be tecJinically 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
Ijj';'^jipp'licab"le"safety precautions and should contain appropriate information on safety implications. For
^^'•'•"''^^plit, feebperating'procedures addressing operating parameters will contain operating instructions
Ibput 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 subjects. Another example of
using operating instructions to properly implement operating procedures is in starting up or shutting down
the process. In these cases, different parameters will be required from those of normal operation. These
Operating instructions need to clearly indicate the distinctions between startup and normal operations such
as the appropriate allowances for heating up a unit to reach the normal operating parameters. Also the
operating instructions heed 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
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and the control system; otherwise, it may not be apparent to the operator.
'I,if1 ':;':' '.; liil i.1 : ' III I II II I :,
Itlp^erating procedures and instructions are important for training operating personnel. The operating
procedures are often viewed as the standard operating practices (
-------
Appendix F
OSHA Guidance on PSM
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 safety and health hazards of the chemicals and processes they work
with for the protection of themselves, then: 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-the-job training can also be very effective for teaching other job
tasks, duties, or other important information. An effective training program will allow the employee to
fully participate in the training process and to practice their skill or knowledge.
Employers need to periodically evaluate their training programs to see if the necessary skills, knowledge,
and routines are being properly understood and implemented by their trained employees. The means or
methods for evaluating the training should be developed along with the training program goals and
objectives. Training program evaluation will help employers to determine the amount of training their
-------
Appendix F
OSHA Guidance on PSM F-6
Employees understood, and whether the desired results were obtained. If, afterthe evaluation, it appears
>i "ihat the trained employees are not at the level of knowledge; and skill that was expected, the employer will
^eed to revise the training program, provide retraining, or provide more frequent refresher training sessions
until the deficiency is resolved. Those who conducted the training and 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.
Careful consideration must be given toassure that employees including maintenance and contract
employees receive current and updated training. For example, if changes are made to a process, impacted
employees must be trained in the changes and understand the effects of the .changes on their job tasks (e.g.,
,.",any new operating procedures pertinent to their tasks). Additionally, as already discussed the evaluation of
the employee's absorption of training will certainly influence the need for training.
&'^J$!:'j;i Employers will need to review their maintenance programs and schedules to see if there are areas where
IJKJfJ^i!' I'fbjisal^p.wn" maintenance is used, rather ft31!, an on-going mechanical" integrity program. Equipment used
to process, store, or handle highly hazardous chemicals needs to be designed, constructed, installed and
maintained to minimize the risk of releases of such chemicals. This requires thata mechanical integrity
progralm be in place to assure the continued integrity of process equipment.
Elements of a mechanical integrity program include the identification and categorization of equipment and
instrumentation, inspections and tests, testing and inspection frequencies, development of maintenance
procedures, training of maintenance personnel, the establishment of criteria for acceptable test results,
documentation of test and inspection results, and documentation of manufacturer recommendations as to
meantime to failure for equipment and instrumentation.
The first line of defense an employer has available is to operate and maintain the process as designed, and
|^> l^eep the chemicals contained. This line of defense is backed up by the next line of defense which is the
epntrolled release of chemicals through venting to scrubbers or flares, or to surge or overflow tanks which
fH^f^i'*^ designed to receive such chemicals, etc. These lines of defense are the primary lines of'defense or
Siiiiiit:; 1*1 '"»rhearis'fi) prevent unwanted releases. The secondary lines of defense would include fixed fire protection
systems like sprinklers, water spray, or deluge systems, monitor guns, etc., dikes, designed drainage
systems, and other systems which would control or mitigate hazardous chemicals once an unwanted release
occurs. These primary and secondary lines of defense are what the mechanical integrity program needs to
protect and strengthen these primary and secondary lines of defenses where appropriate.
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 instrumentation and the
listed equipment the employer would prioritize which pieces of equipment require closer scrutiny than
others. ' '
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Meantime to failure.of'various instrumentation arid equipmeritparts 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
-------
Appendix F
F-,7 OSHA Guidance on PSM
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 inspectipns 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 arid 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
scree'ns for erosion, corrosion or cracking and other deficiencies. Some of these inspections may be
performed by state or local government inspectors under state and local statutes. However, each employer
needs to develop procedures to ensure that tests and inspections are conducted properly and that
consistency is maintained even where different employees may be involved. Appropriate training is to be
provided to maintenance personnel to ensure that they understand the preventive maintenance program
procedures, safe practices, and the proper use and application of special equipment or unique tools that
may be required. This training is part of the overall training program called for in the standard.
/
A quality assurance system is needed to help ensure that the proper materials of construction are used, that
fabrication and inspection procedures are proper, and that installation procedures recognize field
installation concerns. The quality assurance program is an essential part of the mechanical integrity
program and will help to maintain the primary and secondary lines of defense that have been designed into
the process to prevent unwanted chemical releases or those which control or mitigate a release. "As built"
drawings, together with certifications of coded vessels and other equipment, and materials of construction
need to be verified and retained in the quality assurance documentation.
Equipment installation jobs need to be properly inspected in the field for use of proper materials and
procedures and to assure that qualified craftsmen are used to do the job. The use of appropriate gaskets,
packing, bolts, valves, lubricants and welding rods need to be verified in the field. Also, procedures for
installation of safety devices need to be verified, such as the torque on the bolts on ruptured disc
installations, uniform torque on flange bolts, proper installation of pump seals, etc. If the quality of parts is
a problem, it may be appropriate to conduct audits of the equipment supplier's facilities to better assure
proper purchases of required equipment which is suitable for its intended service. Any changes in
equipment that may become necessary will need to go through the management of change procedures.
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,
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ill"!; i1 i!"?::: ,lir,f tepijperature'1 ranges)' flow rates, etc.) arid the importance"of operating within these limits. While the
Operator rriust have the flexibility to maintain safe operation within the established parameters, any
bperalbn outside of these parameters requires review arid 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
in catalyst and changes in operating conditions to improve yield or quality. Equipment changes include
among others change in materials of construction, equipment specifications, piping pre-arrangements,
exp^rimen 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
'lif5lV:^' -'"Ways to'detect temporary changes as well as those that are permanent. It is important that a time limit for
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temporary changes be established and monitored since, without control, these changes may tend to become
;• ^ pgj^jjjjgfl^ Temporary changes are subject to the management of change provisions. In addition, the
•'ii'Si:i"HI i !Ji:i;"lntoa|inienf of changegrocedures'"are used to insure 'that the"equipment"and"procedures are returned to '
~ ^.!'';... ^''^jnto tiie 'operating prbceSure's 'and'theprbcess."" 'Employers may'wisn' to'develop a"fbrm 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 operating procedures, maintenance
procedures, inspection arid testing, P&BDS, electrical classification, training and communications,
pre-stariup 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 npted so that these revisions can be made permanent when 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
br one is being upated " " ' "" ' "" ' ^ " ' ' -
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 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
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Appendix F
F-9 "••'•• OSHA Guidance on PSM
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 PHA recommendations need to be reviewed
as well to see what impacts they may have on the process before beginning the startup.
COMPLIANCE AUDITS
Employers need to select a trained individual or assemble a trained team of people to audit the process
safety management system and program. A small process or plant may need only one knowledgeable
person to conduct an audit. The audit is to include an evaluation of the design arid 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 tp 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
procedure aiid 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
example, the audit team will review all aspects of the training program as part of the overall audit. The
team will review the written training program for adequacy of content, frequency of training, effectiveness
of training in terms of its goals and objectives as well as to how it fits into meeting the 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
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i'':::'i!'l5SHA ..... Guidance on PSM
F- 10 '
inspection, the team can observe actual practices such as safety and health policies, procedures, and work
authorization practices. This approach enables the team to identify deficiencies and determine where
corrective actions or improvements are necessary.
An audit is a technique used to gather sufficient facts and information, including statistical information, 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.
The audit team, through this systematic analysis, should document areas which require corrective action as
well as those areas where the process safety management system is effective and working in an effective
manner. This provides a record of the audit procedures and findings, and serves as a baseline of operation
data for future audits. It will assist future auditors in determining changes or trends from previous audits.
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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
determine what 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 to
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 that 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.
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INCIDENT INVESTIGATION
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Incident investigation is the process of identifying the underlying causes of incidents and implementing
fteps to prevent similar events from occurring. The intent of an incident investigation is for employers to
learn frgm 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 occfur, but could have.
f|.
Employers need to develop in-house capability to investigate incidents that occur in their facilities. A team
fi^eds 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
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1,113
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Appendix F
F-ll * ' OSHA Guidance on PSM
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. Theii; 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 their
representatives informed about relevant safety and health issues and employers may be able to adapt these
practices and procedures to meet their obligations Under this standard. Employers who have not
implemented an occupational safety and health program may wish to form a safety and health committee, of
employees and management representatives to help the .employer meet the obligations specified by this
standard. These committees can become a significant ally in helping the employer to implement and
maintain an effective process safety management program for all employees.
HOT WORK PERMIT
Non-routine work which is conducted in process areas needs to be controlled by the employer in a
consistent manner. The hazards identified involving the work that is to be accomplished must be
communicated to those doing the work, but also to those operating personnel whose work could affect the
safety of the process. A work authorization notice or permit must have a procedure that describes the steps
the maintenance supervisor, contractor representative or other person needs to follow to obtain the
necessary clearance to get the job started. The work authorization procedures need, to reference and
coordinate, as applicable, lockout/tagout procedures, line breaking procedures, confined space entry
procedures and hot work authorizations. This procedure also needs to provide clear steps to follow once
the job is completed to provide closure for those that need to know the job is now completed and
equipment can be returned to normal.
CONTRACTORS
Employers who use contractors to perform work in and around processes that involve highly hazardous
chemicals, will need to establish a screening process so that they hire and use contractors who accomplish
the desired job tasks without compromising the safety and health of employees at a facility. For
contractors, whose safety performance on the job is not known to the hiring employer, the employer will
need to obtain information on injury and illness rates and experience and should obtain contractor
references. Additionally, the employer must assure that the contractor has the appropriate job skills,
knowledge and certifications (such as for pressure vessel welders). Contractor work methods and
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Appendix F
OSHA Guidance on PSM
F-12
»^i|;^^p*enences should be "evaluated. '"'Foir example," does the "contractor conducting "demolition work swing
loads over operating processes or does the contractor avoid such hazards?
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Contract employees must perform their work safely. Considering that contractors often perform very
specialzed and potentially hazardous tasks such as confined space entry activities and non-routine repair
-tctiyities it is quite important that their activities be controlled while they are working on or near a covered
process. A permit system or work authorization system for these activities would also be helpful to all
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 process where
employee safety is fully recognized will benefit all of those who work in the facility whether they be
Contract employees or employees of the owner. .
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