Do I Need To Develop a Risk Management
Program?
Dear Ag Center client:
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By June 21, 1999, some agricultural establishments may be jj
required to submit written plans to EPA describing how they will 1
protect against the release of certain hazardous chemicals, and
to begin putting their risk management program into effect. A
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EPA's National Agriculture Compliance Assistance Center can -£j^<
help you determine: ,j ^Helping Agriculture Comply vith
Environmental Requirements
to what extent your ag establishment is covered by EPA's risk
management program requirements
where to go for detailed compliance assistance.
This compliance assistance package contains:
i
this cover letter, which includes a general explanation of the risk management
program and its requirements, plus contacts for more information on risk
management program requirements and how to comply
a document to help determine if you are subject to the risk management program
requirements
a list of all chemicals covered by the risk management program.
How to use these materials:
1. Read the general explanation of the program (below).
2. Work through the included applicability document, "Chapter 1: General
Applicability" (reprinted by the Ag Center from EPA's General Guidance for Risk
Management Programs).
3. If you conclude that you have a covered process for which you need to develop a
risk management program, go to "Help From EPA" (below). Written plans are
due by June 21,1999.
4. If you DO NOT need to develop a program, remember that you still must adhere
to the "general duty clause" of the Clean Air Act. For details on this general
responsibility, see "General Clean Air Act Requirement" (below).
U.S. Environmental Protection Agency
National Agriculture Compliance Assistance Center 726 Minnesota Avenue Kansas City, KS 66101
Toll-free: l-888-663;-2155 Internet: www.epa.gov/oeca/ag
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General Information About the Risk Management Program
EPA's new Risk Management Program (RMP) requirements could apply to you. Agricultural
establishments that store, handle, or use certain toxic or flammable chemicals above threshold
amounts must develop and implement a program to prevent accidental releases of those
chemicals.
The examples below illustrate common chemicals and thresholds used in ag operations that will
subject you to the RMP:
Chlorine in quantities greater than 2,500 Ibs. Chlorine is commonly used in
agriculture for washing fruits, vegetables, and other harvested products and for
disinfection.
Ammonia in quantities greater than 10,000 Ibs. for anhydrous or 20,000 Ibs. for
aqueous. Ammonia is often used in agriculture for food refrigeration systems.
Note: Ammonia held by a farmer on an agricultural establishment for use as an
agricultural nutrient is exempt from the requirements, as long as it is used on that
establishment. It would NOT be exempt if resold or used on another
establishment. Farm cooperatives and groups of farmers who buy, use, and sell
ammonia are NOT exempt.
Propane in quantities greater than 10,000 Ibs. originally triggered the RMP requirements.
However, propane is NOT included at this time. This means that the June 21, 1999, deadline for
submitting RMP plans does not apply to propane. If propane triggers RMP requirements in the
future, EPA will announce the change.
Flammable hydrocarbon fuels (including butane, ethane, methane, and others) in quantities
greater than 10,000 Ibs. originally triggered the RMP requirements. However, at this time,
flammable hydrocarbons intended for use as fuels trigger the RMP requirements only in quantities
greater than 67,000 pounds. This means that the June 21, 1999, deadline for submitting RMP
plans does not apply to flammable hydrocarbon fuels in quantities of 67,000 pounds or less. If
flammable hydrocarbon fuels in quantities less than 67,000 pounds trigger RMP requirements in
the future, EPA will announce the change. If you are not sure whether a fuel is a hydrocarbon,
contact EPA's RMP Hotline at 1-800-424-9346 or 703-412-9810 for assistance.
These examples do not cover all the circumstances that may require you to comply with the risk
management program. Be sure to check the list of all chemicals covered by the law and then
consult the "General Applicability" chapter from EPA's General Guidance for Risk Management
Programs (enclosed) to determine how the requirements apply to your establishment.
U.S. Environmental Protection Agency
National Agriculture Compliance Assistance Center 726 Minnesota Avenue Kansas City, KS 66101
Toll-free: 1-888-663-2155 Internet: www.epa.gov/oeca/ag
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Your Risk Management Program
As a farmer, you may be using hazardous chemicals that pose a risk to the surrounding
community should an accident occur. The Risk Management Program rule requires businesses of
all sizes and types to implement a "risk management program," a regular program of activities
designed to prevent an accidental chemical release.
Many of the baseline requirements of this rule ~ such as evaluating the dangers associated with
your operations and determining how to make them safer are activities that conscientious
businesses already undertake using established industry codes and standards (such as NFPA-58),
so you may already be in compliance with parts of this new regulation.
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To fully comply, you will need to develop and implement a risk management program for the
chemicals of concern on your establishment. How much you will need to do in your program will
depend upon the level of risk that your operations pose to nearby communities.
Submitting a Written Plan
A written summary of your program ~ called a "Risk Management Plan" must be submitted to
EPA by June 21, 1999. It will be made available to state and local officials involved in planning
for and responding to chemical emergencies, and to the public. In this way, police, firefighters,
and the people who live and work near your establishment can be assured that you are taking
steps to prevent accidents involving chemicals that could cause a risk to the community.
General Clean Air Act Requirement '
Even if you determine that you do not have a process that requires a formal risk management
program, remember that you still must adhere to the "general duty clause" of the Clean Air Act
[Section 112(r)(l)]. This clause, which went into effect in 1990, makes the owners and operators
of facilities that have extremely hazardous substances responsible for ensuring that the chemicals
are managed safely. :
The statute says that owners and operators have a general duty to identify the possible hazards of
the chemicals at their facility, do what is necessary to prevent the releases of those chemicals, and
take steps that will limit the harmful effects of any accidental releases. Facilities can make sure
they are working towards fulfilling their General Duty Clause obligations by:
* adopting or following relevant industry codes or standards,
being aware of accidents or incidents in their industry sector and what they reveal
about potential hazards,
understanding unique circumstances of their facility which may require a tailored
program of planning and prevention.
U.S. Environmental Protection Agency
National Agriculture Compliance Assistance Center 726 Minnesota Avenue Kansas City, KS 66101
Toll-free: 1-888-663-2155 Internet: www.epa.gov/oeca/ag
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Help from EPA
For additional information on the Risk Management Program listed chemicals and its
requirements, you can:
Call EPA's RMP Hotline at 1-800-424-9346 or 703-412-9810
The Hotline has technical staff who can provide you with up-to-date information
and help answer your questions about the Risk Management Program.
Go to the RMP web site at http://www.epa.gov/swercepp/acc-pre.html
This site provides access to information about the Risk Management Program,
including guidance documents, support for submitting Risk Management Plans,
and questions and answers about the Risk Management Program Rule. Many
documents can be downloaded from this site.
Get free publications/software from NSCEP
The National Service Center for Environmental Publications can supply most of
EPA's Risk Management Program materials. NSCEP will send you one free copy
of up to five document/software titles in any two-week period. You can request
documents/software by title or document number (see partial list of RMP materials
and their document numbers below).
Call in requests to: 1-800-490-9198
Fax requests to: 1-513-489-8695
Request online: http://www.epa.gov/ncepihom/
Guidance documents and publications available
EPA and several key industry associations have developed guidance and model
plans to help facilities comply with the Risk Management Program. Call the RMP
hotline or visit the RMP web site for a comprehensive list. Some of the key
documents include:
Risk Management Program Guidance for Ammonia Refrigeration. This
guidance provides model risk management program plans for facilities with
ammonia refrigeration systems. The guidance covers only anhydrous
ammonia and provides offsite consequence analyses that are specific to the
ways in which ammonia is handled in an ammonia refrigeration system.
EPA Document Number: EPA 550-B-98-014
Web address: http://www.epa.gov/swercepp/ap-ingu.htm#ammonia
EPA's General Guidance for Risk Management Programs. When no
industry-specific guidance has been developed for a sector, this document
helps a facility to develop risk management programs and plans.
EPA Document Number: EPA 550-B-98-003
Web address: http://www.epa.gov/swercepp/ap-gegu.htm.
RMP*Submit Software and Manual. This is EPA's free personal
computer software for facilities to use in submitting the required Risk
Management Plans. The manual provides instructions on how to submit
U.S. Environmental Protection Agency
National Agriculture Compliance Assistance Center 726 Minnesota Avenue Kansas City, KS 66101
Toll-free: 1-888-663-2155 Internet: www.epa.gov/oeca/ag
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plans and how to complete each data element. It is the official method for
submitting Risk Management Plans. Since this software has error checking
capability, EPA reconlmends you use it rather than the paper form to avoid
common reporting errors.
EPA Document Number for CD-ROM version and manual: 550-C99-001
EPA Document Number for Diskette version and manual: 550-C99-002
EPA Document Number for User Manual only: 550-B99-001 (This manual
contains the paper forms you will need if you do not plan to file
electronically.)
Web address: http://www.epa.gov/swercepp/ap-rmsb.htm#obtain
U.S. Environmental Protection Agency
National Agriculture Compliance Assistance Center 726 Minnesota Avenue Kansas City, KS 66101
Toll-free: 1-888-663-2155 Internet: www.epa.gov/oeca/ag
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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)
That has more than a threshold quantity
4> Of a regulated substance
4> In a process.
The goal of this chapter is to make it easy for you to identify processes that are
covered by this rule so you can focus on them.
This chapter walks you through the key decision points (rather than the definition
items above), starting with those provisions that may tell you that you are not subject
to the rule We first outline the general applicability provisions and the few
exemptions and exclusions, then discuss which chemicals are "regulated substances.
If you do not have a "regulated substance" at your site, you are not covered by this
rule. The exemptions may exclude you from the rule or simply exclude certain
activities from consideration. (Throughout this document, when we say rule we
mean the regulations in part 68.)
We then describe what is considered a "process," which is critical because you are
subject to the rule only if you have more than a threshold quantity in a process. The
chapter next describes how to determine whether you have more than a threshold
quantity.
Finally we discuss how you define your overall stationary source and when you must
comply These questions are important once you have decided that you are covered.
For most facilities covered by this rule, the stationary source is basically all covered
processes at your site. If your facility is part of a site with other divisions of your
company or other companies, the discussion of stationary source will help you
understand what you are responsible for in your compliance and reporting. Exhibit
1-1 presents the decision process for determining applicability.
STATE PROGRAMS
This guidance applies to only 40 CFR part 68. You should check with your state government to
SSneTf thelte has its own accidental release prevention rules or has obtained deleJ^on from
EPA to implement and enforce part 68 in your state. State rules may be more stnngent than _EPA s
ruks Unless your state has been granted delegation, you must comply with part 68 as described in
mis document even if your state has different rules under state law. See Chapter 11 for a discussion of
state implementation of part 68.
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EXHIBIT 1-1
EVALUATE FACILITY TO IDENTIFY COVERED PROCESSES
Is your facility
a stationary
source?
Do you have
any regulated
substances?
STOP!
You are not covered
by the rule.
Define your
processes
Do you have any
regulated substances above
a threshold quantity in a
process?
You are subject
to the rule.
Assign Program levels to
covered processes
(see Exhibit 2-1)
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Chapter 1
General Applicability
1.2 GENERAL PROVISIONS
The CAA applies this rule to any person who owns or operates a stationary source.
"Person" is defined to include
States and any officer, agency, or employee thereof.
The rule, therefore, applies to all levels of government as well as private businesses.
CAA section 112(r)(2)(c) defines "stationary sources" as:
"Any buildings, structures, equipment, installations, or substance emitting stationary
activities
4- Which belong to the same industrial group,
Which are located on one or more contiguous properties,
O Which are under the control of die same person (or persons under common
control), and
- From which an accidental release may occur."
EPA has added some language in the rule to clarify issues related to transportation
(see below).
FARMS (§68.1 25)
The rule has only one exemption: for ammonia when held by a farmer for use on a
Sm This exemption applies to ammonia only when used as a fertilizer by a fanner.
Ses not apply to agricultural suppliers or the fertilizer manufacturer, t does not
apply to farm cooperatives or to groups of farmers who buy, use, and sell ammonia.
Tthe evlrmat a farmer stores one or more other regulated substance above
threshold quantities, that storage would be covered.
TRANSPORTATION ACTIVITIES
to DOT under 49 U.S.C. 6010.5 are not covered. Piping at your source, however, is
covered Storage of natural gas incident to transportation (i.e., gas taken from a
SSe during non-peak periods and placed in storage fields, then returned to the
Sine wh needed) is not covered. Storage fields include, but are not limited to,
depleted oU ^ gas reservoirs, aquifers, mines, or caverns. Liquefied natural gas
facilities covered by 49 CFR part 193 are not covered.
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Chapter 1
General Applicability 1-4
Qs&As
STATIONARY SOURCE
Q. What does "same industrial group" mean?
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A. Operations at a site that belong to the same three-digit North American Industry Classification
System (NAICS) code (which has replaced the old two-digit SIC codes) belong to the "same industrial
group. In addition, where one or more operations at the site serve primarily as support facilities for the
main operation at the site, the supporting operations are part of the "same industrial group" as the main
operation. For example, if you manufacture chemicals (NAICS 325) and operate a waste treatment
facility (NAICS 562) that handles primarily wastes generated by your chemical operations, the waste
operation would be considered a support operation. If you operate a petrochemical manufacturing
operation (NAICS 32511) next to your petroleum refinery (NAICS 32411), the two plants would be
considered in different industrial groups and would require two RMPs unless the majority of the
refinery's production .was used by the chemical manufacturing plant.
Q. What does "contiguous property" mean?
A. Property that is adjoining. Public rights-of-way (e.g., railroads, highways) do not prevent property
from being considered contiguous. Property connected only by rights-of-way are not considered
contiguous (e.g., two plants with a connecting pipeline).
Q. What does "control of the same person" mean?
A. Control of the same person refers to corporate control, not site management. If two divisions of a
corporation operate at the same site, even if each operation is managed separately, they will count as
one source provided the other criteria are met because they are under control of the same company.
Transportation containers used for storage not incident to transportation and
transportation containers connected to equipment at a stationary source are considered
part of the stationary source. Transportation containers that have been unhooked from
the motive power that delivered them to the site (e.g., truck or locomotive) and left on
your site for short-term or long-term storage are part of your stationary source. For
example, if you have railcars on a private siding that you use as storage tanks until you
are ready to hook them to your process, these railcars should be considered to be part
of your source. If a tank truck is being unloaded and the motive power is still
attached, the truck and its contents are considered to be in transportation and not
covered by the rule. You should count only the substances in the piping or hosing as
well as the quantity unloaded. Some issues related to transportation are still under
discussion with DOT.
RELATIONSHIP TO OSHA PROCESS ;SAFETY MANAGEMENT STANDARD EXEMPTIONS
The OSHA Process Safety Management (PSM) standard (29 CFR 1910.119) exempts
retail facilities, substances used solely as a fuel if such substances are not part of a
process containing another regulated substance, flammable liquids stored in
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_l-5
: storage tanks, am
Chapter 1
General Applicabilit
of the OSHA exemptions. EPA s rule coyas rei governments if
substances stored in atmospheric storage tanks an 1 state and toe* g
they own or operate a faculty ' ftcflito as well as
are excluded from
threshold determinations
1 3
REGULATED SUBSTANCES AND THRESHOLDS (§68.130)
flaable ch.nucals
63 flammable ga** imd highly volatile B»STm released. ^ rule also
1.4 WHAT IS A PROCESS
The concept of "process" is key to whether you are subject to this rule. Process is
defined in 40 CFR §68.3 as:
"Vessel" in §68.3 means any reactor, tank, drum, barrel, cylinder, vat, kettle, boiler,
pipe, hose, or other container.
requirements you must meet if the process is covered.
What does this mean to you?
If you store a regulated substance in a single vessel in quantities above the
threshold quantity, you are covered.
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Chapter 1 '
General Applicability \ 1-6
more vessels are connected occasionally, they are considered a single process
for the purposes of determining whether a threshold quantity is present.
^ If you have multiple unconnected vessels, containing the same substance, you
will have to determine whether they need to be considered together as co-
located. '
A process can be as simple as a single storage vessel or a group of drums or cylinders
in one location or as complicated as a system of interconnected reactor vessels,
distillation columns, receivers, pumps, piping, and storage vessels.
SINGLE VESSELS
!
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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. '
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INTERCONNECTED VESSELS
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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
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 of an
accidental release. YouJ: 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.
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In some cases, such as in a large refinery or multi-unit chemical plant, 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 OS HA'3 interpretation of "process" as that term is used in OSHA's
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Chapter 1
General Applicability
PSM rule. Therefore, if your facility is subject to the PSM rule, the limits of your
processes) for purposes of OSHA PSM will be the limits of your processes) for
Purposes of RMP (except in cases involving atmosP£edc *<^
flammable regulated substances, which are exempt from PSM but not RMP). If your
facility is not covered by OSHA PSM and is complicated from an engineering
perspective, you should consider contacting your implementing agency for advice on
determining process boundaries. .
CO-LOCATION
The third possibility you must consider is whether you have separate vessels that
contain the same regulated substance 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 wil 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 bum, would the tire
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 scenario that could lead to a release of
a threshold quantity.
For flammables, you should consider the distance between vessels. If a fire could
spread from one vessel to others or an explosion could rupture multiple vessels, you
must count all of them. For toxics, a release from a single vessel will not normally
lead to a release from others unless the vessel fails catastrophically and explodes,
sending metal fragments into other vessels. Co-located vessels containing toxic
substances, however, may well be involved in a release caused by a fire or explosion
that occurs from another source. The definition of process is predicated on the
assumption that explosion will take place. In addition, a collapse of storage racks
could lead to multiple vessels breaking open.
If the vessels are separated by fire walls or barricades 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.
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.
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Chapter 1
General Applicability
1-8
PROCESSES WITH 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
other storage or process vessels in between with other regulated substances above their
thresholds, the two vessels with the first substance may be considered to be part of a
larger process involving the other intervening vessels and other regulated substances,
based on co-location.
Exhibit 1-2 provides illustrations of what may be defined as a process.
DIFFERENCES WITH OSHA
OSHA aggregates different flammable liquids across vessels in making threshold
determinations; OSHA, also aggregates different flammable gases (but does not
aggregate flammable liquids with flammable gases); EPA aggregates neither.
Therefore, if you have three co-located or connected reactor vessels each containing
5,000 pounds of a different flammable liquid, OSHA considers that you have 15,000
pounds of flammable liquids and are covered by the PSM standard. Under EPA's
rule, you would not have a covered process because you do not meet the threshold
quantity for any one of the three substances. OSHA, like EPA, does not aggregate '
quantities for toxics as a class (i.e., each toxic substance must meet its own threshold
quantity).
1.5 THRESHOLD QUANTITY IN A PROCESS
!
The threshold quantity for each regulated substance is listed in 40 CFR §68.30, in
Appendix A. You should determine whether the maximum quantity of each substance
in a process is greater than the threshold quantity listed. If it is, you must comply with
this rule for that process. Even if you are not covered by this rule, you may still be
subject to reporting requirements under the Emergency Planning and Community
Right to Know Act (EPCRA).
QUANTITY IN A VESSEL
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To determine if you have the threshold quantity of a regulated substance in a vessel
involved in a single process, you need to consider the maximum quantity in that vessel
at any one time. You do not need to consider the vessel's maximum capacity if you
never fill it to that level. Base your decision on the actual maximum quantity that you
may have in the vessel. Your maximum quantity may be more than your normal
operating maximum quantity; for example, if you may use a vessel for emergency
storage, the maximum quantity should be based on the quantity that might be stored.
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Schematic Representation
EXHIBIT 1-2
PROCESS
Description
1 vessel
1 regulated substance above TQ
Interpretation
1 process
2 or more connected vessels
same regulated substance
above TQ
2 or more connected vessels
different regulated substances
each above TQ
pipeline feeding multiple vessels
total above TQ
3
1 process
2 or more vessels co-located
same substance
total above TQ
1 process
1 process
2 or more vessels co-located
different substances
each above TQ
2 vessels, located so they won't be
involved in a single release
same or different substances
each above TQ
1 process
2 processes
2 locations with regulated substances
each above TQ
1 series of interconnected vessels
same or different substances above TQs
plus a co-located storage vessel
containing flammables
1 or 2 processes
depending on distance
1 process
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Chapter I :
General Applicability | i-ip
AGGREGATION OF SUBSTANCES
t
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.
|
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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.
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QUANTITY IN A PIPELINE
i
The maximum quantity in a pipeline will generally be the capacity of the pipeline
(volume). In most cases, pipeline quantity will be calculated and added to the
interconnected vessels.
INTERCONNECTED/CO-LOCATED VESSELS
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If your process consists of two or more interconnected vessels, you must determine the
maximum quantity for bach 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.
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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.
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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.
j . *
+ 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.
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Chapter 1
General Applicability
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).
QS&AS
PROCESS
Q. Do 1 have to do my hazard review, process hazard analysis, or other prevention activity on the
whole process or can I break it into separate units?
A. Once you have determined that you have a covered process, you can divide the covered process any
way you want to implement the prevention program. If you have multiple interconnected storage and
reactor vessels in your process, you may want to treat them separately when you conduct the hazard
review or process hazard analysis, if only to make the analyses easier to manage. Storage and reactor
vessels may require separate maintenance programs. You should do what makes sense for you.
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 tire.
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).
Note that in a revision to part 68, EPA changed the concentration for hydrochloric
acid to 37 percent or greater (see Appendix A).
TOXICS WITHOVT A LISTED CONCENTRATION
For toxics without a listed concentration, if the concentration is less than one percent
you need not consider the quantity in your threshold determination. If the
concentration in a mixture is above one percent, you must calculate the weight of the
regulated substance in the mixture and use that weight to determine whether a
threshold quantity is present. However, if you can measure or estimate (and
document) that the partial pressure of the regulated substance in the mixture is less
than 10 mm Hg, you do not need to consider the mixture. Note that the partial
pressure rule does not apply to toluene diisocyanate (2-4, 2-6, or mixed isomers) or
oleum.
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Chapter 1
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:
i
"Materials that will rapidly or completely vaporize at atmospheric pressure and normal
ambient temperature or, that are readily dispersed in air, and that will burn readily.
This degree usually includes:
i
FLAMMABLE GASES
Flammable cryogenic materials
I
Any liquid or gaseous Material that is liquid while under pressure and has a flash point
below 73 F(22.8 C) and a boiling point below 100 F(37.8 C) (i.e., Class 1A
flammable liquids)
Materials that will spontaneously ignite when exposed to air."
FLAMMABLES NOT COVERED BY PART 68 (§68.115)
The following flammables are not considered part of a "stationary source" and,
therefore, any regulated substances contained in them need not be included in your
calculations of threshold quantities:
i
i
+ Naturally occurring hydrocarbon reservoirs; and
* Naturally occurring hydrocarbon 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.
I
"Naturally occurring hydrocarbon reservoirs" includes oil and gas fields, where the
hydrocarbons occur in nature and from which they are pumped; it does not include
natural formations, such;as salt domes, where hydrocarbons are stored after they have
been produced or processed. Transportation subject to state oversight or regulation
refers to transportation in pipelines.
You do not need to consider the following flammable substances when you determine
the applicability of the rule:
+ Gasoline, when in distribution or related storage for use as fuel for internal
combustion engines;
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Chapter 1
General Applicability
Naturally occurring hydrocarbon mixtures prior to entry into a petroleum
refining process unit (NAICS code 32411) or a natural gas processing plant
(NAICS code 211112). Naturally occurring hydrocarbon mixtures include
any of the following:
Condensate - hydrocarbon liquid separated from natural gas that condenses
because of changes in temperature, pressure, or both, and that remains liquid
at standard conditions;
Crude oil - any naturally occurring, unrefined petroleum liquid;
Field gas - gas extracted from a production well before the gas enters a natural
gas processing plant (any processing site engaged in the extraction of natural
gas liquids from field gas, fractionation of mixed natural gas liquids to natural
gas products, or both); and
Produced water - water extracted from the earth from an oil or natural gas
production well, or that is separated from oil or natural gas after extraction.
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.
Not? that these same exclusions apply to EPCRA section 313; you may be familiar
with them if you comply with that provision.
ARTICLES (§68.115(b)(4))
You do not need to include in your threshold calculations any manufactured item
defined at §68.3 (as defined under 29 CFR 1910.1200(b)) that:
+ Is formed to a specific shape or design during manufacture,
4. Has end use functions'dependent in whole or in part upon the shape or design
during end use, and
4 Does not release or otherwise result in exposure to a regulated substance
under normal conditions of processing and use.
USES (§68.115(b)(5))
You also do not need to include regulated substances in your calculation when in use
for the following purposes:
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
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Chapter 1
General Applicability
+ Use of regulated substances present in process water or non-contact cooling
water as drawiji from the environment or municipal sources, or use of
regulated substances present in air used either as compressed air or as part of
combustion.
ACTIVITIES IN LABORATORIES
!'
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 j 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:
i
+ Specialty chemical production;
* Manufacture, processing, or use of substances in pilot plant scale operations;
and .
* Activities conducted outside the laboratory.
1.6 STATIONARY SOURCE
i
The rule applies to "stationary sources" and each stationary source with one or more
covered processes must file an RMP that includes all covered processes.
i
SIMPLE SOURCES
i
For most facilities covered by this rule, determining what constitutes a "stationary
source" is simple. If you own or lease a property, your processes are contained within
the property boundary, and no other companies operate on the property, then your
stationary source is defined by the property boundary and covers any process within
the boundaries that has more than a threshold quantity of a regulated substance. You
must comply with the rule and file a single RMP for all covered processes.
i
MULTIPLE OPERATIONS OWNED BY A SINGLE COMPANY
If the property is owned or leased by your company, but several separate operating
divisions of the company have processes at the site, the divisions' processes may be
considered a single stationary source because they are controlled by a single company.
Two factors will determine if the processes are to be considered a single source: Are
the processes located on one or more contiguous properties? Are all of the operations
in the same industrial group?
If your company does have multiple operations that are on the same property and are
in the same industrial group, each operating division may develop its prevention
program separately for its covered processes, but you must file a single RMP for all
covered processes at the site. You should note that this is different from the
requirements for filing under CAA Title V, and EPCRA section 313 (the annual toxic
release inventory), where each division could file separately if your company chose to
do so.
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Chapter 1
General Applicability
OTHER SOURCES
RMP for any operations that you own or operate.
Another possibility is that one company owns the land and operates there while
sharing emergency response functions.
u and another company Jointly own a site, but have
property and controlled by a single owner.
JOINT VENTURES
You and another company may jointly own covered .
entity you have established to operate these processes should file ttie RMP.
consider this entity a subsidiary, you should be listed as the parent company in the
RMP.
MULTIPLE LOCATIONS
If you have multiple operations in the same area, but they are not on ^f
connected land, you must consider them separate stationary sources and file separate
RMPs for each even if the sites are connected by pipelines that move chemicals
es. 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
entsofart68nolaterthanJune21, 1999. Tins means that
specify prior to that time.
have a covered process is after June 21, 1999, or you bring a new
^^1"
which you first have i substance
process.
-------
EXHIBIT 1-3
STATIONARY SOURCE
Schematic Representation
Description
Interpretation
ABC Chemicals
General Chemicals Division
ABC Chemicals
Plastics Division
same owner
Same industrial group
ABC Chemicals
Agricultural Chemicals Division
1 stationary source
1 RMP
ABC Chemicals
ABC Chemicals
two owners
XYZ Gases
2 stationary sources
2RMPs
1 ABC
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
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.
Brown Property offices
ABC
Chemicals
1
two owners
Pet Supply Storage
(no regulated substances)
2 stationary sources
2 RMPs
1 ABC Chemicals
1 Farm Chemicals
-------
1-17
Chapter 1
General Applicability
QS & AS
STATIONARY SOURCE
Q. I operate a single covered process on a site owned by a large company. I manufacture a regulated
substance that I pipe to the other company for use in its processes. At what point do the piping and
substance become part of the other company's stationary source?
A. The answer will vary. The company that owns and maintains the piping should probably consider
ft part of its stationary source. If, however, there is a point (e.g., a valve or meter) where the receiving
company is considered to take ownership of the substance, then you may decide to divide the piping
and its contents at that point.
Q. The definition of process would seem to say that my process is part of the larger company's
process because they are interconnected. Why can't the larger company just include my process in its
RMP?
A. Your process is not part of the larger company's stationary source because it does not meet the
statutory criteria for stationary sources. Although the process may be part of the same industrial group
and is at the same location, it is not under control of the same person. Therefore, the process is a
separate stationary source and must have a separate RMP.
-------
Chapter 1
General Applicability
1-18
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 process by adding new reactor vessels, but do not change the substances?
A. Because increasing the number of reactor vessels is a major change to your 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 1 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.
-------
CHEMICALS INCLUDED IN EPA'S RISK MANAGEMENT PLAN
The following is a list of chemicals that trigger the Environmental Protection Agency's Risk
Zc or £±bb cne^als above the threshold quantity listed for each chemical must develop
and implement a plan to prevent accidental releases of those chemicals.
Propane in quantities greater than 10,000 Ibs. origin
However nrooane is NOT 'included at this time. This means that the June 21, 1999, deadline lor
^SSaS^S^ no. apply to propane. !f propane triggers RMP requirements m the
future, EPA will announce the change.
Flammable hydrocarbon fuels (including butane, ethane, methane, and others) i ir
contact EPA's RMP "~*"~ * i-«nn^74-9346 or 703-412-9810 for assistance. - . -
CHEMICALS INCLUDED IN EPA'S RISK MANAGEMENT PLAN
Regulated Substance
1,1-Dichloroethylene
1,1-Dimethyl hydrazine
1,2-Ethanediamine
1,2-Propadiene
1,3-Butadiene
1,3-Butadiene, 2-methyl-
1,3-Pentadiene
l-Buten-3-yne
1-Butene
1-Butyne
1-Chloropropylene
1-Pentene
1-Propene
1-Propene, 1-chloro-
CAS Number Threshold Quantity
75-35-4 10,000
57-14-7 15,000
107-15-3 20,000
463-49-0 10,000
106-99-0 10,000
78-79-5 10,000
504-60-9 10,000
689-97-4 10,000
106-98-9 10,000
107-00-6 10,000
590-21-6 10,000
109-67-1 10,000
115-07-1 10,000
590-21-6 10,000
Page 1 of 7
-------
Regulated Substance
1-Propene, 2-chloro-
1-Propene, 2-methyl-
1-Propyne
2,2-Dimethylpropane
2-Butenal
2-Butenal, (e)-
2-Butene
2-Butene, (E)
2-Butene-cis
2-Butene-trans
2-Chloropropylene
2-Methyl-l-butene
2-Methylpropene
2-Pentene, (E)-
2-Pentene, (Z)-
2-Propanamine
2-Propen-1 -amine
2-Propen-l-ol
2-Propenal
2-Propenenitrile
2-Propenenitrile, 2-methyl-
2-Propenoyl chloride
3-Methyl-1-butene
Acetaldehyde
Acetic acid ethenyl ester
Acetylene
Acrolein
Acrylonitrile
Acrylyl chloride
Allyl alcohol
Allylamine
Ammonia (anhydrous)
Ammonia (cone 20% or greater)
Arsenous trichloride
Arsine
Aziridine
Aziridine, 2-methyl
Benzene, 1,3 -diisocyanato-2-methyl-
Benzene, 1,3-diisocyanatomethyl-
Benzene, 2,4-diisocyanato-1 -methyl-
Bis(chloromethyl) ether
Borane, trichloro-
Borane, trifluoro-
Boron trichloride
CAS Number Threshold Quantity
557-98-2
115-11-7
74-99-7
463-82-1
4170-30-3
123-73-9
107-01-7
624-64-6
590-18-1
624-64-6
557-98-2
563-46-2
115-11-7
646-04-8
627-20-3
75-31-0
107-11-9
107-18-6
107-02-8
107-13-1
126-98-7
814-68-6
563-45-1
75-07-0
108-05-4
74-86-2
107-02-8
107-13-1
814-68-6
107-18-6
107-11-9
7664-41-7
7664-41-7
7784-34-1
7784-42-1
151-56-4
75-55-8
91-08-7
26471-62-5
584-84-9
542-88-1
10294-34-5
7637-07-2
10294-34-5
10,000
10,000
10,000
10,000
20,000
20,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
15,000
5,000
20,000
10,000
5,000
10,000
10,000
15,000
10,000
5,000
20,000
5,000
15,000
10,000
10,000
20,000
15,000
1,000
10,000
10,000
10,000
10,000
10,000
1,000
5,000
5,000
5,000
Page 2 of 7
-------
Regulated Substance
Boron trifluoride
Boron trifluoride compound with methyl ether 1:1
Boron, trifluoro[oxybis[methane]]-, (T-4)-
Bromine
Bromotrifluoroethylene
Butane
Butane, 2-methyl-
Butene
Carbon disulfide
Carbon oxide sulfide (COS)
Carbonic dichloride
Carbonochloridic acid,l-methylethyl ester
Carbonochloridic acid, methylester
Carbonochloridic acid, propylester
Carbonyl sulfide
Chlorine
Chlorine dioxide
Chlorine monoxide
Chlorine oxide
Chlorine oxide (C1O2)
Chloroethane
Chloroform
Chloromethane
Chloromethyl ether
Chloromethyl methyl ether
Crotonaldehyde
Crotonaldehyde, (E)-
Cyanogen
Cyanogen chloride
Cyanogen chloride ((CN)C1)
Cyclohexanamine
Cyclohexylamine
Cyclopropane
Diborane
Diborane(6)
DichJoromethyl ether
Dichlorosilane
Difluoroethane
Dimethylamine
Dimethyldichlorosilane
Dimethylhydrazine
Epichlorohydrin
Ethanamine
Ethane
r AS Number Threshold Quantity
7637-07-2
353-42-4
353-42-4
7726-95-6
598-73-2
106-97-8
78-78-4
25167-67-3
75-15-0
463-58-1
75-44-5
108-23-6
79-22-1
109-61-5
463-58-1
7782-50-5
10049-04-4
7791-21-1
7791-21-1
10049-04-4
75-00-3
67-66-3
74-87-3
542-88-1
107-30-2
4170-30-3
123-73-9
460-19-5
506-77-4
506-77-4
108-91-8
108-91-8
75-19-4
19287-45-7
19287-45-7
542-88-1
4109-96-0
75-37-6
124-40-3
75-78-5
57-14-7
106-89-8
75-04-7
74-84-0
5,000
15,000
15,000
10,000
10,000
10,000
10,000
10,000
20,000
10,000
500
15,000
5,000
15,000
10,000
2,500
1,000
10,000
10,000
1,000
10,000
20,000
10,000
1,000
5,000
20,000
20,000
10,000
10,000
10,000
15,000
15,000
10,000
2,500
2,500
1,000
10,000
10,000
10,000
5,000
15,000
20,000
10,000
10,000
Page 3 of 7
-------
Regulated Substance
Ethane, 1,1-oxybis-
Ethane, 1,1-difluoroT '.
Ethane, chloro-
Ethanedinitrile
Ethaneperoxoic acid
Ethanethiol ;
Ethene ;
Ethene, 1,1-dichloro-
Ethene, 1,1-difluoro-
Ethene, bromotrifluoro-
Ethene, chloro-
Ethene, chlorotrifluoro-
Ethene, ethoxy- '
Ethene, flupro- ,
Ethene, methoxy-
Ethene, tetrafluoro-
Ethyl acetylene
Ethyl chloride
Ethyl cyanide
Ethyl ether
Ethyl mercaptan ;
Ethyl nitrite
Ethylene
Ethylene oxide
Ethylenediamine
Ethyleneimine
Ethyne
Fluorine
Formaldehyde
Formaldehyde (solution)
Formic acid, methyl ester
Furan
Hydrazine ;
Hydrazine, 1,1-dimethyl-
Hydrazine, methyl- !
Hydrochloric acid (cone 30% or greater)
Hydrocyanic acid
Hydrofluoric acid (cone. 50% or greater)
Hydrogen
Hydrogen chloride (anhydrous)
Hydrogen chloride (gas only)
Hydrogen cyanide
Hydrogen fluoride (anhydrous)
Hydrogen selenide
CAS Number Threshold Quantify
60-29-7 10,000
75-37-6 10,000
75-00-3 10,000
460-19-5 10,000
79-21-0 10,000
75-08-1 10,000
74-85-1 10,000
75-35-4 10,000
75-38-7 10,000
598-73-2 10,000
75-01-4 10,000
79-38-9 10,000
109-92-2 10,000
75-02-5 10,000
107-25-5 10,000
116-14-3 10,000
107-00-6 10,000
75-00-3 10,000
107-12-0 10,000
60-29-7 10,000
75-08-1 10,000
109-95-5 10,000
74-85-1 10,000
75-21-8 10,000
107-15-3 20,000
151-56-4 10,000
74-86-2 10,000
7782-41-4 1,000
50-00-0 15,000
50-00-0 15,000
107-31-3 10,000
110-00-9 5,000
302-01-2 15,000
57-14-7 15,000
60-34-4 15,000
7647-01-0 15,000
74-90-8 2,500
7664-39-3 1,000
1333-74-0 10,000
7647-01-0 5,000
7647-01-0 5,000
74-90-8 2,500
7664-39-3 1,000
7783-07-5 500
Page 4 of 7
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Regulated Substance
Hydrogen sulfide
Iron carbonyl (Fe(CO)5),TB-5-l 1)-
Iron, pentacarbonyl-
Isobutane
Isobutyronitrile
Isopentane
Isoprene
Isopropyl chloride
Isopropyl chloroformate
Isopropylamine
Methacrylonitrile
Methanamine
Methanamine, N,N-dimethyl- .
Methanamine, N-methyl-
Methane
Methane, chloro-
Methane, chloromethoxy-
Methane, isocyanato-
Methane, oxybis-
Methane, oxybis[chloro-
Methane, tetranitro-
Methane, trichloro-
Methanesulfenyl chloride,trichloro-
Methanethiol
Methyl chloride
Methyl chlorocarbonate
Methyl chloroformate
Methyl ether
Methyl formate
Methyl hydrazine
Methyl isocyanate
Methyl mercaptan
Methyl thiocyanate
Methyltrichlorosilane
Monoethylamine
Monomethylamine
Nickel carbonyl
Nitric acid (>= cone 80%)
Nitric oxide
Nitrogen oxide (NO)
Nitrous acid, ethyl ester
Oleum (fuming sulfuric acid)
Oxirane
Oxirane, (chloromethyl)-
CAS Number Threshold Quantity
7783-06-4
13463-40-6
13463-40-6
75-28-5
78-82-0
78-78-4 '
78-79-5
75-29-6
108-23-6
75-31-0
126-98-7
74-89-5
75-50-3
124-40-3
74-82-8.
74_87-3
107-30-2
624-83-9
115-10-6
542-88-1
509-14-8
67-66-3
594-42-3
74-93-1
74-87-3
79-22-1
79-22-1
115-10-6
107-31-3
60-34-4
624-83-9
74-93-1
556-64-9
75-79-6
75-04-7
74-89-5
13463-39-3
7697-37-2
10102-43-9
10102-43-9
109-95-5
8014-95-7
75-21-8
106-89-8
10,000
2,500
2,500
10,000
20,000
10,000
10,000
10,000
15,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
5,000
10,000
10,000
1,000
10,000
20,000
10,000
10,000
10,000
5,000
5,000
10,000
10,000
15,000
10,000
10,000
20,000
5,000
10,000
10,000
1,000
15,000
10,000
10,000
10,000
10,000
10,000
20,000
Page 5 of 7
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Regulated Substance ;
Oxirane, methyl-
Pentane
Peracetic acid
Perchloromethyl mercaptan
Phosgene
Phosphine
Phosphorous trichloride
Phosphorus oxychloride :
Phosphorus trichloride
Phosphoryl chloride
Piperidine
Plumbane, tetramethyl- ;
Propadiene
Propane (postponed by court order)
Propane, 2,2-dimethyl- ;
Propane, 2-chloro- , '
Propane, 2-methyl
Propanenitrile !
Proparienitrile, 2-methyl-
Propene
Propionitrile . j
Propyl chloroformate
Propyleneimine
Propyne
Silane
Silane, chlorotrimethyl-
Silane, dichloro-
Silane, dichlorodimethyl-
Silane, tetramethyl-
Silane, trichloro-
Silane, trichloromethyl-
Sulfur dioxide (anhydrous)
Sulfur fluoride (SF4), (T-4)- i
Sulfur tetrafluoride
Sulfur trioxide '
Sulfiiric acid (fuming)
Sulfuric acid, mixture with sulfur trioxide
Tetrafluoroethylene
Tetramethyllead
Tetramethylsilane i
Tetranitromethane
Thiocyanic acid, methyl ester |
Thiomethanol
Titanium chloride (TiC14)(T-4)-
CAS Number Threshold Quantity
75-56-9 10,000
109-66-0 10,000
79-21-0 10,000
594-42-3 10,000
75-44-5 500
7803-51-2 " 5,000
7719-12-2 15,000
10025-87-3 5,000
7719-12-2 15,000
10025-87-3 5,000
110-89-4 15,000
75-74-1 10,000
463-49-0 10,000
74-98-6 10,000
463-82-1 10,000
75-29-6 10,000
75-28-5 10,000
107-12-0 10,000
78-82-0 20,000
115-07-1 10,000
107-12-0 10,000
109-61-5 15,000
75-55-8 10,000
74-99-7 10,000
7803-62-5 10,000
75-77-4 10,000
4109-96-0 10,000
75-78-5 5,000
75-76-3 10,000
10025-78-2 10,000
75-79-6 5,000
7446-09-5 5,000
7783-60-0 2,500
7783-60-0 2,500
7446-11-9 10,000
8014-95-7 10,000
8014-95-7 10,000
116-14-3 10,000
75-74-1 10,000
75-76-3 10,000
509-14-8 10,000
556-64-9 20,000
74-93-1 10,000
7550-45-0 2,500
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Regulated Substance
Titanium tetrachloride
Toluene diisocyanate(unspecified isomer)
Toluene-2,4-diisocyanate
Toluene-2,6-diisocyanate
Toluenediisocyanate(mixed isomers)
Trichloromethanesulfenylchloride
Trichlorosilane
Trifluorochloroethylene
Trimethylamine
Trimethylchlorosilane
Vinyl acetate
Vinyl acetate monomer
Vinyl acetylene
Vinyl chloride
Vinyl ethyl ether
Vinyl fluoride
Vinyl methyl ether
Vinylidene chloride
Vinylidene fluoride
TAS Number Threshold Quantity
7550-45-0
26471-62-5
584-84-9
91-08-7
26471-62-5
594-42-3
10025-78-2
79-38-9
75-50-3
75-77-4
108-05-4
108-05-4
689-97-4
75-01-4
109-92-2
75-02-5
107-25-5
75-35-4
75-38-7
2,500
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
15,000
15,000
10,000
10,000
10,000
10,000
10,000
10,000
10,000
Page 7 of 7
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