United States
Environmental Protection
Agency
Region 10 M/S ECL-116
1200 Sixth Avenue
Seattle, WA 98101-9797
Alaska
Idaho
Oregon
Washington
Facility and LEPC Assistance
October 1997
&EFA
Guide to the Accidental Release
Prevention Requirements
(Section 112(rY)
of the Clean Air Act
i
For More Information
Contact the Emergency Planning and Community Right-to-Know
Hotline
(800) 424-9346 or (703) 412-9810
TDD (800) 553-7672
Monday-Friday, 9AM to 6PM, eastern time
Visit the CEPPO Home Page at http://www.epa.gov/swercepp/
Contact your EPA Region 10 representative
Melanie Hoff
EPA Washington Operations Office
300 Desmond Dr. S.E, Suite #102
Lacey, WA 98503
360-753-9477
hoff. melanie@epamail. epa. gov
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LIST OF SUBSTANCES FOR ACCIDENTAL RELEASE PREVENTION
CLEAN AIR ACT SECTION 112(R) - FACT SHEET
On 31 January 1994, EPA promulgated a final rule under provisions of the Clean Air Act
(CAA) Amendments s.ll2(r) for the prevention of accidental releases of hazardous
substances. The rule establishes a list of chemicals and threshold quantities that identify
facilities subject to subsequent accident prevention regulations. The listed substances have
the potential to pose the greatest hazard to public health and the environment in the event
of an accidental release. On 15 April 1996, EPA proposed several amendments to the final
rule. The list constitutes the first of two necessary elements for the prevention of chemical
accidents under EPA's CAA mandate. The second element is the requirement for risk
management planning. A facility that handles more than a threshold quantity of a listed
substance in a process is subject to the risk management planning requirements of CAA
section 112(r).
The purpose of the CAA provisions for accident prevention is to ensure that facilities
reduce the likeli-hood and severity of accidental chemical releases that could harm the
public and the environment. These provisions also ensure that the public and state and
local governments can receive facility-specific information on potential hazards and the
steps being taken to prevent accidents.
Regulatoiy Background
In 1986 the Emergency Planning and Community Right-to-Know Act (EPCRA) became
law. EPCRA improves the ability of communities to prepare for and respond to chemical
accidents. Under EPCRA, communities must develop emergency response plans, based
on information that facilities must provide on the hazardous chemicals they handle. In the
1990 amendments to the Clean Air Act, Congress included requirements for accidental
release prevention regulations in section 112(r). Congress also mandated that the
Occupational Safety and Health Administration (OSHA) adopt a process safety
management standard to protect workers from the workplace effects of chemical
accidents; the standard was issued on 24 February 1992.
Characterisitics of the Final Rule
Under the CAA, EPA must develop an initial list of at least 100 substances that, in the
event of an accidental release, could cause death, injury, or serious adverse effects to
human health or the environment.
If a facility has more than a threshold quantity of these substances in a process, then it
must develop and implement a risk management program. That program must include a
hazard assessment, prevention program, and an emergency response program. Summary
risk management plans will be submitted to a central location and will be made
electronically available to state and local authorities as well as the public. The final rule for
risk management planning was promulgated on 20 June 1996.
3
The statutory criteria EPA considered in selecting substances for the list include severity
of acute adverse health effects, likelihood of release, and potential magnitude of human
exposure. EPA set threshold quantities for each regulated substance based on its toxicity,
reactivity, volatility, dispersibility, and flammability, as well as the amount known or
anticipated to cause effects of concern.
The list EPA promulgated in 1994 includes 77 acutely toxic chemicals, 63 flammable
gases and volatile flammable liquids, and Division 1.1 high explosive substances as listed
by DOT in 49 CFR 172.101. The final rule establishes threshold quantities for toxic
substances ranging from 500 to 20,000 pounds. For all listed flammable substances, the
threshold quantity is 10,000 pounds, while all explosive substances have a threshold
quantity of 5,000 pounds. The rule sets forth the procedures for determining whether a
threshold quantity of a regulated substance is present at a stationary source. Specific
exemptions to the threshold determination are also included for mixtures, articles, and
certain uses and activities. The rule also specifies the requirements for petitions to the
Agency to add substances to, or delete substances from, the list.
Proposed Changes
Following EPA's promulgation of the final list rule, some members of the regulated
community raised questions about certain provisions they felt were inconsistent with the
intent EPA expressed in the preamble and other documents supporting the
final rule. In response, EPA published proposed amendments to the final rule on 15 April
1996.
The first proposed modification would be to delete the category of Division 1.1
explosives. The Agency also proposes to exempt from threshold quantity determinations
regulated flammable substances in gasoline used as fuel and in naturally occurring
hydrocarbon mixtures prior to initial processing. Further, the
Agency proposes clarification of the provision for threshold determination of flammable
substances in a mixture. Modifications to the definition of "stationary source" are
proposed to clarify the exemption of transportation and storage related to transportation
and to clarify that naturally occurring hydrocarbon reservoirs are not stationary sources
or parts of stationary sources. In addition, EPA proposes to clarify that 40 CFR part 68
does not apply to sources located on the Outer Continental Shelf. EPA believes these
proposed changes will focus accident prevention more appropriately on stationary
sources with high hazard operations and reduce duplication with other similar
requirements.
For those provisions of the list rule that EPA is proposing to amend, the Agency has
finalized a stay of effectiveness until it takes final action on the proposed modifications.
Thus, owners and operators of processes and sources that EPA has proposed not be
subject to risk management planning requirements would not have to comply with CAA
section 112(r) until EPA has determined whether to finalize the proposed list rule
amendments.
4
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Affected Universe
EPA estimates that approximately 66,000 facilities will be affected by the list and risk
management planning rules, if the proposed list amendments are adopted. The facilities
include chemical and many other manufacturers, cold storage facilities with ammonia
refrigeration systems, public water treatment systems, wholesalers and distributors of
these chemicals, propane retailers, utilities, and federal facilities.
Conclusion
According to the risk management planning requirements of the Clean Air Act, facilities
that handle certain hazardous substances must act to prevent chemical accidents. They
must also share information about their prevention efforts with the public, workers, and
government. EPA expects these new partnerships among stakeholders in prevention
activity to prove a dynamic force in reducing the number and severity of chemical
accidents.
5
RISK MANAGEMENT PLANNING: ACCIDENTAL RELEASE PREVENTION
Final Rule: Clean Air Act section 112(r) - Factsheet
Preventing accidental releases of hazardous chemicals is the shared responsibility of
industry, government, and the public. The first steps toward accident prevention are
identifying the hazards and assessing the risks. Once information about chemicals is
openly shared, industry, government, and the community can work together toward
reducing the risk to public health and the environment. Important new provisions in the
Clean Air Act advance the process of risk management planning and public disclosure of
risk. These requirements will affect facilities that produce, handle, process, distribute, or
store certain chemicals. The final rule for risk management planning was promulgated on
20 June 1996.
Managing Chemicals Safely
Section 112(r) of the amended Clean Air Act (CAA), signed into law on 15 November
1990, mandates a new federal focus on the prevention of chemical accidents. The
objective of section 112(r) is to prevent serious chemical accidents that have the potential
to affect public health and the environment. Under these requirements, industry has the
obligation to prevent accidents, operate safely, and manage hazardous chemicals in a safe
and responsible way. Government, the public, and many other groups also have a stake
in chemical safety and must be partners with industry for accident prevention to be
successful.
The risk management planning requirements of CAA section 112(r) complement and
support the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA).
A milestone in federal actions, EPCRA helps local communities prepare for and respond
to chemical accidents. It requires communities to develop emergency response plans,
based on information from industry concerning hazardous chemicals. Under the new
CAA requirements, stationary sources (facilities) must identify and assess their chemical
hazards and carry out certain activities designed to reduce the likelihood and severity of
accidental chemical releases. Information summarizing these activities will be available to
state and local governments, the public, and all other stakeholders. Using this information,
citizens will have the opportunity to work with industry to reduce risks to the community
from chemical accidents.
In the broadest sense, risk management planning relates to local emergency preparedness
and response, to pollution prevention at facilities, and to worker safety. In a more
focussed sense, it forms one element of an integrated approach to safety and
complements existing industry codes and standards. The risk management planning
requirements build on OSHA's Process Safety Management Standard, the chemical safety
guidelines of the Center for Chemical Process Safety of the American Institute of
Chemical Engineers, and similar standards of the American Petroleum Institute and
Chemical Manufacturers Association, as well as the practices of many other
safety-conscious companies.
6
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It's the Law..
CAA section 112(r) mandates that EPA publish rules and guidance for chemical accident
prevention. These rules must include requirements for sources to develop and implement
risk management programs that incorporate three elements: a hazard assessment, a
prevention program, and an emergency response program. These programs are to be
summarized in a risk management plan (RMP) that will be made available to state and
local government agencies and the public.
Who's Covered
Any source with more than a threshold quantity of a listed "regulated substance" in a
single process must comply with the regulation. "Process," in terms of the regulation,
means manufacturing, storing, distributing, handling, or using a regulated substance in any
other way. Transportation, including pipelines and vehicles under active shipping orders,
is excluded. On 31 January 1994, EPA promulgated a final list of 139 regulated
substances: 77 acutely toxic substances, 63 flammable gases and volatile liquids, and
Division 1.1 high explosives as listed by DOT. The final list rule established threshold
quantities for toxics ranging from 500 to 20,000 pounds. For all listed flammables, the
threshold quantity is 10,000 pounds. EPA proposed modifications to the final list on 15
April 1996. These modifications would exclude facilities handling explosives,
exploration/production facilities for oil and gas, and gasoline.
EPA estimates that approximately 66,000 sources will be covered by the rule, assuming
the proposed list amendments are adopted. The universe includes chemical
manufacturers, other manufacturers, certain wholesalers and retailers, drinking water
systems, wastewater treatment works, ammonia refrigeration systems, utilities, and federal
facilities. Sources with at least one covered process must comply with the rule by June
20, 1999.
Three Levels of Compliance
The final risk management planning regulation (40 CFR part 68) defines the activities
sources must undertake to address the risks posed by regulated substances in covered
processes. To ensure that individual processes are subject to appropriate requirements
that match their size and the risks they may pose, EPA has classified them into three
categories ("Programs").
Program 1 requirements apply to processes for which a worst-case release, as evaluated
in the hazard assessment, would not affect the public. These are sources or processes that
have not had an accidental release that caused serious offsite consequences. Remotely
located sources and processes using listed flammables are primarily those eligible for this
program.
Program 2 requirements apply to less complex operations that do not involve chemical
processing (e.g., retailers, propane users, non-chemical manufacturers, and other
7
processes not regulated under OSHA's PSM Standard).
Program 3 requirements apply to higher risk, complex chemical processing operations and
to processes already subject to the OSHA PSM.
RMP Basics
Sources with processes with a regulated substance above a threshold quantity will be
required to carry out the following elements of risk management planning:
An offsite consequence analysis that evaluates specific potential release
scenarios, including worst-case and alternative scenarios
A 5-year history of certain accidental releases of regulated substances from
covered processes
An integrated prevention program to manage risk
An emergency response program
An overall management system to supervise the implementation of these
program elements
A risk management plan (RMP), revised at least once every five years, that
summarizes and documents these activities for all covered processes
Based on their limited potential for serious offsite consequences, sources are not required
to implement a prevention program, an emergency response program, or a management
system for Program 1 processes. Sources with processes in Program 2 and Program 3
must address each of the above elements.
Links
The OSHA PSM Standard (29 CFR 1910.119) reflects the key elements that the
petrochemical industry, trade associations, and engineering societies have deemed
essential to safe management of hazardous substances for complex, chemical-processing
operations. EPA has adopted OSE1ASM requirements as the Program 3 prevention
program, with only minor changes in terminology. With few exceptions, processes
assigned to Program 3 are already subject to the OSE1A PSM Standard; the remaining
Program 3 processes are in industry sectors that have a significant accident history.
EPA has also worked closely with other regulatory programs that focus on risk
management issues for hazardous chemicals in order to foster co-ordination and reduce
burden. EPA and the National Response Team have prepared Integrated Contingency
Plan Guidance to assist sources subject to multiple regulations in preparing a consolidated
emergency response plan. Further, EPA believes that many of the prevention program
8
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requirements for Program 2 processes and the emergency response program requirements
can be satisfied without additional effort because of existing compliance with other federal
and state regulations, industry standards and codes, and good engineering practices.
Making It Work
To document compliance with the rule and provide risk information, all sources must
submit to a central location a risk management plan that includes a registration, an
executive summary, a 5-year accident history, and offsite consequence analysis
information. Sources with Program 2 and 3 processes also must submit information in
the RMP regarding compliance with requirements for the prevention program and the
emergency response program.
EPA is developing a reporting mechanism and form to collect RMPs in a way that
encourages electronic submission. This will make risk management planning information
available far more widely to the public and at a far lower cost than would traditional
reporting. To support electronic submission and reduce the reporting burden, EPA has
standardized the RMP requirements. With the exception of the executive summary, data
elements will be primarily check-off boxes, yes/no answers, or numerical entries.
An "implementing agency" will oversee these requirements and receive the RMPs. It will
audit and inspect a percentage of sources each year and require whatever revisions to the
RMPs are necessary. Under CAA section 112(1), states may request that EPA delegate
the authority to serve as the implementing agency to a state or local agency with the
appropriate expertise, resources, and authority. States may implement their own
programs, although the law demands that program requirements must be as stringent as
EPAnd must include all EPA-regulated substances and processes. Approximately 30 per
cent of the sources subject to the risk management program requirements must also
comply with Title V of the Clean Air Act, which requires permits for emissions of air
pollutants. Section 112(r) is an applicable requirement for Title V permits.
Help for Small Business
Small and medium-sized enterprises may receive information about CAA section 112(r)
through the Small Business Assistance Program in each state, through the Federal Small
Business Assistance Program, through the network of Small Business Development
Centers across the country, through the EPCRA Hotline, and through a range of
electronic outlets.
T o make compliance easier for small businesses, EPA is working with industry groups
to develop model risk management programs. Initially, these model programs will be
developed for ammonia refrigeration, propane handling, and water treatment operations.
The RMP Offsite Consequence Analysis Guidance will eliminate the need for covered
small operations to invest in computer modeling programs and to answer complex
technical questions (e.g., how to model liquefied gases) related to this element of the
hazard assessment.
9
Looking Ahead..
As this final rule is implemented, EPA plans to publish general technical guidance,
guidance for states on implementation, guidance for Local Emergency Planning
Committees on ways to use RMP information in the community, and additional model
plans for certain industry sectors and regulated substances. In addition, the Agency will
produce training packages and disseminate training through a variety of educational
outlets. Workshops, in co-operation with industry and engineering societies, will also be
presented around the country, as well as teleconferences to introduce the new risk
management planning requirements to a diversity of stakeholders.
With risk management planning as the basis for accident prevention, everybody wins.
Industry has an opportunity to demonstrate excellence in safety. Government can show
effective, efficient leadership in developing sensible requirements. And communities will
have a powerful right-to-know tool, as citizens work together toward reducing chemical
risks to public health and the environment.
10
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List of Regulated Substances and Thresholds for Accidental Release Prevention
(Table includes synonyms)
Name
CAS
Threshold (lbs)
l.l-Dichloroethvlene
75-35-4
10.000
1 .l-Dnnetlwl hydrazine
57-14-7
15.000
1 .2-F.thanediamine
107-15-3
20.000
1.2-ProDadiene
463-49-0
10.000
1.3-Butadiene
106-99-0
10.000
1.3-Butadiene. 2-methvl-
78-79-5
10.000
1.3-Pentadiene
504-60-9
10.000
1 -Buten-3-vne
689-97-4
10.000
1-Butene
106-98-9
10.000
1-Butvne
107-00-6
10.000
1-Chlorooroovlene
590-21-6
10.000
1-Pentene
109-67-1
10.000
1 -Pronene
115-07-1
10.000
1-Prooene. 1-chloro-
590-21-6
10.000
1-Prooene. 2-chloro-
557-98-2
10.000
1-Prooene. 2-methvl-
115-11-7
10.000
1 -Pronvne
74-99-7
10.000
2.2-Dimethvlnronane
463-82-1
10.000
2-Butenal
4170-30-3
20.000
2-ButenaL (cl-
123-73-9
20.000
2-Butene
107-01-7
10.000
2-Butene. (1 1
624-64-6
10.000
2-Butene-cis
590-18-1
10.000
2-Butene-trans
624-64-6
10.000
2-Chlorooroovlene
557-98-2
10.000
2-Methvl- 1-butene
563-46-2
10.000
2-Methvlnronene
115-11-7
10.000
2-Pentene. (1 1-
646-04-8
10.000
2-Pentene. ('/)-
627-20-3
10.000
2-Prooanamine
75-31-0
10.000
2-Prooen- 1-amine
107-11-9
10.000
11
Name
CAS
Threshold (lbs)
2-Prooen-l-ol
107-18-6
15.000
2-Prooenal
107-02-8
5.000
2-Prooenenitrile
107-13-1
20.000
2-Prooenenitrile. 2-methvl-
126-98-7
10.000
2-Prooenovl chloride
814-68-6
5.000
3-Methvl- 1-butene
563-45-1
10.000
Acetaldehvde
75-07-0
10.000
Acetic acid ethenvl ester
108-05-4
15.000
Acetylene
74-86-2
10.000
Acrolein
107-02-8
5.000
Acrvlonitrile
107-13-1
20.000
Acrvlvl chloride
814-68-6
5.000
AIM alcohol
107-18-6
15.000
Allvlamine
107-11-9
10.000
Ammonia (anhydrous)
7664-41-7
10.000
Ammonia (cone 20% or greater)
7664-41-7
20.000
Arsenous trichloride
7784-34-1
15.000
Arsine
7784-42-1
1.000
Aziridine
151-56-4
10.000
Aziridine. 2-methvl
75-55-8
10.000
Benzene. 1.3-diisocvanato-2-methvl-
91-08-7
10.000
Benzene. 1.3-diisocvanatomethvl-
26471-62-5
10.000
Benzene. 2.4-diisocvanato-l-methvl-
584-84-9
10.000
Bisfchloromethvl) ether
542-88-1
1.000
Borane. trichloro-
10294-34-5
5.000
Borane. trifluoro-
7637-07-2
5.000
Boron trichloride
10294-34-5
5.000
Boron trifhioride
7637-07-2
5.000
Boron trifluoride compound with methvl ether (1:1)
353-42-4
15.000
Boron, trifhiororoxvbislmethanell-. CI -4)-
353-42-4
15.000
Bromine
7726-95-6
10.000
Bromotrifhjoroethvlene
598-73-2
10.000
Butane
106-97-8
10.000
Butane. 2-methvl-
78-78-4
10.000
12
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Name
CAS
Threshold (lbs)
Butene
25167-67-3
10.000
Carbon disulfide
75-15-0
20.000
Carbon oxide sulfide (COS)
463-58-1
10.000
Carbonic dichloride
75-44-5
500
Carbonochloridic acid. 1-methvlethvl ester
108-23-6
15.000
Carbonochloridic acid, methvlester
79-22-1
5.000
Carbonochloridic acid, nronvlester
109-61-5
15.000
Carbonvl sulfide
463-58-1
10.000
Chlorine
7782-50-5
Z500
Chlorine dioxide
10049-04-4
1.000
Chlorine monoxide
7791-21-1
10.000
Chlorine oxide
7791-21-1
10.000
Chlorine oxide (Cl( )2)
10049-04-4
1.000
Chloroe thane
75-00-3
10.000
Chloroform
67-66-3
20.000
Chloromethane
74-87-3
10.000
Chlorometbvl ether
542-88-1
1.000
Chloromethvl methvl ether
107-30-2
5.000
Crotonaldehvde
4170-30-3
20.000
Crotonaldehvde. (E>
123-73-9
20.000
Cvanosen
460-19-5
10.000
Cvanopen chloride
506-77-4
10.000
Cvanoaen chloride ((CXK 'I)
506-77-4
10.000
Cvclohexanamine
108-91-8
15.000
Cvclohexvlamine
108-91-8
15.000
Cyclopropane
75-19-4
10.000
Diborane
19287-45-7
2.500
l)iboiane(6)
19287-45-7
Z500
Dichloromethvl ether
542-88-1
1.000
Dichlorosilane
4109-96-0
10.000
Difluoroethane
75-37-6
10.000
Dimethvlamine
124-40-3
10.000
Dimethvldichlorosilane
75-78-5
5.000
Dimethvlhvdrazine
57-14-7
15.000
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Name
CAS
Threshold (lbs)
Eoichlorohvdrin
106-89-8
20.000
Ethanamine
75-04-7
10.000
Ethane
74-84-0
10.000
Ethane, l.l'-oxvbis-
60-29-7
10.000
Ethane. 1.1-difluoro-
75-37-6
10.000
Ethane. chloro-
75-00-3
10.000
Ethanedinitrile
460-19-5
10.000
Ethaneoeroxoic acid
79-21-0
10.000
Ethanethiol
75-08-1
10.000
Ethene
74-85-1
10.000
Ethene. 1.1-dichloro-
75-35-4
10.000
Ethene. 1.1-difluoro-
75-38-7
10.000
Ethene. bromotrifhioro-
598-73-2
10.000
Ethene. chloro-
75-01-4
10.000
Ethene. chlorotrifluoro-
79-38-9
10.000
Ethene. ethoxv-
109-92-2
10.000
Ethene. fhioro-
75-02-5
10.000
Ethene. methoxv-
107-25-5
10.000
Ethene. tetrafluoro-
116-14-3
10.000
Ethvl acetylene
107-00-6
10.000
Ethvl chloride
75-00-3
10.000
Ethvl cvanide
107-12-0
10.000
Ethvl ether
60-29-7
10.000
Ethvl mercaotan
75-08-1
10.000
Ethvl nitrite
109-95-5
10.000
Ethvlene
74-85-1
10.000
Ethvlene oxide
75-21-8
10.000
Ethvlenediamine
107-15-3
20.000
Ethvleneimine
151-56-4
10.000
Ethvne
74-86-2
10.000
Fluorine
7782-41-4
1.000
Formaldehvde
50-00-0
15.000
Formaldehvde (solution)
50-00-0
15.000
Formic acid, methvl ester
107-31-3
10.000
14
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Name
CAS
Threshold (lbs)
Furan
110-00-9
5.000
Hvdrazine
302-01-2
15.000
Hydrazine. 1.1-dimethvl-
57-14-7
15.000
Hvdrazine. methvl-
60-34-4
15.000
Hvdrochloric acid (cone 30% or greater)
7647-01-0
15.000
Hvdrocvanic acid
74-90-8
Z500
Hvdrofluoric acid (conc. 50% or greater)
7664-39-3
1.000
Hvdrosen
1333-74-0
10.000
Hvdrosen chloride (anhydrous)
7647-01-0
5.000
Hvdrosen chloride (yas only)
7647-01-0
5.000
Hvdrosen cvanide
74-90-8
Z500
Hvdrosen fluoride (anhvdrous)
7664-39-3
1.000
Hvdrosen selenide
7783-07-5
500
Hvdrosen sulfide
7783-06-4
10.000
Iron carbonvl fFefCOm (TB-5-Ill-
13463-40-6
Z500
Iron. oentacarbonvl-
13463-40-6
Z500
Isobutane
75-28-5
10.000
Isobutvronitrile
78-82-0
20.000
Isooentane
78-78-4
10.000
Isoorene
78-79-5
10.000
Isooroovl chloride
75-29-6
10.000
Tsonronvl chloroformate
108-23-6
15.000
Isooroovlamine
75-31-0
10.000
Methacrvlonitrile
126-98-7
10.000
Methanamine
74-89-5
10.000
Methanamine. N.N-dimethvl-
75-50-3
10.000
Methanamine. N-methvl-
124-40-3
10.000
Methane
74-82-8
10.000
Methane, chloro-
74-87-3
10.000
Methane. chloromethoxv-
107-30-2
5.000
Methane. isocvanato-
624-83-9
10.000
Methane. oxvbis-
115-10-6
10.000
Methane. oxvbislchloro-
542-88-1
1.000
Methane. tetranitro-
509-14-8
10.000
15
Name
CAS
Threshold (lbs)
Methane, trichloro-
67-66-3
20.000
Methanesutfenvl chloride, trichloro-
594-42-3
10.000
Methanethiol
74-93-1
10.000
Methvl chloride
74-87-3
10.000
Methvl chlorocarbonate
79-22-1
5.000
Methvl chloroformate
79-22-1
5.000
Methvl ether
115-10-6
10.000
Methvl formate
107-31-3
10.000
Methvl hvdrazine
60-34-4
15.000
Methvl isocvanate
624-83-9
10.000
Methvl mercaotan
74-93-1
10.000
Methvl thiocvanate
556-64-9
20.000
Methvltrichlorosilane
75-79-6
5.000
Monoethvlamine
75-04-7
10.000
Monomethvlamine
74-89-5
10.000
Nickel carbonvl
13463-39-3
1.000
Nitric acid (conc 80% or preatert
7697-37-2
15.000
Nitric oxide
10102-43-9
10.000
Nitrosen oxide (NO)
10102-43-9
10.000
Nitrous acid, ethvl ester
109-95-5
10.000
Oleum (rum in s sulfuric acid)
8014-95-7
10.000
Oxirane
75-21-8
10.000
Oxirane. (chloronietlivl)-
106-89-8
20.000
Oxirane. methvl-
75-56-9
10.000
Pentane
109-66-0
10.000
Peracetic acid
79-21-0
10.000
Perchloromethvl mercantan
594-42-3
10.000
Phossene
75-44-5
500
Phosohine
7803-51-2
5.000
Phosphorous trichloride
7719-12-2
15.000
Phosphorus oxvchloride
10025-87-3
5.000
Phosphorus trichloride
7719-12-2
15.000
Phosphorvl chloride
10025-87-3
5.000
Pineridine
110-89-4
15,000
16
-------
Name
CAS
Threshold (lbs)
Plumbane, tetramethyl-
75-74-1
10,000
Propadiene
463-49-0
10.000
Propane
74-98-6
10,000
Propane, 2.2-dinictlivl-
463-82-1
10,000
Propane, 2-chloro-
75-29-6
10,000
Propane, 2-methvl
75-28-5
10,000
Propanenitrile
107-12-0
10.000
Propanenitrile, 2-methyl-
78-82-0
20,000
Propene
115-07-1
10,000
Propionitrile
107-12-0
10,000
Propyl chloroformate
109-61-5
15,000
Propylene
115-07-1
10.000
Propylene oxide
75-56-9
10,000
Propyleneimine
75-55-8
10,000
Propyne
74-99-7
10,000
Silane
7803-62-5
10,000
Silane. chlorotrimethvl-
75-77-4
10.000
Silane. dichloro-
4109-96-0
10,000
Silane. dichlorodimethyl-
75-78-5
5,000
Silane. tetramethyl-
75-76-3
10,000
Silane. trichloro-
10025-78-2
10,000
Silane. trichloromethvl-
75-79-6
5.000
Sulfur dioxide (anhydrous)
7446-09-5
5,000
Sulfur fluoride (SI'4). (T-4)-
7783-60-0
2,500
Sulfur tetrafluoride
7783-60-0
2,500
Sulfur trioxide
7446-11-9
10,000
Sulfuric acid (fuming)
8014-95-7
10.000
Sulfuric acid, mixture with sulfur trioxide
8014-95-7
10,000
T etrafluoroethylene
116-14-3
10,000
Tetramethyllead
75-74-1
10,000
Tetramethylsilane
75-76-3
10,000
T etranitromethane
509-14-8
10.000
Thiocyanic acid, methyl ester
556-64-9
20,000
Thiomethanol
74-93-1
10,000
17
Name
CAS
Threshold (lbs)
Titanium chloride (TiC14) CI -4)-
7550-45-0
Z500
Titanium tetrachloride
7550-45-0
2.500
Toluene diisocvanate (unspecified isomer)
26471-62-5
10.000
T oluene-2.4-diis ocvanate
584-84-9
10.000
T oluene-2.6-diis ocvanate
91-08-7
10.000
Toluenediisocvanate (mixed isomers)
26471-62-5
10.000
Trichloromethanesulfenvl chloride
594-42-3
10.000
Trichlorosilane
10025-78-2
10.000
Trifluorochloroethvlene
79-38-9
10.000
Trimethvlamine
75-50-3
10.000
Trimethvlchlorosilane
75-77-4
10.000
Vinvl acetate
108-05-4
15.000
Vinvl acetate monomer
108-05-4
15.000
Vinvl acetylene
689-97-4
10.000
Vinvl chloride
75-01-4
10.000
Vinvl ethvl ether
109-92-2
10.000
Vinvl fluoride
75-02-5
10.000
V invl methvl ether
107-25-5
10.000
Vinvlidene chloride
75-35-4
10.000
Vinvlidene fluoride
75-38-7
10.000
18
-------
"Threshold Determination
Is a threshold quantity of a regUeted substance in a process?
For Toxics
iNo
Is the substance
MH3, HCL, H=, or
NA?
Yes ^
MH3>20%
HCL>30%,
l"F>50o/q
NAt>80%?
|no
No
Is the substance
< 1%ofthe
wscfit of the
mixture?
Yes
Covered
Process
Yes
Yes
Is quantity of listed
sibstance>
threshold quantity?
Yes
No
Not Coveted
INo
Is the partial
pressire<10
mmHg?
Yes
Not Coveted
No
Covered
Process
Yes
Is the quantity of
sibstanoe>
threshold
quantity?
No
Not Coveted
19
Threshold Determination
Is a threshold quantity of a regUated substance in a process?
For Flammables
Is substance regulated
under the list rule of
112(r)?
Yes
Is the substance pure?
No
Is substance < 1 % of the
weight of the mixture?
No
Does the entire mixture
meettheNFPA4
criteria?
Yes
Is the total c
mixtire>
quar
uantityofthe
threshold
itity?
No
Not covered
No
Yes
Is the quantity of the
pure sibstance >
threshold quantity?
Yes
t
Covered
Process
Yes
Not covered
No
Not covered
No
Not covered
Yes
Covered Process
* There are some exceptions - see list rule
20
-------
CAA 112(r) Applicability and Program Level
Is substance regulated
under the list rule of
No ^
Process not covered.
112(f)?
i Yes
Is the quantity for
substanoe in process
over the threshold
quantity?
.Yes
Has there been an
aocident involving the
substanoe that lead to
death, injury, response
or restoration activities
for an environmental
receptor in past five
years?
.Yes
Is covered process in
SIC code 2611, 2812,
2821,2865, 2869,2873,
2879, or 2911?
.No
Yes
es
No
Is distance to endpoint for
worst-case less than the
distance to any public
receptor?
No
Yes
Has facility coordinated
emergency response
program with local
authorities?
Is covered process
subject to OSHA PSM
29 CFR 1910.119?
No
t
Yes
Program 3 Level Program 2 Level Program 1 Level
21
Program Level Requirements
Program 1
Program 2
Program 3
Hazard Assessment
Hazard Assessment
Hazard Assessment
Worst-case analysis
Worst-case analysis
Worst-case analysis
Alternative releases
Alternative releases
5-year Accident History
5-year Accident History
5-year Accident History
Management Program
Management Program
Management Program
Document
Document
management system
management system
Prevention Program
Prevention Program
Prevention Program
Certify no additional
Hazard review
Hazard review
steps needed
Operating Procedures
Operating Procedures
Training
Training
Maintenance
Maintenance
Incident Investigation
Incident Investigation
Compliance audit
Compliance audit
Management of
Change
Pre-startup review
Contractors
Employee Particip.
Hot Work Permits
Emergency Response P.
Emergency Response P.
Emergency Response P.
Coordinate with local
Develop plan and
Develop plan and
responders
program
program
RMP Contents
RMP Contents
RMP Contents
Executive summary
Executive summary
Executive summary
Registration
Registration
Registration
Worst-case data
Worst-case data
Worst-case data
5-year accident history
5-year accident history
5-year accident history
Certification
Prevention program
Prevention program
Emergency response
Emergency response
Certification
Certification
22
-------
The Risk Management Plan
40 CFR Part 68 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.
68.170 Prevention program/program 2.
68.175 Prevention program/program 3.
68.180 Emergency response program.
68.185 Certification.
68.190 Updates.
68.150 Submission.
(a) The owner or operator shall submit a single RMP that includes the information
requited by §§68.155 through 68.185 of this part for all covered processes. The RMP shall
be submitted in a method and format to a central point as specified by EPA prior to June 21,
1999.
(b) The owner or operator shall submit 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 of this part; 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 of this part.
(d) Notwithstanding the provisions of §§ 68.155 to 68.190 of this part, the RMP shall
e>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 review by Federal and state representatives
who have received the appropriate 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 following elements:
(a) The accidental release prevention and emergency response policies at the stationary
source;
(b) The stationary source and regulated substances handled;
(c) The worst-case release scenario(s) and the alternative release scenario(s), including
administrative controls and mitigation measures to limit the distances for each reported
scenario;
(d) The gsneral accidental release prevention program and chemical-specific prevention
steps;
(e) The five-year accident history;
(f) The emergency response program; and
(g) Planned changes to improve safety.
23
68.160 Registration.
(a) The owner or operator shall complete a single registration form and include 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 company;
(4) The name, telephone number, and mailing address of the owner or operator;
(5) The name and title of the person or position with overall responsibility for RMP
elements and implementation;
(6) The name, title, telephone number, and 24-hour telephone number of the
emergency contact;
(7) For each covered process, the name and CAS number of each regulated substance
held above the threshold quantity in the process, the maximum quantity of each regulated
substance 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 identifier;
(9) The number of full-time employees 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 inspection of the stationary source by a Federal, state,
or local government agency and the identity of the inspecting entity.
68.165 Offsite consequence analysis.
(a) The owner or operator shall submit in the RMP information:
(1) One worst-case release scenario for each Program 1 process; and
(2) For Program 2 and 3 processes, one worst-case release scenario to represent all
regulated toxic substances held above the threshold quantity and one worst-case release
scenario to represent all regulated flammable substances held above the threshold quantity.
If additional worst-case scenarios for toxics or flammables are required by § 68.25(a)(2)(iii)
of this part, the owner or operator shall submit the same information on the additional
scenario(s). The owner or operator of Program 2 and 3 processes shall also submit
information on one alternative release scenario for each regulated toxic substance held above
the threshold quantity and one alternative release scenario to represent all regulated
flammable substances held above the threshold quantity.
(b) The owner or operator shall submit 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 vaporization);
(5) Quantity released in pounds;
(6) Release rate;
(7) Release duration;
(8) Wind speed and atmospheric stability class (toxics only);
(9) Topography (toxics only);
(10) Distance to endpoint;
(11) Public and environmental receptors within the distance;
(12) Passive mitigation considered; and
24
-------
(13) Active mitigation considered (alternative releases only);
68.168 Five-year accident history.
The owner or operator shall submit in the RMP the information provided in § 68.42(b) of
this part on each accident covered by § 68.42(a) of this part.
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 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 processes the information applies.
(b) The SIC code for the process.
(c) The name(s) of the chemical(s) covered.
(d) The date of the most recent review or revision of the safety information and a list
of Federal or state regulations or industry-specific design codes and standards used to
demonstrate compliance with the safety information 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 hazard 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 review.
(f) The date of the most recent review or revision of operating procedures.
(g) The date of the most recent review 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 review or revision of maintenance procedures and the
date of the most recent equipment inspection or test and the equipment inspected or tested.
(i) The date of the most recent compliance audit and the expected date of completion
of any changes resulting from the compliance audit.
(j) The date of the most recent incident investigation and the expected date of
completion of any changes resulting from the investigation.
(k) The date of the most recent change that triggered a review or revision of safety
information, the hazard review, operating or maintenance procedures, or training.
68.175 Prevention program/Program 3.
(a) For each Program 3 process, the owner or operator shall provide the information
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 processes 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 information was last reviewed or revised.
(e) The date of completion of the most recent PHA or update and the technique used.
(1) The expected date of completion of any changes resulting from the PHA;
(2) Major hazards identified;
25
(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 review 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 review or revision of maintenance procedures 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 management of change procedures.
(j) The date of the most recent pre-startup review.
(k) The date of the most recent compliance audit and the expected date of completion
of any changes resulting from the compliance audit;
(1) The date of the most recent incident investigation and the expected date of
completion of any changes resulting from the investigation;
(m) The date of the most recent review or revision of employee participation plans;
(n) The date of the most recent review or revision of hot work permit procedures;
(0) The date of the most recent review or revision of contractor safety procedures; and
(p) The date of the most recent evaluation of contractor safety performance.
68.180 Emergency response program.
(a) The owner or operator shall provide in the RMP the following information:
(1) Do you have a written emergency response plan?
(2) Does the plan include specific actions to be taken in response to an accidental
releases of a regulated substance?
(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 review or update of the emergency response plan;
(6) The date of the most recent emergency response training for employees.
(b) The owner or operator shall provide the name and telephone number of the local
agency with which the plan is coordinated.
(c) The owner or operator shall list other F ederal 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 provided in § 68.12(b)(4) of this part.
(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, information, and belief formed
after reasonable inquiry, the information submitted is true, accurate, and complete.
68.190 Updates.
(a) The owner or operator shall review and update the RMP as specified in paragraph
(b)of this section and submit it in a method and format to a central point specified by EPA
prior to June 21, 1999.
26
-------
(b) The owner or operator of a stationary source shall revise and update the RMP
submitted under § 68.150 as follows:
(1) Within five years of its initial submission or most recent update required by
paragraphs (b)(2)-(b)(7) of this section, whichever is later.
(2) No later than three years after a newly regulated substance is first listed by EPA;
(3) No later than the date on which a new regulated substance is first present in an
already covered process above a threshold quantity;
(4) No later than the date on which a regulated substance is first present above a
threshold quantity in a new process;
(5) Within six months of a change that requires a revised PHA or hazard review;
(6) Within six months of a change that requires a revised offsite consequence analysis
as provided in § 68.36 of this part; and
(7) Within six months of a change that alters the Program level that applied to any
covered process.
(c) If a stationary source is no longer subject to this part, the owner or operator shall
submit a revised registration to EPA within six months indicating that the stationary source
is no longer covered.
27
EPA ANNOUNCES INTERAGENCY INITIATIVE ON EMERG. RESPONSE
FOR RET .EASE: FRIDAY, MAY 31, 1996
EPA ANNOUNCES INTERAGENCY INITIATIVE ON EMERGENCY
RESPONSE
In support of President Clinton's review of federal authorities related to hazardous
materials prevention, mitigation and response, EPA, today announced the publication of
an agreement to implement an interagency "One-Plan Guidance" for release of oil and
hazardous substances. The One-Plan Guidance was developed under the auspices of the
National Response Team, with participation by industry and environmental groups, state
agencies; EPA, the U.S. Coast Guard, the Occupational Safety and Health Administration,
the Research and Special Programs Administration in the Department of Transportation
and the Minerals Management Service in the Department of Interior.
The guidance provides facilities with a common sense option for meeting multiple
emergency planning require-ments under eight different federal regulations. The guidance
includes a core facility response plan for releases of oil and hazardous substances under
existing federal laws. The core plan contains information that emergency responders will
need to implement the initial stages of the response. The core plan will be supplemented
with annexes that contain information such as a description of the facility's incident
command system and data on specific hazards at the facility, required to meet specific
federal regulatory requirements. Facility plans prepared in accordance with the guidance
will satisfy facility emergency response planning requirements of the five agencies listed
above and will be the federally preferred method of such planning. The One-Plan
Guidance approach serves to minimize duplication of effort and unnecessary paperwork
burdens.
Copies of the guidance can be obtained by calling the RCRA/Superfund Hotline at
1-800-424-9346 or 703-412- 9810. The guidance also can be obtained via the Internet at
http://www.epa.gov/swercepp.
28
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Phone Numbers for Spill Reporting
and Hotline Environmental Information
Emergency Release/Spill Reporting -
NRC 1-800-424-8802 (National Response Center)
Individual States (SERC) call:
Alaska 1-800-478-2337
Idaho 1-208-334-4570
Oregon 1-503-378-6377
Washington 911 and then SERC at 1-800-258-5990,
then WA Dept. of Ecology closest Regional Office
NW Reg. 1-206-649-7000, or
SW Reg. 1-360-407-6300, or
Central 1-509-575-2490, or
Eastern 1-509-456-2926
Local LEPC
Note: Other numbers may need to be called.
CHEMTREC 1-800-424-9300 Provides 24 hour information and/or assistance to
emergency responders. Operated by the Chemical Manufacturers Association & does
not fulfil any statutory or regulatory reporting requirements.
Assistance with enviromental concerns about chemicals, wastes and other
materials regulated by your own State.
In the State of Alaska (DEC) 1-907-428-7000
In the State of Idaho (DEQ)
Coeur d'Alene (North Idaho Regional Off.) 1-208-769-1422
Lewiston (North Central ID Reg. Off.) 1 -208-799-4370
Boise (Southwest ID Reg. Off.) 1-208-373-0550
Twin Falls (South Central ID Reg. Off.) 1 -208-736-2190
Pocatello (Eastern ID Reg. Off.) 1-208-236-6160
Idaho Falls (E. ID Satellite Off.) 1 -208-528-2650
In the State of Oregon (DEQ) 1-503-229-5263
In the State of Washington (DOE) 1-800-633-7585
29
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