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  • Criteria for selecting alternative release scenarios

    As part of the hazard assessment, owners and operators of Program 2 and Program 3 covered processes must identify and analyze alternative release scenarios (40 CFR §68.28). What criteria should be used when selecting an alternative release scenario? The owner or operator of a stationary source subject to the risk…

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  • Does the distance to endpoint start at the process or stationary source boundary?

    When selecting the worst-case release scenario for Program 2 and 3 processes as required by 40 CFR §68.25, a stationary source owner or operator must analyze the release scenario that results in the greatest distance to an endpoint. Does the "greatest distance to an endpoint" refer to the greatest total…

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  • Using meteorological station data for off-site consequence analyses

    For the purpose of the offsite consequence analyses required under 40 CFR Part 68, Subpart B, there are several instances in which data gathered at a local meteorological station may be used to establish the modeling parameters of wind speed, atmospheric stability, temperature, and humidity for the stationary source. How…

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  • Underground storage tank off-site impacts to groundwater, drinking water, or soil

    For the worst-case and alternative release scenarios of an underground storage tank, should I consider any impact on groundwater, drinking water, or soil? No. As part of the worst-case and alternative release scenarios, you need to define the offsite impacts to the environment (40 CFR §68.33) by listing the environmental…

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  • Administrative controls considered when determining worst-case release quantity

    For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity…

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  • Are Mechanical Controls Considered Administrative Controls?

    For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity…

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  • Worst-case release from smaller process with larger distance to endpoint

    The owner or operator of a stationary source covered by the risk management program regulations must conduct a worst-case release scenario analysis as part of the required hazard assessment (40 CFR §68.25). The worst-case release is defined as the release of the largest quantity of a regulated substance from a…

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  • Can I use any previous three year meteorological data for worst case scenario?

    I am trying to complete my worst case release scenario for the Risk Management Plan under §68.25. I understand that I am required to use a wind speed of 1.5 m/s and F atmospheric stability class as specified in §68.22(b), unless I can prove that at no time over the…

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  • Does the Fee Rule for Abatement and RRP Programs apply nationwide?

    Answer: The rule applies only in those states and tribes without their own authorized lead programs. Currently, EPA implements the Lead-based Paint Activities program in 11 states and the Lead Renovation, Repair, and Painting Rule in 36 states. Question Number: 23002-33305 Find a printable PDF copy of all frequent questions…

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  • Who is affected by the Fee Rule for Lead Abatement and Renovation, Repair and Painting (RRP) Programs?

    The Fee Rule for Lead Abatement and RRP Programs establishes fees that will be charged for training programs seeking accreditation, for firms engaged in renovations seeking certification and for individuals (for example, risk assessors) or firms engaged in lead-based paint activities that govern lead abatement, inspection and risk assessment activities…

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  • What is the timeline for posting the responses? Will we receive an email with notification on the answers or shall I monitor the website for the posting?

    EPA will respond to the individual email 1 - 2 days after receipt and will post the questions and answers to the RFA website very soon thereafter.

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  • How many worst-case release scenarios must be analyzed and documented in the RMP?

    As a part of the hazard assessment requirements in 40 CFR Part 68, Subpart B, I must analyze worst-case release scenarios and document certain analyses in my risk management plan (RMP). How many worst-case release scenarios must be analyzed, and how many analyses must be specifically documented in the RMP…

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  • Identifying public receptors and property with restricted access

    Does public receptor cover only buildings on a property or the entire property? If the owner of the land next to my site restricts access to the land, is it still a public receptor? Public receptors are not limited to buildings. For example, if there are houses near your property…

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  • When to Revise OCA

    The risk management program in 40 CFR Part 68 requires facilities to conduct an off-site consequence analysis (OCA) to provide information to state, local, and federal governments and the public about the potential consequences of an accidental chemical release. When does a facility need to revise its OCA? The owner…

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  • No trespassing signs restricted access onsite or offsite public receptor

    The definition of public receptor is "offsite residences, institutions (e.g., schools, hospitals), industrial, commercial, and office buildings, parks, or recreational areas inhabited or occupied by the public at any time without restriction by the stationary source ..." Offsite is further defined to include "areas within the property boundary [of the…

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