United States Office of Solid Waste EPA 555-B-04-001 Environmental Protection and March 2009 Agency Emergency Response www.epa.gov/emergencies



# GENERAL GUIDANCE ON RISK
MANAGEMENT PROGRAMS
FOR CHEMICAL ACCIDENT PREVENTION (40 CFR PART 68)

Office of Emergency Management

### ABOUT THIS DOCUMENT

This document provides guidance to help owners and operators of facilities that manufacture, use, store or otherwise handle certain extremely hazardous chemicals to determine if they are subject to EPA’s Chemical Accident Prevention regulations at 40 CFR part 68 and, if so, to comply with those regulations. The discussion in this document is intended solely as guidance. The statutory provisions and EPA regulations described in this document contain legally binding requirements. This document is not a regulation itself, nor does it change or substitute for those provisions and regulations. Thus, it does not impose legally binding requirements on EPA, States, or the regulated community. This guidance does not confer legal rights or impose legal obligations upon any member of the public.

While EPA has made every effort to ensure the accuracy of the discussion in this guidance, the obligations of the regulated community are determined by statutes, regulations, or other legally binding requirements. In the event of a conflict between the discussion in this document and any statute or regulation, this document would not be controlling.

Interested parties are free to raise questions and concerns about the substance of this guidance. This is a living document and may be revised periodically without public notice. EPA welcomes public input on this document at any time.

## TABLE OF CONTENTS

Page

INTRODUCTION

................................................................... i

CHAPTER 1 : GENERAL APPLICABILITY

.......................................... 1-1

1.1 INTRODUCTION

..................................................... 1-1 1.2 GENERAL PROVISIONS

............................................... 1-3 1.3 REGULATED SUBSTANCES AND THRESHOLDS (§68.130)

................ 1-5 1.4 WHAT IS A PROCESS

................................................. 1-6 1.5 THRESHOLD QUANTITY IN A PROCESS

................................ 1-9 1.6 STATIONARY SOURCE

.............................................. 1-15 1.7 WHEN YOU MUST COMPLY

......................................... 1-16

CHAPTER 2 : APPLICABILITY OF PROGRAM LEVELS

............................. 2-1

2.1 WHAT ARE PROGRAM LEVELS?

...................................... 2-1 2.2 PROGRAM 1

......................................................... 2-3 2.3 QUICK RULES FOR DETERMINING PROGRAM 1 ELIGIBILITY

............ 2-9 2.4 PROGRAM 3

........................................................ 2-12 2.5 PROGRAM 2

........................................................ 2-13 2.6 DEALING WITH PROGRAM LEVELS

.................................. 2-15 2.7 SUMMARY OF PROGRAM REQUIREMENTS

........................... 2-18 2.8 EXAMPLE SOURCES

................................................ 2-21

CHAPTER 3 : FIVE-YEAR ACCIDENT HISTORY

.................................... 3-1

3.1 WHAT ACCIDENTS MUST BE REPORTED?

.............................. 3-1 3.2 WHAT DATA MUST BE PROVIDED?

................................... 3-1 3.3 WHEN MUST ACCIDENTS BE REPORTED?

.............................. 3-9 3.4 OTHER ACCIDENT REPORTING REQUIREMENTS

....................... 3-9

CHAPTER 4 : OFFSITE CONSEQUENCE ANALYSIS

................................. 4-1

4.1 INTRODUCTION

..................................................... 4-1 4.2 WORST-CASE RELEASE SCENARIOS

.................................. 4-4 4.3 ALTERNATIVE RELEASE SCENARIOS

................................ 4-12 4.4 ESTIMATING OFFSITE RECEPTORS

................................... 4-20 4.5 EXAMPLES OF WORST CASE SCENARIOS

............................. 4-24 4.6 EXAMPLES OF ALTERNATIVE RELEASES

............................. 4-26

CHAPTER 5 : MANAGEMENT SYSTEM

............................................ 5-1

5.1 GENERAL INFORMATION

............................................ 5-1 5.2 HOW TO MEET THE MANAGEMENT SYSTEM REQUIREMENTS

........... 5-1

## TABLE OF CONTENTS (Continued)

Page

CHAPTER 6 : PREVENTION PROGRAM (PROGRAM 2)

.............................. 6-1

6.1 ABOUT THE PROGRAM 2 PREVENTION PROGRAM

...................... 6-1 6.2 SAFETY INFORMATION (§ 68.48)

...................................... 6-1 6.3 HAZARD REVIEW (§ 68.50)

............................................ 6-7 6.4 OPERATING PROCEDURES (§ 68.52)

.................................. 6-13 6.5 TRAINING (§ 68.54)

................................................. 6-18 6.6 MAINTENANCE (§ 68.56)

............................................. 6-20 6.7 COMPLIANCE AUDITS (§ 68.58)

...................................... 6-23 6.8 INCIDENT INVESTIGATION (§ 68.60)

.................................. 6-25 6.9 CONCLUSION

...................................................... 6-28

CHAPTER 7 : PREVENTION PROGRAM (PROGRAM 3)

.............................. 7-1

7.1 PROGRAM 3 PREVENTION PROGRAM AND OSHA PSM

.................. 7-1 7.2 PROCESS SAFETY INFORMATION (§68.65)

.............................. 7-3 7.3 PROCESS HAZARD ANALYSIS (§68.67)

................................. 7-6 7.4 OPERATING PROCEDURES (§68.69)

................................... 7-9 7.5 TRAINING (§68.71)

.................................................. 7-10 7.6 MECHANICAL INTEGRITY (§68.73)

................................... 7-10 7.7 MANAGEMENT OF CHANGE (§68.75)

................................. 7-12 7.8 PRE-STARTUP REVIEW (§68.77)

...................................... 7-13 7.9 COMPLIANCE AUDITS (§68.79)

...................................... 7-13 7.10 INCIDENT INVESTIGATION (§68.81)

.................................. 7-13 7.11 EMPLOYEE PARTICIPATION (§68.83)

.................................. 7-15 7.12 HOT WORK PERMITS (§68.85)

....................................... 7-15 7.13 CONTRACTORS (§68.87)

............................................ 7-16 APPENDIX 7A PHA TECHNIQUES

.................................... 7-18

CHAPTER 8 : EMERGENCY RESPONSE PROGRAM

................................. 8-1

8.1 NON-RESPONDING FACILITIES (§ 68.90(b))

............................. 8-1 8.2 ELEMENTS OF AN EMERGENCY RESPONSE PROGRAM (§ 68.95)

.......... 8-2 8.3 DEVELOPING AN EMERGENCY RESPONSE PROGRAM

. . . . . . . . . . . . . . . . . . 8-6 8.4 INTEGRATION OF EXISTING PROGRAMS

.............................. 8-9 8.5 HAVE I MET PART 68 REQUIREMENTS?

............................... 8-12 8.6 COORDINATION WITH LOCAL EMERGENCY PLANNING ENTITIES (§ 68.95(c))

......................................................... 8-15

CHAPTER 9 : RISK MANAGEMENT PLAN

.......................................... 9-1

9.1 ELEMENTS OF THE RMP

............................................. 9-1 9.2 RMP SUBMISSION

................................................... 9-3 9.3 ISSUES PERTAINING TO SUBMISSIONS OF AND ACCESS TO CLASSIFIED, CONFIDENTIAL BUSINESS INFORMATION (CBI), AND TRADE SECRETS

... 9-4 9.4 RMP UPDATES, CORRECTIONS AND DE-REGISTRATIONS (§ 68.190)

...... 9-5

## TABLE OF CONTENTS (Continued)

Page

CHAPTER 10 : IMPLEMENTATION

............................................... 10-1

10.1 IMPLEMENTING AGENCY

........................................... 10-1 10.2 REVIEWS/AUDITS/INSPECTIONS (§ 68.220)

............................ 10-2 10.3 RELATIONSHIP WITH TITLE V PERMIT PROGRAMS

.................... 10-4 10.4 PENALTIES FOR NON-COMPLIANCE

.................................. 10-4

CHAPTER 11 : COMMUNICATION WITH THE PUBLIC

............................. 11-1

11.1 BASIC RULES OF RISK COMMUNICATION

............................ 11-1 11.2 SAMPLE QUESTIONS FOR COMMUNICATING WITH THE PUBLIC

........ 11-5 11.3 COMMUNICATION ACTIVITIES AND TECHNIQUES

. . . . . . . . . . . . . . . . . . . 11-13 11.4 FOR MORE INFORMATION

......................................... 11-19

APPENDICES

APPENDIX A 40 CFR PART 68 APPENDIX B SELECTED 2002 NAICS CODES APPENDIX C TECHNICAL ASSISTANCE APPENDIX D OSHA GUIDANCE ON PSM APPENDIX E SUPPLEMENTAL GUIDANCE FOR AMMONIA REFRIGERATION FACILITIES (FORTHCOMING) APPENDIX F SUPPLEMENTAL GUIDANCE FOR WASTEWATER TREATMENT PLANTS (FORTHCOMING) APPENDIX G SUPPLEMENTAL GUIDANCE FOR WAREHOUSES AND CHEMICAL DISTRIBUTORS (FORTHCOMING) APPENDIX H SUPPLEMENTAL GUIDANCE FOR PROPANE STORAGE FACILITIES (FORTHCOMING)

## LIST OF BOXES AND EXHIBITS IN RMP GUIDANCE

LIST OF EXHIBITS

CHAPTER 1 EXHIBIT 1-1 EVALUATE FACILITY TO IDENTIFY COVERED PROCESSES EXHIBIT 1-2 PROCESS EXHIBIT 1-3 STATIONARY SOURCE

CHAPTER 2 EXHIBIT 2-1 EVALUATE PROGRAM LEVELS FOR COVERED PROCESS EXHIBIT 2-2 PROGRAM LEVEL CRITERIA EXHIBIT 2-3 DEVELOP RISK MANAGEMENT PROGRAM AND RMP EXHIBIT 2-4 COMPARISON OF PROGRAM REQUIREMENTS

CHAPTER 3 EXHIBIT 3-1 ATMOSPHERIC STABILITY CLASSES

CHAPTER 4 EXHIBIT 4-1 CONSIDERATIONS FOR CHOOSING A MODELING METHOD EXHIBIT 4-2 

### POSSIBLE SOURCES OF ASSISTANCE ON MODELING EXHIBIT 4-3 REQUIRED PARAMETERS FOR MODELING WORST-CASE SCENARIOS EXHIBIT 4-4 REQUIRED PARAMETERS FOR MODELING ALTERNATIVE SCENARIOS

CHAPTER 5 EXHIBIT 5-1 SAMPLE MANAGEMENT DOCUMENTATION

CHAPTER 6 EXHIBIT 6-1 SUMMARY OF PROGRAM 2 PREVENTION PROGRAM EXHIBIT 6-2 SAFETY INFORMATION REQUIREMENTS EXHIBIT 6-3 CODES AND STANDARDS EXHIBIT 6-4 SAMPLE SAFETY INFORMATION SHEET EXHIBIT 6-5 HAZARD REVIEW REQUIREMENTS EXHIBIT 6-6 SAMPLE CHECKLIST (EXTRACT) EXHIBIT 6-7 OPERATING PROCEDURES REQUIREMENTS EXHIBIT 6-8 TRAINING CHART EXHIBIT 6-9 MAINTENANCE GUIDELINES EXHIBIT 6-10 SAMPLE AUDIT CHECKLIST FOR SAFETY INFORMATION AND HAZARD REVIEW EXHIBIT 6-11 INCIDENT INVESTIGATION REQUIREMENTS EXHIBIT 6-12 SAMPLE INCIDENT INVESTIGATION FORMAT

CHAPTER 7 EXHIBIT 7-1 COMPARABLE EPA AND OSHA TERMS EXHIBIT 7-2 SUMMARY OF PROGRAM 3 PREVENTION PROGRAM EXHIBIT 7-3 PROCESS SAFETY INFORMATION REQUIREMENTS EXHIBIT 7-4 PROCESS HAZARD ANALYSIS REQUIREMENTS EXHIBIT 7-5 OPERATING PROCEDURES REQUIREMENTS EXHIBIT 7-6 MECHANICAL INTEGRITY CHART EXHIBIT 7-7 MANAGEMENT OF CHANGE REQUIREMENTS EXHIBIT 7-8 PRE-STARTUP REVIEW REQUIREMENTS EXHIBIT 7-9 INCIDENT INVESTIGATION REQUIREMENTS

## LIST OF BOXES AND EXHIBITS IN RMP GUIDANCE (Continued)

EXHIBIT 7-10 EMPLOYEE PARTICIPATION REQUIREMENTS EXHIBIT 7-11 HOT WORK PERMITS REQUIREMENTS EXHIBIT 7-12 CONTRACTORS CHART EXHIBIT 7A-1 APPLICABILITY OF PHA TECHNIQUES EXHIBIT 7A-2 TIME AND STAFFING FOR PHA TECHNIQUES

CHAPTER 8 EXHIBIT 8-1 FEDERAL GUIDANCE ON EMERGENCY PLANNING AND RESPONSE EXHIBIT 8-2 FEDERAL EMERGENCY PLANNING REGULATIONS EXHIBIT 8-3 INTEGRATED CONTINGENCY PLAN OUTLINE EXHIBIT 8-4 SAMPLE INTEGRATION EFFORT

CHAPTER 9 EXHIBIT 9-1 RMP UPDATES, CORRECTIONS AND DE-REGISTRATIONS

CHAPTER 11 EXHIBIT 11-1 SEVEN CARDINAL RULES OF RISK COMMUNICATION

## LIST OF BOXES AND EXHIBITS IN RMP GUIDANCE (Continued)

LIST OF BOXES

INTRODUCTION GUIDANCE FOR INDUSTRY-SPECIFIC RISK MANAGEMENT PROGRAMS STATE PROGRAMS IF YOU ARE NEW TO REGULATIONS WHAT IS A LOCAL EMERGENCY PLANNING COMMITTEE?

CHAPTER 1 STATE PROGRAMS Qs AND As: STATIONARY SOURCE AGGREGATION OF SUBSTANCES Qs AND As: PROCESS Qs AND As: STATIONARY SOURCE Qs AND As: COMPLIANCE DATES

CHAPTER 2 Qs AND As: PROCESS AND PROGRAM LEVEL Qs AND As: PUBLIC RECEPTORS Qs AND As: DETERMINING DISTANCES Qs AND As: ENVIRONMENTAL RECEPTORS Qs AND As: ACCIDENT HISTORY Qs AND As: OSHA

CHAPTER 3 Qs AND As: PROPERTY DAMAGE Qs AND As: ACCIDENT HISTORY

CHAPTER 4 RMP OFFSITE CONSEQUENCE ANALYSIS GUIDANCE Qs AND As: WORST-CASE AND MITIGATION HOW TO OBTAIN CENSUS DATA AND LANDVIEW HOW TO OBTAIN USGS MAPS Qs AND As: OFFSITE CONSEQUENCE ANALYSIS EXAMPLES OF WORST CASE SCENARIOS EXAMPLES OF ALTERNATIVE RELEASES

CHAPTER 6 Q AND A: MAINTENANCE Q AND A: AUDITS

CHAPTER 7 Qs AND As: IMPLEMENTATION AND PROGRAM LEVEL Qs AND As: PROCESS SAFETY INFORMATION Q AND A: “REVISING” A PHA Qs AND As: OFFSITE CONSEQUENCES

## LIST OF BOXES AND EXHIBITS IN RMP GUIDANCE (Continued)

CHAPTER 8 WHAT IS “RESPONSE”? WHAT IS A LOCAL EMERGENCY PLANNING COMMITTEE? HOW DOES THE EMERGENCY RESPONSE PROGRAM APPLY? PLANNING FOR FLAMMABLE SUBSTANCES

CHAPTER 10 Qs AND As: DELEGATION Qs AND As: AUDITS

CHAPTER 11 WHAT DOES YOUR WORST-CASE “DISTANCE TO ENDPOINT” OR RELEASE DISTANCE MEAN? WHAT DOES IT MEAN THAT WE COULD BE EXPOSED IF WE LIVE/WORK/SHOP/GO TO SCHOOL X MILES AWAY? IF THERE IS A WORST-CASE ACCIDENT, WILL EVERYONE WITHIN THAT DISTANCE BE HURT? WHAT ABOUT PROPERTY DAMAGE? HOW SURE ARE YOU OF YOUR ENDPOINT DISTANCES? WHY DO YOU NEED TO STORE SO MUCH ON SITE? WHAT ARE YOU DOING TO PREVENT RELEASES? WHAT ARE YOU DOING TO PREPARE FOR RELEASES? DO YOU NEED TO USE THIS CHEMICAL? WHY ARE YOUR DISTANCES DIFFERENT FROM THE DISTANCES IN THE EPA LOOKUP TABLES? HOW LIKELY ARE THE WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS? IS THE WORST-CASE RELEASE YOU REPORTED REALLY THE WORST ACCIDENT YOU CAN HAVE? WHAT ABOUT THE ACCIDENT AT THE [NAME OF SIMILAR FACILITY] THAT HAPPENED LAST MONTH? WHAT ACTIONS HAVE YOU TAKEN TO INVOLVE THE COMMUNITY IN YOUR ACCIDENT PREVENTION AND EMERGENCY PLANNING EFFORTS? CAN WE SEE THE DOCUMENTATION YOU KEEP ON SITE?

## INTROD UCTION

WHY SHOUL D I REA D THIS GUI DA NCE?

If a tank , drum, con tainer, pipe, or other “p rocess” at your facility contains any of the extremely haz ardous toxic and flam mable substances listed in the Code of F ederal Regulat ions (C FR) at 40 CFR 68.13 0 in an amou nt above the “th resho ld quan tity” specified for that substance, you are required to develop and im plement a risk
managem ent program under a rule issued by the U.S. Env ironmental Protection Agency (E PA). (See Appe ndix A of this docum ent for the list of substances and the threshold quantity estab lished for each substance.) The rule, “Chem ical Accident Prevention Prov isions” (part 68 of Title 40 of the CFR ), applies to a wide v ariety of facilities that handle, m anufacture, store, or use toxic substances, including chlorine and am monia and hig hly fl amm able sub stances such as propan e (flam mable substances used solely as fuel or sold by retailers are not covere d). This documen t provides technical g uidance on how to determine if y ou are subject to part 68 and how to comp ly with part 68. The original com pliance deadline for part 68 was June 21, 1 999, for f aci lit ies subj ect to th e par t by th at da te. F or so urce s tha t fi rst beco me subject to part 68 after June 21, 1 999, you m ust be in comp liance no later than the date on which y ou first have m ore than a threshold qua ntity of a listed substa nce in a
process.

The goal of part 68 and the risk m anagement program it re quires is to prevent accidental releases of substances that can cause serious h arm to the public and the environment from short- term exposures an d to mitigate the severity of releases that do occu r. Und er the C lean Ai r Act (C AA), E PA was require d to iss ue a rul e specifying the types of actions to be taken by facilities (referred to in the law as stationa ry sou rces) to preve nt accid ental re leases o f such h azardo us chem icals in to the atmosphere an d reduce their potential im pact on the public and the environm ent. Part 68 is that rule.

In general , part 6 8 requi res th e foll owing:



### � Covered facilities m ust develop and implement a risk man agement pro gram and maintain doc umentation of the program at the site. The risk

mana gem ent prog ram in cludes a n analy sis of th e poten tial offs ite
conseq uences of a wors t-case ac ciden tal re lease , a five-year accide nt hist ory, a rele ase pre ventio n progra m, and emerge ncy plan ning.



### � Covered facilities m ust develop and submit a risk managem ent plan (RMP) to EPA no later than June 21, 1999, or th e date on which the facility first has more than a thres hold quantity of a listed substance in a process , whichever is later. The RMP ge nerally describes the fac ility’s risk m anagement program. The RMP is available to federal, state, and loca l governm ent agencies and the p ublic, with som e restrictions on the av ailability of the offsite consequence analy sis sections of the RMP.



### � Cover ed facil ities m ust im pleme nt the r isk m anage ment progr am an d updat e their RMPs periodically or when certain process or other changes o ccur, as required by the rule.Introduction -iiThe phrase "risk management program" refers to all of the requirements of part 68, which must be implemented on an ongoing basis. The phrase "risk management plan (RMP)" refers to the document describing the risk m anagement program that you must submit to EPA.

HOW DO I USE THIS DOCUMENT?

This document is a technical guidance designed for owners and operators of sources covered by part 68. It will help you to:

 Determine if you are covered by the rule;

 Determine what level of requirements is applicable to your covered process(es);

 Understand what specific risk management program ac tivities must be conducted;

 Select a strategy for implementing a risk managemen t program, based on your current state of compliance with other government rules and industry standards and the potential offsite impact of releases from y our process(es), and;

 Understand the reporting, documentation, and risk c ommunication components of the rule.

This document provides guidance and reference mater ials to help you comply with EPA's chemical accident prevention regulations. It does not create any legally binding requirements on its own; its purpose is to help explain the requirements already established in part 68. It does not provide guidance on any other rule or part of the CAA. 

### GUIDANCE FOR INDUSTRY

- SPECIFIC RISK MANAGEMENT PROGRAMS

EPA worked with industry representatives to develop supplemental guidance for industryspecific risk management programs for the following industries:

 Propane storage facilities  Chemical distributors  Waste water treatment plants  Warehouses  Ammonia refrigeration

Industry-specific guidance is either appended to th is guidance or is contained in stand-alone documents that you can obtain from EPA's website at www.epa.gov/emergencies/rmp . If an industry-specific appendix or guidance document exi sts for your process(es), you should consider using it because it will provide more info rmation that is specific to your process(es), including dispersion modeling and prevention progra m elements.-iii- Int roduct ion



### STATE PROGRA MS

This guidance applies to 40 CFR part 68. You should check with yo ur state govern ment to determ ine if the st ate has its own acciden tal relea se prev ention r ules or has obt ained d elegat ion from EPA to implement and enforce an accidental release prevention prog ram as a substitute for part 68 in you r state. State rules m ay be m ore stringent that EP A’s rules. They m ay cover m ore substances or cover the same substanc es at lower thresholds. They may also impose ad ditional requirements. For

exam ple, Ca lifornia ’s state progr am re quires a seism ic study

. See C hapter 1 0 for in forma tion on state imple menta tion of part 68. Unles s you r state h as been grant ed dele gation , you must comp ly wit h part 68 as described in this document even if your stat e has different rules under stat e law.



### WHAT DO I DO FIRST?

Before developing a risk m anagement program, you should do five things:

(1) Determine which, if any, of your pro cesses are covered by this program

Only sources w ith a threshold quantity of a “listed” or “reg ulated” substance (see Ap pendix A) in a “proce ss” nee d to com ply w ith part 68. “P rocess” is defined by the rule in § 68.3 and do es not necessarily correspond with an engineering co ncept of process. The req uirements apply only to cov ered
processes. See Chap ter 1 for more in formation on how to determine w hether you have one or more “p rocesses” subject to the rule.

(2) Determine the appropria te program level for each cov ered process

Depending on the specific characteristics of a co vered process and the results of the offsite conseque nce analysis for that process, it may be subject to one of three different sets of requirements (called program lev els). See Chapter 2 for m ore information.

(3) Determine EPA's requirements for the facility and each covered process

Certain require ments apply to the f acility as a wh ole, wh ile othe rs are process-specific. See Chapter 2 for m ore information.

(4) Assess your operation s to identify current risk man agement activities

Because you pro bably conduct som e risk man agement activ ities already (e.g. , emp loyee trainin g, eq uipme nt ma intenan ce, and emer gency plannin g), you should rev iew your current o perations to determine the extent to which they meet the provisions of this rule. EPA does not expect you to redo these activities if they alrea dy meet th e rule's requirem ents. See Chapters 5 to eight individually for guidance on how to tell if your existing practices can mee t those require d by EPA.

(5) Review the regulations and this guidance to dev elop a strategy for conducting the add itional actions you nee d to take for each cover ed pro ces s. Dis cus s th e re qui rem ent s wit h ma nag eme nt a nd s taff.Introduction

March 2009 -ivThe risk management program takes an integrated app roach to assessing and managing risks and will involve most of the operati ons of covered processes. Early involvement of both management and staff will help develop an effective program.



### FLEXIBLE NATURE OF REQUIREMENTS

Finally, keep in mind that many part 68 requirement s do not specify exactly what you must do to meet them; instead, they provide you wit h flexibility to develop an approach that makes sense for your facility. This a llows you to tailor your program to fit the particular conditions at your facility. The degree of complexity required in a risk management program will depend on the complexi ty of the facility. For example, the operating procedures for a chemical distributor are likely to be relatively brief, while those for a chemical manufacturer will be ext ensive. Similarly, the length of training necessary to educate employees on such pro cedures will be proportional to the complexity of your operating procedures. And wh ile a facility with complex processes may benefit from a computerized maintenan ce tracking system, a small facility with a simpler process may be able to trac k maintenance activities using a logbook.

There is no one "right" way to develop and implemen t a risk management program. Even for the same rule elements, your program will be different from everyone else's programs (even those in the same industry) because it will be designed for your specific situation and hazards — it will reflect wh ether your facility is near the public and sensitive environmental areas, the specific equ ipment you have installed, and other relevant factors.



### WHERE DO I GO FOR MORE INFORMATION?

EPA’s chemical accident prevention requirements wer e published in the **Federal Register**  on January 31, 1994 (59 FR 4478) and June 20, 1996 (61 FR 31667). EPA has amended the rules several times. A consolidated copy of these regulations is available in Appendix A.

EPA works with industry and local, state, and feder al government agencies to assist sources in complying with these requirements. For m ore information, refer to Appendix C (Technical Assistance). Your local emerg ency planning committee (LEPC) also can be a valuable resource and can help you discuss issues with the public.

Finally, if you have access to the Internet, EPA ha s made copies of the rules, fact sheets, and other related materials available at th e home page of EPA's Office of Emergency Management at: www.epa.gov/emergencies/rmp . Please check the site regularly as additional materials are posted.-v- Int roduct ion



### GLOSSARY OF TERMS

We hav e tried t o mak e this d ocum ent as c lear and readab le as po ssible, but if y ou hav e rarely dealt with regulations before , some of the language m ay seem in itially odd and con fusing. All reg ulations have their own v ocabulary. A few words and phras es have very specific meaning s within the regulation. Som e of these are unusual, which is to say they are not used in everyday language. Others are defined by the rule in way s that vary to some deg ree from their ev eryday m eaning. The followi ng are the m ajor reg ulatory terms used in this do cume nt and a brief in troduct ion to t heir meaning w ithin the context of part 68

. They are defined in § 68.3 of the ru le.

“ Stationary source” basical ly m eans fac ility. The CA A, and thus pa rt 68, u se the t erm “ stationa ry source” and we explain it in C hapter 1

. Gene rally, we use “facilit y” in its plac e in thi s docum ent.

“Process” is given a broad meaning in this rule and docum ent. Most people think of a process as the mixing or reacting of chem icals. Its m eaning under this ru le is much broad er. It basically means any equipment, includ ing storage v essels, and activities, such as loading, that involves a regulated substance and could lead to an accidental release. Chapter 1 discusses th e definition of process under th is rule i n detail

. “Regulated substance” means one o f the 140 chem icals listed in part 68.

“Threshold quantity” means the qu antity, in pounds, of a regulated sub stance which, if exceed ed, trigger s covera ge by this r ule. Eac h regula ted sub stanc e has it s own thr eshol d quant ity. If you have more than a thres hold quantity of a regulated substance in a process, you must com ply with the rule. Chapte r 1 expl ains ho w to det ermine wh ether you have a th resho ld quan tity.

“Vesse l” means any container, from a single drum or pipe to a larg e storage tank or sphere.

“Public receptor” generally m eans any place w here people live, w ork, or ga ther, with the exception of roads. Building s, such as houses, shops, office building s, industrial facilities, the areas surrounding building s where people are lik ely to be present, such as yards and parking lots, and recreati onal are as, suc h as par ks, s ports ar enas, r ivers, lakes , beach es, are consid ered pu blic receptors. Chapter 2 d iscusses public receptors.

“Environmental receptor ” means a lim ited number of n atural areas that are officially designated by the state or federal go vernment. Chapter 2 discusses this definition.Int roduct ion -vi

### WHA T IS A LOCA L EMERGENC Y PLA NNING COM MITTEE?

Local emerg ency planning committee s (LEPCs) were form ed under the Federal E mergency Planning and Comm unity Right- to-Know Act (E PCRA) of 1986. The comm ittees are designed to serve as a

commun ity forum fo r issues relating to prep aredness for emerg encies involving hazardous substances. They consist of representatives from local govern ment, local indu stry, transportation groups, health an d medical org anizations, com munity g roups, and the m edia. LEPCs:



### � Collect information fro m facilities on haz ardous substances that pos e a risk to the community; 

### � Develop a conting ency plan for the commun ity based on this information; and 

### � Make information on hazardous su bstances available to th e general public.

Contact the may or's office or th e county em ergency m anagement office for more inform ation on your LEPC.

## CH APTER 1 : GE NER AL APPLI CABIL ITY

1.1 INTRODUC TION

The purpose of this chapter is to help you determ ine if you are sub ject to Part 68, the risk manag ement prog ram rule. Part 68 covers y ou if you are:



### � The own er or op erato r of a st ation ary sour ce (fa cilit y)



### � That has more than a t hreshol d quant ity



### � Of a regulated sub stance



### � In a process.

The goa l of this chapte r is to m ake it easy for yo u to ide ntify process es that are

cove red b y thi s rul e so yo u can focu s on t hem.

This chapter walks y ou through the k ey decision points (rather than the definition items above), starting with those provisions that m ay tell you that you are not s ubject to the rule. We first outline the general applicability provisions and th e few

exem ptions a nd excl usions, then di scuss w hich ch emica ls are "r egula ted sub stances ." If y ou do n ot hav e a "reg ulated s ubstanc e" at y our site , you are not cover ed by this rule. Th e exem ptions m ay exc lude you from the rul e or sim ply ex clude c ertain activities fr om consideration. (T hroughout this document, whe n we say "rule" we mean the reg ulations in part 68.)

We then describ e what is consi dered a "proces s," whi ch is cr itical be cause y ou are subject to the rule only if you hav e more than a threshold quantity of a regulated substance in a process. The chapter next describes h ow to determine whether you have more t han a th resho ld quan tity.

Finally, we discu ss how you d efine your ov erall stationary source an d when you
must comp ly. Th ese que stions a re imp ortant o nce yo u hav e decid ed that you a re

cover ed. Fo r mos t facilit ies cov ered by this ru le, the stationa ry sou rce is b asically all covered processes at your site. I f your facility is part of a site with other divisions of
your comp any or other com panies, the discussion of stationary source will help you underst and wh at you are resp onsible for in y our com pliance and rep orting

. Exh ibit 1-1 prese nts the decisi on proc ess for deter mining app licab ilit y.



### STATE PROGRAMS

This gu idance applies to only 40 CFR part 68

. You should check with y our stat e gov ernme nt to determine if the state has its own accidental relea se prevention rules o r has obtained deleg ation from EPA to impl emen t and en force pa rt 68 in your state. State ru les m ay be more string ent than EPA’s rules. Unless your s tate has been g ranted d elegat ion, y ou mu st com ply w ith part 68 as d escribed in this document ev en if your state has different rules under state law

. See Chapter 10 for a discussion of state implem entation of part 68.Chapter 1 Ge neral A pplic ability 1-2



### EXHIBIT 1-1 EVALUATE F ACILITY TO I DENTIFY COVERED P ROCESSES

No

Yes

No

Yes

No

Yes Is y our fac ility a stationary

source?

Do you have
any reg ulated substanc es?

Define your

processes STOP! You are not covered by t he rule

Do you have any regulated substances above

a thresh old q uantity in
a proc ess?



### You are subject to the rule

Assign Program levels to covered
processes (see Exhibit 2-1)Chapter 1 1-3 Ge neral A pplic ability

1.2 GENERAL PROVISIONS

The CAA applies the R isk Managem ent Program rule to any perso n who owns or operate s a stati onary source

. "Pers on" is d efined t o includ e:

"An individual, co rporation, partnership, assoc iation, State, mu nicipality, political subdivision of a state , and any ag ency, departm ent, or instrumenta lity of the United States a nd any officer , age ncy, or em ploye e thereo f."

The rule, therefore, applies to all levels of go vernment as well as private bu sinesses.

CAA section 112(r)(2)(c) defines "stationary sources" as:

"Any buildin gs, s tructure s, equi pmen t, insta llations , or su bstance emitt ing st ationary activities



### � Which belong to the same industrial g roup,



### � Which are located on one or more contig uous properties,



### � Which are under the control of the same perso n (or persons under co mmon control), and



### � From which a n accidental release m ay occur."

EPA has added so me languag e in the rule to clarify issues related to transportation (see bel ow).

F A RM U SE OF A M M ON IA (§68.125)

The rule exempts am monia when held by a farm er for use on a farm

. This exemption applies to am monia only when u sed as a fertiliz er by a farm er. I t does n ot apply to agricu ltural su ppliers or the f ertiliz er ma nufactu rer. I t does n ot apply to farm cooperatives or to g roups of farmers w ho buy, use, and sell amm onia. In the event that a fa rmer s tores on e or m ore othe r regu lated su bstance abov e thresh old quantities, that storage would be covere d.

F LAMMABLE F UELS (§68.126)

The flam mable substan ces liste d in § 6 8.130 are excl uded fr om co verag e under part 68 whe n they are use d as a f uel or h eld for sale as a fuel a t a retai l facilit y. A retail facility is defin ed as a stationa ry sou rce at w hich m ore than half of the inc ome i s obtained from direct sales to end users or at which more tha n one-half of the fuel sol d, by vo lume, is so ld th roug h a cyl inde r exc hange progr am.
Unless your facility meets the definition of a “retail facility,” if you hold a listed flamm able sub stance f or purp oses oth er than on-s ite use as fuel, you a re poten tially

cover ed by part 68 . For e xamp le, if y ou ma nufactu re a list ed flam mable fuel, u se it as a che mical feedsto ck, o r store i t in bul k for sale and do not meet the def inition of a retail fa cility, you m ay be cover ed by the rul e. I f you store a listed fl amm ableChapter 1 Ge neral A pplic ability 1-4

substance for non- fuel use and also use s ome of it on- site as a fuel, the quantity used as a fue l is not cover ed; the quantit y not used on site as a fuel is potenti ally s ubject to the rule. If y ou are a retailer who sells a flammab le fuel and a listed toxic s ubstance, the toxi c substa nce is p otential ly sub ject to th e rule, but the flamm able sub stance i s excluded from co verage.

T RANSPORTATI ON A CTIVI TIES

The rule applies only to stationary sources. It does not apply to transportation, including storag e incident to transportation. Transportation includes, but is not limited to, transportation subject to oversight or regulation under 49 CFR parts 192 (Federal safety standards for transportation of natural a nd other gas by pipeline), 193 (Federa l safety standar ds for l iquefied natural gas f acilities ), or 19 5 (Fede ral safe ty standards for transportation of hazardous liquids by pipeline), or a state natura l gas or hazardous liqui d program for which the state has in effect a cer tificatio n to DOT under 49 U.S.C . 60105. Storag e of natural gas inc ident to transportation (i.e., gas taken from a pipeline during n on-peak periods and placed in storage fields, then returned to the p ipeline when n eeded) is not c overe d. Sto rage f ields in clude, but are not limited to, d epleted oil and gas reservoirs, aquifers, m ines, or caverns.



### Q S 

### & As S TATI ONARY 

### S OURCE

Q. What does “sam e industrial group” m ean?

A. Operations at a site that be long to the sam e three-dig it North American Industry Classification System (N AICS) cod e prefix (which has replac ed the old SI C codes) belong to the “same ind ustrial
group. I n addition, where on e or more opera tions at the site serve primarily as su pport facilities for the main operation at the site, the supporting operations are part of the “same industrial g roup” as the main operatio n. For exam ple, if you m anufact ure che mical s (NAI CS 325 ) and op erate a w aste treatment facility (N AICS 56 2) that handles prim arily wastes ge nerated by y our chemical opera tions, the waste operation wo uld be considered a sup port operation. I f you operate a p etrochemical manufacturing operat ion (NAICS 32511) next to your petrol eum refinery (NAICS 32411), the two plants would be consid ered in different industrial g roups and would requ ire two RMPs unless the majorit y of th e refine ry’s p roducti on was used by the che mical manu facturin g plan t.

Q. What does “contig uous property” m ean?

A. Property that is adjoining. Public rig hts-of- way (e.g. , railroads, highw ays) do not prev ent property from being considered contiguous. Pro perty connected on ly by rig hts-of- way are not conside red con tiguou s (e.g ., two plants with a c onnecti ng pip eline).

Q. What does “control of the same person” mean?

A. Contr ol of th e sam e perso n refers to corp orate co ntrol, n ot site m anage ment. If t wo div isions o f a corporation operate at the sa me site, ev en if each operation is m anaged separately , they will coun t as

one sou rce pr ovided t he othe r crit eria a re met bec ause th ey are und er cont rol of the same c ompany.Chapter 1 1-5 Ge neral A pplic ability

Transportation containers used for storage not incident to transportation and transpo rtation contain ers con nected to equip ment at a stat ionary source are considered part of the station ary source. Transportation containers that have been unhooked from the motive power that delivere d them to the site (e.g., truck or locomotive) a nd 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 sid ing that you use as stora ge tan ks un til yo u are re ady to hook them to yo ur proc ess, th ese rail cars should be considered to be part of your s ource. If a tank truck is being unloaded and the m otive power i s still a ttached , the tr uck an d its co ntents a re cons idered t o be in transpo rtation and not cover ed by the rul e. You should count o nly th e substa nces in the pipi ng or hosing as well as the q uantity unload ed. S ome i ssues re lated to
tran spor tatio n are stil l und er di scus sion with DOT.

R ELA TI ONSH IP TO OSHA P ROCESS S AFETY M ANA GEMENT S TANDARD E XEMPTIONS

The OSHA Process S afety Managem ent (PSM) standard (29 C FR 1910.119) exempts retail facilities, s ubstances used solely as a fuel if such subs tances are not part of a proce ss conta ining another regul ated sub stance, flamm able liq uids sto red in atmospheric storag e tanks, and rem ote oil and gas p roduction. In addition, state and local governm ents are not subject to federal O SHA standards.

EPA's R isk Managem ent Program Rule has a different set of exemptions tha n the OSHA PSM stan dard; O SHA ex empts some proces ses that EPA d oes not exem pt, and vice ve rsa. You should c arefully evaluate the exemptions o f the Risk Manage ment Progr am ru le to de termin e wheth er you r proces s is cov ered, e ven if it qualifie s for an OSHA PSM ex empti on. Fo r exam ple, th e EPA rule exe mpts flammable substances used as fuel a nd fuels sold at retail facilities, but does not exempt non- fuel substances sold at retail fa cilities. The EPA rule do es not exempt substances stored in atm ospheric storage tank s, and it applies to state and local
governm ents. If su ch governm ents own or operate a facility where there is more than a threshold quantity of a regulated substa nce in a process, they must com ply with the rule. As discussed in Section 1.5, m any oil and g as production facilities, as w ell as most retail gas stations and propane retailers are not subject to the rule bec ause the flammable substances at these facilities are e xcluded from thres hold determinations.

1.3 REGULA TED SUB STA NCES A ND THRE SHOLDS (§68.13 0)

The list of substances regu lated under § 68.130 is in Appendix A. Check the list carefull y. I f you do not have a ny of these su bstance s (eithe r as pur e substa nces or in mixtures abov e 1 percent concentration) o r do not have th em above their listed threshold quantities, y ou do not need to read any further bec ause you are no t covered.

The list includes 77 chem icals that were listed because they are acutely toxic; they can cause serious health e ffects or death from short-term exposures. The list also

cover s 63 fla mm able g ases an d high ly v olatile f lamm able liq uids. Th e flam mable chemicals hav e the potential to form vapor clouds an d explode or burn if re leased. The rule also cov ers flam mable mixt ures tha t includ e any of the l isted fla mm ables if the mixture meets the cri teria for the Nat ional Fire Prot ection Associa tion's (NFPA) 4 rating (see Ch apter 1, section 1.5).Chapter 1 Ge neral A pplic ability 1-6

1.4 WHAT IS A PROCESS

The conc ept of "p rocess" is key to whe ther y ou are s ubject to this ru le. Pro cess is defined in 40 CFR §68.3 as:

"Any activity involving a regulated substan ce, including any use, storage, manufacturing, handling, or on-site m ovement o f such substances, or c ombination of these ac tivitie s. For the pur poses o f this d efinitio n, any group of ve ssels th at are interconnected, or separate v essels that are located such that a regulated substa nce could be involv ed in a potential release, shall be considered a sing le process."

"Vessel" i n §68. 3 mea ns any reactor , tank , drum , barre l, cyl inder, vat, k ettle, b oiler, pipe, h ose, or other c ontaine r.

EPA’s definiti on of process is ide ntical to the de finition of pr ocess under the OSHA PSM standard. Unde rstanding the definition of process is impo rtant in determining whether you hav e a threshold quantity of a regulated sub stance and what lev el of requirements y ou must m eet if the process is cov ered.

What does this mea n to you?



### � If you store a regulated sub stance in a single v essel in quantities abov e the threshold quantity, y ou are covered.



### � If y ou hav e interc onnecte d vess els that altog ether ho ld mo re than a thresh old quantity of a reg ulated substance, y ou are covered. The connections need not be permanen t. If two or more v essels are connected occasion ally, they

are con sidered a sing le proce ss for th e purpo ses of d eterm ining whethe r a thresho ld quan tity is presen t.



### � If you have multiple unconnected vess els containing the sam e substance, you will have to determ ine whether they are co-located a nd thus considered a single process for pu rposes of the rule.

A process can be as simple as a sing le storage vesse l or a group of drums or cylinders in one loc ation or as comp licated as a system of interconnected reactor vessels, distillation colum ns, receivers, pum ps, piping, and storage vesse ls.

S INGLE V ESSELS

If y ou hav e only a sing le ves sel cont aining a reg ulated s ubstanc e, yo u need not wor ry about the other possibilities for defining a process a nd can skip to section 1.5. For the purp oses of definin g a th reshold quantit y, y ou need only conside r the qu antity in this v essel.

I NTERCONNECTED V ESSELS

In g eneral, if you have two or more vesse ls that c ontain a regul ated sub stance a nd are connected through piping or hoses fo r transfer of the regulated substance, you must consider the total quantity of the regulated su bstance in all the connected vessels andChapter 1 1-7 Ge neral A pplic ability

piping when d eterm ining if you have a thresh old qua ntity in a pro cess. I f the v essels are connected for transfer of the substance using hoses that are som etimes disconnected, you still have to consid er the contents of the v essels as one process, because if one v essel w ere to ru pture w hile a h ose was attache d or a h ose wer e to break during the transfer, both tank s could be affected. Therefo re, you m ust count the quantities in both tank s and in any co nnecting piping or hoses. You cannot conside r the pr esence of autom atic shu toff v alves or other devic es that can lim it flow, because these are assumed to fail for the purpose of determ ining the total quantity in a proces s.

Once you hav e determined that a process is covered (the process contains m ore than a thresh old qua ntity of a reg ulated s ubstanc e), yo u mus t also c onsider equipm ent, piping, hoses, or other interconnections that do not carry or c ontain the regulated substance, but that are im portant for accidental release pre vention. Equip ment or

connec tions which co ntain utili ty servic es, pro cess co oling wa ter, st eam, elec trici ty, or other non- regulated substances m ay be considered part of a process if such equipment could cause a regulated su bstance release or interfere with mitigating the consequences of an accid ental release. Your prev ention program for this process will need to cove r such equipmen t. If, bas ed on your ana lysis, it is determ ined that interconnected equipm ent or connections not c ontaining the reg ulated substance cannot cause a reg ulated substance release or in terfere with mitig ation of the consequences of such a release, then such equ ipment or connec tions could safely be considered outside the lim its or boundaries of the c overed process.

In som e cases, such as in a large refinery o r multi-u nit chemical plant, determining the boundaries of a proc ess for purposes of the RMP rule may be complicated. In the preamble to the June 20, 1996 rule (61 F R 31668), EPA clearly stated its intent to be consist ent with OSHA ’s interp retation of “pr ocess” as that term i s used i n OSHA ’s PSM rule. Therefore, if y our facility is subject to the PSM rule, the lim its of your process(es) for purposes of OSHA PSM will b e the limits of y our process(es) for
purpose s of RMP (excep t where the two rules’ a pplicab ility d iffer su ch as fo r retail facilitie s and atmospheric stor age tanks). If your facility is not covered by OSHA PSM and is com plicated from an e ngineering persp ective, you should consider contacting you r implemen ting agency for advice on d etermining pro cess boundaries.

C O -L OCA TI ON

The third possibility y ou must conside r is whether you have separate v essels that contain the same regulated substance tha t are located such that they could be involv ed in a single release

. I f so, y ou mu st add t ogeth er the to tal quan tity in all such v essels t o determ ine if y ou hav e mor e than a thresho ld quan tity. This possibi lity w ill be p articula rly im portant if you store a regul ated sub stance i n cyli nder s or b arr els or ot her c onta ine rs in a war ehou se or outs ide in a r ack. In s ome cases, you m ay have tw o vessels or sy stems that are in th e same building or room. For eac h of the se cases , you should ask y ourself:



### � Could a release from one of the containers lea d to a release from the other? For example, if a cylinder of prop ane were to rupture and burn, would the fire spread to other propane cylinders?Chapter 1 Ge neral A pplic ability 1-8



### � Could an eve nt external to the containers, such as a fire or explo sion or collaps e of col lision ( e.g., a veh icle col lides w ith sev eral sto red con tainers)
, have t he pote ntial to release the reg ulated s ubstanc e from mult iple containers?

You must dete rmine whether the re is a credible scenario that could lead to a release of a threshold quantity

.

For flam mable s, yo u shoul d consi der the distanc e betwe en ves sels. I f a fire could spread from one vessel to others or a n explosion could ruptu re multiple ve ssels, you
must count a ll of the m. F or toxic s, a rel ease fro m a si ngle v essel w ill not n ormal ly lead to a release from others unless the v essel fails catastrophically an d explodes, sending meta l fragm ents int o other vesse ls. Co -loc ated v essels c ontaini ng toxic substances, howev er, may well be involv ed in a release caused b y a fire or explosio n that occ urs from anothe r source . You should assum e such a fire or explosi on coul d take p lace in determ ining whethe r separa te ves sels cou ld be in volv ed in a single release. In additio n, a co llapse o f storag e rack s could lead to mult iple v essels breaking open

.

If vessels are separated by fire walls or barricades that will contain the blast wav es from explosions o f the substances, y ou will not need to c ount the separated v essels, but you would count any that are in the same room. You may no t dismiss the possibility of a fire sprea ding based on a n assumption tha t your fire brig ade will be able to preve nt any spread

. You should ask y ourself how far the fire would spread if the worst happens — the fire brigade is slow to arrive, the w ater supply fails, or the local fire de partmen t deci des it is safe r to let the fir e burn i tself out. If you ha ve sepa rat e vess els cont ain ing a r egul ate d sub sta nce t hat coul d be a ffe cte d by th e same accident, you sho uld count them as a single process.

P ROCESSES WITH M ULTIPLE C HEMICALS

When y ou are d eterm ining whethe r you have a cover ed proc ess, y ou shou ld not l imit your consideration to vessels that hav e the same reg ulated substance. A covered process includes any vessels that altog ether hold more than a threshold quantity of one of more reg ulated substances and that are interconnected or co- located. Therefore, if you hav e four storage or rea ctor vessels holding four different regulated substances above th eir individual thresholds and they are located close enough to be involved in a single even t, they are conside red a single process. One implicatio n of this approach is that if y ou have two v essels, each containing slightly less tha n a thresho ld quan tity o f the sa me re gulate d subst ance an d locate d a con siderab le distance apart, and y ou have other sto rage or process v essels in between with other regulated substances a bove their thresholds, the two vessels with the first substance may be considered to be part of a larger process inv olving the o ther intervening vessels and other reg ulated substances, based on co-location.

Exhibit 1-2 provides illustrations of w hat may b e defined as a process.

D O N OT A GGREGATE QUANTITIE S OF DIFF ERENT SUBSTANCES

OSHA aggr egates differe nt flam mable liquids across vesse ls in m aking thresho ld determinations. O SHA also agg regates different flam mable gases (but does notChapter 1 1-9 Ge neral A pplic ability

aggregate flammable liquids with flamm able gases). EPA aggreg ates neither. Therefore, if you hav e three co-located or connected reactor v essels each containing 5,000 pounds of a different flamm able liquid, OSHA considers that you have 15,000
poun ds of flamma ble liqu ids and a re co vere d by th e PSM stan dard

. Unde r EPA 's rule, y ou wou ld not h ave a cover ed proc ess bec ause you do n ot me et the th reshold quantit y for any o ne of th e three substan ces. O SHA, like E PA, do es not a ggre gate quantit ies for t oxics as a class (i.e., each to xic sub stance m ust m eet its o wn thre shold quantit y).



### AGGRE GATION OF SUBSTANCES

A toxic substan ce is ne ver ag greg ated wi th a dif ferent t oxic su bstance to dete rmine whethe r a thresho ld quan tity is presen t. If your process consist s of co- located vesse ls with differen t toxic substances, you must determ ine whether each substan ce exceeds its threshold qu antity.

A flam mable substan ce in on e vess el is ne ver ag greg ated wi th a dif ferent f lamm able sub stance i n another vesse l to det ermin e wheth er a thre shold q uantity is pres ent. H owev er, if a flamm able mixture m eets the criteria for NFPA -4 and con tains different regulated flam mables, it is the mixture, not the indivi dual su bstance s, that is consi dered in determ ining if a thre shold q uantity is pres ent.

1.5 THRESHOLD QUANTIT Y IN A PROCESS

The thres hold qu antity for eac h regu lated su bstance is liste d in 40 CFR § 68.130 , in Appendix A. Y ou should determ ine whether the m aximum quantity of each substance in a process is greater than the thresho ld quantity listed. If it is, y ou must comply w ith this rule for that process. Even if y ou are not covered by this rule, y ou may still be subject to other reporting req uirements, such as those under the Emer gency Planni ng an d Com munit y Rig ht to Kno w Act ( EPCRA ).

Q UANT ITY IN A V ESSEL

To determine if y ou have the thresh old quantity of a regulated substance in a vessel involved in a single process, y ou need to consider the maximu m quantity in that

vesse l at any one tim e. You do not need to consid er the v essel' s max imum capacit y if
you n ever f ill it to that lev el. Ba se you r decisi on on t he actu al ma ximum quantit y that you m ay have in the vessel. Yo ur maxim um quantity may be more than y our normal operating maximu m quantity; for example, if y ou may use a vessel for
emergency storage, the m aximum quantity should be based on the quantity that might be stored.

"At any on e time" mea ns you nee d to con sider the lar gest qua ntity t hat you eve r have in the vessel. I f you fill a tank with 50,000 pou nds and imm ediately begin using the substan ce and d epleting the con tents, y our m aximu m is 5 0,000 pounds

. If you f ill the ve ssel fou r time s a ye ar, yo ur ma ximum is still 50,000 pounds

. Throu ghput is
not con sidered becaus e the ru le is co ncerned about t he ma ximum quantit y yo u could release in a sin gle ev ent.

### EXHIBIT 1-2 PROCESS
Schematic Representation Description Interpretation

1 vessel 1 reg ulat ed su bsta nce a bov e TQ 1 process

2 or m ore con nected vesse ls

same regulated substance abov e TQ 1 process

2 or m ore con nected vesse ls different regulated substance each abov e TQ 1 process

pipelin e feedin g m ultiple vesse ls
tota l abo ve TQ 1 process

2 or more v essels co-located

same substance
tota l abo ve TQ 1 process

2 or more v essels co-located differen t substances each abov e TQ 1 process

2 vessels, located so they won’t b e involved in a single release same or different substances each abov e TQ 2 processes

2 locations with reg ulated substances each abov e TQ 1 or 2 processes depending on d istance

Flamm able 1 series of inte rconnec ted ve ssels same or different substances above TQs plus a co-located storage vessel containing flam mables 1 processChapter 1 1-11 Ge neral A pplic ability

Q UANT ITY IN A P IPELI NE

The maximum quantity in a pip eline will generally be the capacity o f the pipeline (volume). In m ost cases, pipeline quantity will be calculated and added to the interconnected vessels.

I NTERCONNECTED /C O -L OCATED V ESSELS

If your process consists of two o r more interconnected vessels, yo u must determ ine the maxim um quantity for each vessel an d the connecting pipes or hoses. The maximum for each individual vessel and pipe is added together to d etermine the maximum for the process.

If you have determ ined that you m ust consider co- located vessels as on e process, you must determ ine the maxim um quantity for each vessel an d sum up the quantities of all such vessels.

Q UANT ITY O F A S UBS TAN CE IN A M IXTURE OR S OLUT IO N

T

OXICS WIT H LISTED CONC ENTRATI ON

Four toxic substances ha ve listed concentrations in the rule: hydroch loric acid — 37 percent or greater; hy drofluoric acid — 50 percen t or greater; nitric acid — 80 percent or gr eater; a nd am monia — 20 pe rcent or greater.



### � If you have these substance s in solution and their co ncentration is less than the liste d conce ntration , you do not need to consid er them at all.



### � If you have one of these four above their liste d concentration, yo u must determ ine the weigh t of the substan ce in th e soluti on and use that to calculate the quantity p resent. If tha t quantity is g reater than the threshold, the process is covere d. For exam ple, aqueous am monia is cov ered at concentrations above 20 percent, with a thre shold quantity of 2 0,000 pounds. If the solution is 25 percent am monia, y ou would need 80, 000 pounds of the solution to meet th e threshold quantity; if the solution is 44 percen t

amm onia, y ou wou ld need 45,45 5 pound s to m eet the thresho ld quan tity (quantity of m ixture x percentage o f regulated substance = quantity of regula ted sub stance).

Note th at in a r evisio n to par t 68, E PA cha nged the con centrati on for h ydroc hloric acid to 37 perc ent or g reater (s ee App endix A ).Chapter 1 Ge neral A pplic ability 1-12



### Q S 

### & A S 

### P ROCE SS

Q. Do I have to do m y hazard rev iew, process haza rd analysis, or oth er prevention activ ity on the whole process or can I break it into separate units?

A. Once you hav e determined that y ou have a cov ered process, you can divide the c overed process
any way you wan t to impl ement th e preven tion pr ogram. If you have multipl e inte rconne cted st orage and reactor vessels in your process, y ou 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 m ay require separate m aintenance program s. You should d o what mak es sense for
your process.

Q. How far apart do sep arate vessels hav e to be to be considere d different processes?

A. There is no hard and fas t rule fo r how g reat this distanc e shoul d be be fore y ou do n ot need to consider the vessels a s part of one process. Two vessels at opp osite ends of a larg e warehouse room might hav e to be considered as o ne process if the entire w arehouse or room could be engu lfed in a fire. Tw o vess els sepa rated by the sam e distan ce out o f doors mig ht be fa r enoug h apart that a fi re affectin g one would be unlik ely to spread to the o ther. Y ou ma y wan t to con sult wit h you r local f ire department. Y ou should then use y our best professional judgm ent. Ask y ourself how mu ch of the regulated substance co uld be released if the w orst happens (you have a m ajor fire, an explosion, a natural disaster).

T OXI CS WI THOU T A LI STE D CON CEN TRA TI ON

For toxics without a listed concentration, if the con centration is less than one percent you need not c onsider the quantity in your threshold d etermination. I f the concentration in a m ixture is above one percent, you m ust calculate the weig ht of the regula ted sub stance i n the m ixture a nd use that we ight t o determ ine whe ther a threshold quantity is p resent. Howev er, if you can m easure or estimate (an d document) that the partial pressure of the reg ulated substance in the m ixture is less than 10 mm Hg, y ou do not need to consider the mixture

. Note that the partial pressure rule does not ap ply to toluene diisoc yanate (2- 4, 2-6, or mixed isom ers) or ole um.

EPA treats toxic m ixtures differently from OSHA. Un der the OSHA P SM standard, the enti re weig ht of th e mix ture is c ounted toward the thre shold q uantity ; under part 68, only the w eight of the toxic su bstance is counted.

F LAMMABLES

Flamm able m ixtures are sub ject to th e rule o nly if there is a reg ulated s ubstanc e in the mixtu re ab ove on e per cent and t he en tir e mixt ure me ets the N FPA-4 c rit eri a. If the m ixture m eets bot h of the se crite ria, y ou mu st use t he weig ht of th e entire mixtu re (not just the l isted su bstance ) to det ermin e if yo u excee d the th reshold quantity. The NFP A-4 definition is as follows:Chapter 1 1-13 Ge neral A pplic ability

"Materials that will rapidly or completely v aporize at atm ospheric pressure and

norma l amb ient tem perature or that are rea dily d ispersed in air, and tha t will b urn readily. This deg ree usually includes:

Flammab le gases

Flamm able cry ogeni c mat erials

Any liquid or g aseous material that is liquid while under press ure 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 exp osed to air."

F

LAMM ABLES NOT COVERED BY P ART 68 (§68.115)

The following flam mables are not co nsidered part of a "stationary source" and, therefore, any reg ulated substances contained in them need n ot be included in y our calculations of threshold quan tities:



### � Naturally occurring hydrocarbon reserv oirs; and



### � Naturally occurring hydrocarbon transp ortation subject to oversig ht or regulation under 49 CFR parts 192, 1 93, or 195, or a state natural gas or hazard ous liqu id prog ram fo r which the sta te has i n effect a certif ication to DOT under 49 U.S .C. 60105.

"Naturally occurring hydrocarbon reserv oirs" include oil and g as fields, where the hydrocarbons occur in nature and from which they are pumped; they do not include natural formations, such as salt dom es, where hydro carbons are stored after they have b een pro duced o r proces sed. Tra nsporta tion sub ject to DO T and/or state oversight or reg ulation refers to transportation in pipelines and liquefied natural gas facilities.

You do not need to consider the following flammable substances when y ou determine the applica bility of the rule:



### � Gasoline, when in d istribution or related storag e for use as fuel for intern al combustion eng ines;



### � Naturally occurring hydrocarbon m ixtures prior to entry in to a petroleum refining process unit (N AICS co de 32411) or a natural gas processing plant (NAICS code 211112). N aturally occurring hydrocarbon m ixtures include
any o f the fo llowing :



### � Condensate - hydrocarbon liquid separated from n atural gas that conde nses because of chan ges in temp erature, pressur e, or b oth, an d that r emain s liquid at stand ard con ditions;



### � Crude o il - a ny na turally occurri ng, u nrefined petrole um li quid;Chapter 1 Ge neral A pplic ability 1-14



### � Field gas - gas extracted from a production well befo re the gas enters a natural gas processing plant (any processin g site engag ed in the extraction of natural gas liquids from field gas, fractionation of mixed natura l gas liquids to natural gas produ cts, or both); and



### � Produced water - water extracted from the earth from a n oil or natural gas production well, or that is separated from o il or natural gas after e xtraction.

E

XCLUSI ON FOR FLAMMABLE SUBSTANCE S USED AS F UEL OR HELD FOR SAL E AS
FUEL AT RETAIL FACILITI ES (§68.126)

A flamm able substance listed in Tables 3 and 4 o f §68.130 is excluded from coverage when the substance is used as fuel at the source o r held for sale as a fuel at a retail facility. Retail facilities include any station ary source where more than one half of the incom e (from fuel sales) is obtained from direct sales to end users or at which more tha n one-half of the fuel sold, by volume, is sold through a cylinder exch ange progr am.

E XCLUSIONS (§68.115)

The rule has a numbe r of a ddit iona l exc lus ions that allo w you t o igno re ce rta in it ems that con tain a re gulate d subst ance wh en yo u determ ine whe ther a th reshold quantit y is prese nt. No te that t hese sa me ex clusion s apply to EPC RA sec tion 31 3; you should be familiar with the m if you are subject to that provision.

M

ANUFACTURED I TEMS & A RTICLES (§68.115( B

)(3))

You do not need to include in your threshold calculations any manufactured item defined at §68. 3 (as de fined un der 29 C FR 191 0.1200 (b)) tha t:



### � Is form ed to a specific shape o r design during manufacture,



### � Has end use functions dependent in whole o r in part upon the shap e or design during end use, and



### � Does not release or othe rwise result in exposure to a regulated substan ce under normal co nditions of processing and use.

C

ERTAIN U SES OF R EGULATED S UBSTANCES (§68.115( B

)(4))

You also do not ne ed to include regula ted substances in y our calculation when in use for the following p urposes:



### � Use as a structural com ponent of the stationary source;



### � Use of products for rou tine janitorial maintenance;



### � Use b y emplo yees of fo ods, drugs , cos meti cs, o r oth er pe rso nal items containing the reg ulated substances; andChapter 1 1-15 Ge neral A pplic ability



### � Use of regulated s ubstances present in process water or non- contact cooling water as drawn from the environm ent or municipal s ources, or use of regulated substances p resent in air used either as compressed air or as part of combustion.

A CTIV ITI ES IN L ABORATORIES (§68.115( B

)(5))

If a regula ted sub stance i s man ufacture d, proc essed, or used in a lab oratory at a stationary source und er the supervision o f a technically qualified individual (as defined by § 72 0.3 (ee) of 40 CF R), the quantity of the substance need n ot be considered in determ ining whether a th reshold quantity is p resent. This exclusion does not extend to:



### � Specialty chem ical production;



### � Manufacture, processing, or use of substances in pilot plant scale operations; and



### � Activi ties c onduct ed outs ide the labora tory.

1.6 STAT IONARY SOURCE

The rule applies to "stat ionary source s" and e ach stat ionary source with o ne or m ore covered processes m ust file an RMP that includ es all covered proces ses.

S IMPLE S OURCES

For m ost faci lities co vered by th is rule, determ ining what co nstitute s a “sta tionary source” is simple. If yo u own or lease a p roperty, you r processes are contained within the property boundary, and no other compa nies operate on the prop erty, then your stationary source is defined by the property bou ndary and cov ers any process within the boundaries that has more than a threshold quantity of a regulated substance. You m ust comply with the rule and file a single RMP for all covered
processes.

M ULTIPLE O PERATI ONS O WN ED B Y A S INGLE C OMPANY

If the property is owned or leased by your co mpany, but several separate o perating divisions of the com pany have processes at the site, the d ivisions’ processes m ay be conside red a si ngle s tationar y sou rce beca use they are con trolled by a s ingle
comp any. Two fac tors wil l determ ine if th e proce sses are to be c onsider ed a sin gle source: Are the processes located on one or m ore contiguous prop erties? Are all of the operations in the sam e industrial group?

If y our com pany does ha ve m ultiple operatio ns that are on t he sam e prope rty an d are in the same indu strial group, each o perating division may dev elop its prevention
progr am se parately for its cover ed proc esses, but yo u mus t file a s ingle RMP for all covered processes at the site. You shou ld note that this is different fro m the requirements for filing under CAA Title V, and EPCRA section 313 (the annualChapter 1 Ge neral A pplic ability 1-16

toxic release inventory ), where each div ision could file separately if your com pany chose to do so.

O THER S OURCES

There are situations where two or more separate companies occup y the same site. The simplest of these c ases is if multiple co mpanies lease land at a site (e.g., an industrial park). Ea ch company that has covered processes must file an RMP that include s inform ation on its own cover ed proc esses at the site

. You are resp onsible for filing an RMP fo r any operations tha t you own or operate.

Anothe r possib ility i s that o ne com pany owns th e land a nd oper ates the re while leasing part of the site to a second com pany. I f both companies have cove red
process es, eac h is con sidered a separ ate stati onary source and m ust file separate RMPs even if they have contractual relatio nships, such as supply ing product to each other or sharing em ergency respon se functions.

If you and another com pany jointly own a site, but have separate operations at the site, you each m ust file separate RMPs for y our covered process es. Ownership of the land is not relev ant; a stationary source consists of covered processes located on the same property and controlled by the same person (or persons under com mon control).

J OINT V ENTURES

You and another com pany may jointly own cov ered processes. I n this case, the leg al entity you h ave established to o perate these processes should file the RMP. I f you consider this entity a subsidiary, yo u should be listed as th e parent compan y in the RMP.

M ULTIPLE L OCATIONS

If y ou hav e mul tiple op erations in the s ame a rea, bu t they are not on phy sically
connect ed land , you must consid er them separat e statio nary s ources and file separat e RMPs fo r each, even if the si tes are c onnecte d by p ipelines that m ove ch emica ls

amon g the sites. Reme mber, the rul e applie s to cov ered pro cesses a t a sing le location.

Exhibit 1-3 provides exam ples of stationary sou rce decisions.

1.7 WHEN YOU MUST COMPLY

June 21, 1999 was the original com pliance date for facilities that had covered processes as of that date. If the first tim e you hav e a covered proce ss is after June 21, 1999, or you bring a new process on line after th at date, you m ust com ply w ith part 68 no l ater tha n the da te on w hich y ou first have more than a t hreshol d quant ity of a regulated substance in a process. By that time y ou must hav e developed and implemented all of the elemen ts of the rule that apply to each of you r covered processes, and yo u must subm it an RMP to EPA in the specified form and manner (see Ch apter 9 for deta iled inf ormat ion on subm itting your RMP).Chapter 1 1-17 Ge neral A pplic ability



### Q S 

### & A S 

### S TATI ONARY 

### S OURCE

Q. I opera te a single cov ered process on a site o wned by a larg e company

. I m anufacture a regulated substance tha t I pipe to th e other company for use in its processes. At what point do the piping and substan ce become part of the other com pany’s stationary source?

A. The ans wer wil l vary

. The co mpan y that owns a nd ma intains the pipi ng sh ould pr obably consider it part of its stationary source. I f, however, th ere is a point (e.g ., a valv e or meter) whe re the receiving com pany is considered to take ownership of the substance, then you may decide to divide the pipi ng an d its co ntents a t that p oint.

Q. The def inition of proc ess wou ld seem to say that m y proc ess is p art of th e larg er com pany’ s process becaus e they are inte rconnec ted. Wh y can’ t the lar ger co mpan y just in clude m y proc ess in its RMP?

A. Your process is no t part of the larger company’s statio nary source because it does not m eet the statutory criteria for stationary sources. Althoug h the process m ay be part of the same industrial
group and is at the s ame l ocation , it is n ot unde r contro l of the same person

. Theref ore, th e proce ss is a separate stationary so urce and must have a separate R MP.EXHIBIT 1-3 - STATIONARY SOURCEChapter 1 1-19 Ge neral A pplic ability



### Q S 

### & A S 

### C OMPLIANCE 

### D ATES

Q. What happens if I bring a new covered process on line (e.g., insta ll a second storage tank) after submitting m y original R MP?

A. For a new co vered process added after the initial comp liance date, you must be in com pliance on the date you first ha ve a regulated substance above the threshold quantity. There is no grace period. You must dev elop and implem ent all the applicable rule elem ents and update y our RMP before y our process contains m ore than a threshold qua ntity of a regu lated substance.

Q. What if EPA lists a new substance?

A. You w ill hav e three years from the date on whi ch the n ew listi ng is effectiv e to com e into compliance for any process that is cov ered because EPA h as listed a new substanc e.

Q. What if I ch ange a process by adding new re actor vessels, but d o not change the substances?

A. Because increasing the number o f reactor vessels is usu ally a major chan ge to your process, you will have six m onths to update y our RMP to reflect chang es in your prev ention program elements and report any other cha nges.

Q. What if the qua ntity in the p rocess f luctuate s? I may not hav e a thre shold q uantity now, but I will inter mittent ly excee d the th resho ld quan tity.

A. You do not nee d to com ply w ith the rule and file an RMP unl ess yo u hav e mor e than t hreshol d quantity in a proces s; however, on ce you hav e more than threshold quantity in a process, you m ust be in com pliance imm ediately

. In this sit uation, with fl uctuatin g qua ntities, it ma y be p rudent t o file
now, s o you will be in com pliance when y our qua ntity exceeds the thr eshold. You m ay als o want to consider a “predictive filing” (see Chapter 9 for more inform ation on predictive filing ).

## CHA PTER 2: A PPLICA BILITY OF PROGRA M LEVELS

2.1 WHA T A RE PROGRA M LEVELS?

Once y ou hav e determ ined tha t you have o ne or m ore pro cesses s ubject to this ru le (see Ch apter 1) , you need to identif y wha t action s you must take to com ply. The rule defines three P rogram level s based on pro cesses’ relativ e poten tial for public i mpac ts and the level of effo rt neede d to pre vent a ccident s. For each P rogram level , the ru le defines requirements that reflect the level of risk and effort associated with the
process es at th at lev el. The Progr am le vels a re as fo llows:

Program 1: Proces ses whi ch wou ld not a ffect th e public in the c ase of a
worst- case rel ease (in the lan guag e of Par t 68, p rocesse s “with no pub lic receptors within the distance to an endpoint from a worst-case release”) and with no accide nts wit h speci fic of fsite conseq uences within the pas t five years are eligible for Program 1, which im poses limited haz ard assessment requirements and m inimal preven tion and emerg ency response requ irements.

Program 2: Proc ess es no t eli gibl e for Progr am 1 or subj ect to Pr ogra m 3 are placed in Prog ram 2, which imposes stream lined prevention prog ram requirements, as w ell as additional hazard assessment, m anagement, and
emergency response requirem ents.

Program 3: Proces ses not eligib le for P rogram 1 and e ither su bject to OSHA's PSM standard under federal or state OSHA prog rams or classified in one of ten specified N orth American I ndustrial Classification Sy stem (NAICS) codes are placed in Prog ram 3, which imposes OSH A’s PSM standar d as the preve ntion p rogram as well as addi tional h azard assessm ent, managem ent, and emerg ency response requ irements.

If you assign a process to Program 2or 3 when it m ight qualify for Program 1 , the implementing agency m ay enforce all the req uirements of the h igher program levels. If, howev er, you are already in compliance w ith the prevention elem ents of Program 2 or Program 3, you m ay want to assig n it to Program 2 or 3 to inform the

commun ity of your prevention efforts.

See Exh ibit 2- 1 for a diagra m of t he deci sion rul es on d eterm ining Progr am le vel.

K EY P OI NTS TO R EMEM BER

In determi ning pro gram level (s) fo r your pr ocess (es), keep in mind the fol lowing:

(1) Each process is assig ned to a program lev el, which indicates the risk
managem ent measures neces sary to com ply with this reg ulation for that
process , not th e facilit y as a whole. The elig ibility of one process for a program lev el does not influence the eligibility of other covered processes for other program levels.

## EXHIB IT 2- 1
EVA LUA TE PROGRA M LEVELS FOR COVERED PROCESSChapter 2 2-3 Ap plicab ility of Pro gram Leve ls

(2) Any pr ocess th at meets the crit eria for Pr ogram 1 can be assign ed to Program 1 , even if it is subje ct to OSHA PSM or is in one of th e NAICS codes listed for Prog ram 3.

(3) Program 2 is the d efault pr ogram le vel. There are no "standard criteria" for Program 2. Any process that does not m eet the applicability criteria fo r either Program s 1 or 3 is subject to the req uirements for Prog ram 2.

(4) Only one Program level can a pply to a process. If a proce ss consists of multiple production or operating units or storage vessels, the highest Program lev el that applies to any segment of the process applies to all parts.



### Q & A P ROCESS AND 

### P ROG RAM 

### L EVEL

Q. My p rocess i ncludes a series of inte rconnec ted unit s, as w ell as se veral storag e vess els that are co-located. Several sections of th e process could qualify for Program 1. Can I divide m y process into sections for the purpos e of assigning Program levels?

A. No, y ou cann ot subd ivide a proce ss for th is purpo se. The highe st Prog ram le vel th at appli es to any section of the process is the Prog ram level for the whole process. If the entire pro cess is not eligible for Prog ram 1, then th e entire process m ust be assigned to Program 2or Program 3.

2.2 PROGRA M 1

W HAT AR E THE E LIGIBILITY R EQUIRE MENTS ?

Your pr ocess is eligib le for P rogram 1 if:

(1) The re ar e no “ publ ic re cept ors ” wit hin a “dis tan ce to an en dpoi nt fr om a worst- case rel ease” (s ee belo w expla nation o f these key terms );

(2) The proc ess has had no release of a reg ulated s ubstanc e in the past fiv e year s where exposure to the substance, its reaction produ cts, overpressures gener ated by explos ion inv olving the sub stance, or radi ant hea t from a fire involving the substance resulted in one or more o ffsite deaths, injuries, or
respons e or res toration activ ities for exposu re of an envir onme ntal rec eptor; and

(3) You have coo rdinated your em ergency respon se activities with the lo cal responders. (This requirem ent applies to any covered process, re gardless of program lev el.)Chapter 2 Ap plicab ility of Pro gram Leve ls 2-4

W HAT I S A P UBLIC R ECE PTOR ?

The rule (§ 68.3) defines public as "any person except an employ ee or contractor of the stat ionary source ." Con sequent ly, em ploye es of ot her faci lities th at ma y shar e your site are conside red mem bers of the public ev en if they share the same phy sical location

. Bein g "the public, " howev er, is n ot the s ame a s being a publi c recept or.

Public receptors include “offsite residences, institutions (e.g., sc hools and hospitals), industrial, com mercial, and office buildings, park s, or recreational areas inhabit ed or oc cupied by the public at any time withou t restric tion by the sta tionary source where m embers of the pu blic could be exposed to toxic concentrations, radiant heat, or ov erpressure, as a result of a n accidental release.” Offsite means areas be yond your p roperty bounda ry and "areas w ithin th e prope rty bo undary to which the public has ro utine and unrestricted access during or outside b usiness hours."

The first step in identifying public receptors is determ ining what is “offsite. ” For
most facilitie s, that determ ination will be straig htforwa rd. I f you restrict access t o all of you r prope rty all of the t ime, “offsite ” is any thing beyon d you r prope rty boundaries. Ways of restricting access includ e fully fencing the property, placing security guards at a reception area or using ID badg es to permit entry

. If you do not restrict access to a section of your pro perty and the pub lic has routine and unrestricted access to it during or after busine ss hours, that section w ould be “offsite.” For exam ple, if your operatio ns are fenced but the p ublic has unrestricted access to your park ing lot during or after business hours, the parking lo t is “offsite.” In the case o f facilities such as hospitals, schools, and hotels that shelter mem bers of the public as part of their function or business, the parts of the facility that are used to shelter the public wou ld be “offsite.”

Not all areas of fsite are potenti al publi c recept ors. The point o f identi fying public receptors is to locate those p laces where there are lik ely to be, at least some of the time, mem bers of the pub lic who se healt h could be harm ed by short- term e xposure to an accid ental re lease at your site. Th e basic test for identify ing a public r eceptor is thus whether an area is a place where it is reason able to expect that m embers of the public will routinely g ather at least some of the time.

The defin ition of “public recepto r” itself specifi es the t ypes o f areas w here m embe rs of the public ma y routinely g ather at least some of the time: residen ces, institutions such as hospitals and sch ools, buildings in general, parks and recreational areas. There should be little difficulty in identifying res idences, institutions and bu sinesses as such , and v irtually any r esidenc e, insti tution a nd busi ness wi ll quali fy as a public receptor, even w hen the property is used only seasona lly (as in a v acation home). Notably, a residen ce includes its yard, if any, and an institution or business includ es its gro unds to the ext ent that empl oyees or othe r mem bers of the pub lic are l ikely to routinely gather there at least some of the time for bu siness or other purposes (s ee discuss ion of r ecreatio nal area s below ). The o nly ci rcums tances t hat wou ld justify not considering such a property a pu blic receptor would be w here your facility owns or contr ols the propert y and restrict s access to it, o r no m embe r of the public inhabit sChapter 2 2-5 Ap plicab ility of Pro gram Leve ls

or occupies it at any time. Where a h ospital, school, hotel or other entity that provid es publ ic shelt er is its elf subjec t to the part 68 rule, i t will b e its ow n publi c receptor except for those area s where mem bers of the public are no t allowed to go at any time.

Buildin gs oth er than residen ces, in stitutio ns or bu sinesse s are als o high ly lik ely to qualify as pub lic rece ptors si nce the functio n of m ost buil dings is at le ast in p art to shelter people. Accor dingly , toll b ooth pl azas, transit stations , and a irport te rmina ls would q ualify as pub lic rece ptors. For a b uilding not to qualify as a pu blic rec eptor, one of t he cir cumstan ces ment ioned above wou ld have t o apply.

Every desig nated p ark or recreat ional ar ea, or a t least s ome p ortion t hereof, is apt to be a public gatherin g place by virtue of facilities m ade available to the public (e.g., visitors’ center, play ground, g olf course, camp ing or picnic area, marina or ball field) or attributes that mem bers of the public routinely seek to use (e. g., beach). I t does not matter whether use of such facilities is seasonal; routine use for at least part of the
year would qu alify t he area as a pub lic rece ptor.

At the same tim e, some portion of a designated park or recreational area may no t be a public recepto r. For instanc e, a lar ge sta te or na tional p ark m ay inc lude rel ativel y inaccessible tracts of land that do not contain public fac ilities or receive routine u se. Occasional hiking , camping or hunting in su ch areas would not q ualify the areas as public receptors.

An area need n ot be de signat ed a rec reationa l area to be one in fact. If a n area i s routinely used for recre ational purposes, ev en if only seasonally , it is a recreational area for purposes of the part 68 rule. For ex ample, a m arina may not bill itself as a “recreat ional ar ea,” bu t if a m arina ho uses rec reationa l boats, it qual ifies as a public recepto r. Fur ther, if your facility or a ne ighbo ring p roperty owner allows the pub lic to make ro utine recreational use of som e portion of land (e.g ., a ball field or fishing pond), that po rtion of land w ould qu alify a s a pub lic rece ptor.

Roads a nd park ing lo ts are n ot inclu ded as s uch in t he defin ition of “public recepto r.” Nei ther are places where p eople ty pically gathe r; instea d they are use d to travel from one pla ce to an other or to park a veh icle wh ile atten ding a n activ ity elsewhere. Howev er, if a parking lot is predictably an d routinely used as a place of busines s (e.g ., a fa rmer’ s mar ket) o r for a recreati onal pu rpose (e .g., a coun ty fair ), it would qualify as a public receptor.

In g eneral, farm land wo uld not be con sidered a publi c recept or. Ho wever , if farm land, or a portion thereo f, is predictably and routinely occupied by farm w orkers or other mem bers of public, ev en if only on a seasonal basis, that portio n of the land would be a public rec eptor.

If you are in doubt about w hether to consider certain area s around your fac ility as public r eceptor s, yo u shoul d consu lt with the rele vant l ocal off icials an d land o wners and your im plementing a gency for g uidance.Chapter 2 Ap plicab ility of Pro gram Leve ls 2-6



### Q S 

### & A S 

### P UBLI C 

### R ECEPT ORS

Q. My pr ocesses are fen ced, bu t my offices and pa rking lot for custom ers are n ot restri cted. W hat is conside red offs ite? Wha t is con sidered a publi c recept or?

A. The unr estricte d areas would b e consid ered off site. H owev er, they would not be p ublic re ceptors because you are responsible for the safety of those who wo rk in or visit your offices and b ecause parking lots are not generally public receptors.

Q. What is considered a rec reational area?

A. Recreational areas wo uld include land that is d esigned, constructed, designated, or u sed for recreational activities. E xamples are nation al, state, county, or city park s, other outdoor recreationa l areas such as golf courses or swimm ing pools and b odies of waters (oceans, lakes, rivers, and
stream s) when used b y the public f or fishi ng, s wimm ing, or boati ng. P ublic an d priv ate area s that a re predictably used for hunting, fishing , bird watching, bike riding, hiking, o r camping or other recreati onal us e also w ould be consid ered rec reationa l areas. EPA e ncourag es you to cons ult with land owners, local officials, and the comm unity to reach an agreement on an area’s status; yo ur local
emergency planning com mittee (LEPC) c an help you w ith these consultations. E PA recogniz es that some judgm ent is involved in determining whether an area shou ld be considered a recreation al area.

Q. Does public receptor cover only b uildings on a prop erty or the entire prop erty? If the owner of the land next to my site res tricts ac cess to the land , is it s till a pu blic rec eptor?

A. Public recept ors ar e not li mited to buildi ngs. For e xample, if ther e are ho uses ne ar your p roper ty, both th e house s and th eir ya rds are conside red pub lic rece ptors be cause it is lik ely th at resid ents wi ll be pres ent in o ne or th e other at least some of the t ime, and, in fact, p eople a re like ly to b e in m ore danger if they are outside when a release occurred. The ability of others to restrict access to an area does no t chang e its sta tus as a public recepto r. You need to consid er whet her that land is gener ally unoccupied. I f the land is undev eloped or rarely has anyone on it, it is not a public receptor. If yo u are not sure of the land ’s use o f occup ancy, you s hould t alk w ith the landow ner and the com munit y about it s status

. Beca use it is the lan downer and m embe rs of th e local comm unity who are likely to be affected by y our decision, you should involv e them in the d ecision is you hav e doubts.

W HAT I S A DI STANCE TO AN ENDPOINT FROM A WORST - CASE REL EASE ?

In broad term s, the distance to an e ndpoint is the distance a toxic vapor cloud, fire, or explosion from an accidental release will travel before dissipating to the point that serious injuries from short- term exposures w ill no longer occur. The rule establishes "endpoi nts" for each re gulate d subst ance an d define s the ci rcums tances o f a worst-case release scenario (e.g., re lease type, rate and duration, weather) (see Chapter 4 or the Risk Management Progra m Guidance for O ffsite Consequence Analysi s for m ore info rmatio n). You will h ave to define a worst -cas e releas e (usua lly the loss of the total conten ts of your larg est vessel) for each P rogram 1 process and determine the distanc e to the endpoint for tha t release. (EPA has developedChapter 2 2-7 Ap plicab ility of Pro gram Leve ls

guidance for defining and analyz ing worst- case releases; you m ay also conduct modeling o n your own to determine the dista nce to the endpoint for worst-case releases.) Beyond that endpoint, the effects on people are not con sidered to be
severe enoug h to merit the ne ed for additional action un der this rule.

To define the area of potential impact from the worst-cas e release, draw a circle o n a map, u sin g the p roce ss as the c ent er an d the dist ance to th e end poin t as t he ra dius

. If there are public receptors w ithin that area, your process is not eligible for Program 1.



### Q & A D ETERMI NING 

### D ISTANCES

Q. Our distance to the endpoint for the worst- case release is 0.3 m iles. The nearest public recepto r is 0.32 miles a way. What tools are available to docu ment that the pu blic receptor is beyon d the distance to the endpoint s o we can qualify for Program 1?

A. The resu lts of an y air d ispersio n mod el (from EPA’s guida nce doc umen ts or ot her m odels) a re not precise predictions. They represent an estima te, but the actual distances to the endpoint could b e closer t o or far ther fro m the point o f releas e. I f your distanc e to the endpoi nt and d istance to a pub lic recepto r are so close t hat yo u canno t docum ent, us ing a USGS map, that th e two p oints ar e differ ent, it woul d be ad visabl e to com ply w ith the highe r Prog ram le vel. The mo st detai led m aps av ailable from the US Geolog ical Sur vey (scale o f 1:24, 000) ar e accura te enou gh to map t he dista nces you cite and document that the two points (wh ich are about 100 feet a part) differ. GPS sy stems may also allow you to differe ntiate these points.

A CCID ENT H ISTORY

To be eligible for Prog ram 1, no rele ase of the regulated substance from the process can have resulted in one or more offsite deaths, injuries, or response or restoration activities at an env ironmental receptor d uring the five years prior to subm ission of your RMP. A release of the regula ted substance from another process has no bearing on whether the first proces s is eligible for Prog ram 1.

W

HAT IS AN I NJURY ?

An injury is defined as "any effect on a hu man that results eithe r from direct exposure to toxic concen trations; radiant heat; or ov erpressures from accid ental releases or from the direct consequences of a vapor cloud explo sion (such as flying glass, debris, and other projectiles) from an accidental release." The effect m ust "require medical treatm ent or hospitalization." This definition is taken fro m the OSHA regulatio ns for keeping employee injury and illness logs and should be famili ar to m ost em ploye rs. Med ical trea tment is furth er defin ed as “t reatm ent, other than first aid, adm inistered by a phy sician or registered profes sional personnel under s tanding orders from a phy sician. ” The de finition of me dical tre atmen t will likely capture m ost instances of hospitaliz ation. Howev er, if someone goes to the hospital following direc t exposure to a release an d is kept ov ernight for observ ation (even if no specific injury or illness is found), that would qualify as hospitalization and so wo uld be c onsid ered an inju ry.Chapter 2 Ap plicab ility of Pro gram Leve ls 2-8

W

HAT IS AN E NVIRONMENTAL R ECEPTOR ?

The environmen tal receptors you nee d to consider are lim ited to natural areas such a s nationa l or stat e park s, fores ts, or m onum ents; of ficially desig nated w ildlife sanctuaries, preserves, refuges, or areas; an d Federal wilderness areas. All of these areas can be identified on local U.S. Geolog ical Survey m aps.

W

HAT A RE R ESTORATI ON AND R ESPONSE A CTIV ITI ES ?

The type of restoration an d response activity conducted to address th e impact of an accidental release will depend on the type of release (volatilized sp ill, vapor cloud, fire, or explosion), but may includ e such activities as:



### � Collection and disposal o f dead animals an d contaminated p lant life;



### � Collect ion, tre atmen t, and disposa l of soi l;



### � Shutoff of drin king water;



### � Replacement of damaged vegetation; or



### � Isolation of a natural area due to contam ination associated with an accidental release.



### Q & A E NVIRONM ENTAL 

### R ECEPT ORS

Q. Do environmental receptors include areas th at are not Federa l Class I areas under the CAA?

A. Yes. The list of env ironm ental re ceptors in Part 68 incl udes ar eas in a ddition to thos e that q ualify as Federal Class I areas under CAA section 162. Under Part 68, national park s, monum ents, wilderness areas, and fore sts are environm ental receptors regardless of size. State pa rks, mon uments, and forests are also env ironmental receptors.

D OCUMEN TI NG P RO GR A M 1 E LIGI BIL ITY

For every P rogram 1 process at your facility , you m ust keep records d ocumenting the eligibility of the p rocess for Program 1. For each Pro gram 1 p rocess, your record s shoul d inclu de the f ollowi ng:



### � A description of the w orst-case release sce nario, which m ust specify the vessel or pipeline and substance selected for w orst-case analy sis, assumptions and parameters used, and the rationale for selection. Assumpti ons may inc lude us e of any ad ministr ative co ntrol s and any p assive mitigation that would limit the q uantity that could be released;Chapter 2 2-9 Ap plicab ility of Pro gram Leve ls



### � Documentation o f the estimated qua ntity of the worst- case release, release rate, and duration of releas e;



### � The methodolo gy u sed to d eterm ine dist ance to endpoi nts;



### � Data used to determ ine that no public receptor would be affected; and



### � Informa tion on your coo rdination with public respon ders.

2.3 QUICK RUL ES FOR DETERM INING PROGRAM 1 ELIG IBILI TY

You g enerally will no t be abl e to pre dict wit h certai nty th at the w orst- case sce nario for a particular process will m eet the criteria for Progra m 1. Proce sses containing certain substances, howev er, may be more lik ely than others to be eligible for Progr am 1, and pro cesses c ontaini ng cer tain oth er subst ances m ay be very unlik ely to be eligible for Pro gram 1 b ecause of the toxicity and physical prope rties of the substances. The inform ation presented below m ay be useful in id entifying process es that may b e eligible for Prog ram 1.

T OXIC G ASES

If you have a process co ntaining more than a threshold quan tity of any reg ulated toxic gas that is no t liquefied by refrig eration alone (i.e., y ou hold it as a g as or liquefied under pressure), the distance to the endpoint estimated for a w orst-case release of the t oxic g as will gener ally b e seve ral mi les. A s a resu lt, the distanc e to endpoint is unlikely to be less than the d istance to public receptors, unless the process is very remote. I n some cases, however, toxic g ases in processes in enclos ed
areas may be eligible for Prog ram 1.

R EFRIGERA TED T OXIC G ASES

If you have a process co ntaining anhy drous amm onia liquefied by refrig eration alone, and you r worst-case relea se would take p lace into a diked a rea, the chances
are go od that the proc ess m ay be eligib le for P rogram 1, unl ess ther e are pu blic recepto rs ver y clos e to the proces s. Ev en if y ou hav e man y tim es the t hreshol d quantity of am monia, the proc ess may s till be eligible for Prog ram 1.

If you have a process co ntaining ethylen e oxide, anhyd rous hydroge n fluoride, or methyl chlorid e liquefied by refrig eration alone, and the re lease would take place into a diked area, the process may be eligible for Prog ram 1, depend ing on the siz e of the dik ed area, the qua ntity of the r egula ted sub stance, and the locatio n of pu blic receptors.

The wors t-cas e analy sis for a proces s contai ning c hlorine liquefi ed by refrig eration is unlikely to sh ow eligibility fo r Program 1, unless your site is extremely remote from the public or the release w ould occur within an e nclosure.Chapter 2 Ap plicab ility of Pro gram Leve ls 2-10



### Q S 

### & A S 

### A CCIDENT 

### H IST ORY

Q. What is the relationship betwee n the accident history criteria for Program 1 and the five- year accident history? I f my proc ess is eligible for Prog ram 1, do I still need to do a fiv e-year ac cident histo ry?

A. The fiv e-y ear acci dent his tory i s an inf ormat ion coll ection r equirem ent that is desi gned to provide data on a ll serious accidents invo lving release of a regulated substance from a cov ered
process.

In contra st, the Program 1 ac ciden t hist ory crit eria f ocus on accide nts cau sing offsite harm of the
most serious kind: death o r injury of pers ons or s ignifi cant ha rm to a publi c recept or. On site effects, shelterings- in-place, and evacuations that hav e occurred must be reported in the fiv e-year acciden t histor y, bu t they are not consid ered in determ ining Progr am 1 eligib ility. Therefo re, it is possible for process to be eligible for Prog ram 1 and still h ave experienced a release that must be reported in the accident histo ry for the source.

Q. A proc ess with more than a thresho ld quan tity o f a reg ulated s ubstanc e had an acciden t with offsite consequences three y ears ago. After the accident, we altered the process to reduce the quantit y stor ed on s ite, alt hough the qua ntity still exc eeds the thresho ld quan tity. Now th e worst

case release scenario indicates th at there are no public recep tors within the distance to an endpoint. Can this process qualify for P rogram 1?

A. No, the process cannot qualify for P rogram 1 until five years have passed since any accident with consequences that d isqualify a process for Program 1

.

T OXIC L IQUIDS

The distance to an endpoint for a worst-cas e release involv ing toxic liquids k ept under ambient co nditions may be smaller than the distance to public recep tors in a numb er of ca ses. I f public recepto rs are n ot foun d very close t o the pr ocess (w ithin 1⁄2 mile), the proc ess may b e eligible for Prog ram 1. Ho wever, sm all-sized facilities are highly un likely to m eet to be eligible for Program 1 if they are in a developed

area. Remotely lo cated facil ities or proc esses found ne ar the center of large (acreage) sites are m ore likely to b e eligible.

Substances that are potential candidates to be in proce sses that are eligible for Program 1 are noted below. Generally, processes that contain toxic liquids at elevat ed tem perature s, inclu ding t he toxic liquids listed b elow, w ould be less lik ely to be el igible for Pro gram 1 than those at ambi ent tem perature , and p rocesse s in diked areas are m ore likely to b e eligible for Prog ram 1 than thos e in undiked areas

. For processes containing toluene diisocyanate (including toluene 2, 4-diisocya nate, toluene 2,6- diisocy anate, and uns pecified isom ers) or e thylen e diam ine, th e worst

­Chapter 2 2-11 Ap plicab ility of Pro gram Leve ls

case analysis of a s pill of more than a threshold quantity into an undiked area under ambient conditions is likely to dem onstrate eligibility for Program 1

. If the a rea of the spill is diked, even processes con taining very large quantities of the se substances
may be elig ible for Prog ram 1

. In additio n, proc esses co ntainin g the followi ng tox ic liquids under a mbien t condit ions are likely to be e ligibl e for Pr ogram 1 if a s pill would take place in a diked area an d public receptors are not close to the process:



### � Chloro form 

### � Cyclohexylam ine 

### � Hydrazine 

### � Isob utyron itrile 

### � Isop ropyl chlorof ormat e 

### � Oleum 

### � Propylene oxide 

### � Titanium tetrachloride 

### � Vinyl acetate mon omer

W ATER SOLUTI ONS OF TOXIC SUBSTANCES

The list o f regu lated su bstance s includ es sev eral com mon w ater sol utions o f toxic substances. Processes c ontaining such solu tions at ambient tem peratures may be eligible for Prog ram 1 (dependin g in som e cases on the concentratio n of the solution), if spills would b e contained in dike d areas and public recepto rs are not located close to the process (within 1⁄2 mile). As noted abov e, small- sized facilities in developed areas are highly un likely to be e ligible for Progra m 1; rem otely located facilitie s or pro cesses f ound ne ar the c enter of large (acreag e) sites are m ore lik ely to be eligible.

Processes containing the following water solutions under am bient conditions m ay be eligib le for P rogram 1, ass uming diked areas th at woul d conta in the s pill:



### � Ammo nia in solution 

### � Formaldehy de (comm ercial concentrations) 

### � Hydro fluoric acid (co ncentra tion 50 to 70 p ercent) 

### � Nitric acid (comm ercial concentrations) 

### � Oleum

F LAMMABLE S UBSTANCES

Many p rocesse s contai ning r egula ted flam mable substan ces are likely to be e ligibl e for Program 1, unless there are pu blic receptors within a v ery short distance. If yo u have a pro cess co ntain ing up to a bout 20 ,000 pou nds (tw ice th e thre shold quanti ty) of a reg ulated f lamm able sub stance ( other th an hy droge n), y our pro cess is likely to be eligible for Prog ram 1 if y ou have no pu blic receptors within about 400 yards (1,200 feet) of the proce ss. If y ou have up to 100,000 pounds in a process (ten times the threshold quantity), the process may be eligible for Prog ram 1 if there are no public receptors within abo ut 700 yards (2, 000 feet). I n general, it wo uld be worthw hile to conduc t a wors t-cas e analy sis for a ny pro cesses c ontaini ng on ly flamm ables to determ ine Pro gram 1 elig ibility , unles s you have public r eceptor s very close to the process. Consequently, y ou may have to conduct more worst- caseChapter 2 Ap plicab ility of Pro gram Leve ls 2-12

analyses if you want to qualify processes for Program 1; for Program 2 and 3
process es, y ou need analy ze onl y one worst- case rel ease sce nario to cover all flammables. For Program 1, you m ust be able to dem onstrate, through y our worst-case analy sis, that every process you claim is Program 1 meets the criteria.

2.4 PROGRA M 3

Any covered process that i s not eligible for Pr ogram 1 and meets one of the two criteria specified below is sub ject to Program 3 requirements, w hich include risk
managem ent measures and requirements v irtually identical to the O SHA PSM Standard.

W HAT A RE T HE E LIGIBILITY C RITE RIA F OR P RO GR A M 3?

Your pr ocess is subject t o Prog ram 3 if:



### � Your process does no t meet the elig ibility requiremen ts for Program 1, and



### � Either

(a) Your process is subject to O SHA PSM (federal or state); or

(b) Your process is in one of ten NAI CS codes specified in part 68.

W HAT I S THE OSHA PSM S TANDARD ?

The OSHA Process S afety Managem ent standard (codified at 29 CFR 1910.119 ) is a set of procedures in thirteen managem ent areas designed to protect worker he alth and safety in case of acc idental releases. Sim ilar to EPA' s rule, OSHA P SM applies to a range of facilities that ha ve more th an a threshold quantity of a listed substance in a process. All processes subject to this rule and the OS HA PSM standard (fede ral or state) and not eligible for Program 1 are assigned to Program 3 because the Prog ram 3 pre vent ion p rogr am is vi rtu all y iden tic al to the e lemen ts of the P SM st anda rd. If
you a re alrea dy co mply ing w ith OSH A PSM f or a pro cess, y ou prob ably w ill need to take few, if any , additional steps and d evelop little, if any , additional docum entation
to me et the re quirem ents of the Pro gram 3 prev ention e lemen ts (see C hapter 8 for a discussion of differences betw een Program 3 prevention and OSHA PSM). EPA placed all covered O SHA PSM processes in Program 3 to eliminate th e possibility of imposing o verlapping, in consistent requirements on the same p rocess.

W HAT AR E THE T EN NAICS C ODES ? (§ 68.10)

Program 3 requirements are a pplicable to a covere d process if the process is in one of ten manufacturing NAICS codes: 32211, 324 11, 32511, 3251 81, 325188, 325 192, 325199, 325211, 325311, or 32532. These NAI CS codes were selected based on an analys is of ac ciden tal re lease data an d repre sent ac tiviti es for which a r elati vely highChapter 2 2-13 Ap plicab ility of Pro gram Leve ls

proportion of sources reporte d releases. The following are the NAI CS codes and the

assoc iated activi ty:

NAICS Code Indu stry

32211 Pulp m ills 32411 Petroleum refineries 32511 Petrochemical m anufacturing 325181 Alkalies and chlorine manufacturing 325188 All other basic inorg anic chemical m anufacturing 325192 Cyclic crude and intermediate m anufacturing 325199 All other basic orga nic chemical m anufacturing 325211 Plastics material and resin manufacturing 325311 Nitrogenous fertiliz er manufacturing 32532 Pesticide and other ag ricultural chemical m anufacturing

H OW D O I D EFIN E A NAICS C OD E FO R A P ROCESS ?

Unless you h ave on ly one proces s, yo u proba bly ha ve no t prev iously needed to assign a NAI CS code to each o f your processes. If yo ur covered process includes several industrial activ ities, you will need to determine the primary NA ICS code for assigning Prog ram level ba sed on the prim ary activity of the process. I f the process covers multip le industrial activities, y ou may list several NAI CS codes for the process on the reg istration part of the RMP. Even if a proce ss is considered a support activity for your m ain production (e.g ., your wareh ouse or wastewater treatment system ), you m ust assign it a separa te, appropriate code (e.g ., 56221 for waste treatment) to determine if it is sub ject to Program 3

. This assignment does not affect you r ability to consider su ch support processes as part of the same industrial group for p urposes of defining your stationary source; the two decisions are separate.

NAICS C OD ES F OR A P ROCESS VS

. P RIMARY F ACILITY NAICS C ODE

For purposes of det ermining program levels, you must identify the appl icable NAICS codes for each indiv idual process. Unless you have only one process, there may not be a r ela tio nshi p bet ween the c over ed pr oces s NAICS code (s) and yo ur fa cil ity's prima ry NA ICS code. The prim ary N AIC S code for yo ur facil ity m ay be simila r to the NAIC S codes that you determine for sev eral if not all of you r processes, but the prima ry NA ICS code fo r the fac ility s hould n ot be us ed as a default value or to identify a NAI CS code for a sing le process. The prim ary NAI CS code for the facility is assigned based on the activity that contributes the larg est percentage of
your revenue and is the code y ou use when y ou complete C ensus forms.

2.5 PROGRA M 2

Progr am 2 is consi dered a default progr am le vel be cause a ny co vered proces s that is not eligible for Prog ram 1 or assig ned to Program 3 is, by defau lt, subject to Program 2 requir emen ts, incl uding a stream lined ac cident p reven tion pro gram

. One or mo re process es at y our faci lity ar e like ly to b e in Pro gram 2 if:Chapter 2 Ap plicab ility of Pro gram Leve ls 2-14



### � You are a retailer and d o not perform an y chemical processing activities, such as an ag ricultur al fertil izer re tailer.



### � You are a publicly owned facility in a state that does not hav e a delegated OSHA p rogr am.



### � You use regulated acids in solution in activ ities that do not fall into on e of the ten NAI CS codes specified for Program 3

.


### � You sto re regul ated l iquid flammable substa nces in atmosphe ric st orage tanks for use as a feedstock or for sale to retailers.

W HAT AR E THE E LIGIBILITY C RITERI A FOR P RO GR A M 2?

Your pr ocess is subject t o Prog ram 2 if:



### � Your process does no t meet the elig ibility requiremen ts for Program 1;



### � Your process is not su bject to OSHA PSM (federa l or state); and



### � Your process is not cate gorized in N AICS co de 32211, 32411, 32511, 325181, 325188, 325192, 325199, 325211, 325311, or 32532.

When determining what program level is appropriate fo r your cove red process, keep in mind that if it does no t meet the Program 1 criteria, i f it is not covered by OSHA PSM, and it is not class ified in the NAI CS codes listed abov e, the process automatically is subject to Program 2 requirements.

Exhibit 2-2 provides a sum mary of th e criteria for determining Program level.Chapter 2 2-15 Ap plicab ility of Pro gram Leve ls



### EXHIBIT 2-2 PROGR AM LEVEL CR ITERIA

Program 1 Program 2 Program 3

No accidents in the previous fi ve years that resul ted in any of fsi te:

De ath Injury Respons e or r est orat ion acti vit ies at an envi ronment al r ecept or The proces s i s not eli gibl e for Program 1 or su bject to Prog ram 3. Process i s not el igi ble for Program 1.

No public recep tors in worst-case circl e. Pro cess is sub ject to O SH A P SM

.

Emergency res ponse coordinat ed with local respon ders. Process i s clas sif ied in NAICS code 322 11 - P ulp M ills 32411 - Petroleum Ref ineri es 32511 - Petrochemica l Manufacturing 32518 1 - Alkalies and Chlorine Manufacturing 325 188 - All Oth er B asic Ino rganic Chemical Ma nufacturi ng 32519 2 - Cyclic Crude and Intermediate Manufacturing 325 199 - All Oth er B asic O rganic Chemical Ma nufacturi ng 32521 1 - Plastics Material and Resin Manufacturing 325311 - Nitrogenous Ferti lize r Manufacturing 32532 - Pestici de and Other Agricul tural Chemical Manufacturing

2.6 DEALI NG WITH PROGRAM LEVELS

W HAT I F I HAVE M ULTIPLE P RO GR A M L EVELS ?

If y ou hav e mor e than o ne cov ered pro cess, y ou ma y be d ealing with m ultiple program lev els in your risk managem ent program

. If y our faci lity h as proc esses su bject to d ifferent progr am le vels, you w ill need to comply w ith different program requirements for d ifferent processes. Nev ertheless, you must submit a sing le RMP for all cove red processes.

If you prefer, you m ay choose to ado pt the most string ent applicable program level requirements for all co vered processes. For example, if you have three covered
process es, one eligib le for P rogram 1 and t wo sub ject to Pr ogram 3, yo u may find it administratively easier to follow the Pro gram 3 req uirements for all three coveredChapter 2 Ap plicab ility of Pro gram Leve ls 2-16

processes. Rem ember, thoug h, that this is only an option; we expec t that most sources will comp ly with the set of program lev el requirements for w hich each process is eligible.



### Q S 

### & A S 

### OSHA

Q. If my state administers the OSHA progra m under a dele gation from the federal OSHA, does that mean that m y processes that are subject to OSHA PSM u nder the state rules are in P rogram 3?

A. Yes, as long as the process does not qualify for Prog ram 1. An y process subject to PS M, under federal or state rules, is con sidered to be in Prog ram 3 unless it q ualifies for Program 1.

Q. I am a publicly own ed facility in a state w ith a delegated OS HA program

. Why are m y processes considered to be in Pro gram 3 w hen the same p rocesses in a state where federal OSHA runs the
program are in Program 2?

A. Federal OSHA cannot impose its rules on state or local g overnments, but when OSH A delegates its program to a state for implem entation, the state im poses the rules on itself an d local gove rnments. Because these gov ernments are com plying with the identical OSHA P SM rules imposed by federal OSHA, they are sub ject to Pr ogram 3. I n mee ting t heir obl igatio ns unde r state O SHA ru les, the y are already substantially in compliance w ith the Program 3 prevention pro gram requirem ents. State and local g overn ments in non -stat e-pl an state s are no t subject to any OSHA rules a nd mu st com ply w ith Program 2

.

C AN THE P RO GR A M L EVE L FO R A P ROCESS C HA NGE ?

A change in a covered process or in the surrounding commun ity can result in a change in the pro gram lev el of the process. I f this occurs, you must subm it an updated RMP within six months of the change that altered the program level for the covered process. If the process no longer qualifies as a covered process (e.g., as a result of a change in the quantity of the regulated substance in the process), yo u must update and re- submit you r RMP within six m onths indicating that th e process is no longer subject to any program level requireme nts. If it is your only c overed process,
you a re no lo nger s ubject to the Par t 68 reg ulation s and w ill need to "dere gister " your RMP (see C hapter 9 for more information). Ty pical examples of switching program lev els include:

M OVING U P

From Program 1 to Program 2 or 3. You h ave a cover ed proc ess sub ject to Progr am 1 requirem ents. A new re sidentia l deve lopme nt resul ts in pu blic rec eptors being located within the distance to the endp oint for a worst- case release for that
process. The process thus is no longer elig ible for Program 1 and must be evaluated to determine whe ther Program 2 or Program 3 applies. You must update andresubmit you r RMP within six m onths of the progra m level ch ange, indicating andChapter 2 2-17 Ap plicab ility of Pro gram Leve ls

documenting that your process is now in com pliance with the new program lev el requirements.

From Not Covered to Progra m 1, 2 or 3. You have a process that was not originally cov ered by part 68, but, due to a plan ned expansion in prod uction, you plan to increase the am ount of regul ated sub stance i n the pr ocess to a lev el that w ill exceed the threshold quan tity for that substance. You mus t determine which program lev el applies and com e into compliance with the rule by the time yo u increase the amoun t of regulated substan ce in the process to a level exceeding the thres hold qu antit y.

From Program 2 to Program 3. You have a process that involv es a regulated substance above th e threshold that is not in one of the ten NAI CS codes specified for Program 3 and that had not be en subject to OSHA P SM. Howeve r, due to one of the following OSH A regulatory changes, the proc ess is now subject to the O SHA PSM standard:



### � An OSHA PS M exemption applicab le to your process has been eliminated
, or



### � The regulated substance h as been added to O SHA's list of highly ha zardous substances.

As a result, the process becomes subject to P rogram 3 requirements and y ou must update and re- submit you r RMP to EPA w ithin six months, indicating and docu menti ng tha t your proc ess is no w in c ompli ance with the P rogr am 3 requirements.

S WITCHING D OWN

From Program 2 or 3 to Program 1. At the ti me you submit your RMP, you have a covered process subject to Program 2 or 3 requirem ents because it experienced an accidental release of a reg ulated substance with offsite impacts four y ears ago. Subsequent process chan ges have m ade such an eve nt unlikely (as demonstrated by the worst-case release analysis). O ne year after y ou submit y our RMP, the process has n ot ex peri ence d an a cci dent for f ive ye ars , so i t is n ow el igib le fo r Pro gram 1. If you elect to qualify the process for Prog ram 1, y ou must update and re-subm it your RMP within six m onths of the progra m level ch ange, indicating and documen ting that the process is now in compliance w ith the new prog ram level req uirements.

From Program 2 or 3 to Not C overed. You have a covered process that has been subject to Program 2 or 3 requirem ents, but due to a red uction in production, the amount of a reg ulated substance it holds n o longer exceeds the threshold. Therefore, the process is no long er a covered proces s. You m ust update and re- submit you r RMP within six m onths indicating that y our process is no long er subject to any program lev el requirements. If this was y our only cov ered process, you must “deregister” your RMP.Chapter 2 Ap plicab ility of Pro gram Leve ls 2-18

2.7 SUMMARY OF PRO GRAM REQUIR EMENTS

Regardless of the p rogram lev els of your processe s, you m ust complete a fiv e-year acciden t histor y for each pr ocess (s ee Chap ter 3) an d subm it an RM P that c overs all processes (see Chapter 9). Depending o n the program level of each of your processes, you must comply with the addi tional requir ements described bel ow. Exhibit 2-3 diagr ams t he requ ireme nts in g eneral a nd Exh ibit 2- 4 lists t hem i n mor e detail.

P RO GR A M 1

For each Program 1 process, you must conduct and document a worst-case re lease analysis. You must coordinate y our emergen cy response activ ities with local responders and sign the Program 1 certification as part of y our RMP subm ission.

P ROGRAMS 2 AND 3

For all Program 2 and 3 processes, you must conduct and docum ent at least one worst-case release analysis to cov er all toxics and one to cover all flam mables. You may need to conduct additional w orst-case release an alyses if worst- case releases from different parts of your facility w ould affect different public recep tors. You must also condu ct one alternative release scenario analysis for ea ch toxic and one for all flammable s. See Chapter 4 or the RMP Offsite Consequence Analysis Guidance for specific requiremen ts. You m ust coordinate your emergency response activities with local responders and , if you use y our own emp loyees to respond to releases, you must develo p and implem ent an emerg ency response prog ram. See C hapter 8 for more details.

For each Program 2 process, you must im plement all of the elements of the P rogram 2 prevention prog ram: safety info rmation, haz ard review, operatin g procedures, training , mai ntenanc e, com pliance audits, and inc ident in vestig ations. See C hapter 6 for more details.

For each Program 3 process, you must im plement all of the elements of the P rogram 3 prev ention p rogram : proces s safety inform ation, process hazar d analy sis, sta ndard operating procedures, training, m echanical integrity, compliance aud its, incident investigations, m anagement of change, pre- startup reviews, con tractors, employ ee participation, and hot wo rk permits. See Chapter 7 for m ore details.Chapter 2 2-19 Ap plicab ility of Pro gram Leve ls



## EXHIBIT 2-3 DEVELOP RISK MANAGE MENT PROGRA M AND RMPChapter 2 Ap plicab ility of Pro gram Leve ls 2-20



### EXHIBIT 2-4 COMPA RISON OF P ROGRAM REQUIREME NTS
Program 1 Program 2 Program 3

Worst- case rel ease an alysis Worst- case rel ease an alysis Worst- case rel ease an alysis
Alternative release analy sis Alternative release analy sis
5-y ear acci dent his tory 5-y ear acci dent his tory 5-y ear acci dent his tory

Document m anagement system Document m anagement system
Prevention Prog ram Certify no additional prevention steps needed Safety Information Process Safety I nformation

Hazard Rev iew Process Hazard A nalysis.
Operating Procedure s Operating Procedure s Training Training

Maintenance Mechanic al In tegrity

Incident I nvestigation Incident I nvestigation
Comp liance A udit Comp liance A udit
Manage ment of Ch ange Pre-Startup R eview

Contrac tors
Employee Participation

Hot Wor k Perm its
Emergency Response Prog ram

Coordinate with local respond ers Develop plan an d program and coordinate with local respond ers Develop plan an d program and coordinate with local respond ers

Submit One R isk Managem ent Plan for All Cov ered ProcessesChapter 2 2-21 Ap plicab ility of Pro gram Leve ls

2.8 EXAMPLE SOURCES

The six sources described in th is section will be used in this document to highlight impor tan t sta ges i n deve lopi ng a ri sk mana gement progr am.



### Source A

A chemical distribu tion facility stores isoprop ylamine in 55-gallon drums inside a wareho use. Th e facilit y stor es a tot al of 80 drum s in clo se prox imity to each other, so they are conside red “co -loc ated” an d their content s are ad ded tog ether to determ ine if th e applic able thr eshold quantit y is ex ceeded. Since the tota l quanti ty in t he co- located drum s excee ds the a pplicab le threshold quantity of 10,000 pounds, th e warehouse is a cov ered process.

The ware house i s locate d 50 y ards ins ide the facility fence l ine and the nea rest pub lic receptor (another industrial facility ) is 100 yards from the fence line. The distanc e to the overpressure endpoint for a worst-cas e release from a s ingle 55- gallon drum is approximately 0.05 miles or 88 y ards. There is no public receptor within the distance to an endpoint from a worst-case release, and the proces s had n o accid ental re leases o f isopro pylam ine resu lting in offsi te imp acts in the last five ye ars. The process is elig ible for Program 1.



### Source B

An agricultural retailer loc ated in a comm ercial area has a 200- ton tank of anhy drous ammonia and an 18,000- gallon propane tank

. The retailer unloads both ammonia and propane from these bulk tank s into smaller tank s that are then transported to farms. The factory is not fenced. The facility is within 0.15 mile of residences and the business center o f a small town.

The facility has one cov ered process: the 200- ton tank of am monia. Beca use propane is a flammable fuel and the facility is a retailer, the propane is n ot subject to part 68. A worst-case release analysis finds tha t the worst-case release of amm onia will potentially im pact the residences and the busine ss cente r of tow n. The f acility is not s ubject to OSHA PSM, n or is th e amm onia storag e categ orized in one of the t en liste d NAI CS cod es for P rogram 3. As a resul t, the p rocess i s subject to Program 2.Chapter 2 Ap plicab ility of Pro gram Leve ls 2-22



### Source C

A bulk products terminal has co- located petroleum p roduct tanks containin g 10,000,000 pounds of a regu lated flamma ble mixture in on e area, and co- located chemical tank s containing 500,000 pounds o f toluene diisocyanate in another area. The facility serves as a wh olesale supplier to industrial facilities in the surroun ding area for these and other (non- regulated) petroleum and industrial chemical pro ducts. The facility is within 0.2 m ile of another industrial facility

. The facility has two cov ered processes: the flam mable m ixture tanks (Process A) and the toluene diisocyanate tan ks (Process B). A worst-c ase release analysis find s that the worst- case release from Process A will potentially im pact the adjacent industrial facility, but the worst case release from Process B will not imp act any offsite receptors. Process A is subject to O SHA PSM, but Process B is not subject to OSHA PSM. Therefore, Process A is subject to Pro gram 3 an d Process B is elig ible for Prog ram 1

. If Proces s B had been su bject to O SHA P SM, it w ould als o be su bject to Program 3

.


### Source D

A me tal prod ucts m anufact urer sto res hy drochlo ric acid (37 per cent sol ution) a nd uses it in its plating process, w hich is connected to a storage tank that holds 50,000 pou nds of the solution. Hydrochloric acid is delivered in tank trucks and unloa ded into the storage tank. The m anufacturer also operates a wastewater treatment plant that u ses chlorine, supplied from five, interconnected oneton tanks, which are stored in a rack

. The facility is in an industrial area and borders directly on another industrial facility, whose workers park in the area clo se to the fence line. In addition, a river borders one side of the facility.

The facility has two cov ered processes: the 50, 000-pound tank of hyd rochloric acid at 37 percent (Process A) and the process involv ing five intercon nected one-ton tanks of chlorine in the
wastewater treatment plant (Process B). A worst-case relea se analysis finds that the worst-case releases from both processes will potentially impact the bord ering industrial facility and its workers. Process B is subject to the O SHA PSM standard, but Process A is n ot. Process A is a lso not catego rized in one o f the ten listed N AIC S codes for Pro gram 3. Ther efore, Process B is su bject to Program 3 and Process A is s ubject to Program 2.Chapter 2 2-23 Ap plicab ility of Pro gram Leve ls



### Source E

An inorganic chem ical manufacturer uses hydrofluoric acid in solution to manufa cture fluoroboric acid at a site that is approximately 500 yards squa re. It also has a water treatm ent plant using chlorine. The manufacturer stores 1 0 tons of 70 percent H F solution, which is piped to the reactor vessels. The w astewater treatment plan t stores an averag e of ten one- ton tanks of chlorine together on a rack

. The plant is in an ind ustrial area. The HF storag e tank is 150 y ards from the property boundary

. The nearest neighb oring building or workers are 30 0 yards away

.

The facil ity ha s two c overe d proce sses: th e proce ss inv olving the 10- ton tank of hy drofluo ric acid at 70 perc ent (Pro cess A) and pro cess inv olving the ten co- located one- ton tank s of chl orine in the wastewater treatm ent plant (Process B). A worst-c ase release analysis find s that the worst- case releases from both processes will potentially impact the neig hboring building s and workers. Process B is subject to the OSHA PSM standard, but P rocess A is not. P rocess A activities are categorized in NAICS code 325188. Therefore, both processes are subject to Program 3

.



### Source F

A large chemical manufacture r operates a sit e that is approxi mately a half mile wide and two miles long, with a major riv er on one long side and a four- lane road on the other. There are industrial facilities on the other side of the road and river (a half-m ile wide); neighboring facilities' fence lines abut the compan y's prop erty boundary

. The compan y maintains a 300-y ard buffer zone on each narrow end of the facility and 50-y ard buffer between its pro cesses and the road and river. The
company manufactures a v ariety of chem icals, including ch loroform, chorine, epichlorohydrin, ethyle ne, HC l, hy droge n cyan ide, TDI , met hyl ch loride, phosg ene, an d propy lene, a ll of wh ich are
prese nt above thres hold qu antit ies in proces s vessel s and st orage ta nks. The TDI proce ss and s torage tanks are located at the center of the facility. The ethylene and propylene tank s are located 500 yards from the river bank

. A propane tank , used as a back up fuel source, is located just inside the buffer zone, 50 yards from the highway and 100-y ards from the entran ce of a facility across the highway.

Although the facility has a numbe r of separate production an d storage units, se veral of the units with regulated toxic substances are conside red to be co- located and, therefore, are one process. The prop ylene and eth ylene tanks are far enoug h apart to be co nsidere d separ ate proc esses. A wors tcase release analysis de termines that both of these tanks hav e no public receptors w ithin the distances to their endpoint. The TDI process is not co- located or interconnected to any other cov ered process. A wors t-cas e releas e analy sis dete rmine s that th e TDI proces s’s wor st-ca se relea se woul d reach its endpoint within the fencelin e. None of these three processes has experienc ed a release of a reg ulated substance during the past five ye ars that resulted in any offsite consequences. Each of these is, therefore, eligible for P rogram 1. The propane tank also is not co- located with any other covered

vesse l. Bec ause it is used as a bac kup fu el for b uilding s on sit e, it is not sub ject to th e RMP regulation. The other pro cesses are subject to Progra m 3 because a t least one of the produc tion or storage units in each process is subject to OSHA PSM, and their wors t-case scenarios w ould impact public receptors.Chapter 2 Ap plicab ility of Pro gram Leve ls 2-24

## CHAPTER 3: FIVE-YEAR ACCIDENT HISTORY

The five-year accident history involves the reporting of significant accidental releases of one or more of the regulated substances from a covered process in the five years prior to the submission of an initial or updated Risk Management Plan (RMP). A five-year accident history must be completed for each covered process, including the processes in Program 1, and must include all accidental releases meeting specified criteria, as discussed below.

Note that a Program 1 process may have had an accidental release that must be included in the five-year accident history, even though the release does not disqualify the process from Program 1. The accident history criteria that make a process ineligible for Program 1 (certain offsite impacts) do not include other types of effects that require inclusion of a release in the five-year accident history (on-site impacts and more inclusive offsite impacts). For example, an accidental release may have led to worker injuries, but no other effects. This release would not bar the process from Program 1 (because the injuries were not offsite), but would need to be reported in the five-year accident history. Similarly, a release may have resulted in damage to offsite foliage (environmental damage), triggering reporting, but because the foliage was not part of an environmental receptor (e.g., national park or forest), it would not make the process ineligible for Program 1.



### 3.1 WHAT ACCIDENTS MUST BE REPORTED?

The five-year accident history covers only certain releases:



### � The release must be from a covered process and involve a regulated substance held above its threshold quantity in the process.



### � The release must have caused at least one of the following:

� On-site deaths, injuries, or significant property damage (§68.42(a));

or

� Known offsite deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place (§68.42(a)).

If you have had a release of a regulated substance from a process where the regulated substance is held below its threshold quantity, you do not need to report that release even if the release caused one of the listed impacts or if the process is covered for some other substance. You may choose to report the release in the five-year accident history, but you are not required to do so.

3.2 WHAT DATA MUST BE PROVIDED?

The following information should be included in your accident history for every reported release:

Date. Indicate the date on which the accidental release began.Chapter 3 Five-Year Accident History 3-2

Time. Indicate the time at which the release began.

Release duration. Indicate the approximate length of time of the release in minutes.

Chemical(s). Indicate the regulated substance(s) released. Use the name of the substance as listed in § 68.130 rather than a synonym (e.g., ethylene oxide rather than oxirane). If the release was of a flammable mixture, list the primary regulated substances in the mixture if feasible; if the contents of the mixture are uncertain, list it as a flammable mixture.

Quantity released. Estimate the amount of each substance released in pounds. The amount should be estimated to two significant digits, or as close to that as possible. For example, if you estimate that the release was between 850 and 900 pounds, provide a best guess. We realize that you may not know precise quantities. For flammable mixtures, you may report the quantity of the mixture, rather than that of the individual regulated substances.

Release event. Indicate which of the following release events best describes your accident. Check all that apply:



### � Gas Release. A gas release is a release of the substance as a gas (rather than vaporized from a liquid). If you hold a gas liquefied under refrigeration, report the release as a liquid spill.



### � Liquid Spill/ Evaporation. A liquid spill/evaporation is a release of the substance in a liquid state with subsequent vaporization.



### � Fire. A fire is combustion producing light, flames, and heat.



### � Explosion. An explosion is a rapid chemical reaction with the production of noise, heat, and violent expansion of gases.



### � Uncontrolled/Runaway Reaction . A release event caused by an uncontrolled chemical reaction that generates excessive heat, pressure, or harmful reaction products. Such events may involve highly exothermic chemical reactions, self-reactive substances (e.g., substances that undergo polymerization), unstable, explosive, or spontaneously combustible substances, substances that react strongly with water or other contaminants, oxidizers, peroxide-forming substances, or other types of chemical reactions that generate harmful products or byproducts. This category of release event may often occur in conjunction with one of the previous categories. In such cases, be sure to check this category in addition to any other applicable release event category (e.g., explosion). The burning of ordinary flammable substances is not typically included in this category.

Release source. Indicate all that apply.Chapter 3 3-3 Five-Year Accident History



### � Storage Vessel. A storage vessel is a container for storing or holding gas or liquid. Storage vessels include transportation containers being used for on-site storage.



### � Piping. Piping refers to a system of tubular structures or pipes used to carry a fluid or gas.



### � Process Vessel. A process vessel is a container in which substances under certain conditions (e.g., temperature, pressure) participate in a process (e.g., substances are manufactured, blended to form a mixture, reacted to convert them into some other final product or form, or heated to purify).



### � Transfer Hose. A transfer hose is a tubular structure used to connect, often temporarily, two or more vessels.



### � Valve . A valve is a device used to regulate the flow in piping systems or machinery. Relief valves and rupture disks open to release pressure in vessels.



### � Pump . A pump is a device that raises, transfers, or compresses fluids or that attenuates gases by suction or pressure or both.



### � Joint . The surface at which two or more mechanical components are united.



### � Other . Specify other source of the release.

Weather conditions at time of event (if known). This information is important to those concerned with modeling the effects of accidents. Reliable information from those involved in the incident or from an on-site weather station is ideal. However, this rule does not require your facility to have a weather station. If you do not have an onsite weather station, use information from your local weather station, airport, or other source of meteorological data. To the extent possible, complete the following:



### � Wind Speed and Direction . Wind speed is an estimate of how fast the wind is traveling. Indicate the speed in miles per hour. Wind direction is the direction from which the wind comes. For example, a wind that blows from east to west would be described as having an eastern wind direction. You may describe wind direction as a standard compass reading such as "Northeast" or "South-southwest."

You may also describe wind direction in degrees--with North as zero degrees and East as 90 degrees. Thus, northeast would represent 45 degrees and south-southwest would represent 202.5 degrees. Abbreviations for the wind direction such as NE (for northeast) and SSW (for south-southwest) are also acceptable.



### � Temperature . The ambient temperature at the scene of the accident in degrees Fahrenheit. If you did not keep a record, you can use the high (forChapter 3 Five-Year Accident History 3-4

daytime releases) or low (for nighttime releases) for the day of the release. Local papers publish these data.



### � Stability Class . Depending on the amount of incoming solar radiation as well as other factors, the atmosphere may be more or less turbulent at any given time. Meteorologists have defined six atmospheric stability classes, each representing a different degree of turbulence in the atmosphere. When moderate to strong incoming solar radiation heats air near the ground, causing it to rise and generating large eddies, the atmosphere is considered unstable, or relatively turbulent. Unstable conditions are associated with stability classes A and B. When solar radiation is relatively weak, air near the surface has less of a tendency to rise and less turbulence develops. In this case, the atmosphere is considered stable or less turbulent with weak winds. The stability class is E or F. Stability classes D and C represent conditions of neutral stability or moderate turbulence respectively. Neutral conditions are associated with relatively strong wind speeds and moderate solar radiation. Exhibit 3-1 presents the stability classes associated with wind speeds, time of day, and cloud cover.



### � Precipitation Present . Precipitation may take the form of hail, mist, rain, sleet, or snow. Indicate "yes" or "no" based on whether there was any precipitation at the time of the accident.



### � Unknown . If you have no record for some or all of the weather data, indicate "unknown" for any missing item. We realize that you may not have weather data for accidents that occurred in the past. You should, however, collect these data for any future accidents.



### EXHIBIT 3-1 ATMOSPHERIC STABILITY CLASSES

S URFACE W IND S PEED AT 10 M ETERS D AY N IGHT

Incoming Solar Radiation Thinly Overcast or

$ 4/8 low

cloud # 3/8 Cloud

Meters per

second Miles per hour Strong* Moderate Slight**

< 2 <4.5 A A-B B

2-3 4.5-7 A-B B C E F

3-5 7-11 B B-C C D E

5-6 11-13 C C-D D D D

>6 >13 C D D D D

* Sun high in the sky with no clouds. ** Sun low in the sky with no clouds.Chapter 3 3-5 Five-Year Accident History

On-site impacts. Complete the following about on-site effects.



### � Deaths. Indicate the number of on-site deaths that are attributed to the accident or mitigation activities. On-site deaths means the number of employees, contract employees, offsite responders, or others (e.g., visitors) who were killed by direct exposure to toxic concentrations, radiant heat, or overpressures from accidental releases or from indirect consequences of a vapor cloud explosion from an accidental release (e.g., flying glass, debris, other projectiles). You should list employee/contractor, offsite responder, and other on-site deaths separately.



### � Injuries. An injury is any effect that results either from direct exposure to toxic concentrations, radiant heat, or overpressures from accidental releases or from indirect consequences of a vapor cloud explosion (e.g., flying glass, debris, other projectiles) from an accidental release and that requires medical treatment or hospitalization. You should list injuries to employees and contractors, offsite responders, and others separately.

Medical treatment means treatment, other than first aid, administered by a physician or registered professional personnel under standing orders from a physician.

Your Log of Work-Related Injuries and Illnesses (OSHA Form 300) and Injury and Illness Incident Report (OSHA Form 301) will help complete these items for employees.



### � Property Damage . Estimate the value of the equipment or business structures (for your business alone) that were damaged by the accident or mitigation activities. Record the value in American dollars. Insurance claims may provide this information. Do notinclude any losses that you may have incurred as a result of business interruption.

Known offsite impacts. These are impacts that you know or could reasonably be expected to know of (e.g., from media reports or from reports to your facility) that occurred as a result of the accidental release. You are not required to conduct an additional investigation to determine offsite impacts.



### Q S 

### & A S 

### P ROPERTY 

### D AMAGE

Q. What level of offsite property damage triggers reporting?

A. Any level of known offsite property damage triggers inclusion of the accident in the five-year accident history. You are not required to conduct a survey to determine if such damage occurred, but if you know, or could reasonably be expected to know (e.g., because of reporting in the newspapers), that damage occurred, you must include the accident.Chapter 3 Five-Year Accident History 3-6



### � Deaths. Indicate the number of offsite deaths that are attributable to the accident or mitigation activities. Offsite deaths means the number of community members who were killed by direct exposure to toxic concentrations, radiant heat, or overpressures from accidental releases or from indirect consequences of a vapor cloud explosion from an accidental release (e.g., flying glass, debris, other projectiles).



### � Injuries. Indicate the number of injuries among community members. Injury means any effect that results either from direct exposure to toxic concentrations, radiant heat, or overpressures from accidental releases or from indirect consequences of a vapor cloud explosion from an accidental release (e.g., flying glass, debris, other projectiles) and that requires medical treatment or hospitalization.



### � Evacuated. Estimate the number of members of the community who were evacuated to prevent exposure that might have resulted from the accident. A total count of the number of people evacuated is preferable to the number of houses evacuated. People who were ordered to move simply to improve access to the site for emergency vehicles are not considered to have been evacuated.



### � Sheltered. Estimate the number of members of the community who were sheltered-in-place during the accident. Sheltering-in-place occurs when community members are ordered to remain inside their residence or place of work until the emergency is over to prevent exposure to the effects of the accidental release. Usually these orders are communicated by an emergency broadcast or similar method of mass notification by response agencies.



### � Environmental Damage. Indicate whether any environmental damage occurred and specify the type. The damage to be reported is not limited to environmental receptors listed in the rule. Any damage to the environment (e.g., dead or injured animals, defoliation, water contamination) should be identified. You are not , however, required to conduct surveys to determine whether such impact occurred. Types of environmental damage include:

� Fish or animal kills.

� Lawn, shrub, or crop damage (minor defoliation).

� Lawn, shrub, or crop damage (major defoliation).

� Water contamination.

� Other (specify).Chapter 3 3-7 Five-Year Accident History

Initiating event. Indicate the initiating event that was the immediate cause of the accident, if known. If you conducted an investigation of the release, you should have identified the initiating event.



### � Equipment Failure. A device or piece of equipment failed or did not function as designed. For example, the vessel wall corroded or cracked.



### � Human Error. An operator performed a task improperly, either by failing to take the necessary steps or by taking the wrong steps.



### � Weather Conditions. Weather conditions, such as lightning, hail, ice storms, tornados, hurricanes, floods, or high winds, caused the accident.



### � Unknown.

Contributing factors. These are factors that contributed to the accident, but were not the initiating event. If you conducted an investigation of the release, you may have identified factors that led to the initiating event or contributed to the severity of the release. Indicate all that apply.



### � Equipment Failure. A device or piece of equipment failed to function as designed, thereby leading to or worsening the accidental release.



### � Human error. An operator performed an operation improperly or made a mistake leading to or worsening the accidental release.



### � Improper Procedures. The procedure did not reflect the proper method of operation, the procedure omitted steps that affected the accident, or the procedure was written in a manner that allowed for misinterpretation of the instructions.



### � Overpressurization. The process was operated at pressures exceeding the design working pressure.



### � Upset Condition. Incorrect process conditions (e.g., increased temperature or pressure) contributed to the release.



### � By-pass Condition. A failure occurred in a pipe, channel, or valve that diverts fluid flow from the main pathway when design process or storage conditions are exceeded (e.g., overpressure). By-pass conditions may be designed to release the substance to restore acceptable process or storage conditions and prevent more severe consequences (e.g., explosion).



### � Maintenance Activity/ Inactivity. A failure occurred because of maintenance activity or inactivity. For example, the storage racks remained unpainted for so long that corrosion caused the metal to fail.Chapter 3 Five-Year Accident History 3-8



### � Process Design. A failure resulted from an inherent flaw in the design of the process (e.g., pressure needed to make the product exceeds the design pressure of the vessel).



### � Unsuitable Equipment. The equipment used was incorrect for the process. For example, the forklift was too large for the corridors.



### � Unusual Weather Conditions. Weather conditions, such as lightning, hail, ice storms, tornados, hurricanes, floods, or high winds contributed to the accident.



### � Management Error. A failure occurred because management did not exercise its managerial control to prevent the accident from occurring. This is usually used to describe faulty procedures, inadequate training, inadequate oversight, or failure to follow existing administrative procedures.

Whether offsite responders were notified. If known, indicate whether response agencies (e.g., police, fire, medical services) were contacted.

Changes introduced as a result of the accident. Indicate any measures that you have taken at the facility to prevent recurrence of the accident. Indicate all that apply.



### � Improved/ Upgraded Equipment. A device or piece of equipment that did not function as designed was repaired or replaced.



### � Revised Maintenance. Maintenance procedures were clarified or changed to ensure appropriate and timely maintenance including inspection and testing (e.g., increasing the frequency of inspection or adding a testing method).



### � Revised Training. Training programs were clarified or changed to ensure that employees and contract employees are aware of and are practicing correct safety and administrative procedures.



### � Revised Operating Procedures. Operating procedures were clarified or changed to ensure that employees and contract employees are trained on appropriate operating procedures.



### � New Process Controls. New process designs and controls were installed to correct problems and prevent recurrence of an accidental release.



### � New Mitigation Systems. New mitigation systems were initiated to limit the severity of accidental releases.



### � Revised Emergency Response Plan. The emergency response plan was revised.



### � Changed Process. Process was altered to reduce the risk (e.g., process chemistry was changed).Chapter 3 3-9 Five-Year Accident History



### � Reduced Inventory. Inventory was reduced at the facility to reduce the potential release quantities and the magnitude of the hazard.



### � Other.



### � None. No changes initiated at facility as a result of the accident (e.g., because none were necessary or technically feasible). There may be some accidents that could not have been prevented because they were caused by events that are too rare to merit additional steps. For example, if a tornado hit your facility and you are located in an area where tornados are very rare, it may not be reasonable to design a "tornado proof" process even if it is technically feasible.

3.3 WHEN MUST ACCIDENTS BE REPORTED?

When an RMP is first submitted to EPA, it must contain a five-year accident history including all of the accidents that meet the reporting criteria discussed above and that occurred within five years of the date of the RMP is submitted. When an RMP isupdated as required by section 68.190 of the rule, it must contain an updated fiveyear accident history including all of the accidents that meet the reporting criteria and that occurred within five years of the date on which the updated RMP is submitted. In addition, on April 9, 2004, EPA published a final rule that amended the accident history reporting requirement (and certain other provisions of the risk management program). Beginning on that date, if an accident occurs that meets the reporting criteria, it must be reported in the RMP five-year accident history within six months of the accident, as required by section 68.195 of the rule, unless it is included in an RMP update prior to that time. EPA took this action to require more timely reporting of significant accidents in RMPs so that government, industry and the public would be more quickly alerted to the possibility of similar accidents occurring elsewhere.

3.4 OTHER ACCIDENT REPORTING REQUIREMENTS

You should already have much of the data required for the five-year accident history because of the reporting requirements under the Comprehensive Emergency Response, Compensation, and Liability Act (CERCLA), EPCRA, and OSHA (e.g., log of work-related injuries and illnesses). This information should minimize the effort necessary to complete the accident history.

At the same time, some of the information originally reported to response agencies may have been incomplete or inaccurate because it was reported during the release when a full assessment was not possible. It is imperative that you include the most accurate, up-to-date information possible in the five-year accident history. This information may not always match the original estimates from the initial reporting of the accident's effects.

CERCLA Section 103(a) requires you to immediately notify the National Response Center if your facility releases a hazardous substance to the environment in greater than a reportable quantity (see 40 CFR part 302). Toxic substances regulated underChapter 3 Five-Year Accident History 3-10

part 68 are also CERCLA hazardous substances, but most of the flammable substances regulated under part 68 are not subject to CERCLA reporting. Notice required under CERCLA includes the following information:



### � The chemical name or identity of any substance involved in the release



### � An indication of whether the substance is on the list referred to in Section 302(a)



### � An estimate of the quantity of substance that was released into the environment



### � The time and duration of the release



### � The medium or media into which the release occurred.

EPCRA Section 304 requires facilities to report to the community emergency coordinator of the appropriate local emergency planning committee (LEPC) and state emergency response commission (SERC) releases of extremely hazardous substances to the environment in excess of reportable quantities (as set forth in 40 CFR part 302). All toxic substances regulated under part 68 are subject to EPCRA reporting; flammables regulated under part 68 are generally not subject to EPCRA reporting. The report required by EPCRA is to include:



### � Chemical name or identity of all substances involved in the accident



### � An estimate of the quantity of substances released to the environment



### � The time and duration of the release.

The owner or operator is also required to release a Follow-up Emergency Notice as soon as possible after a release which requires notification. This notice should update the previously released information and include additional information regarding actions taken to respond to the release, any known or anticipated acute or chronic health risks associated with the release, and where appropriate, advice regarding medical attention necessary for exposed individuals.

OSHA's Log of Work-Related Injuries and Illnesses, OSHA Form 300, is used for recording and classifying recordable occupational injuries and illnesses, and for noting the extent and outcome of each case. The log shows when the occupational injury or illness occurred, to whom, what the injured or ill person's regular job was at the time of the injury or illness exposure, the kind of injury or illness, how much time was lost, and whether the case resulted in a fatality, etc. The following are the sections of the illness/ injury log that are useful in completing the accident history.



### � Column B: Employee’s name



### � Column C: Job titleChapter 3 3-11 Five-Year Accident History



### � Column D: Date of injury or onset of illness



### � Column F: Description of injury or illness



### � Columns G, H, I, K, L: Indicate whether a death occurred, whether injury resulted in lost workdays or restricted duty, and number of work days away form work or on restricted duty.



### � Column M: Indicates whether injury occurred or type of illness.

P ART 68 I NCIDENT I NVESTIGATION

An incident investigation is a requirement of the rule (§68.60 and 68.81). For accidents involving processes in Program 2 or Program 3, you must investigate each incident which resulted in, or could reasonably have resulted in, a catastrophic release of a regulated substance. A report, which includes the following information, should be prepared at the conclusion of the investigation:



### � Date of incident



### � Date investigation began



### � Description of the incident



### � Factors that contributed to the incident



### � Any recommendations resulting from the investigation.

Because the incident investigation report must be retained for five years, you will have a record for completing the five-year accident history for updates of the RMP.Chapter 3 Five­Year Accident History 3­12



### Q S 

### &A S 

### A CCIDENT 

### H ISTORY

Q. When does the five­year period to be reported in the accident history begin?

A. The five­year accident history must include information on all accidental releases from covered
processes meeting the specified criteria that occurred in the five years preceding the date of submission of your initial RMP or your most recent update required under section 68.190, as well

as information provided to revise the accident history for any accidental releases that occur prior
to the next required update. For example, if an RMP is updated on June 21, 2009, the five­year accident history must cover the period between June 21, 2004, and June 21, 2009. If a reportable accident occurs two months later, the five­year accident history must cover the period between June 21, 2004, and the date of the accident (see next question for further explanation).

Q. I recently submitted my five­year RMP update required by section 68.190 (b)(1) and included
my accident history for the previous five years. Two months later, we had another reportable accident. Do I have to do anything to revise my RMP?

A. Yes. You must revise your accident history within six months of the date of the new accident to include information about it. You do this by correcting section 6 of your RMP (the accident history section) so that it includes all accident history information reported on the most recent update, as well as the information about the new accident. You should also indicate the reason for
your correction (i.e., new accident history information) in the appropriate field in section 1 of RMP*eSubmit. Facilities reporting under Programs 2 and 3 must also revise the incident investigation information in their RMPs (section 7 or 8 of their RMP). Specifically, the date of investigation (40 CFR 68.170(j)) and the expected date of completion of any changes (40 CFR 68.175(l)) should be revised. You do not need to update or correct any other section of the RMP, unless you have taken actions (e.g., as a result of the accident) that trigger an update in accordance with section 68.190.Chapter 3 3-13 Five-Year Accident History



### Q S 

### & A S 

### A CCIDENT 

### H ISTORY 

### ( CONTINUED 

### )

Q. If a facility has recently changed ownership, is the new facility owner required to include accidents which occurred prior to the transfer of ownership in the accident history portion of the RMP submitted for the facility?

A. Yes, accidents involving covered processes that occurred prior to the transfer of ownership should be included in the five-year accident history. You may want to explain that the ownership has changed in your Executive Summary.

Q. If I have a large on-site incident, but no offsite impact, would I have to report it in the five-year accident history?

A. It would depend on whether you have onsite deaths, injuries, or significant property damage. You could have a large accident without any of these consequences (e.g., a large spill that was contained); this type of release would not have to be included in the five-year accident history.

Q. I had a release where several people were treated at the hospital and released; they attributed their symptoms to exposure. We do not believe that their symptoms were in fact the result of exposure to the released substance. Do we have to report these as offsite impacts?

A. Yes, you should report them in your five-year accident history. You may want to use the executive summary to state that you do not believe that the impacts can be legitimately attributed to the release and explain why.

## CHA PTER 4: OFFSIT E CONSEQUE NCE A NA LYSIS

RMP OFFSITE CONSEQUENCE ANA LYSIS GUIDANCE

This chap ter is in tended for peo ple who plan to do thei r own a ir dispe rsion m odeling

. If you p lan to do yo ur own mode ling, this ch apter w ill prov ide yo u with the basi c inform ation y ou need to com ply with the rule requirem ents; it does not prov ide modeling methodolog ies. For people wh o do not plan to do their own m odeling, EPA has prepared a separate d ocument, RMP Offsite Consequence Analysis Guidance, which p rovide s sim ple m ethods and refe rence ta bles for determ ining distanc e to an endpoint for worst- case and alternative relea se scenarios. I n conjunction with the Nation al Oceano graph ic and A tmosp heric A dmini stration (NOAA ), EPA has als o dev eloped a softw are program, RMP*CompTM, that performs calculations d escribed in the RMP Offsite Consequence Analysis Guidance. RMP*Com pTM is available for free from the EPA I nternet website at http://yosemite.ep a.gov/oswe r/CeppoWeb.nsf/content/rm p-com p.htm. I n addition, EPA has developed industry -specific gu idance for several ind ustries covered by part 68, which are appended to this d ocum ent. I n the ap pendice s, EPA provi des che mical -spe cific m odeling for the applica ble industries, using the methods described in the RMP Offsite Consequence Analysis Guidance

.



### 4.1 INTRODUC TION

The offsite consequence analy sis consists of two elem ents:



### � Worst-ca se relea se scen ario analysis to identify the potential reach and effect of hypothetical w orst-case accidental releases, as follows:

� For a process to qualify for Program 1 (see Chapter 2), a worst-case release scenario analy sis m ust be d one for each to xic and flamm able substance held abov e the applicable threshold q uantity in the
process

. The pr ocess is eligib le for P rogram 1 if the re are n o publi c receptors within the distance to an endpoint for any of the worst- case scenarios analyze d and the other Pro gram 1 criteria are met (see Chapter 2). Conseq uently, for ev ery Program 1 process, you must conduct a worst- case scenario analysis for each regulated su bstance above the thr eshold in the p rocess. Howe ver, i n you r RMP th e only

wors t-cas e sce nari o ana lysi s you mu st re port for a Progr am 1 process is for the toxic or flammable substance that, if released under worst-ca se conditions, would potentially effect the larg est geographical are a around your fac ility. In the languag e of the rule, such a scenario results “in the greatest distance to an endpoint,”

mean ing th at the d anger ous effe ct of th e toxic or flam mable substan ce exten ds the l onges t distan ce befo re dissi pating to relatively harm less levels.

� If your site has Program 2 and/or Program 3 processes (processes that are not eligible for Program 1 — see Chapter 2), y ou must identify , analy ze and report one wo rst-c ase scen ario to represen t all of the t oxic reg ulated s ubstanc es held above thresho ld quan tities inChapter 4 Offsite C onse que nce A nalysis 4-2

Program 2and/or 3 processes (i.e. , the worst- case release of the toxic substance that results in the greatest distance to endpoint,), and
one worst-case scenario to represent all of the flamma ble regulated substan ces held abov e thresh old qua ntities i n Prog ram 2 and/or 3 processes (i.e., the w orst-case release o f the flamm able substance that results in the greate st distance to endpoint).

� You m ay nee d to sub mit an additio nal wor st-ca se analy sis if a
worst- case rel ease fro m els ewhere at you r facilit y cou ld poten tially affect public receptors different from those potentially affected by the init ial wors t-cas e scena rio(s).



### � Alterna tive rel ease sc enario analysis to identify the potential reach and effect of hypothetical ac cidental releases under m ore realistic circumstances, for all Program 2 and Program 3 processes, as follow s:

� You m ust iden tify an d analy ze rea sonable release scenari os that are more likely to occur than worst- case release scenarios and th at reach an off-site endp oint, unless no such scenario exists.

� In y our RMP , you must report one alte rnativ e releas e scena rio analy sis for e ach reg ulated t oxic su bstance held ab ove th e applic able threshold quantity in a Program 2 or 3 process, includ ing the substance considered in a worst-case analy sis.

� In y our RMP , you must also re port on e altern ative release scenario
represen ting a ll flam mable substan ces held abov e the ap plicable threshold quantity in a Program 2 or 3 process.

If the distance to the endpoint for y our worst-case release just reaches your fenc e line, you m ay not hav e an alternative release scenario with a distance to an endpoint that goes bey ond the fence line. H owever, y ou still must report an alternative release scenario.

H OW SHOULD I CO NDU CT THE ANALYS IS ?

As noted above , You may use EPA' s RMP Offsite Consequence Analysis Guidance
to ca rry o ut you r con sequ ence anal ysis

. Resu lts obta ine d usi ng the metho ds in EPA's Guidance are expected to be conservativ e. Conservativ e assumptions ha ve been introdu ced to c ompe nsate fo r high level s of unc ertainty

. EPA 's g uidance is optio nal, and you are free to use other air dispersion models, fire or e xplosion models, or comp utation meth ods pro vided that:



### � They are publicly or comm ercially available o r are proprietary m odels that you are wi lling t o share with th e implemen ting agen cy;



### � They ar e recog nized by in dustry as appl icable t o curren t practic es;



### � They ar e appro priate f or the c hemic als and conditi ons bei ng m odeled;Chapter 4
4-3 Offsite C onse que nce A nalysis



### � You use the applicable definitions of worst- case scenarios; and



### � You use the applicable parameters specified in the rule.

Complex m odels that can account fo r many site- specific factors may give less

cons erva tive esti mates of of fsi te co nseq uenc es th an th e simp lif ied metho ds in EPA's guidance, particularly for alternative scenarios, for which EPA h as not specified



### EXHIBIT 4-1 CONSIDERA TIONS FOR CHOOSING A MODELING METHOD

Approach Examples Advantages Disadvantages

Simp le guidance EP A’s Offsite Consequence An alysis Guidance � Free � No com puter requ ireme nts � Simple to use � Provides al l data needed � Provides t ables of dist ances � Eas es co mplia nce w ith rule � Co nserva tive resu lts � Few site-s pecific f actors considere d � Little flexib ility in scenar io development

Simp le computer mod els EP A mo dels, such as RMP*CompTM � No/low cost � M ay be simple to use � Can consider some sit especific f actors � Som e may not b e simple to use � Likely t o give conservative results � M ay not a ccep t all of EP A’s required assumptions � M ay not inc lude c hem icalspec ific data � M ay not a ddr ess all
consequences
Complex computer mod els Co mm ercially availab le mod els � May addres s a va rie ty of

scen ari os � May consider many sit especific f actors � M ay be c ostly � May requi re hi gh l evel of experti se

Calcu lat ion methods “Yellow Boo k” (Neth erl ands TNO) � Low co st � No com puter requ ireme nts � M ay req uire ex pertise to ap ply methods � M ay req uire de velop men t of a variety o f data

many assum ptions. Howe ver, c omple x mod els m ay be expensi ve and require considerable expertise to use; EPA's op tional guidance is de signed to be sim ple and straightforward. Y ou will need to consid er the tradeoff in deciding how to carry out your required conse quence analyses. Exhibit 4-1 provides additional suggestions on making this decision.

Whether you u se EPA 's g uidance or anot her m odeling meth od, y ou shou ld bear in mind tha t the re sults you obtai n from model ing your wo rst-cas e or alt ernat iveChapter 4 Offsite C onse que nce A nalysis 4-4

scenarios should not be considered to predict the lik ely results of an acc idental release. The worst- case assumptions are very con servative, and , regardless of the model used, y ou can expect v ery conservativ e results. Results from modeling alternative scenarios will be less conservative; however, y ou still must use conservative en dpoints.

In addition, results of an actual release w ill depend on m any site-sp ecific conditions (e.g., wind speed and other weathe r conditions) and factors related to the release (e.g. , when and ho w the re lease oc curs, h ow long it tak es to st op it). You sh ould make reaso nable assumpt ions re gardin g such fa ctors in devel oping your alter native scenarios, but the circum stances surrounding an actual release m ay be different. Diff ere nt mod els like ly wil l pro vide diff ere nt re sul ts, e ven wi th th e same assumptions, and most m odels have not b een verified with ex perimental data; therefor e, resu lts of ev en soph isticate d mod eling have a high degre e of unc ertainty and should be v iewed as providing a basis for discussion am ong the regu lated

commun ity, emerg ency planners and responders, and the pu blic, rather than predictions. Modeling results should be considered particularly uncertain ov er long distanc es (i.e. , 10 k ilome ters or m ore).

Exhibi t 4-2 provi des sugge stion s for as sista nce on mode ling.

W HEN D OES THE O FFSITE C ONSEQUENCE A NALYS IS (O CA) N EED TO B E R EVISED ?

You’ll need to rev ise your OCA when a chang e at your facility results in the distance to an endpoint from a worst-case release rising or falling by at least a facto r of two. For exa mple, if you incr ease you r invent ory subs tanti ally or i nstal l passi ve mitigation to limit the potential release rate, you should re-estimate the distance at an endpoint. I f the distance is at least do ubled or halved, you must update and ressubm it the R MP. Fo r mos t substa nces, t he quan tity th at woul d be rel eased w ould have to increase (or decrease) by m ore than a factor of fiv e to double (or halv e) the distance to an endpoint. Depending on the regulated substan ce, installation of passiv e miti gation syste ms su ch as c ontainm ent dik es or en closure s can si gnific antly affect th e distan ce to an endpoi nt.

4.2 WORST -CA SE RE LEA SE SC ENA RIOS

This sect ion des cribes t he assu mptio ns yo u mus t mak e and w hat yo u need to do to
meet t he re quir ement s for wors t-cas e sce nari o ana lysi s und er th e rul e. Exh ibi t 4-3 summariz es the required param eters for the worst- case analysis. EP A has defined a worst-case release as the release of the larg est quantity of a reg ulated substance from a vessel or pipe th at results in the greatest distance from the p oint of release to a specified endpoint, bey ond which serious injury is not expected to occ ur (§68.3). You must estim ate the distance as follows:



### � Part 68, Appendix A lists the toxic endpoin t you mu st use for each regu lated toxic su bstance

. For t he wors t-cas e analy sis for t oxic su bstance s, yo u are required to estim ate the air disp ersion d istance to the e ndpoin t, usin g cert ain conservative assu mptions concerning quantity released an d release conditions.Chapter 4
4-5 Offsite C onse que nce A nalysis



### � A vapor cloud explosion is specified as the worst-case sc enario for flamm able sub stances

. For t he wors t-cas e analy sis for f lamm able substances, you need to estimate th e distance to an ov erpressure endpoint of 1 pound per squ are inch (psi) re sulting from a vap or cloud explos ion of a cloud containing the largest quantity of the regulated flam mable substance from a ves sel or process pipe line failu re.



### EXHIBIT 4-2 POSSIBLE SOURCES OF ASSISTA NCE ON MODELING

� You may be able to obt ain modeli ng help f rom the i mplementi ng agency in y our area; for exampl e, local a nd stat e implement ing age ncies in Delawar e, Flor ida, Georgi a, and ot her “del egated” s tate s (see Chapte r 10) a re pre pared t o provi de ass ist ance t o regu lat ed sour ces. If you a re i n anot her s tat e, y ou may obtai n help f rom the EPA regional offi ce for y our st ate.

� If y ou use cert ain models , user s’ gr oups may be a sour ce of ass ist ance; f or example, there is an ALOHA model user s’ group.

� If you u se a c ommerci al model , y ou probabl y can reque st assi sta nce f rom th e model devel oper or distribu tor.

� Publ ic at io ns of th e Ce nt er fo r Pr oce ss Saf et y o f t he A mer ic an I ns ti tu te of Che mi cal Eng in eer s ( AICh E) may provide u seful inf ormation on modeling; examples of such publ icat ions i nclude:

< Guideli nes f or Eval uati ng the Char acter ist ics of Vapor Cl oud Explos ions, Flash Fi res, and BLEVEs (1994), and

< Gu ideline s for U se of V apo r Clo ud D ispersio n M ode ls (1987).

� EPA publicati ons als o may provide us eful modeling i nformat ion; e xamples i nclude:

< Wo rkbo ok o f Scree ning Tech niqu es for A ssessing Imp acts o f Tox ic Air P olluta nts , EPA450/4-88-009 (September 198 8), and

< Gu idanc e on the App lication of Re fined D ispersion M odels for H azardo us/Toxic A ir Release
, EPA -454/R-93-002 (M ay 1993).

< Technic al Backgr ound Document for Offs it e Consequenc e Analys is for Anhydrous Ammonia, Aqueous Ammonia Chlor ine, and Sulf ur Dioxi de EPA-550-B99- 017.

< EP A guidan ce is available at the Sup port Ce nter for Regulato ry Air M odels: http://www .epa.g ov/sc ram0 01//Chapter 4 Offsite C onse que nce A nalysis 4-6

W ORST -C ASE R ELEASES OF T OXIC S UBSTANCES

For the worst- case release analysis for toxic substances, y ou need to use the

assum ptions d iscusse d below , the p ropertie s of the substan ce, and an app ropriate air dispersion model o r EPA's o ptional guidance to estimate the distance from the release point to the point a t which the concentration of the substance in air is equal to the toxic endpoint spe cified in the rule. Beca use the assumption s required for the
worst- case an alysis are v ery co nserv ative, the res ults lik ely w ill also be ver y

conserv ative. The end points s pecified for the regul ated tox ic subst ances a re intended to be protectiv e of the general p ublic. These endpoints are concentrations below which it is believ ed nearly all indiv iduals could be exposed for one-half to one hour wi thout an y seri ous hea lth effe cts. I n additi on, the worst- case an alysis is carried out using v ery conservativ e assumptions ab out weather and release conditions. The distance to the endpoint estima ted under worst- case conditions should not be c onsider ed a z one in w hich the public would l ikely be in d anger ; instead, it is intended to provide an estim ate of the maxim um possible area that might be affected in the unlikely event of catastrophic conditions. Distances g reater than about 10 k ilometers are particularly uncertain. EPA intends the estimated dista nces to provide a basis for a di scuss ion among t he regul ated co mmunity,
emergency planners and responders, and the public, rather than a basis for any specific predictions or actions.

M ODELING A SSUMPTIONS

Quantity. EPA has defined (§68.3) a worst- case release as the release of the largest quantity of a reg ulated substance from a vessel or proce ss line (pipe) failure that results in the greatest d istance to a specified endpo int. For substances in vessels, you
must assum e release of the largest amount in a sin gle vessel; for substances in pipes,
you m ust assu me re lease of the larg est am ount in a pipe. The larg est quan tity sh ould be dete rmine d taki ng int o accou nt adm inistrat ive co ntrols. Adm inistrat ive co ntrols are written procedures that lim it the quantity of a substance that can be store d or processed in a vessel or pipe at any one time, or, alter natively, occasional ly allow a vessel or pipe to s tore larger than usual quantities (e.g., d uring turnaround). You do
not nee d to con sider th e possib le cause s of the worst- case rel ease or the prob ability that such a release m ight occur; the release is simply ass umed to tak e place.

Release Height. All releases are assum ed to take place a t ground lev el for the worst-case analy sis. This is a conserv ative assump tion in most cases

. Even if y ou think a grou nd-level release is unlikely at your site, y ou must use th is assumption for the worst-case analysis.

Wind Speed and Atmospheric Stability. Meteorological condition s for the
worst- case sce nario ar e define d in the rule as atmo spheric stabilit y clas s F (sta ble
atmos phere) a nd wind speed o f 1.5 m eters pe r secon d (3.4 miles per hou r). I f, however, y ou can demon strate that the minim um wind spee d at your site (m easured at 10 meters) has been higher than 1.5 meters per second, or that the m aximum atmosphere stability has always bee n less stable than class F, you m ay use the minimum wind speed and m ost stable atmosphe ric conditions at you r site for the
worst- case an alysis

. To dem onstrate highe r min imum wind s peeds o r less st able atmospheric condition s, you will nee d to document local meteorolog ical data fromChapter 4
4-7 Offsite C onse que nce A nalysis

the previous three y ears that are applicable to y our site. If you do not k eep weather data for your site (m ost sources do not), y ou may call another nearby s ource, such as an airport, or a com piler, such as the Nation al Weather Service, to determine wind speeds for your are a. Exhibit 3- 1 in Chapter 3 describe s atmospheric stability classes in relati on to w ind spe ed and cloud c over. Your a irport o r other source will be able to giv e you inform ation on cloud c over. A sm all diffe rence in wind s peed pr obably will no t lead to a sign ificant d ecrease in the d istance to the e ndpoin t.



### EXHIBIT 4-3 REQUIRED PARA METERS FOR MODELING WORST-CA SE SCENA RIOS

Endpo ints � For t oxi c su bst ance s, use th e en dpoi nt spe cif ied in part 68, Append ix A. � For f lammabl e subs tanc es, use t he endpoi nt of an over press ure of 1 pound per squar e in ch (ps i) f or vapo r cloud exp losions.

W ind speed/stability � Use wind speed of 1.5 meters per second and F s tabil ity class unles s you can demonstrat e that local meteorological data applicable to the s ite show a higher minimum wind speed or less stable atmosphere
at a ll ti mes dur ing the previ ous t hree year s. If you ca n demons tra te a hig her mi nimu m wind speed or less stab le atmo sphe re ov er three years, the se minim ums m ay be u sed.

Amb ient temperature/humidity � For toxic substances, us e the highest daily maximum temperature during t he past three years and

avera ge hum idity for the site.

He ight of re lease � For toxic subst ances, assume a g round leve l rel ease.

Topography � Use urban or rur al t opography, as appropriat e.

Dense or neutrally buoyant gases � Tables or models u sed for di spersi on of regu late d toxic s ubstance s must appropriat ely a ccount f or gas den sity.

Temperature of releas ed substance � For liqui ds (other than ga ses l iquefi ed by ref riger ation) , use the hi ghest daily maximum tempera ture, base d on data fo r the pr eviou s three ye ars, or a t proc ess tem pera ture, wh icheve r is higher

. � Assume gases liquefi ed by refrigerat ion at atmospheric pressure are r eleased at thei r boiling points.

Temperature and Humidity. For th e worst -cas e releas e of a re gulate d toxic substan ce, y ou mu st assum e the hi ghest daily maxim um te mpera ture tha t occurr ed in the previous three y ears (the highest tem perature reached in the last three years) and the av erage humid ity fo r the sit e. I f you have n ot kep t inform ation on temp erature and humidity at your site, y ou may obtain it from a lo cal meteorolog ical station. EPA's RMP Offsite Consequence Analysis Guidance assumes a tempera ture of 25°C (77°F ) and 50 percen t hum idity. If y ou use the EPA 's g uidance for y our offs ite consequence analysis, you m ay use these assum ptions even if the actual highest tempe rature a t your site is highe r or low er. I f the tem perature at yo ur site i s significantly lowe r, EPA's guidance m ay giv e overly con servative results,Chapter 4 Offsite C onse que nce A nalysis 4-8

particul arly fo r toxic liquids. Sma ll differ ences in temp erature and hum idity are unlike ly to h ave a major e ffect on results , howe ver.

Topography. Two choices are prov ided for topography for the worst- case scenario. If y our site is loca ted in a n area w ith few buildin gs or other ob structio ns, y ou shou ld assume open (ru ral) conditions. I f your site is in an urban location, or is in an area with many obstructions, you should assume urban conditions.

Gas or Vapor D ensity. For the worst- case analysis, y ou must use a model appropriate for the density of the released g as or vapor. G enerally, for a subs tance that is lighter than air o r has a density sim ilar to that of air, yo u would use a m odel for neutrally buoy ant vapors. The initial vapor density of a substance with re spect to air can be estim ated from its m olecular weight, ass uming air h as a "molecular weight" of approxim ately 29. For a substance that is heav ier than air (molecular weight greater than 29), you generally wou ld use a dense g as model. There are cases where a dense g as model m ay be appropriate fo r a substance with m olecular weight of 29 o r less (e .g., release of a co mpres sed ga s as a c old va por) or where a neutral ly buoyant plum e model m ay be appropriate fo r a substance with a h igher molecu lar weigh t (e. g., re lea se by s low e vapor ati on, w ith cons ide rabl e mixi ng wit h air ). In additio n, dens e gase s and v apors w ill beco me ne utrally buoy ant thro ugh m ixing with air as they m ove downwind

. If y ou can account for suc h conditions in m odeling, yo u may do so.

E

STIMATI NG R ELEASE R ATES

Toxic Gases. Toxic gases include all regulated toxic sub stances that are gases at ambient tem perature (temperature 2 5o C, 77o F). F or the consequence analy sis, the total quantity in the s ingle largest v essel or process line is assu med to be release d as
a gas over a period of 10 m inutes, except in the case of gases liquefied by refrigeration under atm ospheric pressure. The release rate (per minute) for a gas (not lique fied by r efrige ratio n) is th e tota l quant ity rel eased divided by 10. Pass ive mitigation m easures (e.g., en closure) may be taken into acco unt in the analysis of the
worst-case scen ario. A 10- minute release m ust be assumed for gases regard less of the model y ou use.
Gases liquefied by refrigeration alone (not u nder pressure) and released into diked
areas may be modeled as liquids at their boiling points, if the pool form ed by the released liquid would b e grea ter than one cen timete r (0.39 inches) in dept h. I n this
case, you m ay assume the liquefied gas is re leased from a po ol by evap oration at the boili ng point of the gas

. If the ref rigera ted li quefi ed gas is not con taine d by passi ve mitigation, o r if the pool form ed would have a depth of one centim eter or less, you
must treat the release d subst ance as a gas release d ove r 10 m inutes. EPA' s analy sis indicated that pools of g as liquefied by refrig eration with a depth of one centimeter or less would ev aporate so rapidly at their boiling points tha t treatment as g aseous releases over 10 m inutes is reasonable.

Toxic liquids. For toxic liquids, y ou must assum e that the total quantity in a vessel is sp ill ed, f ormin g a poo l. Fo r tox ic li quid s car rie d in p ipe lin es, yo u must assu me that the largest quantity that might be released from th e pipeline forms a pool. Passive mitig ation systems (e.g., dik es) may b e taken into accou nt in consequenceChapter 4
4-9 Offsite C onse que nce A nalysis

analy sis. Y ou mu st assum e that th e total q uantity spilled spread s instan taneous ly to a depth of one centim eter (0.39 inches) in an undiked area or co vers a diked area instantaneously. Y ou estimate the relea se rate to air as the rate of evaporation from the pool. To estim ate the evaporation ra te, you need to estimate the surface area of the pool. You ca n take into accoun t the surface characteristics of the area into which the li quid wou ld be sp illed ; for ex ample, so me models fo r pool e vaporat ion wil l take into account the typ e of soil if the spill will tak e place in an unpav ed area. Your mode ling a lso sho uld con sider th e leng th of tim e it wil l take for the pool to evaporate.

You may use any approp riate model to estim ate the evaporation ra te of a spilled regulated substance from a pool and estim ate the air dispersion distance to the specifie d endpo int of th e regu lated su bstance

. The re lease ra te can t hen be used to estim ate the distanc e to the endpoi nt.

E

STIMATI NG D ISTANC E TO THE E NDPOINT

You m ay use any a ppropri ate m odel, a s discus sed abo ve, to estim ate the distanc e to the end point sp ecified in part 68 App endix A for a re lease of a reg ulated t oxic substance, using th e required modelin g assumptio ns.

W ORST -C ASE R ELEASES OF F LAMMABLE S UBSTANCES

For the worst- case scenario involv ing a release of a regulated flamm able substance (a flammab le gas or vo latile flammable liquid), you m ust assume that th e quantity of the flamma ble substance is released into a vapor cloud and that a vapor cloud explosi on resu lts. Yo u mus t estim ate the distanc e to an endpoin t to an o verpre ssure level of 1 pound per square inch (psi) from the explosion of the v apor cloud.



### � If the flam mable substance is normally a gas at amb ient temperature and handled as gas o r liquid under pressure or if the flamm able substance is a g as handled as a refrigerated liquid and is not conta ined when released or the contained pool is one c entimeter or less dee p, you m ust assume the to tal quantity is released as a gas and is inv olved in a v apor cloud explosion.



### � If the flam mable substance is a liquid or a refrigerated gas released into a
cont ain ment a rea with a dep th gr eat er th an on e cen time ter , you ma y assu me that the quantity that volatilizes in 10 minutes is inv olved in a v apor cloud explosion.

As in the case of the worst-case release analysis for toxic sub stances, the worst- case distanc e to the endpoi nt for fl amm able sub stances is base d on a n umbe r of v ery

conserv ative assum ptions. Releas e of the total q uantity of a fla mm able sub stance i n a vessel or pipe in to a vapor cloud generally wou ld be highly unlikely. Vapor cloud explosions are also unlik ely events; in an actual release, the flam mable gas or vapor relea sed to a ir might di spers e witho ut ignit ion, or it might bu rn inst ead of e xplodi ng, with more lim ited consequences. The en dpoint of 1 psi is intend ed to be conservative an d protective; it does not define a level a t which severe injuries or death would be commonly exp ected

. An overpr essur e of 1 psi is unli kely to have serious direct effects on peop le; this overpressure m ay cause property damage suchChapter 4 Offsite C onse que nce A nalysis 4-10

as partial demolition of houses, which can result in injuries to people, and shattering of glass window s, which may cause skin laceration from flying glass.

To carry out the wors t-case conseque nce analysis for flam mable substances, you m ay use a TN T-equ ivalen t mod el (i.e. , a m odel tha t estim ates the explos ive ef fects of a flammable substance by com parison with the effects of an equivalent quan tity of the high e xplosiv e trinitr otoluen e (TNT), b ased on the av ailable comb ustion e nergy in the vapor cloud - see Guidelines for Evaluating the Characteristics of Vap or Cloud Explosions, Flash Fire s, and BLEVEs (1994) for additional inform ation). Such models allow y ou to estimate the distance to a specific ov erpressure level, based on empirical data from TNT explosions. I f you use a TNT- equivalent m odel, you m ust assume that 10 percent of the flamm able vapor in the cloud participates in the explosion (i.e., y ou assume a 1 0 percent yield factor for the explosion). Y ou do not have t o use a TNT-eq uivale nt mo del; oth er mo dels are avail able tha t take into account more site- specific factors (e.g., degree of confinem ent of the vapor cloud). Generally, howe ver, a TNT-eq uivalent mod el is the simplest to use.

N UMBE R OF S CEN AR IO S

The number of w orst-case scenarios you must analyze depen ds on several factors as discussed below. Y ou only need to consider the hazard (toxicity or flam mability) for which a substance is reg ulated (i.e., even if a regulated toxic substance is also flammable, you only need to consider toxicity in your analy sis; even if a reg ulated flammable substance is also toxic, y ou only need to consider flamm ability).

P

RO GR AM 1 PROCESSES

To demonstrate that a process is eligible for P rogram 1 (see Chapter 2), y ou must conduct a worst- case release analysis for every toxic an d flammab le regulated substance held in that pro cess above the ap plicable threshold quantities. For the process to be in Prog ram 1, that ana lysis must sh ow that the distance to the specified endpoin t for ev ery re gulate d subst ance in the pro cess is small er than the dist ance to any public receptor. If y ou have sev eral processes that m ay qualify for Program 1
, you will hav e to conduct worst- case analysis for each process to determ ine which qualify. You will need to report in the RMP the worst- case results with the g reatest distance to an endpoint fo r those processes yo u determine to b e eligible for Prog ram 1.

If the distance to the endpoint in the w orst-case analy sis is equal to or g reater than the dist ance to an y publ ic re cept or, t he pr oces s wou ld be in Pr ogra m 2 or Pr ogra m 3 (discussed below). When you consider po ssible eligibility of your processes for Progr am 1, you m ay wa nt to lo ok pa rticular ly at p rocesse s contai ning only flammable substances, which are likely to hav e shorter worst- case distances than toxic substances.

P

RO GR AM 2 AND 3 PROCESSES

For all your Prog ram 2 and 3 processes taken tog ether, you m ust identify, carry out and report in the RMP one worst-case analysis for the reg ulated toxic substances and

one wo rst-c ase ana lysis for the regula ted flam mable substan ces held abov e theirChapter 4
4-11 Offsite C onse que nce A nalysis

thresho ld quan tities in those p rocesse s. The b asic pur pose of the wo rst-c ase ana lysis is to ide ntify the ge ograp hical ar eas and the pub lic rece ptors an d popul ation w ithin those ar eas that could b e affect ed by a wors t-cas e releas e. The r elease t hat resu lts in the greatest distance to an endpoint would affe ct the largest g eographical area and the greatest num ber of public receptors and people, so as a g eneral matter only that release (and not others affecting a smaller area) ne eds to be reported. The reported scenario for toxic substances must be the scen ario estimated to resu lt in the greatest distanc e to a t oxic en dpoint; for flam mable substan ces, it must be the s cenario estimated to lead to the greatest distance to 1 psi overpressure fo r a vapor cloud explosi on. A ddition al wors t-cas e analy ses m ust be r eported for tox ic or fla mm able substan ces if a worst- case rel ease fro m a d ifferent locatio n at the facility potenti ally would affect a som ewhat different geog raphical area containing public receptors and people in addition to th ose affected by the scenario giving the greatest distance.

I DENTIFY ING THE "W ORST " W ORST -C ASE S CEN ARIO

Toxics. To determine the scenario that giv es the greatest distance to an endpoint for processes containing toxic substances, y ou may have to analy ze more th an one scenario, because the distan ces depend on m ore than simply the quantity in a
process. For toxic liqu ids, for example, distances depend on the magnitud e of the toxic endpoint, the m olecular weight and volatility of the s ubstance, and the tempe rature o f the su bstance in the p rocess, as well as quan tity. A sm aller qu antity of a substance at an elev ated temperature m ay giv e a greater distance to the endpoint than a larger quantity of the same su bstance at ambient temperature. I n some cases, it may be difficult to predict which sub stance and process will g ive the greatest worst-case distan ce. You also m ay need to carry out analyses of w orst-case scenarios for locations at sig nificant distances from each other to determ ine whether different public receptors m ight be affected by releases.

Flammables. For fla mm able sub stances , the g reatest quantit y in a proces s is lik ely to give the greatest distance to the endpoint, but there m ay be variation s, depending on heat of com bustion and distance to th e fence line. You may hav e to carry out several analyses to identify the scenario that gives the greatest distance to the endpoint. As in the case of toxic substances, you also m ay need to carry out analyses for locations far apart from each other to determ ine whether different g eographical areas and thus public rece ptors might be affected.

For both toxic and flam mable substances, the worst-cas e distances should be considered only ap proximations.Chapter 4 Offsite C onse que nce A nalysis 4-12



### Q S 

### & A S 

### W ORST 

### -C ASE AND 

### M ITI GATION

Q. At my facility , if the worst- case rel ease sce narios f or reg ulated t oxic su bstance s and th e worst

case scenario for regu lated flamma ble substances involv e the same proc ess, must I analyze bo th?

A. Yes. I f the wo rst-c ase rele ase scen arios fo r regu lated to xic sub stances and reg ulated f lamm able substances in Progra m 2 and 3 processes are associated with the same proce ss, the two worst- case relea se scen arios must be ana lyzed sep arate ly.

Q. What m easures qualify as "pas sive m itigati on"?

A. Passive mitig ation is defined in § 68 .3 as "equipmen t, devices, or tech nologies that function without human, mechanical, or other energy input." Passive m itigation system s include building enclosures, dikes, and containment walls. Measures such as fire sprinkler system s, water curtains, valves, scrub bers, or flares would n ot be considered passiv e mitigation b ecause they require h uman, mechanical, or en ergy input to function.

Q. When analyzing the worst-cas e scenario for regulated toxic substances, m ust I anticipate a specific cause (e.g., fire, explosion, etc.) o f the scenario?

A. No. The worst- case an alysis for a re lease of regul ated tox ic subst ances m ust con form to speci fic assumptions as ide ntified in § 68.25(c) and (d). Anticipated cause s of the release will not affect the analys is, and are not requir ed. A spec ific c ause may be consid ered i n analyzi ng the al terna tive release scenario s althou gh it i s not a requirem ent.

Q. Would all of the reg ulated substances stored in a salt dome be assumed to be released in the
worst-case scen ario?

A. The worst case scenario for salt domes w ould be examin ed in a manne r similar to that for underg round s torage tanks

. Rese rvoirs or ve ssels su fficient ly bur ied und ergrou nd are p assive ly mitigated or p revented from failing catastrophically

. You should ev aluate the failure of piping connected to underg round storage for th e worst-case a nd alternative scenarios.

Q. Are valv es in piping consid ered administrativ e controls?

A. No, adm inistrative controls are w ritten procedures that lim it the quantity stored or flowing through the pipes. Valves are considered active mitig ation systems.

4.3 AL TERN AT IVE RE LEA SE SC ENA RIOS

There are only a few required assumptions for the alternative scen ario analysis. Exhibit 4-4 summariz es the required assum ptions.Chapter 4
4-13 Offsite C onse que nce A nalysis



### EXHIBIT 4-4 REQUIRED P AR AM ETERS FOR M ODELING A LTERNA TIVE SCENA RIOS

Endpoints � For toxic substa nces, use the endpoi nts specifie d in part 68, Appendix A. 

### � For flamm able substances, use as the endpoints:

< Overpressure of 1 pound per square inch (psi) for vapor cloud explosions,

< Radian t heat o f 5 kil owatts per squ are m eter (k W/m 2 ) (or equivalent dose ) for fireballs or pool fires, or

< Lower flamm ability limit (LF L) for vapor cloud fires.

Wind sp eed/sta bility 

### � Use typical m eteorological conditions at your site.

Ambient tempera ture/hu midity 

### � Use average temperature/hum idity data gathe red at your site or at a local meteorolo gical station.

Height of release 

### � Release height m ay be determ ined by the release scenario.

Topography 

### � Use urban or rural topo graphy, as appropriate.

Dense or neutrally b uoyant gases 

### � Tables or mode ls used for disp ersion o f regu lated to xic sub stances must approp riately

accoun t for gas densit y.

Temperature of released sub stance 

### � Substan ces m ay be conside red to b e releas ed at a process or am bient te mpera ture tha t is appropriate for the scenario.

A CCEPTABLE A LTERNATI VE S CEN AR IO S

Your al ternativ e scena rio for a cover ed Prog ram 2 or 3 pr ocess m ust be o ne that is more likely to occur than the w orst-case scenario and that reaches an end point offsite, unless no such s cenario exists. You d o not need to dem onstrate greater likelihood of occurrenc e or carry out any analysis of probab ility of occurrence; y ou only nee d to use reason able j udgement a nd knowle dge of th e proce ss. If, usi ng a combination of rea sonable assumption s, modeling of a release of a reg ulated substance from a process shows that the relevant endpoint is n ot reached offsite, y ou can use the mo deling results to dem onstrate that a scenario does not exist for the
process that wi ll giv e an end point o ffsite. Even in that instanc e, yo u still m ust repo rt an alternative scenario (i. e., one with an o nsite endpoint) for Prog ram 2 and 3 processes. Alternative scenarios are not required fo r Program 1 processes.Chapter 4 Offsite C onse que nce A nalysis 4-14

Releas e scena rios you should consid er inc lude, b ut are not limi ted to, the fol lowing, where applicable:



### � Tran sfer h ose rel eases due to sp lits o r sudde n uncou pling;



### � Process piping releases from failures at flang es, joints, welds, va lves and valve seals, and drains or bleeds;



### � Process vessel or p ump releases due to cracks, seal failure, drain bleed, or plug failure;



### � Vessel overfilling and spill, or overpressuriz ation and venting through relief valves or rup ture disks; and



### � Shipping container mishandling and breakage or puncturing lead ing to a spill.

For alternative release sce narios, you m ay consider activ e mitigation s ystems, su ch as interlocks, shutdo wn system s, pressure relieving devices, flares, em ergency isolation system s, and fire water and deluge system s, as well as passiv e mitigation systems. Mitigation system s considered mus t be capable of withstand ing the even t that trig gers t he relea se whil e rem aining functio nal.

You should consider your five- year accident history and failure scenarios identified in your haza rd review or proce ss hazards analy sis in selecting alternativ e release scenarios for regulated toxic or flamm able substances (e.g ., you m ight choose an actual event from your accident histo ry as the basis of your scenario). Y ou also may consider any other reasonable scenarios.

The alternative scenarios y ou choose to analy ze should be scen arios that you consider possible at y our site. Althoug h EPA requires no explanation of your choice of scen ario, y ou shou ld choo se a sce nario th at you think you c an expl ain to
emergency responders and the pu blic as a reasonable alternativ e to the worst- case scenario. For exam ple, you could pick a scenario base d on an actual ev ent, or you could c hoose a scenari o that y ou worr y abo ut, bec ause cir cumst ances a t your site mak e it a po ssibility

. If you b elieve that th ere is n o reaso nable sc enario t hat cou ld lead to offsite consequences, you m ay use a scenario that has no offsite im pacts for your alternative analysis. You should be prepared to e xplain your choice of such a scenario to the public (as well as to the im plementing a gency), sho uld questions arise.

A LTERNATI VE R ELEASES OF T OXIC S UBSTANCES

To estimate distances to the endpoint for alternativ e releases of toxic substance s, you need to identify reaso nable scenarios for the reg ulated substances in cov ered processes at your site and model these scenarios using appro priate models. As noted above , for al ternativ e releas e scena rios, y ou are p ermitt ed to ta ke cre dit for b oth passi ve and act ive mitiga tion sys tems, if both ar e in pla ce. Mod eling al terna tive releases of to xic substances is discussed bel ow.Chapter 4
4-15 Offsite C onse que nce A nalysis

Although alternativ e scenarios are intended to be more lik ely than worst- case scenarios, the analys is of alternative scenarios should not be expected to provide realistic estimates of areas in which the pub lic mi ght be endang ered in case of a release. The same conservative, protective endpoints are used for alternative re lease analysis as for wors t-case analy sis. These endpoints are inte nded to represent exposure levels below which most members of the public will not su ffer any serious health effects. The endpoints are based on exposures for longer periods tha n may b e likely in an a ctual re lease. In a ddition , mo deling carried out to estim ate dist ances to these endpoints, ev en when based on more realistic assum ptions than used for the
worst-case m odeling, likely will provide results with a high deg ree of uncertainty. These estimated distances should not be considered a necessarily accurate prediction of the results of an actual release.

M ODELING A SSUMPTIONS

Quantity. EPA has not s pecified any assum ptions you m ust make concerning quantity released for an alternative release scenario

. You could con sider any site-specific factors in developing a reasonable estimate o f quantity released (e. g., the qua ntity that cou ld be re leased f rom a sheared pipe in the tim e it wou ld tak e to shut off flow to the pip e).

Release Height. You may assume any appropriate release heig ht for your alternative scenarios. For example, you may analyze a scenario in which a reg ulated substance would be relea sed at a height w ell above gro und level.

Wind Speed and Atmospheric Stability. You should use typical meteoro logical conditions at your site to model alternativ e scenarios. To determ ine typical conditi ons, y ou ma y need to obta in local mete orolog ical dat a that a re appli cable to your site. I f you do not k eep weather data for y our site (most sou rces do not), yo u may call an other nearby source, such as an airport, o r a compiler, su ch as the National Weather Service , to determine w ind speeds for yo ur area. Your airport or other so urce wi ll be ab le to g ive y ou info rmatio n on clo ud cov er.

E

STIMATI NG R ELEASE R ATES

Toxic Gases. To estimate a release rate for toxic gases, you may make an y appropr iate ass umpti ons bas ed on c onditio ns at y our site and us e any appropr iate model. EPA 's RMP Offsite Consequence Analysis Guidance provi des a si mple
equa tio n and chemi cal -spec ifi c dat a for esti mati ng the rele ase r ate of a ga s fro m a hole in a vessel o r pipe based on hole size, tank p ressure, and chem ical properties. The siz e of the hole m ight b e estim ated fro m, fo r exam ple, th e hole s ize th at woul d result from shearing off a valve or pipe from a vessel.

Tank or pipe dam age or failure resulting in the release of a g as liquefied under pressure migh t be an appropriate alternativ e scenario at som e sites. If s uch a release would b e possib le at y our site , you may need to consid er a m odel or metho d that w ill deal with this type of scenario.

You als o shoul d consi der the duratio n of the release

. EPA does n ot requi re you to assume any specific time period for the release. You could estimate the releaseChapter 4 Offsite C onse que nce A nalysis 4-16

duratio n based on the length of tim e it wou ld tak e to sto p the re lease, o r you could estim ate a m aximu m dur ation ba sed on a calcul ated rel ease rat e and th e quant ity in the tank or pipe s. I f you estim ate that a releas e of tox ic gas would be stop ped v ery quickly, resu lting in a "puff" rather th an a plume, you may want to use a m odel that deals with puff releases. EPA's RMP Offsite Consequence Analysis Guidance is not appropriate for estimating distance to an endpoin t for puff releases. EP A provides inform ation on vario us othe r mod els, inc luding those s uitable for anal ysis o f puff releases, at the Support C enter for Regulatory Air Models: http://w ww.ep a.gov /scram 001//.

You may consider both passiv e and active m itigation in estim ating release rates. F or gases, passiv e mitigation m ay include enclosed spaces. Active mitigation for gases may include an asso rtmen t of tech niques includi ng au tomat ic shuto ff valv es, rap id transfer systems (emergency drainage), and w ater/chemical spray s. These mitig ation techniques have the effect of reducing either the release rate or the duration of the release, or both. EP A's RMP Offsite Consequence Analysis Guidance includes methods of acco unting for m itigation. You a lso may u se your kn owledge or other methods to accou nt for mitigation

.
Toxic liquids. For alternative releas es of toxic liquids, y ou may consider any scenario that would be reasonable for your site. For alternative relea se scenarios, you
are perm itted to take credit f or both passiv e and ac tive m itigati on sy stems , or a combination if both are in place. For liquids, passive m itigation may include techniques such as dik es and trenches. Ac tive mitig ation for liquids ma y include an assortment of techniq ues including autom atic shutoff valve s, emergen cy drainage, foam or tarp cov erings, and water or chemical spray s. These mitig ation techniques have the effect of red ucing either the qua ntity released into the pool or the evaporation rate from the pool. EPA 's RMP Offsite Consequence Analysis Guidance discusses some m ethods of accounting for mitigation

.

E

STIMATI NG D ISTANC E TO THE E NDPOINT

For alte rnativ e releas es, y ou ma y use any ap propria te mo del (as discuss ed in 4. 1) to estim ate the distanc e to the specifi ed endp oint for an alte rnativ e releas e of a regulated toxic substan ce. You m ay use site- specific conditions, including typical weather conditions, and consider any site- specific factors appropriate to y our scenario. You m ust use the endpoints sp ecified in part 68 Appen dix A, as for the worst-case analy sis.

A LTERNATI VE R ELEASES OF F LAMMABLE S UBSTANCES

Alterna tive re lease sc enarios for flam mable substan ces are somew hat m ore complicated than fo r toxic substances because the consequences of a release and the endpoint of concern m ay vary

. For the worst ca se, the consequence o f concern is a vapor cloud explo sion, with an ov erpressure endpoint. Fo r alternative scenarios involving fires rather than explosions, other endpoints than o verpressure (e.g ., heat radiation) may need to be considered

. The rule specifies endpoin ts for fires based on the heat radiation level that may c ause second degree burns from a 40-second exposure and the lowe r flammability limit (LFL), w hich is the lowest conce ntrationChapter 4
4-17 Offsite C onse que nce A nalysis

in air at which a substa nce wil l burn. Som e possib le scena rios inv olving flamm able substances ar e discussed belo w.



### � Vapor cloud fires (flash fires) may result from dispersio n of a cloud of flamm able v apor an d igni tion of the clou d follow ing di spersio n. Suc h a fire could fl ash bac k and could r epresen t a sev ere heat radiatio n haza rd to
anyon e in the area of the clo ud. Vap or cloud fires m ay be mode led usin g air dispersion modeling techniques to estim ate distances to a concentratio n equal to the LFL.



### � A pool fire , with potenti al radia nt heat effects, may result f rom a spill of a flammable liquid. The endpoint for th is type of fire, as listed in the rule, is a radiant heat lev el of 5 k ilowatt s per sq uare m eter (k W/m2) for 40 seconds ; a 40-second ex posure to this heat level could cause second degree burns.



### � A boiling liquid, expanding vapor explosion (B LEVE) , leading to a fireball that may produce intense heat, may occu r if a vessel containin g flammable material ruptures explo sively as a res ult of exposure to fire. Heat radiation from the fireb all is the primary hazard; vesse l fragments a nd
overp ressure from the exp losion a lso can result. BLEVE s are g enerally considered unlikely events; howev er, if you think a BLEVE is possible at your s ite, y ou shou ld estim ate the distanc e at wh ich radi ant hea t effects mig ht lead to secon d deg ree burn s, sinc e that is the effe ct of co ncern underlying the rule’s endpoint for fires. The point of offsite consequence analyses is to determ ine how far away from the point of release effects of concern could occur, s o you should e stimate the distance fo r BLEVEs even thoug h one w ould no t last fo r 40 sec onds. For BL EVEs, y ou wou ld need to estimate the radiant h eat level at which exposure for the duration of the BLEVE would c ause se cond de gree b urns. You the n would need to estimate the distance to that heat lev el. You also m ay want to con sider models or calculation methods to estimate effects of vessel fragm entation, although you are not required to analy ze such effects.



### � For a vapor cloud ex plosion to occur, rapid release of a large quantity of flammable material, turbulent co nditions (caused by a turbulent release or
conge sted con ditions in the a rea of th e releas e, or b oth), a nd othe r factor s are generally necessa ry. Vapor cloud e xplosions generally are considered unlikely ev ents; however, if conditions at your site are conducive to vapor cloud explosions, y ou may want to consider a v apor cloud explosion as an alternative scenario. The 1 psi overpressure e ndpoint still applies to a v apor cloud explosion for purp oses of analyz ing an alternative scenario, but yo u could use less conserv ative assump tions than for the worst- case analysis, includi ng an y reas onable estim ate of th e quant ity in the clo ud and the yi eld factor. A vapo r cloud deflagration, involving lower flame spe eds than a detonation and resulting in less damag ing blast effects, is m ore likely than a deton ation

. You may assu me a vapor cl oud def lagrat ion for the alt ernat ive scenario, if you th ink it is appropriate, and use the radiant heat endpoint (adjusted for dur ation).Chapter 4 Offsite C onse que nce A nalysis 4-18



### � A jet fire may resu lt from the punctu re or rupture of a tank or pipeline contain ing a comp ressed o r liquef ied ga s under pressur e. The g as can form a jet that discharges into the air in the direction of th e hole; the jet then ma y ignite. Jet fires could con tribute to BLEVEs and fireb alls if they im pinge on tanks of flam mable substances. A large horiz ontal jet fire may h ave the potential to pose an offsite hazard. You may wan t to consider a jet fire as an alternative scenario, if ap propriate for your site.

M ODELING A SSUMPTIONS

Quantity. EPA has not s pecified any assum ptions you m ust make concerning quantity released for altern ative scenario analy sis for flamm able substances. You may consid er any site- specific factors in develo ping a reasonable estimate of quantity released, as for toxic substances (e.g ., the quantity th at could be released from a ruptur ed pipe in the t ime it would take t o shut o ff flow to the p ipe).

Release Height. You may assume any appropriate release heig ht for your alternative scenarios for flam mable substances.

Wind Speed and Atmospheric Stability. Meteoro logica l condit ions m ay hav e little effect on some sc enarios for flamm able substances (e.g ., vapor cloud explosions and BLEVEs ), but m ay hav e a relat ively large effect o n others (e.g. , a va por clou d fire resulting from downwind dispersion of a vapor clou d and subsequent ig nition). You should use ty pical m eteorolo gical conditi ons at y our site to mo del app ropriate alternative scenarios. To determine typ ical conditions, you may ne ed to obtain local meteorological data that are applicable to y our site, as discussed ab ove.

E

STIMATI NG R ELEASE R ATES

Flammable Gases. To esti mate a rel ease r ate fo r flammabl e gases, you may make any appropriate assum ptions based on condition s at your site. You may consider the effects of both passiv e and ac tive m itigati on sy stems

. The m ethods provid ed in EPA's RMP Offsite Consequence Analysis Guidance for rate of release of a g as from a hole in a vesse l or pipe for toxic g ases also can be used for flammab le gases. Chem ical- specific data ar e prov ided for flamm able g ases, to be used along with h ole size and tank pressure to estimate release rates.

Flammable liquids. For alternative releas es of flamm able liquids, you may conside r any scenario that wo uld be r easonab le for y our site

. You are per mitted to take c redit fo r both p assive and act ive m itigati on sy stems , or a c ombin ation if both are in place, as for toxic liquids. You could consider release of the liquid into a pool and rele ase to a ir by p ool ev aporatio n, if y ou cons ider thi s to be a reason able scenario.

If evapo ration of a flamm able liquid from a pool is an appropriate assu mption for
your a lternati ve sce nario, you c an use a ny sci entifica lly ap propria te me thod to estimate the ev aporation rate.Chapter 4
4-19 Offsite C onse que nce A nalysis

E

STIMATI NG D ISTANC E TO THE E NDPOINT

You may use any approp riate model to estim ate the distance to the spe cified endpoint for alternative scenarios for regulated flammable substances. Sev eral possible conse quences of relea ses of flammable substanc es are discusse d below.

Vapor cloud fire. You m ay use any a ppropri ate m odel to estim ate dist ances fo r a vapor cloud fire. The LFL endpoint, spe cified in the rule, would be appropriate for vapor cloud fires. You may use air dispersion m odeling to estim ate the maxim um distanc e to the LFL. You m ay wa nt to co nsider, howev er, whe ther it i s like ly tha t a flamm able g as or v apor co uld disp erse to the m aximu m dis tance to the LF L befor e reaching an ig nition source. The actual dis persion distance before ig nition might be much shorter than the maxim um possible distan ce.

Pool fire. Any approp riate model m ay be used for p ool fires of flamm able liquids. The appl icable e ndpoin t specif ied in t he rule is the h eat radi ation le vel of 5 kW/m 2

.

BLEVE. If a fireball from a BLEVE is a potential release scenario a t your site, y ou may use any mod el or calculation me thod to estimate the distance to a radiant heat level that can cause second degree bu rns (a heat "dose" equiv alent to the specified radiant heat en dpoint of 5 k W/m 2 for 40 seconds).

Vapor cloud ex plosion. If y ou have the po tential at your site for the rapid release of a large quantity of a flamm able vapor, particularly into a congested area, a vapor cloud explosion m ay be an approp riate alternative release scena rio. For the alternat ive an alysis , you may estim ate any reason able qu antity of flam mable substance in the va por cloud. The endpoin t for vapor cloud explosions is 1 psi, as for th e worst case; however, a smalle r yield f actor may be used f or the a ltern ative scenario analysis.

N UMBE R OF S CEN AR IO S

You are required to an alyze at least o ne alternative release scen ario for each listed toxic su bstance you h ave in a Prog ram 2 or Prog ram 3 proces s abov e its thr eshold quantity. I f you have the same substa nce above the thre shold in several pro cesses or location s, yo u need only a nalyz e one al ternativ e scena rio for i t. You also ar e required to analyz e one alter native relea se scen ario r epres entin g all regulated flammable substances in Progra m 2 or 3 pro cesses; you do n ot need to analyz e an alternative scenario for eac h flammab le substance above the threshold. For ex ample, if you have five listed substances — chlorine, amm onia, hydrog en chloride, propylene, and a cetylene — abov e the threshold in Prog ram 2 or 3 p rocesses, you will need to analyze one alternative scen ario each for chlorine, am monia, and hydrogen ch loride (toxics) and a sing le alternative scenario to cover propylen e and acetyl ene (fla mm able sub stances ).

No al ter nat ive s cena rio anal ysis is re quir ed fo r reg ula ted subs tan ces i n Pro gram 1
process es. I f worst- case sce nario an alysis for a p rocess s hows n o publi c recept ors within the distance(s) to the applicable endpoint(s), and the process meets the other Program 1 criteria, you do not have to carry out an alternative sc enario analysis for the process.Chapter 4 Offsite C onse que nce A nalysis 4-20

In addition, no alternative scenario analysis is required for any process that do es not conta in more th an a thr eshol d quant ity of a r egulat ed subs tance , even if you beli eve such a process is a lik ely source of a relea se.

4.4 ESTIMATING OFFSITE RECEPTORS

The rule requires that you include in your RMP an estimate of the residential populations within the g eographical areas that c ould be affected by the hypothetical
worst-case or alternative releases y ou have analy zed. The geo graphical area is the area wi thin t he cir cle def ined by t he endp oint f or your wo rst-cas e and al terna tive release scenario s (i.e. , the ce nter of the circ le is the point o f releas e and th e radius is the distance to the endpo int). In ad dition, you m ust report in the RMP w hether certain types of pub lic receptors and env ironmental receptors a re within the circles.

R ESIDENTIAL P OPULATIONS

To estimate residential pop ulations, you m ay use the m ost recent Census data o r any other so urce of data tha t you believ e is m ore accu rate. Y ou are n ot requi red to update Census data or conduc t any surve ys to devel op yo ur estim ates. C ensus d ata are available in public libraries and in the LandView system, which is available o n DVD (see box below). T he rule require s that you estimate popula tions to two significant digits. For example, if there are 1,260 peo ple within the circle, y ou may report 1,300 people. If the num ber of people is between 10 and 100, estim ate to the
nearest 10. I f the nu mber of peop le is les s than 1 0, prov ide the actual n umbe r.

Census data are presented by Census tract. If y our circle covers only a portion of the tract, y ou shou ld dev elop an estim ate for t hat port ion. Th e easies t way to do t his is to determine the p opulation density per square mile (total po pulation of the Census tract div ided by the num ber of s quare m iles in t he tract ) and ap ply th at densi ty fig ure to the number o f square miles w ithin your circle. B ecause there is likely to be considerable variation in actual densities within a C ensus tract, this num ber will be approxi mate. The rule , howe ver, d oes not require you t o correc t the nu mber.

O THER P UBLIC R ECEPTORS

Other p ublic re ceptors must be note d in the RMP (se e the di scussio n of pu blic receptors in Chapter 2). If there are a ny schools, residen ces, hospitals, prisons, public recreational areas or aren as, or comm ercial or industrial areas within the circle, you m ust repo rt that. You a re not r equired to dev elop a l ist of al l public receptors; you m ust simply check off that one or more such a reas is within the circle. Most receptors can be identified from local street m aps.

E NVIRONM ENTAL R ECEPTORS

Environmen tal receptors are defined as n atural areas such as national or state parks, forests, or monu ments; officially designated wildlife san ctuaries, preserves, refu ges, or areas; and Federal w ilderness areas. Only environme ntal receptors that can be identified on local U.S. Geological Surv ey (USGS) m aps (see box below) n eed to be conside red. Y ou are n ot requi red to l ocate ea ch of th ese spe cifically

. You are onl y required to check o ff in the RMP which specific types of areas are within the circle.Chapter 4
4-21 Offsite C onse que nce A nalysis

If any part of one of these recep tors is within your circle, you m ust note that in the RMP.

Importa nt: The rule does n ot requi re you to asse ss the l ikelih ood, ty pe, or severi ty of potential impacts on either public or env ironmental receptors. Identifyin g them as within the circle sim ply indicates that they could be adverse ly affected by the release.



### H OW TO 

### O BTAI N 

### C ENSUS 

### D ATA AND 

### L AND 

### V IEW 

### ®

Census data can be fo und in publications of th e Bureau of the Cen sus, available in p ublic libraries, inclu ding County and City D ata Book

.

LandView ® is a desk top mapping system tha t includes database extracts fro m EPA, th e Bureau of the Census, the U. S. Geological S urvey. These d atabases are presented in a geographic co ntext on maps that show jurisdictional boundaries, detailed n etworks of roads, rivers, and railroads, census block group and tract polyg ons, schools, hospitals, churches, cem eteries, airports, dam s, and other landmark fea tures. LandView lets y ou determine the population within any radius, anywh ere in the U.S.

For PC and Mac . $129 for 2 D VD set, cover s entire country

U.S. Departm ent of Comm erce Bureau of the Census P.O. Box 277 943 Atlanta, GA 30384 -7943 Phone: (301) 763- INFO (46 36) (Customer S ervices -- orders) Phone: (301) 763- 1128 (G eogra phy S taff - - co ntent) http://www.cen sus.gov/geo/landview/

Further information on Census data is av ailable at the Bureau of th e Census web site at

www.cen sus.gov.Chapter 4 Offsite C onse que nce A nalysis 4-22



### H OW TO 

### O BTAI N 

### USGS M APS

The production of digital cartographic data and graphic map s comprises the larg est component o f the USGS Nationa l Mappin g Pro gram

. The U SGS' s mos t fami liar pro duct is the 1:24 ,000- scale Topogr aphic Q uadrang le Map. This is t he prim ary sc ale of d ata prod uced, a nd depi cts gr eater de tail for a smaller area th an intermediate- scale (1:50,000 and 1 :100,000) and sm all-scale (1:250,0 00, 1:2,000,000 or sm aller) products, which sho w selectively le ss detail for larger areas.

To order maps, publica tions, and oth er mis cellaneo us prod ucts on paper a nd com pact dis c med ia from the USG S by m ail, send your o rder form and p ayment to:

USGS I nformation Serv ices Box 25286 Denver, CO 80225

By fax, call 30 3-202- 4693 and transm it the order form.

To order digita l map s, dig ital cart ograp hic and geog raphic d ata, ae rial pho tograp hs, and satellit e imag ery pr oducts from the USG S by m ail, sen d you r order form and pay ment to: USGS EROS Data Center 47914 252nd Street Sioux Falls, SD 5 7198

By fax, call 60 5-594- 6589 and transm it the order form.

Online, subm it you r order throug h the U SGS on -line orderin g site , The US GS Sto re at: http: //sto re.us gs.gov/

For more inform ation, visit the US GS Earth Science I nformation Center on the Interne t at http://ask.usgs.g ov, or for ordering assistance, call 1- 888-ASK- USGS. For add itional information, contact any USG S Earth Science I nformation Center or call 1-800- USA-MAP S.Chapter 4
4-23 Offsite C onse que nce A nalysis



### Qs and As OFFSIT E CONSEQUENC E ANALYSIS

Q. How c lose m ust a st ationary source be to a weathe r station for tha t station 's d ata to b e applic able to the stationary sourc e?

A. EPA ha s not se t specif ic dista nce lim its, bu t will a llow ow ners an d opera tors to use reas onable judgement in dete rmining w hether data from a weather station is applicable to the stationary so urce. Factors such as topog raphy and dis tance b etween the stat ionary source and a w eather s tation s hould be taken into con sideration when ev aluating the applicability of the weather station' s data to the stationary source.

Q. Must ai r disper sion m odels th at are u sed to a nalyz e worst -cas e releas e scena rios be able to account for multiple vessels and how those vessels could impact one anoth er in the event of an accidental release?

A. No. Models used for worst-case release scenario analysis do not need to consider co mpounding effects of accid ental re leases f rom m ultiple vesse ls becau se wors t-cas e releas e is def ined by the rul e as a sin gle v essel or proces s line fa ilure th at will result in the g reatest distanc e to an endpoin t.

Q. If the estim ated population chang es, would the RMP have to be upd ated?

A. No. Chang es in U.S. Cens us data do not necessitate a correction or update of the RMP. However, all u pdates to the RMP shou ld use the most recent U.S. Censu s data.

Q. What if a flamm able ev ent has a differ ent tim e durati on than the 5 k w/m 2 for 40 seconds?

A. EPA recogniz es that flamm able events m ay occur for a differe nt amount of ex posure time. Therefore, the owner or op erator should determ ine the distance to an eq uivalent exposure - e.g. if the flamm able ev ent occ urs for 20 seco nds, de termin e the di stance t o an eq uivale nt expo sure level

.
Q. Could positive bu oyancy m odels be used?

A. Yes, provid ed there is a basis for us e and the owner or operator explains the rationale for use of positive buoya ncy mod els.Chapter 4 Offsite C onse que nce A nalysis 4-24

4.5 Examples of Wors t Case Scen arios



### EXAMPL E < 

### SOURCE A

Source A, a re tail ope ration t hat sup plies am monia , has o ne cov ered pro cess: a 200- ton am monia storage tank. Source A carries out worst-case con sequence analyses fo r this process, with the following results: For 400,000 pounds o f anhydrous am monia, the distan ce to the specified endpo int (0.14 mg /L) is estimated as more than 10 miles.

Residences and a busin ess center are located within 0.15 miles o f the facility; therefore the regulated
process is not e ligibl e for Pr ogram 1. So urce A must report t he resu lts of th e worst -cas e analy sis in the RMP.



### EXAMPL E < 

### SOURCE B

Source B is a m edium- sized metal p roducts manufacturer with two processes con taining regulated toxic su bstance s abov e their t hreshol ds: a ta nk sto ring 5 0,000 pounds of 37 p ercent h ydroc hloric a cid for use in plating p rocesses and five interc onnected, one- ton tanks of chlorine used in a wastewater treatment plant. O nly one worst- case analysis is required for toxic substances for P rogram 2 and Program 3 processes; because of the greater toxicity and volatility of chlorine, Source B ex pects that
a worst-case re lease of chlorine would result in the greatest dista nce to the endpoint. Source B does not beli eve th e hyd rochlor ic acid process would be elig ible for Prog ram 1 becaus e of the proxim ity of public receptors (including workers at an a djacent industrial facility), and, therefore, only carries out the worst- case an alysis for the chlorin e proce ss. A distanc e of 2. 80 mi les to th e endpo int is estimated for a release of 2,000 pounds o f chlorine. Since there are public receptors within that distance, Source B m ust report this worst- case analysis in the RMP.

EXAMPLE < SOURCE C

Source C is an inorg anic chemical m anufacturer with two cov ered processes: a tank containing 10 tons of 70 percent hy drofluoric acid solution and ten one-ton tan ks of chlorine on a rack for
wastew ater trea tment

. Sour ce C m ust carr y out one wo rst-c ase ana lysis for reg ulated t oxic substances for Progra m 2 and Pro gram 3 p rocesses. Because the toxic endpoint of chlorine is lower than that of hydroflu oric acid, and because the release rate will probably be greater for a g as than a solution , Sourc e C dec ides to carry out the analy sis for c hlorine as the r equired worst- case an alysis for toxi c sub sta nces

. Sour ce C b eli eves the h ydro flu ori c aci d pro cess may be e ligi ble for P rogr am 1 and, therefore, decides to do a worst- case analysis for this process as well. Re sults of the worst- case analyses for these two processes are:



### � 2.80 miles for 2,000 pounds of c hlorine 

### � 1 mile for 20,0 00 pounds of 70 p ercent hydrofluoric acid (released in a diked area)

Home s and b usiness es are lo cated le ss than a mile from either p rocess; therefor e, neith er proce ss is eligible for Prog ram 1. Sou rce C must rep ort the results of the worst- case analyses for chlo rine.Chapter 4
4-25 Offsite C onse que nce A nalysis



### EXAMPL E < 

### SOURCE D

Source D is a l arge c hemic al ma nufactu rer with 11 reg ulated s ubstanc es abov e their t hreshol d quantities, including th ree flammab le substances and eig ht toxic substances. The p rocesses containing flam mable substances are: three 18,000- gallon tanks c ontaining 26,000 pounds of ethylene, 66,000 pounds of propy lene, and 65,000 pounds of propane; the propane, howev er, is used as a fuel and is not su bject to the rule. The largest quantities of toxic substances in processes are: 25,000 pounds of toluene diisocyanate (TDI ), 100,000 pound s of chloroform, 25,000 pounds of anhydrous hy drogen chloride, 2 0,000 pounds of c hlorine, 80,000 pou nds of epichlorohyd rin, 100,000 pounds of meth yl chloride, 10,0 00 pounds of hy drogen cyan ide, and 1,000 po unds of phosgen e. For the RMP , Sourc e D has to repo rt one w orst- case an alysis for flam mable substan ces and one for toxic substances; howeve r, Source D believ es the processes containing flammable substances may be eligible for Prog ram 1 and, th erefore, chooses to carry out a worst- case analysis for each of these
processes. I n addition, Source D believes the process es containing TDI and chloroform may be eligible for Prog ram 1, because of the low vo latility of TDI and the relatively low toxicity of chloroform, and decides to carry out analyses to determ ine eligibility. Source D is not sure which of the othe r proces ses con taining toxic s ubstanc es will give the g reatest distanc e to the endpoi nt; therefore, it conducts screenin g analyses for all these processes. The w orst-case distances for vapor cloud explosions of the flammable substances are: 

### � 0.24 miles for 26,000 pounds of ethylene; 

### � 0.32 miles for 66,000 pounds of propylene.

The worst-case distan ces to the endpoints for the toxic substances are: 

### � 0.06 miles for 2 5,00 0 pou nds o f TD I; 

### � 0.49 miles for 1 00,0 00 po unds of ch lor ofor m; 

### � 4.8 miles for 2 5,000 pounds of h ydrogen chlo ride; 

### � 10 miles for 20, 000 pounds of chlorine ; 

### � 2.2 miles for 8 0,000 pounds of e pichlorohydrin; 

### � 2.0 miles for 1 00,000 pounds of methyl chlorid e; 

### � 5.2 miles for 1 0,000 pounds of h ydrogen cy anide; and 

### � 11 miles for 1, 000 pounds of pho sgene.

The processes containing ethylene and propy lene are located 500 y ards (0.28 miles) from a river (0.5 miles wide). The dis tance to the end point fo r these two pro cesses d oes not extend beyo nd the r iver, which is not a recreational area; the processes are elig ible for Program 1 (having met the other criteria). The distances to the en dpoint for the TDI process do not reach public receptors in any direction; therefore, this process is also eligible for Pro gram 1.

Source D repor ts the w orst- case an alysis results for eth ylene , propy lene, a nd TDI to dem onstrate eligibility for Prog ram 1. Sinc e propylene was the “worst” worst- case scenario for all reg ulated flamm ables at the fac ility, the sou rce doe s not ha ve to report a ny oth er wors t-cas e scena rio resu lts for flam mable substan ces. The source does re port the results for phosg ene as the required wo rst-case analysis for toxic sub stances.Chapter 4 Offsite C onse que nce A nalysis 4-26

4.6 Examples of A lternative Re leases



### EXAMPL E < 

### SOURCE A

Source A, a retail op eration that supplies am monia and prop ane, has one cov ered process: an

amm onia sto rage t ank co ntainin g 400 ,000 p ounds o f anhy drous a mm onia (a regula ted toxi c substance). The worst- case consequence analy ses for this process indicated it is not eligible for Program 1

. Source A m ust carry out and report an alternative scen ario analysis for the p rocess. Any

reasona ble and defens ible sce narios c an be an alyz ed for t he proc ess, pr ovide d they are m ore lik ely than the worst- case scenario and reach a n off-site endpo int (unless no such scena rio exists). The source must be able to explain its choice o f scenarios.



### EXAMPL E < 

### SOURCE B

Source B is a m edium- sized metal p roducts manufacturer with two covered processes containing regulated toxic substan ces: a chlorine wastewater treatment plant with 10,000 pounds of chlorine and a tank contain ing 50 ,000 p ounds o f 37 per cent hy drochlo ric acid

. Beca use of t he prox imity of pub lic receptors, neither of these p rocesses is eligible for P rogram 1. Source B m ust carry out and report an alternative scenario analy sis for each of the tw o regulated substance s. Source B m ay analyz e any scenario s that a re reaso nable fo r the sit e and p rocesse s, prov ided the y are more likely than th e worst

case scenario and reach a n off-site endpo int (unless no such scena rio exists). The source m ust be able to explain its choice o f scenarios.



### EXAMPL E < 

### SOURCE C

Source C is an inorg anic chemical m anufacturer with two cov ered processes, one con taining 20,000 pounds of chlorine and the other containing 20,000 pounds of 70 percent hydrofluo ric acid. Source C’s worst-case analyses indicated th at these processes are not eligible for Prog ram 1. Sou rce C must carry out and repo rt an alternative scenario analysis for each of these substances. The scena rios must be mo re like ly tha n the w orst- case sce nario an d reach an off- site end point (u nless no such sc enario exists). Within these constraints, the scenarios ma y be develo ped based on any reasonable and defensible assumption s. The source m ust be able to explain its choice of scenarios.Chapter 4
4-27 Offsite C onse que nce A nalysis



### EXAMPL E < 

### SOURCE D

Source D is a larg e chemical m anufacturer with cove red processes containing two regulated flammable substances and eigh t regulated toxic subs tances. The worst- case analyses show ed that the processes containing the flamma ble substances (ethylen e and propylene) are eligible for Prog ram 1. For flamm able substances, Source D need not carry out and report an alterna tive scenario analy sis.

The worst-case ana lyses showed that the process containing 25,000 pounds o f the toxic substance toluene diisocy anate (TD I) al so is el igible for Pro gram 1; ther efore, Source D does not nee d to car ry out an a ltern ative sc enari o analys is for TDI. Sourc e D must car ry out an d repor t an alt ernat ive scenario analysis for ea ch regulated toxic su bstance in a covere d non-Prog ram 1 process; th us,

scena rios mus t be deve loped and anal yzed for hyd rogen ch lorid e, chlo rine, epichl orohydr in, methyl chloride, hydrog en cyanide, chloro form, and pho sgene. I f the substances are found in more than one vessel , the an alysis should be condu cted wi th res pect t o the ves sel th at pre sents the grea test r elati ve risk o f a relea se. An alyses of each vesse l are no t neede d. Sou rce D ca n dev elop an y reas onable scenario s for th ese sub stances that are more likely than th e worst -cas e scena rio and reach an off- site endpoint (unless no such scenario exists), and m ust be able to explain its choice of scenario.

## CHAPTER 5: MANAGEMENT SYSTEM

5.1 G ENERAL INFORMATION (§68.15)

If y ou have at least one Program 2 or Program 3 process (see Chapter 2 for guidance on determ ining the Program levels of y our processes), the m a nagem e nt sy stem provision in § 68.15 requires y ou to:

Develop a m a nagem e nt sy stem to oversee the im plem entation of the risk

m a nagem e nt program elem ents;

Designate a qualified person or position with the overall responsibility for the developm ent, im plem entation, and integr ation of the risk m a nagem e nt program elem ents; and

Docum e nt the nam es of people or positions and define the lines of authority through an organizational chart or other sim ila r docum ent, if y ou assign responsibility for im plem enting individual requirem e nts of the risk m a nagem e nt program to people or positions other than the person or positi on with overall responsibility for the risk

m a nagem e nt program

.

A BO UT THE M AN AG E M E N T S YSTEM P RO VI SI O N

Managem e nt com m itm ent to process safety is a critical elem ent of any facility ’ s risk

m a nagem e nt program

. Since the program requires ongoing im plem entation of accident prevention and em ergency response m easures, m a nagem e nt com m itm ent does not end when the risk m a nagem e nt plan is subm itted to EPA. For process safety to be a constant priority , facility personne l m u st rem a in com m itted to every elem ent of the risk m a nagem e nt program

. By satisfy ing the requirem e nts of this provision, y ou are ensuring that:



### — The risk m a nagem e nt program elem ents are integrated and im plem ented on an ongoing basis; and



### — All groups within a source understand the lines of responsibility and

com m unication.

5.2 H OW TO MEET THE MANAGEMENT SYSTEM REQUIREMENTS

Sources covered by this rule are diverse, so y ou are in the best position to decide how to appropriately im plem ent the risk m a nagem e nt program elem ents at y our facility

. Therefore, the rule provides considerable flexibility in com p ly ing with its program requirem e nts.

W HA T D O ES T HI S M EA N FO R M E A S A S MA LL F A C ILITY ?

As a sm all facility that m u st com p ly with this provision, y ou m o st likely have one or two Program 2 or 3 processes. To begin, y ou m a y identify either the qualified person or position with overall responsibility for im plem enting the risk m a nagem e nt program elem ents at y our facility

. As a sm all facility , it m a y m a ke sense and beChapter 5 Managem e nt System 5-2

practical to identify the nam e of the qualified person, rather than the position. Recognize that the only elem ent of y our m a nagem e nt sy stem that y ou m u st report in the RMP is the nam e of the qualified pe rson or position with overall responsibility

. Further, changes to this data elem ent in y our RMP do not trigger a special update of
y our RMP (although such changes m u st be reflected in RMP updates subm itted for other reasons - see Chapter 9 for m o re inform ation on RMP updates).

Identification of a qualified individual or position with overall responsibility may be all you need to do if the person or position nam e d directly oversees the

em ploy ees operating and m a intaining the processes. You m u st define the lines of authority with an organizational chart or sim ilar docum ent only if y ou choose to assign responsibility for specific elem ents of the risk m a nagem e nt program to persons or positions other than the pers on with overall responsibility

. For a sm all facility , with few em ploy ees, it is likely that y ou will m eet the requirem e nts of this provision by identify i ng the one person or position with the overall responsibility of im plem enting the risk m a nagem e nt program elem ents. If this is the case, y ou need not develop an organizational chart.

Even if y ou m eet the requirem e nts of this section by nam i ng a single person or position, it is im portant to recognize that the person or position assigned the responsibility of overseeing im plem entation m u st have the ability and resources to ensure that y our facility and em ploy ees carry out the risk m a nagem e nt program , particularly the prevention elem ents, on an continuing basis. Key to the effectiveness of the rule is integrated m a nagem e nt of the program elem ents.

W HA T D O ES T HI S M EA N FO R M E A S A M EDIUM O R L AR G E F A C ILITY ?

As a m e dium or large facility y ou m a y ha ve m o re personnel turnover than sm aller sites. For this reason, it m a y m a ke m o re sense at y our facility to identify a position, rather than the nam e of the specific pe rson, with overall responsibility for the risk

m a nagem e nt program elem ents. Rem e m b er that the only elem ent of y our

m a nagem e nt sy stem that y ou m u st report in the RMP is the nam e of the qualified person or position with overall responsibility

. Also note that changes to this data elem ent in y our RMP do not require y ou to update y our RMP.

As a relatively large or com p lex facility , y ou m a y choose to identify several people or positions to supervise the im plem entation of the various elem ents of the program ; therefore, y ou m u st define the lines of authority through an organizational chart or sim ilar docum ent. Further, m o st large facilities already have likely developed and

m a intained som e ty pe of docum entation defining positions and responsibilities. Any internal docum ents y ou currently have s hould be the starting point for defining the lines of authority at y our facility

. You m a y find that y ou can sim p ly use or update current docum ents to satisfy this part of the m a nagem e nt sy stem provision. Exhibit 5-1 provides a sam ple of another ty pe of docum entation y ou m a y use in addition to or as a replacem ent for an organization chart.

Defining the lines of authority and roles and responsibilities of staff that oversee the risk m a nagem e nt program elem ents will help to:



### — Ensure effective com m unication about process changes between divisions;Chapter 5 5-3 M anagem ent System



### — Clarify the roles and responsibilities related to process safety issues at y our facility ;



### — Avoid problem s or conflicts am ong th e various people responsible for im plem enting elem ents of the risk m a nagem e nt program ;



### — Avoid confusion and allow those res ponsible for im plem entation to work together as a team ; and



### — Ensure that the program elem ents are integrated into an ongoing approach to identify i ng hazards and m a naging risks.

Rem e m b er that all of the positions y ou identify in y our docum entation will report their progress to the person with overall responsibility for the program

. However, nothing in the risk m a nagem e nt program rule prohibits y ou from satisfy ing the

m a nagem e nt provision by assigning process safety com m ittees with m a nagem e nt responsibility , provided that an organizati onal chart or sim ilar docum ent identifies the nam es or positions and lines of authority

.Chapter 5Management System5-4EXHIBIT 5-1SAMPLE MANAGEMENT DOCUMENTATIONPositionPrimary ResponsibilityChangesResponsibility re: ChangesOperations ManagerDeveloping OPsOversight of operationOn-the-job trainingOn-the-job competency testingProcess Safety InformationSelecting participants for PHAs,incident investigationsDevelop management of change andpre-startup proceduresNew EquipmentNew Process ChemistryNew Process ParametersNew ProceduresChange in Process UtilizationInformhead of trainingInformhead of maintenanceInformlead for PHAsInformhazmat teamas neededInformcontractorsTraining SupervisorDevelop, track, oversee operatortraining programTrack competency testingSet up and track operator refreshertrainingSet up training for maintenanceWork with contractorsNew EquipmentNew Process ChemistryNew Process ParametersNew ProceduresChange in Process UtilizationNew regulatory requirementsRevise training and refresher trainingcoursesRevise maintenance courses, asneededInformother leads of need foradditional trainingMaintenance SupervisorDevelop maintenance schedulesOversee and document maintenanceRevise schedules as neededNew EquipmentNew Process ChemistryNew Process ParametersNew ProceduresChange in Process UtilizationInformoperations manager ofpotential problemareasInformtraining supervisor of anytraining revisionsInformcontractorsRevise schedulesHazmat TeamChiefDevelop and exercise ER planTrain respondersTest and maintain ER equipmentCoordinate with public respondersSelect participants in accidentinvestigationsNew EquipmentNew Process ChemistryNew Process ParametersNew ProceduresChange in Process UtilizationNew regulatory requirementsRevise the ER plan as neededInformoperations manager ofproblems created by changesWork with training supervisor torevise training of teamand others5-5Chapter 5Management SystemEXHIBIT 5-1SAMPLE MANAGEMENT DOCUMENTATIONPositionPrimary ResponsibilityChangesResponsibility re: ChangesHealth and Safety OfficerOversee implementation of RMPDevelop accident investigationproceduresOversee compliance auditsDevelop employee participationplansConduct contractor evaluationsTrack regulationsNew EquipmentNew Process ChemistryNew Process ParametersNew ProceduresChange in Process UtilizationNew regulatory requirementsInformall leads of new requirementsand assign responsibilitiesEnsure that everyone is informed ofchanges and that changes areincorporated in programs as needed

## CHA PTE R 6: PR EVENT ION PR OGRA M (PROG RA M 2)

6.1 ABO UT TH E P RO GR AM 2 PR EV EN TI ON PR OG RAM

Most Program 2 processes are likely to be relatively simple and m ay be located at small businesses. EPA develop ed the Program 2 prevention pro gram by identifying the basi c elem ents tha t are the founda tion of sound p reven tion pra ctices — safety information, haz ard review, operatin g procedures, trainin g, mainten ance, compliance audits, and accident inv estigation. By meeting o ther Federal regulations, state laws, indus try code s and st andar ds, and good engin eerin g practi ces, you p robabl y have already addressed m ost Program 2 prevention elem ents.

As important as each of the eleme nts is, you will not gain the full be nefit from them unless you integ rate them into a risk managem ent system that you im plement on an
on-g oing b asis. For exa mple, your hazard revie w mu st be bu ilt on th e safety information y ou compile; the results of the hazard review should be used to revise and upd ate yo ur oper ating and m aintena nce pro cedures ; work ers m ust be t rained i n these procedures and m ust use them ev ery day.

You will have substantially less docum entation and record k eeping responsibilities for a Program 2 process than y ou will for a Prog ram 3 process. In addition, EPA has worked with v arious industry sectors to develop industry -specific m odel risk
managem ent program s for Program 2 and 3 processes (a ppended to this g uidance). The industry-sp ecific guidance helps by sugg esting standard elem ents for the sector tha t EPA expe cts woul d be a ppro pri ate for p art icu lar busi ness es in the s ect or. If there is an industry- specific appendix for y our sector, you should use that information to supp lement this g uidance.

There are seven elem ents in the Pro gram 2 prev ention p rogram , which is set f orth in the Part 68 regulation s at Subpart C.. Exhibit 6-1 of this guidance sets out each of the seven elem ents and corresponding section numbers.

You must integ rate these seven elem ents into a risk m anagement program tha t you and your staff im plement on a d aily basis. Und erstanding and m anaging risk s must be part of the way you operate. Doing so will p rovide benefits bey ond accident prevention. Prev entive mainten ance and routine inspection s will reduce the num ber of equipment failures and down tim e, and well- trained workers, aw are of optimum operating param eters, will allow y ou to gain the m ost efficient use of yo ur processes and raw materials.

6.2 SAF ETY INFORMA TION (§ 68.48 )

The purpose of this requirem ent is to ensure that y ou understand the safety -related aspects of the equipm ent and processes y ou have, k now what lim its they place on your operations, an d adopt accepted standard s and codes where th ey apply. Having up-to-date safet y informa tion ab out your proces s is the founda tion of an effe ctive prevention prog ram. Many elements (especially the hazard rev iew) depend on the accuracy and thorou ghness of the inform ation this element req uires you to prov ide.Chapter 6 Preven ti on Progr am (Progr am 2) 6-2



### EXHIBIT 6-1 SUMMARY OF PROGR AM 2 PREVENTION PROGRAM

Number Section Title
§ 68.48 Safety Information
§ 68.50 Hazard Rev iew
§ 68.52 Operating Procedure s
§ 68.54 Trai ning
§ 68.56 Maintenance
§ 68.58 Comp liance A udits
§ 68.60 Incident I nvestigation

W HAT D O I N EED T O D O ?

You must com pile and maintain safety informatio n related to the regu lated subst ances and proc ess equ ipment f or each Program 2 pr ocess

. You prob ably have much of this info rmation already as a result of com plying with OSHA standards or other rules. EPA h as limited the inform ation to what is lik ely to apply to the
process es cov ered un der Pro gram 2. Ex hibit 6- 2 giv es a bri ef sum mary of the s afety information requirem ents for Program 2.

H OW D O I S TART ?

MSDSs. If y ou are s ubject to this ru le, yo u are al so subjec t to the require ments to maintain Material Safety Data Sheets under th e OSHA Haz ard Comm unication Standard (HCS) (29 CFR 1910.1200 ). If y ou do not hav e an MSDS for a reg ulated substance, you s hould contact you r supplier or the m anufacturer for a copy

. Because the rule states that you must hav e an MSDS that m eets OSHA requirem ents, you m ay want to review th e MSDS to ensure that it is, in fact, com plete. Besides prov iding the chemical nam e, the MSDS for a re gulated substance (or a mixture containing the regulated substance) m ust describe the substance’s physical and chem ical characteristics (e.g., flas h point, vapor pressure), physical h azards (e.g., flammability , reactivity), h ealth hazards, routes of entry, exposure limits (e.g. , the OSHA permi ssible e xposure level ), prec autions for safe handlin g, g enerally applicable control m easures, and em ergency and first aid procedures. (See 29 CFR 1910.1200(g) for the complete set o f requirements for an MSDS.)Chapter 6 6-3 Preven ti on Progr am (Progr am 2)



### EXHIBIT 6-2 SAFETY INFORM ATION REQUIREME NTS

You must compile and maintain this sa fety You must updat e the sa fety information: You must ensure: info rma tio n if: 

### U Material Safety Data 

### U That the process is 

### U There is a major change at Sheets design ed in co mplia nce wit h your business that makes the 

### U Maximum in tended recognized cod es and safety inform ation in accurate inven tory standards 

### U Safe upper and lower
param eters 

### U Equipment specificatio ns 

### U Codes & standar ds used to design , build , and o perate the process

Maximum Inventory. You mus t document the maximum intended inventory of any

vesse l in wh ich yo u store or proc ess a re gulate d subst ance ab ove it s thresh old quantit y. I f you are not sure of the cap acity of the v essel, y ou can obtain t his inform ation fr om th e man ufacture r of the vesse l. In some cases, this inf ormat ion wil l be attached to the v essel itself.

You may want to check with any trade asso ciation or standards g roup that develops standards for your in dustry to determ ine if there are any limitations on inv entories. For example, in some cases th e maxim um capacity of a tank m ay be 10,000 gallons, but an industry stan dard may recommen d that the tank ne ver be filled to m ore than 85 percent capacity. If y ou follow the standard, your ma ximum inventory wo uld be 8,500 gallons.

Storage and Process L imits. You mus t document the safe upper and lower tempe ratures and pre ssures, proces s flows (if app licable) , and c ompo sitions (if applicable) for your p rocess.

Every substan ce has limits on the temperature and pressures at which it can be stored or used; these limits are determined by both the properties of th e substance and the vessels it which it is kept. I f you do not k now these limits, you should co ntact your vendo r, the s ubstanc e man ufacture r, or y our trad e assoc iation. They w ill be ab le to provide the dat a you need

. It is import ant tha t you know th ese li mits so you can take action t o avo id situa tions w here the se lim its ma y be e xceeded

. Many people are aware of the dang ers of overheating their vessels, but extreme low tem peratures also
may pose hazards you should know a bout.

If y ou are m oving substan ces thro ugh p ipes or hoses, you n eed to d efine sa fe temperatures and p ressures for that mo vement; ag ain, these limits w ill be determined by both th e subst ance an d the pi ping. For example, the sub stanc e may toler ate hi ghChapter 6 Preven ti on Progr am (Progr am 2) 6-4

press ures, but the pipes may ha ve struc tural limits. To oper ate sa fely, you must have this information. The pipe manufacturer will be able to prov ide these data.

If you are reacting chem icals, you need to understand whether th e reaction will be
comp romis ed if y ou va ry the temp erature or press ure. A gain, it is im portant to define both the upper an d lower limits. Reactions may become unstab le outside of their limits and com promise safety

. Check w ith the substance m anufacturer for information on this subject if you are uncertain about the limits for particular subst ances you are us ing.

The requirement to com pile and maintain information on pro cess flows and compositions will apply to yo u if you transfer su bstances through pip ing or hoses and if you m ix or react the substance. It is im portant in these cases that y ou underst and the safe lim its for f low and comp osition. The pip e or hos e vend ors will be able to provide you with the m aximum flow rates that their products are designed to handle. You m ust also be aware of a ny hazards that could be created if y our processes are contam inated; for example, if your substance or equipment cou ld be contaminated by water, you m ust know whe ther that creates different haz ards, such as corrosion.

For m any P rogram 2 proce sses, re acting or mi xing w ill not b e an iss ue, but if you are mixin g or r eacting regul ated sub stances , you should unders tand wh at will happen if the composition v aries. If y ou are uncertain about th e effects of changing composition and do not have a chemist or chem ical engineer on y our staff, the substance manufactu rer should be able to h elp you.

Equipment Specifications. You mus t document the specifications of any equipment y ou use to store, m ove, or react reg ulated substances in a cov ered process. Equipment specificatio ns will usually inclu de information on the materials of construction, actual desig n, and tolerances. The vendor should be able to provide this information; y ou may have the specifications in your files from the time of purchase. Many v essels and other pieces of equipment prov ide specification data on an attached name plate. You are not expected to develop engineering drawings of your equipm ent to meet this re quirement, but y ou must be ab le to document that your equipment is app ropriate for the substances an d activities for which it is used, and you must know what the limits of the equ ipment are.

Specifi cations are par ticularl y im portant if you r vess els or p ipes are not spe cifically designed for y our type of operatio n. Substances m ay react with certain metals or corrode them if water is introduced. Yo u should be sure that the vessels yo u purchase or lease are appro priate for your operatio ns. Understanding equipment specific ations w ill help you w hen y ou need to buy replace ment parts. Any s uch par ts must b e app ropr iat e for your e xis tin g equi pment and yo ur us e of t hat equi pment

. It is not s ufficien t to rep lace par ts with somet hing t hat "fits " unless the new part m eets the specifications; substitution of inappropriate parts m ay create serious haz ards.

Codes and Stand ards. You m ust doc umen t the co des and standar ds yo u used to design and bu ild yo ur facil ity an d that y ou follo w to op erate. These co des wil l probably include the electrical and building codes that you m ust comply with under
state or local la ws. Y our equ ipmen t vend ors will be able to prov ide yo u withChapter 6 6-5 Preven ti on Progr am (Progr am 2)

information on the codes they com ply with for their p roducts. Exhibit 6- 3 below lists so me co des that may be rele vant t o you r operat ion. N ote that the Na tional F ire Protection Association (NF PA) codes m ay have be en adopted as state or lo cal codes. The American Nation al Standards In stitute (ANSI) is an umbrella stan dards-setting organization, w hich imposes a specific process for gain ing approval of standards and codes. ANSI codes may include codes and stan dards also issued by other organizations.



### EXHIBIT 6-3 CODES AND STANDARDS

O RGAN IZ ATI ON S UBJECT /C ODES

American Nation al Stan dard s Inst itu te (A NSI) Piping, Electrical, P ower wiring, I nstrumentation, Lig hting, Product
stora ge and han dling, Ins ulati on and fi repro ofing, P ainti ng and coa ting, Ventilati on, No ise and Vibration , Fire p rotectio n equip ment, Safety equipm ent, Pu mps, Com pressor s, Motor s, Refr igerat ion equ ipmen t, Pneumatic conv eying
American Society of Mechanic al Eng ineers (ASME) Power boilers, Pressure vessels, Piping , Compressors, Shell and tube heat exchangers, Vessel com ponents, General desig n and fabrication codes

American Petroleum Insti tut e (AP I) Wel ded t anks , Rot ati ng equ ipmen t, Bu lk li quid stor age sy ste ms

National Fire Protection Association (NFP A) Fire pumps, F lammable liquid code, LNG storage and handling , Plant equipment and layout, Electrical sy stem design, Shutdown sy stems, Pressure relief equipm ent, Venting requirem ents, Gas turbines and engines , Cooli ng tower s, Stor age tanks
American Society for Testing Material s (ASTM) Inspection and testing, Noise an d vibration, Materials of construction, Piping ma terials and system s, Instrum entation

H OW D O I D OCUMENT A LL T HIS ?

EPA do es not e xpect y ou to d evelo p piles of pape rs to do cume nt you r safety inform ation. Your MS DS(s) a re usua lly th ree or fo ur pag es long

. You only have t o keep t hem o n file, as you already do for OSHA. Equip ment specific ations a re usually on a few sheets or in a book let provided by the vendor; y ou need only k eep these on file. You ca n probably docum ent the other inform ation on a single sheet that simply lists eac h of the required item s and any code s or standards that apply

. See Exhibit 6-4 below for a sam ple. Maintain that sheet in a file and update it wh enever any item c hanges or new equipment is add ed.Chapter 6 Preven ti on Progr am (Progr am 2) 6-6



### EXHIBIT 6-4 SAMPLE SA FETY INF ORMATION SHEET

P ROPANE S TORA GE
MSDS Propane On file (1994)

Maxim um I ntended Inv entory 400,000 pounds
Temper ature Upper: max 110°F Lower: min -15°F

Pressur e Upper: 240 psi @ 110°F Lower: 35 psi @ -15°F

Flow R ate Loading: 100 G PM (max) Unloading: 265 GPM (max)
Vapor Piping 250 P SIG
Liquid Piping and Compressor Discha rge 350 P SIG

Safety Relief Valves Each re lieves 9,250 SCFM/a ir RV 1 replaced 9/96 RV 2 replaced 6/97 RV 3 replaced 8/98

Excess Flow Va lve 3", closes at 225 GP M with 100 PSI G inlet 2", closes at 100 GP M with 100 PSI G inlet 2", closes at 34,500 SCFH with 100 PSIG inlet
Emergency Sh utoff Valve ESV 1 1/4", closes at 26 ,000 SCFH w ith 100 PSI G inlet ESV 2", closes at 225 G PM with 100 PSI G inlet

Codes and Standards Designed under NFPA-58 -1985
Pipin g Design ASME B31-3

Tank Des ign ASME NB# 0012

The equi pmen t specif ications and lis t of any applica ble stan dards a nd code s will probabl y m eet the requirem ent that you e nsure th at you r proces s is des igned in complia nce wit h recogn ized and general ly good engi neeri ng pract ices. If you have any doubt that y ou are meeting this requirement, your trade association or implementing agency m ay be helpful in d etermining if th ere are practices or standards that you are not aware of that m ay be useful in y our operation.

After y ou hav e docum ented y our safe ty inf ormat ion, y ou shou ld doub le check it to be sure that th e files y ou hav e reflec t the eq uipme nt you are cur rently using

. I t is important to k eep this information up to date. Whenev er you replace equ ipment, beChapter 6 6-7 Preven ti on Progr am (Progr am 2)

sure that you put the new equipm ent specifications in the file an d consider whether any of you r other prevention elem ents need to be rev iewed to reflect the new equipm ent.

U PDA TI NG SA FET Y I NFOR MATI ON

The Part 68 rule also requires that you update y our safety inform ation whenever a major change oc curs that mak es the information inaccurate. Such chan ges can include changes in process design or o peration that can sign ificantly affect other portion s of y our risk mana gem ent prog ram. Before starting up a pr ocess a fter a major change, all relevant elem ents of the risk m anagement program, including prevention prog ram elemen ts, must be rev iewed and updated as appropriate. For

exam ple, a m ajor chan ge in process operati on ma y requ ire yo u to up date y our safe ty inform ation, as well as you r haza rd rev iew and operati ng pro cedures

. Oper ators must be trained in any updated p rocedures before starting up the changed process. Additionally, a m ajor process change could potentially require y ou to update yo ur offsite consequence analy sis if, for example , you substantially increase your
regu lat ed su bst ance inven tor y or in sta ll a p ass ive mi tiga tio n syst em.

In u pdating safety inform ation su bsequen t to a m ajor proc ess cha nge, you s hould also determine wh ether new or revise d information relev ant to your process has becom e avai lable. For exa mple, since f ederal, state an d indus try sta ndards are part of the safety inform ation that must be compiled, any new or revised standards that
are app licable to the c hange itself o r to the chang ed proc ess sho uld be r eflected in the update.

W HERE T O G O F OR M ORE I NFOR MATI ON

MSDSs. MSDSs are av ailable from a num ber of websites. Ch emical manufacturers’ webs ites are often the best source of up-to- date MSDS inform ation. Other on-line MSDS databases hav e multiple copies o f MSDSs for each subs tance and can help yo u find an MSDS that is well organiz ed and easy to read. EPA has n ot verified the accuracy or completeness of MSDSs on any website nor does it en dorse
any p articula r vers ion of a n MSDS

. You should revie w any MSDS y ou use to ensu re that it meets the req uirements of OS HA’s hazard com munication standard (29 CFR 1910.1 200).

Guidance and R eports. Although the publications below targ et the chemical indu str y, you ma y fin d use ful info rmat ion i n the m:



### � Guidelines for Process S afety Docum entation, Center for Ch emical Process Safety of the Am erican Institute of Chemical Eng ineers 1995.



### � Loss Prevention in the Process I ndustries, Volumes I , II , and II I, Frank P. Lees, Butterworths: Lo ndon 1996.

6.3 HAZ ARD REVIEW (§ 68 .50)

For a Program 2 process, you must conduct a hazard review

. EPA has stream lined the process hazard analysis (PHA) req uirement of OS HA’s PSM standard to create aChapter 6 Preven ti on Progr am (Progr am 2) 6-8

requirement that w ill detect process hazard s at the simpler p rocesses in Program 2. The haz ard rev iew wil l help y ou dete rmine whethe r you are m eeting applica ble codes and standards; iden tify, evaluate a nd address the typ es of potential failures; and foc us yo ur em ergen cy res ponse p lanning efforts

. Many Prog ram 2 proces ses are

cover ed by industr y- specific risk m anage ment progr am g uidance (appen ded to t his guidance) that wil l help with this ha zard review.

W HA T DO I NEED TO DO ?

The hazard review is key to understanding how to operate safely o n a continuous basis. You m ust identify and rev iew specific hazards and safeguards for your Program 2 processes. EPA lists the types of haz ards and safeguards in the rule. Exhibit 6-5 below summarizes things you must do for a hazard revie w.



### EXHIBIT 6-5 HAZARD REVIEW REQU IREMENTS

Conduc t a re view & identify... Use a guide for conducting the revi ew. Docume nt result s & resolve problem s. Update your hazard revi ew.


### U The hazards associated with the Progra m 2 proce ss & regula ted substa nces. 

### U Opportunities for equipment malfunction or human error that could cause a release. 

### U Safeguards that will control the hazards or prevent the malfunction or

error. 

### U Steps to detect or monitor re leases. 

### U You may use any checklist (e.g., one
pr ov id ed in in du st ryspecific risk management program guidance) to conduct the review. 

### U For a pr ocess designed to industrystandards like NFPA58 or Fe deral /st ate design rules, check the equip ment to make sure that it’s fabricated, installed, and operated
pr op er ly. 

### U Your hazard review must be documented and y ou must show that you have addressed problems

. 

### U You must up date
you r revie w at leas t once every five yea rs or whene ver ther e is a major change in the
process

. 

### U In the case of a major change, y ou must resolve problems identified in the new review before you startup the chang ed proce ss.

H OW D O I S TART ?

There are three possible approach es to conducting a hazard review ; which you u se depends on you r particular situation.

1. Processes designed to legal or industry-specific codes. If y our process was designed and built to comply with a federal or state stand ard for your industry or anChapter 6 6-9 Preven ti on Progr am (Progr am 2)

industry-sp ecific design code, your hazard review may largely rely on the standard or code to identif y haz ards. Th e standa rd-s etting organ izatio n has co nducted a haz ard review for that ty pe of process, identified th e hazards, and developed equipm ent and operating requirem ents to minim ize the risks. You can use the co de or standard as a checklist. You need supplement that checklist only to the extent you are aware of other hazards that the standard or code does not address. The purpose of your rev iew is to ensure that yo ur equipment m eets the code, addresses any other haz ards to the extent practicable and is bein g operated in app ropriate ways.

If you have a single vessel or other sim ple equipment, you can probably conduct the review relatively quickly. You will need a co py of the code or standards and

someo ne who is fam iliar wi th both the req uirem ents and your equipm ent to e nsure that the person can reason ably assess y our compliance. If yo u have an opera ting engineer, he or s he may be able to conduct the review. I f you do not h ave any technical staff, your v endor or trade association m ay be able to he lp you. I f you seek outside help, howev er, work with whoever conducts the review so that you understand what they find. Also, to th e extent the person cond ucting the revie w identifies hazards not a ddressed by the c ode or standard, y ou should address those hazards to the exten t practicable.

2. Ind ustry c hecklis t/indus try-spe cific risk manage ment pro gram. If there is not a single code or standard you m ust meet, y ou may want to use a check list developed by a third party , such as a national trad e association. EPA has also developed
supp lemen tal guida nce f or in dust ry-spe cif ic ri sk mana gement progr ams fo r some industry sectors. These guidance docum ents are appended to this guidance, and include checklis ts that may provide an adequate basis for your review.

If you use guidance prov ided by a trade a ssociation or EPA, it probably identifies what your haz ards are and what ty pes of equipmen t and procedures y ou should be using

. You r job is to use the check list to d ecide if you m eet the requirem ents and , if you do not, whether you sho uld. In s ome cases, y our individual circum stances may make a c hecklist item u nnecessary or m ay pose haz ards not identified by the check list that you s hould c onsider

. As with an industry -specific standard, if you hav e an operating eng ineer or an operato r know ledge able ab out the equipm ent and proces s, he o r she m ay be able to conduct the review

. If y ou do not hav e any technical staff, your vendo r or trade associa tion m ay be able to help y ou. I f you seek o utside h elp, ho wever , work with whoever conducts the review so th at you understand what they find.

If you us e an in dustry standa rd or m odel, y ou may h ave to m odify it to address site-specific concerns. Never use someone else's checklist blindly. You must be sure that it ad dresses all of your potential problems.

3. Develop your own checklist

. If y ou have no ind ustry-specific standards or checklists, you will have to de sign your o wn hazard rev iew. As discussed in the requi rements secti on (Exh ibit 6 -5), the r eview must identi fy:



### � The hazards of the reg ulated substance and proc ess;Chapter 6 Preven ti on Progr am (Progr am 2) 6-10



### � Possible equipmen t failures or human errors that could lead to a release;



### � Safeguards used o r needed to preven t failures or errors; and



### � Steps used or needed to detect or mon itor releases.

You will probably be able to define the hazards of the sub stance using the MSD S, which lists the haza rdous properties of the sub stance. The hazards of the process (as
oppose d to the equipm ent) wil l be lim ited for many Prog ram 2 proces ses. H owev er, if you react or m ix chemicals, if y our process could be c ontaminated by water or other chemicals, o r if you operate a process involvin g high tem peratures or pressures or hav e other unique circum stances , you may have process hazar ds that you n eed to identify. Your safety information should help here.

The next step may be to conduct a sim plified "What If" process , where your technical staff ask "What if it stops or fails?" for each piec e of equipment and "What if the operator fails to do th is?" for each procedure. Most industry standards and codes consider these ques tions and provide responses in terms of design standards and ope rating practic es. I f you are doin g this on yo ur own, the im portant thing to remember is that you should not assume tha t an equipment failure or human error will not happen. A sk whether the sa feguards that y ou think protect the equipment or operato r are rea lly ad equate. In many cases, they may be adeq uate, b ut it is useful t o ask, to force y ourself to examine your own assum ptions.

From this ex ercise, you s hould d evelo p a chec klist o f item s that y ou need to conside r. For exam ple, if you h ave li sted m ixing tank p ump f ailure a s a poss ible prob lem, t he ch eckl ist might t hen i ncl ude t he fo llo wing i tems t o che ck: pu mp maint enance plans, tank h igh- level alarm s, ov erflow tanks. You w ould als o want to ask what effect a power outage w ould have on th e pump. Y ou may want to consider the particular procedures that h ave to be followe d for safe operation of the equipment and ask what would happen if an operator omits a step or d oes them out of order. Do y our procedures address the se possible problem s? Would failure of the
pump affect t he safe operatin g lim its you hav e docum ented in your safety information?

When y ou finis h the ch ecklis t, it is useful t o show it to y our ope rators. They a re familiar with the eq uipment and m ay be able to po int out other areas of con cern. A review wi th your ven dors or trade associ ation may also hel p; thei r wider knowledge of the industry m ay giv e them ideas abo ut failures you m ay not hav e experienced or considered.

You may also use any o f the other techniques desc ribed in Appendix 7- A to Chapter 7. Thes e techn iques g enerally require more trained staff an d mor e time ; they are particularly appropriate for processes that involv e reacting or m anufacturing chemicals.

N ATURAL E VENTS AND O THER O UTSIDE I NFLUENCES

Whichever approach y ou use, you should consider reasonably anticipated external events as well as internal failures. I f you are in an area subject to earthquakes,Chapter 6 6-11 Preven ti on Progr am (Progr am 2)

hurricanes, or floods, y ou should exam ine whether your process would surv ive these natural event s witho ut relea sing t he subs tance. In y our haz ard rev iew, y ou shou ld consider the potential im pacts of lightning strikes and pow er failures. If your proc ess coul d be h it by vehic les , you s houl d exa mine t he co nseq uenc es of that

. If you have anything near the process that could bu rn, ask yo urself what would hap pen if the fire affected the process. For example , if you hav e a propane tank and an ammonia tank at your facility and they are close to each other, when you look at the ammonia tank you sh ould consider what a fire in the propane tank would do to the ammonia. These considerations m ay not be part o f standard checklists o r model
programs.

In addition, you may want to check with vendors, trad e associations, or profession al organizations to determine if there are new standards for safety systems o r designs, or if there are detection or m itigation system s that may be applicable to yo ur process that you should c onsider when yo u evaluate yo ur existing equipm ent. If y our equipm ent is d esigne d and b uilt to a n earlie r vers ion of a standar d, yo u shoul d consider whether upg rades are needed.

R ESP ONDI NG TO F IN DI NGS

The person or persons wh o conduct the rev iew should develo p a list of findings and

recommen dations. You m ust ensure that problem s identified are addressed in a time ly mann er. E PA do es no t req uir e tha t you i mpleme nt eve ry re commen dat ion. It is up to you t o mak e reason able de cisions about w hich rec omm endatio ns are necessary and feasible. You may decide that other steps are as effective as the

recom mend ed actio ns or th at the ri sk is t oo low to me rit the e xpense. You m ust, however, docum ent your decision o n each recomm endation. If you are im plementing

a recomm endation, you sh ould document the schedule for im plementation. I f you are tak ing ot her step s to add ress the problem or deci de the p roblem does n ot me rit action, you shou ld document the basis for your decisio n.

D OCUMEN TI NG TH E RE VI EW

You sh ould m aintain a copy of the c heckl ist or o ther doc umen tation a ppropri ate to the review m ethod you used. For a checklist approach, the easiest wa y to docum ent findi ngs is to enter them on th e checkl ist af ter ea ch ite m. This ap proac h will gi ve you a sim ple, concise way of keeping track of finding s, recomm endations and conducting follow- up to resolve recom mendations. Y ou may also want to create a separate document of recomm endations that require im plementation or oth er resoluti on. E xhibit 6 -6 is a partia l check list dev eloped for a pr opane s torage facility risk manag ement prog ram; it provid es a sample of the level of detail nee ded in a check list and a form at for d ocum enting your finding s (if y ou are c onducti ng a h azard review for a p ropane storag e facilit y, do not use this ch ecklis t - u se the c omple te checklist provide d in the Supplem ental Risk Manag ement Prog ram Guidance fo r Propan e Storag e Facili ties (ap pended to this guida nce).Chapter 6 Preven ti on Progr am (Progr am 2) 6-12



### EXHIBIT 6-6 SAMPLE C HECKLIST ( EXTRACT) *

Piping, Equipment, Co ntainer Appurtenan ces Yes/No/NA Comments/Follow-up

1. On installa tions w ith stair ways and lad ders, a re catwalks prov ided so personnel need not walk on an y portion of the vesse l?

2. Is pip ing designed in accordance with AS ME B31.3, 1993 edition?

Pump and compressor discharg e and liquid transfer lines shall be suitable for a working pre ssure of 350 psi (3-2.8.2(a) o f NFPA 58, 19 95 edition)

Vapor piping shall be suitable for a workin g pressure of 250 psi (3-2 .8.2(b of NFPA 58, 1995 edition)

3. Is the c apacity of the pressu re relief devices desig ned as specified in 2- 3.2 and 3- 2.5 of NFPA 5 8, 1995 edition?

4. Are appropriate lev el gauges, temperature indicators, and pre ssure gauges ins talle d on fix ed ASME s torage tanks as specified in 2-3.3.2(b), 2-3.3.3, 2.3.4, 2.3.5 of NFPA 58, 199 5 edition?

5. Are appropriate h ydrostatic relief valv es installed between every section of liquid piping , which can be blocked by manual or autom atic valves as specified in 2­ 4.7 and 3- 2.9 of NFPA 5 8, 1995 edition?

6. Is ap propriate corrosion protection in stalled as required by 3- 2.12 of NFPA 58, 1995 edition?

7. On installations w ith pumps, are they installed as specified in 3-2 .13 of NFPA 5 8, 1995 edition? On installations with an automatic by pass valve, are they installed on the discharg e of the pump as specified in 3­ 2.13(b)(1) and 2- 5.2 of NFPA 5 8, 1995 edition?

* Note: Standard and code citations included in th is sample are prov ided as examples. Industry codes and standards are rev ised on a periodic basis, and their requirem ents may change significan tly from one edition to the next. I n designing or implementing a check list, you should consult the edition of the industr y stan dard tha t applie s to the relev ant proc ess (or process chang e), and incorpo rate the applica ble requirements into y our hazard rev iew.Chapter 6 6-13 Preven ti on Progr am (Progr am 2)

U PDATES

You must up date the review ev ery fifth year o r whenever a m ajor change in a process takes place, whichever occurs first. For most P rogram 2 processes, major changes are lik ely to occur infreque ntly. I f you install a new tank next to an existing
one, you wo uld want to consider w hether the closeness of the two creates any n ew hazards. Replacin g a tank w ith an identical tank would not be conside red a change. Replacing a tank with a new ty pe of tank should trigger an u pdate. Chang ing process composition or safe operating lim its is considered a m ajor change. Ev en if changes prove to be m inor, you should examine the p rocess carefully before s tarting. Combining old and new equip ment can som etimes create unexp ected hazards. Y ou will op erate m ore safe ly if y ou tak e the tim e to ev aluate t he haz ards be fore
proce eding.

W HERE T O G O F OR M ORE I NFOR MATI ON

Although the pu blications below target the chemical industry , you m ay find useful inf ormat ion i n the m:



### � Guidelines for Hazard Evaluation Procedures, 2nd Ed. with W orked examples , Center for Chem ical Process Safety o f the American Institute of Chemical Eng ineers 1992.



### � Evaluating Process Safety in the Chemical Industr y , Chemical Manufacturers Association.



### � Loss Prevention in the Process Industries , Volumes I , II , and II I Frank P. Lees, Butterworths: Lo ndon 1996.



### � Management of Process Hazards (R.P. 750), A merican Petroleum Institute.



### � Risk-Based Decision Making (Publication 1628 8) , American P etroleum Institute.

6.4 OPERA TING P ROCED URES (§ 68. 52)

Written operating procedure s describe in detail what tasks a process ope rator must perform, set safe process operating para meters that m ust be maintained, and set safety precau tions fo r operat ions an d mai ntenanc e activ ities. Th ese pro cedures are the guide for telling your em ployees how to work safely everyday , giving everyone a quick source of info rmatio n that c an prev ent or m itigate the effe cts of a n accid ent, and providing workers and m anagement with a standard ag ainst which to assess performance.

W HAT D O I N EED TO D O ?

You must prep are written operating p rocedures that giv e workers clear instru ction for safely conducting activities involv ing a covered process. You m ay use standar dized proced ures de velop ed by industr y gr oups or provi ded in industry-sp ecific risk man agement pro gram g uidance documen ts as the basis for y ourChapter 6 Preven ti on Progr am (Progr am 2) 6-14

operatin g proc edures, but be sure to check that th ese stan dard pr ocedure s are appropriate for your activities and m odify them as needed. You must ensure that your operating procedures are updated, if necessary, w henever there is a m ajor change and before you startup the c hanged process. Exhibit 6-7 briefly sum marizes what your operatin g procedures m ust address.



### EXHIBIT 6-7 OPERATIN G PROC EDURES REQU IREMENTS

Steps for each operating phase Other Procedures 

### U Initial startup 

### U Consequences of dev iating 

### U Normal operations 

### U Steps to avoid, correct deviations 

### U Temporary op erations 

### U Equipment inspec tions 

### U Emergency shutdown 

### U Emergency operations 

### U Normal shutdown 

### U Startup foll owing a normal or emergency shutdown or a majo r change

Your operating pro cedures must be:



### � Appropriate for you r equipment and operations;



### � Complete; and



### � Written in language that is easily unders tood by y our operators [e.g. , if your operato rs inclu de pers ons wh ose prim ary la nguag e is Spa nish, y ou shou ld consider whether the instruc tions should be prov ided in Spanish as w ell as Engli sh].

The procedures do not hav e to be long. If yo u have sim ple equipment tha t requires a few basic steps, that is all you have to cover.

H OW D O I S TART ?

If you already have written procedures, y ou may not have to do anything m ore. Review the proc edures. You m ay want to wa tch operators perform ing the steps to b e sure tha t the pr ocedure s are be ing us ed and are app ropriate

. Talk with th e opera tors to iden tify any p roble ms they have i denti fied a nd any impr ovements they may have made or wou ld suggest. When you are sa tisfied that they m eet the criteria listed above, yo u are finished. You may w ant to check them against any recommen ded procedu res prov ided by equipm ent m anufact urers, t rade ass ociation s, or st andard setting organiz ations, but you are not required to do s o. You are respon sible for ensuring that the pro cedures explain how to operate your equ ipment and proce sses safely.

If y ou do n ot hav e writte n proce dures, you m ay be able to review your standar d procedures with yo ur operators and write them down. You also may want to checkChapter 6 6-15 Preven ti on Progr am (Progr am 2)

with equipment manufacturers, trade associations, or standard settin g organiz ations. They may have recom mended practices a nd procedures that y ou can adapt. Do not accept a nyone else' s proce dures w ithout c hecki ng to be sure that th ey are adequa te and app ropri ate fo r your pa rticu lar eq uipment and uses and are writt en in la nguage that y our ope rators w ill unde rstand. You m ay als o want to rev iew any require ments imposed under state or federal rules. For example, if y ou are subject to federal rules for load ing an d unl oadi ng of h azar dous mater ial s, th ose r ule s may di cta te so me procedures. Copies o f these rules may be sufficient for those op erations if your
oper ato rs ca n und ers tan d and use t hem.

W HAT D O T HESE P ROCEDURES M EAN ?

The rule lists eight ty pes of procedures. N ot all of them m ay be applicable to you. The following is a brief description to help y ou decide whether y ou need to dev elop procedures for each item

. If a p articular element does not apply, do not spend any time on it. We do not expect yo u to create a docum ent that is meaning less to you. You should spend your time o n items that will b e useful to you.

Initial Startup. This item applies p rimarily to facilities that process or use substances and cov ers all the steps you need to take be fore you start a pro cess for the first time. You should include all the steps needed to check out equipment as well as the steps needed to start th e process itself. I f you sim ply store a reg ulated substance, there is no startup. Wareho uses, for examp le, will probably not have procedure s for startup. Retailers who store a substance and do wnload it should hav e procedures for chec king o ut an d loa ding the ve sse l for the f irs t ti me for this item.

Normal Operations. These procedures should cover your basic operations. I f you are a warehouse, these would include stack ing, mov ing, and repack aging, if y ou do that. For retailers, they would cover lo ading and dow nloading. For users, the procedu res wou ld inclu de all th e steps operato rs tak e to che ck the proces s and en sure that equipment is functioning properly and substances are flow ing or mix ing
appropr iately

. These are yo ur core procedu res that you e xpect y our ope rators to follo w on a dai ly basis to run you r proce sses sa fely.

Temporary Operations. These operations are short- term; they w ill usually occur either when your regular process is shu t down or when a dditional capacity is ne eded for a lim ited per iod. Th e proce dures sh ould co ver th e steps you n eed to t ake to

ensure that the se oper ations w ill func tion saf ely. The proc edures will g enerally
cover pre- startup checks and determinations (e.g ., have y ou determined w hat the maximum flow rate will be). The actual operating proce dures for running th e tempo rary p rocess m ust be w ritten, and ope rators m ust be t rained t o use th em, b efore the operation is put into p lace.

This item may apply to m ost facilities. Even warehouses may need to consider procedures to ensure that if a new substance or p roduct is brought in to the warehouse for tem porary storag e, the n ecessary steps a re tak en befo re that s torage occurs to

ensure that it i s safe (e .g., barrels are not stack ed too h igh or located with incompatible substan ces). If it is possible that you w ill operate your proces s in a way that is not c overed under norm al operations, you should have proce dures forChapter 6 Preven ti on Progr am (Progr am 2) 6-16

temporary o perations. If you will sim ply shutdown y our process (e.g. , stop unlo adi ng the subs tan ce) , you c an ign ore t his item.

Emergency Shutdowns and Operations. These procedures cov er the steps you need to ta ke if you mus t shu tdow n your proc ess quic kly. Fo r most Progr am 2 facilities, these procedures will be brief because shutting a process down w ill be little different in an em ergency than in ordinary circum stances; you will sim ply shut off the flow or stop an y unloading or loading. Fo r warehouses, they may no t apply. If you have a m ore complex pro cess (e.g., one that operates under hig h pressure or temperature), y ou will need procedures to ensure that you can shutdown safely

. Normally y ou gradually reduce flows, depressuriz e, and lower tem peratures. If you need to do any of these quickly , you m ust have procedures that identify the steps workers should tak e to carry out these operations safely.

Normal Shutdown. These procedures apply mainly to facilities that process or use regulated substances. They may apply to y ou even if y ou only store a substance and
you e mpty the tan k for cleanin g. The se proc edures probabl y will not app ly to warehouses unless they repackage.

These pro cedures should provi de all th e steps needed to stop a proce ss safel y. F or a complex proces s or one that op erate s under extre me condit ions, s hutdow n may take

cons ide rabl e time and ma y be ha zard ous. The p roce dure s sho uld s et ou t the time that should be take n and the check s that must be made before proc eeding to the nex t steps.

Startup following a normal or emergency shutdown or a major chan ge. These procedures may be similar to tho se for initial startup. Startup procedures following

norma l shutdo wn m ay inc lude few er equip ment check s becau se you may not nee d to check equipm ent on a frequen t basis. You s hould i nclude all the s teps y our wor kers should take to ens ure that the process can operate safely. Sta rtup after an emerg ency shutdown will g enerally require m ore checks to ensu re that valves that were closed are open and that they and other equipm ent are still functioning properly. These procedu res will be lim ited if y ou only store a substan ce; they may not app ly to warehouses in m ost instances.

Consequences of Deviatio ns. Your o perating proced ures sho uld tell the wo rkers what will happen if so mething starts to go wrong

. For exam ple, if the pressure or temperature beg ins to rise or fall unexpected ly or the flow rate from one feed suddenly drops sh arply, the operator must know (1) whether this poses a problem that must be add ressed, and (2) what steps to take to co rrect the problem o r otherwise respond to it. You r safety inform ation will have defin ed the safe operating limits for
your s ubstanc es and p rocesse s; the h azard review will ha ve def ined the possib le consequences and the s teps needed to prev ent a deviation from causing serious problems. You should include this inform ation in each of the othe r procedures (startup, normal op erations, shutdowns), ra ther than as separate docu ments.

If your substance is one that has a distinctive odor, c olor, or other characteristic that operators will be able to sense, you shou ld include in your procedures information about what to do if th ey notice leak s. Frequently, people are the m ost sensitive leakChapter 6 6-17 Preven ti on Progr am (Progr am 2)

det ect ors

. Take advan tage of th eir abil iti es to catc h lea ks bef ore t hey be come serious.

Equipment Inspections. You should includ e steps for routine inspection and surveillance of equipm ent by operators as part of your other procedures. These inspect ions co ver th e item s that o perators should look for on a daily basis t o be su re that the equipm ent is ru nning safely (e.g. , vib ration c hecks ). These inspect ions are not the same as those detailed checks that maintenance w orkers will perform , but rather are the "eyeball," "sound," and "feel" tests that ex perienced operators do, o ften without realizing it. Your operators, y our vendors, and your trade association can help you define th e things that should trigger concern : When is a sm all leak at a seal normal; when is it a cause of concern? How much vibration is norm al? What does a smoothly ru nning mo tor sound like?

U PDA TI NG P ROCEDURES

You must up date your procedure s whenever y ou change y our process in a way that alters th e steps needed to opera te safel y. I f you add new equipm ent, y ou will need to expand your pro cedures or develop a separate set to cov er the new items

. Whenever
you c hange your safety inform ation y ou shou ld rev iew y our pro cedures to be s ure that they are still appro priate. Anytim e you conduct a hazard review , check y our operating procedures as you im plement chang es to address hazard s.

W HAT K IND OF D OCUMENTS D O I H AV E TO K EEP ?

You m ust m aintain your c urrent s et of op erating proced ures. Y ou are n ot requi red to keep old v ersions; in fact, you should avoid d oing so because keeping cop ies of outdated procedures m ay cause confusion

. You should d ate all procedures so y ou will know wh en they were last updated.

W HERE T O G O F OR M ORE I NFOR MATI ON

Although the repo rts below target the chemical industry , you m ay find useful inf ormat ion i n the m:



### � Guidelines for Process S afety Fundamentals for General Plant Operatio ns , Center for Chem ical Process Safety o f the American Institute of Ch emical Engineers 1995.



### � Guidelines for Safe Pro cess Operations and Main tenance , Center for Chem ical Pro cess Sa fety o f the Am erican I nstitute of Che mical Engi neers 1995



### � Guidelines for W riting Effective Operating an d Maintenance Procedures
, Center for Chem ical Process Safety o f the American Institute of Ch emical Engineers 1996.Chapter 6 Preven ti on Progr am (Progr am 2) 6-18

6.5 TRA INING (§ 68.54 )

Trai ning pro grams oft en provi de immedia te bene fits b ecaus e trai ned wor kers have fewer accidents, dam age less equipm ent, and improv e operational efficiency. Training giv es work ers the inform ation th ey nee d to un derstan d how t o opera te safely and why safe operations are necessa ry. A training program, including refreshe r trainin g, is the ke y to e nsuring that th e rest o f your preve ntion p rogram is effective. You a lready have s ome type of training prog ram because y ou must conduct training to c omply w ith OSHA' s Hazard Com munication Standa rd (29 CFR 1910.1 200).

W HAT D O I N EED TO D O ?

You must train all new workers in your operating procedures develop ed under the previous preve ntion program element; if any of your m ore experienced work ers need training on these pro cedures, you sho uld also train them . For workers already operating a process on June 21, 1999, y ou may certify in writing that the employ ees have the "required k nowledge, sk ills, and abilities to safely carry out the du ties and
respons ibilities as prov ided in the ope rating proced ures" (§ 68.54 (a)). Th is "grandfather clause" m eans that you do not need to conduct additional training for workers operat ing a pro cess by J une 21, 1 999, who have the approp riate knowledge and skills to operate the process safely, in accordance with the o perating procedures. This certification should be k ept in your files; y ou should not subm it it to EPA unless s pecifica lly req uested b y an E PA offi cial.

Any time operating procedures are revised, y ou must train ev eryone using the new procedures. At least o nce every thre e years, yo u must prov ide refresher training on the ope rating proced ures ev en if th ey hav e not ch anged

. The tr aining must cover all parts of the operating procedures, including information on the consequences of deviations and steps needed to address dev iations.

You are not required to provide a specific amount of training or type of training

. You sh ould de velop a traini ng ap proach that wo rks fo r you. If y ou are a smal l facility, one- on-one training and on-the- job training may work best. Larger facilities
may wan t to provide classroom training or v ideo courses develop ed by ven dors or trade associations before m oving staff on to supervised w ork. You m ay have sen ior operators present the training or use trainers prov ided by ve ndors or other outside

sources. The form and the length of the training will depe nd on your reso urces and
your pro cesse s. If you can t each so meone the basics in two ho urs and safel y move them on to sup ervised work, that is all right. The important thing is that your workers understand how to operate safely and can carry o ut their tasks properly

. Find a system that wo rks fo r you. Exhib it 6- 8 lists t hings that y ou ma y find useful in deve lopi ng your trai ning progr am.

You are also required to ensure that each work er trained has understood the training and is competent to operate the process safely

. You m ay decide what kind or kind s of com petency testing to use. Obser vation by a senior o perator may be app ropriate in many cases. If y ou provided classroo m training, you may want to use both tes ting and demonstration or observation. Y ou are required to report in the RMP on the type(s) of com petency testing you use.6-19 Chapter 6 Preven ti on Progr am (Progr am 2)



### EXHIBIT 6-8 TRAINING CHART

U Who needs training? Clearly identify the employ ees who need to be trained and the subjects to be covered.



### U What are the objectives? Specify learnin g objec tives, and wr ite them in clea r, me asurabl e term s before training begins. Remem ber that training m ust address the process op erating procedures.



### U How will you meet the training objectives? Tailor the specific training m odules or segm ents to the training o bjectives. Enhance learning b y including hands-on trainin g like using simulators when ever approp riate

. Make the train ing envir onment as much like t he worki ng enviro nmen t as yo u can, consist ent with safety

. Allo w you r emp loyee s to practice the ir skills and demonstra te what they know.



### U Is your training program working? Evaluate you r training progra m periodically to see if your em ployees have the skills and know th e routi nes req uired under you r opera ting pro cedur es. Make sure that languag e or presentation are not b arriers to learning. D ecide how you will measure y our employ ees’ competence.



### U How will your program work for new hires and refresher training? Make sur e all wo rkers – i nclud ing maint enance and cont ract e mployees – recei ve initial and refresher training. If y ou make changes to process chemicals, equipment, or te chnology, make sure that involved workers understand the changes and the effects on their jobs.

H OW D OES T HIS T RA IN IN G F IT WITH O THER R EQUIRED T RAI NING ?

You are required by OSHA to prov ide training under the Hazard Com munication Standard (29 CFR 1910.1200); this training covers the haz ards of the chem icals and steps to take to prev ent exposures. DO T has required training for loading and unloading of haz ardous materials (49 CFR part 172, su bpart H). Som e of that training will lik ely co ver ite ms in your operatin g proc edures. You d o not n eed to repeat that training to m eet EPA's requirements. Y ou may want to integrate the training program s, but you do not have to do so.

W HAT K IND OF D OCUMENTATION D O I N EED TO K EEP ?

In the RMP, you are required to report on the date of the most recent rev iew or revision of yo ur training prog ram. You are also required to report o n the type of training required (e.g ., classroom o r on-the- job) and the type of competency te sting used. You should keep on site an y current training materials or schedu les used. The rule doe s not re quire y ou to k eep par ticular r ecords of you r trainin g prog ram. It is
enoug h for y ou to h ave on site inf ormat ion that suppor ts what is repo rted in the RMP and your im plementation of the training program overall. You may wan t to keep an attendance log for an y formal trainin g courses and refresh er training to ensure that

ever yone w ho ne eds t o be t rai ned i s tra ine d. Suc h logs will help you pe rfo rm a compliance audit o r demonstrate com pliance with the rule althou gh you are not required to keep log s for this rule.Chapter 6 Preven ti on Progr am (Progr am 2) 6-20

W HERE T O G O F OR M ORE I NFOR MATI ON



### � Guidelines for Process S afety Fundamentals for General Plant Operatio ns , Center for Chem ical Process Safety o f the American Institute of Ch emical Engineers 1995.



### � Guidelines for Technical Planning for On-Site E mergencies , Center for Chem ical Pro cess Sa fety o f the Am erican I nstitute of Che mical Engi neers 1995.



### � Federally Mandated Training and Information (Public ation 12 000), American Petroleum Institute.

6.6 MAINT ENA NCE (§ 68.56 )

Preve ntive maint enance, inspect ion, an d testin g of e quipm ent is c ritical t o safe operations. Waiting fo r equipment to fa il often means w aiting for an accident that could harm peo ple and the environ ment. Further, a thorough m aintenance program will save yo u money by cutting down-tim e caused by equ ipment failures. Y our hazard revie w and s afety inform ation w ill hav e identi fied equ ipmen t that is critical to safe operations. You should use that inform ation to build you r maintenance
prog ram.

W HAT D O I N EED TO D O ?

You must prep are and implem ent procedures for m aintaining the m echanical integrity of proce ss equipment, a nd train your wo rkers in the m aintenance procedu res. Y ou ma y use procedu res or in structio ns from equipm ent ve ndors, in Federal or state regulatio ns, or in industry codes as the basis of your mainten ance program. You should dev elop a schedule for inspe cting and testing your equipm ent based o n man ufacture rs' r ecom mend ations o r your own ex perienc e if that sugg ests more frequent insp ection or testing is w arranted. Exhibit 6- 9 briefly sum marizes the elements of a m aintenance program that would satisfy EPA's rule.

H OW D O I S TART ?

Your first step will probab ly be to determ ine whether you already meet all these requirements. I f you review your existing written procedures and determine that they a re appro priate, you d o not n eed to r evise or rewr ite them

. If your worke rs are already trained in the procedures and carry them out, y ou may not need to do anything else.

If you do not have w ritten procedures, yo u will need to dev elop them. Y our equipment v endors may be able to prov ide procedures and m aintenance schedules. Using these as the basis of your p rogram is ac ceptable unless your use varies from that contemplated b y the vend or or manufacturer (see below). Your trade associa tion m ay als o be ab le to he lp you with in dustry -spe cific ch ecklis ts. I f there are existing industry standards, your trade association can prov ide you with the ref ere nces

. Copi es of thes e may fo rm the basi s for your ma int enan ce pr ogra m. IfChapter 6 6-21 Preven ti on Progr am (Progr am 2)

there are federal or state reg ulations that require certain m aintenance, you s hould use these as well.



### EXHIBIT 6-9 MAINTENA NCE GUID ELINES

Written procedures 

### Inspectio n & testin g Training U You may use 

### U Inspect & test process 

### U Train process maintenance procedures provided equipm ent. employees in process hazards by the ven dor or trade 

### U Use rec ogniz ed and gener ally and how to avoid or correct association, etc., as the accepted good en gineering an unsafe condition. basis for your practices. 

### U Make sure this training program. If yo u 

### U Follow a schedule that matches covers the procedure s choose to develop the m anufact urer’s applicable to safe job your own, y ou must recommen dations or that prior performance. write them dow n. operating experience in dicates is nece ssary.

You need to determ ine if procedures prov ided by ve ndors, manufactu rers, trade associations, or others are a ppropriate for your o peration. If your safety info rmation indicates that you are operating in a stand ard way (e.g ., using only parts designed for refrigeration service in your cold storag e system), you may assume that these other procedures will work for you. I f you are using equipment for p urposes other than those for which it was designed, y ou need to decide w hether your use ch anges the kinds of m aintenance required.

T RAI NING

Once y ou hav e writte n proce dures, you m ust ensu re that y our m aintena nce wo rkers are trained in the procedures and in the haza rds of the process. A s with the training discuss ed in th e prev ious sec tion, h ow yo u prov ide this trainin g is u p to y ou. We believe that yo u are in the best position to decide how to train your worke rs. Vendors may provide the training or videos; y ou may already provide training on hazard s and h ow to a void o r correc t them as part of Haz ard Com munic ation S tandard training under O SHA re gulati ons. Y ou do n ot need to repe at this t raining to com ply with this rule.

If y ou hire contrac tors to do yo ur ma intenan ce, y ou shou ld ensu re that t hey ar e trained to carry out the proced ures. U nder the rule, a ny m aintena nce con tractor is required to ensure that each contract maintenanc e worker is trained to perform the maintenance proced ures developed by the facility. Yo u can help this process by providing training or by dev eloping agreem ents with the contractor that give y ou the

assuran ce that only t rained w orkers will be sent to your site. F or any outside work er, you mus t ens ure t hat they a re in for med of the h azar ds of your p art icu lar proc ess

. If you have standard equipmen t and hire contractors that sp ecialize in servicing your types of processes, you can ensure their knowledg e through ag reements with the
contrac tor.Chapter 6 Preven ti on Progr am (Progr am 2) 6-22

I NSPECTION A ND T ESTING

You m ust esta blish a schedul e for in spectin g and testing equipm ent asso ciated w ith

cover ed proc esses. The freq uency of insp ections and tes ts mu st be co nsisten t with manufacturer’s recom mendations, indu stry standards or cod es, good eng ineering practices, and you r prior operating exp erience. In particular, you shou ld use your own experience as a basis for examining any schedules rec ommend ed by others. Many things m ay affect whether a schedule is appropriate. The manufacturer m ay

ass ume a c onst ant rate of us e (e. g., th e amou nt of subs tan ce pu mped p er ho ur)

. If
your use v aries considerably, the variations m ay affect the wear on the equipme nt. Extreme weather conditions may also impact we ar on equipmen t.

Tal k with your o pera tor s as yo u pre pare or ad opt t hese proc edur es an d sch edul es. If their experience indicates that eq uipment fails m ore frequently than th e manufacturer expects, you sho uld adjust the inspection schedule to reflect that experience. Y our hazard revie w will have i dentifie d these potenti al probl em ar eas as w ell and should be used as yo u dev elop sch edules. For ex ample , if y ou dete rmine that co rrosion is one of the hazards of the process, y our schedule mu st address inspections for corrosio n and re placem ent befo re failu re. Yo ur trade associa tion m ay als o be ab le to provide advice on these issues.

W HAT K IND OF D OCUMENTATION M UST I K EEP ?

In the RMP, you are required to report on the date of the most recent rev iew or revision of yo ur maintenance pro cedures and the date of the most recent eq uipment inspection or test and equ ipment inspected o r tested. You m ust keep on site y our written proced ures an d sched ules as well as any ag reeme nts yo u hav e with
contractors. The rule does n ot require that you keep particular records of your maint enance progr am. It is enoug h for y ou to h ave on site inf ormat ion that suppor ts what is reported in the R MP and your im plementation of the maintenance prog ram overall. For exa mple, yo u may want to keep m aintenance logs to k eep track of whe n inspections and tests were done.

W HERE T O G O F OR M ORE I NFOR MATI ON

Codes and Stand ards: The following g roups develop cod es and standards that m ay help you determ ine the appropriate frequency and methods to use for testing an d inspection: National Boa rd Inspection C ode, the Am erican Society for Testing and Material, American P etroleum I nstitute, National Fire Protec tion Association, American Nation al Standards In stitute, American S ociety of Mechanical E ngineers.

Guidance and Reports. Although the reports below target the chemical industry , you may fin d use ful info rmat ion i n the m:



### � Guidelines for Equipme nt Reliability Data with D ata Tables , Center for Chem ical Pro cess Sa fety o f the Am erican I nstitute of Che mical Engi neers 1989.



### � Guidelines for Process S afety Documentation , Center for Chem ical Process Safety of the Am erican Institute of Chemical Eng ineers 1995.Chapter 6 6-23 Preven ti on Progr am (Progr am 2)



### � Pressure Vessel Inspection Code: Maintenance Inspection , Rating, Repair, and Alteration (API 510 ), American P etroleum I nstitute.



### � Tank Inspection, Repa ir, Alteration, and R econstruction (Std 65 3) , American Petroleum I nstitute.



### Q & A M AINTE NANCE

Q. I use propane as a raw m aterial in my manufacturing process. I lease the tank from the propane supplie r. The s upplier does al l the m aintena nce. My staff ne ver w ork on the equ ipmen t. What should I do?

A. As part of your co ntrac t with t he supp lier, it woul d be hel pful t o gain an a greement , in wri ting, that the supplier will prov ide maintenance an d trained maintenan ce workers that m eet the requirements of 40 CFR 68.56.

6.7 COMPLIA NCE A UDIT S (§ 68 .58)

Any risk m anagement program sh ould be reviewed periodically to ensure that employees and contractors are im plementing it properly. A c ompliance audit is a way for yo u to evaluate and measure the effectiv eness of your risk managem ent program. An audit review s each of the prev ention program elements to ensu re that they are up- to-date and are being im plemented and w ill help you identify problem areas and take correc tive actions. As a result, you' ll be running a sa fer operation.

W HAT D O I N EED TO D O ?

At least every three y ears, y ou mu st certif y that you h ave ev aluated comp liance w ith the prevention prog ram requirem ents for each covere d process. At least o ne person on your audit team must be k nowledgeable abo ut the covered pro cess. You m ust develop a report o f your finding s, determine and document an appropriate response to each finding, a nd document th at you hav e corrected any deficie ncy.

You must rev iew compliance with each of the required elements of the prevention
program. Because Program 2 processes are g enerally simple, the audit should not take a long time. You may wan t to develop a sim ple checklist; Exhibit 6 -10 prov ides

a sam ple form at.

Once y ou hav e the ch ecklis t, yo u, yo ur chief operato r, or so me ot her pers on who is knowledgeab le about your pro cess, singly or as a team, should walk throu gh the facility and check on relevant item s, writing down comme nts and recomm endations. For example, you may want to talk w ith employee s to determine if th ey have be en trained and are fam iliar with the procedures.

You must resp ond to each of the find ings and docum ent what actions, if any , you take to address prob lems. You should take steps to correct any deficiencies you find.Chapter 6 Preven ti on Progr am (Progr am 2) 6-24

You may choose to have the audit conducted by a qualified outside party

. For example, y ou may have some one from anothe r part of your com pany do the au dit or hire an expert in y our process. I f you do either o f these, you sho uld have an emplo yee w ho work s with o r is resp onsible for the proces s work with th e audito r, both to understand the findings and answ er questions.

Again , the p urpose of the c ompli ance au dit is to ensure that y ou are c ontinui ng to implement a prevention prog ram as required. Remem ber, the risk m anagement program is an on-g oing process; it is n ot a set of docum ents that you dev elop and put on a sh elf in ca se the g overn ment inspect s you r site. Ind eed, g overn ment inspect ors will expect your fac ility operators to be fam iliar with and imp lementing y our acciden t prev ention p rogram

. To be in com pliance with (a nd ga in the b enefits of) the rule , proce dures m ust be f ollowed on a da ily ba sis; doc umen ts mu st be k ept up t o date. Your com pliance audit must check com pliance with each prev ention program element and indica te areas that need to be improved. You may choose to expand th e scope to cover y our compliance w ith other parts of the rule a nd the overall safety of your operation, b ut you are not re quired to do so.

W HAT K IND OF D OCUMENTATION M UST I K EEP ?

You must kee p a writ ten re cord of audit f indin gs and your respon se to th ose fi ndings and documents that deficiencies have b een corrected. You must keep the two most recent audit reports, but y ou need not ke ep a report that is m ore than five y ears old. You may also want to k eep a record of who conducted the audit, bu t you are not required to do this.

W HERE T O G O F OR M ORE I NFOR MATI ON



### � Guidelines for Auditing Process Safety Mana gement Sy stems, Center fo r Chem ical Pro cess Sa fety o f the Am erican I nstitute of Che mical Engi neers 1993.



### Q & A A UDITS

Q. Does the comp liance audit requireme nt cover all of the Part 68 requiremen ts or just the prevention prog ram requirem ents?

A. The compliance audit requirement applies o nly to the prevention program s under Subpart C. If you have a Prog ram 2 process, you must certify that you have evaluated compliance with the Program 2 prevention prog ram provision s at least every three years to v erify that the procedure s and pra ctices d evelo ped und er the ru le are ad equate and are being follow ed. Yo u may want to expand your aud it to check other p art 68 elements, but you are not required to do so.6-25 Chapter 6 Preven ti on Progr am (Progr am 2)



### EXHIBIT 6-10 SAMPLE A UDIT CHECK LIST FOR SAF ETY INFOR MATION AN D HAZAR D REVIEW

Element Yes/No/NA Action /Comple tion Da ta
Safety Information
MSDSs up-to -date and av ailable to workers?

Maximum in tended inventory determined?

Determined Safe upper and lower temperature? Safe upper and lower pressures? Safe process flow rates? Compositions?
Equipment specificatio ns Tanks? Pipin g? Pressure relief valv es? Emergency shutoff valves ? Gauges? Pumps? Compressors? Hoses?

Hazard Review
Has equ ipmen t been i nspecte d to det ermin e if it is designed, m anufactured, installed, and operated according to industry standards a nd codes?
Are the results of the insp ections documented?

Have inspect ions be en cond ucted a fter ev ery major change?

6.8 INCIDENT INVESTIGA TION (§ 68.60 )

Incidents can provide valuab le information abou t site hazards and th e steps you need to tak e to pre vent a ccident al relea ses. O ften, th e imm ediate c ause of an inci dent is the result of a series of oth er problems that n eed to be addressed to prevent

recurrences. For exam ple, an operator' s mistake m ay be the result of poor training. Equipm ent failu re ma y resu lt from impr oper m aintena nce or m isuse. Without a thorough inv estigation, you may m iss the opportunity to identify and solv e these problems.Chapter 6 Preven ti on Progr am (Progr am 2) 6-26

W HAT D O I N EED TO D O ?

You must inv estigate each incident w hich resulted in, or could have resulted in, a catastrophic release of a reg ulated substance. A catastrophic release is one that presents an imm inent and substantial endan germent to public health and the environment. If the incid ent meets the criteria for including in the five-y ear accident history section of y our RMP, it warrants an incident investig ation. Exhibit 6- 11 briefly summ arizes the ste ps yo u mus t take for inv estiga ting i ncident s. You should also con sider in vestig ating minor acciden ts or ne ar mis ses bec ause the y m ay hel p you id entify problem s that c ould lea d to m ore seri ous acc idents; howev er, yo u are not required to do so under part 68.



### EXHIBIT 6-11 INCIDENT I NVESTIGA TION REQUIR EMENTS

U Initiate an inv estigati on pro mptly

. Begin inves tigatin g no l ater tha n 48 ho urs followi ng the inciden t.


### U Summariz e the in vestiga tion in a repo rt. Among other things, the rep ort must identify the factors contributing to th e incident. Rem ember that ide ntifyi ng the root ca use m ay be more impor tant tha n identi fying the ini tiating event

. The report must also in clude any

recommen dations for corrective ac tions. Reme mber that the purpos e of the report is to help manag ement take corrective action.



### U Address the report’s findings and

recommendations. Establish a system to address prom ptly and resolve the incident rep ort findings and

recommen dations and docum ent resolutions and corrective actions.



### U Review the report with your staff and

contractors. You must sha re the report - its findings and

recommen dations - with affected workers w hose job task s are rel evant to the i ncident

. 

### U Retain the rep ort. Keep i ncide nt inves tigati on summari es for five
years.

H OW D O I S TART ?

You should start with a simple set of p rocedures that you will use to begin an investigation. You may want to assign someone to be responsible for com piling the initial incident data and putting together the inv estigation team. The investigation will proceed more smoothly if your team includes personnel who have been trained in accident investig ation methods an d your inve stigation procedures. If yo u have a small facility, y our "team" m ay be one perso n who works with the local responde rs, if they were inv olved.Chapter 6 6-27 Preven ti on Progr am (Progr am 2)

The purpose of the inv estigation is to find o ut what went wrong and why, so you can prevent it from happening ag ain. Do not stop at the obvious failure or "initiating
event " (e.g ., the hose wa s clog ged, the ope rator fo rgot t o check the con nection ); try to determine why the failure occurred. I n many cases, the underlyin g cause will be what matters (e.g ., the operator did no t check the conne ction because the operating procedures and training did not include this step ). If the a ccident occurred because of operator error, yo u should determin e if the operator m ade the mistak e because he or she had been trained inadequately or trained in the wrong pro cedures or because design flaws m ade mistakes likely. I f you write off the accident as operator error alone, you m iss the chance to tak e the steps needed to p revent such errors the next time. Sim ilarly, if equipm ent fails, you sho uld try to decide w hether it had been used or maintained im properly.

Rememb er, your g oals are to prevent accidents, not to blam e someone, an d correct any problem s in your prev ention program

. In this way, yo u can prevent recu rrences.

In som e cases, an inves tigation will not tak e long. I n other cases, if y ou have a
comp lex faci lity, equipm ent has been se verely dama ged, or the w orkers serious ly hurt, an investig ation may take several da ys or week s. You should talk with the operators who were in the area at the time and check record s on maintenance (another reason for k eeping logs). If equipm ent has failed in an unu sual way, y ou may need to talk t o the m anufact urer and your trade as sociatio n to det ermin e if similar equipm ent has suffered sim ilar failures.

You must de velop a s ummary of the accide nt and i ts caus es and make

recommen dations to prevent rec urrences. You m ust address each recom mendation and document the resolution and any actions taken. Finally, you must review the findings with operato rs affected by the find ings.

W HAT K IND OF D OCUMENTATION M UST I K EEP ?

You must m aintain the summ ary of the accident investigation and recomm endations and doc umen t resolu tions an d correc tive a ctions. A sam ple form at is sh own in Exhibit 6-12 that combines all o f these in a single form. Note that the form also includes accident data that y ou will need for the fiv e-year ac cident history. These data are not necessarily part of the incident inv estigation report, but including them will cr eate a recor d you can us e late r to cre ate th e acci dent hi story.

W HERE T O G O F OR M ORE I NFOR MATI ON

Although the repo rts below target the chemical industry , you m ay find useful inf ormat ion i n the m:



### � Guideli nes for Investig ating C hemica l Proce ss Incid ents , Center for Chem ical Pro cess Sa fety o f the Am erican I nstitute of Che mical Engi neers 1992.



### � Guide for Fire and Explosion Investigations (NFPA 921), Nationa l Fire Protection Association.Chapter 6 Preven ti on Progr am (Progr am 2) 6-28



### EXHIBIT 6-12 SAMPLE INCIDENT INVESTIGATION FORMAT

Ammonia Tank Releas e Date: May 15, 2003; 3 pm Substan ce: Am monia Quantity: 2 tons

Duratio n: 2 ho urs Weather: 82 F, 8 m ph winds Date Inv estigation Started: May 16, 2003
Description: Unload ing ho se split open a nd spill ed subs tance; o perator was in the main building and failed to notice spill for several m inutes
Findings Recommendations Actions
Hose sp lit beca use the pressur e was too great Replace hose with hig her pressure hose Revise procedures for checking
on pres sure Replaced hose as

recommen ded; revised procedures; conducted training on new procedures
Operator failed to stay at the tank during loading Conduc t refresh er train ing to stress necessity of rem aining at the tank during loading Refresher training prov ided; safety meet ings a dded an d held on a monthly basis to review safety issues

Tank re quired m anual sh utoff Determ ine if au tomat ic shuto ff valv e is feas ible Automat ic shut off valve installed

6.9 CONCL USION

Man y of you will need to do lit tle that 's new t o comp ly wit h the Progr am 2 prevention prog ram, because complying with other Federal rules, state requirements, and industry- specific codes and standards results in complian ce with many Program 2 elements. A nd if you' ve voluntarily implemen ted OSHA' s PSM standard for y our Program 2process, you' ll meet the lesser P rogram 2 prevention prog ram requ ire ments

. No mat ter what choi ces yo u make i n comp lyin g with the P rogr am 2 prevention prog ram, keep these things in m ind:



### � Inte grate the elem ents of your p reven tion pro gram

. For P rogram 2 owne rs and ope rators, a ma jor chang e in any singl e elem ent of y our pro gram should lead to a review of other elements to identify any effect caused by the change.



### � Make accident prev ention an institution at y our site. Like th e entire risk
managem ent program , a prevention p rogram is m ore than a collection of written documents. It is a w ay to mak e safe operations and accid ent prevention the way you do busine ss everyday

.


### � Check your operat ions on a conti nuing ba sis and ask if you c an improve them to ma ke the m saf er as we ll as m ore effi cient.

## CHA PTE R 7: PR EVENT ION PR OGRA M (PROG RA M 3)

Man y of you will need to do lit tle that is ne w to c omply w ith the P rogr am 3 prevention prog ram, because y ou already hav e the OSHA PS M program in place. Whether you' re building on the PSM standard or creating a new program , keep these things in m ind.



### � EPA an d OSHA have differen t lega l author ity — E PA for offsite consequences, OSH A for on-site consequences. I f you are already complying with the PSM standard, your process haz ard analysis (PHA ) team will have to consid er whether new haz ards could affect the public or the environment offsite. For exam ple, protection me asures that are suitable for workers (e.g ., venting releases to the outdoors) m ay be the v ery kind of thing that imperils the pub lic.



### � Inte grate the elem ents of your p reven tion pro gram

. You must ensure that a change in any single elem ent of your prog ram leads to a re view of other elements to identify any effect caused by the chang e.



### � Most i mportan tly, make ac ciden t preven tion an insti tutio n at your site. Li ke the entire risk m anagement program, a prevention prog ram is m ore than a collection of written docum ents. It is a way to m ake safe operations a nd accident prevention the way yo u do business ev eryday.



### 7.1 PROGRA M 3 PREVENT ION PROGRA M A ND OSHA PSM

The Program 3 prevention prog ram includes the requirements of the OSHA PSM standar d. When ever w e could , EPA used OS HA' s lang uage v erbatim

. How ever, there w ere a fe w term s that E PA had to chan ge to reflect t he diffe rences b etween its
aut hori ty and OSHA's

. For examp le, O SHA re gula tes to pr ote ct wo rker s; EP A's responsibility is to protec t public health and safety and the environm ent. Therefore, an "own er or op erator" s ubject to EPA' s rule m ust inv estiga te any catastr ophic release "that presents im minent and subs tantial endangerm ent to public health and the environm ent," but an OSHA "employer" w ould focus its concerns o n the workplace. To clarify these distinctions, we d eleted specific references to w orkplace impacts and "safety and health" contained in OSHA's PSM standards. We also used differen t dates and refe rences w here ap propria te. Ex hibit 7- 1 com pares te rms in EPA's rule with their counterparts in the OSHA PSM stan dard.



### EXHIBIT 7-1 COMPA RABLE EPA AND OSHA TER MS

OSHA TERM EPA TERM
Highly haz ardous substance Employer Facility Standar d Regulated substance Owner or operator Stationary source Rule or partChapter 7 Preven ti on Progr am (Progr am 3) 7-2

There are twelve elem ents in the Program 3 prevention pro gram. E ach element corresponds with a section of subpart D of part 68. Exhibit 7- 2 sets out each of the twelve elements, the corr esponding section numbers, and OSHA references

. Two OSHA eleme nts are not incl uded. Emer gency respon se is de alt with separat ely in part 68; the OS HA trad e secret s requir emen t (prov ision of trade s ecret in forma tion to employee s) is be yond EPA's st atuto ry autho rity.



### EXHIBIT 7-2 SUMMARY OF PROGR AM 3 PREVENTION PROGRAM (40 CFR PART 68, SUBPART D)

SECTION TITLE OSHA PSM REFERENCE

§ 68.65 Process Safety I nformation PSM standard § 1910. 119(d).
§ 68.67 Process Hazard Analysis (PHA) PSM stan dard § 1 910.11 9(e).
§ 68.69 Operating Procedure s PSM stan dard § 1 910.11 9(f).
§ 68.71 Trai ning PSM standard § 1910. 119(g).
§ 68.73 Mechanic al In tegrity PSM stan dard § 1 910.11 9(j).
§ 68.75 Manage ment of Ch ange PSM standard § 1910. 119(l).
§ 68.77 Pre-Startup R eview PSM stan dard § 1 910.11 9(I).
§ 68.79 Comp liance A udits PSM stan dard § 1 910.11 9(o).
§ 68.81 Incident I nvestigation PSM s tan dard § 191 0.11 9(m)
§ 68.83 Employee Participation PSM stan dard § 1 910.11 9(c).
§ 68.85 Hot Wor k Perm it PSM stan dard § 1 910.11 9(k).
§ 68.87 Contrac tors PSM standard § 1910. 119(h).

OSHA provid ed guidance on PSM in non- mandatory appendix C to the stan dard. OSHA has reprinted th is appendix as PSM Gui delines for Complian ce (OSHA 3133). The OS HA g uidance is repro duced, reorder ed to tr ack pa rt 68, i n Appe ndix D. The remaind er of this chapter briefly outlines the major require ments and provides a discussion of any differences between EPA and OSHA. I n some cases, further guidance is p rovided on the m eaning of specific term s. For more detailed guida nce reg arding PSM req uirem ents, y ou shou ld refer to the O SHA g uidance in Appendix D.Chapter 7 7-3 Preven ti on Progr am (Progr am 3)



### Q S 

### &A S 

### I MPLEMENTAT ION AND 

### P ROG RAM 

### L EVEL

Q. My process is a series of storage and process vessels, con nected by piping , containing sev eral regulated substances, with a few co- located tanks of oth er substances. Do I have to im plement one prevention prog ram to cov er all aspects of the process even if different operato rs, different process chemistry, a nd different hazards a re involved in various parts of the process?

A. You should im plement the prog ram in the way that make s sense to you. For a com plex process such as yours, you may need to divide the process into sections (e. g., production units for particular products, storage u nits) for the PHA and compliance aud its, to keep the a nalyses man ageable. Operating and m aintenance procedures (and the training in these procedures) should be de veloped for
opera ting uni ts; co mbining pr ocedur es for diffe rent t ypes of un its in to a sin gle docu ment may make them harder to u se; training operators in procedures they do not need would w aste time and perh aps confuse operato rs. Yo u may want to collect and sto re proce ss safet y info rmatio n by i ndivid ual unit s to make it easier to use. Other p arts of the program (contractors, emp loyee participation, pro cedures for pre-startup, managem ent of change, a nd hot work) a re likely to be commo n to all parts of the process. In your RMP, y ou will report a sing le prevention prog ram for each cov ered process, whether you divide up the process or not.

Q. I have a tank with 1 ,000,000 pounds of toluene diisocyana te (TDI), which is covered under the RMP rule, but not un der OSHA PSM. Considered by itself, the TDI w ould be Program 2 for EPA. The tank , howe ver, i s close to equip ment that has chlorin e abov e the ap plicable thresho ld and i s subject to OSHA PSM a nd Program 3. Should the TDI tank be considere d part of the sam e process as the e quipm ent con taining the chl orine? How do es this affect th e prog ram le vel?

A. If a relea se event invo lving one reg ulated substance, such a s a fire, explosion, co llapse or collision, could also inv olve the release of a nother regulated subs tance or interfere with m itigation of such a r elease, then bo th subs tances, and the ir assoc iated v essels a nd equi pmen t are co nsidere d part of a single process. When you do your PHA for the process, yo u must ev aluate whether a release event involv ing the TDI tank could hav e such effects on the ch lorine, or whether a relea se event involving the chlorine cou ld affect the T DI tank. If a single release event could involve both the TDI and chlorine, then both are subject to both OSH A PSM and Prog ram 3.

7.2 PROCESS SA FETY INF ORMAT ION (§68.65)

Exhibit 7-3 briefly summ arizes the process safety information requirem ents.Chapter 7 Preven ti on Progr am (Progr am 3) 7-4



### EXHIBIT 7-3 PROCESS SA FETY INF ORMATION REQUIREME NTS

For chemicals, you must complete information on: 

### U Toxicity 

### U Permi ssible e xposure limit s 

### U Physi cal data 

### U Reactiv ity 

### U Corrosi vity 

### U Thermal & chem ical stability 

### U Hazardous effects of

inadvertent m ixing of
mater ials tha t could foreseeably occur For process technology, you must provide: 

### U A block flow d iagram or simplified process flow diagram 

### U Informa tion on process chem istry 

### U Maxim um in tended inven tory of the EPA- regulated chemical 

### U Safe upper & lower limits for

such items as tem perature, pressure, flows, or composition 

### U An evaluation of the

consequences of dev iation For equipment in the process, you must inclu de information on: 

### U Materials of construction 

### U Piping & instrum ent diagrams (P& IDs) 

### U Electrical classification 

### U Relief system design & design basis 

### U Venti latio n system de sign 

### U Design codes & standards employed 

### U Safe ty sys tems 

### U Material and energy balances for processes built after June 21, 1999

W HERE T O G O F OR M ORE I NFOR MATI ON

Diagrams. You m ay find it use ful to c onsult A ppendix B of O SHA' s PSM fi nal rule (fo r exa mple b loc k flo w and proc ess flow diagr ams), compu ter soft ware progr ams that do P&I Ds or other diagra ms.

Guidance and R eports. Various engin eering societi es issue technic al repor ts relating to process des ign. Other sou rces you m ay find useful includ e:



### � Guidelines for Process S afety Documentation , Center for Chem ical Process Safety of the Am erican Institute of Chemical Eng ineers 1995.



### � Emergency Relief System Design Using DIE RS Technology, American Institute of Ch emical Eng ineers, 1992.



### � Emergency Relief System s for Runaway Ch emical Reactions and Storage Vessels: A Summary of Multiphase Flow Methods , American I nstitute of Chemical Eng ineers, 1986.



### � Guidelines for Pressure R elief and Emergency H andling Systems, Center for Chemical Process Safety of the Am erican Institute of Chemical Eng ineers, 1998.



### � Loss Prevention in the Process Industries , Volumes I , II , and II I, Frank P. Lees, Butterworths: Lo ndon 1996.Chapter 7 7-5 Preven ti on Progr am (Progr am 3)



### Q S 

### & A S 

### P ROCE SS 

### S AFETY 

### I NFORMATI ON

Q. What does “m aterials of construction” apply to and how do I find this inform ation?

A. You mus t document the materials of construction for all process equipm ent in a covered process. For example, you need to k now the materials of construction for process vessels, storage vessels, piping, hoses, valves, and flanges. Equipm ent specifications should prov ide this information.

Q. What does “electrical classification” mean?

A. Equipmen t and wiring for lo cations where fire and ex plosion hazards m ay exist mu st meet requirements based on the hazards. Each room, section, or area m ust be considered separately

. Equipment shou ld be mark ed to show Class, Group, and operating temperature or tem perature range. You m ust dete rmine the app ropriate classifi cation f or each area an d ensur e that th e equip ment used is suitable for that classification. The equipment cov ered includes transform ers, capacitors, m otors, instruments, relay s, wiring, switch es, fuses, generato rs, lighting, alarms, rem ote controls,

commun ication, and groun ding. Electrical class ification will be included in equipment specifications.

Q. What does “relief sy stem design basis” mean?

A. Relief system s include, but are not limited to, relief v alves, relief headers, relief drums, and rupture disks

. Desi gn ba sis m eans do cume nting how the loads a nd siz es of th e relief system , as we ll as inlet and outlet size s, were determin ed. This includes a descriptio n of overpressure sc enarios considered, the scenario th at creates the largest load to be relieved, the assumptions us ed, and if the device meets a certain code. Relief devices on pressure vessels must conform to AS ME codes. Industry codes (e.g., A PI RP 5 20) also provide g uidance on scenarios that should be considered an d on equations for sizing of devices. Scenarios you may need to consider include fi re, blocked flow, control valve fa ilure, overheating , power outage , tube rupture, and cooling water failure. For twophase flow, yo u should review AIChE p ublications from the Design I nstitute for Emerg ency Relief Syste ms (D IER S).

Q. What do I have to do for m aterial and energy balances?

A. For new processes, you m ust document bo th material and ene rgy inputs an d outputs of a process. For example, you would do cument the quan tity of a regula ted substance added to the process, the quantity consum ed during the pro cess, and the quantity that remains in th e output. This requirem ent will not generally apply to storag e processes.Chapter 7 Preven ti on Progr am (Progr am 3) 7-6

7.3 PROCESS HA ZAR D A NAL YSIS (§68.67)

Exhibit 7-4 provides a sum mary of th e requirements for p rocess hazard analy ses (PHAs).



### EXHIBIT 7-4

PROCESS HA ZARD AN ALYSIS REQUI REMENTS

Techniques must be one or The PHA must co ver:: Other requirements: mor e of : 

### U Analysi s must be d one by a 

### U Identification of p revious, 

### U Wha t If 

### U Hazards of the pro cess team, one m ember of which potenti ally c atastrop hic 

### U Checklist has experience with the inciden ts 

### U What If/Check list
process, one m ember of 

### U Engineering a nd 

### U Hazard and Op erability Study which i s kno wledg eable admin istrativ e contro ls (HAZOP) about the PHA tech nique applicable to the haz ards 

### U Failure Mode an d Effec ts 

### U A system must be developed 

### U Consequence of failure o f Analysis (FMEA) for add ressing the tea m’s control s 

### U Fault Tre e Analy sis

recommen dations and 

### U Siting 

### U Appropriate equivalen t documenting resolution and 

### U Huma n factor s methodo logy corrective actions tak en 

### U Qualitative evalu ation of 

### U The PHA must be updated at health and safety im pacts of least on ce eve ry fiv e year s control failure 

### U PHAs and docum entation of actions must be kept for the life of the process

EPA/OSHA D IFFERE NCES

If your Program 3 process is also subj ect to OSHA PSM, you can use the PHA conducted for OSHA PSM compliance as your initial process hazard analysis for EPA purposes, pro vided you conducted your in itial OSHA PHA prior to May 26, 1997 (the date by which all initial OSH A PHAs m ust have been co mpleted). I n such
cases, you can also update and rev alidate your PHA on OSHA’s sch edule, but your update should consider o ffsite impacts. Lik ewise, any initial P HA performed after May 26 , 1997 must consid er offsi te imp acts in order fo r it to s atisfy EPA’s requirem ents (se e below ).

Offsite impacts. You should consider of fsite impacts when you condu ct a PHA under EPA' s rule (except for an initial P HA where yo u are using the P HA conducted for OSHA PSM). If yo u are in the Prog ram 3 prev ention program because you m ust comp ly wit h the P SM stand ard, y ou ma y not have f ully c onsider ed offsi te conseq uences becaus e the fo cus of P SM is wo rker pro tecti on. Prac tical ly speaki ng, there sh ould be few ins tances w here the scenari os cons idered f or OSH A fail t o address offsite impacts. A well- done PHA should identify all failure scenarios that could lead to significa nt exposure of work ers, the public, or the environment. The only issue that m ay require further con sideration for Part 68 purp oses is whether anyChapter 7 7-7 Preven ti on Progr am (Progr am 3)

protection measures that are adequate for work er safety are inadequa te for public and enviro nmental safet y.

Consider two circum stances — one where O SHA’s PSM standard and EPA’s risk
managem ent program rule lead to the sam e result, and another w here protecting workers could m ean endangering the public and the en vironment. For flamm ables,
any sc enario t hat cou ld affec t the pu blic alm ost cert ainly would h ave th e poten tial to affect workers; m easures taken to pro tect your em ployees likely will protect the public a nd the e nviron ment. For to xics un der PSM , howe ver, y ou ma y plan to address a loss of containm ent by ven ting toxic vap ors to the outside air. In each circumstance, a P HA should define h ow the loss of containm ent could occur. Howev er, for EPA, t he PHA team should reasses s vent ing as an app ropriate mitigation m easure.

R EJ ECT IN G T EA M R ECOMM ENDATI ONS

You m ay no t alway s agre e with y our PH A team 's re comm endatio ns and may wish to reject a recommen dation. OSHA' s compliance directiv e CPL 2- 2.45A(revised) states that you m ay decline a team recomm endation if you can document one of the following: (1) the analysis upon wh ich the recomm endation is based contains releva nt factu al error s; (2) th e recom mend ation is not nec essary to prot ect the health of employe es or contractors; (3) an altern ative measure would provide a sufficient level of protection; or (4) the recomm endation is infeasible. Fo r part 68, you may also decline a recom mendation if y ou can show that it is not necessary to protect public h ealth an d the en vironm ent.

U PDA TI NG A ND R EVA LI DA TI NG Y OUR PHA

For EP A and O SHA, you m ust upd ate and reval idate y our PH A at lea st once every five years. If your initial PHA was done for OSHA com pliance, you m ay update and revalidate it every five years on the OSHA schedule, but make sure tha t your PHA update considers offsite im pacts.

You should also upd ate or revalidate y our PHA whenev er there is a new haz ard or risk cr eated by changes to your pr ocess

. Such cha nges might i nclud e intr oduci ng a new pro cess, p rocess e quipm ent, or regul ated sub stance; altering proces s chem istry that results in any ch ange to safe operatin g limits; or o ther alteration that introduces a new hazard. You mig ht, for example, introduce a new haz ard if you installed a gas pipeline next to a storag e tank containing a regulated substan ce. Other candidates could be mak ing changes in process constituents that in crease the possibility of runaway reactions o r polymeriz ation. Or you may ha ve made major process chang es in order to com ply w ith a rev ision to an indu stry d esign code or standar d that y ou are subject to (i.e., your facility may be required to com ply with rev ised code requirements by a state law, local law or the languag e in the code itself). E PA also

recommen ds that you cons ider revalidating y our PHA whenev er adjoining processes create a hazard.

Rememb er that you hav e a general duty to prevent accidents and ensure safety at your source, w hich may require you to tak e steps beyond th ose specified in the risk
managem ent program rule.Chapter 7 Preven ti on Progr am (Progr am 3) 7-8



### Q & A “R EVIS ING 

### ” A 

### PHA

Q. The rule states that I have to update my RMP whenever I revise a PHA

. What constitutes a revised PHA? Every tim e I go through m anagement of change procedu res I m ake a notation in the PHA file for the proce ss, but would that co nstitute a revised PH A if the change did not affect the validity of the PHA?

A. All changes (e xcept replacement in kind) are subject to the managem ent of change of procedures. When pro cesses u nderg o min or chan ges (e .g., mino r rerout ing of a pipin g run) , inform ation is typically added to a PHA file to reflect the change, ev en though the v alidity of the PHA is not affec ted by th e modifi catio n. Thes e minor ch anges an d the ad ditio n of inf ormatio n about the cha nge to the PHA file are n ot considered a ' revision' o f the PHA under th e part 68. Major chang es that invalidate a PHA , leading y ou to 'upda te' or ' revalidate' th e PHA so that it ac curately reflects the hazards of the proc ess, are considered a rev ision of the PHA u nder part 68.

W HERE T O G O F OR M ORE I NFOR MATI ON

Appendix 7- A of this chapter prov ides a summ ary of each of the techniques, a description of the typ es of processes for which they may be appropriate, and estimates about the time and staff required for each.

Part 68 and OSHA PSM require that whiche ver technique or tech niques you use, you must have at least one person on the PHA team who is trained in the use of the technique. Training on such techniques is av ailable from a num ber of professional
organ izatio ns as w ell as p rivate comp anies. You m ay hav e staff m embe rs who are capable of providing this training as we ll. Many trade asso ciations publish detailed guidance on m ethods for conducting a process hazard analysis. You might find the followi ng do cume nts usef ul.



### � Guidelines for Hazard Evaluation Procedures, 2nd Ed. with W orked Examples , Center for Chem ical Process Safety o f the American Institute of Chemical Eng ineers 1992.



### � Evaluating Process Safety in the Chemical Industr y , Chemical Manufacturers Association.



### � Loss Prevention in the Process Industries , Volumes I , II , and II I, Frank P. Lees, Butterworths: Lo ndon 1996.



### � Management of Process Hazards (RP 750), Am erican Petroleum I nstitute.



### � Risk-Based Decision Making (Publication 1628 8) , American P etroleum Institute.Chapter 7 7-9 Preven ti on Progr am (Progr am 3)



### Q S 

### & A S 

### O FFSITE 

### C ONSEQUENCES

Q. What does EPA m ean by “consider offsite consequences”? D o we have to do an environm ental impac t assess ment (EIA )?

A. EPA does not expect you to do an EIA. Potential consequences to the public and the e nvironment are alre ady an alyz ed in th e offsite conseq uence a nalysi s. I n the P HA, E PA onl y exp ects y ou to identify any failu re scenarios that could lead to public exposures and to examine wh ether your strategies are adequate to reduce the risk of such exposures.

Q. If I need to revis e a PHA to cons ider off site con sequenc es, wh en do I have to do th at?

A. In g eneral, for a PHA originally com pleted to meet the requirements of O SHA PSM that did not consider offsite consequences, you should rev ise the PHA to con sider offsite consequences w hen you update that PHA. Any PHA for an RMP- covered process c ompleted or upd ated after August 1 9, 1996, when part 6 8 was effective, s hould examine offsite consequences.

7.4 OPERA TING P ROCED URES (§68.6 9)

Exhibit 7-5 summariz es what your o perating procedures m ust address. Operatin g procedures must b e readily accessible to workers who o perate or maintain th e process. You m ust review operating procedures as often as necessary to assure th at they reflect current practices and any chang es to the process or facility

. You m ust certify annually that the operating pro cedures are current and ac curate.



### EXHIBIT 7-5 OPERATIN G PROC EDURES REQU IREMENTS

Steps for each operating phase 

### U Initial startup 

### U Normal operations 

### U Temporary op erations 

### U Emergency shutdown 

### U Emergency operations 

### U Normal shutdown 

### U Start up foll owing a turnaround or emergency shutdown 

### U Locko ut/tag out 

### U Confin ed spac e entry 

### U Opening process equipment or pip ing 

### U Entranc e into t he facil ity Operatin g limits 

### U Consequences of

deviations 

### U Steps to avoid,

correct deviations Safety & h ealth considerations 

### U Chemical properties & hazards 

### U Precautions for preven ting chem ical exp osure 

### U Contro l mea sures fo r expos ure 

### U QC for raw m aterials and chem ical inv entory 

### U Special or unique haz ards Safety systems & their functions 

### U Address

whatev er is applica bleChapter 7 Preven ti on Progr am (Progr am 3) 7-10

W HERE T O G O F OR M ORE I NFOR MATI ON

Chapter 7 of this docu ment provid es descriptions of each op erating phase and when these phases may not apply to ce rtain operations.



### � Guidelines for Process S afety Fundamentals for General Plant Operatio ns , Center for Chem ical Process Safety o f the American Institute of Ch emical Engineers 1995.



### � Guidelines for Safe Pro cess Operations and Main tenance , Center for Chem ical Pro cess Sa fety o f the Am erican I nstitute of Che mical Engi neers 1995.



### � Guidelines for W riting Effective Operating an d Maintenance Procedures
, Center for Chem ical Process Safety o f the American Institute of Ch emical Engineers 1996.

7.5 TRA INING (§ 68.71)

You are require d to tra in new operato rs on th e opera ting p rocedur es and c over h ealth and safety haz ards, emerg ency operations, a nd safe work p ractices applicable to the employee' s tasks. At leas t every three years you m ust provide refresher train ing (you must consult with employees involved in operating the proce ss to determine the appropriate frequency). Finally, y ou are required to determ ine that each operator has received and unders tood the training and keep a record fo r each employ ee with the date of the training a nd the method used to verify that the employ ee understood the train ing.

W HERE T O G O F OR M ORE I NFOR MATI ON



### � Guidelines for Process S afety Fundamentals for General Plant Operatio ns , Center for Chem ical Process Safety o f the American Institute of Ch emical Engineers 1995.



### � Guidelines for Technical Planning for On-Site E mergencies , Center for Chem ical Pro cess Sa fety o f the Am erican I nstitute of Che mical Engi neers 1995.



### � Federally Mandated Training and Information ( Publication 12000)
, American Petroleum Institute.

7.6 MECHA NICA L INTEGRIT Y (§68.73)

You must ha ve a mechan ical i ntegri ty progra m for pres sure ves sels a nd stor age tanks, piping systems, relief and vent systems and devices, emergency shutdown system s, cont rols, an d pum ps. Ex hibit 7- 6 briefl y sum mariz es the o ther req uirem ents for your me chan ica l int egri ty pr ogra m.Chapter 7 7-11 Preven ti on Progr am (Progr am 3)

W HERE T O G O F OR M ORE I NFOR MATI ON

Guidance and R eports. Other sources of g uidance and reports y ou may find useful include:



### � Guidelines for Process E quipment Reliability Data with Data Tables , Center for Chemical Pro cess Safety of the American I nstitute of Chemica l Engineers 1989.



### � Guidelines for Process S afety Documentation , Center for Chem ical Process Safety of the Am erican Institute of Chemical Eng ineers 1995.



### � Pressure Vessel Inspection Code: Maintenance Inspection , Rating, Repair, and Alteration (API 510 ), American P etroleum I nstitute.



### � Tank Inspection, Repa ir, Alteration, and R econstruction (Std 65 3) , American Petroleum I nstitute.



### EXHIBIT 7-6 MECHANICAL INTEGRITY CHART

Written procedures 

### U Establish &

implement written procedu res to maintain the integrity of
process equipm ent. Training



### U Train process

maintenance employees in an overview of the
process and its hazards. 

### U Make sure this

training cover s the procedures applica ble to safe job performance. Inspection & testing 

### U Inspect & test

process equipm ent. 

### U Use recogniz ed and

generally accepted good engin eering practices. 

### U Follow a sched ule that matches the

manu facturer ’s

recommen dations or

more frequen tly if prior operating experience indicates is nece ssary. 

### U Document each

inspection & test with: Date, inspector name, equipment ID, test or inspection performed, results. Equipment deficiencies 

### U Correct

equipment deficiencies before further use of process equipment or whenever

necessa ry to

ensur e safe ty. Quality

assurance 

### U Establish a QA

program for new construction & equipm ent, ne wly installed equipm ent, maintenance materials, and spare parts & equipm ent.Chapter 7 Preven ti on Progr am (Progr am 3) 7-12

7.7 MANA GEMENT OF CH ANGE (§68.75)

Exhibits 7-7 briefly summ arizes EPA' s MOC requireme nts.

W HERE T O G O F OR M ORE I NFOR MATI ON



### � Management of Chang e in Chemical Plants: Learning from Case Histories
, Center for Chem ical Process Safety o f the American Institute of Ch emical Engineers 1993.



### � Plant G uidelin es for T echnica l Manage ment of Chemi cal Pro cess Sa fety
, Center for Chem ical Process Safety o f the American Institute of Ch emical Engineers 1992.



### � Management of Process Hazards (RP 7 50) , American P etroleum I nstitute.



### EXHIBIT 7-7 MANAG EMENT OF C HANGE REQ UIREMENTS

MOC procedures must address:



### U Technica l basis for th e change



### U Im pact on safety and hea lth



### U Modifica tions to operating procedures



### U Nece ssa ry ti me period for the change



### U Authorization requirements for
propos ed chan ge Employees affected by the change must:



### U Be informed of the

chang e before startup



### U Trained in the

chang e before startup Update proces s safety info rma tio n if:



### U A change cov ered by MOC pro cedures results in a change in a ny PSI required under E PA’s rule (see § 67.65) Update operating
pro ced ure s if:



### U A change cov ered by MOC procedu res resul ts in a c hange in any operating procedure required under E PA’s ru le (see § 67.69)Chapter 7 7-13 Preven ti on Progr am (Progr am 3)

7.8 PRE-S TA RTUP REVIE W (§68. 77)

You must con duct your pre- startup safety revie w for new stationary sources or modified stationary sources when the m odification is significant en ough to require a change in safety information. Y ou must condu ct your pre- startup review before you introdu ce a reg ulated s ubstanc e to a p rocess, and y ou mu st addre ss the i tems listed in Exhibit 7-8.



### EXHIBIT 7-8 PRE-STA RTUP REV IEW REQUIRE MENTS

Design Specifications 

### U Confirm that new or modified construction and equipment meet design specifications. Adequate Procedures 

### U Ensure that
proce dures for saf ety, operating, m aintenance, and em ergen cies are adequate and in place. PHA/MOC Perform a PHA and resolve or im plement any

recommen dations for new
process. Meet management of chan ge requirements for m odified
process. Training 

### U Confirm that each employ ee involved in the process has been train ed comple tely.

7.9 COMPLIA NCE A UDIT S (§68 .79)

You must con duct an audit of the pro cess to evaluate com pliance with the prev ention
program req uirements at least on ce every three years. At least o ne person involv ed in the audit must be knowledg eable about the process. You must d evelop a report of the findings and d ocument appropriate responses to each finding and documen t that deficiencies have been addressed. The two m ost recent audit reports m ust be kept on-site.

W HERE T O G O F OR M ORE I NFOR MATI ON



### � Guidelines for Auditing Process Safety Managemen t Systems , Center for Chem ical Pro cess Sa fety o f the Am erican I nstitute of Che mical Engi neers 1993.

7.10 INCIDENT INVESTIGA TION (§68.81)

Exhibit 7-9 briefly summ arizes the steps y ou must tak e for investigating incidents.Chapter 7 Preven ti on Progr am (Progr am 3) 7-14



### EXHIBIT 7-9 INCIDENT I NVESTIGA TION REQUIR EMENTS

U Initiate an inv estigation promptl y. Begin investig ating no later than 4 8 hours following the inciden t.


### U Establi sh a k nowled geabl e investigation team

. Establish an investig ation team to g ather the facts, analyze the event, and develop the how and why of what went wrong. At least one team m ember m ust have kn owledge of the p rocess involved. Consider adding other workers in th e process area where the incident occurred . Their knowledg e will be significant and should give y ou the fullest insight into the incident. Ide ally, emplo yees who m ay serve as investigation
team mem bers should be trained in investigation techn iques before an incident occurs.



### U Summariz e the investigatio n in a report. Amon g othe r thing s, the r eport m ust iden tify th e factor s contributing to the inc ident. Remem ber that identifying the root
cause may be more im portant than identifying the initiating
event. The report m ust also include any recomm endations for correcti ve act ions. R emem ber that the pur pose of the rep ort is to help manag ement take corrective action.



### U Address the team ’s findings and

recommen dations. Establish a system to address prom ptly and resolv e the incident report findings and recommen dations; document resolutions and corrective actions.



### U Review the repo rt with your

staff and contractors. You must sha re the report - its findings and recom mendations ­ with affected worke rs whose job tasks are relevant to the inciden t.


### U Retain the repo rt. Keep incident investig ation reports for five y ears.

You must inv estigate each incident w hich resulted in, or could have resulted in, a "catastrophic release of a reg ulated substance." A c atastrophic release is one that “presents an imm inent and substantial endan germent to public health and the enviro nmen t.” Al thoug h the ru le requi res yo u to inv estiga te only those i ncident s which resulted in, or c ould reasonably ha ve resulted in, a catastrophic release, EPA

encoura ges y ou to in vestig ate all a ccident al relea ses. I nvesti gating mino r accide nts

or near misse s can he lp you identif y prob lems that cou ld resul t in m ajor relea ses if left unaddressed.

W HERE T O G O F OR M ORE I NFOR MATI ON



### � Guideli nes for Investig ating C hemica l Proce ss Incid ents , Center for Chem ical Pro cess Sa fety o f the Am erican I nstitute of Che mical Engi neers 1992.



### � Guide for Fire and Explosion Investigations ( NFPA 921) , Natio nal Fire Protection Association.Chapter 7 7-15 Preven ti on Progr am (Progr am 3)

7.11 EMPLOYEE PA RTICIPA TION (§68.83)

The rule requires you to consult with you r employees and their representative s on the conduct and dev elopment of proce ss hazards analy ses and other required pro cess safety manag ement elem ents. Exhibit 7- 10 briefly sum marizes wh at you m ust do.



### EXHIBIT 7-10 EMPLOYEE PARTIC IPATION REQUIREME NTS

U Write a plan. Develop a written plan of action regard ing how y ou will implem ent employee p articipation.



### U Consul t with employees. Consult your em ployees and their rep resentatives regardin g conducting and developing PHAs and other elements of proc ess safety m anagement in the risk m anagement program rule.



### U Provi de acce ss to information. Ensure that your employees and th eir represen tatives have access to PHAs and all other inform ation required to be dev eloped under the rule.

7.12 HOT WOR K PER MITS ( §68.85 )

Exhibit 7-1 1 briefl y sum mariz es how to me et the h ot work perm it requi remen t.



### EXHIBIT 7-11 HOT WORK P ERMITS REQU IREMENTS

U Issu e a hot work permi t. You m ust issu e this p ermit for hot work conduc ted on o r near a covered process.



### U Implem ent fire prevention and protection. You must ens ure that the fire preven tion and protection requirements in 29 CFR 1910.252 (a) are implem ented before the hot work beg ins. The permit m ust document this.



### U Indicate the app ropriate dates. The pe rmit sho uld ind icate the dat es auth orized for hot work.



### U Identif y the work. The permit mu st identify the object on w hich hot work is to be performed.



### U Maintain the permit on file. You must k eep the permit on file until workers have comp leted the hot work operation s.

W HERE T O G O F OR M ORE I NFOR MATI ON



### � Standard for Fire Prev ention in Use of Cu tting and Welding Processes (NFPA 518), N ational Fire Protection Asso ciation.



### � Standard for W elding , Cutting and Brazing, 29 CFR 1910 Subpart Q.Chapter 7 Preven ti on Progr am (Progr am 3) 7-16

7.13 CONT RA CTOR S (§68 .87)

Exhibit 7-1 2 sum mariz es both yours and the contrac tors' respon sibilitie s where contractors perform m aintenance or repair, turnarou nd, major renov ation, or specialty work on or adjacent to a cov ered process.



### EXHIBIT 7-12 CONTRACTORS CHART

Your contractor must... You must...



### U Ensure training for its employ ees. The
a contra ctor, y ou mu st obtai n and e valua te 

### U Check safety performance

. When selecting
contrac tor m ust train its em ploye es to en sure information reg arding the safety performance that the y perf orm t heir jobs safely and in of the c ontracto r. accorda nce wit h you r source ’s safet y procedures. 

### U Provide safety and haza rds information. 

### U Ensure its employees kn ow process hazards

You must inform the contractor o f potential fire, explosion, or toxic release hazards; and o f and applicable emergen cy actions. The
your emerg ency response activ ities as they contractor must assu re that contract emp loyees relate to the contractor’s work and the process. are aware of hazard s and emerg ency proce dures relat ing to th e employee s’ work. 

### U Ensure safe practices

. You must ens ure that you have safe work practices to control the 

### U Document training. The contractor mus t entrance, presence, and exit of contract prepare a record docum enting and v erifying employees in covered process areas. adequa te emplo yee trai ning.



### U Verify that the contractor a cts responsibly. 

### U Ensure its employees are following your You must v erify that the contractor is fulfilling safety procedures. its responsibilities. 

### U Inform you of hazards. The contractor must tell yo u of any unique hazar ds prese nted by its work or of any hazards it finds du ring performance.

EPA/OSHA D IFFERE NCES

EPA has no autho rity to require that y ou maintain an occupational injury and illnes s log for c ontra ct emplo yees. Be aw are, ho wever, t hat OSHA does have this au thori ty, and that the PSM standard includes this requirem ent. (See 29 CF R 1910.1 19(h)(2 )(vi)).Chapter 7 7-17 Preven ti on Progr am (Progr am 3)

W HERE T O G O F OR M ORE I NFOR MATI ON



### � Contra ctor an d Clien t Relati ons to A ssure P rocess S afety , Center for Chem ical Pro cess Sa fety o f the Am erican I nstitute of Che mical Engi neers 1996.



### � API/CMA Managers Guide to Implementing a C ontractor Safety Program (RP 2221), Am erican Petroleum I nstitute.



### � Improving Owner a nd Contractor Safety P erformance (RP 2220) , American Petroleum I nstitute.Chapter 7 Preven ti on Progr am (Progr am 3) 7-18



## A PPEND IX 7-A PHA TECHNIQUES

This appendix provides descriptions of each of the PHA techniques listed in the OSHA PS M standard and in EPA ’s RMP rule at § 68.6 7. These descriptions include information on what each technique is, which ty pes of processes they may be appropriate for, what their limitations are, and what level of effort is ty pically associated with each. This information is based on Guidelines for Hazard Evaluation Procedures , 2nd Ed., pub lished by AI ChE/CCPS. I f you are interested in more detailed discussion and work ed examples, y ou should refer to the A IChE/CCP S volume

.

Neith er the infor mation b elow no r the fu ll AIChE/C CPS volume wi ll pro vide you wi th enou gh information to cond uct a PHA. The ru le requires that your PHA team in clude at least one person trained in th e tec hniq ue you use. Tra ini ng in P HA te chni ques is ava ila ble from a numbe r of o rgan izat ions

. If you must conduct multiple P HAs, you a re likely to ne ed to update you r PHAs frequently , or you hav e a comp lex proc ess that will ta ke sev eral we eks to analy ze, y ou ma y wan t to con sider tra ining one or m ore of your e mployees

. If you have a si ngle pro cess t hat is unlikel y to change more than once ever y five
years, you may find it more cost- effective to hire a trained PHA leader.

DESCRIPTIONS OF TECHNIQUES

C HECKLI STS

Check lists are prim arily u sed for process es that are cov ered by standar ds, cod es, and industr y practices — for exam ple, storage tank s designed to A SME standards, am monia handling covered by OSHA (29 CF R 1910.111), pro pane facilities subject to NFPA- 58. Checklists are easy to use an d can help fam iliariz e new s taff wit h the pr ocess e quipm ent. A ICh E/CCP S states that ch ecklis ts are a highly cost-effective way to identify customarily recognized haz ards. Checklists are dependent on the experie nce of t he peop le who devel op them ; if the check list is n ot com plete, t he anal ysis m ay no t identi fy hazardous situations.

Check lists are created by ta king the app licable standar ds and practice s and u sing t hem t o gener ate a lis t of que stions t hat seek to iden tify an y diff erences or defi ciencies

. If a check list for a process does not exist, an experienced person m ust develop one based on standards, p ractices, and facility or equipm ent experience. A completed check list usually prov ides "yes," "no," "not applicable," and "need more information" answers to each item. A checklist analy sis involves tou ring the process area and comparin g equipme nt to the list.

AIC hE/CCP S estim ates tha t for a s mall or simp le sys tem a check list wil l take 2 to 4 hours to
prepare , 4 to 8 hours t o eval uate the proces s, and 4 to 8 h ours to docum ent the results. For la rger o r mor e comp lex proc esses, a check list wil l take 1 to 3 days t o prepa re, 3 to 5 day s to ev aluate, and 2 t o 4 day s to docum ent.Chapter 7 7-19 Preven ti on Progr am (Progr am 3)

W HAT -I F

A What-I f is a brainstorming approach in which a group of peop le familiar with the process ask questions about possible d eviations or failures. These questions may be framed as What-If, as in "What if the pump fails?" or may b e expressions of m ore general concern, as in "I w orry about contam ination during unloading ." A scribe or recorde r takes down all of the questions on flip charts or a comp uter. The questions are then div ided into specific areas of in vestigation, us ually related to conseq uences of interest. Each area is then address ed by one or more team membe rs.

What-If analyses are intended to identify haza rds, hazardous situa tions, or accident scenarios. The team of experience d people identifies accident s cenarios, consequences, and existing safeg uards, then suggest possible risk reduction alternatives. The m ethod can be used to examine dev iations from design, construction, modification, or operating intent. I t requires a basic understand ing of the process and an ability to c ombine possible deviations from design intent with outcomes. A IChE describ es this as a powerful procedure if th e staff are experienced; "otherw ise, the results are like ly to be incom plete."

A What-I f usually review s the entire process, from the introduction of the c hemicals to the en d. The analy sis m ay foc us on p articula r conse quences of conc ern. A ICh E prov ides the follow ing ex ample of a Wha t-I f questi on: "Wha t if the raw m aterial i s the w rong c oncentr ation?" The team would then try to determine how the process would resp ond: "If the co ncentration of acid were d oubled, the reaction could n ot be co ntrolled and a r apid ex otherm would result. " The tea m m ight t hen rec omm end step s to prevent feeding wrong concentra tions or to stop the feed if the reaction could not b e controlled.

A What-I f of simple sy stems can be d one by one or two people; a m ore complex pro cess requires a lar ger t eam an d lon ger mee tin gs. AICh E/CC PS es tima tes that for a small or si mple s yste m a Wha t-If analysis will tak e 4 to 8 hours to p repare, 1 to 3 day s to evaluate the p rocess, and 1 to 2 days to docum ent the re sults

. For lar ger or more complex p roces ses, a W hat-If will take 1 to 3 days to pr epare , 4 to 7 days
to eva luate, a nd 4 to 7 day s to doc umen t.

W HAT -I F /C HECKLIST

A What-I f/Checklist com bines the creative, b rainstorming as pects of the What- If with the systematic app roach of the Check list. The combination of techniques can com pensate for the weak nesses of each. The What- If part of the process can help the team identify hazard s and accident scenarios that are bey ond the experie nce of t he team mem bers. Th e check list pro vides a mor e detail ed sys temat ic
approac h that c an fill i n gap s in the brainst ormin g proc ess. The techniq ue is g enerally used to identif y the most com mon haza rds that exist in a process. AIChE states that it is often the first PHA conducted on a process, with s ubsequent analyses using more detailed approaches.

The purpose of a What- If/Checklist is to identify haz ards and the gene ral types of accidents that could o ccur, e valua te quali tative ly the effects of the e ffects, and det ermin e wheth er safeg uards a re adequate. Usually the What-I f brainstorming precedes the use of the checklist, althoug h the order can be reversed.

The technique usually is performed by a team experienc ed in the design, operation, and maintenance of the process. The num ber of people required de pends on the com plexity of the process

. AIChE/C CPS estimates th at for a small or simple system a What-I f/Checklist analys is will take 6 to 1 2 hours to prepare, 6 to 12 hours to evalu ate the process, and 4 to 8 hours to docum ent the results. For larger or mo re com plex pro cesses, a What- If/C heckl ist will take 1 to 3 d ays to prepare , 4 to 7 days to evalu ate, an d 1 to 3 week s to doc umen t.Chapter 7 Preven ti on Progr am (Progr am 3) 7-20

HA ZOP

The Haz ard and Operab ility A nalysi s (HAZ OP) wa s orig inally devel oped to identif y both hazards and operab ility problems at chemical process plants, particularly for processes using technologies with w hich the plant was not familiar. The technique has been found to be useful for existing proces ses as w ell. A HAZ OP requ ires an interdis ciplinar y team and an experie nced te am le ader.

The purpose of a HAZ OP is to review a process or operation systematically to identify whethe r process deviations co uld lead to undesirable co nsequences. AI ChE states that the techn ique can be used for continuous or batch processes and can be a dapted to evaluate w ritten procedures. I t can be used at any stage in the life of a process.

HAZOPs u sually require a series of meetings in which, using process drawings, the team systematically evaluates the im pact of deviations. The team leader uses a fixed set of gu ide words and applies them to p rocess parameters at each point in the process. Guide words inclu de "No," "More," "Less," "Part of," "As well as," Rever se," and "Other t han." Process para meters considered include flow, pressure, temperature, level, com position, pH, frequenc y, and v oltage. As the team applies the g uide words to each process step, they record th e deviation, with its causes, consequences, safeguards, and actions needed, or the need for more in formation to ev aluate the deviation.

HAZOPs req uire more resources than simpler techniq ues. AIC hE states that a sim ple process or a review with a narrow scope m ay be done by as few as three or fo ur people, if they have the technical skills and experience. A large or c omplex process u sually requires a team of five to sev en people. AIC hE/CCP S estim ates tha t for a s mall o r simp le sys tem a HAZ OP ana lysis will tak e 8 to 1 2 hours to prepare , 1 to 3 days to eva luate th e proce ss, and 2 to 6 days t o docum ent the results. For la rger o r mor e complex proces ses, a HA ZOP will t ake 2 to 4 da ys to pre pare, 1 to 3 weeks to evalu ate, an d 2 to 6 wee ks to docu ment.

F AI LURE M ODE AND E FFECTS A NALYS IS (F ME A)

A Failure Mode and E ffects Analysis (FMEA ) evaluates the way s in which equipm ent fails and the system' s response to the failure. The focus of the FMEA is on single equipm ent failures and system failures. An FMEA usually generates recommendations for increasing equipment reliability

. FMEA does not examin e human errors directly, but will consider the impact o n equipment of human error. AIChE s tates that FMEA is "not efficien t for identifying an exhaustive list of combinations of e quipment failures that lead to accidents."

An FMEA produces a qualitative, sy stematic list of equipm ent, failure modes, and effects. The analy sis can easily be upd ated for desig n or sy stems chang es. The FMEA u sually produc es a tab le that, for each item of equipment, includ es a description, a list of failure modes, the effects of each failure, safeguards that exist, and actions recom mended to add ress the failure. For exa mple, for pum p operating normal, the failure modes would include fails to stop when required, stops when required to run, seal leaks or ruptures, a nd pump case leaks or ruptures. The effects would detail both the immed iate effect and the impact o n other equipmen t. Generally, w hen analyzing impacts, analy sts assume that ex isting safeguards do not work, AI ChE states that "m ore optimistic assum ptions may be satisfactory as long as all equipment failure modes are analy zed on the sam e basis."

An FMEA requires an equipment list or P&ID, knowledge of the equipment, knowledg e of the system , and r esponse s to equ ipmen t failure

. AI ChE sta tes that on av erage, an hou r is suff icient to analyze two to four pieces of equipm ent. AI ChE/CCPS estim ates that for a sma ll or simple sy stem anChapter 7 7-21 Preven ti on Progr am (Progr am 3)

FMEA will take 2 to 6 hours to prepare, 1 to 3 days to evaluate the proce ss, and 1 to 3 day s to document the results. For larg er or more com plex processes, an FME A will take 1 to 3 days to prep are, 1 to 3 weeks to ev aluate, and 2 t o 4 wee ks to docum ent.

F AULT T REE A NALYS IS (F TA)

A Fault Tree Analysis (FTA) is a deductive technique that focuses on a particular accident or main system failure and provides a method for determining c auses of the event. The fault tree is a graphic that display s the combinations of equipment fa ilures and human errors that can result in the accident. The FTA starts with the accident and identifies the immediate causes. Each im mediate cause is examined to d etermine its causes u ntil the basic causes of eac h are identified. AI ChE states that the strength of FTA is its ability to identify combinations of b asic equipment an d human failures that can lead to an accident, allow ing the analy st to focus preventiv e measures on significant basic causes.

AIChE s tat es th at FT A is we ll su ite d for anal yses of hi ghly r edun dant syst ems. Fo r sys tems vulnerable to sing le failures that can lead to a ccidents, FMEA or H AZOP are be tter techniques to use. FTA is often used when another technique has id entified an accident that requires more detailed an alysis. The FTA looks at com ponent failures (malfun ctions that require that the co mponent be rep aired) and faults (m alfuncti ons tha t will re medy them selves once th e condi tions ch ange)

. Failu res and faults a re divided into three g roups: primary failures and faults occur w hen the equipm ent is operating in th e environment for which it was intend ed; secondary failures and faults occur when the system is operating outside of intended env ironment; and com mand faults and failures are malfunctions where the equipm ent performed as desig ned but the system that comm anded it malfunction ed.

An FTA requires a detailed knowledg e of how the plant o r system w orks, detailed proces s drawings and pro cedures, and kn owledge of com ponent failure mod es and effects. AI ChE states that FTAs need well trained an d experienced analy sts. Although a single analys t can develop a fault tree, input and review from others is need ed

AIChE/C CPS estimates th at for a small or simple system an FTA will take 1 to 3 days to prepare, 3 to 6 days for model construction, 2 to 4 days to evaluate the proce ss, and 3 to 5 day s to document the results. For larger or more com plex processes, an FTA will take 4 to 6 days to prepare, 2 to 3 weeks for mode l constr uctions , 1 to 4 week s to ev aluate, and 3 t o 5 wee ks to docum ent.

Other Techniq ues

The rule allows you to use other techniques if they are functionally equivalent. The A IChE Guidelines inc ludes descrip tions of a number of other techniques incl uding Preliminary Hazard Review, Cause-Cons equence Analysis, Event Tree Analy sis, and Hum an Reliability Analy sis. You m ay also develop a hy brid technique that com bines features of seve ral techniques or apply more than on e technique.

Selecting a T echnique

Exhibit 7A- 1 is ada pted fro m the AIC hE Gui delines and ind icates w hich tec hniques are appropriate for particular phases in a process's design and operation

.Chapter 7 Preven ti on Progr am (Progr am 3) 7-22

EXHIBIT 7A-1

APPLICABILITY OF PHA TECHNIQ UES

Checklist Wha t-If What- IfChecklist HAZOP FMEA FTA

R&D 

### T
Design 

### T T T
Pilot Plant Operation 

### T T T T T T
Detailed Engineering 

### T T T T T T

Construction /Start-Up 

### T T T
Routine Operation 

### T T T T T T

Modification 

### T T T T T T

Incident I nvestigation 

### T T T T

Decomm issioning 

### T T T

Factors in Sele cting a Tec hnique

Type of process will affe ct your selection of a technique. AI ChE states that m ost of the techniques can be used for any process, but some are b etter suited for certain processes than others. FMEA efficiently analy zes the hazard s associated with com puter and electronic sy stems; HAZ OPs do not work as well w ith these. Processes or storage units desig ned to industry or governm ent standards can be handled with check lists.

AIChE lists What-If, What-I f/Checklist, and H AZOP as be tter able to handle batch p rocesses than FTA or FMEA be cause the latter do not eas ily deal with the n eed to evaluate the time-dep endent nature of batch operations.

Analysis of m ultiple failure situations is best ha ndled by FTA. Single-failure techniques, such as HAZOP an d FMEA, are not n ormally used to handle these althoug h they can be extended to evaluate a few sim ple acci dent sit uations invol ving more than on e even t.

AIChE s tates that when a process has operated relatively free of accidents for a lon g time, th e potential for high con sequence events is low, and there hav e been few chang es to invalidate the experie nce bas e, the l ess exh austiv e techn iques, such as a Chec klist, can be used. When the opposi te is true, the more rig orous techniques are m ore appropriate.

A fin al fa cto r in s ele cti ng a te chni que i s time requ ire d for vari ous t echn ique s. Exh ibi t 7A-2

summ arizes AIC hE's estimates of the tim e requir ed for v arious s teps. Th e full te am is usually invol ved in the evaluation step; fo r some techniques , only the team leader and scribe are inv olved in the prepara tion and documentation steps.Chapter 7 7-23 Preven ti on Progr am (Progr am 3)

EXHIBIT 7A-2

TIME AND STAFFING FOR P HA TECHNIQUES

Che cklist W hat-If W hat-If Che cklist HAZ OP FM EA FTA

Simp le/ Smal l Sy ste m

# Sta ff 1-2 2-3 2-3 3-4 1-2 2-3

Prepara ti on 2-4 h 4-8 h 6-12 h 8-12 h 2-6 h 1-3 d

Mo deling 3-6 d

Evalu ati on 4-8 h 1-3 d 6-12 h 1-3 d 1-3 d 2-4 d

Document ati on 4-8 h 1-2 d 4-8 h 2-6 d 1-3 d 3-5 d

Lar ge/C omp lex Pro cess

# Sta ff 1-2 3-5 3-5 5-7 2-4 2-5

Prepara ti on 1-3 d 1-3 d 1-3 d 2-4 d 1-3 d 4-6 d

Mo deling 2-3 w

Evalu ati on 3-5 d 4-7 d 4-7 d 1-3 w 1-3 w 1-4 w

Documentation 2-4 d 4-7 d 1-3 w 2-6 w 2-4 w 3-5 w

h = hou rs d = days (8 ho urs) w = weeks (4 0 hours)

## C H APT E R 8 : E M E R G E N C Y R E S P O N S E P R O G R AM

If you have at least one P rogram 2 or Program 3 process at yo ur facility, Part 68 requires you t o imp lemen t an em ergen cy res ponse p rogram if you r emp loyee s will respond to some releases involv ing regulated s ubstances. An em ergency respon se program co nsists of an emerg ency response plan , emergen cy response equipm ent procedures, emp loyee training, and procedures to ensure the program is up-to- date. (See the box on the next page for m ore information on What is Response?)

EPA re cogni zes th at, in s ome c ases (pa rticular ly for retailer s and o ther sm all operations with few em ployees), it m ay not be approp riate for employ ees to conduct response operations for releases of regulated substan ces. For exam ple, it would be ina ppro pri ate , and prob abl y unsa fe, f or an ammoni a ret ail er wi th on ly one full -time emplo yee to expect that a t ank fi re could be han dled wi thout th e help o f the lo cal fire department or othe r emergency responder. EPA does not intend to force such facilitie s to dev elop em ergen cy res ponse c apabilit ies. A t the sa me tim e, yo u are responsible for ensuring effective eme rgency respon se to any releases a t your facility. I f your local public responders are not capable of providing such response, you must take steps to ensure that effective response is available (e.g. , by hiring response contractors).



### 8.1 NON-RESPONDING FACILITIES (§ 68.90(b))

EPA has adopted a policy for non- responding facilities sim ilar to that adopted by OSHA in its Hazardous Wast e Operations and Emergency Respons e (HAZWOPER) Standard (29 CFR 1910.120), which allows certain facilities to dev elop an
emergency action plan to ensure e mployee sa fety, rather than a full-fledged
emergency response plan. I f your em ployees will not resp ond to accidental releases of regulated substance s, you need not comply with the emerg ency response plan and
progr am re quirem ents pro vided you c oordina te with local re sponse agenc ies to ensure that they w ill be prepared to respond to an emerg ency at you r facility. (You
may want to briefly revie w the p rogram desig n issues discuss ed in 8. 2 prior to making this decisi on.) Th is will help to ensure that you r communit y has a str ategy for responding to a nd mitigating the threat posed by a release of a reg ulated substan ce from your facility . To do s o, yo u mus t ensure that y ou hav e set up a way to notify emer gency respon ders wh en there is need for a re sponse. Coord ination with local respon ders al so enta ils th e foll owing:



### � If y ou hav e a cov ered pro cess wi th a reg ulated t oxic su bstance , you r facilit y must be included in the comm unity emerg ency response plan prepared under EPCRA rega rding a response to a potential release.



### � If y ou hav e a cov ered pro cess wi th a reg ulated f lamm able y ou mu st ensur e that the local fire departm ent is capable of respond ing to a potential relea se and aware of its respons ibility to do so.

Although y ou do not need to report on these coordination activities in yo ur risk

mana gem ent plan , to do cume nt you r efforts you s hould k eep a re cord of :Chapter 8 Emergency Response Program 8-2



### � The em ergen cy con tact (i. e., nam e or org anizat ion and numb er) that you w ill call for a toxic or flam mable release, and



### � The organization(s) tha t you work ed with on response procedures.



### What is “Response”?

For pur poses o f Part 6 8, “res ponse” has the same mean ing as that ter m has under OSHA’ s HAZWOPER Standard. OSH A defines emerg ency response as “a response effort by employees from outside the imm ediate release area or by other designated res ponders ... to an occurrence which results, or is likely to result, in an unco ntrolled release of a haz ardous substance.” The k ey factor here is that responders are designated for such tasks by their employer. This definition excludes “responses to incidental releases of hazardous substan ces where the substance can be absorbed, neutralized, or otherw ise controlled at the tim e of release by em ployees in the im mediate release
area, o r by m aintena nce per sonnel” as well as “res ponses to relea ses of h azardo us subs tances w here there is no pot ential s afety or healt h haza rd (i.e. , fire, explosi on, or chem ical exp osure). ” Thus, if you expect y our employ ees to take action to end a small lea k (e.g., shutting a valv e) or clean up a spill that does not pose a n immed iate safety or health h azard, this action co uld be considered an incidental response and y ou would not need to develop an em ergency respon se program if your employees are limited to such activities.

However, due to the nature of the reg ulated substances subject to EPA ’s rule, only the most min or incidents would be includ ed in this exception. In gen eral, most activ ities will qualify as a response due to t he im media cy of the disp ersion o f a toxi c plum e or spr ead of a fire, th e vola tilizat ion of a spill, and the threat to pe ople on and off site. As a result, if y ou will have y our employ ees involved in any substantial w ay in responding to releases, you will need to deve lop an emerg ency response program. Your emerg ency response proc edures need only apply to “response” actions; other activities will be described in your m aintenance and operating procedures.

The rem ainder o f this ch apter is applica ble only to thos e facilit ies whi ch will conduct at least som e emergency response operations them selves. As no ted above,
you may want to review the next section before m aking a dec ision on whether y our facility will take re sponsibility for condu cting any resp onse activities.

8.2 ELEMENTS OF A N EMERGENCY RESPONSE PROGRA M (§ 68.95)

If you will respond to releases of regulated substances w ith your own em ployees,
your emerg ency response prog ram mus t consist of the following elements:



### � An emerg ency response plan (maintained at the facility) that includes:

� Procedures for inform ing the public and emergency response agencies about releases
,

� Documentation o f proper first aid and em ergency m edical treatment necessary to treat hum an exposures, and

� Procedures and m easures for emerg ency response.Chapter 8 8-3 Emergency Response Program



### What is a Loca l Emergency Planning C ommittee?

Local emerg ency planning committee s (LEPCs) were form ed under the Em ergency Plann ing and Commu nity Right- to-Know Act (E PCRA) of 1986. The comm ittees are designed to serve as a

commun ity forum fo r issues relating to prep aredness for emerg encies involving releases of hazardous substances in their jurisdictions. They con sist of representatives from local govern ment (including law enforc ement and firefig hting), local industry , transportation group s, health and medical organ izations, com munity g roups, and the m edia. LEPCs:



### � Collect information fro m facilities on haz ardous substances that pos e a risk to the community; 

### � Develop a conting ency plan for the commun ity based on this information; and 

### � Make information on hazardous su bstances available to th e general public.

Contact the may or's office or th e county em ergency m anagement office for more inform ation on your LEPC.



### � Procedures for using , inspecting, testing , and maintainin g your em ergency respons e equip ment;



### � Training for all em ployees in relev ant procedures; and



### � Procedures to review and update, as app ropriate, the emerg ency response plan to reflect change s at the facility and ensure that employ ees are informed of changes.

Your plan mu st be coordinated with th e comm unity plan dev eloped under the Emergency Planning and C ommunity Right- to-Know Act (E PCRA, also k nown as SARA Title II I). I n addition, at the reques t of local emerg ency planning or response officials, you m ust provide any information necessa ry for develop ing and implementing the comm unity plan.

In k eeping with th e appro ach out lined in Chapte r 6, EP A is no t requir ing fa cilities to keep s pecific records docum enting trainin g and main tenance activ ities rel ated to
emergency response program s. It is en ough that facilities hav e on hand records sufficient to demons trate compliance w ith the training and maintenance requirem ents. H owev er, as n oted ab ove, facilitie s mus t main tain an on-s ite
emergency response plan as well as emergenc y response equipm ent maintenance an d
program ev aluation procedures.

Alth ough E PA's re quir ed el ement s are esse nti al to any eme rgen cy res pons e pro gram, they are not com prehensive gu idelines for creating an adequate response capability

. Rather than establish anoth er set of federal requirem ents for an emerg ency response prog ram, E PA ha s limi ted the p rovi sio ns of its r ule to th ose t he CAA manda tes

. If you have a regulated substance on site, you are already subject to at least on e emergency response rule: OSH A's em ergency action plan requirements (2 9 CFR 1910.38). Under OSHA HAZ WOPER, any facility that handles "haz ardousChapter 8 Emergency Response Program 8-4

substances" (a broad term that includes all of the C AA regulated su bstances and thus applies to all facilities with cov ered processes) mu st comply with either 29 CFR 1910.38(a) or 1910. 119(q). If you have a hazmat te am, you are subject to the 29 CFR 1910.119(q) requirements. I f you determ ine that the emerg ency response progr ams y ou hav e deve loped to comp ly wit h these other ru les satis fy the elem ents listed a t the be ginnin g of th is sectio n, yo u will n ot hav e to do anyth ing ad ditiona l to
comp ly wit h these eleme nts. A ddition al gui dance o n mak ing th is decis ion is provided in section 8.5.

In addition, be careful not to confuse writing a set of em ergency respon se procedures in a plan with dev eloping an em ergency respon se program. An emerg ency response plan is only one element of the integ rated effort that mak es up an emerg ency respons e prog ram. Althou gh the plan ou tlines th e action s and eq uipme nt nece ssary to respond effectively , training, prog ram evaluation , equipment m aintenance, and coordin ation w ith loca l agen cies m ust occu r regu larly i f your plan is to be u seful in
an emergen cy: The goal o f the program is to enable you to respond quick ly and effectiv ely to any e merg ency. The doc umen ts listed in Exh ibit 8- 1 may be help ful in deve lopi ng spe cif ic el ement s of yo ur eme rgen cy res pons e pro gram.Chapter 8 8-5 Emergency Response Program



### Exhibit 8-1 Federal Guid ance on Emerg ency Planning an d Response

Hazardous Materials Eme rgency Planning Guid e (NRT-1), N ational Response Team
, 2001. Although desig ned to assist com munities in planning for hazma t incidents, this guid e provides useful information on de veloping a re sponse plan, including planning team s, plan review, and ongoing planning efforts.

Criteria for Review of H azardous Materials Emerge ncy Plans (NRT -1A), Nati onal Resp onse Tea m, May 1988. This g uide provides criteria for evaluating respo nse plans.

Integrated Contingency P lan , National Response Team, (61 FR 28642, June 5, 1996). This provides guidance on how to consolidate m ultiple plans developed to comply with various federa l regulations into a single, func tional emergen cy response plan.

Emergency Response Guidebook , U.S. Departm ent of Transportation, 2000. This guidebook was developed jointly by the US Departm ent of Transportation, Transport Can ada, and the Secretariat o f Commu nications and Transportation of Mex ico (SCT) for use by firefighters, police, an d other
emergency services personnel w ho may be the first to arrive at the scene of a transportation incident involv ing a hazard ous m aterial. It is prim arily a guide to aid f irst resp onders in (1) q uickly identifying the s pecific or generic classificatio n of the material(s) in volved in th e incident, and (2) protecting them selves and the g eneral public during this initial response phase of the incident. The ERG is updated ev ery three to four y ears to accomm odate new products an d technology . The next version is scheduled for 2004. Copies are made availab le free of charge to public emerg ency responders through state emergenc y response coordin ators.

Respon se Infor mation Data S heets (RI DS), U S EPA and Na tional O ceanic a nd Atm ospheri c Administration. Developed for use with the Com puter-Aided Man agement of Emergency Operations (CAMEO) software, th ese documents o utline the properties, haz ards, and basic safety and response practices for thousands of h azardous chem icals.

Finally, rem ember that y ou are responsible for ensu ring that any release from y our processes can be handled effectively. If you plan to rely on lo cal responders for some or all of th e response, you must determ ine that those responders h ave both the equipment and training needed to d o so. If they do not, y ou must tak e steps to meet any needs, either by developin g your ow n response capabilities, dev eloping mu tual aid ag reeme nts with other f acilities , hiring respon se contr actors, or prov iding support to local responders so they can acquire equipm ent or training.

R ELA TI ONSH IP TO HAZWOPER

If you choose to establish and m aintain onsite emerg ency response capa bilities, then you will be sub ject to the detailed provisions of the OSHA or EPA HAZ WOPER Standard. HAZ WOPER covers preparing an em ergency respon se plan, employ ee training , med ical m onitorin g of e mploy ees, re cordk eeping , and o ther iss ues. C allChapter 8 Emergency Response Program 8-6

your s tate or f ederal d istrict O SHA of fice for more inform ation on comp lying with the HA ZWOP ER Sta ndard. State a nd loca l gov ernme nts in s tates wi thout a delegated OSHA program are subject to HAZWO PER under EPA 's 40 CF R part 311.



### Ho w Do es th e E me rg en cy R es po ns e P ro gr am Appl y?

The requirements for the emergency response program are intended to apply across all covered processes at a facility. Although certain elements of the p rogram (e.g ., how to use sp ecific items of
respons e equip ment) may differ f rom o ne proc ess to a nother, EPA d oes not intend or expe ct you to develop a separate emergency response program for each covered process. With this in m ind, you shoul d real ize that your emerge ncy resp onse pr ogram will probab ly apply t o your ent ire fa cilit y, although technically it need only ap ply to covere d processes.

For exa mple, a facili ty m ay hav e two s torage tanks , one c ontaini ng sli ghtly more than a thresho ld
quan tit y of a r egul ate d sub sta nce a nd on e wit h sli ghtl y les s. Th e fac ili ty is like ly to adop t the same response approach (e.g ., procedures, equipm ent, and training) fo r releases whether or not the process is “cove red.” Si milarl y, a faci lity may have two adj acent flammable s stor age tanks , one con taini ng a regulated substance ab ove the threshold a nd the other containing another, unlisted flam mable. The facility is likely to adopt the sam e approach for releases w hether or not the process is “covered.”

8.3 DE VE LO PI NG AN E ME RG EN CY RE SP ON SE PR OG RAM

The developmen t of an emerg ency response prog ram should be approached systematically

. As described in section 8.2, all facilities com plying with these emergency response program provisions wil l already be subj ect to OSHA HAZWOPER

. As a result, y ou are likely to fall into one of two groups:



### � You have already met severa l federal requirements for emergenc y planning and are inter ested in devel oping an integra ted pro gram to mini mize duplica tion (se ction 8. 4).



### � You have a p re-existing emergency response program (perhaps based on an internal policy decision) and need to determ ine what additional activ ities you will nee d to con duct (se ction 8. 5).

S TEPS FOR G ETTI NG S TARTED

The follo wing steps ou tline a s ystem atic app roach th at can s erve a s the fra mewo rk for the program development process in each of th ese cases. Following these initial steps will al low you to conduc t the re st of th e proce ss more ef ficie ntly.

Form an e mergenc y respo nse pro gram tea m. The team should consist of employees with varying degrees of em ergency respon se responsibilities, as well as
personn el with expertis e from each fu nctiona l area o f your facility

. You should consider including p ersons from the fo llowing departm ents or areas:



### � Maintenance; 

### � Operati ons or l ine pers onnel;Chapter 8 8-7 Emergency Response Program



### � Upper a nd line mana gem ent; 

### � Legal ; 

### � Fire and hazm at response; 

### � Environmen tal, health, and safety affairs; 

### � Training ; 

### � Securit y; 

### � EPCRA section 302 em ergen cy coo rdinato r (if one exists) ; 

### � Public relations; and 

### � Personn el.

The membersh ip of the team w ill need to be m ore or less extensive depending on the scope of the em ergency respon se program. A three-m ember team may be appropriate for a sm all facility with a coup le of process operators cross -trained as fire resp onders, while a facility with it s own h azm at team and en vironm ental af fairs department m ay need a doz en representatives.

Collect relevant facility documents. Mem bers of the dev elopm ent team should colle ct and r eview al l of the follo wing:



### � Existing emergency respon se plans and procedures; 

### � Submissions to the LEPC under E PCRA sections 302 and 303; 

### � Hazard evalu ation and release m odeling inform ation; 

### � Hazard c ommunicat ion and emergency r espons e trai ning; 

### � Emer gency drill an d exerc ise prog rams; 

### � After-action reports and response critiques; and 

### � Mutual aid agreem ents.

Identify existing programs to coordinate efforts. The team should identify any related program s from the follow ing sources:



### � Corporate- and industry- sponsored safety, tra ining, and plann ing efforts; and



### � Federal , state, and loc al gov ernme nt safet y, tra ining, and pla nning efforts (see Ex hibit 8- 2).Chapter 8 Emergency Response Program 8-8



### Exhibit 8-2 Federal Emergency Planning Regulations

The following is a list o f some of the fe deral emergen cy planning regulations:



### � EPA's O il Pollution Prevention Regulation (SPC C and Facility R esponse Plan Requirem ents)

- 40 CFR part 112.7(d) and 1 12.20-.21 ; 

### � MM's Facility R esponse Plan Reg ulation - 30 CFR part 254; 

### � RSPA's Pipeline Response Plan Regulation - 49 CFR part 19 4; 

### � USCG's Facility Response P lan Regulation - 33 CFR part 15 4, Subpart F; 

### � EPA's R isk Managem ent Program s Regulation - 40 CFR part 68 ; 

### � OSHA' s Eme rgenc y Act ion Pla n Reg ulation - 29 CFR 1 910.38 (a); 

### � OSHA's Process Safety Stan dard - 29 CFR 1910.119; 

### � OSHA's HAZWOPER Regulation - 29 CFR 1910. 120; 

### � OSHA’s Fire Brig ade Regulation - 29 CFR 1910. 156; 

### � EPA's R esource Conservation and Recovery Act Contingenc y Planning Requirements - 40 CFR part 264, S ubpart D, 40 CF R part 265, Subp art D, and 40 CF R 279.52. 

### � EPA' s Eme rgenc y Plan ning a nd Com munit y Rig ht-to -Know Act Re quirem ents - 40 CFR part 355. (These planning requirements apply to comm unities, rather than facilities, bu t will be releva nt when faciliti es are c oordina ting w ith loca l planni ng an d respo nse enti ties). 

### � EPA’s Storm water Regulations - 40 CFR 122. 26.

Facilities may also be subject to state and loca l planning requirem ents.

Determin e the st atus of e ach req uired p rogram e lement. Using the info rmation collected, you sho uld assess whether each required program element (see section 8.2) is:



### � In place and sufficient to meet the requirements of part 68;



### � In place, bu t not sufficient to m eet the requirements of Part 68; or



### � Not in place.

This examination will sh ape the nature of y our efforts to comp lete the emerg ency response program required under the risk managem ent program

. For exam ple, if you are alre ady in comp liance w ith OSH A's HAZW OPER Standar d, yo u hav e proba bly satisfied most, if no t all, of the requirem ents for an emerg ency response prog ram. Section 8.6 explains the intent of each of EPA 's requirem ents to help you determine whether you are already in com pliance.

Take additional actio ns as necessary.Chapter 8 8-9 Emergency Response Program

T AI LORI NG Y OUR P ROGRA M TO Y OUR H AZA RDS

If y our pro cesses a nd chem icals po se a v ariety of haz ards, it may be nece ssary to tailor some elem ents of your em ergency respon se program to these specific hazard s. Unless each part of y our program element is appro priate to the release scenarios that
may occu r, your em ergency respon se program cannot be fully effectiv e. Your program sh ould include core elem ents that are appropriate to m ost of the scenarios, supplemented w ith more specific resp onse information fo r individual scenarios. This dist inction should be refle cted in your e merg ency r esponse plan, which s hould explain when to access the general and sp ecific response inform ation. To do this, you will need to consider the following four steps:



### � Identify a nd characterize the ha zards for each cov ered process. The process hazards analysis (see Chapter 7) or haz ard review (see C hapter 6), and offsite consequence analy sis (see Chapter 4) shou ld provide this inform ation.



### � For eac h prog ram e lemen t, com pare the activ ities inv olved in resp onding to each ty pe of ac cident s cenario and de cide if t hey ar e differ ent eno ugh to require separate approaches. For example, response equipm ent and training will likely be different for releases of toxic v ersus flamm able gases.



### � For those program elements that m ay be chem ical- or process- specific, identify what and how system s and procedures need to be modified. For

exam ple, if existing mitig ation sy stems are ina dequate for resp onding to certain types of releases, you will need to consider what additiona l types of equipment are nee ded.



### � Consider possible causes of emergenc ies in developing your em ergency response program

. You should co nsider both the haz ards at your facility and in the s urround ing en vironm ent. I n mak ing th is deter minat ion, y ou shou ld consider your suscep tibility to:

� Fires, spills, and v apor releases;

� Floods, temperatu re extremes, tornad oes, earthquakes, and hurricanes;

� Loss of utilities, including power failures; and

� Train derailments, bom b threats, and other m an-mad e disasters.

8.4 INTE GRA TION O F EXIS TING P ROGRA MS

A number of other federal statutes and reg ulations require emerg ency response planning (see Exh ibit 8-2). O n June 5, 1996, the N ational Response Team (NRT), a multi-ag ency group chaired by EPA , published the I ntegrated Conting ency Plan Guidance in the Federa l Register (61 FR 28642). This guida nce is intended to be used by facilities to p repare emerge ncy response plans for responding to releases of oil and hazardous substances. The guid ance provides a m echanism for cons olidating multiple plans that y ou prepared to com ply with va rious regulations into a single, functional emerg ency response plan or integrated conting ency plan (I CP).Chapter 8 Emergency Response Program 8-10

The IC P gui dance d oes not chang e existi ng reg ulatory require ments ; rather , it provides a form at for organizing and presenting m aterial currently required b y regulations. I ndividual regula tions are often mo re detailed than the I CP guidance. To ensure full complian ce, you will still n eed to read and com ply with all of the federal regulations that ap ply. The gu idance contains a series of matrices design ed to assis t you in cons olidatin g va rious pl ans whi le docu menti ng co mplia nce wit h these federal requireme nts.

The NRT and the age ncies responsible for rev iewing and appro ving plans to which the ICP o ption applies have agreed that integ rated response plans prepared according to the guidance w ill be acceptable and the fe derally preferred m ethod of response planning. The NR T anticipates that future deve lopment of all fede ral regulations addressing em ergency respon se planning will inc orporate use of the I CP guidance.

As shown in Exh ibit 8-3, the ICP form at is organized into three main sec tions: an introductory section, a core plan, and a s eries of supporting an nexes. The notice published in the Federal Register explains the intended structure of the I CP and provid es detai led ann otation

. EPA 's E PCRA/ RCRA/ Superfu nd Hotl ine can supply you with a cop y and answer g eneral questions about the guidance; for further information and g uidance on com plying with specific regulations, y ou should contact the appropriate federal ag encies.

A N A PPR OAC H TO I NTE GRA TI ON

Like m any o ther fac ilities, you m ay hav e opted to dev elop an d mai ntain se parate documents and procedures for each federal emergency planning requirem ent. However, m eeting the Clean A ir Act emerg ency response requ irements prov ides you with the opportunity to integrate sev eral existing prog rams. I ntegrating the v arious
emergency response efforts you conduct (both those m andated by m anagement and by gov ernment) will increase the usefulness of y our emergen cy preparedness activities and decrease th e burden associated with maintaining m ultiple program s. Integration will improve your chances to respond effectively to a release by streamlining y our training and elim inating overlaps and conflicts in the roles an d
respons ibilities of yo ur em ploye es unde r differe nt prog rams. Howev er, it is important to note that, although y ou are encouraged to integrate y our emergen cy respons e effort s, it is not a re quirem ent of t he Clea n Air A ct.

If you have multiple emergency response program s, you should consider integrating them into a s ingle progr am w ith proc edures for resp onding to yo ur mo st like ly release scenarios. The I CP Guidance discusse d above prov ides comparison m atrices for a nu mber of fe deral programs t hat wil l help yo u accompl ish the follo wing:



### � Distinguish the indiv idual regulatory provisions with w hich you m ust comply, and



### � Iden tify w here an integ rated ef fort can meet the req uirem ents of two or more regulations.

The requirements of v arious emerge ncy response prog rams may be similar, but the subtle differences between req uirements will lik ely determine the degree to wh ichChapter 8 8-11 Emergency Response Program



### Exhibit 8-3 Integrated Contingency Plan Outline

Section I - Plan Introduction E lements

1. Purpose and Sco pe of Plan Coverage 2. Ta ble of Co ntents 3. Current Revisi on Date 4. Gener al Fa cil it y Ide nti fi cati on Inf ormat ion

a. Faci li ty name b. Owner/operator/agent (include physi cal and mailing address and phone number)

c. Physical add ress of the facility (include county/parish/boro ugh, latitude/longitude, and d irections) d. M ailing ad dress of the fac ility (corre spo nde nce c ontac t)

e. Other iden tif ying inf ormation ( e.g. , ID numbers, SIC Code, oil s torage s tart -up date ) f. Key contact (s) f or plan devel opment and maint enance g. Pho ne numb er for key contac t(s) h. Facili ty phone n umber I. Facili ty f ax number

Section II - Core Plan Elements

1. Discovery 2. Initial Response

a. Procedures f or int ernal and exter nal not ifi cati ons (i .e., contact , organi zati on name, and phone n umber of fac ili ty emer gency r esponse coordi nator, faci lit y res ponse team pers onnel, federal , st ate, and local officials) b. Est abl is hmen t of a re spon se ma nag emen t s ys tem

c. Procedures f or preli minary asses sment of the s itu ation, incl uding an i dentif icat ion of i ncident type, hazards i nvolved, magnit ude of th e problem, an d resources threa tened d. Pro ced ures fo r estab lishmen t of ob jective s and prior ities for resp onse to the sp ecific incid ent, includ ing: (1) Immediate goals/tacti cal planning (e. g., protecti on of workers and public as prioriti es) (2) Mitigat ing act ions ( e.g. , dis charge/ releas e control , conta inment , and recove ry, as appropria te) (3) Identification of resourc es required for response

e. Procedures f or implement ation of tac tica l plan f. Procedure for mobi liza tion of resource s 3. Sustained Actions 4. Termination and Follow-Up A ctions

Section II I - Annexes

Annex 1. Faci li ty and Loca li ty Inf ormat ion

a. Facil it y maps b. Facilit y drawings

c. Facilit y description/ layout, i ncluding identi ficati on of facili ty hazards and vulnerable res ources and populations on and off the faci lity which may be impacted by an incidentChapter 8 Emergency Response Program 8-12



### Exhibit 8-3 (continued)

Annex 2. Notif icat ion

a. Internal noti ficati ons b. Comm unity not ifi cations

c. Federal and state agency noti ficati ons Annex 3. Response Management Syst em

a. Ge neral b. Comm and

c. Operations d. Planning

e. Logist ics f. Fina nce/ procur ement /admi nis tra ti on Annex 4. Inci dent Document ati on

a. Post a ccide nt i nves ti gati on b. Incident hist ory Ann ex 5. T raining a nd E xercise s/Drills Annex 6 . Respo nse Critique and Plan Re view and M odification Pro cess Annex 7. Preven ti on Annex 8. Regul atory Compliance and Cross -Refer ence Matrices

integration is a feasible and beneficial undertak ing (see Exhibit 8- 4). To help you identify the releva nt rules and regulation s, the ICP Guidance provid es section-by -section reg ulatory citations for each emergency response program element for each o f the regulatory programs listed in Exhibit 8- 2.

8.5 HAVE I MET PA RT 68 REQUIREMENTS?

EPA believes tha t the creation of m ultiple response plans to m eet slightly different federal or state standards is co unterproductive, div erting resources that co uld be used to dev elop be tter resp onse ca pabiliti es. Ther efore, as part of the o verall effort t o reduce the impositio n of potentially dup licative or redundant fe deral requirements, EPA has limited its requirements for the emergen cy response prog ram to the g eneral provisions m andated by Con gress, as described in Section 8.2.

As a result, EPA believes that facilities subject to o ther federal emerg ency planning requirements m ay have alread y met the requirements of these regulations. For example, plans developed to com ply with other E PA contingency planning requirements and th e OSHA HAZ WOPER rule (29 CF R 1910.120) will lik ely meet the requirements for the emergen cy response plan (and most of the requirements for the emergen cy response prog ram). The follow ing discussion presen ts some g eneral guidance on wh at actions you need to take for each of the required elem ents.

E ME RGEN CY R ESPONSE P LAN

If you already have a written plan to com ply with another p lanning regulation , you do not need to write another plan, but only add to it as necessary to cover the elements listed below

.Chapter 8 8-13 Emergency Response Program



### Exhibit 8-4 Sample Integ ration Eff ort

Written site evacuation procedures are requir ed by sever al emergency planning regulations. In keeping with the spirit of the I CP Guidance, rather than preparing multiple sets of evacuation procedures (and possibly introducing dangerous error s as components are revised and upda ted), y ou may want to co mpile a sin gle set of proce dures tha t include s the spec ific elements mandated by all of the regulations. For example, I f you have one or more adjacent operating areas that evac uate to the same location(s), this approach will be very effective. On the other hand, if y ou have widely se parated operating area s with different evacuation routes and asse mbly points, inte gratio n will be le ss useful

.

Area Signal Escape R oute Assembl y Point Supervi sor
Shippi ng Room Horn Blue Fro nt Ga te Shippi ng Supe rvi sor

Contr ol Room Horn Green Parki ng Lot Lead Operat or

Tank Farm Rad io Red Side Ga te Inspe ctor

Keep in mind: At a minim um, yo ur plan must de scribe:



### � Your procedures for inform ing the public and offsite emerg ency response agenc ies of a release

. This m ust incl ude the group s and in dividu als that will be co nta cte d and why, t he mea ns by w hic h the y will be co nta cte d, th e time frame for notification, and the information that will be prov ided.



### � The proper first aid and em ergency m edical treatment for em ployees, first responders, and m embers of the pu blic who may have been exp osed to a release of a reg ulated s ubstanc e. This must include standar d safety precautions for victim s (e.g., apply water to exposed sk in immed iately) as well as more d etailed information for medical professionals. You must a lso indicate who is likely to be re sponsib le for p rovidi ng the approp riate
treatment: an em ployee, an em ployee with specializ ed training, or a medical profess ional.



### � Your pr ocedure s for em ergen cy res ponse i n the ev ent of a release of a regulated substance. This must include d escriptions of the actions to be taken by em ployees and other individuals on- site over the entire co urse of the rele ase ev ent:

� Activation of alarm systems an d interpretation of signa ls;

� Safe evacuation, a ssembly, and return;

� Selection of response strateg ies and incident com mand structure;

� Use of response equipm ent and other release m itigation activities; andChapter 8 Emergency Response Program 8-14

� Post-release equip ment and person nel cleanup and deconta mination.

P LA NNI NG C OORDI NA TI ON

If y ou hav e alread y coo rdinated with lo cal resp onse ag encies o n how t o respo nd to poten tial r eleas es of re gulate d subst ances and you have ensure d an eff ective response, you d o not need to tak e any further action.

One of the m ost important issues in an emerg ency response prog ram is deciding which response actions w ill be assigned to em ployees and wh ich will be handled by offsite personnel. As a result, talking to public response org anizations will be critical when y ou dev elop your em ergen cy res ponse p rocedur es. Alt hough EPA is not requ iring you to be able to resp ond to a releas e alone , you should not sim ply

assum e that lo cal resp onders will be able to mana ge an emerg ency. You m ust wor k with them to d etermine what they can do, and then expand your ow n abilities or establish mutual aid agreements o r contracts to handle those situations that will be left to you.

Keep in mind: Your coordination m ust involve p lanning for releases of regulated substan ces from all cov ered pro cesses a nd mu st cov er:



### � What offsite response assistance y ou will require for potential release scenarios, including fire-fighting , security, and notification of the public;



### � How you w ill request offsite response assistanc e; and



### � Who will be in charg e of the response operation and how will autho rity be delegated down the internal and offsite chain of comm and.

Coordination equiva lent to that required for plan ning for extrem ely hazardous substan ces und er EPC RA sec tions 30 2-30 3 will b e consid ered su fficient to me et this requirement. A more detailed disc ussion of this elem ent is provided in 8.6.

E ME RGEN CY E QUIPMENT

If you already have written procedures for using and maintaining your em ergency response equipmen t, you do no t need to write new procedures.

Keep in mind: Your p rocedur es mu st apply to any emer gency equipm ent rele vant t o a response involv ing a covered process, including all detection and m onitoring equipment, alarm s and comm unications system s, and personal protectiv e equipment not used as part of no rmal operations (and thus not subject to the prev ention program requirements related to operating procedures and maintenance). The procedures must describe:



### � How and wh en to us e the eq uipment proper ly;



### � How and when the equipment sh ould receive routine maintenance; andChapter 8 8-15 Emergency Response Program



### � How and when the equipment sh ould be inspected and tested for readiness.

Written procedures com parable to those necessary for process-related equipment unde r the OSHA P SM St anda rd an d EPA's Progr am 2 an d 3 Pr even tio n Pro grams will be conside red suff icient to meet this req uirem ent.

E MPLOYEE T RAI NING

If you already train yo ur employe es in how to respond to (or evacuate from ) releases of re gula ted subs tan ces, then you do not n eed a new t rai ning progr am.

Keep in mind: Your training must address the actions to take in res ponse to releases of regulated substance s from all cov ered processes. The training should be based directly on the proce dures that you ha ve included in y our emergen cy response plan and m ust be g iven t o all em ploye es and c ontracto rs on si te. I ndivid uals sho uld receive training a ppropriate to their responsibilities:



### � If they will only need to evacuate, then their training should cov er when and how to evacuate their location.



### � If th ey m ay nee d to act ivate an alarm syste m in r esponse to a rel ease ev ent, the n the ir t rai ning shou ld co ver wh en an d how to us e the alar m syste m.



### � If th ey wi ll serv e on an emer gency respon se team , then their tra ining should cover where em ergency equipment is deploy ed, how to use em ergency equipment and how the incident com mand syste m works

.
Emergency response training co nducted in com pliance with the OSH A HAZWOP ER Standar d and 2 9 CFR 1910.3 8 will b e consid ered su fficient to me et this r equirem ent.

R ESPONSE P LAN E VA LUA TI ON

If you already have a formal practice for regular review and updates of y our plan based on change s at the facility, y ou do not need to develop additional p rocedures.

Keep in mind: You m ust also identif y the types of chan ges to the fac ility t hat wou ld cause the plan to be u pdated (e.g., a new covered p rocess) and include a m ethod of

commun icating any ch anges to the plan to your em ployees (e.g. , through training ). You m ay wa nt to se t up a re gular schedul e on wh ich yo u revi ew yo ur entir e emergency response plan and iden tify any special conditions (e.g., a drill or exercise) that could result in an interim review.

8.6 COORDIN AT ION WIT H LOCA L EMER GENCY PLA NNING ENTI TIES (§ 68. 95(c))

Once you determ ine that you hav e at least one cove red process, you should open

commun ications with local em ergency plann ing and response officials, including your local em ergency plann ing comm ittee (LEPC) if one exists

. Because yo ur LEPC consists of representatives from man y local em ergency plann ing and response agencies, it is lik ely to be the best source of information on the critical emergency response issues in y our comm unity. Howe ver, in som e cases, there m ay not be anChapter 8 Emergency Response Program 8-16

active LEPC in your comm unity. I f so, or if your state has not designa ted your

comm unity as an em ergen cy pla nning district under E PCRA, you w ill lik ely ne ed to
contact local a genci es indiv idually to dete rmine which entities (e.g. , fire d epartm ent, emerg ency m anage ment agenc y, po lice dep artme nt, civ il defen se offic e, publ ic health agency) have jurisdiction for y our facility.

K EY C OORDINATION I SSUES

If you have any o f the toxic regulated substances above th e threshold quantity, you should have already designated an em ergency coord inator to work w ith the LEPC on chemical em ergency prepa redness issues (a requirem ent for certain facilities regulated under EP CRA). I f you have not (or if your fa cility has only regulated flammable substances), you may wan t to do so at this tim e. The emerg ency coordinator should be the individual m ost familiar with y our emerg ency response program (e. g., the person designated as hav ing overall resp onsibility for this prog ram in your m anagement system — see Chapter 5).

Involv ement in the activ ities of your LEP C can have a dramatically po sitive effect on
your emerg ency response prog ram, as well a s on your relationsh ip with the surrounding com munity. Your LEPC can provide technical assistan ce and guidance on a number of topics, such as con ducting response trainin g and exercises, developing m utual aid agreem ents, and evaluating public alert system s. The coordination process will h elp both the com munity and the facility prepare for an
emerg ency, reducin g exp enditur es of tim e and m oney, as well as help ing el imina te redundant efforts.

You should consider providing the LEPC with draft v ersions of any em ergency respons e prog ram e lemen ts relate d to loc al em ergen cy pla nning efforts

. This submission can in itiate a dialogue with the comm unity on potential p rogram improvem ents and lead to coordin ated training and ex ercise efforts. In return, your LEPC can support your emerg ency response prog ram by p roviding inform ation from its own emergency pl annin g effort s, incl uding:



### � Data on wind direction and weather conditions, or access to local meteorological data, to help yo u make decisions related to the ev acuation of employees and public alert notification;



### � Lists of emerg ency response training programs available in the area fo r training police, medi cal, an d fire d epartm ent pers onnel, to help you i dentify what training is alread y available;



### � Schedules of em ergency exercise s designed to test th e comm unity response plan to spur coordinated commun ity-facility exercises;



### � Lists of emerg ency response resou rces available from both public and privat e sourc es to he lp you determ ine whe ther and how a mutua l aid agreement co uld support your program; an dChapter 8 8-17 Emergency Response Program



### � Details on inci dent co mm and stru cture, e merg ency p oints of contac t, availability of em ergency m edical services, and public alert and notification systems.

Upon completio n of your em ergency respon se plan, you sh ould coordinate with the LEPC, local respons e organizations, local hospitals, and oth er response organiz ations (e.g., st ate hazmat team) and offer them a copy o f the pl an. In some in stanc es, onl y a portion of the plan m ay be of use to individuals or org anizations; in such cases, you should consider m aking only that portion of the plan available. For ins tance, it may be appropriate to send a hospital only the sec tions of your plan that address
emergency medical procedure s and decontam ination.

You may also want to prov ide your LEPC and local response entities with a description of your emergency response program elements, as w ell as any im portant subsequent amen dments or upda tes, to ensure that the co mmunity is aware of the
scope o f your facility respon se effor ts prior to an e merg ency. Altho ugh th e sum mary of your em ergency respon se program will be publicly av ailable as part of you r RMP, this information m ay not be as up -to-d ate or as comprehensive. Rem ember, the LEPC has been giv en the a uthority under E PCRA and Cle an Air A ct reg ulation s to request any inform ation necessary for p reparing the com munity respo nse plan.



### Planning f or Flammable Substances

In th e case o f regu lated fla mm able sub stances , the fi re depa rtmen t with jur isdictio n ove r your facility may already be conducting fire pre vention inspecti ons and pre-planning activit ies under its own authority. Your participation in these efforts (as re quested) will allow local res ponders to gather th e inform ation th ey nee d and p repare f or an em ergen cy. I f there i s no loc al fire d epartm ent, or if there is only a v olunteer fire departmen t in your area, y ou may need to contact other local response or plann ing offi cials (e.g., po lice) to dete rmine how you can wor k with the community.

## CHAPTER 9: RISK MANAGEMENT PLAN (PART 68, SUBPART G)

You must submit one risk management plan (RMP) to EPA for all of your covered
processes (§ 68.150). EPA has developed a system to submit your RMP via the Internet (RMP*eSubmit) for your use. Your RMP is due no later than the latest of the following dates:

• The date on which your facility first has a regulated substance above the threshold quantity in a process; or

• Three years after the date on which a regulated substance is first listed by EPA, if your facility has that regulated substance above the threshold quantity.

You must fully update and resubmit all nine sections of your RMP at least every five
years. Under certain circumstances, RMPs must be updated and resubmitted before their five­year anniversary (see 40 CFR §68.190(b)). Your five­year anniversary date is listed in the notification letter or e­mail that was sent to you after you submitted
your last RMP.

The Agency has an Internet­based system, called RMP*eSubmit, for submitting a

new RMP or making changes or corrections to an existing RMP. RMP*eSubmit is available on EPA’s Central Data Exchange (CDX)

– the Agency's electronic reporting site. If you are new to submitting RMPs, you should go to EPA’s public Web site at 

### www.epa.gov/emergencies/rmp to find instructions on how to obtain a CDX account and register as an RMP submitter or certifier in CDX.

Facilities that submit RMPs and later change their process(es) in ways that make them no longer subject to part 68 (e.g., switching to unregulated substances or reducing inventories of regulated substances to less than threshold quantities) must de­register their RMP within six months of making the change.

Finally, facilities submitting changes to their RMPs must identify the type of change being submitted and the reason for the change (e.g., submission of an updated RMP

as a result of a process change at the plant). This information will help implementing agencies understand the nature of the RMP submission being made.

9.1 ELEMENTS OF THE RMP

The length and content of your RMP will vary depending on the number and program levels of the covered processes at your facility. See Chapter 2 for detailed guidance

on how to determine the program levels of each of the covered processes at your facility.

Any facility with one or more covered processes must include in its RMP:

• An executive summary (§ 68.155);Chapter 9 Risk Management Plan 9­2

• The registration for the facility (§ 68.160);

• The certification statement (§ 68.185);

• A worst­case scenario analysis for each Program 1 process; at least one worst­case scenario analysis to cover all Program 2 and 3 processes involving regulated toxic substances; at least one worst­case scenario analysis to cover all Program 2 and 3 processes involving regulated flammables (§ 68.165(a));

• The five­year accident history for each process (§ 68.168); and

• Information concerning emergency response at the facility (§ 68.180).

Any facility with at least one covered process in Program 2 or 3 must also include:

• At least one alternative release scenario analysis for each regulated toxic substance in Program 2 or 3 processes and at least one alternative release scenario analysis to cover all regulated flammables in Program 2 or 3
processes (§ 68.165(b));

• A summary of the prevention program for each Program 2 process (§ 68.170); and

• A summary of the prevention program for each Program 3 process (§ 68.175).

Subpart G of part 68 (see Appendix A) describes the data required for each of the elements. RMP*eSubmit and its accompanying user’s manual contain more detailed instructions. RMP*eSubmit is designed to limit the number of text entries. For example, the rule requires you to report on the major hazards identified during a PHA

or hazard review and on public receptors potentially affected by worst­case and alternative release scenarios. RMP*eSubmit provides a list of options for you to check for these elements. Except for the executive summary, the RMP consists primarily of yes/no answers, numerical information (e.g., dates, quantities, distances), and a few text answers (e.g., names, addresses, chemical identity). Where possible, RMP*eSubmit provides “pick lists” to help you complete the form. For example, RMP*eSubmit provides a list of regulated substances and automatically fills in the CAS numbers when you select a substance. The RMP*eSubmit User’s Manual and on­line help screens explain each data element and provide guidance on acceptable data entry. Access to both RMP*eSubmit and the RMP*eSubmit User’s Manual is available free of charge

– for further instructions visit EPA’s Web site at www.epa.gov/emergencies/rmp.

9.2 RMP SUBMISSION

ELECTRONIC SUBMISSION

EPA has made RMP*eSubmit available to complete and file your RMP. RMP*eSubmit does the following:Chapter 9 9­3 Risk Management Plan

• Provides a user­friendly, Web­based RMP Submission System;

• Performs data quality checks, accepts limited graphics, and provides on­line help including defining data elements and providing instructions;

• Online reporting simplifies the process. It saves you time, and improves data quality and security;

• EPA uses industry­standard technology, including encryption used by most commercial banks, as well as stringent user ID and password protocols to protect your information; and

• You will be able to access your RMP online at any time.

For a facility to submit their RMP, the certifier will be required to have a CDX
account. Some facilities may use CDX to report other data to the Agency, and if your facility’s certifying official already has a CDX account, he/she can use it to obtain

access to RMP*eSubmit. If you are new to CDX, visit EPA’s public Web site at www.epa.gov/emergencies/rmp
, to learn how to obtain a CDX account and gain

access to RMP*eSubmit.

HARD COPY SUBMISSION

If you are unable to submit electronically you may fill out the Paper Submission form available in the RMP*eSubmit User’s Manual and send it in with your RMP. See the RMP*eSubmit User’s Manual for more information on the Paper Submission form. If you submit on paper, you will need to use the official form. If you do not use the official form, your RMP cannot be processed. You can download the RMP*eSubmit User’s Manual free of charge at www.epa.gov/emergencies/rmp.

IMPORTANT REMINDERS

If you submit on paper, do not forget your certification letter. A certification letter is required for all RMP submissions. See the RMP*eSubmit User’s Manual for more information on the certification letter.

If you use the RMP*eSubmit system, you will certify your RMP electronically

– however, you will be required to submit a one­time Electronic Signature Agreement form prior to the first time you submit an RMP using RMP*eSubmit. The CDX system will guide you through the ESA process when you first register for CDX

access as an RMP certifying official.

EPA’s old PC­based electronic reporting software

– RMP*Submit

– will no longer be available for download from the EPA Web site beginning in March 2009.

WHERE DO I SEND MY RMP?Chapter 9 Risk Management Plan 9­4

If you use RMP*eSubmit, your RMP will be submitted over the Internet. The
process will require you to complete and mail a one­time Electronic Signature Agreement to EPA prior to your first RMP submission using RMP*eSubmit.

If you submit a hard copy RMP, you must also include a certification letter (see the RMP*eSubmit User’s Manual for more information on the 

### certification letter). After completing the certification letter and RMP forms, you should send them together via certified mail to:

Risk Management Plan (RMP) Reporting Center P.O. Box 1515 Lanham­Seabrook, Maryland 20703­1515

For courier and FEDEX packages, the address is: Risk Management Plan (RMP) Reporting Center c/o CSC Suite 300 8400 Corporate Drive New Carrollton, Maryland 20785

9.3 ISSUES PERTAINING TO SUBMISSIONS OF AND ACCESS TO CLASSIFIED, CONFIDENTIAL BUSINESS INFORMATION (CBI), AND TRADE SECRETS

WHAT SHOULD I DO ABOUT CLASSIFIED INFORMATION?

Only Federal agencies and their contractors at Federal facilities may make claims of classified information. If you have such a claim, EPA urges you not to submit the information you claim as classified as part of your RMP. If any classified information is critical to the clarity and completeness of any part of the RMP, you should submit that information separately, on paper, in an annex to the RMP. Any

annex marked as classified will be reviewed only by Federal and state representatives who have received security clearances and are thereby authorized to review such information.

WHAT SHOULD I DO ABOUT CONFIDENTIAL BUSINESS INFORMATION (CBI)?

Under CAA section 114(c), 40 CFR part 2 and part 68, you may claim some information included in your RMP as CBI if you are able to show that the information meets the substantive criteria set forth in 40 CFR 2.301. These criteria generally require that the data be commercial or financial in nature, that they not be available to the public through other means, that you take appropriate steps to prevent disclosure, and that disclosure of the data would be likely to cause substantial harm to your competitive position. Review of any CBI claims will be handled as provided for in 40 CFR part 2. However, part 68 provides that certain RMP data elements may not be claimed as CBI because they do not convey any business­sensitive information. EPA has developed specific procedures for submission of CBI claims for RMPs. See §§ 68.151 and 68.152 for details on what data may be claimed as CBI and how to assert such claims. It is worth noting that few CBI claims have been asserted since RMPs were first submitted in 1999.Chapter 9 9­5 Risk Management Plan

In general the part 68 procedures provide that:

• Owners or operators must substantiate CBI claims at the time they make the claim by providing documentation demonstrating that the claim meets the criteria
set forth in 40 CFR 2.301.

• Substantiating information may be claimed confidential by marking it as CBI. Information that is not so marked will be treated as public and may be disclosed without notice to the submitter. If substantiating information is claimed confidential, the owner or operator must provide a sanitized and unsanitized version of the substantiating information.

• The owner, operator, or senior official with management responsibility of the stationary source must sign a certification that the signer has personally examined the information submitted and that, based on inquiry of the persons who compiled the information, the information is true, accurate, and complete, and that those portions of the substantiation claimed as confidential would, if disclosed, reveal trade secrets or other confidential business information.

If your RMP will include CBI, contact the RMP reporting center by phone at (301) 429­5018 or by e­mail at userrmp.usersupport@csc.com to obtain instructions on how to complete your submission.

9.4 RMP UPDATES, CORRECTIONS AND DE­REGISTRATIONS (§ 68.190)

Whether and when you are required to fully update and resubmit, correct, or deregister your RMP is based on what changes occur at your facility. Please refer to the Exhibit 9­1 and note that you are required to take action with regard to your RMP on the earliest of the dates that apply to your facility. In some cases, changes at the facility may require only a partial revision of the RMP or a simple correction of administrative or emergency contact information. Exhibit 9­1 also covers these situations.

Corrections to submissions made in hardcopy form or via the Agency’s previous electronic reporting software (RMP*Submit) will need to be made in RMP*eSubmit. Regardless of how you submitted your last RMP, all data for your current RMP will be available via RMP*eSubmit, and can be corrected on­line as necessary.

C AN I F ILE P REDICTIVELY ?

Predictive filing is an option that allows you to submit an RMP that includes regulated substances that may not be held at the facility at the time of submission. This option is intended to assist facilities such as chemical warehouses, chemical distributors, and batch processors whose operations involve highly variable types and quantities of regulated substances, but who are able to forecast their inventory with

some degree of accuracy. Under § 68.190, you are required to update and resubmit
your RMP no later than the date on which a new regulated substance is first presentChapter 9 Risk Management Plan 9­6

in a covered process above a threshold quantity. By using predictive filing, you will
not be required to update and re­submit your RMP every time you receive a new regulated substance if that substance was included in your latest RMP submission (as long as you receive it in a quantity that does not trigger a revised offsite consequence analysis as provided in § 68.36). RMP*eSubmit contains an option to indicate that
your RMP is a predictive filing.

If you use predictive filing, you must implement your Risk Management Program and
prepare your RMP exactly as you would if you actually held all of the substances included in the RMP. This means that you must meet all rule requirements for each regulated substance for which you file, whether or not that substance is actually held

on site at the time you submit your RMP. Depending on the substances for which
you file, this may require you to perform additional worst­case and alternative­case scenarios and to implement additional prevention program elements. If you use this option, you must still update and resubmit your RMP if you receive a regulated substance that was not included in your latest RMP. You must also continue to comply with the other update requirements stated in § 68.190.Chapter 9 9­7 Risk Management Plan



### EXHIBIT 9­1 RMP UPDATES, CORRECTIONS AND DE­REGISTRATIONS Change That Occurs Date by Which You Must Update, Correct or De­register your RMP
No changes occur At least once every 5 years from its initial submission or most recent update

A newly regulated substance is first listed by EPA Within 3 years of the date EPA listed the newly regulated substance if your facility has more than a threshold quantity of that substance in a process

A regulated substance first becomes present above its threshold quantity in:

­ a process already covered; or

­ a new process On or before the date the quantity of the regulated substance exceeds the threshold in the process

A change occurs at your facility that requires a revised PHA or hazard review Within 6 months of the change

A change occurs at or near your facility that requires a revised offsite consequence analysis (e.g., you increase your inventory of a regulated substance such that it increases the distance to the endpoint by a factor of 2 or more, or a new public receptor is constructed

near your facility) Within 6 months of the change

A change occurs that alters the Program level that previously applied to any covered process Within 6 months of the change

An accidental release meeting the reporting criteria of § 68.42 occurs at your facility Add to and correct accident history information and incident investigation data elements within 6 months of the date of the accident (revising other RMP sections is not required unless facility changes resulting from an accident trigger a full update)

Facility emergency contact information changes Correct the emergency contact information within

one month of the change (revising other RMP elements is not required).

Minor administrative change (i.e., correct a clerical error or supply additional information) Correct the information as soon as practicable (revising other RMP elements is not required).

A change occurs that makes the facility no longer subject to the requirement to submit an RMP Submit a de­registration letter to EPA within 6 months of the change, indicating that the RMP is no longer requiredChapter 9 Risk Management Plan 9­8

H OW D O I D E ­R EGISTER ?

If your facility is no longer covered by this rule, you must submit a letter to the RMP Reporting Center within six months indicating that your stationary source is no longer covered.

R ECURRING A CCIDENT P REVENTION P ROGRAM R EQUIREMENTS

Don’t forget that in addition to updating your RMP submission, the Risk Management Program regulation contains various recurring implementation requirements for covered facilities’ accident prevention and emergency response programs. When you update your RMP, you should ensure that you are up to date with implementation of these requirements and that your updated RMP reflects the
most recent information for your prevention and emergency response programs. The following is a list of some key elements in your RMP that you should review, as well

as recurring prevention and emergency response program implementation requirements that you should make sure are completed:

• Review and update your offsite consequence analyses (OCA) at least once every 5 years (40 CFR 68.36).

For your worst­case and alternate­case scenarios, you should review your documentation to determine that the parameters and assumptions used in the analyses are still appropriate. Such assumptions include the use of any administrative controls or passive mitigation, the estimated quantity released, the release rate, and the duration of release. The results of this review should be documented and maintained as part of your RMP records. Any changes to the scenarios resulting from this review, including changes in the distance­toendpoint, should be reported in your updated submission.

You should review the data used to identify and estimate population and environmental receptors to be sure that it is current. For example, new construction in your area may have resulted in public receptors closer to your facility than was the case when you first conducted the OCA for your facility. Also, you may have used Census data to estimate the residential population within the distance to endpoint. If so, you should update this estimate based on the latest Census data. Census data can be found in publications of the US Census Bureau. These publications, including the County and City Data Book,

are available on the Census Bureau website (www.census.gov) and in public libraries.

• For Program 2, review and update your hazard review at least once every 5 years (40 CFR 68.50).

The review and any updates of the hazard review, as well as resolution of any problems identified, must be documented. You should report the date of your most recent hazard review update, and the completion date for any changes resulting from the hazard review, in your RMP update.Chapter 9 9­9 Risk Management Plan

• For Program 3, update and revalidate your process hazard analysis (PHA) at least

once every 5 years (40 CFR 68.67).

This revalidation must be conducted by a team with expertise in engineering and
process operations. The team must include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific PHA methodology being used. The revalidation is intended to assure that the PHA is consistent with the current process.

To revalidate your PHA, you should evaluate your current process hazard analysis for accuracy and completeness. This evaluation should include checking that all modifications to your process are reflected in the PHA; evaluating the
process safety information to ensure that it is complete, current, and accurate; verifying that operating procedures are adequate, up­to­date, and implemented; documenting that PHA recommendations have been incorporated into equipment design, process conditions, mechanical integrity, operating procedures, training, and emergency response; verifying that recommendations have been implemented; reviewing incident investigation reports. Updated and revalidated PHAs completed to comply with OSHA’s Process Safety Management Standard (29 CFR 1910.119(e)) are acceptable to meet this requirement as long as they also considered hazards that could result in off­site consequences.

The revalidation and any updates of the process hazard analyses, as well as resolution of any recommendations, must be documented. This documentation
must be retained as part of your RMP records for the life of the process. You should report the date of your most recent process hazard update, and the completion date for any changes resulting from the process hazard update, in
your RMP update.

• The Risk Management Program requires several aspects of your prevention
program to be periodically implemented or reviewed. The most recent dates for these activities should be reported in your RMP update:

Training in operating procedures (40 CFR 68.54 and 68.71): For both Program 2 and 3, you are required to provide refresher training at least every three years, and more often if necessary.
Compliance audits (40 CFR 68.58 and 68.79): For both Program 2 and 3, you are required to audit your procedures and practices for compliance with the Risk Management Program regulations at least every three years to verify their adequacy and implementation.

Maintenance/Mechanical Integrity (40 CFR 68.56 and 68.73): For both Program 2 and 3, you are required to inspect and test your process equipment according to the schedule that you have established based on good engineering practices.

Operating procedures (40 CFR 68.89): For Program 3 only, you are required to certify annually that your operating procedures are current and accurate.

Management of change (40 CFR 68.75): For Program 3 only, you are required toChapter 9 Risk Management Plan 9­10

update your process safety information and your procedures and practices for a covered process in the event of any change to the process chemicals, technology, equipment, or procedures.

• Correction of your five­year accident history.

You must submit a correction that revises your five­year accident history within six months of an accidental release of a regulated substance from a covered
process that resulted in deaths, injuries, or significant property damage on site, or known off­site deaths, injuries, evacuations, sheltering in place, property damage,

or environmental damage.

• Verify your process information.

Although you have an ongoing responsibility to monitor whether changes to your process or to the quantities stored or handled alter your program level eligibility,
your five­year update is an opportunity to verify that each covered process still
meets the eligibility criteria for its program level.

• Review your emergency response program or coordination with local officials.

If your employees will take part in responding to accidental releases, you are required to periodically review and update, as appropriate, your emergency response program and to notify your employees of any changes to your emergency response plan (40CFR 68.95). You must include the date of your most recent review of your emergency response program and most recent training in your re­submission. You should contact your Local Emergency Planning Committee (LEPC) to verify whether your facility is currently included in the community emergency response plan. You should also review and update your procedures for notifying emergency responders in an emergency. These last two steps are particularly important if your employees will not respond to accidental releases.

## CHA PTER 10: IMPLEMENT A TION

10.1 IMPLEMENTING AGENCY

The implementin g agency is the federal, state, or local agency that is taking the lead for implem entation and enforcem ent of part 68 or the s tate or local equivalent. The implementing agency w ill review RMPs, s elect some RMPs for audits, and conduct on-site inspections

. The implem enting agency should be you r primary co ntact for information and ass istance.

W HO I S M Y I MPLE MENTI NG A GENCY ?

Under the CAA, EPA will serv e as the implem enting agency until a state or local
agenc y seek s and is grant ed dele gation under C AA sec tion 11 2(l) and 40 CFR part 63, subpart E. Y ou should check with the EPA Reg ional Office to determ ine if your state or county has been granted deleg ation or is in the process of seeking d elegation. The Regional Office w ill be able to provid e contact names at the state or local lev el. See http://yosem ite.epa.gov/o swer/ceppoweb.nsf/conten t/regions.htm for addresses and contact inform ation for EPA Reg ional offices.

I F THE P RO GR A M I S D ELEGATED , W HAT D OES T HAT M EAN ?

To gain deleg ation, a state o r local a gency must demo nstrate that it h as the a uthority and resources to im plement and enfo rce a chemical accid ent prevention prog ram that is at l east a s stri ngent as part 68

. Some stat es and l ocali ties may ch oose to take delegation of the pro gram for so me, but not all, of the substances reg ulated under part 68. I n the case of states and localities that take only “partial delegation” of the
program, EPA is the im plementing a gency for the regulated substances not covered by the stat e or l ocal progr am.

When EPA determ ines that a state or local ag ency has the requ ired authority and resources, EPA m ay grant the program full or partial approval dep ending on whe ther the state or local prog ram covers all or just some reg ulated substances. For those regula ted sub stances cover ed, if t he state or loca l rules d iffer fro m par t 68 (a s tate’s rules are allowed to differ in certain specified respects, as discussed below), EP A will adopt, throug h rulemaking , the state or local prog ram as a substitute for part 68 in the state or locality, making the state program federally enforceable. In m ost cases, the state or locality will take the lead in implementation and enforcem ent, but EPA maintains the ability to enforce the state or local rules wh ich EPA adopted fo r that jurisdiction. Should EPA decide that it is necessary to take an enforc ement action against a facility in a delegated state or locality, the action would be based on the state or local rule that E PA adopted as a su bstitute for part 68. Sim ilarly, citizen actions under the CAA would be based on the state rules that EPA adopted.

Although states and localities may choose to cover only a subset of part 68 regulated substances, they m ay not add or d elete substances from the part 68 list of reg ulated substances; only EP A may determine the list of regulated substances fo r part 68
purposes. States and localities that take deleg ation are also not free to modify the form and m anner o f RMP re porting (althou gh the y m ay add to RMP require ments ). Any state or local program m ust require covered fa cilities to submit RMP s asChapte r 10 Imple menta ti on 10-2

provided by part 68, Subpart G. Consequently, even if yo u are located in a state o r local jurisdiction that has taken delegation of the pa rt 68 program , you will con tinue to file an RMP in the fo rm and m anner specified by E PA to the central location EPA design ates. Y ou shou ld chec k with your state to determ ine whe ther y ou need to file additio nal data for stat e use or subm it ame nded co pies of the RMP with th e state t o cover state elem ents or substances.

If y our stat e or loc ality h as been grant ed dele gation , it is i mport ant that you c ontact your state or local im plementing a gency to d etermine if the state o r locality has requirem ents in additio n to tho se in pa rt 68. State an d local rules m ay be more stringent than part 68

. This document does not cover state and local requirem ents.



### Qs & As Delegation

Q. What states have been granted deleg ation?

A. The following state s have been g ranted full or partial deleg ation:

Delawa re Florida Georg ia Kentu cky Mississippi New Jersey North Carolina North D akota Ohio South Carolina

In a ddition , the fo llowing territor ies and local juri sdiction s have been g ranted d elegat ion: Pu erto Rico, t he Virg in Is lands, Alleg heny County (PA), Jefferson County (KY), a nd Fors ythe C ounty (NC).

Check with y our EPA Reg ional office contacts for a cu rrent list of states, territories, and counties granted or seek ing delegation.

Q. In wha t ways m ay state and local ru les be more string ent? Does this docum ent provide g uidance on state and local differences?

A. States and loc alities m ay im pose m ore deta iled req uirem ents, s uch as r equirin g m ore documentation or more frequent repo rting, specifying hours of training or maintenance sch edules, impos ing eq uipme nt requi remen ts or ca ll for ad ditiona l analy ses. S ome s tates an d locali ties are likely to cov er at least some ad ditional chemicals and may use lower thresholds. This d ocument does not cover these differen ces.

Q. Will the general duty clause be delegated ?

A. EPA is not deleg ating implem entation and enforcem ent of the general d uty clause (CAA section 112(r)(1)). States, how ever, may adopt their own g eneral duty clause u nder state law.

10.2 REVIEWS/A UDITS/INSP ECTIONS (§ 68.220)

The implementin g agency is required under part 68 (or a delegated state or local program) to review and cond uct audits of RMPs. Reviews are relativ ely quickChapte r 10 10-3 Imple menta ti on

checks of the RMP s to determine w hether they are com plete and whether they contain any i nform ation th at is cle arly p roblem atic. F or exam ple, if an RMP for a process containing flam mables fails to list fire and explosion as a ha zard in the
preve ntion p rogram , the im pleme nting agenc y m ay fla g that as a pr oblem

. The R MP data system will perform som e of the reviews automatically by flaggin g RMPs submitted without necessary data elem ents completed.

RMP audits are m ore comprehensiv e than reviews. Facilities may be selected for audits based on any of the following criteria, set out in §68.22 0:



### � Acciden t histor y of th e facilit y 

### � Acciden t histor y of o ther fac ilities i n the sa me in dustry 

### � Quantit y of r egula ted sub stances handle d at the site 

### � Location of the facility and its proximity to public and env ironmental recepto rs 

### � The presence of specific reg ulated substances 

### � The haz ards ide ntified in the R MP 

### � A plan providing for random, neutral oversight

W HAT A RE A UDITS A ND H OW M ANY W ILL B E C ONDUCTED ?

Audits are relatively detailed reviews of RMPs to determine compliance with part 68 and req uire rev isions w here ne cessary to ensu re com pliance

. Aud its help identif y whether the underly ing risk m anagement program is being implem ented properly. For example, the implem enting agency may loo k for any inconsistencies in the dates reported for complian ce with prevention program elem ents. If y ou reported that the date of your last rev ision of operating pro cedures was in June 2003 but your training
progr am w as last r eview ed or re vised in Dece mber 2001, the im pleme nting agenc y is likely to ask why the training program was not reviewed to reflect new operating procedures.

The age ncy m ay loo k at o ther item s that c ould in dicate p roblem s with imple menta tion. F or exam ple, if you a re repor ting o n a dist illation colum n at a refinery, but used a checklist as y our PHA technique, or you fail to list an appropriate set of process h azards for the process chemicals, the agency m ay seek further explanations as to w hy you rep orted in the way you did. The im plementing
agency m ay compa re your data with that of other facilities in the sam e industrial sector using the sam e chemicals to iden tify differences that m ay indicate com pliance problems.

If audits indicate potential problems, they may lead to requests for m ore information
or to on -site inspect ions. I f the im pleme nting agenc y dete rmine s that p roblem s exist, it may issue a preliminary determination listing the necessary rev isions to the RMP, an explanation of the reaso ns for the revisions, and a timetable. Section 68.220 provid es detai ls of th e adm inistrat ive pr ocedure s for res pondin g to a prelim inary determination.

The number of aud its conducted will v ary from state to state and from year to yea r. Neither the CAA n or part 68 sets a num ber or percentage o f facilities that must beChapte r 10 Imple menta ti on 10-4

audited during a yea r. I mplem enting agenc ies will set the ir own goals, based o n their resources and particular conce rns.

W HAT A RE I NSPECTIONS ?

Inspections are site visits to check on the accuracy of the data reported in R MPs and on the implem entation of all part 68 elem ents, including risk managem ent program requirements. D uring inspections, th e impleme nting agency will probably rev iew the documentation for rule elements, such as the PHA reports, operating procedures
, maintenance schedu les, process safety in formation, and train ing. Unlik e audits, which may only focus on the RMP but m ay lead to determ inations concerning needed improv ements to the risk managem ent program , inspections will focus on the underly ing ri sk m anage ment progr am its elf.

Implem enting agencies will determine how many in spections they need to conduct. Audits may lead to inspections or ins pections may be done separately

. Depending on the focu s of the inspect ion (all cover ed proc esses, a sing le proce ss, or p articula r part of the r isk managemen t progra m) and the size of t he faci lity, i nspect ions may ta ke several hours to sev eral weeks.

10.3 RELA TIONS HIP WIT H TIT LE V P ERMIT PROGRA MS

Part 68 is an applicable requirement for purp oses of the CAA Title V permit program and m ust be l isted in a Title V a ir perm it. Yo u do no t need a Title V air perm it solely because y ou are subject to part 68. If you are required to apply for a Title V permit because you are subj ect to require ments under some other part of the CAA,
you m ust:



### � List par t 68 as an appl icable r equirem ent in y our per mit



### � Incl ude con ditions that req uire y ou to ei ther sub mit a comp liance s chedule for meeting the requirements of part 68 by the a pplicable deadlines or include comp liance w ith part 68 as p art of y our cert ificatio n statem ent.

You m ust also provi de the p ermitt ing ag ency w ith any other r elevan t inform ation it requests.

The RMP and sup porting docum entation are not part of the per mit an d gen erally should not be subm itted to the permitting authority unless spe cifically requested.

If you have a Title V perm it and it does not addres s the part 68 requirem ent, you should contact your permi tting authori ty and determ ine whe ther y our per mit n eeds to be amended to reflect part 68.

10.4 PENALTIES FOR NON-COMPLIANCE

Penalti es for v iolating the req uirem ents or prohibi tions of part 68 are set forth in CAA section 113. This section provides for both civil and criminal penalties. EPA
may assess civil penalties of not m ore than $32,500 pe r day per v iolation. Anyon e convi cted of know ingly viola ting p art 68 m ay als o be pu nished by a f ine purs uant toChapte r 10 10-5 Imple menta ti on

Title 18 of the U.S. C ode or by im prisonment for no more than fiv e years, or both;
anyone conv icted of knowing ly filing false info rmation m ay be punished by a fine pursuant to Title 18 or by imprisonm ent for no more than two years.



### Q S 

### & A S 

### A UDITS

Q. If we are a Voluntary Protecti on Program (VPP) facili ty under OSHA’s VPP program, are we exempt from audits?

A. You are exem pt from audits that are based on the acciden t history of y our industry sector o r on random , neutr al ove rsight

. How ever, part 68 include s other criteria for deci ding w hat faci lities to audit that are not affected by a VPP rating. A n implem enting agency that is basing its au diting strategy on o ne of these other criteria m ay select you r facility to audit, altho ugh EPA ex pects that VPP facilities will generally not be a high priority for audits unless they have a serious accident.

Q. If we h ave been audited by a qualified third party, for I SO 14001 certification o r for other
programs, are we exempt from audits?

A. No, but y ou may want to inform your implem enting agency that you hav e gained such certification and indicate wheth er the third party rev iewed part 68 com pliance as part of its audit. The implementin g agency has the discretion to determ ine whether you should be audited.

Q. Will we be audi ted if a member of t he publ ic req uests an audi t of our facil ity?

A. The im pleme nting agenc y will have to decid e wheth er to res pond to such p ublic re quests. EPA’s intention is that part 68 im plementation reflect that hazards are prim arily a local concern.

## CHA PTER 11: COMMUNICA TION WIT H THE P UBLIC

Once you hav e prepared and subm itted your RMP, E PA will mak e it available to the public. CAA section s 112(r) and 114(c) requ ire that RMPs be m ade available to the public, except for any classifi ed or co nfident ial busi ness inf ormat ion con tained i n RMPs or the off- site consequence analy sis (OCA) sections of RMPS (sections 2 through 5). Members of the publ ic may obtain copies of RMPs (wi thout the OCA sections) by requesting them from EPA in writing (including by email). Mem bers of the public may also read, but not co py, the OCA sections of RMPs in federal reading room s. There is a mo nthly limit on the number o f facilities for which any member of the public can v iew OCA in readin g rooms.

In v iew of t he publ ic’s acc ess to R MPs, y ou shou ld expe ct that y our com munit y will discuss the hazards and risks associated w ith your facility as indicated in you r RMP. You wi ll neces sarily be part of such discuss ions. Th e public and the press a re like ly to ask you questions because only you can prov ide specific answers about your facility and you r accident prevention program. This dialogue is a m ost important step in preve nting chem ical acc idents a nd shou ld be en courag ed. Yo u shoul d respond to these questions honestly and candidly. Refus ing to answer, reacting defensi vely , or att ackin g the regula tion as unneces sary a re like ly to m ake pe ople suspici ous and willing to assu me th e worst

. A ba sic fact of risk comm unicatio n is that tru st, onc e lost, is ver y hard to reg ain. A s a resu lt, yo u shoul d prepa re as ea rly as possible to begin talking abou t these issues with the co mmunity , Local Eme rgency Plannin g Com mittee s (LEPC s), Sta te Em ergen cy Re sponse Comm issions (SERC s), other local and state officials, and other interested parties.

Another reason that the public and press m ay ask que stions about your facility is the increased concern about d omestic terrorism issues since Septem ber 11, 2001. The fact that your facility is regulated under the EPA Risk Management Program m eans that y ou prob ably s tore rel ativel y larg e quant ities of extrem ely to xic or f lamm able subst ances , and peo ple may be co ncern ed abou t secur ity at you r faci lity.

Comm unicatio n with the pub lic can be an o pportun ity to devel op yo ur relat ionship with the comm unity and build a level of trust am ong you, your neigh bors, and the

commun ity at large. By com plying with the RMP rule, yo u are taking a number of steps to prevent accid ents and protect the com munity. These steps are the individ ual eleme nts of y our risk mana gem ent prog ram. A well -des igned and pro perly implemented risk mana gement pro gram will s et the stage for inform ative and productive dialog ue between you and your com munity. The purpose of this chapter is to suggest how this dialogue may occu r. In add ition, note that som e industries have develop ed guidance and other materials to assist in this process; contact y our trade association for m ore information.



### 11.1 BA SIC RULES OF RISK CO MMUNICA TION

Risk comm unicatio n mea ns estab lishing and m aintaini ng a d ialogu e with t he publ ic about the hazards at your operation an d discussing the step s that have been or can be taken to redu ce the r isk po sed by these h azards

. Of p articula r conce rn unde r this ru le are the hazards related to the chemicals y ou use and what w ould happen if y ou had an accidental release.Chapte r 11 Co mm unicatio n with the P ublic 11-2

Man y compa nie s, gove rnmen t age nci es, a nd ot her e nti tie s have conf ront ed th e same issue y ou ma y face : how t o discu ss with the pub lic the r isks t he com munit y is subject to. Exhibit 11- 1 outlines seven “ru les” of risk com munication that hav e been developed based o n many experiences of dealing with the public about risks.

A key m essage of these "rules" is the importance and legitimacy of public concerns. People generally are less tolerant of risk s they cannot con trol than those they can. For exa mple, most people are wil ling to a ccept the ris ks of dri ving beca use the y have

some control over what ha ppens t o them

. How ever, they are ge nerally more uncomfortable accep ting the risks o f living near a facility that handles h azardous chemicals if they feel that they hav e no control over whether the facility ha s an acciden t. The C lean Ai r Act’s provis ion for public a vailab ility o f RMPs g ives p ublic an opportunity to take part in reducing the risk of chem ical accidents that mig ht

occur in thei r communit y.

Exhibit 11-1: Seven Cardinal R ules of Risk Communication

1. Accept and inv olve the public as a legitimate pa rtner

2. Pla n carefu lly and eval uate y our effo rts

3. Listen to the pu blic’s specific concerns

4. Be honest, fran k, and open

5. Coordinate and collaborate with other credible sources

6. Meet the nee ds of th e med ia

7. Speak clea rly and with com passion

H AZA RDS VERSUS R ISKS

Dialog ue in th e com munit y will be con cerned with bo th haz ards an d risk s; it is usef ul to be cl ear abou t the diff ere nce b etwe en th em.

Hazards are inherent properties that cannot be ch anged. Chlorine is toxic when inhaled or ingested; p ropane is flamm able. There is little that y ou can do with these chemicals to chang e their toxicity or flam mability. If you are in an earthquak e zone or an area affected by hurricanes, earthquak es and hurricanes are haz ards. When you conduct your haz ard review or proc ess hazards analy sis, you will be identifying y our hazards and determ ining whether the potential exposure to the h azard can be redu ced in any way (e.g. , by l imitin g the quantit y of c hlorine stored on-s ite).

Risk is usual ly ev aluated based o n seve ral va riables, includi ng the likeli hood of a release occurrin g, th e inhere nt haz ards of the che mical s com bined w ith the quantit y released, and the potential impact of the release on the public and th e environm ent. For example, if a release during loa ding occurs frequen tly, but the quan tity ofChapte r 11 11-3 Co mm unicatio n with the P ublic

chemical released is typically sm all and does not g enerally mig rate offsite, the overall risk to th e public is low. I f the likelihood of a catastrophic release occurring is extre mely low, b ut the n umbe r of peo ple who could b e affect ed if it occurre d is large, the ov erall risk may still be low because o f the low probability that a release will oc cur. On t he othe r hand, if a rel ease oc curs r elati vely freq uentl y and a large number of peop le could be affected, the overall risk to th e public is high.

The rule does not require y ou to assess risk in a quantitative way because, in m ost cases, the data yo u would need to estim ate risk levels (e. g., one in 1 00 years) are not available. Ev en in cases where data such as equipm ent failure rates are availab le, there are large uncertainties in using that data to determine a nu merical risk lev el for your facility, b ecause your facility is probably not the same as othe r facilities, and your sit uatio n may be dynamic

. There fore, you may want to assign q ualit ative values (high, medium , low) to the risk s that you hav e identified at your fa cility, but you shoul d be pre pared to expl ain the terms if you do. For example, if you bel ieve that the worst- case rel ease is very unlik ely to occur, you m ust gi ve g ood rea sons; you m ust be a ble to p rovide specifi c exam ples of measu res that you h ave ta ken to prevent such a releas e, such as installation of new equipmen t, careful training of
your w orkers , rigo rous pre ventiv e mai ntenanc e, etc. You s hould a lso be a ble to show docu menta tio n to s uppo rt yo ur cl aim.

W HO W ILL A SK Q UESTIONS ?

Your L ocal Em ergen cy Pla nning Com mittee (LEPC ) and ot her faci lities ca n help you id entify indiv iduals i n the fo llowing group s who m ay be review ing R MP data and asking questions. I nterested parties may include:

(1) Persons living near the facility and e lsewhere in the com munity or working at a nei ghbor ing fa cility

(2) Local officials from zoning and planning boards, fire and police departments, health and building code officials, elected officials, and various county and sta te offic ials

(3) Your employ ees

(4) Special interest groups including env ironmental org anizations, cham bers of
commerce, unions, and v arious civic org anizations

(5) Journalists, reporters, and other m edia representatives

(6) Medical professionals, educators, consultants, neigh boring com panies and others w ith spec ial expe rtise or interest s

In gen eral, people will be con cerned about accident risk s at your facility , how you manage the risks, a nd pote ntial impacts of an acc ident on heal th, saf ety, pro perty, natural resources, com munity infrastru cture, comm unity imag e, property v alues, and other m atters. Those in dividu als in th e public and pri vate s ector w ho are r esponsi ble for deal ing w ith thes e imp acts and the ass ociated risksalso w ill hav e an int erest in working w ith you to address these risks.Chapte r 11 Co mm unicatio n with the P ublic 11-4

W HAT I NFORMATION A BOUT Y OUR F ACI LITY IS A VAI LABLE TO THE P UBL IC ?

As noted above , EPA is leg ally required to m ake RMPs av ailable to the public, except for any CBI they may contain

. Publ ic acces s to the OCA s ections of RMP s is restricted, but the public m ay still read, if not copy, those section s. Under the regula tions g overn ing pu blic acc ess to t he OCA section s of RMP s (see 4 0 CFR Part 1400), any m ember of the pu blic may rea d those sections for up to 10 facilities per month, with no restriction on the g eographical location of the facilities for which that information is soug ht. Any m ember of the pu blic may a lso read the OCA sections of RMPs for any facility in or potentially affectin g the jurisdiction of the loca l
emergency planning com mittee in which that person lives or works.

Even thoug h most of the contents of RMPs are av ailable to the public, it is likely that people will want addition al information. P eople who request cop ies of RMPs will be aware that the RMPs they receive do not in clude the OCA sectio ns. Interested
persons may also know that you retain additional information at y our facility (e.g.
, docum entation of the r esults r eported in the O CA sec tions of your RMP) an d are required to mak e it available to EP A or its implem enting agency during inspections or compliance aud its. Therefore, they m ay request additional information. EP A

encoura ges y ou to p rovide public access t o additi onal inf ormat ion upo n reaso nable request. If EPA or its im plementing a gency were to request additional inform ation, it would be availab le to the public under se ction 114(c) of the CA A, except for confidential business inform ation and OCA info rmation.

The public may also be interested in other information relev ant to risk m anagement at your facility, such as:



### � Submissions und er sections 302, 304, 311-312, and 313 of the E mergency Planning and C ommunity Right to Know Act (EPCRA) repo rting on chemical storag e and releases, as well as the comm unity emerg ency response plan prepared under EP CRA section 303



### � Other reports on haz ardous materials m ade, used, gen erated, stored, spilled, released and transported, th at you subm itted to federal, state, and local agencies



### � Reports on work place safety and acc idents developed un der the Occupational Safety and Health Act that y ou provide to em ployees, who may choose to mak e the information p ublicly available, such as medic al and
exposu re recor ds, che mical data sh eets, an d traini ng m aterials



### � Any other inform ation you hav e provided to pu blic agencies that can be accessed by m embers of the pu blic under the federal Freed om of I nformation Act and simil ar state laws (a nd that may have been m ade wid ely av ailable
over t he I nternet)



### � Any p ublishe d mat erials o n facilit y safe ty (eit her indu stry- or site- specific ), such as agency reports on facility acc idents, safety eng ineering man uals and textbooks, and p rofessional journal articles on facility risk mana gement, fo r

exam pleChapte r 11 11-5 Co mm unicatio n with the P ublic

11.2 SA MPLE QU ESTI ONS FOR COMMUN ICA TING W ITH T HE PU BLIC

Smaller businesses may not have the resources or time to dev elop the types of outreach program s, described later in this ch apter, that many larger chem ical companies hav e used to handle pub lic questions and com munity relation s. For man y small busine sses, c omm unicatio n with the pub lic will usually occur w hen y ou are asked questio ns abou t inform ation in your RMP. I t is im portant that y ou resp ond to these questions constructively. Go bey ond just answering que stions; discuss what you have done to prevent a ccidents and work with the com munity to reduce risks. The people in your c ommunity will be looking to you to prov ide answers.

To help y ou estab lish a p roducti ve dia logue with th e com munit y, th e rest o f this section presents questions y ou are likely to be asked and a framework for answering them. These are e lements of the pu blic dialogue that y ou may anticipate. The person from your f acility desig nated a s respon sible fo r com munic ating with th e public should review the following and talk to other comm unity organiz ations to determine which questions are m ost likely to b e raised and identify other foreseeable issues. Rememb er that others in the com munity, n otably LEPCs and other emerg ency managem ent organizations are also likely to be asked the se and other sim ilar questions. You shou ld consider the unique fea tures of your facility , your RMP, and your h istorica l relatio nship w ith the comm unity (e.g. , prior acciden ts, brea kdow ns in the coo rdinatio n of em ergen cy res ponse e fforts, and m anage ment- labor di sputes)
, and work tog ether with these other org anizations to answer these questions for y our sit uat ion a nd to reso lve t he is sues asso cia ted with them.Chapte r 11 Co mm unicatio n with the P ublic 11-6



### What does your worst-case “distance to endpoint” or release distance mea n?

The distance is intended to pro vide an estim ate of the maxim um possible area that might b e affected by a c atastrop hic rele ase from your facility

. It is inten ded to e nsure th at no po tential r isks t o publi c health a re ove rlooke d, but the dist ance to an end point es timate d under worst- case co ndition s shoul d not be considered a “p ublic danger z one.”

In m ost case s, the m athem atical m odels u sed to a nalyz e the w orst- case rel ease sce nario as defined in the rule may overe stima te the a rea that would be im pacted by a r elease. In other ca ses, th e mod els
may undere stima te the a rea. Fo r distan ces gr eater th an appr oxima tely s ix mi les, the results of toxi c gas dispersion m odels are especially un certain, and you should be prepared to d iscuss such possibi lities in an ope n, hon est m anner.

Reas ons t hat model ing may u nder est imat e the dist ance gener all y rel ate to th e ina bil ity o f some models to accoun t for site-specific facto rs that migh t tend to increase the actua l endpoint distance. For example, assume a facility is located in a rive r valley and handles dense toxic g ases such as chlorine. If a release were to occur, th e river valley could channel the toxic cloud much farther than it might trav el if it were to disperse in a location with gen erally flat terrain. I n such cases, the actua l endpoint distance m ight be long er than that predicted using generic look up tables.

Reasons that the area m ay be overe stimated include:

C For tox ics, the weathe r condit ions (v ery lo w wind speed, calm conditi ons) ass umed for a

wors t-cas e rel ease scen ari o are unco mmon an d pro babl y woul d not last as lo ng as t he ti me the rele ase wou ld tak e to trav el the d istance estim ated. I f weath er cond itions a re diffe rent, the distance to endpoint w ould be much shorter, because the release would be dispersed, and in t he proc ess dil uted, mor e quickl y.

C For flam mable s, altho ugh e xplosio ns can o ccur, a release of a fla mm able is more likely to disperse harmlessly or burn. I f an explosion does oc cur, however, debris from the b last could affect an even broader area than wou ld be indicated by the distance to endpoint fo r the flamma ble substance.

C In gen eral, some m odels cannot take in to account other site- specific factors that mig ht tend to disperse the chem icals more quick ly and limit the distance.

Note: W hen esti matin g wor st case release distanc es, the rule do es not a llow fac ilities t o take into
account activ e miti gation syste ms an d practi ces that could l imit t he scop e of a re lease. Specifi c systems (e.g ., monitoring , detection, control, pre ssure relief, alarms, mitigation) m ay limit a rele ase or prevent the failure from occurring

. Also, if y ou are required to analy ze alternative release scenario s (i.e. , if y our faci lity is in Prog ram 2 or Prog ram 3 ), these scenari os are g enerally more realistic than the worst case, and you can offer to provide add itional information on those scenarios.Chapte r 11 11-7 Co mm unicatio n with the P ublic



### What does it mean that we could be exposed if we live/work/shop/go to school X miles away?

(For a n accid ent invo lving a flamma ble sub stance) :

The dista nce m eans tha t people who ar e in tha t area ar ound th e facilit y cou ld be hu rt if the conten ts of a tan k or othe r vessel explod ed. The blast of the e xplos ion cou ld shat ter win dows and damage buildings. I njuries would be the result of the force of the explosion and of flying glass or falling debris.

(For a n accid ent invo lving a toxic su bstance ):

The distance is based on a concentration of the chem ical that you could be exposed to for an hour withou t suffer ing ir revers ible hea lth effe cts or o ther sy mptom s that w ould m ake it difficu lt for y ou to escape. If you are within tha t distance, you co uld be exposed to a greater concentration of the chemical. I f you were exp osed to higher lev els for an extended period of time (10 m inutes, 30 minutes, or long er), you could b e seriously hurt. However, that does not mean that you would be. Rememb er, for worst case scenario s, the rule requires y ou to mak e certain conservativ e assumptions with respect to, for exam ple, wind speed and atmospheric stability

. If the w ind speed is highe r than that used in the m odeling, or if the atmosphere is m ore unstable, a chem ical release would be dispersed more qu ickly, and the distances would be much sm aller and the exposure tim es would be shorter. If th e question pertains to an alternative release scenario, you probably assumed ty pical weather conditi ons in t he mo deling

. Theref ore, th e actual impa ct dista nce cou ld be sh orter or longe r, and you should be prepared to ack nowledge this and clearly explain how you chose the conditions for your release scena rio.

In g eneral, the pos sibility of harm depend s on the concen tration of the c hemic al you are exp osed to and the length of time you are exposed.Chapte r 11 Co mm unicatio n with the P ublic 11-8



### If there is a worst-case accident, will eve ryone within that distance be hurt? What abou t propert y damage?

It is impo rtant to reme mber that wo rst-c ase scen arios ar e very unlik ely. In g eneral, even if a ve ry large accidental release d id occur, not ev eryone within the circle defined by the worst-case distan ce to endpoint would be hurt.

In analy zing the pote ntial consequences of a w orst-case release, we look at two types of chem icals ­ toxics and flamm ables. Releases of flam mables do not usually lead to exp losions; released flamm ables ar e mor e like ly to d isperse withou t igni ting. If t he relea sed flam mable does ig nite, a fire is more l ikely tha n an expl osion , and fi res ar e usual ly conce ntrat ed at th e faci lity.

For an ex plosi on, ever yone wit hin the dista nce-to-end point circl e would certa inly fee l the bl ast wave since it would m ove in all directions at once. Howev er, while some people within the circle could be hurt, it is unlik ely th at eve ryone would be since some people would probabl y be i n less v ulnerab le locations. Most injuries would p robably be due to the effects of flying glass, falling debris, or impact with nearby objects.

For toxic chemica ls, whether som eone within the circle is h urt by a release dep ends on many factors. First, the released chem icals would usually move in the direction of the wind (except for some dense
gases , which may be con strained by te rrain fe atures t o flow in a dif ferent d irection ). Gen erally , only people downw ind from the fac ility w ould be at risk of expo sure if a release occurre d, and this is normally on ly a part of the p opulation inside the circle. If the w ind speed is mo derate, the chemi cal s wou ld di sper se qu ickl y, and peop le wo uld b e exp osed to lo wer l evel s of t he ch emica l. If the release is stopped quick ly, they m ight be exposed for a very sh ort period time, w hich is less likely to cause injury. Howev er, if the wind speed is low or the release con tinues for a long tim e, exposure levels will be higher and m ore dangerous. The population at risk w ould be a larger proport ion of t he total popula tion ins ide the circle. You sh ould be prepare d to dis cuss bo th possibilities.

General ly, it is the p eople w ho are c losest t o the fa cility — within a half m ile or le ss — wh o would face the greatest dang er if a large accident occurred.

Damage to property and the environme nt will depend on the type of chem ical released. I n an explosion, environm ental impacts and property dam age may extend beyond the distance at which injuries could occur. For a vapor release, env ironmental effects and property dam age may occur as a result of the reactivity or corrosivity of the chemical o r toxic contamination

.Chapte r 11 11-9 Co mm unicatio n with the P ublic



### How sure are you of you r endpoint distances?

Perhaps the largest sin gle difficulty asso ciated with hazard a ssessment is that differe nt models and modeling a ssumptions will y ield somewhat d ifferent results. There is no on e model or set of assumptions that w ill yield “certain” results. Models represent scientists’ best e fforts to account for all the va ria ble s invo lved in an acci dent al re lea se. W hil e all model s are gener all y base d on t he sa me physical principles, d ispersion modeling is not an exact science due to the limited opportunity for real-world v alidation of results. No model is perfect, and every m odel represents a som ewhat different analytical approach

. As a result, for a given scen ario, people can use d ifferent consequence mode ls and o btain es timate s of the distanc e to the toxic e ndpoin t that in some situatio ns mi ght v ary by a factor of ten. Even using the same m odel, different input assum ptions can cause wide variations in the predictions. I t follows that, when you present a sing le value as y our best estimate o f the endpoin t distan ce, oth ers will be able to claim that th e answe r ough t to be d ifferent , perha ps gre ater, perhaps smal ler, dep ending on the assum ptions u sed in m odeling and the choice of mo del itse lf.

You therefore need to recognize that y our estimated distance lies within a considerable band of uncertainty, and to commun icate this fact to those who have an interest in your results. A neighboring fa cility handling th e same cov ered substances as y ou do may have com e up with a different result for the sam e scenario for these reasons.

If you use EPA’s RMP Offsite Consequence Analysis Guidance or one of the i ndustry -spe cific guidance docum ents that EPA has d eveloped, y ou will be able to add ress the issue of uncertainty by stating that th e result s you have gener ated are conser vativ e (that i s, they are lik ely to overe stima te distances). Howev er, if you use o ther models, y ou will have to provide your own assessment of where your specific estimate lies within th e plausible range of uncertainties.



### Why do you need to st ore so much on-site?

If you have not prev iously considered the feasibility of reducing the quantity, y ou should do so w hen you develop your risk m anagement program. Many com panies have cited p ublic safety concerns as a reason for reducing the quantities of haz ardous chemicals s tored on-site or for switching to nonhazard ous sub stitutes

. If you h ave ev aluated your process and de termin ed that you n eed a ce rtain volume to maintain you r operations, you should explain this fact to the public in a forthrig ht manner. As appropriate, y ou should also discuss any alternatives, such as reducing storage quantities and scheduling m ore frequent deliveries. Perhaps these options are feasible - if s o, you should consider implementing them; if not, e xplain why y ou consider these alternativ es to be unacceptable. For example, in som e situations, more frequent deliveries wo uld mean m ore trucks carryin g the substan ce throu gh the comm unity on a reg ular bas is and a great er oppo rtunity for sm aller- scale relea ses bec ause of more freq uent lo ading an d unloa ding.Chapte r 11 Co mm unicatio n with the P ublic 11-10



### What are yo u doing t o prevent r eleases?

If you have rigorously implemen ted your risk managem ent program , this question will be your chance, if you h ave not already done so, to tell the commun ity about yo ur prevention activ ities, the safe design features o f your operations, the specific activities that y ou are performing such as training , opera ting p rocedur es, m aintena nce, et c., and any i ndustry codes o r standa rds yo u use to operate safely. I f you have installed new equipm ent or safety sy stems, upg raded training, or h ad outside experts review your site for safety (e.g., insuranc e inspectors), you could offer to share the results. You m ay also want to mention state or fed eral rules you com ply with.



### What are yo u doing t o prepare f or releases?

For such questions, y ou will need to talk about the coordination th at you hav e done with the local fire department, L EPC, or m utual aid groups. Such coordination m ay include activ ities such as defining an incident command structure, developing notification protocols, cond ucting response training and ex ercises, devel oping mutu al aid a greem ents, a nd ev aluating public alert sy stems

. This descrip tion is p articula rly im portant if you r emp loyee s are no t desig nated o r traine d to res pond to releases of regulated su bstances.

If your employees will be involv ed in a response, y ou should describe y our emergen cy response plan and the emer gency respon se resou rces av ailable at the fa cility (e.g. , equip ment, person nel), as well as throu gh res ponse c ontracto rs, if a ppropri ate. Y ou also may want to indicat e the ty pes of e vents for which such resources are applicable. Finally , indicate your sch edule for internal em ergency response training and drills and exercises and d iscuss the results of the latest relevant drill or exercise, including p roblems found an d actions taken to address them.



### Do you need to use th is chemical?

Again, if y ou have not y et considered the feasibility of switching to a non-haz ardous substitute, yo u should do so when you deve lop your risk managem ent program

. Assuming that there is no substitute, you sho uld describe why the chemical is critical to what you p roduce and explain wh at you do to h andle it saf ely. If ther e are su bstit utes ava ilabl e, you sho uld des cribe how you have evaluated such optio ns.Chapte r 11 11-11 Co mm unicatio n with the P ublic



### Why are your distances different from the distances in the EPA lookup tables?

If you did your own modeling, this question may come up. You should be rea dy to explain in a general way how your m odel works and why it produces different results. EPA allow s using other mode ls (as lo ng as certain param eters an d condi tions sp ecified by the rule are met) because it realizes that EPA lo okup table results w ill not necessarily reflect all site-specific condition s.

In addition, although all m odels are generally based on the sam e physical principles, dispersion modeling is not an exact science due to the limited op portunity for real- world validation of the results. Thus, the m ethod by which different models co mbine the basic factors such as wind sp eed and atmospheric s tability can result in distan ces that readily v ary by a fa ctor of two (e.g. , five miles
versus ten m iles). The introduction of site- specific factors can produce additional differences.

EPA re cogni zes th at diffe rent m odels w ill prod uce diff ering estim ates of the dist ance to an end point, especially for releases of toxic substances. The Ag ency has prov ided a discussion of the
uncerta inties a ssociate d with the m odel it has ado pted for the OC A Guid ance. You ne ed to underst and tha t the di stances produc ed by anothe r mod el lie w ithin a band of uncerta inty a nd be a ble to demonstrate and commu nicate this fact to those wh o are reviewing your results.



### How likely are the worst- case and altern ative release scena rios?

It is gen erally not possible to provide accurate num erical estimates of how likely these s cenarios are. EPA ha s stated that pr ovidin g such numb ers for a ccident scenari os rarel y is fe asible b ecause the data needed (e.g., on rates for equipm ent failure and hum an error) are not usually available. Ev en when data are available, the re are large uncertainties in applying the data because each fac ility’s situation is unique.

In general , the ri sk of the worst-ca se scen ario i s very low. Although catas troph ic vesse l fail ures ha ve occurred, they are rare events. Co mbining the m with worst- case weather conditions m akes the overall scenario ev en less likely. This does not m ean that such even ts cannot or will not ha ppen, howev er.

For the alternative scen ario, the likelihood of the release is greater and will depend, in part, on the scenario you chose

. If y ou selected a scenario bas ed on your accid ent history or industry accident history , you should explain this to the pub lic. Y ou shou ld also discuss any s teps y ou are t aking to prevent such an a ccide nt fro m recurr ing.Chapte r 11 Co mm unicatio n with the P ublic 11-12



### Is the worst -case release you reported really the wo rst accident you can have?

The answ er to th is quest ion wil l depen d on th e type of facil ity y ou hav e and h ow yo u handl e chemicals. EP A defined a specific scen ario (failure of the single largest vessel) to provide a

comm on basi s of com parison amon g faci lities na tionwid e. So, if you have only one ves sel, EP A’s worst case is likely to be the worst ev ent you could h ave.

On the other hand, if you have a process which inv olves multiple co-located or in terconnected vessels, it is possible that you could h ave an accident m ore severe than EP A’s worst case scenario. If credible scenario s exist that could be m ore serious (in terms of quantities released or consequences) than the E PA worst case scenario , you should be ready to discuss them. For example, if you store chem icals in small contain ers such as 55- gallon drum s, the EPA- defined worst-c ase release scenario invol ves a release from only one cont ainer, b ut a fire or expl osion a t the fac ility could release larger qu antities if multiple contain ers are involved . In this ca se, you should be ready to frankly discu ss such a scenario with the public. If you take p recautions to prevent such scenarios from occurrin g, y ou shou ld expla in these precau tions al so. I f an acc idental release is mo re like ly to involv e mul tiple dr ums t han a si ngle d rum a s a resu lt, for exam ple, of the dru ms be ing st ored clo sely together, then y ou must select su ch a scenario as y our alternative release scen ario so that informa tion on this scenario is av ailable in your RMP

.

Chemical m anufacturers may want to talk ab out releases that could result from runaway reactions that could continue for sev eral hours. This type of event could resu lt in longer exposu re times.



### What abou t the accide nt at th e [name of similar facilit y] that happ ened last month?

This question highlig hts an important p oint: you need to be aware of ev ents in your indus try (e.g., acciden ts, new safety meas ures) fo r two re asons. First, your perform ance lik ely w ill be co mpare d to that of your com petitors. Second, learnin g about the circum stances and causes of acc idents at other facil ities like your s can he lp you pre vent suc h accid ents f rom occur ring at yo ur fac ilit y.

If inform ation is available on accidents that happen at fac ilities similar to yo urs (e.g., from reports, case studies, journal articles, or o ther sources), you should be familiar with and have evaluated whethe r your facility is at ris k for simila r accide nts. Y ou shou ld tak e the ap propria te me asures t o prevent the accident from occurring and be prepared to d escribe these actions. I f your facility has experienced a similar release in the past, this info rmation m ay be docum ented in your accid ent history or other pub licly available reco rds, depending o n the date and nature o f the incident, the quantity released, an d other factors. I f you have already taken steps specifically desig ned to address this type of accident, whether as a result of this accident, a prior acciden t at your facility, or other internal decision-m aking, y ou should describe these efforts. If, based on your evaluation, y ou determine that the a ccident could not occur at your facility, you should discu ss the pertinent differences between the tw o facilities and explain wh y you believ e those differences should prevent the accident from occurring at y our facility.Chapte r 11 11-13 Co mm unicatio n with the P ublic



### What actions have you taken to involve the community in your accident prevention and emergen cy planning efforts?

If y ou hav e not ac tively invol ved th e com munit y in a ccident preve ntion an d eme rgenc y plan ning i n the past, you sh ould acknowledg e this as an area where you could im prove and start doin g so as y ou develop you r risk manag ement prog ram. The em ergency respon se provisions of pa rt 68 require you to coordinate with y our LEPC and/or lo cal fire department, depending on w hether your facility holds toxics and/or flamm able substances. More g enerally, you may w ant to become an active participant in the LEPC, SE RC, and regio nal mutual aid o rganizations serv ing your area

. Other opportunities for com munit y inv olvem ent are fire safe ty coo rdinatio n activ ities wi th the l ocal fir e depar tment , joint training and exercises w ith local public and priv ate sector response personne l, the establishment of g reen fields between the fac ility and the com munity, a nd similar efforts.

When dis cussing acciden t prev ention a nd em ergen cy pla nning with th e com munit y, y ou shou ld indicate any n ational progr ams i n which you p articipa te, suc h as the Chem ical Man ufacture rs Association’s Responsible Care program or Comm unity Awareness and Emerg ency Response
progr am or OSHA ’s Volun tary P rotectio n Prog ram. If fu lly im pleme nted, t hese pr ogram s can he lp impro ve the safety of the f acility and the comm unity. You m ay hav e future plans t o partic ipate in areas descri bed previously or have new init iatives associa ted with the risk management program. Be
sure y ou ask what e lse the comm unity would l ike y ou to d o and e xplain h ow yo u will d o it.



### Can we see th e document ation you keep on site?

If th e reque sted inf ormat ion is n ot confi dential busines s inform ation, EPA en courag es you to ma ke it availa ble to t he publ ic in a r easonab le ma nner. (Since t he OCA section s of y our RMP are av ailable to the public on a restricted bases, it mak es sense that the docum entation underlying those sections be made av ailable in a mann er that reflects its sensitivity .) Although y ou are not required to p rovide this information to th e public, refusing to provide it sim ply because y ou are not com pelled to is not the best approach. I f you decide not to provide any or most of this material, you should have g ood

reaso ns for n ot doin g so and be prepar ed to ex plain these r easons to the pu blic. Simply taki ng a defensive position or referring to the extent of your legal obligations is like ly to threaten the effectiveness of y our interaction with the co mmunity

. Offer as m uch information as possible to the publi c; if pa rticu lar doc uments wo uld reve al prop rieta ry infor mation, try to pr ovide a r edact ed copy,

summ ary, o r som e other form that ans wers th e com munit y’s co ncerns. You m ay wa nt to w ork w ith your LEPC on this issue. You should also be aware that information that EPA or the im plementing
agenc y obta ins as p art of an inspect ion or i nvesti gation conduc ted und er secti on 114 of the C lean Ai r Act would be av ailable to the public under section 114(c) of the Ac t to the extent it does no t reveal confidential business inform ation or OCA inform ation.

11.3 COMMUNICATION ACT IVITIES AND T ECHNIQUES

Although this section is most applicable to larger com panies, small bu sinesses may want to review it and use some of the ideas to expand their comm unications with the public. To prepare for effectiv e comm unication with the com munity, y ou should:Chapte r 11 Co mm unicatio n with the P ublic 11-14

(1) Adopt an organ izational policy th at includes basic risk commun ication principles (see exhibit 11- 1)

(2) Assign responsibilities a nd resources to im plement the policy

(3) Plan to use "best com munication practices"

A DOPT AN O RGANIZATIONAL C OMM UNICA TIONS P OLICY

An org anizat ional po licy w ill supp ort com munic ation w ith the public o n you r RMP and m ake it an inte gral p art of m anage ment practice s. Othe rwise, break downs are likely to occur, which could cause m istrust, hostility and co nflicts.

A policy helps to establish comm unication as a norm al organizational function and to present it as an oppo rtunity rather than a b urden or threat. The policy can be incorporated in an org anization's policies, an approach tak en by m any comp anies who be long t o the R esponsi ble Car e prog ram o f the Ch emica l Manufa cturers Association (CMA). These companies hav e adopted CMA' s Codes of Manag ement Practices, which contain risk comm unication principles and practice s.

Rememb er that what you commun icate is more im portant than the type of communica tion po licy or p rogram you us e, and wh at you ac tuall y do to maintain a safe facility is m ore important than anything y ou say. Yo ur company ’s safety and
preve ntion st eps in y our risk mana gem ent prog ram s hould s erve a s the co re elem ents of an y ris k commun ica tio n pro gram.

A

SSIGN R ESPONSIBI LITI ES AND R ESOURCES

A policy is only a paper promise until it is regularly and effectively implemented

. Thus, you should follow up your commun ication policy by (1) having top managem ent participate at the outset an d at key p oints throughout the

comm unicatio n proce ss, and (2) ass igning comm unicatio n respo nsibilit ies with in your organiz ation and providing the necessary resou rces.

Experie nce has demo nstrated that as signin g resp onsibili ty to k nowled geabl e managers, plant engineers, and staff and encourag ing participation by employees
, (most of whom are likely to be comm unity residents) is a g ood comm unications practice. Delegating commu nication functions to outside technical consultants, attorneys, and pu blic relations specialists has repeated ly failed to im press the

comm unity and ev en tend s to inc ur mi strust. (However, i f you hired a firm w ith ackno wledg ed expe rtise in dispers ion m odeling , you may want th em on hand to help respond to technical question s.)

Commu nications staff will need w ork time an d resources to prepare pres entation materials, hold m eetings with interested persons in the com munity, a nd do other work necessary to respond to questions and concerns and m aintain ongoing dialogue. A training prog ram in com munication sk ills and incentives for good perform ance also may be advisable.Chapte r 11 11-15 Co mm unicatio n with the P ublic

Organizations have a legitim ate interest in preventing disclosure of confidential business information or statements that ina dvertently and unfairly harm the organization or its employees . Thus, you sho uld assure that you r risk comm unication staff is instructed on how to deal with situations that pose these problem s. This may mean that y ou have an intern al procedure enabling your staff to bring such situations to top manag ement and leg al counsel for quick resolution, keeping in mind that unduly defensiv e or legalistic responses that result in restricting the amount of information that is p rovided can dam age or destroy the risk com munication process.

Your comm unication staff may find the following steps helpful in addressing the priority issues in the c ommunic ation process:

Prior to RMP Subm ittal



### � Enlist employee support for, and inv olvement in, the comm unication process



### � Build on work you have done with yo ur LEPC, fire depa rtment, and local official s, and gain t heir ins ights



### � Incorporate techn ical expertise, mana gement com mitment, and employ ee involvem ent in the risk com munication process



### � Use your RMP' s executive sum mary to b egin the dialog ue with the

commun ity; be sure y ou have tak en all of the steps y ou present



### � Taking a com munity persp ective, identify which data elements need to be clarified, interpreted, or am plified, and which are most likely to raise

commun ity concerns; then co mpile the inform ation needed to respond and determine the m ost understandable m ethods (e.g., u se of graphics) for presenting the inform ation

At Submittal



### � Review the RMP to assure that you are familiar with its data elements and how the y wer e deve loped. In particul ar, rev iew the hazar d assess ment, prevention, and re sponse program features, as well as do cumentation of the methods, data, and assumptions used, especially if an outside consultant performed the analy ses and developed these materials. You have certified their accuracy and y our spokesperson should know th em intimately , as they reflect your plan



### � Review yo ur performance in implementing the prevention and response programs an d prepare to discuss prob lems identified and actions taken



### � Review yo ur performance in investigating accidents and prepare to discuss any corrective actions that followedChapte r 11 Co mm unicatio n with the P ublic 11-16

Other Steps



### � Identify th e most likely concerns about risk s identified in the RMP b ut not fully addressed, con sult with manag ement and safety engineering, and determine additional m easures the organiz ation will take to res olve these

concerns



### � Avoid m isrepresentations and m inimize the ro les of public relations speciali sts



### � Identify "be st commu nication practices" (as described in the next section) and plan how to u se them

U SE "B EST C OMM UNICA TION P RACTIC ES "

Many f acilities already have gaine d consi derable experie nce in c omm unicatin g with the public. Lessons from their experiences are describe d below. How ever, the va lue of these best practices and your credibility w ill depend on yo ur facility's possession and ongoing demonstration of certain essential qualities:



### � Top ma nagem ent com mitm ent (e.g ., own er and f acility mana ger) to impro ving safety



### � Honest y, op enness, and co ncern fo r the co mm unity



### � Respect for public concern s and perceptions



### � Comm itmen t to m aintaini ng a d ialogu e with a ll secto rs of th e com munit y, to learning from this dialogue, and to being prepared to change y our practices
to ma ke y our faci lity m ore safe



### � Commitm ent to continuous im provement through internal proced ures for evaluating incide nts and promotin g organiz ational learning



### � Knowledge of safety issues and safety managem ent methods



### � Good working relationships with the LE PC, fire departm ent, and other local official s



### � Active support for the LEPC and related activities



### � Employee support and com mitment



### � Continuation of com mitment d espite potential public hostility or mistrust

Another note: Becaus e each facility and c ommunity involves a unique combinatio n of factors, the practices used to achieve g ood risk com munication in on e case do not necessarily ensure the same quality result when used in an other case. Therefore, while it is advisable for you to rev iew such experience to identify "best

commun ication practices," you should carefully ev aluate such practices to determ ineChapte r 11 11-17 Co mm unicatio n with the P ublic

if they can be adapted to fit y our uni que circ umsta nces. For exa mple, if you r facilit y is in the middle of an urban area, y ou probably will use different approaches than you would use if it were located in an industrial area far from any residential populations. These practices a re complem entary approaches to delivering y our risk management message an d respo nding to the con cerns of the c ommunity.

With these cautions in m ind, a numbe r of "best" practices are outlined below for consideration. First, y ou will want to establish formal channels for inform ation- sharing and co mm unicatio n with stakeh olders. The m ost basi c approaches include:



### � Convene public meetings for discussion and dialog ue regarding your risk
managem ent program and RMP and tak e steps to have th e facility owner or
manager an d all sectors of the com munity particip ate, including m inorities and low -inc ome r esident s



### � Arrang e mee tings with lo cal m edia rep resentat ives t o facilit ate thei r underst anding of yo ur risk mana gem ent prog ram a nd the p rogram summ ary present ed in y our RMP



### � Establish a repository of information on safety matters fo r the LEPC and th e publ ic an d, if elec tro nic , pro vide soft ware for p ubli c use

. Some organizations also have prov ided computer term inals for public use in the

commun ity library or fire department

Other, more res ource-intensiv e activities of this ty pe to consider include:



### � Create and con vene f ocus g roups (s mall w orking group s) to fac ilitate dialogue and action on specific concerns, inclu ding technical m atters, and take steps to assure that memb ership in each grou p reflects a cross section of the comm unity and includes technically trained person s (e.g., eng ineers, medical professionals)



### � Hold seminars o n hypothetical release scenarios, prevention and response
programs, applicable standards and ind ustry practices, analy tic methods and models (e.g ., on dispersion of a irborne releases, health effects of airborne
concent rations) , and o ther m atters o f specia l conce rn or co mplex ity



### � Convene special m eetings to foster dialog ue and collaborations with the LEPC a nd the f ire depa rtmen t and to establi sh a m utual as sistance networ k with other facility m anagers in the com munity or region



### � Establish hot lines for telepho ne and e-m ail commu nications between interest ed parti es and y our des ignate d risk comm unicatio n staff a nd, if feasible, a web site for p osting useful inform ation

In all of these efforts, remem ber to use plain lang uage and com monly un derstood terms; avoid the use of acronym s and technical and leg al jargon. I n addition, depending on y our audience, kee p in mind that the preparation of m ultilingual materi als may be us eful or even nece ssary.Chapte r 11 Co mm unicatio n with the P ublic 11-18

Second ly, you may want to init iate o r expan d progra ms that mor e dire ctly in volve the comm unity in you r operations and safety programs. Traditional approaches include:



### � Arrange facility tours so that mem bers of the public can v iew operations and discuss safety procedu res with supervisors and employ ees



### � Schedule drills and sim ulations of incidents to dem onstrate how preve ntion and res ponse p rogram s work , with particip ation by comm unity respond ers and other organiz ations (e.g., ne ighboring com panies)



### � Conduct a “Safety Street” - a commun ity forum g enerally sponsored b y

severa l indust ries in a locality , where your represen tative s presen t facilit y safety informatio n, explain risks, and respond to public questions (see Sect ion 1 1.4 f or a r efe renc e to mo re in for mati on on this progr am)



### � Periodi cally reaffirm and de mons trate y our com mitm ent to s afety in accordance with and be yond regulato ry requiremen ts and present data on
your s afety perform ance, u sing a ppropri ate ben chma rks or meas ures, in newslet ters and by po sting the info rmatio n at y our web site



### � Publicly honor and reward manag ers and employ ees who have performed safety responsibilities in su perior fashion and citiz ens who have made impor tant con tributio ns to th e dialog ue on s afety

If com munity interest is significant, y ou may also want to consider the following activities:



### � Invite pu blic participation in m onitoring imp lementation of y our risk

mana gem ent prog ram e lemen ts



### � Inv ite publ ic partic ipation in audi ting y our per forma nce in s afety responsibilities, such as chem ical handling and trac king procedu res and analysis and follow- up on accidents and n ear misses



### � Organize a committee comprised of repres entatives from the facility, other industr y, em ergen cy pla nning and res ponse o rganiz ations, and co mm unity groups and chaired by a com munity leade r to independently evaluate your safety and com munication efforts (e. g., a Com munity A dvisory Pane l). You may also want to finance the com mittee to pay for an independent engineering co nsultant to assist with technic al issues and learn what can be done to impr ove sa fety, and the reby s hare co ntrol w ith the comm unity

Your co mm unicatio n staff s hould r eview these e xamp les, co nsider d esigni ng the ir

own ac tivitie s as we ll as join t efforts with o ther loc al org anizat ions, a nd ultim ately decide with th e com munit y on w hich set of prac tices ar e feasib le and c an best create a health y risk comm unicatio n proce ss in y our com munit y. On ce these decisio ns are made , you may want to integ rate the chosen set of p ractices in an o verall

commun ication program for your facility , transform som e into standard procedures, and m onitor a nd ev aluate t hem f or conti nuous i mprov emen t.Chapte r 11 11-19 Co mm unicatio n with the P ublic

O THER C OMM UNICA TION O PPORTUNITIES

By com plying with the RMP rule and participatin g in the com munications process with the comm unity, you should have dev eloped a compre hensive system for preventing, m itigating, and responding to chem ical accidents at your facility. Why not share this know ledge with y our staff, others yo u do business with (e. g., custom ers, dis tributor s, cont ractors) , and, perhap s throug h indus try g roups, others in your i ndustry ? If you t ransfer this k nowled ge to others, you c an help impr ove th eir chemical safety managem ent capabilities, enhance pu blic safety beyo nd your

commun ity, and possibly gain econom ic benefits for your o rganization.

11.4 FOR MORE INFORM AT ION

Among the numerous p ublications on risk co mmunicatio n, the following may be particul arly h elpful:



### � Improving Risk Com munication , National Academ y Press, Washing ton, D.C., 1989



### � "Safety Street" and othe r materials on the Kanawha Valley Dem onstration Progr am, C hemic al Manuf acturers Associ ation, Arling ton, VA



### � Commu nity Awareness an d Emerge ncy Response C ode of Managem ent Practices and various Guidance, Chem ical Manufacturers Association, Arling ton, VA



### � Commu nicatin g Risks to the P ublic , R. Kasperson and P . Stallen, eds., Kluwer Publishing C o., 1991



### � "Challe nges i n Risk and Sa fety C omm unicatio n with the Pub lic,” S . Maher, Risk Managem ent Professionals, Mission Viejo, CA , April 1996



### � Primer on Health Risk Com munication Principles and Practices, Ag ency for Toxic Substances and Disea se Registry, on the World Wide Web at atsdr1.atsdr.cdc.gov :8080



### � Risk Communication about Chemicals in Your Community: A Manu al for Local O fficials , US Environ mental Protection A gency, EP A EPCRA/Superfund/R CRA/CAA Ho tline



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