United States Office of Solid Waste EPA 550-B-98-010

Environmental Protection and Emergency Response October 1998

Agency (5104) www.epa.gov/ceppo/

Chemical Emergency Preparedness and Prevention Office RMP SERIES

RISK MANAGEMENT

PROGRAM GUIDANCE

FOR

WASTEWATER

TREATMENT PLANTS

(40 CFR PART 68)

 Printed on recycled paper

October 27, 1998

This document provides guidance to help owners and operators of wastewater treatment plants to

determine if their processes are subject to chemical accident prevention regulation under section

112(r) of the Clean Air Act and 40 CFR part 68 and to comply with regulations. This document

does not substitute for EPA’s regulations, nor is it a regulation itself. Thus, it cannot impose

legally binding requirements on EPA, states, or the regulated community, and may not apply to a

particular situation based upon circumstances. EPA may change this guidance in the future, as

appropriate.
October 27, 1998
October 27, 1998

TABLE OF CONTENTS

INTRODUCTION

CHAPTER 1 GENERAL APPLICABILITY

1.1 Introduction 1-1

1.2 General Provisions 1-3

1.3 Regulated Substances and Thresholds 1-4

1.4 What is a Process 1-5

1.5 Threshold Quantity in a Process 1-10

1.6 Stationary Source 1-17

1.7 When You Must Comply 1-18

CHAPTER 2 APPLICABILITY OF PROGRAM LEVELS

2.1 What Are Program Levels 2-1

2.2 POTW Program Levels 2-3

2.3 Program 1 2-5

2.4 Quick Rules for Determining Program 1 Eligibility 2-11

2.5 Program 3 2-13

2.6 Program 2 2-14

2.7 Dealing with Program Levels 2-16

2.8 Summary of Program Requirements 2-18

CHAPTER 3 FIVE-YEAR ACCIDENT HISTORY

3.1 What Accidents Must Be Reported 3-1

3.2 What Data Must Be Provided 3-1

3.3 Other Accident Reporting Requirements 3-10

CHAPTER 4 OFFSITE CONSEQUENCE ANALYSIS

4.1 Worst-Case Release Scenarios 4-3

4.2 Alternative Release Scenarios 4-20

4.3 Buildings 4-40

4.4 Estimating Offsite Receptors 4-45

4.5 Documentation 4-47

4.8 Symbols for Chapter 4 4-48

Appendix 4A Equations 4-59

Appendix 4B Limitations of Results 4-65
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CHAPTER 5 MANAGEMENT SYSTEM

5.1 General Information 5-1

5.2 How to Meet the Management System Requirements 5-1

CHAPTER 6 PREVENTION PROGRAM (PROGRAM 2)

6.1 About the Program 2 Prevention Program 6-1

6.2 Safety Information (§ 68.48) 6-1

6.3 Hazard Review (§ 68.50) 6-9 

6.4 Operating Procedures (§ 68.52) 6-14

6.5 Training (§ 68.54) 6-18

6.6 Maintenance (§ 68.56) 6-21

6.7 Compliance Audits (§ 68.58) 6-26

6.8 Incident Investigation (§ 68.60) 6-28

6.9 Conclusion 6-31

Appendix 6A Checklists 6-33

CHAPTER 7 PREVENTION PROGRAM (PROGRAM 3)

7.1 Prevention Program 3 and OSHA PSM 7-1

7.2 Process Safety Information (§ 68.65) 7-3

7.3 Process Hazard Analysis (§ 68.67) 7-7

7.4 Operating Procedures (§ 68.69) 7-10

7.5 Training (§ 68.71) 7-12

7.6 Mechanical Integrity (§ 68.73) 7-13

7.7 Management of Change (§ 68.75) 7-17

7.8 Pre-Startup Review (§ 68.77) 7-18

7.9 Compliance Audits (§ 68.79) 7-19

7.10 Incident Investigation (§ 68.81) 7-20

7.11 Employee Participation (§ 68.83) 7-21

7.12 Hot Work Permits (§ 68.85) 7-21

7.13 Contractors (§ 68.87) 7-22

Appendix 7-A PHA Techniques 7-24

CHAPTER 8 EMERGENCY RESPONSE

8.1 Non-Responding Sources 8-1

8.2 Elements of an Emergency Response Program 8-3

8.3 Developing an Emergency Response Program 8-6

8.4 Integration of Existing Program 8-9

8.5 Have I Met Part 68 Requirements 8-11
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8.6 Coordination with Local Emergency Planning Committees 8-16

CHAPTER 9 RISK MANAGEMENT PLAN

9.1 Elements of the RMP 9-1

9.2 RMP Submission 9-2

9.3 Resubmission and Updates 9-3

CHAPTER 10 IMPLEMENTATION

10.1 Implementing Agency 10-1

10.2 Reviews/Audits/Inspections 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 Basic Rules of Risk Communication 11-1

11.2 Sample Questions for Communicating with the Public 11-4

11.3 Communication Activities and Techniques 11-13

11.4 For More Information 11-19

APPENDICES

APPENDIX A PART 68

APPENDIX B Reserved

APPENDIX C EPA REGIONAL CONTACTS

APPENDIX D OSHA CONTACTS

APPENDIX E TECHNICAL ASSISTANCE

APPENDIX F OSHA GUIDANCE ON PSM 
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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 Processes

Exhibit 2-2 Federal OSHA States

Exhibit 2-3 States with Delegated OSHA Programs

Exhibit 2-4 Program Level Criteria

Exhibit 2-5 Develop Risk Management Program and RMP

Exhibit 2-6 Comparison of Program Requirements

CHAPTER 3

Exhibit 3-1 Atmospheric Stability Classes

CHAPTER 4

Exhibit 4-1 Steps for an Offsite Consequence Analysis

Exhibit 4-2 Required Parameters for Modeling

Exhibit 4-3 Distances to Toxic Endpoint — Chlorine

Exhibit 4-4 Distances to Toxic Endpoint for Chlorine

Exhibit 4-5 Distances to Toxic Endpoint — Sulfur Dioxide

Exhibit 4-6 Distances to Toxic Endpoint for Sulfur Dioxide

Exhibit 4-7 Distances to Toxic Endpoint for Anhydrous Ammonia Liquefied Under Pressure

Exhibit 4-8 Ratio of Vapor Pressure of Ammonia in 30% Aqueous Ammonia

Exhibit 4-9 Distances to Toxic Endpoint for Aqueous Ammonia

Exhibit 4-10 Distance to Overpressure Endpoint of 1 psi for Vapor Cloud Explosions of Methane

Exhibit 4-11 Distance to Overpressure Endpoint of 1 psi for Vapor Cloud Explosions of Propane

Exhibit 4-12 Distances to Toxic Endpoint for Chlorine

Exhibit 4-13 Release Rates and Distance to the Endpoint for Liquid Chlorine Releases

Exhibit 4-14 Release Rates for Two-Phase Releases from Pipes Carrying Liquid Chlorine

Exhibit 4-15 Release Rates and Distance to the Endpoint for Chlorine Vapor Releases

Exhibit 4-16 Release Rates and Distance to the Endpoint for Liquid Sulfur Dioxide Releases

Exhibit 4-17 Distances to Toxic Endpoints for Sulfur Dioxide

Exhibit 4-18 Release Rates for Two-Phase Releases from Pipes Carrying Liquid Sulfur Dioxide

Exhibit 4-19 Release Rates and Distance to the Endpoint for Sulfur Dioxide Vapor Releases

Exhibit 4-20 Release Rates and Distance to the Endpoint for Liquid Ammonia Releases

Exhibit 4-21 Distances to Toxic Endpoint for Anhydrous Ammonia 

Exhibit 4-22 Distances to Toxic Endpoint for Aqueous Ammonia 

Exhibit 4-23 Distance to Overpressure Endpoint of 1 psi for Vapor Cloud Explosions of Propane
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Exhibit 4-24 Distance at Which Exposure to a Propane BLEVE Could Lead to Second-Degree Burns

Exhibit 4-25 Neutrally Buoyant Plume Distances to LFL (rural)

Exhibit 4-26 Neutrally Buoyant Plume Distances to LFL (urban)

Exhibit 4-27 Ten-Minute Building Release Attenuation Factors for Prolonged Releases of Anhydrous

Ammonia

Exhibit 4-28 Ten-Minute Building Release Attenuation Factors for Prolonged Releases of Chlorine and

Sulfur Dioxide

Figure 4-1 Worst-Case Scenario — Predicted Distances to Toxic Endpoint for Chlorine

Figure 4-2 Worst-Case Scenario — Predicted Distances to Toxic Endpoint for Sulfur Dioxide

Figure 4-3 Worst-Case Scenario — Predicted Distances to Toxic Endpoint for Anhydrous Ammonia

Figure 4-4 Worst-Case Scenario — Predicted Distances to Toxic Endpoint for Aqueous Ammonia

Figure 4-5 Alternative Case Scenario — Predicted Distances to Toxic Endpoint for Chlorine

Figure 4-6 Alternative Case Scenario — Predicted Distances to Toxic Endpoint for Sulfur Dioxide

Figure 4-7 Alternative Case Scenario — Predicted Distances to Toxic Endpoint for Anhydrous

Ammonia

Figure 4-8 Alternative Case Scenario — Predicted Distances to Toxic Endpoint for Aqueous

Ammonia

Figure 4-9 Guidance on Effectiveness of Building Mitigation for Alternative Scenarios

Figure 4-10 Simplified Presentation of Worst Case and Alternative Scenario on a Local Map

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 Operating Procedures Requirements

Exhibit 6-7 Training Chart 

Exhibit 6-8 Maintenance Guidelines

Exhibit 6-9 Sample Audit Checklist for Safety Information and Hazard Review

Exhibit 6-10 Incident Investigation Requirements

Exhibit 6-11 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
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October 27, 1998

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

CHAPTER 9

Exhibit 9-1 RMP Updates

CHAPTER 11

Exhibit 11-1 Seven Cardinal Rules of Risk Communication
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October 27, 1998

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

Qs and As: Process

Aggregation of Substances

Q and A: Changing Inventories

Qs and As: Compliance Dates

CHAPTER 2

Q and A: Process and Program Level

Qs and As: Public Receptors

Q and A: Determining Distances

Q and A: Environmental Receptors

Qs and As: Accident History

Qs and As: OSHA

CHAPTER 3

Qs and As: Property Damage

Qs and As: Accident History

CHAPTER 4

RMP*Comp

Qs and As: Worst-case and Mitigation

How to Obtain Census Data and LandView

How to Obtain USGS Maps

CHAPTER 6

Q and A: Maintenance

Q and A: Audits

CHAPTER 7

Qs and As: Implementation and Program Level

Qs and As: Process Safety Information

Qs and As: Offsite Consequences
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October 27, 1998

CHAPTER 8

What Is a Response

What Is a Local Emergency Planning Committee?

How Does the Emergency Response Program Apply?

Planning for Flammable Substances

CHAPTER 9

Q and A: Revising a PHA

CHAPTER 10

Qs and As: Delegation

Qs and As: Audits

CHAPTER 11

What Does Your Worst-case 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 An Accident, Will Everyone Within That Distance Be Hurt? What About Property Damage?

How Sure Are You of Your Distances?

Why Do You Need to Store So Much on Site?

What Are You Doing to Prevent Releases?

What Are You Doing to Prepare for Releases?

Do You Need to Use this Chemical?

Why Are Your Distances Different from the Distances in the EPA Lookup Tables?

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?