We hear a lot about our biases showing up in many SMS elements and how these biases hamper the SMS and mislead us. But not all biases can be a bad thing. One element where our biases shine brightly is in the Causal Analysis of accidents. For decades now, we have been told over and…...
A process covered under 40 CFR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed at 40 CFR §68.10(b). One of those criteria is that the distance to a toxic or flammable endpoint for a worst-case release assessment is less than the distance to any public receptor. Are…...
Performance of the hazard assessment required under 40 CFR Part 68, Subpart B, includes analysis of both worst-case release scenarios (40 CFR §68.25) and alternative release scenarios (40 CFR §68.28). In each of these analyses, passive mitigation systems may be taken into consideration. If a tank has a “double wall,” does that qualify as “passive…...
I use propane as a raw material in my manufacturing process. I lease the tank from the propane supplier. The supplier does all the maintenance. My staff never work on the equipment. What should I do?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Which states have been granted a delegation of EPA’s authority to implement and enforce the risk management program rule?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
Certain exemptions may apply to determine whether more than a threshold amount of a regulated substance is present at a stationary source under 40 CFR Part 68. One exemption is for regulated substances that are “manufactured, processed, or used in a laboratory at a stationary source under the supervision of a technically qualified individual as…...
I recently submitted my five-year 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?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...
If an owner of a stationary source leases propane tanks from a gas supplier, who is responsible for preparing and submitting the risk management plan (RMP) addressing the propane tanks?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
I run a wastewater treatment plant that is subject to the risk management program regulations in 40 CFR Part 68 for a covered process containing chlorine. A chlorine scrubber system at the plant is designed to prevent any possible releases from reaching a toxic endpoint offsite. How does this active mitigation system affect my selection…...
The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs annually, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)). Are stationary sources responsible for determining if coordination activities should occur more often than annually?… Membership Required You must be a member...
Does the owner or operator have to maintain a written copy of the RMP on site at the stationary source?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
To analyze the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity (40 CFR §68.25(b)). Are mechanical controls such as…...
