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Threshold quantity in a process under the RMP rule

Scenario 1: There is a pipeline feeding multiple vessels (4) that total above the threshold quantity. Does this scenario have a threshold quantity of a regulated substance in a vessel involved in a single process?

Yes

No

Scenario 2: There are two vessels that are co-located with the same substance. The total is above the threshold quantity. Does this scenario have a threshold quantity of a regulated substance in a vessel involved in a single process?

Yes

No

Scenario 3:  There are two vessels. They are located so they won’t be involved in a single release. They have different substances, each above the threshold quantity. Does this scenario have a threshold quantity of a regulated substance in a vessel involved in a single process?

Yes

No

Click below to see the answers.

Threshold quantity in a process under the RMP rule: Answers

Scenario 1 Answer:  Yes. A facility must determine whether the maximum quantity of each substance in a process is greater than the threshold quantity listed. If it is, the facility must comply with the RMP rule for that process. The maximum quantity in a pipeline will usually be the capacity of the pipeline (volume). In most cases, pipeline quantity will be calculated and added to the interconnected vessels.

Scenario 2 Answer: Yes. For co-located vessels that are one process, a facility must determine the maximum quantity for each vessel and sum up the quantities of all such vessels.

Scenario 3 Answer: No. This is two processes and not one. There is no concrete rule for how great the distance should be between separate vessels before a facility does not need to consider the vessels as part of one process. Two vessels at opposite ends of a large warehouse room might have to be considered as one process if the entire warehouse or room could be engulfed in a fire. Two vessels separated by the same distance out of doors might be far enough apart that a fire affecting one would be unlikely to spread to the other. Ask yourself how much of the regulated substance could be released if the worst-case scenario happens.