The Regulator's Use of the Worst-Case Scenario
The Regulator's Use of the Worst-Case Scenario (1996)-The requirements of the USEPA’s Risk Management Program (RMP) regulations (40 CFR Part 68) to perform worst-case scenario analysis of potential acute accidental releases of listed regulated substances will make mandatory everywhere an effort that has been occurring in various states throughout the country. The USEPA’s RMP regulations will require covered ammonia refrigeration facilities to perform worst-case consequence assessments of catastrophic accidental releases. Consequence assessment information will, for the first time, be publicly available. While there has been considerable discussion on the definition of “worst-case” as it relates to ammonia refrigeration systems, and the high degree of subjectivity in performing such analyses, there has been relatively little discussion on how this information will be used. For several years, New Jersey, California, and Delaware have required dispersion and consequence analysis as part of their risk management programs. Ammonia refrigeration facilities in these states have been conducting and reporting to state and local agencies the results of off-site consequence assessments. This paper will review activities and programs in these states and evaluate the use of this data for risk management, emergency response planning, and public information inquiries. The paper will also address the planned use of the data to be generated by the USEPA’s RMP regulation; it will also offer recommended uses of this information as it relates to ammonia refrigeration, as well as potential misuses of the data.
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