The views presented in this paper are those of the author and do not necessarily represent those of the United States Environmental Protection Agency. Abstract Oil and gas operations will be impacted by the risk management program regulations to be promulgated by the U.S. Environmental Protection Agency (EPA) under the Clean Air Act, as amended in 1990 (CAA). In part, the CAA requires facilities with certain hazardous substances above threshold quantities to conduct hazard assessments, implement accident prevention and emergency response programs and prepare risk management plans. The EPA has published final lists of toxic and flammable substances; hydrogen sulfide and several hydrocarbons were listed. The risk management program regulations have been proposed. This paper provides an overview of the statutory requirements for accidental release prevention in section 112(r) of the CAA. The applicability of the final lists to the oil and gas industry is described and the proposed risk management program regulations are summarized. Examples of analyses illustrating potential effects of accidental releases of "sour" gas, methane, propane and pentane are presented. The paper concludes with a brief discussion of some major issues raised in public comments to the proposed rule. Introduction Section 112(r) of the Clean Air Act, as amended in 1990 (CAA), contains several provisions for the prevention of accidental chemical releases. In part, these provisions:–Establish a general duty for owners and operators of stationary sources producing, processing, handling or storing extremely hazardous substances–Require the EPA to promulgate an initial list of at least 100 substances, including 16 mandatory substances as specified in the CAA–Require the EPA to establish a threshold quantity for each listed substance–Require the EPA to promulgate regulations to require P. 569
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