Learn the Issues
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Where to Find EPA Actions on SIP Submittals
Where to find official rulemaking about air State Implementation Plans in the Federal Register and Code of Federal Regulations.
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Opportunities for Input on Housatonic Rest of River Permit Submittals
Opportunities for Input on Housatonic Rest of River Permit Submittals
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Clean Air Act Permitting in Tennessee
Information on air permitting in Tennessee and EPA's oversight.
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Complying with process safety information (PSI) resulting from new and updated recognized and generally accepted good engineering practices (RAGAGEP)
My Program 3 process was built prior to new and updated recognized and generally accepted good engineering practices (RAGAGEP) for my industry. Do I need to implement the new industry practices to comply with process safety information (PSI) requirements under 40 CFR §68.65? EPA expects owners and operators to regularly…
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Do the OSHA PSM training requirements satisfy RMP personnel training?
Under the risk management program regulations at 40 CFR Part 68, sources with Program 2 and Program 3 covered processes are required to develop prevention programs that include personnel training. Will compliance with the training requirements under OSHA's Process Safety Management standard (PSM) satisfy the training requirements under 40 CFR…
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Does compliance under OSHA's PSM demonstrate compliance with the risk management program?
The Clean Air Act Amendments of 1990 (CAAA) mandated the Occupational Safety and Health Administration (OSHA) to develop a regulatory program to protect workers from the risk of accidents that involve hazardous chemicals. OSHA promulgated its Process Safety Management Standard (PSM) on February 24, 1992 (57 FR 6356), codified at…
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Do I have to conduct incident investigations of releases resulting from theft?
The incident investigation provisions of 40 CFR Part 68 (§§68.60 and 68.81) require facilities to investigate incidents that resulted in or could reasonably have resulted in a catastrophic release. Are covered facilities required to perform incident investigations of releases resulting from theft of covered substances, such as anhydrous ammonia? If…
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Hot Work Definition and Requirements
Facilities subject to the Program 3 Prevention Program requirements in 40 CFR Part 68 must include in their Risk Management Plan the date of the most recent review or revision of hot work permit procedures in Section 7.13. What is considered hot work and what are the requirements related to…
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Guidance for on-site compliance evaluations under CAA §112(r)
CAA §112(r)(6)(L) provides employees and employee representatives with rights to participate in EPA CAA §112(r) compliance evaluations. What formal guidance is available from EPA regarding the involvement of facility employees and employee representatives in EPA and delegated Agency on-site compliance evaluations conducted under CAA §112(r)? The EPA Office of Land…
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Is there an EPA enforcement policy for violators of CAA §112 and the risk management program rule?
Yes, EPA has issued a Final Combined Enforcement Policy for section §112(r) Risk Management Program .
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Comprehensiveness and format of a management system
What is a management system (40 CFR §68.15(a))? How comprehensive must it be? Is there a standard format? The management system required under Subpart A of 40 CFR Part 68 is essentially a system defined by facility managers for integrating the implementation of the risk management program elements and assigning…
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How to deregister facility from risk management program
How do I deregister my facility from the risk management program? If a facility is no longer subject to the risk management program, the facility owner or operator must deregister within six months (40 CFR §68.190(c)). To deregister, you should submit a letter to the RMP Reporting Center within six…
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Consolidated List of Chemicals Subject to EPA Regulatory Programs
EPA implements a number of regulatory programs that use specific chemical lists as part of the process to determine reporting applicability. Is there a consolidated list of chemicals that are subject to EPA programs? The Consolidated List of Chemicals subject to the Emergency Planning and Community Right-To-Know Act (EPCRA), Comprehensive…
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Statutory authority and regulatory source for the risk management program
What is the statutory authority and the regulatory source for the risk management program regulations that are codified in 40 CFR Part 68? The risk management program regulations were promulgated pursuant to the §112(r) accidental release prevention provisions of the Clean Air Act, as amended in 1990. The regulatory sources…
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How may state and local rules be more stringent?
In what ways may state and local rules be more stringent? Does this document ( General Risk Management Program Guidance ) provide guidance on state and local differences? States and localities may impose more detailed requirements, such as requiring more documentation or more frequent reporting, specifying hours of training or…
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Other Resources for HFC Allowance Allocation and Reporting
The text of the AIM Act
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RMP Executive Summary Elements
The owner or operator of a stationary source subject to 40 CFR Part 68 must include an Executive Summary in their Risk Management Plan. What elements must be included in the RMP Executive Summary? Pursuant to 40 CFR §68.155, the Executive Summary must briefly describe the following: accidental release prevention…
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Updating RMP with Change in Ownership
Pursuant to the risk management program regulations in 40 CFR §68.10, an owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process must prepare a risk management plan (RMP). If a facility changes owner, but the manufacturing operations have…
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Submitting Annual Certification for Operating Procedures to EPA
The owner or operator of a facility who must prepare a Risk Management Plan (RMP) for a Program 3 process is required to develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information (40 CFR…
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Lead at Superfund Sites: Guidance
Access guidance documents, short sheets, and training videos for addressing lead contamination at Superfund sites.