Learn the Issues

This page shows all of the pages at www.epa.gov that are tagged with Learn the Issues.

  • Are the risk management program requirements applicable to federal facilities?

    Yes. The requirements at 40 CFR Part 68 are applicable to an owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process (40 CFR §68.10(a)). The definition of stationary source includes buildings, structures, equipment, installations, or substance emitting stationary…

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  • Worst-case Scenario for Flammable Mixtures

    For the risk management program, where the concentration of the regulated flammable substance in the mixture is one percent or more by weight of the mixture, the entire weight of the mixture must be applied toward the 10,000 pound threshold quantity for the flammable substance unless the owner or operator…

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  • Compliance date for adding covered processes

    What happens if I bring a new covered process on line (e.g., install a second storage tank) after submitting my original RMP? For a new covered process added after the initial compliance date, you must be in compliance on the date you first have a regulated substance above the threshold…

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  • Treatment of Air Quality Monitoring Data Influenced by Exceptional Events

    Describes and documents data handling for air quality measurements flagged as being affected by exceptional events like wildfires, dust storms, volcanic eruptions, etc.

  • Did the Risk Management Program final rule affect the List Rule?

    Did the Risk Management Program final rule ( 61 FR 31668; June 20, 1996) change or affect the January 31, 1994, List of Regulated Substances and Threshold Quantities final rule (59 FR 4478; January 31, 1994)? No. The Risk Management Program final rule did not alter the 1994 "List Rule;"…

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  • Do the risk management program regulations cover the loading and unloading of transportation containers?

    Would the risk management program regulations cover the loading and unloading of transportation containers? The definition of stationary source includes transportation containers used for storage not incident to transportation and transportation containers connected to equipment at a stationary source for loading or unloading (40 CFR Section 68.3). In a January…

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  • Must separate amounts of regulated substances be aggregated for threshold determinations?

    Drums containing regulated substances (listed in 40 CFR §68.130) are stored in several separate locations at a stationary source and there is no possibility that an accidental release in any of the individual storage areas would impact any of the other storage areas. Must the overall amount of the regulated…

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  • How did the January 6, 1998, final rule affect the definition of stationary source?

    How did the January 6, 1998, final rule ( 63 FR 640) affect the definition of stationary source, as it relates to the transportation exemption? The January 6, 1998 final rule amended the regulatory definition of stationary source by removing previous references to "active shipping papers" and "temporary storage" and…

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  • Time Frame to Submit RMP Emergency Contact Information Changes

    How much time does the owner or operator of a stationary source have to submit a correction to a Risk Management Plan when the emergency contact information changes? The Risk Management Plan (RMP) regulations require an owner or operator of a stationary source to correct their RMP within one month…

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  • Hydrochloric acid and hydrogen chloride listed separately

    Why are hydrochloric acid and hydrogen chloride listed separately in the list of regulated substances at 40 CFR §68.130? The aqueous form (hydrochloric acid) and the anhydrous form of this chemical (hydrogen chloride) have been assigned different thresholds.

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  • Is a source in compliance with OSHA's PSM already in compliance with Part 68?

    If a stationary source includes processes that are subject to both the OSHA process safety management (PSM) standard and the Program 3 risk management program requirements, what must the owner or operator of the stationary source do to demonstrate compliance under 40 CFR Part 68? A source owner or operator…

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  • Is methane generated on site and used for fuel subject to Part 68?

    A wastewater treatment plant generates methane through a natural digestion process, then stores and uses the methane as fuel. Under 40 CFR Part 68, must the owner or operator of this stationary source evaluate the amount of methane to determine whether more than a threshold amount is present in any…

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  • Is underground storage included in the definition of a process?

    Would underground storage of a regulated substance listed at 40 CFR §68.130 subject a stationary source owner or operator to the risk management program regulations? If more than a threshold quantity of a regulated substance is present in a process at a stationary source, the owner or operator of that…

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  • Is replacing a process tank considered a modification?

    If an RMP covered facility replaces a storage tank that is a covered process with a new tank containing the same regulated substance, is this considered to be a modification of an existing process, or a new process? Assuming the new tank contains the same substance and occupies the same…

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  • Amounts of chlorine present in sodium hypochlorite

    Must the amount of chlorine present in sodium hypochlorite be considered when determining whether a process is subject to the Risk Management Program regulations in 40 CFR Part 68? No. The risk management program regulations apply only to processes that contain more than a threshold quantity of one of the…

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  • Which chemicals are covered by the general duty provisions?

    For CAA section 112(r)(1), General Duty, what are the chemicals that are covered? There is no specific list of substances which subject a stationary source owner or operator to the general duty provisions. The general duty provisions apply to owners and operators of all stationary sources which have any "extremely…

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  • RMP Self-Paced Training Courses

    Does EPA offer any self-paced training courses covering the Risk Management Program under Clean Air Act Section 112(r)? Yes, EPA Region 7 developed self-paced training modules for facilities with program level 1, 2 or 3 processes. The modules cover topics such as RMP applicability, offsite consequence analysis, 5-year accident history…

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  • Owner / Operator Compliance Audit Timeline

    The regulations in 40 CFR §§68.58 and 68.79 require the owner or operator of facilities to conduct and document compliance audits at least every three years, although an owner or operator is not required to conduct a compliance audit prior to submitting a facility’s first RMP. Must an owner or…

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  • No Procedure for Requesting RMP Five-Year Review Extension

    The Risk Management Program (RMP) regulations require the owner or operator of a stationary source to revise and update the source's RMP at least once every five years from the date of its initial submission or most recent full update (§68.190(b)). Is there a procedure for obtaining an extension to…

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  • CAMEO Training Opportunities

    Where can I find CAMEO training opportunities? Information on CAMEO training and events is available at the EPA CAMEO website.

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