Learn the Issues

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

  • Is gasoline exempt from the requirements of Part 68?

    Is gasoline exempt from the requirements of 40 CFR Part 68? Although gasoline is not specifically listed as a regulated substance under 40 CFR Section 68.130, it may contain one or more regulated substances. On January 6, 1998 ( 63 FR 640), EPA exempted from threshold determination regulated flammable substances…

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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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  • Are there any industry exemptions from the risk management program regulations?

    Are there any overall industry exemptions from the Accidental Release Prevention provisions and Risk Management Program regulations? No. However, there are exemptions that are widely applicable and affect many facilities in certain sectors. For example, ammonia used as an agricultural nutrient, when held by farmers, is exempt from part 68…

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  • Does the chlorine listing apply only to gaseous forms of chlorine?

    There is no qualifier attached to the listing for chlorine (40 CFR §68.130). The listing, therefore, applies to chlorine (CAS number 7782-50-5), regardless of physical state.

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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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  • 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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  • 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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  • 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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  • 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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  • 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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  • Are different substances aggregated for threshold determinations?

    A toxic substance is never aggregated with a different toxic substance to determine whether a threshold quantity is present. If your process consists of co-located vessels with different toxic substances, you must determine whether each substance exceeds its threshold quantity. A flammable substance in one vessel is never aggregated with…

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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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  • 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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  • 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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  • 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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  • Are bulk storage terminals exempt from filing a Risk Management Plan?

    There is no general exemption for bulk storage terminals. However, the threshold exemption for "regulated substances in naturally occurring hydrocarbon mixtures prior to entry into a natural gas processing plant or a petroleum refining processing unit" would exempt certain storage terminals, such as crude oil storage terminals where the regulated…

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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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  • 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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  • Are methane processes at landfills subject to RMP?

    Some landfills collect methane gas and either vent, flare, or store it for subsequent fuel use. Are methane processes at landfills subject to the requirements of the EPA Risk Management Program? In general, methane processes at landfills will not be covered under the Risk Management Program. Methane that is collected…

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