Learn the Issues
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Threshold determination for mixture containing flammable substance and water
A stationary source has in a process a mixture containing 9,000 pounds of butane and 1,001 pounds of water. The mixture meets the criteria for a National Fire Protection Association flammability rating of 4 (NFPA 4). Is this process covered under the RMP regulations? Yes. Where the concentration of the…
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Stationary source subject to OSHA PSM but below EPA threshold
A stationary source is subject to the OSHA process safety management standard (PSM) because it exceeds the OSHA PSM threshold for chlorine. The stationary source does not, however, exceed the threshold for chlorine (or any other regulated substances) in a process under the Risk Management Program regulations (40 CFR §68.130)…
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Should tank capacity be considered when determining thresholds?
When determining whether a threshold amount of a regulated substance is present in a process (e.g., a tank), must the owner or operator of a stationary source consider the total capacity of the process, or the actual amount of regulated substance contained in the process? The threshold determination is based…
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Qualifier "solution" in the listing for formaldehyde
Formaldehyde is listed in 40 CFR 68.130 with the qualifier "solution." Does the qualifier refer only to mixtures of formaldehyde and water, or does it apply to any liquid mixture containing formaldehyde? Formaldehyde (CAS No. 50-0-0) is listed with the qualifier "solution" because pure formaldehyde has a tendency to polymerize…
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Process identification and distance between vessels
How far apart do separate vessels have to be to be considered different processes? There is no hard and fast rule for how great this distance should be before you do not need to consider the vessels as part of one process. Two vessels at opposite ends of a large…
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Part 68 regulations compared to other CAA provisions
Do the risk management program regulations at 40 CFR Part 68 place additional requirements on stationary sources that are currently in compliance with all other provisions of the Clean Air Act (CAA)? Yes. Owners and operators of stationary sources who meet the applicability criteria at 40 CFR §68.10 must comply…
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Distinction between "process" and "covered process"
What is the distinction between a "process" and a "covered process" under the risk management program regulations at 40 CFR Part 68? Process means any activity involving a regulated substance, including any use, storage, manufacturing, handling, or on-site movement of such substances, or combination of these activities. A "covered process"…
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When must RMPs be submitted, updated, and corrected?
When must the risk management plans (RMPs) required under 40 CFR Part 68, Subpart G, be submitted? When are updates and corrections required? Compliance with the risk management program requirements (including submission of an RMP) is required by the date on which a regulated substance first becomes present above a…
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Different results using ALOHA and RMP*Comp
I tried running the same scenarios in ALOHA and in RMP*Comp. I got different answers. Why? The results you obtain using RMP*Comp may not closely match the results you obtain running the same release scenario in a more sophisticated air dispersion model such as ALOHA or DEGADIS. That's because of…
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Worst-case release scenarios for toxics and flammables involving the same process
At my facility, if the worst-case release scenarios for regulated toxic substances and the worst-case scenario for regulated flammable substances involve the same process, must I analyze both? Yes. If the worst-case release scenarios for regulated toxic substances and regulated flammable substances in Program 2 and 3 processes are associated…
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How often must compliance audits be performed?
How often must owners or operators of stationary sources subject to the risk management program regulations perform compliance audits? The regulations at 40 CFR §§68.58(a) and 68.79(a) state that owners or operators must certify that they have evaluated compliance with the applicable prevention program provisions at least once every three…
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When does the accident history's five-year period begin?
The hazard assessment requirements under 40 CFR Part 68, Subpart B include provision of a five-year accident history, as specified at §68.42. When does the five-year period to be reported in the accident history begin? The five-year accident history must include information on all accidental releases from covered processes meeting…
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Definition of recreational area for determining offsite impacts in RMP
What is considered a recreational area? Recreational areas would include land that is designed, constructed, designated, or used for recreational activities. Examples are national, state, county, or city parks, other outdoor recreational areas such as golf courses or swimming pools and bodies of waters (oceans, lakes, rivers, and streams) when…
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RMP Records Maintained Onsite
Pursuant to 40 CFR Part 68, Subpart G, the owner or operator of a stationary source subject to the risk management program regulations in Part 68 must develop and submit a risk management plan (RMP). Does the owner or operator have to maintain a written copy of the RMP on…
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Air Modeling - Announcements
Air Modeling Recent Additions
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Mystic River Watershed Steering Committee Meeting, October 11, 2018
View document(s) for the October 11, 2018 Mystic River Watershed Steering Committee Meeting.
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Mystic River Watershed Water Quality Science Forum, January 24, 2013
Document(s) from the January 24, 2013 Water Quality Science Forum for the Mystic River Watershed.
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Mystic River Watershed Municipal Subcommittee Meeting, November 15, 2012
Document(s) from the November 15, 2012 Municipal Subcommittee Meeting for the Mystic River Watershed.
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Mystic River Watershed Steering Committee Meeting, October 13, 2016
Document(s) from the October 13, 2016 Steering Committee Meeting for the Mystic River Watershed.
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Mystic River Watershed Open Space Subcommittee Meeting, September 29, 2016
Document(s) from the September 29, 2016 Open Space Subcommittee Meeting for the Mystic River Watershed.