Learn the Issues
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Are "tube" trailers considered a single process?
Tube trailers carry bulk liquids that are stacked in a rack type arrangement on the back of a truck trailer. This arrangement often is used to carry highly hazardous materials such as anhydrous hydrogen chloride. The tubes are manifolded together, but usually only one tube at a time is connected…
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Ammonia used as agricultural nutrient held by farmers and the general duty clause
Does the exemption at 40 CFR 68.125 for "ammonia used as an agricultural nutrient, when held by farmers" apply to the CAA Section 112(r)(1) general duty clause? No. The exemption for ammonia held by farmers for use as fertilizer applies only to the provisions of the risk management program regulations…
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Applicability for a process at a facility connected to another facility by piping
The definition of process would seem to say that my process is part of the larger company’s process because they are interconnected. Why can’t the larger company just include my process in its RMP? Your process is not part of the larger company’s stationary source because it does not meet…
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Determining thresholds for different chemicals in interconnected vessels
According to the definition of "process" in 40 CFR §68.3, any group of vessels that are interconnected is considered to be a single process. If a stationary source has two interconnected vessels and one contains 6,000 pounds of butane while the other contains 6,000 pounds of propane, is this a…
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Can the partial pressure exemption be applied to formaldehyde solutions?
Formaldehyde is not specifically listed with a concentration cutoff, but is listed with the qualifier "solution". Can the partial pressure exemption be applied to formaldehyde solutions? According to 40 CFR §68.115, the amount of any listed toxic substance present in a mixture at a concentration greater than 1% does not…
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Rainwater in containment system of SPCC regulated farm
What do I do with rainwater that accumulates in my containment system for a farm regulated by the Spill Prevention, Control, and Countermeasure (SPCC) rule? Check the rainwater for any oil, and if no oil is present, this can be released. If there is oil in the water, this water…
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Liability of oil retailers at SPCC regulated farm
If a farm is out of compliance of Spill Prevention, Control, and Countermeasure (SPCC) regulations and is checked by EPA and/or has a spill, is the retailer that filled the tank liable? No, EPA considers the oil tank owner responsible for lack of compliance.
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Counting Ammonia and Ammonium Hydroxide for Emergency Planning Notification under EPCRA section 302
Ammonium hydroxide is a solution of ammonia in water. If a facility stores ammonium hydroxide (CAS #1336-21-6) in a large storage tank on site, should the facility include the quantity of ammonia in ammonium hydroxide for the Emergency Planning and Community Right-to-Know Act (EPCRA) section 302 emergency planning notification? The…
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Differences between the risk management program and EPCRA
How do the Clean Air Act (CAA) risk management program requirements differ from the hazardous chemical reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA)? The hazardous chemical reporting requirements under EPCRA sections 311 and 312 ( 40 CFR Part 370 ) are separate and distinct from those…
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Should very similar combinations of hazardous chemicals be aggregated?
How should a person determine whether very similar combinations of hazardous chemicals (e.g., different colors of paint or different blends of gasoline) that have separate MSDSs (Material Safety Data Sheet) should be aggregated for Tier II reporting? The owner or operator of a facility may make the EPCRA §§311 and…
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Cardlock Fueling Stations and EPCRA 311 / 312
Cardlock fueling stations are locations that allow businesses to obtain a card for each driver or vehicle and then provide 24-hour, automated access to the fueling station by using the card. For the Emergency Planning and Community Right-to-Know Act (EPCRA) material safety data sheet (MSDS) and chemical inventory reporting, gasoline…
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Can states designate liquified petroleum gas facilities under Section 302
Does the statute allow the state to designate facilities which produce, use, or store certain quantities of liquified petroleum gas as emergency planning facilities? EPA considers the designation of additional facilities to be accomplished through naming individual sites or companies, or by designation of certain classes of facilities as newly…
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SPCC Rule regulated oil types
What types of oil does the Spill Prevention, Control, and Countermeasure (SPCC) Rule address? The term oil means oil of any kind or in any form, including, but not limited to: petroleum; fuel oil; sludge; oil refuse; oil mixed with wastes other than dredged spoil; fats, oils or greases of…
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Fact Sheet: Final Rule 22 - Protection of Stratospheric Ozone: Revision to References for Refrigeration and Air Conditioning Sector To Incorporate Latest Edition of Certain Industry, Consensus-based Standards
Section 612 provides that EPA must prohibit the use of a substitute where EPA has determined that there are other available or potentially available substitutes that pose less overall risk to human health and the environment.
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Virginia Land Revitalization Cleanup Websites
Government agencies involved in cleanup in Virginia
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Recommendations for Area Designations Round 3
Letters from states recommending area designations.
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WaterSense Accomplishment Reports
WaterSense Accomplishments reports
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2021 P3 Expo - Advancing Next Generation Genomic Tools for Detection of Naegleria Fowleri in Potable Water
Advancing Next Generation Genomic Tools for Detection of Naegleria Fowleri in Potable Water P3 Team
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Children Are Not Little Adults!
They are often more likely to be at risk from environmental hazards because of unique activity patterns/behavior, physiological differences, and windows of susceptibility during early lifestages including fetal development and puberty.
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SO2 Designations - Round 4 State Recommendations and EPA Responses
Sulfur Dioxide Designations - State Recommendations Round 1