Learn the Issues

This page shows all of the pages at www.epa.gov that are tagged with Learn the Issues.
  • Are chemicals in a tank car exempt from threshold determinations under 40 CFR Part 68?

    The definition of stationary source does not apply to transportation, including storage incident to transportation (40 CFR Section 68.3). Are chemicals in a tank car (e.g., tanker truck or rail car) therefore exempt from threshold determination? The chemicals in the tank car are exempt only if the tank car is…

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  • Ammonia present in ammonium hydroxide

    The list of regulated toxic substances at 40 CFR Section 68.130 includes both "ammonia (anhydrous)" and "ammonia (conc 20% or greater)," but does not include a specific listing for "ammonium hydroxide." The Chemical Abstract Registry Service (CAS) number for ammonium hydroxide is 1336-21-6, and the CAS number for ammonia is…

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  • RMP Covered Facilities

    Who is covered by the RMP rule under CAA §112(r)(7)? Section 112(r) of the CAA contains several provisions. The two most relevant to the regulated community at this time are Sections 112(r)(1) and 112(r)(7). Owners and operators of stationary sources at which regulated or any other extremely hazardous substances are…

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  • Will the general duty clause be delegated?

    The general duty clause (CAA section 112(r)(1)) is not included in Part 68 and, therefore, will not be delegated to states that have taken implementation of the RMP program. States, however, may adopt their own general duty clause under state law.

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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.

  • Virginia Land Revitalization Cleanup Websites

    Government agencies involved in cleanup in Virginia

  • Recommendations for Area Designations Round 3

    Letters from states recommending area designations.