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  • What if the quantity in the process fluctuates?

    What if the quantity in the process fluctuates? I may not have a threshold quantity now, but I will intermittently exceed the threshold quantity. You do not need to comply with the rule and file an RMP unless you have more than threshold quantity in a process; however, once you…

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  • Why are industries exempt under OSHA's PSM subject to RMP?

    The Program 3 prevention program requirements under 40 CFR Part 68 are almost identical to the requirements of OSHA's process safety management (PSM) standard. OSHA exempts certain industries from the PSM standard. Why does EPA not exempt those same industries from the CAA §112(r) risk management program requirements? EPA and…

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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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  • 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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  • 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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  • Updating RMP if EPA lists a new substance

    What if EPA lists a new substance? You will have three years from the date on which the new listing is effective to come into compliance for any process that is covered because EPA has listed a new substance.

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  • What does "same industrial group" mean?

    Operations at a site that belong to the same three-digit North American Industry Classification System (NAICS) code prefix (which has replaced the old SIC codes) belong to the “same industrial group. In addition, where one or more operations at the site serve primarily as support facilities for the main operation…

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  • Change of owner and RMP facility ID number

    If a facility is sold to a new owner, does it keep its' original RMP Facility ID number? Yes. The facility will keep the ID number assigned by EPA.

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  • Resubmission of RMP for a facility that previously deregistered

    A covered facility deregisters its RMP because it no longer has more than a threshold quantity of a regulated substance in a covered process. If the facility becomes subject to the CAA §112(r) risk management program regulations at a later date and submits a new RMP, should the facility submit…

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  • Facility ID number and re-registering a facility

    If a facility deregisters, then reregisters, should the facility use the original RMP Facility ID or will it be assigned a new ID? The facility should use the original ID assigned by EPA.

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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"…

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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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  • 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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  • 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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  • If laboratory chemicals are stored outside the laboratory, are they exempt from threshold determination?

    Under 40 CFR Part 68, for the purpose of determining whether more than a threshold amount of a regulated substance is present at a stationary source, certain exemptions may apply. One such exemption is provided for "activities in laboratories" (40 CFR §68.115(b)(6)). If laboratory chemicals are stored outside the laboratory…

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