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East Palestine, Ohio Train Derailment
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Risk Management Program (RMP)
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What’s the difference between short-term and long-term chemical exposure levels?
Acute or short-term exposure assumes that a person has been exposed to a chemical for a short period of time. Long term, also known as chronic, exposure assumes a person has been constantly exposed to a chemical for a lifetime, or approximately 70 years.
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How do the different parts of particulate matter (PM) fit together?
The various parts of PM in the NEI are related as follows. PM10-FIL > PM25-FIL because PM10-FIL includes PM25-FIL PM25-PRI = PM25-FIL + PM-CON This equation only applies at the process level. Because some sources only can report PM2.5 (due to test method differences), this equation does not apply to…
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How does PM2.5 relate to PM species such as EC, OC, SO4, NO3, PMFINE, and DIESEL-PM25?
Primary PM2.5 estimates are speciated into the five PM species in the NEI: elemental (black) carbon (EC), organic carbon (OC), nitrate (NO3), sulfate (SO4), and the remainder of PM25-PRI (PMFINE). Diesel engine PM25-PRI and PM10 emissions are also labeled as DIESEL-PM25 and DIESEL-PM10 for mobile source diesel engines. For all…
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Is our East Palestine City Park safe for activities?
Yes. Results show that levels of dioxin and semi-volatile organic compounds are well below any levels that we would consider restricting activities, and all are either at or below typical background levels for soil in the United States. In addition, the village has cleaned all recreational equipment, including the pool…
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What is being done to control dust?
Norfolk Southern contractors use engineering controls to reduce dust generated from cleanup activities and disturbed soil surfaces. All contaminated material leaving the derailment site is secured and tarped, and all contaminated material on site is tarped nightly. Trucks are decontaminated before they leave the site, and large water trucks are…
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Can a facility divide a process when assigning program levels?
My process includes a series of interconnected units, as well as several storage vessels that are co-located. Several sections of the process could qualify for Program 1. Can I divide my process into sections for the purpose of assigning Program levels? No, you cannot subdivide a process for this purpose…
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If a stationary source has processes ineligible for Program 1, are all processes ineligible?
If a stationary source has several processes that are covered under 40 CFR Part 68, and some of those processes have had an accidental release within the past five years (effectively making those processes ineligible for Program 1 status), are the individual processes from which no accidents have occurred also…
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If a covered process has an accident, when does it lose eligibility for Program 1 status?
A process covered under 40 CFR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed at 40 CFR §68.10(b). Those criteria include a requirement that the process cannot have had an accidental release of a regulated substance that led to offsite death, injury…
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Applicability of program levels and prevention program requirements for co-located vessels
I have a tank with 1,000,000 pounds of toluene diisocyanate (TDI), which is covered under the RMP rule, but not under OSHA PSM. Considered by itself, the TDI would be Program 2 for EPA. The tank, however, is close to equipment that has chlorine above the applicable threshold and is…
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Changing from a Program 2 or 3 process to a Program 1 process
If five years have passed since the last accident involving a covered process, and that process meets the other two requirements identified under 40 CFR §68.10(b) for Program 1 eligibility, could that process become a Program 1 process even if it had previously been identified as a Program 2 or…
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Can I grow a garden at home or plant crops?
Yes. You can continue to use your land as you normally would. Residential soil sampling results are within typical ranges for the area. Follow normal measures like peeling root vegetables and washing leafy greens.
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What are the terms used to describe the length of exposure to substances?
Acute exposure is any contact with a substance that occurs once or for up to 14 days. Intermediate exposure is contact occurring for more than 14 days but less than one year. Chronic exposure is contact occurring for longer than one year.
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Assigning program level 1 if a public receptors is just beyond distance to endpoint
Our distance to the endpoint for the worst-case release is 0.3 miles. The nearest public receptor is 0.32 miles away. What tools are available to document that the public receptor is beyond the distance to the endpoint so we can qualify for Program 1? The results of any air dispersion…
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Process that meets Program 1 requirements and Program 3 applicability
Program 3 applies to processes in certain NAICS codes as well as any process subject to the OSHA Process Safety Management (PSM) standard, unless the process is eligible for Program 1. If a process meets the requirements of Program 1, but is also in NAICS code 32211 (one of those…
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Can a process qualify for Program 1 if it has had an accident?
A process with more than a threshold quantity of a regulated substance had an accident with off-site consequences three years ago. After the accident, we altered the process to reduce the quantity stored onsite. Now the worst-case release scenario indicates that there are no public receptors within the distance to…
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