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  • CFAT Impacts on EPCRA and RMP

    The Department of Homeland Security’s Chemical Facility Anti-Terrorism Standards (CFATS) impose comprehensive federal security regulations for high-risk chemical facilities. Do the CFATS alter the requirements that apply to a facility covered under both CFATS and either the Emergency Planning and Community Right-to-Know Act (EPCRA) or the Clean Air Act section…

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  • EPCRA Reporting Mechanisms for Protecting Sensitive Business Information

    Does EPCRA provide any mechanisms for facilities that must submit Tier II inventory information to protect sensitive business information? Trade secret and confidential location information (CLI) are two separate confidentiality provisions under EPCRA. Trade secret claims made under EPCRA Sections 303, 311, 312, or 313 allow facilities to claim the…

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  • What is a farm for purposes of the SPCC Rule?

    In the December 2006 amendments to the SPCC Rule, EPA defined a farm as "a facility on a tract of land devoted to the production of crops or raising of animals, including fish, which produced and sold, or normally would have produced and sold, 1,000 or more of agricultural products…

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  • Examples of an agent of a Professional Engineer

    Except as provided in 40 CFR §112.6 for qualified facilities, a Professional Engineer (PE) or an agent of the PE must visit and examine the facility before the PE certifies an SPCC Plan (40 CFR §112.3(d)). What are some examples of an agent of a PE? An agent of a…

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  • What is considered bulk oil storage capacity?

    The revised rule recognizes that oil is sometimes stored in bulk and sometimes used operationally. A bulk storage container is any container storing oil at a facility. Bulk oil storage containers may include, but are not limited to tanks, containers, drums, and mobile or portable totes. Operational use includes oil-filled…

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  • Will an Ozone Generator protect me and my family from COVID-19?

    No, do not use ozone generators in occupied spaces. When used at concentrations that do not exceed public health standards, ozone applied to indoor air does not effectively remove viruses, bacteria, mold, or other biological pollutants. Visit the Centers for Disease Control and Prevention's website for best practices to protect…

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  • Mobile fuel tanker as a facility

    Is a non-transportation related mobile fuel tanker with more than 55 gallons located near a 55 gallon drum storage area considered a facility? Perhaps. "Facility" is defined in Part 112 to mean "any mobile or fixed, onshore or offshore building, structure, installation, equipment, pipe, or pipeline (other than a vessel…

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  • Are landfills covered under Title III of SARA since they are covered by RCRA?

    Yes, landfills are subject to certain Title III requirements. Subtitle A of Title III is intended to identify facilities which present a potential hazard for a chemical emergency and to provide a process for local emergency planning committees to engage with such facilities in determining the significance of the release…

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  • Can air cleaning devices that use bipolar ionization, including portable air cleaners and in-duct air cleaners used in HVAC systems, protect me from COVID-19?

    Bipolar ionization (also called needlepoint bipolar ionization) is a technology that can be used in HVAC systems or portable air cleaners to generate positively and negatively charged particles. Provided manufacturers have data to demonstrate efficacy, manufacturers of these types of devices may market this technology to help remove viruses, including…

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  • Will running an evaporative cooler (sometimes known as a "swamp cooler") or whole-house fan help protect me and my family from COVID-19?

    Both evaporative coolers (or "swamp coolers") and whole-house fans can help protect people indoors from airborne transmission of COVID-19 because they increase ventilation with outside air to cool indoor spaces. Evaporative coolers are used in dry climates. They use water to provide cooling and increase relative humidity indoors. When operating…

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  • Where can professionals who manage school, office, and commercial buildings get information on ventilation and filtration to respond to COVID-19?

    Professionals who operate school, office, and commercial buildings should consult the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) guidance for information on ventilation and filtration to help reduce risks from the virus that causes COVID-19. In general, increasing ventilation and filtration is usually appropriate; however, due to the…

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  • Are mobile boosters eligible for the transportation exemption?

    An oil company owns many wells on an oil field. Each well is on its own plot of land. These plots are not adjacent or contiguous and, therefore, each well is its own facility. When operating these wells, it is sometimes necessary to inject air or gas into the well…

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  • What is a field-constructed container?

    What are the types of containers or equipment containing oil reservoirs that would be considered field-constructed containers and thus subject to the brittle fracture evaluation of 40 CFR §112.7(i)? As found in the Preamble language provided on page 47112 of the July 17, 2002 SPCC final rule, EPA provides a…

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  • What is oil-filled operational equipment?

    Oil-filled operational equipment is equipment that includes an oil storage container (or multiple containers and associated piping intrinsic to the operation of the equipment) in which the oil is present solely to support the function of the apparatus or the device. It is not considered a bulk storage container, and…

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  • Pipeline tanks and the transportation exemption in Title III

    An oil corporation's pipeline facility contains three kinds of tanks. One type is a breakout tank used to receive and store hazardous liquids transported by a pipeline for reinjection and continued transportation by the corporation's pipeline. Another type is used to receive and store hazardous liquid for delivery to pipelines…

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