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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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  • Is methane generated on site and used for fuel subject to Part 68?

    A wastewater treatment plant generates methane through a natural digestion process, then stores and uses the methane as fuel. Under 40 CFR Part 68, must the owner or operator of this stationary source evaluate the amount of methane to determine whether more than a threshold amount is present in any…

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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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  • Is gasoline exempt from the requirements of Part 68?

    Is gasoline exempt from the requirements of 40 CFR Part 68? Although gasoline is not specifically listed as a regulated substance under 40 CFR Section 68.130, it may contain one or more regulated substances. On January 6, 1998 ( 63 FR 640 ), EPA exempted from threshold determination regulated flammable…

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  • Compliance date for adding covered processes

    What happens if I bring a new covered process on line (e.g., install a second storage tank) after submitting my original RMP? For a new covered process added after the initial compliance date, you must be in compliance on the date you first have a regulated substance above the threshold…

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  • Covered chemicals and the definition of process

    Does a chemical need to be in a process to be covered by the CAA §112(r) risk management program requirements? The risk management program requirements apply to owners and operators of stationary sources that have more than a threshold quantity of a regulated substance contained in a process (40 CFR…

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  • What is the definition of a "technically qualified individual"?

    For the purpose of determining whether more than a threshold amount of a regulated substance is present at a stationary source under 40 CFR Part 68, certain exemptions may apply. One exemption is for regulated substances that are "manufactured, processed, or used in a laboratory at a stationary source under…

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  • Secondary containment calculations in SPCC Plan

    The SPCC regulations in 40 CFR §112.7(c) require facilities to provide appropriate containment or diversionary structures or equipment to prevent discharges as described in §112.1(b). Does a facility's SPCC Plan have to include calculations to demonstrate compliance with the §112.7(c) general secondary containment requirements? EPA does not require facilities to…

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  • What are the specifications for bulk storage secondary containment systems?

    For purposes of the SPCC requirements, "secondary containment for bulk storage facilities must be constructed to at least provide for the capacity of the largest single tank with sufficient freeboard for precipitation. EPA believes that the proper standard of "sufficient freeboard" to contain precipitation is that amount necessary to contain…

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  • What are the amended requirements for oil-filled operational equipment?

    Instead of providing secondary containment for qualified oil-filled operational equipment, an owner or operator may prepare an oil spill contingency plan and a written commitment of manpower, equipment, and materials to quickly control and remove discharged oil. He/she must also have an inspection or monitoring program for the equipment to…

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  • PE certification and applying PE's seal

    Except as provided in 40 CFR §112.6 for qualified facilities, a Professional Engineer (PE) must certify a facility’s SPCC Plan. In order to certify an SPCC plan, must a PE apply his seal to the plan, or is the PE’s signature on a certification statement sufficient for SPCC purposes? For…

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  • What types of oil does the 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 animal, fish, or marine mammal origin; vegetable oils, including oil from seeds, nuts, fruits…

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  • PE certifying a technical amendment

    Except as provided in 40 CFR §112.6 for qualified facilities, a Professional Engineer (PE) must certify all technical amendments to an existing SPCC Plan (§112.5(c)). When certifying a technical change to an existing SPCC Plan, does the PE have to inspect and certify the entire Plan or only the amended…

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  • Leasing out empty oil storage containers.

    A facility leases out empty stationary tanks to other facilities that use the tanks to store oil (e.g., gasoline). The stationary tanks are empty while at the initial facility and eventually leased to other customers to be reused for oil storage. Is the facility that leases out the empty tanks…

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  • Inspection or monitoring program requirements when using alternative secondary containment for oil-filled operational equipment

    Instead of providing secondary containment for qualified oil-filled operational equipment, an owner or operator may prepare an oil spill contingency plan and a written commitment of manpower, equipment, and materials to quickly control and remove discharged oil. He/she must also have an inspection or monitoring program for the equipment to…

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