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Displaying 1 - 15 of 90 results
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Obtaining an RMP ID Number
How can a facility subject to the Risk Management Plan (RMP) requirements obtain its RMP ID number? The owner or operator of a regulated RMP facility that has already submitted an RMP, may obtain the facility's identification number (RMP ID Number) by contacting the RMP Reporting Center (703-227-7650). An RMP-covered…
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Does EPA have enforcement authority for the risk management program regulations?
Yes. Under §113 of the CAA, the Agency has the authority to bring administrative and judicial actions against violators. Judicial actions can be civil and criminal in nature. Section 113(a)(3) authorizes the Agency to order violators to comply with the risk management program regulations. Under section 113(b), the Agency may…
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Criteria for selecting stationary sources to audit
What criteria will be used to select stationary sources for periodic compliance audits of risk management plans (RMPs) submitted under 40 CFR Part 68, Subpart G? The implementing agency will, according to the regulations at 40 CFR §68.220(b), select stationary sources for audits based on any of the following criteria…
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Is there a citizen suit provision applicable to RMP?
Is there a citizen suit provision applicable to CAA §112 and the risk management program rule? Yes, section 304 of the CAA includes a citizen suit provision for violations of emission standards or limitations promulgated under the Act.
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Accessing RMP Data
Is Risk Management Plan (RMP) data available to the public and, if so, where can it be found? Risk Management Plans (RMPs) prepared and submitted pursuant to CAA section 112(r) are, by statute, available to the public. Members of the general public may obtain RMP data by visiting a designated…
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Hot Work Definition and Requirements
Facilities subject to the Program 3 Prevention Program requirements in 40 CFR Part 68 must include in their Risk Management Plan the date of the most recent review or revision of hot work permit procedures in Section 7.13. What is considered hot work and what are the requirements related to…
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Do I have to conduct incident investigations of releases resulting from theft?
The incident investigation provisions of 40 CFR Part 68 (§§68.60 and 68.81) require facilities to investigate incidents that resulted in or could reasonably have resulted in a catastrophic release. Are covered facilities required to perform incident investigations of releases resulting from theft of covered substances, such as anhydrous ammonia? If…
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Do Program 1 processes have to complete a process hazard analysis?
Do owners or operators of Program 1 processes have to complete a process hazard analysis? No. The Program 1 requirements do not include a process hazard analysis (40 CFR §68.12(b)). Program 3 processes require completion of a process hazard analysis (40 CFR §68.12(d)(3)) while Program 2 processes must complete a…
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Is a hazard review synonymous with a process hazard analysis (PHA)?
The prevention program requirements under 40 CFR Part 68, Subparts C and D, include hazard reviews and process hazard analyses. Is a hazard review synonymous with a process hazard analysis (PHA)? No. A hazard review is different from a PHA. A hazard review is part of the Program 2 prevention…
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How often must compliance audits be performed?
How often must owners or operators of stationary sources subject to the risk management program regulations perform compliance audits? The regulations at 40 CFR §§68.58(a) and 68.79(a) state that owners or operators must certify that they have evaluated compliance with the applicable prevention program provisions at least once every three…
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How may state and local rules be more stringent?
In what ways may state and local rules be more stringent? Does this document ( General Risk Management Program Guidance ) provide guidance on state and local differences? States and localities may impose more detailed requirements, such as requiring more documentation or more frequent reporting, specifying hours of training or…
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Is it required that the professional engineer conducting the engineering review must be licensed in the state in which the renewable fuel facility is located?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The licensed professional engineer should comply with the state laws where the renewable fuel facility is located to determine whether or not their license allows them to conduct business in that state.
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May records, regardless of whether they are paper or electronic, be stored off-site?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. Refiners, oxygenate blenders and importers must indicate where records will be kept on all facility registrations.(7/1/94) This question and answer was originally posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994…
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Is the licensed professional engineer conducting the engineering review required to perform the site visit in person, or can they delegate the site visit to another person who maybe assisting them in the engineering review?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Pursuant to §80.1450(b)(2), all verifications must be performed by the licensed professional engineer conducting the engineering review. This requirement includes conducting the site visits. The licensed professional engineer conducting the engineering review must perform the site visits to…
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In filing company and facility registrations, if a parent corporation has several subsidiary corporations it desires to register and report to EPA under one company ID number, would it be permissible to register all of the facilities operated by the subsi
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In this situation the parent corporation should register for a company ID # and facilities operated by the subsidiary corporations should be registered as separate facilities but under the parent corporation's company ID #.(8/29/94) This question and answer…
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