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Displaying 1 - 15 of 93 results
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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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What will constitute a valid electronic signature for electronic submission of reports to EPA?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA will require that each party who wants to report electronically must sign an agreement that the use of electronic reporting methods will be considered equivalent to paper methods and that personal identification numbers assigned by EPA will…
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What is the definition of a responsible corporate officer (RCO) who is required to certify some of the submissions involved?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Under § 80.75(n), reports to EPA must be signed and certified as correct by the owner or a responsible corporate officer of the refiner, importer, or oxygenate blender. "Owner" means the person who is the principal owner of…
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Could we become the delegated authority for submission of reports on behalf of our members?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Individual blenders could rely on your association to submit reports to EPA on their behalf. . However you should understand that if any reports are not submitted or are submitted improperly then responsibility would fall upon the individual…
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By our reading of the regulations, the only reporting required of the oxygenate blender who elects to comply with the oxygen standard on a per gallon basis is a yearly report due the last day of February of each year (beginning in 1996) that states the to
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Your interpretation is correct.(10/31/94) This question and answer was originally posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF) (333 pp, 18.17 MB, EPA420-R-03-009, July 2003, About…
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Question 14, Section VI.C., of the July 1, 1994 Question and Answer Document provides an example of the creation and addition of two different batches to form a composite mixture. All or a portion of this composite is shipped as RFG. How will the refinery
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Question 14 relates to in-line blending operations that have petitioned EPA for and received an exemption from the independent sampling and testing requirements of the RFG regulations. In such petitions, refiners often define a "batch" of in-line blended…
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The batch report requires reporting the volume percent for six oxygenates -methanol, MTBE, ethanol, ETBE, TAME and t-butanol. If a refiner or oxygenate blender uses MTBE or ethanol as an oxygenate, and does not include in its calculation of oxygen weight
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Trace amounts of oxygenates that may be present in MTBE or ethanol do not have to be reported. However, where a refiner reports total oxygen weight percent that includes MTBE or ethanol plus other oxygenates in larger than…
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If a door is outside the work area but used by workers to enter and exit the room, does the door need to be covered with plastic?
If the work area is smaller than the entire room, and the door is not within the work area, you do not need to cover the door with plastic. However, all personnel, tools, and other items, including the exterior of containers of waste, must be free of dust and debris…
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For an exterior renovation where vertical containment is set up at a distance of less than ten feet from the work surface, must we still extend the ground containment beyond the vertical barrier to meet the ten-foot requirement?
My firm replaces windows. Various obstacles make it difficult to set up the ten-foot exterior ground containment in a way that would enable our renovators to perform the work and still effectively contain dust. In these cases, we lay the ground containment, but also use vertical containment measures to completely…
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In the EPA Certified Renovator Initial course, plastic sheeting is taped to the floor at several corners, but not around the entire perimeter. Must the plastic be "sealed" to the floor on all four edges by tape or just taped at several locations?
It depends on the specifics of the renovation job. The RRP Rule requires the renovation firm to cover the floor surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in the work area 6 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to…
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What are the requirements for covering doorways used to access the work area?
Doors used as an entrance to the work area must be covered with plastic sheeting or other impermeable material in a manner that allows workers to pass through while confining dust and debris to the work area. Question Number: 23002-21413 Find a printable PDF copy of all frequent questions pertaining…
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