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Displaying 1 - 15 of 57 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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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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If my fuel is already registered with the Fuels and Fuel Additives program under 40 CFR Part 79, do I still need to register with the RFS2 program under 40 CFR Part 80?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. Even if your fuel or fuel additive is already registered under 40 CFR Part 79, there are additional registration requirements for parties regulated under the RFS2 program, as specified in 40 CFR 80.1450.
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Does compliance under OSHA's PSM demonstrate compliance with the risk management program?
The Clean Air Act Amendments of 1990 (CAAA) mandated the Occupational Safety and Health Administration (OSHA) to develop a regulatory program to protect workers from the risk of accidents that involve hazardous chemicals. OSHA promulgated its Process Safety Management Standard (PSM) on February 24, 1992 (57 FR 6356), codified at…
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Applicability of compliance audit provisions to non-prevention program elements
I have a Program 2 covered process and a Program 3 covered process at my stationary source. I am required (by 40 CFR Section 68.58 and 40 CFR Section 68.79) to certify compliance with prevention program requirements every three years. These compliance audits specifically address the prevention program portions of…
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Does a five-year update satisfy the requirement to conduct a compliance audit?
The owner or operator of a stationary source with a Program 2 or Program 3 process must conduct a compliance audit at least every three years to ensure compliance with the prevention program requirements and must revise and update the risk management plan (RMP) at least every five years (§§68.58…
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RMP Program Level 2 and 3 compliance audit frequency
Pursuant to the risk management program regulations, facilities with Program Level 2 and 3 processes must perform compliance audits at least once every three years (40 CFR §§68.58 and 68.79). Do regulated facilities have to perform the audits within exactly three years or can facilities perform the audits any time…
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Does a PHA for OSHA satisfy EPA's PHA requirement for Program 3?
The risk management program regulations require that an initial process hazard analysis (PHA) for each Program 3 process be completed no later than June 21, 1999 (or by the time the process first has more than a threshold quantity of a regulated substance, if that occurs after June 21, 1999)…
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