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  • How is waste leaving the derailment site tracked?

    EPA on-scene coordinators are assigned to track liquid–and solid–waste trucks entering and leaving the derailment site. They log every truck, oversee the loading and covering of waste, truck washing and weighing, and the proper placement of placards. Responders take pictures throughout the process. All trucks go to approved and regulated…

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  • What happens after the track work is completed?

    The track work has been the highest priority to remove most contamination as early as possible. This, plus preventing the spread of contamination by capturing water from the site and constructing a bypass of Sulphur Run around the site will continue into June. While track work and water management continue…

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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 does the on-site wastewater treatment process on site entail?

    EPA has approved a workplan to allow Norfolk Southern to treat hazardous wastewater on-site, removing vinyl chloride and other contaminants to dispose of the treated wastewater off-site as a non-hazardous waste. Currently, the train derailment site generates nearly one million gallons of wastewater per week from the collection of stormwater…

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  • Where is the treated wastewater going?

    The wastewater treatment system removes derailment contaminants using several steps, including sedimentation and filtration. The treated wastewater is then tested to verify vinyl chloride is below the drinking water standard. Once treated, water is sent to facilities certified to accept non-hazardous wastewater and that are regulated by federal and state…

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  • Are there health risks to driving through Taggart Street?

    There are no anticipated health risks along Taggart Street associated with project activities. As work proceeds, to ensure worker and community safety, the Unified Command will continue to evaluate site conditions for health and safety considerations. While traffic will be able to proceed through the work areas along Taggart Street…

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  • How much waste was removed as part of the cleanup efforts?

    In late October, EPA announced the completion of major derailment site excavation. Remaining contaminated soil and debris were removed for off-site treatment or disposal. Contact water continues to be treated in an on-site wastewater treatment system prior to removal for off-site disposal. As of November 13, over 174,000 tons of…

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  • Are the trucks leaving the derailment site spreading contamination?

    Each truck leaving the derailment site that is carrying contaminated waste is checked to ensure all material is safely secured. Also, all trucks go through a washing process before departing the site. The washing process ensures the vehicles’ wheels and undercarriage are free of dirt and mud. Street sweepers are…

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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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