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Displaying 16 - 30 of 43 results
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What are the anticipated uses of risk management plans?
What are some of the anticipated uses for the Risk Management Plans (RMPs)? RMPs will be used by many different audiences in many different ways. Industry and trade associations will use RMPs to understand common industry practice and identify practices that could be utilized to reduce risks at facilities. The…
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Are OSHA Voluntary Protection Program facilities exempt from audits?
If we are a Voluntary Protection Program (VPP) facility under OSHA’s VPP program, are we exempt from audits? You are exempt from audits that are based on the accident history of your industry sector or on random, neutral oversight. However, part 68 includes other criteria for deciding what facilities to…
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Correcting RMP with new emergency contact information
Pursuant to the risk management program regulations, the owner or operator of a regulated stationary source is required to submit a correction within one month of any change in the emergency contact information (40 CFR §68.195(b)). What should the owner or operator do for the required correction if they do…
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RMP enforcement powers - states, LEPCs, and fire departments
Would states that have not applied for or received delegation of Clean Air Act 112r/RMP have any enforcement powers? Do LEPCs or fire departments have any enforcement powers? Would this be through the citizen suit provision or is there another statutory mechanism? States that have not applied for or received…
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What are the responsibilities of the Chemical Safety and Hazard Investigation Board?
Section 112(r)(6) of the CAA as amended in 1990 required the President to establish a Chemical Safety and Hazard Investigation Board. Has the Board been established? What are the responsibilities of this Board? The Chemical Safety and Hazard Investigation Board has been established. The Board's responsibilities include investigating chemical accidents…
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State air permitting agency assigning EPA implementation and enforcement
Can a state air permitting agency unilaterally assign to EPA the implementation and enforcement of the requirements of 40 CFR Part 68.215(e)? No, such reassignment of responsibilities can only be achieved by the state entering into a written agreement with the Administrator under which EPA will implement and enforce the…
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RMP Self-Paced Training Courses
Does EPA offer any self-paced training courses covering the Risk Management Program under Clean Air Act Section 112(r)? Yes, EPA Region 7 developed self-paced training modules for facilities with program level 1, 2 or 3 processes. The modules cover topics such as RMP applicability, offsite consequence analysis, 5-year accident history…
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If a facility is grandfathered, is it also exempt from the requirement that feedstocks must be renewable biomass?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Even if a facility is exempt from the 20% GHG reduction requirement, in order to generate RINs, the facility is still required to use feedstocks that meet the definition of renewable biomass. The definition of renewable fuel in…
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Are Canadian facilities included in the grandfathering provision? Does the grandfathering provision extend to facilities that commenced production up to December 31, 2009?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The grandfathering provisions apply equally to facilities inside and outside the RFS program area. Facilities that commenced construction (as defined in §80.1403(a)(4)) prior to December 19, 2007, and which satisfy the timely construction requirements of §80.1403(c)(1) and (2)…
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Naturally Occurring Hydrocarbon Mixtures Exemption
Pursuant to the risk management program regulations under 40 CFR §68.115(b)(2)(iii), regulated substances in naturally occurring hydrocarbon mixtures prior to entry into a natural gas processing plant or a petroleum refining process unit do not need to be considered when determining whether more than a threshold quantity is present at…
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Are facilities that have received ISO 14001 certification exempt from audits?
If we have been audited by a qualified third party, for ISO 14001 certification or for other programs, are we exempt from audits? No. However, you may want to inform your implementing agency that you have gained such certification and indicate whether the third party reviewed Part 68 compliance as…
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Will risk management plan (RMP) submissions be subject to audits?
Will risk management plan (RMP) submissions be subject to audits? If so, who will conduct the audits? Yes. According to 40 CFR §68.220(a), the implementing agency will periodically audit RMPs in order to review their adequacy, and may require revisions of RMPs as necessary to ensure compliance. The implementing agency…
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Applicable requirements for Title V air permits
Under the CAA, air permitting authorities must ensure that sources are in compliance with applicable requirements to issue a permit. Do the CAA §112(r) provisions constitute applicable requirements for Title V air permits? Yes. Section 112(r) is an applicable requirement for CAA Title V air permits under 40 CFR Parts…
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Comprehensiveness and format of a management system
What is a management system (40 CFR §68.15(a))? How comprehensive must it be? Is there a standard format? The management system required under Subpart A of 40 CFR Part 68 is essentially a system defined by facility managers for integrating the implementation of the risk management program elements and assigning…
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Consolidated List of Chemicals Subject to EPA Regulatory Programs
EPA implements a number of regulatory programs that use specific chemical lists as part of the process to determine reporting applicability. Is there a consolidated list of chemicals that are subject to EPA programs? The Consolidated List of Chemicals subject to the Emergency Planning and Community Right-To-Know Act (EPCRA), Comprehensive…
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