Do I have to count the quantities of my RMP covered chemicals in railcars sitting on my site?

We don’t see this often, so I feel it is worthy of posting this RMP Citation.  I have written several articles about this and posted a couple of citations.  This one was just posted this week…

Process Safety Information [40 C.F.R. 68 .65(c)(l)(iii)] – $300

[Facility] failed to include quantities containing regulated substances purchased for its facility located in disconnected railcars as part of its maximum intended inventory.  Facility addressed this post inspection.

CLICK HERE for the ESA

 

 

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