Would the risk management program regulations cover the loading and unloading of transportation containers?
The definition of stationary source includes transportation containers used for storage, not incident to transportation, and transportation containers connected to equipment at a stationary source for loading or unloading (40 CFR Section 68.3).
In a January 6, 1998 final rule (63 FR 640), EPA clarified that if a container REMAINS ATTACHED TO THE MOTIVE POWER THAT DELIVERED IT TO THE SITE, EVEN IF A FACILITY ACCEPTS DELIVERY, IT WOULD BE IN TRANSPORTATION, and the contents would not be subject to threshold determination (63 FR 643).
PLEASE TAKE NOTE: this says the contents of the transportation containers during loading and unloading do not have to be considered in the threshold determination. But if the process is a COVERED PROCESS, the loading and unloading activities (e.g. connected to the process) are a COVERED TASKS under PSM/RMP.