How far would you go with the “co-Location” coverage to determine PSM/RMP coverage?

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This summer we saw a 300,000-gallon water tank fail which pushed a generator into a covered process which led to a release of the HHC/EHS. The questions I wish to pose are:

  1. Should the water tank have fallen under the PSM/RMP program due to its proximity to the covered process?
  2. Should the proximity of the water tank be part of the facility siting assessment in the PHA?

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