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What does EPA plan to do to verify the accuracy and completeness of submitted Risk Management Plans (RMPs)?
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Would the risk management program regulations cover the loading and unloading of transportation containers?
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Some landfills collect methane gas and either vent, flare, or store it for subsequent fuel use. Are methane processes at landfills subject to the requirements of the EPA Risk Management Program?
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Oleum, which is a mixture of sulfuric acid and sulfur trioxide, is listed as a regulated toxic substance in 40 CFR §68.130.
Sulfur trioxide is also listed individually as a regulated toxic substance.
Suppose a single process consists of one vessel containing oleum and one vessel containing sulfur trioxide. Must the amount of sulfur trioxide in the oleum be aggregated with the amount of pure sulfur...
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Why are hydrochloric acid and hydrogen chloride listed separately in the list of regulated substances at 40 CFR §68.130?
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Several toxic substances are listed as regulated substances under 40 CFR §68.130 with concentration qualifiers (e.g., “conc 37% or greater”).
What does this concentration mean?
When determining whether a threshold amount of these substances exists in a process, should I consider the weight of the entire solution, or simply the amount of the regulated toxic substance in the solution?
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Drums containing regulated substances (listed in 40 CFR §68.130) are stored in several separate locations at a stationary source and there is no possibility that an accidental release in any of the individual storage areas would impact any of the other storage areas. Must the overall amount of the regulated substance present at the stationary source be considered when determining whether the threshold...
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Under 40 CFR Part 68, to determine whether more than a threshold amount of a regulated substance is present at a stationary source, certain exemptions may apply. One such exemption is provided for “activities in laboratories” (40 CFR §68.115(b)(6)). If laboratory chemicals are stored outside the laboratory, are they exempt from threshold determination?
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Effective February 24, 2023, 6:00 p.m. EST, the registration process for RMP*eSubmit Certifying Officials is changing to use additional Central Data Exchange (CDX) registration features.
Certifying Officials will now be required to identity proof and sign a standard CDX Electronic Signature Agreement (ESA) as part of CDX the registration process.
The CDX ESA is different than the facility ESA generated...
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This is an interesting agreement, none like I have seen before. Had OSHA done this inspection, using their new Wilfull Instance-by-Instance Penalty Adjustments, this case could have exceeded $1M in fines. Yet, the case resulted in $0 in fines and a correction plan. This facility had two (2) releases (Oleum and Ammonia) in the same month last year, prompting the EPA inspection. ...
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Respondent operated a facility to provide pre-cooling and short term storage for fresh vegetables harvested by local growers, including lettuce, cabbage, and brussels sprouts. Respondent produced, used, or stored more than 10,000 pounds of ammonia (anhydrous) at the Facility and was subject to the requirements of CAA§ 112(r)(7). Respondent was subject to Program 3 requirements because it had...
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