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  • Are there any industry exemptions from the risk management program regulations?

    Are there any overall industry exemptions from the Accidental Release Prevention provisions and Risk Management Program regulations? No. However, there are exemptions that are widely applicable and affect many facilities in certain sectors. For example, ammonia used as an agricultural nutrient, when held by farmers, is exempt from part 68…

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  • Definition of Fuel

    A flammable substance listed in 40 CFR §68.130 is excluded from the risk management program regulations when it is used as a fuel or held for sale as a fuel at a retail facility (§68.126). What is the definition of fuel for the purposes of this exclusion? There is no…

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  • What exactly is EPA looking for when it takes samples from the soil around residential homes?

    Typically, a person’s primary exposure to soil occurs within the top two feet – working or playing in the yard, gardening, tracking soil into the home, etc. EPA collected samples from the top two feet of soil during the site investigation, focusing the evaluation in the area of the highest…

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  • How do we know that we have not been exposed to contamination from the Landfill for the past 40+ years?

    EPA works closely with its partner, the Agency for Toxic Substances and Disease Registry (ATSDR) in evaluating potential health exposures from waste sources. ATSDR has the ability to look at the cancer registry data to evaluate potential past exposures, while EPA’s role is to evaluate current and future exposure. ATSDR…

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  • Why has it taken EPA so long to fully define the physical boundaries of the Norwood Landfill site?

    EPA did not conduct extensive historical research during the initial investigations in 2017 and 2018. EPA’s previous investigations were based on community request for an assessment of the Norwood Landfill. There was sufficient evidence at that time to move forward with sampling the areas specified by the community without conducting…

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  • What year was the landfill closed? What if any regulations would the Landfill have to have complied with during the closure process?

    During the 1960s, there were minimal environmental regulations regarding landfills and their closure protocol. Historic aerial photographs do not depict organized landfilling via waste disposal on the land after 1963, indicating that most of the activities associated with the Norwood Landfill Site occurred prior to regulations. Additionally, there are no…

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  • Can Norwood residents be exposed to contamination if we grow and eat our own vegetables from gardens in our yards?

    To date, contamination has not been found on residential properties that would pose a risk. In addition, the concentrations of the contaminants found at the Norwood Site are often found in urban communities. Studies show that exposure to contaminants via vegetable gardens is negligible. With the exception of some root…

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  • How is EPA conducting sampling at the Old Norwood Dump and Norwood Landfill?

    EPA took surface soil samples from areas throughout the former Dump area, in a few locations in Norwood Park and along the access road between the Dump and Norwood Landfill. EPA also took soil samples from areas of the Norwood Landfill that were previously inaccessible due to overgrown vegetation. Geoprobe…

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  • How did EPA select the list of regulated substances?

    The list of regulated substances under the chemical accident prevention provisions is found in 40 CFR Part 68. How did EPA select the substances to be included in this list? The chemical accident prevention provisions promulgated pursuant to Section 112(r) of the Clean Air Act (CAA) are designed to focus…

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  • RMP Contractor Related Requirements

    Facilities subject to the Program 3 Prevention Program requirements in 40 CFR Part 68 must include in their Risk Management Plan the date of the most recent review or revision of contractor safety procedures in Section 7.14 and the date of the most recent review or revision of contractor safety…

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  • Distinction between "process" and "covered process"

    What is the distinction between a "process" and a "covered process" under the risk management program regulations at 40 CFR Part 68? Process means any activity involving a regulated substance, including any use, storage, manufacturing, handling, or on-site movement of such substances, or combination of these activities. A "covered process"…

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  • Threshold determination for mixture containing flammable substance and water

    A stationary source has in a process a mixture containing 9,000 pounds of butane and 1,001 pounds of water. The mixture meets the criteria for a National Fire Protection Association flammability rating of 4 (NFPA 4). Is this process covered under the RMP regulations? Yes. Where the concentration of the…

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  • What is the definition of fuel for the purposes of the fuel exclusion for the risk management program?

    A flammable substance listed in 40 CFR §68.130 is excluded from the risk management program regulations when it is used as a fuel or held for sale as a fuel at a retail facility (§68.126). What is the definition of fuel for the purposes of this exclusion? The two prongs…

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  • Why did EPA select the twenty percent concentration cut-off value for aqueous ammonia?

    The list of regulated substances in 40 CFR §68.130 includes aqueous ammonia that is at a concentration of 20 percent (by weight) or greater. Why did EPA select 20 percent as the concentration cut-off value? Commonly used commodity solutions of ammonia (which mean the bulk shipments, not bottles of ammonia…

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  • Stationary source subject to OSHA PSM but below EPA threshold

    A stationary source is subject to the OSHA process safety management standard (PSM) because it exceeds the OSHA PSM threshold for chlorine. The stationary source does not, however, exceed the threshold for chlorine (or any other regulated substances) in a process under the Risk Management Program regulations (40 CFR §68.130)…

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