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). Is the stationary source subject to the Risk Management Program, requirements?

No. A stationary source is subject to the Risk Management Program requirements only if it has more than a threshold quantity of a regulated substance in a process.