PCI' PSM and RMP Digest

June 21, 1999 was the deadline for filing initial RMP's for those processes in operation at that time. The RMP must be resubmitted every 5 years, so this year, 2009, all those RMP's that were filed in 1999 will be due for re-submittal.

The EPA is making things somewhat easier by releasing software for online submittal. But, there is still an amount of work that must be done to properly file the information. All of the 14 elements of PSM must be reviewed to assure that all the information is up to date and accurate. It may be possible that your audit or PHA will need to be updated prior to submittal. Get started now to assure all your information is up to date and accurate.

If your ammonia inventory has changed, your worst case and alternative case scenarios may change, which in turn effects the toxic endpoint radius, which could change the estimated population.

If you need any assistance, send us a note or call, and we can help assure your information is accurate and on time.

I don’t quote any code or regulation without using the code or regulation as a guide. I learned early in my career that as soon as I utter the words “the code says….” someone would actually open the book I was referring to and point out some mistake. Even today, with all of the talking and interpreting and consulting, I will find that when I read the actual text, I see words that put an entirely different spin or interpretation on the topic at hand.

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