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Risk Management Program
CAA §112(r)(3) provides EPA the authority to amend the list of regulated substances. Does EPA expect to add chemicals to the list of regulated substances in the near future?
Does EPA have enforcement authority for the risk management program regulations?
If a facility changes owners and significant changes have been made to plant operations is the facility required to update all sections of the RMP and resubmit it to EPA?
If a facility changes owners, but the manufacturing operations have not changed, are they REQUIRED to update their RMP?
Is there an EPA enforcement policy for violators of CAA §112 and the risk management program rule?
Would states that have not applied for or received delegation of Clean Air Act 112r/RMP have any enforcement powers? Do LEPCs or fire departments have any enforcement powers? Would this be through the citizen suit provision or is there another statutory mechanism?
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