Carry RMP compliance into air-permit terms and certification

Use this document to resolve one bounded operational decision: Carry RMP compliance into air-permit terms and certification. Only the official source and traced locations below supply facts. Confirm applicability before acting.

Source fact:

The official 40 CFR 68.215 – Permit content and authority requirements from Environmental Protection Agency via eCFR supports the following bounded statements:

• For a stationary source subject to part 68 and part 70 or 71, the air permit must list part 68 as applicable and require either a compliance schedule or certification of part 68 compliance, including RMP registration and submission. The research record locates this support at 40 CFR 68.215(a)(1), 68.215(a)(2)(i), and 68.215(a)(2)(ii), read with 40 CFR 68.215(a) (eCFR anchors p-68.215(a)(1), p-68.215(a)(2)(i), and p-68.215(a)(2)(ii)).
• A pre-deadline part 70 or 71 permit lacking those conditions must be revised or reopened under the applicable permit procedures. The research record locates this support at 40 CFR 68.215(c) (eCFR anchor p-68.215(c)).

Do not import neighboring assumptions into the source record. The supported task is a scoped comparison involving critical rooms, power, cooling, water, fire protection, alternate sites, physical barriers, and documented recovery paths and the conditions the source actually describes.

What the source does not establish

This applies only to stationary sources jointly subject to 40 CFR parts 68 and 70 or 71. The permitting authority determines permit action, completeness, inspection, and enforcement. A correct source interpretation can still be inapplicable to a particular design. Confirm identity and access control, Windows DNS where networked services use it, time, communications, utilities, life-safety systems, vendors, and authorized responders, ownership, and change authority instead of treating documented behavior as a deployment guarantee.

Applicability questions

• For source statement 1 at 40 CFR 68.215(a)(1), 68.215(a)(2)(i), and 68.215(a)(2)(ii), read with 40 CFR 68.215(a) (eCFR anchors p-68.215(a)(1), p-68.215(a)(2)(i), and p-68.215(a)(2)(ii)), which observable configuration, record, or test can confirm applicability here?
• For source statement 2 at 40 CFR 68.215(c) (eCFR anchor p-68.215(c)), which observable configuration, record, or test can confirm applicability here?
• Which owner can attest to the recorded state of critical rooms, power, cooling, water, fire protection, alternate sites, physical barriers, and documented recovery paths, including exceptions?
• What baseline for identity and access control, Windows DNS where networked services use it, time, communications, utilities, life-safety systems, vendors, and authorized responders must accompany the source-specific observation?
• Which success, stop, and escalation criteria are written before testing begins?

DSE recommendation:

DSE recommends using the cited source as the evidence anchor for this decision. Use a two-person review for the source interpretation and the resulting operational decision. Record the source location, examined part of critical rooms, power, cooling, water, fire protection, alternate sites, physical barriers, and documented recovery paths, observed and expected states, owner, and reason for deviation.

Do not move from citation to production in one step. Pilot the decision where practical, observe agreed signals, retain a reversal point, and verify identity and access control, Windows DNS where networked services use it, time, communications, utilities, life-safety systems, vendors, and authorized responders. Handle credentials, keys, recovery data, and personal information through approved secure channels.

Verification and evidence

Keep the source locations 40 CFR 68.215(a)(1), 68.215(a)(2)(i), and 68.215(a)(2)(ii), read with 40 CFR 68.215(a) (eCFR anchors p-68.215(a)(1), p-68.215(a)(2)(i), and p-68.215(a)(2)(ii)); 40 CFR 68.215(c) (eCFR anchor p-68.215(c)) adjacent to the sanitized artifacts used for comparison. Prefer facility inventories, inspection records, alarm and shutdown tests, maintenance history, recovery exercises, and corrective actions, with enough identity and timing data for an independent recheck.

Retain the starting state, authorization, execution record, outcome, deviation, and final state as one review package. Move disruptive checks to an approved test path. Reopen the decision when versions, design, dependencies, ownership, or official guidance changes.

Official references

• 40 CFR 68.215 – Permit content and authority requirements — Environmental Protection Agency via eCFR