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Would an underground salt dome be subject to the Risk Management Program in Louisiana if it held above the Threshold Quantity of a substance regulated under 40 CFR, Part 68?

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Would an underground salt dome be subject to the Risk Management Program in Louisiana if it held above the Threshold Quantity of a substance regulated under 40 CFR, Part 68?

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A1: Underground storage caverns (salt domes) can be subject to RMP if they have a regulated chemical above its threshold quantity and the storage cavern is not considered “exempt transportation”. Exempt transportation includes storage fields for natural gas where gas taken from pipelines is stored during non-peak periods, to be returned to the pipelines when needed. Natural gas does not include natural gas liquids that have been extracted from natural gas. Transportation activities subject to regulation or oversight under 49 CFR parts 192, 193, or 195 are exempted from RMP. The definition of Stationary Source states that “storage incident to transportation” is considered exempt transportation. In order for an underground storage cavern to be considered “storage incident to transportation”, the cavern must be connected directly to a pipeline regulated by 49 CFR parts 192 or 195 which transports the chemical into the storage cavern and is connected directly to a pipeline regulated by 49

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