Stationary sources subject to the Program 3 Prevention Program requirements in 40 CFR Part 68, Subpart D, must include in their Risk Management Plan the date of the most recent review or revision of hot work permit procedures in Section 7.13. What date should the owner or operator enter in Section 7.13 if the stationary source does not perform hot work on or around a Program 3 process?
The owner or operator should enter the date that he or she ensured that the new process (or an existing process moving up to Program 3) complied with the hot work permit requirements. It would not matter whether or not the stationary source had actually done any hot work. The management system for controlling hot work not only includes the hot work permit, it would also typically be included among the safe work practices identified in §68.69(d) as required for Program 3. Safe work practices, such as hot work permit procedures, are developed well in advance of the work requiring those procedures actually being performed. For example, for any operational or maintenance procedures that might require hot work, the owner or operator would need to ensure that the procedure requires the user to perform hot work in accordance with the stationary source’s hot work permit permitting system.