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Introduction to CERCLA 103, EPCRA, and RMP.pdf

Introduction to CERCLA 103, EPCRA, and RMP.pdf

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Management of Change Procedures<br />

• A change is a modification <strong>to</strong><br />

o<br />

o<br />

o<br />

Process equipment or instrumentation<br />

Technology, procedures, raw<br />

materials, or<br />

Processing conditions<br />

• A change is NOT “Replacement in<br />

kind” which means a replacement<br />

that “satisfies the design<br />

specifications”<br />

80

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