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- Program Levels
Displaying 1 - 15 of 35 results
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Can a facility divide a process when assigning program levels?
My process includes a series of interconnected units, as well as several storage vessels that are co-located. Several sections of the process could qualify for Program 1. Can I divide my process into sections for the purpose of assigning Program levels? No, you cannot subdivide a process for this purpose…
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If a stationary source has processes ineligible for Program 1, are all processes ineligible?
If a stationary source has several processes that are covered under 40 CFR Part 68, and some of those processes have had an accidental release within the past five years (effectively making those processes ineligible for Program 1 status), are the individual processes from which no accidents have occurred also…
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If a covered process has an accident, when does it lose eligibility for Program 1 status?
A process covered under 40 CFR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed at 40 CFR §68.10(b). Those criteria include a requirement that the process cannot have had an accidental release of a regulated substance that led to offsite death, injury…
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Applicability of program levels and prevention program requirements for co-located vessels
I have a tank with 1,000,000 pounds of toluene diisocyanate (TDI), which is covered under the RMP rule, but not under OSHA PSM. Considered by itself, the TDI would be Program 2 for EPA. The tank, however, is close to equipment that has chlorine above the applicable threshold and is…
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Changing from a Program 2 or 3 process to a Program 1 process
If five years have passed since the last accident involving a covered process, and that process meets the other two requirements identified under 40 CFR §68.10(b) for Program 1 eligibility, could that process become a Program 1 process even if it had previously been identified as a Program 2 or…
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Is there one document available that includes the latest version of the Renovation, Repair, and Painting (RRP) Rule, with all amendments added to their associated locations, in complete form, and not including the preamble?
Answer: Yes. Visit the RRP Web site at https://www.epa.gov/lead/answers-frequent-questions-about-epas-lead-renovation-repair-and-painting-rrp-rule Question Number: 23002-19407 Find a printable PDF copy of all frequent questions pertaining to lead .
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Will insurance premiums go up for contractors covered by the Renovation, Repair, and Painting (RRP) Rule that work in homes and child-occupied facilities with lead-based paint?
The practice of carrying insurance to cover work in older homes from potential lead poisoning damages is not new. The RRP Rule, because it sets a clear standard of care and allows contractors to demonstrate that they meet that standard by taking appropriate training and using proper work practices, could…
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I am planning to renovate my home. How can I find a lead-safe certified firm?
EPA has a searchable database to help you locate lead-safe certified firms near you at: https://cdxapps.epa.gov/ocspp-oppt-lead/firm-location-search . In addition, you can call EPA's lead hotline at 1-800-424-LEAD (5323) if you have questions. Question Number: 23002-18044 Find a printable PDF copy of all frequent questions pertaining to lead .
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How much will it cost contractors to comply with the RRP Rule?
Answer: In order to comply with the RRP rule, renovators will incur costs for EPA certification and costs to take a training course from an EPA-accredited training provider, as well as for supplies needed in order to carry out the required lead-safe work practices designed to reduce exposure to lead…
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How long will it take EPA to process my application to be a lead-safe certified firm?
EPA is required to process your application to be a lead-safe certified firm within 90 days of receipt. In most instances, properly-completed firm applications are processed in about one month. Question Number: 23002-17543 Find a printable PDF copy of all frequent questions pertaining to lead .
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If there are differences among EPA's, HUD's, and my State's lead-safe work and housing requirements, which ones do I have to comply with?
You must comply with all applicable requirements. The initial 8-hour renovator training course will teach you how to perform lead-safe work practices safely and effectively in compliance with the EPA Lead Renovation, Repair, and Painting (RRP) Rule and the Housing and Urban Development (HUD) Lead Safe Housing Rule. The RRP…
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What records will my firm be required to keep to comply with the Renovation, Repair, and Painting Rule?
The following records must be retained for three years following the completion of a renovation: Reports (if any) certifying that lead-based paint is not present; Records relating to the distribution of the lead pamphlet; and Documentation of compliance with the requirements of the regulation ( EPA has prepared a sample…
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Assigning program level 1 if a public receptors is just beyond distance to endpoint
Our distance to the endpoint for the worst-case release is 0.3 miles. The nearest public receptor is 0.32 miles away. What tools are available to document that the public receptor is beyond the distance to the endpoint so we can qualify for Program 1? The results of any air dispersion…
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Process that meets Program 1 requirements and Program 3 applicability
Program 3 applies to processes in certain NAICS codes as well as any process subject to the OSHA Process Safety Management (PSM) standard, unless the process is eligible for Program 1. If a process meets the requirements of Program 1, but is also in NAICS code 32211 (one of those…
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Can a process qualify for Program 1 if it has had an accident?
A process with more than a threshold quantity of a regulated substance had an accident with off-site consequences three years ago. After the accident, we altered the process to reduce the quantity stored onsite. Now the worst-case release scenario indicates that there are no public receptors within the distance to…
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