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Change of owner and RMP facility ID number
If a facility is sold to a new owner, does it keep its' original RMP Facility ID number? Yes. The facility will keep the ID number assigned by EPA.
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Facility ID number and re-registering a facility
If a facility deregisters, then reregisters, should the facility use the original RMP Facility ID or will it be assigned a new ID? The facility should use the original ID assigned by EPA.
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Resubmission of RMP for a facility that previously deregistered
A covered facility deregisters its RMP because it no longer has more than a threshold quantity of a regulated substance in a covered process. If the facility becomes subject to the CAA §112(r) risk management program regulations at a later date and submits a new RMP, should the facility submit…
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RMP Records Maintained Onsite
Pursuant to 40 CFR Part 68, Subpart G, the owner or operator of a stationary source subject to the risk management program regulations in Part 68 must develop and submit a risk management plan (RMP). Does the owner or operator have to maintain a written copy of the RMP on…
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Change of Ownership
If a facility that is subject to the risk management program regulations in 40 CFR Part 68 is sold to another owner, is the facility required to make a correction or a full update of its risk management plan (RMP)? If there are no changes in the covered operations at…
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RMP*eSubmit preparer access
How does a new Preparer get access to a Risk Management Plan (RMP) via RMP*eSubmit? First, the person must register with CDX. To register with CDX, go to https://cdx.epa.gov/ and complete the registration process for a Risk Management Plan “Preparer”. Once set up as a “Preparer”, the Certifying Official needs…
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May I use the pamphlet “Protect Your Family From Lead in Your Home” to meet my obligations for pre-renovation education under the RRP Rule?
Answer: No. As of December 22, 2008, only the pamphlet “ Renovate Right ” may be used to comply with the pre-renovation education requirements of the RRP Rule. “ Protect Your Family ” is still available for use during real-estate sales and lease transactions and for general information. Question Number…
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My firm is replacing windows in a condominium. Is this type of exterior work considered work in a common area, and if so, must other owners and occupants be informed about the job?
Exterior renovations of multi-unit target housing are considered renovations of a common area. A common area is a portion of a building that is generally accessible to all residents or users of the building. Renovations in common areas of multi-unit target housing, such as condominiums, must be performed in accordance…
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Under the Pre-Renovation Education Rule, I have the option of using a certificate of mailing to notify the owner or occupant. What is the difference between a certificate of mailing and certified mail?
A certificate of mailing is a receipt showing evidence of mailing, while certified mail provides proof of mailing and delivery of mail. When using the certificate of mailing option, no record is kept at the mailing office and a receipt is not obtained when mail is delivered to the addressee…
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When multiple contractors are involved in a single renovation, must every contractor provide pre-renovation education? Can a certified firm assign its responsibility to a property management company?
All firms performing, offering or claiming to perform renovations are responsible for ensuring compliance with the pre-renovation education requirements of the RRP Rule. However, it is unnecessary for the same notifications and information to be given out repeatedly during a single renovation. Accordingly, a firm may discharge the task by…
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Five-year Anniversary Due Date and Time
Pursuant to the risk management program regulations in 40 CFR §68.190, the owner or operator of a stationary source shall revise and update the RMP at least once every five years from the date of initial submission. At what time on the 5-year anniversary date is the RMP due? The…
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Required Contractor Contact Information
A facility that uses a contractor to prepare its RMP must include in the registration section the name, mailing address, and telephone number of the contractor who prepared the RMP (40 CFR §68.160(b)(14)). When a contractor only prepares a portion of an RMP on behalf of a facility, does the…
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If a facility changes owners and significant changes have been made to plant operations is the facility required to update all sections of the RMP and resubmit it to EPA?
Yes. If the facility has new ownership and plant operations have changed significantly, the new facility owner/operator needs to do a resubmission. For details on how to resubmit, see the Web page for RMP*eSubmit .
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RMPs for stationary source with multiple program levels
If a stationary source comprises some covered processes that meet the eligibility requirements for one of the three programs (i.e., Program 1, 2, or 3) and some processes that are subject to a different program, must the owner or operator of the source submit multiple risk management plans (RMPs)? No…
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Certification Statement for Correction
Does the certifying official have to sign a certification statement for a correction to a Risk Management Plan? If so, does that certification apply to the entire RMP or just for the correction being made? Yes, the certifying official must sign a digital certification statement in RMP*eSubmit, and it will…
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