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How often does a facility need to complete an oil spill response training under the FRP requirements?
Facilities subject to the Facility Response Plan (FRP) regulations in 40 CFR Part 112, Subpart D are required to develop a facility response training program to train those personnel involved in oil spill response activities (§112.21(b)). How often does a facility need to complete an oil spill response training under…
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What is a significant and substantial harm facility?
Some substantial harm facilities may meet the criteria for a significant and substantial harm facility. After you have prepared and submitted your FRP, the RA may determine that your facility has the potential, not just for substantial harm, but for significant and substantial harm. If the RA makes that determination…
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What is a renovation?
The Lead Renovation, Repair, and Painting (RRP) Rule covers activities that modify an existing structure and that result in the disturbance of painted surfaces. All types of repair, remodeling, maintenance, modernization, and weatherization projects are covered, including projects performed as part of another Federal, State, or local program, if the…
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When installing a roof, my firm does not create dust by directly sanding or cutting painted surfaces, but we do hammer the unpainted side of the lumber from above. Does the RRP Rule apply to this work?
The Lead Renovation, Repair, and Painting (RRP) Rule applies to work that disturbs painted surfaces. If hammering painted components, even on the unpainted side, disturbs paint, creating dust or chips, the RRP Rule applies. Question Number: 23002-23787 Find a printable PDF copy of all frequent questions pertaining to lead .
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PE certification for an FRP if an SPCC impracticability determination is made
If the owner or operator of a facility subject to the SPCC regulations determines that the installation of any of the specified secondary containment structures or equipment is not practicable and accordingly provides in the facility’s SPCC Plan an oil spill contingency plan following the provisions of 40 CFR Part…
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Are renovations that disturb stucco subject to the RRP Rule? Does it matter whether the stucco has been painted?
Answer: The Lead Renovation, Repair, and Painting (RRP) Rule applies to work that disturbs painted surfaces. Therefore, renovations that disturb stucco are subject to the RRP Rule only if the stucco has been painted. Question Number: 23002-14025 Find a printable PDF copy of all frequent questions pertaining to lead .
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Are Department of Energy weatherization projects covered under the RRP Rule?
Answer : The Lead Renovation, Repair, and Painting (RRP) Rule defines “renovation” to include weatherization projects such as cutting holes in painted surfaces to install blown-in insulation or to gain access to attics, and planing thresholds to install weather stripping. Other types of weatherization projects, such as window replacement, are…
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If I am painting a wall on which there are multiple coats of latex paint over the old lead-based paint and the paint is not peeling down to the lead paint level must I comply with the new Renovation, Repair, and Painting (RRP) regulations?
Yes, if the painted surface of the wall will be disturbed by the renovation. Question Number: 23002-18485 Find a printable PDF copy of all frequent questions pertaining to lead .
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If a homeowner removes all the painted surfaces in a room and then hires a certified firm to remodel the room, does the renovator need to follow the RRP Rule?
No. Projects that do not disturb a painted surface are not subject to the RRP Rule. Question Number: 23002-18301 Find a printable PDF copy of all frequent questions pertaining to lead .
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Elements to include in Facility Response Plan
What key elements should I include in my Facility Response Plan? As you prepare your FRP, be sure that your plan includes the following elements: Emergency Response Action Plan (an easily accessible stand-alone section of the overall plan) including the identity of a qualified individual with the authority to implement…
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What are the FRP recordkeeping requirements?
What FRP recordkeeping requirements must I satisfy? You must maintain the response plan at your facility, along with plan updates reflecting material changes. You must also keep a log of response training drills and exercises. Records of inspections of response equipment must be kept for five years. If you determine…
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Under FRP, what is the definition of a qualified individual?
The FRP regulations require facilities to prepare an emergency response action plan and identify a qualified individual that has full authority, including contracting authority, to implement removal actions (40 CFR §112.20(h)(i)). What is the definition of a qualified individual? The relevant statute, CWA 311(j)(5)(C)(ii) requires that the plan identify the…
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What RRP requirements apply to a comprehensive renovation project involving the removal and replacement of all interior painted surfaces from target housing or a child-occupied facility?
A project that involves the removal and replacement of all interior painted surfaces but leaves all exterior painted surfaces intact is considered a renovation for RRP purposes. Therefore, all requirements of the RRP Rule apply including, but not limited to, those for firm and renovator certification, containment, waste disposal, cleaning…
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Does the RRP Rule apply to demolishing and disposing of the following types of structures?
Question: Does the RRP Rule apply to demolishing and disposing of: An entire pre-1978 home or building? An entire, non-attached free-standing structure on the same property such as a garage, shed, or gazebo? An attached but segregated section of pre-1978 home or building such as a sunroom, addition, two-story porch…
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Does the RRP Rule apply where no paint at all is present, such as in a 100 year old unfinished basement?
No. The RRP Rule applies to activities that result in the disturbance of painted surfaces. Where there is no paint to disturb, the RRP Rule does not apply. Question Number: 23002-15691 Find a printable PDF copy of all frequent questions pertaining to lead .
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