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Displaying 1 - 15 of 57 results
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CFAT Impacts on EPCRA and RMP
The Department of Homeland Security’s Chemical Facility Anti-Terrorism Standards (CFATS) impose comprehensive federal security regulations for high-risk chemical facilities. Do the CFATS alter the requirements that apply to a facility covered under both CFATS and either the Emergency Planning and Community Right-to-Know Act (EPCRA) or the Clean Air Act section…
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EPCRA Reporting Mechanisms for Protecting Sensitive Business Information
Does EPCRA provide any mechanisms for facilities that must submit Tier II inventory information to protect sensitive business information? Trade secret and confidential location information (CLI) are two separate confidentiality provisions under EPCRA. Trade secret claims made under EPCRA Sections 303, 311, 312, or 313 allow facilities to claim the…
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Are renovations performed on detached garages, sheds and other detached outbuildings on the property subject to the RRP Rule?
Yes. EPA interprets target housing to include pre-1978 buildings or structures that are (1) located on the residential portion of the property, and (2) associated with the residential use of the property. As a practical matter, the entire property of most urban and suburban residential lots is normally considered to…
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How do the RRP requirements apply to renovations on a pre-1978 building that contains both multi-room apartments (i.e., target housing) and zero-bedroom dwellings?
In pre-1978 buildings that contain a mix of target housing and zero-bedroom dwellings, the Lead Renovation, Repair, and Painting (RRP) Rule applies only to renovations performed in target housing and common areas. Common areas are those portions of a property generally accessible to residents/users of target housing, and can exist…
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Does zoning affect the target housing determination? For example, would a pre-1978 house that is zoned for commercial or office use, but used for residential purposes be considered target housing?
In determining whether a pre-1978 property is target housing, it is the actual or intended use of the property that matters, not its zoning classification. Therefore, a pre-1978 house that is used or intended to be used as a residence, even if only temporary, is target housing regardless of its…
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When testing a work area, does one lead test kit or paint chip sample suffice for any single component?
The certified renovator is only required to use one lead test kit or paint chip sample for each component, even if the surface of the component is extensive (e.g., a large wall). Question Number: 23002-23865 Find a printable PDF copy of all frequent questions pertaining to lead .
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Can a homeowner use an EPA-recognized lead test kit to check for lead-based paint?
Answer: A number of lead test kits are available for consumer purchase in most retail hardware stores; however, the Consumer Product Safety Commission (CPSC) states that consumers should exercise caution when using these lead test kits to evaluate consumer products for potential lead exposures. Find more information online . To…
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How can I obtain D-Lead® test kits?
The D-Lead® test kits are available for purchase from certain distributors and retail outlets. Locate a distributor or retailer online , email [email protected] or call 414-962-3006. Question Number: 23002-16390 Find a printable PDF copy of all frequent questions pertaining to lead .
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Is lead paint testing required under the Lead Renovation, Repair and Painting (RRP) Rule?
No. A firm can either assume lead-based paint is present and follow the requirements of the RRP Rule (which requires no testing), or test and if lead-based paint is found follow the requirements of the regulation. Question Number: 23002-32338 Find a printable PDF copy of all frequent questions pertaining to…
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Are landfills covered under Title III of SARA since they are covered by RCRA?
Yes, landfills are subject to certain Title III requirements. Subtitle A of Title III is intended to identify facilities which present a potential hazard for a chemical emergency and to provide a process for local emergency planning committees to engage with such facilities in determining the significance of the release…
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Are mobile boosters eligible for the transportation exemption?
An oil company owns many wells on an oil field. Each well is on its own plot of land. These plots are not adjacent or contiguous and, therefore, each well is its own facility. When operating these wells, it is sometimes necessary to inject air or gas into the well…
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Pipeline tanks and the transportation exemption in Title III
An oil corporation's pipeline facility contains three kinds of tanks. One type is a breakout tank used to receive and store hazardous liquids transported by a pipeline for reinjection and continued transportation by the corporation's pipeline. Another type is used to receive and store hazardous liquid for delivery to pipelines…
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How would the Lead Renovation, Repair and Painting (RRP) Rule classify a pre-1978 property that is used for both residential and non-residential purposes?
EPA has interpreted target housing to include pre-1978 buildings or structures that are (1) located on the residential portion of the property, and (2) associated with the residential use of the property. In other words, if a portion of residential property is used for nonresidential purposes, the portion will nonetheless…
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If a renovation is taking place in a home built in 1950, but in an addition that was built in 1980, does the Lead Renovation, Repair and Painting (RRP) Rule apply to the renovation?
Yes. The RRP Rule applies to a renovation in target housing unless it has been determined that the components affected by the renovation are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight…
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Older hotels built before 1978 are knocking down walls, combining two hotel rooms, and making their units two-room or even three-room suites. Does the RRP Rule apply when one-room units are converted to two-room suites?
Yes. A renovation performed for the purpose of converting a building, or part of a building, into target housing or a child-occupied facility is a renovation for purposes of the RRP Rule. Hotel suites that provide a sleeping area that is separate from the living area are covered by the…
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