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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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How does the Safe Drinking Water Act limit lead in pipes, plumbing fittings, fixtures, faucets, solder and flux?
Answer: Section 1417 of the Safe Drinking Water Act (SDWA) establishes the definition for “lead free” as a weighted average of 0.25% lead calculated across the wetted surfaces of a pipe, pipe fitting, plumbing fitting, and fixture and 0.2% lead for solder and flux. The Act also provides a methodology…
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Is exposure to lead contaminated drinking water from absorption through skin a health threat?
Answer: Human skin does not absorb lead in water. For more information visit our website: https://www.epa.gov/ground-water-and-drinking-water/basic-information-about-lead-drinking-water . Question (23002-32377) Find a printable PDF copy of all frequent questions pertaining to lead .
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Are non-transient, non-community water systems (NTNCWSs) required to monitor for lead and copper?
Answer: All community water systems (CWSs) and NTNCWSs must collect lead and copper tap samples. The frequency of the monitoring and number of samples to be collected and analyzed is based primarily on the number of people served and tap water monitoring results. For an outline of monitoring requirements (e.g…
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Is there anything else I can do beyond flushing my tap or buying bottled water?
Answer: Yes, find “Important Steps You Can Take to Reduce Lead in Drinking Water” if you are concerned about lead in their drinking water. The list is not intended to be exhaustive or to imply that all actions equally reduce lead from drinking water. EPA recommends you also contact your…
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My neighbors got their water tested and found lead. Is my water safe?
Answer: Lead usually gets into drinking water through contact with plumbing materials such as lead pipes or lead solder, or faucets, valves, and fixtures made of brass (brass contains some lead). Since each home has different plumbing pipes and materials, test results are likely to be different for each home…
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Can one still sell lead solder under the Lead Ban?
Answer: Section 1417(a)(3) of the Safe Drinking Water Act (SDWA) prohibits the sale of solder and flux that is not lead-free unless the solder or flux bears a prominent label stating that it is illegal to use the solder or flux in the installation or repair of any plumbing providing…
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Why do water systems add phosphate to drinking water? What are the health effects of drinking water containing phosphates?
Answer: Public water systems (PWSs) commonly add phosphates to drinking water to prevent the release of metals in drinking water. Orthophosphate is most commonly used for lead and copper control. Polyphosphates sequester iron and manganese to prevent discolored water but are not effective to control lead and copper. Blended phosphates…
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Does drilling holes in window frames to install window treatments such as shades and shutters qualify as minor repair and maintenance?
Yes, as long as the installation does not disturb more than six square feet of painted surface per room within a 30-day period. Question Number: 23002-15404 Find a printable PDF copy of all frequent questions pertaining to lead .
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If a renovator disrupts 20 square feet or less of painted surface per side on several sides of the exterior of one property, does the RRP Rule apply?
Yes. To qualify for the exception for minor repair and maintenance activities, the total amount of exterior paint disrupted must be 20 square feet or less. In addition, the job must not use prohibited practices or involve window replacement or demolition of painted surfaces. Question Number: 23002-18379 Find a printable…
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If I use a hammer to make a hole is a wall that is two feet on each side, does the RRP Rule apply?
Yes. Although making the hole disrupts less than six square feet of painted surface, using a hammer to make the hole is demolition of the surface, so the minor repair and maintenance exception does not apply. Making the hole using a cut-out technique that does not destroy the section of…
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