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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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What is the definition of “overburdened community” that is relevant for EPA Actions and Promising Practices?
EPA Actions and Promising Practices apply the description of overburdened communities articulated in EPA’s Plan EJ 2014. The term is used to describe the minority, low‐income, tribal and indigenous populations or communities in the United States that potentially experience disproportionate environmental harms and risks due to exposures or cumulative impacts…
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How will an EPA regional office determine whether a permitted activity impacts a potential overburdened community? What screening tool or process will EPA regional offices use to screen permit applications?
The Agency has developed a nationally consistent screening tool to help identify communities that are potentially overburdened. This tool, known as EJSCREEN, is one of several tools being developed under Plan EJ 2014. EPA anticipates that its regional offices will use EJSCREEN and other readily available information, including known community…
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Some of the Promising Practices are mentioned in EPA regulations, guidance and recommendations that EPA has issued in the past. So why is EPA issuing the Promising Practices?
EPA is issuing Promising Practices to encourage permit applicants to strategically plan and conduct enhanced outreach to overburdened communities in the permitting process. As some commenters noted, EPA has recommended some of the outreach strategies included in Promising Practices previously. Nevertheless, EPA believes that it is important to issue Promising…
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A home sustained flooding as a result of a hurricane. Once the flood water recedes, my firm must make the necessary renovations. How do the record keeping requirements apply to an emergency renovation?
Emergency renovations (other than interim controls performed in response to a child with an elevated blood lead level) are exempt from the training, certification, sign posting, waste handling and containment requirements of the Lead Renovation, Repair and Painting (RRP) Rule only to the extent necessary to respond to the emergency…
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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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Can renovator training courses, both initial and refresher courses, be taught online or via distance learning?
Answer: The final Renovation, Repair and Painting regulation, like the abatement program, permits the use of alternative training techniques (e.g., video training, computer-based training) as a supplement to the hands-on skills assessment, or as a substitute for the lecture portion of the training course requirements outlined in § 745.225. In…
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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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