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What questions was EPA trying to find answers to during its first round of sampling at the Norwood Landfill site?
The main question that EPA seeks to answer is whether the identified waste areas warrant consideration for placement of the Site on the National Priorities List (NPL) or Superfund List. In the first round of sampling, EPA collected surface soil samples (0-2 feet) from the landfill property, and surface water…
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What does it mean when EPA finds contamination that “exceeds screening levels?”
Screening levels are not the same as cleanup or action levels. An exceedance of a screening level indicates the need for additional evaluation, potentially including a site-specific risk assessment.
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If EPA finds any contamination associated with the Norwood Landfill site that “exceeds” what is considered safe, will EPA clean up that contamination - even if the Agency cannot find any “pathways” for that contamination to reach humans or sensitive environments?
If the sampling data shows an exceedance of a screening level, EPA will consult with the site Toxicologist and the Agency for Toxic Substances and Disease Registry (ATSDR) to conduct a human health risk screening assessment to determine any potential threat to human health. EPA will also consult with the…
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How do you know you are not missing some areas that might be contaminated?
EPA uses all credible information available, including community input, regarding the boundaries and geographic areas of waste that may have been deposited or where contaminated soil may have been placed. The team selects its sampling locations based on those areas and consults historic aerial images that help depict those boundaries.
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Will EPA sample the Glenolden Laboratory property?
The former Glenolden Laboratory property located on South Avenue is a separate site. The previous owners conducted a voluntary cleanup pursuant to the Pennsylvania Department of Environmental Protection’s (PADEP) Environmental Cleanup Program, known as Act 2. Concerns regarding remedial actions conducted under Act 2 should be directed to PADEP as…
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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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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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When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity?
When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity? Do I calculate the amount of painted surface disrupted using the standard for interior renovations (six square feet or…
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