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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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Five-year Anniversary Due Date and Time
Pursuant to the risk management program regulations in 40 CFR §68.190, the owner or operator of a stationary source shall revise and update the RMP at least once every five years from the date of initial submission. At what time on the 5-year anniversary date is the RMP due? The…
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Required Contractor Contact Information
A facility that uses a contractor to prepare its RMP must include in the registration section the name, mailing address, and telephone number of the contractor who prepared the RMP (40 CFR §68.160(b)(14)). When a contractor only prepares a portion of an RMP on behalf of a facility, does the…
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If a facility changes owners and significant changes have been made to plant operations is the facility required to update all sections of the RMP and resubmit it to EPA?
Yes. If the facility has new ownership and plant operations have changed significantly, the new facility owner/operator needs to do a resubmission. For details on how to resubmit, see the Web page for RMP*eSubmit .
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RMPs for stationary source with multiple program levels
If a stationary source comprises some covered processes that meet the eligibility requirements for one of the three programs (i.e., Program 1, 2, or 3) and some processes that are subject to a different program, must the owner or operator of the source submit multiple risk management plans (RMPs)? No…
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Certification Statement for Correction
Does the certifying official have to sign a certification statement for a correction to a Risk Management Plan? If so, does that certification apply to the entire RMP or just for the correction being made? Yes, the certifying official must sign a digital certification statement in RMP*eSubmit, and it will…
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