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Obtaining an RMP ID Number
How can a facility subject to the Risk Management Plan (RMP) requirements obtain its RMP ID number? The owner or operator of a regulated RMP facility that has already submitted an RMP, may obtain the facility's identification number (RMP ID Number) by contacting the RMP Reporting Center (703-227-7650). An RMP-covered…
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Does EPA have enforcement authority for the risk management program regulations?
Yes. Under §113 of the CAA, the Agency has the authority to bring administrative and judicial actions against violators. Judicial actions can be civil and criminal in nature. Section 113(a)(3) authorizes the Agency to order violators to comply with the risk management program regulations. Under section 113(b), the Agency may…
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Criteria for selecting stationary sources to audit
What criteria will be used to select stationary sources for periodic compliance audits of risk management plans (RMPs) submitted under 40 CFR Part 68, Subpart G? The implementing agency will, according to the regulations at 40 CFR §68.220(b), select stationary sources for audits based on any of the following criteria…
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Is there a citizen suit provision applicable to RMP?
Is there a citizen suit provision applicable to CAA §112 and the risk management program rule? Yes, section 304 of the CAA includes a citizen suit provision for violations of emission standards or limitations promulgated under the Act.
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Accessing RMP Data
Is Risk Management Plan (RMP) data available to the public and, if so, where can it be found? Risk Management Plans (RMPs) prepared and submitted pursuant to CAA section 112(r) are, by statute, available to the public. Members of the general public may obtain RMP data by visiting a designated…
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How may state and local rules be more stringent?
In what ways may state and local rules be more stringent? Does this document ( General Risk Management Program Guidance ) provide guidance on state and local differences? States and localities may impose more detailed requirements, such as requiring more documentation or more frequent reporting, specifying hours of training or…
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How often does a facility need to complete an oil spill response training under the FRP requirements?
Facilities subject to the Facility Response Plan (FRP) regulations in 40 CFR Part 112, Subpart D are required to develop a facility response training program to train those personnel involved in oil spill response activities (§112.21(b)). How often does a facility need to complete an oil spill response training under…
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What is a significant and substantial harm facility?
Some substantial harm facilities may meet the criteria for a significant and substantial harm facility. After you have prepared and submitted your FRP, the RA may determine that your facility has the potential, not just for substantial harm, but for significant and substantial harm. If the RA makes that determination…
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Statutory authority and regulatory source for the risk management program
What is the statutory authority and the regulatory source for the risk management program regulations that are codified in 40 CFR Part 68? The risk management program regulations were promulgated pursuant to the §112(r) accidental release prevention provisions of the Clean Air Act, as amended in 1990. The regulatory sources…
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RMP Information Center
If I have additional questions regarding the RMP regulations, who can I contact via telephone for further assistance? You may contact the EPCRA, RMP & Oil Information Center, a publicly accessible service that provides up-to-date information on the regulatory requirements of the RMP program, including the applicability, program levels, off-site…
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PE certification for an FRP if an SPCC impracticability determination is made
If the owner or operator of a facility subject to the SPCC regulations determines that the installation of any of the specified secondary containment structures or equipment is not practicable and accordingly provides in the facility’s SPCC Plan an oil spill contingency plan following the provisions of 40 CFR Part…
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If a company has several legal entities, does each entity have to become a certified firm?
Answer: Yes, if the corporate structure is such that the parent company is not liable for actions of the separate legal entities. Question Number: 23002-18225 Find a printable PDF copy of all frequent questions pertaining to lead .
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My non-profit organization applies for and receives grants to renovate older homes. We do not perform the renovations ourselves, we hire renovation contractors to perform them on our behalf. Must my non-profit organization become an RRP-certified firm?
Answer: Yes, even though your organization's employees do not actually perform the renovation activities, your organization must be an RRP-certified renovation firm because your organization, through the grant process, is offering to perform renovations for compensation, i.e., the grant. Question Number: 23002-19775 Find a printable PDF copy of all frequent…
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I am a facilities manager for a church with daycare and preschool programs. I recently became a certified renovator. If my staff and I do our own painting and remodeling work, do we need to be a certified firm?
Answer: Yes, if you perform, offer, or claim to perform renovations in a portion of the building that is a child-occupied facility. The RRP Rule defines a child-occupied facility as a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, under 6 years…
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If the demolition, cleanup, and cleaning verification portion of a renovation project is performed under the direction of a certified renovator using trained workers, can uncertified workers complete the job if further disturbance of paint will not occur?
If the demolition, cleanup, and cleaning verification portion of a renovation project is performed under the direction of a certified renovator using trained workers, can uncertified workers complete the job if further disturbances of painted surfaces will not occur? For example, a certified firm establishes containment and removes wall and…
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