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Underground Storage Tanks in SPCC Plans
If a gas station that has less than 42,000 gallons completely buried oil storage capacity and no aboveground oil storage capacity installs a new aboveground tank with a capacity greater than 1,320 gallons, must the facility’s Spill Prevention, Control, and Countermeasure (SPCC) Plan address the underground storage tanks (USTs) in…
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Container capacity less than 55 gallons
Do facilities need to consider containers that are less than 55 gallons for applicability under 40 CFR Part 112? No. The third column of page 47066 of the July 17, 2002 Preamble states that "You need only count containers of 55 gallons or greater in the calculation of the regulatory…
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Oil-filled equipment capacity
When counting against the 1,320 aboveground storage capacity threshold, would operational storage of oil (such as in a hydraulic press) be used? Oil which is contained in equipment is required to be factored into the storage capacity for the facility even though the oil may be only used for ancillary…
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If your farm does not have fuel storage that will flow into US waters by a ditch, river, stream, or lake, do you have to prepare a SPCC Plan?
No. EPA suggests you use a common sense approach. If one of your oil storage tanks leaks, and the spilled oil would not flow into navigable waters or adjoining shorelines, you do not have to prepare a Plan. Remember that you still have the responsibility to clean up any spilled…
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Ground water pathways related to reasonably expected to discharge
The SPCC Rule applies to facilities that could reasonably be expected to discharge into navigable waters (40 CFR §112.2(a)). Does a facility need to consider ground water pathways when determining if a discharge of oil could reasonably be expected to reach navigable waters? Owners and operators should consider whether on-site…
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SPCC responsibility for tanks on leased property
What if I leased some parcels, and there are tanks already present? Am I responsible for these tanks? You could be. If you plan to use these tanks, make sure in your lease agreement, it states who is responsible for these tanks. If the lease does not state who is…
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How do I contact EPA about lead concerns in my area?
Answer: You may call the National Lead Information Center at 1-800-424-LEAD(5323) or visit our Contact Us about Lead page . You can also report violations online . Question Number: 23002-33312 Find a printable PDF copy of all frequent questions pertaining 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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If a remodeling company that is a certified firm uses all contractual workers rather than employees, must each contractual worker be a certified renovator, or can the workers be trained on the job by a certified renovator employed by the firm?
Firms hiring contractual workers may provide the certified renovator that oversees the renovation project and provides on-the-job training to contractual workers and other non-certified workers. Question Number: 23002-18377 Find a printable PDF copy of all frequent questions pertaining to lead .
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Is the certified renovator assigned to a specific project responsible for the work practices of other contractors on the project if the certified renovator is an employee of the general contractor of the project?
All firms performing renovations must ensure that all individuals performing renovation activities on behalf of the firm are either certified renovators or have been trained by a certified renovator. A firm acting as a general contractor may satisfy this requirement by hiring another certified firm that takes responsibility for ensuring…
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What about a situation where the homeowner is acting as their own general contractor and hires multiple companies to do different portions of the work? In this situation, would each business participating be required to follow the rules and assign a separate certified renovator to supervise their portion of the work including separate containment?
Answer: While the homeowner may be performing the role of general contractor by hiring firms and organizing their work, the homeowner is not performing, offering, or claiming to perform a renovation and therefore does not need to be a certified firm. The firms hired by the homeowner to perform renovation…
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The certified renovator is required to have proof of their certification at the work site. If the certified renovator provides on-the-job training to workers, does there need to be documentation of that training at the work site too?
Answer: No. Certified renovators must have with them at the work site copies of their initial course completion certificate and their most recent refresher course completion certificate. Certified renovators are also responsible for providing training to non-certified workers on the work practices they will be using in performing their assigned…
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What training requirements apply to non-certified workers who have previous EPA/HUD lead-safe work practices training or accredited abatement supervisor or worker training?
The Lead Renovation, Repair, and Painting (RRP) Rule requires certified renovators to provide on-the-job training (OJT) to non-certified workers on the work practices they will be using in performing their assigned tasks. The amount of OJT needed and the topics that need to be covered depend on the knowledge and…
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How do I determine if my farm could reasonably discharge oil into or upon navigable waters or adjoining shorelines?
You can determine this by considering the geography and location of your farm relative to nearby navigable waters (such as streams, creeks and other waterways). You should consider if ditches, gullies, storm sewers or other drainage systems may transport an oil spill to nearby streams. Estimate the volume of oil…
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Mixture with oil as an additive (e.g., oil-based paint)
SPCC applicability thresholds for aboveground and completely buried oil storage capacities are established in 40 CFR §112.1(d)(2). If a facility has a tank that contains a mixture with oil as an additive, such as oil-based paint, should the entire mixture be counted towards a facility’s threshold capacity? Yes; if a…
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