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- 112.6 Qualified Facilities
Displaying 1 - 15 of 24 results
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Visit and examination requirements for SPCC self-certification
Pursuant to 40 CFR §112.6, the owner or operator of a facility that meets the criteria in §112.3(g) for either a Tier I or Tier II qualified facility may self-certify the facility's SPCC Plan. As part of the self-certification, the owner or operator must certify that he or she has…
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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 certified renovator is an employee of the certified firm, can the firm maintain all required records (those required of the firm and of the certified renovator); understanding that the certified renovator must also keep a copy of his certification as well as employee training records/documentation on the jobsite?
Answer: The renovation firm is the entity responsible for retaining and making available to EPA all records necessary to demonstrate compliance with the RRP Rule for a period of three years following completion of the renovation. The certified renovator is responsible for preparing the records demonstrating that the renovation was…
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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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Availability of electronic SPCC Plan template
Part 112, Appendix G to prepare an SPCC Plan. Is the Tier I qualified facility SPCC Plan template available in an electronic version? EPA has made available electronic versions of the Tier I qualified facility Plan template to help the owner or operator of a Tier I qualified facility develop…
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Under the RRP Rule, can the required records and documentation be stored electronically rather than as paper copies?
Answer: Yes. The renovation firm is responsible for retaining and making available to EPA all records necessary to demonstrate compliance with the Lead Renovation, Repair, and Painting (RRP) Rule for a period of three years following completion of the renovation. The RRP Rule does not specify the format in which…
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My firm installs carpets. Sometimes there is no need to remove an existing carpet before installing the new carpet, but sometimes there is. How do I know when I need to comply with the Lead Renovation, Repair and Painting (RRP) Rule?
If when installing the carpet, you disrupt six square feet or less of painted surface per room, the job is not covered by the RRP Rule . Question Number: 23002-19749 Find a printable PDF copy of all frequent questions pertaining to lead .
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Please provide guidance on how the Agency will interpret the term “minor repair and maintenance activities.”
Answer: “Minor repair and maintenance” is defined in 40 CFR 745.83 as activities that disrupt less than 6 square feet or less of painted surface per room for interior activities or 20 square feet or less of painted surface for exterior activities where none of the work practices prohibited or…
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Does the minor maintenance exception mean that if I drill one-inch holes in a painted surface to blow insulation into an enclosed wall cavity, I could drill 864 holes in the interior or 2880 holes on the exterior before I had to comply with the RRP Rule?
The exception is based on the area of paint disrupted, which in this example is based on the combined areas of the holes drilled in the wall. Question Number: 23002-15677 Find a printable PDF copy of all frequent questions pertaining to lead . Other Frequent Questions about the RRP Program…
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In a multi-family building, does the standard for interiors of six square feet or less, or the standard for exteriors of 20 square feet or less of disrupted painted surface apply to the whole building or can it be applied to each separate unit?
For interiors, the exception for work that disrupts six square feet or less of painted surface applies to each individual room and is inclusive of all work done in the room in any 30-day period. For exteriors, to qualify for the exception for minor repair and maintenance activities, the total…
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Under the RRP Rule, can the certified renovator comply with the rules by keeping records regarding his certification and employee training electronically, provided he can display them on a hand held device or laptop on the job site?
Yes. The Lead Renovation, Repair, and Painting (RRP) Rule does not specify the format in which these documents must be kept, but they must be available at the work site. Documents are not available if they cannot be viewed. Certified renovators must have with them at the work site copies…
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If a general contractor and one or more subcontractors are involved in a single renovation project, which persons or entities are responsible for preparing, retaining and making available the necessary records?
Answer: The certified renovator, whether assigned by a general contractor or subcontractor, is responsible for preparing the records demonstrating that the renovation was conducted in compliance with the work practice standards, including training provided to non-certified workers. All renovation firms involved in a project share the responsibility for retaining and…
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Is replacing a pane of glass or fixing a broken window balancer a renovation covered by the RRP Rule?
It depends. Replacing a pane of glass or fixing a broken window balancer can disturb paint. If the job disrupts more than six square feet of painted surface per room, the job is not considered minor repair and maintenance and it is covered by the RRP Rule. When removing a…
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