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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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Who is responsible for controlling dust and debris from renovation waste once the waste container or truck used to transport the waste leaves the renovation site?
When a renovation firm transports waste from renovation activities, the firm must contain the waste to prevent release of dust and debris. The Lead Renovation, Repair and Painting (RRP) Rule does not address the responsibilities of other entities. EPA recommends consulting with state and local waste disposal authorities to learn…
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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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For purposes of cleaning the work area following a renovation, is the interior floor of a garage considered interior or exterior space?
In general, the interior floor of a garage is considered an interior space for purposes of post-renovation cleanup. EPA recognizes the fact that it may occasionally be impossible for firms to meet all of the cleaning and verification requirements under the Rule for garage floors such as those that are…
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If a renovator uses the required practices to remove containment and clean a work area, then performs successful cleaning verification, can the project then be done using uncertified workers and without work practices required by the RRP Rule?
Yes, as long as the balance of the project can be completed without disturbing a painted surface. Question Number: 23002-18385 Find a printable PDF copy of all frequent questions pertaining to lead .
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Elements to include in Facility Response Plan
What key elements should I include in my Facility Response Plan? As you prepare your FRP, be sure that your plan includes the following elements: Emergency Response Action Plan (an easily accessible stand-alone section of the overall plan) including the identity of a qualified individual with the authority to implement…
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What are the FRP recordkeeping requirements?
What FRP recordkeeping requirements must I satisfy? You must maintain the response plan at your facility, along with plan updates reflecting material changes. You must also keep a log of response training drills and exercises. Records of inspections of response equipment must be kept for five years. If you determine…
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Under FRP, what is the definition of a qualified individual?
The FRP regulations require facilities to prepare an emergency response action plan and identify a qualified individual that has full authority, including contracting authority, to implement removal actions (40 CFR §112.20(h)(i)). What is the definition of a qualified individual? The relevant statute, CWA 311(j)(5)(C)(ii) requires that the plan identify the…
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My firm is replacing windows on a pre-1978 home. The homeowner already scraped and repainted their house but did not follow lead-safe work practices, leaving paint chips scattered throughout the landscaping. How best should I proceed?
A firm working on a property that is already contaminated with paint chips, dust, debris and residue must proceed by containing the work area for the renovation, and complying with all cleaning requirements under the Lead Renovation, Repair and Painting (RRP) Rule for that work area. Paint chips, dust, debris…
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Under the RRP Rule, do paint chips and debris need to be removed from protective sheeting even if such chips and debris can be effectively contained by the sheeting or the sealed container the sheeting is contained in for disposal?
Yes. After the renovation has been completed, the firm must clean the work area until no dust, debris, or residue remains. The first cleaning step required by the Lead Renovation, Repair, and Painting (RRP) Rule is to collect all paint chips and debris and, without dispersing any of it, seal…
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When renovating the exterior of a high-rise building, does the requirement to close and seal doors and windows within 20 feet of the renovation include closing those openings two-plus floors above the floor where work is to be performed?
Not necessarily. When establishing containment for an exterior renovation on a multi-story building, you must close all doors and windows within 20 feet of the renovation on the same floor as the renovation, and close all doors and windows on all floors below that are the same horizontal distance from…
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When waste from renovations has been removed from the work area and placed in on-site storage, may the waste be stored in a covered waste container or must it all be bagged for disposal?
Properly implemented, either option can meet the requirements of the Lead Renovation, Repair and Painting (RRP) Rule . At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure, or behind…
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FRP Site Plans with Varying Storage Contents
The Facility Response Plan regulations require subject facilities to prepare and maintain a site plan diagram that includes, among other things, the contents of bulk oil storage tanks, drum oil storage areas, and surface impoundments ( 40 CFR Part 112 Appendix F ). When the contents of these storage units…
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SPCC Qualified Facilities Substantial Harm Criteria Certification
Are SPCC qualified facilities required to complete and maintain a copy of the Certification of the Applicability of the Substantial Harm Criteria form located in Appendix C of 40 CFR Part 112? Yes, all SPCC regulated facilities, including qualified facilities, that do not meet the criteria of a substantial harm…
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