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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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Does an ethanol producer who sells undenatured ethanol to a U.S. importer who denatures it at the port need to register with EPA under RFS?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The RFS regulations specify that foreign producers of ethanol for use in transportation fuel, heating oil or jet fuel for import to the US who do not add denaturant to their product, must register under RFS. See 80.1450(b)…
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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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What changes did EPA finalize to the SPCC Rule in December 2006?
The revised rule modifies requirements for facilities with smaller oil storage capacity and specific types of oil-filled operating equipment. If a facility has 10,000 gallons or less in aggregate aboveground oil storage capacity and the facility meets the oil discharge history criteria, then an owner/operator of a facility may prepare…
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SPCC change in ownership
If there is a change in ownership at a facility, can the facility operate under the same SPCC Plan without the certification from a professional engineer (PE)? If no change in procedures has been made, it may still be feasible to operate under the existing SPCC Plan. The information in…
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Liability of oil retailers at SPCC regulated farm
If a farm is out of compliance of Spill Prevention, Control, and Countermeasure (SPCC) regulations and is checked by EPA and/or has a spill, is the retailer that filled the tank liable? No, EPA considers the oil tank owner responsible for lack of compliance.
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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 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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PE certifying a technical amendment
Except as provided in 40 CFR §112.6 for qualified facilities, a Professional Engineer (PE) must certify all technical amendments to an existing SPCC Plan (§112.5(c)). When certifying a technical change to an existing SPCC Plan, does the PE have to inspect and certify the entire Plan or only the amended…
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What are the requirements for a foreign producer who wishes to generate RINs for the renewable fuel they produce?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Foreign producers who plan to generate RINs must register and conduct a third-party engineering review pursuant to section 80.1450. Additionally, such foreign producers must meet the requirements in section 80.1466 prior to generating any RINs for their fuel…
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Is a PE required to review an SPCC Plan if it has not changed?
Under the 2002 regulations, is a PE required to review the SPCC Plans at the end of a 5-year SPCC Plan cycle if no changes have occurred at the facilities? No. It is the responsibility of the owner or operator to document the completion of a review and decide whether…
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PE certifying an SPCC plan in a different state
Except as provided in 40 CFR §112.6 for qualified facilities, a licensed Professional Engineer (PE) must review and certify an SPCC Plan for it to be effective to satisfy the requirements of Part 112 (§112.3(d)). When reviewing and certifying a facility’s SPCC Plan, must the PE be licensed in the…
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How did EPA amend the requirements for animal fats and vegetable oils in 2006?
In December 2006, EPA removed the following SPCC requirements for the following specific types of animal fat and vegetable oil facilities: Requirements for onshore oil production facilities (Section 112.13) Requirements for onshore oil drilling and workover facilities (Section 112.14) Requirements for offshore oil drilling, production, or workover facilities (Section 112.15)…
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