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Please clarify whether oxygenates blended into either conventional gasoline or Reformulated Blendstock for Oxygenate Blending (RBOB) downstream of the refinery need to be included in sulfur compliance calculations.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.205(c) provides that a refiner or importer may include oxygenates added downstream from the refinery or import facility if the requirements under § 80.69(a) or § 80.101(d)(4)(ii) of the RFG/CG regulations are met. Therefore, a refiner or…
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A home sustained flooding as a result of a hurricane. Once the flood water recedes, my firm must make the necessary renovations. How do the record keeping requirements apply to an emergency renovation?
Emergency renovations (other than interim controls performed in response to a child with an elevated blood lead level) are exempt from the training, certification, sign posting, waste handling and containment requirements of the Lead Renovation, Repair and Painting (RRP) Rule only to the extent necessary to respond to the emergency…
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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 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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In the NPRM, the sulfur standards were expressed without decimal places, but the final rule provides that the standards are expressed with two decimal places (§§ 80.195, 205). Why did EPA include this change?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA included the decimal places to ensure that the sulfur standards are not exceeded by rounding down actual average sulfur levels. We do not believe reporting the average sulfur level to two decimals creates any additional burden as…
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It is our understanding that, if a portion of the gasoline produced by a refinery located within the GPA is sold outside of the United States, that gasoline is not subject to the sulfur standards and it only has to meet the standards of the country to whi
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Gasoline that is exported for sale outside the United States is not subject to the requirements of the gasoline sulfur rule, including gasoline produced by a refiner located within the GPA. See § 80.200(c).
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Does the RRP rule apply to contractors working on homes damaged by a hurricane or other natural disaster?
Damage from a major storm or other natural disaster could result in the need for emergency renovations. Certain requirements of the RRP Rule do not apply to emergency renovations, which are renovation activities that were not planned but result from a sudden, unexpected event that, if not immediately attended to…
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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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6. Is commingling of different types of ethanol permitted? If so, what systems must be employed?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . With one exception, the RFS program places no restrictions on the mixing of ethanol produced in different facilities, by different feedstocks, or through different processes. Also, RINs assigned to ethanol are fungible, in that a specific assigned RIN…
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If a facility is grandfathered, is it also exempt from the requirement that feedstocks must be renewable biomass?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Even if a facility is exempt from the 20% GHG reduction requirement, in order to generate RINs, the facility is still required to use feedstocks that meet the definition of renewable biomass. The definition of renewable fuel in…
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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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