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Does EPA’s announcement of June 18, 2010 modify the Lead Renovation Repair and Painting Rule’s requirements that contractors use lead-safe work practices when working in pre-1978 housing or child-occupied facilities?
Answer: This announcement does not change the requirement that all contractors take steps to protect children and families from the dangers of lead poisoning by becoming certified and following the work practice standards and the associated recordkeeping requirements. As of April 22, 2010 all contractors have been required to be…
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How does the June 18, 2010 announcement impact renovators in states that have adopted their own RRP programs?
Answer: If you work in a state authorized by EPA to run their own renovation program, you should contact them for information on their certification requirements. If you work in a state where EPA administers the renovation program your firm needs to be certified by EPA. Please refer to the…
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Thousands of renovators are already trained and their firms are EPA certified. Will EPA enforce against renovators who did not receive their training certification before December 31, 2010?
It is most important that all contractors follow the RRP work practice standards. However, EPA is providing additional time for renovation firms and workers to obtain the necessary training and certifications before the enforcement of the firm certification and individual renovator requirements begins. Therefore, renovators who have not been able…
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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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Is there any volume cap when using previously-retired 2008 or 2009 biodiesel RINs to satisfy an obligated party?s 2010 Biomass Based Diesel RVO? Can 2008 or 2009 biodiesel RINs that were previously-retired in 2009 also be used to satisfy Advanced Biofuel
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . 2008 and 2009 biodiesel and renewable diesel RINs (that is, RFS1 RINs with a D code of 2 and RR code of 15 or 17) used for compliance purposes in 2009 can also be used to reduce the…
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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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The regulations at 80.1427(a)(7)(iii) say that 2008 biodiesel RINS + 2009 biodiesel RINs cannot exceed 20% of the 2010 RVO. Does this mean that 80% of the 2010 biomass-based diesel RVO has to come from 2010 RINs?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The 20% rollover cap under RFS2 is the same as the rollover cap under the RFS1 program. However, the rollover cap only places a limit on previous year RINs that were NOT used for compliance in 2008 or…
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Does the June 18, 2010, announcement mean that EPA will not enforce certification and training requirements until after October 1, 2010, for firms and December 31, 2010, for renovators?
Answer: EPA is not stopping its enforcement against any renovation firms and individual renovators who do not comply with requirements of work practice standards and associated recordkeeping requirements. However, EPA is providing additional time for renovation firms and workers to obtain the necessary training and certifications before enforcement of 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 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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Under section 80.1405, the standard for biomass based diesel (BBD) is calculated via a fraction, the numerator of which is equal to the RFV for BBD in compliance year i times 1.5. For 2010 only, would you agree that, using the example of the calculation f
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The percentage standard for biomass-based diesel in years 2011 and beyond will be based upon the volumes specified in CAA 211(o)(2)(B)(i)(IV), unless some portion of that volume is waived per CAA 211(o)(7)(E). For 2010, the numerator of the…
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Who would be liable for the fine if a state or local government that was not a certified firm hired a contractor that was not certified?
Answer: The hired firm would be in violation of the Renovation, Repair, and Painting Rule if it was uncertified and performing a covered renovation. Question Number: 23002-24814 Find a printable PDF copy of all frequent questions pertaining to lead .
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Are components removed from the home to be cleaned up and reused subject to the waste handling requirements in the rule?
Answer : While components to be reused rather than disposed of are not considered waste for the purposes of the Lead Renovation, Repair, and Painting (RRP) Rule , it is likely that, even if they do not contain lead-based paint, they are contaminated with dust or debris from the project…
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