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Secondary containment for oil-filled operation equipment under SPCC
On December 26, 2006, EPA provided an optional alternative to the general secondary containment requirements in 40 CFR §112.7(c) for qualified oil-filled operational equipment ( 71 FR 77266 ). Because the alternative is optional, an owner or operator could choose to comply with the existing SPCC requirements to provide general…
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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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When testing a work area, does one lead test kit or paint chip sample suffice for any single component?
The certified renovator is only required to use one lead test kit or paint chip sample for each component, even if the surface of the component is extensive (e.g., a large wall). Question Number: 23002-23865 Find a printable PDF copy of all frequent questions pertaining to lead .
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Can a homeowner use an EPA-recognized lead test kit to check for lead-based paint?
Answer: A number of lead test kits are available for consumer purchase in most retail hardware stores; however, the Consumer Product Safety Commission (CPSC) states that consumers should exercise caution when using these lead test kits to evaluate consumer products for potential lead exposures. Find more information online . To…
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How can I obtain D-Lead® test kits?
The D-Lead® test kits are available for purchase from certain distributors and retail outlets. Locate a distributor or retailer online , email [email protected] or call 414-962-3006. Question Number: 23002-16390 Find a printable PDF copy of all frequent questions pertaining to lead .
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Is lead paint testing required under the Lead Renovation, Repair and Painting (RRP) Rule?
No. A firm can either assume lead-based paint is present and follow the requirements of the RRP Rule (which requires no testing), or test and if lead-based paint is found follow the requirements of the regulation. Question Number: 23002-32338 Find a printable PDF copy of all frequent questions pertaining to…
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SPCC requirements for transfer areas associated with exempt USTs
Gas stations typically are not subject to the SPCC Rule because completely buried storage tanks subject to 40 CFR Part 280 or 281 are exempt per §112.1(d)(4). However, a gas station would be subject to the SPCC Rule if it has more than 1,320 gallons of oil in aggregate above…
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Do the changes in the 2006 Amendments apply to oil-filled manufacturing equipment?
No. The amendment does not change any requirements for oil-filled manufacturing equipment. Oil-filled manufacturing equipment remains subject to the SPCC requirements (including those for containment), but an owner/operator may determine that secondary containment is impracticable and comply with the alternative measures in section 112.7(d).
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What is an oil spill contingency plan?
Instead of providing secondary containment for qualified oil-filled operational equipment, an owner or operator may prepare an oil spill contingency plan and a written commitment of manpower, equipment, and materials to quickly control and remove discharged oil. He/she must also have an inspection or monitoring program for the equipment to…
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Secondary containment requirements for mobile refuelers
What secondary containment requirements apply to mobile refuelers? General secondary containment requirements in §112.7(c) still apply to mobile refuelers at SPCC regulated facilities. General secondary containment should be designed to address the most likely discharge from the container and from oil transfers into or from the mobile refueler. The general…
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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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What lead test kits are recognized by EPA?
Answer: EPA recognizes three lead test kits for use in complying with the negative response criterion of the RRP rule. They are the Luxfer Magtech LeadCheck TM kit (for use on ferrous metal, plaster, drywall and wood), the State of Massachusetts kit (for use on drywall, plaster), and the D-Lead®…
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