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Displaying 1 - 15 of 26 results
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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 the Renovation, Repair, and Painting (RRP) Rule apply to renovations done in an apartment between tenants? Does it matter if children live in other apartments in the building?
Answer: Temporarily unoccupied or vacant rental housing is not exempt from the requirements of the RRP Rule. Question Number: 23002-15669 Find a printable PDF copy of all frequent questions pertaining to lead .
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My firm is performing a renovation in an unoccupied home that will be put up for sale when work is done. Does the RRP Rule apply to this renovation?
Yes. Temporarily unoccupied or vacant housing is not exempt from the requirements of the Lead Renovation, Repair, and Painting (RRP) Rule . Question Number: 23002-19754 Find a printable PDF copy of all frequent questions pertaining to lead .
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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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Does the Renovation, Repair, and Painting (RRP) Rule apply where no paint at all is present, such as in a 100 year old unfinished basement?
No. The RRP Rule applies to activities that result in the disturbance of painted surfaces. Where there is no paint to disturb, the RRP Rule does not apply. Question Number: 23002-15696 Find a printable PDF copy of all frequent questions pertaining to lead .
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Does the RRP Rule apply to federal employees performing work on federal facilities?
Yes. Federal agencies and their employees must comply with all Federal, State, interstate, and local requirements, both substantive and procedural, respecting lead-based paint in the same manner and to the same extent as any non-governmental entity. In addition, the RRP Rule requires all renovations performed after April 22, 2010, to…
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Does the RRP rule apply to simple painting activities that occur when rental properties turn over? Approximately half of the rental units in the country get new tenants each year. This means a large number of properties are being repeated.
If there is no surface preparation that disturbs the existing paint prior to painting, the RRP Rule does not apply. If you disturb paint by scraping or sanding while preparing the surface, the RRP Rule applies. Question Number: 23002-15692 Find a printable PDF copy of all frequent questions pertaining to…
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Does the RRP Rule apply to office buildings, stores, and other commercial buildings?
No, unless the renovation is taking place in a child-occupied facility that is located in a commercial building. “Child-occupied facility’’ means a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, under six years of age, on at least two different days within…
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My firm repairs windows by removing and replacing the sash. We may disturb paint on the hinges and screws, but do not otherwise disturb a painted surface. Is this work subject to the Lead Renovation, Repair and Painting (RRP) Rule?
Replacement of a window sash by simply unscrewing hinges or releasing it from a jambliner does not constitute "window replacement" for purposes of the RRP Rule . Therefore, such tasks may fit within the definition of minor repair and maintenance i.e., activities that disturb six square feet or less of…
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Eligibility for qualified oil-filled operational equipment in event of a discharge
Does a facility automatically lose eligibility for the option for qualified oil-filled operational equipment if the equipment has an oil discharge? No. Facilities that choose this alternative and later have a reportable oil discharge from qualified oil-filled operational equipment do not automatically lose eligibility. However, the spill reporting requirements would…
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Can qualified facilities also use the alternative requirements for qualified oil-filled operational equipment?
Yes. Facilities that meet the criteria for qualified facilities and qualified oil-filled operational equipment may benefit from both of the alternative approaches. Since an impracticability determination is not necessary for qualified oil-filled operational equipment, the owner/operator can self-certify the SPCC Plan and is not required to have a PE develop…
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Does the RRP Rule apply to renovations that disturb ceramic tile where the glaze on the tile contains lead at regulated levels?
No. Ceramic tile glaze is neither a surface coating nor a painted surface. Therefore, renovations that disturb ceramic tile glaze are not subject to the RRP Rule. Question Number: 23002-15691 Find a printable PDF copy of all frequent questions pertaining to lead .
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