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If I am painting a wall on which there are multiple coats of latex paint over the old lead-based paint and the paint is not peeling down to the lead paint level must I comply with the new Renovation, Repair, and Painting (RRP) regulations?
Yes, if the painted surface of the wall will be disturbed by the renovation. Question Number: 23002-18485 Find a printable PDF copy of all frequent questions pertaining to lead .
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If a homeowner removes all the painted surfaces in a room and then hires a certified firm to remodel the room, does the renovator need to follow the RRP Rule?
No. Projects that do not disturb a painted surface are not subject to the RRP Rule. Question Number: 23002-18301 Find a printable PDF copy of all frequent questions pertaining to lead .
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My local community has formed a “Long Term Recovery Committee”. The committee gathers donations and provides assistance to families via volunteer work crews and/or contracted skilled labor. Are these efforts subject to the RRP Rule?
My local community has formed a “Long Term Recovery Committee” to assist in the rebuilding and recovery efforts following a natural disaster. The committee, which is a coalition of member agencies from the faith community, nonprofit agencies, government programs, businesses and individual donors, gathers monetary and material donations and provides…
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Older hotels built before 1978 are knocking down walls, combining two hotel rooms, and making their units two-room or even three-room suites. Does the RRP Rule apply when one-room units are converted to two-room suites?
Yes. A renovation performed for the purpose of converting a building, or part of a building, into target housing or a child-occupied facility is a renovation for purposes of the RRP Rule. Hotel suites that provide a sleeping area that is separate from the living area are covered by the…
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What is "housing for persons with disabilities"?
“Housing for persons with disabilities” means housing that is designed to meet the special needs of persons with disabilities and that is reserved for such persons. A person with a disability may include a person who has a disability attributable to a mental or physical impairment, or a person with…
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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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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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Clean Water Act (CWA) and CERCLA Hazardous Substance Lists
What is the relationship between the hazardous substance lists under the Clean Water Act (CWA) and under CERCLA? All CWA hazardous substances and CWA toxic pollutants are CERCLA hazardous substances, whereas only some CERCLA hazardous substances are CWA hazardous substances. CERCLA section 101(14) defines “hazardous substance” by reference to lists…
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Does the term "target housing" mean just low income housing, or any home built before 1978 regardless of the financial status of the occupants?
Answer: “Target housing” means any housing constructed prior to 1978, except housing for the elderly or persons with disabilities or any 0-bedroom dwelling (unless any child who is less than six years of age resides or is expected to reside in such housing). The income of the occupants of the…
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Using TRI Form R for Continuous Release Reporting
A facility wants to use the reduced reporting option under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) section 103(f)(2) for releases of hazardous substances that occur in a manner that is continuous and are stable in quantity and rate. Can the Toxics Release Inventory (TRI) Form R be…
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Determining the amount released for Ammonia and Ammonium Hydroxide for Release Notification Requirements under CERCLA section 103 and EPCRA section 304
Ammonia (CAS number 7664-41-7) is an Extremely Hazardous Substance (EHS), listed at 40 CFR Part 355 Appendix A and Appendix B with a reportable quantity (RQ) of 100 lbs. Both ammonia and ammonium hydroxide (CAS number 1336-21-6) are listed as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances…
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EPCRA Release Notification of RQ in Any 24-Hour Period
EPCRA section 304 requires notification to the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) when there is a release of a reportable quantity (RQ) of either a CERCLA hazardous substance or an extremely hazardous substance (EHS). CERCLA section 103(a) and 40 CFR 302.6 require notification…
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Release notification requirements for an EHS generated as by-product
Pursuant to Section 304(a)(2), the owner or operator of a facility must report to the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) any releases of extremely hazardous substances (EHSs) or CERCLA hazardous substances which equal or exceed established reportable quantities (RQs). This requirement only applies…
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Spills onto concrete floors inside a building
A facility has a spill of an extremely hazardous substance in an amount greater than its reportable quantity. The spill occurs on a concrete floor that is inside a facility building. Before the spill can be cleaned up, a portion (less than RQ) of the EHS enters the outside atmosphere…
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Reportable quantity calculations for chemicals in abandoned containers
Must any amount of a listed chemical contained within abandoned or discarded barrels, containers, or other receptacles be considered to determine if a specific reportable quantity has been exceeded under EPCRA Section 304 notification requirements? 40 CFR §355.61 (April 22, 1987, 52 FR 13395 ) defines a release as "any…
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