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Can a facility divide a process when assigning program levels?
My process includes a series of interconnected units, as well as several storage vessels that are co-located. Several sections of the process could qualify for Program 1. Can I divide my process into sections for the purpose of assigning Program levels? No, you cannot subdivide a process for this purpose…
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If a stationary source has processes ineligible for Program 1, are all processes ineligible?
If a stationary source has several processes that are covered under 40 CFR Part 68, and some of those processes have had an accidental release within the past five years (effectively making those processes ineligible for Program 1 status), are the individual processes from which no accidents have occurred also…
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If a covered process has an accident, when does it lose eligibility for Program 1 status?
A process covered under 40 CFR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed at 40 CFR §68.10(b). Those criteria include a requirement that the process cannot have had an accidental release of a regulated substance that led to offsite death, injury…
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Applicability of program levels and prevention program requirements for co-located vessels
I have a tank with 1,000,000 pounds of toluene diisocyanate (TDI), which is covered under the RMP rule, but not under OSHA PSM. Considered by itself, the TDI would be Program 2 for EPA. The tank, however, is close to equipment that has chlorine above the applicable threshold and is…
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Changing from a Program 2 or 3 process to a Program 1 process
If five years have passed since the last accident involving a covered process, and that process meets the other two requirements identified under 40 CFR §68.10(b) for Program 1 eligibility, could that process become a Program 1 process even if it had previously been identified as a Program 2 or…
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How much flexibility do applicants have in refining the Outcomes and Outcomes over time using an adaptive management approach?
Full Question How much flexibility do applicants have in refining the Outcomes and Outputs identified in their application over time using an adaptive management approach? Answer EPA recognizes that “adaptive management” can be an effective tool in getting the best results. Adjustments to outputs and outcomes based on the adaptive…
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Do we have to pair hands-on, place-based Great Lakes enviro education with one of the other GLRI actions/related MOP?
Full Question Do we have to pair hands-on, place-based Great Lakes enviro education (i.e., GLRI Measure of Progress, GLRI MOP 5.1.1 youth impacted through education and stewardship projects) with one of the other GLRI actions/related MOP? Answer Projects that relate to 5.1.1 are not required to connect to another specific…
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Should applications include Outputs and Outcomes related to Project Subrecipient evaluation criteria?
EPA cannot provide a recommendation on this question. Applicants must decide whether or not they develop outputs and outcomes based on Project Subrecipient evaluation criteria for themselves. Please see section I.F. for information on Outcomes, Outputs, and Performance Metrics which includes information on performance measurement and evaluation plans.
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How do applicants reflect the 6th year of funding on the SF424A form, as there is only room for 5 years?
We realize this is a limitation of the form and expect applicants to provide information to the best of their ability. Applicants should also provide sufficient information in the budget narrative section of their application.
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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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Can letters of support be emailed directly to EPA?
Only materials submitted as part of the grant application submitted on Grants.gov will be considered. If supporters wish to send letters directly to EPA, they may email ( [email protected] ). However, for them to be considered with the application, the applicant organization should be copied on those email messages with…
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Assigning program level 1 if a public receptors is just beyond distance to endpoint
Our distance to the endpoint for the worst-case release is 0.3 miles. The nearest public receptor is 0.32 miles away. What tools are available to document that the public receptor is beyond the distance to the endpoint so we can qualify for Program 1? The results of any air dispersion…
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