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Change of owner and RMP facility ID number
If a facility is sold to a new owner, does it keep its' original RMP Facility ID number? Yes. The facility will keep the ID number assigned by EPA.
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Facility ID number and re-registering a facility
If a facility deregisters, then reregisters, should the facility use the original RMP Facility ID or will it be assigned a new ID? The facility should use the original ID assigned by EPA.
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Resubmission of RMP for a facility that previously deregistered
A covered facility deregisters its RMP because it no longer has more than a threshold quantity of a regulated substance in a covered process. If the facility becomes subject to the CAA §112(r) risk management program regulations at a later date and submits a new RMP, should the facility submit…
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RMP Records Maintained Onsite
Pursuant to 40 CFR Part 68, Subpart G, the owner or operator of a stationary source subject to the risk management program regulations in Part 68 must develop and submit a risk management plan (RMP). Does the owner or operator have to maintain a written copy of the RMP on…
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Change of Ownership
If a facility that is subject to the risk management program regulations in 40 CFR Part 68 is sold to another owner, is the facility required to make a correction or a full update of its risk management plan (RMP)? If there are no changes in the covered operations at…
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RMP*eSubmit preparer access
How does a new Preparer get access to a Risk Management Plan (RMP) via RMP*eSubmit? First, the person must register with CDX. To register with CDX, go to https://cdx.epa.gov/ and complete the registration process for a Risk Management Plan “Preparer”. Once set up as a “Preparer”, the Certifying Official needs…
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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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If a door is outside the work area but used by workers to enter and exit the room, does the door need to be covered with plastic?
If the work area is smaller than the entire room, and the door is not within the work area, you do not need to cover the door with plastic. However, all personnel, tools, and other items, including the exterior of containers of waste, must be free of dust and debris…
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For an exterior renovation where vertical containment is set up at a distance of less than ten feet from the work surface, must we still extend the ground containment beyond the vertical barrier to meet the ten-foot requirement?
My firm replaces windows. Various obstacles make it difficult to set up the ten-foot exterior ground containment in a way that would enable our renovators to perform the work and still effectively contain dust. In these cases, we lay the ground containment, but also use vertical containment measures to completely…
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In the EPA Certified Renovator Initial course, plastic sheeting is taped to the floor at several corners, but not around the entire perimeter. Must the plastic be "sealed" to the floor on all four edges by tape or just taped at several locations?
It depends on the specifics of the renovation job. The RRP Rule requires the renovation firm to cover the floor surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in the work area 6 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to…
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What are the requirements for covering doorways used to access the work area?
Doors used as an entrance to the work area must be covered with plastic sheeting or other impermeable material in a manner that allows workers to pass through while confining dust and debris to the work area. Question Number: 23002-21413 Find a printable PDF copy of all frequent questions pertaining…
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To avoid harming the homeowner's grass and landscaping, may my firm fold up the plastic sheeting used for containment at night and re-use it the next day?
Yes, as long as your firm does so in a way that contains any dust and debris on the plastic. One way to accomplish this is to collect and remove the paint chips and debris from the plastic sheeting at the end of each day, mist the sheeting and fold…
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What mil plastic is considered impermeable?
The regulation does not specify a particular thickness of plastic sheeting considered to be impermeable, but rather includes a performance standard. The performance standard requires firms to isolate the work area, prevent dust and debris from exiting and ensure plastic sheeting is not torn or displaced. Certain guidance materials recommend…
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