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  • What is a studio apartment?

    A studio apartment is an apartment in which the living area is not separated from the sleeping area. Question Number: 23002-22148 Find a printable PDF copy of all frequent questions pertaining to lead .

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  • When testing a property for the presence of lead prior to beginning a renovation using an EPA-recognized lead test kit, must I test every component affected by the renovation?

    Answer: Yes. Because certified renovator training does not cover sampling protocols, certified renovators using EPA-recognized lead test kits or performing paint chip sampling to determine the applicability of the RRP Rule must test each and every component that will be affected in order to determine that the RRP Rule does…

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  • Does the RRP Rule apply to renovations in mobile homes?

    Answer: Yes, if the mobile home meets the definition of target housing. “Target housing” is any housing constructed before 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…

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  • What is a child-occupied facility?

    Answer: A child-occupied facility is a building, or a 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 any week (Sunday through Saturday period), provided that each day's visit lasts at least three…

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  • Atmospheric conditions used for off-site consequence analyses

    What atmospheric conditions must a source assume when performing the offsite consequence analyses required under 40 CFR Part 68, Subpart B? For the worst-case release analysis, 1.5 meters per second wind speed and F atmospheric stability class must be assumed, unless the stationary source owner or operator can demonstrate that…

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  • Program levels and the difference in worst-case release analysis requirements

    The preamble to the Risk Management Program Rule ( 61 FR 31668; June 20, 1996 ) states that "one worst-case release scenario will be defined to represent all toxics, and one worst-case release scenario will be defined to represent all flammables held above the threshold at the source" ( 61…

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  • Methods to identify affected populations

    As part of the risk management program, a facility owner or operator must prepare an off-site consequence analysis (OCA) and estimate in the risk management plan (RMP) the residential population within the geographical area that could be affected by the hypothetical worst-case or alternative releases that the facility has analyzed…

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  • Definition of recreational area for determining offsite impacts in RMP

    What is considered a recreational area? Recreational areas would include land that is designed, constructed, designated, or used for recreational activities. Examples are national, state, county, or city parks, other outdoor recreational areas such as golf courses or swimming pools and bodies of waters (oceans, lakes, rivers, and streams) when…

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  • Worst case release scenario for toxic and flammable substances in same Program 1 process

    Under the risk management program regulations in 40 CFR Part 68, if a Program 1 process contains a threshold amount of both a regulated toxic substance and a regulated flammable substance, should a worst case release scenario be analyzed for each of the substances in the process? Yes, a worst…

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  • Definition of off-site for identifying public receptors

    My processes are fenced, but my offices and parking lot for customers are not restricted. What is considered offsite? What is considered a public receptor? The unrestricted areas would be considered offsite. However, they would not be public receptors because you are responsible for the safety of those who work…

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  • What measures qualify as "passive mitigation"?

    Passive mitigation is defined in § 68.3 as "equipment, devices, or technologies that function without human, mechanical, or other energy input." Passive mitigation systems include building enclosures, dikes, and containment walls. Measures such as fire sprinkler systems, water curtains, valves, scrubbers, or flares would not be considered passive mitigation because…

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  • Ammonia (concentration 20% or greater) and Ammonia (anhydrous) Alternative Release Scenarios

    Pursuant to the Risk Management Program regulations, the owner or operator shall identify and analyze at least one alternative release scenario for each regulated toxic substance held in a Program 2 or Program 3 process above its threshold (40 CFR §68.28). If a facility has both ammonia and ammonia (anhydrous)…

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  • Are sleeping areas in buildings built before 1978, such as those in fire and police stations, considered target housing?

    Firehouses and police stations are not target housing. Therefore, places of temporary rest for employees in these buildings, such as sleeping rooms, are not subject to the Lead Renovation, Repair, and Painting (RRP) Rule . Question Number: 23002-33291 Find a printable PDF copy of all frequent questions pertaining to lead…

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  • How does a firm or renovator document or confirm the age of the structure? Is a signed statement by the occupant sufficient? Can publicly available information such as tax records, etc. be sufficient?

    Renovation firms are responsible for determining the age of the property. The property owner is likely to be a good source of information on the age of a home or other building, but the firm may not rely on the statement of the property owner as to the construction date…

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  • Does the RRP Rule apply to removing a roof that is not painted?

    The RRP Rule applies to work that disturbs painted surfaces. Where there is no paint to disturb, the RRP Rule does not apply. Question Number: 23002-15689 Find a printable PDF copy of all frequent questions pertaining to lead .

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