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Displaying 16 - 30 of 40 results
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RMP Self-Paced Training Courses
Does EPA offer any self-paced training courses covering the Risk Management Program under Clean Air Act Section 112(r)? Yes, EPA Region 7 developed self-paced training modules for facilities with program level 1, 2 or 3 processes. The modules cover topics such as RMP applicability, offsite consequence analysis, 5-year accident history…
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Why are gloves, which are exposed to large amounts of lead dust, not required to be disposed of under the Lead Renovation, Repair and Painting (RRP) Rule?
The RRP Rule requires the renovation firm to use precautions to ensure that all personnel, tools, and other items are free of dust and debris before leaving the work area. Workers with contaminated clothing can take that contamination home to their own children, and taking contaminated equipment to another jobsite…
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Vulnerable Zone Determination
Vulnerable zones are areas that could be affected by a release from a chemical accident at a facility subject to the risk management program requirements in 40 CFR Part 68. How can one determine if they live or work within a vulnerable zone? The Vulnerable Zone Indicator System (VZIS) allows…
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Naturally Occurring Hydrocarbon Mixtures Exemption
Pursuant to the risk management program regulations under 40 CFR §68.115(b)(2)(iii), regulated substances in naturally occurring hydrocarbon mixtures prior to entry into a natural gas processing plant or a petroleum refining process unit do not need to be considered when determining whether more than a threshold quantity is present at…
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Are facilities that have received ISO 14001 certification exempt from audits?
If we have been audited by a qualified third party, for ISO 14001 certification or for other programs, are we exempt from audits? No. However, you may want to inform your implementing agency that you have gained such certification and indicate whether the third party reviewed Part 68 compliance as…
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Will risk management plan (RMP) submissions be subject to audits?
Will risk management plan (RMP) submissions be subject to audits? If so, who will conduct the audits? Yes. According to 40 CFR §68.220(a), the implementing agency will periodically audit RMPs in order to review their adequacy, and may require revisions of RMPs as necessary to ensure compliance. The implementing agency…
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Applicable requirements for Title V air permits
Under the CAA, air permitting authorities must ensure that sources are in compliance with applicable requirements to issue a permit. Do the CAA §112(r) provisions constitute applicable requirements for Title V air permits? Yes. Section 112(r) is an applicable requirement for CAA Title V air permits under 40 CFR Parts…
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Comprehensiveness and format of a management system
What is a management system (40 CFR §68.15(a))? How comprehensive must it be? Is there a standard format? The management system required under Subpart A of 40 CFR Part 68 is essentially a system defined by facility managers for integrating the implementation of the risk management program elements and assigning…
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Consolidated List of Chemicals Subject to EPA Regulatory Programs
EPA implements a number of regulatory programs that use specific chemical lists as part of the process to determine reporting applicability. Is there a consolidated list of chemicals that are subject to EPA programs? The Consolidated List of Chemicals subject to the Emergency Planning and Community Right-To-Know Act (EPCRA), Comprehensive…
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How to deregister facility from risk management program
How do I deregister my facility from the risk management program? If a facility is no longer subject to the risk management program, the facility owner or operator must deregister within six months (40 CFR §68.190(c)). To deregister, you should submit a letter to the RMP Reporting Center within six…
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Is there an EPA enforcement policy for violators of CAA §112 and the risk management program rule?
Yes, EPA has issued a Final Combined Enforcement Policy for section §112(r) Risk Management Program .
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How should lead-containing wastes from RRP renovations be handled and disposed?
While at the work site, wastes must be collected at the conclusion of each work day and at the conclusion of the renovation and stored under containment, in an enclosure, or behind a barrier that prevents release of dust and debris out of the work area and prevents access to…
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Can non-certified workers transport debris off site under the RRP Rule if they have had documented on-the-job training in this activity by the certified renovator?
Answer: Yes. The RRP Rule requires the certified renovator to regularly direct the work being performed by other individuals to ensure that the work practices are being followed, including ensuring that dust or debris does not spread beyond the work site. The certified renovator is responsible for providing training to…
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Under the Lead Renovation, Repair and Painting (RRP) Rule, how should I dispose of contaminated water used in two-bucket mopping?
EPA recommends contacting your local water treatment authority and asking about local requirements for handling and disposing of waste water. Question Number: 23002-20756 Find a printable PDF copy of all frequent questions pertaining to lead .
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States with authority to implement / enforce the risk management program rule
Which states have been granted delegation of EPA's authority to implement and enforce the risk management program rule? The current list of delegated states and counties is: Delaware, Florida, Georgia, Mississippi, New Jersey, North Carolina, North Dakota, Ohio, and South Carolina. Additionally, the following territories and local jurisdictions have delegation…
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