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Determining frequency of coordination activities
The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs annually, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)). Are stationary sources responsible for determining if coordination activities should occur more often than annually? Ultimate responsibility…
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Visit and examination requirements for SPCC self-certification
Pursuant to 40 CFR §112.6, the owner or operator of a facility that meets the criteria in §112.3(g) for either a Tier I or Tier II qualified facility may self-certify the facility's SPCC Plan. As part of the self-certification, the owner or operator must certify that he or she has…
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Who Must Develop an Emergency Response Program?
The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date…
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Availability of electronic SPCC Plan template
Part 112, Appendix G to prepare an SPCC Plan. Is the Tier I qualified facility SPCC Plan template available in an electronic version? EPA has made available electronic versions of the Tier I qualified facility Plan template to help the owner or operator of a Tier I qualified facility develop…
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Is it permissible for a training provider to employ more than one training manager?
Answer : Yes. The Rule requires that a training provider employ a training manager that meets the qualifications in 40 CFR 745.225(c)(1). EPA does not interpret this to be a limitation on the permissible number of training managers. Therefore, a training provider may employ more than one training manager so…
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If a renovator takes the refresher course early, would the new certification be valid for five years from the date of training, or five years from the date that the previous certification expires?
Question : I’m a training provider and have been accredited for the renovator refresher course. If a renovator takes the refresher course early (i.e., before their previous certification has expired), would the new certification be valid for five years from the date of training, or five years from the date…
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I'm an accredited training provider. Can the final course assessment to be administered in an "open book" format?
No. The training provider is responsible for maintaining the validity and integrity of the course test to ensure that it accurately evaluates the trainee’s knowledge and retention of the course topics. A course test administered in an open book format does not evaluate whether a student has sufficiently learned and…
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Remote coordination with local authorities
The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs annually, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)). If a stationary source is in a remote location and in-person annual coordination is deemed impractical, can…
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Emergency Response Coordination Activities Effective Date
The RMP Amendments finalized on January 13, 2017 included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93). The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018. Because…
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Do all renovation course instructors need to be approved as principal instructors? For example, to reach a 6:1 student-to-instructor ratio with 18 people in the class, may we have one principal instructor who teaches the entire lecture and is assisted by two additional hands-on instructors (who are not approved as principal instructors)?
Answer: Every accredited training program must employ a qualified training manager, and it is the job of the training manager to designate a qualified principal instructor for each course. The principal instructor is responsible for the organization of the course and oversees the teaching of all course material. The training…
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Tier I qualified facility template use under Part 112
In the 2008 Amendments to the SPCC Rule, EPA provided a template for the owner or operator of a Tier I qualified facility to create an SPCC Plan. Does EPA require a Tier I qualified facility to use the template in 40 CFR Part 112, Appendix G? Does EPA allow…
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Difference between an SPCC Tier I and Tier II qualified facility
In the SPCC regulations in 40 CFR Part 112, what is the difference between a Tier I and Tier II qualified facility? How did EPA establish the multi-tiered approach for qualified facilities? A Tier II qualified facility is one that has an aggregate aboveground oil storage capacity of 10,000 U.S…
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Types of Information Relevant for Response Planning
The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency…
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If a student in a renovator training course is unable to read and understand English, may the exam be read to them in their native language?
No. Separate course accreditations are required for each renovation course a training provider offers that is in a language other than English. Courses presented in a language other than English must use instructor manuals, exams, and other course materials in that language that have been reviewed by EPA as part…
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May renovator training providers provide reasonable accommodations to people with disabilities?
Yes. However, to pass the course an individual must successfully complete the hands-on skills assessment and receive a passing score on the course test. Question Number: 23002-19568 Find a printable PDF copy of all frequent questions pertaining to lead .
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