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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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What does it mean when EPA finds contamination that “exceeds screening levels?”
Screening levels are not the same as cleanup or action levels. An exceedance of a screening level indicates the need for additional evaluation, potentially including a site-specific risk assessment.
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How do you know you are not missing some areas that might be contaminated?
EPA uses all credible information available, including community input, regarding the boundaries and geographic areas of waste that may have been deposited or where contaminated soil may have been placed. The team selects its sampling locations based on those areas and consults historic aerial images that help depict those boundaries.
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If EPA finds any contamination associated with the Norwood Landfill site that “exceeds” what is considered safe, will EPA clean up that contamination - even if the Agency cannot find any “pathways” for that contamination to reach humans or sensitive environments?
If the sampling data shows an exceedance of a screening level, EPA will consult with the site Toxicologist and the Agency for Toxic Substances and Disease Registry (ATSDR) to conduct a human health risk screening assessment to determine any potential threat to human health. EPA will also consult with the…
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What questions was EPA trying to find answers to during its first round of sampling at the Norwood Landfill site?
The main question that EPA seeks to answer is whether the identified waste areas warrant consideration for placement of the Site on the National Priorities List (NPL) or Superfund List. In the first round of sampling, EPA collected surface soil samples (0-2 feet) from the landfill property, and surface water…
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Will EPA sample the Glenolden Laboratory property?
The former Glenolden Laboratory property located on South Avenue is a separate site. The previous owners conducted a voluntary cleanup pursuant to the Pennsylvania Department of Environmental Protection’s (PADEP) Environmental Cleanup Program, known as Act 2. Concerns regarding remedial actions conducted under Act 2 should be directed to PADEP as…
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Does an ethanol producer who sells undenatured ethanol to a U.S. importer who denatures it at the port need to register with EPA under RFS?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The RFS regulations specify that foreign producers of ethanol for use in transportation fuel, heating oil or jet fuel for import to the US who do not add denaturant to their product, must register under RFS. See 80.1450(b)…
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My firm installs carpets. Sometimes there is no need to remove an existing carpet before installing the new carpet, but sometimes there is. How do I know when I need to comply with the Lead Renovation, Repair and Painting (RRP) Rule?
If when installing the carpet, you disrupt six square feet or less of painted surface per room, the job is not covered by the RRP Rule . Question Number: 23002-19749 Find a printable PDF copy of all frequent questions pertaining to lead .
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Will EPA conduct sampling in local parks in the Norwood community?
EPA will sample Norwood Park because of its close proximity to the Old Norwood Dump and Norwood Landfill. There is no current information that would warrant sampling in other parks.
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Will EPA sample the Norwood school?
EPA continues to work closely with the Interboro School District, but there are no plans to sample the Norwood school at this time. For site investigations, sampling activities must be based upon the identification of a potential source of contamination. Based upon research and historic images, EPA has not seen…
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Please provide guidance on how the Agency will interpret the term “minor repair and maintenance activities.”
Answer: “Minor repair and maintenance” is defined in 40 CFR 745.83 as activities that disrupt less than 6 square feet or less of painted surface per room for interior activities or 20 square feet or less of painted surface for exterior activities where none of the work practices prohibited or…
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Does the minor maintenance exception mean that if I drill one-inch holes in a painted surface to blow insulation into an enclosed wall cavity, I could drill 864 holes in the interior or 2880 holes on the exterior before I had to comply with the RRP Rule?
The exception is based on the area of paint disrupted, which in this example is based on the combined areas of the holes drilled in the wall. Question Number: 23002-15677 Find a printable PDF copy of all frequent questions pertaining to lead . Other Frequent Questions about the RRP Program…
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