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East Palestine, Ohio Train Derailment
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Lead
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Renovations Covered by the RRP Rule
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How is waste leaving the derailment site tracked?
EPA on-scene coordinators are assigned to track liquid–and solid–waste trucks entering and leaving the derailment site. They log every truck, oversee the loading and covering of waste, truck washing and weighing, and the proper placement of placards. Responders take pictures throughout the process. All trucks go to approved and regulated…
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What happens after the track work is completed?
The track work has been the highest priority to remove most contamination as early as possible. This, plus preventing the spread of contamination by capturing water from the site and constructing a bypass of Sulphur Run around the site will continue into June. While track work and water management continue…
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What does the on-site wastewater treatment process on site entail?
EPA has approved a workplan to allow Norfolk Southern to treat hazardous wastewater on-site, removing vinyl chloride and other contaminants to dispose of the treated wastewater off-site as a non-hazardous waste. Currently, the train derailment site generates nearly one million gallons of wastewater per week from the collection of stormwater…
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Where is the treated wastewater going?
The wastewater treatment system removes derailment contaminants using several steps, including sedimentation and filtration. The treated wastewater is then tested to verify vinyl chloride is below the drinking water standard. Once treated, water is sent to facilities certified to accept non-hazardous wastewater and that are regulated by federal and state…
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Are there health risks to driving through Taggart Street?
There are no anticipated health risks along Taggart Street associated with project activities. As work proceeds, to ensure worker and community safety, the Unified Command will continue to evaluate site conditions for health and safety considerations. While traffic will be able to proceed through the work areas along Taggart Street…
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A home sustained flooding as a result of a hurricane. Once the flood water recedes, my firm must make the necessary renovations. How do the record keeping requirements apply to an emergency renovation?
Emergency renovations (other than interim controls performed in response to a child with an elevated blood lead level) are exempt from the training, certification, sign posting, waste handling and containment requirements of the Lead Renovation, Repair and Painting (RRP) Rule only to the extent necessary to respond to the emergency…
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Does the Renovation, Repair, and Painting (RRP) Rule apply to renovations done in an apartment between tenants? Does it matter if children live in other apartments in the building?
Answer: Temporarily unoccupied or vacant rental housing is not exempt from the requirements of the RRP Rule. Question Number: 23002-15669 Find a printable PDF copy of all frequent questions pertaining to lead .
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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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Are renovations performed on detached garages, sheds and other detached outbuildings on the property subject to the RRP Rule?
Yes. EPA interprets target housing to include pre-1978 buildings or structures that are (1) located on the residential portion of the property, and (2) associated with the residential use of the property. As a practical matter, the entire property of most urban and suburban residential lots is normally considered to…
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I have a for-profit business where I purchase residential properties and renovate them. Is this type of renovation work on pre-1978 properties covered by the Lead Renovation, Repair, and Painting (RRP) Rule?
Yes. Individuals who buy, renovate and sell pre-1978 residential properties for a profit (i.e., house flippers) or lease pre-1978 residential properties (i.e., landlords), and do the renovation work themselves, are performing renovations for compensation and are therefore subject to all requirements under the RRP Rule . You must be a…
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How do the RRP requirements apply to renovations on a pre-1978 building that contains both multi-room apartments (i.e., target housing) and zero-bedroom dwellings?
In pre-1978 buildings that contain a mix of target housing and zero-bedroom dwellings, the Lead Renovation, Repair, and Painting (RRP) Rule applies only to renovations performed in target housing and common areas. Common areas are those portions of a property generally accessible to residents/users of target housing, and can exist…
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Does zoning affect the target housing determination? For example, would a pre-1978 house that is zoned for commercial or office use, but used for residential purposes be considered target housing?
In determining whether a pre-1978 property is target housing, it is the actual or intended use of the property that matters, not its zoning classification. Therefore, a pre-1978 house that is used or intended to be used as a residence, even if only temporary, is target housing regardless of its…
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How much waste was removed as part of the cleanup efforts?
In late October, EPA announced the completion of major derailment site excavation. Remaining contaminated soil and debris were removed for off-site treatment or disposal. Contact water continues to be treated in an on-site wastewater treatment system prior to removal for off-site disposal. As of November 13, over 174,000 tons of…
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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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