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How often does a facility need to complete an oil spill response training under the FRP requirements?
Facilities subject to the Facility Response Plan (FRP) regulations in 40 CFR Part 112, Subpart D are required to develop a facility response training program to train those personnel involved in oil spill response activities (§112.21(b)). How often does a facility need to complete an oil spill response training under…
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What is a farm for purposes of the SPCC Rule?
In the December 2006 amendments to the SPCC Rule, EPA defined a farm as "a facility on a tract of land devoted to the production of crops or raising of animals, including fish, which produced and sold, or normally would have produced and sold, 1,000 or more of agricultural products…
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Examples of an agent of a Professional Engineer
Except as provided in 40 CFR §112.6 for qualified facilities, a Professional Engineer (PE) or an agent of the PE must visit and examine the facility before the PE certifies an SPCC Plan (40 CFR §112.3(d)). What are some examples of an agent of a PE? An agent of a…
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What is a significant and substantial harm facility?
Some substantial harm facilities may meet the criteria for a significant and substantial harm facility. After you have prepared and submitted your FRP, the RA may determine that your facility has the potential, not just for substantial harm, but for significant and substantial harm. If the RA makes that determination…
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What is considered bulk oil storage capacity?
The revised rule recognizes that oil is sometimes stored in bulk and sometimes used operationally. A bulk storage container is any container storing oil at a facility. Bulk oil storage containers may include, but are not limited to tanks, containers, drums, and mobile or portable totes. Operational use includes oil-filled…
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Mobile fuel tanker as a facility
Is a non-transportation related mobile fuel tanker with more than 55 gallons located near a 55 gallon drum storage area considered a facility? Perhaps. "Facility" is defined in Part 112 to mean "any mobile or fixed, onshore or offshore building, structure, installation, equipment, pipe, or pipeline (other than a vessel…
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What is a field-constructed container?
What are the types of containers or equipment containing oil reservoirs that would be considered field-constructed containers and thus subject to the brittle fracture evaluation of 40 CFR §112.7(i)? As found in the Preamble language provided on page 47112 of the July 17, 2002 SPCC final rule, EPA provides a…
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PE certification for an FRP if an SPCC impracticability determination is made
If the owner or operator of a facility subject to the SPCC regulations determines that the installation of any of the specified secondary containment structures or equipment is not practicable and accordingly provides in the facility’s SPCC Plan an oil spill contingency plan following the provisions of 40 CFR Part…
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What is oil-filled operational equipment?
Oil-filled operational equipment is equipment that includes an oil storage container (or multiple containers and associated piping intrinsic to the operation of the equipment) in which the oil is present solely to support the function of the apparatus or the device. It is not considered a bulk storage container, and…
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If a company has several legal entities, does each entity have to become a certified firm?
Answer: Yes, if the corporate structure is such that the parent company is not liable for actions of the separate legal entities. Question Number: 23002-18225 Find a printable PDF copy of all frequent questions pertaining to lead .
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My non-profit organization applies for and receives grants to renovate older homes. We do not perform the renovations ourselves, we hire renovation contractors to perform them on our behalf. Must my non-profit organization become an RRP-certified firm?
Answer: Yes, even though your organization's employees do not actually perform the renovation activities, your organization must be an RRP-certified renovation firm because your organization, through the grant process, is offering to perform renovations for compensation, i.e., the grant. Question Number: 23002-19775 Find a printable PDF copy of all frequent…
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I am a facilities manager for a church with daycare and preschool programs. I recently became a certified renovator. If my staff and I do our own painting and remodeling work, do we need to be a certified firm?
Answer: Yes, if you perform, offer, or claim to perform renovations in a portion of the building that is a child-occupied facility. The RRP Rule defines a child-occupied facility as a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, under 6 years…
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If the demolition, cleanup, and cleaning verification portion of a renovation project is performed under the direction of a certified renovator using trained workers, can uncertified workers complete the job if further disturbance of paint will not occur?
If the demolition, cleanup, and cleaning verification portion of a renovation project is performed under the direction of a certified renovator using trained workers, can uncertified workers complete the job if further disturbances of painted surfaces will not occur? For example, a certified firm establishes containment and removes wall and…
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Must maintenance workers at kindergartens and elementary schools become certified renovators if they perform renovations covered by the RRP Rule? Are the schools or school systems then required to become certified renovation firms?
On or after April 22, 2010, all renovations covered by the Lead Renovation, Repair and Painting (RRP) Rule must be directed by certified renovators and must be performed by certified renovators or individuals trained by a certified renovator. The RRP rule requires any firm, including a local government agency that…
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Elements to include in Facility Response Plan
What key elements should I include in my Facility Response Plan? As you prepare your FRP, be sure that your plan includes the following elements: Emergency Response Action Plan (an easily accessible stand-alone section of the overall plan) including the identity of a qualified individual with the authority to implement…
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