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Criteria for oil production facilities to be qualified facilities
Qualified facilities are eligible for streamlined regulatory requirements in 40 CFR §112.6, which include self-certification of SPCC Plans. What criteria do oil production facilities have to meet in order to be considered qualified facilities? Oil production facilities, like all other facilities, must meet the criteria in §112.3(g)(1) or (2) to…
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Secondary containment for oil-filled operation equipment under SPCC
On December 26, 2006, EPA provided an optional alternative to the general secondary containment requirements in 40 CFR §112.7(c) for qualified oil-filled operational equipment ( 71 FR 77266 ). Because the alternative is optional, an owner or operator could choose to comply with the existing SPCC requirements to provide general…
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SPCC requirements for transfer areas associated with exempt USTs
Gas stations typically are not subject to the SPCC Rule because completely buried storage tanks subject to 40 CFR Part 280 or 281 are exempt per §112.1(d)(4). However, a gas station would be subject to the SPCC Rule if it has more than 1,320 gallons of oil in aggregate above…
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Do the changes in the 2006 Amendments apply to oil-filled manufacturing equipment?
No. The amendment does not change any requirements for oil-filled manufacturing equipment. Oil-filled manufacturing equipment remains subject to the SPCC requirements (including those for containment), but an owner/operator may determine that secondary containment is impracticable and comply with the alternative measures in section 112.7(d).
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What is an oil spill contingency plan?
Instead of providing secondary containment for qualified oil-filled operational equipment, an owner or operator may prepare an oil spill contingency plan and a written commitment of manpower, equipment, and materials to quickly control and remove discharged oil. He/she must also have an inspection or monitoring program for the equipment to…
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Secondary containment requirements for mobile refuelers
What secondary containment requirements apply to mobile refuelers? General secondary containment requirements in §112.7(c) still apply to mobile refuelers at SPCC regulated facilities. General secondary containment should be designed to address the most likely discharge from the container and from oil transfers into or from the mobile refueler. The general…
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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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Eligibility for qualified oil-filled operational equipment in event of a discharge
Does a facility automatically lose eligibility for the option for qualified oil-filled operational equipment if the equipment has an oil discharge? No. Facilities that choose this alternative and later have a reportable oil discharge from qualified oil-filled operational equipment do not automatically lose eligibility. However, the spill reporting requirements would…
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Can qualified facilities also use the alternative requirements for qualified oil-filled operational equipment?
Yes. Facilities that meet the criteria for qualified facilities and qualified oil-filled operational equipment may benefit from both of the alternative approaches. Since an impracticability determination is not necessary for qualified oil-filled operational equipment, the owner/operator can self-certify the SPCC Plan and is not required to have a PE develop…
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SPCC compliance dates for farms
What are the Spill Prevention, Control, and Countermeasure (SPCC) compliance dates for farms? On November 22, 2011, EPA amended the date by which certain farms must prepare, or amend, and implement their SPCC Plans to May 10, 2013 to comply with SPCC rule amendments promulgated since July 2002 ( 76…
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Can contractors submit their application to EPA before they complete required training, or must the application be submitted after the training is complete? Is proof of training required by the EPA in order for the contractor's application to be approved?
Answer: The firm certification process does not include the submission of renovator training credentials, so a firm can apply for certification before completing required training. As part of the application, the firm is required to certify it will comply with the requirements of the RRP Rule, including ensuring that all…
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