Environmental basics: Massachusetts Contractor Business & Law Practice Questions

The EPA lead Renovation, Repair and Painting (RRP) rule applies mainly to work that disturbs paint in which buildings?

The RRP rule covers renovations for compensation in target housing (pre-1978 housing) and child-occupied facilities built before 1978, the year lead paint was banned for residential use.

Before renovating a pre-1978 home, when must the firm give the owner EPA's lead hazard information pamphlet?

The pamphlet (Renovate Right) goes to the owner, and to an adult occupant if the owner does not live there, no more than 60 days before renovation. The firm keeps a signed acknowledgment or a certificate of mailing sent at least 7 days before work.

Interior minor repair and maintenance that disturbs no more than how much painted surface per room is outside the RRP work-practice rules?

Minor repair and maintenance means 6 square feet or less per room inside, or 20 square feet or less outside, and never includes window replacement, demolition of painted surfaces or prohibited practices.

A contractor replaces one window in a 1965 house. Does the RRP minor-repair exemption apply?

The definition of minor repair and maintenance excludes window replacement regardless of size, so lead-safe work practices and a certified firm are required.

Which paint-removal practice is prohibited under the RRP rule?

Open-flame burning or torching is banned. High-speed sanding or grinding needs a HEPA-exhaust shroud, and heat guns must stay below 1,100 degrees Fahrenheit.

For how long is an EPA RRP firm certification valid before the firm must recertify?

Firm certification expires no more than 5 years after EPA approval, and firms must recertify every 5 years. Each job also needs a certified renovator assigned.

How long must an RRP firm keep records showing compliance on a renovation job?

Firms must retain, and provide to EPA on request, all records needed to show compliance for 3 years after the renovation is completed.

After interior RRP work, how does a certified renovator usually verify cleaning?

The renovator visually inspects, then wipes windowsills, uncarpeted floors and countertops and compares each cloth to the cleaning verification card, re-cleaning areas that fail.

When does a construction site generally need Clean Water Act stormwater permit coverage?

Construction activity disturbing one acre or more needs NPDES permit coverage, as do smaller sites that are part of a larger common plan of development that will disturb one acre or more.

Under EPA's Construction General Permit, what plan must the operator prepare before starting earth-disturbing work?

The SWPPP describes the site's erosion and sediment controls, pollution prevention, inspections and stabilization. Coverage is obtained by filing a Notice of Intent with the permitting authority.

Under EPA's construction effluent guidelines, which discharge from a site is prohibited?

The C&D rule prohibits discharging wastewater from concrete washout, fuels, oils, soaps and solvents, and requires controls to minimize pollutants and stabilize disturbed areas.

Which practice helps keep sediment from leaving a construction site?

Erosion and sediment controls include silt fences, stabilized entrances, inlet protection, phasing and prompt stabilization of disturbed areas.

Before demolishing or renovating a commercial building, what does the asbestos NESHAP require the owner or operator to do first?

The owner or operator must thoroughly inspect the affected part of the facility for asbestos, including nonfriable material, before demolition or renovation begins.

Under the asbestos NESHAP, how much notice is generally required before a regulated demolition or asbestos removal begins?

Written notice generally must be postmarked or delivered at least 10 working days before work begins. Demolitions need notice even when no asbestos is present.

Under the asbestos NESHAP, full removal requirements apply to a renovation when regulated asbestos material reaches at least what amount on pipes?

The thresholds are 260 linear feet on pipes, 160 square feet on other facility components, or 35 cubic feet where the amount could not be measured beforehand.