2.1.1 Lead Renovation, Repair, and Painting Program: considering new post-work requirements designed to ensure cleaning meets clearance standards
Common renovation activities like sanding, cutting, and demolition can create hazardous lead dust and chips by disturbing lead-based paint, which can be harmful to adults and children. To protect against this risk, on April 22, 2008, EPA issued the Lead Renovation, Repair, and Painting Program rule (Lead RRP) requiring the use of lead-safe practices and other actions aimed at preventing lead poisoning. Under the rule, beginning April 22, 2010, contractors performing renovation, repair, and painting projects that disturb lead-based paint in homes, child care facilities, and schools built before 1978 must be certified and must follow specific work practices to prevent lead contamination. On May 6, 2010, EPA proposed additional requirements designed to ensure that renovation work areas are adequately cleaned after renovation work is finished and before the areas are re-occupied. These additional requirements included dust wipe testing after renovations and additional cleaning, if needed, designed to ensure that renovation work areas meet clearance standards before re-occupancy. The cost of EPA's proposed additional testing requirements were between $272 million to $290 million per year ($2008). EPA is now reviewing the efficacy of both its original testing requirements as well as those additional requirements proposed in 2010 and expects to issue a final rule in summer 2011.
2.1.11 National Pollutant Discharge Elimination System (NPDES): coordinating permit requirements and removing outdated requirements
EPA plans to review the regulations that apply to the issuance of NPDES permits, which are the wastewater permits that facility operators must obtain before they discharge pollutants to any water of the United States. EPA plans to review NPDES permitting regulations in order to find provisions that are outdated or ineffective. EPA expects the review to most likely focus on: a) eliminating inconsistencies between regulations and application forms; b) improving the consistency between the application forms; c) updating the application forms to address current program practices; d) clarifying the existing regulations and modifying or repealing permitting, monitoring, and reporting requirements that have become obsolete or outdated due to programmatic and technical changes that have occurred over the past 20 years; and e) modifying permit documentation and objection procedures to improve the quality and transparency of permit development. As an example of an outdated regulation which could be changed to reduce burden, as well as improve transparency and public access to information, EPA is considering whether to revise the public notice requirements to allow a state to post notices and draft permits on their state agency websites in lieu of traditional newspaper posting. EPA expects to propose modifications to NPDES permit regulations by the end of 2011.
The proposed plan also included 15 regulatory reviews that the Agency will focus on in the longer term. These actions focus on reducing regulatory burdens in some of its reporting programs, coordinating regulatory requirements in some programs, simplifying and clarifying requirements in several programs such as the Water Quality Standard regulations and Clean Air Act Title V Permit programs and reducing burden in the State Implementation Plan among others. To read EPA’s preliminary plan and to comment on the plan, go to Web page.