Document orJrn0z2n6Y4bMpnwRanqq3

. Section Convnsnt >er Commentator tn r - Comment Resoonse _ the OSHA standard to orotect employees' health can be achieved bv the use of resolratorv ecuipment, even In those situations where wettino is not imolemented and emissions may nroduce concentrations in excess of the OSHA exposure limit. The extent to which emissions to the outside air are reduced cannot be determined. The Agency intends that OSHA regulated industries report renovation operations to the Administrator. Without the reporting requirements, the Agency's enforcement of the renovation standard will be relatively ineffective; therefore, the standard has not been revised. 100 The frequency and lead time for written The Agency has reevaluated the reportinq requirements notice of Intention to do repetitive of the amendments and a discussion of the revised renovation work on certain processes is excessive. reporting requirements for renovation operations is presented in the response to comment number 101. The notice of intention to do renovating work must be postmarked or otherwise delivered to the Administrator as soon as possible, prior to commencing renovation. The Agency believes that the frequency and lead time reporting requirements are reasonable and will not cause untenable hardships for any renovation operation. 101 The proposed reputations should be modified to include definitions of "emergency and routine maintenance The Agency agrees that routine and emergency renovation operations should be distinguished and reported to the Administrator by separate reporting procedures. There renovating," and to stipulate that fore, the standard has been revised by adding a written notice of intention toper- definition for planned renovation" and "omorc^ncy form these operations must be filed renovation." once every year for each plant site DUP 0 9 0 4 1 3 1