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  • Release Notification for Lead from Ammunition

    Pursuant to 40 CFR 302.6 , any person in charge of an onshore facility shall, as soon as he or she has knowledge of any release of a hazardous substance from a facility in a quantity equal to or exceeding the reportable quantity (RQ) in any 24-hour period, immediately notify…

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  • EPCRA 312 Tier II Maximum Number of Occupants for Part-Time Occupied Facilities

    On July 13, 2012 ( 77 FR 41300 ), EPA added fields to the EPCRA Tier II form that require the owner or operator to indicate whether the facility is manned or unmanned and the maximum number of occupants present at the facility at any one time. How should facilities…

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  • Determining EPCRA 311 / 312 Compliance After Modifying Solid Manufactured Item

    Under EPCRA section 311(e)(2), any substance present as a solid in any manufactured item to the extent exposure to the substance does not occur under normal conditions of use is exempt from the definition of hazardous chemical and therefore need not be reported under EPCRA sections 311 and 312. However…

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  • States May Have More Stringent Tier II Reporting Requirements

    Pursuant to the Emergency Planning and Community Right-to-Know Act (EPCRA) section 312, facilities meeting the general applicability requirements of 40 CFR 370.10 must submit Tier II inventory information by March 1st. Can states have more stringent requirements than the federal requirements? If so, how can I find out about the…

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  • No Street Address Availability Tier II Reporting

    Pursuant to 40 CFR 370.42(d) , Tier II chemical inventory information must include the complete name and address of the location of the facility (including the full street address or state road, city, county, State and zip code), latitude and longitude. If a facility does not have a street address…

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  • EPCRA Release Notification of RQ in Any 24-Hour Period

    EPCRA section 304 requires notification to the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) when there is a release of a reportable quantity (RQ) of either a CERCLA hazardous substance or an extremely hazardous substance (EHS). CERCLA section 103(a) and 40 CFR 302.6 require notification…

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  • Using TRI Form R for Continuous Release Reporting

    A facility wants to use the reduced reporting option under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) section 103(f)(2) for releases of hazardous substances that occur in a manner that is continuous and are stable in quantity and rate. Can the Toxics Release Inventory (TRI) Form R be…

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  • Where to Sign Paper Tier II Form

    Pursuant to 40 CFR 370.42(a) , the owner or operator filling out the federal EPCRA Tier II Inventory Form must certify that all information included in the Tier II submission is true, accurate, and complete. The instructions indicate that an original signature is required on at least the first page…

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  • Determining the amount released for Ammonia and Ammonium Hydroxide for Release Notification Requirements under CERCLA section 103 and EPCRA section 304

    Ammonia (CAS number 7664-41-7) is an Extremely Hazardous Substance (EHS), listed at 40 CFR Part 355 Appendix A and Appendix B with a reportable quantity (RQ) of 100 lbs. Both ammonia and ammonium hydroxide (CAS number 1336-21-6) are listed as Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substances…

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