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  • Counting Ammonia and Ammonium Hydroxide for Emergency Planning Notification under EPCRA section 302

    Ammonium hydroxide is a solution of ammonia in water. If a facility stores ammonium hydroxide (CAS #1336-21-6) in a large storage tank on site, should the facility include the quantity of ammonia in ammonium hydroxide for the Emergency Planning and Community Right-to-Know Act (EPCRA) section 302 emergency planning notification? The…

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  • Local Emergency Planning Committee request of notification for exempt chemicals

    Under Section 312 , if a local emergency planning committee requests a Tier I/II from a facility owner/operator for a substance which is exempt (either under EPCRA, Section 311(e), or the OSHA Hazardous Communication Standard, 29 CFR 1910.1200(b)) , are they required to comply with the request? If the LEPC…

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  • EHSs and the EPCRA emergency planning requirements

    What is purpose of the list of extremely hazardous substances in regards to the emergency planning requirements of EPCRA? The extremely hazardous substances list and its threshold planning quantities are intended to help communities focus on the substances and facilities of most immediate concern for emergency planning and response. However…

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  • Does hydrogen sulfide present in the ground count towards the TPQ and RQ?

    A petroleum company is drilling for oil contained in the ground below their facility. Would the hydrogen sulfide present in the ground be counted toward the threshold planning quantity (TPQ) for this extremely hazardous substance (EHS) under Section 302? Also, if there is a reportable release of this EHS above…

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  • Calculating vulnerability zone distances for EHSs in solutions

    When calculating vulnerability zone distances, how would the quantity released (QR) be handled for an extremely hazardous substance (EHS) in solution? If the EHS is in solution, a facility can make a rough estimate of the QR using equation (1) on page G-2 of the "Technical Guidance for Hazards Analysis."…

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  • Threshold planning quantity (TPQ) for a non-reactive extremely hazardous substance (EHS) solid handled both as a solution and as a powder

    How does a facility apply the threshold planning quantity (TPQ) for a non-reactive extremely hazardous substance (EHS) solid that is handled both as a solution and as a powder? Facilities that handle both the powdered and solution forms of a particular non-reactive solid EHS will have to consider the quantities…

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  • Will LEPCs impose significant requirements on small businesses?

    Will the local emergency planning committees impose significant requirements on small businesses? Will EPA clarify the information requirements in the emergency planning guidance and in the rulemaking? The Agency's small business analysis does not indicate that emergency planning requirements will cause a significant burden to small facilities. Small facilities are…

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  • Section 302 notification requirements for transportation of EHSs

    How do Section 302 notification requirements apply to transportation of an extremely hazardous substance (EHS)? Although Section 302 reporting requirements do not apply to the transportation of any EHS, including transportation by pipeline, or storage of EHS under active shipping papers, transportation activities within a community should be addressed in…

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  • Criteria used by Regional Response Teams to review emergency plans

    Title III states that the Regional Response Teams (RRTs) "may" review and comment upon an emergency plan. What criteria will the RRT use for reviewing these plans? The National Response Team (NRT) published the Hazardous Materials Emergency Planning Guide in which Appendix D: Criteria for Assessing State and Local Preparedness…

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  • Are on-site contractors responsible for EHSs brought on-site?

    For Section 302 purposes, if a contractor brings an extremely hazardous substance (EHS) on-site to a facility over the threshold planning quantity, is the owner/operator of the facility or the contractor required to make the notification to the LEPC? For Section 304 purposes, if a contractor bursts a tank at…

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