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  • Criteria for selecting alternative release scenarios

    As part of the hazard assessment, owners and operators of Program 2 and Program 3 covered processes must identify and analyze alternative release scenarios (40 CFR §68.28). What criteria should be used when selecting an alternative release scenario? The owner or operator of a stationary source subject to the risk…

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  • Use Federal Tier II Form When Claiming Trade Secret

    40 CFR Part 350 allows facilities to withhold certain chemical information when reporting under EPCRA if the facility claims those chemicals to be a trade secret. When submitting the required trade secret claim package for Tier II reports, must a facility use the federal Tier II inventory form or can…

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  • How is waste leaving the derailment site tracked?

    EPA on-scene coordinators are assigned to track liquid–and solid–waste trucks entering and leaving the derailment site. They log every truck, oversee the loading and covering of waste, truck washing and weighing, and the proper placement of placards. Responders take pictures throughout the process. All trucks go to approved and regulated…

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  • Are hazardous chemicals present at rail yards subject to EPCRA 311/312?

    Yes, hazardous chemicals present at rail yards are subject to EPCRA Sections 311 and 312, if they are not stored incident to transportation and they are present at the rail yard in amounts equal to or in excess of the minimum thresholds in 40 CFR 370.10(a). As explained in the…

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  • E-cigarette and EPCRA 311 / 312 Reporting

    Are hazardous chemicals used to make e-cigarette products considered tobacco or tobacco products and thus exempt from EPCRA sections 311 and 312 reporting requirements? No. The MSDS reporting requirements under EPCRA Section 311 and Chemical Inventory (i.e., Tier II) reporting requirement under EPCRA Section 312 apply to owners and operators…

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  • Agricultural use exemption and chemicals used for fish farming

    Sections 311 and 312 require facility owners or operators to submit Material Safety Data Sheets (MSDSs) and annual inventory reports for any hazardous chemical subject to OSHA's Hazard Communication Standard (29 CFR §1910.1200(c)) which is present at a facility above a reportable threshold (40 CFR §370.10) . An owner or…

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  • Hazardous chemicals used in animal digestors or incinerators

    Are hazardous chemicals used in equipment, such as an animal carcass digestor or incinerator, located on the grounds of a medical or veterinary facility exempt from the definition of hazardous chemical and, therefore, exempt from reporting under EPCRA Sections 311 and 312? Any substance to the extent it is used…

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  • Agricultural use exemption and fuels

    Does the agricultural use exemption, Section 311(e)(5), apply to fuels used by harvesting services to transport crops from the farm to the market or the food processor? Does the agricultural use exemption apply to the fuel used by the farmer to transport crops from the farm to the market or…

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  • EPCRA 311 / 312 Reporting Responsibility For Industrial Park Owner

    EPCRA sections 311 and 312 assign responsibility for reporting to “the owner or operator of any facility which is required to prepare or have available a material safety data sheet (MSDS) for a hazardous chemical under the Occupational Safety and Health Act (OSHA) of 1970 and regulations under that act.”…

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  • Bricks May Be Eligible for Solid and Manufactured Item Exemption for EPCRA 311 / 312 Reporting

    For safety data sheet (SDS) and Tier II inventory reporting under EPCRA Sections 311 and 312, there is an exemption for solid and manufactured items that do not have the potential for exposure under normal conditions of their use. Are bricks eligible for the solid and manufactured item exemption under…

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  • How can I get help interpreting well sampling results?

    Residents requesting Columbiana County water well sample results or assistance interpreting results taken by AECOM or Stantec laboratories can email ( [email protected] ). Additionally, a toxicologist is available to answer questions at 800-222-1222. Columbiana County residents near East Palestine with drinking water wells can request sampling by calling 330-849-3919. Pennsylvania…

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  • What’s the difference between air sampling and air monitoring?

    Air monitoring and air sampling are two different methods of looking at air quality. Air monitoring uses electronic devices to provide real-time readings of contaminants in the air. Air sampling involves trapping air over a period of time in a container that is then sent to a laboratory for analysis…

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  • How does EPA oversee cleanup at the derailment site?

    EPA leads the Unified Command consisting of different agencies to approve Norfolk Southern’s workplans and weekly activities. EPA also coordinates with other agencies to perform oversight, such as with Ohio EPA, the Columbiana County Health District, and the Pennsylvania Department of Environmental Protection. EPA and Ohio EPA personnel oversee safety…

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  • Is the air monitoring equipment detecting chemicals of concern?

    Yes, the air monitoring and sampling equipment are capable of detecting many chemicals of concern in the community and currently detections are below levels of concern. Some of the monitoring equipment may not detect a portion of the chemicals at lower levels–specifically n-butyl acrylate. However, there are independent tools used…

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  • What’s the difference between short-term and long-term chemical exposure levels?

    Acute or short-term exposure assumes that a person has been exposed to a chemical for a short period of time. Long term, also known as chronic, exposure assumes a person has been constantly exposed to a chemical for a lifetime, or approximately 70 years.

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