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  • Why does EPA recommend submitting a list for EPCRA 311?

    Why does EPA recommend submitting a list rather than Material Safety Data Sheets (MSDS) to meet the requirements of Section 311? Lists will minimize the paperwork burden for state and local governments and local fire departments. In addition, the list can be used as an index to inventory forms required…

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  • Facilities that close during a reporting year

    A facility storing hazardous chemicals on site permanently ceases operations and notifies the State Emergency Response Commission (SERC). Since the facility will no longer be in operation on March 1 of the following year, must the owner/operator of the closed facility submit a Tier I or Tier II hazardous chemical…

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  • Recommended approach for reporting lead acid batteries when complying with Tier II reporting

    Does EPA have a standard or recommended reporting approach for lead acid batteries when complying with EPCRA Section 312 Chemical Inventory Reporting (i.e., Tier II reporting)? EPA suggests that facilities report for lead acid batteries in the same manner they used when complying with EPCRA Section 311 MSDS reporting requirements…

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  • Purchases but never receives or stores a hazardous chemical over threshold amount

    If a facility purchases more than 10,000 pounds of a hazardous chemical for which OSHA requires an MSDS in a calendar year but never actually receives or stores more than the 10,000 pound threshold at one time, must the facility report under EPCRA Sections 311 and 312? The MSDS and…

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  • How are mixtures handled for Sections 311 and 312 reporting?

    The owner or operator of a facility may meet the requirements of Sections 311 and 312 by choosing one of two options: • Providing the required information on each component that is a hazardous chemical within the mixture. In this case, the concentration of the hazardous chemical in weight percent…

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  • Redoing calculations if RMP*Comp is updated

    Will RMP*Comp be updated? If so, would I have to redo calculations I might already have made with an earlier version? No, you do not have to redo your work if you have already completed your consequence analyses. RMP*Comp is based on the EPA's Offsite Consequence Analysis Guidance (OCA Guidance)…

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  • Different distances to toxic endpoints with different versions of RMP*Comp

    I've noticed that for certain chemicals, RMP*Comp gives substantially different distances to the toxic endpoint than previous versions. Why? In the current version of RMP*Comp, we have incorporated new chemical-specific distance tables for ammonia, chlorine, and sulfur dioxide. The generic tables are still used for other chemicals (you can see…

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  • Distance to endpoint calculations used by RMP*Comp

    Does RMP*Comp perform some math or modelling in order to arrive at an endpoint distance, or is it simply interpolating from the tables in the EPA's Offsite Consequence Analysis Guidance (OCA Guidance)? RMP*Comp follows the procedures set out in the OCA Guidance . This means that for some scenarios, the…

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  • EPCRA 312 Back Reporting for Previous Years

    Facilities subject to EPCRA section 312 (40 CFR part 370) must submit an inventory form annually to the state emergency response commission (SERC), local emergency planning committee (LEPC), and local fire department. Do facilities have to report for previous years if they were subject to hazardous chemical inventory reporting but…

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  • EPCRA 311 / 312 Applicability to Brine / Salt Solutions

    Are facilities required to prepare or have available a material safety data sheet/safety data sheet (MSDS/SDS) for brine/salt solutions under the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS) ( 29 CFR 1910.1200 )? Yes, facilities are required to prepare or have available an MSDS/SDS for brine/salt solutions…

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  • Definition of Ambient Temperature for EPCRA 312 Reporting

    The Tier II Hazardous Chemical Inventory form, used to meet annual EPCRA section 312 reporting requirements, requires facility owners or operators to note whether reported hazardous chemicals are present at, above, or below ambient temperature. What is meant by ambient temperature? Ambient temperature means that the material is stored in…

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  • Electronic Submission of Tier II Inventory Information

    Pursuant to the Emergency Planning and Community Act (EPCRA) Section 312, facilities must submit by March 1st every year Tier II inventory information regarding any hazardous chemical present at their facility at any time during the previous calendar year in an amount equal to or in excess of its threshold…

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  • Does Ammonia in Ammonium Hydroxide count toward the EHS threshold for reporting under EPCRA section 312?

    A facility has 9,000 pounds of ammonium hydroxide (19 percent solution) present on site at a given time. For reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA) section 312, must the amount of ammonia in ammonium hydroxide be counted (and aggregated) towards the reporting threshold for extremely hazardous…

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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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  • Ethanol added to food / beverages and Tier II reporting (i.e., EPCRA Section 312)

    Is Ethanol (CAS# 64-17-5) that is added to foods or alcoholic beverages exempt from the Emergency Planning and Community Right-to-Know Act (EPCRA) section 312 chemical inventory (i.e., Tier I/II) reporting requirements? EPCRA Section 312 requires facility owners or operators to submit annual chemical inventory reports (Tier I/Tier II Forms) for…

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