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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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  • For 311 list reports, how are mixtures identified?

    For Section 311 reporting, how are mixtures identified if a list is submitted instead of the MSDSs? An owner or operator can comply with the requirements of Section 311 for a mixture of hazardous chemicals by providing the common or trade name of the mixture listed by hazard category or…

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  • Reporting for an EHS mixture based on a concentration range

    A facility has a mixture which contains extremely hazardous substances (EHSs). The Material Safety Data Sheet (MSDS) for the mixture only indicates a range of concentration for its components. For the purposes, of reporting under EPCRA Sections 302, 304, and 311/312 of EPCRA, should the facility owner/operator report be based…

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  • Does a facility have an option how to report a mixture containing EHS?

    Under Sections 311 and 312, when extremely hazardous substances are contained within a mixture, does a facility still have the option to report the mixture as a whole or by its hazardous components? Yes, the mixture may be reported as a whole or by its hazardous components. To determine whether…

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  • What information is required on lists submitted for Section 311?

    What is required if a list is submitted instead of the actual material safety data sheets (MSDS) under Section 311? Instead of submitting an MSDS for each hazardous chemical, the owner or operator may submit a list of the hazardous chemicals for which the MSDS is required. This list must…

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  • Updates for 311 MSDS reporting

    How would a facility report a hazardous chemical that they acquired above the reporting threshold after the October 17, 1987 deadline, for Section 311? An update must be submitted within three months anytime there is discovery of significant new information, or if an unreported hazardous chemical is present in a…

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  • Designating a facility subject to emergency planning requirements

    A natural gas distribution facility consists of a series of pipelines and breakout storage tanks. The substances stored at the facility are exempt from all applicable provisions of EPCRA (except Section 304) under the transportation exemption at Section 327. Can such a facility be designated (under the authority of Section…

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  • Can the RQ assigned to hydrochloric acid be used for hydrogen chloride gas?

    Hydrogen chloride gas is introduced into water to form hydrochloric acid. Saturation for this reaction occurs at 38 percent (%). Therefore, any hydrogen chloride present after the saturation point is reached, does not go into solution and will remain in the gaseous state. Can the reportable quantity (RQ) assigned to…

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  • Applicability determination for one chemical in different physical states

    A facility is required to keep two MSDSs on file for the same hazardous chemical (oxygen); one for the gas phase and one for liquid phase because they present different risks. Would the same chemical present at a facility in different physical states be aggregated for threshold determinations? The applicability…

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  • 311/312 - Thresholds for retail gas station with aboveground and underground tanks

    If a retail gas station stores gasoline or diesel fuel in both aboveground and underground tanks, what EPCRA thresholds do they apply to determine if they have to report gasoline or diesel fuel on their Tier I or II form? If they have to report, do they report all the…

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  • Are releases into a POTW subject to CERCLA section 103(a) reporting requirements?

    Are releases of a pollutant into a Publicly Owned Treatment Works (POTW), when the pollutant is specified in and in compliance with the pretreatment standards of the Clean Water Act, subject to CERCLA section 103(a) reporting requirements? No. The introduction of any pollutant into a POTW, when the pollutant is…

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  • Are pharmaceutical research pilot plants exempt from 311 and 312?

    A pharmaceutical research lab contains a pilot plant of its overall operation. The products manufactured in the pilot plant are not sold, but are distributed to hospitals and other health care facilities for use in continued clinical testing. Is the pilot plant exempt or must it report its hazardous chemicals…

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  • Are the quantities of different hazardous constituents additive?

    In determining whether a Reportable Quantity (RQ) has been released, are the quantities of different hazardous constituents additive under the mixture rule? No. RQs of different substances are not additive under the mixture rule; releasing a mixture containing half an RQ of one hazardous substance (other than radionuclides) and half…

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  • Emergency release notification and trade secret chemicals

    Question No. 3 of the trade secret substantiation form requires the submitter to list all local, state, and federal government entities to which the submitter has disclosed the specific chemical identity. Does the submitter need to report Section 304 emergency release notification if the submitter had a covered reportable release…

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  • CERCLA reporting requirements for compounds

    How do CERCLA reporting requirements apply to a compound if it is not individually listed but falls under a generic class of compounds? To date, the Agency has not established any RQs for the CWA broad generic classes of compounds that are CERCLA hazardous substances. Therefore, releases of substances that…

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