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  • Chemicals subject to reporting (EPCRA Section 304)

    What chemicals are subject to reporting under EPCRA Section 304? Chemicals subject to Section 304 notification requirements are CERCLA hazardous substances listed under 40 CFR Table 302.4 and the extremely hazardous substances listed under 40 CFR part 355 Appendix A and B .

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  • Tank used to store ammonia to be used as both agricultural fertilizer and coolant

    Ammonia is held for sale by a retailer in a large storage tank. The retailer sells the ammonia as both an agricultural fertilizer and as a coolant for air conditioning systems. Section 311(e)(5) of EPCRA exempts from the definition of a hazardous chemical "(a)ny substance to the extent it is…

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  • Applicability of EPCRA 304 to EHSs in abandoned receptacles

    Must any amount of a listed chemical contained within abandoned or discarded barrels, containers, or other receptacles be considered to determine if a specific reportable quantity has been exceeded under the SARA Section 304 notification requirements? Section 355.61 defines a release as "any spilling, leaking, pumping, pouring, emitting emptying, discharging…

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  • Where should the Tier I form be sent and what is the deadline?

    The owner or operator subject to this reporting requirement must submit a Tier I inventory form (or the optional Tier II inventory form) for all hazardous chemicals present at the facility in excess of the established threshold to the state emergency response commission, the local emergency planning committee, and the…

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  • When and where should an air carrier report a release?

    When and where should an air carrier report a release? For instance should the release be reported to the state where the release occurred or to the airport of destination? Since aircraft should have radio communication capabilities, the report should be given to the state(s) likely to be affected by…

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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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