EMERGENCY PLANNING & COMMUNITY RIGHT-TO-KNOW ACT
The Emergency Planning & Community Right-To-Know Act (EPCRA) was passed by Congress to create a program with two basic goals:
- To increase public knowledge of and access to information on the presence of toxic chemicals in communities, releases of toxic chemicals into the environment, and waste management activities involving toxic chemicals; and,
- To encourage and support planning for responding to environmental emergencies.
To meet these goals, EPCRA created the Toxics Release Inventory (TRI) and the hazardous chemical inventory. This information enables state and local governments and the community to identify what needs to be done at the local level to better deal with pollution and chemical emergencies.
Annual reports of this information are due on March 1 of each year for Tier II reports, and July 1 for TRI reporting.
TIER II REPORTS: DUE MARCH 1
Facilities covered by EPCRA must submit an emergency and hazardous chemical inventory form to the Local Emergency Planning Commission, the State Emergency Response Commission and the local fire department. Information required for Tier II reporting includes:
- Basic facility identification information, emergency and non-emergency employee contact information, and information about chemicals stored or used at the facility;
- The chemical name or the common name as indicated on the MSDS;
- An estimate of the maximum amount of the chemical present at any time during the preceding calendar year and the average daily amount;
- A brief description of the manner of storage of the chemical;
- The location of the chemical at the facility; and
- An indication of whether the owner of the facility elects to withhold location information from disclosure to the public.
FORM R REPORTS: DUE JULY 1
Under Section 313 of EPCRA, certain businesses are required to report each year on the amounts of EPCRA Section 313 chemicals their facilities released into the environment (either routinely or as a result of accidents), or otherwise managed as waste. Reporting is required if certain threshold quantities are exceeded. Section 313 Form R reporting requires facilities to:
- Report for each listed chemical the amount released to air, water, land, underground injection and transferred off-site to disposal.
- Report the amounts of those chemicals otherwise managed as waste, including on-site treatment, combustion for energy recovery, recycling and transfers offsite for treatment, combustion for energy recovery and recycling.
AIR EMISSION SUMMARY REPORTS: DEADLINE VARIES BY STATE
Under the Clean Air Act (CAA), EPA has set limits on the quantity of a pollutant that can be in the air anywhere in the United States. The law allows individual states to manage pollution controls and to enforce more stringent requirements; however, states are not allowed to have weaker pollution controls than those set for the whole country.
Facilities with air emissions are required to submit annual air emissions summary reports for the previous calendar year due on March 31 each year. Reporting requirements for emissions inventories will vary, depending on the number of account locations and number of emissions types and quantities, but typically reports must include:
- Actual emissions of VOC, NOX, carbon monoxide (CO), sulfur dioxide (SO2), lead (Pb), particulate matter of less than 10 microns in diameter (PM10), any other contaminant subject to National Ambient Air Quality Standards set by the CAA, emissions of all hazardous air pollutants, or any other contaminant requested by the state from individual emission sources.
- Any change in operating conditions, including start-ups, permanent shut-downs of individual units, or process changes at the facility, and increases or reductions in total annual emissions.
QUESTIONS? CONTACT US
GaiaTech can assist with any questions you may have regarding your facilities' reporting requirements under the above regulations. For more information, call Cindi Mercer in Dallas at 469.385.1600, ext. 248, or Dave Buchalter in Atlanta at 404.812.0001, ext. 242.
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