“Facilities covered by The Emergency Planning and Community Right-to-Know Act (EPCRA) must submit an emergency and hazardous chemical inventory form (Tier II Report) to the LEPC, the SERC and the local fire department annually.” This report is due March 1st of each year.
The EPA currently lists over 300 Extremely Hazardous Chemicals. If you use, store or manufacture any of the listed chemicals at or above their Threshold Planning Quantity (TPQ), those chemicals must be reported in a Tier II Report. Please note – if a chemical does not meet its TPQ, but you manufacture, use or store over 500 pounds in weight at your facility, it also must be disclosed in a Tier II Report. In addition, ALL other chemicals have a TPQ of 10,000 pounds, and if you use, store or manufacture these chemicals in quantities greater than 10,000 pounds at your facility, they must also be reported.
If a chemical meets its TPQ, an Emergency Planning Document must also be prepared.
It is important to note the standard of measurement for these chemicals is pounds, not gallons. Items easily overlooked are Compressed Gases (propane, nitrogen, oxygen) which may weigh over 10 pounds per gallon; Forklift Batteries contain battery acid and approximately 18% of the total weight of a battery, in some cases one battery could reach the 500 pound threshold.
You may already have the necessary documents by another name. If you have a Spill Prevention Plan certified by a professional engineer it would meet the requirement for over 10,000 pounds (1,320 gallons) of petroleum products. An RCRA Contingency Plan, developed for hazardous waste, may meet the requirement if modified.
We do an on-site inspection, prepare all necessary cover letters and documentation, including a chemical list and site diagram. If needed, we also prepare an Emergency Planning Document for your facility.
For the 2015 annual reporting we completed over 125 reports.