Fuel Conditional Exemptions From EPCRA Tier 2 Reporting

Do facilities need to report fuels stored on-site under EPCRA 311 and 312? In most cases, fuels must be considered under EPCRA 311 and 312, and must be reported on Tier I or Tier II forms if the maximum inventory during the reporting year exceeds the EPCRA reporting threshold of 10,000 pounds, or lower if an Extremely Hazardous Substance (EHS). There are some limited exceptions for fuel storage. However, these apply only to retail establishments and only to storage in underground storage tanks (USTs). For such facilities, the condition exemption applies only to two fuel types: •For gasoline at a retail gas station, the threshold level is 75,000 gallons, if storage meets some specific conditions •For diesel fuel at a retail gas station, the threshold level is 100,000 gallons, again if storage meets some specific conditions.

Caltha LLP provides specialized expertise to clients nationwide in the preparing hazardous material and chemical inventories for EPCRA Tier I and Tier II reports, preparing EPCRA 311 and EPCRA 312 reports, and preparing cost-effective chemical inventory and MSDS management programs.

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