Click here for summary of EPA and Court actions on EPCRA reporting for farms.
On February 1, 2108 the U.S. Court of Appeals for the D.C. Circuit extended a stay of air emissions reporting from livestock wastes through at least May 1, 2018.
Showing posts with label EPCRA. Show all posts
Showing posts with label EPCRA. Show all posts
Friday, February 2, 2018
Deadline For Report Air Releases From Farms Extended
In April 2017, the D.C. Circuit Court ruled that farms were required to report air releases of hazardous substances above certain thresholds under the Clean Air Act and EPCRA. EPA released guidance on those reporting obligations in November 2017. EPA requested a stay of 90 days to provide the agency additional time to prepare for any reporting obligations, cited a need for more time to refine guidance to industry on meeting the reporting obligations and to finalize agriculture-specific forms that would be used to report emissions from animal wastes to EPA.
Click here for summary of EPA and Court actions on EPCRA reporting for farms.
On February 1, 2108 the U.S. Court of Appeals for the D.C. Circuit extended a stay of air emissions reporting from livestock wastes through at least May 1, 2018.
Click here for summary of EPA and Court actions on EPCRA reporting for farms.
On February 1, 2108 the U.S. Court of Appeals for the D.C. Circuit extended a stay of air emissions reporting from livestock wastes through at least May 1, 2018.
Sunday, November 26, 2017
MinnesotaToxic Pollution Prevention Plan Update Due January 1, 2018
The Minnesota Toxic Pollution Prevention Act (TPPA) requires facilities that report toxic chemical releases under EPCRA 313 to prepare a Pollution Prevention Plan (P2 Plan) for chemicals reported on EPA Form R. In addition to submitting their EPA Form R to the Environmental Protection Agency (EPA) and the Minnesota Emergency Planning and Community Right-to-Know Act (EPCRA) Program, TRI reporting sites must prepare a Pollution Prevention Plan and to submit annual Pollution Prevention Progress Reports based on those plans to the Minnesota EPCRA Program.
There are two reoccurring P2 requirements for TRI reporting sites in Minnesota:
The Pollution Prevention Plan and Progress Report do not apply to chemicals that are not required to be reported on EPA Form R, are reported on EPA Form A, or are reported on EPA Form R but have no on-site release or off-site transfer amounts.
Click here for more information and regulatory updates on EPCRA reporting.
There are two reoccurring P2 requirements for TRI reporting sites in Minnesota:
- Annual P2 Progress Report - due with TRI report on July 1, and
- Biennial Update to Pollution Prevention (P2) Plan - due by Jan 1 for each odd-numbered year (update required in 2017 must be completed by January 1, 2018)
The Pollution Prevention Plan and Progress Report do not apply to chemicals that are not required to be reported on EPA Form R, are reported on EPA Form A, or are reported on EPA Form R but have no on-site release or off-site transfer amounts.
Click here for more information and regulatory updates on EPCRA reporting.
Sunday, November 5, 2017
Certified Environmental and Safety Audit in Raleigh
Caltha LLP Project Summary
Project: Multimedia EH&S Compliance AuditClient: National Corporation
Location(s): Raleigh-Durham Region, North Carolina
Key Elements: EH&S audit, hazardous waste, air permit, hazardous material storage, wastewater permit, hazard communication
Overview: Caltha staff conducted a multimedia environmental, health and safety audit of this industrial facility located in Raleigh-Durham Region. The scope of the audit included:
- EPCRA
- Hazardous and Solid Waste Management- 15A NCAC 13B
- Current NC Air Permit
- NC Air Pollution Control Rule – NCAC 15A-2D
- Current wastewater discharge permit
- TSCA
- Tanks
- Hazard communication
- DOT Hazardous material transportation
Click here to review other example Caltha EH&S auditing projects. Click here to review other Caltha projects in North Carolina and NC regulatory updates.
Friday, July 21, 2017
Chicago Multimedia Compliance Audit For Manufacturing Plant
Caltha LLP Project Summary
Project: HSE Compliance Audit
Client: High Tech Manufacturer
Location(s): Chicago, Illinois
Key Elements: EH&S audit, hazardous waste, air permit, hazardous material storage, wastewater permit, PPE assessment, hazard communication
Overview: Caltha LLP conducted a multimedia environmental, health and safety audit of this manufacturing facility located in Cook County. The scope of the audit included:
- EPCRA
- Hazardous and Solid Waste Management
- Current IEPA Air Permit
- Cook County Air Emission Ordinance
- Current wastewater discharge permit
- TSCA
- Tanks
- Hazard communication
- DOT Hazardous material transportation
The audit was led by a IIA-certified professional auditor.
For more information on Caltha LLP services, go to the Caltha Contact Page
Saturday, January 14, 2017
Changes To Toxic Release Inventory Reporting Chemicals In 2017
On November 28, 2016, the USEPA published a final rule that adds a HBCD category to the TRI list of reportable chemicals. The HBCD category includes two CASRNs:
•3194-55-6 (1,2,5,6,9,10-HBCD) and
•25637-99-4 (HBCD).
•3194-55-6 (1,2,5,6,9,10-HBCD) and
•25637-99-4 (HBCD).
Since the HBCD category meets the TRI criteria for a persistent bioaccumulative toxic (PBT) chemical, USEPA established a reporting threshold of 100 lbs for the category.
The rule was effective November 30, 2016, and applies to the 2017 reporting year with the first reports due by July 1, 2018.
On November 16, 2016, the USEPA published a proposed rule to add a NPE category, which contains thirteen NPEs, to the TRI list of reportable chemicals. NPEs are nonionic surfactants used in adhesives, wetting agents, emulsifiers, stabilizers, dispersants, defoamers, cleaners, paints, and coatings. If finalized as proposed, facilities required to report NPEs included in the new category would file just one TRI report form for the covered NPEs.
Toxic Release Inventory reports for calendar year 2016 are due by July 1, 2016
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
Sunday, December 25, 2016
Tier II Hazardous Material Reporting in Wisconsin | When Are Tier 2 Reports Due?
EPCRA 302/311/312 reports (“Tier II Reports”) are due on an annual basis to the State and Local Emergency Planning Committee and local emergency response agencies, such as the fire department. The information provided is used in the evident of an emergency, such as a fire, to evaluate potential chemical and other hazards at the property, and to select appropriate protection equipment and fire fighting techniques. EPCRA reporting facilities disclose the types, quantities and locations of hazardous materials. Facilities also provide with Safety Data Sheets for each material.
There are separate reporting requirement for hazardous materials (any material that requires a Safety Data Sheet under OSHA rules) and Extremely Hazardous Substances (EHS) which are a specific chemicals listed by US EPA. A very common example of one such EHS is sulfuric acid.
When are Tier II reports due in Wisconsin?
The Tier 2 report is due March 1 of each year and is based on chemicals stored at your site during the previous calendar year. Reporting can be completed by using the Wisconsin Hazmat Online Planning and Reporting System.
Caltha LLP provides technical support to facilities in Wisconsin that submit reports under EPCRA 311 and EPCRA 312. Click here for a summary of some recent changes to EPCRA Tier II reporting requirements
For more information or to request a quote go to:
Caltha LLP EH&S Compliance Support Services
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
Monday, November 16, 2015
Tier 2 Reporting Under EPCRA 311 and 312 and Local Hazardous Material Reporting Regulations
With the end of the year approaching, many facilities will soon be reviewing the hazardous chemicals they store on-site to determine if they exceed the thresholds for Tier 2 reporting under EPCRA 312 (40 CFR 370) and equivalent State regulations. Local emergency response agencies can have additional hazardous chemical reporting requirements, in addition to Tier 2 reports.
The EPA rules that determine reporting requirements set out two options for determining thresholds.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
Click here to review example Caltha projects for EPCRA and other compliance reporting support.
The EPA rules that determine reporting requirements set out two options for determining thresholds.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
Click here to review example Caltha projects for EPCRA and other compliance reporting support.
Wednesday, March 13, 2013
Ortho Nitrotoluene Proposed For Be Added To List Of EPCRA TRI Chemicals
EPA is proposing to add ortho-nitrotoluene (o-nitrotoluene) to the list of chemicals subject to reporting under section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) and section 6607 of the Pollution Prevention Act (PPA). o-Nitrotoluene has been classified by the National Toxicology Program in their 12th Report on Carcinogens as "reasonably anticipated to be a human carcinogen." EPA believes that o-nitrotoluene meets the EPCRA section 313(d)(2)(B) criteria because it can reasonably be anticipated to cause cancer in humans. Based on EPA’s review of the available production and use information, the agency believes that o-nitrotoluene is expected to be manufactured, processed, or otherwise used in quantities that would exceed the EPCRA section 313 reporting thresholds.
Comments on the proposed addition of o-Nitrotoluene to the list of TRI chemicals must be received on or before May 13, 2013.
Caltha LLP provides specialized expertise to clients nationwide in the preparing and submitting annual toxic release inventory reports, and preparing cost-effective chemical tracking procedures.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
Comments on the proposed addition of o-Nitrotoluene to the list of TRI chemicals must be received on or before May 13, 2013.
Caltha LLP provides specialized expertise to clients nationwide in the preparing and submitting annual toxic release inventory reports, and preparing cost-effective chemical tracking procedures.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
Wednesday, March 6, 2013
Petition To Remove Acetonitrile From TRI Reporting Requirements Denied By EPA
EPA has announced that it is denying a petition to remove acetonitrile from the list of chemicals subject to reporting requirements under section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) and section 6607 of the Pollution Prevention Act of 1990 (PPA). EPA reviewed the available data on this chemical and determined that acetonitrile does not meet the deletion criterion of EPCRA section 313(d)(3), specifically due to its potential human health impacts.
EPCRA section 313(d) authorizes EPA to add or delete chemicals from the list and sets criteria for these actions. EPA may add a chemical to the list if any of the listing criteria in Section 313(d)(2) are met. To remove a chemical from the list, EPCRA requires that EPA demonstrate that none of the listing criteria are met. The EPCRA section 313(d)(2) criteria are:
(A) The chemical is known to cause or can reasonably be anticipated to cause significant adverse acute human health effects at concentration levels that are reasonably likely to exist beyond facility site boundaries as a result of continuous, or frequently recurring, releases.
(B) The chemical is known to cause or can reasonably be anticipated to cause cancer or teratogenic effects, or other serious or irreversible chronic health effects.
(C) The chemical is known to cause or can be reasonably anticipated to cause significant adverse effect on the environment, because of its toxicity, persistence in the environment, or tendency to bioaccumulate in the environment
Caltha LLP provides specialized expertise to clients nationwide in the providing technical assistance in preparing Toxic Release Inventory (TRI) Reports, and other environmental reporting requirements under EPCRA.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
EPCRA section 313(d) authorizes EPA to add or delete chemicals from the list and sets criteria for these actions. EPA may add a chemical to the list if any of the listing criteria in Section 313(d)(2) are met. To remove a chemical from the list, EPCRA requires that EPA demonstrate that none of the listing criteria are met. The EPCRA section 313(d)(2) criteria are:
(A) The chemical is known to cause or can reasonably be anticipated to cause significant adverse acute human health effects at concentration levels that are reasonably likely to exist beyond facility site boundaries as a result of continuous, or frequently recurring, releases.
(B) The chemical is known to cause or can reasonably be anticipated to cause cancer or teratogenic effects, or other serious or irreversible chronic health effects.
(C) The chemical is known to cause or can be reasonably anticipated to cause significant adverse effect on the environment, because of its toxicity, persistence in the environment, or tendency to bioaccumulate in the environment
Caltha LLP provides specialized expertise to clients nationwide in the providing technical assistance in preparing Toxic Release Inventory (TRI) Reports, and other environmental reporting requirements under EPCRA.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
Monday, December 10, 2012
Rules For NP and NPE Under TSCA and EPCRA 313
EPA has initiated rulemaking to restrict the use of nonylphenol (NP) and its ethoxylates (NPEs) under a proposed significant new use rule (SNUR) using existing Toxic Substances Control Act (TSCA) authority and under the Emergency Preparedness and Community Right-to-Know Act (EPCRA). EPA plans to issue the proposal in the next year. NP and NPEs are used in industrial laundry detergents, oil spill dispersants, personal care products, industrial soaps, and other products, but the agency has raised concerns that the chemicals are highly toxic to aquatic life, environmentally persistent, moderately bioaccumulative and potential endocrine disruptors.
As part of the action plan, EPA is working with the industrial laundry industry to phase out that use of the chemicals by the end of 2014. The action plan also says the agency intends to encourage manufacturers of all NPE-containing direct-release products, such as firefighting gels and foams, dust-control agents and de-icers, to move to NPE-free formulations. Earlier this year the agency released an alternatives assessment for NP and NPEs through its Design for the Environment program that identified eight safer alternatives. The TSCA section 5 SNUR would serve as the next step under EPA's action plan, complementing the phaseout by restricting industry from reintroducing the chemical in new applications.
The SNUR would require persons who intend to manufacture, import, or process certain NP and NPE chemicals for an activity that is designated as a significant new use by the proposed rule to notify EPA at least 90 days before commencing that activity. The notification would provide EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs to prevent unreasonable risk to human health or the environment.
The action plan also indicates EPA may add the chemicals to its EPCRA Section 313 Toxics Release Inventory (TRI) list, and has proposed under TSCA section 5(b)(4) to put NPs and NPEs on a list of chemicals that present or may present an unreasonable risk of injury to health or the environment. The chemicals-of-concern list alone would have no regulatory consequences or trigger a rule.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
As part of the action plan, EPA is working with the industrial laundry industry to phase out that use of the chemicals by the end of 2014. The action plan also says the agency intends to encourage manufacturers of all NPE-containing direct-release products, such as firefighting gels and foams, dust-control agents and de-icers, to move to NPE-free formulations. Earlier this year the agency released an alternatives assessment for NP and NPEs through its Design for the Environment program that identified eight safer alternatives. The TSCA section 5 SNUR would serve as the next step under EPA's action plan, complementing the phaseout by restricting industry from reintroducing the chemical in new applications.
The SNUR would require persons who intend to manufacture, import, or process certain NP and NPE chemicals for an activity that is designated as a significant new use by the proposed rule to notify EPA at least 90 days before commencing that activity. The notification would provide EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs to prevent unreasonable risk to human health or the environment.
The action plan also indicates EPA may add the chemicals to its EPCRA Section 313 Toxics Release Inventory (TRI) list, and has proposed under TSCA section 5(b)(4) to put NPs and NPEs on a list of chemicals that present or may present an unreasonable risk of injury to health or the environment. The chemicals-of-concern list alone would have no regulatory consequences or trigger a rule.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
Monday, July 23, 2012
New EPCRA Tier I and Tier II Reporting Requirements
In the July 13, 2012 final rule, US EPA has added new reporting requirements to Tier I and Tier II reporting forms it believes will be helpful for state and local agencies to develop or modify their community emergency response plans EPA is adding new data elements and revising existing data elements on the Emergency and Hazardous Chemical Inventory Forms under Section 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA). In addition, EPA is revising the chemical reporting section of the Tier II inventory form to make reporting easier for facilities and make the form more user-friendly for state and local officials.
The rule will take effect on January 1, 2014.
Under EPCRA Section 312, if a facility has hazardous chemicals at or above the reporting threshold specified at 40 CFR Part 370, the facility owner or operator is required to submit an emergency and hazardous chemical inventory form (either Tier I or Tier II) to the State Emergency Response Commission (SERC), the local emergency planning committee (LEPC), and the local fire department by March 1 each year. The Tier I reporting form requires facilities to report on the general types and locations of hazardous chemicals present at the facility. Tier II inventory forms require facilities to report specific information on the amounts and locations of hazardous chemicals present at the facility. Currently, all states require facilities to submit the federal Tier II inventory form or a state equivalent form.
What is the difference between Tier 1 EPCRA Report Forms and Tier 2 EPCRA Report Forms?
Read about State EPCRA Tier II Reporting support services
EPA will now require facilities to report their latitude and longitude as well as the identification numbers assigned under the Toxic Release Inventory (TRI) program and the risk management program. Also, they will be required to indicate whether chemicals are stored at a manned or unmanned location. Another change involves reporting on the number of occupants that are expected to be in the facility at any one time rather than the maximum number of employees. EPA decided to allow facilities the option of including the facility phone number on the revised forms, as well as contact information for the facility parent company. However, facilities will be required to provide emergency contact information.
Facilities must now indicate if they are subject to EPCRA Section 302 and Clean Air Act Section 112(r), also known as the Risk Management Program.
The final rule adds separate data fields for reporting pure chemical and mixtures in the chemical reporting section of the Tier II inventory form along with a new requirement to provide a description for the storage types and conditions. The rule revises the Tier II inventory form for facilities to report any additional state or local reporting requirements or to voluntarily report hazardous chemicals below the reporting thresholds.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
The rule will take effect on January 1, 2014.
Under EPCRA Section 312, if a facility has hazardous chemicals at or above the reporting threshold specified at 40 CFR Part 370, the facility owner or operator is required to submit an emergency and hazardous chemical inventory form (either Tier I or Tier II) to the State Emergency Response Commission (SERC), the local emergency planning committee (LEPC), and the local fire department by March 1 each year. The Tier I reporting form requires facilities to report on the general types and locations of hazardous chemicals present at the facility. Tier II inventory forms require facilities to report specific information on the amounts and locations of hazardous chemicals present at the facility. Currently, all states require facilities to submit the federal Tier II inventory form or a state equivalent form.
What is the difference between Tier 1 EPCRA Report Forms and Tier 2 EPCRA Report Forms?
Read about State EPCRA Tier II Reporting support services
EPA will now require facilities to report their latitude and longitude as well as the identification numbers assigned under the Toxic Release Inventory (TRI) program and the risk management program. Also, they will be required to indicate whether chemicals are stored at a manned or unmanned location. Another change involves reporting on the number of occupants that are expected to be in the facility at any one time rather than the maximum number of employees. EPA decided to allow facilities the option of including the facility phone number on the revised forms, as well as contact information for the facility parent company. However, facilities will be required to provide emergency contact information.
Facilities must now indicate if they are subject to EPCRA Section 302 and Clean Air Act Section 112(r), also known as the Risk Management Program.
The final rule adds separate data fields for reporting pure chemical and mixtures in the chemical reporting section of the Tier II inventory form along with a new requirement to provide a description for the storage types and conditions. The rule revises the Tier II inventory form for facilities to report any additional state or local reporting requirements or to voluntarily report hazardous chemicals below the reporting thresholds.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
Thursday, May 24, 2012
Severe Weather Emergency Procedures To Minimize Releases
In advance of hurricane season, U.S. Environmental Protection Agency (EPA)has issued a Hazardous Weather Release Prevention and Reporting alert to remind facility operators of certain regulations that require minimization of chemical releases during process shutdown operations. This alert is designed to increase awareness among facility operators about their obligation to operate facilities safely and report chemical releases in a timely manner.
The alert specifies operational release minimization requirements and clarifies reporting requirements, including exemptions. Unlike some natural disasters, the onset of a hurricane is predictable and allows for early preparations to lessen its effect on a facility. Before hurricane force winds and associated storm surge flooding damage industrial processes, the alert recommends that operators take preventive action by safely shutting down processes, or otherwise operate safely under emergency procedures.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website
The alert specifies operational release minimization requirements and clarifies reporting requirements, including exemptions. Unlike some natural disasters, the onset of a hurricane is predictable and allows for early preparations to lessen its effect on a facility. Before hurricane force winds and associated storm surge flooding damage industrial processes, the alert recommends that operators take preventive action by safely shutting down processes, or otherwise operate safely under emergency procedures.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website
Saturday, January 28, 2012
EPCRA 312 Tier II Reports Due March 1, 2012
EPCRA Tier II Hazardous Chemical Storage Reports are due March 1 for sites subject to hazardous chemical reporting. Under the Federal Emergency Planning and Community Right-to-Know Act (EPCRA), any facility that stores hazardous chemicals can have both one-time and annual reporting, specified in Section 311 and 312 of EPCRA. Under EPCRA, hazardous chemicals are any substances for which a facility must maintain a Material Safety Data Sheet (MSDS) under the OSHA Hazard Communication Standard – if a material has an MSDS, it is considered to be a hazardous chemical under EPCRA. This can include materials which might not immediately be considered “chemicals”, such as batteries, fuels, metals, etc.
EPCRA rules apply to all types of sites, and are not limited to a particular industrial sector – reporting sites can be commercial, institutional, warehousing, retail or any other type of site which could store or use chemicals. Facilities with chemicals in quantities that equal or exceed the thresholds must report. The thresholds can be specific to different types of chemicals and can be as low as 500 pounds for some materials, and as high as 10,000 pounds.
As an overview, to comply with EPCRA hazardous chemical storage reporting requirements, for any hazardous chemical used or stored on-site above threshold amounts, facilities must maintain a MSDS, and submit the MSDSs to their State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and local fire department. Over time, if the site recieves revised MSDS, most current MSDS must also be submitted. Facilities must also report an annual inventory of these chemicals by March 1 of each year to their SERC, LEPC and local fire department. Under the Federal rule, facilities could provide a report using either a Tier I or Tier II form. However, in practice most States require the Tier II form be used.
Request information on EPCRA Reporting consultant services
FAQ: How are Tier I and Tier II reports different?
Caltha LLP provides specialized expertise to clients nationwide in the preparation and submittal of chemical storage reports, preparation of Toxic Release Inventory (TRI) reports, and preparing cost-effective EH&S management programs.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website
EPCRA rules apply to all types of sites, and are not limited to a particular industrial sector – reporting sites can be commercial, institutional, warehousing, retail or any other type of site which could store or use chemicals. Facilities with chemicals in quantities that equal or exceed the thresholds must report. The thresholds can be specific to different types of chemicals and can be as low as 500 pounds for some materials, and as high as 10,000 pounds.
As an overview, to comply with EPCRA hazardous chemical storage reporting requirements, for any hazardous chemical used or stored on-site above threshold amounts, facilities must maintain a MSDS, and submit the MSDSs to their State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and local fire department. Over time, if the site recieves revised MSDS, most current MSDS must also be submitted. Facilities must also report an annual inventory of these chemicals by March 1 of each year to their SERC, LEPC and local fire department. Under the Federal rule, facilities could provide a report using either a Tier I or Tier II form. However, in practice most States require the Tier II form be used.
Request information on EPCRA Reporting consultant services
FAQ: How are Tier I and Tier II reports different?
Caltha LLP provides specialized expertise to clients nationwide in the preparation and submittal of chemical storage reports, preparation of Toxic Release Inventory (TRI) reports, and preparing cost-effective EH&S management programs.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website
Thursday, January 5, 2012
Summary Of TRI Chemical Release Data For 2010
The U.S. Environmental Protection Agency (EPA) is releasing its annual national analysis of the Toxics Release Inventory (TRI), for reporting year 2010. Total releases including disposals for the latest reporting year, 2010, are higher than the previous two years but lower than 2007 and prior year totals.
The 2010 TRI data show that 3.93 billion pounds of toxic chemicals were released into the environment nationwide, a 16 % increase from 2009. The increase is mainly due to changes in the metal mining sector, which typically involves large facilities handling large volumes of material. In this sector, even a small change in the chemical composition of the ore being mined may lead to big changes in the amount of TRI chemicals reported nationally. Several other sectors also reported increases in toxic releases in 2010, including the chemical and primary metals industries.
Total air releases decreased 6 % compared to 2009, continuing a trend seen over the past several years. Releases into surface water increased 9 % and releases into land increased 28 % compared 2009, again due primarily to the metal mining sector.
TRI data is submitted annually to EPA and states by numerous industry sectors including manufacturing, metal mining, electric utilities, and commercial hazardous waste facilities. Facilities must report their toxic chemical releases to EPA under the federal Emergency Planning and Community Right-to-Know Act (EPCRA) by July 1st of each year. The Pollution Prevention Act of 1990 also requires information on waste management activities related to TRI chemicals.
The 2010 TRI data show that 3.93 billion pounds of toxic chemicals were released into the environment nationwide, a 16 % increase from 2009. The increase is mainly due to changes in the metal mining sector, which typically involves large facilities handling large volumes of material. In this sector, even a small change in the chemical composition of the ore being mined may lead to big changes in the amount of TRI chemicals reported nationally. Several other sectors also reported increases in toxic releases in 2010, including the chemical and primary metals industries.
Total air releases decreased 6 % compared to 2009, continuing a trend seen over the past several years. Releases into surface water increased 9 % and releases into land increased 28 % compared 2009, again due primarily to the metal mining sector.
TRI data is submitted annually to EPA and states by numerous industry sectors including manufacturing, metal mining, electric utilities, and commercial hazardous waste facilities. Facilities must report their toxic chemical releases to EPA under the federal Emergency Planning and Community Right-to-Know Act (EPCRA) by July 1st of each year. The Pollution Prevention Act of 1990 also requires information on waste management activities related to TRI chemicals.
Caltha LLP provides specialized expertise to clients nationwide in the preparation of TRI reports, developing chemical tracking procedures, and preparing cost-effective EH&S management programs.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website Monday, November 7, 2011
EPA Reinstates TRI Reporting Requirements For Hydrogen Sulfide
The U.S. Environmental Protection Agency (EPA) has announced that it is reinstating Toxic Release Inventory (TRI) reporting requirements for hydrogen sulfide. Hydrogen sulfide was added to the TRI list of toxic chemicals in a final rule published on December 1, 1993. However, on August 22, 1994, EPA suspended the TRI reporting requirements for hydrogen sulfide in order to address issues that were raised by members of the regulated community regarding the information used to support the original listing decision. On February 26, 2010, EPA published a Federal Register document that provided the public with the opportunity to comment on EPA’s review of the currently available data on the human health and environmental effects of hydrogen sulfide. After consideration of public comments, EPA has concluded that the reporting requirements for hydrogen sulfide should be reinstated.
This action will be effective for the 2012 TRI reporting year. The first reports for the 2012 TRI reporting year are due from facilities by July 1, 2013.
TRI is a publicly available database that contains information on toxic chemical releases and waste management activities reported annually by certain industries and federal facilities. The purpose of today’s action is to better inform the public about toxic chemical releases in their communities and to provide the government with information for research and the potential development of regulations.
Hydrogen sulfide occurs naturally in crude petroleum, natural gas, volcanic gases, and hot springs. It can also result from the breakdown of organic matter, and is produced by human and animal wastes. Hydrogen sulfide can also result from industrial activities, such as food processing, coke ovens, kraft paper mills, tanneries, and petroleum refineries. Individuals living near a wastewater treatment plant, a gas and oil drilling operation, a farm with manure storage or livestock confinement facilities, or a landfill may be exposed to higher levels of hydrogen sulfide.
This action will be effective for the 2012 TRI reporting year. The first reports for the 2012 TRI reporting year are due from facilities by July 1, 2013.
TRI is a publicly available database that contains information on toxic chemical releases and waste management activities reported annually by certain industries and federal facilities. The purpose of today’s action is to better inform the public about toxic chemical releases in their communities and to provide the government with information for research and the potential development of regulations.
Hydrogen sulfide occurs naturally in crude petroleum, natural gas, volcanic gases, and hot springs. It can also result from the breakdown of organic matter, and is produced by human and animal wastes. Hydrogen sulfide can also result from industrial activities, such as food processing, coke ovens, kraft paper mills, tanneries, and petroleum refineries. Individuals living near a wastewater treatment plant, a gas and oil drilling operation, a farm with manure storage or livestock confinement facilities, or a landfill may be exposed to higher levels of hydrogen sulfide.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP WebsiteSunday, August 14, 2011
New EPCRA Tier I & Tier II Reporting Forms Proposed
US EPA has proposed a significant revision to the forms and types of information required to be submitted under EPCRA Tier I and Tier II. Title III of SARA (EPCRA) established authorities for emergency planning and preparedness, emergency release notification reporting, community right to-know reporting, and toxic chemical release reporting. It is intended to encourage State and local planning and preparedness for releases of extremely hazardous substances (EHSs) and to provide the public, local governments, fire departments and other emergency officials with information concerning chemical releases and the potential chemical risks in their communities.
As background, under the emergency planning provisions of EPCRA (40 CFR part 355), a facility is required to provide a one-time notification to the State Emergency Response Commission (SERC) and the local emergency planning committee (LEPC) if the facility has any EHS present at the site in excess of its threshold planning quantity (TPQ). Reporting requirements under the community right-to-know provisions, sections 311 and 312 of EPCRA are ongoing obligations. Sections 311 and 312 of EPCRA apply to owners and operators of facilities that are required to prepare or have available a material safety data sheet (MSDS) for a hazardous chemical defined under the Occupational Safety and Health Act (OSHA) Hazard Communication Standard (HCS). If the hazardous chemical is present at or above the reporting thresholds, the facility owner or operator is required to submit a MSDS to the SERC and LEPC. Under section 312 of EPCRA, if a hazardous chemical is present at or above the reporting threshold, the facility owner or operator is required to submit an emergency and hazardous chemical inventory form (Tier I or Tier II) to the SERC, LEPC and the local fire department annually by March 1.
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The Tier I and Tier II forms were first published in 1987 and were amended in
1990. Recently, State and local agencies requested that EPA modify these forms to include new data elements and revise existing data elements to make it more useful for emergency planning and response.
What is the difference between Tier I and Tier II reporting requirements under EPCRA?
One of the important changes proposed for the EPCRA Tier I and Tier II reporting forms helps clarify how quantities of EHS chemicals were determined. In a final rule published in 2008, EPA clarified how to report a hazardous chemical mixture. The facility has to aggregate all amounts of that EHS present throughout the facility in mixtures and in pure form to determine if the reporting threshold for EHS has been met or exceeded. If the reporting threshold for that EHS is exceeded, then the facility would have an option to report the mixture or the EHS component.
The current Tier I and Tier II reporting form requires facilities to report the name of the mixture, indicate whether the mixture contains an EHS, indicate the physical and health hazards of the mixture, and report the amount present on-site, as well as the type of storage and storage locations. The regulated community and the state and local agencies, however, are unsure if the amount present on-site refers to the mixture or the non-EHS hazardous chemical or the EHS in the mixture. In order to clarify the reporting of pure chemicals vs. mixtures, the proposed Tier II form has separate entries for mixtures and pure chemicals.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website
As background, under the emergency planning provisions of EPCRA (40 CFR part 355), a facility is required to provide a one-time notification to the State Emergency Response Commission (SERC) and the local emergency planning committee (LEPC) if the facility has any EHS present at the site in excess of its threshold planning quantity (TPQ). Reporting requirements under the community right-to-know provisions, sections 311 and 312 of EPCRA are ongoing obligations. Sections 311 and 312 of EPCRA apply to owners and operators of facilities that are required to prepare or have available a material safety data sheet (MSDS) for a hazardous chemical defined under the Occupational Safety and Health Act (OSHA) Hazard Communication Standard (HCS). If the hazardous chemical is present at or above the reporting thresholds, the facility owner or operator is required to submit a MSDS to the SERC and LEPC. Under section 312 of EPCRA, if a hazardous chemical is present at or above the reporting threshold, the facility owner or operator is required to submit an emergency and hazardous chemical inventory form (Tier I or Tier II) to the SERC, LEPC and the local fire department annually by March 1.
Request information on EPCRA reporting support services provided by Caltha
The Tier I and Tier II forms were first published in 1987 and were amended in
1990. Recently, State and local agencies requested that EPA modify these forms to include new data elements and revise existing data elements to make it more useful for emergency planning and response.
What is the difference between Tier I and Tier II reporting requirements under EPCRA?
One of the important changes proposed for the EPCRA Tier I and Tier II reporting forms helps clarify how quantities of EHS chemicals were determined. In a final rule published in 2008, EPA clarified how to report a hazardous chemical mixture. The facility has to aggregate all amounts of that EHS present throughout the facility in mixtures and in pure form to determine if the reporting threshold for EHS has been met or exceeded. If the reporting threshold for that EHS is exceeded, then the facility would have an option to report the mixture or the EHS component.
The current Tier I and Tier II reporting form requires facilities to report the name of the mixture, indicate whether the mixture contains an EHS, indicate the physical and health hazards of the mixture, and report the amount present on-site, as well as the type of storage and storage locations. The regulated community and the state and local agencies, however, are unsure if the amount present on-site refers to the mixture or the non-EHS hazardous chemical or the EHS in the mixture. In order to clarify the reporting of pure chemicals vs. mixtures, the proposed Tier II form has separate entries for mixtures and pure chemicals.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website
Wednesday, July 6, 2011
Proposed Expansion of TRI Reporting Industry Sectors
EPA has announced a proposed rule would expand the scope of industry sectors covered by Emergency Planning and Community Right-to-Know Act (EPCRA) section 313, also known as the Toxics Release Inventory (TRI).
As originally enacted, EPCRA 313 applied only to the manufacturing industry sectors. The statute, however, also allows the EPA Administrator to add sectors to TRI to the extent that doing so is relevant to the purposes of EPCRA 313. Under this authority, the EPA in 1997 added seven additional industry sectors to the list of sectors covered by TRI. The current proposed rule would add or expand coverage to the following industry sectors:
As originally enacted, EPCRA 313 applied only to the manufacturing industry sectors. The statute, however, also allows the EPA Administrator to add sectors to TRI to the extent that doing so is relevant to the purposes of EPCRA 313. Under this authority, the EPA in 1997 added seven additional industry sectors to the list of sectors covered by TRI. The current proposed rule would add or expand coverage to the following industry sectors:
- Iron Ore Mining,
- Phosphate Mining,
- Municipal Waste Incineration,
- Industrial Dry Cleaning,
- Petroleum Bulk Storage, and
- Steam-Only Production from Fossil Fuels.
EPA currently expects to publish a Notice of Proposed Rule Making (NPRM) in the Federal Register around December 2012.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.
For further information contact Caltha LLP at
or
Wednesday, February 16, 2011
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.
For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website
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.
For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website
Thursday, December 16, 2010
Toxic Release Inventory TRI Reporting Summary 2009
U.S. Environmental Protection Agency (EPA) has released its annual national analysis of the Toxics Release Inventory (TRI) for reporting year 2009. In 2009, 3.37 billion pounds of toxic chemicals were released into the environment, a 12% decrease from 2008. The analysis, which includes data on approximately 650 chemicals from more than 20,000 facilities, found that total releases to air decreased 20% since 2008, and releases to surface water decreased 18%, and to land 4% since 2008.
The EPA analysis shows decreases in the releases of persistent, bioaccumulative, and toxic (PBT) chemicals including lead, dioxin, and mercury. Total disposal or other releases of mercury decreased 3% and total disposal or other releases of both dioxin and lead decreased by 18%. Seven percent few facilities reported to TRI from the previous year, continuing a trend from the past few years.
EPA added 16 chemicals to the TRI list of reportable chemicals in November. [read more about new chemicals added to TRI reporting] These chemicals are reasonably anticipated to be human carcinogens, and represent the largest chemical expansion of the program in a decade. Data on the new TRI chemicals will be reported by facilities on July 1, 2012.
info@calthacompany.com or Caltha LLP Website
The EPA analysis shows decreases in the releases of persistent, bioaccumulative, and toxic (PBT) chemicals including lead, dioxin, and mercury. Total disposal or other releases of mercury decreased 3% and total disposal or other releases of both dioxin and lead decreased by 18%. Seven percent few facilities reported to TRI from the previous year, continuing a trend from the past few years.
EPA added 16 chemicals to the TRI list of reportable chemicals in November. [read more about new chemicals added to TRI reporting] These chemicals are reasonably anticipated to be human carcinogens, and represent the largest chemical expansion of the program in a decade. Data on the new TRI chemicals will be reported by facilities on July 1, 2012.
Caltha LLP provides specialized expertise to clients nationwide in the preparation of EPCRA 313 Toxic Release Inventory reports, developing chemical tracking procedures, and preparing cost-effective EH&S management programs.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website
Wednesday, December 15, 2010
Saccharin Removed From CERCLA List of Hazardous Substances
U.S. Environmental Protection Agency (EPA) has removed saccharin, a common artificial sweetener, and its salts from the list of hazardous substances. Saccharin was a listed CERCLA hazardous substance and had a reportable quantity (RQ) of 100 pounds; saccharin is also listed as a chemical subject to EPCRA 313 (SARA 313) toxic release inventory (TRI) reporting.
Saccharin was labeled a potentially cancer-causing substance in the 1980s. In the late 1990s, the National Toxicology Program and the International Agency for Research on Cancer re-evaluated the available scientific information on saccharin and its salts and concluded that it is not a potential human carcinogen. Because the scientific basis for remaining on EPA’s lists no longer applies, the agency has removed saccharin and its salts from its lists.
EPA proposed the removal of saccharin and its salts from the lists on April 2010 and did not receive any comments opposing the proposal.
Saccharin was labeled a potentially cancer-causing substance in the 1980s. In the late 1990s, the National Toxicology Program and the International Agency for Research on Cancer re-evaluated the available scientific information on saccharin and its salts and concluded that it is not a potential human carcinogen. Because the scientific basis for remaining on EPA’s lists no longer applies, the agency has removed saccharin and its salts from its lists.
EPA proposed the removal of saccharin and its salts from the lists on April 2010 and did not receive any comments opposing the proposal.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.
For further information contact Caltha LLP at
or
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