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TXT2, Regulated Identity, and Customer Numbers for Tier II reporting

Where can a facility find their TXT2 Number, Regulated Entity Number, and Customer Number that may be needed to complete the EPCRA Section 312 Chemical Inventory Report (i.e., Tier II report)? TXT2 Numbers, Regulated Entity Numbers, and Customer Numbers a

Storage location for batteries in forklifts when complying with Tier II reporting

As part of Tier II Chemical Inventory Reporting, a facility must provide a brief description of the precise location of the hazardous chemical at the facility (40 CFR §370.42(i)(8)(i)).  A facility is reporting forklift batteries on their annual Tier II

Recommended approach for reporting lead acid batteries when complying with Tier II reporting

Recommended approach for reporting lead acid batteries when complying with Tier II reporting

Chemicals in facility pipelines and the EPCRA transportation exemption

Section 327 of the Emergency Planning and Community Right-to-Know Act (EPCRA) exempts from any Title III reporting requirement (other than the §304 notification obligation) substances or chemicals in transportation and/or being stored incident to transport

Ethanol added to food / beverages and Tier II reporting (i.e., EPCRA Section 312)

Is Ethanol (CAS# 64-17-5) that is added to foods or alcoholic beverages exempt from EPCRA section 312 chemical inventory (i.e., Tier I/II) reporting requirements?  EPCRA Section 312 requires facility owners or operators to submit annual chemical inventor

Tier II reporting for agricultural dusts and agricultural products handled in powdered form (i.e. combustible dust)

EPCRA Section 312 requires facility owners or operators to submit annual chemical inventory reports (Tier I/Tier II Forms) for any OSHA defined hazardous chemical subject to OSHA's Hazard Communication Standard (29 CFR section 1910.1200) when present at a

CO2 in beverages and EPCRA 311 / 312 reporting

Is CO2 added to beverages covered under Section 311(e)(1) exemption? Section 311(e)(1) exempts any food, food additive, drug, or cosmetic regulated by the Food and Drug Administration (FDA).  EPA considers a substance to be regulated by the FDA as long a

Applicability of EPCRA 311 and 312 to state and local government facilities

Are state and local government facilities subject to EPCRA Sections 311 and 312 in states with OSHA-approved state plans covering those facilities? The Occupational Safety and Health Act prohibits OSHA from covering state and local government workers, unl

Are hazardous chemicals present at rail yards subject to EPCRA 311/312?

Yes, hazardous chemicals present at rail yards are subject to EPCRA Sections 311 and 312, if they are not stored incident to transportation and they are present at the rail yard in amounts equal to or in excess of the minimum thresholds in 40 CFR 370.10(a)

When does “storage incident to transportation” end?

Are hazardous chemicals stored at the destination indicated on the shipping papers considered to be storage “incident to transportation” if they will be shipped later on to another destination under new shipping papers? Section 327 of EPCRA exempts fr

Applicability of EPCRA §§302 and 304 to EHSs produced on-site

If an extremely hazardous substance is not stored on-site but is produced in a process such as incineration, is it exempt from both threshold planning quantity calculation and release reporting if the release is covered by a Clean Air Act permit? If the h

Are on-site contractors responsible for EHSs brought on-site?

For Section 302 purposes, if a contractor brings an extremely hazardous substance (EHS) on-site to a facility over the threshold planning quantity, is the owner/operator of the facility or the contractor required to make the notification to the LEPC?  F

Can states designate liquified petroleum gas facilities under Section 302

Does the statute allow the state to designate facilities which produce, use, or store certain quantities of liquified petroleum gas as emergency planning facilities?   EPA considers the designation of additional facilities to be accomplished through nam

Calculating EHS quantities within landfills

How are the quantities of the extremely hazardous substances (EHSs) to be calculated in determining if landfills are subject to the section 302 requirements? EPA realizes the practical problems presented for landfills in complying with the Title III requi

Calculating vulnerability zone distances for EHSs in solutions

When calculating vulnerability zone distances, how would the quantity released (QR) be handled for an extremely hazardous substance (EHS) in solution? If the EHS is in solution, a facility can make a rough estimate of the QR using equation (1) on page G-2