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EPCRA Reports Due by March 1, 2019

 

Tier 2 Emergency and Hazardous Chemical Inventory reporting is approaching.   The Emergency Planning and Community Right to Know Act (EPCRA) of 1986 was implemented to help communities plan for emergencies involving hazardous substances.  EPCRA requires hazardous chemical emergency planning by federal, state and local governments, Indian tribes, and industry. It also requires industry to report on the storage, use, and releases of hazardous chemicals to federal, state, and local governments.  The primary group of FUELIowa members impacted by the reporting requirements will be bulk plant operators, but marinas and fleet fueling facilities may also fall within the scope of the regulation.  Most C-stores are exempted from the reporting requirements unless storing more than 75,000 gallons of gasoline or 100,000 gallons of diesel fuel in underground storage tanks.  When analyzing whether your facility is subject to Tier 2 reporting requirements, combine all grades of a single product to determine whether your facility meets the applicable threshold.

The following classification numbers will be requested from facilities:

CAS Numbers:

Gasoline- CAS 8006-61-9

Diesel Fuel – CAS 68334-30-5

Kerosene – CAS 8008-20-6

Fuel Oil – CAS 68334-30-5

Aviation Gasoline, Jet A, JP 8 – CAS Mixture

NAICS Code (SIC no longer adequate):

Petroleum Bulk Plants:  NAICS 424710

Heating Oil Dealers:  NAICS 454310

Retail Gasoline Stations with Convenience Stores:  NAICS 447110

Retail Gasoline Stations without Convenience Stores:  NAICS 447190

Information Required on EPCRA Forms:

EPCRA forms now require information on the physical hazards and health hazards of each product stored on site meeting the minimum reporting threshold (10,000 lbs).  This information must be obtained from Safety Data Sheets (SDS) provided by your supplier.  Suppliers are required to provide a copy of the most recent SDS for product sold to downstream petroleum marketers.  Suppliers often have a copy of their SDS on their website. 

Physical and health hazard categories appear as two separate columns on the new Tier 2 Form.  Under each column, a series of hazards are listed next to check off boxes.  For physical hazards check the boxes marked explosive and flammable.  For health hazards check the following boxes:

  • Skin corrosion or irritation
  • Serious eye damage or irritation
  • Respiratory or skin sensitization
  • Carcinogenicity
  • Reproduction toxicity
  • Aspiration hazard

Dun and Bradstreet Number Locator

The financial officer of your facility should be able to provide the Dun & Bradstreet number. If you do not have this information, the following link to the Dun & Bradstreet website will get you started.

https://www.dnb.com/

Toxic Release Inventory (TRI) and Risk Management Program (RMP)

Tier 2 forms now ask whether the facility is subject to emergency planning under Section 302 of EPCRA (TRI) or the chemical accident prevention requirements under 112r of the Clean Air Act (RMP).  Typically, small petroleum bulk plant operators located downstream from a terminal rack are not subject to TRI or RMP.

Iowa Reporting Requirements

FUELIowa members can access applicable forms and instructions here on the Iowa DNR website.  The same link can be used to access an updated county emergency management listing.  Tier 2 reports are required to be completed and submitted to the Iowa DNR by March 1, 2019.  As a reminder, reports filed by March 1, 2019 cover the 2018 calendar year.  If you have questions about filing the report, please contact Elonda Bacon at 515-725-0302.

Federal Tanks & Equipment State Compliance







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