Saturday, March 7, 2015

EPCRA-302



The Emergency Planning and Community Right-To-Know- Act or EPCRA is to allow state and local planning for chemical emergencies, provide for notification of emergency releases of chemicals, and address communities right-to-know about toxic and hazardous chemicals. EPCRA is also known as Title III of the Superfund Amendments and Reauthorization Act (SARA.)
                EPCRA Section 302 requires facilities to notify the state/tribe emergency response commissions (SERCs/TERCs) of the presence of any "extremely hazardous substance." Any facility that has any of these extremely hazardous materials at or above the threshold quantity has 60 days to notify the SERC and LEPC after they receive their shipment or produce the substance on site. These extremely hazardous substances and their allowable quantities are listed in 40 CFR part 355, appendices A and B. Here is a link for the table of the hazardous substances that section 302 covers on the list of lists: http://www.bnl.gov/esh/env/compliance/docs/SaraTitleList.pdf These extremely hazardous substances, or TPQs, are determined by the US EPA based on their potential to cause significant health effects in a single exposure.
                Section 302 of EPCRA is for emergency response planning. This section requires state and local authorities to develop chemical emergency preparedness and response capabilities through better coordination and planning with local businesses.  Facilities have 30 days to report to the US Environmental Protection Agency any changes in the status of substances that would affect emergency planning. An example of this change is closing a facility, bringing a new extremely hazardous substance on site, moving the substances to a different location at the facility, and removing all extremely hazardous substances from a facility. If a facility has an extremely hazardous substance that exceeds the threshold planning quantity, the owner or operator must submit a one-time notification to the Georgia state Emergency Planning Commission (SERC) and the Local Emergency Planning Committee (LEPC) if one exists in your community.
                If an EHS is present in a mixture, only the quantity (in pounds) of the EHS within the mixture applies toward the TPQ assessment. Refer to the Material Safety Data Sheet (MSDS) to determine the mixture component percentages. For instance, if a 100 pound mixture contains 20% by weight of an EHS, then the EHS is present at 20 pounds. You do not have to count an EHS in a mixture if the concentration of that EHS is less than or equal to one percent. Some common EHSs and their 302 TPQs include ammonia (500 lbs), formaldehyde (500 lbs), chlorine (100 lbs), sulfuric acid (1,000 lbs), nitric acid (1,000 lbs), and phosphorus (100 lbs). TPQs refer to the cumulative total of each chemical stored at a facility. For instance, if a facility has 500 pounds of sulfuric acid used in wastewater treatment and 600 pounds of sulfuric acid in an electric fork lift battery, reporting is required because sulfuric acid is present at the facility over 1000 pounds, the TPQ. There are two main differences between EHS reporting associated with §302 and §312. First, an EHS in §302 is reportable if it meets or exceeds the TPQ. An EHS is reportable under §312 if it meets or exceeds the TPQ OR 500 pounds if 500 pounds is lower than the TPQ.

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