Don't forget that the Environmental Protection Agency’s Emergency Planning and Community Right to Know (EPCRA) Tier II reports must be filed with local or state emergency response authorities no later than March 1, 2015.
EPA checks for filing of EPCRA Tier II reports during routine and compliance audits or after a release has occurred. Fines for violating EPCRA Tier II reporting is $37,500 per day, per violation.
Retail facilities with a storage capacity greater than 75,000 gallons of gasoline and/or 100,000 gallons or more of diesel fuel must file EPCRA reports. Bulk plants and fleet fueling facilities that stored more than 10,000 pound of hazardous chemicals, including petroleum fuels, at any single time during 2014 also must file the report.
Retail fueling facilities at or below these capacity thresholds are exempt from the annual Tier II reporting under Federal regulations. Some states, however, have set lower reporting thresholds, use unique Tier II reporting forms or now require electronic filing of Tier II reports. State EPCRA offices can verify local variances in Tier II reporting requirements.
Trucsktops and travel plazas should note that the new Tier II form asks whether the facility is subject to emergency planning under Section 302 of EPCRA or the chemical accident prevention requirements under 112r of the Clean Air Act. Last year, the Tier II Form also required additional data including facility phone number, latitude and longitude coordinates of the facility, and an estimate of the maximum number of people at the facility at any one time.
Tier II reporting forms and instructions can be found here.
A complete list of state EPCRA Tier II requirements and procedures can be downloaded here.
Tier II Submit Software for electronic filing can be found here.
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