rdous
& 312:
Sections 311
Emergency a
Chemical Inventory
Reporting
The minimum threshold for Sections 311-
312 reporting for EHS substances is
500 lbs. or the TPQ, whichever is less.
The minimum threshold limit for any
OSHA hazardous chemical requiring a
Material Safety Data Sheet (MSDS) that is
not an EHS is 10,000 lbs.
Within 90 days of reaching the reportable
threshold, Section 311 requires a one time
submission of the MSDS or a list of
MSDSs for the reportable chemicals to the
SERC, the LEPC and the local fire
department.
Section 312 requires a filing of either a
Tier I or a Tier II report annually by
March 1 following the year reporting is
triggered. Tier II reports must be submitted
to the SERC, the LEPC and the local fire
department. The facility should check with
the LEPC and the SERC about how to
submit a Tier II report.
Example of Section 311/312 Requirement
If your facility stores, uses or produces more
than 10,000 lbs. of methanol, drip gas or
natural gas condensate at any one time, then the
facility is required to report this hazardous
chemical per Section 311/312. Any hazardous
chemical that is required to have an MSDS
under OSHA regulations is considered a
hazardous substance unless it is exempt under
Sections 311/312.
United States
Environmental Protection Agency
EPA 903-F11001
March 2011
How to Report a Release
A report of hazardous substance release or
oil spill takes only a few minutes.
To report a release or spill, contact the
National response Center (NRC) at:
1-800-424-8802.
The NRC is staffed 24 hours a day.
If reporting directly to the NRC is not
possible, reports of incidents that occur in
Delaware, Maryland, Pennsylvania,
Virginia, West Virginia or the District of
Columbia also can be made to the
EPA Region 3 Response Center at:
215-814-9016.
A delay in reporting a release creates a
delay in emergency response resources
and may further endanger the
community.
ADDITIONAL RESOURCES
For more information on EPCRA, please go to
the website at:
http://go.usa.gov/gAH
For an EPCRA Overview, please go to the
website at:
http://go.usa.gov/goi
For information regarding the "List of Lists" -
a consolidated list of chemicals subject to
EPCRA, CERCLA and Section 112 (r) of the
Clean Air Act, please go to:
http://go.usa.gov/gA6
Printed on chlorine-free, 100%
recycled/recyclable paper
with 100% post-consumer fiber.
Emergency Planning and
Community Right-to-Know Act
Guide for
Marcellus Shale
Gas Drilling Facilities


**L PrO^


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EPA REGION 3




1650 Arch Street
Philadelphia Pa 19103-2029

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It's About Being
A Good Neighbor
Complying with the Emergency Planning anrl
Community Right-to-Know Act (EPCRA) and
other environmental laws saves lives and
protects the environment.
Facilities that use, produce, manufacture or
store hazardous chemicals must provide
information to all applicable Local Emergency
Planning Committees (LEPCs), State
Emergency Response Commissions (SERCs)
and Local Fire Departments (LFDs), if they
have chemicals at, or above, reporting
thresholds.
Risks can be eliminated or appropriate
actions taken if emergency responders
know in advance what chemicals
they may be dealing with at the site.
When a fire or explosion occurs at a drilling
facility and information is unknown regarding
the chemicals released, the community could be
harmed by a toxic plume or by contaminated
runoff that moves offsite.
Info for Marcellus Shale Well Facilities
Facilities that store, use or release certain
chemicals are subject to various reporting
requirements. Reported information is made
publicly available so that interested parties can
learn about potentially dangerous chemicals in
their community.
Section 302: Emergency
Planning Notification
All facilities that have an Extremely Hazardous
Substance (EHS) above its Threshold Planning
Quantity (TPQ) for any period of time must notify
the SERC and LEPC within 60 days after they first
receive a shipment or produce the substance on
site.
EPCRA 302 also requires an Emergency Response
Plan to be developed in coordination with the
LEPC, and a Facility Emergency Coordinator must
be named by the facility having an Emergency
Management System (EMS).
There are no exemptions under Section 302.
Anytime an EHS is present at, or above, the TPQ, a
facility official must notify the SERC and LEPC.
Note: The State may have more stringent requirements
Example of Section 302 Requirement
Some companies add hydrofluoric acid (HF), an EHS,
in addition to other hazardous chemicals,
to their Frac fluid.
Because the HF is an EHS and, if the aggregated
amount of the HF at the facility equals or exceeds
the TPQ of 100 pounds at any one time, then
Emergency Planning Notifications to the LEPC and
the SERC are required by the facility.
Regulations at 40 CFR 370.28(c) require facilities to
aggregate the amounts of each EHS present at the
facility, whether it is present as a mixture component oi
in its pure form to determine if the TPQ is reached.
Note: If the aggregate amount of HF exceeds the
reporting threshold of 100 lbs., then this chemical is
also reportable under Sections 311/312.
Section 304: Emergency
Notification Requirements
A facility must notify state and local authorities
responsible for local emergency planning in
two situations:
1.	if there is a release at the facility (which
includes releases from motor vehicles,
rolling stock or aircraft) of an Extremely
Hazardous Substance (EHS) or a Hazardous
Substance in excess of the reportable
quantity (RQ) for that substance,
or
2.	if the release could result in potential
exposure of persons outside the boundary of
the facility property.
Report chemical releases immediately to any SERC,
Tribal Emergency Response Commission (TERC),
and LEPC potentially affected by the release.
Facilities must also report a release of a CERCLA
Hazardous Substance to the
National Response Center (NRC) at:
1-800-424-8802.
EPA has identified and listed over 700 Hazardous
Substances under the Comprehensive Environmental
Response, Compensation and Liability Act
(CERCLA) and has assigned a reportable quantity to
each substance. Chemicals on the EHS list have
been assigned reportable quantities.
Note: In most instances, a facility must also submit,
within 30 days, a written follow-up report about the
incident to the SERC and LEPC.
There are no penalties for reporting a spill
unnecessarily, but there may be significant
penalties for not immediately reporting one.

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