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^ - * .. * EPA REGION 3 1650 Arch Street Philadelphia Pa 19103-2029 ------- 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. ------- |