Ice Rinks
&EPA
United States
Environmental Protection
Agency
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW ACT
REPORTING GUIDANCE
Refrigeration Systems
U.S. EPA Region 1 has developed this document to assist ice rink owners and operators in
communicating effectively with their state and local emergency planners and responders as
required under the federal community right-to-know regulations. Protecting the community from
potential risks, including those associated with ammonia refrigeration systems operations, is the main
goal of the Emergency Planning and Community Right-to-Know Act.
EBBERT m
GIRBEDTS ft
Indoor Ice Arena. Source: Cory Partner: St. Cloud State University
What is EPCRA and why is it important?
Congress passed the
Emergency Planning and
Community Right-To-Know
Act (EPCRA) in 1986 to help
communities prepare for
chemical emergencies. It
also requires facility owners
and operators to report
annually on the presence of
hazardous chemicals at their
facilities. In 2018, two ice rinks
in New England faced EPCRA
reporting violations from EPA
and had to pay fines. Failure
to follow EPCRA requirements
can lead to EPA enforcement
penalties; more importantly, not
following the requirements can
lead to ineffective response
to hazardous situations,
which places employees
and customers at risk in an
emergency. Hazardous
chemicals subject to these
EPCRA requirements may be
found in numerous forms, such
as in products, batteries, liquid
solutions, solid materials, and
other substances.
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Nov 2019
EPA-901-F-19-001
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What are the reporting requirements under EPCRA?
EPCRA has four major
provisions: emergency
planning (Section 302),
emergency release notification
(Section 304), hazardous
chemical inventory reporting
requirements (Sections 311-
312), and toxic chemical
release inventory (Section 313).
Generally, Section 313 does not
apply to ice rinks. Section 302
requires facilities with Extremely
Hazardous Substances (EHS),
such as ammonia or sulfuric
acid, at or above their threshold
planning quantities (TPQs) to
notify their State Emergency
Response Commission (SERC)
and the local emergency
planning committee (LEPC) of
the chemicals' presence within
60 days of bringing them on-site
for the first time (See 40 C.F.R.
Part 355). These facilities must
designate a facility emergency
coordinator who will participate
in the LEPC emergency
planning process under Section
303. Under Section 304, a facility
must report an accidental
release at or above the
reportable quantity (RQ) of an
EHS or a hazardous substance
listed under section 102 of the
Comprehensive Environmental
Response, Compensation,
and Liability Act (CERCLA).
In the case of ammonia, for
example, a release of 100
pounds or more should be
reported to the SERC and the
LEPC. Additionally, Section 103
of CERCLA requires reporting
of any CERCLA hazardous
substance, such as ammonia to
the National Response Center.
Sections 311-312 of EPCRA
require facilities storing
hazardous chemicals above
threshold amounts to submit
a Safety Data Sheet (SDS) or
a list of hazardous chemicals
to SERCs, LEPCs, and Fire
Departments, and thereafter
to submit an annual chemical
inventory form to these entities.
Many states - including all New
England states- require that the
comprehensive "Tier 2" form be
used for this annual reporting,
rather than the shorter Tier 1
form. Learn more about EPCRA
requirements here: https://
www.epa.gov/epcra/epcra-
fact-sheet
Section 302
Emergency Planning
Section 302 requires
facilities with Extremely
Hazardous Substances
(EHS), such as ammonia
or sulfuric acid, at or
above their threshold
planning quantities
(TPQs) to notify their
State Emergency
Response Commission
(SERC) and the local
emergency planning
committee (LEPC)
of the chemicals'
presence within 60 days
of bringing them on-site
for the first time (See 40
C.F.R. Part 355).
EPCRA 304/CERCLA
103 Emergency
Release Notification
Under EPCRA section
304 and section 103
of the Comprehensive
Environmental Response,
Compensation, and
Liability Act (CERCLA),
a facility must report an
accidental release at or
above the reportable
quantity (RQ) of an
EHS or a hazardous
substance listed under
CERCLA section 102. In
the case of ammonia,
for example, a release
of 100 pounds or more
should be reported to
the SERC, LEPC, and
National Response
Center.
Sections 311-312
Hazardous Chemical
Inventory Reporting
Requirements
Sections 311-312 of
EPCRA require facilities
storing hazardous
chemicals above
threshold amounts to
submit a Safety Data
Sheet (SDS) or a list of
hazardous chemicals
to SERCs, LEPCs, and
Fire Departments, and
thereafter to submit
an annual chemical
inventory form to
these entities,
(see above)
Section 313
Toxic Chemical
Release Inventory
Generally, Section
313 does not apply
to ice rinks.
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Tier 2 Reporting under EPCRA Section 312
What is Tier 2 reporting?
Most ice rinks using ammonia as a refrigerant are subject to EPCRA Tier 2 reporting under Section 312.
EPCRA Section 312 requires facilities to submit an EPCRA Tier 2 form by March 1 annually to their SERC,
LEPC, and local fire department. Emergency responders use this information to plan, prepare for,
prevent, and respond to any chemical emergencies, including spills or releases, at a facility.
Note that EPCRA Tier 2 reporting requirements may not apply to municipally owned and operated
rinks in states that do not have an OSHA-approved state plan to protect workers. Find out about your
state plan at https://www.osha.gov/dcsp/osp/index.html
Do I need to submit a Tier 2 form?
You need to report if you have a threshold amount of any chemical, including EHSs, for which
facilities are required to have a Safety Data Sheet (SDS) by the Occupational Safety and Health
Administration (OSHA).
The types of hazardous chemicals an ice rink might need to report include, but are
not limited to:
•	Ammonia (500-pound EHS threshold)
•	Non-ammonia refrigerants, such as R-22orR-134a (10,000-pound threshold)
•	Lead Acid Batteries, which contain both sulfuric acid (500-pound EHS threshold) and lead
(10,000-pound threshold)
~	Lead acid batteries can be found in Zamboni® or other ice resurfacing machines, trucks,
maintenance equipment, and backup generators.
•	Coolants, such as Glycol or Brine solutions (10,000-pound threshold)
•	Non-consumer cleaning solutions present in non-consumer form (10,000-pound threshold)
•	Sand (10,000-pound threshold)
•	De-icer, such as salt or urea (10,000-pound threshold)
•	Fuel for a backup generator (10,000-pound threshold), such as:
~	Propane (approximately 2,500 gallons equals 10,000 pounds)
~	Diesel or #2 fuel oil (approximately 1,562 gallons equals 10,000 pounds)
~	There is no reporting requirement for using natural gas through a pipeline.
Do I have to report for an ice skating rink that is only open for 3 months during a calendar year?
The EPCRA Tier 2 annual reporting requirement is based on how much hazardous chemical you
have on-site at any one time during the previous calendar year. You need to submit a Tier 2 form
if you have a threshold amount of any hazardous chemical, including EHSs on-site at any time
during the year.
Be sure to check if your state has lower reporting thresholds than the federal requirements. For example, Vermont
has a reporting threshold of 100 pounds for most chemicals.
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When are Tier 2 forms due?
Tier 2 forms are due annually
by March 1 for the previous
calendar year. Additionally, if
you bring a hazardous chemical
into your facility for the first
time in an amount that meets
or exceeds the threshold, and
you have never reported that
chemical before, you will have
to submit an SDS or hazardous
chemical list to the LEPC, SERC,
and fire department within
three months of meeting or
exceeding that threshold
(alternatively, you may submit
a Tier 2 form). See 40 C.F.R. §§
370.20 - 370.33. This is a one-time
reporting requirement to make
sure the emergency response
and planning agencies have
timely information about the
new presence of hazardous
chemicals at your facility.
Please check with your state
for the preferred method.
How do I submit my annual Tier 2 form?
The owner or operator of the ice rink must submit the
required Tier 2 form to the State Emergency Response
Commission (SERC), Local Emergency Planning Committee
(LEPC), and local fire department. All New England states
require electronic reporting. However, some LEPCs and fire
departments may request a hard copy. Find online reporting
software and information at these links:
Tier2 Submit™ software: https://www.epa.gov/epcra/tier2-
submit-software
EPCRA Tier 2 reporting information: https://www.epa.gov/
epcra/epcra-sections-311-312
State Tier 2 reporting requirements and procedures: https://
www.epa.gov/epcra/state-tier-ii-reporting-requirements-and-
procedures
For more information:
EPCRA, RMP and Oil Information center: 800-424-9346
EPCRA fact sheet:
https://www.epa.gov/epcra/epcra-fact-sheet
EPA List of Lists: https://www.epa.gov/sites/production/
files/2015-03/documents/list_of _lists.pdf
EPCRA Hazardous Chemical Reporting regulations: 40 C.F.R. Part
370 https://www.gpo.gov/fdsys/pkg/CFR-2017-title40-vol30/
pdf/CFR-2017-title40-vol30-part370.pdf
EPCRA information on Extremely Hazardous Substances:
https://www.epa.gov/epcra/final-rule-extremely-hazardous-
substance-list-and-threshold-planning-quantities-emergency
Attend an EPA EPCRA Tier 2 training in New England: https://
www.epa.gov/epcra/emergency-planning-and-community-
right-know-act-epcra-workshops-new-england
EPA's web-based eDisclosure Portal:
www.epa.gov/compliance/epas-edisclosure
If you have questions, please contact the EPA Region 1 office
email at: Rlassist@epa.gov
This document is intended for regulatory guidance only and should not be substituted for a thorough
review of existing federal regulations. Be sure to review your state and local requirements as well as the
federal requirements discussed in this factsheet.
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