Environmental and Regulatory Reporting Requirements

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Environmental and Regulatory Reporting
Requirements Glenn Clapp Wake County Emergency
Management
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• Objectives
• To discuss the key environmental and regulatory
  reporting requirements for hazardous chemicals
  present at facilities in Wake County
• To conduct an overview of the emergency
  hazardous chemical spill reporting requirements
  for facilities in Wake County

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The Two Basic Types of Reporting for Hazardous
Chemicals

• Routine reporting of hazardous chemicals stored
  or possessed by a facility

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And.....

• Reporting of hazardous chemical spills/emissions
  into the environment

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Routine Hazardous Chemical Reporting

• Tier II Reports
• Site Specific Plans
• Risk Management Plans

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Tier II Reporting
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• Purpose of Tier II Reporting
• To track the presence of hazardous chemicals in
  a systematic manner
• To allow responding public safety personnel to
  have the ability to obtain critical information
  relating to both the facility itself and the
  hazardous chemicals contained therein at
  facilities within their jurisdiction

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Tier II Reporting Requirements In Wake County,
the Local Emergency Planning Committee (LEPC)
requests that a Tier II Report be filed by any
facility that uses, stores, or manufactures
hazardous chemicals (any chemical requiring a
Material Safety Data Sheet) in which the quantity
of any hazardous chemical meets or exceeds the
lesser of the following thresholds
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• 55 gallons or 500 pounds
• The EPAs Threshold Planning Quantity (TPQ)
  stated in the List of Lists

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• Comparison of Federal and State Reporting
  Requirements
• Federal
• Tier II Reports (when requested) for
• EHSs 500 lb. or TPQ
• All other hazardous chemicals 10,000 lb.

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• State
• Hazardous Substance Lists (including emergency
  contacts, chemical names, max. amts., location,
  and temp./press. information) for hazardous
  substances at or in excess of 55 gal./500 lb.
  (whichever is greater) shall be maintained by the
  employer and submitted to the Fire Chief having
  jurisdiction.
• or
• Appropriate reporting under EPCRA Sec. 312
  (d)(2) (Tier II)

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• Federal Exemptions
• Exemptions for certain chemicals and facilities
  (i.e. foods, drugs, and cosmetics regulated by
  the FDA, substances used in a laboratory or
  hospital by technically qualified individuals,
  etc.)
• Gasoline 75,000 gal. threshold
• Diesel Fuel 100,000 gal. threshold

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But what do all these reporting requirements mean
for facilities in Wake County?
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Persons responsible for hazardous chemical
reporting for facilities in Wake County only have
to remember the following Tier II Reports should
be submitted for all hazardous chemicals present
in quantities meeting or exceeding the 55
gal./500 lb. or TPQ (whichever is lower)
threshold.
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Tier II Reporting Schedule Tier II Reports are to
be submitted on or before March 1st for hazardous
chemicals on-site at any time during the
preceding calendar year, or at any time in which
significant changes in chemicals or company
information occur.
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• Submittal of Tier II Reports
• Tier II Reports should be submitted to
• The State Emergency Response Committee (NCERC)
• The appropriate LEPC
• The local fire department having jurisdiction

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However Facilities that utilize Wake Countys
On-line Reporting System only have to submit
their Tier II once. The Tier II Report is then
disseminated to the NCERC and the fire department
having jurisdiction.
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• Content of Tier II Reports
• Company/facility information
• (i.e. location, emergency contacts, site
  diagrams, etc.)
• Chemical information
• (i.e. chemical name, quantity (in ranges),
  location, etc.)

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Site Specific Plans
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• Purpose of Site Specific Planning
• Is the same as for Tier II Reporting
• Greater detail allows for the conveyance of more
  information due to the greater hazards posed by
  the chemicals involved

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Site Specific Plan (SSP) Requirements The Wake
County LEPC requests that any facility within
Wake County storing , using, or possessing any
Extremely Hazardous Substance (EHS) at or in
excess of the Threshold Planning Quantity (TPQ)
stated in the EPAs List of Lists file an SSP
with the LEPC (through WCEM).
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SSP Reporting Schedule Facilities with EHSs that
meet or exceed the TPQ should file an SSP when
requested by the LEPC, when the TPQ is met or
exceeded, or when significant changes in chemical
and/or facility information occur.
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SSP Submittal The SSP Template can be downloaded
from www.co.wake.nc.us/lepc The template can
then be completed and then e-mailed or the disk
sent by mail to Wake County Emergency Management
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• SSP Content
• The SSP can be thought of as simply a more
  detailed Tier II Report. SSPs include
• Detailed emergency contact information
• Detailed facility information
• Emergency plans for hazardous materials
  contingencies
• A detailed EHS inventory and information

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Risk Management Plans
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• Purpose of RMPs
• To protect workers, the public, and the
  environment
• To reduce the chances of a chemical release
• To ensure planning activities are undertaken
• To allow for information dissemination

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RMP Requirements Under Section 112 (r) of the
Clean Air Act, facilities that use, make, or
store quantities of covered substances greater
than the 112 (r) Threshold Quantity (TQ) must
file RMPs with the EPA.
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• Section 112 (r) Substances
• 77 acutely toxic substances
• 63 flammable gases and volatile liquids

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• In addition, such facilities are required to
• Develop a hazard assessment
• Produce a five-year accident history
• Develop an accident prevention program
• Develop an emergency response program

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RMP Reporting Schedule RMPs are required to be
reviewed and re-submitted every five years
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RMP Submittal The RMP Submit software can be
downloaded from the EPA Website www.epa.gov And
the disk with the completed RMP mailed to the
EPA, along with a certification statement
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• RMP Content
• The completed RMP will detail the following
• Facility information
• Chemical information
• Response plans for specified release scenarios

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Reporting of Hazardous Chemical Spills/Releases
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Remember to follow the Thumb Rule at any HAZMAT
incident!
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The most important action in any chemical-related
emergency is the early activation of the 911
system
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In any significant HAZMAT incident within Wake
County, the WCEM Staff Duty Officer will respond
and will ensure that all required reporting is
completed
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• In the Event of a Hazardous Chemical
  Spill/Release, the Following Question Must be
  Asked.....
• Did the spill/release involve an EHS chemical or
  a CERCLA chemical?
• If an EHS, then proceed to the EHS Flowchart
• If a CERCLA chemical, then proceed to the CERCLA
  Flowchart

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EHS Flowchart
No
No Report Needed
EHS at or above RQ?
Yes
Is the chemical a CERCLA hazardous substance?
Yes
See CERCLA Flowchart
No
Did release occur during transport?
Yes
Call 911
No
Did release go beyond the legal boundary of the
facility?
Report to NCERC and Wake County EM
Yes
No
No Report Needed
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CERCLA Chemical Flowchart
Is chemical an EHS at or above RQ?
CERCLA hazardous substance at or above RQ?
No
No
No Report Needed
Yes
Yes
Did release occur during transport?
Yes
Call 911 and NRC
Consult EHS Flowchart
No
Did release go beyond the legal boundary of the
facility?
Yes
Report to NCERC, Wake County EM, and NRC
No
Did release go beyond the confines of an enclosed
structure?
Yes
Call NRC
No
No Report Needed
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In simpler Terms.. In a spill/release event
involving an EHS substance, the NCERC and Wake
County EM should be notified if the quantity of
the EHS spilled/released is at or above the RQ
and the product has any impact on areas outside
the legal boundary of the facility. In instances
in which the release occurs during transport,
call 911.
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In cases in which a CERCLA hazardous chemical is
involved, the National Response Center (NRC) is
notified if the spill/release meets or exceeds
the CERCLA RQ and extends beyond the confines of
any enclosed structure at the facility. The
reporting regulations for EHSs (i.e. reporting
to the NCERC and Wake county EM if the substance
is an EHS, meets or exceeds the RQ, and areas
outside of the legal boundary of the facility are
impacted) still apply.
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Wake County Emergency Management will also assist
with notifying other applicable agencies (i.e. NC
DENR, Environmental Services, DAQ, etc.)
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Wake County RQ Form
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Practical Examples
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A facility stores 110 lbs. Of Chloroacetic Acid
in solution form during the reporting year. Is
the facility subjected to Tier II reporting
requirements in Wake County?
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Yes, because the TPQ is 100 lbs.
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What routine reporting is necessary for a
facility within Wake County storing 1,000 lbs. Of
Peracetic Acid?
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A Tier II should be filed, as the amount exceeds
500 lbs. and a Site Specific Plan should be filed
due to the fact that the TPQ of 500 lbs. is
exceeded
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A 750 lb. spill of Ethaneperoxoic Acid occurs
that extends outside of the legal boundaries of a
facility. What agencies should be notified?
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Wake County EM and the NCERC should be notified.
The NRC is not required to be notified because
the product is not a CERCLA chemical
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Contact Information Wake County Emergency
Management Activated by 911 or call (919)
856-6480 NCERC (NCEM) State EOC (800)
858-0368 National Response Center (NRC) (800)
424-8802
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Questions?
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If you have any further questions, contact Glenn
Clapp Wake County Emergency Management (919)
856-5587 glenn.clapp_at_co.wake.nc.us