Regulated Underground Storage Tank facilities covered by Emergency Planning and Community Right-to-Know Act (EPCRA), also known as SARA Title III, are required to submit an Emergency and Hazardous Chemical Inventory Form to the Local Emergency Planning Committee (LEPC), the State Emergency Response Commission (SERC), and the local fire department annually. Reporting deadlines are coming due.

Facilities must provide a Tier II form as required in the EPCRA guidelines. Some states have specific requirements over and above the federal Tier II requirements, so make sure diligence is done to ensure accuracy. On the federal level, under the Hazardous Chemical Inventory (EPCRA Section 312), facilities are required to submit an annual report on the quantity and location of hazardous chemicals. Tier II forms may be submitted to the SERC, LEPC, and local fire department using EPA’s Tier2 Submit software by March 1 for the previous calendar year.

Does it Apply to Me?

The EPA requires petroleum marketers to report to state or local emergency responders by March 1 of each year the identity, location, and quantity of hazardous materials (gasoline, diesel fuel, etc) when stored at a facility in excess of established threshold volumes. The information must be filed on an Emergency Planning and Community Right to Know (EPCRA) Tier II Inventory Reporting Form or on Tier2 Submit electronic filing software. Tier II reports must also be filed for marinas and fleet fueling facilities as well as retail facilities above certain storage capacities.

What is a Tier II Spill?

The second of the three types of oil spills as categorized by the International Petroleum Industry Environmental Conservation Association (IPIECA). A Tier 2 spill is larger than a Tier 1 spill, but is still one that occurs in the area of the producing company's facilities. Tier 2 spills usually require the aid of other companies and resources, including the government.

For more information from the EPA, please click here. This link includes a list of individual state sites and requirements.

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