Notes for: Step 1, Step 3, Step 4, Step 6, Step 9, and Step 15

 

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Step 1
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DOE Facilities are to comply with the reporting requirements of the Emergency Planning and Community Right-to-Know Act (EPCRA) unless legitimate national security interests would be violated.

 

Every EHS or mixture containing an EHS present at the facility should already be recorded on the Optional Comprehensive Inventory Worksheet(s) or an alternative facility-wide inventory system which better meets the needs of the facility. If this has not yet been accomplished, please complete Module 1: Inventory of Chemicals. Module 1 guides you through the process of identifying all EHSs and collecting the necessary information on them.

 

 

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Step 3
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Only one Worksheet will be completed for each EHS present at the facility. Do not begin a worksheet for each product (i.e., Ammonia may be present in five different products/mixtures at the facility. Information on all five of these products would be entered on the same Optional Aggregation Worksheet A). A separate Worksheet A must be started for each EHS (i.e., If the facility had both ammonia and chlorine on site, one Worksheet A would be started for ammonia and a separate Worksheet A would be started for chlorine).

 

 

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Step 4
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The TPQs and RC for each EHS can be found in 40 CFR Part 355, Appendices A and B.

 

 

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Step 6
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Check both the names and the CAS numbers against the EPA list. Manufactures often use synonyms which are different from EPA's regulatory chemical names.

 

Example of information sources include: purchase records, inventory data calculations made by process engineers, etc.

 

Ignore Section 3 of the Optional Aggregation Worksheet A. Sections 311 and 312 do not apply to Section 302.

 

 

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Step 9
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The presence at the facility of even one EHS at or above its TPQ for any length of time requires the facility owner or operator to make Emergency Planning Notification.

 

 

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Step 15
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EPA has not given LEPCs specific limits to what they may request. Any information the LEPC considers relevant to emergency planning may be requested. All emergency planning facilities must comply with the LEPC requests, unless legitimate national security interests are at stake.