Tier Two Report WHAT IS THE TIER TWO TIER TWO REPORT? EMERGENCY - PDF document

Tier Two Report WHAT IS THE TIER TWO TIER TWO REPORT? EMERGENCY AND HAZARDOUS CHEMICAL � A report required under SARA Title III INVENTORY Section 312 of � Hazardous substances at a facility that are above the threshold, Susan Parker Susan Pa rker � Submitted annually to state and local Michigan Michigan SARA Title III SARA Title III officials, and Program Program � Made available to the public upon January 2012 January 2012 request. 2 Tier Two TIER TWO WHO MUST REPORT? OWNER OR OPERATOR Owner OR Operator? � The owner or operator of a facility � If required under OSHA to prepare or have available MSDSs for hazardous substances present at the facility, � If exemptions do not apply, MSDS � And IF the threshold amount or more of a hazardous substance was present at the facility at any time during the past The report is the responsibility of calendar year. whomever must maintain the MSDS for the hazardous material. 3 4 All Substances covered by All Substances covered by TIER TWO HAZARDOUS SUBSTANCES SARA Title III SARA Title III OS OSHA HA: Tier Two OSHA Hazardous EHS: Emergency EH (MSDS required) � Hazardous Substances = all Plan & Release substances for which OSHA Report requires an MSDS. CERCLA RCLA: Release EHS Report � There is NO LIST of these TOXIC: TRI TO “OSHA” hazardous substances. CERCLA TOXIC RCRA hazardous waste CERCLA RCLA & & EH EHS & & TOX TOXIC are in the List of Lists are in the List of Lists 5 6 Michigan SARA Title III Program 1

Tier Two Report TIER TWO TIER TWO HAZARDOUS SUBSTANCES HAZARDOUS SUBSTANCES 3. Water can have an MSDS, but it is not required by OSHA. 1. OSHA defines hazardous substance as any substance that is a physical hazard or a health hazard. (Pg. 3-4 for description) 2. OSHA requires that MSDSs be maintained for each hazardous substance. 7 8 TIER TWO Tier Two HAZARDOUS SUBSTANCES EXEMPTIONS Some OSHA hazardous substances do 4. OSHA does not require an MSDS not have to be reported on the Tier for Hazardous Waste that is Two report. subject to RCRA. Pg. 3-5: “What Chemicals Are Excluded?” 9 10 Tier Two EXEMPTIONS Tier Two EXEMPTIONS Example: Sheet Metal Sheet metal as Any substance present as a solid in any manufactured item to the extent purchased is a exposure to the substance does not manufactured item. occur under normal conditions of use. There is no potential for exposure to the Situation: solid metal. A facility purchases sheet metal to Sheet metal in manufacture its final product. MSDS is required. Is it exempt? process is no longer a manufactured item. 11 12 Michigan SARA Title III Program 2

Tier Two Report Tier Two EXEMPTIONS Tier Two EXEMPTIONS Example: Sheet Metal EPA’s interpretation published July Section 312 (Tier Two) Exemptions do 2010 says that only the fumes or dust NOT apply to: emitted when the solid is being modified need to be counted toward � Section 302 : Emergency Planning & the Tier Two reporting threshold. Notification Requirements � Section 304 : Hazardous Substance Release Notifications 13 14 TIER TWO GALLONS TO POUNDS THRESHOLD FORMULA FOR CONVERSION The amount on site at any given time Specific Gravity (Relative Density) in storage and in process. from MSDS X � Threshold for “OSHA” hazardous substances = 10,000 pounds. Weight of Water (8.34 lbs per gal) = Gallons must be converted to pounds. Pounds per gallon of substance Formula on Pg. 3-5 15 16 GALLONS TO POUNDS GALLONS TO POUNDS CONVERSION TEST YOUR UNDERSTANDING CONVERSION ANSWER Calculate lb/gal of gasoline 0.75 x 8.34 lb/gal wtr = ____________ 1600 gallons of gasoline From MSDS (Pg. 6-19): Total weight of gasoline = Specific gravity = _____________ 6.3 lb/gal x 1600 gal = ______________ 17 18 Michigan SARA Title III Program 3

Tier Two Report TIER TWO TIER TWO THRESHOLD THRESHOLD RETAIL GAS STATION Thresholds RETAIL GAS STATION Thresholds 10,000 pound threshold applies to: � gasoline = 75,000 gallons if all • E-85 and other Alternative fuels (except stored in compliant USTs gasohol with ≤ 10% ethanol) � diesel fuel = 100,000 gallons if all • Aviation fuel stored in compliant USTs • Heating fuel • Kerosene UST=underground storage tank • Propane 19 20 TIER TWO EXTREMELY HAZARDOUS TIER TWO THRESHOLD SUBSTANCES (EHS) Threshold for Extremely Hazardous Aggregate all occurrences of an Substances (EHS) = the lower of: EHS to determine if threshold is met. � 500 pounds or Pure form + mixture components* � threshold planning quantity = total EHS (TPQ) * If ≥ 1% of mixture, or ≥ 0.1% if EHSs and TPQs are listed carcinogen 21 22 TIER TWO TIER TWO EXTREMELY HAZARDOUS EXTREMELY HAZARDOUS SUBSTANCES (EHS) SUBSTANCES (EHS) EXAMPLE SULFURIC ACID IN INVENTORY � 6 fork lifts with large lead-acid Sulfuric Acid batteries EHS = yes/no? � 55 gal drum pure Sulfuric Acid TPQ = _______ Total lbs Sulfuric Acid = ? Tier Two reporting threshold = ______ 23 24 Michigan SARA Title III Program 4

Tier Two Report TIER TWO EXTREMELY HAZARDOUS MSDS: Sulfuric Acid 66°Be SUBSTANCES (EHS) 55 gallon drum of pure sulfuric acid Specific gravity (from MSDS) = ________ X ______________ (weight of water) = ______ lb/gal sulfuric acid 55 gal x _____ lb/gal = _____lbs sulfuric acid 25 26 TIER TWO Many MSDSs for Batteries EXTREMELY HAZARDOUS are Misleading SUBSTANCES (EHS) Lead-acid Batteries Lead-acid Batteries. Use caution if consulting the MSDS… Approximate Calculation based on total battery weight � Many MSDSs for batteries list a � 2/3 battery weight = Lead percentage of “sulfuric acid” when � 1/3 battery weight = battery acid they mean “battery acid” � 1/3 battery acid weight = Sulfuric Acid � Battery Acid (aka Electrolyte) is a � 1/9 battery weight = Sulfuric Acid mixture of sulfuric acid and water 27 28 TIER TWO TIER TWO EXTREMELY HAZARDOUS EXTREMELY HAZARDOUS SUBSTANCES (EHS) SUBSTANCES (EHS) SULFURIC ACID IN BATTERIES � 6 Batteries Total weight of batteries= � Each Battery Weighs 600 pounds Battery Acid ≈ � How many pounds of Sulfuric Acid are in the batteries? Sulfuric Acid ≈ 29 30 Michigan SARA Title III Program 5

Tier Two Report TIER TWO TIER TWO EXTREMELY HAZARDOUS EXTREMELY HAZARDOUS SUBSTANCES (EHS) SUBSTANCES (EHS) Required Reporting for TOTAL SULFURIC ACID 1244 lbs of Sulfuric Acid? Tier Two - ____ lbs in the batteries • Because ≥ ______ + ____ lbs pure _____ lbs total Emergency Planning Notification (Section 302) • Because ≥ _______________ 31 32 TIER TWO Tier Two THRESHOLD RECAP... � The owner or operator reports The threshold for reporting in � hazardous substances response to requests is zero according to OSHA � if exemptions do not apply, Requests can be made by the SERC, LEPC, Fire Dept with � and IF the threshold amount is jurisdiction over facility ever on site. 33 34 Tier Two Simplified thought process… RECAP... � OSHA Hazardous Substance 1. Is it hazardous? (OSHA MSDS) threshold = 10,000 pounds • No: not subject to reporting • Yes: go to question 2 � Extremely Hazardous Substance threshold = 500 pounds or 2. Is it an EHS? (Appendix A) TPQ (whichever is lower) • No: threshold is 10,000 lbs � Retail Gas Stations are special … • Yes: threshold is TPQ or 500 lbs � So are Requests ... 35 36 Michigan SARA Title III Program 6

Tier Two Report Tier Two TEST YOUR Tier Two REPORT DUE DATES UNDERSTANDING What is the Tier Two reporting Tier Two annual hazardous chemical threshold for… inventory due MARCH 1 ST . � Nitric acid? ___________ Section 311 initial hazardous chemical � Chlorine? ____________ inventory due within 3 months after threshold reached. � Hydrochloric Acid? _____________ � Water? __________________ See Pg. 1-8 for all SARA Title III report � Propane? _______________ due dates. 37 38 ONLINE REPORTING TIER II MANAGER™ Tier II Manager™ 3 reports submitted in the program: Off-the-shelf program customized for 1. Section 312 Tier Two (update as Michigan. needed; submit annually) In 2012, program will be rewritten on a 2. Section 311 Initial Hazardous new platform. Expect improved Chemical Inventory (as applicable) reporting process for 2013! 3. Section 302 Emergency Planning All facility reports must be entered in Notification (update & recertify as this online program. needed) 39 40 Each reporter should have only TIER II MANAGER™ ONE account. 3 modules: 1. Submit – Reporters 2. Planning/Response – LEPCs & Fire Depts (Ingham, Kent, Oakland, Ottawa& Wayne Counties) 3. Administration – Susan & Tonya If you “do not have sufficient access rights,” you are in the wrong module. Username = SARA00001 Username = SARA01011 41 42 Michigan SARA Title III Program 7