Emergency Planning Notification

equipment3Under Section 302 of the Emergency Planning and Community Right to Know Act (also know as SARA Title III),  any facility that has more than the Threshold Planning Quantity (TPQ) of an extremely hazardous substance must notify the Local Emergency Planning Committee (the fire department in most cases).

The list of Extremely Hazardous Sustances (EHS) and the corresponding TPQs can be found in Appendix A of 40 CFR355 .

Note that the TPQ always refer to the pure chemical form. So if you have a mixture that has 33% sulfuric acid in it and the TPQ for sulfuric acid is 1000 pounds, you will reach the TPQ when you have 3000 pounds of that mixture.

This poses an interesting question for large car dealerships and construction equipment lots. Let’s say each car or tuck on the lot has a battery with a 10 pounds mixture of 33% sulfuric acid in it. If the dealership has more than 300 cars on the lot, it will have exceeded the 1000 pounds TPQ limit for the 33% acid mixture. It must then notify the LEPC in accordance with Section 302 of SARA Title III. See EPA letter.

By the way, SARA is not the name of a girl. It stands for Superfund Amendments and Reauthorization Act. When Congress reauthorized the Superfund law in 1986, it put EPCRA into Title III of the reauthorization act. Hence the term: SARA Title III. It is the same thing as EPCRA.

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