Tier II reports due March 1
Reminder: Environmental Protection Agency Emergency Planning and Community Right-to-Know Act Tier II reports must be filed for bulk plants, marinas and fleet fueling facilities that stored more than 10,000 pounds (approximately 1,626 gallons) of hazardous chemicals (petroleum fuels) in fixed storage at any single time during the 2015 calendar year. EPCRA reports must be filed with local and state emergency response authorities no later than March 1. In addition, retail facilities (i.e. gas stations) with a storage capacity greater than 75,000 gallons of gasoline and/or 100,000 gallons or more of diesel fuel must also file EPCRA reports.
EPCRA PAPER FORMS AND ELECTRONIC SUBMISSION SOFTWARE
EPCRA CAS NUMBERS
- EPCRA Tier II forms may be downloaded here. Instructions, including codes needed to fill out the form may be downloaded here.
- CT also allows the EPA Tier2 Submit software for electronic filing. Tier2 Submit electronic filing may be downloaded at here.The paper form is fairly straightforward, however, once you get the hang of the codes. Contact David Chu at (866) 521-4272 if you need help filling out the form manually. The software doesn't actually submit the form for you - you still have to email it to DEEP, which however doesn't accept electronic signatures, so you'll also have to submit a signature certificate if you want to submit electronically, as explained below.
- Connecticut Compliance: Forms may be submitted in the following formats: CD, email or paper. All electronic forms must be validated by the Tier2 Submit software feature prior to submission. To ensure your email is recognized as a formal document and not spam, the email subject line should reflect the following wording "(Name of your facility), Tier Two." All emails must be directed to email@example.com.
- When the Tier Two form is filed electronically or by CD, a signed Connecticut Tier2 Submit Report Certification (PDF) must be submitted because the DEEP is not accepting electronic signatures.
- In addition, you must submit Tier Two information to the LEPC (Local Emergency Planning Committee) and the fire department which have jurisdiction over your facility. Please be aware that towns have various practices for collecting Tier Two information. The facility owner or operator should contact the LEPC chairperson (if there is one appointed) and fire department for the town's specific submission requirements.
EPCRA NAICS CODE
- The following CAS designations (from material safety data sheets) must also be included on EPCRA Tier II reports, as applicable: Gasoline (CAS 8006-61-9); Diesel Fuel (CAS 68476-34-6); Kerosene (CAS 8008-20-6); Fuel Oil (CAS 68476-30-2); Aviation Gasoline (CAS Mixture); Jet A (CAS Mixture); JP 8 (CAS Mixture).
PENALTY FOR FAILURE TO FILE EPCRA TIER II
- For the use on the forms, applicable NAICS codes for the petroleum marketing industry include: Petroleum Bulk plants - NAICS 424710; Heating Oil Dealers - NAICS 454311; Retail Gasoline Stations with Convenience Stores - NAICS 44711; Retail Gasoline Stations without Convenience Stores - NAICS 44719.
- There is no cost to file the reports, but there is a penalty for not filing. The EPA fine for violating EPCRA Tier II reporting is up to $37,500 per day, per violation.