25 Days: Even More FAQ Friday Part 3 of 3
Even a few more FAQs
I’m leaving the following 2 sections on all of the FAQ posts, how to get into the Tier2 FAQ and the EPCRA SARA Hotline number.
Remember that to Filter for Tier II Reporting only you will first need to check Emergency Planning and Community Right to Know on the main page, which will give you the option to check Tier II Reporting (EPCRA 311/312), after which you will want to uncheck Emergency Planning and Community Right to Know so that you see 146 FAQs instead of 303 (the balance of the 303 are unrelated to 311/312)
Another non-intuitive and annoying (to me) feature of the way the FAQ’s work is that if you search, the web page unfilters before searching, so you no longer see only Tier2 FAQs. When you go back, you are still unfiltered.
I’ve provided both a link to the main (filtered) Tier2 only FAQs, and have included the hyperlinks at the bottom of each FAQ that I highlighted. So you can click those and still be looking at the appropriately filtered FAQs in a separate window if you want.
Below is one of the most useful, where to call for help. In my experience, while you may experience some “on hold” time, the information when you get to a person will be excellent and cross referenced to the particular citations or other resources clarifying the question.
EPCRA SARA Hotline
And now for more resources
Short answer, you can use alternative Storage Types and Conditions. Tier2Submit will not reject. Check with your local regulatory authority though. For example, I don’t know if Michigan’s Tier2 Manager program has the same flexibility.
Another one I was not aware of, if Specific Gravity is not available, you can use the specific gravity of water as a default. For non-chlorinated solvents, this would typically have you over-reporting (those typically have a specific gravity less than 1), but for halogenated solvents or concentrated acids the calculated amount using the specific gravity of water would be less than the actual amount (those materials typically have a specific gravity greater than 1). I would suggest getting the accurate information from the SDS provider if possible.
Short answer, the water that has been added to the acid can be excluded from threshold determination calculations.
Interesting distinctions on this one, you might want to take a look. Note that the interpretations with respect to batteries in cars may or may not be consistent with your regulatory authority’s interpretation
And wrapping up for today, just a reiteration that EHS’s must be aggregated for purposes of threshold determinations.
As you can see, the range of FAQ’s is all over the map. TIme well spent to do a quick review of them to see if any others apply to your situation.
More tomorrow, here’s to March 2nd!
Community outreach: What other FAQs have you found useful (or just interesting)?
#SARA312 #SARATierII #SARATier2 #EPCRA #EGLE #March1EPAReportDeadline #ThresholdDeterminations #ExtremelyHazardousSubstances #EHS #ThresholdPlanningQuanitity #TPQ #EPAFAQ #CERCLAFAQ #SARAFAQ #EHSThresholdDeterminations #SARATier2Acids #SARATier2Vehicles #Tier2AlternateContainterType #Tier2AlternatePressure #Tier2AlternateTemperature #Tier2NoSpecificGravity #Tier2SDSMissingInformation
Michigan Environment, Great Lakes, and Energy EGLE links from all three 2022 SARA 312 virtual training course webinars:
I’m reposting these links with my daily Tier2 post because they are so useful.
You can sign in and watch/listen even if you didn’t sign up for the webinar series.
RECORDING LINK FOR SESSION 2: Wed Jan 19, 2022.
Really good example on batteries. This is the “in the weeds” how to conduct your threshold determinations episode: https://attendee.gotowebinar.com/recording/4027906237723673347
I talked to Mike Young, one of the presenters, right after the first webinar. He said that it’s not unusual for them to take phone calls from people from other states (with the warning to confirm that your state doesn’t have differences in their requirements compared to Michigan).
RECORDING LINK FOR SESSION 1:
https://attendee.gotowebinar.com/recording/7957790593170499843
Michigan uses Tier2 Manager for report submission, which is a Michigan-specific program. If your state uses different software, you will need to review its specific requirements.
RECORDING LINK FOR SESSION 3:
https://attendee.gotowebinar.com/recording/2763075340284995085
If your state uses a different software program there may be some differences, but this webinar will probably also cover how to determine the Hazard Ratings, how to enter Locations, and other details associated with report submission. I’ll post the replay when it becomes available.
PRESENTATION: (I wasn’t able to attach a copy of the presentation, email the link below and they will send it to you)
SARA TITLE III – TIER II REPORTING WEBSITE: http://www.michigan.gov/sara
MICHIGAN FACILITIES’ GUIDE TO SARA TITLE III: https://www.michigan.gov/documents/deq/deq-oea-saraguidebook_509720_7.pdf
CONTACT INFORMATION:
Mike Young and Adam Pohl
517-284-7272
