Any postal facility that stores 500 pounds or more of an extremely hazardous substance or 10,000 pounds or more of hazardous and toxic chemicals, at any time within the year, must comply with the reporting requirements of the Emergency Planning and Community Right-to-Know Act (EPCRA), a stand-alone provision of Title III, Superfund Amendments and Reauthorization Act, enacted in October 1986.
EPCRA, along with Executive Order 13514, Federal Leadership in Environmental, Energy, and Economic Performance, reiterated the need for federal agencies to lead by example in their environmental considerations. The regulations and executive order provide guidance for our ongoing commitment to preserve our country’s national resources and to meet our environmental objectives.
Postal Service™ facilities have been reporting under Section 312 of EPCRA for hazardous and toxic chemicals and extremely hazardous substances stored onsite. The reporting threshold is 10,000 pounds or greater for any chemical present (e.g., heating oil, gasoline, sand, and de-icing compounds) and 500 pounds or the threshold-planning quantity for any extremely hazardous substance (e.g., sulfuric acid and sulfuric acid in batteries) stored at a facility at any one time during the preceding calendar.
As applicable, all Postal Service installation heads should submit the emergency and hazardous chemical inventory reporting form (EPCRA Tier2 Form) annually by March 1, 2013, for the preceding calendar year, to the following entities:
n The State Emergency Response Commission (SERC).
n The Local Emergency Planning Committee (LEPC).
n The local fire department that would respond to an emergency at your facility.
Commonly reported substances/thresholds are as follows:
n Lead Acid batteries: The threshold is 500 pounds of sulfuric acid. This threshold can be met by having more than 6 tow motor batteries on site. Estimate the threshold by multiplying the battery weight by 18 percent.
n Gasoline, diesel, and heating fuel: The 10,000-pound threshold can be met at 1,433 gallons of gasoline or 1,223 gallons of diesel/heating fuel.
n Ice melt and anti-skid products (e.g., rock salt, calcium magnesium acetate, and sand): Whether delivered in one bulk location or on pallets dispersed on the site, report the product if the product exceeds 10,000 pounds.
Many states have moved to electronic reporting; if software that is not authorized on USPS® ACE systems is required for this reporting, we will continue to report by hard-copy communications. Each state’s individual reporting requirements, procedures, and forms can be accessed at http://www.epa.gov/osweroe1/content/epcra/tier2.htm. For states that recommend using EPA’s Tier2Submit 2012 software, it is anticipated that Postal Service facilities will be allowed, through an eAccess request, to download and use EPA’s Tier2Submit 2012 software for electronic reporting.
Additional detailed reporting instructions will also be made available through the appropriate regional manager of Environmental Compliance and Sustainability and on the Sustainability website at http://blue.usps.gov/sustainability/. If you have questions about your need to report under EPCRA, contact your regional manager. For Northeast, Eastern, Capital Metro Areas, and Headquarters-related facilities, contact Nicholas DeCarlo at nicholas.decarlo@usps.gov. For questions related to EPCRA reporting in the Great Lakes, Western, Southern, and Pacific Areas, contact Larry Hanna at larry.j.hanna@usps.gov.
— Environmental Compliance and Risk Management, Office of Sustainability, 1-24-13
