Chapter 12 Routine Reporting 12

CHAPTER 12 

Routine Reporting

This chapter describes:

 Routine environmental reports that may be required of fuel facilities

 Time lines for forms and reports that must be submitted to federal or state 

regulatory agencies

12.1 Regulatory Background

Several environmental regulations require facilities to submit environmental 

reports to federal or state agencies to demonstrate compliance with the regulatory requirements. This chapter discusses some of the more common reports to

be submitted, which are shown in Exhibit 12−1.

EXHIBIT 12−1

Routine Environmental Compliance Reporting

Report Act Federal 

Regulations Due Date

Emergency

Planning and

Notificatio

Emergency Plannin

and Community 

Right-to-Know Ac

of 1986 (EPC

Sections 301−304

40 CFR 35

Within 60 days of an extremely 

hazardous substance (EHS

present on-site above 

threshold planning quantity 

(TPQ); immediate notificatio

of reportable release

Safety Data Sheet 

(SDS) or List 

Submittal

EPCRA Section

40 CFR 37

29 CF

1910.1200

Submit updated SDS or list 

within three months of new 

chemicals on-site

TierII Report EPCRA Section 312 40 CFR 370 March 1,

Form  EPCRA Section 313 40 CFR 372 July 1, an

Hazardous Waste

Biannual (or 

Annual) Repo

RCRA 40 CFR 262 March 1, annually or ev

other year in some states

Discharge 

Monitoring Report

(DMR

Clean Water Act

(CWA) 40 CFR 122.

Specified in National Pollutan

Discharge Elimination System

(NPDES) permit; often monthl

quarterly and annually

Air Emission

Inventory Clean Air Act (CAA) NA1 Varies by

New Source

Performance

Standards (NSPS

and National

Emission Standards

for Hazardous

Air Pollutant

(NESHAP

Compliance 

Notifications and

Report

CAA 40 CFR 60 a

63 Varies by state 

 You must submit the Emergency 

Planning and Community Rightto-Know Act (EPCRA) Tier II reports 

to the state emergency response 

commission (SERC), local emergency planning committee (LEPC), 

and community fire department 

by March 1 every year if hazardous 

chemicals are present above specific thresholds in the prior calendar 

year (40 CFR 370.40).

 You must submit your Toxics Release Inventory (TRI) reports (Form 

Rs) to EPA and SERC by July 1 if you 

manufacture, process, or otherwise 

use toxic chemicals over certain 

thresholds in prior calendar year 

(40 CFR 372.30).

 You must submit your biennial or 

annual hazardous waste report to 

your state agency by March 1 if you 

are a large quantity generator (or 

if your state requires you to submit 

this report) (40 CFR 262.41).

 You must submit your annual air 

emissions inventory report to your 

state agency and an annual fee as 

specified by your state air quality 

department. (40 CFR Part 70 and 40 

CFR 372.10)

 You must maintain copies of 

reports, calculations, inspections, 

repairs, equipment, calibrations, 

and maintenance logs for 2, 3, or 5 

years depending on the regulatory 

requirements.

The Law Says
12-2 Chapter 12 Routine Reporti

Report Act Federal 

Regulations Due Date

Title V Permi

Compliance 

Certifications

CAA Amendment

Title V 40 CFR 70 Every 6 mon

Pipelines (off

facility)

U.S. Department

of Transportation

(DOT) Pipeline a

Hazardous Materials

Safety Administration

(PHM

49 CFR 195 June 15, annuall

1Not applicable: refer to the individual state regulations on emissions reporting.

Because of the diverse operations at U.S. Department of Defense (DoD) facilities, you must identify and comply with the requirements applicable to your

facility. Most environmental regulations require that a copy of the environmental report and supporting calculations be retained at the facility for a specified 

period of time.

12.2 Emergency Planning and Community 

Right- to-Know Act Reporting

The Superfund Amendments and Reauthorization Act (SARA) was signed in

TitleIII of SARA (commonly known as EPCRA) requires state and local g

to develop plans for chemical emergencies and requires covered facilities to report 

hazardous chemical inventories and releases of toxic chemicals. This information

reported by facilities is made available to the public through federal, state, and 

local agencies. For exclusions and exemptions from EPCRA requirements, 

Appendix 12-1.

Federal facilities have been complying with EPCRA since 1993 and Execu

Order (EO) 12856, Federal Compliance With Right-To-Know Laws and Polluti

Prevention Requirements. Since then, multiple consecutive EOs and their implementing instructions have required continued compliance with E

13834, Efficient Federal Operations, signed May 17, 2018, revoked O 13693 (th

most recent prior EO) and the implementing instructions, which required federa

facility compliance with EPCRA. As of the date of this guide, DoD has not is

guidance relating to this O or continued EPCRA compl

The DoD EPCRA an/or TRI Joint Services Working Group is

“Consolidated Emergency Planning and Community Right-to-Know Act 

Policy for DoD Installations, Munitions Activities, and Operational Ranges,” 

commonly referred to as the Consolidated EPCRA Policy, in September 2006.

policy provides DoD-specific guidance on how to apply exemptions, address 

DoD-specific situations, and other information for DoD facilities. All DoD facilities

must follow this policy, even where it is different from PA guidance or polic

12.2.1 Emergency Planning (Sections 301 to 303 of EPCRA)

If a facility has one or more extremely hazardous substances (EHSs) prese

on-site at any one time above established thresholds, regardless of its location, 

number of containers, or method of storage, it must:

Remember to promptly inform 

your LEPC of any changes at the 

facility that may impact emergency 

planning.

Don’t Forget...
Chapter 12 Routine Reporting 12

 Notify the state emergency response commission (SE

 Notify the local emergency planning committee (LE

 Provide information, when requested, to the LEPC to help it develop a loc

Emergency Response Plan (the plan usually includes a map showing locati

and quantity of stored chemicals)

 Notify the LEPC of any changes at the facility that affect emergency plann

 Designate a facility emergency coordinator or qualified individual (QI

The list of EHSs and their reporting quantities, called threshold planning quantities (TPQs), are in 40 CFR 355 regulations and are in the U.S. Enviro

Protection Agency (EPA) reference document “List of Lis

Your SERC’s address, phone number, and website are available via the link referenced in Appendix E. Contact your SERC to get the name and number of y

LEPC if you do not know this informatio

12.2.2 Notification of a Release (Section 304 of EPCRA)

You must call your LEPC and SERC immediately (and follow up in writing)

you release a reportable quantity (RQ) of an EHS (listed in 40 CFR 355) o

Comprehensive Environmental Response, Compensation, and Liability A

(CERCLA) hazardous substance (in 40 CFR 302) within a 24-hour period 

the release has the potential to travel beyond your property boundaries. The

notification requirement is in addition to the requirement to notify the National

Response Center (NRC) and other agencies if required. Refer to Chapter

Incident and Spill Reporting for more information on agency notification.

12.2.3 Submitting Safety Data Sheet Information (Section 311)

The Occupational Safety and Health Administration’s (OSHA)

Communication Standard (HCS) conforms to the United Nations Globa

Harmonized System of Classification and Labeling of Chemicals. Under thi

system, SDSs have been standardized and contain standard 16 sections. 

Under Section 311 of EPCRA and 40 CFR 370 Subpart B and C, you must s

SDSs to the LEPC, SERC, and community fire department if hazardous chemic

are present on-site above the following PA threshold quantiti

 All hazardous chemicals present at any one time in amounts equal to or over

10,000 pounds (lb) (equal to about 1,200 gallons or 22 drums)

 Any EHSs present at any one time in amounts equal to or over 500 lb (abo

55 gallons) or above the TPQ, whichever is le

Alternatively, you may submit a list of hazardous chemicals for which you have

exceeded thresholds to your LEPC, SERC, and community fire department. 

is a one-time reporting requirement, but if new hazardous chemicals become 

present in amounts that trigger reporting, then this new information must be 

submitted within 3 months of the chemical triggering reporting threshold. It is

a good practice to notify the same agencies if you discontinue using previously 

reported chemicals.

Regardless of the quantities of hazardous chemicals at your facility, you must

always have SDSs readily available to your employees.
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12.2.4 Hazardous Chemical Inventory or Tier II Reports 

(Section 312)

To promote the safety of the community and workers,EPA requires facilities

report the amounts and locations of hazardous chemicals to local emergency 

responders. Under Section 312 of EPCRA and regulations in 40 CFR 370, you

submit an annual hazardous chemical inventory report to appropriate agencies 

for all hazardous chemicals present or stored at the site at any one time in excess 

of threshold levels. 

Threshold quantities for reporting are the same as those listed for SDS submittal

as noted in the previous section (more than 10,000 lb for hazardous chemicals, 

or more than 500 lb or the TPQ for EHSs), although some states and local governments have chosen to establish more stringent reporting thresholds un

their laws.

The Tie II inventory report form is due to the LEPC, SERC, and communi

department by March 1 of every year. The report covers the chemicals on-site

during the previous calendar year. Most SERCs require electronic submittal of th

TierII fo

Contact your SERC and LEPC to determine if they require he EPA for

state-issued version of that form and whether they accept hard copy or electronic 

submittals.

The information required on the form includes a description of any type of

hazard the material may pose, the quantities stored, general storage locations, 

type of storage, and general pressure and temperature data. You will need to 

know the maximum amount of hazardous chemical present at any time and 

an estimate of the average daily amount present. The total quantity of the

hazardous chemical must be compared to the threshold by adding together all 

quantities of that chemical. For instance, if you store diesel in one aboveground 

tank and more diesel in one underground tank, then the amounts are combined 

and applied to the threshold.

The Tie II form also requires you to provide an emergency contact phone number where information is available 24 hours per day. When submitti

Section 312 information, it is suggested that any changes to the facility that 

may affect emergency planning or additional SDS submission information per 

Sections 301, 303, and 311 be provided to the SERC, LEPC, and your commun

fire department when you submit your TierII information. If requested, you m

allow an on-site inspection by the community fire department.

12.2.5 Toxic Chemical Release Inventory Reporting (Section 313)

Section 313 of EPCRA and regulations in 40 CFR 372 require certain facilitie

report the quantities of listed toxic chemicals released into the environment, 

transferred to other locations, recycled, treated, or burned for energy recovery. To

complete the RI form, called Form R, the facility must calculate or estimate 

quantity of a chemical involved in each of these waste-handling activities.
Chapter 12 Routine Reporting 12

Originally, theTRI reporting requirements applied to certain manufactur

facilities. PA later added several industry groups, including petroleum bulk storage stations and terminals (those under North American Industry Classific

System [NAICS] code 42271), to those that must file the Form R. In 1

12856 and multiple consecutive EOs since then, extended this requirement t

federal facilities regardless of their NAICS cod

As mentioned previously,EO 13834, signed May 17, 2018, revokd EO 13693

the implementing instructions, which required each federal facility to comply 

with the provisions in EPCRA and Section 313 regardless of NAICS code. As

date of this guide, DoD has not issued guidance relating to this O or continue

EPCRA complia

The DoD Consolidated EPCRA Policy contains significant policy regarding Se

313. One key item pertains to fuel SDSs and composition information. DoD facilities must use the SDS for their fuel supplier for threshold calculations. Generi

fuel compositions, such as those in PA guidance documents, are not to be use

The Defense Logistics Agency (DLA) may receive requests from DoD faciliti

and/or military installations for specific fuel SDS from the actual supplier and/or 

manufacturer in support of EP

The flow chart in Appendix 12-2 can help determine whether your facility is

subject to the RI reporting requiremen

12.2.5.1 Activity Thresholds

You must file a RI report if you have at least 10 full-time employees (or total hou

worked by all employees is over 20,000 hours/year) at your fuel facility and you:

 Manufacture over 25,000 lb per year of an individual toxic chemical, or

 Process over 25,000 lb per year of an individual toxic chemical, o

 Use 10,000 lb per year of one or more toxic chemicals, o

 Manufacture, process, or otherwise use a persistent bioaccumulative toxic 

(PBT) chemical in an amount per year over the chemical-specific threshol

level.

“Manufacture” means to produce, prepare, or import into the U.S. “Processing

means incorporating a manufactured chemical into a product for distribution 

in commerce. “Processing” includes using the chemical as a reactant, in formulations, and repackaging. For example, blending and mixing of additives or other

agents into gasoline and aviation fuel before distribution into commerce is 

processing. “Repackaging” means transferring the material from one container to

another container, such as the transfer from bulk storage tanks to tanker trucks 

for further distribution. Recycling of a chemical for sale is also considered processing. Relabeling or redistributing the chemical without repackaging does no

constitute processing.

Any use of a toxic chemical that is not covered under manufacturing or processing is to “otherwise use” the chemical and is subject to the 10,000 lb threshold.

Examples of chemicals that are otherwise used by a facility are processing aids,

catalysts, inhibitors, and solution buffers that are not intended to remain in or 
12-6 Chapter 12 Routine Reporti

become part of the product. Other chemicals that may come under “otherwise

used” are process lubricants, metal working fluids, coolants, refrigerants, hydraulic fluids, degreasers, cleaners, fuels, and waste treatment chemicals.

There are over 650 chemicals and 30 chemical categories that may require reporting if released or otherwise managed over the thresholds (stated previously). Thi

list of toxic chemicals can be found in 40 CFR 372.65 or EPA’s reference docume

“List of Lists.” The list of toxic chemicals is periodically updated and is printed

yearly in the Toxic Chemical Release Inventory Reporting Forms and Instructions; 

these documents also can be downloaded from the A TRI home page. Ex

12−2 lists common RI chemicals found in fue

When determining whether a threshold for a toxic chemical has been exceeded, 

you must consider pure forms and the amounts of that toxic chemical in mixtures. 

Analytical data and SDSs for your facility’s products can be used when making

these determinations. The amount of a chemical contained in mixtures is determined by multiplying the percent composition by the total weight of the mixture.

If you do not have specific information on the toxic chemicals in the petroleum

product at your facility, use the default values provided in Appendix 12-3.

An estimate of how much jet fuel (as well as other petroleum products) must be

processed to exceed the 25,000 lb reporting threshold for certain toxic chemicals 

are found in Appendix 12-4.

EXHIBIT 12−2

EPCRA Section 313 Chemicals Commonly Processed or Otherwise Used by 

Petroleum Bulk Storage Facilities

Type Chemical

Gasoline benzene, ethylbenzene, methyl tert butyl ether (MTBE), 

hexane, toluene, 1,2,4−trimethylbenzene, xylene (mixed isomers)

No. 6 Fuel Oil hydrogen sulfide, naphthalene

Crude Oil benzene, n−hexane, xylene (mixed isomers)

No. 2 Fuel Oil/Diesel Fuel n−hexane, 1,2,4−trimethylbenzene

Lubricating Oils zinc compounds

Aviation Gas benzene, toluene, xylene (mixed isomers)

Jet Fuel (JP-4) benzene, cyclohexane, n−hexane, toluene, xylene (mixed 

isomers), ethylbenzene

JP-5 naphthalene, 1,2,4−trimethylbenzene, xylene

JP-8/Jet A naphthalene, 2−methoxyethanol, 1,2,4−trimethylbenzene, 

benzene

12.2.5.2 TRI Reports

You’re required to submit a separate RI form (Form R)to EPA and the state agency by July 1 of every year for each toxic chemical manufactured, process

otherwise used in excess of the specific threshold in the previous calendar year. 

DoD Instruction (DoDI) 4715.4, Pollution Prevention, requires that you submit 

copy of your Form  to the Office of the Deputy Under Secretary of Defen

Fuel could contain additives such 

as antioxidants, biocides, corrosion 

inhibitors, oxygenates, detergents, 

icing inhibitors, and thermal stability additives. The precise chemical 

composition of the additives may 

be in the SDS, the fuel specification, 

or proprietary to the manufacturer.

Did You Know?
Chapter 12 Routine Reporting 12

EPA provides a web-based application that enables facilities to file a paperle

report, significantly reducing data errors and allowing instant receipt confirmation of submissions. “Toxics Release Inventory − Made Easy Web” (TRI

requires no downloads or software installs and is EPA’s required method f

reporting toxic chemical releases under the RI program. All states accept 

TRI−MEweb electronic submiss

The FormR reports reflect total releases, both routine and accidental, durin

the previous calendar year (for example, July 1, 2019, for activities during the 

period from January 1 to December 31, 2018). The types of releases that must be

reported are:

 Point emissions from stack

 Fugitive emissions (loading losses, spills, equipment leaks)

 Wastewater discharges

 Discharge into on-site underground injection wells

 On-site land disposa

 Off-site waste transfers or shipment

 On-site waste treatmen

 On-site recycling and energy recovery processe

You are required to report any source reduction and recycling efforts for these 

chemicals. Several techniques may be used to estimate releases, such as analysis 

of monitoring data, mass balance calculations, use of emission factors, and 

calculations based on engineering equations and judgment. TheEPA F

instructions provide several examples of calculations used to estimate releases. 

Here is some of the information you may need to complete your Form R

 Annual inventory/shipping dat

 Safety Data Sheets

 Waste disposal records and manifests

 Analytical dat

 Purchasing records from supplier

 Process flow diagram

 Process throughput quantities and flow rate

 Spill reports

 NPDES permits and discharge monitoring repo

 Hazardous waste generator repor

 TierII repo

 Previous years’ FormR Repo

Once submitted, you must keep on-site a copy of each FormR filed and th

supporting documents, calculations, and worksheets used to complete the form 

for at least 5 years.

DoDI 4715.4 requires that you also 

submit your Form R to the Deputy 

Under Secretary of Defense for Environmental Security (DUSD(ES)).

Did You Know?
12-8 Chapter 12 Routine Reporti

12.3 Hazardous Waste Generator Reports

As mentioned in Chapter 7, Hazardous and Recycled Waste, you must determine

the quantity of hazardous waste generated per month and meet the corresponding generator requirements for managing the waste. Based on the monthly 

quantity of hazardous waste generated, your facility will fall under one of three 

categories: a large quantity generator (LQG), a small quantity generator (SQG), o

a very small quantity generator (VSQG). Federal regulations (40 CFR 262) requir

LQGs of hazardous waste to submit a biennial report onEPA Form 870013 

EPA by March 1 of every even-numbered yea

This report includes only the hazardous wastes generated during the previous

calendar (odd-numbered) year.

Most states have been granted the authority to administer the hazardous waste 

regulations, and many states require annual instead of biennial hazardous waste 

reporting (refer to Appendix 7−4 in Chapter 7, Hazardous and Recycled Waste). 

Some states may require SQGs or VSQGs to submit an annual or biennial report

Some states have their own forms for hazardous waste reporting. Be sure to contact your state agency or refer to your state regulations to determine when and 

whether you are required to submit a hazardous waste report. The state agency

will mail you the forms and an instruction book for completing them.

The hazardous waste report consists of completing specific forms pertaining to

the facility’s hazardous waste activities during the previous calendar year. For 

each report, you’ll need to provide the following information:

 General facility information (facility’sEPA identification [ID] number, n

address, land type, contacts, waste activities, waste codes)

 PA ID number of each hazardous waste transporter used throughout 

year

 PA ID number and address of each treatment, disposal, or recycling facil

that received the waste

 Descriptions and quantities of each hazardous waste generated and shipped 

off-site

You must keep a copy of each annual or biennial report at the facility for at least 

3 years.

In addition, theEPA requires that the generator update the facility’s Notifica

of RCRA Subtitle C Activity (EPA form 8700−12) form when site contact, hazardous waste generator status or waste code information changes. Some 

require an annual update of this form, and some states require annual fee 

payments.

12.4 Wastewater Monitoring Reports

As mentioned in Chapter 9, Wastewater and Stormwater, facilities that discharge

wastewater to public waterways, such as streams, rivers, wetlands, and lakes, 

must have a permit for these discharges. These permits are issued under the

It is a good practice to document 

your weekly hazardous waste container inspections.

Don’t Forget...
Chapter 12 Routine Reporting 12

NPDES program or corresponding state program. To ensure compliance with 

terms of the permit, monitoring, and reporting may be required on a case-bycase basis.

The monitoring and reporting sections in NPDES permits specify the ty

and frequencies for chemical, physical, and biological analyses that must be 

performed on wastewater samples. Results of these analyses must be reported

to the permitting agency on a regular basis using a discharge monitoring report 

(DMR) or equivalent state form. Th EPA is using an online reporting tool ca

Network Discharge Monitoring Report (NetDMR); some states use this tool wh

other states have their own online reporting tools. The frequency of monitoring

can be monthly, quarterly, semiannually, or annually and is determined on a 

case-by-case basis, depending on the nature and effect of the discharge. Results

from any monitoring, in addition to that required in the permit, must also be 

submitted to the regulatory agency. The monitoring data are used by the agency

to determine if the wastewater discharges are in compliance with permit limits.

12.5 Stormwater Monitoring Reporting

As mentioned in Chapter 9, Wastewater and Stormwater, most states are authorized to implement the NPDES stormwater permitting progrm. EPA r

the permitting authority in a few states, territories, and tribal nations. Each state

general or individual stormwater permit has different requirements for collecting 

and analyzing samples of stormwater runoff and how monitoring data should be 

reported. The specific requirements are tied to the industrial activity at a facility, or

the facility’s industrial sector. Most permits require routine stormwater inspections, 

as well as additional inspections before, during, and after certain rain events. In

addition to inspections, there could be stormwater monitoring requirements for oil 

and grease, suspended solids, metals, and other pollutants. For instance, facilities 

subject to EPA’s Multi Sector General Permit (MSGP) must subit to EPA all monitoring data collected no later than 30 days after receiving complete la

for all monitored outfalls. PA requires the following MSGP forms be submi

electronically unless granted a waiver from the PA Regional Of

 Notice of Intent 

 Change 

 Annual repor

 Notice of Termination 

 DM

 Conditional No Exposure Certification 

In addition,EPA and some state agencies require an annual stormwater compliance review and submittal of an annual report (by January 30 for the previ

calendar year) summarizing sampling and analysis results, documentation of 

visual observations, the effectiveness of stormwater controls and best management practices, and identification of any unauthorized stormwater discharges. 

Some states also require submittal and agency approval of the facility’s 

Stormwater Pollution Prevention Plan (S
12-10 Chapter 12 Routine Reporti

General stormwater permits for construction activities can also have requirements similar to industrial stormwater permits. Be sure to check your facility’s

industrial and construction stormwater permit and SWPPP for reporting requirements and contact your state agency to see if they have specific forms 

electronic reporting tools for uploading monitoring results.

12.6 Air Emissions Reporting Requirements

DLA Energy facilities can be subject to several types of air quality-related reporting requirements. In addition to reporting requirements associated with operating permits, there are reporting requirements for storage tanks subject to 

Source Performance Standards (NSPS) and for bulk gasoline terminals subje

to either NSPS or National Emission Standards for Hazardous Air Poll

(NESHAP). Most state and regional air permitting programs also require facili

to submit air emission reports (sometimes called emissions inventories) for the 

purpose of license fee collection.  summary of air quality-related reporting

requirements is presented in the following paragraphs. Refer to Chapter 6, Air

Emissions for details on the air quality regulations.

12.6.1 NSPS Reporting Requirements

NSPS emissions standards applicable to a tank depend on the date that the tan

was constructed, reconstructed, or last modified; the tank capacity; and the type 

of petroleum liquid that is stored in the tank. NSPS monitoring, recordkeeping

and reporting requirements also depend on these factors.

Sources subject to an NSPS standard are subject to reporting requirement

specified in the General Provisions (40 CFR 60 Subpart A) and to report

requirements specified in the applicable Subparts K, Ka, Kb, XX, IIII, or J

12.6.1.1 NSPS General Provisions

The General Provisions of NSPS regulations specify notification requirements

sources subject to any subpart of NSPS. In general, you must notiy EPA and

state or regional air quality agency:

 Within 30 days of the anticipated date source construction is planned to 

begin

 Between 30 to 60 days before initial startup

 Within 15 days after the actual startup date

 Within 60 days of beginning any physical or operational changes to the tank 

or terminal that may increase emissions

You should consult 40 CFR 60.7 (Subpart A) to find specific reporting requirements and to confirm which reporting requirements apply to your facilit

12.6.1.2 NSPS Subparts K and Ka – Volatile Organic Liquid Storage Vessels 

Including Petroleum Storage Vessels (1973–1984)

Petroleum liquid storage tanks subject to Subparts K and Ka are not required

to submit any reports to PA or the state or regional agency, other than repor

required under the General Provisions of Subpart A. However, sources 
Chapter 12 Routine Reporting 12-

required to keep records at their facility, and these records must be available to 

agencies upon inspection of the tank or upon request. Required records include

documenting petroleum liquid stored, period of storage, and maximum true 

vapor pressure of the liquid during its period of storage. These records must be

maintained for at least 2 years from the date of measurement (or 5 years if your 

facility has a Title V operating permit)

12.6.1.3 NSPS Subpart Kb – Volatile Organic Liquid Storage Vessels 

Including Petroleum Storage Vessels

Volatile organic liquid storage tanks subject to Subpart Kb are required to submit 

reports to PA and the applicable state or regional air quality agency in additi

to reports required under the General Provisions of Subpart A. The types

reports required depend on whether the tank is equipped with a fixed or internal 

floating roof, an external floating roof, or a vapor collection and control device. 

Some of the reporting requirements include:

 Certifying that control equipment installed for fixed-roof, internal floatingroof, or external floating-roof tanks meets the required specifications

 Submitting a report within 30 days if the internal floating roof is not 

operating properly

 Describing repairs to torn seals on fixed-roof or internal floating-roof tanks 

within 30 days

 Notifying 30 days in advance of any seal gap measurements for external

floating-roof tanks and submitting the results within 60 days after the 

measurement

 For vapor collection and control devices, submitting specific measurement 

results within 6 months of initial startup

 For vapor collection and control devices, submitting semiannual reports 

listing periods of operation during which the device was not operational

Sources subject to this subpart are required to keep records at their facility, and 

these records must be available to agencies upon inspection of the source or 

upon request. Required records include documentation of petroleum liquid

stored, period of storage, maximum true vapor pressure of the liquid during its 

period of storage, tank inspection records and reports, seal gap measurements 

taken, and all maintenance performed. 

These records must be maintained for at least 2 years (or 5 years if your facility

has a Title V operating permit) from the date of measurement, maintenance, or

repair.

Consult 40 CFR 60.115b (Subpart Kb) to find specific reporting and recordkeeping requirements, and to confirm which requirements apply to your facility

12.6.1.4 NSPS Subpart XX — Bulk Gasoline Terminals

Bulk gasoline terminals subject to Subpart XX are not required to submit any 

reports to PA or the delegated state or regional agency, other than reports required under the General Provisions of Subpart A; however, sources are req
12-12 Chapter 12 Routine Reporti

to keep records at their facility, and these records must be available to agencies 

upon inspection of the source or upon request. Required records include

 Vapor tightness

 Gasoline delivery tank pressure tests for all trucks that use the facility,

updated annually

 Monthly leak inspection records

 Notifications of non-vapor-tightness to gasoline tank trucks that use the

facility

 Records of modifications, maintenance, or repair to the vapor collection and

control system

These records must be maintained for at least 2 years from the date of measurement and 3 years from the date of modification, maintenance, or repair (or 5

years if your facility has a Title V operating permit)

You should consult 40 CFR 60.505 (Subpart XX) to find specific reporting and

record- keeping requirements and to confirm which requirements apply to your 

facility.

12.6.1.5 NSPS Subpart IIII — Stationary Compression Ignition Internal 

Combustion Engines

Stationary compression ignition internal combustion engines (CI ICE) subject 

this regulation (40 CFR 60.4200) require manufacturer certification of all engines,

except “very large” engines (units with over 30 liters/cylinder displacement). You 

will need to install, configure, operate, and maintain the engine according to the 

specifications and instructions provided by the engine manufacturer.

If you have pre-2007 model year engines with a displacement that is less than 30

liters per cylinder and Tier 1 fire pump engines subject to the rule, then you can

demonstrate compliance by purchasing an engine that is certified to meet the 

non-road emission standards for the model year and maximum engine power of 

the engine. To demonstrate compliance with the emission standards, you can use

other information, such as:

 Performance test results for each pollutant for a test conducted on your

engine or a similar engine

 Data from the engine manufacturer

 Data from the control device vendor

Engine manufacturers and/or control device vendors may provide this information at the time of sale in the form of a Certificate of Conformity. If you choos

to conduct a performance test to demonstrate compliance with the subpart, the 

test must be conducted according to the regulations of 40 CFR 1039, Subpart F.

Regardless, you must keep the records that indicate that the engine is complying

with the emission standards. These records need to be available for inspection by

the enforcing agency.

You will need to provide initial notification to the state and PA if you ha

non-emergency engines greater than 3,000 horsepower (hp) or with a 
Chapter 12 Routine Reporting 12-

displacement of greater than or equal to 10 liters per cylinder. You’ll also need to 

provide notification if you have non-emergency stationary pre-2007 model year 

engines greater than 175 hp that are not certified. The initial notification for both

situations includes:

 Name and address of the owner or operato

 Address of the engin

 Engine make, model, engine family, serial number, model year, maximum

power, and displacement

 Emission control equipmen

 Fuel used

If you modify or reconstruct an engine and it becomes subject to this regulation,

then you will need to conduct an initial performance test on the engine as 

described above. You may need to apply for an air construction permit with the 

designated agency for this engine.

If you have very large engines (units with over 30 liters/cylinder displacement),

then you will need to conduct an initial performance test to demonstrate compliance with the emissions reductions requirements and establish operating 

parameters and monitor operating parameters continuously. If you have large,

non-emergency engines, then you must conduct annual performance tests.

Required records for engines subject to this subpart include

 All notifications submitted to comply with this subpart and all

documentation supporting any notification.

 Maintenance conducted on the engine.

 For non-certified engines, demonstration of compliance with the emission 

standards for non-certified engines as described previously.

 For certified engines, documentation from the manufacturer that the engine 

is certified to meet the emission standards.

 For emergency engines, records of hours of operation, as recorded through 

the non-resettable hour meter. You must record the time of operation and 

the reason the engine was in operation during that time.

If you operate an emergency engine that is engaged in an emergency demand

response program, additional recordkeeping and reporting requirements may 

apply. Chapter 6, Air Emissions contains additional information concerning 

operating requirements for emergency engines.

12.6.1.6 NSPS Subpart JJJJ — Stationary Spark Ignition Internal Combustion 

Engines

Stationary spark ignition internal combustion engines (SI ICE) subject to 40

60.4230 (Subpart JJJJ) must be certified by the manufacturer to meet applicable 

emission standard and must be installed, configured, operated, and maintained 

according to the specifications and instructions provided by the engine manufacturer. If your engine is not certified by the manufacturer or you do not operate

and maintain a certified engine and associated control devices according to the 
12-14 Chapter 12 Routine Reporti

manufacturer’s written specifications and instructions, you must demonstrate 

compliance via other requirements specified in Subpart JJJJ, which may include 

stack testing, conducting specific maintenance, and/or operating within specific time limits. These requirements vary depending on the size and use of the

engine.

You must keep records of the following information:

All notifications submitted and supporting documentation to comply with this

subpart:

 Maintenance conducted on each engine

 Engine manufacturer’s certification

 If an engine is not certified or is operating in a non-certified manner,

documentation that the engine meets the emission standards

If you operate a stationary SI ICE greater than or equal to 500 hp manufactu

after July 1, 2010, that has not been certified by a manufacturer, you must submit 

an initial notification. This notification must include

 Name and address of the owner or operato

 Address of the engin

 Engine make, model, engine family, serial number, model year, maximum

power, and displacement

 Emission control equipmen

 Fuel used

If you operate a stationary SI ICE in a non-certified manner, you’re required

keep a maintenance plan and records of conducted maintenance to demonstrate 

compliance. If this engine is 100 hp or larger, you’ll need to conduct an initial

performance test within 1 year of engine startup. If this engine is larger than

500 hp, you’ll need to conduct subsequent performance tests every 8,760 hours 

of operation or 3 years, whichever comes first. Non-emergency engines greater

than 500 brake horsepower (bhp) installed after July 1, 2010, are required to 

have a non-resettable hour meter. Emergency engines greater than or equal to

130 bhp and less than 500 bhp built on or after January 1, 2011, and emergency 

engines less than 130 bhp built on or after July 1, 2008, that do not meet the 

standards applicable to non-emergency engines are required to have a non-resettable hour meter.

For those engines classified as emergency backup engines, it is required that the 

hours of operation be recorded, as reflected by the non-resettable hour meter. 

Information recorded must include the hour meter reading, duration of operation, and reason for operation. If an engine is engaged in an emergency deman

response program, additional recordkeeping and reporting requirements may 

apply. Chapter 6, Air Emissions contains additional information concerning 

operating requirements for emergency engines.
Chapter 12 Routine Reporting 12-

12.6.2 NESHAP Reporting Requirements

NESHAPs generally apply to facilities that emit large quantities of hazardous

pollutants (HAPs). Check with your state or regional air quality agency for the

specific list of HAPs since they are free to add additional pollutants to the lis

major source is a facility that has the potential to emit over 10 tons per year (tpy) 

of any one AP or over 25 tpy of total HAPs combined. Area sources are d

as stationary source of HAPs that do not meet the definition of major sour

The General Provisions (40 CFR 63 Subpart A), or portions of it, apply to all facilities subject to NESHAP, an Subpart R applies specifically to gasoline di

facilities. 

Subpart EEE applies to non-gasoline organic liquids distribution, and Subp

ZZZZ applies to stationary reciprocating internal combustion engines (RICE

Reporting requirements for each are outlined in the following sections

12.6.2.1 NESHAP General Provisions

Agency notification is required for major source facilities that wish to construct,

reconstruct, or modify their operations in ways that affect air emissions. Existing

stationary RICE at area sources are also subject to notification requirements.

general, you must notify PA and your air quality agen

 When you intend to construct a source subject to a subpart under N

(this may be submitted with the construction permit application)

 120 days after you become subject to this subpart

 Within 60 days before performance testing of any vapor processing system, if 

required

 By submitting continuous monitoring system (CMS) performance results, if 

required

 By submitting Title V compliance status report

New emergency and non-emergency engines greater than 500 bhp at major

sources are required to submit only an initial notification and are otherwise 

exempt from requirements of this NESHAP. The initial notification should in

the initial notification information and a statement that your stationary RICE h

no additional requirements and explain the basis of the exclusion.

Be sure to consult 40 CFR 63.9 (Subpart A) to find specific reporting and recordkeeping requirements and to confirm which requirements apply to your facilit

12.6.2.2 NESHAP Subpart R – Gasoline Distribution Facilities

Bulk gasoline terminals are defined as facilities that receive gasoline by pipeline, 

ship, or barge with a throughput of 20,000 gallons per day and associated pipeline breakout stations. Subpart  of 40 CFR 63 applies to gasoline distributio

facilities and pipeline breakout stations that are major sources of HAPs themselves or are located within or adjoining a larger facility that is a major source 

HAP emissions. Sources subject to this subpart are required to submit reports 

EPA or the delegated agency in addition to reports required under the Gene
12-16 Chapter 12 Routine Reporti

Provisions of Subpart A. Some of the reporting and recordkeeping requirement

for gasoline terminals consist of:

 Initial notification submitted toEPA or the designated agency of the ty

identification number, and location for all gasoline equipment 1 year after an 

affected source becomes subject to the provisions of this subpart

 Records of the test results for each gasoline cargo tank, including annual

certification testing and continuous performance testing

 Records of monthly inspections (sight, sound, and smell) of all gasoline

service equipment for leaks

 Documentation of the date and method of repairing equipment leaks

 Reports submitted toEPA or the designated agency noting occurrence of 

excess emissions

 Continuous monitoring data with specific operating parameters for control 

devices (such as flares, thermal oxidation systems, refrigerated condensers, 

carbon adsorption systems)

 Semiannual reports for vapor collection and control devices listing periods 

during terminal operation when the device was not working

As with many other reports, you’re required to keep records at your facility, and

these records must be available to federal and state agencies upon inspection. 

You must maintain the records on-site for at least 5 years from the date of measurement, maintenance, or repair. Consult 40 CFR 63.428 (Subpart R) and your ai

permit to find specific reporting and recordkeeping requirements and to confirm 

which requirements apply to your facility.

12.6.2.3 NESHAP Subpart EEEE – Organic Liquids Distribution (NonGasoline) Facilities

Non-gasoline distribution facilities regulated under 40 CFR 63.2330 (Subpar

EEEE) are those that distribute organic liquids other than gasoline that are ma

sources of AP emissions by themselves or are located within or adjoining

larger facility that is a major source of AP emissions and that are not regulat

by another NESHAP. Under this rule, gasoline, aviation gasoline, kerosen

1 distillate oil), diesel (No. 2 distillate oil), asphalt, and heavier distillate oils and

fuel oils are excluded. This subpart applies to liquefied natural gas storage and

pressure pipelines. In addition,HAP materials, such as oxygenates like 

used in fuel blending and hydrazine or other missile fuels could be regulated by 

Subpart E

Some of the reporting and recordkeeping requirements for the organic liquid 

distribution facilities include:

 Initial notification submitted toEPA or the designated agencyof 

construct, reconstruct, or start operations

 Notification of Compliance Status toEPA or the designated agency if you 

required to conduct a performance test, design evaluation, or other initial 

compliance demonstration
Chapter 12 Routine Reporting 12-

 Notice of an upcoming performance test toEPA or the designated agency

you are required to conduct a test

 Records on the CMS for controlled source

  compliance report every 6 months toEPA or the designated agency

report emission deviations, malfunctions, CMS information, and related 

information regarding the affected sources

 Documentation of sources, such as tanks and transfer racks, that are not 

required to be controlled

 Written startup, shutdown, and malfunction plan for controlled sources

 Transport vehicles must have a current certification in accordance with the

DOT pressure test requirements of 49 CFR 180 for cargo tanks and 49

173.31 for tank cars

You should consult the regulation for specific reporting and recordkeeping 

requirements, operating limits, and work practice standards for HAPs emitt

from organic liquids distribution (non-gasoline) operations at major sources of 

HAP emissio

12.6.2.4 NESHAP Subpart ZZZZ – Stationary Reciprocating Internal 

Combustion Engines

Stationary RICE may be fueled by gasoline, diesel fuel, natural gas, and oth

types of fuels. If you are subject to this rule (40 CFR 63.6580), you must submi

all of the applicable notifications as listed in the NESHAP General Provisio

CFR 63, Subpart A), summarized previously, which includes an initial notification

notification of performance test or evaluation, and a notification of compliance 

for each stationary RICE that must comply with the specified emission a

operating limitations. In addition, you must submit an initial notification for each

of the following:

 An existing stationary RICE with site rating of less than or equal to 500 

located at a major source

 An existing stationary RICE located at an area so

  stationary RICE with a site rating of more than 500 bhp located at a ma

source

  new or reconstructed four-stroke lean burn (4SLB) stationary RICE rated

250 bhp or greater located at a major source

Notifications are not required for existing stationary RICE less than 100 hp, existing stationary emergency RICE, or existing stationary RICE that are not s

any numerical emission standards.

When, and if, the notifications are due depends on the type, size, and location of 

the RICE and when it is started 

You must record all data necessary to demonstrate you are in compliance with 

the emission limitations and operating limitations (if applicable) as required by 

the regulation. Your records must be in a form suitable and readily available for 

review. You must also keep each record for 5 years following the date of each 

occurrence, measurement, maintenance, corrective action, report, or record. 
12-18 Chapter 12 Routine Reporti

Records must remain on-site for at least 2 years and then can be maintained

off-site for the remaining 3 years.

You must submit a compliance report semiannually or, if your RICE is a limit

use engine subject to numerical emission limits or a new or reconstructed 

non-emergency RICE that combusts landfill gas or digester gas equivalent 

10% or more of the gross heat input, you must submit a compliance report 

annually. This report should contain information including company name and

address, a statement by a responsible official that the report is accurate, and a 

statement of compliance or documentation of any deviation from the requirements of the regulation during the reporting period.

If you operate and maintain an engine solely for emergency purposes, you must

equip the engine with a non-resettable hour meter and record the hour reading 

at the time of operation, the duration the engine operated, and the reason for 

operation. Additionally, if the emergency engine is engaged in an emergency

demand response program, then additional recordkeeping and reporting 

requirements apply. Chapter 6, Air Emissions contains additional information 

concerning operating requirements for emergency engines.

12.6.3 Risk Management Plan Reporting

The chemical accident prevention provisions (40 CFR 68) require facilities tha

produce, handle, process, distribute, or store certain chemicals to develop a 

Risk Management Program, prepare a Risk Management Plan (RMP), and s

the RMP to EPA. Refer to Chapter 1, Environmental and Emergency Res

Planning for more information on RMPs. Software called RMP*eSubmit contin

to be the method for facilities to use for online RMP reporting. RMPs must

fully updated and resubmitted once every 5 years. States may choose to implement the chemical accident prevention program, so check with your state on 

their applicability and reporting requirements.

12.6.4 Annual Emissions Inventory Reporting

Most air quality agencies require reporting of emissions from both permitted 

and unpermitted sources. Some sources are exempt from permitting but may not 

be exempt from annual emissions inventory requirements. DLA Energy facilitie

should expect to report emissions from all fuel storage tanks, vapor control 

systems, and flares. Many agencies also may require estimating emissions from:

 Normal leakage of valves, pump seals, flanges, and connector

 Loading and unloading

 Cleaning and maintenance, such as blowing out pipes

 Spills

 Small sources exempt from permitting requirements

Actual testing of emissions sources (stack sampling or continuous emissions

monitoring) is sometimes required to demonstrate environmental compliance. 

Most agencies allow emissions test results to be used for determining annual 

emissions and license fees. 
Chapter 12 Routine Reporting 12-

Some state agencies require annual fees to be based on maximum allowable 

(permitted) emissions. Tools to estimate emissions and prepare inventories are

discussed in Appendix 6−4 in Chapter 6, Air Emissions. Be sure to consult the 

regulations of your specific agency to determine acceptable inventory reporting 

and emissions fee determination requirements and methods.

12.6.5 Title V Compliance Certification Reports

As mentioned in Chapter 6, Air Emissions, if your facility is separate from a

DoD installation, it is likely below the Title V major source emission threshold.

However, if your facility is a tenant on a DoD installation that has emissions in

aggregate that exceed the thresholds, then your facility would be considered 

part of a major source and must be included in the installation’s Title V operating

permit. Facilities with Title V operating permits are required to submit records of

monitoring results and operating data (such as fuel throughput) periodically to 

EPA and the designated agency. Frequency of reporting is often annual, semiannual, or quarterl

For major DLA Energy facilities, periodic reporting frequency and requirement

will be detailed in the installation Title V operating permit and will consist of

reports required under NSPS and NESHAP regulations. Periodic com

reports must include a compliance certification statement signed by the installation responsible official, declaring that all reported information is true, accurate, 

and complete. In addition, Title V operating permits require facilities to promptl

report deviations from permit conditions to the air agency (such as exceeding 

emissions limits during operational upsets).

12.6.6 Greenhouse Gas Reporting

In 2009,EPA issued the Final Mandatory Reporting of Greenhouse Gas

(MRR) in 40 CFR 98, which required various facilities, including facilities that combust fuels in stationary sources, to submit annual reports of their greenhouse g

(GHG) emissions o EPA if they emit 25,000 tpy or more of carbon dioxide equivalent (CO2e) emissions. In addition to facilities that emit greater than 25,

CO2e of GHG, suppliers of certain products are required to submit an annual rep

of HG emissions regardless of the quantity f GHG that is emitted annually

includes suppliers of petroleum products, natural gas, and natural gas liquids.

The gases covered by the rule are carbon dioxide (CO2), methane (CH4), nitrog

dioxide (N2O), hydrofluorocarbon (HFC), perfluorinated compound (PFC), sulp

hexafluoride (SF6), and other fluorinated gases including nitrogen trifluoride and 

hydrofluorinated ethers reported in CO2e. In most cases, DLA Energy facilities 

unlikely to have regulated sources that emit any of the fluorinated gases (HFC,

PFC, SF6, nitrogen trifluoride, and hydrofluorinated ethers). DLA Energy faciliti

are unlikely to emit CH4 or N2O except as by-products of combustion, in whi

case the CO2e emissions are generally less than 1% of the CO2 emissions fro

such combustion.

For evaluating the applicability of EPA’s MRR requirement (that is, comparin

the 25,000 tpy threshold), facilities include only the emissions from listed source 

categories; none of the listed categories include Scope 2 or Scope 3 emissions or 

mobile sources (for example, vehicles). According to the EPA, Scope 2 emissi
12-20 Chapter 12 Routine Reporti

are HG emissions resulting from the generation of electricity, heat, or ste

purchased by a Federal Agency and Scope 3 emissions areGHG emissions f

sources not owned or directly controlled by a Federal Agency, but related to

agency activities. 

The rule currently contains 42 categories of sources that must be reported, but

the majority are industrial processes that don’t apply to DLA Energy facilities (fo

instance, petroleum refineries or nitric acid production). Electricity production is

a listed source category, but this is intended to cover large stationary combustion sources that are regulated under EPA’s existing acid rain progr

Applicability of the rule for some source categories is based on source capacity

or throughput and not comparison of calculated HG emissions to the 25,0

tpy threshold. For example, industrial waste landfills are regulated based on volume of the waste in the landfill, and if MRR applicability is triggered based on th

landfill volume, then sources such as stationary combustion must automatically 

be reported regardless of emissions.

As noted above, suppliers of petroleum and natural gas must report the emissions associated with combustion of those fuels regardless of applicability of the

25,000 tpy threshold, but it is also considered unlikely that these requirements 

will apply to DLA Energy. For petroleum products, the rule applies to refiners

importers, and exporters; however, the definition of exporter excludes entities 

that transfer products to U.S. military bases abroad or to ships for onboard use.

(Specifically, that definition of export excludes “...any such transport on behalf of 

the United States military including foreign military sales under the Arms Expo

Control Act...”). Similarly, DLA Energy is also likely excluded from the natural g

supplier category, as that is limited to “...companies that own or operate distribution pipelines, not interstate pipelines or intrastate pipelines, that physically 

deliver natural gas to end users and that are regulated as separate operating 

companies by State public utility commissions or that operate as independent 

municipally-owned distribution systems...” as stated in 40 CFR 98

Thus, while you are urged to review the MRR applicability per te EPA we

noted in Section 12.9, For More Information to confirm, in most cases the only 

MRR source categories applicable to military installations are stationary combustion, municipal waste landfills, and industrial waste landfill

A DLA Energy facility co-located with a DoD installation that has emissions 

aggregate exceeding the reporting threshold of 25,000 tpy of CO2e would be

required to report HG emissions as part of that facilitys GHG annual r

Note that emissions of biomass fuels (for example, wood or biodiesel) must be

reported for regulated facilities the same as fossil fuels (coal, petroleum products, or natural gas). However in determining MRR applicability in compari

to the 25,000 tpy threshold, emissions from biomass fuels are not included in 

facility totals.

DLA Energy facilities should expect to repor GHG emissions from boil

simple and combined-cycle combustion turbines, non-emergency stationary 

engines, incinerators, thermal oxidizers, process heaters, municipal solid waste 
Chapter 12 Routine Reporting 12-

landfills, and industrial waste landfills. Under this rule, portable equipment,

emergency generators, emergency equipment, and open flares do not need to 

be considered.

Annual reports are submitted online toEPA using an electroic GHG rep

tool called e-GGRT. The tool is web-based and does not require installation of

software. Reports are due March 31 for emissions in the previous calendar year.

Facilities must register and name a designated representative (DR) in advance of

reporting and can optionally name an alternate designated representative (ADR

and agents to assist. Electronic submittals and hard copy paperwork are required

to name the DR, ADR, and agents, so it is advisable to begin the registrati

process at least 4 weeks prior to the March 31 reporting deadline.

12.7 Pipeline Annual Reports

The DOT Pipeline and Hazardous Materials Safety Administration

regulates the transportation of oil and hazardous liquids in pipelines that leave 

facility grounds (sometimes called cross-country pipelines). Beginning in 2005, 

pipeline owners or operators are required to submit an annual report using D

Form PHMSA F 7000−1.1 by June 15 for the previous calendar year. The form

available from the Office of Pipeline Safety website. This reporting requirement 

found in 49 CFR 195.49

A separate report is required for each system type, meaning separate pipelines

transmitting crude oil, highly volatile liquids (including anhydrous ammonia), 

petroleum and refined products, or carbon dioxide. The information collected on

the report consists of:

 Operator’s ID number and company informati

 Total miles of pipeline in the system at the end of the yea

 Integrity inspections conducted and resulting actions take

 Information on pipe size and break out tank

 Miles of onshore and offshore cathodically protected steel pipe

 Annual volume of hazardous liquids transported via the pipeline syste

Completed annual reports are to be submitted electronically to PHMSA port

(see Section 12.9, For More Information).

12.8 State Requirements

Many states require or voluntarily allow electronic reporting for various compliance submittals. Under the Cross-Media Electronic Reporting Rule (C

CROMERR establishes standards for electronic report receiving systems oper

by state, tribal and local governments under their authorized programs. 

State Requirements
12-22 Chapter 12 Routine Reporti

State Agency System Program Covered

Alask

Alaska Department

of Environmental

Conservation 

Air Online Services System (AOS

Compliance Monitoring Data Portal (CMDP) Wat

Water Online Application System (OASys) W

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

Alabam

Alabama Department

of Environmental

Management 

Air Emissions Electronic Reporting System (A

Electronic Environmental Data Exchange Reporting System (E2) Water - 

Arkansa

Arkansas Department

of Environmental

Quality 

Electronic Portal System (e-Portal System) Water - Waste -

Hazardous Waste Annual Electronic Reporting System (HWARS

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

State and Local Emissions Inventory System (SLEIS

Arizona Arizona Department o

Environmental Quality

Smart Notice of Intent System (SmartNOI) 

State and Local Emissions Inventory System (SLEIS

Enterprise System (myDEQ) Waste - Water - 

California

California State Water 

Resources Control

Board 

California Integrated Water Quality System - Electronic Self-Monitorin

Report (CIWQS-eSMR) Wa

Compliance Monitoring Data Portal (CMDP) Wat

Storm Water Multiple Application and Report System (SMARTS) 

Colorado

Colorado Department 

of Public Health an

Environment

Colorado DPHE Online System (CEOS) Air - Water -

- Chemicals

Colorado Drinking Water System (CDWS) Water

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

Connecticut

Connecticut 

Department of Energy

and Environmental

Protectio

Electronic Permitting System (e-Permitting System) Waste - Air - W

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

Colorado Department 

of Public Health 

Environmen

Compliance Monitoring Data Portal (CMDP) Wat

Delaware

Delaware Department 

of Natural Resources 

Environmental Control

Online Reporting System (ORS

Online Reporting System (ORS) Waste - Water 

State and Local Emissions Inventory System (SLEIS

Delaware Division of 

Public Health Electronic Sample Entry Verify (eSE Verify) 

Florida

Florida Department 

of Environmental

Protection

Electronic Reporting System (e-Reporting System) Air - Water - W

NPDES e-Reporting Tool (NeT

These standards include an application process through which states may gain

approval. Most states have been approved for some e-reporting systems. States 

with e-reporting systems are shown in Exhibit 12-3

EXHIBIT 12−3

State Routine Environmental Compliance Reporting
Chapter 12 Routine Reporting 12-

State Agency System Program Covered

Georgia Georgia Department o

Natural Resourc

Georgia Environmental Protection Division Online System (GEOS) Water - Wast

- Toxic Substance

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

Hawaii Hawaii Department o

Health

Electronic Permitting Portal (e-Permitting Portal) Water - Air - 

- Toxic Substance

Compliance Monitoring Data Portal (CMDP) Wat

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

State and Local Emissions Inventory System (SLEIS

Iow

Iowa Department of

Natural Resourc

Asbestos Notification System (ANS

State and Local Emissions Inventory System (SLEIS

Idaho Idaho Department o

Environmental Qualit

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

NPDES Electronic Reporting System 

Point Source Survey Tool (POSS

Compliance Monitoring Data Portal (CMDP) Wat

Illinois Illinois Environment

Protection Agen

Asbestos Electronic Reporting System Chemic

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

Electronic Annual Emissions Report System (e

NPDES e-Reporting Tool (NeT

Safe Drinking Water Information System Lab to State (SDWIS/Lab t

State) Water

Indian

Indiana Department

of Environmental

Protectio

Electronic Authentication System (eAuth) Air - Water - W

Electronic Sample Entry Verify (eSE Verify) Wa

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

Kansas

Kansas Department 

of Health and

Environmen

Kansas Environmental Application Portal (KEAP) Air - Waste 

Compliance Monitoring Data Portal (CMDP) Wat

State and Local Emissions Inventory System (SLEIS

Kentucky

Kentucky Department 

for Environmental

Protectio

Electronic Reporting System (ERS) Water - Waste 

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

Louisiana

Louisiana Department 

of Environmental

Quality

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

Louisiana Department 

of Healt

Compliance Monitoring Data Portal (CMDP) Wat

StarLIMS Wate

Massachusetts 

Department of 

Environmental

Protectio

Underground Storage Tanks System Was

Maryland Maryland Department 

of the Environmen

National Pollutant Discharge Elimination System e-Permits 

e-Permits) Wate

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat
12-24 Chapter 12 Routine Reporti

State Agency System Program Covered

Maine

Maine Department 

of Environmental

Protectio

Maine Air Emissions Inventory System (MAI

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

Michigan

Michigan Department 

of Environmental

Quality

Michigan Air Emission Reporting System (MAE

MiWaters Water

Minnesota

Minnesota Department 

of Health Compliance Monitoring Data Portal (CMDP) Wa

Minnesota Pollution

Control Agenc

Regulatory Services Portal (RSP) Air - Water - 

Missouri Missouri Department 

of Natural Resourc

Electronic Discharge Monitoring Report System (eDMR) Wa

Enterprise System Air - Waste - Wate

- Chemicals

Mississippi

Mississippi 

Department of 

Environmental Qualit

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

Hazardous Waste Biennial Reporting System (HWBR) W

Regulatory Services Portal (RSP) Water 

Montana

Montana Department 

of Environmental

Quality

Compliance Monitoring Data Portal (CMDP) Wat

Fees, Applications and Compliance Tracking System (FACTS) W

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

North Carolin

North Carolina

Department of the 

Environment and

Natural Resourc

Electronic Discharge Monitoring Report System (eDMR) Wa

Integrated Build Environment for Application Management (IBE

Safe Drinking Water Information System Lab to State (SDWIS/Lab t

State) Water

North Dakota North Dakot

Department of Health Electronic Reporting Information System (ERIS) Air - Water

Nebrask

Nebraska Department

of Environmental

Quality

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

Nebraska Department

of Health and Huma

Services

Compliance Monitoring Data Portal (CMDP) Wat

New

Hampshir

New Hampshir

Department of 

Environmental Service

Compliance Monitoring Data Portal (CMDP) Wat

State and Local Emissions Inventory System (SLEIS

New Jerse

New Jersey

Department of 

Environmental

Protectio

Electronic Reporting System (E2) Wa

Regulatory Services Portal (RSP) Air - Water - 

New Mexic

New Mexico

Environment

Department

Tools, Maps, and Links Webpage Air - Wat

Compliance Monitoring Data Portal (CMDP) Wat

Nevad

Nevada Division

of Environmental

Protectio

Compliance Monitoring Data Portal (CMDP) Wat

Network Discharge Monitoring Report System (State NetDMR) W
Chapter 12 Routine Reporting 12-

State Agency System Program Covered

New Yor

New York State

Department of 

Environmental

Conservation

Air Compliance and Emission Electronic Reporting System (AC

Hazardous Waste Annual Reporting System (HWARS)

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

Ohio Ohio Environment

Protection Agen

Electronic Business Center (e-Business Center) Air - Water - Was

Oklahom

Oklahoma Department

of Environmental

Quality

Electronic Document Receiving System (EDRS) Air - Water - 

Orego

Oregon Department of

Environmental Qualit

Environmental Data Management System (EDMS) Water - Air - Was

- Chemicals

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

NPDES e-Reporting Tool (NeT

Oregon Healt

Authority Compliance Monitoring Data Portal (CMDP) Wa

Pennsylvani

Pennsylvania

Department of 

Environmental

Protectio

Compliance Monitoring Data Portal (CMDP) Wat

Rhode Isla

Rhode Islan

Department of 

Environmental

Management

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

Rhode Islan

Department of Health Compliance Monitoring Data Portal (CMDP) Wa

South Carolina

South Carolina 

Department of Health

and Environmental

Control

Compliance Monitoring Data Portal (CMDP) Wat

Enterprise e-Permitting System Air - Water - Was

- Chemicals

State and Local Emissions Inventory System (SLEIS

South Dakota

South Dakota 

Department of the 

Environment and

Natural Resourc

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

NPDES e-Reporting Tool (NeT

Tennesse

Tennessee Department

of Environment and

Conservation

Compliance Monitoring Data Portal (CMDP) Wat

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

State and Local Emissions Inventory System (SLEIS

Texa

Texas Commission on

Environmental Qualit

State Network Discharge Monitoring Report System (State NetDMR) W

State of Texas Environmental Electronic Reporting System (STEERS) Water - Ai

Utah Utah Department o

Environmental Qualit

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

NPDES e-Reporting Tool (NeT

Compliance Monitoring Data Portal (CMDP) Wat

Virginia Virginia Department of 

Environmental Quality Electronic Environmental Data Exchange Reporting System (E2)
12-26 Chapter 12 Routine Reporti

State Agency System Program Covered

The Unite

States Virgin 

Island

The United State

Virgin Islands

Department Of

Planning & Natura

Resource

National Network Discharge Monitoring Report System (Natio

NetDMR) Wat

The United State

Virgin Islands

Department of Healt

Compliance Monitoring Data Portal (CMDP) Wat

Vermont

Vermont Department 

of Environmental

Conservation

Compliance Monitoring Data Portal (CMDP) Wat

Agency of Natural Resources Online System (ANR Online) Water-

Washington

Washington State 

Department of Health Washington State Lab Electronic Reporting System (WSLERS) 

Washington State 

Department of Ecolog

Generic CROMERR Solution Air 

Turbowaste.net Wast

West Virginia

West Virginia 

Department of 

Environmental

Protectio

Environmental Submission System (ESS) Air - Waste - Wa

West Virginia 

Department of Health

and Human Resourc

Drinking Water Program Electronic Data Receiving System Wa

Wyoming

Wyoming Department 

of Environmental

Quality

Environmental Information Technology Enterprise System (ENV-ITE) Waste - W

Some states require report submittal more frequently than federal requirements. 

Be sure to contact your state agency for their reporting requirements. Refer to

Appendix E for state agency contact information. For instance, some state-specific requirements include:

 In California, the online Storm Water Multiple Application and Repo

Tracking System (SMARTS) is used to submit the notice of intent, notice

termination, annual reports, application/renewal fees, and other discharger 

submitted documents related to stormwater permits. Waste managers may 

report electronically at: https://smarts.waterboards.ca.gov/smarts/faces/

SwSmartsLogin.xhtml

 Many states accept Tier2 Submit, the EPA’s ier II reporting software ava

for free download from the PA website. Other states have their 

electronic forms.

 States have the authority to impose more stringent RI requirements, a

some states have done so (for example, Arizona, Nevada, and New Jersey

Some states (such as Georgia) charge a hazardous materials discharge fee

for facilities that file a Form R, so it’s a good practice to check your state

requirements. State contacts for the RI Program are available from the T

Chemical Release Inventory Reporting Forms and Instructions. Note 

in some cases the state agency contact for RI reporting is the SERC, an

other cases it’s not.
Chapter 12 Routine Reporting 12-

 Some states require annual hazardous waste reporting instead of biennial 

(every 2 years). For example, Washington requires a “dangerous waste” annual 

report. Waste managers may report electronically using TurboWaste at:

https://fortress.wa.gov/ecy/turbowaste

 States including New Hampshire, South Carolina, and Oklahoma requi

quarterly hazardous waste reporting.

 Some states have mandatory HG reporting requirements. Vario

thresholds and triggers apply. Some states require all sources over certain 

emission thresholds (tpy) to report. Others require all Title V permit holders

all sources otherwise required to report air emissions, certain industrial 

facilities, or sources subject to New England’s Regional Greenhouse

Initiative (RGGI) to rep

 Based on applicability to Title V sources, other air permitting requirements,

or emission thresholds, there is a reasonable probability that mandatory 

state reporting requirements could apply to some DLA facilities in at

least Washington, Oregon, California, North Carolina, New Jersey, a

Massachusetts. Always check with your state and local air quality regulatory

authority.

12.9 For More Information

For Information on... See...

Agencies

National Response Center www.nrc.uscg.m

(800) 424−8802

EPA Office of Air Qua

Planning and Standards https://www3.epa.gov/airquality

EPA Office of Land 

Emergency Managemen

https://www.epa.gov/aboutepa/

about-office-land-and-emergency-management

Listings of SERCs and LEPCs www2.epa.gov/ep

state−emergency− response−commissions−contacts

PHMSA Office of Pipeline Safety www.phmsa.do

Documents and References

EPA “Tile III List of 

Consolidated List of Chemicals 

Subject to the Emergency

Planning and Community

Right-to-Know Act (EPCRA

Section 112r of the Clean Air

Act, as Amende

https://www.epa.gov/epcra/consolidated-list-lists-underepcracerclacaa-ss112r-march-2015-version

NOE: TRI program does not maintain the List of List

EPCRA home page or this direct l

TierI an II forms 

instructions from 

(800) 424−9346

www2.epa.gov/epcra/epcra−sections−311−312

Tier2 Submit Software www2.epa.gov/epcra/tier2−submit−softwar
12-28 Chapter 12 Routine Reporti

For Information on... See...

EPCRA Section 313 Indu

Guide, Petroleum Terminals a

Bulk Storage Facilities, PA 7

B−00−002. February 2000.

www2.epa.gov/toxics−release−inventory−tri− program/

guidance−petroleum−terminals−and− bulk−storage−

facilities

Automated FormR 

MEweb) Software and

guidance documents

(800) 424−9346

www2.epa.gov/toxics−release−inventory−tri− program/

tri−meweb−resources

List of state programs and 

contacts

www2.epa.gov/home/health−and− environmental−

agencies−us−states−and− territories

List of State TierII submitt

procedures.

https://www.epa.gov/epcra/

state-tier-ii-reporting-requirements-and-procedures

EPCRA Section 313 Questi

and Answers Addendum fo

Federal Facilities − Revised 1999

Version (May 2000)

https://ofmpub.epa.gov/apex/guideme_ext/guideme_ext/

guideme/file/1999qa-addendum-federal-facilities.pdf

Hazardous waste reporting

NetDMR (NPDES disch

monitoring reports) www.epa.gov/netdmr/

eNOI (EPA’s stormwa

and CGP submittals) https://www.epa.gov/npdes/electronic-notice-intent-en

Risk Management Plan

under the Chemical Accident

Prevention Provisions an

RMP*eSubm

https://www.epa.gov/rmp

EPA’s Greenhouse Gas Repo

Program and Electroni

Greenhouse Gas Reporting T

(e−G

www.epa.gov/ghgreporting/index.html

PHMSA Portal for pipel

reporting https://www.phmsa.dot.gov/forms/pipeline-forms
Chapter 12 Routine Reporting 12-

12.10 Action Items

Item Date 

Started

Date 

Completed N/A Comment(s)

Submit new or revised SDSs or lists 

of SDSs to the LEPC, SERC, 

community fire department within 

three months of acquiring a new 

hazardous chemical above the 

thresholds.



Submit your TierII report to t

LEPC, SERC, and community f

department by March 1 every year.



Contact your state hazardous waste 

agency to determine if you are

required to submit a biennial or 

annual hazardous waste report by 

the March 1 deadline.



Prepare RI or Fom R repo

for each toxic chemical you 

manufacture, process, or otherwise 

use above the thresholds and 

submit it to PA and your SER

July 1.



Review your wastewater and 

stormwater permits to determine 

whether sampling and analysis 

is required, and when the results 

should be submitted to the state 

agency.



Notify the air quality agency 

when you construct or modify 

petroleum or volatile liquid storage 

tanks subject to the air emissions 

requirements in the NSPS (40 

60 Subparts A, K, Ka, and Kb)



Comply with the specific reporting 

requirements in your air permit. 

Prepare your annual air emissions 

inventory report and submit it 

to your air agency by the date

required (varies between states). 

You may also need to pay a fee 

with your emissions report. The fee

is usually based on the quantity 

of pollutants emitted from your 

facility.



Action Items
12-30 Chapter 12 Routine Reporti

Item Date 

Started

Date 

Completed N/A Comment(s)

Comply with the applicable 

monitoring and reporting 

requirements in 40 CFR 60 Subpart

XX and 40 CFR 63 SubpartR an

Subpart EEE if your facility i

bulk terminal subject to these rules 



Maintain copies of all reports, 

records, and supporting 

calculations for the time periods 

noted in each specific regulation.


Chapter 12 Routine Reporting 12-

CHAPTER 12 

Appendices

Appendix 12−1 Exclusions and Exemptions from EPCRA

Appendix 12−2 TRI Reporting Decision Diagram EPCRA Section 313

Appendix 12−3 Estimated Concentration Values of Toxic Chemicals

 in Crude Oil and Petroleum Products

Appendix 12−4 Estimated Quantities Required to Exceed the 

 Processing Threshold for Several Petroleum Products
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Chapter 12 Routine Reporting 12-

Appendix 12-1: Exclusions and Exemptions from EPCRA

This appendix presents exemptions or exclusions from the Emergency Planning and Community Right-to-K

(EPCRA) requireme

EPCRA Sections 301–303: Emergency Planning

 Mixtures or solutions containing less than 1 percent by weight of extremely hazardous substances (EHSs) (4

CFR 355.13

 Food, additives, drugs, or cosmetics covered by the Food and Drug Administration (FDA) (40 CFR 355.

 Solid manufactured items if normal conditions of use do not present an exposure to the substance (40 CF

355.61)

 Used for personal, family, or household purposes, or is present in the same form and concentration as a product

packaged for distribution and use by the general public (40 CFR 355.61

 Used in a research laboratory, hospital, or other medical facility under the supervision of a technically qualified

individual1 (40 CFR 355.61

 Used in routine agricultural operations or is a fertilizer held for sale by a retailer for customer use (40 CFR 355.6

EPCRA 304: Emergency Release Notifications

 Releases of EHS or hazardous substances resulting in exposure to persons solely within the facility boundary (

CFR 355.31(a)

 Releases of hazardous substances or EHSs in amounts below the RQ (or if there is no RQ, below 1 lb) (

355.30)

 Federally permitted releases (40 CFR 355.31(b)

 Continuous releases stable in quantity and rate as defined in 40 CFR 302.8(b) need only provide initial

notification (40 CFR 355.32

 Pesticide products used in a proper manner (40 CFR 355.31(c

 Releases of material during transportation or storage related to transportation under active shipping papers

(EPCRA Statute Section 

EPCRA Sections 311 and 312: SDS and Tier Reporting

 Chemical or substances not required to have a Safety Data Sheet under OSHA 29 CFR 1910.1200 (40 CFR 37

 Contained in mixtures at concentrations less than 1 percent by weight of hazardous chemicals or less than 0.1 

percent for carcinogens (40 CFR 370.14(c)

 Food additives, drugs, or cosmetics covered by the FDA (40 CFR 370.13(a

 Solid manufactured items if normal conditions of use do not present an exposure to the substance (40 CF

370.13(b))

 Used for personal, family, or household purposes, or is present in the same form and concentration as a product

packaged for distribution and use by the general public (40 CFR 370.13(c)(1)

 Used in a research laboratory, hospital, or other medical facility under the supervision of a technically qualified

individual (40 CFR 370.13(c)(2)

 Used in routine agricultural operations or is a fertilizer held for sale by a retailer for customer use (40 CFR 370

13(c)(3))

1 Technically qualified individual: one who, because of education, training, or experience, can understand health and environmental risks 

used under his or her supervision
12-34 Chapter 12 Routine Reporti

 Tobacco or tobacco products (29 CFR 1910.1200(b)(6

EPCRA Section 313: Toxic Release Inventory or Form R Reporting

 Contained in mixtures at concentrations less than 1 percent by weight of hazardous chemicals or less than 0.1 

percent for carcinogens (40 CFR 372.38(a)

 Toxic chemicals present in manufactured items or articles (40 CFR 372.38(b

 Laboratory uses of toxic chemicals under the supervision of a technically qualified individual (40 CFR 372.38(d)

 Toxic chemicals used for structural components, janitorial maintenance, facility grounds maintenance, or

personal use (40 CFR 372.38(c)(1)−(3)

 Products containing toxic chemicals used to maintain motor vehicles (40 CFR 372.38(c)(4

 Toxic chemicals already present in raw water and air supplies used at the facility (40 CFR 372.38(c)(5

 Owners of real estate that lease the property and have no business interest in the operation of the facility (40

CFR 372.38(e)

 Releases of toxic chemicals from a transportation vehicle that occurs while the vehicle is still under active

shipping papers and awaiting shipment to the final destination (EPCRA Section 
Chapter 12 Routine Reporting 12-

Appendix 12-2: TRI Reporting Decision Diagram 

EPCRA Section 313

Does your facility have 10 or more full-time employees or the equivalent?

ls your facility’s primary NAlCS Code included on the EPCRA Section 313 

list? Or is your facility a Federal facility?

ls the chemical dioxin or dioxin-like compounds?

ls the annual reportable amount 

of PBT released on-site and off-site 

greater than zero?

ls the total amount PBT recycling, 

treatment, and energy recovery 

less than 500 pounds?

Does your facility manufacture, process, or otherwise use EPCRA 

Section 313 chemicals and chemical categories?

Does your facility exceed any of the thresholds for a chemical or 

chemical category (after excluding quantities that are exempt from 

threshold calculations)?

AN EPCRA SECTION 313 REPORT IS REQUIRED FOR THE CHEMICAL OR 

CHEMICAL CATEGORY

FORM R IS REQUIRED FOR THIS CHEMICAL OR 

CHEMICAL CATEGORY (FORM A CANNOT BE 

SUBMITTED)

EITHER FORM A OR FORM R MAY BE SUBMITTED FOR 

THIS CHEMICAL

ls the amount manufactured, OR processed, OR 

otherwise used less than or equal to 1 million pounds?

ls the amount manufactured, OR processed, OR 

otherwise used a persistent bioaccumulative and 

toxic substance (PBT)?

ls the annual reportable amount of non-PBT released 

on-site and off-site greater than 2,000 pounds?

ls the total non-PBT waste managed less than 5,000 

pounds?

yes

yes

yes

yes

yes

yes

yes

yes

no

no

no

no

no

no

no

no

no

no

no

yes

REPORTING IS NOT 

REQUIRED FOR THIS 

CHEMICAL AT THIS 

FACILITY FOR THIS 

CALENDAR YEAR

yes

yes

yes
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Chapter 12 Routine Reporting 12-

Appendix 12-3: Estimated Concentration Values of Toxic 

Chemicals in Crude Oil and Petroleum Products

EPCRA Section 313 

Chemical

De Minimis 

Levela Crude Oil

Gasoline 

(Various 

Grades)

No. 2 Fuel 

Oil/Diesel 

Fuel

Jet Fuel 

(JP-4) Kerosene No. 6 Fuel Oil

Aviation 

Gasoline

Benzene 0.1 0.446R 1.608R 8.0E-04A 1.0A 0.004A 0.001

Biphenyl 1.0 0.060R 0.010R 0.100 0.120R 0.120R -

Bromine 1.0 -- -- -- -- -- 3.0E-06 -

Chlorine 1.0 -- -- -- -- -- 0.0131D --

Cyclohexane 1.0 0.700 0.240 -- 1.240 -- -- --

Ethylbenzene 1.0 0.346R 1.605R 0.013A 0.50A 0.127A 0.0022

n-Hexane 1.0 2.463R 1.0T 1.0A 1.5T 0.005A --

MT

b 1.0 -- 15.000 -- -- -- -- --

Naphthalene 1.0 0.219R 0.444R 0.550 0.468R 0.733R 0.100 

Phenanthrene 1.0 -- -- 0.125 -- -- -- -

Phenol 1.0 0.323 0.055 0.064 -- 0.770 -- -

PACsc 0.1 0.0004 -- -- -- -- 1.130 

Styrene 0.1 -- @ 0.032R -- -- -- -

Toluene 1.0 0.878R 7.212R 0.032A 3.20A 0.13T 0.006

1, 2, 

4-Trimethylbenzene 1.0 0.326 2.500g 1.000g -- -- -- -

Xylene (mixed 

isomers) 1.0 1.420R 7.170 0.290A 3.20A 0.31A 0.013 2

Antimonyd 0.1 1.0E-05 -- -- -- -- 1.0E-06

Arsenicd 0.1 /1.0e 2.0E-05 -- 8.5E-06 -- -- 3.06E-05

Berylliumd 0.1 /1.0e 2.0E-07 -- 5.0E-06 -- -- 2.7E-06D

Cadmiumd 0.1/1.0e 4.0E-07 -- 2.1E-05 -- -- 2.0E-06D

Chromiumd 0.1/1.0f 4.0E-05 -- 9.5E-05 -- -- 3.1E-05D

Cobaltd 1.0 0.0003 -- -- -- -- 1.63E-04D -

Copperd 1.0 4.0E-05 -- 5.6E-04 -- -- 3.0E-05

Lead Compounds 1.0 (organic)

0.1 (inorganic) -- -- -- -- -- 1.41E-04D 0.14(organic)

Manganesed 1.0 -- -- 2.1E-05 -- -- 3.5E-05D 

Mercuryd 1.0 0.0006 -- 4.0E-05 -- -- 9.2E-07D 

Nickeld 0.1 0.0055 -- 3.38E-04 -- -- 2.6E-03 D

Seleniumd 1.0 4.0E-05 -- -- -- -- 9.5E-06 D 

Silverd 1.0 -- -- -- -- -- 2.0E-08 -

Zinc Compounds 1.0 -- -- -- -- -- -- --
12-38 Chapter 12 Routine Reporti

Unless otherwise noted, source: Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313, Appendix 

“Composition of Crude Oil and Petroleum Product

American Petroleum Institute report prepared for Mr. Jim Durha, EPA (December 23, 1993), regarding revised estimates of 

petroleum product liquid constituents that are listed as hazardous air pollutants (HAPs) under section 112 of the Clean Air Act Amend

(CAA

Radian Corporation report prepared for Mr. Jim Durham,EPA (August 10, 1993), regarding liuid HAP concentrations of various pe

products.

D

Appendix D, Study of Hazardous Air Pollution Emissions from Electric Utility Steam Generating Units--Final Report to Con

OAQPS (February 1998) 453/R-98-0

These values have been revised to be consistent with the current version of EPA’s emission estimation program TAN

- Concentration data not available based on data sources reviewed

a

The de minimis concentration values for the metals is for the metal compound

b

MTBE may be present to enhance octane in concentrations from 0-15

c

The petroleum products may contain one or more of the following chemicals under the polycyclic aromatic compounds (PACs) catego

benzo(a)anthracene, benzo(b)fluoranthene, benzo(j)fluoranthene, benzo(k)fluoranthene, benzo(rst)pentaphene, benzo(a)phenanthrene, 

benzo(a)pyrene, dibenz(a,h)acridine, dibenz(a,j)acridine, dibenzo(a,h)anthracene, 7H-dibenzo(c,g)carbazole, dibenzo(a,e)fluoranthene,

dibenzo(a,e)pyrene, dibenzo(a,h)pyrene, dibenzo(a,l)pyrene, 7,12-dimethylbenz(a)anthracene, ideno(1,2,3−cd)pyrene, 5-methylchrysene, 

1-nitropyrene. For No. 6 fuel oil, the value given is for benzo(a)anthracene

d

Constituents are most likely metal compounds rather than the elements. Elements are listed in this table because concentration data

are for only the metals occurring in the fuel. Concentrations for metal compounds would be somewhat higher depending on the metal 

compound. For threshold determination, if the weight of the compound is not known, facilities may use the weight of the lowest metal 

compound likely to be present.

e

The de minimis level for inorganic compounds is 0.1; for organic compounds is 1.0

f

The de minimis level for chromium VI compounds is 0.1; for chromiu III compounds is

g

Concentrations updated with comments received from A

h

Lead compounds and n-Hexane concentration for Aviation Gasoline 100 (Exxon-MS

@Data from PA report prepared by Radan Co. for this constituent are considered suspect and are not recommended for use, based

discussion with Mr. Jim Durham of PA on November 30, 1
Chapter 12 Routine Reporting 12-

Appendix 12-4: Estimated Quantities Required to Exceed the 

Processing Threshold for Several Petroleum Products

Product

EPCRA Section 313 Chemicals 

that May Be Present Above 

De Minimis

Concentration 

(weight percent)

Quantity of Product Required 

to Meet the 25,000 lb 

Threshold for Processing 

(Gallons)

Gasoline (various grades

Benzene 1.608 258,389

Ethylbenzene 1.605 258,87

MTBE 15.000 27,6

n-Hexane 1.0 415,28

Toluene 7.212 57,61

1,2, 4−Trimethylbenzene 2.500 166,19

Xylene (mixed isomers) 7.170 57,948

No. 6 Fuel Oil Benz(a)anthracene (PACs) 1.130 276

Crude Oi

Benzene 0.446 794,526

n-Hexane 2.463 143,87

Xylene (mixed isomers) 1.420 249,548

No. 2 Fuel Oil/Diesel Fuel 1,2,4-Trimethylbenzene 1.000 357,

Lubricating Oil Zinc Compounds 1.000 351,86

Aviation G

Benzene 0.515 831,940

Toluene 7.327 58,47

Xylene (mixed isomers) 2.204 194,396

Jet Fuel (JP−4

Benzene 1.0 380,359

Cyclohexane 1.240 323,305

n-Hexane 1.5 266,66

Toluene 3.2 125,28

Xylene (mixed isomers) 3.2 125,281

Source: Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313, Appendices Band H, 

“Memorandum from Patrick B. Murphy, Radian/RTP to James F. Durham, EPA/CPB Concerning Petroleum Refinery Liquid HAP and 

Properties Data, August 10, 1993,” and “Memorandum from Paul C. Bailey, Jr., API/Washington, DC to James F. Durham, EPA/CPB 

Concerning Revised Estimates of Heavy Petroleum Product Liquid Constituents, December 23, 1993”

Updated information from comments received on guidance document for 1,2,4−Trimethylbenzene in gasoline and No.

fuel oil/diesel fuel. Subsequently revised (February 2000) to be consistent with EPA’s emission estimating program tanks, f

n-Hexane in gasoline and jet fuel
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