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| Designed for the special
needs of the oil & gas operator |
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Most
oil and gas owners or operators are required to file under
Section 312 of SARA Title III because oil and gas exploration
and production facilities normally exceed the reporting
thresholds (10,000 pounds at any time during a calendar
year) for produced hydrocarbons (condensate, crude oil,
or natural gas) that are stored on site.
In addition, many of these facilities
exceed the reporting thresholds for other hazardous chemicals
or hazardous chemical categories, such as fuels or chemicals
used for drilling, completion, production and workover
activities. |
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| Multiple facilities |
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The
Tier Two reporting requirements are further complicated
for multiple facilities that are located in several state,
county, and fire department jurisdictions with each agency
having its own forms and requirements.
Eagle Software monitors the Right-to-Know
laws throughout the year and updates ChemForm to conform
to any changes. |
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Local jurisdictions |
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Reporting
under Section 312 requires the owner or operator of a
facility to submit a copy of the Tier Two report to the
State Emergency Planning Committee (SERC), the Local Emergency
Planning Committee (LEPC) for the county or area of the
reporting facility, and the local fire departments(s)
with jurisdiction over the facility. The state and local
agencies have the authority to modify reporting requirements
as long as the minimum federal guidelines are being address.
For example, Texas has its own Community
Right-to-Know Acts, and although Texas accepts the federal
chemical inventory form it has its own Texas Tier Two
Cover Sheet that the owner or operator is required to
submit with each facility.
ChemForm generates not only the state
report, but also prints and collates the copies required
by the LEPC and fire department. |
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| Initial Tier Two reports required
by Texas |
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In addition to the annual Tier Two Report,
Texas requires facility operators to submit an initial
Tier Two Report and applicable fee within 90 days:
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after
the facility operator begins operation at a new facility
location and acquires one or more reportable hazardous
chemicals at that location, or
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first
acquires one or more reportable hazardous chemicals which
were not included in the most recently submitted annual
Tier Two Report, or
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determines
one or more reportable hazardous chemicals were omitted
from the most recently submitted annual Tier Two report.
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ChemForm can be used throughout the year
to submit any initial report. |
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| Generic
reporting |
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Generic reporting, a simplified means of
compliance, was developed in response to the unique nature
of oil and gas exploration and production activities.
ChemForm's generic reporting feature
is based on the American Petroleum Institute's (API) Bulletin
on the Generic Hazardous Chemical Category List and Inventory
of the Oil and Gas Exploration and Production Industry
(Bulletin E1). Copies of this publication an be obtained
from API Publications Department, 1220 L Street, N.W.,
Washington, D.C. 20005, 202-682-8375. |
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