Environmental Protection Agency (EPA) regulations implementing Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA Title III) set threshold levels (threshold planning quantities, i.e., TPQs) for emergency planning at a local level. Both SARA Title III and CERCLA set reportable quantities (RQs) for reporting releases to the environment. The TPQ for both hydrogen sulfide and sulfur dioxide is 500 pounds; RQs for release reporting are 100 pounds for hydrogen sulfide and 1 pound for sulfur dioxide. TPQs and RQs (trigger levels) and the regulations requiring response plans and release reports under both SARA Title III and CERCLA are set forth in 40 Code of Federal Regulations Part 302, and 40 Code of Federal Regulations Part 355. Refer to API Bulletin E-4 for guidance on release reporting requirements. 'Trigger levels" for response plan and release reporting requirements are subject to change and users shall check the latest revisions for compliance. SARA Title III also requires submission of periodic and annual reports of information to state and local officials on the presence of hazardous chemicals at production
and gas processing facilities. Those regulations are set forth in 40 Code of Federal Regulations Part 370, and API has published suggested generic reporting forms (refer to API Bulletin E-l) that are acceptable to EPA. Appropriate guidance should be sought to assure compliance with these programs for the specific operations.
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