ENV-13-55 Hydrogen Sulfide (H2S) and Reportable Quantity (RQ) Reporting

Description:

This presentation will explore the Hydrogen Sulfide (H2S) data being reported by refineries associated with the Toxic Chemical Release Inventory (TRI) and its potential impacts on the Emergency Planning and Community Right‐to‐Know Act’s (EPCRA) RQ reporting requirements. In particular, the presentation will explore new data and calculations associated with the TRI reporting and its potential impact on facilities’ compliance with the RQ reporting requirements. Issues to be explored include the sources and potential releases of H2S at refineries, as well as the applicability to RQ reporting requirements, including addressing the petroleum exclusion, federally permitted release exemption, and continuous release reporting. Using the data from the initial TRI reporting of H2S, this paper will explore the impact of H2S TRI reporting on their RQ reporting requirements obligations, and learn more about the nuances of RQ reporting.