WHOPRS Support

Our company has ended its operations and only a small number of employees remain.  Virtually all employees will be gone by 1/1/2017 except for those who will be involved with the final removal of assets from the facility.  Consultants has been hired to prepare the upcoming Tier II reports.  I am wondering how the WEM would like the Tier II reports to be prepared.  The primary purpose of these reports is to alert and forewarn emergency response personnel of chemical hazards they could encounter if an emergency arises.  Therefore, should the report be prepared for the conditions that exist at the time of the report (i.e., forward-looking), or should it reflect the full scale operations that did occur earlier in 2016 (i.e., looking back)?  It is quite possible that within a few months there will be no chemicals remaining onsite at/above 10,000 pounds or the TPQ.  By the time of the Tier II due date we anticipate most, if not all, of the chemical materials will be gone from the facility.  Additionally, it is unclear at this time if there will be any onsite contact persons when the Tier II report is submitted, so your guidance on this issue would also be appreciated.

A tier II covers chemical present in the previous year. A report will need to be submitted for 2016 chemicals; make sure that the consultants will have access to your on-line reporting login.  The Tier II that is due March 1, 2017 would be for reportable chemicals only during calendar year 2016. If there are any reportable amounts of chemicals in 2017, then a Tier II report Annual Report will be due for 2017 chemicals also which is due March 1, 2018. When your extremely hazardous chemicals (EHS) are removed, then an amended EPN can be filed to take you off of planning. Then you can file an Update Tier II report and complete Step 2 noting that you no longer store chemicals as of a specific date.

The contact provided should be the best regulatory point of contact who can share information on the report submitted.