American Petroleum Institute

Bulletin on the Generic Hazardous Chemical Category List and Inv. for the Oil and Gas Exploration and Production Ind. Superfund Amendments and Reauthorization Act of 1986, Emer. Planning & Comm. Right-to-Know Act, Title III Sec. 311 and 312 - Second Edition; Errata: 9/1/1991
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Annotation

FOREWORD

Under sections 311 and 312 of the Superfund Amendments and Reauthorization Act of 1986 (SARA Title III), also known as the Emergency Planning and Community Right to Know Act of 1986 (EPCRA) (42 U.S.C. Sections 11021, 11022) owners or operators of oil and gas exploration and production (E&P) facilities must provide to state and local emergency response agencies information on the hazardous chemicals they produce or use in production, drilling, workover, and completion operations. Because the SARA Title III reporting requirements were basically designed to allow communities to plan for emergencies at major industrial sites, they have presented difficulties to E&P operators.

E&P operators have thousands of leases throughout the country and millions of pieces of equipment on the leases. They employ hundreds of contractors who use a wide variety of chemicals at production sites for short periods of time.

Generic reporting, a simplified means of compliance, was developed in response to the problems which SARA Title III reporting requirements create for the E&P industry. The American Petroleum Institute (API) believes the generic reporting approach outlined in this publication (1) can satisfy section 311 and 312 reporting requirements and (2) will be benefit emergency response agencies in planning for or responding to an emergency situation. The Environmental Protection Agency (EPA) agrees the generic reporting concept can meet section 311 and 312 reporting requirements under certain conditions (see Appendix A). State Emergency Response Commissions in most producing states also accept generic reporting. Facility Operators should check with the appropriate authorities.