RCRA & EPCRA (TIER II & Emergency Planning)


Waste determination and waste minimization can be first steps to RCRA compliance.

Hazardous Waste Contingency Plans are required by federal and state regulations for large quantity generators. We assist our clients in preparing these plans and establishing procedures for the prevention of hazardous waste releases to the environment and responding appropriately in such an event.

Some of the elements of these plans are: a detailed description of hazardous waste storage facilities with particular emphasis on loading/off-loading areas; a detailed protocol for notifying regulatory agencies and other responders; and storage practices designed to prevent accidents.

When a release occurs, rapid response is required. Consolidating all response procedures into one plan streamlines the entire process and helps prevent confusion. This can be accomplished with the creation of a single overall plan for the facility (Integrated Contingency Plan). With one set of instructions to follow, personnel do not need to decide which plan applies and the possibility of conflicts between different plans and instructions is minimized.

EPCRA & Tier II Reporting

The Emergency Planning & Community Right To Know Act (EPCRA), also known as Title III of SARA (the Superfund Amendments and Re-Authorization Act), requires facilities with inventories of hazardous substances that exceed a 10,000 pound threshold or extremely hazardous substances that exceed a 500 pound threshold to participate in the emergency planning and notification process.

IRWIN can perform a facility inspection to:

  • determine if a facility triggers EPCRA reporting requirements;
  • develop an inventory of the hazardous and extremely hazardous substances on site;
  • compile the required physical and chemical data about the substances; and
  • prepare the reports (Tier I and Tier II forms) and the facility map need for the submittal.

Flammables and combustibles are usually subject to additional fire code compliance requirements. We are qualified to evaluate compliance with state and local regulations and National Fire Protection Association (NFPA) codes.