Package Delivery and Distribution Company

Multiple Locations

Roux Associates was retained by a package delivery/warehouse storage and distribution company to prepare Tier II Reports and various contingency plans for over 70 of its facilities located throughout the United States and Puerto Rico.

The Tier II Reports were prepared in accordance with the EPCRA/SARA Title III and each States' equivalent to the Hazardous Materials Emergency Response and Community Right-to-Know Act. EPCRA requires facilities that make, store or use certain chemicals at quantities above specified thresholds to file annual inventory reports with the State Emergency Response Commissions (SERCs), Local Emergency Planning Committees (LEPCs) and local fire departments.

Typical reportable chemicals stored at the company's facilities included, but were not limited to: sulfuric acid, lead and various petroleum products. In preparation of the Tier II Reports, Roux Associates conducted a thorough review of both the Federal and State reporting requirements and interviewed State-regulatory personnel, when appropriate, in order to resolve specific reporting requirement issues. Additional project activities included: technical reviews of Material Safety Data Sheets (MSDSs) to determine reporting applicability; identification of jurisdictional SERCs, LEPCs and fire departments for each facility; calculation of associated fee requirements; fulfillment of State-specific electronic/internet reporting requirements; and completion of the required reporting forms.

Roux Associates also assisted the same company in preparing a variety of contingency plans that were mandated by several Federal and State regulatory programs. Such plans included Facility Response Plans (FRP) and Spill Prevention Control and Countermeasure (SPCC) Plans. The FRP Plans were prepared for two airport hubs and were approved by the USEPA.

In light of the new Spill Prevention Control and Countermeasure (SPCC) regulations that were published in the Federal Register of July 17, 2002, Roux Associates conducted a detailed regulatory analysis highlighting the impact of the new regulations on the transportation industry in general and the client in particular. The regulatory analysis provided specific actions to be taken in order to minimize the operational and financial impact of the new SPCC regulations. To that end, Roux Associates generated a "SPCC Plan template" that was tailored specifically to the needs of the client. The template insured consistency and compliance with the new regulations throughout the client's operations. Using the template, Roux Associates assisted the client in updating the SPCC Plans for facilities located in twenty-five states.