Our water plant uses chlorine gas. What do we need to do?

Chlorine is an extremely hazardous substance with a 100 lb threshold, so a plant with chlorine cylinders or ton containers almost always reports. Crossing the threshold planning quantity also triggers a Section 302 notification, due within 60 days.

Is fuel at our fleet yard exempt?

No. The Tier II fuel exemption covers retail gas stations, not government or private fleet fueling.

Do pool chemicals count?

They can. Pool chemicals are hazardous, and large recreation centers or aquatic facilities can exceed thresholds, especially with bulk sanitizer and acid storage.

Is each building a separate facility?

Buildings on one contiguous property under the same operator are generally one facility. Separate properties are separate facilities.

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Government and public sector

Tier II reporting for government facilities: water plants, fleet yards and everything in between

State and local governments are covered by EPCRA like any business, and they often run more reportable facilities than they realize. Water and wastewater plants, public works yards, recreation centers and emergency operations each need their own check. NeoTech helps agencies track every facility and file on time.

Talk to us about your facilities See the platform

Where the chemicals are in government facilities

Water and wastewater treatment

Chlorine gas cylinders and ton containers
Sodium hypochlorite
Ammonia for chloramination
Fluoride compounds
Coagulants such as ferric chloride and aluminum sulfate
Sulfuric acid, caustic soda and lime
Methanol at some wastewater plants

Public works and fleet

Gasoline and diesel in fleet fueling tanks
Motor oil, hydraulic fluid and antifreeze
Lead-acid vehicle and equipment batteries
Liquid de-icers and brine additives

Parks and recreation

Pool chemicals such as calcium hypochlorite and acids
Herbicides and fertilizers

Buildings and emergency services

Emergency generator fuel
Boiler fuel and water treatment
Compressed gases

Four places government reports go wrong

Assuming government is exempt

EPCRA covers state and local governments directly. Federal facilities are covered through a series of executive orders rather than the statute itself, and agency policy generally continues to require Tier II reporting even as those orders have been revoked and replaced over time.

Treating chlorine like an ordinary chemical

Chlorine is an extremely hazardous substance with a 100 lb threshold. A single one-ton container is well over it.

Assuming fleet fuel is exempt

The fuel exemption applies to retail gas stations. A municipal fleet yard that fuels its own vehicles doesn't qualify.

Missing sites

Each separate site, such as a lift station, pump house, satellite garage or rec center, is checked on its own.

How NeoTech handles it

Every facility in one place. Treatment plants, public works yards, buildings and recreation sites, each set up once and tracked together.

State requirements, checked for you. NeoTech checks each facility against its state's Tier II rules and submission system.

SDS extraction. NeoTech's AI extracts and indexes hazard data from SDSs for treatment chemicals, fuels and maintenance products.

Totals combined by chemical. Inventory is combined by CAS number across products and locations, then compared against the correct threshold, including extremely hazardous substance thresholds.

Deadlines on the calendar. Reminders for Section 302 notifications, Section 311 SDS submissions and the March 1 Tier II deadline.

Reports in your state's format. Submission-ready .t2s packages for Tier2 Submit, E-Plan exports and more.

Or let us file for you. NeoTech can submit on your behalf to the SERC, LEPC and fire department.

Minnesota cities and counties: we'll walk the site with you

NeoTech is based in Minneapolis. For Minnesota facilities, our team can collect your chemical inventory on site and load it straight into the platform.

Schedule an on-site inventory

State rules

Tier II requirements differ by state. See our state guides below, or browse every state we cover.

See every state's Tier II requirements →

Frequently asked questions

Do city and county facilities have to file Tier II?: Yes. EPCRA applies to state and local governments directly. Federal facilities are covered through a series of executive orders rather than the statute itself, and agency policy generally continues to require Tier II reporting even as those orders have been revoked and replaced over time.
Our water plant uses chlorine gas. What do we need to do?: Chlorine is an extremely hazardous substance with a 100 lb threshold, so a plant with chlorine cylinders or ton containers almost always reports. Crossing the threshold planning quantity also triggers a Section 302 notification, due within 60 days.
Is fuel at our fleet yard exempt?: No. The Tier II fuel exemption covers retail gas stations, not government or private fleet fueling.
Do pool chemicals count?: They can. Pool chemicals are hazardous, and large recreation centers or aquatic facilities can exceed thresholds, especially with bulk sanitizer and acid storage.
Is each building a separate facility?: Buildings on one contiguous property under the same operator are generally one facility. Separate properties are separate facilities.

Every facility you operate, reported on time

Tell us about your facilities and we'll show you how NeoTech takes each one from inventory to filed report.

Talk to us about your facilities