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What are the required filing P2 Thresholds?

A P2 Plan will need to be prepared and implemented if any one of the following thresholds are met: 

1. A person who owns or operates a facility that meets the reporting requirements prescribed by Arizona Revised Statutes (ARS) § 49-962 shall prepare and implement a P2 plan that addresses a reduction in the use of toxic substances and the generation of hazardous wastes. [Ref: ARS § 49-963.A]

  • During the preceding calendar year, the owner or operator was required to filed an annual toxic chemical release (Environmental Protection Agency Toxics Release Inventory) form (Form A or Form R) for the facility. [Ref: ARS § 49-962(A)(1)]
  • During the preceding calendar year, the facility generated an average of 1 kilogram per month of acutely hazardous waste or an average of 1,000 kilograms per month of hazardous waste in a calendar year, exclusive of an episodic, accidental or remediation related release or occurrence. [Ref: ARS § 49-963(A)(2)]

2. A facility that uses in excess of 10,000 pounds in a calendar year of a toxic substance, as defined in ARS § 49-961 [Ref: ARS § 49-963.D]. Please visit the Environmental Protection Agency (EPA): Toxics Release Inventory (TRI) for a list of toxic substances (chemicals and chemical categories).