Question # 81

81. If a facility in one of the newly added industries, which begins reporting for activities conducted in 1998, has information on the amount of seepage from a landfill in 1998, do they report this amount as a release to land, since they were not required to report the initial disposal to land in the previous year?
No. Facilities are required to report only the amounts that are disposed during the reporting year in which they are disposed, provided certain thresholds have been met and the facility does not conduct any further activities involving amounts previously disposed. Amounts that move within the same media, such as seepage from a landfill to surrounding soils, do not have to be included in release estimates in subsequent years. EPA requires reporting of the amount of toxic chemical placed in an on-site landfill during the year. EPA does not require the facility to estimate migration from the landfill in subsequent years, provided the facility does not conduct activities that further involve the listed toxic chemical disposed.