82. A facility disposes of an amount of waste in a surface impoundment in year 1 for which no report was required. In year 2, a report for the chemical is required and the chemical has migrated from the surface impoundment to ground water. Does the facility have to report the amount migrated in year 2?
No, facilities are only required to report amounts released or otherwise managed in the year that the amounts were released or otherwise managed for chemicals for which they exceeded thresholds (40 CFR Section 372.85(b)(14)). If a facility exceeds thresholds in a subsequent year for a chemical that was disposed of in a preceding year, the facility should not report amounts previously released or otherwise managed. Facilities are also not required to estimate the migration of chemicals from landfills except for the current reporting year.
