Question # 83

83. In 1999, a facility disposes of a waste containing benzene in an on-site landfill, but does not exceed an activity threshold for benzene. The facility does not report the amount of benzene released to the landfill in 1999. In 2000, the facility exceeds a threshold for benzene. If some of the benzene released to land in 1999 seeps from the landfill to groundwater (i.e., migration of previously disposed materials), does the facility report the amount of benzene that seeped into groundwater during 1999?
No. EPA requires reporting of the amount of a toxic chemical placed in an on-site landfill during the reporting year in which these amounts are disposed. Amounts disposed in previous years are not reportable in subsequent submissions provided no additional activity is performed with these amounts.