570. Section 313(g)(2) of EPCRA states that the owner or operator of a facility may use readily available data. In some cases, the available data may be known to be non-representative and reasonable estimates offer more accurate release information. Would EPA, in this instance, favor use of the estimates rather than data?
Yes, it is preferable to use reasonable estimates using the best readily available information if available data (including monitoring data) is known to be non-representative.