Question # 571

571. Section 313(g)(2) of EPCRA states that the owner or operator of a facility may use readily available data for reporting releases of toxic chemicals. If a federal facility has monitoring or emissions data for an EPCRA section 313 chemical that they do not believe are representative, should they still use that data to complete the release calculations on the Form R report?
No. If a federal facility has monitoring or emissions data that are not considered “representative,” the data need not be used. In such cases, a more accurate estimate based on mass balance calculations, published emissions factors, engineering calculations, or best engineering judgement should be used. In such instances, a federal facility should document why the available monitoring data were believed to be unrepresentative.