Question # 572

572. If a covered facility has analytical data that will take extensive time and money to calculate emissions, can that facility use the maximum emissions level specified in their permit to calculate their emissions?
EPCRA allows facilities to use its best readily available data to provide information required under Section 313. When data are not readily available, EPCRA allows facilities to use 'reasonable estimates' of the amounts involved. An owner/operator facility must use his/her best judgment to determine whether analytical data are readily available. If they are not, the facility's use of maximum emissions levels, as specified in its permits, may be a reasonable basis from which to form its estimates. In any event, the owner/operator should carefully document the reason for its decision making.