Question # 579

579. Form R requires estimates of the release to the environment of listed toxic chemicals in specific release categories. If a facility is unable to complete its estimate of these releases by the deadline, should the company leave that entry blank and promise a future estimate, or make the best estimate possible and submit later revisions?
Any covered facility must report by July 1 for the previous reporting year, and the data provided should be the best estimate using the best readily available data. Records supporting the data must be kept for three years. If more accurate data are developed, the facility may submit revised forms. EPA can take enforcement action if they believe that the data do not represent reasonable estimates.