Question # 597

597. During the reporting year, a federal facility discharges waste containing listed EPCRA section 313 metals to an on-site cooling pond. The metals accumulate and settle, and the water is then drained from the cooling pond, leaving a heavy metal sludge. The sludge is then dredged and sent off-site to a recycler. How should the EPCRA section 313 chemicals left in the pond, after the sludge has been removed for recycling, be reported?
Listed EPCRA section 313 chemicals remaining in the pond after the sludge has been removed should be reported as “released to land.” Listed EPCRA section 313 chemicals left in the pond water, which have been drained off, should be reported according to their disposition: either discharged to a stream (back into the cooling pond), discharged to a POTW, transferred to other off-site locations, treated on-site, or recycled on-site.