Question # 604

604. Where does one report routine leaks from pipes? Would these be reported as disposed to land?
Reporting leaks from pipes requires determining where the released toxic chemical goes. For example, a toxic chemical that evaporates would be reported as a fugitive air emissions in Part II, Section 5.1 of the Form R. A nonvolatile material leaking into land, or any material leaking from an underground pipe, would be reported as a release to land and entered in Part II, Section 5.5.4 'Other Disposal.' In either case, the toxic chemical would also be reported in Section 8.1.