Question # 618

618. Because you are required to report the amount of a listed EPCRA section 313 chemical in storm water, how do you know if the chemical is associated with current releases from that year's production or is from legacy waste?
There is no definite way to determine if a chemical in storm water is associated with that year's production or is from legacy wastes. A facility should use its best available information, based on available monitoring data and knowledge of conditions at the facility, to estimate the amount of a listed EPCRA section 313 chemical in storm water resulting from that year's production. In the absence of documentation, listed EPCRA section 313 chemicals found in storm water should be reported as current releases.