1998 EPCRA 313 Q&A, Question # 94

94. If you operate a treatment plant as part of remediation at a Superfund site on your facility, do contaminants (already present at the site) have to be included in calculating thresholds and releases and other waste management activities?
EPCRA Section 313 listed toxic chemicals undergoing remediation are not included in threshold determinations because remediated chemicals are not manufactured, processed, or otherwise used. However, if a covered facility exceeds an activity threshold for a listed toxic chemical elsewhere at the facility, any releases and other waste management activities of the listed toxic chemicals undergoing remediation must be included in the facility's release and other waste management calculations. In that event, a release does not include material already in a landfill but does include any material released to the environment or transferred off-site due to the remedial activity.

Additional Details

Question # 94 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-094 Status Archived
Category 1. Determining Whether or Not to Report: Facility Subcategory 1.E. Threshold Determinations
Keyword(s) Remediation (Remedial), Threshold Determination (Activity Threshold)
Updated Q&A Question Number 145
Prior Q&A [Archived] Question Number 57, 1997 EPCRA 313 Q&A
Revision
History
Prior Source: [Archived] Question Number 57, 1997 EPCRA 313 Q&A: Remediation; Threshold Determination. Type of Change: Minor - Minor edits are those edits which only involve non-substantive additions or deletions of words to provide clarity in the Question and Answer. Description of Substantive Edits: NA - NA indicates no substantive edits were made to the original Question and Answer.