1998 EPCRA 313 Q&A, Question # 95

95. A covered facility removes toxic chemicals from groundwater in a clean-up action. The listed toxic chemicals, after treatment, are sent off-site for disposal. Is the facility required to report? Does the exemption for intake water apply?
Since the toxic chemicals are not manufactured, processed, or otherwise used, no reporting threshold applies to the cleanup action. If the toxic chemicals are manufactured, processed, or otherwise used elsewhere at the facility and exceed a threshold, releases and other waste management activities from the cleanup must also be reported on the Form R. The quantities of toxic chemicals in the remediation wastes that are sent off-site for waste management are reported in Part II, Section 8.8. The intake water exemption does not apply since the toxic chemicals are not being used in a process activity and because the toxic chemicals in groundwater are not at background levels.

Additional Details

Question # 95 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-095 Status Archived
Category 1. Determining Whether or Not to Report: Facility Subcategory 1.E. Threshold Determinations
Keyword(s) Intake Water Exemption (Compressed Air), Release Reporting, Remediation (Remedial), Threshold Determination (Activity Threshold)
Updated Q&A Question Number 147
Prior Q&A [Archived] Question Number 58, 1997 EPCRA 313 Q&A
Revision
History
Prior Source: [Archived] Question Number 58, 1997 EPCRA 313 Q&A: Otherwise Use; Releases-Release Reporting; 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.