1998 EPCRA 313 Q&A, Question # 470

470. If a covered facility has analytical data that will take extensive time and money to calculate emissions, can that facility use the maximum emission level specified in their permit to calculate their emissions?
EPCRA allows facilities to use its best readily available data to provide information required under Section 313. When data are not readily available, EPCRA allows facilities to use 'reasonable estimates' of the amounts involved. An owner/operator facility must use his/her best judgment to determine whether analytical data are readily available. If they are not, the facility's use of maximum emissions levels, as specified in its permits, may be a reasonable basis from which to form its estimates. In any event, the owner/operator should carefully document the reason for its decision making.

Additional Details

Question # 470 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-470 Status Archived
Category 4. Completing the Form R: Releases and Waste Management Calculations Subcategory 4.A. Releases of the Toxic Chemical
Keyword(s) Readily Available, Reasonable Estimates
Updated Q&A Question Number 572
Prior Q&A [Archived] Question Number 33, 1998 Newly Added Industries
Revision
History
Prior Source: [Archived] Question Number 33, 1998 Newly Added Industries: Facility. Addendum means that the source of the 1998 Q"A is the Addendum to the Guidance Documents for the Newly Added Industries (EPA 745-B-98-001). 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.