1998 EPCRA 313 Q&A, Question # 485

485. A mining facility leaches metals from an outdoor ore pile and collects the leachate for further processing. Should the toxic chemicals in the pile be reported as a release to land on the Form R?
During the leaching, the ore pile is considered part of the facility’s process, and toxic chemicals in the pile should not be reported as a release to land. Once the leaching process is complete, and the ore pile is 'closed,' the facility will report the toxic chemicals remaining in the pile as a release to land in Part II, Section 5.5.4 (Other Disposal) of the Form R. However, amounts of listed toxic chemicals that escape the pile during the facility’s leaching process and are either released to land or surface water, for example, must be considered toward release calculations if a threshold has been exceeded.

Additional Details

Question # 485 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-485 Status Archived
Category 4. Completing the Form R: Releases and Waste Management Calculations Subcategory 4.A. Releases of the Toxic Chemical
Keyword(s) Release Reporting, Stockpiles, Storage
Updated Q&A Question Number 592
Prior Q&A [Archived] Question Number 47, 1998 Newly Added Industries
Prior Source: [Archived] Question Number 47, 1998 Newly Added Industries: Disposal; Facility; Form R; Metals; Mining; Process; Release Calculation. 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.