1998 EPCRA 313 Q&A, Question # 498

498. If a company measures its own leaks (valve, flange, pump, etc.) and determines a new fugitive factor, is the code 'E' or 'M' or 'O'?
The company should use the code M if it measured releases of the toxic chemical from its equipment at the facility to determine its release amount. 'E' is used only for published emission factors which are chemical specific. However, in this case, the company would use 'O' which is used if it measured leaks generally or applied non-published factors developed at other facilities.

Additional Details

Question # 498 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-498 Status Archived
Category 4. Completing the Form R: Releases and Waste Management Calculations Subcategory 4.A. Releases of the Toxic Chemical
Keyword(s) Basis of Estimate, Emissions Factors, Releases (Released)
Updated Q&A Question Number 610
Prior Q&A [Archived] Question Number 361, 1997 EPCRA 313 Q&A
Prior Source: [Archived] Question Number 361, 1997 EPCRA 313 Q&A: Emissions Factors. Type of Change: No Change to the Original - No Change to the Original indicates that either no change was made between the original Q"A and the 1998 version of the Q"A or that the only edits that were made involved punctuation changes. Description of Substantive Edits: NA - NA indicates no substantive edits were made to the original Question and Answer.