1998 EPCRA 313 Q&A, Question # 546

546. Are toxic chemicals, such as nitrate compounds from waste treatment systems, that are used for farming at a facility to be reported as a release to land and is this an otherwise use activity?
The use of listed toxic chemicals such as nitrate compounds for farming is to be reported as a release to land under EPCRA Section 313. Listed toxic chemicals applied to land during use for farming constitute a release to an environmental medium (land) and are to be reported as such. This is consistent with the instructions for Section 5.5 of the Form R which state that land treatment/application farming is a disposal method that is considered a 'release to land.' Thus, whether or not this use is intended to be a disposal method, the total quantity released to land during use for farming should be reported as a release to land under Section 5.5.2 of the Form R. The amount of a listed toxic chemical used for farming at a covered facility must also to be applied towards the otherwise use reporting threshold.

Additional Details

Question # 546 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-546 Status Archived
Category 4. Completing the Form R: Releases and Waste Management Calculations Subcategory 4.A. Releases of the Toxic Chemical
Keyword(s) Nitrate Compounds (Nitrates), Otherwise Use, Release to Land (Land Release), Releases (Released), Treatment
Updated Q&A Question Number 274
Prior Q&A [Archived] Question Number 398, 1997 EPCRA 313 Q&A
Prior Source: [Archived] Question Number 398, 1997 EPCRA 313 Q&A: Land Treatment; Nitrate Compounds; Otherwise Use; Releases-Release to Land. 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.