Monday, February 9, 2009

EPCRA - CERCLA Reporting - Changes to Hazardous Substance Release Reporting

Effective January 20, 2009, US EPA is providing an administrative reporting exemption that applies to certain releases of hazardous substances from farm operations. The exemption applies to releases of hazardous substances to the air from animal waste at farms. The final rule reduces the burden of complying with Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the Emergency Planning and Community Right-to-Know Act (EPCRA) reporting requirements for the affected farms.

The final rule does not change the notification requirements if hazardous substances are released to the air from any source other than animal waste at farms (e.g., ammonia tanks), or if any hazardous substances from animal waste are released to any other environmental media, (e.g., soil, ground water, or surface water) when the release of those hazardous substances is at or above its reportable quantity.

Ammonia and hydrogen sulfide are the most common hazardous substances that are emitted from animal waste. Ammonia is a by-product of the breakdown of urea and proteins that are contained in animal waste, while hydrogen sulfide is another by-product of the breakdown of animal waste under anaerobic conditions. However, other hazardous substances, such as nitrogen oxide and certain volatile organic compounds may also be released from animal waste. This rule extends the administrative reporting exemption to all hazardous substances emitted to the air from animal waste at farms.

Caltha LLP assists facilities regulated under CERCLA and EPCRA in meeting their reporting requirements, including EPCRA 311 – EPCRA 312 reporting of releases of hazardous substances.

For further information contact Caltha LLP at
Caltha LLP Website

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