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  • Release notification requirements for releases of aqueous film forming foam

    Aqueous Film Forming Foam (AFFF), a substance commonly used by firefighters, contains ethanol, 2-(2-butoxyethoxy) which is categorized as a glycol ether. Glycol ethers meet the definition of hazardous substance in CERCLA 101(14) because they are hazardous air pollutants pursuant to 112(b) of the Clean Air Act. In 1990, the Clean…

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  • Who must be notified when a release occurs?

    In the event that a listed Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substance or extremely hazardous substance is released in an amount equal to, or exceeding the reportable quantity (RQ) for that substance, the following parties must be notified: Community emergency coordinator for the local or tribal…

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  • Multiple Releases During 24-Hour Period

    CERCLA release notification requirements state that any person in charge of a vessel or an offshore or an onshore facility shall, as soon as he has knowledge of the release of a hazardous substance in a quantity equal to or exceeding the reportable quantity (RQ), immediately notify the National Response…

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  • What types of things have caused applications to be disqualified for administrative reasons?

    Some examples of reasons applications have been disqualified include: Applicant did not complete all of the registrations steps in Grants.gov and could not resolve the issue until 12:01 a.m. the morning after the deadline. Because the applicant could not demonstrate the problem was caused by Grants.gov technical issues, the application…

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  • Releases from a facility onto a public roadway that runs through the facility

    The EPCRA emergency notification regulations require facility owners and operators to immediately report releases into the environment of extremely hazardous substances or CERCLA hazardous substances if the releases exceed specific reportable quantities ( 40 CFR §355.42 ). The notification must be provided to the appropriate State Emergency Response Commission and…

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  • Reporting hazardous substance mixtures

    How are mixtures of hazardous substances (other than radionuclides) reported? EPA issued the "mixture rule" ( 40 CFR section 302.6(b) ), developed in connection with CWA section 311 regulations, as a method for determining when to report releases of mixtures or solutions. Under the mixture rule, if the quantities (or…

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  • Does EPCRA release reporting to State and local government agencies satisfy the CERCLA 103 requirement to report to the NRC?

    Are reports made to State and local government agencies relayed to the National Response Center (NRC) and, if so, does the original call satisfy reporting requirements under CERCLA section 103? Although reports are sometimes passed on to the NRC by State and local government agencies, a person responsible for reporting…

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  • Applicability of CWA broad generic categories to other provisions of CERCLA

    Are the Clean Water Act (CWA) broad generic categories for which no Reportable Quantity (RQ) has been established subject to other provisions of CERCLA? Yes. Releases of compounds within these categories, although not reportable under CERCLA section 103 (unless the compound is listed separately in 40 CFR 302.4, Table 302.4…

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  • Chemicals subject to reporting (EPCRA Section 304)

    What chemicals are subject to reporting under EPCRA Section 304? Chemicals subject to Section 304 notification requirements are CERCLA hazardous substances listed under 40 CFR Table 302.4 and the extremely hazardous substances listed under 40 CFR part 355 Appendix A and B .

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  • Applicability of EPCRA 304 to EHSs in abandoned receptacles

    Must any amount of a listed chemical contained within abandoned or discarded barrels, containers, or other receptacles be considered to determine if a specific reportable quantity has been exceeded under the SARA Section 304 notification requirements? Section 355.61 defines a release as "any spilling, leaking, pumping, pouring, emitting emptying, discharging…

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  • When and where should an air carrier report a release?

    When and where should an air carrier report a release? For instance should the release be reported to the state where the release occurred or to the airport of destination? Since aircraft should have radio communication capabilities, the report should be given to the state(s) likely to be affected by…

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  • Can the RQ assigned to hydrochloric acid be used for hydrogen chloride gas?

    Hydrogen chloride gas is introduced into water to form hydrochloric acid. Saturation for this reaction occurs at 38 percent (%). Therefore, any hydrogen chloride present after the saturation point is reached, does not go into solution and will remain in the gaseous state. Can the reportable quantity (RQ) assigned to…

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  • Are releases into a POTW subject to CERCLA section 103(a) reporting requirements?

    Are releases of a pollutant into a Publicly Owned Treatment Works (POTW), when the pollutant is specified in and in compliance with the pretreatment standards of the Clean Water Act, subject to CERCLA section 103(a) reporting requirements? No. The introduction of any pollutant into a POTW, when the pollutant is…

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  • Are the quantities of different hazardous constituents additive?

    In determining whether a Reportable Quantity (RQ) has been released, are the quantities of different hazardous constituents additive under the mixture rule? No. RQs of different substances are not additive under the mixture rule; releasing a mixture containing half an RQ of one hazardous substance (other than radionuclides) and half…

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  • Emergency release notification and trade secret chemicals

    Question No. 3 of the trade secret substantiation form requires the submitter to list all local, state, and federal government entities to which the submitter has disclosed the specific chemical identity. Does the submitter need to report Section 304 emergency release notification if the submitter had a covered reportable release…

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