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1.What do I need to know about the many methods of disposal and other releases? 2.If a facility in one of the newly included industries

1.What do I need to know about the many methods of disposal and other releases?

2.If a facility in one of the newly included industries receives information on the quantity of seepage from a landfill in 1998 and begins reporting for operations undertaken in 1998, do they record this amount as a release to land, even though they were not required to record the initial disposal to land the prior year?

3. In year 1, a facility disposes of garbage in a surface impoundment for which no report is required. The chemical is obliged to submit a report in year two, and the chemical has migrated from the surface impoundment to ground water. Is the facility required to report the amount transferred in the second year?

4. A facility disposes of benzene-containing garbage in an on-site landfill in 1999, but does not exceed the benzene activity level. The amount of benzene emitted to the landfill in 1999 is not reported by the plant. In the year 2000, the plant breaches a benzene limit. Does the facility record the amount of benzene that seeped into groundwater in 1999 if any of the benzene released to land in 1999 seeps from the landfill to groundwater (i.e. migration of previously discarded materials)?

5. If a covered solvent recovery service comes at a covered facility and either recycles ethylene glycol antifreeze on-site using a mobile recovery unit or removes the ethylene glycol antifreeze for off-site recycling, who is responsible for EPCRA section 313 reporting?

6. A governmental institution does out cleanup work on soils that have been poisoned in the past. As part of the remediation, the plant is using an EPCRA section 313 chemical. Is it necessary for the facility to count the amount of EPCRA section 313 chemical utilized for remediation activities for determining thresholds?

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