Frequent Questions

Separate releases of the same hazardous substance

If a number of releases of the same hazardous substance are occurring at several locations at the same time at a facility (e.g., through leaks in pipes or valves), are multiple reports required?

All releases of the same substance from a single facility should be aggregated to determine whether an RQ has been released from the facility into the environment. However, there may be a case where releases occurring at different facilities at a single contiguous plant or installation on contiguous grounds under common ownership cannot be aggregated to determine if an RQ has been released. If the release from each facility was greater than or equal to an RQ, multiple reports would be required. However, these reports may be made in a single call to the National Response Center. The definition of "facility" under CERCLA section 101(9) is key to an evaluation of CERCLA reporting requirements. For example, as applied to the use of ethylene glycol during aircraft de-icing, there may be releases occurring at different facilities but at a single contiguous plant or installation on contiguous grounds under common ownership. The facility arguably may include the truck applying the de-icer, the aircraft to which the de-icer is applied, the entire airport, and/or other entities, depending on individual circumstances.

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