The Notification Requirements for a Release Under CERCLA and EPCRA
Both CERCLA and EPCRA require you to report a release of a Hazardous Substance or Extremely Hazardous Substance (EHS) above its Reportable Quantity (RQ) in a 24 hour period. Read: Reporting Releases of Hazardous Substances and Extremely Hazardous Substances. Also: What Does CERCLA Identify as a Hazardous Substance?
Notification takes two forms:
- Immediate notification by owner, operator, or person in charge to the NRC, LEPC, and SERC.
- Written follow-up notification(s) to LEPC and SERC “as soon as practicable after the release“.
What is meant by immediate? And what is meant by: “as soon as practicable after the release“? This article will shed some light on these very important requirements. (more…)