CERCLA and EPCRA Reporting Requirements

Asked February 1, 2018, 8:48 AM EST

I am teaching a course in Agriculture Waste Management at South Dakota State University and the 52 students want to know:

  1. What is the latest reporting requirements for CERCLA AND EPCRA?
  2. What size of livestock or poultry operation is required to report?
  3. How is the report submitted (to whom and how often)?
  4. What reporting form is to be used?
  5. What is the best spreadsheet estimator for ammonia and hydrogen sulfide from a livestock or poultry operation?

Codington County South Dakota

1 Response

The CERCLA/EPCRA reporting requirements are currently under a state of flux.

On February 1, 2018, the DC Circuit Court of Appeals granted EPA’s motion to further stay issuance of the EPCRA CERCLA reporting mandate until May 1, 2018. So until May 1, there are no reporting requirements.

However, if and when the court says there is a reporting requirement. The CERCLA and EPCRA rules are for any operation with the potential to emit 100 lb/d or more of ammonia or hydrogen sulfide, regardless of size or housing system. In the past there were exemptions from CERCLA and for smaller operations, but those exemptions have been removed (as of September 2017). Additional information and discussion is available at http://articles.extension.org/pages/28452/cercla-and-epcra-reporting-for-animal-agriculture.