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View Diary: What Exactly is in Dilbit? It is a Secret. (242 comments)

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    And I apologize for not including this in my original reply, may I introduce you to the concept of reportable quantity under Superfund, technically known as CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act):

    Section 103(a) of CERCLA "as amended" and EPA's implementing regulations (40 Code of Federal Regulations (CFR) 302.8) require that the person in charge of a vessel or facility immediately notify the National Response Center (NRC) whenever a reportable quantity (RQ) or more of a CERCLA hazardous substance is released in any 24 hour period, unless the release is federally permitted. The purpose of this requirement is to notify officials of potentially dangerous releases so that they can evaluate the need for a response action.
    Reportable Quantity Adjustments

    RQs under CERCLA are adjusted to one of five levels: 1, 10, 100, 1,000, or 5,000 pounds. EPA bases adjustments to the RQs on the intrinsic characteristics of each hazardous substance, such as the aquatic toxicity, acute and chronic toxicity, ignitability, reactivity, and potential carcinogenicity. An RQ value is established for each of these characteristics of a hazardous substance, with the most stringent RQ value (i.e., the lowest quantity) becoming the final RQ or reporting trigger for that hazardous substance.

    Statutory Reportable Quantities (RQs) are often those set provisionally by Congress (usually at one pound), pending detailed scientific analysis by EPA and adjustment through notice and comment rulemaking. They often do not reflect the relative hazard posed to public health and the environment. By adjusting the RQs, the Agency is able to focus its resources on those releases that are more likely to pose potential threats to public health or welfare or the environment, while relieving the regulated community and government emergency response personnel from the burden of making and responding to reports of releases that are less likely to pose such threats.

    EPA decided to adjust the statutory RQs of CERCLA hazardous substances that are also CWA hazardous substances to make notification requirements for these substances consistent and less confusing for the regulated community. By making the CWA and CERCLA RQs the same, the Agency sought to avoid confusion regarding reporting requirement

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