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The Ag Engineering Update

The latest and greatest from your livestock engineers.

CERCLA Reporting Update Nov 13, 2017


Update: As of Nov 15, 2017 3 pm, farms with continuous releases DO NOT HAVE to submit their initial continuous release notification until the court issues its order, or mandate, enforcing the April 11, 2017, decision.

You can review the material below to familiarize yourself with the continuous release reporting, but NO REPORTING IS REQUIRED until EPA updates its guidance to provide farmers with notice of when the mandate issues and reporting requirements begin. Please check EPA's website for updates.

 

As we have noted recently, an appeals court ruling requires livestock and poultry farmers across the nation to report ammonia and/or hydrogen sulfide emissions in amounts equal or greater than 100 lbs in any 24h period over the course of a year. Further information is available on EPA's website.

How do you know if your operation is exceeding 100 lbs per day threshold? We have developed a simple table that may be of assistance. This was developed using numbers for per animal emissions published by EPA in 2009, and may or may not be representative of your situation. Also, here are calculators you may utilize to estimate daily emissions by livestock species (also using EPA emissions factors):

Swine calculator

Dairy calculator

Beef calculator

Poultry calculator

If you determine that you must report a continuous release, here are the steps to follow (taken from EPA's website on 11-13-2017):

1. Notify the NRC by e-mail (NRC-CERCLA-EPCRA-REPORT@uscg.mil) and identify your reportable release as an"initial continuous release notification." You will need to include: farm name, location (county/state or city/state, not address), and whether it is NH3 or H2S that you report -- in the majority of cases, it will be NH3 (ammonia). (this email is new as of today)

2. Within 30 days of your initial notification, submit an initial written notification to the EPA Region 5 Office and,

3. One year later submit an additional follow-up written notification to the EPA Region 5 Office.

Please note that we will publish EPA Region 5 Office contact information for points 2 and 3 when available.

The deadline is currently November 15, 2017. However, EPA continues to modify their website so you are encouraged to keep checking it prior to taking action.

 

This document and the calculators are intended to assist producers with reporting the possible emission of ammonia and hydrogen sulfide. The guidance provided in this document is consistent with the information published by the U.S. EPA. U of I Extension does not endorse this method of emission estimation. This document should not be considered legal advice and is not a substitute for legal advice.



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