CERCLA and EPCRA Reporting Requirements

EPA clarified reporting requirements for animal feeding operations for ammonia and hydrogen sulfide.

If you are an unpermitted operation YOU ARE NOT AFFECTED BY THESE REGULATIONS.

Permitted operations (CAFOs) may need to reportcertain types of releases to local and state agencies under the Emergency Planning and Community Right to Know Act (EPCRA). Operations that exceed 100 lbs per day ammonia or hydrogen sulfide emissions are required to report with a few exceptions.

Recently released new EPA rules exempt CAFOs from reporting emissions based on the requirements of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).

If you signed up for the Air Compliance Agreement in 2006 then no reporting action is required at this time.

Update January 2010: Note farmers are reporting under EPCRA (not CERCLA) so there is no requirement for a one-year anniversary report. You only need to update your paperwork when there is a major change in your management. Note the EPA region 7 EPCRA fact sheet is wrong on this point.

Initial Resources:

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Initial Phone Reporting Tips

The EPA region 7 fact sheet suggests that permitted animal feeding operations report to the state emergency response committee (SERC) and the local emergency planning committee (LEPC).

To report to the SERC call the following number in Missouri: 573-634-2436.
They will ask you for your name, the operation name, your address, phone number, county and number of animals. They will then issue you a "spill number" that get's you into their system.

To report to your LEPC you need to identify the LEPC covering your area. Go to the following website to look up the appropriate LEPC: http://yosemite.epa.gov/oswer/LEPCDb.nsf/SearchForm?OpenForm.
The most efficient way to determine the correct LEPC is likely your zip code. The website will provide a phone number if you follow the appropriate links. When you call be clear that you are calling with respect to LEPC reporting requirements.

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Written Reporting Tips

After you make a phone report to the state emergency response committee (SERC) and the local emergency planning committee (LEPC) you have 30 days to submit a written report.

That report must include information about the size of your operation and the amount of ammonia you emit from your operation. You also may need to report the amount of hydrogen sulfide that you emit from your operation.

The following presentations provide detailed instructions on filling out the paperwork for these written reports for ammonia loss. We are still gather information on hydrogen sulfide emissions and we will add this as we learn more.

Before you start you will need to print the following documents:

The following files can be viewed on your web browser and take you through examples for listed types of operations:

Grow-Finish Hog Operation with an Anaerobic Lagoon

Grow-Finish Hog Operation with an Under-floor Slurry Pit

Sow Farm with Anaerobic Lagoon

Conventional Dairy with Anaerobic Lagoon

Grazing Dairy with Earthen Storage

Broiler building with Litter

Information in these presentations was derived in part from information provided by University of Nebraska, Missouri Pork Producers Association and the National Cattlemen's Beef Association. These materials should be viewed as educational materials and are not legal advice.  The approach suggested in these presentations represents a good faith effort to estimate ammonia loss from animal feeding operations. On-going research may lead to improved estimates in the future.

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Other Resources on EPCRA

Missouri Pork Producers

National Cattlemen's Beef Association

University of Nebraska

USEPA Region 7

USEPA website on EPCRA

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