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Applicability of EPCRA 304 to EHSs in abandoned receptacles

Must any amount of a listed chemical contained within abandoned or discarded barrels, containers, or other receptacles be considered to determine if a specific reportable quantity has been exceeded under the SARA Section 304 notification requirements?

Section 355.61 defines a release as "any spilling, leaking, pumping, pouring, emitting emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment (including the abandonment or discarding of barrels, containers, and other receptacles) of any hazardous chemical, extremely hazardous substance, or CERCLA hazardous substance."  

Therefore, if a facility has abandoned or discarded any barrels, containers, or other receptacles containing an extremely hazardous substance or a CERCLA hazardous substance and the total amount present in all of the receptacles is in excess of its designated reportable quantity and the containers have the potential to result in exposure to persons off site, the discarding or abandonment of the barrels should be reported as required in Section 355.30.