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Are releases into a POTW subject to CERCLA section 103(a) reporting requirements?

Are releases of a pollutant into a Publicly Owned Treatment Works (POTW), when the pollutant is specified in and in compliance with the pretreatment standards of the Clean Water Act, subject to CERCLA section 103(a) reporting requirements?

No. The introduction of any pollutant into a POTW, when the pollutant is specified in and in compliance with applicable pretreatment standards of CWA section 307(b) or (c) - and enforceable requirements in a pretreatment program submitted by a State or municipality for federal approval under CWA section 402 - is one of the releases permitted under other federal programs as defined by CERCLA section 101(10)(J). Such releases are exempt from CERCLA section 103(a) reporting requirements.

Are releases into a POTW subject to CERCLA section 103(a) reporting requirements?

Emergency Planning and Community Right-to-Know Act (EPCRA)