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The meaning of the phrase "as soon as practicable" for emergency release notification

The release of a reportable quantity (RQ) of an extremely hazardous substance (EHS) or CERCLA hazardous substance within any 24-hour period triggers the EPCRA emergency release notification requirements (40 CFR 355.33).  A facility must make two separate notifications to comply with the EPCRA release notification requirements: an immediate notification and, as soon as practicable thereafter, a written follow-up emergency notification (§355.40).  Has EPA provided guidance on the meaning of the phrase “as soon as practicable?”

EPA believes that thirty days should be sufficient to submit the written follow-up notice of the emergency release to the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC). However, states may implement a more stringent timeframe if they so choose (75 FR 39852, 39857; July 13, 2010).