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 Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substance within any 24-hour period triggers the Emergency Planning and Community Right-to-Know Act (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 (40 CFR 355.40).  Has EPA provided guidance on the meaning of the phrase “as soon as practicable?”

EPA believes that 30 days should be sufficient to submit the written follow-up notice of the emergency release to the State or Tribal Emergency Response Commission (SERC or TERC) and the Local or Tribal Emergency Planning Committee (LEPC or TEPC). However, states or tribes may implement a more stringent timeframe if they so choose (75 FR 39852, 39857; July 13, 2010).