Document M41nEVwDpDvonk8kk9Y00EY6y

To: Distribution From: Dote: 7. G. Jeanson January 4, 1989 Subject: RELEASE AND SPILL REPORTING One of the requirements of the Emergency Planning and Community Right-to-Know Act of 1986, commonly referred to as SARA, is the reporting of releases of certain substances to the environment (Section 304). The report is to be made to the emergency coordinator of the local emergency planning committee and to the Mississippi Emergency Response Commission. This reporting requirement is in addition to the Superfund or CERCLA section 302(a) reporting to the National Response Center which we have been doing for some time. Naturally, the substances and conditions requiring notification are not the same for each of the reports. Table I lists the substances used in the plant that require SARA release reporting. Table II lists the substances used in the plant that require CERCLA section 302(a) release reporting. The tables also show the reportable quantity for each of the substances. The regulations concerning when reporting is required are complex; therefore, the Environmental Coordinator should be contacted immediately in case of a spill or release to help determine if it requires reporting. In general, a spill or release of any substances in excess of the reportable quantity except for federally permitted discharges (most vinyl chloride emissions are federally permitted) must be reported. Any non--permitted release of a gaseous material in excess of the reportable quantity will require reporting for both SARA and CERCLA 302(a). If greater than the reportable quantity of a liquid or solid is spilled on concrete and totally contained before it reaches any soil, the spill does not need to be reported by either SARA or CERCLA 302(a). If greater than a reportable quantity of a liquid or solid is spilled on the ground but the spill does not leave the plant boundary, it needs to be reported to CERCLA 302(a) only. If greater than the reportable quantity leaves the plant boundary, the spill will also need to be reported under SARA. Attached is a form listing the questions usually asked when a release is reported to the National Response Center {CERCLA 302(a) list). This form should be filled out by the operating personnel in the area where the release occurs prior to the phone call Also attached is the Mississippi Emergency Management Agency Hazardous Material Release Report form. When notifying the coordinator of the local planning committee and the Mississippi Emergency Response Coi Milt Isslon of a SARA release, the information in boxes 1 through 9 must be provided. Distribution 1/04/89 Release and Spill Reporting Page 2 In addition to the verbal report of a SARA release, a written followup emergency notice is also required setting forth and: updating the information required to be reported in the verbal report and to include additional information with respect to: 1* Actions taken to respond to and contain the release. 2. Any known or anticipated acute or chronic health risks associated with the release, and 3. Where appropriate, advice regarding medical attention necessary for exposed individuals. This written report is to be sent to the emergency coordinator of the local emergency planning committee and to W. E. Austin, Special Projects Officer, SARA Title III, Mississippi Emergency Response Commission, F. 0. Box 4501, Fondron Station, Jackson, MS 39216-0501. The written report is to be submitted as soon as practicable after the The written report should be submitted within ten days as a warHiwmi A F. G. Jeanson Environmental Coordinator rah attachment 7-3 i- VAB.0001150660 Report to: TABLE I SARA REPORTING MATERIALS 1, .Jerome Huskey Emergency Coordinator, Local Planning Committee tfork Phone: 601-369-6439 Home Phone: 601-369-6439 2. Mississippi Emergency Response Commission 1-800-222--6362 In State (24--Hour Number) 1-601--352--9100 Out of State (24--Hour Number) 1-960-9000 Regular Hours Material Ammonia {(E.H 5 ) Chlorine (S H5>) CAS Number 7664-41-7 7782-50-5 Reportable Quantity Pounds 100 10 Hydrazine ^ H S] Hydroquinone H$) Sulfuric Acid (jB K'b ) 302-01-2 123-31-9 7 664-95-9 1 1 1000 * 7-4 VAB.0001150661 TABLE II CERCLA 302 fa) MATERIALS Report to: National Response Center 1-800-424-8802 Material Aamonia Antimony Trloxlde Asbestos (Friable forms only) Chlorine Di-n-octyl Phthalate RydrazIne Lead Stearate Lead Sulfate Mercury Methanol Phthalic Anhydride PCB's Sodium Hydroxide Sulfuric Acid Vinyl Chloride Unlisted Hazardous Pastes: Characteristic of Corrosivity Characteristics of Arsenic DO04 Toxicity Barium D005 Cadmium D006 Lead D008 Characteristic of Ignltabillty Characteristic of Reactivity i k 7-5 i A Reportable Quantity Pounds 100 1000 1 10 5000 1 5000 100 1 5000 5000 10 1000 1000 1 100 1 1000 10 1 100 100 VAB.0001150662 EMERGENCY RELEASE NOTIFICATIONI FLWgHART C1RCIA AND TITLE III COMBINED REQUIREMENTS 1. ON-SITE RELEASE: EHS YES I REQUIRED t HAZARDOUS FORMAL NOTIFICATION REQUIRED ONLY TO NRC NO FENCEUNE 2. OFF-SITE RELEASE: FORMAL NOTIFICATION REQUIRED ONLY TO NRC rx X X x BSL1ASS FACILITY X x EHS r EXTREMELY HAZARDOUS SUBSTANCE x x CERCLA r CERCLA HAZARDOUS SU6STANCE W9=mmmsem NRC = NATIONAL RESPONSE CENTER (1-800-424-8802) EHS ONLY YES EHS/CERCLA IMMEDIATE NOTICE AND FOLLOW-UP REPORT TO LEPC AND SERC NON DESIGNATED AS "HA2 UNDER CERCLA. NRC UNTIL S" IMMEDI ATE NOTICE TO LEPC^SERC, AND NRC; FOLLOW-UP REPORT TO LCPC, AND SERC A * \ * L .i NO CERCLA ONLY IMMEDIATE NOTICE TO LEPC, SERC, AND NRC; FDLLOW-UP REPORT TO LEPC, AND SERC VAB.OOOl150663l: ATTACHMENT A Superfund Reporting Checklist k I. Below RQ II. Above RQ 1.0 Air A. NESHAPS 1. VCM In VCM service i) Process Vent 1. Less than 10 ppm VCM for 3 hr. TWA 2. Exceeds 10 ppm std * by less than RQ 3. Exceeds lOppm std by more than RQ ii) RV/RD release iSi) RV/RD leak iv) Other leaks v) Incinerator by-pass Not in VCM service 0 Process Vent H) RV/RD release iii) RV/RD leak v) Other leaks Massive Release May also be OSHA reportable within 24 hours if there is exposure 2. BENZENE a) In benzene service i) Process vent 1. In compliance with std 2. Above standard by less than RQ 3. Above standard by more than RQ H) RV/RD release iii) RV/RD leak iv) Other leak No No Yes Yes No No Yes Yes Yes Yes No Yes No No Yes Yes No No VAB.0001150664 f Jl " HI 'T ' H b) Not in benzene service i) Process vent ii) RV/RD release iii) RV/RD leak iv) Leak c) Massive release May be OSHA reportable also B. SIP 1. Release from specifically regulated point a) In compliance with regulation b) Above regulation by less than RQ c) Above regulation by more than RQ 2. Fugitive leak if SEP has fugitive control requirements C. OTHER * 2. Continuous or routine releases 2. Significant increase in continuous or routine release 2.0 WATER A. NPDES regulated discharge 1. Permit exceedance caused by spill of hazardous substance 2. No permit exceedance 3. Permit application identifies substance and amount (concentration) 4. Stormwater outfall B. SPILLS 1. Ground a) Inside Plant 0 Volatile ) Nonvolatile, nonporous surface iii) Nonvolatile, porous surface iv) Sewer (See NPDES) f A Yes Yes Yes No Yes No No Yes No No Yes Yes No No Yes Yes No Yes VAB.0001150665 (i) "Bulk resin" means a resin which is produced by a polymerization proc ess in which no water is used. (j) "Inprocess wastewater" means any water which, during manufactur ing or processing, comes into direct contact with vinyl chloride or polyvi nyl chloride or results from the pro duction or use of any raw material, in termediate product, finished product, by-product, or waste product contain ing vinyl chloride or polyvinyl chloride but which has not been discharged to a wastewater treatment process or dis charged untreated as wastewater. Gas holder seal water is not inprocess wastewater until it is removed from the gasholder. (k) "Wastewater treatment process" includes any process which modifies characteristics such as BOD, COD, TSS, and pH, usually for the purpose of meeting effluent guidelines and standards; it does not include any process the purpose of which is to remove vinyl chloride from water to meet requirements of this subpart. (l) "In vinyl chloride service" means that a piece of equipment either con tains or contacts a liquid that is a least 10 percent vinyl chloride by weight or a gas that is at least 10 percent by volume vinyl chloride as determined according to the provisions of 61.67(h). The provisions of 61.67(h) also specify how to determine that a piece of equipment is not in vinyl chlo ride service. For the purposes of this subpart, this definition must be used in place of the definition of "in VHAP service" in Subpart V of this part. (m) "Standard operating procedure" means a formal written procedure offi cially adopted by the plant owner or operator and available on a routine basis to those persons responsible for carrying out the procedure. (n) "Run" means the net period of time during which an emission sample is collected. (o) "Ethylene dichloride purifica tion" includes any part of the process of ethylene dichloride production which follows ethylene dichloride for mation, excluding product storage fol lowing the final finishing column. (p) "Vinyl chloride purification" in cudes any part of the process of vinyl chloride production which follows j vinyl chloride formation. <q) "Reactor" includes any vessel in which vinyl chloride is partially or to tally polymerized into polyvinyl chlo ride. (r) "Reactor opening loss" means the emissions of vinyl chloride occur ring when a reactor is vented to the at mosphere for any purpose other than an emergency relief discharge as de fined in 61.66(a). (s) "Stripper" includes any vessel in which residual vinyl chloride is re moved from polyvinyl chloride resin. j except bulk resin, in the slurry form j by the use of heat and/or vacuum. In the case of bulk resin, stripper in cludes any vessel which is used to remove residual vinyl chloride from polyvinyl chloride resin immediately following the polymerization step in the plant process flow. (t) "Standard temperature" means a temperature of 20* C (69* F). (u) "Standard pressure" means a pressure of 760 mm of Hg (29.92 in. of Hg). (v) "Relief valve" means each pres sure relief device including pressure relief valves, rupture disks and other pressure relief systems used to protect process components from overpressure conditions. "Relief valve" does not in clude polymerization shortstop sys tems, referigerated water systems or control valves or other devices used to control flow to an incinerator or other air pollution control device. (w) "Leak" means any of several events that indicate interruption of confinement of vinyl chloride within process equipment. Leaks include j events regulated under Subpart V of this part such as: (1) An instrument reading of 10,000 ppm or greater measure according to Method 21 (see Appendix A of 40 CFR Part 60); (2) Indications of liquid dripping; (3) A sensor detection of failure of a seal system, failure of a barrier fluid system, or both; and (4) Detectable emissions as indicated by an instrument reading of greater than 500 ppm above background for i equipment designated for no detecta- j ble emissions measured according to i Test Method 21 (see Appendix A of 40 j I t A VAB.0001150666 NOTIFY MEMA IN THE EVENT OF: HAZARDOUS MATERIAL SPILLS SEVERE WEATHER DAMAGE (tornado, thunderstorms, etc.) RADIOLOGICAL INCIDENTS MISSING/OVERDUE AIRCRAFT MAJOR FIRE or EXPLOSION FLOODING MAJOR TRANSPORTATION ACCIDENTS (Highway, Air, Rail, Marine, Pipeline) EVACUATIONS SEARCH and RESCUE REQUEST FOR NATIONAL GUARD SUPPORT ANY EMERGENCY WHICH MAY REQUIRE STATE SUPPORT ( MEMA WILL NOTIFY THESE STATE AGENCIES IN THE EVENT OF AN EMERGENCY: DEPARTMENT OF NATURAL RESOURCES Bureau of Pollution Control STATE DEPARTMENT OF HEALTH Division of Radiological Health STATE HIGHWAY DEPARTMENT PUBLIC SERVICE COMMISSION HIGHWAY PATROL NATIONAL GUARD DEPARTMENT OF WILDLIFE CONSERVATION OIL AND GAS BOARD - POST THIS NOTICE FOR EMERGENCY REFERENCE --VAB'"667 ir  * ( MEMA-III-1 [OCT87] 7-10 -jn . | rtv I v FAX# 35'1-ttM`t 1 Naaa of ptnon reporting the spill and/or release 2. Company represented: Vista Polymers Inc. 3. Mailing address and phone number: P. 0. Box 91* Aberdeen, Mississippi 39730________ 4. Plant location: Highway 25 South 5 County: Monroe 6* Site of apill: (601) 369-8111 7 . Material spilled: 8. Time and date of spill: 9. Wind direction* wind speed* barometric pressure: 10. Did spill enter a waterway: 11. Water body affected: [ ] Yes [ } Mo 12. Source of spill: 13 Cause of spill NATIONAL RESPONSE CENTER TYPICAL QUESTIONS Pag* 2 14. Wa equipment In operation at the time; 15. Size of spill: [I [ ] No 16. Was there any property damage from the spill: [ ] Yes C ) No A mJ 17. Corrective action taken to stop spill: 18. Old company personnel conduct' cleanup: f1 [ 1 No 19. Ran the affected equipment been repaired C 1 i I No 20. Was anyone hurt: [ ] Yes [ ] No 21 Was any evacuation needed: [ ] Yea f 1 No 22 Have any other agencies been notified of the spill: [ ] Yes [ ] No 23* Do va have any plans to notify any other agenev: ( ] Yes C ] No 1. Time and date incident reported to National Response Center 2. Name of person accepting report 3. Other infor--tIon requested: 4. Signed: 7-7 VAB.0001150670 To Prom R(=u^a Calculation Sheet CauCU L-AT(.cW Pfi,OC^bO^ A K-i.o i V r' AS" Asso/u^s ftt-*- Losz Is Bx\t A- BajT/^majc^r {C 0aj5 fe R >^47< JE M-cy^fc- C_os VAbans. Less, $-(-<69 - T>c=>rr^ (9f ^lc><> 0 (Vt3) (Se"^2^ V - V/(ft/sec P - Vflssso< Oi- Lb C 32.2. IbKVl f+/l (V s t-LVtb 2- PS l <i ^ObST lllTTt AJ> W?<C K I .^<u V ~76.k p/ I \/&tocnw E>^ A(2 C* R (ffz) A ajo OoRAT'O^) 0^ (_*E: C 0/0 6 5 Co Gt,T A^oo/j-r V V^cxbas e (L&SyJ C9> J -h> ta PV^ n E.1 => ?v/ = P lAW - 5.&T. P R.1 T Kw OF V/CM = 62.5 RT M _ p KU2 V <J-~r T- F + 4cc> P. 10.12. PS,A P = PS/A mck^ IX Mw. MotecucAt, W*-iCih1 VJSi o C ' t>6;AC A #^w)(P)(y) (R). (T) = (62,5 4i /m pic 1 (i*aa) (fts) ('(t) C 10.13 P.'A.T2 m-kou;^ _ 5,62. PV Made By Date __ Page V3-20G-S of Job Mo. Firte VAB.0001150671