Document Z4x64vqQnJ9gRBK44vrwwqrz0

^L: rf TO: R. E. Lehmkuhl, J. J. Langford, R. T. Ferrell, D. A, Kuhn I Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles October 31, 1986 EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT ) VIST/ The subject act was passed with the revised Superfund bill. It establishes requirements for state governments and for manufacturers and users of certain chemicals. The requirements are administratively very burdensome, and will have significant impact on Vista, and the chemical industry, as a result of public reaction to required emissions reporting. It is clear at this point that significant manpower will be required to develop and maintain the } required data that must be complied and reported. Also, new release reporting protocols and employee training efforts will be necessary at all plants. In general the act; (a) requires the establishment of emergency planning districts, local commissions, and emergency response plans including public notification of releases; (b) establishes expanded chemical release reporting requirements, including annual reporting of inventories and routine emissions of a large list of chemicals; and (c) creates new enforcement and citizen suit causes of action for non-compliance. It is important that at least the specific items listed below are brought to your attention at this time. 1. State governments will be required to establish emergency planning districts and committees. Each plant must have representatives on the committee. The committees must develop comprehensive emergency release response plans to include community notification and evacuation procedures. 2. The list of chemicals for which releases above an established reportable quantity must be reported has been expanded and reporting requirements are now more specific, including a written follow-up report for all reported releases. The follow-up report must include an assessment of potential health effects resulting from the release and appropriate medical advice. 3. Each plant must prepare, annually, inventory report forms for all hazardous chemicals (as defined by OSHA) which include the following information: (a) estimates of the maximum amount present at any time during the past year; VVV 000015574 Page 2 October 31, 1986 (b) an estimate of average daily amounts present during the past year; and (c) the general location of hazardous chemicals in the facility. Additional information may be requested including a brief description of the manner of chemical storage. The inventory forms must be submitted to the local emergency planning committee, state emergency response commission and local fire department. The information will be made available to the public upon request. 4. Each plant must prepare, annually, toxic chemical release forms for certain chemicals which must include the following information: (a) estimate of maximum amounts of toxic chemicals present at the facility; (b) for each wastestream, the treatment or disposal methods employed and an estimate of treatment method efficiencies, and (c) the annual quantity of the toxic chemicals entering each environmental medium. 5. Each emergency response plan, inventory form, toxic chemical release form, and follow-up written release report shall be made available to the public at a location designated by the local emergency planning committee. Each local committee shall annually publish a notice in local newspapers that the required information has been submitted, is available for review, and where it may be obtained. 6. The act establishes penalties and creates for the first time citizen suit provisions allowing suits for non-compliance with the act. N ------- Thomas G. Grumbles ajo/9 cc Plant Managers Safety Directors Environmental Coordinators W. L. McClain yyV 000015 575 TO: D. A. Kuhn mtr . i I FROM: DATE: Interoffice Communication J* T. G. Grumbles October 31, 1986 PROGRESS REPORT FOR THE WEEK ENDING OCTOBER 31, 1986 VIST* r 1. I accepted a nomination to be the Chairman of EOIC Industrial Hygiene Committee. The group is being reformed to address OSHA's rulemaking activity regarding the Eto STEL. 2. We are continuing to evaluate the impact of the new Emergency Planning and Community Right-To-Know Act passed as a companion bill to the Superfund bill. A letter has been drafted to i advise upper management of the actTs requirements. 3. Researched TSCA regulations for the plants in preparation for completing the TSCA Inventory Update. 4. Joe Ledvina attended the annual DEQ seminar in Baton Rouge. 5. Updated State environmental regulations. 6. Researched applicable DOT regulations on the back hauling of Aberdeen raw materials. A memo will be issued. Thomas G. Grumbles ajo/9 VVV 000015576