Document kmOgrmB3neVMZYBRb1pZoZDVE

ABD00310748 l Interoffice Communication To: F. G. Jeanson K3> From: Dote: K. G. Akins July 6, 1992 Subject: SARA AMD CERCLA RELEASE REPORTING ^1. m VISTA I recently attended a SARA Title III seminar presented by the EPA Region IV in Atlanta. One of the topics was the reporting of chemical releases subject to CERCLA and/or SARA reporting. I thought the information from this presentation was worth passing on to you. The EPA defines the word "immediate" as it is used in when to notify emergency agencies as within 15 minutes. After anyone at your facility becomes aware of a reportable release in excess of the reportable quantity, someone must notify the appropriate agencies within 15 minutes. Obviously this gives little time for calculations of quantities released, emergency response activities, or anything else for that matter. They said you should make the call regardless within 15 minutes with an estimate of a released quantity. This same point was stressed several times by several speakers throughout the day. In the assessment of penalties for late reporting (past 15 minutes), the EPA uses time of time of reporting combined with amount of chemical released to establish a monetary penalty. The definitions and resultant penalty matrix are given below: Level 1: No notification within two hours. Level 2: No notification within one hour but within two hours. Level 3: No notification within 15 minutes but within 1 hour. Level A: The amount released was greater than 10 times the reportable quantity (RQ) . Level B: The amount released was greater than 5, but less than 10 or equal to 10 times the RQ. Level C: The amount released was greater than 1, but less than 5 times the RQ. 1^' ABD00310749 R LEVEL 1 LEVEL 2 LEVEL 3 LEVEL A $20000-$25000 $13200-$16500 $6600-$8250 LEVEL B $13200-$16500 $5000-$6250 $3600-$4500 LEVEL C $6600-$8250 $3600-$4500 $2000-$2500 As always, multi-day penalties can be applied as each passing day constitutes a violation. It was also interesting to find out that reporting of releases can and does prompt chemical safety audits and SARA\EPCRA audits from EPA Region IV. K. G. Akins Senior Environmental Coordinator C: RWS, JEN, GWW "TVie. "~Co (te Koc/Omj Ci KAe' |vm^tA/o Gu^cds. lCau- L& &tcu- "Twer U$> & DtuscoAj A/j^> Tkg' KJee-o ~u P^Oa^-r Alow- I^eQutfLfc^ P-&t?o<L'tiflSc{ CAP 'To Auo*-i$. M./WOfeT Payt. \JouJ f'LCzU/be ^ AajGajY 'SvtsU'TcdsJ Wc ^SHOck^O Ovwaic^s tuAr Tuerv Sham A/may T"<r Qu/ditfi (M/uev/areT-Lf <So ^^a/Ai GtA/Q PouJ U ^ C/l^- UtsT To (^OM.eO/1/^ l^Ho Ca*j Mftlce ~uc Dtai>LC*S Aao Ca^- Apf^,p(L,A-ce h UEtiCL es 4 15 A P. ~iULJ> l & yd VffrM/l/i/enrr' 'SvuuiuyrJ. doAAMenru?