AGRICHEMICAL AGRICHEMICAL RELEASE REPORTING RELEASE REPORTING - - PDF document

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Agrichemical Release Reporting AGRICHEMICAL AGRICHEMICAL RELEASE REPORTING RELEASE REPORTING Susan Parker Susan Parker Michigan Michigan SARA Title III SARA Title III Program Program January 2010 January 2010 1 1 WHAT IS A

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SLIDE 1

Agrichemical Release Reporting

Michigan SARA Title III Program 1

1 1

Susan Parker Susan Parker Michigan Michigan SARA Title III SARA Title III Program Program January 2010 January 2010

AGRICHEMICAL AGRICHEMICAL RELEASE REPORTING RELEASE REPORTING

2 2

WHAT IS A RELEASE? WHAT IS A RELEASE?

  • SPILL, LEAK, PUMP, POUR, EMIT, EMPTY,

SPILL, LEAK, PUMP, POUR, EMIT, EMPTY, DISCHARGE, INJECT, ESCAPE, LEACH, DISCHARGE, INJECT, ESCAPE, LEACH, DUMP, DISPOSE DUMP, DISPOSE

  • LAND APPLICATION OR USE OF A

LAND APPLICATION OR USE OF A SUBSTANCE THAT IS CONSISTENT WITH SUBSTANCE THAT IS CONSISTENT WITH GENERALLY ACCEPTED AGRICULTURAL GENERALLY ACCEPTED AGRICULTURAL MANAGEMENT PRACTICES IS MANAGEMENT PRACTICES IS NOT NOT A A RELEASE. RELEASE.

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SLIDE 2

Agrichemical Release Reporting

Michigan SARA Title III Program 2

3 3

IF THERE IS A RELEASE IF THERE IS A RELEASE… …

Immediately Immediately (within 15 minutes) (within 15 minutes) call: call:

  • Local

Local – – 911 911

  • State

State – – MDA Hotline MDA Hotline

  • Or PEAS if water impacted

Or PEAS if water impacted

  • Federal

Federal – – NRC NRC

  • Phone Numbers on

Phone Numbers on Page 8 Page 8 – – Emergency Emergency Planning for the Farm Planning for the Farm

4 4

REPORT ALL RELEASES REPORT ALL RELEASES

Will this result in over Will this result in over-

  • reporting?

reporting?

  • Probably

Probably Then why do it? Then why do it?

  • There are no penalties for over

There are no penalties for over-

  • reporting.

reporting.

  • It simplifies an otherwise

It simplifies an otherwise complicated requirement (CYA). complicated requirement (CYA).

  • For safety

For safety’ ’s sake. s sake.

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SLIDE 3

Agrichemical Release Reporting

Michigan SARA Title III Program 3

5 5

WHY REPORT ALL RELEASES? WHY REPORT ALL RELEASES? www.michigan.gov/deq www.michigan.gov/deqrelease release

6 6

RELEASE NOTIFICATION RELEASE NOTIFICATION REQUIREMENTS TABLE REQUIREMENTS TABLE

October 27, 2009 October 27, 2009

  • WHAT

WHAT

  • WHEN

WHEN

  • TO WHOM

TO WHOM & &

  • HOW

HOW releases must be reported in State releases must be reported in State & Federal Regulations that apply in MI. & Federal Regulations that apply in MI.

  • Does NOT include release reporting

Does NOT include release reporting requirements in permits, contingency requirements in permits, contingency plans, local ordinances, etc. plans, local ordinances, etc.

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SLIDE 4

Agrichemical Release Reporting

Michigan SARA Title III Program 4

7 7

WHY REPORT ALL RELEASES? WHY REPORT ALL RELEASES? WHY REPORT ALL RELEASES?

This includes:

Releases of variable amounts of

fuels and hazardous substances to the environment,

And fuels from Above Ground

Storage Tanks to secondary containment. This includes: This includes:

  • Releases of

Releases of variable amounts variable amounts of

  • f

fuels fuels and and hazardous substances hazardous substances to the environment, to the environment,

  • And fuels from Above Ground

And fuels from Above Ground Storage Tanks to secondary Storage Tanks to secondary containment. containment.

  • 28 State & Federal regulations have

28 State & Federal regulations have requirements to report releases. requirements to report releases.

8 8

WHY REPORT ALL RELEASES? WHY REPORT ALL RELEASES?

  • A single release might be

A single release might be reportable reportable under multiple regulations. under multiple regulations.

  • Failure to report a release might be

Failure to report a release might be enforceable enforceable under multiple under multiple regulations. regulations.

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SLIDE 5

Agrichemical Release Reporting

Michigan SARA Title III Program 5

9 9

WHY REPORT ALL RELEASES? WHY REPORT ALL RELEASES?

Let Let’ ’s look at 2 federal regulations: s look at 2 federal regulations:

  • CERCLA

CERCLA

  • SARA Title III

SARA Title III First some background First some background… …. .

10 10

BACKGROUND BACKGROUND BACKGROUND

Comprehensive Environmental

Response, Compensation and Liability Act of 1980

Cleanup hazardous waste disposal sites Emergency response for hazardous

substances released into the environment CERCLA = Superfund

  • C

Comprehensive

  • mprehensive E

Environmental nvironmental R Response, esponse, C Compensation and

  • mpensation and L

Liability iability A Act of ct of 1980 1980

  • Cleanup hazardous waste disposal sites

Cleanup hazardous waste disposal sites

  • Emergency response for

Emergency response for hazardous hazardous substances released substances released into the into the environment environment CERCLA CERCLA = = Superfund Superfund

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SLIDE 6

Agrichemical Release Reporting

Michigan SARA Title III Program 6

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December 3, 1984 in Bhopal, India Union Carbide chemical plant Methyl isocyanate release 4,000 deaths 40,000 maimed & seriously injured Plants defoliated Livestock died December 3, December 3, 1984 1984 in Bhopal, India in Bhopal, India Union Carbide chemical plant Union Carbide chemical plant Methyl Methyl isocyanate isocyanate release release 4,000 deaths 4,000 deaths 40,000 maimed & seriously 40,000 maimed & seriously injured injured Plants defoliated Plants defoliated Livestock died Livestock died

12 12

BACKGROUND BACKGROUND BACKGROUND

Superfund Amendments and

Reauthorization Act of 1986 (SARA)

SARA Title III = Emergency

Planning and Community Right-to-Know Act (EPCRA)

  • S

Superfund uperfund A Amendments and mendments and R Reauthorization eauthorization A Act of ct of 1986 1986 ( (SARA SARA) )

  • SARA Title III

SARA Title III = Emergency = Emergency Planning and Community Planning and Community Right Right-

  • to

to-

  • Know Act (

Know Act (EPCRA EPCRA) )

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SLIDE 7

Agrichemical Release Reporting

Michigan SARA Title III Program 7

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CERCLA CERCLA section 103 section 103

  • ≈

≈770 770 Hazardous Substances Hazardous Substances

SARA Title III SARA Title III section section 304 304

  • 355 Extremely Hazardous

355 Extremely Hazardous Substances ( Substances (EHS EHS) ) Each substance has a reportable Each substance has a reportable quantity ( quantity (RQ RQ) for release reporting. ) for release reporting.

BACKGROUND BACKGROUND

14 14

LIST OF LISTS LIST OF LISTS

EPA PUBLICATION EPA PUBLICATION

www.michigan.gov/deq www.michigan.gov/deqrelease release

Look under Look under “ “Related Links Related Links” ” CERCLA Hazardous Substances SARA Title III EHSs RQs for Releases

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SLIDE 8

Agrichemical Release Reporting

Michigan SARA Title III Program 8

15 15

LIST OF LISTS LIST OF LISTS

Press “GO”

16 16

LIST OF LISTS LIST OF LISTS

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SLIDE 9

Agrichemical Release Reporting

Michigan SARA Title III Program 9

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CERCLA section 103 CERCLA section 103

Release Release into the environment into the environment of

  • f a

a CERCLA hazardous substance CERCLA hazardous substance … … in a in a quantity equal to or greater than its quantity equal to or greater than its corresponding reportable quantity corresponding reportable quantity in in any 24 any 24-

  • hour period.

hour period.

18 18

SARA Title III section 304 SARA Title III section 304

Release of a CERCLA hazardous substance or Extremely Hazardous Substance (EHS) ... in a quantity equal to or greater than its corresponding reportable quantity in any 24-hr period that migrates beyond the facility boundaries.

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SLIDE 10

Agrichemical Release Reporting

Michigan SARA Title III Program 10

19 19

WHO MUST REPORT TO WHOM? WHO MUST REPORT TO WHOM?

SARA Title III SARA Title III– – Owner or Operator to Owner or Operator to

  • Local

Local Emergency Planning Emergency Planning Committee ( Committee (LEPC LEPC) and ) and

  • State

State Emergency Response Emergency Response Commission (by calling Commission (by calling PEAS PEAS or

  • r

MDA MDA) ) CERCLA CERCLA – – Person in charge to Person in charge to

  • National

National Response Center ( Response Center (NRC NRC) )

20 20

Examples of Reportable Releases Examples of Reportable Releases

Anhydrous Ammonia Anhydrous Ammonia – – 100 lbs (18 100 lbs (18 gals) gals) Guthion Guthion 2L 2L -

  • ½

½ gal gal Dimethoate Dimethoate 4E 4E – – 2.5 gal 2.5 gal Counter 20CR Counter 20CR – – 480 lbs 480 lbs Sevin Sevin 4F 4F – – 25 gal 25 gal Fuel Fuel – – any amount if potential to any amount if potential to impact ground or surface water impact ground or surface water

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SLIDE 11

Agrichemical Release Reporting

Michigan SARA Title III Program 11

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IF THERE IS A RELEASE IF THERE IS A RELEASE

Follow the instructions on Follow the instructions on page 4 of the Farm page 4 of the Farm Bulletin. Bulletin. This assures compliance This assures compliance with initial reporting for with initial reporting for all 28 regulations in the all 28 regulations in the Table. Table.

22 22

INITIAL NOTIFICATION INITIAL NOTIFICATION

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SLIDE 12

Agrichemical Release Reporting

Michigan SARA Title III Program 12

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Written Follow Written Follow-

  • Up Report

Up Report Due within 7 days Due within 7 days

MDEQ general form: MDEQ general form:

“ “Spill or Release Report Spill or Release Report” ”

Pg 19 in Farm Bulletin Pg 19 in Farm Bulletin Also use this form to document Also use this form to document Initial Notification Initial Notification

24 24

BOTTOM LINE BOTTOM LINE Report the release, then Report the release, then

To determine if a FU report is required. To determine if a FU report is required.

Call: Call: Jack Knorek Jack Knorek 800 800-

  • 405

405-

  • 0101

0101 Or call: Or call: Susan Parker Susan Parker 517 517-

  • 373

373-

  • 8481

8481

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SLIDE 13

Agrichemical Release Reporting

Michigan SARA Title III Program 13

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IMPORTANT ! IMPORTANT !

ALL RELEASES ALL RELEASES MUST BE MUST BE CLEANED UP CLEANED UP – – even if not even if not reportable. reportable.

26 26

ANHYDROUS AMMONIA RELEASE ANHYDROUS AMMONIA RELEASE

For each of the following situations, For each of the following situations, Who must report a release of 100 lbs Who must report a release of 100 lbs

  • f ammonia under
  • f ammonia under

CERCLA sect 103 CERCLA sect 103 or

  • r

SARA Title III sect 304 SARA Title III sect 304? ? Hint: see slide 19 Hint: see slide 19

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SLIDE 14

Agrichemical Release Reporting

Michigan SARA Title III Program 14

27 27

Release from Release from tank tank at an Ag Co at an Ag Co-

  • op
  • p

28 28

Release from Release from supplier hose supplier hose used to fill Tanker Truck used to fill Tanker Truck

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SLIDE 15

Agrichemical Release Reporting

Michigan SARA Title III Program 15

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Release from Release from Tanker Truck Tanker Truck (1) Owned by Supplier or (1) Owned by Supplier or (2) Independently Owned (2) Independently Owned

30 30

Release from Release from nurse tank nurse tank while while ammonia being applied on Farm ammonia being applied on Farm by Supplier by Supplier

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SLIDE 16

Agrichemical Release Reporting

Michigan SARA Title III Program 16

31 31

Release from Release from nurse tank nurse tank owned by

  • wned by

Supplier, being applied by Farmer Supplier, being applied by Farmer

32 32

Release from Release from Farm Tank Farm Tank while while being filled by Tanker Truck being filled by Tanker Truck

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SLIDE 17

Agrichemical Release Reporting

Michigan SARA Title III Program 17

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Release from Release from Tanker Truck Tanker Truck Hose Hose while filling Farm Tank while filling Farm Tank

34 34

Who Must Report Who Must Report… …

If the release from the Tanker Truck If the release from the Tanker Truck’ ’s s hose is due to a problem (faulty hose is due to a problem (faulty valve) with the Farm Tank? valve) with the Farm Tank?

  • The Tanker Truck driver is

The Tanker Truck driver is responsible for reporting. responsible for reporting.

  • How can Tanker Truck drivers

How can Tanker Truck drivers protect themselves from NH protect themselves from NH3

3

releases that are not in their control? releases that are not in their control?

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SLIDE 18

Agrichemical Release Reporting

Michigan SARA Title III Program 18

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Anhydrous Ammonia Farm Tank Anhydrous Ammonia Farm Tank Requirements Requirements

Farm Tanks with storage capacity Farm Tanks with storage capacity ≥ ≥ 500 gals (2750 lbs) must have: 500 gals (2750 lbs) must have:

  • Air Permit

Air Permit

  • Inspection & Maintenance Program

Inspection & Maintenance Program

  • Emergency Response Plan developed

Emergency Response Plan developed and approved by the local fire dept and approved by the local fire dept

  • r county emergency response
  • r county emergency response

agency agency

36 36

Anhydrous Ammonia Anhydrous Ammonia additional Requirements additional Requirements

Farmers that ever have Farmers that ever have ≥ ≥ 91 gals (500 91 gals (500 lbs) of anhydrous ammonia on site lbs) of anhydrous ammonia on site (even if only during application) (even if only during application) must: must:

  • Notify the Michigan SARA Title III

Notify the Michigan SARA Title III Program and the Local Emergency Program and the Local Emergency Planning Committee (LEPC) Planning Committee (LEPC)

  • Have an Emergency Response Plan

Have an Emergency Response Plan developed by the farmer developed by the farmer and and the the LEPC (see Extension Bulletin E LEPC (see Extension Bulletin E-

  • 2575)

2575)

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SLIDE 19

Agrichemical Release Reporting

Michigan SARA Title III Program 19

37 37

Contacts for Help Contacts for Help

  • Release Reporting & Clean

Release Reporting & Clean-

  • up:

up: Jack Jack Knorek Knorek, MDA @ 800 , MDA @ 800-

  • 405

405-

  • 0101

0101

  • Release Reporting & SARA Title III:

Release Reporting & SARA Title III: Susan Parker Susan Parker, MI SARA Title III Program , MI SARA Title III Program @ 517 @ 517-

  • 373

373-

  • 8481

8481

  • SARA Title III & Plans:

SARA Title III & Plans: Your LEPC Your LEPC (contact info online or call Susan Parker) (contact info online or call Susan Parker)

  • Air Permits:

Air Permits: Environmental Assistance Environmental Assistance Center Center @ 800 @ 800-

  • 662

662-

  • 9278

9278