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 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. 2 2 Michigan SARA Title III Program 1
Agrichemical Release Reporting IF THERE IS A RELEASE… … IF THERE IS A RELEASE Immediately (within 15 minutes) (within 15 minutes) Immediately call: call: � Local Local – – 911 911 � State – – MDA Hotline MDA Hotline � State � Or PEAS if water impacted � Or PEAS if water impacted � Federal – – NRC NRC � Federal � � Phone Numbers on Phone Numbers on Page 8 Page 8 – – Emergency Emergency � Planning for the Farm Planning for the Farm 3 3 REPORT ALL RELEASES REPORT ALL RELEASES Will this result in over- -reporting? reporting? Will this result in over 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’ ’s sake. s sake. � For safety � 4 4 Michigan SARA Title III Program 2
Agrichemical Release Reporting WHY REPORT ALL RELEASES? WHY REPORT ALL RELEASES? www.michigan.gov/deqrelease release www.michigan.gov/deq 5 5 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. 6 6 Michigan SARA Title III Program 3
Agrichemical Release Reporting WHY REPORT ALL RELEASES? WHY REPORT ALL RELEASES? WHY REPORT ALL RELEASES? 28 State & Federal regulations have � 28 State & Federal regulations have � requirements to report releases. requirements to report releases. This includes: This includes: This includes: � Releases of Releases of variable amounts variable amounts of of � Releases of variable amounts of � fuels and and hazardous substances hazardous substances fuels fuels and hazardous substances to the environment, to the environment, to the environment, � And fuels from Above Ground And fuels from Above Ground � And fuels from Above Ground � Storage Tanks to secondary Storage Tanks to secondary Storage Tanks to secondary containment. containment. containment. 7 7 WHY REPORT ALL RELEASES? WHY REPORT ALL RELEASES? A single release might be reportable reportable � A single release might be � under multiple regulations. under multiple regulations. Failure to report a release might be � Failure to report a release might be � enforceable under multiple enforceable under multiple regulations. regulations. 8 8 Michigan SARA Title III Program 4
Agrichemical Release Reporting WHY REPORT ALL RELEASES? WHY REPORT ALL RELEASES? Let’ ’s look at 2 federal regulations: s look at 2 federal regulations: Let CERCLA � CERCLA � � SARA Title III SARA Title III � First some background… First some background …. . 9 9 BACKGROUND BACKGROUND BACKGROUND � C Comprehensive omprehensive E Environmental nvironmental � Comprehensive Environmental � Response, R esponse, C Compensation and ompensation and L Liability iability Response, Compensation and Liability Act of ct of 1980 1980 A Act of 1980 � Cleanup hazardous waste disposal sites Cleanup hazardous waste disposal sites � Cleanup hazardous waste disposal sites � � Emergency response for Emergency response for hazardous hazardous � Emergency response for hazardous � substances released into the into the substances released substances released into the environment environment environment CERCLA = = Superfund Superfund CERCLA CERCLA = Superfund 10 10 Michigan SARA Title III Program 5
Agrichemical Release Reporting December 3, 1984 December 3, 1984 in Bhopal, India in Bhopal, India December 3, 1984 in Bhopal, India Union Carbide chemical plant Union Carbide chemical plant Union Carbide chemical plant Methyl isocyanate isocyanate release release Methyl Methyl isocyanate release 4,000 deaths 4,000 deaths 4,000 deaths 40,000 maimed & seriously 40,000 maimed & seriously 40,000 maimed & seriously injured injured injured Plants defoliated Plants defoliated Plants defoliated Livestock died Livestock died Livestock died 11 11 BACKGROUND BACKGROUND BACKGROUND � S Superfund uperfund A Amendments and mendments and � Superfund Amendments and � Reauthorization R eauthorization A Act of ct of 1986 1986 Reauthorization Act of 1986 ( (SARA SARA) ) (SARA) SARA Title III = Emergency = Emergency � SARA Title III � SARA Title III = Emergency � Planning and Community Planning and Community Planning and Community Right- -to to- -Know Act ( Know Act (EPCRA EPCRA) ) Right Right-to-Know Act (EPCRA) 12 12 Michigan SARA Title III Program 6
Agrichemical Release Reporting BACKGROUND BACKGROUND CERCLA section 103 section 103 CERCLA � ≈ ≈ 770 770 Hazardous Substances Hazardous Substances � SARA Title III section section 304 304 SARA Title III 355 Extremely Hazardous � 355 Extremely Hazardous � Substances (EHS EHS) ) Substances ( Each substance has a reportable Each substance has a reportable quantity (RQ RQ) for release reporting. ) for release reporting. quantity ( 13 13 LIST OF LISTS LIST OF LISTS EPA PUBLICATION EPA PUBLICATION www.michigan.gov/deqrelease release www.michigan.gov/deq Look under “ “Related Links Related Links” ” Look under CERCLA Hazardous Substances SARA Title III EHSs RQs for Releases 14 14 Michigan SARA Title III Program 7
Agrichemical Release Reporting LIST OF LISTS LIST OF LISTS Press “GO” 15 15 LIST OF LISTS LIST OF LISTS 16 16 Michigan SARA Title III Program 8
Agrichemical Release Reporting CERCLA section 103 CERCLA section 103 Release into the environment into the environment of of a a Release 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 in corresponding reportable quantity in any 24- -hour period. hour period. any 24 17 17 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. 18 18 Michigan SARA Title III Program 9
Agrichemical Release Reporting WHO MUST REPORT TO WHOM? WHO MUST REPORT TO WHOM? SARA Title III– – Owner or Operator to Owner or Operator to SARA Title III � Local Local Emergency Planning Emergency Planning � Committee (LEPC LEPC) and ) and Committee ( State Emergency Response Emergency Response � State � Commission (by calling PEAS PEAS or or Commission (by calling MDA) ) MDA CERCLA – – Person in charge to Person in charge to CERCLA � National National Response Center ( Response Center (NRC NRC) ) � 19 19 Examples of Reportable Releases Examples of Reportable Releases Anhydrous Ammonia – Anhydrous Ammonia – 100 lbs (18 100 lbs (18 gals) gals) Guthion 2L Guthion 2L - - ½ ½ gal gal Dimethoate 4E Dimethoate 4E – – 2.5 gal 2.5 gal Counter 20CR – – 480 lbs 480 lbs Counter 20CR Sevin 4F 4F – – 25 gal 25 gal Sevin Fuel – Fuel – any amount if potential to any amount if potential to impact ground or surface water impact ground or surface water 20 20 Michigan SARA Title III Program 10
Agrichemical Release Reporting 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. 21 21 INITIAL NOTIFICATION INITIAL NOTIFICATION 22 22 Michigan SARA Title III Program 11
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