Reporting Environmental Spills/Releases

Transcription

1 Procedure No.: WYN Page: 1 of 6 Revision Date Revision Number 05/18/ Revision History Details of Change Revise document to meet new Site Standard for formatting of controlled documents 5/26/ Revise document to update personnel and the procedure.

2 Procedure No.: WYN Page: 2 of 6 1. PURPOSE 1.1. To outline unit and OH-MI-CAN Hub responsibilities and procedures for reporting spills and/or releases. 2. DEFINITIONS 2.1. Spill and or Release A spill and/or release has occurred when there has been an unexpected or unpermitted liberation of a substance from its normal confinement mode. This would include leaking, pumping, pouring, emitting, emptying, discharging, escaping, leaching, dumping or disposing of a substance. A spill or release has also occurred when a permit condition (i.e., air, NPDES, POTW) has been violated List of Lists 3. SCOPE List of Lists Specific is a compiled list of Federal Hazardous Substances and their respective Reportable Quantities cross referenced to the Michigan Polluting Materials List and its respective Threshold Reporting Quantities. See Appendix IV This standard applies to spills/releases, as defined in Section 2.1, which occur anywhere on the site premises. This standard is applicable to all personnel working at the site. 4. PROCEDURE 4.1. General Any person on-site witnessing a spill or release of a substance shall notify appropriate personnel within the unit who will ensure that immediate steps are taken to control and contain the spill or release. Using the guideline presented in Section 4.2, unit personnel will then determine if it is necessary to notify the OH- MI-CAN Hub. For spill/releases, which occur after hours, the Site On Call Schedule should be referred to for the OH-MI-CAN HUB on call listing. The OH-MI-CAN HUB is responsible for notifying the appropriate regulatory agencies if the spill/release is determined to be an externally reportable event as defined in Section 4.5.

3 Procedure No.: WYN Page: 3 of Internally Reportable The spill and/or release must be reported internally if: It results in a release to the environment (i.e., air, land, surface water) It does not result in a release to the environment (i.e., is contained) refer to the flow chart on Page 3 of Appendix 1 for instructions on determining when a contained release of material needs to be reported internally there is a known or suspected violation of a permit (i.e., air, NPDES, POTW) condition the material is a hazardous waste, or it becomes a hazardous waste as a result of cleanup/recovery the material is a petroleum based product (i.e., gasoline, used oil, fuel oil). Note: Whenever there is a question as to whether a spill/release must be reported internally to the OH-MI-CAN HUB, the OH-MI-CAN HUB should be contacted ( ) For internal purposes follow the procedure outlined in Appendix 1, the following information is to be reported to the OH-MI-CAN HUB by telephone immediately after determining that a spill/release has occurred: (This internal procedure should be posted in control rooms and or other common areas for easy reference) The identity of the material CAS # (if applicable) The date/time of the spill/release The amount spilled The portion that was lost to environment (i.e., land, water or air)

4 Procedure No.: WYN Page: 4 of Externally Reportable (See Appendix II for reporting hierarchy) The following types of spills or releases must be reported externally: CERCLA Hazardous Substances and EPCRA Extremely Hazardous Substances - Spills/releases of these substances must be reported if the substance was spilled and/or released to the environment and the amount spilled and/or released to the environment has exceeded the respective "reportable quantity" (RQ) within a 24- hour period. In order for a material to be considered a spill or release to the environment, it must be a loss to ambient air or to a non-contained area such as unprotected land surface, ground water or surface water Michigan Polluting Materials, Oil and Salt - For Michigan Polluting Materials, Oil and Salt, quantities lost to ground water or surface water in excess of the Threshold Reporting Quantity must be reported to the Michigan Department of Environmental Quality Environmental Assistance Division Hazardous Waste - Spills and/or releases which result in implementation of the Site Integrated Contingency Plan or a release to the environment in excess of the RQ must be reported externally Excess Air Emissions - Releases in excess or violation of conditions specified in an installation permit must be reported externally NPDES Permit Violations Any unusual characteristics of the discharge such as unnatural turbidity, color, oil film, floating solids, foams, settleable solids or deposits or any discharge that may endanger human health or the environment Excursions in excess of any of the daily maximum effluent limitations in the site's NPDES permit Any spill or loss of product, by-product, intermediates, oils, solvents, waste material or other polluting substances occurring to surface or ground waters of the state.

5 Procedure No.: WYN Page: 5 of POTW Permit Violations Excursions of permit discharge limitations Any spill, which may cause increased pollution of normal industrial and/or sanitary wastewater; and major spills, which might affect storm sewers or open waterways Any "Slug" discharge, which is defined as a non-routine batch discharge, to the County sewer system. This slug could be at a flow rate and/or pollutant concentration, which will cause interference with the POTW or a pass through The OH-MI-CAN HUB shall make all verbal and written notifications to the appropriate regulatory agency(ies). In addition, the OH-MI-CAN HUB shall notify the EH&S Environmental Center of Expertise (CoE), and the appropriate Business Group VP if a spill or release is reportable to any government agency. 5. RESPONSIBILITES 5.1. OH-MI-CAN Hub Personnel In the event of a spill or release requiring reporting to a governmental agency OH-MI-CAN Hub personnel shall do the following: Take the initial notification and inform appropriate levels of management of the situation Coordinate any and all agency notifications Notify the Site Emergency Coordinator or Alternate Coordinator if necessary Coordinate flow of information until an incident command or other communications mechanism can be established Operating, Laboratory or Other Services Personnel Make initial notification to the On-call system ( ) Coordinate emergency procedures within the operating unit.

6 Procedure No.: WYN Page: 6 of Notify appropriate Business or other Operating Unit contacts of the incident Unit Manager Coordinate notification through the Business Group. 6. REFERENCED DOCUMENTS Appendix I Internal Procedures for Reporting Spills/Releases and Serious Injuries Appendix II Reporting Hierarchy External Spill/Release Reporting Guidelines Appendix III Reportable Quantities for Slug Discharges to the POTW Appendix IV List of Lists WYN Management of Chemical Wastes State of Michigan Part 5 Rules Spillage of Oil and Polluting Materials