Geismar Site Reviewed: 9/27/16 Effective: 9/27/16 Supersedes: 9/29/14 Preparer: Owner: Approver: EHS Team Member EHS Team Leader LA Hub Director EHS

Transcription

1 Procedure No.: EC04 Page: 1 of 12 RECORD OF REVISIONS Date Revision Number Details of Change 09/03 1 Volatile Organic Compound (2.13) definition was added. LDEQ phone numbers were updated. Title V Excursion was added to the Release Notification Form. Revised RQ Table to reflect the LDEQ Emergency Rule that reduces the reportable quantity (RQ) of a number of volatile organic compounds (VOCs) to 100 pounds; Assigned 5000 lbs RQ for the combined emission of VOCs and 100 lbs RQ to the combined emission of highly reactive VOCs. Appendix D has been revised to include the Plant Name, Permit Number and Date Issued and expired permits were deleted. 12/08/03 2 Revised Preparer and Owner in the header to reflect appropriate Environmental Engineer 08/01/04 3 Revised Preparer, Owner, and Approver. Included exempt materials under Section F. Revised order of after hours internal contact. Revised order of agency contact. Updated contact phone number of APSO. 12/19/08 4 Updated hazardous waste spill from RCRA permitted tank procedures. 12/16/10 5 Removed outdated attachments 9/29/14 6 Updated personnel titles; updated incident notification options; clarifications regarding sequence of internal and agency notifications. 8/4/16 7 Review and updates; additional clarifications regarding agency notifications; update references from NTU to NCU

2 Procedure No.: EC04 Page: 2 of PURPOSE The environmental release reporting procedures for the BASF Geismar Site (the Site) are included herein to assure timely reporting to regulatory agencies and to maintain communication on site as necessary. 2. DEFINITIONS 2.1 Adjusted Reportable Quantity For mixtures that contain one or more regulated chemicals, the RQ is adjusted to account for the percent by weight of that regulated chemical in the mixture. For example, if a solution contained 50 percent by weight sodium hydroxide and the minimum site RQ is 1000 pounds, then the adjusted RQ would be 1000/0.5 or 2000 pounds. Therefore, 2000 pounds would have to be spilled to equal the RQ. 2.2 Emergency Condition An Emergency Condition is defined as any condition that could reasonably be expected to endanger the health and safety of the public, cause significant adverse impact to the land, water, or air environment, or cause severe damage to property beyond the Site s boundary. 2.3 Environment Environment is defined as the "navigable waters... any other surface water, groundwater, drinking water supply, land surface or subsurface strata, or ambient air". 2.4 Flammable Gas A Flammable Gas is any material which is a gas at 20 C (68 F) or less and kpa (14.7 psi) of pressure, which is ignitable at kpa (14.7 psi) when in a mixture of 13 percent or less by volume with air; or has a flammable range at kpa (14.7 psi) with air of at least 12 percent regardless of the lower limit. (Reference 49 CFR )

3 Procedure No.: EC04 Page: 3 of Flammable Liquid A Flammable Liquid is a liquid having a flash point of not more than 60.5 C (141 F), or any material in a liquid phase with a flash point at or above 37.8 C (100 F) that is intentionally heated and offered for transportation or transported at or above its flash point in a bulk packaging, with the following exceptions: Any liquid meeting the definition of a compressed gas, either flammable or nonflammable; any mixture having one or more components with a flash point of 60.5 C (141 F) or higher, that make up at least 99 percent of the total volume of the mixture, if the mixture is not offered for transportation or transported at or above its flash point; any liquid with a flash point greater than 35 deg.c (95 deg.f) which does not sustain combustion; any liquid with a flash point greater than 35 C (95 F) and with a fire point greater than 100 C (212 F) according to ISO 2592; and any liquid with a flash point greater than 35 C (95 F) which is in a watermiscible solution with a water content of more than 90 percent by mass. (Reference 49 CFR ) 2.6 Internal Spill Quantity (ISQ) The Internal Spill Quantity or ISQ applies to any chemical or waste on-site and is defined as 10 percent of the Minimum Geismar Site Reportable Quantity or 0.5 pound if the reportable quantity is 1 pound. An ISQ must be reported to Security immediately. The release event is logged and tracked by the EHS On Call (OC) over a rolling 24-hour time period. 2.7 Minimum Geismar Site Reportable Quantity The Minimum Geismar Site Reportable Quantity is the smallest RQ as determined by the comparison of all applicable federal and state release regulations. 2.8 Multiple Releases Multiple Releases are releases of the same chemical or waste that occur at different times within a rolling 24-hour time period. A multiple release scenario may require notification if the total amount released of the same chemical or waste exceeds the Minimum Geismar Site Reportable Quantity within a 24-hour time period.

4 Procedure No.: EC04 Page: 4 of Non-Flammable Compressed Gas A Non-Flammable, nonpoisonous Compressed Gas is any material (or mixture) which exerts in the packaging an absolute pressure of 280 kpa (41 psia) or greater at 20 C (68 F), and is not flammable. (Reference 49 CFR ) 2.10 Normal Confinement or Containment Normal Confinement or Containment is considered to be a vessel, pipe, concrete area, or other artificial means of capture that has prevented a released chemical or waste from entering the environment Release or Unauthorized Discharge A Release or Unauthorized Discharge is defined as a continuous, intermittent, or one-time discharge, whether accidental or intentional that leads to spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing of any hazardous substance or other pollutant into or onto any land, air, water, or groundwater Reportable Quantity (RQ) A Reportable Quantity or RQ is the minimum dry weight amount for a regulated chemical or waste that has been established by a regulatory agency that requires notification to the regulatory agency Volatile Organic Compound (VOC) 2. SCOPE Any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate, which participates in atmospheric photochemical reactions. These procedures apply to a chemical release from the time of its discovery to submittal of the written report to the agencies. The responsibilities of Operations, Security, and EHS personnel are also included.

5 Procedure No.: EC04 Page: 5 of PROCEDURE The Site goal is to initiate the required regulatory reporting as soon as possible from the time of discovery of the release, and no later than 15 minutes from constructive knowledge that a release is reportable. The difference between constructive knowledge and discovery is the time allotted for analysis, calculation or time needed by personnel to access communications to make the call. 4.1 Environmental Releases Requiring Verbal Notification Regulatory Agency Reportable Releases A verbal report to the regulatory agency (or agencies) is required when any of the following conditions exist: A. Emergency Condition The Louisiana State Police HAZMAT unit requires notification of all emergency conditions. The determination of an emergency condition is made by Operations personnel. B. Exceedance of the Site Minimum RQ When the minimum RQ for a listed chemical or waste is exceeded within a rolling 24-hour period, the regulatory agency (or agencies) is contacted via telephone. Verbal notification is made if the material was released from normal confinement to the environment or had the potential of being released and exceeding the RQ. C. Exceedance of an Operating Permit Parameter Any release event that is related to an exceedance of a permit parameter requires agency notification. Such events include an exceedance of mass limits, concentration limits, or equipment operational performance parameters listed in any federal or state air, water, or waste permit. D. Other Regulatory Violations Any release that results in non-compliance with any federal or state directive, regulation, or law requires agency notification. The regulations include DEQ Air Quality Regulations, Water Discharge Regulations, Hazardous Waste Regulations, and any others that may pertain to a release.

6 Procedure No.: EC04 Page: 6 of 12 E. Discharge to the Mississippi River or New River Any release above the RQ that is discharged into or which impacts the Mississippi River and/or New River (via Smith Bayou) requires agency reporting. This notification is required to warn downstream drinking water intake facilities and other downstream users for public safety. F. Releases of (M)SDS Chemicals with No Assigned RQ The Site maintains a (Material) Safety Data Sheet [(M)SDS] for many chemicals or wastes that do not have an assigned RQ by chemical name and are not currently listed by the EPA or the state as an extremely hazardous substance (EHS), a CERCLA hazardous substance, or a DOT hazardous substance. The State Police assigned RQs for these miscellaneous materials including 5,000 pounds for any material having an MSDS, 1000 for pounds for compressed or refrigerated flammable gases, 100 pounds for flammable liquids and 1,000 pounds for all other liquids. Compressed air, compressed nitrogen, and water vapor are not reportable Internal Reportable Releases An internal verbal report is required when a release event results in the following: 4.2 Notification Process A. Exceedance of the Internal Spill Quantity (ISQ) A release to the environment that exceeds the ISQ for a specific chemical requires notification to Security, who in turn will contact the EHS OC. EHS tracks release incidence rates for the Site in order to address preventative measures to reduce RQ releases. B. Verbal Reporting to Regulatory Agencies Releases resulting in a notification to the agencies require internal notification to the EHS OC Notification of Security The following procedures are to be followed in notifying Security of a release: The Release Notification Form is to be used to record relevant release data prior to making a verbal notification by Operations personnel to Security.

7 Procedure No.: EC04 Page: 7 of 12 Security will obtain as much information as possible from the responsible Operations personnel at the time of the incident. Security will complete the Release Notification Form as Operations provides the verbal notification. If any of the information cannot be quickly obtained within 5 to 10 minutes, then Operations must report the release to Security and provide whatever information is available. The regulatory agencies will be notified that additional information will be provided as soon as it becomes available. An estimate of the release quantity should be made, if possible, before notifying Security. In order to provide information indicative of the confidence of the estimate, displayed decimal places should be representative of this confidence. In all cases no more than 15 minutes from constructive knowledge of an RQ release by a unit should elapse before notifying Security for agency notification. In all cases no more than 30 minutes from discovery of any release, even if constructive knowledge cannot be determined that a release is reportable, to allow for notification of all agencies. Any release with offsite impact should immediately be called to Security to allow a GAMA alert. For example, if a release is calculated to be pounds, the estimator should consider what the degree of confidence is in the estimate. In most cases, 25 pounds would be reported. In other cases, the estimate may be further rounded, i.e., 30 pounds. Rounding up should always be the rule to be more conservative. Do not imply a degree of accuracy that you cannot substantiate with "good engineering judgment". Remember, a regulator will always favor an overestimation of a release rather than making an underestimation without applying "good engineering judgment" Notification of Regulatory Agencies For RQ releases that have offsite impact (including any RQ to the air), the EHS OC will, after being notified by Security, contact the regulatory agencies in the following order: Contact Regulatory Agency Ascension Parish Sheriff (LEPC) Louisiana State Police (LSP, DEQ, DOT) National Response Center (Coast Guard, EPA, Homeland Security) LDEQ (notification not required if LSP is notified)

8 Procedure No.: EC04 Page: 8 of 12 For RQ releases that do not have offsite impact (confined to site soil, ditches, etc.), the EHS OC will, after being notified by Security, contact the regulatory agencies in the following order: Contact Regulatory Agency National Response Center (Coast Guard, EPA, Homeland Security) LDEQ (within 24 hours) Note also that offsite impact that could impact neighboring plants, businesses or residences will also trigger a GAMA alert Site EHS Notification (During and After Business Hours) Security must be notified within 15 minutes of constructive knowledge of a RQ. Security will contact EHS OC, who shall make the regulatory agency notifications. In the event that Security is unable to contact the OC within a reasonable amount of time, Security shall make the agency notifications to avoid exceeding the reporting requirement. 4.3 Regulations and Permit Exceedance Reporting Requirements There are media specific notification requirements and guidelines for an unauthorized discharge (release) to the air, land, or water with regard to regulatory compliance issues or permit exceedances. The first notifications are to be made to the EHS OC and the responsible EHS personnel will handle the required 24- hour or immediate reports as needed. EHS OC will have the option to report a nonemergency incident either verbally (by phone) or online. Online reporting is the preferred method since this can be done 24/7, DEQ is the only regulatory agency notified, and a copy of the incident report form can be printed for documentation. Verbal Note: If the incident occurs between 9:00 a.m. and 3:00 p.m. on working days call (225) instead of the phone number provided on Release Notification Form. Online Online notification can be made in lieu of a verbal notification. Access to the DEQ Online Incident Report Form can be made through

9 Procedure No.: EC04 Page: 9 of A verbal or online report to the DEQ within 2 working days is required if: A. Air There has been a violation of an Air Quality regulation, or An air permit limit has been exceeded. Note: Any exceedance of an air permit in an RQ amount must be reported as an RQ A verbal or online report to the DEQ within 24 hours is required if: A. Air There has been an atmospheric release of a toxic air pollutant in excess of that allowed by permit, compliance schedule, or variance. Note: Any exceedance of an air permit in an RQ amount must be reported as an RQ. B. Water There has been a violation of a Water Quality regulation, or the release results in impairment of designated water uses, or a violation of the Site s water permit has occurred, or an exceedance of effluent limitations by a factor of two, except ph, has occurred. C. Land a violation of the Site s RCRA permits has occurred. D. Hazardous Waste a release results in the discharge of hazardous waste or reusable material from any site or facility which spills, mixes, leaches, migrates, or otherwise moves in, into, within, or on any subsurface or groundwater stratum either on-site or off-site. a release from a permitted hazardous waste tank system to the environment must be reported to DEQ within 24 hours of detection with the following exceptions: less than one pound was spilled; and immediately contained and cleaned up. Within 30 days of release a report must be filed with DEQ containing the information required by LAC 33:V.1913.D.3.

10 Procedure No.: EC04 Page: 10 of Required Written Reports Groundwater a release results in the discharge of hazardous waste or reusable material from any site or facility which spills, mixes, leaches, migrates, or otherwise moves in, into, within, or on any subsurface or groundwater stratum either on-site or off-site Operations Procedure Two written notifications are required from Operations following a release: Within five working days after the release, Operations must initiate an Accident/Incident Report in the Site s Incident Communication System. As soon as the estimate of any spill or release is determined. Forward the calculation to the EHS Department Security Procedure For releases that occur after normal business hours, Security acts as the primary contact, Security will notify the EHS OC that a release has occurred and that it has been recorded on a Release Notification Form. This will be done by 8:00 a.m. on the first working day following the release EHS Procedure At the time of the release incident, the NCU EHS team will prepare the written report to the agencies as required within five working days. Responsible Operations management will supply necessary supporting information as requested and will be given an opportunity to review the draft written report and provide input to the report prior to its submission to the agencies. 4.5 Third Party Environmental Releases Third Party Releases Occurring on BASF Property If a release of a material at the Site that does not belong to BASF occurs during or after business hours, the EHS OC is to be notified immediately. A. Obvious Reportable Quantity Either EHS or Security will notify the owner of the material of the release. If the release is obviously an RQ and the owner of the material cannot be reached, then the EHS OC will make an

11 Procedure No.: EC04 Page: 11 of 12 immediate courtesy notification to the Sheriff, State Police, and the other agencies. Either Security or EHS should continue to contact the owner of the materials spilled. It will be the responsibility of the third party contact to make all official regulatory agency notifications. BASF will not assume responsibility for third party releases on its property. B. Unknown Quantity In the event the release quantity is uncertain and it is not apparent whether an RQ has occurred or not, either Security or EHS will contact the responsible third party for reporting, if they deem it necessary. Annex 2 Notifications Document, located in the Geismar Site Integrated Contingency Plan, includes a listing of the off-site facilities (pipeline) that could potentially have a release affecting BASF on BASF property Releases Occurring from Off-Site Non-BASF Facilities Any release or suspected release from other off-site facilities not owned by BASF is not the reporting responsibility of BASF. Any such suspected release detected should be reported to the proper Site Operations Supervisory personnel. Site Security, Safety, and/or Industrial Hygiene groups will handle such occurrences as necessary. 4.6 BASF Internal Release Reporting Procedure Internal Reporting Requirements If there has been a release resulting in an emergency condition, offsite impact, or serious injury or other conditions as defined by Rapid Reporting requirements, the EHS OC must be notified. The EHS OC is to notify the EHS Hub Director, who will notify the Corporate Emergency Response Group and the Vice President & Site General Manager Notification by Site EHS A. The EHS Hub Director - The EHS Hub Director is to be notified of the incident. They are responsible for reviewing any medical injuries or notifying Communications of the need to manage handling press coverage for the event. B. The Site Manager - The Site Manager is to be notified by the Hub Director or EHS On Call within four hours of the incident. This notification is for information purposes only unless the release has an appreciable off-site impact or causes injury on-site.

12 Procedure No.: EC04 Page: 12 of 12 C. The Corporate Emergency Response Group - The Corporate Emergency Response Group, also known as Technical Resource and Chemical Emergency Response (TRACER Team) is to be notified only of releases that result in emergency conditions, off-site impact, or serious injury or as otherwise defined in the Rapid Reporting requirements. The LSP HAZMAT Unit should always be contacted in conjunction with the TRACER Team notification. The 24-hour Hotline Number for the TRACER Team is HELP. 4.7 Release Event Documentation Release Notification Forms The Release Notification Form is to be completed by Security Telephone Logs During telephone conversations with regulatory agencies, the reporting BASF representative (either the Security Sergeant or the EHS OC) should use the telephone log included. This log is intended to be filed with a print out of the Release Notification Form for the incident file record and should be sent to EHS the following morning after a release event Incident/Accident Investigation Report An Incident/Accident Communication Report should be initiated within 48 hours by the incident reporting Operations personnel. 5. RESPONSIBILITIES EHS OC The EHS OC Duty Roster is issued annually and may be periodically updated. The EHS on-call roster is maintained on the Geismar Site EHS Intranet Web Page. The EHS OC is normally on-call from Monday morning at 7:45 a.m. for seven days to the following Monday morning, except when the last day of duty precedes a BASF established holiday. In this case, duty is extended until the next BASF business day. If the EHS OC must travel or desires to be relieved early, it is his or her responsibility to locate a replacement, to notify Security of the change including the duration of the change and any change in the designated phone numbers.