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PERMFILE65789
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PERMFILE65789
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Last modified
8/24/2016 11:11:48 PM
Creation date
11/20/2007 9:02:51 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M1999002
IBM Index Class Name
Permit File
Doc Date
4/26/1999
Doc Name
PRELIMINARY RESPONSE PLAN
Media Type
D
Archive
No
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<br /> <br />community right-to-know reporting (Sections 311 and 312) <br />toxic chemical release reporting (Section 313) <br />Under the emergency planning sections of EPCRA, facilities must identify whether <br />there are Extremely Hazardous Substances (EHSs) present on site. A list of EHSs is <br />provided in 40CFR Part 355 and also in Appendix F of this Response Plan. For each <br />EHS there is a threshold planning quantity (TPQ). If facilities have greater than a TPQ <br />of an EHS present on site, they must notify the Local Emergency Planning Committee <br />(LEPC). Upon review of existing information for the Yankee Gulch Project, this EPCRA <br />requirement will apply only to sulfuric acid. The TPQ for sulfuric acid is 1,000 pounds, <br />which equates to about 65 gallons (assuming a density of 15.35 pounds per gallon). <br />American Soda plans to store approximately two 55-gallon drums (110 gallons) of <br />sulfuric acid at the Parachute Site. Another EHS that could be present at both sites is <br />cyclohexylamine. It is a minor ingredient in one of the boiler feed water treatment <br />chemicals. cyclohexylamine will not be present in levels above the TPQ, which is <br />10,000 pounds. An EHS review will be performed again prior to startup. <br />If a regulated chemical is released into the environment at a level greater than the <br />Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)- <br />defined Reportable Quantity (RQ), the facility must notify the appropriate regulatory <br />agencies as required by EPCRAs emergency notification section. The list in Appendix F <br />also contains RQ values. Therefore, if American Soda has a sulfuric acid spill of greater <br />than the RQ of 65 gallons (which is also the TPQ), notification must be made to <br />applicable regulatory agencies. The RQ of cyclohexylamine is 1 pound (which is much <br />less than the TPQ), which equates to 4,055 gallons of the boiler feed water treatment <br />chemical. Since only two 280-gallon totes (560 gallons) of the chemical will be on site, <br />the RQ cannot be exceeded. Several components of unleaded gasoline and diesel fuel <br />also have regulated RQs. Releases of these chemicals above the RQ would also be <br />reportable. <br />Under Section 311, facilities must provide either a list of OSHA Hazardous Chemicals <br />or copies of Hazardous Chemical MSDSs to the LEPC. Under Section 312, facilities <br />must complete annual inventory reports (Title III, Tier I or Tier fI reports) that identify <br />OSHA hazardous chemical storage quantities, conditions, and locations. The reporting <br />threshold for the inventory report is 500 pounds for EHSs and 10,000 pounds for other <br />OSHA hazardous chemicals. These are the right-to-know requirements of EPCRA. <br />America Soda will submit their OSHA hazardous chemical list or copies of MSDSs to <br />the LEPC for each site prior to startup. American Soda will be required to file the Tier I <br />or Tier I[ report for at least sulfuric acid, sodium carbonate, and sodium bicarbonate. <br />Reports are due each March 1 for the previous calendar year. Amore comprehensive <br />review of material storage information will be performed prior to startup. <br />The LEPC contacts for each site are: <br />9 <br />Preliminarv Response Plan <br />Yankee Gulch Sodwm Minerals Project <br />American Suda, L.L.P. <br />
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