RELEASE REPORTING OF A HAZARDOUS SUBSTANCE

The State Emergency Response Commission (SERC) finalized a set of eight (8) release reporting rules (3750-25-01, 3750-25-05; 3750-25-10; 3750-25-12, 3750-25-13; 3750-25-15; 3750-25-20; 3750-25-25) effective June 30, 1993. The purpose of this section is to make you aware of your reporting obligations in case of a discharge or release.

All verbal notifications made under these rules are to be reported to

• the Ohio EPA’s Emergency Response Section,
• Local Emergency Planning District(s) which may be affected, and
• the jurisdictional fire department(s).

Any owner or operator is required to report a release or discharge under 3750-06 of the Ohio Revised Code anytime there is a release or spill of a regulated chemical which exceeds its assigned Reportable Quantity (R!) and leaves the facility property line. The regulated substances subject to the release reporting requirements are referenced below:

Materials Subject to Release Reporting

1. Extremely Hazardous Substances 40 CFR; Part 355; Appendix A and B;
2. CERCLA Hazardous Substances 40 CFR Part 302; Table 302.4; and
3. Oil (definition includes without limitation to, gasoline, petroleum, fuel oil, sludge, oil refuse and oil mixed with wastes other than dredged spoil)
    
• The Reportable Quantity (RQ) for the discharge of oil including crude oil into or upon navigable waters is an amount which causes a visible film or sheen upon the surface of the water;
• The RQ for the release of oil into the environment, excluding navigable waters, is an amount of 25 gallons or more; and
• The RQ for the release of crude oil from an oil and gas extraction storage facility into the environment, excluding navigable waters, is 210 gallons.

Verbal Notification Requirement

The verbal notification to the fire department, LEPC and Ohio EPA shall be made within 30 minutes of knowledge of the release, unless notification within that timeframe is impractical due to uncertain circumstances. In addition, calls to The National Response Center (NRC) shall be made for those reportable quantity releases involving CERCLA hazardous substances or oil to navigable waters as soon as possible. The National Response Center (NRC) 24-hour number if 1-800-424-8802. The release notification for 24-hour reporting of emergencies is:

In Ohio call: 1-800-282-9378

Out of State
or
 if the 800 number above does not work,
call: 614-224-0946

Be prepared to relay as much of the information listed below as is known or can be estimated at the time of reporting. Please remember this is an initial report and estimates can be corrected in your
follow-up emergency notice report.

• Name and phone number of the person to contact for further information
• Location and source(s) of the release or discharge;
• Chemical name or identify of any substance(s) involved in the release or discharge;
• If the substance an extremely hazardous substance;
• Estimate of the quantity (gallons or pounds) discharged into the environment;
• Time and duration of the release or discharge;
• The environmental medium or media into which the substance was released or discharged;
• Potential health effects associated with the release or discharge of the substance; and
• Report precautions taken, including evacuation, remediation or other proposed response actions.

This information is required under ORC, Section 3750.06(C) and OAC, Rule 3750-25-25(A)(1).

Written Follow-up Requirements

After the release or discharge a written follow-up emergency notice must be submitted within 30 days to the Ohio EPA, Emergency Response Section and the local planning committee of the planning
district(s) in which the release or discharge occurred. If the the release was from a vessel, then the report is sent only to the SERC. This follow-up emergency notice is your company’s opportunity to explain in its own words the circumstances and actions relating to the release of pollutants to the environment. Your written emergency notice should follow the question sequence as indicated in the attached document. If any of the questions are not applicable to your incident, indicate N/A (Not Applicable) for that item.

Written Follow-up Requirements - .pdf Document

This information is required pursuant to ORC, Section 3750.06(D) and OAC, Rule 3750-25-25(A)(2).

The written emergency notice must be submitted
within 30 days of the release or discharge to:

Ohio EPA
Lazarus Government Center
Attention: ER Records Management
50 West Town Street, Suite 700
P. O. Box 1049
Columbus, Ohio 43215-1049

AND

The appropriate County LEPC Emergency Coordinator

The statute provides that if significant additional information regarding the mandatory or voluntary information submitted becomes known during the period one (1) year after the release or discharge, the owner or operator shall submit to the LEPC and the Ohio EPA an updated written notice within three (3) days after learning of the additional information.

If this is the second oil spill release at this location within a 12-month period or a release of over 1,000 gallons which has reached water, then you must submit a copy of your Spill Prevention Control and Countermeasure Plan (SPCC) to the U.S. EPA Regional Administrator and to Ohio EPA within 60 days from the time of the discharge as required by 40 CFR 112.4. Your SPCC plan may be submitted with your response to the 30-day written follow-up report. You may obtain SPCC information by calling
313-676-6500 or the Ohio EPA at 614-644-3063.