Issued: June 1990
Accidental
Release
Information
Program
Implementation Guide
US Environmental Protection Agency
Chemical Emergency Prepared! ess and Prevention OfTice
Washington. DC 20460
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Issued: June 1990
Accidental
Release
Information
Program
Implementation Guide
US Environmental Protection Agency
Chemical Emergency Preparedness and Prevention Office
Washington, DC 20460
-------
TABLE OF CONTENTS
I. INTRODUCTION 1
A. Purpose of this Guidebook
B. Why was ARIP Developed?
C. What is ARIP?
D. Uses of ARIP Information
II. ARIP PROCESS OVERVIEW 3
A. ARIP Participants
B. Criteria for Selecting Releases
C. The ARIP Survey Process
III. REGIONAL RESPONSIBILITIES 8
A. Receipt of NRC Release Report Packet
B. Maintaining an ARIP Release Record System
C. Distributing the ARIP Questionnaire to Facilities
D. Coordinating within the Regional Office
E. Coordinating with State and Local Agencies
F. Answering Facility Questions
G. Processing Completed Questionnaires
H. Forwarding the Questionnaire to Headquarters
IV. FOLLOW-UP ACTIVITIES 12
EXHIBIT 1: ARIP SURVEY PARTICIPANTS
EXHIBIT 2: THE ARIP SURVEY PROCESS
EXHIBIT 3: CHECKLIST AND ARIP TRACKING FORM FOR REGIONAL ARIP COORDINATOR
ATTACHMENTS:
A. ARIP QUESTIONNAIRE
B. SAMPLE NRC RELEASE REPORT
C. TRIGGER CLASSIFICATION NUMBERS
D. FREQUENCY COUNT OF NRC RELEASE REPORTS
E. REGIONAL NRC REPORT SUMMARY SHEET
F. REPEAT RELEASE HISTORY SUMMARY SHEET
G. STARS/SCAP REPORT
H. INITIAL FACILITY NOTIFICATION
I. FOLLOW-UP FACILITY NOTIFICATION
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I. INTRODUCTION
A. Purpose of this Guidebook
This guidebook is designed to describe the purpose and specific
responsibilities to implement the Accidental Release Information Program
(ARIP). The steps detailed in this guidebook will help in the collection of
accidental release information and promote the use of this information by
headquarters, the regions, and others.
B. Why was ARIP Developed?
In recent years, industrial accidents and the potential threats posed to
local communities by accidental chemical releases have attracted more public
attention. In 1985, EPA created an intra-agency task-force to conduct an
analysis of federal release prevention and response initiatives. The task
force concluded that EPA needed to establish a database on accidental releases
to support guidance, training, and other prevention activities. The ARIP
database thus has an emphasis on prevention (such as facility management
practices, hazard assessments, and training) unique among databases concerned
with chemical accidents and releases, such as the National Response Center
(NRC) database and the Acute Hazardous Events Database. In addition, no other
database is designed to document, in detail, all of the causal factors
contributing to an accident, and the steps taken to prevent a re-occurrence.
The ARIP initiative also serves to promote industry examination of health and
safety practices, and the introduction of more effective techniques and
technologies.
C. What is ARIP?
EPA's Chemical Emergency Preparedness and Prevention (CEPP) office
instituted ARIP to collect information on the causes and consequences of
accidental releases, release prevention procedures and equipment, and release
mitigation techniques. In cooperation with the regional offices, EPA
headquarters designed the ARIP questionnaire (see Attachment A) to serve as
the instrument for collecting this information. The information is assembled
from facilities selected by EPA under authority granted by section 104(b)(l)
and 104(.e) of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA or "Superfund") and other statutory provisions.
The survey allows both multiple choice and open-ended responses, and its
forty-two questions are separated into three sections:
• A facility profile, which provides the location and other
background information on the facility to integrate ARIP with
other EPA information collection efforts;
• A hazardous substance release profile, which provides a detailed
description of the circumstances and causes of the release; and
• A clean-up and prevention profile, which focuses on the facility's
prevention and preparedness practices prior to the release and the
changes implemented in response to the release incident.
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EPA conducted a pilot test of the ARIP survey in early 1987 before
instituting the program on a national basis later that year. In response to
the experience of processing over 350 questionnaires during the initial phase
of ARIP, the questionnaire and the criteria for selecting facilities were
revised in the fall of 1988. The survey questions were refined and expanded
to emphasize prevention and improve accuracy, while the selection criteria
were modified to target facilities better. The questionnaire has been
approved by the Office of Management and Budget through January 31, 1991 (OMB
#2050-0065), and the process will then require renewal.
D. Uses of the ARIP Information
ARIP activities support a range of chemical accident prevention and
preparedness efforts involving industry, local and state government, and EPA
regions and headquarters.
At the headquarters level. ARIP will continue to serve as a national
database on accidental releases, detailing patterns of the underlying causes,
industry response, . and prevention practices. As the ARIP database grows, the
information will help EPA to improve prevention program activities by
identifying: (1) the types of facilities most likely to experience an
accidental release, (2) the chemicals most frequently released, (3) the
facility techniques and engineering practices used prior to a release, and (4)
the techniques and practices instituted to prevent a re-occurrence. ARIP data
have already been used to augment the study of prevention practices mandated
by Congress under section 305(b) of Title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA).
The results of headquarters ARIP analyses also provide the basis for the
development of guidance materials and outreach programs. Headquarters has
prepared an ARIP Technical Assistance Bulletin to assist State Emergency
Response Commissions (SERCs) and Local Emergency Planning Committees (LEPCs)
in preparing emergency response plans and in conducting safety audits and
inspections. Dissemination of this bulletin provides local planners with data
and direction for their contact with facilities and thus support the informed
dialogue essential for developing emergency plans. In addition, headquarters
is examining release patterns at facilities with the regional offices and will
issue letters, as needed, to the chief executive officers of facilities
experiencing serious or potentially serious releases.
At the regional level. ARIP can assist in the monitoring of industry
compliance with SARA reporting requirements, Resource Conservation and
Recovery Act-permitted emissions and waste disposal, and sound engineering
practices. ARIP survey information is used to target Chemical Safety Audits,
and recent investigations of major releases by regional personnel were
supported by ARIP survey information on facility operations and management
practices. Coordination with SERCs and LEPCs using ARIP information will help
to promote information transfer on special regional release concerns and the
development of emergency response plans.
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Finally, at the facility level, the ARIP questionnaire serves as a
catalyst for industry to re-examine its chemical safety practices and initiate
engineering and managerial steps related to accident preparedness and
prevention. For example, EPA can use ARIP to identify patterns of serious
releases from single facilities and send facility CEOs or corporate management
a letter describing any serious or potentially threatening releases. These
letters are intended to promote greater management awareness of the importance
of prevention efforts.
II. ARIP PROCESS OVERVIEW
A. ARIP Participants
The successful development of the ARIP database depends upon the
effective involvement of six participants in the data collection process.
These participants and a brief description of their roles are:
• The National Response Center (NRG) receives notifications of
accidental releases from facilities as required by CERCLA section
103(a) and develops a database of release report information.
• The Transportation Systems Center (TSC) of the Department of
Transportation maintains the NRC database, screens NRC reports for
releases that meet certain ARIP criteria, and provides these
reports to EPA headquarters for distribution to the regions.
• Support contractor staff check the accuracy and quality of the
selected NRC reports, code and computerize the completed ARIP
surveys, and perform analyses and generate reports based on the
ARIP data collection.
• Facility Representatives notify the NRC of accidental releases and
complete the ARIP questionnaire at the request of the region.
• The EPA Headquarters Coordinator directs the ARIP program, serves
as the information clearinghouse for logistics questions from all
ARIP participants, approves significant program changes, and
supervises data analysis.
• EPA Regional Coordinators receive NRC reports from headquarters,
verify the release with the facility, maintain the flow of ARIP
questionnaires between EPA and the facilities, support dialogue on
prevention issues between SERCs, LEPCs, and facilities, and
coordinate ARIP activities with state and local agencies.
Regional Coordinators may also initiate an ARIP survey of a
particular release event in their region without, or prior to,
receipt of NRC release reports.
Exhibit 1 illustrates the participants and interactions in the ARIP process.
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| ACME Chemicals I
FACILITIES
Completed
ARIP Survey
EXHIBIT 1
ARIP SURVEY PARTICIPANTS
Notify NRC of Release
NATIONAL
RESPONSE
CENTER
(Release Reports
Database)
EPA-
HQ
On-going
EPA - REGIONS
ARIP
Completed
ARIP Surveys
Coordinate with States,
SERCs, LEPCs, etc.
TRANSPORTATION
SYSTEMS CENTER
(Review NRC Reports-
Select ARIP Releases)
NRC
Release
Reports
ARIP SURVEY
DATABASE
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B. Criteria for Selecting Releases
EPA headquarters establishes the criteria by which release reports are
selected from the NRC notifications. The release must be from a fixed
facility and involve a hazardous substance as defined by CERCLA section
102.Furthermore, release incidents must satisfy one or more of the following
ARIP selection criteria (triggers):
• The quantity released was 1,000 pounds or more for a hazardous
substance with a CERCLA Reportable Quantity (RQ) of 1, 10, or 100
pounds, or the quantity released was 10,000 pounds or more for
hazardous substances with a CERCLA RQ of 1,000 or 5,000 pounds;
• The release resulted in a death or an injury;
• The release was one in a trend of frequent releases from the same
facility (only the fourth through tenth releases within a twelve
month period are surveyed); or
• The release involved a chemical listed by EPA as an extremely
hazardous substance (EHS) under SARA section 302.
The first criterion was designed to address the potential dangers of
large-scale releases, while the second trigger identifies releases that pose a
significant human health impact. EPA developed the third criterion to gather
information about patterns of multiple releases at a facility that could
indicate the possibility of an upcoming catastrophic release. (An ARIP
workgroup consisting of headquarters and regional staff decided to reduce the
scope of this criterion -- surveying only the fourth through the tenth release
- - to reduce the overall volume of NRC reports to the regions without
sacrificing valuable information on repeat releases.) The
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EXHIBIT 2
THE ARIP SURVEY PROCESS
Continued on next page
Screening NRC
Releases for those
that meet
ARIP Criteria
Assure Selection
Quality and Assign
Triggers to
NRC Reports
The National Response
Center (NRC) Records
Initial Release Report
Distribute NRC
Packet to
Each Region
Regions Rle and
Track NRC Packet
Information
• Facilities are required to
report to the NRC releases
of CERCLA hazardous
substances above the
chemical's RQ.
• Transportation Systems
Center (TSC) maintains
NRC database.
• Every two months, TSC
applies ARIP triggers to
select ARIP releases from
NRC database.
• Releases must be of a
hazardous substance at a
fixed facility and satisfy at
least one of the following:
-death/injury
- exceeds RQ multiple
- repeat release
- extremely hazardous
. substance
• HQ support contractor
verifies that each NRC report
satisfies a trigger, and assigns
the trigger number.
• HQ support contractor
generates statistical summaries
about the releases.
• HQ support contractor adds
NRC reports into tracking
database.
• HQ support contractor sorts
NRC Release Reports into
regional packets and sends
packets to HQ ARIP Coordinator.
• HQ ARIP Coordinator sends
NRC reports to each Regional
ARIP Coordinator.
• HQ ARIP Coordinator keeps
track of the number of NRC
releases issued to each region.
• Regions track ARIP releases
using the NRC Record
Identification number and the
date of the release.
Participants:
• TSC sends a list of reports
that meet ARIP criteria to
headquarters.
Facilities, NRC Staff
TSC
HQ, Support Contractor
HQ
Regions
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EXHIBIT 2
THE ARIP SURVEY PROCESS
(continued)
Regional Internal
and External
Coordination and
Release Verification
Distribute
Questionnaire
to Facilities
Process and Use
Questionnaire
Information
Follow Up and
Information
Exchange
Receive ARIP
Questionnaires
from Facilities
• Regions review release reports
for any reason to refrain from
sending an ARIP questionnaire
(e.g., enforcement actions
pending or other regional office
objections).
• Region coordinates with states
to eliminate interference with
with enforcement actions and
to maximize use of release
information.
• Region may want to contact
facility to verify release and to
notify of pending survey.
• Regions may elect to send a
survey to a facility for a
particular release in their region
without, or prior to, NRC release
reports.
• Regions send ARIP
questionnaire and cover letter
to facility.
• Regions send follow-up letter
if a questionnaire is not
returned within 30 days.
' Regions answer questions
from the facility and grant
time extensions. If warranted,
commence enforcement
action if ARIP questionnaire
if not completed.
• Regions log receipt of
returned questionnaire and
note NRC ID number on form.
• Regions must repond to
and resolve confidentiality
claims raised on
questionnaire information.
• Regions review completed
questionnaires, copy them
and forward them to HO.
• HQ codes the questionnaires
and enters data into ARIP
database.
• HQ performs analyses on the
data and generates reports
and bulletins for dissemination.
• Regions can use questionnaires
for enforcement actions, audits/
inspections, and aggregate
analyses.
• HQ distributes ARIP database
to regions on a per request basis
for regional use and analysis.
• Regions and HQ provide
feedback on survey process
and value of ARIP data.
• Regions coordinate and share
information with air/water/land
regional offices.
• Regions exchange ARIP
information with states and
local governments.
• HQ generates reports, bulletins,
and updates for technical
transfer.
• HQ and region alert facility
Chief Executive Officers
concerning particularly serious
or potentially threatening
releases.
Participants:
Regions
Regions
Regions, HQ
Regions, HQ
Regions, HQ
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one Co fifteen, which indicates the trigger or combination of triggers (e.g.,
EHS and Repeat Release) for which the release was selected (see Attachment C).
Each release falls into one of these fifteen classifications, so there is no
double counting. The contractor prepares a frequency count of the release
reports in each trigger category and region (see Attachment D). NRC release
report information is then added to a tracking database. The contractor sorts
the NRC release reports into packets for each region. Approximately 1,400 NRC
release reports will be selected to survey annually.
The Headquarters ARIP Coordinator distributes the packets to the
Regional Coordinators, who verify the release information and then issue
questionnaires to the specified facilities. Regional Coordinators ensure that
the facilities complete the survey, evaluate claims of confidential
information, and then forward groups of completed questionnaires to
headquarters at regular intervals -- it is recommended that the regions
maintain a tracking file on each ARIP survey that they receive. Headquarters
is responsible for entering questionnaire information into the ARIP database,
performing analyses upon the aggregated survey data, and making the results of
its analysis available to the regions and state and local agencies.
III. REGIONAL RESPONSIBILITIES
The active participation of the regions is key to the success of the
ARIP survey. The Regional ARIP Coordinator has the primary responsibility of
insuring that the flow of ARIP questionnaires from EPA to the facilities and
back to EPA is maintained. The following paragraphs outline in more detail
the specific duties of the Regional Coordinator in the ARIP survey process.
A. Receipt of NRC Release Report Packet
The ARIP Regional Coordinator receives a packet of NRC release reports
from the EPA Headquarters Coordinator. The packet will contain NRC release
reports that meet the RQ multiple, EHS, repeat release, or death and injury
criteria, as well as a cover sheet that indexes the reports by their Record
Identification Number (see Attachment E). Separate cover sheets will document
facilities with significant repeat release histories (see Attachment F) and
will be the primary source for identifying facilities with potential operating
problems.
B. Maintaining an ARIP Release Record System
The region should maintain a record of all relevant information and
correspondence concerning each NRC release report and the associated ARIP
questionnaire. This procedure is necessary for several purposes: to track
the general progress of the survey effort, to identify overdue questionnaires,
and to respond to specific inquiries from EPA headquarters, states, and the
facilities. Exhibit 3 is a suggested information checklist that can be
tailored to each regions needs. Information can be recorded either in hard-
copy or computerized files. The Emergency Response Notification System
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EXHIBIT 3
CHECKLIST AND ARIP TRACKING FORM
FOR REGIONAL ARIP COORDINATOR
NRC Record Identification # (ID):
Shipment #: for Release Period
Release Date:
1. NRC release report received from HQ
2. Create correspondence file
3. Enter release report into tracking system
4. Decision to issue ARIP survey to facility
(details in file as necessary, also note
in tracking system)
5. Contact facility to verify release,'
confirm address, and indicate survey is
forthcoming (note in tracking system)
6. Survey sent to facility
(note in tracking system)
7. Facility request for extension
(note in tracking system)
date done and initials
date done and initials
date done and initials
yes or no
date done and initials
date done and initials
date extension request received
8. Follow-up contact with facility for non-
completed surveys (note in tracking system)
9. Completed survey received from facility
(note in tracking system)
10. Review survey for completeness
11. Facility confidentiality claims
(note details in file)
12. Note NRC ID # on survey. Make copies for
distribution to HQ and others. File original.
13. Completed survey forwarded to HQ
(note in tracking system)
14. Regional follow-up activities:
new date requested
date done and initials
date received
date done and initials
yes or no
date done and initials
date done
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(ERNS), a computerized database of accidental releases available to the
regions, provides a convenient structure for entering and updating release
tracking information because much of the ARIP identifier information is
already contained in ERNS. Each region should develop its own system, one
which is best suited to its particular needs.
Regardless of the storage medium, each file should be identified by a
combination of the NRC Record Identification number (ID) and the date of the
release. When communicating with EPA headquarters about a specific release,
the region should use the Record Identification number; refer to the "Record
Identification(ID)" field specified on the release report (Attachment B). The
cover sheets supplied with the NRC packet are useful for referencing
releases.The release information contained in the tracking file can also
provide documentation of ARIP activity to simplify the response to STAR and
SCAP requests (see Attachment G).
C. Distributing the ARIP Questionnaire to Facilities
Before sending a survey questionnaire, the region should ensure that the
survey will not interfere with any other regional, state, or local enforcement
actions related to the release. If the region decides not to issue the ARIP
questionnaire to a specific facility, this decision should be indicated in the
tracking file. Reason(s) for the determination - improper trigger selection,
continuous release, pending enforcement action, or inadequate quantity
information - as well as the source of the decision should be included.
The region should establish specific procedures for distribution of the
ARIP questionnaire to facilities. The Regional Coordinator has the option, of
contacting the facility to verify the release, the address, and alerting the
facility that the survey will be forthcoming. The cover letter to the
facility should follow the content and style of the model in Attachment H: the
format of the letter covers certain legal requirements that cannot be changed.
EPA's legal authority to collect this information must be correctly
referenced. The primary authority is CERCLA section 104 (b)(l) and (e),
although other authorities such as' RCRA section 3007, Clean Water Act section
308(a), and Clean Air Act section 114(a) may be added or substituted if they
are more applicable (e.g., if the facility is a RCRA facility, then RCRA
section 3007 authority would be cited).
The cover letter should specify the details of the incident (e.g., the
date of the release, the chemical(s) involved, and the quantity spilled) and
indicate that the completed questionnaire is expected 30 days after receipt of
the letter. It is of particular importance to indicate that the facility can
claim any of its responses as confidential business information. The Regional
ARIP Coordinator may need to coordinate with other regional offices for the
proper signature on the cover letter, depending on the legal authorities used
to collect the survey information. Finally, although there can be no
modifications to the questionnaire because the form has received official OMB
approval, the region may request supplemental information pertaining to the
release.
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D. Coordinating within the Regional Office
Regional staff should coordinate ARIP activities with other regional
personnel before, during, and after the distribution of ARIP questionnaires to
facilities. By notifying regional SARA section 313 staff, as well as the
enforcement, air, and water offices prior to issuing the questionnaires,
program confusion and conflict can be avoided, and the questionnaire will not
disrupt other regional activities .(i.e., enforcement or sensitive situations).
In addition, some offices within the region may wish to request further
information from ARIP facilities. To facilitate such communication but avoid
unnecessary delays, the Regional Coordinator should consider sending out a
written notice simultaneously to all appropriate offices, explaining that
unless a response is given within the pre-determined time frame, the ARIP
questionnaire will be issued.
E. Coordinating with State and Local Agencies
Maintaining coordination with the states and communities in the region
is also important. The coordination approach can parallel the coordination
within the region, particularly in confirming, by way of a written notice,
that ARIP activities will not interfere with state and local enforcement or
other efforts. Regular communication will allow states the opportunity to
request that additional facilities be surveyed, to request that more detailed
information be supplied, or to .suggest additional uses for ARIP information.
F. Answering Facility Questions
The Regional Coordinator should expect to receive both general ARIP
questions and specific inquiries about completing the survey from facility
representatives. These requests will be aided by providing a telephone number
for inquiries from facilities to the regional office in the cover letter
(Attachment H). The Regional Coordinator should contact the Headquarters
Coordinator or other regional staff if further assistance is required. If the
questionnaire is not completed and returned within 30 days, the region should
draft and send a follow-up letter (see Attachment I) containing a warning of
impending administrative orders, which may result in the facility's being
fined. Once again, the region should maintain a record of all correspondence.
6. Processing Completed Questionnaires
The Regional Coordinator should log the receipt of the completed ARIP
questionnaire in the tracking system. The questionnaires should be reviewed
in coordination with the regional Office of General Counsel to make
determinations on any claims for confidentiality of survey data or any
supplemental information that has been provided. All information claimed as
confidential should be treated as confidential (e.g., restricting access to
this information to unauthorized personnel, using locked files and/or computer
passwords) until determined otherwise. Thus, this information should not be
distributed outside of the Agency, either to the public or to LEPCs and SERCs.
regional personnel should be trained in the procedures and regulations for
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handling confidential information to prevent improper distribution (i.e., 40
CFR Part 2 Subpart B). The tracking system should be amended to indicate the
existence and status of confidential materials in the file.
The ARIP questionnaire can be a valuable source of information for
ongoing regional efforts, and copies should be available for all interested
regional office personnel. Enforcement programs and facility inspections and
audits can be augmented by ARIP data; in addition, the region may choose to
perform analyses on the surveys received -- perhaps in conjunction with the
states or other entities. Headquarters is developing a computerized database
of survey information which will be made available to each regional office.
Each region may elect to develop its own system for tracking, analysis, or
follow-up.
H. Forwarding the Questionnaire to Headquarters
Finally, the region should forward completed questionnaires to the
Headquarters ARIP Coordinator. The package must include a simple cover letter
which lists the surveys enclosed and any problems or comments on the
questionnaires. Each survey should have the Record Identification (ID) number
from the NRC report written on the first page (the initial report page). If.
the region initiated the survey and there is no corresponding ID number, the
region should indicate this action on the first page. The region should
retain as many copies as it needs and send one copy to headquarters, being
sure to remove the instruction pages and any attachments (e.g., process
diagrams and facility drawings that do not pertain to a specific ARIP
question) before copying -- these pages should not be sent to headquarters.
The schedule for delivery of questionnaires is dependant upon the number of
surveys processed, but bi-weekly or monthly intervals are suggested as most
appropriate.
IV. FOLLOW-UP ACTIVITIES
EPA developed ARIP to establish a national database on the causes of
chemical accidents, to promote safety initiatives by industry, and to identify
methods used by facilities to prevent a release from re-occurring. As the
database grows, ARIP's prominence in developing and supporting release
prevention activities increases. Regional ARIP personnel are crucial to the
ARIP process because of their knowledge and working relationships with the
surveyed facilities, as well as the state and local agencies that share
responsibilities and concerns about accidental chemical releases. As a
result, headquarters appreciates feedback from the regions on the logistics of
the ARIP survey process, the benefits of ARIP for regional release prevention
efforts, and any requests for further analyses and technical assistance.
Sharing ARIP information within the regional office by distributing
completed surveys or by providing access to a computerized tracking system
will help coordinate and stimulate regional release prevention and
preparedness activities. Regional Coordinators should also anticipate the
eventual integration of ERNS with other regional computer systems and plan to
develop appropriate links to ARIP tracking and survey information. Regions
may also wish to exchange ARIP data with state and local agencies on a regular
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or formal basis to promote the discussion of special release concerns and the
development of emergency response plans. Headquarters reports and technical
assistance bulletins will be made available, as well as periodic reports
summarizing the interim results of ARIP analysis. This dissemination of ARIP
information will support state and local initiatives such as facility
inspections, .enforcement, and the development and refinement of emergency
planning. Regions may also wish to analyze the ARIP data to identify problem
areas, such as chemicals frequently involved in accidents, common causes of
accidents, and actions facilities have taken to prevent further releases.
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ATTACHMENT A
OMB#: 2050-0065
Expires: January 31,1991
U.S. Environmental Protection Agency
Accidental Release Prevention Questionnaire
Instructions
General Instructions
This questionnaire requests information to supplement reports you may have submitted to the National
Response Center and other federal, state, or local authorities. The instructions below explain the
questionnaire organization, define key words used in the questions, and give specific examples of responses to
each type of question.
Please read the instructions and examples before you answer the questions. When you complete the
questionnaire, place the completed form in the addressed envelope. If you need further assistance, please
contact the person identified in the cover letter.
Organization
The questionnaire is divided into three sections. All questions must be answered.
Section I - Facility Profile: This section asks several general questions about your facility: location,
ownership and current status of operations.
Section II - Hazardous Substance Release Profile: This section asks several key questions concerning the
reported release. It is important that you respond as accurately as you can based on the information available
to you. If additional comments would clarify your response, please note your comments on additional sheets
of paper.
Section HI - Cleanup and Prevention Profile: This section concludes the questionnaire with several
questions concerning your efforts to respond to the release. These questions ask you to provide an assessment
of prevention plans and equipment at your facility and any changes that will be initiated because releases
occurred. The questions have multiple choice responses, plus additional space for alternate answers and
details. Please attach additional pages if necessary.
Agency Disclosure of Estimated Burden
Public reporting burden for this collection of information is estimated to average 27 hours, including time
for reviewing instructions, searching existing data sources, gathering and maintaining data needed, and
completing and reviewing the collection of information. Send comments regarding the burden estimates or
any other aspects of this collection of information, including suggestions for reducing this burden, to Chief,
Information Policy Branch. PM-223, U.S. Environmental Protection Agency, 401M St., S.W., Washington,
D.C. 20460; and to the Office of Information and Regulatory Affairs, Office of Management and Budget,
Paperwork Reduction Project (2050 -0065), Washington, D.C. 20503.
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Definitions
Please refer to the definitions below to clarify the precise meaning and use of the terms in the
questionnaire.
Section I
\
Owner: The legally designated individual, partnership, corporation, or parties that own the facility.
Standard Industrial Classification: The federal government categories of business activity. See Standard
Industrial Classification Manual, Office of Management and Budget, U.S. Government Printing Office,
Washington, D.C.
Section II
Federal authority: Any federal government official delegated responsibility under the Superfund statute for
activities related to hazardous substance releases (e.g., National Response Center, Environmental Protection
Agency and it's regional offices).
General public: Persons not present within the facility boundaries at the time the release occurred (e.g.,
residents near the facility).
Hazardous substance: Any element, compound, mixture, solution, or substance designated under section 102
of the Comprehensive Environmental Response, Compensation, and Liability Act or section 3001 of the Solid
Waste Disposal Act
Local authority: Any local government official with some responsibility for activities related to hazardous
substance releases (e.g., Local Emergency Response Committee (LEPC), fire department).
Process vessel: A tank, vat, or other container in which substances are either blended to form a mixture or
reacted to convert them to some other final product or form.
Release: Any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping,
leaching, dumping, or disposing into the environment.
State authority: Any state government official responsible for remedial or related activities connected with a
hazardous substance release (e.g., State Emergency Response Commission (SERC), state transportation
office).
Storage vessel: Any container (e.g., tank, drum, bottle, tank car, cylinder)used to hold a raw or input material,
a product, or a by-product at ambient conditions or at an elevated or reduced temperature or pressure.
Equipment failure: Failure of equipment which allows a situation where substances may be released from the
equipment.
Operator error: A mistake (e.g., leaving a valve open, failure to respond to process alarms, failure to maintain
process variables or conditions at set point) made during operation of a process by the operator resulting in a
potential release of feed stocks, by-products, or products.
Bypass: A pipe or channel providing an alternate pathway for gas or liquid streams that avoids the main
pathway by detouring around it.
-------
Upset: A malfunction or failure of process controls, alarms, or backup systems due to operator error,
mechanical or equipment failure, or impingement by unexpected events such as fire, explosion, power loss, or
water loss.
Spill: The unintentional or accidental release or flow of a substance from a container causing a loss of the
substance.
Vapor release: Escape of a gas from a storage or process vessel or from the vaporization of volatile liquids.
Migration: The movement of a substance from one place to another in air,water, soil, or other media.
Facility boundary: Fence line or property line marking the perimeter of a facility.
Containment system: A series of curbs, vaults, ponds, and the like which serve to collect and temporarily hold
spilled materials until such time as they are removed or transferred to a secure storage vessel.
POTW: Publically owned treatment works.
Section III*
Cause - Consequence Analysis: A blend of fault tree and event tree analysis. The cause - consequence
diagram displays the interrelationships between accident outcomes and their basic causes.
Dow and Mond Index: Provides a method for relative ranking of the risks in a chemical process plant. The
method assigns penalties to process materials and conditions that can contribute to an accident. Credits are
assigned to plant safety procedures that can mitigate the effects of an accident.
Event Tree Analysis: Considers operator response or safety system response to an initiating event in
determining accident outcome. The results are accident sequences.
Failure Modes, Effects, and Criticality Analysis: A tabulation of the system/plant equipment, their failure
modes, each failure mode's effect on the system/plant, and a criticality ranking for each failure mode. The
failure mode is a description of how equipment fails.
Fault Tree Analysis: A deductive technique that focuses on one particular accident event and provides a
method for determining causes of the event The fault tree is a graphic model that displays the various
combinations of equipment faults and failures that can result in the accident event.
Hazard Assessment: Formal procedures employed to identify potential risks that could lead to an accidental
release (i.e., fault tree analysis)
Hazard and Operability Studies: HAZOP is conducted by teams that brainstorm to systematically identify
hazards or operability problems throughout an entire facility through the use of certain guidewords such as
"no flow" and "no cooling". The consequences of the deviation associated with the guidewords are assessed
and credible deviations are identified and addressed.
Human Error Analysis: A systematic evaluation of the factors that influence the performance of human
operators, maintenance staff, techniques, and other personnel. It will identify error likely situations that can
cause an accident.
Pre-Release Technologies: Technologies designed to reduce the probability that the primary containment
(i.e., tanks, transfer piping, reactor vessel) of the chemical will be breached.
-------
Probabilistic Risk Assessment: Overall measure of risk determined through numerical evaluation of both
accidental consequences and probabilities. Used to assess comparative risk where alternative designs exist,
also for assessment of acceptability of a risk and to suggest risk reduction strategies.
Process Design: Design of process equipment and systems to limit accident potential (i.e., redundant
systems).
Process Control and Monitoring: Controls and detection equipment to provide information on possible or
imminent releases (i.e., pressure sensor, temperature sensor, chemical detector on process line).
Protection: Application of equipment, systems, and procedures to capture, neutralize, or destroy a toxic
chemical before it is released to the environment (i.e., scrubber).
Post-Release Mitigation: Application of equipment, systems, and procedures to capture, neutralize, or
destroy a toxic chemical afifii it is released to the environment.
Siting and Facility Layout: Facility layout based on risks posed to the surrounding community and on widely
accepted safety standards for equipment, procedures, and systems.
What-if Analysis: Considers the consequences associated with events that occur as a result of failures
involving equipment, design or procedures. All possible system failures may be collected in checklist form
and evaluated: for example, "what if the feedpump fails". Compiling a list of failures requires a basic
understanding of what is intended and the ability to combine or synthesize possible deviations and reject
incredible situations.
"The definitions in this section are derived from Guidelines far H/rrnrd Evaluation Procedures. AIChE, 1985, and
the Review ofEmenenty Systems. EPA, June 1988.
-------
Examples of Questions:
Example A
Several questions require a simple marked response to a preceded answer. The example below shows a
correct response.
lla.Check the item below that best describes the status of facility operations at the time of release.
a. X In operation
b. _ Temporarily inactive
c. _ New construction
Example B
Several questions require you to answer with data. A correct response is shown in the example below.
9. Indicate the date release began.
Qfi - 11 -
(month) (day) (year)
Example C
Some questions require you to describe an answer because the available answers to the question do not
cover your situation.
19. Please check the one item below that best describes the location of the release within your facility.
_ Process vessel
_ Storage vessel
_ Valves
_ Piping
_ Unknown
X Other (please describe)
Secondary containment vault
-------
Example D
A few questions require you to fill in tables with data or information from your facility. One example is
shown below. Other tables are similar.
24.a. Identify in the table below the name of each hazardous substance released, the quantity released, and
the concentration and physical state at the time of release.
NAME QUANTITY UNIT PHYSICAL STATE CONCENTRATION
1. Anhydrous Ammonia 50 Ibs gas 100%
3.
4.
Example E
19. Briefly describe the circumstances that led up to the release.
At 11 a.m., two operators began to transfer hydrofluoric acid from a rail tank car to a facility
storage vessel. All proper transfer connections were made but the operators left the vessels
unattended during the chemical transfer. Both the automatic cutoff switch and the overfill warning
alarm failed to function. Within 25 minutes, 250 gallons of hydrofluoric acid had spilled onto the
lined concrete pad before operators noticed the release and closed the feed to the storage vessel.
Meanwhile, the hydrofluoric acid spilled through a cracked section of the secondary containment and
flowed into an adjoining field. Also, a vapor cloud began to form which hampered efforts to contain
and neutralize the free liquid in the release area. Over the facility loudspeaker, all personnel were
alerted to clear the area.
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
ACCIDENTAL RELEASE PREVENTION QUESTIONNAIRE
INITIAL REPORT
SECTION I. FACILITY PROFILE
1. FACILITY NAME:
2. Dun & Bradstreet Number.
3a. FACILITY MAILING ADDRESS:
b.Facility physical address:
Latitude Longitude
4.
DEG
MIN
1
DEG
1
MIN
Street
City
State
Zip Code
Street
City
State
Zip Code
-------
5. NAME AND ADDRESS OF OWNER
OR CHIEF EXECUTIVE OFFICER: .
Name
Street
City
State
Zip Code
6a. RESPONDENT:
Name
Title
Street
City
State
Zip Code
Telephone
b. DATE QUESTIONNAIRE
COMPLETED:
7. Indicate the total number of employees typically at the facility (include all full-time and part-time
employees, all employees on paid sick leave, paid holidays, paid vacations, managers and corporate
officers at the facility).
8. Identify the four-digit Standard Industrial Classification (SIC) that best describes your facility
operations and the primary product or service of this facility.
a. SIC code: ;
b. Primary product or service: ]
c. For facilities with multiple SIC codes, please identify the additional SIC codes.
-2 -
-------
SECTION II. HAZARDOUS SUBSTANCE RELEASE PRQFTLF,
The following section asks several questions concerning the accidental release of hazardous substances. If
exact responses cannot be provided please provide estimates using your best professional judgment.
9. Indicate the date release began.
(month) (day) (year)
Indicate date release ceased.
(month) (day) (year)
10. Indicate time of day release began.
~ A!M.
_ P M.
Indicate the time of day release ceased.
P.M.
lla. Check the item below that best describes the status of the process line where the event occurred at
the time of release.
1. In operation
1 Temporarily inactive
3. _ Testing/Trial Run
4. Scheduled startup
5. Scheduled shutdown
6. New construction
7. During Maintenance
8. __ Production Changeover
b. Check the item below that best describes the current status of the process line where the event
occurred.
1. In operation
2. Temporarily inactive
3. Permanently closed
If item 2 or 3 is marked, answer Question lie; otherwise go to question 12.
-3-
-------
c. Is the shut down of operations at the process line related to the accidental release of hazardous
substances?
_Yes
_No
12a. Were federal authorities notified?
_Yes
_No
b. If yes, please indicate which federal authorities were notified:
1. National Response Center telephone number called ( ^
2. Coast Guard telephone number called ( X.
3. EPA telephone number called (___)_
4. _ Other (specify)
c. Indicate the date and time of day federal authorities were notified.
__ - __ - __ (Date)
(month) (day) (year)
__ : __ (Time)
A.M.
13a. Were state authorities notified?
_Yes
_No
b. If yes, identify all state authorities notified concerning the release. (If more than one, please attach
list on separate page)
(Name) ! (Title)
(Agency) '.
()
(Telephone)
-4-
-------
c. Indicate the date and time of day state authorities were notified.
- - (Date)
(month) (day) (year)
: (Time)
_A.M.
_ P.M.
14a. Were local authorities notified?
_Yes
_No
b. If yes, identify all local authorities notified concerning the release. (If more than one, please attach list
on separate page)
(Name) (Title)
(Agency)
__
(State)
1
(Telephone)
c. Indicate the date and time of day local authorities were notified.
- - (Date)
(month) (day) (year)
: (Time)
_A.M.
P.M.
15a. Was the general public notified?
_Yes
No
-5 -
-------
b. If yes, indicate the person that notified the general public of the release. (If more than one, please
attach list on separate page)
(Name) (Title)
(Agency)
(City)
(State)
(Telephone)
16. For this particular release, what type(s) of communication technologies were used by the facility to
alert and notify the public to evacuate or take other safety measures?
a. Door-to-door notification
b. Loudspeakers/public address system
c. Tone alert radio/pagers
d. Siren/alarms
e. Modulated power lines
f. Aircraft
g. __ Radio
h. Television
i. Cable override
j. Telephone
k. None
1. Other (please describe)
17a. Were members of the general public evacuated? b. Were members of the general public
sheltered in place?
_Yes _ Yes
No
If yes, please indicate number evacuated. If yes, please indicate number sheltered
in place.
18. To the best of your ability, indicate the weather conditions at the time of release for each item below.
Approximations are acceptable.
a. Wind Speed (miles per hour)
b. Wind Direction
c. Humidity (percent)
d. Temperature (Fahrenheit)
e. Precipitation? __Yes _No
-6-
-------
19. Briefly describe the circumstances that led up to the release (if helpful include a sketch).
20. Please check the one item below that best describes the location of the release within your facility.
a. Process vessel
b. Storage vessel
c. Valves on process vessel
d. Valves on storage vessel
e. Piping on process vessel
f. Piping on storage vessel
g. Pumps
h. Joints
i. Unknown
j. Other (please describe)
21. How was the release first discovered? (check as many as apply)
a. Indication by process control device (gauge or monitor)
b. Chemical specific detector
c. General operator observation
d. Observation by foreman or supervisor
e. Injury/death
f. Explosion/fire
g. Major environmental damage
h. Third party notification (i.e., POTW, community, other facility)
i. Other (describe below)
- 7 -
-------
22. Please check the one item below that best describes the primary cause of the release event, (please
check one item only)
a. Equipment failure
b. Operator error
c. Bypass condition
d. Upset condition (explain below)
e. Fire
f. Maintenance activity
g. Unknown
h. Other (Please describe)
23. Please check any items below that describe additional causes of the release event, (check as many
items as apply)
a. Equipment failure
b. Operator error
c. Bypass condition
d. Upset condition (elaborate below)
e. _ Fire
f. Maintenance activity
g. Unknown
h. __ Other (Please describe)
24. Check the items that describe the end effects of the release event (check as many as apply)
a. _ Spill
b. Vapor release
c. Explosion
d. _ Fire
e. _ Other (describe)
-8 -
-------
25a. In the table below, please estimate the quantity of each substance released to each media. Be sure to
specify the measurement unit.
Chemical
Media
Quantity
Unit
la. Name
b. CAS #
c. Physical
State
d. Concentration
Air
Surface Water
Land
Sewer to Treatment
Facility
2a. Name_
b.CAS t
c. Physical
State
d. Concentration
Air
Surface Water
Land
Sewer to Treatment
Facility
3a.Name
b.CAS i
c. Physical
State
d. Concentration
4a. Name_
b.CAS #
c. Physical
State
Air
Surface Water
Land
Sewer to Treatment
Facility
Air
Surface Water
Land
Sewer to Treatment
Facility
d. Concentration
-9 -
-------
b. Please check the items below that describe your methods or source of information for your responses in
Question 25a. (check as many as apply)
physical properties and ambient conditions
on-line instrument
engineering estimate
tank/system inventory
chemical analysis
effluent measured
inventory check
computer simulation
process records
no release to media
other (please describe)
26a. Did any substances identified in Question 25, migrate beyond the legal boundaries of your facility (for
example, a vapor release was carried by prevailing wind beyond the fence line of your facility)?
Yes (If yes, please answer Question 26.b and c)
No (If no, skip Question 26.b and answer Question 26c)
b. In the table below specify the quantities of substances that migrated beyond your facility boundaries.
Chemical Media • Quantity Unit
Air
1. Name: Surface Water
Land
Physical state: POTW
Air
2. Name: Surface Water
Land
Physical state: POTW
Air
3. Name: Surface Water
Land
Physical state: POTW
Air
4. Name: Surface Water
Land
Physical state: POTW
c. Please check the items below that describe your methods or source of information for your responses in
question 26b.
- 10-
-------
physical properties and ambient conditions
on-line instrument
engineering estimate
tank system inventory
chemical analysis
effluent measured
computer simulation
inventory check
process records
assumed
other (please describe)
27. Did injuries occur among facility employees or contractors as a result of the event?
_Yes
_No .
a. If yes, please indicate number of injuries.
b. How many of these received hospital treatment?
Number treated unknown
c. Did deaths occur among facility employees or contractors as a result of the event?
_Yes
_No
If yes, please indicate number of deaths.
28. Did injuries occur among the general public as a result of the event?
_Yes
_No
Don't know
a. If yes, please indicate number of injuries.
- 11 -
-------
b. How many of these received hospital treatment?
Number treated unknown
c. Did deaths occur among the general public as a result of the event?
_Yes
_No
Don't know
If yes, please indicate number of deaths.
29. Please indicate the environmental effects that occurred as a result of the release:
a. __ Fish kills
b. Vegetation damage
c. Soil contamination
d. Groundwater contamination
e. _ Wildlife kills
f. None
g. Other (please specify)
-12-
-------
SECTION III. CLEANUP AND PREVENTION PROFITS,
30. Please describe the immediate response activities taken to contain or minimize the release.
31. Did your facility undertake cleanup of the release?
Yes (If yes, skip Question 32a.)
_No
32a. Please supply the name and address of the party responsible for cleanup.
(Name) (Title)
(Agency) ~~
(City)
(State) t~~
(Telephone)
b. Has cleanup of the release been completed?
Yes (If yes, please answer Questions 32c.)
No (If no, please answer Question 32d.)
c. Indicate the date cleanup activity ceased.
(month) (day) (year)
d. Please indicate the approximate date completion of cleanup activity is expected.
(month) (day) (year)
33. How did you dispose of the waste generated during the spill and cleanup?
On site
Off site
- 13 -
-------
34a. Prior to this release event, which types of formalized hazard assessments were performed? (Check as
many items as apply). For those items checked, please indicate the frequency performed (i.e.,
quarterly, annually, one time, or on occasion).
Frequency
. Cause-consequence analysis
Dow and Mond Hazard Indices ~
Event tree analysis '
Failure modes, effects, and criticality analysis *
Fault tree analysis
HAZOP/hazard and operability studies
Human error analysis
Probabalistic risk assessment
What if analyses
None
Other (please describe)
b. What is your opinion of the effectiveness of each of the assessment techniques used?
35. Prior to this release event, which of the following pre-release controls have been employed specifically
to identify/prevent the type of release that occurred? (Check as many items as apply)
a. Preventative maintenance
b. Regular equipment inspections and testing
c. Hazard assessment
d. Comprehensive audit
e. Regular assessment of equipment designs
f. Process controls for operations monitoring and/or warning
g. Regular upgrading of equipment
h. Comprehensive investigation on similar equipment failure
i. Standard operating procedures
j. _ Release prevention equipment
k. Equipment installation checks
1. Other (please describe)
-14-
-------
36. Prior to this release, what management activities related to safety and loss prevention have been
employed? (Check as many as apply)
a. _ Employee safety training (e.g., OSHA training programs)
b. __ Emergency Response training
c. Employee testing
d. Certification of operators on equipment/system
e. Membership in CAER or other similar programs
f. Release control program
g. Accident investigation reports
h. Research/conferences
i. Safety loss prevention office/officer
j. Corrective action process for deviation from rules
k. Program to improve system design
1. _ None
m. Other (please describe)
37. For this particular release, what method(s) of pre-release protection equipment (systems to capture,
neutralize, or destroy a toxic chemical before it is released into the environment) is used by the facility?
(Check as many items as apply)
a. Containment (i.e., diking, dump tank - explain below)
b. Neutralization
c. Scrubber
d. Flares/incineration
e. Adsorbers
f. Spray curtain
g. Emergency Equipment (i.e., fire fighting)
h. None
i. Other (please describe)
38. For this particular release, what systems or procedures were employed by the facility to minimize
accident potential? (Check all that apply)
a. Backup systems
b. Redundant systems
c. Minimize inventory
d. Valve lock out
e. __ Automatic shut off
f- _ Bypass and surge systems
g. Manual override
h. Limit capacity of equipment
i. Standard Operating Procedures (logs, checklists)
j. Alarms
k. Interlocks
1. _ None
m. Other (please describe)
- 15 -
-------
39. In response to this release, which of the following pre-release controls have been implemented or
modified to identify/prevent future potential releases? (Check as many as apply)
a. Preventative maintenance
b. Regular equipment inspections and testing
c. Hazard assessment
d. Comprehensive audit
e. Regular evaluation of equipment designs
f. Increased process controls for operations monitoring and/or warning
g. Upgrading equipment
h. Revised standard operating procedures
i. Follow accident report investigation recommendations
j. Develop or refine emergency response planning
k. Other (please describe)
40. Describe the changes in the content of your training programs as a result of this release.
41. Describe the immediate equipment repairs and/or replacements, management practices, operational
changes, etc. made as a result of the release.
42. What additional long term preventative measures) will be taken to minimize the possibility of
recurrence?
-16-
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ATTACHMENT B
SUBJECT: CONFIDENTIAL RECORD PRINTOUT
DATE: 02/16/89
RECORD IDENTIFICATION ID)
CODE DAY TO NRC(RDATE):
CODE TIME TO NRC(RTIME):
SPILL STATE(SST):
TRANSPORT MODE:
DUTY OFFICER(DO):
1.
CHRIS COOE(CC):
MATERIAL SPILLED(MATSP):
CHRIS NAME:
QUANTITY SPILLED(QUA):
UNITS:
QUANTITY IN WATER(QUAW):
UNITS IN WATER(UNITSW):
SPILLER'S COMPANY(CORG/DORG):
SPILLER ADDRESS (CADD. CCITY. CST
SPILL CITY, COUNTY(SCITY.SCOUNTY)
SPILL LOCATION 1(LOC1):
SPILL LOCATION 2{LOC2):
DAY SPILLED(DASPI):
TIME SPILLED(TMSPI):
MEDIUM:
WATERWAY AFFECTED(WWY):
CAUSE:
DESCRIPTION OF CAUSE(DESCl):
DESCRIPTION OF CAUSE(DESC2):
VEHICLE ID(VID):
OEATHS(DEA):
INJURED(INJ):
EVACUATIONS?(EVAC):
PROPERTY DAMAGE(PROP):
REMEDIAL ACTION(ACT1):
REMEDIAL ACTION(ACT2):
NOTIFIED: EPA? F REGION(EPAR):
20744
12/03/1988
1549
LA
F
JPM
TRIGGER: 12--> REPEAT RELEASE & EHS
REPORT NUMBER(RNO): 16237
3.
CLX
CHLORINE GAS
Chlorine
800.00 0.00 0.00
LBS
0.00 . 0.00 0.00
NON
PPG INDUSTRIES
CZIP): POB 1000, LAKE CHARLES. LA, 70602
WESTLAKE CALCASIEU
COLUMBIA SOUTHERN ROAD
PPG IND
12/03/1988
1305
AIR? T LAND? F WATER? F 6ROUNDWATER? F FAC? F
AIR
TRANS_ACC? F EQUIP? F OPJRROR? F NATL PHENOM? F DUMP? F UNK? F OTHER? F
CHLORINE NEUTRALIZER/MECHANICAL FAILURE
DAMAGES?(DAM): F
SHUT DOWN CHLORINE CIRCUITS
6 TIME: 1553 USCG? F UNIT(CGU):
TIME:
OTHER? F OTHERS TIME:
STATE LOC? T DISCHR? F NTSB PIPE? F NTSB RAIL? F RSPA OHM? F RSPA OPS? F DOT FRA? F DOT FAA? F
OOT_OMCS F MISCJRC? FMISC_OOE?
NOTIFIED BY CALLER(CNOTIF):
OTHERS NOTIFIED(AGENC):
MISCELLANEOUS INFORMATION(Ml):
MISCELLANEOUS INFORMATION^):
MISCELLANEOUS INFORMATION^):
MISCELLANEOUS INFORMATION^):
DATE HARDCOPY(OHC):
JURISDICTION JURI):
DATE OF ENTRY(OE):
F MISC_FEMA? F MISC_DOO? F
LA STATE POLICE.DEQ~
CHEMTREC? F UNKNOWN? F
12/05/1988
DATE CANCELLATION LETTER(DCANL):
REPORTABLE(RPT):
DATE OF CHANGE(DC):
-------
ATTACHMENT C
Exhibit 1
ARIP Trigger Codes and Descriptions
Code Trigger Description
1 Death/Injury
2 Exceeds RQ Multiple
3 Death/Injury and Exceeds RQ Multiple
4 Repeat Release
5 Repeat Release and Death/Injury
6 Exceeds RQ Multiple and Repeat Release
7 Death/Injury and Exceeds RQ Multiple and Repeat Release
8 Extremely Hazardous Substance (EHS)
9 EHS and Death/Injury
10 EHS and Exceeds RQ Multiple
11 EHS and Exceeds RQ Multiple and Death/Injury
12 EHS and Repeat Release
13 EHS and Repeat Release and Death/Injury
14 EHS and Repeat Release and Exceeds RQ Multiple
15 All Triggers
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ATTACHMENT D
Exhibit 3
Number of ARIF Release Reports by Trigger
Number of
Trigger Code Release Reports
1 9
2 47
3 1
4 11
6 5
8 95
9 3
10 24
11 3
12 39
13 1
Percentage
of Total
4.0%
19.5%
.5%
5.0%
2.0%
39.0%
1.0%
10.0%
1.0%
16.0%
.5%
Trigger Description
Death/Injury
Exceeds RQ Multiple
Death/Injury and Exceeds RQ
Multiple
Repeat Release
Exceeds RQ Multiple and
Repeat Release
Extremely Hazardous Substance
(EHS)
Death/Injury and EHS
Exceeds RQ Multiple and EHS
Exceeds RQ Multiple and EHS
and Death/Injury
Repeat Release and EHS
EHS and Repeat Release and
Death/Injury
14 4 1.5% Exceeds RQ Multiple and
Repeat Release and EHS
243' 100%
-------
Exhibit 2
Number of ARIP Triggered Release Reports by Region
Regions
123456789 10 Total
Triggered
Release
Reports 8 10 28 50 20 60 12 6 37 12 243
May-June
Triggered •
Release
Reports 34 45 89 159 122 281 40 18 119 48 955
Cumulative
10/88 - 6/89
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ATTACHMENT E
Region IV
Number of ARIP Release Reports by Trigger
Trigger Code
1
2
4
6
8
10
11
12
Number of
Releases
1
17
3
1
22
2
1
7
Record Identification Numbers
13192
7538,
9460,
11197
12465
10660
10008
7351,
9663,
10374
11321
12274
7549,
10021
9158,
8811,
10009,
, 11693
, 10711
8834,
10020,
, .10850
, 11655
, 12451
12052
10335,
9056, 9178,
10538, 11014,
, 11698, 12132,
, 11062
8902, 8966, 9280,
10030, 10055, 10368,
, 11022, 11243, 11268
, 11767, 12233,
, 13184
11249,
Percentage
of Total
2%
26%
6%
2%
»
44%
4%
2%
11641, 11782,
11965, 12042 14%
Total 50 100%
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Region VI
The following facility has a release that falls into the Repeat Release trigger category. The ARIP program
requires a questionnaire to be sent to facilities that have repeat releases of CERCLA substances above the
RQ. The facility'should begin receiving questionnaires once it has had its fourth release and will continue
to receive a questionnaire for each subsequent release with a cap at the tenth release. Listed here are the
first three releases at a facility plus the additional releases that qualify as ARIP triggered releases.
Record
Facility Address ID #
Vulcan Chemicals P.O. Box 227 20488
Inc . Ashland Road
Geismer, LA 21105
70734
21181
388
663
4315
6816
*9120
*9101
*11408
Dates
of Releases
11/27/1988
12/12/1989
12/14/1988
01/07/1989
01/14/1989
03/21/1989
04/23/1989
05/16/1989
05/16/1989
06/14/1989
Chemicals
Methyl Chloride
Methyl Chloride
Methyl Chloroform
Methyl Chloride
Mixed Hydrogen
Chloride and
Methyl Chloride
Methyl Chloride
Chlorine
Methyl Chloride
Methyl Chloride
Chlorine
Amounts
27.0
25.0
1000.0
18.0 >
2.0 3
^
80 Ibs.
20 Ibs.
2 Ibs.
70 Ibs.
10 Ibs.
The NRC report for the release to be surveyed is included in this data set.
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ATTACHMENT G
CEP-4 (OSWBt 143)
Report number of Accidental Release Information Program (ARTP) triggered
letters/questionnaires sent to facilities having releases. (This includes both
those releases identified by the National Response Center as well as any
additional releases identified by the Region.)
NRC Record Number
(RNO)
Date
Questionnaire
Sent
NRC Record Number
(FNO)
Date
Questionnaire
Sent
Total Sent from Headquarters
Total Sent Out This Quarter
page 4
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ATTACHMENT H
-> initial Facility Notification <-
Certified Mail
Return Receipt Requested
<7aoility Addr«ss>
Dear
-------
should be sent to EPA within thirty (30) calendar days of your
receipt of this letter. Requests for a reasonable extension of
time can be discussed with the Agency.
You are entitled to assert a claim of business confidentiality,
in accordance with 40 CFR §2.203(b), for any confidential
business or trade secret information produced. Information
subject to a claim of business confidentiality will be made
available to the public only in accordance with the procedures
set forth in 40 CFR Part 2, Subpart B. Unless a business
confidentiality claim is asserted at the time the requested
information is submitted, EPA may make this information available
to the public without further notice to you.
Your completed response should be sent to:
«a«, Title>
<8eotion/Diviaion>
~
If you have any questions concerning this matter, please contact
at .
Sincerely yours,
Enclosure
cc. .
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ATTACHMENT I
-> fleeond Facility Notification <-
Certified Mail i
Return Receipt Requested
Dear :
On you were sent a multi-page
Accidental Release Information Program (ARIP) questionnaire
regarding the following release event(s):
DAM NBC IDi Substance Quantity
A copy of that ^Letter date> notification is attached for your
information.
As of this date, our office has no record of your reply to that
letter. If you have indeed submitted the information requested,
please provide this office with another copy of your response. If
you have not yet submitted your reply, you have <10 or 20> days
from the receipt of this letter to submit that information. A
blank copy of the ARIP questionnaire is enclosed for your use.
Please note that the failure to submit the requested information
in the alloted time may constitute violations of a number of
Federal pollution statutes, including CERCLA Section 104(e)(5),
and will be referred to our
for further action.
If you have any questions regarding this letter or the ARIP
questionnaire, please contact of my staff at .
Sincerely yours,
Enclosure
cc.
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