P.1 

/a/(lo)r?&S-S 

A JOINT VENTURE OF FIRST MISSISSIPPI CORPORATION AND MISSISSIPPI CHEl/lCA^ycORj/JbRATTON 

P. O. BOX 310 TELEPHONE 504 473-9231 

DONALDSONVILLE. LOUISIANA 70346-031 0 

March 18, 1986 

Mr. Lee M» Thomas, Administrator 

Environmental Protection Agency 

401 M. Street, SW 

Washington, D.C. 20460 

Re: Required Notification Under

 nCERCLAn 

Dear Mr. Thomas: 

Triad operates a 1000 TPD ammonia plant and a 1500 TPD urea plant from which 

routine ammonia emissions are incidental to normal operations. While our 

notification obligation under CERCLA remains poorly defined, we feel that some 

documentation of our emissions is probably within tHe intent of CERCLA. This 

letter constitutes a report which we propose to confirm annually. 

A

The rationale for our decisions to date involves two isfl"«»s whirh rpmain 

unresolved in current regulations; continuous releases and federally permitted 

releases. The majority of our ammonia emissions emit from specmc point sources 

which are reported in an Emissions Tnvont-nry Survey (EIS) under Louisiana's 

federally approved air progfam!The EIS, an integral part of our air permit with 

the state.t discloses these ammonia emissions, thus subjecting them to scrutiny 

arSr-regulation by the state. We regard tnese"releases to hp fpHprally permitted 

and thus exempt from 103 reporting requirements. 

Secondarily, both plants have fugitive ammonia emissions from miscellaneous 

sources. While it is not practical to determine such fugitives on a daily basis, 

we estimate that collectively they constitute a source which is more or less 

continuous and which may exceed 100 pounds per day without Triad's knowledge at 

the rime of "lo^ o <-.f iviaH'g ahi_LLELy__to quantify the collective total. 

Regarding such releases, we continue to be guided by the direction given in EPA's 

Interpretive Rule and Policy Statement dated June 2, 1981. We feel this direction is summarized by the following excerpt from Section I.B. of the statement... 

"There are other releases of hazardous substances which are subject to 

the notification requirements of Section 103 (a) and (b). These 

include routine, continuous or anticipated intermittent releases from 

facilities or vessels which are incidental to normal business operations and are not federally permitted releases or otherwise exempt or 

excluded. EPA is not presently requiring notification of these 

releases. Tftese releases ao not generally demand immediate response..-

Requiring immediate notification of these releases would lead to 

thousands of reports each day and make it difficult, if not impossible, 

for the government"to operate its emergency response system." 
P.2 

Mr. Lee M. Thomas 

March 18, 1986 

Page Two 

y 

This direction is equally applicable to the point source emissions which we 

regard as federally permitted. However, out of an abundance of precaution, we 

are filing this annual notification. 

Finally, we recognize a third category of releases which are "episodic, 

nonroutine, unanticipated, or accidental releases...in quantities equal to or 

greater than the notification level...", i.e., 100 pounds for ammonia. We 

clearly regard such releases as subject to Section 103 reporting and will 

continue to report them accordingly. 

Reportedly, EPA is striving to clarify the concepts and requirements 

regarding continuous releases and federally permitted releases. We would 

appreciate receiving such clarification when it becomes available. Meanwhile, we 

trust that this report satisfies the intent of CERCLA's notification requirements. 

BKS/KLC/dm 

Sincerely, 

TRIAD CHEMICAL 

^]^<LMU4JLB. K. Shackelford 

Complex General Manager 

cc: K. L. Crochet 

D. C. Andrews 

H. F. Torres 

J. D. Davis 

W. A. McCrary - FMC 

S. Rogers - MCC