FAILURE TO IMMEDIATELY REPORT THE RELEASE OF A HAZARDOUS SUBSTANCE. RELEASE WAS 218 TIMES THE REPORTABLE QUANTITY. ON MAY 5, 1997, THERE WAS A RELEASE OF 21,847 POUNDS OF TOLUENE DIOSOCYANATE FROM THIS FACILITY. TDI IS A CERCLA HAZARDOUS SUBSTANCE WITH A 100 POUND RQ. FOZMEX NOTIFIED THE NRC THREE HOURS AND 59 MINUTES AFTER KNOWLEDGE OF THE RE- LEASE, WHICH IS NOT IMMEDIATE PURSUANT TO CERCLA 103. THE RELEASE WAS A RESULT OF A TRANSFER PUMP THAT WAS LEFT UN- ATTENDED DURING THE TRANSFER OF PRODUCT FROM A LONG TERM SHORTAGE TANK TO A READY TO USE DAY TANK. THE TDI OVER- FLOWED INTO AN OVERFLOW TANK THEN OUT OF THAT TANK ONTO THE PAVEMENT AND INTO A ADJACENT STROM DITCH. DUE TO THE CHARACTERISTICS OF TDI THE MATERIAL SOLIDIFIED IN THE WATER AND DID NOT MIGRATE BEYOND THE FACILITY'S BOUNDARIES. CASE CLOSED MAY 22, 2000 (SEE #8).