Train derailment of  9 rail cars each filled with Soda Ash (Anhydrous Sodium Carbonate).

Denison Union Pacific switching yard located at the Union Pacific overpass of Highland Drive, on the west side of Denison, Grayson County, Texas.

33.77023W, 096.60261N

For unknown reasons, UP did not initially respond to their derailed soda ash cars (although their contractors did repair the broken track at the derailment site).   Approximately 5 days after the derailment, on 9 June 2012, a local citizen contacted the EPA and NRC to report a release of an unknown substance potentially coming from the derailed cars, which had impacted a nearby drainage ditch and Shawnee Creek. The resident had noted a dark liquid in the creek and ditch after a major storm event on June 5 and 6.  

On 9 June 2012, the EPA Region 6 PDO contacted the Response Duty OSC and START-3 and informed them of a potential response to a train derailment that happened on 3 June 2012, and the Response Duty OSC and START-3 were to leave on the morning of 10 June 2012.

10 June 2012, at approximately 1230 EPA OSC Mike McAteer and START-3 arrived on site. Upon arriving, EPA and START-3 collected facts regarding the incident and took photo documentation of the derailment site. START-3 observed and recorded the rail car numbers, as well as utilizing a hazcat kit to try and identify the two unknowns.  OSC McAteer and START-3 viewed the affected creek, and a pH between 11 and 12 was observed at a location close to the creek entry point downstream of the derailment location. OSC McAteer contacted Union Pacific representatives in regards to the spill, and informed them that Union Pacific needed to activate and mobilize clean up contractors to the site immediately. OSC McAteer also contacted the Denison water department and informed them of the situation. Union Pacific clean up contractors, United Professional Services, arrived on site at 1610 and started cleanup activities in Shawnee Creek. Conestoga-Rovers and Associates, another Union Pacific contractor, arrived on site to document and map the extent of the release and also to take samples within the creek and Randell Lake. A vacuum truck also arrived on scene to start removal of the contaminated water within Shawnee creek. Union Pacific contractors worked until sundown on vacuuming the creek.

11 June 2012, EPA continued to monitor and document cleanup activities. The RP began flushing activities along the ditch on Highland Drive, and all flush water was collected and stored on site in frac tanks. The RP began excavating soil at the incident location, and all soil that was excavated was stored on site (UP switching yard) in a poly lined bermed area. A second poly liner was placed over the contaminated soil and secured in place to prevent precipitation from infiltrating soil. A diversion trench was created at the drainage ditch along the railroad easement to prevent water from flowing into Shawnee Creek. The diversion trench will be pumped out if any water pools within the trench. RP began removing product from within the derailed hopper cars utilizing an auger. The product is stored in super sacks and placed in an area where the owner can collect the soda ash and remove it off site. Two (2) TCEQ representatives were on site to document activities. Rain and possible thunderstorms are predicted for tonight. Containment measures are in place. A rain event occured in the early morning hours of 11 June 2012, producing appoximately 0.31 inches of rain.

12 June 2012. EPA continued to monitor and document cleanup activities. START-3 took pH levels of the ditch along Highland Drive, inside Shawnee Creek, and containment measures on-site. The highest pH level found in Highland Drive ditch and Shawnee Creek was around pH 8, and the highest pH level found in containment measures on-site was around pH 12. Containment trench along drainage ditch on railroad easement was pumped out utilizing a stationary pump that was put in place the night before. A staging area was created on the west side of Highland Drive for the storing of empty hopper cars. Trees and vegetation had to be removed. Soda ash stored in super sacks were moved further into the UP switching yard, and covered with plastic and poly liners. First hopper car was emptied of soda ash, and was transported across Highland Drive to the staging area. Work began on the second hopper car removing soda ash. One (1) TCEQ representative was on site to document activities and pH levels. A rain event occured throughout the overnight hours, and totalled approximately 1.0 inches of precipitation.

13 June 2012. EPA continuned to monitor and document cleanup activities. START-3 took pH levels of the ditch along Highland Drive, inside Shawnee Creek, and containment measures on-site. A pH level of 11 was discovered at an earthen berm in the ditch along Highland Drive next to a leaking vacuum truck. The water was removed by the vacuum truck, and CRA, a UP contractor, tested the water inside of the truck for pH and discovered a level of 11.03. It was later determined the vacuum truck offloaded a second vacuum truck that was at the derailment site, and did not offload the water after the transfer. Shawnee Creek had a pH 8, and the highest level of pH found at derailment site was pH 12, inside containment measures. A second auger was brought in, for a total of two (2) augers and crews removing soda ash from derailed hopper cars. A second hopper car was emptied and transported across Highland Drive to staging area. One (1) TCEQ representative was on site to document activities and pH levels. A rain event occured in the early morning, and again in the mid afternoon totalling approximately .10 inches of precipitation.
 
14 June 2012. EPA continued to monitor and document cleanup activities. START-3 took pH levels of the ditch along Highland Drive, inside Shawnee Creek, and containment measures on-site. The third and fourth empty hopper cars were removed from site and staged at the empty hopper car staging area west of Highland Drive, car numbers TGSX 443552 and FMLX 51286. Shawnee Creek had a pH of 8, and the highest level of pH found at derailment site was pH 11, inside containment measures. Excavation of soil from derailment site is stored on-site for disposal. Access to fifth rail car was made, and emptying of fifth rail car will start 15 June 2012. Two (2) TCEQ representatives were on site to document activities. A thunderstorm came through the area in the early hours of the morning and dropped no more than .25 inches.

15 June 2012. EPA continued to monitor and document cleanup activities. START-3 took pH levels of the ditch along Hightland Drive, inside Shawnee Creek, and containment measures on-site. Fifth hopper car, car # FMLX 52066, was emptied and moved across to empty hopper car staging area, west of Highland Drive. Excavation of contaminated soil was observed, and all soil removed from incident location was transported and stored on-site for disposal. Sixth hopper car, car # FMLX 52020 was moved further up the railroad easement towards Highland Drive for easier access for auger crews. A seventh hopper car, car # FMLX 51360, was rolled over in an attempt to empty contents for excavation, and moved further up the railroad easement towards Highland Drive so auger crews can remove the rest of the contents. A disposal site was identified for contaminated water in frac tanks. Water will be transported by Cheney Trucking to Agricultural Services, Inc. 301 West Louis Street, Hutchins, TX 75141. Maximum pH levels observed by START-3 in Shawnee Creek was pH 8, highest pH found at derailment site was pH 11 (inside containment trench). A late afternoon thunderstorm skirted east of the job site and dropped just a trace amount of rainfall on the site.

During 16-18 June 2012, EPA continued to monitor and document cleanup activities. START-3 took pH levels of the ditch along Highland Drive, inside Shawnee Creek, and containment measures on-site. Hopper car numbers five (FMLX 52066), six (FMLX 52020), seven (FMLX 51360), eight (TGSX 443526), and nine (FMLX 51106) were emptied and moved to empty hopper car staging area, west of Highland Drive. Excavation of the site to remove released soda ash and contaminated soil began, all soil and soda ash removed from site was staged at a bermed, poly lined area and covered with visqueen to prevent water infiltration. 

During 18-25 June 2012, EPA continued to monitor and document cleanup activities. RP contractor activities included maintaining containment measures on site, excavation of derailment site, and CRA conducted field pH testing of soil to ensure proper area and depth was being achieved. All soil was staged on-site for removal in a bermed, poly lined area and covered with visqueen to prevent rain water infiltration. On 20 June 2012, CRA took soil samples which were analyzed by Pace Analytical Services, Inc. located at 400 W. Bethany Rd., Suite 190, Allen, Texas, 75013: (972).727.1123. Sample results indicated a high pH in several locations. RP contractors re-excavated the area in an attempt to remove contaminated soil. OSC McAteer and START-3 observed empty hopper cars being cut into 18”x18” sections by RP contractor Progress Rail Services Corporation, utilizing a cutting torch. All metal sections were transported off site to a scrapping facility in Oklahoma.

On 25 June 2012, EPA continued to monitor and document clearnup activities. Remediation activities expanded to areas beneath new rail line due to possible soda ash in the base material. RP contractors utilized an undercutter to remove soda ash and contaminated soil beneath the new rail line. During undercutting activities, two (2) areas were noted for having high amounts of soda ash underneath the track. After undercutting of an area was completed, RP contractors flushed the track with a pH 4 solution of sulfamic acid and water. All flush water was collected and staged onsite in frac tanks for removal. Backfilling of the area beneath the rail line utilizing ballast rock was completed to re-open the rail line.

During 26 June through 5 July 2012, EPA continued to monitor and document cleanup activities. RP contractors removed the interceptor trench located along the eastern edge of the derailment site, and created smaller containment measures for high pH water seeps observed in the area. RP contractors began backfilling the derailment site utilizing soil obtained from a local quarry, excavators, trucks, a bulldozer, and a compactor. Backfilling of the derailment site was completed on 5 July 2012.

During 6-7 July 2012, EPA continued to monitor and document cleanup activities. RP contractors constructed a permanent containment measure utilizing excavators, trucks, and a bulldozer along the derailment site to mitigate possible off site migration of elevated pH runoff that may occur during a rain event. Containment measure consists of a trench dug into compacted clay along the incident location approximately six (6) feet wide and sloping from two and a half (2.5) feet down to ten (10) feet at the lowest points, and the trench was filled with ballast rock. At each low point, a sump was installed with automated pumps to remove elevated pH water from the trench to a staged frac tank on-site. The frac tank is equipped with a sensor which notifies RP contractors when the frac tank needs to be emptied. The containment trench extends approximately 140 yards across the length of the derailment site.

On 10 July 2012, START-3 visited the site to monitor and document cleanup activities. After a significant rain event, a seep of pH 11 liquid was observed approximately ten (10) yards east of the containment trench, and a large seep of pH 11 water was observed approximately fifty (50) yards east of the containment trench. Both high pH seeps migrated directly into Shawnee Creek. OSC McAteer notified RP via e-mail stating the EPA considers this to be the second release of a pollutant/contaminant to the waters of the United States, and RP needs to mitigate discharge of contaminants to Shawnee Creek. RP contractors constructed containment measures around both seeps utilizing hand held tools, and used powdered sulfamic acid and a pH 2 solution of sulfamic acid and water to neutralize the high pH liquid before discharging to Shawnee Creek. The containment measures were intended to prevent liquids from entering Shawnee Creek. 

During 11-17 July 2012, START-3 continued to make site visits to monitor and document cleanup activities. RP contractors continued remediation activities and extended the containment trench east approximately one-hundred (100) yards. The total length of the containment trench is approximately two-hundred and forty (240) yards. Surveying of the area was conducted by CRA, and RP contractors used hand held tools to excavate along the rail line to evaluate if elevated pH liquid extended past the existing containment measures. No areas were observed to indicate high pH liquid had migrated further east of the existing containment. UP contractors began disposing of contaminated soil staged on UP property at Waste Management’s Hillside Landfill located at 1102 Nelson Road, Sherman, Grayson County, Texas, 75091. Subsequently EPA released START-3 from the incident.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)