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Executive Summary
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On 7/2/14 a Hotline report of a release of ethyl acetate (EA) was received in the Region II REOC. The report stated that the release, amounting to approximately 27,000 lbs, occurred from chemical storage tank over a period of time from 6/19/14 to 6/23/14.
OSCs on duty in the REOC reviewed the NRC report and decided to investigate the cause of the release as well as the seeming delay in discovering the release of a highly odoriferous chemical like EA. On July 2, 2014 two OSCs visited the site to inspect the scene and interview facility management regarding the circumstances leading up to the release and its discovery 5 days later. Facility management explained that the release was from a recently installed double compartmented, horizontal storage tank. Management stated that although the tank had been in service for a few months, there was no approved SOP for tank operations and very little training had been done to familiarize operators with the new tank.
The situation on Thursday, June 19, 2014 was that on the Third (night time) shift one compartment in the tank was partially filled with EA, while the other compartment was empty and being steam-cleaned. It was explained to the OSCs that the steam cleaning process normally took 3 or 4 hours to thoroughly decon the interior. Third shift workers going off duty failed to inform the in-coming Friday morning First shift that the tank was being steam-cleaned, consequently the steam was kept on the empty compartment all day Friday and over the weekend for 5 days, not the normal 3 to 4 hours. The prolonged contact of hi-pressure steam on the uninsulated, bifurcating tank wall for five days resulted in heat transfer from the empty compartment, through the dividing wall and into the adjoining compartment of EA. The EA eventually reached its boiling point and EA vapors were released through the atmospheric top-vent over a five day period. The release apparently went unnoticed until a truck arrived to pick up a load of EA. When the liquid level in the tank was checked prior to loading the truck the missing volume was observed and measured. When the amount of missing EA was calculated the facility noted that the RQ had been exceeded and notified the NRC on July, 1, 2014.
As a result of the visit by the OSCs, the facility is revising its tank cleaning procedures and theSOP pertaining to continuing process operations that span shift changes. Although these revisions had been contemplated by facility management since the release, the EPA visit convinced management to redouble its efforts to formalize the needed revisions and implement them immediately to reduce the risk of future accidental releases into the environment.
Based on the circumstances leading up to the release of a listed CERCLA hazardous substance, a referral of this matter was made to enforcement personnel within the Region II Response and Prevention Branch.
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1. Introduction
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1.1 Background
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Site Number: |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
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Response Authority: |
CERCLA |
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Response Type: |
Emergency |
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Response Lead: |
PRP |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
7/2/2014 |
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Start Date: |
7/2/2014 |
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Demob Date: |
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Completion Date: |
7/2/2014 |
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CERCLIS ID: |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
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1.1.1 Incident Category
Release of CERCLA Hazardous Substance.
1.1.2 Site Description
Hazardous waste treatment facility.
1.1.2.1 Location
Facility is located in an industrial area bordering on a commercial/residential area.
1.1.2.2 Description of Threat
Air release of more than 27,000 lbs. of ethyl acetate.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
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1.2 Incident Objectives
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No information available at this time.
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1.3 Critical Resource Needs
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No information available at this time.
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1.4 Strategic Considerations
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No information available at this time.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
2.1.2 Response Actions to Date
Other than the July 2, 2014 inspection by two Region II OSCs and a possible enforcement action (see below) no further response action is anticipated.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Based on results of an on-site inspection and interview with facility personnel this matter has been referred internally for possible enforcement action. The PRP is identified as Veolia Environmental Services.
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Disposal |
| ethyl acetate |
air |
3000 lbs |
released to air |
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2.2 Planning Section
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2.2.1 Anticipated Activities
None.
2.2.1.1 Planned Response Activities
See Operations Section
2.2.1.2 Next Steps
2.2.2 Issues
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2.3 Logistics Section
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No information available at this time.
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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No information available at this time.
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3. Participating Entities
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No information available at this time.
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4. Personnel On Site
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No information available at this time.
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5. Definition of Terms
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No information available at this time.
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6. Additional sources of information
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No information available at this time.
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7. Situational Reference Materials
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No information available at this time.
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