1994 International
Hazardous Material Spills Conference
October 31 - November 3
Hyatt Regency Hotel
Buffalo, New York
Case Studies
Sponsored by
National Response Team
National Governors' Association
Chemical Manufacturers Association
American institute of Chemical Engineers
In Cooperation with
Canadian Chemical ProducersAssociation (CCPA)
Asociacion Nacional de la Industria Quimica (ANIQ)
The New York State Emergency Response Commision
Developed by the Chemical Emergency Preparedness and Prevention Office
in cooperation with the agencies of the National Response Team
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Case Studies 1994 International Hazardous
November 1994 i Material Spills Conference
CASE STUDIES INTRODUCTION
Acknowledgements - Without: the efforts of the presenters in developing the case studies,
this outstanding learning opportunity would be lost. Their reflection and development
of a presentation demonstrates a commitment to enhancing preparedness.
Introduction - Experience is an excellent teacher and emergency responders learn from
every response. These case studies are intended to allow others to share in that
experiential learning process. The case studies'were developed by individuals in
leadership positions during the response. As such/ reade1^"aTe^ff6Tdea~an opportunity"
to share in the decision process and see the results. These case studies reflect the
observations and opinions of those individuals. In some cases, the study focuses on an
element of the overall response effort to allow a derailed examination of a situation and
the response. \ • •
The case studies are structured to provide an introduction, background, problem,
response and epilogue. To improve your understanding of the cases, a list of key players
is provided on the first page. A set of discussion questions is provided to stimulate
discussion and simulate the decisions faced by the players. The cases are:
Forest Glen Community Intervention
Mr. Les Radford, Mr. Michael White, Ms. Cheryl Irish-Jagow,
and Ms. Helen Sumbler
World Trade Center Bombing 7
Officer John J. Luffey and Officer Stuart N. Goldstein
Colonial Pipeline Response „.. .. 13
Mr. Kevin Koob
The Divex Explosives Site . 27
Mr. Christopher A. Militscher
M/V Astra Peak Response ......:... 37
LTJG William K. Capune \
Case Studies Introduction
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1994 International Hazardous Material Spills Conference • Case Studies
Additional Training - All cases were provided to allow conference attendees to review
the other cases presented. In addition to reviewing cases not attended, they can be used
at a later date as a training tool. Each case has elements which will apply to other
responses. While some aspect of a response will differ, many will be common. Work
through the cases with others on your staff and use; the discussion questions as
opportunities to explore your response strategies. ;
These cases were prepared by the presenters and assembled by the Environmental
Protection Agency Chemical Emergency Preparedness and Prevention Office.
page a . Case Studies Introduction
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Case Studies
November 1994
1994 International Hazardous
Material Spills Conference
FOREST SLEN COMMUNITY INTERVENTION
Introduction
Les Radford, Preparedness Directorate, New York State Emergency Management Office, Albany, NY
Michael White, Niagara County Department of Mental Health, Alcohol and Drug Abuse, Lockport, NY
Cheryl Irish-Jagow, Niagara County Department of Mental Health, Alcohol and Drug Abuse, Lockport, NY
Helen Sumbler, Resident, Forest Glen
This case was prepared for use as a tool to
foster greater understanding of chemical
emergencies and emergency response.
Cases are intended to be used as a basis for
discussion. Each is based on actual
situations, but the presentation may focus
on one aspect of the response for the.
purpose of discussion and instruction.
The Players
State and local organizations
> New York State EmergencyManagement
Office (SEMO)
> Niagara County Department of Mental
Health
U.S. Government Agencies
*• Federal EmergencyManagementAgency
(FEMA)
> U.S. Environmental Protection Agency
(EPA)
INTRODUCTION
The Forest Glen subdivision, located in Niagara County, New
York, was originally a wooded wetland area. The area was used
for the disposal of industrial wastes and other materials during the
1960's into the early 1970's. In 1973, the property was divided
into mobile home lots and became home to approximately 156
people. Many of the families and individuals who lived at Forest
Glen viewed this as their retirement homes. There were strong,
interwoven friendships which gave them a sense of community.
In 1980, the Niagara County Health Department discovered
chemical wastes in the soil. The contaminated soil was excavated
and disposed off site that same year. In 1987, the U.S. EPA
discovered numerous volatile organic compounds, semi-volatile
organic compounds and inorganic compounds in the soil. In July
1989, a preliminary health assessment concluded that there was
significant risk to human health. The site was listed on the
National Priorities List in November 1989 and relocation of the
residents was proposed.
There was widespread fear and anxiety associated with the
potential health impacts and relocation from established
community. Intervention of local mental health professionals
established effective communication and fostered recovery at the
individual and community level.
This case study discusses the need for a coordinated responder
voice and a heightened understanding of the need for emotional
support through psychological intervention for the affected
members of the community.
Forest Glen Community Intervention
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FOREST GLEN COMMUNITY (INTERVENTION
The Response
BACKGROUND
The Forest Glen subdivision was originally wooded
wetland area. Sometime in the mid 60's the area
was cleared of trees. Materials, primarily
consisting of industrial wastes were disposed at the
site until the early 70's. In 1973, the property was
subdivided into mobile home lots. Approximately
156 people resided in 53 homes in the Forest Glen
community. .
Many of the families and individuals who lived at
Forest Glen had viewed it as their retirement
homes. They had selected Forest Glen for two
main factors. It provided them with an affordable
opportunity to own their homes, including the
land, and their interwoven friendships provided a
sense of community.
In 1980, the Niagara County Health Department
collected soil samples and discovered they
contained chemical wastes including PVC dust and
resinous phenolic and cellulose compounds. The
contaminated soil was excavated and disposed off
site the same year.
In 1987, the U.S. EPA inspected the site.
Additional soil samples contained numerous
volatile organic compounds, semi-volatile organic
compounds and inorganic compounds. In July
1989, a preliminary health assessment concluded
that there is a "significant risk to human health for
persons living on the Forest Glen subdivision site".
The site was listed on the National Priorities List in
November 1989.
THE PROBLEM
In light of the contamination detected, relocation
of the residents had been under discussion for
approximately 10 years prior to the decision.
Discussion of relocation was especially traumatic
to the residents as it would impact the sense of
community which had developed.
Frustration among members of the Forest Glen
community increased during discussions of
relocation. The lack of consistency among the
governmental agencies working with the residents
fed the stre:ss and fear within the community.
Agencies had representatives (sometimes several)
^B§§R!ESj9]^§iLoM! agency, however there was
no single individual or organization integrating the
positions of the multiple agencies.
In November 1990, the Niagara County
Department of Mental Health was contacted by
Margaret Guiliani of S.T.O.P.I.T. (Society To
Oppose Pollution In Towns). Her request for
community support included concerns that some
members of the community were expressing anger
and discussing violence as a means to an end. Mr.
Philip Murray, then County Mental Health
Director, arid Cheryl Irish-Jagow a Community
Mental Health Aide with the Department, met with
the citizens of Forest Glen. Out of that meeting
developed the partnership of Mental Health
support and self-help that defused much of the
disabling impact and turned their energies to
healing.
The Niagara County Department of Mental Health
entered the process with input from angry residents
and advocates. No input was available at that time
from governmental organizations involved in the
process. It was difficult to sort out what was real
information related to problems and perceptions
and what in fact was false information generated
by fear and rumor. Our experience confirmed the
frustration of not knowing who was responsible for
what and how we work together as a team to
correct: the problem.
The residents of Forest Glen experienced
heightened ; anxiety, depression, frustration and
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Case Studies
anger as a result of the environmental disaster in
their neighborhood and the community's
perception of helplessness,
The stages of negative impact included:
e Knowledge that testing of the soil had
occurred for ten years with little feedback to
the residents. The residents v/ondered if the
information which was shared, was accurate.
• Announcement that voluntary relocation was
advisable but help in negotiating the process
was available only on an individual basis,
_ fostered rumor and division.
® The perceptions associated with the individual
settlements coupled with inconsistent and
often illogical settlements further fostered
suspicion, mistrust and dissension.
© The big questions for residents;
How sick am I?
What is going to happen to me?
What can I do for myself?
» The answers to the big questions were
sometimes contradictory, vague and
frustrating.
e Secondary and impactful stressors were the
major sense of loss associated with relocating
away from friends, supporters and community.
The Department of Mental Health discovered a
complete lack of open communication between
participating governmental agencies and a lack of
understanding of community anger. Many
governmental representatives continued to rely on
their experience in public domain relocation, such
as sewer construction and highway development,
and appeared confused as to why this community
would need to be dealt with differently.
At this point, intervention by Mental Health
professionals was absolutely necessary to refocus
on healing and preservation of self esteem and self
worth. The consensus community request was to
be relocated together, attempting to maintain the
familial'relationships that had developed.
RESPONSE
When contacted in November 1990, our office
took immediate action to deploy a creative and, for
us, a unique community intervention. We sent
three staff members to the site once per week to
do group, and individual meetings.
On December 10, 1990 the first group meetings
were held at the Forest Glen Site. Our staff did
preliminary measurement for depression utilizing
a Beck ilnventory so that, at the end of the process,
~^e~w^ld"n3e~abTe"n:6~f6Tlcw^^
improvement. The focus of'these group and
individual sessions were to provide a forum for
venting, an opportunity to coordinate information.
and education in methods to deal with stress,
depression and lack of trust.
i
The ability to respond to a clear Mental Health
need was complicated by state and local admission
limitations.. Most specifically, an individual must
be diagnosed with a mental illness and admitted to
a clinic program. It was assessed by the team
assigned to Forest Glen that to subject the residents
to labels of Mental Illness would contribute to
further, heighten their fears of isolation. They
already felt physically sick and contaminated,
manifesting in symptoms of lowered self-esteem
and having a sense of little hope or worth.
Consequently, Niagara County Mental Health was
"at risk" of receiving no financial support for this
critical intervention.
In Fall 1991, the various agencies, EPA, SEMO,
and FEMA all agreed that our intervention was
needed. The implementation and provisions for
reimbursement were unknown and in fact were not
sorted out until 1994.
Because contract support could not be paid, this
intervention was performed by Niagara County
mental health staff diverted from other
responsibilities. This diversion impacted other
departmental functions.
Forest Glen Community Intervention
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1994 International Hazardous Material Spills Conference Case Studies
The intervention consisted of:
* First contact by S.T.O.P.I.T. to Director of
Community Service.
• Department of Mental Health Director met
with residents to articulate mental health
support needs and services.
• Mental Health staff (Supervising Social
Worker, Hot-Line Coordinator and
Community Mental Health Aide) assigned to
Forest Glen special project.
© Group and individual counselling, sessions
held for 15 month period (December 1990 to
March 1992). Initial group session was held
on-site at EPA field office and dealt with
trauma, frustration, fear and anger. Providing
36 sessions for groups ranging from three to
eight individuals totalling approximately 1224
contact hours.
* For individuals who had previous Mental
Health issues or whose problems exceeded
the community interventions limitation, we :
facilitated admission to Mental Health clinics
and support groups. We continue to monitor
individuals who have been admitted to Clinic
Treatment, even today!
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Case Studies
FOREST GLEN COMMUNITY INTERVENTION
Discussion Questions and Epilogue
DISCUSSION QUESTIONS
1. How should Mental Health services be
involved in a disaster related relocation?
2. At what point should Mental Health services
be integrated into the disaster response
process?
3. What mechanisms exist to fund the costs
associated with Mental Health services
provided to a community?
4. Who should provide Mental Health support at
the community level?
5. What strategies between participating agencies
are necessary prior to introduction to the
community?
6. How could Mental Health concerns be
integrated into the local, state and Federal
emergency planning process?
EPILOGUE
The Mental Health Community Intervention at
Forest Glen remained until the last participant was
relocated. Some of the individuals from Forest
Glen still receive Mental Health services; others
are in need but can not be located. This latter
group1 was relocated prior to our arrival and had
not been tracked for location or follow-up by the
various governmental agencies.
Based on the experience at Forest Glen in Niagara
Falls, New York, a Mental Health program
component should be included at every disaster
related relocation. To this end, we recommend
that the Mental Health component be built into
relocation budgets and contracted for at the
beginning of any future project.
The fear and anxiety associated with unknown
impacts on an individual's health and well being
quickly escalates when complicated by mis-
communication, lack of coordination or the
appearance of insensitivity on the part of the local,
state'and Federal responders. This delays the
process and prevents the participation of the
community in planning for the relocation.
A coordinated team approach, including Mental
Health representatives, will decrease community
anger, fear, mistrust and hostility and improve
community participation, understanding and
support, if introduced early and sustained through
the entire response.
Forest Glen Community Intervention!
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1994 International Hazardous Material Spills Conference : Case Studies
FOREST GLEN COMMUNITY IRSTERVEiyTIOiy
Notes
Page 6 Forest Glen Community Intervention
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Case Studies
November 1994
1994 International Hazardous
Material Spills Conference
WORLD TRADE CENTER BOMBIRSG
Introduction
John J. Luffey, Office of Emergency Services, New York Police Department, New York, NY
Stuart N. Goldstein, Office of Emergency Services, New York Police Department, New York, NY
This case was prepared for use as a tool to
foster greater understanding of chemical
emergencies and emergency response.
Cases are intended to be used as a basis for
discussion. Each is based on actual
situations, but the presentation may focus
on one aspect of the response for the
purpose of discussion and instruction.
The Players
City of New York
> Department of Environmental Protection
* Department of Health
> Emergency Medical Services (NYC-EMS)
» Fire Department (FDNY)
> Medical Examiner
* Office of Emergency Management
(OEM)
>• Police Department (NYPD)
State of New York
»• Port Authority of New York and New
Jersey
> State Emergency Management Office
U.S. Government Agencies
> Bureau of Alcohol, Tobacco and
Firearms
*• Federal Bureau of Investigation
> Occupational Safety and Health
Administration
INTRODUCTION
Terrorism occurs somewhere around the world almost daily. It's
origins can be religious or political. In America, we have learned
that terrorism is an act which occurs somewhere else, until just
after noon on February 26, 1993, an explosion of unknown cause
rocked the World Trade Center in New York City.
In addition to the city responders, other local, state and federal
response personnel were involved in the response effort. Because
of the number of responders, a number of coordination issues
required resolution.;
New York City's emergency responders were put to the ultimate
test. Faced with coordination of an emergency producing over
1,000 patients and a federal, state and local law enforcement
response; coordination was paramount.
Good interagency coordination involves good interagency
communication. Good coordination does not start at an
emergency scene, it should start as soon as the responder is
notified about the emergency.
This case discusses coordination issues facing responders.
Learning from this case will further planning efforts.
World Trade Center Bombing
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Case Studies
WORLD TRADE CENTER BOMBING
The Response
THE RESPONSE ORGANIZATION
The Emergency Management System for the City of
New York consists of two component, the Mayor's
Emergency Control Board and the Office of
Emergency Management.
The Mayor's Emergency Control Board has the
responsibility for ensuring the effective use of all
city resources during an emergency. The
Emergency Control Board consists of:
The Mayor - Chairperson
Police Commissioner - Director
Mayor's Director of Operations
Deputy Mayors
Commissioners from appropriate agencies
Executives from private and voluntary
organizations (Red Cross, telephone, utility)
The Office of Emergency Management is the
administrative arm of the Emergency Control Board
and is responsible for creating, maintaining and
updating plans and procedures to ensure the most
effective and coordinated response of city agencies
during an emergency. In this capacity, the Office
of Emergency Management responds to
emergencies, notifies appropriate agencies,
implements interagency plans, and acts as the
liaison between the city and the police On Scene
Coordinator.
BACKGROUND
The World Trade Center consists of two 110 story
office towers, a 47 story office building, two nine
story office buildings, an eight story U.S. Customs
House, and the 22 story Vista Hotel. The two
office towers, each rising 1,350 feet, are the tallest
buildings in New York City. These seven buildings
were constructed around a five acre plaza. All
buildings have entrances into the plaza.
In addition to the buildings, the World Trade
Center's Concourse, located immediately below
the plaza, is the largest enclosed shopping mall in
Manhattan. The World Trade Center also has a
below grade parking garage that holds 2,000 cars,
a New York City Subway System and a Port
Authority Trans-Hudson Train System between
New York City and New jersey.
Approximately 60,000 people work in the World
Trade Center complex with another 90,000 visitors
each day.
On February 26, 1993 at approximately, 1218
hours, New York City's 911 system was
overwhelmed with calls about an explosion that
rocked the World Trade Center. A major
interagency response took place with Police, Fire
and Emergency Medical Service responding to the
scene.
The New York City Office of Emergency
Management has an Agency Liaison Emergency
Radio Trunk (ALERT) frequency. This is a single
frequency (800 MHz) that significant emergency
respondlers carry.as an additional frequency in their
personal radio. This system allows for
communications between the various emergency
response agencies when operating at emergency
scenes.
When the explosion occurred, everyone thought
an electrical 'transformer exploded. Initially, the
loss of power and the smoke throughout the
building supported that assessment.
The first thing considered when a transformer
explodes are PCBs, (Polychlorinated Biphenols).
The NYPD Mobile Decontamination Vehicle was
dispatched in case decontamination was required.
It was not till hours later when the responders
discovered the transformers were fine. Interesting
enough,, the New York City Department of
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Environmental Protection Hazmat Response Unit
stated that the transformers were fine. We iall
began to wonder, what happened. At that time the
explosion was determined to involve a bomb.
The blast tore a 130 foot by 120 foot hole in the
garage. The damage was centered at the B-2 level
and extended two floors up through B-1 into the
Vista Hotel dining area. The blast extended down
three floors to the B-5 level.
Investigation revealed that the bomb was a
sophisticated device placed in a van. The bomb
involved, was planted on level B-2.
PROBLEMS
A number of problems were identified during the
initial response. These included:
® Emergency resppnders couldn't get to the
scene because of major traffic congestion
problems.
® There were three classes of school children
missing in the building.
e The building was open for business and
totally occupied.
e Power outages had occurred throughout the
complex.
e Sometimes, cellular phones did not work,
giving only busy signals.
As the response effort matured, other problems
surfaced.
• Extensive flooding in the basement as a result
of pipes which were ruptured by the blast.
Almost two million gallons of water collected
in the basement after the blast.
® There was asbestos in certain locations in the
building.
« Our radios did not work below grade. ••
• To reduce the impact on the surface
transportation system, certain agencies wanted
to! reopen key streets. This was not
immediately possible because it would hinder
the Criminal Investigation.
® Emergency vehicles would break down over
time.
o The impacts to the city transportation systems
in the area of Lower Manhattan affected
thousands of commuters.
THE RESPONSE
A Primary Interagency Command Post was
established on the front steps of the Vista Hotel.
Following the arrival of the mobil Command Post,
the Primary Command was relocated.
To provide perimeter control, Borough Task Forces
(a pre-designated NYPD crisis response
organization) were ordered to the scene from each
of the seven boroughs of New York.
The Brooklyn Battery Tunnel was closed to the
public. Traffic was rerouted to the Brooklyn
Queens Expressway.
Interagency radios were handed out to significant
response personnel. This provided a "backbone"
communication system for all significant
respqnders.
All subway service was stopped to the World
Trade Center Complex. Subway trains were
detoured to avoid the tracks under the World
Trade Center.
Hard wired phone lines were installed in the
command posts.
Command posts were provided electrical power
from Consolidated-Edison, eliminating the reliance
on generators.
Hard-line phones were put into the crater area for
communication with the Command Post.
World Trade Center Bombing
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1994 International Hazardous Material Spills Conference Case Studies
[
We found a safe, convenient meeting room. This
allowed coordination and planning meetings to
occur outside the command post, so the responders
were able to focus on the planning issues. :
Interagency meetings took place regularly.
We kept the same responders to do the work. This
enhanced the continuity of the interagency
operation.
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WORLD TRADE CEiTER BOMBING
Discussion Questions arid Epilogue
DISCUSSION QUESTIONS
1. What alternatives to cellular phones exist as
secondary communications systems?
2. How would your community accommodate a
requirement to reroute a significant proportion
of the mass transit commuters?
3. In the World Trade Center bombing, initial
assessments suggested a transformer
explosion. How does your organization
handle such preliminary damage assessments?
How accurate are they?
4. How would your community meet the
challenge of supporting the continued
operations of firms with 60,000 employees?
What do the plans say? What facilities exist?
EPILOGUE
A number of issues were identified which resulted
in changes to plans and procedures. These issues
can also be considered by other organizations in
their planning. These include:
Radios - When the 911 system was flooded by
calls about the World Trade Center, the primary
emergency responders could not establish radio
contact with the Port Authority Police. We learned
there was no Interagency Radio Contact with the
Port Authority Police. To correct this, they were
put on the OEM Alert Frequency.
Cellular Telephones - During the response, the
local cellular phone cells were overwhelmed,
eliminating use of the cellular phone as a back-up
for the radio. While the possibility of getting a
cellular site dedicated to interagency emergency
responders (pending), the 800 MHz ALERT
frequency offers a telephone interconnect which
can be used with our Motorola Radios.
Flooding - Almost two million gallons of water
collected in the basement, after pipes ruptured. To
further the response, the water had to be removed
from the basement. The responders learned that
numerous agencies had resources which were
available. Many of these agencies were not on
emergency resource lists. We needed to update
our resource list.
Communications Below Grade - We tried to talk
below grade, into the World Trade Center, on our
800 MHz radios. We learned that our radios did
not work in certain parts of the World Trade
Center. The immediate remedy was the
establishment of point-to-point relays from the
outside to the inside of the building. The
permanent solution resulted installation of radio
repeaters in the World Trade Center.
Vehicle Maintenance - During the response,
emergency vehicles would occasionally break
down at the scene of the World Trade Center.
This resulted in disruptions and logistical concerns.
Later in the response, vehicle maintenance
personnel remained on site maintain and repair
response vehicles. Keep a tow truck and extra
vehicle parts on site too. For responses of long
duration, have vehicle maintenance personnel
make periodic visits to the scene, to check and
repair vehicles as necessary.
Interagency Meetings - Because of the complexity
of the response, frequent interagency meetings
were needed. We needed a conference room
which was large enough for all agencies, close to
the scene, secure from the public, and had 24 hour
accessibility. During the World Trade Center
response, the American Express Travel Offices
donated a large conference room. This office was
located across the street and was open 24 hours.
World Trade Center Bombing
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WORLD TRADE CENTER BOMBING
Notes
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Case Studies
November 1994
1994 International Hazardous
Material Spills Conference
COLONIAL PIPELINE RESPONSE
Introduction
Kevin Koob, Emergency Response Branch, EPA Region III
This case was prepared for use as a too! to
foster greater understanding of chemical
emergencies and emergency response,
Ca$e?-are--ir>tendedjtD-bejjsedLasja basis for
INTRODUCTION
At 0848 hours on jthe morning of March 28, 1993, a rupture
occurs in a 36-inch oil pipeline. The pressure release from the 42-
inch gash in the pipeline causes a 100-foot geyser of number two'
fuel oil in Reston, FairfaTTountyT Virginia. Pipeline control"
instrumentation detects the pressure drop caused by the release
and begins shutdown operations. Even with the damaged pipe
section shut down, discharge continues due to pipeline drainback.
Local responders are the first to identify the location of the release
and to begin oil containment operations. The pipeline operator
mobilized personnel in response to the release. A federal
response is initiated by the U.S. EPA, Region III and the Baltimore
Marine Safety Office of the U.S. Coast Guard.
The released oil impacts the swollen Sugarland Run and begins a
nine mile journey towards the Potomac River upstream of
Washington, DC. The pipeline owner (PRP) receives a Notice of
Federal Interest and'signs the order accepting full responsibility for
the recovery and cleanup of the released oil. A Federal Pollution
Number is issued^ for the emergency response due to the
magnitude of the release and to prepare for contingencies in case
of later default by the PRP. Emergency response operations
involve up to 39 Federal, state, and local agencies and cross many
jurisdictional boundaries.
This case will address the complexities of coordination and
planning associated with an interagency, multi-state response.
discussion. Each is based on actual
situations, but the presentation may focus
on one aspect of the response for the
purpose of discussion and instruction.
The Players
U.S. EPA
> EPA Region 111
>• Technical Assistance Team (TAT)
Responsible Party (RP)
»• Colon ial Pipeline Company
U.S. Coast Guard (USCC)
> Atlantic Strike Team (AST)
> Gulf Strike Team (GST)
> Marine Safety Office (MSO)
*• National Strike Force (NSF)
State and local organizations
> Fairfax County Fire and Rescue
> Fairfax County Health Department
> Fairfax County Water Authority (FCWA)
> Loudoun County Fire and Rescue
* Loudoun County Health Department
>• Virginia Department of Environmental
Quality
> Virginia Water Control Board
U.S. Government Agencies
> Department of the Interior
> Department of Transportation (DOT)
> National Transportation Safety Board
(NTSB)
> U.S. Fish and Wildlife Service (USFWS)
Colonial Pipeline Response
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Case Studies
COLONIAL PIPELINE RESPONSE
The Response
BACKGROUND
The Colonial Pipeline oil spill was the result of a
failure in a 36-inch petroleum pipeline operated by
Colonial Pipeline Company which extends from
the,Gulf of Mexico to Maine, along the East Coast.
The failure caused number two heating oil to be
ejected through the top wall of the pipeline 100
feet into the air. The discharged fuel oil flowed
from the break to the Sugarland Run Creek, a
tributary of the Potomac River. An estimated
407,436 gallons were released into the
environment from the pipeline during the rupture
event. An additional 100,000 gallons were
recovered directly from the inactivated pipeline
after pressure on the pipeline had been relieved.
Pipeline operation is under the jurisdiction of the
U.S. Department of Transportation.
First reports of the spill were received by the
National Response Center (NRC) at 1004 hours on
28 March 1993. The NRC then contacted the
USCG Marine Safety Office (MSO) in Baltimore,
Maryland. The MSO duty officer dispatched a
Coast Guard pollution response team to the scene.
The U.S. EPA Regional Response Center (RRC) was.
contacted at 1010 hours. The RRC duty officer
notified OSC, Kevin Koob, who dispatched the EPA
Technical Assistance Team (TAT) to the scene.
Enroute to the scene, the OSC contacted the USCG
Atlantic Strike Team (AST) and alerted the duty
officer of the potential for a Strike Team activation.
The OSC and TAT arrived on scene at 1415 hours.
The OSC encountered an established command
structure at Fairfax County, Virginia, upon his
arrival. When it became apparent that the release
extended beyond the boundary of Fairfax County,
and potentially beyond the boundary of the
Commonwealth of Virginia, exceeding the
response capabilities of the local and state
authorities, the OSC assumed control of the
response.
After a transitional period, the OSC established a
Unified Command based upon the existing
command structure.
THE PROBLEM
The OSC was faced with the responsibility to
coordinate a multi-state, interagency response. In
addition, because of the proximity to Washington,
DC and agency headquarters, the response enjoyed
high visibility.
THE RESPONSE
The initial break in the pipeline was located
between the Reston Hospital Center, Reston,
Fairfax County, Virginia near the Loudoun County
line. The oil entered Sugarland Run through a
storm water drain passing under Carlisle Drive.
Approximately nine miles of Sugarland Run was
affected by the spill as was the Potomac River as
far south as Mount Vernon.
The first Federal responder on site was dispatched
from the Baltimore MSO by the Baltimore Captain
of the Port, Captain Ron Edmiston. This responder
issued a Letter of Federal Interest to Colonial
Pipeline Company. Colonial agreed to take all
necessary measures for the mitigation of the release
and hired several contractors to begin emergency
containment and recovery operations. A unilateral
order was issued within four days of the release to
Colonial by EPA Region 111.
Upon arrival on scene, the OSC was apprised of
the situation and encountered a fully developed
Incident Command Structure lead by Fairfax
County Fire Department. The OSC began the
transition to a Unified Command incorporating
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representatives from the impacted states (Virginia,
Maryland and the District of Columbia) and local
municipalities as well as the Colonial Pipeline
Company. Oil containment measures had been
implemented at four locations along the
immediately impacted waterway, Sugarland Run.
As the slug of oil progressed along the Sugarland
Run down to the Potomac River, additional Coast
Guard, Strike Team and EPA personnel were
mobilized to the site. The Regional Response
Team (RRT) Co-Chairman and Chief of EPA Region
111 Emergency Response Branch, Dennis Carney
mobilized to the scene and established an Incident
Specific RRT to help coordinate activities.
Additional containment areas were established.
Free product flow was contained in multiple
booms located at the confluence of Sugarland Run
and the Potomac River. The Potomac River was
receiving a substantial sheen. The spread of oil
brought with it the characteristic odor of fuel oil.
A periodic air monitoring program was established
for key areas along the spill route. Ad hoc
responses to citizens' odor complaints were
provided by the EPA's Technical Assistance Team.
Colonial mobilized a large contractor work force.
Tanker trucks were utilized to remove recovered
oil to offsite storage facilities. Vacuum trucks were
mobilized to recover oil and were then used to
pump it into waiting tanker trucks. A vacuum
truck recovery location was established at the
pipeline rupture site to contain the continued
pipeline drainback and eliminate any further
discharge. Two other vacuum trucks were
stationed at bridge crossings on Sugarland Run for
use in oil recovery from the behind booms which
had been established across the waterway.
While vacuum truck recovery locations were
achieving success upstream, the oil downstream
remained trapped and unrecoverable behind the
boom at the confluence of the Potomac River.
This location presented several challenges.
Saturated soil conditions and wooded areas
hindered efforts to move oil recovery equipment to
the containment area. At the same time, the
distance (3/4 mile) from the containment to the
nearest access for tank trucks had to be spanned.
The'1 water quality of the Potomac River was
severely impacted. The downstream municipal
water intake operated by Fairfax County Water
Authority (FCWA) was shut down due
contamination by the discharged fuel oil. FCWA
madte arrangements to borrow water from
surrounding jurisdictions. The water system
remained stable and the reopening of the Potomac
River intake became the highest priority.
Transportation of oil recovery equipment to the
mouth of the Sugarland Run was achieved by
airlift. A CH-46 helicopter was from the U.S.
Marine Corps Base at Quantico, VA was pressed
into service. The U.S. Marine Corps performed the
airlift of critical equipment safely and efficiently.
I
At 'the same time, Colonial was making
arrangements for the shipment of a temporary
pipeline which would be used to bridge the
distance from the Potomac Recovery area to tanker
truck loading and staging located near a small boat
ramp upstream from the Sugarland Run and
Potomac River confluence. Small boats were
utilized to ferry tanks of skimmed oil recovered
from behind the containment booms established at
the I confluence. These tanks were pumped into
tank trucks and shuttled to an off site oil storage
facility.
Construction of the temporary pipeline was
delayed and the Responsible Party's oil skimming
capacity was found to be insufficient to address the
demands of the immediate situation. Colonial
Pipeline's aggressive efforts to secure the additional
necessary equipment and materials was thwarted at
every turn because Colonial had exhausted the
regional inventories. The.OSC began to draw on
other Federal resources. Arrangements were made
with the Atlantic Strike Team for the supply of
additional skimmers and booms. At the same time,
thq Navy Supervisor of Salvage assessment
personnel were mobilized on scene. Additional
Navy Salvage skimming equipment and floating
pipeline were eventually pressed into service. The
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additional equipment and manpower resulted in
increased oil recovery. As the recovery increased,
the remaining oil layer became thinner and more
difficult to recover. The PRP requested permission
to use Elastol, a petroleum coagulant. The OSC
considered the request and in turn, petitioned the
RRT for permission to use Elastol. The RRT
granted approval for the use of Elastol in record
time due to the on scene presence of the RRT
members whose approval was required, per the
Local Contingency Plan, prior to the initiation of
any application of the material. As part of the
approval, the RRT established specific criteria and
conditions for Elastol's use. These included strict
documentation (video) and field testing before bulk
application. Field tests eventually resulted in the
limited use of Elastol at the Potomac Recovery
area.
Difficulties encountered during skimming
operations resulted in an increased amount of
water recovered with the oil. The Commonwealth
of Virginia was consulted in conjunction with the
Unified Command, and agreed to allow decanting
of water from tanker trucks. The decanted water
was returned to Sugarland Run above the Potomac
Recovery area. Decanting procedures increased
efficiency in recovered oil shipments to storage.
Upstream recovery operations were gradually
terminated due to lack of oil for recovery.
Absorbent boom was added to the containment
areas. Periodic inspections were performed,
including removal of accumulated oil and changing
soiled absorbent boom. At this point, work teams
were dispatched to patrol the spill route along the
Sugarland Run. These teams worked to flush any
trapped product from puddles or packets and send
it downstream for collection.
As the Potomac Recovery continued, sheening of
the Potomac decreased and eventually ceased.
Debris collection and removal operations under
the supervision of MSO Baltimore personnel were
terminated. A work crew was dispatched to the
FCWA intake to steam clean away any residual oil.
With this completed, FCWA reopened the intake
on April 8, 1993 at a limited capacity. The
reopening.-,: signaled the end of emergency
operations. The Colonial Pipeline Company
continued cleanup and restoration under a
Unilateral Administrative order issued \&y the EPA.
Colonial Pipeline Company signed the Unilateral
Order on April 9, 1993, and submitted a draft
Response Action Plan (RAP). The emergency
phase was completed on April 9, 1993, with
cleanup efforts continuing under the supervision of
the EPA and its contractors.
Agency Activities
Potentially Responsible Parties - PRP
representatives were served with a Notice of
Federal Interest at the scene of the oil release.
Officials for: the PRP signed the Notice and
accepted full responsibility for the mitigation of the
release. A large contractor force was mobilized to
perform clean up measures.
Federal Agencies -The U.S. EPA provided the OSC
for emergency response operations. The OSC
established a Unified Command Structure to direct
the response and facilitate the exchange of
information and ideas to be used in the clean up
effort. The U.S. Coast Guard supplied personnel
from the; Baltimore MSO, Atlantic Strike Team and
the Gulf Strike Team (GST), forming the National
Strike Force. USCG activities included the
supervision of site health and safety, dispersal of
funds, oil containment and recovery operations
planning, and the supply of oil recovery
equipment. The Captain of the Port, Baltimore
staffed and supervised the southern sector
operations on the Potomac River. The U.S. Marine
Corps provided a CH-46 helicopter to airlift vital
equipment necessary to establish and sustain
recovery operations at the confluence of the
Potomac River and Sugarland Run. The U.S. Navy
Supervisor of Salvage provided contractor
personnel and oil recovery equipment which were
instrumental in achieving and sustaining the high
rate oil recovery experienced during this response.
Additional Federal agencies and Natural Resource
Trustees were on site to offer technical support and
to begin the Natural Resources Damage
Assessment process.
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State and Local Agencies - Fairfax and Loudoun
County Fire and Rescue Departments provided the
initial oil containment measures and established
the initial incident command structure utilized later
as the basis for the Federally lead Unified
Command. These departments subsequently
provided support for EPA's 24-hour emergency
operations.
As the response progressed, representatives of the
Commonwealth of Virginia were on scene to
provide support, technical information and
equipment for sustained recovery operations.
Additionally, representatives from Maryland and
the District of Columbia were on scene to address
concerns of their jurisdictions. State and local
municipalities all provided representatives on the
Unified Command.
Contractors - The EPA's Technical Assistance Team
contractor was on site to assist the OSC with
managing cleanup effort. TAT assisted with site
communications and maintained site logbook and
photo documentation. TAT also conducted
ambient air monitoring in residential and work
areas along the spill route.
Due to the magnitude of the oil release, the
primary concern was the containment and recovery
of the released oil. Sampling was limited to oil
fingerprint analysis by the USCG for future
reference during cleanup efforts beyond the scope
of the emergency response. In addition, residential
well samples were collected by county health
departments to identify any initial impact on the
groundwater along the spill route.
Other significant events during the response action
are outlined below:
Day 1 - 28 March 1993
0848 Pipeline transporting number 2 fuel oil
ruptured and released product into
Sugarland Run, which feeds into the
Potomac River. Colonial Pipeline
officials noted a drop in line pressure and
shut off flow to the ruptured area of the
i pipeline.
1000 Fairfax County Fire and Rescue
confirmed the location of the spill. Initial
booming operations were performed at
several locations along the creek.
Downstream jurisdictions and water
intakes were contacted and apprised of
the situation.
1004 National Response Center (N RC) received
notification of the incident.
1010 EPA Regional Response Center (RRC),
Region III received notification of the
spill.
1200 EPA OSC Kevin Koob directed TAT to
mobilize to the incident scene after
receiving notification from the RRC duty
officer. On the way to the incident
scene, the OSC alerted the USCG
Atlantic Strike Team to the potential for
their activation and required presence on
scene.
1415 The OSC and TAT Fellinger arrived on
scene. The OSC requested the USCG
Atlantic Strike Team (AST) on scene after
receiving an incident overview briefing.
An.incident command meeting was held
every two hours.
2024 AST's Advance Team arrived on scene
and met with the OSC. AST Advance
Team immediately set about assisting in
developing response strategies and
~ transitioning to a Unified Command.
211,0 OSC announced the establishment of a
Federally lead, Unified Command which
would include representatives from the
impacted state and local municipal
governments as well as the Responsible
Party, Colonial Pipeline.
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Colonial Pipeline and Fairfax County mobilized
heavy equipment to the scene for unsuccessful
effort to construct an underflow dam. In addition
to the establishment of containment at the source,
booms were also placed at four downstream
locations:
® Route 7 bridge
® An area along Sugarland Run Road
• The bridge on the Algonquian Parkway
® The confluence of Sugariand Run and the
Potomac River
Vacuum and tanker trucks arrived and were placed
at accessible boom areas for product collection
from Sugarland Run. Mitigation efforts continued
on a 24-hour basis.
Forty-one residents in the area of Sugarland Run
were voluntarily evacuated from their homes.
The Fairfax County Water Authority closed its
intake along the Potomac River due to possible
contamination of the waters in that area.
Day 2 - March 29, 1993
0100 Unified Command met to discuss public
health concerns about odors from two
sorbent fences established close to
residential areas. On advice from AST,
in consultation with the Unified
Command, the OSC directed the fences
be removed.
0430 Colonial Pipeline reported 21 vacuum
trucks mobilized for recovery operations.
AST reported most of the oil had moved
beyond the initial containment boom
sites to the mouth of Sugarland Run.
Colonial Pipeline proposed to construct
a pipeline 3/4 mile overland from the
mouth to a staging area adjacent to a
recreational boat launching facility where
tank and vacuum trucks would be
loaded. Skimmers and prime movers
were to be mobilized by small boat or
airlifted to the recovery site at the mouth
of Sugarland Run.
0900 OSC directed the AST to request Navy
Salvage representative on scene to
provide technical expertise and to
identify additional personnel and
equipment needs.
The Atlantic Strike Team arrived onsite to provide
assistance to response efforts.
Ambient air monitoring was begun in residential
areas of concern as well as recovery operation
areas. The Virginia Water Control Board began
receiving inquiries from citizens concerned about
their well water. An advisory was issued by the
Fairfax County Health Department warning
residents to avoid Sugarland Run. Great Falls
National Park was closed due to complaints of
strong diesel fuel odors.
Marine Corps helicopter arrived and aerial
deployment of skimmers and support equipment
were coordinated with the AST.
Additional skimmers and pumping equipment
requested from the AST and Navy Salvage
Day 3 - March 30, 1993
Unified Command Team members performed an
overflight: of the affected areas. MSO Baltimore
established Southern Sector Command Center at
Boiling Air Force Base.
Residential area air monitoring stations continued
to be evaluated every two hours. TAT responded
to a nearby home where residents reported
unbearable levels of diesel fuel odors. Air
monitoring readings revealed no levels above
background within the house at this time.
Excavation of the pipeline completed with the
National Transportation Safety Board and the
Department of Transportation Office of Pipeline
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Safety on site to investigate the cause of the
rupture.
Loudoun County Health Department sampled area
residential water wells at risk. Results of the
laboratory analysis revealed no volatile organic
compound contamination.
The U.S. Fish and Wildlife Service reported 19
animals have been found affected by the spill.
Four of these animals have died; the rest are in
various states of recovery.
Additional USCG manpower and resources
deployed in a designated southern location to
assess and evaluate downstream environmental
impacts. Colonial representatives directed to
obtain with additional resources and manpower for
additional clean up operations identified by USCG
officials.
Day 4-March 31, 1993
Gulf Strike Team (GST) personnel and equipment
arrived on scene.
AST trained over 100 personnel in the use of a
shoreline evaluation assessment form and
organized reconnaissance teams to assess
Sugarland Run
The EPA drinking water representative, Bill Foster,
was on site to address Potomac River water intake
issues and coordinate with state and local officials.
Colonial estimates 415,000 gallons of water and
product were recovered, with 72% estimated to be
product. A Colonial health and safety auditor is
on-site addressing safety related issues.
The Virginia Water Control Board conducted a
river survey of the Potomac to closely identify
critical areas of concern.
Fairfax and Loudoun County animal control
personnel searched Sugarland Run for injured
animals. A shelter and recovery location was
established to treat the affected animals.
A communication center was established at the
Algonquian Park staging area at the request of the
OSC to facilitate information exchange between
the field and the unified command center.
Day 5 - April 1, 1993
Incident and Unified Command centers were
moved from the spill site to the Fairfax County
Police Department.
An initial field test revealed inconclusive results on
the use of elastol, requiring further tests
TAT continued ambient air monitoring in
residential and site work areas. Readings at the
mouth of Sugarland Run were from background
(0.4 units) to 5 units.
Wetlands/Natural Resources Damage Assessment
(NRDA) initiated by various trustees under the lead
of the U.S. Fish and Wildlife Service. The
Department of the Interior arrived on site to assist
with the NRDA. The OSC approved a ceiling of
$15,000 from the Oil Spill Liability Trust Fund to
reimburse trustees for expected response costs.
Fairfax County Water Authority reported area water
systems as stable and on-line.
The Fairfax County Health Department collected
residential well water samples which are being
analyzed for benzene-toluene-xylene (BTX) and
total petroleum hydrocarbons (TPH). Additional
well water samples will be collected north and
south of Route 7.
Additional containment boom was deployed on
Sugarland Run at the mouth of the Potomac River.
Acting Region III Regional Administrator, Stan
Laskowski, and Acting Director of Superfund
Programs, Abe Ferdas, on site. The USCG
deployed three deflection booms at Fort
Washington to protect the Mason Wildlife Refuge.
The U.S. Department of Transportation Office of
Pipeline Safety issued an administrative order to
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Colonial Pipeline specifying conditions for
reopening the pipeline.
A message board was established for local
residents to phone for regular updates.
Rapid shoreline evaluation teams were dispatched
throughout the entire area affected by the spill.
Teams were organized by EPA and USCG and
were issued specific areas to evaluate and report
upon. Information is being compiled by Virginia
Department of Environmental Services arid TAT.
Work plan for defined area usage of Elastol is
under development.
The Navy Superintendent of Salvage continued to
supply equipment for oil recovery operations.
Virginia Governor Wilder visited the site and was
given an update by the Unified Command. The
governor held a press conference immediately
following the update.
Colonial discovered a second dent on the damaged
pipeline. The damaged section removed.
Concerns over site safety prompts special meeting
to address outstanding issues by AST.
Project ceiling raised to $500,000.
Day 6 - April 2, 1993
AST personnel reported a significant reduction in
the amount of oil contained behind the boom at
the mouth of Sugarland Run. Additional contractor
recovery equipment and personnel were arriving
on scene. The AST recommended to the OSC to
demobilize National Strike Force (NSF) and Navy
Salvage resources. The OSC received concurrence
from the RRT and Unified Command and
authorized the demobilization. NSF continued to
monitor contractor efforts.
OSC petitioned RRT for approval for the use of
Elastol, a chemical oil coagulant. Permission was
given with specific conditions. That evening, the
OSC observed experimental application of Elastol.
Results were inconclusive due to weather
conditions. OSC directed vendor to conduct
additional testing during daylight hours.
Efforts are concentrated on oil recovery at the
mouth of Sugarland Run. Product recovery
estimations stand at 344,000 gallons of oil
recovered. Product recovered at the mouth of
Sugarland Run was 50% water. Decanting
operations were started to decrease shipping water.
Decanted water returned to the Sugarland Run
Site safety plan distributed by Colonial. Plan will
be updated as necessary.
Oiling of a bald eagle that is nesting two young at
Mount Vernon, Virginia reported. Subsequent
reports indicated that the birds were unaffected by
the spill.
Navy Salvage continued supplying equipment for
oil recovery operations.
FCWA system is stable but Potomac intake is still
out of service.
Sugarland Run task force made up of county
officials and citizens was created to address long-
term remediation of Sugarland Run.
Contractor boat capsized during the night in the
process of ferrying oil from the recovery to the
removal area.1 Oil was offloaded before the boat
sunk.
Virginia Department of Environmental Quality and
Department of Environmental Services conducted
fish kill counts along Sugarland Run. USFWS
reported a fish kill at Mason Neck.
U.S. Army Corps of Engineers collecting oiled
debris on the Potomac. Colonial Pipeline tasked
with disposal the waste.
NOAA has assumed the role of lead for the Natural
Resources Damage Assessment.
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Unilateral order issued to Colonial by acting NTSB completed on scene investigation. OSC
Regional Administrator. Prior to issuance, the expressed concern to NTSB about integrity of
Commonwealth of Virginia and Slate of Maryland parallel Colonial Pipeline that may also have been
were notified by RRT Chairman Dennis Carney. damaged by construction in the area.
Day 7 - April 3, 1993
Heavy rains overnight caused the Potomac River to
rise which forced the confluence of Sugarland Run
to shift easterly. As a result, most of the oil
contained behind the boom at the original
confluence had moved to the easterly point. Rapid
flow of the Potomac was causing entrainment of
the oil. AST Commander recommended the
Unified Command shift pumping equipment and
USDQT completed detailed inspection of repaired
pipeline. Approval granted to reopen the pipeline
at 80% of operating pressure at the time of failure.
Local officials negotiated with Colonial over the
safety of reopening the pipeline. Colonial agreed
to delay the reopening for 24 hours for further
negotiations. Colonial reached an agreement with
County Officials to reopen the repaired pipeline at
50% of the operational pressure at the time of
failure. Colonial agreed to develop plan for
critical points for additional testing.
4nvestLgatin.g_
OSC approved the use of Elastol in three locations
based upon evaluation of testing. Further Elastol
use to be approved on a case by case basis.
Route 7 recovery operations halted due to lack of
recovery. Boom was maintained and scheduled for
periodic inspection and removal of any
accumulated product.
A detailed internal inspection (smart pigging) must
be performed and assessed before the pressure can
be incrementally increased up to 80% of
operational pressure at the time of failure. Fairfax
County will be notified ahead of time of all
proposed changes.
Natural Resources Damage Assessment in the pre-
assessment phase. Memorandum of Understanding
drafted for the agencies participating in the
assessment.
State and local remediation and restoration
concerns submitted to EPA. EPA and NOAA to
review recommendations and respond.
Fairfax County demobilized mobile equipment.
Day 8 - April 4, 1993
Operations shift to mop-up and collection of oiled
debris.
Gravel road under construction at the mouth of
Sugarland Run for use in equipment removal.
Construction was later suspended because wet
ground would not support the gravel.
Product recovery estimated at 358,000 gallons.
Team comprised of the Fairfax County Water
Authority, Colonial Pipeline representatives, Fairfax
County officials, USCG and TAT investigated the
FCWA intake on the Potomac River to develop a
plan of action to reopen the intake as soon as
possible.
Day 9-April 5, 1993
Mop-up operations and oily debris collection
continued.
Unified Command meeting held to evaluate
emergency response effectiveness. Equipment
decontamination underway at the forward location
in preparation for equipment demobilization.
Day 10 - April 6, 1993
To date, 372,498 of 407,436 gallons have been
recovered.
Rehabilitated animals (beavers) released to a new
environment.
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Day 11-April 7, 1993
Pipe ditchline excavation expanded as further soil
contamination was identified. ;
A 36-inch harbor boom was installed at the FCWA
intake to deflect sheen and contaminated debris.
Day 12 - April 8, 1993
FCWA Potomac water intake reopened at limited ;
capacity with 24-hour monitoring.
Loudoun County sampled an additional 16 wells. ;
Debris collection on the Potomac River halted by
the Corps of Engineers at the direction of USCG.
Day 13-April 9, 1993
Unilateral Order signed by Colonial. Draft
Response Action Plan (RAP) submitted.
Enforcement OSC Chris Wagner assumes command
for continued cleanup and restoration efforts. i
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COLONIAL PIPELINE RESPONSE
Discussion Questions and Epilogue
DISCUSSION QUESTIONS
1. With a large number of affected jurisdictions,
who should command the response and
cleanup effort for the spill?
2. What goals and priorities exist for emergency
operations.
3. The spread of the oil spill brings the smell of
diesel fuel. Residential complaints of odors
inside houses are received by local health
departments. Well owners along the spill
route are also expressing concern about
contamination to their wells. What provisions
should be made to protect the public welfare? 7.
4. The rainy conditions have caused flooding in
Northern Virginia. The waters of the Run
flow over its banks and into the 100 year
flood plain. The saturated soils quickly turn
to mud under the charge of responders. What
advantages or disadvantages are present due
to the weather?
8.
5. The PRP begins to mobilize contractors to
conduct the oil containment and recovery
operations. The Run is boomed at several
convenient access points up to the Potomac
River. Equipment is mobilized for oil
recovery operations at the established
containment areas. Personnel are distributed
among the containment and recovery
operations along the nine miles of the Run, in
effect creating separate mini-sites. Emergency
operations continue around the clock and, all
of the contractors work long shifts. How 9.
should site safety be addressed for workers at
multiple locations working long shifts?
6. The pipeline has been shut down and material
continues to flow slowly from the hole in the ,
ground created by the pressure release. An
adjacent retention pond is collecting material
and discharging it to the west into a wooded
area. The oil is conveyed by the stormwater
driainage .system to a discharge culvert that
leads to the Run (300 yards west of the
rupture site).
a. How can you secure the rupture site and
eliminate any further oil discharge?
b. What containment or recovery operations
could be utilized for this portion of the
spill route?
After the bridge, the Run flows through a
township park; Access for heavy equipment
is limited until further downstream, when the
run flows alongside of Dranesville Road. At
this point, the Run is meandering and has
spread out into the flood plain. Does this
segment offer any advantages or potential for
containment and recovery .operations?
Slightly further downstream, the next
intersection with the Run is a two-span bridge
at Route 7. The two lane, dual bridge spans
cross the Run at a narrow point with high
banks. Emergency vehicles could be placed
on the bridge and reach the Run with a
minimal length of hose. Heavy traffic during
rush hour is a potential problem for this
location. Does this segment offer any
- advantages/potentials for containment and
recovery operations?
The Run flows from under the Route 7 bridge
and enters a wooded residential area.
Approximately three miles further
downstream, the Run is intersected by the
Algonquian Parkway bridge. Access to the
Run at the bridge is possible using a sewer
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access road. The bridge is a tall and wide
span and the terrain under the bridge is flat,.-
with the Run flooded over its banks. What.
strategies could be utilized for recovery
operations at this access point?
10. The Run continues for a mile through a
regional park property. Harbor boom is
utilized to contain oil before it enters into the
Potomac River. Access is approximately one
half mile away, across water-logged ground
and through woods. Heavy equipment is
having trouble traveling across the swampy
area and the woods add an additional barrier.
The closest location to stage a tanker truck is
at the boat ramp. Access could be gained to
the oil containment on the Run by using a
boat on the Potomac River.
a. What are some options to move recovery
equipment to the . isolated oil;
containment?
b. How do you convey recovered materials
to an access point for loading into a tank
truck?
c. Were the oil to break containment at the
Sugarland Run, what contingencies
should be prepared to handle the oil on
the Potomac River?
11. The recovery site now has a way to pump
recovered oil into tanker trucks for removal
and storage. A bottleneck in the process
occurs when the oil skimming capacity is not
sufficient. The PRP is unable to locate a
contractor to supply such equipment. What
additional resources could be utilized by the
OSC to obtain additional skimming
equipment?
12. As the amount of oil to recover diminishes,
the recovery process itself becomes more
difficult. Physical methods are utilized to
direct oil towards skimmers. The option to
use chemical coagulants is evaluated and
limited applications are performed under strict
.supervision. What is the proper procedure for
the use of chemical coagulants for the
. recovery of oil?
13. Other areas of concern are the large amount
of oiled debris. The debris has collected in
containment booms and interferes with the
skimming process. Oiled debris is removed
from the Run and staged on plastic sheeting.
What is the proper procedure for disposal of
, oiled debris?
EPILOGUE
The Colonial pipeline release was one of the first
major spill events in Region III where many
members of ithe RRT were on scene in a timely
fashion. This provided an opportunity to fine tune
coordination issues which have hindered RRT
activities in the past.
The' Unified Command Structure utilized at the
Colonial Pipeline Oil Spill was the key to
mitigation operations. Fast and frequent
coordination' by all members of the RRT greatly
enhanced the recovery of product and provided a
more cost effective response. The ability of the
Unified Command to quickly reach a cooperative
decision kept response activities moving and
ensuring thatiall interests, Federal, State, and local,
were being considered and protected. For the few
disputes, a consensus was quickly reached, and the
Unified Command's decisions were actively
enforced. Having representatives frorri all levels of
government as well as representation from the
Responsible Party included in the Unified
Command greatly sped coordination at all levels.
The success of operations at the Colonial release
clearly indicate that all levels of government can
efficiently function within a single group, providing
timely and effective decisions.
Utilization of other governmental agencies may
cause jurisdictional jealousies to surface in crisis
situations. Was the use of other agency personnel
an effective strategy in this response?
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Of particular note was the effectiveness of the
Coast Guard Marine Safety Office (MSO)
Baltimore's activity throughout the spill response..
The first federal officials on-scene were members of
the pollution response team dispatched by MSO
Baltimore. The continued presence of MSO'
Baltimore personnel both in the field and as part of
the Unified Command served to enhance the
effectiveness of the response. The southern sector
command established by MSO Baltimore was
invaluable in providing immediate attention to field
requirements as they developed.
The Coast Guard National Strike Force (both the
Atlantic and Gulf Strike Teams), were a most
valuable asset for clean-up expertise, equipment,
and general health and safety issues and overall
management of the spill response. When the Navy
Supervisor of Salvage was asked to provide
recovery/equipment personnel to assist in
mitigating efforts, the Coast Guard was a valuable
link in the liaison between the Unified Command
and Navy Salvage. It should be noted that the
OSC did not request the immediate dispatqh of
Navy Salvage personnel and equipment. Future
response efforts of this nature would benefit from
the immediate dispatch of Navy Salvage personnel
and equipment on scene as quickly as possible; in
order to provide an alternative solution to those
proposed by the Responsible Party. The National
Strike Force was also invaluable .in identifying.
nontraditional sources of equipment. An example
would be identifying the availability of a CH-46
helicopter from the U.S. Marine Corps to airlift
heavy pumps and recovery equipment to areas
unaccessible by road at the mouth of Sugarland
Run. .
The National Resource Trustees represented on shie
by the U.S. Fish and Wildlife Service and the
National Oceanographic and Atmospheric
Administration, also contributed early to mitigation
efforts. NOAA provided aerial photography of the
spill area and USFWS was essential in the damage
estimation to marine and wildlife. Close
coordination between the Natural Resource
Trustees, who were tasked with the formal damage
assessment and EPA Enforcement ensured that
there was no duplication of efforts during the
assessment of affected areas.
The Regional Response Team (RRT) is a body of
Federal and State agency representatives
established by the National Contingency Plan
(NCR) constructed and designed to assist the OSC
in obtaining critical resources and advice during an
emergency response.
Early coordination with the RRT played a key role
in the success of mitigation efforts. This dialogue
gave the OSC rapid access to a large supporting
team and assisted in the resolution of many
problems of both a policy and logistical nature.
The presence of the Region III RRT Co-Chair on
site was of great advantage in obtaining critical
ressurces and approvals as demonstrated by the
Elastpl approval. Timely guidance and approval
for the use of Elastol was obtained within hours of
the Colonial Pipelines first formal request.
The mouth of Sugarland Run was inaccessible to
vacuum trucks or barges. Vacuum trucks could not
gain access to containment sites due to steep
incliries and extremely muddy conditions. As a
-result, a pipeline had to be built approximately 3/4
of a mile long to a staging area where the
recovered product could be loaded into vacuum
and tank trucks. Pumping gear and other heavy
equipment had to be flown in by Marine Corps
helicopter. Use of irrigation piping used for
agricultural .purposes and Navy Salvage floating
hose provided the required length.
Booms placed at the four primary containment and
recovery sites were not set as well as possible.
These areas were boomed straight across Sugarland
Run : as opposed to being set at angles for
deflection. Oil and debris was collected in the
center or catenary of the booms set which had to
be removed by small boats. The NSF offered
guidance to the Colonial Pipeline contractors on
the proper positioning of the boom.
Debris caused the clogging of skimmers. Workers
were forced to continually tend to the skimmers to
remove obstructions. The oil absorbed to the
Colonial Pipeline Response
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debris and caused a sheening effect that required
the removal of tons of oiled debris. The
application of elastol appeared to compound the
problem by "Elastolizing" (coagulating) the debris
with oil.
The flood waters and rapid flow of the Potomac
caused the entrainment of oil under the boom
placed at the mouth of Sugarland Run. The
presence of trees hampered the establishment of
boom lines and the rising waters of the Potomac
River caused the easterly shift of the confluence.
This shift required the repositioning of equipment.
The type of oil (number two fuel oil), the spill
occurring in a fast moving estuary during flood
conditions heavy with accumulated vegetation and
debris made small disc, drum and specialized weir
skimmers the most effective in recovering oil.
Other skimmers, such as the sorbent belt, rope
mop, vacuum type and submersion plane would
have been less successful due to clogging by ,
debris, low recovery efficiency, and limited area
for set up. Local supply of the desirable skimmers
was extremely limited. Colonial Pipeline was
forced to go outside the region to get additional
skimmers. For future spills of this type and
magnitude, it would be advantageous to deploy
NSF and, if available as was in this case, Navy
Salvage equipment early in the response and keep
the equipment operating until adequate supply of
skimmers is on hand in place operating
satisfactorily.
The establishment of an underflow clam would
have been the most effective means of stemming
the flow and setting the stage for enhanced '•
manageable recovery efforts. Due to many factors
and insurmountable obstacles considering the
location and weather conditions encountered at the
scene, this was not possible. Development of a
portable underflow dam system for inland oil spill
response should be evaluated. Deployment of a
portable underflow dam might be accomplished in
the same manner as the NSF's Harbor Boom
Deployment System.
Page 26 Colonial Pipeline Response
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Case Studies
November 1994
1994 International Hazardous
Material Spills Conference
THE DIVEX EXPLOSIVES SITE
Introduction
Christopher A. Militscher, Emergency Response and Removal Branch, EPA Region IV
This case was prepared for use as a tool to
foster greater understanding of chemical
emergencies and emergency response.
Cases are intended to be used as a basis for
discussion. Each is based on actual
situations, but the presentation may focus
on one aspect of the response for the
purpose of discussion and instruction.
The Players .......
U.S. EPA
> Emergency Response Cleanup Services
(ERGS)
> Response, Engineering and Analytical
Contract (REAC)
t- Technical Assistance Team (TAT)
State and local organizations
>• Department of Health and
Environmental Control (SCDHEC)
> Richland County, SC Emergency
Management Services (RCEMS)
* State Fire Marshal's Office (SFMO)
»• State Law Enforcement Division (SLED)
U.S. Government Agencies
»• Agency for Toxic Substances and
Disease Registry (ATSDR)
>• ATF Explosives TechnologyBranch (ETB)
*• Bureau of Alcohol, Tobacco and
Firearms (ATF)
»• ' USCG Gulf Strike Team (GST)
> Corps of Engineers Huntsville Division
> Corps of Engineers Savannah District
* Explosive Ordnance Disposal (EOD)
>• Regional Response Team (RRT)
INTRODUCTION
On Labor Day 1993, Mr. Jack Sutherland, owner of the Divex
Corporation was working alone at his manufacturing facility
outside Columbia, SC. In the early evening, the neighbors heard
an explosion. That explosion killed Mr. Sutherland as he was
making an explosive initiating compound called Lead Styphnate.
The next week, a Divex employee working with the South
Carolina Department of Health and~"Environmental Control was
injured in an explosion while walking outside at a Divex facility.
Several weeks later, the EPA Region IV Emergency Response and
Removal Branch was notified of the facility conditions by the
office of Senator Strom Thurmond. Thus began a 10 month
removal and clean-up which would establish a number of "firsts"
for the Environmental Protection Agency.
This case will examine the use of outside agency expertise and
resources to remediate one of the most dangerous Superfund sites
in the history of the program.
The Divex Explosives Site
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THE DIVEX EXPLOSIVES SITE
The Response
BACKGROUND
The Divex Corporation Explosives Emergency
Response and Removal Action site was one of the
most dangerous EPA Siiperfund Sites in the
program's history. On September 6, 1993, the
owner/operator of the company, which made
initiating explosive compounds, died in an
explosion while making lead styphnate.
The site comprised several locations: a laboratory
located in a commercial, residential area near
downtown Columbia, South Carolina, the main
facility located ten miles north of Columbia in a
rural, residential area, and a warehouse located
near the Richland County Landfill.
The Divex Corporation had filed for bankruptcy in
the Summer of 1993.
One week after the owner, Mr. Jack Sutherland,
was killed, a Divex employee working with the
bankruptcy attorney and the South Carolina
Department of Health and Environmental Control
(SCDHEC), injured his foot in an explosion while
walking at main facility.
EPA Region IV Emergency Response and Removal
Branch (ERRB) was notified of the conditions at the
laboratory site and main facility by Senator Strom
Thurmonds's office through the Richland County
Emergency Management Services (RCEMS) on
October 22,1993. RCEMS personnel believed that
measures to address the conditions at the
laboratory and main facility by SCDHEC were
inadequate after learning that the bankruptcy
attorney terminated his activities through the
Federal District Court.
The Divex Corporation possessed a number of
permits and licenses. These included:
® Bureau of Alcohol, Tobacco and Firearms
(ATF) licensed explosives manufacturing
company
e South Carolina Department of Health and
Environmental Control permitted hazardous
waste transporter
® South Carolina Fire Marshall's Office (SFMO)
permits1 for explosives storage and
manufacturing
® U.S. Department of State license to export
explosives
An EPA On-Scene Coordinator (OSC) responded to
the laboratory location on October 22, 1993, after
learning that power was to be shut off in the
building.. This posed great concern as it was
believed that 300 vials of 98-99% nitroglycerin
were located in the refrigerator. In addition, it was
also believed that many pounds of shock, friction
and heat sensitive initiating explosives were also
located in the laboratory.
At the onset of the response, little information was
known regarding the explosives, hazardous
chemicals and wastes which were potentially
present at the main facility and the warehouse. A
preliminary assessment was needed at all of the
Divex Corporation sites as local and state response
officials were not equipped to deal with all of the
potential hazards associated with the company's
activities. -' . •
THE PROBLEM
The Divex Corporation explosives site possessed
an enormous threat to response personnel and the
local population. It was determined that the blast
radius from the laboratory was approximately one
quarter of a mile and could have killed, injured or
exposed several hundred to thousands of persons
working or living near the laboratory. Besides
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highly sensitive explosive compounds, the
laboratory contained several hundred containers of
poisons, corrosives, flammables and other
hazardous substances. It was also determined that
the main facility contained tens of thousands of
pounds of highly sensitive military ordnance and
high explosives. The estimated blast radius was
approximately eight miles and would have
immediately killed or injured several hundred
persons. The main facility contained 23 magazines
and trailers of other hazardous materials as well,
including cylinders of poisonous, reactive and
corrosive gases, drums of toxic waste, laboratory
containers of poisons, flammables, reactives,
cyanides, radioactive substances and other
incompatible and improperly stored hazardous
substances and wastes.
The effects of an explosion and fire would be
devastating to the entire City of Columbia and
thousands of residents in the Richland County area.
There were no other local, state or other Federal
agencies capable of providing a safe and complete
response to all of the threats possessed by the
Divex Corporation explosives site locations.
RESPONSE
The first EPA OSC responding immediately
requested activation of the Regional Response
Team (RRT) to obtain support from other Federal
agencies, including the ATF and Department of
Defense (DoD). An EPA Emergency Response
Cleanup Services (ERCS) contractor and the
Technical Assistance Team (TAT) contractor were
ordered to the scene of the laboratory to begin
preliminary assessment, contingency planning,
logistical support and immediate cleanup activities.
Qn October 24, 1993, the unstable nitroglycerin
vials were removed from the laboratory site by a
local, state and Federal convoy and detonated
safely at the Richland County Landfill.
On October 23 and 25, 1993, two other senior
OSCs and two junior OSCs were assigned to the
Divex Corporation locations. Christopher A.
Militscher was assigned by the RRT Co-Chair as the
lead OSC for all of the Divex Corporation
explosive site locations.
Through Interagency Agreements (lAGs) with the
U.S. Army Corps of Engineers Savannah District
and the U.S. Coast Guard Gulf Strike Team (USCG
GST), additional support was immediately
requested. The Savannah District began
arrangements for the temporary relocation of a
dozen families near the laboratory and four
families which were close to the main facility. The
GST was requested by the OSC to respond to the
main ; facility to begin a joint preliminary
assessment with the ATF and the Department of
the Army's Explosive Ordnance Disposal (EOD)
group from Fort Jackson, SC. Several ERCS
contractor, TAT and ATF personnel were assigned
to the laboratory location to complete the
preliminary assessment and cleanup of the 250
plus chemical containers, 150 pounds of initiating
explosives and other materials present at the lab.
The OSC developed a site specific IAG with the
ATF Explosives Technology Branch (ETB) to obtain
dedicated resources and expertise from this
specialized group of explosives enforcement agents
during the cleanup activities.
Public meetings and briefings were routinely held
to address the temporary evacuations and
relocations and to provide a coordinated response
from all of the local, state and Federal agencies
involved at the different locations. Local television
and newspaper media coverage was intense for
several weeks during the preliminary assessment
activities.
The relationship between EPA and State response
officials was hampered by previously existing
relatibnships between Divex and state agencies.
SCDHEC's earlier relationship with the Divex
Corporation was that of a permitted hazardous
waste transporter and a funded, hazardous waste
cleanup subcontractor. Other state agencies also
had involvement with the owner as the State Fire
Marshall was a very good friend of Mr.
Sutherland's and the State Law Enforcement
Division (SLED) routinely utilized the Divex
Corporation for the removal and disposal of
explosive items such as pipe bombs. Furthermore,
The Divex Explosives Site
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explosives storage violations from 1991 had not
been corrected at the main facility. All responsible
regulatory authorities claimed they had no
knowledge of the laboratory's existence or its
extremely hazardous conditions. What role the
SCDHEC's RCRA inspection personnel had with
the Divex Corporation owner remains a matter of
concern and investigation. Clearly, hazardous
waste storage and disposal violations went
uncorrected at the main facility and at the
warehouse.
While these activities were being conducted, the
OSC initiated a fourth IAG with the U.S. Army
Corps of Engineers, Huntsville Division to address
packaging and removal of the tens of thousands of
pounds of military ordnance and explosives being
found at the main facility. On November 10,
SLED provided a robot at the request of the OSC to
perform a sweep of the floor in the main building
where the owner died.
On November 17, 1993, SCDHEC identified
certain wastes in the warehouse as being from their
previous cleanup operations with the Divex
Corporation. On November 19, the laboratory
non-explosives wastes were transported to the main
facility to be sorted and treated with the hundreds
of containers being identified at the main facility.
The laboratory site removal phase was completed
following 14 detonations of explosives. The 12
families that had been evacuated were allowed to
return to their homes.
From mid-November to December, the ATF and
GST completed the preliminary assessment at the
main facility. On December 2, a large private
manufacturing explosives company was brought in
to remove and recycle 29,000 pounds of stable
high explosives from that site.
On December 8, the OSC issued a second ERCS
delivery order to another ERCS contractor to
provide direct cleanup services at the main facility
and the warehouse. After completing initial
logistical support activities at the main facility, the
first ERCS contractor was demobilized from the
Divex Corporation explosives site. The OSC
demobilized this ERCS contractor due to an
inability to provide an appropriate and efficient
workplan and site specific health and safety plan
(SSHSP) for the main facility. Utilizing ATF, GST,
Huntsville Divisipn, ERCS contractor, TAT and
RCEMS support, EPA began the process of
addressing the treatment and cleanup of hazardous
materials at the main facility. EPA also activated
the Environmental Response Team (ERT) and the
Response, Engineering and Analytical Contract
(REAQ to provide technical assistance to the OSC
on sampling, monitoring and treatment methods.
The OSC also involved and directed the response
of several identifiable Potentially Responsible
Parties (PRPs), including Clemson University and
Lockheed Aeronautical, for their wastes present at
the main facility.
Other significant events during the removal action
are outlined below:
January 1994
© Huntsville Division begin the detailed
inventory and repackaging of military
ordnance and explosives.
® ERCS contractor begins initial cleanup and
labpacking activities at the warehouse
property.
a Shock-sensitive, explosive compounds were
removed from the warehouse by the Richland
County Bomb Squad, ATF and ERCS
contractor and were stated for ultimate
disposal at the main facility.
® ERCS contractor began small, known
container consolidation and treatment
operations.
@ Air release of suspected sulfur dioxide occurs
during treatment operations and emergency
evacuation plans implemented for on-site
personnel. No injuries or exposures result
from this release.
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February 1994
® ATF, EOD and RCEMS complete removal and
detonation of remaining military ordnance and
explosive items at Fort Jackson. This included
a Dragon anti-tank missile warhead and its
components, additional proximity fuzes and
mines and other materials unsuitable for on-
site detonation or transportation to the Kansas
Army Ammunition Plant (KAAP).
• OSC begins coordination with Internal
Revenue Service (IRS) on disposition of seized
assets the laboratory and office.
® EPA, ERT and ERCS contractor begin hazard
characterization of containers in main
building. Small "pops" from unreacted
crystals detected during operations.
« First shipment of military ordnance to KAAP
completed. Drum in main building
"explodes" during remote removal operations
of drums. The blast is heard 15 miles away.
No injuries or secondary fires resulted.
® ATF, with other support agencies and
contractors, begin the first of thirty on-site
detonations and enhanced burns at the areas
prepared for such activities.
® ATF and the OSC collect wipe samples for
explosive compounds from the main building
to determine which areas may be entered
safely and where other hazardous wastes
containers can be removed without incident.
March 1994
« Flasks containing approximately five pounds
of unstable lead styphnate detonated in-place,
after construction of containment system by
ATF, Huntsville Division, ERCS contractor and
others (this highly dangerous operation
referred to as the "Little Hoover Maneuver").
* ATF, ERT, Huntsville Division, ERCS
contractor and OSC remotely remove
remaining drums in main building by utilizing
foam and a pulley system. EPA identifies
large repainted cylinders labeled by
Sutherland as "propane" as being actually
Pentaborane.
Pentaborarte
Pentaborane is a toxic chemical with a low
exposure limit. Symptoms of inhalation are
dizziness, headaches, drowsiness and light
headedness. . It affects the central nervous
system, eyes and skin. Pentaborane may
spontaneously ignite in moist air.
Color
Physical State
Odor
Exposure Limit
IDLH
Colorless
Liquid
Pungent
0.005 ppm
3 ppm
NIOSH Pocket Guide to Chemical Hazards, 1990
® Radioactive labpacks which were identified by
ERCS contractor, OSC and ERT are removed
by permitted company for ultimate disposal.
EPA begins removal of decontaminated
magazines to other Federal and law
enforcement facilities for recycling/reuse.
• EPA begins enforcement and removal
activities of "nonhazardous" compressed gas
cylinders with PRPs.
® A large spontaneous fire erupts in an on-site
container of treated chemical wastes. ERCS
contractor and RCEMS respond to incident.
• The main building is "detonated" and burned
by ATF to remove remaining threat of
unreacted explosives (referred to as the "The
Hoover Maneuver"). A secondary brush fire
causes the implementation of the emergency
contingency plan and response by the
Richland-Columbia Fire Department.
« A 500 pound aerial bomb was discovered
partially buried under a crane which was in
The Divex Explosives Site
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the process of beifrg scrapped. EOD unit from
Fort Jackson was activated by OSC to remove
and dispose of bomb. ERCS contractor
completes additional dn-site treatment and
stabilization of labpack chemicals.
April 1994
• Integrated Environmental Services (fES), the
pentaborane cylinder subcontractor, begifts
mobilization of specialized equipment, mobile
laboratory and containment structure for on-
site cylinder treatment operations. ERT and
REAC complete ground penetrating radar
surveying of main facility and oMier Divex
Corporation properties.
e PRPs complete last removal of identifiafete
"nonhazardous" cylinders. Ten PRPs remove
a total of approximately 100 cylinders from
the main facility for recycling and reuse.
• TAT completes on-site soil sampling and
begins residential well sampling for relocated
families near the main facility.
June 1994
* IES commences treatment of. large
pentaborane cylinders.
• Small detonation and fire occurs in secondary
containment structure during pentaborane
treatment operations.
® Additional fires and small detonations occur
during pentaborane treatment. On-site
monitoring for boron-hydride compounds
shows that no contaminants escape primary
containment structure.
controls can be made.
July 1994
» ERCS contractor completes removal of all on-
slte was^ewaters and flammable liquids for off-
site treatment and disposal.
* IES employee, Keith Jolly, collapses and
experiences seizures during pentaborane
treatments. Admitted to the hospital, he was
given less than a 10% chance of survival after
lapsing into a coma.
® IES president, Jeff Gold, admitted to hospital.
He is also suspected of being exposed to
pentaborane.
« At the OSC's request, Rich land County, ERT,
REAC, ATSDR, ETI (the ERCS contractor), and
GST are required to conduct a thorough
investigation into the incidents and to test IES
personal protective equipment. SomeoflES's
personal protective equipment fails pressure
tests. OSC requires full accounting of lES's
health and safety practices.
® Mr. Jolly comes out of coma and his condition
seems to be improving. Hospital physicians
and ATSDR confirm pentaborane exposure,
but can not explain his recovery.
® IES recommences cylinder treatment
operations after health and safety problems
are fully addressed and corrected.
August 1994
@ IES completes cylinder treatment operations.
Residents near the main facility are permitted
to return to their homes.
ERCS contractor and GST complete cleanup of
remaining "hidden" wastes from warehouse
property. Fire inside secondary conlairtment
structure requires partial evacuation of on-site
personnel and forces the cessation of further
pentaborane cylinder treatment operations
until additional engineering and desi§r+ Overall, media relations were very favorable
Wastewaters are removed from site by ERCS
contractor and IES. Demobilization activities
are completed. All field activities under
removal action were completed.
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towards EPA, its contractors, Richland County
personnel and the other support agencies. There , .
was some criticism of SCDHEC's failure to address
the problems at the site when first notified of the . .
incident on September 6, 1993. Generally, state
field personnel successfully assisted EPA in several
ways during the cleanup. One initial issue with
SCDHEC was their insistence that EPA was
required to file for state permits for on-site , . , ,
treatment operations. The lead OSC, with
management support, deferred these requests in
accordance with provisions in the National . .
Contingency Plan (NCP). SCDHEC personnel were . ,
privy to all on-site operations and invited to assist' '•:,..•
in the planning of treatment activities. However,
they were reluctant to provide such technical :. • • : ,
assistance and "treated" EPA and other response
agencies as if they were a "regulated" entity.. ' . •'..'•'•.
The Divex Explosives Site Page 33
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THE DiVEX EXPLOSIVES SITE
Discussion Questions and Epilogue
DISCUSSION QUESTIONS
1. What were the real reasons for SCO H EC not
notifying EPA of the incident on September 6,
1993?
2. How can ATF compliance inspectors and EPA
and State RCRA inspectors better coordinate
their regulatory responsibilities for explosive
manufacturing facilities?
3. Can the public be better served by assuring
that conflict of interest regulations similar to
the Federal Government's apply to state and
local officials?
4. How can EPA improve enforcement of the
hazardous waste transportation regulations for
state "permitted" transporters?
5. Should a generic IAG be established between
EPA and ATF's ETB unit?
6. Should a generic IAG be established between
EPA and the Huntsville Division Ordnance
and Explosive Waste Division?
7. Should all military ordnance and explosive
wastes be considered RCRA hazardous
wastes?
8. What methods could EPA employ to assist
states in improving RCRA enforcement and
CERCLA response capabilities?
9. How can. EPA better relate the NCP
provisions, which give OSCs specific
responsibilities and authorities, to other
groups, agencies and other parties?
10. Should EPA ever again allow a cylinder
treatment company or other contractor to treat
pentaborane or other reactive or extremely
toxic boron-hydride compounds? Is there a
safe way to treat these "nerve" gas type
materials?
11. Under which conditions or circumstances
should an EPA OSC be removed from his/her
duties at the scene of an emergency response
or removal action site?
12. How do agencies like EPA, the Corps of
Engineers and ATF develop more effective
partnerships?
EPILOGUE
For perhaps the first time in the history of EPA's
Emergency Response and Removal Program, four
lAGs were required to address all of the hazards
posed by the Divex Corporation explosives site.
Several other significant events and EPA removal
program "firsts", include:
© First time an IAG was developed between the
EPA arid ATF.
® First time that EPA burned a building down as
part of a "safe" method of treatment.
» First time that pentaborane and other
extremely dangerous boron-hydride
compounds were treated on-site.
@ Only removal known to ERT where explosive
wastewaters were successfully treated on-site.
« For only the second time in program history,
a site specific IAG between EPA and
Huntsyille Division's Ordnance and Explosive
Waste Division was developed.
• For perhaps the first tine, over 45 on-site
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detonations and controlled burns were
required to eliminate the explosive threats
posed by this site.
The most important lesson learned was one of
"ego". No one group or agency was capable of
addressing this site alone. Only through numerous
Federal lAGs, several contractors and
subcontractors and enormous support provided by
local officials from Richland County, could this site
be properly cleaned up. Also, this response action
emphasized the point that a site of this magnitude
requires the expertise from dozens of individuals,
but not "experts". Jack Sutherland was touted by
some local and state official to be a chemical and
explosives expert.
Although many activities and were delegated by
the OSC to other Federal response personnel, the
burdens on the OSC were enormous. Over 350
individuals worked at the different Divex
Corporation explosives site locations. With this
magnitude of coordination, it became apparent that
the lead OSC could not remain on the standby
rotation and properly address this incident. The
lead OSC had to request EPA management to
remove him from the standby and response
rotation. Moreover, the concept of rotating OSCs
to cover periods when the lead OSC was not
available on-site proved to be potentially inefficient
and sometimes ineffective. This OSC would not
request a "stand-in" again under similar
circumstances.
One ERCS contractor performed extremely well
during the main facility cleanup. Their field
personnel, as well as other contractors and local,
state and federal agency personnel were
recognized at an awards ceremony by the Richland
County council and the South Carolina Lieutenant
on September 6, 1994. The other ERCS contractor
who initially responded was demobilized after
failing to perform satisfactorily under the EPA's
contract. Some companies use the "corporate
liability" excuse to delay response actions and
increase EPA response costs. ERCS contractors
which are found to perform poorly should be
'"barred" from bidding on future ERCS contracts for
a period of time.
This site contained some of the most dangerous
initiating explosives known, including lead azide,
PETN,; lead styphnate and the little known barium
styphnate. In addition, there were experimental
shock sensitive compounds present on-site, like
hydrazine bis-borane (there is no specific chemical
data, \ MSDS or other reference materials
information on this compound). The site also
possessed armed detonators, anti-personnel mines
and other highly sensitive explosive ordnance
items. Despite these materials which could be
detonated safely, the greatest concern to the OSC
from a technical standpoint came from the
pentaborane, diborane and other boron-hydride
compound compressed gas cylinders.
Pentaborane, especially in large 300 pound
cylinders, can spontaneously explode or, if
releasjed, can be lethal at extremely low
concentrations (somewhere between 15 ppb and
720 ppb - the "experts" aren't certain!). It is as
deadly as most chemical warfare agents, if it
doesn't react completely, explode or spontaneously
react with air, water or dozens of other materials.
On-site detonation was not feasible because of
IDLH concentrations downwind from one cylinder
could, extend to greater than ten miles from the
site. This would require the temporary evacuation
of over 150,000 persons in and around the city of
Colunhbia, SC. Off-site transportation and disposal
was not practicable because there are no permitted
facilities to accept these compressed gas cylinders
and it could endanger the lives of thousands of
persons during transportation. Furthermore, there
are no known locations in the Southeast where
these! cylinders could be detonated without
potentially impacting numerous downwind
communities. Thus, on-site treatment was
attempted and completed by IES. However, the
treatments resulted in several severe incidents and
could have resulted in a catastrophic release. It is
my technical opinion therefore, that the several
large pentaborane cylinders at Redstone Arsenal in
Huntsville, Alabama and the hundreds of
pentaborane cylinders located at Edwards Air Force
Base in California should be transported in
specially designed containers under a nitrogen gas
The Divex Explosives Site
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blanket to remote areas (e.g., the White Sands
Missile Range in New Mexico) and detonated in
combination with liquid oxygen. I believe this is
one of the only safe methods to destroy this failed '
and extremely dangerous rocket fuel. The •
company which produced these materials and sent
them to the Divex facility is currently under an
EPA criminal investigation!
The most important lesson learned from this
emergency response and removal action site was
that even with the most experienced arid talented ]
personnel, the best resources known and available
to the OSC, and the most painstaking planning for
health and safety concerns and other
contingencies, it can just comes down to luck, '•
God's will, and the actions of true heroes, like Mr.
George Mick, Chief of the Richland-Columbia Fire
Service. Without Mr. Mick's assistance and \
bravery on several occasions, some occasional
good fortune, this cleanup could have resulted
with significant loss of life to on-site persons. Mr.
Mick's unselfish actions saved Mr. Jolly's life to
where he has almost fully and inexplicably
recovered from his near fatal exposure. Mr. Mick
was honored by the EPA Regional Administrator for
an outstanding Environmental Service Award for :
his work at the Divex Corporation explosives site. ;
While he was not the only brave or hard working
person on-site, he exemplified the resolve and
perseverance of numerous persons who risked their
lives to mitigate one of the most dangerous sites in
EPA's history.
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Case Studies
November 1994
1994 International Hazardous
Material Spills Conference
MjV ASTRA PEAK RESPONSE
Introduction
William K. Capune, Marine Safety Office, Honolulu, U.S. Coast Guard
This case was prepared for use as a tool to
foster greater understanding of chemical
emergencies and emergency response.
Cases are intended to be used as a basis for
discussion. Each is based on actual
situations, but the presentation may focus
on one aspect of the response for the
purpose of discussion and instruction.
The Players
U.S. Environmental Protection Agency (EPA)
»• Tech Assistance Team (TAT)
Responsible Party (RP)
K Alcantara and Frame (Owner's
Representatives)
>• Industrial Technology (IT)
>• Pacific Environmental (PENCO)
U.S. Coast Guard (USCG)
>• Captain of the Port (COTP)
>• Federal On-Scene Coordinator (FOSC)
*• Marine Safety Office (MSO)
State and local organizations
>• Hawaii Department of Health
*• Honolulu Fire Department
U.S. Government Agencies
> Agency for Toxic Substances
Disease Registry (ATSDR)
and
INTRODUCTION
On 7 January 1994, the M/V Astra Peak anchored off Honolulu
Harbor for a medical, evacuation. The 531 foot, semi-container
vessel had bulk holds; and containers on top of the hatches. The
week before, smoke was observed coming from the number three
hold. The hold was flooded with carbon dioxide. The fire
occurred during a storm when the ship to rolled heavily.
Although the Astra Peak came to port for a medical evacuation, it
was discovered a container was leaking Terbufos, a highly toxic
organophosphate pesticide and needed to assess and repair the
damage from the fire (possibly hazardous materials) in the hold.
The U.S. Coast Guard Captain of the Port was faced with the
requirement to effect the cleanup of the leaking pesticide and
assess the fire damage in the number three hold. The hold
contained flammable cyanide based pesticides, a super oxidizer,
and over 5,000 pounds of matches. As the hatch had not been
opened since the fire, it was not known what had fueled the fire
or even if the fire was out.
The Captain of the Port had to coordinate the cleanup operation
with local, state and federal organizations as well as coordinate
and monitor the actions of the ship's owner, the Responsible Party.
Issues included selection of a location to perform the cleanup,
public safety, and entering a hold where a hazardous materials fire
had occurred.
This case will examine requirement for coordination and
communication in the response process.
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M/V ASTRA PEAK RESPONSE
The Response
BACKGROUND
On /January 1994 (Day 1), the U.S. Coast Guard
Marine Safety Office (MSO), Honolulu received a
call from the law firm Alcantara and Frame.
Alcantara and Frame was retained by the ship
owner to represent the vessel, /Astra Peak. They
were, told the vessel was carrying "general cargo"
and was making a port call at Honolulu for a
medical evacuation and to overhaul a fire in her
number three hold that was believed to be
extinguished. The Astra Peak made her first ever
U.S. port call, anchoring off of Honolulu Harbor.
The /Astra Peak was a 531 foot, semi-container
vessel with bulk holds and containers on top of the
hatches. She was en route from Japan to Mexico.
The /Astra Peak was owned by the Japanese firm
NKK and represented by the law firm of Alcantara
and Frame. The officers of the /Astra Peak were
British and the crew, Filipino.
The week before, smoke was observed coming
from the number three hold. In response, the hold
was flooded with carbon dioxide and the smoke
stopped seven minutes later. The fire occurred
during a storm which caused the ship to take
heavy rolls, some over 35 degrees. The hold
contained quantities of flammable cyanide based
pesticides, a super oxidizer, and over 5,000
pounds of matches. The number three hatch had
not been opened since the fire, so it was not
known what had fueled the fire or even if it was
out.
Although the Astra Peak came to port for a medical
evacuation (which was not related to the fire), she
needed to have the fire damaged hold overhauled
(assessed and repaired).
THE PROBLEMS
During a routine Coast Guard inspection, a leaking
cargo container was detected. The leaking material
smelled like pesticide. The material was later
identified as Terbufos, a pesticide produced in
China.
Terbufos
Technical Terbufos is a highly acutely toxic by
oral, dermal, and inhalation routes of exposure
(Toxicity Category I for all three routes.)
Animal studies have shown that the chemical
is a cholinesterase inhibitor reducing plasma,
brain, and red blood cell cholinesterase
activity.
Color
Physical State
Odor
Clear, brownish
Liquid
Mercaptan-like
EPA Pesticide Fact Sheet 5.2, 1988
The /Astra Peak response then evolved into a two
part response, the first was the pesticide cleanup
and the second was the fire in the number three
hold. ;
The problems included the cleanup of the
organophosphate pesticides which had
contaminated a large area of the deck and
numerous containers.
® How do response personnel enter the
container?
® How many of the other containers have been
affected?
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® Has Terbufos leaked into the number three
hold?
The fire damaged hold presented another suite of
questions.
* What is the best approach to access, clean
and repair the number three hold following
the fire?
e If HAZMAT was involved, how do we detect
what gases are in the hold and how do we
vent them off?
« What has burned and how do we cleanup the
by-products?
RESPONSE
From the information provided by Alcantara and
Frame, the MSO contacted the Astra Peak and
requested additional information concerning the
fire damaged hold. A copy of the dangerous cargo
list was faxed to MSO. From the contents in
number three hold, it was clear there could be a
hazardous materials (HAZMAT) situation. The
stowage plan also listed many other possible
dangers elsewhere, such as one area just listed as
"chemicals", but not what type. The dangerous
cargo list for the number three hold indicated:
@ 1110 kg of 2,4 Toluenediamine UN1709 - A
combustible substance and a suspected
human carcinogen.
9 2988 kg of Cyanide based pesticides UN2902
- Four substances; Danital, Fenvalerate,
Paraphenitidine, and Sumi-Alpha. All of these
pesticides are technical grade (concentrated)
and cyanide based. They are carried in
petroleum, are flammable and under heat can
break down into cyanide gas.
@ 3120 kg of Potassium Bromate UN1484 - A
super oxidizer, capable of supporting fire in
an oxygen deficient atmosphere.
2460 kg of Safety Matches
Flammable and easily ignitable
UN1944 -
The Honolulu Fire Department and HAZMAT team
was notified and put on standby. In addition,
experts; from the University of Hawaii were
contacted for technical advice.
The Astra Peak anchored off port at 2130 hours,
Friday,; 7 January 1994. An investigative team
• from the MSO and representatives from Alcantara
and Frame boarded the vessel that evening. The
Master and Chief Engineer believed the fire was
caused by cargo shifting when the vessel rolled in
heavy seas. They believed that the fire was out,
based ion temperature readings of adjacent holds
and vfents for the number three hold. The
investigation team walked the decks and noticed a
smell similar to that of fireworks. Paint blistering
was visible on the port side of the ship. The
matches were believed to have been stowed on
the starboard side, but the stowplan was not
complete. Sixty two bottles of carbon dioxide
were discharged to put out the fire and flood the
hold arid 48 bottles remained. The MSO and the
Master of the /Astra Peak felt that the carbon
dioxide remaining aboard may not have been
adequate to fight a second fire.
The MSO representatives requested that the master
develpp an action plan for the response to and
overhaul of the fire damaged hold. This action
plan was to include a site safety plan.
The major concern at this stage of the response
was whether the fire was out and how much
HAZMAT was involved in the fire. If the
potassium bromate oxidizer (KBrO3) was involved,
it would have supplied a large amount of oxygen
to the fire and the carbon dioxide would not
extinguish it. The fire could still have been
smoldering and might reflash if the hold were
opened. If the pesticides were involved, they
would have broken down into deadly gases that
would still be in the hold.
Alcantara and Frame retained two local response
companies, Pacific Environment and Industrial
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Technologies (PENCO/IT), for the fire recovery.
While neither company had great experience in
responding to a incident of this magnitude, they
organized with one response supervisor for both
firms.
On Day 2 (8 January 1994), six MSO personnel
boarded the Astra Peak with a USCG industrial
hygienist. MSO personnel conducted a standard
freight vessel boarding and no major discrepancies
were noted. An extensive examination of the
dangerous cargo stowage and segregation was
conducted to determine if the vessel had any other
HAZMAT problems. This inspection revealed one
of the containers on deck was leaking a substance
that smelled like a pesticide. The vessel was
ordered to stay at anchorage until the Captain of
the Port (COTP) approved their action plan.
On Day 4 (10 January 1994), officers from the
/Astra Peak met with the Captain of the Port, his
staff, and other interested parties including state
harbors, Honolulu Fire Department, Fire
Department HAZMAT, and PENCO/IT. The
meeting summarized past events and included a
discussion of whether the fire was out or still
smoldering (with a risk of reflash). Visual
assessment could not be made until the vessel
docked and the 40 freight containers stored an top
of the number three hatch cover were removed.
The vessel representative believed a visual
inspection was required to assess the fire damage,
shifting of cargo, and damage to hazardous cargo.
They proposed that the /Astra Peak dock at Pier 1A
in the Honolulu Harbor for damage assessment.
The COTP adjourned the meeting and met with
local and state representatives to discuss the
proposal. The COTP required the /Astra Peak to
remain at anchorage until air sampling from the
hold was conducted to determine if there were any
products of combustion from the dangerous cargo.
The proposal to dock at Pier 1A was accepted.
Later that day, it was reported the leaking container
on deck, which was noted during the initial
boarding two days earlier, was leaking an
organophosphate pesticide with the trade name
Terbufos. Terbufos is similar to a nerve gas and
can be fatal to humans in very small concentrations
and penetrates through the skin very readily. Why
this leaking container was not reported earlier is
unclear, apparently the vessel's crew didn't feel
that Terbufos was that dangerous. There were 49,
55-gaIlon d^ums of Terbufos in the container and
it was unknown how many were leaking. The
leaking container was stored in the middle of the
hatch cover on top of another container. All 40
containers must be removed before the hold could
be entered.'.
The fire in hold now became a second priority and
the Terbufos cleanup was the first priority. The
deck forward of the superstructure became
classified as a Level C exclusion zone. Two
members ofthe Pacific Strike Team were requested
for assistance. A CERCLA project number was
opened. The contractors Pacific Environment and
Industrial Technology were available to the RP for
cleanup and overhaul.
Following air sampling of the number three hold
vent, the FOSC met with vessel representatives to
discuss the. preliminary findings. The analysis
revealed no trace products of combustion that
could be attributed to the dangerous cargo in the
hold. The absence of by-products was not
definitive but supported all expert opinions that the
fire had been extinguished. Benzene, toluene, and
xylene, however, were detected in the 20 to 50
ppm range.
After discussion between the FOSC and the RP,
four additional Strike Team members were
requested; ,two from the Atlantic Team and two
from the Pacific Team. Two people from EPA's
Technical Assistance Team (TAT) and two members
of the U.S. Department of Health and Human
Services' Agency for Toxic Substances and Disease
Registry (ATSDR) were also contacted for on-scene
technical support. These actions were taken with
the concurence of the RP's agent, Alcantara and
Frame.
The next day (Day 6, 12 January 1994), vessel
representatives met again with FOSC staff,
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chemical experts, contractors, and other agency
representatives to hear the revised action plan for
mitigation. All present agreed that the fire was
most likely out. Lab results showed that the
substance leaking from the container was Terbufos
and it was 80% pure. Terbufos is easily
neutralized with an alkaline solution of bleach or
even a strong detergent. The Responsible Party's
plan was to bring the /Astra Peak to Pier 1A,
decontaminate the deck, remove all the containers
from the hatch cover, then enter the number three
hold. To ensure there was no reflash, the number
three hold would be flooded continuously with
carbon dioxide while on-deck decontamination
was being performed. The carbon dioxide was to
be supplied from on-shore sources.
On Day 8 (14 January 1994), the M/V /Astra Peak
tied up at Pier 1A, Honolulu Harbor. The vessel
was met by personnel from the MSO, Strike Team,
City Fire and HAZMAT teams, PENCO/IT, Police
Department, news media, State Department of
Health, and vessel representatives. The Strike
Team performed a Level B boarding on the vessel
and did not detect Terbufos with photo ionization
detector (PID) air monitoring. Following the Strike
Team assessment, PENCO/IT personnel began
removing unaffected containers from the deck.
The response went slowly. Numerous containers
had to be ungripped and removed by personnel in
Level C protective clothing. They found it difficult
to break container ties while wearing respirators
and some of the workers removed them. When
one worker became nauseated from the Terbufos
(which they assumed to be mercaptans and not
hazardous), others put their respirators back on.
By Day 9 (15 January 1994), the final unaffected
containers were removed from the deck. The
Terbufos container, the one below it, and a
contaminated adjacent container were left aboard
for decontamination.
After the unaffected containers were removed, a
hole was cut in the top of the container holding
the Terbufos drums to ensure the door could be
opened without causing further release. PENCO/IT
personnel than began setting up a decontamination
area and prepping the area for a Level A entry by
the Strike Team. A solution of water, isopropyl-
alcohol, and bleach was used for decontamination.
Delayed by heavy rains, numerous safety violations
as well as a lack of organization, work progressed
slowly into the evening. At 2100 hours, the FOSC
Representative and the RP observed gross safety
violations and secured operations for the evening.
Following that decision, FOSC and contractor
personniel met to discuss safety problems and
identified revisions to the site safety plan.
The next day (Day 10), operations went smoothly,
and the; Strike Team entered (Level A) the Terbufos
container and determined only one drum had
leaked. Soda was used to soak up the free
standing liquid and the water-alcohol-bleach
solution used for decontamination and light
cleanup. There were 49 drums of Terbufos in the
container. One drum near the door was leaking.
The leak was caused due to improper-bracing in
the container allowing loosely loaded drums to tip
over and roll. Terbufos leaked into a lower
container filled with granite sheets. While only
one of the drums leaked, all of the drums had to
be unloaded and decontaminated.
The next day, PENCO/IT entered (Level B) the
Terbufos container and used soda ash to soak up
free standing liquid. Empty drums were packed in
to prevent shifting when the container was lifted
off the ship. When the outside of the Terbufos
container was clean, it was brought onshore for
further i cleanup inside of the container. Gross
decontamination was performed on the granite and
Terbufos containers and a final cleanup of the deck
conducted.
Once the cleanup of the Terbufos was completed,
the response focused on phase two, the fire in
number three hold. As the on-deck cleanup
continued through Day 12, a meeting was held
with Hawaii Department of Health, vessel
representatives, contractors, FOSC representative,
EPA TAT, ATSDR, and Strike Team to discuss entry
into the hold. Air samples taken from the vent that
ran into the number three hold showed no
evidence of significant contamination, however,
they were taken from a vent, not the hold and may
M/V Astra Peak Response
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not have been representative. Samples taken later
did not reveal gases that would have been
produced by a fire involving significant quantities
of HAZMAT, but whether these samples were an
accurate representation of the hold was debatable.
All parties agreed, based on the latest air samples,
that venting the hold at the pier was appropriate.
Venting would be conducted by opening the vents
and using the ship's forced ventilation system to
blow air through the hold.
The next day (Day 13-19 January 1994), the State
of Hawaii wanted to reconsider the proposal for
venting the hold at the pier, proposing to use
scrubbers to clean the air. The SOSC was
considering requiring the vessel to vent at sea.
After a spirited debate, the FOSC dismissed
everyone but the SOSC representative and the
Responsible Party. A decision was then quickly
reached to vent the hold at the pier because
response to possible problems would be easier
with the ship at the pier. The idea of using
scrubbers was ruled out because none were
available that could be adapted to the ship or
handle the air flow expected.
As there was a 30 knot (35 mph) wind blowing
directly out to sea, the group decided to vent the
hold that afternoon. An EPA TAT monitoring team
would conduct air monitoring (in Level C). If
unacceptable readings were detected, the vents
would be closed and the blower secured.
The ship's forced ventilation system was used to
vent the hold. When venting began, 20% of the
lower explosive limit (LEL) was detected initially
with the levels declining sharply as venting
continued. Pierside air monitoring detected
nothing. The venting system was run throughout
the night for opening the next day.
On 20 January 1994 (Day 14), the final three
containers were removed from the deck and the
vessel's carbon dioxide bottles were replaced. The
number three hold was opened and the Strike
Team videotaped the inside of the hold and
conducted air monitoring. Based on the video, it
appeared that only the matches had burned.
Hold air monitoring detected only ambient air and
the deck of the /Astra Peak was downgraded to
Level D, while the inside of the hold remained an
exclusion zone (Level B). Final cleanup of the
Terbufos container took place pierside with Level
B inside the container and Level C in the support
zone around the container. The Strike Team
performed a Level B entry into the hold and found
the fire only affected the safety matches. No other
hazardous materials were involved (not even the
oxidizer or flammable pesticide drums that were
directly under the matches). The inside of the hold
was downgraded to Level D with respiratory
protection.
On Day 15, overhaul of the hold began. On the
pier, 11 suspect drums of Terbufos were transferred
to new drupns. All the drums in the container were
cleaned and properly repacked in a new container,
which was eventually loaded back on the Astra
Peak. Theicleanup area pierside is downgraded to
Level D after completion of the container
repacking., After five days, the /Astra Peak finished
the overhaul of the hold and departed Honolulu
(Day 20 - 26 January 1994).
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ASTRA PEAK RESPONSE
Discussion Questions and Epilogue
DISCUSSION QUESTIONS
1. What questions should response personnel ask
to identify a potential threat?
2, Initially, the /Astra Peak .was held offshore
during the assessment and response planning.
The RP had mobilized PENCO/IT but was not
able to execute the response with the ship
offshore. What factors should be considered
when deciding to bring a ship requiring
response in to the pier?
3. How can coordination with the state and local
governments be improved to maximize
cooperation and coordination during the
decision making process?
4. How would interagency HAZMAT drills have
helped in this response? Should they be
required? How could they be conduducted?
5. How can the OSC obtain dedicated
representatives for a response to avoid
absences during decision making meetings?
6. What plans exist which will speed the
selection of a site for response to a mobile
spill (tank truck, rail car or ship)? How much
control does the response organization have
in site selection?
7. What orientation should be provided to
personnel operating on the "fringes" of
hazardous materials handling?
8. How can site control be implemented to
protect shipboard personnel?
9. How can health and safety threats be
communicated to non-response personnel?
10. How can response personnel validate a
dangerous cargo list for accuracy? What
options exist if the dangerous cargo list is
perceived as inaccurate?
EPILOGUE
Numerous agencies came to assist the Federal On-
Scene Coordinator (FOSC) in this response,
including the Pacific and Atlantic Strike Teams, the
U.S. Department of Health and Human Services
Agency for Toxic Substances and Disease Registry
(ATSDR), and EPA's Technical Assistance Team
(TAT). The State OSC representative varied during
the period.
Although the response was successful, mistakes
v/ere made and there were setbacks. Hawaii is not
a big port and has not had many shipboard
HAZ/viAT responses. As a result, our local
contractors have not had much experience.
PENCO and IT had not worked together before.
This resulted in some organizational problems
which became safety problems. They were
addressed and corrected early on and by the end
of the two week response, the two companies
worked well together.
Communications problems occurred throughout the
response. Although the Unified Command
Structure was used, many problems were a result
of the lack of consistent participation by the State
of Hawaii. There were also problems getting
accurate information from the Astra Peak crew who
didn't feel the threats were really a big problem.
M/V Astra Peak Response
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M/V ASTRA PEAK RESPONSE
Notes
Page 44 M/V Astra Peak Response
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