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EPA-430/9-80-012
August 1980
ILLINOIS CENTRAL GULF TRAIN DERAILMENT
CLAXTON, KENTU'CKY
Environmental Protection Agency
Oil and Special Materials
Control Division
Washington, D.C. 20460
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PREFACE
This report reflects the activities of the Environmental
Emergency Branch (EEB) Region IV, EPA, as it was concerned with
the captioned event. The report outlines the key actions of the
Federal Ch-Scene Coordinator, the Regional Response Team (RRT),
the state, local, and Federal members of the RRT. It reflects
the complexity of responding to environmental emergencies and the
need to coordinate and plan in advance for a major incident such
as this event.
This report is intended to satisfy the requirements of the
National Oil and Hazardous Substances Pollution Contingency Plan
and to help others learn from our experiences.
V. Smith, Chief
Environmental Emergency Branch
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TABLE OF CONTENTS
Section Page
1. SUMMARY 1-1
2. THE SITUATION 2-1
3. PHOTOGRAPHS 3-1
4. PROBLEMS ENCOUNTERED 4-1
5. ANALYSIS OF AIR, WATER, AND SOIL SAMPLES 5-1
a. Report on Air Monitoring
b. Laboratory Analysis of Water
and Soil Samples
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1. SUMMARY
Eighteen railroad tank cars containing vinyl chloride, hydro-
fluoric acid, ethyl acrylate, sodium chlorate, chlorine, caustic
potash, and butadiene were derailed near Claxton, Kentucky. Caustic
potash, ethyl acrylate, and vinyl chloride were discharged from the
ruptured tank cars onto the ground about a quarter of a mile from
Montgomery Creek. The creek was dry at the time of the derailment.
A hopper car of sodium chlorate overturned and mixed with the spilled
ethyl acrylate. The reaction between the two chemicals created a
fire and polymerized some of the ethyl acrylate.
The primary problem associated with this derailment was the
burning of two vinyl chloride tank cars. One of the vinyl chloride
cars flared from a large rupture at one end of the tank car, the
other in the vicinity of the dome.
None of the other tank cars was leaking. However, the potential
for damaging these tank cars in the removal operation, thereby creat-
ing serious environmental problems, existed for seven days.
Meanwhile, the vinyl chloride tank cars were burning and would
have done so for several more days. It was decided to accelerate the
burning of the vinyl chloride by cutting holes in the tank cars with
plastic explosives.
Air Quality Problems
During the combustion phase of vinyl chloride, it is possible
that hydrochloric acid, phosgene, and carbon monoxide can be re-
leased. All of these products are highly toxic when released to the
atmosphere. Also, vinyl chloride is very reactive or explosive at
high temperatures or pressure.
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Thus, it was imperative for the vinyl chloride tank cars to
continue burning. No effort was made to use dry chemicals and carbon
dioxide to extinguish the fire. By putting the fire out, an explo-
sive condition could develop and endanger the integrity of the other
tank cars.
EPA and the Kentucky Department of Natural Resources and Envi-
ronmental Protection set up air surveillance crews to monitor for
toxic chemicals on a 24-hour basis. These crews responded to all
complaints from residents in the surrounding area. In addition, air
sampling was conducted on a routine basis.
Vinyl chloride was detected in the air on several occasions near
the burning tank cars. An acid mist formed during rainy periods and
settled in the valley near the wreck site. The acid mist irritated
the skin and made it difficult to breathe. Work was halted during
these periods.
Air samples were collected and tested for phosgene. However, it
was not possible to detect phosgene in the atmosphere while the vinyl
chloride tank cars were burning.
Venting of the Burning Vinyl Chloride Tank Cars
For seven days, the ruptured vinyl chloride tanks burned while
the other derailed tank cars were removed. One of the vinyl chloride
cars developed a frost line. It was estimated that 25% of the vinyl
chloride remained in this tank car. The other tank car contained
about 70% of its volume. The capacity of each tank car was 20,000
gallons.
A decision had to be made whether to let the vinyl chloride burn
out or vent the tank cars with plastic explosives and accelerate the
burning process. By letting the tank cars burn out on their own,
people would have to remain evacuated from their homes for a long
period of time. In addition, Illinois Central Gulf continued rail
traffic through the area. Thus, the potential for another incident
existed while the tank cars were burning adjacent to the tracks.
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It was decided to vent the tanks and assume a short-term risk of
polluting the atmosphere, rather than risk another explosive-type
incident. An Army Explosive Ordnance Disposal (EOD) team was brought
in by the On-Scene Coordinator to implement a plan for cutting two
holes in each tank car, using plastic explosives. This allowed the
vinyl chloride to flow out of the tank cars into a large diked area.
The vinyl chloride was then ignited by means of an incendiary device.
The charges were set by the EOD team on both tank cars so they
could be vented at the same time. However, the plastic explosives
did not cut through the egress hole on one of the tank cars. Another
plastic charge had to be set to puncture the tank car.
Once the tank cars were punctured, the vinyl chloride burned for
about one hour. This created a huge, black plume that was monitored
by EPA air personnel. It was raining at the time. The mixing of the
rain with the gases released from the burning of the vinyl chloride
created an acid mist. EPA advised the residents, through the
Kentucky State Police, to remain in their homes and out of the acid
mist.
Analyses of Water and Soil Samples
Soil samples were collected by the Kentucky Department of Nat-
ural Resources and Environmental Protection in the area where ethyl
acrylate, caustic potash, sodium chlorate, and vinyl chloride were
discharged. In addition, surface waters, wells, and cisterns were
sampled. Toxic chemicals were not detected in these samples.
Montgomery Creek was dry at the time of this incident. However,
there was concern that, after a rain, the chemicals could enter the
creek via runoff. A retaining structure was constructed to prevent
this occurrence.
In conclusion, this operation was conducted in accordance with
the Regional Contingency Plan; the plan worked and the operation was
a complete success.
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2. THE SITUATION
At 11:50 p.m., on October 17, 1978, a dispatcher for Illinois
Central Gulf Railroad (ICG), reported, via the National Response cen-
ter, a train derailment near Claxton, Kentucky. The initial report
indicated that five tank cars containing sodium chlorate, vinyl chlo-
ride, and hydrofluoric acid were derailed. One of the tank cars was
burning and some of the nearby residents were evacuated.
EPA official Fred Stroud forwarded the information to Jack
Stonebraker, also of EPA, who would become the On-Scene Coordinator
(OSC) for this spill event. Arrangements were made for the OSC and
Jim Littell of EPA's Air Emergency Branch to take the earliest pos-
sible flight to Nashville, Tennessee, in order to respond to this
incident.
During the early morning hours of October 18, EPA continued to
receive updates on the number of tank cars derailed and their con-
tents. Some of the derailed cars contained chlorine, ethyl acrylate,
and caustic potash. The nearest stream was approximately one-half
mile from the wreck site. In addition, two tank cars of vinyl chlo-
ride were burning.
EPA requested assistance from the Gulf Strike Team (GST) and the
Public Information Assistance Team (PIAT). The Gulf Strike Team was
to bring personnel safety equipment and a mobile command post. Both
teams would arrive on-scene later in the day to assist the OSC.
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Response and Observations: Chronological Events
October 18. 1978
Jim Littell and the OSC arrived on-scene at 11:30 a.m., met with
the Kentucky State Highway Patrol and Edward Clark of the State Fire
Marshall's office and obtained the following information:
Eighteen cars were involved in derailment.
Tank cars containing ethyl acrylate, caustic potash, and vinyl
chloride and a hopper car of sodium carbonate had been ruptured
and material discharged on the ground.
The other tank cars containing butadiene, hydrofluoric acid, and
chlorine apparently were not leaking.
144 houses were evacuated in a two and one-half mile radius of
the wreck site.
Two tank cars of vinyl chloride were still burning.
The OSC met George Bradel and Don Hayes of the Kentucky Depart-
ment of Natural Resources and Environmental Protection (KDNREP).
They had just returned from inspecting Montgomery Creek for possible
environmental damage due to the chemical substances discharged from
the ruptured tank cars. However, Mr. Bradel reported that the creek
was dry. There wasn't any evidence of chemical substances in the
streambed. If it rained, there was a possibility that some of the
chemicals could enter the stream via runoff from the wreck site.
This information was forwarded to the EPA regional office. Joe
Lafornara of the Emergency Response Team (ERT) was enroute to observe
the operation.
Ben Eason and Richard Griggs of the PIAT arrived on-scene. The
OSC discussed the situation with them and made plans for responding
to questions from the media and the public. This part of the opera-
tion would begin on the following day.
Early in the evening, Jim Littell and the OSC noticed an inver-
sion taking place in the low areas around the wreck site. The ther-
mal inversion caused the plume from the burning vinyl chloride to
stay close to the ground. There was a distinct odor in the air. The
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air was tested at several locations outside the evacuated zone for
vinyl chloride and hydrochloric acid. All of the instrument readings
were negative for these two chemicals.
October 19, 1978
The mobile command post arrived on-scene at 12:03 a.m. The
State Highway Patrol called South Central Bell to have telephones
installed in the command post.
1:00 a.m. - Bob Tittle of the State Fire Marshall's office reported
that the plume from the burning vinyl chloride cars was much larger
than it had been in the afternoon. He requested that EPA monitor for
toxic chemicals downwind. Jim Littell and the OSC took readings for
the two parameters mentioned above at several locations around the
wreck site and in Dawson Springs, Kentucky, six miles away. The
instruments did not detect any hydrochloric acid or vinyl chloride.
2:47 a.m. - From the command post, a flare-up at the wreck site area
was noticed. The flames illuminated the sky and burned for about 45
minutes. There was speculation as to what caused the flare; some
throught the tank car fractured or exploded, while others thought the
safety valves released vapors that were ignited.
3:00 a.m. - While the tank cars were burning at an accelerated pace,
air samples were taken downwind at several locations. Although the
odor in the air was unpleasant, no toxic chemicals were detected.
7:10 a.m. - The State Fire Marshall reported toxic fumes along High-
way 672 and requested Disaster Emergency Services (DES) to evacuate
this area. The air in the area was monitored but no harmful chemi-
cals were detected. The air was very noxious and the inversion kept
smoke close to the ground.
8:20 a.m. - The OSC took an overflight in a helicopter. There was a
tank car of chlorine lying on a burning coal car. The tank car of
butadiene appeared to be upright and on rails. The ethyl acrylate
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was discharged on the north side of the tracks, had run down the
ballast, and mixed with sodium chlorate. Apparently, this mixture
caused a violent exothermic reaction, sending up a huge fire ball.
One of the vinyl chloride cars was burning from a rupture at one end
of the tank car. The other vinyl chloride car was burning at the
dome.
8:40 a.m. - The OSC held a meeting in the command post to discuss the
situation and review future plans. Agencies represented were as fol-
lows: EPA, GST, State Fire Marshall Office, State Highway Patrol,
DES, Hulcher Emergency Service, Illinois Central Gulf, and Kentucky
Department of Natural Resources and Environmental Protection.
The representative from Illinois Central Gulf provided a com-
plete list of derailed cars and their contents; six vinyl chloride
cars, one sodium chlorate car, one liquid caustic potash car, three
chlorine cars, two cars containing hydrofluoric acid, two ethyl
acrylate cars, one butadiene car, and two coal cars. Plans were to
maintain a status quo since conditions were basically stable. No
attempt was made to put out the fires from the vinyl chloride cars
because extinguishing them would create an explosive condition.
The question was, how long would the vinyl chloride burn? Esti-
mates ranged from one-to-several days. It was decided that Art Prof-
rock of Hulcher and a representative from the State Fire Marshall's
office would take a closer look at the burning cars. Self-contained
breathing apparatus would be utilized in the investigation.
9:30 a.m. - The news media arrived at the command post and asked for
information about the other two tanks that had exploded. The OSC
asked them where they got their information. Their reply was that
DES had dispatched a news release from Frankfort, Kentucky. It was
explained that the same two vinyl tank cars were burning and no other
cars had exploded. Evidently, the flare-up that occurred in the
early morning hours had been construed as an explosion of other tank
cars.
10:15 a.m. - The OSC talked to Debbie Hockensmith of the KDNREP about
setting up a sampling program for wells, surface water, and soil.
It was necessary to determine how far the spilled material had
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penetrated the soil and the direction of the migration. There was
also a possibility of contamination of cisterns and ponds from the
plume. Disposal sites were needed for the contaminated soil.
11:00 a.m. - Mr. Profrock returned from inspecting the vinyl chloride
tank cars. He reported that a frost line had formed on one of the
tank cars. His estimate of the volume of vinyl chloride remaining
was 20%, or 4,000 gallons. A frost line had not appeared on the
other tank car. Perhaps 75-80% of the liquid remained in the tank
car, or about 15,000 gallons.
12:30 p.m. to 3:00 p.m. - During this time period, Debbie Hockensmith
and the OSC conducted joint interviews with the news media. They
wanted to know what had transpired and EPA's plans for monitoring the
air and collecting water samples.
The news media were interviewing nearly every agency present.
It was obvious that a lot of misinformation had been given to the
media. Ben Eason suggested that a news conference be held on October
20, 1978. This would give the media an opportunity to ask questions
of a representative from DES, the State Fire Marshall's office, EPA,
Illinois Central Gulf Railroad, and the State Highway Patrol. The
OSC agreed, and the PIAT made plans for a news conference at 9:30
a.m. on October 20, 1978.
Later, Ben Eason informed the OSC that DES was the coordinator
for the state agencies, and all news releases had to come from their
office in Frankfort, Kentucky. Experience with this type of proce-
dure demonstrates that it doesn't work. Procedures for responding to
questions from the news media by the Federal OSC are clearly outlined
in the National Contingency Plan. Plans for the news conference pro-
ceeded, regardless of whether DES and the other state agencies parti-
cipated.
3:30 p.m. - Mr. Randolph Jensen, Engineer for Rohm and Haas, visited
the command post. Rohm and Haas was the shipper for the two ethyl
acrylate tank cars. Mr. Jenson was helpful in the discussion of the
properties of ethyl acrylate. In his opinion, the mixing of the
strong oxidizer sodium chlorate with the ethyl acrylate started a
fire. The burning of the ethyl acrylate or exposure to heat spon-
sored polymerization to a noxious resin.
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The safety engineer for Illinois Central Gulf came into the
command post looking for Mr. Jensen. He wanted Mr. Jensen to locate
a clean tank car for the transfer of ethyl acrylate remaining in the
ruptured car. The ruptured car was located across the track upwind
from the burning vinyl chloride cars. It was possible that the ethyl
acrylate could be safely removed by a pumping operation.
Mr. Jensen said that the clean cars were located on the east
side of the wreck site. The damaged tank car was on the west side.
The OSC suggested that they get some tank trucks and load them on
flat cars. It was estimated that 10,000-12,000 gallons of ethyl
acrylate remained in the tank car. Therefore, only two tank trucks
would be required. Mr. Jensen said that tank trucks could be on-
scene the next day.
Approximately 250 feet of hose and a diaphragm pump, which could
be run off the train engine, were needed. Arrangements were made by
Mr. Jensen to begin the pumping operation on October 20, 1978.
5:00 p.m. to Midnight - Air monitoring teams were set up to respond
to any complaints. During this time period, several complaints came
in about fumes in certain downwind areas. The instruments were un-
able to detect any harmful chemicals.
October 20, 1978
Midnight to 7:QQ a.m. - Air complaints were responded to, and the air
was monitored on a routine basis. Most of the complaints of a bad
odor came from the citizens in Dawson Springs, Kentucky, about six
miles from the wreck site.
The OSC talked to the chief of police of Dawson Springs. He
indicated that the people really didn't know what was involved in
the train derailment. Most of them wanted to evacuate their homes,
especially when they could smell the fumes in the air.
The air was sampled at several locations in Dawson Springs, but
no harmful chemicals were detected.
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9:00 a.m. - Four television stations and several newspaper reporters
were present for the news conference. Representatives from DES, the
State Fire Marshall's office, Illinois Central Gulf Railroad, Hulcher
Emergency Service, KDNREP, and EPA participated in the conference.
It went well, and afterward, the news media were allowed to go on-
scene to take pictures of the derailment.
11:00 a.m. - An air monitoring crew consisting of Jim Littell and two
members of the Gulf Strike Team went on-site. There were some fire-
men on-site putting water on a chlorine tank car, which was lying on
a burning coal car. Mr. Littell took an air reading for vinyl chlo-
ride and detected about 50 ppm in the smoke. After receiving this
information, the firemen and Hulcher's personnel immediately departed
from the area.
2:00 p.m. - The removal operation of the ethyl acrylate from the
damaged tank car to tank trucks on flat cars began at this time. Two
Gulf Strike Team members monitored the transfer operation. The oper-
ation was completed at 6:00 p.m.
3:00 p.m. - Ben Eason made arrangements with the mayor of Dawson
Springs for the town meeting. The high school gymnasium was reserved
for 7:00 p.m. Mr. Eason traveled to Dawson Springs to assist in
publicizing the meeting. All participants were notified.
7:30 p.m. - 50-100 people attended the town meeting in Dawson
Springs, Kentucky. Members of the panel were as follows:
Jack Stonebraker, EPA OSC
Jim Littell, EPA
Derris Kirkman, State Highway Patrol
Debbie Hockensmith, KDNREP
Rod Raby, Deputy State Fire Marshall
Ed Clark, State Fire Marshall's Office
Jim Walker, Governor's Aide
Mark Holcomb, State Fire Marshall's Office
Mayor Dickson, Dawson Springs, KY
Jannis Rice, Chief of Police, Dawson Springs, KY
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The people asked questions about the environmental problems
associated with the spill incident.
The director of a nursing home was present at the meeting. She
expressed a deep concern for the patients and whether or not they
should be evacuated. Mr. Raby stated that the city had a contin-
gency plan for evacuation. If something happened, the plan would be
implemented immediately. The people of Dawson Springs would have
adequate time for evacuation.
The meeting was very successful. There were no air complaints
during the rest of the night. However, the air was still being
monitored on a routine basis. Sample tests revealed no detectable
levels of harmful chemicals.
October 21, 1978
6:00 a.m. - Hulcher's equipment for re-railing the tank cars began to
arrive on-scene. They were unable to work in the area because of the
thermal inversion in the valley. Jim Littell and an air monitoring
team checked the area for vinyl chloride, hydrochloric acid, phos-
gene, and chlorine. No harmful chemicals were detected. Work could
not begin until the thermal inversion lifted.
9:00 a.m. - A meeting was held at the command post with the OSC, the
Kentucky State Fire Marshall, KDNREP, the Department of Transporta-
tion, and Illinois Central Gulf. Plans for this day were as follows:
Remove chlorine and caustic potash cars.
EPA & KDNREP would collect soil samples and water samples (both
well and surface waters).
Area would be cleared of all personnel except Hulcher's work
crew and State Fire Marshall.
Hulcher would provide safety equipment for their personnel and a
decontamination station.
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10:00 a.m. - Soil samples were collected from several areas where
spillage had occurred. Duplicate samples were taken, one to be
analyzed by the EPA laboratory, the other by state laboratories.
Another sampling crew collected samples from wells, cisterns,
and surface waters.
Noon to 6:30 p.m. - The caustic potash and two chlorine cars were
removed and put on trucks. The vinyl chloride and undamaged ethyl
acrylate cars were moved down the slope toward the tracks on the east
side. All of the tank cars were checked for leaks by Gulf Strike
Team personnel.
we received a report that the health care center in Dawson
Springs, Kentucky, was being evacuated. We checked with the chief of
police and the Health Care Center and found they were evacuating only
those patients with serious health problems. The state police, State
Fire Marshall, and the OSC all agreed that this was not necessary.
7:00 p.m. - During the day, several inquiries were received from
people who had been evacuated from their homes. They were concerned
about damage to crops and livestock.
Mr. H.W. Dorough, toxicologist for the University of Kentucky,
visited the command post to obtain information about the chemicals.
Mr. Dorough received available information from the Chemical Hazards
Response Information System (CHRIS) and Technical Assistance Data
System (TADS) files. He would evaluate the situation and release a
report through one of the state agencies.
October 22, 1978
6:00 a.m. to 6:00 p.m. - The coal cars, chlorine car, butadiene car,
and one of the hydrofluoric acid cars were moved and re-railed. The
hydrofluoric acid car was not put on trucks. Ramps were prepared to
move the burning vinyl chloride cars down the slopes on the north and
south sides of the tracks.
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A representative from Penn Walt Chemical Company talked to the
OSC about the spilled sodium chlorate. He said that sodium chlorate,
a strong oxidizer, is used as a herbicide; if mixed with any organic
material, it would ignite. He was concerned about Hulcher's person-
nel smoking in the area. Also, sodium chlorate is very soluble in
water. Therefore, any water applied in the area would allow the
sodium chlorate to migrate through the culvert under the tracks. The
culvert was blocked on the south side of the tracks but open on the
north side. Unless the culvert were blocked on both sides, the
sodium chlorate could run off into the culvert and be trapped under
tracks.
After receiving this information, no smoking was allowed in the
area, and the culvert was blocked on both sides.
Debbie Hockensmith and the OSC were concerned about the spilled
material entering Montgomery Creek via runoff from the wreck site.
This could be controlled by sumps, trenches, or a retaining struc-
ture. Hulcher's crew agreed to construct a retaining dike to control
the runoff. The structure was completed at 6:30 p.m.
8:00 p.m. - There was a report that a resident of Dawson Road had
been overcome by toxic fumes. Joe Lafornara and a trooper for the
State Highway Patrol responded to the complaint. They found that it
was a prank call.
October 23, 1978
7:30 a.m. - The OSC called Al Smith, Chief of the Environmental Emer-
gency Branch, EPA, Region IV. Mr. Smith was informed that the two
vinyl chloride cars were still burning and probably would burn for
several days. He suggested that holes be cut in the tanks using
plastic explosives, and that the vinyl chloride be ignited in a con-
trolled area.
The OSC talked to Rod Raby about Mr. Smith's proposal. The
State Fire Marshall's office was considering this possibility. Some
time ago, they had used an Army EOD team to cut holes in a butadiene
tank car near Louisville, Kentucky.
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10:00 a.m. - Mr. Raby said that his office was having trouble getting
an Army EOD team. He stated that it could take four-to-five days for
his agency to get a team on-scene. He asked if the OSC could speed
up the process and get an EOD team out of Fort Campbell, Kentucky.
Mr. Raby was told that the OSC would have to make a request to the
Chairman of the National Response Team (NRT), Mr. Ken Biglane.
10:20 a.m. - The OSC called Ken Biglane, EPA Headquarters, Washing-
ton, DC, and requested an Army EOD team. Plans were to cut two holes
in the tank car that was burning at the dome, and a single hole in
the other burning tank car. This would allow the liquid vinyl chlo-
ride to drain out into a large diked area for re-ignition. Mr.
Biglane said that he would make the request through the EOD represen-
tative on the NRT, Col. Sadler.
The removal of the remaining derailed tank cars continued. The
two tank cars of hydrofluoric acid would be the last cars to be put
on the trucks.
2:50 p.m. - Col. Sadler informed the OSC that he could set up direct
liaison with the 17th Explosive Ordnance Detachment at Fort Campbell,
Kentucky.
3:10 p.m. - The OSC contacted Sergeant Hobbs of the EOD and explained
what needed to be done. The EOD team would arrive at the command
post at 6:00 p.m.
4:00 p.m. - A light rain had been falling most of the day and a white
cloud began to settle in the valley around the wreck site. Jim
Littell and the OSC took the air monitoring equipment to the site.
The rain mixing with the gases from the burning vinyl chloride cars
formed an acid mist. This was very irritating to the nasal passages,
which made it difficult to breathe and unpleasant to work.
Hulcher's crew stopped the removal operation for the day.
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6:00 p.m. - The EOD team arrived on-scene, met with the OSC and the
State Fire Marshall, and was given an explanation of what needed to
be done. They had worked with vinyl chloride before, but not burning
tank cars. They were confident, however, that the job could be done.
It was further explained that the holes would not be cut in the
burning tank car until all of the other tank cars were removed from
the area.
On the following day, the EOD team would conduct a practice shot
on a piece of scrap metal in an isolated area.
7:30 p.m. - Ben Eason and the OSC had a conversation with Rod Raby,
Ed Clark, and Bob Tittle. Mr. Raby said that he was envious of EPA
operations because of the command post, the public information group,
and the response of the news media. He claimed that the State Fire
Marshall's office did not have any money or equipment. They had to
borrow all of their equipment.
The OSC asked Mr. Raby what assistance he needed. He wanted
publicity in the news media to get recognition for his program. The
OSC told him that Mr. Eason could set up a news conference so that
the State Fire Marshall's office could explain the procedure for cut-
ting the holes in the burning tanks. Perhaps they could arrange for
the news media to get pictures and film of the detonation of the
burning vinyl chloride tank cars.
It was the OSC's understanding that the State Fire Marshall's
office had to coordinate this type of activity through the DES coor-
dinator. Mr. Raby indicated that he didn't want to comply with the
state contingency plan, primarily because DES had to make news
releases from the Frankfort office. He said it was a poor system.
Mr. Eason made several calls to the news media and arranged a
news conference for the State Fire Marshall's office for 11:00 a.m.
on October 24, 1978.
October 24, 1978
8:00 a.m. - The EOD team arrived and requested the OSC to sign three
civil release forms. They proceeded to the wreck site for the prac-
tice shot. Hulcher's crew continued to re-rail the damaged tank
cars.
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11:30 a.m. - The news conference was conducted by Rod Raby. EPA did
not participate.
1:30 p.m. - The practice shot on a piece of scrap metal was con-
ducted. It was a complete success.
2:00 p.m. - David Hill, EPA, arrived at the command post to take soil
and water samples back to EPA's laboratory in Athens, Georgia.
5:00 p.m. - Major Salter of the EOD team arrived at the command post.
He stated, in the presence of Rod Raby, that his instructions from
Col. Sadler were to coordinate all of the team's activities through
the On-Scene Coordinator. He wanted to explain a proposed plan for
the detonation of the tank car to both the OSC and the State Fire
Marshall. The plan was as follows:
Set charges in both tank cars and let vinyl chloride run into
the contained area and ignite.
Obtain self-contained breathing apparatus, protective clothing,
and backup unit.
Obtain background data on air, water, and soil just prior to
detonation.
The OSC told Major Salter that the personnel safety equipment
was available, and that soil and water samples had been collected for
analysis. The air would be monitored just prior to the detonation by
Jim Littell and state personnel.
Mr. Raby was under the impression that Hulcher would have all of
the damaged tank cars out of the area by 6:00 p.m. He wanted to set
the charges on one of the tank cars that evening. However, Jim
Littell advised the OSC and Mr. Raby that a thermal inversion would
occur that evening. He advised not to detonate the tank car that
evening because the inversion would keep the gases close to the
ground. This could cause some air problems in the area of Dawson
Springs, Kentucky.
The OSC told Mr. Raby that Mr. Littell's advice had to be con-
sidered. The OSC agreed that the tank cars had to be detonated and
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he would accept a short-term risk with air problems versus a long-
term risk of letting tank cars burn out. However, if the conditions
would be better at a later time then perhaps a waiting period was in
order.
Mr. Raby received word from Mr. Hogan that the tank car of
hydrofluoric acid and sodium chlorate wouldn't be moved until 11:00
a.m. the next day. Thus, the decision was made. The tank cars would
not be detonated until all of the other tank cars had been removed.
October 25, 1978
8:00 a.m. - Mike Donohoe, Jim Littell, and Kenneth Yates were stopped
at the check point by the State Highway Police. They were not
allowed on-scene under orders from the State Fire Marshall.
9:50 a.m. - Ben Eason informed the OSC that state personnel were con-
cerned about questions from Frankfort, Kentucky, regarding the treat-
ment of the state in the press.
10:00 a.m. - Mr. Raby wanted the EOD team to go directly to the wreck
site as soon as it arrived. The OSC wanted to talk to Major Salter
before he went on-scene about his plans and signing civil release
forms.
When the EOD team arrived, Major Salter and the OSC reviewed
the plan for detonation. The OSC also told him that there were some
problems with the State Fire Marshall, the reasons for which were
unknown. However, the OSC assured Major Salter that he would support
his plan in any way possible.
10:20 a.m. - The EOD Team, Jim Paskewich, and the OSC went to the
wreck site and met with Rod Raby.
Once again, Major Salter reviewed his plan. Mr. Raby agreed to
the plan, with two exceptions:
EPA air monitoring team would not be allowed on-scene to gather
background data.
The GST could provide backup as long as they remained outside
the evacuated zone. This was one mile away.
2-14
-------
After some discussion, Mr. Raby said that he would allow the OSC
to observe the detonation, but no one else from EPA or the U.S. Coast
Guard. He would allow Ben Eason to set up a movie camera in the
bucket of a bulldozer. Once this was accomplished, Mr. Eason was to
leave the scene. Prior to the detonation, the Army photographer, who
was part of the "firing" part, could trip the camera.
It was obvious to the OSC that Mr. Raby wanted to demonstrate
his authority. The OSC chose to monitor the radio in the command
post rather than challenge his authority and risk getting someone
hurt.
1:00 p.m. to 5:00 p.m. - The EOD team set charges on both tank cars.
All of Hulcher's equipment was moved out of the area. Just prior to
ignition of the fuses, Jim Littell, Kenneth Yates, Charles Dai ley,
and troopers for the State Highway Patrol took up stations on Highway
672 to follow and monitor the plume.
5:16 p.m. - The fuses were ignited, but only the charges on one tank
were detonated. A huge, black plume evolved from the ignition of the
vinyl chloride. It was raining at the time, which held the cloud
down.
A report came in from Mr. Littell that if the wind shifted, the
fumes could affect several houses. He recommended to the state
police that the evacuation zone be increased. The rain mixing with
the gases was creating an acid mist. Mr. Littell noticed a burning
sensation on his skin. He recommended to state police that people
beyond Highway 62 should remain indoors and stay out of the acid
mist.
5:47 p.m. - The EOD team reported that plastic charges cut a hole in
the top of the second tank car but not the bottom. Another plastic
charge would have to be placed in the bottom of the tank car.
9:29 p.m. - The second charge on the tank car was detonated and the
vinyl chloride was ignited. The same conditions that prevailed on the
ignition of the first tank car existed at this time. Jim Littell and
the state air people monitored the plume.
2-15
-------
Both of the tank cars were successfully ignited with complete
burning of vinyl chloride. Only one complaint was received from an
elederly man who was caught in the acid mist. He complained about a
burning sensation when he swallowed. It was recommended that the
rescue squad take him to the hospital where he could be examined by a
physician.
2-16
-------
3. PHOTOGRAPHS
3-1
-------
I .
AERIAL VIEW OF 18-CAR DERAILMENT
NEAR CLAXTON, KENTUCKY
-------
VINYL CHLORIDE TANK CARS ADJACENT TO HOPPER CARS
CONTAINING BURNING COAL
-------
CO
I--.
VINYL CHLORIDE TANK CARS. WHITE TANK CAR
CONTAINS HYDROFLUORIC ACID
-------
OJ
(Jl
TANK CARS, TWO OF WHICH CONTAIN CHLORINE
-------
co
01
VINYL CHLORIDE TANK CAR (NOTICE FROST LINE)
-------
CLOSE-UP OF RUPTURED TANK CAR WITH BURNING
VAPOR PHASE OF VINYL CHLORIDE
3-7
-------
U)
00
HEAVY EQUIPMENT MOVING TANK CARS TO
NORTH END OF TRACKS
-------
CO
I
UD
CHLORINE TANK CAR IN FOREGROUND WAS
REMOVED FROM BURNING COAL CAR
-------
I
I-
o
TANK CAR OF HYDROFLUORIC ACID BEING PREPARED
FOR RELOCATION
-------
CO
HYDROFLUORIC ACID TANK CARS IN RELATIONSHIP
TO THE BURNING VINYL CHLORIDE CARS
-------
I
K^
ro
TANK CARS Of CHLORINE AND VINYL CHLORIDE
REMOVED FROM WRECKAGE
-------
DAMAGE TO OUTER SHELL OF TANK CAR
3-13
-------
TANK CARS RE-RAILED ON NORTH END OF TRACKS
-------
co
i
COMMAND POST FOR FEDERAL, STATE, AND LOCAL
OFFICIALS LOCATED ABOUT TWO MILES FROM WRECK SITE
-------
I
11
en
ANOTHER VIEW OF THE COMMAND POST
-------
4. PROBLEMS ENCOUNTERED
The cooperation between the participating state agencies and the
EPA On-Scene Coordinator was remarkable for the first seven days.
Air, water, and soil samples were collected. There was an exchange
of information concerning the properties of the chemicals involved in
the derailment. The operation was smooth and efficient up to the
point just prior to the venting of the burning tank cars. During the
last 36 hours, however, several problems arose.
October 24, 1978
An incident occurred between Jim Littell and Rod Raby just prior
to the practice shot. Jim Littell was with the EOD team which was in
the process of setting the charges. Rod Raby advised him that he was
too close. Mr. Littell explained that he had the radio for the
team. Mr. Raby stated that the team didn't need a radio and to move
out of the area. Mr. Littell said that he was a big boy now. Mike
Donohoe, who was in visual contact with both parties, told Mr.
Littell that maybe he was too close.
The OSC, who was monitoring the radio in the command post, heard
the conversation. He advised Mr. Littell that he should move out of
the area. Littell reponded, "Okay, that's three and you are the
bossI'm gone."
From then on there was some friction between Mr. Littell and Mr.
Raby.
4-1
-------
October 25, 1978
The State Fire Marshall's representative refused the entrance of
EPA and Coast Guard personnel on-scene, giving the reason that it was
unsafe (however, at the time of the detonation, 60 people were re-
ported to be near the tank cars). In addition, previous authority to
enter the area granted GST personnel to set up backup equipment for
EOD was suspended.
By not allowing EPA and state air monitoring personnel on-scene
prior to the detonation, it was impossible to collect data on air
quality. The OSC asked Mr. Raby his reasoning for not allowing EPA
to monitor the air. He said that Mr. Littell could not come on-scene
because it wasn't safe and that B.F. Goodrich could monitor air with
their instruments and test for vinyl chloride. The OSC told Mr. Raby
that EPA could not support any of the data taken by B. F. Goodrich
unless EPA personnel were allowed on-scene. In addition, EPA wanted
to test for hydrochloric acid and phosgene, as well as vinyl
chloride. Mr. Raby said that EPA would have to monitor the air one
mile outside the evacuation zone.
Privately, Mr. Raby stated to the OSC that he had called EPA in
Washington, DC. It was his understanding that the OSC could take
over the whole operation. If that occurred, he would withdraw all of
the state resources. The OSC stated that it was his intention to
work with the State Field Marshall, not take over the operation.
Moreover, the Gulf Strike Team had been requessted by the EOD
team to provide backup with personnel equipment, so that, if one of
the EOD team members were hurt, Gulf Strike Team personnel would
respond and remove him to a safe location. The State Fire Marshall
insisted that the backup unit remain outside the evacuated zone.
This was totally unacceptable to the On-Scene Coordinator.
4-2
-------
The basis for the State Fire Marshall's reactions is not known;
it could have been a personality conflict or a breakdown in communi-
cation. Regardless, the success of the operation was jeopardized by
actions taken by the Fire Marshall.
Also on October 25, Ben Eason informed the OSC that state per-
sonnel were concerned about questions from Frankfort, Kentucky, such
as, "Isn't anyone from the state of Kentucky down there? All they
see is EPA in the news media." This was not true; the news media
interviewed state personnel several times. There was cooperation
with the public information officer for DES, Mr. Gordon Nichols, on
all news releases until he left.
Mark Holcomb said that everything in the newspaper was about
EPA and that he wasn't going to allow that to happen again in his
area. The OSC reminded both Mr. Raby and Mr. Holcomb that there were
federal laws and state laws. If a spill occurred again in Kentucky,
EPA would respond and utilize all of its resources to protect the
environment.
As far as the newspapers were concerned, the OSC stated that he
could not control what stories were written. All he could do was
give them factual information about the spill event, as outlined in
the National Contingency Plan.
A meeting took place between EPA and the various state agencies
in November, 1978, to discuss the problems associated with the spill
incident. The attached memos present information on the meeting and
its outcome.
4-3
-------
5. ANALYSIS OF AIR, WATER, AND SOIL SAMPLES
5-1
-------
»Tt:
SUBJECT:
FROM:
TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV, Athens, Ga. 30605
December 5, 1978
Trip Report 10/18/78 - 10/26/78
Technical Assistance Request for Air Monitoring Support -
Train Derailment, Princeton, Kentucky
James K. Littell
Air Surveillance
Doyle T. Brittain, Chief
Air Surveillance Branch
SUMMARY
On 10/18/78 we received a telephone call at 0020 requesting assist-
ance involving assessing air quality conditions around a 18 car
derailment in Princeton, Kentucky. Mr. Jack Stonebreaker, designated
On Scene Federal Coordinator, requested our assistance to accompany
him to Princeton, Kentucky for technical assistance pertaining to
assessing air quality toxicity and explosive levels, evacuation perim-
eters necessary to support environmental human and animal life in the
wreck area, and possible long-term damage assessment affecting environ-
mental surrounding caused by any air contaminant leakage from possible
ruptured vessels involved in the train derailment.
We assembled our necessary air sampling equipment and departed for
the derailment scene at 0500 on 10/18/78. Mr. Stonebreaker and I
arrived at the derailment at 11:00 on 10/18/78. After visual inspec-
tion of the scene we found the following condition at the derailment
site:
Eighteen cars were derailed on a 50 to 60 foot deep
slope angling approximately 30 degrees from the rail-
road tracks downward. The derailed cars were reported
to contain the following according to the railroad
manifest supplied. The disposition of each was sur-
veyed by EPA representatives on scene.
6 Vinyl chloride tanks - full - two burning - other
4 intact - liner structure unknown.
1 Sodium chlorate tank - contents partially spilled
and mixing with ethyl acrylate
2 tanks ethyl acrylate - 1 open and spilling -
eventually mixed and reacted with sodium chlorate
1 liquid potassium hydroxide ruptured with contents
spilled on ground.
2 hydrogen floride - intact but in a dangerous position
for possible rupture.
EPA FORM 1320-6 IRKV. 3-76)
5-2
-------
2
1 butadiene - intact - located adjacent to open ethyl
acrylate car - possible explosive hazard
3 chlorine tank cars - one tank ruptured on the outer
core with a coal fire burning around and under the
exposed shell. The other two chlorine cars were
apparently intact, but positioned on their respective
safety valves rendering the safety relief valves in-
operative.
I advised the Federal On Scene Coordinator to evacuate the wreck area,
let the scene be naturally flushed by the atmospheric air before con-
tractors should be allowed to attempt any cleanup. Also, I advised a
2 1/2 raile evacuation radius based on the thermally explosive nature
of the remaining cars and the potential toxic concentrations of chemi-
cals that could potentially be emitted violently in the case of an on
scene explosion.
No personnel other than EPA or State Fire Marshalls were allowed on
scene during this environmental purging process.
Five types of on scene air monitoring tests were conducted throughout
the entire episode including chlorine, vinyl chloride, hydrogen chloride,
phosgene and carbon monoxide. Additional emergency sampling tubes were
ordered and received on 10-20-78 at 0200 to refill the depleted supply
used at the wreck scene and surrounding neighboring areas.
During the entire episode from 10-18-78 to 10-26-78 EPA Air Surveillance
personnel and other Coast Guard and EPA personnel provided the following
assistance for the On Scene Coordinator.
1. Checked the wreck scene each morning before fire and environmental
personnel entered to assure no lethal concentrations would overcome the
entering personnel. Example: 8 dead in the chlorine episode incident
in Youngstown, Florida in 1978 when local populas rushed to the scene of
that derailment.
2. Responded to all air complaints from law enforcement and local citi-
zens involving obnoxious odors, clouds of smoke, etc. mostly occurring
during evening hours between 2100 till 0900 in the morning when ground
level inversion conditions would lift.
3. Provided technical assistance to Mr. Stonebreaker, Federal On Scene
Coordinator, by attending a two hour town meeting held on 10-21-78 in
Dawson Spring, Kentucky. This was requested by Jack Stonebreaker to
squelch rumors of unsafe air conditions being allowed to accumulate in
that town originating from the wreck area.
4. Provided advice on the extc-nt of a safe evacuation perimeter to be
used. This was constantly verbally updated depending on working condi-
tions and the potential of hazards to vessles being moved at the wreck
5-3
-------
-3-
sccne during cleanup operation being conducted by the Hulcher Corpora-
tion and the Illinois Central Gulf Railroad crews.
The following serious problems were encountered and should be addressed:
State of Kentucky Fire Marshall personnel would not allow any environ-
mental personnel on or near the scene of the wreck during the last two
days of the incident. The reasoning stated was not safety but they did
not want Federal people being made aware of the progress of the cleanup
because of publicity releases to the press constantly quoting EPA per-
sonnel as to the disposition of the public safety involved and environ-
mental damage to areas surrounding the derailment scene. This caused
unsafe working conditions to all civilian, local, state and army person-
nel on the derailment scene during the final stages of the cleanup.
The Kentucky State Fire Marshall's supervisor would not allow EPA air
personnel on scene for safety inspections on the day of demolition,
10-24-78. They said that B.F. Goodrich's personnel were monitoring
for vinyl chloride using a continuous vinyl chloride analyzer. This
same analyzer was used by EPA and State Air Pollution personnel on
10-23-78 and found to be unreliable and unstable. Local hydrocarbon
interferences, either negative or positive, were not addressed. Also,
Kentucky State Fire Marshalls provided Army personnel with a lower
explosion level meter that, as like the B.F. Goodrich analyzer, was
not calibrated. The EOD personnel did not know this at the time. On
10-24-78 at 20:54 "batteries went dead" in this explosion meter being
used to monitor the wreck scene combustible gas concentration while
Explosive Ordinance Demolition personnel were preparing to detonate the
second of two vinyl chloride tank cars. Fire Marshall Rabys radioed
instructors to "hit it on its side." These unprofessional sampling
techniques could have resulted in the loss of life of the four Explo-
sive Ordinance personnel from Fort Campbell, Kentucky plus all bystanders
allowed on scene by the Kentucky State Fire Marshall.
The evacuator's perimeter for the wreck scene set by the State of
Kentucky Fire Marshall's Office was between 3/4 to one mile. EPA
personnel requested a minimum of two and one-half miles due to the
severity of the compounds. No increase in evacuation perimeters
were requested by the Fire Marshall's Office during the actual
detonation of the vinyl chloride tanks. This resulted in the unneces-
sary exposing of local residences downwind of the detonation. The
evacuation perimeter was enlarged when EPA personnel visually observed
plume or black smoke discharged from the blast which was approximately
300 to 350 feet high, 1/2 mile wide and of unknown length, set down
on the downwind residential areas after the first detonation. State
police offices, local populous, and State and local Civil Defense and
environmental personnel voiced considerable concern about the breathing
conditions and acid mist forming from this discharged plume. The plume
5-4
-------
-4-
did not dissipate rapidly and citizens downwind of the detonation were
reportedly taken to the local hospitals for treatment from breathing
restrictions and burning skin. EPA and State Air Pollution peronnel
downwind of the detonation experienced skin burning, clothes were
bleached with white spots from the acid mist. Breathing was laborous
after the exposure but it was not known if it was fron the fumes or
lack of sleep. No detectable readings of vinyl chloride, hydrogen
chloride, or phosgene were detected at approximately 5 miles downwind
of the detonation area and inside the black plume discharge. Burning
of the skin was extremely evident.
The Princeton Fire Department was on scene during the demolition and
allerted to go into the wreck area if a house located on a bluff over-
looking the blast area was to catch fire. They were not made aware of
any of the dangers resulting from high temperature burning of vinyl
chloride resulting in phosgene, or from the vinyl chloride liquid
itself should they coine in contact with this principle substance. I
talked with the Princeton Fire Chief about protective equipment and
made him aware of the danger. This action could have caused unneces-
sary health problems or possibly a loss of life to one of the local
fire fighters or to the 50 to 75 spectators positioned approximately
150 yards upwind of the blast area.
ACTION
Action should be immediately taken to stop Kentucky State Fire Marshalls
from 1) Grossely and unnecessarily endangering the local populations and
road travelers from inadequate and unprofessionally devised evacuation
perimeters. Example: 3/4 to one mile during detonation of 30,000 gls.
of vinyl chloride 10-24-78. 2) From hindering State and Federal air
pollution specialists from doing their duties of protecting cleanup
workers, State and Federal environmental and investigation personnel,
etc., and local population and fire fighting crews by illegally instruct-
ing State Police officers to keep these specialists away from the scene.
3) From providing inadequate and uncalibrated air monitoring equipment
and unprofessional advice to personnel from the Explosive Ordinance
Demolition teams or similar professional organizations called into the
area when they are assisting in disposing of this type hazardous material
containers.
A conference should be set up with representatives of State agencies
involved to determine the responsibilities of each agency during this
type emergency to eliminate this type dangerous situation happening
again.
BACKGROUND
Request from Mr. Jack Stonebreaker of 10-18-78 for assistance in respond-
ing to train derailment emergency of 10-17-78.
K. Littell
5-5
Al Smith
-------
DATE:
SUBJECT:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV, Surveillance and Analysis Division
11/2/78 College Station Road, Athens, GA 30605
Analysis of Samples from Train Wreck at Princeton, KY
FROM:
TO:
Tom B. Bennett, Jr., Chief
Analytical Services Section
David Hill, Chief
Ambient Monitoring Section
SUMMARY
Attached are the results of analysis of the Princeton, KY, train
wreck samples (SAD Nos. 78C2943-46).
The water sample (78C2944) was analyzed by the purge-and-trap
procedure with no vinyl chloride or other volatiles being detected
with a minimum detection limit of 5 ug/1.
The sediment samples were all analyzed by a head-space procedure
for vinyl chloride and other volatiles.
The sediment samples were extracted with methylene chloride and
the quantitations on the ethyl acrylate were made from this
extraction.
The gas chromatograph/mass spectrometer was used for the above
analyses.
Five grams of Sample No. 78C2946 were diluted in water and analyzed
by the automated indophenol procedure. Approximately 40 mg/kg of
ammonia was found in this sample.
No other compounds were identified above a 0.5 mg/kg detection
limit.
ACTION
Transmittal of data.
BACKGROUND
Request for analysis.
Enclosure
EPA FORM 1320-6 IRETV. 3-76>
5-6
-------
Project Train Wreck
DATA REPORTING SHEET
J- 1 lllCCLUU, &.I ______ - . . ..... __, _, , v>
ANALYSES TO BE RUM
AD //
3C
943
944
945
946
in
i
^sl
STATION //
1
SSS*'lf.
:/.*ri£ 1A
2
3
ND- None detected.
Tr- Trace
NA-- Not analyzed for.
i/ Tentative identifi
Minimum detection lira!
* - Minimum detection
DATE
SAMPLED
__
10/23/78
1535
nation
£s are in paren
Limit for water
Vinyl
Chloride
mR/kf>
ND(0.5)
ND(''0
ND(0.5)
ND(0.5)
heses.
sample is
Ethyl
Acrylate
ms/klR
4.4
NA
28,000
ND(0.5)
5 'yg/t.
Ethyl-nor-
Propanoatei
ms/kp.
ND(O.S)
NA
tr<0.5
ND(0.5)
r
-------
Bqjartmrnt ©f Agrtrulturp
10-2/1-78 FRANKFORT
Gas Chroma tographic Procedure for the Determination of Ethyl Acrylate Residues in Soil
Reagents
7**^ **** &*#'"
Ethyl Acryl ate Standard,
Apparatus
50 Ml Screw-Top Erlenmeyer flasks (modified by boring a hole in the plastic
cap without puncturing the septum)
5000 microliter gas- tight syringe
Gas chrornatograph equipped with a flame ionization detector and a 1.5% SP 2250,
1.95% SP2401 column
Constant temperature water bath
Procedure:
Sample is ground to pass a 20 mesh sieve. Sample and standards are weighed into
separate 50 ml flasks. Flasks are capped and placed in a boiling water bath for
one hour. At completion of the volatilization period, with flask remaining in the
water bath, the septum is pierced and the sample of the volatile matter is
chromatographed under the following conditions:
Column temp: 75 C
Flow: 24 ml/min
Attn: 10
Inj temp: 105 C
FID temp 250 C
Slope Sens: .05
5-8
-------
r%
\
'
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20«6O
REPORT OF ANALYSIS
t. SAMPLE NO.
1,2 & 3
3. REGION
2. DATE COLLECTED
4. EPA REG. NO.
5. ESTABLISHMENT NO.
6. DESCRIPTION OF SAMPLE
Three soil samples in glass containers
7. NAME AND ADDRESS OF ESTABLISHMENT WHERE SAMPLE WAS COLLECTEOOnc/urfc ZIP code)
8. PRODUCT NAME
Ethyl Acrylate
Residues
9. LOT OR CODE NUMBER(S)
10. NAME AND ADDRESS OF PRODUCER (If different from 7 above)
tl. RESULTS OF ANALYSIS
Sample
Soil-1
Soil-2
Soil-3
Ingredient
Ethyl Acrylate
Ethyl Acrylate
Ethyl Acrylate
Method
GC-FID
GC-FID
GC-FID
Amount Found
Negative
173 ppm
55 ppm
»2. LABORATORY COMMENTS
13. SIGNATURE Oi LAO SUPEnv'1'.OR
Scott Brynn
t«. LABORATORY
Kv-s.t Fed Meat La
15. DATE
10-24-:
EPA Form 3540 i (f
-------
Illinois
Central
Gulf
An tC Induslrie* Company' Illinois Central
Gull Railroad
Two Illinois Cooler
November 9, 1978 ;.', - -.- 233 North Michigan Avenue
-: . -,.. '..'. Chicago. IL 60501
1 ,'.'' v " -:..;;': (312)5651600
Mr. Dame! R. Dolan
Chief, Hazardous Materials & Waste Management
Division of Hazardous Material Waste Management
Pine Hill Plaza
Frankfort, KY 40601
Dear Mr. Dolan:
Reference is made to our meeting on November 7, 1978 at Earlington,
Kentucky concerning possible environmental contamination resulting from
the train derailment at Mile Post 171, Claxtcn* Kentucky. In an effort
to determine the extent of any future environmental problems at the
site, we agreed to execute the following procedures:
1) On the north side of the track in the area where the ethyl acrylate
and vinyl chloride compounds were diked, qualitative samples of
the soils in the dike will be taken at weekly intervals to determine
the rate at which dissipation occurs.
2) On the north side of the track, core samples of embankment soils
will be taken to determine the extent to which the ethyl acrylate
soaked into the embankment.
3) The present dike on the north side will be enlarged to insure that
all residual materials in the dike will be sufficiently contained.
Additional grading will be used to insure the surface runoff will
be directed away from the dike area.
4) The present dike on the south side of the track containing the
vinyl chloride residuals,, will be modified to insure total contain-
ment.
5) A well will be dug at the toe of the embankment on the south side
to monitor the ground water quality of the area. Samples will be
taken at monthly intervals.
6) An additional soil sample on the south side at the toe of the
embankment will be analyzed qualitatively for vinyl chloride.
5-10
-------
-2-
A11 results of these analyses will be forv/arded to you as soon as
possible. I trust that this will meet with your approval, and if there
are any other questions please feel free to contact me on Extension
2384.
Very truly yours,
M. (7. McKinney
Environmental Engineer
cc: Mr. John E. McClure, Jr.
Envrfonmental Supervisor
Hazardous Waste Section
Pine Hill Plaza
Frankfort, KY 40601
Mr. Jack Vfatkins
Environmental Specialist
Division of Hazardous Material & Waste Management
Pine Hill Plaza
Frankfort, KY 40601
5-11
-------
* "'< OMITCO STATES
.? MA \ ENVIRONMENTAL PROTECTION AGENCY
5 ^X'^7 ~ KASMINCTON. D.C. 2046C
''H: "'-"'' REPORT OF ANALYSIS
1. SAMPLE NO.
127376
3. REGION
2. DATE COLLECTED
10-27-78
4. EPA REG. HO.
S. ESTABLISHMENT NO.
IS. DESCRIPTION Or SAMPLE
I
5 Soil & 1 Liquid samples in glass containers
~i. NAVE AND ADDRESS OF ESTABLISHMENT Vr'HEKE SAMPLE WAS COLLECTED'/nc Jud«- Z1T code) B. PRODUCT NAME
Vinyl Chloride &
r 1 Ethyl Aery late
Residues
L J
9. LOT OR CODE NUM3EWIS)
12. NAME AND ADDRESS OF PRODUCER (II ailU-rcnt from 7 above)
11. RESULTS Or ANALYSIS
Sample I Ingredient
4 Vinyl Chloride
Vinyl Chloride
6 Vinyl Chloride
7 Vinyl Chloride
8 Ethyl Acrylate
9 Vinyl Chloride
Method
GLC-EC
GLC-EC
GLC-EC
GLC-EC
GLC-FID
GLC-EC
Amount Found
Positive
Positive
Trace*
Positive
Positive
Trace*
.12. LA-JORATORY COMMLNTS
* Compounds could be showing contamination arid not actual residues
''3. MC-N'-M UFT OT LAM 5'J f !:' ?< VI y
* Scott [;ryr;n /-
5-12
jl*. I A riOHAI O;/>i n
Ob- [ 11-1-
78
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