Saturday, September 6, 2008

AFFAIRS OF STATE

Arizona is somewhat unusual in that it has no county fire departments. Outside of some municipal city limits, small volunteer fire districts have been established for limited rural areas, but the majority of the state isn't served by any organized fire department. Recognizing this problem a number of years ago, the state Division of Emergency Management worked with the governor's office to produce a statewide response plan to address hazmat emergencies.

In the plan, the Arizona Department of Public Safety acts as the state's point of contact for notification. The legislature also tasked DPS with forming a hazmat unit to function as the primary state response. Hazmat technicians in the unit serve as state on-scene coordinators to help access the resources of other state agencies and to act as technical advisers at incident scenes where other public safety agencies have responded.

The state Department of Environmental Quality also has hazmat technician emergency responders. In the plan, DEQ functions as the on-scene coordinator for fixed facilities in addition to tackling the environmental consequences after a transportation incident has stabilized. State law gives no specific jurisdiction to state responders, so DEQ would have a primary incident command role only when there isn't another local agency having jurisdiction.

State technicians have been called on to handle a wide range of chemical transportation accidents, from supporting a municipal fire department to responding in a rural area with no fire agency having jurisdiction.

Municipal assistance

For an example of how the plan functions, consider how state hazmat technicians coordinated with a municipal fire department to handle a suspected toxic liquid spill in the small central Arizona community of Wickenburg. The April 2001 incident started when a truck driver reported to his dispatcher that he had seen liquid coming out of the back of a highway cargo tank with poison placards. The driver said that the truck was traveling with several similarly placarded vehicles northbound on U.S. Highway 89 out of Phoenix.

Department of Public Safety highway patrol units along the route were alerted, as was the police department in Wickenburg, the first town along the route of travel. A short time later, a highway patrol officer stopped a cargo tank with a poison placard, about 20 miles north of the first reported spill.

By this time, a member of the DPS state hazmat team was already en route to Wickenburg and arrived at the stopped truck within a few minutes. An inspection revealed no leaking liquid, but the driver related that four similar vehicles from his company with an identical load were on the road in front of him.

The truck's shipping papers described the load as “1 tank truck RQ Toxic Liquid, Inorganic, NOS (Sodium Azide), 6.1, UN3287, PG III, 5,000 gallons.” That lable breaks down as follows:

  • RQ indicates the chemical meets the EPA definition of a reportable quantity of a hazardous substance that can damage the environment if spilled.
  • The proper shipping name for the chemical, “toxic liquid, inorganic, NOS [not otherwise specified] (Sodium Azide),” means it is a solution of liquids that meet the DOT definition of a poison.
  • The number 6.1 is the designation of a poison or toxic chemical.
  • PG III means Packing Group III, the least toxic of chemicals classified as poisons.

Looking for the leak

The load originally had come from a major airbag propellant manufacturing facility in the greater Phoenix area and was destined for a hazardous waste treatment, storage and disposal facility outside Salt Lake City. The driver said it was actually waste runoff water from when their manufacturing line's fire sprinklers had activated for several fires the previous month. Because no leaking liquid was found, the truck was allowed to continue.

Shortly before, a state hazmat technician had driven through the area of the reported spill, just north of Sun City West. He inspected the roadway with a member of the fire department who was checking the area, but found nothing.

About this time, the Wickenburg Police Department found four of the poison-placarded trucks at a truck stop on the north end of town. A police officer had reported a damp spot under the back end of one of the cargo tanks. The police contacted DPS, where a hazmat technician researched the U.S. DOT Emergency Response Guidebook. He advised police to cordon off the area and keep everyone 80 feet from the apparent spill, based on the following recommendations regarding a UN3287 liquid from Guide 151:

“Isolate spill or leak area immediately for at least 25 to 50 meters [80 to 160 feet] in all directions [depending on size of spill.]… Generally a small spill is one that involves a single, small package (up to a 208-liter [55 U.S. gallon] drum); a small cylinder; or a small leak from a large package. A large spill is one that involves a spill from a large package, or multiple spills from many small packages.”

Litmus test

After the area had been cordoned off, DPS hazmat technicians arrived at the truck stop and coordinated with the fire department, which had been summoned to provide standby rescue, decontamination personnel and an ambulance. DPS technicians examined the area of the spill and determined it was possible that the leaking liquid could be nothing more than wash or rinse water from the rear of the truck. It's common for this nonhazardous liquid to be present after a cargo tank loading area has been cleaned.

DPS technicians contacted the shipper of the liquid to learn its characteristics. Because the use of detection instruments was the definitive way to decide if toxic liquid had spilled, the proper detection method had to be determined. The shipper advised that the liquid produced no flammable vapors and possessed no ionization potential, ruling out the use of combustible-gas indicators or photo-ionization instruments.

A chemist at the manufacturing facility advised that the liquid was alkaline, with a pH of around 11 or 12. Therefore, a simple litmus paper test could determine if the liquid was just water, with a typical pH of about 7, or the actual inorganic toxin. A strip of pH paper was dipped into a small amount of liquid found in a drip pan area around the rear discharge valve, immediately above the wet spot on the ground. Its color change was consistent with pH 11 liquid.

Once the DPS technicians learned that the actual product had been leaking, they contacted the trucking company. Their safety officer, familiar with the product, had the proper protective and spill equipment to handle the situation. Because Wickenburg is only about 50 miles north of the trucking company's main terminal, the safety officer could be on the scene in little more than an hour.

Coordinated transfer

The state of Arizona's hazmat spill contingency plan provides that for transportation incidents, DPS technicians assume the duties of state on-scene coordinator. However, after the scene is stabilized, an agency with primary jurisdiction can become the SOSC.

Because possible environmental consequences were evident at the time of the initial report, the state Department of Environmental Quality had been notified, and one of its emergency response technicians was en route. He arrived at the scene and, based on the identification of the spilled liquid, determined it would have to be cleaned up. DPS notified the carrier's safety officer, who said that the trucking company would handle it completely.

When the trucking company's safety officer arrived, he took responsibility for the spill, donned protective clothing and began to dig up the contaminated dirt. He had brought drums and containers of different sizes, and was able to place the contaminated dirt in a plastic bag, which was then closed inside a 5-gallon can. The can was dispatched with the rest of the trucks to the Utah treatment, storage and disposal facility for disposal along with the rest of the liquid load.

Absorbent material was used to soak up the quart or so of remaining free liquid in the drip pan area, and it was placed in the can along with the dirt. The safety officer completely decontaminated the rear of the truck, and the state DEQ representative notified the fire department that he was satisfied with the condition of the ground and vehicle. The incident was declared over, and the scene was cleared.

Successful coordination and cooperation between the Wickenburg police and fire department, state DPS and DEQ representatives, and the carrier had been the key to the rapid identification, stabilization and cleanup of the toxic liquid.

When no one's in charge

The DPS also is tasked with responding to hazmat incidents in rural areas where no fire department has jurisdiction. In a February 2000 incident, the driver of a vehicle transporting hazardous waste noticed that liquid was running out of the back of his trailer while stopped at a rest area on Interstate 10 about 30 miles south of Phoenix.

The vehicle was transporting a mixed load of hundreds of different containers of hazardous waste from a large number of different California generators, including several universities, the U.S. Coast Guard, hospitals and medical centers, laboratories, businesses, maintenance shops, a school district, and a prison. Such mixed loads are common in the waste transportation industry. The truck was placarded “Dangerous,” “Flammable” and “Flammable Solid — Dangerous When Wet,” and the 59 hazardous waste manifests for the load made a stack about 12 inches thick.

Liquid from leaking packages in the trailer had puddled on the ground behind the vehicle. Although the truck driver had tried to determine the problem, he and two rest area maintenance employees who had tried to help him became sick and were taken to a nearby hospital, where they were later treated and released. A state on-scene coordinator responded to the incident and immediately closed down and evacuated the rest area.

The Arizona Department of Environmental Quality also sent personnel from their emergency response unit to assist. The entry team opened the back doors of the trailer to begin to ventilate the load, and members sampled the air both over the spill and inside the vehicle. While a combustible-gas indicator did not register any readings, a photo-ionization instrument showed the presence of vapors in the vicinity.

Too much to count

The entry team couldn't determine immediately where the leakers were located, as the entire trailer was filled with hundreds of packages. There were 55-gallon drums, double-decked in the front of the trailer, and hundreds of 5-gallon pails triple-stacked on pallets and secured with plastic shrinkwrapping, along with dozens of 30-gallon containers.

The state on-scene coordinator contacted the trucking company transporting the load and arranged for a cleanup contractor from Phoenix to handle the incident. While responders awaited their arrival, crews from the Arizona DOT brought out barricades, traffic cones and portable electric signs, and closed the rest area.

Following the arrival of the cleanup contractor's personnel, a safety meeting was held to brief all concerned on procedures and the varying products in the load. Several entries were conducted to remove the readily-accessible small containers from the rear of the trailer to attempt to find the source of the leaks. All the initial entries were conducted in Level A chemical protective clothing and SCBA.

During the first of these entries, one of the detection and monitoring instruments indicated the presence of 500ppm of carbon monoxide. This reading caused the operation to be suspended temporarily while responders discussed the meaning of this indication. As a precautionary measure, arrangements were made to close down both east- and west-bound lanes of the adjacent interstate, if necessary. There were hundreds of different chemicals represented on the manifests, and there was no way of determining just which of them were involved in the leaks.

The state on-scene coordinator consulted outside technical experts, and all concluded that, in all probability, an “interference reading” was causing a false carbon monoxide indication. There was no fire in the load, and no apparent source for the carbon monoxide that the instrument had indicated.

Now a night operation, portable lighting equipment and generators were used at the site, along with multiple relief crews. As each of the packages was inspected, it became apparent that at least a dozen of them were leaking their contents, and that the entire load of hundreds of containers would have to be removed for complete inspection and decontamination of the packages and trailer. As the packages and drums were taken out of the trailer, tarps were spread over different adjacent areas of the rest area parking lot, and compatible groups were segregated and separation maintained.

The long cleanup

Once the majority of the packages were removed and it was clear there was no further imminent danger from the incident, the responsibility for the scene passed from the DPS to DEQ, and a new state on-scene coordinator from DEQ assumed command. Although DPS provides coordinators during the “fires and explosions” phase of an incident, the duty usually will pass to another state agency once the scene is stabilized.

The DEQ coordinator worked with emergency response representatives from the Arizona DOT and determined that the section of asphalt at the rear of the trailer had been heavily contaminated from the very outset of the incident. They required the cleanup contractor to remove this asphalt and treat it as hazardous waste. Most of the estimated 50 gallons of spilled liquid had penetrated onto the pavement at this location.

As the several dozen leaking packages were discovered in the trailer, they were decontaminated, resealed and overpacked at the scene. It was determined through monitoring that once the packages had been placed into segregation areas in the parking lot, there were no vapors present. Worker protection in this area then was downgraded to Level C. This operation went on for two days, because about half of the packages then had to be reloaded onto another transport vehicle.

The majority of the leaking packages were determined to be waste paint, although one 5-gallon pail of a poison had failed and leaked. Following reloading of the last packages, a thorough inspection of the new transport vehicle was made to ensure proper blocking and bracing of the containers. The parking lot was re-inspected to ensure that no residue remained from the spill, and the clean-up contractor received approval from the state on-scene coordinator to terminate the incident.

Despite the differences in supporting a municipal fire department to responding in a rural area where no fire agency has jurisdiction, the Arizona departments of Public Safety and Environmental Quality are prepared for a wide variety of hazmat incidents.


Stephen L. Hermann, the hazardous materials coordinator for the Arizona Department of Public Safety and senior state on-scene coordinator, has responded to more than 150 serious highway and rail hazmat transportation accidents. He has a bachelor of science degree in explosives technology and is a graduate of the U.S. Army Command and General Staff College and the U.S. Army War College. He has testified before House and Senate subcommittees and has been a member of numerous technical advisory groups for the U.S. departments of Transportation and Energy, U.S. Environmental Protection Agency, and the state of Arizona. He is an NFA guest lecturer.

Wickenburg

From this incident, the DPS determined:

  1. Multiple state and local fire departments, law enforcement and environmental agencies can function smoothly together at a chemical spill if unified command is used, and all are familiar with each other's capabilities.
  2. A shipper or manufacturer may need to be contacted to determine certain characteristics of a chemical to facilitate identification or operations at the scene.
  3. Having a knowledgeable environmental agency representative at a chemical spill scene can lead to rapid resolution of questions concerning the type and nature of cleanup required.
  4. Some trucking companies have the ability to mitigate their own spills and may not have to bring in an independent cleanup contractor, thus saving significant time in starting the work and completing it.

Interstate 10

From this incident, the DPS determined:

  1. Prompt notification of the trucking company involved in a leaking chemical incident ensures the quickest selection and arrival of a cleanup contractor at the scene.
  2. Some chemicals may cause false readings on some detection instruments, creating potential confusion and delay.
  3. When dozens of different chemicals are involved in an incident with leakers, Level A fully encapsulated vapor protective suits and scba need to be employed for entries until certain chemical identification is made.
  4. The need to inspect and decontaminate hundreds of hazardous waste packages in a single load can cause the operation to take several days.


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