Emergency Response

Benzene Railcar on fire in derailment (a lot to look at)

When you see it… Flammable liquid railcar, in fact, it’s a carcinogenic flammable liquid, a Benzene railcar on fire. I know it’s hot as heck in MS this time of year, but dang: Just a lot of opportunities! The better option: Set up an unmanned(!!!) monitor nozzle, lay a couple hundred, if not 1,000s, of…...

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How can I tell if a facility is doing their SCBA inspections “by the book” each month?

A trick question I learned long ago, when it was used on me, is one I use today when auditing a facility that has SCBAs for “Emergency Use Only” (e.g., an ERT). As we are walking to the ERT cage/trucks, I casually ask if the facility fills its bottles/cylinders or if they have a breathing…...

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Safety System (Shear Coupling & Sensor) failure during bulk transfer (Railcar) enabled anhydrous ammonia release

In August 2024, while loading anhydrous ammonia into a railcar at a manufacturing site, a shear coupling on the loadout arm failed to function. Two out of three bolts failed, causing the coupling to open and resulting in a loss of primary containment (LOPC) of pressurized liquefied ammonia, which formed an ammonia vapor cloud.  A…...

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Large-scale (10K pound) Cl2 Release in Freeport, TX

Betting this was just under 10 pounds. That’s a RQ joke as the RQ for Cl2 is 10 pounds – CLEARLY we have exceeded that in this event. (But you never know!) All jokes aside, this is a big one. People wanting to know why it’s taking so long to get an “all clear” 2-hrs…...

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EPA EPCRA/CERCLA citations ($65K) for 350 pound NH3 release from refrigeration process

Respondent produced, used, or stored ammonia at the Facility and released a reportable quantity of an EHS, ammonia. On or about August 31, 2022, a “release,” as that term is defined by Section 329(8) of EPCRA, of ammonia in excess of 100 pounds occurred at the Facility (the release). As a result of the information…...

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Fire Captain falsified Fit-Test Records and is facing charges

A 45-year-old senior fire captain is facing charges after authorities say he improperly conducted respirator fit tests for firefighters and lied about it. He is charged with forgery and tampering with records, the County Prosecutor’s Office said Friday. He signed reports stating the tests had been completed when they had not been finished between Jan…....

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Standards Referenced in OSHA Proposed Rule 29 CFR 1910.156 (Emergency Response)

The following NFPA and ANSI standards, in whole or in part, are to be incorporated by reference into proposed rule 1910.156, per 29 CFR 1910.6. See 29 CFR 1910.6(a)(1). Provisions in the proposed standard are drawn from, or consistent with, the following NFPA standards, but these standards are not proposed to be incorporated by reference:…...

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EHSs and the EPCRA emergency planning requirements

What is purpose of the list of extremely hazardous substances in regards to the emergency planning requirements of EPCRA? The extremely hazardous substances list and its threshold planning quantities are intended to help communities focus on the substances and facilities of most immediate concern for emergency planning and response.  However, while the list includes many of…...

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Release notification requirements for releases of Aqueous Film Forming Foam (AFFF)

Aqueous Film Forming Foam (AFFF), a substance commonly used by firefighters, contains ethanol, 2-(2-butoxyethoxy) which is categorized as a glycol ether.  Glycol ethers meet the definition of hazardous substance in CERCLA 101(14) because they are hazardous air pollutants pursuant to 112(b) of the Clean Air Act.  In 1990, the Clean Air Amendments added 47 individual…...

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Responsibility for SDS Accuracy (EPCRA)

This once caught my eye after all the issues I have encountered with lame SDSs! Remember, these are the first line of information for responding agencies, and man, have they gone downhill over the years. With all the hype of how the GHS would improve the MSDSs of the old days, it has been a…...

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Spills onto concrete floors inside a building (EPCRA reporting)

A facility has a spill of an extremely hazardous substance in an amount greater than its reportable quantity.  The spill occurs on a concrete floor that is inside a facility building.  Before the spill can be cleaned up, a portion (less than RQ) of the EHS enters the outside atmosphere through the window.  Persons in…...

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Who must be notified of a release under Emergency Planning and Community Right-to-Know Act (EPCRA)?

The notice required by section 304 of EPCRA is to be given by the owner or operator of a facility (by telephone, radio, or in person) immediately after the release of a CERCLA hazardous substance or of an EHS at or above the RQ. Notice is to be given to:… Membership Required You must be...

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