Tuesday, January 31, 2012

More Waxahachie Emergency Response Notes

Last October I looked at the fire at the Magnablend chemical facility in Waxahachie, TX as a learning tool for emergency response planners. Recently the facility was once again in the news for emergency response activities related to the aftermath of that fire. According to a news article on WFAA.com recent rains in the area caused containment ponds that collected fire-fighting water (and subsequent rain fall that helped ‘clean’ the facility) to overflow; ponds that “were presumed to still be polluted with chemical residue” according to the article’s author Brett Shipp.

Typically these run-off collection ponds are initially put into place by emergency responders and later improved somewhat by whatever clean-up company comes in to remediate the site. The initial runoff from the firefighting effort would probably have the highest concentration of dangerous chemicals. That is presuming, of course, that teams are able to quickly get into the facility and stop whatever leaks remain.

The initial fill of these ponds is usually emptied quickly in an effort to limit any additional environmental exposure to the chemical mixture involved. Most professional site restoration companies are well experienced in the physical and legal requirements of this process. These operations should be coordinated with local emergency response personnel so that they can respond appropriately to any incidents that occur in the process.

The containment structures are typically left in place until final site clearance is received to collect any subsequent run off from facility clean-up operations or rainfall runoff. The water collected is usually less contaminated than the initial collection in these ponds, but, depending on the chemicals involved at the site, may still harbor dangerous levels of hazardous chemicals. Remember what constitutes ‘dangerous levels’ is dependent on the chemicals involved, some chemicals are still dangerous down to the part per million or even part per billion levels in the environment.

Local emergency response planners need to ensure that these collection ponds are monitored for contaminant levels and liquid level in the ponds. When heavy rains are forecast for the area consideration of draining the current contents before the rain event may prove to be beneficial. Areas of the country that experience frequent short-notice periods of heavy rainfall may want to consider requiring secondary containment facilities to catch any pond overflows.

Provisions need to be put into place to keep these ponds isolated from the community, including restricting access to the ponds. They certainly meet the definition of ‘attractive nuisance’ and may actually be potential targets for fringe elements of the radical environmental movement, particularly if the company involved is already on the hit list for whatever real or imagined environmental slights. Less radical elements may also attempt to include such sites in ‘environmental actions’ designed to call attention to the hazards.

As with all emergency response plans a formal process needs to be put into place to review these situations on an on-going basis. Initial emergency plans for all facilities housing dangerous chemicals need to include run-off management plans. Those plans need to be reviewed and modified as necessary before the incident commander turns the scene back over to the owner or the environmental remediation company designated for site clean-up.

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