In 2013, two remarkably similar accidents that resulted in releases of chlorine gas to the atmosphere were followed by also similar alleged failures by facility staff/management to comply with requirements to immediately notify federal and state agencies about the releases.  

The incidents, which resulted in EPA fines of $18,000 and $42,000, highlight the need for managers to make certain that all employees as well as nonemployees who come on-site and may handle chlorine or be near processes with chlorine or areas where chlorine is stored are aware of the steps to take if a release occurs.  

15-minute window

Regulatory authorities have generally defined immediate notification of a release of a reportable quantity (RQ) of a CERCLA hazardous substance or an Emergency Planning and Community Right-to-Know Act (EPCRA) extremely hazardous substance to mean the "person in charge" (CERCLA) or “owner or operator” (EPCRA) has 15 minutes after the RQ is reached to notify the National Response Center (CERCLA requirement) and the State Emergency Response Commission (SERC) and the Local Emergency Planning Committees (LEPCs) (EPCRA requirements) for each state and locality that may be affected by the release.  Under both CERCLA and EPCRA, the RQ for chlorine is only 10 pounds (lb). 

Chlorine is one of the most common and useful industrial chemicals, and the regularity with which it is shipped, stored, and transferred creates openings for accidental releases.  Chlorine is also toxic to humans and was used in trench warfare during World War I.

Chemical delivery

The first incident, which was reported by the EPA in March, occurred when the driver of a chemical truck mistakenly unloaded hydrochloric acid into a tank containing sodium hypochlorite at a company that processes beets in Paul, Idaho.  When the two chemicals mixed, there was a violent reaction and the tank lid blew off.  Close to 43 lb of chlorine gas were released into the atmosphere, said the EPA.  According to the Agency, the company notified state and federal agencies 46 hours late.

In the second case, also as reported by the EPA, a truck driver at a milk facility in Portland, Oregon, improperly off-loaded a nitric acid- and phosphoric acid-based chemical solution to a tank containing sodium hydroxide and sodium hypochlorite.  A violent reaction resulted, releasing 166 lb of chlorine gas over about 6 hours.  Eight company employees, a truck driver, two contactors, and a person who was driving by at the time of the incident were sent to the hospital.  The company notified the local fire department but failed to immediately notify SERC and the LEPC. 

Supervision and training

The two incidents emphasize the risks associated with deliveries of chemicals by individuals who may not take the proper precautions before off-loading into storage vessels or other equipment.  While the EPA did not specify precisely where the communication failures occurred in these incidents, the violations and fines point clearly to the need for close supervision of chemical deliveries and careful training and refresher training covering actions that must be taken, including immediate notifications, if a hazardous chemical release does occur. 

Information on CERCLA/EPCRA requirements for reporting hazardous releases