Hydrochloric Acid Leak at a Mountain Rest Area
You are westbound on I-70 near Vail with 1,000 lb of UN1789 hydrochloric acid (Class 8, PG II) in 10 drums. At a rest area, you find one drum leaking from a seam; about 25 gallons has run onto asphalt and is heading toward a curb and a snowmelt drain that leads to Gore Creek. No one is injured, no fire, and the rest area is open. You have a spill kit with absorbent, a phone, and the shipping paper. The drum is still upright and leaking slowly. The weather is clear, 45°F, and traffic is light. Your dispatch wants you to clean it up and keep the delivery window in Grand Junction, 3 hours away. The rest area has a water spigot and a trash can.
1. List your immediate actions in order.
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- Stop and park away from the leak; set the parking brake, shut off the engine, and do not smoke. 2) Keep people back and warn them; do not let anyone walk through the liquid. 3) Put on acid-resistant gloves, goggles, and a face shield. 4) Identify the material from the shipping paper, UN1789, Class 8, and use ERG Guide 157. 5) Contain the leak: keep the drum upright, overpack it or plug the seam if trained, and dike the liquid with absorbent. 6) Protect the drain: block the curb and the snowmelt drain with absorbent, sand, or a drain cover. Do not wash it into the drain. 7) Call the supervisor and, if the liquid reaches the creek, call 911.
2. Who must you notify, and is this an immediate DOT report? Explain.
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Notify the carrier's supervisor and the shipper. Call the National Response Center at 1-800-424-8802 if a reportable quantity is released. The CERCLA reportable quantity for hydrochloric acid is 5,000 pounds; 25 gallons is roughly 250 pounds, so this release is below the RQ. It is not an immediate DOT report under 49 CFR 171.15 because there is no fatality, no hospitalization, no evacuation of 25 or more people for an hour, no closure of a major artery for an hour, and no fire. But I would still call the NRC if the acid reaches Gore Creek or if I am unsure, and I would follow Colorado spill reporting requirements and company policy. Document the call times and names.
3. Can you clean up and continue? What about the drum and cleanup materials?
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I can continue only after the leak is stopped, the spill is cleaned, and the damaged drum is made safe. The leaking drum cannot be shipped as is. If it is overpacked, the overpack must be marked and the shipping paper must reflect it; otherwise the drum must be offloaded for repair or disposal. Cleanup absorbent and contaminated soil are hazardous waste and cannot go in the rest area trash. I would bag them, label them, and arrange proper disposal. I would inspect the other nine drums for leaks, take photos, complete the company incident report, and note the spill on the shipping paper or delivery records. If the drum is still leaking, I do not move the truck.