Leaking Herbicide Drum Near a Storm Drain
A small pesticide business stores a 55-gallon drum of a 2,4-D amine herbicide and a 30-gallon drum of an insecticide concentrate in a corrugated-metal shed behind its Ward 5 shop. The shed is 40 feet from a storm drain and has a gravel floor; the nearest sanitary sewer is 150 feet away. An employee discovers that the herbicide drum has rusted through near the bottom and about 2 gallons has leaked onto the gravel. The employee proposes to hose the area into the storm drain and then cover the stain with fresh gravel. A spill kit is stored in the shop but contains only sawdust and one pair of nitrile gloves; the product label and safety data sheet are in the office. The business has no written spill procedure. Rain is forecast in three hours.
1. What immediate actions should be taken, and what should the employee not do?
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Stop the leak if it can be done safely: upright or plug the drum, move unaffected containers away, and keep people back. Do not hose the product into the storm drain; that would turn a small spill into a discharge to the storm sewer and ultimately the Anacostia watershed. Do not cover the stain with gravel; that hides contamination and does not protect groundwater. Don protective gloves, boots, and eye protection; use the safety data sheet to identify hazards and the label for cleanup instructions. Ventilate the shed, eliminate ignition sources if the product is flammable, and place a temporary dike or absorbent around the spill to keep it from reaching the drain 40 feet away. Because rain is forecast in three hours, contain and cover the area first. If the spill is large or hazardous, call 911 and evacuate; do not attempt cleanup beyond training.
2. Describe the reporting, cleanup, and disposal steps, including when to notify authorities.
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Notify the business owner and follow the facility’s emergency plan. Notify DOEE’s spill line and, if the release meets a CERCLA reportable quantity or is a hazardous substance release, the National Response Center; also notify DC Fire and EMS if there is an imminent threat. Do not wait for the rain. Clean up with appropriate absorbent, not sawdust alone if the safety data sheet calls for inert absorbent; collect contaminated gravel and absorbent in labeled, closed containers for proper disposal as hazardous or solid waste according to DOEE rules. Do not put contaminated material in the regular trash or storm drain. Decontaminate reusable equipment and PPE; bag disposable PPE. Document the product name, EPA registration number, approximate amount (2 gal), time, cause, actions, and disposal manifests. Check whether the 2,4-D release is reportable based on concentration and quantity; report if required.
3. What prevention measures should the business adopt?
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Store pesticides in a locked, dry, ventilated area with a liquid-tight floor and no floor drain, away from the storm drain; use secondary containment such as spill pallets or berms for all drums. Inspect containers monthly for rust, corrosion, and leaks; replace damaged drums by transferring product to labeled, compatible containers. Keep a spill kit matched to the safety data sheet-absorbent, PPE, containment tools, and disposal bags-and train employees on the written spill procedure. Keep labels and safety data sheets accessible and post emergency numbers. Do not store pesticides near food, feed, seed, or PPE. Maintain inventory and inspection logs, and dispose of outdated products through a licensed hazardous-waste contractor. Verify that the shed location meets local setback and stormwater requirements; if not, relocate storage. Review the plan after any near miss and document training.