A Corrosive IBC Leak at a Lafayette Truck Stop
At a truck stop near Lafayette at 6:00 a.m., you find a wet streak on your trailer deck and a pool about 3 feet across under the trailer. The load is a 330-gallon IBC tote of UN3264, Corrosive liquid, acidic, inorganic, n.o.s. (phosphoric acid), 8, PG II. The tote's bottom valve is partially open. Vapors are irritating, and two people nearby are coughing. A drainage ditch at the edge of the lot leads to a bayou. You have the shipping paper, emergency response information, PPE, and a spill kit with absorbent, but no acid neutralizer. The truck stop is busy with diesel traffic. You are 120 miles from the consignee and the customer expects delivery at 9:00 a.m.
1. What are your immediate actions and priorities at the scene?
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Protect people first. Keep everyone away and upwind, and do not let anyone walk through the pool. Call 911 and the truck stop manager, and tell them it is phosphoric acid and where the ditch and bayou are. Put on the appropriate PPE if you are trained; if you can safely close the partially open valve, do so, but do not create a vapor exposure. Dike the pool with absorbent or soil to keep it out of the ditch. Do not wash it down and do not use an incompatible neutralizer. Get the two coughing people to fresh air and medical evaluation; if they are hospitalized, that is an immediate-notice trigger.
2. What notifications and reports are required, and when?
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A release from a 330-gallon IBC-a non-small package-is a likely immediate-notice trigger, and any hospitalization would independently trigger notice. Call the National Response Center at 1-800-424-8802 as soon as practical and no later than 12 hours; also notify local emergency responders and the shipper. If the acid reaches the bayou, notify the state environmental agency. Then file the written hazardous materials incident report on DOT Form 5800.1 within 30 days. Keep copies of the shipping paper, emergency response information, and your notes.
3. Can you clean up the spill and continue the delivery? What must happen before the vehicle moves?
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Do not attempt a full cleanup unless you are trained and equipped for a corrosive acid. Use acid-compatible absorbent, containerize the contaminated material, and prevent runoff. The damaged tote cannot go back into service until it is repaired or requalified, or overpacked and properly marked. Inspect the trailer deck for contamination and decontaminate it. Only after the leak is stopped, the spill is contained, and the load is secured should you consider moving. If the tote is compromised, arrange a transfer or replacement at the site; do not deliver a leaking package.