- On Saturday, 2/17/24. Quala received an emergency request to get pipeline fluid from one of their customers. A truck was dispatched to pick-up the load and brought it back to the Yard (515 Industrial Blvd.). At that time, the Driver advised the Ops Supervisor that the load was pungent and he was instructed to keep the load on his truck, sealed.
- On Monday, 2/19/24. Quala off loaded the product into a solidification bay, which are located in an garage w/ open bay doors on the NE side of the property. The product was placed in the solidification bay, because it was an emergency load and Quala’s three solidification tanks already full of product.
- Quala’s normal operating procedures is to off load the pipeline fluid into the sealed solidification tanks. After the products separates, the water is filtered and discharged per their pre-treatment permit. The residual pipeline fluid is combined with saw dust to make a solid waste and is transported to a landfill.
- During the solidification process, saw dust is added to the product to create a solid waste that is allowed to be disposed of at a landfill. With the full load of non-separated pipeline fluid sitting in the solidification bay, the amount of on-site saw dust was not sufficient to solidify the product and suppress the odor. Quala covered the product with all of the saw dust on hand and added a deodorizer surfactant, while an emergency load of saw dust was ordered and delivered at approx. 8:00 AM. By 9:00 AM, the product had been covered with additional saw dust and the odor began to dissipate.
- At 5:22 AM on Monday, 2/19/22. Wooster Fire Division (WFD) was alerted for an odor investigation in the area of Bauer Rd. WFD responded and upon arrival found a strong odor present in the area of 515 Industrial Blvd. During the investigation, the Quala representative advised the emergency responders that they were off-loading a non-hazardous pipeline fluid that was brought in over the weekend. From the information provided, WFD determined that there was no immediate hazard and that the pungent odor had settled in the valley and was moving slowly due to the lack of wind on this morning.
- WFD responded to 5 calls for odor / gas investigation on the morning of 2/19/22, with no hazards found.
- On 2/19/24, the Wooster WWTP received a call regarding a foul odor/gas The supervisor went out to locate and identify the odor. Over the next couple hours a WWPC crew investigated and communicated with City Administration.
- At approx. noon, a Wooster wastewater pre-treatment crew (WWPC) was unable to locate the source of the odor. During correspondence with the Director of Administration, WWPC was advised that WFD had talked to a company on Industrial Blvd. and that the odors were not hazardous.
- The WWPC Supervisor and Utilities Manager performed an onsite visit to the location of the odor. The company apologized for the odor and advised that they were done with the process that was causing the odor.
- On 2/19/22, the WFD Community Risk Reduction Division (CRR) Chief continued to look into the issue and corresponded with a Quala Representative. After returning to the City around lunch and the odor dissipating. A social media post referencing the odor was sent out to advise the community that the odor was non-hazardous and should be mitigated by noon.
- On 2-20-22, City officials fielded multiple calls and inquiries about the odor. At the time there was no significant odor found. WFD CRR Division and Utilities staff continued to correspond with a representative from Quala on the cause of the odor and how to ensure that this type of event does not happen again.
- Quala provided our CRR Division with this summary: “On Saturday 2/17, we received an emergency request to get pipeline fluid from one of our customers. I dispatched the on-call driver to go get the load. He reported to me that it was pungent and I told him to keep it on his truck, sealed up, until Monday. When we off-loaded it, we had to put it into one of our solidification bays as our holding tanks were full and it takes the better part of a day to drain one. There was a smell and we covered it with as much sawdust as possible and applied a surfactant (smell-good) to it. I had an emergency load of sawdust delivered but that was not until 7:30-8 am. We covered the bay with more sawdust and the smell was stopped by 9 am. This was, unfortunately, a perfect storm as you said. It is now a standing order that one holding tank must be empty at all times and we are also working on further protocols just in case that is not sufficient one day. This is a non-hazardous product and has been vetted by our EHS department. It is something we bring in to the plant quite often. This was just an unfortunate situation.
Please reach out if there are any further questions and thank you for your understanding. We look forward to continuing our good working relationship with the city and your department.”
- On 2/20/24, the WWPC issued a notice of violation to the industrial user, under the authority of the user’s Industrial Discharge Permit issued by the City. The user was cited under the following sections of the permit:
III. PROHIBITED DISCHARGES
A. General Discharge Prohibitions:
5. Any noxious or malodorous liquids, gases or solids which, either singly or by interaction, are capable of creating a public nuisance or hazard to life or are sufficient to prevent entry into the sewers for their maintenance and repair.
Permittee will be required to fill out a follow-up report as outlined in the following section of their permit:
V. GENERAL TERMS AND CONDITIONS
C. Accidental Discharges/ Slug Loads: The permittee shall provide protection from accidental discharges of prohibited or regulated materials or substances. Should the permittee experience an upset in operations which result in a temporary state of noncompliance with this permit, or which causes the discharge of a slug load, the permittee shall immediately inform the Water Resource Recovery Facility by telephone (330-263-5294) upon first awareness of the commencement of the upset or slug load. A written follow-up report shall be filed by the permittee with the Water Resource Recovery Facility within five days. The report shall specify:
1. Description of the upset, the cause thereof and the upset’s impact on the permittee’s compliance status.
2. Duration of noncompliance, including exact dates and times of noncompliance, and if the noncompliance continues, the time by which compliance is reasonably expected to occur.
3. All steps taken or to be taken to reduce, eliminate, and prevent recurrence of such an upset or other conditions of noncompliance.
- On 2/21/22, the City received additional calls that the odor returned or did not dissipate completely. The Utilities manager, WWPC supervisor, Asst. Chief of CRR, and I all went out to investigate.
- Wooster staff identified a few pockets of odor in the downtown district. As a result of the found odor pockets, the staff went back to 515 Industrial Blvd. to have further discussion and investigate the on-going concern.
- Upon arrival of the Quala property, the odor became obvious again. We meet with the operations supervisor and he allowed us onto the property and explained to us the situation and their processes.
- At the time of the site visit, Quala had crews loading the non-hazardous solid waste product from the solidification bay into a semi for transport off the property and to a landfill. The operations supervisor advised that there was no odor on the property at approx. 4:30 am when he arrived at work. While loading the product for disposal onto the semi, the process disturbed the product allowing the odor to return. At approx. 8:30 am, while City staff were on site. Approx. 80% of the product had been removed and transported out of the City to a landfill. The operations supervisor advised that the remaining product will be gone by lunch time.
Quala took in a load of oil pipeline fluid, which is a byproduct of the gas/oil pipeline transportation process, and is created as the gas/oil is warmed and dried for distribution to the end user. This byproduct (pipeline fluid) is a combination of water and gas byproducts. The pipeline fluid is tested at the pipeline distribution site to ensure it is non-hazardous. If determined to be non-hazardous by an environmental safety and health employee, the load can be taken by Quala. Quala is not permitted by the Ohio EPA to treat hazardous materials.
Quala brings the non-hazardous “liquid” product on site and combines it with saw dust to create a non-hazardous “solid” product that is allowed to be disposed of at a landfill.
In this case, the City experienced significant odor events on 2 different occasions.
1) The offloading of the liquid product into the solidification bay.
2) The loading of solid product onto semi’s for transportation to the landfill.
To ensure this does not happen again. The Quala operations supervisor advised that they would keep one of the three sealed solidifications tanks empty and available for emergency use.
In the event that all three tanks are full, Quala will keep the product sitting in the truck tank sealed until it can be put into the sealed solidification tanks.
The City staff also requested all documentation on testing and ESH documents for the “pipeline fluid” to be forward to us ASAP.
The Quala Operations supervisor also advised that this is a normal process that their business provides. They process approx. 5000 gallons of liquid product a month and have had very little complaints since Quala has taken over operations.
A review of calls for service for 515 Industrial Blvd. showed 2 calls since 2016.