It looks like the BulkOperationCleanupAction.EntityCleanup constructor (called during the transaction) is calling cacheAccess.removeAll( session );

In the case of EntityReadWriteAccess this invokes the removeAll method inherited from AbstractCachedDomainDataAccess, which does:

getStorageAccess().clearCache( session );

So the cache is cleared here before the transaction is committed.

Also note that the release method in{{BulkOperationCleanupAction.EntityCleanup}} (called after the transaction is committed) calls cacheAccess.unlockRegion( cacheLock );

In the case of EntityReadWriteAccess this is a no-op.

(One possible approach might be to change EntityReadWriteAccess so that removeAll is the no-op and unlockRegion performs the cache eviction.)