THE S OMETOWNS GUIDE

A PUBLICATION OF THE SAFE HOMETOWNS INITIATIVE

THE SAFE HOMETOWNS GUIDE

HOW TO DO A COMMUNITY REASSESSMENT OF CHEMICAL SITE SAFETY AND SECURITY AFTER SEPTEMBER 11, 2001

vulnerable zone

BEFORE

Storage tank

9 miles

Many lives in the community are at risk from accidental or intentional

chemical releases.

AFTER

500 feet

Using safer materials, reducing storage volumes, adding barriers, and relocating

nearest neighbors eliminates major community vulnerability.

A PUBLICATION OF THE SAFE HOMETOWNS INITIATIVE

THE SAFE HOMETOWNS GUIDE

HOW TO DO A COMMUNITY REASSESSMENT OF CHEMICAL SITE SAFETY AND SECURITY AFTER SEPTEMBER 11, 2001

For additional information, updates, links to other resources, and an online copy of this guide visit

AUTHOR Sanford Lewis, J.D.

EDITORIAL CONSULTANT Jonathan D. Fischer

REVIEWERS Susanna Almanza, PODER Joe Anderson, Labor Institute Nicholas A. Ashford, Ph.D., JD, Massachusetts Institute of Technology Dennis Atwood, Federal Emergency Management Agency Charles Barrett, Communications Workers of America/International Union of Electrical Workers Gary D. Bass, Ph.D., OMB Watch Charlotte Brody, Health Care Without Harm Richard Burton, St. James Citizens for Jobs and the Environment Tracey Easthope, Ecology Center of Ann Arbor Rick Engler, New Jersey Work Environment Council Alan Finkelstein, Firefighter and Cuyahoga County Local Emergency Planning Committee Lynn Goldman, MD, Johns Hopkins University Stuart Greenberg, Environmental Health Watch Rebecca A. Head, Ph.D., DABT, Director, Washtenaw County Dept. of Environment & Infrastructure Services Diane Hebert, Environmental Health Watch Rick Hind, Greenpeace USA Sylvia Kieding, Paper, Allied Industrial, Chemical and Energy Workers International Union Denny Larson, Refinery Reform Campaign Tamara Maschino, Clean Air Clear Lake Alexandra McPherson, Clean Production Network Fred Millar, Ph.D., Consultant Paul Orum, Right to Know Working Group Ted Smith, Silicon Valley Toxics Coalition Michael Sprinker, International Chemical Workers Union Prof. Rena Steinzor, University of Maryland School of Law Wilma Subra, Subra and Associates Dr. Paul Templet, Louisiana State University. Lynn Thorp, Clean Water Action Joel Tickner, Sc.D., Lowell Center for Sustainable Production, University of Massachusetts Lowell

Review and comment on this report does not imply endorsement. Organizations are listed for identification purposes only.

FUNDERS We are deeply grateful for the generous support of the following funders, without which the publication of this guide would not have been possible: Bauman Foundation Coming Clean Collaboration Mitchell Kapor Foundation Rose Foundation

NOTICE ON LEGAL OR TECHNICAL ADVICE. This educational guide does not constitute legal or technical advice. Facility owners and operators should consult legal and technical experts. Examples of alternative technologies and materials indicated in the guide are for illustrative purposes only. Inclusion in the guide does not indicate an assessment of the safety, feasibility or applicability of the alternatives for use at a particular facility, but only the mention of the alternatives in public literature.

FAIR USE NOTICE: This document contains copyrighted material for which the use has not been specifically authorized by the copyright owner. We are making this material available in our efforts to advance public understanding of security, safety and environmental issues. We believe that this constitutes a `fair use' of the copyrighted material as provided for in section 107 of the US Copyright Law. If you wish to use this copyrighted material for purposes of your own that go beyond `fair use,' you must obtain permission from the copyright owner.

A CHECKLIST FOR REASSESSING CHEMICAL

SITE SAFETY AND SECURITY

This checklist lays out steps for community reassessments of the safety and security of sites where chemicals are stored, used or produced. It provides a framework for inquiry and action by local emergency responders, local emergency planning committees, public health officials, businesses, workers, and concerned local residents to reduce and eliminate the dangers to communities from these facilities. Page references refer to sections in this guide that discuss this point

1. FORM A COMMUNITY REASSESSMENT GROUP. ...............................................................1-1

2. CONDUCT AN INVENTORY OF CHEMICAL SITE HAZARDS USING COMMUNITY RIGHT TO KNOW LAWS. .............................................................................2-1

A) Where are the chemical production and storage sites in our community? .................2-1 B) What are the dangers of hazardous materials being transported

through our community? ..........................................................................................2-4 C) What are the vulnerabilities posed to the community by facilities and

transportation? .........................................................................................................2-5 D) How have the events of September 11, 2001 changed our community's

understanding of the vulnerabilities and the needs for hazard reduction? .................2-7 E) Which are the priority facilities that pose the greatest danger to

our community? .......................................................................................................2-7 F) What are our priority strategies for hazard reduction?...............................................2-9

3. EVALUATE OPPORTUNITIES FOR REDESIGN TO ELIMINATE VULNERABILITIES AT PRIORITY SITES ............................................................................................................3-1

A) Have the choices of materials and processes used at the site increased hazards? ..........3-1 B) Have the range of inherent safety options been assessed or reassessed?....................3-4 C) Have the costs, benefits and tradeoffs of safety measures been evaluated? ...............3-7

4. IF VULNERABILITIES REMAIN, REASSESS BACK-UP SAFETY AND SECURITY FACTORS. ...........4-1 Buffer Zones/Siting Issues. ................................................................................................4-1 "Add-on" Safety Devices and Practices..............................................................................4-3 Site Security......................................................................................................................4-6 Emergency Response Plans. ............................................................................................4-11

5. IDENTIFY WHO CAN ADVANCE OR ENFORCE HAZARD REDUCTION ..................................5-1 Facility owners and operators ...........................................................................................5-1 Federal, state and local regulators ....................................................................................5-2 Local fire departments......................................................................................................5-3 Labor unions and community labor coalitions ..................................................................5-4 Civic organizations ...........................................................................................................5-5 Local emergency planning committees (LEPC'S) ................................................................5-6 Insurance companies........................................................................................................5-9 State and local lawmakers. ...............................................................................................5-9

6. COMMUNITY-WIDE RESPONSE STRATEGIES: IDENTIFY SHORT TERM AND LONG TERM ACTIONS FOR HAZARD REDUCTION..............................................................6-1

APPENDICES EPA List of Extremely Hazardous Substances ...................................................................................A-1 Examples of Alternatives to Extremely Hazardous Substances..........................................................A-7 Glossary .......................................................................................................................................A-13

THE SAFE HOMETOWNS GUIDE

iii

INTRODUCTION

This is a guide for local health and safety officers, elected officials, emergency responders, local emergency planning committees, businesses, workers and concerned citizens to reassess community safety and security regarding the storage, use, production and transport of extremely hazardous chemicals. Throughout the US economy, thousands of facilities use and ship high volumes of these chemicals, threatening populous communities near to facilities and transit routes where chemical releases can happen.

Most chemical incidents to date have involved accidental releases of chemicals to the environment. The terrorist attacks of September 11, 2001 made apparent that chemical sites around the US could also be targets of terrorists wishing to intentionally harm people and property. While hiring more security guards at these sites may safeguard against some threats, the truth is that these facilities are often so vulnerable that only sharply reducing or eliminating the presence of extremely hazardous substances can truly protect against intentional assaults.

The Blue Plains Sewage Treatment Plant in Washington, DC - located across the Potomac River from the Pentagon - was one of the first places after the September attacks to recognize and act in response to this threat. The facility began a rapid reassessment of its continued storage and use of liquid chlorine. The facility

housed 10 rail cars of toxic chemicals, and the rupture of even one of those cars could have killed thousands within minutes. Over the course of eight weeks, authorities quietly removed up to 900 tons of liquid chlorine and sulfur dioxide, moving tanker cars at night under guard as they raced to secure one of the Washington region's biggest toxic chemical stockpiles. While the conversion to safer materials had been planned to occur over a three year period, the sense of urgency resulting from the terrorist attacks yielded a shift to safer materials over just ten weeks.

Our Safety and Security Is Built Upon the Public's Right to Know

This guide is built upon the assumption that we will

continue to live in an open society, and that we will work to fight hazards and eliminate

vulnerabilities within that context. It details the needs

for responsible uses of information available to the public under existing Right to Know laws, and additional

"Routine" accidents at chemical sites were already a pervasive problem long before the new

information disclosures and institutional arrangements needed to reduce chemical

concerns. Thousands of acci-

hazards at vulnerable sites.

dental releases of hazardous

materials to the environment

have occurred at facilities where extremely haz-

ardous substances are used, stored and pro-

duced. Hundreds are injured or killed each

year. There is a real danger, in many locations,

of a chemical catastrophe that could lead to

the deaths of hundreds or thousands in a sin-

gle incident. In 1984 in Bhopal, India, a single

THE SAFE HOMETOWNS GUIDE

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