Floods, Fires, and Outdated Disaster Plans at Chemical Facilities

Colleen and Casey discuss:

• Risk mitigation for communities near chemical facilities
• The dangerous combination of extreme weather and chemicals
• How we can work towards protecting these communities and first responders

Segment: Katy Love
Editing: Omari Spears
Additional editing and music: Brian Middleton
Research and writing: Pamela Worth
Executive producer: Rich Hayes
Host: Colleen MacDonald

• Hurricane Ida leaves Chemical Facilities and Surrounding Communities Without Power
• Double Jeopardy in Houston
• Chemical Safety: An Urgent Need for Science-Based Protections

Colleen: Right around the time we were planning this episode, Tropical Storm Nicholas was lingering around the Gulf Coast… dumping inches of rain on a region that doesn’t really need it, just over two weeks after Hurricane Ida caused widespread flooding and power outages.

When I think about storms like Nicholas and Ida, my first thought is for the threats to people’s immediate physical safety—like drowning, electrocution, being hit by debris, or the medical emergencies that can happen when power goes out. But there’s another threat that I don’t consider often enough… and that’s the threat to people’s health from damages to industrial facilities in their neighborhoods. Chemical plants, refineries, waste management plants… they can incur damages from the increasingly deadly effects of climate change, including floods, sea level rise, and wildfires. And this means everyone around them is at risk of being exposed to the dangerous chemicals stored within these facilities, whether it’s in the air they breathe, the water they must wade through to escape floods, or the water they drink.

It turns out I’m not the only one who doesn’t think enough about these risks. The Environmental Protection Agency requires chemical facilities to create what are known as Risk Management Plans, or RMPs. And these RMPs are supposed to protect the communities around them from exposure to toxic chemicals in a crisis. But many RMPs fall short much of the time, and neither local governments nor our federal government are doing enough to make sure they’re enforced.

It’s a good thing my colleague Casey Kalman is thinking about this problem. Casey is a researcher with our Center for Science and Democracy, and she joined me to discuss her new analysis of the potential risks to these facilities—and the marginalized communities they’re often located in.

Colleen: Casey, welcome to the podcast.

Casey: Hi, thanks for having me.

Colleen: Yes, it's great to have you here. You recently worked on a project that looked at the potential risk from natural disasters, which we know are becoming more severe with climate change to thousands of industrial facilities that store hazardous, potentially lethal chemicals. What types of facilities did your analysis look at and how did you determine which ones are vulnerable to natural disasters?

Casey: Yes. So our analysis looked specifically at facilities that are regulated under a very specific rule that is part of the Clean Air Act. So to give some background, it is part of the risk management plan rule, which is basically this rule that is put in place to make sure that facilities that are housing hazardous chemicals are doing everything they can to make sure that those facilities are not being released or leaked and having and effect on the people who both work at the facility and those who live in the surrounding communities. So we looked specifically at those facilities.

Colleen: What types of facilities would those be?

Casey: The facilities that are regulated under this rule, it's really a wide swath of different types of industries. And some of them are petrochemical facilities or oil refineries, while there are others that could be, for example, a brewery or a refrigeration facility that might be preparing food to go out to grocery stores and things of that nature. So making sure that they're frozen and then there are the refrigerant chemicals that are part of that process. So it's really a wide variety of facilities. And the number of facilities that are regulated under this particular rule is about 12,000 throughout the U.S.

Colleen: And are they spread across the country, or do they tend to be in consolidated areas?

Casey: So, they are spread relatively evenly throughout the country. I would say, in some ways, the distribution of facilities throughout the country somewhat matches the distribution of the population. So if you were to look on a map of the U.S., there are a large number of facilities clustered, especially along the Gulf Coast, as well as in California, kind of in that Central Valley of California, where there tends to be a lot of agricultural activity. And then the other states that kind of stand out when you look at a map of these facilities would be places in the Midwest like Illinois, Iowa, Kansas, other places where there tends to be a good amount of industrial activity.

Colleen: So you mentioned that there are roughly 12,000-plus facilities in the United States. How many of those facilities are threatened by natural disasters?

Casey: So, from our analysis, we looked at specifically facilities that are at risk of climate-related natural disasters. So we limited it to the types of natural disasters where we felt we could not only draw a pretty clear link between climate change and the natural disaster, but also where we had data available, where there was data available that would allow us to kind of identify which regions were at risk. So we looked specifically at wildfires, inland flooding, coastal flooding, and storm surge due to hurricanes. And we found from this analysis that there are just under 4,000, so about 3,800 facilities that are in areas at risk of one of those natural disasters. Some of which are at risk of more than one of those natural disasters.

Colleen: So what data did you look at for the different types of natural disasters?

Casey: So, for wildfire, we looked at the historic wildfire perimeters. So we identified areas that have previously seen wildfires in addition to using a data set by the U.S. Forest Service that actually identifies area of the country that has a high burn potential. So it's not only areas that have had previous fires, but there's the potential there for fires in the future. For the coastal flooding, we looked at a data set from a previous UCS report where we looked at the potential for coastal flooding as a result of sea level rise. So that was looking into the future into the year 2040. So, in that way, we were also trying to account for the fact that sea-level rise will cause a greater probability of coastal flooding along the Eastern Gulf Coast. And then we also use data from FEMA to look at 100 and 500-year flood zones, as well as data from the National Oceanic and Atmospheric Administration or NOAA to look at the probability of storm surge along the Eastern Gulf Coast due to a category 4 storm was the data that we used. So, in many ways, the data that we used for certain layers, it's giving us a very conservative estimate of the number of facilities at risk because we're not always...we didn't always look at the worst-case scenario, this is actually a somewhat conservative estimate.

Colleen: So are risk management program facilities, are those Superfund sites, or is that different?

Casey: So, that kind of gets into the fact that there are a large number of chemical facilities or just hazardous sites throughout the U.S., but a lot of them are actually regulated under different rules. So, Superfund sites are separate from risk management program sites. Yeah, they're not regulated under the same rules.

Colleen: Superfund sites are areas of land that are contaminated. Is that right?

Casey: Yes, exactly. So, Superfund sites are contaminated areas. It can be an area where a bunch of chemicals were dumped and then buried. Sometimes it can be...there's an entire river, , in the Midwest that is labeled a Superfund site. But basically, they have been contaminated usually by industry in the past and now have been designated a Superfund site because they are in need of funds from the Superfund, which the government has set up to then clean up that site. So the cleanup of those sites often takes decades and the process can be quite complex to get the level of contaminants down to a level that's no longer harmful or potentially hazardous. So that's another category of sites that could potentially be at risk. And I do think it is important to talk about the fact that this analysis only looked at the risk management plan sites because there are facilities that are not currently regulated under RMP that have been hit by extreme weather events and have caused the release of some toxic chemicals.

So, for example, just last year, as a result of Hurricane Laura, there was a facility called the BioLab Chlorine Facility in Westlake, Louisiana. It was hit by the hurricane and as a result of the damage, it released chlorine gas into the surrounding community. And it was said that most of this gas settled pretty close to the facility, but there have been some accounts in some local news reports that say that people who were waiting to get back into their homes after being evacuated, they felt nauseous, or they were having trouble breathing. And that's a facility that's not regulated under RMP, but at the same time, it does have the potential to, I mean, as we've seen, it has released toxic chemicals into the surrounding community. And that facility, they're planning on rebuilding it in the exact same spot. And if they don't take the necessary steps, it's likely that something like this could happen again.

Colleen: So, Casey, have we already seen "double disasters," which I know is the name of your analysis? Have you seen examples of this already in the U.S.?

Casey: Yes. So, unfortunately, there are close to 100 of these events that happen every year, and they can really vary on what causes them. And I can give some examples of perhaps some larger events that people may have heard of, for example, following Hurricane Harvey, as we know, that storm led to an unprecedented amount of flooding in the Houston area, as the hurricane just kind of sat over Texas and just dumped tons of water and rain. But as a result of that event, there were multiple Natech events or natural hazard-triggered technological events, which is what we call these chemical events that occur as result of hurricanes or flooding or whatever natural hazard may have caused the incident. So, as a result of all that flooding, there was a facility called the Arkema Crosby Plant, just outside Houston. It's about, I think, over 50 miles inland. So it's not even necessarily super close to the coast, but because of the unprecedented flooding, that facility, their refrigeration systems which were keeping the organic peroxides that were being held at that facility stable, actually broke down and shut down.

And even though that facility had a risk management plan in place, they were not prepared for the crazy amounts of water that ended up flooding the facility. So, as a result of that, there were several burn events because these chemicals, if not held at the proper temperature, can more or less spontaneously combust. So there were fires that happened as a result. And the facility experienced fires for the four days following the breakdown of those systems. And, unfortunately, that wasn't the only event that happened following Hurricane Harvey. There were numerous spills of hazardous water. I'm talking about untreated wastewater from different facilities that was released, as well as gasoline that was released or spilled in nearby areas. So just from that one event, the way that facilities were not in any way prepared for the amount of flooding that occurred led to multiple different incidents and an amount of exposure and potential harm to the people living in that area that I don't think we'll really understand for a long time.

Colleen: Well, that's interesting because as you were talking about this, I was wondering about the people on the ground in those communities. Who's most at risk when these things happen?

Casey: Yeah. So there have been various demographic analyses looking at the populations that live around these risk management plan facilities, and it is often communities of color and low-income communities that are living immediately around these facilities. So they are often the most affected by these incidents when they do occur, which makes this not only an issue of environmental health, but of environmental justice in that these communities are being disproportionately impacted. And I often feel like when people hear about someone who may be living near a petrochemical facility or something, they often think, "Well, why do those people live there? Why don't they just move?" But because of all the industry in these areas and the industry that often has built up over time, the property value has become so low. Because of the industry presence, that oftentimes even if someone were to sell their home, they would not be able to afford someplace else where they would not experience similar exposures.

So, at the end of the day, this is really something where the solution is not for people to move, the solution is for industry to take responsibility and start putting plans in place to make sure that they're protecting not only their workers and the people who work at their facilities, but also those who live in the surrounding communities. It's not like...you can't say that all of these communities didn't exist before the industry arrived there. I mean, at times sometimes the community will be built up because they actually work at the facilities that are nearby. So, in that way, you might be asking someone to move away from the job opportunities that are available there. Or it's possible that there are plenty of communities where there is a strong history of that community living there. And then all of a sudden industry came in for whatever reason and kind of targeted this area to build up a bunch of these different industries. And now they've found themselves in their historic home that has been overrun by industry that's basically pushing them out, but also poisoning them in the meantime.

Colleen: Were there any other examples?

Casey: there was an incident in Michigan, last year, where there was, once again, an unprecedented level of rain and flooding that occurred. And when coupled with the fact that there was some aging infrastructure and some dams that had not been well-kept, several dams were breached leading to a great amount of flooding. And there were several Dow chemical facilities that were located just on the edge of where the flooding occurred. So this is something that can happen anywhere. And that's just an RMP incident that's associated with a natural disaster. Once again, there are also RMP incidences that occur because of other unintended or unforeseen circumstances that can happen inside facilities as well. For example, there's a Chemtools facility in Illinois that burned for several days. So, it's something that's not just a coastal problem.

Colleen: So, the risk management program facilities or RMPs, as we're referring to them, they're currently in place, but it sounds as if they're either not working or they're not robust enough, maybe you could talk a little bit about the current situation and then how we improve things.

Casey: Yeah. So currently, RMP facilities are required to do an assessment of the risk posed by the facility to workers and the surrounding community. And then they are required to come up with a plan to not only mitigate those risks, but also a plan for what they would do if an incident were to occur. However, in many ways, it has been shown time and time again that the plans that are currently in place are not adequate, especially when it comes to issues of climate change. Climate change is in no way required to be considered in the risk assessment for these facilities. And when it comes to facilities that are located on the coasts, or near rivers, or in areas that are affected by wildfires, it's not really acceptable or adequate to not consider climate change, especially given that we have the science to help us prepare for what we know is coming and what we know has already happened. And so, in that way, the current regulation falls short and continues to put us at risk.

Colleen: So, what are the most critical actions that need to be taken to protect these facilities and the people who live near them?

Casey: So there are a number of things that need to be done in order to make sure that these facilities don't continue to pose a serious risk to workers or fenceline communities. The biggest thing in many ways being the integration of climate change considerations into risk assessment and risk management plans. As we've seen time and time again, these facilities are being hit by extreme flooding and storms. And I don't think we can say for much longer that we weren't expecting it. We know that these things are happening and we need to be prepared. So I think that is top of mind, at least for me. But in addition to that, there are a number of things that can be done, some of which are pretty straightforward. So, for example, information, just making sure that the people who are working at the facility, first responders, and those living around the facility actually know what they're being exposed to.

Making sure that they have information about the chemicals at these facilities, but also what they should be concerned about if there were a potential release, especially with first responders. the GAO put out a statement at one point saying that first responders are not given adequate information about the chemicals at these facilities. And they're the ones on the front lines COLLEEN: Right around the time we were planning this episode, Tropical Storm Nicholas was lingering around the Gulf Coast… dumping inches of rain on a region that doesn’t really need it, just over two weeks after Hurricane Ida caused widespread flooding and power outages.

When I think about storms like Nicholas and Ida, my first thought is for the threats to people’s immediate physical safety—like drowning, electrocution, being hit by debris, or the medical emergencies that can happen when power goes out. But there’s another threat that I don’t consider often enough… and that’s the threat to people’s health from damages to industrial facilities in their neighborhoods. Chemical plants, refineries, waste management plants… they can incur damages from the increasingly deadly effects of climate change, including floods, sea level rise, and wildfires. And this means everyone around them is at risk of being exposed to the dangerous chemicals stored within these facilities, whether it’s in the air they breathe, the water they must wade through to escape floods, or the water they drink.

It turns out I’m not the only one who doesn’t think enough about these risks. The Environmental Protection Agency requires chemical facilities to create what are known as Risk Management Plans, or RMPs. And these RMPs are supposed to protect the communities around them from exposure to toxic chemicals in a crisis. But many RMPs fall short much of the time, and neither local governments nor our federal government are doing enough to make sure they’re enforced.

It’s a good thing my colleague Casey Kalman is thinking about this problem. Casey is a researcher with our Center for Science and Democracy, and she joined me to discuss her new analysis of the potential risks to these facilities—and the marginalized communities they’re often located in.

Poisoning when these incidents occur. Furthermore, also making sure that communities are notified when incidents happen. So making sure that there's some kind of notification system in multiple languages so that everyone can understand what occurred and the risk that they might be incurring. And that should be in language that not only is in multiple languages, but also in simple layman's terms so that everyone can understand and act appropriately.

Fenceline monitoring is another one of our recommendations. So, when we talk about the fence line, we are talking about the area immediately surrounding these facilities. And currently, there's no regulation to make sure that there are air monitors around the facilities measuring for whatever potential chemicals the facility could be releasing. This not only means that we don't have regular data on the potential exposure for people living around these facilities, but also if there were some kind of incident, something like fenceline monitoring would be the best way for us to very quickly understand what is being released and the potential exposure to those nearby so that decisions around evacuations could be made quickly, and so that there could be a proper response, basically. And the one other thing that I want to highlight is the expansion of the RMP coverage. As I've stated, there are hundreds of thousands of facilities throughout the U.S., many of which contain hazardous chemicals, but not all of them are required to put these plans in place to make sure that they're not going to have these unintentional releases during extreme storms or other types of events. So places like the BioLab facility in Westlake, Louisiana should be required to have this kind of plan to make sure that they're not going to harm their workers or those in the surrounding communities.

Colleen: How open are these facilities about the chemicals that they're using, and are they required to disclose that information?

**Casey:**they are required to disclose that information, but the level to which most people can find that information, that's where things start getting a little fuzzy. EPA has a website called the ECHO Facility Search, it's E-C-H-O Facility Search. And you can go and type in a ZIP code or a facility name, and then click on a certain facility to get more information. And you can see year by year, exactly what types of chemicals and how much of each chemical they are emitting each year. However, unfortunately, there is some evidence to show that this information is often outdated, and in that way, not necessarily super reliable, but also, in many ways, you would need to have the background on what those chemicals are and the harm that they could potentially cause you, or how they could interact with each other.

Colleen: Right. I was thinking you probably need a degree in chemistry to understand how harmful it is.

Casey: Yeah. It would take a good amount of effort to actually go onto the EPA websites and start to get an understanding of what are at these facilities and the risks that they pose to you. So that's why we think it's really important to make sure that there are resources available and information is given directly to communities in multiple languages and in terms that most people are going to understand, and that you don't need some kind of advanced degree or skillset to be able to find this information. Because if you're living next to the facility, you should know what your risks are.

Colleen: How do we make these changes happen? Is there a role for the individual?

Casey: Well, in the past, EPA has held several listening sessions for community members and community organizations to voice their concerns and recommendations for how the RMP program could be improved. a listening session usually occurs when a federal agency posts a proposed regulation of some kind, and then there's time for community organizations and stakeholders to voice concerns or support for whatever is in that legislation. These listening sessions that have already occurred were done prior to any legislation being posted. However, hopefully, the EPA will be posting a revised version of the RMP rules in the future. And following that, the public will have the opportunity to respond and voice their support or concerns about the changes that are being made or not being made.

Colleen: So, it sounds like these changes will come at the community level. There'll be opportunities for local communities to get involved.

Casey: it really varies state by state, unfortunately. And oftentimes, things like listening sessions aren't always...basically different states are...some are better about having public comment periods and things like that than others.

Colleen: So it sounds like the solutions will come at the federal level. This is about changing rules on that level. So, how do we make these changes happen? Casey: On a federal level, having the EPA basically reopen and strengthen this RMP rule so that it does include climate change and is more protective of fenceline communities, I think that will be the biggest step that we can take at a federal level.

Colleen: Will they just decide to do this, do they need pressure to do this? How do we get them to do it?

Casey: I would say that there are a large number of community and worker-based organizations that are putting pressure on the EPA to take on this rule and strengthen it.

Colleen: Casey, any areas we didn't cover or final thoughts for our listeners?

Casey: I guess I would just want to reiterate that the people who are most harmed by these events are those working at the facilities, first responders, as well as those living nearest the facilities, which we've already said are disproportionately low-income and communities of color. So, at the end of the day, no one's health and well-being should be harmed as a result of where they live or where they work, and opening up and strengthening this rule will be a key step towards achieving environmental justice in this country.

Colleen: Well, Casey, thanks so much for joining me on the podcast. It's been great talking to you.

Casey: Thank you for having me.