CACE:CACE:Hazardous Chemical Hazardous Chemical Transportation TaskforceTransportation Taskforce

April 30, 2007April 30, 2007

Team Members:Team Members:Andrew MaxwellAndrew MaxwellCollin ArnoldCollin ArnoldSamuel TharpSamuel TharpJohn WhiteJohn White

Proposed ActionProposed Action

Phase I Expansion- AcceptablePhase I Expansion- Acceptable Rail TransportationRail Transportation Need a well developed implementation Need a well developed implementation

plan prior to expansionplan prior to expansion Phase II Expansion- UnacceptablePhase II Expansion- Unacceptable

Departure from Poly Chemical’s current Departure from Poly Chemical’s current operationsoperations

Exposes community to too much riskExposes community to too much risk Just doesn’t make senseJust doesn’t make sense

Transportation Transportation AssumptionsAssumptions

Plant production increases by square of Plant production increases by square of increase in acreage of plant sizeincrease in acreage of plant size

Phase II of the expansion will eliminate all Phase II of the expansion will eliminate all but negligible amounts of exported wastebut negligible amounts of exported waste

Phase II of the expansion will allow import Phase II of the expansion will allow import and processing of the waste of 3 outside and processing of the waste of 3 outside companies of similar size as Poly Chemicalcompanies of similar size as Poly Chemical

Average density of chemicals similar to Average density of chemicals similar to water (for volume calculations)water (for volume calculations)

Amount of Waste Amount of Waste Transported AnnuallyTransported Annually

CurrentlCurrentlyy

Phase IPhase I Phase IIPhase II

MassMass(K tons)(K tons) 19.819.8 49.449.4 148.3148.3

VolumeVolume

(M (M gallons)gallons)

23.123.1 57.857.8 173.3173.3

Train CarsTrain Cars 926926 23112311 69326932

Waste Amount Waste Amount ComparisonsComparisons

Phase I: Transporting per yearPhase I: Transporting per year 14,970 Hummer H2’s14,970 Hummer H2’s 2,369 Swimming pools2,369 Swimming pools

Phase II: Transporting Phase II: Transporting 44,940 Hummer H2’s per year44,940 Hummer H2’s per year 7,102 Swimming pools7,102 Swimming pools

Electronic Code of Electronic Code of Federal Regulations (e-Federal Regulations (e-CFR) CFR)

Title 49: Transportation of HazardousTitle 49: Transportation of HazardousMaterialsMaterials

Would “Print it out” but with saving the trees in Would “Print it out” but with saving the trees in mind…mind…

Part 107Part 107 How to make a emergency guidelineHow to make a emergency guideline 72 pages72 pages

Part 171Part 171 General Information, Regulations and General Information, Regulations and

DefinitionsDefinitions 61 pages61 pages

e-CRF Continuede-CRF Continued

Part 172Part 172 Hazardous Material Info Hazardous Material Info

(exhaustive)(exhaustive) 481 pages481 pages

Part 173Part 173 Basic Shipping RequirementsBasic Shipping Requirements 500+ pages500+ pages

e-CRF Continuede-CRF Continued

Part 174Part 174 Carriage by RailCarriage by Rail 32 pages32 pages

Part 177Part 177 Carriage by Public HighwayCarriage by Public Highway 27 pages 27 pages

e-CRF Continuede-CRF Continued

Part 178Part 178 Special Instruction for Packaging Special Instruction for Packaging

(extensive)(extensive) 600+ pages long600+ pages long

Part 179Part 179 Specifications for Tank Train Specifications for Tank Train

Cars/TrucksCars/Trucks 91 pages91 pages

e-CRF Resultse-CRF Results

2000 2000 pagespages Employees must know most of Employees must know most of

this material in order to load, this material in order to load, move and unload these chemicalsmove and unload these chemicals

LOTS of cross-referencing LOTS of cross-referencing Includes detailed pictures on Includes detailed pictures on

placards, display signs, and placards, display signs, and what/how they should look likewhat/how they should look like

e-CRF Problemse-CRF Problems

Can an employee follow all these to Can an employee follow all these to the letter?the letter?

If Poly Chemical expands, can they If Poly Chemical expands, can they continue waste spill their track continue waste spill their track record?record?

Cutting corners lead to dangerous Cutting corners lead to dangerous consequencesconsequences

Clymers, IN AccidentClymers, IN Accident

Waste Tanker Car Over PressurizedWaste Tanker Car Over Pressurized Catastrophic ruptureCatastrophic rupture $4.8 million in operational losses$4.8 million in operational losses Fire and localized contaminationFire and localized contamination Determined to be result of Determined to be result of

lack of management mandated procedurelack of management mandated procedure poor implementation of Hazmat poor implementation of Hazmat

regulationsregulations

Clymers, IN AccidentClymers, IN Accident

Clymers, IN AccidentClymers, IN Accident

BeforeBefore AfterAfter

Chemicals TransportedChemicals Transported

HCl (Hydrogen Chloride)HCl (Hydrogen Chloride) Currently transported to waste Currently transported to waste

treatment facilitytreatment facility NitratesNitrates ChromiumChromium BenzeneBenzene

BenzeneBenzene

Damages blood, bone Damages blood, bone marrow, central nervous marrow, central nervous system, liver, and urinary system, liver, and urinary systemsystem

Can be fatal if inhaled or Can be fatal if inhaled or ingested in large amountsingested in large amounts

Known carcinogenKnown carcinogen Very possibly mutagenicVery possibly mutagenic Causes adverse reproductive Causes adverse reproductive

effects: female infertility and effects: female infertility and birth defectsbirth defects Benzene + Chromic Anhydride = BOOM Benzene + Chromic Anhydride = BOOM

Benzene Spill:Benzene Spill:China 2005China 2005

Chemical plant explosionChemical plant explosion Estimated 100 tons of benzene Estimated 100 tons of benzene

leaked into Songhua riverleaked into Songhua river Flowed downstream to city w/ Flowed downstream to city w/

population of 4 millionpopulation of 4 million Couldn’t drink water for 5 days Couldn’t drink water for 5 days

during clean-upduring clean-up Still can’t fish in the local waterStill can’t fish in the local water

Benzene is heavier than water Benzene is heavier than water and settled on bottom of riverand settled on bottom of river Makes clean-up extremely Makes clean-up extremely

difficultdifficult

ConclusionConclusion

Safety is our priority Safety is our priority

Safety should be Poly Chemical’s priority as Safety should be Poly Chemical’s priority as wellwell

Phase I Expansion can be done safelyPhase I Expansion can be done safely

Phase II Expansion is unsafe, we must fight Phase II Expansion is unsafe, we must fight itit