CACE: Hazardous Chemical Transportation Taskforce April 30, 2007 Team Members: Andrew Maxwell Collin Arnold Samuel Tharp John White

Proposed Action  Phase I Expansion- Acceptable  Rail Transportation  Need a well developed implementation plan prior to expansion  Phase II Expansion- Unacceptable  Departure from Poly Chemical’s current operations  Exposes community to too much risk  Just doesn’t make sense

Transportation Assumptions  Plant production increases by square of increase in acreage of plant size  Phase II of the expansion will eliminate all but negligible amounts of exported waste  Phase II of the expansion will allow import and processing of the waste of 3 outside companies of similar size as Poly Chemical  Average density of chemicals similar to water (for volume calculations)

Amount of Waste Transported Annually Currently Phase I Phase II Mass (K tons) Volume (M gallons) Train Cars

Waste Amount Comparisons  Phase I: Transporting per year  14,970 Hummer H2’s  2,369 Swimming pools  Phase II: Transporting  44,940 Hummer H2’s per year  7,102 Swimming pools

Electronic Code of Federal Regulations (e-CFR) Title 49: Transportation of Hazardous Materials  Would “Print it out” but with saving the trees in mind…  Part 107  How to make a emergency guideline  72 pages  Part 171  General Information, Regulations and Definitions  61 pages

e-CRF Continued  Part 172  Hazardous Material Info (exhaustive)  481 pages  Part 173  Basic Shipping Requirements  500+ pages

e-CRF Continued  Part 174  Carriage by Rail  32 pages  Part 177  Carriage by Public Highway  27 pages

e-CRF Continued  Part 178  Special Instruction for Packaging (extensive)  600+ pages long  Part 179  Specifications for Tank Train Cars/Trucks  91 pages

e-CRF Results  2000 pages  Employees must know most of this material in order to load, move and unload these chemicals  LOTS of cross-referencing  Includes detailed pictures on placards, display signs, and what/how they should look like

e-CRF Problems  Can an employee follow all these to the letter?  If Poly Chemical expands, can they continue waste spill their track record?  Cutting corners lead to dangerous consequences

Clymers, IN Accident  Waste Tanker Car Over Pressurized  Catastrophic rupture  $4.8 million in operational losses  Fire and localized contamination  Determined to be result of  lack of management mandated procedure  poor implementation of Hazmat regulations

Clymers, IN Accident

BeforeAfter

Chemicals Transported  HCl (Hydrogen Chloride)  Currently transported to waste treatment facility  Nitrates  Chromium  Benzene

Benzene  Damages blood, bone marrow, central nervous system, liver, and urinary system  Can be fatal if inhaled or ingested in large amounts  Known carcinogen  Very possibly mutagenic  Causes adverse reproductive effects: female infertility and birth defects  Benzene + Chromic Anhydride = BOOM

Benzene Spill: China 2005  Chemical plant explosion  Estimated 100 tons of benzene leaked into Songhua river  Flowed downstream to city w/ population of 4 million  Couldn’t drink water for 5 days during clean-up  Still can’t fish in the local water  Benzene is heavier than water and settled on bottom of river  Makes clean-up extremely difficult

Conclusion  Safety is our priority  Safety should be Poly Chemical’s priority as well  Phase I Expansion can be done safely  Phase II Expansion is unsafe, we must fight it