According to chemical facility reports to the EPA, there are 483 U.S. chemical facilities distributed among 43 states that each put 100,000 or more Americans at risk of a Bhopal magnitude disaster. According to the U.S. Naval Research Laboratory these hazards could easily result in thousands of fatalities in a matter of hours following a terrorist attack. The Department of Homeland Security (DHS)...
According to chemical facility reports to the EPA, there are 483 U.S. chemical facilities distributed among 43 states that each put 100,000 or more Americans at risk of a Bhopal magnitude disaster. According to the U.S. Naval Research Laboratory these hazards could easily result in thousands of fatalities in a matter of hours following a terrorist attack. The Department of Homeland Security (DHS) has identified 4,500 high risk chemical facilities in the U.S. The Homeland Security Council estimated that an attack on a 90 ton tank car of chlorine gas would result in: 17,500 fatalities, 10,000 severe injuries and 100,000 hospitalizations. Plant employees and communities living closest to the plants are at the greatest risk.
Hundreds of chemical facilities have eliminated the possibility of a chemical disaster by converting to inherently safer chemical processes. A famous example was the conversion of Washington, D.C.'s wastewater treatment plant from deadly chlorine gas to harmless liquid bleach within 90 days following the 9/11 attacks. This conversion eliminated a terrorist risk to more than one million people at a cost of less than $0.50 per water customer per year. More than 200 other plants have converted since 9/11 and 49 percent did it for less than $100,000. Unfortunately at this rate it will take decades to convert the 2,498 most dangerous plants and there is no requirement that the highest risk plants convert sooner even where cost-effective alternatives are readily available.
In 2002 the EPA proposed to more fully enforce the 1990 Clean Air Act to prevent chemical disasters through the use of safer chemical processes but the proposal was later killed by the White House. Until Congress acts responsibly, the only way to ensure that the DHS and EPA disaster prevention policies are implemented is to enforce the 1990 Clean Air Act's General Duty Clause (GDC). The GDC in the Clean Air Act obligates all chemical facilities to be designed and operated to prevent catastrophic chemical releases. By issuing new rules and guidance under the GDC any resulting hazard reduction would also reduce the work load on the DHS and Coast Guard as more high-risk plants become safer "de-listed" facilities subject to fewer regulations with far less liability. Such a program would also help close security gaps at water and port facilities because the Clean Air Act program already covers those facilities.
As we have seen with disasters, such as the BP oil spill in the Gulf of Mexico, once "fail safe" gadgets fail, it's too late to prevent a catastrophe. I respectfully urge you to use the authority of the Clean Air Act as soon as possible to reduce these catastrophic risks to millions of Americans so that they will no longer be targets of terrorism or Bhopal magnitude chemical accidents.
Thank you, I look forward to receiving your reply.