CACE: Hazardous Chemical Transportation Taskforce

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

2. 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

3. 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)

4. Amount of Waste Transported Annually

5. 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

6. 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

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

8. e-CRF Continued • Part 174 • Carriage by Rail • 32 pages • Part 177 • Carriage by Public Highway • 27 pages

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

10. 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

11. 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

12. 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

13. Clymers, IN Accident

14. Clymers, IN Accident Before After

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

16. 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

17. 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

18. 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