Reader Comment 08-20-10 TRANSCAER

Long time reader and frequent commenter on matters related to the transport of toxic inhalation hazard (TIH) chemicals Fred Millar left a rather long comment on my recent blog about the TRANSCAER training program. I would urge anyone interested in TIH transport or emergency response to read his entire comment, but I think I can safely summarize his complaint about the TRANSCAER training by saying that it does not deal with the problem of emergency response to a catastrophic release of chlorine gas from a railcar.

Non-Catastrophic Release

I think that Fred unfairly disparages the true benefit of the TRANSCAER training. The vast majority of chlorine release incidents in rail or truck transport deal with leaking valves. These releases are not typically going result in the large chlorine gas clouds that will require mass evacuations and result in inevitable mass casualty events.

These type incidents do require first responders to get up close and personal with rail car and truck fittings in a very hazardous personal exposure situation. Proper training in how to respond to these situations will allow these first responders efficiently and safely handle these events.

Fred does make a good point, however, in noting the relatively small number of responders that this program reaches every year. This is a problem since there is a very real need for the program to reach all of the first responders that might be called upon to respond to these incidents. Emergency response personnel in every community where a rail car may pause in transit really do need this training.

Fred is correct in noting that Federal grant monies would be necessary to expand this program to provide truly adequate coverage of the communities involved. This does not need to be a one time event. Any professional safety trainer knows that training like this needs to be repetitive (on at least an annual basis) if it is to be truly effective.

I do think, however, that this combined effort of the railroads and chlorine producers and shippers (who do not see eye-to-eye on chlorine transport issues) is to be commended for what it does accomplish. The creative use of railcars as training aids should be applauded. Congress should certainly look at providing funds for extensive expansion of the program.

Catastrophic Release

I have not attended any of these training events so I am not absolutely sure that the TRANSCAER training does not address the issue of a catastrophic release of chlorine gas. Lacking a comment from the TRANSCAER folks I will accept Fred’s observation about the lack of such coverage, at least for the sake of this discussion.

I would hope that the TRANSCAER folks would at least briefly address the situation with a discussion of evacuation requirements outlined in the Chlorine Institute’s Pamphlet 74. If I were planning/conducting this general chlorine response type training I would also include a relatively brief discussion of how to detect and respond to a catastrophic release with emphasis on the personal protective equipment and mitigation techniques.

I am not sure, however, that a TRANSCAER type hands-on training event is the appropriate forum for the type training and planning event that is necessary to properly prepare a community for a catastrophic chlorine release event on this scale. I’m not sure that there is currently an appropriate forum for that information exchange.

This begs the larger question of how we deal generally with low probability, high impact (LPHI) events of this sort. Getting all communities along all potentially affected rail lines in this country to the point where they have an effective plan (which requires both planning and exercise components for truly effective plans) for a catastrophic release of chlorine gas of a transiting chlorine railcar would be extremely expensive and time consuming. The limited emergency response planning resources in most of these communities would be better focused on events of a higher local probability.

FEMA should be the agency developing generic emergency response plans for the whole spectrum of LPHI events. There should be a manual produced with a whole host of such generic plans that emergency response professionals could easily refer to in the event that an LPHI event actually occurred in their area. This would not be as effective as a locally produced and exercised plan, but it would be a cost/resource effective alternative.

Fixed Chlorine Sites

Fred does mention the US Army’s nerve agent response program for communities surrounding the sites that are finishing up the destruction of the nerve agent munition stockpile as an example of the type of effective emergency response program that would be needed to protect a community from a catastrophic chlorine release. Those programs include the provision of personal protective equipment to potentially affected off-site personnel along with the appropriate training for the use of that equipment. There is also an extensive detection device network surrounding the storage and destruction sites and an often tested and evaluated emergency notification network.

While nerve agent is a much more toxic chemical than chlorine gas, this type of emergency response planning should be considered for the closest neighbors of a facility with release toxic COI of all types, but especially facilities storing/using/producing a significant amount of chlorine gas. At an absolute minimum there needs to be a network of chemical sensors that provide automatic warning of a chemical release. Neighbors within the immediate danger zone need to be trained and equipped to either shelter in place (where appropriate) or evacuate the hazard zone.

Recently the TSA has raised a number of questions about the accuracy of the chlorine gas dispersion model embodied in Pamphlet 74. Until those questions are resolved, that remains the industry standard model and the one that emergency response personnel use for their planning purposes. TSA needs to proceed with their planned studies to evaluate the model, but FEMA should be an active part of those studies. FEMA is the Federal agency responsible for all-hazards emergency response planning and execution. They have an inherent interest in the accuracy of the chlorine gas dispersion model (see my ‘Idea’, TSA Chlorine Dispersion Modeling Study, on the National Dialogue on Preparedness web site and please vote on the 'Idea').