Friday, November 8, 2013

Location, Location, Location

I had an interesting, if brief, telephone conversation yesterday with Michael Jacoby. Mike is on something of a personal mission to correct what he sees as a major flaw in the chemical-reporting and emergency-response programs in the US. That problem is the inaccuracies in location information provided in the EPA chemical reporting programs.

Bad Location Information

You can see a quick visual display of the problem by looking at a relatively new and innovative tool  from the State of Texas, the HOTCOG (Heart of Texas Council of Governments) Tier II Facilities Locator Map. While the majority of the locations appear to be accurate (and I just did a visual confirmation on the system (ie: there is a building at the location that could be such a facility) not an on-the ground survey) there are some locations that the marked location clearly does not reflect the location on the ground.

For example, if you enter the address (the tool will only search by address) of FM 27, Wortham, TX (taken from the Tier II reporting data), you will find this address marked out in the middle of nowhere on Farm-to-Market Road 27. Nothing in the vicinity looks like it could be the storage of hazardous material.

If instead you look at the intersection of W. Conch Avenue and N. 2nd Street in Wortham, TX you will see a Tier II location icon just south of that intersection. Clicking on the icon you learn that it is the location of Verizon-MCI – WTHMTX (presumably a cell tower with a propane powered back-up generator that necessitated a Tier II report) and there is nothing in this residential neighborhood that looks like a Verizon-MCI facility.

Presumably the local volunteer fire department (VFD) knows where this cell tower is. But, as Mike points out, if an adjacent VFD has to respond to this location because the local VFD has responding elsewhere, they will not have the Tier II information available to them warning them of the hazardous material at the location. This could put their lives in danger or cause them to respond in a way that endangers the local community.

Correcting Location Information

At the bottom of Mike’s article at, he outlines the method that the EPA has put into place to allow corrections to be made to Tier II reporting data. The corrected data is provided to the EPA, which presumably vets the data through the reporting facility and then corrects the data on their system.

But if you look at the map at the HOTCOG site discussed earlier you can see the magnitude of the problem. The four Texas counties highlighted on the map are mainly rural in nature (the fifth, less rural, county in the group, McClenden, has its own map). Even if you ignore the oil and gas facilities (this is in the heart of the oil patch) there are still a large number of Tier II sites.

While there is no specific requirement for local fire departments or Local Emergency Preparedness Committees (LEPC) to vet and correct Tier II data in their jurisdictions, they are the only agencies that will specifically need to access this data. They would use this data for emergency planning or execution activities, so one would like to think that they would review and validate the information as part of their planning process.

No one else (government agencies, anyway) has the any real way to validate this information. The EPA does not have the manpower to vet these reported addresses, nor do State or regional authorities.

Source of Problem

The reason for this problem is that the Tier II reporting software provides for filling in blanks for ‘Street’ location for ‘where hazardous materials are present’. The software accepts any data entered into the blank with no way to verify that the information is complete or accurate. A simple misspelling of the street name could place the location of the facility in a completely different sector of a city or county.

In rural locations where there are no street addresses for many facilities a single street name may be used to refer to a number of different locations (search for “FCR 790, Donnie, TX 75838” on the HOTCOG site and see at least five widely separated facilities with that ‘address’). Even in an urban area, a single street address may cover a large number of buildings within a complex.

Mike thinks that there is a simple solution to the problem, the same solution that has been used by the CFATS Top Screen data collection tool. Mike would like to see all Tier II and Tier III reporting include a GPS location (latitude and longitude). This won’t remove all errors in reporting, but it will help avoid those inaccuracies that are due to the fact that street addresses are not always available of sufficiently accurate in describing a location.

BTW: It looks like there may be a large number of unreported Tier II facilities within a mile or so radius of that FCR 790 Donnie, TX ‘address’. Most of the white rectangles on that satellite image are either active or inactive crude oil pumping/storage sites. The active sites would almost certainly have to be reported as having Tier II chemicals on site.

1 comment:

Daryl Lee Spiewak, CEM said...

In Texas, facilities are required to report a street address, unless they do not have an assigned 911 address. Then the facilities must report Lat/Long of the storage site.

• Facilities assigned either a Street Address or 911 Emergency Services Address MUST provide this address in the Street Address field.

• Rural facilities that have NOT been assigned a 911 Address should enter “Lat/Long” in the Street Address field, indicating that the Latitude and Longitude coordinates for the facility will be provided on the next tab (the Location & ID tab).

Some facilities do make errors when they make out their reports and fail to correct them the following year. That is a problem, but no one wants to pay to ground truth the data. EPA, and Texas TCEQ, wait until a facility has a reportable accident and then verifies the reported data as part of the investigation. They facility then gets an appropriate fine for incorrect data.

Sometimes Texas TCEQ issues a contract to check reported data. But I've only a seen TCEQ verify data under the Risk Management Program and not the TIER II program. Sometimes the fire department that receives the TIER II report will go to the facility for an inspection. However, that doesn't always occur.

Requiring all facilities to report LAT/LONG with a physical address+ is probably the best method since the data fields are already there.

Daryl Lee Spiewak, CEM
Waco, TX

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