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Dow facility fails Greenpeace citizen inspections

Dow facility fails Greenpeace citizen inspections

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Published by Greenpeace
Following a citizen inspection conducted by air and land, Greenpeace issued a ‘failed inspection’ report to Dow Chemical Company for failing to fully secure its Texas Operations facility in Freeport, TX against terrorists or catastrophic accidents. The Freeport facility puts 130,000 people at risk.
Following a citizen inspection conducted by air and land, Greenpeace issued a ‘failed inspection’ report to Dow Chemical Company for failing to fully secure its Texas Operations facility in Freeport, TX against terrorists or catastrophic accidents. The Freeport facility puts 130,000 people at risk.

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Categories:Types, Research, Science
Published by: Greenpeace on Sep 08, 2010
Copyright:Attribution Non-commercial

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12/07/2012

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GREENPEACE SECURITYINSPECTION REPORT
 FACILITY: TEXAS OPERATIONS, FREEPORT, TXCOMPANY: THE DOW CHEMICAL COMPANYFINDING: FAILURE TO PREVENT CATASTROPHIC RISKS
702 H Street NW Suite 300Washington DC 20001 Tel/ 202.462.1177
 
 According to Dow’s own reports to theEnvironmental Protection Agency’s (EPA) RiskManagement Program, its Texas Operations inFreeport, TX puts 130,000 people at risk due tothe bulk use and storage of phosgene gas, acompound used as a chemical weapon in WorldWar I. The facility also has up to 7.6 million lbs ofchlorine gas on site that could endanger a similaror larger population in the case of a catastrophicrelease.
It is clear that this Dow facility has failed totake advantage of safer available chemical processesthat would prevent a catastrophic release of phosgeneor chlorine gas resulting from a terrorist attack oraccidental release.
UNNECESSARY RISKS
 These risks existed long before September 11, 2001,and no amount of fences, security cameras, or guardscan fully secure a facility that has an inherent risk of acatastrophic release of a lethal gas.Dow is well aware of safer chemical processes thatwould reduce or eliminate these risks, considering thatmore than 284 chemical facilities have converted since1999.
In 2008, Dow announced a partnership withK2 Pure Solutions (k2pure.com) to use a safer just-in-time process to manufacture chlorineon site at its Pittsburgh, CA plant.
This processeliminates the risks inherent in shipping or storing largequantities of chlorine. In November of 2009, Cloroxannounced it will be converting all of its U.S. facilitiesthat use chlorine gas to safer processes. Accidents happen all too frequently, as was the casewith the fatal explosion in 2005 at the BP refinery in Texas City, TX that killed 15 workers; a costly reminderof the catastrophic risks inherent in many chemicalprocesses.
DOW FACILITY IN FREEPORT 
 The Texas Operations facility in Freeport, TX is Dow’slargest chemical manufacturing site and one of thelargest in the world. The three major complexes —Plant A, Plant B and Oyster Creek —span more than5,000 acres and contain 65 production plants thatmanufacture 32 billion pounds of products each year.Half of the products manufactured at these sites usechlorine somewhere in the process.
Both chlorineand phosgene could be made and used with a just-in-time process that would eliminate theneed for the bulk storage and transport in railcars, which make this facility high-risk.
 
Theworst-case scenario reported by Dow to the EPAis the potential release of 23,000 lbs phosgene,but the Department of Homeland Security(DHS) warned in a Federal Register notice thata terrorist attack, “may involve effects that aremore severe than expected with accidental risk.”
 
FACILITY:TEXAS OPERATIONS, FREEPORT, TXCOMPANY:THE DOW CHEMICAL COMPANYFINDING:FAILURE TO PREVENT CATASTROPHIC RISKS
 
SECURITY INSPECTIONS
 The DHS began to inspect “high risk”chemical plants this year. However, theytestified at a March 3rd Senate hearing thatthey will inspect fewer than five percent of all 4,997 high-risk plants by the end of 2010. The DHS will also not confirm which plantsthey will inspect or whether those plants areviolating any rules. Under current law, theDHS is barred from requiring the use of saferchemical processes that would eliminatepotentially fatal consequences of a terroristattack or accident. The Dow Freeport facility has only addressedsecurity concerns with conventional methodssuch as guards, gates, and security cameras,but these measures are unlikely to stop apotential terrorist attack. In June of 2007,DuPont CEO Charles O. Holliday commentedon security saying,
“I feel very comfortablethat we’ve taken all the reasonable steps,but obviously if someone wants to flyan airplane into a plant, it’s very hardto guard against it.”
Sen. Joe Lieberman,chair of the Senate Homeland Security andGovernment Affairs Committee, has said that
using safer chemical processes is “theonly fool-proof way to defeat a terroristdetermined to strike a chemical facility.”
 There are several security gaps under currentlaw, but these loopholes would be closedif permanent legislation (H.R. 2868) passedby the U.S. House of Representatives lastNovember is enacted this fall.
Dow is amember of lobbying groups, such as theSociety of Chemical Manufacturers and Affiliates, American Petroleum Institute,and the American Chemistry Council,which lobbied against H.R. 2868 as wellas complementary legislation in theSenate.
In a March 27, 2009 letter to Dow’sCEO Andrew Liveris about the potentialcatastrophic liability that Dow’s plants pose,Greenpeace urged Dow to switch to saferchemical processes and break from thislobby by joining other businesses, such asthe railroads, in supporting legislation thatwould prevent disasters. On July 28th, theSenate Homeland Security and Governmental Accountability Committee considered H.R.2868. It was substituted with an amendmentpreserving the current law, and lauded bythe chemical industry. If made law, this policywould handcuff the government’s ability toset standards until 2013.
Last year, Dow provided Greenpeacelegislative language showing that Dowcould support a policy requiring saferchemical processes. Instead, Dow isnow leading industry trade groupssupporting policy that continues tohandcuff the DHS from requiring the useof safer chemical processes that willprotect our communities from chemicalcatastrophes.
 The only sure way to safeguard employeesand surrounding communities from accidentsor terrorism at high-risk chemical plants isthrough prevention. In this regard,
Dow hasfailed to secure its Texas Operationsagainst catastrophic accidents orterrorism. Compounding this failure atthe plant level, Dow has backed awayfrom supporting a policy in Congress thatwould eliminate these catastrophic risksat the highest risk chemical facilities.

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James Enos added this note
TOXIC TRAIN SAFETY - A First Responders Petition caused The Chlorine Institute to conduct a five-month study comparing the safety of secondary containment to the chlorine “C”-Kit for chlorine tank cars. The study proved secondary containment to be, by far, the safest technology for containing and preventing releases of chlorine gas. To see secondary containment - search CHLORTANKER.”
Rudy Caparros added this note
Haz Mat Experts petition Dow Chemical Company for safe rail tank cars transporting gas chlorine. Secondary containment is a necessary improvement that must be implemented. See-- PETITION C KIT for Haz Mat Expert comments.
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