Katrina and toxics update

I received a couple of helpful emails about Katrina and pollution. I'm copying them below. The first is an observation from Cheryl Rofer at Whirled View, an expert in chemistry, international environmental projects, and nuclear and strategic issues. The second is from an engineer / environmental policy friend and colleague, Paul F. Thanks greatly to both of you. I've done a wee bit of editing, and hope you don't mind me posting these responses.

1. Cheryl: The fires that are raging now are going to be putting all sorts of pollution into the air. I've been thinking about the hazardous substances. If the refineries are flooded, they're going to be releasing toxics. There was a photo of an oil slick on the water in what looked like a residential neighborhood last night.

2. Paul: The quick answer is that I don't have a specific document to refer you to regarding that area. But it may help you if I can explain the regulatory process in place under the Clean Water Act that apply to companies that produce, treat, transport, and/or store very large quantities of petroleum and petroleum-like commodities. I'm doing this off the top of my head so forgive me if I gloss over the specifics.

First, even rather small "oil operations" must have an SPCC Plan (Spill Prevention, Control, and Countermeasures) or an integrated equivalent and these plans, while often boilerplated, have quite a lot of details like oil inventories and locations, spill pathway assessments, spill equipment and procedures, interagency ER agreements, notification protocols - usually a decent description of what a facility has and how they handle emergencies.

Second, "bulk oil operations" naturally have even more requirements on them (e.g., emergency drills) and in their plan including other documents that assess environmental impacts. I don't have direct experience with the bulk operations but suffice it to say that each company like this has all this detail sitting on their shelf somewhere. Plus, each company must by law issue copies of their plans to local, state, and perhaps regional emergency response organizations; in my experience, copies are sent to about a dozen entities outside the fence. One entity is the LERC - local emergency response commander (?), I think.

Now, to get to your question... I don't know of these company-specific plans being readily available to the public, in fact, I've never ever heard of a plan/assessment leaving the hands of the entities required to have them. But that doesn't mean they're not accessible. There may be regional EPA offices (out of Atlanta in the gulf case) that fall under FOIA so a request could be made.

From a local/regional standpoint of multiple operations being wiped out simultaneously and having aggregate and possible synergistic, effects, this is much more amorphous in my mind. I really don't know what the LERC, for example, does with a shelf full of reports in terms of assessing these aggregate/synergistic effects. My guess is that it depends on the particular entity. But I'm not experienced at the regional level.

I can add that the mindset of emergency responders is to treat a spill according to the SOP, which would include grabbing a facility's plan off the shelf as they run out the door. Ideally. I can also predict that what you are asking for does not exist. If a large, unconsidered event would occur, then the scientist would run out and try to assess the potential damage ad hoc - hopefully having facility-specific information to fold in. I may be a little pessimistic here. I can also envision that a LERC (or equivalent) would be the one to know that a facility with bulk flammable is down the street from a facility with bulk oxidizers, for example - while each facility may not know of the other's inventories. I suppose the bottom line in answering your question is that this type of information is typically kept within the industrial/ER community and hopefully aggregate details are considered.