September 14, 2005
Fire Chief Adrian H. Thompson
1923 Vermont Ave NW Suite 201 South
Washington DC 20001
Dear Chief Thompson;
As you know, the U.S. Department of Homeland Security's (DHS)
has designated September as National Preparedness Month. Yesterday
Greenpeace simulated a terrorist attack on a 90-ton rail car of
chlorine in front of the U.S. Capitol. That scenario was patterned
after the U.S. Naval Research Laboratory's estimate that 100,000
people could be killed or injured and that "people can die at the
rate of 100 per second."
As this simulation unfolded yesterday, a hazmat team used the
event as a training opportunity. Due to the near life size
appearance, markings, theatrical steam, electronic hissing sound of
our scale model (40 by 12 feet), one of your officers asked if it
could be made available for training exercises by D.C. first
responders in the future.
Given the enormous risks posed by the ongoing shipment of
ultra-hazardous substances through Washington, D.C. we would be
honored to loan it to you. We have already considered using it in
other communities. However, our only caveat is that no matter how
well your hazmat crews are trained, the speed with which a railcar
of poison gas can spread will quickly overwhelm the resources of
any city or federal government. The U.S. Naval Research
Laboratory's computer models and other government warnings make
this abundantly clear.
*** In July of 2004 the Homeland Security Council estimated that
an attack on a chlorine facility could kill 17,500 people,
seriously injure an additional 10,000, send 100,000 more to the
hospital and cause an additional 70,000 evacuations.
*** Prior to the horrific attacks on passenger trains in Madrid
in March 2004 and London in July of this year, an FBI specialist in
weapons of mass destruction (WMD), addressing a chemical industry
conference in June 2003 warned, "You've heard about sarin and other
chemical weapons in the news. But it's far easier to attack a rail
car full of toxic industrial chemicals than it is to compromise the
security of a military base and obtain these materials."
*** In March, 2002, the Washington Posted reported on an
unpublished U.S. Army Surgeon General report which estimated that
900,000 to 2.4 million people could be killed or injured in a
terrorist attack on a U.S. chemical facility in a densely populated
area.
Prevention is the only responsible public safety option.
However, the implementation of the D.C. hazmat re-routing statute
enacted in February has been held up indefinitely by a federal
court challenge from CSXT railroad and the Justice Department.
During that time tons of ultra-hazardous chemicals are being
shipped daily through District neighborhoods.
Although CSXT has made vague claims of voluntarily re-routing
certain dangerous cargo around the north-south "RF&P" line that
runs within four blocks of the U.S. Capitol, they have never made
such claims about the east-west or "Metropolitan" line that runs
through N.E. D.C. As you know, the Metropolitan line runs through
Brookland, Brentwood, adjacent to Catholic University of America
and is less than two miles from the U.S. Capitol.
Without any proof, we have no reason to believe that CSXT's is
re-routing all ultra-hazardous cargo around Capitol Hill all of the
time. For example, we have witnessed many hazardous cargoes,
including chlorine rail cars placarded "1017," rolling through
L'Enfant Plaza's VRE station this summer.
Furthermore, the $9.8 million DHS proposal called, "National
Capital Region Rail Pilot Project" (NCRRPP) to install video
cameras along a "7.5 mile stretch of rail owned and/or operated by
CSX Transportation (CSXT)" is not only an absurdly expensive but it
will also be ineffective in preventing attacks by determined
terrorists. Some have even suggested that terrorists might be
attracted by the possibility of camera's documenting the last
moments of their "martyred" lives as they were in surveillance
photos in the London subway and at U.S. airports four years ago on
September 11th. Not surprisingly the DHS proposal ignores the
Metropolitan line where CSXT has never claimed that ultra-hazardous
cargoes are being rerouted even temporarily.
What has been done to address this? In testimony this January
before the Senate Committee on Homeland Security and Government
Affairs, former Deputy Homeland Security advisor to the President,
Richard Falkenrath said, "the federal government has made no
material reduction in the inherent vulnerability of hazardous
chemical targets inside the United States. Doing so should be the
highest critical infrastructure protection priority for the
Department of Homeland Security in the next two years."
The good news is that re-routing ultra-hazardous cargo is not
only cost effective for government, it will also have a negligible
impact on the railroads because the number of chemicals and
shipments are such a small percentage of their business. Ninety
percent of the transportation risk of all toxic-by-inhalation (TIH)
materials is represented by just six chemicals according to a 2000
risk assessment by Argonne National Laboratories. These chemicals
are: chlorine, ammonia, sulfur dioxide, hydrogen fluoride, fuming
sulfuric acid and fuming nitric acid. Argonne also estimated that
chlorine accounts for 58.5 percent of TIH risk of fatality.
Clearly, the prioritization of the most shipped, most dangerous
hazardous substances will facilitate a rapid implementation of the
most immediate and least costly policy option: re-routing dangerous
cargoes around sensitive areas.
The widespread presence of graffiti on freight trains, including
markings on 90-ton railroad tank cars is proof of the ease with
which they can be accessed. Securing thousands of miles of U.S.
rail lines is a virtual impossibility. The Madrid attacks in 2004
and the London attacks in July were a horrific wake up call to this
vulnerability. The deadly rail car accident in South Carolina in
January that killed ten people was further evidence of how lethal
even a partial release from a chlorine tank car can be.
In June Senator Joseph Biden (D-DE) introduced "The Hazardous
Materials Vulnerability Reduction Act of 2005" (S. 1256) which
would require the Secretary of DHS to regulate the shipment by rail
of extremely hazardous materials (EHMs) and re-route EHMs around
designated "high-threat corridors" with common sense
exceptions.
Ultimately re-routing should also be done in tandem with a
comprehensive chemical security program which phase in safer
available chemicals and processes. Congress is now also considering
this legislation.
We look forward to working with you and your department.
Sincerely,
Rick Hind
Legislative Director, Greenpeace Toxics Campaign