Letter to DC Fire Chief

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*** In March, 2002, the Washington Posted reported on an unpublished U.S. Army Surgeon General report which estimated that 900,000 to  2.4 million people could be killed or injured in a terrorist attack on a U.S. chemical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