Posted by Fred Balin, a resident of the College Terrace neighborhood, on Oct 29, 2006 at 7:47 pm
Resident et al,
The follow-up Planning & Transportation Commission meeting is this Wednesday, Nov 1, (Item 2 following a 6 pm study session), ...
... but please read on ...
There are two key areas with regard to the accidental release of nitric acid from CPI on February 2.
The first is fairly well understood: The forthcoming report of the city-attorney and fire-department investigation, corrective action implemented, and potential punitive measures imposed.
The second crucial concept, however, is only now entering public, city commission, and city council consciousness. That is, how and why a facility with such an extremely high level of toxic substances should be so close to a residential neighborhood, and what the city should now do to prevent this from ever happening again.
Thanks to the detailed research of Barron Park’s Arthur Liberman, we now know that CPI is in a select group of one of only about 20 sites in the entire county with levels of certain hazardous materials so high that it is covered by a special program, the California Accidental Release Management Program (CalARP), often referred to by its section in the California Health & Safety Code, “Title 19.”
The Title 19 threshold substances at CPI include 4161 lbs of nitric acid (over four times the threshold level) and 631 pounds of potassium cyanide (over 6 times the threshold level). A third substance, hydrogen gas, is just under the Title 19 threshold level.
Under Title 19 regulations, CPI must file a risk management plan for approval with the county. Within the worst-case scenarios in their most recent risk management plan is the reaction of a quantity of potassium cyanide with an acid (for example, nitric acid) released over 10 minutes to a “toxic endpoint” of 0.2 miles. Refer to your high school chemistry, and then dwell briefly on the resultant gas from such a reaction.
But current policy in the planning department is that Title 19 sites are not any of their business. Hazardous materials above certain “exempt” quantities are allowed in various “industrial” zones in the city, and the county deals with the oversight of these sites.
Palo Alto’s Fire Department handles the “technical” matters of inspections, compliance, and response, if needed.
The Title 19 toxics issue has recently come up within the context of a new hazardous materials section in revised “Performance Criteria,” currently before the Planning & Transportation Commission. Performance criteria are designed to deal with potential adverse impacts of commercial and industrial areas that are near residential neighborhoods.
Within the new hazardous materials section, the city is proposing to notify residents of risk management plans filed with the county.
This is appropriate and necessary, but hardly sufficient.
The city must regulate Title 19 facilities, and at a minimum, ban new ones adjacent to residential neighborhoods.
Anything less is a prescription for potential disaster.