Is this a safe place for children to frolic in a splash pad? Here are some of the toxic contaminants and safety risks not visible in the above photo…
A post in today’s Cap Times online raises important questions about whether the children’s splash pad planned at the Goodman Community Center will be a “healthy and safe place” for “good clean fun,” as the center’s Executive Director Becky Steinhoff assured us it will be in the May/June issue of the Eastside News.
Adding to questions raised in previous posts, there is a glaring omission in considerations about the safety of this location for a splash pad. Trucks carrying chlorine, toxic chemicals, and hazardous wastes to and from Kipp—and spewing hazardous diesel fumes—will rumble just feet past the children’s splash pad many times a day, every day.
Aluminum die casting is inherently toxic and dangerous, and Kipp has a lousy health and safety record. As we outlined in a previous post, between 1998 and Feb. 2014, the Madison Fire Department/EMS (emergency medical services) made 172 calls to Kipp for fires, explosions, accidents, and/or worker health problems and injuries.[1]
Kipp uses, stores, and transports chlorine, in addition to numerous other highly toxic chemicals. Chlorine is a highly toxic gas that can cause severe health problems (including death) to people exposed to high enough levels. Severe health effects from chlorine inhalation can occur within minutes—well before HazMat teams can get to the scene. The highest potential for such a release near Kipp is during the transport of chlorine; for details, see Kipp’s “Hazardous Materials Incident Initial Response Guidelines.” . With all the trucks going in and out of Kipp for well installation, remediation, etc., the chances of such an accident have likely increased in recent years.[2]
What will happen if there is a chlorine truck accident involving a chlorine release next to the splash pad while children are playing there? What plan does Goodman Community Center have in place for such an incident at its facility? Not long ago, community members asked Goodman Center staff this question and they had never heard of such a plan; they were clearly unprepared. How will the center staff handle such a chlorine or other toxic material accident next to a crowded splash pad? How will kids at an outdoor splash pad “shelter-in-place” if a chlorine spill happens 50 feet away?
[1] The actual number of fires, accidents and injuries is probably higher than this, since Kipp likely tries to avoid calling the Fire Department unless the accidents reach a certain severity level.
[2] Emergency Planning and Community-Right-To-Know (EPCRA)
MKC uses, stores, transports, and releases many highly hazardous chemicals, and is required to follow Emergency Planning and Community-Right-To-Know laws—see here for federal regulations and here for Dane County. Hazardous chemicals at Kipp include chlorine, propane, sodium hydroxide, nitrogen, fluorides, molten aluminum, fuel oils, lubricants and many more. The use, storage, and transport of chlorine are among the most potentially dangerous situations at and around Kipp. According to the “Hazardous Materials Incident Initial Response Guidelines” for Madison Kipp, “the worst-case scenario would involve chlorine being released directly to the outside of the facility during transport.”
Chlorine’s health effects: Permissible Exposure Level–1 ppm; detectable odor threshold–over 1 ppm; 3-5 ppm–slight irritation of the nose and upper respiratory tract; 5-8 ppm–irritation of the respiratory tract and eyes; 10 ppm– immediately dangerous to life and health; 15-20 ppm–immediate severe irritation of the respiratory tract, intense coughing and choking; 30 ppm–shortness of breath, chest pain, possibly nausea and vomiting; 40-60 ppm–development of chemical bronchitis and fluid in the lungs, chemical pneumonia. Prolonged exposure over 50 ppm will cause unconsciousness and death.
Two types of “vulnerability zones” for chlorine accidents at Kipp were modeled in Kipp’s Haz Mat Guideline document. One is the area in which chlorine levels could reach 1/10 of the IDLH (immediately dangerous to life and health)—or the level that “poses a threat of exposure to airborne contaminants when that exposure is likely to cause death or immediate or delayed permanent adverse health effects or prevent escape from such an environment.” The 1/10 factor is added to protect especially vulnerable people, such as those with respiratory disease or illness. The IDLH for chlorine is 10ppm so the 1/10 IDLH is 1ppm. An alternative vulnerability zone based on ERPG-2 (Emergency Response Planning Guidelines), or “the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual’s ability to take protective action.” The ERPG-2 for chlorine is 3 ppm.
Vulnerability zones for chlorine releases are: 3.1 miles at 1 ppm (1/10 IDLH), 1.9 miles at 3 ppm (ERPG-2) “in the worst case scenario, dangerous or deadly levels of chlorine contamination may reach a distance of between .1 and .25 miles downwind of the source within a matter of minutes following the initial release.” Later, the document states that “The lead time for a HAZMAT incident could be from 15-40 minutes. As a result, this short time may not allow for a safe evacuation…An evacuation under these circumstances may expose the population to dangerous toxic chemicals and the decision may be made to shelter-in-place.” The document then lists 11 “shelter-in-place” recommended instructions.
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Do you live in the Kipp Neighborhood? If there is a chlorine accident at Kipp or an accident involving a chlorine truck on a street in the neighborhood:
-How will you know? Is there any system in place to immediately notify you and others in the neighborhood?
-Do you/your family know what the “shelter-in-place” steps are? Do staff at Goodman Community Center/Lowell School?
-Is the community prepared? Are people near Kipp even aware that the potential exists for such an accident?
If you live in the Kipp neighborhood, contact your elected officials, public health agencies, Madison Fire Department and OSHA, with questions. Ask them to look into whether Kipp is following EPCRA laws. Ask them to initiate a public meeting to help prepare residents, schools, and community centers for a chlorine and/or other hazardous chemical accident at or around Kipp. Always include your street address when contacting your political representatives.
Madison Alder Marsha Rummel: 608-772-4555, district6@cityofmadison.com
Senator Fred Risser: (608)266-1627, sen.risser@legis.wisconsin.gov
Representative Chris Taylor: (608) 266-5342, Rep.Taylor@legis.wisconsin.gov
John Hausbeck (Epidemiologist, Madison Dane County Public Health): 608.243.0331, JHausbeck@publichealthmdc.com
Henry Nehls-Lowe (Epidemiologist, Department of Health Services): 608-266-3479, Henry.NehlsLowe@dhs.wisconsin.gov
Dave Bursack, Dane County Local Emergency Planning Committee: 608-266-9051,
Madison Fire Department: 608-266-4420, fire@cityofmadison.com
Occupational Safety and Health Administration (Madison Office): (608) 441-5388
