Environmental expert responds to Carus letter

Prior to La Salle’s City Council meeting Monday, Carus Chemical’s president and CEO issued a letter to Mayor Jeff Grove rebutting information presented by a toxics and remediation specialist from the Sierra Club, who issued her letter to the Environmental Protection Agency and Illinois EPA on her own time.

Denise Trabbic-Pointer, a certified hazardous materials manager volunteering her time in La Salle, has since replied, saying Tuesday she’s not completely sold on some of the arguments from Andy Johnston, the president and CEO of Carus, in his letter.

Trabbic-Pointer’s letter focused primarily on Carus’ facilities and its safety procedures.

Given that residents are finding heavy metals in tests from furnace filters and yards, Trabbic-Pointer said Tuesday what’s at issue is the city’s residents need more testing to determine what’s in the environment and what needs remediation. She is advocating for surface wipe tests, especially where children are present, to ensure the community’s safety, among other recommendations.

She said her March letter to the federal and state EPA agencies was to advocate for a more comprehensive review of remediation and safety procedures, following what she believes was a hasty designation from those agencies. The federal and state EPA have said they don’t believe further testing is necessary, but they have not issued a formal reply to her March letter about the facilities as of yet.

I’m just bringing up the potential and the community concerns.

—  Denise Trabbic-Pointer, a toxics and remediation specialist volunteering her time in La Salle

In a March letter that started the exchange, Trabbic-Pointer said Carus uses a generic emergency response plan that provides little specific data about what is stored on-site; she outlined concerns pertaining to the movement of materials from the Carus site to the Apollo warehouse in La Salle and then to a Lotz Logistics warehouse in Ottawa; she wrote most of the materials stored and manufactured at the facility are solids that can become airborne during storage, handling and use.

Carus responded to Trabbic-Pointer, writing that many of the claims are inaccurate.

“Carus does not have 36 facilities in the La Salle area; we have three,” Johnston wrote. “There is the La Salle plant, the Apollo warehouse, and our headquarters.”

Carus has comprehensive site-specific emergency response plans for all facilities, Johnston said. These plans are federally mandated to be updated regularly and available for regulatory inspection upon request, he said.

“These are not generic plans,” Johnston wrote. “Based on local, state, and federal regulations, this is not allowed.”

Johnston said in the letter that plans can’t be publicly shared, but he said first responders, elected officials and regulators all have access to the plans.

In response, Trabbic-Pointer said Tuesday the comment about 36 facilities was not just Carus. She said sources in the fire department said they had generic plans for 36 or more industries in their area.

“So it doesn’t sound like ‘first responders’ have a copy of the comprehensive plan that Carus says they have,” Trabbic-Pointer said.

Trabbic-Pointer wrote in her March letter the Carus facility uses, stores and manufactures water-reactive and oxidizing materials.

“Carus does not manufacture any water-reactive chemicals,” Johnston wrote in response.

Trabbic-Pointer replied, “We’re both sort of right.”

“As mentioned by Carus, manganese reacts with water to evolve hydrogen gas, which is highly flammable,” Trabbic-Pointer said. “I agree that this is true. It reacts slowly with water, unlike some substances designated as water-reactive that react violently.”

Trabbic-Pointer noted shipping descriptions usually state “metallic substance, water-reactive, N.O.S. (Manganese).”

In her march letter, Trabbic-Pointer said the Jan. 11 fire was initially reported as a release of chlorine from a tanker. Johnston said in his letter, Carus doesn’t have or store chlorine at the La Salle plant.

Trabbic-Pointer said she was referring to information shared from the National Response Center call logs for Jan. 11, noting it appears the item was edited following the 30-day report from Carus.

“Chlorine was the initial chemical release reported and the corrected information still includes chlorine,” Trabbic-Pointer said. “It is not unusual to correct the record once all relevant information is known. What is notable is that they report a release of chlorine and Carus states in their public letter that they don’t use chlorine.”

In Trabbic-Pointer’s initial letter, she said most of the materials stored and manufactured at the facility are solids that can become airborne during storage, handling and use. If such dust is suspended in the air in the right concentration, it can become explosive under certain conditions.

“We have previously tested all applicable materials for explosive dust material, which have all been found to contain insufficient concentrations that would cause a fire or deflagration hazard,” Johnston said. “Carus does not manufacture any materials that could be a combustible dust hazard.”

Trabbic-Pointer said Johnston only mentioned part of her statement in his letter.

“OSHA explains that any combustible material can burn rapidly when in a finely divided form,” Trabbic-Pointer wrote. “If such a dust is suspended in air in the right concentration, under certain conditions, it can become explosable. The force from such an explosion can cause employee deaths, injuries, and destruction of entire buildings. Video of the fire as it began and several explosions followed, appears to indicate that combustible dusts may have either been [the] cause or exacerbated the fire and explosions. Some of the dusts that are generated from facility processes and product handling are combustible dusts.”

Carus has said that damaged packaging of potassium permanganate led to Jan. 11 fire, according to a third-part consultant. The Illinois State Fire Marshal’s Office also conducted a preliminary investigation and found the cause of the fire undetermined with no evidence of suspicious activity.

Trabbic-Pointer questioned Carus’ explanation for the cause of the fire.

“The explanation appears incomplete to me,” she said. “A spark is only part of the fire triangle. They had a spark and oxygen in the air. What was the fuel source? I doubt it could have been just the pallet that set on fire and created the subsequent explosions.”

Trabbic-Pointer said some examples of materials that may be a dust explosion hazard if present as a fine powder include almost any organic material - grain flour, sugar, plastic, corn starch, pharmaceuticals. Powdered metals such as aluminum and magnesium also present a dust explosion hazard. Manganese dust dispersed in air in sufficient concentrations, and in the presence of an ignition source, may be flammable in open spaces or explosive in confined spaces, she said.

In the initial letter, Trabbic-Pointer indicated the Carus facility may be subject to the Clean Air Act and have to report as a different designation, requiring more plans on safe handling and storage, by possibly being above a threshold pertaining to concentrated hydrochloric acid and chlorine.

“The Carus La Salle plant employs basic inorganic manufacturing, not alkaline and chlorine manufacturing,” Johnston wrote. “We have undergone numerous audits and evaluations. Nothing used at the LaSalle plant would be subject to the Clean Air Act Risk Management Program or Process Safety Management.”

Johnston said Carus purchases 37% hydrochloric acid solutions, so no risk management plan is required at the La Salle plant.

“Their responses to the question of hydrochloric acid and whether the waste they send to Ottawa landfill is hazardous or nonhazardous is something that they have to prove to EPA, not me,” Trabbic-Pointer said. “I’m just bringing up the potential and the community concerns.”

In her initial letter, Trabbic-Pointer said some waste materials from the site were reportedly disposed in a Carus-owned landfill, Disposal Area 3, in nearby Ottawa.

“These wastes appear to be characteristic and toxic waste,” Trabbic-Pointer said. “The community would like to know how Carus has determined that the waste placed on land at Disposal Area 3 is not hazardous waste and why they are not required to have a permit as an industrial solid or hazardous waste landfill.”

The material in the Carus landfill is not, and has never been, classified as hazardous, Johnston said.

Trabbic-Pointer said the waste appears to be primarily comprised of manganese, which is flammable in its powder form and reacts slowly with water to produce flammable and explosive hydrogen gas.

“Manganese metal in a powder form can produce hydrogen gas when mixed with water,” Johnston said. “Carus does not manufacture manganese metal, so there is no way it could mix with water and produce a fire.”

Trabbic-Pointer added in her initial letter: “There is a potential for the wastes in Disposal Area 3 landfill to become airborne and therefore an inhalation health risk to the community as well as a risk for waste materials to be deposited on nearby surfaces, soil, and surface waters. In addition to daily hazards posed by the landfill, manganese powder poses a potential risk of explosions and/or fires.”

Johnston replied: “There is no manganese metal, which would produce a powder, in the landfill. The waste that is deposited there does not get airborne. There is a high enough moisture content to prevent that from happening. The waste does not exhibit any hazardous characteristics.”

Trabbic-Pointer said again that is something Carus will need to prove to the EPA.

“They need to ensure it can’t be washed into nearby surface water or into the river,” she said. “They need to provide assurances to the community and they should be specific about how they know it can’t become airborne or go into the river.”

Trabbic-Pointer said asking questions will help ensure the La Salle residents safety.

The toxics and remediation specialist is expected to be at the next La Salle City Council meeting to examine future prospects for more testing in response to the Carus fire.