McDaniel Lambert, Inc.
Introduction
As the title of this paper indicates, we intend to discuss the requirement for communicating worst case scenarios under the EPA’s recent Risk Management Plan rule. Over the course of the paper, however, you’ll probably notice that we are also discussing a few things, which–at first glance–don’t seem to fit into a worst case scenario. In fact, many of the things we describe might seem more ordinary than catastrophic. What’s so bad, you might soon be asking–much less “worst case”–about a 20-year-old state law, some dead trees, and a few dirty cars? What do such things have to do with Toxic Impact Zones and circles of death? The answer is: more than you might expect. In fact, an understanding of and willingness to respond to the concerns that are part of the “everyday scenario” is central to planning communication about the ultimate catastrophe.
This train of thought is counter to much of the discussion leading up to EPA’s release of the Risk Management Plan rule for worst case scenarios. Indeed, in some cases, the new rule has led members of industry to expect a business catastrophe of major proportions. Especially troubling to many are the requirements for communicating with the public about worst case scenarios, a task that seems to inspire its own share of worst case thinking: What if our communication efforts just throw everyone into a panic? What if a bunch of environmental activists try to disrupt the whole process? What if some disgruntled community members try to use this opportunity to chase industry out of town?
For industries in many states, the Risk Management Plan has created a set of demands requiring a new and difficult kind of communication, a task that seems especially daunting to facilities which have in the past seen no need whatsoever to communicate with the public.
The good news is that communicating with the public about worst case scenarios doesn’t have to be a dire prospect. As we will illustrate, the principles necessary to guide this process aren’t all that different from those needed in day-to-day communications about health and environmental risk. In planning for the Risk Management Plan, it is necessary to remember that communication with the public is a process that you need to develop over time. If your facility waits until the results of your worst case scenario are in before making any attempt to communicate with the public, you quite likely will be facing a concerned or angry public at your community meeting. And this public may be wondering why your facility is only now starting communicate-and about such a catastrophic possibility.
Our case study focuses on a successful communication program established at an ammonia and urea manufacturing plant in Kenai, Alaska. This program included public discussion of what would happen in the event of a catastrophic ammonia release, and resulted in the creation of a Shelter-in-Place video, which the company created with the assistance of local residents and the fire department. Kenai’s “catastrophic success story” is a telling example of how communicating with the public about worst case scenarios can actually provide a valuable opportunity for industrial facilities to improve relationships with the communities in which they operate.
In this paper we will focus on what you need to do to communicate effectively with the public, including: 1) the importance of making worst case scenario planning part of a long-term risk communication process; and 2) the need to actively involve the public, including your own non-management employees, trusted and credible third-party sources, and special target audiences.
I. Assessing your Environmental Vulnerabilities: Identifying a Long-Term Risk Communication Strategy
In planning your communication strategies under the Risk Management Plan, the central point to keep in mind is the importance of making the worst case scenario discussion part of a long-term risk communication effort. You need to ask some central questions: Where does your facility stand in relation to the local community right now? Is the public aware of the facility? Have you built a relationship with community leaders and groups? What is the facility’s health, environment, and safety record? Have key employees received training in risk and crisis communication? What media coverage, if any, has your facility received?
Answering these questions will take time, as will initiating new activities and strategies to respond to concerns that will be raised in the process. But time invested up front will save time later on by helping you anticipate and avoid many potential difficulties along with way.
And this brings us to the discussion of a twenty-year old state law, some dead trees, and a few dirty cars, all of which-for better or worse-were part of the situation facing the company’s Kenai Fertilizer Plant in 1992.
The Kenai Plant was built in 1968 and expanded in 1977. The facility includes two ammonia manufacturing plants and two urea plants. The Kenai Plant is located on the major road linking the cities of Kenai and Nikiski, Alaska. The area between the two communities is heavily forested and generally semi-rural, with small commercial operations along the highway and several side roads leading up to a few scattered residences and small subdivisions. The year-round population living within a half-mile of the plant is less than 10, and about 100 residents reside within one mile of the plant. About 1,000 residents live within two miles of the plant.
Despite the low population density in the immediate area, it was impossible for the Kenai Plant to retain a low profile. The Kenai Plant is one of the largest plants of its kind in the world-the biggest point source emitter in Alaska and, in 1988, number 12 in the nation. Every day the plant produces approximately 3,800 tons of ammonia, about half of which is combined with carbon dioxide to produce 3,400 tons of urea. And every year, the plant tops the regional emissions list on the Toxics Release Inventory, mostly because of the amount of ammonia released. 80,000 tons of ammonia are stored on site-“80,000 tons of death,” as one employee wryly put it.
So when a 20-year-old state environmental law began to be reinterpreted in local administrative courts during the early 1990s, Kenai knew it would not have the luxury of hiding its head in the Alaskan snow. The law in question states that “No person may permit any emission which is injurious to human health or welfare, animal or plant life, or property, or which would unreasonably interfere with the enjoyment of life or property” (18 AAC 50.110). In 1992, this law was referenced as part of the Sierra Club’s attempt to invalidate an air permit that had been granted to a pulp mill in Sitka. The permit was revoked, and the mill, shut down.
Following up on this victory, environmental groups notified the Alaska Department of Environmental Conservation (ADEC) that they would challenge any new permits that did not include some showing of compliance with this statute. The company recognized that a major part of its credibility was defined simply in relation to its status as a member of a chemical industry.
To make matters more complicated, the Kenai Plant’s personal relationship with the community had also suffered over the years, in large part because of a swath of dead trees cutting out a path out that extended away from the plant. About ten acres of trees northwest of the plant had died ten or fifteen years earlier; by the early 1990s, most of the lifeless trees were still standing, a sign to the public of ammonia’s deadly power. Ammonia plant and brown, leafless trees-it looked like a clear case of cause and effect to the surrounding community. From the air, travelers could see that the steam plume emanating from the plant precisely matched the position of the dead trees. For years, company denied that there was any proven connection between the dead trees and the ammonia. The public didn’t agree.
Indeed, a 1988 survey of local residents suggested that the community saw the dead trees as a symbol of the company’s overall insensitivity. Moreover, a lack of concrete information about what killed the trees seemed to contribute to the spread of rumors concerning the relationship between ammonia, urea, poisoned water, and polluted air.
Another problem facing the company concerned a history of complaints from an industrial neighbor downwind from the plant. At the Phillips Petroleum Plant, employees frequently complained about damage to their cars from the ammonia fumes. “We don’t like ammonia/urea all over our cars!” one employee explained in response to a survey. “At what point does the company feel its responsibility for its emissions ends?” asked another. And while they were busy cleaning the residue off their cars, Phillips employees worried about the potential for catastrophe at the ammonia plant. “We hear your alarm sound and then wait on pins and needles wondering what’s going on and what to do,” one worker said.
All of these issues are typical of the concerns, problems, and situations facing industry every day. A new regulation is created, or an old regulation is reinterpreted, requiring new compliance measures. Community members don’t like the way an industrial facility looks, smells, or sounds, and later they become suspicious about the safety of that facility. Employees at one industrial facility start focusing their attention-and their complaints-on the problems of another facility.
Such issues and concerns are usually not pleasant to deal with, but they are an unavoidable part of the context in which any communication-either about routine issues or catastrophic chemical releases-will occur. It is thus essential that industrial facilities understand and address day-to-day concerns in order to communicate effectively with the public.
Therefore, we recommend that, before beginning to scope out the details of a worst case scenario, your facility take the time to assess potential environmental vulnerabilities which could leave the facility open to public concern and even outrage.
Environmental vulnerability factors are not identical to industrial hazards. In fact, the sorts of things that might make a facility vulnerable to public outrage are often not even noticeable to members of industry. Who cares if the company sign is looking a little bit rusty as long as the plant is safe? What’s wrong with a bit of odor when it means the smell of money is wafting in the breeze? And what can industry do about the fact that somebody built a school across the street from a refinery or ammonia plant that had been in the neighborhood for decades?
Environmental vulnerability factors do matter, however, often quite a lot. In addition to the things just mentioned, these factors include physical cues to ongoing pollution, proximity to important scenic or cultural sites, large volumes of emissions or hazardous wastes, and a history of poor community outreach. Environmental vulnerability factors are especially important because they can damage the credibility of your business, which can seem uncaring, uninvolved, or uninterested in the community’s well-being. A list of common environmental vulnerability factors is provided in Table One.
It is important to begin identifying your facility’s vulnerabilities now. Then, you need to seek out remedies to these problems. Keep documentation of the actions you’ve taken to remedy the situation. If appropriate, have the work you’ve done reviewed by an outside observer, such as a community resident or member of the local fire department.
The Kenai Plant identified several areas of environmental vulnerability, which are summarized in Table Two.
For the Kenai Plant, the most important and effective “remedy” to address a number of concerns was to reduce emissions. In fact, ammonia emissions have been decreased 95% between 1986 and 1996. To effect these reductions, the company used a combination of techniques, including the installation of ammonia recovery systems, the modification of operating methods, and the installation of flares to burn non-recoverable emissions and upset releases. The company also sought out appropriate forums, including newspaper notices and public meetings, to let the public know what the plant had done to reduce emissions and to provide other information about ammonia.
In 1992, the Kenai Plant initiated a tree-planting program, with more than 1,200 seedlings planted to replace the trees that had died ten to fifteen years earlier. Equally as important, the facility finally took responsibility for the dead trees and explained to the public how new operational conditions would prevent such a problem from happening again.
Another step taken by the company was to conduct a human health and environmental risk assessment to evaluate the potential effects of air emissions from the plant. This step was required in order to comply with the environmental law cited earlier and to ensure renewal of an air permit in November 1993. In performing the health risk assessment, however, the Kenai Plant went beyond compliance in two important ways: 1) the company sponsored a community meeting to make public the results of the risk assessment as soon as they were available; 2) In response to community interest, the company discussed the possibility of a catastrophic ammonia release and worked with the community to provide information to the public about how it could be protected in the event of such a release.
Rather than alarming the public, Kenai’s discussion of Shelter-in-Place was effective and reassuring for many because it emerged out of a long-term process of gradually improving relations and communications between the company and the public. This relationship will be of central importance to Kenai’s own future efforts to comply with the Risk Management Plan.
II. Working with the Public
In planning to communicate about worst case scenarios, it is important not to view the public as some nameless mass ready to run into a panic at the first mention that a risk exists from the facility. On the other hand, it is also necessary to recognize that there are some complex issues involved in the communication of a worst case scenario. Advance planning is essential, as is this often-repeated and seldom-followed piece of advice: Know your audience.
Because of the great strides made in recent years to improve the safety of industrial facilities, members of industry are often quick to emphasize the safety features that exist to prevent major accidents. And the public does appreciate the measures taken to improve industrial safety. But the memory of major disasters–Bhopal, Three Mile Island, the recent TWA crash-means that the public will also continue to recognize that the worst, can, in fact, happen. As a result, the public wants to know what will happen if the worst case does occur. In other words, how will the facility know that something is wrong and what will the facility do about it?
In addition, it is essential to remember this key point: the public already knows there is a risk. They want you to talk about it.
The Shelter-in-Place meeting and video developed by the Kenai Plant provide an encouraging story of catastrophe communication. One reason for the program’s success lies in the interaction between company employees and community members in the discussion of catastrophe planning. Kenai’s health, environmental and safety manager knew from his work on the Local Emergency Planning Committee that the community was concerned about the potential for catastrophic releases. He brought this knowledge to the planning table.
And Kenai employees made a simple, but very important observation: If people want information about what to do in the event of a major catastrophe, there is no sense in arguing, “This can’t happen here.” It is really much easier to say, “This is what we are prepared to do to protect this community in case worse comes to worst.”
Kenai’s discussion of Shelter-in-Place techniques emerged out of a public meeting that was held to discuss the results of the health risk assessment. At that meeting, environmental specialists from the company included discussion of a worst-case scenario developed from the health risk assessment. They asked, What would be the health risks to a person living for 70 years at the place with the potential maximum off-site exposure. This person “spent all his time outside and ate vegetables and meat that had been exposed to the emissions” (Peninsula Clarion, 11/5/93). The company reported that the increased cancer risk from such an exposure would be one in a million. The community and the local press appreciated the information. In addition, the much more difficult issue of catastrophic release was also broached at that meeting, leading one resident to pose the now-famous question, “But what am I supposed to do when one of your ammonia tanks fails?” This question ultimately resulted in the making of the Shelter-in-Place video and training workshops.
In preparing for the initial meeting, the company recognized that it would be important to involve non-management employees in the public discussions. Before the November 1993 public meeting, the company held a series of meetings about the results of the health risk assessment with its own employees, who were paid overtime to attend. Employees were encouraged to come to the community meeting, and many did, bringing their families. In addition, a series of meetings were held specifically for employees of the neighboring Phillips Petroleum facility to discuss such concerns as ammonia hazards, plant detection systems, and personal protective equipment.
In developing the video and the workshops, the company also solicited the active participation of credible, outside third-parties, including representatives from the fire department and the local elementary school. Firefighters assisted in the presentation and explanation of Shelter-in-Place techniques, while school children and other local residents were called upon to demonstrate such techniques in the video. The Shelter-in-Place video itself resulted in large part from the interest shown by a teacher at the local school who wanted to learn and teach others shelter-in-place techniques.
The production of the video and the series of community training skills workshops provided an effective follow-up to the discussion that began at the meeting held to discuss the health risk assessment. The program has been successful in large part because Kenai employees took the time to identify key audiences, to respond to the public’s concerns, and to involve these audiences actively in the communication process.
III. Conclusion
In concluding, we would like to re-emphasize a point that has been central to this discussion: communication is a process, and that process needs to get underway early.
Communication about worst case scenarios under the Risk Management Plan will never be easy, but the process will be much easier if all parties-industry, regulators, and the public-are involved up front. For industry’s part, this means assessing the environment vulnerabilities of your facility, identifying key audience concerns, and working with the public to address those concerns.
By doing these things, your facility will be in a much better position to talk with the public about the potential for a catastrophe. And you will be in the position to avoid a communications catastrophe in the process.
Table One. Environmental Vulnerability Factors
· Physical cues to ongoing pollution, e.g., clouds of steam, smells, noise
· History of community or employee health complaints
· Large volumes of emissions or hazardous wastes
· History of unexplained odors or releases
· Presence of “dreaded” substances, such as those known to cause cancer
· Poor facility housekeeping or appearance
· Proximity to sensitive locations, including schools, nursing homes, and hospitals
· Reports of health problems among school children or staff
· Proximity to important scenic or cultural sites
· Active presence of organized environmental groups
· History of poor community outreach
· Lack of risk and crisis communication training
Table Two. Kenai Plant: Environmental Vulnerability Assessment
· Presence of visible plumes from stacks from the plant
· Periodic episodes of odors emanating from the plant
· Presence of significant quantities of “acutely hazardous materials”
· Large volumes of product stored or handled
· Proximity to important scenic or cultural sites including the Cook Inlet and the Kenai National Wildlife Refuge
· Past incidents which received media coverage, including the dead trees visible across the street from the plant
· Target of environmental/special interest groups: Greenpeace once protested against the plant by chaining themselves to a shipping dock.
· Complaints about health effects, including working conditions at cooling tower
· Complaints about environmental problems, including drift from the cooling tower
· Failure to develop outreach program: strained relationship because of dead trees, cooling tower issues
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