Threat from Climate-Induced Spills Goes Beyond Superfund and Toxic Release Inventory Sites

by David Flores

March 19, 2018

This post is the first in a forthcoming series about climate change and the increasing risk of floods releasing toxic chemicals from industrial facilities in Virginia.

At the tail end of winter, a succession of "bomb cyclones" and nor'easters has brought fierce winds and surging coastal flooding to the mid-Atlantic and Northeast. These storms remind us of the deepening vulnerability of our coastal and riverfront communities and infrastructure to intensifying extreme weather and flooding. This "freakish" winter weather comes just six months after a previously unimaginable trio of hurricanes laid waste to parts of Texas, Florida, and Puerto Rico. The flooding that followed the hurricanes also unleashed significant amounts of toxic chemicals into the environment, signaling that any state with industrial facilities near coasts and in floodplains – including Virginia and other mid-Atlantic states – could be vulnerable to toxic floodwaters in the aftermath of powerful storms.



While much of the nation's attention has shifted away from the severe weather events of the past six months, many returning residents and local governments are rightly concerned about the potential toxic contamination wrought by destructive floodwaters scouring pollution from industrial sites. And they should be. Most lawmakers in federal and state governments have ignored the deepening need to address the threat posed by the broad gap in protections between our flood control and pollution control regimes.

Fortunately, mainstream media are starting to take notice. A decade ago, we learned about the 8 million gallons of oil and gas spilled throughout Louisiana and Alabama following Hurricane Katrina. Not long after Superstorm Sandy, a consortium of researchers and journalists in New Jersey took a thorough look at the state's federally permitted facilities and found that almost 1,700 are vulnerable to five feet or more of sea level rise. In the years since Katrina and Sandy, we have seen incrementally more reporting on the climate vulnerability of industrial sites and the resulting phenomenon of toxic floodwaters.

For those parts of the country far removed from September's historic hurricane season, it must have seemed as though the succession of record-breaking storms crawled across our coasts in slow motion. Their forecasting and the long duration of the events provided an opportunity for several outlets to analyze and report about industrial vulnerability in advance of the storms and in near real-time. FiveThirtyEight published an interesting map of hospitals, Superfund sites, Toxic Release Inventory (TRI) facilities, and nuclear power facilities in Hurricane Irma's projected path. CPR took a look at climate-vulnerable communities in Florida ahead of Irma, comparing their likely burden of recovery to that of President Trump, who owns several properties in the state. After Hurricane Harvey, the Union of Concerned Scientists published an impressive interactive map illustrating the industrial facilities, including wastewater treatment plants and major oil and gas facilities, exposed to the observed and modeled extent of flooding throughout Texas, while The New York Times published maps identifying the location of reported oil and hazardous waste spills, storm-induced air pollution emissions, and flooding of Superfund sites as a result of Hurricane Harvey.

Last month, The New York Times reported on the nationwide vulnerability to flooding of so-called Toxic Release Inventory sites within Federal Emergency Management Agency-designated flood-zones. The Times located some 2,500 TRI facilities within the nation's designated 100-year floodplains. TRI facilities are a narrow category of sites that are required by federal law to publicly report permitted toxic pollution releases if they process or use particular toxic chemicals above certain thresholds – they hardly represent the universe of industrial facilities that deal in toxic and hazardous materials. Regardless, the extent of flood-vulnerable TRI facilities should capture the attention of and action by regulators in every state. However, the Times' analysis – along with that of FiveThirtyEight and Union of Concerned Scientists, among others – misses the bigger picture. It's only a slice – albeit a particularly toxic one – of the larger threat of toxic floodwaters and the health risks posed by flooding of industrial sites.

So what exactly is missing from the picture? Surely the risk of exposure is growing as more and more Superfund, TRI, and other industrial sites become increasingly vulnerable to rising sea levels, expanding floodplains, intensified precipitation, and larger and more frequent hurricanes hurtling through wider and more unpredictable pathways. In this sense, the climate side of the equation is magnifying. However, Superfund, TRI, and nuclear power facilities are only some of the thousands of different types of industrial sites – broadly defined – that cluster near waterways and highways in both rural and urban communities. Prior mapping efforts have missed thousands of sites that also store, produce, or transport hazardous materials or contamination in varying magnitudes of toxicity, quantity, and sensitivity to inundation. Sites like public landfills, agricultural supply stores, and brownfields subject to voluntary remediation are among sites that have been left off of such maps.

With such gaps in mind, we recently examined specific areas of Virginia and found industrial facilities vulnerable to climate impacts at numbers far exceeding those counted among Superfund and TRI reporting sites exclusively. In the state capital, Richmond, we identified 126 industrial facilities subject to EPA regulatory or reporting requirements that are located within Federal Emergency Management Agency-designated flood zones. Of those, 11 are TRI-reporting facilities, while the other 115 include sites like metal-plating facilities using such toxic substances as hexavalent chromium, wastewater-treatment plants storing millions of gallons of untreated sewage and industrial waste, and petroleum facilities with underground storage tanks containing oil and gas. Significantly, the figure excludes industrial sites that are subject to state regulatory control or that are unregulated altogether, meaning the actual number of facilities vulnerable to climate impacts and flooding is likely much higher.

CPR intends to build on this analysis throughout the rest of the year, taking a close look at the climate vulnerability of all kinds of industrial facilities located in Virginia's James River watershed, from the mouth of the Chesapeake Bay to the highland communities of Covington and Clifton Forge. Working closely with our partners at Chesapeake Commons and the James River Association, we will also study communities that are themselves vulnerable to flooding and exposure to floodwaters contaminated by upstream toxic spills. In their way, these communities are not unlike Crosby or Port Arthur in Texas, two communities surrounded by polluting industry that were exposed to spilled chemicals from the Arkema chemical plant and Valero Energy refinery, respectively, during Harvey. Pairing our geospatial and policy investigations, we will build broad awareness about toxic floodwater risks in Virginia and, if all goes well, determination among policymakers, communities, and advocates for state and local solutions.

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Also from David Flores

David Flores, J.D., is a CPR Policy Analyst. He joined CPR in 2016 to work on climate adaptation policy and advocacy. Before joining CPR, Mr. Flores spent eight years working for watershed nonprofit Blue Water Baltimore, where he managed water quality monitoring research, legal and regulatory advocacy, and Clean Water Act compliance monitoring and enforcement programming.

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