Kids in Danger Zones 

One in Three U.S. Schoolchildren at Risk from Chemical Catastrophes

SEPTEMBER 2014
AUTHORS

Amanda Frank, Policy Analyst, Citizen Health & Safety

Sean Moulton, Director of Open Government Policy

CONTRIBUTORS

Denise Moore, Database Administrator

Katherine McFate, President and CEO 

Brian Gumm, Communications Director 

Lukas Autenried, Open Government Intern

July Tran, Regulatory Policy Intern

PHOTO CREDITS

Flickr user Presidio of Monterey (Creative Commons)

Flickr user smi23le (Creative Commons)

Flickr user Jonas Bengtsson (Creative Commons)

ACKNOWLEDGEMENTS

The Center for Effective Government’s work on chemical safety issues is made possible by the generous 

support of the Bauman Foundation, Ford Foundation, Open Society Foundations, Cornell Douglas Foundation, Rockefeller Brothers Fund, Scherman Foundation, SR Mott, and anonymous donors. 

ABOUT THE CENTER FOR EFFECTIVE GOVERNMENT

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common good, protects people and the environment, and advances the national priorities defined by an 

active, informed citizenry.

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or in part, are permitted to do so if they provide attribution to the Center for Effective Government as the 

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Kids in Danger Zones

One in Three U.S. Schoolchildren at Risk 

from Chemical Catastrophes
TABLE OF CONTENTS

Executive Summary 

 

Introduction

What Did We Find?

1. Risk Broadly Dispersed and Concentrated in Some Areas

2. The Riskiest Facilities

3. The Chemicals that Create Risk, Less Dangerous Alternatives

How We Can Make Our Children Safer

 

Appendix I: Methodology

1. Previous Analysis

Appendix II: Table A - Number of Students in Vulnerability Zones, by State

Appendix III: Table B - Percentage of Students in Vulnerability Zones, by State

Appendix IV: Table C - Facilities that Put 200,000 or More Students at Risk

Appendix V: Number of RMP Facilities and Vulnerability Zone Populations in This 

Report by Industry Sector

1

5

7

7

12

15

17

21

22

24

26

28

31
1

EXECUTIVE SUMMARY 

Shortly before 8 p.m. on April 17, 2013, a fertilizer storage and distribution facility in West, Texas 

exploded, killing 15 people, injuring more than 200, and destroying over 150 buildings, including three 

schools. Had the explosion occurred during the day, scores of children could have died. 

This is not an isolated case. In August 2012, the release of a toxic cloud from a Chevron refinery sent 

15,000 residents of Richmond, California to the hospital with respiratory problems. In January 2014, 

toxic chemicals used in coal processing leaked into the Elk River in West Virginia, contaminating the 

water of 300,000 people in nine counties. 

Hazardous facilities are reporting safety incidents every day. With an aging industrial infrastructure in 

close proximity to major population centers, and fewer state and federal staff to inspect these facilities, 

the risks are growing. 

But we can change this. There are practical, immediate steps we can take to reduce the chemical hazards 

in communities across the country and to reduce the risks our children face. This report discusses these 

steps and actions individual people can take to ensure they happen. 

Kids in Danger Zones examines the number of children who attend a school located within the selfreported vulnerability zone of over 3,400 high-risk chemical facilities in the U.S. These facilities produce, 

use, or store dangerous chemicals and so must report them to the federal Risk Management Program of 

the U.S. Environmental Protection Agency (EPA). The facilities that are the focus of this study represent 

about a quarter of all the facilities reporting to the Risk Management Program. The locations of 122,968 

public and private schools, educating 53.6 million students, were mapped against the vulnerability zones 

of these chemical facilities. 

What we found is alarming:

	At least one in every three schoolchildren in America today (36 percent of pre-kindergarten through 

high school students) attends a school within the vulnerability zone of a hazardous chemical 

facility. Over 19.6 million children in 48 states are in such a zone. Most of the children, their 

parents, and their teachers have no idea that they are at risk. [For state figures, see Appendices II and 

III, Tables A and B]
2

	Half of these children (over 10.3 million) are in schools located in more than one chemical 

vulnerability zone. The most at-risk school – San Jacinto Elementary School in Deer Park, Texas – is 

located in the vulnerability zones of 41 different chemical facilities.

	Houston, Texas; Baton Rouge, Louisiana; and Beaumont-Port Arthur, Texas are the most high-risk 

metro areas – i.e., they contain many schools in multiple vulnerability zones. Memphis, Tennessee 

and Wilmington, Delaware also have many schools located in multiple vulnerability zones. [See map 

on p. 12]

	Every single child attending school in 102 counties in 22 states, a total of over 2.3 million kids, are 

in the chemical vulnerability zone of at least one facility. The states with the most high-risk counties 

are Texas, Virginia, Kentucky, and Louisiana.

	Ten high-risk chemical facilities reported having a vulnerability zone that exposes over 500,000 

children to chemical risks. These facilities are located in New Jersey, Texas, California, and Illinois. 

The Kuehne Chemical Company in South Kearny, New Jersey, reported a 14-mile vulnerability zone 

because it has up to 2 million pounds of chlorine onsite. Depending on wind and weather conditions, 

an accident involving chlorine gas could expose over 861,000 children in Manhattan, Newark, and 

Jersey City to toxic vapors and respiratory damage.

 

Another 32 facilities located in New Jersey, Texas, California, Illinois, Florida, Arizona, and Minnesota 

reported individual danger zones that put between 250,000 and 500,000 children at risk. 

	Sixty percent or more of the students attending school in the states of Utah, Rhode Island, Texas, 

Louisiana, and Nevada are in vulnerability zones, as well as more than half the students in 

Delaware and Florida.

	California, Texas, Florida, Illinois, and New York have the largest number of students at risk

because they have the largest number of students overall and chemical facilities located in or near 

major metropolitan areas. [For more detailed information on specific states and cities, see statespecific fact sheets.]
3

What We Can Do to Keep Our Children Safe 

We can make our children safer without shutting down industrial production or losing jobs. 

	The most effective way to protect our children from chemical disasters is to require 

companies to use safer chemical alternatives when they are available. Many are already doing 

so. Bleach manufacturing and water and wastewater treatment plants represent over 60 percent 

of the facilities in this study. Chlorine is the most common toxic chemical they use. There are 

cost-effective alternatives to chlorine gas. In fact, the Clorox Company began shifting away from 

the use of chlorine gas years ago. As a result, 13 million Americans are no longer in vulnerability 

zones associated with their plants. The Blue Plains water treatment plant that serves Washington, 

DC switched from chlorine gas to liquid bleach shortly after the 9/11 terrorist attacks and reduced 

the risk to 1.7 million people. 

	Facilities can shrink their vulnerability zones by reducing the amount of toxins produced 

or stored onsite. Facilities could produce and ship their products in smaller batches instead of 

accumulating large quantities on worksites near major population centers. Reducing the size of all 

the vulnerability zones mapped in our study by half would protect 11 million children. 

	New facilities with dangerous chemicals should not be sited near major population centers 

or probable growth areas around metropolitan areas. We don’t have to keep making the same 

mistakes. New facilities should commit to the safest available technologies and chemicals and 

be located away from population centers, with established buffer zones to prevent residential 

development too close to the facilities. In some areas, this may require changes to zoning laws. 

What can you do to reduce the vulnerability of all American schoolchildren?

The Obama administration is in the midst of exploring new rules to govern the handling and safety of 

hazardous chemicals. Write to the EPA and ask the agency to develop rules that contain the demands 

above. 
4

What can you do to reduce the vulnerability of schoolchildren in your community? 

	Educate people in your school district, community, and state about the risks of chemical disasters. 

•	 Share this report and the interactive map with your friends, relatives, and neighbors so they 

can see the risks to their own schools and communities.

•	 Talk to your PTA or PTO – encourage teachers to use our curriculum to explore the issue of 

chemical risk and ways everyday citizens can make their communities safer. 

•	 Write a letter to the editor of your local paper. 

	Advocate for policy changes on the local, state, and federal levels. 

•	 Ask your city council representative to pass a resolution supporting the shift to safer chemical 

alternatives. 

•	 Ask your state representatives to require the use of safer chemicals at facilities located near you.

•	 Contact your state’s environmental agency and ask staff to hold a hearing and/or to send a 

comment to the federal EPA about reducing risks in your community.

•	 Tell Congress to support new requirements to shift to safer chemical alternatives.

•	 Register to vote and encourage candidates to support improved safety and better protections 

for children.

	Encourage the individual companies that put your schools at risk to voluntarily shift to 

safer alternatives and to reduce their “vulnerability footprint” by reducing the amount of 

dangerous chemicals they produce and store at a facility near you. 

•	 The interactive risk map allows you to find the name of the company at the center of each 

vulnerability zone, its address, and the amount of chemicals it stores. This should give you 

enough information to contact the facility and arrange a meeting. You can also use the 

information to launch a local letter-writing campaign and/or encourage a local reporter to 

investigate this issue. You can look up each facility’s enforcement record with EPA or OSHA to 

see if they have been cited for health and safety violations. Additionally, the Corporate Research 

Project may provide useful information on the corporate owners of particular facilities.

	Prepare school staff and children should a chemical event occur. 

•	 Each facility in this report is supposed to have a Risk Management Plan on record with the 

first responders and emergency management officials in your community. Ask your local first 

responders to come to the schools in your area and conduct a drill or to talk to your PTA and 

explain emergency procedures so everyone knows the plan in the event of a disaster. Eastern 

Kentucky University has produced a guide for developing an emergency action plan for 

schools that includes a wide variety of emergencies, including hazardous material releases.
5

INTRODUCTION

We value our children and do everything we can to keep them safe. We demand food labels, inspect 

imported toys, and require car seats for infants and toddlers. We require lead-free paint and unleaded 

gasoline to protect their developing brains. We monitor the quality of their drinking water. We insist that 

restaurants are clean, playground equipment is safe, and pajamas aren’t flammable. And when we send 

them to school, we want crossing guards, school nurses, reliable buses, recess monitors, and fire drills. 

We’ve passed a number of important laws to protect the health and safety of our families and children 

over the years – the Pure Food and Drug Act, the Clean Air Act, the Clean Water Act, the Safe Drinking 

Water Act, and the Food Safety Modernization Act. But one area that has proved surprisingly resistant to 

effective oversight is toxic chemicals. 

The Toxic Substances Control Act was passed in 1976 to regulate the use and distribution of harmful 

chemicals, but almost 40 years later, only 200 of the more than 84,000 chemicals currently registered for 

use in the U.S. have been thoroughly tested to determine their impact on human health. And only five 

of the chemicals shown to have a negative impact on health have actually been restricted. Literally tons 

of inadequately tested, potentially harmful chemicals and known human toxins are in use in industrial 

production sites and storage facilities across the country. These stocks of toxic chemicals represent a 

looming, silent risk in communities nationwide. 

The risk only becomes visible when catastrophes occur – like the chemical cloud that escaped from a 

Chevron refinery in 2012 and blanketed Richmond, California, sending 15,000 people to the hospital; or 

the fertilizer distribution center that exploded in West, Texas in 2013, killing 15 people; or the Elk River 

leak of 7,500 gallons of toxic chemicals earlier this year that contaminated the water supply of 300,000 

West Virginians. Unfortunately, as the industrial infrastructure of private companies ages,1 the ratio 

of health and safety inspectors per worksite declines,2 and our population centers expand, the risks of 

chemical catastrophes are increasing. 

1 The storage tank on the Elk River that leaked was over 70 years old. A study of chlorine facilities produced 14 years ago noted that 

the majority at that time were over 20 years old and a third were over 55 years old. If those plants are in operation today, they would be 

over 70 years old. Worrell, Phylipsen, Einstein, and Martin, “Energy Use and Energy Intensity of the U.S. Chemical Industry,” April 2000. 

Commissioned by EPA.

2 See Nick Schwellenbach, What’s At Stake: Austerity Budgets Threaten Worker Health and Safety, Center for Effective Government. Aug. 29, 

2013. Available at http://www.foreffectivegov.org/whatsatstake-workersafety. 
6

This report documents the number of schools and schoolchildren within the chemical vulnerability 

zones of 3,429 high-risk chemical facilities operating in the U.S. today. Almost 13,000 facilities must 

report to the Risk Management Program of the U.S. Environmental Protection Agency (EPA) because 

they produce, use, or store large quantities of certain toxic or hazardous chemicals. The facilities report 

their “vulnerability zones” – the areas around each facility that would be affected if a chemical release 

or explosion occurred. While this information must be reported to EPA, information on vulnerability 

zones is not available in a centralized place; data must be collected in person at regional EPA reading 

rooms that have limited hours.3 The facilities are also required to submit an emergency plan for the 

surrounding community should a disaster occur, which is to be shared with emergency personnel in 

those communities.4

Staff at the Center for Effective Government mapped the vulnerability zones of the 3,429 facilities that reported having at least 100,000 people in their vulnerability zones and/or were in one of seven industries.5

We then examined the schools and students that fell within these vulnerability zones.6 (See Appendix I 

for more details on our methodology.) 

3 The vulnerability zone data was gathered through research we participated in in 2013 that resulted in a collaborative report entitled Who’s 

in Danger? Race, Poverty, and Chemical Disasters. Available at http://comingcleaninc.org/whats-new/whos-in-danger-report. 

4 There was some question about whether the first responders who died in West, Texas understood the risk of explosion from the materials 

being stored there.

5 Who’s in Danger? Race, Poverty, and Chemical Disasters.

6 In April 2014, the Center for Effective Government released an analysis and interactive map that examined the proximity of nearly 

100,000 public schools to all 12,728 facilities in the Risk Management Program. We found that nearly one in ten public school students 

attended school within one mile of a facility that had large enough quantities of hazardous chemicals that they reported to EPA’s Risk 

Management Program. This new analysis uses the self-reported vulnerability zones of 3,429 facilities, many of which are much larger than 

one mile. We also included private schools in our analysis, so the students covered rose from 49.4 to 53.6 million. 
7

Figure 1. Nationwide Map of High-Risk Facilities

WHAT DID WE FIND? 

At least one in every three schoolchildren in the U.S. attends a school within the vulnerability zone of a 

hazardous chemical facility (19.6 million of the 53.6 million children enrolled in pre-kindergarten through 

high school). This is 36 percent of all schoolchildren in the country. That’s a shocking number. 

Risk Broadly Dispersed and Concentrated in Some Areas

The risks from these facilities are widely dispersed across the country. In only two states – Vermont 

and Alaska – are no schools inside a known vulnerability zone for a facility. The states with the largest 

number of students in vulnerability zones are also the states with the largest number of residents overall. 

Half the children found in vulnerability zones are in the five most populous states – California, Texas, 

Florida, Illinois, and New York.
8

Table 1: Top Five States for Number of Schools and Students in Vulnerability Zones

State Number of Schools in 

Vulnerability Zones

Number of Students in 

Vulnerability Zones

Percentage 

of Students in 

Vulnerability Zones

California 5,727 3,317,846 49%

Texas 5,658 3,206,006 61%

Florida 2,908 1,495,051 51%

Illinois 2,466 1,084,352 47%

New York 2,210 1,027,864 33%

But a larger proportion of children in several less populated states are at risk than in these larger states. 

Sixty percent or more of all the students in the states of Utah, Rhode Island, Texas, Louisiana, and 

Nevada attend schools within a vulnerability zone. 

Table 2: Top Five States for Percentage of Students in Vulnerability Zones

State Number of Schools in 

Vulnerability Zones

Number of Students in 

Vulnerability Zones

Percentage 

of Students in 

Vulnerability Zones

Utah 699 424,701 69%

Rhode Island 311 108,777 67%

Texas 5,658 3,206,006 61%

Louisiana 1,082 502,349 61%

Nevada 426 275,914 60%

Notably, Texas is the only state on both lists: it has the second-highest number of students in vulnerability 

zones, which represents over 60 percent of all students in the state. Texas has more petroleum refining 

facilities, chemical industry plants, wastewater treatment, and water treatment facilities than any other state.

And within states, the risks are concentrated in certain regions because the hazards from chemical 

facilities are local in nature. Our analysis identified 102 counties in 22 states where every student in the 

county attends a school inside at least one vulnerability zone.
9

Figure 2. Counties Where Every Student Goes to School 

in At Least One Vulnerability Zone

Table 3: States Containing Four or More Counties 

with 100% of Students in Vulnerability Zones

State Counties with 100% of Students in Vulnerability Zones

Texas Aransas, Brazos, Burleson, Calhoun, Dallas, Gregg, Howard, Hutchinson, Jefferson, 

Kleberg, Live Oak, Nueces, Orange, Potter, Rockwall, Victoria

Virginia Buena Vista*, Caroline, Charles City, Colonial Heights*, Covington*, Franklin 

City*, Galax*, Harrisonburg*, Hopewell*, Norfolk*, Petersburg*, Portsmouth*, Prince 

George*, Richmond City*, Roanoke City*, Salem*

Kentucky Ballard, Boyd, Carlisle, Carroll, Gallatin, Greenup, Henderson, Hickman, Livingston, 

Lyon, Marshall, McCracken, Trimble

Louisiana Ascension, Calcasieu, East Baton Rouge, East Carroll, East Feliciana, Iberville, 

Jefferson, Orleans, St. Bernard, St. Charles, St. James, St. John the Baptist, West 

Baton Rouge

Tennessee Benton, Bradley, Davidson, McMinn, Meigs, Shelby

Indiana Dearborn, LaPorte, Ohio, Switzerland, Vigo

Georgia Glynn, Liberty, McIntosh, Richmond

Illinois Crawford, Grundy, Massac, Putnam

Mississippi DeSoto, Hancock, Noxubee, Perry

*Indicates an independent city that acts as a county.
10

Complete coverage of all schools within a county can be the result of a single facility with a large vulnerability zone that covers a large area or a cluster of dangerous facilities. Both of these factors are at play in 

Texas, where in 16 counties, all the students are in vulnerability zones. For instance, in Aransas County, 

two facilities in a neighboring county with 25-mile vulnerability zones encompass all of Aransas’ seven 

schools. In Jefferson County, the sheer number of nearby facilities – 35 within the county itself – is a 

major factor that contributes to all schools being at risk.

Virginia also has 16 counties in which all the schools fall into vulnerability zones, but some of these are 

actually independent cities that act as counties and have smaller overall acreage than counties in other 

states. The state also has a significant number of chemical industry and water and wastewater treatment 

plants. Kentucky and Louisiana each have 13 counties where every student is at risk. Kentucky has a 

handful of facilities with large vulnerability zones. For example, virtually all of Henderson County falls 

within the 25-mile vulnerability zone of Brenntag Mid-South, Inc., a bleach manufacturing facility. The 

large number of parishes in Louisiana in which all the children are in vulnerability zones is the result of 

the chemical industry.

Figure 3. Distribution of Vulnerability Zone Sizes
11

Many but not all of these counties are part of metro areas within states. In some places, the risks explode 

with the concentration of population. Urban schoolchildren in Texas, Louisiana, and Tennessee are in 

multiple vulnerability zones.

Table 4. Number of Schools and Students in Multiple Vulnerability Zones

Number of 

Vulnerability Zones

Number of Schools 

in this Range

Number of Students 

in this Range

30-41 70 47,218

20-29 358 215,243

10-19 602 301,754

2-9 19,302 9,814,835

The greater Houston area is the worst example: more than 270 of its schools are in multiple vulnerability 

zones. San Jacinto Elementary in Deer Park, Texas, sits in 41 different vulnerability zones. In Baton 

Rouge, Louisiana, some schools are in 22 different vulnerability zones. The facility with the largest 

vulnerability zone in our data is located in Baton Rouge – Honeywell International Inc. Baton Rouge 

Plant has a vulnerability zone with a 40-mile wide radius encompassing 283 schools. The Beaumont-Port 

Arthur, Texas metropolitan area contains schools that sit in 15 different overlapping vulnerability zones. 

Many schools sit right beside facilities with wide vulnerability zones.
12

Figure 4. Vulnerability Zones in Houston, Texas

The 880 schools situated in the most vulnerability zones are all located in Texas and Louisiana. But 

Memphis, Tennessee and Wilmington, Delaware also have schools situated in as many as 10 different 

vulnerability zones.

The Riskiest Facilities

The level of risk associated with a particular chemical facility has to do with the quantity of chemicals 

being handled, how dangerous those chemicals are, and the proximity of the facility to population 

centers. Several of the facilities in our data have hundreds of thousands of students in their vulnerability 

zones because they are large, handle very toxic chemicals, and are near large population centers.
13

Table 5: Facilities Putting over 500,000 Students at Risk

Facility Name City and State

Number of 

Students in 

Facility’s 

Vulnerability 

Zone

Number of 

Schools in 

Facility’s 

Vulnerability 

Zone

Chemical in 

Facility’s RMP

Kuehne Chemical Co., 

Inc. South Kearny, NJ 861,639 1,887 Chlorine

Central Regional 

Wastewater System Grand Prairie, TX 766,761 1,265 Sulfur dioxide (anhydrous)

Solvay USA Inc., 

Houston Plant Houston, TX 714,446 1,167 Oleum (fuming sulfuric acid)

KIK SoCal Inc. Santa Fe Springs, 

CA 679,002 1,118 Chlorine

JCI Jones Chemicals 

Inc. - Torrance Torrance, CA 625,832 1,071 Sulfur dioxide (anhydrous)

PVS Chemical 

Solutions, Inc. Chicago, IL 611,745 1,347 Sulfur dioxide (anhydrous)

Agrifos Fertilizer L.L.C. Pasadena, TX 605,554 1,004 Ammonia (anhydrous)

Thorofare Plant West Deptford, NJ 546,854 1,283 Hydrofluoric acid 

(conc >50%)

Houston Ammonia 

Terminal, L.P. Pasadena, TX 539,602 903 Ammonia (anhydrous)

GATX - Colton, CA 

Tank Car Facility Colton, CA 511,089 722 Bromine

See Appendix IV for a longer list of top facilities.

Table 5 lists the ten facilities with the most students inside their vulnerability zones. Seven of the ten 

facilities on the list are in California and Texas, but New Jersey houses the facility that places the most 

students and schools at risk because it is in the New York City metro area.

The Kuehne Chemical Company7 in South Kearny, New Jersey has a 14-mile vulnerability zone with 

1,887 schools and 861,639 students situated within it. The facility’s vulnerability zone encompasses nearly 

all of Manhattan, as well as all of Jersey City and Newark. The company holds up to 2 million pounds of 

chlorine gas for use in manufacturing bleach. Chlorine gas is heavier than air, and if leaked spreads close 

to the ground and can be carried by wind. Contact with chlorine gas produces the same effects as when it 

was used as a chemical weapon in World War I: burning of skin and eyes, respiratory damage, and even 

death.

7 To research a facility’s enforcement record with EPA or OSHA to see if they have been cited for health and safety violations, visit http://

echo.epa.gov/ and http://ogesdw.dol.gov/. You can also use the Corporate Research Project to find information on the corporate owners of 

particular facilities, available online at http://www.corp-research.org/. 
14

Central Regional Wastewater System in Grand Prairie, Texas (a city between Dallas and Fort Worth) 

puts the second-largest number of students at risk, with a vulnerability zone stretching 25 miles. It stores 

360,000 pounds of sulfur dioxide for use in wastewater treatment, along with other chemicals such as 

chlorine gas. Sulfur dioxide is colorless and can travel far when leaked. Immediate exposure irritates skin 

and eyes, damages lungs, and can prove fatal. The fifth and sixth facilities on the list are both chemical 

manufacturers that also list sulfur dioxide as their most dangerous chemical. JCI Jones Chemicals 

Inc. in Torrance, California stores up to 180,000 pounds of sulfur dioxide at any given time and has a 

vulnerability zone of 16 miles. PVS Chemical Solutions, Inc. in Chicago, Illinois stores 1.5 million pounds 

of sulfur dioxide and has a 25-mile vulnerability zone.

The facility putting the third-most students at risk is Solvay USA Inc.’s Houston plant, a chemical 

manufacturing facility. It stores over 41 million pounds of toxic chemicals and has a vulnerability zone 

stretching 25 miles. Solva’s most risky chemical is oleum, which is created by dissolving sulfur trioxide 

gas in sulfuric acid. If exposed to air, it can create a sulfuric acid cloud. Oleum is highly reactive and can 

form flammable or explosive hydrogen gas when exposed to certain metals. The chemical burns skin, 

eyes, and lungs on contact.

The seventh and ninth facilities on the list, both in Pasadena, Texas, list anhydrous ammonia as their 

most dangerous chemical. Agrifos Fertilizer L.L.C. uses ammonia to produce fertilizer, with up to 13.5 

million pounds of it onsite at a time. Houston Ammonia Terminal, L.P. is a chemical storage facility 

that holds up to 60 million pounds of anhydrous ammonia. Both have vulnerability zones of 25 miles. 

Anhydrous ammonia is a gas that is harmful even in small amounts. Low exposures can burn eyes and 

lungs, and higher exposures can cause blindness and death.

Eighth on the list is Thorofare Plant in West Deptford, New Jersey, which also has a 25-mile vulnerability 

zone. Thorofare manufactures chemicals and has 1.4 million pounds of hydrofluoric acid in compressed 

gas form. Hydrofluoric acid is used to make a variety of products, including refrigerants, plastics, and 

pharmaceuticals. Exposure to the gas burns eyes and lungs and can be fatal by causing fluid buildup in 

the lungs.

Tenth on the list is GATX Tank Car Facility in Colton, California, which cleans railcars that transport 

chemicals. Its most hazardous onsite chemical is bromine, which is used to help vent railcars with toxic 

or flammable chemicals. Bromine is a fuming liquid that can damage lungs, skin, and eyes and cause 

serious long-term effects. It is not flammable but can cause combustible materials to burn faster. GATX 

stores 210,000 pounds of bromine and has a vulnerability zone of 25 miles.
15

The Chemicals that Create Risk, Less Dangerous Alternatives

Our research focused on facilities in seven major industry sectors. Combined, the industry sectors below 

are estimated to put more than 134 million people at risk.8 (See Appendix V for an industry breakdown 

of populations at risk.) While facilities in these industries use a variety of chemicals, there were some 

strong trends in the main chemicals listed as responsible for the vulnerability zones. Table 6 examines 

those industry sectors and names the chemical most often listed as the cause of the vulnerability zone for 

each.9

Table 6: Chemicals Most Often Listed in Risk Management Plans, by Industry10

Industry Chemical Percentage of Facilities 

Listing this Chemical

Bleach Manufacturing Chlorine 77%

Water Treatment Chlorine 86%

Wastewater Treatment Chlorine 99%

Chemical Manufacturing Chlorine 13%

Pulp and Paper Manufacturing Chlorine dioxide 76%

Petroleum Refining Hydrofluoric acid (conc >50%) 38%

Electrical Power Generation Ammonia (anhydrous) 60%

Chlorine was the most common chemical listed as the cause of these vulnerability zones. In three of 

the industry sectors, chlorine was the main cause by far, being used or stored at 77 to 99 percent of 

the facilities. Chlorine is prevalent in wastewater and water treatment facilities, where it is used as a 

disinfectant, and is heavily used in bleach manufacturing.

Fortunately, several cost-effective alternatives to chlorine gas exist for wastewater and water treatment. 

Sodium hypochlorite is like a stronger version of bleach used to clean homes. As a liquid, it does not have 

the same release risks as chlorine gas but still maintains its disinfecting properties. Another alternative 

is ultraviolet light, which kills bacteria without the use of chemicals. A recent study found that 554 

water and wastewater treatment plants have already switched to various safer alternatives and estimated 

that those changes eliminated chemical risks for more than 40 million people.11 But thousands of other 

facilities continue to use chlorine gas.

8 Who’s in Danger? Race, Poverty, and Chemical Disasters.

9 To calculate the number of students and schools each chemical puts at risk would require a separate GIS analysis for each chemical.

10 There are 128 facilities in our analysis that do not fit into any of these industry sectors. 

11 Reece Rushing and Paul Orum, “Leading Water Utilities Secure Their Hazards,” Center for American Progress, March 2010. Available at 

http://www.americanprogress.org/issues/security/news/2010/03/02/7538/leading-water-utilities-secure-their-chemicals/. 
16

Bleach manufacturing companies can also replace chlorine gas with sodium hypochlorite. In 2009, the 

Clorox Company began switching from chlorine gas to sodium hypochlorite in all of its facilities. This 

decision removed the risk to over 13 million Americans12 and demonstrated that switching to safer 

chemical processes is feasible and can be profitable. Other bleach manufacturers have begun producing 

chlorine bleach as needed from salt and electricity, eliminating the need for storage of large quantities of 

the dangerous chemical.

In fact, industry alternatives exist for all the major chemicals listed above.

•	 Pulp and paper manufacturers generally use chlorine dioxide as a bleaching agent. When the 

chemical is exposed to sunlight, it breaks down into oxygen and chlorine gas. Chlorine-free 

chemicals, such as hydrogen peroxide and ozone, can be used as bleaching agents with fewer 

risks. 

•	 Electrical power generators use anhydrous ammonia in pollution reduction systems. Safer 

alternatives include an aqueous solution (anhydrous ammonia dissolved in water) or solid urea, 

which is mixed onsite. Power plants that use anhydrous ammonia average vulnerability zones 

close to 3.5 miles, while those using aqueous solutions average vulnerability zones under half a 

mile.13

•	 Petroleum refineries that use hydrofluoric acid as a catalyst can switch to processes that use 

sulfuric acid, which isn’t even covered by RMP because of its low airborne release risk. Refineries 

can also use solid acid and liquid ionic catalysts, which significantly reduce risks to surrounding 

communities.

12 Greenpeace. Available at http://www.greenpeace.org/usa/en/media-center/news-releases/clorox-to-eliminate-chlorine-d/. 

13 Who’s in Danger: Race, Poverty, and Chemical Disasters.
17

HOW WE CAN MAKE OUR CHILDREN SAFER

We have had strong rules to ensure air and water quality for a generation, but we have failed to establish 

similar protections to reduce the risk of chemical accidents. Facilities that generate toxins in their 

production processes have legal limits on the amounts they can emit and are required to install the best 

available anti-pollution technologies in order to reduce potential exposure and harm to the public. The 

risk chemical facilities pose is just as real a danger and should be similarly regulated.

Fortunately, companies, legislatures, and agencies can take steps to reduce the size of vulnerability zones 

and ensure that children and schools are beyond their boundaries.

The most effective way to protect our children from chemical disasters is to require companies to use 

safer alternatives whenever possible. We have a rare opportunity at the federal level to establish new 

rules requiring companies to shift to the safer chemical alternatives that are available. In the wake of the 

West, Texas disaster, the president issued an executive order for EPA, the Occupational Safety and Health 

Administration (OSHA), and the Department of Homeland Security (DHS) to review, upgrade, and 

coordinate their policies covering chemical facilities.

Over half of the facilities putting students at risk are wastewater or water treatment facilities, with most 

using chlorine gas as a disinfectant. Clean water is vital to human health and can be achieved by using 

safer alternatives like liquid chlorine, ozone, or UV radiation. Indeed, water treatment facilities across 

the country have been voluntarily choosing to reduce potential harm by shifting to safer chemicals and 

technologies. A recent study found that 554 water and wastewater treatment plants have switched to 

various safer alternatives and estimated that those changes eliminated chemical risks for more than 40 

million people.14

Yet thousands of facilities continue to employ highly dangerous chemicals. Instead of this piecemeal 

approach to safety and the current federal approach focused on risk management, we need to move to a 

mandatory prevention-based approach. Facilities and companies should be required to show that they 

understand the risks their current chemical production and storage poses to nearby schools and students. 

They should demonstrate that they know of and have plans to shift to less hazardous chemicals and 

industrial production processes where feasible. If they won’t switch, they should explain why and lay out 

another plan for mitigating risks to the community.

14 Reece Rushing and Paul Orum, “Leading Water Utilities Secure Their Hazards,” Center for American Progress, March 2010. http://www.

americanprogress.org/issues/security/news/2010/03/02/7538/leading-water-utilities-secure-their-chemicals/.
18

Though EPA is driving potential policy changes in the Risk Management Program, other agencies, 

including OSHA and DHS, need to incorporate any safer alternatives requirements into their programs 

and rules, as well.

Facilities can and should shrink their vulnerability zones by limiting the amount of hazardous 

chemicals they store or produce onsite – especially when they operate near schools or urban areas. 

Even when dangerous chemicals cannot be replaced, facilities can significantly reduce their vulnerability 

zones by reducing the quantities of chemicals stored onsite. Bringing chemicals to these facilities in realtime, with the expectation that they will use them shortly after delivery, reduces the need to store large 

amounts of hazardous chemicals onsite for significant periods of time. This incredibly simple but effective 

step can greatly limit risks to nearby communities.15

Similarly, facilities sometimes have the option to store a chemical in a way that reduces its toxicity or 

volatility. For instance, some chemicals can be mixed with other chemicals or materials to make them 

more stable and less dangerous. Then the facility can use a process onsite to extract the hazardous 

material only when it is needed. This means there are never large amounts of the toxic chemical on hand, 

again dramatically shrinking vulnerability zones and protecting neighboring schools, students, and 

communities.

Finally, new high-risk facilities should not be built near large urban areas or probable growth areas 

around cities. Some of the most hazardous facilities have been in place for years as communities around 

them have grown. But there is no excuse for new high-risk facilities to be located so dangerously close to 

major population centers. If companies cannot commit to using the safest chemicals and technologies, 

then their facilities need to be located as far from population centers as possible. New facilities should 

also come with buffer zones that prevent residential development or school construction near the facility. 

Changing the way hazardous facilities are sited may require changes to zoning laws. In most states, 

changes to zoning laws are made on the local level through city or town councils, planning boards, 

zoning boards, or other official bodies. Local officials should take into account the high level of risk these 

facilities pose to children, schools, and local areas when making zoning decisions. They should require 

chemical facilities to directly communicate risks to county executives, mayors, local emergency response 

agencies, hospitals, school administrators, and local residents, including the disclosure of all hazardous 

chemicals onsite at the facilities and emergency response plans.

15 “Cleaning Up With Rent-a-Chemical: Lease programs are emerging as a safer, more environmentally friendly way to manage chemicals,” 

Elizabeth Grossman, Ensia, Sept. 15, 2014. http://ensia.com/features/cleaning-up-with-rent-a-chemical/. 
19

How you can act now to help protect all American schoolchildren from chemical disasters

The Obama administration is in the midst of exploring new rules to govern the handling and safety of 

hazardous chemicals. EPA has the authority to make safer chemicals a requirement for facilities reporting 

to its Risk Management Program. As EPA considers revisions to the program, concerned parents, 

teachers, school administrators, organizations, and others have the opportunity to tell the agency that 

requiring safer chemicals is the best way to safeguard our schools and communities. EPA is accepting 

comments until Oct. 29. Write to EPA and ask the agency to protect our children by requiring 

facilities to switch to safer chemicals.

How you can reduce the vulnerability of schoolchildren in your community 

National policy changes could mean a tremendous reduction of risk for thousands of schools across 

the country. But even if policymakers have the courage to act, it will take some time before any new 

requirements are in place that result in changes at local facilities. While parents, teachers, local officials, 

and others should weigh in on the national policy debate, they need not wait for those results. Action can 

be taken at the local level, and you can take part through the following:

Learn about risks in your community and share this information with other community members, as 

well as local and state leaders.

•	 Share this report and the interactive map with your friends, relatives, and neighbors so they 

can see the risks to their own schools and communities.

•	 Talk to your PTA or PTO – encourage teachers to use our curriculum to explore the issue of 

chemical risk and ways everyday citizens can make their communities safer. 

•	 Write a letter to the editor of your local paper. 

Advocate for policy changes on the local, state, and federal levels. 

•	 Ask your city council representative to pass a resolution supporting the shift to safer chemical 

alternatives. 

•	 Ask your state representatives to require the use of safer chemicals at facilities located near you.

•	 Contact your state’s environmental agency and ask staff to hold a hearing and/or to send a 

comment to the federal EPA about reducing risks in your community.

•	 Tell Congress to support new requirements to shift to safer chemical alternatives.

•	 Register to vote and encourage candidates to support improved safety and better protections 

for children.
20

Put pressure on local facilities to voluntarily switch to safer chemical alternatives.

•	 The interactive risk map allows you to find the name of the facility at the center of each 

vulnerability zone, its address, and the amount of chemicals it stores. This should give you 

enough information to contact the facility and arrange a meeting. You can also use the 

information to launch a local letter-writing campaign and/or encourage a local reporter to 

investigate this issue. You can look up each facility’s enforcement record with EPA or OSHA

to see if they have been cited for health and safety violations. Additionally, the Corporate 

Research Project may provide useful information on the corporate owners of particular 

facilities.

Share this information with local school officials and insist they have an emergency plan in place.

•	 Each facility in this report is required to have a Risk Management Plan on record with the 

first responders and emergency management officials in your community. Ask your local first 

responders to come to the schools in your area and conduct a drill or to talk to your PTA/

PTO and explain emergency procedures so everyone knows the plan in the event of a disaster. 

Eastern Kentucky University has produced a guide for developing an emergency action plan 

for schools that includes a wide variety of emergencies, including hazardous material releases.

Public pressure can push companies and policymakers to make better choices. Tell them that the safety of 

the children in your community requires their action. 
21

APPENDIX I: METHODOLOGY 

The data on chemical facilities in this analysis comes from the U.S. Environmental Protection Agency’s 

(EPA) Risk Management Program. The program requires facilities that produce, handle, process, 

distribute, or store large amounts of certain toxic or flammable chemicals to submit a risk management 

plan (RMP) that includes a vulnerability zone analysis.

The vulnerability zone is a circular area around the facility that indicates the area that could be affected 

by a chemical release or explosion of the facility’s largest single container (and interconnected piping) of 

certain extremely hazardous substances. The size of the zone depends on the quantity and characteristics 

of the chemical. EPA defines the general methods that facilities must use in determining vulnerability 

zone size or distance (radius), and then companies use modeling programs to determine and report their 

facilities’ vulnerability zones.

All people living or working within vulnerability zones are at risk of serious harm, but actual impacts of a 

release would vary due to weather, wind direction, distance from the facility, and other factors.

Most of the RMP data was obtained through a Freedom of Information Act request to EPA and is current 

as of Dec. 27, 2013. However, the vulnerability zone information is limited and available only through 

designated federal reading rooms. The RMP data on the 3,429 facilities was gathered in standardized 

notes made through multiple visits to federal reading rooms within the last five years.

Given the restricted access, research on vulnerability zones was prioritized to address the facilities that 

placed the most people at risk and for key industry sectors. The vulnerability information was collected 

for the following types of facilities:

1. Facilities that self-reported in their RMP having 100,000 or more people living within their 

vulnerability zones, regardless of industry sector.

2. Facilities that belong to the following seven industry sectors: potable water treatment, wastewater 

treatment, commercial bleach manufacturing, electric power production, petroleum refining, 

pulp and paper production, and chemical manufacturing.16

16 The chemical category includes facilities belonging to either the American Chemistry Council (ACC) or the Society of Chemical 

Manufacturers and Affiliates (SOCMA). 
22

The facilities’ self-reported latitude-longitude data was used to establish facility locations and map 

them using Geographic Information System (GIS) software (ESRI ArcGIS Desktop Advanced 10.2). 

We corrected location data only for nine facilities that had obviously inaccurate geographic coordinates 

that placed the facilities in the ocean. Otherwise, the latitude-longitude location data as reported by the 

facilities was relied upon and was not changed.

The school data in this analysis is from the U.S. Department of Education, Institute of Education 

Sciences, National Center for Education Statistics (NCES). The private school data is specifically from 

the Private School Universe Survey (PSS) for the 2011-12 school year. The public school data is from the 

Common Core of Data (CCD) for the same time period.

The CCD is an official list of public elementary and secondary schools in the United States. The data is 

collected annually and is considered to be a comprehensive statistical database of these schools. The PSS 

is also an annual survey of schools, but the schools are private (i.e. public funding is not their primary 

means of support) and must meet certain criteria to be considered. Home school organizations that don’t 

offer classroom teaching are not included.

Schools from each data set were included only if they were operational for the 2011-12 school year as 

determined by the NCES. Each of the data sets contains information including numbers of students 

attending the school and the latitude and longitude of the school. The latitude and longitude data was 

used to map school locations using Geographic Information System (GIS) software (ESRI ArcGIS 

Desktop Advanced 10.2). We spot-checked all schools cited in this report and our state fact sheets and 

moved a few that were incorrectly located. No other school locations were corrected or changed from the 

latitude and longitude data provided. We also kept all schools on the map, even if they have closed since 

the 2011-12 survey was conducted.

Previous Analysis

In an April 2014 analysis, we found that nearly 10,000 public schools are located within one mile of the 

almost 13,000 chemical facilities that report to EPA’s Risk Management Program. Based on the data we 

used in that analysis, 4.6 million students, or one in ten, were found to be at risk.

This new analysis is more extensive. Most importantly, we were able to use the self-reported vulnerability 

zones for 3,429 RMP facilities. These zones are a more accurate measure of the risk being generated by 
23

each facility than the simple, universal one-mile buffer we originally used. Also, many of the vulnerability 

zones are significantly larger than our original one-mile buffer. This restricts the new analysis to a 

fraction of the RMP facilities, but the research specifically focused on finding the zones that put the most 

people at risk and those for industry sectors with some of the widest spread across states.

Additionally, we were able to expand the universe of schools impacted. Our original analysis only 

included 98,524 public schools with 49.4 million students in kindergarten through 12th grade that we 

were sure were open and had students. For this new analysis, we included private schools and were able 

to better identify open public schools, for a total of 122,968 schools with 53.6 million students.

NOTE: The information on chemical risk is only available because federal law requires local facilities to 

develop emergency response plans, and open government rules require that these plans be made public. 

The Center for Effective Government has fought to protect and extend transparency rules for the last 25 

years. Though this information is technically publicly available, one has to physically visit a regional EPA 

reading room to access it. EPA should make vital information like this more accessible to everyone.
24

APPENDIX II: TABLE A – NUMBER OF 

STUDENTS IN VULNERABILITY ZONES, BY 

STATE

Rank State

Totel Number 

of Schools in 

Vulnerability Zones

Total Number 

of Students in 

Vulnerability Zones

1 California 5,727 3,317,846

2 Texas 5,658 3,206,006

3 Florida 2,908 1,495,051

4 Illinois 2,466 1,084,352

5 New York 2,210 1,027,864

6 Pennsylvania 1,741 744,199

7 New Jersey 1,492 648,641

8 Ohio 1,364 608,038

9 Tennessee 1,020 510,215

10 Louisiana 1,082 502,349

11 Indiana 889 440,675

12 Utah 699 424,701

13 Michigan 940 382,506

14 Minnesota 890 337,171

15 Arizona 609 336,469

16 Virginia 627 321,394

17 Georgia 545 306,555

18 Kentucky 659 294,892

19 Nevada 426 275,914

20 North Carolina 524 273,072

21 Missouri 681 269,449

22 South Carolina 507 256,144

23 Oklahoma 529 244,346

24 Washington 542 240,194

25 Alabama 467 214,791

26 Kansas 475 202,439

27 Maryland 432 178,200

28 Mississippi 305 155,439

29 Iowa 258 114,198

30 Nebraska 251 111,657
25

31 Oregon 279 110,724

32 Rhode Island 311 108,777

33 Wisconsin 313 107,169

34 Arkansas 246 106,360

35 New Mexico 248 106,302

36 West Virginia 260 97,366

37 Massachusetts 208 91,138

38 Delaware 196 87,471

39 Connecticut 202 77,611

40 New Hampshire 178 67,353

41 Colorado 106 51,117

42 Montana 88 33,254

43 North Dakota 67 27,211

44 Wyoming 53 17,564

45 Maine 72 13,477

46 Hawaii 17 11,370

47 Idaho 24 6,354

48 South Dakota 4 337

Note: Alaska and Vermont do not appear as neither have schools located in the vulnerability zones included in this study.
26

APPENDIX III: TABLE B – PERCENTAGE OF 

STUDENTS IN VULNERABILITY ZONES, BY 

STATE

Rank State

Percentage 

of Students in 

Vulnerability 

Zones

Number of 

Students in 

Vulnerability 

Zones

Total Number of 

Students in State

1 Utah 69% 424,701 614,495

2 Rhode Island 67% 108,777 162,402

3 Texas 61% 3,206,006 5,216,401

4 Louisiana 61% 502,349 818,310

5 Nevada 60% 275,914 458,147

6 Delaware 58% 87,471 150,634

7 Florida 51% 1,495,051 2,938,440

8 California 49% 3,317,846 6,714,357

9 Tennessee 48% 510,215 1,068,085

10 Illinois 47% 1,084,352 2,297,389

11 New Jersey 43% 648,641 1,517,873

12 Kentucky 40% 294,892 738,455

13 Kansas 39% 202,439 518,933

14 Indiana 39% 440,675 1,132,036

15 Pennsylvania 37% 744,199 1,992,009

16 Minnesota 37% 337,171 915,420

17 Oklahoma 35% 244,346 691,688

18 Nebraska 33% 111,657 334,625

19 South Carolina 33% 256,144 770,749

20 New York 33% 1,027,864 3,093,860

21 West Virginia 33% 97,366 294,304

22 New Hampshire 32% 67,353 210,613

23 Ohio 31% 608,038 1,931,220

24 Arizona 30% 336,469 1,121,001

25 New Mexico 30% 106,302 354,390

26 Mississippi 29% 155,439 531,578

27 Alabama 27% 214,791 793,595

28 Missouri 27% 269,449 1,014,842

29 North Dakota 26% 27,211 103,394

30 Virginia 24% 321,394 1,350,514

31 Michigan 23% 382,506 1,654,001
27

32 Montana 22% 33,254 149,813

33 Iowa 22% 114,198 522,595

34 Washington 21% 240,194 1,118,793

35 Arkansas 21% 106,360 504,956

36 Wyoming 19% 17,564 91,644

37 Oregon 19% 110,724 594,672

38 Maryland 18% 178,200 974,386

39 North Carolina 17% 273,072 1,589,707

40 Georgia 17% 306,555 1,801,894

41 Connecticut 13% 77,611 614,648

42 Wisconsin 11% 107,169 981,931

43 Massachusetts 9% 91,138 1,063,641

44 Maine 7% 13,477 195,113

45 Colorado 6% 51,117 897,742

46 Hawaii 5% 11,370 214,371

47 Idaho 2% 6,354 289,661

48 South Dakota 0.2% 337 136,896

Note: Alaska and Vermont do not appear as neither have schools located in the vulnerability zones included in this study. 
28

APPENDIX IV: TABLE C – FACILITIES THAT 

PUT 200,000 OR MORE STUDENTS AT RISK

Rank Facility Name City, State

Number of 

Students in 

Facility’s 

Vulnerability 

Zone

Number of 

Schools in 

Facility’s 

Vulnerability 

Zone

Chemical in 

Facility’s RPM

1 Kuehne Chemical Co., 

Inc. South Kearny, NJ 861,639 1,887 Chlorine

2 Central Regional 

Wastewater System Grand Prairie, TX 766,761 1,265 Sulfur dioxide (anhydrous)

3 Solvay USA Inc., 

Houston Plant Houston, TX 714,446 1,167 Oleum (fuming sulfuric acid)

4 KIK SoCal Inc. Santa Fe Springs, 

CA 679,002 1,118 Chlorine

5 JCI Jones Chemicals 

Inc. - Torrance Torrance, CA 625,832 1,071 Sulfur dioxide (anhydrous)

6 PVS Chemical 

Solutions, Inc. Chicago, IL 611,745 1,347 Sulfur dioxide (anhydrous)

7 Agrifos Fertilizer L.L.C. Pasadena, TX 605,554 1,004 Ammonia 

(anhydrous)

8 Thorofare Plant West Deptford, NJ 546,854 1,283 Hydrofluoric acid 

(conc >50%)

9 Houston Ammonia 

Terminal, L.P. Pasadena, TX 539,602 903 Ammonia (anhydrous)

10 GATX - Colton, CA 

Tank Car Facility Colton, CA 511,089 722 Bromine

11

Village Creek 

Wastewater Treatment 

Plant

Arlington, TX 496,858 826 Sulfur dioxide 

(anhydrous)

12 AMVAC Chemical 

Corporation Los Angeles, CA 490,614 850 Chlorine

13

Occidental Chemical 

Corp. - Deer Park VCM 

Plant

Deer Park, TX 478,283 799

Hydrogen 

chloride 

(anhydrous)

14 NTMWD Wylie Water 

Treatment Plant Wylie, TX 452,542 728 Chlorine

15 Chemical Unloading 

Facility Perris, CA 449,158 629 Chlorine

16 Baker Petrolite 

Corporation - Bayport Pasadena, TX 444,064 746 Formaldehyde (solution)

17 Eastside Water 

Treatment Plant Sunnyvale, TX 436,049 761 Chlorine

18

Occidental Chemical 

Corp. - BG Chlor-AlkaliVCMLa Porte, TX 435,017 721 Chlorine
29

19 Delta Deer Park Deer Park, TX 384,887 633 Toluene 

2,6-diisocyanate

20 Kaneka Texas 

Corporation Pasadena, TX 382,367 658 Chlorine

21 Clean Harbors Deer 

Park, LP La Porte, TX 373,829 606 Chloromethyl methyl ether

22

Champion 

Technologies' Fresno 

Facility

Fresno, TX 366,033 612 Formaldehyde 

(solution)

23

Infineum USA L.P. 

Bayway Chemical 

Plant

Linden, NJ 361,551 765 Chlorine

24 Paulsboro Refining 

Company LLC Paulsboro, NJ 360,230 869 Hydrofluoric acid (conc >50%)

25 KIK (Houston) Inc. Houston, TX 350,651 642 Chlorine

26 INVISTA Intermediates 

LaPorte Plant LaPorte, TX 350,610 583 Formaldehyde (solution)

27 La Porte Plant La Porte, TX 349,660 580 Hydrofluoric acid 

(conc >50%)

28 PDV Midwest Refining, 

LLC Lemont, IL 348,402 702 Hydrofluoric acid (conc >50%)

29 Allied Universal 

Corporation Miami, FL 332,125 631 Chlorine

30 Sentry Industries, Inc. Miami, FL 324,734 646 Chlorine

31

Pioneer Americas 

LLCd/b/a Olin Chlor 

Alkali Product

Santa Fe Springs, 

CA 320,838 504 Chlorine

32 DPC Enterprises, L.P. Glendale, AZ 313,536 554 Chlorine

33

Hill Brothers Chemical 

Co. - Phoenix Facility 

2006

Phoenix, AZ 305,423 546 Chlorine

34 Clear Lake Plant Pasadena, TX 294,699 459 Ethylene oxide

35 Petra Chemical 

Company Dallas, TX 290,165 531 Chlorine

36 Arkema Inc. - Houston 

Plant Houston, TX 287,332 478 Hydrogen sulfide

37 KIK Pool Additives, Inc. Ontario, CA 282,413 392 Chlorine

38 Central Wastewater 

Treatment Plant Dallas, TX 271,542 490 Chlorine

39 Saint Paul Park 

Refining Company LLC St. Paul Park, MN 270,386 702 Hydrofluoric acid (conc >50%)

40 Alexander Orr Water 

Treatment Plant Miami, FL 260,132 512 Chlorine

41 DXI Industries, Inc. Houston, TX 257,751 424 Sulfur dioxide 

(anhydrous)

42 Argo Terminal Argo, IL 257,737 527 Vinyl acetate 

monomer

43 Tarrant County Water 

Supply Project Euless, TX 248,104 381 Chlorine
30

44 East Water Purification 

Plant Houston, TX 247,896 429 Chlorine

45 Equistar Chemicals L.P. 

- Bayport Underwood Pasadena, TX 247,178 368 Ethylene oxide

46 Southside WWTP Dallas, TX 241,938 424 Sulfur dioxide 

(anhydrous)

47 Elm Fork Water 

Treatment Plant Carrollton, TX 240,774 405 Chlorine

48 Trainer Refinery Trainer, PA 234,270 552 Hydrofluoric acid 

(conc >50%)

49 Houston Plant Pasadena, TX 226,847 376 Chlorine

50 Brenntag Southwest - 

Greens Bayou Houston, TX 224,067 375 Chlorine

51 Fiveash Water 

Treatment Plant

Fort Lauderdale, 

FL 223,552 390 Chlorine

52 John E. Preston Water 

Treatment Plant Hialeah, FL 222,708 459 Chlorine

53 General Chemical Bay 

Point Works Pittsburg, CA 221,863 445 Hydrofluoric acid (conc >50%)

54

GB Biosciences 

Corporation/Greens 

Bayou Plant

Houston, TX 217,635 363 Chlorine

56 Pennakem, LLC Memphis, TN 213,124 393 Furan

57 Velsicol Chemical LLC 

(Memphis) Memphis, TN 212,699 394 Chlorine

58

Pioneer Americas LLC 

dba Olin Chlor Alkali 

Product

Henderson, NV 209,975 288 Chlorine

59 Helm Fertilizer 

Terminal, Inc. Memphis, TN 202,246 385 Ammonia (anhydrous)
31

APPENDIX V: NUMBER OF RMP FACILITIES 

AND VULNERABILITY ZONE POPULATIONS 

IN THIS REPORT BY INDUSTRY SECTOR*

Industry Sector RMP Facilities** Vulnerability Zone 

Population***

Water treatment 1,284 33,692,612

Wastewater treatment 686 21,004,374

Bleach manufacturing 91 63,952,735

Electric power generation 334 4,052,030

Petroleum refining 130 18,484,212

Pulp and paper production 72 5,462,950

Chemical manufacturing  778 79,726,744

Total for all sectors 3,433** *** 134,932,009

Note: Because of overlapping vulnerability zones, figures in the final column are not cumulative.

* This table is reproduced from “Who’s in Danger: Race, Poverty, and Chemical Disasters” May 2014, Environmental Justice and 

Health Alliance for Chemical Policy Reform. http://comingcleaninc.org/assets/media/images/Reports/Who%27s%20in%20Danger%20Report%20FINAL.pdf.

** Facilities may be in more than one industry sector and thus do not equal the total for all sectors.

*** Values represent merged overlapping vulnerability zones to eliminate double counting within each industry sector. Because 

facilities may be in more than one sector, the sum of population values does not equal the population total for all sectors.

  Defined as member companies of the American Chemistry Council (ACC) or the Society of Chemical Manufacturers and 

Affiliates (SOCMA).

** *** The number of facilities does not exactly match the number examined for this report, as several facilities had deregistered 

since the May report.
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