Improving Communications Between A Company And Its
Neighbors: A Logical Process And Model
Improving Communications Between A Company And Its Neighbors: A Logical Process And Model
By Robert A. Thomas, Ph.D.
Loyola Chair in Environmental Communications and Director
Center for Environmental Communications
Department of Communications
Loyola University
New Orleans, LA 70118-6195
bthomas@loyno.edu
Don Baker, External Affairs Manager
Shell Chemicals
P. O. Box 10
Norco, LA 70079
dmbaker@shellus.com
Kirk Menard, Manager, Safety, Health, and Environment
Norco Refinery, Motiva Enterprises, LLC
15536 River Road
Norco, LA 70079
am193446@msxsopc.shell.com
TABLE OF CONTENTS
- Forward
- Preface
- Effective Communication with the Community
- Charter Development Assumptions
- Charter
- Motiva/Shell Norco Community-based Research
- Motiva/Shell Norco Chemical Plant: December 8, 1998 Unusual Events
- Findings
- Recommendations
- Work in Progress
- Summary
Overview of EPA's Common Sense Initiative
In November 1993, President Bill Clinton and Environmental Protection Agency (EPA) Administrator Carol Browner announced the creation of the Common Sense Initiative (CSI). The initiative reflects the Administrator's commitment to setting strong environmental standards while encouraging common sense, innovation, and flexibility in how the standards are achieved. The goal of CSI is cleaner and cheaper environmental protection for entire industries, achieved by modifying existing environmental regulations and policies. The approach is tailored to specific concerns within an industry sector, rather than a "one-size-fits-all" approach to environmental regulation. The objective in establishing the CSI is to bring together representatives from other Federal agencies, State and local government, environmental organizations, environmental justice organizations, industry, labor, communities, and other stakeholders to look at the full range of environmental requirements affecting industry. The six industries chosen to participate in this initiative were:
- Auto Manufacturing
- Computers and Electronics
- Iron and Steel
- Metal Finishing
- Petroleum Refining
- Printing
Petroleum Refining Sector
The NACEPT Petroleum Refining Sector Subcommittee has made significant accomplishments over the past several years, largely through the collaborative efforts of interested stakeholders, and with the support of the American Petroleum Institute (API) and the National Petrochemical and Refiners Association (NPRA). The support of industry trade associations was critical to the success of the initiative. Projects undertaken by the Sector have dealt with issues involving streamlining environmental reporting, improving communication and public access to reported information, evaluating innovative technologies, and increased regulatory flexibility in exchange for improved environmental performance.
Currently the NACEPT Petroleum Refining Sector Subcommittee membership consists of approximately 20 members with highly diverse and knowledgeable backgrounds. Members come from organizations such as Shell Oil, Sunoco, Equiva Enterprises, Marathon Ashland Petroleum, Sierra Club, Louisiana Environmental Action Network (LEAN), Deep South Center for Environmental Justice, Louisiana Department of Environmental Quality (LDEQ), Texas Natural Resource Conservation Commission (TNRCC), and Toledo Department of Public Utilities.
A significant challenge to initiatives undertaken within this sector centered around trust, which historically has been low. The sector's first project, "Refinery Air Information Reporting System (RAIRS)," was purposefully limited in scope to provide a foundation for building trust among stakeholders. The goal of the project was to conduct an analysis of all current air emissions reporting requirements at refineries in an effort to reduce the reporting burden on the industry. Concurrent with this activity was the need to improve communications with communities and provide easier access to information by the public.
The trust and experience gained from this process was applied to a second more substantial project addressing equipment leaks at petroleum refineries. The "Equipment Leaks" project has potentially significant environmental impacts within both petroleum refining and other related industries. This is focused on evaluating innovative technologies to significantly improve the effectiveness of current leak detection and repair programs at refineries to substantially reduce fugitive air emissions.
More recently, the NACEPT Petroleum Refining Sector Subcommittee has taken on another project focused on communications involving the accidental releases at refineries. While the initial scope of this project focused on accidental releases, the scope has been significantly broadened to include all communications. A project of this nature would probably not have been possible during the earlier stages of this process. Work began on a pilot project in December 1998, when two Louisiana pilot facilities, Motiva Refinery and Shell Norco Chemical (Motiva/Shell), volunteered to participate. The goal of the pilot project is to develop a model program for improving communications between Motiva/Shell and their community that could be tailored to the needs of other communities and industries.
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The NACEPT process described and presented in this document was undertaken in the spirit of building trust through better communication among the Louisiana operations of Motiva Norco Refining Company and Shell Norco Chemical Plant (together referred to as Motiva/Shell in this document); their employees, the citizens of Norco, Louisiana; and other interested parties.
Most industries appear to believe that they are doing an adequate job communicating with their immediate neighbors. In fact, most have a variety of techniques that they employ that reach many households, especially those of present or past employees. Motiva/Shell has been going above and beyond the norm in reaching out to the community, but one of the findings of this project is that they have not truly communicated with citizens from all walks of life in Norco.
In mid-1998, Wilma Subra (the Subra Company) and Mike Meeuwsen (Equiva, a division of Shell/Texaco/Saudi Aramco Alliance), both members of the NACEPT Petroleum Refining Sector Subcommittee, suggested that Norco is a classic example of a community that could benefit from this initiative. If the citizens and Motiva/Shell could develop a model and efficient system for improved communications about citizens concerns, company activities, company policies and procedures, then the overall relations might be enhanced considerably.
Motiva/Shell officials readily agreed to embark on the NACEPT program, seeing it as an excellent way to respond to changing public expectations, increased scrutiny by the media, the changing regulatory environment, and improved community relations.
The original committee representation (see the acknowledgments section below) was chosen to ensure that the concerns of a cross-section of the community would be heard. The following report is the culmination of very open and quite frank discussions that addresses the communication needs of the citizens of Norco, Louisiana.
The project has been very successful in opening a dialogue within the community about how to ensure honest, open communication. The Findings and Recommendations will surely be of benefit to Norco and its citizens. However, there were regrets. During a defined period of community discussion and trust-building, several outside groups (notably Greenpeace and the Sierra Club) chose to hold demonstrations in the community, thus angering many citizens and causing them to question motivations of some participants. EPA participated in a meeting hosted by one segment of the community (Concerned Citizens of Norco), during which they aired concerns that were being addressed during the NACEPT project, while including outside allies but not all local stakeholders (Motiva/Shell, local government, LDEQ). Unfortunately, this served to undermine the spirit of open and honest communication.
In the end, the NACEPT Working Group has produced an excellent model to expand communication in a way that will benefit all the citizens of Norco.
The members of the NACEPT Working Group, all of whom have given of their valuable time and expertise, are as follows:
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Tab Troxler, Director St. Charles Department of Emergency Preparedness
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Dickie Duhe, St. Charles Parish Councilman and Motiva employee
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Clyde Taylor, St. Charles Parish Deputy Sheriff and Norco resident
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Milton Cambre, Norco resident, Presidential Point of Light award winner
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Edie Sirmon, Principal, Norco Elementary School
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Craig Matherne, Norco resident and Shell Chemical employee
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Margie Richard, Norco resident and NACEPT Petroleum Refining Sector Subcommittee member
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Greg Southworth, Manager Environmental, Motiva Norco Refining
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Kirk Menard, Manager Safety, Health, and Environment, Norco Refinery, Motiva Enterprises, LLC
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Don Baker, External Affairs Manager, Shell Chemicals
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Lily Galland, Community Relations, Shell Norco and former resident of Norco
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Glenda Clement, Norco Civic Association
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Percy Hollins, Norco resident
Dr. Robert Thomas, Loyola Chair in Environmental Communications and Director of the Center for Environmental Communications, Loyola University, was selected as the facilitator for all project meetings as well as providing communications counsel to the committee.
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III. EFFECTIVE COMMUNICATION WITH THE COMMUNITY
Since 1980, there has been a significant shift in attitudes and expectations of the American public regarding the relationship between business & industry and society in general. Corporate social responsibility and sustainable development are helping to reshape the role of business and industry from simply one of providing useful products and services to the public. Concerns about the environment, public health, political involvement, corporate philanthropy and communications are expanding the public's agenda. Specifically, the public expects corporations to be more open and responsive to these concerns and provide assurances that business operations are conducted in a social, political, economic and ethical manner.
Case for action
Over the past several decades, there has been a significant shift in public expectations regarding the relationship between business & industry and the various publics they serve. A common theme being expressed is "What's in the best interest of the public."
People are not accepting the old adage of "Let the buyer beware." Product quality at affordable prices, extended warranties, product recalls, environmental stewardship, and being socially responsible have emerged onto the global landscape. Traditional corporate structure has been reshaped with a new focus on global operations concerned with cost and competitiveness. It is becoming increasingly more difficult for business and industry to balance their internal needs with the changing expectations of the public. Concerns about the environment, public health, global climate change place additional pressure on companies to be more socially responsible. Communications with the public, which has traditionally been somewhat inconsistent, has taken on a new dimension.
These societal shifts have evolved due to several factors, including
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an increase in the public's awareness of environmental issues
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business and industry's changing role in society
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a more aggressive and participatory society that is no longer unwaveringly pro-industry
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more stringent regulations on business and industry
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a legal environment that has become more litigious
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sustainable development has become a concern of many special interest groups.
These shifts in public attitude are forcing companies to be more open, communicative and responsive to the needs of the public and their communities.
The meaning of social performance has broadened to include corporate involvement in economic development, education reform, helping prepare potential workers for the workplace, welfare reform among others. Companies have discovered that building positive and supportive relationships based on trust and understanding with their communities have many dividends such as:
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Support for permit renewals
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Support for expansions and new facilities
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Reduced potential for litigation
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Community Support During Crisis Situations
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More balanced media coverage
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Increased Employee Volunteerism
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Broader Based Community Support
More specifically within Louisiana, there has been a significant increase in the level of activity and the number of accusations by National and State environmental groups targeting a number of refineries and chemical plants located along the Mississippi River. Motiva/Shell are among the petrochemical facilities being accused of causing cancer and other health problems, causing property values to plummet, causing noise pollution, and reducing the overall quality of life in the community. While these allegations do not reflect the opinions of the majority of Norco residents, it does emphasize the need for effective and continuous two-way communications to address these accusations by special interest groups.
It is clear that a strong case for action exist for business and industry to improve on-going communications with key publics and the communities they represent. Effective, open communications are instrumental in developing and maintaining a long-term relationship built on trust and credibility.
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IV. CHARTER DEVELOPMENT ASSUMPTIONS
The charter development for the NACEPT Release Reporting Communication Study was undertaken by a sub-team of Motiva/Shell representatives who first developed a "draft" charter for review and approval by the full NACEPT Release Reporting Communication Team. In the development of the draft charter, certain unstated assumptions were relied upon, which were later surfaced as the Communication team met and dialogued on the community concerns at hand.
First, and foremost, there was an assumption by the sub-team that the issue at hand was that communication of releases, and the mechanisms and processes for these communications was the primary, if not sole issue. This assumption was based on the view that segments of the community had only requested more information on releases.
A corollary to the first assumption, or a second assumption, was that the primary want of the community was simply "more information." The presumption here was that the community had a good understanding of it's primary need, which was as stated a need for additional release reporting information, and if any other needs existed, they would have been stated.
A third assumption was that if there is a need or an interest in more release information from some segments of the community, then something about the current release reporting and communication system must be "broken."
A fourth assumption was that all members of the community were sufficiently familiar with the local manufacturing facility, the sub-team presuming that all segments of the community had knowledge and understanding of the local operations, maintenance, and other work processes of Motiva/Shell.
The fifth assumption was that all segments of the community were intimately familiar with the local community emergency response capabilities of the Parish, given that a substantial community education effort had been undertaken several years prior and that education effort was effective.
A sixth assumption was the belief that the community was homogenous in need, meaning one solution to the release reporting information need would satisfy all segments of the local community.
And a seventh assumption was the NACEPT Release Reporting Communication Study would fully satisfy the interested members of the community, and would preclude any other local or outside effort, activities, or initiatives.
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Objective:
To improve the effectiveness of communicating accidental release information to the Norco community and other stakeholders.
Actions:
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To evaluate and analyze the need for a system to communicate accidental release information to the Norco community. A NACEPT Working Group comprised of representatives from Motiva/Shell, the Norco community, local school principals, and St. Charles Parish Department of Emergency Preparedness (DEP) will be charged with this evaluation. The first step in the evaluation will be to determine what information needs to be included, what triggers the reporting process, how will the information be communicated, and what are the roles/responsibilities of all the stakeholders (define the problem).
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To define the current release communication process in the Norco community (including communication by state and parish authorities, the Citizen's Advisory Panel, and Motiva/Shell personnel).
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To identify what works well with the current release reporting system and opportunities for improvement in order to reach the desired process for release reporting (gap analysis).
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To identify process changes that will take advantage of the opportunities for improvement (close the gaps).
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To include the Norco community, St. Charles Parish, and Motiva/Shell during the implementation of the identified process changes.
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To develop a mechanism for evaluating the effectiveness of the changes that have taken place (i.e., community survey, etc.) (feedback system).
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To provide routine updates to the NACEPT Petroleum Refining Sector Subcommittee as the project progresses. In addition, Subcommittee members are to be kept informed as to meeting dates and locations so they may attend if they choose.
VI. MOTIVA/SHELL - NORCO COMMUNITY-BASED RESEARCH
Overview
The citizens of south Louisiana have long influenced the Motiva/Shell-Norco complex. Concurrently, both companies have been an influence on the area; in fact, the host community - Norco - is named after the parent company of the first refinery in the area, the New Orleans Refining Company (NORCO). The "company town" history is a critical data point in understanding the long-term relationship between the company and community attitudes and perceptions. In short, the co-dependency between the company and multiple generations of local Motiva/Shell employees over an 80-year period has resulted in a greater tolerance to industrial operations than in other "near neighbor" populations. See Figure 1 below.
Figure 1: The Norco Area (Click Here for larger view)
Research Approach
Motiva/Shell is working with the EPA's NACEPT Petroleum Refining Sector Subcommittee to develop a model outreach effort. One element of the effort is the establishment of a mechanism to measure the effectiveness of outreach programs. Statistically valid opinion research via a telephone survey of the community was selected as the primary research tool.
Motiva/Shell has voluntarily tracked community opinion in Norco utilizing statistically valid telephone surveys for nearly 10 years. Therefore, a solid baseline of opinion research was already in existence prior to the NACEPT project. In that process, the opinions of the community as a whole have been assessed. Communication programs have been implemented and/or modified to reflect the stated needs of the community. Communications have improved and Motiva/Shell's position in the community has benefited accordingly.
1998 Survey Methodology
The most recent Motiva/Shell community survey was conducted by Southern Media and Opinion Research, Inc. of Baton Rouge, Louisiana, and developed in association with Harris, DeVille & Associates, Inc. of Baton Rouge, Louisiana, and Mobile, Alabama. It was designed to address the opinions of residents in St. Charles Parish with special attention to the Norco area on familiarity and favorability toward the local petrochemical industry and on issues of concern to industry. This project tracks earlier surveys conducted in November 1994 and 1996.
Interviews were completed by telephone with 615 residents of St. Charles Parish. The interviews were conducted from Thursday, October 15, through Wednesday, October 21, 1998. The survey was designed to provide for a parish-wide sample of 400 and a supplemental sample, which would yield approximately 250 interviews among Norco residents. The parish was divided into four geographic areas based on telephone exchanges:
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Norco
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Luling - Boutte - Hahnville
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Destrehan - New Sarpy - St. Rose
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Paradis - Des Allemands.
The sample design for Norco called for a base sample of 35 with an estimated supplemental sample of 215. The interviews conducted in Norco were assigned U.S. Census block group designations based on address.
The statistics compiled for the entire parish area have a sample error not greater than plus or minus 5.1 % at the 95 % level of confidence. In other words, there is a 95 % certainty that the statistics on the survey are not more than 5.1 % above or below the figure that would have been obtained if all the households in the parish would have been interviewed. The sample error associated with the statistics for the Norco survey of 250 residents is not greater than plus or minus 6.3 % at the 95 % level of confidence.
Demographic highlights of the parish-wide survey include:
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Twenty-nine percent of the respondents work in the chemical industry or have a member of their household who does.
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Females made up 57 percent of the total respondents, and males comprised 43 percent.
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Seventy-seven percent of respondents were White; 18 percent were Black, and 3 percent were of other ethnic descent.
1998 Survey Findings
Overall, residents in the parish area think conditions in Louisiana are good and have improved over the last four years.
When asked about their opinions about local petrochemical plants, respondents were generally positive. Most had a favorable impression of the local petrochemical plants; however, White respondents were more favorable than Blacks.
In addition, respondents continued to think that local plants are doing too little to keep citizens informed about their activities. Interestingly, historical data showed that fewer people are getting their information about local companies from the newspaper, television and word-of mouth compared to a similar survey from four years ago.
Nearly half of the respondents thought the amount of pollution from petrochemical plants was staying the same, but Black respondents were more likely to think emissions were increasing compared to White respondents.
Another interesting finding was in the area of risk versus benefit. Compared to two years ago, data indicated that people think risks from chemical plants are slightly increasing while benefits are decreasing.
Historical data showed that respondents continue to think Motiva/Shell as the two petrochemical companies that have done the most to show a genuine concern about the people in the area. Data also showed that Norco area respondents were generally more favorable toward Motiva/Shell than respondents parish-wide and give them higher performance ratings in the areas of economic/job development, safety, pollution control and community outreach.
A more detailed analysis of the data, however, indicates significant variations in response within the Norco community by demographic variable, most notably race. The Black population is generally less trusting and less appreciative of the benefits of industry than is the White population. Given the Norco population is about 20% Black, it is incumbent upon Motiva/Shell to try and determine what barriers exist, if any, to communicating with the entire Norco population.
Focus Groups
Telephone surveys provide an excellent tool for identifying community concerns and tracking performance. However, an inherent limitation is the superficial nature of the questioning. Therefore, a natural follow up to telephone surveys is more in-depth face-to-face interviews with the population of interest. Focus groups provide an excellent mechanism to garner more detailed data. Focus groups, however, do not provide a representative sample of the entire population.
Accordingly, Motiva/Shell commissioned Harris, DeVille & Associates (HDA) to conduct focus group(s) in Norco to gather insight into the disparities in opinions that exist within the Norco community. Specifically, communications tools and messages were assessed, including questions such as:
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What type of information do you want/need from Motiva/Shell?
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What type of information do you need during an emergency event?
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How do you expect to receive these data?
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What is the best way to get that information to you?
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How quickly do you expect to hear it?
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What types of information do you need in a non-emergency situation?
Focus Group Methodology
A review of the telephone survey data indicated the most significant variations in response were based upon race and geography. Specifically Black residents of the Diamond Community expressed the greatest variations in response when compared to Norco as a community. Therefore, the first in-depth questioning was held with Diamond Community residents.
The general parameters set for participants of the focus group was residency in the Diamond Community and being a Black adult. Ideally, the focus groups would have 8-12 participants. Approximately 15-20 participants were recruited to ensure an adequate sample size. Two local minority churches were used as the mechanism for recruiting participants.
Participants were to offer a representative profile of gender and occupation. A 50/50-male/female ratio and diversity of occupations were invited to participate in the focus group.
As is the norm for focus groups, participants were paid $50 for participating.
The focus group was conducted on Monday, March 15, 1999, from 5:30 to 7:30 p.m. in the Good Hope Missionary Baptist Church in the Diamond Community. Ten residents (6 females and 4 males) participated and occupations represented included construction, religious leader, teacher, retail, clerical, retired, and law enforcement.
Focus Group Findings
Key findings from the focus group included:
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Jobs are the main benefit of Motiva/Shell being in the community. There was some recognition of products, as well.
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There was strong appreciation of Motiva/Shell's participation in schools.
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There were strong concerns expressed over no job opportunities for Diamond residents.
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Concern over emergency response, the health risk from pollution, and nuisance issues were the top three concerns mentioned.
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There was also a concern over communication with Motiva/Shell. The thought was if you know someone at Motiva/Shell, then you have a way to communicate. Otherwise, real access to the plants is severely limited.
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There was high interest expressed in learning more about Motiva/Shell's hiring practices; moderate interest existed in product issues.
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There was a high level of concern over communication during an emergency event. The focus was on the impact of an event on individual families.
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There was recognition that the parish Office of Emergency Preparedness is responsible for emergency communication.
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Group expects to receive emergency data from police.
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Group felt that a siren or alarm system is the best way to notify them in an emergency situation.
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Plant workers and parish Office of Emergency Preparedness are the most trusted sources of the "real" story for an emergency event.
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Most expect to be notified about an incident within 15-30 minutes.
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People expect to be notified if some action is required on their part.
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In an emergency, the group expects to be told what to do.
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The parish needs to let people know what to do to protect themselves and their families in an emergency situation.
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The group felt that Motiva/Shell did not communicate enough with the Diamond Community and could do a better job informing the community on a regular basis.
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The group felt that differences in opinions by race in the parish are due to differing education levels, cultural backgrounds, and access to information.
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The group also felt these differences can be removed by better communications and having people work in industry.
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The group felt that churches are the best mechanism to resolve differences in opinion.
In addition to the responses to the questions and issues raised by the facilitator, the following observations were recorded:
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The group professed a strong work ethic and sense of commitment to community.
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A buyout of the community was neither volunteered nor discussed.
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The group feels invisible to Motiva/Shell.
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The group expressed respect for Motiva/Shell.
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The group wanted an equal opportunity to go to work.
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Many of the concerns expressed can be resolved through dialogue.
A complete transcript of the focus group session is available upon request.
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VII. SHELL NORCO CHEMICAL PLANT: DECEMBER 8, 1998 UNUSUAL EVENTS
On December 8, 1998, two unusual events occurred at the Shell Norco Chemical Plant in approximately the same time frame, resulting in a key learning for the NACEPT study. One of the events (a reactor overpressure) had the potential for a vessel rupture, had a significant amount of community involvement due to the precautionary measures taken, and did not involve the release of any material. The other event involved the release of 37% hydrochloric acid (HCl) in an amount below the reportable quantity and had minimal community impact. No one was injured in either of the events.
These events received and are continuing to receive a significant amount of public and media attention due to the proximity of their timing. Shell requested that students who had already arrived at nearby schools shelter in place as a precautionary measure because of the reactor overpressure. Because a number of kindergarten through third grade students were still in route to school, they were diverted by the Parish (=County) Emergency Response Coordinator to a high school four miles from the plant. This relocation created significant unexpected media attention. In addition, the annual NEJAC conference was being held in Baton Rouge. The group had toured the Norco area on December 6, 1998, and a member of the community made an impassioned plea for help at the meeting on the night of December 8th. This brought the December 8th events to the attention of the LDEQ, EPA, Sierra Club, LEAN, and other state and national organizations. Greenpeace, Sierra Club, and other environmental groups ultimately staged protests near the plant.
Emergency response plans of Shell, St. Charles Parish, and the State worked as planned. Review of the incidents concluded that the decisions and communications during the event were appropriate and timely.
The key learning from this event is that communication during an event, even with a system as sophisticated as the one in St. Charles Parish, in insufficient. The key to success is working with the public in advance to insure they understand what occurs inside the plant, how they will be communicated with during an emergency, what will happen to their children and what they should do themselves. In addition to understanding, the public needs to trust that government and industry will do the right things in an emergency to protect public health and safety.
Resins Unit
The first incident involved the batch resins unit that manufactures epoxy resins for use in circuit boards. This process heats resins and methyl ethyl ketone (MEK, a paint solvent) to form another resin. During this reaction, the viscosity (thickness) of the material increased more rapidly than expected. This is an indication of an uncontrolled reaction and there was the potential for the pressure to rise to a point where the vessel would rupture if the relief device failed. At the time, the vent line from the rupture disc was cool so the conservative assumption was that the line was plugged. (Investigation after the event showed that the rupture disc had not blown and that the relief line was not plugged.)
At 0815, the event was declared an unusual event and the on site emergency response team was activated. The incident commander arrived at the scene and upgraded the event to an alert level at 0827. The alert level tells the DEP, parish officials responsible for managing the public response, to assemble their personnel. The incident commander also requested that the nearby schools shelter in place due to the potential of flying debris from a rupture. The state police were also notified at this time and Shell representatives with radios were sent to the nearby schools.
Because the kindergarten through third grade students were on the way to school, the DEP director made the call to reroute the busses to a high school outside the area which could have been impacted. The DEP has the capability to communicate directly with bus drivers by radio. The DEP also informed the schools next to the plant to shelter in place. The local press picked up the notification to the bus drivers and questions on the status of the plant began as early as 0850. The general community was advised of the alert occurring at the site via cable TV and at 0945 a message went over the automatic phone line to the town of Norco. Seven hundred and thirty messages were delivered in less than 15 minutes on the status of the plant.
The state police arrived at the plant at 0935 and joined incident command and at 1005 the LDEQ arrived to catch samples. The LDEQ did not catch any samples because there had been no release. (Shell did some community verification samples as part of the routine emergency response plan. No MEK was found in the community.)
The plant monitored the reactor temperature to determine the status of the reaction and at 1052 downgraded the event to an unusual event and at 1140 declared an all clear.
At 1500, Shell sent flyers and a message over the automatic phone system to the community describing what had happened.
Shipping
At 1210, a railroad tank car was overfilled and four hundred pounds of material was spilled on the ground. A visible HCl plume drifted over the maintenance building and into the community then rapidly dispersed. Because we were in the process of unstaging from the previous incident, firewater was rapidly put on the spill and samples in the community were caught within three minutes of the event starting. No HCL was measured in any of the samples (this matched the observation that the cloud had rapidly dispersed.) No injuries at either the plant or in the community were reported.
Because the release was below the reportable quantity and there were no reports of injury or damage, the release was only called into the DEP. However, the state police emergency response personnel were onsite during this release.
Communication with the community on this event was minimal.
Community Response
Significant press coverage occurred on the day of this event. This coverage created a significant level of emotions because of the sheltering of some students while apparently evacuating others. (Remember that the K - 3 students were rerouted, not evacuated.) Confusion on what the public was supposed to do and the lack of using community sirens (reserved for the next level of emergency when the DEP wants the public to take immediate action) added to the emotions of the day.
That evening the event was discussed at the NEJAC meeting which was being held in Baton Rouge. The presentation was highly charged and presented the responses of the day as falling well short of what people should expect. This resulted in the EPA and LDEQ meeting with Shell on December 10th to review the incident and the response. It also resulted in several local and national environmental groups becoming involved in the incident.
Air samples were caught by the National Bucket Brigade Project at 1641 in the nearby community. The results were all in the low part per billion range and were on the low side of range of results that would be found in any urban environment. These concentrations were represented as being harmful to the people in the community and proof that the incident was still continuing hours after Shell had stated the event was over. This accusation added to the emotions of the event.
An attempt was made to have a public meeting on December 11th, but was canceled because of an inability to get all the concerned parties together. Because of the Christmas holidays, the meeting was delayed until January 14, 1999. Shell, LDEQ, EPA, Concerned Citizens of Norco, and Greenpeace representatives participated. It was a very emotion packed meeting, but there were legitimate concerns expressed about how a member of the community would be informed of an incident and how they would know what to do. The lack of understanding of the parish's emergency response system is a key learning. The system is one of the best in the nation and efforts to educate the community have been going on for approximately twenty years.
There have been numerous other meetings about this incident. They range from a response evaluation with the DEP to protests from Greenpeace. Shell has also sponsored surveys and focus groups to fully understand the needs of the community.
Key Learnings
The December 8th incidents are an interesting case study on communications during emergencies. The look backs by the emergency response organizations indicate they believe that appropriate protective actions were taken by all involved. However, two opinions have developed in the community. One is that the response and communications met the needs of the community and the other is that it fell far short. Motiva/Shell's assessment is that the difference lies in the amount of knowledge about Shell and trust that Shell will do the right things the community members have. Both of these items are developed outside of the time frame of an emergency.
Forward Plan
The plan for improving the response to this type of incident include meeting with various groups within the community to discuss our performance and their expectations, reviewing the incident with the NACEPT panel to see if there were possibilities for learning outside the Norco community and participation with the LDEQ in setting up a Community Industry Panel.
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As stated previously, the NACEPT process has provided extremely valuable communication information that will potentially enhance the relationship between the Norco community, its citizens, Motiva/Shell (the reference used herein for Motiva Norco Refining Company and Shell Norco Chemical Plant), respective workers, and other interested parties. Over the period of the NACEPT project, the types of questions addressed include:
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How do we account for the survey differences between the Black and White communities?
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Is it possible to communicate within the community as a whole, or do we need to identify portions that have different communications requirements?
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Are there any gaps between community expectations and current communication systems?
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Does Motiva/Shell know the kinds of information the community needs to know, or is Motiva/Shell making false a priori assumptions?
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Do all sections of the community really want an open relationship with Motiva/Shell and/or neighboring plants?
The following discussion identifies key findings that need resolution.
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There is a significant disparity in opinions about the effectiveness of communications among the Black populations, White populations, and the plants. This was revealed in the surveys by Harris DeVille and Associates and became ever more clear during focus group discussions.
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Inconsistencies exist in parish-/industry-sponsored emergency notification and the public's knowledge of response procedures. Many do not know that there are regularly scheduled tests of the emergency warning system conducted by the parish's DEP.
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There is an information void that exists related to "quick response" on environmental and emergency issues.
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The greater the perceived benefit from Motiva/Shell, the less the perceived risk.
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Related to the last finding is that the more involvement citizens have with the chemical plant, the more comfort they feel about living in Norco.
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Generally, the closer citizens live to the fence-line, the more they worry. They feel they have less time to react.
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Informal communication networks exist, but they do not serve all citizens in any neighborhood. Informal networks, by definition, are likely to miss people who are not members of these networks. Although formal communications may be applied equally, they are not equally supported by informal communications networks, hence the disparities that exist within the area.
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NACEPT assumptions about communications issues were myths. The following comments on each may be compared numerically to those in the previous assumptions section (IV: Charter Development Assumptions):
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Communication of releases, and the mechanisms and processes for these communications was the primary, if not sole issue. Response - release communication and the processes for these communications was only one of numerous issues later surfaced in discussions.
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The primary want of the community was simply "more information." Response - the community does want more information on the facility, including release information, but also expects other information on general activities associated with the facility, not just the "negative" information.
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If there is a need or an interest in more release information from some segments of the community, then something about the current release reporting and communication system must be "broken." Response - The current reporting and communication system is "state of the art" in technology (i.e., the program for St. Charles Parish is among the best in the country, including the use of technology) and is not "broken." However, it is intimidating to some members of the community and is thus not entirely effective.
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All members of the community were sufficiently familiar with the local manufacturing facility, the sub-team presuming that all segments of the community had knowledge and understanding of the local operations, maintenance and other work processes of the Norco Refinery. Response - Selected segments of the community are not familiar with the facility.
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All segments of the community were intimately familiar with the local community emergency response capabilities of the Parish, given that a substantial community education effort had been undertaken several years prior and that education effort was effective. Response - Selected segments of the community are not familiar with the capabilities of the Parish, and the effort to educate several years prior needs to be repeated.
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The community is homogenous in need, meaning one solution to the release reporting information need would satisfy all segments of the local community. Response - Various segments of the community have different understandings of the facilities and parish operations, and thus have different information and education needs.
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The NACEPT Release Reporting Communication Study would fully satisfy the interested members of the community, and would preclude any other local or outside effort, activities, or initiatives. Response - The NACEPT Release Reporting Communication Study did not satisfy all members of the community and did not preclude other local or outside activities or initiatives.
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Different audiences require different methods of communications. People in the community who have a work history with the plant feel very comfortable calling plant managers to discuss issues or gain information; people who do not have the work history are not comfortable making contact, thus they do not call. The group identified three audiences who may need different methods of communication: the White community (most of whom have a work history with the plant), the Diamond Community (Black), and the Concerned Citizens of Norco (a group of approximately 45 Black citizens).
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Communications from the plants are perceived to be inconsistent, and among Blacks are associated only with safety incidents inside the facilities. The feeling is that the lack of consistency of unanticipated communications causes citizens to expect an inadequate flow of information. As an example, the plants' April 1, 1999, prior notice through several media venues regarding a planned flaring was cited as an excellent example of communication with the community, but citizens then wondered why flares reported in the media on July 23, 1999 (Times Picayune, East Jefferson Edition, B2), were not handled the same way.
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Citizens appreciate open meetings where issues may be discussed. Such meetings build trust.
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The plants cannot rely on one communication system alone to deliver the messages. When only one method is used, no matter how effective it has been in the past or in other places, it will probably miss persons needing the information.
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Citizens in the Diamond Community have concerns about their long-term health, and some are interested in having their property purchased at a fair price.
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There is a tendency to tell people what the company wants them to know rather than what the people may need to know.
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A safe evacuation route for persons living between the East Plant and West Plant, especially people in the Diamond Community, is a key issue.
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The NACEPT Working Group members have been satisfied with the operations of the DEP, led by Tab Troxclair.
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The following recommendations are discussed in a logical order, but should not be considered as rank-ordered on the basis of importance. The NACEPT process has identified them all as priorities. One characteristic of a company that is serious about communicating with its surrounding community is that it gives priority attention to each of the following.
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Get to know your neighbor. Companies must know and understand their community and key audiences. This may be accomplished through formal research (thorough survey programs that have statistical validity) and ongoing direct contact with the community. The latter is best accomplished through a formal system of regular (monthly, quarterly, etc.) meetings on the citizens' turf. Every effort must be taken to ensure that the entire community is aware of the meetings. Every employee should be encouraged to communicate with neighbors and family about the activities of the companies.
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Be open to the community's concerns and key issues and address them rationally. If they are important to the community, they should be important to Motiva/Shell. Form a partnership with the community and leverage plant resources for the good of all the citizens. Plants should establish procedures for handling community concerns or complaints. Dedicated plant personnel should be available to respond to community calls 24 hours per day, seven days per week.
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Provide periodic tours of the facilities that explain plant operations, policies, and procedures. Take the mystery out of plant operations. People are much less fearful of what they have seen and understand.
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Be proactive. Do not wait until something bad happens to talk to the community. Citizens should hear good news, upcoming events, concerns the plant has such as potential problems (and how they are being addressed), and certainly anything out of the ordinary (such as unusual flares or sounds) that are anticipated. As an example of the importance of this action, if a person works in the plant, he/she knows that a sudden flare indicates that the gas compressor has tripped and that the safety feature is working. If one has no knowledge of the workings of the plant, the a sudden loud flare stimulates the question "Where do I run?"
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Employees of Motiva/Shell are a critically important audience. Let them know what is going on, both inside and outside the fence line.
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Communications should be improved with all populations that are affected by the results of operations by Motiva/Shell. Though it is obvious that the citizens living in Norco are the most likely to be impacted by challenges associated with plant operations, it is important that Motiva/Shell be ever vigilant to identify and communicate with groups of people who may in some way come in contact with such issues as air and water contamination.
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Due to a variety of reasons discussed during this program and enumerated in this paper, communications programs must be developed that target the Diamond Community, part of which is the Concerned Citizens of Norco, without alienating other neighborhoods. There is a need to improve "informal" communications within the Diamond Community so that formal communications will be believed and followed.
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Work with community organizations such as neighborhood groups, schools, churches, and civic organizations to develop relationships within the community. Listen carefully to every voice in the community and weigh their comments carefully. Telephone notification systems are effective ways to notify community residents of issues/events of importance.
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Be absolutely sure that all citizens can be contacted during a crisis. Presently, the system uses automated telephone dialing systems, television, knocking on doors, handing out fliers, notifying keep community leaders and organizations, and the like. Develop a system that ensures that people who do not have telephones and televisions are alerted immediately.
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Understand changing expectations concerning social responsibility and respond to them justly and promptly. Do not be mistaken about the importance of social ills within neighboring communities. Remember, the neighbors are humans who have needs. Though the company does not need to accept responsibility for all situations that exist, it is the right human thing to do to take responsibility for helping provide solutions. It is also obvious that it is in the best overall interests of companies to practice social justice and leverage their respective resources for the good of the community.
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Provide employment opportunities for local residents and facilitate skills training for those willing to learn. This is social responsibility at its best, but it also benefits the company and the community at large. Skilled, educated, employed people are good for everybody, especially themselves and their families.
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Participate in community projects that meet specific community needs and expectations. A characteristic of a socially responsible company is that they develop and maintain a list of community needs and expectations, and that list is known to the public and used as a checklist for company projects.
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Provide information to the community to address fears and concerns about public health.
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On a quarterly basis, the NACEPT Working Group will review the implementation of the recommendations, evaluate improvements in communications with the community, and develop additional action items as appropriate. Periodic progress reports will be provided to the NACEPT Working Group.
Recognizing that a number of changes were needed to improve the communication process with the entire Norco community, and encouraged by progress resulting from the NACEPT Working Group, Motiva/Shell has implemented the following initiatives.
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Within the Diamond Community of Norco, a core group comprised of representatives of both churches and Motiva/Shell has been formed. Meeting as a group on a monthly basis, with more frequent subcommittee meetings, the group has identified two focus areas designed to improve communications and add value to community residents. The first area involves youth development with the second being on-the-job (OJT) training. Youth development programs underway include tutoring/mentoring, leadership skills training, community service, and fund raisers. The OJT initiative is designed to provide job skills training, dressing for success, and job interview skills, among others.
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A community-wide telephone alert system has been installed, and recently improved, to notify and keep residents aware of emergency situations. This system is also available to communicate other information to community residents when warranted. Similarly, an agreement has been reached among the St. Charles Parish School Board, Sacred Heart School, and Motiva/Shell to install a similar telephone system among local schools.
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A new Community Awareness/Emergency Response brochure is being developed to raise awareness and provide information to community residents about what to do in case of an emergency. This brochure will provide residents with information about which local radio, television, or cable channel to turn to for information, as well as information about sheltering in place and/or evacuations. In addition, a condensed version of this information will be available on refrigerator magnets, which will also be provided to community residents and schools.
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Community Concerns Handling Procedures, a subsection of the companies' Policies and Procedures, have been rewritten to broaden the scope of responsibility of Motiva/Shell site supervisors, who are on duty 24 hours a day, seven days a week. The new procedures require immediate response to community calls/concerns about plant operations. All calls are logged and appropriate action is taken by the site supervisors to resolve issues/concerns. All inquiries/complaints are forwarded to the Community Concerns Committee (a committee made up of Motiva/Shell employees that is provided for in the companies' Policies and Procedures; its purpose is to assure that community complaints/concerns are being addressed in a timely manner), chaired by the External Affairs Manager, for review and further action if required. This committee meets twice monthly to ensure all complaints have had a response.
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Motiva/Shell and other local industrial facilities have agreed to participate in a Community Industry Panel created to improve communications and address community concerns. The LDEQ has agreed to facilitate the panel selection and will assure broad-based community involvement. The first panel meeting was held on August 26,1999, with subsequent meetings scheduled for the third Thursday of each month.
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The crisis communication plan for Motiva/Shell has undergone considerable modifications including the creation of a Crisis Communication Management Team, composed of Motiva/Shell employees, that is responsible for all communications during an emergency event. Not only does the revised plan better identify key audiences, but it provides greater resources needed to effectively manage communications during an incident.
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These changes, in addition to the community outreach programs Motiva/Shell currently has in place, should significantly improve the Norco community's understanding about plant operations. Further, as community concerns are better identified, there is a greater likelihood that available resources will be targeted to the areas of greatest need.
It is evident from this study that public issues and/or concerns lead to changes in public policy. Clearly the public is interested in being a "player" on decision making relative to the public interest. Increasingly, the question being asked by special interest regards, "is it in the best interest of the public?"
With this in mind, it is definitely in the best interest of business and industry to recognize this change in public attitude and expectation. The need for more open and proactive communication has never been greater.
Further public expectation for business and industry involvement in resolving social issues is on the rise. It is apparent that the role of business and industry is undergoing significant changes. Sustainable development is only one of many examples that balance economic growth with potential impacts on public health and safety and the environment.
In the case of Norco, industry has generally been viewed as a positive influence on the community. However, it is clear from this study that a holistic approach to communications and/or community relations does not address the needs of the entire community. Indeed there are considerable differences among residents of the Norco community. Recognizing these differences and being responsive to these differences can only result in stronger, longer lasting relationship with all members of the Norco community. This outcome is clearly in the best interest of Motiva/Shell.
Don Baker
Don Baker received a B.S. Degree in Business from the University of Florida in 1969 and a M.S. Degree in Political Science from Southern Illinois University in June 1983. He joined Shell in the Southern Marketing Region - Retail Sales, in Tampa, Florida, in 1969, as a Regional Marketing Representative. After various assignments in Sales and Market Development, he was promoted to Manager - Sales Development - Oil Products, in1974, in Charlotte, North Carolina. He was promoted to Territory Manager, Philadelphia, Pennsylvania District in 1977. In 1930, he was transferred to Houston, Texas, into the Public Affairs Department, Domestic Affairs. He transferred in 1982 into the Plans and Integration Group, Products, Public Affairs. In 1983 he was promoted to Community Relations Manager - Midwest and moved to St. Louis. In August 1938, be was promoted to External Affairs Manager - Southeast and moved to New Orleans. In this capacity he is responsible for developing and implementing programs designed to improve internal and external communications, interfacing with government officials, monitoring legislative activity and managing issues of interest to the community and Shell.
Don is well respected for his knowledge of crisis management and the communication dimension associated with a crisis. He has conducted many seminars, both within Shell and to external audiences throughout the United States. Don is also respected for his strategic planning skills and has been actively involved in change management and redesign initiatives, both internal and external to Shell. He is also a Professional Accredited Business Communicator, ABC (International Association of Business Communicators), one of only 600 accredited in the world.
Kirk Menard
Kirk Menard commenced working for Shell Oil Company in November 1978 as an Industrial Hygienist. He transferred to the Norco Complex in February 1980 as Industrial Hygiene Group Leader until July of 1990 and became Manager of Alkylation Operation in March 1994. Menard became Manager of Health and Safety from then until May of 1995. Currently Menard is the Manager of Safety Health and Environmental for Motiva Enterprises, LLC. He has a Bachelor of Science Degree in environmental science from Lamar University and a Master of Science Degree in environmental science from the University of Texas, School of Public Health. Menard has a Juris Doctor from Loyola University and is a certified Industrial Hygienist by the American Board of Industrial Hygiene.
Robert A. Thomas
Dr. Robert A. Thomas is an academician, a business/environmental community liaison, a media source for environmental news, and a family man. He was Founding Director of the Louisiana Nature & Science Center, where he gained the Greater New Orleans community's trust in his knowledge of science education, environmental issues, and natural history. Dr. Thomas now holds the Loyola Chair in Environmental Communications and is Founding Director of the Center for Environmental Communications at Loyola University New Orleans. He is also actively involved in Cypress Swamp Tours, a Westwego-based ecotourism business.
Dr. Thomas, who received his Ph.D. in Vertebrate Zoology from Texas A&M University, holds Adjunct Professorships at the University of New Orleans, Tulane University, and Louisiana State University. He is the past President of the Association of Nature Center Administrators and is a member/chair of several academic, business, and civic boards and committees, including the Policy Advisory Committee for the Outer Continental Shelf program of the U. S. Minerals Management Service. He served on the Accreditation Commission of the American Association of Museums and as Chair of the Environmental Advisory Committee for the Strategic Petroleum Reserve.
September 23, 1999