Though Baltimore's emergency planners have long known that a devastating chemical accident could occur in the train tunnel under Howard Street, the city's 440-page emergency plan does not address such a problem and never mentions the tunnel.

The plan, required by federal law, has no provision for responding to chemical accidents involving trucks or trains, even though city Fire Marshal William E. Martin said yesterday: "Most of my worry is about transportation accidents, because they can happen anywhere."

Last week, that worry became reality, when a 60-car CSX freight train hauling toxic chemicals derailed, setting off a disastrous domino effect: a fire that burned under a downtown street for days, a water main break and a spill of caustic hydrochloric acid that stymied firefighters' efforts to douse the blaze.

Mayor Martin O'Malley praised firefighters' courage, saying in a letter Tuesday that the department "helped Baltimore navigate this crisis without the loss of a single life. There is no clearer indication of our success."

Yet, O'Malley added: "It is not a question of if, but when ... Baltimore will again be confronted with comparable challenges." He said the Fire Department needs to answer several "fundamental questions," including: "Were we adequately prepared to respond to this crisis?"

Fire officials are already at work on an accident post-mortem, Martin said.

Gene Reynolds, a chemical safety expert at FMC Corp. in Fairfield and an emergency planner here for 18 years, said local officials never devised a plan for combating an accident in the tunnel because they thought a fire there would burn itself out. And if toxic gas were to seep from the tunnel, they thought that it could not be effectively contained.

The plan - drafted in 1987 - devotes two of 440 pages to the risk of chemicals spilling or burning on roads or railways. It includes no highway or rail maps, no assessment of accident-prone intersections and no list of chemicals traveling through the city or the routes that they take.

Federal grants are available to improve the city's preparedness, but city officials were unaware of that until told yesterday by The Sun.

Experts who reviewed the plan at The Sun's request said it has many other shortcomings.

"It's not very sophisticated," said Fred Millar, a nationally known expert on hazardous materials transportation and former head of hazard analysis for the District of Columbia's emergency planning committee. "Nothing in here relates to the worst-case scenario."

Martin, a city fire chief and head of the volunteer Local Emergency Planning Committee that prepared the report, acknowledged yesterday that the plan has large gaps.

For example, in most chemical emergencies people are instructed to "shelter in place," closing windows and turning off air conditioners to keep out toxic fumes. But most of the city's schools, hospitals and nursing homes have no plan for such action, and officials don't know which buildings are airtight enough to be safe.

Martin said that information would improve the chances of getting through another accident without serious injuries or deaths.

'Don't have the resources'

"If the chief [top administrator Carl E. McDonald] relieved me of all my other responsibilities and said, ... 'Here's a blank check. Do what you need to. Get it done,' I could improve this plan drastically," said Martin. "But we don't have the resources."

The federal Emergency Preparedness and Community Right-to-Know Act of 1986 requires states and cities to plan for chemical accidents, including ones that occur on roads and railways. But neither the federal government nor the city provides money to pay for the work, which is mostly done by volunteers, Martin said.

"You've heard of unfunded federal mandates? Well, this is one," Martin said. At meetings, "either I buy the doughnuts or [Capt. George Clinton] buys the doughnuts out of our own pocket. We're trying to do the best we can with what we have."

Martin's complaint about lack of funding upset Rep. Elijah E. Cummings, whose 7th District abuts Mount Royal Station at the north end of the tunnel.