LACK OF PROTECTION FOR COMMUNITIES AT RISK FROM AMMONIUM NITRATE STORAGE FACILITIES.
EXPLOSION AT THE WEST FERTILIZER PLANT IN TEXAS
On April 17, 2013, an explosion and fire in the West Fertilizer
facility in West, Texas, resulted in at least 14 fatalities, 226 injuries, and
widespread community damage. Large
quantities of ammonium nitrate (AN) fertilizer exploded after being heated by a
fire at the storage and distribution facility.
The U.S. Chemical Safety Board (CSB) stated few months ago that the fire
and explosion was preventable. It should
never have occurred. It resulted from
the failure of a company to take the necessary steps to avert a preventable
fire and explosion and from the inability of federal, state and local
regulatory agencies to identify a serious hazard and correct it.
Cause and Origin Investigation of the Deadly explosion at the West Fertilizer Plant in Texas
At around 7:30 p.m.
on April 17, 2013, emergency dispatchers received reports of smoke and flames
at the West Fertilizer Company’s storage and distribution center in the town of
West, Texas (population 2,800), located on Interstate 35 just up the road from
Waco. Firefighters from the town’s
volunteer fire department rushed to the scene, where the fire seemed to be
quickly intensifying. Neighbors who
lived nearby, including many residents of the West Rest Haven Nursing Home,
located just 200 yards (183 meters) from the West Fertilizer facility, gazed at
the fiery spectacle. The nursing home
was close enough to the billowing smoke that the facility’s staff began moving
residents to more protected areas inside the building to avoid the hazard.
A crew of 22
emergency responders arrived at the site and, assisted by two West residents,
attempted to douse the flames. The fire was large and getting bigger, and it
was in the process of engulfing a wooden warehouse. The structure was comprised
of wood-framed bins with wooden walls and contained approximately 60 tons of
fertilizer-grade ammonium nitrate, a granular solid that can detonate in
certain conditions when it interacts with fire. Built in 1961, the building
lacked automatic sprinklers or suppression features and was not required to
install them, since Texas lacks a state fire code. There were no state regulations guiding
appropriate storage amounts of the fertilizer. The facility was unattended at the time of the
fire.
About 20 minutes
after the fire was reported, the ammonium nitrate detonated, producing an
enormous explosion that pulverized much of the West Fertilizer site and sent
chunks of concrete, wood, and steel hurtling into the surrounding
neighborhoods. The explosion’s shockwave rocked the entire town.
The blast was heard
80 miles away and registered a magnitude 2.1 tremor that was recorded by the
U.S. Geological Survey. At the West Rest Haven Nursing Home, the windows
shattered and the roof collapsed, trapping scores of elderly residents beneath
the rubble. Across the street from the nursing home, the West Terrace apartment
complex was shredded by the explosion. A half-mile from the blast site, the
West Middle School suffered major damage, as did the West Intermediate School.
Nearly 200 homes were damaged or destroyed.
The explosion killed
15 people: 10 firefighters, ranging in age from 26 to 52; their two civilian
helpers; two residents from the West Terrace apartment complex; and a nursing
home resident. About 200 people were injured. Many of the impacted structures —
including the two schools, the nursing home, and the apartment complex — have
since been demolished. The U.S. Chemical Safety Board (CSB), which has released
preliminary findings on the incident and is working on a final report,
estimates that total damages could exceed $230 million. The cause of the fire
has not been determined; in its preliminary findings, the CSB said that “the
explosion resulted from an intense fire … that led to the detonation of” the
stored ammonium nitrate.
West prompted an
executive order by President Barack Obama directing the federal government to
improve safety and security at chemical facilities, and the Department of
Homeland Security has sought the assistance of NFPA as part of its efforts to
carry out that order. The Environmental Protection Agency (EPA) has also
answered calls to action from the president and CSB by taking part in a working group, including the
Occupational Health and Safety Administration (OSHA), that is addressing
chemical facility safety.
The activity is timely and necessary, since the
potential for another disaster extends far beyond West, Texas. The USEPA
estimates that 13,000 facilities similar to West Fertilizer pose threats to
communities throughout the U.S.
Preliminary Findings of the U.S.
Chemical Safety Board from its Investigation of the West Fertilizer Explosion
and Fire. CSB Says the Disaster Should Never
had happened
The
CSB has made the following observations and preliminary findings to date, which
are subject to further revision and development as the investigation unfolds:
1)
The explosion at West Fertilizer
resulted from an intense fire in a wooden warehouse building that led to the
detonation of approximately 30 tons of Ammonium Nitrate (AN) stored inside in wooden
bins. Not only were the warehouse and bins combustible, but the building also contained
significant amounts of combustible seeds, which likely contributed to the intensity
of the fire. According to available seismic data, the explosion was a very powerful
event.
2)
Whether additional factors such as
material characteristics, shock, or contamination contributed to the incident
remains to be determined. Company employees described a PVC plastic pipe that
was located directly above the AN bin that detonated, and likely would have
been melted by the fire. Additionally, large amounts of potentially flammable
anhydrous ammonia were stored along the southern edge of the warehouse building.
3)
The building lacked a sprinkler system
or other systems to automatically detect or suppress fire, especially when the
building was unoccupied after hours. By the time firefighters were able to
reach the site, the fire was intense and out of control. Just 20 minutes after
the first notification to the West Volunteer Fire Department, the detonation
occurred.
4)
Both National Fire Protection
Association (NFPA) and the International Code Council (ICC), private
organizations that develop fire codes that are widely applied across the U.S.,
have written code provisions for the safety of ammonium nitrate. Many of these safety
provisions are quite old[1]
and appear to be confusing or contradictory, even to code experts, and are in
need of a comprehensive review in light of the West disaster and other recent
accidents. For example the ICC’s International Fire Code directs users to a
defunct code for ammonium nitrate (NFPA 490, last issued in 2002) rather than
the current code, known as NFPA 400.
5)
The existing
fire codes do contain some useful provisions; for example the codes do require
a fire resistant barrier between AN and any stored flammable or combustible materials
and have provisions to avoid AN confinement and promote ventilation during fire
conditions. However, even the most current NFPA 400 standard allows AN
to be stored in wooden buildings and in wooden bins, and does not mandate
automatic sprinkler systems unless more than 2500 tons of AN is being stored –
vastly more than the approximately 30 tons that was sufficient to devastate
much of the town of West. In addition,
the standard contains a “grandfathering” provision that allows existing buildings
that were constructed prior to code adoption – and fail to meet all of its provisions
– to continue in use.
6)
Texas has not adopted a statewide fire
code, and state law actually prohibits most smaller rural counties from
adopting a fire code. McLennan County, where the West facility was located, had
not adopted a fire code, although it technically had the authority to do so
because of its proximity to the more populous Bell County. The West Fertilizer
facility was thus not required to follow any NFPA or ICC recommendations for
the storage of AN.
7)
Although some U.S. distributors have
constructed fire-resistant concrete structures for storing AN, fertilizer
industry officials have reported to the CSB that wooden buildings are still the
norm for the distribution of AN fertilizer across the U.S.
8)
Industry has developed other forms of
ammonium nitrate that are reported to reduce or eliminate the risk of
accidental detonation. For example, compounding the ammonium nitrate with
calcium carbonate (limestone) “practically eliminates any risk of explosion in
its storage, transportation, and handling,” while preserving the AN’s nutritive
value.[2] Calcium ammonium nitrate fertilizers have
been widely used in Europe. Ammonium sulfate
nitrate also has been found to be non-explosive provided the percentage of AN is
held below about 37%.[3]
9)
The federal OSHA standard for
“Explosives and Blasting Agents” (29 CFR 1910.109) does have requirements for
ammonium nitrate fertilizer; its provisions are similar to the NFPA codes.
Unlike the NFPA codes – which West was not legally required to follow under any
fire code – the OSHA standard would have applied. Like NFPA, however, the OSHA standard does not
prohibit wooden bins or wooden construction, and does not require sprinklers
unless more than 2500 tons of AN is present. However, OSHA public records
indicate that OSHA last inspected the facility in 1985, and no citations were
issued under the “Explosives and Blasting Agents” standard.
10)
OSHA’s Process Safety Management
standard (29 CFR 1910.119) or PSM was adopted in 1992 and is designed to prevent
catastrophic workplace incidents involving highly hazardous chemicals. PSM
requires companies to have a variety of management elements to prevent
catastrophic incidents, such as conducting hazard analyses and developing
emergency plans. Ammonium nitrate is not, however, one of the listed chemicals
that triggers PSM coverage. The PSM standard also contains an exemption for
retail facilities.
11)
The EPA’s Risk Management Program rule
(40 CFR Part 68) or RMP was adopted in 1996 and is designed to prevent catastrophic
offsite and environmental damage from extremely hazardous substances. As the
name suggests, the rule requires covered facilities to develop a Risk
Management Plan, implement various safety programs, and analyze offsite
consequences from potential accidents. Once again, however, ammonium nitrate is
not one of the listed chemicals that triggers RMP coverage. West Fertilizer was
RMP-covered due to its stored ammonia, and the company’s offsite consequence
analysis considered only the possibility of an ammonia leak, not an explosion
of ammonium nitrate.
12)
OSHA considered adding ammonium nitrate
along with other highly reactive chemicals to its list of PSM-covered
substances in the late 1990’s. However, this proposal was shelved in 2001. In
developing the RMP regulation, the EPA did not explicitly include explosives or
reactive chemicals in the list of covered chemicals. In 2002, the CSB issued a
study on reactive hazards, identifying 167 prior reactive incidents (including
a 1994 explosion at an ammonium nitrate manufacturer). The Board recommended
that both OSHA and EPA expand their standards to include reactive chemicals and
hazards. However, neither agency has yet
acted upon the recommendations.
13)
No federal, state, or local standards
have been identified that restrict the siting of ammonium nitrate storage
facilities in the vicinity of homes, schools, businesses, and health care
facilities. In West, Texas, there were hundreds of such buildings within a mile
radius, which were exposed to serious or life-threatening hazards when the explosion
occurred on April 17.
14)
West volunteer firefighters were not
made aware of the explosion hazard from the AN stored at West Fertilizer, and
were caught in harm’s way when the blast occurred. NFPA recommends that firefighters evacuate
from AN fires of “massive and uncontrollable proportions.” Federal DOT guidance
contained in the Emergency Response Guidebook, which is widely used by
firefighters, suggests fighting even large ammonium nitrate fertilizer fires by
“flood[ing] the area with water from a distance.” However, the response
guidance appears to be vague since terms such as “massive,” “uncontrollable,”
“large,” and “distance” are not clearly defined. All of these provisions should
be reviewed and harmonized in light of the West disaster to ensure that
firefighters are adequately protected and are not put into danger protecting
property alone.
15)
While U.S. standards for ammonium
nitrate have apparently remained static for decades, other countries have more
rigorous standards covering both storage and siting of nearby buildings. For
example, the U.K.’s Health and Safety Executive states in guidance dating to
1996 that “ammonium nitrate should normally be stored in single story, dedicated,
well-ventilated buildings that are constructed from materials that will not
burn, such as concrete, bricks or steel.”[4]
The U.K. guidance calls for storage bays “constructed of a material that does
not burn, preferably concrete.”
16)
CF Industries, a principal manufacturer
of AN that was one of the suppliers to West, also recommends more rigorous
safeguards in its Material Safety Data Sheet (MSDS) for the chemical. In the
section entitled “Handling and Storage,” CF recommends that “Storage
construction should be of non-combustible materials and preferably equipped with
an automatic sprinkler system.”[5]
Although companies are required to issue
MSDS’s, the recipients of this information like West Fertilizer are not
obligated to follow the recommended safety precautions. West lacked these
safeguards.
17)
The Bureau of Alcohol, Tobacco,
Firearms, and Explosives (ATF) has regulations for ammonium nitrate used as an
explosive but these do not apply to ammonium nitrate used as fertilizer. The
U.S. Department of Homeland Security has reporting requirements for companies
that have a threshold amount of fertilizer grade ammonium nitrate. However, the
authority of DHS is to require security measures to protect against theft,
diversion, or other intentional acts; DHS does not regulate the safety of ammonium
nitrate to prevent conditions leading to accidental detonation.
18)
The Emergency
Planning and Community Right-to-Know Act of 1986 (EPCRA) contains an exemption
from hazardous chemical reporting for “fertilizer held for sale by a retailer
to the ultimate customer.” The EPA has interpreted this provision as not applying
to firms, like West, that make custom blends of bulk fertilizer for customers’ use.
In 2012, West Fertilizer filed an EPCRA Tier II report with the McLennan County
Local Emergency Planning Committee (LEPC). West reported the presence of up to 270
tons of ammonium nitrate, as well as anhydrous ammonia, at the site. The company
did not provide the LEPC or the West Fire Department with an ammonium nitrate
MSDS indicating the material’s hazards, nor does EPCRA automatically require that
information to be provided. There is no indication that West’s filing with
local authorities resulted in an effort to plan for an ammonium nitrate emergency.
The EPA says it has
responded to the executive order by taking part in a Chemical Facility Safety
and Security Working Group comprised of representatives from the EPA,
Department of Homeland Security, OSHA, and other sectors. The group recently
released a preliminary list for improving chemical safety and security options
that is now out for public comment. The options specifically consider the
improvement of risk management practices at chemical facilities as well as the
storage and handling of ammonium nitrate.
“We have engaged
industry to identify hazards and are looking at their existing programs and
activities to see how they can be advanced,” the EPA said in a statement to
NFPA Journal.
“We have also heard
from local emergency responders. They have important needs such as
preparedness, capacity preparedness, and ready access to critical information
that needs to be addressed.”
Similar Chemical Explosions
The ammonium nitrate is known to be an explosive material, and we got a taste of its explosiveness in 1947 in Texas City. The Texas City disaster was an industrial accident that occurred April 16, 1947 in the Port of Texas City. It was the deadliest industrial accident in U.S. history, and one of the largest non-nuclear explosions. Originating with a mid-morning fire on board the French-registered vessel SS Grandcamp (docked in the port), its cargo of approximately 2,300 tons (approximately 2,100 metric tons) of ammonium nitrate detonated, with the initial blast and subsequent chain-reaction of further fires and explosions in other ships and nearby oil-storage facilities killing at least 581 people, including all but one member of the Texas City fire department. The disaster triggered the first ever class action lawsuit against the United States government, under the then-recently enacted Federal Tort Claims Act (FTCA), on behalf of 8,485 victims.
Other chemical plant explosions in recent years include:
· T2 Laboratories explosion in Jacksonville, Florida in December 19, 2007. See http://www.csb.gov/assets/1/19/T2_Final_Copy_9_17_09.pdf
· Sythron Chemical Facility Explosion, North Carolina January 31, 2006. See http://www.csb.gov/assets/1/19/Synthron_Final_Report1.pdf
· MFG Chemical Inc. Toxic Gas Release, in Dalton, Georgia, August 12, 2004. See http://www.csb.gov/assets/1/19/MFG_Report.pdf
The Role of Insurers
We recommended many years ago that the safety and reporting rules are expanded to include reactive chemicals and hazards; but nothing ever happened – then the West Texas disaster hits us. With the proposed construction of several new fertilizer plants across the United States, we believe that safety rules are urgently needed.
The insurers can
play a key role in helping preventing similar disasters. According to Allianz, the insurers took a
$200 million hit as a result of the explosion.
Considering that there are 13,000 thousands of these plants across the United
States and additional plants are being proposed to take advantage of the oil
boom in the states, there is significant risk posed by fertilizer plant
explosions.
In most developed
countries, including the United States, insurance is one of the principal risk
management instruments, not only for aiding in recovery after a disaster, but
also for encouraging future investments that are more resilient to potential
hazards. We always had an issue with
these “grandfathered” facilities, like the one at West, Texas that are not
compliant with the NFPA code or other fire codes. Compliance with the regulations does not
always mean that it is safe or that it follows the modern or proper safety
procedures. How come not a single
insurer realized the risk by this plant and the thousands of other plants across
the United States? The insurers can find
a way of forcing them to install the appropriate safeties and controls to at
least prevent the risk of explosions and the carnage to human life.
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[1] NFPA 400 refers users to a 1953 publication by the U.S.
Bureau of Mines for information on the explosive properties of AN.
[2]
Calcium ammonium nitrate (CAN) must still be protected from
contamination with other chemicals that can re-sensitize it to detonation. See
Popovici Ipochim, N.N.; Icechim, M.M.; “Other Ammonium Nitrate Fertilizers;” In
Keleti, C. (ed.); Nitric Acid and Fertilizer Nitrates; New York: Marcel
Dekker Inc., 1985.
[3]
Ibid.
[4] U.K. Health and Safety Executive; “Storing and Handling
Ammonium Nitrate;” Available from http://www.hse.gov.uk/pubns/indg230.pdf