Curious:
Basing myself on prior incidents and the reaction time taken by the CSB to make their formal reports, I would not expect any official report from them until after a year has passed. This is one of the regrettable and typical efficiency features of all government agencies everywhere I’ve been in the past 53 years.
However, the preliminary “findings” already is pointing to typical governmental incompetence, bungling, failures, and lack of updating, accurately describing the hazards involved, and applying the correct safety procedures. Obviously, this is contributing to the ultimate issuance of the Final Report – which I suspect will have to be carefully edited and “word-smithed” to avoid burning or blaming any government safety agency or individual. It’s called protecting your backside. For example, I cite and quote the following (note the script in bold):
- “Many of these safety provisions are quite old 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.”
- “..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 2,500 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.”
- “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.”
- “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 2,500 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.”
- “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 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.”
- “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.”
- “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.”
- “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.”
- “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.”
These findings, albeit “preliminary”, already point to the government’s failure to protect the public due to either stupidity, incompetence or lack of interest. Additionally, you will note that this report itself contains its own degree of technical incompetence or ignorance: “large amounts of potentially flammable anhydrous ammonia were stored along the southern edge of the warehouse building". Any experienced chemical engineer knows that anhydrous ammonia WILL NOT BURN on its own. The ammonia did not contribute to the fire. It will burn while being incinerated by another fuel, but there has never been any report or experimental results attesting to pure ammonia burning like a fuel. Therefore, even this finding shows the effect of the incompetence and ignorance of typical governmental agencies when they attempt to show knowledge and credibility in the chemical processing industry.
In addition to the above, nothing has been written as to what is commonly already known here in Texas: a local firefighter was suspected and investigated for allegedly setting the fire intentionally. I have heard nothing more about this topic that surfaced weeks after the incident. What I do know as factual is that the small fertilizer facility was installed when there were no houses or human population in the immediate area. As in most of these incidents where people are hurt, the population density around the complex increased on its own for whatever reason. Real estate developers apparently were not aware of the potential hazards or didn’t care. But for whatever reason, as chemical engineers we should be aware of the public’s ignorance (especially the governments’) and always take these facts into consideration when planning and operating a chemical plant installation or facility.
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West Fertilizer Fire & Explosion.docx 1.69MB
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