There was a significant lack of guidance in planning for flooding or other severe weather events in the Arkema chemical plant fire in Crosby, TX, after Hurricane Harvey, was a finding by the U.S. Chemical Safety Board (CSB).
In the days leading up to the August 31 incident at the Arkema plant, an unprecedented amount of rain fell at the plant due to Hurricane Harvey, causing equipment to flood and fail. As a result, chemicals stored at the plant decomposed and burned, releasing fumes and smoke into the air.
“Our investigation found that there is a significant lack of guidance in planning for flooding or other severe weather events,” said CSB Chairperson Vanessa Allen Sutherland. “Based on other government reports, we know that there is a greater likelihood of more severe weather across the country. As we prepare for this year’s hurricane season, it is critical that industry better understand the safety hazards posed by extreme weather events.”
The Arkema chemical plant manufactures and distributes organic peroxides used to produce consumer goods such as solid surface countertops and polystyrene cups and plates. Some of the organic peroxides produced at the plant must be kept below 32 degrees Fahrenheit to prevent them from decomposing and catching fire. Under normal operation, the organic peroxides are stored in low temperature warehouses and shipped in refrigerated trailers.
Extensive flooding caused by heavy rainfall from Hurricane Harvey caused the plant to lose power and backup power to all of the low temperature warehouses. Workers at the Arkema facility, called the ride out team, moved the organic peroxides from the warehouses to refrigerated trailers, which were then relocated to a high elevation area of the plant. Three of those trailers, however, were unable to be moved and eventually flooded and failed. With refrigeration on those trailers lost, there was nothing to stop the chemicals inside from heating up and catching fire.
All Arkema employees evacuated from the facility and more than 200 residents living nearby the facility were evacuated and could not return home for a week. Twenty-one people sought medical attention from reported exposures to the fumes and smoke released into the air.
In its final report, the CSB called for more robust industry guidance to help hazardous chemical facilities better prepare for extreme weather events, like flooding, so similar incidents can be avoided.
The key lessons for companies within areas that are susceptible to extreme weather include:
1. Facilities should perform an analysis to determine susceptibility to potential extreme natural events – such as flooding, earthquakes, and high winds
2. When conducting analyses of process hazards, or facility siting, companies should evaluate the potential risk of extreme weather events and the adequacy of safeguards
3. When evaluating and mitigating the risk from extreme weather events facilities should strive to apply a sufficiently conservative risk management approach
4. If flooding is the risk, facilities must ensure that critical safeguards and equipment are not susceptible to failure by a common cause and that independent layers of protection are available in the event of high water levels
It turns out, Arkema’s insurance company had warned about the extreme flood hazard at its Crosby facility roughly one year before Harvey hit. “Although a September 2016 report from Arkema’s insurer, FM Global, identified flood risks to the Crosby facility, including these floodplain designations, Arkema Crosby facility employees, other than a past facility manager, appeared to be unaware of this information,” the CSB said in its report.
Although U.S. federal process safety rules require companies to compile relevant process safety information, the CSB said current regulations do not specifically identify flood insurance maps and related studies as required process safety information. The agency cautioned that other chemical companies also might be unaware of the potential for flood risks to create process safety hazards at their facilities.
Beyond its call for new industry guidance, the CSB report also urged the Environmental Protection Agency (EPA) to tighten its regulations to explicitly cover catastrophic reactive hazards that can potentially seriously impact the public, including those resulting from self-reactive chemicals and combinations of chemicals.
“Considering that extreme weather events are likely to increase in number and severity, the chemical industry must be prepared for worst case scenarios at their facilities,” Sutherland said. “We cannot stop the storms, but working together, we can mitigate the damage and avoid a future catastrophic incident.”