Questions Still Unanswered about Ammonium Nitrate

Texans need a measured approach to hazardous materials as the state continues to recover from the devastation witnessed in the April 17, 2013, West Fertilizer Company storage and distribution facility explosion in West, TX. The explosion, fueled by ammonium nitrate (AN), killed 15 people, injured more than 160, and damaged or destroyed more than 500 buildings.

Strangely enough, large fires at two other Texas fertilizer facilities handing AN – Bryan’s El Dorado Chemical in July 2009 and Athen’s East Texas Ag Supply in May 2014 – did not result in explosions Not enough research, regulatory examination, responder training or public meetings were conducted following the El Dorado Chemical Facility to help prevent the loss of responders that happened at West. But questions still need to be addressed by the chemical industry about what made the difference between chemicals stored in each of these Texas facilities:

• What was the volume of ammonium nitrate with associated surface area?

• What was the ventilation of the facility?

• What was the facility temperature at the time of initial reaction and when fire/smoke was noted?

• Who was the manufacturer of the ammonium nitrate?

• What was the concentration/quality percentage of ammonium nitrate shipped and stored onsite?

• Was the ammonium nitrate further mixed/enriched onsite?

Answers could ensure that no Texas citizen live in fear that this tragedy occur in their backyards. Based on the volume of chemicals manufactured, usage, storage and shipment of chemicals the Texas chemical industry has a good track record. However, this incident is cause to reexamine our laws and emergency management practices.

Texas is a business friendly environment that strives to balance the safety needs of its citizens and industry. There are measureable emergency management activities that can be implemented to:

• Ensure public safety,

• Ensure responder safety,

• Minimize environmental impact, and

• Minimize property loss.

This document is an attempt to examine preventative/mitigation measures regarding existing and future chemical facilities. Three of the 15 West, TX deaths were living close to the chemical facility. West and the state of Texas failed to consider the “worst case scenario” in allowing construction near the chemical facility without an adequate buffer zone. This document also addresses actionable information associated with responders.

The majority of responders in Texas are volunteer firefighters. Twelve of the 15 deaths associated with the West explosion were volunteer firefighters. These responder losses can be directly attributed to the lack of:

• Regulatory laws and codes - proximity to urban areas, inspections, reportable quantity, etc.,

• Facility plans and relevant local hazardous material response plans,

• Responder personal protective equipment,

• Hazardous Material response training for volunteer firefighters, and

• Drills / exercises.

Texas Government Code 418 requires each Chief Elected Official and their appointed leaders to ensure that necessary and appropriate actions are taken to protect people and property from any threat or hazard. When threatened, Texas citizens expect elected or appointed leaders to take immediate action to resolve the problem. Citizens expect their government to marshal its resources, channel the efforts of the whole community—including voluntary organizations and the private sector—and, if necessary, solicit assistance from outside the jurisdiction. Emergency management generally refers to activities associated with avoiding and responding to natural and manmade hazards. In examining “what” Texas can do to prevent another West our approach is to use the four phases of emergency to move our state forward: prevention/mitigation, preparedness, response and recovery.

Prevention / Mitigation    New Chemical Facilities

• All facilities must be permitted for allowable quantities of ammonium nitrate and Threshold Planning quantities of extremely hazardous substances.

• Facilities storing reportable quantities of ammonium nitrate and Threshold Planning Quantities of extremely hazardous substances must not be built within safe distance limits (1/3 mile, 1/2 mile and 1 mile) or stored in proximity to populated areas or existing structures, thereby providing a buffer zone. The distance is based on the volume of the material the facility is regulated to store and the ascribed distance is from the facility fence to the nearest structure. Once the facility has been constructed no new public, residential, or commercial buildings may be constructed within the designated distance based on the volume of the material stored.  Cities/counties must establish codes to enforce that restriction.

• Storage of chemicals within the facility must be separated in accordance with state, federal, and industry standards.

• Automatic water sprinklers to extinguish/contain fire on non-water reactive materials.

• Water hydrant - water supply availability within 100ft of the facility.

• Runoff and drain to an outside of building collection/retention area, a minimum of 100ft from existing facility structures. 

• Facilities must have a designated, qualified emergency / safety manager onsite during normal working hours.

• Facilities must have a qualified security person on duty after work hours to provide notification of any facility related incident.

• Facility emergency / safety manger must keep an updated binder containing hard copies of Material Safety Data Sheets for each chemical stored within each facility building.

• Each facility building should be placarded with temporary signage, so that it can updated daily to provide a visual of what materials are stored within each facility building. The signs should be located next to each building entrance and exit wherein chemicals are stored.

• Display placards/signage on the facility fence and exits. Each facility should be placarded with temporary signage, so that signage may be updated daily to provide a visual of what materials are stored within the facility.

• Display an unobstructed wind sock so that responders can readily determine wind direction.

• Harden building(s) up to the maximum height of materials that will be stored that may present an explosive hazard. This preventive measure is designed to deflect an explosive hazard vertically should a reaction occur.

• Earthen berms will be built inside the facility fence to the height of the building, paralleling the long sides of the building storing explosive hazards at no less than a 45o angle to deflect explosive hazards vertically.

• Ensure storage bins are made of noncombustible materials. The bins storing corrosive materials may need to be sprayed with sealants to coat and prevent degradation of the storage bin.

• Automatic smoke / fire and security alarms that immediately notify 911.

• Portable / hand-held fire extinguishers for hazard specify chemicals stored in proximity to those chemicals.

• Conduct annual facility inspections. Develop chemical facility checklist cased upon state, federal and industry standards.  Facilities not in compliance with permitted standards will be fined and subject to cessation of all operations.

• Determine Reportable Quantities and Threshold Planning Quantities of extremely hazardous substances for Texas chemical facilities using 40 CFR Part 355, Appendix A as guidance.

• Facilities will have an emergency siren to notify facility employees and the public when the automated smoke/fire alarms and sprinkler systems are activated. 

Existing Chemical Facilities (Grandfathered or Retrofitted)

• Existing facilities must not allow buildings to be constructed within a half mile/800 meters of their fence line, thereby providing a buffer zone.  Cities/counties must establish codes to enforce that restriction. 

• Storage of chemicals within the facility must be separated in accordance with state, federal, and industry standards.

• Water supply or water tankers must be available to responding fire departments.

• Facilities must have a designated, qualified emergency / safety manager onsite during normal working hours.

• Facilities must have a qualified security person on duty after work hours to provide notification of any facility related incident.

• Earthen berms will be built inside the facility fence to the height of the building, paralleling the long sides of the building storing explosive hazards at no less than a 45o angle to deflect explosive hazards vertically.

• Facility emergency / safety manger must keep an updated binder containing hard copies of Material Safety Data Sheets (MSDSs) for each chemical stored within each facility building.

• Each facility building should be placarded with temporary signage, so that it can updated daily to provide a visual of what materials are stored within each facility building. The signs should be located next to each building entrance and exit wherein chemicals are stored.

• Display placards/signage on the facility fence entrance and exits. Each facility should be placarded with temporary signage, so that signage may be updated daily to provide a visual of what materials are stored within the facility.

• Ensure storage bins are made of noncombustible materials. The bins storing corrosive materials may need to be sprayed with sealants to coat and prevent degradation of the storage bin.

• Display an unobstructed wind sock so that responders can readily determine wind direction.

• Smoke / fire alarms every 20ft within each facility building.

• Facilities will have an emergency siren to notify facility employees and the public when the smoke/fire alarms are activated. The facility emergency /safety manager

will need to be able activate the siren 24/7.

• Portable / hand-held fire extinguishers for hazard specify chemicals stored in proximity to those chemicals.

• Conduct annual facility inspections. Develop chemical facility checklist cased upon state, federal and industry standards.  Facilities not in compliance with permitted standards will be fined and subject to cessation of all operations.

• Determine Reportable Quantities and Threshold Planning Quantities of extremely hazardous substances for Texas chemical facilities using 40 CFR Part 355, Appendix A as guidance.

Preparedness Planning

• Facility emergency response plan or emergency operations plan specific to local and facility hazards; natural and manmade hazards.

• Facility emergency response plan or emergency operations plan will be connected with the county/city emergency operations plan.

• Notification of county/city emergency management coordinator within 24hrs of arrival of chemicals to be stored that the State of Texas has determined to be a Reportable Quantities or having reached the  Threshold Planning Quantities of extremely hazardous substances.

• Notification of county/city emergency management coordinator within 24hrs when chemicals stored at the facility no longer meet the Reportable Quantities or the Threshold Planning Quantities of extremely hazardous substances as determined by the State of Texas.

• County/city emergency management coordinator will ensure that fire departments that would respond to an emergency call associate with the facility are aware of changes facility Reportable Quantities or the Threshold Planning Quantities of extremely hazardous substances as determined by the State of Texas. 

• Facility emergency / safety manager will provide the county/city emergency management coordinator with a duplicate copy of the facility MSDS binder. Facility MSDS copies will be provided to the county/city emergency management coordinator within 24hrs of arrival of a new chemical arriving to be stored at a facility.

• Facility MSDS copies provided to the county/city emergency management coordinator who will in turn provide copies to the departments responsible for responding to the facility.

• County/city emergency management coordinator will develop and conduct Local Emergency Planning Committee (LEPC) meetings quarterly.

• Facility emergency / safety manager will participate quarterly in the LEPC meetings with the county/city emergency management coordinator, responders and other entities.

• Ensure current Emergency Response Guide (ERG) is available to all responders; the ERG should be in every response vehicle.

• Texas Division of Emergency Management needs to rewrite Annex Q Hazardous Materials and Oil Response using a subject matter hazardous material response expert. The Annex has the most senior firefighter assuming command as the incident commander, this is not in accordance with NIMS/ICS principles. The practice is the most qualified person after the initial response will be the incident commander. The Annex is a template that does not differentiate between volunteer and paid departments, rural or metropolitan areas, available capabilities/resources and a general lack of local specificity.

• Ensure that facility related hazards are referenced within the county/city emergency operations plan and hazard mitigation plan.

Training

• Develop and make available hazardous material response courses (awareness and operations level courses) that are a mixture of blended learning; online and face-to-face training. Training has to be available 24/7 to accommodate volunteer and paid responders.

• ICS training must move beyond being NIMS compliant.  It must be scenario based to engage application of practices and decision making in potential incidents found in their community.

• Facilities must conduct and ensure that each employee has received hazardous material awareness level training. Refresher hazardous material awareness level training will be held every two years. Participant sign-in rosters are required.

• Facilities must conduct and ensure that each employee has received training on their facility specific emergency response plan or emergency operations plan. Refresher facility specific emergency response plan or emergency operations plan training will be held every two years. Participant sign-in rosters are required.

• Facility must have a minimum of one employee who has been certified hazardous material operations level onsite during hours of operation.

• Facility must have an existing contract with a hazardous material response/cleanup team. This team must be available 24/7.

• Volunteer fire departments will ensure that all personnel have received hazardous material awareness level training. Refresher hazardous material awareness level training will be held every two years. Participant sign-in rosters are required to be signed by the Fire Chief.

• Volunteer fire departments having 10 active members or more will have and maintain a certified two man team at the hazardous material operations level with appropriate personal protective equipment. Copies of certificates will maintained by the Fire Chief.

• Provide every responder training on how to use the current Emergency Response Guide (ERG); the ERG should be in every response vehicle.

• Volunteer fire departments will ensure that all personnel receive scene size-up, decision-making and application training (difference between online and performance).

• County/city emergency management coordinators must conduct and ensure that all responders identified within ANNEX Q Hazardous Material and Oil Spill Response are aware of their roles and responsibilities. Refresher training will be held every two years. Participant sign-in rosters are required.

Drills/Exercises

• Facility will conduct annual drills to include fire, evacuation, notification, severe weather, etc., and involve local emergency responders.

• Facility emergency / safety mangers will participate in county/city exercise planning team meetings and every three years as a part of a county/city exercises.

Response

• Facility will immediately notify 911 and county/city emergency management coordinator when a hazardous material incident has occurred.

• County/city emergency management coordinator will immediately notify the Disaster District Chair or the District Coordinator when a facility hazardous material incident has occurred.

• Facility emergency /safety manager or representative will meet the first responding agency at the facility entrance and provide them a copy of the facility MSDS binder, describe chemical hazard, building(s) involved, types and quantities of chemicals, and facility responses are associated with the incident.

• Develop response priorities based upon specific hazards associated with chemicals stored in facility building. Such as:

 Responder safety,

 Public safety,

 Environmental impact, and

 Property impact.

• Ensure public is notified of a hazardous incident that may or will affect them. Provide guidance to shelter-in place or evacuate, as necessary to ensure public safety.

• When a facility has an explosive hazard, consider responder safety and let the chemical fire burn out when it can be accomplished safely.

• Facility, county/city emergency management coordinator and response agencies will document their responses to the hazardous material incident.

Recovery

• Conduct a thorough after action review that includes the facility and responding agencies.  Information gathered during this review process will be put into a formal after action report; at a minimum provide copies of the report to the facility emergency /safety manager, city/county emergency management coordinator, Texas Division of

Emergency Management, and the Texas Commission on Environmental Quality.

• Ensure facility emergency response plan or emergency operations plan and city/county emergency operations plan is updated based upon after action report corrective actions and lessons-learned.

• Identify and upgrade facility and local hazardous material response capabilities.  

• Update laws and codes necessary to ensure public, responder, environment and property safety.

The aforementioned chemical facility emergency/safety management related requirements are considered reasonable, citizen and business friendly, responder oriented, and cost

effective to maximize safety and minimize risks. 

Costs associated with the identified measures would be minimal for the chemical industry, mainly communication and coordination with local emergency management for existing facilities. The real measureable costs to be taken would be on behalf of the State of Texas’ main response agency, volunteer / career fire departments. Volunteer / career fire departments must have the necessary means and capabilities to respond to hazardous material incidents. Fortunately, when considering the volume of chemicals that are transported, stored and manufactured in the State of Texas, we have a good track record regarding our response to chemical related incidents. Unfortunately, it has taken the lives of 15 Texas citizens to make us aware of our hazards and lack of an appropriate set emergency management steps regarding all aspects of the chemical industry.