West Texas and Ammonium Nitrate: Part 3

Here is what we have been told happened in West Texas

Around 7:30 p.m. on April 17, a fire broke out at the West Chemical and Fertilizer Company plant in West, Texas, a small town of about 2,800 people 75 miles south of Dallas. Twenty minutes later, it blew up."

What happened to put the responders in the area where they could be affected by an explosion -should the ammonium nitrate explode - is not known.

I have been struggling with this post.  I am re-writing this one and will delete the one I wrote after this.  I don't want to point fingers, and that's the direction I was going.  The purpose of this blog is to describe complex issues and situations.  I want to educate not pontificate, retaliate, exasperate  or blab on about my indignation over a situation.

So let me change my tune, and write about what happened so we can maybe all get on board and prevent this type of situation from happening again,

When I give my DOT class on transportation of hazardous materials I tell my students that the DOT method for labeling and marking is "all about communication."  You may know what's in the drum, but the emergency responder or the guy off-loading it does not.  So you tell them.

DOT Training Module 3

I tell all my students to know everything important about the chemicals they may come in contact with.  What is the hazard when it is sitting there nicely and what will it do when it spills or is involved in a fire?  If you don't know, ask, Google it, look it up, read the MSDS/SDS  I give everyone my business card with my phone number and tell them to call me for another set of eyes.  I have done this for years now, because the guy who gets hurt is no longer me, but the person who comes in contact with the hazardous material.

It comes down to communication.  Communication, and the ability to understand what it means, is what protects employees and the community.

Let's go back to 1984 in Bopal India.  That catastrophe brought about a new law called the Emergency Planning and Community Right-to-Know Act - or EPCRA.  Under this law, a business that has on site, more than 10,000 pounds of a hazardous chemical must notify the State Emergency Response Committee (SERC), the Local Emergency Response Committee (LEPC), and the local fire department of the chemicals and amounts they have on their property.

Here is how this communication is designed to protect public health:

• Under the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 311, facilities must submit the same MSDSs they maintain for OSHA to their SERC, LEPC, and local fire department. Or, facilities may choose to submit a detailed list of the same chemicals instead. This is a one-time submittal; facilities have three months after becoming subject to the OSHA regulations to submit their material.
• Facilities that need to submit MSDSs or chemical lists under Section 311, also need to submit an annual inventory report for the same chemicals (EPCRA Section 312). This inventory report must be submitted to the SERC, LEPC and local fire department by March 1 of each year.

Ammonium nitrate is an OSHA hazardous chemical (oxidizer) so the facility was required to tell all three entities that they had up to 540,000 pounds of ammonium nitrate.

Here is how it is done in Texas:

Source

If you look at number 5 you will see that it is the same requirement as the EPA.

You can see why EPCRA is kind of a good idea.  The LEPC and the Local Fire Department are going to be involved if there is an emergency, so, you know, the guys responding would probably like to know what they might be coming up against.  That's the "communication" part of EPCRA.

If notification is made, the LEPC and the FD can then put forth a plan on how they would respond in the event of all types of anticipated emergencies.  They could visit the plant, meet with the plant personnel, understand the unique properties of the chemicals they have.  They could - with this notification - come up with a plan of response BEFORE there was an emergency.  That, by the way, is why it is called a Local Emergency PLANNING Commission.

So...did this notification take place in West Texas?

Here is what KHOU out of Houston writes:

Each business is required to report its hazardous chemicals to its county. West Fertilizer Co. had, in fact reported its ammonium nitrate to McLennan County.

Here is where fingers start getting pointed.  I don't want to do that, but it is inevitable that it will take place.  I am trying to sell the idea of communication and planning, because it works to minimize risk and protect public health.

KHOU writes:

[Steve] Howie heads the Kaufman County LEPC and said he is familiar with the dangers of ammonium nitrate. A fertilizer storage company similar to the one in West is located near downtown Terrell. He says emergency responders in his community are well aware that a fire in the fertilizer storage building means one thing. 

"If it's in the building housing 50,000 pounds of ammonium nitrate we are going to evacuate the area and back off," said Howie.

That's how they do it in Kaufman County.  In the event of a fire at a plant that houses ammonium nitrate, the fire department has been instructed to "back off."

This fire and explosion happened in West Texas, which is in McLennan County.

According to KHOU:

The federally mandated body of community leaders designed to plan for such hazards did not exist in McLennan County. The official listed as the head of the McLennan County LEPC is County Judge Scott Felton. Felton, appointed to the post last year, told News 8 in an interview that he's never heard of the LEPC.

McLennan County Emergency Operations Coordinator Frank Patterson said he has no knowledge of an emergency planning committee or any meetings with officials in West about potential risks in the community. 

It really is all about communication and planning.  Here is what I have, here is what can happen, here is how we should respond in the event of an emergency.  That's how you have domain over a hazardous chemical.  You respect it and give it what it requires.


Next post: West Texas and Ammonium Nitrate: Part 4

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