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Arkema Inc. Chemical Plant Fire

Overview

Hurricane Harvey flooding at the Arkema Crosby facility disabled electrical power and critical cooling safeguards for refrigerated organic peroxide storage. As temperatures rose, organic peroxide products decomposed and burned in refrigerated trailers. Multiple fires occurred. Emergency responders were exposed. A public evacuation zone was established. Nearby residents were evacuated for an extended period.

Incident Snapshot

Field Value
Facility / Company Arkema Inc.
Location Crosby, TX
Incident Date August 31, 2017
Investigation Status The CSB's final investigation report was released on May 24, 2018.
Accident Type Chemical Manufacturing - Fire and Explosion Investigation
Final Report Release Date May 24, 2018

What Happened

  • August 24, 2017: Hurricane Harvey made landfall in southeast Texas.
  • August 25, 2017: Arkema halted production and began storm preparations.
  • August 27, 2017: Significant flooding occurred. Workers began moving organic peroxide products into refrigerated trailers.
  • Around 2:00 am on August 28, 2017: Floodwater reached the main power transformers and the facility lost power.
  • Backup generators turned on automatically, but rising floodwater forced workers to turn them off for safety.
  • By August 29, 2017: Arkema requested evacuation of the ride-out crew. Emergency responders established a 1.5-mile evacuation zone.
  • Starting August 30, 2017: Arkema provided telemetry data showing increasing trailer temperatures and temperatures above estimated SADTs in some trailers.
  • Around midnight on August 30, 2017: White smoke was reported coming from the facility. Highway 90 was shut down, then reopened based on lack of visual confirmation and telemetry data.
  • Around 2:00 am on August 31, 2017: The first refrigerated trailer decomposed to the point of combustion and caught fire.
  • September 1, 2017: Two more refrigerated trailers ignited and burned.
  • September 3, 2017: Emergency responders conducted a controlled burn of the remaining six refrigerated trailers.
  • September 4, 2017: The evacuation zone was lifted and residents were allowed to return home.

Facility and Process Context

  • The Arkema Crosby facility produced about 30 different types of organic peroxide products.
  • The facility had nine organic peroxide storage buildings, including seven Low Temperature Warehouses maintained between -20 °F and 0 °F.
  • The facility used seven diesel-powered emergency generators, a liquid nitrogen system, and refrigerated truck trailers as backup cooling and storage.
  • The facility was located within the 100-year and 500-year flood plain, and the entire site was within a floodplain according to the June 2007 Flood Insurance Rate Map.
  • The facility had a hurricane preparedness plan and an Emergency Response Plan.
  • Arkema's most recent process hazard analysis for organic peroxide storage at the Crosby facility was completed in November 2013.
  • Arkema modified its corporate PHA policy in 2014 to require identification and evaluation of natural hazards such as flooding.
  • The facility had a history of flooding over the past 40 years.

Consequences

  • Fatalities: No fatalities were explicitly reported in the provided source extracts.
  • Injuries: Twenty-one emergency responders sought medical attention from exposure to fumes generated by the decomposing products. Three police officers reported symptoms including nausea, headaches, sore throat, and itchy watering eyes.
  • Environmental release: The report states that no organic peroxides or their likely decomposition products were detected in EPA surface water samples, and no sulfur dioxide was released during the incident. Arkema reported the release of approximately 23,000 pounds of organic material into the floodwater.
  • Facility damage: The first trailer burned, followed by two more fires and a controlled burn that consumed eight remaining trailers. In excess of 350,000 pounds of organic peroxide combusted.
  • Operational impact: The facility lost power, backup power, and critical organic peroxide refrigeration systems. All Arkema employees evacuated. A 1.5-mile public evacuation zone was established. More than 200 residents within 1.5 miles could not return home for a week. Highway 90 was closed and later reopened after the all-clear on September 4, 2017.

Key Findings

Immediate Causes

  • Flooding caused the facility to lose electrical power.
  • The loss of electrical power caused loss of cooling capability for the Low Temperature Warehouses.
  • Loss of cooling capability led to decomposition and combustion of organic peroxide products.
  • Organic peroxide products stored inside a refrigerated trailer decomposed, causing the peroxides and the trailer to burn.

Contributing Factors

  • Extensive flooding caused by heavy rainfall from Hurricane Harvey exceeded the equipment design elevations.
  • The same floodwater that caused the facility to lose electrical power also compromised the emergency generators, liquid nitrogen system, and refrigerated trailers used to temporarily store the organic peroxide products.
  • The ride-out crew could not move the refrigerated trailers to higher elevation in the facility.
  • The refrigerated trailer that likely generated the vapor cloud did not have telemetry data capability.
  • Telemetry data measured air temperature inside the trailer and not the temperature of the organic peroxide products.
  • Emergency response officials initially decided to keep Highway 90 open because it served as an important route for hurricane recovery efforts.
  • Emergency response officials reopened Highway 90 based on lack of visual confirmation of decomposition and telemetry data indicating that no decomposition should be occurring.

Organizational and Systemic Factors

  • The Arkema team that performed the Low Temperature Warehouse PHA for the Crosby facility did not document any flooding risk.
  • Arkema did not incorporate the 2007 FEMA flood information into its process safety management systems and did not evaluate the potential flood risks.
  • Arkema’s Emergency Response Plan did not identify the possibility that flooding could lead to a loss of electric power, the subsequent loss of refrigeration capability, and the resulting decomposition of organic peroxide products.
  • None of Arkema's safeguards used to address electrical power failure met company or industry standards for analyzing independent protection layers for Harvey-level flooding.
  • Arkema did not consider flooding of its safety systems to be a credible risk.
  • Arkema’s process hazard analysis and corporate policies did not document flooding risk for the Low Temperature Warehouses.
  • Arkema’s insurer, FM Global, identified flood risks to the Crosby facility, but facility employees other than a past facility manager appeared to be unaware of this information.
  • The PSM standard does not contain an express regulatory requirement for companies to consider flood insurance maps and related studies as process safety information or to consider flood risk or flood hazards in their PHAs or facility siting reviews.
  • Arkema’s internal guidance on layers of protection does not allow safeguards to be considered as independent protection layers if the initiating event can prevent the safeguard from performing its safety function.

Failed Safeguards or Barrier Breakdowns

  • redundant refrigeration systems in the Low Temperature Warehouses
  • emergency generators to provide power in case a Low Temperature Warehouse lost power
  • liquid nitrogen for alternative cooling
  • refrigerated trailers to store organic peroxide temporarily
  • backup emergency generators
  • the liquid nitrogen system
  • the refrigerated trailers used to temporarily house the organic peroxide products

Recommendations

  1. 2017-08-I-TX-R1 | Recipient: Arkema Crosby facility | Status: Closed – Acceptable Action | Summary: Reduce flood risk to as low as reasonably practicable (ALARP). Ensure that any safeguards for flooding meet independent layer of protection requirements.
  2. 2017-08-I-TX-R2 | Recipient: Arkema Inc. | Status: Closed - Acceptable Action | Summary: Within 18 months, develop a policy requiring that Arkema and its subsidiaries that manufacture organic peroxides or that have processes which involve more than the threshold quantities of highly hazardous chemicals (HHC) periodically (corresponding with PHA cycle), analyze such facilities to determine whether they are at risk for extreme weather events such as hurricanes or floods.
  3. 2017-08-I-TX-R3 | Recipient: Arkema, Inc. | Status: Closed - Acceptable Action | Summary: Establish corporate requirements for its facilities that manufacture organic peroxides or that have processes which involve more than the threshold quantities of highly hazardous chemicals (HHC) to ensure that critical safeguards, such as backup power, function as intended during extreme weather events, including hurricanes or floods.
  4. 2017-08-I-TX-R4 | Recipient: Center for Chemical Process Safety (CCPS) | Status: Closed – Acceptable Action | Summary: Develop broad and comprehensive guidance to help companies assess their U.S. facility risk from all types of potential extreme weather events, including common mode failures of critical safeguards, sufficient independent layers of protection for flooding scenarios, incorporation of relevant safety information such as flood maps as process safety information, and involvement of relevant professional disciplines.
  5. 2017-08-I-TX-R5 | Recipient: Harris County, Texas | Status: Closed – Acceptable Action | Summary: Update emergency operations training to help ensure that personnel enforcing evacuation perimeters are not harmed by exposure to hazardous chemical releases, including use of analytical tools, air monitoring, personal protective equipment, and periodic refresher training.

Key Engineering Lessons

  • Flood risk must be evaluated as part of process hazard analysis and process safety information for facilities whose safeguards can be disabled by flooding.
  • Critical safeguards should not rely on multiple systems that can all fail from the same floodwater common mode failure.
  • Backup power, alternative cooling, and temporary storage systems must remain functional under the credible extreme weather conditions for the site.
  • Telemetry or monitoring data that measures only air temperature may not be sufficient to determine the condition of temperature-sensitive reactive materials.
  • Emergency response decisions about roadway access should account for the possibility of ongoing decomposition and release when visual confirmation is lacking.

Source Notes

  • Priority 1 final report findings were used to resolve conflicts and populate the authoritative incident record.
  • Spanish executive summary and English final report were both treated as final report sources. The English final report was used where it provided more specific detail.
  • Recommendation status change summaries were used only for recommendation status updates and later corrective action details.
  • No fatalities were explicitly reported for the Arkema Crosby incident in the provided source extracts.

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