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Bio-Lab Lake Charles Chemical Fire and Release

Overview

On August 27, 2020, Hurricane Laura damaged buildings at Bio-Lab's Lake Charles facility in Westlake, Louisiana. Rainwater contacted stored trichloroisocyanuric acid (TCCA), initiating decomposition that released toxic chlorine gas and caused a fire. The incident led to a shelter-in-place order and a closure of a portion of Interstate 10 for over 28 hours. No injuries were reported.

Incident Snapshot

Field Value
Facility / Company Bio-Lab, Inc.
Location Westlake, LA
Incident Date 2020-08-27
Investigation Status The CSB's investigation was released on April 24, 2023.
Accident Type Reactive Incident
Final Report Release Date 2023-04-24

What Happened

  • On August 24, 2020, Bio-Lab began shutting down its Lake Charles operations using its Hurricane Plan.
  • On August 25, 2020, nine employees assigned to the Bio-Lab Hurricane Crew reported to the facility around 5:00 p.m. and raised TCCA-based formulation above floor level by placing the material on triple-stacked pallets.
  • On August 26, 2020, at approximately 7:00 a.m., Bio-Lab management announced its decision to evacuate the facility due to the approaching hurricane’s strength; at approximately 9:30 a.m., all employees left the facility after completing a final walk-around.
  • Around 1:00 a.m. on August 27, 2020, Hurricane Laura made landfall in Cameron as a Category 4 hurricane.
  • On August 27, 2020, winds from Hurricane Laura caused portions of the roof of Bio-Lab Plant 4 to be torn off the building.
  • By 8:30 a.m. on August 27, 2020, rainwater from Hurricane Laura had contacted the TCCA-based formulation material in Plant 4, initiating a reaction that led to a decomposition that released toxic chlorine gas and caused a fire.
  • At approximately 8:32 a.m., the Calcasieu Parish Communications District E911 received its first report of the release.
  • Around 8:54 a.m., the Louisiana State Police spoke with a Bio-Lab representative, who confirmed the release was likely chlorine vapors resulting from the decomposing product.
  • At approximately 9:00 a.m., two Bio-Lab employees entered the facility and attempted to obtain SCBAs and assess the situation.
  • At approximately 11:03 a.m., the Lake Charles Fire Department arrived at the facility.
  • Around 12:09 p.m., emergency responders entered the facility wearing personal protective equipment.
  • By approximately 3:21 p.m., US Fire Pump was on-site and flowing fire water to Plant 4.
  • At approximately 5:30 p.m., a first responder observed a white cloud emitting from the Finished Goods Warehouse, which had also been severely damaged by Hurricane Laura.
  • At 7:30 a.m. on August 28, 2020, the vapors emitting from the facility were considerably reduced and determined to be controlled.
  • On August 28, 2020, at approximately 2:30 p.m., the incident was sufficiently controlled, Interstate 10 was reopened after it had been closed for 28 hours, and the shelter-in-place order was lifted.

Facility and Process Context

  • Bio-Lab, Inc. is a KIK Custom Products subsidiary that manufactures and supplies pool and spa chemicals, including chlorinated isocyanurates.
  • The Bio-Lab Lake Charles facility was built in the late 1970s by Olin Chemical Corporation in Westlake, Louisiana.
  • At the time of the incident, Bio-Lab had 111 employees.
  • Plant 4 held an estimated 70,000 to 100,000 pounds of TCCA-based formulation.
  • The Finished Goods Warehouse held over one million pounds of TCCA-based formulation inventory.
  • The facility was one of approximately 37 industrial chemical/petrochemical facilities in the Cameron/Lake Charles, Louisiana area.
  • There were over 10,000 people residing in over 4,000 housing units within approximately one mile of the facility.
  • The Bio-Lab facility was built in 1979 and was designed in 1978.
  • The Bio-Lab facility was not subject to OSHA Process Safety Management regulations because it did not have any process chemicals above the threshold limits set in the OSHA regulation, but Bio-Lab had chosen to be PSM compliant.
  • The Bio-Lab facility had a fire protection system with four fire water pumps and a freshwater reservoir.
  • Bio-Lab did not have automated fire sprinklers in Plant 4 or the Finished Goods Warehouse.
  • The Bio-Lab facility did not conform to NFPA 101 Life Safety Code and NFPA 400 Hazardous Materials Code requirements described in the report.

Consequences

  • Fatalities: 0
  • Injuries: There were no reported injuries from this event. Post-incident, nine firefighters were taken to the hospital for evaluation after inhaling hazardous vapors, and were subsequently released.
  • Environmental Release: A large plume of hazardous gases, including toxic chlorine, was released into the air and crossed the facility boundary; chlorine gas was measured slightly above the EPA Acute Exposure Guideline Level (AEGL-1) in two locations.
  • Facility Damage: The decomposition and fire destroyed Plant 4 and severely damaged the Finished Goods Warehouse; Hurricane Laura also damaged additional structures at the facility.
  • Operational Impact: A portion of Interstate 10 was closed for over 28 hours; the Calcasieu Parish Office of Homeland Security and Emergency Preparedness issued a shelter-in-place order; Bio-Lab invested approximately $250 million to reconstruct the damaged facility and resumed production operations around March 2023.

Key Findings

Immediate Causes

  • rainwater contacting stored trichloroisocyanuric acid-based formulation
  • Category 4 Hurricane Laura winds damaged portions of the facility’s building roofs that were not built to current wind design requirements
  • The probable cause of the second event was the decomposition of a TCCA-based formulation that had gotten wet or heated during the September 14, 2020, event.

Contributing Factors

  • Bio-Lab’s inadequate preparation for extreme weather
  • Bio-Lab’s deficient process hazard analysis action item management system
  • insufficient regulatory coverage of chemicals with reactive hazards
  • Bio-Lab’s inadequate and largely nonfunctional fire protection system
  • the absence of automatic extinguishing systems
  • access to the decomposing pallets was hindered by other surrounding poorly stacked pallets of materials
  • The forklifts used to move the materials were sliding on the wet floor
  • the continued fume formation was causing visibility in the warehouse to worsen

Organizational and Systemic Factors

  • Bio-Lab did not learn the importance of preparing for extreme weather after the 2017 Arkema incident
  • Bio-Lab did not implement industry guidance for extreme weather preparation that was updated and published after the Arkema incident
  • Bio-Lab had no documentation that the 2010 PHA recommendation was ever implemented
  • Bio-Lab communicated that it does not have a PHA action item management system
  • Bio-Lab did not adequately maintain its fire protection system to ensure its functionality
  • Bio-Lab did not ensure that enough of its staff, including its assigned hurricane crew, knew how to activate the rental backup generator

Failed Safeguards or Barrier Breakdowns

  • the site’s fire protection system was inadequate and largely nonfunctional
  • the backup emergency generator was not functional
  • one diesel fire water pump was nonfunctional before the hurricane made landfall
  • the facility did not have automated fire sprinklers in Plant 4 or the Finished Goods Warehouse
  • the facility did not have a fire detection system in Plant 4 or the Finished Goods Warehouse
  • Bio-Lab did not conform to NFPA 101 Life Safety Code safeguards identified for high-hazard industrial occupancies
  • Bio-Lab did not conform to NFPA 400 Hazardous Materials Code requirements
  • Bio-Lab did not have documentation of close-out status for the 2010 PHA recommendation
  • The Rockdale County Fire Department arrived on-site at 5:54 a.m. but did not immediately enter the building because the Bio-Lab emergency responders believed they could isolate the decomposing product by relocating storage bags using forklifts.
  • conditions were no longer safe to continue the work

Recommendations

  1. 2001-01-H-R1 | Recipient: Occupational Safety and Health Administration (OSHA) | Status: Previously Issued Recommendations Reiterated in This Report | Summary: Amend the Process Safety Management (PSM) Standard, 29 CFR 1910.119, to achieve more comprehensive control of reactive hazards that could have catastrophic consequences.
  2. 2001-01-H-R3 | Recipient: U.S. Environmental Protection Agency (EPA) | Status: Previously Issued Recommendations Reiterated in This Report | Summary: Revise the Accidental Release Prevention Requirements, 40 CFR 68, to explicitly cover catastrophic reactive hazards that have the potential to seriously impact the public, including those resulting from self-reactive chemicals and combinations of chemicals and process-specific conditions.
  3. 2020-05-I-LA-R1 | Recipient: Bio-Lab Lake Charles | Status: Closed – Acceptable Action | Summary: Evaluate the hazards to the Bio-Lab Lake Charles facility from hurricanes and accompanying wind, rainwater, floodwater, or storm surge forces. Implement processes and safeguards for protection against those hazards, such as through: constructing new and maintaining existing buildings and structures to withstand hurricane winds and flooding, with a particular focus on those containing hazardous materials; implementing safeguards and processes to ensure hazardous chemicals are not compromised and released during extreme weather events; and following the guidance presented in the CCPS Monograph Assessment of and Planning for Natural Hazards.
  4. 2020-05-I-LA-R2 | Recipient: Bio-Lab Lake Charles | Status: Closed – Acceptable Action | Summary: Develop and implement an improved Process Hazard Analysis (PHA) action item management system. At a minimum the PHA action item management system should ensure that each PHA action item or recommendation is assigned to an appropriate person with a deadline for initial evaluation; document and maintain the rationale if the action item or recommendation is modified or rejected; and track the status of all action items or recommendations until completion.
  5. 2020-05-I-LA-R3 | Recipient: Bio-Lab Lake Charles | Status: Open – Acceptable Response or Alternate Response | Summary: Perform process hazard analyses (PHAs) on all buildings and units processing or storing trichloroisocyanuric acid. Ensure that the PHAs are revalidated at least every five years. Also include the building design basis as process safety information for the PHA team to reference during their analysis.
  6. 2020-05-I-LA-R4 | Recipient: Bio-Lab Lake Charles | Status: Closed – Acceptable Action | Summary: Revise the Bio-Lab Lake Charles emergency response plan to require the following: the site’s fire protection system is properly maintained and routinely function-tested in accordance with published industry guidance and NFPA requirements; any equipment identified as nonfunctional must be repaired in a timely manner in accordance with NFPA requirements; emergency and fire protection equipment (in particular fire water pumps) must be checked regularly to ensure it is in good working order one month before the start of the U.S. hurricane season, as recommended by the Center for Chemical Process Safety Monograph Assessment of and Planning for Natural Hazards; and site personnel must be trained on the use of all emergency generators and other emergency equipment at least one month before the start of the U.S. hurricane season.
  7. 2020-05-I-LA-R5 | Recipient: Louisiana Governor and Louisiana State Legislature/Secretary of the Louisiana Department of Environmental Quality (LA DEQ) | Status: Open – Awaiting Response or Evaluation/Approval of Response | Summary: Under existing statutory or regulatory authority or through the establishment of new authority by executive or legislative action, for all existing chemical manufacturing and storage facilities that: 1) Are located in a hurricane-prone region as defined by the International Building Code, and 2) Manufacture or store or can inadvertently or otherwise produce (e.g., by chemical reaction) regulated substances inside equipment or building(s) built before more current wind design requirements came into effect require the facility operators to evaluate the hazards to their facilities from hurricanes and accompanying wind, rainwater, floodwater, or storm surge forces. Require the facility operators to implement processes and safeguards for protection against those hazards, such as through: ensuring that buildings and structures (both new and existing) can withstand hurricane winds and flooding, with a particular focus on buildings and structures containing hazardous materials; implementing safeguards and processes to ensure that hazardous chemicals are not compromised and released during extreme weather events; and/or following the guidance presented in the Center for Chemical Process Safety Monograph Assessment of and Planning for Natural Hazards.
  8. 2020-05-I-LA-R6 | Recipient: Environmental Protection Agency (EPA) | Status: Open – Awaiting Response or Evaluation/Approval of Response | Summary: Implement the five open recommendations issued in the 2022 U.S. Government Accountability Office Report titled Chemical Accident Prevention: EPA Should Ensure Regulated Facilities Consider Risks from Climate Change, which are: provide additional compliance assistance to Risk Management Plan (RMP) facilities related to risks from natural hazards and climate change; design an information system to track common deficiencies found during inspections, including any related to natural hazards and climate change, and use this information to target compliance assistance; issue regulations, guidance, or both, as appropriate, to clarify requirements and provide direction for RMP facilities on how to incorporate risks from natural hazards and climate change into their risk management programs; develop a method for inspectors to assess the sufficiency of RMP facilities’ incorporation of risks from natural hazards and climate change into risk management programs and provide related guidance and training to inspectors; and incorporate the vulnerability of RMP facilities to natural hazards and climate change as criteria when selecting facilities for inspection.

Key Engineering Lessons

  • Buildings and structures storing reactive hazardous materials should be designed and maintained to withstand site-specific extreme weather loads, including hurricane winds and rainwater intrusion.
  • Reactive materials such as TCCA require safeguards to prevent water contact after structural damage, because rainwater intrusion can initiate decomposition, fire, and toxic gas release.
  • Fire protection systems, emergency generators, and fire water pumps must be maintained and function-tested so they remain available during extreme weather events.
  • Process hazard analyses for buildings and storage units containing reactive materials should include building design basis and be tracked to closure through an effective action item management system.
  • Automatic sprinklers and fire detection were identified as absent in Plant 4 and the Finished Goods Warehouse, indicating the importance of fixed protection for high-hazard storage occupancies.

Source Notes

  • Primary incident facts, causes, consequences, and recommendations were taken from the final report (source_priority 1), which overrides lower-priority documents where conflicts existed.
  • Recommendation status updates from later CSB status change summaries were used to update recommendation statuses for R1, R2, and R4 where explicitly stated.
  • The final report text included a second event at a different facility (Bio-Lab Conyers) and a September 18, 2020 trailer decomposition; these were not merged into the main incident narrative except where explicitly referenced in the source extracts.
  • Some source extracts contained truncated or malformed recommendation text; summaries were preserved only to the extent explicitly provided.

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