West, TX: rushing to conclusions didn’t help
Following the 2013 disaster in West, TX many in the media and public focused on the supposed failures of the site owner and various government agencies. News reports ridiculed the facility for failing to “imagine” a proper worst-case scenario or “not checking the box” to indicate a flammable or explosive material on-site. One outlet went as far as asserting that “The company lied to EPA when they said that there is no risk of fire or explosion at the facility…” Thus, it became established (and quickly) that at least 14 people, 11 of them first responders, died because of obvious and apparently willful failures. But there were some big problems with this rush to judgment.
Let’s start by getting our bearings with some basic facts. Anhydrous ammonia is a poison gas stored in high-pressure steel tanks (the long white cylinders you saw on the news). Ammonium nitrate is a granular solid stored in bulk on the ground under a simple roof. Both are produced in very high quantities in this country. Both are used as fertilizer.
Shortly after the blast, the media honed in on the anhydrous ammonia stored in multiple tanks across the site. Anhydrous is classified by the EPA as toxic, not flammable. The EPA Risk Management Program (RMP) required the fertilizer depot owner in West to predict the effects of a “worst-case scenario.” Under the rule, the worst-case scenario for a toxic gas is defined as the complete release within 10 minutes of the contents of the single largest tank during certain atmospheric conditions (i.e., slow wind at 77 degrees). It is a prescribed scenario from which the facility cannot deviate, with no “imagination” allowed, and it is not a minor event. A complete loss of a bulk anhydrous ammonia tank within 10 minutes will easily send lethal or permanently disabling concentrations of gas miles downwind.
But soon, all the focus on anhydrous dissipated because news emerged that the tanks holding this gas were intact – and thus not the cause of the explosion. Focus quickly shifted to ammonium nitrate held onsite. This material, under specific conditions, can be quite explosive, but is not covered under the RMP rule since it is classified as neither extremely toxic nor extremely flammable. So, there could be no failure to “check the box” and no “lie” or deception on the part of the facility when reporting both the lack of fire or explosion risk and their worst-case scenario under the RMP rule. The required scenario focused strictly on toxic anhydrous ammonia. Even had there been bulk propane at the site, common for these facilities, nothing would change since propane held for fuel is exempt from the rule.
Another blind alley that many went down concerns the lack of OSHA inspections. It was legitimate to wonder why the workplace safety agency hadn’t visited this facility since 1986. The simple answer is that OSHA is chronically underfunded and rarely able to visit small workplaces with low injury rates unless there are safety complaints or catastrophic events like this one. But that misses the point. The very comprehensive OSHA Process Safety Management (PSM) rule addresses only listed highly hazardous chemicals, which ammonium nitrate is not. An OSHA Compliance Officer would have no regulatory interest in ammonium nitrate beyond hazard communication and safe material handling for employees. The rule does cover anhydrous ammonia, but, as we now know, that material was not involved in the West event.
So, where are the media and public right to raise concern? Early reports and the Department for Homeland Security (DHS) seemed to agree that the site did not register with DHS as required for handlers of ammonium nitrate. The requirement to report “Chemicals of Interest” also covers anhydrous ammonia, but no one seemed to be mentioning lack of registration for that. DHS addresses registration through an extensive “CSAT Top-Screen” report, and ammonium nitrate is reported if the facility manufactures, processes, uses, stores or distributes either 400 or 2,000 pounds or more of commercial grade material depending on the specific composition. In either case the West site reportedly had many times those amounts on-site.
DHS reviews Top-Screen reports to determine whether facilities must submit a Chemical Security Assessment Tool (CSAT) Security Vulnerability Assessment (SVA). If review of the SVA indicates a high-risk facility, DHS requires the site to develop a Site Security Plan. Since the West facility apparently did not submit the initial Top-Screen, subsequent reviews were not done. Would that have mattered?
With 4,000 or more such facilities across the country and easy access to all of them, it takes little analysis to conclude that they are not seen as high-risk sites: security is generally limited to fences and the occasional camera. The DHS rule addresses security, and proper registration would have triggered no requirement to reduce or eliminate the stockpile of ammonium nitrate. The risk, though well documented, would have remained.
Despite being continuously referred to in the media as “extremely explosive,” ammonium nitrate is not formally classified as an explosive. It is an oxidizer and is typically described on Safety Data Sheets as “stable” and “may be combustible at high temperature.” How then do we explain what happened in West, Texas?
Two historical events shed some light. In the 1995 Oklahoma City bombing, ammonium nitrate (AN) was mixed with fuel oil (FO) such as diesel to create an ANFO bomb that was detonated with an initiating charge of dynamite. That is the classic ammonium-nitrate-as-bomb scenario, but it requires considerable effort to succeed. For the West, TX disaster, the best illustration is Texas City in 1947 when a ship loaded with ammonium nitrate exploded after several hours of smoldering and burning, killing over 600 including the entire Fire Department. Recall that the West fire burned intensely for 20-30 minutes before the explosion. In this scenario, all that is required for an explosion is a large concentration of ammonium nitrate and intense heat and fire – much simpler than making a bomb, but just as deadly.
As a career emergency response manager, I’ve come close to being injured or killed on responses more times than I care to admit (or tell my wife). For all responders, those near-misses are “lessons learned” that must be passed on to other responders and communities. That’s what came from West.
What then were the right questions for the media and the public to be asking at that point? Here are two: Where should first responders have been at the time of the explosion and were there training failures or information gaps that led to those first responders being too close to the blast when it happened? This is not second guessing those who tried to put out that fire. It is, however, meant to provoke a conversation about what may have gone wrong and why. And since it was mostly first responders who died, this is best approached by media, by investigators and everyone else as a story of defining and managing risk and emergency response.
The obvious follow-up questions are how much risk can or should a community live with, how is that defined and measured, and who gets to decide? How many times after West did we hear “Who let them put a facility like that so close to all these people?” The answer is that we all did; the planners, the citizens, the developers, the government. Addressing these issues affects everything from property values to planning and zoning to your right to know (or not) to disaster preparedness and casualties. How much risk can you live with in your town?