An article listed in today’s DHS Daily Open Source Infrastructure Report reports that thousands of fish were killed along a 10-mile length of a local creek after a chemical plant fire in Hanover, PA. The story is a bit more complex and point to an emergency response planning problem that is fairly common in facilities that handle chemicals.
According to news reports at 3:30 Monday morning a fire started in the chemical facility that “manufactures nonhazardous crop protection and nutritional agrochemicals”. At least one news report said that fire officials intended to let the fire burn out rather than put more water on the fire. Two separate news reports (here and here) said that responders established a local retention pond to recover the water that flowed out of the fire. Another article reported that the local emergency service agency was concerned about possible adverse effects from run-off from the fire.
In any case, the fire was ultimately put out and the facility was declared to be a total loss. This is typically the case when a chemical warehouse becomes involved in a major fire.
Concerns about fire run-off were apparently correct (not unusual in a chemical facility fire). In addition to the reported fish kill mentioned earlier the local water system that apparently uses water from the same creek closed their intakes to stop contaminants from entering their system (and thus avoiding the problems seen in the Freedom Industry spill). This means that local residents that get water from that system are on severe water restrictions and looking for bottled water.
And, of course, the problem continues to spread down stream. Local officials in the Hanover area expect the contamination to be gone from their area in a week or so. They’ll be testing the water to make sure.
The problem here was that the first fire fighters on the scene did what fire fighters typically do when they arrive at a building with visible flames; they set hoses and started pouring the water on. One article about this incident quoted a local firefighter as saying that maybe a million gallons of water were poured on the flames before someone started diking the outflow.
Unless something is in place to stop it, that water flows to the nearest creek. In a normal residential fire that water is nasty enough with soot and various combustion byproducts that are not healthy to the local environment. In an industrial facility that contains significant amounts of chemicals that water will also contain chemicals that spill from fire damaged containers as well as reaction and fire byproducts of those chemicals. And the larger the facility, the more water that is typically used to stop the fire.
Post Fire Costs
Run-off water collected from a chemical facility fire is going to have to go to some sort of treatment facility. Soil contaminated by that runoff water is going to have to be scraped up and hauled to an industrial land fill (if you are lucky) or to a hazardous waste treatment facility if you are not. Both of those are going to cost big money in the collection, transportation and disposal effort; almost certainly much more money than the lost inventory will cost.
If contaminated fire runoff water gets into a local water course like it did in this instance, the costs are going to skyrocket. Most states fine fish-kills on a per fish basis; their rules were designed to encourage people to prevent smaller spills. Shutting down a water system is sure to result in fines and any number of law suits. Any other businesses that lose money because of contaminated waterways will also seek restitution.
To prevent the post-fire problems seen in this instance in Pennsylvania, requires advance planning by both the facility management and the local first responders. Common sense dictates that these two need to get together well before any emergency happens to decide how to best handle the various problems that can arise on site.
The planning does start first with the facility management. The facility needs to understand the chemicals it has on site and how they are going to react in a fire. If there are any chemicals on site that will react with water, they need to be carefully segregated and the local fire fighters all need to know where they are kept and why it may be dangerous to apply water to those materials. Chemicals that produce seriously toxic byproduct upon combustion also need to identified, segregated and provided special fire protection to keep them from burning, or providing notice to local emergency response officials when they do start to burn.
Finally the facility management needs to take a good look at their facility and determine where any fire water runoff is going to go. Fortunately, most facilities should have already done at least part of this as part of the storm water protection plan efforts. Then facilities need to determine how much water their storm water spill containment system is capable of retaining and what areas are not going to be protected by that system. Re-looking at the SWPP in light of a million plus potential gallons of fire-fighting water may call for some revisions.
With that information in hand it is time to sit down with the local fire department and have a serious discussion about how fires will be handled at the facility. Will the fire be fought with all available means? Will special equipment be required? Will all or parts of the plant be allowed to burn? Will storage tanks need to be kept cool with water curtains to prevent catastrophic releases? Will evacuations be necessary or just shelter in place restrictions?
This is not going to be able to be handled in a single meeting. Questions will be asked requiring further research on both sides. A periodic review of the discussion will be required to make sure that all parties continue to understand what will happen if and when a fire occurs. Any time that there is a significant change in chemical inventory or plant layout the plan will have to be reconsidered.
You don’t want to be making these decisions, or having someone else make them for you, at 3:30 on a Sunday morning with flames coming out of the roof of your facility. You won’t make good decisions and you will pay for them for some time afterwards.