CSB’s Arkema Investigation Update

Earlier this week the Chemical Safety Board (CSB) held a news conference (note this link is to a copy of the email that I received about the press conference, the Sutherland statement is not currently available on the CSB web site) to provide an update on their investigation of the fires at the Arkema site in Crosby, TX after Hurricane Harvey (discussed in this blog here). As part of that news conference, CSB released a video showing the time-line of activities that took place during the incident.

The Time Line

CSB shared the following time-line graphic at that news conference

Commentary

Sutherland concluded her statement by saying: “There is a valuable lesson that facilities in the Gulf and elsewhere should note:  Reassess continuity of operations plans and worst case (sic) scenario assumptions.  Plan and plan again. Don’t be lulled into a false sense of safety by thinking that ‘it can’t/ won’t happen here.’”

A key part of that planning process is the identification of the key assumptions made during that process. Here, for example, the assumption was that flood waters would not exceed 2-ft. I would be surprised if this assumption was made and documented in any formal fashion, but it was made when it was decided to elevate the backup generators by that much.

If the facility had documented the reasoning process that lead to that decision, a periodic review of the plan may have noted that the increased rainfall that storms have been producing in the north-western Gulf Coast in recent years might have called for a revision of that assumption.

All emergency response plans need to be formally reviewed a recurring basis. For example, along the Gulf and Atlantic Coast, chemical facilities should formally review their hurricane response plans every spring, well before the start of the season. That review should include:

• Lessons learned from previous seasons;

• Assumptions about storm action levels;

• Assumptions about worst-case scenarios;

• Shutdown decision points;

• Evacuation decision points;

• Coordination activities with local community responders;

• Facility protection plans; and

• Recovery plans.

Worst-case scenario planning, it must be remembered, should not start with an assumption about what is the worst thing that could happen to the facility. It should start with an analysis of what is the worst thing that can happen at a facility. At the Arkema facility this would have been the decomposition/fire/explosion of the material in one of the cold storage buildings. From that worst-case incident the planning process needs to identify possible routes to that incident and the mitigation measures necessary to prevent those causes.

Was the worst-case planning at the Arkema facility adequate? In hind sight, it is easy to come to the conclusion that it was not; easy, but not necessarily correct. Three feet of flood water had never been documented in that area, so it is hard to fault Arkema (or any of its neighbors) for planning for such flooding. Plans going forward will have to be revised for that eventuality, but it was not reasonable pre-Harvey.

The other thing about emergency planning that we see clearly from this event is that plans need to be modified on the fly as situation change. It is clear from the timeline presented by CSB, that Arkema continued to recognize that the situation was changing for the worst and that they adapted in a timely and proactive manner to those changes. This is one of the reasons that facility evacuation plans in the face of storms like these must consider leaving a team on site to respond to changing conditions.

Any stay behind team needs to include knowledgeable management and operations/maintenance personnel that have the authority and skills to react to changing conditions. They must be protected against the potential storm effects and provided with communications tools to be able to coordinate with local response agencies if required.

As I have noted before in discussing this event, the CSB investigation of the incident should focus on the planning process that was in place for this facility. The result of the investigation should include recommendations for emergency planning actions that chemical facilities should take to prevent damage (with off-site consequences) from predictable natural disasters like hurricanes, floods, tornados, and earthquakes (all in appropriate areas of the country).