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.
The Incident
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.
The Fallout
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.
Fire Response
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.
Fire Planning
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.
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