Natech Accident
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Type
Natech Accident
Date
2020/08/27
Time
08:30
Duration
30 hour(s)
Status
Published

Units Involved

  1. Name
    BIO-LAB Plant 4
    Type
    Process: Other
    Year of Construction
    1979
    Description
    The Plant 4 building was used for production and packaging of TCCA (Trichloroisocyanuric Acid).
    The Plant 4 held an estimated 70,000 to 100,000 pounds of TCCA.
  2. Name
    Finished good warehouse
    Type
    Storage: Warehouse
    Year of Construction
    1979
    Description
    The Bio-Lab Finished Goods Warehouse was divided into three bays for storing raw materials, TCCA finished product, and offspecification materials. It was a single-story pre-engineered “Butler” style steel-framed building built around 1979. The Finished Goods Warehouse had tapered steel moment frames supporting the lightweight steel roof purlins, wall girts, and screw-attached steel or fiberglass exterior sheathing.
    The Finished Goods Warehouse, which contained over one million pounds of TCCA inventory and partially filled supersacks, among other raw materials.

Event Sequences

  1. Name
    Fire and toxic chlorine gas release
    Unit
    1. BIO-LAB Plant 4
    Description
    Hurricane winds torn-off the roof of the Plant 4 building, which was not built to withstand high winds (i.e., it was not designed to the up-to-date wind design requirements).
    Following the roof damage, rainwater contacted the TCCA stored inside, initiating a chemical reaction and subsequent decomposition of the TCCA. The heat produced from the reaction and decomposition initiated a fire, and the decomposition released a large plume of hazardous gases, including toxic chlorine, into the air. The plume of hazardous gases crossed the facility boundary and could be seen over a large portion of the nearby community.
    The Bio-Lab facility and surrounding area had also likely lost electrical power due to damage from the hurricane.
    Substances Involved
    1. Name
      Trichloroisocyanuric Acid
      CAS No
      87-90-1
      Potential Quantity
      500 ton
      Description
      TCCA is a chlorinating agent often used as a sanitizer to kill algae and bacteria in large volumes of water, predominantly swimming pools and hot tubs, and sold in tablet, stick, and granular forms. In large bodies of water, the TCCA is soluble and breaks down slowly, releasing chlorine in the water to sanitize contaminants. When TCCA instead comes in contact with or is
      wetted/moistened by a small amount of water and does not dissolve, it can experience a chemical reaction, generating heat and causing the decomposition of the chemical, which in turn produces toxic chlorine gas and can produce explosive nitrogen trichloride.

      Plant 4 held an estimated 70,000 to 100,000 pounds of TCCA and the Finished Goods Warehouse held over one million pounds of TCCA inventory.
    Initiating EventCritical EventMajor Event
    Component (Non-structural): Roof damage
    Hurricane winds torn-off the roof of the Plant 4 building, allowing rainwater to flow inside the plant and contact the stored TCCA.
    Contributing Factors
    Organisational: Design of plant / equipment / system: Inadequate
    Bio-Lab’s inadequate preparation for extreme weather and deficient process hazard analysis action item management system
    Release: Gas, vapour, mist, or smoke release to air
    The contact of TCCA with rainwater initiated a chemical reaction and subsequent decomposition of the TCCA. The heat produced from the reaction and decomposition initiated a fire. The TCCA decomposition released a large plume of hazardous gases, including toxic chlorine, into the air. The massive toxic gas and smoke plume crossed the facility boundary, travelled over the local community and could be seen over a large portion of the nearby community.
    Contributing Factors
    Other:
    Insufficient regulatory coverage of chemicals with reactive hazards.
    Fire: Other
    The fire quickly evolved, leaving a collapsed roof and severe structural damage to Plant 4 that ultimately destroyed the building. The massive fire also destroyed process equipment installed inside Plant 4.
    Contributing Factors
    Measure: Portable fire extinguishers: Inadequate
    Bio-Lab’s inadequate and largely non-functional fire protection system and the absence of automatic extinguishing systems.
    Organisational: Training / instructions: Inadequate
    Inadequate training to the employees on using the back-up generator to energize the large electric fire water pump during a power outrage.
  2. Name
    Vapor Emission
    Unit
    2. Finished good warehouse
    Description
    Hurricane Laura’s wind severely damaged the Finished Goods Warehouse, which contained over one million pounds of TCCA inventory and partially filled supersacks, among other raw materials.
    At approximately 5:30 p.m. on 27/08/2020, a white cloud emitting from the Finished Goods Warehouse was observed by a first responder.
    Initiating EventCritical EventMajor Event
    Component (Non-structural): Roof damage
    Hurricane Laura’s wind severely damaged the Finished Goods Warehouse.
    Release: Gas, vapour, mist, or smoke release to air
    At approximately 5:30 p.m. on 27/08/2020, a white cloud emitting from the Finished Goods Warehouse was observed.
    -

Weather Conditions

Precipitation
Rain
Average Wind Speed
67 m/s
Description
Around 1:00 a.m. on August 27, 2020, Hurricane Laura made landfall in Cameron (Southwest Louisiana) as a Category 4 hurricane, with maximum sustained winds reaching 150 miles per hour (67 m/s) and a minimum central pressure of 939 millibars.

Emergency Response

Response Planning
Emergency response plan is sufficient in taking Natech events into consideration: No
Response Planning Activities
On August 24, 2020, in preparation for the hurricane, Bio-Lab began shutting down its Lake Charles operations using its Hurricane Plan. After a Bio-Lab, Inc. executive directed the site management to transport chemicals from the facility, the Bio-Lab team worked to secure trucks to remove TCCA from the facility before Hurricane Laura made landfall.
Bio-Lab successfully transported about 825,000 pounds of TCCA from the Finished Goods Warehouse to the Bio-Lab facility in Conyers, Georgia. However, two additional scheduled trucks never arrived at the facility, leaving over one million pounds of TCCA on-site as the hurricane approached.

On August 25, 2020, nine employees assigned to the Bio-Lab Hurricane Crew. Each crew member had specific job assignments, including securing loose items that could become hazardous during the hurricane (e.g., by being propelled by wind), placing sandbags at entrances to prevent floodwater entry, and other tasks defined in the hurricane plan. To protect the remaining TCCA and other products from potential floodwater, the Hurricane Crew raised the materials above floor level by placing the material on triple-stacked pallets.

The Bio-Lab facility had a fire protection system which included four fire water pumps, including two electric and two diesel pumps that started sequentially. A backup generator was required to provide electrical power to the electric pumps during a power outage.

Overall, Bio-Lab had inadequate preparation for extreme weather as it did not implement industry guidance for extreme weather preparation, failing to learn from the experience of past events (e.g., the 2017 Arkema incident in Crosby, Texas, which occurred after extensive flooding from Category 4 Hurricane Harvey caused). TCCA is not covered by the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Standard, pertaining to deficiencies in the process hazard analysis action item management system. The regulatory coverage of chemicals with reactive hazards was insufficient (i.e., regulatory coverage gap).
Difficulties in Response to the Natech Event
Insufficient personnel and equipment to respond to both emergencies: Yes
Damage to lifelines (e.g. water, power, communication, transportation): Yes
Response Teams and Equipment Involved
  • On-site systems (e.g. sprinkler, water cannon)
  • On-site hazmat team
  • Local fire fighting team
  • Regional / national fire fighting teams
  • Regional / national hazmat teams
Sheltering and Evacuation due to the Natech event
  • On-site sheltering
  • On-site evacuation
Response to the Natech Event
The Bio-Lab experienced serious delays (approximately 5.5 hours) in responding to the TCCA decomposition and fire due to an inadequate and largely non-functional fire protection system and the absence of automated sprinkler systems.

At approximately 9:00 a.m. on August 27, 2020, two Bio-Lab employees (a supervisor and a production operator) entered the Bio-Lab facility to assess the situation or control the TCCA decomposition. There was no electrical power at the facility and a backup generator was required to provide electrical power to the electric fire water pumps. However, the backup emergency generator was not functional and the employee was unfamiliar and not able to use it. One diesel fire water pump was activated at around 11:40 a.m. but the water pressure was inadequate due to a leak in the fire water system piping. Due to these problems, the fire worsened and went beyond the capability of the Bio-Lab responding employees.

At approximately 11:03 a.m., the Lake Charles Fire Department arrived at the Bio-Lab facility. External emergency responders—Specialized Response Solutions (SRS) and Haz Mat Special Services, LLC—also arrived to assist with environmental and hazardous material response.
A consensus that “copious amounts of water would be necessary to saturate the product” to reduce and/or control the decomposition reaction.

The Fire Department attempted to use its equipment to draft water from the Bio-Lab freshwater reservoir and experienced technical difficulties with priming their pump, delaying their efforts to get water to the fire.

Haz Mat Special Services demolished the west wall of Plant 4 and a roof (between the 24-hour Storage and 30-day Warehouse) that were preventing the fire water to access to the decomposing TCCA stored on the ground level. After demolition, they accessed the TCCA and saturated it with water, significantly reducing the visible white cloud emitting from the building.

The incident responders removed a back wall of the Finished Goods Warehouse to spray water inside the area containing the decomposing super sacks. In addition, they removed the damaged or compromised TCCA super sacks from the Finished Goods Warehouse to saturate them with water and extinguish the decomposition. 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.

Consequences

Off-site People At Risk
10000
Human Health Impacts
No injuries were reported.
On-site Response and Remediation Costs
250 M USD
Economic Impacts
Bio-Lab invested approximately $250 million USD to redesign and completely reconstruct the damaged facility.
The Bio-Lab facility resumed its production operations around March 2023.
Built-up Areas Impacted
  • Industrial areas (e.g. factories)
  • Utilities (e.g. gas, water, electricity, telecommunication)

Remedial Activities

Decontamination Activities
The fire involving TCCA was distinguished with water supply in large amounts.
Restoration Activities
The facility was reconstructed - enhanced safety features were included surpassing those of the damaged facility.

Lessons Learned

Lessons Learned on Equipment
Companies must ensure that emergency response equipment is fully operational and can function when needed during emergencies. Companies should conduct routine evaluations of the fire protection system’s functionality in accordance with industry guidance and NFPA requirements, adequately maintain the equipment, and repair or replace equipment as appropriate in a timely manner.
Lessons Learned on Organisational Aspects
1. Extreme weather can present serious hazards to facilities that manufacture, process, or store hazardous chemicals. Facilities should evaluate the hazards to processes from extreme weather and implement safeguards to protect from those hazards. The CCPS Monograph Assessment of and Planning for Natural Hazards provides guidance on how to evaluate, risk assess, and protect facilities from natural hazards.

2. It is important to ensure that (1) PHA recommendations are assigned to an appropriate person with a deadline for initial evaluation, (2) the rationale for recommendation modification or rejection is documented, and (3) the status of all action items or recommendations are tracked until completion. Such a process will help ensure that findings and recommendations from PHAs are effectively acted upon.
Lessons Learned on Emergency Response Aspects
Companies must ensure that personnel are trained on how to use emergency response equipment.
ID: 100, Created: Kyriaki GKOKTSI, 2023-04-26 10:03:23 – Last Updated: Kyriaki GKOKTSI, 2023-10-12 14:01:23

Attachments

NoDescriptionFile Size
1.Investigation report by U.S. Chemical Safety and Hazard Investigation Board18.50MB