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Organic Peroxide Decomposition, Release, and Fire at Arkema Crosby Following Hurricane Harvey Flooding Crosby, Texas

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Organic Peroxide Decomposition, Release, and Fire at Arkema Crosby Following Hurricane Harvey Flooding Crosby, Texas Investigation Report Organic Peroxide Decomposition, Release, and Fire at Arkema Crosby Following Hurricane Harvey Flooding Crosby, Texas Incident Date: August 31, 2017 Exposures to Emergency Responders, Community Evacuation, and Property Damage KEY ISSUES: • Understand Site Flood Vulnerability • Conduct a Flood Risk Assessment • Strengthen Flood Resiliency • Improve Emergency Response Report Number: 2017-08-I-TX May 2018 The U.S. Chemical Safety and Hazard Investigation Board (CSB) is an independent Federal agency whose mission is to drive chemical safety change through independent investigations to protect people and the environment. The CSB is a scientific investigative organization, not an enforcement or regulatory body. Established by the Clean Air Act Amendments of 1990, the CSB is responsible for determining accident causes, issuing safety recommendations, studying chemical safety issues, and evaluating the effectiveness of other government agencies involved in chemical safety. More information about the CSB is available at www.csb.gov. The CSB makes public its actions and decisions through investigative publications, all of which may include safety recommendations when appropriate. Types of publications include: Investigation Reports: formal, detailed reports on significant chemical incidents that include key findings, root causes, and safety recommendations. Investigation Digests: plain-language summaries of Investigation Reports. Case Studies: reports that examine fewer issues than Investigation Reports. Safety Bulletins: short publications typically focused on a single safety topic. Hazard Investigations: broader studies of significant chemical hazards. Safety Videos: videos that animate aspects of an incident or amplify CSB safety messages. CSB products can be freely accessed at www.csb.gov or obtained by contacting: U.S. Chemical Safety and Hazard Investigation Board Office of Congressional, Public, and Board Affairs 1750 Pennsylvania Ave NW, Suite 910 Washington, DC 20006 (202) 261-7600 No part of the conclusions, findings, or recommendations of the Board relating to any accidental release or the investigation thereof shall be admitted as evidence or used in any action or suit for damages arising out of any matter mentioned in such report. See 42 U.S.C. § 7412(r)(6)(G). 2 CSB · Investigation Report Table of Contents ABBREVIATIONS, ACRONYMS, AND INITIALISMS ................................................................................................... 6 1. SUMMARY ..................................................................................................................................................... 8 1.1. OVERVIEW OF INCIDENT EVENTS AND ACTIVITIES..................................................................................................... 8 1.1.1. Preparing for Hurricane Harvey ........................................................................................................... 9 1.1.2. Relocation of Organic Peroxides ........................................................................................................ 10 1.1.3. Emergency Response Activities .......................................................................................................... 12 1.2. KEY FINDINGS AND LESSONS .............................................................................................................................. 13 1.3. GUIDANCE TO INDUSTRY ................................................................................................................................... 16 1.4. SUMMARY OF RECOMMENDATIONS .................................................................................................................... 16 2. BACKGROUND INFORMATION ON ARKEMA CROSBY OPERATIONS ............................................................. 18 2.1. ORGANIC PEROXIDES ....................................................................................................................................... 18 2.2. ORGANIC PEROXIDE STORAGE BUILDINGS ............................................................................................................ 20 2.3. REFRIGERATION .............................................................................................................................................. 21 2.4. EMERGENCY GENERATORS ................................................................................................................................ 22 2.5. LIQUID NITROGEN SYSTEM ................................................................................................................................ 23 2.6. REFRIGERATED TRAILERS................................................................................................................................... 24 2.7. PRODUCT TOTES ............................................................................................................................................. 25 3. INCIDENT DESCRIPTION ............................................................................................................................... 27 3.1. THURSDAY, AUGUST 24, 2017 ......................................................................................................................... 30 3.2. FRIDAY, AUGUST 25, 2017 .............................................................................................................................. 32 3.3. SATURDAY, AUGUST 26, 2017 .......................................................................................................................... 33 3.4. SUNDAY, AUGUST 27, 2017 ............................................................................................................................. 36 3.5. MONDAY, AUGUST 28, 2017 ........................................................................................................................... 43 3.6. TUESDAY, AUGUST 29, 2017 ............................................................................................................................ 50 3.7. WEDNESDAY, AUGUST 30, 2017 ...................................................................................................................... 55 3.8. THURSDAY, AUGUST 31, 2017 ......................................................................................................................... 58 3.9. FRIDAY, SEPTEMBER 1, 2017 ............................................................................................................................ 61 3.10. SATURDAY, SEPTEMBER 2, 2017 ....................................................................................................................... 63 3.11. SUNDAY, SEPTEMBER 3, 2017 .......................................................................................................................... 65 3.12. MONDAY, SEPTEMBER 4, 2017 ......................................................................................................................... 66 4. FLOOD INFORMATION ................................................................................................................................. 67 4.1. HISTORY OF FLOOD INSURANCE RATE MAP FOR THE ARKEMA CROSBY FACILITY ........................................................... 75 4.2. FLOOD INSURANCE STUDY ................................................................................................................................ 78 4.3. BASE FLOOD ELEVATION ................................................................................................................................... 79 4.4. 2016 INSURANCE REPORT IDENTIFIED AND EVALUATED FLOOD RISK ......................................................................... 81 5. FLOOD DESIGN AT THE ARKEMA CROSBY FACILITY ...................................................................................... 83 5.1. HURRICANE PREPAREDNESS PLAN ...................................................................................................................... 83 5.2. EMERGENCY RESPONSE PLAN ............................................................................................................................ 83 5.3. STORAGE BUILDING SAFETY GUIDELINES .............................................................................................................. 84 CSB · Investigation Report 3 5.4. PROCESS HAZARD ANALYSIS .............................................................................................................................. 84 5.5. PROCESS SAFETY WORST-CASE SCENARIOS .......................................................................................................... 86 5.6. ARKEMA STATEMENTS ..................................................................................................................................... 86 6. FLOOD PLANNING GUIDANCE ...................................................................................................................... 88 6.1. AMERICAN SOCIETY OF CIVIL ENGINEERS ............................................................................................................. 88 6.2. CENTER FOR CHEMICAL PROCESS SAFETY ............................................................................................................. 89 6.2.1. Guidelines for Safe Warehousing of Chemicals ................................................................................. 89 6.2.2. Guidelines for Safe Storage and Handling of Reactive Materials ...................................................... 90 6.2.3.
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