Dear Chairman Sutherland:
We write to request that the U.S. Chemical Safety Board (CSB) commence an investigation into the tragic explosions at the Arkema chemical facility near Houston, Texas in order to determine the circumstances which led up to the event, and to identify any recommendations to help prevent the impacts of similar events in the future. The proximate cause of the explosion was almost certainly the catastrophic flooding caused by the aftermath of Hurricane Harvey. However, we believe that measures to better plan for extreme weather, especially given the likelihood that such events will increase in frequency and severity due to climate change, could lead to better resiliency and ability to prevent, reduce or mitigate their consequences.
According to reports[1], the Arkema facility was inundated with more than 40 inches of rain due to Hurricane Harvey, and contains organic peroxides which become unstable and explode when they are not kept sufficiently cool. The facility lost its primary power supply because of the hurricane, but its emergency generators, which presumably were installed in order to mitigate against primary power outages, reportedly also failed, as did a secondary emergency cooling system.
The failure of not just one, but two, sources of emergency back-up power raises questions about whether best practices associated with installing and maintaining such systems at facilities located in hurricane- or flood-prone areas were followed, and whether these practices need to be improved. We believe that the CSB, as an independent federal agency charged with investigating industrial chemical accidents, would be the best entity to explore these and any other questions associated with this accident.
Thank you very much for your prompt attention to this matter.