U.S. CHEMICAL SAFETY AND HAZARD INVESTIGATION BOARD

INVESTIGATION REPORT

REPORT NO. 2002-03-I-TX

MARCH 2003

(Destruction of Facility)

THIRD COAST INDUSTRIES

FRIENDSWOOD, TEXAS

MAY 1, 2002

KEY ISSUES

FIRE CONTROL

CONSENSUS STANDARDS

FIRE CODES

PETROLEUM PRODUCTS FACILITY INCIDENT
2
3

Abstract

Information about available

publications may be obtained by

contacting:

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Investigation Board

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and Policy

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Washington, DC 20037-1848

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purchased from:

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Information Service

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For international orders, see:

www.ntis.gov/support/

cooperat.htm.

For this report, refer to NTIS

number PB2003-102364.

.

Salus Populi Est Lex Suprema

People’s Safety is the Highest Law

This investigation report examines a petroleum products facility

incident that occurred on May 1, 2002, at the Third Coast

Industries facility in Friendswood, Texas. A fire of relatively small

magnitude destroyed the entire facility, which blended and packaged

motor oils, hydraulic oils, and engine and other lubricants. This

report identifies the root and contributing causes of the incident and

makes recommendations on fire control, consensus standards, and

fire codes.

The U.S. Chemical Safety and Hazard Investigation Board (CSB) is

an independent Federal agency whose mission is to ensure the safety

of workers, the public, and the environment by investigating and

preventing chemical incidents. CSB is a scientific investigative organization; it is not an enforcement or regulatory body. Established by

the Clean Air Act Amendments of 1990, CSB is responsible for

determining the root and contributing causes of accidents, issuing

safety recommendations, studying chemical safety issues, and

evaluating the effectiveness of other government agencies involved

in chemical safety.

No part of the conclusions, findings, or recommendations of CSB

relating to any chemical incident may be admitted as evidence or

used in any action or suit for damages arising out of any matter

mentioned in an investigation report (see 42 U.S.C. § 7412

[r][6][G]). CSB makes public its actions and decisions through

investigation reports, summary reports, safety bulletins, safety recommendations, case studies, incident digests, special technical publications, and statistical reviews. More information about CSB may be

found at www.chemsafety.gov.
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Contents

EXECUTIVE SUMMARY............................................................ 9

1.0 INTRODUCTION .......................................................... 11

1.1 Background....................................................................... 11

1.2 Investigative Process.......................................................... 11

1.3 Third Coast Industries Facility .......................................... 12

1.4 Flammable and Combustible Liquids................................ 14

1.5 Bulk Storage ...................................................................... 15

1.6 Warehouse Storage .......................................................... 17

1.7 Blending and Packaging Operations ................................. 17

2.0 DESCRIPTION OF INCIDENT .................................... 19

2.1 The Incident ..................................................................... 19

2.2 Fire Origin Theories ......................................................... 22

2.3 Fire Spread Mechanisms .................................................. 22

2.3.1 Rupture of Drums ............................................... 23

2.3.2 Failure of Blend Tanks ........................................ 24

2.3.3 Failure of Tank Wagon ...................................... 24

2.3.4 Liquid Pool Fire at Tank Farm ............................

and Warehouses ................................................ 25

3.0 ANALYSIS OF INCIDENT ............................................. 27

3.1 Fire Protection Analysis ..................................................... 27

3.2 Fire Origin and Detection ................................................. 28

3.2.1 Fire Origin .......................................................... 28

3.2.2 Initial Fire Detection ........................................... 28

3.3 Fire Spread ....................................................................... 29

3.3.1 Rupture of Drums ............................................... 30

3.3.2 Location of Tank Wagon and Blend Tanks ........ 30

3.3.3 Lack of Proper Drainage or Spill Containment ... 31

3.3.4 Tank Design, Condition of Tank Farm Dikes,......

and Location of Storage Tanks ........................... 31

3.3.5 Warehouse Firewalls ......................................... 33

3.4 Water for Manual or Automatic Fire Suppression ........... 33

3.5 Consensus Fire Codes ...................................................... 35

3.5.1 NFPA Flammable and Combustible ...................

Liquids Code ...................................................... 35

3.5.2 Other Consensus Fire Codes ............................. 35

3.5.3 Third Coast Adherence to Fire Codes............... 36

3.5.4 NFPA 30 Issues .................................................. 37

3.5.5 International Fire Code Issues ............................ 38

3.6 OSHA Flammable and Combustible Liquids Standard .... 38

3.7 County Adoption of Fire Codes ....................................... 40
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Contents (cont’d)

4.0 ROOT AND CONTRIBUTING CAUSES..................... 43

4.1 Root Causes...................................................................... 43

4.2 Contributing Cause .......................................................... 44

5.0 RECOMMENDATIONS ................................................ 45

6.0 REFERENCES................................................................. 49

APPENDIX A: Causal Factors Diagram ....................................... 51
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Figures and Tables

1 Layout of Third Coast Industries Facility ........................ 13

2 Third Coast Facility, Prior to Fire ................................... 14

3 Third Coast Storage Tank Farm ..................................... 16

4 Peak Hours of Fire, Early Morning, May 1, 2002 ......... 21

5 Fire at Approximately 7 am, May 1, 2002 ..................... 21

6 Drums Located at Packaging Line 4 ............................... 23

7 Collapsed Blend Tanks Located Near Warehouse 1 ..... 24

8 Remains of Tank Wagon, Front End in Foreground...... 25

9 Failed Storage Tanks....................................................... 26

10 Remains of Warehouse .................................................. 26

11 Section of South Dike Wall, Storage Tank Farm ............ 32

Figures

Table

1 Flammable and Combustible Liquids Classification ....... 15
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Acronyms and Abbreviations

AIChE American Institute of Chemical Engineers

API American Petroleum Institute

BATF Bureau of Alcohol, Tobacco and Firearms

(U.S. Department of the Treasury)

BOCA Building Officials and Code Administrators, Inc.

CCPS Center for Chemical Process Safety

CFR Code of Federal Regulations

CSB U.S. Chemical Safety and Hazard

Investigation Board

EPA U.S. Environmental Protection Agency

°F Degrees Fahrenheit

FM Factory Mutual Insurance Company (FM Global)

gpm Gallons per minute

IAFF International Association of Fire Fighters

ICBO International Conference of Building Officials

ICC International Code Council

IFC International Fire Code

ILMA Independent Lubricant Manufacturers Association

IRI Industrial Risk Insurers

NACo National Association of Counties

NACD National Association of Chemical Distributors

NASFM National Association of State Fire Marshals

NFPA National Fire Protection Association

NVFC National Volunteer Fire Council

OSHA Occupational Safety and Health Administration

PPC Petroleum Packaging Council

RIMS Risk and Insurance Management Society

TCEQ Texas Commission on Environmental Quality

(formerly TNRCC)

TNRCC Texas Natural Resources and Conservation

Commission

VFD Volunteer fire department
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Executive Summary

I

n the early morning hours of May 1, 2002, a fire erupted at the

Third Coast Industries Friendswood facility, located in an unincorporated area of Brazoria County, Texas. The facility—which

blended and packaged motor oils, hydraulic oils, and engine and

other lubricants—was inadequately designed and protected to

prevent the spread of fire.

Firefighters arrived at the scene within minutes, but had insufficient

means to fight the fire, which burned for more than 24 hours. The

fire consumed 1.2 million gallons of combustible and flammable

liquids, and destroyed the site. One hundred nearby residents were

evacuated, a local school was closed, and significant environmental

cleanup was necessary due to fumes and runoff. No employees or

firefighters were injured during the incident.

The U.S. Chemical Safety and Hazard Investigation Board (CSB)

and the Bureau of Alcohol, Tobacco and Firearms (which conducted

an independent investigation for fire cause) were unable to determine the fire’s initiating event. However, the fact that a fire of

relatively small magnitude could not be controlled, and led to loss of

the facility and community impacts, warranted investigation.

The CSB incident investigation revealed the following root causes:

 Third Coast did not conduct an adequate fire protection

analysis to ensure implementation of fire protection measures.

A thorough analysis of fire detection and suppression, bulk and

warehouse storage of flammable and combustible materials,

containment and drainage, and warehouse construction would

have identified specific means of better protecting the facility.

 The Third Coast facility fire suppression system was inadequate

for detecting and warning of fire or smoke or for stopping fire

spread. Key deficiencies were insufficient onsite fire water, no

manual or automatic suppression systems, and no smoke/fire

detection equipment or alarms.

 The Third Coast facility lacked adequate control measures to

limit the spread of the initial fire:

A tank truck containing combustible material was located

too close to blending and packaging equipment.

The [Friendswood] facility . . . was

inadequately designed and protected

to prevent the spread of fire.

Key deficiencies were insufficient

onsite fire water, no manual or

automatic suppression systems,

and no smoke/fire detection

equipment or alarms.

The facility did not have adequate

containment or drainage to control the

spread of burning liquid pools.
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The facility did not have adequate containment or drainage

to control the spread of burning liquid pools.

Warehouse buildings were not constructed to minimize the

spread of fire.

Brazoria County had no laws or regulations that required

Third Coast to comply with established fire codes.

CSB makes recommendations to Third Coast Terminals, the National

Fire Protection Association, the International Code Council, and

Brazoria County. Recommendations are also made to communicate

the findings of this investigation to the Petroleum Packaging Council,

Independent Lubricant Manufacturers Association, American Petroleum Institute, National Association of Chemical Distributors,

National Association of Counties, International Association of Fire

Fighters, National Volunteer Fire Council, National Association of

State Fire Marshals, and Risk and Insurance Management Society.

Brazoria County had no laws or

regulations that required Third Coast

to comply with established fire codes.
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1.0 Introduction

1.1 Background

At approximately 1:00 am on May 1, 2002, a fire erupted at the

Third Coast Industries blending and packaging facility in an

unincorporated area of Brazoria County, near Friendswood and

Pearland, Texas. Firefighters arrived at the scene within minutes, but

had insufficient water to fight the fire and decided to let it burn. The

fire consumed more than 1.2 million gallons of combustible and

flammable liquids1 and destroyed the site.

More than 180 firefighters and support personnel responded to this

incident, and nearly 24 hours was required to bring the fire under

control. No employees or firefighters were injured. Several neighboring buildings were destroyed, 100 residents were evacuated, and

a local school was closed for the day. Environmental remediation

activities, involving removal of contaminated soil and cleanup of

nearby homes, continued for many days.

Because of the serious nature of this incident—the destruction of a

business and consequent loss of employment, potential harm to

firefighters and neighbors, and environmental consequences—the

U.S. Chemical Safety and Hazard Investigation Board (CSB)

launched an investigation to determine root and contributing causes

and to issue recommendations to help prevent similar occurrences.

Because the uncontrolled spread of fire was the key issue, the CSB

investigation focused on those factors that led to total destruction of

the facility. Neither CSB nor other investigative agencies were able

to determine the fire’s initiating event.

1.2 Investigative

CSB investigators arrived at the site on the evening of May 1. The

U.S. Environmental Protection Agency (EPA) and the Texas Commission on Environmental Quality (TCEQ) controlled the active fire

scene. (At the time of the incident, TCEQ was the Texas Natural

Resources and Conservation Commission [TNRCC].) The Bureau

of Alcohol, Tobacco and Firearms (BATF) was also on scene and

conducted an investigation into the cause and origin of the fire.

1

 By CSB estimates: 735,000 gallons of liquid in bulk storage tanks and 530,000 gallons

of liquid in containerized storage (drums and smaller packages).

Process

Because the uncontrolled spread

of fire was the key issue, the CSB

investigation focused on those

factors that led to total

destruction of the facility.
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2 An unincorporated area does not fall under the jurisdictional requirements of a

municipality. It is not “incorporated” into city/town limits.

In conducting its independent investigation, CSB examined physical

evidence, interviewed Third Coast management and hourly employees, and reviewed relevant documents. However, a significant

number of Third Coast documents were lost in the fire.

CSB coordinated its work with the other organizations conducting

investigations, including BATF, EPA, TCEQ, the Occupational Safety

and Health Administration (OSHA), and the Pearland Volunteer Fire

Department (VFD).

CSB contracted with Dr. Robert G. Zalosh, Professor of Fire Protection Engineering at Worcester Polytechnic Institute, Worcester,

Massachusetts, for assistance in assessing the fire scene and analyzing

factors that contributed to the fire spread.

1.3 Third Coast

Third Coast Industries was located on West Clover Lane, in an

unincorporated section of Brazoria County, near Friendswood and

Pearland, Texas, approximately 18 miles southeast of downtown

Houston.2 The company was formed in 1987 and began operations

in 1988. Figure 1 shows the layout of the facility.

Original operations, which consisted of blending windshield washer

fluid and antifreeze, were conducted in warehouse 1. Warehouses

and storage tanks were added over the years to accommodate new

blending and packaging operations. Warehouses 2 and 3 were

added during the 1990s. Warehouse 4A and several acres of land

were acquired in the late 1990s. In 2000, an additional 7 acres was

purchased, and warehouse 4B was added to the complex.

At the time of the fire, Third Coast employed 100 people at the

Friends- wood site. (The only other Third Coast facility—Third

Coast Terminals—is located within the city limits of Pearland, Texas.)

Figure 2 presents an aerial view of the site, showing nearby homes

and businesses.

Industries Facility
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Third Coast blended and packaged windshield washer fluid; antifreeze; motor oils; hydraulic oils; gear oils; greases; engine and engine

part cleaners and solvents; and transmission, brake, and power

steering fluids. These products were marketed under various Third

Coast brand names. The facility also did business as a tolling operation, blending and repackaging material for major oil and lubricant

companies.

Warehouse 1

Warehouse 2

Warehouse 3

Warehouse 4A

Warehouse 4B

Truck well

Covered areas

Truck scale

Office area

Dock

New tanks

(not in use)

New tanks

(not in use)

Truck well

Truck well

Truck well

North

100 feet

Figure 1. Layout of Third Coast Industries facility.
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1.4 Flammable and

Approximately 98 percent of the materials at Third Coast were

classified as Class IIIB combustible liquids, with flash points of 200

degrees Fahrenheit (oF) or greater.3 The National Fire Protection

Association (NFPA) and OSHA classify flammable and combustible

liquids as shown in Table 1.

Flammable liquids with flash points of 100oF or lower can produce

ignitable mixtures under ambient temperature conditions (summer or

direct sun exposure); combustible liquids must be heated to generate

sufficient vapors to produce an ignitable mixture. In either case, both

a source of ignition and the presence of oxygen (air) are required to

ignite the vapors.

A number of consensus standards and codes specify practices for the

storage and handling of flammable and combustible liquids. Organizations such as NFPA and the International Code Council (ICC)

3

 Flash point is defined as the minimum temperature at which a liquid gives off sufficient

vapor to form an ignitable mixture with air near the surface.

Figure 2. Third Coast facility, prior to fire.

Combustible Liquids

Approximately 98 percent of the

materials at Third Coast were

classified as Class IIIB

combustible liquids . . .

2003 GlobeXplorer, Eastman Kodak Company
15

develop consensus codes, while insurance companies such as Factory Mutual (FM) and Industrial Risk Insurers (IRI) publish guidance

on storage and handling. The OSHA Flammable and Combustible

Liquids regulation (29 CFR 1910.106) is based on the NFPA standard.

1.5 Bulk Storage

Seventy-four storage tanks were in use at the time of the fire

(Figure 3). Another 18 storage tanks were installed, but not in use.

The tanks were divided among five diked areas. The rudimentary

diking generally consisted of two courses of hollow masonry blocks.

Although most of the tanks contained Class IIIB liquids, both raw

materials and bulk finished products, the following liquids were also

stored onsite:

 In Tank 19: 4,400 gallons of methanol (flash point 52oF), a

Class IB material used in the production of windshield washer

fluid.

 In Tank 38: 3,500 gallons of mineral spirits, a Class II material

(flash point 105oF).

Flammable IA Below 73 Below 100 Propane

Flammable IB Below 73 > 100 Methanol

Flammable IC 73–100 — Turpentine

Combustible II 100–140 — Mineral

spirits

Combustible IIIA 140–200 — Automatic

transmission

fluid

Combustible IIIB > 200 — Motor oil

Class Flash Point Boiling Point Examples

Table 1

Flammable and Combustible Liquids Classification

Range (oF) Range (oF)
16

 In Tanks 12 and 72: 9,500 gallons of a Class IIIA petroleum

distillate (flash point 150oF) and 1,050 gallons of an automatic

transmission fluid (flash point 198oF), respectively.

CSB estimates that 735,000 gallons of bulk combustible and flammable liquids were stored onsite at the time of the fire.

Class II liquid

71 64

70 63

69 62

68

67

66

65

56

57

9

10

12

11

58

59

60

61

48

53

54

55 52

51

50

49

46 44 43 45

41 42

31

32

33

35

36

39

40

37

34 38

6

5

4 1

3

2

7

8

15

14 17

18

16

20

21

19

24

23

22 25

27

26

30

29

28

W1W2

74

72

73

Truck well

Metal bldg

Maint/office

room

Line 1

Line 2 Line

3 Line 4

Line 5

KEY

Methanol storage

Class IIIA liquid

North

Tank wagon

Likely area of

fire origin

Class IIIB liquid

25 feet

Warehouse 1

Figure 3. Third Coast storage tank farm.
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Packaging Operations

1.6 Warehouse

Four buildings at the Third Coast facility were used for product

blending, packaging, and storage:

 Warehouse 1: Three blending/packaging lines inside the

building; one line just outside, under a roof (line 4, the most

likely point of origin of the fire based on witness statements);

plus an office and maintenance area.

 Warehouse 2: One blending/packaging line; plus storage,

mainly raw materials, and offices.

 Warehouse 3: Two blending/packaging lines; plus storage,

mainly finished product.

 Warehouse 4: Two blending/packaging lines; plus storage,

mainly finished product.

Final products were packaged in various plastic and metal container

sizes—55-gallon drums, gallons, quarts, and 8- and 12-fluid-ounce

containers. At the time of the fire, CSB estimates that the Third

Coast warehouses contained 530,000 gallons of packaged product,

mostly Class IIIB combustible liquids.

1.7 Blending and

The Third Coast facility contained 11 blending/packaging lines—

eight located inside warehouse buildings and three located outdoors

under cover. There were three lines for filling drums, each with the

capacity to fill 400 drums per shift. Other fill lines included a 32-

head filler for quarts of motor oil, a 16-head filler for brake fluid and

antifreeze, an eight-head filler for containers ranging in size from 4

fluid ounces to 5 quarts, and a four-head pail filler.

Storage

At the time of the fire, CSB estimates

that the Third Coast warehouses

contained 530,000 gallons

of packaged product, mostly

Class IIIB combustible liquids.
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19

On the evening of April 30, 2002, 12 Third Coast employees

worked an evening shift. In the warehouse 1 area, two

workers packaged motor, hydraulic, and gear oils into quart containers and 5-gallon pails. They left the site at approximately 11:30 pm.

They told CSB investigators that they followed their normal routine

of turning off lights and motors, and checking that the facility was

locked and secure before leaving.

At 1:05 am on the morning of May 1, the Third Coast contract

security guard arrived at the facility. The guard’s normal routine

was to arrive at 1:00 am and spend approximately 1 hour at the

facility each night, checking to see that gates and doors were locked

and that there were no obvious spills or unusual activity. At approximately 1:20 am, he began his rounds, walking through warehouse 2

to the rear door, facing west. As he looked out the door, he observed a fire in front (east) of warehouse 1.

The guard stated that the fire appeared to be located outdoors on

a worktable at packaging line 4; the table was used for labeling and

package closing. Upon viewing the fire, he immediately returned to

the warehouse 2 office and called 911; he then returned to the door

of warehouse 2. In his opinion, the fire was too intense for him to

risk approaching it; flames extended to the ceiling of the metal

awning over line 4.

At 1:28 am, approximately 7 minutes after receiving the 911 call, the

first emergency responder—the chief of the Pearland VFD—arrived

on scene. The following description is based on the chief’s report:

From a vantage point at the southeast corner of warehouse 2, the chief observed a ground level pool fire, 65

to 80 feet in width, to the east of warehouse 1. The fire

engulfed two box trailers (containing empty drums) and

a 6,000-gallon tank wagon (containing a synthetic motor

oil that Third Coast was repackaging into smaller

containers). The tank wagon was venting under

pressure, and the vented material was burning. The

chief reported hearing sounds of boiling and crackling,

which are indicative of burning heavy hydrocarbon

liquids. He also heard thuds and thumps (possibly

containers expanding and venting) and small explosions

(possibly the failure of smaller containers). As yet, there

was no fire in the storage tank area, located to the

north, or in the main warehouse buildings.

The guard stated that the fire

appeared to be located outdoors

on a worktable

at packaging line 4 . . .

. . . The chief observed a ground level

pool fire, 65 to 80 feet in width,

to the east of warehouse 1.

The fire engulfed two box trailers . . .

and a 6,000-gallon tank wagon.

2.1 The Incident

2.0 Description of Incident
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At this time, the chief called for mutual aid from the Friendswood and

Alvin VFDs. He also requested that law enforcement evacuate

residents of West Clover Lane and the next streets to the east and

west of the Third Coast facility.

As the chief moved north and attempted to enter the facility down

the alleyway between warehouses 3 and 4, he heard two loud

explosions from the tank farm area and backed away. Returning to

the south end of the facility, he observed that the fire had greatly

increased in size and intensity, with pressure and rupture noises much

louder and stronger. He notified arriving units to stage at County

Road 129, approximately 500 feet from the facility.

Insufficient water was available to fight the fire. A maximum flow of

750 gallons per minute (gpm) was established through a tanker relay

system using three portable dump tanks. Firefighters ran a firewater

monitor to protect residential exposures on the east side of West

Clover Lane. Based on the lack of water and the risk of environmental damage due to runoff from contaminated firewater, the decision

was made not to attack the fire.

As the fire spread into the storage tank area, the liquid pool fire was

also observed to be moving from the warehouse 1 area toward the

front of the facility. This caused the fire to spread to a loaded box

trailer and warehouse 2, and also across the southern property line

into a neighbor’s garage and machine shop. Over the course of the

next several hours, the fire engulfed the entire tank farm and spread

through warehouses 2, 3, and 4 (Figures 4 and 5)

The fire was allowed to burn until it was deemed to be of a manageable size for the available water supply. Hand lines were then used,

and firefighting foam was applied to extinguish the remaining fire

spots. The fire was brought under control by midnight—23 hours

after first being reported. The fire departments maintained fire watch

and scene control until 12:30 pm on May 2, when they were relieved by a fire control contractor hired by Third Coast.

The evacuated residents living on West Clover Lane, closest to the

facility, were unable to return to their homes until May 4. On the

south side of the facility, the fire destroyed both a small building and a

small business on adjacent private property. Several homes required

extensive internal and external cleaning to remove soot and smoke

damage. Contaminated soil (2,420 cubic yards) classified by EPA

Based on the lack of water and

the risk of environmental damage

due to runoff from contaminated

firewater, the decision was made

not to attack the fire.

The fire was brought under control

by midnight—23 hours after first

being reported.
21

as nonhazardous industrial waste; soot/ash (10 cubic yards); and

trees and debris (50 cubic yards) were removed from the site for

disposal. Approximately 900,000 gallons of oily and nonoily liquid

waste was also removed from the site.

In July 2002, Third Coast entered into a Voluntary Cleanup Agreement with TCEQ for remediation of the fire scene. Third Coast has

announced that it will not rebuild at this site.

Figure 5. Fire at approximately 7 am, May 1, 2002.

Mark Turvey, Friendswood VFD, Texas

Figure 4. Peak hours of fire, early morning, May 1, 2002.
22

2.2 Fire Origin

Based on the statements of the security guard and the first firefighters

on scene, it is most likely that the fire started outside, directly adjacent

to warehouse 1. After an exhaustive investigation, BATF ruled that

the cause of the fire was “undetermined”—meaning that it could not

conclusively state whether the fire was accidental or deliberately set.

CSB identified a number of possible initiating events, but was unable

to identify which of the following was most likely:

 Flammable or combustible liquids contacting hot surfaces:

Flammable liquids may have contacted hot surfaces, such as

motors or light bulbs. Small quantities of flammable cleaning

solvents were used around the packaging lines. In addition, if

released under pressure as aerosols, combustible liquids act like

flammable liquids.

 Spontaneous combustion of solvent-soaked rags: Although

Third Coast typically stored solvent-soaked rags in special rag

containers, solvent-soaked material could spontaneously combust if mishandled.

 Electrical fire: A consultant retained by Third Coast Industries

identified an electrical short in an office area inside warehouse

1 as a possible point of fire origin. However, the CSB investigation and witness interviews do not support this theory.

 Arson or vandalism: The security guard was at the facility for

only about 1 hour each night. Although the site is fenced, it is a

large area. It could not be ruled out that someone entered the

facility and deliberately set a fire, though the guard did not see

anyone inside the plant.

2.3 Fire Spread

Based on firefighter observations, examination of the fire scene, and

Third Coast information on the materials present onsite at the time of

the fire, CSB identified three mechanisms that contributed to the

rapid spread of the fire:

Mechanisms

Theories

After an exhaustive investigation,

BATF ruled that the cause of the fire

was “undetermined” . . .
23

 Rupture of drums of combustible liquid at packaging line 4,

outside warehouse.

 Failure of blend tanks.

 Failure of combustible liquid tank wagon.

In the initial stages of the fire, it is likely that the first materials involved

were small containers of combustibles and flammables located in and

around warehouse 1. On the night of April 30, Third Coast employees had been packaging motor oil, hydraulic oil, and gear oil in quarts

and 5-gallon pails. In addition, small amounts of methyl ethyl ketone

and other flammable solvents were used for cleanup and surface

preparation at the packaging lines.

The initial small fire involving the smaller containers resulted in a pool

fire, which provided the heat necessary to pressurize the drums of

combustible liquids. It is likely that the drums ruptured and added

fuel to the pool fire, which then spread, affecting the tank wagon

and the blend tanks. This is the point at which CSB believes the

Pearland Fire Chief observed the pool fire.

2.3.1 Rupture of Drums

Approximately 10 drums of combustible liquid were located on and

around packaging line 4, just outside warehouse 1 (Figure 6). The

drums would have loosely surrounded the worktable, where the

security guard observed the initial fire. Evidence indicates that these

drums ruptured due to internal pressure and released their contents,

which subsequently ignited. The sounds heard by the Pearland Fire

Chief upon his arrival on scene were most likely caused by the drums

rupturing.

The drums at packaging line 4 were of standard metal construction

without drum relief devices. This device is a plastic closure that melts

during fire exposure and remains open, allowing pressure to vent. It

is an option for flammable and combustible liquid containers. The

drum relief device protects the container from failure, which would

release the entire contents, and also helps prevent the risk of drums

rocketing into the air and causing damage when they fall. Empty

drums were found on property surrounding the Third Coast site.

Figure 6. Drums located at

packaging line 4.

The initial small fire involving

the smaller containers resulted

in a pool fire, which provided

the heat necessary to pressurize the

drums of combustible liquids.

Evidence indicates that these drums

ruptured due to internal pressure

and released their contents,

which subsequently ignited.
24

2.3.2 Failure of Blend Tanks

Several 2,000-gallon blend tanks were located to the northeast of

warehouse 1. The tanks were supported about 3 feet above ground

by steel legs with no external fireproofing. As the pool fire

surrounded this area, the legs buckled, and the tanks toppled and

contributed their contents to the fire (Figure 7).

Figure 7. Collapsed blend tanks located

near warehouse 1.

The blend tanks were located directly adjacent to the storage tank

farm, separated by a low dike wall. In addition, numerous steel pipes

from the storage tanks traversed the dike walls. Although valves were

closed at the end of each pipe, the lines were typically not isolated

with closed valves at the storage tanks. As the pipelines failed due to

fire exposure, they released materials from the storage tanks that also

contributed to the pool fire.

2.3.3 Failure of Tank Wagon

An aluminum tank wagon containing a combustible liquid synthetic

motor oil (flash point > 400oF) was located within 6 feet of packaging line 4, where the security guard initially observed the fire. Third

Coast was repackaging the material from the tank wagon into smaller

containers for retail sale. The Pearland Fire Chief saw this tank

wagon engulfed by the pool fire. The tank was venting, indicating

that it was already being heated to a significant temperature.

Several 2,000-gallon blend tanks

were located to the northeast

of warehouse 1.

As the pool fire surrounded this area,

the [tank] legs buckled, and

the tanks toppled and contributed

their contents to the fire.

As the pipelines failed . . . they

released materials from the storage

tanks that also contributed

to the pool fire.
25

In a fire of this type, aluminum rapidly weakens and melts. All that

remained of the liquid compartment of the tank wagon after the fire

were several pools of aluminum, as shown in Figure 8. The tank

wagon’s load of fuel contributed to the ground fire, which flowed

toward the storage tanks and the warehouses.

Figure 8. Remains of tank wagon, front end in

foreground. (Note pools of melted and resolidified

aluminum.)

2.3.4 Liquid Pool Fire at

Tank Farm and Warehouses

The Third Coast facility lacked adequate drainage or containment to

prevent liquids released from the drums, blend tanks, and tank wagon

from flowing toward the rest of the facility or offsite. The dike wall

on the south side of the tank farm, closest to the fire origin, was

composed of two courses of hollow cinderblock. The cinderblock

was broken in places and mortared joints were cracked, which

allowed the burning liquid to enter the tank farm and begin pooling

around the storage tanks. The intense heat from the fire caused the

bulk storage tanks to fail, either by overpressure or collapse; the

containerized combustible liquids stored inside burned and destroyed

the warehouse buildings (Figures 9 and 10).

The tank wagon’s load of fuel

contributed to the ground fire,

which flowed toward the

storage tanks and the warehouses.

The Third Coast facility lacked

adequate drainage or containment

to prevent liquids released

from the drums, blend tanks, and

tank wagon from flowing toward

the rest of the facility or offsite.

The cinderblock [wall] was broken in

places and mortared joints were

cracked, which allowed the burning

liquid to enter the tank farm and begin

pooling around the storage tanks.
26

Figure 9. Failed storage tanks.

Figure 10. Remains of warehouse.
27

3.0 Analysis of Incident

3.1 Fire Protection

There is no evidence that Third Coast or its insurance company

conducted formal fire protection analyses, consulted fire

protection experts, or reviewed best practice publications, such as

those of FM and IRI. The NFPA 30 Flammable and Combustible

Liquids Code, though not a requirement in Brazoria County, states:

The extent of fire prevention and control provided for

tank storage facilities shall be determined by an engineering evaluation of the installation and operation, followed

by the application of sound fire protection and process

engineering principles (NFPA, 2000; 2.5.4).

Good practice would extend this evaluation to the entire facility,

including materials handling and warehousing activities. The

Center for Chemical Process Safety (CCPS) notes that consensus

codes:

. . . allow the building official to require a technical

opinion or report identifying and developing alternate

methods of construction or protection from hazards that

are presented by the storage of hazardous material

(CCPS, 1998; p. 69).

As discussed in Sections 3.5 and 3.7, neither the State of Texas

nor Brazoria County required that Third Coast comply with fire or

building codes. However, a fire protection analysis, as required by

fire codes applicable in many other localities, would likely have

identified the shortcomings dicussed in this investigation report.

Third Coast would have been able to evaluate how best to

eliminate the hazards or mitigate the consequences of a fire. The

most likely result would have been identification of the need for:

 An onsite water supply for both manual and automatic fire

suppression.

 Fire detection equipment.

 Improved drainage and containment of large liquid spills.

In 2000, the Pearland VFD visited Third Coast to tour the facility and

give firefighters the opportunity to observe fire hazards. The VFD

assessment included the following observations of the site:

 Construction type: nonprotected metal

 Firewalls: none

 “Water supply minimal, no fire protection systems in place.”

Analysis

. . . A fire protection analysis, . . .

would likely have identified the

shortcomings discussed

in this investigation report.

Third Coast would have been able

to evaluate how best to eliminate

the hazards or mitigate the

consequences of a fire.
28

The preplan assessment also contained the following notes: “Was

suggested to install early warning device as a minimum and fire

suppression system. Also need water source!” There was no requirement for Third Coast to comply with these suggestions and no

evidence that it responded to the assessment.

3.2 Fire Origin and

3.2.1 Fire Origin

CSB and BATF were unable to conclusively determine the initiating

event or the exact point of origin of the fire. However, based on the

following facts and observations, it is most likely that the fire originated outside of warehouse 1 on or near packaging line 4:

 The security guard stated that the fire initially appeared to be

located on a worktable at packaging line 4, outside the building.

 Upon his arrival, the Pearland Fire Chief observed the pool fire

in front of warehouse 1. He did not believe that the warehouse itself was involved in the fire at that time.

 If the fire had originated inside warehouse 1, it is likely that this

would have been readily apparent to the security guard and the

firefighters. Warehouse 1 would have been seen as heavily

involved in fire before the outside areas and packaging line 4

were affected.

3.2.2 Initial Fire Detection

The Third Coast facility did not have automatic fire or heat detectors

in operating or warehouse areas.4

 Heat detectors are commonly

used in flammable liquid processing areas and would have been

activated if the fire originated outside warehouse 1. If the fire originated inside the warehouse, or if fire or smoke traveled inside the

4

 A laboratory area was equipped with an automatic Halon fire suppression system

Detection

. . . It is most likely that the fire

originated outside of warehouse 1

on or near packaging line 4.

The Third Coast facility did not

have automatic fire or heat detectors

in operating or warehouse areas.
29

building during the early stages of the fire, smoke or heat detectors

would have been of value in preventing loss of the facility. FM

Global Property Loss Prevention Data Sheets, a source of good

practices for hazardous operations, state:

Automatic fire detectors can provide early detection and

warning of fire or smoke. They may be used to activate

extinguishing systems or to initiate an alarm, or both .

. . . Although fire detectors can be a valuable part of a

property’s fire protection system, they are not considered

a substitute for automatic sprinklers or other automatic

extinguishing systems (FM, 2000a).

Smoke and heat detection equipment can be set up to automatically

notify a central alarm dispatch center or a local fire station.

If the fire had been detected in its earliest stages, it is likely that the

local fire department would have brought it under control before the

release of large quantities of combustible and flammable liquids,

which fed the fire. Fire trucks typically carry several hundred gallons

of water and some firefighting foam, which likely would have been

sufficient to extinguish a small fire. In addition, Third Coast had a

number of 40-pound dry chemical fire extinguishers onsite that could

have been used. Although the contract security guard stated that the

fire was too intense for him to safely approach, it was initially confined to a small area.

Regardless of the source of the initial fire, automatic fire detection

equipment—coupled with an automatic suppression system in the

area of the packaging lines in and around warehouse 1—would likely

have controlled the fire and summoned the Pearland VFD to control

and extinguish residual burning.

3.3 Fire Spread

By the time firefighters arrived at Third Coast, the fire had escalated

to the point where it could not be controlled with the limited water

available. CSB determined that a number of deficiencies in the

design and layout of the facility, as described below, contributed to

spread of the fire.

If the fire had been detected

in its earliest stages, it is likely that

the local fire department would

have brought it under control before

the release of large quantities

of combustible and

flammable liquids . . .

Regardless of the source of the

initial fire, automatic fire detection

equipment—coupled with an

automatic suppression system . . .

would likely have controlled the fire

and summoned the Pearland VFD

to control and extinguish

residual burning.
30

3.3.1 Rupture of Drums

The Pearland Fire Chief’s initial observation of a pool fire surrounding the box vans and the tank wagon indicates that the drummed

material near packaging line 4 was likely the first large quantity of

liquid involved in the fire. Steel drums exposed to a pool fire will

typically rupture within 5 to 15 minutes due to the buildup of internal

pressure. “The end result of a sealed drum exposed to fire is the

violent failure of the container” (FM, 2000b). When the drums

ruptured, their contents added more fuel to the growing fire and

spread it faster.

The drums at Third Coast were not equipped with relief devices in

their top heads. Relieving style containers vent internal pressure

without initially releasing the liquid contents. Although consensus

codes do not require that metal containers be equipped with relief

devices, fire sprinkler requirements are reduced if containers are so

equipped.

Although drum relief devices do not prevent ultimate failure and

release of liquid contents when exposed to a long-duration fire, they

do allow for longer retention of liquid. If the Third Coast drums had

been equipped with relief devices, it is likely that they would have

largely vented pressure rather than rupturing.

3.3.2 Location of Tank Wagon

and Blend Tanks

The tank wagon (which contained a synthetic motor oil for repackaging) and several blend tanks were located very close to the operating areas of warehouse 1. For Class III liquids, NFPA 30 and OSHA

1910.106 require that loading/unloading facilities be located at least

15 feet from tanks, warehouses, or other plant buildings.

The tank wagon was stationed less than 6 feet from packaging line 4.

NFPA 30 further states that “loading and unloading facilities shall be

provided with drainage systems or other means to control spills.” An

explanatory note adds:

Steel drums exposed to a pool fire

will typically rupture within 5 to 15

minutes due to the buildup

of internal pressure.

If the Third Coast drums had been

equipped with relief devices, it is

likely that they would have largely

vented pressure rather than rupturing.

The tank wagon . . . and several

blend tanks were located

very close to the operating areas

of warehouse 1.
31

The intent of this requirement is to prevent the spread of

uncontrolled, spilled liquid from traveling beyond the

loading or unloading area and exposing surrounding

equipment and buildings (NFPA, 2000; 5.6.4, A.5.6.4).

This is exactly what occurred at Third Coast, with the additional

complication that the liquid was burning.

3.3.3 Lack of Proper Drainage

or Spill Containment

The drums outside warehouse 1, the tank wagon, and the blend

tanks were not located in a curbed area, nor was the drainage

adequate to remove spills. As a result, once the drums began to

rupture and release their contents into the fire, there was no means

to prevent the pool fire from spreading to the tank wagon and the

blend tanks. FM directs that such facilities:

Supply loading and unloading stations with either

curbing, drainage, grading, or a combination to direct a

potential liquid spill to a collection location that is

accessible to fire fighting and liquid recovery operations,

but does not expose important buildings or facilities

(FM, 2000c; p. 35).

3.3.4 Tank Design, Condition of Tank

Farm Dikes, and Location of Storage Tanks

The storage tank areas at Third Coast were not designed to limit the

spread of fire. Because the tanks did not have relief devices suitable

for external fire scenarios, they catastrophically ruptured and released

their contents rather than venting to the atmosphere. NFPA 30 and

OSHA 1910.106 require that aboveground storage tanks have

emergency relief venting in the form of construction5 or a device

5

 One form of construction used in tank design is a frangible roof, which is a weak roof-toshell attachment that preferentially fails over other welded joints when subject to

overpressure. Failure of the roof-to-shell joint provides a means to relieve overpressure

and avoid a catastrophic failure of the tank and loss of contents.

. . . Once the drums began to rupture

and release their contents into the fire,

there was no means to prevent

the pool fire from spreading

to the tank wagon and the blend tanks.

Because the tanks did not have relief

devices . . . they catastrophically

ruptured and released their contents

rather than venting to the atmosphere.
32

to relieve excess pressure caused by an exposure fire (NFPA, 2000;

2.2.5.2.1).6

The NFPA requirement applies to Class I, II, and IIIA tanks, and also

to IIIB tanks if they are located in the same diked area as tanks storing

Class I or II liquids. Class IIIB liquids are specifically exempt from the

OSHA flammable and combustible liquids regulation. However,

because 27 of the 69 tanks storing Class IIIB liquids at Third Coast

were located in diked sections of the tank farm that also contained

Class I and II materials, they were covered under OSHA 1910.106.

The storage tanks were located within 1 foot of the dike wall; in the

vicinity of the initial fire, the wall was composed of two courses of

hollow masonry cinderblock. The wall was in poor condition and

cracked in some spots (Figure 11), which facilitated spread of the

pool fire. Because of the proximity of the tanks to the wall and

processing areas, radiant heat from the pool fire would have heated

the contents of the closest tanks.

6

 OSHA 1910.106(b)(2)(v)(a).

Figure 11. Section of south dike wall, storage tank farm.

. . . Because 27 of the 69 tanks storing

Class IIIB liquids at Third Coast

were located in diked sections

of the tank farm that also contained

Class I and II materials, they were

covered under OSHA 1910.106.
33

7

 NFPA defines “fire resistance rating” as the time that materials or assemblies withstand

a fire test exposure as measured per procedures in NFPA 251, Standard Methods of Tests

of Fire Endurance of Building Construction and Materials.

The warehouse walls at Third Coast

were constructed of corrugated metal.

It is likely that they would have lasted

only 15 to 30 minutes before failing.

“Manual fire suppression

is not normally dependable as

a primary fire protection strategy

for chemical storage warehouses.”

3.3.5 Warehouse Firewalls

NFPA 30 requires that warehouses storing Class IIIB materials have

firewalls and fire doors with a 2-hour fire-resistance rating (NFPA,

2000, 4.4.2.1).7

 The presence of more highly flammable materials

raises the fire-resistance rating requirement to 4 hours. The firewall

must also be designed to remain stable after collapse of the structure

due to fire on either side of the wall. CCPS states that building fire

separations:

. . . increases the likelihood of control of a fire situation

by exposing a limited area that is considered manageable

by automatic and manual suppression efforts, or by a

building’s containment/drainage design (CCPS, 1998;

p. 89).

The warehouse walls at Third Coast were constructed of corrugated metal. It is likely that they would have lasted only 15 to 30

minutes before failing. As a result, the fire quickly breached the

warehouse walls and moved through the facility.

3.4 Water for

The lack of water onsite was a major factor contributing to loss of

the Third Coast facility. In manual firefighting, hydrants provide

water for fire hoses or monitor nozzles. In automatic firefighting, the

heat from a fire typically activates sprinkler and deluge systems.

CCPS states:

Manual fire suppression is not normally dependable as a

primary fire protection strategy for chemical storage

warehouses. Fires may grow to uncontrollable size

before effective manual response can be employed, and

may pose severe risks to firefighters (CCPS, 1998;

p. 113).

CSB determined that if Third Coast had met the requirements of

OSHA 1910.106, it is likely that the fire spread would have been

limited to the warehouse 1 area.

Manual or Automatic

Fire Suppression
34

Third Coast was located more than 1 mile from the closest municipal

source of water. The facility had small wells for potable water and

for miscellaneous uses. One-inch water hoses were available to

extinguish small fires. In addition, several types of fire extinguishers

were located throughout the plant site.

Firefighting water could have been made available in several ways.

For example, a large storage tank or pond could maintain a water

inventory for automatic suppression systems, such as sprinklers or

deluge systems, and for fire hydrants.

During the Third Coast fire, firefighters were able to maintain only a

750-gpm flow of water, which was used mainly to protect houses

and structures outside the fenceline. This water flow was provided

by fire trucks relaying water from the distant hydrants to portable

water tanks. The Pearland Fire Chief estimated that 7,500 gpm

would have been required to attack the fire.

OSHA, NFPA, and consensus fire codes do not require manual

or automatic fire suppression if certain limitations are met with

respect to:

 Amount of flammable or combustible material stored.

 Location of storage with respect to other storage areas and

buildings.

 Construction of facility.

 Location of facility with respect to fencelines and other occupancies.

These limitations are the least stringent for Class IIIB materials.

However, because of warehouse construction, proximity of

fencelines, and amount of material stored, Third Coast did not meet

these requirements and additional fire suppression measures should

have been in place.

Environmental impacts from the runoff of contaminated firefighting

water are always a concern; there is commonly a tradeoff between

aggressively applying water and allowing the fire to burn. One of the

factors considered during response to the Third Coast fire was the

consequence of firewater runoff reaching water drainage ditches;

Third Coast did not have adequate provisions for containment of

such foreseeable contaminants.

. . . Firefighters were able to maintain

only a 750-gpm flow of water,

which was used mainly to protect

houses and structures outside the

fenceline. This water flow was

provided by fire trucks relaying water

from the distant hydrants to portable

water tanks.

OSHA, NFPA, and consensus fire

codes do not require manual or

automatic fire suppression if certain

limitations are met . . . However,

because of warehouse construction,

proximity of fencelines, and amount

of material stored, Third Coast did

not meet these requirements and

additional fire suppression measures

should have been in place.
35

Third Coast Industries was not

obligated by State or County

regulations to abide by NFPA

or other relevant consensus

fire or building codes.

Third Coast Industries was not obligated by State or County regulations to abide by NFPA or other relevant consensus fire or building

codes. However, these codes are used in most other states and

localities to provide a basis for designing and operating facilities to

prevent and mitigate fires.

3.5.1 NFPA Flammable and

Combustible Liquids Code

NFPA 30, Flammable and Combustible Liquids Code, covers:

 Bulk storage of liquids in tanks and similar vessels.

 Storage of liquids in containers and portable tanks in storage

areas and warehouses.

 Handling of liquids in manufacturing and related operations

and processes (NFPA, 2000).

NFPA 30 was first written as a model municipal ordinance in 1913,

as “Suggested Ordinance for the Storage, Handling, and Use of

Flammable Liquids.” It was changed to a code in 1957. NFPA

develops and modifies its standards through a consensus process;

standards are revised on a 3- to 4-year schedule.

3.5.2 Other Consensus Fire Codes

Many jurisdictions within the United States have adopted other

model building and fire codes developed by one of the following

regional organizations:

 Building Officials and Code Administrators, Inc. (BOCA National Fire Code).

 Southern Building Code Congress International, Inc. (Standard

Fire Prevention Code).

 International Conference of Building Officials (ICBO International Building Code).

 Western Fire Chiefs Association (Uniform Fire Code).

3.5 Consensus Fire

Codes
36

In 2000, the BOCA, Southern Building Code Congress, and ICBO

merged to establish the International Code Council (ICC). Its

primary objective is to develop a single set of comprehensive model

construction codes. ICC developed the first edition of the International Fire Code (IFC), which some jurisdictions have begun to

adopt, though many still enforce one of the older regional codes

listed above.

The IFC relies heavily on NFPA 30 for technical fire protection

requirements. Flammable and combustible liquids make up one part

of the fire codes, which also cover residential, mercantile, and

various special occupancies, such as hospitals and dormitories. In

2003, the NFPA fire prevention code (NFPA 1) and the Uniform

Fire Code will be merged to form a new NFPA 1, the Uniform Fire

Code.

In comparing NFPA 30 and the IFC, the CSB fire prevention consultant found the requirements for flammable and combustible liquids

to be roughly comparable.

3.5.3 Third Coast

Adherence to Fire Codes

As detailed in Section 3.7, no State or County regulations required

Third Coast to abide by NFPA 30 or any other fire code. However,

NFPA 30 and other consensus fire codes represent good practices in

the area of fire prevention. As detailed above, CSB identified significant areas where the Third Coast facility fell short of these good

practices:

 No fire prevention analyses were conducted. Any such analyses would likely have identified the need for both automatic

detection and onsite water to control hazards associated with

the flammable and combustible liquids inventory, as well as

effective liquid drainage and containment.

 There was no source of water for manual or automatic fire

suppression.

 The site had inadequate drainage and curbing in the location of

the packaging line, tank wagon, and blend tanks at warehouse 1.

The IFC relies heavily on NFPA 30

for technical fire protection

requirements.

The site had inadequate drainage and

curbing in the location of the packaging

line, tank wagon, and blend tanks

at warehouse 1.
37

 Storage tanks were inadequately designed and sited.

 Warehouse walls did not meet fire-resistance ratings.

If the Third Coast facility had complied with good fire protection

practices, it is likely that the fire spread would have been limited to

the warehouse 1 area.

3.5.4 NFPA 30 Issues

Third Coast was not legally obligated to comply with NFPA 30.

However, it is the key code for flammable and combustible liquids in

the United States and serves as the basis for many other consensus

fire and building codes—and for the OSHA Flammable and Combustible Liquids standard (1910.106).

In the course of this investigation, CSB identified several aspects of

NFPA 30 that should be studied to determine if changes are warranted to mitigate or prevent incidents of this type:

 NFPA 30 does not specify requirements for fire detection,

which are particularly applicable to facilities without automatic

fire suppression. Better fire detection at Third Coast might

have provided firefighters with enough time to contain the

small initial fire.

 Although NFPA 30 allows for reductions in automatic sprinkler

requirements if relief devices are used, it does not require them.

However, the use of relief devices on the Class IIIB liquid

containers at Third Coast would likely have prevented their

explosive rupture, thus slowing the spread of the pool fire.

 NFPA 30 exempts Class IIIB liquids from many of the storage

requirements imposed on more flammable liquids. However,

once ignited, Class IIIB liquids pose the same fire threat as

lower flash point liquids, as exemplified by the fire spread at

Third Coast.

If the Third Coast facility

had complied with good fire protection

practices, it is likely that the fire

spread would have been limited

to the warehouse 1 area.

Better fire detection at Third Coast

might have provided firefighters

with enough time to contain

the small initial fire.

. . . The use of relief devices

on the Class IIIB liquid containers

at Third Coast would likely have

prevented their explosive rupture,

thus slowing the spread

of the pool fire.

. . . Once ignited, Class IIIB liquids

pose the same fire threat as

lower flash point liquids . . .
38

8

 29 CFR 1910.106(a)(18)(ii)(b).

3.5.5 International Fire Code Issues

As similarly stated above for NFPA 30, CSB believes that certain

aspects of the IFC affecting Class IIIB liquids should be studied.

Specifically:

 Because the chapter on Flammable and Combustible Liquids

references NFPA 30 extensively, the code should be revised to

reflect NFPA 30 updates.

 Like NFPA 30, the IFC exempts Class IIIB liquids from certain

storage requirements; however, if ignited, these liquids pose the

same fire threat as lower flash point liquids.

3.6 OSHA Flammable

Flammable and Combustible Liquids, 29 CFR 1910.106, is the key

OSHA standard related to the protection of workers from fire hazards at Third Coast. It was promulgated in 1974, based on the 1969

version of NFPA 30, and has not been substantially modified since

that date. This standard specifically exempts Class IIIB combustible

liquids from coverage: “This section does not cover Class IIIB

liquids. Where the term Class III liquids is used . . . it shall mean

Class IIIA liquids only.”8 The 1969 version of NFPA 30 has been

significantly revised, most recently in 2000.

OSHA determined that 1910.106 requirements were applicable to

Third Coast because it stored and handled Class I, II, and IIIA

liquids—both in bulk and containerized storage. OSHA chose not to

issue a violation because the fire did not expose employees to risk,

and not all of the legal elements required for issuance of a violation

were present. However, OSHA did warn Third Coast that

1910.106 was applicable.

. . . The [IFC] code should be revised

to reflect NFPA 30 updates.

OSHA determined that 1910.106

requirements were applicable

to Third Coast because it stored and

handled Class I, II, and IIIA liquids—

both in bulk and containerized storage.

and Combustible

Liquids Standard
39

Third Coast fell short of compliance with 1910.106 in the following

areas:

 Storage tanks: Spacing, pressure relief for external fires, dike

construction and capacity, and fire resistance for elevated tank

support structures.

 Operating areas: Spill containment and drainage, and separation distance for tank wagon unloading.

 Warehousing: Spacing between buildings and bulk storage,

and between buildings and adjoining property and firewalls.

 Water: Availability of water to supply hose streams, foam

equipment, and automatic sprinklers, as indicated by operational and storage hazards.

Although NFPA 30 has undergone significant changes since 1969,

based on full-scale fire tests to determine how to best extinguish

flammable and combustible liquid fires, and on investigation of fire

incidents, OSHA currently has no plans to revise 1910.106.

The following Class IIIB liquid storage issues are addressed by consensus codes, but are not addressed in 1910.106:

 Bulk storage tanks

Minimum distances from bulk storage tanks to the nearest

side of any public way or nearest important building on the

same property.

Minimum shell-to-shell spacing requirements between bulk

storage tanks.

 Liquid warehouse storage

Maximum height and quantity (gallons) for piles of storage

containers. These specifications vary depending on

whether the piles are protected by fire sprinklers.

Fire-resistance ratings for internal and external walls of

rooms and buildings storing Class IIIB liquids.

 Engineering evaluation

Evaluation of the installation and operation of tank storage

facilities and application of fire protection and engineering

principles.

Third Coast fell short of compliance

with 1910.106 in the following areas:

 Storage tanks

 Operating areas

 Warehousing

 Water

Although NFPA 30 has undergone

significant changes since 1969 . . .

OSHA currently has no plans

to revise 1910.106.
40

9

 In 2003, Pearland will convert to the IFC.

10 SB10, an Act relating to the authority of certain counties to adopt and enforce a fire

code, 75th Legislature.

Despite the problems inherent in an out-of-date regulation, CSB

determined that full compliance with the requirements of 1910.106

would in all probability have controlled the spread of fire to the rest

of the Third Coast facility. However, compliance with the current

version of NFPA 30 (or compliance with an updated OSHA standard) would have provided an enhanced ability to prevent the

spread of fire.

OSHA is aware that 1910.106 is out of date and does not reflect

improvements in fire safety science and technology, as put forth in the

current version of NFPA 30. Although Third Coast was covered

under 1910.106, OSHA is also aware that many similar facilities may

contain Class IIIB materials exclusively and not come under 1910.106

coverage—and possibly pose grave risks to workers and the community. Although CSB concerns with 1910.106 are not directly material

to the Third Coast incident, CSB will inform the Assistant Secretary

of Labor for OSHA of its position on the need to consider updating

1910.106.

3.7 County Adoption

The Third Coast Industries Friendswood facility was not required to

comply with fire codes. In Texas, fire and building codes are not

enforced on a statewide basis. It is the responsibility of municipalities

and counties to both adopt and enforce fire and building codes.

Brazoria County has not adopted a fire code, though some municipalities within the County have, notably Pearland. The other Third

Coast facility, Third Coast Terminals, located within the City of

Pearland, is required to comply with the Standard Fire Prevention

Code (Southern Building Code Congress), which the city adopted as

its local fire code.9

Before 1997, only counties in Texas with populations of more than

250,000 had the authority to adopt a fire code. In 1997, the Texas

Legislature passed a law10 that allows suburban counties to adopt fire

of Fire Codes

. . . Compliance with the current

version of NFPA 30 (or compliance

with an updated OSHA standard)

would have provided an enhanced

ability to prevent the spread of fire.

In Texas, fire and building codes are

not enforced on a statewide basis.

It is the responsibility of municipalities

and counties to both adopt and

enforce fire and building codes.
41

codes if they are adjacent to counties with a population of at least

250,000. As of the 2000 census, Brazoria County had a population

of only 241,000; however, it is allowed to adopt a fire code because

it is adjacent to Harris County (population: 3,400,000).

The statutes connected with this law state that the fire code applies

in unincorporated areas of a county and that it must:

. . . conform to the Uniform Building Code or to a

national fire code adopted by the Southern Building

Code Congress, the National Fire Protection Association, or the Building Officials and Code Administrators

International.11

In 1992, for example, Collin County (2000 census population:

491,000), northeast of Dallas, adopted the IFC. Upon passing an

inspection and paying a fee, new businesses in unincorporated areas

are issued a Certificate of Occupancy by the Collin County Fire

Marshal’s office. Counties generally charge fees for inspections and

permits to offset fire code administration and enforcement costs

(Todd, 2001).

If a fire code had been in place in Brazoria County during construction of the Third Coast facility, it is likely that the specified level of

protection would have been sufficient to reduce the severity of the

Third Coast fire, thus allowing firefighters time to respond and limit

the damage. A fire code would have called for a fire protection

analysis and action to address the identified hazards, through means

such as:

 Ensuring the availability of water

 Installing fire suppression systems

 Reducing inventories of combustible liquids

 Increasing spacing between piles of materials

 Constructing fire-resistant walls in warehouse buildings

 Isolating and controlling bulk storage areas.

11 Texas Statutes, 233.061(c)(1).

If a fire code had been in place

in Brazoria County during

construction of the Third Coast

facility, it is likely that the specified

level of protection would have been

sufficient to reduce the severity

of the . . . fire, thus allowing

firefighters time to respond

and limit the damage.
42
43

4.1 Root Causes

1. Third Coast did not have a management system in place to

identify or analyze serious fire hazards that could affect the

plant, its employees, the surrounding community, or the environment.

Third Coast did not adequately analyze fire hazards or institute

fire protection measures to reduce the likelihood that a small fire

could spread and destroy the facility, endanger the public, and

damage the environment. A thorough fire protection analysis

would likely have identified the need for both automatic fire

detection and onsite water for fire suppression, as well as effective provisions to contain spilled chemicals that could spread the

fire. An analysis would also have identified the inadequate

warehouse construction and problematic location of flammable

and combustible materials.

2. Third Coast did not have adequate measures in place to contain

or control fires that could reasonably be expected to occur, with

resulting effects on the facility, the surrounding community, and

the environment. More specifically:

 The Third Coast facility had an inadequate system of fire

suppression to control the small initial fire or to stop the fire

from spreading.

 Onsite fire water was insufficient to mitigate fire hazards

posed by the inventory of flammable and combustible

materials.

Manual or automatic suppression systems were absent.

Smoke/fire detection equipment or alarms were absent.

 The Third Coast facility lacked adequate control measures

to limit the spread of the initial fire. Specific deficiencies

included:

A tank truck containing combustible material was located

too close to blending and packaging equipment, and the

area did not have adequate containment or drainage.

Blend tank legs were not insulated to prevent premature

failure from fire exposure.

4.0 Root and Contributing Causes
44

No containment or drainage was available to control

liquids that were released outside warehouse 1 during

the initial phase of the fire—which allowed the fire to

spread to the blend tanks and tank truck, and then to the

storage tank farm and the other warehouse buildings.

Inadequate design and construction of diking around the

storage tank farm allowed burning liquid to breach the

dike and pool around the storage tanks.

Warehouse buildings were inadequately designed and

constructed to mitigate fire hazards posed by the inventory of flammable and combustible materials.

 Exterior building walls were not built as 2-hour

firewalls, which would have slowed the spread of

the fire and likely allowed firefighters to take more

aggressive action.

 Warehouse buildings were located too close to each

other, and connecting offices and other rooms

breached the separation between buildings.

4.2 Contributing

Brazoria County had no laws or regulations that required Third

Coast to comply with widely accepted fire codes.

Cause
45

Third Coast Terminals

Audit the Third Coast Terminals facility in Pearland, Texas, in light of

the findings of this report. Take action to ensure that the facility’s fire

suppression and control procedures meet the relevant requirements

of NFPA 30 and OSHA 1910.106. (2002-03-I-TX-R1)

National Fire

Revise NFPA 30, the Flammable and Combustible Liquids Code, to

address the following issues (2002-03-I-TX-R2):

 For facilities that are not staffed around the clock, specify

circumstances where automatic fire detection is needed.

 Narrow exemptions for Class IIIB liquids.

 Expand fire protection analysis requirements to include all areas

of a facility where there may be flammable or combustible fire

risks.

International Code

Revise the International Fire Code to address the following issues

(2002-03-I-TX-R3):

 For facilities that are not staffed around the clock, specify

circumstances where automatic fire detection is needed.

 Narrow exemptions for Class IIIB liquids.

 Expand fire protection analysis requirements to include all areas

of a facility where there may be flammable or combustible fire

risks.

County of

Adopt a fire code, such as the NFPA Uniform Fire Code or the ICC

International Fire Code, for application in unincorporated areas.

(2002-03-I-TX-R4)

Protection Association

(NFPA)

 Council, Inc. (ICC)

Brazoria, Texas

5.0 Recommendations
46

Communicate the findings of this report to your membership.

(2002-03-I-TX-R5)

Independent Lubricant

Communicate the findings of this report to your membership.

(2002-03-I-TX-R6)

American Petroleum

Communicate the findings of this report to your membership.

(2002-03-I-TX-R7)

National Association

Communicate the findings of this report to your membership.

(2002-03-I-TX-R8)

National Association

Communicate the findings of this report to your membership.

(2002-03-I-TX-R9)

International Association

Communicate the findings of this report to your membership.

(2002-03-I-TX-R10)

National Volunteer

Communicate the findings of this report to your membership.

(2002-03-I-TX-R11)

Petroleum Packaging

Council (PPC)

Manufacturers Association

(ILMA)

Institute (API)

of Chemical Distributors

(NACD)

of Counties (NACo)

of Fire Fighters (IAFF)

Fire Council (NVFC)
47

National Association

Communicate the findings of this report to your membership.

(2002-03-I-TX-R12)

Risk and Insurance

Communicate the findings of this report to your membership.

(2002-03-I-TX-R13)

of State Fire Marshals

Management Society

By the

U.S. CHEMICAL SAFETY AND HAZARD INVESTIGATION BOARD

Carolyn W. Merritt

Chair

John S. Bresland

Member

Gerald V. Poje, Ph.D.

Member

Isadore Rosenthal, Ph.D.

Member

Andrea Kidd Taylor, Dr. P.H.

Member

March 6, 2003

(NASFM)

(RIMS)
48
49

6.0 References

Center for Chemical Process Safety (CCPS), 1998. Guidelines for

Safe Warehousing of Chemicals, American Institute of Chemical

Engineers (AIChE).

Factory Mutual Insurance Company (FM), 2000a. Automatic Fire

Detectors, FM Global Property Loss Prevention Data Sheet 5-

48, January 2000.

FM, 2000b. Flammable Liquid Storage in Portable Containers, FM

Global Property Loss Prevention Data Sheet 7-29, May 2000.

FM, 2000c. Flammable Liquid Operations, FM Global Property

Loss Prevention Data Sheet 7-32, September 2000.

National Fire Protection Association (NFPA), 2000. Flammable and

Combustible Liquids Code, NFPA 30.

NFPA, 1999. Standard Methods of Tests of Fire Endurance of

Building Construction and Materials, NFPA 251.

Todd, Heather, 2001. “Up To Code,” County Magazine, Texas

Association of Counties, Jan/Feb 2001.
50
51

Appendix A: Causal Factors Diagram

Fire start inside wh #1

Electrical fire in maint

area or spontaneous

combustion of rags or

aerosol and ignition

source, or arson

Fire inside leads to

multiple container failure

& creates pool fire, or

wh #1 is completely

engulfed and reaches

drums outside

Unlikely that

wh #1 is

completely

engulfed based

on witness

testimony

Unable to

determine cause

Security guard arrives

1:00 am

Guard sees fire in

front of wh #1

1:20 am

Guard calls 911

1:21 am

Pool fire spreads

outside warehouses

Fire starts outside

wh #1

Fire spreads

throughout area

Electrical fire or

spontaneous

combustion of rags or

aerosol and ignition

source, or arson

on or near fill station

Containers fail and

lead to pool fire

OR

OR

Tank truck

too close to

production

equipment No firewall on

wh #1

Pearland Fire Chief

on scene

1:28 am

No control

of flammable

liquid spill

inside wh #1

Flammables

outside too

close to wh #1

Tank truck of

IIIB flammable

involved

Unable to

determine cause
52

Liquid seen burning

and flowing toward

east (W. Clover Lane)

Neighbors evacuated

Facility too

close to fenceline

Fire spreads to wh #2

and tractor trailer on

scale

Fire spreads to tank

farm and other whs

No control

of flammable

liquids in

outside process

area

No control

of flammable

liquids in

outside process

area

Inadequate

dike wall on

tank farm

Fire engulfs tank farm

No fire

protection

measures in

tank farm

No fire

protection

analysis

Event on the main

timeline

Key

Causal factor

Explanatory

event
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