Journal of Hazardous Materials 308 (2016) 164–172

Contents lists available at ScienceDirect

Journal of Hazardous Materials

journal homepage: www.elsevier.com/locate/jhazmat

Case study and lessons learned from the ammonium nitrate explosion
at the West Fertilizer facility
Delphine M. Laboureur, Zhe Han, Brian Z. Harding, Alba Pineda, William C. Pittman,
Camilo Rosas, Jiaojun Jiang, M. Sam Mannan ∗
Mary Kay O’Connor Process Safety Center, Artie McFerrin Department of Chemical Engineering, MS-3122, Texas A&M University, College Station, TX
77843-3122, USA

h i g h l i g h t s

• In-depth technical analysis of the West, Texas ammonium nitrate incident.

• Regulatory analysis for compliance with federal, state and local regulations.
• Facility siting and land use planning implications.
• Need for local coordination of risk information and emergency planning.

a r t i c l e i n f o a b s t r a c t

Article history: In West, Texas on April 17, 2013, a chemical storage and distribution facility caught fire followed by
Received 8 September 2015 the explosion of around 30 tons of ammonium nitrate while the emergency responders were trying to
Received in revised form 13 January 2016 extinguish the fire, leading to 15 fatalities and numerous buildings, businesses and homes destroyed or
Accepted 14 January 2016
damaged. This incident resulted in devastating consequences for the community around the facility, and
Available online 18 January 2016
shed light on a need to improve the safety management of local small businesses similar to the West
facility. As no official report on the findings of the incident has been released yet, this article first investi-
Keywords:
gates the root causes of the incident, and presents a simplified consequence analysis. The article reviews
Case study
Ammonium nitrate
the regulations applicable to this type of facility and recommended emergency response procedures to
Consequence analysis identify gaps between what happened in West and the current regulations, and discusses how the cur-
Regulations rent regulations could be modified to prevent or minimize future losses. Finally, the federal response that
followed the incident until the publication of this paper is summarized.
© 2016 Elsevier B.V. All rights reserved.

1. Introduction
On April 17, 2013, an ammonium nitrate (AN) explosion
occurred in a chemical storage and distribution facility in West,
Texas, leading to 15 fatalities, and more than 200 injuries. The facil-
ity was completely destroyed and buildings, businesses and homes
were damaged up to 1 km from the plant [1]. AN has caused dozens
of major incidents in the last 100 years all over the world, from the
production, storage, and transportation of the material [2]. More
incidents and lessons learned can be found in literature [2].
This article presents an analysis of the West Fertilizer incident
and lessons learned from it. This paper is a preliminary study since
an official report summarizing findings from the incident has not
been released yet. In addition to the preliminary investigation of
the causes and consequences of the incident, the paper will present
a detailed analysis of AN storage regulations in the US—both the
existing regulations that have not been followed, and the gaps that
exist in the current regulations. Finally, the paper will discuss the
government response that followed the incident, up to the publi-
cation of this paper.
2. Incident description and analysis
2.1. West Fertilizer facility

West Fertilizer Company is a chemical storage and distribution

∗ Corresponding author. facility [3], located approximately 75 miles south of Dallas, in the
E-mail address: mannan@tamu.edu (M.S. Mannan). City of West, Texas. The facility was owned by Donald Adair from

http://dx.doi.org/10.1016/j.jhazmat.2016.01.039
0304-3894/© 2016 Elsevier B.V. All rights reserved.
 D.M. Laboureur et al. / Journal of Hazardous Materials 308 (2016) 164–172
Fig. 1. Left: West Fertilizer facility and its surroundings, Right: Warehouse.
Adair Grain Inc., [4] and employed less than 10 people [5]. In 2012,
the company reported annual sales of $4 million [6]. The facility lay-
out, shown in Fig. 1, included grain elevators located at the North
of the site. South of the grain elevators, a chemical warehouse con-
tained different fertilizers and herbicides. The main building was
12,000 square feet [7]. and contained seed bags packed in pallets,
and AN with 34% nitrogen (pure AN), stored in bulk granular form,
in a 24 ft high vertical wooden bin. AN was also stored in smaller
bins with 10 ft high wood panels as separation [7], together with
other substances like potash, ammonium sulfate, or K-MAG—a fer-
tilizer containing potassium, magnesium, and sulfur. Finally, south
of the office building, tanks of anhydrous ammonia (AA) [8] were
stored. Investigation later showed that 100 tons of AN was also
stored in a railcar on the facility [1].
In their 2012 Tier II report, West fertilizer claimed to store
540,000 pounds of AN, 110,000 pounds of anhydrous ammonia,
540 pounds of Grazonnext (herbicide) [9,10], 60 pounds of Reclaim
(herbicide), 192 pounds of Remedy Ultra (herbicide), 29.75 pounds
of Surmount (herbicide), and 400 pounds of Yuma (insecticide) [11].
2.2. Incident timeline
At 5 pm on April 17, 2013, the West Fertilizer plant closed for the
day. According to the facility owner’s son, no machinery was left on
[4]. At 7:30 pm, the local firefighters responded to a fire call at the
plant. At 7:51 pm, the AN stored in the plant exploded. More infor-
mation about the firefighter response is given in Section 3.2. From 8
pm, the emergency responders from North and Central Texas con-
verged on West. Injured survivors were transported to hospitals
in Waco, Temple, Fort Worth and Dallas, and the non-injured sur-
vivors were evacuated, including more than 100 residents from the
nearby nursing home. At 11 pm, the fire at the fertilizer plant was
under control but still smoldering. A storm the day after helped
contain the smoke.
The explosion destroyed a middle school, nursing home, numer-
ous residences, and businesses. In total, 50 structures were
damaged significantly, 100 structures were slightly damaged, and
an apartment complex was destroyed [12]. Debris were found up
to 2.5 miles from the plant [7]. Fifteen people died and 228 people
165
were sent to the hospital, among which 46 were admitted [12]. Of
the fifteen people killed, ten were firefighters, two were civilians
that responded to the fire, and three were civilians who lived in a
close-by residential area [7].
2.3. Ammonium nitrate hazards
According to the National Fire Protection Association [13] stan-
dards NFPA 490 and 704, AN is not considered flammable or
combustible. The EPA considers it a stable, generally difficult to
detonate compound [14]. However, factors like strong shock, high
temperatures under confinement or contamination can lead AN to
detonate [15].
The melting point of AN is around 170 ◦ C [14]. AN decomposes
by different ways, which are described by different equations,
producing various oxynitrides, and the most widely accepted
decomposition pathways are introduced here. At relatively low
temperatures (i.e., around 170 ◦ C), an endothermic reversible reac-
tion occurs as the melted AN vaporizes and forms ammonia and
nitric acid [10,16]:
NH4 NO3 (l)  HNO3 (g) + NH3 (g), H = 176 kJ mol−1
At higher temperatures (i.e., 170–280 ◦ C), an exothermic irre-
versible reaction occurs and AN decomposes into water and nitrous
oxide.
NH4 NO3 (l) → N2 O(g) + 2H2 O(g), H = −59 kJ mol−1
If AN is suddenly heated up to a relatively high temperature,
explosive decomposition will occur, producing nitrogen, oxygen,
and water [10,16].
2NH4 NO3 → 2N2 ↑ + O2 ↑ + 4H2 O, H = −1057 kJ mol−1
The risk of explosion is increased if AN is contaminated by either
organic or inorganic materials like chlorides or powdered metals
[17]. Buczkozski and Zygmunt [18] showed that the addition of alu-
minum dust to pure AN dramatically increases the heat of reaction
from 1592 to 6712 kJ kg−1 .
166 D.M. Laboureur et al. / Journal of Hazardous Materials 308 (2016) 164–172
2.4. Root cause analysis
Preliminary findings from the CSB [19] state that the explosion
at West fertilizer was caused by an intense fire involving 30 tons of
AN in wooden bins, but offer no conclusions regarding the source
of ignition or what additional factors played a role in the explo-
sion. From videos that recorded the progression of the initial fire,
GexCon observed that the fire started in the North East section of
the wooden warehouse that contained the seed room and a storage
bin with 20–30 tons of AN [1]. Therefore, the heat radiated from the
wooden warehouse fire could have increased the AN temperature
to a point where explosive decomposition would occur. However,
the other bin containing around 30 tons of AN located in the ware-
house did not explode, and neither did a railcar containing 100 tons
of AN [1].
What, if any role contamination played in the explosion had not
been determined by the CSB in their preliminary report. The CSB
also made no mention of insufficient volumes of water being used
to fight the fire or the role that could have played. Large volumes
of water must be used when fighting an AN fire. Otherwise, most
of the water will vaporize, and the heat removal by the steam will
not be enough to tackle AN fires. More importantly, a lot of gaseous
products will be generated fast in a short period of time, increasing
local pressure, resulting in confinement, which is a hazard in AN
fires and explosions. The nitrate itself can supply sufficient oxygen
for combustion of other materials, so the steam will not smother
the fire. Therefore, steam is not able to control the temperature
and consequently increase the degree of hazard due to confinement
[20].
By May 2013, the Bureau of Alcohol, Tobacco, Firearms and
Explosives (ATF) and the Texas State Fire Marshal’s Office (SFMO)
had eliminated several potential sources of ignition, including:
rekindling of an earlier fire, spontaneous ignition, 480 V electrical
system, anhydrous ammonia, AN, smoking, and weather. However,
it was not possible to rule out ignition from a 120 V electrical sys-
tem, a golf cart, or an intentionally set fire as potential sources
[21].
2.5. Consequence analysis
According to the CSB preliminary findings 30 tons of AN deto-
nated [19,22]. This value is compared to basic consequence analysis
based on the TNT equivalent method and the analysis of the sur-
rounding damages.
The TNT equivalent mass can be estimated through the size of
the crater created by the AN explosion. ATF stated at a press con-
ference that the crater was 28.3 m wide and 3 m deep [7,23,24].
Based on TNT experiments and previous literature, Ambrosini et al.
[25] validated the empirical equation of Kinney and Graham that
relates the diameter of the crater (D) to the TNT mass (WTNT ) for an
explosion at ground level [26], and which is expressed below with
mass in kg and distance in meters. Following this correlation, the
28.3 m wide crater would be created by 44.5 metric tons of TNT.
D = 0.8(WTNT )1/3
The relative effectiveness of AN compared to TNT is equal to
0.42 [27], where relative effectiveness means the relative mass of
TNT to which an explosive is equivalent (the greater the relative
effectiveness, the more powerful the explosive). Thus, 1 kg of AN
has the same demolition power as 0.42 kg of TNT and the esti-
mated AN mass based on the crater diameter is 106 metric tons.
This value is much higher than the CSB estimate of the AN mass
involved −30 tons.
Bull and Woodford showed that deviation in the estimation of
a crater size can reach 30–40% [28], and AN is known to have an
excellent cratering effect [27], which could lead to an overestima-
tion of the TNT mass from the investigation of the crater. In addition,
the AN effectiveness vary in literature from 0.25 [29] or 0.3–0.55
[30], to 0.84 [31]. In some papers, 0.346 was chosen as the AN
effectiveness, because it corresponds to the ratio of the heat of det-
onation of AN to the heat of explosion of TNT. So choosing a higher
effectiveness factor would bring the AN mass estimate closer to the
CSB value.
The TNT equivalent mass can also be estimated through a
damage analysis. Due to the severity of the incident, a lot of pic-
tures from the damaged surroundings are available through press
releases [32] or via Google Maps [33]. Fig. 2 shows damages on
buildings surrounding the West fertilizer plant, at six different dis-
tances from the AN storage building.
The damaged buildings as shown in Fig. 2 can be related to a
range of overpressure, depending on the severity of the damage
[34,35] and the overpressures estimated from the damages can be
linked to the TNT equivalent curve [36], which is plotted in Fig. 3 for
three different TNT masses; 44 metric tons as estimated from the
crater size, 30 metric tons taking the same TNT mass as the AN mass
estimated from CSB, and 12.6 metric tons that considers 30 metric
tons of AN, converted to TNT via the relative effectiveness factor
of AN of 0.42 [27]. It is difficult to conclude on the equivalent TNT
mass involved in the explosion from the damage analysis due to the
large uncertainty in the estimation of the overpressure, however,
it seems likely that the CSB value is an underestimation based on
Fig. 3. On the other hand, the CSB estimate receives some support
from Koch, who used 12.6t of TNT (30t of AN) to simulate the West
explosion with the software BREEZE ExDAM [22] and found that
the simulation closely matched the observed damage.
In conclusion, even though the simple correlations used in this
study cannot determine the exact amount of AN detonated, the
order of magnitude is validated both from the analysis of the crater
size and from the overpressure and damage analysis.
3. Regulatory analysis
Aside from the incident description in terms of the cause and
consequences, it is also important to investigate the regulatory
aspect of the incident to better understand the current regulations
and potential gaps around the storage and the facility siting of AN,
and together with the emergency response of AN incident, includ-
ing the understanding of the role they played in the catastrophe.
3.1. Ammonium nitrate storage
Different state and federal agencies regulate Texas fertilizer
plants like the one in West, TX [37,38]. This section will focus on
the regulatory analysis of AN storage, both on the violations of the
current regulations, and on the regulatory gaps.
3.1.1. Occupational Safety and Health Administration: OSHA
The OSHA standard 29CFR Section 1910.109(i) provides specific
requirements for the storage of more than 1000 pounds of fertilizer
grade AN in the form of crystals, flakes, grain, or prills containing
a minimum of 60% of AN. Compliance with OSHA requirements
means storing AN in a building no more than one story in height,
with adequate ventilation in the event of fire, dry and free from
water seepage, with available water supplies and fire hydrants [39].
Compliance with the OSHA Explosives and Blasting Agents
Standard, 29CFR 1910.109, has many measures that would have
prevented or mitigated the incident. Among the 26 citations
by OSHA after the incident [40], eight were related to Section
109(i) as described in Table 1. These violations were determined
by OSHA. National Fire Protection Association (NFPA) 400 [41]
 D.M. Laboureur et al. / Journal of Hazardous Materials 308 (2016) 164–172 167

Fig. 2. Damages after the West Fertilizer Explosion: (a) North part of West Fertilizer Plant (75 m from AN), (b) Apartment complex (140 m from AN) [32], (c) House (180 m
from AN) [32], (d) Senior citizen home (200 m from AN), (e) 300 m from AN, (f) 430 m from AN (Images a, d, e, and f taken from Google Street View).

Fig. 3. TNT equivalent curve compared with the overpressure estimated from the damages [36].

Table 1
OSHA citations for violations of 29CFR 1910.109[40].

Article Description

i.2.iii.b Adequate ventilation in the presence of a fire

i.2.iii.c Wall at 50 ft from a combustible building or material has to be fire-resistant.
i.2.iii.d All flooring should be noncombustible or protected against impregnation by AN, and without open drains or traps.
i.4.i.b Bulk storage of maximum 40 ft high except if facilities to fight a room fire are available
i.4.ii.b Wooden bins should be protected against impregnation by AN
i.4.iii.b Height or depth of piles shall be limited by the pressure-setting tendency of the product
i.5.i.a AN shall be in a separate building or shall be separated by approved type firewalls of not less than 1 h fire-resistance rating from storage
of other flammable, combustible or contaminant material
i.7.ii.b Water supplies and fire hydrants shall be available in accordance with recognized good practices
168 D.M. Laboureur et al. / Journal of Hazardous Materials 308 (2016) 164–172
provides recommendations about hazardous materials storage,
similar to Section 109(i) of the OSHA standard.
In addition to Section 109(i), West fertilizer was cited by OSHA
for violations of OSHA standards [40], Including 29CFR 1910.111
[42], 29CFR 1910.134 [43], 29CFR 1910.146 [44], 29CFR 1910.303
[45], and 29CFR 1910.1200 [46].
3.1.2. Department of Homeland Security: DHS
The Chemical Facility Anti-Terrorism Standard (CFATS) from
DHS has been developed to guarantee the security of high-risk
facilities, and addresses hundreds of chemicals, including AN. DHS
stated in the CFATS interim final rule that “if a retail establishment
does exceed any of these [screening threshold quantities], the retail
establishment will have to complete the Top-Screen” [47]. If the
facility stores more than 2000 pounds of a fertilizer mixture con-
taining at least 33% AN, AN with at least 23% nitrogen, or more
than 400 pounds of AN with more than 0.2% combustible substance,
the facility should follow CFATS [48]. It has been widely reported
that West Fertilizer Plant did not file a Top Screen report with DHS
as required under the CFATS regulation [49]. The facility was not
inspected by DHS for compliance with the CFATS requirements.
In December 2007, an amendment to the Homeland Security
Act was enacted to require DHS to regulate the “Secure Handling
of Ammonium Nitrate”. The proposed regulation is now at its final
stage [50], but is still not applicable and the last publication in the
federal register dates of 2011 [51].
3.1.3. Environmental Protection Agency: EPA
EPA has a general duty clause and specific regulations that apply
to West Fertilizer facility. Under the Clean Air Act Section 112(r)(1)
[52], the General Duty Clause applies to any stationary source pro-
ducing, processing, handling, or storing regulated substances or
other extremely hazardous substances which are any chemicals
listed in 40CFR 68 [53], or any other chemicals, which may be
considered extremely hazardous. AN is not listed as a regulated
substance, but anhydrous ammonia is [53].
The following specific EPA regulations also apply. First, West
Fertilizer would be regulated under the Program 2 requirements
of the EPA’s Risk Management Plan (RMP) rule (40CFR 68 [53])
because of the storage quantities of ammonia. In 2006, EPA fined
West Fertilizer Company for not having a Risk Management Plan
[54]. West Fertilizer facility last submitted a Risk Management Plan
in June 30, 2011. Second, West Fertilizer was required to file Tier II
reports, reporting of hazardous chemicals (AN is included) stored
above certain quantities [55]. Tier II reports are submitted to local
fire, emergency and response departments. Over the last seven
years, according to reports filed by West Fertilizer, 2012 was the
only year the company stored AN at the facility [56]. The Tier II
report for 2012 was filed in February 2013, two months before the
incident. There does not appear to be a Tier II report for 2013.
3.1.4. Texas Commission on Environmental Quality: TCEQ [38]
TCEQ is the environmental agency for the state of Texas. Their
goal is to ensure clean air, clean water, and the safe management
of waste [57]. TCEQ usually focuses its attention on major facilities,
rather than small facilities, as sources of air emissions.
TCEQ inspections are typically complaint driven. In 2006, an
investigation at West Fertilizer Co. was initiated after a complaint
of ammonia smell. TCEQ inspected the site and found that the
plant had been operating for two years without a necessary air
quality permit. After issuing appropriate permit, TCEQ never went
back to West Fertilizer Co [38]. West fertilizer Plant had two per-
mits: one for two 12,000 gallon anhydrous ammonia storage tanks,
and one for the material loading and storage operations of dry
fertilizer materials [38]. It is not known if West Fertilizer had all
the necessary permits per TCEQ.
3.2. Emergency response and firefighting
Firefighters received the call on their pager at 7:32 pm [58] [7].
The first trucks arrived at 7:38 pm and started to extinguish the
fire with the water in their truck. As the closest fire hydrant was
located 450 m from the facility, one truck was moved close to the
fire hydrant. As the fire was growing stronger and concerns about
smoke blowing over a residential area and presence of AA tanks
were increasing, one firefighter called for backup and the chief
arrived at 7:45 pm while other firefighters were still arriving to
the site and converging towards the fire. The Dallas Morning News
states that the firefighters agreed to back off and let the fire burn
at 7:50 pm [58].The Fire Department report states that several fire-
fighters thought the team should withdraw, but that no effective
order was given [7]. At 7:51 pm, the AN exploded.
The Emergency Response Guidebook (ERG) [59]. advises to flood
large AN fire areas with water from a distance and recommends
considering an initial evacuation of 800 m, which in West would
mean evacuating almost the whole city. NFPA 490 [13] and the
more recent NFPA 400 [41] advise keeping the AN mass cool, extin-
guishing the fire promptly by quickly applying large volumes of
water, and evacuating the area if the fire reaches uncontrollable
proportions. CSB concluded that these recommendations are not
clearly defined, and should be reviewed and harmonized [19].
In addition, the fire was beyond the early stage where it could
have been extinguished, given the limited resources and water sup-
ply [7]. A conservative rough estimate of the maximum amount of
water that may be needed to prevent AN from reaching 200 ◦ C can
be calculated. Once the temperature reaches 200 ◦ C, the runaway
reaction will start to occur very fast and generate a large amount of
heat, and it is very difficult to control after that. Considering an AN
mass of 270 tons [60], a heat capacity of 1.7 kJ kg−1 K−1 [61]with a
temperature gradient of 200 ◦ C − 20 ◦ C = 180 ◦ C and a heat capac-
ity of water of 4.2 kJ kg−1 K−1 [61] with a gradient of 10 ◦ C, the
amount of water required would be more than 500,000 gallons.
The AN would not be heated uniformly, and some parts could be
heated up faster than the rest. However, the water applied may
not be able absorb that particular part due to the relative posi-
tion of the heated part and water spray. Additionally, considering
water loss in the firefighting process, it may not be used fully to
absorb the heat generated by the fire. More importantly, if water
is close to its boiling point, a large amount of steam will be pro-
duced, increasing pressure, which is very dangerous to AN. Thus,
water is not expected to be heated to near 100 ◦ C. Therefore, it has
been assumed that the temperature of the water will increase only
10 ◦ C in cooling the AN. The average daily consumption for West in
2010 was around 410,000 gallons of water [62], which is less than
the estimated amount. Also, two wells supplying water were out
of service that day, leaving only 317,000 gallons of available water
[7]. This calculation does not prove that the firefighters could not
have extinguished the fire at West Fertilizer, but suggests that they
may not have been able to do so.
The Fire Departments report [7] suggests that the firefighters
that died did not fail in their duties, but that they were not suf-
ficiently trained and prepared. They were volunteers, and have
never been trained on fighting a fire at West Fertilizer [58]. NFPA
472 [63] and OSHA 1910.120HAZWOPER [64] are standards for
firefighter training in hazardous material incidents [65]. In addi-
tion, the training of firefighter employees is regulated by the State
while the training of volunteers is regulated by local authorities
[66]. It appears that the training of volunteer firefighters should be
improved.
 D.M. Laboureur et al. / Journal of Hazardous Materials 308 (2016) 164–172
The Fire Departments report provided several recommenda-
tions for small fire services like West [7]. The Fire Department
should develop guidelines for emergency operations and should
visit and plan responses for major commercial structures. They
should establish an incident management system to provide
command, control, and organization during an emergency using
the NFPA 1021 [67], 1026 [68], 1500 [69], and 1561 [70]. A
strategic incident action plan should be implemented for all emer-
gency operations (NFPA 1021, 1026, 1143 [71]). Firefighter safety,
accountability, and training should be reinforced (NFPA 1000, 1021,
1143, 1500, 1521 [72], 1561). They concluded, similarly to CSB, that
a local Fire Prevention Code and a hazardous materials program
should be adopted [19].
The firefighters were aware of the storage of AN in the facility
through the Tier II report, but were not aware of the hazards linked
to this chemical. West fertilizer did not develop an emergency
response plan to handle anticipated emergencies for the different
chemical stored like AN and AA [40]. CSB also pointed out that West
Fertilizer did not provide the material safety data sheets (MSDS) of
the chemicals stored in their facilities [19]. Under the Emergency
Planning and Community Right-to-Know Act (EPCRA), each county
needs to have a Local Emergency Planning Committee (LEPC) [73].
This committee should identify the facilities with extremely haz-
ardous substances, and develop emergency plans. The McLennan
County Emergency Management Coordinator was not aware of the
explosive potential of chemicals being stored at the West Fertil-
izer Company and never met with city officials about a potential
disaster [74].
3.3. Facility siting
In US, both OSHA and EPA provide separation distances for the
storage of explosives. AN is not classified as an explosive – it is
an oxidizer – however, it has a very well documented ability to
detonate and the authors therefore feel that a review of US and
other regulations regarding explosive storage is illuminating.
The explosives and blasting agents regulation (25CFR 1910.109
[39]) provides Table H-21 giving distances for storage of explosives
(from the Institute of Makers of explosives, 1964). This standard
(25CFR 1910.109) regulates the storage, use and transportation of
explosives and blasting agents, including mixtures of fuel and oxi-
dizers, e.g., mixtures that might contain AN. Table H-21 applies to
“barricaded” explosives, i.e., explosives protected or enclosed by a
thick barricade, either natural or artificial. ATF also gives separation
distances for explosives, in Table 555.218 (CFR 27 part 555, com-
merce in explosives) which gives separation distances from three
types of public facilities: inhabited buildings and public highways
of less or more than 3000 vehicles a day, and distinguish between
barricaded or unbarricaded [75].
In Australia, the Queensland Department of Mines and Energy
provides a Table with safety distances for different masses [76] and
the formula used to calculate the distances, using an AN mass con-
verted to TNT with an equivalency factor of 0.32. Three formulas are
given; one for the storage of associated works (i.e., other buildings
or materials in the facility), and two for class A and class B protected
works. Class A covers public roads, railways or public recreations,
and class B covers public buildings, churches, schools, hospitals, or
other buildings where the public could gather.
Finally, the HSE has developed eight different tables for separa-
tion distances of explosives, depending on the hazard type and the
type of building where the explosive is stored. AN could belong in
hazard type 2: “an explosive which, as a result of, or as a result of any
effect of, the conditions of its storage or process of manufacture has
a serious projectile hazard but does not have a mass explosion haz-
ard” [77,78]. Similar to the Queensland or the ATF standards, three
distances are given depending on the probability of presence of
169
people [78]. In addition, HSE provides a single formula to calculate
the separation distance of type 2 explosives.
Table 2 compares the separation distances calculated for the
storage of 540,000 pounds of AN, as specified in the Tier II report
[11] and Fig. 4 shows some of these calculated distances in the
surroundings of the West Fertilizer facility. Most of the tables pro-
vided by the regulation do not include storage amounts of 540,000
pounds – sometimes because the storage of such large quantities
of explosives is illegal – therefore, an extrapolation based on the
shape of the curve provided by Table had to be performed. Table 2
shows that the OSHA regulation provides a distance that does not
depend on the presence of people, and provides one of the low-
est distances. But it is also the only distance which, according to
the map, does not include any main building or public facilities.
According to the ATF table, West Fertilizer should not have been
allowed to store such a large amount of AN.
AN is not classified as an explosive or included under the regu-
lations and referenced separation distances, however, it has a clear,
demonstrated ability to detonate. As such, the potential for AN to
explode should be considered in facility siting and it may be prudent
to treat AN as an explosive for such purposes. In the case of West,
the separation distances indicated in Fig. 4 and the consequences of
the blast show that West Fertilizer was located too close to critical
infrastructure. Regulations should be revised to either apply these
separation distance requirements to some AN facilities, or include
specific separation distances for AN storage. Existing AN facilities
should be required to address this issue and undertake appropriate
actions to mitigate risk.
4. Federal response
In wake of the West Fertilizer Plant explosion, federal agen-
cies have taken measures to improve the safety and security issues
related with chemical facilities through hearings [79], a president’s
Executive Order (EO) 13650, and the release of new documents
from several federal agencies.
On June 27, 2013, the Senate Committee on Environment and
Public Works, held a full committee hearing entitled [80], “Over-
sight of Federal Risk Management and Emergency Planning Programs
to Prevent and Address Chemical Threats, Including the Events Leading
Up to the Explosions in West, TX and Geismar, LA”. The hearing dis-
cussed the events leading to West incident and Geismar incident
[81], and the importance of enforcing federal regulations to ensure
the safety of such facilities.
On August 1, 2013, president Obama issued an Executive Order
numbered 13650 and entitled “Improving Chemical Facility Safety
and Security” [82]. A Chemical Facility Safety and Security Working
Group has been established, co-chaired by DHS, the EPA, and the
Department of Labor (DOL). There are approximately 20 detailed
tasks. Three progress updates were provided in December 2013,
February 2014, and May 2014, respectively [83]. Nearly 1,800
people from over 25 States participated in listening sessions and
Webinars, and they provided input into the EO process [84]. The
listening sessions were held in several states, including LA, TX, CA,
NJ, FL, IL, and DC.
On August 30, 2013, EPA, OSHA, ATF issued a chemical advisory
entitled [85] “Safe Storage, Handling, and Management of Ammo-
nium Nitrate”. Generally speaking, this document covers AN hazards
description and classification, suggestions on the safe storage of
AN, emergency planning and response, and information resources.
However, there is room for improvement in that the use of sprin-
kler systems should be reconsidered and some redundancies in
different sections should be removed.
On December 9, 2013, OSHA issued a Request for Information
[86] to public on process safety management and prevention of
170 D.M. Laboureur et al. / Journal of Hazardous Materials 308 (2016) 164–172

Table 2
Separation distance (in meters) to store 540,000 pounds of AN.

Minor Road Used road Highway, public buildings Calculation Mass of explosives

OSHA 190 190 190 Extrapolated from table AN

ATF barricaded 270 610 865 Extrapolated from table AN
ATF unbarricaded 541 793 865 Extrapolated from table AN
Queensland 445 762 Formula TNT equivalent
HSE (UK) 170 256 510 Extrapolated from table AN
HSE (UK) 585 Formula AN

Fig. 4. Map of separation distances from the West Fertilizer Plant.

major chemical accidents, containing 17 specific questions. OSHA
requests comment on potential revisions to its existing “PSM stan-
dard, Explosives and Blasting Agents standard, potential updates
to its Flammable Liquids standard, Spray Finishing standard, and
potential changes to PSM enforcement policies” [86].
On January 3, 2014, in response to EO 13650 section 6(a),
the working group also issued a document entitled, “Solicita-
tion of public input on options for policy, regulation, and standards
modernization”[87], the purpose of which is to provide preliminary
options for additional stakeholder discussion and comments. The
document contains 49 questions to be discussed by public [87].
Public comments were submitted by March 31, 2014 [88].
On March 6, 2014, another committee hearing entitled “Prevent-
ing Potential Chemical Threats and Improving Safety: Oversight of the
President’s Executive Order on Improving Chemical Facility Safety and
Security” was organized [89]. A central purpose of the hearing was
to check in on the progress of the EO 13650 Working Group [90].
On July 24, 2014, EPA issued a Request for Information [91] to
public on “Accidental release prevention requirements: Risk Manage-
ment Programs under the Clean Air Act, Section 112(r)(7)”, requesting
comments on potential revisions to EPA’s RMP regulations and
related programs [91].
5. Conclusion
The catastrophic explosion of 30 tons of AN West, Texas was
examined both from a technical point of view by understanding the
physical aspect of the incident, but also from a regulatory point of
view. A consequence analysis based on the crater size and damage
supports the order of magnitude of other estimates of the amount
of AN that detonated but also shows that there is considerable
uncertainty in the amount.
The regulatory analysis showed that West Fertilizer violated
several regulations. The analysis of the emergency response
showed the importance of training of firefighters, especially vol-
unteers, in addition to a clear leadership command. Given the
well-documented possibility that AN may detonate, it may be pru-
dent to treat AN as an explosive for siting certain AN facilities. In
that case, the West plant was either too close to public areas, or
was storing too large a quantity of materials.
Finally, this case study showed the importance of reinforcing
the current regulation and increasing the risk awareness of AN stor-
age through a better coordination of the different Federal Agencies.
Steps in this direction have already been taken with the publication
of the Executive Order, the General Accountability Office report,
and the work performed industry organizations.
References
[1] S. Davis, C. Marsegan, Initial investigative facts in the west fertilizer
explosion, in: Mary Kay O’Connor Process Safety Center 17th Annual
International Symposium, College Station, TX, 2014.
[2] W. Pittman, Z. Han, B. Harding, C. Rosas, J. Jiang, A. Pineda, M.S. Mannan,
Lessons to be learned from an analysis of ammonium nitrate disasters in the
last 100 years, J. Hazard. Mater. 280 (2014) 472–477.
[3] B. Dedman, Texas fertilizer plant also stored explosive chemical used in
Oklahoma City bomb, NBC News, 2013.
[4] Fort Worth Star-Telegram Explosion in West, Fort Worth Star Telegram,
(2013).
[5] A. Langfield, West Fertilizer Plant Showed Few Warning Signs, in NBC News,
(2013).
 D.M. Laboureur et al. / Journal of Hazardous Materials 308 (2016) 164–172
[6] R. Lopez, West Fertilizer Co. Had Spotty Regulatory History, Records Show,
Los Angeles Times, 2013.
[7] Abbott Volunteer Fire Department, Bruceville-Eddy Volunteer Fire
Department, Dallas Fire Rescue Department, Mertens Volunteer Fire
Department, Navarro Mills Volunteer Fire Department, and West Volunteer
Fire Department, Firefighter Fatality Investigation, West Texas April 17, 2013,
(2014).
[8] AASA, Retail Facility Checklist, American Agronomic Stewardship Alliance,
(2013).
[9] CSB, Chemical Safety Board Ongoing Investigation Emphasizes Lack of
Protection for Communities at Risk from Ammonium Nitrate Storage
Facilities; Finds Lack of Regulation at All Levels of Government, (2014), CSB,
Dallas, Tx.
[10] J.H. MacNeil, H.-T. Zhang, P. Berseth, W.C. Trogler, Catalytic decomposition of
ammonium nitrate in superheated aqueous solutions, J. Am. Chem. Soc. 119
(41) (1997) 9738–9744.
[11] Tier II, Tier Two, Emergency and Hazardous Chemical Inventory (Jan 1–Dec 31
2012), in ADAIR GRAIN, INC. DBA WEST FERTILIZER CO., 2012.
[12] Texas Department of Public Safety, Texas Division of Emergency
Management, State situation report. (2013).
[13] NFPA, Code for the Storage of Ammonium Nitrate, in NFPA 490 Technical
Committee on Hazardous Chemicals, (2002).
[14] EPA, Explosion Hazard from Ammonium Nitrate, (1997).
[15] OSHA. Flammable and combustible liquids. 29CFR 1910.106. Available from:
http://www.osha.gov/dte/library/flammable liquids/flammable liquids.html.
[16] W.A. Rosser, S. Inami, H. Wise, The kinetics of decomposition of liquid
ammonium nitrate, J. Phys. Chem. 67 (9) (1963) 1753–1757.
[17] HSE Storing and handling ammonnium nitrate., Available from: <http://www.
hse.gov.uk/pubns/indg230.pdf/>.
[18] D. Buczkozski, B. Zygmunt, Detonation properties of mixtures of ammonium
nitrate based fertilizers and fuels, Cent. Eur. J. Energ. Mater. 8 (2) (2011)
99–106.
[19] CSB Preliminary Findings of the U.S. Chemical Safety Board from its
Investigation of the West Fertilizer Explosion and Fire. (2013).
[20] M.S. Mannan, Process Design, in Lees’ Loss Prevention in the Process
Industries, Fourth edition, Butterworth-Heinemann, Oxford, 2012.
[21] ATF ATF and the State Fire Marshal’s office conclude scene investigation at the
West fertilizer plant, (2013).
[22] S. Koch, Q. Jing, B. Holland, W. Dai, Large-scale explosion consequence
modeling: west, Texas fertilizer plant case study, in: Mary Kay O’Connor
Process Safety Center 17th Annual International Symposium, College Station,
TX, 2014.
[23] R.L. Loftis, Experts Say West Explosion has all Hallmarks of Ammonium
Nitrate as Fuel, DallasNews, 2013.
[24] Y. Staff, ATF: West Blast Crater 93 ft Wide, 10 ft Deep, Time Warner Cable
News, 2013.
[25] R.D. Ambrosini, B.M. Luccioni, R.F. Danesi, J.D. Riera, M.M. Rocha, Size of
craters produced by explosive charges on or above the ground surface, Shock
Waves 12 (2002) 69–78.
[26] G.F. Kinney, K.J. Graham, Explosive Shocks in Air, Springer-Verlag, Berlin, New
York, 1985.
[27] Department of the Army Field Manual 5–250, Explosives and demolitions,
Department of the Army: Washington DC, (1992).
[28] J.W. Bull, C.H. Woodford, Camouflets and their effects on runway supports,
Compu. Struct. 69 (6) (1998) 695–706.
[29] Australian code practice. Safe storage of solid ammonium nitrate, Second
edition, [cited 2013 04/23/2013]; Available from: <http://www.dmp.wa.gov.
au/Documents/Dangerous-Goods/DGS COP StorageSolidAmmoniumNitrate.
pdf./>.
[30] R. Hutchinson, P. Skinner, Ammonium nitrate in ports—storage and
transportation, IChemE Symposium Series (2007).
[31] K.E. Gould, High-Explosive Field Tests: Explosion Phenomena and
Environmental Impacts, Kaman Tempo for the Defense Nuclear Agency, 1981.
[32] S. Mervosh, M. Reeder, In West, A Road of Ruin, The Dallas Morning News,
2013.
[33] Google Maps. [cited 2014 5/8/2014].
[34] R. Pape, K.R. Mniszewski, A. Longinow, M. Kenner, Explosion phenomena and
effects of explosions on structures: III: methods of analysis (explosion
damage to structures) and example cases, Pract. Period. Struct. Des. Constr. 15
(2010) 153–169.
[35] V.J. Clancey, Diagnostic features of explosion damage, in: 6th International
Meeting of Forensic Sciences, Edinburgh, 1972.
[36] TNO, Methods for the calculation of physical effects —due to releases of
hazardous materials (liquids and gases)—‘Yellow Book’, In: C.J.H. van den
Bosch, R.A.P.M. Weterings, (Eds.), (2005).
[37] T. Meyer, ProPublica, Why didn’t regulators prevent the Texas Fertilizer
Explosion? Scientific American, (2013).
[38] TCEQ. Information from TCEQ on West Incident 2013, Available from: <http://
www.tceq.texas.gov/news/releases/4-18west/>.
[39] OSHA, Explosives and Blastic agents, in 29CFR 1910.109, Occupational Safety
and Health Organization.
[40] OSHA, Citation and Notification of penalty, US Department of Labor
Occupational Safety and Health Administration, Fort Worth TX, (2013).
[41] NFPA, Hazardous materials code, in NFPA 400, National Fire Protection
Association, (2013).
171
[42] OSHA, Storage and handling of anhydrous ammonia, in 29CFR 1910.111,
Occupational Safety and Health Organization.
[43] OSHA, Respiratory Protection, in 29CFR 1910.134, Occupational Safety and
Health Organization.
[44] OSHA, Permit-required confined spaces, in 29CFR 1910.146, Occupational
Safety and Health Organization.
[45] OSHA, Electrical—General, in 29CFR 1910.303, Occupational Safety and Health
Organization.
[46] OSHA, Hazard Communication., in 29CFR 1910.1200, Occupational Safety and
Health Organization.
[47] DHS, 6CFR Part 27: Chemical Facility Anti-Terrorism Standards; Final Rule
Federal Register, 72(67), (2007), 17688–17745.
[48] GAO, Chemical Safety—Actions Needed to Improve Federal Oversight of
Facilities with Ammonium Nitrate, in Report to Congressional Requesters,
United States Government Accountability Office (GAO), (2014).
[49] P. Coyle, West Fertilizer CFATS Status, Chemical Facility Security News, 2013.
[50] DHS, Ammonium Nitrate Security Program, RIN 1601-AA52. Fall 2013;
Available from: <http://www.reginfo.gov/public/do/
eAgendaViewRule?pubId=201310&RIN=1601-AA52#/>.
[51] DHS, 6CFR Part 31 Ammonium Nitrate Security Program Federal Register, 76,
(219), (2011), 70366–70367.
[52] EPA, Clean Air Act, Section 112(r): Accidental Release Prevention/Risk
Management Plan rule, in EPA 550-R-09-002, Office of Solid Waste and
Emergency Response, Environmental Protection Agency, (2009).
[53] EPA, Chemical Accident Prevention Provisions, in 40CFR PART 68,
Environmental Protection Agency.
[54] M. Goodman, West Fertilizer Co. Fined in 2006 by EPA, WFAA, 2013.
[55] EPA, Emergency Planning and Community Right-to-Know Act (EPCRA)
Hazardous Chemical Storage Reporting Requirements, United States
Environmental Protection Agency.
[56] J. Schneyer, R. McNeill, J. Roberts, Texas Fertilizer Company Didn’t Heed
Disclosure Rules before Blast, Chicago Tribune, 2013.
[57] Texas Commission on Environmental Quality Available from: <http://www.
tceq.texas.gov/about/>.
[58] D. Tarrant, S. Mervosh, When the Volunteer Firefighters of West Got the Call,
They Knew What They Had to Do. What They Didn’t Know Was That the Next
30 min Would Change Their Brotherhood Forever, The Dallas Morning News,
2013.
[59] PHMSA, Emergency Response Guidebook, Department of Transportation,
Pipeline and Hazardous Materials Safety Administration, Transport Canada,
CIQUIME, (2012).
[60] Tier Two Emergency and Hazardous Chemical Inventory: Adair Grain Inc
West Fertilizer Co., (2012).
[61] AIChE, DIPPR Project 801, Evaluated Standard Thermophysical Property
Values, ed. Design Institute for Physical Properties Sponsored by AIChE. 2012,
Design Institute for Physical Property Research, American Institute of
Chemical Engineers.
[62] Southern Trinity Groundwater Conservation District, Groundwater
Management Plan, (2010).
[63] NFPA, Standard for professional competence of responders to hazardous
materials incidents, National Fire Protection Association, (1997).
[64] OSHA, Hazardous waste operations and emergency response, in 29CFR
1910.120, Occupational Safety and Heath Administration.
[65] Questions about Fire Fighter Training, in: J. Moats, J. Loyd (Eds.), Personnal
Communication, 2014.
[66] R. McGregor, Interview of Randy McGregor, Chief of the Bryan Fire
Department, Interview performed by the Mary Kay O’Connor Process Safety
Center, Editor, (2013).
[67] NFPA, Standard for Fire Officer Professional, in NFPA 1021, National Fire
Protection Association, (2014).
[68] NFPA, Standard for incident management personnel, in NFPA 1026, National
Fire Protection Association, (2014).
[69] NFPA, Standard on fire department occupational safety and health program,
in NFPA 1500, National Fire Protection Association, (2013).
[70] NFPA, Standard on emergency services incident management system and
command safety, in NFPA 1561, National Fire Protection Association, (2014).
[71] NFPA, Standard for wildland fire management, in NFPA 1143, National Fire
Protection Association, (2014).
[72] NFPA, Standard for Fire Department Safety Officer, in NFPA 1521, National
Fire Protection Association, (2008).
[73] EPA, Local Emergency Planning Committees, Environmental Protection
Agency.
[74] B. Shipp, Top Emergency Official Says He Never Warned West of a Potential
Threat, WFAA, 2013.
[75] ATF, Storage of explosives, in 27CFR chapter II, subchapter C, part 555,
subpart K, Bureau of Alcohol, Tobacco, Firearms, and explosives, Department
of Justice, (2012).
[76] Storage requirements for security sensitive ammonium nitrate (SSAN), in
Information bulletin 53, version 3, Department of Mines and Energy,
Queensland Government, (2008).
[77] HSE, Hazard type and classification Health and Safety Executive (UK).
[78] HSE, Table 6 External separation distances, Hazard Type 2, Health and Safety
Executive (UK).
[79] Congress, Hearings: 113th Congress. 2014: <http://www.epw.senate.gov/
public/index.cfm?FuseAction=Hearings.Home/>.
172 D.M. Laboureur et al. / Journal of Hazardous Materials 308 (2016) 164–172
[80] US Senate Full Committee hearing entitled, Oversight of Federal Risk
Management and Emergency Planning Programs to Prevent and Address
Chemical Threats, Including the Events Leading Up to the Explosions in West,
TX and Geismar, LA. 06/27/2013; Available from: <http://www.epw.senate.
gov/public/index.cfm?FuseAction=Hearings.Hearing&Hearing ID=64099921-
ffdc-075c-1328-f94f2fb7bae6/>.
[81] M. DeLuca, One Dead, Scores Injured in Louisiana chemical plant explosion,
NBC News, 2013.
[82] Barak Obama, Executive Order– Improving Chemical Facility Safety and
Security, in Executive Order 13650, The White House Office of the Press
Secretary, (2013).
[83] OSHA. Executive Order 13650: Improving Chemical Facility Safety and
Security. Available from: <https://www.osha.gov/chemicalexecutiveorder/>.
[84] Chemical Facility Safety and Security Working Group, Executive Order 13650:
Actions to Improve Chemical Facility Safety and Security—A Shared
Commitment Report for the President, (2014).
[85] EPA, Chemical Advisory: Safe Storage, Handling, and Management of
Ammonium Nitrate, EPA—OSHA—ATF, Editor, (2013).
[86] OSHA, 29CFR Part 1910: Process Safety Management and Prevention of Major
Chemical Accidents: Request for information Federal Register, 78, (236),
(2013), 73756–73768.
[87] OSHA. Executive Order 13650, Section 6(a) –Solicitation of Public Input
on Options for Policy, Regulation and Standards Modernization. Available from:
<https://www.osha.gov/chemicalexecutiveorder/Section 6ai Options List.html./>.
[88] P. Coyle, EO 13650: Another Request for Input, Chemical Facility Security
News, 2014.
[89] US Senate Full Committee hearing entitled, Preventing Potential Chemical
Threats and Improving Safety: Oversight of the President’s Executive Order on
Improving Chemical Facility Safety and Security. 03/06/2014.
[90] C. Boxer, Boxer Statement: Hearing on Preventing Potential Chemical Threats
and Improving Safety: Oversight of the President’s Executive Order on
Improving Chemical Facility Safety and Security. US Senate Committee on
Environment and Public Works, Press Releases, (2014).
[91] EPA, Accidental Release Prevention Requirements: Risk Management
Programs Under the Clean Air Act, Section 112(r) (7) Request for information.
Federal Register, 79(147), (2014), 44604–44633.