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May I introduce myself, my name is Roy Wilsher, Chief Fire Officer, Hertfordshire Fire and Rescue Service. I was in charge of the fire response to the Buncefield incident coordinating 31 Local Authority Fire and Rescue Services. I was recently handed a copy of your professional publication and read with some surprise the article by David White ("Buncefield -- One Year Later" Nov.-Dec. 2006) incorporating the views of Kelvin Hardingham.

There are a number of inaccuracies in the report which I believe need clarification. The first of which is whether the fire was extinguished or burned out. The initial explosions at Buncefield set alight 20 tanks whilst destroying the pump houses, five main and fixed installations on site. Over the next 24 hours the fire spread to just two more tanks before being held back by cooling jets. Initial estimates from Oil Industry Fire Experts such as Dr. Niall Ramsden, were that the fires could burn for 7-8 days if left and did not spread. The majority of tank fires were extinguished within 36 hours of the main foam attack starting with over 37 million litres (9 million gallons) of product saved. It is true there were some re-ignitions during the main firefighting but this was due to the difficulties in access, logistics and environmental concerns.

Preplanning for Buncefield followed national and international guidelines allowing for the largest tank or largest tank with spread to one other tank being alight, not 20 in the initial explosions. This was not a failure of imagination but was planning for what was on 10 December 2005 a realistic scenario.

In writing this letter I would also like to clarify Kelvin Hardingham's role. From my discussions with Central Government in the UK I have been informed that they did not ask him to attend Buncefield. My understanding is that he attended with Essex Fire and Rescue crews because of his professional association with that Service. Mr. Hardingham was probably greeted by the Fire Commander there as views were being sought from different professionals. Mr. Hardingham was not, however, the operations firefighting coordinator on site reporting direct to Bronze or Silver Command. All command positions stayed with Hertfordshire Officers.

As Mr. Hardingham had no role in the Command structure he would have no detailed knowledge of the command discussions, especially those at Gold situated 15 miles from the scene. It is acknowledged that Mr. Hardingham was on site and got involved in some hands-on tactical firefighting but that is as far as it went. This is demonstrated by his lack of understanding of the water situation. The Buncefield area is situated above a chalk aquifer that feeds the ground water supplies for drinking water to North West London. There was the possibility of a major environmental disaster if this drinking water supply was polluted. That is why water supplies were sometimes interrupted by the Service. Over 10 million litres (over 2 million gallons) were contained on site and 15 million litres (over 3 million gallons) were recycled for cooling jets. This also explains the distribution of hose Mr. Hardingham said shocked him. Again, not being in a command position he would not expect to know where hose and water was being directed.

With regards to the foam supply, over 786,000 litres (almost 200,000 gallons) were used and it is true to say some of this was not up to scratch, mainly supplied by other Fire services. Over 600,000 litres, however, were supplied by Angus Fire, the industry expert producers with whom Hertfordshire had a signed agreement for extra foam if required. They supplied the correct foam. Mr. Hardingham is also misinformed about the evacuation due to a possible tank collapse. The concern was not about the tank exploding, although given the events of Sunday morning this could be an understandable reaction. The concern was about a running fuel fire breaching the bund walls which had high levels of water in them. This proved to be the case as a running fuel fire destroyed some hose and other equipment on Monday afternoon. It is true that industry experts have more knowledge of this type of incident and Dr. Niall Ramsden, crews from Total and others, provided excellent advice.

Hertfordshire Fire and Rescue Service have produced a report that details the actual fire response and a copy is enclosed. Mr. Hardingham personally commented on this report. Mr. Hardingham's only substantive comment was in regard to the intrerruption of water supplies and subsequent breaking up of the foam blanket. Mr. Hardingham does actually mention the repositioning of the 2 x 6 gun after extinguishment of the tank and bund fire in tank 12. This was the second last tank to be extinguished, hardly evidence for the fires burning themselves out.

I am unsure of Mr. Hardingham's motivation for his comment in the article and I find it interesting I have not seen the article in a UK publication. I hope this letter and the report help clarify what happened at Buncefield.

Roy Wilsher
Chief Fire Officer

Kelvin Hardingham Replies: Well, what can I say. Have you never felt that in the aftermath of such fires that the reports and comments from some persons/organizations on many occasions do not correspond with the actual situation(s) presented and dealt with at the time.

I believe that the fire operations in the Buncefield incident has developed into one of these situations, and I know the content of my report(s) will be bourn out by the Fire Teams from BP Coryton refinery UK, Sembcorp UK, Total Lindsey Oil refinery and Essex Fire & Rescue Service who carried out most of the on-site fire fighting operations during the first 48 hours of our attendance.

The facts from my side are basically as follows:

  1. I was contacted at around 1800 hrs that Sunday by the UK Governments Deputy Prime Minister Office and asked to attend as technical advisor, and that is exactly how I introduced myself upon arrival later that evening to the HFRS (Hertfordshire Fire & Rescue Service) on-site incident commander - the Deputy Chief Officer of HFRS.?
  2. At no time did Essex Fire & Rescue Service request or indeed contact me regarding attending this incident, obviously as Buncefield was not in their region of responsibility.
  3. Incident command, i.e. Bronze Command, consisted of two HFRS Divisional Officers and the Deputy Chief Officer. During the three-day period I was constantly attending at the Bronze Command vehicle (I well remember the walk each time as it was nearly a mile to the command post), giving advice to them on recommended tactics and actions when asked -- which was often.
  4. I returned to my home in Leigh-On-Sea twice during the incident and on both occasions received telephone calls from HFRS incident Bronze Commander requesting my re-attendance
  5. I never said I was in a command position but I did function as firefighting activities co-coordinator in conjunction with the HFRS Bronze command.
  6. The water situation was a factor that was constantly under discussion between myself and the HFRS Bronze Commander throughout the first 36 hours up to and even following the evacuation. I was fully appraised at all times of where the fire water was being relayed from and to. The problem we had throughout the first two days was that no-one could explain why we had such a poor water supply on the fire ground with the relay set up to supply considerably more than was actually being delivered
  7. The reason at Bronze Commend level for the evacuation was clearly stated to me at the time as due to concern registering by the Police helicopter hovering above the incident over the heat signal coming from the non fire tank on the SE side of the fire fighting operations. This concern was discussed between myself and the Bronze Command and they decided to evacuate, stating to me that he was concerned regarding the tank exploding if we were not, as I had advised, able to quickly set up to apply cooling waters to the affected tank. I had no discussions with Bronze Command in relation to this evacuation regarding bunds being breached. The only discussion around that time relating to the bunded areas was HFRS's instruction on the grounds of safety that no firefighters were to enter bunded areas to extinguish pressure fires within the bunded areas.

As you are aware there have been a number of UK Fire Journals that have carried articles which have been of similar nature which have included similar reports/comments from myself.

Since the Buncefield incident there has been a plethora of reports/seminars and I have received many comments from the refinery fire personnel who attended the incident at the subsequent seminars. that they felt the fire fighting operations have been widely misrepresented by many of these reports (which have included HFRS).

I stand by my comments within the IFW article and I am comfortable in the knowledge that those oil industry crews who attended and worked with me at the incident during the three days of my attendance will bear out of this and indeed the contents of ALL the articles in IFW and other UK and International publications.

Williams Fire & Hazard Control submitted an invoice to HFRS for our charges in relation to my technical assistance and attendance which was paid promptly by HFRS.

Kelvin M Hardingham
Williams Fire & Hazard Control Inc.


Kudos to Bill Kerney on his recent article in EMS Corner - "Reflective Clothing and Ground Operations (Jan.-Feb. 2007)." I applaud him taking the time to write about the issue of emergency responder visibility. However, I would like to suggest that Bill also highlight the term "high-visibility" when addressing this subject as it is not just about the "reflective" aspects of personal protective equipment. It is also important to emphasize the florescent features of high-visibility vests which help make us more visible in daylight and low light conditions. The best personal protective equipment for working near moving traffic is both florescent and reflective.

The safety of emergency responders working along roadway is very important to me as my former FD experienced an incident in 1998 where 10 of our personnel were struck by a tractor trailer, killing one firefighter and putting 9 others in the hospital. I have been actively working on this issue ever since and we have made significant progress over the last 8 years.

In addition to explaining high-visibility PPE we also teach emergency responders about strategy and tactics for positioning of fire, police and EMS vehicles at incident scenes, vehicle conspicuity recommendations (florescent & reflective chevrons, striping), emergency lighting design consideration, training strategies for personnel and a number of other related subjects.

If you're going to post a follow-up may I suggest that you include comments about the new ANSI 207 - Public Safety Vest standard? An overview can be found here: The Emergency Responder Safety Institute advocates the inclusion of

"breakaway" features on all new public safety vests. That is not a requirement in the new standard (which we fought for) but it is allowed as an option. The feature will help prevent responders from being dragged by a vehicle that might catch the vest while moving. We have seen cases where workers have been snagged by a mirror or other item on a vehicle. ANSI 107-2004 also provides guidance for high-visibility vests although it was written with construction workers in mind. High-visibility vests meeting either standard would be acceptable for responders as long as they are at least a Class 2 or higher according to the ANSI 107 document.

There is also a recently passed federal law that will require workers (including emergency responders!) to wear high-visiblity vests while working along federally funded roadways beginning in 2008. You can review the new rule here:

Also of possible interest to your readers, there are some FREE training resources related to roadway incident safety available at: including several DVDs.

I personally will be conducting another 8-hour H.O.T. Workshop on "Roadway Incident Safety for Emergency Responders" at the FD Instructors Conference in Indianapolis again this year in April. I'll also be speaking about the same subject at the Miltenberger EMS & Trauma Conference in Maryland in March 2007 and tentatively at the VA EMS Symposium in Norfolk, VA in November 2007.

Jack Sullivan
Director of Training
Emergency Responder Safety Institute

Bill Kerney Replies: Jack is totally correct. Thanks for the feedback. The oversight is totally mine and this should have been there as well.


I want to comment on the subject article by David White ("The Trouble With Ethanol" Jan.-Feb 2007). My first comment has to do with the reason ethanol is not introduced into gasoline pipelines. Water will seep into the pipelines, and since typical hydrocarbon fuels such as gasoline do not mix with water, it is merely pushed into the receiving tank, where it is eventually drawn off from the bottom of the tank. Ethanol, being a polar solvent, will absorb all the water in the pipeline and carry it with it into the receiving tank, and as well soak up the water in the bottom of the tank (Just like in your car's gas tank the first time you use ethanol blended fuel). The water absorbed will push the ethanol out of specification due to water content. When we design ethanol plants, we use carbon steel pipes and tanks for fuel ethanol handling and storage without corrosion issues.

My second comment is to clarify that 190 proof indicates a near 95 wt % ethanol, and this is the endpoint of separation in a typical distillation process, where ethanol is boiled out of the fermented mash. The last 5% of water has to be removed, and denaturant (gasoline) has to be added to qualify as a fuel grade ethanol. The denaturant is only added to avoid the beverage taxes so the government does not lose revenue. Each plant has to have a TTB permit, as each plant will have some potable ethanol on site until it is denatured.

My final comment is to thank David White for such an excellent article. I have a lot of respect for your service. I am in the design/build/service business for fuel ethanol process facilities. We have a little bit of an advantage, by sitting with the local fire departments and educating them as to what is in place and what they may have to deal with. As your article illustrates, this product will travel just about everywhere (overland), and it will most likely be a surprise to a responder to find out that, oh, it's a polar solvent. I thank you for your timely article.

Kenneth E. Ulrich, PE
Principal Engineer, ICM, Inc.


Okay, what new kind of level A suit does the photograph depict on the table of contents page of the (Jan.-Feb. 2007) edition. It doesn't look like it is an encapsuated suit to me. My eyes aren't what they use to be, but that doesn't look like a level A suit on page 8 ("Witch Brew") either.

To be sure, those of us who can't read very well look very closely at the photographs.

Loyal reader and looker.
Bill Green
Deer Park, TX

Editor Replies: My error, it was actually Level C. Sorry.?


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