Commercial · Terminals, tank farms and hazmat warehouses

At a storage site, much of what burns belongs to someone else. And the cleanup can outlast the fire.

Name: Crossroads Insurance Recovery Advocates
Address: 1080 W Sam Houston Pkwy N Ste 210, Houston, TX, 77043, US
Telephone: 713-369-4300
Rating: 4.9

Last updated: October 2026

Customers' product in your tanks and racks. Firewater and product in the dike. Inventory, Tier II and sprinkler records the insurer will ask for in the first week. We document and negotiate the full loss for the policyholder, and we tell you plainly when a question belongs with your attorney.

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387,000 barrels

That is how much liquid waste was disposed of after the 2019 ITC Deer Park tank farm fire, on top of more than $150 million in property damage, by ITC's estimate. At a terminal or hazmat warehouse, the cleanup, the customers' product and the lost fees often run longer than the fire did.

Source: U.S. Chemical Safety Board, ITC final report (2023).

First 72 hours

What to do before anything is pumped out, demolished or overwritten

At ITC, the tank gauges showed Tank 80-8 losing about 221 barrels in 27 minutes before the naphtha ignited. Gauge history, alarm data and the failed part are the core of the cause investigation, and all of them are easy to lose in the first days.

Make it safe, then hold the evidence. Keep the failed pump, seal, valve, sprinkler head or pipe in place, or move it under a chain-of-custody log once investigators and the insurer have seen it.

Lock down the data. Save automatic tank gauge history, DCS or SCADA records, alarm monitoring records, CCTV and shift logs before they are overwritten.

Make the state report. A reportable spill goes to the TCEQ spill line at 1-800-832-8224 as soon as possible and within 24 hours. A call to the National Response Center or the LEPC does not count as notice to the state. Which reports apply to your site is a question for your attorney.

Notify every policy that may respond: property, stock, inland marine or warehouse legal liability, pollution, storage tank liability, general liability and umbrella. Log claim numbers and every call.

Build the inventory by owner. List each owner's product by tank or lot, quantity and contract. Hold off on telling customers who pays until your contracts have been reviewed with counsel.

Measure what leaves the site. Track dike contents, recovered volumes and waste manifests from the first truck. ITC recovered 92,222 barrels from its tank farm in 10 days.

Track every dollar from day one. Outside firefighting contractors, vacuum trucks, temporary storage and third-party warehouses are extra expense, and they are only recoverable if they are documented.

Sources: CSB ITC factual update (2019) and final report (2023); TCEQ spill reporting pages.

Three storage losses

What ITC Deer Park, Bio-Lab and West Fertilizer teach a storage operator

Each of these losses turned on a different storage risk: tank farm isolation, sprinkler corrosion on water-reactive stock, and ammonium nitrate with thin insurance. The facts below come from U.S. Chemical Safety Board reports and the press coverage listed in the sources.

ITC Deer Park terminal, Deer Park, Texas, March 2019.

A circulation pump on leased Tank 80-8 failed and released butane-enriched naphtha. The tank farm had no fixed gas detection or automatic fire alarm, and the tank's valves could not be closed remotely. Fire spread to all 14 other tanks in the same containment area, destroying fifteen 80,000-barrel tanks of customers' products. On March 22 the containment wall failed, and the Coast Guard closed seven miles of the Houston Ship Channel. Federal assessors estimated 470,000 to 523,000 barrels of firewater, foam and product reached Tucker Bayou and nearby waters.

Lesson: customers' product, containment, waste, waterway cleanup and civil authority all run at once. Lock down gauge data and the failed part on day one.

Bio-Lab warehouse, Conyers, Georgia, September 2024.

Water from a corroded sprinkler part hit chlorinated isocyanurates around 5 a.m., and the reaction set off more sprinkler heads. The warehouse held about 14 million pounds of reactive chemicals, against roughly 6.2 million pounds anticipated in its 2019 documentation. 1,124 corroded sprinkler heads had been counted in December 2023, and fire protection showed abnormal status on at least 60 of 637 days, or 9.6%. About 17,000 people were evacuated and 90,000 told to shelter. The CSB reports the company decided to cease operations at Conyers in May 2025.

Lesson: inventory records, sprinkler and impairment history, and fire-code approvals become the center of the claim.

West Fertilizer, West, Texas, April 2013.

A fire at the storage and distribution site detonated about 30 tons of ammonium nitrate. Fifteen people were killed, 12 of them emergency responders, and more than 260 were injured. A school, an apartment complex and a nursing home within about 550 feet were damaged and later demolished. The site carried $1 million of insurance against about $230 million of insurance-related losses, and an earlier insurer had dropped it after its surveys flagged unaddressed concerns.

Lesson: know your limits before you need them. Loss-control history follows the file.

Two smaller records add to the picture. At Bio-Lab's Lake Charles, Louisiana site, Hurricane Laura rain reached oxidizer storage in 2020 while the backup generator and one fire pump were already down; it reopened in November 2022, about 26 months later. After the 2007 explosions and fire at Barton Solvents, a Kansas chemical distributor, the CSB's recommendations centered on static buildup in storage tanks, so bonding, grounding and product data will be examined after a tank fire.

Sources: CSB ITC final report and appendices; Texas Tribune and Public Health Watch via KPRC (2023); CSB Bio-Lab Conyers final report (2026); CSB West Fertilizer final report (2016); Fire Engineering; CSB Barton Solvents page.

Reporting

Reporting clocks: the TCEQ spill line, the CSB and Tier II

Some reports run on hours, not days, and the agency calls you make in the first shift become part of the claim file. The table shows the clocks most likely to apply at a storage site.

Report	Deadline	What to know
TCEQ spill line, 1-800-832-8224	As soon as possible and within 24 hours	A call to the National Response Center or LEPC does not count as notice to the state
Petroleum and oil spills	Same TCEQ clock	Reportable at 25 gallons of petroleum product from a non-exempt petroleum storage tank facility onto land, 210 gallons of crude oil onto land, or enough oil to make a sheen on water
Hazardous substance spills	Same TCEQ clock	Onto land, the federal reportable quantity; into water, that quantity or 100 pounds, whichever is less
Written spill follow-up	Within 30 working days	Sent to the TCEQ regional office
U.S. Chemical Safety Board	Within 8 hours	For an accidental release with a death, serious injury or $1 million in property damage (40 CFR 1604.3)
Tier II for fertilizer-grade ammonium nitrate	Within 72 hours	Initial and updated reports; other significant changes have 90 days

Which reports apply to your site, and how you respond to investigators and agencies, are questions for your attorney. Keep a log of every agency contact, report number and document request.

Sources: TCEQ spill reporting, reportable quantity and follow-up pages; 40 CFR 1604.3; TCEQ Tier II timelines.

Who pays which piece

Customers' product vs. your property: how a storage claim splits

A storage claim splits three ways: your own property, other people's product in your care, and pollution and cleanup. For customers' goods, the storage contract usually sets what you owe, and a warehouse legal liability policy pays only that. One broker's example shows a warehouse receipt cap of $0.50 a pound limiting a $1,000,000 fire loss to $500,000.

Piece of the loss	Where it is usually covered	What to check
Tanks, containment walls, docks, racks and buildings	Property form, subject to valuation and coinsurance	Values on older tanks and walls against today's rebuild cost
Your own stock	Property form, under its stock valuation clause	Inventory records against declared values
Customers' product when you are legally liable	Warehouse legal liability	Contract caps, which typically run $0.15 to $3 a pound, or five to 10 times monthly storage charges
Customers' product regardless of fault	Property of others (first-party); some carriers place goods stored for others in inland marine	Whether you carry it, and on what valuation
Product the customer insures itself	The customer's own insurance or self-insurance under the contract	Each contract's insurance and waiver of subrogation clauses
Debris removal	Property form: 25% of the paid direct loss plus the deductible, plus up to $25,000 more in standard ISO terms	Debris costs must be reported in writing within 180 days
Pollutant cleanup on your site	A small fixed sublimit: $10,000 per location per policy year in standard ISO terms	Notice dates, and any separate pollution policy
Off-site cleanup and neighbors' claims	Separate environmental and liability policies, such as pollution legal liability or storage tank liability	A matter for your liability insurers, broker and attorney, not your property claim
Code upgrades on the rebuild	Ordinance or law coverage, to its limit	SB 900 tank standards and fire-code re-approval; ordinance or law coverage excludes pollutant laws
Lost storage, throughput and handling fees	Business income and extra expense	The indemnity period against the time to refill capacity

Contracts can widen your exposure past the policy. A contract that makes you liable for all losses, flood and wind included, can outrun a legal liability policy and leave a gap. Some terminal contracts go the other way: one large operator's agreements left title and insurance or self-insurance with the customer. Value customers' product by owner, product, tank or lot, and contract basis. Contaminated but intact product may still be a total loss, or it may carry a salvage credit.

Whether you are legally liable to a customer, what a receipt cap means for your facts, and whether a lessee can end its contract are legal questions. We document and present the loss; those questions belong with your attorney. For a general warehouse or 3PL loss without chemical exposure, see our warehouse and distribution fire claim page.

Sources: Amwins, Unpacking warehouse legal liability; Kinsale; IMTT in Macquarie Infrastructure 10-K (FY2012); ISO form terms via Open Exam Prep and CP 04 05.

The cleanup

Containment, firewater and cleanup: the bills that keep coming

At a storage site the cleanup can outweigh the fire. ITC disposed of about 387,000 barrels of liquid waste, and its response used 214 vessels, 142 skimmers and 50 vacuum trucks. Bio-Lab's response became a controlled demolition that ran into October 2024, with remediation finished before May 2025.

Split the cleanup into four buckets

Debris of insured property.

Burned tanks, racks, piping and building materials. Usually a debris removal question under the property form, with its own cap and a 180-day written reporting window in standard terms.

Decontaminating your tanks, buildings and stock.

Hydrochloric acid and chlorine residue can damage steel, electrical gear and stock far from the burn. We bring in industrial hygienists to test and document what is present, where and at what levels.

Extracting pollutants from soil and water.

Dike contents, runoff and soil. Standard property forms carry a small fixed pollutant cleanup sublimit, so check every pollution and environmental policy you carry.

Third-party and natural resource claims.

Neighbors, waterways and agencies. These run through liability policies and counsel, not your property claim.

What sets the cleanup bill

Cleanup follows TCEQ's Texas Risk Reduction Program, 30 TAC 350, and remediation can run months.
If a responsible party cannot or will not clean up, TCEQ may step in with state funds and seek penalties.
Disaster-generated hazardous waste keeps its 90-, 180- and 60-day storage limits unless a disaster declaration changes them.
A containment wall is part of the loss whether it held or failed. After ITC's 1970s wall tore at its joints under about 20,000 gallons per minute of firefighting water, the CSB advised designing walls for fully saturated soil, so expect code and betterment arguments on the rebuild.
Some energy policy wording covers sudden seepage only if it is discovered within 60 days and reported in writing within 90 days. Check your notice dates against your own wording.

Every waste manifest, recovered-volume log and disposal invoice is claim proof. Keep them from the first load. Where the carrier cites a pollution exclusion against the cleanup, we document what the fire caused and where it went, and we do not treat the first letter as the end of the conversation. A dispute over how the exclusion's wording applies belongs with your attorney.

Sources: CSB ITC final report and Appendix E; CSB Bio-Lab report; TCEQ spill rules, responsible party page and RG-517c; ISO terms via Open Exam Prep; Universal Sompo sample energy wording (a non-U.S. form, used only to show how such clauses read).

Records

The records the insurer will ask for: inventory, Tier II, NFPA 30 and 400, sprinkler inspections

Expect the carrier to test your inventory, fire protection and contracts as hard as the fire itself. In the Bio-Lab record, stored quantities ran more than double the documentation, and fire protection was abnormal on 9.6% of days.

Inventory against declared values.

Inventory above declared values can raise coinsurance and disclosure arguments. Reconcile inventory by owner and product against Tier II filings, statements of values and permits before the first records request. What follows from a mismatch is a question for your attorney.

Fire protection and impairments.

The ISO protective safeguards endorsement (CP 04 11) excludes fire loss if you knew a scheduled sprinkler or alarm system was impaired and did not tell the insurer, or did not keep it working. It has a 48-hour exception for repairs after breakage, leakage, freezing or opened heads. Impairment logs and notices to the insurer decide which side of that line you are on.

Fire-code status.

The CSB found Bio-Lab's warehouse did not comply with NFPA 400 or NFPA 13, and occupancy class (S-1 vs. H-3), maximum allowable quantities and sprinkler design were all in question. Have your design basis, hydraulic calculations and fire marshal approvals ready.

Water vs. fire

When suppression water reaches water-reactive stock, the water is part of the cause of loss, not only the response. The carrier will look at water, corrosion and maintenance exclusions alongside fire. Document the sprinkler history and the sequence of events from the start.

Proof of loss and examinations

Under standard ISO conditions, a sworn proof of loss is due within 60 days after the insurer asks for it, so the request date sets the clock. Examinations under oath are most likely when inventory records, fire-code status or income projections are in dispute; their scope is a question for your attorney.

Loss-control history

West Fertilizer's earlier insurer dropped it after its surveys flagged unaddressed concerns. Every insurer loss-control survey, and your response to each recommendation, belongs in the claim file.

Sources: CSB Bio-Lab report and release; ISO CP 04 11 10 12 specimen; ISO CP 00 30; CSB West Fertilizer report.

The business interruption fight

Measuring lost storage and throughput income

A terminal earns on capacity, not product. In one large operator's 2012 filing, customers paid a monthly rate per barrel of capacity whether they used the tank or not, with throughput beyond an included number of movements billed separately. ITC's fire took out 1.2 million barrels of nominal capacity, about 9% of the terminal's 13.1 million (computed from CSB figures).

How the loss is measured

Terminals and tank farms: contracted storage fees on the damaged shell capacity, by tank and customer; throughput and handling fees from volume history by dock, rack and rail; ancillary fees for heating, blending, additive injection and railcar unloading; renewals and new contracts lost during the outage.
Hazmat warehouses and distributors: storage and handling fees per pallet, sack or position; gross margin on distribution sales; repackaging and blending.
Continuing expenses: payroll, leases, debt service, permits and fees, including SB 900 vessel fees of up to $2,000 per vessel a year.

Watch the contract terms. Capacity-based fees can continue, pause or end under force majeure, depending on each lease, and that reading belongs with your attorney. Some energy policy wording excludes income lost to lease suspensions after the indemnity period ends.

How we build it

We do not hand the carrier one calculation. We model the loss several independent ways, against the remediation and regulatory-clearance timeline, against your storage contracts and utilization, and against the time to restock and re-permit, and use those models against each other. The look-back period matters too: a soft year inside a multi-year average can drag your baseline down when it does not reflect normal operations.

The clocks in the standard form

Business income starts 72 hours after the physical loss; extra expense starts at once
Extended business income covers 60 days after you reopen unless you bought a longer extended period of indemnity
Customers can re-contract at another terminal quickly, so refilling capacity can take longer than rebuilding tanks
Code-driven delay falls outside the standard period of restoration unless an increased-period endorsement (CP 15 31) was bought

What stretches the period of restoration

SB 900 tank standards for vessels placed in service after Sept. 1, 2027 (see the Texas section).
Tank farm design review. The CSB asked ITC to evaluate its tank farms against API 2610 and NFPA 30, including spacing, subdivision and whether walls hold under firewater. Expect the same questions from your engineer, insurer and regulators.
Safety retrofits. ITC reported a phased program to install remotely operated emergency isolation valves, and installed flammable gas detection.
Fire-code re-approval of occupancy class, maximum allowable quantities and sprinkler design before re-occupancy.
Permits and hearings. Texas renewed ITC's 10-year permit less than a year after the fire; its federal operating permit drew a contested hearing in 2023.
Electrical gear. One contractor reports 40 to 65 weeks for pad-mount transformers and 52 to 80 weeks for medium-voltage switchgear in 2026.
Equipment lead times for tanks, pumps and valves. Get dated vendor lead-time letters in writing.

Extra expense to document

Outside firefighting contractors, foam and pumps (ITC's outside crews arrived about 45 hours into the fire)
Vacuum trucks, skimmers and recovery equipment
Moving product to safety, such as Arkema's move of about 10,500 peroxide containers into refrigerated trailers
Third-party warehouses and temporary storage, as Bio-Lab used
Temporary generators, which TCEQ allows after a declared disaster if they meet 30 TAC 106.511

3x+

Income loss now runs above three times property damage, and up to ten times on some claims.

Marsh, 100 Largest Losses in the Hydrocarbon Industry, 2026

of ITC's nominal tank capacity, 1.2 million barrels, was taken out by one fire.

Computed from CSB figures

26 months

for Bio-Lab Lake Charles to reopen after a storm-then-fire loss in 2020.

Computed from Fire Engineering, one case

Sources: IMTT in Macquarie 10-K (FY2012); CSB ITC factual update, final report and R4/R5 status; TCEQ storage vessel memo; ISO CP 00 30; KPRC (2023); Terrapin Construction Group (2026); CSB Arkema summary; TCEQ RG-517a; Marsh (2026).

Closures

Road, Ship Channel and shelter-in-place closures

A storage fire can shut down sites that never burned. After ITC's wall failed on March 22, 2019, seven miles of the Houston Ship Channel closed, and terminals and docks in that stretch faced vessel limits without damage of their own.

Event	Closure	Source
ITC Deer Park, 2019	Citywide shelter-in-place from 12:50 p.m. March 17 to 6 a.m. March 18; SH 225 closed March 17 to 18; seven miles of the Ship Channel closed from March 22	CSB
Bio-Lab Conyers, 2024	Nightly 7 p.m. to 7 a.m. shelter orders within 2 miles for 17 days; I-20 closed about 18 hours	CSB; The Trucker
Hurricane Beryl, 2024	Port Houston terminals stayed closed July 9; more than 1.76 million CenterPoint customers lost power	ICIS

Civil authority

In the standard ISO form, civil authority income starts 72 hours after an order bars access. Your premises must be in the barred area and within 1 mile of the damaged property, and income is paid for up to 4 consecutive weeks. Check whether an order prohibited access, and its radius and duration, against your own clause. Whether a shelter-in-place order counts as prohibiting access is a question for your attorney.

Dependent properties and utilities

A terminal depends on pipelines, docks, the Ship Channel, rail and its anchor customers' plants. The reverse also holds: ITC's lessees lost access to their product when the terminal burned. Contingent business income and utility services coverage may respond to these losses if you bought them. When a neighbor's plant is the source of the loss, see our chemical plant fire claim page.

Sources: CSB ITC factual update and final report; CSB Bio-Lab report; The Trucker; ICIS; ISO CP 00 30; Rough Notes on utility services.

What the carrier will try

The shortfalls in these claims are predictable. So is how we fight them.

Large losses in this sector are contested on a handful of recurring fronts. None of these mean the carrier is acting in bad faith, it means the policy is complex and the default reading of it favors the insurer unless someone pushes back with documentation. Here's what they try, and what we do about each.

Maintenance

The insurer may point to corrosion, wear or lack of maintenance, as in Bio-Lab's sprinklers, rather than a covered fire.

Our move: We keep the failed part under chain of custody and pull the inspection, testing and work-order records, so the cause analysis rests on the evidence, not the first assumption.

Water vs. fire

Suppression water on water-reactive stock gets treated as a water, corrosion or maintenance loss.

Our move: We document the sprinkler history and the sequence of events from the start. Where the wording itself is in dispute, we work alongside your attorney.

Impairment

The protective safeguards endorsement is raised over impairments or shutdowns not reported to the insurer.

Our move: We assemble the impairment logs, notices and repair timeline so the facts are on the table before anyone argues about them.

Declared values

Inventory above declared or permitted amounts is used to argue coinsurance or disclosure.

Our move: We document the inventory from purchase and storage records by owner and product, reconciled to Tier II filings and statements of values.

Customers' goods

Customers' product is written off because your legal liability is not shown.

Our move: We build the inventory register by owner and contract and match each line to the coverage that fits it. The liability question goes to your attorney.

Pollution

Pollution exclusions are raised against dike contents, runoff and soil.

Our move: Industrial hygienist findings and the four-bucket cleanup split show what the fire caused and where it went.

Tank repair

Heat-exposed tanks are scoped as repairable.

Our move: Engineers on a burnt-tank forum pointed to API 579 fitness-for-service review, hardness testing and a full hydrotest. Get your own engineer's assessment before accepting the carrier's.

Code upgrades

SB 900 tank standards and newer NFPA requirements are called betterment.

Our move: We identify the code and remediation standards the rebuild actually requires and tie them to the ordinance-or-law coverage you bought.

Restoration period

The timeline is set shorter than permits, re-approval and refilling capacity allow.

Our move: Dated vendor letters, permit steps and customer contract records set the real period, including lost customers after reopening.

Situations that often draw a reservation of rights letter: more inventory or chemicals than disclosed, fire protection impaired without notice, pollution in the loss, storm involvement, contract waivers that affect subrogation, and late notice. After it pays, an insurer can pursue whoever caused the loss, such as a pump or valve maker, a sprinkler contractor or a lessee whose product changed the hazard. A storage operator can be the target too: insurers who paid Bio-Lab's neighbors have sued to recover $20 million and more than $115,000 in payments. Those are claims in litigation, not findings. Your contracts' waiver of subrogation terms matter, and that review belongs with your attorney.

Sources: CSB Bio-Lab release; ISO CP 04 11; Eng-Tips; CSB ITC final report; Insurance Journal (2025); Insurance Business (2026).

Texas

Texas rules that gate your restart

SB 900 and the storage vessel program

The Legislature passed SB 900 after the ITC fire. TCEQ estimated about 36,000 Texas aboveground vessels fall under the program, with registration due Sept. 1, 2027. A tank rebuilt after a fire and placed in service after that date may face new-vessel standards. Whether a given rebuild counts as new is a question for your attorney and the engineer of record.

Item	Requirement
Scope	Vessels of 21,000 gallons (500 barrels) or more at petrochemical plants, refineries and bulk terminals holding a regulated substance, including mixtures of 1% or more by weight
Exemptions	Twelve types, including stormwater and wastewater vessels, IBCs, LPG vessels and vessels above 0.5 psig
Existing vessels	Register by Sept. 1, 2027; meet standards at the next out-of-service maintenance after that; certify by Sept. 1, 2037
New vessels (in service after Sept. 1, 2027)	Register and certify within 30 days of startup; meet API 650 and NFPA 30 Chapter 22 location rules
Standards	API 653 and API 2350 for design and maintenance; NFPA 30 Chapter 22.8 or API RP 2001 for fire protection
Fees	$200 a year for 500 to 20,000 barrels, scaled above that, to $2,000 for 750,000 barrels or more
Inspections	TCEQ inspects at least every five years

Ordinance or law

Standard ISO ordinance or law coverage pays for the undamaged part torn down under a building law, demolition, and the added cost to rebuild to code, which pays only if you actually rebuild. The base form's own code-upgrade coverage is the lesser of 5% of the building limit or $10,000, and ordinance or law coverage excludes pollutant laws. Steel mill product prices rose 27.6% in the 12 months to September 2026, and Section 232 tariffs stand at 50% on steel, so tank and piping rebuild costs move fast.

Ordinance or law calculator

Federal gaps for storage

OSHA's process safety rule excludes many flammable liquids stored in atmospheric tanks, and ITC relied on that exemption. The CSB asked OSHA to remove it and asked EPA to cover flammable mixtures rated NFPA 3 or higher; both requests remain open. EPA proposed revisions to its Risk Management Program rule on Feb. 24, 2026, and as of Oct. 20, 2026 no final rule was found. Which dates bind your site is a question for your attorney.

Payment deadlines and appraisal

Texas gives insurers 15 days to acknowledge a claim, 15 business days to accept or reject once they have the items they requested, and 5 business days to pay an accepted claim. Surplus lines carriers get 30 business days to acknowledge and 20 business days to pay. Amount disputes can go to appraisal. In 2026, the Texas Supreme Court ordered appraisal of a Dallas food-distribution warehouse loss from a ruptured fire-suppression water line, holding that possible coverage disputes do not defeat it.

Prompt payment deadline calculator

Storms

Hurricane season runs June 1 to Nov. 30. In 2017, Harvey floodwater cut power and refrigeration to Arkema's organic peroxide storage in Crosby and the product burned; its insurer had flagged the flood risk in 2016. After Hurricane Beryl, Port Houston terminals stayed closed on July 9, 2024, and more than 1.76 million CenterPoint customers lost power. In storm losses, expect flood vs. fire sequencing questions, and keep the timeline of when power, refrigeration and fire pumps were lost.

Sources: SB 900 House bill analysis; TCEQ storage vessel memo (2023); ALL4 (2026); CP 04 05; BLS PPI (Oct. 2026); Shapiro tariff table; 29 CFR 1910.119; CSB ITC page; Spencer Fane (2026); Tex. Ins. Code §§542.055 to 542.057; In re Ace American (Tex. 2026); TCEQ hurricanes page; CSB Arkema report; ICIS.

Checklist

Documents to pull this week

Pull and preserve these before anything is pumped out, demolished or overwritten, and before the first records request.

Contracts and customers' goods

terminal services agreements, tank leases, storage agreements, warehouse receipts and bills of lading; customer inventory statements by owner, product, tank or lot, and date; clauses on who insures product, valuation, liability caps, indemnities, waivers of subrogation and force majeure; certificates of insurance exchanged with customers.

Policies

every policy with full forms and endorsements (property, stock, inland marine or warehouse legal liability, pollution, storage tank liability, general liability and umbrella); statements of values and business income worksheets, including declared inventory values; every insurer loss-control survey with your response.

Tanks

strapping charts, automatic tank gauge history and transfer records; API 653 inspection reports and API 650 construction data; overfill protection records; roof and seal inspections; SB 900 registration in STEERS.

Containment

dike design and as-builts, grading and drainage plans, capacity calculations and past inspections.

Fire protection

design basis (NFPA 30, 400 or 13) and hydraulic calculations; sprinkler inspection, testing and maintenance reports; impairment logs, notices to the insurer and alarm monitoring records; fire pump and foam system test results.

Fire code and hazmat records

fire marshal approvals, occupancy permits and commodity classifications; consultant code reports; Tier II filings against actual inventory; safety data sheets; segregation plans; maximum allowable quantity and control area calculations.

Incident data

DCS or SCADA, gauge and alarm data, CCTV and shift logs; work orders and contractor records for the failed equipment; the failed component, under chain of custody.

Regulatory

spill reports and 30-working-day follow-ups; emissions-event reports; CSB and NRC report numbers; SPCC and facility response plans, air permits and agency correspondence.

Waste and environmental

waste manifests, recovered volumes, disposal invoices and on-site wastewater processing logs; lab data for residue, soil and water.

Income

three to five years of revenue by customer, tank or bay, and service; monthly throughput, occupancy and utilization; contract minimums; customer notices and terminations; extra expense invoices for firefighting contractors, vacuum trucks and temporary storage.

Neighbors and community

claims and letters from neighbors, the county and the state.

The insurance company's adjuster works for the insurance company.

After a major loss, the carrier sends its own adjuster, and often a forensic accountant and engineering consultants, all retained by the insurer. They are competent and they are not neutral; their job is to resolve the claim on terms favorable to the company that pays them. A public adjuster is the licensed counterweight: we represent the policyholder only, we build and present the claim, and we negotiate the settlement.

On a storage loss the asymmetry is the whole problem. The carrier side can bring fire protection engineers, geotechnical and tank engineers, fire-code consultants, cause-and-origin investigators, corrosion specialists and forensic accountants. We document the full loss with the same rigor, and we are paid a percentage of what we recover, so our incentive is your number. We are licensed public adjusters, not attorneys: when a question turns on how the law or the policy language applies in a dispute, or involves customers, investigators, agencies or neighbors, we work alongside your attorney rather than in place of one.

What happens after you call.

Loss review and policy analysis

We read the actual policy - limits, coinsurance, pollution and contamination terms, ordinance-or-law, BI, exclusions - and assess the full scope before anyone commits to a number.

Document the contamination thoroughly, before it's minimized

Destroyed stock, the contamination footprint, the regulated cleanup, and the structure. We bring in industrial hygienists to document exactly what's present, where, and at what levels, while the evidence still exists.

Build the business-interruption claim, modeled several ways

From real utilization and financial records: remediation and clearance timelines, storage contracts, re-permitting, and the right look-back baseline, modeled independently and used against each other to substantiate the full loss.

Present, negotiate, and settle

We present the documented claim, contest the predictable shortfalls - starting with the pollution exclusion - and negotiate the settlement on your behalf through to resolution.

Questions chemical and hazmat storage operators ask

Who do I notify after a chemical storage fire in Texas, and how fast?

A reportable spill goes to TCEQ by phone as soon as possible and within 24 hours, at 1-800-832-8224. The U.S. Chemical Safety Board must be told within 8 hours of an accidental release with a death, serious injury or $1 million in property damage. Which reports apply to your site is a question for your attorney.

Does a call to the National Response Center cover our TCEQ report?

No. TCEQ says a call to the National Response Center or the LEPC does not count as notice to the state. Make both calls if both apply, and log each one.

Who pays for customers' product that burned in our tanks or warehouse?

It depends on your contracts and on whether you carry property-of-others or warehouse legal liability coverage. Some contracts leave title and insurance with the customer. Pull the contracts and policies first; who is liable is a question for your attorney.

Does warehouse legal liability insurance pay if we weren't negligent?

Generally it pays only what you are legally liable for under your storage contract or warehouse receipt. One broker's example shows a $0.50-a-pound cap cutting a $1 million loss to $500,000. Property-of-others coverage, if you carry it, responds to physical loss without a liability requirement.

Is cleanup of firewater, the dike and contaminated soil covered?

Often only in part. Separate debris removal, decontamination of your property, pollutant cleanup and third-party claims, because each sits under different coverage. Standard ISO forms carry a $10,000-per-location pollutant cleanup sublimit. ITC disposed of about 387,000 barrels of liquid waste after its fire.

We stored more than our declared values. What happens?

Expect coinsurance and disclosure questions. Build accurate inventory by owner and product right away, reconciled to Tier II filings and statements of values. What follows from a mismatch is a question for your attorney.

Our sprinklers set off water-reactive chemicals. Is that a fire loss?

The carrier will look at water, corrosion and maintenance exclusions alongside fire. At Bio-Lab in 2024, water from a corroded sprinkler part started the reaction. Document the sprinkler, impairment and inspection history from the start.

Do rebuilt tanks have to meet new Texas standards?

Under SB 900, vessels placed in service after Sept. 1, 2027 must meet API 650 and NFPA 30 Chapter 22 location rules and register within 30 days. Whether your rebuild counts as a new vessel is a question for your attorney and engineer of record.

How is lost income figured for a terminal or warehouse?

From storage, throughput and handling fees, or margin on distribution sales, using contract and volume history, plus continuing expenses. Standard business income starts 72 hours after the loss, and extended coverage after reopening runs 60 days unless you bought more.

A road, the Ship Channel or a shelter-in-place order shut us down. Can we claim it?

Look at civil authority and ingress-egress coverage. The standard clause requires nearby damage and an order that prohibits access, starts after 72 hours, and pays for up to 4 weeks. Whether a shelter-in-place order prohibits access is a question for your attorney.

How long does it take to reopen?

It varies widely. Bio-Lab's Lake Charles site reopened about 26 months after a 2020 storm-then-fire loss. After the 2024 Conyers fire, the CSB reports the company decided to cease operations there. Tank standards, fire-code re-approval, permits and cleanup all set the clock.

Is a public adjuster a lawyer?

No. A public adjuster documents, presents and negotiates your first-party property claim, and Texas law bars public adjusters from practicing law. We work alongside your attorney on legal questions.

What does it cost to hire a public adjuster?

We work on a percentage of the recovery, with no upfront cost. We're only paid if and when you recover, which aligns our incentive with maximizing your settlement. Fee specifics are discussed up front before you commit to anything.

Talk to us

Tell us what happened. We'll tell you straight whether you have a fight worth having.

No cost, no obligation. The fastest path is the phone - for a major loss, call and talk to a person today. A licensed Texas public insurance adjuster will review the loss with you.

713-369-4300

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Tell us what happened. A licensed Texas public adjuster will review the loss with you, and tell you straight whether you have a fight worth having. The review is free.

For fire claims, we call you back within 1 hour and visit your property within 24 hours or less.

A major loss is decided in the first moves. Make yours count.

Talk to a public adjuster who works only for you. No upfront cost - we're paid a percentage only if you recover.

713-369-4300

Crossroads Insurance Recovery Advocates · TDI License 1924788

This page is general educational information about commercial property claims, not legal advice or advice on your specific claim. Crossroads Insurance Recovery Advocates, Texas public adjuster entity license #1924788.

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