U.S.
CHEMICAL SAFETY AND HAZARD
INVESTIGATION BOARD
Urgent Recommendation
Whereas:
1.
On March 23, 2005, the BP Texas City refinery experienced a severe explosion
and
fire accident involving a raffinate splitter tower within the isomerization
(isom)
unit and associated blowdown system that resulted in 15 deaths, 170
injuries,
and significant economic losses; the accident was one of the most serious
U.S.
workplace disasters of the past two decades.
2.
All of the fatalities and many of the serious injuries occurred in or around the
nine
contractor trailers that were sited near process areas and as close as
121 feet from
the isom unit. This unit contained large quantities of flammable
hydrocarbons
and had a history of releases, fires, and other safety incidents
over the previous
two decades.
3.
Workers in adjacent units were injured in trailers as far as 480 feet from the
isom
blowdown drum. A number of trailers as far as 600 feet from the blowdown
drum
were heavily damaged.
4.
At the Texas City refinery, trailers had been periodically sited in and around
hazardous
process areas for reasons of convenience such as ready access to work
areas.
The trailers did not need to be located as close as they were to the process
areas
in order for workers to perform their job duties.
5.
Trailers had been sited periodically in the same location near the isomerization
unit
for a number of years. On September 1, 2004, and prior to a safety
assessment,
BP placed the trailer where 12 workers died near the isomerization
unit; a
month later BP applied a siting policy to approve the location. The eight
other
trailers placed nearby were not analyzed for hazards related to their location,
nor
was the impact of the total occupancy of multiple trailers in close proximity
considered.
6.
Under BP’s siting policy, trailers used for short periods of time such as
turnaround
trailers were considered as posing little or no danger to occupants.
This approach
conforms with the guidance provided in American Petroleum
Institute (API) Recommended
Practice 752, “Management of Hazards Associated
with Location of Process
Plant Buildings.” API 752 states that each company
may define its own
risk and occupancy criteria.
7.
API 752 is a widely recognized practice for complying with facility siting
requirements
under the Process Hazard Analysis element of OSHA’s Process
Safety Management
Standard (29 CFR 1910.119).
8. API 752 provides no minimum safe
distances from hazardous areas for trailers
used in refineries and other chemical
facilities. Trailers are not generally designed
to protect the occupants from
the fire and explosion hazards present in refineries.
In contrast, occupied
buildings (e.g. control rooms, operator shelters) located
within a process
unit are typically permanent and constructed to be blast and fire
resistant.
9.
Trailers can be easily relocated to less hazardous sites. Subsequent to the March
23rd
incident, BP America Inc. announced that it would move trailers at least 500
feet
from hazardous process areas. A number of contractor offices were moved to
an
offsite location.
10.
In 1995, another serious process plant incident involved occupied trailers placed
too
close to hazardous areas, resulting in significant deaths and injuries. At the
Pennzoil
Refinery in Rouseville, Pennsylvania, a hydrocarbon fire that resulted
from
the bursting of two storage tanks led to five fatalities, including two
contractors
who were in trailers sited near the tanks. A 1998 EPA investigation
report
determined that if the trailers had been isolated from the storage tank area
the
casualties may have been prevented.
11.
Under 42 U.S.C. §7412(r)(6)(C) (ii), the Board is charged with “recommending
measures
to reduce the likelihood or the consequences of accidental releases and
proposing
corrective steps to make chemical production, processing, handling and
storage
as safe and free from risk of injury as is possible ….”
12.
Board procedures authorize the issuance of an urgent safety recommendation
before
a final investigation report is completed where there is a likelihood that a
safety
issue is widespread at a number of sites.
Accordingly:
Pursuant
to its authority under 42 U.S.C. §7412(r)(6)(C)(i) and (ii), and in the interest
of
promoting safer operations at U.S. petrochemical facilities and protecting
workers and
communities from future accidents, the Board makes the following
urgent safety
recommendations:
American
Petroleum Institute
In light of the above findings concerning the March
23rd incident at BP’s Texas City
refinery, revise your Recommended Practice
752, “Management of Hazards
Associated with Location of Process Plant
Buildings” or issue a new Recommended
Practice to ensure the safe placement
of occupied trailers and similar temporary
structures away from hazardous areas
of process plants. Ensure that the new
recommended practice:
* Protects
occupants from accident hazards such as heat, blast overpressure, and
projectiles;
*
Establishes minimum safe distances for trailers and similar temporary
structures
away from hazardous areas of process plants;
* Evaluates the siting of
trailers under a separate methodology from permanent
structures, since trailers
are more susceptible to damage, are more readily
relocated, and likely do not
need to be placed near hazardous areas.
American
Petroleum Institute and the National Petrochemical and Refiners
Association
Issue
a safety alert to your membership to take prompt action to ensure the safe
placement
of occupied trailers away from hazardous areas of process plants.
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