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Accidental Business Report 
By 
Farooq Ahmed Memon 
Orasoft Institue 
BBA 2nd semister
INVESTIGATION REPORT 
REFINERY EXPLOSION AND FIRE 
BP TEXAS CITY 
March 23 2005
S. No. Contents Page 
No. 
1 Preface 
2 Letter of authorization 
3 Letter of Transmittal 
4 Introduction 
5 Text of Report 
Introduction 
EXECUTIVE SUMMARY 
Incident synopsis 
Scope of investigations 
Bp group and Texas city 
Observations 
Incident Description 
Health and Safety 
Ignition Source 
6 Conclusion 
7 Recommendation 
8 Appendix
BP Texas City Company 
31, Oil Refinery, 
Texas 
20 May 2005 
Mr. T.M John 
131/9 Texas City 
Texas. 
Dear Sir, 
Having accepted your terms and conditions laid down in your letter dated 27th instant., the Board of Directors 
authorizes to you to make a report on the commercial prospects of BP Texas City Company to be manufactured 
by the firm vide letter No. BP/Rep/85/ dated 20th May 2005. You are requested to submitted your report to the 
undersigned with in 15 days by 15th June 2005. 
You are hereby, assured of all sorts of assistance and help possible from the staff and Executive at any time. 
Let this letter be acknowledge and also mentions the date on which you are going to start your work 
Your faithfully, 
S/d 
Managing Director 
BP Texas City Company
131/9, Texas 
Texas. 
To, 
The Managing Director, 
BP Texas City Company 
Texas. 
Dear Sir, 
In response of your letter No. BP/RED 85 dated 23 March 2005 regarding a report to be prepared 
by me on the subjected which comprises of three parts along with the recommendations and 
suggestions. I hope that you will find the report beneficial for the business of the company. 
Will you please be kind enough to communicate your views? It would be highly regarded if I were 
given a chance to appear before you and explain any of the aspect of the report at your office at 
any time by appointment. 
Your Truly 
s/d 
T.M John
EXECUTIVE SUMMARY 
Incident synopsis 
On March 23, 2005, at 1:20 p.m., the BP Texas City Refinery suffered 
one of the worst industrial disasters in recent U.S. history. Explosions 
and fires killed 15 people and injured another 180, alarmed the 
community, and resulted in financial losses exceeding $1.5 billion. The 
incident occurred during the startup of an isomerization1 (ISOM) unit 
when a raffinate splitter tower2 was overfilled; pressure relief devices 
opened, resulting in a flammable liquid geyser from a blowdown stack 
that was not equipped with a flare. The release of flammables led to an 
explosion and fire. All of the fatalities occurred in or near office 
trailers located close to the blowdown drum. A shelter-in-place order 
was issued that required 43,000 people to remain indoors. Houses were 
damaged as far away as three-quarters of a mile from the refinery. 
 
The BP Texas City facility is the third-largest oil refinery in the United 
States. Prior to 1999, Amoco owned the refinery. BP merged with 
Amoco in 1999 and BP subsequently took over operation of the plant.
 
BP Group and Texas City 
 
The Texas City disaster was caused by organizational and safety 
deficiencies at all levels of the BP Corporation. Warning signs of a 
possible disaster were present for several years, but company officials 
did not intervene effectively to prevent it. The extent of the serious 
safety culture deficiencies was further revealed when the refinery 
experienced two additional serious incidents just a few months after 
the March 2005 disaster. In one, a pipe failure caused a reported $30 
million in damage; the other resulted in a $2 million property loss. In 
each incident, community shelter-in-place orders were issued. 
 
This investigation was conducted in a manner similar to that used by 
the Columbia Accident Investigation Board (CAIB) in its probe of the 
loss of the space shuttle. Using the CAIB model, the CSB examined 
both the technical and organizational causes of the incident at Texas 
City
 
Incident Description 
On the morning of March 23, 2005, the raffinate splitter tower in the refinery’s 
ISOM unit was restarted after a maintenance outage. During the startup, 
operations personnel pumped flammable liquid hydrocarbons into the tower 
for over three hours without any liquid being removed, which was contrary to 
startup procedure instructions. Critical alarms and control instrumentation 
provided false indications that failed to alert the operators of the high level in 
the tower. Consequently, unknown to the operations crew, the 170-foot (52-m) 
tall tower was overfilled and liquid overflowed into the overhead pipe at the 
top of the tower. 
The overhead pipe ran down the side of the tower to pressure relief valves located 
148 feet (45 m) below. As the pipe filled with liquid, the pressure at the bottom 
rose rapidly from about 21 pounds per square inch (psi) to about 64 psi. The 
three pressure relief valves opened for six minutes, discharging a large 
quantity of flammable liquid to a blowdown drum with a vent stack open to 
the atmosphere. The blowdown drum and stack overfilled with flammable 
liquid, which led to a geyser-like release out the 113-foot (34 m) tall stack. 
This blowdown system was an antiquated and unsafe design; it was originally 
installed in the 1950s, and had never been connected to a flare system to safely 
contain liquids and combust flammable vapors released from the process.
Incident Description 
The released volatile liquid evaporated as it fell to the ground 
and formed a flammable vapor cloud. The most likely source 
of ignition for the vapor cloud was backfire from an idling 
diesel pickup truck located about 25 feet (7.6 m) from the 
blowdown drum. The 15 employees killed in the explosion 
were contractors working in and around temporary trailers 
that had been previously sited by BP as close as 121 feet (37 
m) from the blowdown drum.
BP Corporate and Texas City Refinery Background 
On March 23, 2005, an explosion and fires occurred at the BP refinery in 
Texas City, Texas, 30 miles southeast of Houston. The refinery, the 
company’s largest worldwide, can produce about 10 million gallons of 
gasoline per day (about 2.5 percent of the gasoline sold in the United States) 
for markets primarily in the Southeast, Midwest, and along the East Coast. It 
also produces jet fuels, diesel fuels, and chemical feed stocks; 29 oil refining 
units and four chemical units cover its 1,200 acre site. The refinery employs 
approximately 1,800 BP workers, and at the time of the incident, 
approximately 800 contractor workers were onsite supporting turnaround13 
work. The site has also had numerous changes in management at both the 
refinery and corporate levels.
Raffinate Splitter Section 
On the day of the incident, the startup of the ISOM raffinate splitter section 
was initiated. It was during this startup that the tower was overfilled with 
liquid. This section describes the relevant equipment involved in the startup 
on March 23, 2005. 
The raffinate splitter section took raffinate -- a non-aromatic, primarily 
straight-chain hydrocarbon mixture -- from the Aromatics Recovery Unit 
(ARU) and separated it into light and heavy components. About 40 percent 
of the raffinate feed was recovered as light raffinate (primarily 
pentane/hexane). The remaining raffinate feed was recovered as heavy 
raffinate, which was used as a chemicals feedstock, JP-4 jet fuel, or 
blended into unleaded gasoline. The raffinate splitter section could process 
up to 45,000 barrels per day (bpd)16 of raffinate feed.
Flammable Vapor Cloud Formation and Fire 
The liquid hydrocarbon release time was calculated using computerized control 
system data points and the flow times from DIERS modeling (Appendix H). The 
flammable vapor cloud reached a wide area, as is clearly evident by the burned 
area shown in a post-explosion photo (Figure 10). 
The burned area is estimated to be approximately 200,000 square feet (18, 581 
m2). Two mechanisms explain how the vapor cloud covered an area this size in 
such a short interval: the first was direct dispersion from evaporation prior to 
ignition that was responsible for the bulk of the dispersal, and the second was 
“pushing” of flammable vapors as subsonic flames burned through the flammable 
cloud. The hydrocarbon liquid cascading down the stack and blowdown drum 
coupled with the impact of the falling liquid onto process equipment, structural 
components, and piping, promoted fragmentation into relatively small droplets, 
thereby enhancing evaporation and the formation of the flammable vapor cloud
Atmospheric wind also helped push the vapors and small 
droplets downwind, causing them to mix with air. The wind 
direction at the time of the incident was reported to be out of the 
northwest traveling southeast at 5 miles (8 km) per hour and as 
Figure 10 shows, the burned area is elongated in that direction. 
However, portions of the vapor cloud also went upwind and 
cross wind (Appendix H.10.1), which placed the trailer area 
within the flammable cloud covered area.
Ignition Source
Blast Pressure 
Once ignited, the flame rapidly spread through the flammable 
vapor cloud, compressing the gas ahead of it to create a blast 
pressure wave. Furthermore, the flame accelerated each time a 
combination of congestion/confinement and flammable mix 
allowed, greatly intensifying the blast pressure in certain areas. 
These intense pressure regions, or sub-explosions, produced 
heavy structural damage locally and left a pattern of structural 
deformation away from the blast center in all directions. A computer 
simulation49 and a blast overpressure map were developed based 
on site observations, structural analysis, and blast modeling.
Fatalities and Injuries 
In the explosion, 15 contract employees working in or near the trailers 
sited between the ISOM and the NDU unit were killed. Autopsy reports 
revealed that the cause of death for all 15 was blunt force trauma, 
probably resulting from being struck by structural components of the 
trailers. Three occupants in the Quality Assurance/Quality Control 
(QA/QC) trailer perished, and 12 of 20 workers inside the double-wide 
trailer were killed; the others were seriously injured. 
A total of 180 workers at the refinery were injured, 66 seriously enough 
that they had days away from work, restricted work activity, or medical 
treatment. The majority of these suffered multiple injuries, typically 
combinations of: fractures, lacerations, punctures, strains, sprains, 
and/or second- and third-degree burns. Of the seriously injured, 14 
were BP employees; the rest were contractor employees from 13 
different firms. Of the 114 workers given first aid, 35 were BP 
employees; 79 were contract employees from 14 different contracting 
firms. None of the contract workers in the area surrounding the ISOM 
were personnel essential to the startup of the unit.
Equipment and Facility Damage 
The most severe blast damage occurred within the ISOM unit, from the 
trailer area to the catalyst warehouse (Figure 13), and the surrounding 
parking areas. The satellite control room was severely damaged and the 
catalyst warehouse was destroyed. Many of the approximately 70 
vehicles in the vicinity of the ISOM unit were damaged and a number 
were destroyed. More than 40 trailers were damaged; 13 were destroyed. 
On June 30, 2006, the CSB released a detailed analysis of the trailer 
damage, which can be viewed or downloaded from the CSB website,
Post-Incident Emergency Response 
The emergency response teams made a rapid and effective effort to help the 
injured and recover the victims. Texas City Industrial Mutual Aid System 
(IMAS) member companies responded and assisted with fire hose lines and 
search-and-rescue. None of the emergency response personnel were injured 
during rescue efforts. 
The blast produced a large debris field of damaged trailers and vehicles 
located between the NDU and ISOM units. To recover victims from this area, 
the site was necessarily disturbed by the emergency responders. Debris, 
vehicles, and equipment were moved to initiate search-and-rescue and 
recover the fatally injured. As operators and emergency responders entered 
the ISOM unit to isolate the plant, some valve positions were changed, but no 
records were kept to document these changes. Therefore, there was no 
record of the actual state of some of the valves at the time of the incident, 
information that is important when trying to reconstruct the incident and 
determine its causes.
Ineffective and Insufficient Communication Among Operations Personnel 
Two critical miscommunications occurred among operations personnel on 
March 23, 2005, that led to the delay in sending liquid raffinate to storage: 1) 
the instructions for routing raffinate products to storage tanks were not 
communicated from Texas City management and supervisors to operators; 
and 2) the condition of the unit – specifically, the degree to which the unit 
was filled with liquid raffinate – was not clearly communicated from night 
shift to day shift.68 These lapses in communication were the result of BP 
management’s lack of emphasis on the importance of communication. BP 
had no policy for effective shift communication,69 nor did it enforce formal 
shift turnover or require logbook/procedural records to ensure 
communication was clearly and appropriately disseminated among 
operating crew
BP Actions After the Explosion 
In its internal investigation of the March 23, 2005 explosion, 
BP adopted new policies for trailer siting at its facilities. 
Appendix 37 in the “Fatal Accident Investigation Report” 
(Mogford, 2005) outlines the specifics of BP’s new siting 
policy; trailer siting is now based on exclusion zones for 
areas where explosions are possible, and all occupied trailers 
should be located outside of vulnerable areas even if this 
means a location outside the refinery. A large number of 
Texas City personnel were relocated to a permanent building 
away from the refinery after the incident.
Conclusion 
Based on the analysis of the relief system, the blowdown drum was 
undersized and the emergency relief system design did not address the 
potential of a large liquid release in the event the raffinate splitter tower 
overfilled. After the March 23, 2005, incident, BP evaluated the 22 blowdown 
systems at its five U.S. refineries and found that 17 handled flammables. BP 
has publicly pledged to eliminate all atmospheric blowdown systems in 
flammable service at all five of its U.S. refineries. requires that relief system 
designs comply with “recognized and generally accepted good engineering 
practices.” Published PSM compliance guidelines call for inspections to 
ensure that “destruct systems, such as flares, are in place and operating” 
and that “pressure relief valves and rupture discs are properly designed 
and discharge to a safe area” (CPL 2-2.45A, 1994). Therefore, the CSB 
recommended that OSHA implement a special emphasis program for oil 
refineries to focus on blowdown drums that discharge directly to the 
atmosphere and their design
THANKS FOR LISTENING

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Accidental Short Report on Texas City Refinery Explosion 2005

  • 1. Accidental Business Report By Farooq Ahmed Memon Orasoft Institue BBA 2nd semister
  • 2. INVESTIGATION REPORT REFINERY EXPLOSION AND FIRE BP TEXAS CITY March 23 2005
  • 3. S. No. Contents Page No. 1 Preface 2 Letter of authorization 3 Letter of Transmittal 4 Introduction 5 Text of Report Introduction EXECUTIVE SUMMARY Incident synopsis Scope of investigations Bp group and Texas city Observations Incident Description Health and Safety Ignition Source 6 Conclusion 7 Recommendation 8 Appendix
  • 4. BP Texas City Company 31, Oil Refinery, Texas 20 May 2005 Mr. T.M John 131/9 Texas City Texas. Dear Sir, Having accepted your terms and conditions laid down in your letter dated 27th instant., the Board of Directors authorizes to you to make a report on the commercial prospects of BP Texas City Company to be manufactured by the firm vide letter No. BP/Rep/85/ dated 20th May 2005. You are requested to submitted your report to the undersigned with in 15 days by 15th June 2005. You are hereby, assured of all sorts of assistance and help possible from the staff and Executive at any time. Let this letter be acknowledge and also mentions the date on which you are going to start your work Your faithfully, S/d Managing Director BP Texas City Company
  • 5. 131/9, Texas Texas. To, The Managing Director, BP Texas City Company Texas. Dear Sir, In response of your letter No. BP/RED 85 dated 23 March 2005 regarding a report to be prepared by me on the subjected which comprises of three parts along with the recommendations and suggestions. I hope that you will find the report beneficial for the business of the company. Will you please be kind enough to communicate your views? It would be highly regarded if I were given a chance to appear before you and explain any of the aspect of the report at your office at any time by appointment. Your Truly s/d T.M John
  • 6.
  • 7. EXECUTIVE SUMMARY Incident synopsis On March 23, 2005, at 1:20 p.m., the BP Texas City Refinery suffered one of the worst industrial disasters in recent U.S. history. Explosions and fires killed 15 people and injured another 180, alarmed the community, and resulted in financial losses exceeding $1.5 billion. The incident occurred during the startup of an isomerization1 (ISOM) unit when a raffinate splitter tower2 was overfilled; pressure relief devices opened, resulting in a flammable liquid geyser from a blowdown stack that was not equipped with a flare. The release of flammables led to an explosion and fire. All of the fatalities occurred in or near office trailers located close to the blowdown drum. A shelter-in-place order was issued that required 43,000 people to remain indoors. Houses were damaged as far away as three-quarters of a mile from the refinery.  The BP Texas City facility is the third-largest oil refinery in the United States. Prior to 1999, Amoco owned the refinery. BP merged with Amoco in 1999 and BP subsequently took over operation of the plant.
  • 8.  BP Group and Texas City  The Texas City disaster was caused by organizational and safety deficiencies at all levels of the BP Corporation. Warning signs of a possible disaster were present for several years, but company officials did not intervene effectively to prevent it. The extent of the serious safety culture deficiencies was further revealed when the refinery experienced two additional serious incidents just a few months after the March 2005 disaster. In one, a pipe failure caused a reported $30 million in damage; the other resulted in a $2 million property loss. In each incident, community shelter-in-place orders were issued.  This investigation was conducted in a manner similar to that used by the Columbia Accident Investigation Board (CAIB) in its probe of the loss of the space shuttle. Using the CAIB model, the CSB examined both the technical and organizational causes of the incident at Texas City
  • 9.  Incident Description On the morning of March 23, 2005, the raffinate splitter tower in the refinery’s ISOM unit was restarted after a maintenance outage. During the startup, operations personnel pumped flammable liquid hydrocarbons into the tower for over three hours without any liquid being removed, which was contrary to startup procedure instructions. Critical alarms and control instrumentation provided false indications that failed to alert the operators of the high level in the tower. Consequently, unknown to the operations crew, the 170-foot (52-m) tall tower was overfilled and liquid overflowed into the overhead pipe at the top of the tower. The overhead pipe ran down the side of the tower to pressure relief valves located 148 feet (45 m) below. As the pipe filled with liquid, the pressure at the bottom rose rapidly from about 21 pounds per square inch (psi) to about 64 psi. The three pressure relief valves opened for six minutes, discharging a large quantity of flammable liquid to a blowdown drum with a vent stack open to the atmosphere. The blowdown drum and stack overfilled with flammable liquid, which led to a geyser-like release out the 113-foot (34 m) tall stack. This blowdown system was an antiquated and unsafe design; it was originally installed in the 1950s, and had never been connected to a flare system to safely contain liquids and combust flammable vapors released from the process.
  • 10. Incident Description The released volatile liquid evaporated as it fell to the ground and formed a flammable vapor cloud. The most likely source of ignition for the vapor cloud was backfire from an idling diesel pickup truck located about 25 feet (7.6 m) from the blowdown drum. The 15 employees killed in the explosion were contractors working in and around temporary trailers that had been previously sited by BP as close as 121 feet (37 m) from the blowdown drum.
  • 11. BP Corporate and Texas City Refinery Background On March 23, 2005, an explosion and fires occurred at the BP refinery in Texas City, Texas, 30 miles southeast of Houston. The refinery, the company’s largest worldwide, can produce about 10 million gallons of gasoline per day (about 2.5 percent of the gasoline sold in the United States) for markets primarily in the Southeast, Midwest, and along the East Coast. It also produces jet fuels, diesel fuels, and chemical feed stocks; 29 oil refining units and four chemical units cover its 1,200 acre site. The refinery employs approximately 1,800 BP workers, and at the time of the incident, approximately 800 contractor workers were onsite supporting turnaround13 work. The site has also had numerous changes in management at both the refinery and corporate levels.
  • 12. Raffinate Splitter Section On the day of the incident, the startup of the ISOM raffinate splitter section was initiated. It was during this startup that the tower was overfilled with liquid. This section describes the relevant equipment involved in the startup on March 23, 2005. The raffinate splitter section took raffinate -- a non-aromatic, primarily straight-chain hydrocarbon mixture -- from the Aromatics Recovery Unit (ARU) and separated it into light and heavy components. About 40 percent of the raffinate feed was recovered as light raffinate (primarily pentane/hexane). The remaining raffinate feed was recovered as heavy raffinate, which was used as a chemicals feedstock, JP-4 jet fuel, or blended into unleaded gasoline. The raffinate splitter section could process up to 45,000 barrels per day (bpd)16 of raffinate feed.
  • 13. Flammable Vapor Cloud Formation and Fire The liquid hydrocarbon release time was calculated using computerized control system data points and the flow times from DIERS modeling (Appendix H). The flammable vapor cloud reached a wide area, as is clearly evident by the burned area shown in a post-explosion photo (Figure 10). The burned area is estimated to be approximately 200,000 square feet (18, 581 m2). Two mechanisms explain how the vapor cloud covered an area this size in such a short interval: the first was direct dispersion from evaporation prior to ignition that was responsible for the bulk of the dispersal, and the second was “pushing” of flammable vapors as subsonic flames burned through the flammable cloud. The hydrocarbon liquid cascading down the stack and blowdown drum coupled with the impact of the falling liquid onto process equipment, structural components, and piping, promoted fragmentation into relatively small droplets, thereby enhancing evaporation and the formation of the flammable vapor cloud
  • 14. Atmospheric wind also helped push the vapors and small droplets downwind, causing them to mix with air. The wind direction at the time of the incident was reported to be out of the northwest traveling southeast at 5 miles (8 km) per hour and as Figure 10 shows, the burned area is elongated in that direction. However, portions of the vapor cloud also went upwind and cross wind (Appendix H.10.1), which placed the trailer area within the flammable cloud covered area.
  • 16. Blast Pressure Once ignited, the flame rapidly spread through the flammable vapor cloud, compressing the gas ahead of it to create a blast pressure wave. Furthermore, the flame accelerated each time a combination of congestion/confinement and flammable mix allowed, greatly intensifying the blast pressure in certain areas. These intense pressure regions, or sub-explosions, produced heavy structural damage locally and left a pattern of structural deformation away from the blast center in all directions. A computer simulation49 and a blast overpressure map were developed based on site observations, structural analysis, and blast modeling.
  • 17. Fatalities and Injuries In the explosion, 15 contract employees working in or near the trailers sited between the ISOM and the NDU unit were killed. Autopsy reports revealed that the cause of death for all 15 was blunt force trauma, probably resulting from being struck by structural components of the trailers. Three occupants in the Quality Assurance/Quality Control (QA/QC) trailer perished, and 12 of 20 workers inside the double-wide trailer were killed; the others were seriously injured. A total of 180 workers at the refinery were injured, 66 seriously enough that they had days away from work, restricted work activity, or medical treatment. The majority of these suffered multiple injuries, typically combinations of: fractures, lacerations, punctures, strains, sprains, and/or second- and third-degree burns. Of the seriously injured, 14 were BP employees; the rest were contractor employees from 13 different firms. Of the 114 workers given first aid, 35 were BP employees; 79 were contract employees from 14 different contracting firms. None of the contract workers in the area surrounding the ISOM were personnel essential to the startup of the unit.
  • 18. Equipment and Facility Damage The most severe blast damage occurred within the ISOM unit, from the trailer area to the catalyst warehouse (Figure 13), and the surrounding parking areas. The satellite control room was severely damaged and the catalyst warehouse was destroyed. Many of the approximately 70 vehicles in the vicinity of the ISOM unit were damaged and a number were destroyed. More than 40 trailers were damaged; 13 were destroyed. On June 30, 2006, the CSB released a detailed analysis of the trailer damage, which can be viewed or downloaded from the CSB website,
  • 19. Post-Incident Emergency Response The emergency response teams made a rapid and effective effort to help the injured and recover the victims. Texas City Industrial Mutual Aid System (IMAS) member companies responded and assisted with fire hose lines and search-and-rescue. None of the emergency response personnel were injured during rescue efforts. The blast produced a large debris field of damaged trailers and vehicles located between the NDU and ISOM units. To recover victims from this area, the site was necessarily disturbed by the emergency responders. Debris, vehicles, and equipment were moved to initiate search-and-rescue and recover the fatally injured. As operators and emergency responders entered the ISOM unit to isolate the plant, some valve positions were changed, but no records were kept to document these changes. Therefore, there was no record of the actual state of some of the valves at the time of the incident, information that is important when trying to reconstruct the incident and determine its causes.
  • 20. Ineffective and Insufficient Communication Among Operations Personnel Two critical miscommunications occurred among operations personnel on March 23, 2005, that led to the delay in sending liquid raffinate to storage: 1) the instructions for routing raffinate products to storage tanks were not communicated from Texas City management and supervisors to operators; and 2) the condition of the unit – specifically, the degree to which the unit was filled with liquid raffinate – was not clearly communicated from night shift to day shift.68 These lapses in communication were the result of BP management’s lack of emphasis on the importance of communication. BP had no policy for effective shift communication,69 nor did it enforce formal shift turnover or require logbook/procedural records to ensure communication was clearly and appropriately disseminated among operating crew
  • 21. BP Actions After the Explosion In its internal investigation of the March 23, 2005 explosion, BP adopted new policies for trailer siting at its facilities. Appendix 37 in the “Fatal Accident Investigation Report” (Mogford, 2005) outlines the specifics of BP’s new siting policy; trailer siting is now based on exclusion zones for areas where explosions are possible, and all occupied trailers should be located outside of vulnerable areas even if this means a location outside the refinery. A large number of Texas City personnel were relocated to a permanent building away from the refinery after the incident.
  • 22. Conclusion Based on the analysis of the relief system, the blowdown drum was undersized and the emergency relief system design did not address the potential of a large liquid release in the event the raffinate splitter tower overfilled. After the March 23, 2005, incident, BP evaluated the 22 blowdown systems at its five U.S. refineries and found that 17 handled flammables. BP has publicly pledged to eliminate all atmospheric blowdown systems in flammable service at all five of its U.S. refineries. requires that relief system designs comply with “recognized and generally accepted good engineering practices.” Published PSM compliance guidelines call for inspections to ensure that “destruct systems, such as flares, are in place and operating” and that “pressure relief valves and rupture discs are properly designed and discharge to a safe area” (CPL 2-2.45A, 1994). Therefore, the CSB recommended that OSHA implement a special emphasis program for oil refineries to focus on blowdown drums that discharge directly to the atmosphere and their design