Washington, DC, January 12, 2005 - Members of the U.S. Chemical Safety and Hazard Investigation Board (CSB) have unanimously declared that the actions taken by the three companies involved in the fatal BLSR Operating Ltd. accident in Texas are "acceptable." All the recommendations are now "closed" and require no further follow-up by the CSB. The agency found that one company, T&L Environmental Services, exceeded the agency's recommended action. The decision was announced on the second anniversary of the January 13, 2003 accident that killed three workers.
CSB Chairman Carolyn Merritt said, "We are pleased that these companies have taken to heart the CSB recommendations that resulted from our thorough investigation of this very tragic accident. We are satisfied, after careful evaluation, that steps the three companies have taken are likely to prevent the same kind of accident from happening to them again. However, we remain concerned that other facilities may remain unaware of the potentially serious hazards of certain wastes from natural gas production."
The accident occurred on January 13, 2003, when a vapor cloud fire erupted at the BLSR oilfield waste disposal facility near Rosharon, Texas, south of Houston. The fire occurred as two vacuum trucks were unloading liquid wastes from gas production wells - a material known as "basic sediment and water" or BS&W - for disposal at the facility. Vapors from the waste, which was contaminated with highly flammable gas condensate, ignited and fatally burned two BLSR employees and one truck driver. Four other workers suffered serious burns but survived.
In its final report, the CSB found among other causes that the producer of the waste - natural gas well operator Noble Energy - did not recognize the potential flammability of the waste liquid and provide appropriate safety information to either T&L, the trucking company transporting the waste, or BLSR. CSB's investigation showed that BS&W from gas production wells commonly contains significant amounts of gas condensate, a flammable liquid hydrocarbon.
The CSB also found that BLSR management did not have safe unloading and handling practices for potentially flammable wastes and did not control potential ignition sources or use unloading techniques designed to minimize vapor formation. Another root cause was that T&L management did not require oilfield waste generators to provide its truck drivers with information on material hazards.
The CSB also concluded that some in the gas and oil production industry mistakenly assume that a special hazardous waste exemption for BS&W under EPA waste disposal rules also applies to the OSHA and DOT regulations concerning handling and transportation of flammable materials. "Applying pertinent regulations and good practices for flammable materials like BS&W is the key to preventing tragedies like the one in 2003 in Rosharon," CSB lead investigation John Vorderbrueggen said.
CSB issued recommendations to all three companies to prevent future accidents, and unanimously approved of all responses to those recommendations:
- Noble Energy: The Board noted that Noble Energy has provided material safety data sheets (MSDSs) on BS&W waste material to all haulers and disposal facility operators as recommended. The company has provided MSDSs to waste hauler contractors who might remove BS&W from a condensate storage tank and to each disposal facility operator that receives the liquid from condensate storage tanks. The Board also found that Noble has taken several important steps to minimize removal of potentially flammable hydrocarbon products when removing BS&W, instructing that supervisors confirm that each transporter is licensed to carry such oilfield waste and that each has received a copy of the MSDS. The company is now requiring that haulers complete a questionnaire regarding their environmental and safe handling practices.
- T&L Environmental Services, Inc.: The CSB declared that the company had complied with five recommendations designed to ensure that customers know what is being delivered, that vacuum trucks are operated in a safe manner, that emergency procedures address abnormal diesel engine operation, and that adequate training be provided for all personnel. The Board noted that T&L will no longer handle flammable products. The Board found that T&L not only met recommendation requirements on procedures and good practices for safe operation but had "exceeded" the recommended action by installing automatic safety measures, notably the "Diesel Protection System Air Intake Shut Down Valve." Also, the company issued flammable-atmosphere test meters to all drivers and requires the unloading area to be tested before transfer operations begin.
- BLSR Operating Ltd.: The CSB found that BLSR has, in response to a recommendation, developed a proper Waste Acceptance Plan that requires transporters to properly classify the hazard category of all wastes being shipped, and will request from each shipper the appropriate MSDS for each substance. If these are not provided, the waste will not be offloaded by BLSR. The Board noted that BLSR has adopted a recommendation to develop written procedures and provide training to employees on unloading all potentially flammable waste liquids, particularly to prevent static discharges that could ignite fumes. The company has also developed new procedures and provided training to employees - in English and Spanish - on unloading such liquids. Finally, the CSB determined that BLSR has complied with a recommendation to develop proper emergency procedures, particularly for when diesel engines over-speed due to the presence of highly flammable vapors.
The Board is awaiting responses from the U.S. Department of Transportation, OSHA, and the Texas Railroad Commission, which regulates oilfield activity in that state. The CSB recommended that the commission require oilfield drillers and producers to identify potential flammability hazards in waste liquids, and to issue information to the industry on such hazards.
In evaluating responses to its recommendations, Board Members vote on them as "acceptable" or "unacceptable." Within those categories, the Board may choose to keep the matter open or to close it, or to work on an acceptable alternative to the original recommendation. An "Open - Acceptable" designation means that the response is thus far acceptable but the Board is awaiting final action. "Open - Awaiting Response" means that the responding organization has not adequately responded but that the CSB is not ready to close the case. Recommendations are deemed "closed" when no further action is either required or expected.
The CSB is an independent federal agency charged with investigating industrial chemical accidents. The agency's board members are appointed by the president and confirmed by the Senate. CSB investigations look into all aspects of chemical accidents, including physical causes such as equipment failure as well as inadequacies in safety management systems.
The Board does not issue citations or fines but does make safety recommendations to plants, industry organizations, labor groups, and regulatory agencies such as OSHA and EPA. Further information about the CSB is available from www.csb.gov. For more information, contact Sandy Gilmour 202-261-7614 / 202-251-5496 (cell), or Daniel Horowitz, 202-261-7613 / 202-441-6074 (cell).