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Intercontinental Terminals Company (ITC) Tank Fire

Overview

On March 17, 2019, a fire erupted at the First and Second 80’s tank farm at the Intercontinental Terminals Company (ITC) Deer Park terminal in Deer Park, Texas. The fire originated at Tank 80-8 and spread through the tank farm over several days despite firefighting efforts. The incident resulted in the destruction of all fifteen tanks in the containment area, a partial collapse of the containment wall, and a large release of petroleum products, firefighting foam, and water into Tucker Bayou and adjacent waterways.

Incident Snapshot

Field Value
Facility / Company Intercontinental Terminals Company, LLC (ITC)
Location Deer Park, TX
Incident Date 03/17/2019
Investigation Status The CSB's Investigation is currently ongoing.
Accident Type Explosion and Fire Investigation
Final Report Release Date 07/06/2023

What Happened

  • At approximately 10:00am on March 17, 2019, a fire broke out at the First and Second 80’s tank farm at ITC Deer Park Terminal.
  • The fire originated at Tank 80-8 and proceeded to spread throughout the tank farm over the next several days despite firefighting efforts.
  • The ITC Emergency Response Team and the Channel Industries Mutual Aid organization (CIMA) fought the fire between March 17 and March 22.
  • Firefighting operations consisted of the application of firefighting foam mixed with water and the application of water to cool surrounding tanks.
  • On March 22, the fire had been successfully suppressed and firefighters were periodically re-applying additional firefighting foam to maintain a continuous blanket of foam across the site.
  • At approximately 12:00pm on March 22, a section of the containment wall on the north side of the tank farm, between tanks 80-4 and 80-7, failed, allowing the liquid mixture inside the tank farm to flow into the drainage ditch between the tank farm and Tidal Road.
  • The response team had to retreat from immediately impacted areas.
  • Flare-ups of fire in the drainage ditch and tank farm required re-application of firefighting foam.
  • The team deployed additional booms in the waterways to contain product, and took measures to mitigate the leak from the tank farm.
  • Initially, the incident response team utilized T-rail Jersey Barriers and sandbags inside the tank farm in an attempt to build a new containment structure to stop the breach and reestablish containment.
  • This was augmented on March 23 by bringing in off-site soils to reinforce the immediate measures and construct a dike wall inside the breach.
  • Eventually, the incident response team was able to stabilize the site and begin remediation measures.
  • On the morning of March 17, 2019, a fire initiated at the Deer Park, Texas terminal owned and operated by ITC, specifically within the “First and Second 80’s” tank farm.
  • The fire events occurred from Sunday, March 17, 2019, through Saturday, March 23, 2019.
  • By approximately noon on March 17, 2019, the ITC Deer Park emergency response team had activated their association with adjoining facilities and public emergency response agencies via the Channel Industries Mutual Aid (CIMA) group.
  • By this time, fire had spread to Tank 80-11.
  • The decision to contract US Fire Pump on the evening of March 18 would introduce additional personnel, equipment, and tactics to the operation by early morning on March 19.
  • Tank 80-5 took to ignite (approximately 7 hours after fire initiation).
  • Subsequent ignitions were Tanks 80-2, 80-3, 80-6, 80-9 and 80-11 within 6.5 hours after ignition of Tank 80-5.

Facility and Process Context

  • The tank farm consisted of fifteen 80,000-barrel tanks arranged on a grid with five tanks in the east-west direction and three tanks in the north-south direction.
  • A concrete containment wall surrounded the site on four sides.
  • The ground surface inside the tank farm was indicated by ITC as natural grade soil covered with a minimum of six inches of stabilized materials consisting of crushed limestone, crushed concrete, cement stabilized sand, or similar materials.
  • The site was sloped gradually from north to south, with a stormwater drainage system collecting water at the south edge of the tank farm and directing it through pipes and control structures to the drainage ditch near the north-west corner of the site.
  • The containment wall was a cast-in-place concrete wall 8-inches thick and extending above the interior grade of the tank farm approximately 4 feet.
  • The wall was reinforced with two layers of deformed mild-steel reinforcing bars.
  • The wall was cast in sections, with a construction joint every 40 feet.
  • The joints were formed with a shear-key at the joint and a ribbed-wing centerbulb PVC waterstop incorporated into the construction joints to prevent liquids from leaking through the wall at the joints.
  • The drainage ditch between the containment wall and Tidal Road was a concrete-lined structure with a flat bottom and sloped side walls.
  • The concrete slab was approximately 4-inches thick, with welded-wire-reinforcement observed at broken sections of the concrete, typically located near the bottom of the slab.
  • The concrete slabs were cast in sections, with construction joints between the slabs.
  • The welded-wire reinforcement did not span across the construction joints.
  • Holes through the slab were observed along the bottom edge of the sloped side-wall slabs, appearing to have the purpose of providing drainage of groundwater from behind the side slab into the drainage ditch.
  • The overall dimensions of the tank farm were approximately 137.2 m (450 ft) x 222.5 m (730 ft), consisting of three rows and five tanks of columns.
  • The fire occurred in the “First and Second 80’s” tank farm, located on the south side of the ITC site.
  • Tank 80-8 and its counterparts in the “First and Second 80’s” tank farm were 80,000 barrel capacity tanks, with a diameter of 110 feet and a height of 48 feet.
  • With the exception of Tanks 80-9, 80-11 and 80-12, tanks in the farm were provided with an internal floating roof and an external cone roof.
  • Tanks 80-9, 80-11 and 80-12 were provided only with a cone roof.
  • At the time of the fire, Tanks 80-9 and 80-11 were provided with insulation, while the remainder are uninsulated.
  • The insulation consisted of polyisocyanurate panels clad with aluminum jacket.
  • The overall tank farm has approximate dimensions of 449 feet (north-south) by 732 feet (east-west) on the interior of the containment area.
  • The surrounding containment wall is 4 feet in height.
  • Drainage for chemicals within the tank farm is provided by a system of inlets placed between each of the fuel tank groups.
  • Each of the tanks is provided with an installed foam fire suppression system, which is manually supplied and operated.
  • Hydrants and monitors, the majority being combination units, are located around the perimeter of the tank farm.
  • Water-spray systems were also installed on the tank farm manifold systems.
  • The fire systems and emergency response apparatus are supported by four fire pumps located at the north end of the facility, taking water from the ship channel.
  • For vehicle-based emergency response, access is provided into the tank farm at the southeast corner and the northwest corner.
  • Tank 80-8 was in the First and Second 80’s tank farm.
  • Tank 80-8 was an 80,000-barrel aboveground atmospheric storage tank.
  • The tank went into service in 1972 and was original to the ITC Deer Park Terminal.
  • Tank 80-8 was leased to another company for naphtha storage and for naphtha-butane blending operations.
  • The butane injection system was installed in August 2014.
  • In January 2016, a revision was made to the system whereby ITC replaced most of the 2-inch piping with 4-inch piping to reduce the time required to offload trucks.
  • ITC did not equip the Tank 80-8 piping manifold with emergency or remotely operated isolation valves.
  • Under a major fire scenario resulting from a leak near this equipment, neither ITC operators nor emergency responders could access the area to close these manually operated valves.

Consequences

  • Fatalities: None reported.
  • Injuries: 0
  • Environmental release: The section of the north secondary containment wall failed, permitting product, water, and firefighting foam to flow into a drainage ditch along Tidal Road and into the Tucker Bayou waterway north of the site. Approximately 470,000–523,000 barrels of hydrocarbon and petrochemical products, firefighting aqueous film forming foam, and contaminated water were released into Tucker Bayou and adjacent water, sediments, and habitats.
  • Facility damage: The fire spread to the majority of the tanks inside the tank farm. The containment wall displaced laterally, tearing the waterstop at multiple construction joints. The sloped slabs lining the drainage ditch displaced, buckled upward, and some were displaced entirely. The fire caused substantial property damage, including the destruction of fifteen 80,000-barrel aboveground atmospheric storage tanks and their contents. All fifteen tanks were destroyed.
  • Operational impact: Firefighting operations continued from March 17 to March 22. The response team had to retreat from immediately impacted areas. A seven-mile stretch of the Houston Ship Channel adjacent to the ITC Deer Park terminal was closed, as were several waterfront parks in Harris County and the City of LaPorte. Shelter-in-place orders were issued, local schools and businesses either closed or operated under modified conditions, and a portion of State Highway 225 was closed.

Key Findings

Immediate Causes

  • The containment wall primarily displaced laterally, with the lateral movement due to excessive lateral soil and hydrostatic pressures and inadequate soil resistance on the outside of the containment wall and inadequate sliding resistance of the footing.
  • As the wall deflected due to the excessive lateral earth and hydrostatic pressures, the construction joints began to open, tearing the waterstop material and increasing the velocity of the escaping water.
  • The results of the detailed fire modeling and hand calculations indicate that the Tank 80-8 rim fire alone did not provide enough heat to cause the fire to spread to adjacent tanks.
  • An additional heat source, such as a large liquid pool fire at ground level, allowed the fire in Tank 80-8 to spread to the adjacent tanks.
  • The synergistic effects of the tank fire and pool fire at ground level were sufficient to lead ignition at adjoining tanks.
  • The CSB determined that the cause of the incident was the release of flammable butane-enriched naphtha vapor from the failed Tank 80-8 circulation pump, which accumulated in the area and ignited, resulting in a fire.
  • seal failure of a pump operating in conjunction with Tank 80-8

Contributing Factors

  • The area inside the secondary containment walls, as well as the surrounding area of the site, was exposed to a continuous application of water, foam, and spilled hydrocarbon liquid products for six days prior to the breach.
  • Liquid levels inside the containment area could have potentially been as high as 4 feet above grade at the time of the containment wall failure.
  • The sloped slabs of the drainage ditch buckled upward, indicating either a large upward force from soil and hydrostatic water pressures or a large lateral force from lateral sliding of the containment wall.
  • The sloped sidewalls of the ditch were not directly connected to the containment wall, with a gap between the top of the slab and the containment wall of at least 2-feet.
  • The sloped slabs were not sized or reinforced in any way that indicates they were intended to brace the containment wall.
  • The concrete lining to the drainage ditch may have been added after the construction of the containment wall, as aerial imagery suggests.
  • It is possible that the soil geometry outside the wall was changed, perhaps significantly.
  • The soils that are on the outside of the wall contribute greatly to ability of the wall to resist lateral pressures.
  • If water is introduced to poorly compacted backfill, it will more readily absorb into the soils.
  • As the soils become more saturated, they weaken.
  • This additional pressure can be greater than twice the design pressure, possibly overloading the wall or causing the drainage ditch concrete slabs to buckle upward.
  • Tension cracks can form in the soils allowing even more water into the backfill, further weakening the soil and further increasing the lateral pressure against the wall.
  • The poorly compacted zone settle over time, creating pockets for the water to collect and infiltrate, and the high volume of pore space will provide conduits for water to infiltrate.
  • This water will collect then move through the soils, picking up fine particles along the way creating tubes, referred to as “piping”.
  • These tubes act as open conduits for freely flowing water and can eventually erode the subsurface sufficiently to undermine the wall structure and bring hydrostatic pressures to bear.
  • It is most likely that less than optimum on-site soils were used as backfill.
  • CH soils are difficult to manage within a suitable moisture compaction range and, as they are highly plastic in nature, they often fail and deflect excessively under standard compaction effort.
  • It appears that it was difficult to achieve an adequate degree of backfill compaction at soil/structure interfaces, such as along the containment wall, water line, and light pole.
  • With potential for as much as 4-feet of fire suppression water retained in the containment wall for days, this possibly led to saturation of the soils and increased lateral earth pressures against the containment wall.
  • As the wall shifted outward, it further damaged the sloped slab.
  • Eventually, it appears that pieces of the slab were washed out of place by the final torrent of escaping liquid.
  • The overall drainage system is problematic in several ways.
  • Such drainage systems were not required to be designed for large-scale spills, and in this case resulted in the drains being inadequate to move liquids quickly from the area.
  • The inlets were positioned along the same pathway as the transverse piping and the general slope of the tank farm overall would have moved the liquid toward pipeline systems, particularly the transverse piping racks and the manifolds at the south side.
  • A “running fire” would expose other tanks and piping before entering the drainage system.
  • The movement of the fire toward the south, due to the drainage, prevented safe access to the fire system valves and foam connections located along that south wall.
  • The slope likely also contributed to some of the initial tank exposures and can explain some of the fire progression.
  • Burning liquids that were on the ground during the initial and subsequent releases would have followed the slopes toward the inlets to the east of Tank 80-8 and the general slope moving south toward Tanks 80-9 and 80-12.
  • The southward movement would have continued as the drainage piping became overwhelmed, partially explaining the greater range of fire spread and damage on the south side of the tank farm than at the northern section.
  • Fire water system pressure being less than necessary to support use of monitor nozzles in the early stages of the fire.
  • The monitor nozzles initially activated by those first on-scene were not designed to reach the area of the Tank 80-8 piping manifold.
  • The units adjacent to Tank 80-8 that were designed to reach the tank’s piping manifold had become unusable due to the fire exposure, which damaged the monitor nozzles, and thermal exposure concerns to responders.
  • Attempts to use the monitor nozzles further away from the fire area resulted in water streams not reaching the area, since the available pressure at the utilized nozzles was not high enough to support the reach.
  • The inability to deploy foam fire suppression to the tanks was hindered over the duration of the fire due to safety concerns associated with response to the south side of the containment area.
  • There was a concern that the tank had been filled to near capacity and the potential for subsequently overfilling the tank by applying foam.
  • The tank farm is only accessible at points on the north and south, with the latter having been quickly compromised and eliminated as access for the majority of the response.
  • The same is true for access to installed fire protection connections at the south.
  • The ability to place apparatus outside the containment area is also problematic.
  • On the north side of the tank farm, between the north containment wall and Tidal Road, is a ditch that disallows apparatus from being set any closer than the south side of Tidal Road.
  • That would necessitate foam streams to reach nearly 300 ft before being effective on the fire.
  • On the east side, the plant road just to the east of the tank farm was the extraction point for those resources inside the containment area, and therefore could not be used until later in the fire.
  • On the west side, pipe racks and electrical equipment would have pushed resources to the west to allow for beneficial foam stream arcs.
  • To achieve lower-angle arcs, apparatus would have had to set up closer to the railroad siding at the west side, putting the distance to fire at about 350 ft.
  • The same condition exists at the south and would be problematic even if the location wasn’t compromised by fire at that point.
  • The configuration of the tank farms, and the operations therein and at the perimeter, had obviously changed from original construction to the time of the event.
  • The impacts of expanding pipe racks, adding piping and pumps and changing access necessarily adapted response planning over time.
  • The training developed by these organizations for tank farms may not have incorporated the various weather-related, slope/drainage and apparatus placement issues described herein.
  • The uncertainty in the radiative path length could result in the baseline model predictions under predicting the thermal exposure by a factor of 2.
  • The size and number of pressure release vents had a more significant impact on the predicted thermal exposure than the wind speed.
  • The addition of the pool fire significantly changed the profile of the thermal exposure.
  • The combined impact of the pool and vent fires significantly raised the radiant exposure to adjoining tanks.
  • the absence of a flammable gas detection system to alert the operators to the flammable mixture before it ignited approximately 30 minutes after the release began
  • the absence of remotely operated emergency isolation valves (ROEIVs) to safely secure the flammable liquids in Tank 80-8 and the surrounding tanks in the First and Second 80’s tank farm
  • elements of the tank farm design, including tank spacing, subdivisions, engineering controls for pumps located inside the containment area, and drainage systems
  • the resulting accumulation of hydrocarbon and petrochemical products, firefighting foam, and contaminated water in the secondary containment area
  • the breach of the containment wall and a release of materials to the local waterways
  • the atmospheric storage tank exemption contained in the OSHA PSM standard
  • the flammability exemption contained in the EPA RMP rule
  • ITC was unable to isolate or stop the release of naphtha product from the tank.
  • The tank farm was not equipped with a fixed gas detection system, so no alarms were activated to warn ITC personnel of a release.
  • The reduction in tank level and volume that occurred as naphtha product released from Tank 80-8 did not trigger any alarms in the ITC control room.
  • ITC did not equip the Tank 80-8 piping manifold with emergency or remotely operated isolation valves.
  • Under a major fire scenario resulting from a leak near this equipment, neither ITC operators nor emergency responders could access the area to close these manually operated valves.
  • Wind changes caused the fire to continue to spread.
  • Due to the extreme demand, a temporary reduction in water pressure was experienced.

Organizational and Systemic Factors

  • Limited documentation was available on the construction on the tank farm.
  • No design or as-built drawings were made available for review.
  • Atlas Engineering was not able to take destructive samples of the containment wall concrete during fieldwork.
  • Atlas Engineering was unable to perform excavation of the wall base during the site visit.
  • Excavation on the exterior side of the containment wall was not possible due to the presence of active pipelines in the area.
  • It is not clear that an emergency response organization was in place or, if one was in place, that they were an integral part of the design of the facility as intended by API RP 2021.
  • It would seem unlikely that API RP 2021 was implemented as part of the design effort for the “First and Second 80’s” tank farm.
  • Based on available information, PSM analysis of the tank farm had not yet been performed by the time of the fire.
  • Management of change and pre-startup safety review was performed under the broader ITC safety structure.
  • OSHA cited ITC Deer Park for violation of the Process Safety Management Standard (29 CFR 1910.119), confirming the applicability of PSM to Tank 80-8, as a minimum.
  • The 2015 assessment mentions the tank farm only in context of maximum foreseeable losses.
  • The 2017 report assumes any given tank farm to be completely lost, obviating any discussion on effectiveness of installed systems or emergency responders.
  • The 2018 survey provides significantly more detail about the various systems and the emergency response team, but the information does not link the various aspects of fire protection and assumes a maximum loss of a tank farm.
  • There appears to be a gap between the risk-management needs of owners and/or operators of tank farms and the design and management standards available.
  • Fire systems are often not given the same level of attention as other process safety systems.
  • The lack of prescriptive requirements for these aspects of tank farm fire protection often make it difficult for those unfamiliar with the balance of risks to determine how well a facility might be protected or how impactive a feature, or lack thereof, might be to an emergency situation.
  • The decision to not deploy the foam suppression system on Tank 80-8 during the early fire stage was made due to a combination of concerns, primarily based on fire and smoke conditions at the southern perimeter.
  • There was a concern that the tank had been filled to near capacity and the potential for subsequently overfilling the tank by applying foam.
  • No contract was in place at the time of the incident with US Fire Pumps.
  • No contract or relationship beyond the local mutual aid agreements noted previously was in place, based on the available information.
  • The resulting administrative delays and gathering of resources by US Fire Pumps hindered quickly bringing those resources to bear.
  • ITC did not have a formal mechanical integrity procedure in place that defined requirements for maintaining the mechanical integrity of Tank 80-8 and its associated equipment, including the Tank 80-8 circulation pump.
  • ITC did not implement the 2014 hazard review team recommendation for flammable gas detection systems near Tank 80-8 and did not document why it was not implemented.
  • ITC did not apply a formal process safety management program to Tank 80-8 because neither the OSHA PSM standard nor the EPA RMP rule applied to Tank 80-8 and its associated equipment.
  • ITC did not have a written pump rebuild or replacement procedure in place that referenced the pump manufacturer’s recommended instructions to ensure a proper installation of the Tank 80-8 circulation pump when it was rebuilt in December 2018.
  • ITC did not provide maintenance personnel with formal, documented training related to pump maintenance and repair work and did not have a formal program in place to assess their competency.
  • ITC did not have a formal Preventative Maintenance (PM) program in place for the Tank 80-8 circulation pump that included routine maintenance and inspection activities recommended by the pump manufacturer.
  • ITC did not have a quality assurance program in place at the ITC Deer Park terminal to allow it to confirm the origin of replacement parts used in the rebuild of the failed Tank 80-8 circulation pump.
  • ITC did not have a vibration monitoring practice or program in place for the pump at the time of the incident aside from biweekly maintenance walkthroughs.
  • ITC did not schedule installation of a flammable gas detection system in the vicinity of the Tank 80-8 piping manifold prior to the incident.
  • ITC did not equip the First and Second 80’s tank farm storage tanks with ROEIVs configured to automatically close in the event of a power outage, fire, or other event.
  • ITC did not equip the First and Second 80’s tank farm with subdivisions as required by NFPA 30.
  • ITC did not have a formal process safety management program for all atmospheric storage tanks and associated equipment in highly hazardous chemical service.
  • The ITC Deer Park terminal’s management systems lacked essential mechanical integrity program items, such as maintenance procedures, training for pump replacements and rebuilds, and routine preventative maintenance activities, for equipment in highly hazardous chemical service that was not covered by OSHA PSM or EPA RMP requirements.
  • ITC did not retrofit the Tank 80-8 circulation pump with vibration monitoring equipment.
  • ITC did not apply other key elements of a comprehensive process safety management system to atmospheric storage tanks in highly hazardous chemical service, such as Tank 80-8.
  • ITC did not develop and implement a formal PSM program for Tank 80-8 and its associated equipment because of the atmospheric storage tank exemption contained in the OSHA PSM standard and the flammability exemption contained in the EPA RMP rule.

Failed Safeguards or Barrier Breakdowns

  • The containment wall contained waterstop detailing in an effort to maintain a water-tight wall, but the waterstop was torn at multiple construction joints.
  • The wall remained straight and continuous between construction joints, but the wall shifted laterally.
  • The sloped sidewalls of the ditch were not directly connected to the containment wall.
  • The sloped slabs of the drainage ditch do not appear to have been designed to buttress the containment wall.
  • The welded-wire reinforcement did not span across the construction joints.
  • GPR was not able to identify if any dowels existed between the horizontal concrete slab serving as the footing and the vertical concrete wall forming the containment wall.
  • No standing water was seen in the footing, indicating the natural groundwater level was below the base of the footing.
  • The monitor nozzles initially activated by those first on-scene were not designed to reach the area of the Tank 80-8 piping manifold.
  • The units adjacent to Tank 80-8 that were designed to reach the tank’s piping manifold had become unusable due to the fire exposure, which damaged the monitor nozzles, and thermal exposure concerns to responders.
  • Attempts to use the monitor nozzles further away from the fire area resulted in water streams not reaching the area.
  • The tank foam suppression systems are all manually supplied (no connected water supply).
  • The inability to access the foam supply location augmented other considerations about tank fill height on Tank 80-8 specifically in not operating the tank foam system early in the response.
  • The drainage system was inadequate to move liquids quickly from the area.
  • The drainage piping became overwhelmed.
  • The fire system valves and foam connections located along the south wall were not safely accessible.
  • The fire water system pressure was less than necessary to support use of monitor nozzles in the early stages of the fire.
  • The monitor nozzles on the north side were noted to be ineffective by responders, due to low water supply pressure.
  • The installed monitors east of Tank 80-8 were damaged due to proximity of the fire.
  • Useful monitors at the south perimeter of the tank farm were exposed to smoke and direct flame, making them unsafe to use.
  • The fire and ground fire spread northward, forcing resources established within the containment area to pull back or to be abandoned.
  • The mechanical seal on the pump failed on March 17, 2019, allowing butane-enriched naphtha product to release from the pump while it continued to operate.
  • The First and Second 80’s tank farm was not equipped with a flammable gas detection system.
  • The First and Second 80’s tank farm was not equipped with remotely operated emergency isolation valves (ROEIVs).
  • The fixed fire monitor that was designed to reach Tank 80-8 was engulfed in flames and could not be accessed or activated.
  • The positions of other fixed fire monitors inside the tank farm did not allow for them to be aimed directly at the fire engulfing the Tank 80-8 piping manifold.
  • The fixed foam system on Tank 80-8 was not activated.
  • The stormwater drain system in the tank farm was unable to quickly remove the quantity of released materials and firewater from the containment area.
  • The containment wall surrounding the First and Second 80’s tank farm partially collapsed.
  • The Tank 80-8 circulation pump was not equipped with a condition monitoring system capable of detecting excess vibration in the equipment.
  • There was no vibration monitoring system installed on the Tank 80-8 circulation pump.
  • The CCR operator did not identify the ongoing reduction in tank volume and took no measures to secure the butane-enriched naphtha product release.
  • maintenance procedures
  • training for pump replacements and rebuilds
  • routine preventative maintenance activities
  • vibration monitoring equipment
  • flammable gas detection system
  • remotely operated emergency isolation valves (ROEIVs)
  • tank spacing
  • subdivisions between tanks
  • engineering controls for pumps located inside the containment area
  • drainage systems
  • containment wall design
  • OSHA PSM standard coverage for Tank 80-8
  • EPA RMP rule coverage for Tank 80-8

Recommendations

  1. Recommendation 1
  2. Recipient: Not specified
  3. Status: Not specified

  4. Summary: Classify containment structures and drainage structures as systems critical to fire safety and emergency response.

  5. Recommendation 2

  6. Recipient: Not specified
  7. Status: Not specified

  8. Summary: Preserve design and as-built documentation for containment structures, including site grading plans. Make this documentation accessible for future review. Include containment structures as a system to be reviewed when conditions change at the site.

  9. Recommendation 3

  10. Recipient: Not specified
  11. Status: Not specified

  12. Summary: Assess the impacts of adjacent construction, both inside and outside the containment area, to the strength and stability of containment structures. When containment structures are close to a property line, review how changes to adjacent property may affect support conditions of the containment structure.

  13. Recommendation 4

  14. Recipient: Not specified
  15. Status: Not specified

  16. Summary: Design containment walls for fully saturated soils on both sides of the wall. Design for maximum hydrostatic head on the interior of the containment wall assuming all soils are saturated.

  17. Recommendation 5

  18. Recipient: Not specified
  19. Status: Not specified

  20. Summary: Incorporate water stop features to develop full continuity of systems. Pay special attention to terminations or transitions between systems, such as where footing-to-wall joints meet wall construction joints.

  21. Recommendation 6

  22. Recipient: Not specified
  23. Status: Not specified

  24. Summary: Provide robust structural continuity across construction joints, particularly shear and tension continuity.

  25. Recommendation 7

  26. Recipient: Not specified
  27. Status: Not specified

  28. Summary: Ensure adequate compaction of suitable backfill to the structures edge with careful construction technique. Verify acceptable compaction by inspection of compaction results. Ensure adequate compaction of excavations for ancillary items located in proximity to containment structures. If achieving adequate compaction is not practical, other methods such as placement of flowable fill for backfill, pressure grouting along the soil/structure interface, or installation of HDPE membranes lapped below the backfill then up along the soil/structure interface should be considered to reduce the potential for subsurface erosion.

  29. Recommendation 2019-01-I-TX-R1

  30. Recipient: Intercontinental Terminals Company
  31. Status: Closed – Acceptable Action

  32. Summary: Develop and implement a process safety management system for the ITC Deer Park terminal applicable to all atmospheric storage tanks and associated equipment in highly hazardous chemical service. The program should follow industry guidance provided in publications such as the American Petroleum Industry’s API STD 2610, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities and the Center for Chemical Process Safety’s Guidelines for Risk Based Process Safety.

  33. Recommendation 2019-01-I-TX-R2

  34. Recipient: Intercontinental Terminals Company, LLC
  35. Status: Open – Acceptable Response or Alternate Response

  36. Summary: Develop and implement a condition monitoring program for all pumps in highly hazardous chemical service at the ITC Deer Park terminal. Ensure that condition monitoring equipment is programmed with control limits, including but not limited to vibration, consistent with ANSI/HI 9.6.9.-2018, that trigger alarms when control limits are exceeded, and that operating procedures and training reflect the appropriate actions to take when an alarm is triggered.

  37. Recommendation 2019-01-I-TX-R3

  38. Recipient: Intercontinental Terminals Company
  39. Status: Closed – Acceptable Action

  40. Summary: Install flammable gas detection systems with associated alarm functions in product storage and transfer areas at the ITC Deer Park terminal where flammable substance releases could occur. Develop and implement a response plan and operator training for actions to take when an alarm sounds.

  41. Recommendation 2019-01-I-TX-R4

  42. Recipient: Intercontinental Terminals Company, LLC
  43. Status: Open – Acceptable Response or Alternate Response

  44. Summary: Install remotely operated emergency isolation valves configured to “Fail-Closed” for all atmospheric storage tanks that contain highly hazardous chemicals or liquids with a flammability rating of NFPA-3 or higher at the ITC Deer Park terminal.

  45. Recommendation 2019-01-I-TX-R5

  46. Recipient: Intercontinental Terminals Company, LLC
  47. Status: Open – Acceptable Response or Alternate Response

  48. Summary: Conduct an evaluation of the design of all new and existing tank farms at the ITC Deer Park terminal against the applicable sections of the Third Edition of API STD 2610 and the 2021 Edition of NFPA 30. The evaluation should identify additional engineering controls needed to address minimal tank spacing, subdivisions between tanks, placement of process equipment in containment areas, and the adequacy of the containment wall and drainage system designs, accounting for the impact of firefighting activities, including the application of firewater and foam on these systems. Develop and implement recommendations based on findings from the evaluation.

  49. Recommendation 2019-01-I-TX-R6

  50. Recipient: American Petroleum Institute (API)**
  51. Status: Open – Acceptable Response or Alternate Response

  52. Summary: Update API STD 2610, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities, or other appropriate products to include flammable gas detection systems within the leak detection section or where appropriate. The discussion of flammable gas and/or leak detection should address both engineering and administrative controls, including actions associated with responding to a catastrophic or emergency leak.

  53. Recommendation 2019-01-I-TX-R7

  54. Recipient: Occupational Safety and Health Administration (OSHA)
  55. Status: Open – Awaiting Response or Evaluation/Approval of Response

  56. Summary: Eliminate the atmospheric storage tank exemption from the PSM standard.

  57. Recommendation 2019-01-I-TX-R8

  58. Recipient: Environmental Protection Agency (EPA)
  59. Status: Open – Awaiting Response or Evaluation/Approval of Response
  60. Summary: Modify 40 C.F.R. §68.115(b)(2)(i) to expand coverage of the RMP rule to include all flammable liquids, including mixtures, with a flammability rating of NFPA-3 or higher.

Key Engineering Lessons

  • Containment structures and drainage structures should be treated as systems critical to fire safety and emergency response.
  • Containment walls should be designed for fully saturated soils on both sides and for maximum hydrostatic head on the interior of the containment wall assuming all soils are saturated.
  • Water stop features should provide full continuity at terminations and transitions, especially where footing-to-wall joints meet wall construction joints.
  • Robust structural continuity across construction joints is needed, particularly shear and tension continuity.
  • Adequate compaction of suitable backfill to the structure edge is important; if adequate compaction is not practical, flowable fill, pressure grouting, or HDPE membranes should be considered to reduce subsurface erosion.
  • Tank farm design should account for the impact of firefighting activities, including the application of firewater and foam, on containment walls and drainage systems.
  • Flammable gas detection systems with alarm functions are needed in product storage and transfer areas where flammable substance releases could occur.
  • Remotely operated emergency isolation valves configured to fail closed are needed for atmospheric storage tanks containing highly hazardous chemicals or flammable liquids.
  • Condition monitoring programs for pumps in highly hazardous chemical service should include control limits, including vibration, and trigger alarms with defined operator actions.
  • Tank farm design reviews should address minimal tank spacing, subdivisions between tanks, placement of process equipment in containment areas, and adequacy of drainage and containment wall designs.

Source Notes

  • Priority 1 final report findings were used to resolve conflicts over direct cause, consequences, and engineering lessons.
  • The final report appendix on containment wall failure identified the wall displacement as a structural failure driven by excessive lateral soil and hydrostatic pressures and inadequate soil resistance/sliding resistance.
  • The final report on the incident identified the direct cause as release of flammable butane-enriched naphtha vapor from the failed Tank 80-8 circulation pump, which accumulated and ignited.
  • Priority 2 and 3 recommendation status summaries were used to capture official recommendation IDs, recipients, and current statuses.
  • Supporting documents were used only to supplement event chronology and facility context where consistent with higher-priority sources.

Similar Incidents

Incidents sharing the same equipment, root causes, or hazard types.

Same Equipment

Same Root Cause

Same Hazard

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