Massive Multi-Tank Farm Fire
Intercontinental Terminals Company (ITC) Massive Tank Farm Fire
Intercontinental Terminals Company LLC
📍 Deer Park, TX
Incident: March 17, 2019  •  CSB Report: July 6, 2023
0
Fatalities
0
Injuries
Naphtha and Other Flammable Liquids
Chemical Involved
📋 Incident Summary

On March 17, 2019, a catastrophic tank farm fire erupted at the Intercontinental Terminals Company (ITC) facility in Deer Park, Texas. A pump seal failure on a naphtha storage tank released flammable liquid that ignited, and the fire spread to adjacent tanks — ultimately burning seven tanks over approximately 10 days. The fire produced massive toxic smoke plumes affecting the Houston Ship Channel area, triggered shelter-in-place orders, and caused significant environmental damage. No worker fatalities or injuries were reported, but the community impact was severe.

The CSB determined that ITC had no formal process safety management system for its atmospheric storage tanks (which are exempt from OSHA PSM), no flammable gas detection, no remotely operated emergency isolation valves, and inadequate pump condition monitoring. Tank spacing, containment design, and firefighting infrastructure were all found to be deficient.

🔎 Key Findings
Finding 01
No PSM for Atmospheric Storage Tanks
Atmospheric storage tanks are exempt from OSHA PSM coverage — ITC had no formal PSM program for its terminal operations, representing a major regulatory gap.
Finding 02
No Flammable Gas Detection
No fixed flammable gas detection system existed to provide early warning of a pump seal leak before ignition.
Finding 03
No Remotely Operated Isolation Valves (ROEIVs)
Tank inlet and outlet valves could not be remotely closed during an emergency, preventing rapid isolation of burning and adjacent tanks.
Finding 04
Inadequate Pump Condition Monitoring
No vibration monitoring or condition-based maintenance program existed for pumps in flammable chemical service; the failing seal went undetected.
Finding 05
Insufficient Tank Spacing and Containment
Adjacent tank spacing did not meet API STD 2610 requirements; containment walls failed to contain burning liquid during firefighting, allowing fire spread.
Finding 06
Flammable Liquids Outside RMP Coverage
Naphtha (NFPA flammability rating 3) was not covered under EPA's Risk Management Program, leaving additional regulatory protections unavailable.
🔍 Root Causes
1
Regulatory Exemption for Atmospheric Storage Tanks
OSHA's PSM standard explicitly exempts atmospheric storage tanks, allowing terminal operators to store millions of gallons of flammable liquids without formal PSM requirements.
2
Absence of Early Detection and Isolation Safeguards
Without flammable gas detection or remote isolation valves, a small pump seal failure could not be identified and contained before it escalated into a major fire.
3
Inadequate Terminal Design vs. API Standards
The terminal's tank spacing, containment, and fire protection infrastructure did not conform to current API STD 2610 or NFPA 30 requirements.
4
No Condition Monitoring Program
No systematic mechanical integrity program for rotating equipment in flammable chemical service meant the pump seal deterioration was not detected prior to failure.
☑ CSB Recommendations
→ OSHA
Eliminate the atmospheric storage tank exemption from the PSM standard.
→ EPA
Modify the RMP rule to expand coverage to all flammable liquids with an NFPA flammability rating of 3 or higher, including naphtha.
→ ITC
Develop a PSM system for all atmospheric storage tanks following API STD 2610 and CCPS Guidelines for Risk Based Process Safety.
→ ITC
Install flammable gas detection systems, ROEIVs, and a pump condition monitoring program with vibration alarms for all pumps in flammable service.
→ ITC
Evaluate tank farm design against API STD 2610 and NFPA 30; remediate tank spacing, containment wall, and fire protection deficiencies.
→ API
Update API STD 2610 to include requirements for flammable gas detection systems in terminal and tank facilities.
💡 Lessons Learned
The OSHA PSM atmospheric storage tank exemption is a significant safety gap — terminals storing millions of gallons of flammable liquids often have no PSM requirements.
Fixed flammable gas detection with alarm systems is essential at tank terminals — early detection of a pump leak can prevent escalation to a major fire.
Remotely operated emergency isolation valves on storage tank lines allow rapid containment of a release without endangering responders.
Pump condition monitoring (vibration analysis) detects bearing and seal degradation before catastrophic failure — it is a fundamental mechanical integrity tool.
Tank spacing, containment volume, and fire suppression design must account for firefighting water volumes and foam application, not just the stored product volume.
PSM Element: Process Safety Culture & Continuous Improvement
🔨 Safety Meeting Toolbox Talk
▸Have we applied PSM principles (PHA, MI, MOC, emergency planning) to our atmospheric storage tank operations, even though they may be exempt from OSHA PSM?
▸Is fixed flammable gas detection installed around all pumps and transfer areas handling NFPA-3 or NFPA-4 flammability materials?
▸Are remotely operated emergency isolation valves installed on all storage tanks containing highly flammable materials?
▸Do we have a vibration-based condition monitoring program for all pumps in flammable liquid service?
▸Does our containment dike design account for firefighting water volumes, foam application, and containment wall integrity during fire conditions?
Immediate Action Items
✓Conduct a process hazard analysis (PHA) for all atmospheric storage tank operations regardless of PSM regulatory exemption
✓Install fixed LEL gas detectors with audible alarms at all pump areas and transfer stations
✓Install remotely operable isolation valves on all storage tanks containing flammable chemicals
✓Implement vibration monitoring program for all rotating equipment in flammable liquid service
✓Evaluate tank farm layout against API STD 2610 and NFPA 30 — remediate spacing and containment deficiencies
🔗 PSM Failures Behind This Incident

This incident traced to breakdowns across 1 PSM element (PHA). Each represents a documented gap that process safety documentation and consulting can close before a similar event occurs at your facility.

Process Hazard Analysis (PHA)
A structured PHA or HAZOP study exists to identify exactly these scenarios before they occur. When PHA is absent, superficial, or overdue for revalidation, hazards operate unseen until they kill someone.
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