ITC Fire—What Went Wrong? 

Findings from a U.S. Chemical Safety and Hazard Investigation Board investigation determined that a storage tank containing naphtha and butane erupted and spread to 14 tanks located in the same containment area. An estimated 470,000 to 523,000 barrels of chemical products spilled into the Buffalo Bayou, the Houston Ship Channel, and other surrounding bodies of water. The devastation exceeded $150 million, a costly outcome for ITC owners. 

Various safety issues were determined by the board. The ITC facility lacked gas detection systems and emergency isolation valves, had an outdated tank farm design, and had no formal Process Safety Management (PSM) programs implemented. More notably, the investigation revealed that ITC failed to implement recommendations from OSHA (Occupational Health and Safety Administration), the National Fire Protection Association (NFPA), and the EPA (U.S. Environmental Protection Agency). While recommendations were provided, ITC was not required to develop processes to reduce fire events, in part due to an exception from an OSHA PSM standard and an EPA RMP rule. 

The ITC facility event demonstrates the need for facility owners susceptible to similar incidents to implement specialized recommendations to avoid costly outcomes. The key to this is prevention and a comprehensive examination of all fire protection systems, emergency response capabilities, and supporting resources to reduce the probability of catastrophic events. Tools such as the Fire Hazard and Mitigation Analysis (FHMA) methodology may assist. 

Addressing Facility Fire Events Head-On with FHMA 

BakerRisk’s FHMA methodology uses proprietary fire hazard and hydraulic modeling tools (FireHAT©, SafeSite3G©https://www.bakerrisk.com/services/fgtool/) to assess the consequences of fire scenarios and the reliability of fire protection systems, as well as emergency response capabilities to respond to fire events. 

An FHMA analysis is highly recommended to facility owners searching for long-term solutions to reduce fire events, as there are numerous benefits, which include: 

• Accurate Determination of Firewater Demands: Firewater demands needed to address possible fire incidents are calculated based on existing/proposed systems. The calculations can be used to validate or improve upon firewater demand estimate calculation methodologies from entities such as the American Petroleum Institute (API) and the Center for Chemical Processing (CCPS). 

• Consistent Process Safety Information and Documentation: Quantitative results can be used to document design-basis fire impacts, available firewater coverage, calculated firewater demands, etc. 

• Stakeholder Involvement and Interaction: A facilitated workshop is delivered to support facility personnel, including operations, safety personnel, support staff, and management, as well as emergency responders, to participate in the review of proposed recommendations for fire events. 

• Evergreen Model, Including Site Changes: FHMA directly links the results from existing consequence or Facility Siting Studies (FSSs) to fire protection coverage mapping, hydraulic modeling, response capabilities, and fireproofing evaluation tools, ensuring consistency between the studies. More notably, studies can be updated as conditions change as part of an evergreen revalidation protocol. 

One of the most consequential elements to consider before implementing an FHMA is understanding or having a working knowledge of a facility’s strengths, vulnerabilities, gaps, etc., regarding plausible fire events. Facility owners and operators should ask some of the following questions: 

• Do your fire protection systems align with applicable RAGAGEP, as well as corporate and site philosophy/intent? 

• Are there challenges to existing capabilities, such as obstacles that block coverage from fixed systems, access/egress challenges for mobile apparatus, or system degradation, and what actions do you need to take to overcome these challenges? 

• Is equipment performing as intended, or is inadequate design, age, wear, corrosion, or neglect preventing the system from performing as intended? 

• Is your system robust enough to allow for occasional, unplanned outages of key components, such as fire pumps and critical underground fire mains, without jeopardizing your ability to successfully suppress your design-case fires? 

While implementing recommendations may be a challenge for owners, mainly due to financial constraints and business interests, these recommendations are intended to safeguard stakeholders from the aftermath of a fire event, including public scrutiny and the legal challenges that are likely to arise. 

Conclusion 

BakerRisk’s FHMA methodology is aimed at providing comprehensive recommendations tailored to address concerns unique to facilities susceptible to major fire events with the potential to cause substantial operational, financial, and reputational harm. That is the BakerRisk difference. 

For more in-depth analysis into the FHMA methodology, request access to our FHMA Best Practices paper or contact our fire protection experts today.