The CSB issues safety recommendations to prevent the recurrence or reduce the likelihood or consequences of similar incidents or hazards in the future. Recommendations are issued to a variety of parties, including government entities, safety organizations, trade unions, trade associations, corporations, emergency response organizations, educational institutions, and public interest groups. Recommendations are published in CSB reports and are closed only by vote of the Board. The CSB tracks all recommendations and communicates regularly with recommendations recipients to ensure that the recommended corrective actions are implemented. For more information, see Frequently Asked Questions about CSB recommendations.
2019-01-I-TX-6
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. Status: Open - Awaiting Response or Evaluation/Approval of Response
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.
2019-01-I-TX-8
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. (Superseded 2010-02-I-PR-R1 from the Caribbean Petroleum (CAPECO) report) Status: Open - Awaiting Response or Evaluation/Approval of Response
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.
(Superseded 2010-02-I-PR-R1 from the Caribbean Petroleum (CAPECO) report)
2019-01-I-TX-1
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.a 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. Status: Open - Acceptable Response or Alternate Response
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.a 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.
2019-01-I-TX-2
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. Status: Open - Acceptable Response or Alternate Response
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.
2019-01-I-TX-3
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. Status: Open - Acceptable Response or Alternate Response
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.
2019-01-I-TX-4
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. Status: Open - Acceptable Response or Alternate Response
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.
2019-01-I-TX-5
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, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities and the 2021 Edition of NFPA 30, Flammable and Combustible Liquids Code. At a minimum the evaluation should include, but is not limited to the following sections of API STD 2610: Section 4 Site Selection and Spacing Requirements Section 7 Fire Prevention and Protection Section 8.1 Aboveground Petroleum Storage Tanks Section 9 Dikes and Berms Section 10 Pipe, Valves, Pumps, and Piping Systems Section 11 Loading, Unloading, and Product Transfer Facilities and the following chapters of NFPA 30: Chapter 21 Storage of Ignitible (Flammable or Combustible) Liquids in Tanks – Requirements for All Storage Tanks and Chapter 22 Storage of Ignitible (Flammable or Combustible) Liquids in Tanks – Aboveground Storage Tanks The evaluation should identify additional engineering controls needed to address minimal tank spacing, subdivisions between tanks, and placement of process equipment in containment areas. In addition, the evaluation should assess 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. Status: Open - Acceptable Response or Alternate Response
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, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities and the 2021 Edition of NFPA 30, Flammable and Combustible Liquids Code. At a minimum the evaluation should include, but is not limited to the following sections of API STD 2610:
Section 4 Site Selection and Spacing Requirements Section 7 Fire Prevention and Protection Section 8.1 Aboveground Petroleum Storage Tanks Section 9 Dikes and Berms Section 10 Pipe, Valves, Pumps, and Piping Systems Section 11 Loading, Unloading, and Product Transfer Facilities
and the following chapters of NFPA 30:
Chapter 21 Storage of Ignitible (Flammable or Combustible) Liquids in Tanks – Requirements for All Storage Tanks and Chapter 22 Storage of Ignitible (Flammable or Combustible) Liquids in Tanks – Aboveground Storage Tanks
The evaluation should identify additional engineering controls needed to address minimal tank spacing, subdivisions between tanks, and placement of process equipment in containment areas. In addition, the evaluation should assess 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.
2019-01-I-TX-7
Eliminate the atmospheric storage tank exemption from the PSM standard. (Superseded 2001-05-I-DE-R1 from the Motiva report and 2010-02-I-PR-R4 from the Caribbean Petroleum (CAPECO) report) Status: Open - Awaiting Response or Evaluation/Approval of Response
Eliminate the atmospheric storage tank exemption from the PSM standard.
(Superseded 2001-05-I-DE-R1 from the Motiva report and 2010-02-I-PR-R4 from the Caribbean Petroleum (CAPECO) report)