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Safety and environmental standards for fuel storage sites

Health and Safety ExecutiveSafety and environmental standards for fuel storage sitesProcess Safety Leadership Group Final reportHealth and Safety ExecutiveHSE BooksSafety and environmental standards for fuel storage sitesProcess Safety Leadership Group Final report Crown copyright 2009 First published 2009 ISBN 978 0 7176 6386 6 All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmittedin any form or by any means (electronic, mechanical, photocopying, recording or otherwise) without the prior written permission of the copyright for reproduction should be made in writing to: The Office of Public Sector Information, Information Policy Team, Kew, Richmond, Surrey TW9 4DU or e-mail: and environmental standards for fuel storage sitesFinal report4 Safety and environmental standards for fuel storage sitesFinal report5 Foreword 7 Introduction 9 Scope and application 11 Summary of actions required 14 Part 1 Systematic assessment of Safety integrity level requirements 22 Part 2 Protecting against loss of primary containment using high integri

Safety and environmental standards for fuel storage sites Final report 7 The recent Texas City and Buncefield incidents have moved industry and regulators beyond the

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1 Health and Safety ExecutiveSafety and environmental standards for fuel storage sitesProcess Safety Leadership Group Final reportHealth and Safety ExecutiveHSE BooksSafety and environmental standards for fuel storage sitesProcess Safety Leadership Group Final report Crown copyright 2009 First published 2009 ISBN 978 0 7176 6386 6 All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmittedin any form or by any means (electronic, mechanical, photocopying, recording or otherwise) without the prior written permission of the copyright for reproduction should be made in writing to: The Office of Public Sector Information, Information Policy Team, Kew, Richmond, Surrey TW9 4DU or e-mail: and environmental standards for fuel storage sitesFinal report4 Safety and environmental standards for fuel storage sitesFinal report5 Foreword 7 Introduction 9 Scope and application 11 Summary of actions required 14 Part 1 Systematic assessment of Safety integrity level requirements 22 Part 2 Protecting against loss of primary containment using high integrity systems 25 Part 3 Engineering against escalation of loss of primary containment 37 Part 4 Engineering against loss of secondary and tertiary containment 42 Part 5 Operating with high reliability organisations 62 Part 6 Delivering high performance through culture and leadership 64 Conclusion 66 AppendicesAppendix 1 Mechanisms

2 And potential substances involved in vapour cloud formation 67 Appendix 2 Guidance on the application of layer of protection analysis (LOPA) to the overflow of an atmospheric storage tank 82 Appendix 3 Guidance on defining tank capacity 125 Appendix 4 Guidance on automatic overfill protection systems for bulk gasoline storage tanks 129 Appendix 5 Guidance for the management of operations and human factors 142 Appendix 6 Emergency planning guidance 197 Appendix 7 Principles of process Safety leadership 244 Appendix 8 Process Safety Forum: Governance and terms of reference 247 Appendix 9 BSTG report cross reference 249 Appendix 10 Acknowledgements 252 References 256 Abbreviations 264 Further information 267 ContentsSafety and environmental standards for fuel storage sitesFinal report6 Safety and environmental standards for fuel storage sitesFinal report7 The recent Texas City and Buncefield incidents have moved industry and regulators beyond the pure science and engineering responses to develop ways to prevent a recurrence.

3 They have caused us to also critically examine the leadership issues associated with delivering what has to be excellent operation and maintenance of high-hazard responses by industry and regulators to these incidents, and the recommendations arising from their investigations, are essential to ensuring they never happen again. Such responses need to be effective and measured, requiring a dialogue between industry and the community to determine the balance between risk prevention, the viability of the operations and their value to society. In this regard the regulators are the effective representatives and arbiters for formation of the Process Safety Leadership Group (PSLG) in September 2007 was designed to meet the need for an effective framework for interaction between industry, trade unions and the COMAH Competent Authority (CA); a framework in which they could carry out a dialogue to jointly develop, progress and implement meaningful, effective recommendations and practices that improve Safety in our membership consisted of senior representatives of the relevant trade associations, the CA and trade unions.

4 It built on the work of the Buncefield standards Task Group (BSTG), set up in 2006 to translate the lessons learned from that incident into effective and practical guidance that the industry could implement quickly. PSLG expanded the membership to include the Chemical Industries Association and also took on the task of progressing the implementation of the Buncefield Major Incident Investigation Board (MIIB) recommendations. PSLG also saw a need to raise the profile of process Safety leadership throughout the petrochemical and chemical industries in response to criticisms by both the Baker Panel (Texas City) and MIIB (Buncefield) that leadership in this area was lacking and a contributory factor to these events. PSLG has sought to continue the BSTG model of working through the trade associations to measure and encourage progress against the various recommendations.

5 In particular the use of work groups involving the regulator, industry and the trade unions has been key to developing effective, practical guidance and recommendations with buy-in from all involved. To support this work, PSLG developed its Principles of Process Safety Leadership, signed by the trade associations, CA and trade unions, which set out the commitment to the enhancement of process Safety . The trade associations will reflect the principles of process Safety through their own initiatives and actively share progress as programmes roll model of industry and the regulator working together on improving our capability to operate safely is, I am convinced, a very effective one. Taking the path chosen by BSTG and PSLG is not an easy option it requires trust from all parties and a willingness to voluntarily accept measures that require significant investment, both in financial and human terms.

6 The regulator will always, and should always, have the power to act independently to impose change aligned, but not joined was the phrase coined when BSTG set off. However, I am sure we will get better, faster, by jointly finding solutions rather than adopting a prescriptive approach. ForewordSafety and environmental standards for fuel storage sitesFinal report8 This report and its recommendations represent the outcome of a tremendous amount of work by the industry, trade unions and the regulator. I would like to thank them for all their efforts, tenacity and input. Our work can and will make a significant contribution to improving process Safety the challenge for all of us now is to deliver!Tony Traynor Chair Process Safety Leadership GroupSafety and environmental standards for fuel storage sitesFinal report91 The main purpose of this report is to specify the minimum standards of control which should be in place at all establishments storing large volumes of The PSLG also considered other substances capable of giving rise to a large flammable vapour cloud in the event of a loss of primary containment.

7 However, to ensure priority was given to improving standards of control to tanks storing gasoline PSLG has yet to determine the scale and application of this guidance to such substances. It is possible that a limited number of other substances (with specific physical properties and storage arrangements) will be addressed in the This report also provides guidance on good practice in relation to secondary and tertiary containment for facilities covered by the CA Control of Major Accident Hazards (COMAH) Containment 4 Parts of this guidance may also be relevant to other major hazard Taking forward improvements in industry, PSLG built on the developments of the original BSTG using a small, focused, oversight team to provide leadership and support to expert working groups in developing guidance on specific topics.

8 It was chaired by a senior member of industry and involved representatives from the United Kingdom Petroleum Industry Association (UKPIA), the Tank storage Association (TSA), the United Kingdom Onshore Pipeline Operators Association (UKOPA), the Chemical Industries Association (CIA), the Trades Union Congress, the Health and Safety Executive (HSE), the Environment Agency and the Scottish Environment Protection Agency (SEPA). PSLG led, developed and promoted improvements to Safety and environmental controls, in particular: demonstrating effective leadership within the sector; developing organisational and technical solutions; sharing and learning from incidents and good practice; driving forward research; monitoring compliance with the Buncefield MIIB s and BSTG s recommendations; making further recommendations where appropriate; and taking effective account of the findings of the exploration of the explosion mechanism.

9 6 This report reflects the original scope of BSTG, incorporating the detailed guidance provided by PSLG and its working groups. The report is structured into six parts, addressing all 25 of the recommendations included in the Buncefield MIIB Recommendations on the design and operation of fuel storage sites2 report:Part 1: Systematic assessment of Safety integrity level requirementsPart 2: Protecting against loss of primary containment using high integrity systemsPart 3: Engineering against escalation of loss of primary containmentPart 4: Engineering against loss of secondary and tertiary containmentPart 5: Operating with high reliability organisationsPart 6: Delivering high performance through culture and leadershipIntroductionSafety and environmental standards for fuel storage sitesFinal report107 This report supersedes and replaces the BSTG final report which was issued in July 2007.

10 A cross reference between the original BSTG report and this final PSLG report is provided in Appendix The structure of this report aligns with the framework of the Buncefield MIIB Design and operation report, ensuring a clear cross reference between individual recommendations and the detailed guidance which addresses each of these. Guidance to address a specific issue may be split across multiple MIIB recommendations, so the reader should consider the report as a whole when determining what actions should be taken. For example, when considering the need for additional overfill protection measures, the reader should:refer to Parts 1 and 2 and consider the appropriate hazard identification and risk assessment technique outlined in Appendix 5;where appropriate follow the guidance in Appendix 2 for the application of the layer of protection analysis (LOPA) technique; andwhere appropriate use the guidance provided in Appendix 4 to determine the architecture and nature of the protection system.


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