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Safety and environmental standards for fuel storage sites

Buncefield Standards Task Group (BSTG) Final report

1 of 118 pagesSafety and environmental standards for fuel storage sites

Health and Safety

Executive


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Contents

Foreword

Introduction

Part 1: Action required to prevent a further incident – what must go right!

Systematic assessment of safety integrity level requirements

Control and safety systems for petroleum storage tanks

Incorporating the findings of SIL assessments into COMAH safety reports

Protecting against loss of primary containment using high-integrity systems

Management systems for maintenance of equipment and systems to ensure

their continuing integrity in operation

Tank overfill prevention: Defining tank capacity

Fire-safe shut-off valves Remotely operated shut-off valves (ROSOVs)

Testing overfill protection systems

Safe management of fuel transfer

Engineering against loss of secondary and tertiary containment

High reliability organisations

Roles, responsibilities and competence

Staffing and shift work arrangements

Shift handover

Organisational change and management of contractors

Performance evaluation and process safety measurement

Emergency arrangements

Principles On-site emergency plan

Firefighting planning and preparation

Part 2: Detailed guidance on standards for the transfer and storage of fuel

Systematic assessment of safety integrity level requirements

Control and safety systems for petroleum storage tanks

Incorporating the findings of SIL assessments into COMAH safety reports


Management systems for maintenance of equipment and systems to ensure

their continuing integrity in operation

High-integrity, automatic operating overfill prevention systems

Tank overfill prevention: Defining tank capacity

Fire-safe shut-off valves

Remotely operated shut-off valves (ROSOVs)

Testing overfill protection systems

Safe management of fuel transfer


Bund integrity (leak-tightness)

Fire-resistant bund joints

Bund capacity

Firewater management and control measures

Tertiary containment


Roles, responsibilities and competence

Staffing and shift work arrangements Shift handover

Organisational change and management of contractors

Performance evaluation and measuring process safety performance



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Emergency response arrangements

Principles

On-site emergency plan

Firefighting planning and preparation

Part 3: Work in progress on process standards


Maintenance of records


Bund floors (impermeability)

Fire-resistant bund joints

Bund capacity


Management of plant and process changes

Delivering high performance through culture and leadership

Long-term industry leadership

Leadership and process safety culture Process safety management

Hazard identification, layers of protection and assessment of their effectiveness

Emergency response arrangements

Part 4: Comparison of BSTG recommendations with the MIIB report on the

design and operation of fuel storage sites

Appendices

1: Example LOPA assessment for an overfill scenario

2: Defining tank capacity

3: Job factors for management of fuel transfer

4: Key requirements for operational planning 5: Process safety performance indicators

Glossary

References



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Foreword

How industry responds to incidents such as Buncefield and how the regulators

respond on behalf of the public is a measure of our society. A decisive and

dynamic response with all parties co-operating is the product of a democratic and

advanced society.

If there is a serious incident then everybody, including the public, the company

directly involved and any company in the same or similar sectors, suffers

consequences to a greater or lesser extent. It follows that all companies have a

vested interest in ensuring that these incidents do not occur. Stakeholders have a

right to expect compliance with a minimum set of standards and expectations from

everybody in a particular sector and compliance with a higher set of standards for

specific situations involving higher than normal risks.

Shortly after the Buncefield incident, the Buncefield Standards Task Group (BSTG)

was formed consisting of representatives from the Control of Major Accident

Hazards (COMAH) Competent Authority and industry, with the aim of translating

the lessons from Buncefield into effective and practical guidance that industry

would implement as rapidly as possible. This also facilitated a joined-up approach

to managing risk across the sector by providing an authoritative benchmark for

standards and practices. The intent was to ensure more consistent responses to

broadly similar risks. Existing guidance was reviewed and confirmed as industry

standards, with extra detail and examples added where necessary, while in other

cases new standards were created to close gaps. This report contains all of the

recommendations of BSTG including those previously released. A separate report

will detail the progress made in complying with the initial recommendations.

In parallel with the BSTG work, the Buncefield Major Incident Investigation Board

(MIIB) conducted an investigation into what happened at Buncefield. Information

from the MIIB’s reports and from safety alerts issued by the Competent Authority

was factored into BSTG work as appropriate. In addition, BSTG also considered all

the factors that need to go right to prevent such an incident, which helped define

further areas for action. In March 2007, the MIIB issued a report Recommendations

on the design and operation of fuel storage sites.1 It sets out 25 recommendations

to improve safety and environmental performance. Many of these had already been

fully addressed by the BSTG’s work, although others have only been partially

addressed or have yet to be addressed. This lack of an identical match is due to

the decision made at an early stage to balance the need for putting improvements

in place rapidly with the need to await the MIIB’s full recommendations. We believe

that BSTG made the right decision, with significant improvements already having

been achieved.

One of the guiding principles of BSTG has been that we would be judged on the

delivery of improvements, not simply on an intention to deliver. We have achieved

much already; however, we are not complacent and realise that much work

remains to be completed. Outstanding matters will be taken forward by the

Petrochemical Process Standards Leadership Group (PPSLG), which replaces

BSTG, whose working life ends with the publication of this report. PPSLG will also

oversee the monitoring of and reporting on compliance with all of their

recommendations, as well as those of BSTG.



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I believe that the way in which industry and regulator have come together to co-

create and deliver action to prevent a Buncefield-type incident is a model for the

future. PPSLG will continue the approach of industry and regulator being ‘aligned

but not joined’, whereby we are committed to delivering timely and appropriateagreed action through mutual challenge and understanding of our particular

perspectives. Delivery is an essential part of building trust upon which this

approach depends. Critically, success requires us to ‘say what we will do’ and ‘do

what we say’.

Please read this report and turn its recommendations into action. Doing so may

well prevent you and others from suffering the adverse consequences, whether to

people or the environment, of an incident.

Ken Rivers Chair

Buncefield Standards Task Group

24 July 2007



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Introduction

1 The purpose of this report is to specify the minimum expected standards of control which should be in place at all establishments storing large vo

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