Incident Report

Subject:��������������� ��������Buncefield Joint Task group calls for immediate action ���

Date of Email:���Fri 13/10/2006 08:59

Report Detail:

A joint Industry and COMAH Competent Authority (CA) Task Group today called for industry to take immediate measures to implement eight key action points at major petroleum storage facilities. The actions to further improve safety and environmental standards can be found in the Buncefield Standards Task Group: Initial Report at: http://www.hse.gov.uk/comah/alert.htm also copied below

The actions, provide a significant challenge to industry, and are in response to findings contained in the Buncefield Major Incident Investigation Board’s (MIIB) initial report published in July. These recommendations, based on the latest information available, are believed to be precautionary and prudent to offer worthwhile additional public and environmental protection. The actions relate to:

• Pipeline transfers;
• Tank overfill prevention – operating safety margins and level alarms;
• Fire safe shut-off valves and remotely operated shut off valves;
• Containment – bunds and other measures; and
• Shift handover.

The CA are also reviewing the emerging outcomes from the safety and environmental reviews of fuel depots carried out by the Health and Safety Executive (HSE), Environment Agency (EA) and Scottish Environment Protection Agency (SEPA) earlier this year. The CA will report their findings later this year. These may well include the need for industry to take further measures.

The Task Group recommends and the CA requires sites that have bulk tanks storing petroleum that could be overfilled leading to a significant vapour cloud to take immediate action. These sites will now have to implement the recommendations by the deadlines set out in the report. Industry representatives have agreed to complete them and the CA will be monitoring industry progress closely to ensure the enhanced safety standards are introduced on time.

Under the CA’s direction, the Task Group set out to undertake a comprehensive and thorough review of facilities like Buncefield to ensure they operate correctly. The actions detailed above are the first results of this work. The Task Group will make final recommendations to industry aimed at enhancing safety and environmental standards by July 2007.

The CA acknowledges the commitment industry members of the Task Group have shown. It is important that these changes to further improve safety are implemented by the deadlines stated.

Notes to Editors

1. The Control of Major Accident Hazards (COMAH) Regulations 1999 are enforced by a joint Competent Authority: HSE and EA in England and Wales, and HSE and Scottish SEPA in Scotland.
2. The Petroleum Industries Association (UKPIA) represents the oil refining and marketing companies operating in the UK, which also own approximately 2,500 of the UK’s 9,764 service stations, and own and operate the nine crude processing oil refineries in the UK.
3. The Task Group was established in June 2006 and is made up of key industry trade association representatives as well as the Competent Authority, which is providing appropriate oversight and direction. The Task Group includes representation from members of: UKPIA; Tank Storage Association (TSA); Chemical Industries Association (CIA); HSE; EA; SEPA and Cogent Sector Skills Council. Ken Rivers, Shell UK Oil Manufacturing Director and former President of UKPIA, chairs the group.
4. The Major Incident Investigation Board’s Initial report, published on 13 July 2006, into the Buncefield fuel depot fire and explosion on 11 December 2005 can be found at: http://www.buncefieldinvestigation.gov.uk/reports/index.htm
5. HSE issued precautionary advice in February to operators of fuel storage sites following the publication of the first progress report to the Buncefield Major Incident Investigation Board on the joint investigation by HSE and the Environment Agency. HSE requested that operators with consent to store quantities of oil or other fuels that make them subject to the COMAH Regulations 1999, review their operations in the light of information obtained from the investigation at that point and report the outcomes of those reviews to HSE by Easter 2006. HSE inspectors also carried out inspections at these sites. Full details of the safety alert’s findings can be can be found on the HSE’s website at: www.hse.gov.uk/press/2006/e06019.htm
   

Buncefield Standards Task Group
Initial report - recommendations requiring immediate action

Introduction
1. Prior to the Buncefield incident, petroleum storage sites were generally not considered to be sites where an explosion incident on this scale could occur. Buncefield challenged this worldwide perception. The Control of Major Accident Hazards (COMAH) Competent Authority1 and Industry recognised that safety and environmental safeguards needed to reflect this new understanding even though they are extremely rare events. As a first step these strengthened safeguards are being put in place by industry to give added safety & environmental protection. The Regulators and Industry are working to identify and develop new solutions to set a new clearer and higher benchmark standard specific to large-scale petroleum storage. This will provide a significant challenge to industry and the UK fuel supply system.

2. Hence, a ‘COMAH Competent Authority/Industry Standards Task Group2’ was set up, first formally meeting on 14 June 2006, where over 50 people from industry with regulators from HSE, EA and SEPA agreed to undertake a comprehensive and thorough consideration of everything that needs to go right at fuel/oil storage facilities to ensure their safe operation.

3. This report presents the initial recommendations for immediate action from the Task Group responding to, firstly, recommendations in the Buncefield Major Incident Investigation Board reports3 and secondly, areas of concern identified in the safety and environmental reviews of fuel and oil storage sites4 conducted by industry and the regulators in spring 2006.

4. On 22 September 2006, Industry committed to implementing the recommendations in this report. By the end of July 2007, the Task Group, with a strong level of industry support, will make its final recommendations to further enhance safety and environmental Standards so as to improve safety and prevent another Buncefield-type incident.

5. These recommendations are based upon the best knowledge currently available, however this may change and so may lead to further advice. They are believed to be precautionary and prudent to provide worthwhile additional public protection.

Controlling risks at major petroleum storage sites
6. The Buncefield incident involved the overfilling of a large storage tank with petrol supplied through a pipeline. As the petrol flowed over the topside of the tank it formed a large vapour cloud that subsequently ignited. To prevent a similar incident, high standards of control should be in place applying to the storage of petrol on COMAH sites, as defined by the application criteria in Annex 1.

Immediate actions
Pipeline transfers
7. The safe management of product transfer will be improved by receiving site operators positively confirming that they can safely receive the product package before transfer starts and are able to initiate emergency shutdown if necessary. This will be achieved through the use of a standardised consignment transfer agreement. [For completion by January 2007].

Tank overfill prevention
8. Tank-operating practices, staffing levels and systems, must provide effective safety margins to prevent a release5. [For completion by January 2007].

9. The overall systems for tank-filling control must be of high integrity – with sufficient independence to ensure timely and safe shutdown to prevent tank overflow. Site operators should meet the latest international standards6. [For completion by June 2007].

Valves
10. Fire Safe Shut-Off Valves must be fitted close to the tank on both inlet and outlet pipes. These valves should conform to an appropriate fire safe standard7 or be intrinsically fire-safe8. [For completion by April 2007 ].

11. Remotely Operated Shut Off-Valves (ROSOVs) for the emergency isolation of hazardous substances should fail safe9. [For completion by June 2007].

Containment measures
12. Joints in bunds must be capable of resisting fire. Existing bunds should be modified to meet this requirement. [For completion by May 2007].

13. Tertiary containment measures must be capable of preventing the uncontrolled escape of firewater and other products to the environment10. [Site action plans to achieve this should be drawn up by January 2007 - to inform the production of further guidance by June 2007].

Shift handover
14. Effective shift/crew handover communication arrangements must be in place to ensure the safe continuation of operations11. [For completion by January 2007].

Action already taken by the COMAH competent authority
15. Firstly, the Competent Authority issued a safety alert in February 2006 requiring operators of COMAH fuel and oil storage sites to undertake a review of the safety of their operations to ensure that they were maintaining the highest level of plant integrity and operational capability. All sites were contacted by regulators. Initial findings of this review were published in June 2006. This also focused operator vigilance on ensuring that critical control systems continue to function to a high standard. The results of the further analysis of these surveys will be published with the appropriate follow-up action to be undertaken by the Competent Authority commencing in November 2006.

16. Secondly, a safety alert was issued in July 200612 on the testing of tank high-level switches to ensure that this was correctly carried out. Importantly, this was to make sure these switches are left in a fully working order following testing. Industry has advised the COMAH Competent Authority that necessary modifications have been carried out to prevent the switches from being left in a non-operating, dangerous, position following testing and maintenance.

The task group and its work
17. The Task Group comprises of representatives from the Competent Authority - Health and Safety Executive, Environment Agency, Scottish Environment Protection Agency, and industry.

18. Strong, senior and wide-ranging industry support includes - UK Petroleum Industry Association (UKPIA), Tank Storage Association (TSA), UK Onshore Pipeline Operators’ Association (UKOPA), Trades Union Congress (TUC) and the Chemical Industries Association (CIA).

19. There are over 40 people from industry on working groups considering:

1. Definition of sites to which the safety standards will apply.
2. Management of operations.
3. Design and maintenance of plant and equipment.
4. Design and maintenance of control and safety systems.
5. On-site emergency response arrangements.
6. Bunding and other containment.

Annex 1: Types of installation to which the task group’s recommendations will apply
Petrol stored at COMAH top and lower tier sites13 in vertical, cylindrical, non-refrigerated, above ground storage tanks14 with side walls greater than 5 metres in height15 and where the filling rate is greater than 100 cubic metres/hour.

These criteria are based upon the best knowledge currently available, however this knowledge may be improved and so lead to future changes in the application scope. The criteria are believed to be precautionary, so providing worthwhile additional public protection. Further work continues to identify the characteristics of other substances that may have potential to act in a similar manner.

Footnotes and references:

1. HSE, the Environment Agency and the Scottish Environment Protection Agency acting jointly to enforce the Control of Major Accident Hazard Regulations 1999 (COMAH).
2. HSE Press release http://www.hse.gov.uk/press/2006/e06067.htm
3. The MIIB’s Initial Report and three progress reports (http://www.buncefieldinvestigation.gov.uk/reports/index.htm)
4. Initial Report on the findings of the Oil/Fuel Depot Safety Alert Review http://www.hse.gov.uk/comah/buncefield/review.htm
5. Overfill Protection for Storage Tanks in Petroleum Facilities: API Recommended Practice 2350, Third Edition, January 2005. American Petroleum Institute
6. BS EN 61511: 2004 - Functional Safety: Safety Instrumented Systems for the Process Industry Sector. British Standards Institute
7. BS EN ISO 10497: 2004 - Testing of valves. Fire type-testing requirements or BS 6755-2:1987 Testing of Valves – Part 2: Specification for Fire Type – Testing Requirements British Standards Institute
8. By meeting the following criteria: not be constructed of cast iron, have metal-to-metal seats (secondary metal seats on soft-seated valves are acceptable) and not be wafer bolted.
9. Remotely operated shutoff valves (ROSOVs) for emergency isolation of hazardous substances. HSG 244. HSE Books, 2004 ISBN 9 780717628032
10. Managing Fire Water and Major Spillages: PPG 18 - Pollution Prevention Guidelines Series - Joint publication of the Environment Agency, Scottish Environmental protection Agency and the Environment and Heritage Service for Northern Ireland. Ref HO-6/00-12K-C-BBUD. Available from http://www.environment-agency.gov.uk/
11. As described in Reducing Error and Influencing Behaviour, HSG48 2nd ed 2003, HSE Books, ISBN 0 7176 2452 8
12. Safety Alert to operators of COMAH oil/fuel storage sites and others storing hazardous substances in large tanks. http://www.hse.gov.uk/comah/alerts/sa0106.htm
13. Finished petrol as defined in Directive 94/63/EC [European Parliament and Council Directive 94/63/EC of 20 December 1994 on the control of volatile organic compound (VOC) emissions resulting from the storage of petrol and its distribution from terminals to service stations. This also includes blended petrol prior to testing.
14. Typically designed to standards BS2654, BS EN 14015:2004, API620, API650 (or equivalent codes at the time of construction).
15. The only exclusion to this would be tanks that are fitted with an enclosed overflow device designed to direct any liquid overflow to safe temporary storage such as an enclosed vessel or dump tank.