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.