The COMAH Competent Authority (CA), together with the key industry trade associations, set up the Buncefield Standards Task Group (BSTG) 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. Through this joint approach, the site operators involved, committed themselves to the development and implementation of improved safety and environmental standards for oil/fuel storage sites as soon as practicable. The early recommendations encompassing this industry good practice were contained within the BSTG’s initial report which was published in October 2006. The BSTG’s final report, containing further recommendations on good practice was published on 24 July 2007.
The BSTG’s October 2006 report detailed eight recommendations (see Annex 1) and the timescales for operators to achieve various milestones towards full implementation. This report constitutes an update on progress with compliance against these milestones and as such it provides a snapshot of operators’ progress at the 50 sites that are within the scope criteria for the BSTG’s work.
Progress against the majority of issues has been very positive, reflecting the considerable effort made by site operators to improve standards. However, there are some notable exceptions particularly in relation to secondary and tertiary containment actions.
The analysis is based on information provided by operators with assistance from trade associations. This information has been subject to verification by the CA.
Operators were assessed against the agreed timescales. They have been graded as making satisfactory progress if they achieved the relevant milestone or if they had a timetabled action plan in place but were unable to meet a timescale for site-specific reasons that were acceptable to the regulators, e.g. if certain equipment was unavailable owing to supply difficulties. Some of the timescales in the initial report were testing and it was always possible that a limited number of sites would fail to meet the deadlines. It was acknowledged by the members of the BSTG that this was a more responsible way of facilitating rapid improvement than by lengthening timescales so that they were easily met by all.
The initial recommendations represent only a part of the multiple measures required to be in place at sites. They were selected because they represented good practice in areas where previously there was some degree of variation in compliance. The initial recommendations therefore aimed to bring sites to a common position on these eight issues.
A number of operators have gone beyond implementing these initial recommendations, with some of the later BSTG recommendations and Buncefield Major Incident Investigation Board (MIIB) recommendations already being considered and implemented. There has been an emphasis from both the MIIB and the BSTG on the importance of primary containment (keeping substances in the containers where they should be) which may explain the high levels of progress reported here against primary containment recommendations.
For the three recommendations relating to (i) pipeline transfers, (ii) tank-operating practices, staffing levels and systems and (iii) effective shift/crew handover communication arrangements all 50 sites had made satisfactory progress. For the recommendations on fire safe shut-off valves and remotely operated shut-off valves (ROSOVs), one site’s plans to implement both recommendations had unacceptably long timescales and this site has subsequently come out of the scope of BSTG recommendations by altering its filling procedures to eliminate the possibility of a Buncefield-type explosion happening there due to an overfill.
High-integrity tank-filling control is a complex matter as an assessment of the necessary safety integrity level (SIL) has first to be undertaken and then the appropriate measures need to be implemented where required. All operators have completed risk assessments of the SIL for overfill protection controls against the requirements of BSEN 61511, which is the relevant Standard. However, the CA has concerns about the conclusions reached by a number of operators and a verification programme is in place to ensure that the measures implemented as a result of the SIL assessments reduce the risk as low as reasonable practicable (ALARP). In addition to the BSTG guidance on this (an example Layers of Protection Analysis (LOPA)), HSE commissioned a research project in September 2007 to identify good practice in SIL calculation, the findings of which will be disseminated to operators for incorporation into future assessments.
Five sites have not made satisfactory progress in the necessary improvements in fire resistant bund joints. The sites in question have not implemented the measures due to delays in survey and preparatory work. This is not the industry norm and while the CA takes into account a commitment to longer term developments leading to significantly improved measures, it is unacceptable that preparatory work has taken 16 months since the initial BSTG recommendations.
All sites have completed an assessment of their tertiary containment capabilities. These assessments have and will continue to be used in establishing that adequate capacity exists to contain stored substances and liquids from fire fighting measures.
The CA has been monitoring progress with improvements at fuel storage depots since the Buncefield incident and will continue to do so. The findings in this report are being followed up with individual site operators. Where local investigation confirms unsatisfactory progress, the CA will take appropriate enforcement action including the use of Improvement and Prohibition Notices. These notices will clearly state what actions are required in order to comply with them and failure to do so will result in consideration of prosecution by the appropriate regulator.
The CA will equally robustly monitor progress against subsequent BSTG and future Process Safety Leadership Group, PSLG, (the successor to the BSTG) recommendations. The COMAH CA Containment Policy reinforces the need for sites to comply with the recommendations of the BSTG/PSLG. Enforcement action will be taken where appropriate.
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.
Tank-operating practices, staffing levels and systems, must provide effective safety margins to prevent a release.
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 standards.
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 standard or be intrinsically fire-safe.
An assessment against HSG 244 should be completed and Remotely Operated Shut Off-Valves (ROSOVs) for the emergency isolation of hazardous substances should fail safe.
Joints in bunds must be capable of resisting fire. Existing bunds should be modified to meet this requirement.
Tertiary containment measures must be capable of preventing the uncontrolled escape of firewater and other products to the environment. Assessment of sites and action plans for improvement should have been completed.
Effective shift/crew handover communication arrangements must be in place to ensure the safe continuation of operations.