Raising the standards after Buncefield
Simon Storage has taken a lead role in identifying and defining how operating and safety standards can be improved post Buncefield. The company is investing more than £2 million in improvements at its own UK facilities over the next three years, even though it has an award-winning safety record.
Simon has been an active participant in the work being undertaken by the Process Safety Leadership Group (PSLG) and its predecessor, Buncefield Standards Task Group (BSTG), following the explosion at Buncefield in December 2005. The BSTG’s Initial Report in October 2006 detailed ‘Quick Win’ recommendations, which were unanimously accepted by the industry. These ranged from installing fire safe tank shut off valves and fail safe operation of remotely operated shut off valves, through to examination of secondary containment bunds to ensure fire resistance of bund joints and provision of suitable tertiary containment measures.
After its initial recommendations, BSTG started to look in more depth at hardware and software issues that could be improved or modified. The group’s final report, produced in July 2007, once again placed a major emphasis on containment, including protecting against loss of containment using high integrity systems and procedures, and engineering against loss of secondary and tertiary containment. This was followed in February 2008 with the introduction of the Containment Policy, which sets stringent new standards for new build and existing facilities storing and handling gasoline and other fuels.
The Policy represents some of the most significant requirements to affect the industry in recent years and the need to comply is driving development of innovative engineering and automation solutions. The new containment standards take into consideration the type of fuel and infrastructure of the site, as well as how close the site is to near-by communities; the highest standards will apply to sites where the public and the environment are most at risk. The Environmental Agency has visited all fuel storage sites in the UK and categorised them as 1, 2 or 3 (1 being sites where the most urgent action is needed) depending on the risk they pose to the environment based on quality of containment, location and sensitivity to environment.
The Containment Policy identifies and outlines requirements for primary, secondary and tertiary containment systems. Primary systems are most important as they are responsible for ensuring fuel does not escape from vessels where it is normally contained in the first place, whereas secondary and tertiary systems prevent pollutants from escaping the site and contaminating the environment, should primary containment be lost.
Primary means of containment include tanks, pipes and vessels that hold liquids as well as fitted devices such as alarms and emergency shut down systems that allow safe operation and prevent spillages from storage tanks.
Secondary means of containment are enclosed areas around storage vessels or bunds, correctly sized and sufficiently liquid-tight to hold any escaping liquids and any water or chemicals used in fire-fighting, to reduce consequences of any spills that may occur.
Tertiary means of containment include drains designed to limit the passage of chemicals off site, or raised kerbs to prevent liquids that have breached the bunds from escaping into the general area around the site. These are largely planned as contingent measures, should either the primary or secondary means of containment fail.
The engineering costs of complying with the Containment Policy are already proving prohibitive for some companies, who have or are withdrawing from storing and handling fuels at their terminals. For others, the challenge will be balancing the considerable expense of achieving impermeability against ongoing operational and maintenance costs, as well as other safety, health, environment and regulatory driven expenditure. Simon has developed specialised engineering expertise in expanding and upgrading both its own and third party bulk liquid and gases facilities. The company also has experience in engineering within exacting compliance and regulatory environments and is now applying this capability to the development of innovative solutions to meet Containment Policy requirements. Whilst the most obvious answer is to lay concrete within bunds and under tanks this clearly involves high costs, and the disruption to business while the work is carried out means that such a project would inevitably have to be phased. With this in mind, Simon’s in house engineering team is currently considering alternative options, such as the use of clay, butyl lining systems or impervious matting systems.
As well as upgrading existing facilities where necessary, 50,500m3 of recently completed new tankage, associated fittings and tank bunds across Simon’s two Immingham terminals have been designed and built in full compliance with the safety and environmental recommendations of the BSTG. Also, following an internal review and completion of its LOPA (Layers of Protection Analysis) studies, Simon has implemented the higher standard SIL (Safety Integrity Level) 2 systems and automatic shutdown systems on its gasoline receipt systems, over and above the TSA and UKPIA commitment to SIL 1. Whilst it does not disagree that SIL 1 provides an adequate level of safety integrity, Simon is keen to ensure that its systems meet – and even exceed – expectations now and for the foreseeable future.
As a result of Simon’s industry experience and insight into changes taking place, Simon is now offering to provide training and engineering solutions that will help third parties implement actions required to reach the new standards. This activity can be conducted at the customer’s own premises and can cover: LOPA, Containment Policy and Automatic Shutdown Solutions and technical assistance with other products falling within the Buncefield Scope.