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“STUDY OF MAJOR FIRES AT STORAGE TANKS – LESSON

LEARNT AND IMPLEMENTATION”

SUMMER INTERNSHIP PROJECT REPORT

JAMNAGAR MANUFACTURING DIVISION


RELIANCE INDUSTRIES LIMITED

By
KUNAL DEEP
(EC No.19601253)

[B.Tech, Fire & Safety Engineering]


UNIVERSITY OF PETROLEUM AND ENERGY STUDIES
(UPES, DEHRADUN)
Session 2015-19

Under the guidance of


Mr. Mitesh Sharma
General Manager

1
CERTIFICATE

This is to certify that the training report entitled “STUDY OF MAJOR


FIRES AT STORAGE TANKS- LESSON LEARNT
&IMPLEMENTATION” is being submitted by KUNAL DEEP (EC NO.
19601253) in partial fulfillment of requirements for the award of degree of
Bachelor of Technology in Fire & Safety Engineering, University of
Petroleum & Energy Studies during the academic year 2015-2019.

KUNAL DEEP MR. UMESH KHANDALKAR

EC. NO. 19601253 FIRE CHIEF


RIL, JMD

2
DECLARATION

I, hereby declare that the work being presented for the Summer Internship project
entitled “STUDY OF MAJOR FIRES AT STORAGE TANKS – LESSON
LEARNT & IMPLEMENTATION” is an authentic record of work which has
been carried out at Jamnagar Manufacturing Division of Reliance Industries
Limited, under the guidance of Mr. Mitesh Sharma, General Manager, Fire
Department.

Kunal Deep Mr. Mitesh Sharma


EC. NO. 19601253 General Manager
RIL, JMD

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ACKNOWLEDGEMENT

I am thankful and highly indebted to the Management of RELIANCE


INDUSTRIES LIMITED for offering me an opportunity to pursue my
summer internship at JMD, RIL for two months. This internship was a
great chance for my personal and professional development.
I am extremely obliged that I got an opportunity to work under Mr. Mitesh
Sharma, General Manager, Fire Department. It would not have been possible
without his kind support, guidance and constant supervision in completing
this project.

I also express my sincere thanks to Mr. Rakesh Roshan from Training


department, Fire service, JMD RIL for providing multi directional support
throughout the entire internship period at each and every stage of the project
to accomplish the goal.

I would like to express my gratitude towards my parents and employees of


RIL, JMD for their kind co-operation and encouragement which helped me
in completion of this project.

I Offer my sincere thanks to industry persons for giving me such attention and
time and willingly helping me out with best of their abilities.

I perceive this opportunity as a big milestone in my career development. I will


strive to use the gained skills and knowledge in the best possible way and I
will continue to work on their improvement in order to attain my career
objectives.

Kunal Deep
B.Tech, FSE
UPES, Dehradun

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ABSTRACT

Storage facilities include crude oil import terminals, refineries,


petrochemical processing plants, chemical storage depots and plastic
manufacturing facilities. Consequently it contains a large number of
storage tanks containing a wide variety of materials.

This project includes the various types of storage tanks at refineries along
with their selection criteria. As the hazards linked with the storage tanks
are different for different types of tanks so, the various fire hazards
associated with different types of storage tanks has been briefly explained
and apart from that, the special hazards that a storage tank presents in a
specific condition has also been described in the report.

The aim of this project is to study major fires at storage tanks that have
occurred in the past and to gather the learnings from those tank accidents.
This project overviews major tank fires case investigations and in
succession, the key findings from those accidents have been summarized.

This report compiles the recommendations that were given after few
major tank fires by various regulatory bodies across the world. This
Project also includes the study of various safety features for Storage tanks
and Spheres that has been installed at JMD, RIL.

The project also comprises of the gap analysis that has been done in order
to ensure that the storage tank facilities present at JMD, RIL are totally
equipped with all the necessary safety features required for safe handling
of storage tanks.

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ABBREVATIONS

DTA - Domestic tariff area

MTF - Marine tank farm

NFPA - National Fire Protection Association

OISD - Oil Industries Safety Directorate

RIL- Reliance Industries Limited

RTF- Refinery Tank Farm

SEZ - Special Economic Zone

VCE- Vapor cloud explosion

BLEVE- Boiling liquid expanding vapor explosion

ATV - All terrain Vehicles

MOV - Motor Operated valve

HOV - Hand Operated Valve

API – American Petroleum Institute

OSHA – Occupational Health and Safety Administration

CSB – Chemical Safety Board

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TABLE OF CONTENTS
SI.NO. CONTENTS PAGE NO.

1. COVER PAGE 1
2. CERTIFICATE 2
3. DECLARATION 3
4. ACKNOWLEDGEMENT 4
5. ABSTRACT 5
6. ABBREVIATION 6
7. INTRODUCTION TO RIL 10
7.1 LOCATION 11
7.2 MANUFACTURING FACILITIES 11
7.3 THE SEZ REFINERY 12
7.4 THE J3 PLANT 13
8. INTRODUCTION TO STORAGE TANKS 14
9. CLASSIFICATION OF STORAGE TANKS 15
(TREE DIAGRAM)
10. TYPES OF STORAGE TANKS 16
10.1 FIXED ROOF TANKS 17
10.1.1 ACCESSORIES OF FIXED ROOF 18
TANKS
10.1.2 FIXED ROOF TANKS FIRE 21
SCENARIOS
10.2 FLOATING ROOF TANKS 22
10.2.1 ACCESSORIES OF FLOATING 27
ROOF TANKS
10.2.2 FIRE SCENARIOS 30
10.3 HORTON SPHERES 34
10.3.1ACCESSORIES OF HORTON 35
SPHERES
11. MULTIPLE TANK FIRES (SPECIAL 36
HAZARDS)
11.1 RADIANT HEATING 36
11.2 DIRECT FLAME IMPINGEMENT 36
11.3 BOIL OVER 37
11.4 SLOP OVER 38
11.5 FROTH OVER 38
12. SELECTION CRITERIA OF A TANK 39
13. DESIGN & CONSTRUCTIONAL CODES 39
14. MAJOR FIRES AT STORAGE TANKS 40

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14.1 CAPECO DISASTER 40
14.1.1 INCIDENT SUMMARY 40
14.1.2 CHRONOLOGY OF EVENTS 41
14.1.3 KEY FINDINGS 42
14.1.4 RECOMMENDATIONS 44
14.2 MOTIVA ENTERPRISES, DELAWARE 50
14.2.1 INCIDENT SUMMARY 50
14.2.2 CHRONOLOGY OF EVENTS 50
14.2.3 KEY FINDINGS 51
14.2.4 RECOMMENDATIONS 53
14.3 HERRIG BROTHERS’ 57
14.3.1 INCIDENT SUMMARY 57
14.3.2 CHRONOLOGY OF EVENTS 57
14.3.3 KEY FINDINGS 58
14.3.4 RECOMMENDATIONS 61
14.4 BETHUNE POINT WWTP EXPLOSION 62
14.4.1 INCIDENT SUMMARY 62
14.4.2 CHRONOLOGY OF EVENTS 63
14.4.3 KEY FINDINGS 64
14.4.4 RECOMMENDATIONS 65
14.5 ALLIED TERMINAL 68
14.5.1 INCIDENT SUMMARY 68
14.5.2 CHRONOLOGY OF EVENTS 69
14.5.3 KEY FINDINGS 70
14.5.4 RECOMMENDATIONS 71
14.6 BUNCEFIELD DISASTER 72
14.6.1 INCIDENT SUMMARY 72
14.6.2 CHRONOLOGY OF EVENTS 73
14.6.3 KEY FINDINGS 75
14.6.4 RECOMMENDATIONS 76
14.7 JAIPUR OIL DEPOT FIRE 84
14.7.1 INCIDENT SUMMARY 84
14.7.2 CHRONOLOGY OF EVENTS 85
14.7.3 KEY FINDINGS 87
14.7.4 RECOMMENDATIONS 90
15. MAJOR CAUSES OF FIRES AT STORAGE 95
TANKS
15.1 LIGHTNING 95
15.2 OPERATIONAL ERRORS 98
15.3 EQUIPMENT / INSTRUMENT 100
FAILURE

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15.4 STATIC ELECTRICITY 100
15.5 MAINTENANCE ERROR 101
15.6 TANK CRACK / RUPTURE 101
15.7 LEAK & LINE RUPTURE 101
15.8 OTHER REASONS 101
16. PIE CHART 102
17. SAFETY FEATURES AT STORAGE 104
TANKS
18. CHECKLIST (GAP ANALYSIS) 105
19. CONCLUSION 110
20. REFERENCES 111

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INTRODUCTION TO RIL

The reliance group, founded by Dhirubhai H. Ambani (1932-2002) is India’s


largest private sector enterprise, with business in the energy value chain.
Group’s annual revenues are in excess of US $62.2 billion. The flagship
company, reliance industries limited, is a future global 500 company and is
the largest private sector company in India. RIL is India’s largest private
sector company on the integrated energy value chain and has a growing
presence in retail and digital services in India. Backward vertical integration
has been the cornerstone of the evolution and growth of Reliance. Starting
with textiles in the late seventies, reliance pursued a backward vertical
integration in polyester, fiber intermediates, plastics, petroleum refining, and
oil and gas exploration and production to be fully integrated along the
materials and energy value chain. The group’s activities span exploration and
production of oil and gas, petroleum refining and marketing, petrochemicals,
textiles, retails and special economic zones. Reliance enjoys global leadership
in its businesses, being the largest polyesters yarn and fiber producer in the
world and among the top five to ten producers in the world in major
petrochemical products.

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 Location

 Jamnagar is situated on the north-west coast of India; it is located in the


state of Gujarat at village Motikhavdi, Taluka - Lalpur, District - Jamnagar.

 The refinery site is located just to the south of the State Highway No. 25
Situated on the northwest coast of India, the complex is located at
Motikhavdi, Jamnagar district, in the state of Gujarat.

 The location of RIL’s on the west coast of India supported by world class
logistics and port facilities provided the company with freight advantages.
Most of the crude imported is transported on very crude carriers (VLCC).

 The existing refinery at Jamnagar has more than 50 process units, which
together process the basic feedstock, crude oil, to obtain finished products
deploying the following major refining processes:

 Crude oil distillation


 Catalytic cracking.
 Catalytic reforming.
 Delayed coking.

 Manufacturing facilities

Reliance industries limited operates world class manufacturing facilities across


the country at Allahabad, Barabanki, Dahej, Hazira, Hoshiarpur, Jamnagar,
Nagothane, Nagpur, Naroda, Patalganga, Silvasa and Vadodara.
Reliance’s Jamnagar complex represents the largest industrial project ever
implemented in the Indian corporate sector. The Jamnagar manufacturing
complex is a fully integrated manufacturing complex, with a petroleum refinery
complex, an aromatics / petrochemical complex, a power generation complex, a
port and terminal complex as well as access to a pipeline network.

The complex being about 815 km by road away from Mumbai and approximately
30 km from the city of Jamnagar is located in proximity to the Gulf of Kutch, a
sheltered bay close to the Middle - East crude oil sources.

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The refinery complex at Jamnagar consists of more than 50 process units which
together process the basic feedstock, crude oil to obtain various finished
products deploying the following major refining processes: -

 Crude oil distillation (Atmospheric as well as Vacuum distillation)


 Hydrodesulphurization
 Catalytic Reforming Unit
 Fluid Catalytic Cracking Unit
 Delayed Coker Unit
 Sulphur Recovery Unit
 Polypropylene Unit

 THE SEZ Refinery

RIL’s refinery in the Special Economic Zone at Jamnagar, Is the world’s sixth
largest and has an elson complexity index of14.0,making it the largest and most
complex refinery globally. The refinery has capacity of processing 5, 80,000
barrels of crude oil per stream day. In addition to size and complexity, the SEZ
refinery has several advantages:

 Ability to process challenged crude varieties.


 Able to produce EuroV-grades of gasoline and diesel.
 Highly competitive operating cost due to advantages of scale, technology
and operational synergies.

Capability to produce alkylates-a premium gasoline blend component. It will have


the flexibility to maximize production of alkylate by converting butane to
isobutene.

All key processing units including the Fluidized Catalytic Cracking Unit ( FCCU
) ,Vacuum Gas Oil(VGO), Hydrogen Manufacturing Unit(HMU), Diesel Hydro
Desulfurization(DHDS), Propylene Recovery Unit(PRU), Coker unit and the
Polypropylene complex are operating close to their respective design capacities.
All the support units and the utilities are fully operational and presently the
refinery is operating at its designed capacity.

The refinery has successfully processed more than 20 types of crude oils,
including difficult crude oils within a few months of its start-up, thus reflecting
superior quality of assets and capabilities. Exports have commenced to 26
countries, including to the US and Europe.

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The J3 Plant

J3 Expansion project mainly intended to make three major facilities here at JMD
- Gasification complex, C-2 complex and Butyl Rubber. Gasification complex is
designed and will be commissioned to reduce power generation cost at JMD.
Currently we are using Natural Gas as feed to Gas Turbine which is our major
source of power and operational at Captive Power Plant inside the refinery ISBL.
Pet-coke is the end product of the refinery and are sold at very cheap price and
are generally used in boilers to generate heat. In gasification unit, this Pet Coke
will be heated in oxygen deficient atmosphere there by resulting in a lot of
Hydrogen and Carbon Mono-Oxide. This CO & H2 combined is known as
SYNGAS and this gas will be a feed to the Gas Turbine instead of NG and thereby
reducing power generation cost significantly.

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INTRODUCTION TO STORAGE TANKS:

1. INTRODUCTION

Storage tanks are essential industrial facilities to accumulate oil,


petrochemicals and gaseous products. Storage facilities include crude oil
import terminals, refineries, petrochemical processing plants, chemical
storage depots and plastics manufacturing facilities. Since tanks contain
huge mass of fuel and hazardous materials, they are always targets of
serious accidents such as fire, explosion, spill and toxic release which may
cause severe impacts on human health, environmental and properties which
require extensive consideration in terms of the management of design,
manufacture, installation, operation, regular inspection and maintenance.
Every six months or so we are reading in either a newspaper or trade journal
about a petroleum product storage tank fire occurring in the world. A small
accident may lead to million-dollar property loss and a few days of
production interruption whereas large accident results in lawsuits, stock
devaluation, or even company bankruptcy. Although large-scale tank fires
are very rare, they present a huge challenge to firefighters, oil companies
and the environment. Prevention from Storage tank fires is more important
than its fighting because it has been observed that once if a vapor cloud has
been formed and spread then it is almost impossible to restrict it from
getting an ignition source and in turn a major tank fire and explosion. There
are only two alternatives for combating such a fire, either to let it burn out
and alternatively, to actively extinguish the fire, using firefighting foams.
FIRESAFETY is the number one priority in the chemical industry. Its
importance is globally acknowledged especially due to recent significant
chemical accidents.

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CLASSIFICATION OF STORAGE TANKS:

STORAGE TANKS

ABOVE GROUND UNDER GROUND


STORAGE TANKS STORAGE TANKS
TANKS
FIXED ROOF

ATMOSPHERIC STORAGE HORTON SPHERES


TANKS

SINGLE DECK

FIXED ROOF FLOATING ROOF


TANKS TANKS
DOUBLE DECK

INTERNAL FLOATING EXTERNAL FLOATING


ROOF TANKS ROOF TANKS

CONE ROOF DOME ROOF COLUMN


SUPPORTED

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TYPE OF STORAGE TANKS

CONE ROOF FLOOTING ROOF

INTERNAL FLOATING ROOF

DOME ROOF HORTON SPHERE

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1. FIXED ROOF TANKS:

 Fixed roof tanks are vertical steel cylinders with a permanently attached
roof. In the petroleum industry these are typically cone shaped but can be
flat or domed.

 Used for storing non-volatile materials like Heavy oils, gas oil, furnace oils
and non-volatile chemicals.

 These tanks have a vapor space between the liquid surface and the
underside of the roof. On larger tanks, 35 ft. (10 m) and greater in diameter,
the roof is constructed with a weak roof-to-shell joint, so that in event of
an overpressure (such as from an internal explosion) the roof will separate
from the vertical shell to prevent failure at the bottom seam which would
release the entire tank contents.

 Fixed roof tanks comprise of a tank bottom/base, a cylindrical shell


constructed in a number of plated levels-these are called tiers.
 The roof plates are 5mm thick and are interconnected by lap-weld on the
top side only.

 Tanks with fixed roofs include

 Cone roof tanks


 Dome roof tanks
 Column supported roof tanks

 All fixed roof needs to be vented either by open vents or by


pressure/vacuum valves to maintain the pressure difference between tank
vapour pressure and outside atmosphere:
 For liquid to get in, air and vapours must be pushed out. The pressure in
the tank must be slightly above atmospheric.

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 For liquid to get out, air and vapours must be sucked in. The pressure in
the tank must be slightly below atmospheric.

 In non-pressure fixed roof tanks normal venting takes the form of free
flow atmospheric vent which allow unimpeded flow of vapors out of, and
of air into the tank and, at the same time, prevent rain and airborne dust
from getting into the tank.
 In pressure fixed roof tanks, the contents are stored under nitrogen
blanketing to prevent ingress of air/moisture or any foreign material and
to reduce vapor formation.

2. FIXED ROOF TANK APPERETENANCES: -

 Vents:

i. Open vents

The tank breathes in air when the tank pressure is lower than the atmospheric
pressure and breathes out when tank pressure is greater than the set pressure.

Open vents are goose neck type covered with a 4 to 8 mesh screen. Normal
Venting takes the form of free-flow atmospheric vent which allow unimpeded
flow of vapors out of, and of air into the tank and, at the same time, prevent rain
and airborne dust from getting into the tank. The vents are fitted with the flame
arrestors to prevent propagation of flame into the tank.

Pressure Vacuum Relief Valve

Functions:

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 Minimizing vapor loses that would occur by free venting.
 Protection of the tank from excessive pressure or over vacuum.
 Where tanks are blanketed, breathing-in will be from the blanketing gas
system. Necessary control valve is provided for supply of blanketing gas
at constant pressure.

ii. Emergency Venting :

When a tank is exposed to fire, vent capacities based on normal breathing


may not be adequate to cope up with the increased rate of vaporization.

Roof is only lightly attached to shell so that under excessive internal


pressure, the roof torn away from the shell, leaving the shell and its
content intact.

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iii. DIP Hatch :

Dip hatch or gauge hatch is used for gauging the height of a liquid in a
tank as well as to take out samples for testing. Gauge hatch are non-
sparking (or linked with non-sparking material) and self-closing type.

Gauge well pipe (with slots) is provided for all types of tanks. This
should have continuous contact by means of strip with bottom plate of the
tank. Continuous contact makes the tank safe with respect to static charge
accumulation and acts as a support for the gauge well pipe.

iv. Datum Plate:

Datum Plate is a circular/ rectangular steel plate provided on the floor of


the tank just below the Dip hatch pipe.

Datum plate corresponds to the floor of the tank, where the bob of the dip
tape rests.

The height measured from the tapered notch in the gauge pipe to the
datum plate is termed as Reference Height.

v. Manholes:

The number of manholes in a tank depends upon the diameter of the tank
(API 650). Minimum of one flush type clean out manhole is provided for
tanks for access into the tank for inspection and cleaning.

vi. Bottom Drains:

Drains are provided in all tanks for draining water and also for emptying
out the tank for cleaning. Apex down tank bottom have one drain
connection located at the lowest point near the center of the tank in addition
to normal circumferential drains.

 FIXED ROOF TANK FIRE SCENARIOS:

The type of fire scenario for this type of tank are:

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 Vent Fire
 Full Surface Fire
 Bund Fire
 Fixed roof vent Fire: -

 A vent fire is a fire in which one or more of the vents in a fixed roof
tank has ignited.
 Flammable vapors will always be present in the vicinity of vents,
either because of the tank's daily breathing cycle or during tank
filling operations.
 Vent Fire with orange and yellow flames with black smoke will
indicate that the vapor/air mixture in the tank is "fuel rich".
Flashback into the tank may not result in a vapor space explosion
and it may be possible to extinguish the fires using a dry chemical
extinguish any or foam.
 Vent fires with a blue-red 'snapping' flame that is nearly smokeless
will tend to indicate that the vapor/air mixture in the tank is
flammable or explosive. As long as the product is vented through an
open PV valve, flashback may not occur and a vapor space explosion
may be avoided.
 A defective PV valve or flame arrestor may result in a flashback and
subsequent explosion. Therefore, it is imperative that these
components are maintained well and function correctly.

 Fixed Roof Full Surface Fire: -

 A full Surface Fire in a fixed roof tank can be brought about by a vent
fire escalation.
 A vapor space explosion may occur if the vapor space is within a
flammable range at the time of flammable flashback especially if PV
valves and/or flame arrestors are defective.
 Due to explosion if the roof is only partially removed, then there may
be difficulties in applying foam to the tank surface and an insufficient
foam application rate may prolong the fire.
 The fire can be extinguished either by 'topside' foam application, using
monitors and/or pourers or by subsurface foam injection.

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 Fixed roof bund fire:

A fire in bund is any type of fire that occurs within the containment area
outside the tank shell. These types of fire can range from a small spill
incident up to a fire covering the entire a bund area.

3. FLOATING ROOF TANKS:

 Economical storage of volatile liquids with higher degree of safety.


 A steel roof floats on the liquid and moves up and down as oil is pumped
into or out of the tank.
 Absence of vapor space above the liquid.
 Each pontoon is a watertight compartment so that even if there is a leak in
one of the pontoons, the liquid is confined to that particular compartment.
 Each Pontoon has a hatch on the top with covers for checking.

 FLOATING ROOF TANK: TYPES

Single Deck Double Deck


• Single deck roof, having o Entire roof is like a number
pontoon at the of pontoons.
o Underside is in contact
periphery
with the Product.
• Depth of Pontoons 0.4
o Top deck provides
m-0.8 m
insulation over the entire
• Standard Sizes 10 m-60
area.
m. o Vapor loss is minimized.
• Plate size 4.75 mm o High degree of stability &
reserve buoyancy.
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 Single deck floating roof tank:


In single deck floating roof, the buoyancy is derived in the pontoon, an
annular circular pontoon radially divided into liquid tight compartments.

The center deck which is formed by membrane of thin steel plates are lap
welded together and connected to the inner rim of the pontoons.

single deck floating roof tank

 Double deck floating roof tank:


Double deck roof consists of upper and lower steel membranes separated
by a series of circumferential bulkhead which is subdivided by radial
bulkhead.

Double deck roof is much heavier than single deck one, hence it is more
rigid. The air gap between the upper and bottom plates of the deck has
insulation effect which helps against the solar heat reaching.

There is less flexing or distortion of a double deck roof and due to the
construction, there is less chance of corrosion allow seepage of product on
the roof.

 Advantage of floating roof tanks



There is no vapor space and thus eliminating any possibility of
flammable atmosphere.

It reduces evaporation losses and hence reduction in air pollution.

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Vapor emission is only possible from the rim seal area and this would
mainly depend on the type of seal selected and used. This gap
normally represents less than 2% of the total tank area.

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Double deck floating roof tank

 INTERNAL FLOATING ROOF TANK:

 These tanks have a fixed roof over an internal floating roof. The fixed
roof is usually a cone.
 The reason for having an internal floating roof is to conserve vapour and
protect the environment from volatile organic compounds (VOC's).
 The internal floating roof tank reduces the vapour losses by at least 95%.
Such tanks are the same as the ordinary fixed roof cone tanks but with
internal floating roofs.
 These tanks are used to store high volatility (low flash point) liquid or
toxic liquids.
 Where product degradation due to air/moisture ingress is a problem and
fixed roof tanks are used, such tanks should be provided with inert gas
blanketing.
 Nitrogen blanketing for internal floating roof tanks/fixed roof tanks
should be considered for storing hazardous petroleum products like
benzene etc.

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 Advantages:

 Conservation of vapor.
 Promote cleanliness of product.
 Reduce internal corrosion.

 OPEN TOP FLOATING ROOF TANKS

 An open top floating roof tank is a vertical cylindrical tank that has a
roof, which floats in the liquid product surface.
 It significantly reduces evaporative losses and the hazards associated with
having a large, possibly flammable vapour surface.
 Typically, such tanks are used for the storage of crude oil and all volatile
(low flashpoint) products.
 There are 3 basic roof designs:
 Pontoon or single deck roofs.
 Double-deck roofs
 Geodesic roofs.

o Double deck roof: -

The design of the roof provides sufficient buoyancy to keep the roof
floating with any two compartments punctured. The roof is designed to
float directly on the product. The air space between the upper and lower
decks reduces the amount of surface product heating from ambient air
temperature and solar radiation. This significantly reduces the formation
of temperature generated condensable vapour under the floating roof.

o Geodesic roofs: -
In recent years, as weather protection, it has become popular to install
geodesic dome type roofs. These are lightweight structures over the
complete floating roof tank, thus making effectively an internal floating
roof tank. In general, it is thought that, this should be a good fire hazard
management measure because the tank roof is not subject to
environmental extremes such as heavy rainfall, but there are certain
considerations that should be taken into account. Lightning strike, rim
seal fires or spills on the roof.

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ACCESSORIES OF FLOATING ROOF TANKS:

On a floating roof tank there are a number of different fittings such as:

I. Rolling Ladder:

 One end is hinged at the gauge platform and the other end is free to move
on rollers on a runway fixed to the roof.
 Rolling ladders not considered essential for lesser dia. tanks where
occasional descents to the roof is provided by means of a monkey ladder.

II. Wind girder with walkway:

 Open tanks reinforced with stiffening ring called “Wind Girders” to


maintain roundness when tank is subjected to wind loads.
 Can also be used as walkways, in which case the width of the girder is more
than 0.6m, moreover it should not be less than 1 m from top of the shell
with handrails on the open side.
 This primary wind girder is located at or near the top of the tank.
 Secondary wind girder is sometimes required for both floating and fixed
roof tanks, to prevent buckling of the tank shell under wind and/or vacuum
condition

III. Roof Drains:

 Rain falling on to a floating roof must be led away to the outside of the
tank.
 The water is directed from roof via a metal pipe with swivel joints to an
outside gate valve near bottom of the shell.
 Flow of product via drain to the roof is prevented by NRV in the roof drain.

IV. Roof legs:

 Roof supported by number of tubular legs, when not afloat.


 Each leg free to move in a sleeve attached to the roof.
 Position of legs fixed at two points by a securing pin.

Position 1: Minimum height of tank roof in lowest working Position above the

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tank floor.
Position 2: Minimum clearance between tank roof and tank
Floor for maintenance work.

V. Emergency roof drains:

 In case the normal roof drain fails or due to heavy rains, the normal roof
drain is not able to cope with the load, water gets drained though
Emergency roof drain.
 A short length of about 250 mm dia. pipe passes through both decks and
extends slightly above the roof.
 The other end terminates in a hanging turf filled with water and acts as a
seal.
 The water going through the drain falls into the tank and prevents
overloading and sinking of the roof.

VI. Rim vents:


To avoid any damage to the seal due to excess vapor pressure rim vent is
provided which allows the vapor to escape to atmosphere depending upon
the size 1 to 3 rim vents are provided.

VII. Gauging facilities

VIII. Level alarms

IX. Shunts to dissipate static charge between roof and shell

X. Scrapers to remove wax deposits on tank walls

XI. Firefighting equipment’s

XII. Auto Bleeder vents:

 Permit the escape of air when an empty tank is being filled and before the
roof is afloat.
 Protect the tank against vacuum, as they open automatically just before the
roof lands on its support

XIII. Bund Wall:


28
 Bund wall surrounds a single tank or a group of tanks.
 Retains spillages.
 While calculating the capacity of a bunded enclosure, a reasonable
assumption is made that the largest tank will fail but other tanks will be
intact.
 Height of Bund wall: 2 meters. At MTF, Crude tanks have dyke wall
height up to 4 meters.
XIV. Floating roof tank rim seals:

 Rim seal is a vapor conserving device on floating roof tanks.


 There are two types of rim seals: -
1. Primary seals
2. Secondary seals

Primary Seals: -A mechanical primary seal consist of a fabric reinforced


elastomeric seal mounted between the edge of roof and the tank wall.

 The seal is securely fixed to the roof and pushed against the tank wall by
means of a pantograph arrangement and compressed spring type
mechanism.
 This type of arrangement helps to centralize the roof and keep the width of
the gap constant around the entire tank Circumference.
Tube Seals: - This are consisting of fabric reinforced elastomeric tube fitted with
a resilient material.

 The tube distorts according to the movement of the roof such that seal is
maintained between the roof and shell.
 The tubes may be fitted with resilient foam or a liquid.
Secondary seals: - As environmental restrictions have become more stringent
and to reduces losses from emissions, secondary seal mounted above primary
seal.
 Secondary seal gives protection to the primary seal and themselves
exposed.
 Secondary seals are fabricated of Stainless Steel.
 Secondary seal consists of bent compression plates which maintain
constant contact with the tank wall.

29
 EXTERNAL FLOATING ROOF TANK FIRE SCENARIOS:

The types of fire scenario for this type of tank are:


 Rim seal fire
 Spill on Roof Fire
 Full Surface Fire
 Bund Fire
 Pontoon fire

1. Open Top Floating Roof Tank Rim Seal Fires: -

Rim seal fires comprise the majority of fires involving external floating roof
tanks. Rim seal fire is one where the seal between the tank shell and roof has
lost integrity and there is ignited vapor in a seal area.

Fig. Rim seal fire

 Reasons of Rim seal fail: -


1) The primary seal can fail from excessive tank movement or rubbing against
tank walls corroded by salt air or from foreign objects falling into the rim
seal gap.
2) Failure of process monitoring can allow hot product or high vapor pressure
product or gas (including nitrogen or air) into a tank causing an eruption of
vapor and product out of the rim seal area.
3) Failure of process monitoring can lead to overfill of a tank. Tank settling
can cause a tank to go out of round, leading to rim seal gaps.

30
4) When a tank is out of round, there is also the possibility that the roof could
stick or jam. Subsequent sudden movement of the roof could cause product
and flammable vapor to escape into the rim seal area.
5) In the LASTFIRE incident survey, 83.87% initial fire events within the
scope of the survey were lightning ignited rim seal fire.

 Ignition Source Modes – Rim seal Area

1) Lightning is by far the most frequent source of ignition of fires.


2) In the LASTFIRE incident survey, 52 of the 62 initial fire events within
the scope of the survey were lightning ignited rim seal fires.

2. Open Top Floating Roof Tank Spill-On Roof Fires

 A spill-on-roof fire is one where a hydrocarbon spill on the tank roof is


ignited but the roof maintains its buoyancy.
 Flammable vapors escaping through a tank vent or roof fitting may be
ignited.
 It is very difficult to prevent a spill on roof fire from escalating to a full
surface fire because most firefighting systems are designed for fires in the
rim seal area.
 A single spill on roof fire recorded in the LASTFIRE survey occurred at
Milford Haven in 1983 on a single skin roof. The fire covered 50% of the
roof within 10-15 minutes. Within one hour, the fire had escalated to a full
surface fire.
Reasons of open top floating roof tank spill

 Mechanical failure or corrosion is the dominant mode of failure leading to


spills in the roof area.
 Seal or pontoon damage
 Leg failure or failure of the roof leg pads
 Cracking or fracture on the roof
 Roof drain failure
 Leaks from mixers, pipework, flanges or valves

31
Fig. Spill on roof

3. Open Top Floating Roof Tank Full Surface Fires

 A full surface fire is one where the tank roof has lost its buoyancy and some
or the entire surface of liquid in the tank is exposed and involved in the
fire.
 If a roof is well maintained and the tank is correctly operated, the risk of a
rim seal fire escalating to a full surface fire is very low.
 As per LASTFIRE survey, the escalation of rim seal fire into full surface
fire is only 1 out of 55 rim seal fire on operational tanks.
 As per LASTFIRE survey, the escalation of rim seal fire into full surface
fire is only 1.92%.

Fig.9. Full surface fire

Causes

External floating roofs can sink due to flotation failure caused by pontoon
or double deck malfunction.

By excessive weight from rainwater or firewater, where there is an
inadequate drainage either from chock of the drains.

32
4. BUND FIRES:

A fire in the bund is any type of fire that occurs within the containment
area outside the tank shell.

These types of fire can range from a small spill incident up to a fire
covering the entire a bund area.

Fig.8. Bund fire

Causes:

Corrosion of the tank bottom.


Spillage and consequently ignition in bund area.
Leakage from flange.
Tank weld failure.
Piping leakage.

Bund fire escalation from full surface fire


 When the roof sinks to produce a full surface fire, product can escape into
the bund through the roof drain.
 Part of the shell of the tank on fire can collapse. Normally, the tank shell is
designed to collapse inwards when it loses its mechanical strength at high
temperatures.
 The tank shell to bottom seam may fail because of erosion of the tank
foundations by firewater in the bund. Fires on pipework or mixers may
cause flanges or valves to fail, allowing product into the bund.
 Boil over or slop over may occur.

33
5.OPEN TOP FLOATING ROOF TANK PONTOON FIRES

A fire can occur if flammable vapor builds up and is ignited in a pontoon.

Causes

Leakage from pontoon.

Fig.Pontoon fire

4. HORTONS SPHERS

 The Horton sphere is a spherical pressure vessel, which is used for storage
of compressed gases such as propane, liquefied petroleum gases in a liquid
gas stage.
 Product having high vapor pressure such as LPG and Propylene are stored
in Horton sphere.
 Spheres are selected because of equal distribution of pressure or we can
say Maximum volume per unit surface area.
 Standard tanks are not suitable for the storage of liquefied petroleum gases,
such as propane or butane. Owing to the high pressure required to maintain
these gases in a liquid state; they are therefore stored in special pressure
vessels.
 The ideal shape for a pressure vessel is spherical, as the internal pressure
is the same at any point.
 An advantage of spherical storage vessels is that they have a smaller
surface area per unit volume than any other shape of vessels. This means,
that the quantity of heat transferred from warmer surroundings to the liquid
in the sphere, will be less than for cylindrical or rectangular storage vessels.

34
HORTON SPHERE

 ACCESSORIES OF HORTON SPHERES:

a. Safety valve
b. Level indicator
c. Level switches and interlocks
d. ROV – (Remote operated valve)
e. Pressure gauge
f. Temperature indicator
g. Vapor balancing line
h. Combustible gas detectors.
i. Heat detectors.

35
 MULTIPLE TANK FIRES (SPECIALHAZARDS):

There are four main escalation routes which may result in a multiple tank: -

1. Radiant heating from a full surface fire, causing ignition of nearby tank
2. Direct flame impingement
3. Boil-over / slop over
4. Explosive ignition (fixed roof tanks)

Radiant Heating
 Radiant heating from a full surface fire is one possible cause of ignition of a
fire on a nearby tank.
 The heat loading from the fire is conducted through the steel shell and roof of
the neighboring tank and into a layer of fluid next to the wall.
 The heat transfer is not high enough to boil the heated layer next to the wall,
it merely becomes buoyant and sets up convection currents up the wall of the
tank and across the roof.
 These convection currents produce a stratification of the product in the tank,
with a hot layer next to the wall and under the roof.
 Eventually, the fluid at the top of the shell under the roof reaches it initial
boiling point and vapors is driven past the seal to be ignited as a rim seal fire.

Direct Flame Impingement

 The type of fire that is most likely to produce ignition of a nearby tank is a
bund fire impinging on the tank shell.
 Local boiling of the product can occur along the wall of the flame-
impinged tank and the impinging flame easily provides an ignition source
for the vapor driven off.

36
Boil over, Slop over and Frothing

Boil over

One of the major escalation risks of a full surface fire is that of a boil over.
Boil over can occur in fuels which have fractions with differing boiling
points. There is a “rule of thumb” that a boil over.

Boil over is defined in NFPA 30 as “an event in the burning of certain oils
in an open-top tank when, after a long period of quiescent burning, there is
a sudden increase in fire intensity associated with expulsion of burning oil
from the tank.

Boil over occurs when the residues from surface burning become denser
than the unburned oil and sink below the surface to form a hot layer, which
progresses downward faster than the regression of the liquid surface. When
this hot layer, called a ‘heat wave’, reaches water or water-in-oil emulsion
in the bottom of the tank, the water is first superheated and then boils,
almost explosively, overflowing the tank.

These characteristics are present in most crude oils and can be produced in
synthetic mixtures.
 For a boil over to occur, the following conditions must be present:


The full-surface fire must involve all or most of the surface of the liquid.

The tank must contain free water or water in-oil emulsion, typically at the
tank bottom or on top of the sunken roof. This situation is not uncommon
in tanks used to store crude oil. It can occur in other ambient temperature
heavy oil storage.

Generation of a heat wave that enters into contact with water below the
hydrocarbon, presence of water to be converted to steam.

A viscous hydrocarbon which steam cannot readily pass from below.

The LASTFIRE review of major fires recorded 16 fire incidents on tanks
containing boil over fuels of which 7 boiled over, 2 slopped over and 7
spilled oil into the bund when the tank failed without boiling over.

There are three key elements that must be present for boil over to occur in
its most violent form:
1. An open top tank fire
2. A water layer in the tank
3. Development of a high temperature, relatively dense hot zone, which is
determined by the nature of the stored product.

 In full surface fires involving crude or certain specifications of heavy fuel


oils there is the possibility of a boil over.
 This occurs when a hot zone of product falls through the fuel and hits the
water base at the bottom of or elsewhere in the tank.

37
 The water boils, turns to steam and pushes up through the fuel above.
 The result is a massive eruption of tank contents that can spread to several
tank diameters away from the tank.

Slop over

A slop over is the minor frothing that occurs when water applied to the fire as
foam solution boils and turns to steam. The oil must be viscous and its fluid
temperature must exceed the boiling point of water. Since only the surface oil is
involved, a slop over is a relatively mild occurrence.

 Slop over can occur when firewater or foam is introduced into hot oil.
 The water boils and causes the hot oil to froth up and slop out of the top of
the tank.
 This type of event may lead to a bund fire, as well as the initial tank fire.

Froth over

A froth over is the overflowing of a tank that large quantity of foam applied,
particularly when non-aspirated can cause significant froth over events, when
water (or volatile hydrocarbon) boils under the surface of viscous hot oil.

 Product may also boil within a tank.


 This can occur when a tank is engulfed and heated by a bund fire.
If the product has a low boiling point, it is possible to raise its temperature above
it boiling point, leading to the generation of large amounts of fuel vapour, which
may cause frothing of product out of the tank.

38
SELECTION OF A TANK:
A Storage tank is selected on the basis of the vapor pressure of the product to
be stored in the tank. The various types of storage tanks along with the vapor
pressure of the product to be stored is mentioned below:

VAPOR
TANK TYPE PRESSURE
(In Kg/ Cm^2)

CONE ROOF < 0.05

FLOATING ROOF 0.05-0.85

INTERNAL
FLOATING ROOF 0.05-0.85

DOME ROOF 0.85-1.06

HORTON SPHERE >1.06

 DESIGN AND CONSTRUCTIONAL CODES:

 API standard 650:Welded steel tanks for oil storage


 API standard 620:Design and construction of large, welded low pressure
storage tanks.
 IS – 803:Welded steel storage tanks for Oil Storage
 BS – 2564: Vertical steel welded storage tanks with butt welded shell for
petroleum industries.

39
MAJOR FIRES AT STORAGE TANKS

1.CARIBBEAN PETROLEUM TANK TERMINAL EXPLOSION &


MULTIPLE TANK FIRES (GASOLINE TANK EXLOSION):

 INCIDENT SUMMARY:

On the night of October 23, 2009, a large explosion occurred at the Caribbean
Petroleum Corporation (CAPECO) facility in Bayamon, Puerto Rico, during
offloading of gasoline from a tanker ship, the Cape Bruny, to the CAPECO tank
farm onshore. A 5-million gallon above ground storage tank (AST) overflowed
into a secondary containment dike. The gasoline spray aerosolized, forming a
large vapor cloud, which ignited after reaching an ignition source in the
wastewater treatment (WWT) area of the facility. The blast and fire from multiple
secondary explosions resulted in significant damage to 17 of the 48 petroleum
storage tanks and other equipment onsite and in neighborhoods and businesses
offsite. The fires burned for almost 60hours. Petroleum products leaked into the
soil, nearby wetlands and navigable waterways in the surrounding area.

40
 CHRONOLOGY OF EVENTS:

 On Wednesday, October 21, 2009, the Cape Bruny cargo ship arrived at
the CAPECO dock in San Juan Bay to unload CAPECO’s near-weekly
shipment of more than 11.5 million gallons of unleaded gasoline.

 Only Tank 107 with a capacity of 21 million gallons was large enough to
hold a full shipment of gasoline, but it was already holding product. As a
result, CAPECO planned to pump the gasoline shipment to four smaller
storage tanks (405, 504, 409, and 411) and the balance to Tank 107,
expecting the filling to take more than 24 hours.

 At approximately 6:30 p.m., the operator manually calculated that Tank


409 would reach maximum fill sometime between 9 p.m. and 10 p.m.,
since the level indicators were malfunctioned & physically stocked.

 To avoid complications during shift change, the operator fully opened the
valve on Tank 411 and almost completely closed the valve on Tank 409.

 At 10 p.m., as Tank 411 reached maximum capacity and was closed,


operators fully opened the valve on Tank 409. One operator then read the
level on the Tank 409 side gauge (that was malfunctioned) and reported it
to his supervisor, who estimated that the tank would be full at 1 a.m.

 However, between the 11 p.m. and 12 a.m. check, Tank 409 began to
overflow. At the 12 a.m. check, operations staff noticed a fog on the ground
and on the road along Tanks 504, 411 and 409. Fuel gushed from the vents,
creating a spray of gasoline that formed a vapour cloud and pooled in the
secondary containment dike.

 At midnight, the tank farm operator started to perform the hourly check of
Tank 409, but before reaching the tank, he observed a vapour cloud and a
strong smell of gasoline. He contacted the dock operator to halt the flow of
gasoline to the tank and notified the WWT operator.

 Even though there was lack of illumination, they observed a white fog
approximately 3 feet above the ground but could not hear or see gasoline
overflowing from the vents on the tank 409 due to lack of lightning &
topography of the tank farm.

41
 Noting the potential danger, one of the operators was sent to the security
gate, while another operator drove around the facility attempting to find
the source of the leak and developing vapour cloud.

 At 12:23 a.m., on October 23, 2009, security cameras at CAPECO and


neighbouring facilities recorded the ignition of the vapour cloud in the
WWT area. About seven seconds after ignition, the vapour cloud exploded,
creating a pressure wave that damaged hundreds of homes and businesses
up to 1.25 miles from the site. The fire propagated through the vapour cloud
and ignited multiple subsequent tank explosions registering 2.9 on the
Richter scale.

NOTE: On the night of the incident, the transmitter on Tank 409was not
sending level data measurements to the computer. CAPECO operators often
did not rely on the information displayed on the computer because the
transmitters were frequently out of service.

KEY FINDINGS:

Physical Causes

1) The topography of the tank farm allowed the gasoline vapor cloud to
migrate through open dike valves to low-lying areas of the tank farm and
to the storm water retention pond in the wastewater treatment area, where
it ignited.

2) Multiple physical causes likely contributed to Tank 409 overfill:

 Malfunctioning of the tank side gauge or the float and tape apparatus
during filling operations led to recording of inaccurate tank levels;

 Normal variations in the gasoline flow rate and pressure from the Cape
Bruny without the facility’s ability to identify and incorporate the flow
rate change in real time into tank fill time calculations may have
contributed to the overfill;
 Potential failure of the tank’s internal floating roof due to turbulence and
other factors may have contributed to the overfill.

42
Control and Monitoring Failures

1) Inadequate tank filling procedures.

2) CAPECO’s normal filling operations required that operators partially open


the intake valve to a tank while filling another tank, because the pressure
in the pipeline from the dock made manually opening a fully closed valve
difficult. This inefficiency increased the potential error in fill time
calculations.

3) Unreliable tank gauging equipment.

Safety Management Systems

1) Tanks were not equipped with an independent high-level alarm system.

2) Tanks were not equipped with an independent Automatic Overfill


Prevention System for terminating transfer operations.

Human Factors

1) The design of the dike valve system made it difficult to distinguish between
open and closed valve positions.

2) Insufficient lighting in the tank farm areas hindered operators from


observing the overfilling of Tank 409 and the subsequent vapor cloud
formation.

Lack of Reporting Requirements

1) An incomplete national incident database for assessing the frequency of


specific types of incidents at bulk petroleum storage tank terminals inhibits the
development and implementation of more tailored regulatory requirements,
industry consensus standards, and best practices in this sector.

Emergency Response Findings

1) CAPECO and the local fire department lacked sufficient firefighting


equipment to effectively fight and control a fire involving multiple tanks
because they are not required to conduct a risk analysis where they have to

43
consider and plan for the potential of a vapour cloud explosion involving
multiple tanks.

2) CAPECO did not pre plan with local emergency responders or adequately
train facility personnel to deal with a fire involving multiple tanks.

3) Local fire departments lacked sufficient training and resources to respond


to industrial fires and explosion.

4) A lack of coordination among the 43 federal, commonwealth and non-


governmental Organizations that responded to the CAPECO incident
further complicated the emergency response.

 RECOMMENDATIONS

To prevent a similar incident from occurring, the CSB recommends policy


changes to the following regulatory agencies, consensus, and industry
standard-making bodies:

United States Environmental Protection Agency (EPA)


United States Occupational Safety and Health Administration (OSHA)
American Petroleum Institute (API)
International Code Council (ICC)
National Fire Protection Association (NFPA)

44
Environmental Protection Agency (EPA)

Revise where necessary the Spill Prevention, Control and Countermeasure


(SPCC); Facility Response Plan (FRP); and/or Accidental Release Prevention
Program (40 CFR Part 68) rules to prevent impacts to the environment and/or
public from spills, releases, fires, and explosions that can occur at bulk
aboveground storage facilities storing gasoline, jet fuels, blend stocks, and other
flammable liquid having an NFPA 704 flammability rating of 3 or higher. At a
minimum, these revisions shall incorporate the following provisions:

1.) Ensure bulk above ground storage facilities conduct and document a risk
assessment that takes into account the following factors:

 The existence of nearby populations and sensitive environments;


 The nature and intensity of facility operations;
 Realistic reliability of the tank gauging system; and
 The extent/rigor of operator monitoring

2.) Equip bulk aboveground storage containers/tanks with automatic overfill


prevention systems that are physically separate and independent from the tank
level control systems.

3.) Ensure these automatic overfill prevention systems follow good engineering
practices.

4.) Engineer, operate, and maintain automatic overfill prevention systems to


achieve appropriate safety integrity levels in accordance with good
engineering practices.

5.) Regularly inspect and test automatic overfill prevention systems to ensure
their proper operation in accordance with good engineering practice.

6.) Conduct a survey of randomly selected bulk aboveground storage containers


storing gasoline or other NFPA 704 flammability rating of 3 or higher at
terminals in high risk locations (such as near population centres or sensitive
environments) that are already subject to the Spill Prevention, Control and
Countermeasure (SPCC) and/or Facility Response Plan (FRP) rules to
determine:

 The nature of the safety management systems in place to prevent


overfilling a storage tank during loading operations. Analysis of the safety
management systems should include equipment, training, staffing,
operating procedures and preventative maintenance programs.
45
 The extent to which terminals use independent high level alarms,
automated shutoff/diversion systems, redundant level alarms or other
technical means to prevent overfilling of a tank) The history of overfilling
incidents at the facilities, with or without consequence.

 Whether additional reporting requirements are needed to understand the


types of incidents leading to overfilling spills that breach secondary
containment and have the potential to impact the environment and/or the
public, as well as the number of safeguards needed to prevent them.

Occupational Safety and Health Administration (OSHA)

1.) Revise the Flammable and Combustible Liquids standard (29 CFR§
1910.106) to require installing, using, and maintaining a high-integrity
automatic overfill prevention system with a means of level detection,
logic/control equipment, and independent means of flow control for bulk
aboveground storage tanks containing gasoline, jet fuel, other fuel mixtures
or blend stocks, and other flammable liquids having an NFPA 704
flammability rating of 3 or higher, to protect against loss of containment.
At a minimum, this system shall meet the following requirements:

 Separated physically and electronically and independent from the tank


gauging system.

 Engineered, operated, and maintained to achieve an appropriate level of


safety integrity in accordance with the requirements of Part1of International
Electro technical Commission (IEC) 61511-SER ed1.0B-2004,
Functional Safety – Safety Instrumented Systems for the Process Industry Sector.
Such a system would employ a safety integrity level (SIL) documented in
Accordance with the principles in Part 3 of IEC 61511-SER ed1.0B-2004,
Accounting for the following factors:

i. The existence of nearby populations and sensitive environments;


ii. The nature and intensity of facility operations;
iii. Realistic reliability for the tank gauging system; and
iv. The extent/rigor of operator monitoring.

 Proof tested in accordance with the validated arrangements and procedures


with sufficient frequency to ensure the specified safety integrity level is
maintained.

46
2.) Establish hazard analysis, management of change and mechanical integrity
management system elements for bulk above ground storage tanks in the
revised 1910.106 standard that are similar to those in the Process Safety
Management of Highly Hazardous Chemicals standard (29 CFR
§1910.119) and ensure these facilities are subject to Recognized and
Generally Accepted Good Engineering Practices (RAGAGEP).

International Code Council (ICC)

Revise the Section 5704.2.7.5.8 (2015), Overfill Prevention of the International


Fire Code (IFC) to require an automatic overfill prevention system (AOPS) for
bulk aboveground storage tank terminals storing gasoline, jet fuel, other fuel
mixtures or blend stocks, and other flammable liquids having an NFPA 704
flammability rating of 3 or higher, or equivalent designation. These safeguards
shall meet the following requirements:

1.) Engineered, operated, and maintained to achieve an appropriate safety


integrity level in accordance with the requirements of Part 1 of
International Electro technical Commission (IEC) 61511-SER ed1-2004,
Functional Safety – Safety Instrumented Systems for the Process Industry
Sector.

2.) Specified to achieve the necessary risk reduction as determined by a


documented risk assessment methodology in accordance with Centre for
Chemical Process Safety Guidelines for Hazard Evaluation Procedures,
3rd Edition, accounting for the following factors:

i. The existence of nearby populations and sensitive environments;


ii. The nature and intensity of facility operations;
iii. Realistic reliability for the tank gauging system; and
iv. The extent/rigor of operator monitoring.

3.) Proof tested in accordance with the validated arrangements and procedures
with sufficient frequency to maintain the specified safety integrity level.

4.) Ensure that the above changes are not subject to grandfathering provisions
in the codes.

47
National Fire Protection Association (NFPA)

Revise NFPA 30, Flammable and Combustible Liquids Code, Section 21.7.1.1
(2015) for bulk aboveground storage tank terminals storing gasoline, jet fuel,
other fuel mixtures or blend stocks, and other flammable liquids having an NFPA
704 flammability rating of 3 or greater. This modification shall meet the
following requirements:

1) More than one safeguard to prevent a tank overfill, all within an automatic
overfill prevention system as described in ANSI/API Standard 2350 (2015)
Overfill
Protection for Storage Tanks in Petroleum Facilities with an independent level
alarm as one of the safeguards. The safeguards should meet the following
standards:

 Separated physically and electronically and independent from the tank


gauging system;
 Engineered, operated, and maintained for an appropriate level of safety
based on the predetermined risk level after considering part b of this
Recommendation; and
 Proof tested with sufficient frequency in accordance with the validated
arrangements and procedures.

2.) Specified to achieve the necessary risk reduction as determined by a


documented risk assessment methodology conducted in accordance with
Centre for Chemical Process Safety Guidelines for Hazard Evaluation
Procedures, 3rd Edition, accounting for the following factors:

 The existence of nearby populations and contamination of nearby


Environmental resources;
 The nature and intensity of facility operations;
 Realistic reliability for the tank gauging system; and
 The extent/rigor of operator monitoring.

3.) Ensure that the above changes not subject to grandfathering provisions in the
code.

48
American Petroleum Institute (API)

Revise ANSI/API 2350, Overfill Protection for Storage Tanks in Petroleum


Facilities (2015), to require the installation of an automatic overfill
prevention systems for existing and new facilities at bulk aboveground storage
tanks storing gasoline, jet fuel, other fuel mixtures or bloodstocks, and other
flammable liquids having an NFPA 704 flammability rating of 3 or higher. At a
minimum, this system shall meet the following requirements:

1.) Separated physically and independent from the level control and
monitoring system.

2.) Engineered, operated, and maintained to achieve an appropriate safety


integrity level in accordance with the requirements of Part 1 of
International Electro technical Commission (IEC) 61511-SER ed1-2004,
Functional Safety – Safety Instrumented Systems for the Process Industry
Sector.

3.) Specified to achieve the necessary risk reduction as determined by a


documented risk assessment methodology set in accordance with Centre
for Chemical Process Safety Guidelines for Hazard Evaluation
Procedures, 3rd Edition, accounting for the following factors:

 The existence of nearby populations and contamination of nearby


Environmental resources;
 The nature and intensity of facility operations;
 Realistic reliability for the tank gauging system; and
 The extent/rigor of operator monitoring.

4.) Proof tested with sufficient frequency in accordance with the validated
arrangements and procedures to maintain the required safety integrity
level.

49
2.MOTIVA ENTERPRISES, DELWARE:( H2SO4 TANK EXPLOSION)

 INCIDENT SUMMARY:

On July 17, 2001, an explosion occurred at the Motiva Enterprises LLC Delaware
City Refinery (DCR) in Delaware City, Delaware. Jeffrey Davis, a boilermaker with
The Washington Group International, Inc. (WGI), the primary maintenance
contractor at DCR, was killed; eight others were injured. A crew of WGI contractors
was repairing grating on a catwalk in a sulphuric acid (H2SO4) storage tank farm
when a spark from their hot work ignited flammable vapours in one of the storage
tanks. The tank separated from its floor, instantaneously releasing its contents. Other
tanks in the tank farm also released their contents. A fire burned for approximately
one-half hour; and H2SO4 reached the Delaware River, resulting in significant
damage to aquatic life.

 CHRONOLOGY OF EVENTS:

 SO2 vapours from the storage tanks combined with moisture in the air to form
sulphurous acid (H2SO3), which was causing the deterioration of the catwalk.

 In late June 2000, boilermakers from The Washington Group International,


Inc. (WGI), the primary maintenance contractor at DCR, were repairing the
weakened and corroded catwalk at the acid tank farm.

 The catwalk was located at the roof level of the storage tanks. It provided
access to the gauge hatch used to physically measure the tank level and to
various nozzles and instruments.

 On July 17, 2001, four WGI boilermakers and their foreman received their
assignment for the day, via a work order, to continue the job of replacing the
grating on the catwalks in the acid tank farm.
 The permit allowed them to burn/weld and grind “on tank 396” (which was
understood to mean the catwalk grating at tank 396) and gave instructions to
stop hot work immediately if hydrocarbons were detected.
 Two of the boilermakers started out on the ground setting up equipment and
then turned on the welding machine and came up onto the catwalk. After

50
trying the oxy-acetylene cutting torch, they decided to use air carbon arc
gouging because the torch was not hot enough to cut through rust on the
corroded grating.
 There was no communication between WGI and Motiva when WGI switched
from oxy-acetylene to air carbon arc gouging, and a Motiva hot work
requirement for “absolute spark control” was not observed.
 During the morning of July 17, portions of the grating around tank 396 were
removed and replaced. The workers were ready to start working from tank
393 back toward tank 396 when they broke for lunch at noon.
 The boilermaker working the air gouging equipment was kneeling and cutting
out the first piece of grating above tank 393. The second boilermaker on the
platform was standing south of 393 and had his back turned. He reported that
he felt a high pressure burst of air and turned to see his coworker stand up as
tank 393 began to lift off its foundation pad and collapse toward the north,
pulling down the catwalk.
 The second boilermaker turned and ran to the south; he was starting down the
steps at tank 392 when the explosion occurred and he met another coworker,
who was coming up the stairs. Together they fell down the stairs and then
helped each other exit the dike.

 KEY FINDINGS:

 Hot work was conducted in vicinity of the tank with holes.


 A leak in the shell of tank 393, observed in May 2001, was not repaired.
Instead, the tank liquid level was lowered below the leak point and the tank
remained in service.
 Tank holes allowed the contact between flammable vapors and sparks from
hot work
 The vapor space of the tank was not adequately inerted. Design deficiencies
provided an insufficient flow of CO2 to keep the inert atmosphere below the
flammable range.
 Lack of communication from area management about holes in the tank.
Contract maintenance workers were not aware of holes in the tank.

51
 The change from oxyacetylene to carbon arc gouging didn’t contain spark. No
fire blankets were provided to contain the sparks.
 Water ingress from rain and humidity in the tank due to holes led to higher
corrosion rates than from the acid alone.
 The holes in the tank were due to corrosion that allowed air in and flammable
vapors out.
 The repeated recommendations of the tank inspectors that the tank should be
taken out of service as soon as possible were unheeded.
 The CO2 inerting supply to tank 393, installed in 2000, was incapable of
maintaining a nonflammable atmosphere.

Side of tank 393 showing series of patches.

52
Tank 393, collapsed at northeast corner of storage tank dike.

 RECOMMENDATIONS:

1. Occupational Safety and Health Administration:


Ensure coverage under the Process Safety Management Standard (29
CFR 1910.119) of atmospheric storage tanks that could be involved in
a potential catastrophic release as a result of being interconnected to a
covered process with 10,000 pounds of a flammable substance.(2001-
05-I-DE-R1)

2. Delaware Department of Natural Resources and Environmental


Control:
Ensure that regulations developed for the recently enacted Jeffrey
Davis Aboveground Storage Tank Act require that facility management
take prompt action in response to evidence of tank corrosion that
presents hazards to people or the environment. (2001- 05-I-DE-R2)

53
3. Motiva Enterprises, Delaware City Refinery:

 Implement a system to ensure accountability for mechanical integrity


decision making. (2001-05-I-DE-R3) Include the following specific
items:
i. Review of inspection reports by subject area experts, such as
metallurgists or equipment design engineers, to ensure adequate
analysis of failure trends and suitability for intended service.
ii. Establishment of a planning system to ensure the timely repair
of equipment.

The Center for Chemical Process Safety (CCPS) publication, Plant


Guidelines for Technical Management of Chemical Process Safety,
Chapter 3, “Accountability Objectives and Goals,” presents a model for
such a system.

 Review the design of existing tankage that contains or has the potential
to contain flammables to ensure that, at a minimum (2001-05-I-DE-
R4):

i. Inerting systems are installed where appropriate and are


adequately sized and constructed.

ii. Emergency venting is provided.

 Ensure that management of change reviews are conducted for changes


to tank equipment and operating conditions, such as (2001-05-I-DE-
R5):

i. Tank service and contents

54
ii. Tank peripherals, such as inerting and venting
systems.

 Revise the refinery hot work program to address the circumstances that
require use of continuous or periodic monitoring for flammables.
(2001-05-I-DE-R6)

 Upgrade the refinery Unsafe Condition Report system to include the


following (2001-05-I-DE-R7):

i. Designation of a specific manager with decision-


making authority to resolve issues.
ii. Establishment of a mechanism to elevate attention
to higher levels of management if issues are not
resolved in a timely manner.
iii. Identification of a means to ensure communication
of hazards to all potentially affected personnel.

4. American Petroleum Institute (API) :

 Work with NACE International (National Association of Corrosion


Engineers) to develop API guidelines to inspect storage tanks containing fresh
or spent H2SO4 at frequencies at least as often as those recommended in the
latest edition of NACE Standard RP 0294-94, Design, Fabrication, and
Inspection of Tanks for the Storage of Concentrated Sulfuric Acid and Oleum
at Ambient Temperatures. (2001-05-I-DE-R10).

 Revise API tank inspection standards to emphasize that storage tanks with
wall or roof holes or thinning beyond minimum acceptable thickness that may
contain a flammable vapor are an imminent hazard and require immediate
repair or removal from service. (2001-05-I-DE-R11)

 Ensure that API recommended practices address the inerting of flammable


storage tanks, such as spent H2SO4 tanks. Include the following (2001-05-I-
DE-R12):

i. Circumstances when inerting is recommended.

55
ii. Design of inerting systems, such as proper sizing of inerting
equipment, appropriate inerting medium, and instrumentation,
including alarms.

 Communicate the findings and recommendations of this report to your


membership. (2001-05-I-DE-R13)

5. NACE International (National Association of Corrosion


Engineers):

 Work with the American Petroleum Institute to develop API guidelines to


ensure that storage tanks containing fresh or spent H2SO4 are inspected at
frequencies at least as often as those recommended in the latest edition of
NACE Standard RP 0294- 94, Design, Fabrication, and Inspection of Tanks
for the Storage of Concentrated Sulfuric Acid and Oleum at Ambient
Temperatures. (2001-05-I-DE-R14)

 Communicate the findings and recommendations of this report to your


membership.
(2001-05-I-DE-R15)

3.HERRIG BROTHERS FEATHER CREEK FARM


(PROPANE TANK EXPLOSION)

 INCIDENT SUMMARY:

An 18000gallon propane tank exploded because of propane vapor leaked from the
damaged vapor line and liquid propane pipeline that rapidly changed into vapor that
ignited after reaching the direct fired vaporizers, the reason of the accident being
hitting of the pipelines by ATV.The explosion killed two volunteer fire fighters and
injured seven other emergency response personnel. Several buildings were also
damaged by the blast.

56
 CHRONOLOGY OF EVENTS:

 On the evening of the incident, eight high-school-aged teens gathered at the


farm for a party. According to one of the co-owners of the farm, the youths
had attended similar social gatherings at the farm on other dates, but with
neither the knowledge nor the consent of the owners. Neither owner lived at
the farm.

57
 At approximately 11:00 pm, one of the youths began driving an all-terrain
vehicle (ATV) around the farm. Then the driver of the ATV picked up a
passenger and continued his ride. The ATV was heading east between the
propane tank and a turkey barn when it struck two aboveground propane pipes
(liquid and vapor lines) that ran parallel to one another from the propane tank
to direct-fired vaporizers approximately 37 feet to the north of the tank.

 The ATV damaged both the liquid and vapour lines. The liquid line (which
measured approximately ¾-inch inside diameter) was completely severed
from the tank at the location where it was connected to a manual shut-off valve
directly beneath the tank. An excess flow valve protecting the liquid line failed
to function, and propane leaked
out of the tank at the point of the break.

 As the liquid propane sprayed out of the tank, it rapidly changed to vapour.
Propane vapour may have also leaked from the damaged vapour line. Within
a few minutes, propane from the damaged lines ignited, most likely when it
reached one of the direct-fired vaporizers approximately 37 feet away.

 At approximately 11:28 pm, as fire-fighting equipment was being moved into


position, the tank exploded, scattering metal tank fragments in all directions.
One large piece of the tank travelled in a northwest direction, striking and
killing two volunteer firemen. Seven other emergency personnel sustained
injuries as a result of the explosion.

NOTE: The explosion that occurred was a BLEVE.

 KEY FINDINGS& ROOT CAUSES:

 The explosion that occurred at the farm is known as a Boiling Liquid


Expanding Vapor. Explosion or BLEVE. A BLEVE can occur when a
pressure vessel containing a Flammable liquid, like a propane tank, is exposed
to fire.

 In this incident, the tank was engulfed in flames due to a leak of propane under
the tank. These flames created the conditions that produced the BLEVE.
Neither the propane tank nor its aboveground piping was protected by a fence or any
other physical barrier designed to prevent damage from vehicles.

58
The propane tank was equipped with an excess flow valve to protect the tank’s liquid
line Leading to the vaporizers. In the event of a complete break in the liquid line
downstream from the valve, it was designed to close and greatly reduce the flow of
propane from the broken pipe. (Even when an excess flow valve is activated, a small
amount of fluid bleeds through a tiny hole in the valve. Consequently, installation of
a shut-off valve immediately downstream from the excess flow valve is required to
stop all flow.)
 When the ATV severed the liquid line at this installation, however, the excess
flow valve failed to close because the flow capacity of the outlet piping system
downstream of the valve was less than the closing rating of the excess flow
valve installed in the tank. Fire fighters were positioned too close to the
burning propane storage tank when it exploded. They believed that they would
be protected from an explosion if they avoided the ends of the tank.

 The propane storage and handling system was installed at the farm in 1988.
When the tank system was installed, Iowa law provided that the 1979 edition
of the National Fire Protection Association’s Standard for the Storage and
Handling of Liquefied Petroleum Gases (NFPA58) governed the installation.

 Under NFPA 58 and other relevant Iowa law, the State Fire Marshal should
have received a plan of the farm’s propane tank storage and handling system
before it was installed. Iowa law, however, did not specifically designate
which party –the owner or the installer of a large propane storage facility --
was required to notify the State Fire Marshal.

 The CSB’s investigation revealed that the State Fire Marshal had no record of
the system and that it was not installed in compliance with all NFPA 58
requirements adopted as Iowa law.

59
 ROOT CAUSES OF THE ACCIDENT:

1. Protection for aboveground piping was inadequate.

Two aboveground pipes (liquid and vapor lines) that ran from the propane storage
tank to its vaporizers were not protected from potential physical damage from
vehicles. Lack of piping protection allowed a vehicle to crash into these pipes,
breaking them and releasing the propane that ignited.

2. The diameter of the pipe downstream from an excess flow valve was too
narrow, which prevented the valve from functioning properly.

An excess flow valve that was designed to stop the flow of all but an extremely small
amount of liquid propane in the event of a severed line did not function because the
diameter of the pipe downstream from the valve was too narrow to allow the valve
to activate. Post-incident tests of the valve showed that it would have operated as
designed if the pipe downstream had been the proper size. A functioning excess flow
valve on the liquid line would have greatly reduced the severity of the fire that
engulfed the tank. This likely would have prevented the BLEVE.

3.Fire fighter training for responding to BLEVEs was inadequate.

Some training materials provided to the fire fighters led them to believe that they
would be protected from a propane tank explosion by positioning themselves to the
sides of the tank and by avoiding the areas extending from the two ends of the tank.
As a Consequence, fire fighters were positioned too close to the sides of the burning
propane Storage tank when it exploded. Fire fighters did not adequately recognize
the potential For a BLEVE and that a BLEVE can scatter tank fragments in all
directions. In this incident, flying tank fragments from the explosion killed two fire
fighters located Approximately 100 feet from the side of the tank.

4. The State Fire Marshal did not detect deficiencies in the design and
installation of the propane storage facility.

Under Iowa law, the State Fire Marshal should have received a plan of the farm’s
propane system prior to its installation in 1988. The State Fire Marshal had no record
of the farm’s system, however. Iowa law did not specifically designate which party
-- the owner or the installer of a large propane tank facility was required to notify
the State Fire Marshal. In addition, the State Fire Marshal did not have a program in
place to adequately monitor or inspect large propane storage facilities.

60
 RECOMMENDATIONS:

Herrig Brothers Farm

1. Install protection (i.e., fencing or barricades) to protect aboveground propane


pipes from possible damage from vehicles.

2. Install properly sized propane outlet piping from excess flow valves.

Iowa State Fire Marshal

Develop a program to ensure implementation of the requirements of the National


Fire Protection
Association’s NFPA 58 Standard for the Storage and Handling of Liquefied
Petroleum Gases, as adopted by Iowa law. Ensure that this program includes, at a
minimum, the following elements:

 Designation by regulation of the party (such as a facility owner or installer)


who is responsible for submitting planned construction or modification
documents to the State Fire Marshal; Procedures for approving the plans for
new or modified installations; Procedures governing the issuance and posting
of permits authorizing the use of equipment; and on-site inspections of new,
modified, and existing propane and other Liquefied Petroleum Gas storage
facilities that are covered by Iowa state law.

Fire Service Institute of Iowa State University

Ensure that fire fighter training materials address proper response procedures for
BLEVEs.

National Propane Gas Association (NPGA)

61
1. Ensure that fire fighter training materials address proper response procedures for
BLEVEs.

2Distribute the CSB findings and recommendations in this report to NPGA


members.

4.BETHUNE POINT WASTEWATER TREATMENT


PLANT
(Methanol Tank Explosion & Fire):
 INCIDENT SUMMARY:

On January 11, 2006, an explosion and fire occurred at the City of Daytona Beach,
Bethune Point Wastewater Treatment Plant (Bethune Point WWTP) in Daytona
Beach, Florida, killing two employees and severely burning a third. The Bethune
Point WWTP processes wastewater using a treatment that requires the addition of
methanol, a highly flammable liquid. The methanol is stored in an aboveground
storage tank. The maintenance workers using a cutting torch on a roof above the
methanol storage tank accidentally ignited vapours coming from the tank vent. The
flame flashed back into the storage tank, causing an explosion inside the tank that
precipitated multiple methanol piping failures and a large fire that engulfed the tank
and workers.

Location of man-lift basket and 4-inch vent pipe


62
 CHRONOLOGY OF EVENTS:

 In 2004 and 2005, several hurricanes damaged the Bethune Point WWTP,
including two metal roofs used to shade two chemical storage areas.

 Facility personnel removed one of the damaged metal roofs in 200 without
incident. The second metal roof, installed over the methanol storage tank, was
about 30 feet above the ground and more difficult to access.

 In consultation with the facility superintendent, the lead mechanic determined


that facility personnel could remove the second damaged metal roof using a
city owned crane and a rented man-lift. The lead mechanic planned the job to
remove the metal roof. The facility superintendent did not review details of
the job and possible hazards.

 On Monday, January 9, 2006, the lead mechanic and a mechanic prepared to


remove the metal roof. They retrieved the man-lift and crane from other city
facilities. The lead mechanic then familiarized himself with the operation of
the man-lift. Workers at the Bethune Point WWTP had previously used the
city crane and were familiar with its operation.

 On Tuesday, January 10, 2006, the lead mechanic, the mechanic, and a third
worker began removing the metal roof over the methanol storage tank.
Standing in the man-lift, the lead mechanic and mechanic cut the metal roof
into sections with an oxy-acetylene cutting torch and attached the cut sections
to the crane hook. The third worker operated the crane to lower the cut
sections to the ground. While cutting the metal roof, sparks from the torch
ignited a grass fire. The crane operator extinguished the grass fire with a
garden hose. In the early afternoon, the workers ran out of oxygen for the
cutting torch and stopped work for the day. The lead mechanic ordered
another oxygen cylinder so the job could resume on Wednesday.

 On Wednesday, January 11, 2006, three workers continued the roof removal.
About 11:15 a.m., the lead mechanic and the third worker were cutting the
metal roof directly above the methanol tank vent. Sparks, showering down
from the cutting torch, ignited methanol vapour’s coming from the vent,

63
creating a fireball on top of the tank. The fire flashed through a flame arrester
on the vent, igniting methanol vapour’s and air inside the tank, causing a
explosion inside the steel tank.

 The explosion inside the methanol storage tank


•Rounded the tank’s flat bottom, permanently deforming the tank and raising the
side wall about one foot;
•ripped the nuts from six bolts used to anchor the tank to a concrete foundation;
•blew the flame arrester off the tank vent pipe;
•blew a level sensor off a 4-inch flange on the tank top;
•separated two 1-inch pipes, valves, and an attached level switch from flanges on the
side of the tank;
•separated a 4-inch tank outlet pipe from the tank outlet valve; and
•separated a 4-inch tank fill pipe near the top the tank.

 KEY FINDINGS:

 The City of Daytona Beach has no program, written or otherwise, to control


hot work at city facilities.
 The CSB found no evidence that workers at the Bethune Point WWTP
received any methanol hazard training in the last 10 years.
 The City of Daytona Beach does not require work plan reviews to evaluate
the safety of non-routine tasks.
 OSHA 1910.106 permits the use of plastic piping in flammable liquid piping
systems when necessary but does not define necessary.
 NFPA 30 permits the use of plastic piping in flammable liquid piping systems
under certain conditions.
 The methanol tank did not comply with NFPA 30. Valves and their
connection to the tank were PVC instead of steel.
 The failure of the PVC piping attached to the tank and in the methanol, system
greatly increased the consequences of the incident.
 Flame arrester maintenance requirements were not included in the operation
and maintenance manual for the methanol system.
 An aluminium flame arrester was installed on the methanol tank; methanol
corrodes aluminium.
 The flame arrester was not inspected or cleaned since its installation in 1993.
 The flame arrester was so degraded (gaps between the plates inside the flame
arrester were plugged with dirt and aluminium oxide and portions of the

64
plates were corroded away) that it did not prevent a flame from entering the
tank which greatly increased the consequences of the incident.
 No Florida state laws or regulations exist to require municipalities to
implement safe work practices.
 No Florida state laws or regulations exist to require municipalities to
communicate chemical hazards to municipal employees.
 Florida municipalities are not covered by OSHA workplace safety standards.
 No state or federal oversight of public employee safety exists in the State of
Florida.

Root Causes

The City of Daytona Beach


1. did not implement adequate controls for hot work at the Bethune Point WWTP;
and
2. had an ineffective HAZCOM program

Contributing Causes

1. The City of Daytona Beach has no systematic program to evaluate the safety of
non-routine tasks.
2. The aboveground piping and valves in the methanol system were constructed of
PVC in lieu of steel.
3. An aluminium flame arrester was installed on the methanol tank even though
methanol is known to corrode aluminium.
4. The operation and maintenance manual for the Bethune Point WWTP did not
include are acquirement to maintain the flame arrester.

 RECOMMENDATIONS

The CSB makes recommendations based on the findings and conclusions of the
investigation. Recommendations are made to parties that can affect change to
prevent future incidents, which may include the facility where the incident occurred,
the parent company, industry organizations responsible for developing good practice
guidelines, regulatory bodies, and/or organizations that have the ability to broadly
communicate lessons learned from the incident, such as trade associations and labor
unions.

65
Governor and Legislature of the State of Florida
2006-03-I-FL-R1
 Enact legislation requiring state agencies and each political
subdivision (i.e. counties and municipalities) of Florida to
implement policies, practices, procedures, including chemical
hazards covering the workplace health and safety of Florida public
employees that are at least as effective as OSHA.
 Establish and fund a mechanism to ensure compliance with these
standards. Consider legislation providing coverage of Florida public
employees under an occupational safety and health program in
accordance with Section 18(b) of the Occupational Safety and
Health Act of 1970, and Code of Federal Regulations 29 CFR
1956.1. 2006-03-I-FL-R2
 Develop and fund a workplace safety and health consultation
program for Florida public employees similar to the private sector
program currently administered by the Florida Safety Consultation
Program at the University of South Florida.

City of Daytona Beach


2006-03-I-FL-R3
 Adopt city ordinances to require departments to implement policies,
practices, and procedures concerning safety and health in the
workplace for city employees that are at least as effective as relevant
OSHA standards. Emphasize compliance with chemical standards,
including hot work procedures (OSHA Welding, Cutting, and
Brazing Standard, Sections 1910.251 and 1910.252) and chemical
hazard communication (OSHA Hazard Communication Standard
29 CFR 1910.1200). Implement procedures to ensure compliance
with these policies, practices and procedures.

2006-03-I-FL-R4

66
 Ensure that flammable liquid storage tanks used throughout the city
comply with NFPA 30 and minimum federal standards in 29 CFR
1910.106, including appropriate piping and flame arresters.

National Fire Protection Association


2006-03-I-FL-R5
 Revise NFPA 30 to specifically exclude the use of thermoplastics
in aboveground flammable liquid service.

U.S. Department of Labor, Occupational Safety and Health Administration

2006-03-I-FL-R6

 Revise 29 CFR 1910.106 to specifically exclude the use of


thermoplastics in aboveground flammable liquid service.
Water Environment Federation
2006-03-I-FL-R7
 Work with the Methanol Institute to prepare and distribute a
technical bulletin containing information on the safe receipt,
storage, use, and dispensing of
methanol in wastewater treatment plants. In addition, include
information on basic fire and explosion prevention measures when
using bulk methanol (e.g., flame arrester maintenance, hot work
programs, electrical classification).

2006-03-I-FL-R8

 Work with the Methanol Institute to prepare safety training


materials for wastewater treatment facilities that use methanol.

Methanol Institute

2006-03-I-FL-R9

 Work with the Water Environment Federation to prepare and


distribute a technical bulletin containing information on the safe
receipt, storage, use, and dispensing of methanol in wastewater

67
treatment plants. In addition, include information on basic fire and
explosion prevention measures when using bulk methanol (e.g.,
flame arrester maintenance, hot work programs, electrical
classification).

2006-03-I-FL-R10
 Work with the Water Environment Federation to prepare safety
training materials for wastewater treatment facilities that use
methanol.

5.ALLIED TERMINALS: (LIQUID FERTILIZER TANK


FAILURE)

 INCIDENT SUMMARY

On November 12, 2008, a 2-million-gallon liquid fertilizer tank (designated as Tank


201 by the owner) catastrophically failed at the Allied Terminals, Inc. (Allied)
facility in Chesapeake, Virginia, seriously injuring two workers and partially
flooding an adjacent residential neighborhood. On the day of the incident, Allied
was filling Tank 201 with liquid fertilizer to check for leaks prior to painting the
tank. During the filling, a welder and his helper sealed leaking rivets on the tank. At
a fill level about 3.5 inches below the calculated maximum liquid level, the tank split
apart vertically, beginning at a defective weld located midway up the tank. Within
seconds, the liquid fertilizer overtopped the secondary containment, partially
flooding the site and adjacent neighborhood. The collapsing tank wall injured the
welder and his helper, who were working on the tank. Employees of a neighboring
business responded and extricated them. At least 200,000 gallons of the liquid
fertilizer were not recovered; some entered the southern branch of the Elizabeth
River.

68
Allied collapsed tank and neighboring business.

 CHRONOLOGY OF EVENTS

 On Tuesday November 11, 2008, allied began filling Tank 201 with
liquid fertilizer to find and repair rivet weeps9 in preparation for
painting the exterior of the tank.

 On Wednesday, November 12, 2008, at about 2:00 pm, while


Allied continued filling the tank to a level between 26 and 27 feet,
a welder and helper from G&T began sealing weeping rivets. The
welder was working in a man-lift about 15 feet above ground. The
helper was on the ground nearby.

 At about 2:20 pm, as the tank reached a level of 26.72 feet, a vertical
split started midway up the shell and rapidly extended to the floor
and roof of the tank on the side opposite the workers.

 As the pressure of the liquid fertilizer inside the tank opened the
split, the tank shell separated from the bottom and roof, rapidly
releasing the tank’s contents.

 The collapsing tank shell impacted the man-lift, seriously injuring


the welder in the man-lift basket. The tank stairs fell away from the
tank and pinned the helper to the ground. Both workers were briefly
submerged under the liquid fertilizer.

 Employees from a neighboring business witnessed the accident and


quickly extricated the workers

69
 The liquid fertilizer overtopped the secondary containment,
damaging a facility maintenance building and flooding portions of
the facility and the South Hill neighborhood.

 At least 200,000 gallons of the liquid fertilizer were unaccounted


for post-accident cleanup; some flowed into the nearby Elizabeth
River, about 1,000 feet from the tank.

 KEY FINDINGS

1. Although the Fertilizer Institute issued recommended inspection


guidelines for liquid fertilizer tanks in 2001, incorporating API 653 by
reference, Allied was unaware of these guidelines prior to the incident.

2. HMT calculated a “safe fill height” for Tank 201 using the
requirements for weld joints that are spot radiographed. Allied did not
ensure spot radiography was performed on Tank 201.

3. Tank 201 failed at a liquid level of about 26.74 feet, which was less
than the calculated “safe fill height” of 27.01 feet.

4. Allied had no safety procedures or policies for work on or around tanks


that were being filled for the first time following construction,
reconstruction, or major modification. The collapse of Tank 201
seriously injured the two contractors working on the tank.

5. The liquid fertilizer overtopped the secondary containment, flooding


portions of the facility and an adjacent residential neighborhood.
Liquid fertilizer also spilled into the nearby Elizabeth River.

6. Post-incident visual examination of Tank 201 identified defective


welds as the likely immediate cause of the tank failure.

70
 Causes

1. Allied did not ensure that welds on the plates to replace the vertical
riveted joints met generally accepted industry quality standards for tank
fabrication.

2. Allied had not performed post-welding inspection (spot radiography)


required for the calculated maximum liquid level for the tank.

2. Allied had no safety procedures or policies for work on or around tanks


that were being filled for the first time following major modifications
and directed contractors to seal leaking rivets while Tank 201 was being
filled to the calculated maximum liquid level for the first time.

 Recommendations

United States Environmental Protection Agency.


2009-03-I-VA-R4
 Revise and reissue the Chemical Emergency Preparedness
and Prevention Office Rupture Hazard from Liquid Storage
Tanks Chemical Safety Alert.
At a minimum, revise the alert to
 Include the Allied Terminals tank failure,
 Discuss the increased rupture hazard during first fill or
hydrostatic testing, and
 List The Fertilizer Institute fertilizer tank inspection
guidelines in the reference section.
Governor and Legislature of the Commonwealth of Virginia
2009-03-I-VA-R5

Require state regulation of 100,000-gallon and larger fertilizer storage tanks


(which presently are located solely along and in the area of the Elizabeth
River) or authorize local jurisdictions to regulate these tanks. The regulations
should
 Address design, construction, maintenance, and inspection of 100,000-
gallon and larger liquid fertilizer storage tanks, and
 Incorporate generally recognized and accepted good engineering
practice.

71
Allied Terminals, Inc.

2009-03-I-VA-R6

Hire a qualified independent reviewer to verify that maximum liquid levels for all
tanks at Allied’s Norfolk and Chesapeake terminals meet the requirements of
American Petroleum Institute Standard 653, Tank Inspection, Repair, Alteration,
and Reconstruction. At a minimum, the review should verify that all requirements
for welding, inspection of welds, and In-Service and Out-of-Service tank inspections
are met. Make the complete review report for both terminals available to the Cities
of Norfolk, Chesapeake, and Portsmouth, Virginia, as well as the Virginia
Department of Environmental Quality.

2009-03-I-VA-R7

Develop and implement worker safety procedures for initial filling of tanks
following major modification or change-in-service. At a minimum, require the
exclusion of all personnel from secondary containment during the initial filling.

The Fertilizer Institute


2009-03-I-VA-R10
Formally recommend to all member companies the incorporation of The Fertilizer
Institute tank inspection guidelines into contracts for the storage of liquid fertilizer
at terminals.

6.BUNCEFIELD OIL DEPOT FIRE & EXPLOSION:

 INCIDENT SUMMARY:

On the night of Saturday 10 December 2005, Tank 912 at the Hertfordshire Oil
Storage Limited (HOSL) part of the Buncefield oil storage depot was filling with
petrol. The tank had two forms of level control: a gauge that enabled the employees
to monitor the filling operation; and an independent high-level switch (IHLS) which
was meant to close down operations automatically if the tank was overfilled. The
first gauge stuck and the IHLS was inoperable – there was therefore no means to
alert the control room staff that the tank was filling to dangerous levels. Eventually

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large quantities of petrol overflowed from the top of the tank. A vapor cloud formed
which ignited causing a massive explosion and a fire that lasted five days.

Buncefield oil depot fire

 CHRONOLOGY OF EVENTS:

 A Parcel of unleaded petrol was being delivered through pipeline into the tank
from 18:50 hrs. on Saturday, 10th December 2005.
 The tank which had a capacity of 6 million liters was fitted with an automatic
tank gauging system (ATG) which measured the rising level of fuel &
displayed this on the screen of control Panel
 At 03:05 hrs. on Sunday, 11 Dec. 2005, the ATG display flat lined, it stopped
registering the rising fuel level in the tank although the tank continued to fill.
 Consequently, the three ATG alarms, the “USER LEVEL”, the “HIGH
LEVEL”& the “HIGH-HIGH LEVEL” could not operate as the tank
reading was always below these alarm levels.
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 Due to practice of working to alarms in the control room, the control room
supervisor was not alerted to the fact that the tank was at a risk of overfilling.
So, the level of the fuel in the tank continued to rise unchecked.
 The tank was also fitted with Independent High Level Switch (IHLS) set at a
higher level than the ATG alarms. This was intended to provide an audible
alarm to the supervisor and send a signal to close the valve which would stop
the flow of product into the tank.

 The IHLS had a test lever used to check that the control room was functioning.
Pulling the level up simulated a high level and it could be checked that a
closed signal had been sent. Once the test had been finished the padlock had
to be placed on a test lever otherwise it could be left or drop under gravity into
a low-level test position which would prevent the IHLS from detecting a real
high level and sending a close signal.

 The IHLS was left off IHLS when Tank 912 overfilled, the IHLS did not act.
The IHLS failed to register the rising level of fuel, so the “FINAL ALARM”
didn’t and the automatic shutdown was not activated.

 By 05:37 hrs. on 11th December 2005, the level within the tank exceeded its
ultimate capacity & fuel started to spill out of the vents in tank roof.

 CCTV evidence showed that soon after that a white vapor was seen to be
coming from the bund around the tank.

 In the windless condition, this vapor cloud gradually spread to a diameter of


360 meters including the car parking area where a tank of aviation kerosene
was situated.

 The vapor cloud was noticed by the tanker drivers on site, the fire alarm button
was pressed at 06:01 hrs. , which sounded the alarm and started the fire water
pump.

 A vapor cloud explosion occurred almost immediately ignited by the spark


caused by the fire water pump starting most probably.

 By the time of explosion, 25000 liters of fuel had escaped out of the tank.
Over 20 fuel tanks were engulfed in the fire.

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 KEY FINDINGS:

 The immediate and major cause of this accident was the failure
of both the ATG & the IHLS to operate as the fuel level in the
tank increased.
 The tank was fitted with an independent high level switch.
Unfortunately, those who installed and operated the switch didn’t
know/ understand completely the way it worked and therefore
switch was left inoperable after the test.
 The maintenance technicians were required to test the IHLS
using the test lever. They also had to replace the padlock after
the test. Since the padlock was not fitted in the first place and the
maintenance technicians were not told about the reasons for it,
their process models were flawed and they didn’t know that it
needed to be fitted.
 There was only one visual display screen for the data provided
by the ATG systems on a number of tanks that meant only one
tank could be fully viewed at a time.
 NEGLIGENCE:
The Servo gauge stuck that caused the level gauge to flat line.
Actually, it had stuck 14 times between 31st August 2005 when
tank was returned to service after maintenance & 11th December
2005, the accident day.

HOW DID THEY DEAL WITH THIS PROBLEM OF STICKING OF SERVO


GAUGE?

 Sometimes, the supervisors rectified the symptoms of


sticking by raising the gauge to its highest position and then
letting it settle again, a practice known as STOWING.
 On other occasions, Mother well was called in to rectify the
matter, although the definite cause of sticking of servo gauge
was never properly identified.
 Sometimes, sticking was logged as a fault by supervisors &
sometimes not even logged as a fault by them.

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 Mother well control systems Ltd. Was required to select and
purchase a switch suitable for use as an IHLS on a tank storing an
extremely flammable liquid. No information is given on how or
why Mother well selected a TAV switch including why a
multipurpose switch was selected instead of dedicated high level
switch. Mother well was also required to install the IHLS. Mother
well Technicians were not told about the significance of the
padlocks and they believed them to be an optional security
provision.
 The bund at Buncefield had many flaws which caused large
volumes of fuel foam and firefighting water to leak out of the bund
area. Bunds were unable to handle large volumes of firewater
involved in the incident. Within the HOSL site, three bunds – bunds
A, B and C – performed particularly badly. The joints (floor and
wall joints) did not contain water stops. During the fire the sealant
and other joint materials (which were not fire resistant) were badly
damaged. Many of the joints leaked allowing fuel, foam and
firewater to flow onto the site roadways.

 RECOMMENDATIONS: COMAH (Control of Major Accident Hazards)

The recommendations are grouped under the following six headings:

 Systematic assessment of safety integrity level requirements


(Recommendation 1)
 Protecting against loss of primary containment using high integrity systems
(Recommendations 2-10)
 Engineering against escalation of loss of primary containment
(Recommendations 11-16)
 Engineering against loss of secondary and tertiary containment
(Recommendations 17-18)
 Operating with high reliability organizations(Recommendations 19-22)
 Delivering high performance through culture and leadership
(Recommendations 23-25

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 Systematic assessment of safety integrity level requirements

Recommendation 1

The Competent Authority and operators of Buncefield-type sites should develop and
agree a common methodology to determine safety integrity level (SIL) requirements
for overfill prevention systems in line with the principles set out in Part 3 of BS EN
61511.
This methodology should take account of:

▼ The existence of nearby sensitive resources or populations;


▼ The nature and intensity of depot operations;
▼ Realistic reliability expectations for tank gauging systems; and
▼ The extent/rigor of operator monitoring.

 Protecting against loss of primary containment using high


integrity systems

Recommendation 2

Operators of Buncefield-type sites should, as a priority, review and amend as


necessary their management systems for maintenance of equipment and systems to
ensure their continuing integrity in operation.
This should include, but not be limited to reviews of the following:

▼ The arrangements and procedures for periodic proof testing of storage tank
overfill prevention systems to minimize the likelihood of any failure that could result
in loss of containment; any revisions identified pursuant to this review should be put
into immediate effect;

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▼ The procedures for implementing changes to equipment and systems to ensure
any such changes do not impair the effectiveness of equipment and systems in
preventing loss of containment or in providing emergency response.

Recommendation 3

Operators of Buncefield-type sites should protect against loss of containment of


petrol and other highly flammable liquids by fitting a high integrity, automatic
operating overfill prevention system (or a number of such systems, as appropriate)
that is physically and electrically separate and independent from the tank gauging
system. Such systems should meet the requirements of Part 1 of BS EN 61511 for
the required safety integrity level, as determined by the agreed methodology (as
mentioned in Recommendation 1). Where independent automatic overfill prevention
systems are already provided, their efficacy and reliability should be reappraised in
line with the principles of Part 1 of BS EN 61511 and for the required safety integrity
level, as determined by the agreed methodology(as mentioned in Recommendation
1).

Recommendation 4
The overfill prevention system (comprising means of level detection, logic/control
equipment and independent means of flow control) should be engineered, operated
and maintained to achieve and maintain an appropriate level of safety integrity in
accordance with the requirements of the recognized industry standard for ‘safety
instrumented systems’, Part 1 of BS EN 61511.

Recommendation 5

All elements of an overfill prevention system should be proof tested in accordance


with the validated arrangements and procedures sufficiently frequently to ensure the
specified safety integrity level is maintained in practice in accordance with the
requirements of Part 1 of BS EN 61511.

Recommendation 6

The sector should put in place arrangements to ensure the receiving site (as opposed
to the transmitting location) has ultimate control of tank filling. The receiving site
should be able to safely terminate or divert a transfer (to prevent loss of containment
or other dangerous conditions) without depending on the actions of a remote third
party, or on the availability of communications to a remote location. These

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arrangements will need to consider upstream implications for the pipeline network,
other facilities on the system and refineries.

Recommendation 7

In conjunction with Recommendation 6, the sector and the Competent Authority


should undertake a review of the adequacy of existing safety arrangements,
including communications, employed by those responsible for pipeline transfers of
fuel. This work should be aligned with implementing Recommendations 19 and 20
on high reliability organizations to ensure major hazard risk controls address the
management of critical organizational interfaces.

Recommendation 8

The sector, including its supply chain of equipment manufacturers and suppliers,
should review and report without delay on the scope to develop improved
components and systems, including but not limited to the following:
▼ Alternative means of ultimate high11 level detection for overfill prevention that
do not rely on components internal to the storage tank, with the emphasis on ease of
inspection, testing, reliability and maintenance;
▼ Increased dependability of tank level gauging systems through improved
validation of measurements and trends, allowing warning of faults and through using
modern sensors with increased diagnostic capability; and
▼ Systems to control and log override actions.

Recommendation 9

Operators of Buncefield-type sites should introduce arrangements for the systematic


maintenance of records to allow a review of all product movements together with
the operation of the overfill prevention systems and any associated facilities.
The arrangements should be fit for their design purpose and include, but not be
limited to, the following factors:
▼ The records should be in a form that is readily accessible by third parties without
the need for specialist assistance;
▼ The records should be available both on site and at a different location;
▼ The records should be available to allow periodic review of the effectiveness of
control measures by the operator and the Competent Authority, as well as for root
cause analysis should there be an incident;
▼ A minimum period of retention of one year.

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Recommendation 10

The sector should agree with the Competent Authority on a system of leading and
lagging performance indicators for process safety performance. This system should
be in line with HSE’s recently published guidance on Developing process safety
indicators HSG254.

 Engineering against escalation of loss of primary containment

Recommendation 11

Operators of Buncefield-type sites should review the classification of places within


COMAH sites where explosive atmospheres may occur and their selection of
equipment and protective systems (as required by the Dangerous Substances and
Explosive Atmospheres Regulations 2002(ref 6)). This review should take into
account the likelihood of undetected loss of containment and the possible extent of
an explosive atmosphere following such an undetected loss of containment.
Operators in the wider fuel and chemicals industries should also consider such a
review, to take account of events at Buncefield.

Recommendation 12

Following on from Recommendation 11, operators of Buncefield-type sites should


evaluate the siting and/or suitable protection of emergency response facilities such
as firefighting pumps, lagoons or manual emergency switches.

Recommendation 13

Operators of Buncefield-type sites should employ measures to detect hazardous


conditions arising from loss of primary containment, including the presence of high
levels of flammable vapors in secondary containment. Operators should without
delay undertake an evaluation to identify suitable and appropriate measures. This
evaluation should include, but not be limited to, consideration of the following:

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▼ Installing flammable gas detection in bunds containing vessels or tanks into
which large quantities of highly flammable liquids or vapor may be released;
▼ The relationship between the gas detection system and the overfill prevention
system. Detecting high levels of vapor in secondary containment is an early
indication of loss of containment and so should initiate action, for example through
the overfill prevention system, to limit the extent of any further loss;
▼ Installing CCTV equipment to assist operators with early detection of abnormal
conditions. Operators cannot routinely monitor large numbers of passive screens,
but equipment is available that detects and responds to changes in conditions and
alerts operators to these changes.

Recommendation 14

Operators of new Buncefield-type sites or those making major modifications to


existing sites (such as installing a new storage tank) should introduce further
measures including, but not limited to, preventing the formation of flammable vapor
in the event of tank overflow. Consideration should be given to modifications of tank
top design and to the safe re-routing of overflowing liquids.

Recommendation 15

The sector should begin to develop guidance without delay to incorporate the latest
knowledge on preventing loss of primary containment and on inhibiting escalation
if loss occurs. This is likely to require the sector to collaborate with the professional
institutions and trade associations.

Recommendation 16

Operators of existing sites, if their risk assessments show it is not practicable to


introduce measures to the same extent as for new ones, should introduce measures
as close to those recommended by Recommendation 14 as is reasonably practicable.
The outcomes of the assessment should be incorporated into the safety report
submitted to the Competent Authority.

 Engineering against loss of secondary and tertiary containment

Recommendation 17

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The Competent Authority and the sector should jointly review existing standards for
secondary and tertiary containment with a view to the Competent Authority
producing revised guidance by the end of 2007. The review should include, but not
be limited to the following:
▼ Developing a minimum level of performance specification of secondary
containment (typically this will be bunding);
▼ Developing suitable means for assessing risk so as to prioritize the program of
engineering work in response to the new specification;
▼ Formally specifying standards to be achieved so that they may be insisted upon
in the event of lack of progress with improvements;
▼ Improving firewater management and the installed capability to transfer
contaminated liquids to a place where they present no environmental risk in the event
of loss of secondary containment and fires;
▼ Providing greater assurance of tertiary containment measures to prevent escape
of liquids from site and threatening a major accident to the environment.

Recommendation 18

Revised standards should be applied in full to new build sites and to new partial
installations. On existing sites, it may not be practicable to fully upgrade bunding
and site drainage. Where this is so operators should develop and agree with the
Competent Authority risk-based plans for phased upgrading as close to new plant
standards as is reasonably practicable.

 Operating with high reliability organizations

Recommendation 19

The sector should work with the Competent Authority to prepare guidance and/or
standards on how to achieve a high reliability industry through placing emphasis on
the assurance of human and organizational factors in design, operation, maintenance,
and testing.

Of particular importance are:

▼ Understanding and defining the role and responsibilities of the control room
operators (including in automated systems) in ensuring safe transfer processes;
▼ Providing suitable information and system interfaces for front line staff to enable
them to reliably detect, diagnose and respond to potential incidents;

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▼ Training, experience and competence assurance of staff for safety critical and
environmental protection activities;
▼ Defining appropriate workload, staffing levels and working conditions for front
line personnel;
▼ Ensuring robust communications management within and between sites and
contractors and with operators of distribution systems and transmitting sites (such as
refineries);
▼ Prequalification auditing and operational monitoring of contractors’ capabilities
to supply, support and maintain high integrity equipment;
▼ Providing effective standardized procedures for key activities in maintenance,
testing, and operations;
▼ clarifying arrangements for monitoring and supervision of control room staff; and
▼ Effectively managing changes that impact on people, processes and equipment.

Recommendation 20

The sector should ensure that the resulting guidance and/or standards is/are
implemented fully throughout the sector, including where necessary with the
refining and distribution sectors. The Competent Authority should check that this is
done.

Recommendation 21

The sector should put in place arrangements to ensure that good practice in these
areas, incorporating experience from other high hazard sectors, is shared openly
between organizations.

Recommendation 22

The Competent Authority should ensure that safety reports submitted under the
COMAH Regulations contain information to demonstrate that good practice in
human and organizational design, operation, maintenance and testing is
implemented as rigorously as for control and environmental protection engineering
systems.

 Delivering high performance through culture and leadership

Recommendation 23

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The sector should set up arrangements to collate incident data on high potential
incidents including overfilling, equipment failure, spills and alarm system defects,
evaluate trends, and communicate information on risks, their related solutions and
control measures to the industry.

Recommendation 24

The arrangements set up to meet Recommendation 23 should include, but not be


limited to, the following:
▼ Thorough investigation of root causes of failures and malfunctions of safety and
environmental protection critical elements during testing or maintenance, or in
service;
▼ Developing incident databases that can be shared across the entire sector, subject
to data protection and other legal requirements. Examples exist of effective
voluntary systems that could provide suitable models;
▼ Collaboration between the workforce and its representatives, duty holders and
regulators to ensure lessons are learned from incidents, and best practices are shared.

Recommendation 25

In particular, the sector should draw together current knowledge of major hazard
events, failure histories of safety and environmental protection critical elements, and
developments in new knowledge and innovation to continuously improve the control
of risks. This should take advantage of the experience of other high hazard sectors
such as chemical processing, offshore oil and gas operations, nuclear processing and
railways.

7. JAIPUR OIL DEPOT FIRE

 INCIDENT SUMMARY

A devastating fire/explosion accident occurred on 29.10.2009 at about7.30 pm in the


POL installation of M/S Indian Oil Corporation at Sitapura (Sanganer), Jaipur,
Rajasthan killing 11 persons and injuring 45. The product loss of around 60,000 KL
has been reported. In this accident the entire installation was totally destroyed and
buildings in the immediate neighborhood were also heavily damaged. This accident
occurred while officials of M/S IOCL were preparing for pipeline Transfer (PLT)
operations for transferring Motor Spirit (MS) and

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Superior Kerosene Oil (SKO) from their tanks to the tanks of nearby installation of
M/S Bharat Petroleum Corporation Ltd (BPCL). During the PLT operations there
was leakage of MS from a valve in the outlet line of MS tank of IOCL which
continued uncontrolled for about 75 minutes.
This massive loss of containment of MS resulted generation of colossal quantities of
petroleum vapors forming a vapor cloud which covered the entire installation. This
vapor cloud found a source of ignition and a devastation blast occurred. The blast
which completely destroyed the Facilities and building within the Terminal resulted
in 9 of the 11 tanks catching fire in immediate succession, which also spread
subsequently to other two product tanks.

 CHRNOLOGY OF EVENTS:

 On 29th October, 2009; BPCL asked IOCL for receiving MS (1567


KL) and SKO (850 KL) to be received in the neighboring installation
by pipeline transfer on 30th October.
 Manager Operations BPCL who was on a half day duty on29th came
to IOC control room around 2.30 p.m. to plan the activities for next
day’s PLT ( Pipe line transfer ) operations of both MS & SKO.
 However when he met the Shift Officer of IOC, he informed him that
he had received directions from his superior to start SKO transfer
today (i.e. on 29th October).
 Thereafter a telephonic discussion took place between BPCL and
IOCL concerned authorities which finally came to the conclusion that
both MS and SKO transfer operation will start on that day only (on
29th of October, 2009).
 The shift officer had three operators present in his shift at the
beginning of the shift out of which, one of them left the site apparently
without the permission of shift officer at 05:30 PM due to some
personal work
(puja at his house).

 At around 05:10 PM, SKO Tank no. 402-A was taken over from
pipeline Custody to marketing custody. All valve position was

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checked in presence of the shift officer and the water was drained
from the tank.

 Thereafter, the inlet valve to the tank was closed including the
hammer blind valve & the lock which was put on the outlet line
hammer blind was taken out and put on the inlet line hammer blind
valve.

 After the dipping and taking over of the tank from the pipeline, the
SKO tank402-A was lined to SKO pumps for pumping to BPCL by
first reversing the outlet line hammer blind valve in the lineup
position, opening the HOV (Hand operated valve) & Lastly the MOV
in the outlet line finally.

 After finalizing the job for SKO tank, the shift officer proceeded
towards the MS Tank 401-A along with his team. The standard
operating sequence of Pipeline transfer was not followed; MOV was
in open position before the start of Hammer blind valve reversal job
and HOV was operated.

 MS started leaking in vertical direction as a fountain, the height being


approximately 7 to 8 feet but rose gradually to higher levels almost
up to 25 to 30 feet.

 The vapor cloud formed due to leakage of MS spread over almost


entire plant and as the vapor cloud spread in such a large area, the
source of ignition can be anything inside or outside the installation.

 The two possible sources of ignition are:


i. Non-flame proof electrical fittings in administration block of the
terminal.
ii. Spark during starting of the vehicle at the installation.

 Almost simultaneously after the explosion, small blasts followed by


the fire occurred in 9 of the 11 tanks & fire continued to burn till fuel
contents were totally burnt.

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 2 fuel tanks which didn’t ignite immediately caught fire after a few
hours. These two tanks experienced seal fire and their roof was not
blown away.

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 KEY FINDINGS :

 Standard operating procedure not followed.

STANDARD OPERATING FOLLOWED SEQUENCE


SEQUENCE

1. Ensure HOV & MOV are MOV was opened already.


closed.
2. Reverse the position of hammer HOV opened
blind valve.
3. Open the HOV. Hammer blind valve opened
4. Open the MOV ( inching
operation is to be performed to Leakage started
ensure no leakage from
hammer blind valve )

TRANSFR
PUMP -1
11.86 M

MOV HBV HOV

SHEMATIC LAYOUT

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MOV on Discharge line

Hammer Blind and HOV on Discharge Line

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Source of MS Leak

 MOV was used for tank isolation as well as for Hammer Blind isolation. No
fall back provision.
 Absence of written Standard Operating Procedures (SOPs) for the work to be
undertaken and therefore reliance on practices.
 Non availability of one of the shift workman, who was supposed to be on duty,
control room remained unmanned due to it.
 HOV was opened before the completion of hammer blind valve reversal
Operation.
 Not checking the MOV for its open or closed status and not locking it in closed
position.
 MOV was in open position before the reversal of hammer blind valve. MOV
was opened for maintenance by someone between the previous blinding and
the day of accident.
 Not using the proper protective equipment while attempting the rescue work.
 The person who went for the rescue of the other person who was in dazed
condition, drenched entirely in MS & close to asphyxiation, he himself was
overcome by MS vapors that made him immobile.
 Initiation of the critical activity after normal working hours, leading to the
delay in response to the situation.
 Unavailability of second alternate emergency exit; The emergency gate near
the pipeline division had been walled up, the only exit for the pipeline division
officials was through terminal, which became inaccessible due to heavy
concentration of MS vapors.

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 RECOMMENDATIONS : “BY M.B.LAL COMMITTEE”

 DESIGN/ENGINEERING IMPROVEMENT

Upgrading of design to avoid potential loss of containment from any


reasons such as:

 Tank Overflow.
 Tank Floor Corrosion and Leak.
 Tank Roof Water Drain pipe leak (internally).
 Flange leak

NOTE: THE COMMITTEE HAS MADE TECHNICAL


RECOMMENDATIONS UNDER TWO CATEGORIES:

1. For immediate implementation


2. For planned implementation

 Immediate measures:

i) Push buttons on the MOV should be brought just outside the


dyke.

ii) Push button operation should be modified so that action require


for opening is different than action required for closing (e.g. pull
type and push type).

iii) The push button assembly should be mounted at a place where it


is easily visible to the operator.

iv) Lighting adequacy should be checked so that visibility is


adequately ensured at the push button of MOV & HOV
location.

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v) A technical group should study the feasibility of providing a limit
switch on the hammer blind with interlocking for MOV
operation.

vi) Main emergency shutdown switch which should be located in the


Control room should also activate the MOVs to close.

vii ) A separate pad locking arrangement on each of the hammer blinds


on the inlet and outlet lines should be provided so that they can be
independently locked as required.

viii) The pad lock on the hammer blind on the outlet line should not be
removed before the tank joint dipping is completed.

ix) VHF handsets to be provided to each of the operating crew.

x) Supervisor should be present to oversee the pipeline transfer line


up and related operation.

xi) Site specific, Standard Operating Procedures (SOPs) should be


prepared which not only give what the procedures are, but also why
they are needed. These must be made with the involvement of
procedure users and approved by the operations and safety team.

xii) Emergency procedures should be written and available to all personnel


in the installation outlining the actions to be taken by each during
major incident.

xiii) Any bad practice of HOV being opened first before opening of
hammer blind should be done away with and conveyed throughout the
organization.

xiv) Hydrocarbon (HC) detectors shall be installed near all potential leak
sources of class ‘A’ and ‘B’ petroleum products e.g. tank dykes, tank
manifolds, pump house manifolds, etc.

xv) HC detectors of proper type should be selected and should be proof


tested and maintained in good condition.

xvi) Medium expansion foam generators shall be provided to arrest vapour

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cloud formation from spilled volatile hydrocarbons.

xvii) An emergency kit shall be provided consisting of safety items viz. fire
suites, various leak plugging gadgets, oil dispersants and oil adsorbents,
lifting jacks (for rescue of trapped workers), high intensity intrinsically
safe search lights for hazardous area, etc. and shall be readily available
at the terminals.

xviii) Vehicles with spark ignition engine should not be allowed inside the
Installation area except up to the Administrative Block and also to ensure
continuous manning at the control room.

xix ) Advancements in technology make it possible to automate tanks and


terminals with sophisticated systems both in hardware and software.
This enhances the safety and can greatly reduce possibility of human
error by having interlock permissive and recording and measurement of
events like valve opening or closing and measurement of flow rate/level
etc. Existing Terminal managements should review the technology for
retro-fitment which can reduce risk levels.

 MEASURES FOR PLANNED IMPLEMENTATION:

NOTE: All the recommendation under the Immediate Measures category


above should also be considered for new installations.

i) Avoid hammer blind as an equipment in the plant design. Only a closed


system design should be adopted. It is understood that other
OMCs/MNC’s are already using such designs in their installations. Using
a Plug valve or a Ball Valve in place of the Hammer Blind should be an
acceptable option.

ii) Valve on the tank should be Remote Operated Shut Off Valve (ROSOV)
on the tank nozzle inside the dyke with Remote Operation only from
outside the dyke as well as from the control room. ROSOV should be fail
safe and fire safe. It should have only ‘close’ feature and not ‘open’ and
‘stop’ from control room. However, it should have ‘close’, ‘open’ & ‘stop’
operation from the panel located outside the dyke.

iii) SIL (Safety Integrity Level) of the tank level control must be improved
and independent overfill protection meeting the requirement of Part 1 of

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EN 61511 shall be provided. For this purpose, radar gauges must be
provided at least in class ‘A’ tanks in addition to presently existing
positive displacement level indictor/control. The MOVs which are the

primary item for cut off must be always kept in proper and best working
order and the SIL level of the entire interlock loop to be raised to meet
the requirement of EN 61511.

iv) Dyke should be constructed and tested to be leak proof.

v) The floating roof tank design may be reviewed to avoid the possibility of
Cascade or splash of product in the event of an overflow due overfilling.

vi) Design, inspection and repair as per latest API Codes.

vii) High level alarm from the radar gauge and high-high level alarm from a
separate tap off should be provided.

viii) For floating roof tanks, roof drain to be of more robust design to prevent
oil coming out when roof drain is open for water draining operation.

ix) Piping design inside tank dyke area should ensure easy accessibility for
any operations inside dyke in the tank farm.

x) Adequate lighting in operational areas should be ensured.

xii) Thermal Safety Valve (TSV) should be provided at the operating


manifold (outside dyke).

xiii) The dyke volume has been revised to 110% of largest tank in certain
international standards. This should be reviewed by OISD for tank
terminals and refinery tankage.

xiv) Wherever PLT transfers take place, to avoid pilferages, a Mass Flow
Meter with Integrator shall be provided on delivery pipelines.

xv) A CCTV should be installed covering tank farm areas and other critical
areas. The CCTV can nowadays provide with an alarm to provide
warning in case of deviation from any normal situation. The CCTV
monitoring station should be provided both in the control room as well as

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in the Security cabin/office.

xvi) Fire water tank and fire water pump house should be located far away
from potential leak sources/tankage area.

xvii) Remote operated long range foam monitors (1000 GPM and above) to
Fight tank fires shall be provided which should be of variable flow.

xviii) Advancements in technology make it possible to automate tanks and


terminals with sophisticated systems both in hardware and software.
This enhances the safety and can greatly reduce possibility of human
error by having interlock permissive and recording and measurement of
events like valve opening or closing and measurement of flow rate/level.
Most of the operations are controlled from control room and giving the
control room operator an overview of terminal operation. Right sequence
of operation is ensured through interlocks and permissive which bar the
operator from opening the wrong valves. Recording of all events in the
control room computer can provide effective monitoring of operation.
Measurement of flow rates and quantities can give more accurate stock
Control. It is recommended that new installations should evaluate the
technology options in this area and safety enhancing configuration should
be incorporated.

MAJOR CAUSES OF FIRES AT STORAGE TANKS:

 LIGHTNING:

 About one-third of all tank fires are attributed to lightning. Floating roof
tanks (FRT’s) are especially vulnerable to lightning. Poor grounding, Rim seal
leaks, direct hit are some of the reasons behind the tank fires due to lightning.

 How Lightning Causes Tank Fires?

Lightning strikes are characterized by very high stroke currents arriving in a


very brief amount of time. This current will flow across the surface of the
earth until the cell between the thundercloud and earth is neutralized. The
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current will flow in all directions, although the amount will vary in proportion
to the paths of lowest impedance.

 The mostly likely strike location on an FRT is the top of the rim or the gauge
pole.
However, lightning may endanger an FRT if a stroke terminates on:

(1) The roof,


(2) The shell,
(3) Anything attached to the roof or shell, such as the gauge pole, or
(4) A grounded structure or the earth near the FRT.

If lightning terminates on any of these locations a portion of the total lightning


current will flow across the roof-shell interface.

 If lightning terminates near an FRT, either to the earth or to grounded structure


as illustrated in Figure 3, smaller currents will flow across the roof-shell
interface. In either case, lightning related currents will flow across the roof-
shell interface. If the impedance between the roof and shell is high, arcing will
occur across the seal interface.

 There are two major causes of lightning related fires:

 Direct strike.

 The secondary effects such as the bound charge, the electromagnetic


pulse, the electrostatic pulse and the earth currents.

 A direct lightning strike zone has a radius about 10 m. When a storage tank is
in the direct strike zone, flammable vapours exposed to the heating effect or
the stroke channel may be ignited.

 A storm cell induces a charge on the surface of the earth and structures
projecting from the surface under the cell. The charged area varies in size from
15 to 150 sq. km, which is much larger than a direct strike zone. The risk of
secondary effects related fire is far higher than the risk of a direct strike.
After the nearby strike, a well-grounded tank will still take on the storm cell
induced charge, but it releases the charge faster.

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 The rim seal of a floating roof tank is the most likely place to be ignited in a
thunderstorm. Tight sealing to prevent the escape of liquids or vapors is
definitely necessary for storage safety. Vent valve is also a likely place to be
ignited.
• Flame arrestor should be installed.

API RP 545: “Lightning Protection for Above Ground Storage Tanks”

 Because of the high incidence of lightning related tank fires, the American
Petroleum Institute (API) formed a technical committee to investigate the
cause of these fires, evaluate tank designs and write a standard to force
changes in petroleum storage practices to reduce or eliminate lightning related
tank fires. The committee examined all of the variables which contribute to
lightning-related tank fires, including direct strike protection, grounding,
bonding, etc.

 As per NFPA 780 (Lightning Protection Code), shunts are required to be


installed on floating roof tanks above the seal at 3 meter (10 feet) spacing
around the tank perimeter. The purpose of these shunts is to provide a
conductive path from the tank roof to the tank wall.

 Tests conducted for the API RP 545, "Lightning Protection for Above
Ground Storage Tanks", task group have shown that :

1. The shunts can generate showers of sparks during lighting strikes. If there is
a gap between the seal and the tank wall during a lightning strike and if a
flammable mixture is present, a tank fire may result.
2. The fast component of the lightning stroke did not cause ignition of flammable
vapors, whereas the long duration component did cause ignition. The fast
component of the lightning stroke is too brief and has too little energy to ignite
flammable vapors.
3. Bypass conductors will carry the intermediate and long duration components
of the lightning stroke. If these components were allowed to continue to flow
through the shunts, sustained, hazardous arcing would occur at the shunts,
which would ignite any flammable vapors present.

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API RECOMMENDATIONS:

API RP 545 makes three key recommendations to improve the lightning safety of
petroleum storage tanks with external floating roofs, as follows:

1. Install submerged shunts between the roof and shell every 10 feet (3
meters) around the roof perimeter. The shunts should be submerged by one
foot (0.3 meters) or more, and if existing above-seal shunts are present, they
should be removed.

REASON: Shunts are used for the conduction of the fast and intermediate duration
components of the lightning stroke current. The API acknowledges that arcing
occurs between the shunt and shell during all lightning events. However, this arcing
is dangerous only when a flammable vapor is present. If the shunt is submerged, then
theoretically the arcing will occur where no air/oxygen is present, and ignition will
be avoided.

2. Electrically insulate all seal assembly components (including springs,


scissor assemblies, seal membranes, etc.), and all gauge and guide poles,
from the tank roof. The insulation level should be 1kV or more.

REASON: Insulating these components will encourage lightning currents to travel


through preferential paths (shunts and bypass conductors) rather than arcing between
the roof and shell. In other words, all possible current paths must be limited to those
preferential paths between the roof and shell, i.e., the shunts and bypass conductors.
However, it is debatable if the recommended insulation level of one kilovolt will be
sufficient to cause the desired outcome. The test report specifically recommends an
insulation level of “tens of kV and a flashover distance of at least 75mm.”

3. Install bypass conductors between the roof and shell no more than every
30 meters (100 feet) around tank circumference. These bypass conductors
should be as short as possible and evenly spaced around the roof perimeter.
They should have a maximum end-to-end resistance of 0.03 ohms and be of
the minimum length necessary to permit full movement of the floating roof

REASON: Bypass conductors are used for the conduction of the intermediate and
long duration components of the lightning stroke current. One of the observations
from testing was that the fast component of the lightning stroke did not ignite
flammable vapors, and that it was the long component of the lightning stroke that

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caused ignition. With conventional, above-seal shunts, the sustained arc at the shunts
lasted long enough to ignite flammable vapors. Because bypass conductors will
provide a positive bond between the roof and shell, the bypass conductors will
present a lower impedance connection between the roof and shell, as compared to
the shunts. Therefore, the long component of the lightning current will be diverted
away from the shunts and through the bypass conductors.

 OPERATIONAL ERROR:

i) Overfilling
ii) SOP not followed.
iii) Over pressurizing.
iv) Collapse due to vacuum in tank.
v) Water in hot oil tanks.
vi) Sinking of floating roof.
vii) Relief valve accidently opened.

• Overfilling is the most frequent cause in this category. When a tank


containing flammable liquid overfills, fire or explosion is usually
unavoidable. Any spark nearby may ignite flammable vapours released from
the tank.

 CAUSES OF OVERFILLING:

1. Lack of attention.
2. Errors in level indicators.
3. Wrong setting of valves.
4. Change of service.
5. Gravity filling
6. Absence of philosophy of safe filling heights.
7. Failure of manual dip measurement.

 CAUSES OF OVER PRESSURIZATION:

1. The liquid inlet rate is high and the tank vent is not able to take load of filling
vent.

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2. In a blanket tank, it may open up due to plugging of exit lines of vapour.

3. The changes in PCV’S settings or malfunctioning of PCV in blanketed tank.

4. Unplugging or de choking of pipelines if attempted by applying excessive


pressure towards tank, can cause bursting of storage tank.

 CAUSES OF COLLAPSE DUE TO VACUUM:

1. The vent is not clean.

2. Plastic bags, rags or bird nests had covered the vent and a sudden shower will
cause tank collapse.

3. PVRV not properly working.

 WATER IN HOT OIL TANKS:

1. Causes generation of steam due to which oil boils and rips open the tank roof
and overflows.
2. Accidental introduction of water/condensate from the blanketing steam into
tank during rains can also result in such failures.
3. Failure of steam heating coil in tank can also cause boil over in hot oil tanks.

 SINKING OF THE FLOATING ROOF:

Accumulation of rain on the roof creates stresses.


This accumulation can occur due to:

1. Plugged roof drains


2. Plugged roof strainers.
3. Blockage of overflows drains.

The accumulation will tilt tank roof and even sink the roof, exposing petroleum
vapour to atmosphere, which might find an ignition source outside resulting in
flashback fire to the tank.

 EQUIPMENT/INSTRUMENT FAILURE:

1. Thermostat failure.

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2. O2 analyser failure.
3. Relief valve failure.
4. Level indicator failure.
5. Frozen LPG Valve.
6. Overheated by steam heater.
7. Rust vent valve not opened.

 STATIC ELECTRICITY:

1. Rubber seal cutting.


2. Poor grounding.
3. Fluid transfer.
4. Improper sampling procedures.
5. Solid transfer.

 MAINTENANCE ERROR:

1. Sparks
2. Non-explosion proof motor or tools used.
3. Short circuit.
4. Welding.
5. Transformer spark.
6. Poor grounding of soldering equipment.

 TANK CRACK/ RUPTURE:

1. Microbiological sulphate reducing bacteria.


2. Corrosion.
3. Poor fabrication.
4. Shell distortion.
5. Poor soldering.

 LEAK &LINE RUPTURE:

1. Propane line broken by ATV.


2. Flammable liquid leak from a gasket.
3. Cut by oil stealers.
4. Pump leak.
5. Low temperature.

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 OTHER REASONS:

1. Auto ignition
2. Terrorist attack
3. Arson
4. Earthquake / Hurricane.
5. Open flame (Ground fire, smoking etc.)
6. Runaway reaction.

Statistics taken from:


Fire Journal Of Loss Prevention in Process Industries

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Statistics taken from:
Fire Journal Of Loss Prevention in Process Industries .

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 OM&S SAFETY FEATURES:

 Inbuilt safety features of storage tanks and spheres:

• Auto tank RADAR gauging


• Tank high and high- high level alarm
• Tank low level and low-low level alarm
• Discrepancy alarm
• RTDs
• Mass flow meters.
• Side entry mixers trip on tank low level
• Pump trip on low-low level
• N2 PCVs
• PVRV
• Tank roof lifting man way
• Roof breakup welding joint
• Pump interlock on low pressure
• Rim Vent
• Auto bleeder vent
• Cathodic protection
• Electrical Earthing Shunts (Internal/ External)
• Secondary Containment Dyke.
• Emergency Shutdown of Spheres.
• Process monitoring through software.
• Tank unexpected movement alarm
• Emergency sphere PSV release to flare system.
• OWS close network.
• Dyke drain valves to OWS.
• Storm water channel to oil catcher.
• Heat detection lines.
• Vapor balancing lines in spheres.
• Combustible gas detector in Horton sphere
• Inbuilt Thermal expansion philosophy for the movement lineups
• Thermal Safety Valve (TSVs)
• Tank auto change over.

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 GAP ANALYSIS (CHECKLIST):

NOT
FACILITIES/EQUIPMENTS AVAILABLE AVAILABLE REMARKS

Tank Level Control Systems


(ATG with high-high alarm)

Independent high-level switch


(IHLS)

Overfill protection system separated


physically & electronically from
tank gauging system. 

Protection for aboveground


pipelines.

Auto tank radar gauging 

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Thermal safety valves for the
movement line ups 

Emergency roof drains


Secondary seal (Weather shield with


rubber sheet) 

Inerting system

Emergency venting 

Push button on MOV outside the


dyke. 

Push button action different for


opening and different for closing. Switches with
(E.g. Push & Pull type ) direction are
 provided. Lights
are also given to
confirm the
Position.

RED : Open

Yellow : In
process

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Green: Closed
Adequately Lightning to ensure
adequate visibility at the push button
of MOV & HOV operation. 

Main emergency shutdown switch


which should be in control room and
capable of closing MOVs. 

Separate Pad locking arrangements No Hammer


on hammer blinds to lock them  blind valve
independently. present.

Site specific SOPs including what Site specific


and why is the procedure required.  SOPs are
present but
operators are
not clear with
why is the
procedure
required and
what are the
hazards
associated with
not following
the SOPs.
Some of the
Critical operating steps displayed on critical SOPs
board wherever applicable.  should be
displayed on
board.

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Proof tested HCs detector installed
near potential leak sources of Class
A & B Petroleum products 
(E.g. Tank dykes, Tank manifolds
etc.)

Medium expansion foam generators


to arrest vapor cloud formation from
spilled volatile HCs 

All the operation valves outside the


dyke area. 

Dyke constructed and tested for leak


proof 

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Install submerged shunts between
the roof and shell. API RP 545

Electrically insulate all seal


assembly components. API RP 545

Install bypass conductors between API RP 545


the roof and shell.

For e.g. If there


Secondary containment dyke are 4 tanks in one
( 110% capacity of tank )  dyke, then 110 %
of the capacity of
the largest tank
has been taken
into
consideration.

Mass flow meter 

Fire water pump house located far


away from potential leak
sources/tankage area. 

Avoid hammer blind as an


equipment in the plant design. 

Valves on the tank should be


Remote Operated Shut Off Valve 
(ROSOV).

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Vehicles with spark ignition engine Spark arresters
should not be allowed inside the are applied to
Installation area.  vehicles entering
the premises.

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CONCLUSION :
Concluding the project, I would say that the major fires that have
occurred at storage tanks across the globe can be a source of
enormous amount of learning that we can apply at our place in order
to prevent our facilities from such major fires.
A small accident may lead to million-dollar property loss and a few
days of production interruption whereas large accident results in
lawsuits, stock devaluation, or even company bankruptcy.
Although large-scale tank fires are rare, they present a huge
challenge to firefighters, oil companies and the environment.
I have observed that the prevention from Storage tank fires is more
important than its fighting because it has been observed that once if
a vapor cloud has been formed and spread then it is almost
impossible to restrict it from getting an ignition source and in turn a
major tank fire and explosion.
As a result of my gap analysis, I found RIL (JMD) to be completely
equipped with all the safety features required to make a storage tank
safe and almost all the recommendations that were given by the
accident investigating bodies after the major fires across the globe
have already been fulfilled over here that enables the site to meet the
highest standards of fire safety when it comes to storage tanks.

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 REFERENCES :

1. US CSB: United States Chemical Safety Board.

2. COMAH: Control of Major Accident Hazards.

3. API 650: Welded Steel Tanks for Oil Storage.

4. OISD116: Fire Protection Facilities for Petroleum Refineries


and Oil& Gas Processing Plants.

5. MB Lal Committee Report

6. Journal of loss prevention in process industries

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