API 2350: Tank Overfill Protection – An Overview Monday, April 23 2012 Dallas, Texas

1. API 2350: Tank Overfill Protection – An OverviewMonday, April 23 2012Dallas, Texas By PEMY Consulting Philip E. Myers

2. Disclaimer • View and opinions are strictly those of the presenter and do not represent those of the American Petroleum Institute (API) or those of the API 2350 Overfill Revision Taskgroup • At the time of this presentation the editorial process for API 2350 may still be in progress. While every effort is made to present the final outcome, no guarantee that the editorial process may result in changes to what is presented here can be made. • All diagrams and drawings are conceptual in nature and cannot be directly used for design and construction of actual facilities. Such facilities must be individually engineered and designed for each tank and site by qualified personnel

3. Side Note about API/ANSI Process • Standards Development Processes set by American Nations Standards Institute (ANSI). Not all codes use this process (e.g. International Building Code) • Consensus • Openness • Due Process • Committee balance (manufacturers, contractors, consultants, owner/operators, etc) • public review • All comments must be considered • standards are updated or reaffirmed by the same process at intervals not exceeding 5 years. The 2nd edition was already late and we issued the 3rd edition with a change that expanded the scope to include Class II liquids • regularly audited to ensure compliance with the Rules for Standards Committees and that are consistent with the American National Standards Institute (ANSI)

4. Why API 2350 Is Needed

5. Overfill Prevention in Nutshell • The Overfill Prevention Process (OPP) is simple in concept. When receiving product into a tank the flow is terminated prior to the tank level reaching the critical high (CH) level. Use of the word “terminate” in this standard means any of the following: • Terminating the source of pressure (e.g. shutting down a pump), or • Diverting the incoming flow, or • Shutting down the flow (closing a receipt valve), or • Using an alternative way appropriate way of bringing the receipt process to a safe state without overfilling the tank • While this desired end-result termination seems simple, experience suggests the need for a systematic Overfill Prevention Process (OPP) to ensure success over time

6. Drivers for Current Changes • API Revision Cycle past due • Update API 2350 with current applicable standards such as S84 and IEC 61511 for automated safety instrumented systems • Make it more enforceable and prescriptive • Buncefield incident occurred at Sunday December 11th 2005 at the BuncefieldOil Storage Depot, Hemel Hempstead, Hertfordshirein the UK

7. Questions You May Be Asking • Is the new edition really that different than previous editions? • Do I need to upgrade to the latest edition of API 2350? • What are the benefits of upgrading? • What is the rest of industry going to do about it?

8. Historical Background • 2350 first issued in March 1987. Scope restricted to “Terminals receiving transfer of Class I materials (e.g. gasoline) from mainline pipelines or marine vessels.” • The second edition in January 1996 maintained that narrow scope and clarified that it covered ONLY gasoline, mainline pipelines and marine, and not other internal or external transfers. Minor non substantive revisions • The third edition in January 2005 built on the second edition with the Scope significantly expanded to include both Class I and Class II hydrocarbon liquids as well as tankage in broader usage. Receipts of petroleum products from wheeled vehicles are specifically excluded from the Scope of API 2350, referring to PEI 600 for guidance.

9. Scope • The scope of this Standard is specifically limited to storage tanks associated with marketing, refining, pipeline, terminals and similar facilities containing Class I or Class II petroleum liquids. (Note: API 2350 is recommended for Class III liquids) • This standard does not apply to: • Underground storage tanks • Aboveground tanks of 1320 US gallons (5000 liters) or less • Aboveground tanks which comply with PEI 600 • Tanks (process tanks or similar flow through tanks) that are integral to a process. • Tanks containing non-petroleum liquids • Tanks storing LPG and LNG • Tanks at Service Stations • Loading or delivery from wheeled vehicles (such as tank trucks or railroad tank cars)

10. New -Key Components of API 2350 • Management System • Risk Assessment System • Defining Operational Parameters and Categorization • Procedures • Equipment Systems (addition of AOPS)

11. Management System • Management System • Formal written operating procedures (including emergency response) • Trained and qualified personnel • Equipment systems testing and maintenance • Normal and abnormal operating conditions addressed • Moc (management of change) • Investigation process for near misses and incidents • Lessons learned • Communications protocols esp between transporter and owner/operator • API 2350 does NOT specify how to develop/deploy a management system (we will do this in the workshop) • Important Note: On request PEMY will send you a 25 page detailed write up on how to develop and deploy not only a safety management system but an overfill management system as well.

12. Risk Assessment Systemexample of verbal risk assessment “I am willing to take the risk”

13. API 2350 and Risk Assessment • Risk Assessment system shall be used to categorize risks associated with potential overfilling operations as acceptable or unacceptable • Risks are site and owner specific • API 2350 does NOT specify how risk assessments should be conducted • IEC 31010 “Risk management – Risk assessment techniques” lists many such methods. LOPA has been used extensively in the UK for tanks where risks considered significant. • API 2350 Annex E Conceptual Tank Overfill Risk Evaluation

14. Risk • From the Italian word “risicare:” • “to dare” • Risk defines the difference between • a choice and a fate • Risk assessment: • The foundation for rational decision making. Insights. Actions.

15. Consequences Event / Scenario Response Dose Impact Why do risk assessment? Pathway

16. Health & Safety Corporate Public/ Community Reputation Financial Performance Customer Satisfaction Environmental Impacts Employee Commitment/ Alignment Regulatory Relations Strategic Alignment Public Community relations Workers Corp reputation Customers / Consumers Values and Consequences Values for a Pipeline Company “Be the preferred provider of liquid pipeline transportation”

17. Consequences Event / Scenario Response Dose Impact Why do risk assessment? Because the consequences matter to us; values are adversely affected Pathway

18. Eliminate the consequences Change the response curve Consequences Event / Scenario Response Eliminate the root cause Protect the target Dose Sever the pathway Impact Assessment Management Pathway

19. Tank Overfill Protection – Basic Concept of Risk • Behaviors • Procedures/Training • Equipment: • Gauges • Alarms • Auto shutdown Incident Product receipt plan was not completed No automatic shutdown Product Receipt P Tank flow was not verified Alarms did not work Tank rise was not monitored

20. Methods of Risk Assessment • Many methods ranging from qualitative to semi-quantitative to quantitative: • Checklists • Risk matrices • HAZOP approach • Risk Graph • Quantitative Methods • Layers of Protection Analysis (LOPA)

21. Consider These Likelihood Factors: • Frequency, rate and duration of filling • Systems used to properly measure and size receipts to tanks • Accurate tank calibration (both strapping and verified Critical High) • Systems used to monitor receipts • Extent of monitoring / supervision of manual and automatic tank gauging • Impact of complexity and operating environment on the ability of Operating Personnel to execute overfill prevention tasks • Filling multiple tanks simultaneously • Switching tanks during receipt • Large elevation changes between tanks and backflow

22. Consider these Consequence Factors • Hazard characteristics of material (product) in tank • Volatility, flammability, dispersion, VCE potential • Number of people onsite who might be affected by a tank overflowing • Number of people offsite who might be affected by a tank overflowing • Possibility of a tank overflowing resulting in (escalation) of hazardous events onsite or offsite • Possibility of impact to nearby sensitive environmental receptors • Physical and chemical properties of product released during overflowing • Maximum potential overfill flow rates and duration • Secondary containment

23. Initializing Operating Parameters

24. Initializing Operating Parameters - LOCs • Level: Critical High (CH) • Overfill or Damage occurs • Activate Emergency Response • Level: High-High (HH) • Alarm or AOPS • Level: High (Optional) • Alerts NOT Alarm • Normal Fill Level (NFL) • Highest working level

25. Review/revise LOCs when • New tank • Change in floating roof tank seals • Installation of geodesic domes or other kinds of fixed roofs (e.g. when external floating roof tanks receive retrofit covers). • New internal or external floating roof • Side vent changes • Shell extensions • New tank bottom • Addition of ancillary equipment such as foam chambers • Recalibration or re-strapping of the tank • Change of tank gauging equipment • Addition of a gauge tube with datum or change in datum/strike plate • Change in product • Change in incoming or outgoing lines • Change in flow rates, • Change in service if it impacts structural integrity [corrosion, temporary repairs, etc] • Change in operations, such as: parallel tank, floating or high suction, continuous mixer operation • Change in response time resulting from staffing, operation or equipment changes

26. Initializing Operating Operating Parameters - Categories • Operators shall categorize each tank • A way to classify tank overfill systems • Category I: manual system • Category II: ATG with transmittable data to control center • Category III: ATG and independent level alarm transmittable to control center • AOPS: independent addition to Categories I, II, or III

27. Given all things equal, the higher the category of overfill protection system, the more robust and reliable it is. • When a manual system (MOPS) does not have sufficiently low probability of failure on demand, then AOPS should be considered as a means of increasing the OPS reliability (availability)

28. Category I • Configuration • Does not have transmitted alarms • Tank Level is determined by HAND gauging or local Automatic Tank Gauging (ATG) system. • Requires Local “manual” shutdown or diversion or transporter shutdown after receiving “manual” communications from facility • Use only at fully-attended facilities • Monitor continuously first and last and every in-between hour of receipt • Do not use for high frequency or complex receipt operations

29. Category 2 • Configuration • Tank level (ATG required) and alarm is transmitted to remote location (control room) • ATG Alarm set at LOC: HH • Alarm are not independent of ATG system (same sensor for ATG and alarm) • May use Cat 2 at fully or semi attended facility if receipts monitored at the control room • On site monitoring required 30 minutes at start, at end of receipt; for semi attended transporter must participate in monitoring • Alerts recommended at LOC: H

30. Category 3 • Configuration • Tank level and alarm is transmitted to remote location (control room). • Alarm is independent of ATG system and set at High-High LOC. • Requires Local “manual” shutdown or diversion • For unattended operation, alarm shall automatically notify transporter or automatically terminate receipt (AOPS) and receipt termination shall commence in event of power outage

31. Automatic Overfill Protection System (AOPS) • Configuration • Basic Process Control system can be Category I, 2 or 3 • AOPS in independent of operation • AOPS added as another layer of protection on top of Category I, 2 or 3 if risk assessment shows acceptable risk cannot be attained otherwise • Two Options: • 1 Existing Facilities Annex A • 2 New Facilities ISA S84.01 or IEC 61511

32. Response Times • Save time: Do the calculation

33. Beware The Response Time Recommenation: never less than 5 minutes no matter the calculation

34. Putting It Together (partial list) Top management support Mission vision values Risk assessment system Management System People and resources Define Operational Parameters procedures Training, competancy Tank data base, tank standards, field verification, upgrading policy, prioritization for upgrading, policy/consultants for AOPS, etc. etc. etc.

35. Questions • Is the new edition really that different than previous editions? • Do I need to upgrade to the latest edition of API 2350? • What are the benefits of upgrading? • What is the rest of industry going to do about it?

36. Conclusions and Recommendations • The New API 2350 will represent a significant change from past practices but it is consistent with today’s best practices in areas of safety and environmental protection as well as state-of-the-art technology • Authorities will consider it minimum requirements • OMS must be a corporate way of life – created by a vision, a mission and a philosophy • A high level of top level commitment and resources is required - But the alternatives can be costly too • Must be embedded into the corporate value system so that it is a long term process and can outlast the managers and executives who often get promoted out of their positions and who never really truly understood what a safety management system is • Do your part to educate top management that this is really the best way to go if you are going to be in the petroleum business. Do it thru knowledge, education and expertise and hopefully not because of a serious incident