Guidebook For Overfill Prevention & Tank Gauging

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ProductsSolutionsGuidebook for OverfillPrevention & Tank GaugingGuidebook for Overfill Prevention & Tank GaugingABSTRACTThe public, the regulatory community and industry have expectationsthat tank overfills should be addressed proactively and in accordancewith the current edition of API 2350. We aim to provide you with theknowledge and expertise to address the concern for hazardous liquidoverfill unique to your facility, goals, and corporate interests.Authors: PEMY Consulting and Endress Hauser ExpertsPhilip Myers, Brock Trotter, Dean Mallon, Hai-Thuy Ngoand Markus WohlgemuthServices

2Guidebook for Overfill Prevention & Tank GaugingDisclaimerWhilst every effort has been made to ensure the accuracy of the information contained in this guidebook,Endress Hauser will not warrant its accuracy or will, regardless of its negligence, assume liability for anyforeseeable or unforeseeable use made thereof, which liability is hereby excluded. Consequently, such use is atthe recipient’s own risk on the basis that any use by the recipient constitutes agreement to the terms of thisdisclaimer. The recipient is obliged to inform any subsequent recipient of such terms.This publication is made available for information purposes and solely for the private use of the user.Endress Hauser will not directly or indirectly endorse, approve, or accredit the content of any course, event orotherwise where this publication will be reproduced.Copyright noticeThe contents of these pages are Endress Hauser.No part of this work may be reproduced, translated, stored in a retrieval system, or transmitted by any means,electronic, mechanical, photocopying, recording, or otherwise, without prior written permission from thepublisher. Contact the Publisher, Endress Hauser AG, Kägenstrasse 2, 4153 Reinach BL, Switzerland, 2018

Guidebook for Overfill Prevention & Tank GaugingPEMY BiographiesPhilip Myers has broad experience in the chemical, petrochemical, refining experience and hasworked in these facilities in various roles for over 35 years. Of particular relevance, Philip Myersworked with the American Petroleum Institute developing the original ‘Large Diameter Tank FireStudies’ as well as other groups such as the ‘Last Fire’ initiative sponsored by the major oilcompanies such as Exxon, Chevron, and BP. Philip Myers was the founder of the group at ChevronEngineering Research and Technology of the storage tank discipline which he felt was necessary aspart of the fixed equipment (tanks, pressure vessels and piping) work that was being done. Heserved as the chairman of the API 2350 4th edition. Most of his career was at Chevron, but he hasbeen a consultant and worked at a gas utility company. Email: phil@pemyconsulting.comBrock Trotter graduated with a Bachelor’s of Science in Chemical Engineering from theUniversity of Oklahoma and is a registered EIT with the state of Oklahoma. Prior to joining thePEMY Consulting team he performed research in surfactant technologies at the University ofOklahoma with Dr. Jeffrey Harwell. He is also an attendee of the Shell Drilling and ProductionCamp where he was trained in a wide variety of offshore oilfield techniques. As a consultant hehas written publications for Endress Hauser and Emerson regarding tank level equipment as wellas fire and overfill prevention. He has performed work in support of an expert witness regardingpetroleum law and has written articles regarding API 2350, the impact of flooding on the Houstonpetroleum industry, and vapor related process safety engineering. His primary areas of interestinclude process safety engineering, performance engineering, emissions, overfill management,settlement analysis, automation, and risk analysis. Email: brock@pemyconsulting.comContributorsDean Mallon has over 34 years’ experience in chemical, petrochemical, refining and terminalautomation, holding positions as a company owner to instrumentation sales and currentlyNational Product Manager (Level/Tank Gauging) for Endress Hauser in the USA. Dean Mallon hasworked with the American Petroleum Institute for over 8 years, being involved with the API 23504th edition of overfill protection working group and most recently the 5th edition (currently beingreviewed for publication).Hai-Thuy Ngo has a business engineer degree and graduated in the top 5% of his university in2005. He started in 2005 as Marketing/Product Manager for the Endress Hauser Tank Gaugingsolution package in the Oil & Gas industry. Since 2009 he is responsible for the Oil & Gas industryfor the Middle East, Central and South America, North Africa, Central Asia and Southeast Asia.In 2013 he became a TÜV certified functional professional and conducted trainings forEndress Hauser safety specialists. In his global role he has visited more than 40 countries toshare and learn the best practice of different Oil & Gas companies in different countries.Markus Wohlgemuth has more than 25 years of experience across industries in project andproduct management, business development and compliance. Since 2007 he is working atEndress Hauser and is member of several international networks and working groups. As aBusiness Development Manager for solutions he is one of the main responsible for the overfillprevention systems covering national and international requirements including API 2350 as wellas IEC61508 and IEC 61511 related topics. He holds a BSc in electrical engineering, is certifiedcomputer validation manager and TÜV certified functional safety professional.3

4Guidebook for Overfill Prevention & Tank GaugingThe Endress Hauser Guidebook toAPI 2350 & Overfill PreventionChapter 1 – Safety Management Systems and Management’s Role. 7Overview. 7What is a Safety Management System?. 8Background of Overfill Prevention Process. 9OPP Requirements of API 2350. 11Overfill Management in the Larger Context of Safety Management Systems.12Important Prerequisite for Overfill Prevention Process. 12Why is OPP Needed?. 13Chapter 2 – Introduction to API 2350 and Overfill Prevention. 14Why Overfills Matter to You. 14Understanding What’s at Stake for an Overfill. 14Buncefield Case. 16Puerto Rico Capeco Case. 17Chapter 3 – Regulatory Framework and Best Practices. 19The Process Safety Management Connection. 19Best Practices and Current Thinking on Ensuring Process Safety. 19Current Thinking on Ensuring Safety. 20Chapter 4 – Exploring API 2350. 22Introduction. 22Comprehensive Overfill Prevention. 25Applying API 2350. 26Chapter 5 – Risk Assessment. 29Why Overfills Pose Extraordinary Risk Levels. 29New Existing Facilities Issues. 29Difference Between Risk Assessment and Risk Management. 29Risk Assessment Screening. 31Logical Structure of Risk Assessment. 32Risk Screening Example. 32

Guidebook for Overfill Prevention & Tank GaugingChapter 6 – Role of Instrumentation and Technology. 39Introduction and Motivation. 39Tank Gauging Systems. 39Manual Tank Gauging. 42Automatic Tank Gauging. 48Overfill Prevention Systems. 50Proof Testing. 52Contact vs. Non-Contact Level Sensors. 61Categorization of Level Sensors. 62Appropriate Level Sensor for Common Applications. 62Point Level Sensors. 63Continuous Level Sensors. 68Oil Leak Sensors. 74Chapter 7 – Level Measurement Reliability. 75Safety Instrumented Systems. 75Chapter 8 – Procedures, Operations, Testing, and Maintenance. 81Procedures. 81Chapter 9 – How to Develop an OPP (Overfill Prevention Process). 82Appendices. 83Abbreviations. 83Key Terms and Definitions.84Safety Management Systems. 965

6Guidebook for Overfill Prevention & Tank GaugingIntroductionOne of the most significant sources of risk at facilities which store hazardous liquids is an overfill event. Risk isdefined as the product of the probability of a risk event occurring and the consequential severity of that event.Overfill events create significant levels of risk because filling storage tanks occurs often, increasing the probabilityof overfill. The severity of an overfill event may be high because health and safety issues arise, or the environmentis damaged – and fines and lawsuits tend to follow. The worst-case risk event scenario may be a vapor cloudexplosion causing devastation both internally and externally of the offending company. In joint response to recentmajor overfill events, the industry developed API/ANSI Standard 2350.ObjectivesTo address the most common cause of overfill near misses and incidents, the 4th Edition of API 2350 hasintroduced a new requirement related to safety management systems. API 2350 states, “A management systemis required for conformance with API 2350, but this standard does not specify how to implement such a system.”Therefore, the purpose of this guidebook is to help organizations understand what this requirement means andwhy it is important for them to establish a safety management system or consider modifying an existing safetymanagement system to include the overfill prevention process.ScopeAPI 2350 is intended to provide operators with the best practices for implementing and maintaining petroleumstorage tanks to prevent overfill events. The storage of any large amount of fuel crude oil and other hazardousliquid creates risk and potential danger at a facility if not properly operated, maintained and designed.This guidebook is to support organizations to implement the current best practices by industry standards (likeAPI/ANSI Standard 2350, Buncefield Report, IEC 61508 (Functional Safety) and IEC 61511 (Safety InstrumentedSystems)) as they define the “Recognized and Generally Accepted Good Engineering Practice”.

Guidebook for Overfill Prevention & Tank GaugingChapter 1 – Safety Management Systems and Management’s RoleOverview“The Overfill Prevention Process (OPP) 1 is simple inconcept - the termination of the source by: Diverting the incoming flow Shutting down the flow (closing a receiptvalve or terminating a pump) Using an alternative appropriate method ofbringing the receipt process to a safe statewithout overfilling the tank such as enhancedcommunications, knowledge and control ofreceipts and ullage, and manually managedcontrol systemsWhile the desired end-result, the terminationprocess, seems simple, experience indicates theneed for a systematic Overfill Prevention Processto ensure success every time.”The above excerpt, taken from API 2350, is everythingthat is required to prevent overfills - period! Tosuccessfully terminate a receipt for one time mightseem to be easy. To do it safely a million times overis a Herculean task. The current edition of API 2350requires that Owners and Operators set a goal todevelop and implement a safety management systemto control tank overfills. Experience has shown thatwhile this goal appears to be simple, achieving this goalrequires far more than good intentions. It requires botha systematic, sustained, continuously improved safetymanagement system (SMS) and an overfill preventionprocess (OPP). Safety management system is thebroad term used to describe the protocol, training,infrastructure, equipment, sensors, emergencyresponse, and expertise that is developed to assist inthe prevention of a risk event. The Overfill preventionprocess (OPP) is like the Safety Management System(SMS) but focuses exclusively on the prevention of ahazardous liquid overfill events.As a prerequisite, achieving this goal requires seniorlevel management commitment and a substantialinvestment in time and resources. More importantly,it requires that organizations recognize and establishcore values that support the premise that potentialhazards, such as overfills, are not only unacceptableand bad for business but are environmentally1damaging, dangerous, and potentially lethal. It isimportant that they understand the “insuranceconcept” as described later in this guidebook so thatthere is belief in the value of committing resourcesto ensuring these incidents do not happen in theircompanies. Management must promote and maintainsupport by developing and implementing thenecessary standards, programs, safe work practices aswell as providing the resources and funding requiredto achieve this goal.It is not the intent of this guidebook to justify theneed for such organizational values. However, itshould be noted that there are many examples ofcompanies that are either no longer in business orhave had their businesses severely and negativelyimpacted, due to overfills or serious incidents.It is recognized by both industry and regulatoryauthorities that the failure to manage known andpotential risks is a major contributing factor of tankoverfills (as well as other major incidents).To address the most common cause of overfillnear misses and incidents, the 4th Edition of API2350 has introduced a new requirement related tosafety management systems. API 2350 states, “Amanagement system is required for conformancewith API 2350, but this standard does not specify howto implement such a system.” Therefore, the purposeof this guidebook is to help organizations understandwhat this requirement means and why it is importantfor them to establish a safety management system orconsider modifying an existing SMS to include OPP.The acronym SMS means any organization’sgeneral safety management system or safety andenvironmental management system. The acronymOPP, means a specific reference to those aspects ofSMS that apply directly to tank overfill prevention.Thus, when dealing with specific aspects of safetymanagement systems related to overfill prevention,the term OPP is used. Often SMS and OPP are usedinterchangeably and therefore, the term OPP will beused interchangeably. Details on how any companycan implement an OPP are provided for in Appendix:Safety Management Systems Continued.As used in this guidebook, OPP (overfill prevention process) is equivalent to the term used by API 2350, SMS, and means either ageneral safety and environmental management system that has been modified to include overfill prevention or a system. Moreover,OPP is equivalent to a Safety and Environmental Management System.7

8Guidebook for Overfill Prevention & Tank GaugingWhat is Safety Managment System?A management system is “a formally established and documented set of activitiesdesigned to produce specific results in a consistent manner on a sustainable basis” 2.Safety management systems (or as referred to in API 2350 the Overfill Prevention Process(OPP)) can be defined as a management system embedded within an organization’sformal operating framework that includes safety and environmental goals. OPP includesall the elements of safety management systems but with a specific focus on tank productreceipt operations. OPP should be integrated with any existing corporate managementsystems such as safety/environmental management systems. We will genericallyrefer to the management systems as they specifically apply to overfill as OPP.OPP compiles various management and operational procedures and practices into one coherentorganizational structure that maximizes the level of safety and environmental protection.For OPP to be effective, the following actions are required: OPP must be established, implemented, and activelysupported by the organization’s leadership to besuccessful specific to the applicable tank population OPP requires formal responsibility andaccountability at all levels of the organization OPP requires correctly aligned behaviorsand attitudes by all employees OPP requires continued review and improvementthrough activities such as incident and accidentinvestigation, audits, and management of change2 CCPSGuidelines for Risk – Based Process Safety, AIChE

Guidebook for Overfill Prevention & Tank GaugingBackground of Overfill Prevention ProcessThe relationship between management and incidentprevention became acute after several seriousincidents in the chemical process industries caughtthe attention of the public and the regulators. In the1970’s and 1980’s, it became increasingly evident thatmanagement systems, based on science, can effectivelybe used to adjust an organization’s best managementpractices to focus on solving safety and environmentalproblems. Industry organizations such as the Center forChemical Process Safety (CCPS), American ChemicalCouncil (ACC) (formerly Chemical Manufacturer’sAssociation), Canadian Chemical ProducersAssociation, American Petroleum Institute and otherassociations and organizations, both in the US andin other countries, started developing approaches toincorporate safety and environmental managementsystems into the overall organizational structure.Figure 1: Overfill Prevention Management ProcessThese organizations represent the foremost expertsin their individual fields and each aim to providethe information and protocols needed to proactivelyprevent a risk event.The concept of management systems originated withDr. W. Edwards Deming who used Shewart’s work toshow organizations how to improve consistency andquality of goods and services in the workplace. TheShewart Diagram, Figure 2, represents the rudimentsof a simple management system, sometimes called“PDCA” (Plan, Do, Check, Act) or the “ShewartCycle”. The Shewart Cycle is a concept used forunderstanding the steps involved in continuousimprovement. The circular pattern for the ShewartCycle is never-ending, visually displaying the idea ofcontinuous improvement.9

10Guidebook for Overfill Prevention & Tank GaugingShewart Diagram – The 4 Steps of PDCAPLANDetermine the goals and objectives and develop and establish the processes necessary to deliver results inaccordance with the expected output (the goals and objectives). (Note: Focusing on the expected output differsfrom other techniques in that the completeness and accuracy of the specification is also part of the improvement).DOImplement the new processes, often on a small scale if possible, to test effectiveness.(Note: It is important to collect data for charting and analysis to perform the following “CHECK” step).CHECKMeasure the new processes and compare the results (collected in “DO” step) against the expected output(goals and objectives from the “PLAN” step) to ascertain any differences. (Note: Charting data can aid inassessing trends to convert the collected data into information needed for the “ACT” step).ACTAnalyze the differences to determine their causes and determine where to apply changes that will facilitateimprovements. (Note: When an analysis of these four steps does not indicate a need to improve, refine thescope to which PDCA is applied and perform the PDCA again until there is a plan that provides for improvement).ACTPLANImplement theBest SolutionIdentify yourProblemsCHECKDOStudyResultsTest PotentialSolutionsFigure 2: Shewart DiagramAs public reaction to serious safety andenvironmental incidents became increasingly lesstolerant, there was a desire for regulatory activity.One of the first regulations to address incidentprevention through safety management systemswas the OSHA Process Safety Management rule(29CRF1910.119), aiming to prevent the release ofhazardous liquids into the environment throughgovernment regulatory processes. Process safetymanagement requires identification of hazardsassociated with processes using highly hazardouschemicals. The Seveso Directive4 was enactedin Europe and other countries, and it serves asthe European model for hazardous liquid releaseprevention.Today, most organizations agree that developingand implementing a safety management systemis appropriate, even if not required by regulations.However, the requirements and application ofa safety management system is specific to theprocesses, materials and potential hazards ofindividual organizations and facilities.This guidebook is intended to assist organizationsin understanding and applying safety managementsystem to overfill prevention processes, arequirement of API 2350.

Guidebook for Overfill Prevention & Tank GaugingOPP Requirements of API 2350API 2350 states, “A management system is required forconformance with API 2350, but this standard does notspecify how to implement such a system.” The reasonthat API 2350 does not specify how to implement asafety management system is that each system mustbe specifically designed for the organization andfacility using it. It must be remembered that safetymanagement systems were initially created by and forlarge organizations. Smaller companies must designand implement safety management systems that fittheir personnel, resources, equipment, and operations,all of which may be smaller than and different fromthose of the large corporations. However, many smallerorganizations are not taking advantage of formalmanagement systems which include OPP. One criticalkey to developing and using effective managementsystems for smaller organizations is to make thesystems applicable to specific operations or purposes.Some larger organizations have been so involvedin multiple processes (often numbering in thethousands) and corresponding complexities thattheir OPP becomes excessively costly and difficultto implement and manage. The OPP often requiresreevaluations and redesigns to meet specific changesin processes, operations, products, and conditions.Smaller companies can avoid this problem by carefullyevaluating and determining the applicable partsof safety management systems and intelligentlyincorporating them into their own standards, operatingprocedures, and work practices. Many larger companiesare in the process of making their corporate processessimpler and more effective for easier resourceallocation and decision making.API 2350 further states, “If procedures for acomprehensive OPP management system do notexist, then they shall be developed or shall beincorporated by reference into any suitable existingmanagement system. The documented procedures forthe management system shall address all componentsof OPP. These include typical administrative controlssuch as management of change, operating personneltraining and auditability for the OPP components.”4API 2350 recommends that the following specificOPP requirements be established and implemented byorganizations operating storage tank facilities: Formal written operating procedures andpractices covering environmental, safety andemergency response requirements. Trained and qualified operating personnel. Functional equipment systems that are regularlytested and maintained by qualified personnel. Scheduled inspection and maintenance programs foroverfill instrumentation and other equipment. Systems to address both normal and abnormaloperating conditions including emergency shutdownand start-up following emergencies. A management of change (MOC) process whichincludes personnel, product and equipment changes.MOC is the systematic process of identifying alldownstream effects that are caused by any changeto a process. To conduct an MOC, the subject matterexperts should gather to discuss the process changeand how it will impact the downstream processes,emergency response aspects, and scheduling issues. A system to identify, investigate and communicateoverfill near misses and actual incidents. A system to share lessons learned betweenmanagement and employees. A follow-up system to address necessary mitigationof circumstances (causal factors) leading to nearmisses and actual incidents. Communication system protocols both withinthe Owner/Operator organization and betweenthe Transporter and the Owner/Operator that thatare designed to function under abnormal as wellas normal conditions.This Directive (Seveso II) replaced Directive 82/501/EEC (Seveso I, named after the Italian town which suffered exposureto an accidental release of dioxin in 1976). It introduced major changes and new concepts. It focuses on protection of theenvironment, and was the first to cover sub

Prevention & Tank Gauging Guidebook for Overfill Prevention & Tank Gauging ABSTRACT The public, the regulatory community and industry have expectations . has written publications for Endress Hauser and Emerson regarding tank level equipment as well as fire and overfill prevention. He has performed work in support of an expert witness regarding

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