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A screening tool
User guide
ENVIRONMENTAL RISK ASSESSMENT OF BULK STORAGE FACILITIES: A SCREENING TOOL
USER GUIDE
First edition
May 2009
Published by
ENERGY INSTITUTE, LONDON
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Registered charity number 1097899
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This publication has been produced as a result of work carried out within the Technical Team of the Energy Institute (EI), funded by the EIs
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CONTENTS
Page
Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv
3 Information resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
4 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Annexes:
Annex A Example risk phrases for selected materials . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Annex B Example risk phrases for selected petroleum industry products . . . . . . . . . . . 12
Annex C Petroleum industry safety integrity level assessment terminology . . . . . . . . 13
Annex D Screening assessment flowchart . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Annex E Glossary of terms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Figures:
Figure 1 Overall risk matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
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ENVIRONMENTAL RISK ASSESSMENT OF BULK STORAGE FACILITIES: A SCREENING TOOL
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ACKNOWLEDGEMENTS
This project was commissioned by the Energy Institutes Soil Waste Groundwater Group.
The EI wishes to record its appreciation of the work carried out by the Soil Waste Groundwater Group
and others who participated in the development of the screening tool and technical review stages.
In particular the EI would like to thank the following companies/organisations for their valuable
contributions:
Atkins Limited
BP
Chevron
ConocoPhillips
Environment Agency
ExxonMobil
Process Safety Leadership Group Working Group 4: Secondary and Tertiary Containment
Shell
Brian Smithers
Tank Storage Association
Total
Vopak
The screening tool is based on initial developmental work undertaken for the Energy Institute by IKM
Consulting Limited.
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ENVIRONMENTAL RISK ASSESSMENT OF BULK STORAGE FACILITIES: A SCREENING TOOL
USER GUIDE
1.1 INTRODUCTION
The Environmental risk assessment of bulk storage facilities screening tool ('the tool') assesses
the risk to the environment of above-ground bulk liquid storage tanks (ASTs) by considering
the potential for an uncontained release of stored material which may impact upon nearby
sensitive receptors. This report sets out the rationale and fundamental assumptions behind
the tool.
Clearly, it is the aim of any storage facility operator to contain stored liquids within the
primary containment (i.e. the tank). It should be understood that any assumption of a release
inherent in this methodology is for the purposes of assessing the risk to the environment
only.
A detailed probabilistic risk assessment of a storage tank facility can be a time-
consuming and costly undertaking. For this reason, the Energy Institute commissioned the
development of this screening tool to enable storage tank operators to carry out a rapid
assessment of their facilities based upon readily available, or easily obtainable, information
on the receiving environment and the design and operation of the primary, secondary and
tertiary pollution prevention measures (PPM).
The screening methodology is based upon a standard source-pathway-receptor
model and takes into account factors such as the hazardous properties of the stored material,
the proximity and sensitivity of nearby surface and sub-surface receptors, the geological
setting of the storage site and the PPM that are in place.
Owing to their global applicability in the context of storage facilities (and, in particular,
storage facilities holding hazardous liquids), the tool takes account of some of the outcomes
of the investigation into the incident at the Buncefield storage facility (UK, December 2005).
Users may consider reference to national containment policies for the country of use helpful in
the context of deploying this tool (where available for example, the UK COMAH Competent
authority policy on containment of bulk hazardous liquids).
The tool comprises one methodology in the first tier of available risk assessment
techniques and is a screening device for the environmental risks associated with the storage
of bulk liquid in a particular location: it does not present a numerically evaluated, probabilistic
assessment of the likelihood of a particular event, nor does it attempt to quantify the likely
consequence of that event. The tool does not provide a definitive site specific assessment and
should only be used for screening purposes.
It is important to note that the tool does not consider toxicity to humans: alternative
means of assessment (or, indeed, containment) may be appropriate in this regard.
1 COMAH Competent authority policy on containment of bulk hazardous liquids at COMAH establishments;
HSE/Environment Agency/SEPA; February 2008; note that the screening tool does not fully address the
detailed requirements of this policy owing to its UK specificity.
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ENVIRONMENTAL RISK ASSESSMENT OF BULK STORAGE FACILITIES: A SCREENING TOOL
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1.2 BACKGROUND
The European Directive 96/61/EC on Integrated Pollution Prevention and Control (IPPC) ('the
Directive') as enacted in the UK under the Pollution Prevention and Control Act 1999 (now
implemented in England and Wales under the Environmental Permitting (England and Wales)
Regulations 2007 (SI 2007 No. 3538)) requires operators of bulk hazardous materials
storage facilities (installations) to use best available techniques (BAT) to prevent or minimise
pollution from the operation of the installation, such that significant pollution will not be
caused. Guidance on what represents BAT is provided in the Reference document on best
available techniques on emissions from storage, commonly referred to as the Storage BReF
Note.
In the UK, an installation covered by the Directive must obtain a permit from the
Environment Agency (England and Wales), the Scottish Environmental Protection Agency
(SEPA Scotland) or the Northern Ireland Environment Agency (NIEA), in order to operate. A
permit must be applied for and an evaluation of BAT for the installation a 'BAT assessment'
must be included within the application.
Above-ground storage tanks have the potential to cause pollution to the surface
and sub-surface environments via the release of potentially hazardous liquids, where a
release can arise through (for example) leakage, corrosion-induced failure of the tank and its
associated pipework, tank over-filling or, in the extreme case, tank rupture. The likelihood of
the occurrence of a release will be dependent upon the PPM, including a range of primary
containment factors such as the tanks design specification, control systems (e.g. gauging
and alarms), the degree of corrosion protection and the extent and frequency of inspection
and condition monitoring regimes.
Storage tanks should be equipped with secondary containment (e.g. bunding)
which provides a measure of security against the spread of pollution should a loss of
primary containment occur. The effectiveness of the secondary containment as a PPM
including its effectiveness at preventing a spillage from penetrating the underlying ground
and groundwater is dependent upon its capacity, materials of construction and physical
condition.
Storage facilities should also be equipped with tertiary containment to minimise
the consequence of potential failures in the primary and secondary containment systems by
providing an additional barrier to prevent the uncontrolled spread of any lost bulk liquids.
The effectiveness of the tertiary containment PPM is dependent on a range of factors which
include independence from the secondary containment, impermeability to water and the
stored liquid, cellular construction (with the facility to isolate specific cells) and the capacity
to hold the stored liquid and foreseeable entrained or dissolved pollutants.
The design and installation of all PPM should provide for the retention of full
containment capability under the circumstances of prolonged exposure to fire, recognising
2 Bulk storage is covered under the following sections of Part 2 of Schedule 1 to the Environmental permitting
(England and Wales) Regulations 2007 (SI 2007 No. 3538): section 1.2 Part A (1) (h) 'The loading, unloading,
handling or storage of, or the physical, chemical or thermal treatment of (i) crude oil; (ii) stabilised crude
petroleum; (iii) crude shale oil; (iv) where related to another activity described in this paragraph, any
associated gas or condensate; or (v) emulsified hydrocarbons intended for use as a fuel.'; and, Section 4.8
Part B (a) 'The storage in tanks, other than in tanks for the time being forming part of a powered vehicle,
of any of the substances listed below except where the total storage capacity of the tanks installed at the
location in question in which the relevant substance may be stored is less than the figure specified below in
relation to that substance (i) one or more acrylates, 20 tonnes (in aggregate); (ii) acrylonitrile, 20 tonnes;
(iii) anhydrous ammonia, 100 tonnes; (iv) anhydrous hydrogen fluoride, 1 tonne; (v) toluene di-isocyanate,
20 tonnes; (vi) vinyl chloride monomer, 20 tonnes; (vii) ethylene, 8,000 tonnes.'
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ENVIRONMENTAL RISK ASSESSMENT OF BULK STORAGE FACILITIES: A SCREENING TOOL
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the potential for premature failure which the fire scenario presents. Resistance to fire damage
leading to loss of containment should therefore be an inherent component of the design and
installation of the PPM.
In addition, secondary and tertiary containment PPMs should take into account the
need to hold and contain significant volumes of (potentially contaminated) firewater which
may arise in the fire scenario. The holding capacity should be based on a realistic, worst case
assessment of the foreseeable volumes of firewater which may be generated.
Operational procedures (e.g. covering material transfers or bulk loading or unloading
activities) and training of operational staff in their application provide further measures for
the control and prevention of potential releases. Emergency response systems are also very
important: it is essential that such emergency response measures are available for rapid
deployment and that their deployment and use is rehearsed on a regular basis.
The overall environmental risk posed by a storage facility will be dependent upon
the condition of the source (i.e. the storage tank and its contents, together with associated
PPMs), the presence of a pathway (e.g. perhaps presented by porous secondary containment
and permeable subsurface geological formations) and the presence of a receptor (such as an
aquifer).
The primary purpose of the assessment tool is to enable the determination of the
environmental risk in qualitative terms (low, medium or high) and the exploration of options
for the reduction of this risk. However, the screening tool may equally be deployed in support
of applications and BAT assessments required under IPPC and general regulatory interactions
with the Regulator (e.g. the Environment Agency) on the subject of bulk hazardous materials
storage risk.
The screening tool concept was originally developed in Microsoft Excel and was
subjected to a comprehensive field trial by a number of tank storage operators over an
extended period of time. The tool has now been completely rebuilt in Microsoft Access
(which facilitates packaging as a universally downloadable, executable program with in-built
Help facility and guidance), taking into account the following:
The feedback from the field trial received from the storage tank operators and the
members of the EI Working Group (including the Environment Agency).
The latest guidance arising from the investigation into the major incident at the
Buncefield oil storage and transfer depot, Hemel Hempstead, on 11 December
2005.
The latest guidance from the Environment Agency on the protection of groundwater
(GP3).
1.3 OBJECTIVES
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ENVIRONMENTAL RISK ASSESSMENT OF BULK STORAGE FACILITIES: A SCREENING TOOL
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The screening tool methodology operates in Microsoft Access and is based on the five-step
process highlighted below. It is user friendly and predominantly based on selection from
drop-down listings in response to targeted questions.
Aspects of each step are described in more detail below.
Step 1: Initial assessment;
Step 2: Vulnerability assessment;
Step 3: Assessment of pollution prevention measures;
Primary containment;
Secondary containment;
Tertiary and firewater containment;
Step 4: Overall risk assessment, and
Step 5: Exploration and evaluation of mitigation measures.
All sections of the tool have an information button labelled 'Help with this screen?' providing
in-process guidance for the use of the tool. Likewise, most questions within the tool have
a similar information button providing guidance for the specific question, where this is
appropriate.
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ENVIRONMENTAL RISK ASSESSMENT OF BULK STORAGE FACILITIES: A SCREENING TOOL
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The PPM assessment is made up of three individual evaluations covering primary, secondary,
and tertiary and firewater containment, which are described below:
Primary containment requires information upon which an assessment can be made
of the likelihood of a release occurring from an above-ground storage tank based
upon factors such as its design and control techniques (e.g., level gauging, alarms,
etc).
Secondary containment the principal concern here is with the design and condition
of storage tank bunding rather than the tank itself, based upon factors such as
penetration by pipe work, materials of construction, resistance to fire, etc.
Tertiary and firewater containment requires information on whether additional
barriers are in place to contain and prevent the spread of liquid if the primary and
secondary containment systems should fail and, if the stored product is flammable,
information on firewater containment measures and fire resistance.
As for the vulnerability assessment, the risk rating system for the PPM is based on a traffic
light indicator. Risk ratings are given to the individual assessments (primary, secondary, and
tertiary and firewater) but to generate the overall risk rating for PPM, all three assessments
must be completed. As with the vulnerability assessment, individual ratings are provided for
each assessment question response.
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ENVIRONMENTAL RISK ASSESSMENT OF BULK STORAGE FACILITIES: A SCREENING TOOL
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The screening tool generates a qualitative ranking of the risk to the environment, based on
the vulnerability and PPM assessments, according to the risk matrix shown in Figure 1.
High M H H
Medium L M H
Low L L M
This is described as the unmitigated risk rating of the bulk storage tank facility and indicates
the risk presented by the existing status of the Installation. The risk will fall within one of
three categories:
Low Where the overall risk is considered to be acceptable, either because of low
environmental vulnerability or the reduction in risk offered by adequate and
sufficient PPMs; it is unlikely that consideration of further risk mitigation measures
will be necessary.
Medium Where the overall risk is considered to be unacceptable, either because of the high
vulnerability or inadequate PPMs; mitigation measures to reduce the risk should be
evaluated for implementation.
High Where the overall risk is considered to be unacceptable, either because of the high
vulnerability or the absence and/or inadequacy of PPMs; mitigation measures to
reduce the risk must be evaluated for implementation.
It should be noted that, even if the PPM assessment produces a low risk result overall, with
individual low risk results for the primary, secondary and tertiary containment measures, it is
still possible that the overall risk result will be medium or high if the vulnerability assessment is
high. This is because a site may be high risk purely because of its location and the surrounding
and underlying environmental features. Even with the deployment of BAT, indicated by a low
risk result for the PPM, the vulnerability of the surrounding and underlying environment is
unchanged and the overall risk will remain medium or high. Clearly, if this type of assessment
were conducted prior to the construction of a new facility, such a result may indicate that
the facility would be better built elsewhere in order to avoid the risk altogether. However,
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ENVIRONMENTAL RISK ASSESSMENT OF BULK STORAGE FACILITIES: A SCREENING TOOL
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for an existing facility, this type of result presents a set of circumstances which is likely to
require further in-depth consideration and evaluation, in conjunction with input from the
Regulator.
The generation of a medium or high risk rating indicates that further PPMs may be necessary
to secure an acceptable level of risk to the environment. On completion of the assessment, the
evaluation of further PPM options within the tool allows the determination of the optimum
combination of additional measures for the most cost effective reduction of the risk rating.
Once all assessment questions have been answered on each PPM assessment page,
the tool identifies the options which are available on that page for reducing the risk rating in
the area of each specific assessment question. The tool offers the facility to manually insert
site-specific costings for selected options so that they may be ranked in order of effectiveness
(in reducing the risk) and cost of implementation. The most cost effective combination of
mitigation measures can then be selected and the assessment revised to reflect the reduction
in risk rating which will be secured.
The revised risk rating is displayed in the top right-hand corner of the page and in
the indicator boxes for the individual assessment criteria. On the overall assessment page,
the effect on overall risk rating resulting from the implementation of further risk mitigation
options is shown in the table headed 'Mitigated risk rating'. If the risk is still showing as high
or medium, a further range of mitigation options should be selected for consideration, ideally
until the displayed mitigated risk rating is low. With a risk rating of 'low', further, more costly,
site specific assessment may not be necessary, assuming the selected package of additional
mitigating measures are implemented.
The costs associated with the selected mitigation options are summarised in the table
headed 'Cost of mitigation'.
If the risk rating generated is high or medium, it may be necessary to consider more
detailed site specific investigation and risk assessment to develop a more robust assessment
of risk and consequence, based on a more structured probabilistic evaluation of the likelihood
of a particular event and the potential consequences arising from its occurrence. This may
include intrusive site investigations to establish underlying geology in more detail to facilitate
a more accurate assessment of the likelihood of sub-surface migration of spillages.
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3 INFORMATION RESOURCES
Environmental risk information for UK sites can be obtained, on commercial terms, from a
number of sources which include:
Environment Agency (http://www.environment-agency.gov.uk).
Scottish Environment Protection Agency (SEPA) (http://www.sepa.org.uk).
Northern Ireland Environment Agency (http://www.ni-environment.gov.uk).
Landmark Information Group (http://www.landmarkinfo.co.uk/corp/index.jsp).
British Geological Survey (BGS) Mapping (http://www.bgs.ac.uk).
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4 REFERENCES
Integrated pollution prevention and control. Reference document on best available techniques
on emissions from storage, European Commission, January 2005.
The following documents were referenced during development of the screening tool:
Bulletin 24, Downward solute plume migration: Assessment, significance and implications
for characterisation and monitoring of 'diving plumes', April 2006.
SPR/NDT/015/98, Rational decision taking for bund lining of above ground storage tanks,
24 December 1998.
BSI
BS 476-10:2009, Fire tests on building materials and structures. Guide to the principles,
selection, role and application of fire testing and their outputs, December 2008.
Recommendations on land use planning and the control of societal risk around major hazard
sites, July 2008.
Buncefield Standards Task Group (BSTG) Final Report, Safety and environmental standards
for fuel storage sites, July 2007.
Recommendations on the design and operation of fuel storage sites, March 2007.
Control of major accident hazards directive major accident: Short report, July 2006.
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Environment Agency
Underground under threat, groundwater protection: Policy and practice, GP3 Parts 14,
2008.
Pollution Prevention Guideline PPG17, Dairies and other milk handling operations,
environmental alliance.
HSE
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ANNEX A
EXAMPLE RISK PHRASES FOR SELECTED MATERIALS
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ENVIRONMENTAL RISK ASSESSMENT OF BULK STORAGE FACILITIES: A SCREENING TOOL
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ANNEX B
EXAMPLE RISK PHRASES FOR SELECTED PETROLEUM
INDUSTRY PRODUCTS
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ANNEX C
Note: This Annex is in preparation. Full details will be added in due course.
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ANNEX D
SCREENING ASSESSMENT FLOWCHART
What is the
stored material?
Is the material No
hazardous?
STOP
Yes No further
assessment
necessary
Yes
Complete
Primary
Containment
Assessment
Identify risk
mitigation
Complete options and
Secondary ascribe costs
Containment
Assessment
Complete
Tertiary and
Firewater
Containment
Assessment
Risk Assessment
STOP No
Is risk
No further ALARP?
assessment
necessary
Yes
STOP
No further
assessment
necessary
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ENVIRONMENTAL RISK ASSESSMENT OF BULK STORAGE FACILITIES: A SCREENING TOOL
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ANNEX E
GLOSSARY OF TERMS
15
Energy Institute This publication has been produced as a result of
61 New Cavendish Street work carried out within the Technical Team of the
London W1G 7AR, UK Energy Institute (EI), funded by the EIs Technical
Partners. The EIs Technical Work Programme
t: +44 (0) 20 7467 7100 provides industry with cost effective, value adding
f: +44 (0) 20 7255 1472 knowledge on key current and future issues
e: pubs@energyinst.org affecting those operating in the energy sector,
www.energyinst.org both in the UK and beyond.