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Environmental risk assessment of bulk storage facilities: A screening tool

User guide

ENVIRONMENTAL RISK ASSESSMENT OF BULK STORAGE FACILITIES: A SCREENING TOOL

USER GUIDE

First edition

May 2009

Published byENERGY INSTITUTE, LONDON

The Energy Institute is a professional membership body incorporated by Royal Charter 2003Registered charity number 1097899

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ISBN 978 0 85293 393 0

Published by the Energy Institute

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ENVIRONMENTAL RISK ASSESSMENT OF BULK STORAGE FACILITIES: A SCREENING TOOLUSER GUIDE

IIIIII

CONTENTS

Page

Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv

1 Scope and objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.2 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.3 Objectives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2 Screening assessment methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.1 Step 1: Initial assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.2 Step 2: Vulnerability assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 2.3 Step 3: Pollution prevention measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 2.4 Step 4: Overall risk assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 2.5 Step 5: Mitigation measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

3 Information resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

4 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Annexes: Annex A Example risk phrases for selected materials . . . . . . . . . . . . . . . . . . . . . . . . . . . 11Annex B Example risk phrases for selected petroleum industry products . . . . . . . . . . . 12Annex C Petroleum industry safety integrity level assessment terminology. . . . . . . . . 13Annex D Screening assessment flowchart . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Annex E Glossary of terms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Figures: Figure 1 Overall risk matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6


IVIV

ACKNOWLEDGEMENTS

This project was commissioned by the Energy Institute’s 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 LimitedBPChevronConocoPhillipsEnvironment AgencyExxonMobilProcess Safety Leadership Group – Working Group 4: Secondary and Tertiary ContainmentShell Brian SmithersTank Storage AssociationTotalVopak

The screening tool is based on initial developmental work undertaken for the Energy Institute by IKM Consulting Limited.


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1 SCOPE AND OBJECTIVES

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)¹.

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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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 caused². 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 tank’s 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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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).

The screening tool is located on the Energy Institute website (http://www.energyinst.org).

1.3 OBJECTIVES

The objectives of the screening tool are as follows:To provide a qualitative assessment of the risk presented to the environment of above- −ground bulk liquid storage tanks by considering the potential for an uncontained release of a hazardous material which may impact upon nearby sensitive receptors.To identify additional measures which could be implemented to reduce the −environmental risk of a storage facility and to prioritise them according to their cost effectiveness in terms of risk reduction versus cost of implementation.To support an application and BAT assessment required under IPPC, as implemented −by the Environmental Permitting (England and Wales) Regulations 2007 (SI 2007 No. 3538), or general regulatory interactions with the Regulator (e.g. the Environment Agency) on the subject of bulk hazardous materials storage risk.


4

2 SCREENING ASSESSMENT METHODOLOGY

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.

2.1 STEP 1: INITIAL ASSESSMENT

The initial assessment is designed to determine whether there is a source-pathway-receptor linkage for the subject storage facility by requiring information on the properties of the product and the presence of nearby receptors. Specification of material properties is based on standard risk phrases, examples of which are provided in Annex A (for an alcohol, a chlorinated DNAPL and two foodstuff materials) and Annex B (for selected petroleum industry products – unleaded gasoline, diesel, biodiesel and Jet A-1). However, the tool incorporates a full listing of risk phrases via an embedded drop-down table which facilitates easy selection into the assessment according to established material properties.

Likewise, an embedded drop-down table offers a range of options with regard to sensitive receptors which can be selected into the assessment, for example, the presence of an aquifer, water abstractions, tidal surface waters, etc.

A key aspect of the initial assessment is determining whether the product is flammable or highly flammable, which predetermines whether the firewater containment assessment is required within the full screening assessment. If the product is non-flammable then the tool will automatically assign the firewater containment assessment to low risk and answer the questions ‘not applicable’.

If the source-pathway-receptor linkage is unbroken, the tool indicates that the risk assessment is required and Steps 2 to 5 must be completed. If the linkage is broken, for example, owing to the absence of receptors, or if the material stored is not hazardous, then the tool indicates that no further assessment will be required.

The environmental risk rating is developed from the two key assessment steps of the tool: the vulnerability assessment (Step 2) and the PPM assessment (Step 3), which is divided into assessment of primary, secondary and tertiary containment.


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2.2 STEP 2: VULNERABILITY ASSESSMENT

The purpose of the vulnerability assessment is to provide information upon which an assessment of the vulnerability of the environment surrounding and underlying the storage facility may be based. The tool therefore considers the nature of the underlying ground and groundwater and the proximity of surface water via a number of questions which offer a drop-down selection of answers.

Where information is not known, details should be obtained (for a small cost) from the information resources listed in Section 3. Alternatively, the 'don’t know' drop-down option can be selected, although it should be noted that this option automatically assigns the highest level of vulnerability.

An evaluation of the environmental vulnerability is given in the top right-hand corner of the screen in the form of a simple 'traffic light', for universal understanding: green for low vulnerability, amber for medium vulnerability and red for high vulnerability. In order to establish the rating, all questions in the section must be completed. The traffic light rating is also reproduced for individual questions to the right of each question.

2.3 STEP 3: POLLUTION PREVENTION MEASURES

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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2.4 STEP 4: OVERALL RISK ASSESSMENT

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.

Figure 1 Overall risk matrix

Vuln

erab

ility

ass

essm

ent

High M H H

Medium L M H

Low L L M

Low Medium High

Pollution prevention measures

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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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.

2.5 STEP 5: MITIGATION MEASURES

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:

API Soil and Groundwater Technical Task Force

Bulletin 24, Downward solute plume migration: Assessment, significance and implications for characterisation and monitoring of 'diving plumes', April 2006.

BP Exploration Operating Co. Ltd

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.

Buncefield Major Incident Investigation Board

Recommendations on land use planning and the control of societal risk around major hazard sites, July 2008.

Explosion mechanism advisory group report, August 2007.

Buncefield Standards Task Group (BSTG) Final Report, Safety and environmental standards for fuel storage sites, July 2007.

Recommendations on the emergency preparedness for response to and recovery from incidents, July 2007.

Recommendations on the design and operation of fuel storage sites, March 2007.

Buncefield major incident investigation, initial report, July 2006.

Control of major accident hazards directive – major accident: Short report, July 2006.

The Buncefield investigation progress report, February 2006.

The Buncefield investigation second progress report, April 2006.

The Buncefield investigation third progress report, May 2006.


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Environment Agency

Underground under threat, groundwater protection: Policy and practice, GP3 Parts 1–4, 2008.

Environment Agency, Scottish Environment Protection Agency, NI Environment & Heritage Service

Pollution Prevention Guideline PPG17, Dairies and other milk handling operations, environmental alliance.

HSE

HSG 176, Storage of flammable liquids in tanks, 1998.


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ANNEX A EXAMPLE RISK PHRASES FOR SELECTED MATERIALS

Substance Risk Phrase Description

Alcohol(Methanol)

R11 Highly flammable

R23 Toxic by inhalation

R24 Toxic in contact with skin

R25 Toxic if swallowed

R39 Danger of very serious irreversible effects

Chlorinated DNAPL (Trichloroethylene)

R20 Harmful by inhalation

R21 Harmful in contact with skin

R22 Harmful if swallowed

R40 Limited evidence of a carcinogenic effect

R52/R53Harmful to aquatic organisms, may cause long-term adverse effects in the aquatic environment

Foodstuff (Orange Juice)

R38 Irritating to the skin

R51/53Toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment

Foodstuff(Milk)



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ANNEX B EXAMPLE RISK PHRASES FOR SELECTED PETROLEUM

INDUSTRY PRODUCTS

Substance Risk Phrase Description

Unleaded Petrol (Gasoline)

R12 Extremely flammable

R45 May cause cancer

R46 May cause heritable genetic damage

R63 Possible risk of harm to the unborn child

R65 Harmful: may cause lung damage if swallowed

R38 Irritating to skin

R67 Vapours may cause drowsiness and dizziness


Diesel

R40 Limited evidence of a carcinogenic effect


R66Repeated exposure may cause skin dryness or cracking


Biodiesel R65 Harmful: may cause lung damage if swallowed

Jet A-1

R10 Flammable


R38 Irritating to skin



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ANNEX C

PETROLEUM INDUSTRY SAFETY INTEGRITY LEVEL ASSESSMENT TERMINOLOGY

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?

STOP No further assessment necessary

Complete Primary

Containment Assessment

Complete Secondary

Containment Assessment

Complete Tertiary and

Firewater Containment Assessment

Risk Assessment

Identify risk mitigation

options and ascribe costs


Are there any nearby sensitive

receptors?

Low Risk

Is the material hazardous?


Medium Risk High Risk

Is risk ALARP?

Yes

Yes

Yes

No

No

No


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ANNEX E GLOSSARY OF TERMS

ALARP: as low as reasonably practicable.

AST: above-ground storage tank.

BAT: best available technique.

BReF: BAT reference note.

DNAPL: dense non-aqueous phase liquid.

EI: the Energy Institute.

Installation: an IPPC installation as defined under the environmental permitting (England and Wales) Regulations 2007 (SI 2007 no. 3538).

IPPC: integrated pollution prevention control.

PPM: pollution prevention measures.

SEPA: Scottish Environmental Protection Agency.

SIL: safety integrity level.

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This publication has been produced as a result of

work carried out within the Technical Team of the

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provides industry with cost effective, value adding

knowledge on key current and future issues

affecting those operating in the energy sector,

both in the UK and beyond.

Registered Charity Number 1097899

ISBN 978 0 85293 393 0