CDOIF
Chemical and Downstream Oil Industries Forum
Guideline
Leak Detection
Guideline – Leak Detection v0.6 Page 1 of 25
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Foreword
In promoting and leading on key sector process safety initiatives, CDOIF has developed through its
members this guideline on available leak detection techniques for Above-ground Storage Tanks
(AST).
The intent of this document is to provide a reference for those organisations wishing to consider the
use of leak detection systems to provide mitigation against the loss of product from an AST.
It is not the intention of this document to replace any existing corporate policies or processes. The
intent is to provide a reference to users to help in the selection of appropriate leak detection
techniques.
There are no limitations on further distribution of this guideline to other organisations outside of
CDOIF membership, provided that:
1. It is understood that this report represents CDOIF’s view of common guidelines as applied
to leak detection.
2. CDOIF accepts no responsibility in terms of the use or misuse of this document.
3. The report is distributed in a read only format, such that the name and content is not
changed and that it is consistently referred to as "CDOIF Guideline – Leak Detection".
4. It is understood that no warranty is given in relation to the accuracy or completeness of
information contained in the report except that it is believed to be substantially correct at the
time of publication.
It should be understood that this document does not explore all possible options for leak detection,
nor does it consider individual site requirements – Following the guidance is not compulsory and
duty holders are free to take other action.
Guideline – Leak Detection v0.6 Page 2 of 25
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Contents
1. EXECUTIVE SUMMARY........................................................................................................4
2. INTRODUCTION AND SCOPE..............................................................................................5
3. TECHNIQUES FOR LEAK DETECTION................................................................................6
3.1 Gas detection within the tank bund.............................................................................9
3.2 Tank base perimeter/bund floor point detectors........................................................10
3.3 Sump/interceptor point or interface detectors ...........................................................11
3.4 Hydrocarbon detection tapes installed in the bund floor or underneath the tank .......12
3.5 Under tank membrane with tell-tail leak detection.....................................................13
3.6 Interspace loss of vacuum detection.........................................................................14
3.7 Tank level gauging with product loss alarm ..............................................................15
3.8 Point or interface detection at floating roof drain valve outlet....................................16
3.9 Point or interface detection at bund drain valve outlet...............................................17
3.10 Point or interface detection at tank water draw valve outlet ......................................18
4. RISK REDUCTION CONSIDERATION................................................................................19
4.1 Defining the mitigation layer .....................................................................................20
4.2 Claiming risk reduction .............................................................................................21
Abbreviations...................................................................................................................................22
Other relevant publications ..............................................................................................................23
Acknowledgements .........................................................................................................................24
Revision History...............................................................................................................................25
Guideline – Leak Detection v0.6 Page 3 of 25
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
1. EXECUTIVE SUMMARY
Hazardous substances which are stored in above-ground storage tanks could have the
potential to pollute the environment or harm people if the primary containment measure
in which they are stored (i.e. the tank) fails.
Leak detection is one method by which hydrocarbons can be detected should primary
containment fail. Early indication of the failure may ensure that mitigation measures to
prevent escalation of the scenario can be deployed quickly.
The final report of the Process Safety Leadership Groups (PSLG) safety and
environmental standards for fuel storage sites was published in December 2009. Part 2
of that report provides limited guidance on the use of gas and liquid detection systems to
detect overflows from a bulk storage tanks. A research report commissioned by the
Health and Safety Laboratory (HSL), entitled ‘A review of leak detection for fuel storage
sites, ECM/2008/08’ provided further guidance.
As part of its role to deliver improvements in health, safety and the environment, the
CDOIF Process Safety Work-stream agreed to examine the types of leak detection that
had been successfully implemented in the UK. A working group was commissioned to
develop this guideline to assist duty holders in the selection of appropriate techniques
and what impact these systems may have in terms of risk reduction.
There are different leak detection methodologies available, which each have their own
strengths and weaknesses. Methodologies considered in terms of their benefits,
limitations and indicative costs are described in section 3, Techniques for Leak
Detection.
Leak detection systems may reduce the risk to people or the environment. They could
be considered as a further layer of protection against specific scenarios or be considered
a more cost effective risk reduction technique as part of an ALARP (As Low As
Reasonably Practicable) demonstration. The possibility of spurious trips will discourage
their use in automatic systems, whether in the Basic Process Control System (BPCS) or
Safety Instrumented System (SIS). As per other guidance, any claims for risk reduction
as an additional mitigation barrier will require justification in terms of clearly defined
operating procedures and emergency responses.
Guideline – Leak Detection v0.6 Page 4 of 25
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
2. INTRODUCTION AND SCOPE
Leak detection in the context of this guidance relates to the detection of hydrocarbons
following the failure of primary containment. Primary containment inside a bund consists
of the tank shell and associated pipe work. Primary containment may fail in any of the
following ways:
• The tank is over-filled, resulting in loss of product from the top of the tank, or
through roof vents
• Failure of the tank floor
• Failure of the tank wall joints
• Catastrophic tank failure
• Failure of pipe-work associated with the tank
• Failure of pipe-work running through the bund
The risk of these failures occurring can be reduced significantly through measures such
as good inspection, maintenance and repair processes, and where appropriate the
installation of preventative systems such as overfill protection. Leak detection systems
can complement these other measures to reduce the risk further, or they may also
provide an alternative means of risk reduction when other systems or processes are
disproportionate in terms of the risk reduction achieved versus the cost.
This guidance should not be interpreted as a requirement to install such systems, but
instead provide a useful reference to those duty holders who may be considering the
installation of leak detection for the reasons stated. Other techniques are available, and
cost will be variable depending on the technology adopted and existing site
infrastructure. Consideration should also be given to the sensitivities of any installed
system to spurious trips during routine operations (such as flushing), and procedures
should be updated accordingly.
The following sections provide an overview of typical leak detection systems adopted by
the downstream oil industry in the UK – this list is not exhaustive and other techniques
may also be available.
Guideline – Leak Detection v0.6 Page 5 of 25
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
3. TECHNIQUES FOR LEAK DETECTION
Leak detection may be considered as one mechanism for the early detection of failure of
primary containment. Typical examples of Hydrocarbon detection techniques include:
• Gas detection (point sensors)
• Point detectors placed around the circumference of the tank or in the bund floor
• Interface or level detectors placed in an interceptor or sump
• Hydrocarbon detection ‘tapes’ installed in the bund floor, or underneath the base
of the tank
• Under tank membrane with tell-tail leak detection
• Interspace loss of vacuum detection
• Tank level gauging with product loss alarm (wet-stock reconciliation)
• Point or interface detectors located at the outlet to a floating roof drain valve
• Point or interface detectors located at the outlet to a bund drain valve
• Point or interface detectors located at the outlet to a tank water draw valve
Guideline – Leak Detection v0.6 Page 6 of 25
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joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
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Industries Forum
Figure 1 – Examples of Hydrocarbon detection points
Guideline – Leak Detection v0.6 Page 7 of 25
CDOIF
Chemical and Downstream Oil
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CDOIF is a collaborative venture formed to agree strategic areas for
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benefits.
When reviewing the applicability of leak detection techniques, it is important to consider
the circumstances under which it will be used, and the scenario(s) it is intended to
detect, for example:
• Installing liquid or gas detection is unlikely to have an effect on reducing the risk
to people or the environment following catastrophic tank failure, or loss of very
large volumes of product after the failure of wall joint as the volumes lost would
be significant over a very short space of time. However smaller leaks may be a
pre-curser to more significant failures, and therefore leak detection may prove
beneficial.
• Leak detection is likely to be beneficial in mitigating the risk arising from tank
over-fill, or from other significant tank leaks.
• Gas detection may be effective in detection of vapour formation following over­
topping thus limiting the size of a Flammable Vapour Cloud (FVC), but it is
unlikely to be effective in detecting a leak from the base of the tank.
• The positioning of gas detectors can be impacted by prevailing weather
conditions. Gas detectors will be much less sensitive to leaks down-wind of the
detector.
Reference should be made to section 4, Risk Reduction Consideration, for further
information on the benefits that could be claimed, and the restrictions that should be
applied when considering the chosen leak detection system in a risk assessment.
Installations appropriate to new build tanks may not be appropriate for tanks which are
refurbished.
The following sub-sections provide an analysis of typical leak detection techniques, their
benefits and limitations and indicative cost.
Guideline – Leak Detection v0.6 Page 8 of 25
3.1
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Gas detection within the tank bund
Usage Potential benefits Considerations
Indicative
Cost
Gas detectors positioned within
the bund can be used to detect
vapour cloud formation caused
either from tank over-fill or failure
of the tank shell (where these
failures are located in such a
place as to cause cascade of
product likely to form a vapour
cloud)
Early detection of loss of
containment could reduce the
size, or prevent the formation of a
large flammable vapour cloud
which may lead to a Vapour
Cloud Explosion (VCE)
Gas detection is a well
proven technology,
which is generally robust
and cost effective where
a suitable integrity,
reliability or preventative
maintenance strategy is
applied.
Effective positioning of
detectors is important as
the spread of a vapour
cloud will be directly
affected by weather
conditions.
Suitable technology
should be selected
depending upon the
product and conditions
to be detected ­
technology includes
point and open path.
Further information can
be found here:
http://www.hse.gov.uk/p
ubns/gasdetector.pdf
Gas detection would
form part of a mitigatory
Medium
Early detection of loss of
containment could reduce the risk
of a pool fire by detecting vapour
within the bund before ignition.
protection layer – alarm
activation would be
required to initiate
further action and/or
emergency response.
This further activity
would be required to be
clearly defined and
subject to periodic
testing.
Guideline – Leak Detection v0.6 Page 9 of 25
3.2
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Tank base perimeter/bund floor point detectors
Usage Potential benefits Considerations
Indicative
Cost
Liquid point detectors positioned
around the base of the tank, or in
the bund floor (typically in the
lowest gradients of the bund floor)
can be used to detect loss of
containment into the bund, either
from tank over-fill or failure of the
tank shell. In some instances this
may also detect loss of
containment from the tank floor,
though this will be dependent on
the topology and geology of the
bund underneath the tank
Early detection of hydrocarbons in
the bund could reduce the size, or
prevent the formation of a large
flammable vapour cloud which
may lead to a VCE
Early detection of hydrocarbons in
the bund may be used to reduce
the risk of pool fires.
Early detection of hydrocarbons in
the bund may also provide an
early indication of loss of
containment, reducing the risk of
a Major Accident to the
Environment (MATTE)
Liquid point detectors
can provide an early
indication of
hydrocarbons within the
bund, reducing the
escalation of several
scenarios which if
undetected could lead to
a VCE or a MATTE.
Liquid point detection
may be subject to
spurious trips due to
bund materials which
may already be
contaminated, or
through rain water
collecting in the bund.
Detection is only
effective at the point of
measurement, and
therefore the positioning
and number of detectors
require careful
consideration
Care should be taken
when claiming credit for
the reduction in size of a
flammable vapour cloud,
as liquid would only be
detected in the bund if
the tank was already
overflowing – giving time
for the vapour cloud to
form.
Liquid point detection
within the bund would
form part of a mitigatory
protection layer – alarm
activation would be
required to initiate
further action and/or
emergency response.
This further activity
would be required to be
clearly defined and
subject to periodic
testing.
Medium
Guideline – Leak Detection v0.6 Page 10 of 25
3.3
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Sump/interceptor point or interface detectors
Usage Potential benefits Considerations
Indicative
Cost
Liquid Point Detectors positioned
in the bund sump or interceptor
can come in two forms:
1. Simple level switch (fitted
with a displacer for
greater accuracy), or
2. Interface level detectors
These technologies can be used
to detect loss of containment into
the bund either from tank over-fill
or failure of the tank shell. In
some instances this may also
detect loss of containment from
the tank floor, though this will be
dependent on the topology and
geology of the bund underneath
the tank
Early detection of hydrocarbons in
the bund sump or interceptor may
be used to reduce the risk of pool
fires.
Early detection of hydrocarbons in
the bund sump or interceptor may
also provide an indication of loss
of containment, reducing the risk
of a MATTE
Bund sump or
interceptor
liquid/interface detectors
can provide an early
indication of
hydrocarbons within the
bund, reducing the
escalation of several
scenarios which if
undetected could lead to
a MATTE.
Interface level detectors
in particular have been
shown to be very
reliable and easy to
maintain.
Simple level switches in
particular can be subject
to spurious trips due to
rain water collecting in
the bund.
Liquid Point Detection is
only effective at the
point of measurement,
and therefore detection
will only occur where
product collects in the
bund sump/interceptor
Bund sump or
interceptor
liquid/interface detection
within the bund would
form part of a mitigatory
protection layer – alarm
activation would be
required to initiate
further action and/or
emergency response.
This further activity
would be required to be
clearly defined and
subject to period testing.
Hydrocarbon detection
may be linked with
executive action (for
example closing an
automated valve) if
failure is likely to result
in hydrocarbon release
into the bund
Low
Guideline – Leak Detection v0.6 Page 11 of 25
3.4
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Hydrocarbon detection tapes installed in the bund floor or underneath the
tank
Usage Potential benefits Considerations
Indicative
Cost
Hydrocarbon tape/cable detectors
Tape/cable detectors
are an effective method
for detecting leaks from
the tank floor, which
otherwise may be
undetected for some
Tape/cable detectors
can be sacrificial, and
would require
replacement following
detection.
There is a risk of
premature failure of the
system if installation is
not carefully planned
and executed.
positioned underneath the tank
floor can be used to detect loss of
containment from the tank floor.
Early detection of hydrocarbons
underneath the tank may provide
an indication of loss of
time.
Arranged in a lattice
format, this method of
detection may also
provide some accuracy
as to the location of the
Care should be taken in
assessing the
contamination that may
already exist underneath
the tank before
installation
High
containment, reducing the risk of
a MATTE
leak within the tank
floor.
Tape or cable detectors
can either be installed
underneath the tank
base (typically using a
boring technique) or
between two floors of a
double bottomed tank.
Tape/cable detection
underneath the tank
would form part of a
mitigatory protection
layer – alarm activation
would be required to
initiate further action
and/or emergency
response. This further
activity would be
required to be clearly
defined and subject to
period testing.
Guideline – Leak Detection v0.6 Page 12 of 25
3.5
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Under tank membrane with tell-tail leak detection
Usage Potential benefits Considerations
Indicative
Cost
Liquid point detectors positioned
at the outlet of under tank
floor/over membrane leak
detection pipes can be used to
detect loss of containment into the
bund from tank floor failure.
Early detection of hydrocarbons
underneath the tank may provide
an indication of loss of
containment, reducing the risk of
a MATTE
Liquid point detectors
can provide an early
indication of
hydrocarbons within the
bund, reducing the
escalation of several
scenarios which if
undetected could lead to
a MATTE.
Liquid point detection
may be subject to
spurious trips due to
bund materials which
may already be
contaminated, or
through rain water
collecting in the bund.
Detection is only
effective at the point of
measurement, and
therefore the positioning
and number of detectors
require careful
consideration
Under tank membranes
are primarily concerned
with detecting tank floor
leaks. Other leaks
leading to FVC are
unlikely to be detected.
Liquid point detection
within the bund would
form part of a mitigatory
protection layer –
routine operator
monitoring or alarm
activation would be
required to initiate
further action and/or
emergency response,
however the system
indicates failure of only
one of the containment
systems, and therefore
immediate response
may not be required.
Any further activity
would be required to be
clearly defined and
subject to periodic
testing
Low/
Medium
Guideline – Leak Detection v0.6 Page 13 of 25
3.6
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Interspace loss of vacuum detection
Usage Potential benefits Considerations
Indicative
Cost
Loss of vacuum on vacuum
annulus systems installed on tank
floors can be used to detect loss
of containment from the tank floor.
Early detection of hydrocarbons
underneath the tank may provide
an indication of loss of
containment, reducing the risk of
a MATTE
Loss of vacuum
techniques are an
effective method for
detecting leaks from the
tank floor, which
otherwise may be
undetected for some
time.
Loss of vacuum
detection systems are
installed in the space
between an internal
epoxy/steel tank floor
and the external tank
floor.
Loss of vacuum
detection systems would
form part of a mitigatory
protection layer –
routine operator
monitoring or alarm
activation would be
required to initiate
further action and/or
emergency response,
however the system
indicates failure of only
one of the containment
systems, and therefore
immediate response
may not be required.
Any further activity
would be required to be
clearly defined and
subject to periodic
testing
Medium/
High
Guideline – Leak Detection v0.6 Page 14 of 25
3.7
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Tank level gauging with product loss alarm
Usage Potential benefits Considerations
Indicative
Cost
Liquid level monitoring (wet-stock
reconciliation) of the product
within the tank can be used to
detect a loss of containment over
a period of time (for example,
where product is leaking from the
tank).
Monitoring of the tank level for
loss of containment is only
relevant during the period when
the product in the tank is
stationary (for example when no
transfers into or out of the tank
are in progress, such as when a
terminal is closed overnight).
Tank gauging systems can detect
comparatively small leaks of
product loss
Liquid level monitoring is
a well proven
technology with proven
reliability and
repeatability for
Monitoring is normally
via the tank gauging
system
The system should be
configured with a
change in level
(discrepancy) alarm that
is relayed to relevant
Low
Early detection of hydrocarbons in
the bund could reduce the size, or
prevent the formation of a large
flammable vapour cloud which
may lead to a VCE
accuracy
personnel who can take
appropriate action/.
This could either be the
central control room or
security office.
Early detection of hydrocarbons in
the bund may be used to reduce
the risk of pool fires.
Early detection of hydrocarbons in
the bund may also provide an
early indication of loss of
containment, reducing the risk of
a Major Accident to the
Environment (MATTE)
Guideline – Leak Detection v0.6 Page 15 of 25
3.8
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Point or interface detection at floating roof drain valve outlet
Usage Potential benefits Considerations
Indicative
Cost
Leak detection installed on the
outflow from a floating roof drain
valve can provide indication of a
failure of the drain line (hose or
flexible joint) or a sunken floating
roof.
Early detection of hydrocarbons in
the bund may be used to reduce
the risk of pool fires.
Cost effective when
installed in drain lines
from the outlet of the
drain valves
Functionality is only
relevant where the
policy on the site is to
leave the roof drain
normally open, in this
instance leak detection
could be beneficial. The
detection will not
function if the drain line
is closed.
Close care and attention
is needed during the
set-up and
commissioning of such
systems to prevent
spurious alarms and
avoid loss of confidence.
Detection in the drain
line would form part of a
mitigatory protection
Low
Early detection of hydrocarbons in
the bund may also provide an
early indication of loss of
containment, reducing the risk of
a Major Accident to the
Environment (MATTE)
layer – alarm activation
would be required to
initiate further action
and/or emergency
response. This further
activity would be
required to be clearly
defined and subject to
period testing.
Hydrocarbon detection
may be linked with
executive action (for
example closing an
automated valve) if
failure is likely to result
in hydrocarbon release
into the bund.
Guideline – Leak Detection v0.6 Page 16 of 25
3.9
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Point or interface detection at bund drain valve outlet
Usage Potential benefits Considerations
Indicative
Cost
Leak detection installed on the
outflow from the bund drain valve
can provide indication of over-fill
or loss of containment into the
bund.
Early detection of hydrocarbons in
the bund may be used to reduce
the risk of pool fires.
Early detection of hydrocarbons in
the bund may also provide an
early indication of loss of
containment, reducing the risk of
a Major Accident to the
Environment (MATTE)
Cost effective when
installed in drain lines
from the outlet of the
drain valves
Functionality is only
relevant where the
policy on the site is to
leave the bund drain
valve normally open, in
this instance leak
detection could be
beneficial. The
detection will not
function if the drain line
is closed.
Close care and attention
is needed during the
set-up and
commissioning of such
systems to prevent
spurious alarms and
avoid loss of confidence.
Detection in the drain
line would form part of a
mitigatory protection
layer – alarm activation
would be required to
initiate further action
and/or emergency
response. This further
activity would be
required to be clearly
defined and subject to
period testing.
Low
Guideline – Leak Detection v0.6 Page 17 of 25
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
3.10 Point or interface detection at tank water draw valve outlet
Usage Potential benefits Considerations
Indicative
Cost
Leak detection installed on the
outflow from a water drain valve
can provide indication of loss of
containment into the bund.
Early detection of hydrocarbons in
the bund may be used to reduce
the risk of pool fires.
Cost effective when
installed in drain lines
from the outlet of the
Tank water draw is
normally an attended
operation, but can take
place over long periods
of time. In these
instances, hydrocarbon
detection may be of
benefit.
Close care and attention
is needed during the
set-up and
commissioning of such
systems to prevent
spurious alarms and
avoid loss of confidence.
Detection in the water
drain line would form
part of a mitigatory Low
Early detection of hydrocarbons in
the bund may also provide an
early indication of loss of
containment, reducing the risk of
a Major Accident to the
Environment (MATTE)
drain valves protection layer – alarm
activation would be
required to initiate
further action and/or
emergency response.
This further activity
would be required to be
clearly defined and
subject to period testing.
Hydrocarbon detection
may be linked with
executive action (for
example closing an
automated valve) if
failure is likely to result
in hydrocarbon release
into the bund
Guideline – Leak Detection v0.6 Page 18 of 25
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
CDOIF health, safety and environmental improvements with cross-sector
Chemical and Downstream Oil benefits.
Industries Forum
4. RISK REDUCTION CONSIDERATION
Whether or not a leak detection system is installed will be dependent on the benefits that
it gives versus the costs of installation and maintenance - this decision should be made
by the duty holder when completing a risk assessment for the credible scenarios which
could result in loss of containment from an AST. Further guidance relating to risk
assessment can be found here:
• For the protection of people, refer to the numerous publications by the Health
and Safety Executive (HSE) for COMAH, http://www.hse.gov.uk/comah/
• For the protection of the environment, one methodology for environmental risk
assessment is provided in the CDOIF publication ‘Environmental Risk
Tolerability for COMAH Establishments’
The installation of such systems may be appropriate to reduce the risk to people or the
environment (or both). They could be considered as a further layer of protection against
specific scenarios (for example reducing the risk of the formation of a flammable vapour
cloud, or the risk of pollution to an environmental receptor), or be considered a more cost
effective risk reduction technique as part of an ALARP (As Low As Reasonably
Practicable) demonstration. However as any such system will only indicate the presence
of hydrocarbons after they have escaped from the tank, they should only be considered
as a mitigation layer.
Whilst leak detection mechanisms could be configured with an automatic action (for
example closure of an inlet valve, drain valve or stopping a transfer pump), caution
should be taken when considering these systems to be safety related as further
mitigatory actions would be required even if the automatic action1
completed
successfully, i.e.:
Figure 1 – Leak Detection Actions
These further mitigatory actions (for example emergency response) would themselves be
required to have written procedures and be tested in order to claim credit as part of the
risk assessment process.
1
There is a probability of spurious alarms with some types of leak detection technology
used in this application (detection of hydrocarbons in a bunded area) therefore due
consideration should be given to the robustness of installation before integration with an
automated action.
Guideline – Leak Detection v0.6 Page 19 of 25
4.1
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Defining the mitigation layer
Before determining the level of risk reduction that can potentially be claimed following the
installation of leak detection, it is first important to understand what potential
consequences it is intended to mitigate against, and whether it is in support of other
systems such as a Basic Process Control System (BPCS) or Safety Instrumented
System (SIS).
A risk assessment should determine if further measures are required to reduce the risk to
Tolerable if ALARP (TifALARP), and
• Where leak detection is to be considered in support of other systems such as an
SIS or BPCS to reduce overall risk (for example its purpose is to mitigate against
the formation of a large FVC or the risk to an environmental receptor from over­
filling a tank), independence from the BPCS would need to be demonstrated as
with other protection/mitigation layers such as independent alarms. Further
information on independence can be found in the following publications:
o Process Safety Leadership Group (PSLG) final report, Appendix 4
o CDOIF guideline ‘Process Safety Leadership Group – Other Products in
Scope’
• Where the leak detection system is to be considered to reduce the potential for a
MATTE but not in conjunction with other automated systems such as an SIS or
BPCS (for example its purpose is to mitigate the risk against a leak from the base
of a tank), independence would not need to be demonstrated from the BPCS (or
other systems) as the leak detection system is not providing a supporting
mitigation layer to others provided by the BPCS. Further information on
environmental risk assessments and MATTE definitions can be found in the
following publication:
o CDOIF guideline ‘Environmental Risk Tolerability for COMAH
Establishments’
When determining the appropriateness of leak detection as a mitigation layer, clear
descriptions should be given of the definition of the alarm, where and how it is sounded,
who will react to it and how they should react, and how much time is available to react.
This review should include consideration of:
• Sounding the alarm in a different location to the Central Control Room, for
example security building, to increase independence where necessary from the
existing automation systems such as the BPCS and SIS.
• Whether or not there is a need for investigation by local operators should the leak
detection system alarm, and how long this would take.
• Standard and Emergency operating procedures which define what needs to be
done when the alarm is sounded, for example:
o Transfer of the substance to another location
Guideline – Leak Detection v0.6 Page 20 of 25
4.2
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
o Adding water to the tank (where this is a viable option for the type of
substance)
o Shutdown of the process, sub-process or transfer
Note that leak detection introduced as a mitigation layer may reduce the consequence of
loss of primary containment, but would not reduce the frequency.
Claiming risk reduction
The installation of appropriate leak detection, and supporting operational and emergency
procedures can contribute to overall risk reduction in any of the following ways:
• Providing a layer of protection (or additional layer of protection) reducing the
overall risk to people and the environment to TifALARP
• Providing an additional layer of protection in support of existing systems which
may in turn reduce the Safety Integrity Level (SIL) required by a SIS (Note
however installation of leak detection does not negate the need for an
independent SIS for overfill protection on finished gasoline tanks within the
scope of the PSLG)
• Providing the potential for an alternative (subject to ALARP and Cost Benefit
Analysis (CBA)) and more cost effective mechanism for reducing the risk of a
MATTE as part of an ALARP demonstration
Following existing guidance relating to alarm systems as layers of protection, the claimed
risk reduction for leak detection systems can be 0.1 (subject to the requirements laid out
in this guideline, and other applicable publications, and appropriate justification). A claim
of better than 0.1 would not be credible where an operator response to an
alarm/monitoring activity is required, and may be worse depending on the reliability
placed on the chosen detection method.
When completing a risk assessment, appropriate conservatism should be applied when
determining relevant conditional modifiers and the probability of failure on demand of
other independent layers of protection.
Guideline – Leak Detection v0.6 Page 21 of 25
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Abbreviations
Abbreviation Description
ALARP As Low As is Reasonably Practicable
AST Above-ground Storage Tank
BPCS Basic Process Control System
CBA Cost Benefit Analysis
CDOIF Chemical and Downstream Oil Industry Forum
COMAH Control of Major Accident Hazards
EEMUA Engineering Equipment and Materials Users Association
FVC Flammable Vapour Cloud
HSE Health and Safety Executive
HSL Health and Safety Laboratory
MATTE Major Accident to the Environment
PSLG Process Safety Leadership Group
SIL Safety Integrity Level
SIS Safety Instrumented System
TifALARP Tolerable if As Low As is Reasonably Practicable
UK United Kingdom
UKPIA United Kingdom Petroleum Industry Association
VCE Vapour Cloud Explosion
Guideline – Leak Detection v0.6 Page 22 of 25
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Other relevant publications
Further information relating leak detection techniques can be found in the following publications
1) Process Safety Leadership Group, final report – Safety and Environmental Standards for
Fuel Storage Sites
2) Health and Safety Laboratory – A review of leak detection for fuel storage sites,
ECM/2008/08
3) EEMUA 159 – User’s guide to the inspection, maintenance and repair of above ground
vertical cylindrical steel storage tanks, Third Edition
4) EEMUA 183 – Prevention of tank bottom leakage – a guide for the design and repair of
foundations and bottoms of vertical, cylindrical, steel storage tanks, Second Edition
5) EEMUA 191 - Alarm Systems - A Guide to Design, Management and Procurement
6) EEMUA 213 – Emission reduction from oil storage tanks and loading operations, First
Edition
7) Storage BREF (Best Available Techniques Reference Document), 2006
8) Energy Institute Model Code of Safe Practice Part 2
9) Energy Institute Environmental Guidelines for Petroleum Distribution Installations
Guideline – Leak Detection v0.6 Page 23 of 25
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Acknowledgements
This document was created as part of the Chemical and Downstream Oil Industry Forum Process
Safety work stream.
CDOIF wish to record their appreciation to the working group members who were responsible for
creating this guideline:
Name Organisation
Peter Davidson (Chair) UKPIA
Dave Ransome P&I Design Ltd.
Barrie Salmon Tank Storage Association
Raman Sridhar BP
Mike Boothman Phillips 66
Ian Goldsworthy Valero
Craig Pugh Exxon
John Lilley EEMUA
Carol Pickard Total
Bruce Hopwood Shell
Brian Armitage Petroineos
Andy McCormick Essar Oil (UK)
David Howard Environment Agency
Mike Nicholas Environment Agency
Guideline – Leak Detection v0.6 Page 24 of 25
CDOIF
Chemical and Downstream Oil
Industries Forum
CDOIF is a collaborative venture formed to agree strategic areas for
joint industry / trade union / regulator action aimed at delivering
health, safety and environmental improvements with cross-sector
benefits.
Revision History
Rev.Section Description Date Changed By
0 All First Issue 20-Feb-2013 Peter Davidson
0.1 All Project sponsor comments incorporated 21-Feb-2013 Peter Davidson
0.2 All Updated with working group comments 28-Feb-2013 Peter Davidson
0.3 All Updated with further working group comments 16-May-2013 Peter Davidson
0.4 All Updated with final comments from working group 11-June-2013 Peter Davidson
0.5 All Updated with final comments from CA 1-July-2013 Peter Davidson
0.6 All Update with CDOIF Stakeholder Comments 29-Aug-2103 Peter Davidson
Guideline – Leak Detection v0.6 Page 25 of 25

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cdoif-leak-detection-guide.pdf

  • 1. CDOIF Chemical and Downstream Oil Industries Forum Guideline Leak Detection Guideline – Leak Detection v0.6 Page 1 of 25
  • 2. CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Foreword In promoting and leading on key sector process safety initiatives, CDOIF has developed through its members this guideline on available leak detection techniques for Above-ground Storage Tanks (AST). The intent of this document is to provide a reference for those organisations wishing to consider the use of leak detection systems to provide mitigation against the loss of product from an AST. It is not the intention of this document to replace any existing corporate policies or processes. The intent is to provide a reference to users to help in the selection of appropriate leak detection techniques. There are no limitations on further distribution of this guideline to other organisations outside of CDOIF membership, provided that: 1. It is understood that this report represents CDOIF’s view of common guidelines as applied to leak detection. 2. CDOIF accepts no responsibility in terms of the use or misuse of this document. 3. The report is distributed in a read only format, such that the name and content is not changed and that it is consistently referred to as "CDOIF Guideline – Leak Detection". 4. It is understood that no warranty is given in relation to the accuracy or completeness of information contained in the report except that it is believed to be substantially correct at the time of publication. It should be understood that this document does not explore all possible options for leak detection, nor does it consider individual site requirements – Following the guidance is not compulsory and duty holders are free to take other action. Guideline – Leak Detection v0.6 Page 2 of 25
  • 3. CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Contents 1. EXECUTIVE SUMMARY........................................................................................................4 2. INTRODUCTION AND SCOPE..............................................................................................5 3. TECHNIQUES FOR LEAK DETECTION................................................................................6 3.1 Gas detection within the tank bund.............................................................................9 3.2 Tank base perimeter/bund floor point detectors........................................................10 3.3 Sump/interceptor point or interface detectors ...........................................................11 3.4 Hydrocarbon detection tapes installed in the bund floor or underneath the tank .......12 3.5 Under tank membrane with tell-tail leak detection.....................................................13 3.6 Interspace loss of vacuum detection.........................................................................14 3.7 Tank level gauging with product loss alarm ..............................................................15 3.8 Point or interface detection at floating roof drain valve outlet....................................16 3.9 Point or interface detection at bund drain valve outlet...............................................17 3.10 Point or interface detection at tank water draw valve outlet ......................................18 4. RISK REDUCTION CONSIDERATION................................................................................19 4.1 Defining the mitigation layer .....................................................................................20 4.2 Claiming risk reduction .............................................................................................21 Abbreviations...................................................................................................................................22 Other relevant publications ..............................................................................................................23 Acknowledgements .........................................................................................................................24 Revision History...............................................................................................................................25 Guideline – Leak Detection v0.6 Page 3 of 25
  • 4. CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. 1. EXECUTIVE SUMMARY Hazardous substances which are stored in above-ground storage tanks could have the potential to pollute the environment or harm people if the primary containment measure in which they are stored (i.e. the tank) fails. Leak detection is one method by which hydrocarbons can be detected should primary containment fail. Early indication of the failure may ensure that mitigation measures to prevent escalation of the scenario can be deployed quickly. The final report of the Process Safety Leadership Groups (PSLG) safety and environmental standards for fuel storage sites was published in December 2009. Part 2 of that report provides limited guidance on the use of gas and liquid detection systems to detect overflows from a bulk storage tanks. A research report commissioned by the Health and Safety Laboratory (HSL), entitled ‘A review of leak detection for fuel storage sites, ECM/2008/08’ provided further guidance. As part of its role to deliver improvements in health, safety and the environment, the CDOIF Process Safety Work-stream agreed to examine the types of leak detection that had been successfully implemented in the UK. A working group was commissioned to develop this guideline to assist duty holders in the selection of appropriate techniques and what impact these systems may have in terms of risk reduction. There are different leak detection methodologies available, which each have their own strengths and weaknesses. Methodologies considered in terms of their benefits, limitations and indicative costs are described in section 3, Techniques for Leak Detection. Leak detection systems may reduce the risk to people or the environment. They could be considered as a further layer of protection against specific scenarios or be considered a more cost effective risk reduction technique as part of an ALARP (As Low As Reasonably Practicable) demonstration. The possibility of spurious trips will discourage their use in automatic systems, whether in the Basic Process Control System (BPCS) or Safety Instrumented System (SIS). As per other guidance, any claims for risk reduction as an additional mitigation barrier will require justification in terms of clearly defined operating procedures and emergency responses. Guideline – Leak Detection v0.6 Page 4 of 25
  • 5. CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. 2. INTRODUCTION AND SCOPE Leak detection in the context of this guidance relates to the detection of hydrocarbons following the failure of primary containment. Primary containment inside a bund consists of the tank shell and associated pipe work. Primary containment may fail in any of the following ways: • The tank is over-filled, resulting in loss of product from the top of the tank, or through roof vents • Failure of the tank floor • Failure of the tank wall joints • Catastrophic tank failure • Failure of pipe-work associated with the tank • Failure of pipe-work running through the bund The risk of these failures occurring can be reduced significantly through measures such as good inspection, maintenance and repair processes, and where appropriate the installation of preventative systems such as overfill protection. Leak detection systems can complement these other measures to reduce the risk further, or they may also provide an alternative means of risk reduction when other systems or processes are disproportionate in terms of the risk reduction achieved versus the cost. This guidance should not be interpreted as a requirement to install such systems, but instead provide a useful reference to those duty holders who may be considering the installation of leak detection for the reasons stated. Other techniques are available, and cost will be variable depending on the technology adopted and existing site infrastructure. Consideration should also be given to the sensitivities of any installed system to spurious trips during routine operations (such as flushing), and procedures should be updated accordingly. The following sections provide an overview of typical leak detection systems adopted by the downstream oil industry in the UK – this list is not exhaustive and other techniques may also be available. Guideline – Leak Detection v0.6 Page 5 of 25
  • 6. CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. 3. TECHNIQUES FOR LEAK DETECTION Leak detection may be considered as one mechanism for the early detection of failure of primary containment. Typical examples of Hydrocarbon detection techniques include: • Gas detection (point sensors) • Point detectors placed around the circumference of the tank or in the bund floor • Interface or level detectors placed in an interceptor or sump • Hydrocarbon detection ‘tapes’ installed in the bund floor, or underneath the base of the tank • Under tank membrane with tell-tail leak detection • Interspace loss of vacuum detection • Tank level gauging with product loss alarm (wet-stock reconciliation) • Point or interface detectors located at the outlet to a floating roof drain valve • Point or interface detectors located at the outlet to a bund drain valve • Point or interface detectors located at the outlet to a tank water draw valve Guideline – Leak Detection v0.6 Page 6 of 25
  • 7. CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector CDOIF Chemical and Downstream Oil benefits. Industries Forum Figure 1 – Examples of Hydrocarbon detection points Guideline – Leak Detection v0.6 Page 7 of 25
  • 8. CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. When reviewing the applicability of leak detection techniques, it is important to consider the circumstances under which it will be used, and the scenario(s) it is intended to detect, for example: • Installing liquid or gas detection is unlikely to have an effect on reducing the risk to people or the environment following catastrophic tank failure, or loss of very large volumes of product after the failure of wall joint as the volumes lost would be significant over a very short space of time. However smaller leaks may be a pre-curser to more significant failures, and therefore leak detection may prove beneficial. • Leak detection is likely to be beneficial in mitigating the risk arising from tank over-fill, or from other significant tank leaks. • Gas detection may be effective in detection of vapour formation following over­ topping thus limiting the size of a Flammable Vapour Cloud (FVC), but it is unlikely to be effective in detecting a leak from the base of the tank. • The positioning of gas detectors can be impacted by prevailing weather conditions. Gas detectors will be much less sensitive to leaks down-wind of the detector. Reference should be made to section 4, Risk Reduction Consideration, for further information on the benefits that could be claimed, and the restrictions that should be applied when considering the chosen leak detection system in a risk assessment. Installations appropriate to new build tanks may not be appropriate for tanks which are refurbished. The following sub-sections provide an analysis of typical leak detection techniques, their benefits and limitations and indicative cost. Guideline – Leak Detection v0.6 Page 8 of 25
  • 9. 3.1 CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Gas detection within the tank bund Usage Potential benefits Considerations Indicative Cost Gas detectors positioned within the bund can be used to detect vapour cloud formation caused either from tank over-fill or failure of the tank shell (where these failures are located in such a place as to cause cascade of product likely to form a vapour cloud) Early detection of loss of containment could reduce the size, or prevent the formation of a large flammable vapour cloud which may lead to a Vapour Cloud Explosion (VCE) Gas detection is a well proven technology, which is generally robust and cost effective where a suitable integrity, reliability or preventative maintenance strategy is applied. Effective positioning of detectors is important as the spread of a vapour cloud will be directly affected by weather conditions. Suitable technology should be selected depending upon the product and conditions to be detected ­ technology includes point and open path. Further information can be found here: http://www.hse.gov.uk/p ubns/gasdetector.pdf Gas detection would form part of a mitigatory Medium Early detection of loss of containment could reduce the risk of a pool fire by detecting vapour within the bund before ignition. protection layer – alarm activation would be required to initiate further action and/or emergency response. This further activity would be required to be clearly defined and subject to periodic testing. Guideline – Leak Detection v0.6 Page 9 of 25
  • 10. 3.2 CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Tank base perimeter/bund floor point detectors Usage Potential benefits Considerations Indicative Cost Liquid point detectors positioned around the base of the tank, or in the bund floor (typically in the lowest gradients of the bund floor) can be used to detect loss of containment into the bund, either from tank over-fill or failure of the tank shell. In some instances this may also detect loss of containment from the tank floor, though this will be dependent on the topology and geology of the bund underneath the tank Early detection of hydrocarbons in the bund could reduce the size, or prevent the formation of a large flammable vapour cloud which may lead to a VCE Early detection of hydrocarbons in the bund may be used to reduce the risk of pool fires. Early detection of hydrocarbons in the bund may also provide an early indication of loss of containment, reducing the risk of a Major Accident to the Environment (MATTE) Liquid point detectors can provide an early indication of hydrocarbons within the bund, reducing the escalation of several scenarios which if undetected could lead to a VCE or a MATTE. Liquid point detection may be subject to spurious trips due to bund materials which may already be contaminated, or through rain water collecting in the bund. Detection is only effective at the point of measurement, and therefore the positioning and number of detectors require careful consideration Care should be taken when claiming credit for the reduction in size of a flammable vapour cloud, as liquid would only be detected in the bund if the tank was already overflowing – giving time for the vapour cloud to form. Liquid point detection within the bund would form part of a mitigatory protection layer – alarm activation would be required to initiate further action and/or emergency response. This further activity would be required to be clearly defined and subject to periodic testing. Medium Guideline – Leak Detection v0.6 Page 10 of 25
  • 11. 3.3 CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Sump/interceptor point or interface detectors Usage Potential benefits Considerations Indicative Cost Liquid Point Detectors positioned in the bund sump or interceptor can come in two forms: 1. Simple level switch (fitted with a displacer for greater accuracy), or 2. Interface level detectors These technologies can be used to detect loss of containment into the bund either from tank over-fill or failure of the tank shell. In some instances this may also detect loss of containment from the tank floor, though this will be dependent on the topology and geology of the bund underneath the tank Early detection of hydrocarbons in the bund sump or interceptor may be used to reduce the risk of pool fires. Early detection of hydrocarbons in the bund sump or interceptor may also provide an indication of loss of containment, reducing the risk of a MATTE Bund sump or interceptor liquid/interface detectors can provide an early indication of hydrocarbons within the bund, reducing the escalation of several scenarios which if undetected could lead to a MATTE. Interface level detectors in particular have been shown to be very reliable and easy to maintain. Simple level switches in particular can be subject to spurious trips due to rain water collecting in the bund. Liquid Point Detection is only effective at the point of measurement, and therefore detection will only occur where product collects in the bund sump/interceptor Bund sump or interceptor liquid/interface detection within the bund would form part of a mitigatory protection layer – alarm activation would be required to initiate further action and/or emergency response. This further activity would be required to be clearly defined and subject to period testing. Hydrocarbon detection may be linked with executive action (for example closing an automated valve) if failure is likely to result in hydrocarbon release into the bund Low Guideline – Leak Detection v0.6 Page 11 of 25
  • 12. 3.4 CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Hydrocarbon detection tapes installed in the bund floor or underneath the tank Usage Potential benefits Considerations Indicative Cost Hydrocarbon tape/cable detectors Tape/cable detectors are an effective method for detecting leaks from the tank floor, which otherwise may be undetected for some Tape/cable detectors can be sacrificial, and would require replacement following detection. There is a risk of premature failure of the system if installation is not carefully planned and executed. positioned underneath the tank floor can be used to detect loss of containment from the tank floor. Early detection of hydrocarbons underneath the tank may provide an indication of loss of time. Arranged in a lattice format, this method of detection may also provide some accuracy as to the location of the Care should be taken in assessing the contamination that may already exist underneath the tank before installation High containment, reducing the risk of a MATTE leak within the tank floor. Tape or cable detectors can either be installed underneath the tank base (typically using a boring technique) or between two floors of a double bottomed tank. Tape/cable detection underneath the tank would form part of a mitigatory protection layer – alarm activation would be required to initiate further action and/or emergency response. This further activity would be required to be clearly defined and subject to period testing. Guideline – Leak Detection v0.6 Page 12 of 25
  • 13. 3.5 CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Under tank membrane with tell-tail leak detection Usage Potential benefits Considerations Indicative Cost Liquid point detectors positioned at the outlet of under tank floor/over membrane leak detection pipes can be used to detect loss of containment into the bund from tank floor failure. Early detection of hydrocarbons underneath the tank may provide an indication of loss of containment, reducing the risk of a MATTE Liquid point detectors can provide an early indication of hydrocarbons within the bund, reducing the escalation of several scenarios which if undetected could lead to a MATTE. Liquid point detection may be subject to spurious trips due to bund materials which may already be contaminated, or through rain water collecting in the bund. Detection is only effective at the point of measurement, and therefore the positioning and number of detectors require careful consideration Under tank membranes are primarily concerned with detecting tank floor leaks. Other leaks leading to FVC are unlikely to be detected. Liquid point detection within the bund would form part of a mitigatory protection layer – routine operator monitoring or alarm activation would be required to initiate further action and/or emergency response, however the system indicates failure of only one of the containment systems, and therefore immediate response may not be required. Any further activity would be required to be clearly defined and subject to periodic testing Low/ Medium Guideline – Leak Detection v0.6 Page 13 of 25
  • 14. 3.6 CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Interspace loss of vacuum detection Usage Potential benefits Considerations Indicative Cost Loss of vacuum on vacuum annulus systems installed on tank floors can be used to detect loss of containment from the tank floor. Early detection of hydrocarbons underneath the tank may provide an indication of loss of containment, reducing the risk of a MATTE Loss of vacuum techniques are an effective method for detecting leaks from the tank floor, which otherwise may be undetected for some time. Loss of vacuum detection systems are installed in the space between an internal epoxy/steel tank floor and the external tank floor. Loss of vacuum detection systems would form part of a mitigatory protection layer – routine operator monitoring or alarm activation would be required to initiate further action and/or emergency response, however the system indicates failure of only one of the containment systems, and therefore immediate response may not be required. Any further activity would be required to be clearly defined and subject to periodic testing Medium/ High Guideline – Leak Detection v0.6 Page 14 of 25
  • 15. 3.7 CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Tank level gauging with product loss alarm Usage Potential benefits Considerations Indicative Cost Liquid level monitoring (wet-stock reconciliation) of the product within the tank can be used to detect a loss of containment over a period of time (for example, where product is leaking from the tank). Monitoring of the tank level for loss of containment is only relevant during the period when the product in the tank is stationary (for example when no transfers into or out of the tank are in progress, such as when a terminal is closed overnight). Tank gauging systems can detect comparatively small leaks of product loss Liquid level monitoring is a well proven technology with proven reliability and repeatability for Monitoring is normally via the tank gauging system The system should be configured with a change in level (discrepancy) alarm that is relayed to relevant Low Early detection of hydrocarbons in the bund could reduce the size, or prevent the formation of a large flammable vapour cloud which may lead to a VCE accuracy personnel who can take appropriate action/. This could either be the central control room or security office. Early detection of hydrocarbons in the bund may be used to reduce the risk of pool fires. Early detection of hydrocarbons in the bund may also provide an early indication of loss of containment, reducing the risk of a Major Accident to the Environment (MATTE) Guideline – Leak Detection v0.6 Page 15 of 25
  • 16. 3.8 CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Point or interface detection at floating roof drain valve outlet Usage Potential benefits Considerations Indicative Cost Leak detection installed on the outflow from a floating roof drain valve can provide indication of a failure of the drain line (hose or flexible joint) or a sunken floating roof. Early detection of hydrocarbons in the bund may be used to reduce the risk of pool fires. Cost effective when installed in drain lines from the outlet of the drain valves Functionality is only relevant where the policy on the site is to leave the roof drain normally open, in this instance leak detection could be beneficial. The detection will not function if the drain line is closed. Close care and attention is needed during the set-up and commissioning of such systems to prevent spurious alarms and avoid loss of confidence. Detection in the drain line would form part of a mitigatory protection Low Early detection of hydrocarbons in the bund may also provide an early indication of loss of containment, reducing the risk of a Major Accident to the Environment (MATTE) layer – alarm activation would be required to initiate further action and/or emergency response. This further activity would be required to be clearly defined and subject to period testing. Hydrocarbon detection may be linked with executive action (for example closing an automated valve) if failure is likely to result in hydrocarbon release into the bund. Guideline – Leak Detection v0.6 Page 16 of 25
  • 17. 3.9 CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Point or interface detection at bund drain valve outlet Usage Potential benefits Considerations Indicative Cost Leak detection installed on the outflow from the bund drain valve can provide indication of over-fill or loss of containment into the bund. Early detection of hydrocarbons in the bund may be used to reduce the risk of pool fires. Early detection of hydrocarbons in the bund may also provide an early indication of loss of containment, reducing the risk of a Major Accident to the Environment (MATTE) Cost effective when installed in drain lines from the outlet of the drain valves Functionality is only relevant where the policy on the site is to leave the bund drain valve normally open, in this instance leak detection could be beneficial. The detection will not function if the drain line is closed. Close care and attention is needed during the set-up and commissioning of such systems to prevent spurious alarms and avoid loss of confidence. Detection in the drain line would form part of a mitigatory protection layer – alarm activation would be required to initiate further action and/or emergency response. This further activity would be required to be clearly defined and subject to period testing. Low Guideline – Leak Detection v0.6 Page 17 of 25
  • 18. CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. 3.10 Point or interface detection at tank water draw valve outlet Usage Potential benefits Considerations Indicative Cost Leak detection installed on the outflow from a water drain valve can provide indication of loss of containment into the bund. Early detection of hydrocarbons in the bund may be used to reduce the risk of pool fires. Cost effective when installed in drain lines from the outlet of the Tank water draw is normally an attended operation, but can take place over long periods of time. In these instances, hydrocarbon detection may be of benefit. Close care and attention is needed during the set-up and commissioning of such systems to prevent spurious alarms and avoid loss of confidence. Detection in the water drain line would form part of a mitigatory Low Early detection of hydrocarbons in the bund may also provide an early indication of loss of containment, reducing the risk of a Major Accident to the Environment (MATTE) drain valves protection layer – alarm activation would be required to initiate further action and/or emergency response. This further activity would be required to be clearly defined and subject to period testing. Hydrocarbon detection may be linked with executive action (for example closing an automated valve) if failure is likely to result in hydrocarbon release into the bund Guideline – Leak Detection v0.6 Page 18 of 25
  • 19. CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering CDOIF health, safety and environmental improvements with cross-sector Chemical and Downstream Oil benefits. Industries Forum 4. RISK REDUCTION CONSIDERATION Whether or not a leak detection system is installed will be dependent on the benefits that it gives versus the costs of installation and maintenance - this decision should be made by the duty holder when completing a risk assessment for the credible scenarios which could result in loss of containment from an AST. Further guidance relating to risk assessment can be found here: • For the protection of people, refer to the numerous publications by the Health and Safety Executive (HSE) for COMAH, http://www.hse.gov.uk/comah/ • For the protection of the environment, one methodology for environmental risk assessment is provided in the CDOIF publication ‘Environmental Risk Tolerability for COMAH Establishments’ The installation of such systems may be appropriate to reduce the risk to people or the environment (or both). They could be considered as a further layer of protection against specific scenarios (for example reducing the risk of the formation of a flammable vapour cloud, or the risk of pollution to an environmental receptor), or be considered a more cost effective risk reduction technique as part of an ALARP (As Low As Reasonably Practicable) demonstration. However as any such system will only indicate the presence of hydrocarbons after they have escaped from the tank, they should only be considered as a mitigation layer. Whilst leak detection mechanisms could be configured with an automatic action (for example closure of an inlet valve, drain valve or stopping a transfer pump), caution should be taken when considering these systems to be safety related as further mitigatory actions would be required even if the automatic action1 completed successfully, i.e.: Figure 1 – Leak Detection Actions These further mitigatory actions (for example emergency response) would themselves be required to have written procedures and be tested in order to claim credit as part of the risk assessment process. 1 There is a probability of spurious alarms with some types of leak detection technology used in this application (detection of hydrocarbons in a bunded area) therefore due consideration should be given to the robustness of installation before integration with an automated action. Guideline – Leak Detection v0.6 Page 19 of 25
  • 20. 4.1 CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Defining the mitigation layer Before determining the level of risk reduction that can potentially be claimed following the installation of leak detection, it is first important to understand what potential consequences it is intended to mitigate against, and whether it is in support of other systems such as a Basic Process Control System (BPCS) or Safety Instrumented System (SIS). A risk assessment should determine if further measures are required to reduce the risk to Tolerable if ALARP (TifALARP), and • Where leak detection is to be considered in support of other systems such as an SIS or BPCS to reduce overall risk (for example its purpose is to mitigate against the formation of a large FVC or the risk to an environmental receptor from over­ filling a tank), independence from the BPCS would need to be demonstrated as with other protection/mitigation layers such as independent alarms. Further information on independence can be found in the following publications: o Process Safety Leadership Group (PSLG) final report, Appendix 4 o CDOIF guideline ‘Process Safety Leadership Group – Other Products in Scope’ • Where the leak detection system is to be considered to reduce the potential for a MATTE but not in conjunction with other automated systems such as an SIS or BPCS (for example its purpose is to mitigate the risk against a leak from the base of a tank), independence would not need to be demonstrated from the BPCS (or other systems) as the leak detection system is not providing a supporting mitigation layer to others provided by the BPCS. Further information on environmental risk assessments and MATTE definitions can be found in the following publication: o CDOIF guideline ‘Environmental Risk Tolerability for COMAH Establishments’ When determining the appropriateness of leak detection as a mitigation layer, clear descriptions should be given of the definition of the alarm, where and how it is sounded, who will react to it and how they should react, and how much time is available to react. This review should include consideration of: • Sounding the alarm in a different location to the Central Control Room, for example security building, to increase independence where necessary from the existing automation systems such as the BPCS and SIS. • Whether or not there is a need for investigation by local operators should the leak detection system alarm, and how long this would take. • Standard and Emergency operating procedures which define what needs to be done when the alarm is sounded, for example: o Transfer of the substance to another location Guideline – Leak Detection v0.6 Page 20 of 25
  • 21. 4.2 CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. o Adding water to the tank (where this is a viable option for the type of substance) o Shutdown of the process, sub-process or transfer Note that leak detection introduced as a mitigation layer may reduce the consequence of loss of primary containment, but would not reduce the frequency. Claiming risk reduction The installation of appropriate leak detection, and supporting operational and emergency procedures can contribute to overall risk reduction in any of the following ways: • Providing a layer of protection (or additional layer of protection) reducing the overall risk to people and the environment to TifALARP • Providing an additional layer of protection in support of existing systems which may in turn reduce the Safety Integrity Level (SIL) required by a SIS (Note however installation of leak detection does not negate the need for an independent SIS for overfill protection on finished gasoline tanks within the scope of the PSLG) • Providing the potential for an alternative (subject to ALARP and Cost Benefit Analysis (CBA)) and more cost effective mechanism for reducing the risk of a MATTE as part of an ALARP demonstration Following existing guidance relating to alarm systems as layers of protection, the claimed risk reduction for leak detection systems can be 0.1 (subject to the requirements laid out in this guideline, and other applicable publications, and appropriate justification). A claim of better than 0.1 would not be credible where an operator response to an alarm/monitoring activity is required, and may be worse depending on the reliability placed on the chosen detection method. When completing a risk assessment, appropriate conservatism should be applied when determining relevant conditional modifiers and the probability of failure on demand of other independent layers of protection. Guideline – Leak Detection v0.6 Page 21 of 25
  • 22. CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Abbreviations Abbreviation Description ALARP As Low As is Reasonably Practicable AST Above-ground Storage Tank BPCS Basic Process Control System CBA Cost Benefit Analysis CDOIF Chemical and Downstream Oil Industry Forum COMAH Control of Major Accident Hazards EEMUA Engineering Equipment and Materials Users Association FVC Flammable Vapour Cloud HSE Health and Safety Executive HSL Health and Safety Laboratory MATTE Major Accident to the Environment PSLG Process Safety Leadership Group SIL Safety Integrity Level SIS Safety Instrumented System TifALARP Tolerable if As Low As is Reasonably Practicable UK United Kingdom UKPIA United Kingdom Petroleum Industry Association VCE Vapour Cloud Explosion Guideline – Leak Detection v0.6 Page 22 of 25
  • 23. CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Other relevant publications Further information relating leak detection techniques can be found in the following publications 1) Process Safety Leadership Group, final report – Safety and Environmental Standards for Fuel Storage Sites 2) Health and Safety Laboratory – A review of leak detection for fuel storage sites, ECM/2008/08 3) EEMUA 159 – User’s guide to the inspection, maintenance and repair of above ground vertical cylindrical steel storage tanks, Third Edition 4) EEMUA 183 – Prevention of tank bottom leakage – a guide for the design and repair of foundations and bottoms of vertical, cylindrical, steel storage tanks, Second Edition 5) EEMUA 191 - Alarm Systems - A Guide to Design, Management and Procurement 6) EEMUA 213 – Emission reduction from oil storage tanks and loading operations, First Edition 7) Storage BREF (Best Available Techniques Reference Document), 2006 8) Energy Institute Model Code of Safe Practice Part 2 9) Energy Institute Environmental Guidelines for Petroleum Distribution Installations Guideline – Leak Detection v0.6 Page 23 of 25
  • 24. CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Acknowledgements This document was created as part of the Chemical and Downstream Oil Industry Forum Process Safety work stream. CDOIF wish to record their appreciation to the working group members who were responsible for creating this guideline: Name Organisation Peter Davidson (Chair) UKPIA Dave Ransome P&I Design Ltd. Barrie Salmon Tank Storage Association Raman Sridhar BP Mike Boothman Phillips 66 Ian Goldsworthy Valero Craig Pugh Exxon John Lilley EEMUA Carol Pickard Total Bruce Hopwood Shell Brian Armitage Petroineos Andy McCormick Essar Oil (UK) David Howard Environment Agency Mike Nicholas Environment Agency Guideline – Leak Detection v0.6 Page 24 of 25
  • 25. CDOIF Chemical and Downstream Oil Industries Forum CDOIF is a collaborative venture formed to agree strategic areas for joint industry / trade union / regulator action aimed at delivering health, safety and environmental improvements with cross-sector benefits. Revision History Rev.Section Description Date Changed By 0 All First Issue 20-Feb-2013 Peter Davidson 0.1 All Project sponsor comments incorporated 21-Feb-2013 Peter Davidson 0.2 All Updated with working group comments 28-Feb-2013 Peter Davidson 0.3 All Updated with further working group comments 16-May-2013 Peter Davidson 0.4 All Updated with final comments from working group 11-June-2013 Peter Davidson 0.5 All Updated with final comments from CA 1-July-2013 Peter Davidson 0.6 All Update with CDOIF Stakeholder Comments 29-Aug-2103 Peter Davidson Guideline – Leak Detection v0.6 Page 25 of 25