The Evolution of secondary containment tanks The technology for secondary containment of steel underground storage tanks has significantly advanced during the past 15 years. Under today’s standards, several types of secondary containment constructions are permissible. Each of these technologies incorporates some form of corrosion control along with the secondary containment. Among double-wall steel tanks, the most common Steel Tank Institute (STI) corrosion control systems are: the sti-P3 cathodic-protected steel storage tank: the ACT100 composite tank with a 100mm coating of fibre glassreinforced plastic resin (FRP) to provide complete isolation of the steel surface from the corrosive soil environment; the thick polyurethane-coated ACT- 100-U tank and the Permatank jacketed tank. The trend towards secondary containment makes perfect sense. It provides containment to prevent releases into the soil or groundwater as well as all the undesirable elements that go with a release - report writing, clean up, lawsuits and business interruptions. It provides an extra insurance policy just in case the tank was improperly installed or maintained. It offers peace of mid to the tank owner. The numbers reflect the trend. Today, according to the STI, nearly 50 per cent of all steel USTs made in the USA are believed to be secondary containment tanks. Even greater strides have been made in some countries outside the USA. For example, Mexican regulations require that all USTs have secondary containment.
As society became more aware of the hazards with noncompliant underground storage tanks, tank owners also became aware of the great costs involved in cleaning up sites underground to meet regulations. The number of American regulated underground storage tanks decreased from more than two million to less than 700,000 tanks between 1988 and 2000. Where did all of our storage capacity go? In 1988, many tanks were old and seldom used. Most of these were removed and not replaced. Some tank owners simply began using their local service station for motor vehicle fuelling needs rather than store the fuel themselves. Many owner-operators began to install their tanks above ground instead of underground. This trend became quite noticeable after 1990 as AST production boomed. Tank buyers found greater peace of mind with ASTs - due to the perception of fewer regulations and the comforting ability to visually inspect the tank for leaks. Since many of
these tanks were storing flammable and combustible liquids, fire safety codes served as the predominantly regulatory documents dictation requirements for aboveground storage tanks. The most common new use for above-ground tank installation was for motor vehicle fuelling at a private fleet fuelling facility. In some parts of the USA, above-ground tanks were being installed at service stations for environmental reasons, but with complete disregard for the fire codes which generally prohibited such installations. The next decade saw a tremendous level of activity in the fire codes. New language was adopted in the codes to allow above-ground storage tank installations, with many new safety features built in to prevent releases from taking place so that catastrophic failures would not occur. This included the use of secondary containment, insulated/protected tank construction, overfill prevention, thermal expansion and anti-siphon devices, and special emergency vents. One of the more significant changes took place in the mid-1990s with the spill control requirements of the fire codes. The codes adopted secondary containment tanks with a capacity of up to 12,000 gallons as an equivalent to traditional concrete dike installations.
To comply with the new requirements of the codes, third-party test laboratories needed to develop new tank standards. As a result, new construction standards evolved for protected tanks, fire-resistant tanks and vaulted tanks. The most common construction, the protected tank, represents a major change in tank construction. The
protected tank must be insulated to withstand a 2000°F, two-hour pool fire environment exposure without leakage and must incorporate secondary containment. During the past decade, environmental safety awareness, once focused primarily on underground storage tanks, began drifting towards above-ground tanks. As the new century approached, federal and many state agencies either had adopted, or were in the process of adopting, new regulations for above-ground storage tanks. The first proposed revision to the federal AST rule in 1992 was to require impermeable secondary containment for at least 72 hours after a release occurred. This created a whole new movement towards secondary contained ASTs. No longer were spills and releases considered unacceptable only from underground tanks. Steel became a popular option for factory-built ASTs due to its nonpeameable nature. The initial solution was to install the above-ground tank into a steel dike. However, rain could collect in the dike and, in the presence of hydrocarbons, had to be disposed of as a hazardous material. Manufacturers began to provide rain shields over the dike opening. To prevent spills during fill operations diverting over the rain shield and onto the ground, overfill limiting valves were introduced for pressurised filling operations. Tank owners quickly realised that a double-wall, aboveground tank, similar in construction to the underground tank, could fulfil the same function as a diked AST with rain shield. Soon, the double-wall, above-ground tank became a popular installation option in both horizontal and vertical construction. Due to the new trend towards secondary containment tanks, third-party test laboratories incorporated alternative secondary containment tank construction and rectangular tank construction into their standards by 1994. STI responded to the needs of the industry to standardise construction by developing the diked AST F911 standard in 1991, "the double-wall AST F921 standard in 1992, the Fireguard fire-protected standard in 1994 and the Flameshield fire-resistant tank standard in 1999. Clearly, the trend toward secondary containment tanks was a reality. Manufacturers saw their secondary contained AST construction orders increase from almost nothing in 1990 to 50 per cent or more by the year 2000. In 1998 alone, STI members produced nearly 5000 secondary containment ASTs built to STI specifications. New trends continue to evolve with the need for storage tanks. Many industries are opting for the installation of standby power generators, including those mounted directly on top of generator base tanks, either in the form of single-wall, double-wall or protected tank construction.
New designs have been introduced for vertical, aboveground storage tank supports. As regulatory agencies further investigate releases from vertical tank floors resting on grade, the ability to see the tank bottom becomes more and more attractive.
With significant advances in secondary containment options of steel storage tanks over the past 20 years, tank owners are given many viable options. Whether or not secondary containment is mandated for their specific applications, owners would be well advised to consider the investment as an economically and environmentally sound tank installation.
BTec Training for the Industry by Bryan Catcherside
Introduction We are shortly to see the implementation of changes to petrol legislation with the introduction later this year of the Dangerous Substances and Explosive Atmospheres Regulations. The change in the law relating to the storage and dispensing of petrol has been prompted by a weight of opinion critical of the licensing regime on the following counts: Firstly that the licensing system is archaic and not in line with the mainstream of current health and safety legislation Secondly that there is a considerable diversity of approach on the part of the Petroleum Licensing Authorities in relation to standards of enforcement Thirdly that the prescriptive nature of the licensing regime exacerbates the problems arising from the diverse approach to enforcement Speaking as a former senior enforcement officer I confess to finding these arguments compelling. However, the demise of the licensing regime now shifts the focus of attention to the role of the site operator upon whose shoulders the responsibility will rest for researching and assessing the risks associated with his site and implementing the relevant codes of practice to which he must adhere in order to comply with the law. Fundamental to this role is the appointment and training of competent persons to assist him in undertaking the measures he needs to take to comply with his legal obligations. In this respect, the relevance and importance of thorough training cannot be overemphasised.
If the onus is now passing to the site operator and his appointed competent persons, what are the indications that the necessary standards of competence are in evidence within the industry? Well, as remarked earlier, if there is a marked diversity in the standard of petroleum enforcement throughout the country, it must also be said that the standard and method of training personnel within the petrol retail industry regarding petroleum safety is equally diverse.
Forecourt profit margins are low, rendering training comparatively expensive, particularly as such training is not geared to producing profit The high turnover of forecourt personnel discourages investment in training other than the basic elements of induction There are low expectations of the capabilities of personnel employed on the forecourt and little encouragement of personal development in the field of petroleum safety There has been a lack of co-ordinated approach to training within the petroleum retail industry with no industry accepted benchmark of achievement Site operators have tended to regard the existence of their petroleum licence as signifying a continuing compliance with the law, relying upon the annual “once over” by the petroleum officer to point out any irregularities
Factors affecting standards of training
We also found that where training was delivered it tended to be concentrated at the base of the pyramid, that is to say at the lowest level of the company structure, precisely where the turnover of staff was greatest, leaving a hiatus at the levels where the greatest expertise is required. Personnel at the higher supervisory and managerial levels tend to learn “by default”.
As a company we looked at the factors affecting the standards of safety training within the petrol retail industry and identified the following:
Enshrined in the precepts of modern health and safety legislation are the key elements of risk management, competence and training. These elements are wholly
interdependent and are essential factors in ensuring compliance with the law. Training is, therefore, clearly at the epicentre of compliance. Advantages accruing from investment in training There are advantages that accrue from investment in good risk management training: It imparts knowledge and understanding and a culture of “awareness” It is a pro-active insurance policy It protects people from harm or ill-health It protects the environment It protects a company’s assets - property, equipment, stock, data and records It protects a company’s public image It adds value to a company by avoiding costs (consider, for example, the cost of recovery and clean up operations following a large leak of petrol into the ground which might be avoided or mitigated by the vigilance of well trained staff) It is an investment in people It provides in-house expertise - (stated in Regulation 7 of the Management of Health and Safety at Work Regulations 1999, as the preferred option to the external appointment of competent persons i.e. consultants) It secures compliance with the law
The BTEC Qualifications Framework The taison d&treof any petrol filling station is to sell petrol to the public. The very nature of the product can give rise to risk to both personnel and the environment. The BTEC Qualifications in Petroleum Safety (Retail) and Petroleum Risk Management (Retail) have been developed by Fire Risk Management Ltd. to provide a recognised standard for knowledge and understanding in management of that risk. Advantages of a national qualification The availability of a national qualification has the following advantages: It provides the opportunity to adopt a nationally recognised benchmark for ,the management of risk It is a means of achieving compliance with the requirements of health and safety legislation regarding the training of personnel It provides the means of self sufficiency to site operators, managers and supervisory personnel in the necessary skills regarding risk assessment, risk management, the role of competent person and compliance with the legal requirements of regulatory authorities It provides a focus of approach to the training of personnel within the petroleum retail industry It promotes a culture of “awareness” regarding petroleum safety amongst all levels of personnel It provides incentive to personnel to achieve recognition of achievement and status in their field of occupation It encourages personnel to extend their level of expertise by progressing the qualifications structure
The syllabus for the BTEC qualifications was developed by FRM drawing on the in-house expertise of former Senior Petroleum Inspectors with the London Fire Brigade. This followed extensive consultation with leading petrol retail companies and regulatory authorities. There is nothing innovative about the learning content. It is not a reinvention of the wheel, nor is it the spin of management gurus. It is nothing more than the assembly of the essential elements of petroleum risk management in a goal-setting format with a qualification as the end product. The qualifications are not an endorsement of attendance at training courses or a tick box work book approach to competence, but are for key personnel who are able to demonstrate that they have attained a knowledge and understanding commensurate with expertise in their field. If training is to be worthwhile, shouldn’t there be a worthwhile reward for success?
T h e qualifications are: BTEC Intermediate Award in Petroleum Safety (Retail) - Level 2 BTEC Advanced Award in Petroleum Risk Assessment (Retail) - Level 3 BTEC Advanced Certificate in Petroleum Risk Management (Retail) - Level 3 BTEC Advanced Diploma in Petroleum Risk Management (Retail)- Level 3 The Intermediate Award is provided to meet the needs of non-supervisory personnel The Advanced Award and Advanced Certificate cater for the needs of supervisory grades The Advanced Diploma covers all aspects of petroleum safety relating to site operation and management and is suitable for site operators and managerial grades T h e Units of Learning Each qualification consists of a number of units of learning. Each unit is accorded a nominal number of hours which the Candidate might reasonably be expected to take to complete the necessary study and assignments, i.e 10, 30 or 60 hours. The BTEC Petroleum Safety qualifications are made up of 15 units in total. The Intermediate Award consists of units 1 - 3 The Advanced Award consists of units 1, 5 & 6 The Advanced Certificate consists of units 1 - 6 The Advanced Diploma consists of units 4 - 15 The units are as follows: Hazard and Risk Site Operation Emergency Procedures Road Tanker Deliveries Risk Assessment - Principles Risk Assessment - Practical
Petroleum Licensing Procedure Site Plan Maintenance Leak Detection Safety Procedures Vapour Recovery
LPG
The national conference and exhibition were discussed, in particular the fact that, as the name suggests, most of the North West branch members would have been required to travel a significant distance and incur overnight costs in order to take full advantage of the event. How much more convenient it would be to have an event where technical papers could be delivered and industry service providers and equipment manufacturers could display their wares at a local venue and at a ‘cheap and cheerful‘ price.
Safety Documentation Emergency Planning The concept of hazard and risk is introduced in the very first unit and every candidate is encouraged to apply the principles of risk management from the commencement of their course of study. The modular nature of the qualifications provides a natural progression for candidates to obtain the level of expertise commensurate with their responsibilities and for further advancement.
In order to qualify, candidates are required to complete assignments which are assessed by experts in the field of petroleum safety. Many of the assignments will relate to the candidate’s own site.
At this point I would like to say that the distinction of having been the first candidate to obtain a BTEC qualification in Petroleum Risk Management, namely the Advanced Certificate, belongs to none other than Mr. Brian Taylor, the APEA administrator and I would like to congratulate him publicly for this achievement. The BTEC Training Manual Central to the qualifications is the official training manual, “4site”. The manual covers the learning material for all the BTEC units and is available as a definitive “stand alone” guidance and reference manual, in its own right, for site operators, forecourt personnel and also petroleum officers. Sample pages may be downloaded from the company web site. Produced in a ground breaking, user-friendly format, “4site” covers all aspects of petroleum safety utilising colour illustrations, flow charts and clip art in twenty five chapters ranging from “Introducing the Filling Station” to “Site Decommissioning”. Being the central reference work for all training for the BTEC units, “4site” will be subject to continual updating as a result of a rolling programme of liaison with regulatory authorities, client companies and training organisations by means of FRM’s BTEC Standards and Development Board. With the Technical Session of the last APEA North West Branch meeting concluded, the attendees set about the serious business of any industry gathering - the networking.
A few days later Peter Gauntlet, The Corporate Membership Coordinator for the Institute of Petroleum, visited me and reported how the IP’s Yorkshire Branch, in conjunction with the Federation of Petroleum Suppliers, had held a very successful seminar focussing on Road Tanker Transport. Could the APEA North West branch combine with the local IP branches and set-up a similar event? The answer was ‘Yes’ and the result is to be held on November 13th at the Post House Hotel in Haydock. The seminar - entitled ‘The Cost of Loss’ - is aimed at identifying the numerous areas in which profits within the industry are being eroded, and identifying potential solutions. The list of speakers includes representatives from BOSS, HSE and the Environment Agency together with Fairbanks Environmental, CERTA (specialists in environmental impairment insurance) and United Utilities who will be addressing the issue of energy efficiency and green energy. Alongside the seminar there is the chance for local (or not so local if they wish) businesses to have a basic exhibition space where they will be able to discuss their products and services with the delegates.
If you are interested in attending the seminar, or exhibiting, then please contact stevejones@fairbanks.co.uk or telephone me on 01695 51775. This is designed to ensure maintenance of quality and accuracy of content, together with consistency in training course delivery in keeping with the requirements of national qualifications. Revisions to both “4site” and the syllabus will be implemented each year and students will be able to keep abreast of impending changes by having access to the support and update pages on the company web site. Approved Training Organisations Two training organisations meeting the necessary criteria to deliver national qualifications have been approved to provide courses in the BTEC syllabus, namely the London Fire Brigade Commercial Training Unit, and PTF Training Ltd. The courses cover the fundamental elements of the syllabus and give guidance to candidates on the
preparation of their assignments. The training organisations also provide support to candidates on the open learning aspect of their study.
BTEC Qualifications for Petroleum Officers With the emphasis being placed on competence in the workplace the Health and Safety Commission has reciprocal expectations of competence regarding officers of local authorities appointed to enforce health and safety legislation. As with the petrol retail industry, there has been no concerted approach to the training of petroleum officers and, until now, no standard syllabus leading to a national qualification. This has contributed to the justifiable criticism of the differing standards of enforcement encountered throughout the country.
As a means of addressing this issue, FRM has produced a level 4 qualification for Petroleum Officers, namely a BTEC Professional Diploma in Petroleum Regulation. The qualification has been drafted by former senior enforcement officers in consultation with leading enforcement authorities and the Environment Agency. The Professional Diploma The Diploma consists of nine units, namely:
Petroleum Legislation Enforcement Procedures Risk Management Inspection and Monitoring Site Construction Road Tanker Deliveries Safety and Emergency Procedures Petroleum and the Environment Dissertation The Professional Certificate Due to the high profile being given to the issue of competence it was decided to fast- track the introduction of the qualification by issuing the first four units of the Diploma as a qualification in its own right, namely a BTEC Professional Certificate in Petroleum Regulation. This qualification will be available in May. Candidates may then progress the remaining five units completing the Diploma. These units will be available later this year.
Central to the Professional Certificate and Diploma are the principles of enforcement as laid down in the Section 18 HSC guidance to local authorities and the technical guidance for the design, construction, modification and maintenance of petrol filling stations contained in the APEA/IP publication of that name.
As an example of the range of subjects covered in the syllabus the learning content includes report writing and the priority planning of inspections.
Full details of the syllabus for the regulatory qualifications, together with details of associated training courses to supplement the open learning aspect of study, may be obtained from Andy Berry of the London Fire Brigade, or from FRM. In Conclusion We are all here today because of our involvement, in one way or another, in petroleum safety. From this common ground it is fair to say that we all have an interest in promoting safety standards.
Low standards of expectancy beget low standards of achievement. The tick box, “get you by” method of training does not promote safety to the premiership of expertise but, on the contrary, relegates it to the lower divisions of significance in the minds of those to whom it is delivered. Public safety, and protection of the environment, is in the premiership of public concern. It is not negotiable, neither is it a cheap option. It is the sphere of the expert. The range of BTEC qualifications outlined in this presentation, and the parallel nature of the retail and regulatory syllabuses, provide the opportunity for the industry and regulators to move forward and work together towards the common goal of promoting the highest standards of competence in site operation, and consistency and proportionality in enforcement. Ladies and gentlemen, thank you for listening.