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Safety and environmental standards for fuel storage sites
Final report
14
25 Table 1 provides a summary of the MIIB
Design and operation
report recommendations;
Parts 1 to 6 of this report provide the guidance to address each of these recommendations.
Dutyholders should already have met the recommendations within the BSTG report. The CA has
a programme of work to check compliance.
26 The information in Parts 1 to 6 of this guidance is presented in the same order as the
recommendations in the MIIB
Design and operation
report.
27 Within six months of the publication of this report, dutyholders should undertake a gap analysis of
their compliance with the revised and new guidance contained within this report for in-scope gasoline
tanks (as defined in paragraph 24) and record their findings. Within nine months of the publication of
this report dutyholders should agree with the CA an improvement plan to comply with this guidance.
28 For a number of recommendations there is a requirement to ensure that any changes are
incorporated within the safety report. For lower-tier sites, demonstrating that improvements have
been made will be achieved in the normal way by having systems and procedures in place at the
establishment to deliver the intended outcome.
Table 1
Recommendations from the MIIB
Design and operation
report
MIIB recommendation
MIIB sub-recommendation PSLG Report Reference
Systematic assessment of safety integrity level requirements
1 The CA and operators of
Buncefield-type sites should
develop and agree a common
methodology to determine
SIL requirements for overfill
prevention systems in line
with the principles set out in
Part 3 of BS EN 61511. This
methodology should take
account of:
Application of the methodology
should be clearly demonstrated
in the COMAH safety report
submitted to the CA for each
applicable site. Existing safety
reports will need to be reviewed
to ensure this methodology is
adopted.
1(a)
the existence of nearby
sensitive resources or
populations;
Part 1, paragraphs 29–33
Overfill protection systems
for storage tanks,
paragraphs 34–38
Application of LOPA to the
overflow of an atmospheric
tank, paragraphs 39–40
Incorporating the findings
of SIL assessments into
COMAH safety reports,
paragraph 41
Operator responsibilities and
human factors, paragraphs
42–43
1(b)
the nature and intensity of
depot operations;
1(c)
realistic reliability
expectations for tank gauging
systems;
1(d)
the extent/rigour of operator
monitoring.
Summary of actions required