Rules for Xmas drones

Drones: the UK CAA has issued a revised “Dronecode” to help millions getting a drone this year to fly safely and responsibly, and clarify the legal requirements.

This new Dronecode gives a simple set of rules and guidelines established in legislation which outline how to fly drones safely and within the law in the UK: it is hosted on a new dedicated website, www.dronesafe.uk. The code, created by the Civil Aviation Authority, has been agreed and is backed by wide range of leading aviation players, drone retailers and manufacturers, plus also the Department for Transport.

The launch of the new code, follows an industry-first report into user behaviour, attitudes towards, and responsible use of drones; findings led to the new website and the revised and updated Dronecode.

Drone owners and those looking to purchase one should familiarise themselves with this revised Dronecode, which gives a simple set of rules around safe and responsible use:

• Don’t fly near airports or airfields
• Remember to stay below 400ft (120m) and at least 150ft (50m) away from buildings and people
• Observe your drone at all times
• Never fly near aircraft
• Enjoy responsibly

Adherence to the Dronecode will address initial public concern identified in the research and help the wider industries that can harness the power of drones for good to grow. These are certainly front of mind with high expectations among the public for agriculture, medical and healthcare use.

Tim Johnson, Policy Director at the CAA said, “Consumer research on this scale into drone use has never been done before and there was a real need from the aviation and drone industries to find out more about this growing sector. The research shows that the public have understandable concerns about reported drone misuse to date, and demonstrate clearly why the current education program is underway, backed by legal action when appropriate.

“Drones have significant potential and the new Dronecode, which forms the basis of establishing a responsible attitude toward drone flight amongst consumers, will help to protect the safety of the wider aviation industry. It will also help those expected to use drones to improve current operations, from farming to traffic, from healthcare to logistics. Ultimately, people must use their drones safely, and responsibly.”

The new Dronecode and the consumer research is available to download at www.dronesafe.uk, a new website created by the CAA and air traffic control body NATS, and supported by a range of key players in the drone and aviation industries and the Department for Transport.

This Dronecode is for consumer drone use: those using a drone commercially must be licensed and undergo an approved course. Drone users must also remember that if they don’t follow the simple rules they could be prosecuted and go to prison.

This item published with acknowledgement to DPAonthenet.net, who first highlighted this news.

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Fresh air with Brexit @ProcessingTalk

Having been a silent voter during the run up to the referendum, and appalled by the rubbish pedalled by the Politicians on both sides, I was delighted to discover that despite my reservations about leaving the EU, a small majority of the voting population also agreed that the positive aspects of a Brexit outweighed some inevitable early problems.

Why is there so much worry over the UK from my overseas friends and relations? The UK is one of the original trading nations, dating back to the C15th. The world is now a much smaller place, and all nations seek to trade worldwide. No countries or group of countries put up trading barriers (or walls) to stop trade, so business between the EU and the UK across the board will continue. They would lose more business than we would, by ceasing to carry existing business forwards. Plus all the recent growth in UK exports has come from trade with non-EU countries.

Forty years ago, the Politicians suggested joining the Common market would be great, citing cheap wine etc. Just another bad promise I’m afraid. Plus we joined the Common Market, not the EU, a Federation of States whose unelected bosses dictate that cucumbers and bananas shall be straight, and set the minimum size of strawberries to exclude the better English (and Scottish) ones. My niece asked where I would get my supplies of wine – so I mentioned that we drink only Australian and NZ wine, the wine sold expensively in the UK from France is actually the cheap stuff they would not drink themselves, and presumably normally turn into vinegar.

The French describe the British as a nation of shopkeepers. It is true, but I say we are a nation of independent-minded traders, sometimes also called entrepreneurs.

What about Automation

In the UK, there will be a slowdown of investment, and this will hit what little domestic spend there was on process automation. It is in the food industry where automation is needed most, and the suppliers there are surely used to an unwillingness to invest. Other sensors go into machinery that is exported, and some of that will suffer with a turndown in EU trade. The oil industry is not really investing at the moment, but the lower GBP/USD rate might make our oil industry, with its experience, and our costs more competitive in overseas contracts.

Siemens, who were publicly very much against a Brexit, has announced it will put on hold any further investment in its wind turbine manufacturing plant in Hull, where it has just set up a new factory employing 1000 people, at a cost of GBP310m. Hull voted by one of the largest majorities FOR Brexit. Dong Energy, the biggest investor in UK wind power, said “we don’t believe that UK energy policy is dependent on EU membership”. Maybe the UK can impose a trade barrier that stops Areva sending their reactor to Hinkley Point: already a UK Government advisor has suggested the GBP18Bn investment by EDF would be cancelled by the French. Maybe then we could go for a sensible UK/US solution?

From an editor’s point of view, press releases about major onshore automation investment projects in the EU, by British suppliers, have been very thin on the ground for several years. So what is at risk with a Brexit anyway? For the big multinationals, they deal with these contracts through their local subsidiaries, wherever the work or engineering is carried out. Most project descriptions these days mention interlinked CAD systems using resources from 5 or 6 design centres all around the world, and the work flows electronically through country borders. From India to Aberdeen, Houston, Madrid, Romania, Italy, UK and Egypt. So what will change? The Brexit might subtly boost the likelihood of investment projects in Eire, rather than the UK, which would be good news for Ireland.

Changes to expect

Probably the people feeling the pinch most will be the City Traders and the Banks. The pound will settle to a lower level, enabling us to recover faster, and then it will climb back when compared to the Euro, if not the Dollar. Whether there will be any further effects on the EU, I cannot predict. There is very little likelihood of Scotland or Northern Ireland breaking away from the UK and joining the EU separately (but the last time I said something similar to this, it was to say that “clamp-on ultrasonic flowmeters would never be able to measure steam or gas flow” – judge for yourself).

What I would like to see is an end to the extreme contrast between the lowest and the highest salaries in the UK, possibly starting by eliminating those highly paid banking jobs. Already HSBC is relocating their Euro currency trading operation to Paris. Maybe this will put a lid on the property prices in London, and overseas billionaires will sell their empty apartments. At least we will now stop paying high salaries and higher travel expenses to the ineffectively employed UK MEPs (Members of the European Parliament)!

For another viewpoint….

For a different viewpoint, see Eoin O’Riain’s post on his Read-out.net Instrumentation Signpost blog: https://instrumentsignpost.wordpress.com/2016/06/30/nobody-knows-brexit-pauto-tandm/

Nick Denbow

http://www.Processingtalk.info

Multiple approval barriers to free trade in environmental protection systems

As a product development manager, I used to think that the supply of industrial instrumentation equipment was made particularly difficult by the plethora of International, European, American and specific industry (and country) specifications and requirements. In an age of International co-operation it seemed these approvals were designed to act as protective barriers for home industries. But these seem trivial compared to the problems faced by suppliers to the World shipping industry, in particular in relation to environmental protection.

Readers of this column over the years will have been aware that I reported enthusiastically on the Alfa Laval PureBallast treatment system for purifying ballast water discharges from ships, launched back in 2007, at Greenwich. This enthusiasm was because of both the professionalism of the launch, as well as the laudable product objective and aspiration: it was one of the best such events I had attended, despite atrocious windy weather, freak waves and thunderstorms on the boat cruise taking the Editors down to Greenwich! With slightly bigger waves there might have been no Editors left to report on the event!

BWT – Ballast Water Treatment systems

In the Alfa Laval system, light energy, from a broad spectrum source, acts on a Titanium catalyst in the flow, to produce hydroxyl ions, which oxidise and kill any organic material in the ballast discharge. This was developed in co-operation with Wallenius Water, who had done the shipboard tests on some of their ships over the previous three years. Alfa Laval launched this product in January 2007, to make it available for ship-owners in time to meet the IMO regulations that would require such equipment to be installed on all new build ships after 2009, in participating countries.

Another Scandinavian company, Optimarin from Norway, was at the same time addressing the ballast water treatment market, using Ultra-Violet light from high power UV sources (35kW) to kill any potentially harmful invasive organisms straight away. Optimarin was established in 1994 to develop this system, and supplied the first ever BWT system installed in 2000 on the Princess Cruise Line ‘Regal Princess’.

Extended approval timescales

It is significant that it is now 2016, over 20 years since Optimarin was founded, and at least 12 years after the first Alfa Laval systems were installed for sea trials on Wallenius ships. It is also 7 years after the first of the IMO regulations came into force – these did allow several years grace for older ships still operating from prior to 2009. All this makes for a very long lead time for any new product development to grow and become commercial!

Yet only in December last year did the US Coast Guard finally confirm that it would not type approve BWT systems if they failed to totally kill potentially invasive marine organisms transported in ballast water. This will exclude many ‘conventional’ UV purification systems which use lower power lamps as sources, since these render the organisms “unviable” (ie they are still alive but cannot reproduce). The approval tests carried out by DNV to prove performance to the USCG criteria (applying the CMFDA staining test method) takes up to a year, and Optimarin suggests that the testing – due for completion this year – will cost them around US$3m.

Alfa Laval also expresses confidence that their PureBallast system will meet the current USCG test criteria, and their tests will also be completed this year: at the moment, Alfa Laval points out that although US ballast water regulations took effect in 2012, no systems of any technology have yet been type approved by the USCG.

IMO, the World shipping legislative body

Indeed the IMO regulations themselves are not universally applied as yet: the “International Convention for the Control and Management of Ship’s Ballast Water & Sediments” is legislated to enter into force one year after being ratified by 30 states, representing 35% of the world’s tonnage. At present, March 2016, 46 states have ratified, representing 34.8% of the world’s tonnage – almost at the action stage! So the product is on the point of what should be a worldwide legislated requirement…..one more country to ratify the IMO proposal, with one more tanker, and a year later the market will be confirmed. Its only taken nearly 20 years for these products to become a market requirement!

The USCG requirements will have no effect on shipping using previously approved UV BWT systems in the seas and oceans outside US territorial waters.

Individual ship approvals, Insurers, and Ex regulations

The problems for the suppliers are not yet finished: for shipboard use the equipment also requires certification by a whole further range of classification organisations, like DNV GL, Lloyd’s, Bureau Veritas, MLIT Japan, and American Bureau of Shipping. Some tanker operators also require hazardous area approvals, i.e. to Zone 1 ATEX standards in Europe: Optimarin have supplied 10 such systems for the Turkish tanker fleet of Atlantis Tankers, which are designed for the transport of IMO II classified chemical cargoes.

Suppliers and users

Optimarin publish their existing major customers as comprising Saga Shipholding, MOL, Grieg Shipping Group, Gulf Offshore, Farstad Shipping, NYK, Nor Line and Evergreen Marine Corp. Since that initial installation in 2000, Optimarin have sold over 350 units, with 270 already installed. Optimarin in March announced a fleet agreement with UK shipowner and management company Carisbrook, which has the potential to cover retrofits across their entire fleet of 46 bulk and multi-purpose vessels.

Alfa Laval do not publish a customer list nor figures for the total number of their systems installed, but a PR from September 2015 discussed an Asian based shipping line placing an order for 33 systems. Another user has been quoted as MSC Containers.

Ballast water treatment retrofit work has been a major activity for Goltens Green Technologies (www.Goltens.com), a marine engineering contractor, who have already installed over 100 systems, from a current order book of 163. They supply systems from many manufacturers, listed as Optimarin, Bio-UV, Headway, Severn Trent DeNora, Alfa Laval, Auramarine, NK, Hyde Marine and Wärtsilä. Like Alfa Laval, Goltens are also involved in the supply and installation of other shipborne equipment required by and subject to environmental legislation, like SOx and NOx effluent control.

Whilst the retrofit market is important, the new build market is more significant, and obviously supplier attention is concentrated on the shipbuilders of South Korea.

© Nick Denbow, Processingtalk.info

@ProcessingTalk

Fines for oil and gas accidents, in the US and Scotland

There is a commonly held belief that US Courts award larger monetary fines and penalties than European Courts. This perhaps can be tested by some recent comparisons. BP paid $18.7Bn in fines to the US Government after the Macondo blowout in 2010, after already having paid $42Bn in the settlement of criminal and civil suits, and trust fund payments. The blast killed 11 people and discharged 686,000 tonnes of oil into the sea.

The Total Elgin blow-out

In the UK, Total E+P experienced a blow-out on the Elgin offshore platform in 2012, which caused considerable inconvenience to neighbouring offshore operators, where production and other drilling work had to be suspended. The high pressure natural gas leak continued for 51 days. The accident led to a total discharge of 6000 tonnes of gas and condensate into the atmosphere. Closing the well down cost Total around $127m, but also they lost production output from the Elgin-Franklin project for around a year.

Last year the Scottish Courts fined Total E+P $1.67million for the mistakes that led to the discharge and pollution. This makes the Scottish fine per tonne of gas discharge on Total around 1% of the US fine imposed on BP, per tonne of oil discharge. Is this factor a measure of the difference between oil and gas, or the difference between the Courts?

What does this mean for SoCalGas?

Southern California Gas has currently a problem with a major gas leak from the Aliso Canyon gas storage well, which is an abandoned oil well used to store natural gas. This blew in October last year, and is on schedule to be stopped by the end of March. The Californian Air Resources Board has monitored the leak rates, which have now reduced significantly, as the reservoir empties. They suggest the discharge to date has been 83,000 tonnes of methane, also suggesting this is 2.1m metric tonnes of CO2 equivalent.

On the basis of a Scottish Court fine, pro-rata for the discharge of 83,000 tonnes, SoCalGas would face a fine of $23m, if it were based in Scotland. If the US Courts treat a gas discharge in the same way as an oil discharge, then following the BP example, the fine will be 100x greater, or around $2Bn. I think it is more likely that US Courts, even with their normal high value fines, will view air pollution and global warming as far less significant than oil pollution and damage to their local sea environment and beaches. We will wait for some years to see what the fine will be.

Feb 10: UK Courts fine ConocoPhillips

February 10th: Another UK Court ruling relates to ConocoPhillips, who have been fined GBP3m ($4.5m approx) over three dangerous gas releases on the Lincolnshire Offshore Gas Gathering System (LOGGS) between 30 November and 1 December 2012. In the first incident 603Kg of hydrocarbon gas was released.

The fine was related more to the lack of proper procedures and danger posed by the release, to the offshore workers, than the environmental damage.

References

For the SoCalGas leak information website, see www.AlisoUpdates.com.

For the Californian ARB website: http://www.arb.ca.gov/research/aliso_canyon_natural_gas_leak.htm

For the original INSIDER comment on this topic, see https://nickdenbow.wordpress.com/2015/12/23/us-climate-change-contribution/

(c) Nick Denbow – Processingtalk.info

Netherlands takes action over gas field earthquakes

The following article appeared in the HazardEx newsletter this week, and is of particular relevance to the UK current discussions over the safety of fracking in Northwestern UK. The HazardEx newsletter can be accessed via www.hazardexonthenet.net

The Groningen gas field was discovered in the 1960s, and is a conventional gas reservoir, it does not use fracking. As the gas is extracted, small earthquakes have occurred as the ground, the roof of the reservoir, settles, presumably as a result of the reduction in the gas pressure below. Tens of thousands of homes have had to be shored up because of damage caused by the earthquakes

The government of the Netherlands apologised on March 2 for ignoring risks posed by earthquakes caused by production of natural gas in the northern province of Groningen. The apology follows a February 18 report by the country’s independent Safety Board that found that the government, together with Royal Dutch Shell and Exxon, had put profits before safety in exploiting the Groningen gas field.

Economic Affairs Minister Henk Kamp said he was very sorry that the safety interests of Groningers had not received the attention they deserved. He said safety would now come first and that necessary measures would be taken to address the problem.

Last month Kamp ordered production at the Groningen field, Europe’s largest onshore gas field, to be cut by 16% for the first half of 2015, sending prices in northwest Europe surging. He is due to make another decision on production at the field on July 1.

Earthquakes were definitively linked to production at Groningen in 1993, but they became more frequent and intense after production was increased in 2008. Increased gas revenues provided important revenues for the state as the Dutch government pursued unpopular austerity policies.

After a 3.6 magnitude earthquake in 2012 — greater than any Shell and Exxon had forecast — regulators warned the government that citizens’ safety was at risk and called for production to be cut as quickly as possible. But the government did not order a reduction in production until last year, and then only a relatively small one.

The Groningen field accounts for two-thirds of Dutch gas production and the Netherlands supplies about 15% of Europe’s total natural gas, providing an important alternative to Russian gas.

In the wake of the Safety Board report, Dutch political parties across the spectrum are calling for Groningen never to return to former production levels, with left-leaning parties seeking further cuts in production.

Shell and Exxon have so far set aside 1.2 billion euros ($1.3 billion) in compensation after 30,000 buildings were damaged by recent earthquakes, although no serious physical injuries have been reported as a result of the quakes.

New biopharma plant in Switzerland chooses Emerson automation

Belgium-based UCB has awarded Emerson Process Management a Euro4.7m contract to provide integrated process automation and operations management systems for a new biopharmaceutical production centre in Bulle, Switzerland. Emerson’s technologies and engineering services will be crucial in meeting the very high standards expected by the UCB project team.

UCB is investing Euro175m to construct the first phase of a new plant, its first biopharmaceutical project in Switzerland. The 20,000-square-metre facility, which will be one of the largest in Europe, will be the main production centre for Cimzia (certolizumab pegol), which is used to treat rheumatoid arthritis and Crohn’s disease.

“The state-of-the-art and largely automated facility at Bulle will be a model for the industry when it opens in 2015,” said Michele Antonelli, UCB executive vice president. “To ensure the project meets its tight build-out schedule, we selected Emerson Process Management for its demonstrated ability to engineer and coordinate fast-track automation projects of this type.”

Emerson’s integrated solution includes its Syncade Smart Operations Management Suite, DeltaV digital automation system, and AMS Suite predictive maintenance software. Emerson will also provide related engineering services, including design, installation, testing and commissioning.

The Syncade Suite software integrates real-time plant floor data with business processes, decisions, and asset management – a key advantage in managing complex operations and extensive documentation required in pharmaceutical production. Syncade Suite manages workflow processes, including electronic work instructions, equipment status and material tracking, recipe-driven operations, automated weigh and dispense operations, and exception reporting.

“Typical biotech manufacturing can involve thousands of pieces of paper that can affect the ability to produce ‘right-first-time’ batches,” said Lorenzo Zampini, automation project manager. “With Emerson’s integrated operations management and control systems, we can automate the reporting process as well as gain tighter process control for increased productivity and smoother regulatory compliance.”

The Syncade software integrates with Emerson’s DeltaV automation system to facilitate operational activities and information flow from the plant floor up to UCB’s SAP system. In the UCB plant, the DeltaV system will control 163 process units including fermentation, purification, filtration, and bottling.  Emerson’s new electronic marshalling technology with CHARMs (characterization modules) will help minimise installation time by eliminating up to two-thirds of the wiring and connections needed with traditional control systems.

Emerson’s AMS Suite predictive maintenance software that will be supporting HART instrumentation will make it easy for technicians to calibrate critical instruments, check their status, and even detects potential problems before they affect operations.

“Emerson is delighted that UCB has chosen us to automate this ground-breaking facility,” said Steve Sonnenberg, president of Emerson Process Management. “Our proven ability to provide a single source for both plant automation and operations management systems will help UCB seamlessly manage operations from the plant floor to the head office.  We look forward to working with them as they bring the Bulle facility to life.”

“Buncefield – Why did it happen?”

The causes underlying the Buncefield accident, on 11 December 2005, were not quoted in real detail in the several initial reports published, and even in the final report of the Major Incident Investigation Board, issued in 2008, basically because of the impending legal proceedings against several of the companies involved. Sentence was passed on the Defendants on 16 July 2010, with fines and associated costs charged to them of around GBP8.5m. Following that the issue of the Health and Safety Executive COMAH summary report “Buncefield – Why did it happen?” tried to summarize the details of the story. You can see this report on www.hse.gov.uk/comah/buncefield/buncefield-report.pdf.

What was more interesting was to listen to a recent presentation to the InstMC Wessex Section by Colin Howard, of Istech Consulting in Teesside, a company he founded in 2001 after a 35 year career with ICI, and various other roles in C+I, QA and safety. Introducing Mr Howard as a Past President of the Institute of Measurement and Control, and as a soon-to-be Honorary Fellow of the same, Graham Dunkley, Chairman of the Wessex section of InstMC explained to an audience of well over 100 engineers  at the National Motor Museum at Beaulieu that Howard had been the “Expert witness to the Court” in these Buncefield prosecutions: this is an impartial advisor to the Judge – and the Jury – on the technical aspects being discussed in the presentations of evidence to the Court.

Background to the operations

The detail was that the 6000m3 tank receiving the pipeline delivery of 8400m3 of heavy gasoline containing 10% butane inevitably overflowed, by around 300 tons / 250,000 litres, because the operational system in use covering this part of the site relied on high level alarms from the tank level gauging system to tell the operators to switch over to another receiving tank. This level gauging system failed, as it had done 14 times in the previous 3 months, but the operators did not have a display of the tank level visible (which would have shown a static level): the single screen display available to them was devoted to showing a different tank. The independent high level alarm (IHLS), a spring-supported magnetically actuated reed switch driven from a weight on the floating roof, also failed.  This was of an early 1980s design, and the failure was because the padlock holding the maintenance test arm on this switch had not been refitted after use, and therefore did not hold the self test arm in the correct place. The test arm dropped, making the relay move in relation to the end stop, and prevent the magnet reaching the reed switch. In the manual it stated “Fit the padlock for security”, which did not indicate that the padlock hasp had to be 5mm dia +/- 0.1mm, and that any different size would make a malfunction possible, and that this padlock played an essential part in the functioning of the level alarm system. It seems that most other sites using this system have also lost or replaced this padlock with their own unit, not of the required size.

At Buncefield, when delivery drivers reported to the control room that there was a dense cloud of fuel vapour around the tanks – the butane had vaporized when dropping over the edge of the tank in a spray – the operators pressed the Emergency Shut-Down button on the system – use of this was meant to close all tank side valves: but there was no software associated with this button. Later it was shown that of the five security levels in the software only one level was used, and everyone had access to that. While there was no procedure written down for the tank filling activity – a point missed during a recently completed DNV assessment and review of the site procedures – the operators knew that they had to phone Birmingham to have the operators there stop the delivery of the gasoline down the line: they had to use the normal commercial phone land-lines, they had no control system feature that could halt the inflow on site at Buncefield.

The operators did have a Fire Alarm button, which would start the firewater pump to cover the tanks with water, and protect them from the heat of any fire. However, pressing that led to an immediate vapour cloud explosion, probably ignited by a spark from the pump itself: it measured 2.4 on the Richter scale. The fire burned for several days, and the bund walls, another essential safety feature, showed themselves to be inefficient, and leak: the tertiary containment was inadequate. Fire suppressants and fuel leaked into the groundwater around the site.

The fines imposed

The fines imposed were a total of: Total (UK) Ltd GBP2.6m, Hertfordshire Oil Storage Ltd (HOSL), a Total subsidiary, GBP 1.45m, British Pipeline Agency Ltd (BPAL) GBP300k, Motherwell Control Systems 2003 Ltd GBP1k and TAV Engineering GBP1k. In this, apparently it was recognized that larger fines for these two instrumentation companies would threaten their commercial future. Initially some press reports suggested the high level alarms were Cobham float switches, but while Cobham float switches were common on this site, none were involved in this accident. This business has subsequently been sold by Cobham, to AMSensors Ltd.

Howard further commented that these overfill hazards are common occurrences, and over the last 30 years six similar events have been reported. Since Buncefield, there have been two further such events. He comments that in August 2003 Buncefield had a near miss – a dress rehearsal for the December 2005 accident. Then, the IHLS failed, but it was not replaced until April 2004!

What did the Judge say?

The Judge said all the things you would expect. But most relevant was the response to the defence offered by the main operators on site: their defence was that they had sub-contracted level gauging and alarm system maintenance, that they had subcontracted the safety and procedures audit, or in the case of HOSL, it had subcontracted all operational matters on site to Total (UK). In other words they said “It wasn’t our responsibility, we told them to do it!” The Judge ruled that it was not legally possible to pass on (ie sub-contract) such responsibility. “The core of a major hazard business should be clear and positive process safety leadership and board level involvement and competence to ensure that major hazard risks are being properly managed.” It was also noted that “Routine operations are often those in which lax habits are most likely to develop”. The summary report quoted above gives many more such comments.

What did Howard say?

The small comments, maybe of detail, from Colin Howard, were in a way more interesting. The whole site had been split into separate companies, and a perimeter fence built half way across the area covered by a control system: so the half of a system left with the operators of the BPA pipeline was not really adequate. The operators did not like the fact that they had no control over the delivery system, and indeed did not have a flow measurement indicator for that delivery line: during the delivery that caused the overflow, from 1850 hours on the Saturday night, the flow rate was around 550m3/hr: shortly before the accident the rate of flow increased to around 900m3/hr, without the knowledge of the operators, when other off-takes further down the line were ceased.

The IHLS supplied by TAV to Motherwell Control Systems to replace the alarm on this receiving tank was poorly specified (in April 04), and was of a different design: possibly the original design had been upgraded. It had a dual function test lever, for high or low level alarm. There were no MOC procedures in place to check the implications of this, for performance or maintenance procedures, even if there were such maintenance procedures available (this was not specified, but there were no written procedures relating to the tank filling operation). One supervisor did request the fitting of a back-up, second IHLS.

The staff on site were under pressure to increase throughput, possibly by dealing with higher volume deliveries where tank capacity was at a premium – and they were doing excessive overtime: with high staff turnover, their competencies and experience were open to question.

Will it happen again?

Howard commented that since Buncefield, there have been two further similar overfilling events. There are 60 sites of this type known around the UK, and the Process Safety Leadership Guide entitled “Safety and environmental standards for fuel storage sites” that is considered mandatory has seen patchy implementation across these sites: some have a schedule, and plan to conform only by 2014.