IPA18-585-F

PROCEEDINGS, INDONESIAN PETROLEUM ASSOCIATION

Forty-Second Annual Convention & Exhibition, May 2018

NEW LIQUID OVERFLOW HANDLING SYSTEM TO PREVENT PROCESS TANK FIRES

Reza Looyeh*
Adi Kristanto*
Gordon Chu*
Dwi Firman Nugraha*

ABSTRACT Protection, Overfill Prevention, Water Seal Box,

During the investigation of a recent process tank fire,
it was determined that hydrocarbon gas was released
through the malfunctioning and poor integrity of the
tank liquid overflow handling system. This allowed
gas to freely flow through the water seal system and
into the below grade open drain.
Several corrective actions were put in place and a
significantly improved overall water seal design was
successfully developed and safely executed in the
field to address all critical tanks exhibiting constant
and/or intermittent gas release. This improved
design, which uses the existing water seal system,
consists of a new upright elbow/horizontal P-trap
spool with its highest point above the water seal
system to keep the water level at that elevation and
provide a complete sealing.
A second design concept was also proposed and
executed for these liquid overflow handling systems
where the water seals have integrity issues due to
their design. This design replaces the entire liquid
overflow handling system from the tank overflow
nozzle all the way to below grade open drain and it
is fully inspectable by conventional methods. The
design uses a double elbow/horizontal P-trap upside-
down spool to hold the water for sufficient head to
seal the gas from exiting the tank while allowing
liquid overflow discharging into the open drain.
This paper aims to provide a detail sequence of
technical development, lessons learned and design
concepts and intends to provide doable
recommendations for swift corrective actions of
existing aboveground process and storage tank
overflow handling systems in oil and gas industry
while proposing a new design for inclusion into the
applicable codes and standards.
Keywords: Process Tank, Storage Tank, Liquid
Overflow Handling System, Process Fires, Overfill
Horizontal P-Trap Spool
INTRODUCTION
Background
As per current industry practice, process and storage
tanks are generally equipped with an externally
connected liquid overflow handling system. The
liquid overflow handling system is considered as an
additional layer of protection in case process tank
level control(s) fail to prevent overfills during a
normal or abnormal operating condition and other
overfill protective safeguards (if exist, whether
automatic or with operator’s intervention) do not
function as intended.
Overfill is a critical safety hazard which can result in
the loss of tank fluid and potentially major incidents
if the fluid is flammable or environmentally
sensitive. In fact, overfills have been the main cause
of serious incidents in the process industries for
decades. Roos & Myers (2015) reported that the
spills of hazardous products may exceed 100,000
annually across the world and then indicated that
majority of these spills are related to tank overfill
incidents. It is critical to know that overfills do not
happen randomly, and therefore, they are predictable
and thereby preventable.
With stringent legislations and regulations coming
into force nationally and internationally, safety
expectations are rapidly increasing especially where
there exist major consequences for process incidents.
It is therefore difficult for the process industry to
maintain compliance because methodologies that
were deemed acceptable in the past may not conform
to the newer and more stringent requirements. Thus,
process industry is moving towards “zero is
achievable” concept, and, the goal to achieve zero
tank overfills should be within the reach to protect
life and health, protect environment, protect process

* Chevron Pacific Indonesia

plant assets, comply with regulations and
legislations, improve public relations, assume
corporate social responsibility, increase operation
efficiency and minimize financial and legal risks.
Liquid Overflow Handling System
A tank overflow handling system generally consists
of a down-comer pipe, a water seal box and an
outgoing pipe which discharges into a below grade
open drain trench. The water seal box component
also has a second critical function; this is to maintain
a back pressure and prevent the gas (in the vapor
space of the process tank) to exit through the
outgoing pipe. This is achieved by the extended
down-comer pipe immersing into the water content
inside the fully enclosed seal box to form a seal
system preventing the gas to escape (Figure 1).
There is limited literature available on the subject;
most of focuses have been on the robustness and
functionality of overfill protection and safeguards for
both process and storage tanks especially following
the Buncefield major incident occurred in 2005 and
the subsequent investigation report issued by
Buncefield Major Incident Investigation Board in
2007. Since then the focus of new build process and
storage tanks have been on devising flawless overfill
protection safeguards (with several layers of
protection) to eliminate a need for a liquid overflow
handling system. To the best of authors’ knowledge,
relevant codes and standards such as API Standard
650 (2016), ANSI/API Standard 2350 (2012), API
Standard 2000 (2014) and NFPA 30 (2018) also
make very little reference to the liquid overflow
handling system, its integrity and functionality and
the potential scenarios/risks for failure and/or major
incidents.
While NFPA 30 (2018) provides fundamental and
critical safeguards required for the storage, handling,
and use of flammable and combustible liquids,
ANSI/API 2350 (2012) provides more focuses on
protection and prevention with the latter being the
most basic level of protection. This standard
comprise minimum overfill (and damage) prevention
practices for aboveground storage tanks that receive
flammable and combustible liquids. And, although
this standard came into force in 1987 for the first
time, it made little reference to aboveground process
and storage tanks equipped with liquid overflow
handling systems. With operations considered as the
primary overfill protection/prevention safeguard,
careful consideration has also been given to:
 safety and environmental protection
 inspection, testing, and preventive
maintenance (ITPM)
 optimization of the work place and safe
operating practices and protocols, emergency
procedures, and, operator training and
competency
 equipment and system selection and
installation
 management of change (MOC) programs
relative to tank overfill protection and
prevention
 inclusion of current technology and practices
related to process control and automated safety
instrumented systems.
And, therefore, a robust prevention may only be
achieved by ensuring that all of the above elements
are in place and working properly as intended.
Buncefield Major Incident Investigation Board
report (2007) made its key reference to the
management of fire and explosion hazards by
applying methodologies to identify, evaluate, and
control the hazards involved in the processing and
handling of flammable and combustible liquids.
They categorized hazards, but not limiting to,
preparation, separation, purification, and change of
state, energy content, or composition. Overall, they
came up with several recommendations for the
operations involving flammable and combustible
liquids and indicated that such operations shall be
reviewed to ensure that fire and explosion hazards
are addressed by fire prevention, fire control, and
emergency action plans. Since then, many operating
sites have updated existing and/or developed new
safe operating procedures to incorporate the
Buncefield recommendations and ensure their
aboveground process and storage tank overfill
protection and prevention systems are in place and
functioning.
Verma and Self (2014) did a comprehensive
assessment of all research and investigation work
done in past two decades on tank overfill protection
and prevention and published their research work in
2014. In their paper they indicated that in addition to
overflow of hazardous fluids, overfill may
encompass fluids that are safe to discharge to the
atmospheric drains e.g. through a liquid overflow
handling system. Furthermore, with risk assessment
quoted as being the key element in an overfill
management system to develop a robust tank control
system, they assessed two configurations: (a) Fluids
safe to release to atmosphere, and, (b) Fluids not safe
to release to atmosphere; the former to include an
overflow handling system and the latter without one.
They assessed both configurations in detail with
several overfill scenarios and although made some
reference to tank integrity but made no reference to
the integrity of the overflow handling system
especially those with a water seal box.
With brief review of literature as described above
and considering that many of process and storage
tanks built prior to 2000, and currently in service, are
still equipped with overflow handling system, it is
recognized that there is still a gap in industry on how
to safely operate these tanks understanding of high
risks associated with failure of such systems during
an overflow scenario.
During the investigation of a recent process tank
incident, it was determined that the gas, which
escaped the tank and caused the tank fire, was
through the malfunctioning and poor integrity of
liquid overflow handling system allowing gas to
freely flow into the down-comer pipe bypassing the
water seal from within the box and then flow further
into the outgoing pipe and the trench eventually.
Subsequent and detailed field inspection revealed
that the extended down-comer pipe inside the seal
box above the water level was excessively corroded
with several pin holes and therefore not providing
adequate sealing (Figure 2). Further inspection of all
process tanks in the operator’s facilities identified
several failed water seal boxes resulting to the release
of the explosive gas to the hazardous classified areas
either constantly or intermittently.
The asset integrity ITPM plan for overflow handling
system is normally performed as part the piping’s
ITPM (and not tank’s) and includes visual checks
and some random UT testing on the down-comer
pipe near the top of the seal box and/or the outgoing
pipe. Neither of these inspection methods produce
any data related to the integrity of the pipe inside the
seal box. Although there exist other inspection
methods such as radiography or borescope etc., they
also have limitations due to the size, accuracy and
accessibility in the classified hazardous areas. It was
thus noted that the old overflow handling system
design (which includes extended down-comer pipe
into the seal box) would have not allowed for
thorough inspection of the internal sections unless an
intrusive inspection method was used. This was then
considered a deficiency issue from the past tank
design when we did not think about the need to make
safeguards inspected, verified and validated on a
regular basis to ensure they are fit for continued
service as a reliable layer of protection.
Objectives
This paper is therefore aimed to provide a detail
sequence of technical development, lessons
learned and design concepts and intended to
provide field doable recommendations for swift
corrective actions and/or repairs for the existing
aboveground process and storage tank overflow
handling systems in oil and gas industry while
proposing a new design for inclusion into the
applicable codes and standards. Although, the
structural support of the overflow handling system
and design of appropriate pipe supports are
included, the paper does not address shell stiffness
and stability around the overflow nozzle and box
at the top of the shell.
DESIGN METHODS
Several corrective actions were put in place and a
significantly improved design of liquid overflow
handling system was successfully developed to
address all critical cases with constant gas release.
This improved design (hereafter “Alternative 1”),
which uses the existing water seal box, consists of
a new upright elbow/horizontal P-trap spool with
its highest point above the seal box to keep the
water level at that elevation and a new pipe
support. This design eliminates the dependency on
the extended pipe inside the seal box to provide
sealing and is applicable for all seal boxes with
acceptable mechanical integrity (Figure 3).
The key design, operational and construction reasons
for using design Alternative 1 are:
 Existing overflow handling line and water seal
box were examined fully using UT inspection
method and found to be in good shape with no
integrity issues or concerns
 Existing water seal box outlet (outgoing pipe)
has an existing bolted flange allowing the field
execution to be performed with minimal field
work and no hot work activity in classified
hazardous areas
 This design relies on horizontal P-trap to provide
the water seal and not the seal box, and, it is fully
inspectable by the conventional methods such as
Ultrasonic Testing (UT)
  It uses the existing overflow line and seal box
minimizing time and duration of the field
execution while minimizing exposure risk to
the crew and the asset, production impact and
material acquisition/usage
 It ensures the liquid level is always 8 inches
above the seal box providing a complete water
seal and enabling routine inspection and
maintenance
 It uses the existing small-bore water supply
from the bottom of the tank to ensure the
horizontal P-trap pipe is water full at all time
A second design (hereafter “Alternative 2”) was also
developed for those liquid overflow handling
systems where the seal boxes have integrity issues
and are not fit for continued service. This design
replaces the entire overflow handling system from
the tank overflow nozzle flange all the way to the
trench. The design uses a double elbow/horizontal
P-trap upside-down to hold the water for sufficient
head and back pressure to seal the gas from exiting
the tank while allowing liquid overflow discharging
into the trench and it also has new pipe supports
(Figure 4).
The key design, operational and construction reasons
for using design Alternative 2 are:
 Existing overflow handling line and water
seal box were examined fully using UT
inspection and found to have substantial
integrity issues either thinned below
minimum wall thickness or already leaking
due to pin holes
 Existing water seal box outlet (outgoing
pipe) has no available bolted flange
connection and therefore fabricating the
entire overflow with double horizontal P-
traps is done on the shop floor with no or
minimal field construction work and no field
hot work activity in classified hazardous
areas
 Replaces the entire system from tank
overflow flange to the trench minimizing
time and duration of the field execution
while minimizing exposure risk to the crew
and the asset and production impact
 This design relies on the double horizontal P-
trap to provide water seal and it is fully
inspectable by the conventional methods such
as UT inspection
 It ensures there is always an 8 inches of water
column exists to seal the gas
 It has an external water injection point to
ensure the pipe is water full at all time
 It has a draining point which allows flushing
the pipe if the water is contaminated or to
monitor the water level
It should also be noted that both design alternatives
(once installed) benefit from daily operator routine
duty and checklist (ORDC) checks to ensure the
system is fully functional and provide a complete
seal.
EXECUTION PROCESSES
Since these improved designs have different weight
loads and center of gravities compared to those of the
existing systems, it is critical that they have adequate
anchors/pipe support(s) to ensure maintaining the
mechanical integrity of the overflow handling system
as well as the integrity of tank shell during a worst-
case scenario of turbulent overflow or a seismic
event. Such scenarios may also impose longitudinal
moments, lateral forces and moments, and torsion,
and therefore, anchors and pipe supports should be
designed to not only take vertical loads but prevent
lateral movements resulted from turbulent overfilled
liquid travelling rapidly through overflow handling
system or seismic events and prevent moments
imposed on the tank overflow nozzle or shell.
In addition to the requirements to perform process
hazard analysis (PHA) and risk assessments to
encompass all possible abnormal events, each design
alternative requires pipe stress analysis to be
performed for all load cases to identify the maximum
stresses at the tank shell overflow nozzle and in the
overflow handling system. Then, suitable anchors
and/or pipe support(s), either the existing standard
designs or new fit-for-purpose design(s), should be
used or developed to ensure all stresses will remain
within allowable limits as per code requirements and
industry best practices.
Installing a (small bore) pipe connection to
drain/flush out the water from seal box/P-trap pipe in
case of an overflow event (or as part of ORDC) and
installing a fill line to replace the product collected
(drained) from the seal box/P-trap pipe with (fresh)
water, are critical parts of both proposed design
Alternatives 1 and 2. This is to:
 account for an overflow event when occurs; in
this case the water will be replaced with
stagnant product inside the seal box/P-trap
pipe which likely to have gas vapor content to
be released to atmosphere. Thus, a refill line
would become critical and should be used
during ORDC or following an overflow event
to replace the product content with (fresh)
water
 ensure regular replacement of the stagnant
water in the seal box/P-trap pipe, which may
become a medium for bacteria growth and
accelerated corrosion, with (fresh) water, is
performed in an acceptable interval as part of
the ORDC.
RESULTS
Field Repairs
Figure 5 depicts one (sample) design out of 5
possible options for the design Alternative 1 to
account for differences in all existing overflow
handling systems which require repairing using this
design alternative. Other 4 options are shown in
Figure 6.
Figure 7 shows two field pictures taken before the
repair and after the design Alternative 1 was
installed for a process wash tank. As can be seen,
the first option (shown in Figure 5) has been used
to complete this repair. No hot work was
performed in the field but the work included
outgoing pipe dismantling, horizontal P-trap
installation using bolted flange, fabrication of a
second pipe support and finally the civil work
associated with the installation of this second pipe
support. Although not shown, due to connectivity
and proximity of other pipework near this tank,
accurate and several field measurements, detail
constructability review, appropriate isolation plan
and detail lifting plan were the key elements to
complete this repair safely, reliably and
successfully.
Figure 8 depicts one (sample) design out of 5
possible options for the design Alternative 2 to
account for differences in all existing overflow
handling systems which require repairing using
this design alternative for replacement of the entire
overflow handling system. Other 4 options are
shown in Figure 9.
Figure 10 shows two field pictures taken before the
repair and after the design Alternative 2 was installed
for a process clarifier tank. As can be seen, the first
option (shown in Figure 8) has been used to complete
this repair and replacement. Some field cutting work
was performed in the field to minimize the size of
lifted pipes and minimize the potential of damaging
the nearby pipework. No other hot work was
performed during this construction work. The work
included dismantling of the entire overflow handling
system, installation of a double horizontal P-trap
pipework, fabrication of a new anchor support (at the
drain end) and another pipe support (under the down-
comer pipe), and finally, the civil work associated
with the installation of the new pipe supports.
Although not shown, surrounded by other nearby
pipework, accurate and several field measurements,
several and detail constructability reviews,
appropriate isolation plan and detail lifting plan were
the key elements to complete this repair and
replacement work safely, reliably and successfully.
Quality control and quality assurance (QA/QC) were
part of the MOC process during early field
measurements, drawing development and approval,
material selection and suitability assessment, shop
fabrication work and finally during and after the
completion of the installation. Each repaired
overflow handling system was then filled with
adequate water, put back into service and finally
tested with gas detector during normal operation to
ensure there is a zero presence of gas while the tanks
are functioning. The gas measurement and
monitoring and water level checks are part of the
operation daily ORDC in line with safe operating
procedure.
Lessons Learned
Although this repair and replacement work is
normally presumed as a routine construction work, it
is critical to consider the operations’ constraints,
equipment age and asset integrity, constructability
challenges due to equipment and pipework
congestion and complexity surrounding the repair
area, isolation plan, lifting sequence and QA/QC to
ensure no impact to the continuous operation while
conducting the work successfully incident and injury
free. It is thus important to have a detailed MOC
process from early stage of design work to the field
execution and handover to operations to include (but
not limited to) field survey, appropriate issue of
drawings for construction, constructability
review(s), development of engineering/construction
work packs, pipe stress analysis for the worst case
scenario(s), design of non-standard pipe supports,
isolation plan, lifting and handling plan, handling
of field changes during execution, permitting,
inspection, functional reviews, QA/QC, pre-start
up safety review (PSSR) etc.
Some of our key lessons learned for this repair
work are highlighted below:
 A robust MOC process would allow
development of work from early stage to
execution and put back in service. Frequent
audit of the MOC and appropriate functional
reviews by all relevant engineering
discipline would ensure the quality and
appropriateness of the MOC
 Several field surveys and measurements and
constructability reviews are key to ensuring
accuracy of the work before execution
 Lifting and handling plan should include
detail sequence of dismantling as well as
sequence of installation in line with
constructability review recommendations –
This may include crews of different
expertise which may need to work
concurrently to achieve the intent of the
construction work
 QA/QC, PSSR, completion of as build
documentation are key final stages before
closing an MOC
 Detail and accurate planning and scheduling
of the work order is critical to ensure
appropriate completion of the entire work
scope within the planned schedule
 Visual and random UT inspection may not be
adequate as part of an ITPM to confirm good
integrity of a tank overflow handling system.
More intrusive inspection methods such as
borescope through hot tapping or other
technologies may need to be used to better
evaluate the conditions of internal sections
e.g. the extended down-comer pipe inside
the seal box.
 Details of this work can be the source of
discussion during code committee meeting
and for the assessment what needs to be
changed in the current code for better and
wider appropriate awareness and action
across oil and gas industry.
CONCLUSIONS & RECOMMENDATIONS
Overfill protection and prevention are the keys in
providing and maintaining safe, reliable and
continuous operations for the aboveground process
and storage tanks. Although the current industry
focus is on flawless overfill protection and
safeguards, the tank incident statistics over the past
several decades suggest that overfills are still the
cause of many process industry incidents especially
for in-service older tanks in which several layers of
overfill and overflow protection may not be in place
or they may be in place but not functioning.
A recent process tank fire investigation determined
that hydrocarbon gas was released through the
malfunctioning and poor integrity of the tank liquid
overflow handling system allowing gas to freely flow
into the overflow line and through the water seal
system to the below grade open drain, subsequently.
Several corrective actions were put in place
including detail inspections and ORDC, and, two
design alternatives were proposed, i.e. Alternative 1
and Alternative 2, and implemented in the field
safely and successfully. While Alternative 1 uses the
existing water seal box with a horizontal P-trap
addition to maintain a water seal, Alternative 2
replaces the entire overflow handling system with a
double horizontal P-trap pipe. The former is used for
overflow lines which have good integrity and the
latter is proposed where the inspection has identified
some integrity issues. Both designs are fully
inspectable by the conventional methods such as UT
inspection.
The results of this work have been shared widely
through industry alerts and this paper intended to
further share detail sequence of technical
development, lessons learned and design concepts
accordingly. Doable recommendations for
corrective actions of existing aboveground process
and storage tank overflow handling systems have
been proposed and the results of field execution have
been provided to allow other operators to implement
appropriate corrective actions accordingly. And
finally, it has been proposed to develop appropriate
amendment(s) to the applicable codes and standards
to ensure awareness while helping to eliminate or
minimize future incidents associated with any
overflow handling system failure.
ACKNOLEDGEMENTS
The authors would like to thank PT. Chevron Pacific
Indonesia for permission to publish this work. They
would also like to thank the working team
including engineering and technical authroity,
operations, infrastructure maintenance, field
engineering, technical services and contractor
teams who work efficiently to complete the field
remedial work safely, successfully and incident
free.
REFERENCES
ANSI/API Standard 2350, 2012, Overfill
Protection for Storage Tanks in Petroleum
Facilities, American Petroleum Institue.
API Standard 650, 2016, Welded Tanks for Oil
Storage, American Petroleum Institute.
API Standard 2000, 2014, Venting Atmospheric and
Low-pressure Storage Tanks, American Petroleum
Institue.
Buncefield Major Incident Investigation Board,
2007, Recommendations on the design and operation
of fuel storage sites.
NFPA 30, 2018, Flammable and Combustible
Liquids Code, National Fire Protection Association.
Roos, C-J, Myers, P. E., 2015, The Engineer’s Guide
to Overfill Prevention, Emerson Process
Management.
Verma, S. and Self, F., 2014, Design Options for
Overfill Protection for Aboveground Storage Tanks:
Proceedings of American Institue of Chemical
Engineers, 10th Global Congress on Process Safety.
 Figure 1 - Hydrocarbon Processing Tank with Liquid Overflow Handling System

Figure 2 - Pin Hole Failure Inside Water Seal Box Allowing Methane Gas to Freely Escape the Seal System
and Release into Atmosphere
Figure 3 - Tank Liquid Overflow Handling System with Improved Horizontal P-Trap Pipe Spool and Existing
Water Seal Box

Figure 4 - Tank Overflow Handling System with Improved Double Horizontal P-Traps Without a Water Seal
Box
Figure 5 - Sample Option of Design Alternative 1 with Improved Horizontal P-Trap Pipe Spool and Existing
Water Seal Box
Figure 6 - Four Other Sample Options of Design Alternative 1 with Improved Horizontal P-trap Pipe Spool
and Existing Water Seal Box
Figure 7 - Wash Tank Overflow Handling System; (a) Original System Before Repair, (b) Improved System
After Repair Using Design Alternative 1

Figure 8 - Sample Option of Design Alternative 2 with Improved Double Horizontal P-Traps Without a Water
Seal Box
Figure 9 - Four Other Sample Options of Design Alternative 2 with Improved Double Horizontal P-Traps
Without a Water Seal Box
Figure 10 - Clarifier Tank Overflow Handling System; (a) Original System Before Repair, (b) Improved
System After Repair Using Design Alternative 2