International best practices Action Priority

Area of investigation Findings/ Gaps/Issues Tank component ( i.e.: Information Intertek Applicable (Benchmark based on Intertek / Apollo Potential Top event Likelihood Impact Has the Risk been identified Action to Mitigate the Risk Propose action Party 1 - High ASAP (< 3 mth)
roof, shell, bottom, est) Source report Standards by PDO? (PDO/External) 2 - Med (6 to 12 mths)
experience) 3 - Low ( 1 to 3 yrs)

A - Design

2
BS 2654 (original Leak and loss of Perform detailed internal and external surveys to
Missing design/as-built drawings. design code) Full suite of Drawings and Calculations held within a document availability YES - create controlled drawings. PDO (to organize survey)
Design data not Incorrect repairs resulting in leak or catastrophic Low PDO has verbally advised that they
A1 - Design data Complete tank available 5.1 API 650 (latest management system and deemed as controlled document failure Extra time and costs to will carry out surveys to create Recommend 3D laser scanning technique tank External (to perform survey
Missing design calculations/analysis. design code used by Formal procedure for updating drawing (redline/review/update) plan inspections and drawings over a period of time. geometry and a check of the tanks and create drawings)
PDO) conduct repairs. settlement/roundness.

2
BS 2654 (original Tank information (summary) - Controlled PDF document with key
No single source/reference that provides the design code) information/drawings, details, maintenance history and main Not possible to efficiently Yes
A2 - Tank information key tank design, details, maintenance history Complete tank Various sources 5.1.1 API 650 (latest integrity threats Leak due to lack of current summary review Low understand the current Information has been entered into Create a controlled PDF tank summary document PDO
summary and main integrity threats. design code used by Annual integrity statements - Controlled PDF document with key status of the tank. CIMS to part address this issue (but is and keep up-to-date.
PDO) information, details, maintenance history and main integrity not up to date).
threats signed off by management annually.

1
As-built nominal bottom thicknesses OK BS 2654 (original The design of tank bottoms and their construction materials 1. Catastrophic failure. No -
compared to API 650 for crude oil operation. design code) should be selected and designed in accordance with recognized although PDO aware of possible issues Revise SOP to ensure that any hydrostatic water
A3 - Floor design vs Annular plate does not meet the API 650 Tank bottom & annular plates Drawings 5.2 API 650 (latest national standards such as BS 2654, API 650 or DIN 4119-1. Failure during hydrotest Low 2. Leak. hence commission of this study test is minimized to avoid exceeding API PDO
latest code (API 650) minimum thickness of 19mm (Actually 15mm in API 650 design code used by 3. Lack of availability requirement
accordance BS 2654) PDO)

The design of tank shell courses and their construction materials

1
BS 2654 (original should be selected and designed in accordance with recognized
design code) national standards such as BS 2654, API 650 or DIN 4119-1. 1. Catastrophic failure. No, Revise SOP to ensure that any hydrostatic water
A4 - Shell design vs Drawings Use finite element analysis to asses design in detail and identify Catastrophic failure through failure of shell 2. Leak. test is minimized to avoid exceeding API
latest code (API 650) Shell thickness not as per API 650 Tank shell courses API 650 5.2 API 650 (latest most likely failure modes/ this can guide the inspection structural integrity. Low 3. Lack of availability although PDO aware of possible issues requirement PDO
design code used by hence commission of this study
PDO)

2
The design of roofs and their construction materials should be
Only outline drawings of roof available although BS 2654 (original selected and designed in accordance with recognized national
A5 -Roof design vs latest some drawings have produced by inspection Drawings design code) standards such as BS 2654, API 650 or DIN 4119-1. Failure of the roof, loss of buoyancy, asymmetric 1. Mal-operation No, although PDO aware of possible
code (API 650) companies to document repairs. Tank roof API 650 5.2 API 650 (latest sinking and thence jamming. Low 2. Repair costs issues hence commission of this study Build full drawing pack PDO
design code used by 3. Lack of availability
PDO) Use finite element analysis to asses design in detail and identify
most likely failure modes/ this can guide the inspection

B - Inspection

1
B1 - Routine in-service No evidence routine in-service inspections are No
Monthly work order for routine in-service inspections. Routine in-service inspections are not Revise SOP (create monthly SAP work order for
("walk-about") being conducted on a monthly basis External areas - shell, roof, API 653 Inspection report templates - consistent data collection. formally documented inspections).
inspections nozzles/pipework, surrounding area, 6.1, 6.2, 6.3 PDO GU-256 Loss of containment Medium Oil leak / tank failure PDO integrity/inspection team.
(API 653 max one month (There
Maximo,
is an annual inspection evident in
but no documented record) stairs/walkway, foundation WO print out PDO SP-2328 Increased scope (Roof drains/vents, pontoons, level alarm tests)
e.g. every 2-3 months.
(but PDO have verbally said these CVI's Routine in-service inspection checklist and report
are carried out by the operation template to be created.
by operator)
team).

2
Partial - Inspection frequencies based on API 653 suitability
External areas - shell, roof, toe External visual inspections and shell for service assessments. PDO integrity/inspection team
B2 - External inspections Formal 5 yearly external Close Visual Inspection plates, nozzles/pipework, API 653 Best practices require more inspection than API 653 with specific Medium UT checks have been conducted but Visual and NDT inspections to be logged as work (to organize inspections)
6.1, 6.2, 6.4 PDO GU-256 visual and NDT report templates to ensure consistent data Loss of containment (Because of the CP system Oil leak / tank failure orders on SAP.
(Visual) not documented surrounding area, stairs/walkway, PDO SP-2328 collection (e.g. location, method and frequency). A issues) API 653 should be used to determine External visual and NDT inspection report External (to perform
foundation inspection intervals. API 653 templates to be created. inspection)
inspectors should lead the inspection.

Inspection frequencies based on API 653 suitability

for service assessments.

3
Decide on inspection methods (cost/benefit of
Formal API 653 external UT Inspection not best practices methods).
B3 - External inspections documented. (15 yearly) External areas - shell, roof, toe API 653 Best practices require more inspection than API 653 with specific Medium Visual and NDT inspections to be logged as work PDO integrity/inspection team
(to organize inspections)
(NDT) It is verbally reported that the vessel has been plates, nozzles/pipework, Verbal 6.1, 6.2, 6.4 PDO GU-256 visual and NDT report templates to ensure consistent data Loss of containment (Because of the CP system Oil leak / tank failure Partial orders on SAP. External (to perform
subject to crawler UT and past low corrosion PDO SP-2328 collection (e.g. location, method and frequency). A issues) Tank 108 in-service inspection checklist to be inspection)
rates indicate that detailed UT is not required created.
External visual and NDT inspection report
templates to be created.

Minimum inspection frequencies based on API 653 suitability for Inspection frequencies based on API 653 suitability
for service assessments.

3
Inspections at 1992, 2001 & 2019 are within the service assessments. Decide on inspection methods (cost/benefit of
API 653 acceptable timeframes Partial - Internal visual inspections best practices methods). PDO integrity/inspection team
B4 - Internal inspections Inspections are not signed of by API 653 Internal areas - shell, roof, bottom PDO inspection API 653 Best practices require more inspection than API 653 with specific Medium have been conducted but API 653 Visual and NDT inspections to be logged as work (to organize inspections)
plates, annular plates, GRE, 6.1, 6.2, 6.5 PDO GU-256 visual and NDT report templates to ensure consistent data Loss of containment (Because of the CP system Oil leak / tank failure should be used to determine
(Visual and NDT) inspector pipework reports PDO SP-2328 collection (e.g. location, method and frequency). issues) inspection intervals. API 653 orders on SAP. External (to perform
inspectors should lead the inspection. Tank 108 out-of-service inspection checklist to be inspection)
Checklists used are not comprehensive Use of inspection checklists to ensure all safety critical systems created.
are properly inspected e.g. fire fighting and foam. Internal visual and NDT inspection report
templates to be created.

2
Specific visual and NDT report templates to ensure consistent Incorrect repairs
resulting in the tank
API 653 data collection (e.g. location, method and frequency) for each Loss of containment requiring to be taken out Creation of specific visual and NDT report
B5 - Reporting / Report contents lacking information required by Complete tank 2020 inspection 6.6 PDO GU-256 type of inspection (routine, external, internal). Low of service (due to missing No templates to ensure consistent data collection PDO
Documentation API 653. reports PDO SP-2328 reported information (e.g. location, method and frequency) for each
Reports are controlled documents within a document type of inspection (routine, external, internal).
management system uploaded to CIMS post
inspection).

C - Integrity (Corrosion)
Threats

3
Maintain GRE lining specially in the area around
No issues / gaps identified. striker plate where damage has occurred.
C1-1 Internal corrosion (No reported shell wall thickness loss, 2014 and (a) Shell above GRE Specific inspection points and patterns (i.e. away from ladders), Loss of containment Low (no reported internal
[25] 6.2 & 8.1 EMMUA Pub 159 not just random, Detail check points full reporting (not by Oil leak / tank failure Yes Monthly GVI visual (occurrence of leak) inspection. PDO
threat stabilized crude with low water cut and (b) Lower shell (below GRE) exception) corrosion in T-108)
degassed - hence non-corrosive). (c) Bottom (GRE coated) Continue UT measurements during planned
inspection

C1-2 Internal corrosion Outer most plate - severe corrosion, thinning

threat (roof) and detached condition Roof outer shell [25] 5.5.5 EEMUA Pub 159 3 monthly leakage inspection Loss of roof seal and pontoon integrity (roof
buoyancy issues)
High (corrosion already
identified on rood rim)
Roof failure.
Loss of plant availability. Yes - repairs carried out
Confirm cause of corrosion & consider use of
protective coatings
Complete repairs / additional actions and re-
inspect.
PDO Maintenance team
1
 C2 External corrosion
threat - atmospheric
corrosion
No issues / gaps identified .
(PCS-1A coating applied)
Tank shell and roof [25] 6.1 & 9.1 PDO SP-1246
PDO are content with their current coating system, however,
some operators have used an acrylic polyurethane topcoat for
easier maintenance and improved appearance.
Loss of containment
Low (PDO maintain the coating
and have had good
performance over the years)
Oil leak / tank failure Yes - protective coating applied and
maintained.
Continue to inspect and re-coat as required. Continue with current coating
maintenance programme.
3
C3 External corrosion Issues identified with respect to CP system - see Bottom (underside) Yes
threat - underside of below CIMS CP data 5.5.2 & 7 See below Medium PDO has initiated an upgrade Complete CP review and upgrading PDO / CP Contractor
tank bottom plate programme

Maintain a complete and up-to-date record to demonstrate that

Underside of tank bottom (including CIMS data the CP system is operating in accordance with SoP / Std. Yes reported by PDO as per system 1. Keep CIMS updated. 1. PDO Corrosion control and
C3-1. CP system Data Minor -most recent data not in CIMS. 7.2 The CP system is the only mitigation system in place, hence it is Medium 2. Identify responsibilities for data collection, entry maintenance team.
annular plates) best practice to regularly check the CP system to ensure that it is requirement. and assessment /checking. 2. Third party CP contractor.
operational to the maximum effect.

2
For very large dia tanks, readings are taken at rim and in the
NACE SP0193 centre of the floor (as rim readings are not representative). Collect CP readings from either permanent
C3-2. CP monitoring PDO SP-1128 Hence standard practice is to use monitoring tubes or install Leak through the floor damaging the tank Oil leak / loss of reference electrodes installed under tank or use PDO Corrosion Control /
locations No evidence of CP readings at centre Underside of tank bottom CIMS data 7.1 & 7.2 permanent reference electrode under tank bottom. foundations and soil support, which could lead to Medium No monitoring tube (perforated tube with electrode Maintenance Team
API 651 instability and eventual catastrophic failure availability
EN 16299 Alternatively need to undertake calculations / modelling to pulled through).
estimate level of protection

Method of measuring decay used at this time is incorrect.

Should be determined from Instant Off potential. Change to -850 mV criteria and improve CP system
C3-3. CP criteria PDO use the 100 mV criteria Underside of tank bottom CIMS data 7.3 However, whilst the 100 mV criteria is included in some Medium Criteria not routinely applied - special performance by: (1) reducing current drain, (2) PDO Corrosion Control /
standards, it is not applicable to cases where there are mixed authorization required. increasing CP system output Maintenance Team
metal systems. Also consider applying criteria as per EN 14505
Alternative approach (as per EN 14505) should be adopted.

Yes If major tank bottom replacement is required it is

C3-4. Anode layout Grid anode beneath tank bottom not used (for Underside of tank bottom (including System description 7.1 For any new tank (or for a tank with full floor replacement) a Low (CP is possible with other PDO standard drawing (STD-00-
this tank) annular plates) MMO anode grid arrangement should be used. anode groundbed types) 000000-RA-2309-91013-0001) shows recommended the CP Contractor assess options PDO / CP Contractor
for anode grid arrangements as part of the works.
typical layout

D - Maintenance

Probabilistic Planned Maintenance through:

--Plan-Do-Check-Act loop (SP-2328)
--RBI .

3
(see specification and guidelines example) -- Reliability centered maintenance (RCM) focusing on non- 1. Catastrophic failure. Continue to follow procedures and API 653 at all
API 653 times.
D1 - Compliance to PDO Relevant procedures are aligned to the required
API standards. PDO GU-256 API 650 trendable degradation to get the optimum maintenance
requirements of the asset based on experience performance
2. Leak.
3. Mal-operation Yes - as company procedures have
procedures and Complete tank PDO SP-2374 10.2 PDO GU-256 and/or manufacturer advice. Loss of containment Medium 4. Extra costs been aligned to API 650 and 653. Create engineering/technical guidance documents PDO
specifications Reporting to be improved to be fully aligned PDO-2328 PDO SP-2374 --Life cycle costing of maintenance 5. Lack of plant aligned to API 653 and best practices.
with API requirements PDO-2328 --Robust document management system/ document numbering availability
-- Audit schemes at all levels of operation
--Auditing and assessment of subcontractors
-- designated Technical Authorities, intendent within organization

All proposed design, work execution, materials, welding

procedures, examination, and testing methods are approved by Follow procedures and API 653 at all times. API
the company prior to commencement. 653 authorized inspectors role to be made more
Limited evidence that quality of workmanship is apparent in maintenance procedures (SP-2374
being adequately supervised. E.g. all inspection Documents relating to inspection and maintenance of a tank refers to 'QC inspector').

1
and repair work should have an approval from a include the name, company, API 653 certification number and 1. Catastrophic failure. Yes to an extent.
D2 - Quality of recognized API 653 inspector API 653 signature of the authorized inspector responsible for the 2. Leak. Create engineering/technical guidance documents
Inspection/ API 650 supervision of works and overall evaluation of the tank. Loss of containment Company procedures require all work aligned to API 653 and best practices.
workmanship and (Cannot be fully evaluated through a desktop Complete tank maintenance 10.3 PDO SP-2328 Medium 3. Mal-operation to be assessed and as provided by API PDO
QA/QC maintenance study). documentation PDO SP-2374 Audit schemes specially for subcontractors 4. Extra costs 653 inspectors. However, this does Pre and post maintenance
work PDO GU-256 5. Lack of plant not appear to be fully implemented in reporting/documentation improvements.
No evidence of PDO assessment and acceptance Clear differential between inspection and repair work packs availability all cases.
of the inspection company recommendations Suggest combined inspection/repair reports are
prior to commissioning maintenance & repair.. clear Pre and post maintenance reporting/documentation replaced by seperate inspection and repair
reports, with full PDO review and approval.
Work planning to assign WO numbers to each task, so all tasks can
be easily tracked

1
Based on review of inspection reports and
integrity documents, there are actions/repairs API 653 Clear documentation of Maintenance process through: Records, Loss of containment 1. Catastrophic failure. Review oustanding tasks table and determine what
that have been started however no evidence API 650 Cleaning, Inspection, Compliance, Engineering, Repair, FFS. 2. Leak. No evidence these repairs have been has been completed. Add any remaining tasks as
D3 - Outstanding Tasks has been provided whether this has been Complete tank inspection reports 10.1 PDO SP-2328 Work planning to assign WO numbers to each task, so all tasks can Missed repairs resulting in the tank requiring to Medium 3. Extra costs conducted future work orders. PDO
carried out. PDO SP-2374 be easily tracked be taken out of service (or an extension of an on- 4. Lack of plant Ensure that in future full task table is developed
PDO GU-256 going out of service campaign) availability and maintained.

Turnaround should be undertaken as a major

1
Project activity, with planning commencing at
least one year ahead, with >90% of activities 1. Additional time for No.
planned in advance based on previous
D4 Shutdown experience. Complete tank F2F meetings Site visit report EEMUA Pub 159 Turnarounds of major equipment is almost always organised as a Loss of storage capacity High turnarounds. Turnarounds appear to be undertaken Turnarounds to be project based and led by a PDO
(Turnaround) planning & 10.1.3 Project. 2. Additonal costs. as a maintenance activity, with times Senior PDO Engineer
Some of the maintenance is fix on fail, rather 3. Loss of capacity. extending from 4 to 12 months.
than preventative maintenance.
There was no evidence of equipment reliability
data

E - Operations
 Tank 108 PI data shows that during a consistent
period of operation (Sep 17 - Dec 18) tank level
often marginally exceeded 91% high alarm and Yes. Operate within normal tank levels (11-91%).
frequently dipped below low level of 11% (8- 91% high and 94% high-high alarms
9%). Crude temperature always within tank Tank levels consistently remain within high-low level alarm levels. are in place as per the operating Follow tank topping procedure if temporary
design range. manual. Procedures are in place in for increase is required.

1
A log of manual and critical operations such as tank topping is the manual operation of tank topping.
PI data does not indicate when manual tank PI Data API 653 kept. Tank is overfilled resulting in leaking oil and Medium Ensure maximum level is within API 653
Tank Operation PI Data topping has been performed, however there is a MAF Operating MAF Operating vapour clouds - catastrophic fire if ignited. No. acceptable limits as per shell/annular plates
(crude levels and Tank contents 11.1 Manual Crude level is determined manually - best practice is for automatic Oil leak / tank failure measured wall loss. PDO
temperature) procedure in place for this. Must consider Manual PDO PR-1092 measurement. Damage to tank floor GRE liner by support legs High - it has already occurred valve closure instrumentation settings
current tank condition when performing this F2F meetings resulting in risk of corrosion and potential leak. on many occasions are at LL and HH. Ensure low and low-low level alarms are adhered
(wall loss vs allowable tank capacity). Safety critical valves must have Performance Standards which are to.
measured and trended, and instrumented closure settings
The site visit identified valve closure changes and maintenance interventions are made accordingly. Adjust valve closure settings to account for time
commences at the LL and HH levels and does for valves to close.
not include time for valve closure or leaks,
hence overfilling and overemptying almost
always occurs.

Operate within normal tank levels (11-91%) unless

inspection results show degradation.

Max allowable crude level at any time should be
based on API 653 suitability for service
Tank fill height relative assessment results (measured course and
to tank condition annular plate thicknesses vs minimum
allowables).
Tank shell and annular plates
1
Always operating within suitability for service requirements.
API 653 No - Suitability for service assessments CIMS to be fully populated with the most up to
Not addressed in MAF Operating date inspection data and checked against API 653
documentation 11 Manual Tank is overfilled resulting in leaking oil and Medium Oil leak / tank failure not routinely performed/checked.
provided. PDO PR-1092 Any deviation from operational norms is subject to an vapour clouds - catastrophic fire if ignited. CIMS not fully populated with critical minimum
function).
allowable thicknesses (built in CIMs PDO
"Operational Risk Assesment" . The ORA is a fromal procedure and data.
each ORA is fully documented and appropriately recorded API 653 suitability for service assessments to be
performed to determine required plate
thicknesses relative to crude operating levels.

3
API 653 Best practice recommended rate of change is limited to a Fill/empty tank 108 at a maximum rate of 2m per
Tank 108 fill/empty rates are generally below MAF Operating maximum of between 1.5m and 2m per hour. Faster rates should hour.
Tank fill/empty rates 2m per hr based on PI data. Tank contents PI Data 11.2 Manual only be applied subject to risk assessment in advance. Roof failure (damaged legs or rim seals due to Medium Oil leak / Tank failure Rates are typically within range of the
PDO PR-1092 hard landing) recommended rates. Externally visual inspect the roof looking for seal PDO
damage, roof tilt or signs of oil if this rate is
exceeded.

Legs ground at approximately 8/9% crude level

if the leg is pinned in the upper pinhole, and
5/6% when using the lower pinhole.
Operate within normal tank levels (11-91%).

1
PI data indicates crude level consistently drops API 653
to below 8.5-9% resulting in a high chance the Fill/empty tank 108 at a maximum rate of 2m per
levels are being grounded (tank low level is 11%, Tank roof and legs PI data MAF Operating Tank levels consistently remain within high-low level alarm levels. Roof failure (damaged legs). No - normal operating levels dropping hour.
Legs Grounding Out which provides ample grounding clearance). 150 Redline Markup 12.3.1 Manual Avoid grounding legs during typical operation. High Roof failure below low level alarm. PDO
of 162 strikers plates were found damaged and Drawings PDO PR-1092 Externally visual inspect the roof looking for seal
replaced in 2020 inspection. damage, roof tilt or signs of oil if this rate is
exceeded.
Evidence that legs operated in Maintenance and
not Operating Position.

1
The consequences of creeping changes in Not in a standard, Although the consequences of creeping changes has been 1. Human factors failures by Plant Operators. 1. Catastrophic failure.
but widely reported reported on in the technical press and project reports (eg UK 2. Design errors. 2. Leak.
upstream conditions had not been identified by All, including piping, valves, Intertek Site on in technical HSE's KP4 report), it has not yet been codified in Standards. Many 3. Additional time to create and implement work High 3. Mal-operation Initiate a third party review of creeping changes in PDO
Creeping change MAF tank farm, although some of the instrumentation F2F meetings Visit Report papers and books large hydrocarbon producers recognise the importance of packages. 4. Extra costs No the most critical areas, e.g. plant operations
consequences were already being experienced relating to causation creeping change and assess it by means of third party reviews, 4. Not understanding the implications of 5. Lack of plant
(e.g. more sludge) of major accidents including Human Factors considerations. operational changes on safety. availability

Roof drains In contravention to procedure roof drain lines

are open all the time Roof F2F meetings
Intertek Site
Visit Report & EEMUA Pub 159
11.5
Roof drains are usually closed unless required to be open due to
anticipated heavy rain Leak of oil into the flexible drain line Medium
1. Fire
2. Environmental
damage
Yes (in procedure)
Follow procedure.
Resolve conflicting and inconsistent information,
e.g. HAZOP & PEFS.
PDO to carry out additional
checks
1

2
Ensure that the four rim vents are operational at
The 12 relief vents are blocked off (no API 650 all times - inlcude in regular inspection (e.g. every PDO to carry out additional
Vents requirement for vents to be fitted). Roof vents 4.2.1 API 650 Generally vent spacing of 40 to 50 m recommended. Build-up of pressure if vents blocked Medium 1. Seal failure. Yes 3 months).
EEMUA 159 2. Leak. Perform a risk assessment to determine the effect checks
4 rim vents fitted but spacing approx 73 m if any of the vents become non-operational.
 Piping and valves None of the tank farm piping or valves were
clearly marked
Piping Site visit
Intertek Site ISO 20560
Visit Report & ASME A13.1
11.6 BS1710
All major international hydrocarbon companies identify all on-site 1. Working on the wrong line.
piping. 2. Inspecting the wrong line
Medium
1. Fire
2. Environmental
damage
3. Lost time
No Mark up all tank farm lines and valves in
accordance with standards
PDO
2
F - Specifications and guidelines

The main integrity documents are generally Dashboarding of Tank(s) State of health of all barrier guard against
aligned to API. More specific guidance should be major accident hazards
added (above and beyond best practice). Anomaly management procedures

2
Annual integrity statements
API 653 Robust Document management systems Follow procedures and API 653 at all times.
F1 - Alignment to API GU-256 (inspection guidelines) refers to API 653 PDO GU-256 API 650 Comprehensive training program Loss of containment
650/653 & comparison, for tank inspectors. Yes - as company procedures have Create engineering/technical guidance documents PDO
benchmarking to best SP-2374 (repair methods) is aligned to API 653 Complete tank PDO SP-2374
PDO-2328
Throughout PDO GU-256
PDO SP-2374
Audit scheme at all levels
Clear scope of work for any sub-contractors
Low Oil leak / Tank failure been aligned to API 650 and 653. aligned to API 653 and best practices.
practices repair and NDT requirements. PDO-2328 Consistency in style " document templates/ report numbering /
SP-2328 (integrity management) refers to API Robust document control.
653 for tank integrity assessments. contents " etc.
SP-2187 (tank specification) refers to API 650 for Clear process for closing the PLAN_DO_ACT_CHECK loop, whereby
the design specification required for new tanks. the inspection results inform the next inspection plan

G- Competency

1
API 650 1. Human factors failures by Plant Operators. 1. Catastrophic failure.
Concerns expressed at all levels of PDO about API 653 2. Design errors. 2. Leak.
loss of experience. Intertek Site ASME IX International operators maintain a competency profile across 3. Additional time to create and implement work 3. Mal-operation Yes - this was evident from PDO Identify key functions and provide additional
G1. Loss of experience All, including operations F2F meetings assets which considers age profiles and future requirements to High support at Consultant level (ie technical support PDO
Contractors also expressed concern over their Visit Report UK Engineering replace retiring personnel and loss by resignations. packages. 4. Extra costs meetings only, no management function)
own loss of experience. Council guidance on 4. Not understanding the implications of 5. Lack of plant
Competency operational changes on safety. availability

1. Human Factors failures by Plant Operators, e.g. High.

resulting in over-filling and thence a major leak.
G2. 2. Poor quality weldments causing cracks and In times when oil prices are low

2
major leaks. companies respond by reducing
1. Inspectors API 650 All tank farm operators have written job descriptions for 3. Poor quality inspections allowing wall thinning staff numbers and hence the 1. Catastrophic failure. Ensure there are suitable job Descriptions for all
(PDO/Contractor) Evidence provided of five Job Descriptions, PDO Static (see separate API 653 personnel regularly working on their assets. to go unattended, thence major leaks. pool of knowledge available to 2. Leak. personnel who may have an impact on Safety
2. Integrity Engineer which are well laid out, although years of All, including operations Equipment competency ASME IX 4. Inadequate understanding of structural & keep assets safe. 3. Mal-operation Yes - included in current scope Critical Elements PDO
(PDO/Contractor) UK Engineering 4. Extra costs
3. Operation/ required experience is considered to be low Guideline, GU-256 report) For occasional contractor activities
Council guidance on be made to AWS and/or ASME IX such as welding, reference can engineering design resulting in catastrophic tank There may also be a drive to 5. Lack of plant
maintenance (PDO/ Competency collapse. hire cheaper personnel who availability
Contractor) 5. Poor quality maintenance can result in failures, lack the necessary experience -
e.g. of level gauges (Ref: Buncefield accident, UK, Competency is based on:
11 December 2005) Qualifications + Training +
etc. etc. Experience

H - Suitable-for-Service (SFS) / Fit-for-Service (FFS)

Current method for assessing suitability for Determine Level I FFS strictly in accordance with API 653 Ensure inspections are planned and carried out in

2
service does not meet all API 653 requirements, augmented by API 579-1 Level 2 (occasionally Level 3) where accordance with API 653.
e.g. tank 108 level 1 assessment in inspection severe damage identified. 1. Catastrophic failure. CIMs has been created to include API
H1. Compare PDO SP report (initial 2020) stipulated 40% wall loss is inspection reports API 653 Use of FFS assessments to determine next inspection dates. Worst case scenario - catastrophic failure 2. Leak. 653 minimum allowable thickness Carry out FFS assessments in accordance with API PDO (supported by
the criteria for plate replacement. No reference Complete tank MAF Integrity Throughout API 650 Medium 3. Extra costs checks but it is not being fully utilized 653 / API 579.
with API 653 supplied to support this criteria. Assessment 2018 PDO SP-2328 Long term corrosion rates calculated (from installation to current Most likely scenario - leaks 4. Lack of plant due to missing information. experienced FFS consultant)
date). availability PDO have a RBI system in place Ensure CIMS is fully up-to-date, with nominal,
MAF RBI integrity assessment is an uncontrolled Short term corrosion rates calculated (between inspections). minimum allowable and measured thicknesses
UT measurements taken at critical plate locations
document entered for each plate.

Roof flooding.
Roof pontoons were noted as leaking soon after T-108 Test Pack Client review and acceptance of inspection results

1
return to service following 2020 refurb. (2020 Overhauling) Workpacks for repair approved by client prior to commencing root cause analysis of reason for current damage
folder work Loss of containment, loss to leg sleeves evident on latest inspection
H2. Oil in roof Either Inspections not done correctly OR Repair (specifically, "1. Final acceptance inspection by CLIENT or appropriate third party of availability the suspicion is that the damage may have
compartments 5, 6 and methods used resulted in damage Roof Inspection Check 6, 10, 12 API 653 personnel Loss of roof buoyancy High PDO are undertaking inspection PDO integrity/inspection
7 List.pdf", "14. MPT Root Cause Analysis of any unusual anomalies occurred during the refurbishment in 2020,
2021 inspection data has identified that 58 of Reports.pdf", "17. Results of inspection/repair/investigations reviewed and formally specifically support of the roof during the striker
162 support legs (36%) have cracked welds Redline Markup reported across all departments organization, plate replacement
where they join the roof and therefore cannot Drawings.pdf")
be relied upon for structural integrity.

3
1. Catastrophic failure.
H3. Fatigue No fatigue issues identified Shell / Annular plate & bottom plate (based on high
review of fill levels 12.2 API 653
"digital twin" real-time monitoring of fill rates and subsequent
loading on vessel to identify life span. Weld failure leading to leakage Low
2. Leak.
3. Extra costs No, although PDO aware of possible Estimated fatigue life is > 25 yrs. But welds should
to annular connection issues hence commission of this study be continued to be inspected as per current PDO
over time) Note this would be on a cost benefit basis for high risk tanks only 4. Lack of plant frequency.
availability