Newest PEI Committee Takes On Overfill Prevention

RP600 Committee works on overfill prevention for shop-fabricated aboveground tanks.

In 2005, Sonny Underwood's customer, MFA Oil Company, lost the life of a transport worker to a fire during delivery of fuel to a bulk plant in Marshall, Missouri. Although the cause of the fire remains unknown, Underwood says the incident brought safety issues concerning aboveground storage tanks to the forefront. “Anytime you have a loss of life, it brings this kind of thing to the front page.”

RP600 Committee: (seated l-r) Terry Cooper, Alfred Reid, Amy Wessel; (standing l-r) Tracy Barth, Brad Holmes, Sonny Underwood, Sam Lillard, John Albert, Dana Schmidt

A few months later, in May 2006, Underwood, president of Mid-South Steel Products of Cape Girardeau, Missouri, spearheaded PEI's recommended practices for Overfill Prevention for Shop-Fabricated Above-ground Tanks Committee, aka RP600, in an effort to write recommended practices for the installation, inspection, testing and maintenance of overfill protection devices for shop-fabricated aboveground storage tanks. These tanks would have a capacity of 50,000 gallons or less, and be used to store combustible and flammable liquids delivered from wheeled vehicles. Until now, common standards involving the issue were missing from the industry. “There isn't a nationwide, uniform recommended practice for overfill protection, and there is certainly a need for one,” says Underwood. “Cutting down on overfill will save lives and property.”

Life, Property and the Pursuit of Safety
The safe operation of a petroleum storage facility is dependent upon the receipt of product into the intended storage tank within its defined capacity. The goal of RP600 is to provide a concise reference document that consolidates information from equipment manufacturers, installers and industry-related associations concerning the proper installation, inspection, testing and maintenance of overfill protection devices installed on aboveground storage tanks (AST). “We want to make sure we have a practice that adheres to the workings of the industry and applies the principles to our facilities,” says Underwood.

Uniting States
Adhering to industry meant creating a document that was universal among states. “There is no consistency concerning AST overfill,” Underwood points out. “In one state, there may even be two or three opinions on how it should be handled.” Underwood's company is located in Missouri, one of the few states that allow aboveground storage tanks for retail station use, exposing the public to the tanks more often than other states. “Missouri has a lot of retail outlets that have aboveground storage, and they do catch fire. They are not small fires,” says Underwood. “Most fires in the state of Missouri associated with these tanks have involved overfilled tanks. I'm sure other states follow a similar pattern. This is a public safety concern.”

Florida's Department of Environmental Protection began to study the problem in 2003. Two reports, the Cause of Leak Study and the ongoing Leak Autopsy Study, document that overfilling is the most frequent cause of oil spills from aboveground storage tanks and is usually associated with human error. The major causes identified include incorrect equipment installation, improper or missing maintenance, failure to develop tank fill operating procedures or to properly follow product delivery procedures, and incompetent, inexperienced or inattentive product delivery personnel.

The PEI committee believes that part of the problem is due to the lack of consistent criteria among states. Underwood explains, “There are no criteria for putting the overfill protection devices together that will make a safe system in the environment. Our committee's purpose is to write a recommended practice covering the overfill of aboveground storage tanks.”

From Manufacturer to End-User
It was important to Underwood that the ten-member committee represent all aspects of the industry. It is comprised of manufacturers of overfill equipment, state regulators from Missouri, Florida and Virginia, PEI distributors of overfill protection devices, representatives from the American Petroleum Institute, the Steel Tank Institute and end-users. Marcel Moreau, a consultant currently assisting PEI on various RPs, has a regulatory background and serves as the committee consultant and writer of the document.

“We don't think, we know, we have all of our bases covered in the industry with our committee members,” says Underwood.

Declaration of Safety
Prior to their first meeting in August 2006, committee members communicated with Moreau an outline of the important issues they believed the document should contain. Moreau drew up a rough draft for the committee to review and to work out the details of each chapter. “The safety of the people around these storage tanks was our utmost concern,” says Underwood. “We always have safety features and the safety parameters at the back of our minds throughout every aspect of writing this document.” Throughout these months, committee members corresponded regulary through e-mail and conference calls.

This past January, the committee met to review the document before it is distributed to 10,000 people for review. The public comments will be categorized and the committee will meet again this summer to review the comments and further finalize the document that is scheduled to be published in Fall 2007.

The final document plans to minimize the possibility of overfill protection device failure, reduce fire hazards, promote the safe delivery of product into shop-fabricated ASTs from wheeled vehicles, prevent surface and groundwater contamination and minimize environmental hazards.

Delivery of product into tanks from pipeline or barges is not included within the scope of the document. The recommended practices may be applied to horizontal and vertical tanks, single-and multi-walled tanks, as well as insulated and fore protected (resistant) tanks. Tanks covered in the recommended practices are intended for the storage of liquid motor fuels at or near atmospheric pressure.

Saving Lives
Although the committee will no longer meet on a regular basis after publication of the document, it will remain a standing committee of the association. “As technology and regulations change, RPs get reviewed periodically,” says Underwood.

Underwood is confident that the document will serve as a universal guide to preventing AST overfill and follow the trend of other PEI recommended practices. “Every RP that our association has done to date has been well received throughout the industry,” says Underwood. He is hopeful that RP600 will fill a large void throughout the industry and will prevent creating voids in people's lives. “After all,” he says, “the reason for RP600 is to save lives.”

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The PEI Journal • First Quarter 2007 • Volume 1, No. 1 • Contents are Copyright © Data Key Communications, Inc.
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