fire protection system complemented with
mobile/semi-fixed equipment (available to
be deployed at a moment’s notice).
Photo 2: Foam system designed to combat rim
seal fire (4)
worldwide where the floating roof has sunk and
a full surface tank fire developed. An operator’s
Safety Case assessment should consider this
scenario, including its causes, consequences and
firefighting policy (5).
Conclusion and Recommendations
The safety aspect must be incorporated at all
stages of a project, not just during the operational
lifetime of a project. Early intervention will
eliminate and reduce much of the risk associated
with the project. Towards achieving this, this article
introduces the concept of Independent Protection
Layers (IPLs) in order to emphasise the need to
have adequate and effective safety measures to
prepare for catastrophic failure. Below are the
authors’ recommendations:
1. Bunds should be constructed as per
recommended specifications above, with
bund performance standards developed
with minimum performance specifications,
to be used during periodical inspections.
2. Have firefighting capability to manage fire
in a controllable and safe manner to avoid
escalation of fire. This includes proper
planning of emergency response manpower
(competency and training), foam reserve
availability (of suitable type and sufficient
for full surface fire demand) and active
Disclaimer
The specifications detailed for bunding
requirements in this article may be more stringent
compared to the Department of Environment’s
(DOE) requirements. However, note that the
purpose of having bunds is not limited to
containing spills, but also to limit fire and heat
exposure during a pool fire event. Considering the
risk of pool fire, an individual bund is always better
than a common bund for more than one tank, and
the 133% or greater bund capacity is well above
the requirement of 110% maximum capacity of
largest tank.
Note that this article limited discussion
to aboveground storage tanks and does not
discuss underground storage tank requirements
where bunds are not applicable as secondary
containment and other methods to contain spills
such as double wall tanks may be required.
Lastly, the authors were not involved in any
way in the investigation of the Kemaman Bitumen
Company fire and thus the recommendations can
only be treated as opinion.
REFERENCE
(1) News Straits Time: 150 firefighters still
battling Terengganu’s largest blaze in years,
July 6, 2018
(2) Australian Environment Protection Authority :
Bunding and spill management, May 2016
(3) UK HSE : Safety and environmental standards
for fuel storage sites: Process Safety
Leadership Group Final report, 2009
(4) Sensor ACM: Foam and spray system https://
w w w. sensor- acm.pl/our- of fer/for-fuel -
energy-and-chemical-industry/tank-gauging-
equipment-and-solutions/foam-and-spray-
systems/ accessed on 9/7/2018
(5) New Zealand Government worksafe.govt.nz :
Floating roof tank fire scenarios, July 2017
(6) Ireland Environmental Protection Agency :
IPC Guidance Note on Storage and Transfer
of Materials for Scheduled Activities, 2004
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