Develop a publication that addresses preventing the overflow of pressure vessels such as towers and drums. The publication should be applicable to both new and existing pressure vessels. Include the following at a minimum:
a) Description of typical overflow events that could result during normal, upset, or transient operations (startup, shutdown, standby) including the formation of a vapor cloud,
b) Recommended practices for instrumentation to monitor and detect a pressure vessel overflow,
c) Process hazard analysis guidance for pressure vessel overflow scenarios,
d) Recommended practices for safeguards to prevent a pressure vessel overflow,
e) Recommended field and board operator process safety training topics and methods to prevent a pressure vessel overflow,
f) Guidelines for process safety assessments to prevent a pressure vessel overflow, and
g) Incorporate lessons learned from this CSB investigation and the CSB’s BP Texas City Refinery investigation throughout the document.