Addressing API Standard 2350 for

Overfill Protection
A Varec, Inc. White Paper
Addressing
API Standard 2350
for Overfill Protection and Prevention

In the coming months and years, owners and operators of US-based petroleum storage
facilities will be required to meet the American Petroleum Institutes Standard 2350 for overfill
protection. This white paper explains in laymans terms some of the concepts behind the
standard while also providing...

1. What to look for in a control room system when performing a risk assessment.

2. Examples of how to apply the right Varec solution to your chosen API 2350 tank
categorization.

3. A dynamic API 2350 Tank Worksheet.

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Varec, Inc.
 API Standard 2350 provides conceptual overviews
to assist in the definition of a facility specific
Overfill Prevention Process.

Overfill Prevention Process

The updated API Standard 2350 is intended to API Standard 2350 recognizes facility-specific
encompass bulk storage tanks over 1,320 U.S. requirements and places ultimate responsibility
gallons (5000 liters) that contain Class I or Class II for compliance with the owner or operator. For
petroleum liquids and to ensure successful shut- some, performing and documenting these steps in
down of a receipt or transfer operation in the event an unbiased manner can be difficult, especially in
of a possible tank overfill. Standard 2350 provides areas where the Standard is not specific. Therefore,
structured guidance for a facility to identify the it the wise operator will consult with an external
steps required to achieve compliance. In summary, companyone with a wide range of experience
API Standard 2350 recommends that facilities in the areas of controls automation, systems
should perform the following tasks to define and integration, tank gauging, and environmental
document an Overfill Prevention Process (OPP). compliance.
Perform a risk assessment and gap analysis of
current equipment and operations.

Re-categorize tanksidentify and define levels of

concern and response times for each tank based
on the analysis.
Define the required actions to ensure adequate
response to an event.

Document the entire overfill prevention process.

Train facility personnel on the new process and

manage the process.

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Varec, Inc. Overfill Prevention Process
 Operational assessments conducted by a
objective third-party can uncover situations of
risk that your facility personnel would not see.

Risk Assessment
When performing and documenting a risk Risk assessment is an area where a third-party can
assessment, an operator should focus on the provide an unbiased view. A third-party company
probable loss of containment that could occur will ask the questions and help define answers for
under normal and abnormal conditions. Historical situations and processes that facility personnel take
operational datafill times, flow rates, alarm limits, for granted, situations that they feel everybody
operator awareness, operator communications, on site is aware of and knows how and when to
responsibilities, ESD actions, logicshould all be react. A third party can often easily identify these
available for analysis. If data is not available, then undefined and dangerous situations.
data should be collected over a period of time
to estimate future performance. For an optimal
analysis, both the recipients and transporters
operations should be investigated.

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Varec, Inc. Risk Assessment
 Independent measurement systems on category 3 tanks
require uninterrupted power supplies and separate
communications wiring (from the primary ATGS) to the
point of alarm or AOPS activation.

Alarms and Alerts

Standard 2350 does not go so far as to define Generally speaking, for category 1 and 2 tanks,
or recommend methods or equipment that alarm outputs from an ATG system could either
would fulfill the requirements for redundancy or trigger an alarm directly, or be wired to a PLC
electronic signal communications for triggering or control-room system that in turn activates
alarms or activating an overfill prevention system. alarms or alerts. In the case of category 3 tanks,
It simply refers to the use of logic-solving systems communications to a PLC (or DCS) system would
that output to specific alarms or alert indicators be most likely. The PLC system could then activate
based on the categorization of a tank. An the alarm or Automatic Overfill Prevention System
understanding of controls automation and system (AOPS) and share data from the instrument to the
integration will help align operations and systems inventory control system or the transporter while
within APIs tank category structure. still maintaining independence.

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Varec, Inc. Alarms and Alerts
 Tank gauging and alarm systems are utilized at the
discretion of the facility owner and operator when
tanks are fully attended during receipt.

Categorizing Tanks Levels of Concern (LOC)

The revised API standard provides guidance on At a minimum, three LOC are established (CH, HH,
how to categorize a petroleum tank based on the MW) to drive alarms and alerts. Two additional
location of facility personnel and their ability to levels are deemed optional depending on the tank
oversee receipt operations. This guidance helps to category. Each LOC is established by understanding
identify the levels within a tank that would be of the response time that is appropriate for the rate of
concern during filling operations and the required volume change in the tank and the reaction time
response times needed to terminate the receipt. needed by personnel or a system to shut down
Within this context, API Standard 2350 the receipt. Depending on the tank category, API
recommends that the on-tank measurement recommends specific actions be undertaken, and
systems provide a minimum level of protection. alarms, alerts, or notifications be triggered when an
LOC is reached.
* Please refer to the published API Standard 2350 for
specific attendance recommendations

Critical High level (CH) requires an emergency management

response and a notification is recommended.
Automatic Overfill Prevention System (AOPS) on category 3 tanks
is activated between HH and CH levels with an optional alarm.
High-High level (HH) requires an alarm
and receipt termination response.
Maximum Working level (MW)
with optional alert

Working Capacity

Definition of a minimum working

level and alert is optional.

Fig. 1 - Levels of Concern per API Standard 2350

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Varec, Inc. Categorizing Tanks
 Unattended tanks should be monitored
remotely to ensure product level is maintained
within normal operating conditions

Tank Category
Category 1: Fully Attended Tanks (Diagrams 1 Category 3: Unattended Tanks (Diagrams 9,
& 2) Local operations personnel must monitor 10, & 11) A primary ATGS must be used that
levels before and during the receipt and they must transmits level (inventory) information to a control
be able to manually shut down receipt and fill room system. An independent ATG monitors
operations to the tank. The facility personnel must the product level for a high-high condition and
be in communication with the transporter, who is triggers an alarm, also in the control room. The
also able to terminate receipt. primary inventory measurement device and the
measurement device that triggers high-high level
Although the standard does not require
alarms are recommended to operate in real-time
instrumentation or alarms, Varec recommends a
and to use a different continuous measurement
local tank gauge that provides a tank-side display
principle.
and can also trigger a high-high alarm, such as a
beacon and siren at the tank side. Alternatively, An automatic overfill prevention system (AOPS)
an independent alarm switch could be used to shall be employed that is triggered by either a
monitor the high-high level. high-high condition or failure of the primary ATGS.

Category 2: Semi-Attended Tanks (Diagrams 3 The transporter must also the monitor level and
to 8) An automatic tank gauging system (ATGS) the high-high alarm, and must be capable of
must be used that transmits level and high-high remotely terminating receipt.
alarm information to a control room. The control
room personnel must be capable of shutting down
receipt and fill operations remotely. In addition,
the facility personnel must communicate with
the transporter, who must also monitor the high-
high alarm and be capable of terminating receipt
remotely.
Most ATGSs provide alarm outputs via built-in
software, mechanical limit switches or electronic
relays. These can be used to trigger alarms at
the tank side, in the control room, or at the
transporters control room.
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Varec, Inc. Categorizing Tanks
Consideration for floating roof tanks
It should also be noted that additional
consideration must be given to the selection of
an instrument when gauging product in tanks
that use a floating roof, especially for high-high
sensors. API recommends that a gauge should be
able to detect the actual liquid level in the event of
a floating roof partially sinks, fully sinks, or sticks in
position. In some instances a gauge platform is not
available on a floating roof tank. When this is the
case, an operator is forced to measure the floating
roof position and use an offset (the thickness of the
floating roof) to indirectly measure the liquid level.
When this is the case, the management plan should
account for this offset by increasing response times
and/or reducing the working capacity of the tank.

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Varec, Inc. Categorizing Tanks
 Historic data from a control room system, such as
FuelsManager can assist in the definition of tank
categories, assess response times and estimate risk.

Control Room Systems During Receipt

The API Standard overlooks the benefits an A suitable inventory management system should
inventory management system, such as Varecs provide real-time monitoring and alert operators to
FuelsManager software, can provide a facility abnormal conditions, such as deviations between
operator. Such a system can provide valuable expected product levels and those recorded by the
data for the risk assessment and fulfill direct ATGS. A movement-tracking system should be able
requirements for the API-recommended to track, quantify, and document product transfers,
management system. For example, historic data also in real-time. It should do this for all tanks, not
can be analyzed and used to define levels of just those scheduled to receive product.
concern (LOCs), assess alarm response times, and
After Receipt
assist in process improvement.
Of course, the system should provide detailed
When Planning for Receipt
reports that help record and report inventories,
Inventory reports and estimating features (such as track movements, and identify discrepancies.
FuelsManagers Tank Calculator) can function as
planning tools to ensure adequate safety margins
and tank space (ullage) before, during, and after
receipt, and to estimating fill times. Standard
Microsoft role-based security can assist in the
definition of duties, chain of command responses,
and the assignment of control activities to
designated personnel. If a system is also capable of
combining custom graphics with outputs from field
devices, specific displays could assist an operator
in validating the correct valve lineup to ensure
product is delivered to the correct tank.

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Varec, Inc. Control Room Systems
 Example Solutions
There are many ways for the different tank gauging
technologies to be applied to this standard and to
the individual applications of a particular operator.
The following are examples that can be used as
reference solutions.

Float and Tape Tank Gauge Technology

2557 ALS
Diagram 1

Instrument Defined Alarm Level Sitch

- 6700 Liquid Level Indicator (LLI) Functions Levels of Concern
measures product level Min. Response Transporter
- 2557 Alarm Limit Switch (ALS) with Critical High (CH)
Time (RT) Communicates with
Limit switch 1
(Alarm) on-site operations
two (four optional) normally closed Calculate personnel
switch outputs monitors levels of RT or min. of
45 mins
concern and provides local High-High Limit switch 2 High-High (HH)
(Alarm) Calculate
alarm and alerts (audible and visible) per facility
Maximum
Working (MW)

Valve
Final element remote
shut down

6700 LLI
Local ATG display

Float and Tape Tank Gauge Technology

Diagram 2

Instrument Defined
- 2500 Automatic Tank Gauge (ATG) Functions Levels of Concern
measures product level Min. Response Transporter
- 2557 Alarm Limit Switch (ALS) with Critical High (CH)
Time (RT) Communicates with
Limit switch 1
on-site operations
two (four optional) normally closed (Alarm)
Calculate personnel
switch outputs monitors levels of RT or min. of
45 mins
concern and provides local alerts Independent High-High (HH)
contact switch Calculate
(audible and visible) Alarm
per facility
Limit switch 2 Maximum
- Independent Alarm Switch provides Switch
(Alarm) Working (MW)
Spot sensor
High-High alarm overfill protection overfill
protection

Valve
VAREC

Final element remote

shut down
2500
ATG

General Notes for Category 1 Tanks 2500 ATG/ 2557 ALS

Local ATG display & alarm
- Facility is fully attended level switch
- Able to manually shut down fill operations from input valve and/or transporter
- Manually hand gauge tank 30+ minutes after receipt
- All alarms, alerts and notifications are optional
- Diagrams for illustration purposes only; they do not include ATG system elements, such as on tank
temperature and pressure sensors or logic solver systems, such as PLCs.

Category 1 Tanks Fully Attended Facilities

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Varec, Inc. Example Solutions
Float & Tape Tank Gauge Continuous

Diagram 3
Technology Level via
Comms.
Protocol Instrument Defined
- 2500 Automatic Tank Gauge Functions Levels of Concern
Min. Response Transporter
(ATG) measures product level Time (RT) Communicates with
Limit switch Critical High (CH)
- 8200 Current Output 1 (Alarm)
on-site operations
personnel
Transmitter (COT) provides up Calculate
RT or min. of
to 4 limit switches for local Limit switch High-High (HH)
30 mins
output of High-High alarm 2 (Alarm) Calculate
and other levels of concern Maximum per facility
Working (MW)
- FuelsManager monitors
continuous level via
transmitters 4-20 mA Control
output Room Minimum Valve
Working (Low) VAREC
Final element remote
shut down
2500
ATG

2500 ATG/ 8200 COT

Local ATG display & ATG level
transmission & optional alerts

Servo Tank Gauge Technology Continuous 6005 STG

Diagram 4
Level via Local ATG display & ATG level
Comms.
- 6005 Servo Tank Gauge (STG) Protocol Instrument Defined transmission & optional alerts
measures product level and Functions Levels of Concern
Min. Response Transporter
provides dual overfill Time (RT) Communicates with
OP Relay 1 Critical High (CH)
protection relays for local (Alarm)
on-site operations
Calculate personnel
output of High-High alarm and RT or min. of
other levels of concern OP Relay 2 High-High (HH)
30 mins

- FuelsManager monitors (Alarm) Calculate

continuous level via STG field Maximum per facility
Working (MW)
communications output
(Modbus, Mark/Space, etc.)
Control
Room Minimum Valve
Working (Low) Final element remote
shut down

Radar Tank Gauge Technology

Continuous
Level via

Diagram 5
- 7200 or 7500 series Radar Tank Comms. Instrument Defined
Protocol
Gauge (RTG) measures product Functions Levels of Concern
Min. Response Transporter
level Time (RT)
Relay 1 Critical High (CH) Communicates with
- Dual relays in the 4590 Tank (Alarm) 7200/7500 RTG on-site operations
Side Monitor (TSM) provide Primary Calculate
RT or min. of
personnel
local High-High alarm and measurement 30 mins
Relay 2 High-High (HH) with alarm
Critical High notifications (Alarm) Calculate
- FuelsManager monitors Maximum per facility
continuous level via TSM field Working (MW)

communications output
(Modbus, Mark/Space, etc.) Control
Room Minimum Valve
Working (Low) Final element remote
shut down

4590 TSM
Local ATG display & ATG level
General Notes for Catagory 2 Tanks transmission & optional alerts
- Facility is fully attended
- Able to remotely shut down fill operations from input valve via FuelsManager system
- Control room and transporter maintain frequent communications
- Diagrams for illustration purposes only; they do not include ATG system elements, such as on tank
temperature and pressure sensors or logic solver systems, such as PLCs.

Category 2 Tanks Fully Attended Facilities

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Varec, Inc. Example Solutions
 Float and Tape Tank Gauge Continuous
Technology Level via
Diagram 6

Comms.
Protocol Instrument Defined
- 2500 Automatic Tank Gauge (ATG) Functions Levels of Concern
Min. Response Transporter
measures product level Time (RT) Monitors High-High
Output 1 Critical High (CH)
- 2920 Float & Tape Transmitter (Alarm)
level alarm via
Limit Switch or Output
(FTT) transmits level via field Calculate
RT or min. of
comms. protocol (Modbus, Output 2 High-High (HH) 30 mins
Mark/Space, etc.). The AC (Alarm)
Calculate
version provides four software Output 3 Maximum per facility
(Alert) Working (MW)
outputs while the AC or DC
version provides up to an
additional 4 limit switches Control
- FuelsManager monitors Room Output 4 Minimum Valve
continuous level via FTT field (Alert) Working (Low)
VAREC

+
C
2500
ATG Final element remote
communications output shut down

(Modbus, Mark/Space, etc.) 2500 ATG/ 2920 FTT

- Transporter monitors limit switch Local ATG display & ATG level
transmission & alarms/alerts
output direct from tank gauge for
High-High alarm condition

Servo Tank Gauge Technology Continuous

Level via
6005 STG
Diagram 7

Local ATG display & ATG level

Comms.
- 6005 Servo Tank Gauge (STG) Protocol Instrument Defined transmission & optional alerts
measures product level and Functions Levels of Concern Transporter
Min. Response Monitors High-High
provides four relays for local Time (RT)
Relay 1 Critical High (CH) level alarm via 4-20 mA
output of High-High alarm and (Alarm) Output
other levels of concern Calculate
RT or min. of
- FuelsManager monitors Relay 2 High-High (HH) 30 mins
continuous level via STG field (Alarm)
Calculate
communications output Relay 3 Maximum per facility
(Alert) Working (MW)
(Modbus, Mark/Space, etc.)
- Transporter monitors a separate
4-20 mA output direct from the Control
servo tank gauge for High-High Room Relay 4 Minimum Valve
alarm condition (Alert) Working (Low) Final element remote
shut down

Radar Tank Gauge Technology Continuous

Level via
Diagram 8

Comms.
- FMR50 series or 7500 series Radar Protocol Instrument Defined
Tank Gauge (RTG) measures Functions Levels of Concern
Min. Response Transporter
product level Time (RT) Monitors High-High
Relay 1 Critical High (CH)
- Dual relays in the 4590 Tank Side (Alarm) FMR50/7500 RTG
level alarm via
Calculate Relay
Monitor (TSM) provide local Primary RT or min. of
High-High alarm and Critical High measurement 30 mins
Relay 2 High-High (HH) with alarm
notifications (Alarm) Calculate
- FuelsManager monitors Maximum per facility
Working (MW)
continuous level via TSM field
communications output
(Modbus, Mark/Space, etc.) Control
- Transporter monitors Relay Room Minimum Valve
output direct from the TSM for Working (Low) Final element remote
shut down
High-High alarm condition
4590 TSM
Local ATG display & ATG level
transmission & optional alerts
General Notes for Category 2 Tanks
- Facility is semi-attended
- Able to remotely shut down fill operations from input valve via FuelsManager system
- Control room and transporter maintain communications as agreed
- Diagrams for illustration purposes only; they do not include ATG system elements, such as on tank
temperature and pressure sensors or logic solver systems, such as PLCs.

Category 2 Tanks Semi-Attended Facilities

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Varec, Inc. Example Solutions
Radar/Servo Tank Gauge Continuous Redundant
Technology Level via

Diagram 9
Level via
Comms. 6005 STG
Protocol Instrument Defined
- FMR50 series or 7500 4-20 mA
Functions Levels of Concern
series Radar Tank Gauge (RTG) Transporter
Monitors HH alarm,
measures product level Relay 1 Critical High (CH)
AOPS and primary level
(Alarm) AOPS RT
- 6005 Servo Tank Gauge (STG) AOPS
FMR5x or sufficient Calculate via logic solver
4-20 mA RT or min. of and communicates
measures product level for 7500 RTG for flow
15 mins
termination with control room
Relay 2 High-High (HH) Primary
overfill, provides a 4-20 mA (Alarm) measurement Calculate
output for AOPS activation Relay 3 Maximum per facility
and up to 4 relays for local (Alarm) Working (MW)
output of High-High alarm and
6005 STG
other levels of concern
Control Continuous
- FuelsManager monitors Room overfill
Relay 4 Minimum protection Valve
continuous level via TSM field (Alarm) Working (Low) Final element remote
communications output shut down
(Modbus, Mark/Space, etc.)
4590 TSM
and redundant level via STGs 2nd 4-20 mA Local ATG display & ATG level
output and provides system alarm at deviation transmission ( optional Relay alerts)

Float & Tape/Radar Tank Continuous

Level via

Diagram 10
Gauge Technology Comms. Redundant
Protocol Level via Instrument Defined
- 2500 Automatic Tank Gauge Logic Solver
Functions Levels of Concern
(ATG) measures product level Transporter
Output 1 Critical High (CH)
- 2920 Float & Tape Transmitter Monitors HH alarm,
(Alarm) FMR5x RTG AOPS RT
(FTT) transmits level via field AOPS Continuous sufficient Calculate
RT or min. of
AOPS and primary level
for flow via logic solver
comms. protocol (Modbus, High-High (HH)
overfill termination 15 mins and communicates
Output 2/ protection
Mark/Space, etc.) The AC Overfill RTG Calculate
with control room
version provides four software Output 3 Maximum per facility
outputs while the AC or DC (Alarm) Working (MW)

version provides up to an
additional 4 limit switches Control
- FMR50 series Radar Tank Gauge Room Output 4 Minimum Valve
(RTG) measures for overfill (Alert) Working (Low)
VAREC

Final element remote

+
C

2500
ATG

(AOPS & High-High levels) shut down

- FuelsManager monitors 2500 ATG/ 2920 FTT

continuous level via FTT, redundant level via logic Local ATG display & ATG level
transmission & alarms/alerts
solver (RTG) and provides system alarm at deviation

Servo/Radar Tank Gauge Continuous

Level via

Diagram 11
Technology Comms. Redundant 6005 STG
Protocol Level via Local ATG display & ATG level
- 6005 Servo Tank Gauge (STG) Logic Solver Instrument Defined transmission & optional alerts
Functions Levels of Concern
measures product level for
Transporter
and provides up to 4 relays for Relay 1 Critical High (CH) Monitors HH alarm,
monitoring levels of concern (Alarm) FMR5x RTG AOPS RT AOPS and primary level
sufficient Calculate via logic solver
- FMR50 series Radar Tank Gauge AOPS Continuous
for flow RT or min. of and communicates
overfill 15 mins
(RTG) measures for overfill Overfill High-High (HH)
protection
termination with control room
(AOPS & High-High levels) RTG/Relay 4 Calculate
Maximum per facility
- FuelsManager monitors Relay 2
(Alarm) Working (MW)
continuous level via STG field
communications output
(Modbus, Mark/Space, etc.), Control
redundant level via logic solver Room Relay 3 Minimum Valve
(Alert) Working (Low)
(RTG) and provides system Final element remote
shut down
alarm at deviation

General Notes for Category 3 Tanks

- Facility is unattended
- Remotely shut down fill operations from input valve via FuelsManager system
- Logic solver relays all High-High, AOPS, and primary level states to transporter
- Control room and transporter maintain communications as agreed
- Diagrams for illustration purposes only, they do not include ATG system elements, such as on tank
temperature and pressure sensors or logic solver systems, such as PLCs.

Category 3 Tanks Unattended Facilities

13
Varec, Inc. Example Solutions
 The decision an operator has before them when
addressing API Standard 2350 is how to meet
the measurement, alarm, redundancy and fail
safe requirements through device I/O, systems
capabilities and communications.

Summary
API Standard 2350 does not force an owner or operator to re-invest
capital in expensive instrumentation and systems. To address the
needs of inventory measurement and overfill protection with tank
gauging systems (as defined by API Standard 2350), operators
must clarify their operational and overfill response procedures for
their facility and agree to these with their transporter. They must
also identify the tank category based on their unique operations
which LOCs demand automation for alarms and, if required, how
they will meet the measurement, alarm, redundancy, and fail safe
requirements through existing measurement technologies, device
I/O, systems software, and logic solver capabilities.

14
Varec, Inc. Summary
 API Standard 2350 Worksheet
As noted by API, the capacity of a tank depends on the tank type, size, configuration, construction and
operational parameters. The following worksheets can be used as a guide to help establish various tank
parameters, such as levels of concern, response times and instrument functionality. They are not intended
to replace authorized safety documents contained in an OPP or response management plan.

Tank Information
Facility Contact
Tank Number Prepared by
Location Date

Category Levels of Require Actions Response

Concern and Comments Times (RT)
Critical - ft/inches
High (CH)
- barrels
- mins
AOPS - ft/inches

- barrels
- mins
High - ft/inches
High (HH)
- barrels

Max - ft/inches - mins

Working
- barrels
(MW)

Alarms Alerts LOCs Device

Working Capacity

Critical High (CH)

- ft/inches
AOPS
High High (HH)
- barrels
Max Working (MW)
Min (Low) Working

- ft/inches
Min (Low)
Working - barrels
(LW)

Receipt A. Maximum E. Volume Received

Information Fill Rate - barrels/min (During RT Period) - barrels

(HH to CH) B. Maximum Safety Factor

Determined by
Response Time - mins facility operator
C. Maximum Time to
Achieve Total Shutdown - mins
D. Response F. Volume (E) Adjusted
Time - mins by Safety Factor - barrels

Notes
- B = for facility operator or transporter - D=B+C - Safety Factor includes maximum - B and C may be different durations
to begin to start shutdown or diversion - E = A x D for each simultaneous line measurement error to be determined in response to maximum working as
- C diversion after facility operator or flowing to tank by facility operator compared to High-High.
transporter begins response - F = E x SF - Items A-D shall be calculated for all
simultaneous incoming sources.
 About Varec
Since its founding in 1928, Varec has been a leading innovator
in the petroleum and chemical sectors, delivering automated
systems and professional services for tank farm, terminal and
refinery operators and owners worldwide. Today, Varec provides
completely integrated measurement, control and automation
solutions that are specifically designed to ensure safe storage
and distribution, track product visibility and provide accurate
accounting for the local facility operator to the corporate
enterprise. This includes functionality for overfill prevention,
facility monitoring and release detection.
About API Standard 2350
To obtain a copy of API Standard 2350 please visit:
http://www.publications.api.org
The information presented in this white paper is for informational purposes only and
is made available as a guide only. Varec, Inc. makes no representation, warranty, or
guarantee in connection with this publication and hereby expressly disclaims any
liability or responsibility for loss or damage resulting from its use. Please refer to
the most recent applicable standards published by API, federal, state, or municipal
regulation concerning liquid overfill protection, prevention, and safety in petroleum
storage facilities.

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Document Code : PRO093GVAE0816