COMPLIANCE – STANDARDS & BEST PRACTICES TRACK

MONDAY, JUNE 12 | 2:20 P.M. – 3:15 P.M.

API 2350: What to Expect from the Updated Standard

During 2017, the American Petroleum Institute (API) will release the fifth edition of API
Recommended Practice 2350: Overfill Protection for Storage Tanks in Petroleum Facilities (API
2350) for review and comment by industry stakeholders. Earl Crochet, Kinder Morgan, current
co-Chair of the API 2350 Tank Overfill Committee, will review proposed changes to API 2350
that could impact terminal operations, including updates to the scope, risk assessment and
technology provisions in the existing standard. Crochet will also examine how industry standards
are developed and approved and discuss opportunities for terminal companies to participate in
the process.

ABOUT THE SPEAKER

Earl Crochet is the Director of Engineering and Operational Optimization for Kinder Morgan
Terminals and has almost 29 years of experience in the liquid pipelines and terminals industry.
Previously, he served as General Manager for Kinder Morgan Terminals in the Gulf Region, the
largest liquid terminals complex in North America, and Director of Field Operations for Plantation
Pipe Line, a 3,300 mile products pipeline in 8 southern states. He has been a Certified API 653
Aboveground Storage Tank Inspector since 1993. He has been a member of the API
Subcommittee of Aboveground Storage Tanks (SCAST) since 1994, (including serving as past
Chairman and Vice-Chairman) and currently co-chairs the API 2350 Tank Overfill Committee.
He has also been a member of the API 2611 Facility Piping Committee and the Storage Tank
Task Force. He was a member of the ILTA Board of Directors from 2009-2015 and served as
Chairman of the Board in 2014 and Chairman Emeritus in 2015. Crochet is a registered
Professional Engineer in three states and earned a Bachelor of Science degree in Mechanical
Engineering and a Master of Business Administration, both from Louisiana State University.
API 2350: What May Be Expected
in the Updated Standard

Earl J. Crochet, P.E.

Kinder Morgan Terminals
 Disclaimer
• The views, opinions, and conclusions
expressed today are those of the
presenter and do not necessarily reflect
those of the International Liquid Terminals
Association, American Petroleum Institute
or Kinder Morgan Inc. and its related
companies.
 Who exactly is Kinder Morgan?
• KM Natural Gas
• KM Liquid Pipelines
• KM CO2
• KM Canada
• KM Terminals
Kinder Morgan System Map: www.kindermorgan.com
First, a few things you need to know about me…
• I am passionate (and talk a lot) about my
wife and family.
• I am fanatical (and talk a lot) about LSU,
especially FOOTBALL.
– (Only 82 more days until kickoff!!!)
• I have strong opinions about many things,
including the energy industry.
• (I am more than willing to share those
opinions; just ask me later.)
So, where are we going?
 What are we going to talk about?
• Brief explanation of how the API
Standards process works
• Talk about some of the major changes of
the current (4th Edition) from the previous
(3rd Edition) of API 2350.
• Discuss the status of the future (5th
Edition) of API 2350
– Some parts that might (I repeat might) change
– Some parts that won’t change
• Answer any questions I can
 API Standards Creation 101
• (Or everything you always wanted to know
about creating API Standards but were
afraid to ask!)
 API Standards Creation 101
• From the API Procedures for Standards
Development:
• 5.2.1 Openness
• Participation in API standards activities is
open to all parties (persons and
organizations) that have a direct and material
interest in the subject of a standard.
Consideration shall be given to the written
views and objections of all participants and
the right to appeal shall be made available to
adversely affected parties (see 5.8).
 API Standards Creation 101
• 5.2.2 Balance
• 5.2.2.1 Overview
• API seeks broad input to its standardization activities
including the participation of all parties representing interest
categories appropriate to the nature of the standard, and
allows for open attendance at standards meetings (see
5.10.1). API strives for balanced representation (for example,
targeting one-third representation for the traditional model of
the three interest categories of operator-user, manufacturer-
service supplier, and general interest) in an effort to avoid a
majority of any one interest category. The criteria for balance
are that a) no single interest category constitutes more than
one-third of the membership of a consensus body dealing with
safety-related standards or b) no single interest category
constitutes a majority of the membership of a consensus body
dealing with other than safety-related standards.
 API Standards Creation 101
• 5.2.2.2 Interest Categories
• In defining the interest categories appropriate to API
standards activities, consideration shall be given to at least
the following.
• a) Operator-User—the entity that is using the product
specified in the standard or performing the operations or
practices described in the standard.
• b) Manufacturer-Service Supplier—the entity that is
fabricating a product specified in the standard or used in
performing the operations or practices described in the
standard or the entity that is providing a service in compliance
with the standard.
• c) General Interest—an entity that is neither of the above but
has a direct and material interest in the product, operation, or
practice described in the standard. Typically this category
includes consultants.
 API Standards Creation 101
• Other interest categories such as the
following may be established within a
standards committee in order to insure
adequate levels of representation.
• d) Government—Federal, state, or other
regional regulatory body.
• e) Academia—College or university-affiliated
expert.
• f) Association—Professional society or non-
governmental authority.
• g) Non-Governmental Organization (NGO)—
Labor, consumer interest.
 API Standards Creation 101
• 5.2.3 Consensus
• API develops industry standards on the basis of
consensus. Consensus is established when
substantial agreement has been reached by
directly and materially affected interests.
Substantial agreement means more than a simple
majority but not necessarily unanimity. Consensus
requires that all views and objections be
considered, and that an effort be made toward
their resolution. For purposes of these
Procedures, consensus shall be defined as a
majority of those eligible to vote shall have voted
and approval by at least two-thirds of those
voting, excluding abstentions.
 API Standards Creation 101
• 5.5 Membership on Standards Committees
• Membership on standards committees is open to all parties having a direct
and material interest. Members shall be able to fully participate in the
standards committee activities, and shall be capable of providing technical
contributions or subject matter expertise; however, participation shall not be
unreasonably restricted on the basis of technical qualifications. Membership
in API is not a requirement for membership on standards developing
committees; however, membership in API is required for membership on
standards policy committees.
• Assignment of voting or non-voting status on a consensus body is
determined by the chairman in consultation with API staff. All directly and
materially affected parties in the subject of a standard shall be assigned a
vote (with one vote per company: see 5.6.5.1), unless a party elects to be a
non-voting member of the consensus body or adding a new voting member
would cause the consensus body to become unbalanced (5.2.2).
• All voting members shall be active participants in standards committee
activities: removal of voting rights from consensus body members may be
employed in accordance with individual committee procedures. Criteria for
removal should include failure to regularly participate in meetings and to
return letter ballots.
 API Standards Creation 101
• 5.6.4 Ballot Format
• A ballot shall concisely state the proposed action
being balloted. All ballots shall provide for four
voting options:
• a) Affirmative;
• b) Affirmative with comment;
• c) Negative with reasons;
• d) Abstain;
• Negative votes are required to be accompanied by
comments related to the proposal and votes
unaccompanied by such comments will be
recorded as “invalid negatives” without further
notice to the voter.
 API Standards Creation 101
• 5.6.6 Ballot Approval
• For a proposed ballot action to be considered
approved, all comments shall be considered
and in accordance with 5.2.3, both of the
following conditions shall be satisfied:
• a) a majority of the members who are eligible
to vote shall have voted; and
• b) at least two-thirds of the combined valid
affirmative and valid negative votes
(excluding abstentions) shall be affirmative.
 API Standards Creation 101
• For more details:
• http://mycommittees.api.org/standards/Ref
erence/API%20Procedures%20for%20Sta
ndards%20Development-2016.pdf
 API 2350 4th Edition – How we got here
• 3rd edition published January 2005
• Current (4th) edition published May 2012
• Changed Overfill to Critical High (CH)
• Changed Safe Fill to High-High (HH)
• Changed Normal Fill to Maximum Working
(MW)
 API 2350 3rd vs. 4th Edition
• Main body was only 10 pages in 3rd; 30
pages in 4th
• 3 appendixes in 3rd; 5 in 4th
• Changed from 4 levels (Overfill, Safe Fill,
Hi, Normal Fill) in 3rd to 3 levels (Critical
High, High-High, Maximum Working) in 4th
• Introduced Tank Categories 1-3 in 4th
Where is the 5th Edition headed?
 Possible changes to 5th edition
• May add Category 0 – Tanks with no
gauges
• May delete Management system
• May allow wireless for AOPS
• Expands on risk assessments
• May remove 15/30/45 base case timelines
 5th Edition is still being “debated”
• First face to face meeting held in Houston
August 2016
• Second face to face also held in Houston
March 2017
• First draft version went out for comments
from committee members this Spring
• 319 comments received!
• Another face to face planned later this
year, probably in Houston