Assessment as to whether a Baseline Report, in accordance with the requirements of section 86B of the EPA Act 1992 as amended, is required.

Transcription

1 Bray (Ireland) Cork (Ireland) Lisburn (N. Ireland) Birmingham (GB) Assessment as to whether a Baseline Report, in accordance with the requirements of section 86B of the EPA Act 1992 as amended, is required. For IED P Document Number v energy@enviro-consult.com Registered Office: Parnell House, 19 Quinsboro Road, Bray, Co. Wicklow A98 XV04. Registered Number Directors: Robert B. Sutcliffe, Ronan T. Sutcliffe Environmental Services for Industry Including Air, Noise & Water Monitoring Energy & Water use reduction Bund Testing IPC/IED/Waste Licence Compliance Environmental Management Systems to ISO EIS & Planning Air & Noise Modelling Occupational Dust & Noise Affiliations & Accreditations ISO9001:2008 Registration No. 2015/2170 ISO14001:2004 Registration No. 2012/1427 MCERTS Certified personnel for stack testing Member of Royal Society for Prevention of Accidents EMPI Membership

2 Project Start Form Task Task (summary) BATC Review Work charged on an hourly basis Order logged by RBS Date Jan 2017 Proj Manager RD Target hours Not defined MS required? No Analysis cost, 0 Involves lab? No Hire costs, 0 Site visit required? Yes Fee (specify or ) 70/hr UIK N/A as periodic invoicing Date invoiced End of month VAT Rate 23% Contact address Fermoy Client phone Client dobrien@micro Bio.ie PO covers Choose an item Document Lead Sheet Organisation Micro Bio Site Fermoy Permit/Lic No. (if applic) P Client contact Denis O'Brien Client Action Approval & Issue Deliverable Order Description of task BATC Review Work Proposal number 4863 Client PO PO Invoice on Periodic basis Report title BATC Review Document number Report template Standard Report template Type of document Report Method Statement N/A Format for issue PDF Site visit by RD Date last site visit 01/02/2017 Document author RD Date written 27/02/2017 Approved by RBS Date approved 27/02/2017 Report version nr 1.01 Issued by RD Date report issued 27/02/2017 Doc issued to As per client info Method issue All results satisfactory If not satisfactory, further testing required If satisfactory, when is next test due? N/A N/A N/A Key to personnel RBS Bob Sutcliffe, Director, CEng, MIMechE, MIEI,CEM RTS Ronan Sutcliffe, Director, Dip. Environmental Protection GB George Byrne, MSc Biosystems Engineering RD Richard Deeney, B.Sc. AIEMA JC John Cullen, BAgSc, P.Grad.Dip Environmental Engineering VB Valerie Browne, BSc Environmental and Earth System Science Conditions relating to the issue of this report: 1. No alteration to this report by third parties is permitted 2. Where this report is reproduced, it shall only be reproduced in full. 3. Reports remain the property of Environmental & Efficiency Consultants (Ireland) Limited until paid for in full. Report History 1.00 Issued 1.01 Report amended considering reviewer feedback on risk level definitions Document No.: v1.01 Page 2 of 25

3 Table of Contents 1. INTRODUCTION PURPOSE SCOPE BACKGROUND/CONTEXT METHODOLOGY METHOD ASSESSING THE NEED FOR A BASELINE REPORT STAGE 1: HAZARDOUS SUBSTANCES USED, PRODUCED OR RELEASED AT MICRO BIO IRELAND FERMOY STAGE 2: DETERMINATION OF RELEVANT HAZARDOUS SUBSTANCES STAGE 3: ASSESSING SITE SPECIFIC POLLUTION POTENTIAL Assessment of Relevant Hazardous Substances Scenarios in which Emissions to GW and/or Soil may occur Risk Assessment to Determine Pollution Risk Risk Evaluation CONCLUSIONS RECOMMENDATIONS TABLE OF TABLES TABLE 3-1 HAZARDOUS MATERIALS PRESENT ON-SITE... 6 TABLE 3-2 DETERMINATION OF RELEVANT HAZARDOUS SUBSTANCES... 8 TABLE 3-3 RISK ASSESSMENT OF SCENARIOS IN WHICH EMISSIONS TO GW AND/OR SOIL MAY OCCUR TABLE 3-4 RISK COLOUR CODES TABLE 3-5 RISK ASSESSMENT TO DETERMINE POLLUTION RISK TABLE 3-6 RISK EVALUATION TABLE OF APPENDICES APPENDIX 1 SITE LAYOUT PLAN APPENDIX 2 RISK LEVEL DEFINITION Document No.: v1.01 Page 3 of 25

4 1. Introduction 1.1 Purpose The purpose of this assessment is to determine whether a Baseline Report, in accordance with the requirements of section 86B of the EPA Act 1992 as amended, is required. 1.2 Scope Micro Bio s Chlor-Alkali manufacturing installation in Fermoy Industrial Estate, Fermoy, Co. Cork and activities which take place there are considered under the scope of this assessment. 1.3 Background/Context The EPA have initiated a Review of Micro Bio s existing IED licence (P ). This review is for the purposes of updating their licence to ensure compliance with the requirements of the European Commission decision on BAT conclusions applicable to Micro Bio s installation (Commissions Implementing Decision 2013/732/EU). For the purposes of the review, the reference number in the EPA s Register of Licences is P As part of the Review, Micro Bio are required to complete an Industrial Emissions Licensing: Section 90(1)(aa) Review Form. Section D.2 of this form requires that Micro Bio undertake an assessment as to whether a Baseline Report, in accordance with the requirements of section 86B of the EPA Act 1992 as amended, is required. A full Baseline Report should report on the following: a) Information on the present use and, where available, on past uses of the site; and; b) Where available, existing information on soil and groundwater measurements that reflect the state at the time the report is drawn up or, alternatively, new soil and groundwater measurements having regard to the possibility of soil and groundwater contamination by those hazardous substances to be used, produced or released by the installation concerned. This document details the assessment which took place to achieve the objective of determining whether a full Baseline Report is required in this instance. Document No.: v1.01 Page 4 of 25

5 2. Methodology 2.1 Method This assessment took place in accordance with the European Commission Guidance concerning Baseline Reports under Article 22(2) of Directive 2010/75/EU on industrial emissions. Eight stages have been identified in this process. Stages 1-3 are completed to decide whether a Baseline Report is required. Where during stages 1-3 it is demonstrated on the basis of the available information that a Baseline Report is not required, there is no need to progress to the later stages. If a Baseline Report is required stages 4-8 are then completed to product a full Baseline Report. As stated, this document details the assessment to determine whether a Baseline Report is required (i.e. stages 1-3 of the relevant guidance). Stages 1-3 to determine the requirement for a full Baseline Report, as defined by the relevant guidance, are detailed below: Stage Activity Objective 1 Identify which hazardous substances are used, produced or Determine whether or not released at the installation and produce a list of these hazardous substances are hazardous substances. used, produced or released in view of deciding on the need to prepare and submit a Baseline Report. 2 Identify which of the hazardous substances from Stage 1 are relevant hazardous substances (see Section 4.2). Discard those hazardous substances that are incapable of contaminating soil or groundwater. Justify and record the decisions taken to exclude certain hazardous substances 3 For each relevant hazardous substance brought forward from Stage 2, identify the actual possibility for soil or groundwater contamination at the site of the installation, including the probability of releases and their consequences, and taking particular account of: the quantities of each hazardous substance or groups of similar hazardous substances concerned; how and where hazardous substances are stored, used and to be transported around the installation; where they pose a risk to be released; In case of existing installations also the measures that have been adopted to ensure that it is impossible in practice that contamination of soil or groundwater takes place. To restrict further consideration to only the relevant hazardous substances in view of deciding on the need to prepare and submit a Baseline Report. To identify which of the relevant hazardous substances represent a potential pollution risk at the site based on the likelihood of releases of such substances occurring. For these substances, information must be included in the Baseline Report. A site audit took place on 01/02/2017 for the purposes of informing the stages to determine the need for a Baseline Report to be completed. The audit involved assessing (i) hazardous materials storage and management on-site (ii) environmental management practices on-site and (iii) the site specific pollution possibility. A follow up desk based review of data and information pertaining to the site and the local environment (with reference to publically available data) then took place. Document No.: v1.01 Page 5 of 25

6 3. Assessing the Need for a Baseline Report 3.1 Stage 1: Hazardous Substances Used, Produced or Released at Fermoy The following materials classified as hazardous in accordance with the 'CLP' Regulation (EC) No 1272/2008 are stored/used/produced on-site: Table 3-1 Hazardous Materials Present On-site Hazardous Location On-site Form Nature of Use CAS# EC# H Phrases Hazard Symbol Max Capacity Material (tonne) Hydrochloric acid HCl tank farm Liquid Product H314, H335, H290 Corrosive, irritant 2,000 Sodium Hydroxide Caustic Tank Farm Liquid Product H314, H290 Corrosive 2,000 Sodium Hypo Tank Liquid Product H290, H314, Corrosive, Irritant, 100 Hypochlorite Farm H318, H335, H400 Dangerous to the Environment Potassium Bulk Tank Liquid Product H290, H302, H414 Corrosive, Irritant 200 Hydroxide Sulphuric Acid Bulk Tank Liquid Product H314 Corrosive 50 (B7) Phosphoric Acid Warehouse Liquid Product H314 Corrosive 2 (building 4) Nitric Acid Warehouse Liquid Product H272, H314 Flammable, 2 Chlorine gas Hydrogen gas Nitrogen gas Hydrogen Chloride (building 4) Process Area Process Area Process Area Vents at A2-1 and A2-2 Gas Converted to Product / Emission to Air H270, H330, H319, H335, H315, H400 Corrosive, Toxic Corrosive, Dangerous to the Environment, Oxidizer, Toxic Gas Converted to H220, H280 Fire hazard, Product Compressed Gas Gas Purging H280, H281 Compressed Gas 10 Gas Emission to Air H335, H314, H331, H290, H318, H281, Corrosive, Toxic, Harmful by Inhalation, not stored it is vented Document No.: v1.01 Page 6 of 25

7 Hazardous Material Oil heating) (central Fuel Oil (on-site vehicles) Lab Chemicals N/K Not Known Location On-site Form Nature of Use CAS# EC# H Phrases Hazard Symbol Max Capacity (tonne) H280, H302, Serious Health H311, H330. Hazard H315, H332, H314 Compressed Gas Oil Tank in 1.5 m 3 Building 5 Diesel adjacent Building 1 tank to Central lab and Process lab Liquid Fuel H304, H226, H315, H411, H336, H412, H335 Liquid Fuel H226, H304, H315, H332, H351, H373, H411 Flammable, Irritant, Dangerous to the Environment, Serious Health Hazard Flammable, Dangerous to the Environment, Harmful by Inhalation, Irritant Liquid Waste reagents Various Various Various Various <20 litres 2.5 m 3 Document No.: v1.01 Page 7 of 25

8 3.2 Stage 2: Determination of Relevant Hazardous Substances An assessment took place to determine which hazardous substances present on-site, considering their hazardousness, mobility, persistence and biodegradability (as well as other characteristics), are capable of contaminating soil or groundwater and are therefore relevant to this assessment. This assessment referred to information from material Safety data Sheets for the products and from the European Chemicals Agency C&L Inventory The table below details a summary of this assessment for each hazardous substance present on-site and includes justifications as to why each substance has been deemed relevant or not. Table 3-2 Determination of Relevant Hazardous Substances Hazardous Material Relevant? i.e. Why/ Why Not? Capable of Polluting Groundwater and/or Soil Hydrochloric acid Yes Large discharges may contribute to the acidification of water and may be fatal to aquatic and plant life. This substance has considerable solubility and mobility in soil/sediment and water. Sodium Hydroxide Yes Large discharges may contribute to the acidification of water and may be fatal to aquatic and plant life. This substance has considerable solubility and mobility in soil/sediment and water. Sodium Hypochlorite Yes Toxic effect linked with corrosive properties. Considerable solubility and mobility. Highly mobile in soils/sediment. Potassium Hydroxide Yes Toxic effect linked with corrosive properties. Low potential for absorption in soil however soluble in water and considered a groundwater pollutant. Sulphuric Acid Yes Toxic effect linked with strongly corrosive properties. Large discharges may contribute to the acidification of water and may be fatal to aquatic and plant life. Miscible in water. Forms corrosive mixtures with water even when diluted. Reduces ph and may endanger drinking water supplies. High mobility in soil and sediments. Phosphoric Acid Yes Toxic effect linked with strongly corrosive properties Nitric Acid Yes Toxic effect linked with strongly corrosive properties Chlorine gas No This substance does not pose a risk to groundwater or soil as it is stored in gaseous form. Hydrogen gas No This substance does not pose a risk to groundwater or soil as it is stored in gaseous form. Nitrogen gas No This substance does not pose a risk to groundwater or soil as it is stored in gaseous form. Hydrogen Chloride No This substance does not pose a risk to groundwater or soil as it is stored in gaseous form. Oil (central heating) Yes This product is dangerous to the environment and may have a deleterious effect on organisms if released. Fuel Oil (on-site Yes This products are dangerous to the environment and may have a vehicles) deleterious effect on organisms if released. Lab Chemicals Yes Lab chemicals on-site have various hazardous properties and are often dangerous to the environment and deleterious to organisms. Document No.: v1.01 Page 8 of 25

9 3.3 Stage 3: Assessing Site Specific Pollution Potential The following has taken place to determine the site specific pollution risk associated with each relevant hazardous substance: 1. An assessment of each relevant hazardous substance considering the following: a. The quantity of each hazardous substance handled, produced or emitted in relation to its environmental effect. b. The location of each hazardous substance on the site e.g. where it is or will be delivered, stored, used, moved around the site and/or emitted c. The method of storage, handling and use of each relevant hazardous substance and how the substance is controlled on-site. d. An assessment of the presence and integrity of containment mechanisms, nature and condition of site surfacing, location of drains, services or other potential conduits for migration. 2. Identification of the scenarios which releases to the environment may occur 3. A Risk Assessment to determine the likelihood of a significant release of a relevant hazardous substance to soil and/or groundwater Assessment of Relevant Hazardous Substances The Site Layout Plan (pdf version) shown in Appendix 1 should be referred to when reviewing this Section: Hydrochloric Acid Micro Bio operates a membrane cell electrolysis plant to produce the inorganic chemical Hydrochloric Acid (HCl). The electrolysis process produces hydrogen gas, chlorine gas and sodium hydroxide. The hydrogen and chlorine are burnt and scrubbed into water to produce the hydrochloric acid. HCl is stored on-site within the bulk storage tanks, NB8, NB9, NB11 & NB12, with a maximum site capacity of 2,000 tonnes. The HCl tanks are positioned within bunded tank farms in an area to the centre of the facility. HCl is piped into the containment tanks directly from the processing area. To minimize the potential for a release to the environment the HCl storage tanks undergo ultrasonic testing every 4 years and are stored within a secondary containment bund. These bunds are integrity tested every three years and were last tested in November 2016, where all bunds passed. Gas monitoring for HCl takes place around the HCl tanks to detect the presence of any HCl leaks and to ensure a prompt response to any leaks. Dedicated, contained filling areas for bulk tankers and non bulk (5lit 1000lit containers) are provided. A road tanker loading procedure is in place to minimize releases during transfer of materials from storage tanks to road tankers for dispatch off-site to customers. Deliveries are a high frequency event and subject to SOP and supervision. Safety valve systems are situated on all bulk storage tanks. Any spillages will be diverted via the site drainage system to the WWTP which has 150 m3 spare capacity which can be used for secondary retention. There are no planned emissions of HCl to soil or waters. There has been no recorded incident causing a release of this substance to the environment in the past. Document No.: v1.01 Page 9 of 25

10 Sodium Hydroxide Micro Bio operates a membrane cell electrolysis plant to produce the inorganic chemical Sodium Hydroxide (NaOH). NaOH solutions produced are piped into a containment tank NB13 from the processing area. This containment tank is situated in bunded locations in the centre of the site. All tanks undergo daily visual inspection.these bunded areas are periodically integrity tested. A maximum of 2,000 tonnes of sodium hydroxide can be stored on-site. Dedicated, contained filling areas for bulk tankers and non bulk, a tanker loading SOP, safety valve systems and spill containment in the WWTP are provided to control tanker loading operations and minimize the potential for an environmental release of NaOH There are no planned emissions of NaOH to soil or waters. There has been no recorded incident causing a release of this substance to the environment in the past Sodium Hypochlorite Sodium Hypochlorite (NaClO) is a final product from the manufacturing process on site. NaClO is stored within bulk storage tanks, with a maximum site capacity of 100 tonnes. NaClO is piped directly from the process area to the storage tanks. Storage tanks are contained in bunded locations at the centre of the site, adjacent to Building 1. All tanks undergo daily visual inspection. These bunded areas are periodically integrity tested. Dedicated, contained filling areas for bulk tankers and non bulk, a tanker loading SOP, safety valve systems and spill containment in the WWTP are provided to control tanker loading operations and minimize the potential for an environmental release of NaClO. No systematic discharge of Sodium Hypochlorite to water occurs, any Sodium Hypochlorite generated is collected and sold as product. Sodium Hypochlorite which may enter the Wastewater Treatment plant is chemically dechlorinated prior to discharge. There are no planned emissions of NaClO to soil or waters. There has been no recorded incident causing a release of this substance to the environment in the past Potassium Hydroxide The company also trades in Potassium hydroxide (KOH) liquor. KOH is stored within bulk tanks on site, with a maximum capacity on site of 100 tonnes. KOH tanks are bunded and located within the hard-standing concrete yard area. A maximum of 200 tonnes of KOH can be stored on-site at any one time. As well as this KOH is used in the formulation process on-site. Formulation processes take place in Building 2 on-site. KOH is stored on-site in tanks which are situated in bunded locations. These bunds are periodically integrity tested. All tanks undergo daily visual inspection. Dedicated, contained filling areas for bulk tankers and non bulk, a tanker loading SOP, safety valve systems and spill containment in the WWTP are provided to control tanker loading operations and minimize the potential for an environmental release of KOH. There are no planned emissions of KOH to soil or waters. There has been no recorded incident causing a release of this substance to the environment in the past. Document No.: v1.01 Page 10 of 25

11 Sulphuric Acid The company also trades in solutions of Sulphuric Acid (H2SO4). H2SO4 is brought onto site in bulk format and stored within a bulk tank, maximum holding capacity on site is 50 tonnes. H2SO4 material is reformulated to lesser concentrations by addition of de-ionised water, or re-packaged into smaller volume containers, depending upon customer requirements. H2SO4 is stored on-site in a bulk tank. This tank undergoes daily visual inspections and is situated in a bunded area which is periodically integrity tested. Dedicated, contained filling areas for bulk tankers and non bulk, a tanker loading SOP, safety valve systems and spill containment in the WWTP are provided to control tanker loading operations and minimize the potential for an environmental release of H2SO4. There are no planned emissions of H2SO4 to soil or waters. There has been no recorded incident causing a release of this substance to the environment in the past Phosphoric Acid Phosphoric Acid (H 3PO 4) is used in the formulation process on-site. Phosphoric acid containers are brought on-site and stored in secondary retention sump pallets in Building 4, the maximum storage capacity being 2 tonnes. These sump pallets are integrity tested every three years. Formulation processes take place in Building 2 on-site. Phosphoric acid containers are transported from Building 4 to Building 2 for formulation via forklift by trained forklift operators. The formulation process takes place in bunded areas. Any release or accidental spill of Phosphoric Acid will be captured by secondary containment, or, where the secondary containment system fails, will be captured by the site drainage system and directed towards the WWTP. There are no planned emissions of H 3PO 4 to soil or waters. There has been no recorded incident causing a release of this substance to the environment in the past Nitric Acid Micro Bio trade in Nitric Acid (HNO 3). In addition it is utilized in the formulation process onsite. Nitric acid containers are brought on-site and stored in secondary retention sump pallets in Building 4, the maximum storage capacity being 2 tonnes. These sump pallets are integrity tested every three years. Formulation processes take place in Building 2 on-site. Nitric acid containers are transported from Building 4 to Building 2 for formulation via forklift by trained forklift operators. The formulation process takes place in bunded areas. Any release or accidental spill of Nitric Acid will be captured by secondary containment, or, where the secondary containment system fails, will be captured by the site drainage system and directed towards the WWTP. There are no planned emissions of HNO 3 to soil or waters. There has been no recorded incident causing a release of this substance to the environment in the past. Document No.: v1.01 Page 11 of 25

12 Oil (central heating) Heating oil is stored in a self bunded oil tank situated in Building 5 on-site. This oil tank is domestic in size (<1,200 litres). It is used in a boiler situated in the boiler house in Building 1. Spill kits and SOP s for fuel delivery and loading are in place. Fuel delivery is inspected by personnel whenever it occurs. All storage tanks on site are within the process zone, and are drained towards the onsite WWTP, with a 150 m3 excess capacity for emergency use. The WWTP outlet can also be stopped in the event of a fuel leak to the system and hold the liquid until such time as it can be safely removed. There has been no recorded incident causing a release of oils to the environment in the past Fuel Oil Diesel for fork-lifts and the loading shovels used to transport materials on-site is stored in a self-bunded oil tank situated in another concrete bund adjacent to Building 3 and Building 1. Spill kits and SOP s for fuel delivery and loading are in place. Fuel delivery is inspected by personnel whenever it occurs. Fuel is filled via a triggered hose which can limit the quantity of any accidental discharges. All storage tanks on site are within the process zone, and are drained towards the onsite WWTP, with a 150 m3 excess capacity for emergency use. The WWTP outlet can also be stopped in the event of a fuel leak to the system and hold the liquid until such time as it can be safely removed. There has been no recorded incident causing a release of oils to the environment in the past Lab Chemicals A small volume of lab chemicals are stored on-site in the Central lab in Building 1 and in the Process Lab in Building 3. Lab chemicals are stored in accordance with their MSDS s and are disposed of via an appropriately authorized hazardous waste contractor. Main office building and laboratory areas are constantly manned during operational day. There has been no recorded incident causing a release of lab chemicals to the environment in the past. Document No.: v1.01 Page 12 of 25

13 3.3.2 Scenarios in which Emissions to GW and/or Soil may occur Scenarios in which Emission of relevant hazardous substances to GW/Soil may occur are detailed in Table 3-3 overleaf. Circumstances under which emissions may occur include the following: Accidents/Incidents e.g. tanker overturning on site road; vessel rupturing; leaking underground tank; seal breaking; accidental discharge; leaks from drain ruptures; fire; Routine operations e.g. drips during delivery or from pipe joints, small spills during decanting/transfer of product, leaks from blocked or broken drains, cracks in concrete hard-standing; Planned emissions e.g. discharges to land or groundwater. Document No.: v1.01 Page 13 of 25

14 Table 3-3 Risk Assessment of Scenarios in which Emissions to GW and/or Soil may occur Risk ID Process Risk Scenario Circumstances which Relevant Hazardous emissions may occur Substance 1 Fuel Storage Loss from tanks/ Accident/Incident Heating oil and Fuel oil pipelines/ unloading/ delivery, groundwater and/or soil contamination 2 Bulk Storage and Spillage during Tanker Accident/Incident Aqueous chemicals 1 Handling (aqueous loading operations chemicals) 3 Bulk Storage and Loss from bulk storage Accident/Incident Aqueous chemicals 1 Handling (aqueous tanks/pipelines chemicals) 4 Bulk Storage and Catastrophic loss from Accident/Incident Aqueous chemicals 1 Handling (aqueous bulk storage tanks/ chemicals) pipelines, and bund fracture resulting in loss of chemicals across site and into the WWTP 5 Underground drainage Potential Routine Operations Aqueous chemicals 1 network leaks/cracks in underground pipework resulting in pathway for contamination 6 Secondary Bunding Possible migration of Routine Operations Aqueous chemicals 1 (Concrete Hardstanding) contaminants 7 Production Process explosion Accident/Incident Aqueous chemicals 1 leading to discharges to water and/or soil resulting in unscheduled or shock load discharge from production disrupting treatment process 8 Production Spillages from Accident/Incident Aqueous chemicals 1 production, through cells not connected securely to pipes 9 Wastewater treatment Gradual losses through Routine Operations Aqueous chemicals 1 plant WWTP fractures/cracks in tanks and pipelines 10 Fire Fire-emissions to air, Accident/Incident Aqueous chemicals 1 firewater discharge to WWTP, surface water or groundwater 11 Traffic Loss to environment Aqueous chemicals 1 due to incidents involving vehicles (forklifts, trucks, etc) 1 Aqueous chemicals refer to chemicals stored and/or transferred onsite in significant quantities. The following is an exhaustive list of such chemicals: Hydrochloric Acid, Sodium Hydroxide, Sodium Hypochlorite, Potassium Hydroxide, Sulphuric Acid, Phosphoric Acid, Nitric Acid and lab chemicals (various). Document No.: v1.01 Page 14 of 25

15 3.3.3 Risk Assessment to Determine Pollution Risk A Risk Assessment to determine the pollution risk associated with each scenario has taken place and is detailed in Table 3 5 below. Information from Section was referred to when completing the Risk Assessment. For each hazard, the likelihood of occurrence and severity is assessed and the significance for the risk is assigned by way of a risk level. The definitions for the risk levels are contained in Appendix 2. An overall risk score is determined by multiplication of the occurrence score by the severity score. The resultant score is then displayed in a risk matrix as presented below. Figure 1 Risk Matrix The colours provide a broad indication of the critical nature of each risk, and are defined as follows: Table 3-4 Risk Colour Codes Colour Red Yellow Green (Dark and Light) Description These are considered to be high-level risks requiring priority attention. These risks have the potential to be catastrophic and as such should be addressed quickly. These are medium-level risks requiring action, but are not as critical as a red coded risk. A These are lowest-level risks and indicate a need for continuing awareness and monitoring on a regular basis. Whilst they are currently low or minor risks, some have the potential to increase to medium or even high level risks and must therefore be regularly monitored and if cost effective mitigation can be carried out to reduce the risk even further this should be pursued. If all risks are scored in the Green category a full Baseline Report is not required as there is no significant possibility for contamination of soil or groundwater. If any risk is scored in the Red or Yellow categories it is recommended mitigation measures are implemented to reduce risk and a full Baseline Report is required as there is a significant possibility for contamination of soil or groundwater. Document No.: v1.01 Page 15 of 25

16 Table 3-5 Risk Assessment to Determine Pollution Risk Risk ID Process Risk Scenario Severity 1 Fuel Storage Loss from tanks or during delivery/unloading 2 Bulk Storage and Handling (aqueous chemicals) Spillage during Tanker loading operations Basis of Severity 3 Fuel stored only in moderate quantities (i.e. one domestic sized diesel storage tank and a number of oil 205 l drums). Control measures in place to prevent and minimize any release of material (secondary and tertiary retention, spill kits, SOP for fuel delivery). Potential for moderate impact in the event of a release of material to the yard area and penetration of a small amount of material through deteriorated / cracked parts of the yard. Negligible risk of large scale release causing major impacts. 3 Bulk quantities of aqueous chemicals stored on-site in primary vessels (tanks, IBC s and drums) and contained in road tankers. Control measures in place to prevent and minimize any release of material during tanker loading activities Occurrence Basis of Occurrence Risk Score (Severity X Occurrence) 6 2 Numerous administrative and engineering controls in place to prevent loss of containment and subsequent release to the environment therefore ensuring very low risk of material being released to the surrounding environment. 2 Numerous administrative and engineering controls in place to prevent loss of containment and subsequent release to the environment therefore ensuring very low risk of material being released to the surrounding environment. 6 Document No.: v1.01 Page 16 of 25

17 Risk ID Process Risk Scenario Severity Basis of Severity (Dedicated filling areas, secondary and tertiary retention, tanker loading SOP, safety valve systems). Occurrence Basis of Occurrence Risk Score (Severity X Occurrence) 3 Bulk Storage and Handling (aqueous chemicals) Loss from bulk storage tanks/pipelines Potential for moderate impact in the event of a release of material to the yard area and penetration of a small amount of material through deteriorated/cracked parts of the yard. Negligible risk of significant release causing major impacts. 3 Bulk quantities of aqueous chemicals stored on-site in primary vessels (tanks, IBC s and drums). Control measures in place to prevent and minimize any release of material stored in bulk quantities (secondary and tertiary retention, periodic tank and bund integrity testing, gas monitoring for substances of concern, ERP on-site). 2 Numerous administrative and engineering controls in place to prevent loss of containment and subsequent release to the environment therefore ensuring very low risk of material being released to the surrounding environment. 6 Potential for moderate impact in the event of a release of material to the yard area and penetration of Document No.: v1.01 Page 17 of 25

18 Risk ID Process Risk Scenario Severity 4 Bulk Storage and Handling (aqueous chemicals) Catastrophic loss from bulk storage tanks/ pipelines, and bund fracture resulting in loss of chemicals across site and into the WWTP Basis of Severity a small amount of material through deteriorated/cracked parts of the yard. Negligible risk of significant release causing major impacts. 4 Bulk quantities of aqueous chemicals stored on-site in large primary vessel. Control measures in place to prevent and minimize any release of material stored in bulk quantities (secondary and tertiary retention, periodic tank and bund integrity testing, gas monitoring for substances of concern, ERP on-site). Potential for major impact in the event of failure of all controls and release of large volume of material to the site. Occurrence Basis of Occurrence Risk Score (Severity X Occurrence) 2 Numerous administrative and engineering controls in place to prevent loss of containment and subsequent release to the environment. Likelihood of catastrophic loss and failure of multiple controls is very low. Evidence of ground subsidence in the past which posed problems however bund integrity testing is in date. 8 5 Underground drainage network Potential leaks/cracks in underground pipework resulting in pathway for contamination 3 Underground pipework in good condition. In the event of a loss of material to the yard area and subsequently to the drainage system a very small volume of hazardous material may penetrate through cracks before clean- 2 Numerous administrative and engineering controls in place to prevent loss of containment and subsequent release to the environment therefore ensuring very low risk of material being 6 Document No.: v1.01 Page 18 of 25

19 Risk ID Process Risk Scenario Severity 6 Secondary Bunding (Concrete Hardstanding) Possible migration of contaminants 7 Production Process explosion leading to discharges to water and/or soil resulting in unscheduled or shock load discharge from production disrupting treatment process Basis of Severity up occurs. This may have a moderate impact upon underlying soil and groundwater. 3 Only a very small volume of material has the potential to migrate through bunds as they are in good condition, are fit for purpose and are periodically integrity tested (every 3 years). In the event of a release from a primary storage vessel it is likely No material or only a very small volume of material has the potential to penetrate through any bunds on-site at any time thereby causing only a moderate impact on underlying soil and groundwater quality. 3 Release of mixed contaminants resulting in unscheduled or shock load discharge from production. Production safety systems in place to automatically shut down raw material feed in and production during an incident. Exceedances of the ELV s short duration only. Occurrence Basis of Occurrence Risk Score (Severity X Occurrence) released to the surrounding environment. 1 Given control in place the likelihood of a loss of containment from primary storage and subsequent migration of material through bunds is considered very low. 2 Production area is contained and all run off diverted to WWTP. Production has several safety systems in place to prevent uncontrolled release including automatic linked shutdown and pipe work purging. Where a supply or process issue is detected, the processing plant is designed to automatically stop, resulting in stoppage of 3 6 Document No.: v1.01 Page 19 of 25

20 Risk ID Process Risk Scenario Severity 8 Production Spillages from production, through cells not connected securely to pipes 9 Wastewater treatment plant WWTP Gradual losses through fractures/cracks in tanks and pipelines 10 Fire Firewater discharge to WWTP, surface water or groundwater Basis of Severity 2 Loses would be of low volume and directed towards the WWTP on site for further treatment/holding. 3 Localised low volume impact beneath the bunds/concrete surface, over long durations. 3 There has never been a fire on site which required significant fire-fighting effort. Local Fire Brigade have run on-site exercises to improve responses times and familiarity with the site. Extensive fire protection measures. Emergency response team in place. The balance tank is maintained so that there is a minimum 150m3 reserve capacity (50% Occurrence Basis of Occurrence Risk Score (Severity X Occurrence) material in/through the process. Manual shutdown is also possible in emergency situations, cutting off supply of material to the process. 2 System pipework is all above 4 ground, and mostly automated, reducing likelihood of mistaken connections. Cells are pressure tested prior to installation. Potential for spillages to go unnoticed minimal. 2 Tanks and pipelines regularly 6 inspected and fitted with level alarms. A gravity flow system is in place to minimise emission in the event of a power failure. 2 Process building has very 6 limited flammable items, enabling cutting of flow of raw material into the building as a suitable means of stopping fuel supply. Warehouses/workshops have limited sources of ignition sources, and are selfcontained. Main office building and laboratory areas are constantly manned during operational day and follow normal precautions Document No.: v1.01 Page 20 of 25

21 Risk ID Process Risk Scenario Severity 11 Traffic Loss to environment due to incidents involving vehicles (forklifts, trucks, etc) Basis of Severity of total capacity) available at all times. 3 Primary vehicle movements occur across the process yard area, which is concreted and drained to the WWTP, significantly reducing risk to soil/groundwater. WWTP has holding capacity for 150m3 of shock loading within tanks, and is regularly monitored. Parts of the yard area however show evidence of crack and deterioration which may result in some minor losses of material to the environment in the event of a traffic incident. Occurrence Basis of Occurrence Risk Score (Severity X Occurrence) and awareness for fire prevention for office spaces. ERP in place on-site. 3 Speed limit on site, drivers 9 are familiar with loading and unloading procedures. Warning signs in place for low pipework, bund areas. All drivers are qualified/trained to man the vehicle(s) under their control. Document No.: v1.01 Page 21 of 25

22 3.3.4 Risk Evaluation Table 3-6 Risk Evaluation Risk ID Process Potential Risk Severity Occurrence Risk Score Risk Colour 2 11 Traffic Loss to environment due to incidents involving vehicles (forklifts, trucks, etc) 4 Bulk Storage and Catastrophic loss from Handling (aqueous bulk storage tanks/ chemicals) pipelines, and bund fracture resulting in loss of chemicals across site and into the WWTP 1 Fuel Storage Loss from tanks or during delivery/unloading 2 Bulk Storage and Spillage during Tanker Handling (aqueous loading operations chemicals) 3 Bulk Storage and Loss from bulk storage Handling (aqueous tanks/pipelines chemicals) 5 Underground drainage Potential network leaks/cracks in underground pipework resulting in pathway for contamination 7 Production Process explosion leading to discharges to water and/or soil resulting in unscheduled or shock load discharge from production disrupting treatment process 9 Wastewater treatment plant WWTP Gradual losses through fractures/cracks in tanks and pipelines 10 Fire Firewater discharge to WWTP, surface water or groundwater 8 Production Spillages from production, through cells not connected securely to pipes 6 Secondary Bunding (Concrete Hardstanding) Possible migration of contaminants As per Matrix shown in Table 3-4 Document No.: v1.01 Page 22 of 25

23 4. Conclusions As can be seen from the Table 3-6, all identified Risks at the site are in either light or dark green bands and as a result are considered to be low level risks. A full Baseline Report is therefore not required as there is no significant possibility for contamination of soil or groundwater. These are lowest-level risks and indicate a need for continuing awareness and monitoring on a regular basis. Whilst they are currently low or minor risks, some have the potential to increase to medium or even high level risks and must therefore be regularly monitored and if cost effective mitigation can be carried out to reduce the risk even further this should be pursued. 5. Recommendations Although it is unlikely that an emission of relevant hazardous materials to GW/soil will occur given the existing control measures in place on-site it is recommended that areas of the hard surface area of the yard which have suffered deterioration and cracking are repaved to ensure the full integrity of all parts of the site. Document No.: v1.01 Page 23 of 25

24 Appendix 1 Site Layout Plan Document No.: v1.01 Page 24 of 25 EPA Export :06:27:12

25 Appendix 2 Risk Level Definition Occurrence Risk Level Definitions Severity Risk Level Definitions No. Ref. Risk Level Definition No. Ref. Risk Level Definition 1 Very low So unlikely, it can be assumed occurrence may not be experienced in the life of the facility. 2 Low Unlikely, but possible to occur in the life of the facility. 1 Trivial No materials released to the environment due to containment systems in place or; trivial, negligible types and/or quantities of hazardous substances are released to the environment, causing negligible environmental impacts. 2 Minor Small quantities of harmful materials are released to the environment cause a minor, temporally short alteration to environmental quality 3 Medium Likely to occur sometime in the life of the facility 4 High Will occur several times in the life of the facility 3 Moderate A moderate quantity of hazardous materials are released to the environment relative to the volumes of materials stored on-site and the sensitivities of the receiving environment, causing a short to medium term, adverse impact on local environmental quality, that can be readily mitigated with moderate costs 4 Major A large quantity of materials has been released to the environment causing a major, longer term, adverse impact upon environmental quality that can only be mitigated with significant costs 5 Very high Likely to occur often in the life of the facility 5 Massive A very large quantity of materials has been released to the environment causing catastrophic, long term impacts upon the local environment and the wider region, which can only be mitigated with very high costs. Document No.: v1.01 Page 25 of 25 EPA Export :06:27:12