ATTACHMENT J ACCIDENT PREVENTION & EMERGENCY RESPONSE

Transcription

1 ATTACHMENT J ACCIDENT PREVENTION & EMERGENCY RESPONSE

2 Attachment J Industrial Emissions Licence Application J.1 Accident Prevention This Accident Prevention information sets out the various measures at PTTE in preventing environmental accidents from occurring at the facility. The Emergency Response Procedure (ERP) should also be consulted the ERP deals directly with response to environmental emergency risks at the facility. The ERP is attached to this Section. Apart from risks to the environment, there are Health and Safety issues to be addressed. These issues are dealt with separately in the company Health and Safety Manual. The main environmental accident risks relevant to the PTTE operations in no particular order are: Surface water pollution Groundwater pollution Air Pollution Flooding Power Loss Vehicle collision Explosion with releases to air These are dealt with below. J.1.1 SURFACE WATER POLLUTION The following section outlines the prevention measures associated with possible accidental surface water pollution. (a) Process Effluent: There is no process effluent generated and hence no discharge to sewer or surface water of any process effluent from the facility. The only exception is the small amounts of waste water with residues of chlorine as a by-product made when generating deionised water (DI) for production at PTTE. The waste water is treated by the on-site waste water treatment plant. The DI plant is a modest off the shelf system which is maintained and serviced to schedule to ensure that only water residue is produced as waste. Auxiliary Chemicals Ireland Ltd T/A PT Technologies Europe. Page 1 of 7

3 Attachment J Industrial Emissions Licence Application (b) Surface water run-off: All yard storm water run-off are served by a series of road gullies (marked RG on Drawing ref 1822-C-011) that lead to drainage boxes (marked S1 to S5 on Drawing ref 1822-C-011) on drainage channels with all surface water drainage being discharge to four separate soak-away locations at each corner of the site. Presently there are no surface water interceptor units located at the site. In the unlikely event of significant outside spillage, the liquid will be firstly contained by the company spill procedure and secondly, any liquid escape will be further contained above ground via drain covers and localised bunding. Please refer to the Fire Water Risk Assessment report by ENVIROCO in 2012 for further emergency handing details which is located in attachment I.4 of this application. Small spills will be handled by the company spill procedure (attached to this section) in order to further minimise contaminated run-off. There is no outside handling of solvents/raw materials except for dispatch and deliveries to the rear of the main building. (c) Foul sewerage All sanitary waste is discharged directly to the on-site waste water treatment plant with associated percolation system. This WWTP is maintained and serviced to the manufacturers design details. (d) Bunded chemical and liquids storage Any accidental spills within bunded areas will be contained inside the bunds. Outside chemical storage locations are confined to a large bund store for bulk vertical vessels containing solvent raw material storage. This precast insitu concrete bund is fully closed and the wall strong enough to protect the vessels from accidental vehicle collision with a fork lift truck or other vehicle. There is also a smaller internal bund inside the main building where the solvent mixing tanks are located in case of any accidental spill at this location. The internal bund store therefore prevent rainwater infiltration. There is also temporary storage of all product and some smaller quantities of raw materials inside the main building on racking for use on-site. Appropriate spill kits are available at strategic locations here to deal with any emergency leaks/spills. There may be temporary storage of raw materials and product at the despatch area (uncovered) on occasion while awaiting further movements on and off-site. In this instance, care and attention is practised by employees on loading and vehicle movements to ensure no accidental damage/liquid spills. Auxiliary Chemicals Ireland Ltd T/A PT Technologies Europe. Page 2 of 7

4 Attachment J Industrial Emissions Licence Application J.1.2 GROUNDWATER POLLUTION The following section outlines the prevention measures associated with possible accidental ground water pollution. (a) Process Effluent: There is no process effluent generated and hence no discharge to ground of any process effluent from the facility. As mentioned previously, the small amounts of by-product water containing chlorine and iron residues are accommodated by the on-site waste water treatment system. (b) Ground water run-off: The outside areas of the facility are covered in tarmac and small sections of concrete and therefore this protective hardstanding will prevent any run-off from entering the ground. There is a concrete kerb also separating the hardstanding areas from the surrounding landscaping on-site thus preventing run-off from entering soil areas on/off-site. (c) Materials storage. Please refer to bunding storage descriptions previously for section J.1.1 (d). All inside storage of materials is thus confined to inside the main building, outside storage is accommodated by the bund store and therefore this prevents spills entering the ground. (d) Foul sewerage All sanitary waste is discharged directly to the on-site waste water treatment plant with associated percolation system. This WWTP is maintained and serviced to the manufacturers design details and is appropriate for the staffing levels on-site. J1.3 AIR POLLUTION The following section outlines the prevention measures associated with possible accidental air emissions pollution. (a) Process emissions: The scheduled process air emissions are identified in section I.1.1 of Attachment I of this application i.e. one point source emission point for VOCs and particulates which only occurs twice per week based on production of batches of Lube product. Controls for the point source emission are as follows; The emissions of total organics as C and total particulates were monitored by an independent consultancy. Auxiliary Chemicals Ireland Ltd T/A PT Technologies Europe. Page 3 of 7

5 Attachment J Industrial Emissions Licence Application In the abnormal event of the bag house filter not working correctly management will promptly make arrangements to repair it. A preventative maintenance schedule is in place to ensure adequate operation of the emission point from the bag house filter unit. In terms of fugitive emissions, the following controls are in place to avoid accidently VOC releases; All solvents and solvent based raw materials stored in bulk vessels, IBCs or drums, are fully secure with a no open lid policy in place for materials in storage. This prevents accidental fugitive VOC emissions. Liquids are transferred using fully enclosed pipework, couplings and pumps. There is no open pouring of solvents. Only exact quantities of solvents from the mixing tanks are delivered to product lines, this is achieved mechanically by a dedicated solvent dispensing system. This automated process achieves solvent delivery in an efficient manner, avoiding spills and minimising fugitive emissions as the solvent is delivered directly into the packaging. Packaging of products occurs directly after solvent delivery for each line process. Bottle neck seals, clips and barrier bags are all used for various specific products to customer requirements. This also further prevents possible fugitive emissions from solvents in products. The timely manner of packaging ensures minimal fugitive emissions also. J1.4 FLOODING The following section outlines the prevention measures associated with possible accidental flooding. The site is located in a fully serviced industrial site close to a business park and not located in any flood plain area. All surface water run-off for the site is accommodated by localised soak-away points. All liquid raw materials on-site are stored as described in section J.1.1 (d) and this will avoid interaction with outside flood water should any unforeseen situation arise. J1.5 POWER LOSS The following section outlines the prevention measures associated with possible accidental power loss or interruption at the facility. In the event of power loss or interruption, there will be minimal impact to the environmental in terms of accidental releases. This is for the following reasons; Auxiliary Chemicals Ireland Ltd T/A PT Technologies Europe. Page 4 of 7

6 Attachment J Industrial Emissions Licence Application The point source emission point will not function and therefore no emission will occur. Production operations are manual or semi-automatic processes at the facility and hence, no control measures required in the event of breakdown or power failure. All solvents and solvent raw material storage is unaffected by power cuts as there is no solvent heating/cooling required on-site. Normal production can resume once power is fully restored without any significant waste production apart from unfinished products/materials in the machines. All solvents in the dispensing lines are secure and fit for purpose for continuation once power is restored. J1.6 VEHICLE COLLISION The following section outlines the prevention measures associated with possible accidental vehicle collision at the facility. In the unlikely event of vehicle collision, there will be minimal impact to the environmental in terms of accidental releases. This is for the following reasons; All production operations occur inside the main building in a designed facility purpose built to increase production efficiency with minimal interactions with vehicles. All outside solvents storage as described in section J.1(d) avoids vehicle collisions. Should any accident collision occur e.g. fork lift truck piercing a drum/ibc, the immediate spill will be handled as per the company spill procedure (attached) All fork lift truck drivers are appropriately trained to avoid accident situations. There is strict low speed limit in place at the facility (5km/hr) for all fork trucks and incoming raw materials deliveries. J1.7 EXPLOSION WITH RELEASES TO AIR The following section outlines the prevention measures associated with possible accidental explosive releases to air at the facility. An explosion with subsequent uncontrolled release to air is possible but a highly unlikely event. This is for the following reasons; Auxiliary Chemicals Ireland Ltd T/A PT Technologies Europe. Page 5 of 7

7 Attachment J Industrial Emissions Licence Application All production operations occur inside the main building in a designed facility purpose built to ensure minimal possibilities of explosions. There is a strict no smoking policy on-site at production and high risk areas. All sockets & switches are Ingress Protected (IP) areas where solvents/solvent based inks are used to avoid electrical sparking. Site security ensures no unauthorised access during and post opening hours. CCTV is also used on-site. These measures avoid possibilities of vandalism with fire. J.2 Emergency response The Emergency Response Procedure (ERP) deals directly with response to environmental emergency risks at the facility. The ERP is attached to this Section and the following summary details are noted: An inventory of fire extinguishers located at strategic points throughout the site is kept onsite. These fire extinguishers are serviced and checked on a scheduled basis. The site is served by water supply from the existing site and there are fire hydrant points located around the site. The existing emergency response procedure is communicated to all staff on-site as part of the ISO 14001:2004 management system. Emergency contact numbers (including after hours numbers) are to be posted at locations throughout the building in the event of an emergency situation. In the event of a small localised fire outbreak during working hours, staff would attempt to put out the fire. Should the fire become uncontrollable, staff will call out the fire brigade and evacuate the building as per the ERP. J.2.1 Firewater run-off The water used to extinguish a fire (fire-water), will contain dilute quantities of chemicals affected by the fire. Unless the contaminated fire-water can be retained on site, it can cause pollution to surface water, sewers, soil and groundwater. If a significant risk exists for firewater to leave a site and cause pollution, then a Risk Management Programme must be implemented. This programme will outline the actions that must be taken in order to reduce the risk of fire-water polluting the environment. A Risk Management Programme will typically include the implementation of management systems and engineering controls to reduce or eliminate potential hazards or sources of pollution. Engineering techniques to help minimise the spread of fire-water contamination Auxiliary Chemicals Ireland Ltd T/A PT Technologies Europe. Page 6 of 7

8 Attachment J Industrial Emissions Licence Application include; Underground storage tanks Above ground storage tanks Drain covers Cut off valves on sumps Absorbent booms and materials Please refer to the Fire Water Risk Assessment Report 2012 for further assessment details at PTTE and recommendations. J.2.2. Spillages These will be handled by employees where they occur using absorbent booms and adsorbent materials. Employees will be trained in on their use and spill kits will be maintained around strategic locations at the site for use. J.2.3 Emergency Contact Numbers These are contained with the ERP (Appendices). Auxiliary Chemicals Ireland Ltd T/A PT Technologies Europe. Page 7 of 7

9 Copy of Emergency Response Procedure (ERP)

10 Facility Emergency Response Procedure (ERP) Revision Number: Date Page: Rev of 6 Authorised by: Brendan Keating Approved by: Shane Casey 1.0 PURPOSE This procedure applies to all employees, visitors and outside workers at PTT and identifies Clause of ISO14001: SCOPE The main emergency risks associated with PTT driver operations are: Fire Vehicle Accidents Liquid spills (chemicals) This emergency plan outlines the emergency procedure that should be followed when dealing with any of these potential emergency situations. 3.0 PROCEDURE 3.1. EMERGENCY FIRE RESPONSE PROCEDURE The following section outlines the emergency response procedure and individual responsibilities in the event of fire at the facility. Please note: there are smoke sensor alarms in the building which will activate in the event of fire and/or smoke FINDER On discovering an emergency situation the finder should; a) Raise the alarm by either - Call out in the yard and factory floor areas and inform the reception of the location and nature of the emergency, or - Raise the alarm by pressing a fire button box, located in the facility offices b) If appropriate and trained to do so, attempt to tackle the emergency with the available emergency equipment, e.g. fire extinguishers, hose reel. c) If the finder considers the emergency to be beyond control, leave immediately by the nearest fire exit and proceed to the designated assembly point at the front of the site just inside the front gates.

11 Facility Emergency Response Procedure (ERP) Revision Number: Date Page: Rev of RECEPTION Upon notification of an emergency by the employee the reception area should: a) If evidence of a fire exists, dial 112/999 immediately and give the relevant information that is available to the relevant emergency services. b) Keep telephone lines clear for emergency calls. c) Take roll call for visitors/representatives and inform the Managing Director or Business Unit Manager of the headcount status. d) On the instructions of the Managing Director or Business Unit Manager inform employees to leave the site. e) Prevent incoming traffic except for the outside emergency services. f) Direct outside emergency services to the site of the emergency upon their arrival BUSINESS UNIT MANAGER The role of the Business Unit Manager or in his absence, department managers on hearing the alarm is as follows: a) Proceed directly to the source of the emergency (only if safe to do so). b) Liaise with reception. c) Give instructions to contact outside emergency services if required, providing information on the nature of the emergency. d) Give instructions to an appropriately trained person to bung the surface water outlet pipes, using the bungs provided e) Give instructions to have all employees removed from the site depending on the nature of the emergency. f) Receive information on any missing employees. g) Instruct first aiders to proceed to the site of the emergency (only if safe to do so). h) To initiate a search and rescue for any missing employees, if deemed safe to do so. i) Hand over control of the emergency to outside emergency services on their arrival and provide any information/assistance required or requested. j) Give the all clear when informed by the emergency services to do so.

12 Facility Emergency Response Procedure (ERP) Revision Number: Date Page: Rev of FIRST AIDERS On hearing the alarm First Aiders should: a) Leave immediately by the nearest fire exit and proceed to the designated assembly point at the front of the site just inside the front gates. b) If requested to do so by the Business Unit Manager or Department Managers proceed to the site of the emergency to provide assistance. c) If assistance is not requested then remain at the assembly point until further notice by either the Business Unit Manager or the Department Managers EMERGENCY ACCIDENT RESPONSE PROCEDURE On discovering an accident situation the finder should: a) Inform the Business Unit Manager or in his absence the respective Department Manager of the location and nature of the accident. b) Inform the reception to the location and nature of the accident if the Business Unit Manager or Department Managers are unavailable. c) If appropriate and trained to do so, attempt to deal with the incident with available first aid equipment. d) The Business Unit Manager or Department Managers will assess the situation and request first aiders to proceed to the accident if needed. e) In the event of a serious accident, if either the Business Unit Manager or Department Managers are unavailable then the finder shall alert the outside emergency services or request another employee to contact the outside emergency services and provide information on the location and nature of the accident. All employees are aware of the Work Related Accident Procedure and the need for all accidents to be reported and documented on an Accident Report Form EMERGENCY SPILL RESPONSE PROCEDURE Spill Kits are positioned at the facility at planned locations labelled with Spill Kit Notices CHEMICAL SPILLS a) These are most likely to occur at the solvent dispensing product lines and other areas where solvents and chemical liquids are stored (e.g. when transferring fluids to and from containers). b) If a spill does occur then quickly contain it using absorbent material from spill kits provided in the various locations at the facility. c) Inform the immediate employee in the area of the spill to ensure no further accidents by slipping.

13 Facility Emergency Response Procedure (ERP) Revision Number: Date Page: Rev of 6 d) In the event of a significant spill i.e. greater than 5litres, the Production & Plant Manager is informed immediately. e) Used adsorbent spill material should be placed in a designated metal barrel for hazardous waste disposal. This barrel will be situated in the hazardous solid waste quarantine area (inside the factory floor). 4.0 RESPONSIBILITIES The following section outlines the responsibilities and duties of all PTT employees with regard the Facility Emergency Response Procedure: 4.1. BUSINESS UNIT MANAGER a) Providing overall direction and support to those employees responsible for the plan. b) Having available adequate financial and manpower resources to prepare for and carry out emergency duties. c) Responding to all external inquiries from interested parties in connection with an emergency. d) Taking full control of operations in an emergency. e) Providing/organising training for personnel with responsibilities as outlined in this emergency plan. f) Overseeing the 2 evacuation/emergency drills to be carried out per year PRODUCTION & PLANT MANAGER a) Reviewing and updating the emergency plan in conjunction with relevant management staff. b) Monitoring the effectiveness of the plan through periodic drills to be held at least twice a year. c) Overseeing all emergency responses (if present). d) Checking and maintaining all necessary emergency supplies and equipment. e) Organising a minimum of 2 evacuation/emergency drills per year.

14 Facility Emergency Response Procedure (ERP) Revision Number: Date Page: Rev of PTT EMPLOYEES All employees are accounted for in the event of an emergency by roll call. Ensure this procedure is kept up to date; that all required changes are communicated and that this document is maintained as a controlled document in accordance with Document Control DPC procedure and by the Quality Representative 5.0 REFERENCES DPC WRAP ARF Document Control Work Related Accident Procedure Accident Report Form 6.0 REVIEW AND AMENDMENT HISTORY This document should be reviewed As required by the Internal Audit schedule; At least once annually; More frequently as may be required in order to ensure adequacy. All changes made to this document must be recorded in the table below: Paragraph Description(s) Date Signature Revision

15 Facility Emergency Response Procedure (ERP) Revision Number: Date Page: Rev of 6 APPENDIX A EMERGENCY TELEPHONE NUMBERS Business Unit Manager Rick Livingstone Production & Plant Manager Brendan Keating Fire Emergency 112/999 Cork University Hospital Gardaí 112/999 Gardaí Fermoy Cork County Council Headquarters Cork County Fire Service Headquarters Cork County Fire Service North Divisional Headquarters Environment Section Water and Sanitary Services Section water.servicesnorth@corkcoco.ie EPA (HQ, Wexford) EPA (Cork regional office) ESB Emergency GAS Emergency (leaks only)

16 Copy of Chemical Spill Clean-up Procedure

17 Chemical Spill Cleanup Procedure Revision Number: Date Page: Rev of 2 Authorised by: Brendan Keating Approved by: Shane Casey 1.0 PURPOSE To establish and maintain procedures for management of spills, for all employees whose work can have a significant effect upon the environment. This procedure identifies Clause of ISO14001: SCOPE This procedure applies to all employees of PTT involved in chemicals and liquids handling and working with same. 3.0 PROCEDURE 3.1. These are most likely to occur at the solvent dispensing product lines and other areas where solvent and chemical liquids are stored (e.g. when transferring fluids to and from containers) If a spill does occur then quickly try to stop the flow of the liquid (stop pump, filling head, closing of stop cap etc) Inform other employees in the immediate area of the spill to ensure no further accidents or incidents occur In the event of a significant spill i.e. greater than 5 Litres, the Production and Facilities Manager is to be informed immediately The spill must be contained as quickly as possible so to ensure that minimal impact of the environment. The spill will be contained using adsorbent materials from spill kits provided in the various locations at the facility. All employees involved in the spill clean will wear appropriate PPE Used adsorbent material should be placed in a designated metal barrel for hazardous waste disposal by an approved contractor. This barrel will be situated in the hazardous solid waste quarantine area (inside the factory) 4.0 RESPONSIBILITIES The following section outlines the responsibilities and duties with regard the Chemical Spill Cleanup Procedure:

18 Chemical Spill Cleanup Procedure Revision Number: Date Page: Rev of 2 All employees have a duty of care to report any possible leaks of chemicals that occur within the facility Only those employees who have had the required training will part in the cleanup of such chemical leaks It is the responsibility of the Production and Facilities Manager to manage any leaks that do occur and to put in place procedures so to ensure that the issues does not reoccur 5.0 REFERENCES CP EP Communication Procedure Environmental Policy 6.0 REVIEW AND AMENDMENT HISTORY This document should be reviewed As required by the Internal Audit schedule; At least once annually; More frequently as may be required in order to ensure adequacy. All changes made to this document must be recorded in the table below: Paragraph Description(s) Date Signature Revision