Attachment J ACCIDENT PREVENTION & EMERGENCY RESPONSE Cadbury Ireland Limited Project Ref: OES1061_01
Cadbury Ireland Limited February 2007 Attachment J J.1 Accidental Emissions Control Accidental emissions can occur due to minor accidents in handling of materials or, as a consequence of a major incident. Cadbury Ireland Rathmore apply a philosophy of prevention, which is based on a three element approach involving: Procedural Control Risk Assessment Training Procedural control is an ongoing component of the approach as modifications and revisions are made to existing procedures, and new ones are prepared based on live experience at the installation. This procedural control extends from routine control over environmental issues, to the response to be followed in the event of a loss of control. In addition, maintenance, calibration and testing procedures are in place to minimise the potential for loss of control occurring in the first instance. The principles of risk assessment are applied to identify and evaluate those areas where the risk of an environmental incident is likely to occur, and decide on the control measures necessary to be implemented. Training ensures that personnel are proficient on implementing procedures that are in place which in turn prevents errors which may succumb to an accidental release. Safety and environmental awareness training is provided for all new employees on site. Storage and Transport: Liquids used on site are stored in accordance with suppliers requirements and are inspected in accordance with Quality procedures. Liquids are generally transported internally and externally via a piped distribution network, which has consequent reductions in the potential for accidental spillages. Individual drums will be transported manually and by forklift within the plant. The quantity of drummed chemicals stored on-site at any one time is kept to a minimum. OES Consulting Page 1 of 6
Cadbury Ireland Limited February 2007 Attachment J J.2 Procedural Control The following procedures are in place to cover both the avoidance of control loss and the actions to restore control, and minimise the potential for environmental impact at the installation. Ref Title QP06 QP09 QP17 QP25 QP26 QP29 QP31 QP32 QP33 QP34 QP36 QP37 QP38 QP39 QP41 QP45 QP48 QP55 QP57 QP59 QP60 QP65 QP68 QP69 QP71 QP74 QP80 Calibration Procedure Corrective and Preventive Action Procedure Training Procedure Solid and Hazardous Waste Management Underground Piping Integrity Check Wastewater Treatment QHSE System Review Procedure Integrity of Bunds Minimising Environmental Damage due to Fire Milk Storage Silo Integrity Checks QHSE Policy Procedure QHSE Objectives and Targets Procedure QHSE Management Programme Environmental Effects Procedure Environmental Reports Procedure Communications Procedure Control of Chemicals, Oils and Grease Hazard Identification Risk Assessment and Risk Control Hazardous Materials Management Above ground Storage Tank Management Good Housekeeping Management Incident OH&S Investigation OH&S Competence Procedure for Ensuring OH&S Control Procedure for Hazard Reporting Control of Risks arising from Contractors Control of Risks arising from Petrol and Diesel OES Consulting Page 2 of 6
Cadbury Ireland Limited February 2007 Attachment J QP81 QP83 QP87 QP90 QP93 QP94 QP95 QP105 QP106 Procedure for Emergency Preparedness Procedure for Permits to Work Control of Risks arising from Batteries Control of Risks arising from Fire Control of Risks arising from Substances Control of Risks arising from Noise Control of Risks arising from Pressure Systems Procedure for OH&S Incident and Accident Reporting Procedure for Control of Vehicles at Rathmore Site J.3 Emergency Response (Crisis Management) The Cadburys Rathmore Emergency Response Management Manual is based on a comprehensive risk assessment of all aspects of the installation and is part of a defined Hazard Identification and Hazard Evaluation process. It addresses a full range of minor and major emergency situations. Examples for specific scenarios include: Chemical Spill Product Spill Dangerous Material Escape Battery Spill Steam Escape Vehicle Collision Effluent Plant Failure Fire Explosion An Emergency Response Manual which details the emergency response procedures, contact numbers and organisational control during, and outside of, normal business hours has been prepared for the plant In the event of spillage or accidental emission, a Supervisor/Manager instigates corrective action as follows: Identify the source of emission/spillage Shut off emission/spillage. Detail a team responsible for containment/clean up. Notify the relevant Authorities. Investigate the cause of the incident and take corrective action. The duty Line Manager on site has access to emergency contact telephone numbers of relevant Authorities and relevant plant personnel in the event of an emergency situation. The Emergency Response Manual which details hazard evaluation, emergency response procedures and organizational control during normal business hours and outside of these hours can be seen in Appendix J.1. OES Consulting Page 3 of 6
Cadbury Ireland Limited February 2007 Attachment J J.4 Bunding and Containment The Cadbury (Ireland) Rathmore facility is bounded along the northern perimeter by the River Blackwater, and important salmonid river, which is designated as a Candidate Special Area of Conservation (csac) of International Importance. With the exception of bulk liquid raw material, intermediates and other ingredients, all liquid hazardous chemicals and fuels used are bunded directly or are stored on proprietary bunded units. Where possible all bunds on site are located within covered areas. Bunds are regularly inspected and accumulated rainwater from external bunds is either transferred to the oil receptor or to WWTP depending on the nature of the material being stored. The storage capacity of the bunded areas within the facility can be seen in Appendix J.2. Visual inspections are undertaken on the HFO tank and on any other bunded area once per month. The underground pipes for the bunker and fuel areas are visually inspected twice per year. All inspection are records were kept of the visual inspections. A copy of the most recent visual inspection for the bunded areas can be seen in Appendix J.3. As a precautionary safety measure drain covers are placed on gulley openings during the bulk delivery of HFO, Caustic, Acid to minimise the potential for environmental impact should an accidential spillage occur. In addition surface drains in the vicinity of the Milk Intake area are routed directly to the wastewater treatment plant providing protection from accidental spillages in this area. OES Consulting Page 4 of 6
Cadbury Ireland Limited February 2007 Attachment J J.5 Site Drainage Cadbury Ireland Rathmore have commissioned MWP, Consulting Engineers to undertake a complete assessment of the drainage network and to make recommendations for replacement or remedial works. The main conclusions of the MWP report are summarised below: A new industrial wastewater drainage system is required to collect and convey process wastewater to the wastewater treatment plant. This industrial wastewater system should be constructed from stainless steel to offer sufficient durability against corrosive agents in the wastewater. A new domestic wastewater sewer system to collect and covey the sanitary wastewater Two new crossings of the railway will be required to convey the proposed new pipelines from the factory to the wastewater treatment plant. These will require directional drilling beneath the railway. It is proposed to create a third crossing to make provision for future ducts and services, which may require to cross the railway. Drainage Remediation Project (DRP) It is proposed to undertake the DRP is on a phased basis over approximately 3-5 years. The aims and objectives of each phase of the DRP are illustrated below: Areas presenting the greatest risk to groundwater have been made priority with process and domestic effluent lines classified as highest priority and repairs to storm water lines least. This work is ongoing and the major areas of concern have been addressed. OES Consulting Page 5 of 6
Cadbury Ireland Limited February 2007 Attachment J J.6 Facilities for Containment of Firewater As part of the DRP a measures will be undertaken to ensure the requirements for retention of firewater in the eventuality of a fire at the facility. This will include provisions for: Assessing, and where necessary upgrading the WWTP to ensure it would have adequate containment to treat water runoff which may potentially originate from fire fighting water volumes in the event of an emergency. Ensuring that any potentially contaminated runoff originating from the surface water drainage network is diverted to a containment area, prior to treatment within the WWTP. OES Consulting Page 6 of 6
Appendix J.1 Emergency Manual
The Energency Manual Contents EVACUATION PROCEDURE EMERGENCY CONTACT NUMBERS FIRST AID INFORMATION EMERGENCY RESPONSE TEAM FIRE WARDENS MAJOR EMERGENCIES FIRE EXPLOSION BOMB ALERT LETTER / PARCEL BOMB BOMB THREAT TOXIC CLOUD FROM NEIGHBOUR TOXIC CLOUD FROM CADBURY LEGIONELLA OUTBREAK ASBESTOS CONTAMINATION INCOMING WATER CONTAMINATION CADBURY CONTAMINATE DRAINAGE NEIGHBOUR EMERGENCY POWER CUT CHEMICAL SPILL BATTERY SPILL VEHICLE COLLISION STEAM ESCAPE DANGEROUS MATERIAL ESCAPE PRODUCT SPILLAGE FLOOD EFFLUENT PLANT FAILURE WEATHER DAMAGE PERSON NOT IN WORKPLACE DISTURBANCE USE OF WEAPONS USE OF ALCOHOL / DRUGS INTRUDERS SUICIDE ATTEMPTS LOCAL EMERGENCIES
Appendix J.2 Capacity of Bunded Areas
Register of Bunded Areas No. Location/Description Contents Length (m) Width (m) Height (m) Capacity (m 3 ) 7 HFO Bund Heavy 13.40 17.20 2.5 576.20 Fuel Oil 8 HFO Bund Waste Oil 13.40 17.20 2.5 576.20 9 HFO Bund Diesel Oil 13.40 17.20 2.5 576.20 10 HFO Bund Diesel Oil 13.40 17.20 2.5 576.20 19 Caustic tore Caustic 3.80 3.4 0.83 10.72 Soda 20 Acid store Nitric Acid 5.0 1.95 0.83 8.10
Appendix J.3 Bund Integrity Test Reports for 2006