This Technical Measures Document refers to the emergency response and spill control measures that can be adopted in plant operation to ensure safe operation.
It should be noted that the criteria requirements for the section of the COMAH Report dealing with Emergency Response Arrangements are provided in Part 2, Chapter 6 of the Safety Report Assessment Manual (SRAM). This Technical Measures Document is intended to provide additional detail on the measures that should be considered in plant design and operational procedures.
Related Technical Measures Documents include:
The relevant Level 2 Criterion is 18.104.22.168(29)d, e.
Generation and implementation of effective emergency response and spill control procedures are fundamental aspects of a safety management system.
The on-site emergency plan, prepared for Regulation 9 of COMAH should address procedures for dealing with emergency situations involving loss of containment in general terms. Full detail of the required contents is provided in Part2, Chapter 6 of the SRAM. In brief, the main points for inclusion are:
The emergency plan should be simple and straightforward, flexible and achieve necessary compliance with legislative requirements. Furthermore separate on-site and off-site emergency plans should be prepared.
The emergency procedures should include instructions for dealing with fires, leaks and spills. The procedure should describe how to:
Evacuation of areas in the event of fire or toxic gas emission should be addressed in an emergency evacuation procedure. This should specify designated safe areas, assembly points and toxic gas shelters. The procedure should also identify responsible personnel whose duties during area evacuation include:
A fire fighting strategy should consider:
The emergency spill control procedure should include the following key sections:
Once the hazardous material has been contained to prevent spread of the material to other areas, the material should be treated wherever possible to render it safe. Acids and alkalis may be treated with appropriate neutralising agents. Due to the differing properties of the various groups of chemical, an appropriate treatment strategy with suitable chemicals should be established in each case. For example, highly concentrated hydrochloric acid will fume when spilled so prior to neutralisation the spill should be diluted with a water spray.
Once the material has been treated the cleared up the area should be washed with large volumes of water. Most chemical plants and associated areas are serviced by chemical drains that feed to the effluent treatment plant. The washing operation will represent an abnormal loading on the effluent treatment plant, and it is vital that in any situation where this is likely to happen the staff responsible for operation of the effluent treatment plant are notified so that appropriate measures can be adopted. The effluent treatment plant operatives are likely to require the following information:
In the case of fire water run off, much larger volumes of water are employed and the provision of firewater lagoons to contain potentially toxic firewater is required.
Process specific emergency spill kits (acid, alkali, solvent, toxic etc) and appropriate personal protective equipment should be readily available with supporting procedures. These spill kits should be maintained on a regular basis to ensure that they are always available and fit for purpose. This ensures that the most appropriate measure is at hand to deal with a spill or fire in the most effective way.
Issues that should also be addressed include:
Existing guidance provides comprehensive information with respect to best practice for emergency response and spill control procedures.
Guidance for emergency responses for chlorine, anhydrous ammonia, LPG, nitrocellulose, flammable dusts, and flammable liquids storage plants and chemical warehouses are given in the specific guidance notes listed below.
Additional material providing much insight into analysis of offsite consequences through a risk management program is now available from the United States Environmental Protection Agency. This provides guidance on offsite consequence analysis for toxic gases, toxic liquids, and flammable substances. The risk management analysis will have a significant impact on the format and content of an emergency response or spill control procedure.
General guidance is available in the ILO publication 'Major hazard control: A practical manual'.
ILO, PIACT, `Major Hazard Control: A Practical Manual', 1988.
Seeley, L.A. and Moosemiller, M.D., 'Planning for Emergency Response', DNV Technica, Inc., Chemical Engineering, 102, 6, p84, June 1995.
AIChE/CCPS, `Plant Guidelines for Technical Management of Chemical Process Safety', New York, 1992.
EPA / CEPP, 'Risk Management Program Guidance for Offsite Consequence Analysis', RMP Series, United States Environmental Protection Agency / Chemical Emergency Preparedness and Prevention Office, April 1999.
Robinson, B.W. and UK Chlorine Producers, 'General guidance on emergency planning within the CIMAH Regulations for chlorine installations', 1986.
Lees, F.P., 'Loss Prevention in the Process Industries: Hazard Identification, Assessment and Control', Second Edition, Butterworth Heinemann, 1996.
CONCAWE Reports (published by the Oil Companies European Organizations for Environmental and Health Protection), Emergency planning guidance notes: