EI Technical Committee

26 Mar 2014

Demonstrating

‘All Necessary Measures’

at Petroleum Bulk Stores

Pat Conneely

COMAH, Chemical Production & Storage

(CCPS)

Presentation Structure

• HSA/CCPS roles

• Legal requirements in PBS sector

• Dublin Port situation

• All Necessary Measures in practice

HSA Divisions

Chemicals & Prevention Division

CCPS Role

COMAH site distribution

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Background

• In 2005 – Fire Response Policy Group engaged consultants

Byrne O’Cleirigh (BO’C) to do a study to help develop a fire

protection strategy for Dublin Port

• All COMAH sites Covered

• Reviewed potential major accidents and performance of

current firewater systems

BO’C Report

• 2006 – BO’C Report completed.

Among Findings:

• Inadequate resources – full tank or bund fires

• Domino effects not considered

Among Options:

• New ring main (450mm) and associated infrastructure

for bund fire response

Buncefield (Dec 2005)

Legal Framework

• Operators must take ‘all necessary measures’ under COMAH

• Petroleum Bulk stores – shared with the proper authority

• Legal duties on DPC?

• Duties under SHWWA 2005

• Fire Services Act

Dublin Port Strategic Importance

• 45% ‘Oil’ through Dublin Port

• Economic Effect of an accident?

• Environmental & Health Effects?

• ‘Political’ Effects?

Main Actors in Dublin Port

• Dublin Port Company (DPC)

o Landlord

o Coordinator

o Port Infrastructure

• Dublin City Council (DCC) o Water

o Dublin Fire Brigade (DFG)

o Planning control

• Site operators o Petroleum Bulk Stores 1979

o COMAH - “take all necessary measures”

PBSs in Dublin Port

Lack of Progress

• Bulk Oil Stores Survey in 2006/7

• Obtained copy of BOC report in 2008

• HSA arranged meeting in 2009 to discuss progress

• Responsibility for the water supply?

• Who pays?

• Ongoing Communication process

Initiation of Process

• Consideration of legal and technical issues

• Twin-track

• December 2009 – Letter to operators

• Review of emergency response arrangements

• Written risk assessments, major fire scenarios, evidence of compliance with IP 19 or equivalent, reviews following Buncefield, Domino effects considered

• Documents to be available on day of inspection

Follow-up meetings DPC/DCC

• Review progress on water supply issue

• Clarification of DPC role under PBS and the Oil Jetties

Regulations – the proper authority

• Issuing of licenses and setting conditions

What are ANM?

• Basic duty on operators under COMAH

• Broadly – are the risks of MA reduced in so far as reasonably

practical?

• Good practice is the starting point

• Legislative provisions

• Standards – IS/EN’s, API,B.S.

• Guidance – HSG 176, CIRIA, BREF, EPA

• Upper end of scale – QRA, CBA

ANM on bunds

• Reg. 31(4) (a) of the 1979 regulations (dealing with petroleum only) require bunds to be impermeable: (4) Every retaining enclosure under paragraph (1) of this Regulation shall—

(a) be designed, constructed and constantly maintained so as to adequately—

(i) prevent escape or leakage of petroleum and the spread of fire,

(ii) resist, as far as is practicable, undue seepage or absorption into the ground of petroleum

• HSG 176 : The floor of the bund should be of concrete or other material substantially impervious to the liquid being stored, and with drainage where necessary to prevent minor spillage collecting near tanks. Stone chippings and similar materials may be used providing the underlying ground is impervious. A suitable buried membrane can also be used, as can specially designed systems using the water table to retain liquids not miscible with water.

• Environmental Protection Agency, Fire-water Retention Facilities, 1995

ANM on Firewater Supply

• PBS Regulation 75 - the owner ‘shall provide in accordance with good standards of practice…. a sufficient output of water at an adequate pressure… sufficient and suitable means for the cooling of storage tanks which may be affected by fire and mobile, portable or transportable fire-fighting equipment, devices, materials, smothering agents or other substances’

• IP 19 - Fire precautions at petroleum refineries and bulk storage installations

• NFPA 30, API publications

ANM on Emergency Response

• IP 19 (2nd Ed.) used as first choice

• It provides guidance on selecting, implementing and monitoring the continuing performance of site-specific justified risk reduction measures - from prevention through detection, protection systems to mitigation measures - to reduce the risk from design event fires at installations that process and store petroleum, intermediates and refined products.

• IP 19 takes a risk based approach to determine the necessary measures required (which includes both prevention and mitigation measures).

Questions for Inspection

1. Has a risk assessment been carried out?

2. Does the risk assessment identify site-specific tank-top fire and bund pool fire scenarios (excluding class III only sites)?

3. Are the firewater and foam resources that will be required to deal with events in point 2 calculated?

4. Are the calculations correct?

5. Are the facilities available to deliver the identified rates?

6. Are appropriate emergency response plans in place?

7. Has risk assessment identified the quantity of firewater and run-off and appropriate retention facilities.

Technical Advice

• Codes and Standards for Fire Fighting and Fire Protection Systems

• Overview of Buncefield Recommendations

• Use of Fire Protection Systems on Fixed Roof Tanks with Internal Floating Roofs

• Fire Fighting Water Mains - Underground and Aboveground Systems

Inspection follow-up

• Review of information gathered

• Sites assessed individually

• Calculations checked

• Improvement Notices to issue

Notices Issued

IP 19 – tank or bund fire involving flammable liquids:

1. Consequence distance to thermal radiation levels of 6.3, 8 & 32 kW/m2

2. Resources required

3. Resources available

4. Plan to remedy any shortfall

Process

• Focus maintained on operators

• Contact maintained with other stakeholders

• Stakeholders and operators interacting outside the enforcement process

2010-2013

• Notice Extensions

• Meetings…

• 2011: Sign off IN’s subject to suitable port infrastructure

• One lagging site – resolved

Infrastructure Project

• Meetings ,consultants ,detailed plans, meetings…

• Planning permission

• Aboveground Fire main

• Agreement

Outcome

• Fire main and associated services commissioned in Feb 2014

• Planning possibilities

• Site changes in prevention and emergency response

• Cost

• Ongoing process

EI Technical Committee

26 Mar 2014

Demonstrating

‘All Necessary Measures’

at Petroleum Bulk Stores

Pat Conneely

COMAH, Chemical Production & Storage

(CCPS)