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Posted By Emma Forbes
Please forgive my ignorance on this one, but would/could you prepare an emergency plan for a diesel spillage under COMAH and/or MHSWR Reg 8....
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Posted By steve e ashton
Emma:
It depends... We need more information to answer your query accurately.
In general terms, COMAH only applies to those facilities which have more than threshold quantities of specified materials.
Diesel is (normally) outside the flammability limits specified (i.e. fp>55C) so would not fall within COMAH for that reason - but I suspect (Without looking it up in CHIP- can ANYONE CONFIRM?) that it carries risk phrase 51 or 52, being toxic to aquatic organisms or causing long term adverse effects in the environment - so more than 500 tons stored=lower tier, 2,000 tons= top tier.
Note that COMAH covers Environmental issues as well as 'normal' health and safety - fire and toxicity - so ANY diesel spill into an area of water used for abstraction or biologically sensitive is likely to be counted as a major accident.
For those sites below COMAH thresholds, then the duties from other regs will apply. Not sure that small diesel spills would count as 'serious and imminent danger' in my lexicon - so probably not Reg 8 of the Mgt regs. The requirement for a spillage prevention and control/response plan would probably best be justified under Regs 3 and 5... Unless there is some tweak in the Environment Regs that I am not familiar with....
Hope this helps clarify a little - mail direct if you need further assistance.
Steve
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Posted By Dave Wilson
Water quality regs / EPA may apply
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Posted By Emma Forbes
Hi guys, thanks for the responses.
It's a theoretical situation, in a garage scenerio as part of my PgC (should have perhaps put this on the other forum).
I've considered the fact that it would be primarily an environmental issue but wondered if there was a health and safety element. I'll be mentioning the issue of insufficient bunding.....
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Posted By steve e ashton
A retail garage will not normally hold sufficient quantities of diesel (or petrol) to be a comah site, and I would be very surprised if there are any commercial fleet garages that hold above threshold quantities...
Another avenue you may need to explore would be the Petroleum License conditions if applicable - I would suspect that most Local Authorities will insist that the site operator has appropriate plans and procedures in place.
Your comment on bunding suggests there is an above-ground tank? Leaks easy to see (compared to below-ground storage, where serious leaks may go undetected for long periods of time, causing very high remediation costs) but bund walls need to be impermeable - it is all too common to find bunds with open pipes at ground level to 'drain rainwater' ...
If the tank is 'double skinned' - as many bowsers are - then the second skin is effectively the bund... although there are problems ensuring that valve penetrations and pipes are incapable of spilling the tank contents.
Not my area of expertise though - hope someone else can help with more specific info... Good luck with the PGC.
Steve
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Posted By TK
Emma
You will not find petrol forecourt/garages that are COMAH sites. The closest is probably fuel wholesalers i.e. large bulk storage. They ones I looked at when I was a regulator stored petrol, diesel and kerosene. They supplied tanker loads to supermarkets and a nearby airport.
Although petrol was the product that posed the main risks, you could expect that a spillage of any product would be covered in the Emergency Plan.
The risk is that the spillage has the potential to be an initiator to another event and this escalates further,.e.g. a domino effect. You'll find that all source pathway receptor scenarios will be covered in the risk assessments. Emergency plans will take account of these.
Thomas
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