Rank: New forum user 
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first time poster so please be gentle! We are going to have a 24000 litre ethanol road tanker permamanently sited at my place of work. In terms of other substances we will have approx 21000 litres of kersoene on site and 7.5 tonne of LPG. Do I need to be concerned about COMAH regs?
Thanks
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Rank: New forum user 
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Let me point you towards the Energy Institute website https://www.energyinst.org, and specifically. You should do a search Containment Systems Working Group's (CSWG), they will point you to the appropriate regulations etc. Guidance will include: COMAH CA ‘Containment policy’ and EU Directive on the control of major-accident hazards involving dangerous substances (‘Seveso lIl directive’), and EI Guidance on conceptual design, selection and life cycle assurance of liners intended to improve integrity of bunds to above-ground storage tanks for bulk storage of petroleum, petroleum products or other fuels. NOte: There are different rules for sub terranian tanks so make sure your risk assessments are accurate and leave details on here if you need further guidance.
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Rank: Super forum user
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Go through COMAH regs particularly having a look at Schedule 1 and Appendix 1. I didn’t think ethanol appears in the list but it might be included indirectly.
The regs are at http://www.hse.gov.uk/pUbns/priced/l111.pdf
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Rank: Forum user
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The short answer is yes!
From the info you have provided you may be going to become a lower tier COMAH site under the aggregation rule. Look at Schedule 1 in the ref given above.
Ethanol is a Cat 2 flammable liquid, Lower tier threshold 50t. You will have 24 t
Kerosene: Cat 3 flamm liquid, Lower tier threshold 5000 t. You have 21 t
LPG: Flammable gas. Lower tier threshold 10t you have 7.5 t
Using the aggregation rule: Ethanol: 24/50 of the threshold = 0.48;
Kerosene: 21/5000 = negligible amount for COMAH (less than 2% of threshold)
LPG: 7.5/10=0.75
0.48 + 0.75 = 1.23 Therefore you will become COMAH lower tier This is just a quick check and you need to go through the guidance yourself, check the tonnages stored, confirm categories etc. Good Luck
Edited by user 12 May 2017 08:17:32(UTC)
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Rank: New forum user
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LPG is actually a named substance in it's own right with a LT threshold of 50T and an UT threshold of 200T. Also, you didn't mention the process conditions regarding the ethanol so you may fall into the lower risk category (of 5c) which has an LT threshold of 5000T.
So you may be well below it, but as advised previous, check and make sure.
Edited by user 12 May 2017 13:50:00(UTC)
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 1 user thanked Jason_B for this useful post.
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Rank: Forum user
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If it is permanent storage, you will be expected to provide permanent storage rather than a portable storage tank.
If you haven't already, take a look at HSG176 Storage of flammable liquids in tanks.
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Rank: Forum user
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Jason_B is absolutely right - thanks for the correction.
LPG and Kerosenes are named substances in part 2 of schedule 1. So their Lower tier limits are indeed 50t and 2,500t respectively. If you are NOT processing the ethanol by heating or pressure or in conditions which could give rise to a major accident then the LTL would be 5000t.
At least its Friday now
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