Major Emergency Management Guidance for Seveso III Establishments

The National Steering Group (Department of Environment, Community and Local Government) has published a guidance document entitled "A Framework for Major Emergency Management" on the www.mem.ie website. It is primarily concerned with the obligations and responsibilities of the relevant Principal Response Agencies (PRA's) and Local Competent Authorities (LCA's) with regard to External Emergency Planning for Seveso Upper Tier Establishments, under the Seveso III Directive (2012/18/EU) as implemented in Ireland by S.I. 209 of 2015 (2015 COMAH Regulations). It outlines new requirements that apply to both upper and lower tier establishments.

External Emergency Planning Zone

The Consultation Distance is defined in the 2015 COMAH Regulations as a distance or area relating to an establishment, within which there are potentially significant consequences for human health or the environment from a major accident at the establishment, including potentially significant consequences for development such as residential areas, buildings and areas of public use, recreational areas and major transport routes. IT is noted that the Health and Safety Authority has not yet published any guidance on criteria required for setting the consultation distance.

The MEM Guidance document states "the LCA's/PRA's may consider defining an area wider than the Consultation Distance, if appropriate. The External Emergency Planning Zone (EEPZ) is a name given to an extended area defined in the External Emergency Plan (EEP) which will be greater than the Consultation Distance". Consequence modelling must be performed for the Consultation distance and the External Emergency Planning Zone (EEPZ). These areas may differ in certain circumstances. The MEM Guidance document indicates that the Consultation Distance is suitable for Land Use Planning and a larger area may be needed for emergency planning.

The main concern for operators is the extremely conservative consequence endpoints on which the EEPZ is based. These are outlined as follows.

• Distance to the AEGL1 endpoint concentration for toxic releases – the airborne concentration causing notable discomfort, irritation, or certain asymptomatic nonsensory effects to the general population that are not disabling, transient and reversible upon cessation of exposure
• Distance to 10 mbar overpressure level for explosion scenarios – typical pressure for glass failure (causes light injuries from fragments)
• Distance to 1 kW/m² thermal radiation level for fire scenarios – the threshold for pain from heat radiation is 1.5 kW/m².

Although emergency response plans are only required for upper tier establishments, the MEM Guidelines indicate that consequence modelling to the above endpoints is to be provided to emergency response authorities for both lower and upper tier establishments. These endpoints are extremely conservative and represent neither fatal nor serious injury consequences. Operators have concerns regarding public perception, in the event that mapping showing consequence contours representing the above endpoints is made available to the public. As the external emergency planning process is managed by emergency response authorities, the public consultation and communications process is not within the control of operators.

Another concern is the limitations of consequence modelling software in determining distances to these extremely low consequence levels. For example, assuming a pressurised release from a 1 tonne chlorine drum through a 10mm hole, the distance to the AEGL-2 (equivalent to reversible health effects) is over 7km. The software used does not have the capability to determine the distance to the AEGL-1. Therefore, publicly publishing data on distances to consequence endpoints that do not represent a real hazard to human health or that can be accurately verified is a significant concern for operators.

Public information/Confidentiality

The MEM Guidance Document recommends that the LCA request a hard copy of the Safety Report from the operator and any maps that they might need in digital format which poses a confidentiality concern.

Some requirements of the Emergency Services Pre Incident Planning Form in Appendix C also pose possible confidentiality risks:

• delivery information of Hazardous materials;
• biological, radiological and machinery hazards (Subjects not covered by CoMAH); and
• CAS numbers of hazardous materials.

Operators have concerns regarding the disclosure of information that is not only commercially confidential, but could pose a security risk. The MEM Guidance document doesn't detail how such information would be managed and the circumstances under which it would be made available to the public.

Contact: fergal.callaghan@awnconsulting.com