Prepared by WG Environment

ENL N 8

ENVIRONMENTAL INCIDENTS

1 INTRODUCTION
In this newsletter we are providing examples of what an environmental incident is and providing a summary of the reasons for reporting environmental incidents as a reminder to EIGA members to report environmental incidents both internally and to EIGA. Environment means the air, water, soil, flora and fauna and/or nuisance to the communities surrounding our plants.

2 SUMMARY
Prevention of environmental incidents is of increasing importance to EIGA members. Although we are a in a clean industry relative to some there are still simple steps we can take to eliminate these incidents and guard against the possible consequences. EIGA member companies should have a system of reporting environmental incidents within their own companies, according to the guidelines below. All incidents should be investigated and corrective actions put in place so as to have continual improvement as part of a good environmental management system. Any environmental incidents that are relevant to Gas Company activities should be reported through to EIGA so that lessons can be learnt for the whole industry.

3 WHAT IS AN ENVIRONMENTAL INCIDENT ?

Environmental incidents Incidents which involve the planned or unplanned releases of substances from our plant and equipment that could be environmentally harmful to air, water, and/or land, including both noise and radiation and the discovery of historical contamination that has the potential for impacting nearby sites. These could also result in breaches of plant permits or complaints of nuisance from our neighbours as well as environmental damage. Some general examples include: The leaking of oil from an above ground tank over several years causing soil and groundwater contamination. Nuisance from industrial fires.
EUROPEAN INDUSTRIAL GASES ASSOCIATION

AVENUE DES ARTS 3 5 B-1210 BRUSSELS PHONE +32 2 217 70 98 FAX + 32 2 219 85 14 E-mail : info@eiga.org

Some examples specific to the gas industry include: The accidental release of lime from an acetylene plant to a river killing fish and other river life. The release to air of ammonia from an air separation unit plant chiller, during maintenance. The accidental discharge of hydrogen fluoride from a cylinder causing damage to trees and plants in the surrounding area. The release of phosphine from a lime pit resulting in complaints from neighbouring residents. The discovery of an acetone plume from an underground tank, in the groundwater under a site that is impacting a nearby drinking water well.

It is sometimes difficult to decide if release incidents are significant or not because the concentration of the releases and the environmental impact may not be known. However all releases with the potential for environmental impact or off site nuisance should be reported as lessons can still be learnt from these near misses.

4 WHY ARE THESE INCIDENTS IMPORTANT?

4.1 For internal Company reporting

It is particularly important that environmental accidents and incidents are covered within a reporting system since many such incidents have potentially serious consequences for EIGA member companies such as Potential claims for civil liability Adverse publicity and public reactions Actual environmental damage and associated clean up costs Prosecution from the authorities. The reporting of environmental incidents is an essential part of any companies environmental management system. This is because it means that lessons are learnt from the incidents to improve the environmental controls and prevent reoccurrence.

4.2

For reporting to EIGA

EIGA actively promotes high standards of safety and environmental protection and in this regard one of the objectives of EIGA is the sharing of accident information and the publishing of appropriate corrective recommendations. Many lessons can be learned from such incident and accident reports, which remain entirely confidential and anonymous. These lessons can be used to prevent similar events recurring and thereby prevent injury, environmental damage and other loss to EIGA member companies.

5 RECOMMENDATIONS ON REPORTING SYSTEMS

5.1 For internal Company reporting

Internal reporting systems must cover the following essential elements What is to be reported a description of what is an environmental incident Who to report the incident to this can involve a chain of command in a large organization Who to get immediate help from - this should be part of the company emergency response system Guidelines on investigation and root cause analysis

EUROPEAN INDUSTRIAL GASES ASSOCIATION

AVENUE DES ARTS 3 5 B-1210 BRUSSELS PHONE +32 2 217 70 98 FAX + 32 2 219 85 14 E-mail : info@eiga.org

5.2

For reporting to EIGA

All EIGA members are encouraged to report both actual and potential safety and environmental incidents and accidents using the reporting format developed by EIGA Safety Advisory Group (SAG). These reports are handled on a confidential basis and added to the EIGA accident database. The importance of reporting both safety and environmental incidents and accidents through their company representative to SAG can not be over emphasised. Members are also encouraged to provide any examples of incidents and accidents that relate to the use of industrial or speciality gas by a non-EIGA member company from which lessons could be learned. Lessons from these incidents are then used to develop the guidelines and best practices published by EIGA WG-5.

6 PREVENTIVE MEASURES
Some generic preventive measures that EIGA member companies should take to protect against such incidents, as part of an environmental management systems approach are Attention to design and modifications of equipment; Care in storage and handling of oil and chemicals; Improved maintenance of plant and equipment; Training and awareness of environmental issues for operating staff; Emergency response planning to incidents.

The EIGA Code of Practice Environmental Management gives more details regarding good environmental practices and how environmental incidents can be avoided.

7 EXAMPLE INCIDENTS
7.1 OIL

All Industrial Gases sites use oil or diesel for operation, heating and transportation. The storage and use of these oils represents a major environmental hazard as it only takes one litre of oil, evenly dispersed, to contaminate 1 million litres of water. Incidents reported to WG-5 include the ones described below and many similar. 1. In one incident 50000 litres of fuel oil escaped from a bunded storage tank when a plastic connection to a level gauge failed. There was a concealed hole in the bund, which was adjacent to a drain. As a result a nearby watercourse was badly polluted and fines of over 20000 were levied. 2. In another case a spill of 2000 litres of heating oil resulted from failure to properly control filling procedures, this resulted in clean up costs of over 10000. If the oil had entered the nearby canal the consequences would have been much more serious. 3. A third incident involved in oil entering a storm drain due to re-routing of the drainage system. Again substantial fines and clean up costs were the result. These events give us the following messages Filling procedures need to be tightly controlled and supervised Storage of oil requires adequate bunding and maintenance of the bunding

EUROPEAN INDUSTRIAL GASES ASSOCIATION

AVENUE DES ARTS 3 5 B-1210 BRUSSELS PHONE +32 2 217 70 98 FAX + 32 2 219 85 14 E-mail : info@eiga.org

The layout of the drains needs to be planned for each site so that oil can not enter surface water Emergency planning must consider environmentally harmful events such as oil spills, as well as safety incidents.

7.2

LIME

Limewater is a by-product of acetylene production. Whilst it can be used in many beneficial applications, and even as a fertilizer, uncontrolled releases can still cause damage to the environment. Examples include Acetylene plant had been closed down - lime tanks were full and the anti-siphoning arrangement out of action with the manual shut-off valve open. Lime siphoned from the tanks and filled the pit. During the clean up, lime was led into storm drain, causing stream pollution that resulted in fish kill and a fine of over 20000. The lessons learn include Operators to have correct training for the equipment All equipment must be well maintained and in good condition.

7.3

GAS RELEASES

Release of chlorine from reaction between sulphuric acid and sodium hyperchlorite. Acid sprayed from cooling water chemical dosing pump. Escape of ammonia from refrigeration plant. Gas detector not wired in - 3 workers collapsed and taken to hospital. No emergency evacuation plan in place for gas leaks.

7.4

NUISANCE

A large quantity of perlite was released and spread to surrounding houses when an ASU cold box was over pressured. Due to a communication problem a leaking joint was not identified and restart of the plant cause the box to overpressure. Complaints of odours from acetylene factory.

Feedback
EIGA WG-5 members welcome feedback on this and other publications. If you need any more information or would like to make any comments please contact your WG-5 representative, the WG-5 Chairman or the EIGA office. Stephen Bradley, Air Products PLC Chairman WG-5; Telephone +44 1932 24 9992; Fax+ 44 1932 24 9271; e-mail: bradlesc@apci.com

All technical publications of EIGA or under EIGAs name, including Codes of practice, Safety procedures and any other technical information contained in such publications were obtained from sources believed to be reliable and are based on technical information and experience currently available from members of EIGA and others at the date of their issuance. While EIGA recommends reference to or use of its publications by its members, such reference to or use of EIGAs publications by its members or third parties are purely voluntary and not binding. Therefore, EIGA or its members make no guarantee of the results and assume no liability or responsibility in connection with the reference to or use of information or suggestions contained in EIGAs publications. EIGA has no control whatsoever as regards, performance or non performance, misinterpretation, proper or improper use of any information or suggestions contained in EIGAs publications by any person or entity (including EIGA members) and EIGA expressly disclaims any liability in connection thereto. EIGAs publications are subject to periodic review and users are cautioned to obtain the latest edition.

EUROPEAN INDUSTRIAL GASES ASSOCIATION

AVENUE DES ARTS 3 5 B-1210 BRUSSELS PHONE +32 2 217 70 98 FAX + 32 2 219 85 14 E-mail : info@eiga.org