hpl-Umwelt-Consult GmbH UNECE-Seminar 8.-9. · PDF fileGeorgswerder landfill - dioxin contamination of the oily phase of the site leachate) This problem arose by ... hpl-Umwelt-Consult

UNECE-Seminar 8.-9. November 2011 in Bonnhpl-Umwelt-Consult GmbH 1

Prof. Dr.-Ing. Hans-Peter Lühr


Sandoz - synonymous with a series of major chemical accidents:Feyzin (France) 1966, Flixborough (England) 1974, Seveso (Italy) 1976, Bhopal (India) 1984, Frankfurt-Höchst (Germany) 1993, Toulouse (France) 2001, Kolontar (Hungary) 2010.

25 years after “Sandoz” incident in 1986time to take stock and to define and discuss shortcomings

with regard to:� plant safety at chemical production sites and other facilities e.g. dams,� effectiveness of notification and information systems,� availability of disaster control measures,� implementation of after care measures for revitalization.


What happened?

1.November 1986fire broke out in a warehouse of Sandoz in Schweizerhalle (8 km above Basel city centre) situated directly to the Rhine.

About half a million people in the near vicinity of the factory escaped an inferno.

About 10 metres from the main site of the fire: chemicals such as sodium, acid chlorides and other water-sensitivematerials, which would have reacted explosively like bombs on contact with water from the sprinklers.

About 250 metres away Phosgene had been stored.


original purpose of the warehouse:storing machines and equipment (approval from 1977)

converted to a storage facility for various chemicals without installing any fire safety systems

Conclusion of the official investigation reportcause of the fire by an incorrect usage of a shrink gun while packaging pallets containing Prussian blue

smouldering.


warehouse contained about 90 chemical substances of 1.350 tonnesamong these 20 pesticides

water from the fire extinguishers washed about 30 to 40 tonnes of chemicals into the Rhine

no firewater containment barriers available

assumption during the fire by partial combustion - especially of plastics dioxins could result, which also enter the Rhine with the firewater.


Effects of the incident:

Fortunately no acute impact on human life.

But� undefined cocktail of toxic substances entered the Rhine� large scale fish mortality (over 100 tonnes of dead fish floated down the

river)� water fleas, fly larvae and water snails were completely destroyed� river sediment was contaminated for long stretches� contamination in the Rhine could be traced analytically right up to the

Netherlands� waterworks along the Rhine that obtained drinking water largely from

river bank filtrate had to shut down� drinking water supply was temporarily suspended

Overall ecological balance was severely disturbed


Environmental political situation at the time of the incident

� early 1970s entirely governed by a medium-based approach� after care measures, i.e. remediation and restoration � potential hazards emanating primarily from the chemicals industry were

either not recognised or were downplayed because overestimation of self-regenerating ability (ability of the substratum to decontaminate itself, self-purification ability of water bodies)

till mid 1970s entire length of Rhine was a sewer

No awareness about the magnitude and variety of chemical substances and productsAfter the occurrence of some major chemical accidents, e.g. Flixborough, Seveso and Sandoz as well as Chernobyl disaster chemicals were brought into the popular debate.

Slogans were Seveso is everywheresubstance of the month


From mid 1980sshift to the precautionary principle

This principle means

� to act in awareness of human fallibility

� to act on well-founded suspicions

� to reverse the burden of proof, not in the legal, but in a methodological sense. Who ever releases a substance/product into the environment must prove that it is harmless

� using the best technology to safely prevent any hazards for man or the environment

� to prevent as far as possible the spread or dilution of substances in the environment.

� conducting research to detect hazards as early as possible


Chemical industry didn’t learn its lessons in the 10 years after Seveso (1976). Aim was

� to review all existing safety measures within the “independent self responsibility approach”

� to forestall the legal machinery and the pressure for state intervention by voluntary agreements

Lobbying activities were focussed on adapting government regulations to the needs of the industry.

policy makersand

administration industry

irreconcilable

foes


This attitude can be documented by a paper of a reputed German chemicals manufacturer during this time

“The water authorities and/or police should be voluntarily inform edwhen the danger of water contamination cannot be prevented usingin-house means and also in cases where it can be prevented through in-house means but is visible to outsiders.”

However

� accidents lifted the veil from the dangers associated with chemicals production.

� problems could no longer be swept under the carpet

� European industrialised nations found themselves forced to adopt relevant legal regulations for protecting the environment


The Sandoz incident illustrates the importance of precautionary measures

No optimization of single elements,but as an overall concept.

Overall concept must

� encompass warehousing and other secondary facilities as an integral part of the production process

and� implement the same high level of safety standards for these facilities as for

the production process

Plant-specific safety concept must be planned around the hazard potential of substancesso as to prevent an uncontrolled material transfer from technical systems.

The Sandoz case is a negative example in this regard.


same time

soil and water contamination through contaminated sites (old landfills and

contaminated industrial sites) came into public focus (1983 Hamburg-Georgswerder landfill - dioxin contamination of the oily phase of the siteleachate)

This problem arose by

� single-wall construction technology of plants and plant components such as storage tanks, pipelines, reactors etc.

� underground placed installations

� built over of these installations as industrial production expanded and land was limited

Leakages remained undetectedresulting in large scale ground water contamination.


emission standard approach

� limiting emissions at source so that no harmful impacts can occur

� minimising required emissions for intended and unintended production operations

� sealing tightly technical systems that uncontrolled material transfer into the open cycle of the environment is impossible during intendedand unintended operations

precautionary principle

emission standard approach environmental quality approach


environmental quality approach

� countries closely linked to the sea through their waterways prefer this approach

� definition of quality standards for waters� intervention only when harmful impacts are visible or quality

standards exceeded

Basis for the demand of an integrated approach to environmental protection

manufacture of products intended for the marketandsolid, liquid, gaseous and energy wastesoriginating during production form one unit from a scientific, technical and legal perspective.


What are the Consequences?

European levelSeveso I Directive (after Bhopal disaster in 1984) was replaced with

the more stringently Seveso II Directive in 1996.

Main content� list of classified hazardous substances,� special requirements for companies possessing specified quantities of

such substances,� information to the public,� guidelines for official monitoring,� preparation of external and internal emergency plans.


special requirements

� The company/plant must be registered with the relevant official body.

� It must regularly prepare safety reports.

� It must have internal and external emergency plans.

� Adequate safety distance must be maintained from residential areas and nature reserves.

� The safety measures must be made public.

� Serious accidents must be notified as soon as possible and relevant measures must be adopted.

� The company must be monitored on a regular basis.

Another new feature of the Seveso II Directiveapplicable not only to specific facilities/installations, but for the entire operations of a company


integrated approach to the entire issue of plant safetyIPPC Directive 96/61/EC(Integrated Pollution Prevention and Control)

objective of the integrated concept

� prevention of emissions into the air, water and soil as far as possible

and

� reduction of emissions where prevention is not possible.

IPPC Directive based on Best Available Techniques (BAT)

Best Available Techniques compiled for each industry branchpublished inBREF notes


How to Configure the Conceptual Approach to an Effective Risk Management?

Plant includes all equipment necessary for � production process� all ancillary facilities such as

� storages of raw materials, � hazardous substances, � intermediate products, � final products, � solid wastes, � sewage treatment plant, � sewers, � pipelines for the transport of substances, � all transport facilities for the transport of materials,

intermediate products, final products and wastes


A secure plantmust be

both in theintended and not intended operation

� dense, stable and resistant against

mechanical, thermal and chemical effects.

� water-polluting substances must be quickly and reliably identifiedand retained. The same requirements are for fire-fighting water in case of fire.

Realization by a two-barrier conceptconsisting of technical and organizational elements

� first barrier: direct containment of substances at all facilities of a plant. (relevant for production process)

� second barrier: in case of accidents or incidents, which cannot be excluded or to avoide leakages.


Basic Principle of an Adaquate Security System

first barrier

Second barrier

� Two Barrier-Concept

� Controllability

� Repairability

Each plant can be lead back to this concept!


Consideration of entire substance flow from the entrance into the plant up to the outcome from the plant. Substance flow analysis through the entire plant: basic prerequisite for a secure plant

to ensure at every point of the plantfor each activity of a safe plant

Strategy of this concept: „zero emission“

Concept can be achieved by technology and organization at any time

� Question of socio-political consensus and economic costs

� All arising production-related emissionssuch as gaseous, liquid and solid wastes can be discharged to the corresponding media air and water and deposited in landfills according to the conditional approval of discharge conditions for the plant.


raw materialauxiliaries

storage- raw materialauxiliaries

storage- final products

final products

production

gaseous – liquid – solidwastes

interim storage

Sandoz-problem


Immission-oriented approachesregarding the requirements of a secure plant are irrelevant. They are important

� defining water quality

� deducing warning- and alarmplans

Requirementsbased in EU-countries on theWater Framework Directive (WFD) ,

which are based on an immission-oriented approach.

Objectives are concretized on definitions of thedesired state of the waters,in terms like„ good“.The definition„ good“ is immission-relatedand an Environmental Quality Standard (EQS)


Realisation of an active risk management„Safety Chain“

„Safety Chain“ include all essential fields of risk management.It is independent of

� water bodies

� political and regional responsibilities

� regions and regional groupings.

„Safety Chain“ is a logical model for the prevention and management ofchemical accidents. Can be used for

� required management plans and measure programs

� actions in the river and transboundary river basin institutions

� common platformfor the licensing and monitoring authorities andriver basin commissions, as well as for operators of plants.


Structure of the „Safety Chain“

Basic Preparation

Prevention Measures

Preparedness

Response

Damage Review

Follow up

Precautionary RiskManagement

Crisis Management

After CareManagement

Feedback


Lessons learnt?

� Organization Structures for Transboundary Risk Management

� Legal Instruments

� Risk Management within the UNECE


Organization Structures for Transboundary Risk Management

�International Commission for the Protection of the Rhine against Pollution (ICPR) (1963),

�Convention on the Protection of the Rhine against Chemical Pollution (1976),

�Rhine Action Programme (1987),

�Convention for the Protection of the Rhine (1999) signed by France, Germany, Luxemburg, the Netherlands, Switzerland and EU,

�International Commission for the Protection of the Elbe (ICPE) (1980),�International Commission for the Protection of the Oder (ICPO) (1996),

�International Commission for the Protection of the Danube (ICSD) (1998)

�International Commission for the Protection of the Moselle and theSaar (ICPMS) (1961)

�International Meuse Commission (IMK) (2002).


principles and aims

� precautionary principle,

� avoiding emissions at source,

� polluter-pays principle,

� principle of sustainable development,

� use and development of the state of the art (best available techniques) andbest environmental practice,

� no transferring environmental pollution fromone environment media toanother.


Wide spectrumof topics for preventing incidents and ensuring plant safety isundertaken by the different river-basin-commissions

� definition of „substances hazardous to water“,

� in-plant pipeline safety,

� joint storage,

� sealing systems in collecting chambers,

� transhipment of substances hazardous to water/transhipment points,

� fire protection strategy,

� plant monitoring,� internal alarmand hazard control planning,

� problemof fire-fighting water retention,

� basic requirements for plants handling substances hazardous to water,

� inventarisation of potential accidental risk spots

� and and ....


Legal Instruments

Basis Declaration of the United Nations Conference on the Human Environment (Stockholm Declaration), 1972

The Rio Declaration on Environment and Development(Rio Declaration), 1992

Convention on the transboundary effects of industrial accidents („Industrial Accidents Convention“), 1992

Convention of the protection and use of transboundary watercourses and international lakes („Water Convention“), 1992

for plant-based handling of environmentally harmful substances


EU region

European Commission issued a series of EU-directives protecting man and environment from potentially damaging industrial accidents

� Directive 96/82/EG „Control of Major-Accident Hazards “(Seveso II-Directive),

� Directive 2008/1/EG „Integrated Pollution Prevention and Control“(IPPC-Directive),

� Directive 85/337/EWG „Environmental Impact Assessment Directive“(EIA Directive),

� Directive 2000/60/EG „Water Framework Directive“ (WFD).


Basis of a general crisis managementfor water bodies by Article 11 (3) ofWater Framework Directive (WFD)

„ ...any measures required to prevent significant losses ofpollutantsfromtechnical installations and to prevent and/or to reducethe impact of accidental pollution incidents for example asa result offloods, including through systems to detect or give warning of such events, including in the case of accidents, which could not reasonablyhave been foreseen, all appropriate measures to reduce the risk toaquatic ecosystems.“


Risk Management within UNECE

Basis

1992: Convention on the transboundary effects of industrial accidents(„ Industrial Accidents Convention“ )

Convention of the protection and use of transboundary watercoursesand international lakes („Water-Convention“ )

First operative measures

1998: first joint workshop for both conventions (Berlin)

1999: second joint workshop (Hamburg)


Objectives and recommendations of the „99-workshop“

� technologies, including safety measures and technical standards, in orderto prevent transboundary water pollution through industrial accidents,

� early warning and alarmsystems, including networks of contact points, toenable speedy and effective response,

� notification procedures and mutual assistance in the event of an industrialaccident,

� methods for determining dangerous activities along transboundary rivers,

� promoting the exchange of safety equipment and further technologicaldevelopments,

� long-term work programme for improved safety equipment in hazardousplants (SEVESOII-plants).

“long-term”: 5 years for implementation in industrial countries

10 years for countries in transition


The Deficits

Analysis of International Warning and Emergency Plans (IWEP) expelsclear deficits.

A number of technical and organizational requirements andaffiliated measuresare in place,

but they are unequal in their precision and depthand not uniform in all organizational structures.

Lack of

� qualified personnel,

� availibility of adequate equipment,

� clear definition of responsibilities,

� information and communication among the relevant parties.



FACED IN THE WESTERN COUNTRIES1. Risk coming from shipping (discharges and accidents)

2. Risk of complacency in ensuring prevention and maintaining high level of safety at major industrial facilities

3. Micropollutant problem (pharmaceutical)

4. Definition of pollution (application of thresholds)

5. New chemical substances

6. Incompatibility of communication technology used

FACED IN THE EASTERN COUNTRIES1. Pollution from abandoned sites

2. Information exchange and notification between states: differences in procedures from state to state, different cultures and philosophies (communication problems)

3. Information to the public

4. Enforcement of procedures and safety standards

5. Early warning and emergency plans

6. Inventory of risk sources

7. Personnel capacity


Thank youfor

your attention.

Documents

hpl-Umwelt-Consult GmbH UNECE-Seminar 8.-9. · PDF fileGeorgswerder landfill - dioxin contamination of the oily phase of the site leachate) This problem arose by ... hpl-Umwelt-Consult