PSLG and COMAH Compliance
Cost-Effective Risk Management
Ensuring compliance with the developing standards for the storage of bulk liquids is the key challenge in the coming years for the oil refining and storage industry according to one of the sector’s leading consultancies.
The environmental implications of the Control of Major Accident Hazard (COMAH) Containment Policy and PSLG Final Report are a vital area which operators must address. Since the Buncefield explosion, the focus on safety and, in particular, the effective containment of hazardous materials has understandably intensified.
IKM has helped operators in the north of England and Scotland to prepare detailed appraisals of their facilities, with a key focus on the environmental setting. At each facility, this process began with a gap analysis, to ensure use of all available existing study work, followed by a site topographic survey to provide the bare data for capacity calculations, bund stability and overlapping modelling. Release scenarios were then modelled using Computational Fluid Dynamic (CFD) software to predict overlapping volumes and hydrodynamic forces on bund walls. Stability of bunds to forces was assessed using finite element modelling. Sophisticated risk-based fate and transport modelling was also undertaken, for both overland and below ground oil migration.
IKM has also developed a bespoke bund visual inspection guide for operators to use to assess bund condition and develop maintenance of improvement programmes. Such assessments have been used by various parties to inform the design of: tank foundations, below tanks detection systems, bund upgrades, requirements for bund liners and tertiary containment, as operators have reviewed the necessary upgrades to their storage facilities to achieve compliance.
Our objective, wherever possible, is to help the operators to understand their environmental risk and to develop cost effective ways for them to achieve compliance. IKM, through detailed analysis, can inform the operator of their level of risk to ground and surface waters in the event of tank failure, and provide detailed information for the operator to discuss alternative means of compliance with the regulator.
Our approach uses a multi-disciplinary team with much hands on experience of petrochemical facilities; a detailed understanding of the guidelines; a thorough examination of the site setting, including: geology, hydrogeology, historical records, topography, the range and integrity of existing containment measures, preferential pathways, potential failure scenarios and their direct and predicted impacts on the environment.
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