- Site: Springfields
- IR number: 21-135
- Date: November 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
To confirm the adequacy of the management of conventional health and safety hazards at Springfields Fuels Limited (SFL). In particular to examine compliance with the Control of Major Accident Hazards Regulations 2015 (COMAH).
The inspection visit was conducted together with the Environment Agency as part of the COMAH Competent Authority (CA), to assess asset integrity management of hydrofluoric acid (HF) storage vessels and transfer pipelines. The CA also took the opportunity to provide the dutyholder with advice regarding the COMAH safety report (SR) preparation and submission.
Interventions Carried Out by ONR
A remote interaction was followed by an inspection on the site.
The key activities undertaken to judge compliance with the application of COMAH were as follows:
- Review of COMAH asset integrity management arrangements, in relation to HF storage plant and pipeline transfer.
- Site inspection of HF storage vessels, transfer pipeline and support structures.
- Provide the dutyholder with an overview of SR preparation processes.
Explanation of Judgement if Safety System Not Judged to be Adequate
N/A
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Based on the aspects examined the CA was satisfied that HF tanks and pipes are fit for purpose and meet relevant good practice; that these items undergo appropriate examination, inspection, maintenance, testing and that responsible staff are suitably qualified and experienced personnel. The CA was satisfied that HF pipeline shortfalls identified by SFL are being addressed.
Overall, within the areas sampled the CA established that major accident hazards associated with loss of containment are being adequately controlled.
The CA offered the following advice during the inspection:
- The dutyholder should assure itself that older tanks, where design information may be scarce, are still fit for purpose and risk is as low as reasonably practicable (ALARP).
- SFL should ensure that lifting equipment is stored in accordance with their arrangements and lifting beams are marked with the safe working load.
- SFL should repair the rip at the base of the HF splash curtain or alternatively install a replacement.
- SFL should ensure that worn labels are replaced before they become illegible.
- SFL should more closely manage actions to a timely conclusion where these actions offer improvements and strengthen ALARP justifications.
During the walk down, CA identified staff were operating two computer-based process control systems within the tank farm control room. CA considered this arrangement to be in need of improvement and informed the dutyholder.
CA took the opportunity to provide the dutyholder with information regarding the COMAH safety report (SR) pre-receipt activities and agreed to timetable a discussion in early 2022 to address SR submission and pre-receipt in greater depth.
Conclusion of Intervention
Overall the arrangements were judged to be adequate, although some aspects were below the standard expected. The dutyholder undertook to address these matters, which will be followed up in future inspections.