Application Made  to become a Lower Tier COMAH (Control Of Major Accidents and Hazards) - November 2002

In the Summer of 2002 we had begun a major review of our activities and how we may be affected by the changes to the COMAH limits for various substances, in particular those for fuel oils and waste oils.

As a result of this review we decided to apply to become a lower Tier site for the reasons as laid out below which were included in our submission to the competent authorities:

Dear Sirs,

We are writing to inform you that due to a recent review of our inventory of substances we now believe that this site will be covered by the lower tier category of the COMAH Regulations.

 Enclosed is the tank usage document that we used to calculate our aggregation, which as a result of the revised inventory has risen from 0.966 to 1.331, hence bringing us into lower tier COMAH Regulations.

 We have considered the possible implications of waste oil being categorised R50, however, based on the information provided by our trade association, we believe the threshold for upper tier notification for R50 is 25000 tonnes.   We are well below this limit, but possibly above the lower tier limit of 2500 tonnes.   Even so, we are notifying based on an aggregation score of greater than 1 for flammable, and highly flammable substances.

 We anticipate that our MAPP and safety management description will be completed by 31/12/02, and hope that submission by this date will be adequate.

 Information required in a notification, as required by regulation 6(1), as described in schedule 3 of the COMAH regulations follows;

 Name and address of operator
Chemical Recoveries, Smoke Lane, Avonmouth, Bristol, BS11 0YA.

Address of establishment concerned
As above.

Name or position of the person in charge of the establishment
Mr Nicholas Roads, Managing Director.

 Information sufficient to identify the dangerous substances or category of dangerous substances present –
See enclosed document entitled ‘Chemical Recoveries Avonmouth Tank Usage/COMAH volumes’. (not available online)

Quantity and physical form of the dangerous substances present – 4792.8 tonnes of liquids. 

Description of activity – Storage and treatment of waste solvents oils, and water.

 Details of the elements of the immediate environment liable to cause a major accident or to aggregate consequences thereof – proximity to upper tier COMAH site