H1 Annex A – Amenity & accident
risk from installations and waste
activities
Published by:
Environment Agency
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Bristol BS1 5AH
Tel: 0117 934 4000
Email: [email protected]
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GEHO0410BSIG-E-E v2.1
Annex A Amenity & accident risk from installations and
waste activities
This guide gives advice on assessing the risk arising from
accidents and amenities on installations and waste sites
when applying for a bespoke permit under the
Environmental Permitting Regulations.
It is part of the Environment Agency’s H1 Environmental
Risk Assessment Framework and should be read in
conjunction with the H1 Environmental Risk Assessment –
Overview guide to understand who needs to use it and how
it fits in to the framework.
Content
Introduction .................................................................................................................................... 3
Overview ...........................................................................................................................3
What steps are you taking to manage risks? ....................................................................4
What are the chances of causing harm?...........................................................................4
How serious could the harm be?.......................................................................................5
What is the overall risk? ....................................................................................................5
Identify what you could harm ............................................................................................5
Odour............................................................................................................................................... 8
Noise and vibration........................................................................................................................ 9
Fugitive emissions....................................................................................................................... 10
Visible Plumes.............................................................................................................................. 13
Accidents ...................................................................................................................................... 16
What you should do next.................................................................................................18
.
H1 Annex A Accident Risk installations & waste
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1
Summary of changes
Below is a summary of changes made to this Annex since the launch in April 2010.
Annex
version
Date
Changes
Template
version
Issue 2.1
December
2011
Introduction of a module for risk
assessment of visible plumes.
H1 April 2011
Improved clarity of examples within
the amenities table of risk.
Simplifying the introduction and
reformatting the document in
response to the 2010 H1 public
consultation.
Taking account of the impact of the
Waste Hierarchy1.
Reference to the Environment
Agency’s emerging Noise
Screening tool.
1
http://www.environment-agency.gov.uk/static/documents/Business/Waste_Hierarchy.pdf
H1 Annex A Accident Risk installations & waste
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Introduction
Introduction
This guide on assessing amenity and accident risks is a part of the Environment Agency’s
H1 Environmental Risk Assessment framework as described in the H1 Overview 2
document. It is aimed at:
•
installations
•
waste operations other than landfills. (For Landfills see Annex i).
You should check regulatory guidance notes3 if your are unsure whether you fall into one
of these categories.
You should follow this guide if:
•
you are applying for a permit under the Environmental Permitting Regulations
for either an installation or a waste operation
•
you need to carry out a bespoke risk assessment
•
you are working through H1 Environmental Risk Assessment
•
you have been advised to assess amenity risks (odour, noise, fugitive
emissions) and accidents from your activity
You should not work through this guidance without first reading through H1 Environmental
Risk Assessment – Overview to see how it fits in to the risk assessment process for
permit applications and carrying out the necessary preliminary steps.
Overview
H1 Environmental Risk Assessment – Overview gives a four-step process for assessing
your activity:
1.
identify risks from your activity
2.
complete risk assessments for these
3.
choose appropriate measure to control these (if needed)
4.
present your assessment.
This guide is an annex to Step 2. It will help you identify people or parts of the
environment that could be harmed by your activity and to carry out risk assessments for:
2
3
•
odour
•
noise and vibration
•
fugitive emissions (including dust and pests)
•
visible plumes
Available via the Environment Agency website.
http://www.environment-agency.gov.uk/business/topics/permitting/36419.aspx
H1 Annex A Accident Risk installations & waste
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3
•
accidents.
You will need to complete each of these sections unless you can show that they are not
relevant to you. The actual assessments are fairly straightforward and give you tables to
complete for your activity. When you fill these in, you will need to think about:
•
the steps you are taking to manage risks
•
the chances of causing harm
•
how serious that harm could be.
The rest of this introduction explains how you can use these factors to work out what risk
your activity presents to the environment.
What steps are you taking to manage risks?
You should put in place control measures to make sure that there are no significant risks
from your activity and bear these in mind when you complete the assessment.
We expect that the steps you take to protect the environment will normally be those
identified in the guidance documents set out in Table 1.1 (note that not all these will be
applicable to your activity).
Table 1.1 – Measures you should take to protect the environment
Hazard
Basic Guidance
Other guidance
Odour
How to Comply with your
4
environmental permit with
particular reference, where
relevant, to Part 3 of that
document.
H45 – odour – Annex on odour
management plan
Noise
Fugitive emissions*
H36 – Noise – Annex on noise
management plan
Visible plumes
Accidents
* Fugitive emissions are uncontrolled hazards associated with an activity such as vapours, dust,
litter, pests, vermin.
The risk assessments will ask you to list the measures you propose to employ for each
hazard from your activity. You should also identify the guidance you have based these
measures on.
What are the chances of causing harm?
When thinking about the chances of your activity causing harm, you should think about
how you propose to operate. For example the chances of a dust problem are lower if you
4
http://publications.environment-agency.gov.uk/pdf/GEHO0411BTSP-e-e.pdf
http://publications.environment-agency.gov.uk/PDF/GEHO0411BTQM-E-E.pdf
6
http://publications.environment-agency.gov.uk/PDF/GEHO0411BTQM-E-E.pdf
5
H1 Annex A Accident Risk installations & waste
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operate indoors, keep doors closed and use water sprays to keep the dust down. You
should also describe the chances of a problem if things go wrong, for example if your
water or power is cut off.
You must not be too optimistic about how effective your risk management measures will
be and your assessment must reflect our professional experience of how effective
measures are. We may ask you to go back to your assessment if we think you have not
accurately reflected the chance of there being a problem.
How serious could the harm be?
The severity of harm from a risk depends on:
•
how much a person or part of the environment is exposed
•
how sensitive a person or part of the environment is.
Some parts of the environment can be very sensitive. For example, fish and aquatic
insects can be harmed by even the slightest exposure to certain chemicals.
What is the overall risk?
The level of risk is a combination of:
•
how likely a problem is to occur
•
how serious the harm might be.
Risk is highest where both the likelihood of a problem is high and the potential harm is
severe. Risk is lowest where a problem is unlikely to occur and the harm that might result
is not serious.
Identify what you could harm
The first step is to think about how your activity could harm the environment. You need to
think about what is around your site that could be affected by your activities. We call
these “receptors” and they can be people, property, and the natural and physical
environment.
You must list everything that is around your site that could be harmed by what you are
doing or propose to do. Only look for receptors that could be near your site and could
reasonably be affected by your activities.
Table 1.2 lists common receptors and tells you how to find out if they are near your site.
The websites listed in Table 1.2 are easy to use and many will just ask you for your site’s
postcode to work out what is nearby.
There are also a number of websites that will show you satellite pictures of your site and
the surroundings. These can be useful but remember that the pictures may be several
years old. You should include the date of any pictures that you use.
H1 Annex A Accident Risk installations & waste
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5
Provide a scale plan showing your site layout and all nearby receptors (houses, schools,
rivers etc). This should have a big enough range to show any receptors that you might
affect. Where possible also show the location of any hazards on your site that may
present a risk to these receptors. Not all hazards will have a specific location on your site,
but where they do please show them on the plan.
When you have identified the receptors around your site, you should carry out an
assessment for each risk from your activity.
Table 1.2 – Sources of information on common receptors
Type of receptor
Where you can get information
Specially protected nature conservation sites.
Nationally designated sites (e.g. Ramsar, SAC,
SPA, SSSI, LNR, AONB, National Park etc. –
you don’t need to know what these stand for at
this stage only if there are any of these sites
around your site)
www.magic.gov.uk/
www.jncc.gov.uk/
Local nature conservation sites (e.g. County
Wildlife Sites, Local Wildlife sites)
Local Wildlife Trusts
Do you know of any protected nature
conservation species near your site, e.g. native
crayfish or otter? If so, please tell us.
Local Records Centre
Single houses or groups of houses (estates,
villages etc)
OS map of the local area
Schools, hospitals, factories, shops etc.
OS map of the local area
Footpaths, recreation areas such as playing
fields and playgrounds
OS map of the local area
Fields and allotments used for growing food
OS map of the local area (and some
local knowledge)
Waterbodies (rivers, lakes, streams and ponds)
OS map of the local area
Ancient woodland
Natural England ancient woodland
inventory www. natural england.org.uk
and www.magic.gov.uk/
Designated landscape sites (e.g. AONB,
National Parks, Heritage Coast etc)
www.magic.gov.uk/
Historic buildings, listed buildings,
archaeological sites (e.g. Scheduled Ancient
Monuments, Battlefields, Listed Parks and
Gardens)
Local planning authority for listed
buildings, Institute of historic building
conservation (www.ihbc.org.uk), The
National Trust, County Archaeologist
(local county council)
Local geological sites (e.g. RIGGS sites)
Local Authority, Local RIGGS group
Water abstraction points
Environment Agency website
H1 Annex A Accident Risk installations & waste
Local Authority
Local Wildlife Trust
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6
Type of receptor
Where you can get information
(www.environment-agency.gov.uk)
Local Authority environmental health
departments for private water supplies
Groundwater beneath your site, particularly
sensitive groundwater catchments e.g. source
protection zones
Environment Agency website
(www.environment-agency.gov.uk)
Other nearby industry e.g. Control of Major
Accident Hazards (COMAH) sites
Environment Agency website
(www.environment-agency.gov.uk),
local HSE office (www.hse.gov.uk)
Sensitive land uses – e.g. commercial fish
farms, farmland
Ordnance Survey Map, local
Environment Agency office,
Environment Agency website
(www.environment-agency.gov.uk)
Coastal/estuarine areas
Local contingency plans, coastal atlases
Drainage systems/sewers
Local water companies – for example
Anglian Water, Thames Water etc.
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Odour
Please list each possible odour source in a separate row in Table 1. This should include any activities you propose to do, or any wastes or
substances that you will deal with at your site that could cause a smell. Refer to the 'Introduction' within 'How to comply'7 for more information on
Odour assessments. You should then complete the rest of Table 1. Where risk management techniques prove ineffective, with the likelihood of
complaints to the Environment Agency, the operator may be required to submit an Odour Management Plan, for implementation in agreement
with the regulator – see H4.
Table 1 – Assessment of odour risks
Hazard
What has the
potential to cause
harm?
Receptor
Pathway
What is at risk?
What do I wish
to protect?
How can the
hazard get to the
receptor?
Risk management
What measures will you take to reduce the risk?
If it occurs who is responsible for what?
Probability of
exposure
How likely is this
contact?
Consequence
What is the harm that
can be caused?
There are no
possible sources of
odour at the site.
What is the
overall risk?
What is the risk that
still remains? The
balance of probability
and consequence.
None.
Smell from
composting
windrows out the
back of the
reception shed.
Thorpe village
800 m to the
south.
Air - Northerly
winds or lengthy
periods of calm.
May occur for 15
days/yr (Met
Office stats
attached).
Measures as described in How to comply and the
Industry code of practice. Only turning activities will
cause a problem at this distance. We will not do this
with these weather conditions.
Fairly probable.
Odour annoyance will
have more impact in
summer when people
are outdoors and
temperatures are higher.
Perhaps 12 days/yr.
Consequence medium.
Not significant if
carefully managed.
Failure of scrubber
liquor pumps due to
power failure.
Trading Estate
retail units
200m to the
north.
Air
If it occurs, instigate process shutdown procedure (30
minutes).
Power failure has
occurred once in the
last 5 years.
Unabated odorous offgas to atmosphere. But
for less than 30 minutes.
Not significant.
Inversion conditions
preventing
dispersion from
stack.
Community to
the east on
hillside.
Air
Inversion conditions
happen once or twice
per year. May fail to
predict occasionally.
Very noticeable smell
but for very short
duration until shut down
occurs.
Not significant.
7
Advise regulator by telephone immediately 0800
807060 (24 hour service).
On site weather station with logging facility. Daily
weather forecast received from Met office.
If it occurs, finish current batch but reduce temperature
if possible. Hold further batches of Product X. Product
Y can be run on reduced temperature.
http://publications.environment-agency.gov.uk/PDF/GEHO0411BTSP-E-E.pdf
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Noise and vibration
Please list each possible source of noise or vibration in a separate row in Table 2. This should include any activities you propose to do at your
site that might produce:
•
a noise or vibration that could be heard beyond the boundary of your site
•
a vibration that could be felt beyond the boundary of your site.
You should identify each source of the noise or vibration as either fixed or mobile (for example vehicle reverse-warning noise).
Refer to the 'Introduction' within 'How to comply' for more information on noise and vibration assessments.
You should then complete the rest of Table 2. Any residual risk identified as being more than ‘Insignificant’ may need to be processed through
the Environment Agency’s Noise Screening Tool. Where risk management techniques prove ineffective, with the likelihood of complaints to the
Environment Agency, the operator may be required to submit a Noise Management Plan, for implementation in agreement with the regulator see H3.
Table 2 – Assessment of noise and vibration risks
Hazard
Receptor
What has the
potential to cause
harm?
What is at risk?
What do I wish to
protect?
Pathway
How can the
hazard get to the
receptor?
Risk management
What measures will you take to reduce the
risk?
Probability of
exposure
How likely is this contact?
Consequence
What is the harm that
can be caused?
If it occurs – who is responsible for what?
There are no
possible sources
of noise from the
activities.
Engine noise from
loading shovel,
from reverse
warnings.
Noise from baling
machinery at the
back of storage
area 3.
What is the
overall risk?
What is the risk that still
remains? The balance of
probability and
consequence.
None.
List nearby
receptors
Site is close
enough for noise
to be audible
For example, closing doors, visual inspections,
routine maintenance through to withdrawing
machinery from service or stopping the activity
altogether.
Frequency - Include day
or night, weekday or
weekend exposure.
intermittent or continuous.
If immediate action cannot be taken the
reasons should be noted. Record and act on
complaints, inform the regulator.
H1 Annex A Accident Risk installations & waste
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Include likely duration,
noise level or increase in
noise level (at source or
receptor) and any
characteristics.
Low if management
techniques are effective.
Fugitive emissions
Please list each possible source of fugitive emissions in a separate row in Table 3. This should include any activities you propose to do at your
site that might produce:
•
releases to air, such as from storage of raw materials or wastes and evaporating volatile organic compounds (VOCs)
•
dust
•
releases to water and land, such as potential leaks or spills from the storage or handling of liquids that could harm the environment
•
uncollected run-off from operational and storage areas
•
possible sources of wind-blown litter
•
mud that could get off the site
•
pests that could get off site, such as vermin or flies.
Refer to 'Emissions of substances not controlled by emission limits' within 'How to comply' 8 for more information on fugitive emissions. You
should then complete the rest of Table 3. Where risk management techniques prove ineffective, with the likelihood of complaints to the
Environment Agency, the operator may be required to submit an Emissions Management Plan, for implementation in agreement with the
regulator.
8
http://publications.environment-agency.gov.uk/PDF/GEHO0411BTSP-E-E.pdf
H1 Annex A Accident Risk installations & waste
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Table 3 – Assessment of fugitive emission risks
Hazard
What has the potential
to cause harm?
Receptor
Pathway
Risk management
What is at risk?
What do I wish to
protect?
How can the
hazard get to the
receptor?
What measures will you take to reduce the
risk?
People living at
Land End
Cottage R1 –
400m east of the
site
Wind blown dust
The following technical guidance actions will
be taken to reduce the dust [list].
Probability of
exposure
Consequence
What is the
overall risk?
How likely is this contact?
What is the harm that
can be caused?
What is the risk that
still remains? The
balance of probability
and consequence
Dust could potentially
reach the dwelling when a
strong wind blows in that
direction which it could for
perhaps 50 days a year.
The management actions
should prevent this
happening.
Nuisance - dust on
cars, clothing etc.
Not significant.
If it occurs – who is responsible for what?
To Air
Dust from screening
plant 3.
Visual dust monitoring in accordance with local
operating procedure.
Shift manager is responsible for checking wind
strength and direction and stopping operations
if needed.
VOCs from pipework.
Local residents
or school beyond
the boundary of
the activity.
Vapours carried
on the wind.
Potential sources of fugitive emissions are
identified and then included within a routine
maintenance programme. Low boiling solvents
may be a priority.
Fugitive vapours could
reach sensitive receptors,
but appropriate
management actions
should prevent this from
happening.
Complaints of
odours/smells in
vicinity of local
receptors.
Low if management
techniques are
effective.
Local surface
waters or
groundwaters.
Flow by gravity.
Demolition waste stockpile should be held on
an impermeable surface or within a contained
area with suitable capture of any contained
pollutants before release.
Unchecked, run-off could
reach sensitive receptor,
but management actions
should prevent this
happening.
Pollution of local
surface or
groundwater.
Low if management
techniques are
effective.
Local residents
or school beyond
the boundary of
the activity.
Airborne
transportation.
Isolation and securing/removal of wastes that
are attracting scavengers. regular inspections
by nominated personnel
Wastes left unattended
could result in problems
off—site.
Potential for the
spreading of disease
and adverse health
impacts on vulnerable
people..
Low if management
techniques are
effective.
To water
Run off from the
demolition waste
stockpile.
Pests
Flies on farmyard
manure could move offsite and affect nearby
residents
H1 Annex A Accident Risk installations & waste
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Hazard
Receptor
Pathway
Risk management
Probability of
exposure
Consequence
Without appropriate
barriers installed airborne
materials could reach
sensitive receptors.
Likelihood of
complaints where
appropriate techniques
are not adopted and
maintained.
What is the
overall risk?
Mud/Litter
Litter from paper bale
storage area.
Local residents
or school beyond
the boundary of
the activity.
Airborne
transportation.
H1 Annex A Accident Risk installations & waste
Keep operations within enclosed buildings.
Where not possible, erect litter fences around
the site to capture any potential airbourne
materials.
v 2.1 December 2011
12
Low if management
techniques are
effective.
Visible Plumes
Please list each possible source of visible plume in a separate row in Table 4. For example:
•
condensation or visibility of combustion process gases released to air,
•
condensation of cooling tower vapours,
•
condensation of other process vapours
Refer to 'Emissions to air, water and land' within 'How to comply'9 for more information on visible plumes.
You should then complete the rest of Table 4.
9
See link: http://publications.environment-agency.gov.uk/PDF/GEHO0411BTSP-E-E.pdf
H1 Annex A Accident Risk installations & waste
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Table 4 – Assessment of visible plume risks
Hazard
What has the potential to
cause harm?
Receptor
Pathway
What is at risk?
What do I wish to
protect?
How can the
hazard get
to the
receptor?
Risk management
What measures will you take to reduce
the risk?
Probability of
exposure
How likely is this contact?
Consequence
What is the harm
that can
If it occurs – who is responsible for what?
be caused?
What is the
overall
risk?
What is the risk that
remains?
The balance of
probability and
consequence.
To Air
There are no visible impacts
beyond the site boundary, or
there are no sensitive
receptors due to the
remoteness of the location.
Screened out no further
assessment
required.
Regular small impact from
operation of listed activity.
Plume length exceeds site
boundary for <5% of
daylight hours per year.
No local
sensitive
receptors.
Dispersion
by wind
e.g. Maximising heat transfer within the
combustion activity.
Make regular observations
over a suitable time period
including a variety of
meteorological conditions.
Nuisance – reduced
Insignificant visibility, could
be important depending upon
site location and proximity to
main travel routes or
sensitive receptors.
Regular small impact from
operation of listed activity.
Plume length exceeds site
boundary for <5% of
daylight hours per year.
Sensitive local
receptors.
Dispersion
by wind
e.g. Maximising heat transfer within the
combustion activity.
Make regular observations
over a suitable time period
including a variety of
meteorological conditions.
Nuisance – reduced Low
visibility, could be important
depending upon site location
and proximity to main travel
routes or sensitive receptors.
Low
Regular large impact from
operation of listed activity.
Plume length exceeds site
boundary for >5% of
daylight hours per year.
Sensitive local
receptors.
Dispersion
by wind
e.g. Reducing pollutant emissions
consistent with the application of Best
Available Techniques.
Make regular observations
over a suitable time period
including a variety of
meteorological conditions.
Nuisance - reduced Medium
visibility, could be important
depending upon site location
and proximity to main travel
routes or sensitive receptors.
Medium
Continuous large impact
from operation of listed
activity. Plume length
exceeds site boundary for
>25% of daylight hours per
year.
Sensitive local
receptors.
Dispersion
by wind
e.g. Reducing pollutant emissions
consistent with the application of Best
Available Techniques.
Make regular observations
over a suitable time period
including a variety of
meteorological conditions.
Nuisance - reduced High
visibility, could be important
depending upon site location
and proximity to main travel
routes or sensitive receptors.
High
None
H1 Annex A Accident Risk installations & waste
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Insignificant
Hazard
Receptor
Pathway
Risk management
Probability of
exposure
To Water
Visible plume in discharge
to surface water.
This is unlikely to
receive approval.
H1 Annex A Accident Risk installations & waste
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15
Consequence
What is the
overall
risk?
Accidents
Please list each possible source of accidents in a separate row in Table 5.
'How to Comply' 10 gives more advice on the type of accidents you should think about, which include:
•
transferring substances (e.g. loading or unloading vessels).
•
overfilling vessels
•
plant or equipment failure (e.g. over-pressure of vessels and pipework, blocked drains).
•
containment failure (e.g. bund or overfilled drainage sumps, loss of landfill gas or leachate)
•
fires or failure to contain fire waters
•
making the wrong connections in drains or other systems
•
poor storage arrangements of hazardous substances
•
incompatible substances coming into contact
•
unwanted reactions and/or runaway reactions
•
emission of an effluent before adequately checking its composition
•
vandalism
•
flooding.
This is not a comprehensive list. You also need to work out what other situations are relevant to you. In particular there may be risks specific to
your industry that should be considered.
As a guide, you could assume that operator error will occur at least once in every 100 times an operation is carried out. For example, you might
drop or damage a drum from a forklift or have a spillage from a tanker
You should then complete the rest of Table 5.
10
http://publications.environment-agency.gov.uk/PDF/GEHO0411BTSP-E-E.pdf
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Table 5 – Assessment of accident risks
Hazard
Receptor
Pathway
Risk management
What has the
potential to cause
harm?
What is at risk?
What do I wish to
protect?
How can the
hazard get to the
receptor?
What measures will you take to reduce the risk?
Spillages from
pesticide handling &
storage areas
escaping.
Vulnerable
groundwater
beneath site.
Cracks in poor
impermeable
surface and
through the
ground.
Leak from the waste
oil storage tank
escaping the
containment.
Local water
course.
Fire in wood stockpile
causing emissions to
air and firewater
discharge.
Probability
of
exposure
Consequence
What is the
overall risk?
How likely is this
contact?
What is the harm that can
be caused?
What is the risk that still
remains? The balance of
probability and
consequence
Ensure containment measures are appropriate.
Maintenance and regular inspection procedure designed and
implemented.
Very unlikely if
appropriate
measures are
used.
Contamination of local
groundwater and potential
nearby abstractions.
Not significant with
measures indicated now
in place.
Via the surface
water drainage
system.
Design of containment and control of fugitive emissions –
maintenance and inspection procedure.
Very unlikely if
appropriate
measures are
used.
Contamination of local
water course.
Not significant.
Local water
course.
The surface water
drainage system.
Fire precautions as in 'How to Comply' and training in fire
hazards.
Air.
Airborne
transportation.
Fire hose nearby. Shift manager is responsible for actions in
event of fire. Actions are listed in the works procedures.
Unlikely if
appropriate
measures are
used.
Smoke, local nuisance, risk
of fire spreading to other
areas or premises.
Not significant as long
as contaionment is
appropriate and
management
procedures adhered to.
If it occurs – who is responsible for what?
If it occurs the oil spill equipment is located nearby. The shift
engineers are responsible for and trained in its use.
Wood is not treated so firewater relatively uncontaminated.
Slopes direct fire water to car park area for containment prior
to testing before release through interceptor.
H1 Annex A Accident Risk installations & waste
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Potential for pollution of
local surface or
groundwater if fire water is
not contained and tested
before release.
Odour
Fugitive emissions
What you should do next
If you are happy that you have completed your assessment correctly, you should:
•
complete any other risk assessments for your activity, as set out in Step 2 of H1
Environmental Risk Assessment – Overview
•
if you have assessed all the risks from your activity, continue with Step 3 of H1
Environmental Risk Assessment – Overview.
Accidents
H1 Annex A Accident Risk installations & waste
v 2.1 December 2011
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4 Annexes
Annex 1-Emission Benchmarks
Annex 2- Other Guidance
Available and Glossary
H1 Annex A Accident Risk installations & waste
v 2.1 December 2011
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