If it is dangerous to light a cigarette on the site, then how could it possibly be a safe location for a power station and woodchip store?
Criminal negligence by five companies 12 years ago caused Europe’s biggest peacetime explosion and fire at the Buncefield Oil Depot near Hemel Hempstead.
Miraculously, nobody died, though 43 were injured and hundreds of homes and businesses were damaged or destroyed at a cost of £1 billion. Companies owned by BP, Shell and Total were eventually fined a paltry £5.3 million.
The subsequent investigation resulted in 18 recommendations to ensure that far greater attention would in future be paid to health and safety when deciding planning applications on or close to the most dangerous industrial sites – the Control of Major Accident Hazards (COMAH) sites.
At last there was hope that the regulatory authorities would finally have to take the safety of workers and residents more seriously, at least around the approximately 350 most dangerous sites in the UK.
Such hopes were dashed in January 2012 when David Cameron announced: "This coalition has a clear New Year's resolution: to kill off the health and safety culture for good”.
Funding for the Health and Safety Executive is being cut by 46 percent over the ten years starting 2009/10. Under the Red Tape Challenge, launched in 2011, 2,400 regulations have been scrapped, environmental guidance has been slashed by 80 percent, and fire safety inspections have been greatly reduced.
Although the Red Rape Challenge has formally ended, the deregulation drive has not: the government’s Better Regulations Executive continues to identify ever more regulations to be cut or ‘simplified – including regulations relating to the safety of COMAH sites.
As part of my work with Biofuelwatch, I have been supporting residents’ groups opposed to biofuel and biomass power stations across the UK for nearly a decade.
In recent years, we have been contacted again and again by residents concerned about proposed plants which come with a particularly high explosion risk: Biomass – and waste – gasifiers.
So far, no such waste or biomass has been operated successfully over a significant period in the UK - many have been built and failed. One of them – a Municipal Solid Waste gasifier – failed quite spectacularly, with hundreds of air permit breaches, an explosion and a fire.
The risks of biomass gasifiers are summarised in a 2007 report published by the European Commission and include gas leakages, fires, explosions, and suffocation and contamination of workers.
There have been some alarming planning decisions, amongst them the approval of a waste wood gasifier on a site in West Thurrock which has a pipeline for diesel, petrol and ethanol running right next to the proposed planned, partly above ground.
A large sign near the jetty (right next to the site) warns: “Danger – Highly Inflammable Petroleum Spirit – No Smoking or Naked Lights”.
If it is dangerous to light a cigarette on the site, then how could it possibly be a safe location for a power station and woodchip store? Fortunately, the owners of the site, Procter & Gamble, do not seem to have pursued this any further. Perhaps they have quietly ditched such a high-risk plan?
After the West Thurrock decision, I wondered whether there would any circumstances in which a planning proposal might be rejected on health and safety grounds?
A current planning dispute in Milford Haven suggests that that answer is no. The proposal in question is a larger biomass and waste gasifier proposed by a start-up company called Egnedol
I believe it must rank amongst the UK’s most dangerous planning proposals.
The site lies within two ‘top tier’ (i.e. highest risk) COMAH areas, due to nearby oil tanks and LNG storage tanks. Milford Haven is Europe’s largest LNG import site and the LNG tankers would be crossing right in front of Egnedol’s plant.
Hazards from those sites include flammable liquids and gases, fires and explosions. Two overlapping COMAH sites are defined as “domino groups”, with increased risks and potential impacts of major accidents.
I believe that the drawings submitted as part of the planning application omit basic safety features for gasifiers. In 2009, the European Commission issued guidelines on how to minimise health and safety risks of biomass gasifiers, to which the UK’s Health and Safety Executive had contributed.
Without a flare, there is no way of preventing a build-up of pressure inside the gasifier in the event that a gas engine malfunctions and shuts down.
If the pressure was to become too high, the plant would explode. A gasifier without a flare would basically be a ticking time-bomb – and in this case, a time-bomb right next to some of the UK’s most dangerous industrial infrastructure.
Egnedol’s representatives responded to those concerns by claiming that in such an event the gas would be transported to storage tanks across the road – with no indication as to how this could be achieved within a few crucial minutes, and in disregard of the European safety guidelines.
The Planning Inspector tasked with making a recommendation to Welsh Ministers opened a second consultation round in the autumn. Objectors were told that they could only comment on the impacts of the plant on the site’s ecology.
Other representations, including about the risks to the lives of residents and workers, would be ignored. As was a joint letter by Pembrokeshire Friends off the Earth, the Environment Network Pembrokeshire and Biofuelwatch.
This letter expressed alarm “that fire and explosion risks continue to be ignored entirely, despite the fact that Egnedol proposes to build a plant that contravenes safety guidelines, thus posing a significant explosion risk inside two COMAH zones.”
The Health and Safety Executive commented that it had no objections because there would be no “explosives” on the site – a reference to the fact that syngas is not legally classified as flammable or explosive, even though it is both.
It has shown no concern about the fact that a gasifier breaching vital safety guidance could be built right next to LNG tanks and ships. Its failure to raise an objection has stopped the local authority from objecting on health and safety grounds.
Welsh Ministers are yet to determine the application, but the other agencies’ unwillingness to consider the health and safety of local people does not bode well. Worryingly, the Welsh Government is not merely the ‘neutral’ arbiter of the planning application, because it sold part of the site to Egnedol in 2015. Pembrokeshire Council sold Egnedol the remainder.
The fact that such a - literally – explosive proposal could be granted in Wales is particularly alarming: unlike England, Wales has passed a Wellbeing of Future Generations Act, which should ensure that the planning system prioritises wellbeing goals, one of which is the goal of maximising physical and mental health.
Fortunately, there is a high chance that Egnedol will never manage to build and start up its gasifier even if it obtains planning permission.
Yet planning consent for Egnedol would prove to me that the planning and regulatory system across England and Wales will not protect the lives of local people, even from some of the most dangerous proposals.
Almuth Ernsting is a co-director of Biofuelwatch.