The Circle K Dublin Port Terminal is subject to the Chemicals Act (Control of Major Accident Hazards Involving Dangerous Substances) Regulations – the COMAH Regulations – due to the quantity of oil (petroleum) products that it stores. Under the COMAH Regulations, the Terminal qualifies as an Upper Tier establishment.
The COMAH Regulations lay down rules for the prevention of major accidents involving dangerous substances and seek to limit, to the greatest practicable extent, the consequences for human health and the environment of such accidents. The overall objective of the Regulations is to provide a high level of protection at COMAH establishments in a consistent and effective manner.
In accordance with Regulation 8(1), Circle K has submitted a Notification to the Health and Safety Authority. As an Upper Tier Establishment, Circle K is also required to submit a Safety Report to the HSA under Regulation 11(1), and to review and update the Safety Report every five years. The most recent Safety Report was submitted to the HSA in 2022.
Circle K Dublin Port
The Circle K Dublin Port Terminal imports, stores, loads, and distributes oil (petroleum) products and renewable products. The products are imported to one of the four yards from ships docked at the oil berths, via the Dublin Port Common Oil Pipeline, and are distributed by road tanker either from Terminal 2 (the majority of products) or Yard 4 (aviation fuel). Ethanol and additives are imported to the site by road tanker.
The products are stored in aboveground storage tanks in bunds. They are transferred to the road loading area in Terminal 2 from Yards 1, 2, 3 or 4 via the Common Oil Pipeline, or from the tanks in Yard 4 to the road loading area in Yard 4, where they are loaded into road tankers for distribution.
The import of product into the site can take place at any time of the day, and the distribution of product via road tanker is carried out 24 hours per day, 7 days per week.
The dangerous substances stored and handled at the Terminal with the potential to result in a major accident are:
- petrol (gasoline) (class I petroleum)
- kerosene and Jet A1 (class II petroleum)
- diesel (class III petroleum)
- gasoil (class III petroleum)
Circle K also stores and uses smaller quantities of petroleum product additives and marker dyes (for kerosene and gas oil).
Each of these substances – gasoline, kerosene / Jet A1, diesel, gas oil, and ethanol – as well as the marker dyes is classified as flammable. Gasoline is classified as extremely flammable, ethanol is classified as highly flammable, and the other substances are classified as flammable. All of the substances, except for ethanol, are also classified as toxic to aquatic life with long lasting effects.
The potential major accident hazards associated with the flammable substances are fires and, in the case of gasoline, vapour cloud explosions. The potential impacts from such major accidents are thermal radiation for fires, and overpressures for vapour cloud explosions. Fires may also result in the generation of smoke which may be carried down wind.
The Terminal is connected to the Dublin Port alarm system, which is used to alert users of the Port to emergencies. In the event of an accident or incident at Circle K, you will be advised via sounding of the Dublin Port alarm. When the alarm is activated, the Dublin Port Harbour Police / Port Security are alerted and investigate the alarm before deciding on the required actions.
The port-wide alarm system is a continuous wailing alarm sound. On hearing the Dublin Port alarm, you should:
- Be aware that an incident is on-going.
- Account for staff, visitors, and contractors.
- Continue to operate as normal unless instructed otherwise, or unless your individual company procedures instruct you otherwise.
- Wait for further instructions from the Harbour Police / Port Security or the Principal Emergency Services (An Garda Síochána, the Ambulance Service, or the Fire Service).
Port users should await further information from Dublin Port Operations / Port Security. Members of the public should tune in to a national radio station for updates
The Dublin Port alarm is tested at 11am on the 1st week of the month.
The information in this notice is available electronically at www.circlek.ie.
HSA Site Visits
In its role as the Central Competent Authority under the COMAH Regulations, the HSA conducts site visits. The most recent HSA site visit at the Terminal was on 18th May 2022. Further information on HSA site visits can be obtained by contacting Circle K (see contact details above) or from the HSA (see www.hsa.ie).
Access to Information
The COMAH Regulations require the HSA to make certain information on COMAH establishments permanently available to the public, and this information is available on the HSA’s website (www.hsa.ie). Additional information may be obtained from the HSA, or by contacting Circle K (see contact details above), subject to Regulation 26 of the COMAH Regulations.
Major Accident Hazards
The types of major accident that could arise at the Terminal are:
- A fire in a bulk storage tank, resulting in thermal radiation
- A fire in a bund, resulting in thermal radiation
- A pool fire outside a bund, resulting in thermal radiation
- A vapour cloud explosion from a release of gasoline (petrol) from a bulk tank or road tanker, resulting in overpressure effects
- A release of petroleum product that does not ignite
- A release of petroleum product that could impact on the environment
The Terminal has been designed and is operated to minimise the potential for such major accidents to occur. The Terminal is equipped with a fire protection system to detect and respond to potential fire scenarios, which includes connection to the Dublin Port water mains, firewater pumps, firefighting foam, foam systems on certain tanks, firewater systems on certain tanks, bund foam pourers, foam monitors, and hand-held equipment. The fire protection system is compatible with the emergency services’ equipment.
Circle K also maintains spill response equipment that is deployed in the event of a spill or release. The surface water drainage systems are connected to the Port’s drainage system, which in turn are equipped with interceptors to prevent the release of material that may enter the system. All the storage tanks are located in secondary containment areas (bunds), and therefore the potential for a spill or release to migrate offsite is minimised.
Fires give rise to thermal radiation; exposure to thermal radiation can result in injury to people, or damage to buildings, plant, and equipment. The extent of any injury or damage depends on the level of thermal radiation and the time exposed to the thermal radiation. For the largest fire scenarios at the Terminal, the thermal radiation effects that could result in injury from prolonged exposure do not extend outside the area of the Port estate.
Fires can also give rise to smoke; exposure to smoke from petroleum fires can cause irritation (to the eyes, nose, throat) and may cause breathing difficulties.
Vapour cloud explosions give rise to overpressures; exposure to an overpressure can result in injury to people, either directly or being hit with debris, and damage to buildings, plant, and equipment. Explosion overpressures are generally of a short duration. For the largest vapour cloud explosion scenarios at the Terminal, the overpressure effects resulting in injury or damage to buildings do not extend outside the area of the Dublin Port estate.
Spills and releases that do not ignite may migrate beyond the area of the release. Contact with petroleum products can result in injury to people through contact with the skin, ingestion and / or inhalation. Petroleum products can also result in damage to the aquatic environment.
In co-operation and consultation with the emergency services, Circle K has developed emergency response procedures to prevent, and limit the consequences of, major accidents. The mitigating actions include technical elements (such as the fire protection systems), and routine emergency exercises for both terminal staff and the emergency services.
As an Upper Tier COMAH establishment, Circle K is required to, and has, developed an Internal Emergency Plan to respond to the potential major accidents and to minimise their effects.
Circle K has also liaised with the external emergency services in the development of the External Emergency Plan for the Terminal:
- An Garda Síochána
- The Health Service Executive
- Dublin Port Company
- Dublin City Council
- Dublin Fire Brigade
The Internal and External Emergency Plans are subject to regular testing and review to ensure that they remain up to date and appropriate to the major accident hazards at the Terminal.
In the event of any emergency, Dublin Port Company appoints a Site Incident Controller, who manages the DPC resources, liaises with external agencies responding to the emergency, and keeps the Dublin Port Company emergency management team updated on the event. Dublin Port Operations / Port Security co-ordinate the response to emergencies, and control traffic within the Port.
During an emergency it may be necessary to evacuate the Port, or parts of the Port. The Port is divided into six areas for evacuation planning purposes. Dublin Port Operations / Port Security control traffic flow throughout the Port in the event of an evacuation of one or more areas.
Port users and members of the public will be directed by Dublin Port Operations if the Port is to be evacuated. In the event of an accident, all instructions and orders from the emergency services and Dublin Port Company must be followed.