Major Hazard Risk Exposures in Cyprus

By Dr Alan Waring

My previous Risk Watch article (‘Mari-Vassilikos Disaster: Did EAC Comply with Seveso Directive?’) summarised a number of the requirements of the EU Major Hazards Directive (the ‘Seveso II Directive’) and asked whether the Electricity Authority of Cyprus (EAC), the operators of the Vassilikos power station site, had complied with the requirements incumbent on them. Having since read some of the bizarre statements on this matter reported from the on-going Polyviou Inquiry, I feel obliged to clarify in more detail what the EAC’s obligations were – and still are. These obligations also apply to any other site that EAC (or indeed other operators) have which meet the Directive’s application criteria – including almost certainly any onshore gas terminal or processing facility relating to either LNG shipments and/or offshore gas reception.

A Smoke Screen?
A glimpse of the Alice in Wonderland beliefs apparently prevalent in EAC was provided to the Polyviou Inquiry by the Deputy Civil Defence chief Mr Chrysilios Chrysiliou, who reported the EAC’s stance thus: “Their view was that because chemicals were not involved and there was no fire in the fuel, it was not a Seveso incident”.
A complete red herring! First, the EU Major Hazards Directive does not restrict its scope to ‘chemicals’ (an ill-defined term) but is (quote) “applicable to all establishments where dangerous substances are present in sufficiently large quantities to create a major-accident hazard”. As I stated previously, those dangerous substances are identified in the table of Annex 1 of the Directive, together with specified threshold quantities for each substance which determine whether in any one case the Directive must be complied with by the site operator. Fuel oil and diesel come under Category 6 (Flammable). The threshold quantities for Category 6 are 5,000 tonnes for Articles 6 and 7 (Notification and Major Accident Prevention Policy –MAPP respectively) and 50,000 tonnes for Article 9 (Safety Report).
Press reports stated immediately after the explosion that there were 135,000 tonnes of fuel oil in the Vassilikos tanks, whereas the EAC said recently that 87,000 tonnes remain in the tanks. Either way, it is indisputable that EAC was required to comply with Articles 6, 7 and 9 BEFORE the explosion, so as to PREVENT any major accident. That requirement applied even if the Mari site and munitions were not next door.
What does EAC mean by “declaring a Seveso incident”? Surely they are not trying to get away with ‘cherry picking’ the Articles of the Directive which they believe apply to them. Article 15 (Information on Incidents Notifiable to the EU Commission) is only one of 25 Articles in the Directive. EAC has persistently failed to comment on its compliance with the Directive prior to the Mari explosion. Why is it trying to start its ‘compliance clock’ in relation to the Directive only from the time of the explosion, whereas its ‘Seveso’ compliance obligations started way back with Cyprus’s EU accession?
So, I come back to the key questions I raised in earlier articles and, in particular, where is EAC’s pre-Mari MAPP for the Vassilikos site and when was it first drafted and similarly any amendments? Where is its pre-Mari Safety Report for the Vassilikos site? What action has ever been taken to implement its MAPP and any recommendations of its Safety Report? What about its similar obligations in relation to its other sites?

What? No Compliance Documentation?
Habeas compilatio! Let’s have the compliance documents! This is what Mr Polyviou should have demanded in order to meet his instruction from the Attorney General to “examine this catastrophe in its entirety” but there is, as yet, no evidence that he is even remotely aware of the EAC’s duty regarding the EU Directive. To be sure, Mr Polyviou has spotted some glaring holes in the testimony of senior EAC officials. For example, he noted that it was undisputed that the EAC Plant Director sent a report to his HQ in February 2009 that showed his awareness of the arrival and location of the munitions at Mari next door. Yet the current EAC Director says that no documents on this are traceable. When Mr Polyviou asked why there was no record of the Plant Director’s report, the EAC Director gave a truly astonishing answer: “What we heard came from statements to the media, which in fact said that the material was inert and could even be stored in the city centre. There was no reason to investigate any further. We were reassured by the statements”.
Let us be clear. No one is suggesting that the EAC had any responsibility for the explosion at the Mari Naval Base. However, to reiterate, the EAC definitely did have its own major hazard responsibilities for its own site. Let us remember again, it was sheer luck that its fuel tanks did not go up when the blast from Mari struck Vassilikos. The EAC Director’s reported statement taken at face value is terrifying in its demonstration not only of serious management failures with documentation control on high risk issues but also of a woeful ignorance of the major hazard risk exposures and control requirements. Worse, it reveals a very casual attitude and a willingness to accept hearsay statements of reassurance on such critical matters from media reports instead of the EAC making its own due diligence enquiries and protective arrangements as required by the EU Directive. That Directive demands that operators, including EAC, “guarantee a high level of protection for man and the environment”.

Present and Future Risk Exposures
If any of the EAC sites holds inventories of designated dangerous substances, such as fuel oil, that exceed the EU Directive’s threshold quantities then each site has a present and on-going obligation to comply with the Directive.
As the EAC has not revealed what, if anything, it has done regarding compliance at each power station site, we can only guess about the current levels of risk control. However, the EAC Director’s statement to the Polyviou Inquiry about the pre-Mari position is hardly reassuring. And what of the future? The pre-existing plan to add a Liquefied Natural Gas (LNG) terminal to Vassilikos for receipt of bulk gas by ship is apparently still on track. Nothing wrong with that per se but, of course, it will have a huge impact on the major hazard profile of the overall site and the “safe operating envelope”. The threshold quantities of LNG specified in Annex 1 of the Directive are 50 tonnes (Article 6 Notification and Article 7 MAPP compliance) and 200 tonnes (Article 9 Safety Report compliance).
LNG presents awesome explosion risks. As a gas liquefied under pressure, any rupture of a tank, pipe or seal can lead initially to a BLEVE (Boiling Liquid Expanding Vapour Explosion) followed by a much more serious UVCE (Unconfined Vapour Cloud Explosion) or air-fuel explosion. The high pressure shock wave can exceed 3,000m/s or 9 times the speed of sound. Remote locations and strict safety controls for such facilities are therefore de rigeur.
The advent of offshore gas extraction east of Cyprus will also almost certainly result in onshore gas reception and processing terminals in Cyprus. Whichever company or organisation is the operator of such a facility, they will be subject to the EU Major Hazards Directive. Let’s hope for everyone’s sake that they comply.