Last year, the Runcorn site was rocked by a series of major spills and prosecutions for breaches of discharge consents. ICI was fined £15,000 and £34,000 for two incidents which occurred in 1996 (ENDS Reports 266, p 51 and 270, p 46 ).
The company will shortly be prosecuted for a spill of 150 tonnes of chloroform last April (ENDS Report 267, pp 3-4 ), and may also face charges for a trichloroethylene spill in May. After the latter incident, the Agency met senior ICI managers to discuss its concerns and announced an in-depth audit of the works which was carried out over five days in July (ENDS Report 268, pp 24-25 ).
Overall, the Agency says it found "no evidence to suggest" that the incidents were attributable to a common cause, though pending legal action prevented it from exploring activities directly related to the main spills. A survey showed that staff have a "high level of environmental awareness".
However, the Agency identified a large number of other deficiencies - and expresses "particular concern" over delays in implementing some site instructions setting out procedures for safety and environmental protection.
The Agency's findings call into question earlier regulatory oversight of the Runcorn works. An audit carried out in 1995 by its predecessor HM Inspectorate of Pollution concluded that the site was "well managed with good environmental policies, procedures and work systems" (ENDS Report 254, pp 8-9 ).
In contrast, the latest investigation found "poor implementation" of instructions for alarm and interlock systems on two of three plants audited. Internal ICI audits over the past two years had identified the problem, but no remedial action had been taken. Housekeeping was generally good, but the Agency witnessed an internal audit of the Per/Tri plant which was found to be "poor". Many faults - including burst bags of reagents and a broken pump drip tray above a drain - had been present for some time but had not been identified in earlier audits.
The Agency also examined the adequacy of piping systems which transfer chemicals around the site. On the older plants, standards of control and instrumentation were "just adequate".
In general, the Agency found "no obvious reduction" in expenditure on maintenance, though it was "not possible to conclude" whether historic expenditure had been adequate. It urges ICI to continue its move away from reactive maintenance.
But the main issue to emerge from the audit is the adequacy of measures to prevent and contain spills. A 1996 instruction on inspection and maintenance of bunds has not been implemented anywhere on the site, and ICI has "no firm commitment to a compliance date". Some incident reports were "very poorly completed" - and in just one of ten cases examined by the Agency had recommendations been carried out by the target date.
In general, the Agency notes, ICI places "heavy reliance" on alarms to prevent overfilling of tanks and other spillages. Only a "very few" tanks have secondary containment. For many tanks, the Agency says, an overflow would pass directly to storm drains "with no further means of containment."
Overall, the Agency concludes, "wider consideration should be given to secondary containment at source". However, it makes no reference to its own unimpressive record in this area.
In the early 1990s, ICI resisted pressure from the National Rivers Authority to fit bunding and other containment measures. The NRA had hoped that the integrated pollution control (IPC) regime, introduced in 1991, would enable it to force the issue.
IPC authorisations for the site - most of which were issued at least 3-4 years ago - required ICI to submit feasibility reports on containment measures. Deadlines for many of these submissions have now passed - but the Agency has instead accepted ICI's request that a prioritised programme of investment should be agreed for the site as a whole.
ICI is now conducting a major risk assessment of on-site storage as part of "Project Pathway", which is focussing mainly on historic site contamination (ENDS Report 259, pp 8-9 ). The work will not be completed until late 1999 - and improvement works are unlikely to be approved until the next decade.
In January, ICI also suffered a leak of sulphuric acid from a storage tank on its Billingham works on Teesside. Nine fire appliances attended the incident.