VAN DER VEEN, MSKENS 1

ENVIRONMENTAL RISKS ASSOCIATED WITH ACTIVITIES INVOLVINGAMMONIUM NITRATE IN THE NETHERLANDSVAN DER VEEN, HENK1 and MSKENS, PETER J.W.M.2

1 Policy coordinator, Directorate for Local Environmental Quality and Traffic, Ministry ofVROM

2 Deputy regional inspector, VROM Inspectorate, South Unit, Ministry of VROM

Rijnstraat 8, 2515 XP The Hague, The Netherlands

SUMMARY

Since the early 1990s the Inspectorate of the Ministry of Housing, Spatial Planningand the Environment (the VROM Inspectorate) has implemented enforcement campaignswith a central focus on risks for human safety. The most recent campaign involved a studyof the risks associated with the storage and use of ammonium nitrate in the Netherlands,and the extent to which the statutory regulations are being complied with. The study wascarried out at the four big ammonium nitrate producers in the Netherlands and at a limitednumber of storage companies where ammonium nitrate or products containing that sub-stance are being stored. This particular study was initiated in response to the explosion ofan ammonium nitrate storage centre in Toulouse on 21 September 2002, in which 30 peo-ple died.

The enforcement campaign revealed that the risk control procedures at the bigammonium nitrate producers are adequate and, hence, that incidents like the one inToulouse are not likely to happen. However, at the storage companies the risks associatedwith ammonium nitrate were shown to be more substantial. In addition, there appeared tobe room for improvement in the labelling of products containing ammonium nitrate and inthe directive regulating the storage of such products.

Safety indicator system at discharge site for ammonium nitrate solution

1 RISK POLICY AS PART OFENVIRONMENTAL POLICY INTHE NETHERLANDS

In the Netherlands, risk policy hasbeen a major component of environmentalpolicy for over two decades. Before the oilcrisis in the 1970s it was common practiceto flare the gaseous fraction if it could notbe used on site, but in the wake of the cri-sis the market value of fossil hydrocarbonsincreased to such an extent that the large-scale utilisation of the gaseous fractionbecame commercially interesting. Sincethat time the application of LPG (LiquefiedPetroleum Gas) as a fuel for motor vehiclesand as a raw material for the chemicalindustry has increased exponentially in theNetherlands. The authorities realised, how-ever, that certain risks were associated withthe storage, application and transport ofLPG and commissioned a study into thoserisks in the 1980s. That study made use ofthe Quantitative Risk Analysis as aninstrument for risk assessment. This riskassessment strategy was then implement-ed as a policy instrument in theNetherlands by virtue of the governmentsIntegrated LPG Memorandum.

2 RISK POLICY ENFORCEMENT

The government complementedthe new policy with a number of statutoryregulations to ensure that the policy couldbe effectively enforced. Examples includethe LPG Filling Stations (Road Traffic)Decree and the Serious Accident RisksDecree. The latter decree also served asthe instrument under which the EU Post-Seveso Directive was implemented in theNetherlands.

In the early 1990s the Inspectoratefor the Environment at the time launched arisk-oriented enforcement campaign, thepurpose of which was to implement theLPG Filling Stations Decree. In subse-quent enforcement campaigns conducted

by the Inspectorate, risk policy enforce-ment was repeatedly shown not to attractthe attention it deserves.

The fact that risk policy in theNetherlands was not properly enforcedand that the safety of citizens was beingjeopardised was brought home with avengeance by major incidents involvingmany fatal casualties in the towns ofEnschede (May 2000, explosion of fire-works factory) and Volendam (New YearsDay 2001, fire in a caf/dance club). Sincethen new statutory regulations in the areaof risk policy (fireworks, fire safety of build-ings etc.) have been introduced, and allpublic authorities involved (municipalities,provinces and central government) havereinforced systematic risk policy enforce-ment procedures. The Inspectorate for theEnvironment (which later merged into theVROM Inspectorate) was also strength-ened as part of that overall effort.

3 ENFORCEMENT STUDY INTO THERISKS ASSOCIATED WITH THEPRODUCTION AND STORAGE OFAMMONIUM NITRATE

In the morning of Friday 21September 2001, an explosion took placein a chemical factory in the French city ofToulouse. The Grande Paroisse company(part of the Total/Fina/Elf group) is situatedin the southern part of the city, in the mid-dle of a residential district. The explosionhad disastrous effects, and the newspa-pers reported 30 deaths, 2,442 injured (34of whom seriously) and 600 homes thatwould be uninhabitable for a long time tocome.

Even though the precise cause ofthe accident has not yet been fully estab-lished, the first signs were that the explo-sion took place in a storage space formaterials containing ammonium nitrate.The Dutch authorities were obviously eagerto know whether accidents of this naturecould also take place at similar companies

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in the Netherlands.This is why the Minister of VROM

commissioned the VROM Inspectorate toexplore the manner in which ammoniumnitrate and products containing ammoniumnitrate are being manufactured, processedand traded in the Netherlands. The pur-pose was to find out whether the storage of and activities with ammo-

nium nitrate in the Netherlands are suffi-ciently safe;

the rules and regulations issued to guar-antee safety are properly enforced;

existing rules and regulations are suffi-cient to ensure safety.

The study was performed at thefour biggest fertiliser producers in theNetherlands: Hydro Agri Sluiskil and ZuidChemie Sas van Gent (Zeeland province),DSM Agro Geleen (Limburg province) andDSM Agro IJmuiden (North-Hollandprovince), but also involved a number offertiliser storage companies.

4 PROPERTIES OF AMMONIUMNITRATE

The accident in Toulouse occurredwhen the substance called ammoniumnitrate exploded (detonated)1. Ammoniumnitrate is a substance with a special riskprofile.

It is a solid which, under specificconditions (high concentrations, high tem-peratures, confinement and the presenceof catalysts such as oil and chloride), canexplode or decompose releasing noxiousfumes.

In the past this substance caused anumber of very serious accidents, some ofwhich involved hundreds of fatalities. Notsurprisingly the production, storage anduse of the substance are subject to strictprecautionary measures. In theNetherlands, products that contain ammo-nium nitrate (fertilizer) are classified in haz-ard categories A1 and A2, B and C2.

The Dutch production companiesexclusively make fertilizer in the A2, B andC categories. Import, storage and tranship-ment activities with fertilizer in category A1take place on a modest scale.

5 FERTILISER PRODUCERS

The study of the four companiesthat produce and process huge volumes ofammonium nitrate has shown that underthe present circumstances the chance ofan accident in the Netherlands comparableto the one in Toulouse is negligible. This ismainly because the ammonium nitrate atthose companies is different in compositionfrom the substance that exploded at thestorage company in Toulouse.

The four companies in the studydid, however, show differences in terms ofproduct range, working methods, safetypolicy and safety record.

Nevertheless, the researchers con-

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Bulk storage of fertilizer containing ammoniumnitrate

Discharge site for ammonium nitrate

clude that at the moment of the study allfour companies operated under sufficientlysafe conditions as regards the production,processing and storage of ammoniumnitrate and fertilizers containing that sub-stance. The safety procedures for materialscontaining ammonium nitrate and checkson their composition were found to be ade-quate and properly complied with in prac-tice.

All company sections involved inthe study could produce up-to-date permitsunder the Environmental Protection Act.The permits had relevant coverage andwere consistent with the applicable qualityrequirements. The companies were foundto operate largely in conformity with theguidelines stated in their permits. However,the implementation of the 1999 SeriousAccidents Risks Decree was found to belacking in some respects.

The VROM Inspectorate took stepsagainst one of the four companies, orderingit to halt the supply and upgrading of amaterial containing a particular type ofammonium nitrate. The company could notresume this operation until the VROMInspectorate was satisfied that the qualityof the material could be sufficiently guaran-teed.

6 FACILITIES FOR THE STORAGE ANDUTILISATION OF, AND THE TRADE INAMMONIUM NITRATE

Firms that stock ammonium nitratefor trading or processing purposes form asecond category of relevant companies.Given the large number of companies inthis category and the enormous differencesin terms of company type, size and natureof operations it proved impossible to pro-duce a complete picture of all facilitieswhere ammonium nitrate is or might bepresent.

The exploratory study, however,suggests that in the Netherlands an esti-mated 170 companies process, store or

use this product in some form or another.The situation at companies that

operate in the distribution chain for C- fertil-izer, such as wholesalers, was generallyfound to be satisfactory.

Fertilizer refiners (blenders andcoaters) proved to merit some closer atten-tion, as blending and coating activities atthose companies sometimes generatedtypes in the risk category of B- fertilizer. Atsome companies storage conditions andfire fighting procedures were found to fallshort of relevant category requirements.

Industrial ammonium nitrate is trad-

ed at wholesalers and chemical storageand transhipment companies. In manycases reliable information about the riskprofile (read: detonation aspects) of thematerial is lacking. The study highlightedvarious companies of this type where con-ditions were so dangerous as to call for anintervention. A few companies use ammo-nium nitrate as a raw material or auxiliarysubstance in production processes, but nosignificant irregularities were encounteredthere.

7 PRODUCT QUALITY, LABELLINGAND STORAGE CONDITIONS

In many cases ammonium nitrateand products containing the substance thatare traded on the market come from out-side the Netherlands. The labels suggestthat these products qualify as oxidising

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Combustible materials (pallets) in the storageof fertilizer containing ammonium nitrate

agents and should be treated accordingly,rather than as explosives. However, thereare reasons to assume that some of thoseproducts are certainly prone to detonationand wrongly exempted from a strict treat-ment regime.

Many of these products are tradedwith little or no accompanying risk informa-tion. The statutory product informationleaflets were found to be incomplete andmisleading on a number of crucial aspects.

The detonation properties ofammonium nitrate and products containingthat substance are assessed under varioustypes of regulations, each associated withits own test system. This generates confu-sion and may cause the actual risks to beunderestimated.

The CPR-1 directive, used in theNetherlands in the storage of fertilizerscontaining nitrates, needs to be updated. Ina number of respects the directive appearsto have become obsolete and its provisionsare too vague. It should also be made con-sistent with (new) international provisionsconcerning the classification of sub-stances, packaging and safety policy.

The 1999 Serious Accidents RisksDecree contains a relatively high thresholdvalue for ammonium nitrate. The Decreeonly becomes applicable in the case ofconsiderable storage volumes, in contrastto the threshold values for other sub-stances with similar risk profiles.Harmonisation is called for, preferably with-in an EU context.

8 RECOMMENDATIONS

Given the findings of the study, theVROM Inspectorate makes the followingrecommendations: The knowledge about the risk profile of

ammonium nitrate and products contain-ing ammonium nitrate, and the transla-tion of that knowledge into policy, mustbe improved. For example, the descrip-

tion and labelling of products availableon the market must be refined and stan-dardised. It is also necessary to updatethe CPR-1 safety directive.

Information about the risk profile of activ-ities involving the use of ammoniumnitrate and products containing ammoni-um nitrate must also be improved. This isclearly a joint task for the public authori-ties and the business community.

The public authorities should more effec-tively structure and intensify their super-vision of safety procedures for the treat-ment of ammonium nitrate and productscontaining ammonium nitrate. Thisapplies in particular to the import ofthese products, but production and stor-age methods used in companies withinthe Netherlands also call for continuousattention.

9 AFTERWORD

Time and again, large-scalecalamities of the type that have alsooccurred in the Netherlands in recent yearsemphasise the need for constant vigilanceat companies and public supervisoryauthorities alike. Risk-oriented enforce-ment campaigns like the one dealt with inthis paper will continue to be necessary, aseach successive campaign reveals theexistence of companies where risks are stillnot being properly attended to, as well aslow levels of compliance and poor-qualityrules.

10 NOTES

1 The term detonation refers to theprocess in which a local shock in a sub-stance brings about a reaction zone thatmoves through the substance on a shockwave at supersonic speed. Explosionshave a highly destructive effect.Deflagration refers to the process inwhich local heating of a substance brings

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about a reaction zone that moves throughthe substance by transferring heat, withoutthe need for oxygen. The decompositionprocess will continue even after the heatsource has been removed. Deflagrationcauses large volumes of nitrous vapoursto be released, and cannot be extin-guished by cutting off the oxygen supply.Under certain conditions (confinement) thedeflagration process may lead to detona-tion, also knows as explosion combus-tion.2Danger categories for products contain-ing ammonium nitrate / fertilizersA1: risk of detonationA2:will only detonate under exceptional

conditions and releases noxious fumes(nitrous vapours) in the case of a fire

B: may deflagrate under certain conditionsand releases noxious fumes (nitrousvapours) in the case of a fire

C: will release noxious fumes (nitrousvapours) in the case of a fire

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