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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

The 21st september 2001 disaster in Toulouse :

an historical overview of the Land Use Planning

Nicolas Dechy, Sandrine Descourrière, Olivier Salvi

Accidental Risk Division, INERIS1
BP n°2 – Parc Alata, 60550 Verneuil en Halatte, France

Abstract

More than three years after the Toulouse disaster, on 21st september 2001, the direct
causes of the explosion of the storage of roughly 400 tons of off-specification
ammonium nitrate (AN) in a fertilizer plant are not clearly established. It will
probably be a major lesson to learn from this disaster. However the plant was located
in the vicinity of Toulouse city and the explosion turned into a disaster with severe
damages and effects : 30 people were killed, up to 10 000 people were injured,
14 000 people received therapy for acute post traumatic stress, and the cost was
estimated by insurers of 1.5 billion Euro. Another major lesson is that, in the
continuous debate on where to locate levers of actions for major accident prevention,
the Land Use Planning (LUP) came back into the issue of regulators in France and
the EU. Therefore, the aim of this paper is to provide information on the key points of
the history of the LUP that was set between the plant and the neighbouring activities.
Also, the damages of the disaster in this LUP context are discussed.

Keywords : Toulouse, Disaster, Land Use Planning, Risk, Scenario

Introduction
One of the first question is to wonder if we need the LUP in our risk management
tools ? The recent major accidents in Enschede in 2000 and in Toulouse in 2001
showed that disasters continue to occur throughout the EU despite the efforts to
control major accident hazards with Seveso I and Seveso II directives. This statement
is strengthened by the trend of major accidents recorded in the MARS (Major
Accident Reporting System) database of the European Commission [1,2], that
indicated a trend of approximately 30 to 40 major accidents per year throughout the
EU. So, one of the conclusions is that controlling major accident hazards by reducing
the risk on-site is not sufficient to promote a sustainable development for both
industry and urban areas without LUP in the next decades [3]. Another conclusion is
that the Seveso I and II Directives have their limits and the disaster was a shocking
surprise for part of the public opinion that lived in the “zero risk” faith.

These statements were made by the European Parliament [4] 2 weeks after the
Toulouse disaster. They asked, in a context of sustainable development (safety,

1
Institut National de l’Environnement Industriel et des Risques

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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

employment, environment), for a new risk management based on the logic of “risk
removal”. The EP also “called on the Member States to initiate urgently an in-depth
review of policies on regional and urban planning in the vicinity of risk sites,
including as regards the fiscal aspects”. The EP “considers that, in the case of high-
risk industrial sites, consultation procedures between public authorities and elected
representatives, local residents, industry and staff representatives should make it
possible to restructure these sites”. Mathieu and Levy [5] made an estimate of more
than a million people that live in the vicinity of French’s 1240 Seveso II sites (in
2001). On the other hand, the EP is “bearing in mind that the chemical sector employs
several million people in the European Union, and in particular 900 000 people in
France”. The EP “invites the EC to learn from this experience by proposing law and
control reinforcement (under the Seveso II Directive) which could lead to the
extension of safety areas, including retroactively”. Finally, the EP “strongly opposes
any attempt to relocate dangerous sites to countries where environmental and social
standards are lower than those in force in EU territory, and urges the Member States
and the Union to implement all possible technical and financial measures, and take all
political step, to achieve this objective”.

After the event, among several investigations, the environment Ministry mandated the
Inspection Générale de l'Environnement (IGE, general inspectorate for environment)
for an investigation made public [6]. INERIS was mandated by IGE for some
technical parts (materials, chronology, origin and causes, damages and effects, LUP).
The accident explosion's strength, its damages and effects, its first lessons and some
information related to the causes have already been published by INERIS [7,8,9]. In
addition recent results from InVS epidemiological survey [10] have shown greater
effects on people than the official statement reported six months after the disaster.
The InVS estimated the following figures : 10 000 injured people (some with sequela
such as auditory or esthetic, and also walking disorder) and 14 000 people that
received therapy for acute post traumatic stress in the 18 months after the event.

This paper is mostly based on investigation reports that have been made public [5,6]
and aims at providing a global overview of the LUP history around the AZF plant and
its neighbouring chemical plants. It will therefore mainly use a chronological
approach to address the co-development, interactions, and struggle of industries and
urban areas. In a first part, it will go back from the 17th century to underline the old
concerns about the LUP. Then, it will focus on the large development of urban areas,
mostly after WWII. In the second part, it will deal with the 1989 LUP process that
was designed in a local, national and EU context and was still in use in 2001. Then,
the LUP context after 1989 will be addressed. The paper will end with some lessons
about the LUP with regards to damages, and some changes after the event.

1. An overview of the history of Toulouse urban growth and its

chemical plants
As a general background, one should keep in mind the fact that, from 1914 to 2000,
the Toulouse population was multiplied by five, and by ten in the Toulouse urban
area (in the urban area, 150 000 inhabitants in 1914, 250 000 after World War II, 550
000 in 1975 and 750 000 in 2000). At the same time, the urban area was therefore

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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

probably multiplied by ten. This demographic growth is exceptional and points the
real race that urban area and industries struggled for more than 150 years [5]. This
competition and interaction are discussed below through the history.

1.1 The beginning of the explosive manufacturing to World War I [5,6,11,12]

The southern Toulouse chemical platform has been linked for a long time to the
history of the city : it results from a manufacturing tradition for military uses. In the
17th century, a small mill for black powder manufacturing, using the river energy, was
settled on the Island of Tounis on the Garonne river close to the bridge Pont Neuf
(now the centre of Toulouse, located in A on figure 1). In 1675, in order to move
away the hazard, the powder plant was settled at the northern part of the Island du
Ramier (located in B). However, there were 3 explosions – 2 explosions in 1781 and
1816 which damaged the neighbouring and the 1840 resulting in 9 deaths [11]. Due to
these 3 accidental explosions and probably because of the urban pressure, the city
council took the decision to remove the plant a second time from the inner city and to
transfer it to the south of the city (located in C). In 1840, the explosive factory had a
non-aedificandi zone (land use planning Vitry, easy to be controlled because on
potentially flooded area). New manufacturing buildings were set up in 1850-1860 on
the island (located in C), in 1877 on the southern island (located in D, more than 3 km
from the inner city, where the SNPE is), and the trend was accelerated by the World
War I when the factory was linked to the rail.

The explosive factory was highly

developed by the war and as many as 30
000 people were working there. The
explosive factory settled on the left
shore (located in E, where the AZF site
was) during this period up to the limit of
the southern boarder of the city. A
psychiatric hospital called Guy
Marchant settled in 1856, 5 km south
from the center (located in F) and
started to face the factory at that time.
So until that time, one can assume that
the question of risk was really perceived
[5] in the sense that the explosive
factory had moved south as the urban
area did (free areas), but also in a logic
of risk removal [5,6]. However, after
WWI, the move of the explosive factory
stopped and was overtaken by the urban Figure 1 : The move of the plants (A to E) through
area. This conflicting situation was the ages (17th century to 20th century)
perceived and discussed (chapter 1.3).

1.2 The chemical activities, from 1924 to the explosion [5,6,11,12,13]

In 1924, the ONIA (Office National Industriel de l’Azote, later became AZF for
Azote de France) was created by the State to use the Haber process (ammonia

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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

manufacturing by hydrogenation of nitrogen, a process from Germany as a

compensation of WWI) to produce fertilisers. The choice of Toulouse was for several
reasons : after the war, the State’s explosive factory had to sell part of its facilities
creating a lot of unemployed workers ; and also because of the methane proximity,
the rail delivery system, the water of the Garonne and the market need for the
agriculture of the region. It was an important decision for the growth of Toulouse’s
city : in 1930, the ONIA had 3 000 employees and because it was a state funded
activity, the 1929 economic crisis effects were low.

The factories were bombed during the WWII and the damage to the city was quite
large with numerous victims but this was less important than the 2001 explosion
according to testimonies [11]. However the ONIA factory was re-built and by 1950
had 3 500 employees. It changed of names and owners several time : APC (Azote et
Produits Chimiques) in 1967, merged with the fertiliser division of Rhône Poulenc,
was re-organised and then belonged to CDF Chimie-AZF in 1987, and since 1991 it
became part of Grande Paroisse (Société Chimique de Grande Paroisse) inside
Atochem division that was owned by the TotalFinaElf Group. In 2001, there were
470 employees (and 200 sub-contractors) on a plant of 70 ha, versus 1 150 in 1995.

The SNPE (Société Nationale des Poudres et Explosifs) was created in 1971 and was
based on the former explosive factory on the southern part of the Island "du
Ramier/Empalot". In 1973, the public company stopped its explosives manufacturing
activities which were replaced by chemicals manufacturing. The company still works
for defence purposes but mainly for space applications, applied chemistry such as
pharmaceuticals applications. In 2001, there were 469 employees. On the same site,
another company, Isochem, was created in 1998 to manufacture chemicals for
pharmaceuticals applications with 38 employees.

Tolochimie settled south from AZF in 1961, belonged first to Rhône Poulenc group
and then in 1996 to the SNPE group. It receives the phosgene from SNPE by a
pipeline over the Garonne River. The company produces intermediate chemicals to be
used for manufacturing chemicals for agriculture and for pharmaceutical applications.
In 2001, there were 110 employees.

1.3 The urban area development from WWI to the LUP approval in 1989
[5,11,12,13,14]

In 1926, the city’s mayor wanted to develop the city. In 1928, another aedificandi-
zone (Plan Cornudet) was proposed to isolate the ONIA-AZF site by green areas
(where buildings were forbidden) but could not struggle with the urban development
(the urban area doubled between 1914 and 1940 for an increase of a quarter of the
number of inhabitants). Houses and flats were built at La Faourette, la Croix de Pierre
and Empalot (located in 1, 2 and 3 in figure 2) with low prices.

The WWII pushed again for the growth of the explosive manufacturing activity with
20 000 employees [12]. In 1947, another LUP (plan Nicod) was approved. However
despite a warning from the Director of the explosive factory (letter of 23rd of July
1944) that asked for avoiding the building of flats too close, the plan was not applied
because of the need for development. There was a starting of a debate (to remove
sites) but the urgent priority after the war, was to build flats, universities, roads [5,6].

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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

The 30 glory years of the industrial growth, the development of aeronautical industry,
and later the return of 36 000 refugees from Algeria in the sixties pushed for a rapid
development of flats (Papus, Bagatelle, Faourette in the fifties, located in 4, 5 and 1)
at a rate of 5 000 housings per year [14]. An ambitious urban plan was put in place in
the sixties, called "Le Mirail" (located in 6), at 4-5 km from the inner city, in order to
host 100 000 inhabitants (in fact less than 40 000 now) and a university (located in 7).
A new urban plan was approved in 1962 in order to limit an anarchy in the
development in this euphoric period [5]. The choice for urban growth and for the
development of industrial jobs was stated in urban plans in 1968 and in 1971. The
technological risk was not mentioned in those urban plans.

This urban pressure forced the building of flats closer to the chemical industry. This
trend was accelerated by the decrease or change of activities of the explosive factory.
It had already happened in the twenties with the sale of some facilities to ONIA. Part
of the plant areas were ceased by the owner, the state, for low prices to investors to
support the housings needs : e.g. in 1949 (cité du Rebecou in Portet sur Garonne,
located in 8) and in 1974 (cité ANS, not located). Other parts were sold to other state
actors. As an example, a professional training centre (Camp du Bordelongue in 1954,
located in 9), a technical high-shool (Gallieni et Françoise, located in 10), a chemical
engineering school (Institut du Génie Chimique, located in 11) and housing for
teachers and students (cité universitaire Daniel Faucher, located in 12) were built on
former explosive factory fields (ceased in 1954-1956).

Companies (EDF, located in

13), a bus park (Semvat,
located in 14) and fields for
industrial areas (in 1964
between the road RN 20 and
Poudrerie de Braqueville,
located in 15, and in 1972 in
the field du Chapitre,
located in 16) settled closer
and closer to the chemical
platform. During the 1980s,
the urban development
continued further to the
south of Toulouse (west
from AZF site). Figure 2 : Urban settlement around chemical plants after WWII

During this period (fifties to seventies), the pollution impact of the chemical plants
was of greater concern by neighbours (environmental pollution rising concerns) than
the major accident risk (before the Seveso accident in 1976). However, the priority
was not the environment but to reverse the fall of the number of employees [11].

This historical analysis from the settlement of the chemical plants and the urban area
shows that in this case, after WWI, the urban area has settled closer and closer when
the chemical plants stopped to move away from the center. In particular this trend
was accelerated after WWII, due to several factors (among them, the overall urban
development priorities, the change in activities of the explosive factory and the cease

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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

by the State of its former fields). Mathieu and Levy [5] consider that there was no real
will to prevent this vicinity despite the early concerns with the former non aedificandi
zone in LUP (Vitry, in 1840), or a proposal (with Cornudet plan in 1928), with the
urban plan (Nicod in 1947) and the warning letter from the Director of the explosive
factory in 1944. The urban plans (end of sixties) referred to the urban development
choice. As stated by Mathieu and Levy [5], Toulouse is not a unique case. This
statement could question the stakeholders' perception of the main priorities (versus
the major hazard concern, cf chapter 2.1) during that period. Ten years later (cf
chapter 2.3) this potential high risk situation was explicitly stated by the city.

2. The 1989 Land Use Planning design process

2.1 The major hazard risk rising concerns and the laws in France

The situation in France about risk control regulations started in 1810 and 1917 on
hazardous and unsanitary plants. Following several major accidents in France (Feyzin
in 1966) and in Europe (Flixborough in 1974 and more importantly Seveso in 1976),
the concerns of the citizens and regulators lead to several risk and pollution control
regulations in France2 and the EU3. Therefore, safety studies under the responsibility
of companies were required. These studies required to perform risk analyses, to
estimate the probability and the potential effects of major accidents and to define
some threshold effects distances. The safety studies were regulated by the local
control authorities4. In the eighties, other disasters have shocked the minds (Mexico
and Bhopal in 1984, Basel and Chernobyl in 1986).

In France, a law5 required that LUP should be designed and controlled where new
plants (in particular Seveso ones) would plan to settle. In such cases, new plants
would have to compensate for the control on urban planning. For existing plants, the
principle was that former agreements for settlement should not be modified by new
laws. LUP control tools could be created by the urban planning procedure of general
(public) interest project (PIG, Plan d’Intérêt Général). This procedure does not
require paying for urban planning and could be used despite the disagreement of local
stakeholders. This led to the fact that the Equipment Ministry did not want to extend
LUP that are compensated because usually they are free. And industrials did not want
to pay. In practice this tool was not widely used (10% of cases according to [5]).

This 1987 law also required for some plants to set an external emergency plan with
fire and rescue services and the Authorities (it was called Plan Particulier
d'Intervention, PPI, the internal emergency plan was required by Seveso I).

As a general statement after the analysis of several cases in France, Mathieu and Levy
[5] pointed that the discussions between the State authorities, the cities and their
representatives often lead to reducing the LUP perimeters (compared to threshold
effects distances estimated in safety studies) without "real risk reduction" (real risk

2
Law 76-663 19th of July 1976 and its Decree 77-1133 of 21st September 1977
3
Seveso I Directive 82/501/EEC the 24th of June 1982
4
Inspection des Installations Classées pour la Protection de l'Environnement (ICPE), in DRIRE
5
Law 87-565 of the 22 of July 1987

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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

being represented by major accident scenarios). These discussions or negotiations

were not transparent. They [5] considered that today the LUP perimeters are usually
too small compared to "real" hazard (estimated hazard in safety studies, envelope
scenarios close to worst case scenario) and talked about "politically correct
perimeter" that sometimes stops at the edge of a road, a city…

2.2 The plants activities and hazardous potentials

The activities of the 3 plants (AZF, SNPE and Tolochimie) required the use of toxic
gases (Ammonia, Chlorine and Phosgene) in large quantities. These activities were
covered by safety regulations in the eighties (cf previous chapter).

In 2001, the AZF plant had 470 employees on a 70 ha area. It manufactured6

ammonia (1 150 tons/day), nitric acid (820 t/d), urea (1 200 t/d) and AN. It
manufactured AN fertiliser grade prills (850 t/d), technical grade for explosives
purposes with fuel-oil (400 t/d of ANFO) and nitrogen solution (1 000 t/d). It
manufactured also other chemicals such as melamine (70 t/d), resins, glue, formol and
chlorine based compounds. The plant hosted large storage capacities : ammonia (one
tank of 5 000 tons and one sphere of a 1 000 tons for cryogenic ammonia, both
double casing, and six pressurised tanks of 50 tons each, and a gazometer), chlorine
(two wagons of 65 tons in a confined warehouse and two wagons waiting for
unloading outside), AN (15 000 tons bulk, 15 000 tons bags and 1 200 tons of hot
solution). The distribution was made with pipelines (gaseous for chlorine ; gaseous,
cold and hot liquid for ammonia). Also on the 21st september, in the southern part of
the plant, there were also 4 chlorine wagons and 20 ammonia wagons.

The SNPE plant was devoted to the manufacturing of several chemical materials
(hydrogen, phosgene,…), materials for space applications and phosgene derived
compounds. It received two ammonia wagons (47 tons each) and distributed it with
two pipelines of 600 m and 700 m long. It received two chlorine wagons (65 tons
each) that were parked in a confined warehouse. The phosgene was manufactured and
stored in four tanks of 10 tons each in a confined warehouse. The gaseous phosgene
was distributed to the processes in pipelines. Containers of 950 kg of phosgene are
manufactured and sold.

The Tolochimie plant manufactured aromatic amines and isocyanates for protection
of crops and plants, and also paintings and coatings. The plants hazardous facilities
were the storage and distribution of phosgene, the phosgene pipelines (single and
double casing) and the phosgene reactor. During its transportation and use the
phosgene was in a mono-chloro-benzene solution. The phosgene was stored in two
spheres of 7,6 tons in a confined warehouse.

2.3 The Toulouse LUP rising concerns and the 1989 LUP process

According to [5,6], the Toulouse city would have been alerted about the dangers of
the site at the end of the seventies. In March 1979, the city of Toulouse services
mentioned in a letter that the Tolochimie plant is not compatible with the city.

6
the quantities manufactured in the eighties are not known, however orders of magnitude are given
with the 2001 figures from [6]

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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

However, there was nothing specifically mentioned in the 1982 plan for urban
development. The plan was standing for a better life quality but did not mention the
chemical plants' future. In 1984, the mayor of Toulouse publicly stated that he was
for the removal of chemical plants. In 1989, the industrial area had 30 companies and
3 600 employees at stake (half of them working for the 3 chemicals plants [15]). In
parallel, in 1978, the first safety studies were required to the 3 plants by the local
control authorities. In 1989, 15 safety studies had been reviewed and 8 of them were
analysed by a third party expert [15].

So it is clear that, in Toulouse in the eighties, the high risk due to the vicinity of
hazardous plants and urban area was known. It was not possible to remove the
industries or to evacuate large areas of the city. Therefore the key issue was to launch
a LUP process in order not to increase this risk by reducing the population’s exposure
(by stopping urban growth) and to reduce the hazard and pollution from the plants.
The 1987 law provided a LUP tool for existing sites with the PIG procedure. It was
approved for the chemical platform (AZF-GP, SNPE and Tolochimie) the 21st august
1989 [15]. It was one of the first PIG’s in France that was set-up.

In the 1989 LUP regulation document [15], it was stated that the safety deficiencies
identified already lead to investments of 10 Million € (today’s equivalent) for the 3
companies. There was also an agreement that new safety systems (double
containment) for high-risk processes (chlorine and phosgene workshops, phosgene
pipeline) would be implemented in 1992. It is argued that the possible leaks would be
confined and the major risk would be significantly reduced. It is also stated that only
3 sites in France have implemented these safety systems and that the cost would be of
14 M€ (today equivalent).

Then it is [15] mentioned that the "zero risk" does not exist. Therefore after the risk
management by industries, the actions to reduce risk are the LUP and the emergency
planning (internal and external). The external emergency plan PPI was approved on
the 30th of June 1989. Both actions are based on the risk analysis and the estimates of
the threshold effects distances for some selected potential scenarios in the safety
studies. Therefore the focus of the discussion is now on the selection, modelling and
effects assessment process of scenarios in safety studies for LUP design purposes.

2.4 The selection process of the scenarios for LUP design

At that period in France, the state of the art for choosing scenarios for outlining LUP
perimeters were based on a well-known deterministic view. It means that despite the
occurrence probability of events and some of the safety barriers, the selected scenario
should be at the same time : a representative of a or the major accident (close to the
hazard potential) in order to estimate “envelope” (kind of maximum) effects
distances; but it should be reasonable to think to this scenario (stated in [15])
according to the risk analysis. There was room for expert debate and negotiations.

So between 1983 and 1989, the Environment Ministry launched a work group to fix
the reference scenarios for liquefied toxic gases storage. It was decided that it would
be the rupture of the largest collecting pipe in liquid phase for ammonia, chlorine and
phosgene [6,15]. Another key issue was the question of the effects thresholds to be
chosen for effects distances estimates. At that time also, there were no clear

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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

guidelines for choosing these thresholds effects [6]. The Toulouse LUP process
launched by the authorities was a prototype and helped the national workgroup. Later
in 1990, a guideline [16] for selecting, modelling and choosing the effects threshold
for the LUP scenarios was approved by the Ministry for Environment.

In the nineties, the local control authorities summarised the 1989 LUP distances in
the table 2 [6]. In accordance with the 1990 LUP guideline [16], the PIG effects
distance is based on lethal concentration for 50 % of people exposed and the PPI
effects distance is based on first irreversible effects (IDLH).
Table I : LUP (PIG and PPI) perimeters for the chemical plants of Toulouse
Site Accidental scenario Hazardous Distance for Distance for
substance PIG (m) PPI (m)
Pipeline rupture of a tank, 14 900 kg Ammonia 894 1 600
AZF-GP release
Toulouse Pipeline rupture of a wagon when Chlorine 465 (with 875 (with
unloading, 350 kg release containment) containment)
SNPE Pipeline rupture of a wagon when Chlorine 500 (with 875 (with
unloading, 420 kg release containment) containment)
Manufacturing reactor, 550 kg release Phosgene 600 (with 1175 (with
containment) containment)
Tolochimie Manufacturing reactor, 1100 kg release Phosgene 900 2150

However, it was only written in [15] that in the event of a major accident on each site,
the irreversible effects could be observed for non-protected people in perimeters of
900 m for Tolochimie (phosgene reactor), 894 m for AZF-Grande Paroise (liquefied
ammonia storage) and 600 m around SNPE (toxic gas networks). This was the
definition of the PIG perimeter (cf to figure 3).

In Toulouse in June 1988, there

was a meeting between the control
authorities and the emergency and
rescue services for the design of
the external emergency plan (PPI)
perimeter for the 3 sites and the
thresholds were discussed :

• the PIG perimeter where

urban exposure should not
increase because it could be an
area where sufficient toxic
gases would lead to death ;

• the PPI perimeter would

define an area where, if
sufficient toxic gases, people
could suffer and they would
require the role of rescue
services (cf to figure 3).
Figure 3 : PIG and PPI perimeter fixed in the 1989 LUP

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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

Barthelemy et al, [6] analysed the thresholds chosen and showed that the thresholds
for the same toxic gas are the same through the 3 sites but the thresholds are different
between toxic gases : for ammonia, the lethal effects for first people ; for chlorine,
limit between the irreversible-reversible effects ; for phosgene, lethal effects for 50%
of people exposed. For the choice of the thresholds for PPI perimeter, they stated the
same problem.
2.5 A comparison with the LUP scenarios of other fertiliser plants

On the demand of IGE [6], an overview of LUP around six fertilizer plants in France
(with similar process and storage than AZF-GP site), was done in 2001 [17], in order
to compare the distances proposed by local control authorities for LUP procedures :

Table II : overview of compared effects distances for several fertiliser plants in France
Site Accidental scenario Hazardous Distance for Distance for
substance lethal effect (m) irreversible effect (m)
AZF-GP Toulouse Pipeline rupture ammonia 900 1 600
2 Pipeline rupture ammonia 4 500 6 000

3 Unknown ammonia 350 1 000

4 Unknown ammonia 200 500
5 Unknown ammonia 1 250 2 000
6 Pipeline rupture ammonia 900 2 000
7 Unloading operation ammonia 400 900

A detailed comparative analysis of the accidental scenario choice according to the

design of equipment, their effects estimates with assumptions, and modelling and the
effects thresholds used has not been performed for the study [17]. This kind of study
was performed in the ASSURANCE Project funded by the EU [18].

However, as a general conclusion, this table already underlines that the discrepancies
between LUP distances can not be understandable for the public if the way to
determine them is not transparent. This remark urged the need to establish a clear risk
assessment process and a transparent decision making that enables to understand the
discrepancies because of technical elements and local context. This overview also
enabled the following conclusions : for each site, the representative major accident
scenario for LUP purpose is a release of ammonia (and effects distances estimated are
rather different according to the sites) and that the scenario of AN explosion was not
proposed for LUP purposes. The 1989 LUP around AZF-GP site followed these two
principles [17].

2.6 Comments on the 1989 LUP scenarios chosen

First of all, the major lesson is that the AN explosion for LUP purpose was not
considered for several reasons (cf chapter 3.3) and this situation was not unique.
However, some lessons concerning the scenarios chosen in the safety studies and for
the LUP purposes have been identified and are useful to share. Barthelemy et al [6]
considered that they look like more to major incidents than to accidents as the
common sense would define them. In fact, the scenarios considered the action of
safety measures (such as leak detection) that lead to small amount of toxic releases to
balance the financial counterpart required [15]. As a reminder, later, a LUP guideline

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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

[16] was edited in 1990 by the Environment Ministry in order to clarify the rules of
scenarios selection for LUP purposes.

In the eighties, the first step was to stop urban growth and reduce hazard potential
with the use of the PIG procedure. As a conclusion of the 1989 LUP document [15],
the general interest of the PIG design is recalled. It is written that it copes with the
requirement of protecting inhabitants of a possible accident. But this requirement
should be assessed according to the economical consequences on the urban area
covered by the PIG and the economical impact of the chemical plants on Toulouse.
Indeed, Barthelemy et al [6] expressed their doubts about the possible concern of not
displaying effects distances that could not be really used for designing the LUP that
would face too many inhabitants housings and a foreseeable opposition. They
considered that the local control authorities were in a position to make decisions they
should not have the possibility to take. The Toulouse urban situation was not suitable
for a strict application of the principles of LUP around high-risk sites. Indeed, the
PIG perimeter on AZF included 1 130 people and the PPI perimeter included
approximately 16 000 people.

In addition, as mentioned in [15], in case of changes inside the plants, the control
authorities would require safety barriers in order to keep the safety perimeter.

Barthelemy et al [6] stated that for the PPI perimeter approval in June 1989, the
significance of the possible illness in some areas and the methodology used to fix the
safety distances were not precisely described by the local control authorities. Also,
they pointed out that the document for the PPI external emergency plan, mentioned
that the accident scenarios used to set-up the internal emergency plan would not lead
to effects outside the plants. They [6] considered that these sentences may not have
helped the risk perception of the actors in charge of the PPI emergency plan design.
They [6] verified this assumption with regards to the exercises that were set-up to test
the external emergency plan. Four exercises were organised between 1991 and 1995
but none since then. These exercises focused on some parts of the emergency plan. In
1999, the local authorities prepared an exercise but had to postpone it.

3. The Land Use Planning after 1989

3.1 The LUP compliance control between 1989 and 2001

It was mentioned the following rules inside the PIG perimeter [15]:

• new buildings are allowed only for new and existing “chemical culture”
companies,
• new buildings such as housings, stores, buildings of important height,
buildings that could host a lot of people, sports and leisure facilities would be
unauthorised,
• renewal and small extension of existing buildings is possible with limitations
(no more than x% of existing surface, x varying between 1989 and 2001) if
they do not lead to more than a little increase in population density,
• road infrastructure could be modified and increased if safety improvement is
demonstrated, in the sense of reducing the time exposure in the PIG area

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Between 1989 and 2001, in the PIG-zone, the total built area decreased, and so did
the number of people. Some limited extensions were allowed (e.g. : for a hospital and
for a private house). No new housing was authorised. Mathieu and Levy [5]
considered that since the 1989 PIG [15] was approved, the urban development was
efficiently controlled by the local State services.

However, during the LUP process, a department store (Darty) settled in 1986-1987 in
a former garage. The assessment of an increase of exposure of people was not in the
scope of the authorisation procedures of the local authorities. Later in 1992, a night-
club (the Bikini, at 200 m from SNPE site) got an authorisation for an increase of area
where it was argued that the increase would be lower than 20%. In fact, the project of
the owner was to host 300 to 700 people (versus 300). The architect explained at first
that the capacity of 500 people would not change. Then for the project, it was
proposed a revised estimate of 369 people. Barthelemy et al [6] considered that the
interpretation of the regulating tool let the risk to be increased.

On the other hand, focusing on the hazard potential, several increase of

manufacturing capacities were licensed in the nineties with regards to the safety
studies of the chemical plants. These safety studies were submitted to the local
stakeholders. But as noticed [6], it was argued that the potential additional major risk
would be kept inside the previously defined perimeters of the LUP.

3.2 The emergence of urban changes for the chemical plants in the nineties

In 1991, with the expansion of Toulouse’ city into the neighbouring towns,
discussions were started with a few cities, industrials and some associations, and for
the first time, the idea of removing the chemical plants was debated. In 1995, the
urban plan insisted on the other activities of Toulouse to develop the city. They stated
that the chemical manufacturing plants also started to work for pharmaceutical
applications.

After the Seveso II Directive, the 1998 local urban planning finally took a clear
position for long term changes, in particular for the chemical plants [5]. It is written
explicitly the concerns about the major accident risk (toxic release and explosions).
Also they considered that a long-term change of these activities would greatly help
the city to develop the quality of life along the river Garonne.

During this period, several safety studies and environmental pollution assessment
studies for AZF-GP were discussed (within a SPPPI : a committee for discussing
environmental impact and risks with local stakeholders). The neighbouring towns and
associations used this opportunities to show their concerns. In particular in 1999, an
increase of the manufacturing capacities with an investment of 25 M€ (with 4 M€ in
environment and safety) was debated at the SPPPI. The question of the impact of the
fall of an aeroplane on the chemical plants was asked [6].

In 1996, the trade house of Toulouse proposed to the mayor, among other ideas, for
the urban plan development discussions, to strengthen the chemical industry and to
develop another chemical industry area. The response of the Toulouse city was clear
in 1997 when they considered that there was no opportunity to increase the chemical
risk in this area [6].

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In May 2001, the Mayor of Toulouse asked the State authorities if they had really
assessed the possible effects of a major accident in all the dimensions (in particular
the number of potential fatalities). The Prefect, representative of the State authorities
replied in June 2001 and mentioned in particular the PPI emergency plan perimeter.
They also informed Toulouse' city that the PIG perimeter could be modified
according to the results of INERIS study (chapter 3.4) after the recent safety studies.

3.3 Revisions of safety studies on AZF-GP site between 1989 and 2001

Since 1989, AZF-GP site produced 5 new safety studies (for 5 new installations) and
4 revisions of former safety studies. In these new and revised studies, various
accident scenarios were presented, and effects distances were given for these
scenarios.

Among all the safety studies of the site, the AN explosion was not considered because
of low probability of AN explosion in normal conditions and operations (for a
material respecting the norm and being not polluted, the 1990 safety study reviewed
in 1995, did not consider any explosion for a 15 000 tons of AN 33,5% because of the
requirement of a powerful detonator). A fire scenario on AN was considered among
36 accident scenarios in the safety studies (in accordance with the position of the
UNIFA, the group of Fertiliser manufacturers in France). In March 2001, there were
discussions between the regulator, the UNIFA and explosives experts on the major
accident scenarios to estimate for AN in safety studies. The UNIFA referred to past
events and mentioned that AN explosions only occurred with fuel, or fire with
containment, or were initiated by another explosive. On the other hand, the experts'
group on explosive' materials, under the responsibility of the Army, had recalled that
NK fertilisers with 31,5% of Nitrogen should be well controlled for the transportation
and the use.

Notice that, the AN off-spec storage was not covered by the Seveso II Directive and
was therefore not a criteria that could trigger a safety study. This lesson was
implemented in a modification of the Seveso II Directive after the disaster [9].

3.4 Project of revision of PIG between 1989 and 2001

After the 1989 PIG approval and PPI design, and in order to comply with the 1990
guideline [16], operators of the chemical platform were asked in 1995 to provide
effects distances according to that guideline. These specific “LUP” studies were
completed in 1999. For AZF-GP site, new distances were less important than those
taken in the 1989 PIG. In particular, lower effects distances were estimated after
hazard potential reduction measures but not only.

In 2000, the local control authorities asked INERIS, as a technical support, to check
these “LUP” safety studies. Discrepancies on effects distances estimates were
expected due to several factors : i) the assumptions on the accidental scenario were
different between stakeholders within the scope of the use of the 1990 LUP guideline
(safety measures taken into account were for example different) ; ii) the effects
thresholds on toxic gas have evolved in the nineties (decrease) ; iii) the models used
to estimate the dispersion of the release were different between actors and have often
been updated.

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INERIS expertise study was in progress when the explosion occurred, and was
presented to the stakeholders in November 2001. According to preliminary results
given for the inquiry [6], Barthelemy et al [6] stated that this expertise emphasised
that some accident scenarios, such as toxic gas releases, could lead to greater effect
distances (much more important than those taken in the PIG).

4. General comparison of estimated effects and LUP

4.1 Estimated effects after the damages investigation

INERIS' damage investigation [7,19] may have help to mark out the different zones
where the critical overpressure thresholds of 140 and 50 mbar7 were reached or
exceeded. These thresholds were used in 2001 in safety studies for ICPE8 in order to
mark out the zones where the lethal effect (threshold of 140 mbar) and irreversible
effects (threshold of 50 mbar) on human health can be experienced for pressure
waves. These effects distances are then used in the LUP design process described
previously. Thus, the range of 20 to 40 tons adopted for the TNT equivalent also
implied [6,7,19] :

• a distance roughly between 280 and 350m for the critical overpressure of 140
mbar,
• and a distance roughly between 680 and 860m for the critical overpressure of 50
mbar.

It should be kept in mind that these estimates includes uncertainties [7,19] and should
be used with regards to other TNT equivalent estimates from several investigations
[8,20].

According to the distance between the AN explosion epicentre and the ammonia
storage (350 m), and the previous discussion upon the threshold effects distances
estimated after the damage investigation, it would mean that the threshold of 140
mbar for lethal effects would have been observed inside the PIG zone, and the
threshold of 50 mbar for irreversible effects would have been inside the PPI zone.

It should be kept in mind that most of the 30 fatalities were inside the LUP-PIG zone
(the 21 fatalities on site, one at SNPE, one at Brossette store) but 7 off-site fatalities
were outside the PIG perimeter. The meaning of the first lethal effects thresholds of
140 mbar used for LUP purposes does not exclude fatalities outside the perimeter.
For the injuries, at the present time, it is only possible to conclude that the effects
were much larger than the PPI perimeter. Fortunately, most of the injuries had
reversible effects but some wounded have some sequela (auditory, eye, walking
disorder) [10].

7
1 mbar = 100 Pascal
8
ICPE site total of ≅50 000 sites in France including Seveso II sites that have to assess accidental
scenarios in safety studies

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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

4.2 Some comments on the LUP and the effects

Some insights of this investigation can be highlighted :

• In safety studies, when modelling consequences of an explosion, overpressure is
assumed to be isotropic. According to INERIS estimates, iso-overpressure lines
were not circular, directional effects have been noticed (due to the protection of
large concrete buildings, hills,…). LUP decisions are based on safety studies,
which necessarily give a simplified representation of possible accidents [21].
• The estimated overpressure is lower than 140 mbar beyond the PIG perimeter.
The estimated overpressure is lower than 50 mbar beyond the PPI perimeter. It
could be understood that the 1989 LUP distances were not so inadequate to the
overpressure thresholds estimated a posteriori. But :
- LUP and emergency planning were based on toxic effects, and not on
overpressure so phenomenon are rather different and in particular their
kinetics which underlined the vulnerability of the urban area ; as a reminder
their site location was rather different (distance of 350 m),
- Without the occurrence of any domino effect, the majority of the deaths were
inside this first PIG zone corresponding to the lethal effects [5,6].
- A significant number of victims were located beyond the 1600 metres (PPI)
perimeter and the estimated 860 m from the place of explosion. This PPI
perimeter in 1989 was supposed to be the perimeter were people, in case of a
major accident, would require the rescue of emergency services. The threshold
of 50 mbar also appeared not being a relevant one for emergency planning. In
particular, a lot of wounded people required rescue services from indirect
effects (broken windows,…). The threshold for emergency planning for
overpressure effects was lowered in the new regulations after the disaster.
- The damages went beyond these 1989 LUP and emergency response
distances. But on the other hand, Mathieu and Levy, 2002, consider that
greater distances would not have lowered the impact because the urban areas
were built before 1989 and the LUP had no retroactively force for existing
sites and housings (cf figure 4).

Figure 4 : After the explosion, the AZF site inside the city of Toulouse

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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

One of the final lessons of this historical analysis for Mathieu and Levy [5] is that it is
possible to act inside the LUP zone, which appears today to be too small and that it is
not possible to interfere on a housing built before the LUP creation. This situation
lead to a high vulnerability of the urban area and its inhabitants despite its knowledge
by stakeholders. This high vulnerability was confirmed by the disaster and it became
non-acceptable with regards to the decisions of the Prime Minister (cf chapter 5.2).

5. The changes in Land Use Planning after the disaster

5.1 LUP in the new law 2003-699

This problem of the lack of a retroactive force in the PIG procedure of 1987 (it was a
parliament debate and choice in 1987) has been identified by the Authorities.
Therefore, a new law 2003-699 [22] was adopted in particular to implement several
lessons of Toulouse disaster [5,6,9]. In particular about LUP, the French Environment
Ministry identified two main questions : How to deal with the existing situation
without increasing the hazard ? How to treat current very hazardous cases ?

The first principle is that each increase of a LUP perimeter from industrials will lead
to compensation from them. In the vicinity of Seveso sites, PPRT (technological risk
prevention plan) will define no (or reduced) man’s land and those that need housing
protections (windows,…). This plan could use financial incentive tools in order to let
the people leave their house or in order to expropriate them. Therefore, a vulnerability
assessment of the stakes will be required in order to apply this plan. They will be
managed by local stakeholders including the public. The cost will be shared by
companies, local authorities and the State. The government considers this proposal as
new in Europe which implementation will take years.

Also the role of insurers was pointed, as they could be more incentive to promote risk
management and risk reduction. The new safety studies will have to estimate
probabilities of occurrences of major accidents scenarios with the cost of the potential
economical damages to the goods (as a reminder, the new law focuses only on 670
Seveso site high threshold versus a total of 1 250 Seveso Sites in 2001). Thus, the
industrials will get interested in being risk secured with an insurance contract as in the
past. A financial damage assessment based on accidental scenarios will be required in
the annual financial report of the company. By the shareowners and financial analysts
reading, this information regulation aims to be incentive.

5.2 LUP after the accident

During more than 6 months, the 6 companies (1 100 employees) of the chemical zone
were stopped, reviewing their safety studies in order to get another license to operate
from the local authority. In April 2002, roughly 6 months later after the accident, the
TotalFinaElf group decided to close the AZF-GP plant (450 direct employees).
Later on, the Prime Minister decided to close the phosgene activities of the
neighbouring companies (SNPE and Tolochime). Several demonstrations of
inhabitants have shown the non-acceptability of any new disaster potential in the area.

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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

Since then, the AZF-GP plant has been demolished and new projects such as a cancer
research center have been promoted. The other chemical plants have been closed
(Tolochimie) or have reduced their activity (SNPE).

Conclusion
The Toulouse disaster is a case history to illustrate the LUP conflicting situation that
was observed in the 20th century with the co-development of the urban area and
industries. The history of Toulouse and its chemical plants shows that the urban area
has overtaken the chemical plants despite the former removal history of the high-risk
explosive factory. In particular in the fifties and sixties, the priorities of the urban and
industrial development overcame some wills to maintain a former tradition of LUP. It
was strengthen by the change and decrease of activities of the plants with the cease of
fields that gave opportunities to this urban growth.
After this period, the case although illustrate the rising concerns about the risk society
in the last 30 years. Indeed, since the eighties, the safety studies, the risk control with
inspections of the authorities, the LUP and emergency planning procedures helped the
risk management process but had no retroactive force on the potential risk previously
created by the vicinity of urban area and high-risk industries.
The case of Toulouse does not seem to really escape from the rule [5]. Until 2001, the
AN explosion scenario was not taken into account for LUP purposes for several
fertiliser plants. The damage caused and effects on the people of Toulouse were very
large and different to those expected in safety studies. As a matter of fact, the
vulnerability of the urban area and its inhabitants was still too high with regards to the
remaining hazard potential, and after the disaster, most of it was removed.
The question of the risk assessment and the selection of scenarios for the purposes of
designing LUP and emergency plan have been identified as key points to improve.
The authorities have implemented several lessons into a new law [22] and launched a
new framework (PPRT) to set LUP for high-risk industries. This new process will be
more transparent and will integrate the stakeholders (in particular the public and
workers) in the decisions. The risk acceptability and its communication are becoming
more integrated in a global risk management process.

Acknowledgements
To the French Environment Ministry for its funding upon these studies.

References
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[2] EC Council communication n°2002/C 28/01
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required by the Seveso II directive, International ESMG Symposium, Nürnberg, Germany 8-10
October 2002, on Process safety and industrial explosion protection
[4] European Parliament resolution on the explosion of a factory in Toulouse – Minutes of the
03/10/2001 – Provisional Edition – B5-0611, 0612, 0614 and 0615/2001

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 Proceedings of the ESReDA 28th Seminar – June 14th-15th 2005, Karlstad University, Sweden

[5] Mathieu B., Levy F. (2002) Risque industriel et maîtrise de l’urbanisation suite à l’accident
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[22] The new law : Loi n°2003-699 du 30 juillet 2003 relative à la prévention des risques
technologiques et naturels et à la réparation des dommages

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