Introduction:
During the last 50 years the chemical industry worldwide has undergone changes of great importance as a result of scientific and technological advances, which has allowed the appearance of new processes, new industries and new chemical products on the market.
All these advances have helped the chemical industry grow, increasing its production capacity. Along with them, the number of people who work in the process plants and who live in their surroundings has also increased. Both the workers and the population settlements near these industries are exposed to the risks and therefore to the consequences of technological accidents in these industries, such as those that occurred on December 3, 1984 in Bhopal, India, on December 21, 1984. September 2001 Accident at the AZF Fertilizer Factory in an industrial zone south of Toulouse, France in 2001 and April 18, 2013 in West Texas, United States.
The environmental legislation in force in Cuba makes it very clear the priority that the Cuban state gives to safety and protection to man, facilities and the environment, in particular from the adverse effects derived from the improper handling of dangerous chemical substances., as well as hazardous chemical waste, based on the ordering and integration of national activities in the field of Chemical Safety.
Decree-Law 309 “On Chemical Safety”, in its Articles 28 and 29 establishes the Safety Report (IS) as a document that constitutes an obligation of the entities that are in charge of Installations with Greater Danger (IPM) and is an indispensable requirement for the safe operation of the same. Consequently, Resolution No. 148/2013 of CITMA: "Regulation on the Management of Security Risks in Industrial Installations with Greater Danger" in Article 50 defines that the IS is part of an environmental regulatory strategy aimed at demonstrating that the facilities Hazards (IPM) are safely operated, providing evidence that existing hazards have been identified, risks have been assessed and all measures have been taken to reduce them to tolerable levels.
The IS is also one of the components of the environmental impact assessment process, according to Article 19 of Resolution 132/2009 “Regulation of the Environmental Impact Assessment process”, which establishes that the IS must accompany the application for an environmental license for the operation phase of an IPM.
To guarantee the correct and timely preparation of the Safety Reports and their presentation to the Regulatory Authority by the facilities with greater danger (IPM), the Regulation establishes in its Chapter VI, Fourth Section, that the holders of the same have the Obligation to prepare a Safety Report Preparation Plan (PPIS) that must be submitted for acceptance to the National Center for Chemical Safety of the CITMA Office of Environmental Regulation and Nuclear Safety, as part of the supporting documentation, first of all to the application for an environmental license for the installation execution stage for new installations with greater danger (IPM) or secondly, as part of the documentation of the Safety Report,where the owner of the facility with greater danger (IPM) demonstrates that all the necessary measures have been adopted to prevent major accidents, as well as their consequences for human health, the integrity of the facility itself and the environment, thus responding to Article 29 of Decree-Law 309/2013.
II. Methods or Technologies.
• GRAY 1.2 Regulatory Guide for the preparation of the Safety Report. 2014. CITMA.
• GRAY 1.21 Regulatory Guide for Safety Assessment for IPM. 2014. CITMA.
• GRAY 1.22 Regulatory Guide for the preparation of the Safety Report Preparation Plan. 2014. CITMA.
General objectives.
The Safety Report Preparation Plan aims for IPM holders (ECC CUPET Matanzas, UEB Rayonitro Matanzas and EFP Nuevitas) to:
1. Understand the regulations and legal requirements that protect the Safety Report (IS).
2. That the IS be executed in a systematic and structured manner based on the regulations and legal requirements that protect it.
3. Ensure the planning of the work to be carried out to make it and thus guarantee the quality of the preparation process.
4. Provide the resources to meet the deadlines required in the IS.
5. Be used as a baseline to measure the progress and quality of the IS preparation process in consideration of the PPIS approved by the regulatory authority.
6. Plan consultation with IS workers and other stakeholders.
III. Work Results.
Scope.
The PPIS covers all areas and process facilities and their operations that are under the control of IPMs where one or more of the hazardous chemical substances (SQP) are present, as well as hazardous chemical wastes that are handled in the organization, including infrastructures or common or related activities in sufficient quantities to constitute potential sources of major accidents.
Security Philosophy in IPM:
IPMs in Cuba have a safety philosophy that responds to different elements, fundamentally focused on OSH through an Occupational Health and Safety Management System (OSH) according to the requirements of NC 18001: 2015. Regardless of the SGSS, the current security philosophy also responds to Fire Protection (PCI) and disaster reduction, both natural, technological and sanitary according to the Disaster Reduction Plan.
Currently, the IPMs in question lack a security system focused directly on Process Security, so it is necessary to work towards the establishment of:
• Commitments in the current OSH policy that reflect Process Safety.
• That the Process Safety management is integrated into the current OSH SG system.
• A solid Process Safety Culture, through the training and awareness of all the entity's workers.
Security report in IPM (GRAY-1.2, V.2)
Activities of the Safety Report according to the continuous improvement approach (GRIS-1.21.2010)
Stages of PPIS
Stage 1: Identification of Major Hazards (IPM)
• Describe (including rationale) the methodology for the identification of major hazards that will be used.
• Provide detailed information on team members participating in Major Hazard Identification; including aspects related to its competence.
• Define the concept of “Major Accident” for IPM
• Prepare the list of Major Accident Hazards identified (PAM); relating to the operations and activities carried out in the facility identified as a result of the hazard identification sessions (TIDEP).
• Identify Major Accident Scenarios (EAM); considering the initiating events and the consequences associated with each of the major hazards identified; as well as representative settings.
• Completion of the Preliminary Register of Major Hazards (RPM).
Stage 2. Estimation of Major Accident Risk
• Establish risk tolerability / acceptability criteria (eg Risk Matrix) for the IPM.
• Estimate the Consequences for each of the Major Accident Scenarios identified; including detailed information on each of the safety studies carried out or to be carried out to determine the magnitude of the consequences (eg fire and explosions, leaks of toxic substances, spills, etc.)
• Estimate the possibility of major accidents occurring.
• Assignment of the level of risk associated with each of the identified PAMs.
• Determination of priorities for risk reduction.
Stage 3. Selection and evaluation of the suitability of the control measures
1. Identification of the existing control measures, based on the Preliminary Register of Major Hazards (RPM) and through the performance of the Bow Tie Interactive Workshops for each of the process units, carrying out the following activities:
• Confirmation of the applicability of hazards, causes, stop events and consequences to the corresponding process units.
• The application of the control hierarchy during the identification of barriers / control measures: Elimination, Prevention, Control and Mitigation.
• The assignment of responsibilities for each of the barriers.
2. Identification of the List of Critical Safety Systems (SCS) of the facility and preparation of the Interrelation Matrix between Major Accident Hazards and the corresponding Critical Safety Systems (SCS).
3. Development of Performance Standards (GRAY 1.2 p. 4.2.3.2 “Identification of Critical Safety Systems and Performance Standards”) for each of the identified SCS.
4. Evaluation of the suitability of the SCS, also considering the results of the review of compliance with the SCS design against the applicable safety rules and regulations (GRAY 1.2 p. 4.2.3.1 “Suitability of Control Measures”).
Stage 4. Risk reduction (“As low as reasonably practical” ALARP level) and risk communication
• Definition of the ALARP criterion (qualitative).
• Identification of the additional control measures necessary to reduce the risks of major accidents to ALARP levels with the priorities for their implementation; through the Bow Tie / ALARP Interactive Workshops with the participation of workers.
• Demonstration that risks are reduced to ALARP levels.
• Risk communication, through the communication of the resulting Bow Tie diagrams at all levels of the IPM and their use during the control of the works during the detailed engineering and construction and assembly stage.
Elements that make up the PPIS
1. General aspects. Background. General description of the installation.
2. Administrative structure of the PPIS and the SE
3. Execution schedule of the Safety Report.
4. Tasks to be carried out during the preparation of the Safety Report.
The planning process for the preparation of the Safety Report corresponds to what is established in Chapter VI Fourth Section "Of the Safety Report Preparation Plan" of the Regulations, which includes the following: (Art. 78 of the Regulations):
• The scheduling of tasks and deadlines to prepare the SI
• The methodologies used to carry out the different stages of the SE
• The consultation process that will be carried out with the workers and other interested parties.
• The manner in which the integrity of systems critical to the safety of the facility will be managed during construction and assembly work.
5. Methodologies to develop the Safety Report (IS).
Stage of the ES Possible technique (s) to be used Description Rationale for your choice
Identification of Major Hazards • What if? (What if?)
• HAZOP (Hazard and operability analysis)
• Task Analysis (Task Analysis) These Hazard Identification Techniques will be used, with the aim of fully and systematically identifying all the hazards associated with the process in this facility. Later on, the demonstration of the choice of these techniques as those used in the safety evaluation of the installation is proposed.
Risk Estimation • Risk Assessment Matrix.
• Analysis of consequences (fires, explosions, leaks, spills, etc.)
• Frequency estimates.
• Historical record of national and foreign incidents.
• Analysis of uncertainty and sensitivity. It is described in each corresponding section of the safety report.
Qualitative risk acceptance criteria will be used. The EIS advised by the CES will carry out the SE with the multidisciplinary group depending on the level of information available.
Software will be used for modeling scenarios.
Matrices will be used.
The information provided by UEB Rayonitro will be used.
Selection and evaluation of the suitability of control measures • Bow Tie
• Comparison with applicable legal safety standards and requirements Described in each corresponding section of the safety report. Joint workshops will be held with the EIS, the CES and designated personnel. Comparison with the applicable legal safety standards and requirements is mandatory in the safety review.
Risk reduction and communication • Bow Tie
• Qualitative ALARP criteria It will be described in each corresponding section of the report to be delivered. It will be mandatory in accordance with the criteria that are defined.
6. Consultation process
Considering that the T-IPM must carry out an effective consultation process with workers and union representatives, the population, emergency services, etc. that ensures the participation of everyone in the activities related to the development and implementation of the Safety Report, as established in Article 66 of the regulation, the IPM will carry out a dynamic consultation process that allows knowing, issuing criteria and guaranteeing continuous improvement in:
• Identification of major hazards.
• The risk assessment of major accidents.
• The selection and evaluation of the suitability of the critical control measures.
• Risk reduction (ALARP) and risk communication.
IV. Conclusions
1. The PPIS is carried out with technicians and specialists from the companies ECC CUPET Mtzas, EFRO Nuevitas and Rayonitro Mtzas and it is delivered to the National Center for Chemical Safety of the CITMA Office of Environmental Regulation and Nuclear Safety for approval.
V. References
• Law No. 81: 1997 ´´On the Environment´´.
• Decree Law 309: 2013 ´´Of Chemical Safety´´.
• Resolution No. 132: 2009. CITMA. "Regulation of the Environmental Impact Assessment Process"
• Resolution No.148: 2013. CITMA. ´´Regulation on the Management of Risks to the Safety of Processes in Industrial Installations with Greater Danger´´.
• GRAY 1.2 Regulatory Guide for the preparation of the Safety Report. 2014. CITMA.
• GRAY 1.21 Regulatory Guide for Safety Assessment for IPM. 2014. CITMA.
• GRAY 1.22 Regulatory Guide for the preparation of the Safety Report Preparation Plan. 2014. CITMA.
• Procedures, plans, work manuals and other technical documents of the facilities where the PPIS is performed
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