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Specific Content of the Safety Report Ike van der Putte ike.van.der.putte@rps.nl

This project is funded by the European Union Projekat finansira Evropska Unija. Specific Content of the Safety Report Ike van der Putte ike.van.der.putte@rps.nl. Specific Content SAFETY REPORT (ref. SEVESO I and II, with additional notes considering SEVESO III).

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Specific Content of the Safety Report Ike van der Putte ike.van.der.putte@rps.nl

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  1. This project is funded by the European Union Projekat finansira Evropska Unija Specific Content of the Safety ReportIke van der Putteike.van.der.putte@rps.nl

  2. Specific Content SAFETY REPORT (ref. SEVESO I and II, with additional notesconsidering SEVESO III)

  3. Sections of the Directivesrelevant to this presentation96/82/EC Directive (Seveso II) as amended by 2003/1005/CEarticle 9/ article 10 - Safety Report andAnnex II – Minimum data to be considered in the Safety Report Additional Notes based on SEVESO III ANNEX II minimum data Safety Report and ANNEX III – Safety Management System

  4. General obligations of the operator A clear general requirement is imposed on the operator of a Seveso-type establishment (article 5 of the Directive). More specifically: “…the operator is obliged to take all necessary measures to prevent major accidents and, in the case of such an accident, to limit its consequences for man and the environment” “…the operator is required to prove, at any time, to the public authority responsible for carrying out the duties under the Directive (so-called Competent Authority) that he has taken all the necessary measures as specified in the Directive”.

  5. Obligations of the operator – Safety report UT article 9/ 10 Member states shall require the operator of an Upper Tier establishment to produce a safety report for the purpose of demonstrating that • a major accident prevention policy (MAPP) and a safety management • system (SMS) have been put into effect; • major-accident hazards are identified and necessary measures have been • taken to prevent such accidents and to limit their consequences for man and • the environment; • adequate safety & reliability have been incorporated into the design, • construction, operation and maintenance of any installation; • internal emergency plans have been drawn up, supplying information to • enable the external emergency plan to be drawn up; • information for land-use planning decisions has been given.

  6. Task of the Competent Authority in relationtosafetyreports (1) • The Competent Authority is required to examine the safety report and to • communicate the conclusions of its examination to the Operator. • Before finalizing these conclusions, the Competent Authority may request • further information from the Operator; in addition an inspection of the • establishment, in accordance with Article 18, “Inspections” may be carried • out to verify whether the information contained in the safety report • corresponds with the situation as it is in reality. • The conclusions should generally be in written form, and they should make • reference to the date of the safety report in question and any other • supplementary documentation reviewed for this purpose. • A pro forma statement by the Competent Authority that the safety report has been • received and seems complete will not be sufficient.

  7. Task of the Competent Authority in relation tosafetyreports (2) The conclusionsshould make reference to general conclusions based on the safety report in general and to specific cases of accuracy where individual examples have been examined in detail. Deficiencies and inaccuracies must be described where identified, however it is not expected that the competent authority should identify every single inaccuracy. Note:a large number of deficiencies and inaccuracies may lead the competent authority to reject the safety report and require that a revised document is submitted.

  8. In Summary • The Competent Authority • examines the Safety Report • requests further information from the operator (if necessary) • decidestoallow or • prohibit (Art. 17/ art 19) the bringing into use or continued use • of the establishment • communicates conclusions to the operator.

  9. Article 9/10: Safety Reports This article of the Directive requires that an operator of an upper-tier Seveso type establishment produce a safety report In the Seveso II Directive(96/82/EC) significant additional requirements (including the MAPP and SMS) were introduced as part of a more comprehensive “safety report”.

  10. THRESHOLDS • Annex I • Two categories based on quantities stored • Lower Tier • Upper Tier • Upper Tier has more responsibilities

  11. REQUIREMENTSLOWER TIER • General Obligations • Notification • Major Accident Prevention Policy • Modifications • Accident Reports • Cooperation with Authorities

  12. OBLIGATIONSUPPER TIER • Lower Tier Obligations and • Safety Report (incl. MAPP & SMS) • Internal Emergency Plans • Information to Public

  13. The requirements for policies and management systems which apply to a lower tier establishment are: similar to those for an upper tier establishment except that: • the Directive states that the requirements should be proportionate to the major-accident hazards presented by the establishment, • it is not necessary to prepare a detailed report for demonstrating how the Safety Management System has been put into effect; • the document setting out the MAPP must be ‘made available’ but need not necessarily be sent to the competent authorities.

  14. Collation of Information on process/activity Risk Assessment Hazard Identification Iterative Process Hazard Screening Scenario Definition (High Risk Hazards Only) Fine tuning of scenario definition based on risk evaluation results and impacts of risk reduction measures Risk Evaluation Risk Reduction Risk assessment

  15. Risk Assessment Review Existing Preventative/Control Measures Identify Further Preventative/ Control Measures Risk Reduction Carry out Cost/Benefit Analysis Review for Acceptability – As Low As Reasonably Practicable (ALARP) Accept or Implement Preventative/ Control Measures Risk reduction

  16. ANNEX IIMINIMUM DATA AND INFORMATION TO BE CONSIDERED IN THESAFETY REPORT SPECIFIED IN ARTICLE 9/ 10 I. Information on the management system and on the organization of the establishment with a view to major accident prevention (ref article 7 and Annex III: MAPP & SMS) II. Presentation of the environment of the establishment III. Description of the installation IV. Identification and accidental risks analysis and prevention methods V. Measures of protection and intervention to limit the consequences of an accident

  17. I. Information on the management system and on the organization of the establishment with a view to major accident preventionThis information shall contain the elements given in Annex III. (a) the major accident prevention policy (MAPP) should be established in writing and should include the operator's overall aims and principles of action with respect to the control of major-accident hazards; (b) the safety management system (SMS) should include the part of the general management system which includes the organizational structure, responsibilities, practices, procedures, processes and resources for determining and implementing the major-accident prevention policy (7 SMS issues described in detail); • organizationandpersonnel • identification and evaluation of major hazards • operational control • management of change • planning foremergencies • monitoring performance • audit and review

  18. II. PRESENTATION OF THE ENVIRONMENT OF THE ESTABLISHMENT A. description of the site and its environment including the geographical location, meteorological, geological, hydrographic conditions and, if necessary, itshistory; B. identification of installations and other activities of the establishment which could present a major-accident hazard; C. description of areas where a major accident may occur.

  19. III. DESCRIPTION OF THE INSTALLATION A. description of the main activities and products of the parts of the establishment which are important from the point of view of safety, sources of major-accident risks and conditions under which such a major accident could happen, together with a description of proposed preventive measures; B. description of processes, in particular the operating methods; C. description of dangeroussubstances: 1. inventory of dangerous substances including: — the identification of dangerous substances: chemical name, CAS number, name according to IUPAC nomenclature, — the maximum quantity of dangerous substances present or likely tobe present; 2. physical, chemical, toxicological characteristics and indication of hazards, both immediate and delayed for man and the environment; 3. physical and chemical behaviour under normal conditions of use or underforeseeableaccidentalconditions.

  20. IV. IDENTIFICATION AND ACCIDENTICAL RISK ANALYSIS AND PREVENTION METHODS A. detailed description of the possible major-accident scenarios and their probability or the conditions under which they occur including a summary of the events which may play a role in triggering each of these scenarios, the causes being internal or external to the installation; B. assessment of the extent and severity of the consequences of identified major accidents including maps, images or, as appropriate, equivalent descriptions, showing areas which are liable to be affected by such accidents arising from the establishment, subject to the provisions of Articles 13(4) (SR public info) and 20 (confidentiality); C. description of technical parameters and equipment used for the safety of installations. NOTE SEVESO III: also review of past accidents and lessons learned to prevent these

  21. V. MEASURES OF PROTECTION AND INTERVENTIONTO LIMIT THE CONSEQUENCES OF AN ACCIDENT A. description of the equipment installed in the plant to limit the consequences of major accidents; B. organization of alert and intervention; C. description of mobilizable resources, internal or external; D. summary of elements described in A, B, and C above necessary for drawing up the internal emergency plan prepared in compliance with Article 11 (Emergencyplans).

  22. In Summary Contents of Upper Tier SAFETY REPORTS Minimum SEVESO requirements for a SR (Upper Tier) • Description of establishment and neighboring environment • Dangerous Substances (Quantities vs SEVESO Qualifying quantities ) • Hazard Analysis (HA) : safety critical equipment/circuits • Major Accident Scenarios (Reference Scenarios), Phenomena with consequences outside the establishment Worst Case Scenarios (WCSs) • Consequence Zones (Z1, Z2, Z3) • Risk Assessment RA (Consequence based or QRA) • Domino • Safety Management System of the company as implemented in the establishment __________________________________________________________________________________ Ref. G. PAPADAKIS - SEVESO SERBIA 24th June 2013

  23. Safety Report Structure and development

  24. Structure of Safety Report • Introduction - Background • Safety Management System • Major Accident (MA) Prevention Policy • MA Organisation • MA Planning • Risk Control Systems • Performance Measurement • Audit and Review

  25. Structure of Safety Report(Continued) • Description of the Environment • Description of the Installation • Principal Installations • Facilities for Limiting the Consequences of a Release • Unit Operations • Areas with Potential for MAH • Hazardous Materials on Site

  26. Structure of Safety Report • Hazard Identification and Risk Assessment • Measures of Prevention, Control and Intervention • References • Attachments - Basis of Safety, Site Plans, Meteorological Data, Inventory of Hazardous Materials, Extracts from Site Risk Assessments

  27. Safety Report Hazards Basis for Inclusion in Safety Report • Multiple types - fire, explosion, toxic gas release • Highest risks • Offsite impacts • Environmental impact • Demonstrate ALARP

  28. Safety Report Hazards (Continued) • Dust Explosion • Hydrogen Release - Fire & Explosion • Toxic Gas Release • Solvent Tank Farm Fire • Environmental Release

  29. Safety Report Development • Collaborative effort with CA • Worked through Employers Group • Worked with CA individually • Biggest problem - getting direction on specifics, e.g. modelling end-points. • CA learning also

  30. Compliance - Interdependent Events • Carry out risk assessment • Develop scenarios and carry out modelling • Develop internal emergency plans • Supply information for external emergency plans • Inform Community

  31. Compliance - Interdependent Events (Continued) • Submit Safety Report • HSA review and agree report • Specified areas agreed, impact on • external emergency plans • Carry out necessary modifications/ implement procedures, e.g. Siren

  32. Discussions with HSA • DEMONSTRATE acceptable risk • Worst Possible vs Worst Credible • Emergency Services need Worst Case • Specified Distance vs Consultation Distance • Dangerous Dose vs ERPG • Little credit for good SMS

  33. Discussions with HSA (Continued) • Consider Escalation • Use Quantified Risk Assessment (QRA) to demonstrate credible • Address hierarchy of Elimination, Reduction, etc. • Specified areas for rivers?

  34. Discussions with HSA (Continued) • Consider flooding/high water table • Consider Heritage sites • Containment rather than modelling for Environmental risks • Appropriate data for modelling

  35. Resources • Risk Assessment • Consultant for 9 months • Safety Engineer for 6 months • Process Engineers for 10 weeks • Safety Report • Consultant for 6 months • Safety Engineer for 4 months • Staff for 1 month

  36. References COUNCIL DIRECTIVE 96/82/EC of 9 December 1996 on the control of major-accident hazards involving dangerous substances(OJ L 10, 14.1.1997, p. 13) – consolidated version DIRECTIVE 2012/18/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 4 July 2012 on the control of major-accident hazards involving dangerous substances, amending and subsequently repealing Council Directive 96/82/EC Planning for Emergencies Involving Dangerous Substances for Slovenia. Final Report. Contract no: SL-0081.0011.01. 28 February 2012. I.van der Putte: Regional Environment Accession Project (REAP). Nethconsult/BKH Consulting Engineers/RPS. Subcontractors: AEA Technology, URS/Dames & Moore, EPCE, Project Management Group, REC Hungary

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