Safety analysis review

A safety review is undertaken by the design, construction and operation organizations, and the control bodies. As all the regulatory documents repeat and as also explained by those who have for a long time been involved in this activity (Bourgeois et al., 1996), it is essential that this control function is independent, competent and credible. 

I will use some experience accumulated over several decades of involvement in safety reviews to add here some further additional and more detailed considerations on the subject with some examples. 

---

There are many methods of safety analysis reviews that are available and can be applied to a facility or project design to overcome human errors and the various failures of the process system. The methods may be either qualitative or quantitative in nature. 

In 1959, an American Society for Testing and Materials task group made recommendations on test procedures for evaluating radiation effects on materials, which led to recommended practices for surveillance tests on structural materials in nuclear reactors. As part of their safety analysis review, the AEG ensured that each plant conducted a reactor vessel irradiation surveillance program per American Society for Testing and Materials standards to evaluate the shift in RTnot over the plant life, especially in the beltline region opposite the core midplane where the reactor vessel sees the largest neutron flux. 

Process Safety Analysis This part treats the analysis of a process or project from the standpoint of hazards, risks, procedures for making potential damage estimates, and project reviews and audits. It can be helpful to management in assessing risks in a project. It consists of the following ... 

An applicant for a construction permit files a Preliminary Safety Analysis Repori (PSAR) presenting design criteria and preliminary design information, hypothetical accident analyses, safety features, and site data. An Environmental Report (ER) must be submitted to evtiluatc the env ironmental impact of the proposed facility, and information must be submitted to the. Uornev Cieneral and the NRC staff for antitrust review. 

Solomon, K. D. and W. G. Kastenburg, 1985, Estimating the Planning Zones for the Shoreham Nuclear Reactor, A Review of Four Safety Analysis, Rand note N-2353-DOE September. 

This paper reviews data on certain thermodynamic aspects of the nonstoichiometric Pu-0 system, which may serve as a basis for use In reactor safety analysis. Emphasis Is placed on phase relationships, vaporization behavior, oxygen-potential measurements, and evaluation of pertinent thermodynamic quantities. Limited high temperature oxygen potential data obtained above the fluorite, diphasic, and sesquioxide phases In the Pu-0 system are presented. 

It is therefore easy to see why this current drug safety paradigm, with its lack of standards in data collection and analysis, hinders the analysis of adverse events. Without data standards in place, it is difficult to build practical, reusable tools for systematic safety analysis. With no standard tools, truly standardized analyses cannot occur. Reviewers may forget their initial analytical processes if they are not using standardized data and tools. Comprehensive reproducibility and auditability, therefore, become nearly impossible. In practice, the same data sets and analytical processes cannot be easily reused, even by the same reviewers who produced the original data sets and analyses. Not using standardized tools slows the real-time systematic analysis... 

DOE Order 5480.23 specifies that hazard and accident analyses be included in safety analyses for nuclear facilities. Likewise, DOE Order 5481.IB, "Safety Analysis and Review System," requires hazard and accident analyses be included for non-nuclear facilities. Two nuclear SAR topics overlap with the PrHA. 

U.S. Department of Energy, DOE Order 5481.IB, "Safety Analysis and Review System," Washington, DC, September 1986. 

Other possible preliminary safety analysis methods are concept safety review (CSR), critical examination of system safety (CE), concept hazard analysis (CHA), preliminary consequence analysis (PCA) and preliminary hazard analysis (PHA) (Wells et al., 1993). These methods are meant to be carried out from the time of the concept safety review until such time as reasonably firm process flow diagrams or early P I diagrams are available. 

Hazard and Operability Analysis (Hazop) (Kletz, 1992) is one of the most used safety analysis methods in the process industry. It is one of the simplest approaches to hazard identification. Hazop involves a vessel to vessel and a pipe to pipe review of a plant. For each vessel and pipe the possible disturbances and their potential consequences are identified. Hazop is based on guide words such as no, more, less, reverse, other than, which should be asked for every pipe and vessel (Table 1). The intention of the quide words is to stimulate the imagination, and the method relies very much on the expertise of the persons performing the analysis. The idea behind the questions is that any disturbance in a chemical plant can be described in terms of physical state variables. Hazop can be used in different stages of process design but in restricted mode. A complete Hazop study requires final process plannings with flow sheets and PID s. 

Is there a routine mechanism such as Joh Safety Analysis (JSA) in which tasks such as this are systematically reviewed for potential hazards JSA is a procedure that systematically identifies (1) job steps, (2) specific hazards associated with each job step, and (3) safe job procedures associated with each step to minimize accident potential. 

A reactive chemicals/process hazard analysis (PHA) to be completed every three years (see Reference 11). Special consideration may be given to facilities that have lower levels of process risk and which have demonstrated superior safety performance to extend this frequency up to five years. Facilities that pose higher process risk or who have lower safety performance may be recommended to have reactive chemicals/PHA reviews more frequent than every three years. In certain countries, government regulation will determine the frequency and other requirements for Process Hazard Analysis reviews. Dow will follow the government requirements where they are more stringent. 

As can be seen from the Global Reactive Chemicals Standard, all existing chemical processes will have a Reactive Chemicals/Process Hazard Analysis review on a predefined periodic basis. In addition, every new plant Production Leader should review their process with the Reactive Chemicals Committee within 90 days of assuming responsibility for a pilot or production plant. Prior to the review, the Leader should acquire training on the chemistry and processes that they are working with. This should include an evaluation of raw materials, processes, products and waste to understand any potential reactive chemical hazards. They should review and be prepared to answer questions from the completed and updated RC/PHA protocol questionnaire as well as other relevant materials in their plant Process Safety Folder, such as F EI, CEI, etc. The review should cover all auxiliary operations to the process such as raw material and product storage drum, tank car and truck loading. 

NRC (2007), Identification of Potential Hazards in Site Vicinity , Section 2.2.1-2.2.2 of Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, Report NUREG-0800, March. 

The ultimate responsibility for the safety of a process facility lies with the senior management. A company s senior and local management should therefor ensure the appropriate process hazard analysis reviews are undertaken. (Appendix A provides an example of a typical statement from a company s CEO). 

Review and revise the Incident Action Plan Safety Analysis (HlCS Form 261) and implement correction or mitigation strategies. ... 

The first task, hazard identification, is crucial in process system safety analysis, because the effectiveness of the other two tasks depends on it. The traditional methods for identifying hazards during the 1960 s (including process reviews , codes of practice , checklists , and safety audit ) were no longer considered adequate in the 1970 s. There was a need for a technique which could anticipate hazardous problems, particularly in areas of novelty and new technology where past experience was limited. 

At this phase no technical hurdles are anticipated. Future actions include conducting a safety design review (HazOps analysis), establishing an activity-based target date for a critical design review, and generating a system level functional specification document which will help define the research boundaries for this project. 

A food additive may have screened out of a safety analysis since there are no hazards associated with the product, but the potential for tampering with a loaded tank truck or rail car may raise the concern of potential contamination of the product. Therefore, a review of the measures in place to prevent and detect tampering at the origin, along the route, and at the destination may be warranted. 

A tank track of flammables may have ranked low in a safety analysis as the consequence footprint of such materials can be much smaller than that of toxics. But, if an attack along this route has the ability to result in a consequence that could significantly damage a critical transportation route and result in an extended shutdown for cleanup and repair, then this segment of the route may warrant escalation in the security review. Also, the shipment could be hijacked, enabling the flammables to be diverted from the planned route. 

As discnssed in Chapter 3, the results of the initial company-level prioritization were based solely on the chemical hazards and identified facihties whose transportation operations would require a facihty/operational level review. The focus of this example is on the security of the hazardous materials in and out of a single XYZ Chemical facihty, and is the same Asian plant that was evaluated for safety issues in Chapters 4 and 5. In addition to the corporate directive to evaluate transportation safety risk at this facihty, the site security manager was informed of the need to complete a security risk analysis of the hazardous materials in transit. To inihate the security review, the security manager and health and safety manager met to review the findings of the safety analysis. In addition to focusing on chemicals and hazards from the initial safety prioritizahon, the security prioritization process also considers ... 

---