Overview of Key Health and Safety Requirements

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1 Overview of Key Health and Safety Requirements Key stages in a project and who needs to be involved Responsibilities of the different parties There are a variety of people who may need to be involved with the commissioning, purchasing, building and installing of a new AD plant. There will then be a testing and handover phase, followed by ongoing operations and maintenance. The list below shows some typical functions. For some projects, one company may carry out a number of the functions. In other cases, small consortia of companies may be formed to carry out the project. Regardless of how the groups are formed, there are basic responsibilities from a safety perspective, which need to be allocated and managed correctly. The following provides an overview of the responsibilities of these people and organisations. The site owner/client The owner provides the location, which impacts on the safety, design and operation of both the plant and any potential impacts on the surrounding area. Under the regulations, it is the owner who chooses to build the plant and to operate it and is, therefore, ultimately responsible for all aspects of the plant, equipment, ongoing operations and maintenance, from a regulation perspective.

2 Plant designers Designers of the plant are responsible for ensuring that the design is fit for purpose, including, crucially, a Hazard and Operability Study (HAZOP), which will involve those, who will build and commission the plant as well as those who will eventually operate it. Local Authorities, planners etc A number of formal permissions need to be obtained before any site work is carried out. These are Planning Permission, Building Consents, Building Regulations and Environment Agency (EA)/Scottish Environment Protection Agency (SEPA) permission. The latter includes agreement for emission points, such as relief valves, as well as drain outlets. Plant and equipment suppliers Although the site owner is responsible for having chosen to use a particular piece of equipment, the supplier should ensure that they comply with Clause 76 of the 2008 edition of the HSE approved code of practice for Safe use of working equipment, which begins: If you provide work equipment for use at work where you do not control its use or the premises where it is to be used, you should still ensure that the work equipment complies with PUWER 98 (Provision and Use of Working Equipment Regulations). Site preparers Those who are engaged in any preparation activities such as clearing the site, building the foundations, providing access routes, drainage and other building services need to be aware of both building regulations and CDM (construction design and management) regulations. Plant installers CDM (Construction Design Management) regulations apply. CDM requires the designer to consider the mitigation of risk in their design for those that will construct, operate and maintain the plant and equipment. Suppliers should not just consider construction alone. Operators Those who are engaged in the ongoing operation of the plant need to be appropriately trained and fully informed of all of the safety processes and procedures agreed and handed over by the designers and constructors of the plant. They must follow all incident prevention and reporting procedures. In particular, where a plant is designed to be operated by a specific number of people, it is important to ensure that the correct number is actually engaged on site. As the plant is established in regular use, it is important to ensure that all new operators brought in are fully trained as above. Plant Maintainers Those who maintain plant on an on-going basis, must provide a safe system of work (i.e Permit to Work) for the operators and be supplied with all relevant operational procedures and safety documentation. They must ensure that related processes are managed properly and maintained safely whilst they carry out their work.

3 The safety issues to be addressed at each stage There are a number of points in the life of a project where safety reviews need to be carried out. The operation of an Anaerobic Digestion plant and associated processes, such as CHP engines, involves conformance with a number of European and UK regulations. These are applicable not only when a plant is first built but through its operational lifetime and particularly if modifications and improvements are made or changes are planned for the surrounding environment. In planning, commissioning, building and operating an Anaerobic Digestion plant and its associated processes, a number of formal safety assessments must be carried out. Planning Permission and Building Regulations from the Local Authority This needs to be obtained once an outline design of the plant and its potential location have been established DSEAR Regulations DSEAR (Level 1 Overview) DSEAR (Dangerous Substances and Explosive Atmospheres) Regulations (2002) incorporates EU requirements referred to as ATEX ATEX 137 Safety of Workers in potentially explosive atmospheres and Chemical Agents Directive, brought together by the Health and Safety Executive (HSE) as DSEAR. HSE Approved Codes of Practice and Guidance (ACOP) gives a list of topics and provides the HSE interpretation of the requirements of DSEAR. It covers: Dangerous Substances and Explosive Atmospheres Design of plant, equipment and workplaces Storage of dangerous substances Control and mitigation measures Safe maintenance, repair and cleaning procedures Dangerous substances can put peoples safety at risk from fire and explosion. DSEAR puts duties on employers

4 and the self-employed to protect people from risks to their safety from fires, explosions and similar events in the workplace; this includes members of the public who may be put at risk by work activity. DSEAR is a legal requirement. In these regulations dangerous substances are those, which can put peoples safety at risk from fire and explosion. The objective of the AD process is to produce a gas rich in methane, which is flammable, and in some circumstances explosive. It should also be noted that some waste handling processes, which feed into AD, may create combustible dusts and these areas will also be subject to DSEAR regulations. The DSEAR regulations require designers and operators to put suitable safety controls in place to prevent fires and explosions. DSEAR also covers issues such as training, signage, inspection and maintenance, change control. A brief summary flow chart is given below. There is a need to identify fire and explosion hazards, assess the risk and identify suitable mitigation measures. If no other solutions can be found then controlling potential ignition sources by defining Hazardous Areas is the next option. Hazardous areas are the final line of defense. Equipment designed to be installed in Hazardous areas incorporate design features which reduce the likelihood of ignition. DSEAR COMPLIANCE Existing Plant/Equipment (eg: Flare tower) Common to Both (e.g. Flare off excess biogas) New/Modified Plant (e.g. new stack extension) Identify & Assess Fire and Explosion Hazards (e.g. enclosed high temperature flame + failure of ignition system for biogas risk) Complete Plant Risk Assessment ALARP = As Low As Reasonably Practicable Is Risk ALARP Identify Additional Measures to Reduce Risk (e.g. ignition failure sensor, warning boards for when flame is ignited) Classify Hazardous Areas (e.g. CHP and Flare compound) Background to DSEAR (Level 2) The risk of fire or explosion of flammable materials in industrial processes has been recognised as a major issue for many years. The Oil, Gas, Chemical and Mining (released methane) industries have for many years installed equipment specifically designed to reduce the risk of ignition.

5 DSEAR also applies to powders. Dense clouds of fine organic material (such a flour or sugar) can (and has) explode with significant, sometimes fatal results. This is especially prevalent for anaerobic digestion where a biological process can cause chemicals and substances to react rapidly. This is can be seen with sudden ph or temperature changes. The DSEAR regulations 2002 have three basis requirements: All flammable material on a site be identified and then risk assessed; Where necessary control of ignition sources should be achieved through Hazardous Area classification; Management systems should be in place to maintain risk control measures. The risk assessment should consider all process activities, e.g. normal operation and start-up, shut-down, sampling, cleaning etc. This should identify where risks must be controlled through control of ignition sources, i.e. Hazardous Area classification. For example, if CHP failure occurs there needs to be a means of dealing with the excess production of biogas. Hazardous Area Classification Flammable mixtures can exist in and around equipment. For example a tank storing flammable material could have a flammable atmosphere inside the tank and around any tank vents. This flammable atmosphere could be present continuously. The pump, which transfers the flammable material, is normally sealed, i.e. there is no flammable atmosphere outside the pump. However, during maintenance or a periodic small leak on the pump there will be flammable atmosphere this may only occur less than 10 hours per year. A distance can be estimated for the size of the flammable atmosphere depending on the material itself and the size of the leak. For the different durations of the flammable atmospheres (e.g. continuous or less than 10 hours per year) there are different Zones classifications. For continuously present flammable atmospheres the equipment is designed to reduce the likelihood of ignition more than for the situation where the flammable atmosphere is only present less than 10 hours per year. This is a highly technical area. For hazardous areas there should be clearly marked signs ( Ex signs) and controls people should not carry un-classified electrical equipment into the area, such as testing and sampling equipment. The equipment installed in the area (electrical and mechanical) must be designed for the application and be suitably Ex rated. DSEAR management systems As discussed above, equipment should be designed and installed for the Hazardous Area. However, management systems are required to ensure these risk control measures remain in place. Equipment needs to be periodically inspected to ensure it has not been damaged and the protection de-graded. This must be done by competent people. Maintenance staff must also be competent and trained in Hazardous areas. The area must have appropriate signage to ensure visitors, external maintenance staff etc., are aware of the Hazardous area and do not bring other ignition sources into the area. There needs to be a safe system of work in place to control activities in Hazardous areas welding and grinding should not be allowed while there is the potential for a flammable gas cloud to occur. Non-sparking tools should be used in the area. Those working in the area should wear anti-static work-wear. Below is a summary flowchart.

6 Classify Hazardous Areas Provide EX Signage Validate Equipment Installed in Zoned Areas Identify Personal Protective Equipment Is All Equipment Suitable for Zone Type Replace/Relocate or Demonstrate Basis of Safety Review & Update Programme of Planned Inspection/Maintenance Audit/Review Revise and Implement Employee Training/Awareness/Instruction Information is also available at: HSE The HSE document most relevant is L138, which provides an overview of DSEAR requirements Location for free HSE ACoP downloads (example) DSEAR Frequently asked questions ESA ICoPS (Landfill gas generation but similar types of issues to AD). HAZOP Study What is a HAZOP? (Level 1 Overview) A HAZOP (Hazard and Operability) study is a structured and systematic assessment of a process design that is used to identify and evaluate possible risks. It applies to existing or planned processes, provided design specifications and information are available. The HAZOP team would comprise of a committee of all involved in the operation, design and construction of the process. There is a Chair, who should be experienced but not involved in the process and a Secretary. The remainder of the committee can vary with roles such as designer, user/operator, constructor, maintainer etc being involved. The team uses a set of guidewords to challenge the design. The design intent (the purpose of a piece of equipment or system) is identified and the team then look at deviations: what can cause the deviation, how

7 significant this is and what controls are in place. For example, if a tank is designed to mix slurry, a deviation would be NO mixing due to stirrer gear box failure, motor failure or power loss. It follows the flow chart below. The output is a structured report, giving a qualitative assessment of each part of the process. Define design intent (e.g. mix slurry) Consider guideword (e.g. NO No Mixing) List causes (e.g. motor failure, power failure, shaft failure). Assess consequences (solids fall to bottom tank needs to be dug out loss of 3 days operation). Identify controls (e.g. Alarm if agitator not turning) Identify additional actions (e.g. plan maintenance check on motor every 6 months) Repeat for all guidewords Example: This example shows the HAZOP technique as it has been applied to an AD plant. Each plant is different (different feedstock and /or equipment) and so each requires it s own HAZOP. The objective of the HAZOP study is to ensure the design is robust, that all the safety / environmental and operability issues are identified and adequate controls put in place. It should enable the process to be commissioned more quickly and reduce safety / environmental risks during the operation of the plant. If implemented at the Design stage of the project and before the major equipment items are ordered it can also save money and prevent expensive retrofits being needed to correct risks, which could have been identified and removed earlier. The standard for HAZOP is IEC61882 and this defines the minimum standard to be achieved.

8 A HAZOP is normally carried out by a team of people consisting of a chairman together with the designer(s) and those operating and maintaining the plant. A HAZOP is specific to a particular design and is undertaken once the main design is developed but before it is completed. Description of the Method (Level 2) HAZOP studies were developed in the early 1970s by ICI, a major chemical manufacturer of that time. They were used to assess the designs of the chemical processes from inception through design to post construction activities. HAZOP studies are sometimes used to describe a range of safety studies. For the detailed HAZOP the documents that are typically used are the piping and instrumentation diagrams (P&IDs) or Engineering Line Diagrams (ELDs). These P&IDs are split into different systems or nodes and a team would perform a logical study of the system. This team usually contains system designers, operators, maintenance technicians, instrument engineers and safety representatives. If there is any need for a specialist input then these people could be drafted in as and when required. The method involves applying a set of deviation guidewords to the design intent of each system in turn. A typical range of deviation guidewords are provided below:

9 (DO) HAZOP Guidewords & their Generic Meanings Material: Quantity Activity Properties Intended material with properties at Design Conditions. One or more intended activities. No No stirring taking place Intended and any other activities do not occur. Further Applications: Source/Destination. Time. Intended sources and Destinations. Time : Duration, Sequence N/A More Less Reverse As Well As More stirring than needed Greater physical properties, e.g. High Temperature Less stirring than needed Lower physical properties, e.g. Low Temperature Logical opposite of intended material, e.g. Acid instead of Alkali, Hot instead of Cold. An additional component in the material. More of the intended activity, e.g. high flowrate or excessive heating. Less of the intended activity, e.g. low flow-rate or inadequate heating. Logical opposite of intended activity, e.g. cool instead of heat or reverse flow. An additional activity, e.g. Heat & Transfer when only transfer is intended. Destination : N/A Too much time (duration). Later. Destination : N/A Too little time (duration). Sooner. Source and destination reversed possibly via circuitous route. Batch sequence reversed. Additional sources or destinations, e.g. drain, gland leak. Part Of One or more components in a multicomponent mixture is/are missing. One or more of the intended activities is not done, e.g. transfer but not heat. Less sources or destinations if multi-feed or destination. Other Than A totally different material. A totally different physical condition, e.g. frothing. A totally different activity. All the material taken from totally different sources or destinations. For each system studied the design intent (i.e. purpose of the equipment) is established by the team or the designers. The guidewords are then applied logically to the system to determine what the possible causes of deviation from that design intent might be. The consequences of the deviation are evaluated along with the various safeguards to protect the system. If these safeguards are considered adequate then the study proceeds to the next guideword. If additional safeguards are considered necessary or more information is required then the assembled team can make an appropriate recommendation. The recommendations or actions are then investigated and the responses recorded. This procedure may then be followed by a review meeting where the written responses are reviewed and agreed on by the team. In undertaking a HAZOP study at whatever stage there must be a certain level of competence in the team selected. The reason for selecting a team of diverse individuals is to provide as broad a cross section of the disciplines as possible to try to identify potential issues with the design. It is also important that the team approach the study with an open mind and an inquiring attitude so that the design and operation can be effectively explored. Contractual difficulties and a defensive attitude can be significant contributors to

10 undermining the effectiveness of a HAZOP study. Information is also available at: Functional Safety Management Functional Safety Management is the term used to describe the overall safety of a plant or process. It sits above the safety and design of individual components or pieces of equipment and focuses on how they are integrated together to construct a plant or process. It assesses whether the system or equipment is designed to operate correctly in response to its inputs, including the safe management of likely operator errors, hardware failures and wider environmental changes. The standards which govern it are BS EN and IEC 61511; these are now the universal standard by which the Health and Safety Executive measures safety systems. As part of Functional Safety Management, there are a number of regulations and formal assessment methods used. For more information see SIL Safety Integrity Level and SIF Safety Instrumented Function SIL describes the reliability required while SIF describes the system. A SIL loop is an electronic safety system implemented to take over should there be a failure in the underlying process, which would otherwise create an unacceptable level of risk. If the process itself is capable of meeting and dealing with all the levels of risk deemed adequate, there is no need for a SIL. With proper consideration of safety requirements at the early stages of plant design through the HAZOP process, it is unlikely that there would be a need for SIL loops in a normal AD Plant. Further information, tailored to needs of people involved in Functional Safety from different perspectives such as owner, designer, maintainer, operator etc is available at Flares to Burn Waste Gas All biogas processing facilities include Flares which are primarily used to burn any excess biogas that is surplus to the demands of the CHP engines or when the CHP engines are not available. Flaring is used to destroy flammable, toxic or corrosive vapours, particularly those produced during process upsets and when gas has to be released in an emergency. The flare is a crucial piece of equipment for the operation of the plant as, if the flare is not available, waste gas will potentially have to be vented (released to the atmosphere) with attendant safety risks. Hence the flare system must be engineered for maximum reliability. Flares are generally designed to the American Petroleum Industry standards API 537 (Flare Details for General Refinery and Petrochemical Service, September 2003) and API 521 (Pressure relieving and Depressuring Systems, 2007) and British Standard BS 5908 ( Code of practice for fire precautions in the chemical and allied industries) For the specific example of flaring biogas, there is also a publication from the Environment Agency (Guidance on Landfill Gas Flaring Version 2.1). It is important that the design provided by the Flare Manufacturer satisfies these standards and guidelines.

11 Table showing timeline, activities and responsibilities Typical timescales Who needs to be involved? What needs to be done? Design and Planning Build and Handover Operate and Commission Maintain 12 months 12 months 3 months 20 years The site owner Plant suppliers Planning Contract specification and documentation review. Include identification of any basic hazards associated with the plant and its intended location. This includes surrounding buildings and sites. e.g. Schools, offices, communities etc. Design review for both safety and operability (HAZOP) for DSEAR. The site owner Plant suppliers Construction Pre-fabrication formal safety review HAZOP Involve Designers, builders, fabricators, and operators The site owner Suppliers Operators Maintainers DSEAR Regulation 7 Handover to ensure that all safety issues identified in the Design Phase are addressed and all documentation is complete. Involve main contractors, site owner and operators The site owner Operators Maintainers HAZOP safety review for any changes or modifications. Involve Designers, builders, fabricators, and operators Security and Public Access Anaerobic Digestion facilities are complex process plants, incorporating a number of different technologies and producing materials, some of which are potentially toxic and harmful. It is important, therefore, that the surroundings of the site and the potential for untrained staff to visit are considered during all phases of the design, construction, commissioning and operational phases. For example, a plant designed to take municipal waste may be adjacent to a waste disposal site where members of the public bring waste. A site located at a college will need to allow students to see and experience the plant s operation. A facility located on a farm will need to integrate with the other working aspects of the farm and allow access for the input material to be delivered and the resulting digestate to be removed for use on the land. The surrounding location will vary from site to site, with some adjacent to residential and community facilities (e.g. schools, offices, factories etc) and some in rural locations. There are two main bodies to be consulted in planning the location of the site the HSE and the local Planning Authority. They will advise on the necessary guidelines to be adopted and the policies, procedures and security measures to be put in place. Other Standards, Definitions and Organisations HSE Health and Safety Executive SIESO Society of Industrial Emergency Services Officers COMAH Control of Major Accidents and Hazards. Regulations. Sites are graded and the HSE is generally only interested in top-tier COMAH sites. AD Plants will generally be in the lower tiers

12 BS EN 61508, also known as IEC Functional Safety of Electrical/Electronic/Programmable Electronic Safety Related Systems. They require that the company/organisation makes a conscious decision on the level of tolerable risk for a system. There is no set value proscribed. If, however, a company has issued a COMAH report, then the fatal accident rate is specified in it. That same value must be used for the SIL assessment Industry bodies may give recommended levels UKAS UK Accreditation Service. Covers the Certification of functional safety management, (valid internationally) ATEX French standard for Europe Atmosphere Explosif. (the EAR half of DSEAR) Hierarchy of Importance 1. UK Law Health and Safety at Work act 2. UK Government Department regulations 3. EU Law see EN on a standard etc. 4. HSE Guidance Approved Code of Practice - ACOP 5. British Standards 6. International Standards 7. Industry Codes of Practice 8. Industry guidance/other guidance

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