Construction of Boysun GPP ALARP Demonstration Study Report ALARP DEMONSTRATION STUDY REPORT BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C C 10.11.2021 Issued for Review Prashant Mali Lasha Nodia Leonid Asaftei B 17.08.2021 Issued for Review Prashant Mali Lasha Nodia Leonid Asaftei REV. Date Revision Purpose Originated Checked Approved 1 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report REVISION LOG SHEET Revision B C Date 17.08.2021 10.11.2021 Audit objective Issued for Review Issued for Review Originated Prashant Mali Prashant Mali Checked Lasha Nodia Lasha Nodia Approved Leonid Asaftei Leonid Asaftei HOLDS Hold # Hold Description 2 / 43 Page BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report TABLE OF CONTENTS Page ABBREVIATIONS USED.................................................................................................................................... 6 REFERENCES ................................................................................................................................................... 7 1. INTRODUCTION ...................................................................................................................................... 8 2. SCOPE & OBJECTIVE ............................................................................................................................ 9 3. 4. 2.1 Scope ......................................................................................................................................... 9 2.2 Objective.................................................................................................................................... 9 GENERAL INFORMATION .................................................................................................................... 11 3.1 Project location ....................................................................................................................... 11 3.2 Project Information ................................................................................................................. 13 3.3 General Project Description ................................................................................................... 13 ALARP PROCESS ................................................................................................................................ 16 4.1 4.2 4.3 5. 6. 7. Introduction ............................................................................................................................. 16 4.1.1. Risk Reduction .......................................................................................................... 16 4.1.2. ALARP ....................................................................................................................... 17 Approach - Demonstrating ALARP........................................................................................ 18 4.3.1. Good Engineering Practice ...................................................................................... 18 4.3.2. Effective Hazard Management Strategy .................................................................. 19 Cost Benefit Analysis ............................................................................................................. 21 RISK ACCEPTANCE CRITERIA ........................................................................................................... 22 5.1 Individual Risk Acceptance Criteria ...................................................................................... 22 5.2 Societal Risk Acceptance Criteria ......................................................................................... 22 OVREVIEW OF PROCESS HAZARD ANALYSIS (PHA) STUDIES...................................................... 24 6.1 HAZID/ENVID Study ................................................................................................................ 24 6.2 HAZOP Study .......................................................................................................................... 24 6.3 FERA Study ............................................................................................................................. 25 6.4 QRA Study ............................................................................................................................... 25 MAJOR HAZARDS FROM PHA STUDIES ........................................................................................... 26 7.1 High Risk Scenarios from HAZID/ENVID .............................................................................. 26 7.2 High Risk Scenarios from HAZOP Study .............................................................................. 26 3 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report 8. 7.3 FERA ........................................................................................................................................ 29 7.4 QRA .......................................................................................................................................... 31 location Specific Individual Risk (LSIR) Results .................................................... 31 7.4.2. Societal Risk Results................................................................................................ 32 ALARP DEMONSTRATION................................................................................................................... 33 8.1 9. 7.4.1. Overview of ALARP Demonstration from QRA Study.......................................................... 33 8.1.1. location Specific Individual Risk (LSIR) Results (Including Modification Factor)34 8.1.2. Societal Risk Results (Including Modification Factor)........................................... 36 8.2 HAZID Study Recommendations ........................................................................................... 37 8.3 HAZOP Study Recommendations ......................................................................................... 37 8.4 FERA Study Recommendations ............................................................................................ 37 8.5 QRA Study Recommendations .............................................................................................. 38 8.6 Review of PHA Recommendations ........................................................................................ 39 CONCLUSION ....................................................................................................................................... 43 LIST OF TABLES Table 1: Risk Acceptance Criteria Table 2: High Risk Hazards from HAZID Study Table 3: High Risk Hazards from HAZOP Study – Unit 213 (Representative Case) Table 4: Impact of Fire & Explosion on Buildings from FERA Study Report Table 5 – Location Specific Individual Risk Value Table 6 – Top Ten Risk Integral Table Table 7: Probability of Failure on Demand for Independent Protection Layer Table 8 – Location Specific Individual Risk Value Table 9- High Risk Contributors for Risk Ranking Locations at ALARP Table 10 – Effect Level Risk Contributors for Risk Ranking Locations Table 11: Review of PHA Recommendations 22 26 26 29 31 33 33 34 34 35 40 LIST OF FIGURES Figure 1: Risk reduction Hierarchy Figure 2: ALARP (General Representation) Figure 3 – Individual Risk Criteria Figure 4 – Societal Risk Criteria (FN Curve) Figure 5 – Multilevel Individual Risk Contour for Boysun Gas Processing Plant (BGPP) Figure 6- F (Frequency) & N (Number of fatalities) Curve for Boysun Gas Processing Plant 4 / 43 16 17 22 23 31 32 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report Figure 7 – Multilevel Individual Risk Contour for Boysun Gas Processing Plant (BGPP) Figure 8- F (Frequency) & N (Number of fatalities) Curve for Boysun Gas Processing Plant 5 / 43 34 36 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report ABBREVIATIONS USED Abbreviation AGR Concept Acid Gas Removal AGRU Acid Gas Removal Unit ALARP As Low as reasonably Practicable BDV Blow Down Valve BGPP Boysun Gas Processing Plant CFD Computational Fluid Dynamics EEN Enter Engineering (Client - EPC Contractor) ENVID Environmental Hazard Identification EPC Engineering, Procurement and Construction ESD Emergency Shutdown FEED Front-End Engineering Development FERA Fire & Explosion Risk Assessment GPP Gas Processing Plant HAZID Hazard Identification HAZOP billion standard cubic meters per annum HSE Health Safety Environment IDLH Immediately dangerous to Life & Health IRPA Individual Risk Per Annum LSIR Location Specific Individual Risk MOC Management of Change PFD Process Flow Diagram PPE Personnel Protective Equipment PSM Process Safety management PSV Pressure Safety Valve QRA Quantitative Risk Assessment SCE Safety Critical Element SGCOC Surhan Gas Chemical Operating Company FC LLC (COMPANY) SOP Standard operating procedure SRU Sulfur Recovery Unit U&O Utility Facilities & Offsites 6 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report REFERENCES Sr. No. 1 2 Doc. Title Doc. Number Fire and Explosion Risk Assessment Study - Boysun Gas Processing Plant Quantitative Risk Assessment Report of Boysun Gas Processing Plant (BGPP), Surkhandarya, Uzbekistan. J-7011-S-RT-1802-Rev 01 J-7011-S-RT-1801-Rev 01 3 License HAZOP Study 1736_LICENSE_HAZOP_Rev A 4 Open Art HAZOP Study 1736_OPENART_HAZOP_Rev A 5 Utility Art HAZOP Study 1736_UTILITY_HAZOP_Rev A 6 HAZID/ENVID Report BGPP-WOOD-F-200-000-0-HS-REP-00001-E 7 Basic Engineering Design Guidelines BGPP-UZLE-D-200-000-AL-BOD-00001-E-R3 8 Active Fire Protection Philosophy 9 Passive Fire Protection Philosophy BGPP-UZLE-D-200-000-0-HS-PHI-00002-E-R1 10 Fire And Gas Detection Philosophy BGPP-UZLE-D-200-000-0-HS-PHI-00003-E-R2 11 Process Safety Design Philosophy BGPP-UZLE-D-200-000-0-HS-PHI-00004-E-R1 12 Escape, Evacuation Philosophy BGPP-UZLE-D-200-000-0-HS-PHI-00005-E-R1 13 Instrument Automation Philosophy BGPP-UZLE-D-200-000-0-IN-PHI-00001-E-R1 14 Emergency Isolation and Depressurization Philosophy BGPP-UZLE-D-200-000-0-PR-PHI-00001-E-R2 15 Drainage Philosophy BGPP-UZLE-D-200-000-0-PR-PHI-00002-E-R1 16 Overpressure Protection Philosophy BGPP-UZLE-D-200-000-0-PR-PHI-00003-E-R3 17 Systems And Equipment Isolation Philosophy BGPP-UZLE-D-200-000-0-PR-PHI-00007-E-R1 18 Safeguarding And ESD Philosophy BGPP-UZLE-D-200-000-0-PR-PHI-00020-E-R1 BGPP-UZLE-D-200-000-0-HS-PHI-00001-E-R1 - AFP 7 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report 1. INTRODUCTION The project envisages the construction of a new Gas Processing Plant (hereinafter named GPP) to partly produce a treated gas suitable for domestic use or export, produced at gas field “Mustaqilligning 25 yilligi” located in the Surkhandarya region of the Republic of Uzbekistan. The gas field will process 5 BCMA of raw natural gas with high content of CO2 and H2S, processed in a Gas Processing Plant (hereinafter named GPP) to partly produce a treated gas suitable for domestic use or export. GPP will be fed by Raw Natural Gas, connected from gas field to GPP inlet battery limits through seven (7) dedicated gas pipelines (one from each of the cluster pads) connected to an inlet manifold. GPP shall consist in two (2) parallel trains, each train designed for 2.5 BCMA and basically consisting of the following main units: • Inlet Gas Separation Unit • Acid Gas Removal Unit (AGRU) (licensed by Shell) • Dehydration Unit • Sulphur Recovery Unit (SRU) (licensed by Shell) In addition to these, there are other main units common to both trains: • Sulphur Solidification Unit • Sour Water (Chemical Oxidation) Unit (licensed by Shell) • Utility Facilities & Offsites (U&O) 8 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report 2. SCOPE & OBJECTIVE Scope 2.1 The Scope for ALARP Demonstration study is limited to Surhan Gas Chemical Operating Company (SGCOC) Boysun Gas Processing Plant (BGPP), Uzbekistan. Following units are included in BGPP. Unit Code 210 211 212 213 214 215 216 217 218 219 241 242 243 251 253 261 263 264 265 266 280 290 291 292 410 460 470 710 715 Description Inlet Manifold Test Separator Inlet Separator Unit Sulfinol M Sulfinol X SRU Dehydration Unit Sulphur Granulation Unit Chem Oxydation Formation Water Treatment Steam and BFW Generation Steam Condensate Polishing Heating Water System Service Ins Air Nitrogen System Raw Water Distribution Fire Water System Cooling Water Potable Water Demin Water Treatment Fuel gas Flare system Sweet flare Acid flare Sulphur Storage System Waste water treatment Chemical Storage Normal Power Supply Emergency Diesel Generator Objective 2.2 The objective of the study is to confirm that risk reduction to ALARP levels at the BGPP facilities are demonstrated using the following hierarchy of techniques, depending on the nature and complexity of the risk: 1. Engineering judgement 2. Qualitative risk assessment (HAZID/HAZOP) 3. Quantitative risk assessment (FERA/QRA) 4. Analysis of ALARP proposals 5. Cost-benefit analysis 9 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report All risks and particularly those associated with the major hazards of fire, explosion and loss of containment, shall be demonstrated to be ALARP and reported accordingly. The project design philosophy has ensured throughout that risks to plant personnel, third parties and the environment are not increased so that they exceed the Project Risk Acceptance Criteria and are demonstrated to be as low as reasonably practicable (ALARP). The approach proposed to effectively achieve this objective is summarised as: • Prevention of incidents stemming from accidental loss of containment and; • Efficient control of any such incident, should one nevertheless occur. These objectives has been assured by using a risk based approach to the design of the facilities, applying the appropriate Codes and Standards and quality assurance procedures, all reinforced by Safety Reviews undertaken at key stages in the design process. 10 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report 3. GENERAL INFORMATION 3.1 Project location The working area is located 100 km Northwest of Termez in the Boysun district of Surkhandarya region, 7.7 km Southeast of the village of Kofrun. Legend Clusters Project export gas pipeline DIN 800 mm. Project water pipeline Project collectors from well pad Project water pipeline 11 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report Legend Project water pipeline Project FOCL Notes: From the starting point of parallel laying of water conduit and FOCL line to the GPP, laying of project utilities shall be carried out in one corridor. 12 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report 3.2 Project Information PROJECT INFORMATION Project Name: EPC Contractor: COMPANY: Boysun Gas Processing Plant (BGPP) Enter Engineering Pte. Ltd. (EEN) Surhan Gas Chemical Operating Company FC LLC (SGCOC) DD Subcontractor Uzliti Engineering LLC Official name of the production site: Mustaqilligning 25 yilligi Location of the production site: 3.3 Boysun district of the Surkhandarya region in the Republic of Uzbekistan Location type: Greenfield Project type: DD (Detail Design) General Project Description Regarding the layout of the plant, the GPP is divided in three different main areas, interconnected between them: • GPP Main Area: containing most of the process and utility units, and the flares area. Water Treatment Area (containing the raw water and wastewater treatment units) to be located within GPP main area. • Sulfur Handling Area: located SW and away about 100 m near to the main GPP area, connected by means of one liquid Sulfur pipeline, and containing the units for Sulfur solidification and solid Sulfur storage, handling and loading in truck or trains. Raw Gas Field (Out of GPP SOW) N Raw Gas Pipelines (by others) Raw Water Sources (Out of GPP SOW) Raw Water Pipelines (Out of GPP SOW) Sulfur Handling Area GPP Main Area Flare Liquid Sulfur Pipelines Location is on HOLD (HOLD 01) Surhan Gas Chemical Operating Company (SGCOC) plans to develop “Mustaqilligning 25 yilligi” (M25) gas field, which is located in the Boysun District, Surkhandarya Region, in the Republic of Uzbekistan. The overall project development includes drilling of production wells, construction of the gas gathering system (9 compressor stations), the Gas Processing Plant (GPP), associated utilities / pipelines and other supporting facilities, 13 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C C Construction of Boysun GPP ALARP Demonstration Study Report infrastructure, and common utility systems necessary for safe operation and maintenance of the complex. The design total capacity of the M25 field for new GPP facilities is 5 billion standard cubic meters of reservoir fluid per year (5 BCMA). The overall GPP includes all processing units, utilities, offsite and infrastructure necessary to produce sales gas (will be exported through one existing gas pipeline, and a new one will be built) and elemental (granules or blocks) Sulfur. • Inlet Gas Separation Unit Raw inlet gas is sent to three-phase separator to remove liquid water, with dissolved CO2 and H2S. Acid water with dissolved H2S and CO2 shall be routed to sour water stripper (Formation Water Treatment System), while raw gas shall be processed in Acid Gas Removal Unit. Although no hydrocarbon liquid is expected, it is taken into consideration to be sent to Formation Water Treatment (Unit 219) in case of presence. • AGR Unit The primary purpose of the Acid Gas Removal (AGR) unit is the removal of acid gases, H2S and CO2, to a level compatible with the quality requirements of the treated gas for export. • Sulfur Components Absorber section (Sulfinol-M Unit) In the first step, H2S and mercaptans are removed by means of a hybrid amine solvent (Sulfinol-M) that is selective for H2S removal and is effective in mercaptan removal. The resulting CO2 concentration in the treated gas of the Sulfinol-M absorber is 7-8 mol%. The feed gas is supplied from the inlet separation unit and enters the feed gas knock-out drum, where remaining liquid in the gas is separated. From this KO drum, the gas is sent to the absorber where it is contacted countercurrently with lean Sulfinol-M solvent. The treated gas then goes to the treated gas knock-out drum provided with demister to prevent entrainment of Sulfinol-M components to the downstream Sulfinol-X Unit. The solvent is brought into the main Sulfinol-M absorber by a charge pump. Semi-lean solvent coming from the SCOT Absorber is brought into Sulfinol-M absorber. The rich Sulfinol- M solvent is flashed in a hydrocarbon flash vessel. A slipstream of lean solvent treats this flash gas stream in the flash gas absorber to remove H2S, and the flash gas is routed to the incinerator. The loaded solvent from both the main absorber and the flash gas absorber is routed via a Lean/Rich heat exchanger to the regenerator. • CO2 and COS Absorber Section (Sulfinol-X Unit) In the second step, CO2 and COS are removed by means of a hybrid amine solvent (Sulfinol-X) that is selective for CO2 and COS removal. Treated gas is supplied from Sulfinol-M unit and enters the Sulfinol-X main absorber where it is contacted counter-currently with lean Sulfinol-X solvent. The treated gas then goes to the treated gas knock-out drum provided with demister to prevent entrainment of Sulfinol-X components to the downstream Sulfur Recovery Unit. The solvent is brought into the main Sulfinol-X absorber by a charge pump. The rich Sulfinol- X solvent is flashed in a hydrocarbon flash vessel. Flash gas is routed to the incinerator. The loaded solvent is routed via a Lean/Rich heat exchanger to the regenerator. 14 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C C Construction of Boysun GPP ALARP Demonstration Study Report • Dehydration Unit Mercaptans are fully removed by Sulfinol-M Unit and Mercaptans concentration of the treated wet gas at the exit of AGR unit. • Sulfur Recovery Unit The Sulfur Recovery Unit (SRU) processes the main acid gas from the Acid Gas Removal, together with other small flash gas containing off-gas streams coming from other units. The SRU consists of a Claus Units for each line with low-pressure oxygen used as oxidant of Claus reaction. • Sulfur Solidification Unit Sulfur Solidification Unit shall be one of vendor package items intended to convert the liquid Sulfur in solid Sulfur. • Sour Water Treatment (Chemical Oxidation) Unit H2S oxidation process will be used to treat the sour water from Quench Column by applying chemicals like caustic, Sodium Bisulphite, Hypochlorite which are chemicals commonly applied for this treatment. This straightforward approach will achieve the required specification of 5 ppm H2S in the water. • Formation Water Treatment Unit Formation Water Treatment Unit treats part of the contaminated water condensate from Inlet Gas Separation Unit, AGR and SRU (acid water from KO Drum), in order to avoid accumulation of H2S and other dissolved gases (e.g., CO2) in the water. These dissolved gases, in particular the bulk of CO2, H2S contained in the sour water are removed by means of LP stripping steam supplied to the stripping column, where acid injection is applied to prevent scale formation. Water from stripper bottom is sent to WWT, Sour Gas is routed to acid flare system for burning. Once the operation is stable, sour gas will be forwarded to U-215 Sulphur Recovery System. 15 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report 4. ALARP PROCESS 4.1 Introduction 4.1.1. Risk Reduction Risks to personnel or assets may be managed by either reducing the potential (frequency) of an event, or mitigating the consequence of those potential accidents. The measures employed to achieve this can be classified into three main categories: • Inherent Safety/Prevention – safety by effectively removing hazards or minimizing the potential for hazards to be realized. For example, substituting a flammable solvent for an alternative low hazard fluid, or use of fully rated equipment which would protect against a gas break through case from a selection of process options or design basis that aim to achieve inherent upstream vessel of higher pressure. • Detection and Control – provision of measures to detect incidents and control their affects. Examples include gas detection allowing isolation and blowdown of facilities to limit release sizes. • Mitigation - measures that minimize the final consequences when a hazard is realized, such as use of a passive fire protection to limit the damage caused by an ignited release, or escape systems designed to avoid casualties. The above is a hierarchy and the preferred safeguard should always be to design for inherent safety or prevention whenever practicable. Inherent Safety is described below. Inherent Safety At all relevant design stages, effort will be made to manage hazards by the application of Inherent Safety principles rather than control and mitigation methods (after the event). The process being utilized can be illustrated as below; Figure 1: Risk reduction Hierarchy 16 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report Where and if possible (noting that there are some constraints to the following associated with a upgrade/revamp project), the inherent safety features that will be considered by engineers during the design are: • Physical segregation/separation • Reducing inventories/storage quantities • Reduce design pressures, and pressure interfaces (hence potential overpressure scenarios) • Use of corrosion resistant materials. • Reducing leak sources by using welded pipework, as opposed to flanged connections. The premise behind the application of these techniques is that preventing releases / accidents is preferential to mitigating their effects after the initial loss of containment. Subsequent risk reduction measures are important when inherent safety cannot be achieved, and they are generally the requirements of regulation, codes and standards and shall be considered where necessary to reduce risks. The most effective controls are via Elimination, Substitution and then followed by Engineering controls (control and mitigation). E. Eliminating hazards and ensuring inherent safety principles are applied is vital at the concept and design stages. During the operational stage, the emphasis on further risk reduction measures is towards control, mitigation and emergency response measures, as the fundamentals of the design cannot usually be changed meaning that hazards cannot usually be eliminated or substituted. As part of Project Development several safety studies have been performed that has assessed the risk of facility (either qualitatively or quantitatively) by investigating hazard scenarios & risk reduction measures in place. The studies also resulted in range of recommendations to further reduce the risk to ALARP. 4.1.2. ALARP The ALARP (“as low as reasonably practicable”; see Figure below) principle is widely used in the oil and gas industry. The use of the ALARP principle may be interpreted as, satisfying a requirement to keep the risk level “as low as possible.” This involves weighing a risk against the trouble, time and money needed to control it. Thus, ALARP describes the level to which it is expected to see workplace risks controlled. Figure 2: ALARP (General Representation) 17 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report The Health and Safety Executive (HSE) provides the following advice in terms of ALARP (Ref. - HSE Guidance, ‘ALARP at a Glance’): ‘In essence, making sure a risk has been reduced ALARP is about weighing the risk against the sacrifice needed to further reduce it. The decision is weighted in favour of health and safety because the presumption is that the duty-holder should implement the risk reduction measure. To avoid having to make this sacrifice, the duty-holder must be able to show that it would be grossly disproportionate to the benefits of risk reduction that would be achieved. Thus, the process is not one of balancing the costs and benefits of measures but, rather, of adopting measures except where they are ruled out because they involve grossly disproportionate sacrifices.’ 4.2 Approach - Demonstrating ALARP For the BGPP facilities, assurance that the design conforms to the ALARP principles is achieved by the combined application of: • Design according to good practice. • Application of an effective strategy for managing identified hazards with all reasonably practicable improvements implemented. First and foremost it is demonstrated that the design of the facility follows good design principles, complies with statutory provisions, uses appropriate design codes and standards, and follows industry accepted practices with equipment based on proven practices and technology. Once good practice is established, application of an effective strategy for managing hazards is demonstrated. Here risk reduction measures are balanced against cost (in money, time or complexity) of implementing such measures with all reasonable practical improvements implemented unless they can clearly be shown to be “not reasonably practicable”. In making the demonstration it has been attempted to categorize design decisions and measures into those which conform to what is considered to be “good practice” and those which arise from the hazard management process and go beyond what is considered to be good practice. Actual measures involve aspects of both and the division is necessarily subjective. 4.3.1. Good Engineering Practice ‘Good practice’ is defined in the HSE general ALARP guidance (‘ALARP Suite of Guidance’) as: “those standards for controlling risk that HSE has judged and recognised as satisfying the law, when applied to a particular relevant case, in an appropriate manner.” Compliance with statutory provisions and use of appropriate design codes and standards and industry accepted practices provides a robust design basis for the BGPP facilities. The statutory requirements used in the design of the BGPP are presented in the Basic Engineering Design Guidelines (Ref 7). Industry recognized codes and standards to which the BGPP facility designed are detailed in individual discipline philosophy documents and the Basic Engineering Design Guidelines: 18 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report • Active Fire Protection Philosophy (Ref. 8) • Passive Fire Protection Philosophy (Ref. 9) • Fire And Gas Detection Philosophy (Ref. 10) • Process Safety Design Philosophy (Ref. 11) • Escape, Evacuation Philosophy (Ref. 12) • Instrument Automation Philosophy (Ref. 13) • Emergency Isolation and Depressurization Philosophy (Ref. 14) • Drainage Philosophy (Ref. 15) • Overpressure Protection Philosophy (Ref. 16) • Systems and Equipment Isolation Philosophy (Ref. 17) • Safeguarding and ESD Philosophy (Ref. 18) No exceptions to design codes have been identified that would impact risk to personnel. 4.3.2. Effective Hazard Management Strategy Process Safety Design Philosophy (Ref. 11) gives the hazard management Procedure for new installations which are part of the GPP Complex Project to be applied to licensed units (unless licensor special requirements dictate otherwise), open-art units, utilities and offsites. Section 5 gives the risk UK HSE risk acceptance criteria. The QRA (Ref 2) has calculated that the risks to personnel are within the region “risks are tolerable if reduced to as low as reasonably practicable”. This means that the adoption of risk reduction measures beyond those associated with good design practice are balanced against the cost (in money, time, or complexity) of implementing such measures with the emphasis to implement improvements unless they can clearly be shown to be “not reasonably practicable”. Once measures to reduce risk further are shown to be not reasonably practicable, the risks to personnel are considered ALARP. In this respect the risks to personnel are demonstrated as being “tolerable if ALARP” by the application of an effective hazard management strategy where the levels of risk achieved by designing in accordance with good practice are reduced further by implementation of reasonably practicable measures. The core elements of the strategy, for effective hazard management is given below: • The identification of all hazards; • The assessment to determine Major Hazards • The evaluation of the risks from Major Hazards (qualitatively or quantitatively); 19 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report • The identification of potential measures for risk reduction for which the following hierarchy of preference has been applied: - Elimination and minimization of hazards by design (inherently safer design) - Prevention (reduction of likelihood) - Detection (transmission of information to control point) - Control (limitation of scale, intensity and duration), and - Mitigation of consequences (protection from effects). • The analysis of risk reduction measures and the associated benefits (including evaluation of reasonable practicability involving cost benefit analysis when appropriate). 20 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report Following hazard Identification/Risk Assessment studies are carried for BGPP facility. • • • • • • • • • • • • • • • 4.3 HAZID/ENVID (Ref. 6) HAZOP (Ref. 3, 4 & 5) FERA Study (Ref. 1) QRA Study (Ref. 2) Building Risk Assessment - BGPP-UZLE-D-200-000-0-FF-STU-10004 Escape, Evacuation and Rescue Assessment Study - BGPP-UZLE-D-200-000-0-FF-REP-10005 Flare Radiation and Dispersion Analysis Study - BGPP-UZLE-D-200-290-0-FF-STU-10001 Reliability, Availability and Maintainability (RAM) Study - BGPP-UZLE-D-200-000-0-FF-STU-10006 Material Handling Study - BGPP-UZLE-D-200-000-0-SA-REP-10001 Noise Mapping Study - BGPP-UZLE-D-200-000-0-FF-STU-10008 Vapor Cloud Explosion Study (CFD) - BGPP-UZLE-D-200-000-0-FF-STU-10004 60% Model Review - BGPP-UZLE-D-200-000-0-AL-REP-10002 90% Model Review - BGPP-UZLE-D-200-000-0-AL-REP-10003 Review Report of Isolation of Equipment for Maintenance - BGPP-UZLE-D-200-000-0-HS-REP-00001 Review Report Project Design Requirements - BGPP-UZLE-D-200-000-0-AL-REP-10001 Cost Benefit Analysis In addition to ensuring that risks do not exceed intolerability limits it is a Project goal that the risks are reduced to ALARP (as low as reasonably practicable). Cost benefit analysis can be used to assess the viability and priority of risk reduction measures. Cost benefit analysis of the proposed risk reduction measures can be performed using established cost benefit methodologies. 21 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report 5. RISK ACCEPTANCE CRITERIA 5.1 Individual Risk Acceptance Criteria In the UK-HSE criteria, the individual risk levels for the onsite populations can be classified as follows. Table 1: Risk Acceptance Criteria Acceptance Fatality Unacceptable Broadly Acceptable Tolerable ≥ 1 fatality in 1,000 years ≤ 1 fatality in 1 million years 1 fatality between 1,000 and 1 million years This risk acceptance criterion is given in below image: Figure 3 – Individual Risk Criteria *Note: In Individual risk to workers means individual risk to onsite personnel and Individual risk to public means individual risk to offsite people 5.2 Societal Risk Acceptance Criteria The societal risk represents the frequency of having an accident with N or more people being killed simultaneously. The people involved are assumed to have some means of protection. The societal risk is presented as an FN curve, where N is the number of deaths and F the cumulative frequency of accidents with N or more deaths. 22 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report Figure 4 – Societal Risk Criteria (FN Curve) 23 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report 6. OVREVIEW OF PROCESS HAZARD ANALYSIS (PHA) STUDIES 6.1 HAZID/ENVID Study Two HAZID/ENVID review sessions were conducted as part of the Boysun Gas Processing Plant Project: first session, held on 14th to 17th April 2020, covered some of the process units in project scope, while the second session was carried out on 25th May to 29th May 2020 for analyzing the remaining plant sections. The whole scope of the HAZID/ENVID sessions was divided into 21 Nodes: 6 (six) nodes analysed in the first session and 15 nodes analysed in the second one. HAZID/ENVID review was conducted based on procedure BGPP-WOOD-F-200-000-0-HS-PRO-00002-E, including the project risk matrix and HAZID/ENVID check list. The appointed HAZID/ENVID Team: • Identified any significant hazards associated with the implementation of the project design. • Analyzed, for each identified hazard, the possible causes highlighting the potential consequences. • Assessed the related qualitative level of risk (consequence severity for people and for environment as well as the likelihood of the occurrence) • Identified the already defined control/mitigation measures. Reference Report - HAZID/ENVID REPORT - Doc. No.: BGPP-WOOD-F-200-000-0-HS-REP-00001-E 6.2 HAZOP Study Following are the details for HAZOP studies conducted. 1. License HAZOP workshop was conducted from 9th March to 27th March 2021 and covered following units. • U213, U214 & U215 • total of Twenty (20) nodes were identified for these units. 2. Open Art HAZOP workshop was conducted from 9th March to 16th March 2021 and covered following units. • U210, U212, U216, U217, U219. • total of Twenty (20) nodes were identified for Open art units. 3. Utility HAZOP workshop was conducted for Ten (10) days from 22nd March to 1st April 2021 and covered all units in Utility. The units are given below. • U241, U242, U243, U251, U253, U261, U263, U264, U265, U266, U280, U290, U291, U292, U460, U470, U710, U715. • total of Forty (40) nodes were identified for Utility units. For each selected node deviations were identified based on standard guidewords, the consequences of these hazards were identified, and risk ranked based on risk matrix. Reference Reports – 24 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report • • • 6.3 License HAZOP Study - 1736_LICENSE_HAZOP_Rev A Open Art HAZOP Study - 1736_OPENART_HAZOP_Rev A Utility Art HAZOP Study - 1736_UTILITY_HAZOP_Rev A FERA Study The study presented Fire and Explosion Risk Assessment results carried out using DNV PHAST & SAFETI software version 8.22, for each defined failure case of the Boysun Gas Processing Plant, in order to give an overview on the extent of impact from potential major accident scenarios. The types of events presented are: • Jet fire • Flash fire • Pool fire • Explosion The assessment was based on the hazards that may occur during the operations of the project according to information available. The scope of work is limited to the different components associated with the proposed facility. The facilities of the Gas Processing Plant Boysun, Uzbekistan considered for the FERA study are units – 210, 211, 212, 213, 214, 215, 216, 217, 218, 219, 241, 242, 243, 251, 253, 261, 263, 264, 265, 266, 280, 290, 291, 292, 410, 460, 470, 710, 715. 6.4 QRA Study The QRA study addresses Risk Assessment of the various facilities available and Hazardous operations carried out at the above mentioned facility of Boysun Gas Processing Plant (BGPP). Surhan Gas Chemical Operating Company may consider implementation of the recommendations made in the report as per their individual merit. As part of the QRA study, hazard scenarios were identified for the project facility and consequence analysis was carried out using DNV PHAST software version 8.22. The risk analysis was carried out using DNV SAFETI software version 8.22 to obtain risk results in the form of LSIR contours and F-N curve. These risk results were assessed based on the HSE UK Risk Acceptance Criteria and the Individual Risk Per Annum for the employees was found to broadly lie in the ALARP and the societal risk falls broadly in the ALARP region accounting the Proposed Safeguard Measures. The Risk contour for the nearby villages is not reached, hence it is deduced that the risk for the nearby village falls under the Acceptable region. 25 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report 7. MAJOR HAZARDS FROM PHA STUDIES Hazards at BGPP were identified along with their existing risk in studies listed in section above. The HAZID/HAZOP study gives the qualitative risk, while QRA & FERA gives the quantitative risk associated with hazard scenarios. This section describes the existing risk at BGPP & identifies the hazards/scenarios whose assigned risk falls in intolerable region. 7.1 High Risk Scenarios from HAZID/ENVID HAZID/ENVID Report (Doc. No.: BGPP-WOOD-F-200-000-0-HS-REP-00001-E) is referred for high risk hazards in BGPP. Below is the list of hazards with high risk (with assigned risk rank of 1 & 2) hazards from HAZID Study. Table 2: High Risk Hazards from HAZID Study GW Specific GW Cause Consequence Safeguards S L R Environmental Hazards and natural phenomena Erosion Riverbank erosion: not applicable for the GGP but for pipeline Movement of supports and overstress of the line - D 3 2 Zero level in deaerator Damage of pumps and loss BFW supply to Steam generator (tubes dry condition) and desuperheater. Emergency plant shutdown. D 3 2 Overfilling in K.O. drum Release of liquid to flare and potential overpressure leading to consequent release of flammable gas (acid gas) (jet fire) / Dispersion of H2S D 3 2 Accidental release of liquid Sulphur (along pipeline routing interference with roads, collision with vehicles) Release of liquid Sulphur to the atmosphere and consequent Sulphur solidification. Potential Injury of public (hot fluid and Sulphur fire) E 3 1 Excess/zero Level Process Process - Release of inventory Process 7.2 ESD system (opening of deaerator bypass low level) ESD system (stop of pumps - Low low level) protecting pumps damages DCS for High / high high level in KO Drum Firefighting system F&G Detection FERA/QRA Study Emergency response plan Escape route Leak detection system FERA/QRA Study Emergency response plan Escape ways (pipeline are in open area) High Risk Scenarios from HAZOP Study The HAZOP study reports presents HAZOP worksheets for all units at BGPP, HAZOP worksheet for unit 213 is referred to identify the high risk hazards which are presented in table below as representative case. Likewise other units have high risk hazard potential which can be referred from HAZOP study Reports. Table 3: High Risk Hazards from HAZOP Study – Unit 213 (Representative Case) Cause 1.1.2 Inadvertent Closure of any Manual Isolation Valve Consequence Cat S L R 1.1.2.1 Upstream pressurization leading to over pressurization loss of S E 5 2 26 / 43 Safeguards 72 212-PSV-01003A/B is available. BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report Cause Consequence Cat S L R containment leading to fire/toxic release and fatality, possible Environmental hazard Safeguards 73 212-PIT-01004 will initiate the 212- IS-01004 to open 212-BDV01001. 1.1.3 Malfunction Closure of 1.1.3.1 Flaring of raw Gas leading to both 213-XV- 01010 & 213-XV- Loss of production, toxic release, and 01110 (Common cause failure) fatality S E 5 1.1.4 213-PIC-01102 malfunction Opening of 213PCV-01102 S E 2 S E 2 1 A M 2 2 197 PDAH on 213-PDIT-01001 S E 5 2 2 LAHH on 213-LIT-1003 will trigger 213-S- 1001 to close the S S E E 3 3 1 1 3 213-CHV-01001 Provided. 4 213-CHV-01004 Provided. 1.1.5 Leakage in the system due to corrosion. 1.1.6 Demister blockage 1.2.1 More flow from upstream node (Unit 212 FCV-01003A) 1.3.1 No feed to Absorber 1.3.2 High level in Absorber 1.1.4.1 Flaring of raw Gas leading to Loss of production toxic release and fatality 1.1.5.1 Loss of containment leading to fire/toxic release and fatality, possible Environmental hazard 1.1.6.1 Less flow to absorber leading to Loss of production. 1.2.1.1 High Level on KO Drum leading to carry over to the Absorber, loss of containment leading to fire/toxic release and fatality, possible Environmental hazard 1.3.1.1 Possible reverse Flow 1.3.2.1 Possible reverse Flow 195 PCV-01102 opens to flare 2 196 FAL on 213- FI-01017 1 1.4.1 Possible External Fire 1.4.1.1 Possible over pressurization leading to Explosion and possible fatality. S E 2 1 1.4.2 Blockage of demister pads. 1.4.2.1 Possible over pressurization leading to Explosion and possible fatality. S E 2 1 1.5.1 213-PIC-01102 malfunction Opening of 213PCV-01102 1.5.1.1 Flaring of raw Gas leading to Loss of production toxic release and fatality S E 2 1 1.8.1 LIC-01001 Malfunction closure of 213-LCV-01001 1.8.1.1 Possible carryover of Liquid, loss of containment leading to fire/toxic release and fatality, possible Environmental hazard S 1.8.2 Malfunction closure of XV-01001 1.8.2.1 Possible carryover of Liquid, loss of containment leading to fire/toxic release and fatality, possible Environmental hazard S E 4 1 1.8.3.1 Possible carryover of Liquid, 1.8.3 Inadvertent Closure of loss of containment leading to fire/toxic Manual Isolation Valve 213-BVrelease and fatality, possible 01022/23/24 Environmental hazard S D 3 2 1.9.1 LIC-01001 Malfunction 1.9.1.1 Over pressure in Down Stream system and Sour Gas will enter in 27 / 43 E 4 1 196 FAL on 213- FI-01017 2 LAHH on 213-LIT-01003 will trigger 213-S- 01001 to close the inlet valves. 213- XV-01010/213XV- 01110 7 213-LIT-01001 will give high level alarm for operator to work. 2 LAHH on 213-LIT-01003 will trigger 213-S- 01001 to close the inlet valves. 213- XV-01010/ 213-XV- 01110 7 213-LIT-01001will give high level alarm for operator to work. 2 LAHH on 213-LIT-01003 will trigger 213-IS- 01001 to close the inlet valves. 213- XV-01010/ 213-XV- 01110 198 LALL on 213-LIT-01004 will trigger 213-IS- 01001 to close BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report Cause Opening of 213-LCV-01001 Consequence downstream and Loss of containment may lead to possible fatality. 1.11.1.1 Piping corrosion. loss of containment leading to fire/toxic release 1.11.1 Condensation in the and fatality, possible Environmental Piping. hazard 2.1.2.1 Flaring of Gas leading to loss of 2.1.2 213-PCV-01103 production. loss of containment leading to fails open. fire/toxic release and fatality, possible Environmental hazard 2.1.3.1 Pressurization of 213-01-VN2.1.3 Downstream valves 04/05 and 13-01-VE-01, loss of closed 213-XVcontainment leading to fire/toxic release 01022 and fatality, possible Environmental hazard 2.1.4.1 Less flow to the Downstream Unit (Unit-214). Flaring of 2.1.4 Blockage of Demister of Gas through PCV- 01102 leading to 213-01-VN- 05 Loss of Gas. Toxic release and possible fatality 2.2.1 More flow from upstream node 2.2.1.1 High pressure in the System (Absorber), leading to potential Fire & Explosion, Loss of Containment, Exposure to Toxic Gas, Environmental Hazard and Potential Fatality. 2.2.1 More flow from upstream node 2.2.1.3 Solvent Carryover, leading to potential Fire & Explosion, Loss of Containment, Exposure to Toxic Gas, Environmental Hazard and Potential Fatality. 2.4.1.1 Overpressurization of the 2.4.1 Inadvertent closure of the System leading to potential Fire & 213-XV- 01022 and manual Explosion, Loss of Containment, valves on 213-GP- 01002Exposure to Toxic Gas, Environmental 9501. Hazard and Potential Fatality. Cat S L R S E 5 2 the inlet valves. 213- XV-01010/ 213-XV- 01110 8 213-IS-01001 will trip 213-XV- 01001 S E 5 2 5 Material is selected accordingly S E 2 1 S E 2 1 S E 2 1 S E 5 2 14 213-PCV-01103 is provided. 213-PDI-01003 is Provided. S E 4 1 17 Downstream KOD is provided. S E 5 2 Safeguards 18 213-BDV-01011 will open on confirm fire (IS-01-01008). 19 213-XV-01022 position status is mentioned on DCS. 20 213-PCV-01103 is provided 21 212-PSV-01003A/B is sized for Blocked Outlet. 22 213-PIT-01070A/B/C (2oo3) will activate IS-01008 leading to blow down of the Unit. 2.5.1 213-PCV-01103 wide open 2.5.1 213-PCV-01103 wide open 2.5.1.1 Flaring of Gas leading to Loss of production. loss of containment leading to fire/toxic release and fatality, possible S Environmental hazard 2.5.1.3 Solvent carryover due to surge in Gas flow rate. loss of containment S leading to fire/toxic release and fatality, 28 / 43 E 4 1 E 4 1 23 213-PIT-01070 A/B/C low pressure provided. alarm 24 Downstream KOD 213-01VN-05 is provided. BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report Cause Consequence Cat S L R Safeguards possible Environmental hazard 2.5.2 Opening of Blow Down Valve 213-BDV-01011 2.5.2.1 Refer to 2.5.1.1 S E 4 1 2.6.1 External Fire near 21301-VN-05 2.6.1.1 Possible over pressurization leading to Explosion and possible fatality. S E 5 2 2.6.2 External Fire near 21301-VE-01 2.6.2.1 Possible over pressurization leading to Explosion and possible fatality. S E 5 2 2.6.3 High temperature gas flow from Unit-212. 2.6.3.1 Hydrocarbon condensation in absorber leading to foaming, offspec gas A and leading to loss of production. H 3 2 2.9.1 213-BV-01060 closed. 2.9.1.1 Carryover of the hydrocarbons in solvent line, possible fire hazard. S E 3 1 2.10.1 closure of 213- XV01003 / manual valve and/or 213-LCV- 01010 stuck closed 2.10.1.1 Liquid carryover to unit-214. loss of containment leading to fire/toxic release and fatality, possible Environmental hazard S E 5 2.12.1 213-LCV-01010 wide open. 2.12.1.1 Gas blow by to flash vessel 213-01-VH-06, Loss of containment and possible fatality. Environmental Impact. Possible Fire hazard. S E 5 2 33 213-PSV-01003A/B/C/D 35 213-IS-01004 will closed on 213-XV- 01002 34 213-PCV-01008C 36 213-RO-01030 provided on liquid outlet line. 2.14.1 Heat tracing failure 2.14.1.1 Potential blockage in the piping leading to over pressurization and S leakage resulting in flammable/ toxic gas release. E 5 2 38 PSV upstream lines are routed such as slops towards the source. 7.3 2 25 Open Close Indication of BDV in DCS. 18 213-BDV-01011 will open on confirm fire (IS-01-01008). 27 213-PSV-01002A/B/C/D are provided. 27 213-PSV-01002A/B/C/D are provided. 18 213-BDV-01011 will open on confirm fire (IS-01-01008). 28 213-TDI-01002 with low temperature alarm provided. 30 213-IS-01006 will closed on 213-XV- 01003. FERA The impact of the fire & explosion scenarios on the building as identified from the FERA report is presented in table below. Is No. Table 4: Impact of Fire & Explosion on Buildings from FERA Study Report Description Building/s impacted 211-IS-01 Raw gas from gas gathering header of cluster 4 to 211-XV 00001 Analyzer shelter (513-34) 211-IS-02 211-XV 00001 to 211-XV 00003 through 211-00-VT-01A Analyzer shelter (513-34) 211-IS-03 211-XV 00003 to Inlet Separator system train 1 (212-01-HA-01) and Inlet Separator system train 2 (212-02-HA-01) (Battery Limit) Analyzer shelter (513-34) 211-IS-04 Raw gas from gas gathering header of cluster 3,5 to 211-XV 00006 Analyzer shelter (513-34) 211-IS-05 211-XV 00006 to 211-XV 00008 through 211-00-VT-01B Analyzer shelter (513-34) 29 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report Is No. Description Building/s impacted 211-IS-06 211-XV 00008 to Inlet Separator system train 1 (212-01-HA-01) and Inlet Separator system train 2 (212-02-HA-01) (Battery Limit) Analyzer shelter (513-34) 211-IS-07 Raw gas from gas gathering header of cluster 4,7 to 211-XV 00011 Analyzer shelter (513-34) 211-IS-08 211-XV 00011 to 211-XV 00013 through 211-00-VT-01C Analyzer shelter (513-34) 211-IS-09 211-XV 00013 to Inlet Separator system train 1 (212-01-HA-01) and Inlet Separator system train 2 (212-02-HA-01) (Battery Limit) Analyzer shelter (513-34) 211-IS-10 Raw gas from gas gathering header of cluster 6 to 211-XV 00016 Analyzer shelter (513-34) 211-IS-11 211-XV 00018 to Inlet Separator system train 1 (212-01-HA-01) and Inlet Separator system train 2 (212-02-HA-01) (Battery Limit) Analyzer shelter (513-34) 211-IS-12 Sour water from 211-XV 00020 to Inlet separation system (Battery Limit) through 211-00-CZ-01G/H Analyzer shelter (513-34) 213-IS-01 Sour Gas (Battery Limit) from 212-01-HA-01 to 213-XV-01010 Analyzer shelter (513-34) 213-IS-02 213-XV-01010 to 213-XV-01001 / 01002 / 01003 / 01022 / 213-SDV-01021 / 01023 Analyzer shelter (513-34) 214-IS-05 Acid gas from 214-PCV +01017A to Unit 215 - Incinerator Main Substation-512-01 214-IS-06 From 214-00-TA-01 to 214-00-TA-01 GPP Process Substation 512-02 216-IS-01 Treated Gas from 214-01-VN-03(B.L) to 216-XV-01004 at the inlet of 21601-HA-01A/B Regeneration gas compressor shelter train-1 513-03 216-IS-02 From 216-XV-01004 at the inlet of 216-01-HA-01A/B / 216-XV-01033 to 216-XV-01041 at the Outlet of 216-01-VX-01 Regeneration gas compressor shelter train-1 513-04 216-IS-08 From 216-XV-01042 at the Outlet of 216-01-VX-02 D to 216-XV-01033 Regeneration gas compressor shelter train-1 513-05 710-IS-01 Raw gas from gas gathering header of cluster 4 to 211-XV 00001 Gas Engine generators building 715-IS-01 From truck connection for unloading for Unloading to Daily tank Main Control Room 511-00, RIB Utilities area 511-01, BFW Pumps Shelter 51307 30 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report 7.4 QRA 7.4.1. LOCATION SPECIFIC INDIVIDUAL RISK (LSIR) RESULTS LSIR is used to indicate the risk for individual who is positioned at a particular location for 24 hours per day, 365 days per year. The risk exposure is calculated for all relevant hazards and summed up to give the overall risks for the installation. LSIR contour for BGPP facility is shown below: Figure 5 – Multilevel Individual Risk Contour for Boysun Gas Processing Plant (BGPP) From the LSIR contours, the inner contour cover up to the radius of 156.63 m from the centre of the Unit 210 located near Unit 211 represents IRPA of 1E-02/Avg.Year which comes under the INTOLERABLE region. The contour representing the IRPA of 1E-03/Avg. Year comes under the ALARP Region, this impact will cover up to the radius of 175.08 m from the centre of the Unit 210 located near Unit 211. The yellow line represents the IRPA of 1E07/Avg. Year which comes under the ACCEPTABLE Region, this impact will cover up to the radius of 3558.3 m from the centre of the Unit 210 located near Unit 211. The orange line represents the IRPA of 1E-08/Avg.Year which comes under the ACCEPTABLE Region, this impact will cover up to the radius of 4537.18m from the centre of the Unit 210 located near Unit 211. The blue line represents the IRPA of 1E-09/Avg.Year which comes under the ACCEPTABLE Region, this impact will cover up to the radius of 4973.22 m from the centre of the Unit 210 located near Unit 211. It is the frequency at which an individual or an individual within a group may be expected to sustain a given level of harm (typically death) from the realization of specific hazards. Table 5 – Location Specific Individual Risk Value LSIR (/avg. year) IRPA-Day Shift (/avg. year) IRPA-Night Shift (/avg. year) Risk level Chemical warehouse for utilities 1.67E-03 8.37E-04 8.37E-04 ALARP Administration building 4.42E-04 2.21E-04 2.21E-04 ALARP Domestic building 7.15E-04 3.57E-04 3.57E-04 ALARP Canteen 5.59E-04 2.80E-04 2.80E-04 ALARP Warm-up / Sanitary building 1.79E-03 8.96E-04 8.96E-04 ALARP Risk Ranking Locations 31 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report LSIR (/avg. year) IRPA-Day Shift (/avg. year) IRPA-Night Shift (/avg. year) Risk level Main control room 1.39E-03 6.93E-04 6.93E-04 ALARP Mechanical and repair shop 4.61E-04 2.30E-04 2.30E-04 ALARP Laboratory 9.33E-04 4.67E-04 4.67E-04 ALARP Security services facility 3.24E-04 1.62E-04 1.62E-04 ALARP Security gatehouse for personnel, for cars and trucks 1.04E-03 5.22E-04 5.22E-04 ALARP Risk Ranking Locations IRPA = LSIR*Occupancy Factor Occupancy Factor = 0.5 (It is calculated for 12 hrs/day). 7.4.2. Societal Risk Results The second definition of risk involves the concept of the summation of risk from events involving many fatalities within specific population groups. This definition is focused on the risk to society rather than to a specific individual. We can identify specific groups of people who work on or live close to the installation; for example, communities living or working close to the station. Figure 6- F (Frequency) & N (Number of fatalities) Curve for Boysun Gas Processing Plant In the F-N plot shown above, the red line represents the maximum risk criteria and green line represents the minimum. The region between the yellow and the red line is called the ALARP region as shown in the above figures, green line which is the actual risk falls in the UNACCEPTABLE region. 32 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report Table 6 – Top Ten Risk Integral Table Isolatable Section Risk Integral [/Avg. Year] 213-IS-07-100 mm-IDLH 2.35E-01 213-IS-07100 mm-ERPG-2 2.10E-01 215-IS-05 - 100 mm-ERPG-2 6.27E-02 215-IS-05 - 100mm-IDLH 6.27E-02 213-IS-12-100 mm-Flammable 3.03E-02 213-IS-11-100 mm-Flammable 2.82E-02 213-IS-07-FBR-IDLH 2.08E-02 213-IS-07-FBR-ERPG-2 2.07E-02 212-IS-01-100mm-IDLH 1.25E-02 212-IS-01-100mm-ERPG 2 1.25E-02 8. ALARP DEMONSTRATION It has been found that the societal risk at BGPP is in unacceptable region. This suggests the requirement to demonstrate ALARP. To reduce a risk to lowest tolerable level practicable involves balancing reduction in risk to a level, objectively assessed, where the trouble, difficulty and cost of further reduction measures becomes unreasonably disproportionate to the additional risk reduction obtained. 8.1 Overview of ALARP Demonstration from QRA Study For demonstrating the Unacceptable /ALARP the proposed safeguard measures like BDV, Fire and Gas Protection System, Active Fire Protection System, Passive Fire Protection System can be considered, that is the credit has been provided for the proposed safeguards in the failure frequency calculation as mentioned in table below. Table 7: Probability of Failure on Demand for Independent Protection Layer Independent Protective Layer Probability of Failure on Demand (PFD) Fire & Gas detection system 0.006 Blow down system 0.017 Automatic ESD system 0.017 Passive Fire Protection 0.01 QRA Study demonstrated that after accounting the above mentioned safeguards the risk is reduced from unacceptable to ALARP region and it is presented below. 33 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report 8.1.1. location Specific Individual Risk (LSIR) Results (Including Modification Factor) Figure 7 – Multilevel Individual Risk Contour for Boysun Gas Processing Plant (BGPP) Table 8 – Location Specific Individual Risk Value 7.04E-05 IRPA-Day Shift (/avg. year) 3.52E-05 IRPA-Night Shift (/avg. year) 3.52E-05 Administration building 8.26E-06 4.13E-06 4.13E-06 ALARP Domestic building 1.85E-05 9.25E-06 9.25E-06 ALARP Canteen 1.26E-05 6.29E-06 6.29E-06 ALARP Warm-up / Sanitary building 7.18E-05 3.59E-05 3.59E-05 ALARP Main control room 5.10E-05 2.55E-05 2.55E-05 ALARP Mechanical and repair shop 7.57E-06 3.78E-06 3.78E-06 ALARP Laboratory 2.80E-05 1.40E-05 1.40E-05 ALARP Security services facility 3.88E-06 1.94E-06 1.94E-06 ALARP Security gatehouse for personnel, for cars and trucks 3.41E-05 1.71E-05 1.71E-05 ALARP Risk Ranking Locations LSIR (/avg. year) Chemical warehouse for utilities Risk level ALARP IRPA = LSIR*Occupancy Factor Occupancy Factor = 0.5 (It is calculated for 12 hrs/day). Table 9- High Risk Contributors for Risk Ranking Locations at ALARP Sr. No Risk Ranking Locations at ALARP High Risk Contributors 1 Chemical warehouse for utilities Toxic\Unit 470\IS 01\FBR 2 Administration building Toxic\Unit 215\IDLH\215-IS-05 - FBR 3 Domestic building Toxic\Unit 215\IDLH\215-IS-05 - FBR 4 Canteen Toxic\Unit 215\IDLH\215-IS-05 - FBR 5 Warm-up / Sanitary building Toxic\Unit 215\IDLH\215-IS-05 - FBR 34 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report Sr. No Risk Ranking Locations at ALARP High Risk Contributors 6 Main control room Toxic\Unit 215\IDLH\215-IS-05 - FBR 7 Mechanical and repair shop Toxic\Unit 216\216-IS 03\25 8 Laboratory Toxic\Unit 215\IDLH\215-IS-05 - FBR 9 Security services facility Security gatehouse for personnel, for cars and trucks Toxic\Unit 216\216-IS 03\25 10 Toxic\Unit 215\IDLH\215-IS-05 - 100 Table 10 – Effect Level Risk Contributors for Risk Ranking Locations Sr.No . Risk Ranking Locations Effect Level Flash fire to LFL fraction effect level 1 2 3 4 5 Chemical warehouse for utilities Administration building Domestic building Canteen Warm-up / Sanitary building Indoor toxic effect level 5.10679E-06 Jet fire radiation effect level - 4 kW/m2 6.80529E-07 Jet fire radiation effect level - 5 kW/m2 5.19048E-07 Jet fire radiation effect level - 8 kW/m2 2.21613E-07 Jet fire radiation effect level - 12.5 kW/m2 Jet fire radiation effect level - 32 kW/m2 Main control room 1.17563E-07 9.16832E-09 Jet fire radiation effect level - 37.5 kW/m2 Outdoor toxic effect level 2.87441E-05 Flash fire to LFL fraction effect level 1.61959E-10 Indoor toxic effect level 4.90535E-07 Outdoor toxic effect level 3.63704E-06 Flash fire to LFL fraction effect level 2.48266E-10 Indoor toxic effect level 1.13163E-06 Outdoor toxic effect level 8.12044E-06 Flash fire to LFL fraction effect level 2.15321E-10 Indoor toxic effect level 7.51003E-07 Outdoor toxic effect level 5.54131E-06 Flash fire to LFL fraction effect level 1.42617E-07 Indoor toxic effect level 4.99829E-06 Jet fire radiation effect level - 4 kW/m2 4.98312E-09 Jet fire radiation effect level - 5 kW/m2 3.323E-09 Jet fire radiation effect level - 8 kW/m2 1.14629E-09 Jet fire radiation effect level - 12.5 kW/m2 Jet fire radiation effect level - 32 kW/m2 Jet fire radiation effect level - 37.5 kW/m2 Outdoor toxic effect level 6 Risk Total [/Avg. Year] 3.71512E-07 Flash fire to LFL fraction effect level Indoor toxic effect level 35 / 43 7.5986E-09 9.96E-10 6.58001E-10 5.9107E-10 3.0665E-05 6.69815E-08 3.405E-06 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report Sr.No . 7 8 9 10 Jet fire radiation effect level - 4 kW/m2 Risk Total [/Avg. Year] 8.30433E-10 Jet fire radiation effect level - 5 kW/m2 5.58852E-10 Outdoor toxic effect level 2.20107E-05 Flash fire to LFL fraction effect level 1.41094E-10 Indoor toxic effect level 4.89863E-07 Outdoor toxic effect level 3.29484E-06 Flash fire to LFL fraction effect level 2.66545E-09 Risk Ranking Locations Mechanical and repair shop Laboratory Security services facility Security gatehouse for personnel, for cars and trucks Effect Level Indoor toxic effect level 1.7597E-06 Outdoor toxic effect level 1.22305E-05 Flash fire to LFL fraction effect level 1.29449E-11 Indoor toxic effect level 2.76142E-07 Outdoor toxic effect level 1.66613E-06 Flash fire to LFL fraction effect level 3.56546E-07 Indoor toxic effect level 2.30999E-06 Jet fire radiation effect level - 4 kW/m2 2.17208E-08 Jet fire radiation effect level - 5 kW/m2 1.55692E-08 Outdoor toxic effect level 1.42036E-05 8.1.2. Societal Risk Results (Including Modification Factor) Figure 8- F (Frequency) & N (Number of fatalities) Curve for Boysun Gas Processing Plant 36 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report In the F-N plot shown above, the red line represents the maximum risk criteria and green line represents the minimum. The region between the yellow and the red line is called the ALARP region as shown in the above figures, green line which is the actual risk falls in the ALARP region. The result of this QRA study shows that the individual risk comes under the ALARP region, and the Societal risk comes under ALARP region. 8.2 HAZID Study Recommendations Total of 72 recommendations resulted from the study, covering: • occupational health and safety issues, especially for the plant’s operation: need to develop operating procedures for access to process areas and for personnel protection (PPE, manual loading operations) • maintenance needs for blowers and reactor in SRU unit • reference scenarios for pipeline design (routing, supports, etc.) • sizing criteria for PSV • need of further evaluation during HAZOP review • environmental issues: noise study, permitting, waste disposal needs during commissioning and construction phases. Out of 72 recommendation 4 recommendations are generated for high risk hazards described in Section 7.1. 8.3 HAZOP Study Recommendations The process hazard analysis (HAZOP study) carried out at detailed design stage of the project generated broad range of recommendation to ensure good plant operability & reduced likelihood of loss of containment scenarios. Total 796 recommendations are generated through HAZOP studies performed for the BGPP. Below table gives the number of recommendations from HAZOP study. HAZOP Study Document Number Units Covered Open Art HAZOP Study 1736_OPENART_HAZOP_Rev A U210, U212, U216, U217, U219 License HAZOP Study 1736_LICENSE_HAZOP_Rev A Utility Art HAZOP Study 1736_UTILITY_HAZOP_Rev A U213, U214, U215 U241, U242, U243, U251, U253, 261, U263, U264, U265, U266, U280, 291, U292, U460, U470, U710, U715 8.4 No. of Recommendation 332 228 236 FERA Study Recommendations FERA Study Recommendations are given below. 1. The 25 mm leak size flash fire scenario for the Isolatable sections 715-IS-01,212-IS-01,210-IS-01, 210-IS02,210-IS-03,210-IS-04,210-IS-05,210-IS-06,210-IS-07,210-IS-08 is found to affect the adjacent equipment or facility, hence consider providing proper shielding at the appropriate places. 2. The 1E-06/year risk effect level contour for the Flash fire Scenario encompass the entire facility, hence it is recommended to avoid any ignition sources and consider providing suitable fire rating for the Electrical / Instrumentation components for use in hazardous areas during emergency conditions (i.e. when flammable gas is present). 37 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report 3. The following Process Area building is subjected to Main Control Room - 511-00, RIB Utilities Area - 511-01, GPP Process substation - 512-02, Main Substation – 512-01, Gas engine generators building - 513-01 Regeneration gas compressor shelter train 1, BFW pumps shelter- 513-07, Analyzer shelter (513-34), is subjected to 8 kw/m2 jet fire radiation, hence ensure fire protection/firewall for these building is provided. 4. The following Process Area building Analyzer shelter (513-34), 512-02-GPP process substation, Regeneration gas compressor shelter train 1, Main Control Room - 511-00, is subjected to 32 kw/m2 jet fire radiation, hence ensure active and passive fire protection for these building/structures. 5. Ensure Providing Passive fire protection for the equipment, as mentioned in the above table no 8 / Figure No 16, its structures and Piperack since it is subjected to the Jet Fire Radiation between 8 kw/m 2 and 32 kw/m2. 6. The 1E-05 /year risk effect level contour for the overpressure level is not reached. 7. Though the risk /failure frequency for the diesel tank is moderate, based on the overpressure Impact Analysis Table no 5,6, &7 the Main Control Room and Chemical Ware house may subjected to the Over pressure level of 3 psi, 5 psi, 12 psi due to the 25 mm failure case of Diesel Tank, hence, if possible, consider providing blast proof wall for the Main Control Room and Chemical Ware house. 8. The Pool fire radiation of 8 kw/m2 of 213 -00-TA-02 fire reaches the entire tank farm and its adjacent unit equipment, hence ensure providing Fire detection and protection system for the all the tanks. 8.5 QRA Study Recommendations The result of this QRA study shows that the individual risk comes under the ALARP region and the Societal risk comes under ALARP region. In order to bring down the risk from ALARP to Acceptable the following safety systems should be ensured to prevent the uncontrolled flow and mitigate the consequence • • • • • Activate audible and visual alarms to alert personnel Standard Operating Procedure Emergency Response Plan Escape and Evacuation Route with adequate windsock at strategic location. Regular Inspection & Audits Based on the result the toxic risk contributes major risk for the risk ranking location considered for the study and the effect zone of H2S toxic gas covers most of the facility. Therefore, it is recommended to consider provision of HVAC system with auto shut-off damper in all occupied buildings. The personnel should carry appropriate escape sets in addition to personnel toxic monitors where a timely evacuation cannot be made while they are working toxic effect zone. General Recommendations 1. Vehicles are generally considered to be an ignition source. It is recommended that all the vehicles entering the facility shall have a provision of spark arrestors installed on their exhaust silencers. 38 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report 2. It is recommended that Warning and Safety Signage complying the requirement of ANSI Z535- 2011 and OSHA standards shall be installed at all strategic locations of the facility identifying the hazards associated with chemicals being manufactured/handled. 3. The workforce present in the areas having probability of exposure to hazardous chemicals within the facility shall be trained to carry necessary PPEs to avoid occupational injury or emergency. 4. Fire Fighting equipment (e.g., fire water pumps, fire water storage, water curtains, fire extinguishers, etc.) are available with the facility. 5. Eye wash and safety showers are installed at strategic locations of the plant 6. Facility team maintains a good working condition of plant through; 7. Good Housekeeping 8. Use of PPEs 9. Strategic Communication Protocol and System 10. Standard Operating Procedures (SOPs) and Standard Maintenance Procedures (SMPs) 11. Preventive and Predictive Maintenance Practices. 12. Electrical Safety 13. Colour Coding System 8.6 Review of PHA Recommendations The risk at BGPP is largely contributed by toxic gas (H2S) hazard. Out of top ten risk contributors shown previous section (Table 10), six are due to toxic gas scenarios (impact of IDLH concentration) followed by flammable risk. The below table depicts the review of recommendations resulted from various safety studies and their importance to ensure ALARP demonstration. For HAZOP/HAZID, it is assumed that low risk recommendations are being implemented along with high risk recommendations, the action tracking procedure/close-out procedure shall ensure that all recommendations are implemented and are approved. For FERA and QRA studies, all recommendations are mentioned in below table and are analyzed with respect to their impact. It is assumed that plant will have Preventive Maintenance practice implemented during Operation to ensure the performance of all the safeguards to meet their desired output. Safety Critical Elements (SCEs) shall be identified, and special/rigorous maintenance schedule shall be followed for maintenance of SCEs. Management of Change (MOC) in accordance with PSM (Process Safety Management) practices shall be implemented during operation phase of the plant as a part of PSM Implementation. 39 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report Table 11: Review of PHA Recommendations Time of Implementation Type of recommendation Study recommendation Procedural HAZID - 72 recommendations are initiated, majorly these are related to process design improvement. HAZOP - 796 recommendations are initiated, majorly these are related to process design improvement. FERA 1 2 3 4 5 The 25 mm leak size flash fire scenario for the Isolatable sections 715-IS-01,212IS-01,210-IS-01, 210-IS-02,210-IS-03,210-IS-04,210-IS-05,210-IS-06,210-IS07,210-IS-08 is found to affect the adjacent equipment or facility, hence consider providing proper shielding at the appropriate places. The 1E-06/year risk effect level contour for the Flash fire Scenario encompass the entire facility, hence it is recommended to avoid any ignition sources and consider providing suitable fire rating for the Electrical / Instrumentation components for use in hazardous areas during emergency conditions (i.e. when flammable gas is present). The following Process Area building is subjected to Main Control Room - 511-00, RIB Utilities Area - 511-01, GPP Process substation - 512-02, Main Substation – 512-01, Gas engine generators building - 513-01 Regeneration gas compressor shelter train 1, BFW pumps shelter- 513-07, Analyzer shelter (513-34), is subjected to 8 kw/m2 jet fire radiation, hence ensure fire protection/firewall for these building is provided. The following Process Area building Analyzer shelter (513-34), 512-02-GPP process substation, Regeneration gas compressor shelter train 1, Main Control Room - 511-00, is subjected to 32 kw/m2 jet fire radiation, hence ensure active and passive fire protection for these building/structures. Ensure Providing Passive fire protection for the equipment, as mentioned in the above table no 8 / Figure No 16, its structures and Piperack since it is subjected to the Jet Fire Radiation between 8 kw/m2 and 32 kw/m2. 40 / 43 Design Improvement Needs further Assessment Design (CFD/CBA) Operation Risk after Implementation ALARP Yes /No It is assumed that low risk recommendations are being implemented along with high risk recommendations, the action tracking procedure/close-out procedure shall ensure that all recommendations are implemented and are approved. - Y N Y - Y - Y N Y - Y - Y N (Note 1) Y - Y - Y N (Note 1) Y - Y - Y N (Note 1) Y - Y BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Construction of Boysun GPP ALARP Demonstration Study Report Time of Implementation Type of recommendation Study recommendation 6 7 QRA 1 2 3 4 5 6 7 8 9 10 11 12 13 Though the risk /failure frequency for the diesel tank is moderate, based on the overpressure Impact Analysis Table no 5,6, &7 the Main Control Room and Chemical Ware house may subjected to the Over pressure level of 3 psi, 5 psi, 12 psi due to the 25 mm failure case of Diesel Tank, hence, if possible, consider providing blast proof wall for the Main Control Room and Chemical Ware house. The Pool fire radiation of 8 kw/m2 of 213 -00-TA-02 fire reaches the entire tank farm and its adjacent unit equipment, hence ensure providing Fire detection and protection system for the all the tanks. Vehicles are generally considered to be an ignition source. It is recommended that all the vehicles entering the facility shall have a provision of spark arrestors installed on their exhaust silencers. It is recommended that Warning and Safety Signage complying the requirement of ANSI Z535- 2011 and OSHA standards shall be installed at all strategic locations of the facility identifying the hazards associated with chemicals being manufactured/handled. The workforce present in the areas having probability of exposure to hazardous chemicals within the facility shall be trained to carry necessary PPEs to avoid occupational injury or emergency. Fire Fighting equipment (e.g., fire water pumps, fire water storage, water curtains, fire extinguishers, etc.) are available with the facility. Eye wash and safety showers are installed at strategic locations of the plant Facility team maintains a good working condition of plant through; Good Housekeeping Use of PPEs Strategic Communication Protocol and System Standard Operating Procedures (SOPs) and Standard Maintenance Procedures (SMPs) Preventive and Predictive Maintenance Practices. Electrical Safety Colour Coding System 41 / 43 Needs further Assessment Design (CFD/CBA) Risk after Implementation ALARP Yes /No Procedural Design Improvement - Y CFD (Note- 2) Y - Y - Y (Note 1 & 3) Y - Y Y - N - Y Y - Y N Y - Y Y - N - Y Y - Y N Y - Y Y Y Y Y Y - N N N N N Y - Y Y Y Y Y Y Y Y Y Y - N - Y Y Y Y - Y N N N Y Y Y - Y Y Y BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Operation Construction of Boysun GPP ALARP Demonstration Study Report Notes: 1. The Active Fire Protection Philosophy (Ref. 8) & Passive Fire Protection Philosophy (Ref. 9) is in place. 2. The requirement is assessed through Vapor Cloud explosion study (CFD) - BGPP-UZLE-D-200-000-0-FF-STU-10005. 3. The Fire Detection System requirements are specified by the F & G detection philosophy (Ref. 10), the fire & gas detector layouts is prepared accordingly. Also, F & G mapping study report (BGPP-UZLE-D-200-000-0-FF-STU-10002) can ensure the requirement. 42 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C Boysun Gas Processing Plant (BGPP) ALARP Demonstration Study Report 9. CONCLUSION Overall, all the recommendations mentioned above can be implemented, no recommendation requires change in design, ongoing engineering phase of the project must ensure the implementation of these recommendations. Need for CBA (Cost Benefit Analysis) may not arise as long as all the recommendations are implemented in totality unless the decision of accepting any of the recommendation is not challenged by any of the stake-holder or Company. It has been demonstrated that the BGPP development presents risk to personnel which are ALARP. It has been calculated (Ref 2) that the Individual Risk Per Annum (IRPA) values for each worker group are considerably less than the maximum tolerable limit (1.00E-03) but are greater than the broadly tolerable region (1.00E-06) and lie within the “tolerable if ALARP” region. ALARP has been achieved by: • Providing a robust design basis for the facilities with the use of Good Engineering Practice by means of compliance with statutory provisions and use of appropriate design codes and standards and industry accepted practices. • Applying an effective hazard management strategy of hazard identification, giving rise to recommendations concerning the elimination, prevention, control, and mitigation of major hazard risk which is integrated into meeting the applicable local & international standards. • Implementing those demonstrated to be reasonably practicable (with support to decision making from cost benefit analysis where appropriate). Where measures judged to involve sacrifice grossly disproportionate to the risk benefits obtained, these measures shall be excluded. 43 / 43 BGPP-UZLE-D-200-000-0-FF-REP-10006-E-C