ACTION 2: Recording and assessment of existing situation

The principal tasks under this sub action include:

• Identification of dangerous substances such as: common fossil fuels (liquid and gas) and all lubricants and other engine oils widely produced, transported, handled and consumed in Greece and other EU countries by project industrial partners.
• Identification of project target-groups i.e.:
  • industrial producers of selected substances and classes
  • carriers/ transporters via sea, road, rail and pipelines
  • distributors (i.e. fuel distribution, filling stations)
  • controlling Authorities (i.e. port Authorities, Environmental and Safety Authorities, Labour Inspection, ADR Authorities)
  • potential users of HSE related and REACH Regulations (i.e. industrial producers, SMEs, petrol stations, public and other third parties).

An expert team will organize and perform a users awareness survey to identify the level of users understanding and knowledge regarding the requirements and obligations derived by chemicals legislation and regulation, as well as the degree of implementation of safety and environmental measures during operations in the transportation and handing of chemicals. A number of appropriate questionnaires will be developed and filled in by the target groups. The outcomes of the survey will define the needs and set the framework for organizing the training and public awareness campaigns of the users (see ACTION 8).

The methodology that will be employed in order to determine project target-groups will include:

• Utilization of project industrial partners data (i.e. collaborators and customers)
• Legislation review related to transportation and loading/ unloading activities for the selected HazChem

During the implementation of this sub action representatives (No. to be defined) from TUC will travel to Athens in order to collaborate with representatives from MOH and AVINOIL, for the conduction of the survey and the evaluation of its results.

Beneficiary responsible for implementation of this sub action will be MOH in collaboration with TUC and AVINOIL.

Identification and recording of regulations and analysis of legislative requirements related to the identified project target groups. In this sub action European and international regulations under which Greece has been harmonized will be examined:

• REACH: Registration Evaluation Authorization and Restriction of Chemicals Regulation (EC No 1907/2006)
• CLP: Classification Labelling and Packaging of Substances and Mixtures Regulation (EC No 1272/2008)
• ADR: European Agreement concerning the International Carriage of Dangerous Goods by Road
• RID: International Carriage of Dangerous Goods by Rail Regulations of the Intergovernmental Organization for International Carriage by Rail
• IMDG CODE: International Maritime Dangerous Goods Code of International Maritime Organization for the Transport of Dangerous Goods by Sea
• SEVESO II: Council Directive SEVESO II for the Prevention of Major Accidents Involving Dangerous Substances and the Limitation of their Consequences for Man and the Environment (ΚΥΑ 12044/613/ΦΕΚ 376Β΄-19.3.2007)

The legislation and standards project industrial partners are subjected to, will be mainly considered and examined.

Beneficiary responsible for implementation of this sub action will be TUC in collaboration with MOH and AVINOIL.

According to REACH Regulation, Strictly Controlled Conditions (SCCs) have constituted controlling mechanisms of intermediate products. SCCs are described as:

1. the substance is rigorously contained by technical means during its whole lifecycle including manufacture, purification, cleaning and maintenance of equipment, sampling, analysis, loading and unloading of equipment or vessels, waste disposal or purification and storage
2. procedural and control technologies shall be used that minimize emission and any resulting exposure
3. only properly trained and authorized personnel handle the substance
4. in the case of cleaning and maintenance works, special procedures such as purging and washing are applied before the system is opened and entered
5. in cases of accident and where waste is generated, procedural and/ or control technologies are used to minimize emissions and the resulting exposure during purification or cleaning and maintenance procedures
6. substance-handling procedures are well documented and strictly supervises by the site operator.

Strictly Controlled Conditions are recommended to be seen (by ECHA – “Guidance for intermediates”) as a combination of technical measures that are underpinned by management systems, including training, process controls, monitoring and personal protective equipment. A typical example of technical measures for petrochemical industry includes:

• Enclosed transfers designed to prevent leaks e.g. self-draining transfer lines
• High integrity methods of material loading and unloading (e.g dry lock couplings, vapour capture and recovery)
• Plant designed to facilitate the draining and flushing of plant equipment items prior to maintenance, with recycle and/or suitable disposal of wastes
• High integrity (low emission) valve packings and flange seals
• In-line process controls and/or contained systems for process sampling
• Low emission pumps e.g. canned, magnetic, mechanical seals
• Routine monitoring and inspection for leaks to reduce fugitive emissions

(by ECHA – “Guidance for intermediates”)

The analysis for the determination of Strictly Controlled Conditions will be realized taking into consideration all issues and elements contained in Safety Management System (SMS) of SEVESO II Directive for the control of major accidents involving dangerous substances, such as:

• Organization and personnel issues
• Identification and evaluation of major accidents
• Operational control issues (including maintenance)
• Management of change issues
• Planning for emergencies
• Monitoring performance
• Audit and review (of the SMS)

In addition, the legislation and on-site procedures of project industrial partners will define the analysis framework of this sub action.

Beneficiary responsible for implementation of this sub action will be MOH in collaboration with TUC and AVINOIL.

The principal stages of loading/ unloading, handling and transportation of dangerous petrochemicals with different modes such as road, rail, sea and pipelines will be identified and recorded. The analysis of lifecycle stages will be performed at national and European level and the results will be compared. For example the loading/ unloading methods that will be examined include rail switch tracks and rail tank car loading racks, tank truck loading racks, marine docks, pipeline connections, etc. In addition, all means and principal operations related to the lifecycle stages of selected chemicals transportation (fuels and oils) at national level will be determined (i.e. rail tank cars, tank trucks, marine vessel transfer operations). All these data will be the basis for the implementation of project objectives and actions. HSE information of dangerous petrochemicals included in MSDS will be the basis of the analysis of SCC in all handling Life Cycle stages of substances.

The methodology that will be employed in order to collect all the necessary data will include:

• Utilization of project industrial partners data
• Utilization of relevant studies and other literature
• Communication with representative project target-groups in order to obtain relevant data and interviews
• Review of loading and unloading operations: examination of the use and scope of loading checklists, methods of overfill protections, common procedures for overfill protection (sensors, automatic shut-off), spill control measures etc
• Visits at hazard chemicals loading/ unloading and handling areas of the project industrial partners and other target-groups aiming at identifying and recording the critical information on lifecycle transportation using appropriate checklists

Beneficiary responsible for implementation of this sub action will be MOH in collaboration with TUC and AVINOIL.

This sub action refers to the identification, recording, assessing methods and techniques for HazChem relevant to leaks, spills, emissions and damage.  A review of available emission estimation techniques (EETs) in air, water and soil will be performed with reference to:

• sampling or direct measurements,
• mass balance,
• fuel analysis or other engineering calculations, and
• relevant emission factors.

Best industrial practices in monitoring emissions will be reviewed and the most suitable EET will be correlated to critical operations and areas in the transportation of chemicals in which a leak or a spill is more likely to occur (i.e. tank truck loading racks, rail switch tracks, loading platforms or docs, marine docks, pipeline connections and other areas where a product is loaded or unloaded). Outcomes of past LIFE projects will be also taken into account in order to utilize experience gained and best practices proposed by past Environment projects.

Reviews of past accidents will be taken into account, regarding the transportation and storage of chemical with minor or major impacts into the environment will be performed using data by the industry partners as well as official recorded national and EC data (Greek Min. for the Environment, UNEP, EC Environment, JRC, Major Accident Hazard Bureau MAHB -MARS Database). Important information will be taken into account so as to identify key parameters and good industrial practices derived by historical data with reference to:

• dangerous substances involved and their classification ,
• released quantities,
• affected eco-systems-environmental receptors,
• extent of environmental consequences (short-term and long term effects),
• time of recovery, etc.

Beneficiary responsible for implementation of this sub action will be TUC in collaboration with MOH and AVINOIL.

Best available practices, emergency planning techniques and environmental restoration practical guidance’s as applied by industry partner’s (MOH, AVIN) and as recommended by other industries and/or the competent Authorities will be studied to identify a range of environmental, safety and social (authorities) mechanisms that can be used to minimize emissions and environmental impacts. These mechanisms will be correlated to critical areas and operations in the selected routes in the transportation of chemicals.

Utilizing the outcomes from the above mentioned sub actions a set of criteria will be defined for benchmarking BATs and recorded practices taking into account the parties and the individuals involved, legislative requirements, regulations and standards specifications, BATs and BREFs in monitoring and quantifying emissions, operational practices, common incidents, accidental events etc. A benchmarking exercise will be launched and results will be compared with the reviews of practices. The benchmarking exercise will be based on common benchmarking methodologies. To this end a working group of diverse experience and expertise (industry, research, authorities) will be setup and will provide a systematic evaluation of the recorded data along with the collaboration with a subcontractor (to be defined) as an external assistance.

The most suitable guidance as indicated by the analysis  considering the activities, the personnel and the Authorities involved, will be correlated to critical operations and areas in the transportation of chemicals and best control and inspection procedures will be proposed.

During the implementation of this sub action representatives (No. to be defined) from TUC will travel to Athens and to Corinth in order to have a technical meeting with representatives from MOH and AVINOIL. The technical meeting will refer to the implementation of this sub action and the assessment of the results of Action 2 in general.

Beneficiary responsible for implementation of this sub action will be MOH in collaboration with TUC and AVINOIL.