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| Study of risk and PPP
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Article 30 of the LGEEPA states that: when it comes to activities considered to be highly risky under the terms of this law, the manifestation of environmental impact must include the corresponding Risk Study.
In the regulation of the law of the ecological balance and protection to the environment (LGEEPA) in the field of environmental impact assessment, referred to in article 5 those who intend to carry out the following works or activities, previously the authorization shall be required of the Secretariat, through the submission of an environmental impact assessment (EIS) and points out the work or following activities:
Hydraulic, developing general communication, oil pipelines, gas pipelines, carbon pipelines and pipelines, oil industry, petrochemical industry, chemical industry, sugar industry, industry of cement, electricity industry, exploration, exploitation and beneficiation of minerals and substances reserved to the Federation, facilities for treatment, confinement or disposal of hazardous waste, as well as radioactive waste, forest exploitation in tropical forests and species of difficult regeneration, forest plantations, forest areas land use changes, as well as forests and arid zones, industrial parks which provide highly risky activities, real estate developments that affect coastal ecosystems, works and activities in wetlands, mangroves, lagoons, rivers, lakes and estuaries connected with the sea and its coasts or federal areas, works in protected natural areas, fishing activities which may endanger the preservation of one or more species or cause damage to ecosystems, activities aquaculture which may endanger the preservation of one or more species or cause damage to ecosystems, agricultural activities which may endanger the preservation of one or more species or cause damage to ecosystems.
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| Highly Risky Activities
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A highly risky activity is defined as: An activity that is to be included within its management, quantities of substances exceeding those indicated in the 1st. and 2nd. List of activities highly risky, published by agreement of the Secretaries of the Interior, urban development and ecology.
First listing of highly risky activities is composed by those activities in which toxic substances are handled, and in that list are explicitly exempted the usage and application of pesticides with toxic properties, under that there is no specific legislation for the case, which regulates this activity in particular. This list was published in the Official Gazette of the Federation on March 28, 1990.
Also, on 4 May 1992 was issued the second listing of highly risky activities, which corresponds to those that handle flammable and explosive substances.
The main feature of these listings, is that they incorporate the concept of Quantity Report, i.e., the maximum amount of substances considered in these lists, which handle or store a company and, if this amount is exceeded, the company is regarded as highly risky, and an environmental risk assessment should be provided.
When an installation is in operation and is in the case mentioned above, you must prepare and submit a risk study comply with the Guide for the development of the study of environmental risk; SEMARNAT-07-008 "Presentation of the risk study for companies which work with highly dangerous substances", and each of the points mentioned therein, must be developed with the sufficient technical depth, capable of supporting the comprehensive evaluation of the installation. Diagrams of pipe and Instrumentation (DPI) and levels of the facility, based on detailed engineering, readable and updated, as well as an executive summary of the study of risk must also occur.
One of the main points of the preparation of the risk ,studies is to determine potential rays of affectation, through the application of mathematical simulation models, of the probable maximum risk events identified in the study.
To define and justify the areas of security of the installation into the environment, use the following parameters:
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The Article 17 of this regulation, mentions that when high risky activities are involved in terms of Law, an ERS must be included.
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The Article 18 of the same Law states the following: The Risk Study that is referred in the Article 17, is formed by the EIS that must include:
I. Stage and preventive measures arising from the analysis of environmental risks related to the project.
II. Description, when in case, of the protection areas around the facilities.
III. Marking of safety environmental measures.l.
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Determination of the level of study |
SEMARNAT establishes that there are four different levels of information for the submission of studies of the environmental risk;
Level 0 (Land Lines)
Level 1 (Preliminary Risk Report)
Level 2 (Risk Study)
Level 3 (Risk Analysis)
The Risk Study should be provided in the General direction of Integral management of materials and risky activities (DGGIMAR), the Assistant of management for environmental protection, the Secretariat of environment and natural resources (SEMARNAT).
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| Program for the Prevention of Accidents (PPA)
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Article 147 of the LGEEPA points out that the conduct of commercial activities or highly risky services, must be carried out in accordance with the provisions of this law, as well as the Mexican official standards and regulations emanating from it. Any person performing highly risky activities, under the terms of the regulation, shall formulate and submit to the Secretary an environmental risk assessment as well as subject to the approval of that unit and the secretariats of: governance, energy, trade and industrial promotion, health, and labor and social welfare programs for the prevention of accidents (PPA) in carrying out such activities they can cause serious ecological imbalances.
With regard to hazardous materials, it should be noted only those materials classified as highly dangerous, according to the listings that classified an activity as a highly risky, they are stored or processed at the facility or establishment and all necessary actions identified in the submitted environmental risk assessment should be considered as a minimum.
All procedures related to the attention of emergencies inside and outside the installation, on the basis of the evaluation and prioritization of risks identified in the environmental risk assessment should be linked. Also must be related equipment and services available in the installation for emergency care, and preventive measures must be focused to eliminate or reduce the frequency and/or severity of the identified events. |
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| According to this remark, it is necessary that all the risk studies are accompanied by the corresponding PPP, which describe the following sections: |
1.-General information of the establishment or installation of the legal representative of the company and responsible for the elaboration of the program for the prevention of accidents.
2.-Description of the environment of the establishment or facility where the highly risky activities are performed.
3.-Managed hazardous materials and potential areas of involvement.
4.-Identification of preventive measures to control, mitigate or eliminate the consequences and reduce their likelihood.
5.-Schedule of activities arising from the environmental risk study presented by the establishment or installation.
6.-Emergency response plan.
7.-Directory of functional infrastructure for the implementation of the emergency response plan to the interior and exterior installations.
8.-Plan to reverse the effects of potential releases of hazardous materials, people and the environment (bodies of water, flora, fauna and soil).
9.-Compliance with the regulations in the field of security, prevention and care of emergency issued by the federal government units that make up the Commission, in terms of article 147 of the LGEEPA.
10.-Externally chemical emergency response plan.
11.-Communication of risks. |
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