7.1 BACKGROUND 7.3 SCOPE OF WORK 7.4 METHODOLOGY

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1 7 RISK ASSESSMENT & DISASTER MANAGEMENT PLAN 7.1 BACKGROUND Risk Assessment is a management tool for determining the hazards and risk associated with the various activities of a project and compute the damage potential of these hazards to life and property. Risk Assessment provides basis for determining the safety measures required to eliminate, minimize and control the risks as detailed in Disaster Management Plan (DMP) to handle onsite and offsite emergencies. In Chemical Industry, Risk Assessment is carried out for the various hazards involved in storage and handling of hazardous raw materials, intermediates and finished products as well as for the manufacturing processes used by the unit. 7.2 OBJECTIVES The given study was focused to fulfill the following objectives : Identification of safety areas Ientification of process and storage hazards Visualization of maximum credible accident (MCA) scenarios Consequence analysis of scenarios Determination of quantities released, impact zones Estimation of damage distances for the accidental release scenarios with recourse to Maximum Credible Accident (MCA) analysis Preventive and control measures required for reducing the risk factors Delineation of Disaster Management Plan 7.3 SCOPE OF WORK Based on the objectives as defined above, the scope of work for the given study was identification of the process and storage hazards of proposed RUC plant extension and their assessment for consequence and risk involved. For this following has been conducted :- 1. Hazard Identification General description of project Study of manufacturing activities Study of plant facilities and layout Hazardous inventory Associated process and storage hazards Safety measures as proposed by the proponent 2. Hazard Assessment Identification of MCA and worst case scenarios using standard techniques Consequence analysis of selected scenarios using EFFECT model on ALOHA software 3. Determination of risk reduction measures 4. Preparation of DMP 5. Recommendations 7.4 METHODOLOGY Following methodology has been followed for given Risk Assessment Study as described in Guidelines for Chemical Process Quantitative Risk Assessment by CCPS with the help of frequency data from Purple Book,2008. The guidelines given by SEAC as well as Technical Guidance Manual of MoEFCC have also been followed. Collecting Input data about Process,Inventories and Site conditions Hazard Identification Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 191 of 252

2 Defining the Potential Accident Scenarios Evaluation of Consequences and Estimation of Accident Frequencies Estimate the Impacts Estimate the Risk Identify and Prioritize the Risk Reduction measures. 7.5 HAZARD IDENTIFICATION This is important and critical step in risk assessment. It is critical because Hazard omitted is hazard not analyzed. The tools used for identification are experience, detailed process knowledge, engineering codes, checklist, HAZOPs etc. The unit shall handle hazardous materials and shall have a defined and organized hazard control and prevention system in place. The following statutory compliances shall be applicable to the unit : 1. Gujarat Factories Rules, Manufacture, Storage and Import of Hazardous Chemicals (Amended) Rules, Petroleum Act, 1934, Petroleum Rules, Gas Cylinder Rules, 2004 The hazards involved in the process are due to major two factors, Process conditions: High pressure, High temperature Material handled: Flammable, Toxic The inventory of hazardous material in the storage area is significantly larger than the inventory involved in the process, hence the scenarios selected for the consequences calculations are from storage vessels. These vessels are located near the respective plants only. Hydrogenation is the only high pressure process in the unit. The failure of high pressure hydrogenation vessel is identified as incident scenario. Normal lookout for materials, initiating events and incidents are tabulated in table in following pages. Process Hazards Initiating Events Incident Outcome Significant Inventories of : Equipment Failure Discharge of gas or liquid to atmosphere Flammable Material Pumps Dispersion of Material(Toxic) Combustible Material Valves s Unstable Material Sensors Pool fire Corrosive Material Interlock Jet Asyphyxiants Loss Of containment Flash Shock Sensitive Materials Tanks Explosion Higly Reactive Materials Vessels Confined Explosion Toxic Materials Pumps Unconfined Explosion Extreme Physical Conditions Heat Exchangers Dust Explosion High Temperatures System Failure Physical Explosion High Pressures Human Error Cryogenic Temperatures Design Failure Vacuum Pressure Cycling Temperature Cycling Vibration/Liquid Hammering Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 192 of 252

3 7.5.1 and Explosion Hazards The unit will handle Natural gas and Hydrogen as major flammable gases. No. of low and medium volatile chemicals are also to be handled in storage tanks and drums which pose fire and explosion hazards Toxic Release Hazards Excessive or unexpected generation of toxic gas may result due to vessel pressurization. Leakage or rupture in pipelines, valves, and reaction vessels can cause release of toxic gas into the immediate environment posing serious risk to health and environment. The new Accelerator products involve handling of solid raw materials as well as products which have potential for chemical dust generation and thereby have toxic effects Chemical Spill The unit shall use chemicals stored in drums and carboys which have to be transferred from storage area to shop floor manually through forklifts. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 193 of 252

4 Environmental Impact Assessment (EIA) - EMP and Risk Assessment Study Report 7.6 STORAGE HAZARDS AND CONTROL MEASURES Product storage Sr. No. Full name of the product Produ ction Rate MT/da y State i.e. Solid / Liquid / Gas No. of conta iner MT (unit) B.P. C Range Fl. P. C Range LEL UEL% TLV LD50 mg/kg or ppm LC50 mg/l or mg/m 3 Health Hazard Hazard React ivity Antioxidants Vulkanox Liquid to 381 > 94 NA NA LD50 oral, rat: >2000 mg/kg Irritant to skin,eyes, toxic for ingestion Flammable Stable, decomposes on heating 2 Antioxidants -Vulkanox Liquid NA NA LD50 oral, rat: >2000 mg/kg 3 Vulkanox Solid 220 at 13.3 hpa upto 200 no flash point NA NA LD50 oral, rat: mg /kg 4 Vulkanox Solid 230 at 13.3 hpa Approx. 200 NA NA LD50 oral, rat: 3340 mg /kg 5 Accelerator -Vulkanox HS Solid NA NA LD50 oral, rat: >2000 mg/kg 6 Accelerator -Vulkanox SP Liquid NA NA LD50 oral, rat: >2000 mg/kg 7 Accelerator -Vulkacit CZ/C Solid NA NA LD50 oral, rat: 5300 mg/kg 8 Accelerator -Vulkacit DZ/C Solid NA NA LD50 oral, rat: >5000 mg/kg 9 Accelerator -Vulkacit NZ/C Solid NA NA LD50 oral, rat: >6310 mg/kg 10 Accelerator -Vulkacit MBT Solid NA NA LD50 oral, rat: >3.8 mg/kg The products both solids and liquids are flammable and toxic to skin, eyes and also toxic to aquatic life. Irritant to skin,eyes, toxic for ingestion Irritant to skin,eyes, toxic for ingestion Irritant to skin,eyes, toxic for ingestion Irritant to skin,eyes, toxic for ingestion Irritant to skin,eyes, toxic for ingestion Irritant to skin,eyes, toxic for ingestion Irritant to skin,eyes, toxic for ingestion Irritant to skin,eyes, toxic for ingestion Irritant to skin,eyes, toxic for ingestion Flammable Flammable Flammable Flammable Flammable Flammable Flammable Flammable Flammable Stable, decomposes on heating Stable upto 200 C Stable upto 200 C Stable Stable Stable Stable Stable Stable Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 194 of 252

5 Environmental Impact Assessment (EIA) - EMP and Risk Assessment Study Report Raw material storage Sr. No. Full name of the raw material State i.e, solid / Liquid / Gas No. of container & Size at site No. Total MT Storage Parameters Temp C Pres. kg/cm 2 M.P. C B.P. C, Fl. P. C LEL UEL% TLV ppm or mg/m3 LD50 mg/kg or LC50 mg/l Sp. gr Vapour Densit y (air =1) Health hazard NFPA rating Hazard Reactivity Aniline Liquid Atm M.P -6 C, B.P 184 C 2 Acetone (U/g) 3 Sodium Hydroxide 4 Hydrochloric Acid 5 Toluene (u/g) Liquid 2 for pure 2 for rec. 2 for impure Atm M.P -95 C, B.P 56 C Liquid 1 30 Atm M.P - 12 C, B.P C Liquid 1 30 Atm B.P 81.5 to 110 C Liquid 1 30 Atm M.P C, B.P C ppm LD50-oral mg/kg LC50 inhalation 248 ppm-4h TLV TWA ppm LD mg/kg NA NA NA LD mg/kg > 100 NA NA LC (V) mg/m3 1 h LD mg/kg TLV TWA - 50 ppm, TLV STEL ppm LD mg/kg, LC mg/m3-4h NA Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 195 of 252

6 Sr. No. Full name of the raw material State i.e, solid / Liquid / Gas No. of container & Size at site No. Total MT Storage Parameters Temp C Pres. kg/cm 2 M.P. C B.P. C, Environmental Impact Assessment (EIA) - EMP and Risk Assessment Study Report Fl. P. C LEL UEL% TLV ppm or mg/m3 LD50 mg/kg or LC50 mg/l Sp. gr Vapour Densit y (air =1) Health hazard NFPA rating Hazard Reactivity Methyl Isoamyl Ketone 7 Methyl Ethyl Ketone 8 Methyl Isobutyl Ketone Liquid Liquid Liquid 2 for pure 1 for rec 1 for impure 1 for pure 1 for rec 1 for impure 2 for pure 1 for rec 1 for impure Atm C M.P C, B.P C ppm LD50-oral- 5700mg/kg, LC50- inhalation 3813ppm - 6h Atm C BP 79.6 C LD50-oral- >2000 mg/kg, LC mg/m3 4h Atm C MP -84 C BP C ppm LD mg/kg LC ppm-4h to Aminodiphenyl amine (kept in molten state) Liquid Atm. 100 C MP ->70 C BP 354 C >250 NA NA LD50-oral mg/kg NA NA NA NA NA 10 Methyl Hexyl Ketone liquid Drum BP C MP 16 C 52 C closed cup NA LD50 : 3089 mg/kg LC50 > 2132ppm/6h r NA NA NA 11 Phenol solid Drum MP 42 C ppm LD Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 196 of 252

7 Sr. No. Full name of the raw material State i.e, solid / Liquid / Gas No. of container & Size at site No. Total MT Storage Parameters Temp C Pres. kg/cm 2 M.P. C B.P. C, Environmental Impact Assessment (EIA) - EMP and Risk Assessment Study Report Fl. P. C LEL UEL% TLV ppm or mg/m3 LD50 mg/kg or LC50 mg/l Sp. gr Vapour Densit y (air =1) Health hazard NFPA rating Hazard Reactivity Styrene Liquid cool C MP C BP C BP 182 C, dermal- 630 mg/kg NA LD mg/kg, LC mg/l-4h NA H2SO4 98% Liquid 1 50 Atm C BP >100 C NA NA 1 mg/m3, NA CZ/DZ/NZ granules Solid Bag MP 97 C 176 NA 15 LD at 25 C NA NA NA NA 15 NaMBT Solution (50%) Liquid Drum MP 155 C < 108 C not applica ble not applicable LD 50 - > 2000 mg/kg 1.25 to 1.28 NA NA NA NA 17 Hydrogen Gas Gas Pipeline through - - B.P -253 C NA 4-74% NA NA NA NA Para nitroaniline NA Not available solid Bag M.P C, B.P 260 C 213 NA 3 mg/m3 LD50-oral- 750mg/kg, 1.4 NA Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 197 of 252

8 Preventive Measures provided Level indicator with high level alarm and level overfill switch on DCS. Chilled water circulation, Flame proof fittings, Tank level control on DCS. CCOE License premises, Earthing and Bonding, Tank insulated with Urethane puff insulation, SOP for tanker unloading, Flame arrester, breather valves provided on vents, very low FP chemicals stored underground, continuous nitrogen purging in vents of Pure MIAK and Vulkanox 4030, HCl tank vent provided with scrubber pot, U/g Acetone tanks provided with vent chiller, Lightning arrester provided near to tank, Gas Leak Detector, HC detectors Control Measures Provided :- hydrant system, Portable Extinguishers, Foam TEnder, Water Hydrant and Monitor, Self Contained Breathing Apparatus, Flame proof spanner, Dike wall for containment, Shower & Eye Washer near Tank Farm Area The unit shall be a MAH installation in accordance to the schedule 3 of MSIHC rules, PROCESS HAZARDS AND THEIR CONTROL MEASURES Table - Process Hazards and their Control Measures Sr. Name of hazard Its source and reasons Effects on No. employees 1 Mechanical Sources: Moving object, Chain pulley block, lifting devices, grinding and Injury hazards welding work, working at height, Reason- Deviation in the procedure, use of faulty equipment 2 Electrical Personal electrical shock, Short circuit Injury hazards 3 Exposure to (or Leakages of hazardous chemicals, fugitive emission, opening of Injury and handling of) equipment for repair and maintenance, manual charging, confined space health effects substances. entry, waste handling etc Sr. Name of hazard Control measure provided No. 1 Mechanical hazards HAZOP of every process, Risk assessment and mitigation Covering of the moving part, Scaffolding and fall protection for working at height Periodic inspection of lifting tackles and pressure vessels, HSE guideline- Good working practices, SOPs, Work permit system Regular HSE training 2 Electrical hazards Electrical shock proof gloves and shoes, Electrification as per zone classification, Electrical work permit system 3 Exposure to (or handling of) substances. through Leakage from line / valve Failure of part of vessel or jacket Spillage from drums / bags No open handling of chemicals and waste is allowed. Vents of toxic chemicals storage and processes are connected to off gas incinerator SOP for decontamination of equipment and pipelines for maintenance and repair are available. Device conditioning tag PPE rules for the site are available. ABEK masks and dust masks (P1/P3) are compulsory for working in the potential chemical exposure area and dust prone area. Automatic water spray system is installed in the CME plant to neutralize toxicity of CME. Anti-dotes; methylene blue (for aromatic amines) and cyanide kit (for acrylo nitrile) are available in the OHC There is no open handling of hazardous waste. ETP sludge is being filled in jumbo bags and transported to BEIL for landfill. Adequate PPEs are provided for packing work of ETP sludge. Drum decontamination procedure is made. Adequate PPEs are made available. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 198 of 252

9 7.8 OTHER HAZARDS & CONTROL Following are the other possible hazards : Explosion due to Natural gas this hazard shall exist only after unit gets NG supply from GSPL or GGCL Structural failure this hazard is related to other hazards Transportation hazards - proponent has taken adequate fire protection and control measures as mentioned in later sections. Toxic Release from outside taken care by GIDC fire station, mutual aid and District authorities Natural Calamity (Flood, Earthquake, lightning etc.) The project area is sufficiently away from major river - Narmada river, since the site is at an elevation of ~ 40 m from the MSL. Storm water drainage network is inplace and also the floods or abnormally high precipation may obstruct block the internal roads and SH-64 & 165 only for a short period owing to the good drainage towards the sea. Jhagadia GIDC estate falls in the Seismic Zone III. are no instances of Tsunami in the recorded past. Since the estate is located at sufficient height from sea, there Sensitive locations around the project Table - Sensitive locations around the project Receptor station no. Receptor Approx. Aerial Dist. From the site, km Direction w.r.t project site Upwind or downwind w.r.t project site and predominant wind direction (SW-NE) 1. Dadheda , SSW Upwind 2. Talodara , SE Crosswind 3. Selod , NNE Downwind 4. Fulwadi ,N Downwind 5. NH-8 Vadodara Mumbai 6.92 NWW Crosswind 6. SH E Downwind 7. SH W Crosswind 8. Selod fulwadi via SH N Downwind 9. Fulwadi to Kapalsadi 1.26 NNW Crosswind 10. Dadheda to Sardarpura 2.50 SW Upwind 11. Ankleshwar-Rajpipla railwayline PROPOSED RISK REDUCTION MEASURES FOR THE PROJECT NWW Crosswind Proponent is committed to provide advanced risk reduction measures as already exists in the unit. Existing Safety Features Systems The Plant is built as per engineering codes & standards such as ASME, applicable Indian standards (IS).Incinerator in provided and all hydrocarbon vents are directed to incinerator. This include safety valve and rupture discs discharge and normal vents. DCS Control System and Emergency Shutdown System The plants are fully automated and controlled through DCS system.plc based Emergency Shutdown system is also provided. These systems shuts down the plant based on defined interlocks and isolate all feeds to reactors / storages through remote ON/OFF valves, stops pumps. Defined Standard Operating Procedures Maintenance systems Hazardous materials like CME, TMA, Oleum are handled in the plant. Defined maintenance procedures are followed for maintenance of lines or equipments handling these hazardous materials. Special types of gaskets are used for CME, TMA. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 199 of 252

10 Standard Operating procedures are available for all critical activities like oleum tanker, TMA tanker unloading. Every tanker unloading and loading is done in presence of operator only. Water Network: water ring is provided around all process units of the plant. The ring is kept pressurized by continuously running jokey pumps. The network ring is provided with hydrants & monitors placed sufficiently to cover all process areas. In case of any emergency 1 electrical motor driven and 2 diesel engine driven pumps provides required water flow for firefighting.3000m3 of water is kept as fire water reserve within Raw Water Tank. Automatic and Manual Spray System Automatic medium velocity water spray is provided in flammable material storage area like MEK and Styrene aboveground tanks. The detection and actuation is through quartzite bulb sensors. Automatic spray valves can be operated manually from field also. & Gas Detection detection in flammable storage area is provided with quartzite bulb sensors. Gas detectors are placed in the process area at strategic locations. Safety at Storage areas Flammable Material storage (Acetone, Toluene, MIK, Styrene, MIBK, Aniline, & MEK) All flammable storage tanks and vessels are separated with sufficient distances. They are placed in concrete dike. Hydrocarbons like Acetone, Toluene, MIK and MIBK are stored in underground tanks. This will minimize the danger of failure of these tanks and damage due to adjacent fire. MEK tank farm is in separate concrete dyke. The fire water hydrant and monitors are placed around the storage areas sufficiently. Above ground flammable storage tank, MEK and Styrene are provided with medium velocity fire water spray system which automatically actuated through QB sensors. Breathing valves are provided on atmospheric tanks to take care of pump out and pump in requirements. Emergency vent, safety valves, rupture disc is provided to safeguard system from overpressure. The discharge from all these valves is directed to either atmosphere or disposal system. All pumps are kept outside dike area and remote operated valve is provided at pump suction to isolate in case of emergency. Toxic Material storage (H2SO4, HCL,4-Aminophenyl Amine) All toxic storage tanks and vessels are separated with sufficient distances. They are placed in concrete dike. water hydrant and monitors are placed around storage tanks. 4-Aminophenyl Amine is stored in atmospheric tank in molten condition. The material is kept in molten state by means of steam coils inside the tank. This material will solid at normal atmospheric temperature. Hence in case of spillage or leakage this material will solidify. Common features of Storage Tanks Located and marked in the designated area for hazardous material storage. Level indicators with high / low alarms in tanks are provided. Interlocks are provided to stop pump,close ON/OFF valves to avoid overfilling. Breathing valve, Safety relief valve with rupture disc to be provided on the tanks. Concrete Dyke wall provided to contain spillage / leakages, acid proof tiles provided for each material tanks separately. water ring with hydrants is available in storage area. Medium velocity water spray system is provided for flammable material storage tanks. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 200 of 252

11 In addition, a well planned disaster management system is in place through onsite emergency plan implemented by dedicated team of experience professionals. Preventive Maintenance of all control systems and instrumentation is carried out Training of SOPs and emergency handling are given to all employees as per training calendar Well equipped OHC and ECC Hence, a good level of inbuilt plant safety and risk control is prevailing and is anticipated to remaint the same after proposed expansion Details of Protection System Sprinkler systems, Medium Velocity Water Spray (MVWS) is installed on following tanks a. Styrene tank b. Methanol tank c. TMA tank d. MEK tank e. Methyl Chloride storage area Fix Water curtain system is installed at CME plant protection The entire plant has been classified in the hazardous area & accordingly the fire hydrant system, medium velocity water spray system has been laid in the plant. The fire fighting facilities available in the plant are as per the TAC Norms. Also all the relevant provisions as per Gujarat Factory Rules 1963 are being complied with. The process equipment is easily accessible for fire fighting. All the electrical equipment in the classified area is flame proof as per the requirement of the area. The equipment is properly earthed for protection against accumulation of any static charge. Protection against lightening has been provided for the units & storage area. Smoking is prohibited inside the battery limit. In the plant, no flammable cylinder containing compressed gas is being stored in any workroom of the area. Drains have been provided in the plant to confine the escape of any leakage of flammable liquids & are routed to underground drain. Adequate numbers of bins have been provided in the plant for waste materials. Proper escape routes have been provided in the plant & are clearly marked. The First Aid & fighting equipment provided in the plant conforms to relevant Indian Standards. The Extinguishers provided in the plant cover the entire plant. These extinguishers are of similar make & having the same methods of operation. These extinguishers are numbered having date of last refilling, inspection & next inspection due on. These extinguishers are checked and maintained once in three months by well trained and experienced personnel in the field of fire and safety and record of such inspection and maintenance is maintained at the plant. All the officers at plant are well trained in safety and fire protection and are assisted by well-trained fire fighters for any emergency. Besides all the security guards, contract labours are also trained in fire fighting. Hydrant system provided in the factory premise is designed as per TAC regulations. The fire hydrant system comprises of the following: Water Storage : The hydrant system shall be served by common raw water cum firewater reservoir having a total capacity of 7000 m3 (3000 m3 for fire m3 for palnt). The tank is made for MS material and is located on above ground with proper RCC base. The pump house level is such that flooded suction is available to the fire water pump sets. Pumps : pump house having a electrical driven and two diesel engine driven Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 201 of 252

12 fire pumps of capacity 272 m3/hr delivering water at 8 kg/cm2 (g). The diesel engine driven pump sets shall be used in case of power failure or in stand-by mode. A small 20 m3/hr jockey pump is provided in pump house which runs continuously to maintain pressure of 7.0 kg/cm2 continuously in hydrant mains. Hydrant Ring: A suitably sized and well-interconnected ring mains is provided in the factory area. At regular intervals of 45M a standby post and a hydrant valve is provided. A wet riser and hydrant valve at each staircase landing is provided for upper floors in the building. Near each hydrant valve a hose box with 2 nos. 15M long canvas hose and G.M branch pipe with nozzle is provided. The ring mains and risers have suitable isolation gate valves to direct flow of water to seat of fire and to isolate damaged/broken mains in case of major fire outbreak and plant damage. As per the standard practice of the company, Mock drills are conducted on monthly basis & Disaster drill involving District Administration, brigade, and Police on half yearly basis as per guidelines of Factory Act At design, construction & commissioning stages Inbuilt safety features :- Fail safe instrumentation and control systems for DCS and PLC, including indicators, high and low alarms, NRVs, controllers and autoshutoff systems as well as interlocks PSVs and TSVs as well as rupture discs on reactors and storage tanks Intelligent / Fuse less MCC for entire site Smoke detectors, LEL detectors & HC detectors at all plants and storages Civil foundations and structural work shall take into account protective measures for earthquakes, cyclones, landslides, flooding etc. Seamless pipelines used wherever necessary. Jumpers provided on flanges to prevent static charge. Flange guards to prevent splashing incase of gasket failure. Lightning arrester installed at all critical locations Electrical grounding of the vessels / equipment/machinery and flameproof and sparkproof fittings and electrical. A well-planned and well-maintained electrical grounding system with sufficient earthing pits provided covering all areas handling flammable chemicals including storages, production areas, loading, unloading areas, warehouses etc. Storage tanks and areas designed and constructed in compliance to the various applicable rules under Manufacture, storage & Import of Hazardous Chemicals Rules, Explosives Act, Petroleum act, Factories act and SMPV rules. Nitrogen blanketing, flame arrestors, water sprinklers, breather valves and vapor recovery systems provided to storage tanks as per requirement of MSDS and applicable rules. The bulk chemicals storage area kept away from the main production areas. For emergency management :- hydrant system covering the entire plant to be provided. Emergency power for all critical drives / instruments Extinguishers placed at all the appropriate places. Sand buckets also made available. Self Contained Breathing apparatus (SCBA), LEL detectors and oxygen detectors procured for emergency handling. Garland drains covering the plant to contain contaminated water during fire emergency Dedicated storage for fire water Eye washers / showers provided at all required locations Personal protective equipments provided to all the employees related to the type of work and hazard associated Mutual aid from neighboring industries available whenever need arises. Well equipped OHC and ECC Onsite emergency plan and emergency management team. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 202 of 252

13 7.9.3 During operational phase Safe operating procedures developed for handling of hazardous chemicals and for critical process operations such as loading and unloading tankers, drum charging, drum movement, vessel opening or drum opening, work permit systems Do and Don ts for handling chemicals and process operations (Annexure 20) DCS and PLC controlled operations with interlocks and autoshutdown systems Appropriate PPE provided to workers w.r.t type of operation and material handled. Preventive maintenance schedule for all critical equipment and vessels planned and followed. Do s and don ts for maintenance of critical equipment and machinery prepared and instructed to operators (List is annexed as Annexure 20) Work Permit system implemented for hot work in Plant / Off-Site / Storage area, Vessel Entry Permit, Working at Height, Opening of the Process lines. Training programs conducted for workmen in following areas : Operational safety procedures start up and shut down procedure. Handling and storage of hazardous chemicals precautions against exothermic and pressurized operations. Importance of using personal protective equipment Handling and operation of Self-breathing apparatus Understanding of MSDS Information Causes of Accident and preventive measures Good housekeeping Fighting Onsite emergency plan and individual role and responsibilities All employees covered under Group Insurance Policy along with personal accident cover Accident records maintained and top management at global headquarters appraised using Incident Reporting System (IRS) Periodical medical checkup of employees done & health records kept and health card issued to each and every employee. All the equipment and pipelines marked for identification All the safety devices and instruments like safety valves, tested, inspected and recalibrated as per safety norms. hydrant system, fire alarms, LEL detectors examined periodically and preventive maintenance to be undertaken. Hydraulic testing of pressure vessels, and tanks done through Government approved Competent Person. (As per rule). Match boxes, Cigarettes, Mobile, any petroleum product prohibited. Visitors required to deposit such items at security gate. To check preparedness of workers for emergency control, mock drills on regular basis and disaster drills as per factory inspectorate guidelines to be conducted. fighting team with adequate firefighters in each team and having proper training Trained first aid team (total 57 nos. as on date) Ignition exclusion Zones of the Plant clearly marked with No Sparks Zone. Head count of all employees inside the Plant premises maintained by the Duty Security Head in a register on the Gate. Similarly, head count of all contract workers and labourers maintained. It should be noted that Lanxess has Jhagadia factory has received the prestigeous ICC award for safety in Most recently, the group LANXESS is also a pioneer founder member in the ICC Nicer Globe initiative for enhancing road safety for transportation of hazardous goods through Transport & Distribution Safety, Chemical Emergency Response, Transport Security. There have been total three reportable accident since SOP is available for defining system for classifying, reporting and investigating accidents and near misses. The SOP classifies incidents in three levels as per company s global directives Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 203 of 252

14 The top management onsite and corporate offices are appraised by IRS online system. For emergency, PA system and walkie talkie are used between plant units. Respsonsibilities are assigned as under : 1. Adequacy of document and monitoring the process- Head HSE 2. IRS reporting Level 3 HSE coordinator of individual BU 3. IRS reporting Level 2 and 1- Head HSE 4. Reporting to authority- Safety Officer 5. FIR reporting Respective area Supervisor 6. Investigation of incident- Individual BU 7. Reporting to Management- As per crisis communication chart There have been three (3) reportable accident till date since 2010 (contract employee) All incidents/near misses reported to Plant manager. Re audit of the site is done for ensure implementation of the recommendation to avoid the recurrence of the incident & accident. The lost time information is accounted 7.10 VISUALIZATION OF ACCIDENT SCENARIOS Based on the inventory, physical and chemical properties as well as the activities associated with storage and handling of hazardous chemicals, the largest potential hazard inventories are considered. Different release scenarios are visualized for these inventories and short-listed for carrying out the consequence analysis. One scenario considered for all is Catastrophic Failure, which is the worst case (WC) and frequency of which is very rare in the lifetime of the plant. Hence most credible accident scenarios (MCA) are also considered, primarily leaks from tanks or vessels. Normally all vessels or tanks have following connections 1. Inlet Pipe, Outlet Pipe, Level indication connections, Vent pipe, Minimum Flow line(if pump is at outlet), Pressure indication connection 2. Leak in the vessel or leak from the flange joints of these connections is possible. The leak through flange failure is considered from 50% of flange perimeter and accordingly equivalent area is calculated. This area is approximated to hole of 50mm or 2 diameter. The small bore pipes less than 2 is considered full bore leak. 3. The atmospheric tanks catastrophic failure is considered as worst case scenario 4. The hydrogenation reactor catastrophic failure is considered as worst case scenario for reactor / process area Selection of Initiating Events And Scenarios Following event tree is followed for deciding toxic and/or flammable effects: Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 204 of 252

15 Based on the inventory of hazardous chemicals and their hazardous properties, following accident scenarios have been visualized for the given project. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 205 of 252

16 Environmental Impact Assessment (EIA) - EMP and Risk Assessment Study Report Table - Worst Case (WCS) and Most Credible Accident (MCS) Scenarios selected for the study S. Hazardous Press Temp Equipment Scenario Scenario Considered Type Leak Release Type of No Material Bar g Deg.C Considered Area of Size Duration consequence scenar (dia, (max) in io mm) mins 1. Acetone Transfer piping including pump Storage Leak from pump discharge pipeline feeding to reactor from storage tank MCS Explosion Flammable 2. Aniline 2 Ambient Ambient Storage Tank Storage Catastrophic Failure of tank WCS - - Explosion Flammable Toxic 3. Aniline 4 30 Transfer piping including pump Storage Leak from pump discharge pipeline feeding to reactor from storage tank MCS Explosion Flammable Toxic 4. H2SO Transfer piping Storage Leak from pump discharge pipeline MCS Toxic including pump feeding to reactor from storage tank 5. HCl 4 30 Transfer piping Storage Leak from pump discharge pipeline MCS Toxic including pump feeding to reactor from storage tank 6. Methyl Ethyl Ambient Ambient Storage Tank Storage Catastrophic Failure of tank WCS - - Flammable Ketone 7. Methyl Isoamyl 4 30 Transfer piping Storage Leak from pump discharge pipeline MCS Flammable Ketone including pump feeding to reactor from storage tank 8. Methyl Isobutyl 4 30 Transfer piping Storage Leak from pump discharge pipeline MCS Flammable Ketone including pump feeding to reactor from storage tank 9. Styrene Ambient Ambient Storage Tank Storage Catastrophic Failure of tank WCS - - Flammable 10. Toulene 4 30 Transfer piping Storage Leak from pump discharge pipeline MCS Flammable including pump feeding to reactor from storage tank 11. Hydrogen Pipeline Reactor Leak from hydrogen supply line MCS Explosion 12. Hydrogen Hydrogenation Reactor Catastrophic Failure of reactor WCS - Instantaneo Explosion 13. MEK mixture in reactor Reactor Hydrogenation Reactor us Reactor Catastrophic Failure of reactor WCS - Instantaneo us Flammable Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 206 of 252

17 Figure - Locations of selected scenarios 7.11 CONSEQUENCE ANALYSIS Hazardous substance on release can cause damage on a large scale in the environment. The extent of damage is dependent upon the nature of the release and the physical state of the material. It is necessary to visualize the consequences and the damages caused by such releases. The quantification of the damage can be done by means of various models, which can further be related in terms of injuries and damage to exposed population and buildings. Software used for consequence analysis for proposed project of M/s. Pidilite Industries Ltd. at Dahej - III : ALOHA (AREAL LOCATIONS OF HAZARDOUS ATMOSPHERES) Is part of the CAMEO suite developed by US Environmental Protection Agency (EPA), ALOHA is an atmospheric dispersion model used for evaluating releases of hazardous chemical vapors, including toxic gas clouds, fires, and explosions. Using input about the release, ALOHA generates a threat zone estimate. A threat zone is the area where a hazard (such as toxicity, flammability, thermal radiation, or damaging overpressure) is predicted to exceed a userspecified level of concern. Threat zones can also be plotted on maps with MARPLOT to display the location of facilities storing hazardous materials and vulnerable locations (such as hospitals and schools). Specific information about these locations can be extracted from CAMEO information modules to help make decisions about the degree of hazard posed. In order to assess the damage, the damage criteria have to be first defined. There are three principle types of exposures to hazardous effects Heat radiation from a jet, pool fire, a flash fire or a BLEVE Explosion, Toxic effects, from toxic materials or toxic combustion products A basis for the weather conditions (Temperature, wind speed etc.) is chosen for input in these models. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 207 of 252

18 Frequencies Estimation: The risk is computed as product of consequence of event and frequency of occurring of the event.as part risk assessment frequency estimation is one of the activity.in literature and published guidelines the frequencies of catastrophic failure of various equipments are published. For this assessment the used set of frequencies is taken from Dutch Purple book,2008. Also for credible scenarios the frequencies for leaks from equipments or pipelines are available in the same source as above. For credible scenario the frequency of leak event is calculated as summation of frequencies of each element in the considered vessel. No Item Mode Of Failure Failure Frequency 1 Atmospheric Storage Tanks Catastrophic Failure 10E-9 /yr Significant Leak 10E-5 /yr 2 Process Pipelines <=50mm Dia Full Bore rupture 8.8 x 10E-7 /yr Significant Leak 8.8 x 10E-6 /yr >50mm<=150mm Dia Full Bore rupture 2.6 x 10E-7 /yr Significant Leak 5.3 x 10E-6 /yr <150mm Dia Full Bore rupture 8.8 x 10E-7 /yr Significant Leak 2.6 x 10E-6 /yr 3 Hoses Rupture 3.5 x 10E-2 /yr 4 Pressure Vessel Catastrophic Failure 3 x 10E-6 /yr Significant Leak(6" nozzle) 7 x 10E-6 /yr 5 Liquid Line Pipeline Leak 3 x 10E-7 /yr Fittings Leak 5 x 10E-6 /yr 6 vapor line Leak 3 x 10E-6 /yr 7 6" Pipe Leak (1 kg/s) 6x 10E-6 /yr 8 3" Pipe Leak (1 kg/s) 6 x 10E-5 /yr 9 Flange Leak (1 kg/s) 3 x 10E-4 /yr 10 Pump Seal Leak (1 kg/s) 5 x 10E-3 /yr For warehouse where the drums of chemicals are stored and handled the frequencies are as follows, No Item Mode Of Failure Failure Frequency storage of substances in Liquid Spill 1 x 10E-5 Per handling 1 warehouses 8.8 x 10E-4 / yr with protection levels 1 and 2 storage of substances in Liquid Spill 1 x 10E-5 Per handling 2 warehouses with protection level x 10E-4 / yr Failure History Data Table - Failure History data Sl. Item International Data Indian Data No. 1 Process Controller 2.4 x 10-5 hr x 10-5 hr-1 2 Process Controller Valve 2 x 10-6 hr x 10-5 hr-1 3 Alarm 2.3 x 10-5 hr x 10-5 hr-1 4 Leakage at biggest storage tank 5 x 10-5 yr x 10-5 yr-1 5 Leakage pipe line 1 x 10-7 m-1yr x 10-8 m-1yr-1 6 Human failure 1 x 10-4 (demand) x 10-3 (demand)-1 Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 208 of 252

19 Assumed Failure Rate For The Study Table - Assumed failure rate for the study SNo. Item Rupture (yr-1) Leakage (yr-1) 1 Pipe lines < >15 2 Vessel - pressurized - Atmospheric x x x x 10-4 Damage Due To Incident Radiation Intensity Table - Damage Due To Incident Radiation Intensity Incident Radiation Type of Damage Intensity (kj/m²s) 62.0 Spontaneous ignition of wood 37.5 Sufficient to cause damage to process equipment 25 Minimum energy required for ignite wood at infinitely long exposure (non piloted) 12.5 Minimum energy required of piloted ignition of wood, melting plastic tubing etc. 4.5 Sufficient to cause pain to personnel is unable to reach cover within 20 sec.; however blistering of skin (1st degree burns) is likely 1.6 Will cause no discomfort on long exposure Physiological Effects Of Threshold Thermal Doses Table - Physiological Effects Of Threshold Thermal Doses Dose Threshold (kj/m²) Physiological Effect 375 Third Degree Burns 250 Second Degree Burns 125 First Degree Burns 65 Threshold of pain, no reddening or blistering of skin caused 1st Degree Burns Involve only epidermis, blister may occur 2nd Degree Burns Involve whole of the epidermis over the area of burns plus some portion of dermis 3rd Degree Burns Involve whole of epidermis and dermis. Subcutaneous tissues may also be damaged Heat Radiation & Escape Time Table - Heat Radiation & Escape Time Radiation Intensity BTU/hr/ft² Time to Pain Threshold (Seconds) 440 (1.39 kw/m²) (1.6 kw/m²) (2.33 kw/m²) (2.9 kw/m²) (4.7 kw/m²) (6.93 kw/m²) (9.5 kw/m²) (11.66 kw/m²) (19.9 kw/m²) 2 Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 209 of 252

20 Tolerable Over Pressure Limits For Various Objects Table - Tolerable Over Pressure Limits For Various Objects Incident Over Pressure Object (Bar) 0.02 Schools 0.04 Domestic Housing 0.05 Public Roads 0.07 Ordinary Plant Buildings 0.10 Buildings with shatter resistant windows fixed roof tanks containing highly flammable or toxic materials 0.20 Floating roof tanks, other fixed roof tanks, cooling towers, utility areas site roads 0.40 Other hazardous plants 0.70 Non-hazardous (if occupied) plants. Control room designed for blast resistance Assumptions Common for all Scenarios Following atmospheric conditions are considered. Atmospheric Conditions Inputs Maximum Temperature Deg.C 41.5 Minimum Temperature Deg.C 11.5 Maximum Wind speed m/s 11.2 Minimum Wind speed m/s 2.1 Average Wind speed m/s Wind Direction From South West Humidity % 70 Ground Roughness Urban or Forest Cloud Cover % 50 As minimum wind speed 2.1 is only present at less than 1% of year, for atmospheric stability class 3m/s speed is selected and accordingly D class is default value by ALOHA. But to get more stable weather condition, this stability class is overridden to E. Hence at lower temperature to analyze for more stable atmospheric condition stability class 3E is considered. For higher temperatures i.e. day time condition the atmospheric stability class is taken as D and wind speed is taken as 6m/s. The analysis will be done for both cases. For any particular case if other stability class is chosen, it is included in its detail analysis. The transfer of chemicals from storage tanks to process area/reactor is by means of centrifugal pumps. The discharge pressure of pumps is assumed in range of 4 7 barg.for calculation the pump discharge pressure is taken as 4 barg. For credible scenario the leak may be from chemical transfer lines or from pump seals. The leak may be from pump suction piping also. But for conservative results the leak is assumed from discharge piping or seals as pressure will be higher in this case In case of credible scenario, the release is from 10mm hole and release duration is 10 mins. This time includes detection, response and isolation during event. This assumption is based on the DCS control system, emergency shutdown system and leak detection systems are available in the plant and discussion with plant personnel. Following points considered, Pump start / stop facility is available from DCS (Control Room) Sufficient indications and Alarms are configured for effective monitoring Interlocks and Emergency Shutdown valves are provided which isolates the required stream through ON/OFF valves or stops the pump. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 210 of 252

21 This time includes detection, response and isolation during event. The discharge through leak is modeled as liquid flow through sharp edged orifice and calculated using following equation. Q = (A*Kd*Sqrt(P1-P2/Sp.Gravity))/11.78.(Ref : API520 Liquid Discharge eqn) Q = Volumetric Flow, lit/min A = Orifice Area, mm2 Kd = Discharge coefficient P1 = Upstream pressure, kpa P2 = Downstream pressure, kpa For underground flammable storages the leak is assumed outside this u/g storage area and which do not have any bund wall or dike. Except hydrogenation reactor, all scenarios will be analyzed in respective pumping locations in storage area. The hydrogen cylinder leak scenario is considered in, cylinder bank area. All storages at atmospheric pressure and temperature. At respective class atmospheric temperatures, flash point is higher and chemical may not ignite. But to assess the radiation effect at such situations, the radiation effect is calculated assuming burning is started due to other ignition source. For chemicals having flash point more than 45degC,the effect is analsyed only for class D. The sulfuric acid is 98% conc and not oleum. The consequences of toxic material are calculated up to the LC 50 / LD 50 concentration for catastrophic failure and Maximum credible scenario. (If LC50 value is not available, then whichever value is available from IDLH,ERPG,AGCL) For thermal radiation the distances for radiation level 37.5 kw/m2, 4kw/m2 and 1.6kw/m2 are calculated. For vapor cloud explosion the distance for overpressure of 0.5psi is calculated Water network is provided all along the plant with hydrants, monitors, risers and spray system. water system comprises of FW storage of 3000m3 and pumping system. The pumping system consists of Jockey pump,3main FW pumps ( 2 Diesel Engine driven + 1 Electric motor driven) Specific assumptions are mentioned in the detailed description of each scenario in following sections. The ALOHA text summary output for each scenario is annexed as Annexure 12. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 211 of 252

22 Environmental Impact Assessment (EIA) - EMP and Risk Assessment Study Report Summarized Table for effects of Consequences Toxic End Points Table - Toxic End points of Consequence Analysis No Hazardous Material Equipment Considered Scenario Selected Material Released End Point Endpoint Concentration Stability Class Maximum Distance Maximum Distance to IDLH 1 Sulfuric Acid Pump and associated piping 2 Hydrochloric Acid Pump and associated piping 3 Aniline Pump and associated piping Kg ppm m m Leak through 10mm hole 1233 LC D (6) <10 <10 ERPG2 510 E(3) <10 <10 ERPG2 Leak through 10mm hole 1225 LC D (6) <10 < E(3) <10 <10 Leak through 10mm hole 919 LC50 44(mg/lit) D (6) <10 <10 44(mg/lit) E(3) <10 <10 4 Aniline Storage Tank Catastrophic Failure 100KL LC50 44(mg/lit) D (6) <10 <10 44(mg/lit) E(3) <10 <10 Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 212 of 252

23 Environmental Impact Assessment (EIA) - EMP and Risk Assessment Study Report Flammable Endpoints Table - Flammable End points of Consequence Analysis No Hazardous Material Equipment Considered Scenario Selected Material Released Stabilty Class Flash Envelope Diameter LOC(60% of LEL) Explosion Overpressure Distance for 0.5psi 0.05bar pool/ Jet Burn Duration Heat Iradiation Maximum distances, m kg m m mins 37.5Kw/m2 4Kw/m2 1.6Kw/m2 1 Acetone Pump and Leak from 809 D (6) <10 - Pool 6 < associated 10mm dia. piping hole E(3) <10 - Pool 7 < Toluene Storage Tank Leak from 845 D (6) <10 - Pool mm dia. hole E(3) <10 - Pool 5 < Methyl Pump and Leak from D (6) <10 - Pool Isobutyl associated 10mm dia. Ketone piping hole E(3) <10 - Pool 5 < Methyl Pump and Leak from D (6) <10 - Pool Isomyl associated 10mm dia. Ketone piping hole E(3) <10 - Pool 6 < Methyl Ethyl Storage Tank Catastrophic 100KL D (6) <10 - Pool > Ketone Failure E(3) <10 - Pool > Hydrogen Pipeline Leak from 22.4 D (6) < mm dia. hole E(3) Styrene Storage Tank Catastrophic 100KL D (6) <10 - Pool > Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 213 of 252

24 Environmental Impact Assessment (EIA) - EMP and Risk Assessment Study Report No Hazardous Material Equipment Considered Scenario Selected Failure 8 Aniline Storage Tank Catastrophic Failure 9 Aniline Pump and associated piping 10 Hydrogen Hydrogenation Reactor (Explosion) 11 Solvent (MEK) Hydrogenation Reactor () Leak 10mm hole from dia. Catastrophic Failure Catastrophic Failure Material Released Stabilty Class Flash Envelope Diameter LOC(60% of LEL) Explosion Overpressure Distance for 0.5psi 0.05bar pool/ Jet Burn Duration Heat Iradiation Maximum distances, m kg m m mins 37.5Kw/m2 4Kw/m2 1.6Kw/m2 E(3) <10 - Pool > KL D (6) <10 - Pool > E(3) <10 - Pool Chemical below flash point (70 degc) 919 D (6) <10 - Pool 9 < E(3) <10 - Pool Chemical below flash point (70 degc) 14.1 D (6) E(3) D (6) 112( s E(3) 112( s Note : Material Released is the total material discharged to atmosphere. In case of Liquid Pool, from this released material some of the material will be evaporated and dispersed in direction of wind. This evaporated quantity will be less than total quantity depends on the properties of material spilled and atmospheric conditions. Detailed output of aloha is attached as annexure 12. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 214 of 252

25 Inference of Consequence analysis Aboveground Storage Area The catastrophic failure of atmospheric storage tanks of Styrene, Aniline and MEK is analyzed. The frequency of catastrophic failure of atmospheric tanks is 5 x 10E-6. The major consequence is pool fire. In case of catastrophic failure of tank the released liquid will be contained inside the dyke and pool is formed. The maximum radiation from pool fire is estimated from MEK fire.mek is stored at sufficiently spaced from other storage area and process area. The 4.0 kw/m2 radiations from MEK fire (53m) will not cross MEK storage area boundary. In case of Styrene the 4.0 kw/m2 radiation distance is 45m. Both these tanks are equipped with medium velocity FW spray system. In case of Aniline the 4.0 kw/m2 radiation distance is 30m As most credible scenario, which are calculated for all reactants and raw material transfer lines can take place at storage area as well as reactor / process area. The frequency of such leaks is 5 x 10E-6. The major hazards from all these flammable leaks are pool fire. The radiation experienced is maximum in case of MIBK. The 4.0 kw/m2 radiations from MIBK fire will be experienced upto 25m. Aniline release will pose toxic hazard. The analysis shows that the toxic hazard from the Aniline release is not significant Reactor Area The catastrophic reactor failure analysed are resulting in explosion and release of flammable material like Methyl Ethyl Ketone (MEK). In case of explosion the 0.5 psig (which may cause shattering of glasses) overpressure will be experienced up to 25m. The release of flammable solvent from the reactor during its explosion will create fireball. The fireball diameter is estimated as 112m.But as the reactors are located in process building the extent of fire ball may be limited within this building. This fire will last for 8 secs.the 37.5 kw/m2 radiation will be experienced in the process building for these 8 secs. The hydrogenation reactors are generally equipped with safety systems to take care for runaway reactions, over-temperature and over-pressure scenarios. For this temperature, pressure indications with alarm and trip interlocks are used. The frequency of reactor failure is 5 x 10E-6 and ignition is almost instantaneously due to hydrogen. As most credible scenario, which are calculated for all reactants and raw material transfer lines can take place at storage area as well as reactor / process area. The frequency of such leaks is 5 x 10E-6. The major hazards from all these flammable leaks are pool fire. The radiation experienced is maximum in case of MEK. The toxic hazards from the materials handled in the process area are not significant Underground Storage Area The underground storage will eliminate the possibility of catastrophic failure of storage vessels.the most credible scenarios considered in this area are 10mm leak from pump discharge lines of all flammable reactants, solvents. The frequency of such leaks is 5 x 10E-6. The major hazards from all these flammable leaks are pool fire. The radiation experienced is maximum in case of Toluene. The 4.0 kw/m2 radiations from Toluene fire will be experienced upto 29m HCL / Sulfuric Acid Storage Area As most credible scenario, the released is analysed as 10mm leak from individual chemical pump discharge line to reactor / Storage. The frequency of such leaks is 5 x 10E-6.For oleum the frequency is increased by 10 due to corrosive nature Risk to Individuals from a Major Release The risk to health to an individual at a specific point in the direction of the plume or heat radiation is dependent on a number of factors, the most important being: o the direction of the wind when the release takes place; and o mitigating factors, such as whether the individual might be indoors or out of doors. In the case of the wind direction, the plume width may be represented by the sector of a circle having an included angle of 15 o. In such a case, on the basis that wind direction arise, it is possible to approximate that an individual present in a single location for one year may be exposed for only 15/360ths of that year, or 4 x 10-2 Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 215 of 252

26 No In reality, it is unlikely that a person would be present at any one location in the open air for 100% of the year. Allowing for periods at work or indoors, a risk reduction factor of 3 is reasonably conservative.(three shift operation is considered) Also the fatality % due to radiation is assumed at 50%.This assumption is based on the reposne time and the duration of fire in our case. We have two major fires,one is due to hydrogenation reactor failure in reactor area and other is due to solvent (MEK) tank failure. The r eactor fire will last for 8 sec and for storage tank the response time is 2 mins to evacuate persons from the area. The overall consequence of the mitigation due to wind direction and indoor/outdoor location would be the product of these three factors, namely 1.33 x The overall chance of an individual being affected at a specific location by exposure to the radiation would be as indicated in following table. From the table it is clear that for catastrophic failure the distances for 50% fatality is more than MCS scenarios. Hazardou s Chemical Incident/Dif ferent Cases Hydrogenation Reactor () 1 Methyl Ethyl Ketone(So lvent) Catastroph ic Failure of Reactor Radiat ion for 50% fatality (kw/m 2) Flammable Storage Area(Above Ground) 2 Methyl Ethyl Ketone(So lvent) Catastroph ic Failure of tank 3 Styrene Catastroph ic Failure of tank 4 Aniline Catastroph ic Failure of tank Distan ce to Radiat ion for 50% fatality (m) Frequen cy of Occuran ce per yr No of Vessels/Re actors (No of Probable Sources) Freque ncy of Occura nce per yr E E E E E E E E MIAK Pipeline Leakage E E- 05 Flammable Storage Area(Under Ground) 8 Toluene Pipeline E E- Leakage 05 9 MIBK Pipeline E E- Leakage Acetone Pipeline E E- Leakage RECOMMENDATIONS Consequ ence Mitigation factor Frequenc y of Occuranc e per yr (Represen ting Individual Risk) Cummulat ive Individual Risk (Areawise ) 6.94E E E E E E E E E E E E E E E E E E E E E E E E Reactor area Hydrogenation Reactor runaway The mitigation controls to avoid damage due to hydrogenation reactor explosion are of two types, to avoid the runaway to happen and other measure to minimize the damage if runaway occurs. To avoid runaway normally, o The safety systems which will detect high temperature and pressure which are provided by licensor, shall be maintained and tested with fixed maintenance schedule Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 216 of 252

27 o The cooling water system should be provided emergency supply and auto cut in provision for standby cooling water pump should be provided. o Alarms and interlock can be provided on cooling water side to detect any failure as this is direct measurement To minimize damage once runaway occurs, o Safety valve on the reactor should be designed to take care runaway reaction scenario or as per licensor s recommendation. o The steel structure and safety interlock cabling within process area should be fireproofed Spiral wound gaskets are recommended for hydrocarbon lines. Screwed fittings should not be used except for stainless steel instrumentation. water network providing hydrants and monitors should be around reactor building/ process area. Also provision of hydrants on elevated structures and buildings to be ensured. proofing requirement of structure and equipment supports needs to be analysed and fireproofing to be provided accordingly. The process area should be classified area for selection of electrical equipments and instruments. The construction and fabrication should be as per standard codes and practices ( ASME /ANSI / IS etc) as the failure frequencies will be valid for such construction. If there is some deviation then the frequencies may increase Small Release of flammable solvents / chemicals (Most Credible scenarios) Small flammable solvent fires can be extinguished with extinguishing powder. Spiral wound gaskets are recommended for hydrocarbon lines. Screwed fittings should not be used except for stainless steel instrumentation. On long pipelines of solvents, thermal relief valves should be fitted, the relief valve must vent to a safe location, e.g. the storage tank as this is liquid relief. water network providing hydrants and monitors should be around reactor building/ process area. Also provision of hydrants on elevated structures and buildings to be ensured. proofing requirement of structure and equipment supports needs to be analysed and fireproofing to be provided accordingly Storage Area The gas detection will provide early information of the leak and it will provide some time to take corrective action (isolation, stopping of pump etc) to avoid the incident.consider placing gas detectors at strategic places in storage area. The regular inspection of the FW spray system and FW network along the storage area should be done with schedule. For sulfuric acid and HCL consider placing SO3 and HCL gas detectors covering possible potential leak sources. Ensure safety shower and Eye wash is placed in Sulfuric acid and HCL acid storage area General The plant handles flammable materials like Toluene, Styrene, methyl ethyl ketone. The handling of these materials requires control of spark, ignition source, and open flame. This is ensured by selecting equipments as per Hazardous area classification analysis. Ensure that all electrical installations and instruments are as per hazardous area classification(ref IS 5571 & 5572) Critical switches and alarms shall always be kept online especially in reactor area. Provide training for employees in the procedures established for their operating and maintenance functions. Also a refresher training program at specific intervals is to be prepared to keep operators updated. Shut off and isolation valves shall be easily approachable in emergencies A wind direction pointer shall also be installed at cavern site so that in an emergency the wind direction can be directly seen and downwind population cautioned Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 217 of 252

28 Smoking shall be prohibited in designated locations. Work likely to involve flame or sparks, such as, welding or burning, shall be performed only after the area is checked for no presence of flammable material and other safety arrangement as required. A proper training shall be given to the staff to handle any emergency situation and use of PPE during the work and emergency. Self-Contained Breathing apparatus (SCBA) shall be well maintained for emergency handling. Personal protective equipments to be provided to all the employees related to the type of work and hazard associated Mutual aid from neighboring industries to be made available whenever need arises. To check preparedness of workers for emergency control, mock drills on regular basis and disaster drills as per factory inspectorate guidelines to be conducted DISASTER MANAGEMENT PLAN The proponent M/s. Lanxess India Pvt. Ltd. is an established international group and as regards the proposed expansion of Antioxidants & Accelerators, already similar manufacturing sections are operating successfully and safely at the Jhagadia site. The proposed new production shall be carried out within RUC plant which is already well-equipped and well-prepared w.r.t safety. Moreover, HAZOP studies are carried out prior to any equipment or plant setup which identifies hazards associated and ensures inbuilt preventive and emergency control measures at the design stage itself. There shall be inbuilt safety in the plant through DCS and PLC operations and safety interlocks. Also the technology adopted is the most proven technology already implemented in similar units of the group. The plant design and layout aspects also comply with the applicable regulations and requirements of industrial ergonomics. Thus, the risks associated with the project are having low probability and severity. Lanxess Jhagadia site management has prepared and implemented an on-site emergency plan as per the global directives of the company. The plan is in compliance to the requirements of The Chemical Accidents Rules and Factories Act. The DMP includes emergency preparedness plan, emergency response team, emergency communication, emergency responsibilities, emergency facilities, and emergency actions. Another onsite emergency plan as per SCHEDULE 8-A of Gujarat Factory Rules 68-J/12/(1) is also prepared. The abstracts of onsite plan are annexed as Annexure -23 The plan also includes an OFF site emergency plan for the concerned government authority giving details about steps to be taken to inform related Government agencies, Medical Centers, Rescue teams and other local agencies, in an event where the emergency poses danger to surrounding area requiring evacuation. EIA Consultant has reviewed the latest plan (Doc. No. IMS-HSE-CL-3002, issue no. 11 dated ) for suitability and adequacy w.r.t proposed expansion. The review points are mentioned herewith Objectives of DMP As per latest plan - Any additions or modifications required for expansion - To localise the emergency and thereafter, totally Following objectives may be added :- eliminate it. To minimise the effects of the emergency on human, environment and property. To inform Employees, the general public and the authority / risk assessed, safe guard provided. Residual risk if any and the role to be Attainment of these objectives calls for prompt mobilisation of all available resources and activating counter-emergency procedures by all employees. played by them in event of emergency. To secure the safe rehabilitation of affected area and to restore normalcy. To ensure safety of the works before personnel re-enter and resume work. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 218 of 252

29 Components of DMP As per latest plan - Any additions or modifications required for expansion - Emergency Organization - structure, duties No additions or modifications are required and responsibilities of authorities response team, their coordinators Communication Key Personnel Emergency Action Facilities Hazard Assessment Identification of Emergencies and action Post emergency action Training Emergency Response As per latest plan - Any additions or modifications required for expansion - Written procedures for controlling different types of emergencies No additions or modifications are required Training of workforce for procedures and individual roles and responsibilities Availability of emergency response equipment with location and quantity and incharge Levels of Emergency & Response As per latest plan - Any additions or modifications required for expansion - LEVEL - 1 The level of emergency which is controllable No additions or modifications are required within the plant / area. Emergency may be due to: a) Small spot of fire in the plant. b) Toxic gas release for short duration. c) Collapse of small equipments. LEVEL 2 The emergency which is confinable within the Factory premises. Emergency may be due to: a) Big fire in factory premises b) Medium scale explosion c) Heavy leakage of toxic gas for short duration. LEVEL- 3 Likelihood of vapour cloud with formation of toxic / flammable gases drifting and affecting the general public (i.e. outside of plant premises). This type of emergency arises out of: a) Explosion in high pressure vessel containing toxic / flammable material. b) Heavy leakage of toxic material for a long duration from pipe line or storage tanks. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 219 of 252

30 Emergency Communication The unit shall have quick and effective communication system to make the emergency known through effective communication system a) inside the factory (b) to key personnel outside normal working hours (c) to the outside emergency services and authorities and (d) to neighboring factories and public in vicinity. The communication system beginning with raising the alarm, declaring the major emergency and procedure to make it known to others shall include the following : Declaring the major emergency Emergency Siren Code Information And Warning Safe Assembly Points Declaration Of Emergency Inside factory Emergency no. 110 is assigned. Walky-talkies are available with all departments Emergency Communication Center is built near Gate 1 and out of reach all the hazardous area which is commonly used in any emergency. Intercom nos. of all BUs as well as outside aid agencies and neighbouring industries and govt. offices are listed in the plan Following system of communication is formulated at site Assembly points are designated as : i) Admin building Ground floor, ii) Admin building I floor, iii) Main Canteen bridge Office. Location of immediate safe rooms in the respective plant area :- Every BU and services have maintained a safe room consisting of escape mask and communication system Siren codes are also defined as : Plain for three minute Gas Leakage Wailing for three minutes Natural Calamities & Wailing for three minutes Offsite Emergency All clear Testing Plain for one minute Plain & wailing for one minute on Every Monday at 1000 hrs. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 220 of 252

31 LANXESS JHAGADIA 6) Emergency communication and Action- On-Site Emergency Walky-talky Incident controller Emergency controller Production In-charge all Bus Utilities Electrical sub-station ETP 2 Incident controller 3 Emergency controller, tender, ambulance ECC Tel No. 110/ PA system/ fire alarm panel/site controller 1 Site controller 4 (Line of action proceeds from 1 to 7 Action 5 is all clear) 2 and 5 Telephone Plants and offices 4 Squad members, First aiders 3 6 HSE BU BU Germany LXS India Crisis Team Site Head Autho rity IRS 7 Emergency Management Team Roles and responsibilities of Site Controller, Incident Controller and other key personnel for emergency control are also defined in the plan. No additions or changes are required for RUC plant expansion. Controlling emergency The existing DMP includes the following : Evacuation & Transportation Safe Close-Down Use Of Mutual Aid Use Of External Authorities Medical Treatment Accounting for personnel Access to Records Rehabilitation Mitigation of Environmental Impact during emergency for -, Explosion Chemical Spillage No further additions or changes are required for the expansion. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 221 of 252