PROCEDURE NUMBER: PRC-SAF-16 (Preparation of Piping and Equipment for Repair) Page 1 of 10 Rev. 1.4 Date: 10/17/2016 Rev. 2.

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1 ZACHARY SITE PROCEDURE NUMBER: PRC-SAF-16 (Preparation of Piping and Equipment for Repair) Page 1 of 10 Rev. 1.4 Date: 10/17/2016 Rev. 2.0 Date: 11/7/18 PRC-SAF-16 Zachary Site SAFETY POLICIES and PROCEDURES Line-breaking Revision #3-06/03/2011 Version Reason For Change Date Changed/Reviewed By 1.0 Revision Number rest to 1.0 at transfer into Documentum Jan R. Hall, EHS&S Specialist, Zachary EHS 1.1 Annual Review conducted; changes made to align with BASF standards 10/25/2013 R. Hall, EHS&S Specialist, Zachary EHS 1.2 Changes: see MOC /15/2014 R. Hall, EHS&S Specialist, Zachary EHS 1.3 Annual Review 09/28/2014 R. Hall, EHS&S Specialist, Zachary EHS 1.4 Annual Review 10/17/2016 T. Schexnaydre EHS&S Specialist 2.0 Annual Review: Minor Changes/Updates 11/7/2018 R. D Amico EHS&S Specialist

2 Page 2 of 10 CONTENTS 1.0 PURPOSE 2.0 SCOPE 3.0 DEFINITIONS 4.0 SAFETY 5.0 SPECIAL EQUIPMENT 6.0 RESPONSIBILITIES 7.0 PROCEDURE DETAILS 8.0 ANNUAL MANAGEMENT SYSTEM REVIEW 9.0 TRAINING 10.0 RECORD KEEPING 11.0 TABLES 12.0 ATTACHMENTS 13.0 REFERENCES

3 Page 3 of PURPOSE 1.1 This procedure provides information and standard safe work practices for the safe opening of piping and equipment that contains or previously contained a Hazardous Energy Source or may have been under pressure. 2.0 SCOPE 2.1 Unless specifically stated otherwise, this procedure applies to Line Breaking activities at the Zachary site. 3.0 DEFINITIONS Eyes Review - The use of 2 or more individuals to review a job or task in the field to ensure all hazards are identified and eliminated/controlled through the use of safe work practices or PPE, communication/awareness, etc. At a minimum this must include a Permit Issuer and a member of the work crew. Each Permit issued with a Lock Out / Tag Out Line breaking is mandatory to conduct a 4 Eyes Review. 3.2 Flammable - Material that falls into a specific category listed below: Aerosol, flammable - An aerosol that can yield a flame projection exceeding 18 inches at full valve opening, or a flashback (a flame extending back to the valve) at any degree of valve opening Contracted Employee- An individual or group of individuals for whom BASF provides direct supervision in their day to day activities and direction as to how an activity is to be performed Contractor- An individual engaged by or through a third party to perform services principally for the third party Gas, flammable - (A) A gas that, at ambient temperature and pressure, forms a flammable mixture with air at a concentration of thirteen (13) percent by volume or less; or (B) A gas that, at ambient temperature and pressure, forms a range of flammable mixtures with air more than twelve (12) percent by volume, regardless of the lower limit Liquid, flammable - Any liquid having a flashpoint below 100 deg. F (37.8 deg. C), except any mixture having components with flashpoints of 100 deg. F (37.8 deg. C) or higher, the total of which make up 99 percent or more of the total volume of the mixture. 3.3 Hazardous Energy Source - Any electrical, mechanical, hydraulic, kinetic, pneumatic, chemical, thermal, or other energy (e.g., radiation), including stored or residual energy, that if unexpectedly or inadvertently released, could cause injury to personnel, or if introduced into a process could be hazardous. 3.4 Line Breaking - The actual opening/separation/removal of equipment containing or having previously contained a Hazardous Material/Energy source. Equipment includes, but is not

4 Page 4 of 10 limited to all types of flanges, pumps, manways/hatches, screwed pipe, fittings, exchanger tube plugs, valves, tubing, hoses, Other types of connections/openings in process or utility service. 3.5 Permit Acceptor- Person responsible for obtaining approval to do work. 3.6 Permit Issuer- personnel that have been trained, qualified, and authorized to issue permits on behalf of the operating/owning department. 3.7 Lock Out / Tag Out Sheet- A log sheet that must be completed before the start of a job that contains information about equipment being locked out, the type of isolation device being used and the location of each isolation device. All individuals placing locks must list each lock placed/removed on the Lock Out / Tag Out Sheet. 3.8 Owning/operating department- The unit or department that operates or is responsible for the daily operation of the process, area or facility where work is being conducted. 4.0 SAFETY 4.1 This procedure is a description of a portion of the overall safety process for the plant. 5.0 SPECIAL EQUIPMENT 5.1 Review Special Equipment Sections for PRC-SAF-02 (Lock Tag Try) and PRC-SAF-11 (Confined Space Entry) procedures. 6.0 RESPONSIBILITIES 6.1 Management is Responsible for: Providing support and resources to implement this program. 6.2 Supervision is Responsible for: Job specific training within their areas Ensuring that procedures defined in Section 7.6 of this policy are properly followed. 6.3 Employee is Responsible for: Understanding and complying with this procedure Operations personnel are responsible for properly clearing, securing and locking out (LOTO) the affected process equipment before issuing a work permit Maintenance or Construction personnel performing work on the project are responsible for making certain that the affected process piping/equipment is properly secured and tagged/locked. 6.4 Contractor is Responsible for:

5 Page 5 of Understanding and complying with this procedure. 6.5 EHS&S Specialist is Responsible for: Conducting the annual management system review Implementation and execution of this program. He shall provide direction and leadership with special emphasis placed on general safety procedures, training, recognizing unsafe conditions of this policy. 7.0 PROCEDURE DETAILS 7.1 All Line Breaking work, except for routine activities (ex. filter cleaning, hose disconnection, process sampling, etc.) performed by trained Owning Department personnel, must be authorized through the issuance of a properly prepared Safe Work Permit as per PRC-SAF- 06 (Work Permits) Routine activities performed by trained Owning Department personnel do not require a Safe Work Permit provided that the work is performed according to a current procedure (ex. JSA, etc.) which specifies mechanisms that provide protection equal to safeguards that would have been required by a permit (Same Level of PPE). 7.2 A Lock Out / Tag Out Sheet must be completed before the start of a job and must contain information about equipment being locked out, the type of isolation device(s) being used and the location of each isolation device. All individuals placing locks must list each lock placed/removed on the Lock Out / Tag Out Sheet. The Lock Out / Tag Out shall be properly prepared as per PRC-SAF-02 (LOTO). 7.3 Every effort should be made to thoroughly isolate, depressurize, empty, purge, drain, clean, and lock/tag affected piping and equipment to ensure it is free of Hazardous Energy Sources, as specified by PRC-SAF-02 (LOTO). 7.4 All applicable Line Breaking safeguards and PPE requirements must remain in effect until it is positively verified that Hazardous Energy Sources or pressure are no longer present or are controlled to the extent that they no longer pose a hazard to personnel. Verification must be made through one or more of the following methods: No liquid or vapors present Creation of a minimum ½ air gap between flanges; Testing (ex. neutral ph of flush water); and/or Must be documented on both copies of the permit Can only be downgraded by a Qualified Operator in the area 7.5 Do not assume a valve or check valve doesn't leak. Proper and thorough inspection must be made. Assume that they do leak until proven otherwise. Must prepare on both sides of check valve. Previous contaminants can leak back into prepared equipment. 7.6 The area or department supervisor, typically the production supervisor, shall ensure that the following is performed:

6 Page 6 of Determine the nature of repairs to be done. This will dictate the types of preparation necessary Initiate the Safe Work Permit Plan and prepare the job Specify additional protective equipment and materials to wash or neutralize any accidental spills Drain the required piping or evacuate the line to empty the system of material. a. If gas or steam is required to void the piping, blow back into a tank or vessel if possible. Always check the material used is compatible with the contents of the system. b. If a line must be blown out to atmosphere, take proper steps to prevent over pressuring causing splashing. Use a grounding device if you blow out flammable or combustible material into drums Lock off valves to isolate the section requiring repairs Bleed off excess pressure, Place "Danger - Do Not Operate" tag on all valves that are isolating the voiding section. These tags must not be removed until the repairs are completed, and all work permits have been returned and equipment cleared If hot work is to be performed in place on the system, there must be two means of positive isolation points (Block and Blind/ Block and Stoppel/ Double block and Bleed). The piping should be steamed if combustible or flammable materials were present in the system; however, systems where materials such as sodium, potassium, aluminum chloride, or phosphorous trichloride may be present should be given special consideration prior to using steam, water, or air Ensure that bleeder valves are left open to aid in discovering leaks in the valve off system. Locked and tagged in the Open position Conduct a 4 Eyes Review with a member of the work crew before issuance of the Safe Work Permit. At a minimum this review shall confirm the following, as applicable to the work: a. All Line Break locations have been identified and all Line Break precautions taken, such as the placement of barricades and warning signs around the area if necessary. b. Bleeders nearest each line break are open and unplugged. c. There is no pressure or purges on the equipment on which the work crew is to perform work. d. The immediate piping/equipment is cool. e. Testing with a properly calibrated combustible gas detector on lines or equipment which may have contained Flammable gases or liquids.

7 Page 7 of 10 f. Personnel performing the work have been informed of the hazards, special safety precautions (ex. PPE), escape routes, and location of the nearest safety shower/eye wash. g. Communication to or coordination with all groups potentially affected by the Line Breaking activity (ex. personnel working underneath or adjacent to the Line Break). h. The Job scope is mutually agreed upon and documented as such on the Safe Work Permit Maintenance or Construction personnel performing work on a tagged-out system should not by-pass the lock out procedure where it applies. They should inspect the system for proper tag out Visually check for any signs of leaking into the tagged-out system. If leaks are found, the system should be blinded off and properly prepared Barricades and/or barricade tape should be used to restrict access when Line Breaks are in elevated locations or over grated platforms. Consider use of splash or drain pans to protect personnel and equipment below Defensive positioning must be used to avoid a spray or release when attempting a Line Break (ex. break of flanges on the opposite side of piping from the employee) When breaking into any system, except for nitrogen, air or potable water, the proper PPE must be worn as indicated by PRC-SAF-10/CRC. This includes all process lines even process water lines. The minimum PPE in any Line Breaking situation must be: a. Gloves appropriate for the hazard; b. Full-face protection (face shield or full-face respirator) if there is the potential for splashing or spraying in the face When entering a thermowell, the system must be fully depressurized and appropriate PPE must be worn. Assume that there is no thermowell in place when opening the system Termination of line breaking activities All applicable pre-work and PPE requirements shall remain in effect until it is positively verified that Hazardous Energy Sources are no longer present or are controlled to the extent that they no longer pose a hazard to personnel. Verification shall be made through one or more of the following methods and pre-work, including PPE must remain in effect until verification is documented on the permit, as applicable, by Operating/Owning Department personnel: Read the work permit to determine hazardous materials in the system and safety equipment required Do not flush lines or do any hot work without the proper notification and work

8 Page 8 of 10 permit such as for hot work or vehicle entry Do not open valves or remove tags from valves without proper approval from Owning Department personnel If a system or equipment, after it has undergone a Line Break, is closed up but not put back into service and is subsequently reopened, then the subsequent reopening must be considered as a new Line Break and must adhere to all respective safeguards and PPE Check that all equipment and tools are secured, and the area is cleaned before turning over the work permit Stand by as the system is returned to service to aid in the event there are problems such as leaks. 8.0 Annual Management System Review A review of the effectiveness of the Line Breaking program must be conducted and documented on an annual basis. The results of the review, as well as any necessary corrective actions, will be communicated to site leadership and affected personnel. The review shall cover the following minimum elements: A. A comparison of the program with actual practices and corporate requirements. B. A review of incident reports involving Line Breaking activities that have occurred since the last management system annual review. C. Interviews with Permit Issuers, personnel performing Line Breaks, and other Affected Employees, including contractor employees where applicable regarding their roles and responsibilities. D. Inspection of at least one Line Breaking job, while in progress, to ensure that all applicable precautions indicated on the Safe Work Permit have been implemented in the field. E. Review of applicable maintenance and calibration records for monitoring equipment. 9.0 TRAINING 9.1 Training will be provided to those personnel whose roles and responsibilities are impacted by this procedure Personnel will be trained to recognize the applicability of Line Breaking situations and the necessary means to safeguard against the hazards posed during these activities Training will be conducted initially and at least every 3 years RECORDKEEPING 10.1Training records shall be kept in the EHS&S Office.

9 Page 9 of Annual Management Review records shall be kept in the EHS&S Office TABLES 11.1Reserved for future revision 12.0 ATTACHMENTS 12.1Reserved for future revision 13.0 REFERENCES 13.1 BASF Zachary Safety Manual 13.2 BASF Corporate Safety & Health Manual 13.3Document Historical Data Origination Date 05/05/1997; Ferro Document Revision /05/1997; Ferro Document Revision /06/2003; Ferro Document Revision /16/2011; Novolyte Document; Revision made by Robin Hall 3.0 Revision Notes: a. Footer and Header changes to include Company logo b. Contents categorized into the following: 1. Purpose 2. Scope Added contents 3. Definitions 4. Safety 5. Special Equipment 6. Responsibility Added contents 7. Procedure Details 8. Training 9. Record Keeping 10. Tables 11. Attachments 12. References c. References to previous ownerships (BASF, Grant, etc.) removed and

10 Page 10 of 10 replaced with the following Generic phrase: the Company s Zachary Site, or a similar reference phrase d. Responsibilities have been categorized into the following (additional responsibility categories will be added as needed): 1. Management responsibilities 2. Supervision responsibilities 3. Employee responsibilities 4. Contractor responsibilities 5. EHS&S Manager responsibilities January 2013 Document placed in Documentum; Version reset to Version 1.1 (10/25/2013) Changes made to align procedure with BASF Standards Category added: ANNUAL MANAGEMENT SYSTEM REVIEW Version 1.2 (06/15/2014) see MOC NOTE: Information for future revisions will be maintained in the document s Version Table located on the Title page.