Line Breaking/Line Cutting. Supersedes: 10/2016 (Rev.09) Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager

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1 Procedure No.: PA Page: 1 of 20 Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager Document Revision Change Table Revision Number Revision Description Revised By Revision Date 01 Incorporated BASF Corp. requirements TF 03/ Changed Header and Footer VB 06/08 03 Change in Section AFG 06/09 Add 4.1.1K, requiring operations to be present at all initial line TAD 01/11 04 breaks. Add for clarification and matching of corporate Line Break procedure 05 Modified step 4.6 to add annual PPE grid review TAD 04/ Modified step 4.4.1, E, to add verify bleeds/vents are free from TAD 08/2012 obstruction. Added the requirements for Safety and Health Advisory 218 TF 07/ (Update of Corporate Line Breaking Procedure) and added Attachment 1 (Work Instructions for Plug/Blind Flange Removal from Bleed Valve) Changed to Shift Supervisor designation; added that only hand DLS 12/15 08 tools shall be used on initial line break in Section ; added reference to EHS Requirement document Occupational Safety and Industrial Hygiene N-R-OSA-001-EN-M A Referenced Documentum and TSA procedures. DLS 10/ Referenced Review using EHS website resources Added Line cutting procedures to comply with Corporate DLS 9/17 requirements.

2 Procedure No.: PA Page: 2 of PURPOSE To establish standard work practices and procedures for initial safe opening of, and ensuing work on flanges, pipes, valves and equipment which contained or may have contained hazardous materials, thermal hazards (hot or cold) or may have been under pressure. 2. DEFINITIONS 2.1. 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 Employee An individual engaged by or through a third party to perform services principally for the third party Cut Tape Cut tape is an Orange tape with black directional arrows that are applied on both sides of a proposed cut line. There are also spaces for assigning numbers for tracking purposes along with an area for signatures and dates for approval Cut Tape Unique Identifier A number that allows for a unique and specific identification. (work notification number for maintenance related work and project number with tie-in number for Capital Projects that signify the parent work that the work originates from followed by a sequence number or letter. Examples could include: Not# , , etc or UNIC.XXXXX & TP , TP ) Hazardous Material/Energy Source Any electrical, mechanical, hydraulic, 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 pose a risk of: - Health, physical, or environmental hazard, - Cryogenic, - High Temperature (greater than 120 degrees Fahrenheit), or - Pressure 2.6. Line Breaking The actual opening/separation/removal of equipment containing or having previously contained a Hazardous Material/Energy source Equipment includes but is not limited to all types of flanges, manways/hatches, screwed pipe, fittings,

3 Procedure No.: PA Page: 3 of 20 exchanger tube plugs, valves, tubing, hoses, sanitary connections or other types of connections/openings in process or utility service Operating/Owning Department The BASF unit or department that operates or is responsible for the daily operation of the process, area or facility where work is being conducted Permit Issuer Personnel that have been trained, qualified, and authorized to issue permits on behalf of the Operating/Owning Department. 2 DEFINITIONS CONT D 2.9. Permit Acceptor Person responsible for obtaining approval to do work Servicing Department/Group Any personnel involved in activities that are outside the scope of routine production or utility operations. 2.9 Written Operating Procedure A document that describes in writing the chronological steps necessary to complete a job including safety and quality considerations for each step Eyes Principle The use of 2 or more individuals (equipment operator/owner and individual(s) performing the work) to assess tasks to ensure that all hazards are identified and eliminated or controlled through safe work practices, use of PPE, communication and awareness etc. 3. SCOPE This procedure applies to initial opening of lines or equipment which contained or may have contained hazardous material, or may have been under pressure. Routine production activities (e.g. filter cleaning, hose connection or disconnection, and process sampling) may be performed by qualified operations personnel without completion of a safe work permit if current equipment-specific written operating procedures are utilized which cover the identification and control of hazards and proper PPE is utilized as noted in the PPE Grids. NOTE: The removal of plugs and blind flanges from bleed valves are considered line breaks. See Attachment 1 for Work Instructions for Plug/Blind Flange Removal.

4 Procedure No.: PA Page: 4 of PROCEDURE 4.1. Pre-Line Breaking Activities Owning/Operating Department Prior to the performance of any work falling within the scope of this procedure, the Owning/Operating Department shall: A. Determine if this line break is detailed in the Documentum or a Safe Operating Procedure (SOP) that details clearing, isolation, and MIP requirements for this break. If it is not in Documentum, a Task 4. PROCEDURE cont d 4.1. Pre-Line Breaking Activities cont d Owing/Operating Department cont d Safety Analysis must be written to document the hazards and mitigation of this activity. B. Initiate a safe work permit in accordance with Safety and Health Procedure PA Safe Work Permits. C. Identify the last contents within the equipment and identify the hazards in terms of: Flammability Toxicity Corrosivity Temperature Pressure Any other known or anticipated hazard These hazards will be noted on the safe work permit in Section 5. D. Trace lines and/or equipment involved in the line break. Key items that should be noted include: Location of line break Isolation points Upstream/downstream branches Vent & drain points Liquid traps Hose and blow-down connections Check valves

5 Procedure No.: PA Page: 5 of 20 Other items that may influence the line preparation and break E. Ensure that the lines or equipment have been emptied, purged, flushed, drained, vented, isolated and locked/tagged as applicable to ensure the system is free from recognized hazards. Note: Opening of a bleed valve does not constitute an initial break due to the possibility of the bleed valve being plugged with material. F. Verify that de-pressurization of lines or equipment and absence of material has been accomplished by opening vents and drains or by other means deemed appropriate. The vents/drains used for this 4. PROCEDURE cont d 4.1. Pre-Line Breaking Activities cont d Owing/Operating Department cont d verification need to be checked to be free of obstruction. The Owning/Operating Dept. must hang a completed red tag at the point where the de-energization was verified, i.e. bleed, vent, start/stop switch, etc. G. On lines or equipment which may have contained flammable and/or toxic liquids or gases, test with a properly calibrated combustible gas indicator initially and intermittently during work. Initial monitoring results will be noted on the safe work permit in Section 5. Any LEL reading above 0% will need the approval of the Shift Supervisor. Prior to commencing work, It is the Shift Supervisors responsibility to evaluate the risks associated with the task and implement safety measures to mitigate that risk, safety measures may include additional isolation, purging, steaming, ventilation, PPE, etc. The permit issuer will document in Section 5 of the safe work permit the frequency that additional monitoring will occur i.e. hourly, every two hours, etc Hot work will be performed in accordance with Safety and Health Procedure PA H. Ensure that where work is performed on elevated piping or equipment, the area below the work will be barricaded and splash pans provided as needed. Signs will be posted warning of overhead work.

6 Procedure No.: PA Page: 6 of 20 I. Ensure that personnel performing the work will be fully informed of any potential hazards, special safety precautions, location of nearest safety shower/eye wash station and have the appropriate personal protective equipment. This will be accomplished using the 4-Eye Principle. J. Ensure that the safe work permit has been completed and signed and is maintained at the work site. 4. PROCEDURE cont d 4.1. Pre-Line Breaking Activities cont d K. Ensure that any other permits such as confined space, lockout/tagout or hotwork, are completed per the corresponding safety procedure. L. If any Line Cutting or Drilling of lines or piping required, please refer to 4.4 section of this procedure (Line Cutting). M. During all initial line breaks (first break), an operations technician shall be present Servicing Department/Group Prior to commencing the work, Service Department/Group personnel involved in the line breaking activities shall ensure that: A. The lines or equipment have been properly prepared. An inspection of the lines/equipment shall be made with the Owning/Operating Department (4-Eye Principle) B. All applicable safe work procedures are in use and applicable safe work permits are properly completed. C. Appropriate personal protective equipment has been defined and is in use Personal Protective Equipment Assessment

7 Procedure No.: PA Page: 7 of 20 The appropriate type of personal protective equipment (PPE) used during a given line breaking situation will vary with the hazards associated with the material, equipment, location, and ability to verify that the equipment/line is clear. The specified PPE must be consistent with the Safety and Health Procedure PA Personal Protective Equipment and associated PPE Grids Minimum PPE Protection The minimum PPE in any line breaking situation shall be: Hard hat Eye protection (goggles at a minimum) Face shield and Goggles (if required by the PPE grids) Appropriate work gloves 4. PROCEDURE cont d 4.3 Personal Protective Equipment cont d Additional PPE A. In situations where there is a potential for a hazardous liquid drip, leak or spray upon opening, chemical resistant suits, gloves, and boots will be used per the Site PPE Procedure and specific chemical PPE Grids. Gloves will be sealed to keep materials from contacting the skin. B. Where a potential for vapor or gas exposure exists, respiratory protection will be used. Safety and Health Procedure PA Respiratory Protection shall be followed. C. In situations where an LEL reading greater than zero was obtained Flash Suits or additional PPE may be required. The Shift Supervisor will be responsible for determining the proper PPE to be used. The following guidelines should be considered: % LEL reading inside the pipe. % LEL reading outside the pipe in the general area in which the work is performed. Is there flow or no flow of flammable material? Is the work area confined where vapors could accumulate? Does the wind speed and direction help or hinder the situation?

8 Procedure No.: PA Page: 8 of 20 Does the size of the pipe or equipment result in a large volume of vapor? What is the potential for a flash fire? What is the potential for static discharge? Can non-spark producing tools be used? Is the isolation point a positive seal or could it fail (sewer plug, etc.)?

9 Procedure No.: PA Page: 9 of PROCEDURE cont d 4.3. Initial Line Break Personnel breaking lines must place themselves in a defensive position to avoid a spray of liquid or release when attempting the initial opening. Only hand tools shall be used on the initial line break (i.e. NOT pneumatic, hydraulic, or other power tools). Flanges will be cracked open on the opposite side of the line from the employee. If there is a possibility of flammables or LEL then non-sparking tools will be used When line breaking operations require the use of airline respirators or SCBA, special consideration must be addressed as to the potential hazards involved, for example: - Rescue of initial work crew personnel - Placing the equipment in a safe condition, if for any reason the initial work crew cannot The Shift Supervisor for the above will decide on the appropriate number of stand-by personnel (if any) with respect to qualifications Vs expected task and the level of PPE during the initial break and or as the personnel performing the line break All applicable pre-work and PPE requirements shall remain in effect until it is positively verified that Hazardous Material/Energy Sources are no longer present or are controlled to the extent that they no longer pose a hazard to personnel. Verification shall be make through one or more of the following methods and documented on the permit by Operating/Owning Department personnel. Testing (ie., neutral ph of flush water) The creation of a minimum ½ air gap between flanges Establishing a purge out an open drain valve adjacent to the planned line break. Atmospheric monitoring for flammables, and/or toxic gas or vapor Monitoring for respirable atmosphere when working on lines containing asphyxiants Other methods that prove that no hazard(s) exist.

10 Procedure No.: PA Page: 10 of PROCEDURE cont d 4.4. Line Cutting Procedure Purpose of this procedure is to ensure the protection of personnel, the safe operation of plant processes, and environment by eliminating line cutting errors that could create a release of energy and/or hazardous materials This Procedure applies to cuts made on service lines and utility lines within the boundary of the plant. This procedure does not apply to any piping that has been disconnected and moved to an external controlled environment such as a Fab Area or any new plant construction where there are no live lines in the area For demolition of piping systems, refer to Port Arthur Site Equipment Demolition/Deconstruction Procedure All locations where piping will be cut, must be clearly identified, labeled and authorized before cutting into any line or piping. A. Installation of Cut Tape and Tie in Tags. A.1. A.2. A.3. A.4. Activities when line cutting is required, cut tape shall be applied on both sides of the proposed area. This will identify the exact location of where the line is to be cut. Ensure that the cut tape cannot be more than 16 inches the proposed cut point. All cut tape that is to be applied, must contain a tie-point tag number or a Cut Point Unique Identifier. This number or identifier ensures that each cut point can be uniquely identified, planned and tracked on the permit and JSA. The cut tape is applied by the Contractor Company, Planning Department or Third-Party Quality Assurance personnel. The cut tape can be applied any time prior to permit issuance. A.5. When applying the cut line tape to the pipe, please proceed in the following manner:

11 Title: Individual Unit Procedure Function: Health and Safety No.: PA Page: 11 of 20 Port Arthur, TX. Reviewed: 5/2017 Supersedes: 10/2016 Identify area of the proposed cut on the pipe or line. Ensure to utilize visual confirmation and associated documents (P&ID s). Apply that cut line tape on both sides of the proposed cut area. Ensure that the directional arrows of the cut tape are pointing inward towards the proposed cut line. Verify that the cut line tape cannot be more than 16" from the proposed cut line on both sides Insert your Tie-point Number or Cut Point Unique Identifier on the applied cut tape A.6. Effective: 5/2017 All locations where piping will be cut must be clearly identified by a marking tool in the field. The location where a line is to be cut for the installation of a Tie in Point will be identified by a tag with this information Tie-In/Cut Point# Job# P&ID # Date Tagged By (BASF Operations Rep.) BASF Projects Rep. if applicable Examples:

12 Procedure No.: PA Page: 12 of 20 A.7. The cut point will be identified and marked on the pipe at the exact location of where that line is to be cut. B. Permitting. B.1. Prior to the permit issuance, the following personnel are required to perform the 4-eyes Principal Walkthrough. The Operations Representative (Permit Issuer) The contracted company representative cutting the line. (Permit Acceptor) The contracted company coordinating the line tiein work if applicable. (Sub-Contractor) B.2. During the process of performing the 4 eye Principal Walkthrough the following items need to be reviewed and verified. Permit Issuer and Acceptor will verify that the line to be cut has been properly isolated per PA Control of Hazardous Energy Policy (MIP). All Tie Point/Cut Point Unique Identifier # s are listed on the Safe Work Permit and JSA. This also shall list the order in which to make the cuts, if there is more than one. Cut tape has been installed on the pipe and cut point has been identified on the line or piping. Permit Issuer and Acceptor will verify that the Tie- Point Tag # s and or Cut Point Unique Identifiers are on the cut tape and that the cut tape is attached on the correct piping. The line to be cut must be verified for 0 LEL and Zero energy state by the Permit Issuer and Permit

13 Procedure No.: PA Page: 13 of 20 Acceptor as part of the 4-eye permit verification step. If the line that is to be cut cannot be verified to have 0 LEL and zero energy within 10 of the cut, a hole to the minimum size of 1/8-inch must be drilled on the pipe. Refer to Section 4.7 of this procedure. Once identification is verified with a monitor reading of Zero LEL and Zero Energy, the cut tape will be signed off and dated by all parties responsible for ensuring positive and accurate line identification of the cut line. If the time between the initial monitoring and the cutting activities exceed 30 minutes, then the area requires monitoring again before starting any cutting activities. If cuts that have had the cut tape signed and date cannot be completed during the permitted time frame, then the cut tape must be removed from the pipe. After removal of the signed and date cut tape, please install new cut tape at the same location for future review and authorization. C. Drilling holes for Verification of No Pressure and 0 LEL/Zero Energy. C.1. If during planning or permitting processes and there isn t a sufficient bleed within 10 of the cutting activities, the use of a 1/8-inch hole(s) can be utilized to verify 0 LEL and zero energy prior to making any cuts. Note: The hole must be drilled on the top or as close to the top of the demo side of the pipe that is to be cut to allow operations personnel a means to verify no Positive Pressure is present and test internal atmosphere of line for LEL prior to cutting. Note: The hole should be on the Cut Line if possible.

14 Procedure No.: PA Page: 14 of 20 C.2. C.3. C.4. C.5. C.6. C.7. Person or persons responsible for drilling hole must confirm that the drill bit being used is appropriate for the material being drilled. PPE assigned for the drilling of the line must be to the level of potential exposure for the previous contents of the line being cut or to the equivalent of Initial Line Break as per the Site PPE grids. Personnel cannot downgrade PPE until an initial line break has occurred and a verification of hazards has been performed confirming no potential exposure to personnel. A separate permit must be issued to perform any hole drilling activities. All drilled holes must be reamed out to ensure that clear paths to internal surfaces have been achieved. An appropriately sized plug of appropriate construction material should be available to plug the drilled hole if there is pressure on the system. This should be part of the JSA. If a hole(s) has been drilled and the Operations Technician cannot confirm 0 LEL or zero energy. All activities shall be stopped and additional line preparation activities shall be performed until the Owning/Operating Department and Service Personnel agree the line/equipment status is acceptable. If a single line break can be made to verify 0 LEL and zero energy for multiple line cuts, then a single permit may be used for the proposed cuts. Line Breaking may include valve, PSV removal, flange separation, etc. If a single permit is issued for multiple cuts, then the following must be included on the safe work permit and JSA. o o o Each cut listed must have a cut point unique identifier. Sequence or order of proposed cuts Location used to verify 0 LEL and zero energy must be specified (i.e. PSV, Valve, flange or hole drilled) D. Line Cutting.

15 Procedure No.: PA Page: 15 of 20 D.1. D.2. D.3. All adjacent lines to the line that is to be cut will marked to identify that the adjacent lines are in service with streamers (Red Barricade tape with black diagonals). All live lines within a 3' radius must be identified. Any line adjacent to the line that will be cut must have a barrier put in place if there is any potential for the cutting apparatus used to be able to impact the adjacent line. This barrier must be substantial enough to not allow cut or penetration into the adjacent line whether the line is live or not. (Examples of a barriers are but not limited to are plywood, 2x4, pipe coupon etc). When performing the actual tasks of cutting a line or piping, all activities shall be in compliance with the following Port Arthur Procedures: PA Control of Hazardous Energy, PA Hot Work Permits, PA Safe Work Permits D.4. D.5. D.6. D.7. Person cutting the line must ensure the identifier on the line and permit are the same, and that the cut tape has been signed and dated (that day) by the appropriate persons. Drilling the hole to verify LEL and 0 Energy does not constitute a First Line Break. BASF personnel must attend the line cut as it will be the first break. Before cutting into any lines or piping, ensure to setup measures of containment in case there is residual or leftover materials within the line or piping. (buckets, plastic, etc). It is a Requirement for all personnel performing cutting activities to visually verify each cut point before initiating any cuts. This is to ensure that the cut

16 Procedure No.: PA Page: 16 of 20 location is the correct location to be cut and that it has the correct Tie Point/Unique Identifier number and that it is cut in the correct order of sequence as described on the Safe Work Permit and JSA. D.8. D.9. If the line cut is the initial line break, PPE must match requirements for process line contents under pressure. If during planning or permitting processes and there isn t a sufficient bleed at the point of cutting activities, the use of a 1/8-inch hole(s) can be utilized to verify 0 LEL and zero energy prior to making any cuts Post-Line Breaking Activities If a system or piece of equipment, after it has undergone a Line Break, is closed but not put back in service and is subsequently reopened, the subsequent reopening is considered a new Line Break and must adhere to all the requirements of the initial Line Break The permit will be cleared by the Servicing Department/Group personnel and the Owning/ Operating Department All permits must be returned to the Owning/Operating Department upon completion of the work and job clean-up Review of Program The Port Arthur Site shall review the effectiveness of Line Breaking practices at least annually using the Management System Review Checklist in the OSIH section of the Environmental Safety and Health website to ensure that the management system is properly implemented and the elements adequately control Line Breaking activities. At a minimum, the following management system elements shall be included in the review: A comparison of the site procedure and site permit to the corporate procedure and corporate permit requirements. A review of incident reports involving Line Breaking activities that have occurred since the last management system annual review. Inspection of a least one Line Breaking job in progress to ensure all applicable precautions were indicated on the permit and implemented in the field. Interviews with Permit Issuers, persons performing Line Breaks and other affected employees, including contractor employees where applicable.

17 Procedure No.: PA Page: 17 of 20 A review of applicable equipment and instrument maintenance and calibration records. A review of all site PPE grids Training 4. PROCEDURE cont d BASF and Contracted Employees Involved in Line Breaking Activities Permit Issuers and personnel performing Line Breaks shall receive training on how to recognize the applicability of Line Breaking situations, the requirements for issuing a permit, and the necessary means to safeguard against the hazards posed during these activities Training cont d Training shall be delivered in accordance with the EHS curriculum assignment process and job specific training. Re-training of an employee is required whenever: Deviations or inadequacies in an employee s performance of an applicable procedure indicate a lack of knowledge is a cause. An applicable procedure has been changed. 5. RESPONSIBILITIES Contractor Employees will receive Line Breaking training during their ISTC Port Arthur site specific training conducted prior to working at the Port Arthur Site and additional training by their employer at the site Port Arthur Site Leadership Team Has primary responsibility for implementation of this procedure Environmental, Health, and Safety Manager Has primary responsibility for the initiation, re-issuance, administration, and/or interpretation of this procedure Port Arthur Site Employees and Contractors Have primary responsibility for adherence to procedure including identifying deficiencies in the procedure, and identifying, reporting and correcting activities not in compliance with the procedure. 6. RELATED DOCUMENTS

18 Procedure No.: PA Page: 18 of 20 BC Line breaking Line Cutting Corporate Procedure PA Control of Hazardous Energy PA Hot Work PA Safe Work Permits PA Personal Protective Equipment PA Respiratory Protection PA Piping Tie-Ins Requirement Occupational Safety and Industrial Hygiene N-R-OSA-001-EN-M Attachment 1 Work Instructions for Plug/Blind Flange Removal from a Bleed Valve Attachment 1 Work Instructions 1. Plug/Blind Flange Removal from a Bleed Valve Scope: These Work Instructions cover the removal of a plug or blind flange from a bleed valve and only applies to the owning/operating department personnel. The control of the hazardous energy must stay under the exclusive control and within 10 of the individual performing the procedure/task. Each plug/blind flange that is opened is considered a new line break until the energy source to it has been verified to a Zero Energy state. Assessment: This procedure takes into account and addresses the control of all hazardous energy sources, proper personnel protection, and environmental concerns. This procedure along with process and safety training allow the employee to meet all necessary precautions and does not require them to perform tagout of isolating devices due to all isolation devices being within their exclusive control. This will achieve effective protective measure complying with the Safety Procedures PA A - Control of Hazardous Energy Sources and PA Line Break. Process/Utility Pipe The current version Plug can or be Blind viewed Flange in the Electronic Document Management System

19 Procedure No.: PA Page: 19 of Prior to pulling plug/blind flange ensure that any other affected personnel has been notified. Safety: Prior notification allows others to be aware of task and location in cases of an accident and limit work in the area that might be affected. 3. Ensure bleed valve is closed from process/utility by blocking in. Safety: Energy must be isolated prior to any break, to remove or minimize the safety exposure potential. Pulling plug/blind flange without the valve being seated will increase risk of exposure. 4. Refer to PPE Grid to identify the needed PPE for pulling a plug/blind flange from a bleed on a process or utility line. Safety: Make sure temperature, physical state, and pressure ratings (as applicable) are all as expected for this task. 5. Area around and below the location where the line break will be made should be cleared of personnel. Safety: The use of a barricade will keep people a safe distance away. 6. Safety shower location verification for each break must be made to ensure a quick response in case it is needed. 7. Put on proper PPE to pull plug/blind flange that is in/on bleed valve and position yourself in a defensive position to minimize exposure to process chemical in the case the valve does not hold or pressure has built up between the valve and the plug/blind flange. Also make sure your escape route is open and uncluttered. Safety: Proper PPE and positioning are essential to making sure you minimize your risk of exposure in case of an unexpected release of energy/chemical. 8. Begin to remove plug/blind flange in a controlled manner to minimize your exposure. Safety: Remove plugs slowly to be able to allow any residual pressure to bleed off as you near the end of the threads. You may also be able to determine if the valve has failed to seat off properly. If you are breaking a blind flange you should first loosen the bolts away from you slowly. This will help divert the residual energy away from you if any is present or if

20 Procedure No.: PA Page: 20 of 20 the valve has failed to seat. Loosening the bolts slowly will allow you to tighten them back up if it appears it is not safe to continue removing the blind flange. 9. Close bleed and replace plug/blind flange before line/equipment is put back in service.