RISK ASSESSMENT FOR SUN PHARMACEUTICAL INDUSTRIES LIMITED BULK DRUG AND INTERMEDIATES MANUFACTURING UNIT AT PLOT NO

RISK ASSESSMENT FOR SUN PHARMACEUTICAL INDUSTRIES LIMITED BULK DRUG AND INTERMEDIATES MANUFACTURING UNIT AT PLOT NO. HA-1, MALANPUR, BHIND, MADHYA PRADESH Introduction The main objective of risk assessment study is to propose a comprehensive but simple approach to carry out risk analysis and conducting hazard analysis study. Risk analysis and risk assessment provides details on Risk Assessment techniques used to determine risk posed to people who work inside or live near hazardous facilities, and to aid in preparing effective emergency response plans by delineating a Disaster Management Plan (DMP) to handle on-site and assist in dealing off-site emergencies with District Administration. Hence, RA is a site or risk specific assessment which is complex and needs extensive study, shall involve process understanding, hazard identification, consequence modelling, probability data, vulnerability models/data, local weather and terrain conditions and local population data. RA may be carried out to serve the following objectives: Hazard Identification Identification of hazardous situations. Identification of hazard sources Generation of accidental release scenarios for escape of hazardous materials from the facility Identification of vulnerable units with recourse to hazard indices Hazard quantification and Evaluation Hazard quantification - consequence analysis to assess the impacts by estimation of distances of occurrences of hazardous events (toxic concentration, heat radiation, pressure wave transmission) due to process and computation of reliability of various control paths Suggest risk mitigation measures based on engineering judgement, reliability and risk analysis approaches. Disaster Management Plans Figure 1: Risk Assessment Conceptual Framework 1

Methods of risk prediction shall cover all the design intentions and operating parameters to quantify risk in terms of probability of occurrence of hazardous events and magnitude of its consequence. Details of Storage Facilities The raw materials (required for the manufacturing of products) will be stored in Tank farms, drums, containers (for liquid raw materials) and bags (for solid raw materials) which are in turn stored in the raw materials storage area. RISK MODELLING Simulation of each identified hazardous chemical for consequence analysis has been done by using ALOHA. ALOHA (Areal Locations of Hazardous Atmospheres) is a computer program designed to model chemical releases for emergency responders and planners. It can estimate how a toxic cloud might disperse after a chemical release as well as several fires and explosions scenarios. ALOHA is designed to produce reasonable results quickly enough to be of use to responders during a real emergency. Therefore, ALOHA s calculations represent a compromise between accuracy and speed. Many of ALOHA s features were developed to quickly assist the responder. For example, ALOHA: Minimizes data entry errors by cross-checking the input values and warning the user if the value is unlikely or not physically possible. Contains its own chemical library with physical properties for approximately 1,000 common hazardous chemicals so that users do not have to enter that data. In the present case, a prediction has been done assuming most unfavorable meteorological condition like low wind speed of 1 m/s and stable atmospheric condition F. In case of an accident, the chemicals will spill on ground, may cause toxic fume dispersion, may catch fire and cause thermal radiation or the vapor cloud may travel and meeting an ignition source, may explode causing pressure waves and damaging structures. All these possible situations have been predicted with affected distance of Level of Concern (LOC). Key Program Features Generates a variety of scenario-specific output, including threat zone pictures, threats at specific locations, and source strength graphs. Calculates how quickly chemicals are escaping from tanks and puddles, and predicts how those release rates change over time. Models many release scenarios like: 1. Toxic gas clouds, 2. BLEVEs (Boiling Liquid Expanding Vapor Explosions), 3. Jet fires, 4. Vapor cloud explosions, and 5. Pool fires. 6. Evaluates different types of hazard (depending on the release scenario): toxicity, flammability, thermal radiation, and overpressure. ALOHA is developed jointly by the National Oceanic and Atmospheric Administration (NOAA) and the U.S. Environmental Protection Agency (EPA). ALOHA model needs site specific information to calculate solar insolation like location name, latitude and longitude of location and its elevation. It can model both light gases using Gaussian Model and heavy gases using 2

DEGADIS. It also needs building type, building surroundings, wind speed, direction (from meteorological measurement), wind measuring heights, ground roughness, cloud cover, stability class, inversion and humidity. It also needs storage tank type and orientation, tank dimension, state of chemical, temperature inside the stank, diameter of assumed or actual accidental opening in tank, leak type and assumed or actual height of opening ALOHA software was used to model the effects of each scenario taking into consideration the usual atmospheric conditions as well as the worst case atmospheric conditions. ALOHA is a computer program designed especially for use by people responding to chemical releases when an accident has taken place, as well as for emergency planning. ALOHA models key hazards - toxicity, flammability, thermal radiation (heat) and overpressure (explosion, blast force) - related to chemical releases that result in toxic gas dispersions, fires and/or explosions. ALOHA allows for the specification of concentration limits for the purpose of consequence assessment (e.g., assessment of human health risks from contaminant plume exposure). Damage Criteria used in the project The hazardous categories is modeled in Table 1. Table 1: Hazard categories modeled in ALOHA Scenario\Source Tank Puddle Vapor cloud (flash fire) Flammable area Flammable area Vapor cloud (explosion) Overpressure Overpressure Vapor cloud (Dispersion of Toxic vapor) Toxic vapors Toxic vapors Pool fire Thermal radiation Thermal radiation BLEVE (fireball) Thermal radiation NA (A) Thermal Damage The thermal radiation effects on people depend upon the length of time they are exposed to a specific thermal radiation level. ALOHA uses three threshold values (measured in kilowatts per square meter) to create the default threat zones: Red: >10 kw/ m 2. -- potentially lethal within 60 sec; Orange: >5 kw/ m 2 -- second-degree burns within 60 sec; and Yellow: >2 kw/ m 2 -- pain within 60 sec. Longer exposure durations, even at a lower thermal radiation level, can produce serious physiological effects. The threat zones displayed by ALOHA represent thermal radiation levels of certain hazardous chemicals in the environment in case it is under fire. (B) Overpressure: This is a case of explosion due to overpressure in tank or a vapour cloud explosion when it meets a spark on the way. The threat zones are as follows: Red: 8.0 psi (Destruction to Buildings) Orange: 3.5 psi (Serious Injury Likely) Yellow: 1.0 psi (Shatters Glass) (C) Toxic release: For toxic release, there are several hazard classification systems in use. Some chemicals have not been classified in every system. ALOHA determines its default toxic Level of Concern (LOC) values based on the following: PACs: Protective Action Criteria 3

This dataset combines all three common public exposure guideline systems (AEGLs, ERPGs, and TEELs) and implements a hierarchy-based system. (AEGLs are used preferentially, followed by ERPGs, and then TEELs.) If ALOHA is defaulting to the PAC values, it means that there are no AEGL or ERPG values in the ALOHA chemical library for that substance. In this case, the PAC values will be the TEEL values. TEELs are derived using existing LOCs and by manipulating current data. This process is less intensive than the AEGL or ERPG process, and TEELs have been defined for more than 3,000 chemicals. 1) Acute Exposure Guideline Levels (AEGLs) Acute Exposure Guideline Levels (AEGLs) are Toxic Levels of Concern (LOCs) that is used to predict the area where a toxic gas concentration might be high enough to harm people. The guidelines define three-tiered AEGLs as follows: AEGL-1: The airborne concentration of a substance above which it is predicted that the general population, including susceptible individuals, could experience notable discomfort, irritation, or certain asymptomatic nonsensory effects. However, the effects are not disabling and are transient and reversible upon cessation of exposure. AEGL-2: The airborne concentration of a substance above which it is predicted that the general population, including susceptible individuals, could experience irreversible or other serious, long-lasting adverse health effects or an impaired ability to escape. AEGL-3: The airborne concentration of a substance above which it is predicted that thegeneral population, including susceptible individuals, could experience life-threatening health effects or death. 2) The Emergency Response Planning Guidelines (ERPGs) The American Industrial Hygiene Association (AIHA) has issued three levels of ERPG values based on toxic effect of the chemical for use in evaluating the effects of accidental chemical releases on the general public. The Emergency Response Planning Guidelines (ERPGs) are Toxic Levels of Concern (LOCs) that is used to predict the area where a toxic gas concentration might be high enough to harm people. The ERPGs are three tiered guidelines with one common denominator: 1-hour contact duration. Each guideline identifies the substance, its chemical and structural properties, animal toxicology data, human experience, existing exposure guidelines, the rationale behind the selected value, and a list of references. ERPG 1: The maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hour without experiencing other than mild transient adverse health effects or perceiving a clearly defined, objectionable odour. ERPG 2: The maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action. ERPG 3: The maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hour without experiencing or developing life threatening health effects. The most important point about the ERPGs is that they do not contain safety factors usually incorporated into exposure guidelines. Rather, they estimate how the general public would react to chemical exposure. Just below the ERPG-1, for example, most people would detect the chemical and may experience temporary mild effects. Just below the ERPG-3, on the other hand, it is estimated that the effects would be severe, although not lifethreatening. The ERPG should serve as a planning tool, not a standard to protect the public. 4

3) Temporary Emergency Exposure Levels (TEELs) There are three TEEL levels that are important for responders to consider: TEEL-1: Maximum concentration in air below which it is believed nearly all individuals could be exposed without experiencing other than mild transient health effects or perceiving a clearly defined objectionable odour. TEEL-2: Maximum concentration in air below which it is believed nearly all individuals could be exposed without experiencing or developing irreversible or other serious health effects or symptoms that could impair their abilities to take protective action. TEEL-3: Maximum concentration in air below which it is believed nearly all individuals could be exposed without experiencing or developing life-threatening health effects. 4) Immediate Dangerous to Life or Health (IDLH) Immediately Dangerous to Life or Health (IDLH) level is a limit originally established for selecting respirators for use in workplaces by the National Institute for Occupational Safety and Health (NIOSH). A chemical's IDLH is an estimate of the maximum concentration in the air to which a healthy worker could be exposed without suffering permanent or escape-impairing health effects. It was recommended that appropriate respirator (as per NIOSH) be kept handy/easily available. The IDLH was not designed to be an exposure limit for the general population. It does not take into account the greater sensitivity of some people, such as children and the elderly. For AEGLs, ERPGs and TEELs, the rank number increase with the hazard level, so that AEGL-3 is more hazardous than AEGL-1. Typically, the 3 values are used for the most hazardous (red) threat zones because they represent the threshold concentration above which health effects may be life threatening. INPUT USED FOR ALOHA MODELLING SITE DATA Location: GHIRONGI INDUSTRIAL AREA, BHIND DISTRICT, MADHYA PRADESH. Wind Speed: 1m/s Stability Class: F Air Temperature: 29.6 0 C Relative humidity: 50% CONSEQUENCES ANALYSIS FOR FAILURE SCENARIOS OF HAZARDOUS CHEMICALS (A) ACETONE CHEMICAL DATA: Chemical Name: ACETONE CAS Number: 67-64-1 Molecular Weight: 58.08 g/mol AEGL-1:: 200 ppm AEGL-2: 3200 ppm AEGL-3: 5700 ppm LEL: 26000 ppm UEL: 130000 ppm Vapor Pressure at Ambient Temperature: 0.37 atm Ambient Boiling Point: 56.3 C Ambient Saturation Concentration: 370,756 ppm or 37.1% SOURCE STRENGTH: Leak from hole in vertical cylindrical tank Circular Opening Diameter: 10 centimeters 5

Flammable chemical escaping from tank (not Opening is 0.7 meters from tank bottom burning) Release Duration: ALOHA limited the duration to 1 Max Average Sustained Release Rate: 249 hour kilograms/min (averaged over a minute or more) Total Amount Released: 10,368 kilograms The puddle spread to a diameter of 60 meters. Note: The chemical escaped as a liquid and formed an evaporating puddle PART I: TOXIC AREA OF VAPOR CLOUD THREAT ZONE: Model Run: Heavy Gas Orange: 254 meters --- (3200 ppm = AEGL-2) Red : 196 meters --- (5700 ppm = AEGL-3) Yellow: 1 Kilometer --- (200 ppm = PAC-1) Figure 2: Toxic Area of Vapor Cloud - Acetone PART II: FLAMMABLE AREA OF VAPOR CLOUD Model Run: Heavy Gas Red : 128 meters (15600 ppm =60% LEL = Flame Pockets) Yellow: 280 meters --- (2600 ppm = 10% LEL) 6

PART III: BLAST AREA OF VAPOUR CLOUD Figure 3: Flammable area of Vapor Cloud - Acetone Threat Modelled: Overpressure (blast force) from vapour cloud explosion Model Run: Heavy Gas Type of Ignition: Ignited by Spark or Flame Red: LOC was never exceeded --- (8.0 psi = destruction of buildings) Orange: 103 meters (3.5 psi = serious injury likely) Yellow: 150 meters --- (1.0 psi = shatter glass) Figure 4: Blast area of Vapor Cloud - Acetone CASE B: LEAKING TANK, CHEMICAL IS BURING AND FORMS A POOL FIRE THERMAL RADIATION FROM POOL FIRE Red : 17 meters --- (10.0 kw/(m 2 ) = potentially lethal Orange: 25 meters --- (5.0 kw/(m 2 ) = 2nd degree within 60 sec) burns within 60 sec) Yellow: 41 meters --- (2.0 kw/(sq m) = pain within 60 sec) 7

SOURCE STRENGTH Leak from hole vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (assumed) Flammable chemical is burning as it escaping from tank Burn Duration: ALOHA limited the duration to 1 hour Max Burn Rate: 362 kilograms/min Total Amount Burned: 21,295 kilograms The puddle spread to a diameter of 12.4 meters. Figure 5: Thermal Radiation from Pool Fire- Acetone CASE C: BLEVE, TANK EXPLODES & CHEMICAL BURNS IN A FIREBALL THREAT ZONE Threat Modeled: Thermal radiation from fireball Orange: 449 meters --- (5.0 kw/(sq m) = 2nd degree burns within 60 sec) Red: 315 meters --- (10.0 kw/(sq m) = potentially lethal within 60 sec) Yellow: 704 meters --- (2.0 kw/(sq m) = pain within 60 sec) SOURCE STRENGTH Leak from hole vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (Assumed) BLEVE of Flammable liquid in vertical cylindrical tank Fireball Diameter: 183 meters Burn Duration: 12 Seconds 8

Figure 6: BLEVE- Acetone SUMMARY FOR ALOHA RESULTS Leaking Tank, Chemical is not burning &forms an evaporating puddle Leaking Tank, Chemical is burning & forms a pool fire. BLEVE, tank explodes & Chemical burns in a fireball. Situation Affected Distance (m) Red Orange Yellow Toxic Area of Vapour Cloud 196 254 1000 Flammable Area of Vapour Cloud 128-280 Blast: Vapour Cloud Explosion - 103 150 Thermal radiation 17 25 41 Thermal radiation 315 449 704 (B) ETHANOL CHEMICAL DATA: Chemical Name: ETHANOL CAS Number: 64-17-5 Molecular Weight: 46.07 g/mol ERPG-1: 1800 ppm ERPG-2: 3300 ppm ERPG-3: 3300 ppm IDLH: 3300 ppm LEL: 33000 ppm UEL: 190000 ppm Vapor Pressure at Ambient Temperature: 0.10 atm Ambient Boiling Point: 78.1 C Ambient Saturation Concentration: 102,227 ppm or 10.2% SOURCE STRENGTH: Leak from hole in vertical cylindrical tank Opening is 0.7 meters from tank bottom (Assumed) Circular Opening Diameter: 10 centimeters (Assumed) Flammable chemical escaping from tank (not burning) 9

Release Duration: ALOHA limited the duration to 1 Max Average Sustained Release Rate: 93.2 hour kilograms/min (averaged over a minute or more) Total Amount Released: 3,395 kilograms The puddle spread to a diameter of 77 meters. Note: The chemical escaped as a liquid and formed an evaporating puddle PART I: TOXIC AREA OF VAPOR CLOUD THREAT ZONE: Model Run: Heavy Gas Orange: 154 meters --- (3300 ppm = ERPG-2) Red: Not Applicable Yellow: 217 meters --- (1800 ppm = ERPG-1) PART II: FLAMMABLE AREA OF VAPOR CLOUD Figure 7: Toxic area of vapor cloud - Ethanol Model Run: Heavy Gas Red : 47 meters (19800 ppm =60% LEL = Flame Pockets) Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances. Yellow: 154 meters --- (3300 ppm = 10% LEL) Figure 8: Flammable area of vapor cloud - Ethanol 10

PART III: BLAST AREA OF VAPOUR CLOUD Threat Modelled: Overpressure (blast force) from vapour cloud explosion Model Run: Heavy Gas Type of Ignition: Ignited by Spark or Flame Red: LOC was never exceeded --- (8.0 psi = destruction of buildings) Orange: LOC was never exceeded (3.5 psi = serious injury likely) Yellow: 34 meters --- (1.0 psi = shatter glass) Figure 9: Blast area of vapor cloud - Ethanol CASE B: LEAKING TANK, CHEMICAL IS BURING AND FORMS A POOL FIRE THERMAL RADIATION FROM POOL FIRE Red : 17 meters --- (10.0 kw/(m 2 ) = potentially lethal Orange: 25 meters --- (5.0 kw/(m 2 ) = 2nd degree within 60 sec) burns within 60 sec) Yellow: 39 meters --- (2.0 kw/(sq m) = pain within 60 sec) SOURCE STRENGTH Leak from hole vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (Assumed) Flammable chemical is burning as it escaping from tank Burn Duration: ALOHA limited the duration to 1 hour Max Burn Rate: 362 kilograms/min Total Amount Burned: 20,915 kilograms The puddle spread to a diameter of 16.7 meters. 11

Figure 10: Thermal Radiation from Pool Fire - Ethanol CASE C: BLEVE, TANK EXPLODES & CHEMICAL BURNS IN A FIREBALL THREAT ZONE Threat Modeled: Thermal radiation from fireball Orange: 435 meters --- (5.0 kw/(sq m) = 2nd degree burns within 60 sec) Red: 304 meters --- (10.0 kw/(sq m) = potentially lethal within 60 sec) Yellow: 683 meters --- (2.0 kw/(sq m) = pain within 60 sec) SOURCE STRENGTH Leak from hole vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (Assumed) BLEVE of Flammable liquid in vertical cylindrical tank Fireball Diameter: 183 meters Burn Duration: 12 Seconds SUMMARY FOR ALOHA RESULTS Figure 11: BLEVE- Ethanol 12

Leaking Tank, Chemical is not burning &forms an evaporating puddle Leaking Tank, Chemical is burning & forms a pool fire. BLEVE, tank explodes & Chemical burns in a fireball. (C) ETHYL ACETATE CHEMICAL DATA: Situation Affected Distance (m) Red Orange Yellow Toxic Area of Vapour Cloud - 154 217 Flammable Area of Vapour Cloud 47-154 Blast: Vapour Cloud Explosion - - 34 Thermal radiation 17 25 39 Thermal radiation 304 435 683 Chemical Name: ETHYL ACETATE CAS Number: 141-78-6 Molecular Weight: 88.11 g/mol PAC-1: 1200 ppm PAC-2: 1700 ppm PAC-3: 10000 ppm IDLH: 2000 ppm LEL: 21800 ppm UEL: 115000 ppm Vapor Pressure at Ambient Temperature: 0.15 atm Ambient Boiling Point: 77.0 C Ambient Saturation Concentration: 153,839 ppm or 15.4% SOURCE STRENGTH: Leak from hole in vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (Assumed) Flammable chemical escaping from tank (not burning) Release Duration: ALOHA limited the duration to 1 hour Max Average Sustained Release Rate: 192 kilograms/min (averaged over a minute or more) Total Amount Released: 7,328 kilograms The puddle spread to a diameter of 67 meters. Note: The chemical escaped as a liquid and formed an evaporating puddle PART I: TOXIC AREA OF VAPOR CLOUD THREAT ZONE: Model Run: Heavy Gas Red: 115 meters --- (10000 ppm = PAC -3) Orange: 245 meters --- (1700 ppm = PAC-2) Yellow: 287 meters --- (1200 ppm = PAC-1) 13

PART II: FLAMMABLE AREA OF VAPOR CLOUD Figure 12: Toxic area of Vapor Cloud Ethyl Acetate Model Run: Heavy Gas Red : 104 meters (13080 ppm =60% LEL = Flame Pockets Yellow: 218 meters --- (2180 ppm = 10% LEL) PART III: BLAST AREA OF VAPOUR CLOUD Figure 13: Flammable area of Vapor Cloud Ethyl Acetate Threat Modelled: Overpressure (blast force) from vapour cloud explosion Model Run: Heavy Gas Type of Ignition: Ignited by Spark or Flame Red: LOC was never exceeded --- (8.0 psi = destruction of buildings) Orange: 85 meters (3.5 psi = serious injury likely) Yellow: 128 meters --- (1.0 psi = shatter glass) 14

Figure 14: Blast area of Vapor Cloud Ethyl Acetate CASE B: LEAKING TANK, CHEMICAL IS BURING AND FORMS A POOL FIRE THERMAL RADIATION FROM POOL FIRE Red : 15 meters --- (10.0 kw/(m 2 ) = potentially lethal Orange: 24 meters --- (5.0 kw/(m 2 ) = 2nd degree within 60 sec) burns within 60 sec) Yellow: 38 meters --- (2.0 kw/(sq m) = pain within 60 sec) SOURCE STRENGTH Leak from hole vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (Assumed) Flammable chemical is burning as it escaping from tank Burn Duration: ALOHA limited the duration to 1 hour Max Burn Rate: 386 kilograms/min Total Amount Burned: 22,645 kilograms The puddle spread to a diameter of 12.7 meters. Figure 15:Thermal Radiation from Pool Fire Ethyl Acetate CASE C: BLEVE, TANK EXPLODES & CHEMICAL BURNS IN A FIREBALL 15

THREAT ZONE Threat Modeled: Thermal radiation from fireball Orange: 423 meters --- (5.0 kw/(sq m) = 2nd degree burns within 60 sec) Red: 295 meters --- (10.0 kw/(sq m) = potentially lethal within 60 sec) Yellow: 666 meters --- (2.0 kw/(sq m) = pain within 60 sec) SOURCE STRENGTH Leak from hole vertical cylindrical tank Opening is 0.7 meters from tank bottom (Assumed) Fireball Diameter: 19 meters Circular Opening Diameter: 10 centimeters (Assumed) BLEVE of Flammable liquid in vertical cylindrical tank Burn Duration: 12 Seconds Figure 16: BLEVE Ethyl Acetate SUMMARY FOR ALOHA RESULTS Leaking Tank, Chemical is not burning &forms an evaporating puddle Leaking Tank, Chemical is burning & forms a pool fire. BLEVE, tank explodes & Chemical burns in a fireball. (D) HEXANE CHEMICAL DATA: Situation Affected Distance (m) Red Orange Yellow Toxic Area of Vapour Cloud 115 245 287 Flammable Area of Vapour Cloud 104-218 Blast: Vapour Cloud Explosion - 85 128 Thermal radiation 15 24 38 Thermal radiation 295 423 666 Chemical Name: HEXANE CAS Number: 110-54-3 Molecular Weight: 86.18 g/mol AEGL-1: N/A AEGL-2: 2900 ppm AEGL-3: 8600 ppm IDLH: 1100 ppm LEL: 12000 ppm 16

UEL: 72000 ppm Ambient Boiling Point: 68.5 C SOURCE STRENGTH: Vapor Pressure at Ambient Temperature: 0.24 atm Ambient Saturation Concentration: 244,913 ppm or 24.5% Leak from hole in vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (Assumed) Flammable chemical escaping from tank (not burning) Release Duration: ALOHA limited the duration to 1 hour Max Average Sustained Release Rate: 247 kilograms/min (averaged over a minute or more) Total Amount Released: 10,361 kilograms The puddle spread to a diameter of 61 meters. Note: The chemical escaped as a liquid and formed an evaporating puddle PART I: TOXIC AREA OF VAPOR CLOUD THREAT ZONE: Model Run: Heavy Gas Red: 144 meters --- (8600 ppm = AEGL 3) Orange: 227 meters --- (2900 ppm = AEGL-2) Yellow: Not Applicable PART II: FLAMMABLE AREA OF VAPOR CLOUD Figure 17: Toxic area of Vapour Cloud - Hexane Model Run: Heavy Gas Red : 155 meters (7200 ppm =60% LEL = Flame Pockets) Yellow: 337 meters --- (1200 ppm = 10% LEL) 17

PART III: BLAST AREA OF VAPOUR CLOUD Figure 18: Flammable area of Vapour Cloud - Hexane Threat Modelled: Overpressure (blast force) from vapour cloud explosion Model Run: Heavy Gas Type of Ignition: Ignited by Spark or Flame Red: LOC was never exceeded --- (8.0 psi = destruction of buildings) Orange: 126 meters (3.5 psi = serious injury likely) Yellow: 186 meters --- (1.0 psi = shatter glass) Figure 19: Blast area of Vapour Cloud - Hexane CASE B: LEAKING TANK, CHEMICAL IS BURING AND FORMS A POOL FIRE THERMAL RADIATION FROM POOL FIRE Red : 20 meters --- (10.0 kw/(m 2 ) = potentially lethal Orange: 30 meters --- (5.0 kw/(m 2 ) = 2nd degree within 60 sec) burns within 60 sec) Yellow: 49 meters --- (2.0 kw/(sq m) = pain within 60 sec) SOURCE STRENGTH 18

Leak from hole vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (Assumed) Flammable chemical is burning as it escaping from tank Burn Duration: ALOHA limited the duration to 1 hour Max Burn Rate: 330 kilograms/min Total Amount Burned: 19,709 kilograms The puddle spread to a diameter of 8.2 meters. Figure 20: Thermal radiation from Pool fire - Hexane CASE C: BLEVE, TANK EXPLODES & CHEMICAL BURNS IN A FIREBALL THREAT ZONE Threat Modeled: Thermal radiation from fireball Orange: 529 meters --- (5.0 kw/(sq m) = 2nd degree burns within 60 sec) Red: 75 meters --- (10.0 kw/(sq m) = potentially lethal within 60 sec) Yellow: 825 meters --- (2.0 kw/(sq m) = pain within 60 sec) SOURCE STRENGTH Leak from hole vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (Assumed) BLEVE of Flammable liquid in vertical cylindrical tank Fireball Diameter: 172 meters Burn Duration: 11 Seconds 19

Figure 21: BLEVE- Hexane SUMMARY FOR ALOHA RESULTS Leaking Tank, Chemical is not burning &forms an evaporating puddle Leaking Tank, Chemical is burning & forms a pool fire. BLEVE, tank explodes & Chemical burns in a fireball. Situation Affected Distance (m) Red Orange Yellow Toxic Area of Vapour Cloud 144 227 - Flammable Area of Vapour Cloud 155-337 Blast: Vapour Cloud Explosion - 126 186 Thermal radiation 20 30 49 Thermal radiation 75 529 825 (E) ISO PROPYL ALCOHOL CHEMICAL DATA: Chemical Name: ISO PROPYL ALCOHOL CAS Number: 67-63-0 Molecular Weight: 60.10 g/mol PAC-1: 400 ppm PAC-2: 2000 ppm PAC-3: 12000 ppm IDLH: 2000 ppm LEL: 20000 ppm UEL: 127000 ppm Vapor Pressure at Ambient Temperature: 0.076 atm Ambient Boiling Point: 82.0 C Ambient Saturation Concentration: 76,411 ppm or 7.64% SOURCE STRENGTH: Leak from hole in vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (Assumed) Flammable chemical escaping from tank (not burning) Release Duration: ALOHA limited the duration to 1 hour Max Average Sustained Release Rate: 89.2 kilograms/min (averaged over a minute or more) Total Amount Released: 3,229 kilograms The puddle spread to a diameter of 78 meters. Note: The chemical escaped as a liquid and formed an evaporating puddle PART I: TOXIC AREA OF VAPOR CLOUD THREAT ZONE: Model Run: Heavy Gas Red: 57 meters --- (12000 ppm = PAC 3) Orange: 177 meters --- (2000 ppm = PAC-2) Yellow: 424 meters --- (400 ppm = PAC-1) 20

Figure 22: Toxic area of vapor cloud Isopropyl Alcohol PART II: FLAMMABLE AREA OF VAPOR CLOUD Model Run: Heavy Gas Red : 57 meters (12000 ppm =60% LEL = Flame Pockets) Yellow: 177 meters --- (2000 ppm = 10% LEL) Figure 23: Flammable area of vapor cloud Isopropyl Alcohol CASE B: LEAKING TANK, CHEMICAL IS BURING AND FORMS A POOL FIRE THERMAL RADIATION FROM POOL FIRE Red : 18 meters --- (10.0 kw/(m 2 ) = potentially lethal Orange: 27 meters --- (5.0 kw/(m 2 ) = 2nd degree within 60 sec) burns within 60 sec) Yellow: 42 meters --- (2.0 kw/(sq m) = pain within 60 sec) SOURCE STRENGTH Leak from hole vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) 21

Opening is 0.7 meters from tank bottom (Assumed) Burn Duration: ALOHA limited the duration to 1 hour Total Amount Burned: 21,284 kilograms Flammable chemical is burning as it escaping from tank Max Burn Rate: 365 kilograms/min The puddle spread to a diameter of 14.7 meters. Figure: 24: Thermal Radiation from Pool Fire Isopropyl Alcohol CASE C: BLEVE, TANK EXPLODES & CHEMICAL BURNS IN A FIREBALL THREAT ZONE Threat Modeled: Thermal radiation from fireball Orange: 435 meters --- (5.0 kw/(sq m) = 2nd degree burns within 60 sec) Red: 304 meters --- (10.0 kw/(sq m) = potentially lethal within 60 sec) Yellow: 683 meters --- (2.0 kw/(sq m) = pain within 60 sec) SOURCE STRENGTH Leak from hole vertical cylindrical tank Opening is 0.7 meters from tank bottom (Assumed) Fireball Diameter: 183 meters Circular Opening Diameter: 10 centimeters (Assumed) BLEVE of Flammable liquid in vertical cylindrical tank Burn Duration: 12 Seconds SUMMARY FOR ALOHA RESULTS Figure: 25: BLEVE Isopropyl Alcohol 22

Leaking Tank, Chemical is not burning &forms an evaporating puddle Leaking Tank, Chemical is burning & forms a pool fire. BLEVE, tank explodes & Chemical burns in a fireball. Situation Affected Distance (m) Red Orange Yellow Toxic Area of Vapour Cloud 57 177 424 Flammable Area of Vapour Cloud 57 177 - Blast: Vapour Cloud Explosion - - - Thermal radiation 18 27 42 Thermal radiation 304 435 683 (F) METHANOL CHEMICAL DATA: Chemical Name: METHANOL CAS Number: 64-56-1 Molecular Weight: 32.04 g/mol AEGL-1: 530 ppm AEGL-2: 2100 ppm AEGL-3: 7200 ppm IDLH: 6000 ppm LEL: 71800 ppm UEL: 365000 ppm Vapor Pressure at Ambient Temperature: 0.21 atm Ambient Boiling Point: 64.7 C Ambient Saturation Concentration: 211,757 ppm or 21.2% SOURCE STRENGTH: Leak from hole in vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (Assumed) Flammable chemical escaping from tank (not burning) Release Duration: ALOHA limited the duration to 1 hour Max Average Sustained Release Rate: 123 kilograms/min (averaged over a minute or more) Total Amount Released: 4,645 kilograms The puddle spread to a diameter of 74 meters. Note: The chemical escaped as a liquid and formed an evaporating puddle PART I: TOXIC AREA OF VAPOR CLOUD THREAT ZONE: Model Run: Heavy Gas Red: 134 meters --- (7200 ppm = AEGL -3) Orange: 279 meters --- (2100 ppm = AEGL-2) Yellow: 621 meters --- (530 ppm = AEGL-1) 23

PART II: FLAMMABLE AREA OF VAPOR CLOUD Figure: 26: Toxic Area of Vapor Cloud - Methanol Model Run: Heavy Gas Red : 30 meters (43080 ppm =60% LEL = Flame Pockets) Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances. Yellow: 134 meters --- (7180 ppm = 10% LEL) Figure: 27: Flammable Area of Vapor Cloud - Methanol CASE B: LEAKING TANK, CHEMICAL IS BURING AND FORMS A POOL FIRE THERMAL RADIATION FROM POOL FIRE Red : 16 meters --- (10.0 kw/(m 2 ) = potentially lethal Orange: 22 meters --- (5.0 kw/(m 2 ) = 2nd degree within 60 sec) burns within 60 sec) Yellow: 34 meters --- (2.0 kw/(sq m) = pain within 60 sec) SOURCE STRENGTH Leak from hole vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) 24

Opening is 0.7 meters from tank bottom (Assumed) Burn Duration: ALOHA limited the duration to 1 hour Total Amount Burned: 20,399 kilograms Flammable chemical is burning as it escaping from tank Max Burn Rate: 363 kilograms/min The puddle spread to a diameter of 21 meters. Figure: 28: Thermal radiation of Pool Fire- Methanol CASE C: BLEVE, TANK EXPLODES & CHEMICAL BURNS IN A FIREBALL THREAT ZONE Threat Modeled: Thermal radiation from fireball Orange: 375 meters --- (5.0 kw/(sq m) = 2nd degree burns within 60 sec) Red: 259 meters --- (10.0 kw/(sq m) = potentially lethal within 60 sec) Yellow: 592 meters --- (2.0 kw/(sq m) = pain within 60 sec) SOURCE STRENGTH Leak from hole vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (Assumed) BLEVE of Flammable liquid in vertical cylindrical tank Fireball Diameter: 183 meters Burn Duration: 12 Seconds 25

Figure: 29: BLEVE- Methanol SUMMARY FOR ALOHA RESULTS Leaking Tank, Chemical is not burning &forms an evaporating puddle Leaking Tank, Chemical is burning & forms a pool fire. BLEVE, tank explodes & Chemical burns in a fireball. Situation Affected Distance (m) Red Orange Yellow Toxic Area of Vapour Cloud 134 279 621 Flammable Area of Vapour Cloud 30-134 Blast: Vapour Cloud Explosion - - - Thermal radiation 16 22 34 Thermal radiation 259 375 592 (G) TOULENE CHEMICAL DATA: Chemical Name: ETHANOL CAS Number: 64-17-5 Molecular Weight: 92.14 g/mol AEGL-1: 67 ppm AEGL-2: 560 ppm AEGL-3: 3700 ppm IDLH: 500 ppm LEL: 11000 ppm UEL: 71000 ppm Vapor Pressure at Ambient Temperature: 0.047 atm Ambient Boiling Point: 110.4 C Ambient Saturation Concentration: 47,662 ppm or 4.77% SOURCE STRENGTH: Leak from hole in vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (Assumed) Flammable chemical escaping from tank (not burning) Release Duration: ALOHA limited the duration to 1 hour Max Average Sustained Release Rate: 3.59 kilograms/min (averaged over a minute or more) Total Amount Released: 211 kilograms The puddle spread to a diameter of 14.2 meters. Note: The chemical escaped as a liquid and formed an evaporating puddle PART I: TOXIC AREA OF VAPOR CLOUD THREAT ZONE: Model Run: Heavy Gas Orange: 50 meters --- (560 ppm = AEGL-2) Red: 17 meters --- (3700 ppm=aegl-3) Threat zone was not drawn because effects of nearfield patchiness make dispersion predictions less reliable for short distances. Yellow: 170 meters --- (67 ppm = AEGL-1) 26

Threat zone was not drawn because effects of nearfield patchiness make dispersion predictions less reliable for short distances. PART II: FLAMMABLE AREA OF VAPOR CLOUD Figure: 30: Toxic area of vapor cloud- Toulene Model Run: Heavy Gas Red : 10 meters (6600 ppm =60% LEL = Flame Pockets) Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances. Yellow: 34 meters --- (1100 ppm = 10% LEL) Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances. PART III: BLAST AREA OF VAPOUR CLOUD Threat Modelled: Overpressure (blast force) from vapour cloud explosion Model Run: Heavy Gas Type of Ignition: Ignited by Spark or Flame Red: LOC was never exceeded --- (8.0 psi = destruction of buildings) Orange: 51 meters - (3.5 psi = serious injury likely) Yellow: 76 meters --- (1.0 psi = shatter glass) 27

Figure: 31: Blast area of vapor cloud- Toulene CASE B: LEAKING TANK, CHEMICAL IS BURING AND FORMS A POOL FIRE THERMAL RADIATION FROM POOL FIRE Red : 20 meters --- (10.0 kw/(m 2 ) = potentially lethal Orange: 31 meters --- (5.0 kw/(m 2 ) = 2nd degree within 60 sec) burns within 60 sec) Yellow: 50 meters --- (2.0 kw/(sq m) = pain within 60 sec) SOURCE STRENGTH Leak from hole vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (Assumed) Flammable chemical is burning as it escaping from tank Burn Duration: ALOHA limited the duration to 1 hour Max Burn Rate: 379 kilograms/min Total Amount Burned: 22,493 kilograms The puddle spread to a diameter of 10 meters. Figure: 32: Thermal radiation from Pool Fire- Toulene CASE C: BLEVE, TANK EXPLODES & CHEMICAL BURNS IN A FIREBALL THREAT ZONE 28

Threat Modeled: Thermal radiation from fireball Orange: 551 meters --- (5.0 kw/(sq m) = 2nd degree burns within 60 sec) Red: 389 meters --- (10.0 kw/(sq m) = potentially lethal within 60 sec) Yellow: 859 meters --- (2.0 kw/(sq m) = pain within 60 sec) SOURCE STRENGTH Leak from hole vertical cylindrical tank Circular Opening Diameter: 10 centimeters (Assumed) Opening is 0.7 meters from tank bottom (Assumed) BLEVE of Flammable liquid in vertical cylindrical tank Fireball Diameter: 189 meters Burn Duration: 12 Seconds SUMMARY FOR ALOHA RESULTS Leaking Tank, Chemical is not burning &forms an evaporating puddle Leaking Tank, Chemical is burning & forms a pool fire. BLEVE, tank explodes & Chemical burns in a fireball. Situation Figure: 33: BLEVE - Toulene Affected Distance (m) Red Orange Yellow Toxic Area of Vapour Cloud 17 50 170 Flammable Area of Vapour Cloud 10-34 Blast: Vapour Cloud Explosion - 51 75 Thermal radiation 20 31 50 Thermal radiation 389 551 859 Interpretation & Conclusion: It has been interpreted that the worst case scenario will be toxic gas spread from leakage of acetone from tank and the travel distance will be upto 1000m. The maximum distance till where the effect of accident can be seen, will be up to a distance of 1000m. Therefore it requires immediate evacuation of population up to 1000m and provide immediate medical facilities for injured persons as mentioned in Disaster Management Plan. 29

Figure 34: ALOHA Source Point for worst case scenario of Acetone PRACTICE TO BE FOLLOWED FOR HAZARDOUS CHEMICALS, HANDLING, STORAGE, TRANSPORTATION AND UNLOADING. The safe practices for handling, Storage, Transportation and unloading of Hazardous Chemicals are given in Table 2. Table 2: Safe practice to be followed for handling, storage, transportation and unloading of Hazardous Chemicals S.No Activity Scenario Mitigation Measures 1. Unloading and storing of drums Leaks, splash or fire 2. Charging to reactors and service tanks Leaks, splash or fire Unloading ramp Drum cushioning Trained operators Sorbent pads Respirator with face shield and chemical clothing. Fire extinguisher and hydrant Checking compatibility before storing. Availability of eye wash/shower facility nearby Precautions against ESD Leak containment facility Trained operators Sorbent pads Respirator with face shield and chemical clothing. Fire extinguisher and hydrant Availability of eye wash/shower facility 30

3. Unloading to storage tanks Leaks, splash or fire Nearby. SOP for activity Tanker loading and unloading permit. Precautions against ESD Leak containment facility Trained operators Sorbent pads Respirator with face shield and chemical clothing. Fire extinguisher and hydrant Availability of eye wash/shower facility nearby. DISASTER MANAGEMENT PLAN Disaster A disaster can be defined as an "occurrence of such magnitude so as to create a situation in which normal pattern of life within a facility is suddenly disrupted, adversely affecting not only the personnel and property within the facility but also in its vicinity." Emergency planning is an integral part of the overall loss control program and is essential for any well run organization. This is important for effective management of an accident / incident to minimize losses to people and property, both in and around the facility. The important aspect in emergency management is to prevent by technical and organizational measures, the unintentional escape of hazardous materials out of the facility and minimize accidents and losses. Not only are unrecognized hazardous conditions which could aggravate and emergency situation be discovered, the emergency planning process also brings to light deficiencies such as lack of resources necessary for effective emergency response. Emergency planning also demonstrates the organizations commitment to the safety of employees and increases the organizations safety awareness. The objectives of the emergency planning are to describe the facility s emergency response organization, the resources available and applicable response actions. Thus, the objectives of emergency response plan can be summarized as follows: Rapid control and containment of the hazardous situation; Minimizing the risk and impact of an event/accident; and Effective rehabilitation of the affected persons, and prevention of damage to property. In order to effectively achieve the objectives of emergency planning, the critical elements that form the backbone of the plan are: Reliable and early detection of emergency and careful planning. The command, Co-ordination, and response organization structure alone with efficient trained personnel. The availability of resources for handling emergences. Appropriate emergency response actions. Effective notification and communication facilities. Regular review and updating of the plan. 31

Proper training of the concerned personnel. Declaring Fire Emergency Any one discovering a fire shall attempt to put out the fire by using the first aid firefighting appliances. Simultaneously, he would shout FIRE, FIRE, FIRE/THEE, THEE, THEE (in local language) till the assistance arrives. Any one or his colleagues who hears, shall immediately inform the Shift In-charge and Control Room over phone or in person giving the exact location of the emergency. The Incident Controller on hearing the incident of emergency, would proceed to the scene of emergency and assess the situation and decide whether a major emergency exists or is likely to escalate into major one. If a major one, he would activate the on-site emergency plan by sounding the siren to code and informs the Store Controller. The key personnel would report to the emergency control centre and take respective charge. Firefighting Plan/Arrangements The Project Site will have well-developed Onsite Emergency Plan for handling Fire emergencies. The firefighting arrangements proposed for project site are mentioned below and given in Table 3. Sr. No. Engineering & Administrative Controls: Sufficient engineering controls will be provided in manufacturing unit to avoid any fire incident like interlocking, earthing and grounding etc. Proper supervision and employee s awareness are at top most priority. Fire Detection System: At places smoke detectors and manual call points will be provided. Core Group: Plant will have a core group especially for firefighting and emergency handling. Training: Core group members will be regularly trained on firefighting. Mock Drill and Fire Drills: Mock drills and Fire drills will be carried out regularly in plant. Fire Hydrant System: Fire hydrant system will be provided Table 3: Details of Fixed Fighting Systems Fire Safety System Description Type of Pump Capacity Remark 1 Fire Pump house no-1 Jockey Pump Diesel Pump Electrical Pump 10.8 m3/hr 273m3/hr 273 m3/hr 2 Fire Pump house no-2 Electrical Pump 273 m3/hr 3 Fire Pump house no-3 Jockey Pump Diesel Pump Electrical Pump 10.8 m3/hr 273 m3/hr 273 m3/hr Reservoir capacity- 600KL with auto feeding through borewell pump Reservoir capacity- 350KL with auto feeding through borewell pump Reservoir capacity 650KL with auto feeding through borewell pump 32

Sr. No. Fire Safety System Description Type of Pump Capacity Remark Water 4000L - AFF Foam 1000L (3%) - CO2 Fire extinguishers 6 no. 22.5kg Each - DCP Fire extinguishers 2 no. 75 Kg each - 4 Fire Tender Hose Pipes 8 no. 30 M each - Hose Pipes 2 no. 15 M each - 5 Self-Contained breathing apparatus (SCBA) Fire Proximity Suit 2 no. - - SCBA Set 3 no. 300bar each - Emergency torch (Chargeable) At entrance of each module 49 no. 6 CO2 Fire Extinguishers 582 no. 7 DCP Fire Extinguishers 181 no. 8 ABC Powder Stored Pressure Extinguisher TEC Powder Stored Pressure Extinguisher 2 no s in Tender and one spare in Safety office 10 no s of 200 Bar and 39 no s of 300Bar 2.0Kg, 3.2Kg, 4.5Kg, 6.8Kg, 9.0 Kg,22.5 Kg 10.0Kg, 25.0Kg, 50.0Kg, 75.0Kg 480 no. 9.0Kg,10.0 Kg - 26 9.0Kg - 9 Mechanical Foam 70 no. 9.0Ltr, 50Ltr - 10 Spray Systems 53 no. - - 11 Fire Suit Proximity 9 no. and Fire entry suit 3 no s - - 12 Wind Sock 11 no. - - 13 Sluice Valve 103 no. - - 14 Foam Trolley 22 no. - 15 Foam Flooding System 20 no. 20 no s in Warehouse(Tank farm Area) - - - - Total Foam 13470 L 16 Hose reel 86 no. - - 17 Hydrant System Total Hydrant points= 355 no., Hose Box=299, hose pipes= 524 18 Monitors 41 no s - - 31 fixed and 10 portable - 33

Sr. No. Fire Safety System Description Type of Pump Capacity Remark 19 Safety Shower 109 no. - - 20 High Expansion foam generators 2 no. 23 Heat Detection System 2 no. 300L/min and 100L/min Non Bulk Drum Shed area Warehouse 24 MCP (Manual Call Point) 140 no. In All Modules - 25 AFFF Foam compound 7930 L - 26 AR-AFFF Foam compound 4110 L - - 26 HAZMAT Foam compound 420 L - - - - Figure 35: Proposed Fire Safety Layout Declaring Chemical leakage or fire in the Storage Area Any person discovering Chemical leakage or fire will immediately inform the control room giving the exact location of leakage or fire. The Incident Controller will proceed to the storage to assess the situation. Meanwhile, the person discovering fire shall try to extinguish it, if it is safe to do so, using suitable fire extinguishers. If the leakage could be attended safely, he will call the maintenance and get it attended 34

Chemical leakage from storage Drum shall be collected and not allowed to spread. If the leakage is very heavy, the Store Controller shall be informed and on his confirmation, he will take suitable action. If the leakage has caught fire, the Incident Controller will initiate the On-site Emergency Plan by operating the siren to emergency code. The Site Controller will be informed. Recovery Procedures The procedures outlined in this section are intended for re-establishing normal operations at the earliest after an emergency. In addition, the procedure also provides for determining the cause of the accident, so that such incidents can be prevented in future. The following are the requirements of a recover procedure : a. Incident investigation b. Establishing a recovery team c. Damage Assessment d. Clean-up and restoration e. Post-Emergency and Recovery Reporting. Store Controller will arrange to organize suitable teams for the above tasks. Incident Investigation Incident investigation should be taken up to determine the cause of the emergency and the means of preventing any such occurrences again. Procedure The investigation team should immediately seal off the incident scene and commence its investigation to minimize the loss of any physical evidence. The investigation of the scene should include: a. Photographing the area. b. Determining the point of origin of the fire/leak/explosion, if applicable. c. Nothing any unusual items in the area or any damage that is in consistent with the type of incident. Written or recorded statements will be taken from all store keeper involved, potential witnesses and others who might have pertinent knowledge about the incident. Report A final report will be prepared to include the most probable cause(s) and recommend corrective measures. The report should consider: a. Failure of Storage container b. Failure of maintenance c. Failure of procedures d. Inadequate training e. Human error etc. Corrective Actions a. The investigation team will be responsible for conducting a review of response activities during the emergency to evaluate the adequacy of training, equipment and procedures. 35

b. The Store Controller will be responsible for ensuring that all corrective actions are taken to ensure better responses to emergencies to prevent recurrence of the incident, if any in future. Recovery Team Purpose In order to facilitate the restoration of the company after an emergency, a team known as Recovery Team is to be constituted by Store Controller to manage recovery activities, including damage assessment. Organization The number of persons in the Recovery Team will vary depending on the nature of the incident and the extent of recovery operations. As a general rule, however, individuals representing Maintenance, Production, Safety, Quality Control, Personnel, Accounts, Engineering etc. should be involved. The recovery team will be responsible for damage assessment, clean up and salvage operations and the restoration of the storage activities. A primary function of the recovery team will be to assess the damage to structures, equipment and materials. Clean-up and Restoration Operations As soon as incident investigations are completed and restoration plans have been made, clean up and restoration activities should commence. Post-Emergency Recovery Reports The Officer-in-charge of Safety will hold review sessions with emergency response personnel to evaluate the following: a. The adequacy of emergency response procedures. b. The adequacy of the investigation of the cause of the incident. c. Summaries the post-emergency activities. A full report will be prepared and copies given to all persons concerned. The final report will summarize all previous reports and reviews as mentioned in this section 36

Figure 36 Management Hierarchy Safety Precautions for Storage and Handling of Chemicals/ Solvents For handling chemicals/solvents, the management of SPIL will adopt various practice of preventive and predictive maintenance. Some of them ae mentioned below: Precautions for storage and handling of Chemicals/Solvents: Storage with proper enclosures and markings Proper ventilation will be provided. Sufficient fire extinguishers and PPE will be made available at project site. Flame proof fittings will be provided wherever, required at project site. Smoking will be prohibited. Protection against lightning will be provided. Precautions against ignition sources will be arranged. Sufficient access for firefighting will be provided in the unit. All employees will be provided with adequate and appropriate PPE like masks, gloves, helmet, chemical suits, and safety shoes. Safety Precautions for Handling of LNG (Liquefied Natural Gas) Storage, transfer, and transport of LNG may result in leaks or accidental release from tanks, pipes, hoses, and pumps at land installations and in LNG transport vessels and vehicles. The storage and transfer of LNG also poses a risk of fire and, if under pressure, explosion, due to the flammable characteristics of its boil-off gas (BOG). Precautions for storage and handling of LNG: 37