6 additional studies – risk assessment · situations and discusses the contents of an emergency...

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M/S. INEOS ABS (INDIA) LTD. ENVIRONMENTAL IMPACT ASSESSMENT AND RISK ASSESSMENT ON EXPANSION OF STYRENE ACRYLONITRILE PRODUCTION ADDITIONAL STUDIES - RISK ASSESSMENT KADAM ENVIRONMENTAL CONSULTANTS FEBRUARY 2011 123 6 ADDITIONAL STUDIES – RISK ASSESSMENT 6.1 Introduction An emergency is considered to be a situation of process deviation that may lead to or actually leads to a major accident/disaster with potential short term and/or long term risk and damage consequences to life and property in and/or around the factory. A Disaster is a catastrophic consequence of a major emergency/accident that leads to, not only extensive damage to life and property but also disrupts all normal human activity for a pretty long time and requires a major national and international effort for rescue and rehabilitation of those affected. Since the occurrence of a disaster is very remote for this project, the report focuses on emergency situations and discusses the contents of an Emergency Plan (EP) and Contingency Plan (CP). EP is a guide, giving general considerations, directions and procedures for handling emergencies likely to arise from deviations to planned operations. The site specific document contingent to – and demonstrating suitable implementation of the EP is called the CP. The CP, being site specific, will require to be updated once the construction, and later on, production commences. 6.2 Emergency Plan: Structure The EP is supposed to be a dynamic, changing, document focusing on continual improvement of emergency response planning and arrangements. A structure working on a Plan, Do, Check & Review (PDCR) cycle has been therefore suggested. Another advantage of doing this is to have a system that is in synchronicity with commonly used EHS systems such as ISO 14001 and OHSAS 18000. 6.3 Policy Expanded Incorporation’s Environment, Health and Safety Policies guide the Emergency Response Plan. These policies are to be made accessible to all at site and to other stakeholders. The policies have been framed considering legislative compliance, stakeholder involvement, continual improvement, and management by objectives. 6.4 Planning Event Classification and Modes of Failure Hazards that can lead to accidents in operations are discussed in this section. Important hazardous events are classified in Table 6-1. Table 6-1: Event Classification Type of Event Explanation BLEVE Boiling Liquid Evaporating Vapour Explosion; may happen due to catastrophic failure of refrigerated or pressurized gases or liquids stored above their boiling points, followed by early ignition of the same, typically leading to a fire ball Deflagration Is the same as detonation but with reaction occurring at less than sonic velocity and initiation of the reaction at lower energy levels Detonation A propagating chemical reaction of a substance in which the reaction front advances in the unreacted substance at or greater than sonic velocity in the unreacted material Explosion A release of large amount of energy that form a blast wave Fire Fire

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Page 1: 6 ADDITIONAL STUDIES – RISK ASSESSMENT · situations and discusses the contents of an Emergency Plan (EP) and Contingency Plan (CP). EP is a guide, giving general considerations,

M/S. INEOS ABS (INDIA) LTD. ENVIRONMENTAL IMPACT ASSESSMENT AND RISK ASSESSMENT ON EXPANSION OF STYRENE ACRYLONITRILE PRODUCTION

ADDITIONAL STUDIES - RISK ASSESSMENT

KADAM ENVIRONMENTAL CONSULTANTS FEBRUARY 2011

123

6 ADDITIONAL STUDIES – RISK ASSESSMENT

6.1 Introduction

An emergency is considered to be a situation of process deviation that may lead to or actually leads to a major accident/disaster with potential short term and/or long term risk and damage consequences to life and property in and/or around the factory.

A Disaster is a catastrophic consequence of a major emergency/accident that leads to, not only extensive damage to life and property but also disrupts all normal human activity for a pretty long time and requires a major national and international effort for rescue and rehabilitation of those affected.

Since the occurrence of a disaster is very remote for this project, the report focuses on emergency situations and discusses the contents of an Emergency Plan (EP) and Contingency Plan (CP).

EP is a guide, giving general considerations, directions and procedures for handling emergencies likely to arise from deviations to planned operations. The site specific document contingent to – and demonstrating suitable implementation of the EP is called the CP. The CP, being site specific, will require to be updated once the construction, and later on, production commences.

6.2 Emergency Plan: Structure

The EP is supposed to be a dynamic, changing, document focusing on continual improvement of emergency response planning and arrangements. A structure working on a Plan, Do, Check & Review (PDCR) cycle has been therefore suggested. Another advantage of doing this is to have a system that is in synchronicity with commonly used EHS systems such as ISO 14001 and OHSAS 18000.

6.3 Policy

Expanded Incorporation’s Environment, Health and Safety Policies guide the Emergency Response Plan. These policies are to be made accessible to all at site and to other stakeholders. The policies have been framed considering legislative compliance, stakeholder involvement, continual improvement, and management by objectives.

6.4 Planning

Event Classification and Modes of Failure

Hazards that can lead to accidents in operations are discussed in this section. Important hazardous events are classified in Table 6-1.

Table 6-1: Event Classification

Type of Event Explanation

BLEVE Boiling Liquid Evaporating Vapour Explosion; may happen due to catastrophic failure of refrigerated or pressurized gases or liquids stored above their boiling points, followed by

early ignition of the same, typically leading to a fire ball

Deflagration Is the same as detonation but with reaction occurring at less than sonic velocity and initiation of the reaction at lower energy levels

Detonation A propagating chemical reaction of a substance in which the reaction front advances in the unreacted substance at or greater than sonic velocity in the unreacted material

Explosion A release of large amount of energy that form a blast wave

Fire Fire

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Type of Event Explanation

Fireball

The burning of a flammable gas cloud on being immediately ignited at the edge before forming a flammable/explosive mixture.

Flash Fire A flammable gas release gets ignited at the farthest edge resulting in flash-back fire

Spill Release ‘Loss of containment’. Release of fluid or gas to the surroundings from unit’s own equipment / tanks causing (potential) pollution and / or risk of explosion and / or fire

Structural Damage Breakage or fatigue failures (mostly failures caused by weather but not necessarily) of structural support and direct structural failures

Vapour Cloud Explosion

Explosion resulting from vapour clouds formed from flashing liquids or non-flashing liquids and gases

6.4.1 Maximum Credible Risk Scenarios (MCLS)

Probable hazards associated with various chemicals handled at INEOS ABS. are as below

Table 6-2 : Probable Hazard Associated

S. No. Material Probable Hazards

1. Styrene Fire, Toxic and Explosive

2. Acrylonitrile Fire, Toxic and Explosive

3. Toluene Fire, Toxic and Explosive

4. Fuel Oil Fire

6.4.2 Maximum Credible Loss Scenario Identified

Broadly, two situations can arise:

1. Emergency situations involving loss of containment of hazardous materials. For the proposed facility, the following containment loss scenarios may be envisaged:

• Loss of Acrylonitrile due to catastrophic rupture of Acrylonitrile storage tank.

• Loss of Acrylonitrile due to catastrophic rupture of Acrylonitrile tanker.

• Loss of Acrylonitrile due to 10mm, 20mm and 50mm leak in the storage tank.

• Loss of Acrylonitrile from pipe connected to the Acrylonitrile storage tank – 20% crosses sectional area failure and 100% failure of the pipeline.

• Loss of Styrene due to catastrophic rupture of styrene storage tank.

• Loss of Styrene due to catastrophic rupture of Styrene tanker.

• Loss of Styrene due to 10mm, 20mm and 50mm leak in the storage tank.

• Loss of Styrene from pipe connected to the Acrylonitrile storage tank – 20% crosses sectional area failure and 100% failure of the pipeline.

Consequence analysis of all the above mentioned containment loss scenarios has been discussed and related consequence isopleths are provided at the end of Chapter.

2. Emergency situations not involving loss of containment are generally more likely to occur and the following are possible:

• Falls due to working at heights (during construction/repair and maintenance).

• Electric shock caused by contact with faulty electrical equipment, cables, etc.

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• Falls on floors made slippery by aqueous solutions or solvents.

• Burns by splashes of liquids, by steam or hot vapors, by contact with hot surfaces.

• Exposure to adverse environmental factors (for e.g. high temperature).

Emergency situations involving containment failure as mentioned above have been modeled for their consequence distances using the software ‘PHAST’ version 6.51, prepared by DNV Technica, UK.

With respect to emergencies situations not involving loss of containment, general recommendations are given at the end of the chapter.

MSDA / Safety Data of, Acrylonitrile, Toluene, Styrene and FO are attached vide Annexure 11, 12, 13 and 14.

6.4.3 Consequence Assessment

Toxic, flammable and explosive substances released from sources of storage as a result of failures or catastrophes, can cause losses in the surrounding area in the form of:

• Toxic gas dispersion, resulting in toxic levels in ambient air,

• Fires, fireballs, and flash back fires, resulting in a heat wave (radiation), or

• Explosions (Vapour Cloud Explosions) resulting in blast waves (overpressure).

Consequences of Toxic Release

Acrylonitrile has an IDLH (Immediately Dangerous to Life and Health) of 85 ppm.

Weather conditions selected are 1/B (prevalent during the day).

Consequences of Fire/Heat Wave

The main consequence is a heat wave that results in heat being exerted on the surrounding life and property, causing damage. The term used to define excess heat is called radiation and is expressed in kilowatt per m2 or kw/m2. The dose is the amount of heat radiation received in unit time and is expressed as kilowatt-hour / m2 or kwh/m2. Some important damage thresholds, expressed as ‘radiation dose’ include:

• Fatal to humans: 37.5 kwh/m2

• First Degree burns to humans: 12.5 kwh/m2. This is also the limit where burning of wood (and consequent damage to environment and property) takes place.

• First Degree burns to humans: 4 kwh/m2

Consequences of Explosions

In case of Vapour Cloud Explosions (VCE’s), the main consequence is a blast wave that results in great pressure being exerted on the surrounding life and property, causing damage. Some important damage thresholds with respect to overpressure include:

• Fatality: 1 bar (16 psi)

• Ear drum rupture of humans: 0.41 bar (6 psi)

• Structural damage to buildings: 0.2 bar (3 psi)

• Glass damage: 0.03 bar (0.5 psi)

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6.4.4 Consequences of Containment Failure and Release of Material into Environment

Release of Acrylonitrile into Environment

It is expected that Acrylonitrile would have four storage tanks for Acrylonitrile having a capacity of 2 tanks of 230 KL and 2 tanks of 160 KL. Maximum storage quantity of Acrylonitrile is 780 KL.

The consequence scenarios considered are loss of Acrylonitrile due to failure of the pipeline connecting to the tank (20% cross sectional area failure and 100% failure cases have been considered) and full rupture of the Acrylonitrile storage tank, which is an extremely unlikely event and rupture of tank truck transporting acrylonitrile having capacity 30 MT.

The consequence distances for due to release of Acrylonitrile due to the various scenarios is provided in Table 6-3.

Table 6-3: Radiation Level and Effect Distance Due to Release of Acrylonitrile

Failure Scenario Description Consequence Met

Data

Effective Distance in meter to Radiation Level

1.6 kW/m2 4 kW/m2 12.5 kW/m2

37.5 kW/m2

10 mm leak from storage tank

Jet fire

1.5/B 23.54 15.63 N.R. N.R.

2.0/C 24.16 16.05 N.R. N.R.

4.0/D 25.46 17.47 N.R. N.R.

Early pool fire

1.5/B 22.27 16.61 11.51 7.28

2.0/C 25.48 19.91 15.18 10.52

4.0/D 28.30 23.10 18.60 12.72

Late pool fire

1.5/B 66.93 46.79 30.09 15.82

2.0/C 68.74 49.30 33.69 19.37

4.0/D 70.85 52.78 37.90 23.23

20 mm leak from storage tank

Jet fire

1.5/B 44.98 30.02 11.56 N.R.

2.0/C 45.89 30.54 15.73 N.R.

4.0/D 48.14 32.67 20.07 6.39

Early pool fire

1.5/B 39.23 28.44 19.23 10.86

2.0/C 40.37 29.71 20.98 12.14

4.0/D 47.08 37.68 29.79 20.38

Late pool fire

1.5/B 73.54 51.64 33.52 18.22

2.0/C 75.01 53.23 35.78 20.08

4.0/D 128.27 94.06 66.20 43.48

50 mm leak from storage tank Jet fire

1.5/B 105.33 70.37 33.66 3.19

2.0/C 106.59 71.11 39.30 7.00

4.0/D 111.31 74.66 45.73 21.76

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Failure Scenario Description Consequence Met

Data

Effective Distance in meter to Radiation Level

1.6 kW/m2 4 kW/m2 12.5 kW/m2

37.5 kW/m2

Early pool fire

1.5/B 73.73 51.83 33.71 18.40

2.0/C 75.56 53.78 36.33 20.63

4.0/D 90.14 67.73 49.34 32.34

Late pool fire

1.5/B 73.73 51.83 33.71 18.40

2.0/C 75.56 53.78 36.33 20.63

4.0/D 291.27 207.13 139.38 93.92

20% Pipe Diameter Vertical

Jet fire

1.5/B 16.37 10.99 N.R. N.R.

2.0/C 17.71 11.79 4.36 N.R.

4.0/D 19.80 14.74 9.82 N.R.

Early pool fire

1.5/B 26.58 18.12 10.77 4.00

2.0/C 26.75 18.36 11.43 4.22

4.0/D 26.87 19.37 13.01 5.08

Late pool fire

1.5/B 68.06 46.16 28.04 12.74

2.0/C 68.51 46.73 29.28 13.58

4.0/D 68.83 48.59 31.94 16.04

100% Pipe Diameter Vertical

Jet fire

1.5/B 16.37 10.99 N.R. N.R.

2.0/C 17.71 11.79 4.36 N.R.

4.0/D 19.80 14.74 9.82 N.R.

Early pool fire

1.5/B 26.58 18.12 10.77 4.00

2.0/C 26.75 18.36 11.43 4.22

4.0/D 26.87 19.35 13.01 5.08

Late pool fire

1.5/B 68.06 46.16 28.04 12.74

2.0/C 68.51 46.73 29.28 13.58

4.0/D 68.83 48.59 31.94 16.04

Catastrophic Rupture of Tank Late pool fire

1.5/B 69.36 47.47 29.35 14.04

2.0/C 70.40 48.62 31.17 15.47

4.0/D 73.33 53.08 36.44 20.53

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Tanker Failure

Acrylonitrile is transported from Kandla to Katol. Taker carring acrylonitrile is about 30MT. Precourtion has been taken during the transportation of tanker and tanker dirvers also trained for any kind of emergency occurred during tranportation.There are various precaution which taken during transportations like:

• Tanker driver must be trained by third party.

• Tanker fitness certificate is required.

• Before loading of material checked tanker with assign checklist.

• Tanker driver and cleaner are also trained on site by safety dept.

• Insulated Tanker used for Acrylonitrile transportation.

• Fire extinguishers are provided in driver cabin in case of emergency.

• Hydro test certificate must be required for Acrylonitrile.

• PPE's also provided.

• Tanker driver must have MSDS and TREM card of chemical, etc.

Failure Scenario Description Consequence Met

Data

Effective Distance in meter to Radiation Level

1.6 kW/m2 4 kW/m2 12.5 kW/m2

37.5 kW/m2

Tanker Rupture of Acrylonitrile

(30MT) Late pool fire

1.5/B 310.51 211.99 132.12 75.43

2.0/C 311.90 213.40 135.48 79.78

4.0/D 313.12 145.85 143.12 92.73

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D 6-1: Risk Contour of Late Pool Fire due to 10mm leak of Acrylonitrile carrying pipeline at weather condition 2.0/C.

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D 6-2: Risk Contour of Late Pool Fire due to 20mm leak of Acrylonitrile carrying pipeline at weather condition 4.0/D.

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D 6-3: Risk Contour of Late Pool Fire due to 50mm leak of Acrylonitrile carrying pipeline at weather condition 1.5/B.

Release of Styrene into Environment

It is expected that Styrene would have two storage tanks for Styrene having a capacity of 680 KL. INEOS ABS is storing maximum 1360 KL of styrene at a time.

The consequence scenarios considered are loss of Styrene due to failure of the pipeline(10mm, 20mm, 50mm) connecting to the tank (20% cross sectional area failure and 100% failure cases have been considered) and full rupture of the Styrene storage tank, which is an extremely unlikely event.

The consequence distances for release of Styrene due to the various scenarios as discussed earlier are provided in Table 6-4. It is observed that:

Table 6-4: Radiation Level and Effect Distance Due to Release of Styrene

Failure Scenario Description Consequence Met Data

Effective Distance in meter to Radiation Level

1.6 kW/m2 4 kW/m2 12.5 kW/m2

37.5 kW/m2

10 mm leak from storage tank Jet fire

1.5/B 16.38 10.61 4.03 N.R.

2.0/C 16.88 10.98 3.91 N.R.

4.0/D 17.33 12.15 6.08 4.56

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Failure Scenario Description Consequence Met Data

Effective Distance in meter to Radiation Level

1.6 kW/m2 4 kW/m2 12.5 kW/m2

37.5 kW/m2

Early pool fire

1.5/B 28.72 21.18 14.85 9.00

2.0/C 29.11 21.75 15.67 9.51

4.0/D 32.12 25.49 19.83 13.27

Late pool fire

1.5/B 67.16 44.77 20.96 N.R.

2.0/C 68.65 47.13 22.01 N.R.

4.0/D 73.97 54.76 27.22 N.R.

20 mm leak from storage tank

Jet fire

1.5/B 23.66 18.96 10.88 N.R.

2.0/C 23.50 20.41 12.34 N.R.

4.0/D 25.26 23.35 14.56 9.18

Early pool fire

1.5/B 40.65 26.19 18.59 9.73

2.0/C 42.23 30.86 20.84 11.21

4.0/D 47.93 37.46 28.48 17.25

Late pool fire

1.5/B 73.36 47.78 21.54 N.R.

2.0/C 76.41 51.62 23.55 N.R.

4.0/D 84.94 63.16 30.70 N.R.

50 mm leak from storage tank

Jet fire

1.5/B 58.82 38.41 22.72 37.50

2.0/C 63.75 41.67 25.36 9.38

4.0/D 73.17 50.02 30.70 19.49

Early pool fire

1.5/B 59.01 40.14 19.70 -

2.0/C 61.64 43.63 22.65 -

4.0/D 68.69 51.86 30.64 -

Late pool fire

1.5/B 72.69 47.11 20.87 N.R.

2.0/C 76.37 51.57 23.51 N.R.

4.0/D 84.61 62.84 30.37 N.R.

20% Pipe Diameter Vertical

Jet fire

1.5/B 16.16 10.52 5.56 N.R.

2.0/C 18.44 12.35 7.40 N.R.

4.0/D 22.42 15.98 10.68 6.92

Early pool fire

1.5/B 45.32 30.62 15.66 6.75

2.0/C 46.16 31.76 17.14 6.91

4.0/D 47.92 33.91 21.20 7.52

Late pool fire 1.5/B 68.56 42.99 16.74 N.R.

2.0/C 70.52 45.72 17.65 N.R.

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Failure Scenario Description Consequence Met Data

Effective Distance in meter to Radiation Level

1.6 kW/m2 4 kW/m2 12.5 kW/m2

37.5 kW/m2

4.0/D 74.11 52.34 19.88 N.R.

100% Pipe Diameter Vertical

Jet fire

1.5/B 16.16 10.52 5.56 N.R.

2.0/C 18.44 12.35 7.40 N.R.

4.0/D 22.42 15.98 10.54 6.92

Early pool fire

1.5/B 45.32 30.62 15.66 6.75

2.0/C 46.16 31.76 17.14 6.91

4.0/D 47.92 33.91 21.20 7.52

Late pool fire

1.5/B 68.56 42.99 16.74 N.R.

2.0/C 70.52 45.72 17.65 N.R.

4.0/D 74.11 52.34 19.88 N.R.

Catastrophic Rupture of Tank Late pool fire

1.5/B 70.47 44.90 18.65 N.R.

2.0/C 73.22 48.42 20.36 N.R.

4.0/D 80.24 58.47 26.00 N.R.

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D 6-4: Risk Contour of Early Pool Fire due to 10mm leak of Styrene carrying pipeline at weather condition 4.0/D.

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D 6-5: Risk Contour of Early Pool Fire due to 20mm leak of Styrene carrying pipeline at weather condition 2.0/C.

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D 6-6: Risk Contour of Jet Fire due to 50mm leak of Styrene carrying pipeline at weather condition 1.5/B.

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D 6-7: Risk Contour of Early Pool Fire due to 20% leak of Styrene carrying pipeline at weather condition 4.0/D.

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D 6-8: Risk Contour of Early Pool Fire due to 100% leak of Styrene carrying pipeline at weather condition 4.0/D.

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7 DISASTER MANAGEMENT PLAN

7.1 Personnel Deployment

7.1.1 Plant Operations & Maintenance

Vice President (OPNS) will be overall in-charge of the plant operation with the following key personnel assisting him:

• Manager (Production)

• Manager (S&E)

• Sr. Executive (S&E)

• Manager ( P&A )

• Sr. Manager (Q A)

• Sr. Manager (Engineering)

Executive (Production) reporting to Production Manager will be in-charge of the plant during shift-hours with the following personnel assisting him:

• Plant Operators

• Technicians

• Fire Attendant

• Security Supervisor

• Emergency Squad Members

• Firs aid members

7.1.2 Plant Security

Plant security section will be headed by Security officer reporting to Manager (P&A) and will be assisted by security supervisors and guards under him. Apart from general security functions, the security supervisor will direct and control incoming traffic to the plant, check entry and exit of all personnel and vehicles, verify and issue entry passes to all visitors. Particularly they will ensure safe movement of tankers and exercise control over the respective drivers in observing plant safety rules including 'No smoking' rules. They will be in-charge of communication after the office hours. Supervisors are assisted by security guards.

7.1.3 Fire Fighting

Fire fighting activity will be supervised by Manager (Safety & Environment) who will be assisted by Executives (S & E), Fire attendants and Emergency Squad Members. Emergency Squad Members drawn from various departments will assist in fire fighting till the arrival of external fire brigade. Fire attendant will be responsible for maintaining fire fighting equipments and for imparting fire fighting training to the plant personnel, Fire Department will be under Production Executive after office hours.

In the plant, necessary fire fighting and personal protective equipments are kept in readiness. Emergency squad members are always available at the site who can rush to the emergency site in the shortest period of time. These volunteers are regularly trained to meet any emergency arising due to fire, explosion, spill or toxic release. They are identified by Blue colored helmets.

Name of Emergency Squad Members are displayed at security notice board in every shift.

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7.1.4 Medical Aid

It is ensured that the injured in the plant are promptly given first aid during plant emergency before they are shifted to hospital for medical attention depending on the requirement. Sufficient numbers of employees are trained in first aid technique and it is ensured that they are available round the clock. The Occupational Health Centre of the factory can be used for the medical treatment of the workers in normal working hours and at the time of any emergency. It has sufficient space capacity and sited in a safe place. All First aid trained employees are identified by Green colored helmets.

Name of First aid trained members are displayed at security notice board in every shift.

An ambulance is available at the site round the clock.

7.1.5 Support Services

Support Services such as administration, personnel, and commercial, materials etc. will be headed by the Managers of respective services and will be normally working in the general shift. Most of these persons can be contacted over telephone in case of necessity after office hours.

7.2 Emergency Contacts

The first person to be contacted immediately in an emergency by the Production Executive will be as follows:

1. Vice President (Operations)

2. Manager (Production)

3. Manager (Safety & Environment)

4. Sr. Executive (Safety & Environment)

5. Manager (P & A)

The above-designated persons will make all other necessary contacts and arrangements.

7.3 Local Government Emergency Assistance

In addition to resources in the INEOS ABS, local police and fire brigade resources from nearby industries may be called upon in the event of OFF SITE emergency. Injured persons shall be sent to Dr. Supeda Hospital, / Referral Hospital / ESI Hospital or if required, to the specialized hospitals in Baroda will also be available to treat the injured.

7.4 Safety and Mitigating Measures

7.4.1 Safety Consideration in the Design

INEOS ABS (India), Katol has an excellent safety record as Safety is given prime importance in all aspects. Safety considerations in the design of IABS SAN plant and other important mitigating measures provided to contain and control an emergency are outlined below:

General Safety Considerations;

• Adherence to international engineering standards in the design, construction and testing of the storage tanks, equipment and other hardware.

• Statutory approvals for hazardous storage, waste treatment and disposal, stack emissions etc.

• The various facilities in the complex are well laid out with storage tanks containing hazardous materials located away from the main process plant.

• Underground storage facility for Toluene to minimize the risk.

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• Hazardous waste incineration system is provided to incinerate hazardous waste generated in the plant as well as from Nandesari plant.

• 100% Emergency power back up from DG set so that plant can be operated safely even during GEB power failure.

• Full fledged, TAC approved Fire Protection system.

7.4.2 Equipment and Process Safety

• All storage tanks are located in dykes, and equipped with high and low level alarm, flame arrestor, breather valve and foam injection wherever required.

• All equipment are protected against overpressure by pressure relief systems.

• Remote operated isolation valves are provided on suction lines of Styrene and Acrylonitrile pumps so as to isolate the storage tanks immediately in case of any eventuality.

• Remote operated emergency solvent system to control run away reaction, in all four reactors.

• Acrylonitrile and Styrene unloading is done with canned pumps with no mechanical seal arrangement. So chances of leakage are reduced considerably.

• There is provision for collecting the spillage and leaks from the storage tanks and transferring out for treatment and safe disposal.

• 15 on line gas detectors and 36 smoke detectors are provided in the plant and buildings respectively to help operating staff for early detection of Gas leak or Fire. Indications for the same have been provided in the control room and security office. .

• Multiwarn- II (For measuring % LEL, Toxic gases and Oxygen) is used to measure the concentration of gases in plant area before Hot work as well as for issuing Entry permits. MSA make explosimeter is also used for % LEL measurement before Hot work while Gas tech tubes are used for work environment monitoring.

• Elaborate dust control system is provided.

• The plant process control is by Distributed Control System (DCS). The DCS system is backed up by “Uninterrupted Power Supply System (UPS)” to enable safe plant operation even during total power failure.

• Fail-safe control valves to enable them to go to either open or close position on air failure, which ever is safe from operational point of view.

• All electrical equipments in hazardous area are flame proof.

• The pipelines are color coded in plant for identification.

• All safety valves discharge is directed to a separate stack with scrubber through knock out drum.

• Jump over on flange joints of all hydrocarbon and pellet carrying lines are provided.

• Brass rods with earthings are installed in Styrene and ACN T/F to dissipate static charge from person before entering in dyke area.

• All rotating machineries equipped with full proof guards

7.4.3 Fire Protection & Fire Fighting Facilities

The Plant is equipped with a comprehensive fire protection system. Following facilities have been provided for the fire fighting:

• Fire Water Supply

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• Hydrants & Monitors

• Foam Injection for Storage Tanks

• Portable Fire Extinguishers

Firewater System includes firewater storage reservoirs (2X 580 M3), fire pumps (diesel and electric), jockey pump, fire water piping network, fire hydrants (30 single hydrants, 5 double hydrants, 15 FEH.), water monitors (12nos.) and hose and foam-makers. Trolley mounted / wheeled foam monitors and fire extinguishers are also available at site. Medium Velocity water spray system installed on ST/ACN storage tanks.

Pump Specification

Type of Pump Quantity Capacity m3/ hr Head mwc

Main pump (Electrical driven) 1 273 70

Diesel Driven Pump (Standby) 1 273 70

Jockey Pump(Electrical driven ) 1 11.8 72

• In case of total power failure or during electrical fire, the stand-by diesel driven firewater pump can be used. Fire hydrant header is running throughout the plant and hydrant points are located as per the requirement. Furthermore, DCP, Foam and CO2 type portable fire extinguishers are available in requisite nos. all over the plant at the site.

Fire Extinguishers Details

Type of Extinguishers Capacity Kg Quantity

DCP 25 4

DCP 10 76

CO2 6.8 26

CO2 6.5 9

CO2 4.5 4

CO2 2 6

Foam 9 12

• A round the clock ambulance and first aid facility by trained personnel are available at the site.

• Onsite emergency plan is prepared and responsibility is given to trained key / functional personnel.

• Gastec tubes are used for Work Environment Monitoring.

List of Safety Instruments

Sr. No. Type Quantity

1. Multiwarn II for LEL, Toxic, and O2 Measurement. 1

2. Explosimeter, Make: MSA (Model 2A) 1

3. Gastec Detector Tubes & Pump, Make: Gastec 1

4. Static meter 1

Seven Self-contained breathing apparatus sets with two extra Air cylinders are available with safety dept.

Four airline respirators are readily available in plant area

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Two Ambo bags for artificial respiration are available in

1. Occupational Health Centre

2. M.C.C. Room

Other safety appliances are always available in required quantity.

One Fire proximity Suit for Entry in fire Area.

7.5 Communication System

Communication is the life line of handling an emergency. When an emergency occurs it is necessary to blow the siren immediately, to declare an emergency, to inform the works emergency controllers, to inform the plant emergency services and affected areas within the plant as well as outside if necessary.

Therefore, the following facilities are also provided in the plant for an effective two way communication:

1. Intercoms and two-way Paging System for normal and emergency in-plant communication.

In case of any emergency, always use phone no. 731 to inform in control room

2. Manual call points at strategic locations are provided for quick communication in case of Fire...

3. External Telephone for emergency contacts with Works emergency controllers, fire brigades, hospitals, and police and for all other contacts including District Authorities, Government Agencies, neighboring Industries etc. provided.

When the external telephones are not working, an emergency plant vehicle with a runner / messenger could also be used for outside communication. Communication to the neighboring public, if necessary, should be through police and their wireless van.

Different patterns of siren sounded for declaring various types and stages of emergency and for declaring ‘ALL CLEAR’ situation is depicted below. The alarm system should be checked periodically to test the efficiency and its interpretation by all concerned.

There are two sirens provided in the complex, which can be operated from the Security Office during any emergency. Each siren has a range of 2 miles and is operated with breaking sound after 15 secs. These sirens are blown at 9:00 hrs and 17:00 hrs. Regularly.

7.5.1 Emergency Siren Tone

ON HEARING EMERGENCY SIREN

• Non-essential personnel shall follow safe route for evacuation

• Key personnel shall report to emergency control center

EMERGENCY SIREN

EMERGENCY SIREN (EXPLOSION FIRE, TOXIC FLUID RELEASE ETC) :

4 BLOW OF 15 SEC EACH

SIREN:

ON:15 SECS ON:15 SECS ON:15 SECS ON:15 SECS

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ALL CLEAR : CONTINUOUS SIREN FORTWO AND HALF MINUTES

SIREN : FOR TWO & HALF MNUTES

TESTING: CONTINUOUS SOUND FOR 15 SECS. ONLY ONCE.

SIREN :

ON:15 SECS ONLY

7.6 Emergency Response Plan

Emergency Response Plan is a pre-requisite for managing an emergency since it designates persons authorized to take control of the emergency and to direct emergency operations.

Essential elements of an emergency response plan are the following:

• Constitution of an emergency response team with specific responsibilities and establishing the chain of command.

• Communication of an emergency, alerting and activating emergency services.

• Taking control of the emergency and putting into action emergency procedures.

• Informing concerned authorities, agencies and public bodies about the occurrence of the emergency.

7.6.1 Emergency Control Centre

The emergency control centre is necessary for directing all emergency operations and should be located in a position of minimum risk and should be easily accessible.

The centre should also have telephone links with inside and outside the plant. In the present case, the Safety office is designated as the Emergency Control Centre (ECC) of the plant. It is the place from which the operations to the emergency are directed and co-ordinate. The site main controller, key personnel and senior officers of the company will attend it. Moreover the administration office can also be used as an alternate emergency control centre if required. ECC is sited in an area of minimum risk and close to a state highway to allow for ready access. In addition to good communication facilities, the emergency control centre is required to keep the following information handy and up-to date:

• Names, Addresses of all personnel present in each shift of the plant.

• Important telephone numbers and addresses of plant and outside personnel, which may be required in an emergency.

• Latest hazardous material inventories in the storage tanks.

• Emergency equipments out of service.

• Display of likely hazardous scenarios and affected areas of the plant, assembly points, escape routes etc.

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7.6.2 Emergency Response Team

Incident Informer

An Incident Informer is a person who on noticing an abnormal or hazardous situation in the plant immediately communicates the same to the Shift-in-charge/Executive (Production) in the Control Room. The Shift-in-charge/Executive (Production) on receiving the information immediately contacts the Incident Controller. There may be situations when Shift-in-charge/ Executive (Production) himself anticipates an emergency from the control room itself from the control system (DCS) and alarms.

Incident Controller (IC)

• Manager (Production)

• Shift in charge / Executive (Production) present in shift

Incident Controller is the designated authority responsible for assessing and declaring an emergency, and in directing emergency operations in the affected area of the plant. He is fully familiar with the plant facilities, its operations and personnel. Till his arrival at the incident site, in-charge of the shift, acts on his behalf as an alternate and initiates necessary emergency actions, and there after assists him in implementing emergency procedures.

Site Main Controller (SMC)

• Vice President (Operations)

Alternate

• Manager (Production)

The Site Main Controller is the designated authority heading the Emergency Response Team and is also familiar with the plant and the personnel and is responsible for assessing and declaring the emergency as well as for calling off the emergency.

On being informed about the OFF SITE emergency in the plant, he proceeds to the Emergency Control Centre and on arrival at the plant, assumes overall control of the emergency. Till his arrival, the Incident Controller acts on his behalf.

Based on the magnitude of the emergency, the Site Main Controller in consultation with the Incident Controller may call any or all of the following members of the team to report to him for further assistance.

Emergency Services (Taken from Key Personnel list)

1. Manager (Safety & Environment)

2. Sr. Executive (Safety & Environment)

3. Manager (P&A)

4. Security Officer

5. Executive (P&A)

Support Services

1. Sr. Manager (Engineering –Mechanical)

2. Executive (Electrical)

3. Dy. Manager (Instrument)

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7.7 Responsibilities of Emergency Personnel

7.7.1 Site Main Controller (SMC)

• Site Main Controller relieves the Incident Controller of the responsibilities of overall emergency control as soon as he arrives in the plant and takes stock of the situation and thereafter will position himself in the Emergency Control Centre and give directions from there.

• Exercises direct control over areas of the plant which are affected by the incident and constantly reviews the situation in the affected area with the Incident Controller.

• Assesses the magnitude of the incident and decides to call additional personnel and to shutdown the total operations in the plant including loading or unloading operations depending on the nature of emergency.

• Ensures that medical aid is promptly provided to the casualties and their relatives are informed.

• Organizes evacuation and transportation of personnel from the assembly points to a safe location in or outside the plant.

• If external help is needed, co-ordinates for outside emergency services, like Kalol Fire Bridge (Ph. No o2676-235101).

• Initiates the Off-Site Emergency Plan, if outside area and neighboring habitants are likely to get affected.

Ensures that affected personnel are transported to external medical centers, if required and keep constant liaison with these medical centers during the course of the emergency through the medical officer.

Keeps Corporate Office and concerned Government Agencies informed of the emergency and if necessary arranges information to the outside habitants through police.

7.7.2 Incident Controller (IC)

Incident Controller on reaching the site of the incident relieves the Shift-in-charge of the responsibilities of directing the emergency operations and assumes total control of emergency operations in the affected area.

Assesses the magnitude of the incident and decides to call any Emergency. Determines the adequacy of the emergency services.

Directs emergency operations from the incident site to localize emergency, keeping in mind the priorities for safety of personnel, least damage to the property and environment and minimum loss of materials.

Ensures that all non-essential personnel of the affected area are evacuated to the appropriate assembly points for evacuation to a safer place.

Provide advice and information to the Fire and Security Personnel and Local Fire Service as and when they are called.

Removes the casualties to the Occupational Health Centre. Establishes contact and maintains communications with the Emergency Control Centre.

Ensures that key personnel have been called in, if need be and provides advice and information as required, to the emergency services.

Continuously reviews the situation with the Site Main Controller.

Essential Services

When summoned by the Site Main Controller.

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7.7.3 Manager (Safety & Environment)

Proceeds to the Fire Station, establishes contact with firemen and Incident Controller and supplements efforts in Fire fighting.

Assists in searching for casualties and their removal to the Occupational Health Centre.

Organize outside assistance in fire fighting and rescue operations if required.

Mobilizes personal protective equipment and safety appliances and assists personnel handling emergency in using them.

Assists trained first-aid members in providing first aid to those who are injured.

Carries out necessary formalities in the fatal cases and keeps Site Main Controller informed about the casualties.

Keeps a check on any new development of unsafe situation and report the same to the Incident Controller.

Collects and preserves evidence to facilitate future inquiry.

Informs SMC / IC on the matters related to statutory obligations.

7.7.4 Security Supervisor

Assumes total control of the storage facility under the directions of the Site Main Controller.

Controls traffic movement, removes truck and tanker drivers outside the plant and prevents entry of all non-essential personnel.

Cordons off the incident site and keeps the site clear of by standers.

Assist in the evacuation of personnel, if necessary to the assembly points or safe areas.

Support Services:

When summoned by the Site Main Controller, the support services will be provided by

1. Sr. Manager (Engineering)

2. Executive (Electrical)

3. Dy. Manager (Instrument)

Assumes charge for the smooth operations of all emergency equipment and systems.

Sr. Manager (Engineering) takes charge of shift maintenance technicians and assigns them emergency repair work in consultation with Incident Controller.

Sr. Manager (Engineering) organizes external engineering services such as crane services, if required.

Executive (Electrical) co-ordinates with GEB in case of any failure or damage to the HT electrical system.

7.7.5 Manager (P & A)

Assumes charge of all external communication in consultation with Site Main Controller.

Takes charge of EPABX Board and deputes a trained person (e.g. security guard or office assistant) to man the board when regular telephone operator is off duty and restricts the unnecessary calls.

Deputes a runner / messenger, if established communication fails.

Prepares case papers for those who are required to be admitted in a hospital. Organizes ambulance service to transport them to the hospitals and contacts designated hospitals and nursing homes informing

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them about the emergency and alerts them to be prepared to admit the injured, arranges blood donors of various blood groups to assist hospitals in procuring blood.

Collects information on roll-call from the assembly points.

In case of prolonged emergency, arranges for relief of personnel and their catering needs.

Establishes contacts with the families of injured personnel.

Co-ordinates with Corporate Office and issues press or public statements if required.

Receives and meets important visitors and Government Officials.

7.8 Emergency Evacuation

When an emergency occurs, it is necessary to evacuate personnel from the affected area of the plant who are not directly involved in the emergency operation. Depending upon the magnitude of the emergency, sometimes it is desirable to evacuate personnel from the adjacent area also if there is a possibility of the incident escalating affecting the area.

The necessity for evacuation in the plant may arise due to fire or toxic release of acrylonitrile in the affected area, which would also extend to the adjacent area.

For the purpose of evacuating personnel, safe assembly points are chosen and clearly marked. The assembly points are selected so as to eliminate the hazards to the extent possible. The location of the hazardous areas where an emergency could occur, plant roads, assembly points and escape routes are marked on overall Plot Plan.

There are two assembly points as below:

1. Front Site

• Assembly point near temple

2. Back site

• Assembly Point in new land near scrap yard.

On hearing the siren, all non-essential personnel should go to the safest assembly point depending upon wind direction and site of accident.

Emergency squad members equipped with protective gear evacuate injured and trapped personnel.

Head count is taken at the assembly points by personnel dept. and a list of personnel gathered shall be made.

Instructions are given to vehicle drivers on the route to be followed and safe place where the personnel are to be taken.

7.9 Emergency Procedures

Handling of emergency calls for critical planning and ensuring a state of readiness at all times. Proper handling of the actual emergency needs certain actions to be taken before the emergency to ensure that all systems are ready and the emergency can be handled smoothly. Similarly after an emergency rehabilitation and reconstruction programs are necessary. The actions to be taken before, during and after an emergency are described below:

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7.9.1 Actions to be taken before the Emergency

Employee Training

All employees are trained to respond to fires, spills, leaks, etc. If on-site personnel are at risk or otherwise unable to respond safely to an emergency situation, outside assistance shall be summoned. All employees shall receive annual training and / or refresher training during regularly scheduled safety and environmental meetings on the following:

• Emergency Response Plan

• Personal Protective Equipment

• First Aid

• Fire Fighting Equipment

• Fire and Gas Detection / Suppression Systems

• Hazard Communication

• Work Permit System

• Lockout / Tag out Procedures

• Confined Space Entry Procedures

• Spill Prevention and Control Procedures

• Static Electrical hazards

• Tank farm safety

• SHE Case study of INEOS.

• On the Job

Preventive Maintenance And Testing Of Emergency Response Equipment

• All protective equipment shall be cleaned and kept in good working order. Self Contained Breathing Apparatus equipment shall be periodically cleaned and checked as per manufacturer's guidelines. Acid suits, rubber boots and gloves, goggles, and face shields shall be cleaned and decontaminated, if necessary, after each use.

• Communications and monitoring equipment / alarms shall be tested regularly and be covered under the plant preventive maintenance program. Testing of alarm and monitoring systems varies depending on the specific requirements of equipment manufactures.

• All portable fire extinguishers shall be inspected regularly to ensure they are properly charged or filled and ready for use.

Emergency Drills

As required by the Indian Manufacture, Storage, and Import of Hazardous Chemical Rules (MSIHC 1989), mock drills shall be held every six months to practice emergency response techniques. This would avoid confusion and save valuable time which would result in reducing the extent of loss to plant / equipment and human resources.

Container Labeling

As required by the MSIHC Rules 1989, labeling of container / tank contents is required which of course will aid in the training and addressing accidents. Therefore, labels should be placed on all tanks indicating the contents therein. NFPA Hazard Labels are painted on STYRENE/ACN/DMAC storage tanks

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7.9.2 Actions to be taken during the Emergency

As described under section 4.0 the types of scenarios that may lead to emergency situations in the plant are:

• Release of toxic chemicals

• Pool fire of flammable liquids

Emergency Response to Spillage of Hazardous Material

A hydrocarbon leak can be detected using hydrocarbon detectors. As soon as a leak in piping or equipment handling hydrocarbons is noticed, the immediate action should be to evacuate the downwind area and make efforts to isolate the source of supply.

Personnel performing such emergency operations should wear all personal protective equipment and use Self Contained Breathing Apparatus wherever required.

Immediately on report of heavy leak, the Incident Controller should take following actions.

1. Instruct to stop all open flames to avoid possible vapour cloud explosion.

2. Stop unloading of the road tankers.

3. Declare the EMERGENCY

4. Evacuate the downwind area and restrict entry.

5. If the situation can lead to off-site implications, inform to the nearby inhabitants and industries.

6. Only persons required for combating the leakage should be allowed to enter the area.

7. Instruct to isolate the source of leak as quickly as possible and arrange for safe shutdown of the plant if required.

8. If emergency situation permits, attempt repair using necessary precautions.

9. Use personal protective equipments such as self-contained breathing apparatus, on line air breathing apparatus or gas mask with canister along with other non-respiratory equipments while entering the leakage zone.

10. Leakages point should be preferably approached from higher elevation and upwind direction.

11. Saw dust or commercial sorbent can be used to absorb bulk liquid spillages.

12. Flush spill area with large quantity of water. Do not use hot water.

13. In case of containment of liquid in sump, reduce toxic and fire hazard with foam.

14. A large spill of any material has to be collected in drums and burn safely in incinerator.

15. Use water spray to disperse the vapors and to provide protection for the men attempting to stop the leak.

16. Verify the following information on a Spill Report Form:

• Time of spill,

• Material spilled,

• Cause of spill,

• Estimated quantity of the spill,

• Location of spill, and

• Personnel injuries (if any).

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17. Perform all other responsibilities as per the Emergency Response Plan.

Emergency Response to a Storage Tank Fire

Following possible approach may be used to handle an emergency situation involving a tank fire:

• Assess the situation and gather required information on the accident including suspected casualties, rescue operations required, materials involved, tank details, weather conditions and resources available.

• Consider possible alternatives to bring the situations under control and make decisions with reference to line of action i.e. whether to attempt to extinguish the fire or only to control its spread, requirement of emergency response personnel or not etc.

• Take appropriate response actions :

a. Isolate the area and remove all nonessential personnel.

b. Evacuate the area downwind of the fire or possible vapour clouds.

c. If remote isolation of the vessel is possible, provide for doing so, to avoid flammable vapour cloud formation.

d. Attempt to extinguish the fire using the appropriate extinguishing agents and methods.

e. Approach to fire from upwind. The personnel involved should wear appropriate protective equipment.

f. Cool the vessel involved in fire and adjacent vessel with water using all available means to prevent spread of the fire.

g. Prevent the overflowing of fire water from dykes and other containment systems.

7.9.3 Actions to be taken after the Emergency

After decision has been made by Site Main Controller to call off the emergency, following necessary actions are recommended:

• Analysis of the incident. Conduct a follow-up audit to develop safeguards to prevent recurrence. Modify Emergency plan as necessary.

• Rehabilitation of plant and off-site personnel.

• Repairing the plant machinery and reconstruction of structure.

A spokesperson from the INEOS ABS shall be made available to talk with the press and public during and after the emergency.

7.10 Emergency Response Plan for Nucleonic

7.10.1 Introduction

The action prescribed in this plan should be implemented in the case of occurrence of an emergency involving a nucleonic device. The criteria for declaring and for terminating an emergency as stipulated in this plan should be adhered to, In case of any doubt, Chairman, Emergency Response Committee (ERC). V.P. Operation or his alternate R.S.O. and Dy. manager (Instrument)) Should be contacted.

Members of the Emergency Response Committee.

• Chairman

• R.S.O.

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• Members

Emergency Situations

The Occurrence of one or more of the following situations may be considered as an emergency.

• Receipt of a nucleonic device from the supplier in damaged conditions.

• Loss or theft of or damage to the nucleonic device due to accidents (e.g. fire, explosion) during storage before installation/ servicing /maintenance.

• Loss of theft of or damage to the nucleonic device due to accidents (e.g. fall from a height, fire explosion) after installation.

• Failure of shutter during operation/ servicing /maintenance.

• Loss or theft of or damage to the nucleonic device due to accidents (e.g. fire, explosion) during storage after decommissioning pending disposal

• Disposal of the nucleonic device as scrap

• Loss or theft of or damage to the nucleonic device due to accidents during transport of the nucleonic devices for reinstallation / disposal.

• Any other of normal situation with a potential to result in exposure of individual to radiation.

• Any one noticing any of the above instances should immediately bring the matter to the notice of shift In charge, R.S.O. or Chairman, Emergency Response committee. Above mention people can declare an emergency.

7.10.2 Action Plan

The following action plans can be initiated as the case may be.

RSO

• Contact the carrier as well as supplier and check how the device was damaged, if received device found damaged.

• Inform Chairman or his alternate.

• In case of theft or loss, inform the security dept.

• In case of fire or explosion contact fire dept. for help.

• Inform, AERB, Niyamak Bhavan, Anushaktingar Mumbai 400 094 and the seller of the device.

• Measure the radiation level around the device and record the observations, if the measured levels are in excess of the prescribed limits then cordon the area for employees and report the matter to chairman ERC and to AERB , Niyamak Bhavan, Anushaktingar Mumbai 400 094

• Arrange for temporary shielding in front of the shutter of gauge immediately if shutter is not working properly.

• Arrange for adequate security for the device in an exclusive storage room during storage of the device.

• Act as advised by AERB Niyamak Bhavan Anushaktingar, Mumbai 400 094 .

• If the device is examined by the supplier and thereupon declared safe for installation and operation advise Chairman, ERC to terminate the emergency.

• Inform AERB Niyamak Bhavan Anushaktinagar Mumbai 400 094.

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Security Officer

• Ensure that adequate security is provided to the device until the emergency is terminated.

• Inform the police in the event of suspected theft or during disposal.

Fire officer

• Rescue the injured if any

• Fight fire if there is a fire accident.

• Segregate the nucleic device under the supervision of the RSO.

Telecommunication operator

• Keep in touch all the emergency response personnel.

• Reserve the phone lines for emergency.

• Act as directed by Chairman ERC.

Manager P & A

• If it is required to transfer injured persons out of the company premises, arrange for the necessary transportation

Medical Officer

• If any person is injured or undergoes trauma, provide the necessary medical attention.

Chairman ERC.

• Verify the information provided regarding abnormal situation before declaring emergency.

• Convene a meeting of the ERC as well as monitor the rescue activities.

• Direct the security officer to provide security to the device.

• Intimate to AERB Niyamak Bhavan Anushaktinagar, Mumbai 400 094 regarding the emergency.

• Upon ensuring that the device has been safely removed from the premises or that it is safe for installation and use or to dispose it, terminate the emergency.

• Intimate AERB, Niyamak Bhavan Amishaktinagar, Mumbai 400 094 regarding the termination of the emergency.

Table 7-1: Persons to be contacted in the event of an Emergency

Name Designation Mobile Number

Address Telephone No.

Office Residence Office Residence

Mr. S. P. Agrawal

Head, Radiological safety division, AERB, Mumbai

Niyamak bhavan,Anushakti nagar, Mumbai

Mumbai 022-25990655, 25990670

---

Mr. N. V. Duggal

V.P. ( Operations)

9825146716 Katol, Dist. Panchmahal

Vadodara 02676 238990

0265-2390011

Vikash P Suthar

Dy. Manager 9909904185 Katol, Dist. Panchmahal

Halol 02676 238990

---

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Parvez Bata Manager 9909029148 Katol, Dist. Panchmahal

Baroda 02676 238990

0261- 2571984

P. S. Shah Executive 1733 Kalol 02676 238990

7.10.3 Emergency Exercise

Emergency exercises should be conducted at least once every year. The exercise should include following elements.

• A realistic emergency scenario should be simulated.

• The ERC should convene a meeting and decide act as if it were a real emergency.

• Emergency should be declared.

• All action plans as prescribed in the emergency response manual should be implemented.

• All the communication channels and emergency response personnel should be activated.

• The emergency should terminated as per criteria

• The exercise should be assessed by a team of individuals who are not members of the ERC.

• A review of the exercise should be conducted.

• The lessons leant from the exercise should be judiciously incorporated in the emergency response manual.

7.11 Safety Practices Implemented At Site for Acrylonitile

7.11.1 Storage and Handling of Acrylonitrile

• General Precautions: Avoid breathing of or contact with this material. Only use in well ventilated areas. Wash thoroughly after handling.

• Use the information in this data sheet as input to a risk assessment of local circumstances to help determine appropriate controls for safe handling, storage and disposal of this material.

• Handling: Keep away from heat. Keep away from sources of ignition. Ground all equipment containing material. Do not ingest. Do not breathe gas/fumes/ vapor/spray. Wear suitable protective clothing. In case of insufficient ventilation, wear suitable respiratory equipment. If ingested, seek medical advice immediately and show the container or the label. Avoid contact with skin and eyes. Keep away from incompatibles such as oxidizing agents, metals, acids, alkalis.

• Storage : Light Sensitive. Store in light-resistant containers. Store in a segregated and approved area. Keep container in a cool, well-ventilated area. Keep container tightly closed and sealed until ready for use. Avoid all possible sources of ignition (spark or flame).

7.11.2 Location of Storage Tank of Acrylonitrile

• The design of the tank farm has taken account of the likely consequences of any accidental spillage or fire. Products which react chemically with Acrylonitrile are kept in totally segregated storage.

• Storage tank is located at ground level and in the open air so that should a leak occur, it is more likely to be detected and any vapour emissions will be dispersed by natural ventilation.

• Storage tank is located in a well ventilated position away from potential sources of ignition or so as to minimise the effect of radiation from any fire which could possibly occur in any adjacent area.

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• Tank is surrounded by a bund wall capable of containing 110 % of the capacity of the tank within the bund. The walls and floor of the bund is impervious to liquid and designed to withstand a full hydrostatic head. Bund walls are not be higher than 1.5 meters to ensure adequate natural ventilation of the bundled areas, ready access for fire fighting, and good means of escape in any emergency situation.

• The floor of the bund is sloped to prevent minor spillages remaining below tank. Provision is made for the removal or drainage of surface water from the area within the bund. Bunds are provided with valves outside the bund walls, with procedures in force to ensure these valves remain closed, and preferably locked, except when draining are being removed. Acrylonitrile contaminated draining must be collected in drums and incinerated.

• No combustible material or full or empty drums should be stored in the bund or against the bund wall.

7.11.3 Tank Construction

• The storage tank is of adequate strength and capacity for the proposed duty. It is sited on an impervious base and surrounded by a bund of adequate size and strength. The tank and its supports are designed and constructed in accordance with an appropriate nationally recognized standard of good engineering practice.

• Storage tank is compatible with shipping and receiving requirements. Storage times in excess of six months are avoided to minimize degradation of Acrylonitrile quality.

• The material of construction is carbon steel .

• Tanks are cleaned, physical means, before initial use to remove rust.

• The use of a multi-compartmented tank is not recommended because of the risk of product contamination or heating from adjacent compartments.

• Acrylonitrile storage tank do not require insulation or refrigeration.

• White paint should be considered for storage tank exterior surface, to minimise temperature rise.

• A manhole of minimum 500 mm dia is provided on all tanks to allow for internal inspection and cleaning.

• An earthing point is fitted on the tank and connected to a quality earthing pit

• Acrylonitrile is stored under a nitrogen blanket in order to avoid explosive vapour mixtures.

• Acrylonitrile is handled in closed system. This can be achieved by using a vapour return line when loading or unloading. If unloading is done by nitrogen pressure, the displaced vapours in the tank should then be routed to a vapour treatment unit.

• A pressure/vacuum relief valve is provided at the top of the tank.

• The vent shall terminate in a safe place away from sources of ignition and from occupied areas, passageways or sheltered space where vapour could accumulate. Free circulation of air around this vent is essential to disperse vapours.

7.11.4 Level and Temperature Measurement

• Storage tank is provided with a suitable means of determining both the liquid level and temperature in the tank, without the necessity of opening a gauge hatch, which would involve personnel exposure to acrylonitrile.

• A high level switch is installed to prevent overfilling.

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7.11.5 Pipe work

• Pipelines should normally be of the same material as the tank.

• A tank discharge line should be provided which should be a minimum of 50 mm nominal bore. The line may be taken from the bottom or side of the tank and should be fitted with an isolating valve as close to the tank wall as possible. In all cases discharge should be by pump. The pump and controls must be sited outside the bund.

• A facility is provided for draining the tank. This is fitted on the lowest point on the tank and fitted with a suitable isolation valve and blanked off when not in use.

• Wherever possible, continuously welded pipe work should be used. However, where pipe work may have to be disconnected for maintenance or inspection, flange joints should be fitted. Flanges should conform to recognised national Standards and Codes. Spiral wound gaskets with graphite filling are recommended. Screwed fittings should not be used except for stainless steel instrumentation.

• Pipe work should be routed to ensure that joints are not located over doorways, windows or close to possible sources of ignition and to minimise the possibility of accidental damage.

• Fixed, dedicated loading/unloading arms are recommended. If hoses are used for loading or unloading operations, they must be acrylonitrile -resistant lined armoured austenitic stainless steel flex hose or equivalent.

• Hoses must be inspected for wear or damage frequently and replaced as necessary. It is recommended that a hose testing programme is to be prepared and implemented. .

• Hoses should be tested at least once every year. The test should comprise an hydraulic pressure test at 1.5 x the working pressure, an electrical continuity test and a visual inspection. Hoses should be properly marked.

7.11.6 Pumps

• Pumps must be located outside tank bunds, on an impervious base, in an open space, and not in walled or confined spaces. Centrifugal pumps are normally used for acrylonitrile.

• Double mechanical seals or hermetic closed pumps (magnetic drive) may be used although the latter is preferred. The first one must be equipped with a water flush facility or nitrogen barrier fluid for environmental considerations.

• Pumps should be constructed either of cast steel or stainless steel. Plastic pumps should not be used.

• Pumps may be driven pneumatically, hydraulically or electrically. Where electric motors are used to drive the pump, they should be flameproof.

• If pumps are remotely controlled, then a stop button must be provided at the pump and at the delivery point.

• The capacity of pumps should be such that the linear velocity of the liquid being pumped does not exceed 7 m per second in the pipelines.

• It should be noted that if centrifugal pumps are used, flow under gravity may occur when the pump is stopped hence proper NRV’s are to be provided at pump discharge.

• In order to avoid accidental creation of a vacuum (e.g. when vapour return line is blocked or nitrogen feed interrupted), a pressure switch in the suction of the pump is recommended to stops the pump when the pressure in the line drops below atmospherical pressure.

7.11.7 Valves

• Valves should be fitted directly on all bottom outlets of a tank unless these branches are blanked off.

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• Isolating valves may be ball or gate valves with PTFE seats. However local/national regulations might forbid PTFE in valves because of its low melting point. Angle or globe valves are also acceptable on acrylonitrile service.

• Diaphragm valves must not be used with acrylonitrile.

• Valve bonnets gaskets may be soft iron, spiral wound or equivalent.

7.11.8 Fire Protection Consideration

• Provision should be made to apply an 'alcohol' type foam to storage tanks, in the event of a tank fire. Foams may be applied onto the liquid surface via an external foam 'riser' or via internal foam distributors.

• Water is not an effective fire extinguishing agent for acrylonitrile although it may be used as a cooling agent on adjacent equipment. External water coolant sprinkler systems should be installed where ambient temperatures can be high.

• Tanks should be provided with safety relief systems which on high pressure relieve the tank vapour contents to a safe location. A vent scrubbing and flare relief system is both appropriate methods of disposal.

• Flame arrestors should be installed in the case of a flare system with regular inspection to check for possible polymer build-up.

7.12 Safety Practices Implemented At Site for Styrene

7.12.1 Location of Storage Tanks

• The arrangement and lay out of storage tanks are taken into account :

a) normal operation

b) emergency operation

c) fire fighting activities

• The design of the tank farm is taken account of the likely consequences of any accidental spillage or fire. Products which react chemically with styrene, such as strong acids and oxidising agents, should be kept in totally segregated storage.

• Storage tanks are located away from potential sources of ignition, and in a position so as to minimise the effect of radiation from any fire which could possibly occur in an adjacent area. It is recommended that the tank outlet valve is remote-controlled and fire-retardant (good fire resistance).

• Storage tanks are discharged by pump. Tanks should not be elevated to allow gravity is charge, because of the difficulties of stopping gravity flow in the event of a fire.

• 2 tanks are erected on an impervious base and are surrounded by a bund wall capable of containing at least the capacity of the largest tank within the bund. The walls and floor of the bund should be impervious to liquid and designed to withstand a full hydrostatic head. Bund walls should be designed to ensure adequate natural ventilation of the bunded areas, ready access for fire fighting, and good means of escape in any emergency situation.

• It is recommended that the tank is located excentric inside the bund in order to improve the accessibility of the tank in case of a fire.

• The floor of the bund is sloped to prevent minor spillages remaining below any tank.

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• Provisions are made for the removal or drainage of surface water from the area within the bund. Bund drains are provided with valves outside the bund wall, with procedures in force to ensure these valves remain closed, except when drainings are being removed.

• No combustible materials, equipment, etc should be stored in the bund or against the bund wall.

7.12.2 Tank Construction

• The storage tanks are of adequate strength and capacity for the proposed duty. The tank and its supports should be designed and constructed in accordance with an appropriate nationally recognized standard of good engineering practice.

• The sizes of storage tanks are compatible with shipping and receiving requirements. Storage duration in excess of three to six months should be avoided to minimise degradation of styrene quality.

• Carbon steel storage tanks are used for styrene monomer. Vertical storage tanks are often used for large volume storage. Horizontal tanks are also satisfactory for bulk storage, but these are generally used for small installations.

• Tank linings can help to minimize polymer formation. Inorganic zinc silicate linings are recommended for storage tanks. If a tank lining is used, it is important to ensure that a satisfactory tank earthing arrangement is provided.

• The interiors of tanks for styrene should be as smooth as possible and contain an absolute minimum of supports, pipes and internal projections where polymer may collect and eventually fall back into the liquid. Therefore a self-supporting, dome-type roof is recommended for new vertical storage tanks.

• This type of construction simplifies the installation of linings and also permits uninhibited condensed vapours to return to the liquid monomer, thus reducing the polymer and stalactite problem.

• All the nozzles above the normal liquid level in the tank should be large in diameter and kept to a minimum.

• In hot climates, large tanks with low throughputs or turnover rate should be protected against direct sun heating (for example, by the use of reflecting paint, a sun protection roof or equivalent). In this case, insulation and / or a separate cooling unit with a styrene circulation system is recommended.

• If the styrene bulk storage system is not used for several days, the monomer should be recirculated through all parts of the system, to minimize polymer formation. Recirculation should be executed periodically, for example once per week, to avoid continuous heat input from the recirculation pump into the system.

• A manhole of minimum 500 mm diameter should be provided on all tanks to allow for internal inspection and cleaning.

• Design of new storage tanks shall be based on full draining concept, sloped to outlet with no trapped areas.

• It is normal practice to fit tanks which are storing highly flammable liquids with a pressure/vacuum relief valve (PVRV valve) to protect the tank against overpressure or vacuum conditions. During venting, potential flammable vapours may be released. To prevent flash back to the tank in the event of an external fire, it is recommended that the PVRV is fitted with an integral flame arrestor.

• In the case of styrene, PVRV's may stick due to styrene polymer formation and flame arrestors may become blocked with polymer. Therefore, for styrene, the advantage of fitting a PVRV valve has to be balanced against the risk of blockage, with the potential consequence of damage to the tank if liquid is removed from the tank whilst the vent is blocked. Some companies may prefer to fit PVRV valves whilst also introducing a stringent procedure for regular checking of the valve for signs

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of styrene polymer formation. Other companies may refer to fit tank vents with an atmospheric vent which terminates in a safe place, away from any source of ignition or from occupied areas.

• Each tank shall have a proper earthing system; resistance to earth to be checked according to national requirements, preferably at least once in a year.

7.12.3 Level and Temperature Measurement

• Storage tanks must be provided with a suitable means of determining the liquid level and should have temperature measurement in the tank.

• Float type dial reading level gauges are acceptable. However, for remote readings flange mounted differential pressure transmitters (electronic or pneumatic) are recommended.

• A safety facility, with a high-level audible alarm, automatically shutting down the discharge process in the event of overfill, is strongly recommended. In the absence of an automatic, fail safe, shutdown facility, procedures must be present which prevent tanks from being overfilled.

• All storage tanks should contain local temperature indicators and temperature sensors for remote readings. It is recommended that level and temperature recording equipment is provided in the control room. The connections for pressure and level measurements should be designed in such a way as to prevent blocking by polymer.

7.12.4 Pipelines

• All pipelines shall be adequately grounded, to discharge static electricity safely.

• The tank discharge line shall be designed according to the maximum flow restriction. The line will be taken from the side of the tank and should be fitted with an isolating valve as close to the tank wall as possible. In all cases discharge should be by pump.

• To facilitate thorough mixing in the storage tank when new styrene monomer is added, the inlet line should always be at the opposite side of the tank to the outlet line. If the inlet line enters the top of the tank then it must extend to a point close to the tank bottom, to prevent splash filling and the formation of static electricity.

• It is recommended that all gaskets used in handling of styrene are made of graphite, viton ®, fluoro-elastomer, PTFE, or equivalent.

• A sump in the tank bottom should be provided for draining the tank. This should be fitted to the lowest point on the tank, provided with a suitable isolation valve and blanked off when not in use.

• Location of the manhole opposite the sump will facilitate high pressure water cleaning from the manhole.

• Wherever possible, continuous welded pipelines should be used. However, where pipelines have to be disconnected for maintenance or inspection, flange joints should be fitted. Screwed fittings should not be used except for stainless steel instrumentation lines.

• Pipelines should be routed to ensure that flanges are not located over doorways, windows or close to possible sources of ignition and to minimize the possibility of accidental damage.

• Fixed, dedicated loading/unloading arms are recommended. If hoses are used for loading or unloading operations, they should be made of suitable materials, e.g. stainless steel or fluoro elastomer.

• Hoses must be inspected and pressure tested on a regular basis. Records must be kept of inspection data.

• All tanks and pipeline connections must be clearly identified. Proper hose connection flanges and couplings are essential.

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• Pipelines should not be trace heated. In very warm climates, it is advisable to protect the pipelines from the effects of the sun by heat insulation.

7.12.5 Pumps

• Pumps should be located outside tank bunds, on an impervious base, in an open space, and not in walled or confined spaces.

• Centrifugal pumps with enclosed impellors and mechanical seals are most widely used in styrene service. However displacement pumps are also satisfactory.

• Pumps should be constructed of either cast steel or stainless steel. Copper, bronze or plastic should not be used.

• Pumps may be driven pneumatically, hydraulically or electrically. Where electric motors are used, they shall be explosion-proof.

• If pumps are remotely controlled, then a stop button should be provided at the pump and at the loading or delivery point.

• The design of pumps and pipelines should be such that the velocity of the liquid is limited, to prevent electrical charge build up.

• It should be noted that if centrifugal pumps are used, flow under gravity may occur when the pump is stopped.

• Deadheading of the pump should preferably be monitored by a temperature device, with a shut-down action.

7.12.6 Valves

• Valves should be fitted directly on all bottom outlets of a tank, unless these branches are blanked off.

7.12.7 Earthing Connection

• Earthing connections shall be provided at both sides of each bottom outlet nozzle, or in the centre of the chassis at both sides.

7.12.8 Electrical Considerations

• The selection, installation and maintenance of electrical equipment for use in hazardous areas should be based on an appropriate area classification system.

• It is good practice to control the proper functioning of the earthing by an indicator light. In addition, it is recommended to interlock the earth-proving with the loading / unloading pumps.

• Working areas, i.e., tank stairs, platforms, loading and unloading facilities should be adequately illuminated for emergency response and security reasons.

7.12.9 Fire Fighting Considerations

• A contingency plan shall be in place and tested in practice on a regular basis, at least once a year.

• Provisions should be made to apply foam injection to storage tanks, in the event of a tank fire. Water is not an effective fire extinguishing agent for styrene, although it may be used as cooling agent on adjacent equipment.

• External water coolant sprinkler systems should be installed on the tanks where ambient temperatures are high.

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7.12.10 Unloading Area

• There should be sufficient space for easy access of vehicles

• Unless it is connected to the unloading facilities, it should be possible for the vehicle to be removed from the unloading area in the case of an emergency

• Barriers, warning notices are required. Special consideration may need to be given to prevent shunting close to the unloading area

• Unloading arms are preferred to hoses

• The earthing point should be checked on a regular basis.

7.13 Personnel Protective Equipment Provided by INEOS ABS

Personnel Protective Equipment provided by INEOS ABS is given as follows

• PVC Acid alkali proof hand gloves

• Leather Hand gloves

• Cotton hand gloves

• Electric shock proof hand gloves

• Super nitrile hand gloves for AN

• Super nitrile suit for AN

• PVC acid alkali proof suit

• PVC acid alkali proof apron

• PVC acid alkali proof Gumboot

• Earmuff

• Ear Foam Plug

• Cotton Dust Mask

• Safety Goggles

• Safety Belt

• Canister Type Gas Mask

• Airline Gas Mask

• PVC acrylic Face Shield

• Safety Shoes

• Breathing Air Cylinder

• Nylon Rope Ladder

• BC 76 5 DIN Gas welding goggles

• BC 76 11 DIN Electrical welding goggles

• Helmet with Face shield

• Post mortem Rubber Gloves

• Safety Helmet Yellow

• Safety Helmet Blue

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• Organic vapour mask

• Safety Helmet

7.14 Occupational Health and Industrial Hygiene

There are many hazards involved in the production of SAN. Major occupational health and safety hazards anticipated are during handling of chemicals.

These substances are mainly in the form of:

• Emission of Toxic vapours

Other hazards involve the use of:

• Mechanical equipments

• Manual handling (Loading-unloading of raw materials and products)

7.14.1 Major Occupational Health and Safety hazards

• Falls on floors made slippery by aqueous solutions or solvents

• Electric shock caused by contact with faulty electrical equipment, cables, etc.

• Burns by splashes of chemicals, by steam or hot vapors, by contact with hot surfaces

• Chronic poisoning by inhalation or ingestion of Hazardous chemicals

• Exposure to adverse environmental factors (high temperature and humidity)

• Chemical exposure can occur when residue liquid, products, intermediates and sludge is removed from the equipment.

7.14.2 Provisions Proposed to Conform to Health/Safety Requirements

Provision for following matters need to be made:

• Checking packaging or container labels and material safety data sheets;

• Regular communication between workers, supervisors and employers about likely hazards; Regular training to all concerned people.

• Regular inspection of workplaces, plant and equipment;

• Regular review of tasks and procedures; and

• Checking of previous incident and injury records for recurring situations.

• Job risk analysis

• Enclosed systems for chemicals, relocation of employees or physical barriers

• Storing hazardous substances in a lockable, enclosed area with adequate ventilation

• Limiting access to chemical storage areas to authorized people only

• Ensuring all labels remain intact on containers and packaging

• Use of pumps and automated systems instead of manual handling

• Minimizing risk of items accidentally dropping into tanks, splashing operators

• Minimizing risk of items accidentally dropping into tanks, splashing operators.

• Double earthing for motors and regular testing of Earth pits

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• Earthing interlocks for tanker loading / unloading

• Gas detectors for leak detection and alarms

• Use of work permit systems, checklists and PPEs

7.14.3 Personnel Protective Equipment to the Workers

• Wear personnel protection, such as eye protection, gloves & chemical resistant clothing to avoid exposure of skin or eyes to corrosive solids, liquids, gases or vapors

• Safety shoes or boots with non-slip soles, and/or safety helmet etc

• Wear safety goggles in all cases where the eyes may be exposed to dust, flying particles, or splashes of harmful liquids

• Wear respirator when exposed to harmful dusts, gases or vapors.

7.14.4 Fire Protection and Safety Measures

There are chances of fire hazards due to using of hazardous chemicals in the production process, to avoid which following measures will be taken:

• Provision of fire extinguishers, fire hydrant systems, and fire alarm systems will be made.

• Earthling strips will be provided at all floors and equipments.

• Flame proof fittings / equipments will be used in flameproof area.

• Safety trainings will be imparted to the employee as well as contract employees.

• Safety work permit system will be followed.

7.15 List of Medical facilities and Equipment

7.15.1 First aid Facility

• 14 Numbers of persons trained in administering First Aid.

• 05 Numbers, first aid boxes in Company premises & 03 no. First Aid Boxes in our Company Vehicles.

Table 7-2: Location of First Aid Box

S. No. Location

1 Installed at Occupational Health Centre

2 Installed at Mechanical Workshop

3 Installed at Q.A. Laboratory

4 Installed at MCC Room

5 Installed at Company Ambulance Van ( GJ 17 V 92)

6 Installed in our SAN Tankers GJ 6 V 7447

7 Installed in our SAN Tankers GJ 6 U 8153

8 Installed in our SAN Tankers GJ 6 Z 8797

• 05 Numbers, eye washers and 11 nos. safety showers at different location in the plant.

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7.15.2 Mutual aids

• 05 Hospitals at Kalol and 08 Hospitals are nearly in 15 Kms radius.

• Referral Hospital, ESI Hospital, N.M.G. Trust Hospital, Dr. Supeda Surgical Hospital, & Sanjivani Hospital, – Kalol.

Table 7-3: Equipment at Occupational Health Centre

Item Quantity

Amboo’s Bag 01

Oxygen Cylinder Resuscitator (One each in Ambulance & O.H.C.)

02

Recovery Bed at O.H.C. 01

Stretchers ( One in Ambulance & Two at O.H.C. ) 03

Table 7-4: Antidotes at Occupational Health Centre

S. No. Name of Antidotes Quantity Use For

1 Cyanide Antidote Kit 02 Toxic exposure to Acrylonitrile

7.15.3 Emergency Vehicles Details

• Full flagged Ambulance No. GJ-17 V 92 is available for 24 hours in Company premises. .

• One commercial vehicle available for 24 hrs at Company premises.

7.15.4 Medical Check up

• Pre-employment Medical Check-up and Periodical medical check-up of all the employees and contract workers as per requirements of Factories Act and Gujarat Factories Rule by the help of Dr. D.K. Supeda, M.S. & C.I.H. & Dr. Rakesh Patel, M.B.B.S., D.I.H. The doctors conduct counseling with all the employees after completion of the Medical check up.

Medical Records

• Medical records are available in Occupational Health Centre for 24 hours.

Emergency Medical Preparedness:

• We are facilitated with all basic medical medicines and equipments to extend emergency medical services at workplace.

Visiting Doctor Services:

• Dr. D.K. Supeda, M.S. & C.I.H. visits the O.H.C. on twice a week bases to consult / discuss medical matters with the employees.

Health Awareness Programmes:

• The company periodically organizes in house health awareness programmes on various health related issues for the employees inviting internal and external faculties.

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Bio-Medical Waste Management System:

We have availed services of Samvedana B.M.W. Incinerator, Halol for collection, segregation and disposal of the Bio-medical waste generated at the premises. The body is GPCB approved.( Registration No.KL-1394 )

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8 RECOMMENDATIONS

Recommendations are made for different aspects of the project and are given in subsequent paragraphs. MSDS of Acrylonitrile, Toluene, Styrene are provided as Annexure 11 to 14 to the report.

8.1 Storage of Hazardous Chemicals in Bulk

• Attempt should be made to find suitable less hazardous alternate chemicals, to replace the hazardous chemical. The inventory of all hazardous chemicals for that matter must be kept as minimum as possible.

• The tanks should be located so as not to pose safety problems due to leakage and reaction with other chemicals stored nearby.

• The storage area should be declared as a prohibited area and should be provided with fencing having at least two exits / “No Smoking” and/or “Prohibited Area” display boards, as applicable should be provided at site.

• The storage tank and foundation should be of suitable material of construction to prevent corrosion.

• The connections and openings to the tank should be as less as possible so that the possibility of leakage and maintenance hazards is minimized.

• Each storage tank should have necessary instruments to monitor its level, pressure and temperature.

• The storage tanks / area should have suitable fire protection and fire fighting facility.

• The name of chemical, type of hazard, emergency operational instructions, antidote first aid etc. should be displayed near each tank.

• All cables and electric fittings shall be constructed, installed, protected, operated and maintained in such a manner so as to prevent risk of open sparking.

• Storage of Hazardous Chemicals in Drums and other Containers

• The drums should never be filled full with the liquid chemical. There should be sufficient space to take care of thermal expansion.

• The drums should preferably be stored in a well ventilated shed (preferably away from process units) with impermeable floor sloping away from drums.

• Periodic site inspection should be carried out to ensure that there is no leakage from any of the drums.

8.2 Unloading of Tank Trucks

• Before the tanker enters the industry premises, the tanker is to be inspected for authorized entry and safe & sound condition of the tanker, its contents and that of the prime mover. Tankers entering plant are to be fitted with flame arresters on their exhaust.

• The quality of the chemical in the tanker should be ascertained before unloading to avoid contamination of chemical already at storage.

• Coupling used for connecting hose to tanker must be leak proof.

• For flammable chemicals, the tanker and the hose are to be properly earthed before starting unloading operation.

• Unloading should be done under personal supervision of responsible staff authorized by the management.

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• Provision of sample quantity of water / neutralizing medium to take care of leakage / spillage must be made. Also steam and inert gas hose stations must be available at unloading point.

• Fire alarm and fire fighting facility commensurate with the chemical should be provided at the unloading point.

8.3 Hazardous Waste Transport

• The occupier of hazardous substance shall prepare six copies of the manifest (transporting documents) in Form 9 comprising of colour code indicated below (all six copies to be signed by the transporter):

• Copy 1 (white): to be forwarded by the occupier to the State Pollution Control Board or Committee

• Copy 2 (yellow): to be retained by the occupier after taking signature on it from the transporter and rest of the four copies to be carried by the transporter

• Copy 3 (pink): to be retained by the operator of the facility after signature

• Copy 4 (orange): to be returned to the transporter by the operator of facility after accepting waste

• Copy 5 (green): to be returned by the operator of the facility to State Pollution ControlBoard / Committee after treatment and disposal of wastes.

• Copy 6 (blue): to be returned by the operator of the facility to the occupier after treatment and disposal of wastes

• The occupier shall forward copy number 1 (white) to the State Pollution Control Board or Committee and in case the hazardous waste is likely to be transported through any transit State, the occupier shall prepare an additional copy each for such State and forward the same to the concerned State Pollution Control Board or Committee before he hands over the hazardous waste to the transporter.

• No transporter shall accept hazardous wastes from an occupier for transport unless it is accompanied by copy numbers 2 to 5 of the manifest. The transporter shall return copy number 2 (yellow) of the manifest signed with date to the occupier as token of receipt of the other four copies of the manifest and retain the remaining four copies to be carried and handed over to respective agencies as specified in sub-rule (4).

8.4 General Safety Practices

8.4.1 Work Permit System

• It is recommended that plot plans of the installation and the operating blocks should be displayed in the fire and concerned unit control rooms respectively and site of hot jobs under progress should be indicated on these plot plans with red pins.

• No hot/cold work shall be undertaken without a work permit except in the areas pre-determined and designated by the owner-in-charge.

• Permit should be issued only for a single shift and its validity should expire at the termination of the shift. However, where the work has to be continued, the same permit may be revalidated in the succeeding shift, by authorized person after satisfying the normal checks.

• Equipment or area where work is to be conducted should be inspected to ensure that it is safe to carry out the work and assess other safety requirements / stipulations.

• Unsafe conditions for performance of work may arise from surrounding area. It should be cleaned-up to remove flammable material such as oil, rags, grass etc.

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• Other activities (routine / non-routine) being carried out near-by which can create conditions unsafe for performance of the permit work, should be taken into consideration and the concerned persons should be alerted accordingly.

• Running water hose and portable fire extinguisher are required respectively to flush / dilution in case of release of any hazardous chemical or to quench sparks and to put out small fires immediately.

• In order to meet any contingency, it should be ensured that the fire water system including fire water pumps, storage, network etc. is checked and kept ready for immediate use

• Equipment / Vessel, on which the work permit is being issued, should be completely isolated from the rest of the plant with which it is connected during normal operation, in order to ensure that there is no change in the work environment with respect to presence of toxic / flammable gases, liquids, hazardous chemicals etc. in the course of the work.

• Equipment under pressure should be depressurized after isolation. This will be followed by draining / purging / water flushing etc. as the case may be.

• Proper means of exit is required in case of emergencies developed on account of the work or otherwise. Availability of an alternate route of escape should be considered.

8.4.2 Contractor Safety

• Duties & responsibilities of the contractor should include the following:

• To implement safe methods and practices, deploy appropriate machinery, tools & tackles, experienced supervisory personnel and skilled work force etc. required for execution.

• To prepare a comprehensive and documented plan for implementation, monitoring and reporting of Health, Safety and Environment (HSE) and implement the same after its approval.

• To nominate qualified & trained Safety Engineers / Officers reporting to the Site in charge, for supervision, co-ordination and, liaison for the implementation of the safety plan

• To arrange for fire protection equipment as per the advice of owner

• To ensure that its employees have completed appropriate health and safety training as required by the statute / regulation and also as per requirements of the Owner / Consultant

• To comply with all the security arrangements of owner.

• To ensure availability of First Aid boxes and First Aid trained attendant.

• To ensure that all incidents including near misses are reported to all concerned immediately.

• To ensure strict compliance with work permit system by carrying out work only with appropriate work permits and after ensuring that all safety precautions / conditions in the permit are complied with and closing the same after job completion.

• To ensure that the workers likely to be exposed to hazardous chemicals/materials have access to appropriate Material Safety Data Sheets (MSDS), wherever applicable, and provide necessary mitigation measures.

• To ensure that appropriate warning signboards or tags are displayed.

• To ensure that workers have proper training for their job assignments, including use of appropriate PPE and first aid fire fighting equipment.

• To comply with all applicable safety and health standards, rules, regulations and orders issued by competent authority pertaining to the assigned activities.

• To conduct daily inspections to ensure compliance with safety standards, codes, regulations, rules and orders applicable to the work concerned.

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8.4.3 Static Electricity

• Ensure no metal objects/appurtenances projecting from roof/shell plates, which will attract highly charged spots in fuel for dissipation.

• Ensure reduced rate of flow initially into tank/vessel until fill point/nozzle is completely submerged in fluid.

• Ensure periodic checking and recording of earthing test for tanks and piping systems are maintained.

• Agitation with air, steam gas, jet nozzle or mechanical mixtures should be avoided.

• Ensure no personl is allowed on tank roof for gauging / sampling during product transfer unless dip pipes extend to bottom of tanks. Use only mechanical gauges for ascertaining product transferred during transfer operations otherwise.

• Protective bonding is required when fill open containers where the product to be handled has a flash point below 54.5 Deg.C (130 Deg.F) or, in the case of a higher flash point product, when it is heated to within 6.0 Deg. C (15 Deg.F) of its flash point. The purpose is to keep the nozzle and container at the same electrical potential, thus avoiding a possible static spark in the area of a flammable mixture.

• Small containers made up of plastic or other non-conductive materials should not be used for filling of fuels.

• Water washing is safe from a static electricity stand-point. However, there should be no insulated conductive objects within the tank.

8.4.4 Lightning Protection

• Measures to control fugitive emission from storage tanks should be given special consideration.

• Structures of exceptional vulnerability by reason of explosive or highly flammable contents need special consideration and every possible protection need to be provided even against the rare occurrence of a lightning discharge.

• A lightning protection system (Conventional Air Terminal System) consists of the following three basic components - Air terminal, Down conductor and Earth connection

• Non-conducting chimneys whose overall width or diameter at top is upto 1.5m shall be provided with one down conductor, and chimneys with overall width or diameter at top more than 1.5m shall be provided with 2 no. down conductors

• Metal stacks shall be properly earthed at the bottom.

• Flammable liquids shall be stored in essentially gastight structures.

• Openings where flammable concentrations of vapour or gas can escape to the atmosphere shall be closed or otherwise protected against the entrance of flame.

• Structures and all accessories e.g. dip-gauge hatches, vent valves shall be maintained in good and sound operating conditions.

• Flammable air-vapour mixtures shall be prevented to the greatest possible extent from accumulating outside storage tanks.

• Potential spark-gaps between metallic conductors shall be avoided at points where flammable vapours may escape or accumulate.

• A properly designed / constructed gas tight storage tanks considered to be self-protected against lightning provided it is properly earthed and bonded. Such a structure may not require any additional means of lightning protection.

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8.5 Personnel Safety

8.5.1 Personnel Protective Equipment

• Protective equipment should be inspected frequently to ensure that it is in good condition. Frequency of checking can be decided depending upon the usage.

• After the use of protective equipment, it should be cleaned and disinfected before being issued to another person

• Know about MSDS of hazardous chemicals used. So proper PPE can be used.

• A person not-familiar with MSDS and not trained in use of appropriate PPE shall not commence any work with hazardous chemicals.

• Frequently refer to the MSDS and use of appropriate PPE

• Display prominently requisite information on MSDS and use of PPE through illustrations

• It is essential that right type of PPE and in sound condition be used.

• All stocks of PPEs should be periodically inspected, serviced and maintained and unusable ones removed from stock of usable PPEs and sent for disposal.

• All PPEs should be cleaned for personal hygiene and kept packed in poly bags.

• All PPEs should be inspected before and after each use.

8.5.2 Training

• Participant’s reaction should be obtained in respect of the course content; training methods/techniques used by the faculty, quality of course material etc.

• It should be ascertained whether participants’ learning in terms of knowledge and skills in specific areas or activities e.g. safe operating and maintenance procedures, fire prevention and control etc. have improved after the training. i.e. effectiveness of training should be judged.

• It should be checked in what ways and to what degree/extent the attitude of the participants (values or beliefs) have been influenced by the training programme. An evaluation of their behavior on the job is necessary for this purpose.

• Change in participants’ performance at their place of work as a result of the training, should be evaluated.

• The effectiveness of faculty in each training programme should be evaluated and necessary changes if need be, should be made in subsequent training programmes.

• The impact of the training programmes on the performance standards of the organisation and attainment of tangible results with respect to safety should be evaluated.

• Records of training should be maintained in respect of every employee indicating the types and the period of training programmes attended, performance evaluation and the need for future training.

• The impact of training programmes should be evaluated in terms of overall safety objectives achieved.

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8.6 Safety of Plant Equipment

8.6.1 Thermal Insulation

• Frequency of Visual Inspection to thermal insulation shall be once a year for plants and mobile equipment. This visual inspection shall be preferably carried out before monsoon, to check for any damage/deterioration, and record the same.

• Like equipment, insulation also shall be checked and maintained at regular intervals. Preventive maintenance of insulation is very much necessary for safe and economic operation.

8.6.2 Electrical Equipment

• Before initiating the inspection of electrical equipment and associated circuits, Inspector should familiarize himself with the complete previous history of the equipment/circuits, design parameters, service, and likely areas of concern, manufacturer’s recommendations and such other pertinent data to arrive at the appropriate inspection procedure.

• The field inspection of electrical equipment in an operating unit is classified into following three types as follows:

On Stream Inspection

This covers audio visual inspection items (instrument aided or otherwise) for checking of general equipment conditions, while the equipment is in operation. (e.g. an abnormal nose or vibration of motor, leakage of transformer oil or overheating of equipment etc., can be assessed through such inspections).

Shutdown Inspection

This covers those inspection items for checking conditions of equipment and systems which cannot be revealed through on-stream inspection (such as internal condition of equipment). This inspection shall be carried out after taking the shutdown of the related equipment after obtaining the Electrical Line Clearance and Work Permit requirements

Inspection of Standby Equipment and Spare Parts

The standby electrical equipment electrical equipment shall be inspected on the same basis and schedule applicable under shutdown inspection, so that changeover from normal to standby equipment shall be possible without any downtime of unit operation.

8.6.3 Reactors

Reactors and pressure vessels will be designed such that the safe working pressure of the reactors is never exceeded. As per the American Society of Mechanical Engineers (ASME), the safe working pressure of a vessel should always be higher of the two conditions mentioned:

• 10% higher than the maximum operating pressure, or

• 2 kg/cm2 more than the maximum operating pressure

Minimum statutory requirements include:

• Safety relief valves or rupture discs

• Pressure gauges

• Isolation valves or valves to prevent connected equipment over-pressurization

• Drain valve at the bottom to drain of condensates

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Vents of pressure relief systems should lead to a surge tank whose vent should lead to a scrubbing system that should have reserve overhead water tank with interlock with critical operating parameters such as pressure. Other safety devices that may be considered include:

• High / low pressure alarms, and

• Interlocking equipment to prevent over-pressurization; such as between compressors and connected equipment.

Pressure relief devices and rupture discs are always the last resort. Engineered design should include high / low pressure alarms, auto trips that are set up at pressure above the operating pressure but below the relief systems.

In general, all reactors and pressure vessels will conform to rules laid down in The Static and Mobile Pressure Vessels (Unfired) Rules 1981.

8.6.4 Equipment Safety

Pumps

Pre-starting procedure

• Equipment: Pump shall be thoroughly cleaned.

• Piping: Assembly of all piping shall be checked to ensure that they are as per the design drawing. Piping shall be thoroughly flushed to remove rust preventive/foreign material.

• Support: Relevant pipe supports shall be checked to ensure that they are as per design drawing.

• Alignment: Alignment of pump and prime mover shall be carried out.

• Bearing: Bearings shall be lubricated with correct lubricant wherever applicable.

• Prime mover: The prime mover shall be prepared for operation as manufacturer’s instruction. In case of Electric Drive correct direction of rotation shall be ensured in decoupled condition. Insulation value of motor and cable shall be checked and recorded.

• Packing: For gland packing and mechanical seal, cooling and flushing shall be ensured. Mechanical Seals (if applicable) shall be installed as per manufacturer’s recommendations.

• Heating up before startup: Pumps on high temperature service shall be heated up gradually to an even temperature before putting on service.

• Balancing drum leakage: For pumps equipped with balancing drums, any valve in the line shall be locked open for ensuring leakage return to pump suction or to the vessel.

Start-up Procedure

• The free rotation of the pump shall be checked.

• Ensure all instruments are installed as per P&I diagram.

• Ensure that strainer is provided in the suction line.

• Discharge valve shall be closed (if not already closed).

• On pumps having externally sealed stuffing boxes, the injection line valves shall be opened and sealing fluid allowed to flow to the seal cages.

• Pump shall be properly primed.

• Prime mover shall be started as per prescribed recommendation.

Post-start Checks

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• All instrument readings shall be checked and recorded periodically.

• Vibration readings shall be checked and signature shall be taken as necessary.

• Stuffing box packing shall be checked for overheating.

• Temperature rise, vibration and any abnormal sound from bearings shall be checked.

• Cooling water flow shall be checked frequently.

• Suction and discharge pressure shall be monitored to ensure proper operating condition.

Compressors

• During the start-up operations proper lubrication shall be ensured, the system shall be purged with inert gas and sample shall be taken for analysis, each suction and discharge valve shall be checked for correct positioning, the compressor shall be manually rotated to ensure free rotation, prime mover shall be started as per manufacturer’s instructions and the direction of rotation shall be checked.

• The mechanical running test shall be conducted to assess the performance of the compressor

• Oil pressures and temperatures shall be monitored to ensure that they are within the range recommended by manufacturer

• For compressors with oil seals, the amount of inward oil leakage (contaminated oil) from each seal, with approximate design differential pressure shall be measured

• Compressor drains should be inspected before and after the test to ensure that oil has not entered the compressor casing.

• All warning, protective and control devices shall be checked.

Diesel Engines

• Fuel, oil, water and exhaust shall be checked for leaks.

• Air cleaner oil level shall be checked.

• Oil level in hydraulic governor shall be checked, if provided.

• The following checks shall be carried out after every 250 hours - condition of entire oil, the filter elements for metal particles and oil sludging, element holes and tears, oil in aneroid control, if provided, belts, fan hub and drives.

Mechanical Seals

Inspection of Seal Components Prior to Installation:

• It should be ensured that all parts are kept clean; especially the running faces of the seal ring and insert.

• The seal rotary unit should be checked to ensure that the drive pins and/or spring pins are free in the holes or slots.

• The set screws in the rotary unit collar should be checked to ensure that they are free in the threads.

• The thickness of all gaskets should be checked against the dimensions shown on the assemble drawing. Improper gasket thickness will affect the seal setting and the spring load imposed on the seal.

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• The fit of the gland ring to the equipment should be checked to ensure that the gland ring pilot enters the bore with a reasonable guiding fit for proper seal alignment. It should be ensured that there is no interference or binding on the studs or bolts or other obstructions.

• It should be ensured that all rotary unit parts of the seal fit over the shaft. ‘V’ ring should be placed on the shaft individually, and never be installed on the shaft while they are seated in the seal ring or rotating assembly.

• Both running faces of the seal should be checked to ensure that there are no nicks or scratches. Imperfections of any kind on either of these faces will cause seal leakage.

Fixing of mechanical seal

• The complete seal assembly drawings and instructions should be carefully studied before starting installation.

• All burrs and sharp edges should be removed from the shaft or shaft sleeve including sharp edges on key-ways and threads. Worn shaft or sleeves should be replaced.

• The stuffing’s box bore and stuffing box face should be checked to ensure that they are clean and free of burrs.

• The shaft or shaft sleeve should be marked with various reference marks required for installation of seal as per assembly drawings.

• The shaft or sleeve should be oiled lightly prior to seal assembly to allow the seal parts to move freely over it.

• The rotary units should be installed on the shaft or sleeve in proper sequence.

• The back of the collar should be set at the proper distance from the original reference mark on the shaft or sleeve. Tighten all set screws firmly and evenly.

• The seal faces should be wiped clean and a thin oil film applied prior to completing the equipment assembly.

• The gland ring should be inserted with insert over the shaft carefully. Complete the equipment assembly taking care when compressing the seal into the stuffing box.

• The gland ring and gland ring gasket should be seated to the faces of the stuffing box by tightening the nuts or bolts evenly and firmly enough to affect a seal at the gland ring gasket.

Rotating Equipment

• Maintenance work on any rotating equipment should be started only after obtaining the work permit from the concerned department. Ensure that the equipment is electrically isolated. Also its isolation from other processes is to be ensured.

• During opening of equipment such as pumps and compressors, it is a good practice to treat the equipment as if it were under considerable pressure even though all steps have been taken to relieve the pressure.

• Vehicle entry permit should be obtained from the concerned authority before bringing any crane or any other equipment for removing the pump/equipment.

Inspection of Storage Tanks

• Inspection of tanks during fabrication shall be carried out as per the requirements of the applicable codes, specifications, drawings etc. This inspection requires regular checks on the work at various stages as it progresses. During fabrication, a thorough visual check should be undertaken and the

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tank should be checked for foundation pad and slope, slope of the bottom plates, proper welding sequence and external & Internal surfaces etc.

• Roof plates shall be inspected for defects like pin holes, weld cracks, pitting etc., at water accumulation locations

• Tanks pads shall be visually checked for settlement, sinking, tilting, spalling, cracking and general deterioration

• Anchor bolts wherever provided shall be checked for tightness, and integrity by hammer testing.

• All open vents, flame arrestors and breather valves shall be examined to ensure that the wire mesh and screens are neither torn nor clogged by foreign matter or insects.

• If a tank is insulated, the insulation and weather proof sealing shall be visually inspected for damage

• Grounding connections shall be visually checked for corrosion at the points where they enter earth and at the connection to the tank.

• The tanks shall be inspected for any obvious leakage of the product. Valves and fittings shall be checked for tightness and free operations.

• The tanks shell shall be visually examined for external corrosion, seepage, cracks, bulging and deviation from the vertical.

Pipes, Valves and Fittings

• The inspection of piping during fabrication shall be carried our as per the requirement of applicable codes, specifications, drawings, etc. This inspection requires regular checks on the work at various stages as it progresses. The inspection shall include Identification and inspection of material, approval of welding procedures in accordance with code and tender requirement, carrying out of performance qualification test and hydrostatic testing.

• Visual inspection shall be made to locate leaks. Particular attention should be given to pipe connections, the packing glands of valves and expansion joints.

• Pipe supports shall be visually inspected for condition of protective coating or fire proofing if any. If fireproofing is found defective, sufficient fireproofing should be removed to determine extent of corrosion.

• If vibrations or swaying is observed, inspection shall be made for cracks in welds, particularly at points of restraint such as where piping is attached to equipment and in the vicinity of anchors.

• Line shall be checked for bulging, bowing and sagging in between the supports.

• Conditions of paint and protective coating shall be checked.

• Pipelines shall be inspected for cracks. Particular attention should be given to areas near the weld joints.

• Externally coverts lined piping shall be visually inspected for cracking and dislodging of concrete.

• All piping, which cannot be checked on the run, shall be inspected during shutdown. These are mostly high temperature piping. During shutdown inspection, hammer-testing and hydrotesting as applicable should be carried out in addition to visual, ultrasonic and radiographic inspections.

• Pipelines in some of the services like water, phenol and steam are prone to pitting corrosion. Neither ultrasonic nor radiographic testing will reveal the actual internal condition of the pipes in such service. In such cases samples shall be cut for thorough internal examination, at scheduled comprehensive inspections. The samples shall be spilt open in two halves and internal surfaces inspected for pitting, grooving, etc.

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• Piping shall be opened at various locations by removing valves at flanged locations to permit visual inspection. When erratic corrosion or erosion conditions are noted in areas accessible for visual examination, radiographic examination or ultrasonic testing shall be performed to determine thickness.

• The gasket faces of flange joints, which have been opened, shall be inspected visually for corrosion and for defects such as scratches, cuts and grooving which might cause leakage. Ring gaskets and joints shall be checked for defects like dents, cuts, pitting and grooving.

• Inspection shall be made for hot spots on internally insulated piping. Any bulging or scaling shall be noted for further inspection when the equipment is shut down.

Boiler

At the time of fabrication

Inspection of new Boiler at the time of fabrication shall be done as per applicable codes and statutory requirements and shall include the following:

• Study of the tender document and all the technical specifications.

• Identification and inspection of the materials.

• Approval of the welding procedures.

• Approval of welders performance qualification test.

• Check for nozzle orientation, joints fitup and overall dimension as per the approved drawings.

• Check to ensure that the welding is carried out as per approved welding sequence and procedures with approved electrodes and qualified welders.

• Inspection of the weld joints for proper quality during welding.

• Checks to ensure proper preheat and post weld heat treatment wherever required.

• Inspection of repairs, if any, before giving clearance for hydrostatic testing.

At the time of operation

• Before a new boiler is put into service, the internal surface of steam generating section shall be chemically cleaned. This process includes boil out to remove grease followed by an acid cleaning to remove mill scales and rust. During the boil out period solution samples shall be taken periodically to monitor alkalinity, pH, Fe, silica and oil content.

• Inspection shall be made for hot spots, blistered paint and corrosion on exterior plates, which could be indications of refractory insulation failure.

• Leaks from boiler drums, fittings, headers and other pressure parts shall be checked during operation.

• Ladders, stairways, platforms and walkways shall be inspected visually for corrosion, cracked weldings, mechanical damage or any other deterioration, which may cause structural weakness. Light hammer testing should be done to locate the weakest locations. Platforms and walkways should be inspected for any skidding surface like oil, grease etc.

• Analysis of boiler feed water and blow down water shall be carried out periodically

• While the boiler is in operation the condition of the flame should be checked through the view glass provided at the rear and front end to ensure proper tuning of air-fuel ratio.

• Fuel gas lines should be checked for any leakages from flanges, valves and fittings using gas detectors.

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• The boiler and the forced Draft air blowers should be checked for any abnormal noise and vibrations.

• Supports and structures shall be inspected for excessive deflections, swaying, and peeling of paints and chippings of mill scale.

• Internal inspection of boiler and its auxiliary equipment should be done before and after cleaning. If oil is found in any part of the boiler, the source for this leakage should be identified for necessary rectification.

• The pipe connections around the boiler shall be inspected for distortion, metal wastage, supports, settlement of foundation and pipe roller movements.

• Visual inspection for the external surface of shell column for pitting, corrosion, and cracks shall be done.

Pressure Relieving Devices

• All pressure relieving devices shall be bench tested for set pressure, blow down and leakage as applicable prior to installation.

• The following inspection checks shall be carried out once in every six months for breather valves on storage tanks - discharge opening should be checked for obstruction, flame arrestor wherever provided shall be inspected for fouling, bird nests or clogging, element shall be inspected for mechanical damage, deposits, scaling etc. and cleaned before onset of monsoon, oil filled type liquid seal valve shall be inspected for oil level, fouling, bird nests, foreign material etc. and free movement of pallet shall be checked.

• Visual inspection of different parts of safety valve shall be done after dismantling to check the condition of flanges for pitting, roughening, decrease in width of seating surface etc.

Heat Exchangers

• General visual inspection of inside and outside surfaces and welds shall be carried out for signs of pitting, grooving, scaling, erosion or impingement attack.

• All the nozzles and small bore connections shall be checked for thinning.

• Prior to cleaning, all the accessible parts of heat exchanger shall be inspected for fouling deposits, scaling, etc.

8.7 Tank Farm Safety

8.7.1 Inspection of Storage Tanks

• All vents storages and reactors and safety relief valve vents to be taken above the roof- top if inside the building or taken above the nearest roof of the building and fitted with flame arrestors.

• All electrical equipments should be flame proof.

• Smoke/heat sensors with fore alarm should be installed.

• Electrical bonding and earthing of flanges/piping and vessels must be carried out.

8.8 Emergency Management

8.8.1 Emergency Prevention

• Preparation of a Preventive Maintenance Schedule Programme covering maintenance schedules for all critical equipments and instruments as per recommendations of the manufacturers user manuals,

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• Establishment of a computerized Failure Modes Effects and Criticality Analysis (FMECA) or similar procedure to generate data on failures of critical equipments and instruments based on mode wise failures and their criticality. This requires codification of equipments, instruments and their modes of failure and their criticality. Consideration may be given to the use of appropriate software for processing FMECA data for review of the Preventive Maintenance Schedule and for improvement of the same to ensure critical failures,

• Establishment of a Non Destructive Testing (NDT) system as necessary. This may not be feasible in-house but there are specialized organizations who undertake the work, and the same may be used.

• Importantly, it is of great importance to collect and analyse information pertaining to minor incidents and accidents at the site, as well as for recording near-misses or emergencies that were averted. This information gives an indication of how likely or unlikely it is for the site to face actual emergencies and what should be further done to prevent them from occurring.

• Establishment of an ongoing training and evaluation programme, incorporating the development of capabilities amongst employees about potential emergencies and ways and means of identifying and averting the same. Most emergencies do not occur without some incident or an abnormal situation. So there is always some time of few seconds to few minutes to arrest an incident of abnormal situation from turning in to an emergency. This is the role of the shift in-charge who is the incident controller (IC) along with his shift team.

• Material Safety Data Sheets (MSDS) or chemical information sheets (CIS) should be kept handy.

• Fire and emergency alarms should be provided; alarm recognition training should be given to every employee.

• Regular mock drills should be conducted on a specific potential disaster scenario as determined through risk assessment study

• Safe operating procedures including safe emergency and normal shut down procedures and safe maintenance procedures should be adopted.

• The roles and responsibilities of all responsible for the control of emergency should be clearly defined.

• List of key personnel and authorities (including police, factory inspector, district magistrate, state and central level authorities, experts, doctors, village leaders) along with their location should be kept handy.

• Personal Protective Equipments (PPEs) and safety torches should be made available.

• Sufficient antidotes and first aid facilities like stretchers, beds, wheel chairs etc should be made available in the factory dispensary/hospital to cope with emergency.

• Liaison with outside agencies, home guards and civic authorities for co-operation in mitigating the emergency consequences.

8.8.2 Emergency Response

Onsite Emergency Response

• Shut down and Isolation: Raising the alarm, followed by immediate safe shut down of the power supply, and isolation of effected areas.

• Escape, Evacuation and Rescue: Safeguarding human lives at site by commencement of the Emergency Evacuation and Rescue Plan. Ensuring that all personnel are accounted for and carrying out a head count of persons evacuated. Notification and commencement of offsite emergency plan in case offsite impacts are possible.

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• Stopping the development of the emergency: Control or response to the emergency depending upon its nature (fire, toxic release or explosion). Fire can be somewhat better controlled through fire fighting, while toxic release impacts can be partially controlled through proper communication with affected population. Impacts of explosions impacts can not be controlled once they occur, hence efforts will require focusing on provision of relief or control of secondary impacts (such as property damage or fires) resulting from explosions.

• Treatment of injured: First aid and hospitalization of injured persons.

• Protection of environment and property: During mitigation, efforts should be made to prevent impacts on environment and property to the extent possible.

• Welfare of the personnel managing the emergency: Changeover, first aid and refreshments for the persons managing the emergency.

• Informing and collaborating with statutory, mutual aid and other authorities including those covered in the Local Crisis Group.

• Informing and assisting relatives of the victims.

• Informing the news and electronic media.

• Preserving all evidences and records: This should be done to enable a through investigation of the true causes of the emergency.

• Investigation and follow up: This requires to be carried out to establish preventive measures for the future and a review of the DMP & its annexures to fill up the deficiencies in the emergency planning procedures.

• Ensuring safety of personnel prior to restarting of operations: Efforts require to be made to ensure that work environment is safe prior to restarting the work.

Off-site Emergency Response Plan

An emergency may affect areas offsite of the works as for example, an explosion can scatter debris over wide areas and the effects of blast can cover considerable distances, wind can spread burning brands of gases. In some cases e.g. as the result of an explosion, outside damage will be immediate and part of the available resources of the emergency services may need to be deployed in the affected areas. In any case, the possibility of further damage may remain, e.g. as the result of further explosion or by the effect of wind spreading burning brands of hazardous material.

It will be necessary to prepare in advance simple charts or tables relating the likely spread of the vapors cloud taking into account its expected buoyancy, the local topography and all possible weather conditions during the time of release. It may also be desirable to install instruments indicating wind speed and direction, which could be done jointly with surrounding industries.

8.8.3 Inspection of Fire Fighting Equipment and Systems

• The internal and external surfaces of the cylinder body shall be coated with Zinc or lead-tin alloy

• Material used for the cylinder shell shall be identified to ensure conformity with manufacturing standard.

• Extinguisher (DCP Vessel) is prone to internal corrosion at the interface between the dry powder top level and empty space; periodic inspection should therefore be undertaken.

• The shell of the DCP extinguisher shall be visually inspected externally once a month and internally once every three months to check for any mechanical damage or corrosion.

• A DCP extinguisher body shall be removed from service and destroyed when it is corroded or damaged to such an extent at repair is required, when the shell threads are damaged, when it has

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failed in hydro testing or when the extinguisher has been exposed to high temperatures due to proximity of fire.

• The internal coating and external painting shall be checked for damage/deterioration once in three months.

• The safety valve shall be visually inspected for corrosion or damage once every three months. The safety valve shall be bench tested at rated test pressure once every three years.

• All DCP extinguishers shall be permanently punched at the bottom ring with Manufacturer’s name, year of manufacture, manufacturer’s Sr. No. and Inspectors stamp.

• Equipment, which will automatically detect heat, flame, smoke, flammable gases, or other conditions likely to produce fire or explosion and cause automatic actuation of alarm and protection equipment should be provided.

8.8.4 Recommendations on Individual Accident Risks

• Fall of persons from height: Training, use of life harness (Safety belt) for working at height, providing platforms with railing at height, barricading pits and eliminating piping and other trips in passages are needed to prevent fall accidents of individuals.

• Fall of objects from overhead work: Helmet use is essential for all project personnel, irrespective of their job nature; use of proper tools properly and handling non-greasy tools is important in preventing falls of objects; use of MS plates on overhead platforms to help restrict the fall of objects since even nuts and bolts can cause injuries.

• Object hits on the body causing injuries: These accidents are prevented by providing appropriate guards and barricades for all moving parts and in-running nips.

• Hand and foot injuries: Training may be given to workers pertaining to these techniques. Use of safety shoes with toe protection cup and use of appropriate hand gloves for specific activities are required in addition to use of correct tools and correct methods.

• Flying objects and splinters causing face injuries: Use of face shields is required wherever such hazards exist.

• Falls, vehicle accidents, flying objects and falling objects causing head injury: Head injury is a very serious injury. Use of helmet should be mandatory. Helmet should be worn with snugly fitting chin belt. This is very important, as the chin belts are never used in India. Non-use of chin belt, leads to the helmet flying off before the head hits during falls exposing the head for injuries.

• Collisions of vehicles with other vehicles, other structures and human beings: Vehicular movement restrictions and routes need to be displayed. Backing of vehicles has high risk of accidents. Backing alarm signal (Not musical one) be made mandatory on all vehicles. For fork lift trucks now they come fitted with infra red sensors to detect objects behind about one meter away are available. All such measures are ensured to prevent collisions.

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9 CONCLUSIONS

9.1 Summary of Impacts

9.1.1 Ambient Air

Ambient air monitoring carried out in post monsoon season of year 2010 shows that the ambient air quality for SPM, SO2, NOx, are well within the limits specified by CPCB.

Emissions from the boiler, finishing section stacks were analyzed for their impacts on the Ground level concentration (GLC) for various distances using the dispersion modeling guidelines given by the Central Pollution Control Board, New Delhi and the Industrial Source Complex Short Term Model (ISCST3) of the United States Environment Protection Agency (USEPA). The maximum incremental addition due to proposed expansion is estimated to be 22.67 µg/m3, 3.41 µg/m3, 0.69 µg/m3 for SOx, NOx and PM respectively. These GLCs are expected to occur at a distance of 200m from the source towards the West direction.

The concentration limit for SO2 and NOx in the ambient air, as specified by CPCB is 80 µg/m3. The baseline ambient air concentration of SO2 was observed to be around 11.9 µg/m3 and NOx in the study area was observed to be around 15.2 µg /m3.

Thus it can be concluded that the impact on ambient air quality due to INEOS ABS’s proposed activities are within acceptable norms.

Further, it is emphasized that all the emissions have to be strictly controlled as mentioned in the mitigation measures of this chapter and summarized in the Environmental Management Plan.

9.1.2 Water Resources

The assessment of impacts on the water environment due to proposed expansion of INEOS ABS is as follows:

There will be requirement of water for construction for the proposed expansion. For existing production water requirement is approximately upto 271 kld, which will increase to 415 kld due to proposed expansion. Wastewater only consists of utility wastewater, and not organic contents bearing wastewater the existing primary ETP is having a capacity to treat upto 120 KLD wastewater. Even with the proposed expansion, this capacity will not be exceeded. After treatment water will be used for inland purpose i.e. gardening.

9.1.3 Soil Quality

All precautionary measures have to be strictly controlled as mentioned in the mitigation measures discussed in the previous chapters. Surface soil samples were taken at different locations. These were analysed for a range of parameters.

9.1.4 Noise Levels

Noise levels shall be within limits specified by GPCB at plant boundary, after implementation of the mitigation measures. Hence there is no adverse impact on noise levels by INEOS ABS’s operations.

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9.1.5 Flora and Fauna

Flora

The floristic component of the study area does not include any rare or endangered species. Thus, impact on rare and endangered species of flora is also ruled out.

Fauna

The quality of ambient air and fresh water system will remain practically unaffected. Thus indirect impact on fauna, due to these abiotic factors is ruled out. The proposed activities do not envisage destruction of habitat and feeding or breeding area of faunal species. Thus, no impacts on rare / endangered species are envisaged due to site operations.

9.1.6 Socio-economic Environment

No adverse impact is expected on sanitation and community health.

9.1.7 Conclusions

Thus, it can be concluded on a positive note that after the implementation of the mitigation measures and Environmental Management Plan the normal operation of INEOS ABS will have negligible impact on environment.

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10 BACKGROUND OF THE AGENCY CONDUCTING ENVIRONMENTAL STUDIES

Kadam Environmental Consultants, Vadodara, Gujarat have been entrusted by INEOS ABS (India) Ltd for carrying out the above mentioned study. Kadam Environmental Consultants (KEC) is one of the oldest and largest environmental consulting firms in Gujarat and India with about 160 personnel deployed in various activities.

KEC has been active in this field of environment since 1981 and has handled important assignments in India as well as abroad. KEC has a full-fledged division for environmental impact assessment and audits with chemical engineers, environmental planners, environmental engineers, civil engineers, microbiologists, zoologists, botanists, chemists and industrial chemists (including persons specializing in fieldwork pertaining to sampling). Total environmental staff at KEC and its group companies currently employed more than 210 persons.

The company has its own air, water, microbiological and soil testing laboratories for analyzing physicochemical and bacteriological parameters including heavy metals. The KEC laboratories are certified to ISO 9001-2008 and are inspected by Gujarat Pollution Control Board (GPCB) as well as the Central Pollution Control Board (CPCB) Regional Office at Vadodara at regular intervals. The KEC laboratory at vadodara is recognized by the Ministry of Environment and Forests (MoEF) under the Environmental Protection Act, 1986. KEC is recognized as Environmental Auditors (under the Environmental Audit scheme propounded by the Honorable High Court of Gujarat) by the Gujarat Pollution Control Board.

Following the MoEF Circular dated 2nd December, 2009; KEC has applied for registration as an EIA Consultant with NABET. The application is currently being processed by NABET.