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Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006 Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP Report For proposed EXPANSION in existing Synthetic Organic Chemicals unit of M/s. Black Rose industries Limited. at Plot No. 675, Jhagadia Notified GIDC Industrial Estate, Dist - Bharuch, Gujarat State, India Chapter 7. Risk Assessment and Disaster Management Plan Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 209 of 264 7 RISK ASSESSMENT & DISASTER MANAGEMENT PLAN 7.1 BACKGROUND Risk Assessment is a management tool for determining the hazards and risk associated with the various activities of a project and compute the damage potential of these hazards to life and property. Risk Assessment provides basis for determining the safety measures required to eliminate, minimize and control the risks as detailed in Disaster Management Plan (DMP) to handle onsite and offsite emergencies. In Chemical Industry, Risk Assessment is carried out for the various hazards involved in storage and handling of hazardous raw materials, intermediates and finished products as well as for the manufacturing processes used by the unit. 7.2 OBJECTIVES The given study was focused to fulfill the following objectives: - Identification of safety areas - Identification of process and storage hazards - Visualization of maximum credible accident (MCA) scenarios - Consequence analysis of scenarios - Determination of quantities released, impact zones - Estimation of damage distances for the accidental release scenarios with recourse to Maximum Credible Accident (MCA) analysis - Preventive and control measures required for reducing the risk factors - Delineation of Disaster Management Plan 7.3 SCOPE OF WORK Based on the objectives as defined above, the scope of work for the given study has been framed as under: - Hazard Identification General description of project Study of manufacturing activities Study of plant facilities and layout Hazardous inventory Associated process and storage hazards Safety measures as proposed by the proponent - Hazard Assessment Identification of MCA and worst case scenarios using standard techniques Consequence analysis of selected scenarios using EFFECT model on ALOHA software - Determination of risk reduction measures - Preparation of DMP - Recommendations 7.4 METHODOLOGY Following methodology has been followed for given Risk Assessment Study as described in “Guidelines for Chemical Process Quantitative Risk Assessment” by CCPS with the help of frequency data from “Purple Book” , 2008. The guidelines given by SEAC as well as Technical Guidance Manual of MoEF&CC have also been followed. Collecting Input data about Process, Inventories and Site conditions Hazard Identification Defining the Potential Accident Scenarios

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Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor proposed EXPANSION in existing Synthetic Organic Chemicals unit of M/s. Black Rose industries Limited.

at Plot No. 675, Jhagadia Notified GIDC Industrial Estate, Dist - Bharuch, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 209 of 264

7 RISK ASSESSMENT & DISASTER MANAGEMENT PLAN

7.1 BACKGROUNDRisk Assessment is a management tool for determining the hazards and risk associated with the various activities ofa project and compute the damage potential of these hazards to life and property. Risk Assessment provides basisfor determining the safety measures required to eliminate, minimize and control the risks as detailed in DisasterManagement Plan (DMP) to handle onsite and offsite emergencies.In Chemical Industry, Risk Assessment is carried out for the various hazards involved in storage and handling ofhazardous raw materials, intermediates and finished products as well as for the manufacturing processes used bythe unit.

7.2 OBJECTIVESThe given study was focused to fulfill the following objectives:

- Identification of safety areas- Identification of process and storage hazards- Visualization of maximum credible accident (MCA) scenarios- Consequence analysis of scenarios- Determination of quantities released, impact zones- Estimation of damage distances for the accidental release scenarios with recourse to Maximum Credible

Accident (MCA) analysis- Preventive and control measures required for reducing the risk factors- Delineation of Disaster Management Plan

7.3 SCOPE OF WORKBased on the objectives as defined above, the scope of work for the given study has been framed as under:

- Hazard Identification General description of project Study of manufacturing activities Study of plant facilities and layout Hazardous inventory Associated process and storage hazards Safety measures as proposed by the proponent

- Hazard Assessment Identification of MCA and worst case scenarios using standard techniques Consequence analysis of selected scenarios using EFFECT model on ALOHA software

- Determination of risk reduction measures- Preparation of DMP- Recommendations

7.4 METHODOLOGYFollowing methodology has been followed for given Risk Assessment Study as described in “Guidelines forChemical Process Quantitative Risk Assessment” by CCPS with the help of frequency data from “Purple Book” ,2008.

The guidelines given by SEAC as well as Technical Guidance Manual of MoEF&CC have also been followed. Collecting Input data about Process, Inventories and Site conditions Hazard Identification Defining the Potential Accident Scenarios

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor proposed EXPANSION in existing Synthetic Organic Chemicals unit of M/s. Black Rose industries Limited.

at Plot No. 675, Jhagadia Notified GIDC Industrial Estate, Dist - Bharuch, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 210 of 264

Evaluation of Consequences and Estimation of Accident Frequencies Estimate the Impacts Estimate the Risk Identify and Prioritize the Risk Reduction measures.

7.5 HAZARD IDENTIFICATIONThis is important and critical step in risk assessment. It is critical because Hazard omitted is hazard not analyzed.The tools used for identification are experience, detailed process knowledge, engineering codes, checklist, HAZOPsetc.The unit shall handle hazardous materials and shall have a defined and organized hazard control and preventionsystem in place. The following statutory compliances shall be applicable to the unit:

1. Gujarat Factories Rules, 19632. Manufacture, Storage and Import of Hazardous Chemicals (Amended) Rules, 2000

The hazards of the materials are identified from the MSDS. The major hazards are toxic, fire and explosion.Flammable material will form pool on leakage and this pool can sustain a pool fire. In case of toxic material thevapors evaporated from pool disperse in downstream direction and may cause problem for people in process units /buildings

The inventory of hazardous material in the storage area is significantly larger than the inventory involved in theprocess, hence the scenarios selected for the consequences calculations are from storage vessels. These vesselsare located near the respective plants only.

7.6 STORAGE HAZARDS AND CONTROL MEASURESThe materials involved are of toxic and flammable nature. The major hazardous materials, their inventories and theirhazardous properties are tabulated in Annexure-26.

All chemicals are stored and handled in accordance with Material Safety Datasheet. MSDS of few importantchemicals are annexed as Annexure – 38.

The unit is not an MAH installation in accordance to the schedule 3 of MSIHC rules, 2000 also after expansion.

New Chemicals to be handled after proposed expansionS. No. New hazardous chemicals along with its Hazard

nature to be handled in the unitProducts for which it shall be used

1 p-formaldehyde (Toxic) N-Methylol Acrylamide

Table 7-4 List of Hazardous chemicals to be handled after expansionLiquid and Solid Storages (drums, carboys)Sr.No.

Hazardous Chemical Name andNature of its Hazard

State Equipmentconsidered

Size ofcontainer(MT)

Max. No. ofcontainers

Max. storagequantity (MT)

1. N-Methylol Acrylamide (Product)(Toxic)

Liquid Drums 0.2 400 80

Bags Storage (Solids)Sr.No.

Hazardous Chemical Name andNature of its Hazard

State Equipmentconsidered

Size ofcontainer

kg

Max. No. Ofcontainers

Max. storagequantity (MT)

1. p-Formaldehyde (Raw Material)(Formaldehyde 98%) (Flammable and Toxic)

Solid Bags 25 1200 30

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor proposed EXPANSION in existing Synthetic Organic Chemicals unit of M/s. Black Rose industries Limited.

at Plot No. 675, Jhagadia Notified GIDC Industrial Estate, Dist - Bharuch, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 211 of 264

Liquid Storage (Above ground Vertical fixed roof storage Tank)Sr.No.

Full name of the rawmaterial and its hazard

State Equipmentconsidered

Existing No. oftanks & Size (KL) at

site

AdditionalNo. of tanks

& Size

Storage ParametersPress. kg/cm2 Temp °C

1. Acrylonitrile(Flammable& Toxic)

Liquid Storage Tank 2 nos., 190 MT each(1 filled + 1 empty atall times)

none Atmospheric withN2 Blanketing

Ambient

2. Acrylic Acid(Flammable)

Liquid Storage Tank Nil 1 no., 200 MT Atmospheric N2Blanketing

Ambient

3. Caustic (Toxic) Liquid Storage Tank Nil 1 no., 200 MT Atmospheric AmbientProducts

4. Acrylamide (Toxic) Liquid Storage Tank 3 nos., 250 MT each(2 filled + 1 empty atall times)

none Atmospheric Ambient

Preventive Measures provided Flammable Storage Tanks of Acrylonitrile and Acrylic Acid : - Tanks are properly Earthed. Earthing and

Bonding provided to Unloading pump and Tankers. Tank vent equipped with Breather valve, followed by VentHE and then with Flame arrester. Tanks are installed in dyke containment. Tanks are provided with Levelindicator with high level alarm and level overfill switch. SOP is in place for Tanker unloading (annexed asAnnexure -36). All electrical and instrumentation fixtures are Flame proof Lightning arresters are provided asper requirement.

Majority Production processes to be observed and controlled by DCS system incorporating adequateinstrumentation through temp. and pressure indicators, controllers and recorders.

All reactors shall be provided with interlocking / cutoff system to cut heating if cooling water/chilling water injacket is stopped

All pressure vessels are equipped with PSVs. Welded pipes to be used wherever feasible Suitable gasket material to be used Suitable gland packing to be used in valves Regular inspection and Preventive maintenance are carried out with reference to plant operations like pumps,

valves, pipes etc as per maintenance program.

Control Measures Provided :- Fire hydrant system in place. Portable Fire Extinguishers are installed as perrequirement. Foam and Water Monitor installed around Tank farm storing flammable materials. Sprinkler system isprovided on Acrylonitrile tank for cooling of tank in case of high temperatures, Safety shower and eye wash installedat critical locations. Storage tanks storing hazardous chemicals provided with dyke for containment. ECC equippedwith Self Contained Breathing Apparatus, PPE’s. Onsite Emergency plan is in place. Site has a dedicated andtrained Fire fighting team and First Aider team.

7.7 PROCESS HAZARDS AND THEIR CONTROL MEASURESTable 7-1 Process Hazards and their Control MeasuresSr.No.

Cause Reason Type ofHazardspossible

Probability/ Severity

Preventive Measuresprovided

Control Measuresprovided

1. Leakagefrom line/ valve

Failure ofvalve orjoints

ChemicalSpill,ToxicRelease,Fire

Low/Low

All lines / valvesperiodically checked.Preventive maintenanceof all safety devicesOperators trained toarrest leakages.PPE’s providedFlameproof fixturesprovided wherever

Fire Extinguishers, Firehydrant systemSand buckets,First-aid and Medicalfacilities

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor proposed EXPANSION in existing Synthetic Organic Chemicals unit of M/s. Black Rose industries Limited.

at Plot No. 675, Jhagadia Notified GIDC Industrial Estate, Dist - Bharuch, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 212 of 264

Sr.No.

Cause Reason Type ofHazardspossible

Probability/ Severity

Preventive Measuresprovided

Control Measuresprovided

applicable2. Failure

of part ofvesselor jacket

Overpressureand failure ofsafety device

ChemicalSpill,ToxicRelease,Fire

Low/Medium

Operators trained for theprocess and SOPs inplace.Preventive maintenanceof all safety devicesPPE provided toWorkers.Flameproof fittings areprovided whereverapplicable

DCS controlledoperations

Fire Extinguishers, Firehydrant systemSand buckets,First-aid and Medicalfacilities

3. Spillagefromdrums /bags

Manual error,rupture

ChemicalSpill,ToxicRelease

Low / Low Operators trained tohandle Drums and Bags.PPE’s provided toOperators

Spill kitFirst Aid Kit available

7.8 OTHER HAZARDS & CONTROLFollowing are the other possible hazards and its controls: Mechanical hazards- Scaffolding and fall protection for working at height, Periodic inspection of lifting tools

and tackles, inspection of pressure vessels, SOPs, Work permit system, HSE guidelines in place andregularly refreshed by HSE trainings

Electrical hazards - Electrical shock proof gloves and shoes provided, Electrification as per zoneclassification, Electrical work permit system in place

Structural failure – Building design / Structural design as per relevant codes and standards. Buildingstability certificate available.

Transportation hazards - proponent has taken adequate fire protection and control measures for in-plantand parked transportation as mentioned in later sections.

Toxic Release from outside – taken care by GIDC fire station, mutual aid and District authorities. JhagadiaIndustrial Association (JIA) is setting up Disaster Management Centre for the same.

Natural Calamity (Flood, Earthquake, lightning etc.) – The project area is sufficiently away from major river -Narmada river, since the site is at an elevation of ~ 40 m from the MSL. Storm water drainage network is in placeand also the floods or abnormally high precipitation may obstruct block the internal roads and SH-64 & 165 only for ashort period owing to the good drainage towards the sea.

Jhagadia GIDC estate falls in the Seismic Zone III. Since the estate is located at sufficient height from sea, thereare no instances of Tsunami in the recorded past.

7.8.1 Sensitive locations around the projectTable 7-2 Sensitive locations around the projectReceptorstation

no.

Receptor Approx. AerialDist. From the

site, km

Direction w.r.tproject site

Upwind or downwindw.r.t project site andpredominant winddirection (SW-NE)

1 Dadheda 1.26 343.32°, N Downwind2 Talodara 2.24 65.61°, NE Downwind3 Randedi 2.00 159.59°, SSE Crosswind4 Sardarpura 3.88 319.25°,NW Crosswind5 Internal road connecting SH64

to GIDC 0.77 244.42°, SW Upwind

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor proposed EXPANSION in existing Synthetic Organic Chemicals unit of M/s. Black Rose industries Limited.

at Plot No. 675, Jhagadia Notified GIDC Industrial Estate, Dist - Bharuch, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 213 of 264

Study Area Map (Area within 10 km radius from centre of project site)

Co-ordinates of Centre of Project Site: Latitude: 21°37'20.38"N, Longitude: 73°8'3.52"E

The study area comprises of:-- 74 nos. residential areas and agricultural land uses- Ponds and lakes- Part of Ankleshwar GIDC Industrial estate- Part of Valia GIDC industrial estate- Full land of Jhagadia GIDC Industrial estate- Amravati and Kaveri river stretches- Kondh ki khadi- Part of NH no. 8, SH 13, SH 168, SH 175, SH 165 and SH 64- Railway track of Ankleshwar – Rajpipla rail line

7.9 PROPOSED RISK REDUCTION MEASURES FOR THE PROJECTProponent has provided and is committed to provide advanced risk reduction measures in the unit. Specificmeasures taken for storage and handling of Acrylonitrile and p-formaldehyde are delineated in chapter 2 of thisreport in compliance to TOR No. 3.

7.9.1 Existing Safety Features Systems The Plant is built as per engineering codes & standards such as ASME, applicable Indian standards (IS).

Pressure vessels are provided with safety valves for emergency venting.

DCS Control System and Emergency Shutdown SystemThe plants are automated to be best possible extent and controlled through DCS system. Necessaryinstrumentation is provided on vessels and tanks for indication and control. Alarms are provided fortemperature and pressure wherever required. The operators have definite instruction for the action to be takenon equipment or process malfunction.

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor proposed EXPANSION in existing Synthetic Organic Chemicals unit of M/s. Black Rose industries Limited.

at Plot No. 675, Jhagadia Notified GIDC Industrial Estate, Dist - Bharuch, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 213 of 264

Study Area Map (Area within 10 km radius from centre of project site)

Co-ordinates of Centre of Project Site: Latitude: 21°37'20.38"N, Longitude: 73°8'3.52"E

The study area comprises of:-- 74 nos. residential areas and agricultural land uses- Ponds and lakes- Part of Ankleshwar GIDC Industrial estate- Part of Valia GIDC industrial estate- Full land of Jhagadia GIDC Industrial estate- Amravati and Kaveri river stretches- Kondh ki khadi- Part of NH no. 8, SH 13, SH 168, SH 175, SH 165 and SH 64- Railway track of Ankleshwar – Rajpipla rail line

7.9 PROPOSED RISK REDUCTION MEASURES FOR THE PROJECTProponent has provided and is committed to provide advanced risk reduction measures in the unit. Specificmeasures taken for storage and handling of Acrylonitrile and p-formaldehyde are delineated in chapter 2 of thisreport in compliance to TOR No. 3.

7.9.1 Existing Safety Features Systems The Plant is built as per engineering codes & standards such as ASME, applicable Indian standards (IS).

Pressure vessels are provided with safety valves for emergency venting.

DCS Control System and Emergency Shutdown SystemThe plants are automated to be best possible extent and controlled through DCS system. Necessaryinstrumentation is provided on vessels and tanks for indication and control. Alarms are provided fortemperature and pressure wherever required. The operators have definite instruction for the action to be takenon equipment or process malfunction.

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor proposed EXPANSION in existing Synthetic Organic Chemicals unit of M/s. Black Rose industries Limited.

at Plot No. 675, Jhagadia Notified GIDC Industrial Estate, Dist - Bharuch, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 213 of 264

Study Area Map (Area within 10 km radius from centre of project site)

Co-ordinates of Centre of Project Site: Latitude: 21°37'20.38"N, Longitude: 73°8'3.52"E

The study area comprises of:-- 74 nos. residential areas and agricultural land uses- Ponds and lakes- Part of Ankleshwar GIDC Industrial estate- Part of Valia GIDC industrial estate- Full land of Jhagadia GIDC Industrial estate- Amravati and Kaveri river stretches- Kondh ki khadi- Part of NH no. 8, SH 13, SH 168, SH 175, SH 165 and SH 64- Railway track of Ankleshwar – Rajpipla rail line

7.9 PROPOSED RISK REDUCTION MEASURES FOR THE PROJECTProponent has provided and is committed to provide advanced risk reduction measures in the unit. Specificmeasures taken for storage and handling of Acrylonitrile and p-formaldehyde are delineated in chapter 2 of thisreport in compliance to TOR No. 3.

7.9.1 Existing Safety Features Systems The Plant is built as per engineering codes & standards such as ASME, applicable Indian standards (IS).

Pressure vessels are provided with safety valves for emergency venting.

DCS Control System and Emergency Shutdown SystemThe plants are automated to be best possible extent and controlled through DCS system. Necessaryinstrumentation is provided on vessels and tanks for indication and control. Alarms are provided fortemperature and pressure wherever required. The operators have definite instruction for the action to be takenon equipment or process malfunction.

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor proposed EXPANSION in existing Synthetic Organic Chemicals unit of M/s. Black Rose industries Limited.

at Plot No. 675, Jhagadia Notified GIDC Industrial Estate, Dist - Bharuch, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 214 of 264

Defined Standard Operating Procedures Maintenance systemsHazardous materials like Acrylonitrile, Acrylic acid, Acrylamide, are being handled and p-formaldehyde will behandled in the plant. Critical activities are identified and Standard Operating procedures are available for allsuch critical activities (List of SOPs and SOP for packing of finished goods & unloading procedure ofAcrylonitrile tanker is annexed as Annexure -36). Preventive maintenance procedure and schedule is in placefor all critical equipment.

Fire Water Network:Fire water ring is provided covering entire plot area under occupation. The ring is kept pressurized bycontinuously running jokey pumps. Fire hydrant system shall be augmented to cover new plant section.Necessary network components shall be provided.

Area Segregation: - Proposed expansion area will be segregated Flame proof and Non Flame proof areaas per Zone classification. Flame proof fittings/Equipment will be provided in designated flame proof areas.

Common features of Storage Tanks- Located in a designated area within Concrete Dyke wall.- Level indicators with high / low alarms in tanks are provided. Interlocks are provided to stop pump,

close ON/OFF valves to avoid overfilling.- Breathing valve and Flame arrestors provided on Storage tank storing Flammable chemicals. ,- Fire water ring with hydrant post is available in storage area.

7.9.2 Inbuilt Safety at design, construction & commissioning stages Fail safe instrumentation and control systems for DCS, including indicators, high and low alarms, NRVs,

controllers. PSVs and TSVs on reactors, detectors at required locations Civil foundations and structural work shall take into account protective measures for earthquakes, cyclones,

landslides, flooding etc. Jumpers provided on flanges to prevent static charge. Lightning arrester installed at all critical locations A well-planned and well-maintained electrical grounding system with sufficient earthing pits provided

covering all areas handling flammable chemicals including storages, production areas, loading, unloadingareas, warehouses etc.

Storage tanks and areas designed and constructed in compliance to the various applicable rules underManufacture, storage & Import of Hazardous Chemicals Rules, Explosives Act, Factories act and GujaratFactories Rules.

Flame arrestors, water sprinklers, breather valves provided to Storage tanks as per requirement andapplicable rules.

The bulk chemicals storage area kept away from the main production areas.

For emergency management: (to be augmented for new plant section) - Fire hydrant system covering the entire plant to be provided. Fire hydrant system shall be augmented

to cover new plant section. Suitable type and no. of Fire Extinguishers shall be provided at new plant sections Emergency power for all critical drives / instruments Additional procurement of Self Contained Breathing apparatus (SCBA), LEL detectors and oxygen

detectors for emergency handling. Drains covering the plant to contain contaminated water during fire emergency Eye washers / showers to be provided at all required locations Well equipped First-aid centre already available Amendment to Onsite emergency plan and emergency management

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor proposed EXPANSION in existing Synthetic Organic Chemicals unit of M/s. Black Rose industries Limited.

at Plot No. 675, Jhagadia Notified GIDC Industrial Estate, Dist - Bharuch, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 215 of 264

7.9.3 Safety During operational phase Safe operating procedures are developed for handling of hazardous chemicals and for critical process

operations such as loading and unloading tankers, drum charging, drum movement, vessel opening ordrum opening, work permit systems. Copy annexed as Annexure – 36.

Appropriate PPE provided to workers w.r.t type of operation and material handled. Preventive maintenance schedule for all critical equipment and vessels planned and followed. Do’s and

don’ts for maintenance of critical equipment and machinery prepared and instructed to operators (Copyannexed as Annexure 18)

Work Permit system implemented for hot work in Plant / Storage area, Vessel Entry Permit, Working atHeight, Opening of the Process lines.

Training programs are conducted for employees for SOPs and safety as per yearly plan. The plan and copyof one such training record is attached as Annexure – 35.

All employees covered under Group Insurance Policy along with personal accident cover Accident records maintained and top management at headquarters appraised Periodical medical checkup of employees done & health records kept All the equipment and pipelines marked for identification All the safety devices and instruments like safety valves, tested, inspected and recalibrated as per safety

norms. Fire hydrant system, Fire extinguishers, fire alarms, detectors examined periodically and preventive

maintenance to be undertaken. Hydraulic testing of pressure vessels and tanks done through Government approved Competent Person.

(As per rule). Match boxes, Cigarettes, Mobile, any petroleum product prohibited. Visitors required depositing such items

at security gate. To check preparedness of workers for emergency control, mock drills on regular basis and disaster drills as

per factory inspectorate guidelines to be conducted. Fire fighting team with adequate firefighters in each team and having proper training Trained first aid team Head count of all employees inside the Plant premises maintained by the Duty Security Head in a register

on the Gate. Similarly, head count of all contract workers maintained.

Specific storage and handling measures :AcrylamideThe quantity of acrylamide being stored at the unit is 500 MT. The material will be directly pumped from themanufacturing process to the storage tanks. As per established safe storage method, the material will contain apolymerization inhibitor and stored at 20°C in SS304 tanks in order to avoid polymerization.The tanks are marked and labeled as “ Acrylamide Solution (50 %) with tag number. Two storage tanks are providedto enable transfer and storage of different production lots.One tank of 250 MT capacity(third tank) is always kept empty for emergency transfer from other tanks.

AcrylonitrileThe maximum quantity of acrylonitrile being stored at the unit is 190 MT. Two storage tank of 190 MT capacity eachhas been installed. One tank of 190 MT capacity is being/ shall be kept empty at all times. The material is being /willbe transported by special dedicated tankers and unloaded using specially selected gland less pumps. Acrylonitrilestorage tanks are located 20 m away from the utility building.Acrylonitrile tank is blanketed with nitrogen gas and with alarm system for nitrogen flow.Storage tank is equipped with Breather valve and Flame arrestor. Vent HE with Chilled water circulation is providedto capture traces of Acrylonitrile escaping during storage.Sprinkler system are provided for cooling of tank in case of high temperatures.Fire hydrant system with two foam monitors are provided in and around acrylonitrile tank farm.Prescribed antidotes- cyanide kit for acrylonitrile made available at site.Handling of acrylonitrile is done in closed systems thereby avoiding possibility of leakages and possible contact.Acrylonitrile detectors are installed to alert any accidental leakage of Acrylonitrile.

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor proposed EXPANSION in existing Synthetic Organic Chemicals unit of M/s. Black Rose industries Limited.

at Plot No. 675, Jhagadia Notified GIDC Industrial Estate, Dist - Bharuch, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 216 of 264

Acrylic AcidAcrylic acid is a toxic and inflammable chemical.The quantity of acrylic acid proposed to be stored is 200 MT. It shall be stored in 1 tank in the tank farm. Thematerial will be transported by tankers and unloaded using specially selected seal less (gland less) pumpsFire hydrant system with water and foam monitors shall be installed.Handling shall be done in closed systems thereby avoiding possibility of leakages and possible contact.

Caustic sodaThe quantity of caustic soda proposed to be stored shall be 200 MT in tanks. The tank would be in tank farm withdykes. Necessary safety equipment shall be provided.

Activated CarbonActivated carbon is non-flammable and non- toxic, however, appropriate PPE should be used when handling thesame. The quantity of activated carbon proposed to be stored is 10 MT. It shall be stored in small bags in theprocess plant building in a closed and exhaust-ventilated room. The process plant building is provided with firehydrant protection, eye wash stations, and shower booths at strategic locations on every floor.

7.9.4 Fire Fighting ArrangementsFire hydrant detailsSource of Water : Water tank of capacity 305 KL and it is located near GIDC water storage tankFire pumps details The entire fire hydrant line is pressurized with auto pressure switch at 7 kg/cm2 at all

given times.Three pumps have been installed at existing premises and details of the same arementioned below:Jockey pump of 11 m3/hr which maintains pressure at 7 kg/cm2 continuously by autoswitch.Electrical driven pump 137 m3/hr also in auto mode at 7 kg/cm2.DG driven pump of 137 m3/hr and it is emergency pump which can operate ineventuality of power failure.

Hydrant System Details 18 number of fire hydrant post are provided at all critical locations of the plant. Thesehydrants, having single and double heads, are continuous monitored and checked bythe on duty safety officer.

(Source : Onsite plan of Black Rose Industries Ltd.)

Fire hydrant layout diagram is annexed as Annexure -16Fire hydrant system shall be augmented during expansion.

Fire Extinguishers:A total 56 nos. of different types of portable fire extinguishers have been provided at existing premises. Details of thesame are mentioned below:Sr. No. Type of Fire extinguisher Capacity Quantity Installed1. ABC Type 2 kg 32. ABCType 6 kg 253. CO2 2 kg 34. CO2 9 kg 205. Mechanical Foam 9 kg 56. Sand Buckets 9 Ltr 50(Source : Onsite plan of Black Rose Industries Ltd.)

Foam tank is provided for effective firefighting and for hazardous chemicals spill handling.All risers have two independent ring mains for adequate water flow and safety.Firefighting points are located at an appropriate safe distance from tank dykes so as to allow effective firefightingoperations.A foam/water sprinkler system is located near dyke area of the acrylonitrile storage tanks for quick and effectivehandling of spills.

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor proposed EXPANSION in existing Synthetic Organic Chemicals unit of M/s. Black Rose industries Limited.

at Plot No. 675, Jhagadia Notified GIDC Industrial Estate, Dist - Bharuch, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 217 of 264

Additional fire fighting systems shall be provided as per GFR during expansion.

Emergency Equipment (as per latest onsite plan)Personal Protective EquipmentRespiratory Non-respiratorySCBA Nos. 02 TypeDust Masks, Organic vapor masks Goggles, Hand gloves, Gumboots, Helmets

Fire entry suit w/o breathing apparatus YES – 02 Nos.Electric siren with 0.5 km range YES – 01 no.Manual Siren with 1 km range YES – 01 no.

Fire-fighting teamAll personnel of Black Rose Industries have received training on first aid and fire. Refresher training is a continuousprocess.Trained firefighters : available in all shifts + general shiftTrained for :- Fire Fighting / Rescue / SCBA/ First Aid/ Toxic spill control – external as well as internalAdequate fire fighting personnel shall be made available at new plant sections also.

Detectors & alarmsIndustry has installed acrylonitrile gas detectors at critical locations like loading, transfer pump area, near reactorswhere acrylonitrile is consumed. These detectors are connected to the DCS system for continuous monitoring.Suitable alarm set have been programmed in the DCS system for alerting the plant personnel in case of anyleakage.Suitable manual call points for fire alarm system shall also be installed.

Audio alarms with trip system are provided in the DCS to bring the plant under control at any point of time. Online data recorder are provided to monitor the parameters of the process plants. The operators and supervisor arecontinuously taking rounds of the plant and monitoring the processes parameters through local monitoringinstruments provided in the field. Operators are also equipped with Portable Acrylonitrile detectors whenever theyare in field / areas where acrylonitrile is consumed.

A public address system controlled from DCS room warns of abnormal situations throughout the plant for takingquick and corrective action.Plant security personnel are present on all gates of premises and strategic location for the security of the plant. Anyperson or employee or contractor personnel are not allowed without proper purpose / gate pass.CCTV cameras have been installed throughout the plant premises monitoring the site 24x7.

Inhouse medical facilityAn First Aid Centre is developed in the security building equipped with First-Aid facilities. Antidotes for majorchemicals handled by the unit are identified and maintained in the center.It is suggested by EIA consultant to have oxygen administering system at First Aid centre as it is the first aidmeasure for proposed products. Also first-aiders should be given refresher training for first aid measures for the newproducts and raw material especially para –formaldehydeVisiting qualified CIH doctor is appointed as Factory Medical Officer (FMO) - who visits twice in a week to attendroutine work related / non related complaints. FMO is responsible for carrying out pre as well as periodical medicalexamination. The doctor is also accessible for speedy contact and consultation.

External aid for firefighting and medical emergencyDistance of the nearest fire brigade i.e. GIDC Jhagadia Fire Station is @ 5.00 km from the project site and it will take10 min. to reach the project site to take care of any emergencies.Hospitals of Sewa Rural, Jhagadia and Ankleshwar GIDC are within reach

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Unit has own company vehicles for emergency transport. Unit has ensured that one vehicle is always available atsite for Emergency transport. Plant Security personal, having valid driving license, will act as drivers for emergencytransport. Ambulance service from 108 is also available.

Other Emergency control arrangements : Self Contained Breathing Apparatus Oxygen meter dB meter Fireproof Asbestos blanket – 1 no. Foam making unit – 2 nos. Emergency siren – at ECC, tested weekly to check its effectiveness.

It is suggested by EIA consultant to procure Explosive meter for which proponent has agreed.

Assembly pointsIdentificationSr. No

Location of theAssembly Point

AccommodationCapacity

1 Near Security Office 902 Near PCC room 90

The organization has developed an on-site emergency plan to handle emergencies and accidents and upgrades itperiodically.

7.10 VISUALIZATION OF ACCIDENT SCENARIOSBased on the inventory, physical and chemical properties as well as the activities associated with storage andhandling of hazardous chemicals, the largest potential hazard inventories are considered. Different releasescenarios are visualized for these inventories and short-listed for carrying out the consequence analysis.

One scenario considered for all is ‘Catastrophic Failure’, which is the worst case (WC) and frequency of which isvery rare in the lifetime of the plant.

MCA (Maximum Credible Accident) analysis is considered the most appropriate consequence analysis method forrisk assessment since it does not involve quantification of the probability of occurrence of an accident and estimatesthe consequent effects of an accident scenario in terms of damage distances of heat radiation, toxic releases, vaporcloud explosion, pool fire etc. Major hazards posed by hazardous chemical storages can be assessed using MCAanalysis. Hence most credible accident scenarios (MCA) primarily account for leaks from tanks, vessels orpipelines.

Leak in the vessel or leak from the flange joints of these connections is possible. The leak through flangefailure is considered from 50% of flange perimeter and accordingly equivalent area is calculated. This areais approximated to hole of 10mm or 10% of pipe diameter. The small bore pipes less than 2” is consideredfull bore leak.

For our analysis we consider leak from pipeline which are at pump discharge, hence it shall be pressurizedand feeding to reactor or storage.

7.10.1 Selection of Initiating Events and ScenariosFollowing event tree is followed for deciding toxic and/or flammable effects:

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Based on the inventory of hazardous chemicals and their hazardous properties, following accident scenarios havebeen visualized for the given project.

Isolation of acrylonitrile storage area:Acrylonitrile storage tanks are located 20 m away from the utility building. The acrylonitrile storage tank area issituated in downwind direction of wind and is surrounded by a dyke and connected to an isolation tank. The dykeand isolation tank, both are capable of holding 110%of the largest tank’s capacity.Hence, catastrophic failure of tank will not result in pool formation as entire material shall be contained in theisolation tank.

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Based on the inventory of hazardous chemicals and their hazardous properties, following accident scenarios havebeen visualized for the given project.

Isolation of acrylonitrile storage area:Acrylonitrile storage tanks are located 20 m away from the utility building. The acrylonitrile storage tank area issituated in downwind direction of wind and is surrounded by a dyke and connected to an isolation tank. The dykeand isolation tank, both are capable of holding 110%of the largest tank’s capacity.Hence, catastrophic failure of tank will not result in pool formation as entire material shall be contained in theisolation tank.

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Based on the inventory of hazardous chemicals and their hazardous properties, following accident scenarios havebeen visualized for the given project.

Isolation of acrylonitrile storage area:Acrylonitrile storage tanks are located 20 m away from the utility building. The acrylonitrile storage tank area issituated in downwind direction of wind and is surrounded by a dyke and connected to an isolation tank. The dykeand isolation tank, both are capable of holding 110%of the largest tank’s capacity.Hence, catastrophic failure of tank will not result in pool formation as entire material shall be contained in theisolation tank.

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Table 7-3 Worst Case (WCS) and Most Credible Accident (MCS) Scenarios selected for the study

No Hazardous Material PressureBar g

TemperatureDeg C

EquipmentConsidered Scenario Selected Type of Scenario

LeakSizemm

ReleaseDuratio

nmins

Flammable/Toxic

1 Acrylic Acid Atm. Amb. Tank WCS Catastrophic Failure - - Flammable

2 Acrylonitrile 2.0 Amb.Pump/ DischargePipeline

MCS Leak through Pipeline 10 5 Flammable/Toxic

WCS : Worst Case Scenario MCS : Most Credible Scenario

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7.11 CONSEQUENCE ANALYSISHazardous substance on release can cause damage on a large scale in the environment. The extent of damage isdependent upon the nature of the release and the physical state of the material. It is necessary to visualize theconsequences and the damages caused by such releases. The quantification of the damage can be done by meansof various models, which can further be related in terms of injuries and damage to exposed population and buildings.

Software used for consequence analysis for proposed expansion project: ALOHA (AREAL LOCATIONS OFHAZARDOUS ATMOSPHERES)

Is part of the CAMEO suite developed by US Environmental Protection Agency (EPA), ALOHA® is an atmosphericdispersion model used for evaluating releases of hazardous chemical vapors, including toxic gas clouds, fires, andexplosions. Using input about the release ALOHA generates a threat zone estimate. A threat zone is the area wherea hazard (such as toxicity, flammability, thermal radiation, or damaging overpressure) is predicted to exceed a user-specified level of concern. Threat zones can also be plotted on maps with MARPLOT to display the location offacilities storing hazardous materials and vulnerable locations (such as hospitals and schools). Specific informationabout these locations can be extracted from CAMEO information modules to help make decisions about the degreeof hazard posed.

In order to assess the damage, the damage criteria have to be first defined.There are three principle types of exposures to hazardous effects

Heat radiation from a jet, pool fire, a flash fire or a BLEVE

Explosion,

Toxic effects, from toxic materials or toxic combustion productsA basis for the weather conditions (Temperature, wind speed etc.) is chosen for input in these models.

7.11.1 Frequency Estimation:The risk is computed as product of consequence of event and frequency of occurring of the event. As part riskassessment frequency estimation is one of the activity. In literature and published guidelines the frequencies ofcatastrophic failure of various equipment are published. For this assessment the used set of frequencies is takenfrom Dutch Purple book, 2008.Also for credible scenarios the frequencies for leaks from equipment or pipelines are available in the same source asabove. For credible scenario the frequency of leak event is calculated as summation of frequencies of each elementin the considered vessel.

No Item Mode Of Failure Failure Frequency1 Atmospheric Storage Tanks Catastrophic Failure 10E-9 /yr

Significant Leak 10E-5 /yr2 Process Pipelines

<=50mm Dia Full Bore rupture 8.8 x 10E-7 /yrSignificant Leak 8.8 x 10E-6 /yr

>50mm<=150mm Dia Full Bore rupture 2.6 x 10E-7 /yrSignificant Leak 5.3 x 10E-6 /yr

<150mm Dia Full Bore rupture 8.8 x 10E-7 /yrSignificant Leak 2.6 x 10E-6 /yr

3 Hoses Rupture 3.5 x 10E-2 /yr4 Pressure Vessel Catastrophic Failure 3 x 10E-6 /yr

Significant Leak(6" nozzle) 7 x 10E-6 /yr5 Liquid Line Pipeline Leak 3 x 10E-7 /yr

Fittings Leak 5 x 10E-6 /yr

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No Item Mode Of Failure Failure Frequency6 vapor line Leak 3 x 10E-6 /yr7 6" Pipe Leak (1 kg/s) 6x 10E-6 /yr8 3" Pipe Leak (1 kg/s) 6 x 10E-5 /yr9 Flange Leak (1 kg/s) 3 x 10E-4 /yr10 Pump Seal Leak (1 kg/s) 5 x 10E-3 /yr

For warehouse where the drums of chemicals are stored and handled the frequencies are as follows,No Item Mode Of Failure Failure Frequency

1storage of substances inwarehouseswith protection levels 1 and 2

Liquid Spill 1 x 10E-5 Per handling

Fire 8.8 x 10E-4 / yr

2storage of substances inwarehouseswith protection level 3

Liquid Spill 1 x 10E-5 Per handling

Fire 1.8 x 10E-4 / yr

Table 7-4 Failure History dataSN Item International Data Indian Data

1 Process Controller 2.4 x 10-5 hr-1 3.0 x 10-5 hr-12 Process Controller Valve 2 x 10-6 hr-1 2.4 x 10-5 hr-13 Alarm 2.3 x 10-5 hr-1 4.6 x 10-5 hr-14 Leakage at biggest storage tank 5 x 10-5 yr-1 3.0 x 10-5 yr-15 Leakage pipe line 1 x 10-7 m-1yr-1 3.0 x 10-8 m-1yr-16 Human failure 1 x 10-4 (demand)-1 1.8 x 10-3 (demand)-1

Table 7-5 Assumed failure rate for the studySN Item Rupture (yr-1) Leakage (yr-1)

1 Pipe lines<3”3”-15”>15

10-610-7--

10-510-610-8

2 Vessel- pressurized- Atmospheric

5 x 10-61 x 10-5

5 x 10-51 x 10-4

Table 7-6 Damage Due To Incident Radiation IntensityIncident RadiationIntensity (kJ/m²s) Type of Damage62.0 Spontaneous ignition of wood37.5 Sufficient to cause damage to process equipment

25 Minimum energy required for ignite wood at infinitely long exposure (nonpiloted)

12.5 Minimum energy required of piloted ignition of wood, melting plastic tubing etc.

4.5 Sufficient to cause pain to personnel is unable to reach cover within 20 sec.;however blistering of skin (1st degree burns) is likely

1.6 Will cause no discomfort on long exposure

Table 7-7 Physiological Effects Of Threshold Thermal DosesDose Threshold (kJ/m²) Physiological Effect375250125

Third Degree BurnsSecond Degree BurnsFirst Degree Burns

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Dose Threshold (kJ/m²) Physiological Effect65 Threshold of pain, no reddening or blistering of skin caused1st Degree Burns Involve only epidermis, blister may occur2nd Degree Burns Involve whole of the epidermis over the area of burns plus some portion of

dermis3rd Degree Burns Involve whole of epidermis and dermis. Subcutaneous tissues may also be

damaged

Table 7-8 Heat Radiation & Escape TimeRadiation Intensity BTU/hr/ft² Time to Pain Threshold (Seconds)440 (1.39 kW/m²) 60550 (1.6 kW/m²) 40740 (2.33 kW/m²) 30920 (2.9 kW/m²) 161500 (4.7 kW/m²) 92200 (6.93 kW/m²) 63000 (9.5 kW/m²) 53700 (11.66 kW/m²) 46300 (19.9 kW/m²) 2

Table 7-9 Tolerable Over Pressure Limits For Various ObjectsIncident OverPressure (Bar) Object0.02 Schools0.04 Domestic Housing0.05 Public Roads0.07 Ordinary Plant Buildings0.10 Buildings with shatter resistant windows fixed roof tanks containing highly

flammable or toxic materials0.20 Floating roof tanks, other fixed roof tanks, cooling towers, utility areas site roads0.40 Other hazardous plants0.70 Non-hazardous (if occupied) plants. Control room designed for blast resistance.

7.11.2 Assumptions Common for all ScenariosMaximum Temperature Deg.C 41.5Minimum Temperature Deg.C 11.5Maximum Wind speed m/s 6Minimum Wind speed m/s 2Average Wind speed m/s 2-6Wind Direction From South WestHumidity % 70Ground Roughness Urban or ForestCloud Cover % 50

Atmospheric stability class D and E are considered for analysis. The stability classes are selected based on thetemperature & wind velocity. The software prompts most suitable stability class based on temperature & windvelocity. For project atmospheric temperature & wind velocities the software prompted stability classes D & Eare selected for analysis.

Stability class D & wind velocity 6 m/s represents most turbulent atmosphere at site which is ideal to analyzeeffects within or nearby plant area. Stability class E and wind velocity 2 m/s represents most stable atmosphereat the site which is ideal to analyze effects at far distances.

For any particular case if other stability class is chosen, it is included in its detail analysis. It is assumed that sufficient indications and Alarms are configured for effective monitoring

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In case of credible scenario, the release is from 10mm hole and release duration is 5 min. This time includesdetection, response and isolation during event. This assumption is based on the control system, emergencyshutdown system and leak detection systems are available in the plant and discussion with plant personnel.Following points considered,

Pump start / stop facility is available from DCS (Control Room) Sufficient indications and Alarms are configured for effective monitoring This time includes detection, response and isolation during event.

The discharge through leak is modeled as liquid flow through sharp edged orifice and calculated using LiquidDischarge equation.

All storages at atmospheric pressure and temperature. Acrylonitrile and Acrylic acid tanks have nitrogenblanketing. For all pool vaporization initial pool temperature is taken as ambient temperature. If the differenttemperature is taken it is indicated at the specific scenarios assumptions.

The transfer of chemicals from storage tanks to process area/reactor is by means of centrifugal pumps. Thedischarge pressure of pumps is assumed in range of 2 barg.

At respective class atmospheric temperatures if flash point is higher the chemical may not ignite. But to assessthe radiation effect at such situations, the radiation effect is calculated assuming burning is started due to otherignition source

For chemicals having flash point more than 45 degC,the effect is analyzed only for class D. For all toxic material release LC50 and IDLH are taken as the toxic end points. If LC50 is not available then

LD50 values are considered and IDLH values are not available ERPG-2 or ERPG-3 values are considered. For thermal radiation the distances for radiation level 37.5 kw/m2, 4kw/m2 and 1.6kw/m2 are calculated. For vapor cloud explosion the distance for overpressure of 0.5 psi is calculated Fire water system comprises of FW network mains, monitors throughout the plants. The tanks of acrylonitrile and acrylic acid are placed in dyke as below.

Acrylonitrile and caustic are not compatible hence they need to be in separate dyke.

(Ref : CAMEO Chemicals)

Two tanks of Acrylonitrile are placed in separate dyke and Acrylic Acid is in single dyke.Specific assumptions are mentioned in the detailed description of each scenario in following sections. The ALOHAtext summary output and mapping of threat zones superimposed on google earth imagery of the site plan for eachscenario is annexed as Annexure 12.

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In case of credible scenario, the release is from 10mm hole and release duration is 5 min. This time includesdetection, response and isolation during event. This assumption is based on the control system, emergencyshutdown system and leak detection systems are available in the plant and discussion with plant personnel.Following points considered,

Pump start / stop facility is available from DCS (Control Room) Sufficient indications and Alarms are configured for effective monitoring This time includes detection, response and isolation during event.

The discharge through leak is modeled as liquid flow through sharp edged orifice and calculated using LiquidDischarge equation.

All storages at atmospheric pressure and temperature. Acrylonitrile and Acrylic acid tanks have nitrogenblanketing. For all pool vaporization initial pool temperature is taken as ambient temperature. If the differenttemperature is taken it is indicated at the specific scenarios assumptions.

The transfer of chemicals from storage tanks to process area/reactor is by means of centrifugal pumps. Thedischarge pressure of pumps is assumed in range of 2 barg.

At respective class atmospheric temperatures if flash point is higher the chemical may not ignite. But to assessthe radiation effect at such situations, the radiation effect is calculated assuming burning is started due to otherignition source

For chemicals having flash point more than 45 degC,the effect is analyzed only for class D. For all toxic material release LC50 and IDLH are taken as the toxic end points. If LC50 is not available then

LD50 values are considered and IDLH values are not available ERPG-2 or ERPG-3 values are considered. For thermal radiation the distances for radiation level 37.5 kw/m2, 4kw/m2 and 1.6kw/m2 are calculated. For vapor cloud explosion the distance for overpressure of 0.5 psi is calculated Fire water system comprises of FW network mains, monitors throughout the plants. The tanks of acrylonitrile and acrylic acid are placed in dyke as below.

Acrylonitrile and caustic are not compatible hence they need to be in separate dyke.

(Ref : CAMEO Chemicals)

Two tanks of Acrylonitrile are placed in separate dyke and Acrylic Acid is in single dyke.Specific assumptions are mentioned in the detailed description of each scenario in following sections. The ALOHAtext summary output and mapping of threat zones superimposed on google earth imagery of the site plan for eachscenario is annexed as Annexure 12.

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In case of credible scenario, the release is from 10mm hole and release duration is 5 min. This time includesdetection, response and isolation during event. This assumption is based on the control system, emergencyshutdown system and leak detection systems are available in the plant and discussion with plant personnel.Following points considered,

Pump start / stop facility is available from DCS (Control Room) Sufficient indications and Alarms are configured for effective monitoring This time includes detection, response and isolation during event.

The discharge through leak is modeled as liquid flow through sharp edged orifice and calculated using LiquidDischarge equation.

All storages at atmospheric pressure and temperature. Acrylonitrile and Acrylic acid tanks have nitrogenblanketing. For all pool vaporization initial pool temperature is taken as ambient temperature. If the differenttemperature is taken it is indicated at the specific scenarios assumptions.

The transfer of chemicals from storage tanks to process area/reactor is by means of centrifugal pumps. Thedischarge pressure of pumps is assumed in range of 2 barg.

At respective class atmospheric temperatures if flash point is higher the chemical may not ignite. But to assessthe radiation effect at such situations, the radiation effect is calculated assuming burning is started due to otherignition source

For chemicals having flash point more than 45 degC,the effect is analyzed only for class D. For all toxic material release LC50 and IDLH are taken as the toxic end points. If LC50 is not available then

LD50 values are considered and IDLH values are not available ERPG-2 or ERPG-3 values are considered. For thermal radiation the distances for radiation level 37.5 kw/m2, 4kw/m2 and 1.6kw/m2 are calculated. For vapor cloud explosion the distance for overpressure of 0.5 psi is calculated Fire water system comprises of FW network mains, monitors throughout the plants. The tanks of acrylonitrile and acrylic acid are placed in dyke as below.

Acrylonitrile and caustic are not compatible hence they need to be in separate dyke.

(Ref : CAMEO Chemicals)

Two tanks of Acrylonitrile are placed in separate dyke and Acrylic Acid is in single dyke.Specific assumptions are mentioned in the detailed description of each scenario in following sections. The ALOHAtext summary output and mapping of threat zones superimposed on google earth imagery of the site plan for eachscenario is annexed as Annexure 12.

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7.11.3 Summarized Table for effects of ConsequencesTable 7-10 Toxic End points of Consequence Analysis:

No Hazardous Material Equipment Considered Scenario Selected MaterialReleased End Point Endpoint

ConcentrationStabilityClass

MaximumDistance toLC50

MaximumDistance toIDLH

1 Acrylonitrile Pump / Discharge Pipeline MCS - Leak Through 10mm Hole 322 kg LC504hrs

2.09 mg/l 6D <10 492.09 mg/l 2E <10 33

Flammable EndpointsTable 7-11 Flammable End points of Consequence Analysis:

No HazardousMaterial

EquipmentConsidered Scenario Selected Material

ReleasedStabilityClass

Flash FireEnvelopeDiameterLOC(60% ofLEL)

ExplosionOverpressure Distancefor 0.5psi0.05bar

pool/ Jet Fire BurnDuration

Heat Irradiation Maximum distances,m

min 37.5Kw/m2 4Kw/m2 1.6Kw/m2

1 Acrylic Acid Storage Tank CatastrophicFailure 190KL

6D - - Pool fire >60 <10 21 27

2E - - Pool fire This chemical is solid (12 degree c) at atmospherictemperature

2 AcrylonitrilePump /DischargePipeline

MCS - LeakThrough 10mmHole

322 kg6D - - Pool fire <10 11 14

2E - - Pool fire <10 11 16

Note : ‘Material Released’ is the total material discharged to atmosphere. In case of Liquid Pool, from this released material some of the material will be evaporated and dispersed indirection of wind. This evaporated quantity will be less than total quantity depends on the properties of material spilled and atmospheric conditions.Detailed output of aloha with overlay on google earth imagery and site plan is attached as Annexure – 12.

7.11.4 Inference of Consequence analysis The catastrophic failure of atmospheric storage tanks of Acrylic Acid is analyzed, where the released liquid will be contained inside the dyke and pool is formed. Most credible scenario - Radiation effect of pool fire caused by 10mm leak through pipeline of acrylonitrile pipeline is analyzed. 14.0 kw/m2 and 37.5 kw/m2 radiation distance are <

10 m, 1.6 kw/m2 radiation distance are 14 m and 16 m for atmospheric condition D & E respectively. Most credible scenario - The toxic effect of 10mm leak through pipeline of acrylonitrile pipeline is analyzed. The LC50 (2.09 mg/l) distance is <10 m for atmospheric condition D &

E. The IDLH (85 ppm) distance is 49 & 33 m for atmospheric condition D & E respectively and shall not go beyond plant battery limits.

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7.11.5 Risk to Individuals from a Major Release The risk to health to an individual at a specific point in the direction of the plume or heat radiation is dependent on a number of factors, the most important being:

the direction of the wind when the release takes place; and mitigating factors, such as whether the individual might be indoors or out of doors.

In the case of the wind direction, the plume width may be represented by the sector of a circle having an included angle of 15°. In such a case, on the basis that wind direction arise, it ispossible to approximate that an individual present in a single location for one year may be exposed for only 15/360ths of that year or 4 x 10-2

In reality, it is unlikely that a person would be present at any one location in the open air for 100% of the year. Allowing for periods at work or indoors, a risk reduction factor of 3 isreasonably conservative.(three shift operation is considered)

Also the fatality % due to radiation is assumed at 50%.This assumption is based on the response time and the duration of fire in our case. The overall consequence of the mitigation due to wind direction and indoor/outdoor location would be the product of these three factors, namely 1.33 x 10-2. The overall chance of an individual being affected at a specific location by exposure to the toxic gases would be as indicated in following table. From the table it is clear that for catastrophic

failure the distance for 50% fatality is more than MCS scenarios.

Risk To Individual : ToxicNo Hazardous

ChemicalIncident/Different

CasesFrequency ofOccurrence

per yr

No ofJoints/Flanges/

Valves(No of Probableleak locations)

Frequencyof

Occurrenceper yr

ConsequenceMitigation

factor

Frequency ofOccurrence

per yr(RepresentingIndividual Risk)

CumulativeIndividual Risk

(Area wise)

1 Acrylonitrile Leak through 10mmhole

1.00E-05 6 6.00E-05 1.33E-02 7.98E-07 7.98E-07

Risk To Individual : Flammable

No HazardousChemical

Incident/DifferentCases

Consequence EffectOverpressure(psig)/Radiation(kw/m2)

FrequencyofOccurrence

per yr

No ofVessels/Reactors(No of ProbableSources)

FrequencyofOccurrence

per yr

ConsequenceMitigationfactor

Frequency ofOccurrence

per yr(RepresentingIndividual Risk)

CumulativeIndividual Risk(Area wise)

1 Acrylonitrile Leak through10mm hole

Radiation(Pool Fire) 1.00E-05 6.00 6.00E-05 1.33E-02 7.98E-07 7.98E-07

2 Acrylic Acid CatastrophicFailure

Radiation(Pool Fire) 1.00E-05 1.00 1.00E-05 1.33E-02 1.33E-07 9.31E-07

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor Proposed EXPANSION of Synthetic Organic Chemicals In Existing Unit Of M/s. BLACK ROSE INDUSTRIES LTD.At Plot no. 675, Jhagadia GIDC Notified Industrial Estate, Tal- Jhagadia, Dist – Bharuch 393 110, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 227 of 264

7.12 RECOMMENDATIONSTank Storage Area

General:• Caustic and Acrylonitrile should be in separate dyke.• No pumps to be installed inside the dyke.• ACN transfer pumps should have double mechanical seals.• ACN tanks & Acrylic acid tanks are having N2 blanketing.• The tanks shall be provided with breather valve and flammable material tanks breather valves shall be provided

with flame arrester. The tanks shall have an emergency vent. The breather valve & emergency vent should bedesigned as per API 2001.

Fire Protection: The major fire scenario is pool fire. If pool fire arises due to failure of any of the tank inside dyke, it is very important

to prevent failure of other tanks in the adjacent area. This can be achieved by keeping the other tanks cool withwater spray.

It is recommended to have water spray for all the tanks (Acrylonitrile, Acrylic Acid). The actuation of the water spraycan be automatic or manual.

Fire water network providing hydrants and monitors should be around tank farm, reactor building/ process area.Also provision of hydrants on elevated structures and buildings to be ensured.

Only monitors are not sufficient, adequate numbers of hydrants are also required. The hydrants shall be placed notmore than 30m distance between them inside process area and 45m in other & utility area.

The suitable foam fire extinguishing system should be used for pool fire fighting. This can be semi fixed system withconnections to all tanks and dykes and portable foam cans can be used along with fire water monitors around tankfarm.

Fireproofing requirement of structure and equipment supports needs to be analysed and fireproofing to be providedaccordingly.

Emergency vehicle shall move around explosive storage tank farm. In the event of a fire involving acrylonitrile, use alcohol resistant foam, or normal foam if not available, and liquid

tight protective clothing with breathing apparatus.

Instrumentation & Control: Each tank should have one local and one electronic level indicator. The electronic level indicator can be used to

interlock with pumps for stop at high level (unloading pump) and low level (for transfer pump) ACN detectors can be installed at the strategic locations in the plant battery limit which helps in alarming that ACN

is escaping to offsite. ACN is highly reactive and reacts violently with strong oxidizing agents. ACN emits toxic fumes of hydrogen cyanide

and nitrogen oxide when heated to decomposition. Critical switches and alarms shall always be kept online especially in reactor/process area.

Other Recommendations: The plant handles flammable materials like Acrylonitrile and Acrylic Acid, etc. The handling of these materials

requires control of spark, ignition source, and open flame. This is ensured by selecting equipment as perHazardous area classification analysis. Ensure that all electrical installations and instruments are as perhazardous area classification(ref IS 5571 & 5572)

Spiral wound gaskets are recommended for hydrocarbon lines. Screwed fittings should not be used except forstainless steel instrumentation.

Sufficient FW storage and pumping system should be provided as per applicable rules, to support FW network. The construction and fabrication should be as per standard codes and practices (ASME /ANSI / IS etc) as the

failure frequencies will be valid for such construction. If there is some deviation then the frequencies may increase. Provide training for employees in the procedures established for their operating and maintenance functions for

new chemicals to be handled especially monomer, oil and p-formaldehyde. Also a refresher training program atspecific intervals is to be prepared to keep operators updated.

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor Proposed EXPANSION of Synthetic Organic Chemicals In Existing Unit Of M/s. BLACK ROSE INDUSTRIES LTD.At Plot no. 675, Jhagadia GIDC Notified Industrial Estate, Tal- Jhagadia, Dist – Bharuch 393 110, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 228 of 264

Shut off and isolation valves shall be easily approachable in emergencies The fire fighters crew who is responding to emergency involving such chemicals should be aware of toxic effects of

stored chemicals, existing as well as new for this expansion and should use the advised PPEs for thosechemicals.

A wind direction pointer shall also be installed at cavern site so that in an emergency the wind direction can bedirectly seen and downwind population cautioned

Smoking shall be prohibited in designated locations. Work likely to involve flame or sparks, such as, welding orburning, shall be performed only after the area is checked for no presence of flammable material and other safetyarrangement as required.

A proper training shall be given to the staff to handle any emergency situation and use of PPE during the work andemergency.

First-aid centre shall be upgraded as per first aid requirement of new chemicals First-aiders shall also be given training for new chemicals to be handled. Self-Contained Breathing apparatus (SCBA) shall be well maintained for emergency handling. Personal protective equipment to be provided to all the employees related to the type of work and hazard

associated Mutual aid from neighboring industries to be made available whenever need arises. To check preparedness of workers for emergency control, mock drills on regular basis and disaster drills as per

factory inspectorate guidelines to be conducted.

7.13 DISASTER MANAGEMENT PLANThe proponent M/s. Black Rose Industries Limited is already carrying out production activities with a good record ofsafety management. The proposed new plant shall have similar operations as for existing w.r.t production,manufacturing processes, utilities, chemical inventory, process control, safety aspects etc. and with better planttechnology.

Proponent is committed to employ best available technology for manufacturing of proposed products. Latest design andinstrumentations shall be used in process equipment fabrication. The new plant operations shall be DCS controlled withminimum manual operations. The plant design and layout aspects also comply with the applicable regulations andrequirements of industrial ergonomics. Thus, the risks associated with the project are having low probability andseverity.

The Company has obtained certification for compliance with ISO 9001 Quality Management System, ISO 14001Environmental Management System as well as OHSAS 18001 Occupational Health and Safety management. Hence,management’s commitment towards Quality and Environmental conservation is demonstrated by inbuilt systems andprocedures. Certificates are annexed as Annexure – 21.

BRIL management has prepared and implemented an on-site emergency plan in compliance to the requirements of TheChemical Accidents Rules and Factories Act. The DMP includes emergency preparedness plan, emergency responseteam, emergency communication, emergency responsibilities, emergency facilities, and emergency actions.The content page of onsite plan is annexed as Annexure -22.

The plan also includes an OFF site emergency plan for the concerned government authority giving details about steps tobe taken to inform related Government agencies, Medical Centers, Rescue teams and other local agencies, in an eventwhere the emergency poses danger to surrounding area requiring evacuation.

EIA Consultant has reviewed the latest plan assessing suitability and adequacy w.r.t proposed expansion. The reviewpoints are mentioned herewith.

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor Proposed EXPANSION of Synthetic Organic Chemicals In Existing Unit Of M/s. BLACK ROSE INDUSTRIES LTD.At Plot no. 675, Jhagadia GIDC Notified Industrial Estate, Tal- Jhagadia, Dist – Bharuch 393 110, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 229 of 264

7.13.1 Objectives of DMPAs per latest plan - Any additions or modifications required for expansion - To provide resource and methods for effective control of

emergencies arising out of toxic leakage and fire due tohazardous chemicals.

To prevent the emergency turning into a disaster. To enable synchronized action from all the coordinating

agencies with least possible delay. To minimize damages to the property, people and

environment. To permit effective rescue operation and treatment of the

causalities. To train the people to act efficiently and with confidence in

an emergency. To bring the situation back to normal in the least possible

time. To provide information to the local government and semi

government agencies in a timely manner. To minimize its occurrence.

To inform Employees, the general public and the authority /risk assessed, safe guards provided, residual risk if any andthe role to be played by them in event of emergency.

To inform authorities and Mutual Aid centres to come forhelp.

To secure the safe rehabilitation of affected area and torestore normalcy.

To provide authoritative information to the news media To preserve records, equipment etc., and to organize

investigation into the course of the onsite emergency andpreventive measure to stop its recurrence.

To ensure safety of the works before personnel re-enterand resume duty

To work out a plan with all provisions to handleemergencies and to provide necessary inputs foremergency preparedness and periodical rehearsal

7.13.2 Components of DMPAs per latest plan - Any additions or modifications required for expansion - Emergency Organization - structure, duties and

responsibilities of authorities response team, theircoordinators

Communication Action Onsite Off-site Emergency plan

Training, Rehearsal & Records Annexures in prescribed formats

7.13.3 Emergency ResponseAs per latest plan - Any additions or modifications required for expansion - Written procedures for controlling different types of

emergencies Training of workforce for procedures and individual roles

and responsibilities Availability of emergency response equipment with

location and quantity and incharge

Additions for new product manufacturing sections andstorages shall be made in line with the results ofconsequence analysis and other risk assessment studiescarried out by the management as per requirement

Following points shall be kept in mind while preparing theprocedures : The exposure of workers to be limited as much as possible

during the operation Contaminated areas should be cleaned and, if necessary

disinfected Limited impact on the environment at the extent possible.

Levels of EmergencyThe communication system beginning with raising the alarm,declaring the major emergency and procedure to make itknown to others include the following :

There are two Assembly points :Location AccommodationNear Security Cabin AllNear PCC room All

ECC is designated as Security block. ECC shall be equipped withrequired items as per list. ECC in charge as identified for individualECC will maintain it.

Declaring the major emergency Emergency Siren Code Information And Warning Safe Assembly Points Declaration Of Emergency

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor Proposed EXPANSION of Synthetic Organic Chemicals In Existing Unit Of M/s. BLACK ROSE INDUSTRIES LTD.At Plot no. 675, Jhagadia GIDC Notified Industrial Estate, Tal- Jhagadia, Dist – Bharuch 393 110, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 230 of 264

Emergency Communication (Available system at BRIL)As per latest plan - Any additions or modifications required for

expansion -Levels of Emergency and Siren Codes are mentioned in the plan.

On hearing siren – in case of fire – one minute continuous sirenOn hearing siren – in case of toxic leakage / chemical spillage – repeated 15second sirens with 5 second pause over a period of one minuteOffsite emergency - repeated 15 second sirens with 5 second pause over aperiod of three minutes

Electrical Siren has a coverage of 0.5 km areaManual siren has a coverage of 1 km area

Addition of alarms, PA system and sirens innew plant section.

Increase coverage of electrical Siren to 1 kmarea

All clear – Long continuous siren lasting oneminuteTesting - Plain & wailing for one minute onEvery Monday at 1100 hrs.

1) Landline telephones2) Emergency mobile phones3) Emergency phone at Emergency Control Room4) Mobile phone with Senior Engineer5) E-mail communication facilities6) Internet leased line7) Internet dongle in case of leased line failure8) Walkie talkie for use between GIDC Jhagadia units for emergency communications

Any additions or modifications required for expansionThere shall be additional manpower employed in the plant during construction phase as well as operational phase of theexpansion including contract labour. These additional manpower, particularly construction labour shall be given propertraining on the levels of emergency and their role during emergency. Regular inspection and examination of theirawareness about possible incidences and their emergency response shall be undertaken by EHS personnel. Mock drillfor construction labour is also suggested.

Emergency Management Team - additional personnel from new plant sections to be addedThe following emergency management executive/personnel are required to play stellar role in combating theemergency.

Site Main Controller Incident Controller (Manager (Oprns.) /manager (Maintenance)) Deputy Incident Controllers (Deputy Manager / Asst. Manager) Essential Workers Key Personnel Plant Supervisor/Operator Communication Controller/Telephone Operator Personnel Officer Security Officer Safety Officer

The plan designates all positions and also defines the roles and responsibilities of Site Controller, Incident Controllerand other key personnel for emergency control. Personnel from new plant sections shall be added in the list of allpositions of emergency management team.

Controlling emergency - This is not included in existing plan

The existing DMP includes the following : Onsite action and emergency control procedures based on consequence analysis results Evacuation & Transportation Safe Close-Down Use Of Mutual Aid Use Of External Authorities

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor Proposed EXPANSION of Synthetic Organic Chemicals In Existing Unit Of M/s. BLACK ROSE INDUSTRIES LTD.At Plot no. 675, Jhagadia GIDC Notified Industrial Estate, Tal- Jhagadia, Dist – Bharuch 393 110, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 231 of 264

Medical Treatment Accounting for personnel Access to Records Rehabilitation

Mitigation of Environmental Impact during emergency for - Fire, Explosion Chemical Spillage Mitigation of Environmental Impact during emergency for -Fire, Explosion and Chemical Spillage

Addition for new chemicals which shall be handled after proposed expansion :- Hazard information as per MSDS Consequence analysis shall be included together with their emergency control procedures if different from

existing. Antidotes of new chemicals shall also be reviewed and made available with OHC and external hospitals. Specific medical treatment as per MSDS shall be noted by FMO and added in OHC manual and given

training to first-aiders and nurses.

Changes in Annexures to onsite emergency planAnnexure No. Annexure Changes or additions

1. Identification of the factory No. of workers working in all shifts and any other change inincharge personnel

2. Map of the area and Factory Layout To be revised for new sections3. Process & vessel Hazard & Controls Add for new products4. Storage Hazards & Controls Add for new hazardous chemical storages5. MSDS Add for new hazardous chemicals6. Other Hazards & Controls No change7. Evacuation Table Add for new hazardous chemicals to be handled8. Incident Controllers update9. Deputy Incident Controllers update10. Site Main Controllers update11. Key Personnel update12. Essential Workers update13. Assembly Points No change14. Emergency Control Centre revise with new site plan, list of new Emergency organization15. Fire & Toxicity Control Arrangements Update for new fire hydrant components installed at new plant16. Medical Arrangements update17. Transport & Evacuation arrangements update18. Alarms and Sirens Update with new sirens, alarms and detectors installed at new

plant areas and storage areas19. Internal Phones update20. External Phones update21. Nominated persons to declare major

EmergencyNo change

22. A form to record Emergency Telephonecalls

No change

23. Statutory communication update

Offsite Emergency Preparedness – already addressed in existing planAbstracts of Latest District Disaster Management Plan (DDMP) downloaded from website of Bharuch Collector’s Officeare presented herewith for information on emergency control facilities available in this region :-

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor Proposed EXPANSION of Synthetic Organic Chemicals In Existing Unit Of M/s. BLACK ROSE INDUSTRIES LTD.At Plot no. 675, Jhagadia GIDC Notified Industrial Estate, Tal- Jhagadia, Dist – Bharuch 393 110, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 232 of 264

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor Proposed EXPANSION of Synthetic Organic Chemicals In Existing Unit Of M/s. BLACK ROSE INDUSTRIES LTD.At Plot no. 675, Jhagadia GIDC Notified Industrial Estate, Tal- Jhagadia, Dist – Bharuch 393 110, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 232 of 264

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor Proposed EXPANSION of Synthetic Organic Chemicals In Existing Unit Of M/s. BLACK ROSE INDUSTRIES LTD.At Plot no. 675, Jhagadia GIDC Notified Industrial Estate, Tal- Jhagadia, Dist – Bharuch 393 110, Gujarat State, India

Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 232 of 264