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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

CHAPTER 6 RISK ASSESSMENTS AND SAFETY MEASURES

6.1 PREAMBLE

Increasing use of hazardous chemicals as raw materials, intermediates and finished products has attracted attention of the Government and the public at large in view of the chemical disasters. The serious nature of the accidents, which cause damage to the plant, personnel and public, has compelled industries to pay maximum attention to the safety issues and also to effectively manage the hazardous material and operations. It is mandatory for the industries handling hazardous chemicals to maintain specific safety standards and generate an on-site emergency plan and keep it linked with offsite emergency plan.

The Risk Assessment Study and Safety Management for the proposed expansion of M/s. Trisha Speciality Chemicals Pvt. Ltd. have been carried out and the details are elaborated in this chapter. Based on the findings & recommendations of RA report risk management plan for the proposed project has also been prepared and included.

Risk Assessment is defined as a continuous and integrated process of identification, evaluation and measurement of risks, along with their potential impact on the organization.

The benefits of risk assessment include the following:  Prevention or reduction in occurrence of accidents.  Mitigation of the severity and/or consequences by way of improved process techniques, fire protection systems, arrangements of storage, inventory monitoring to fit production requirements.  Development of confidences in employees by improving competency.  Preparedness and prompt response to deal with any accident.

The safety management includes the implementation of preventive methods or accident prevention methods to avoid incident or accident and handling of emergency in case of accident.

6.2 Objectives & methodology of risk assessment study

A three ‘LEVEL’ risk assessment approach has been adopted. The brief outline of the three tier approach is given below:

 Level 1 Risk Screening

This is top down review of worst case potential hazards/risks, aimed primarily at storage of chemicals, which pose the highest risk. The Material Safety Data Sheets (MSDS) of the chemicals were reviewed to identify the potential hazards posed by the chemicals. Various screening factors considered include: o Inventory of hazardous materials; o Hazardous properties;

RAONEP Report Prepared by Ahmedabad 1 Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

o Storage capacity

 Level 2 Risk Scenario Identification

After identification of potential hazards, different risk scenarios were delineated for each of the chemicals based on the nature of hazard.

 Level 3 Quantitative Risk Assessment

ALOHA 5.4.7 version software was used for the risk assessment of the raw materials and products, which will be stored at the premises. Risk assessment was carried out for each of the risk scenarios identified for the chemicals in case of leakages from the storage tanks. Worst possible scenarios were taken into account for the risk analysis.

6.3 Hazards Classification

6.3.1 Details of Hazardous Chemicals

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Table 6.1: Hazardous chemical Identification as per MSIHCR with storage details Day Tank Storage Tank details, MT Total Hazardous Falling under category of Threshold Storage Storage No. Hazard Chemical name MSIHC Rules Quantity in MT Capacity, MT Existing Proposed Total capacity, MT 1 Caustic lye 1. As per Schedule 1 Part I (a) - 3 37 - 37 40 Corrosive sr. no. 3 as Toxic chemical as

LD50 as 90 mg/kg falling between 50 to 200 mg/kg 2. Sr. no. 571 of schedule 1 part II 2 Formaldehyde 1. As per Schedule 1 Part I(b) 5 T for rule 5,7- 1.62 27.00 - 27.00 28.62 Flammable , (v) as flammable liquid 9,13-15 toxic under rule 2e (i), 4 (1)(a), 4(2), 17 and 18 50 T for 10-12 2. As per Schedule 1 Part I (a) sr. no. 3 as Toxic chemical as

LD50 as 100 mg/kg falling between 50 to 200 mg/kg 3. Sr. no. 285 of schedule 1 part II 4. Sr. No. 112 of Group-2 Toxic Substance in Schedule 3 Part I 3 Octanol 1. As per Schedule 1 Part I(b) - 3 - 25 25 28 Flammable (iii) as very highly flammable liquids under rule 2e (i), 4 (1)(a), 4(2), 17 and 18 4 Oleum (23 %) 1. Sr. No. 121 of Schedule 3 15 t (as 5.67 - 38.00 38.00 43.67 Corrosive

Part I Group 2 Toxic Tiroxide-SO3) for &toxic substance rule 5, 7-9 and 2. Sr. no. 444 of schedule 1 75 t for 10 to 12 part I as Oelum

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Day Tank Storage Tank details, MT Total Hazardous Falling under category of Threshold Storage Storage No. Hazard Chemical name MSIHC Rules Quantity in MT Capacity, MT Existing Proposed Total capacity, MT 3. Sr. No. 590 of schedule 1 part I as 4. Sr. no. 11 of Schedule 2 Sulfur Trioxide storage as Isolated storage 5 Sulphuric Acid 1. Group -2 – Toxic Substances - 2.76 37.00 - 37.00 39.76 Corrosive – sr.no.121-

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Table 6.2: Characteristics of hazardous chemicals to be used as per the MSIHC Rules

Main properties (refer MSDS, Sch‐9 of MSIHC Rules)

Full name of State : Solid, LD Sr. No. LEL 50 product Liquid or Gas LC mg/kg -oral B.P. F.P. 50 Specific Gravity Vapor Density mg/kg °C °C UEL (Water = 1) (Air = 1) LD % 50 mg/L -dermal 1 2 3 6 7 8 9 10 11 12 1. Caustic Lye Aqueous 1388 N.A. N.A. N.A. N.A. 2.300 -- 6 100 2. Formaldehyde Liquid 96 50 203 1.080 0.62 to 1.04 36 270 2047 3. Octanol Liquid 184 77 -- 1400 0.827 4.5 >2600

- 4. Oleum (23%) Liquid 100-140 -9 to 30 -- -- 1.892 --- 500

Sulphuric Acid -- 5. Liquid 270 – 340 -- 510 2140 1.840 3.4 (98%) --

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6.3.2 Potential Hazard Classification

The hazard classification has been carried out based on the data provided in MSDS data sheets and as per the classification MSHIC Rules, 1986 and its amendments thereof. The hazard classification is given in Tab

Table 6.3: Potential Hazard Classification and Analysis of Chemicals to be handled in the Proposed Expansion Unit No. Hazardous Chemical Hazard Rating System Type of Hazard/Risk Involved name 1 Oleum (Toxic and TLV – 5 ppm, STEL – 10 ppm,  Toxic when contact with skin Corrosive Liquid) NFPA ratings: Health – 4 , Flammability -2 ,  Cause Burns Instability – 0 , Flash Point – NA  Toxic , if swallowed  Irritating to skin , eye and respiratory system 2 Octanol (Flammable TLV: - STEL: -  Highly flammable and Corrosive liquid) NFPA ratings:Health: 2; Flammability: 2;  Toxic when contact with skin Instability:0  Toxic by inhalation o Flash Point: 81 C  Toxic , if swallowed  Danger of very serious irreversible effects 3 Formaldehyde TLV – 0.3 ppm (1 ppm ),  Flammable (Corrosive Liquid) NFPA ratings: Health – 3 , Flammability -2 ,  Toxic when contact with skin Reactivity – 0 ,  Toxic by inhalation Flash Point – 50°C  Toxic , if swallowed  Causes burn  Limited evidence of carcinogenic effect  Risk of serious danger to eyes. 4 Sulphuric Acid TLV – 1mg/m3,  Toxic when contact with skin (Corrosive& Reactive) NFPA ratings: Health – 3 , Fire – 0 Physical-2 ,  Toxic by inhalation Personal Protection – C  Toxic , if swallowed  Causes burn  Limited evidence of carcinogenic effect  Highly reactive.  Reacts violently with: many chemicals, including, water

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No. Hazardous Chemical Hazard Rating System Type of Hazard/Risk Involved name  Corrosive to: aluminum alloys, carbon steel, and other metals.  Risk of serious danger to eyes. 5 Caustic Lye (Corrosive STEL – 2mg/m3,  Flammable & Reactive) NFPA ratings: Health – 3 , Flammability– 0  Toxic when contact with skin Instability-1  Toxic by inhalation  Toxic , if swallowed  Causes burn  Limited evidence of carcinogenic effect  Risk of serious danger to eyes.  Incompatible Materials: Highly reactive.  Reacts violently with: many chemicals, including, water, organic acids (e.g. acetic acid), inorganic acids (e.g. hydrofluoric acid), oxidizing agents (e.g. peroxides), metals (e.g. aluminum)  Corrosive to: aluminum alloys, carbon steel, and other metals

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6.4 Risk Scenarios:

6.4.1 Worst Case Scenario:

In worst case scenario conditions, For projection of maximum effects due to release of chemicals is considered by considering maximum amount of chemical leakage or at sudden release of all the chemicals within a minute time, in the atmosphere, with considering meteorological data for projection of probable loss of chemicals, release of fumes, vapor and area covered, number of persons affected.

It is projection at project stage, to take preventive measures to avoid such type of incidents, at actual level. It is also useful for training and awareness for company employee and surrounding village or nearby people by giving proper information in prior, to take care of emergency in real condition.

6.4.2 Maximum Credible Accident (MCA)

A Maximum Credible Accident (MCA) can be characterized as the worst credible accident. In other words: an accident in an activity, resulting in the maximum consequence distance that is still believed to be possible.

A MCA-analysis does not include a quantification of the probability of occurrence of the accident. Another aspect, in which the pessimistic approach of MCA studies appears, is the atmospheric condition that is used for dispersion calculations. As per the reference of the study, weather conditions having an average wind speed of 3.0 m/s have been chosen.

The objective of the study is Emergency planning, hence only holistic & conservative assumptions are used for obvious reasons. Hence, though the outcomes may look pessimistic, the planning for emergency concept should be borne in mind whilst interpreting the results.

6.4.3 Consequence Analysis Calculations:

The Consequence Analysis has been done for selected scenarios. This has been done for weather conditions having wind speed 3.0 m/s. In Consequence Analysis, geographical location of the source of potential release plays an important role. Consideration of a large number of scenarios in the same geographical location serves little purpose if the dominant scenario has been identified and duly considered.

Software Used for Calculations:

ALOHA (Areal Locations of Hazardous Atmospheres): Aloha is a computer program designed especially for use by people responding to chemical accidents, as well as for emergency planning and training. ALOHA can predict the rates at which chemical vapors may escape into the atmosphere from broken gas pipes, leaking tanks, and evaporating puddles. It can

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then predict how a hazardous gas cloud might disperse in the atmosphere after an accidental chemical release.

ALOHA is an air dispersion model, which you can use as a tool for predicting the movement and dispersion of gases. It predicts pollutant concentrations downwind from the source of a spill, taking into consideration the physical characteristics of the spilled material. ALOHA also accounts for some of the physical characteristics of the release site, weather conditions, and the circumstances of the release. Like many computer programs, it can solve problems rapidly and provide results in a graphic, easy-to-use format. This can be helpful during an emergency response or planning for such a response.

6.4.4 Scenarios: Based on the identified potential hazards of the chemicals, different scenarios were delineated as given in following Tables:

Table 6.4: Possible Accident Scenarios at M/s. Trisha Specialty Chemicals Pvt. Ltd. Scenario* MCL Pressure Temp. Qty. 1 Release of Oleum - Ambient Ambient 96 kg *Scenario for Oleum is as follows, Table 6.5: Worst Case Scenario Scenario MCL Red Zone, meter Orange Zone, meter Yellow Zone, meter 1 Release of Oleum <10 <10 60

Modeling Output:

The modeling output for the identified potential riskscenarios for oleum is given below.

SITE DATA: Location: TSCPLGIDCKERALBAVLA, INDIA Building Air Exchanges Per Hour: 0.19 (sheltered double storied) Time: December 14, 2016 1604 hours ST (user specified)

CHEMICAL DATA: Warning: OLEUM can react with water and/or water vapor. This canaffectthe evaporation rate and downwind dispersion. ALOHA cannot accuratelypredict the air hazard if this substance comes in contact with water. Chemical Name: OLEUM Solution Strength: 23% (by weight) Ambient Boiling Point: 131.5° C Partial Pressure at Ambient Temperature: 9.37e-004 atm Ambient Saturation Concentration: 940 ppm or 0.094% Hazardous Component: SULFUR TRIOXIDE CAS Number: 7446-11-9 Molecular Weight: 80.06 g/mol AEGL-1 (60 min): 0.2 mg/cu m) AEGL-2 (60 min): 8.7 mg/cu m) AEGL-3 (60 min): 160 mg/cu m)

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

ATMOSPHERIC DATA: (MANUAL INPUT OF DATA) Wind: 1 meters/second from NE at 3 meters Ground Roughness: 3.0 centimeters Cloud Cover: 5 tenths Air Temperature: 14° C Stability Class: B No Inversion Height Relative Humidity: 50%

SOURCE STRENGTH: Evaporating Puddle Puddle Area: 5 square meters Puddle Mass: 96 kilograms Ground Type: Concrete Ground Temperature: 14° C Initial Puddle Temperature: Ground temperature Release Duration: ALOHA limited the duration to 1 hour Max Average Sustained Release Rate: 2.51 grams/min (Averaged over a minute or more) Total Amount Hazardous Component Released: 150 grams THREAT ZONE: Model Run: Gaussian Red: less than 10 meters --- (160 mg/cu m) = PAC-3) Note:Threat zone was not drawn because effects of near- fieldpatchinessmake dispersion predictions less reliable for short distances. Orange:less than 10 meters --- (8.7 mg/cu m) = PAC-2) Note: Threat zone was not drawn because effects of near-field patchinessmake dispersion predictions less reliable for short distances. Yellow: 59 meters --- (0.2 mg/(cu m) = PAC-1)

The output is superimposed on Boundary of Trisha Speciality Chemical Pvt Ltd in Google Map and shown as Image 6.1.

Interpretation: Estimated maximum distance is 60 meter from the source of release from the tank source.

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

6.5 Risk Assessment

After the identification of hazards and likely scenarios, risk assessment was carried out for oleum using the ALOHA software and the risk associated with different types of chemicals is described in following table.

Table 6.6: Types of Risk Associated With Different Types of Chemicals Sr. Type of Name Causes No. Chemical 1. Corrosive  Sulphuric Acid Eye irritation, skin allergy. Sometimes ingestion Chemicals  Formaldehyde and inhalation of such chemical causes gastro-  Caustic Flakes intestinal irritation and damage to the central nervous system. 2. Flammable  Octanol It creates worst case of fire hazard or explosion chemicals  Oleum and it is major threat. Cause high-level thermal radiation, and smoke which may effects the nearby area as well as the persons working in that area also. This type of chemicals are stored in such condition to prevent the fire and handled very carefully. Thermal shock and reactive chemicals produces fire explosion that affects nearby areas as well as workers working in that area. 3. Toxic  Sulphuric Acid Form vapor clouds or fumes having lower Chemicals  Oleum concentration are hazardous then the flammable component. Organic solvents are toxic in nature.

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6.5.1 Corrosive Liquids a) Name of the Chemicals associated with the risk: Sulphuric Acid, Oleum b) Type of Associated Activity: Handling, storage and process c) Type of Storage: Tank Table 6.7: Risk description and control measures for Sulphuric Acid & Oleum No. Potential Sub Hazard Risk Assessment Control Measures Hazard Severity Probability Risk 1. Injury due Body Injury Serious Highly Moderate 1. Proper to forklift Unlikely maintenance of forklift shall be done. 2. Container Eye Serious Highly Moderate 1. Proper personnel fall from Contact Unlikely protective forklift & equipment like material gloves, goggles, Skin Moderate Unlikely Moderate spillage apron, helmet, contact gumboot etc. will be provided. Inhalation Minor Highly Minor Unlikely 2. Inert material (e.g., vermiculite, dry sand or earth) Slip & Fall Serious Highly Moderate will be provided Unlikely which can absorb the chemicals 3. Leakage Eye contact Serious Highly Moderate leaked or spilled. from Unlikely container 3. Eye washer & shower will be Inhalation Minor Unlikely Minor provided. Skin Minor Highly Minor contact Unlikely 4. Leakage in Fire Serious Highly Moderate 1. Provide training to presence of Unlikely the workers and ignition employee to sources handle the worst scenario. 2. Use spark-proof equipment during handling. 5. Electrical Fire, Injury Serious Highly Major 1. Proper enclosure shock circuit & Loss of Unlikely of Electrical property equipment with earthing will be provided.

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

6.5.2 Flammable & Toxic Liquids a) Name of the Chemicals associated with the risk: Octanol b) Type of Associated Activity: Handling, storage and process c) Type of Storage: Tank Table 6.7: Risk description and control measures for Octanol No. Potential Hazard Sub Risk Assessment Control Hazard Measures Severity Probability Risk

1. Drum/Carboys Injury Moderate Unlikely Moderate 1. Proper Falling From personnel Palette from protective equipment height or loading like gloves, /unloading goggles, material to tank Spillage Moderate Unlikely Minor apron, via pump helmet, gumboot etc. will be provided. 2. Inert material (e.g., vermiculite, dry sand or earth) will be provided which can absorb the chemicals leaked or spilled. 3. Good quality palate should be used. 2. Leakage from Eye Serious Unlikely Moderate 1. Proper drums/carboys contact personnel protective Inhalation Moderate Unlikely Moderate equipment like gloves, of vapour goggles,

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

Skin Moderate Unlikely Moderate apron, contact helmet, gumboot etc. will be provided. 2. Inert material (e.g., vermiculite, dry sand or earth) will be provided which can absorb the chemicals leaked or spilled. 3. Escape of Vapor Inhalation Minor Likely Moderate 1. Proper from during of Vapor ventilation handling should be provided to Fire Serious Highly Moderate allow escaping the unlikely vapor fumes. 2. Flameproof Electrical equipment & safety gadgets like fire extinguisher should be provided. 4. Injury due to Body Serious Highly Moderate 1. Proper Forklift Injury Unlikely maintenance of forklift shall be done.

6.5.3 Accident Record No major and minor accidents were reported.

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

6.6 Preventive and Mitigate Measures

6.6.1 Safety Measures for Storage of Hazardous Chemicals

6.6.1.1 General Recommendations for Storages:

Main Risk prevailing at storage tank is Fire, Following measures is ensured for prevention/ control of fire at storage tanks.  Availability of water supply  Fire reservoir of sufficient quantity  Fire hydrant and monitor nozzle installation  Foam system  First aid appliances  Secondary containment for the storage of hazardous chemicals.  Toxic and flammable gas leak detection , alarm and control system  Critical switches and alarm should be always kept in line.  Fire extinguishers should be tested periodically and should be always kept in operational mode.  Fire detectors should be installed near those points which handle large amount of material and operate under high temperature and pressure.  Shut off and isolation valves should be easily approachable in emergencies.  Surrounding population (includes all strata of society) should be made aware of the safety precautions to be taken in the event of any mishap within the plant. This can effectively be done by conducting the training programs.  A wind direction pointer should also be installed at storage site, so that in an emergency the wind direction can be directly seen and downwind population can be cautioned.  The fire protection equipment shall be kept in good operating condition at all time and firefighting system should be periodically tested for proper functioning and logged for record and corrective actions.  Fire exit for escape  Persons to be trained for handling any type of emergencies.  Persons to be trained for use of fire extinguisher, fire control system.  First –Aid training to be provided to every employee and necessary first –aid facility with anti-dotes to be kept ready.  Alternate power availability ( D.G. Set )  Provision of railing for height area , with toe guard  Earthing provision, for flange joint  Provision of proper heat insulation  Noise Control facility , or PPEs  Interlock system for storage tanks and vessels  Machine guarding

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

6.6.1.2 Handling and storage of Oleum /

Following measures shall be ensured for storage and handling.  Dyke with slopped ground floor  Tank vent is to be connected with Sulfuric acid storage tank/submerged water bath  A nearby safety shower and eye washer availability of water supply  Availability of sand bucket or slaked lime  SCBA and acid-proof hand gloves , availability  Level indicator  Tank Labeling  Tanker outlet valve should be of SS with Teflon coating and leak proof  DCP fire extinguishers availability  Fire UG tank of sufficient quantity  First aid appliances  Secondary containment for the storage of hazardous chemicals.  Fire extinguishers should be tested periodically and should be always kept in operational mode.  Surrounding population (includes all strata of society) should be made aware of the safety precautions to be taken in the event of any mishap within the plant. This can effectively be done by conducting the training programs.  A wind direction pointer should also be installed at storage site, so that in an emergency the wind direction can be directly seen and downwind population can be cautioned.  The fire protection equipment shall be kept in good operating condition at all time and firefighting system should be periodically tested for proper functioning and logged for record and corrective actions.  Fire exit for escape  Persons to be trained for handling any type of emergencies.  Persons to be trained for use of fire extinguisher, fire control system.  First –Aid training to be provided to every employee, and necessary first –aid facility to be kept ready.  Alternate power availability ( D.G. Set )  Provision of railing for height area, with toe guard  Interlock system for storage tanks and vessels

6.6.1.3 Preventative Measures for incidents that might be occurred due to oleum: Some of the preventative measures that will be undertaken to avoid the occurrence of this type of incident include:  Handling by trained experienced personnel only.  Provision for remote shut-off facility, area will be barricaded, only authorized person entry, no smoking board, DCP type fire extinguisher to be provided.  Probable affected person will be aware/educate about probable hazard risk and response in case of emergency. First-Aid facility will be provided with trained person availability and all required contents.

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

 Flameproof electrical fittings will be used at chemical storage area.  Equipment’s containing the material will be grounded to prevent static electricity.  Onsite emergency plan prepared and mock drill will be carried out.  Safety sign board displaying Do’s and Don’ts at work place and storage area in local language, MSDS will be made available.  Proper and effective Personal Protective Equipment’s will be provided.  Highly controlled and closely monitored operations.

Remedial Actions and Recommendations: • Spare tank provided to transfer the material in case of leak. • Stock of dry sand & lime is kept near the storage area, • Provision of Respiratory protective equipment & personal protective equipment, • Safety shower & eye wash unit installed. • Strict supervision while unloading, regular testing & inspection of tanks  Evacuate the affected area.

6.6.2 Preventive control Measures to avoid/Control Worst Case Scenario & MCA (Maximum Credible Accident) Scenario

We have considered or assumed worst case scenario modeling for preparedness of Emergency situation only. Oleum & Octanol will be stored with provision of Dyke wall facility and emergency storage tank, and necessary precautions.

However, some precautions and control measures are as under:

• Formaldehyde, Sulfuric Acid and Caustic Lye are stored in storage tanks having RCC enclosure to safeguard leakages, losses and damages. • Oleum & Octanol will be stored in storage tanks having RCC enclosure to safeguard leakages, losses and damages.

Type of Hazard possible and Control Measures provided 1) Octanol • Frequent inspections, no smoking–spark– ignition on Open flame in the vicinity • Provided Hose pipe with sufficient length to fight fire from distance. • Safe operating practices are formed. • Storage of water & overhead water tank to fight fire or accidental leak. • Dry sand near tank to contain leak & PPEs are provided. • Spare tanks/drums provided 2) Formaldehyde • Detached storage area. • Spare tank provided to transfer the material in case of leak. • Stock of dry sand is kept near the storage area. • Provision of Respiratory protective equipment & personal protective equipment.

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

• Safety shower & eye wash unit installed • Strict supervision while unloading, • Regular testing & inspection of tanks.

6.6.3 Mitigation Measures during Manufacturing Activity:

The key strategy for managing the potential risks associated during manufacturing activity will be the development and implementation of the following actions, policies and procedures.

Facilities and Resources:  Chemical storage facilities to comply with relevant legislation, standards, building codes as well as codes of practice with regard provision of ventilation and separation requirements;  Sufficient quantities of spill response equipment for containing and cleaning up chemical and fuel spills; and  Fire equipment to comply with relevant legislation, standards, building codes as well as codes of practice.

Management Policies, Plans & Procedures:  Incident Reporting Policy  Fire Action Plan (including preventative measures)  Environmental Management Plan  Maintenance Schedule  Spill Response Procedures

Training:  Chemical storage (separation and ventilation requirements), handling (reading labels, MSDS etc) and response (spill containment and clean up);  Oil spill containment and clean-up;  Fire safety (identifying and managing fire risks and suppression techniques);  Incident reporting  Operation of equipment

Maintenance:  Inspect and maintain equipment as per legal requirements (fire equipment), the maintenance schedule (machinery, facilities vehicles and tools) and documented procedures (spill response equipment and chemical stores); and  The routine inspection and monitoring of equipment.

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

6.6.4 Process hazards and controls Sr. Name of Name of Materials Name of Operating Types of Control No. the plant, the in the the parameters hazards measures Department hazardous process vessel (pressure, possible provided or place process operation and its temperature (Exothermic. and with their location etc.) Run away operation quantity pressure release, toxic release, fire, explosion etc. Main Plant Mixing Oleum Jacketed NTP endothermic No manual + + vessel reaction handling, Heating Octanol with followed by enclosed + + stirring exothermic reaction, no Pulverising TEA gas fume + generation, Filtration Exothermic + reaction is controlled by Drying cooling in jacket. cooling is ensured by cooling pump temperature & pressure indicators, SV provided

6.7 Occupational Health & Safety Program

M/s. Trisha Specialty Chemicals Pvt. Ltd. is committed towards the Health and Safety of workers and provided a facility of pre medical and regular medical check-up of employees for detecting any kind of adverse effect on the health of employee due to the chemical or work place condition and providing opportunity to improve the working condition. The workers exposed to fugitive emission will be provided with some protective devices like dust mask to prevent respiratory disorders. The workers exposed to higher noise level will be provided with ear muffs/ ear plugs.

The protective devices will be provided to the employees handling hazardous substances. Proper handling of the hazardous chemicals and the maintenance of Material Safety Data Sheet (MSDS) will be followed to ensure safety within the plant area.

Drinking water supply for the employees will be provided by the project proponent and the

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standard of the drinking water will be as per WHO guidelines. Proper sanitary facilities will be made available by the project proponent so that employees do not suffer from any health ailments.

The employees will be made aware of general sanitary practices. Periodical training programme to inform the employees about their task, associated risk, and safe-working practices will be undertaken.

Training will also include information on accident prevention, proper control and maintenance of equipment and safe material handling practices.

A regular monitoring of the Occupational Health and Safety will reduce the chances of accidents hence all the records of job related accidents and illness should be maintained as per the requirements of factory act. This information will be reviewed and evaluated to improve the effectiveness of Environmental Health and Safety programme.

The following occupational measures will be adopted:  The workers will be provided with personal protective equipment’s such as gloves, goggles, safety shoes, helmets and dust masks.  Periodic medical checkup of the workers for audiometric, blood tests, physical examination, etc. as per applicable rules.  First aid medical facility will be made available at the site and medical kit will be made available at strategic location and plant personnel will be trained for first aid medical treatment.  Dispensary and medical facility is available in the nearby GIDC area and that will be utilized in the case of emergency. However. The company will appoint one doctor for further consultation and treatment in case of emergency.

Table6.9 : Details of PPEs should be provided: No. Department Identified No. of PPE provided to Contaminant exposed each workers workers 1 Dryer Formaldehyde 30 Dust Masks , Safety Goggles and Safety shoes 2 Process Formaldehyde , octanol , 4 Dust mask, Safety acid Goggles , Apron , Safety Gloves 3 Boiler SPM 6 Helmet , Dust Masks , Safety Goggles , Safety Shoes , Safety Gloves , Apron 4 Press Formaldehyde 30 Dust Masks , Safety Goggles , Safety Shoes , Safety Gloves 5 Cutting and RSPM 10 Helmets , Dust Masks ,

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

Sanding Safety Goggles , Safety Gloves , Safety Shoes 6 ETP RSPM 1 Helmet , Dust Masks , Safety Shoes , Safety Gloves , Safety Goggles 7 Laboratory Formaldehyde 2 Dust Masks , Safety Gloves , Apron, Safety Goggles , Safety Shoes 8 Office Staff Formaldehyde 20 Dust Masks

6.8 On Site Emergency Plan and Disaster Management Plan:

As emergency is said to have risen when operators in the plant are not able to cope with a potential hazardous situation i.e. loss of an incident causes the plant to go beyond its normal operating conditions, thus creating danger. When such an emergency evolves, chain of events which affect the normal working within the factory area and / or which may cause injuries, loss of life, substantial damage to property and environment both inside and around the factory takes place and a DISASTER is said to have occurred.

Various steps involved in Disaster Management Plan can be summarized as follows: 1. Minimize risk occurrence (Prevention) 2. Rapid Control (emergency response) 3. Effectively re habitat damaged areas (Restoration)

Disaster Management Plan is evolved by careful scrutiny and interlinking of a. Types and causes of disaster b. Technical know-how c. Resource availability

Types of Disaster: a. Due to Fire and Explosion b. Due to Vapor Cloud c. Due to Toxic Gas Release from: i. Within the Unit ii. External Sources d. Hurricane, Flood, Cyclone and other Natural Calamities

This plan is developed to make best possible use of resources to: • Reduce possibilities of accident. • Contain the incident and control it with minimum damage. • Safeguard others • Rescue the victims and treat them suitable. • Identify the persons affected/ dead. • Inform relatives of the causalities. • Provide authorities information to the news media. • Preserve relevant records and equipment needed as evidence in case of any inquiry.

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

• Rehabilitate the affected areas.

The primary purpose of the on-site emergency plan is to control and contain the incident and so as to prevent from spreading to nearby plant. It is not possible to cover every eventuality in the plan and the successful handling of the emergency will depend on appropriate action and decisions being taken on the spot. Following three staged activities are suggested as they are co-related and provide better points for emergency preparedness, emergency action and subsequent follow up.

6.8.1 Pre- Emergency Activity: The following are the details of Pre-emergency plan: Internal Safety Survey

It is conducted by Safety department. • To identify various hazards in plant area. • To check protective equipment of workability. • To check various Safety installations. • To check fire system, fire water pumps, water shower etc. • To suggest extra modification required.

Third Party Survey Experts of consultants conduct Third Party Survey. • To identify various hazards inside the factory. • To conduct survey on available Safety equipment. • To check built in safety system for its efficiency. • To suggest modification/new additions in the system.

Non-Destructive Testing (NDT)

• To prepare a list of equipment/pipe lines for non-Destructive testing. • To prepare a plan for replacements/repairs as per testing reports. • To maintain Plant wise record to compare with the last period.

Safety valve Testing

• To prepare a list in the plant. • To prepare a periodic schedule for their testing & maintaining record. • To prepare a plan for replacements/repairs.

Fire Fighting system Testing

• To prepare a list of fire hydrants, Fire Fighting appliances, Fire water pumps and other available appliances and maintain the record. • To plan for testing schedule. • To replace defective equipment/accessories. • To check fire water pumps capacity.

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

• To check all firefighting equipment/appliances under fire services for operability.

Mock drills

• To conduct internal mock drill for training the workers. • To conduct drills to check the performance of workers and equipment. • To know the draw backs/defects of the system and its corrective actions.

Training

• To operate regular training of employees for handling various safety equipment. • To train workers for fire emergency. • To educate workers for different type of emergency.

Personal Protective Equipment (PPE)

• To arrange for sufficient quantity of personal protective equipment. • To train workers to use each PPE. • To maintain them in good condition

Communication

• To maintain internal/external communication system in good working condition. • To modify the siren sound for emergency. • To install wind-sacks to indicate wind direction.

Emergency Lights • To check and maintain the emergency lights in control room and selected areas. • To keep sufficient number of torches in supervisor’s cabin/plant and in each department.

Emergency Control Room

• To identify the place of emergency control room. • To identify the alternative emergency control room. • To keep sufficient quantity of PPE in control rooms. • To provide proper telephone system in emergency control room. • To provide plan of the factory showing hazardous points and emergency control point in emergency control room.

Assembly Points • To identify the location for assembling the plant emergency staff and co-ordinate in case of emergency • To utilize the services of others to fix assembly points for non-essential workers and to assemble in case of emergency.

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

Liaison with State Authorities

• To keep liaison with police, fire brigade, Factory Inspector, Collector, local hospital and keep them informed. • To inform them about the requirement in advance. • To keep them informed about mock drills.

6.8.2 Emergency Time Activity:

Under these activities, the staff in the plant at various levels with pre-assigned duties is expected to work in a coordinated manner to meet emergency situation, remove the emergency conditions and bring the plant to normal with the help of resources available within and outside the plant. Availability and correct use of different means of communication and control is an important time activity. Sequence of action in case of various types of emergencies (Fire and Leakage of chemicals):

• Any person noticing fire or explosion or leakage of chemicals from pipeline or other equipment, should attract attention of nearby personnel by using or siren available within premises. • The area should be checked clear of people and organize emergency shutdown of the plant/ equipment. • The total quantity of chemical leaked should be ascertained and discharge of Air pollutants through stack should be stopped. • Other persons in the area will help the injured persons to go out of the place i.e. at open area and immediately arrange for first aid. • Simultaneously by Telephone he will contact the emergency control center. • He will inform the Incident controllers and key personnel depending upon the nature of emergency. • He will also guide the outside agency emergency aid services till the Incident Controller/ Site Main Controller reaches to the site of Incident. • As soon as Incident controller/Site Main Controller reaches to the site of incident he will take charge of the situation and guide/advice in tackling the emergency. • It is necessary to know that everyone on the site should be accounted for and that the relatives of causalities will be informed. It is necessary to have an up dated list of the names of people at site on Holidays and weekly off days. • If the situation is not likely to be controlled by the available sources incident controller/Site Main controller will assess the situation and declare the emergency as “OFF SITE EMERGENCY”. • The incident controller/Site Main Controller will continue to do the available resources to control and contain the emergency till the outside authorities and aid services reaches to the incident site. • After District Authority reaches to the site, he will extend all the necessary help, assistance and give required information/data as when required to control & contain the emergency.

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

6.8.3 Post – Emergency Activities:

A post-emergency base activity of steps taken after the emergency is over so as to establish the reasons of the emergency and preventive measures to be taken. The main steps involve: • Collection of records • Conducting inquiries and preventive measures. • Making Insurance claims • Inquiry reports and suggestions Implementations

6.9 Off-Site Emergency Plans:

The Offsite emergency plan is made based on events, which could affect people and Environment outside the premises. The off site plan is largely a matter of ensuring the co- ordination of proposed services and their readiness as far as possible, for the specific hazards and problems, which may arise in as incident. Briefly two main purposes of the plan are as under: • To provide the local district authorities, police, fire brigade, doctors etc. the basic information of risk and environmental impact assessment and to appraise them of the consequences and the protection / prevention measures and control plans and to seek their help to communicate with the public in case of major emergency. • To assist the district authorities for preparing the offsite emergency plan for the district or particular area. We have made our key personnel and other fully aware about this aspect. The function of the offsite plans are as under:

Structure of the offsite emergency plan includes the following:- • Organizational set up-Incident controller /Site main controller, Key personnel, etc • Communication facilities - List of important telephones • Specialized emergency equipment - Firefighting equipment • Specialized Knowledge - Trained people • Voluntary Organization - Details of organization • Chemical information - MSDS of hazardous substances • Meteorological information - Weather condition, Wind velocity etc • Humanitarian arrangement - Transport, First aid, Ambulance.

Role of the factory management The onsite and offsite plans are come together so that the emergency services are call upon at the appropriate time and are provided with accurate information and a correct assessment of situation.

Role of local authority Generally the duty to prepare the off-site plan lies with the local authority. They may have appointed an emergency planning officer (EPO) to prepare whole range of different emergency within the local authority area.

Role of fire authority

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Trisha Speciality Chemical Pvt. Ltd., Plot no.1015 & 1016, GIDC Estate, Kerala, near Bavla, Taluka-Dholka, District-Ahmedabad, State Gujarat

The control of a fire is normally the responsibility of the senior fire brigade officer who would take over the handling of fire from the Incident Controller on arrival at the site.

Role of police The overall control of an emergency is normally assumed by the police with a senior officer designated as emergency coordinating officer. Formal duties of the police during emergency include protection of life and property and controlling traffic movements.

Role of health authorities Health authorities, including doctors, surgeons, hospitals, ambulances etc. have a vital role to play following a major accident and they should form an integral part of the emergency plan. Major off site incidents are likely to require medical equipments and facilities in addition to those available locally.

Role of the “mutual aid” agencies Some types of mutual aids are available from the surrounding factories, as per need, as a part of the onsite and offsite emergency plan.

The role of the factory inspectorate In the event of an accident, the factory inspector will assist the District Emergency Authority for information and help in getting mutual aid from surrounding factories. Unit maintains the records of details of emergency occur, corrective preventive measures taken and in future the same practice will be continue. Unit has displayed the details like list of assembly points, name of the persons involve in the safety team like site controller, incident controller etc.

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