154364437.xls.

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6/27/2013

Plant A

A major process is produced in a two-step synthesis. The first step, defined as Segment 1, involves hazardous chemistry with runaway reaction potential. The reaction is carried out in a low flashpoint solvent with high accute toxicity. The flammable liquid is stored in an above tank. The facility is old and not well maintained. Operating procedures and safe operating parameters are not well defined. (See Table 2 above for "X" indicating this segment to be applied) 1 Flammable Liquid Tank Farm Fire C L E Risk $ Bus Interupt CBI 10 6 3 180 $100 1 3 3 41 369 $100,000 16 1 2 140 280 $1,000,000 40 829 (min = $1) $ legal liabil CLL $1 0 $1 0 $1 0

Segment No. 1

Minor Moderate Major Segment No. 1

CPI 2 15 80

CPR 0 5 20

CEI 0 5 0

CCI 0 0 0

Minor Moderate Major Segment No. 1

3 Flammable Liquid / Combustible Material Fire in Processing Area C L E Risk $ Bus Interupt CBI CPI CPR 5 5 3 75 $1,000 3 0 0 2 2 70 280 $100,000 16 40 12 1 1 100 100 $300,000 25 50 20 455 5 Flammable Vapor / Gas Explosion C L E Risk $ Bus Interupt 1 1 7 7 $1,000 1 1 48 48 $100,000 0.7 0.5 129 45.15 $2,000,000 100.2 7 Run-Away Chemical Reaction C L E Risk $ Bus Interupt 3 3 24 216 $1,000 2 3 105 630 $1,000,000 1 3 340 1020 $10,000,000 1866 $ Bus Interupt $1 $1,000 $100,000

CEI 0 0 0

CCI 0 0 0

$ legal liabil CLL $1 0 $1,000 2 $10,000 5

Minor Moderate Major Segment No. 1

CBI 3 16 53

CPI 2 20 50

CPR 1 10 20

CEI 0 0 0

CCI 0 0 0

$ legal liabil CLL $100 1 $1,000 2 $20,000 6

Minor Moderate Major

CBI 3 40 99

CPI 15 20 90

CPR 4 10 20

CEI 0 20 80

CCI 0 10 40

$ legal liabil CLL $1,000 2 $10,000 5 $100,000 11

Segment No. 1 11 Release of Toxic Liquid C L E Risk Minor 0.5 0.5 15 3.75 Moderate 0.3 0.5 68 10.2 Major 0.2 0.1 287 5.74 19.69 Segment No. 1 Summary 1 3 5 7 11

29 Materials that are extremely Toxic In Low quantities CBI CPI CPR CEI CCI $ legal liabil CLL 0 2 1 5 5 $1,000 2 3 30 10 10 10 $10,000 5 16 100 20 80 60 $100,000 11

Flammable Liquid Tank Farm Fire Flammable Liquid / Combustible Material Fire in Processing Area Flammable Vapor / Gas Explosion Run-Away Chemical Reaction Release of Toxic Liquid RS1=

Risk 829 455 100 1,866 20 3,270

Rank 2 3 4 1 5

R.A. Hawrelak

1:12 AM

Plant B

The second step of the synthesis is carried out in Plant B, defined as Segment 2. The second step is a chlorination raction in an aqueous reaction media.The products produced are non-toxic and non-flammable. Chlorine feedstock is highly toxic. The facility is state-of-the-art in all respects. The procedures, operating parameters and personnel are excellent. The chlorine is supplied from a railcar containing 30,000 lbs that is properly designed and protected. PSV maintenance is done by the supplier. The facility is located in a densely populated suburban location.

Segment No. 2

(See Table 2 above for "X" indicating this segment to be applied) (min = $1) $ legal liabil $1 $100,000 $1,000,000

10 Release of Toxic Gas or Vapor C L E Risk Minor 3 4 20 240 Moderate 1 2 91 182 Major 0.5 1 315 157.5 579.5 Segment No. 2 20 Hurricane C L E Risk Minor 5 1 14 70 Moderate 3 0.75 75 168.75 Major 0.7 0.5 155 54.25 293 Segment No. 2 Summary

$ Bus Interupt $1,000 $10,000 $1,000,000

CBI 3 7 40

CPI 5 30 100

CPR 2 10 20

CEI 5 10 80

CCI 5 23 50

CLL 0 11 25

$ Bus Interupt $1,000 $100,000 $1,000,000

CBI 3 16 40

CPI 2 13 40

CPR 2 10 20

CEI 4 5 10

CCI 3 20 30

$ legal liabil $1 $100,000 $250,000

CLL 0 11 15

10 Release of Toxic Gas or Vapor 20 Hurricane

Risk Rank 579.5 1 293.0 2 RS2 = 872.5

Overall Summary RS1 RS2 3,270 872.5

Table 1

Product Manufacturing Risk Assessment Qualities of Design / Procedures Automatic Sprinklers Smoke / Heat Detectors Explosions Suppression Systems Damage Limiting Construction Inertion Systems Ventilation Systems (Hi-Point, Lo-Point, Specific, # of Air Changes, Once Through, etc.) Explosion Proof Equipment Intrinsically Safe Equipment Purge Boxes Hot Work Procedures Confined Space Entry Procedures Process Safety Interlocks Emergency Relief Devices Operator Training Emergency Backup Systems Emergency Response Teams Disaster Plans Alarm Systems Proximity to Community (distance to nearest neighbor) Personnel Protective Equipment Administrative Controls Initial process Development to Remove Undesirable Compounds

Table 2

Product Manufacturing Risk Assessment Generic Hazardous Events Segment 2 Segment 1 Selected Events X X X X

Hazard Source Fire

No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30

Events Flammable Liquid Tank Farm Fire Flammable Liquid Drum Storage Fire Flammable Liquid / Combustible Material Fire in Processing Area Combustible Material Warehouse Fire Flammable Vapor / Gas Explosion Dust explosion Run-Away Chemical Reaction Overpressure (Mechanical Energy-Failure of Pressurized Container) Detonatable Material Release of Toxic Gas or Vapor Release of Toxic Liquid Environmentally Toxic Toxic to Humans Unloading Incident Failure of Vessel / Container Release of Highly Reactive Material Unknown Release Failure of Controlling Procedures Flood Hurricane Tornado Earthquake Snow Bomb, Bomb Threat Firebomb Disruption of Utilities (Water, Electric, Natural Gas, etc) Blocked Access to Site Physical harm to Key Personnel Materials That Are Extremely Toxic In Low quantities High Risk Matenance Operations

Explosions

Hazard Mtl Release With Signif Impact

X X

Natural Disasters

Terrorism Arson Theft Civil Disorder Personnel Safety Risk (Toxicity, Material Process Hdlg Fatality

Table 3

Product Manufacturing Risk Assessment Hazardous Event Consequences

FIRE 1 Flammable liquid fire in storage area (tank farm, drum storage) resulting from spill of material Minor (Involving less than 50 U.S. gallons, such as a spill while sampling, leaking hose or flange. Fire controlled by local extinguishers.

Moderate Involving 50 to 5500 U.S. gallons, such as overfilling of a vessel, ruptured unloading hoses, punctured drum. Major Involving more than 500 U.S. gallons, such as failed bottom outlet on storage tank or ruptured transfer line.

2 Fire In Processing Area Minor Spill while sampling or charging from drum, (less than 10 U.S. gallons). Controlled by fire extinguishers. No major damage.

Moderate Spill involving 10 to 50 U.S. gallons. Controlled by fixed fire protection. Damage to instrumentation, loss of batch, etc. Major Spill involving more than 50 U.S. gallons. Major damage to equipment and buildings.

3 Warehouse Fire Minor Trash fire controlled by fire extinguisher.

Moderate Fire involving stored material; some water and smoke damage. Major Fire involving stored material; extensive water and smoke damage. Fire resulting in major damage to the building. (Can use New 94 Baker V3.2 Model adapted for insurance company evaluation).

EXPLOSIONS Minor

Explosion in equipment resulting in damage to equipment only. (Max 100 lbs of flammable). Level 2 by TNO method. To max of 1.0 psig overpressure on IRI Damage Table.

Moderate Explosion in process area from release of flammable gas or vapor. Damage to equipment and relief panels activated. (100 to 1,000 lbs of flammable). Levels 2 to 5 by TNO method. From 1.0 to 5.0 psig overpressure on IRI Damage Table. Major Confined vapor cloud explosion (VCE) in congested process area. Levels 5 to 10 by TNO method. From 5.0 to 10.0 psig overpressure on IRI Damage Table.

HAZARDOUS MATERIAL RELEASE Minor Release from a PSV, PSV reseats to a tight shut-off.

Moderate Release of a toxic gas from a 150 lb cylinder. Major D Water ingress to a reactive mixture: continuous release from a PSV or rupture disc.

NATURAL DISASTERS

1 Earthquake Minor

Is the site in a recognized eathquake zone?

Cracks in walls / floors. Vessels shifted off their supports.

Moderate Dislodged / ruptured pipe racks. Loss of tilities. Major Loss of buildings, disruption of surface travel (impact on availability of plant personnel and emergency response personnel). Is the site in a recognized flood plain? Water / mud / silt damage to equipment; above ground vessels moved off supports.

2 Flood Minor

Moderate Loss of utilities. Damage to control systems. Water ingress to storage vessels. Major Foundations weakened / compromised. Impact on availability of plant personnel and emergency response personnel. Does the site have a history of hurricane / tornado exposure?

3 Hurricane / Tornado Minor

Damage from windblown objects.

Moderate Siding / pannels blown off buildings Major Loss of utilities / communications. Impact on availability of plant personnel and emergency response personnel.

4 Snow / Extreme Cold / Ice Minor Frozen process lines. Frozen sprinkler lines.

Moderate Building damage from snow loading. Major E Impact on availability of plant personnel and emergency response personnel.

TERRORISM / ARSON / CIVIL DISORDERS / RIOTS Does the location introduce any risk associated with terror, arson, civil disorders or riots?

PERSONNEL SAFETY RISK

(Extreme toxicity)

Does the process handle any highly toxic material, or can the process accidentaly form a highly toxic material? (Highly toxic is defined as lethal in small doses).

Table 4

Product Manufacturing Risk Assessment Likelihood Rating 10 9 8 7 6 5 4 3 2 1 0.8 0.7 0.6 0.5 0.4 0.3 0.2 0.1 L Description Might Well Be Expected Possibly Expected Quite Possible Possible Unusual but Possible Only Remotely Possible Unlikely Conceivable but Very Unlikely

Practically Impossible Virtually Impossible

Table 5

Product Manufacturing Risk Assessment Exposure E Rating 10 9 8 7 6 5 4 3 2.5 2 1.5 1 0.75 0.5 Description Continuos Almost Continuous (10x/day) Semi-Continuous (5x/day) Very Frequent (2x/day) Frequently (daily) Practically Daily (5x/wk) Practically Daily (3x/wk) Occasional (weekly) Occasional (biweekly) Unusual (monthly) Very Unusual (quarterly) Rare ( a few per year) Very Rare

Table 6

Product Manufacturing Risk Assessment Risk Consequences

CBI

Business Interuption and Property Losses

CBI $ CBI Factor Calc'd CBI $100 1 1.06 $1,000 3 2.62 $10,000 6 6.50 $100,000 16 16.12 $1,000,000 40 39.97 $10,000,000 100 99.09 Slope Constant b 0.3943081 -1.7595079 Calc'd CBI 1.06 2.62 6.50 16.12 39.97 99.09 Event Class Minor Minor Moderate Moderate Major Major

Business Interuption and Property Loss $

100 CBI Factor

LINEST = CBI $ $100 $1,000 $10,000 $100,000 $1,000,000 $10,000,000

10

1 $100

$1,000

$10,000 $100,000 $1,000,000 $10,000,000 $ Value

Personal Injury CPI 0 1 2 3 4 5 6 7 8 9 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48

Description

CPI Class Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate

Superficial Injury or Illness

Minor Injury or Illness

Public Relations CPR 0 1 2 3 4 5 6 7 8 9 10 12 14 16 18 20

Description

CPR Class Minor Minor Minor Minor Minor Moderate Moderate Moderate Moderate Moderate Major Major Major Major Major Major

Minor Problem

Moderate Problem

Major Problem

Moderate Injury or Illness

50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 80 82 84 86 88 90 92 94 96 98 100

Major Injury or Illness

One Fatality

A Few Fatalities

Many Fatalities

Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major

Environmental Impact Description CEI 0 1 2 3 4 5 Minor Contamination easily cleaned 6 7 8 9 10 12 14 16 18 20 Sever contamination. Major effort 22 to clean 24 26 28 30 32 34 36 38 40 42 44 46 48

CEI Class Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate

Community Impact CCI 0 1 2 3 4 5 6 7 8 9 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48

Description

CCI Class Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Moderate Major Major Major Major Major

Superficial Odor, ERPG 1

Moderate Irritation. ERPG-2

Sever and Life Threatening ERPG-3

50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 80 82 84 86 88 90 92 94 96 98 100 CLL

Major Contamination. Widespread and Outside Site

Dissastrous Contamination. Local area persistant. Rural area.

Catastrophic Contamination. Major regional, water source Legal Liability

Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major

50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 80 82 84 86 88 90 92 94 96 98 100

One Fatality

A Few Fatalities

Many Fatalities

Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major Major

CBI $ CBI Factor Calc'd CBI $1,000 2 2.00 $12,000 5 4.99 $3,500,000 40 40.41 $10,000,000 60 59.48

Legal Liability
100 CLL Factor

LINEST = CBI $ $1,000 $5,000 $100,000 $1,000,000 $10,000,000

Slope Constant b 0.3683734 -1.8517646 Calc'd CBI 2.00 3.62 10.91 25.47 59.48 Event Class Minor Minor Moderate Major Major

10

1 $1,000

$10,000

$100,000 $1,000,000 $10,000,000 Value, $