Succinct summary of representative risk management measures (RMMs) and operational conditions (OCs)

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1 Succinct summary of representative risk management measures (RMMs) and operational conditions (OCs) Legal name of applicant(s): Grupa LOTOS S.A. Submitted by: Grupa LOTOS S.A. Substance: 1, 2-dichloroethane (EDC) EC No , CAS No Use title: Use as an extraction solvent in the de-waxing of petroleum vacuum distillates and de-asphalted oil and de-oiling of slack wax for the production of base oils and paraffinic waxes. Use number: 1

2 ECS and WCS Task (ERC/spER C or PROC) Annual amount per site (tonnes/ year) ECS 1 ERC4 ''''''''''''''''''''' tonnes in 2015 in circulatio n loop ( t/a) Technical RMMs, including: *Containment, *Ventilation (general, LEV ) *customized technical installation, etc After condensers and water/solvent separation vessel, waste waters are treated in a stripper column. After this stripper column treatment the water (''''''''''' ppm of EDC) is sent to the general chemical and biological waste water treatment unit plant. All equipment of de-waxing and de-oiling facility unit is connected to a general ventgas balance vessel (Gasometer tank) to ensure regular pressure in the unit and to avoid direct releases Organisational RMMs, including: *Duration and Frequency of exposure *OSH management system *Supervision *Monitoring arrangements *Training, etc Monitoring in the air phase outside the plant conducted in 2015 and in the STP effluents (once a month) PPE (characteris tics) Effectiveness of waste water and waste air treatment (for ERC) Efficiency measured in waste waters out of the WWSTP > 99.97% Emission in Air out of the plant > 99.65% Release factors: water, air and soil (for ERC) Release factor in : Waters: Default 100% (ERC4) by measurements in effluent of STP: < kg/d Air: Default 100% (ERC4) by measurements of concentration in the air phase and measurements of deposit outside the plant: < 1.55 kg/d. Soil : Default 5% (for ERC4): in the present case: 0% or 0 kg/d as the sludges of the onsite STP are not applied onto agricultural soils. Detai led info. in CSR (page ) WCS1 Production process including storage, transfers, All equipment and processes from production units involving EDC are under closed systems. All of the columns, vessels are *Duration = 8h/day. *Frequency = all year (only 3 weeks each 4 year maintenance None (except during

3 recycling, waste transfers (PROC2) equipped with the control systems i.e. level, pressure, temperature control devices. The seals of the rotary equipment are mainly single but the process of replacing them with the double-axial face seal with barrier fluid is under execution. The drained streams which contain EDC are collected in the close drain vessel and are reprocessed in the unit. In case of emergency, the equipment is connected to the buffer vessels located on the unit. The buffer vessels are under filtration gas blanket. break) *under management sampling for QC, see WCS2 below). none WCS2 EDC sampling for QC (PROC8b) Closed loop sampling (vent and non-return valves, flexible hoses with quick disconnect coupling for better operator safety) (closed sampling process). Outdoor. *Duration = 5 mins. *Frequency = 1 per 24h gloves KCl/ nitrile;

4 minim layer thick. 1.2 mm; min. break eff. =95% *Under management none WCS3 Receive of EDC from rail tank (PROC8b) Containment: fixed connection and hose steel connections. Fixed connection and hose steel connections with gas offtake at a safe point / transfer to general vent gas treatment system no direct emission to atmosphere (eff.=80%). *Duration = 3 hours (5 mins sampling, 5 mins connecting/disconnecti ng of flexibles, 170 unloading). *Frequency = 1 per 2 years Dermal gloves KCl 890 / Fluorocaoutc houc ;

5 Assurance of leak-proofness by leak test after establishing the connection and complete capture of the residual quantities by inert gas into the flexibles. Outdoor. *under management minim layer thick. <1.0 mm; 30 min. break eff. = 95% Respiratory, full face mask A2B2E2K2 HgP3 eff. = 95% WCS4 Non routine maintenance and cleaning (PROC8b) Containment: open system WCS4 covers small repairs equipment where the equipment can t be fully flushed (see description WCS5). Outdoor or indoor with good general ventilation. *Duration = 15 mins *Frequency = 1 per month gloves KCl 890 / Fluorocaoutc houc minim layer thick. <1.0 mm;

6 *Under management min. break eff. = 95%, full face mask A2B2E2K2 HgP3 eff. = 95% WCS5 General maintenance and cleaning (PROC8b) Before any equipment dismantling, the equipment is purged with solvent (DCM/EDC) until all wax is washed off. The solvent is returned to the plant s feed (circulated in enclosed system). Then the equipment is purged with base oil in order to bind and flush out solvent completely. The base oil used for purging is *Duration = 6 hours *Frequency = over 3 weeks every 4 years gloves KCl 890 / Fluorocaoutc houc minim layer thick. <1.0 mm; 30 min. break

7 returned to the plant s feed (circulated in enclosed system). The description of the maintenance work to do as well as the specific risk management measure to follow are described in a permit procedure. Outdoor or indoor with good general ventilation. *Under management eff. = 95%, full face mask A2B2E2K2 HgP3 eff. = 95% WCS6 Laboratory QC (PROC15) *Local exhaust ventilation: yes- All handling EDC samples are done under fume cupboard (eff. = 90%). This equipment is certified and controlled each year. *Indoor good general ventilation *Duration = 20 mins *Frequency = 1 per 24h gloves KCl/ nitrile; minim layer thick. 1.2 mm; min. break 54 6

8 . *Under management eff. = 95% No Abbreviations: WCS=Worker contributing scenario, ECS= Contributing Scenario,* ERC= Release Category (or sperc if available), PROC= Process category, LEV=Local Exhaust Ventilation, PPE=Personal Protective Equipment 7