PRC-SAF-22. Zachary Site. SAFETY POLICIES and PROCEDURES. Hot Work Permit. Revision #3-06/03/2011. Date Reason For Change Changed/Reviewed By

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1 ZACHARY SITE PROCEDURE NUMBER TITLE: PRC-SAF-22 (Hot Work Permit) Page 1 of 20 Rev. 1.7 Date: 06/01/15 PRC-SAF-22 Zachary Site SAFETY POLICIES and PROCEDURES Revision #3-06/03/2011 Hot Work Permit Date Reason For Change Changed/Reviewed By Jan Revision Number rest to 1.0 at transfer into Documentum R. Hall, EHS&S Specialist, Zachary EHS 06/15/14 Categories added; see Section 20 Document History R. Hall, EHS&S Specialist, Zachary EHS 09/26/2014 Annual Review; removed Revision Number Reset message found in footer; Minor changes made to document R. Hall, EHS&S Specialist, Zachary EHS 03/2015 Alignment with new requirements of BC Tanner Martinez

2 Page 2 of 20 CONTENTS 1.0 PURPOSE 2.0 SCOPE 3.0 DEFINITIONS 4.0 RESPONSIBILITIES 5.0 GENERAL REQUIREMENTS 6.0 FIRE WATCH REQUIREMENTS 7.0 SPECIAL PROVISIONS FOR FLAME / SPARK-PRODUCING HOT WORK WITHIN OPERATING LIMITS OF UNITS IN OPERATION 8.0 SPECIAL PROVISIONS FOR ELECTRICAL WORK 9.0 SPECIAL PROVISIONS FOR ELECTRICALLY POWERED TOOLS AND EQUIPMENT 10.0 TRAINING 11.0 ANNUAL MANAGEMENT SYSTEM REVIEW 12.0 RECORDKEEPING 13.0 ATTACHMENTS

3 Page 3 of PURPOSE 1.1 The purpose of this procedure is to establish a uniform procedure covering the preparation and issuance of Hot Work Permits throughout the Zachary Site. This procedure is based on the philosophy that the safety of personnel and the protection of equipment are of paramount importance; consequently short cuts must not be taken and methods must not be devised which will circumvent the spirit of this procedure. Hot work shall be controlled within the guidelines provided in this procedure to minimize the risks of fire or explosion. 1.2 This procedure identifies the responsibilities of plant personnel in issuing Hot Work permits, the conditions under which Hot Work permits may be issued, and the requirements and/or restrictions necessary for issuing Hot Work permits. 2.0 SCOPE 2.1 This procedure applies to all personnel at the Zachary Site including contractor personnel. 2.2 This procedure applies to all Hot Work activities conducted at the Zachary site, except where exceptions to the Hot Work requirements are specifically identified in this procedure. 2.3 This procedure is not to be used to allow Permanently Installed electric equipment not Listed or Labeled for use in an Electrically Classified Area. 2.4 This procedure does not apply to Hot Taps. Hot Tap must be covered by site-specific procedures based on API Recommended Practice 2201, Safe Hot Tapping Practices in the Petroleum and Petrochemical Industries, and GS-P-ME-001, Hot Tapping of Piping. 3.0 DEFINITIONS Eyes Review - The use of 2 or more individuals to review a job or task in the field to ensure all hazards are identified and eliminated/controlled through the use of safe work practices or PPE, communication/awareness, etc. At a minimum this must include a Hot Work Supervisor and a member of the work crew. 3.2 Applicable Distance - 35 feet (10.7 m) in all directions from the Hot Work area, unless otherwise stated. 3.3 Combustible -. A material that could be ignited by coming into contact with open flames, heat or sparks. This includes such items as paper, wood, plastic, cloth, liquid with a closed cup flash point at or above 100 degrees F (37.8 C) but below 200 degrees F (93.3 C. 3.4 Container - Any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, piping, or the like. 3.5 Electrically Classified Areas - Locations where fire or explosion hazards may exist due to the presence of flammable gases, flammable vapors, combustible vapors, combustible dusts, or ignitable fibers/particulates. Area Electrical Classification Drawings are available from the Engineering Manager or designee.

4 Page 4 of Exempted Areas Areas that are specifically designated for the routine performance of Flame or Spark-Producing Hot Work, and where a Hot Work Permit is not required. 3.7 Explosive Atmospheres - A range of concentrations of gases, dusts, or fibers with air that can support ignition. The range of concentrations is material-specific. The range for a material can vary based on pressure, temperature, and oxygen content. 3.8 Flammable - Material that falls into a specific category listed below: Aerosol, flammable - An aerosol that can yield a flame projection exceeding 18 inches at full valve opening, or a flashback (a flame extending back to the valve) at any degree of valve opening Gas, flammable - (A) A gas that, at ambient temperature and pressure, forms a flammable mixture with air at a concentration of thirteen (13) percent by volume or less; or (B) A gas that, at ambient temperature and pressure, forms a range of flammable mixtures with air more than twelve (12) percent by volume, regardless of the lower limit Gas, liquefied flammable - A flammable gas that is handled in a liquid state by keeping it under pressure or at low temperatures. Class 1A flammable liquids (any material with an NFPA flammability rating of "4," and any material with an "F+" rating on the German Gefahrstoffliste) are liquefied flammable gases. Process conditions will determine whether or not a material is to be considered a liquefied flammable gas. Any flammable liquid stored or handled significantly above its boiling point, but kept liquid by pressure is also considered a liquefied flammable gas Liquid, flammable - Any liquid having a flashpoint below 100 deg. F (37.8 deg. C), except any mixture having components with flashpoints of 100 deg. F (37.8 deg. C) or higher, the total of which make up 99 percent or more of the total volume of the mixture Solid, flammable - A solid, other than a blasting agent or explosive, that is liable to cause fire through friction, absorption of moisture, spontaneous chemical change, or retained heat from manufacturing or processing, or which can be ignited readily and when ignited burns so vigorously and persistently as to create a serious hazard. 3.9 Hot Tap - A procedure used in the repair, maintenance, and service activities which involves welding on a piece of process equipment which cannot be isolated, depressurized, or cleared; for the purpose of installing connections or appurtenances. Refer to Maintenance Procedure GS-P-ME-001, Hot Tapping of Piping.

5 Page 5 of Hot Work - Any activity that falls into one of the following categories: Flame- or Spark-Producing Hot Work means an operation that can produce enough heat from flame, spark, or other means, such as friction, with sufficient energy to ignite combustibles or flammables. Examples include electric arc and gas welding, grinding, cutting, burning, brazing, soldering, and other spark-producing or heat-producing operation Non-rated Electrical Equipment Hot Work includes the use of portable electric equipment and electronic devices in Electrically Classified areas and that are not Listed or Labeled for use in the Electrically Classified Area Vehicle Access Hot Work includes the operation of electric, gas, diesel, or internal combustion engines in Electrically Classified Areas, unless the equipment has been approved for use in the area by a nationally recognized testing lab. For example, powered industrial trucks may be manufactured for use in specific Electrically Classified Areas Hot Work Supervisor Operating/Owning Department personnel who have been specified to issue Hot Work permits. Each person must be trained and qualified per this procedure. Authorized Hot Work Supervisors include all qualified BASF operators and warehouse personnel, as identified by the respective Operations Manager Incipient Stage Fire A fire which is in the initial or beginning stage and which can be controlled or extinguished by portable fire extinguishers, Class II standpipe or small hose systems without the need for protective clothing or breathing apparatus 3.13 Listed or Labeled - Equipment that meets identified standards or has been tested and is suitable for a specific use. Independent testing laboratories, such as UL, TUV, CSA, or others, assign a listing number and maintain a list of products that meet the identified standards requirements. The listing organization will use some means to identify listed equipment, which can include labeling Operating/Owning Department - The unit or department that operates or is responsible for the daily operation of the process, area, or facility where work is being conducted Permanently Installed - Equipment that is hard-wired or equipment used without a person present 100% of the time it is in use Permit Issuer Personnel identified by the Operating/Owning Department who a) are trained to recognize Hot Work situations, the requirements for issuing a permit, and the necessary means to safeguard against the hazards posed during these activities, b) are knowledgeable of the area and/or processes in which Hot Work is taking place along with the potential hazards, and c) takes responsibility for management of the Hot Work activity. The Permit Issuer must be a different individual than the personnel performing the Hot Work activity and the Permit Acceptor.

6 Page 6 of Revalidation The process of reusing an existing Hot Work permit to authorize work. Revalidation must include using the 4 Eyes principle to review the existing permit and current field conditions in order to ensure the scope, conditions, and safety precautions listed on the existing permit have not changed. Required approval signatures must be obtained at the time of revalidation. 4.0 RESPONSIBILITIES 4.1 Management is responsible for: Implementation of the requirements of this procedure Ensuring that personnel are trained on requirements of this procedure Designating in writing the Hot Work Supervisors authorized to issue Hot Work permits their respective unit/department (by name or function) Reviewing the results of the annual program review and ensuring corrective actions are implemented Approving any exceptions to the requirements identified in this procedure. 4.2 Hot Work Supervisors are responsible for: Understanding the requirements of this procedure Conducting an initial field inspection of the Hot Work area and throughout the Hot Work as needed; and taking action to correct any problems observed in these inspections Identifying the precautions necessary for Hot Work and ensuring that the precautions are in place before permitting Hot Work to proceed Ensuring that field conditions are safe before issuing a Hot Work Permit Completing and issuing Hot Work Permits in their area. 4.3 Each employee is responsible for: Understanding and complying with the requirements of this procedure Understanding the specific responsibilities for any roles that they are required to perform during Hot Work (ex. Fire Watch, Hot Work Supervisor, etc.). 4.4 Each Contractor is responsible for: Informing their personnel on the specific requirements of this procedure Following all aspects of this procedure as applicable to their work.

7 Page 7 of Safety Specialist is responsible for: Updating this procedure as necessary to ensure compliance with BASF requirements Coordinating the annual management system review of the Hot Work program Approving and inspecting any temporary fabrication areas where flame / spark-producing hot work will be allowed without a Hot Work Permit. 5.0 GENERAL REQUIREMENTS 5.1 Hot Work conducted in Exempted Areas must ensure adequate safeguards to prevent fires. The following is a list of Exempted Areas and activities at the Zachary Site: Area used for lighting of boilers Designated smoking area Inside the Maintenance Shop Laboratory, when using flames under a hood Contractor area at far west end of the Zachary Site Specific areas so designated by the Plant Manager during periods of new construction, extended repair or dismantling of obsolete equipment. These areas must be reviewed and approved by the Safety Specialist and be inspected at least every 30 days to ensure that Hot Work precautions are being followed Routine Non-rated Electrical Equipment Hot Work and Vehicle Access Hot Work performed by Operating/Owning Department personnel when current equipment-specific operating procedures (e.g., TJAs, JSAs, SOPs) are utilized which specify mechanisms that provide protection equal to safeguards that would have been required by a Hot Work permit. 5.2 Flame/ Spark-Producing Hot Work is not permitted in the following situations: In areas not authorized by a Hot Work Supervisor; In buildings while sprinkler protection is impaired; In the presence of Explosive Atmospheres; On a metal partition, wall, ceiling or roof having a combustible covering or insulation, or on walls or partitions of combustible sandwich-type construction; On pipes or other metal that is in contact with Combustible walls, partitions, ceilings, roofs, or other Combustibles close enough to cause ignition by conduction; Where Explosive Atmospheres may develop inside un-cleaned or improperly prepared tanks or equipment, which have previously contained Flammables or Combustible Dusts with air; Where Explosive Atmospheres may develop in areas with an accumulation of Combustible Dusts (refer to Attachment D); and/or In areas near the storage of large quantities of exposed Combustible or Flammable material.

8 Page 8 of The following actions must be taken to ensure that Flammable and Combustible materials are removed from the affected equipment and area prior to the initiation of Hot Work: The area, where a Hot Work operation will be performed, shall be inspected by the Hot Work Supervisor prior to approving Hot Work Permits Containers and equipment that previously contained Flammables or greases, tars, or other materials shall be isolated, according to procedure PRC-SAF -02 Lockout Procedure, prior to allowing Flame/Spark-Producing Hot Work on the equipment. Isolation shall consist of one or more of the following methods: a. A blank or stopper plate inserted in the line. Blanks must be of the construction and thickness to sustain the pressure for which the line is rated. b. Double block and bleed valve arrangement where the two block valves are closed and the bleed, in between, is opened and secured by locks or tags. c. Lines are disconnected and misaligned from the equipment Containers and equipment that previously contained Flammables or greases, tars, or other materials, that when subjected to heat might produce Flammable vapors, must be cleaned and purged to make absolutely certain there are no Flammables present prior to allowing Flame/Spark-Producing Hot Work All hollow spaces, cavities, or containers must be vented to protect against overpressure due to thermal expansion before preheating, cutting or welding. Consider potential hazards in vent path Combustibles must be moved at least 35 feet from Hot Work operations. If they cannot be removed then they must be protected by flame-proof guards, curtains, or covers. All sewers, floor drains, or wall openings must be covered with flame-proof tarp and wetted down prior to starting the Hot Work operation Combustible dust must be cleaned from the vicinity of the Hot Work operations. This includes equipment, machines, overhead structures, and floors Openings or cracks in walls or floors within 35 feet of Flame/ Spark-Producing Hot Work must be tightly covered with fire-retardant or noncombustible material to prevent the passage of sparks to adjacent areas Ducts and conveyor systems, that might carry sparks to distant Combustibles or Flammables, shall be shielded, or shut down, or both Fire-retardant shields or guards shall be provided to prevent ignition when Flame/ Spark- Producing Hot Work is done near walls, partitions, ceilings, or roofs of Combustible construction If all fire hazards cannot be removed then fire-retardant covers, metal shields, guards or curtains shall be used to confine the heat, sparks and slag, and to protect the immovable fire hazards. The edges of the covers must be appropriately sealed to contain sparks.

9 Page 9 of All potentially affected personnel or work groups must receive appropriate communication to ensure coordination of activities and to prevent adverse impact Atmospheric monitoring must be conducted with a properly calibrated LEL meter to verify the absence of an Explosive Atmosphere in the work area. a. The LEL meter must be functionally tested by exposing the sensor to a known gas concentration before each use or daily, whichever is less frequent. b. The LEL meter must be calibrated within one month prior to the testing and the calibration date must be recorded on the permit. c. Initial monitoring, where required, must be done within 2 hours of the start of Hot Work. d. If a measurable level is detected then Hot Work is not allowed or must cease until the source is found, eliminated and subsequent testing meets requirements. Any exception to this rule requires the approval of both the Safety Specialist and the Plant Manager. e. The LEL meter results must be recorded on the Hot Work Permit, including the meter serial number, the readings for (%) percentage of oxygen and LEL, and the name of the person conducting the monitoring. f. Tests must be made at the specific area(s) where Hot Work will be conducted or where sparks or other ignition sources may occur. g. For Flame/ Spark-Producing Hot Work, representative test points within 35 feet of the Hot Work location, including low points (such as sumps, drains, trenches), must be considered. h. Continuous monitoring or repeat monitoring must be conducted according to the frequencies specified in Attachment A. 5.4 An approved Hot Work permit (Attachment B) must be issued by a designated Hot Work Supervisor for any Hot Work activity, unless specifically exempted in 5.1 this procedure Hot Work Permits must specify the exact area where the work is to be performed (e.g.: Dioxane Reactor, second level, Dioxane unit) and specifically state the nature of the work Hot Work Permits are limited in duration to the shift on which they are issued, not to exceed 16 hours. If a job continues beyond the designated time then a new permit must be issued or the existing permit must be revalidated A 4 Eyes Review must be conducted prior to the start of Hot Work to ensure that all Hot Work precautions are in place. Signing of the permit by a designated Hot Work Supervisor signifies that all Hot Work precautions are in place prior to the start of Hot Work. a. The maximum amount of time between the 4 Eyes Review and the start of actual Hot Work must not exceed two (2) hours. The permit must be revalidated or reissued if two hours is exceeded The Hot Work Supervisor, who performs the 4 Eyes Review, is responsible to review all precautions on the permit with the individual receiving the permit and to ensure that all requirements outlined in this procedure are followed.

10 Page 10 of The person(s) performing the Hot Work shall review and sign-off the permit as a means of acknowledging acceptance that conditions are safe to begin work. a. The work crew copy of the permit must be available at the work site for the duration of the Hot Work. b. When the job is complete, it is the responsibility of the individual(s) doing the work to return the Hot Work Permit to the Hot Work Supervisor All work covered by a Hot Work Permit must stop immediately when any emergency alarm is sounded and may not resume until the "all clear" is given and a new Hot Work Permit is issued or the existing permit is revalidated When Hot Work is to be performed in a confined space, a properly prepared Confined Space Entry Permit shall be issued with Hot Work being authorized by the Entry Supervisor A Hot Work permit does not authorize smoking or matches in any area. 5.5 Line Breaking operations involving flammables cannot proceed simultaneously with Hot Work within a distance of 75 ft unless approved by the Designated Management Representative. 5.6 When dismantling enclosed equipment, which previously contained flammable chemicals, use of flame producing Hot Work equipment will be approved only after all other options have been exhausted. 5.7 Proper PPE shall be selected and utilized as applicable to the specific Hot Work activity. Such PPE may include, but is not limited to, helmets, hand shields, goggles, face shields, lifelines, and/or protective clothing. 5.8 When an incident occurs during Hot Work activities, the Hot Work permit must be scanned and added to the AIM report. 5.9 The Hot Work Permit must be updated or revalidated if any of the following changes occur: Change in work scope Change in Permit Issuer Change in Permit Acceptor 5.10 Following completion of the work or end of the permit duration, the Hot Work permit must be returned to a Permit Issuer from the Owning Department and closed out. Closure of the permit requires: Reviewing the status of the work and discussing any hazards encountered or left in the workplace Signing of the Permit Closure section by a member of the Work Crew and a Permit Issuer. 6.0 Fire Watch Requirements 6.1 At least one Fire Watch is required whenever Flame/Spark-Producing Hot Work is performed in locations where other than an Incipient Stage Fire might develop or if any of the following conditions exist:

11 Page 11 of Appreciable Combustibles or Flammables, in building construction or contents, are closer than 35 feet to the point of Flame/Spark-Producing Hot Work, or Appreciable Combustibles or Flammables are more than 35 feet away from the point of Flame/Spark-Producing Hot Work, but may be easily ignited by sparks, or Wall or floor openings within 35 feet expose Combustibles or Flammables in adjacent areas including concealed spaces in walls or floors, or Combustibles or Flammables are adjacent to the opposite side of metal partitions, walls, ceilings, or roofs and are likely to be ignited by conduction or radiation. 6.2 More than one Fire Watch may be required depending on the nature of the work. The Hot Work Supervisor will make this determination when issuing the permit for the Hot Work. 6.3 The fire watch shall: Be present in the area where Flame/Spark-Producing Hot Work is occurring for the entire duration of the work and for at least a half hour after completion of the Hot Work activities to detect and extinguish possible smoldering fires Be equipped with the proper fire-fighting equipment (e.g., portable fire extinguisher or water hose) and be trained on its use and limitations Constantly observe for changing conditions, the presence of Combustibles or Flammables, spark/slag containment, and the recognition of any abnormal events which may affect the ongoing Flame/Spark-Producing Hot Work Have the responsibility and authority to immediately shut down the Hot Work if hazardous conditions are observed Be briefed on the potential hazards of the area and be knowledgeable of the means to obtain assistance and the activation of emergency alarms and procedures. This may include carrying a radio for the duration of the Hot Work. 7.0 Special Provisions for Flame/Spark-Producing Hot Work Within Operating Limits of Units in Operation 7.1 Flame/Spark-Producing Hot Work within the operating limits of units in operation should be done only after careful consideration. 7.2 After a Hot Work Permit has been issued for Flame/Spark-Producing Hot Work, the following activities within the same operating unit limits are prohibited while the Hot Work Permit is in effect Disconnecting lines, venting, purging or opening of bleeders in hydrocarbon service or low pressure steam condensate systems Drawing hydrocarbon samples Switching hydrocarbon pumps Deheading vessels normally containing hydrocarbons.

12 Page 12 of Drawing down water legs in vessels where hydrocarbons may be included Blowing down leads on hydrocarbon meters Other operations capable of releasing flammable liquids and gases. 8.0 Special Provisions for Electrical Work 8.1 A Hot Work Permit is required to open explosion proof electrical equipment, purge boxes, breaker boxes, junction boxes or other electrical equipment that has live 110 volts or higher, when the equipment is present in an Electrically Classified Area. 9.0 Specific Provisions for Electrically Powered Tools or Equipment 9.1 Electrically powered tools or equipment such as drills, cameras, cellular phones, pagers, etc., are considered sources of ignition. Equipment, which is not designated by the manufacturer as intrinsically safe or does not meet area electrical classification, shall not be used without a properly executed Hot Work permit. 9.2 Specific Provisions for 110 Volt Tools or Equipment 10.0 Training Electrically powered tools shall not be used if similar equipment is available with an alternate power source such as steam, air, etc If electrical power tools or equipment is the only reasonable alternative, all cords and connections are to be securely suspended and/or tied well away from walking, working, and damp areas with a non-conductive material. Ground fault circuit interrupters shall be used on appropriate equipment BASF and Contracted Employees Involved in Hot Work Activities: Hot Work Supervisors, Permit Acceptors, Fire Watch personnel, and personnel performing Hot Work shall receive training on how to recognize the applicability of Hot Work situations, the requirements for issuing a permit, and the necessary means to safeguard against the hazards posed during these activities Training shall be delivered in accordance with the EHS curriculum assignment process and documented with the following: a. Each trainee s name, b. Date(s) of attendance, c. Means used to verify understanding, and d. Learning Objective(s) for the course

13 Page 13 of Retraining of an individual is required whenever: a. Deviations or inadequacies in an individual s performance indicate that lack of knowledge is a cause. b. An applicable procedure has been changed. c. As required by the BASF EHS Curriculum Assignment Process BASF and Contracted Employees not directly involved in Hot Work will receive awareness training in accordance with the EHS curriculum assignment process Contractors are required to train their personnel on Hot Work requirements as applicable to their work Annual Management System Review 11.1 A review of the effectiveness of the Hot Work Permit program must be conducted and documented on an annual basis. The following minimum elements of the Hot Work management system must be included in the review: A review the site procedure and permit to ensure all currently required elements are included A review of a representative sample of the closed permits issued since the last Hot Work management system review to determine the effectiveness, completeness, and accuracy of the permit system A review of all incidents and other nonconformance reports involving Hot Work activities that have occurred since the last Hot Work management system annual review. The review should verify root causes have been properly identified and appropriate corrective actions have been implemented Inspection of at least one Hot Work job-in-progress to verify site practices comply with the site procedure. Verification of the training personnel involved in this job-in-progress received Interviews with a representative number of Permit Issuers, Permit Acceptors, persons performing Hot Work, Fire Watches, and other affected employees, including Contractors and Contracted Employees where applicable, to verify they understand their role/responsibility; A review of applicable equipment and instrument maintenance and calibration records A review of Exempted Areas, as identified in 5.1, where Hot Work permits are waived to ensure minimum requirements are implemented Owning/Operating Department management must review the results of the Hot Work program review, direct corrective actions, and ensure corrective actions are implemented The review shall be documented and any necessary corrected actions tracked until completion.

14 Page 14 of RECORDKEEPING 12.1 Closed permits shall be retained for the period necessary to facilitate the program review in 11.0, but no longer than one year. Any problem encountered during a Hot Work related operation must be noted on the permit so that appropriate revisions to the Hot Work program can be made When an incident occurs during Hot Work activities, the hot work permit issued for that job shall be retained for at least one year from the date of the incident. The permit must also be scanned and added to the incident report Records of training will be maintained per BASF record retention requirements ATTACHMENTS 13.1 Attachment A: LEL Testing Frequencies 13.2 Attachment B: Image of Hot Work Permit 13.3 Attachment C: Checklist for Annual Management System Review (Non-Mandatory) 13.4 Attachment D: List of Combustible Dusts at the Zachary Site

15 Page 15 of 20 Attachment A LEL Testing Frequencies

16 Page 16 of 20 Attachment B

17 Page 17 of 20 Attachment C Hot Work Management System Review Checklist (Non-mandatory) SITE: DATE: A Management System is a collection of programs, operations, people, documents, policies, guidelines, procedures, facilities, and equipment implemented to effectively satisfy an objective. It is independent of an individual expertise and contains checks and balance to ensure sustainability. PLAN BC , Hot Work; Site procedure for Hot Work activities; Permits for Hot Work activities DO Examples (all may not be applicable): Pre-work area assessments and evaluations; pre-work isolation and preparation techniques; permit issuance and work authorization process; work-in-progress review; coordination and communication among affected stakeholders. CHECK Examples (all may not be applicable): Closed permit reviews, including documentation and retention; training verification; previous site management system review; equipment calibration and maintenance records. ACT/REPORT Correct deficiencies; assess and review effectiveness; report to stakeholders A check mark in the yes box for an item indicates that item is in place and effective. A check mark in the no box for an item indicates there is a deficiency related to that item. The details column should record what was examined in order to indicate yes or no. When no yes or no indication is given for an item, an explanation must be given in the details column indicating why the item was not applicable. All non-conformances of the Hot Work management system must be entered into the site non-conformance tracking database for follow-up through closure. PLAN Yes No Item Details Has the corporate procedure been revised since the last Hot Work annual review? If so, does the current site procedure contain all required elements? 1 Have any advisories or alerts been issued since the last Hot Work annual review? If so, does the current site procedure contain all required elements? 1 Have changes taken place at the site since the last Hot Work annual review that affect the site Hot Work 1 procedure? If so, is the current site procedure accurate? Are affected stakeholders involved in the development and/or revision of the site procedure related to Hot Work? 1 Is the current site permit thorough, accurate, and reflective of the site procedure requirements? 1 Is only the current version of the site Hot Work permit(s)

18 Page 18 of 20 Yes No Item Details and other records related to Hot Work being used? Are there means to provide opportunity for feedback and communication with affected stakeholders, including contractor and contracted employees? Examples include permit debriefing after work is complete; start-of-shift safety talks; safety meetings; etc. Do stakeholders (Permit Issuers, persons performing the work, affected employees, EHS) understand their roles and responsibilities? 1 If the site uses more than one site procedure or permit to cover the requirements related to Hot Work as defined in BC , then all related site procedures and permits must be included in this annual review. DO Verify by review of work-in-progress Yes No Item Details Were the necessary permit(s) available in work area? After review of the active permit and discussion with personnel involved in the work activity, was the permit issuance process in the site procedure followed? For example, did the Permit Issuer and the individual(s) performing the work meet at the work site and review the permit, were all safeguards in place prior to the work being authorized, etc. After examination of the work area and the active permit, was the work area hazard assessment adequately performed? Were proper safeguards for the identified hazards indicated on the permit? Were these safeguards in place prior to beginning the work? When drawings or other documents were used to determine the isolation or preparation plan, did the documents reflect as-is conditions? After examination of the work area, were all equipment and instruments specified on the permit in place and functioning? After examination of the active permit, was work approval authorization documented on permit? After examination of the work area and discussion with affected stakeholders, was Hot Work activity notification to affected stakeholders adequate (signs, pre-shift talks, postings, etc.)? Permit # for work-inprogress reviewed: Equipment or instrument identification #: Permit Issuer (name): Person(s) performing work (name(s)):

19 Page 19 of 20 CHECK Yes No Item Details Do the equipment and instrument records indicate the required maintenance and calibration is performed? Verification must include checking records for the actual equipment and instruments used during the work-inprogress. Were the permit issuer and person(s) performing the work from the work-in-progress review trained? Was the required training delivered according to the EHS curriculum assignment process? Was the training documented? Were the training records retained as required? Based on a review of incidents involving Hot Work activities, were all root causes properly identified in the incident report(s)? Do the corrective actions in the incident report address the root cause(s)? Are the corrective actions being implemented in a timely manner? Were common trends observed for the collection of incidents that were not addressed by the corrective actions for individual incidents? Were common trends used to develop site goals, targets and objectives for site management? For work areas where Hot Work permits have been waived, are all areas listed in the site procedure(s)? Do the conditions in all permit-exempted areas reflect adequate fire protection precautions are in place and functioning effectively (good housekeeping, proper fire fighting equipment available, shielding of non-moveable combustibles, etc.) ACT/Report Yes No Item Details Are performance measures/indicators of performance used to provide stakeholder feedback, instruction, and guidance? Are applicable contractor and contracted employees included in the feedback, instruction and guidance? Based on review of the previous annual management system review, is follow-up on non-conformances adequate? Were results of the previous review communicated to stakeholders in a timely manner? Reviewer Signature Review Completion Date

20 Page 20 of 20 Attachment D List of Combustible Dusts at the Zachary Site TMA BHT NDC HNDA Irganox Sodium acetate Nafion / Invista catalyst