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GUIDELINES FOR DEVELOPING QUANTITATIVE SAFETY RISK CRITERIA

Center for Chemical Process Safety New York, New York

An AlChE Industry Technology Alliance

CBWILEY A JOHN WILEY & SONS, INC., PUBLICATION

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This book is one in a series of process safety guideline and concept books published by the Center for Chemical Process Safety (CCPS). Please go to www.wiley.com/go/ccps for a full list of titles in this series.

http://www.wiley.com/go/ccps


Center for Chemical Process Safety New York, New York

An AlChE Industry Technology Alliance

CBWILEY A JOHN WILEY & SONS, INC., PUBLICATION

It is sincerely hoped that the information presented in this document will lead to an even more impressive safety record for the entire industry. However, neither the American Institute of Chemical Engineers, its consultants, CCPS Technical Steering Committee and Subcommittee members. their employers. their employers' officers and directors, nor ABS Consulting Inc. and its employees warrant or represent, expressly or by implication, the correctness or accuracy of the content of the information presented in this document. As between ( I ) American Institute of Chemical Engineers, its consultants, CCPS Technical Steering Committee and Subcommittee members. their employers, their employers' officers and directors, and ABS Consulting Inc. and its employees and (2) the user of this document, the user accepts any legal liability or responsibility whatsoever for the consequcnce of its use or misuse.

Copyright 0 2009 by American Institute of Chemical Engineers, Inc. All rights resewed.

A Joint Publication of the Center for Chemical Process Safety of the American Institute of Chemical Engineers and John Wiley & Sons, Inc.

Published by John Wiley & Sons, Inc., Hoboken, New Jersey Published simultaneously in Canada.

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Library of Congress Cataloging-in-Publication Data is available.

Guidelines for developing quantitative safety risk criteria i Center for Chemical Process Safety. p. cm.

Includes index.

1. Chemical plants-Accidents--Risk assessment. 2. Chemical industry-Accidents-Prevention. I. American Institute of Chemical Engineers. Center for Chemical Process Safety.

TP150.A23G85 2009 660'.2804-d~22 2009019922

ISBN 978-0-470-26140-8 (cloth)

Printed in the United States of America

1 0 9 8 7 6 5 4 3 2 1

http://www.copyright.comhttp://iwww.wiley.comigo!permissionhttp://www.wiley.com

CONTENTS

Preface Acknowledgments List of Tables List of Figures Acronyms and Abbreviations Glossavy

INTRODUCTION

1.1 What is Risk? 1.1.1 Risk Basics 1.1.2 1.1.3

Why is Risk Assessment Important? Residual Risk versus “Zero Incidents”

1.2 Scope of these Guidelines 1.3 Objectives of these Guidelines

1.3.1 1.3.2

What these Guidelines Are Intended to Achieve What These Guidelines Do Not Intend

2 FUNDAMENTAL CONCEPTS OF RISK ASSESSMENT AND RISK CRITERIA 2.1 A Brief History of Risk Assessment

2.1.1 The Early History 2.1.2

2.1.3 The Qualitative Approach to Risk Assessment 2.2.1

The Beginnings of the Modern Consideration of Technological Risk Risk Assessment in the Process Industries

PHAs as an Example of Qualitative Risk Assessments

2.2

xiii

xix xxi

xxix

x V

X X V

11 11 11

12 13 15

15

V

vi GUIDELINES FOR DEVELOPING QUANTITATIVE SAFETY RISK CRITERIA

2.2.2 Semi-Quantitative Risk Matrices 2.2.3 2.2.4

Other Uses for Risk Matrices A Brief Comparison of Qualitative and Quantitative Risk Assessment

2.3 Technical Aspects of QRA 2.3.1 Consequence Modeling 2.3.2 Frequency Modeling 2.3.3 Developing a Comprehensive QRA 2.3.4 Standardization of Approach

2.4.1 Individual Risk 2.4.2 Societal Risk The Role of QRA and Risk Criteria 2.5.1

Risk Tolerance as a Function of Societal Values 2.6.1 What Is ‘Risk Tolerance’? 2.6.2 2.6.3 Public Perceptions of Risk Definition and Applications of the “As Low as Reasonably Practicable” (ALARP) Principle Uncertainty and Its Impact on Risk Decision Making 2.8.1 Sources of Uncertainty 2.8.2 Addressing Uncertainty

2.4 Quantitative Risk Criteria

2.5 Impact of Evolving Consensus Standards and Recommended Practices

2.6

Public Values as the Basis for Risk Criteria

2.7

2.8

3 LEARNING FROM REGULATORY PRECEDENTS 3.1 Why Study Risk Criteria?

3.1.1 The Value of Risk Criteria Precedents 3.1.2 How This Chapter Is Organized 3.1.3 Other Precedents The Evolution of Risk Criteria in the UK 3.2.1 3.2.2

3.2.3 Royal Society - 1983 3.2.4

3.2 UK Atomic Energy Authority - 1967 Health and Safety CommissiodAdvisory Committee on Major Hazards - 1976

Health and Safety Executive - 1988

17 20

20 21 21 26 29 30 31 31 35 37

38 39 39 40 41

44 46 46 47

49

49 49 50 51 51 52

52 53 54

CONTENTS vii

3.2.5 Health and Safety Executive - 1989 55

Dangerous Substances - 1991 55 3.2.7 Health and Safety Executive - 1992 57 3.2.8 Health and Safety Executive - 2001 57 3.2.9 Current Guidance to Industry and HSE Inspectors 59

3.2.6 Health and Safety Committee/Advisory Committee on

3.2.10 Other HSE Approaches To Addressing Societal Risk 60 3.3 The Evolution of Risk Criteria in the Netherlands 60

3.3.1 3.3.2

3.3.3

3.3.4 3.3.5

3.3.6

3.3.7

Groningen - 1978 60 Dutch Ministry for Housing, Spatial Planning, and the Environment - 1984 61 Dutch Ministry for Housing, Spatial Planning, and the Environment - 1988/1989 63 Dutch Parliament - 1993 64 Dutch Ministry of Transport, Public Works, and Water Management - 1996. 64 Dutch Ministry for Housing, Spatial Planning, and the Environment - 1999 65 Dutch Ministry for Housing, Spatial Planning, and the Environment - 2004 65

3.4 Comparison of Risk Criteria in the UK and the Netherlands 67 3.4.1 3.4.2

3.4.3 3.4.4

3.4.5 3.4.6

3.4.7

Individual Risk Criteria for Workers 67 Distinction between Individual Risk Criteria for New and Existing Establishments 67 Criteria for Broadly Acceptable (or Negligible) Risk 69 The Distinction between Vulnerable and Less Vulnerable Objects 69 The Issue of F-N Curve Slope 69 A Perspective on the Numerical Disparities between the UK and Dutch Criteria 69 Difficulties in Satisfying the More Stringent Dutch Risk Criteria 71

3.5 Learning from and Applying the Precedents 73

3.5.2 Balancing On-site and Off-site Risk Perspectives 75

3.5.4 Rigid Limits Versus Advisory Goals 75

3.5.1 Balancing Individual and Societal Risk Perspectives 73

3.5.3 Experience-based Versus Technology-Driving Criteria 75

GUIDELINES FOR DEVELOPING QUANTITATIVE SAFETY RISK CRITERIA viii

4

3.5.5 3.5.6 Basis for Calculating Risks 3.5.7 Risk Criteria Scaling 3.5.8

3.5.9

Application of the ALARP or ALARA Principle

Application of New Risk Criteria to Old Establishments Risk Criteria for Transportation Risk

CONSIDERATIONS IN DEVELOPING RISK CRITERIA

4.1 4.2 4.3

4.4

4.5

4.6 4.7 4.8 4.9

4.10

4.11 4.12

Determine the Need to Establish Risk Criteria Determine the Risks to be Addressed Determine/Classify the Population to be Addressed 4.3.1 On-site populations 4.3.2 Off-site populations Determine Which Risk Criteria to Develop 4.4.1

4.4.2

Determine Whether Risk Criteria Will Distinguish Between New and Existing Facilities Determine Philosophy for Continuing Risk Reduction Develop Individual Risk Criteria Develop Societal Risk Criteria Qualifymalidate the Risk Criteria 4.9.1

4.9.2

Decide on a Philosophy for Apportioning and Scaling the Risk Criteria 4.10.1 Apportioning and Scaling Societal Risk Criteria 4.10.2 Apportioning Risk Criteria to Individual Scenarios 4.10.3 Calibrating the System Over Time Periodically Revalidate the Risk Criteria Matching the Risk Criteria with the System and with the Risk Estimation Methodology

Will the Risk Criteria Address Both Individual and Societal Risk? Will the Risk Criteria Define a De Minimis Level of Risk?

Relating Risk Criteria to Commonly Tolerated Levels of Risk Relating Risk Criteria to Societal Values Reflected in Regulatory Precedents

76 76 77

77 78

79

80 82 82 82 83 84

84

84

85 87 87 88 88

88

90

91 93 95 98 98

100

CONTENTS

4.12.1 Matching the Scope of the Study to the Basis for the Risk Criteria

4.12.2 Providing Consistency Between the QRA Methodology and the Risk Criteria

4.12.3 Clearly Defining the Basis for the Risk Criteria 4.13 Risk Criteria in the Multinational Context 4.14 Consideration of Short DuratiodHigher Risk Activities

5 FUTURE TOPICS

ix

5.1 5.2 Enhancing Risk Assessment Technology

Fostering the Application of Risk-Based Decision Making

Appendix A: Understanding and Using F-N Diagrams A. 1 Construction of an F-N Curve to Display Data

A. 1.1 A. 1.2 Presentation of Societal Risk Criteria A.2.1 A.2.2

The Mathematics of the F-N Curve Calculating and Plotting an Example F-N Curve

Defining the Risk Criteria F-N Curve The Significance of the Slope of the F-N Curve

A.2

A.3 F-N Criteria Slope Selection

B. 1 Appendix B: Survey of Worldwide Risk Criteria Applications

Evolution of Land Use Planning Criteria in the UK B. 1.1 Health and Safety Executive (HSE) - 1989 B. 1.2 HSE - 2008

B.2 Land Use Planning Criteria in the Netherlands B.3 Hong Kong B.4 States of Sao Paulo, Rio de Janeiro, and Rio Grande do Sul,

Brazil B.5 Singapore B.6 Malaysia B.7 Australia

B.7.1 Western Australia B.7.2 New South Wales B.7.3 Queensland B.7.4 Victoria B.7.5 Other Australian States

B.8 Canada

101

101 101 102 103

105

105 106

109 109 110 110 113 113 114 116 119 120 120 124 126 127

130 133 135 135 135 138 141 141 143 143

X GUIDELINES FOR DEVELOPING QUANTITATIVE SAFETY RISK CRITERIA

B.9 France B. 10 Switzerland B. 1 1 Santa Barbara County, California, USA B. 12 United States Federal Government Agencies

B.12.1 Nuclear Regulatory Commission (NRC) B.12.2 Department of Energy (DOE) B. 12.3 Environmental Protection Agency (EPA) B.12.4 Food and Drug Administration (FDA) B. 12.5 Occupational Safety and Health Administration

(OSHA) B.12.6 Department of Defense (DOD)

B.13 New Jersey, USA B. 14 International Maritime Organization (IMO) B. 15 Other Nations B.16 Summary

C. 1 Appendix C: Development of Company Risk Criteria

Case Study Number 1 C. 1.1 C. 1.2 C. 1.3

Development of Corporate Criteria Applying the Criteria within the Businesses Validation of the Criteria against Regulatory Precedents

(2.2.1 Principles C.2.2 General Observations (2.2.3

(2.2.4

C.2 Case Study Number 2

Company Risk Criteria Based upon Regulatory Precedents Basis for Selection of Risk Criteria

C.3 Case Study Number 3 C.3.1 C.3.2 Applying the Criteria C.3.3

Development of Company Elevation Criteria

Use of QRA and Risk Elevation Criteria C.4 Case Study Number 4

C.4.1 Introduction C.4.2 C.4.3 (2.4.4 Establishing Risk Tolerance Criteria

Initial Use of Qualitative Tools Initial Use of Quantitative Tools

144 147 148 151 151 152 153 155

155 156 158 159 161 161

171 171 171 173

175 177 177 178

178 180 181 181 182 183 184 184 184 185 186

CONTENTS

REFERENCES INDEX

xi

191 207

PREFACE

The American Institute of Chemical Engineers (AIChE) has been involved with process safety and loss prevention in the chemical, petrochemical, hydrocarbon processing, and other process industries since its founding in 1908. As these industries increased in scale and economic importance in the years following World War 11, AIChE’s activities in this area expanded through specific programming activities and publications. AIChE’s symposia, journals, and other publications have been important safety resources for chemical engineers, industrial chemists, and other technical professionals in these industries.

In 1985, following major chemical disasters in Mexico City, Mexico, and Bhopal, India, the Center for Chemical Process Safety (CCPS) was established as an AIChE Technology Alliance. The charter of CCPS is to develop and disseminate technical information for use in the prevention of major chemical accidents. CCPS is supported by more than 120 sponsors worldwide, including process industry companies, engineering consulting companies, and government entities. These sponsors provide funding, and, more importantly, technical knowledge, expertise, and professional guidance through participation in various CCPS project subcommittees. One important product of CCPS, in support of its charter, is a series of guidelines books which provide information on implementation of various aspects of a complete process safety management system.

Process hazard analysis, risk analysis, and risk management have been recognized as critical features of a process safety management program by CCPS from its inception in 1985. The first product of CCPS was the first edition of Guidelines for Hazard Evaluation Procedures, published in 1985, and now in its third edition (published in 2008). The second and third editions of this book include discussion of qualitative risk evaluation tools, which can be incorporated into process hazard studies. CCPS has also published several important books related to process risk analysis, including:

xiii

xiv GUIDELINES FOR DEVELOPING QUANTITATIVE SAFETY RISK CRITERIA

Guidelines for Chemical Process Quantitative Risk Analysis (1 989, 2nd Edition published in 2000) provides a complete methodology for quantitative process risk analysis. Evaluating Process Safety in the Chemical Industry: A User's Guide to Quantitative Risk Analysis (2000) is an overview of the use of quantitative risk analysis techniques in the process industries for engineers and managers. Tools for Making Acute Risk Decisions with Chemical Process Safety Applications (1 995) describes how various decision analysis techniques can be applied to management decision making incorporating the results of risk analysis studies. Layer of Protection Analysis: SimpliJed Process Risk Assessment (2001) provides a description of a simplified technique for evaluating process safety risks.

This book, Guidelines for Developing Quantitative Safety Risk Criteria, provides additional guidance on the use of risk analysis studies for process risk management decisions. Over the last several decades, as quantitative risk analysis has been applied increasingly in the process industries, many government and industry organizations have begun to develop and apply risk criteria as tools for making process risk management decisions. This book surveys experience with the development and application of these criteria, and provides guidance on how an organization might use this experience to establish its own risk criteria. The book does not recommend criteria, or endorse specific criteria that have been used by various organizations. The focus is on understanding the meaning of the various criteria that have been used, their bases, how they are applied, and how this experience can be used by an organization that is considering similar approaches as a part of its own process risk management system. We hope that this book will help engineers and managers in the process industries better understand risk criteria, how they can be applied, how they can become one element of a comprehensive process risk management system, as well as understand the limitations and potential problems that might be associated with the use of risk criteria.

CCPS wishes to thank the Risk Criteria Subcommittee for their efforts to prepare Guidelines for Developing Quantitative Safety Risk Criteria:

Wayne Chastain Don Connolley Mike Considine Les Cunningham Tom Dileo Ken Harrington Dennis Hendershot Dave Jones Shakeel Kadri Greg Keeports Kevin Klein Sam Mannan Bill Marshall Jack McCavit Chee Ong Scott Ostrowski Tim Overton Bayan M. Saab Mike Schmidt Angela Summers Karen Tancredi John Wincek Brent Woodland Mike Yurconic

Eastman Chemical Company BP BP Merck A lbemarle Chevron Phillips Chemical CCPS Staff Consultant Chevron Air Products and Chemicals, Inc. Rohm and Haas Company, retired Solutia, Celanese Texas A&M University Eli Lilly and Company CCPS Emeritus Shell ExxonMobil Dow LyondellBasell Industries Emerson Process Management

DuPont Croda, Inc. Conoco/Phillips Intel

SIS- TECH

xv

xvi GUIDELINES FOR DEVELOPING QUANTITATIVE SAFETY RISK CRITERIA

Walt Frank of Frank Risk Solutions, Inc. (formerly of ABS Consulting) and John Farquharson of ABS Consulting were the authors of the book. Steve Arendt, Myron Casada, and Henrique Paula of ABS Consulting provided valuable contributions to its outline and content. Dr. Paula’s past extensive research to identify relevant resources on the development of safety risk criteria throughout the world was of great value in developing the book. Karen Taylor edited the manuscript, Susan Hagemeyer prepared the manuscript for the printer, and Paul Olsen provided graphics support.

CCPS also thanks the following peer reviewers for taking the time to review the final manuscript of the book, and providing extensive and valuable input and comments:

Ben Ale Lee Alford Nasir Ali Arnold Allemang Marco Amaral Wim Blom Sergio D. M. Castro Mohan Chahal Phil Crossthwaite Brian Dunbobbin Leopoldine Montiel Frioni Martin Goose Richard C. Griffin Koos Ham Randy Hawkins Jean-Paul Lacoursiere Steve Leigh John R. Lockwood Donald K. Lorenzo John Marshall Georges A. Melhem Jose Luiz Mendes Thia Cheong Meng Lisa Morrison Art Mundt Lou Nathanson Robert Ormsby Bill Ostrowski Robin Pitblado Ana Flavia Sampaio

Technical University Devt European Process Safety Centre Conoco/Phillips Dow, retired ABS Consulting Chevron ABS Group Services do Brasil, Ltda. ConocoPhillips DNV Air Products and Chemicals, Inc. CETESB IChemE Safety & Loss Prevention Subject Group Chevron Phillips Chemical TNO Built Environment and Geosciences RRS Schirmer University of Sherbrooke Croda International plc Independent risk consultant ABS Consulting Dow, retired ioMosaic Corporation INEA International Rejnery Services Singapore BP International Limited Dow, retired ConocoPhillips CCPS ConocoPhillips DNV ABS Consulting

ACKNOWLEDGMENTS xvii

Gregg SaPP Conoco/Phillips Marcos Tadeu Seriacopi CETESB Irfan Shaikh Diogo Singulani INE.4 Emery Thomas ConocoPhilIips Hal Thomas

Lloyd’s Register North America, Inc.

Air Products and Chemicals, Inc.

LIST OF TABLES

TABLE 1.1. TABLE 2.1.



TABLE 2.6.

TABLE 2.7.

TABLE 2.8.

TABLE 3.1.

TABLE 4.1.

TABLE 4.2.

TABLE A.l .

TABLE A.2.

TABLE A.3.

TABLE A.4.

Risk Based Process Safety Elements Example Consequence Categories - Qualitative Risk Matrix Example Frequency Categories - Qualitative Risk Matrix Example Risk RankingiResponse Categories - Qualitative Risk Matrix Example Semi-Quantitative Risk Matrix Suggested Mishap Severity Categories for Semi- Quantitative Risk Matrix Suggested Mishap Probability Levels for Semi- Quantitative Risk Matrix Example Mishap Risk Categories and Mishap Risk Acceptance Levels Attributes of Qualitative Versus Quantitative Studies Comparison of UK and Dutch Individual Risk Criteria Individual Risk of Accidental Work-Related Death in US, 2006, Fatalityiyear Individual Risk of Accidental Death in US, 2003, Fatalityiy ear

8

16 16

17 18

18

19

20

23

68

89

90

F-N Calculations 111

Sample QRA Results 111

QRA Results Sorted By Decreasing N

F-N Presentation of QRA Results

112

112

xix

xx GUIDELINES FOR DEVELOPING QUANTITATIVE SAFETY RISK CRITERIA

TABLE B.1.

TABLE B.2.

TABLE B.3.

TABLE B.4.

TABLE B.5.

TABLE B.6.

TABLE B.7.

TABLE B.8.

TABLE B.9.

TABLE B.lO.

TABLE B. l l .

TABLE B.12.

TABLE B.13.

TABLE B.14.

TABLE B.15.

TABLE B.16.

TABLE B.17.

TABLE B.18.

TABLE B.19.

TABLE C.l .

TABLE C.2.

HSE’s PAHDI Decision Matrix

Hong Kong Individual Risk Criteria

Individual Risk Criteria for Three States in Brazil

Singapore Individual Risk Criteria

Western Australia Individual Risk Criteria

MIACC Risk Criteria for Land Use Planning

Matrix for Determining Severity of Consequences

Risk Assessment Frequency Ranges

Decision Matrix for Permitting New or Modified Facilities

Determination of Global Hazard Levels for PPRT

Guidance for Proposed Land Use Decisions Based Upon Hazard Rating

Guidance for Existing Land Use Decisions Based Upon Hazard Rating

Various Risk Criteria Used by EPA (as of 1996)

Individual and Societal Risk Criteria for DOD Test Range Operations

Individual and Societal Risk Criteria for DOD Explosives Handling Operations

Proposed IMO Individual Risk Criteria

Proposed IMO Societal Risk Criteria

Summary: Individual Risk to the Public

Summary: Individual Risk to Workers

Company B’s Individual Risk Criteria

Company D’s Public Risk Criteria

126

129

132

134

137

143

145

145

146

146

147

147

154

157

158

159

160

162

167

179

188

LIST OF FIGURES

FIGURE 2.1. FIGURE 2.2. FIGURE 2.3. FIGURE 2.4. FIGURE 2.5. FIGURE 2.6. FIGURE 2.7. FIGURE 2.8. FIGURE 2.9. FIGURE 2.10. FIGURE 2.11. FIGURE 3.1. FIGURE 3.2. FIGURE 3.3. FIGURE 3.4. FIGURE 4.1. FIGURE 4.2. FIGURE 4.3. FIGURE 4.4. FIGURE 4.5.

FIGURE 4.6.

FIGURE A.l .

Example Qualitative Risk Matrix Levels of Risk Analysis Scale of Risk Assessment Efforts QRA Process Consequence Analysis Flowchart Sample Event Tree Example Individual Risk Contour Example Individual Risk Profile Example F-N Curve Current Dutch Societal Risk F-N Risk Criteria HSE Tolerability of Risk Diagram Farmer Curve Groningen Societal Risk Criteria Comparison of UK and Dutch Societal Risk Criteria A Risk Performance Convergence Risk Criteria Development Flowchart TOR Diagram with De Minimis Level TOR Diagram without De Minimis Level Levels at which Risk Must be Managed Levels over Which Risk Criteria May Be Apportioned

Societal Risk Curves from the WASH- 1400 Study F-N Curve for Hypothetical QRA Results

16 22 22 25 27 28 32 33 36 42 44 52 62 68 74 81 86 86 92

93

102 113

xxi

xxii

FIGURE A.2.

FIGURE A.3.


Hypothetical QRA Results with UK HSE Societal Risk Criterion 115

Comparison of f-N and F-N Curves for a ‘Risk Neutral’ Slope 115

FIGURE A.4. Historical F-N Curve with -1 Slope 117

FIGURES B.la. and B.lb.

FIGURE B.2

FIGURE B.3

FIGURE B.4.

FIGURE B.5.

FIGURE B.6.

FIGURE B.7.

FIGURE B.8.

FIGURE B.9.

Illustration of HSE’s Consultation Distance around Fixed Facilities and Pipelines

Hong Kong Societal Risk Criteria

Societal Risk Criteria for Three States in Brazil

New South Wales Proposed Societal Risk Criteria

Queensland Individual Risk Criteria

Victoria Societal Risk Criteria

MIACC Land Use Planning Risk Criteria

Swiss Societal Risk Criteria

Santa Barbara County Risk Criteria

FIGURE B.10. DOD Test Range Societal Risk Criteria

FIGURE B. l l .

FIGURE C.l.

FIGURE C.2.

FIGURE C.3.

FIGURE C.4.

FIGURE C.5.

FIGURE C.6.

Summary of Relevant Maximum Tolerable Societal Risk Criteria

Company A’s Perspective on Unsustainable Risk

Company A’s Societal Risk Criteria for a

Business Division

Company A’s Societal Risk Criteria for a Large Site Company A’s Societal Risk Criteria for a Small Site Regulatory Criteria for Public Societal Risk Relevant to Company A’s Business Portfolio Comparison of Company A’s and Regulatory Criteria for Public Societal Risk for a Major Facility

125

128

131

140

141

142

144

149

151

157

169

172

173

174

175

176

177

LIST OF FIGURES xxiii

FIGURE C.7. Comparison of Company A’s and Regulatory Criteria for Public Societal Risk for a Small Facility 178

Company B’s Societal Risk Criteria for the Public 179

Company B’s Societal Risk Criteria for

Employees and Contractors 180

182

FIGURE C.8.

FIGURE C.9.

FIGURE C.10. Company C’s Elevation Criteria

FIGURE C. l l . Company D’s Individual Risk Criteria, Illustrating Application of ALARP 190

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