Document 0q0bLKxLRxa14XBxJMva1j9ZR
DOW U. S. A. Consolidated Audit Program
GLYCOL I PLANT OPERATIONS
Date of Report:
12/19/96
Superintendent:
Charles Jackson, Bldg., 2901 LAD
cc: Buck Bailey, Bldg. 3301W, LAD Chris Messelt, Bldg. 3502W, LAD
Leigh Hill, Bldg. 2901, LAD Julie Broome. Bldg. 6650, LAD
Enclosed are the recommendations from the various audits for your response. According to the Dow U.S. Area Consolidated Audit Program Guidelines and the OSHA Process Safety Management (PSM) standard 1910.119, you must develop an implementation plan as a response to the recommendations. The plan must include the name(s) of the employee(s) assigned to each action item along with an expected and actual completion date for each item.
Please note that efforts have been made by the Functional Audit Teams to help prioritize each recommendation. They will be identified as: M = Must Do, (based on compliance issues, government regulations, Dow policies or S&LP) and HR = Highly Recommended, (necessary to mitigate an anticipated or potential hazard).
It is the responsibility of the plant/department supervision to communicate the results of the consolidated audit to all employees. Communication must include the results of the Process Hazard Analysis. PHA's include the Reactive Chemicals, Chemical Exposure Index (CEI), Process Safety and Loss Prevention/Fire/Burner Management audit and the Employee Survey Results. This must be completed within 90 days after the audit report date and documented.
Please send your approved implementation plans to Connie Kalencki, Bldg. 3502W by February 14,1997. We will forward a copy to members of the Core Audit Team and the appropriate section to the Functional Team Leaders.
Enclosed Audit Recommendations:
1. Process Hazard Analysis 3. Laboratory Audit 5. Reactive Chemical Audit 7. Loss Prevention/Fire Audit 9. Hazardous Materials Transportation
Review
2. Occupational Health Audit 4. Electrical Reliability Audit 6, Security Audit 8. Safety Audit
Howard Wilkinson, Administrator LAD Consolidated Audit Program
DO
A fDENTIL'
CONF
LAD PROCESS HAZARD ANALYSIS (PHA's)
Recommendations:
M 1. Communicate results of the Consolidated Audit to plant personnel within 90 days after the audit report date and document.
Guidelines For Communicating Process Hazard Analysis (PHA's) To Employees
The OSHA Process Safety Management (PSM) Standard (29CFR 1910.119) requires that facilities covered by this standard perform a formal process hazard analysis, communicate the results of this analysis to plant employees whose work assignments are in the process and who may be affected by the recommendations or actions.
Currently the LAD Consolidated Audit Process include PHA's (reactive chemical reviews, hazardous materials transportation reviews, chemical exposure index audits, fire & explosive index reviews).
The following guidelines can be used to communicate the Process Hazard Analysis (PHA's) to plant employees. Communication to employees may be done in a regular scheduled safety meeting or during a safety training day and documented.
REACTIVE CHEMICAL REVIEW:
A. Review all worst case scenarios identified by the plant and LAD Reactive Chemicals Committee. Make sure that plant personnel have a thorough knowledge of the reactive chemicals potential. Discuss the safe operating limits and consequences of deviation. Discuss the reactive chemical control systems including hardware, software and procedures. Discuss all other safeguards or action plans that are aimed at avoiding and mitigating the consequences of each scenario.
B. Review the recommendations from the LAD Reactive Chemicals Committee and the plant action plans to correct the recommendations.
C. Review the results of the employee interviews which are done by the LAD Reactive Chemicals Committee during the Consolidated Audit and the plant follow-up actions to address any deficiencies.
Action Taken/To Be Taken;
Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
DOW CONFIDENTIAL Page 2
DO A 045431 CONFIDENTIAL.
HR = Highly Recommended
CHEMICAL EXPOSURE INDEX REVIEW:
The Chemical Exposure Index (CEI) provides a simple method of rating the relative acute health hazard potential to people in neighboring plants or communities from possible chemical release incidents. Absolute measures of risk are very difficult to determine, but the CEI system will provide a method of ranking one hazard relative to another.
A. Review the list of plant hazardous chemicals that were evaluated by the plant.
B. Review the worst case scenarios and calculated CEI value. This shall include dispersion data and charts that were developed from the plant CEI review.
C. Review all actions required to prevent the worst case. It may be a simple case of reviewing employee job responsibilities from an existing plant emergency drill. Any preventive maintenance, thickness checks, Technology Center recommendations, visual inspections and recommendations from the consolidated audit team should be reviewed also.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
FIRE & EXPLOSION INDEX:
The Fire & Explosion Risk Analysis System is a step-by-step objective evaluation of the realistic fire, explosion and reactivity potential of process equipment and its contents. The purpose of the F&EI system is to: 1) Quantify the expected damage of potential fire, explosion and reactivity incidents in realistic terms. 2) Identify equipment that would be likely to contribute to the creation or escalation of an incident, and 3) Communicate the F&EI risk potential to management.
A. Review the plant F&EI process units and classified hazard levels ("heavy", "moderate" etc.). See Table 6, pg. 38 - F&EI Guide, 7th edition.
B. Review the list of process units in your plant that were reviewed.
C. Review the evaluation of realistic fire, explosion and reactivity potential of the process unit and its contents. (Depending on the level of hazard, certain process equipment spacing, process equipment/piping standards and loss prevention principles are applied to the process to minimize the hazard level).
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion P'"'
M = Must-Do
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D0 A 04543? CONFTDFNTT AL
HR = Highly Recommended
OCCUPATIONAL HEALTH AUDIT
(Date:
Tuesday, December 2,1996)
AUDIT TEAM:
Harvey Cavalier, Bruce Heinze, Dan Jones
PLANTCONTACT: Harvey Cavalier
ATTENDING: Jackson
Harvey Cavalier, Bruce Heinze, Dan Jones, Howard Wilkinson, Charles
WRITER:
Bruce Heinze
GENERAL INDUSTRIAL HYGIENE/MEDICAL
OSHA Form #2203, "Job Safety and Health Protection", and the Safety Department's bulletin board posting "Employee Rights Under The VPP and OSHA" which explain the rights of workers protected by these programs were posted.
Recommendations: M 1. The Chemical & Physical Agent Inventory(CPAI) needs to be reviewed and updated for 1996.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HAZCOM PROGRAM The written program and MSDSheets were current. The results of monitoring are being communicated to the individuals involved in a timely manner.
Recommendations: M 1. The equipment and contents cross reference file in the Plant IH Manual needs to be reviewed and updated for 1996.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 2. The monitoring results for CLR employees needs to be sent to their employer.
Action TakenJTo Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
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HR = Highly Recommended
DO A 045433 CONFIDENTIAL
M 3. Portable containers (e.g., 55 gallon drums, 5 gallon pails, etc.) in the process area need to be labeled in accordance with Dow labeling requirements.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
HEARING CONSERVATION
The written program was current. Hearing protectors were readily available. The noise regulation was posted.
Recommendations: None at this time.
RESPIRATORY PROTECTION
The written program was current. Air taps were labeled in the control room. Respirator cleaning stations were clearly identified and had cleaning supplies readily available.
Recommendations: M 1. Storage of respirator face pieces attached to auxiliary air supplies for breathing air bottles needs to be upgraded for units located in control room area.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 2. The semi-annual evaluation of the plants respiratory program needs to be completed for 1996.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 3. Dust mask should be worn when operating sandblasting unit in Maintenance Shop until leaks in the system are repaired.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
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HR = Highly Recommended
PERSONAL PROTECTIVE EQUIPMENT
The written Personal Protective Equipment program was current.
Recommendations: None at this time.
ERGONOMICS
Plant personnel attended the Save-A-Back presentation.
Recommendations: None at this time.
THERMAL STRESS
Recommendations: None at this time.
VENTILATION
Hood surveys were current.
Recommendations: M 1. Leak(s) in sandblasting cabinet system need to be repaired to prevent blasting media escaping to atmosphere.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 2. Housekeeping around sandblasting cabinet needs to be addressed.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
WELDING Health hazard and welding rod hazard signs were posted.
M = Must-Do
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DO A 045435 CONFIDENTIAL
HR = Highly Recommended
Recommendations: M 1. Welding curtains should be shortened to provide an opening of two feet at floor level.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
ASBESTOS
The written Asbestos program was current
Recommendations: M 1. Deficiencies on the Annual Inspection form need to be corrected and so documented.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
RADIATION Not applicable.
LABORATORY AUDIT (Wednesday - December 20,1996.)
AUDIT TEAM:
Howard Wilkinson, Sidney Hood
PLANT CONTACT:
Sidney Hood
WRITER:
Howard Wilkinson, A1 Ribes
All action items from the December 14,1993 lab audit was completed. The Glycol I lab was found to be in excellent condition. Housekeeping was excellent Equipment manuals are available to employees. Storage area was found to be in excellent condition (storage space is available, samples are separated, old samples have been discarded).
M = Must-Do
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DO A 045436 CONFIDENTIAL
HR = Highly Recommended
RECOMMENDATIONS: Ml. If you continue to use Mercury filled thermometers, a procedure needs to be developed and communicated to cover clean-up if one is broken.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
ELECTRICAL RELIABILITY AUDIT SUMMARY (October 8,1996)
AUDIT TEAM:
Billy Stears, Phil Bruder
PLANT CONTACT: Ray Johnson
WRITER:
Bill Stears, Phil Bruder
INTRODUCTION:
The electrical reliability audit for Glycol I and Tank Farm was conducted in October 8, 1996 as per the Five Point Electrical Reliability Program. The overall condition of the electrical assets of Glycol I are good and the overall condition of Tank Farm are fair.
Those items identified with an index of 4 or higher in the Electrical Reliability report need some attention and require a response. Please refer to the report.
Glycol I
Recommendations: M 1. Update and post Safety Electrical One Line Diagram, L14 and L83 is not shown
feeding TR-15. MCC 6-A not shown on SEOLD.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 2. Proper labeling of motors per S&LPS-214.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
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DO A 045437 CONFTDFNTT AL
HR = Highly Recommended
M 3. Electrical Room Door: Install warning and exit signs or ligtitg per OSHA 1910.38 (Q) B-1512 and MCC 6A.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 4. Check MP 5C - running very hot.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 5.
Paint the following equipment:
LBS 12
MPD 2B
LBS 83
MPD 102A
MCC 6A
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 6. Install Lockable Switches on all control stations.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
HR 7.
Field junction boxes not installed in accordance with LGE-0370-00. (i.e.)
UB 1403
UB 1200
UB 1401
R-4
UB 1900
Recommended that all junction boxes be checked for compliance with LGE -0370-00.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
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A 045438 CONFTOFNTTAI.
HR = Highly Recommended
HR 8.
Cable trays are overfilled and broken. Repair as needed:
A. Cable tray above B 1505 is overloaded, B. Cable tray by AH7 is broken. C. Cables out of tray by DV 1205 A. D. Cables not tied to cable tray by E 300 A.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
HR 9. Replace missing conduit covers by:
FJB 6102 HB 1403 AD-10 A AD - 10 B
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 10. Seal opening in building 1511 and MCC 6A.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 11. Repair hole in MCC 12 section H5.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 12. Ground switch handle on L 14 and L 83.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion imfe
DO A 045439 CONFIDENTIAL
M = Must-Do
DOW CONFIDENTIAL Page 10
HR = Highly Recommended
Tank Farm
Recommendations: M 1. Post a current Safety Electrical One Line Diagram in all MCC building ' s.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 2. Ground motors in accordance with G7C 0104 * 00, P 111 A&B.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual CompletionDate
M 3.
(Q).
Electrical Room Doors: Install warning and exit signs or lights per OSHA 1910.38
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual CompletionDate
M 4, Install emergency lights and smoke detectors in all MCC's.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual CompletionDate
HR 5. Paint and repair the following MCC buildings:
MCC-D MCC-6
MCC-C MCC-F
MCC-A MCC-E
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual CompletionDate
M = Must-Do
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DO A 045440 CONFIDENTIAL
HR = Highly Recommended
HR 6.
Paint the following equipment:
XFMR-C
MCC-6
XFMR-F
Switch Gear for P 111 A&B
Action Taken/To Be Taken: Responsibility
Expected CompletionDate Actual Completion Date
HR 7. Add Nitrogen Pad to XFMR-F.
Action Taken/To Be Taken: Responsibility
Expected CompletionDate Actual Completion Date
HR 8. Remove abandoned cable in North piperack.
Action TakenJTo Be Taken: Responsibility
Expected CompletionDate Actual Completion Date
HR 9. Tie cable to cable tray B MCC-D.
Action Taken/To Be Taken: Responsibility
Expected CompletionDate Actual Completion Date
HR 10. Replace missing conduit covers by PP-I.
Action Taken/To Be Taken: Responsibility
Expected CompletionDate Actual Completion Date
HR 11. Repair or replace corroded cable trays.
Action Taken/To Be Taken: Responsibility
Expected CompletionDate Actual Completion Date
M = Must-Do
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DO A 045441 CONFIDENT! Al-
HR -- Highly Recommended
REACTIVE CHEMICALS AUDIT (Tuesday - December 3,1996)
AUDIT TEAM:
Buck Bailey, Joe Schell, Gerald Wagener
ATTENDING:
Howard Wilkinson, Joe Schell, Charles Jackson, Leigh Hill, Buck Bailey, Julie Broome, S. M. Hood, Kenny Chemin, Roger Thompson, Gerald Wagener
PLANT CONTACT:
WRITER:
Gerald Wagener
During the "walk-through" inspection, a spot check of the procedures and IPT modules was done. The results were excellent-Pertinent reactive chemical hazards and lines of defense are clearly listed. Also, random interviews of the operations personnel was done to check the deployment of reactive chemical knowledge (SOS's scored 75% and the OS's scored 90%).
Recommendations: M 1. Bring/document closure to the following recommendations from the 1994 New Superintendent Review:
A) Document procedures and safeguards in place to avoid reactivity of methocel pilot plant vent with Glycol 1 vent to TOX.
B) Improve reliability of vent C12 analyzer flow switches. C) Resolve proper location of PO pump temperature thermocouples. D) Develop a chemical compatibility chart for Glycol 1 (perhaps this
should be a global effort for the Technology Center. E) Develop lines of defense for runaway reaction in PO Absorbers.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M2
Develop a reactive chemical manual for Glycol 1 and centralize all of the
reactive chemicals files for the plant (this includes concerns and follow-up from previous review,
all the worse case scenarios and lines of defense, chemical compatibility chart, and pertinent
reactive chemical data.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
DO A 045442 CONFIDENTIAL
M = Must-Do
DOW CONFIDENTIAL Page 13
HR = Highly Recommended
M3
Perform positive ID testing on PO absorber bed material before placing in service to
insure that it is diatomaceous earth and not something else.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M4
Concerning the hydrogen source for TPG hydrogenation: Currently, the plant is
depending on COA for proper ID. Ask the Tech Center if there are any known contaminants
(perhaps acetylene) that could cause a runaway reaction. If so, analysis should be done.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Complefion Date
HR 5
Concerning the results of the random interviews of operations persoi i nel:
Determine if the sampling was representative and, if so, consider re-emphasizing reactive
chemicals training.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
SECURITY AUDIT SUMMARY (Tuesday - December 3,1996))
AUDIT TEAM:
Joe Goodwin
PLANT CONTACT:
WRITER:
Howard Wilkinson, Joe Goodwin
Employees challenge strangers in their work areas. A sign-in/out log is available for visitors to the plant in the Control Room. Emergency communications and alert systems are in place and working well.
Keep up the good work.
Recommendations: None at this time
DO A 045443 CONFIDENTIAL
M * Must-Do
DOW CONFIDENTIAL Page 14
HR = Highly Recommended
LOSS PREVENTION/FIRE/BURNER MGMT7CEI REVIEW (Date: Tuesday, December 3,1996)
AUDIT TEAM:
Buck Bailey, Bill Franklin, Leigh Hill, Steve Janda
PLANT TEAM:
Leigh Hill
ATTENDING:
PLANT CONTACT:
Leigh Hill
WRITER:
Buck Bailey
INTRODUCTION:
Following is a list of recommendations from the recent Consolidated Audit at the Glycol 1 plant. These were developed from a standard Loss Prevention questionnaire, plant inspection, and discussion with the staff and the Technology Center,
OPERATING DISCIPLINE
Recommendations: 1. This topic was reviewed and there are no recommendations for further action.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
CHEMICAL EXPOSURE
Recommendations: M 1. Complete the CEI plot plan documentation to show the extent of the exposure area for the spill scenario. Set up a permanent PHA / CEI file to comply with the OSHA documentation
practices.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
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DO A 046444 C.ONFTDFNTIAL
HR = Highly Recommended
PROCESS HAZARD ANALYSIS/HAZOP
Recommendations: M 1. Complete the F&EI plot plan documentation to show the potential damage areas for the calculated cases. Contact Engineering to get a permanent drawing made of the plot plan showing the circles of involvement for the calculated cases. Set up a permanent PHA/F&EI file to comply with the OSHA documentation practices.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 2. Review the two HAZOP studies that have been conducted at Glycol 1 to be sure all recommendations have been acted upon. File in a permanent PHA file for OSHA documentation.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
FIRE PROTECTION SYSTEMS
Recommendations: HR 1. Update the Fire Protection Plat Plan as a part of the T-300 area sprialder project.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
CRITICAL INSTRUMENT SYSTEMS
Recommendations: M 1. Die Critical Instrument L.P.P. 15.4 has recently been updated and the Louisiana Division Instrument Department has taken a lead role in reviewing the various plant's programs. Contact them to have someone from the plant technical staff as a primary contact for reviewing and updating the critical instruments list and test procedures.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
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DO A 045445 CONFIDENTIAL
HR = Highly Recommended
PRESSURE VESSELS
Recommendations: None at this time.
INSURANCE PACKAGE
Recommendations: M 1. Complete the compilation and review of the various documents of the Insurance Package for communication with the Corporate Loss Prevention and Insurance departments.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
BURNER MANAGEMENT:
Recommendations: M 1. Schedule a review meeting with Loss Prevention and the Mod5 burner management control engineer to discuss the THROX burner program controls. Complete the Mod5 burner management audit questionnaire prior to the meeting.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M 2. Update the THROX burner management documentation package to comply witit tire current Loss Prevention Principle 13.1.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
DO A 045446 CONFIDENT! At...
DOW CONFIDENTIAL Page 17
HR = Highly Recommended
FACILITY SITING
Recommendations: Ml. An area of special emphasis by OSHA is the inclusion of control room / office siting considerations as part of the plant PHA's. Summarize in the audit questionnaire features of the building locations and other safety systems that contribute to personnel protection. (Ex. Separation from PO, gas monitors, fire protection systems, smoke detectors, etc.)
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
MISCELLANEOUS:
Recommendations: M 1. Update the questionnaire to reflect the few changes made during the pre-audit Keep the updated copy on file as the original Consolidated Audit / PHA document for OSHA record keeping purposes.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
SAFETY AUDIT (Tuesday, December 3,1996)
AUDIT TEAM:
Don Jones, Howard Wilkinson, Julie Broome, Eddie Supple, Brian Pope, Wayne
Turner and Pam Usie
PLANT TEAM:
Don Denova
ATTENDING: Don Denova
Charles Jackson, Don Jones, Julie Broome, Roger Thompson, Howard Wilkinson,
PLANT CONTACT: Don Denova
WRITERS:
Don Jones, Howard Wilkinson,
M = Must-Do
DOW CONFIDENTIAL Page 18
00 CON?
HR = Highly Recommended
SAFETY QUESTIONNAIRE
A. Program Structure and Planning No Recommendations
B. Employee Participation No Recommendations
C. Contractor Safety No Recommendations
D. Accident/Incident Investigation and Reporting No Recommendations
E. Audits No Recommendations
F. Safe Work Practices No Recommendations
G. Emergency Planning and Means of Egress No Recommendations
H. Employee Training No Recommendations
I. Safe Operation of Motor Vehicles and Motorized Handling Equipment No Recommendations
J. Off-The-Job Safety No Recommendations
EMPLOYEE SURVEY
HR 1. Review Pre-Audit Safety Survey results and take appropriate action.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
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DO A 045448 CONFIDENTIAL
HR = Highly Recommended
DOCUMENTATION REVIEW AND FIELD AUDIT
AUDIT TEAM:
Julie Broome, Roddey Peebles, Pam Usie, Eddie Supple, Mike Wetsel
M 1. Consolidated audit needs to be circulated and follow-up items need to be reviewed with personnel. Opportunity should be given for employee comments. Documentation should be kept showing review and follow-up on any comments. (OSHA 1910.119)
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 2. Document review of FEI and CEI with plant personnel. Cover worst case scenario and show plot plan with radius of exposure circles. (OSHA 1910.119)
Action Taken/To Be Taken:
Responsibility
Expected Completion Date Actual Completion Date
M 3. Label HAZCOM Book for MSDS sheets. (OSHA 1210.1200)
Action Taken/To Be Taken:
Responsibility
Expected Completion Date Actual Completion Date
M 4. Ensure refresher training of employees is complete and documented. (OSHA 1910.119)
Action Taken/To Be Taken:
Responsibility
Expected Completion Date Actual Completion Date
M 5. Consult with employees on frequency of refresher training. Document survey of employees on refresher training frequency. (OSAH 1910.119)
Action Taken/To Be Taken:
Responsibility
Expected Completion Date Actual Completion Date
HR 6. Review PSM piping registration program and inspection results with employees.
M = Must-Do
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HR = Highly Recommended
0 A 045449 CONFIOENTTfyi
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M 7. Review and reinforce location of MSDS manual with contract employees. (OSHA 1910.1200)
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M 8. Ensure operators are aware of critical operating procedures and their location on the computer. (OSHA 1910.119)
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 9. Supporting documentation for '93 audit--CEI, FEI, Reactive chemicals--was not found during documentation audit Information should be easily accessible. CEI, FEI, reactive chemicals sections must be retained for life of equipment (OSHA 1910.119)
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 10. Post plant safety policy with plant superintendent signature. (OSHA VPP)
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
HR 11. Update division safety policy in control room on bulletin board. (OSHA VPP)
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M 12. &(b))
Need sandblast manometer installed to do flow checks
M = Must-Do
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(OSHA 1910.94(4) (a) 00 A 0454*50
conftDFNtt4a7 HR = Highly Recommended
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M 13. Update fall protection inspection checklist used on C9 inspection. (Need to have engineering data to perform inspection of any permanently installed fall protection.) (S&LP S-32S HI.d)
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 14. Document completion or include work orders on C9 inspection items to allow for tracking of follow-ups to deficiencies. Recommend routing inspections through the safety coordinator to ensure documentation is complete prior to filing. S&LP S-330
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 15. Plant orientation needs to be updated--several inaccurate scenes (use of mouthbit respirator for work). OSHA 1910.1200
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 16. Any block indoctrination tests which indicate a score of less than 100% or show items are missed must also show review of correct information with the individual. OSHA 1910.119
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M 17. Need to update and post list ofjobs not requiring permits or onsite (removing/ tunning conduit, pulling wire are too general to be listed). (USA-4 & LAD-4 II. A& B)
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M 18. PSM piping files need to be completed with owner signature and inspector signature. Work orders should also be cross referenced to specific deficiencies/items found. OSHA 1910.119 & S&LP S-334
M = Must-Do
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HR = Highly Recommended
D A 0454&f conftdfnti^
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M 19. Repair intercom by DV-4001 (load station).
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 20. Hamesses/lanyards not tagged and improperly stored (load rack Piv-ij>g i 50 j, I&E shop, maintenance shop, mezzanine area in shop). Audit areas for non-compliance and remove any untagged or improperly stored equipment. (S&LP S-328 III. d)
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 21. Evaluate fall prevention on tanks in tank storage area. (S&LP S-328 Attachment 1)
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 22. Install or repair handrail on structure south of DV-1203. (S&LP S-328)
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 23. Oxygen reading is 25% on AH-10 (Hbm is off on many of them). AH-6 oxygen meter horn is on but need appears stuck at 20.9% Audit analyzer houses for proper functioning of oxygen instrumentation and alarms. (USA-5, LAD-5 IV A&B Enclosure entry)
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 24. Place analyzer house #11 bottle on grating to prevent corrosion. S&LP S-209
Attachment 1 D.
DO A 04545?
Action Taken/To Be Taken:
CONF TDENT i At.
M = Must-Do
DOW CONFIDENTIAL Page 23
HR = Highly Recommended
Responsibility
Expected Completion Date
Actual Completion Date
M 25. Post entrance requirements on door to AH-2. LAD-5 E
Action Taken/To Be Taken Responsibility
Expected Completion Date
Actual Completion Date
M 26. The wire securing cylinder behind AH-2 is only acceptable for short term installations. Permanent cylinders should be stored using a chain or metal strap. (S&LP S-209 Attachment 1) S&LP S-209 Attachment 1 A.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 27. Evaluate replacing R-4 decking. It is badly corroded.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual
CompletionDate
M 28. Monogoggle sign laying on ground by E-256A should be posted.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual
CompletionDate
M 29. One of the Five minute air pack cabinets by C-2C is empty. Restock or remove.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual
CompletionDate
HR 30. Evaluate modifying or removing unsupported 2" line above P37.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Comp'.ei'r-'
M 31. Repair chain monoggogle signs around T-200. Action Taken/To Be Taken:
M = Must-Do
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A 045A53 DO CONF tr)E^'nAL HR = Highly Recommended
Responsibility
Expected Completion Date
Actual Completion Date
M 32. Ladder south of D-62 needs gate. (OSHA 1910.23 (a) (2))
Action Taken/To Be Taken;
Responsibility
Expected Completion Date
Actual Completion Date
M 33. Repair eye wash on safety shower in diked area of DH-1202B. (S&LP E-5)
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 34. Evaluate support on utility air station #3.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 35. Repair intercom by E256C.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 36. Re-hang monogoggle sign (laying on deck) in D2 area.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M 37. Replace or repair railing by AH-11. Top rail is missing (2 foot section ) by AH-11 2nd deck. S&LPS-328
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion bate
HR 38. Evaluate steps on ladders by DV-1261. First and last step is too large. Consider adding concrete platform or additional step.
M * Must-Do
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HR = Highly Recommended
DO A 045454 CONFIDENTIAL
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
HR 39. Label start/stop position on P-300C/D. Start/stop positions unreadable P-300 C/D.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 40. Evaluate replacing grating south side of E-310. Grating is corroded.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 41. Pipe south of E-152A is labeled hot, but is painted orange like nitrogen. Consider using alternate color to orange if the line is not a nitrogen line.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 42. Repair holes in grating just south of AH-2 (trip hazard). Also, evaluate securing the grating as some grating is more flex than others. (OSHA 1910.22 (a) (3))
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 43. Evaluate placement of hazard/waming signs on deck around/above D-102. Caution sign is turned so visible coming down steps. Signs says to notify CR. No signs on ladders.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 44. Replace jack stands by E-130 and with line off of E-108B. They appear to be
homemade with no readable capacity or anti slip rings. Evaluate permanent methods of support if
these stands are not for temporary use. (S&LP S-217)
Oo ^
Action Taken/To Be Taken:
Co^p T n 54 5 5 [NTi4L
Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
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HR = Highly Recommended
HR 45. Evaluate cage on ladder (east of E-710 to deck to safeties). Ladder is close to unprotected handrail where fall could result to ground.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 46. Large step from platform to ladder on top of T700. Consider extending cage to handrail behind ladder.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 47. Evaluate modifying steps to piperack by roadway west side of plant--tread depth appears to be too short
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M 48. Empty and full escape packs are stored together in I&E shop. These should be separated and clearly labeled.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 49. TDC room needs to be inspected for housekeeping-doors open, covers off, ladder guard not used. Aisle on mezzanine level of TDC room was cluttered and also has some unprotected floor openings (south wall).
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 50. Storage shelf is about to fall down and needs repair on 2nd level of I&E shop.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
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HR = Highly Recommended
DO A 045456 CONFIDENTIAL
M 51. 2nd level of I&E Shop must have capacity posting.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 52. Wooden box outside of pipe threader lean-to (maintenance shop) is busted. Nails exposed. (Contains alignment clamps.) Box should be repaired or destroyed.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 53. Railing on mezzanine level in maintenance shop is too low to be guardrail for fall prevention (S&LP S-328).
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 54. Safety equipment required for grinder in maintenance shop has some handwritten requirements which may be ignored. Proper permanent sign should be installed. S&LP S-217 II A.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 55. Capacity of lifting device in shop should be posted. S-217 ID. D.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 56. Nylon chokers in millwright area hard/impossible to read labels. Chokers should be removed from service or returned to tool room. S&LP S-216IV C.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Anna* Crwu/
M 57. Rehang Do Not Enter sign by DV-1262. Sign down.
CDOONFAIDENTIAL
M = Must-Do
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HR = Highly Recommended
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M 58. Post and mark exits in maintenance shop.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 59. Evaluate changing orientation of handle on safety shower by DV-3. Handle to shower is vertical instead of horizontal--could be hard to activate.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
HR 60. Beware of Obstructions sign in tank farm needs to be repaired.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
HR 61. Emergency phone #'s are incorrect in tank farm (DV-3 and DV-4). Correct signs.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
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Oo cqnf * <s^ HR = Highly Recommended
HAZARDOUS MATERIALS TRANSPORTATION REVIEW (HMTR) AND DISTRIBUTION FACILITIES ASSESSMENT (DFA) (Date of Review and Assessment: 12/12/96)
AUDIT TEAM:
Dean Smith, L.C.(Skipper) Hughes
PLANT TEAM:
Sidney Hood
PLANT CONTACT:
Glenda Townsend, Pat Lars
LOGISTICS CONTACT: Sue Grissom
WRITER:
Dean Smith
Areas Reviewed:
Rail Car Loading / Unloading Cargo Tank Loading / Unloading D.O.T. Compliance
Chemicals Reviewed Propylene Oxide Propylene Dichloride Carbon Tetrachloride and Crude stream Perchloroethylene and Crude stream Allyl Chloride PDC
DRJ# 4 3 4 4 4
Transportation Mode(s) Rail Hwy
yes yes yes Intermodal yes no yes no yes
(All incoming) Incoming
All areas of the HMTR were satisfactory. Items from the previous Consolidated Audit: Recommendations: All items from the previous audit have been addressed satisfactorily.
DISTRIBUTION FACILITY ASSESSMENT - DFA
Compliance related items:
M 1. Loading / Unloading Check lists for Rail Cars and Cargo Tanks Check lists are being used for
a pre-inspection and post inspection of loading and off-loading of tank cars and cargo tanks (inclusive of tank trucks and intermodal containers). However, some items that need to be documented (which may be included in the training/procedures) are not included.
M = Must-Do
DOW CONFIDENTIAL Page 30
-n oas459 HR = Highly Recommended
Recommendation: Please refer to the latest edition of the N.A. Hazardous Materials Distribution D.O.T. compliance check sheet. Procedures and check sheets may be located on the following server: WLASIM2 PCCOMMON \ DOT\ Dottmg > Rcl&ulck - Rail car load and unload check sheet > Tcldunld = DOT procedures for T/C load/unload > Ttldunid = DOT procedures for T/T load/unload. You may want to wait for the new edition of the S&LP's to come out that may include other requirements in this area.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
2. Check lists Legibly Signed: Some check lists reviewed did not have a legible signature. Review with loaders to ensure a legible signature is used - this could include one or two initials and the last name.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 3. Connected Transfer Lines: D.O.T. requires that transfer lines be disconnected immediately
after the transfer process has taken place and for any other reason which may cause a halt to the transfer process. There has been no exact definition of what "immediately" means - other than interpretations rendered by our local FRA inspector. "Immediately" to him is no longer than it takes to shut the system down and secure the car from spills, leaks or drips. This does not include enough time to pull and analyze a sample. Recommend following as closely as possible to the above interpretation.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
Tank Truck Area - Safety:
HR 1. Transfer hoses at the P.O. loading station - recommend removing unnecessary hoses that have
not been used in a while. One hose flange was noted as being fairly well rusted on the gasket
face.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
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HR = Highly Recommended
DO A 045460 CONFIDENTIAL
M 2. How does the loader know whether or not the loading hose is within testing time frame. A tag
is affixed to the hose when it is first tested and registered in the pressure vessel program - but after that, who or what system keeps up with testing. (See additional comments in Rail area)
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
Tank Truck Area - Loss Prevention
HR 1. Why is there no foam fire suppression system at the P.0 loading rack - has S&LP and Fire
Protection reviewed this area?
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
Rail Car Area - Safety:
M 1. Setting Brakes: At the time of inspection, two t/c's did not have brakes set as per D.O.T,
Railroad may or may not set brakes on the t/c's that they "spot" at the loading rack. All cars in the process of being loaded or unloaded must have the brakes set well.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
HR 2. Product load arms:
Recommend as part of the plant/loading facility C-9 check list, regular inspection and/or servicing of the swivel joints of each loading arm.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
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HR = Highly Recommended
M 3. Regular Testing Of Load/Off-load Tubes and Hoses: As of this review, most transfer hoses
are initially tested and logged with the divisions pressure vessel program. With the next issue of the S&LP's, this process will be transferred to the plant and/or appropriate logistics area. Also, testing requirements and frequency will change. Recommend putting in place a system to acuurately track the status of all loading/off-loading tubes and hoses.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
Rail Area Environmental:
HR 1. The rail car - central loading rack - has drip pans for small leaks, however has no contain -
ment for a major spill. This was noted in the Environmental Supt. Audit Recommend reviewing need for containment and/or diversion.
Action TakenJTo Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
Additional comments: The Glycol I plant is essentially not responsible for the Central Load Rack; this responsibility now lies with the Site Logistics group.
Thanks to Skipper Hughes for all his efforts in helping to complete this review and assessment; the Glycol I plant and the Central Load rack have done a great job in improving this operation over the past several years - keep up the good work!
M = Must-Do
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OO A 045462 CONFIDENTIAL
HR = Highly Recommended