Document 10v3XXbgLDqzLrNvK1qBzOQ3q
*1^1J
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Date of Report: Superintendent:
DOW NORTH AMERICA
JZ.&gw'g
CONSOLIDATED -AUDIT PROGRAM
The Dow Chemical Company**'
fj^r
19
5/795
Methanes Plant
PO Box
ORNft`ana 70765-0150 linin'
Don Taylor, Bldg. 4601
cc: Roddey Peebles, Bldg. 1601, LAD Maurice Oubre, Bldg. 6650, LAD Chris Messelt, Bldg. 3502W, LAD John Muiphy, Bldg. 101, Freeport, TX
Buck Bailey, Bldg. 3301W, LAD J"
'lirM?ILC1 0
Enclosed are the recommendations from the various audits for your response. According
to the Dow North American Area Consolidated Audit Program Guidelines and the OSHA ik^P
Process Safety Management (PSM) standard 1910.119, you must develop an
implementation plan as a response to the recommendations. The plan must include the
& (1*7 76
name(s) of the employee(s) assigned to each action item along with an expected completion u f ^
date for each item. Your plan must be reviewed and approved by the area Major Manager
by July 5, 1995.
*
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 (CE1), Process Safety and Loss Prevention/Fire/Bumer Management audit and the Employee Survey Results. This must be completed within 90 days after the audit and documented.
Please send your approved implementation plans to Connie Kalencki, Bldg. 3502W by July 7,1995. 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. f 2.
3. 4. 5. 6. 7. 8. 9.
LAD Process Hazard Analysis Occupational Health Audit Laboratory Audit Electrical Reliability Audit Reactive Chemical Audit Security Audit Hazardous Materials Transportation Audit Loss Prevention/Fire Audit Safety Audit
Howard Wilkinson, Administrator LAD Consolidated Audit Program
M = Must*Do
DOW CONFIDENTIAL Page 1
HR = Highly Recommended
DO A 03?7fi6 CONFIDENTIAL
LAD PROCESS HAZARD ANALYSIS
Recommendations:
1. Communicate results of the Consolidated Audit to plant personnel within 90 days after the audit report date. The communication must include a brief summary of the Reactive Chemical Review, Employee Survey results, Chemical Exposure Index results, Safety & Loss Prevention/Fire/Bumer Management Audit results.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
x I uiir
Actual Completion Date
M = Must-Do
DOW CONFIDENTIAL Page 2
HR = Highly Recommended
DO A 037787 OONFTDFNTTAL
OCCUPATIONAL HEALTH AUDIT
0
AUDIT TEAM: Dave Albert, Jackie Paul
PLANT IH CONTACT:
WRITER:
Mike Young Maralee Marchant
M = Must-Do
DOW CONFIDENTIAL Page 3
HR = Highly Recommended
00 A 03078a OONF TDFNTIA!
LABORATORY AUDIT
(April 5, 1995 - 10:30 a.m. - 12:00 p.m.)
AUDIT TEAM:
Howard Wilkinson, David Smith, A1 Ribes
PLANT CONTACT: Terry Vavassuer
WRITER:
Howard Wilkinson, A1 Ribes
The Methanes Plant laboratory seems to be running well since the last audit. All action items from previous audit have been completed and closed out. Cabinets are labeled and emergency shut-offs are in place for GC's.
Recommendations:
M 1. Remove all re-agents that are not needed in the process (calcium carbide).
Action Taken/To Be Taken:
Responsibility
Terfij
Expected Completion Date
7/7 hs
HR 2. Clean out all spray paint cans.
Actual Completion Date
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
7/7
Actual Completion Date
M 3. Install sign on refrigerator door "Not Explosive Proof'.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
6T/15*
Actual Completion Date
M = Musi-Do
DOW CONFIDENTIAL Page 4
HR = Highly Recommended
00 A 037789 CONFIDENTIAL
ELECTRICAL RELIABILITY AUDIT SUMMARY
(February 1995)
AUDIT TEAM:
Mike Gee
PLANT CONTACT: I^a^ \]ou+J6-
WRITER:
Mike Gee
The electrical reliability audit for Chlorinated Methanes was conducted in February, 1995 as per the Five Point Electrical Reliability Program.
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.
Condition of electrical assets of Methanes show a commitment to continuous improvement. The audit team finds that CMP has an overall good condition.
Recommendations:
HR 1. Ten - fifteen percent of motors have grounds loose or not grounded to frame. Ground Motors per L7C-0101-00 par 5.4. Train block electrical personnel in proper grounding practices.
Action Taken/To Be Taken:
Responsibility
CWe
Expected Completion Date Actual Completion Date
HR 2. Ninety percent of cables in field junction box have the overall shield ungrounded. Connect overall shields to ground. Train block Instrument and Electrical personnel in proper grounding practices.
Action TakenITo Be Taken:
Responsibility
tedux flurrfs
Expected Completion Date
7lithe
Actual Completion Date
M = Musi-Do
DOW CONFIDENTIAL Page 5
HR = Highly Recommended
DO A 037790 CONFTDFNTTAI
M 3. Safety Electrical One Line diagram is not current or correct. Correct SEOLD.
Action Taken/To Be Taken:
Responsibility
i(odr\b{ (Wft
Expected Completion Date
Sh^lfiS
Actual Completion Date
M 4. Bus system not identified by SEOLD I.D. Label all switchgear bus with SEOLD I.D.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
I M = Must-Do
DOW CONFIDENTIAL Page 6
HR = Highly Recommended
DO A 03?? CONFTDFNTT
O' <
REACTIVE CHEMICALS AUDIT
Thursday, November 10, 1994 (8:30 a.m. to 11:00 a.m.)
AUDIT TEAM: Gerald Wagener, Don Jones, John Monroe, Joe Schell, Buck Bailey, Scott Hanrahan, Mark Mitchell, Seb Corbino
PLANT CONTACT:
Kevin Kelley
ATTENDING:
Don Taylor, Julie Clebert, Joe Schell, Gary Rizzo, Buck Bailey, Vic McMurray, Jim Haney, Gerald Wagener, Barry Young, Kevin Kelley, Howard Wilkinson
WRITER:
Gerald Wagener
RECOMMENDATIONS FROM REACTIVE PRE-CONSOLIDATED AUDIT REVIEW (served as new superintendent review) Thursday, November 10, 1994 (8:30 a.m. to 11:00 a.m.)
M 1. Concerning the inadvertent use of titanium parts in dry chlorine:
a. Add a statement to the block safety indoctrination package on the reactive chemical hazards of using titanium parts in dry chlorine service.
b. Consider adding a checksheet that addresses this hazard to maintenance procedures for equipment used in chlorine service.
Action Taken/To Be Taken:
Responsibility
flriaA QotaHo
Expected Completion Date
Actual Completion Date
HR 2.
Concerning the reactive chemicals review slides for the
Thermal Chlorinator: Add "Evacuation of personnel from reactor
area during start-up" to the lines of defense for avoiding injuries due
to a possible deflagration/detonation
Action Taken/To Be Taken: Responsibility
fv
M = I )o
Expected Completion Date
7It hr
50
COW CONFIDENTIAL
Page 7
Actual Completion Date
HR * Highly Recommended
03?79? CDOONFtDFWT T 1
M 3.
Consider the following scenario and make sure appropriate safeguards are in place to avoid a runaway decomposition: D-l Tar pot is blocked in and 235# steam flow does not shut off. If the decomposition temperature is not known ARC data should be generated.
Action TakenITo Be Taken:
Responsibility
Keo'ia
Expected Completion Date
i
Actual Completion Date
HR 4.
Review the materials of construction in the sulfuric acid
demister and make sure that they are compatible over the range of
temperature and % sulfuric acid that will be encountered in normal
and upset conditions.
Action TakenITo Be Taken: Responsibility
Expected Completion Date
hr
Actual Completion Date
RECOMMENDATIONS FROM CONSOLIDATED AUDIT FINAL
WRAP-UP MEETING Monday, April 18, 1995(10:30 a.m. to 11:30 a.m.)
HR 1.
There is no reactive chemicals contact person for the Methanes
plant. This responsibility should be assigned to someone.
Action TakenITo Be Taken:
Responsibility
Oorv faytuf
Expected Completion Date Actual Completion Date
HR 2.
Consider developing a reactive chemicals IPT module and
include all the major worst case scenarios and lines of defense.
Action TakenITo Be Taken: Responsibility
Expected Completion Date
1 (lh 5
Actual Completion Date
M = Must-Do
DOW CONFIDENTIAL Page 8
HR * Highly Recommended
DO A 030793
confidential
HR 3.
Summaries of reactive chemicals reviews including the worst
case scenarios and lines of defense should be reviewed with the outside
operators and boardmen.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
io loo
Actual Completion Date
HR 4.
Review job procedures and if there is a reactive chemical
hazard associated with the job being performed consider adding a
paragraph listing the hazard.
Action Taken/To Be Taken:
Responsibility
(ncOu\
Expected Completion Date
Actual Completion Date
HR 5.
Train operators on the reactive hazard of inadvertently using a
titanium part in dry chlorine service. Most did not know when
interviewed.
Action Taken/To Be Taken:
Responsibility Don'ut
Expected Completion Date
fe/ 30
Actual Completion Date
HR 6.
Plant communications book could be an excellent means for
communicating current reactive chemical issues. We only found one
entry pertaining to reactive chemicals (Sealants database information
from Kevin Kelley). Information on the incident involving methyl
chloride in a tank car with aluminum baffles could not be located.
Action TakenITo Be Taken:
Responsibility
Jul.e
Expected Completion Date
<o/3D
Actual Completion Date
7. Worst case scenarios for the various sections of the plant are not included with the procedures. Consider either including them with
the procedures or include them in the new Dynamic Data Display system.
Action TakenITo Be Taken:
Responsibility
Expected Completion Date
it) ^ tt cxbtK.
Actual Completion Date
M = Musl-Do
,, .DOW CONFIDENTIAL Page 9
HR = Highly Recommended
HR 8.
R-250 procedures for dumping spent catalyst: The specific
hazard of spontaneous ignition of organic material on the spent
alumina is not listed. The comment in the procedures is "because
catalyst is so dry, we need to spray water mist on the catalyst as it is
being sucked from the reactor to comply with landfill regulations."
Action Taken/To Be Taken:
Responsibility
SWoe.
Expected Completion Date Actual Completion Date
7/ 1*1
HR 9.
PSA carbon change out procedures need to be reviewed and
the flammability hazard of dry carbon in air need to be included.
Action Taken/To Be Taken: Responsibility
Expected Completion Date Actual Completion Date
HR 10. A listing and summary of reactive chemicals data was not available for the Methanes plant. This needs to be done and we recommend that the Tech Center assists.
Action Taken/To Be Taken: Responsibility
Ktoi'n / IMimce
Expected Completion Date
1
Actual Completion Date
M = Musl-Do
DOW CONFIDF.NTIAL Page 10
HR = Highly Recommended
D A 03?795 ^onftdfntjai
SECURITY AUDIT SUMMARY
(April 18, 1995)
AUDIT TEAM: A1 Lott
PLANT CONTACT:
Bruce Miles
WRITER:
Howard Wilkinson/Al Lott
Employees challenge strangers in their work areas. A sign-in/out log is available for visitors to the plant in the office area.
Emergency communications and alert systems are in place and working well.
Keep up the good work.
Recommendations:
No Recommendations at this time.
M = Must-Do
DOW CONFIDENTIAL Page 11
HP. = Highly Recommended
00 A 033796 OONFIDFNTTAI.
HAZARDOUS MATERIALS TRANSPORTATION REVIEW (HMTR) AND DISTRIBUTION FACILITIES ASSESSMENT (DFA)
0
AUDIT TEAM: Dean Smith
PLANT CONTACT:
WRITER:
Julie Clebert Dean Smith
Chemicals Reviewed DR1 # TRANSPORTATION MODE: PRODUCT (P) ________________________________ -All received by Hwy-__________ FEED (FT)
M = Must-Do
DOW CONFIDENTIAL Page 12
HR = 1
.y Recommended
DO A 037797 GONFTDFNTTAL
LOSS PREVENTION/FIRE/BURNER MGMT./CEI REVIEW
(Tuesday, April 18, 1995)
AUDIT TEAM: Kevin Alexcee, Bill Franklin, Roddey Peebles
PLANT CONTACT:
Jim Haney, Kevin Kelley, Steve Ledoux
ATTENDING:
Don Taylor, Julie Clebert, Kevin Alexcee, Gary Rizzo, Buck Bailey, Vick McMurray, Jim Haney, Stephen Ledoux, Kevin Kelley, Howard Wilkinson, Barry Young
WRITER:
Buck Bailey, Kevin Alexcee
Following is a list of comments and recommendations resulting from the Consolidated Audit / Loss Prevention audit:
The plant is generally in good condition with respect to Loss Prevention design, due in part to the recent plant capital expansion. Many of the current Loss Prevention design considerations were incorporated into that project.
FLAMMABLE MIXTURES
HR 1. Review the low pressure flammables storage tanks to assure
rfv.'
that the controls and monitoring is adequate to prevent oxygen
co^
contamination.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M = Musi-Do
DOW CONFIDENTIAL Page 13
HR = Highly Recomme___a
DO A 03279B OONFTDFNTIA1
FACILITY SITING - DRAINAGE
HR 1.
When the sprinkler system is next tested, verify that the
surface drainage is adequate to avoid area flooding.
Action Taken/To Be Taken: Responsibility
O
Expected Completion Date
Actual Completion Date
EQUIPMENT / BUILDING LOCATION AND FIRE RISK
HR 1.
Review cable tray passage ways to be sure they are properly
sealed to comply with good electrical installation guidelines.
Action Taken/To Be Taken:
Responsibility
CWl't Lh/nmcV
Expected Completion Date Actual Completion Date
HR 2.
Review the possibility of installing a combustible gas monitor
in the fresh air intake to office and control room.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
CHEMICAL EXPOSURE INDEX (CEI)
HR 1.
Review the layout of chlorine area monitors to reconsider the
need for additional installations, specifically in the NW quadrant of the
plant.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
7/56
Actual Completion Date
HR 2.
Some of the chlorine instrumentation valving is showing signs
of corrosion. Also, some indications of gasket deterioration has been
observed.
Action TakenITo Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
DOW CONFIDENTIAL M HR = Highly Recommended
Page 14
DO A 037799 CONFIDENTIAL
HR 3.
Wrap up the documentation of the CEI calculations package.
Action Taken/To Be Taken:
Responsibility
Keon
Expected Completion Date
&l IS"
Actual Completion Date
M 4.
The Dow "Process Risk Management Guideline" requires a HAZOP study for any scenarios areas where the CEI exceeds 200. Since Dow has reviewed this company guideline with OSHA, it is also an OSHA 1910.119 requirement. Review with Loss Prevention to determine the scope and timing of the HAZOP study activity.
Action Taken/To Be Taken:
Responsibility
ty* G^c-&.
Expected Completion Date
7//y
Actual Completion Date
HAZOP See recommendation in the CEI section.
ELECTRICAL SYSTEMS
HR 1.
Any recommendations from the Electrical Maintenance Dept.
5-Point Audit should be included here.
Action TakenfTo Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
FIRE PROTECTION SYSTEMS
HR 1.
Review and update the plant Fire Protection Plot Plan to
comply with recent changes made in the area coverage. Contact Loss
Prevention to initiate the activity.
Action TakenfTo Be Taken:
Responsibility
Expected Completion Date
7/* as
Actual Completion Date
M = Must-Do
DOW CONFIDENTIAL Page 15
HR = Highly Recommended
DO A 032800 CONFTDFNTTAl
HR 2. Review the smoke detector needs for B-4610 with the Fire Protection Dept.
Action Taken/To Be Taken:
Responsibility
*<
Expected Completion Date
Actual Completion Date
HR 3.
Review the CGD coverage in the new area of the plant.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
HR 4.
Combustible gas detectors should be included on the critical
instruments program.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
CRITICAL INSTRUMENT SYSTEMS
HR 1.
Review instruments test procedures. Several are listed as
"Missing" or "Wrong name".
Action Taken/To Be Taken:
Responsibility
AtsWch'i
Expected Completion Date
thy
Actual Completion Date
HR 2.
Some procedures do not indicate the exact process condition
the instrument is intended to respond to. Trip or alarm set points
should be noted exactly in the procedure to assure proper calibration
checks.
Action Taken/To Be Taken: Responsibility
A[ swr*
Expected Completion Date
fr/ (H
Actual Completion Date
M = Must-Do
DOW CONFIDENTIAL Page 16
HR Highly Recommended
DO A 032801 C0NFTDFNTTA1
HR 3.
Several of the procedures are redundant. Review these to be
sure they provide adequate instruction for the instrument technician.
Action Taken/To Be Taken:
Responsibility
fW 5WH1
Expected Completion Date
Actual Completion Date
EMERGENCY BLOCK VALVES
HR 1.
Review vessels with >5,000 gal. capacity to see if they comply
with the current Tech Center and L.P.P. guidelines.
Action Taken/To Be Taken:
Responsibility *
<3r> fcoc'C
Expected Completion Date
ufci
Actual Completion Date
HR 2.
Consider identification of EBV's per L.P.P. 1.5.5.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
PRESSURE VESSELS/PRESSURE RELIEF
HR 1.
A division plan is in progress to identify and document PSVs
that must comply with requirements outlined in the OSHA 1910.119
Regulation. Coordinate this activity with the Process Engineering
Dept, to develop a plan of action and schedule. Your area Safety
Superintendent is also assigned to be involved in this effort.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M = Musi-Do
DOW CONFIDENTIAL Page 17
HR = Highly Recommended
DO A 03?80? CONFIDENTIAL
CRITICAL EQUIPMENT
HR 1. Review the critical equipment list for anything not spared that would extend a plant outage due to lack of a replacement. (Ex. Thermal Chlorinator start up rectifier, major compressor parts, etc.)
Action Taken/To Be Taken:
Responsibility
rTT* -
skue. -
.
Expected Completion Date
/o(zo
Actual Completion Date
EMERGENCY PLAN
M 1. Parts of the "Emergency Plan" questionnaire were incomplete. Review to be sure these are adequately included in the plant procedures.
Action Taken/To Be Taken:
Responsibility
(/ft
Expected Completion Date
7/tf
Actual Completion Date
INSURANCE PACKAGE
M 1. Follow up with Loss Prevention to complete and review the insurance material that must be sent to the Corporate Loss Prevention office.
Action Taken/To Be Taken:
Responsibility
ufc
Expected Completion Date
?/m
Actual Completion Date
OSHA PROCESS SAFETY MANAGEMENT
M 1. Review the "Process Hazard Analysis" (F&EI, CEI, Reactive Chemicals) with the plant staff and operations and provide training on the process.
Action Taken/To Be Taken: Responsibility
\)t
Expected Completion Date
'WJd
Actual Completion Date
(
M = Must-Do
DOW CONFIDENTIAL Page 18
HR = Highly Recommended
DO A 037803 CONFIDENTIAL
M 2.
Conduct a PHA training meeting with the plant technical and supervisor staff. Schedule with Loss Prevention to present the training and provide material for further presentation to the operations employees. This will include F&EI and CEI.
Action Taken/To Be Taken:
Responsibility \fiL
Expected Completion Date
iOidO
Actual Completion Date
The preparation and cooperation of the technical staff is appreciated very much. They started early and were well prepared for the pre-audit activity meetings.
Loss Prevention and the Fire Protection Department are available as necessary to be involved in any follow up activity.
^' lust-Do
DOW CONFIDENTIAL Page 19
HR = highly Recommended
DO A 03^804 C0NFTDFNTTA1.
SAFETY AUDIT
(April 18, 1995 -- 12:15 p.m. to 12:45 p.m.)
AUDIT TEAM: Don Jones, Howard Wilkinson, Pam Usie, Roddey Peebles, Eddie Supple
PLANT CONTACT:
Brian Donnallo
ATTENDING:
Kevin Kelley, Larry Young, Jim Haney, Roddey Peebles, Brian Donatto, Vic McMurray, Don Jones, Gary Rizzo, Julie Clebert, Don Taylor, Howard Wilkinson
WRITER:
Don Jones, Howard Wilkinson, Roddey Peebles
Listed as follows is the Final CMP "Safety" Consolidated Audit Report. If you have any questions or comments, please contact Howard Wilkinson on the Questionnaire, me on the Documentation Review and Roddey Peebles on the Employee Survey/Field Inspections.
Thanks for the help!
EMPLOYEE SURVEY
Recommendations:
M 1. Based on the Safety Employee Survey results and review with the CMP staff, action plans should be developed and implemented to address the following areas:
a. Management Support: Questions 5,6,10 b. Employee Participation: Questions 12,13,14,15,16 c. Individual Responsibility for Safety: Questions 17,18,
19,20,22,24,26 d. Miscellaneous: Questions 27,28,29,30,31
Action Taken/To Be Taken:
Responsibility \K,
Expected Completion Date 7/
Actual Completion Date
M = Must-Do
DOW CONFIDENTIAL Page 20
HR = Highly Recommended
DO A 03?805 CONFTDFNTIAl
SAFETY QUESTIONNAIRE
A. Program Structure and Planning
The Methanes plant recently re-organized its safety organization to better serve its employees. The new organization include a safety committee, six safety teams and a safety leadership team. Each team has its own safety responsibilities defined.
The plant superintendent actively participate in all plant safety programs and communicate through safety/tailgate meetings and letters. Safety expectation, objectives, goals and plans are defined and communicated. The Behavior Based safety program is presently being use to address employee behavior and reduce accidents/incidents.
Recommendations:
HR 1. Define/communicate and document a specified time for response to safety suggestions and unsafe conditions.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
7/35
Actual Completion Date
B. Employee Participation No Recommendation
C. Contractor Safety No Recommendation
D. Accident/Incident Investigation and Reporting
Each employee has the responsibility to report all incidents to their immediate supervisor. Incidents are investigated promptly and communicated. Root cause analysis is use to determine cause.
M = Musi-Do
DOW CONFIDENTIAL Page 21
HR = Highly Recommended
00 A 03?806 00NFTDFNTTA1
Recommendations:
M 1. Develop a plan to track corrective actions to closure on accident/incident reports.
Action Taken/To Be Taken: Responsibility
Oon
Expected Completion Date
7 in
Actual Completion Date
E. Audits No Recommendations.
F. Safe Work Practices
Recommendations:
1. Conduct annual performance audits of safe work permits, confined space entry and lockout/tagout. Also, deviations must be track to completion.
Action Taken/To Be Taken:
Responsibility
Qnar\
Expected Completion Date
(2-13-9
Actual Completion Date
M 2. Define who can authorize a confined space entry permit.
Action Taken/To Be Taken:
Responsibility (fe to O0!\
Expected Completion Date
Actual Completion Date
G. Emergency Planning and Means of Egress No Recommendations.
M a Must-Do
DOW CONFIDENTIAL Page 22
HR = Highly Recommended
DO A 032807 CONFTDFNTT Al.
H. Employee Training
Recommendations:
M 1. Documentation of training superintendent and technical employees new to the process must be maintained on file.
Action TakenITo Be Taken: Responsibility
Expected Completion Date
7//<f
Actual Completion Date
I. Safe Operation of Motor Vehicles and Motorized Handling Equipment No Recommendations.
J. Qff-The-Job Safety No Recommendation
DOCUMENTATION REVIEW A. Audits No recommendations.
B. Basic Safety
M 1. Revise Plant Safety Policy per New Superintendent.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
P>rvCu\
M = Musi-Do
DOW CONFIDENTIAL Page 23
HR = Highly Recommended
00 A OBP0O8 CONFTDFNTTAI
C. Unit Emergency Plans
M 1. Emergency drill documentation looks good. However, include name of each individual participating in drill instead of shift name.
Action Taken/To Be Taken:
Responsibility
I(W'X
Expected Completion Date
7//*f
Actual Completion Date
D. Job Safety Analysis
M 1. The Communique Book is used for communicating changes in procedures, etc. However, all applicable employees are not signing and dating.
Action Taken/To Be Taken:
Responsibility
Vi o
Expected Completion Date
7/3-8
Actual Completion Date
E. Accident/Incident Investigations
M 1. Several corrective actions are well beyond the expected completion dates. Emphasis should be placed on completing these actions in a reasonable amount of time. However, in cases where the expected completion date cannot be met, a new expected completion date should be established. In addition, an explanation should be included as to why the original date was not met.
Action Taken/To Be Taken:
Responsibility
/ Gnc\r\
Expected Completion Date
Actual Completion Date
M = Musi-Do
DOW CONFIDENTIAL Page 24
h. Highly Recommended
DO A 002809 CONFTDFNTTAl
F. Safety and Health Suggestions
M 1. Several corrective actions on Unsafe Condition Reports are beyond the expected completion date. Response time needs improvement. Emphasis should be placed on responding in a reasonable amount of time. However, in cases where the expected completion date cannot be met, a new expected completion date should be established. In addition, an explanation should be included as to why the original date was not met.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual CompletionDate
G. Safety Equipment Inspections & Checks
HR 1. Post C-9 checklist in control room.
Action Taken/To Be Taken:
Responsibility
ft mo
Expected Completion Date
7//H
Actual CompletionDate
M 2. Perform checks on C-9 checklist and sign off on master on or before the due dates. All scheduled dates, next due date, last date, etc. blocks need to be completed.
Action Taken/To Be Taken:
Responsibility [2kwi\
Expected Completion Date ^
Actual CompletionDate
M = Must-Do
DOW CONFIDENTIAL Page 25
HR = Highly Rccv .ended
DO A 03?810 CONFTDFNTT Al.
M 3. Deficiencies identified during the C-9 inspections must be documented and corrective actions tracked to completion. Documentation must show: * What corrective action was * Who completed corrective action * When corrective action was completed
Champs System is being utilized in some cases but not all. There needs to be a more consistent approach. In addition there needs to be some follow-up to assure that items listed in the Champs System have been completed.
Action Taken/To Be Taken:
Responsibility
(5 net f\
Expected Completion Date
IP'l&T)
Actual Completion Date
H. Hazard Identification Inspections
M 1. Deficiencies identified during inspections must be documented and corrective actions tracked to completion. Documentation must show: * What corrective action was * Who completed corrective action * When corrective action was completed
Action TakenITo Be Taken:
Responsibility
G-a^/ IWk
Expected Completion Date
71%
Actual Completion Date
I- Predictive Preventive Maintenance No recommendations.
J. Variances No recommendations.
M = Musi-Do
DOW CONFIDENTIAL Page 26
HR = Highly Recommended
DO A 032811 CONFIDENTIAL
K. Contractors/Vendor/Visitor Orientation
M 1. Update plant orientation. Include test as part of the orientation.
Action Taken/To Be Taken:
Responsibility
bn**
Expected Completion Date
y/g%
Actual Completion Date
L. Safety and Operations Training
M 1. Some formal training on Mod V not being documented. Documentation must include the subject, instructor, date and signature of employees that attended.
Action Taken/To Be Taken:
Responsibility
OoMit
Expected Completion Date
toliti
Actual Completion Date
M 2. Maintain technical employee training documentation on file and make sure accessible in a reasonable amount of time.
Action TakenITo Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
HR 3. Training in areas that is not applicable for a particular employee should be noted as "not applicable" on the documentation.
Action TakenITo Be Taken:
Responsibility
Expected Completion Date
/ (Wc IjwvlW't
1/
Actual Completion Date
M 4. Documentation should include signature of employee participating in the training.
Action TakenITo Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
DOW CONFIDENTIAL Page 27
HR = Highly Recommended
DO A 033817 CONFTDFNTIA1
M. Safety Committee Activities No recommendations.
N. Safe Work Practices No recommendations.
FIELD INSPECTION #1
A. Lockout/Tagout System
1. Red tagged equipment over ninety days - masters 6522, 6807, 6821, 6844, 6643, 6703, 7081. Some of these masters have been signed off but not cleared while others were never accepted.
M Recommendation: Need lo clgty up all masters over ninety days by either Retagging or perm^meht isolation.
\
Action Taken/To Be Taken:
Responsibility \ /
Expected Completion Date 7/4
Actual Completion Date
2. On field check of master 7375 the air was not tagged as indicated on the master.
M Recommendation: Train/retrain people on proper isolation and lockout/tagout procedures.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
lit
Actual Completion Date
3. On field inspection of master 7345 the nitrogen purge check valve, assembly was not as per S&LP 313.
M Recommendation^ assembly.
Train ^mpfyype on S&LP 313 check valve
Action Taken/To Be Taken:
A rift'l
M = Must-Do
7/H DOW CONFIDENTIAL
Page 28
(>l<\
HR = Highly Recommended
00 A OOPS13 OONFTDFNTTAI
Responsibility i
Expected Completion Date
Actual Completion Date
(
M = Musi-Do
DOW CONFIDENTIAL Page 29
HR = Highly Recommended
DO A 03P814 CONFTDFNTTAL
B. Safe Work Permit
The safe work permit audit was conducted on 3/1/95. The results of the audit are attached.
M Recommendation: audit.
Follow-up to correct all deficiencies noted in the
Action Taken/To Be Taken: Responsibility
Expected Completion Date
7/tf
Actual Completion Date
C. Control Board Area
1. Step ladder located inside Emergency Response Room blocking door..
IV
M Recommendation: Remove ladder and store properly.
Action Taken/To Be Taken:
'A
Responsibility
Expected Completion Date
it if
Actual Completion Date
2. An out of date plant "Critical Safety Procedures" book was found in the control room, > N
M Recommendation: Remove
Action Taken/To Be Taken: Responsibility
Expected Completion Date 6/?
Actual Completion Date
3. Uncovered garbage can in designated eating area.
M Recommendatioh: Gpver Can\
ilV
Action Taken/To Be Taken:
Responsibility
tyrin')
ixpected Completion Date
(ell
Actual Completion Date
M = Must-Do
DOW CONFIDENTIAL Page 30
HR = Highly Recommended
DO A 03P815 CONFTDFNTTA!
D. Office Area
1. Project trailer
HR a. Needs general housekeeping. Lots of things cluttering floors of empty offices.
b. Lighted exit sign not lit.
M Recommendation: Repair
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
7/V
2. Maintenance Building
Actual Completion Date
a. Janitors closet cluttered with broken chair and junk.
Recommendation: Perform housekeeping.
X'-"-'
Action TakenITo Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
({/( b. Fire extinguisher sitting on floor in hall.
Recommendation: Secure
Action Taken/To Be Taken:
Responsibility
Shga
Expected Completion Date
7/5"
3. Main Office Building
Actual Completion Date
a. Uncovered garbage can in lunch room.
M Recommendation: Cover can
f\ fylfa/rTaken/To Be Taken:
Responsibility
Expected Completion Date
(oil
Actual Completion Date
SM
M = Musi-Do
DOW CONFIDENTIAL Page 31
ITl = Highly Recommended DO A 032816
CONFIOFNTIAI
b. Unsecured fire extinguishers throughout building.
HR Recommendation: Secure all fire extinguishers
Action Taken/To Be Taken:
Responsibility
Dor\r\)t
Expected Completion Date
tolU
Actual Completion Date
c. Old Computer Room in need of a lot of housekeeping. Lots of junk and trash.
HR Recommendation: Perform housekeeping
Action TakenITo Be Taken:
Responsibility 0>C
Expected Completion Date
(el/q
Actual Completion Date
d. Fire extinguishers in old computer room with mounting bracket pulled loose from the wall.
HR Recommendation: Repair
Action Taken/To Be Taken: Responsibility
Expected Completion Date io/m)
Actual Completion Date
HR e. Area behind old control board needs housekeeping attention.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
i//H
Actual Completion Date
f. Five gallon container with no label behind old control board.
M Recommendation: Relabel or properly discard.
Action TakenITo Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M = Musi-*'
DOW CONFIDENTIAL Page 32
HR = Highly Recommended
DO A 037817 C.ONFTDFNTT At
E. Lab Facilities
See lab audit portion of consolidated audit
F. Motor Control Centers
See Loss Prevention and Electrical portions of consolidated audit.
G. Maintenance Shop and I&E Areas
1. Pedestal grinder
a. Tool rest not at or above centerline of the wheel.
M Recommendation: Position tool rest to be at or above centerline of wheel.
Action Takeit/To Be Taken;
Responsibility ftiotA fa
Expected Completion Date
7/7
b. Wheel is not square
Actual Completion Date
M Recommendation: Dress wheel to remove groove in center of wheel
Action Taken/To Be Taken:
Responsibility
faW fa
Expected Completion Date
7/7
c. No waming/instructions signs posted
Actual Completion Date
M Recommendation: Install instruction/waming signs
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M = Musl-Do
DOW CONFIDENTIAL Page 33
HR = Highly Recommended DO A OOPB18
CONFIDENTIAL
2. Pipe threading machine
a. No waming/instruction signs posted
M Recommendation: Install signs
Action Taken/To Be Taken:
Responsibility
Ptd& *v
3. Drill Press
Expected Completion Date 7/?-/
a. No waming/instruction signs posted
M Recommendation: Install signs
Action Taken/To Be Taken:
Responsibility
ft'
Expected Completion Date
Actual Completion Date Actual Completion Date
4. Horizontal band saw N/A
5. Welding and cutting area a. No welding shield around area where welding occurs
M Recommendation: Install curtain or welding shield.
Action TakenITo Be Taken:
Responsibility
f\dbA\
Expected Completion Date
"77^-1
Actual Completion Date
( M = Must-Do
DOW CONFIDENTIAL Page 34
HR = Highly Recommended
DO A 03?819 CONFTDFNTT At.
6. Other equipment
a. Jaws on bench vise badly warn
M Recommendation: Replace jaws
Action TakenITo Be Taken:
Responsibility &W
Expected Completion Date 7/k-f
7. Hand held power tools
Actual Completion Date
M a. Drill with locking trigger - remove drill until trigger lock removed.
Action TakenITo Be Taken:
Responsibility
Expected Completion Date
I 7/il
Actual Completion Date
M b. Jig saw fvith packllet^g^er and no safety - Remove jig saw
Action TakenITo Be Taken: \
Responsibility
Expected Completion Date
8. Hand tools
Actual Completion Date
0>/S
No Recommendations
9. Lifting tools
No Recommendations
10. Safety Equipment
No Recommendations
M = Musi-Do
DOW CONFIDENTIAL Page 35
HR = Highly Recommended
DO A 032830 CONFTDFNTTA1
11. Housekeeping
a. Comers and side walls not cleared of excess material
HR Recommendations: Perform general housekeeping
Action Taken/To Be Taken:
Responsibility
Mm-
Expected Completion Date
7/j.l
Actual Completion Date
H. Warehouses No Recommendations.
I. Spare Parts Storage No Recommendations
J. Motorized Vehicles No Recommendations
FIELD INSPECTION #2
A. Loading Rack
M 1. Compressed gas cylinder outside AH #12 tied with nylon strap. Replace nylon strap with chain.
Action Taken/To Be Taken:
Responsibility
Jalit
Expected Completion Date
7>l
Actual Completion Date
HR 2.
The tank truck loading shack appears to be an air tight building, i.e. rubber gaskets on doors and windows. Check to make certain that with the air conditioner off that the building is not depleted of oxygen if occupied.
Action Taken/To Be Taken:
Responsibility
Julie
Expected Completion Date
obi
M = Musi'Do
DOW CONFIDENTIAL Page 36
Actual Completion Date
.-IR = Hjghly Recommended DO A 033831
OONFTDFNTTAI
M 3. Quick opening valve not plugged on tank truck waste pot. Plug all quick opening valves in hazardous service.
Action Taken/To Be Taken:
Responsibility
Ji>ire
Expected Completion Date
rht
Actual Completion Date
HR 4. Hoses causing tripping hazard on tank truck loading deck. Perform , housekeeping.
Action Taken/To Be Taken:
Responsibility
joLe
Expected Completion Date
7/2 I
Actual Completion Date
M 5. Unlabeled container in tool cabinet. Label or properly dispose contents of container.
Action Taken/To Be Taken:
Responsibility
fall
Expected Completion Date
7/A
Actual Completion Date
M 6. Chainfall on loading filter deck held by rusty choker. Also there is no weight limit on beam holding choker and chainfall. Need to support chainfall with beam with marked capacity equal to or greater than chainfall. Discard rusty choker.
Action Taken/To Be Taken:
Responsibility
xrJit
Expected Completion Date
7/a
Actual Completion Date
HR 7. Hoses causing tripping hazard on loading filter deck. Perform housekeeping.
Action Taken/To Be Taken:
Responsibility
Uol'f
Expected Completion Date
'llA
Actual Completion Date
HR 8. Hoses causing tripping hazard on south end of tank car loading rack. Perform housekeeping.
Action Taken/To Be Taken: Responsibility
TIAe
M Musi-Do
Expected Completion Date
~ih(
DOW CONFIDENTIAL Page 37
Actual Completion Date
HR = Highly . .xomniendcd DO A 03PBP7
OONFIDFNTT Al
HR 9. There is only one safety shower/eyewash station on north upper deck of tank car loading rack. Evaluate the need for a second shower/eyewash.
Action Taken/To Be Taken:
Responsibility Toll?
Expected Completion Date
Actual Completion Date
M 10. Hazardous waste drums in non-designated storage area near tank car loading rack. Remove drums to designated storage area and properly dispose.
Action Taken/To Be Taken:
Responsibility
Julie
Expected Completion Date
7/<*i
Actual Completion Date
HR 11. The waste pots are all purged with N2 through the use of N2 hoses. Hard pipe nitrogen to these waste pots instead of using hoses.
JliKe 7/4
B. Sulfuric Acid Area ('C-6501
M 1. Nitrogen fittings used to hook to process line without proper block and bleed arrangement. Install nitrogen ties with proper block and bleeds.
Action Taken/To Be Taken:
Responsibility
sTeoe
Expected Completion Date
m /oj^b
Actual Completion Date
HR 2. Numerous safety showers without eyewash nozzle covers. Emphasize to all employees, Dow and Contract, that these nozzles need to be covered when not in use.
Action Taken/To Be Taken: Responsibility
bomt
Expected Completion Date
th
Actual Completion Date
M = Must-Do
DOW CONFIDENTIAL Page 38
HR = Highly Recommended
DO A 03?8?3 C.ONFTDFNTTAl
HR 1. Area chains do
side^ Reinstall chains.
Action Taken/To Be To,
Responsibility
Expected Completion Date
7/7
Actual Completion Date
bis
HR 2. HR 3.
A line at the top of first stairs is supported with #9 wire. Install correct support.
7/M5 D-610 deck needs houseke ' attention. .
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
D. General Area
M 1. Hoist in field not properly marked with rated capacity. Beams supporting hoists not marked with rated load capacity. Label both hoists and beams with rated capacity.
Action Taken/To Be Taken:
Responsibility
Adi'i
Expected Completion Date
7/ta
Actual Completion Date
M 2. Coupling guard on BL-500 doesn't completely cover rotating parts. Install guard to protect against rotating parts.
Action Taken/To Be Taken: Responsibility
fide**,
Expected Completion Date
Actual Completion Date
M = Mlj. Do
DOW CONFIDENTIAL Page 39
HR = Highly Recommended
DO A 00?8?4 CONFIDE NTTAt
HR 3.
No entry instructions on the east door of AH #10. The instructions posted on the west door to the analyzer house calls for two green lights to be on before entering. There are no lights. Install proper/correct entry instructions and install green lights or change instructions.
Action Taken/To Be Taken:
Responsibility
Debbit H\acX.
Expected Completion Date
Actual Completion Date
HR 4. AH #7 has no door handle and only one green entry light for 02 content. Install door handle and check to see if second green light for . entry is required.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
to!20
Actual Completion Date
HR 5. Chainfall and rope used to support a line in the pipe rack north of T-8. Install proper support.
Action Taken/To Be Taken:
Responsibility
Ato*
Expected Completion Date
7/2$
Actual Completion Date
M 6. The instrument shop is using Hansen fittings on plant air. OSHA requires that a dedicated fitting be used for breathing air. Hansen/ fittings are Dow's choice for breathing air in LAD.
Recommendation: Remove Hansen fittings in shop and make all employees aware of this requirement.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
8/Pi
Actual Completion Date
M 7. The compressed gas cylinder rack north of instrument shop has some unlabeled bottles. Label cylinders or properly discard.
Action Taken/To Be Taken: Responsibility
M S.
M = Musi-Do
Expected Completion Date
s-im
DOW CONFIDENTIAL
Page 40
Actual Completion Date
HR = Highly Recommended 00 A 0328
CONFTDFNTI
<\: <r
HR 8. The maintenance shop needs housekeeping attention.
Action Taken/To Be Taken: Responsibility
Expected Completion Date 7/7
Actual Completion Date
DISTILLATION, CONDENSING &
THERMAL CHORINATION AREA
M 1. Quick opening valves unplugged coming off of D-l 300, D1302, P1320A, dry vent east of P-1320A, D-100 and P-1555B. Plug all quick opening valves in hazardous service.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
7/7
Actual Completion Date
HR 2. The valves and piping coming off of dry vent are about hip high and could cause a problem to people trying to get to the intercom. Look at relocating the intercom.
Action Taken/To Be Taken:
Responsibility
ifiowit
Expected Completion Date
7/a S'
Actual Completion Date
HR 3. Install rack for fire hose north end of new train.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
7/2-$
HR 4. Install hose racks by nitrogen stations.
Actual Completion Date
Action Taken/To Be Taken:
Responsibility
3a 10
Expected Completion Date
/d/M>
Actual Completion Date
M 5. Unmounted fire extinguisher between T-155A and T-1830. Mount fire extinguisher
Action Taken/To Be Taken: Responsibility
Qowtt
M = Must-Do
Expected Completion Date 7M$
DOW CONFIDENTIAL
Page 41
Actual Completion Date
HR = Highly Recommended 00 A 03?8
OONFTOFNTT
<N <C
HR 6.
Safety Shower/Eye Wash station 2/PB-38402/CD1-450C next to T1555B is too close to the platform located behind the shower, potentially causing hazard to person in shower during a chemical exposure. Rotate shower ninety degrees to remove away from platform.
Action Taken/To Be Taken:
Responsibility
iOonm'i
Expected Completion Date
/of^O
Actual Completion Date
HR 7. Housekeeping Items
a. Bolts/hoses, etc. by P-1320's b. Channel locks by T-1555B and P-1750 c. Valve handle on platform by T-1555A d. Nuts, bolts, etc. on top of building next to R-1300 e. Trash on platform in between fans EC 1540 f. Sling and tarp on platform by fans EC-1510 g. Hoses lying on deck above El500 h. Roll of cable left on deck next to R-1300 I. Trash inside vessel skirts D1150, 1140, 1110, C1260 j. Unlabeled container by cooling tower pump 1020B
Action Taken/To Be Taken: Responsibility
Expected Completion Date
7/7
Actual Completion Date
HR 8. Landing platform for transition ladder on T-1830 seems too small. Consult Engineering to see if platform meets all OSHA and Engineering requirements.
Action Taken/To Be Taken:
Responsibility Q
Expected Completion Date
7l}
Actual Completion Date
HR 9. Entrance to ladder to the upper deck by V-l"XpB in partially blocked by piping from K-1750 to El 750. Rotate ladder ninety degrees to allow for unrestricted access.
Action Taken/To Be Taken:
Responsibility
Qcirty
Expected Completion Date
7
Actual Completion Date
M = Musi-Do
DOW CONFIDENTIAL Page 42
HR = Highly Recommended
M 10. No inspection date on fire extinguisher #98, only hydro test date marked. Have fire department inspect extinguisher and date.
Action Taken/To Be Taken:
Responsibility
Donnie
Expected Completion Date
712-8
Actual Completion Date
HR 11. Old decontamination tags still on valves by fin fan coolers #2978, 2979, 2981, 2984 and 2987. Remove old tags.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M 12. Labeling coming off of nitrogen station under fin fan. Relabel station.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
7/iS
Actual Completion Date
HR 13. Scaffold #15576 on south side of E-1430 has access ladder right next to handrail causing to little clearance for climbing. Move access ladder to east side.
Action Taken/To Be Taken:
Responsibility
tyonrit
Expected Completion Date
71
Actual Completion Date
M 14. Steam outlet on top deck by El302 with no label. Label all utility steamlines.
Action Taken/To Be Taken:
Responsibility
Omohp
Expected Completion Date
7/^8
Actual Completion Date
M 15. Scaffold bracing on walking platform above El 302 causing tripping hazard. Remove hazard or use warning device to alert people to the hazard.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
7/w
Actual Completion Date
M = Must-Do
DOW CONFIDENTIAL Page 43
HR = Highly Recommended
QO A 03?&> CONFTDFNTT
M 16. No ladder gate on the short ladder down to deck Ml lines to R-1300. Install ladder gate.
Action Taken/To Be Taken:
Responsibility
Ptdo
Expected Completion Date
fo lit*
Actual Completion Date
M 17. Grating clips not bolted down on third deck, R-1300, north side.^Secure clips.
Action Taken/To Be Taken:
Responsibility
' Ado*
Expected Conipletion Date
/o!%/>
Actual Completion Date
M 18. Utility station not labeled upper R1300 deck, north side. Label all utility stations.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date 7/pg-
Actual Completion Date
M 19. Cylinders by AH-15 sitting on ground instead on grating to prevent bottom corrosion. Install grating for cylinder to sit on.
Action Taken/To Be Taken:
Responsibility
Oebbi'e MqHs
Expected Completion Date
7/dS
Actual Completion Date
M 20. Fire extinguisher on AH #14 & 15 not labeled/numbered.
Action TakenITo Be Taken:
Responsibility
Expected Completion Date
7/2$
Actual Completion Date
HR 21. Actuator hanging by rope by T-1500. Install permanent support.
Action Taken/To Be Taken: Responsibility
41
Expected Completion Date
/old-0
Actual Completion Date
M = > Do
DOW CONFIDENTIAL Page 44
HR = Highly Recommended
DO A 03P839 CONFIDFNTTAl
M 22. Nitrogen station not labeled on the deck by fire extinguisher #109. Label as per S&LP standard 313.
Action Taken/To Be Taken:
Responsibility
OoM\ie
Expected Completion Date
7/zg
Actual Completion Date
HR 23. Safety shower and eye wash #31, south side of cooling tower, second deck has a tripping hazard to anyone using the shower. Recommend rotating the shower ninety degrees to remove tripping hazard.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
7M
Actual Completion Date
HR 24. The first step to the ladder to T-251 appears to be too high. Consult with Engineering to see if the distances are in compliance with OSHA and Engineering standards.
Action Taken/To Be Taken:
Responsibility
shoe.
Expected Completion Date
~r{a$
Actual Completion Date
M 25. The hand/off/auto switch to P-255B cannot be read. Relabel switch positions.
Action TakeitlTo Be Taken:
Responsibility
Expected Completion Date
8 hn
Actual Completion Date
M 26. Cylinder by AH #13 not on grating. Install grating under cylinder to prevent bottom corrosion.
Action Taken/To Be Taken:
Responsibility
AebW MftcVC
Expected Completion Date
7US
Actual Completion Date
M 27. Quick opening valve between PI 500 A & B, T-1500 to tank car not plugged. Plug all quick opening valves in hazardous service.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M = Must-Do
.
DOW CONFIDENTIAL Page 45
HR = Highly Recommended
DO A 037830
OONFTDFNTTAl
HR 28. The alarm button on safety shower/eye wash station #28 is labeled "pinch point". Recommend mounting alarm button a few inches higher to remove as a pinch point.
Action Taken/To Be Taken: Responsibility
Expected Completion Date
Actual Completion Date
M 29. Several quick opening, unplugged, valves on vent line next to P1450C. Plug valves
Action Taken/To Be Taken:
Responsibility
OotMi}
Expected Completion Date 7/^5
Actual Completion Date
M 30. Grating not completely secured around PI030 A&B deck, T-1500 deck, decking by V-1265. Recommend that all grating in plant be audited for proper securement since unsecured grating found in several locations.
Action Taken/To Be Taken:
Responsibility
PidaA
Expected Completion Date
ff/N
Actual Completion Date
M 31. The nitrogen stations in the block have no painted backboards as required by S&LP 313. Install painted backboards.
Action Taken/To Be Taken:
Responsibility
Expected Completion Date
Actual Completion Date
M = Musi-Do
DOW CONFIDENTIAL Page 46
HR = Highly Recommended
DO A 037801 CONFIDFNTTA!
SAFE WORK PERMIT AUDIT
DATE:
3/1/95
AUDITED BY: Brian Donatto, Roddey Peebles
PERMIT AUDITED: Pull fuses and disconnect electrically P-513B 3/1/95
Audit notes:
In Section I-#4, "NONE" was checked under special hazards to protect against. Although "NONE" was checked, there were four special hazards checked.
In Section I-#5, the special equipment to address the special hazards did not address all of the special hazards checked.
Section II, Line and Equipment Openings was filled out. This did not fit the permitted job.
Red tag master was not in the Permit Office.
PERMIT AUDITED: Dismantle scaffolding throughout the block 3/1/95
Audit notes:
In Section I-#5 of two different permits for dismantling scaffolding, the special equipment to address the special hazards did not address all of the special hazards checked.
One permit was written to dismantle scaffolding throughout the block. This is too general. Permits needs to be more specific and additional permits written if necessary to cover different areas of the plant.
M = Must-Do
DOW CONFIDENTIAL Page 47
HR = Highly Recommended
DO A 033B32 OONFTDFNTTAL
PERMIT AUDITED: Replace R-250 a tail line - 2/27/95
Audit-notes:
In Section I-#5 the special equipment to address the special hazards did not address all of the special hazards checked.
In Section II-#3 was checked "N.A". This should have been checked "No". This job required supplied air which was addressed in the special equipment and special instructions. To do this work without breathing air would have required cleaning and purging.
PERMIT AUDITED: Run piping from oil cooler to seal on P-470 A 2/27/95
Audit notes:
Section I-#5 did not list special equipment to protect against thermal bums and skin contact checked in Section I-#4.
PERMIT AUDITED: Insulate RE-1540 A and R-250 a tail line 2/27/95
Audit notes:
Two different jobs in two different areas of the plant put on one permit. Should have written two permits.
PERMITS AUDITED: Insulation jobs on R-250 B
Audit notes:
Worker list unacceptable. Workers should be listed on the permit or a crew roster should be used and attached to the permit. If a crew roster exists for red tagging on a job, then "See Roster" is acceptable.
PERMIT AUDITED: Pull P-201 B - 2/25/95 Audit notes:
M = Musi-Do
DOW CONFIDENTIAL Page 48
HR = Highly Recommended
DO A 032833 OONFIDFNTTAl
Section IV-Permit Close out not complete. Everything was checked off but permit worker closeout not signed.
M = Musi-Do
DOW CONFIDENTIAL Page 49
HR s- ^kly Recommended
Dn A 037834 conftdfnttal
PERMIT AUDITED: Install AOV to DR-101 - 3/1/95
Audit notes:
- Section I-#5 did not address all the special hazards checked in Section I#4.
Field audit conducted.
Fitter was aware of hazards associated with the job.
Permit had been reviewed with the fitter prior to beginning work.
Fitter complimented the permit writer highly on the issuing of the permit and the detail of the on-site inspection.
M = Must-Do
DOW CONFIDENTIAL Page 50
HR = Highly Recorc cd
D A 03P83S
confidfnttai.