Document 3pMxJzJ34xVzR391JOrkG320

]Ld)iiii5sasuMi ID3v2s 5 m (Caimsd&Miiittai AmKilfll Chemical Exposure Index March 1991 Dow Confidential DO A 12141? CONFIDFNTTAl Contents Purpose Preparation Instructions Agenda Personal Interview Questions CEIndex-Chemical Exposure Index and Radii of Exposure Program (Index) Pre-Audit Questionnaire 1 2 4 6 7 23 DO A CNF iDfTMT r a;^ Guide for a Chemical Exposure Index Audit DO A 121414 CONFIDENTIAL LOUISIANA DIVISION MARCH, 1991 Dow U.S.A. Tne Dov, Crerrica' Co~'Ga"v e 0 S'j/ : = -r L3,, : a-a ~Z~ti :' r TO: PLANT SUPERINTENDENT/DEPARTMENT HEAD RE: CHEMICAL EXPOSURE INDEX AUDIT The CEI Audit will be a part of the Louisiana Division Consolidated Audit Program. The audit will be the responsibility of the Superintendent/Department Head. The purpose of this audit is to provide an in-depth review of our Louisiana Division plant facilities that produce or handle quantities of materials which could, if released, possibly cause injury to persons outside our fence lines. The audit will be reviewing the section(s) of the plant that have a Chemical Exposure Index (CEI) of 100 or greater. You should start your preparations by reviewing the attached Chemical Exposure Index Guide and developing or updating the C.E.I.'s for your plant's various chemicals and potential loss of containment scenarios. You will need to complete and send a copy of the review package to the Audit Facilitator ten (10) calendar days prior to the audit. A CEI Functional Audit Team, Major Manager and a Superintendent from another department is required for areas with a CEI of 100-300. In addition, a U.S. Area Loss Prevention Representative will be required for a CEI of 300 or greater. Also, a Corporate Representative will be required for a CEI above 400. A CEI of 100 requires a review by the Superintendent and Major Manager only. NOTE: Prompt response to the CEI calculations is necessary. A 30 day pre-audit notification to the U.S. Area will be necessary for some areas. Contact Jim Gibson at Ext. 8103, for a U.S. Area Loss Prevention Representative required on C.E.I.'s of greater than 300. Jim should also be contacted for a Functional Audit Team if the CEI is 100 or greater. Attached is a guide including instructions on what is needed to prepare for the audit and how the audit will be conducted. If there are any questions concerning the audit, please contact me. Jim Gibson CEI Functional Team Leader Building 3305 Ext. 8163 Do A 1?14i5 confidential CHEMICAL EXPOSURE INDEX AUDIT PURPOSE To review potential release scenarios with a CEl greater than 100, or those that result in odor detection beyond the fence line. The goal is to prevent these potential releases from occurring. This goal can be accomplished by taking the following actions when possible. These actions are in priority order. 1. ELIMINATE THE POTENTIAL HAZARD WHERE POSSIBLE. 2. REDUCE THE POTENTIAL RELEASE. a Reduce the quantity of material. b. Reduce the duration of the release. c. Reduce the frequency of the release. 3. PROVIDE MITIGATION Reduce the impact of the potential release. 1 DO A 121416 CONFIDENTIAL CHEMICAL EXPOSURE INDEX AUDIT PREPARATION INSTRUCTIONS These Audit Instructions are being sent to Louisiana Division plants/departments as an audit to be accomplished in the Consolidated Audit Program. You should start your preparation early to assure a thorough review package. A copy of the audit package should be sent to the Functional Team Leader at least ten calendar days prior to the audit. A. AREAS OF OONCERN Only the area(s) of your operation which has a calculated Chemical Exposure Index(es) greater than 100 is covered by this audit, or those that show an odor detection radius beyond the fence line. (A CEI of less than 100 requires a review by the Superintendent and his Manager only!) B. REVIEW PACKAGE The following package requirements must be completed and sent to the Louisiana Division Auditing Facilitator at least 10 calendar days prior to the audit. 1. UST OF ALL CHEMICALS FOR WHICH CEI CALCULATIONS DONE This includes those with CEI's less than 100 or those with a potential odor detection beyond the fence line. 2. A CHEMISTRY SHEET This sheet should include all desired reactions as well as all undesired reactions. 3. A SIMPLIFIED PROCESS FLOWSHEET This flowsheet should include the vessels and quantity of chemicals with CEI's 100 or greater or those with an odor problem. 4. A BRIEF DESCRIPTION OF THE "WORST CREDIBLE SCENARIO FOR EACH SCENARIO WITH A CEI GREATER THAN 100. 5. A COPY OF THE SUMMARY SHEETS AS PER ATTACHED CENDEX PROGRAM FOR CEI AND DISPERSION POR EACH SCENARIO WTTH A CEI GREATER THAN 100 OR THOSE WITH AN ODOR PROBLEM. D0 A 121417 r-nWFTDFNTTAL 6. A PLOT PLAN AND AREA MAP WITH: a Three circles based on EEPG numbers These circles represent the distance (radii of exposure) that 1, 10 and 100 times the EEPG concentrations are predicted to travel for NEUTRAL atmospheric conditions. b. A circle based on the Odor Threshold If the Odor Threshold is less than the EEPG concentration, include a circle for the distance that concentration is predicted to travel for NEUTRAL atmospheric conditions. c. Location of gas monitors, spill detectors, etc. Clearly show the location and type of any device used to detect a release. 7. THE CEI PRE-AUDIT QUESTIONNAIRE (Attached, nine pages) 8. ONE COPY OF THE MASS & ENERGY BALANCE K3R YOUR PLANT. One mass and energy balance flowsheet set should be sent to the Process Engineering representative only. U.S. Area and Corporate Representatives The Functional Team Leader will invite appropriate Dow U.S. Area or Corporate Safety and Loss Prevention representatives for for reviews with CEI's of greater than 300 or greater than 400 respectively. Notification for outside auditors must be done thirty days in advance of the audit. 3 D0 A 121418 confidential Chemical Exposure Index Audit Agenda i. OVERVIEW PRESENTATION TO THE AUDIT TEAM ('Allow 30 Minutes) 1. What is the status of the recommendations made in the previous review? a Have there been any major changes or additions to the plant since the last review? b. Are there any other specific concerns which should be addressed but were not identified in the CEI review? 2. Summarize the results of the CEI calculations, include results of the odor threshold dispersion modeling. 3. Review the "worst credible" case loss of containment release scenarios including plot plans showing dispersion model results. 4. Discuss any CEI related incidents that have occurred. 5. Discuss your lines of defense that would prevent your "worst credible" release scenario from occurring. 6. Discuss the mitigation procedures for each scenario. 7. Discuss your plant's CEI related concerns generated from the audit preparation. 8. Discuss your plans for improving your operations from a CEI standpoint. II. PRE-AUDIT QUESTIONNAIRE (* Allow 30 minutes) A Review the information provided in the questionnaire on an exception basis. III. DOCUMENTATION AUDIT (" Allow one hour) Following the plant's presentation, two members of the audit team will examine the plant's program documentation. The plants documentation should include: Emergency Plan P&ID's/Material Balance Flowsheet Operation Discipline In-Plant Training Program Maintenance Checklist Operating Procedure Area Monitoring System Records Piping Specifications Completeness and quality will be used as a criteria for evaluating the documentation. 4 CONFIDENTTAL IV. HYPOTHETICAL EXERCISE (* Allow one hour) Two members of the audit team will simultaneously conduct an exercise designed to evaluate the response to an emergency situation involving a major release of chemical X. The production shift on duty the day of the audit will be given a written description of an emergency involving a major release of chemical X. The Superintendent and Safety Superintendent has previously developed an exercise based on an actual potential concern. The shift personnel will be given five minutes to develop a response to the situation (i.e., who would be notified, what actions would be taken in the field, etc.). Written materials may be utilized by the shift, i.e., operating discipline, checklists, etc. The production shift will then be asked to verbally describe their response to the audit team members. V. INTERVIEW (* Allow one hour) A member of the audit team will interview an operator in the plant. See the attached questions. VI. wrap UP (* Allow 30 minutes) The CEI Functional Team Leader will prepare a written report to be sent to the Audit Facilitator to be included in the Consolidated Audit report to the plant. If there are any questions on the audit procedures, please call Jim Gibson at Ext. 8163. * Note: The documentation audit, hypothetical exercise, and interview will take place currently. 5 Do A CONFrOF/vriAL. CHEMICAL EXPOSURE INDEX AUDIT PERSONNEL INTERVIEW Introduce yourself and explain purpose of the audit to the interviewee. Emphasize to the interviewee that his/her information may be used in the feedback session at the end of the EOPC/CEl audit. However, names will be held in confidence. NOTE All questions are not applicable to ail interviewees. These are only guidelines. 1. How long have you been a Dow employee and in which plants and areas have you worked? 2. Explain your current job function. 3. Is this plant a good place to work in relation to chemical exposures and their effect on the public in general, beyond the Dow fence line? 4. Do you feel that supervision is receptive to suggestions regarding emergency response practice? Do you feel that supervision takes issues related to the CAER program, emergency planning, etc., seriously? Can you give an example? 5. What type of emergency response training have you received? Do you understand the hazards and the appropriate emergency responses? Does the training program include procedures to respond to spills or releases in the environment that may affect the public at large? 6. Are you familiar with the Chemical Exposure Indices (CEI) of your plant's products and raw materials? 7. What procedure do you follow for emergencies such as gas releases, spills, fires, etc.? 8. When was the last time you were personally involved in a planned emergency drill in your plant for the release of gas or liquid of concern? 9. How are emergency response policies communicated? 10. What type of training have you received in the proper use of personnel protective equipment employed for combating spills, gas releases, and fires? 11. Do you feel that Dow overall is doing all that is necessary to prevent you. your neighboring plants, and the public from being exposed to chemicals that are handled in your plant? 6 DO A 12142 CONFTDFNTIA1 CEINDEX - CHEMICAL EXPOSURE INDEX AND RADII OF EXPOSURE PROGRAM 1.0 INTRODUCTION CEINDEX is a program to determine the Chemical Exposure Index and Radii of Exposure for possible chemical release incident. The output from this program is suitable documentation for CEl Audits. The Chemical Exposure Index and Radii of Exposure are for internal Dow use only. The purpose of these calculations is to focus attention on the potential chemical release incidents of greatest concern. The review will provide the opportunity for recommendations, improvements and concurrences from the appropriate knowledgeable people. CONTACTS EEPG Odor Threshold Numbers - Gary Meier CEINDEX Program - Jim Gibson MIDAS Program - Delaine Rawlings LOCATION 3502E 3305 2301 PHONE 1809 8163 8781 CHEMICAL EXPOSURE INDEX The CEl formula takes into account the five most important factors which influence the magnitude of exposure from any potential release: toxicity, quantity, distance to area of concern, molecular weight and process variables (i.e., temperature, pressure, reactivity). For each potential release, the CEl is calculated for three areas of concern: 1) Public, 2) Other Dow facilities and 3) Other businesses. The CEl to the public is the basis for establishing both the frequency and depth of process review. The Chemical Exposure Index is intended to be used as a simple tool for ranking potential toxic hazards in a comparable and quantitative manner. RADII OF EXPOSURE Simple atmospheric dispersion models are used to estimate the potential impact on the surrounding areas. The Radius of Exposure defines the maximum downwind distance which may be affected by the toxic release. There are two different values to be considered for each release. These are 1) the EEPG concentration (Emergency Exposure Planning Guidelines) and 2) the Odor Threshold. The Radii of Exposure are calculated for either of these values for three atmospheric conditions typical to the area. When EEPG concentrations are used, the program calculates the Radii of Exposure for concentrations equal to 1, 10 and 100 times the EEPG concentration. The program only calculates the Radii to the Odor Threshold when that value is used. 7 DO A 121422 CONFIDENTIAL The Radii of Exposure for the neutral atmospheric conditions should be used to plot the 3 EEPG concentration circles required for the CEI Audit. If the Radius of Exposure to the Odor Threshold or the EEPG concentration (IX) at neutral atmospheric conditions is greater than the distance to the public, then the scenario should be included in the CAER program (Midas System). The other radii of exposure can be used as a guide for estimating downwind impact of a particular release. 2.0 GENERAL INFORMATION The CEINDEX program is user-friendly. The program can be run interactively, where the user is prompted for the required information or the program can be run from an input file. The user must specify keyboard entry or file entry at the beginning of the program. The program input and results are stored In the following files. Input: F11ename.dat Output: Filename.lls The program Is set up to read and write either metric or britlsh units. The user must specify the units desired at the beginning of the program. The default units for each piece of Input data required is indicated at the end of each question, enclosed In parenthesis. The CEINOEX program can be accessed from any VAX within the Texas Division Cluster system. To run the program, type in the following line at the $ prompt. G1395SROOT:[DISPICE INDEX 8 DO A 1?14?3 CONFTDFNTTAL 3.0 INPUT REQUIREMENTS UNITS Plant name Plant location Chemical name Total quantity stored in plant Largest single containment Storage temperature Storage Pressure Boiling point temperature Flash point temperature Molecular weight Concentration type (EEPG or Odor Threshold) EEPG concentration Type of release (gas release or liquid spill) Discharge quantity (Total amount discharged In 15 min.) Release duration Source elevation Source diameter Release exit velocity (use if jet flow is to be considered) Spill area (if a liquid spill Is considered) Acute health hazard factor Distance to public Distance to other Dow plants Distance to other businesses Process penalties kg / lb kg / lb deg C / deg F psia / atm deg C / deg F deg C / deg F g/m**3 / ppm 9 / lb min m / ft m / ft m/s / ft/s m**Z / ft**2 NOTES: 1) The discharge quantity Is the amount that Is released in 15 minutes regardless of the duration of the release. For example, if 1000 lbs. are released In 1 minute then the discharge quantity is 1000 lbs. If 4000 lbs. are released In one hour at a constant rate then the discharge quantity for 15 minutes Is also 1000 lbs. Z) Release Duration - The program uses this time and the discharge quantity to determine a release rate. If the release lasts less than 15 minutes. Input the actual minutes used to determine discharge quantity. If the release can last longer than 15 minutes, use the default value of 15 minutes NOT the actual release duration. 9 4.0 RESULTS A summary of the Chemical Exposure Index calculation and the Radii of Exposure calculations will appear on the user's screen. The complete program results In a suitable documentation form will be stored in the output file specified (filename.1 is). The file will contain the input data, a summary of the Chemical Exposure Index and a table of the Radii of Exposure for vapor concentrations 1, 10 and 100 times the EEPG concentration or for the Odor Threshold for the chemical released. The Radii of Exposure has been calculated for three different atmospheric conditions which typically occur in Texas Division. PLEASE NOTE: The program has a maximum cutoff distance of 5 miles. If the predicted downwind distance exceeds 5 miles, the program will print out that the radii of exposure exceeds 5 miles and will include a message stating that: "The calculated distance exceeds the limits of dispersion model coefficients. Contact Process Engineering, if the actual predicted distances are needed." Remember: This is a simple, empirical rating system to be used for Internal Dow use only. 5.0 EMERGENCY EXPOSURE PLANNING GUIDELINES (EEPG) The Emergency Exposure Planning Guideline Is the maximum airborne concentration of a material which can be tolerated by an Individual for an hour, without incurring permanent health effects or symptoms which would Interfere with their ability to take appropriate action. Current known EEPG concentrations are Included In this manual in Section 1S.0 and are also supplied with the CEI audit information. Documentation will be maintained by the H&ES Information Center. .0 ODOR THRESHOLD The Odor Threshold Is a value based on detection by odor. This value is Important because It Is the lowest concentration that can be smelled Indicating a chemical release has occurred. Current known Odor Thresholds are Included In this manual In Section 15.0 and are also supplied with the CEI audit Information. Documentation will be maintained by the H&ES Information Center. 7.0 CHEMICAL EXPOSURE INOEX The Chemical Exposure Index Is the value obtained by multiplying the five risk factors described below. The factors are categorized Into directly proportional scale numbers to maintain quick and simple calculations. Absolute measures of risk are not possible, but the CEI provides a means for ranking one potential hazard relative to another. The Chemical Exposure Index to the public determines the frequency and depth of review. Please note, for the CEI calculations, the non-linear or logarithmic functions normally associated with distance and the rate of dispersion are Ignored. Absolute numbers are not the objective of the CEI. 10 00 A 121425 CONFIDENTIAL 8.0 ACUTE HEALTH HAZARD FACTOR The Acute Health Hazard Factor combines the toxicity and the volatility properties of a substance. To assure consistency, the Industrial Hygiene department will issue toxicity data as Emergency Exposure Planning Guidelines (EEPG) in parts per million. The Health Hazard Factor may be determined by dividing the EEPG by the relative volatility. Relative volatility equals vapor pressure (mm Hg <? 25 deg C) divided by 760 mm Hg. For gases, the relative volatility is equal to 1. 9.0 PROCESS PENALTY FACTOR The process penalty factor Is based on pr.-ess conditions which could generate large amounts of vapor In relatively short periods of time. The two largest driving forces are 1) pressure or overpressure (ie, liquids well above their boiling points or high pressure gasses) and 2) run-away reactions. Therefore, if either condition exists, a penalty Is applied. If the pressure on the system is over 10 psig (1.75 atm absolute), use 2 for this factor. If the material is, or can become, thermally unstable below 100 deg C, or Is reactive with common materials like air, water, or other possible contaminants, use 2 for this factor. If both factors apply, use 4. If neither apply use 1. 10.0 VAPOR QUANTITY FACTOR The vapor quantity factor Is based on the maximum weight of material which could be released as a gas, or could be vaporized during 15 minutes of the worst case situation. Please be sure to select the absolute worst form of pressure, temperature, mechanical or human failure, run-away reaction or contamination that Is possible. Do not however, arbitrarily assume 100% of the contaminant will be released and vaporized In 15 minutes. Two factors to be considered when determining the vapor quantity factor are: 1) A credible scenario for a release and 2) The rate at which toxic material would be release In such a scenario. The scenario chosen should be a realistic worst case and not the absolute worst case that could conceivably happen. Some "quick and easy" equations for determining the maximum discharge rate through a nozzle have been Included In section 14.0. The vaporization rate of a liquid spill can be determined using the program EVAP, which is available on the cluster system. To obtain an Instruction manual, type In the following command at the $ prompt: 01395SROOT:[DISPJEVAP_HELP.TXT Other methods are Included In the "Chemical Exposure Index" manual. li A 121426 CONFIDE; NT TAL 11.0 DISTANCE FACTOR The distance factor is based on the distance between the point of release and 1) the public 2) other Dow plants 3) other businesses. The public is officially defined as residences, collecting points of people (1e, schools, hotels, churches, shopping malls) or frequently used public roads. 12.0 MOLECULAR WEIGHT FACTOR The molecular weight factor Is based on the molecular weight of the chemical released. The molecular weight relates directly to the density of the vapor cloud which Is inversely proportional to the rate of dispersion. 13.0 METEROLOGICAL CONDITIONS The meterologlcal conditions at the time of a toxic release will affect the transport and diffusion of the vapor cloud Into the atmosphere. Atmospheric turbulence Is the most common means for quantifying the meterologlcal conditions so that the affected area can be determined. Atmospheric turbulence can be divided Into two groups, mechanical turbulence and convective turbulence. Mechanical turbulence 1$ generated by fluctuations In wind direction and the motion of the air In response to surface roughness (1e, buildings, trees, etc.). A high wind speed with very little fluctuation In wind direction will tend to carry the release to a greater distance downwind and disperse It over a narrow crosswind distance. Fluctuations In wind direction tend to spread the release over a larger crosswind distance, thereby decreasing the concentration downwind. Likewise, surface roughness tends to spread the release over a larger volume of air, thereby decreasing the concentration downwind. Convective turbulence Is caused by thermal effects ie, surface heating and cooling. There are three main categories of atmospheric stability; unstable, neutral and stable. An atmosphere that 1$ well mixed due to moderate to strong winds or one that Is overcast, Is considered to be 'neutral'. The thermal effects are negligible and the temperature decreases slightly with increasing height. When solar radiation causes the air near the surface of the earth to heat up and rise the atmosphere Is considered to be 'unstable'. This condition Is particularly common during periods of low wind speeds. As night falls, the cooling air near the surface of the earth tends to shrink and settle, again, especially at the lower wind speeds. There Is very little turbulence In this case and this atmospheric condition is considered to be 'stable'. Texas Operations Is In a 'neutral' condltlon-approximately 49% of the time, in a stable condition approximately 29% of the time and In an unstable condition approximately 22% of the time. 12 00 Co NF ^ 1?1427 TFNTT At. 14.0 MAXIMUM DISCHARGE RATE A. LIQUID CALCULATIONS ASSUMPTIONS: VESSEL IS LIQUID FULL WITH THE BROKEN NOZZLE CLOSE TO THE BOTTOM PRESSURE REMAINS CONSTANT UNTIL TANK IS EMPTY. NO FLASHING OCCURS UNTIL LIQUID IS OUTSIDE THE VESSEL. MAXIMUM FLOW IS DETERMINED AND ASSUMED TO BE CONSTANT. Umax - 0.7*(2*g*dH)**.5 Fmax - Umax*A*D where, A * Cross-sectional area of hole, ft**2 dH - Differential pressure In feet of head (vessel pressure - atmospheric pressure) D Density, lb/ft**3 Fmax - Maximum flowrate through the hole {lb/s) g Gravitational constant, ft/$**2 Umax - Maximum velocity, ft/s NOTE: To determine the vaporization rate of liquid spills See section 10.0 S. GAS CALCULATIONS ASSUMPTIONS: PRESSURE REMAINS CONSTANT UNTIL VESSEL/PIPELINE IS EMPTY. MAXIMUM FLOW IS DETERMINED AND ASSUMED TO BE CONSTANT. Fmax - A*(144*g*k*P1*0i*(2/(k+l))**(k+l/k-l))**.5 Umax - 0.7*(2*g*dH)**.5 where, A - Cross-sectional area of hole, ft**2 dH - Differential pressure In feet of head (Initial pressure - atmospheric pressure) ## D1 - Initial density, lb/ft**3 Fmax - Maximum flowrate through the hole (lb/s) g - Gravitational constant, ft/s**2 k - Constant, ratio of the specific heats (Cp/Cv) (can assume 1.35 for most gasses) PI - Initial pressure, lb/1n**2 Umax - Maximum velocity, ft/s ## NOTE: If compressible fluid, and 0.5*(H upstream) > (H downstream) then dH 0.5*(H upstream) 13 D0 A 1?142$ CONFIDENTIAL EEPG AND ODOR THRESHOLD VALUES FOR THE CE1 CALCULATION EEPG VALUES The following Emergency Exposure Planning Guidelines (EEPG) are based on the official EEPG values issued by the Corporate Occupational Health Board and the additional tentative EEPG values used in the Texas Operations' MIDAS system. These values are used for the Chemical Exposure Index (CEI) calculation. The CEI calculation can be performed with the CEINDEX computer program (described in another handout). This EEPG list is believed to include the majority of the chemicals for which CEI calculations will be necessary. However, there are many materials which do not appear on the list. For chemicals without an EEPG. jjs the factor of 3 times the Dow Industrial.Hygiene Guide (IHG) as the -"EEPG". for the CEI calculation. IHGs consist of non-Dow sources of exposure limits such as the TLVs, PELs and WEELs as well as the Dow sources. The IHGs are listed on the Chemical and Physical Agent Inventory which is located In the plant Industrial Hygiene Manual. If an IHG is not available, contact the plant Industrial Hygienist or Tracy Parsons (x3784). The plant will need to provide a Material Safety Data Sheet when making a request for an IHG or EEPG. Judgement should be used when deciding to do the CEI calculation; not all materials require a CEI calculation. For example, solids or materials with a very low vapor pressure and low toxicity concern do not need to be included In the plant CEI calculation. ODOR THRESHOLD VALUES The Odor Threshold for each of the chemicals Is also provided on the attached 11st. This value Is based on detection by odor or irritation whichever Is lower. Like the EEPGs, the Odor Threshold values are primarily useful as planning tool. When the Odor Threshold values are used In place of the EEPG values In the CEINDEX computer program, they indicate the distance at which a plant release might be detected, especially by the public. This calculation Is especially useful if the Odor Threshold is significantly lower than the EEPG value. TWP/RLD/10-18-89 14 DO A 121429 CONFIDENTIAL ! I? HE DOW CHEMICAL COMPANY November 29, 1990 EMERGENCY PLANNING GUIDELINES: EEPGs AND ERPGS Attached is a complete updated list ot EEPGs and ERPGs. There have been manv requests tor these values tor use in the Chemical Exposure index 1CEI) calculations being done globally tor ail chemicals at each Dow piant. Since there are relatively tew ot these formally established values, we have been recommending the following approach. 1. Use an established EEPG/ERPG when available. 2. Use the CEI Health Hazard Scale Number shown on the enclosed list, when available. Use the workplace exposure guideline (Dow IHG, ACGIH TLY or AIHA WEED as the basis tor a tentative emergency planning guideline. If the chemical has a STEL or Ceiling value, use that. If it does not, use three times the TWA value. 4. It no workplace guideline exists, reconsider the need for an EEPG vaiue or CEI calculation. Is there sufficient vapor pressure and volume ror the chemical to be of concern as a potential accidental release to a neighboring community? 5. If none of the above options provides the needed information, contact me. I will try to suggest an appropriate Health Hazard Scaie Number tor the CEI calculation but will need to know the vapor pressure or the chemical. Please distribute this information, as needed, within your area ot responsibility. It is important that the various Dow iocanons use consistent emergency guideline values for the same chemicals. If you have questions about this recommended approach, let me know. \ Marlene G. Swank Health & Environmental Sdenees 517/636*3976 Attachment 15 DO A 121430 CONFTDENTTAl EMERGENCY PLANNING GUIDELINES: ERPCs AND FEPC^ Chemical ERPC-: Acetone cyanohydrin Acrolein Acrylic add Acrylonitrile Allvl chloride** Ammonia Bromine Butadiene n-Butyiisocvanate Carbon disulfide Carbon tetrachloride Chloracetyl chloride Chlorine Chloroform Chloropicrin Ihlorosulfonic add Crotonaldehyde Diketene Dimethviamine Epichlorohvdrin Ethyl chloride Ethylene dichloride Ethylene oxide Formaldehyde Hexachlorobutadiene Hydrogen bromide Hydrogen chloride Hydrogen cyanide** Hvdrogen fluoride Hydrogen sulfide liobutyronitrile Methacrvlonitrile Methyl iodide Methyl mercaptan Monomethylamine Perfluoroisobutyiene Phenol Phosgene Phosph ms pentoxide Propylene ride 0.1 ppm 2 ppm -- 300 ppm 25 ppm 0.3 ppm 10 ppm -- 1 ppm -- 0.1 ppm 1 ppm -- NAt 1 mg/mJ 2 ppm 1 ppm 1 ppm 2 ppm 1 ppm 3 ppm 3 ppm NA 5 ppm 0.1 ppm 10 ppm 25 ppm 0.005 ppm 10 ppm NA 10 ppm NA 5 mg/m^ 16 ERPC-2/EEPC 10 ppm* 0.5 ppm 50 ppm 20 ppm* 40 ppm 200 ppm 1 ppm 50 ppm 0.2 ppm* 50 ppm 100 ppm* 1 ppm 3 ppm 100 ppm* 0.2 ppm o 10 5 100 50a 5BJEG-? 3 ppm T50 ppm 3 ppm 1000 ppm -i ppm 5000 ppm 1000 ppm 20 ppm 20 ppm 3 ppm 100 mg/mJ 50 ppm 50 ppm 500 ppm 100 ppm ppm 30 ppm 100 ppm 25 ppm , 50 ppm 100 ppm 500 ppm 125 ppm 100 ppm 500 ppm 0.3 ppm 200 ppm 1 ppm 100 mg/m^ Do A lpI43i CONFTDFNTJA! SOME CHEMICAL EXPOSURE INDEX (CEI) HEALTH HAZARD SCALE NUMBERS FOR CHEMICALS WITH NO EEPG/ERPG Chemical Acetic add Acrvlamide AUvl chloride Benzene Biphenyl Butene Butviene oxide Chloroaifluoroethane (Isotron 142B) Chloromethvl methvl ether Chloroorene Cvclohexane Cvclohexanol Cvdohexanone DEPCT Diaminopropane Dichlorobutene Dimethvl ether Dimethvl sulfoxide Dinoseb 1,4-Dioxane Diphenvl oxide DOWCO* 429 Ethvl acrylate Ethyl chloroacetate Ethylbenzene Ethvienediamine Gasoline Hvdroxvethyl aoviate Isocvanatoethvl methacrylate Isopropyol chiorofonnate Isopropylamine Methanol Methyl chloride Methvl chloroacetate Methvl chloroform Methyl methacrylate Methylene chloride - Perchloroethylene Health Hazard Scale Number* I 1 3 2 1 1 2 1 4 1 1 1 1 1 2 2 0 1 1 1 1 2 1 1 1 1 1 3 3 1 3 1 1 1 1 17 DO A 121432 CONFIDENTIAL =EMERGENCY RESPONSE PLANNING GUIDELINES American INDUSTRIAL HYGIENE ASSOC lATICf "he Emergency Response Planning Guideline (E.RPG) values are intended to crovioe estimates cf concentration ranges wnere one mtgnt reasonaoiv anticioate ooserving adverse effects as desertoea in me oefimtions tor E=PG-i. ERPG-2. and ERPG-3 as a conseauence of exoosure to tne soecific suostance. 7he^flfi is tne maximum airoorne concentration oeiow wmen it is oeiievea tnat nearly an individuals couid Oe exoosea for uo to i nr witnout experiencing otner tnan rmio transient adverse neann effects or perceiving a cteariy defined oDjectionaoie ooor. "he ERPG-2 is tne maximum airoorne concentration oeiow wmcfl it is Oetieveo tnat neany ail individ uals couio ee exoosea for uo to t nr witnout exoeriencing or aeveioomg irreversiote or otner serious neaitn erfects or symotoms tnat could tmoair tneir aoilities to taxe oroteettve action. "he ERPG-3 s tne maximum airoorne concentration oeiow wmen it is oeneveo tnat neariv an noiviouais ccuio oe exposed for uo to t nr witnout experiencing or aeveioomg life-threatening neaitn effects. The committee recognizes (and ail wno maxe use of these values should rememoeri tnat numar. responses ao not occur at precise exposure levels but can extena over a wide range of concentrations. The values oenveo for ERPGs snouid not oe expected to protect everyone Out should be apoiicaoie to most individuals in tne general population, in all populations tnere are hypersensitive moividuais wno wm snow adverse resoonses at exposure concentrations tar oeiow levels wnere most individuals wouic normally resoonc. Furthermore, since tnese values nave oeen oenveo as planning and emergency resoor.se guidelines, not as exposure guidelines, they do not contain tne safety factors normally incorp rated mto ?xoosure guidelines, instead, they are estimates, oy tne committee, of the tnresnoios aoove wmen mere would oe an unacceptaoie lixeiihooo of ooserving tne defineo effects. The estimates are eased on me avaiiaoie cata summarized in me documentation, in some cases wnere the oata are limited, tne uncertainty of tnese estimates is large. Users of the ERPG values are strongiy encouraged to review carefully me documentation oefore applying tnese values. in developing tnese ERPGs. human expenence has been empnasizetrto tne extent data are avaname. Since tms type of information is rarely available, however, and. wnen available, usually is only for i w ievei exposures, animal exposure data most freouentiy form the oasis for tnese values. The most pertinent i nformation is derived from acute inhalation toxicity studies tnat nave included clinical observations anc nistooatnotogy. The focus is on tne highest levels not snowing the effects described by tne definitions or tne EnPG ieveis. Next, data from reoeat tnnaiation exposure stuoies with clinical observations anc nistooatnoi gy are considered. Following tnese m imoortance are tne basic, typically acute, studies wnere mortality is tne maior focus. When inhalation toxicity oata are either unavailable or limited, data from studies involving otner routes of exposure will be considered. More value is given to tne more ngorousiv conducted studies, and data from snort-term studies are considered to be more useful in estimating pos sible effects from a single 1-hr exposure. Finally, if mechanistic or aose-resoonse data are available, reare aootieo. on a case by case basis, as appropriate. it is recognized that there is a range of times that one might consider for tnese guidelines: however it was tne committee's decisi n to focus its efforts on only one time period. This dectsi n was oaseo on me availability of toxicology information and a reasonable estimate for an exposure scenario. Users wno may choose to extrao (ate these values t othertimeoen os are cautioned t review the documentation fuiiv since suen extrapolations tend to n to only over very limited time frames, if at all. *0 A 121 CONFIDENT 16.0 SAMPLE CASE A. EXAMPLE INPUT FILE FOR AN EEPG CONCENTRATION RUN YOUR PLANT !PLANT NAME YOUR BLOCK 'PLANT LOCATION CHLORINE !CHEMICAL NAME 6000.000000 [TOTAL QUANTITY STORED IN PLANT 2000.000000 '.LARGEST SINGLE CONTAINMENT 86.000000 '.STORAGE TEMPERATURE 129.000000 [STORAGE PRESSURE -29.290001 '.BOILING POINT TEMPERATURE 0.000000 [FLASH POINT TEMPERATURE 71.000000 [CONTAMINANT MOLECULAR WEIGHT 3.000000 !EEPG CONCENTRATION E [E-EEPG, O-OOOR THRESHOLD L [G-GAS RELEASE. L-LIQUID SPILL 840.000000 [TOTAL DISCHARGE QUANTITY 15.000000 [RELEASE DURATION 0.000000 [SOURCE HEIGHT 200.000000 [SPILL AREA 5 [ACUTE HEALTH HAZARD FACTOR 3 [DISTANCE FACTOR - TO THE PUBLIC 4 [DISTANCE FACTOR - TO DOW PLANTS 3 [DISTANCE FACTOR - TO OTHER BUSINESSES 2 [PROCESS PENALTY B. EXAMPLE INPUT FILE FOR AN ODOR THRESHOLO RUN YOUR PLANT [PLANT NAME YOUR BLOCK [PLANT LOCATION CHLORINE [CHEMICAL NAME 6000.000000 [TOTAL QUANTITY STORED IN PLANT 2000.000000 [LARGEST SINGLE CONTAINMENT 86.000000 [STORAGE TEMPERATURE 129.000000 STORAGE PRESSURE -29.290001 [BOILING POINT TEMPERATURE 0.000000 [FLASH POINT TEMPERATURE 71.000000 [CONTAMINANT MOLECULAR WEIGHT 1.000000 IOOOR THRESHOLD 0 [E-EEPG, D-ODOR THRESHOLO L [G-GAS RELEASE, L-LIQUID SPILL 840.000000 1 TOTAL DISCHARGE QUANTITY 15.000000 [RELEASE DURATION 0.000000 [SOURCE HEIGHT 200.000000 SPILL AREA 5 [ACUTE HEALTH HAZARD FACTOR 3 [DISTANCE FACTOR - TO THE PUBLIC 4 [DISTANCE FACTOR - TO DOW PLANTS 3 [DISTANCE FACTOR TO OTHER BUSINESSES 2 [PROCESS PENALTY 19 DO A 121434 CONFIDENTIAL C. EXAMPLE OUTPUT FILE ****** oow CONFIDENTIAL FOR AN ****** EEPG CONCENTRATION RUN DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** CHEMICAL EXPOSURE INDEX DATE: 16-NOV 89 RELEASE SCENARIO: A RELEASE FROM A CHLORINE CYLINDER PLANT: YOUR PLANT LOCATION: YOUR BLOCK CHEMICAL: CHLORINE TOTAL QUANTITY IN PLANT: 6000.00 lb LARGEST SINGLE CONTAINMENT: 2000.00 lb STORAGE TEMPERATURE: 86.00 deg F STORAGE PRESSURE: 129.00 psla BOILING POINT: -29.29 deg F FLASH POINT: 0.00 deg F MOLECULAR WEIGHT: 71.00 EEPG CONCENTRATION: 3.0 ppm CHEMICAL EXPOSURE INDEX SUMMARY ACUTE HEALTH HAZARD FACTOR: 5 (0.0 - 0.99) VAPOR QUANTITY FACTOR: 2 (100 lbs - 999 lbs) MOLECULAR WEIGHT FACTOR: 4 ( >.45) PROCESS PENALTIES: 2 (overpressure or run-away reaction potential) DISTANCE TO THE PUBLIC TO DOW PLANTS TO OTHER BUSINESSES DISTANCE FACTOR 3 (1000 ft - 5279 ft) 4 ( < 1000 ft) 3 (1000 ft - 5279 ft) CEI ' 240 320 240 CHEMICAL EXPOSURE INDEX TO THE PUBLIC - 240 BIANNUAL REVIEW - SITE, SUPERINTENDENT AND MAJOR MANAGER STHE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD $FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ****** OOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** 20 DO A 3 Pi 435 CONF IDENTIC ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DISPERSION SUMMARY FOR EEPG CONCENTRATIONS RELEASE SCENARIO: A RELEASE FROM A CHLORINE CYLINDER DATE: 16-NOV-89 CHEMICAL - CHLORINE TOTAL DISCHARGED - 840.00 LBS RELEASE DURATION - 15.00 MIN MOLECULAR WEIGHT - 71.00 EEPG CONCENTRATION - 3.0 ppm PLANT - YOUR PLANT SOURCE HEIGHT - 0.00 FT SPILL AREA - 200.00 SQ. FT SOURCE TEMPERATURE - *29.29 DEG F AMBIENT TEMPERATURE - 86.00 DEG F THE RELEASE IS A LIQUID SPILL THE RELEASE IS CONTINUOUS THE RADII OF EXPOSURE ARE BASED ON PEAK CONCENTRATIONS RADII OF EXPOSURE (feet) 9 ground level * 9 plume centerline EEPG (ppm) UNSTABLE 12. mph NEUTRAL** 12. mph STABLE 6. mph 3.0 2194. 4300. 10180. 30.0 684. 1134. 2503. 300.0 251. 343. 685. ** THE NEUTRAL CONOITION IS TO BE PLOTTED FOR ALL AUDITS/REVIEWS UNSTABLE ATMOSPHERIC CONDITION - SLIGHT SOLAR RADIATION WITH LOW WIND SPEEDS (<10 mph) OR STRONG RADIATION WITH HIGH WIND SPEEDS (>10 mph). NEUTRAL ATMOSPHERIC CONDITION - WELL MIXED ATMOSPHERE DUE TO MODERATE/STRONG WIND SPEEDS (>10 mph) AND SLIGHT/MODERATE SOLAR RADIATION. ANY OVERCAST CONDITION. STABLE ATMOSPHERIC CONDITION - LOW WIND SPEEDS (<10 mph) AT NIGHT. THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOEL INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** 21 DO A 101436 CON/f rDFNTjAi D. EXAMPLE OUTPUT FILE FOR AN ODOR THRESHOLD RUN ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DISPERSION SUMMARY FOR OOOR THRESHOLD RELEASE SCENARIO: A RELEASE FROM A CHLORINE CYLINDER DATE: 16-NOV-89 CHEMICAL - CHLORINE PLANT - YOUR PLANT TOTAL DISCHARGED - 840.00 LBS RELEASE DURATION - 15.00 MIN MOLECULAR WEIGHT - 71.00 ODOR THRESHOLD - 1.0000 ppm SOURCE HEIGHT - 0.00 FT SPILL AREA 200.00 FT**2 SOURCE TEMPERATURE - -29.29 DEG F AMBIENT TEMPERATURE - 86.00 DEG F THE RELEASE IS A LIQUID SPILL THE RELEASE IS CONTINUOUS THE RADII OF EXPOSURE ARE BASED ON PEAK CONCENTRATIONS ODOR THRESHOLD (ppm) 1.0 RADII OF EXPOSURE (fet) @ ground level - 0 plume centerline UNSTABLE 12. mph NEUTRAL** 12. mph STABLE 6. mph 3926. 8296. 20521. ** THE NEUTRAL CONDITION IS TO BE PLOTTED AND REVIEWED FOR THE CEI AUDIT IF THE NEUTRAL RADIUS OF EXPOSURE EXCEEDS THE DOW FENCELINE. THE USE OF ODOR THRESHOLDS IN THE OISPERSION MOOEL PROVIDES DATA USEFUL IN DETERMINING THE LIKELIHOOD OF OLFACTORY DETECTION IN DOWNWIND FACILITIES AND IN THE COMMUNITY. UNSTABLE ATMOSPHERIC CONDITION - SLIGHT SOUR RADIATION WITH LOW WIND SPEEDS (<10 mph) OR STRONG RADIATION WITH HIGH WIND SPEEDS (>10 mph). NEUTRAL ATMOSPHERIC CONDITION - WELL MIXED ATMOSPHERE DUE TO MOOERATE/STRONG WIND SPEEDS (>10 mph) AND SLIGHT/MODERATE SOLAR RADIATION. ANY OVERCAST CONDITION. STABLE ATMOSPHERIC CONDITION LOW WIND SPEEDS (<10 mph) AT NIGHT. ** FOR INTERNAL DOW USE ONLY ** ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DOW CONFIDENTIAL ***** 22 00 A 121437 CONFIDENTIAL POWER ONE PROCESS CYCLE D0 A 121438 CONF1DFNT1AL lO Fhtr TO PLANTS TO PLANTS MTEH KELLS (DIESEL) WATER TREATING TO COMPENSATE 01 STB I BUT I ON S F w */? P*.d/v/ r ?/Ur\ DO A 121440 CONFIDFNTTAL CEIP1U9Z.XLS POWER 1/UTILITIES CHEMICAL LIST CHEMICAL CEI AHH Chlorine HCl Methane Hydrogen 288 81 18 0 TO________ EEPG EEPGX1 EEPGX10 EEPGX10Q ERPG-1 4 1 3 1.762 0.46 0.137 3.441 3 3 25 0.662 0.181 0.616 2.37 1 0 1000 0.112 0.028 00 1 0 1000 1.077 0.269 0.067 0 CEI AHH TO EEPG EEPGX1 EEPGX10 EEPGX100 ERPG-1 Chwical Exposure Index Acute Health Hazard Scale Hufcers Odor Threshold, (ppa) Dow Emergency Exposure Planning Guidelines, (ppa) Radii of Exposure at 1 tiaes EEPG, (ailes) Radii of Exposure at 10 tiaes EEPG, (ailes) Radii of Exposure at 100 tiaes EEPG, (ailes) Radii of Exposure at 1 tiaes Odor Threshold, (ailes) Page 1 Do C OMp rc>rMTr "o tAWK fWM ? jj (. (\ < O a CONFTDFNTTA CEIC12.XLS CHLORINE CHEMISTRY DESIRED REACTION Algaeide and Disinfection of Water UNDE8IRED REACTIONS C12 + Organics -------- Heat(Possible Fire OR Explosion) Inadvertent Use of Reactive Lubricants and Solvents in chlorine Service. Prevented by Training and Material Controller. C12 + Fe + Heat ------> Fire chlorine system runs at ambient conditions. Heat tracing is self limiting to keep gas temperature at 90 degrees F. EMM 2/92 CEICL2 DO A 121443 CONFIDENTIAL CEIPRS.XLS PREVIOUS REVIEW STATUS Listed Below are the Recommendations from the Previous CEI Audit Review. The Comments and suggestions from the review along with the Plant's Responses are attached. 1. utilise Division Chlorine for disinfection of potable water with 150# bottles for bach up. A One inch line was run and 150# bottles are employeed for back up for disinfection of potable water. 2. Consider mounting pressure regulator on one ton cylinder if it is to continue suppling chlorine to the potable water filters. On ton cylinders were discontinued to the potable water filters. 3. Find out about heat tracing. Heat tracing is the self limiting kind with a maximum temperature off 200 F. 4. Check out analyser shack. Analyser shack has been properly labeled. The chlorine monitor in the analyser shack signal has been routed to alarm on the KOD. 5. Chlorine to block 35 is via pipeline. Consider upgrading block 35's chlorinator and supply system. Chi rine monitors have been installed at block 35 both in the shack and around the chlorine piping. An EBV has been installed at block 35 which can be closed in block 18 if there are problems. Plans are in place to modify the chlorine piping going to block 35 t reduce the pressure to 20 psig from 140 to reduce the amount f chlorine that could be released. 6. Block 40 has chlorine cylinders - install signs indicating that chi rine is present. A sign has been installed. mid 2/92 CEIPRS DO A I21444 CONFIDENTIAL CHEMICAL EXPOSURE INDEX PLANT ______________________________ CHEMICAL (One per Index) LARGEST SINGLE CONTAINMENT '2 lb* PRESSURE OF CONTAINMENT % FLASH POINT C ___________________ LOCATION g<-8C* TOTAL QUANTITY IN PLANT * TEMPERATURE OF CONTAINMENT r BOILING POINT * 2* ________________ MOLECULAR WEIGHT 7o . 9________________ VA^<. p/Zfiju*e ityo ihii EMERGENCY EXPOSURE PLANNING GUIDELINE (EEPG) CONCENTRATION, (Refer to CEI Pg. 6 & Tables I &. II, Pgs. 10-11) a____________________ I. Complete the Chemical Exposure Index Summary (on page 5) and show highest CEI to the Public-------------------------------- --- 288 This CEI number determines the level of review needed: 0 to 100 Internal review -- Superintendent and Major Manager review and sign every two years. 100 to 300 Site Review Committee, Superintendent and Major Manager review every two years. 300 to 400 Area Representative and the preceding group review every two years. Above 400 Corporate Representative and the preceding group review every two years. II. Complete Chemical Exposure Review Checklist (see page 7, CEI) prepare Review Package, and indicate date ready for further reviews. (Will be scheduled with Loss Prevention Contact) ______________ III. List any Sights, Odors, or Sounds which might come from your facility and cause public concern or in quiries (e.g., smoke, large relief valves, odors below hazardous levels such as mercaptans or amines, etc.) Reviewed by: Plant Superintendent or Manager: Major or General Manager: _________ Site Review Representative: ____ (If Public CEI is above 100) Area Review Representative: ____ (If Public CEI is above 300) Corporate Review Representative: (If Public CEI is above 400) Form W17J0 4 CHEMICAL EXPOSURE INDEX SUMMARY Complete the following Table (See Note 1) by filling in and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as identified in the following formula (See "Definitions of Scale Numbers" CEI, page 6): 1. ACUTE HEALTH HAZARD SCALE NO. X II. X III. X IV. X V. m VI. VAPOR QUANTITY SCALE NO. DISTANCE (RECIPROCAL) SCALE NO MOLECULAR WEIGHT SCALE NO PROCESS PENALTIES SCALE NO CHEMICAL EXPOSURE INDEX Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source#1 i T*ri fluVo To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business Source #2 (if needed) _________________ To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business 1. II. III. IV. V. VI. (CEI) 4 3 3 4 Z 28$ 4- 3 4 4 z 384. 4* 3 3 4 z Z8 8 NOTE 1 -- The distance scale number in column III is the only factor normally expected to change, so column III and the corresponding CEI (column VI) are all that would normally be expected to differ from the first calculation for each source. NOTE 2--Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 -- Use additional sheets if additional sources with differing potential Impact are present. NOTE 4 -- It is important to documenUhe worst case scenarios for future reference. See "Review Procedure and Check List," page 7. < Fam C41TSO DO A 121446 c CONFIDENTIAL ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** "MICAL EXPOSURE INDEX PLANT: UTILITIES LOCATION: LAD CHEMICAL: CHLORINE TOTAL QUANTITY IN PLANT: 2000.00 lb LARGEST SINGLE CONTAINMENT: 2000.00 lb STORAGE TEMPERATURE: 86.00 deg F STORAGE PRESSURE: 80.00 psia BOILING POINT: -29.18 deg F FLASH POINT: 0.00 deg F MOLECULAR WEIGHT: 70.90 EEPG CONCENTRATION: 3.0 ppm EXPOSURE RISK POTENTIAL SUMMARY ACUTE HEALTH HAZARD FACTOR: 4 (1.0 - 9.9) VAPOR QUANTITY FACTOR: 3 (1,000 lbs - 10,000 lbs) MOTECULAR WEIGHT FACTOR: 4 ( > 45) PI SSS PENALTIES: 2 (overpressure or run-away reaction potential) distance TO THE PUBLIC TO DOW PLANTS TO OTHER BUSINESSES DISTANCE FACTOR 3 (1000 ft - 5279 ft) 4 ( < 1000 ft) 3 (1000 ft - 5279 ft) E.R.P. VALUE 288 384 288 EXPOSURE RISK POTENTIAL TO THE PUBLIC = 288 BIANNUAL REVIEW r- SITE, SUPERINTENDENT AND MAJOR MANAGER THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE'METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** D0 A confi^htia **** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DISPERSION SUMMARY TOTAL DISCHARGED = 2000.00 LBS RELEASE DURATION = 15.00 MIN MOLECULAR WEIGHT = 70.90 SOURCE TEMPERATURE = 86.00 DEG F EEPG CONCENTRATION = 3.0 ppm SOURCE HEIGHT = 0.00 FT SOURCE DIAMETER = 0.16 FT EXIT VELOCITY - 621.04 FT/S PERCENT DILUTION - 0.00 AMBIENT TEMPERATURE = 86.00 DEG F THE RELEASE IS A GAS RELEASE THE RELEASE IS CONTINUOUS THE RADII OF EXPOSURE ARE BASED ON PEAK CONCENTRATIONS CONC (ppm) RADII OF EXPOSURE (miles) ground level - plume centerline UNSTABLE 12. mph (20 %)* NEUTRAL 8. mph (40 %)* STABLE 4. mph (40 %)* 3.0 0.425 1.762 30.0 0.150 0.460 300.0 0.064 0.137 APPROXIMATE % OF TIME IN THIS WEATHER CONDITION 8.153 1.735 0.411 INSTABLE ATMOSPHERIC CONDITION - SLIGHT SOLAR RADIATION WITH LOW WIND SPEEDS (<10 mph) OR STRONG RADIATION WITH HIGH WIND SPEEDS (>10 mph). IEUTRAL ATMOSPHERIC CONDITION - WELL MIXED ATMOSPHERE DUE TO MODERATE/STRONG WIND SPEEDS (>7 mph) AND SLIGHT/MODERATE SOLAR RADIATION. ANY OVERCAST CONDITION. TABLE ATMOSPHERIC CONDITION - LOW WIND SPEEDS (<10 mph) AT NIGHT.. 'HE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD 'OR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** DO a 1 CONFIDENT O' r <*<-- ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** IJMICAL EXPOSURE INDEX PLANT: UTILITIES LOCATION: LAD CHEMICAL: CHLORINE TOTAL QUANTITY IN PLANT: 2000.00 lb LARGEST SINGLE CONTAINMENT: 2000.00 lb STORAGE TEMPERATURE: 86.00 deg F STORAGE PRESSURE: 80.00 psia BOILING POINT: -29.18 deg F FLASH POINT: 0.00 deg F MOLECULAR WEIGHT: 70.90 EEPG CONCENTRATION: 1.0 ppm EXPOSURE RISK POTENTIAL SUMMARY ACUTE HEALTH HAZARD FACTOR: 4 (1.0 - 9.9) VAPOR QUANTITY FACTOR: 3 (1,000 lbs - 10,000 lbs) MOLECULAR WEIGHT FACTOR: 4 ( > 45) PF 3SS PENALTIES: 2 (overpressure or run-away reaction potential) DISTANCE TO THE PUBLIC TO DOW PLANTS TO OTHER BUSINESSES DISTANCE FACTOR 3 (1000 ft - 5279 ft) 4 ( < 1000 ft) 3 (1000 ft - 5279 ft) E.R.P. VALUE 288 384 288 EXPOSURE RISK POTENTIAL TO THE PUBLIC = 288 BIANNUAL REVIEW - SITE, SUPERINTENDENT AND MAJOR MANAGER THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVEMETHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DO A 121449 CONFIDENTIAL A-' U ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DISPERSION SUMMARY TOTAL DISCHARGED = 2000.00 LBS RELEASE DURATION = 15.00 MIN MOLECULAR WEIGHT = 70.90 SOURCE TEMPERATURE = 86.00 DEG F EEPG-/CONCENTRATION = 1.0 ppm SOURCE HEIGHT = 0.00 FT SOURCE DIAMETER = 0.16 FT EXIT VELOCITY = 621.04 FT/S PERCENT DILUTION = 0.00 AMBIENT TEMPERATURE = 86.00 DEG F THE RELEASE IS A GAS RELEASE THE RELEASE IS CONTINUOUS THE RADII OF EXPOSURE ARE BASED ON PEAK CONCENTRATIONS CONC (ppm) RADII OF EXPOSURE (miles) ground level - plume centerline UNSTABLE 12. mph (20 %)* NEUTRAL 8. mph (40 %)* STABLE 4. mph (40 %)* 1.0 0.721 3.441 10.0 0.243 0.864 100.0 0.093 0.238 APPROXIMATE % OF TIME IN THIS WEATHER CONDITION 21.500 3.521 0.815 UNSTABLE ATMOSPHERIC CONDITION - SLIGHT SOLAR RADIATION WITH LOW WIND SPEEDS (<10 mph) OR STRONG RADIATION WITH HIGH WIND SPEEDS (>10 mph). NEUTRAL ATMOSPHERIC CONDITION - WELL MIXED ATMOSPHERE DUE TO MODERATE/STRONG WIND SPEEDS (>7 mph) AND SLIGHT/MODERATE SOLAR RADIATION. ANY OVERCAST CONDITION. STABLE ATMOSPHERIC CONDITION - LOW WIND SPEEDS (<10 mph) AT NIGHT. THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** DO A 121450 CONFIDFNTTAL CHEMICAL EXPOSURE INDEX plant mn f/>s________________________________ CHEMICAL (One per Index) _c #'*** ____________ LARGEST SINGLE CONTAINMENT / d Q<H> PRESSURE OF CONTAINMENT go A*!p. FLASH POINT, C _______________________ __ LOCATION l3coc< iZ CAO __________ TOTAL QUANTITY IN PLANT * TEMPERATURE OF CONTAINMENT AmtifMr BOILING POINT * 2 ? r MOLECULAR WEIGHT ?? _ _________ VAP*4 P4CSJurt. i,(mSo r*** *V EMERGENCY EXPOSURE PLANNING GUIDELINE (EEPG) CONCENTRATION, (Refer to CEI Pg. 6 & Tables I & II, Pgs. 10-11)________ U_________________ I. Complete the Chemical Exposure Index Summary (on page 5) and show highest CEI to the Public---------------------------------------- Hi This CEI number determines the level of review needed: 0 to 100 Internal review -- Superintendent and Major Manager review and sign every two years. 100 to 300 Site Review Committee, Superintendent and Major Manager review every two years. 300 to 400 Area Representative and the preceding group review every two years. Above 400 Corporate Representative and the preceding group review every two years. II. Complete Chemical Exposure Review Checklist (see page 7, CEI) prepare Review Package, and indicate date ready for further reviews. (Will be scheduled with Loss Prevention Contact) ______________ III. List any Sights, Odors, or Sounds which might come from your facility and cause public concern or in quiries (e.g., smoke, large relief valves, odors below hazardous levels such as mercaptans or amines, eta) Reviewed by: Plant Superintendent or Manager^, Major or Genera) Manager______ Site Review Representative:______ (If Public CEI is above 100) Area Review Representative: _____ (If Public CEI is above 300) Corporate Review Representative: (If Public CEI is above 400) Farm G4V730 4 Date jr//*/? '3-23-73 121A5l 00 R DFNTlRO CHEMICAL EXPOSURE INDEX SUMMARY Complete the following Table (See Note 1) by filling in and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as identified in the following formula (See "Definitions of Scale Numbers" CEI, page 6): 1. ACUTE HEALTH HAZARD SCALE NO. X II. X III. X IV. X V. - VI. VAPOR QUANTITY SCALE NO. DISTANCE (RECIPROCAL) SCALE NO. MOLECULAR WEIGHT SCALE NQ PROCESS PENALTIES SCALE NO. CHEMICAL EXPOSURE INDEX Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source #1 / cHU*.K*f 4 To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business SnijrMi MO (if ndAd) To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business 1. II. III. IV. V. VI. (CEI) 4134 Z 4 1 A 4 z 11% 4 4 3 4z 4 Z 3 4 z i fz 4- z 4 4 z ij-t 4 23 4 z in NOTE 1 -- The distance scale number in column III is the only factor normally expected to change, so column III and the corresponding CEI (column VI) are all that would normally be expected to differ from the first calculation for each source. NOTE 2--Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 -- Use additional sheets if additional sources with differing potential impact are present. NOTE 4 -- It is important to documenUhe worst case scenarios for future reference. See "Review Procedure and Check List," page 7. Baca ct form &41720 c DO A 121452 CONFIDENTIAL ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** :MICAL EXPOSURE INDEX PLANT: UTILITIES LOCATION: LAD CHEMICAL: CHLORINE TOTAL QUANTITY IN PLANT: 750.00 lb LARGEST SINGLE CONTAINMENT: 150.00 lb STORAGE TEMPERATURE: 86.00 deg F STORAGE PRESSURE: 6.80 psia BOILING POINT: -29.18 deg F FLASH POINT: 0.00 deg F MOLECULAR WEIGHT: 70.90 EEPG CONCENTRATION: 3.0 ppm EXPOSURE RISK POTENTIAL SUMMARY ACUTE HEALTH HAZARD FACTOR: 4 (1.0 - 9.9) VAPOR QUANTITY FACTOR: 2 (100 lbs - 999 lbs) MOT OCULAR WEIGHT FACTOR: 4 ( > 45) PI ESS PENALTIES: 2 (overpressure or run-away reaction potential) uISTANCE TO THE PUBLIC TO DOW PLANTS TO OTHER BUSINESSES DISTANCE FACTOR 3 (1000 ft - 5279 ft) 4 ( < 1000 ft) 3 (1000 ft - 5279 ft) E.R.P. VALUE 192 256 192 EXPOSURE RISK POTENTIAL TO THE PUBLIC = 192 BIANNUAL REVIEW - SITE, SUPERINTENDENT AND MAJOR MANAGER THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DO A 121453 CONFIDENTIAL ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DISPERSION SUMMARY TOTAL DISCHARGED - 150.00 LBS RELEASE DURATION = 15.00 MIN MOLECULAR WEIGHT = 70.90 SOURCE TEMPERATURE = 86.00 DEG F EEPG CONCENTRATION = 3.0 ppm SOURCE HEIGHT = 0.00 FT SOURCE DIAMETER = 0.16 FT EXIT VELOCITY = 46.58 FT/S PERCENT DILUTION = 0.00 AMBIENT TEMPERATURE * 86.00 DEG F THE RELEASE IS A GAS RELEASE THE RELEASE IS CONTINUOUS THE RADII OF EXPOSURE ARE BASED ON PEAK CONCENTRATIONS CONC (ppm) RADII OF EXPOSURE (miles) ground level - plume centerline UNSTABLE 12. mph (20 %)* NEUTRAL 8. mph (40 %)* STABLE 4. mph (40 %)* 3.0 0.116 0.370 1.465 30.0 0.041 0.099 0.361 300.0 0.013 0.031 0.096 * APPROXIMATE % OF TIME IN THIS WEATHER CONDITION JNSTABLE ATMOSPHERIC CONDITION - SLIGHT SOLAR RADIATION WITH LOW WIND SPEEDS (<10 mph) OR STRONG RADIATION WITH HIGH WIND SPEEDS (>10 mph). NEUTRAL ATMOSPHERIC CONDITION - WELL MIXED ATMOSPHERE DUE TO MODERATE/STRONG WIND SPEEDS (>7 mph) AND SLIGHT/MODERATE SOLAR RADIATION. ANY OVERCAST CONDITION. STABLE ATMOSPHERIC CONDITION - LOW WIND SPEEDS (<10 mph) AT NIGHT. THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** CODNFrADENn4AS,4 CHEMICAL EXPOSURE INDEX PLANT u + I' LOCATION 8 <-oi 19 Lao CHEMICAL (One per Index) A avous He/ TOTAL QUANTITY IN PUNTItil* URGEST SINGLE CONTAINMENT 3 8, 7<> J*>3 TEMPERATURE OF CONTAINMENT PRESSURE OF CONTAINMENT ATik. SHe/tic. BOILING POINT <7 F FUSH POINT, "C Mo/<e MOLECUUR WEIGHT ____________________ EMERGENCY EXPOSURE PUNNING GUIDELINE (EEPG) CONCENTRATION, (Refer to CEI Pg. 6 & Tables I & II, Ffcs. 10-11)___________ 2 S I. Complete the Chemical Exposure Index Summary (on page 5) and show highest CEI to the Public ---------------------------------------- 9J This CEI number determines the level of review needed: 0 to 100 Internal review -- Superintendent and Major Manager review and sign every two years. 100 to 300 Site Review Committee, Superintendent and Major Manager review every two years. 300 to 400 Area Representative and the preceding group review every two years. Above 400 Corporate Representative and the preceding group review every two years. II. Complete Chemical Exposure Review Checklist (see page 7, CEI) prepare Review Package, and indicate date ready for further reviews. (Will be scheduled with Loss Prevention Contact) ______________ III. List any Sights, Odors, or Sounds which might come from your facility and cause public concern or in quiries (e.g., smoke, large relief valves, odors below hazardous levels such as mercaptans or amines, etc.) Reviewed by: Plant Superintendent or Manager:^, Major or General Manager _______ Site Review Representative: _______ (If Public CEI is above 100) Area Review Representative: ______ (If Public CEI is above 300) Corporate Review Representative: _ (If Public CEI is above 400) _ Form O#iT20 uu. 4 3 DO A 121455 CONFIDENTIAL. CHEMICAL EXPOSURE INDEX SUMMARY Complete the following Table (See Note 1) by filling in and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as identified in the following formula (See "Definitions of Scale Numbers" CEI, page 6): 1. ACUTE HEALTH HAZARD SCALE NO. X II. X III. X IV. X V. - VI. VAPOR QUANTITY SCALE NO. DISTANCE (RECIPROCAL) SCALE NO. MOLECULAR WEIGHT SCALE NO. PROCESS PENALTIES SCALE NO. CHEMICAL EXPOSURE INDEX Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source #1 A a-Aa-i LmE To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business Source #2 fif needed) TAwk To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business 1. II. III. IV. V. VI. (CEI) 32 3l 3Z 3 3 / Si 4 3 i ?Z 33 / si 33 33 3 3 43 33 3 3 I 8j 1 /t> 8 1 3/ NOTE 1 -- The distance scale number in column III is the only factor normally expected to change, so column III and the corresponding CEI (column VI) are all that would normally be expected to differ from the first calculation for each source. NOTE 2 -- Only different sources of the same chemical should be evaluated on this sheet. Use a separate Ch mical Exposure Index for every different chemical. NOTE 3 -- Use additional sheets if additional sources with differing potential impact are present. NOTE 4 -- It is important to document the worst case scenarios for future reference. See "Review Proc dure and Check List," page 7, -- ( of Fom 0*1720 Do A 121456 5 CONFIDENTIAL ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** EMICAL EXPOSURE INDEX PLANT: UTILITIES LOCATION: LAD CHEMICAL: AQ. HCL TOTAL QUANTITY IN PLANT: 38800.00 lb LARGEST SINGLE CONTAINMENT: 38800.00 lb STORAGE TEMPERATURE: 86.00 deg F STORAGE PRESSURE: 14.70 psia BOILING POINT: 178.00 deg F FLASH POINT: 0.00 deg F MOLECULAR WEIGHT: 36.00 EEPG CONCENTRATION: 25.0 ppm EXPOSURE RISK POTENTIAL SUMMARY ACUTE HEALTH HAZARD FACTOR: 3 (10 - 99) VAPOR QUANTITY FACTOR: 3 (1,000 lbs - 10,000 lbs) MOLECULAR WEIGHT FACTOR: 3 (34 - 45) DI ESS PENALTIES: 1 (no process penalties) DISTANCE TO THE PUBLIC TO DOW PLANTS TO OTHER BUSINESSES DISTANCE FACTOR 3 (1000 ft - 5279 ft) 4 ( < 1000 ft) 3 (1000 ft - 5279 ft) E.R.P. VALUE 81 108 81 EXPOSURE RISK POTENTIAL TO THE PUBLIC = 81 NO REVIEW - SUPERINTENDENT AND MAJOR MANAGER APPROVAL THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE' METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DISPERSION SUMMARY TOTAL DISCHARGED = RELEASE DURATION = MOLECULAR WEIGHT = SOURCE TEMPERATURE EEPG CONCENTRATION 1643.00 LBS 15.00 MIN 36.00 86.00 DEG F 25.0 ppm SOURCE HEIGHT = 0.00 FT SOURCE DIAMETER = 0.16 FT EXIT VELOCITY = 1004.78 FT/S PERCENT DILUTION - 0.00 AMBIENT TEMPERATURE - 86.00 DEG F THE RELEASE IS A GAS RELEASE THE RELEASE IS CONTINUOUS THE RADII OF EXPOSURE ARE BASED ON PEAK CONCENTRATIONS CONC (ppm) RADII OF EXPOSURE (miles) ground level - @ plume centerline UNSTABLE 12. mph (20 %)* NEUTRAL 8. mph (40 %)* STABLE 4. mph (40 %)* 25.0 0.207 0.662 250.0 0.086 0.181 2500.0 0.048 0.060 APPROXIMATE % OF TIME IN THIS WEATHER CONDITION 2.646 0.616 0.141 UNSTABLE ATMOSPHERIC CONDITION - SLIGHT SOLAR RADIATION WITH LOW WIND SPEEDS (<10 mph) OR STRONG RADIATION WITH HIGH WIND SPEEDS (>10 mph). NEUTRAL ATMOSPHERIC CONDITION - WELL MIXED ATMOSPHERE DUE TO MODERATE/STRONG WIND SPEEDS (>7 mph) AND SLIGHT/MODERATE SOLAR RADIATION. ANY OVERCAST CONDITION. STABLE ATMOSPHERIC CONDITION - LOW WIND SPEEDS (<10 mph) AT NIGHT.. THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** DO ca^o^^r1r4Z58 ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** EMICAL EXPOSURE INDEX PLANT: UTILITIES LOCATION: LAD CHEMICAL: AQ. HCL TOTAL QUANTITY IN PLANT: 38800.00 lb LARGEST SINGLE CONTAINMENT: 38800.00 lb STORAGE TEMPERATURE: 86.00 deg F STORAGE PRESSURE: 14.70 psia BOILING POINT: 178.00 deg F FLASH POINT: 0.00 deg F MOLECULAR WEIGHT: 36.00 EEPG CONCENTRATION: 3.0 ppm EXPOSURE RISK POTENTIAL SUMMARY ACUTE HEALTH HAZARD FACTOR: 3 (10 - 99) VAPOR QUANTITY FACTOR: 3 (1,000 lbs - 10,000 lbs) MOLECULAR WEIGHT FACTOR: 3 (34 - 45) PI ESS PENALTIES: 1 (no process penalties) DISTANCE TO THE PUBLIC TO DOW PLANTS TO OTHER BUSINESSES DISTANCE FACTOR 3 (1000 ft - 5279 ft) 4 ( < 1000 ft) 3 (1000 ft - 5279 ft) E.R.P. VALUE 81 108 81 EXPOSURE RISK POTENTIAL TO THE PUBLIC * 81 NO REVIEW - SUPERINTENDENT AND MAJOR MANAGER APPROVAL THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DO a CO^F 459 T Al ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DISPERSION SUMMARY TOTAL DISCHARGED = 1655.00 LBS RELEASE DURATION = 15.00 MIN MOLECULAR WEIGHT = 36.00 SOURCE TEMPERATURE = 86.00 DEG F EEPG CONCENTRATION 3.0 ppm SOURCE HEIGHT - 0.00 FT SOURCE DIAMETER = 0.16 FT EXIT VELOCITY = 1012.12 FT/S PERCENT DILUTION = 0.00 AMBIENT TEMPERATURE * 86.00 DEG F THE RELEASE IS A GAS RELEASE THE RELEASE IS CONTINUOUS THE RADII OF EXPOSURE ARE BASED ON PEAK CONCENTRATIONS CONC (ppm) RADII OF exposure (miles) 8 ground level - 8 plume centerline UNSTABLE 12. mph (20 %)* NEUTRAL 8. mph (40 %)* STABLE 4. mph (40 %)* 3.0 0.543 2.357 30.0 0.192 0.598 300.0 0.081 0.165 APPROXIMATE % OF TIME IN THIS WEATHER CONDITION 12.023 2.363 0.552 UNSTABLE ATMOSPHERIC CONDITION - SLIGHT SOLAR RADIATION WITH LOW WIND SPEEDS (<10 mph) OR STRONG RADIATION WITH HIGH WIND SPEEDS (>10 mph). NEUTRAL ATMOSPHERIC CONDITION - WELL MIXED ATMOSPHERE DUE TO MODERATE/STRONG WIND SPEEDS (>7 mph) AND SLIGHT/MODERATE SOLAR RADIATION. ANY OVERCAST CONDITION. STABLE ATMOSPHERIC CONDITION - LOW WIND SPEEDS (<10 mph) AT NIGHT. THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** DO A 121460 CONFIDENTIAL ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** EMICAL EXPOSURE INDEX PLANT: UTILITIES LOCATION: LAD CHEMICAL: AQ. HCL TOTAL QUANTITY IN PLANT: 38800.00 lb LARGEST SINGLE CONTAINMENT: 38800.00 lb STORAGE TEMPERATURE: 86.00 deg F STORAGE PRESSURE: 14.70 psia BOILING POINT: 178.00 deg F FLASH POINT: 0.00 deg F MOLECULAR WEIGHT: 36.00 EEPG CONCENTRATION: 25.0 ppm EXPOSURE RISK POTENTIAL SUMMARY ACUTE HEALTH HAZARD FACTOR: 3 (10-99) VAPOR QUANTITY FACTOR: 2 (100 lbs - 999 lbs) MOTECULAR WEIGHT FACTOR: 3 (34 - 45) ESS PENALTIES: l (no process penalties) DISTANCE TO THE PUBLIC TO DOW PLANTS TO OTHER BUSINESSES DISTANCE FACTOR 3 (1000 ft - 5279 ft) 4 ( < 1000 ft) 3 (1000 ft - 5279 ft) E.R.P. VALUE 54 72 54 EXPOSURE RISK POTENTIAL TO THE PUBLIC - 54 NO REVIEW - SUPERINTENDENT AND MAJOR MANAGER APPROVAL THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** ***** dow CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DISPERSION SUMMARY TOTAL DISCHARGED = 600.00 LBS RELEASE DURATION = 15.00 MIN MOLECULAR WEIGHT = 36.00 SOURCE TEMPERATURE = 86.00 DEG F EEPG CONCENTRATION = 25.0 ppm SOURCE HEIGHT 0. 00 FT SOURCE DIAMETER = 0,16 FT EXIT VELOCITY = 366 .93 FT/S PERCENT DILUTION = 0.00 AMBIENT TEMPERATURE = 86.00 THE RELEASE IS A GAS RELEASE THE RELEASE IS CONTINUOUS THE RADII OF' EXPOSURE ARE BASED ON PEAK CONCENTRATIONS CONC (ppm) RADII OF EXPOSURE (miles) ground level - plume centerline UNSTABLE 12. mph (20 %)* NEUTRAL 8. mph (40 %)* STABLE 4. mph (40 %)* 25.0 0.124 0.373 250.0 0.052 0.110 2500.0 0.025 0.045 APPROXIMATE % OF TIME IN THIS WEATHER CONDITION 1.436 0.370 0.114 JNSTABLE ATMOSPHERIC CONDITION - SLIGHT SOLAR RADIATION WITH LOW WIND SPEEDS (<10 mph) OR STRONG RADIATION WITH HIGH WIND SPEEDS (>10 mph). NEUTRAL ATMOSPHERIC CONDITION - WELL MIXED ATMOSPHERE DUE TO MODERATE/STRONG WIND SPEEDS (>7 mph) AND SLIGHT/MODERATE SOLAR RADIATION. ANY OVERCAST CONDITION. STABLE ATMOSPHERIC CONDITION - LOW WIND SPEEDS (<10 mph) AT NIGHT.. CHE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD rOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** D a l?346-> c-ONFID F^NTTAt CHEMICAL EXPOSURE INDEX PLANT _. P 0 w g/2 A______________________ CHEMICAL (One per Index) r*tr*A*e _ LARGEST SINGLE CONTAINMENT Wo** PRESSURE OF CONTAINMENT _ 7 Ftt/C FLASH POINT, *C_____________________________ LOCATION Z 8 LAO TOTAL QUANTITY IN PLANT TEMPERATURE OF CONTAINMENT BOILING POINT _ _ ____________________ MOLECULAR WEIGHT _ 4 6__________________ EMERGENCY EXPOSURE PLANNING GUIDELINE (EEPG) CONCENTRATION, (Refer to CEI Pg. 6 & Tables I & II, Pgs. 10-11)_____________________________ I. Complete the Chemical Exposure Index Summary (on page 5) and show highest CEI to the Public This CEI number determines the level of review needed: 0 to 100 Internal review -- Superintendent and Major Manager review and sign every two years. 100 to 300 Site Review Committee, Superintendent and Major Manager review every two years. 300 to 400 Area Representative and the preceding group review every two years. Above 400 Corporate Representative and the preceding group review every two years. II. Complete Chemical Exposure Review Checklist (see page 7, CEI) prepare Review Package, and indicate date ready for further reviews. (Will be scheduled with Loss Prevention Contact) ______________ III. List any Sights, Odors, or Sounds which might come from your facility and cause public concern or in quiries (e.g., smoke, large relief valves, odors below hazardous levels such as mercaptans or amin s, etc.) Reviewed by: Plant Superintendent or Manager Major or General Manager _____ Site Review Representative: _____ (If Public CEI is above 100) Area Review Representative: ____ (If Public CEI is above 300) Corporate Review Representative: (If Public CEi is above 400) 4 2Z U-U OO A 121463 CONFIDETNTIAI CHEMICAL EXPOSURE INDEX SUMMARY Complete the following Table (See Note 1) by filling in and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as identified in the following formula (See "Definitions of Scale Numbers" CEI, page 6): 1. X II. X III. X IV. X V. m VI. ACUTE HEALTH HAZARD SCALE NO. VAPOR QUANTITY SCALE NO. DISTANCE (RECIPROCAL) SCALE NO. MOLECULAR WEIGHT SCALE NO. PROCESS PENALTIES SCALE NO. CHEMICAL EXPOSURE INDEX Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source #1 /wSTHA^g - 8 ***< 2-9 To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business Source #2 (if needed) ________________ To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business 1. ii. Hi. IV. V. VI. (CEI) 13 13 X3 3J 4X 3X Z /8 2 ZV 2 /8 NOTE 1 -- The distance scale number in column III is the only factor normally expected to change, so column III and the corresponding CEI (column VI) are all that would normally be expected to differ from the first calculation for each source. NOTE 2 -- Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 -- Use additional sheets if additional sources with differing potential impact are present. NOTE 4 -- It is important to document the worst case scenarios for future reference. See "Review Procedure and Check List," page 7. Back of Form 041720 5 DO A 12i4&4 cDNFJDENTrAL ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** eMICAL EXPOSURE INDEX PLANT: POWER 1 LOCATION: LAD CHEMICAL: METHANE TOTAL QUANTITY IN PLANT: 0.00 lb LARGEST SINGLE CONTAINMENT: 0.00 lb STORAGE TEMPERATURE: 86.00 deg F STORAGE PRESSURE: 70.00 psia BOILING POINT: -161.00 deg F FLASH POINT: 0.00 deg F MOLECULAR WEIGHT: 16.00 EEPG CONCENTRATION: 1000.0 ppm EXPOSURE RISK POTENTIAL SUMMARY ACUTE HEALTH HAZARD FACTOR: 1 (1,000 - 100,000) VAPOR QUANTITY FACTOR: 3 (1,000 lbs - 10,000 lbs) MOLECULAR WEIGHT FACTOR: 1 (15 - 22) PI ESS PENALTIES: 2 (overpressure or run-away reaction potential) DISTANCE TO THE PUBLIC TO DOW PLANTS TO OTHER BUSINESSES DISTANCE FACTOR 3 (1000 ft - 5279 ft) 4 ( < 1000 ft) 3 (1000 ft - 5279 ft) E.R.P. VALUE 18 24 18 EXPOSURE RISK POTENTIAL TO THE PUBLIC = 18 NO REVIEW - SUPERINTENDENT AND MAJOR MANAGER APPROVAL THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DO A 121465 CONFIDENTIAL ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** dispersion summary TOTAL DISCHARGED = 1600.00 LBS RELEASE DURATION = 15.00 MIN MOLECULAR WEIGHT = 16.00 SOURCE TEMPERATURE = 86.00 DEG F EEPG CONCENTRATION = 1000.0 ppm SOURCE HEIGHT = 0.00 FT SOURCE DIAMETER = 0.16 FT EXIT VELOCITY = 2201.59 FT/S PERCENT DILUTION * 0.00 AMBIENT TEMPERATURE = 86.00 DEG F THE RELEASE IS A GAS RELEASE THE RELEASE IS CONTINUOUS THE RADII OF EXPOSURE ARE BASED ON PEAK CONCENTRATIONS CONC (ppm) RADII OF EXPOSURE (miles) ground level - G plume centerline UNSTABLE 12. mph (20 %)* NEUTRAL 8. mph (40 %)* STABLE 4. mph (40 %)* 1000.0 0.041 0.112 10000.0 0.010 0.028 100000.0 0.000 0.000 APPROXIMATE % OF TIME IN THIS WEATHER CONDITION 0.433 0.105 0.000 INSTABLE ATMOSPHERIC CONDITION - SLIGHT SOLAR RADIATION WITH LOW WIND SPEEDS (<10 mph) OR STRONG RADIATION WITH HIGH WIND SPEEDS (>10 mph). NEUTRAL ATMOSPHERIC CONDITION - WELL MIXED ATMOSPHERE DUE TO MODERATE/STRONG WIND SPEEDS (>7 mph) AND SLIGHT/MODERATE SOLAR RADIATION. ANY OVERCAST CONDITION. STABLE ATMOSPHERIC CONDITION - LOW WIND SPEEDS (<10 mph) AT NIGHT. rHE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** 00 A 121466 confidential CHEMICAL EXPOSURE INDEX plant r QMfrg aJ____________________ CHEMICAL (One per Index) LARGEST SINGLE CONTAINMENT _e>" PRESSURE OF CONTAINMENT J FLASH POINT, C 0__________________ LOCATION l*.c*9 TOTAL QUANTITY IN PLANT TEMPERATURE OF CONTAINMENT *Wa*r BOILING POINT -~V3y MOLECULAR WEIGHT ? EMERGENCY EXPOSURE PLANNING GUIDELINE (EEPG) CONCENTRATION, (Refer to CEI Pg. 6 & Tables I & II, Pgs. 10-11)_____________________________ I. Complete the Chemical Exposure Index. Summary (on page 5) and show highest CEI to the Public This CEI number determines the level of review needed: 0 to 100 Internal review -- Superintendent and Major Manager review and sign every two years. 100 to 300 Site Review Committee, Superintendent and Major Manager review every two years. 300 to 400 Area Representative and the preceding group review every two years. Above 400 Corporate Representative and the preceding group review every two years. II. Complete Chemical Exposure Review Checklist (see page 7, CEI) prepare Review Package, and indicate date ready for further reviews. (Will be scheduled with Loss Prevention Contact) ______________ III. List any Sights, Odors, or Sounds which might come from your facility and cause public concern or in quiries (e.g., smoke, large relief valves, odors below hazardous levels such as mercaptans or amines, etc.) Reviewed by: Plant Superintendent or Manager Major or General Manager_____ Site Review Representative:_____ (If Public CEI is above 100) Area Review Representative: ____ (If Public CEI Is above 300) Corporate Review Representative: (If Public CEi is above 400) fcjm C41T30 4 OQ A 1 -S C0N^0^Nr^ CHEMICAL EXPOSURE INDEX SUMMARY Complete the following Table (See Note 1) by filling in and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as identified in the following formula (See "Definitions of Scale Numbers" CEI, page 6): 1. ACUTE HEALTH HAZARD SCALE NO. X II. X III. X IV. X V. m VI. VAPOR QUANTITY SCALE NO. DISTANCE (RECIPROCAL) SCALE NO. MOLECULAR WEIGHT SCALE NO. PROCESS PENALTIES SCALE NO CHEMICAL EXPOSURE INDEX Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source m HyoaotgyU - W'lfrg. To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business Source #2 (if needed) To (1) Public (2) Other in*company Facility (3) Non-company Plant or Business 1. II. ill. IV. V. VI. (CEI) X 33 o 20 X 3 4 6Z 6 1 33 O2 0 NOTE 1 -- The distance scale number in column III is the only factor normally expected to change, so column III and the corresponding CEI (column VI) are all that would normally be expected to differ from the first calculation for each source. NOTE 2--Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 -- Use additional sheets if additional sources with differing potential impact are present. NOTE 4 -- It is important to documenUhe worst case scenarios for future reference. See "Review Procedure and Check List," page 7. Back of Fonn 0*1770 DO A 121468 CONFIDENTIAL ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** EMICAL EXPOSURE INDEX PLANT: POWER 1 LOCATION: LAD CHEMICAL: HYDROGEN TOTAL QUANTITY IN PLANT: 53000.00 lb LARGEST SINGLE CONTAINMENT: 8600.00 lb STORAGE TEMPERATURE: 86.00 deg F STORAGE PRESSURE: ****** psia BOILING POINT: -434.00 deg F FLASH POINT: 0.00 deg F MOLECULAR WEIGHT: 2.00 EEPG CONCENTRATION: 1000.0 ppm EXPOSURE RISK POTENTIAL SUMMARY ACUTE HEALTH HAZARD FACTOR: 1 (1,000 - 100,000) VAPOR QUANTITY FACTOR: 3 (1,000 lbs - 10,000 lbs) MOLECULAR WEIGHT FACTOR: 0 ( < 15) PI ESS PENALTIES: 2 (overpressure or run-away reaction potential) DISTANCE TO THE PUBLIC TO DOW PLANTS TO OTHER BUSINESSES DISTANCE FACTOR 3 (1000 ft - 5279 ft) 4 ( < 1000 ft) 3 (1000 ft - 5279 ft) E.R.P. VALUE 0 0 0 EXPOSURE RISK POTENTIAL TO THE PUBLIC = 0 NO REVIEW - SUPERINTENDENT AND MAJOR MANAGER APPROVAL THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** 00 A 121469 CONFIDENT T4I **** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DISPERSION SUMMARY TOTAL DISCHARGED = 8600.00 LBS RELEASE DURATION = 15.00 MIN MOLECULAR WEIGHT = 2.00 SOURCE TEMPERATURE = 86.00 DEG F EEPG CONCENTRATION = 1000.0 ppm SOURCE HEIGHT = 0.00 FT SOURCE DIAMETER = 0.16 FT EXIT VELOCITY = ******* FT/S PERCENT DILUTION * 0.00 AMBIENT TEMPERATURE = 86.00 DEG F THE RELEASE IS A GAS RELEASE THE RELEASE IS CONTINUOUS THE RADII OF EXPOSURE ARE BASED ON PEAK CONCENTRATIONS CONC (ppm) RADII OF EXPOSURE (miles) 8 ground level - plume centerline UNSTABLE 12. mph (20 %)* NEUTRAL 8. mph (40 %)* STABLE 4. mph (40 %)* 1000.0 0.271 1.077 10000.0 0.085 0.269 100000.0 0.027 0.067 APPROXIMATE % OF TIME IN THIS WEATHER CONDITION 4.676 1.068 0.258 JNSTABLE ATMOSPHERIC CONDITION - SLIGHT SOLAR RADIATION WITH LOW WIND SPEEDS (<10 mph) OR STRONG RADIATION WITH HIGH WIND SPEEDS (>10 mph). JEUTRAL ATMOSPHERIC CONDITION - WELL MIXED ATMOSPHERE DUE TO MODERATE/STRONG WIND SPEEDS (>7 mph) AND SLIGHT/MODERATE SOLAR RADIATION. ANY OVERCAST CONDITION. JTABLE ATMOSPHERIC CONDITION - LOW WIND SPEEDS (<10 mph) AT NIGHT. ?HE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD rOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** Do A 121470 CONFID6TNTIA1 RED TAG CHLORINE LINE TO CHLORINATOR/CYLINDER AREA 1) BLOCK IN CHLORINE BLOCK TO POTABLE WATER AREA. VALVE IS LOCATED IN THE AIR NE OF GRAVITY FILTERS. 2) ALLOW ENOUGH TIME FOR CHLORINATOR TO REMOVE REMAINING CHLORINE FROM LINE. (VERIFY BY CHECKING FLOW AT CHLORINATOR.) 3) BLOCK AND RED TAG BLOCK VALVE TO CHLORINATOR. 4) BLOCK AND RED TAG BLOCK VALVE TO CHLORINE CYLINDERS. 5) TAG OUT HEAT TRACING BREAKER IN MCC. (B4-3) a) TURN SWITCH ON BREAKER FROM AUTO TO OFF. b) TURN BREAKER HANDLE TO OFF POSITION. REG TAGS - 1) CLORINE BLOCK VALVE (AIR) 2 BLOCK VALVE TO CHLORINATOR 3) BLOCK VALVE TO CHLORINE CYLINDERS 4) HEAT TRACING SWITCH (B4-3) 5) HEAT TRACING BREAKER (B4-3) KP 3/10/89 1 SWAPPING CHLORINE FEED FROM DIVISION SYSTEM TO BLOCK BOTTLES 1) BLOCK IN MAIN VALVE OVER-HEAD PIPE RACK AND RE D TAG (NORTH-EAST OF GRAVITY FILTERS USING A MANLIFT.) 2) ALLOW ENOUGH TIME FOR CHLORINATOR TO REMOVE REMAINING CHLORINE FROM LINE. (VERIFY BY CHECKING FLOW AT CHLORINATOR) 3) BLOCK IN AND RED TAG BLOCK VALVE TO CHLORINATOR. A) OPEN BLOCK VALVE FROM CHLORINE BOTTLES TO CHLORINATOR. 5) OPEN FEED VALVE OF CHLORINE BOTTLE. KP 2/28/89 DO C0'W?*> DOW U.S.A. - LOUISIANA DIVISION EMERGENCY PLAN SECTION A PAGE 24 Fire or Explosion Response A. Notification to Gate 1 Security personnel will be made by dialing 333. Phones will ring at Gate 1, Fire Station, Environmental Services, Medical, and Safety. The caller should give their name, location, a description of the emergency, and the assistance needed. The caller should stay on the line until all the necessary information is given to the departments answering the call. Only those departments that should respond to the scene of the emergency will talk to the caller. Notification to Gate 1 can be made on the radio emergency frequency. B. Action taken: 1) Security/Fire Protection - Gate 1 Security personnel will announce the emergency on the all area page, and the radio emergency frequency. Security and Fire Protection personnel will respond in accordance with their Department Emergency Plan. 2) Medical/Security Department - if there are injuries, the Medical Department will respond in accordance with their Department Emergency Plan. If the incident occurs after hours or on a weekend, the Security First Responder will respond. 3) Environmental Services/Industrial Hygiene - the person on call will respond according to their Department Emergency Plan, and assess any impact on the environment. 4) Site Emergency Manager - upon being notified by Gate 1 Security personnel, the SEM will decide what the proper response should be. For incidents that have high potential to or have already caused injury to personnel, damage to equipment, off-site impact and visibility, the SEM will activate the Emergency Operation Center, and instruct Security personnel to implement the necessary call lists to get people to the Emergency Operation Center to address the problem. 5) Operating Personnel - after notifying Security of the problem they will activate their Unit Emergency Plan, including: a. Direct emergency responders to the incident location, and assisting in the response. Restricted For Use Within Dow 3/14/91 ^0 A ip-, CO/VFTOfr DOW U.S.A. - LOUISIANA DIVISION EMERGENCY PLAN SECTION A PAGE 25 b. Remove the sources of fuel from the fire if that is the correct approach. Chemical Release, Spill or Leak A. Notification to Gate 1 Security personnel will be made by dialing 333. Phones will ring at Gate 1, Fire Station, Environmental Services, Medical, and Safety. The caller should give their name, location, a description of the release, including what is being emitted, and what category should be assigned to it. Only the Security person at Gate 1 will ask questions of the caller. Notification to Gate 1 can be made on the radio emergency frequency. B. Action taken: 1) Security/Fire Protection - Gate 1 Security personnel will activate "MIDAS", and input information received about the incident. At the same time the incident will be announced over the all area page and the radio emergency frequency. As soon as "MIDAS" has printed out the response scenario, the downwind areas along with the recommended actions will be announced on the all area page and the radio emergency frequency. Security and Fire Protection personnel will respond in accordance with their Department Emergency Plan. 2) Medical/Security Department If there are injuries resulting from the release the Medical Department will respond in accordance with their Department Emergency Plan. If the incident occurs after hours or on a weekend, the Security First Responder will respond. 3) Environmental Services/Industrial Hygiene - The person on call will respond according to their Department Emergency Plan. The responder will determine both the size of and the concentrations in the release. This information will be given to the SEM as quickly as possible. 4) Site Emergency Manager - Upon being notified by Gate 1 Security personnel, the SEM will decide what the proper response should be. For releases that have high potential to or have already caused personnel to be exposed, damage to equipment, off site impact and visibility, the SEM will activate the Emergency Restricted For Use Within Dow 3/14/91 DO A 121474 CONFIDENTIAL DOW U.S.A. - LOUISIANA DIVISION EMERGENCY PLAN SECTION A PAGE 26 Operation Center, and instruct Security personnel to implement the necessary call lists to get people to the EOC to address the problem. 5) Operating Personnel * After notifying Security of the problem they will activate their Unit Emergency Plan, including: a. Direct emergency responders to the incident location. b. Take the necessary action to stop the release. Restricted For Use Within Dow 3/14/91 CHEMICAL EXPOSURE II^DEX AUDIT PRE-AUDIT QUESTIONNAIRE Please check off YES, NO, or N/A (not applicable) for each question. Provide additional details if requested. When was the last CEI review?__1989___________________________ What chemicals were discussed and what were the CEI values? Chemical CEI Please list all chemicals in your plant that exhibit a Chemical Exposure Index (CEI) of 100 or greater. 1.__ CHLORINE_____________________________________________ 5.'________ ;______________________________________________ Please list all chemicals that have spill/release scenarios (neutral atmospheric condition and "EEPG XI") exhibiting a radius of exposure that exceeds the distance from your plant to the public. 1. CHLORINE_____________________________________________ 2_____________________________________________________________ 3_______________________________________________________ EES. NO NLA ___ _X______ Have these scenarios been included in the CAER/MIDAS program? \ Please have appropriate map plots Variable for review at the audit. \ Please list all chemicals that have spill release scenarios (neutral atmospheric condition and "ODOR THRESHOLD X 1") exhibiting a radius of exposure that exceeds the distance from your plant to the public. \ 1. CHLORINE , __________\ 2.J.Z Z.--L --------------------- j--------------------1-- -- -- - 3..-.-----.---------------------------------------------\^----------------------------------------- YES NO. NLA ___ __X_ ____ Have these scenarios been included in the CAER/MIDAS program? Please have appropriate map plots available for review at the audit. DOW CONFIDENTIAL 23 DO CO/v/r 7rof~Nr 4 >6 Tqi CHEMICAL EXPOSURE INDEX AUDIT PRE-AUDIT QUESTIONNAIRE Please check off YES, NO, or N/A (not applicable) for each question. Provide additional details if requested. When was the last CEI review?__1989______________________________________________ _ What chemicals were discussed and what were the CEI values? Chemical CEI CHLORINE HCL 28E &1 Please list all chemicals in your plant that exhibit a Chemical Exposure Index (CEI) of 100 or greater. 1. ..CHLORINE_____________________________________________ 3. Please list all chemicals that have spill/release scenarios (neutral atmospheric condition and "EEPG X 1") exhibiting a radius of exposure that exceeds the distance from your plant to the public. 1. CHLORINE 2. 3. YES NO N/A ___ _X_ ___ Have these scenarios been included in the CAER7MIDAS program? Please have appropriate map plots available for review at the audit. Please list all chemicals that have spill release scenarios (neutral atmospheric condition and "ODOR THRESHOLD X 1") exhibiting a radius of exposure that exceeds the distance from your plant to the public. 1--CHLORINE 2. __HC1_____ 3. _____________ YE_S NO N/A ___ ____X_ __ Have these scenarios been included in the CAER/MIDAS program? Please have appropriate map plots available for review at the audit. EMM 2 92 DOW CONFIDENTIAL 23 DO CoMp- rFNrr( The following pre-audit questions apply to those areas of the operation that process, transfer, or store chemicals whose impact in the event of a release incident would have a significant negative impact on public areas. Impacts on or of immediately surrounding facilities should be considered in a secondary way. A. OPERATING PROCEDURES Yes _X_ No N/A ___ ____ 1. Does the plant have checklists that are used to shut down and clear equipment/piping to insure that the contents are not left in the equipment, or accidentally released into the environment? If the answer is yes: a. Please have documentation available for review at the audit. If the answer is no: b. How is this function accomplished? c. What are the plant's plans for doing this in the future? _X_ ___ ___ 2. Does the plant have checklists that are used for starting up out of service equipment/piping that insures that no raw material, process streams or product will be accidentally released into the environment? If the answer is yes: a. Please give examples and documentation If the answer is no: b. How does the plant accomplish this function? c. What are the plant's plans for this in the future? EMM 2 92 DOW CONFIDENTIAL 24 Oo A . Yes _X_ No N/A ___ ____ 3. X_ 4. XX_ Does the plant have procedures for the initial opening of lines and equipment? If the answer is Yes: a. Please have the documentation available for review at the audit. Does the plant have procedures that define exactly who is responsible for the operation, inspection and maintenance of adjacent and intra-interplant pipelines and associated equipment? a. Do they include normal operations? b. Do they include emergency operations? c. Please have the documentation available for review at the audit* If the answer is no: c. What are the plant's plans for developing these procedures?________________________________ B. PLANT COMMUNICATIONS _X ___ ____ 5 Does the plant have an up-to-date emergency call list? If the answer is no: a. What are the plant's plans for developing one? EMM 2 92 DOW CONFIDENTIAL 25 121479 DO CONF 1 dHNT I At- Yes _X_ _X_ _x_ _x_ No N/A 6. ___ ____ ___ _ ___ -- ___ ____ ___ ____ Does the plant have written notification procedures for the following emergencies? a. Gas Release b. Spill c. Fire d. Emergency Response e. Other If yes to any of the above: a. Please provide documentation at the audit for review. If no to any of the above: f. Describe what the plant's plans are in this area? 7. Does the plant have procedures for establishing contact with Field Headquarters during an emergency? If the answer is yes: a. Please provide documentation at the audit for review. C. AREA MONITORING SYSTEMS _X_ ___ ____ 8 Does the plant use an area monitoring system for toxic materials? If the answer is yes: a. How often are these monitors checked and calibrated? _ONCE PER MONTH. b. Please have documentation available at the audit for review. _X_ ___ ____9. Are plant personnel trained to respond to the alarms from area monitors? If the answer is yes: EMM 2 92 a. What is the frequency of retraining? -- Once per year.___________ _ DOW CONFIDENTIAL 26 DO A 121480 CONFIDENT I Al D. PLANT PIPING SYSTEMS CHLORINE Yes No N/A ___ ___ JL 10. Does the plant monitor corrosion in the piping systems of the facility? If the answer is yea: a. How is monitonne done? b. Please provide the documentation at the audit for review. ___ ___ _X 11. Does the plant have areas in the piping system that requires constant or repetitive repairs? If the answer is yes: a. Please describe what is being done to prevent recurrence. ------------------------JL12 ___ JL 13. Does the plant have a preventive maintenance program in please to monitor the integrity of the piping system? Consider all elements; i.e., paint, insulation, corrosion, supports, shoes, etc. a. Be prepared to discuss this at the audit. Are outside-the-block material distribution systems monitored for leaks? a. How is this done? b. How freauentlv? ___ _ _X__ 14. Do the plant's toxic material distribution systems undergo pressure testing on a routine basis? If the answer is yes: a. How often? b. Please provide documentation at the audit for review. ___ ___ X 15. Do the plant's toxic material distribution systems have prominently displayed phone numbers for notification of problems and emergencies? EMM 2 92 DOW CONFIDENTIAL 27 [)0 A 121 481 CONFIDENTIAL D. PLANT PIPING SYSTEMS HCL Yes No N/A ___ _X ____ 10. Does the plant monitor corrosion in the piping systems of the facility? If the answer is yes: a. How is monitoring done? b. Please provide the documentation at the audit for review ___ _X ____ 11. Does the plant have areas in the piping system that requires constant or repetitive repairs? If the answer is yes: a. Please describe what is being done to prevent recurrence. _X_ ___ ___ ___ 12. ___ .NZA13. Does the plant have a preventive maintenance program in please to monitor the integrity of the piping system? Consider all elements; i.e., paint, insulation, corrosion, supports, shoes, etc. a. Be prepared to discuss this at the audit. Are outside-the-block material distribution systems monitored for leaks? a. How is this done? b. How frequently?. _X____ _______ 14. Do the plant's toxic material distribution systems undergo pressure testing on a routine basis? If the answer is yes: a. How often? WHEN EVER REPAIRED. b. Please provide documentation at the audit for review. ___ ___ __ 15. Do the plant's toxic material distribution systems have prominently displayed phone numbers for notification of problems and emergencies? EMM 2 92 DOW CONFIDENTIAL 28 DO A 12148? CONFIDENTIAL E. PLANT MECHANICAL EQUIPMENT Yes No N/A 16. What kind of pumps does the plant use in toxic service? GOULDS EQR HCL ONLY. NO CHLORINE PUMPS _X_ ___ --__ 17. Are these the kind of pump systems that will minimize leak potential? (i.e., tandem or dual seals, sealess pumps, etc.) ___ ___ ____ If not can they be? ___ _X_ ____ 18. Does the plant have a preventive maintenance program in place for mechanical equipment? If the answer is yes: a. Please have the documentation available for review at the audit. If the answer is no: b. What are the plant's plans to develop one? The only pm done on the acid pumps are changing of oil which is already done on a routine basics Developing a maintenance plan F. TRAINING FOR EMERGENCY RESPONSE _x_ _x_ _x_ _x_ _x_ -- - _X_ 19. ----- --- ----- ---- ----- _------- ------ . ----- ---------- . X X ___ ____ 20. Have the scenarios for chemical spills and gas releases, that have the most probable chance of occurring, been reviewed with: a. Plant operators/technicians? b. Supervision? c. Other affected employees? d. Process Engineering (CEINDEX Program)? e. Safety and Loss Prevention? f. Environmental (data of MIDAS system)? g- Adjacent plant supervision? Security Have your reviews included all possible scenarios that would be deemed "major releases", affecting the public beyond the Dow fence line? EMN1 2 92 DOW CONFIDENTIAL 29 DO A 121483 CONF IOFNTJqi Does the plant conduct routine, periodic "what if" emergency drills on the release of toxic chemicals? a. Is each shift involved? b. Do supervisors participate? If yes, w hat level of supervision? Everyone in the block participates.* c. year. d. Is there a regular schedule for these exercises? Twice per Is Industrial Security involved in these practice drills in any way? If yes, in what wav? They sometimes set them up and participate______________________________________________ e. How often are drills conducted? Staff - Twice/year Shifts once per quarter f. When was the last time your plant had a planned emergency drill involving the release of a toxic gas or liquid? 6-91 Staff: 12/91 for operations g. What chemical was used in your last planned emergency dril1 ? Chlorine____________ h. Have you used different toxic or odorless chemicals in previous drills? No, chlorine and HC1 are the only two Does the plant have a formalized training program for those people who conduct periodic inspections of concerned facilities? (Example: weekly pipe inspection checklist, what to look for, etc.) How do you insure that "lessons to be learned" from incident investigations are passed on to all concerned personnel? Lessons to be learned are passed on through new procedures. Procedures are passes around ; operators sign them. DOW CONFIDENTIAL 30 DO A 121484 CONFIDENTIAL Does the plant have written procedures detailing how to mitigate releases of toxic chemicals in the plant? (Examples: pump to another tank, apply foam, drive a wooden peg, etc.) HC1-YES; CHLORINE-NO If the answer is yes: a. Does the plant periodically train operating personnel on these procedures and methods for mitigating liquid spills or gas releases from the facility? If yes, how often? ANNUALLY FOR HCL If yes, how is the training documented? TRAINING SUPERVISOR b. Please provide at least one example for review at the audit. Has the plant reviewed its emergency response personnel protective equipment inventory with Industrial Hygiene? (appropriateness, types, numbers, etc.) Does the plant have sufficient quantities of emergency response personnel protective equipment on hand to satisfy the need in the event of a major emergency? If the answer is yes: a. Is it kept at strategic locations for ease of access in case of an emergency? Are there checklists employed for the periodic inspectionmaintenance. and testing of the plant emergency equipment? (ammonia curtains, foam deluge systems, and fire monitors) If the answer is yes: a. How often? b. Who does it? If the answer is no: c. Please discuss the plant's plans. SECURITY DOES THIS FOR POWER 1/UTILITIES DOW CONFIDENTIAL 31 DO A 121485 CONFIDENTIAL Yes No N/A _X_ __ 28. 29. _X_ _ 30. _x_ __ _x__ __ _x_ __ _x__ _x_ __ Are plant personnel trained in the proper use of the various personnel protective equipment employed for combatting liquid spills, gas releases, and fires? If the answer is yes: a. How often? ANNUALLY b. How is this training documented? ANNUAL HEALTH DAY How many people are involved in training on the proper emergency response to a liquid/vapor chemical release of concern? a. Operators/technicians b. Supervision (all levels) c. Others d. Total of above all - _______ all Have you consulted with neighboring plants immediately surrounding your facility to determine the effects of spills/releases by them on your plant and personnel? If the answer is yes: a. Do you have the proper type of personnel protective equipment if your plant is downwind of a spill or release from those facilities? b. Sufficient quantities of equipment? c. Is this equipment inspected or checked periodically? If yes, how often? SCBA'S Once Per Year; Resp. 2/year. d. Do you train your plant personnel on how to respond when exposed to a gas released from an adjacent plant? If yes, how often? Annually e. Do you participate in emergency drills when hypothetical releases originate in plants other than your own? If yes, how often? Annually If the answer is no to #20: Please describe what the plant does in the event of one of these emergencies, and future plans. EMM 2 92 DOW CONFIDENTIAL 32 D0 A 121486 CONFIDENTIAL ELECTRICAL 5PT. AUDIT cfsc <x <'-f i--i~t Uj <r S n^ oo u