Document 4aD1mr6VqZMa1jvZ80y6vjV6p

LOSS PREVENTION AUDIT Page 43 Mechanical Integrity MANAGEMENT SYSTEMS REFERENCES: OSHA Process Safety Management (1910.119, Paragraph!) A .1. Yes [X] No Do you have written procedures to assure on-going integrity of process equipment? (i.e., pressure vessels, EBV's, fire protection systems, etc.) Plans: Procedures in plant library contain operating discipline that addresses this. Also, the Pressure Vessel Group's records contain this information. A 2. Yes [X] No 0 Are the employees involved in maintaining the on-going integrity of process equipment given an overview of the process and its hazards, and trained in the procedures applicable to their job. Plans: In-Plant Training (IPT) for each operator and staff member currently being done. A 3. Yes [X] No Q Do inspection and testing procedures follow Dow site or Division guidelines? Plans: Inspections and tests are performed by a centralized group in the division that functions according to site guidelines. A 4. Yes [X] No Q Do the frequency of inspections and tests of process equipment meet accepted Dow site or Division guidelines? Plans: See answer above. A 5. Yes [X] No D Are all inspections and tests documented as per Dow guidelines? Plans: Pressure Vessel Group documents and plant receives copies. (Revised 02/18/94; cmk) 3/28/95; LAD:bwb DO A 04771? OONFTDFNTTA l LOSS PREVENTION AUDIT Page 44 _______ A 6. Yes [X] No Q Are suspected deficiencies corrected in a safe and timely manner after necessary means are taken to assure safe operations. Plans: Deficiencies are noted and relaved to the plant to correct at the earliest possible time. A 7. Yes [X] No In the construction of new plants and equipment, is equipment fabricated according to Dow site or Division standards and suitable for the process application for which they will be used? Plans: Plant piping and equipment material specs are followed. A 8. Yes [X] No Q Are appropriate checks and inspections performed to assure that equipment is installed properly and consistently with design specifications? Plans: Management of Change program is in place. B 9. How do you assure that maintenance materials, spare parts and equipment are suitable for the process application for which they are being used? Some parts are color-coded. All are tagged for the job they will be used on. Titanium parts are stored separately, MOC process is followed. Plans: Working on adopting chlorine plant procedure to lock-up small titanium parts and to positively identify unlabeled parts with MTS's Texas Nuclear Device as necessary. B 10. How do you assure the proper materials of construction are used in maintenance and new projects? Plans: Plant piping and material specs and MOC program. (Revised 02/18/94; cmk) 3/28/95; LADibwb DO A 04 770 3 CONFTOFNTTAI LOSS PREVENTION AUDIT Page 45 B 11. Yes [X] No D Do you have a list of the proper gaskets for each part of your process? (LPP 6.6) Plans: Included in piping and equipment specs. Yes [X] No Q Is gasketing covered in your piping specification? (Revised 02/18/94; cmk) 3/28/95; LADrbwb 0*77'4 DO ^ cot'*'" '