Document 7YZvLXqVXkY1Mx3JOQLJzbgj

LfDinasasmsi aTasad&m Chemical Exposure Index March 1991 Dow Confidential rn^A 04?506 CONFTOFNT7AI. 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 HO A 042507 OONFTOFNTTAl Guide for a Chemical Exposure Index Audit DO A 042508 CONFTDFNTTAl LOUISIANA DIVISION MARCH, 1991 Dow U.S.A The Dow Chemical Company P.0 Box 150 Plaquemine, Louisiana 70765-0150 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. 8163, 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 40509 CQNF ^FNTIAI CHEMICAL EXPOSURE INDEX AUDIT PURPOSE To review potential release scenarios with a CEI 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 042510 r.ONFj DFNTJAl. 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 CONCERN Only the area(s) of your operation which has a calculated Chemical Exposure lndex(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. LIST 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 CE INDEX PROGRAM FOR CEI AND DISPERSION FOR EACH SCENARIO WITH A CEI GREATER THAN 100 OR THOSE WITH AN ODOR PROBLEM. 2 Oo oo/vp- A 4?Sii ro/vr.rAl 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 FOR 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 DO A 04P51? 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 plant's 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 DO A 042513 CONFTDFNTTAL 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 COMf ?4?514 rDFNTTA|. 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/CEI audit. However, names will be held in confidence. NOTE: All questions are not applicable to all 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 plants 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? oo CO/VP A 4?Sle 6 Tt)^TT4L 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 CEI 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 CEI 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 CEI is calculated for three areas of concern: 1) Public, 2) Other Dow facilities and 3) Other businesses. The CEI 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 CO/MF A D4?s16 f DFMt T Al. 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.11s The program is set up to read and write either metric or british 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 CEINDEX 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. @1395$R00T:[DISPJCEINDEX 8 fto CO/vjcr0f-^rrA( 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**2 / 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. 2) 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 DO A 04P518 OONFIDFNTIAL 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.lis). 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 15.0 and are also supplied with the CEI audit information. Documentation will be maintained by the H&ES Information Center. 6.0 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 INDEX 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. V, 10 00 A 042519 CONFTDFNT TAl 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 process conditions which could generate large amounts of vapor in relatively short periods of time. The two largest driving forces are 1) pressure or overpressure (1e, 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:[DISP]EVAP_HELP.TXT Other methods are included in the "Chemical Exposure Index" manual. li DO A 042520 CONFIDFNTTA1 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 meterological 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 meterological conditions so that the affected area can be determined. Atmospheric turbulence can be divided Into two groups, mechanical turbulence and convective turbulence. Mechanical turbulence is generated by fluctuations In wind direction and the motion of the air In response to surface roughness (ie, 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 Is 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' condition 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 DO A 04?5?1 CONFIDENTIAL 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 (Ib/s) g - Gravitational constant, ft/s**2 Umax - Maximum velocity, ft/s NOTE: To determine the vaporization rate of liquid spills See section 10.0 B. 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*Di*(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/in**2 Umax - Maximum velocity, ft/s ## NOTE: If compressible fluid, and 0.5*(H upstream) > (H downstream) then dH - 0.5*(H upstream) 13 DO A 0425?? CONFTDFNTTAI EEPG AND OOOR THRESHOLD VALUES FOR THE CEI 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. use 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 list. 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 042523 CONFIDENTIAL. -^0^ THE DOW CHEMICAL COMPANY November 29, 1990 . .. EMERGENCY PLANNING GUIDELINES: EEPGs AND ERPGS Attached is a complete updated list of EEPGs and ERPGs. There have been many requests for these values for use in the Chemical Exposure Index (CEI) calculations being done globally for ail chemicals at each Dow plant. Since there are relatively few of 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. 3. Use the workplace exposure guideline (Dow IHG, ACGIH TLY or AIHA WEED as the basis for 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. If no workplace guideline exists, reconsider the need for an EEPG value or CEI calculation. Is there sufficient vapor pressure and volume tor 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 for the CEI calculation but will need to know the vapor pressure or the chemical. Please distribute this information, as needed, within your area or responsibility. It is important that the various Dow locations use consistent emergency guideline values for the same chemicals. If you have questions about this recommended approach, let me know. v Marlene G. Swank Health & Environmental Sciences 517/636-3976 Attachment 15 00 A 04?^4 ccWtdcnttal EMERGENCY PLANNING GUIDELINES: ERFGs AND EEPC.s chemical ERPG.-1 Acetone cvanohvdrin Acrolein Acrylic acid Acrylonitrile Allvl chloride** Ammonia Bromine Butadiene n-Butylisocvanate Carbon disulfide Carbon tetrachloride Chloracetvl chloride Chlorine Chloroform Chloropicrin Chlorosulfonic add Crotonaldehvde Diketene Dimethylamine Epichiorohydrin Ethyl chloride Ethylene dichloride Ethylene oxide Formaldehyde Hexachlorobutadiene Hydrogen bromide Hydrogen chloride Hydrogen cyanide**' Hydrogen fluoride Hydrogen sulfide Isobutyronitrile Methacrvlonitrile Methyl iodide Methyl mercaptan Monomethylamine Perfluoroisobutvlene Phenol Phosgene Phosphorus pentoxide Propylene oxide 0.1 ppm 2 ppm -- 300 ppm 25 ppm 0.3 ppm 10 ppm -- 1 ppm -- 0.1 ppm 1 ppm -- NA+ 1 mg/m^ 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 ERFG-2/EEFG* 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 5 mg/m3 10 ppm 5 ppm 100 ppm 20 ppm 5000 ppm* 100 ppm* 50 ppm* 10 ppm 10 ppm 5 ppm* 20 ppm 10 ppm 20 ppm 30 ppm 100 ppm 10 ppm* 50 ppm 25 ppm 100 ppm 0.1 ppm 50 ppm 0.2 ppm 25 mg/m3 500 ppm* EBEGv 3 ppm 250 ppm -- 3 ppm 1000 ppm 4 ppm 5000 Dpm -- 1000 ppm -- 20 ppm 20 ppm -- 3 ppm 100 mg/m3 50 ppm 50 ppm 500 ppm 100 ppm -- 25 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/m3 DO A 04?5?S CONFJDFNTTAI SOME CHEMICAL EXPOSURE INDEX (CEI) HEALTH HAZARD SCALE NUMBERS FOR CHEMICALS WITH NO EEPG/ERPG Chemical Acetic add Acrvlamide 4 Ally! chloride 3en2ene Biphenyl Butene Butylene oxide Chlorodifluoroethane (Isotron 142B) Chloromethvl methyl ether Chloroprene Cyclohexane Cvclohexanol Cyclohexanone DEPCT Diaminopropane Dichlorobutene Dimethyl ether Dimethyl sulfoxide Dinoseb 1.4-Dioxane Diphenvl oxide DOWCO* 429 . Ethyl aaylate Ethyl chloroacetate Ethylbenzene Ethylenediamine Gasoline Hvdroxvethvl acrylate 4 *m * Isocyanatoethyl methacrylate IsoAoroD vol chioroformate Isopropylamine Methanol Methyl chloride Methyl chloroacetate Methyl chloroform Methyl methacrylate Methylene chloride Perchloroethylene Health Hazard Scale Number* 1 1 3 2 1 T 2 1 4 17 . 1 1 1 1 1 2 2 0 1 1 1 1 -> *7* 1 1 1 1 1 3 3 * 3 2 1 1 1 1 EMERGENCY RESPONSE PLANNING GUIDELINES American INDUSTRIAL HYGIENE ASSOC IATIO The Emergency Response Planning Guideline (ERPG) values are intended to crovide estimates of concentration ranges wnere one mignt reasonaoiy anticioate ooserving adverse effects as aescnoeo in tne definitions for ?.PG-*<. ERPG-2. ano ERPG-3 as a consequence of exposure to tne soecific suostance. The ERPG-1 is the maximum airoorne concentration oelow wnich it is oelieveo that nearly all individuals could be exodsed for uo to i nr without experiencing otner than mild transient adverse neaitn effects or perceiving a clearly defined objectionaoie odor. The ERPG-2 is the maximum airbdrne concentration below wnich it is believed that nearly ail individ uals couid be exooseo for uo to t hr witnout experiencing or developing irreversible or other serious neaitn erfects or symptoms tnat could impair tneir abilities to taxe protective action. "he ERPG-3 ,s tne maximum airporne concentration oelow wmcn it is believed that nearly an individuals could be exposed for ud to t hr witnout experiencing or developing life-threatening .neaitn effects. i The committee recognizes (ano all wno make use of these values snouid rememoeri tnat human responses do not occur at precise exposure levels but can extend over a wide range of concentrations. Th values derived for ERPGs snouid not be expected to protect everyone but snouid be applicable to m st individuals m tne general population. In all populations there are nypersensittve individuals wno wui show adverse responses at exposure concentrations far below levels wnere most individuals would normally resoonc. Furthermore, since these values nave oeen denveo as planning ano emergency response guidelines, not as exposure guidelines, they do not contain the safety factors normally incorp rated into exposure guidelines, instead, they are estimates, oy tne committee, of the thresnolds above wmcn there would be an unacceptable likelihood of observing the defined effects. The estimates are based on tre available oata summarized in tne documentation. In some cases wnere the data are limited, tne uncertainty of these estimates is large. Users of tne ERPG values are strongly encouraged to review carefully tne documentation before applying tnese values. in developing tnese ERPGs. human expenence has been empnasizeorto the extent data are available. Since this type of information is rarely available, however, and. when available, usually is only for i w level exo sures. animat exposure data most frequently form tne basis for tnese values. The most pertinent information is derived from acute inhalation toxicity studies that nave included clinical observations ana ntstooatnoiogy. The focus is on tne highest levels not snowing the effects described by tne definitions of tne ERPG ieveis. Next, data from repeat innaiation exposure studies with clinical observations and histo- oathoiogy are considered. Following these m importance are tne basic, typically acute, studies wnere mortality is tne major focus. When inhalation toxicity data are either unavailable or limited, data from studies involving other routes of exposure will be considered. More value is given to tne more rigorously 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 mecnamstie or aose-resoonse data are available, tr-ej are applied, on a case by case basis, as appropriate. V ,. it is recognized that there is a range of times that one might consider for tnese guidelines: however, it wasth committee's decisi n to focus its efforts on only one time period. This decision was bas don tne availability of toxicology information and a reasoned! estimate for an exposure seen**TM I l*M cno setoextrao late these values t othertime periods are cautioned! reviewthe 00 A 042526 since suen extrap tati ns tend to hold only over very limited time frames, if at all. confident ial 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 SE-EEPG, D-ODOR 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 THRESHOLD 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 !ODOR THRESHOLD D IE-EEPG, D-ODOR THRESHOLD L IG-GAS RELEASE, L-LIQUIO SPILL 840.000000 {TOTAL DISCHARGE QUANTITY 15.000000 {RELEASE DURATION 0.000000 {SOURCE HEIGHT 200.000000 1SPILL 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 fyp- C. EXAMPLE OUTPUT FILE FOR AN EEPG CONCENTRATION RUN *********** DOW CONFIDENTIAL ****** 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 VALUE 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 SFOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** 20 DO A 047SP8 CONFIDENTIAL V ****** 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) 0 ground level - 0 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 CONDITION 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. ** FOR INTERNAL DOW USE ONLY ** ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** 21 DO A 04?5?9 CONFIDENTIAL D. EXAMPLE OUTPUT FILE FOR AN ODOR THRESHOLD RUN ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DISPERSION SUMMARY FOR ODOR THRESHOLD RELEASE SCENARIO: A RELEASE FROM A CHLORINE CYLINDER DATE: 16-N0V-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 (feet) @ 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 DISPERSION MODEL 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 MODERATE/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 ***** 00 A 047530 22 CONFIDENTIAL 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?____________________________________ What chemicals were discussed and what were the CEI values? Chemical CEI Please list ail chemicals in your plant that exhibit a Chemical Exposure Index (CEI) of 100 or greater. 1. 2. 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. 2. 3. YES NO N/A ___ ______ ________ Have these scenarios been included in the CAER/MIDAS 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 XI") exhibiting a radius of exposure that exceeds the distance from your plant to the public. 1._____________________________________________________________________ 2. 3.____________________________________________________________ YES NQ N/A. ___ ___ ____ Have these scenarios been included in the CAER/MIDAS program? Please have appropriate map plots available for review at the audit. 23 oo A 04;>^ T^NTJAI 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 ui m m ___ _ ___ 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 ves: a. Please have documentation available for review at the audit. If the answer is na: b. How is this function accomplished? c. What are the plant's plans for doing this in the future?___________________________________ _____ 2. Does the plant have checklists that are used for start ing 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 1$ ves: a. Please_o1ve examples and documentation. If the answer Is q&: b. How does the plant accomplish this function? c. What are the plant's plans for this in the future? 24 A 04?^, conf^nt',a, li Nfi NZA ___ __ ___ 3. Does the plant have procedures for the initial opening of lines and equipment? If the answer is ves: a. Please have the documentation available for review at the audit. 4. Does the plant have procedures that define exactly who is responsible for the operation, inspection and main tenance of adjacent and Intra/interplant pipelines and associated equipment? If the answer is ___ ___ 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 ug: c. What are the plant's plans for developing these { procedures? 8. PLANT. COMMUNICATIONS ___ __ ___ 5. Does the plant have an up-to-date emergency call list? If the answer Is nfl: a. What are the plant's plans for developing one? 25 DO A 043533 GONFTDENTT At. Nfl NZA 6. Ooes the plant have written notification procedures for the following emergencies? a. Gas Release b. Spill c. Fire d. Emergency Response e. Other If to any of the above: a. Please provide documentation at the audit for review. If ng 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 ves: a. Please provide documentation at the audit for review, C. AREA MONITORING SYSTEMS ___ __ ___ 8. Does the plant use an area monitoring system for toxic materials? If the answer Is ves: a. How often are these monitors checked and calibrated? b. Please have documentation available at the audit for review, 9. Are plant personnel trained to respond to the alarms from area monitors? If the answer Is ves: a. What Is the frequency of retraining? 26 DO A 042534 OONFTDFNTTAl D. PLANT PIPING SYSTEMS Yes NO N/A 10. Does the plant monitor corrosion in the piping systems of the facility? If the answer is ves: a. How is monitoring done? b. Please provide the documentation at the audit for rmsa11. Does the plant have areas in the piping system that requires constant or repetitive repairs? If the answer is ves: a. Please describe what is being done to prevent recurrence. 12. Does the plant have a preventive maintenance program in please to monitor the Integrity of the piping system? Consider all elements; l.e., paint, insulation, corro sion, supports, shoes, etc. a. Be prepared to discuss this at the audit. 13. Are outslde-the-block material distribution systems monitored for leaks? a. How is this done? b. How frequently? 14. Do the plant's toxic material distribution systems undergo pressure testing on a routine basis? If the answer Is ves: a. How often? b. Please provide documentation at the aud1t_fsr review. 15. Do the plant's toxic material distribution systems have prominently displayed phone numbers for notification of problems and emergencies? 27 DO A 043535 CONFIDFNTIAL E. PLANT MECHANICAL EQUIPMENT Yes No N/A ___ __ ___ 16. What kind of pumps does the plant use In toxic service? 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? 18. Does the plant have a preventive maintenance program in place for mechanical equipment? If the answer is ves: a. Please have the documentation available for review at the audit. If the answer Is nfl: b. What are the plant's plans to develop one? F. TRAINING FOR EMERGENCY RESPONSE 19. 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? ___ __ ___ 20. Have your reviews Included all possible scenarios that would be deemed "major releases", affecting the public beyond the Dow fence line? V 00 A 04?53f> 28 OONF I DFNTIAl vs* mm 21. 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 yfis, what level of supervision? c. Is there a regular schedule for these exercises? d. Is Industrial Security involved in these practice drills in any way? If ves. in what way? - . - - e. How often are drills conducted? f. When was the last time your plant had a planned emergency drill Involving the release of a toxic gas or liquid? g. What chemical was used In your last planned emergency drill? h. Have you used different toxic or odorless chemicals in previous drills? 22. 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.) 23. How do you Insure that "lessons to be learned" from Incident investigations are passed on to all concerned personnel? _____ 29 DO A 04?537 OONF T DFNT I At M Nfl NZA 24. Does the plant have written procedure! detailing how to mitigate releases of toxic chemicals In the plant? (Examples: pump to another tank, apply foam, drive a wooden peg, etc.) If the answer Is ves: a. Does the plant periodically train operating personnel on these procedures and methods for mitigating liquid spills or gas releases from the facility? If yi, how often? _____ If y, how is the training documented? b. Please provide at least one example for review at the audit. 25. Has the plant reviewed Its emergency response personnel protective equipment Inventory with Industrial Hygiene? (appropriateness, types, numbers, etc.) 26. 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 a. Is It kept at strategic locations for ease of access in case of an emergency? 27. Are there checklists employed for the periodic inspection, maintenance, and testing of the plant emergency equipment? (ammonia curtains, foam deluge systems, and fire monitors) If the answer is ves: a. How often? __ b. Who does it? __________________________________ If the answer Is gg: c. Please discuss the plant's plans. i 30 00 A 04?538 CONFIDENTIAL