Document 82Qn8pBgQgoknK6ZLqdaQOaqa

CHLOR - ALKALI 2 1994 REACTIVE CHEMICALS REVIEW MAINTENANCE PROCEDURES MAINTENANCE i METALS: Dry Chlorine Service: Service where materials will be in contact with chlorine where the moisture content is less than 5 PPM water by weight in chlorine. Recommended Materials: Carbon Steel - Safe at temperatures less than 155 C (311 F) Iron - Safe at temperatures below 175 C (347 F) Filter Elements - wound fiberglass and sintered metal are -- recommended. Avoid polypropylene and organic materials they react with chlorine. Dry chlorine reacts violently with hot steel O No welding on chlorine lines that have not been isolated and depressured Welding cables must not be clamped to chlorine lines WARNING: At ordinary temperatures, dry chlorine reacts with: 0 METALS.DOC Aluminum Arsenic Gold Mercury Selenium Tellurium Tin TilaniUm Dow Confidential 00 A 0?95,4 CONFIOENTIA! 09/29/94 MAINTENANCE \ METALS: Wet Chlorine Service: Recommended Materials: Titanium - High resistance to wet chlorine gas The amount of water necessary to prevent a chlorine - titanium reaction will vary with temperature and pressure Note: Titanium is highly reactive with dry chlorine gas and liquid chlorine Storage: Titanium equipment and materials are clearly identified (purple paint) and stored in a designated area in CA - 2 warehouse. This area is separated from other parts and locked. Material controller is responsible for this area. METALS.DOC Dow Confidential DO A 029595 CONFIDENTIAL 09/29/94 MAINTENANCE METALS: Caustic Service: Service where materials will be in contact with caustic varying in concentration from 8.5% to 50%. Note: High corrosion rates will be caused by elevating temperatures and / or concentrations. . Recommended Materials: Carbon Steel pipe - 8.5 % caustic less than 150 F and strong r concentrations of caustic below 120 F Nickel pipe - Concentrations above 8.5 % with a temperature greater than 120 F Aluminum, Zinc, Tin and Copper are rapidly attacked by caustic and their use should be avoided. Miscellaneous Applications: Heat Transfer Materials - Hot water and steam are recommended for heat transfer applications. Avoid organic materials that react with chlorine. METALS.DOC Dow Confidential OO A 029596 OONFlbE'NTT AL 09/29/94 MAINTENANCE I \ Cleaning / Purging Equipment and Lines: Chlorine: Hot water or steam is recommended over solvents Preferred solvent for cleaning chlorine equipment is carbon tetrachloride Purge chlorine systems with dry air or nitrogen - take necessary precautions to prevent contaminating an instrument air system when using dry air Dry all chlorine equipment with nitrogen to a dew point of - 60 F Caustic: All materials to be thermal cut, heated or welded should be washed with 3% (1 N) HCI (This includes post weld heat treatment area). Rinse with water after acidizing. Sandblast inside and outside of pipe or material in the area where cutting, welding or postweld heat treatment will take place. Re-acidize and rinse area as per above steps. A Dow employee should test the material with litmus paper or phenolphthalein to assure that it has been cleaned and rinsed properly. The pheno. will turn from a clear liquid to a pink to purple color when caustic is present. DO A 0P'9597 CONFIDENTIAL CIEANING.DOC Dow Confidential 09/29/94 MAINTENANCE Lubricants: Non - Saturated hydrocarbon based oils and greases react violently with chlorine under moderate to extreme operating conditions. Only APPROVED lubricants will be used for chlorine service. Approved lubricants for chlorine service at CA - 2 include: Greases: Fluorolube GR 544 (Sealant for gaskets) Climax FL - 5 Oil: Fluorolube FS - 5 Approved Multi - Purpose usage lubricants for CA - 2 include (NOT to be used for Chlorine service): CA II Caustic 1 REGAL 68 EP-2 REGAL CAP32W LUBRIPLATE EMB MARFAK #2 Multi Fax Grease Mobil Lubri-Mist Koppere Grease Mobil SHC-634 (Synthetic Lub.) MF EP2 Grease FGL-2 (Food Grade) MN EP2 Add Grease Grease (Mobil - Exxon - Texaco) MO Mist 2 Merpa 220 REGAL 32 REGAL 68 Perma 6 Cartridge R220 Seal REGAL 100 REGAL 150 Regal R & O 32 REGAL 220 Oil Slipkote Grease Sullube Oil Ml 50 Meropa 650 T Sample FMO-2400AW Super FGL-2 EP-100 _ DO A 029598 CONFIDENTIAL LUBES.DOC Dow Confidential 09/29/94 Chlor-Alkali 11/Caustic Reactive Chemicals Review Key Potential Reactive Concerns and Prevention Systems 1) Chlorine/Hydrogen Explosion Prevention Scenario 1 - Low anolyte level >> Generator trips @ 2 inch level 2 level TX's and low level carbon probe - critical instruments ModS voting logic - 2/3, 2/2, 1 Scenario 2 - Excessive cell header vacuum Chlorine Compressor Trips if..... 1) CHP reaches 9.5 in H20 vacuum (instantaneous) 2) CHP reaches 8.0 in H20 vacuum for 10 seconds 3) CHP less than 8,0 in H20 vacuum twice within 2 minutes >> Triple redundant pressure TX's - critical instruments >> ModS voting logic Vacuum Breaker mechanical relief at 6.0 in H20 vacuum Scenario 3 - High Hydrogen in Tailgas Generator runback @ 4.75% (20 second delay) until cone. < 3.75% Generators will runback to 0 KA Triple redundant H2 analyzers - critical instruments >> Mod5 voting logic Scenario 4 - Hydrogen Backflow from H2 train to Cells Discharge EBV closes upon H2 compressor trip T-206 will vent gas in train Individual stacks at cells backup T-206 PREVENT.DOC Page 1 of 3 Dow Confidential DO A 029599 CONFIDFNTTAL EMH 9/28/94 Chlor-Alkali ll/Caustlc Reactive Chemicals Review Key Potential Reactive Concerns and Prevention Systems 2) Chlorine/lron Fire Prevention Scenario 1 - High 2nd/3rd stage compressor discharge temperature Compressor trips @ 32$ F on either stage Triple redundant temperatures on each stage Mod5 voting logic 3) Hydrogen/Oxygen Explosion Scenario 1 - Low H2 compressor suction pressure/ 02 intrusion H2 compressor trips if..... >> Greater than 0.5% oxygen in H2 or.... Low suction pressure on 4 pressure TX's * Less than 1.5 inches H20 vacuum (2 sec delay any TX) * Greater than 0.3 inches H20 pressure (2 TX's furthest from suction) * Greater than 0.125 inches H20 pressure (2 TX's closest to suction) 4) Titanium/Dry Chlorine Fire Scenario 1 Use of titanium parts in wrong service Titanium parts storage policy >> Limited titanium usage at CAM (E-201/202 tubes, wet CI2 gas scrubber internals) Water and brine flow TX's to E-201/202, flow alarms, automatic backup >> Mod5 controls protect against dry CI2 backflow PREVENT.DOC Page 2 of 3 Dow Confidential oo * cov-tf EMH 9/28/94 Chlor-Alkali 11/Caustic Reactive Chemicals Review Key Potential Reactive Concerns and Prevention Systems 4) Nitrogen Trichloride Decomposition Scenario 1 - High N2 compounds in brine >> Monitor nitrogen compounds in brine - treat with HOCL Scenario 2 - Excessive NCI3 levels in taffy Comprehensive Mod5 taffy pot/purification reboiler controls Scenario 3 - Buildup of "heavies" in CI2 Evaporators >> Automatic purging (popping) of all CI2 evaporator exchangers PREVENT DOC Page 3 of 3 Dow ConMontM Q79601 cDohfto^tt.al EMH i/26/94 SUPERVISORS INVESTIGATION OF ACCIDENT/INCJDENT - S-305 PRELIM ALREADY SUBMITTED B PRELIMINARY FINAL DOW CHEMICAL U.SA. LOUISIANA DIVISION SUPERVISOR'S INVESTIGATION OF ACCIDENT/INCIDENT L-63 (REV. 11-91) RECORD 9258 *C 'NTRACTOR O ..iTC 0 RWC tt............. 0 DAW # ....... ..... B PSA $50000 PD qOOW 0 FIRST AID 0 injury prevente q PRECAUTIONARY o ILLNESS ACCIDENT CLASSIFICATION INDUSTRIAL MEDICAL _____ NON INJURY...X... ^I'lp STANDARD VIOLATION __________ DATE OF ACCIDENT: _...12/a/92._ TIME OF ACCIDENT: ....3:Q0AM.._ DATE INVESTIGATED: --12.1JB/93.,, ENVIRON.______ RxCHEM.______ DATE REP SUBMITTED: ...-1/.18/93... Block and Location of Accident BI.Q.Ck.26..Ghlo.r.:Alkalj..Jl, Name of lnjured\lnvolved Employee None_______________ .Cjeli.Ar.e.a___________________ __________ Clas* _______N/A___ Time at Dow (Mos). ______N/A_____ Master No.___________ N/A. Contractor Involved/Supervisor .None__ Time on Job (Mos.) ______ N/A______ Chemical Released (Environ/RxChem only) None. Pounds, PPM (Environ/RxChem only) N/A_____ Accident/Incident Description (10 Words or Less) .Chlar.in.e..cell.hy.droge.n.outI.et pIug8ed.w/sto.pRer........... ..... Accident/Incident Description (Full) App.roximaiely,.l.0.h.ours.Jafler..siartup..of.the..cliloj:ine.CircuitAl..an,.oper.ator..djsc.oyexed.hydroa.en.fis.caping..fr.om.the..,,,...... ..... causiic..side.Qf..a.ctilQriiie..cell..on..S^_Qnihls..typej3f..Sr.ie.s..tha.tiy.clro8.enisjptende.d..tQ.es.capeir.om.ttie.hy.di:o8en___ ____ Copposite..side)..side..Qf.the.ceil.ttir.o.ugli.ajsepar.atB.pQil.,,H.yctrDgea.exilingJhe..cell.lhr.ouflh..tfie,caustjc.sidejs.an ------------------- indicat).on.of.plug8ing..on.the.,hydr.05.en.idfi..aj[)djsjnQrma)ly.jcoxrecle.d.by.."JX)ddino.Dul"tbB.hy.dro8en.putl.et.pip.e------------------ vyhjJfi.prep.arina.tQ.dp.tliis..on.lhis,particuiax.cell..ihft.liydr.ogenxiu.tletp)pej/v!as.fo.undia.b.e..brQken.and.separated..,,A..... ..... . rubb.eistopp.er..bad.beeiipia.ced..intQ.thfi..Qpari.ejnd.Df.the.drPkaapip.e..opJlie..cfilLside.,,.This.rQrces..the..hydroflen.to.-------------- exillbfi.cbiorine.ceJltJnr.ough.tbfi..caustjc^ide...Ibisjr.eatlyjncr.eases.Jlbe.jcbanCES-Of.hydrog.en.fintenng..tlie..cbtar.in.e ----------c.Qmpartmeat.Qf..a.c.ellivJnich..can.rasultjn.a.hydj:paen/cWorinexplQsion...Jhe.stDpp.er..was.xemQYed...the.piping ----------------- ,r"-9pecied..an.d..the..op.eratiQn.Qf.ibe..cll.was..relurned..tojiQanal...ltjs..unkno.wn.as..tQ.wbo..insta)l.ed.lb.e..sloppe/. ----------------a--i.jt.was.ms.talle.d..Qr..wby RESULTS CLASSIFICATION (List all that apply with code number and description from back page) ACCIDENT / INCIDENT INJURY SSS.QTHERfReactiye.Chemicals.Concfim.None____________________________ _____ BODY PART N/A---------- ---- ------------ JOB BEING PERFORMED (List one from Group I and all that apply from Group J40..OPERAT1QN./.RO.UIINE__________________________________________________________ fl75.0PRAT10N./..STARXUP..___________ __________________ _________________________ CAUSES (List all that apply with code number and description from back page) AT TIME OF ACCIDENT PRE-EXISTING .999.0.Lh.er.-UAa.u.thori2ed.Pxactice.SBlJrainina-------------------- ___________________________ _____ _________ .aifljEquipmentPailujte FOLLOW UP ACTION TO PREVENT RECURRENCE: Action: C.o.mmuni.cate..incidfint.ta.alLCA.Ilj3Bisonn.el.------------------------------------------------ Responsibility : Landry.___________ Expected Completion Date: _l/31/93-- Actual Completion Date: _____1(21/39. Action :________________ ___ _.--____________________________________________________________ Responsibility: Expected Completion Date: Actual Completion Date; Action : -------- ----------------------------------------------------- ----------------------------------------------------- ---- ----------------- --------------- Responsibility :,, Expected Completion Date:Actual Completion Date: Landry, Prejean, Mabile, LeJeune, ______________ N/A_______ ^wperintendent's^ Signature Signature of Injured Original To: Safety DepartmeM Copies To. Department Reporting; Major Manager Safety Superintendent: Environmental Superintendent; Legal Department 00 A 02960.? CONFIDENTIAL 0 oow Dow Chemical USA-Louisiana Division 0 Safety f9331 O CONTRACTOR Supervisor's Investigation of Accident/Incident I 1 Illness SAFETY CATEGORIES (Attachment 1) .. , , Injury Non-lnjury ENVIRONMENTAL (Attachment 2) Q Environmental (Reference LAO SSLP S-305) GENERAL INFORMATION V MTC L A/C ID DAW |D Fatality O RMTC O RWC DAW O Fatality Q Inj. Prevented Q Precautionary First Aid PSA ? Q Yes Q No Hpsa Bus. Loss Dept. Rept. Internal Internal Plant Dow Agency Dale of Incident-,, Time nf Incident- ,, ? ,, Dale Investigated: fi/17/Ql Date Report Submitted: R/iflrqt Block in Which Incident Occurred: Chlor-Alkali II Block 36 Location within Block: Cell Area; Name of Involved Employee: None Master or Social Sec #: N/A Employee Classification: .MZA_________________ Time in Class (mos): Time at Dow(mos.) tMTime on Job (mos): MS________ _________________ MA_____________ _____________ Contractor Firm: None_________________________ Contract Supervisor: WA For Reactive Chemicals, Chemical Exposure, or Environmental Incidents: Chemical Involved: None Quantity Released (lb): ___________! Spill Category: QA C]B QC (for Environmental Incidents only) CI21993- __ 1 Short Incident Description (less than 10 words): Fire on cathode end nf Ceil Series 6 Full incident Description: While cell operator was making a round he smelled something burning. Upon investigating he found the cathode end of S-6 arcing. After putting a water hose on the arcing, it started to smoke badly on both ends of the series. A fire broke out on both ends of the senes, senes was then shutdown tor repairs. Load was cut on the circuit, tire monitors were applied, ana me ore Department was tailfed. Aner n was aeterrrtmea mat a tie roa haa orok^n. me circuit was shuiuown.------------------------- - " *1 Accident / Incident Type (Attachment 3): .,-ry: None ynn Fira / Fxniosinn___________ 3fin Fmiinment Failure----------- Body Part(s): AIZA. Job Being Performed (Attachment 4): Group I: 100 Operation Routine_________________ Group II: Causes At the Time Of the Incident: Pre-Existing Causes; 8io Fnuinment Failure __________________________ 387 Maintenance-------------------------------------------------- ______ 999 OTHER - Ground on Series 880 Corrosion (see Attachment 5 for Cause Definitions) Root Cause (select one of above): ____ ____________________ 9R7 Maintenance Follow-Up Actions: Action: Train operations personnel on identification of broken tie rods------------------------------------------------------------------------ Responsible (Name / #): Pittman.Expected Date: 5/2/94 Actual Date: Action: Evaluate need for rnutine inspections of rell tie rods. insulators-_and associated equipment (Not feasible.)-- Responsible (Name / #): Pittman____________________________ Expected Date: ___ 7/3Q/93___Actual Date: 12/30/93 Action: Develop and document emergency procedure for response taarcifla and fires an cells Responsible (Name / #): Pittman/Normand .Expected Date: 5/2/94 Actual Date: Action: ._________ _________________________________ _________ Responsible (Name / #):____________________________________ Expected Date: -------------------- Actual Date: ------------------- Action: __ __________________________________________________________________________________________________________ _ -ponsible (Name / #):Expected Date: ----------------------------------------------------------------------------Actual Date: ------------------- ^ ___________ Mabile Normand Landrv----------------- SHIFT ------------------- __m_______________________________________________________________________________________ Superintendent's Signature investigated By Signature of Injured DO ft 029&O3 CONF i dent I Ai. Edow CONTRACTOR Dow Chemical USA Louisiana Division Supervisor's Investigation of Accident/Incident E Safety 193621 Q Environmental Illness V 1TC VC_ daw_ Fatality SAFETY CATEGORIES (Atlachment 1) Injury ______ Non-Injury RMTC D RWC DAW Fatality D Inj. Prevented D Precautionary First Aid PSA ? Yes No Epsa Bus. Loss O Dept. Rept. Q Internal ENVIRONMENTAL (Attachment 2) GENERAL INFORMATION O Internal Plant ODow O Agency Tim* nl Incident- lll(j;IW Dale Invesliqaled: Date Report Submitted: .. Block in Which Incident Occurred: Chlor-Alkali ll Rlor.k 36 Name of Involved Employee: None________________________ Employee Classification: WA______________________________ Time at Dow(mos) NIA_______________________________ __ Contractor Firm: None___________________________________ . Location within Block; Cell Area Master or Social Sec #: N/A Time in Class (mos): N/A_______ Time on Job (mos): N/A_______ Contract Supervisor: N/A For Reactive Chemicals, Chemical Exposure, or Environmental Incidents: Chemical Involved: Hydrogen____ Quantity Released (lb): : Spill Category; QA Qb C (for Environmental Incidents only) 021993- Short Incident Description (less than 10 words): Hydrogen explosion- chlorine series #5 ft 8 hydrogen logs Full Incident Description: Approximately one hour after a plant trip due to a power failure, a small hydrogen explosion occurred inside hydrogen headers for chlorine series 5 & 8. When the plant tripped, the computer control failed to open the nitrogen valves for purging of the hydrogen logs. As a result air was drawn into the logs as the system cooieo down forming an explosive ffiixiure. ' "" Accident / Incident Type (Attachment 3): -,...y: None Body Part(s): 7nn Fire ' Fxnlnsion__________ ftnn Reactive Chemicals-------- MA. Job Being Performed (Attachment 4): Group I: _________________ _________ __________ . Group II: Causes At the Time Of the Incident: Pre-Existing Causes: 999 othfr . Crash Shutdown 999 OTHER-- Inadequate Computer Program -- (see Atlachment 5 for Cause Definitions) Root Cause (select one Of above): 909 OTHFR - Inadequate Computer Program Follow-Up Actions: Action: Modify Mod5 program to ensure opening of nitrogen upon trio to eliminate-min-max problem Responsible (Name / #): Barthoiomew/LongExpected Date: 17/17/93 Actual Date: 17/70/93 Action: Add low flow alarm on nitrogen for rectifier no load condition (red alarm!................. ................. ... . - Responsible (Name / #): Bartholomew/long Expected Date: __________________ 12/17/93 .. Actual Date: Action: Consider low pressure alarm on hydrogen header_____ _------------------------------------------------------------------------------------Responsible (Name /#): Mellieon____________________________ Expected Date: 17/1/93 . Actual Date: / y sf ! Action: Consider elimination of manometers on hydrooen loos.---------------------------------------------------------------------- --_--------Responsible (Name / #): Mellieon.Expected Date: ... 12/01/93,- Actual Date: JzJ.fr pi 3.... Action: Consider,redundancy in nitrogen valves. __--------------- --------------------------------------------------------------------- ------- ------- -ponsible (Name / #): Mellieon_________________________ --Expected Date: 12/Q1/93 Actual Date: _j Mellieon. Hudson, Sandow, Landry. Lively. SHIFT ~ Moniotte, Armstrong. Breaux, Bartholomew. _______________ ^______________ Superintendent's Signature l ff^ul^Inve^iiaieS'By Members Signature of Injured DO A 029604 CONFIDENTIAL. g|OOW Dow Chemical USA - Louisiana Division CONTRACTOR Supervisor's Investigation of Accident/Incident _____ (Reference LAD S&LP S-30S) I I Illness SAFETY CATEGORIES (Altachment 1) ,, Injury Non-Injury ENVIRONMENTAL (Attschment 2) H Safety 19370 Q Environmental GENERAL INFORMATION ICl"MTC VC IJ DAW JQ Fatality 0 RMTC O RWC DAW Fatality Inj. Prevented O Precautionary First Aid PSA f 0 Yes No 0 PSA 0 Bus. Loss 0 Dept. Rept. H Internal Q Internal Plant Q Dow 0 Agency Time nf Incident' Date Investigated: Date Report Submitted: QlYI PM 11/12/9.1 Block in Which Incident Occurred: Chlor-Alkali II Block 3fi Location within Block: Name of Involved Employee: NoneMaster or Social Sec #: N/A Employee Classification: N/ATime in Class (mos): Time at Dow(mos) JiZATime on Job (mos): Contractor Firm: None_________________________ Contract Supervisor: For Reactive Chemicals, Chemical Exposure, or Environmental Incidents: Cell Area N/A _ N/A n/a Chemical Involved: ,,_______________________________________ Quantity Released (lb): ; Spill Category: QA Qb C (for Environmental Incidents only) CI21993- Short Incident Description (less than 10 words): Hydrogen leak / fire on hydrogen log expansion hoot Full Incident Description: A small lire developed at a hydrogen leak from an expansion boot on the west end of S-6 hydrogen log. The fire was extinguished and joint was tightened. ____________________________ Accident / Incident Type (Attachment 3): _ None ?no Fire / Explosion Body Part(s): m Job Being Performed (Attachment 4): Group I: 100 Operation Routine__________________ Group II: 1)35 No TaaK Causes At the Time Of the Incident: 999 OTHER - Leak_______ _ 83Q Procedures Pre-Existing Causes: (see Attachment S for Cause Definitions) Root Cause (select one of above): ________________ ___________aart Procedure*__________ Follow-Up Actions: Action: Revise Procedure for handing of boots to hydrogen loos------------------------------------------------------------- Responsible (Name / #): Armstrong_______ _________ ______ __ Expected Date: 12/17/93 Actual Date: Action:__________ ___ ___________________ _______ ______________________________________________________ Responsible (Name / #):____________________________ ________ Expected Date: Actual Date: Action:________________________________ _________________________________ ______________ _ Responsible (Name / #):;Expected Date: Actual Date: Action: ______________________________ _____ _________________________________________________________ Responsible (Name /#):Expected Date; Actual Date: Action: ________________________________________________________________________________________________ Re^Donsible (Name / #): jf) Expected Date: 1Actual Date: -------------------------------------------------------------- Pittman Domingue. Armstrong. I andrv SHIFT ________ __________ N/A Superintendent's Signature remi-M<!!* Investigated By Signature f Injured A 02^605 Operation Requirements CI-1 and CA-2 Follow-up actions from CA-2 Cell Explosion Investigation Communication: CI-1 and CA-2 Communications Notes Effective: 12/21/94 The following actions are to be added to the minimum requirements for cell operators: 1. Visual round on all radial distributors once per shift. 2. Run 2 salt cells on each round. There are to be 2 salt rounds per shift unless approved by the shift supervisor or his designee. 3. Salt check cells will be separated by a minimum of 2 full covers. The location of the salt cells will be a cell crew responsibility. Periodic salt profiles will be re-instituted on cell crew. 4. Plugged radial feeders should be unplugged per procedure promptly. 5. Salt should be taken off the series if the highest of the two salt cell is >300 but less than 305 for 2 consecutive rounds -OR- the salt is higher than 305 on any round. Salt should be put back on when the maximum salt sample' Is <300 gpl and all other series parameters appear normal. ( hydrogen, voltage, pH etc.) 6. Series gas chromatographs are vital instruments. If they malfunction the operator should perform any known repair procedures or the analyzer technician should be called out. Ed Pittman Cell Operations Production Supervisor 12/21/94 DO A 029606 CONFIDENTIAL 00 A 009607 CONFIDENTIAL LAD EMERGENCY DRILL REPORT Plant: Chlor-Alkali Dept, (block 29) Date: 5/31/95 Shift/Team: "B" shift and Day Personnel Participants: Same Drill Scenario: HCL line west of HE-201 has severe leak. Wind is out ofWNW at 5 MPH. Actions: 1) Spill was announced as a drill. 2) The spill horn was set by the control room operator. 3) Control room operator called Security. 4) Page was made to clear the block craftsmen to the warehouse. 5) HCL to outfall control was blocked. 6) Solvents was notified that Caustic block had no pH control. 7) Outside operator updated situation. 8) Made sure that the sump was routed to the outfall and not T-2. 9) Craft personnel were accounted for. 10) HCL line was isolated. 11) Called office personnel and accounted for. 12) Washed up leak and tagged. 13) All clear was given. Comments: Operations personnel responded well to the drill. Some of the Day personnel were not aware of all responsibilities but were concerned enough to ask questions as to what happens next. Several persons with key responsibilities were out of the block at the time of the drill. Changes Suggested: Yes LAD Emergency Drill Critique/9-13-95/pj DO A 029608 CONFIDENTIAL LAD EMERGENCY DRILL CRITIQUE Most all of the personnel without emergency responsibilities knew what to do during the drill. Craftsmen sheltered immediately as well as day personnel in the office building. A few problems encountered were: 1) Group leaders did not report to the control room as to personnel safety status and if everyone was accounted for. This information needed to be requested by the control room. 2) Area sweeps were late. 3) The emergency plan found in the control room was an obsolete version. Emergency responsibilities had not been changed to reflect Department personnel changes. 4) One individual entered the block while the red lights were flashing. The individual said he knew what the flashing lights were for but just didn't see them. LAD Emergency Drill Critique/9-13-95/pj A 029609 CONFIDENTIAL. 2 LAD EMERGENCY DRILL CHANGES/FOLLOW-UP ACTIONS Change/Follow-Up Action: Communicate drill findings to all personnel. Responsible Person: Donnie Landry Expected Completion Date: 11/28/95 Actual Completion Date: 11/28/95 Change/Follow-Up Action: Generate a quick and easily accessible list of emergency actions with both primary and backup responsibilities listed by names. Responsible Person: Ike Sumly Expected Completion Date: 4/30/96 Actual Completion Date: Change/Follow-Up Action: Inform personnel of the requirements concerning communication of personnel status to the control room. Responsible Person: Donnie Landry Expected Completion Date: 11/28/95 Actual Completion Date: 11/28/95 LAD Emergency Drill Critique/9-13-95/pj oo A CONF AL. 3 Change/Follow-Up Action: emergency plan as needed. Reveiw and update the block Responsible Person: Ike Sumly Expected Completion Date: 12/31/95 Actual Completion Date: 12/31/95 Change/Follow-Up Action: Determine requirements, if any, for use of the "buddy system" when sweeping the plant for stragglers. Responsible Person: Donnie Landry Expected Completion Date: 11/30/95 Actual Completion Date: 11/30/95 LAD Emergency Drill Critique/9-13-95/pj OO A 0296.1.1 CONFIDFNTTAL 4 LAD EMERGENCY DRILL REPORT Plant: Chlor-Alkali Dept, (blocks 35,36) Date: 6/1/95 Shift/Team: "B" shift and Day Personnel Participants: Same Drill Scenario: Liquid CI2 leak on line to CI2 Plant at PSV-515 (located N/W of T-35 in the piperack) Actions: 1) The spill was announced as a drill. 2) The spill horn was set by the control room operator. 3) Security was called and a block page was made to clear areas. 4) Air handlers were turned off in B-3601. 5) Announcement to clear B-3601. 6) Control room operator simulates use of fresh air mask. 7) Control room operator communicates with outside operator on isolation of the leak. CI2 plant to block and sniff from their end. 8) Operator and permit writer don SCBA's and sweep the block for personnel. 9) Leak is isolated and spill condition cleared after 15 minutes from first page. Comments: Operations personnel responded well to the drill. Some of the Day personnel were confused as to what to do and where to go without instruction. Day personnel in blocks 35 and 36 evacuated as instructed. There were no reports to the control room as to status of personnel at assembly points. Changes Suggested: Yes A 0,?96,? ,> CONFIDENT lAi LAD Emergency Drill Critique/9-13-95/pj 1 LAD EMERGENCY DRILL CRITIQUE Building air handling units were shut off and intakes closed. Security was called, appropriate pages were made, and control room operator simulated use of fresh air system. All personnel responded well to instructions. Observations of problems were as follows: 1) Personnel response to the intitial page was confused. Personnel with key responsibilities during emergencies were either absent or serving as observers. Backup for those personnel was not clear. 2) Not everyone had all required PPE available for use. Time was lost trying to find it. 3) Block 35 personnel responded to the evacuation instructions but did not contact the control room once reaching the assembly point to notify of status. 4) Day personnel responded to the evacuation but did not contact the control room. LAD Emergency Drill Critique/9-13-95/pj D0 A 029613 CONFIDENT!AL 2 LAD EMERGENCY DRILL CHANGES/FOLLOW-UP ACTIONS Change/Follow-Up Action: Communicate drill findings to all personnel. Responsible Person: Donnie Landry Expected Completion Date: 11/28/95 Actual Completion Date: 11/28/95 Change/Follow-Up Action: Generate a quick and easily accessible list of emergency actions with both primary and backup responsibilities listed by names. Responsible Person: Donnie Landry Expected Completion Date: 4/30/96 Actual Completion Date: Change/Follow-Up Action: Inform personnel of the requirements concerning communication of personnel status to the control room. Responsible Person: Donnie Landry Expected Completion Date: 11/28/95 Actual Completion Date: 11/28/95 LAD Emergency Drill Critique/9-13-95/pj DO A 029614 CONFIDENTIAL 3 Change/Follow-Up Action: Determine requirements (if any) for use of the "buddy system" when sweeping the plant site for stragglers. Responsible Person: Donnie Landry Expected Completion Date: 11/30/95 Actual Completion Date: 11/30/95 LAD Emergency Drill Critique/9-13-95/pj DO A 0?96\5 CONFIDENTIAL 4 LAD EMERGENCY DRILL REPORT Plant: Chlor-Alkali Dept, (block 36) Date: 9/14/95 Shift/Team: "C" shift - Clayton Chavis, Pat Graham, Mike LeJeune, Henry Woods Participants: Same Drill Scenario: While operator was making a Cell Area round, he noticed the smell of something burning between S-1 and S-2. Upon further investigation, the source was identified as being a hydrogen wye on S-4. Actions: 1) Area Operator notified Control Room Operator and searched for fire extinguisher. 2) Control Room Operator made block page and notified Plant Security. Changes Suggested: Yes LAD EMERGENCY DRILL CRITIQUE 1) First response to fire should have been to spray water and not spend time looking for a fire extinguisher. 2) Extra SOS investigated the fire instead of reporting to and backing up the Control Room Operator. LAD Emergency Drill Critique/9-13-95/pj DO A 02961.6 CONFIDENTIAL V LAD EMERGENCY DRILL CHANGES/FOLLOW-UP ACTIONS Change/Follow-Up Action: Communicate drill findings to all personnel. Responsible Person: Donnie Landry Expected Completion Date: 12/14/95 Actual Completion Date: 12/14/95 Change/Follow-Up Action: Train Operations Personnel on types of Cell Area fires and appropriate response to each. Responsible Person: Operations Supervisors Expected Completion Date: 6/30/96 Actual Completion Date: Change/Follow-Up Action: Communicate backup responsibilities of the Second S.O.S. on shift during emergency situations. Responsible Person: Operations Supervisors Expected Completion Date: 12/31/95 Actual Completion Date: 12/31/95 DO A 029617 CONFIDENTIAL LAD Emergency Drill Critique/9-13-95/pj 2 LAD EMERGENCY DRILL REPORT Plant: ShiftTTeam: *~Ci" Teo.--v Participants: Date: JcP-~~ /<2 -C'?5' A/a1 L'-'V , Drill Scenario: !Y)atrr e-1 f-L> E'-Zl^tA" 's leh , I3^fe iW4 <Q^tT^ is ffO') LLxl<n 2IV %'0S Actions: (Those actions taken by personnel participating in the drill) Ci^V^ lacxS) , /Y)^rfo^ cJoWt^ . 'B^iadoLJ^ Circw^US-fcS Xksp0S5 . CJW Ar^a V -<.S5A>.aJ?0=^o^^l, /Vci,^A*Jfcf(pnX - /^5-S/S'^' 75<^cvT^ f\S> Gk<cC Orv .^ 57^rvx ^ 5^00^-^ Ca^sht (PlckJf yvdc S'l^e >$. ^ lEL^to-r^ 7a Ce//s ^\rMe*o C >VcyC4$ ol^e 7> LyH~Je Ccn^rz>/ F'JUs' )Jo5T^K.cffo^ c/<w> Gr~c Ra-fvri* 7a ^Asi ^'cle, f'Fi-btt ^ fimo, is c4v^ cf1 (Porterr-tHe/' J-rtk idio fizO ^py^fYS OsJ jf^2(4 j%lv> -fe tejpjfcK, r;,e. CcM! 72 Hr yCKpv" ^ Sir^_dt)<=> LAD Emergency Drill Critique/9-13-95/pj oo a op^aia CONFTDFNTIAL 1 LAD EMERGENCY DRILL CRITIQUE (How did the drill go? Any significant findings/problems - good and bad?) 7a(JLQ -ho' j/7st Ah> -FasT ~/s -f'L.e Changes Suggested: Ye: -tut, bJr A. ~h> do. LAD EMERGENCY DRILL CHANGES/FOLLOW-UP ACTIONS Responsible Person:_____ Expected Completion Date: Actual Completion Date:__ LAD Emergency Drill Critique/9-13-95/pj 029blq DO A 2 LAD EMERGENCY DRILL REPORT Plant: CALnVKC_ Shift/Team: C ~ Participants: CAVt| Drill Scenario ~TC Date: iXl I'll ^ CAAWciS /^LfcA-l-A^O jft**] ; - Cojt Actions: (Those actions taken by personnel participating in the drill) C[far* [oOjAsitr o4 <^.`11 Vy^ody< looidej^ Sk*ot~ ~h C&t'. 0+>e/C*=W rt>o^ 'c^od&i 4^^ Qy\ C&se V\cl Oslor-^^^^ ` TgfiXDri S(2G.u,ri 4^ ^ Scc^n'^ /\>V.-Pei erNU{r&v^xAJh>.l "feCa^cL c) Q^AaQ< ck'U-tl* ^\smA- 4^11 . hui^ ^SpecW- ^ ?* AW- Ue*- <t^\cl -fc> u5*/ `tr'r^ L-b iv^o LAD Emergency Drill Critique/9-13-95/pj DO A 029620 CONFIDENTIAL 1 LAD EMERGENCY DRILL CRITIQUE (How did the drill go? Any significant findings/problemg - good and bad?) d J <S> CovJtxJ^v^ a* 5k Vtt. (S^a^5 >&* Changes Suggested: ^es^No Change/Follow-Uo Action: Responsible Person: Expected Completion Date: -fv^> Actual Completion Date:_______________ Change/Follow-Up Action: Responsible Person:_____ Expected Completion Date: Actual Completion Date:__ Change/Follow-Up Action: Responsible Person: Expected Completion Date: Actual Completion Date: LAD Emergency Drill Critique/9-13-95/pj yLAv. lix DO A 029621 conftdfnttal 2 LAD EMERGENCY DRILL REPORT C $PLANT: ' 3-- SHIFT/TEAM: A PARTICIPANTS: iisbvJlv*- /Yl/kM&JL K fc\J*-V \pt^\ \\sJU. DATE: 3'37'ff~ CHANGES SUGGESTED:______ YES (see page #2) DRILL DOCUMENTATION MUST INCLUDE: A. COVER SHEET (Page#l) B. DRILL CRITIQUE (Page #2) C. CHANGES/FOLLOW-UP ACTIONS (Page #2) D. COMMUNICATION (Page #3) 1/ NO Do ^ 0 ONPxo ^rrAL' LAD EMERGENCY DRILL CRITIQUE CRITIQUE OF DRILL, WHAT WAS LEARNED FROM DRILL? A______________________ 2 D0 A 029623 onftdfmttal c 2 LAD EMERGENCY DRILL REPORT Plant: Chlor-Alkali Dept, (block 29) Date: 7/25/95 Shift/Team: "D" shift - Dale Duval, Joyce Geason, David Broussard, Herbert Duggan Participants: Same Drill Scenario: Power Failure - Lost all lights in the Control Room, outside in the Plant, and most all mechanical equipment. Actions: 1) Activated Power Failure Procedure. 2) Kept User Plants up with C/E. Some of the user pumps wer able to be restarted immediately. 3) CI2 Plant having problems getting river water. Cut back on water to CD-203 and CD-204 in order to help problem. 4) Tank car and truck loading was down and contacted loader to secure area, then report to the Control Room. Changes Suggested: Yes LAD Emergency Drill Critique/9-13-95/pj DO A 02967A CONFTDFNTTAL 1 ( LAD EMERGENCY DRILL CRITIQUE 1) Lighting in the Control Room was inadequate. 2) Outside lighting was inadequate. 3) Most newer Operations Personnel not very familiar with Power Failure Procedure. 4) Need easily accessible storage area for flashlights. 5) CI2 Plant had problems getting river water. Didn't have enough available operators to allow someone to leave to restart river water pumps. LAD Emergency Drill Critique/9-13-95/pj DO c 0Np 2 LAD EMERGENCY DRILL CHANGES/FOLLOW-UP ACTIONS Change/Follow-Up Action: Communicate drill findings to all personnel. Responsible Person: Donnie Landry Expected Completion Date: 12/14/95 Actual Completion Date: 12/14/95 Change/Follow-Up Action: Audit emergency lighting in the Control Room Responsible Person: Leonard Fair Expected Completion Date: 3/15/96 Actual Completion Date: Change/Follow-Up Action: Review Power Failure Procedure with Operations Personnel. Responsible Person: Operations Supervisors Expected Completion Date: 12/31/95 Actual Completion Date: 12/22/95 do a confidential LAD Emergency Drill Critique/9-13-95/pj 3 4f Change/Follow-Up Action: Discuss with CI2 Plant Management th availability of CI2 Plant Operations Personnel to restart river water pumps after such power failures. Responsible Person: Allan Sandow Expected Completion Date: 3/31/96 Actual Completion Date: Change/Follow-Up Action: Evaluate methods to maintain uninterrupted C/E flow to Glycol I Plant. Responsible Person: John Dizor Expected Completion Date: 12/31/95 Actual Completion Date: 12/31/95 LAD Emergency Drill Critique/9-13-95/pj * tcfioOoNFIOF0N2TT A7t. c 4 I clc^u / DO A 029628 CONFIDENTIAL Special Tagging Consid rations 1 Red Tags are standard cards used to identify all isolating devices used for energy control. They are warning devices and DO NOT provide physical restraint t prevent operation of the device, such as that which would be provided by a lock. Individuals must not get a false sense of security from the presence of the tag. When a Red Tag is attached to a device, that device is NOT to be operated under any circumstances. The tag must NOT be removed, ignored, or otherwise defeated. Red Tags must be legible and understandable. The tag is to be securely fastened to the device so it cannot b accidentally detached. Any Red Tags found unattached must be reported to department supervision immediately. Violation of the Lockout/Tagout standard will result in appropriate disciplinary action. piu 6/22/04 Do A 0,?96.?9 confident tai Lockout/Tagout Responsibiliti 3 Owner: 1. Establish isolation procedures 2. Specify and purchase lockable equipment when available Operations Representative: 1. Attach locks or tags on equipment being isolated 2. Physically verify isolation (ensure equipment rendered safe) 3. Review conditions with job representative and workers 4. Address worker concerns 5. Review and communicate addendums 6. Verify release after work complete 7. Notify personnel when equipment placed back in service Job Representative: 1. Review job scope with operations representative 2. Review, verify, and confirm isolation 3. Resolve differences with operations representative Workers: 1. Review prior to signing job acceptance 2. Communicate concerns 3. Notify operations representative when complete, scope changes, or other hazards identified 4. Return equipment to safe status 5. Sign released when job complete pill 6/22/94 DO A 009630 CONFIDENTIAL S-208, EXPLOSIMETERS (COMBUSTIBLE & OXYGEN METERS) I. General Information A. Scope B. Statement of Standard C. Definitions To specify the limitations, testing, and maintenance of explosimeters and oxygen meters. Explosimeters and Oxygen Meters are to be tested prior to use. Any meter which fails to function properly shall not be used. Explosimeter - meter used to measure the level of oxygen and combustible gases in an area to ensure a safe work atmosphere D. Responsibilities 1. Department Supervision: a. Administer this standard b. Designate the individual department meter contact c. Ensure meters are returned to the Instrument Shop for the quarterly inspection and calibration and whenever found defective d. Establish a process to maintain documentation of persons trained to use meters 2. Instrument Department: a. Train and certify Department Meter Contacts annually as instructors. Appropriately document. b. Purchase meters for use in the Division, maintaining appropriate records c. Maintain list of meters approved for division use d. Recommend meters for Department use e. Perform in-depth inspection and calibration of department meters quarterly in central Instrument Shop and repair defective meters f. Maintain records of meter inspection and repair for a period of three years plus current 3. Department Meter_Contact: a. Ensure proper care of these meters b. Ensure the proper use of the meters c. Be certified by the Instrument Department as a meter instructor d. Certify others in their area in the safe use of these meters Safety & Loss Prevention Standard S-208, Explosimeters (Combustible and Oxygen Meters) 12/13/94 Par' " 00 A 0P9637 CONFIDENTIAL II. Training Requirements j A. Users Only persons who have successfully completed the Oxygen and Explosimeter Training Class, and who have valid certificates, may use meters. Users must demonstrate competency as a part of training. Recertification is required annually. B. Trainers The Department Meter Contact will certify others in their area. This person must be experienced in the use of the meters, a certified user, prior to be trained as an instructor. III. Selection and Purchase of Meters A. Miscellaneous Meters used will be evaluated for accuracy, reliability, and maintenance repair cost prior to division use. For selection of the meters most suitable for departmental needs, consult the Instrument Department. They will in turn order the appropriate meters. IV. Calibration and Testing of Meters A. Designated Areas B. Calibration Station Setup Each department using meters will have a designated place for storage, charging, and testing/calibration of the meters. All meters not being used should be in this area. The calibration station must conform to the "Explosion Meter Calibration Station" diagram in Attachment 1. NOTE: Only rechargeable batteries are to be used in meters due to the explosion potential of alkaline batteries when attempting to recharge. C. Calibration Gases A cylinder of 2.5% Methane in air mixture will be used for testing combustible gas meters. Use of any other mixture must be approved by the Instrument and Safety Departments. Calibration gases should be purchased in 220 cu. ft. cylinders. Small test cylinders should be used for field calibration only when meters are used for prolonged periods. D. Calibration and Meters are to be tested and calibrated prior to each use. In Testing addition, in-depth inspection and calibration must be Schedule performed by the Instrument Department at least quarterly. Safety & Loss Prevention Standard S-208, Explosimeters (Combustible and Oxygen Meters) _, 3 3 confidential 12/13/94 Page 67 E. Calibration Procedure The steps below can be applied to most meters. For a more specific check, follow the instructions for meter being used. Units must be tested in a clean, combustible-free atmosphere. Step Action 1 Remove the sample probe and tube. Check cotton filter housed in meter end of probe. If dirty or wet, replace filter. 2 Clean and dry the moisture trap (if applicable). 3 Turn unit on and check battery voltage. NOTE: Never calibrate a unit plugged into charger. 4 Check pump flow and alarm (if applicable). 5 Zero oxygen meter using Nitrogen. If not zero, adjust zero potentiometer until zero is obtained. 6 Check oxygen reading in air. Should be 21%. If not, adjust oxygen calibrate potentiometer until 21% reading is obtained. 7 Check combustible meter for zero in clean air. If not reading zero, adjust combustible gas zero potentiometer until zero reading is obtained. 8 Introduce calibration gas (2.5% Methane in air). Combustible gas meter should go upscale to 55% for Gastech GX-3,1214, GP204 2.5% for BioMarine 902A. If reading is incorrect, adjust combustible gas span potentiometer until correct reading is obtained. NOTE: An explosion meter with a bad combustible gas detector will appear to be working. The ONLY way to tell if the sensor is good is by putting a calibration gas on it and checking the span. F. Confined Space Meters must be tested after use but prior to entry in confined Entry Post Use space entry situations (See USA-5). Only steps 4 and 6 listed Testing above are required for this post use function check. Do not issue the permit until this post use test is completed. If the meter requires any adjustments, do not permit the entry. G. Procedure for If the unit fails any of the steps above, doesn't hold Defective Meters calibration or function properly, or if the user is not satisfied that the unit is working properly, DO NOT USE IT. Tag the unit and send it to the Instrument Department for repair. o?9&3A confidential. Safety & Loss Prevention Standard S-2Q8, Explosimeters (Combustible and Oxygen Meters) 12/13/94 Page 68 II. Additional Procedures A. Isolation If one of the accepted methods for isolating equipment listed in Section IV.A.2.a. of USA-5 cannot be performed then the alternate method to be used must be approved by the Superintendent/Department Head. If blinds or pancakes are used to provide isolation, then the blind thickness shall meet Dow Engineering Details L4G6420-01 for RF and FF flanges and L4G-6420-02 for RTJ flanges (See Attachments 2 and 3). B. Air Quality Testing Air quality tests will be performed at all expected entry points into the confined space. Consider also the possibility of stratification of the atmosphere within the confined space. If it is possible, testing must be done at a variety of points within the space. The post use functional check required by USA-5, Section IV.C.3, need not include recalibration of the instrument. Checking it against a known reference sample is sufficient. C. Ventilation If forced or induced ventilation is used, it should provide a minimum of ten volume changes per hour, must have a valve or switch readily accessible to allow fast shutoff of the air should a spill occur D. Testing for Concentration of Last Contained Compound Confined spaces should be cleaned below the Threshold Limit Value (TLV) of the last contained compound (see Attachment 1). If not, entry procedures must be reviewed and approved by Industrial Hygiene. If there is no simple method to determine the TLV or the chemical does not have a published exposure guideline and/or it is known that the chemical does not cause acute inhalation toxicity (i.e., death or serious illness), then a procedure which includes cleaning or decontamination, the use of ventilation or PPE, and which has been approved by Industrial Hygiene, can be used in lieu of obtaining a TLV. E. Lighting Low voltage, explosion proof, lighting is preferred. If the situation however requires more lighting than this can provide, the lighting used must be 115VAC industrial grade with a caged protector and protected by a Ground Fault Circuit Interrupter (GFCI) located outside of the space. Safety & Loss Prevention Standard LAD-5, Confined Space Entry 12/13/94 Page 90 D0 A 029635 CONFIDENTIAL V. Limitations and Other Considerations A. Temperature Exposure The approved explosimeters are not good for temperatures below 5 F or above 140 F. When used at 100 to 140 F, the meter must be recalibrated in the field at a temperature which approximates the one at which it will be used. B. Extended Usage Meters used continuously for extended periods, such as to monitor welding or hot work for a whole shift, should be tested and calibrated periodically (as conditions warrant but at least every 4 hours) to correct any drift due to temperature changes, sample changes, degradation of sensor, etc. C. Different The meter is calibrated with 2.5% Methane in air. The Explosive Limits compounds to be checked may have a different explosive than Checked limit. In addition, permanently mounted meters may be calibrated for a different explosive limit other than the meter. Consult the Instrument Department in these situations. D. Oxygen Deficient or Oxygen Rich Atmospheres An explosion meter cannot be used to measure combustible gas in atmospheres that are oxygen deficient, below 10%, or oxygen rich, more than 25%, oxygen by volume. These conditions will cause erroneous readings. Special fittings are available for these instances, such as sampling in nitrogen or other inert atmospheres. These meters and fittings must be clearly labeled for their special use and stored separately from the normal meters. It is recommended that they be placed under lock and key. These meters require special training not included in the regular explosion meter training classes. Improper use of this fitting could result in a false sense of safety. For the correct training in the use of this type of fitting, contact your Department Meter Contact or the Analyzer Department. E. Silicone Tetraethyl lead or compounds containing silicon/may poison Compounds combustible gas sensors, and give inaccurate readings. F. Concentrations In combustible gas concentrations above 100% L.E.L., the > 100 % LEL explosion meter will give erroneous readings. G. Liquids These units are not made to take liquid samples. If liquid is drawn into the unit, it is no longer safe for use and should be tagged and sent to the Central Instrument Shop immediately. Safety & Loss Prevention Standard S-208, Explosimeters (Combustible and Oxygen Meters) PO A 029636 CONFIDENT IAL. 12/13/94 Page 69 Explosion Meter Calibrati n Station Diagram Safety & Loss Prevention Standard S-208, Hxplosimeters (Combustible and Oxygen Meters) 12/13/94 page 70 NAME: ________________________________________________MASTER # DEPARTMENT: DATE: 1. Why do we use the portable combustible gas/oxygen meters in the Division? 2. What does the scale on the combustible gas meter indicate? 3. If a person is not certified in the use of the explosimeter, is it O.K. for him/her to use it? 4. At what oxygen meter reading would you start to get concerned about your safety? ___ 5. At what elevated temperature isre-calibration required?___________________________ 6. What is meant by lower explosive limit (LEL) and upper explosive limit (UEL)? LEL______________________________________________________________________________ UEL_____________________________________________________________________________ Why is this important for you to know?_____________________________________________ 7. Describe the meter reactions to these mixtures. A. Lean mixture______ ___________________________________ _______________________________ B. Explosive mixture__________________________________________________________________ C. Rich mixture ____________________________________________________________________ 8. What is the correct meter setting when calibrating the oxygen meter in normal atmospheric air? 9. What is meant by the vapor density of a gas? Why is this important for you to know? 10. When checking for combustible gas, the oxygen meter should read with in what range? 00 COfyp 1, '0ENTial 11. If you have purged a line with inert gas, such as nitrogen, what should you check first? Why?_________________________________________________________________________ 12. What is the only way for you to know that a combustible gas sensor is working properly? 13. When a liquid is drawn into the explosimeter, is it safe to reuse the meter after you have thoroughly dried it? 14. Are the Divisions combustible gas/oxygen meters accurate between the LEL and the UEL?_______________ 15. If you are using the explosimeter and the combustible gas meter pegs up scale, what action should you take?. 16. If you zero the combustible gas meter and put 2.5% methane/air calibration gas on the unit and the meter reads 35% LEL, what should you do? 17. What should the combustible gas meter read with 2.5% methane/air calibration gas applied? ___ 18. Is it acceptable to check calibration of the explosimeter while they are plugged into the charge unit? 19. List three conditions that would cause an explosimeter to require re-calibration. A. _______________________________________________________________________________________ B. _______________________________________________________________________________________ C. _______________________________________________________________________________________ 20. Where should you test and calibrate the explosimeter? QO A 029640 CONFIDENTIAL NAME: ;_________________________________________________ DEPARTMENT: MASTER# DATE: 1. Why do we use the portable combustible gas/oxygen meters in the Division? 2. What does the scale on the combustible gas meter indicate? 3. If a person is not certified in the use of the explosimeter, is it O.K. for him/her to use it? 4. At what oxygen meter reading would you start to get concerned about your safety? ___ 5. At what elevated temperature isre-calibration required?________________________ __ 6. What is meant by lower explosive limit (LEL) and upper explosive limit (UEL)? LEL_____________________________________________________________________________ UEL_____________________________________________________________________________ Why is this important for you to know?_____________________________________________ 7. Describe the meter reactions to these mixtures. A. Lean mixture________________________________________________________________________ B. Explosive mixture __________________________________________________________________ C. Rich mixture ____________________________________________________________________ 8. What is the correct meter setting when calibrating the oxygen meter in normal atmospheric air? 9. What is meant by the vapor density of a gas? Why is this important for you to know? 10. When checking for combustible gas, the oxygen meter should read with in what range? Do ^ r> 7,Q . , CNPTDFNTr4L 11. If you have purged a line with inert gas , such as nitrogen, what should you check first? Why?_______________________________________________________________ ____ 12. What is the only way for you to know that a combustible gas sensor is working properly? 13. When a liquid is drawn into the explosimeter, is it safe to reuse the meter after you have thoroughly dried it? 14. Are the Divisions combustible gas/oxygen meters accurate between the LEL and the UEL?_______________ 15. If you are using the explosimeter and the combustible gas meter pegs up scale, what action should you take? 16. If you zero the combustible gas meter and put 2.5% methane/air calibration gas on the unit and the meter reads 35% LEL, what should you do? 17. What should the combustible gas meter read with 2.5% methane/air calibration gas applied? ____ 18. Is it acceptable to check calibration of the explosimeter while they are plugged into the charge unit? 19. List three conditions that would cause an explosimeter to require re-calibration. A. ____________ _____________________________________________________________________ B. ___________ ,,___________________________________________________________ _________________ C. ._______________________________________________________________________________________ 20. Where should you test and calibrate the explosimeter? DO A 0296A? CONFIDENTIAL NAME: __ DEPARTMENT: MASTER# DATE: 1. Why do we use the portable combustible gas/oxygen meters in the Division? 2. What does the scale on the combustible gas meter indicate? 3. If a person is not certified in the use of the explosimeter, is it O.K. for him/her to use it? 4. At what oxygen meter reading would you start to get concerned about your safety? ___ 5. At what elevated temperature isre-calibration required?___________________________ 6. What is meant by lower explosive limit (LEL) and upper explosive limit (UEL)? LEL______________________________________________________________________________ UEL_____________________________________________________________________________ Why is this important for you to know?_____________________________________________ 7. Describe the meter reactions to these mixtures. A. Lean mixture____________________ ;___________________________________________________ B. Explosive mixture __________________________________________________________________ C. Rich mixture ____________________________________________________________________ 8. What is the correct meter setting when calibrating the oxygen meter in normal atmospheric air? 9. What is meant by the vapor density of a gas? Why is this important for you to know? 10. When checking for combustible gas, the oxygen meter should read with in what range? DO A 039643 CONFIDENTIAL 11. If you have purged a line with inert gas, such as nitrogen, what should you check first? Why?_________________________________________________________________________ 12. What is the only way for you to know that a combustible gas sensor is working properly? 13. When a liquid is drawn into the explosimeter, is it safe to reuse the meter after you have thoroughly dried it? 14. Are the Divisions combustible gas/oxygen meters accurate between the LEL and the UEL?_______________ 15. If you are using the explosimeter and the combustible gas meter pegs up scale, what action should you take? 16. If you zero the combustible gas meter and put 2.5% methane/air calibration gas on the unit and the meter reads 35% LEL, what should you do? 17. What should the combustible gas meter read with 2.5% methane/air calibration gas applied?____ 18. Is it acceptable to check calibration of the explosimeter while they are plugged into the charge unit? 19. List three conditions that would cause an explosimeter to require re-calibration. A. _______________________________________________________________________________________ B. C. 20. Where should you test and calibrate the explosimeter? DO A 029644 CONFIDENTIAL / 00 A 0^9645 co^tofnttAl CHLOR-ALKALI DEPARTMENT EMPLOYEE SURVEY SAFETY INCENTIVE PROGRAMS FOR 1996 { SURVEY RESULTS AND COMMENTS Safety Question of the Week: Weekly Monthly Other Discontinue 15 18 1 10 Comments: Have it every two wks. Increase monthly award $. (3) Environmental Question of the Week: Comments: Weekly Monthly. Other Discontinue 15 17 2 10 Have it every two wks. Increase monthly award $. (3) Unsafe/Environmental Condition Reports: Award for best: Comments: Monthly Other Discontinue 20 8 16 Award the best one for the year. Award the best USCR monthly. (2) Award the best quarterly. (7) Other Comments/Ideas: Send a copy of the questions to the lab. Discontinue BBS Program. (4) Have on the spot awards for doing/knowing the correct thing. Use some award money to buy biscuits for shift folks monthly. Stop giving individual awards and promote team atmosphere by giving food, jackets, etc. Include outstanding items from BBSO's in selection pool. Have monthly drawings for # of BBSO's over the minimum. ,, Do D O/vp- j 29646 rNTT4L Miscellaneous Safety Concerns: Elevated Work - Fall Protection - Use of: Employees must be continuously protected from injury due to falls, including movement to and from the actual work area, whenever exposed to an unprotected side or edge with a fall hazard of 6 ft. or more or that is above a recognized hazard such as an open vat, rotating equipment, etc. Safety Harnesses and Lanyards are to be inspected by the user prior to use. Each lanyard must have a current metal inspection tag that has not expired. Tags on lanyards are good for only 6 months. Each harness must have a current metal inspection tag that has not expired. Tags on harnesses are good for only 1 year. These are 2 (two1) separate inspection tags. If a harness or a lanyard does not have a tag, or it the tag has expired, that piece of equipment may not be used. This is a Dow Policy, which OSHA will consider as Law for Dow. It is a severe violation of Dow Policy and OSHA Standards to remove a good tag from one piece of safety equipment and place it on another. DO A 0296'" CONFIDENT! <r THE UISIANA DIVISION IMPLEMENTATION PLAN VISION ELEMENT KEY OBJECTIVE MEASURES & TARGETS oo 251 O HQm2m 3> Mno> J~n> O' 0) SAFETY & HEALTH ENHANCEMENT Sponsor: Chris Messelt We will strive to achieve a workplace where no one is injured. Our site OSHA injury rate will be <1.0 by December 1996. Compliance process deficiencies will be zero by April 1996, including C-9 checklists, red tags, and safe work permits. Process Safety improvement will include 100% on MOC, 100% on focused training, 100% on leak-free commissioning and 100% on PSM compliance by December 1996. No incidents with community impact by December 1996. Dow caused distribution incidents will be reduced 55% by December 1996 and 90% by December 1998 with 1994 as the base year. 1995 Permit and Red Tag Audits - Division Required: (Ike and Wilbert check 5 of each per week per Division Guidelines) Permits Audited: 470 % Correct: 97.2% Red Tags Audited: 455 % Correct: 96.5% BBS Observations Data: (Department Data through regular Observations) Permits Audited: 1085 % Correct: 96% Red Tags Audited: 644 % Correct: 97% BBS Observations Data From CAII Shutdown: Permits Audited: 460 % Correct: 97% Red Tags Audited: 224 % Correct: 97% Fourth Quarter Dow only: Permits Audited: 39 % Correct: 91% Red Tags Audited: 45 % Correct: 90% Chlor-Alkali Department Safety Checklist Compliance: (Formerly C-9) Total Items Required: 370 Discrepancies: 8 % Compliance: 97.8% "WllN aQ X ^03 Discrepancies: 5 weekly checks on emergency horns and lights were missed. 2 annual training requirements were not completed (02/Combustible meter and Scott air pack) 1 annual audit was not completed (Flow check on sandblast unit) /?ev' C^J 00 C-ONF rr- ^965 TrjNTTAL CHLOR-ALKALIII EMERGENCY PLAN AUTHOR: Lot's Of Folks DEVELOPED: Unknown REVIEWED: N/A REVISED: 12/15/95 BY: D.L.Landry EMRPL440.DOC REVISION#: 3 APPROVED BY: Gretchen Leblanc EFFECTIVE DATE: 12/22/95 AREA: SAFETY TYPE: EMERGENCY PLANS I. OBJECTIVE: To ensure that the Public, Chlor-Alkali II Personnel, and all other Division Personnel are properly protected and informed in the event of an Emergency situation. This includes the safe and orderly Shutdown of CA II. II. REVISIONS: 12/15/95 Added Level I and II Freeze Plans to Section III. Added 4. Severe Freeze to Section V, B. Reworded Section XIV., B, 2 to include requirement for personnel searching plantsite alone to carry radios. Added new Section XXI on Severe Freeze and re-numbered remaining sections. 12/28/94 Miscellaneous corrections throughout the entire plan and the addition of new sections: IV-C-5, Vlll-T, Vlll-U, Xl-D-E-F-G-H, XVII-G. MAJOR REWRITE. 07/30/93 Changed Control Room Breathing Air Description III. REFERENCES: Louisiana Division Emergency Plan Manual Chlor-Alkali II Hurricane Preparation Procedure Chlorine Leak Response Procedure Computer Room Fire Procedure Level I and II Freeze Plans for CA II IV. POSSIBLE INTERNAL EMERGENCIES: A Power Failures B. Chemical release to Air, Ground, or Water (Chlorine, Caustic, HCL, H2S04, Oil, Carbon-Tet, Fuel Gas, Hydrogen, Sodium Hypochlorite, Sodium Bisulfite). C. Fires 1. Hydrogen Fires 2. Building Fires 3. Oil Fires Chlor-Alkali II Operating Procedures EMRPL440 DOC Dow Confidential A 029655 CONFIDENTT AL. 3/10/96, 12:57 PM Page i of 17 4. Fuel Gas Fires 5. CL2 - Fe Fires D. Hydrogen Air Explosion E. Hydrogen Chlorine Explosion F. Nitrogen Trichloride Exothermic Reaction G. Injuries: Chemical, Falls, Etc. V. POSSIBLE EXTERNAL EMERGENCIES: A. Chemical Release B. Weather 1. Hurricane 2 Floods 3. Tornadoes 4. Severe Freeze C. Bomb Threats D. National Emergencies VI. PERSONNEL: SHIFT MAKE UP 5 People (1 - Operations Supervisor, 2 - S O S 'S, 2 - O.S.) DAY PERSONNEL 19 Dow People (Approx.) 15 Craft People (Approx.) VII. HAZARDOUS CHEMICALS AND QUANTITIES: Chemical Quantities Stored Carbon Dioxide Carbon-Tetrachloride Caustic - 50% (100% Basis, Non-Flammable) Cell Effluent (9% Caustic, 100% Basis, Non-Flammable) Chlorine Liquid And Gas Fuel Gas Hydrochloric Acid Hydrogen Gas Production Hydrogen Gas (Tube Trailer) Oil Sodium Hypochlorite Sulfuric Acid Sodium Bisulfite 100,000 Lbs. 1,000 Gal. 18,300,000 Lbs. 2,600,000 Lbs. 300,000 Lbs. 1,000,000 CFH 60,700 Gal. 9,000 SCF/Min 0 To 30,000 SCF 53,000 Gal. 851 Lbs. 32,000 Gal. . .8,000 Gal. Liquid Chlorine Capacities of Plant Equipment under normal operating conditions: Chlor-Alkali II Operating Procedures EMRPL440 DOC Dow Confidential ><5656 slT l AL LIQUID CHLORINE PIPING: LINE SIZE 1/ ,, ,,3'/2ti u 1" iv 2" 2 V2" 3" 6" CAPACITY PER 100' OF PIPE (LBS.) 20 35 56 132 218 480 827 1876 LIQUID CHLORINE EQUIPMENT: TAFFY POT T-205 T-204 D-501 D-526 T-503 T-35 E-531 SHELL D-511 E-511 HEAD E-512 HEAD D-529 4.000 12.400 700 8,500 2,600 2.400 150.000 18.000 2,000 2,000 800 2,600 VIII. EMERGENCY ALARMS AND EQUIPMENT: A, Emergency Horn - Used to communicate Immediate Emergency Condition and Block Evacuation of Craft Personnel. B. Battery Powered Lighting in the Control Room and Motor Control Center. C Sprinkler System (located over C-201 A) manually activated from the Control Room. D. Twelve Deluge Guns, strategically located. E. One Portable 150# Dry Chemical Fire Extinguisher and one Portable 75# C02 Fire Extinguisher. F. Three 2 Bottle and One 6 Bottle Fresh Air Breathing Apparatus on carts. G. One Control Room Breathing Air System connected to 12 Fresh Air Bottles with enough air to supply three Operators with air for greater than 90 minutes. H. Thirteen Scott Air Pacs located in the Control Room Building. I 5-Minute Escape Packs located throughout the Plant Chlor-Alkali II Operating Procedures EMRPL440 DOC Dow Confidential 3/10/96, 12:57 PM 00 A 029657 Page 3 of 17 confidential J. Spare Canisters for Full Face Masks, located in the Control Room Building. K. Hand-Held Fire Extinguishers Located Throughout The Plant. L. Electrical Flashsuits located in the Motor Control Centers. M. Steam Snuffing Systems for Gas Turbine Tunnel Oil Fires. N. Safety Showers with Alarm System in the Control Room identifying location. O. Bumpless Transfer System (U.P.S.) for Supplying Power to the TDC and MOD 5 Process Control Computers. P. Two Battery Banks for supplying power to the U.P.S. System and Critical Equipment. Q. Building Housing Absorbent Pads, Booms, Oil Sorb. R. Two Sandbag Storage Boxes for emergency use. S. Votrax Audible Alarm -Synthesized Voice for early warning of CL2 Cells Spill Potential. T. 02 Analyzers in the Field Instrument Houses Alarm in the Control Room. IX. ELECTRICAL FEEDERS: A. Two 14KV Electrical Motor Power Sources which can be automatically transferred. 1, Division Power Feeder H-10 2. Division Power Feeder H-28 B. 14KV Alternate Cell Power Source H-10 and H-28. C. 2.4KV Motor Power Feeders are: 1. L-21/Backup L-11, L-22 2. L-34 3. L-23 D. Two D.C. Battery Banks 1 Process Control Computer Backup MOD 5 2. Equipment D C. Oil Pumps (Backup) 3. Control Room Instrumentation 4. Plant Intercom System Fed from an Inverter (Backup) Chlor-Alkali II Operating Procedures EMRPL440.DOC Dow Confidential DO A 029658 CONFIDENTIAL 3/10/96, 12:57 PM Page 4 of 17 X. SAFETY EQUIPMENT REQUIREMENTS: Each Person is required to have. A. Hard Hat B. Respirator C. Monogoggles D. Hearing Protection E. Rubber Boots - For all Operating Personnel and Visitors entering the Caustic, Cell, and Acid Areas. Electrically Tested Boots are Required in the Cell Area. All Plant Visitors are required to use the Sign-In Book for visitors, located in the Office Professional's Office Area. All Dow In-Block Non-Operations Personnel must use the Sign-Out Board for Emergency Accountability. XI. EMERGENCY RESPONSE INITIATION: A, The Control Room (EXT.-8527) is the Central Point for all information and instructions during any Emergency. It is the responsibility of the Operations Supervisor or his/her substitute to see that the proper Emergency Procedure is activated and that evacuation, if necessary, is carried out in a safe manner B Reporting Emergencies: Any person discovering an Emergency Situation will immediately contact the Control Room and give the following information: 1. Location of the Emergency 2. Type of Emergency 3. Any other Pertinent Information The Control Room Operator will immediately sound the Emergency Horn, if necessary, and report it to Plant Security by dialing (EXT. 333.) He/She must report to Security the following: 1. His/Her Name 2. His/Her Department 3. The Type of Emergency (Fire, Spill, Injury, Etc.) 4. The Chemical Involved (Gas or Liquid, and Size, if Applicable). 5. The Location in the Block, if Applicable. 6. Any Specific help needed, if known (Fire, Truck, Ambulance, Etc.) If A Fire Truck or Ambulance is being dispatched, the Control Room Operator will direct someone to meet it at the appropriate Block Entrance. DO A 029659 CONFIDENTIAL. Chlor-Alkalt II Operating Procedures EMRPL440.DOC Dow Confidential 3/10/96, 12 57 PM Page 5 of 17 c. Upon Sounding of the Emergency Horn: 1. All uninvolved Dow Operations Personnel must report to the Control Room for instructions. 2. An announcement should be made at once regarding the Emergency. 3. If manpower is available, an Operations person should be assigned to monitor the Plant Ecology System. 4. The Safety Contact, Environmental Contact, MOD 5 Specialist, and the Instrument Supervisor, if present, should report to the Control Room for possible assistance. 5. All Burning, Welding, and other Potential Ignition Sources must be extinguished. 6. Block Craft Personnel will evacuate the Block and assemble at Block 35 Warehouse unless otherwise directed. I & E Personnel will shelter in the I & E Shop in B-3601. 7. All Non-Essential Dow Personnel (Personnel without Defined Emergency Responsibilities) and Visitors will report to the Conference Room in Building 3601, unless otherwise directed, for further instructions. Sheltering at that location is normal procedure. D. Response to Votrax Audible Alarm: The Votrax Alarm will clear area 1 due to the potential of backpressure of the Cells, as indicated by Pressure Transmitters on each Series. Unless a routine test of the Spill Alarm is being conducted, it must be assumed that a Hazardous Condition exists and the following actions taken: 1. All Craft Personnel are required to use Mouthbit Respirators and Leave Area 1. Normal assembly is at the Block 35 Warehouse. 2. The Control Room Operator will check Instrumentation to determine necessary actions to correct the situation. Assistance from the Outside Area Operator may be required and that person will use appropriate Respiratory Protection depending on present conditions and instructions from the Control Room Operator. See CL2 Leak Response Procedure. 3. Once the situation is corrected, or determined that it was a false alarm, an all-clear will be announced and the craftsmen may return to work. Unless otherwise instructed, work permits must be re-initialed or approved prior to returning to work. E. Response to CL2 Detection on Area Monitors: 1. The Control Room Operator will announce that CL2 is being detected in an area and that all personnel in that area are to use their respirators and leave the area. Those persons should evacuate to a crosswind location or the Block 35 Warehouse, depending on wind directions or instructions from Dow Operations. 2. The Control Room Operator will notify the Area Operator of the location and amount of CL2 being detected so that the Operator can safely investigate the source with appropriate Respiratory Protection. See CL2 Leak Response Procedure. 3. Once the source has been determined and the problem has been corrected, an all-clear will be given and personnel may return to work. Unless otherwise instructed, work permits will need to be re-initialed or approved prior to returning to work. Chlor-Alkali II Operating Procedures EMRPL440.DOC Dow Confidential DO A 009660 CONFIDENTIAL 3/10/96, 12:57 PM Page 6 of 17 F. Response to Instrument House 02 Alarms: These houses are equipped with 02 Analyzers with a green light for indication of adequate 02 content and a red light with Audible Alarm to indicate that the 02 content is at an unacceptable level. Personnel may not enter an Instrument House unless the 02 level is adequate. If an 02 Analyzer in one of these houses alarms, it will also alarm in the Control Room. Response is as follows: 1. The Control Room Operator will notify the Area Operator to check the house to verify that it is not occupied by personnel. The Instrument Analyzer Technician will be notified immediately to determine validity of the alarm. 2. Persons may not enter the house without first checking the 02 content with a portable meter. 3. In the event of an emergency, the Control Room Operator will notify Security at (EXT.#333) for assistance. G. Response to Safety Shower Alarms: 1. The Control Room Operator will immediately announce that there is a Safety Shower Alarm and the location of it. 2. Operations Personnel in the block must respond to the page immediately. Personnel responding to the page must be wearing all Area Required PPE. 3. Immediate assessment of injury and/or potential must be made upon arrival at the Safety Shower. Response to this assessment should be as follows: If the Shower Alarm was an accidental activation, the Control Room Operator must be notified and an all-clear given immediately. If the Shower Alarm was used to attract attention to an accident/injury other than a Chemical Exposure, such as a fire, unconsciousness, or a fall, the Control Room Operator must be notified immediately so that appropriate help can be called. If Chemical Injury and/or potential is evident, or even questionable, the very first and most important thing to do is to get the injured under the shower, clothes removed, if contaminated, and using the eyewash, if affected. If the injury's eyes are not affected by the Chemical Exposure, the Monogoggles should not be removed. If a Chemical Leak affects the safe use of the shower, the injured must be moved to a Safer Shower location. Precautions must be taken to prevent further injuries/exposures to all personnel. The second most important thing to do is to notify the Control Room Operator of the situation so that medical help can be called for. After help is called on (EXT. #333), the Control Room Operator will assign someone to meet the Ambulance at the nearest drive access to the shower. The injured must remain washing under the shower, or eyewash for a minimum of 15 minutes, or until told to stop by a member of the Dow Medical Team. 4. An all-clear will be given on the Shower Alarm when it has been determined that all necessary help has arrived on the accident scene and that the situation is under control. Chlor-Alkali II Operating Procedures EMRPL440 DOC Dow Confidential 3/10/96. 12.57 PM Page 7 of 17 `SS4&NTIal H. Response to Division Pages: 1. When division pages are made pertaining to Spills, Fires, etc. Originating from Blocks other than CA II, an assessment will be made as to the impact on CA II. Once this has been done, an announcement by the Operations Supervisor, or designee, will be made as soon as possible on the effects of the condition on CA II. More detailed responses are contained in Section XV., Part E, of this procedure. I. General Operator Responsibilities: 1. The Control Room Operator is the primary focal point for all communications in emergencies. He/she will direct the actions of Operations Personnel, as needed, during an emergency. 2. The extra S.O.S. on shift will report to the Control Room and assist the Control Room Operator as needed. ' 3. Outside Operators will address the emergency situation as is required and directed by Control Room Operators. 4. The Operations Supervisor will give direction, instruction, and assistance as needed. XIV. EVACUATION: A. The Plant will be Evacuated on Instructions from any of the following: 1. The Emergency Coordinator or Plant Security in a Division-Wide Emergency or release from an adjacent area. 2. The Chlor-Alkali Manager 3. The Chlor-Alkali II Plant Superintendent or His/Her Substitute, The Operations Supervisor, or Substitute. Unless specified otherwise, all Personnel will be Evacuated except the Shift on Duty, The Plant Superintendent, and those people specifically designated at the time of the Emergency to assist in Emergency Procedures. B. Personnel Evacuation Responsibilities: Block Supervision will be responsible for carrying out Evacuation of Personnel. During Day Working Hours; 1. The Craft Supervisor, with the assistance of the Block Foreman, will account for and direct the movement of Maintenance Personnel on the roadways Industrial Craft Foremen should report their workers accounted for to the Contract Supervisor or Foreman. 2, The Operations Supervisor and Permit Coordinator will inspect the Plant Site for Personnel injury and evacuation problems. Personnel searching the plantsite alone must have radio contact with the Control Room at all times.. 3 The highest level of Supervision of the Non-essential Engineering Staff will account for and direct the assembly and evacuation, if necessary, of all Non-essential Day Personnel and Visitors. Chlor-Alkali II Operating Procedures EMRPL440 DOC DO A 029662 Dow Confidential CONFIDFNTTAI 3/10/96, 12:57 PM Page 8 of 17 4. The Electrical Supervisor, with the Senior Dow Instrument person as backup, will account for and direct the Instrument Group and the Electrical Group. C. Emergency Radios will be carried by: 1. Operations Supervisor on Duty 2. Highest Level of Supervision in charge of Evacuation 3. Craft Supervisor D. In-Block Communications Radios will be carried by: 1. Permit Coordinator 2. Same Person as #2. in "C" above 3. Personnel searching plantsite E. All Radios should be used for Monitoring Purposes with the exception of Requested Updates and/or Reporting Emergencies. F. If an Emergency should occur at Night or on Weekends, the Operations Supervisor or Shift Leader will evacuate Personnel as they see necessary and assign a leader to carry a radio. G. Evacuees will remain together until the Emergency is cleared. H. Evacuation Routes: Emergency Conditions and Wind Direction will dictate Evacuation Routes. However, Normal Evacuations will be to Union Road at the South side of the Block, then East to Chlorine Road and Gate #1 or West on Union Road toward Gate #4. I. Assembly Areas: 1, Craft Personnel will assemble at Block 35 Warehouse unless directed to another assembly point. I & E Personnel will shelter in B-3601 Shop unless otherwise directed. 2. All Dow Non-essential Personnel will assemble at the Conference Room. The Office Professional, with the Safety Contact as backup will check the Visitors Sign-In Book and the Sign-Out Board and bring a Personnel Roster for a head count. The highest level of Supervision present will account for all personnel. If the Conference Room is not a safe place to meet, assembly should be at a Roadway Assembly Point. If these Assembly Areas are not accessible due to the emergency, the parking lot or North-South Road at the West Block limits should be used. An area located crosswind to a Spill will normally be the best location. If the decision is made to remain in the building (Cocooning or Sheltering), all building air intakes must be shut off. co^io Chlor-Alkali II Operating Procedures EMRPL440 DOC Dow Confidential 3/10/96, 12 57 PM Page 9 of 17 XIII. PLANT SHUTDOWN: A. Plant Shutdown will be executed on instructions from the following: 1. Chlor-Alkali Manager 2. Chlor-Alkali II Plant Superintendent Or Substitute. 3. The Operations Supervisor or Substitute. 4. The Emergency Coordinator or Plant Security in a Division-Wide Emergency. B. Upon completion of the Shutdown, the remaining Personnel may be Evacuated, depending on the nature of the Emergency. The Operations Supervisor and two SO.S.'s will remain except when severe danger exists. Note: If an Immediate, Total Evacuation is announced, the Crash Shutdown Procedure will be initiated and "all" personnel must leave as instructed. C Crash Shutdown Procedure: 1. De-Energize Generators. 2. Trip Gas Turbines 3. Ensure Adequate Instrument Air Pressure 4. Energize J-250 Dump Scrubber 5. Trip Chlorine Compressor 6. Activate EBV's 7. Trip C-520 8. Block In 235# Steam If Time and Conditions Permit, Proceed with an Orderly Plant Shutdown. XIV. POWER FAILURES: A. Chlor-Alkali II has seven (7) Electrical Feeders entering the Plant. A failure of any of the Feeders will result in a Plant upset. However, the most Critical Failure would be a loss of H-28 and the loss of H-10. In such an event: 1. Evacuate Craft Personnel. 2. Account for, and/or Evacuate, Non-Essential Dow Personnel. 3. Report any Chemical Releases to Plant Security on (EXT.-333). 4. Assure the Operation of the Chlorine Dump Scrubber. 5 Confirm the Operation of the Effluent Recovery System. 6, Stabilize Plant Condition. 7 Communicate with the Division Power Plant on failure. 8. Notify Supervision. Chlor-Alkali II Operating Procedures EMRPL440.DOC Dow Confidential DO A 029664 CONFIDENTIAL 3/10/96, 12.57 PM Page lOof 17 XV. CHEMICAL RELEASE (GAS) - CHLORINE/ACID/CAUSTIC/CARBON-TET FROM CHLOR-ALKALIII: A. If a Toxic Gas release occurs in this plant or from some other source which effects Personnel at CA II, we will normally continue to operate. Depending on the situation, that decision will be made by the Operations Supervisor or Control Room Operator in the Plant at the time of the incident. The Control Room Operator: 1. Sound the Emergency Alarm. 2. Notify Security using (EXT. 333) (If the Release is in CA II) 3. Issue Immediate Standby and/or Evacuation Communication, as applicable. 4. Notify Supervision. Remaining Operations Personnel: 1. Account for Block and Craft Personnel 2 Secure Plant B. Chemical Release (Liquid) Acid/Caustic/Oil/Carbon Tet/Sodium Hypochlorite from Chlor-Alkali to Outfall: A major Safety and Ecology problem could develop if any one of several 50% Caustic or Cell Effluent tanks developed a major leak. The Plant Area is not diked sufficiently to prevent a major Caustic Spill from entering the return canal. The best course of action would be to evacuate any people who might be exposed to the liquid and notify the Solvents Plant to dump HCL in the return canal to help neutralize the Caustic. (See Tank Spill Procedure following). Control Room Operator: 1. Notify Security using(EXT. 333). 2. Contact Solvents Plantof approach of material. 3. Notify Supervision. Remaining Operations Personnel: 1. Take Immediate Steps To Prevent Further Spillage. 2. Secure Plant Chlor-Alkali II Operating Procedures EMRPL440 DOC Dow Confidential DO A 009665 CONFTDFNTIAI 3/10/96. 12.57 PM Page ii of 17 C. Internal Chemical Release: Control Room Operator: 1. Evacuate necessary people from affected area. 2. Sound Emergency Horn if Total Block Evacuation is necessary. 3. See Division Guidelines on Internal Reporting of Releases. Remaining Operations Personnel: 1. Secure Problem Area. 2. Account for all affected Personnel. D. Waste Storage Spill Cleanup: To be added later E. Chemical Releases originating from Neighborhood Plants: 1. The Operations Supervisor or the Control Room Operator will assess the situation and make a judgement as to the duration and Concentration Exposure to CA II. A Block announcement, concerning the status and impact on CA II Block, should be made as soon as possible after the assessment has been made, A. Non-Essential Personnel may be evacuated and Plant Operation continued with Safety Precautions and Equipment. B. If Gas Turbine intakes are affected, Turbines may be shut down. Partial Plant Operations will continue. C. A decision may be made to initiate a Total Plant Shutdown and Evacuation. Chlorinated Methanes could release flammable materials which might carry into the CA II Block. The most likely material would be a Methylchloride Spill since they inventory a large quantity. If a large vapor cloud of Methylchloride entered CA II, all ignition sources should be shut off. The Methanes Plant is more likely to have an HCL or CL2 Spill which could enter CA II. Neither of these materials is flammable. That situation should be handled as an internal release as normally handled. The Chlorine I Plant is likely to have Chlorine Gas Releases which, at some time, will enter the CA II Plant. These can be handled as Plant Personnel normally handle our own releases. The Cellulose Plant is very unlikely to have an incident which would produce an emergency situation in the CA II Plant. Cellulose does inventory Propylene Oxide. If, for some reason, a Propylene Oxide Vapor Cloud occurred and did move into the CA II plant, it would be imperative to shut off all ignition sources immediately Propylene Oxide is extremely flammable and explosive. DO A 0296 CONFTDFNTT Chlor-Alkali II Operating Procedures EMRPL440 DOC Dow Confidential 3/10/96, 12:57 PM Page 12 of 17 XVII. FIRES: Fires should be reported to the Control Room, giving location and severity. At this time, without delay, action should be taken. If fire can be handled with Block Personnel, it should be. However, (EXT. 333) should be dialed, giving all necessary information. A. Hydrogen Fires 1. Stack Fire - Can be extinguished by switching stacks. Procedure should be followed carefully. 2. Hydrogen Headers - CA II Fire Protection for assistance. If fire cannot be extinguished with a water hose or fire extinguisher, cut load to 20KA and add Nitrogen to Hydrogen Log. B. Electrical Fires In most cases, Electrical Fires may be extinguished by opening necessary switches to isolate, then use Fire Extinguishers. Use C02 extinguishers first and dry chemical if C02 is not available. C02 is preferred over dry chemical, since the dry chemical leaves a powder residue that will require extensive cleaning. C Oil Fires Oil fires are more likely to get started around the Gas Turbine Areas. The Turbines run at very high temperatures and small leaks can occur. Temperature Monitoring Devices are installed in the Exhaust end of both G.T.'s and are indicated in the Control Room. In addition, fixed dry Chemical Extinguishers are located in this area for quick and effective fire fighting capabilities. 15# steam is piped into Gas Turbine Tunnels for extinguishing Oil Fires. If fires are of a small, contained nature, dry chemical will extinguish them easily. However, if the fire is large, Fire Fighting Equipment or Foam Application may be necessary. D. Building Fires: 1. Evacuate the Building of Staff Personnel. 2. Notify Plant Security on (EXT. 333). 3. Control Room Operators are to prepare to operate with Breathing Air. 4. Air Conditioning Unit should be shut down. 5. Electrical supply to affected areas should be de-energized. 6. Activate Halgon* System if Computer Banks are threatened. *Halgon will not support life, Breathing Air is necessary for entry following activation of the System. Refer to Computer Room Fire Procedure. 7. Standby for Operations Upset and possible shutdown. 8. Assist Plant Security, as possible. 9. Notify Supervision. c^^ntx6? Chlor-Alkali II Operating Procedures EMRPL440.DOC Dow Confidential 3/10/96, 12:57 PM Page 13 of 17 E. Fuel Gas Fires: 1. Notify Plant Security on (EXT. 333). 2. Direct Water Monitors to area to cool Equipment. 3. Hook up Nz, start a purge, and block in the fuel source. Allow the N2 to purge the fuel to the fire source. 4. Stabilize Plant Operation. 5. Notify Supervision. F. Hydrogen Chlorine/Air Explosions: 1. Notify Plant Security on (EXT. 333). 2. Account for Craft and Block Personnel. Inspect Plant Site for possible injuries. 3. Issue Immediate Evacuation Communications. . 4. Secure Plant. 5. Notify Supervision. G. Hydrogen Tube Trailer: The Hydrogen Tube Trailer becomes CA II responsibility when it enters the division destined for CA II. Air Products, the supplier of the trailer, has an Emergency Response Team available to counter or assist with emergencies. Contact is by way of 1-800-523-9374. (Painted on the Tube Trailer). Hz is very light and rises into the atmosphere rapidly. The immediate leak area has the most potential to ignite. During daylight, a Hz flame is nearly invisible Evidence of a fire will likely be from impacted surrounding materials, or from feeling the heat of the fire. In The Event Of A Leak Or Fire: 1. Notify Plant Security On (EXT. 333). 2. In the event of a leak, extinguish all ignition sources in the area, 3 Clear appropriate area of Personnel. 4, Direct Water Deluge Guns on the Tube Trailer for cooling as soon as a problem is detected. 5, Notify Air Products @ 1-800-523-9374 for possible assistance. 6, Evaluated the circumstances and determine if isolation is possible. The Division Fire Team will assist in this evaluation. To isolate, Protective Clothing must be worn and approach slowly (feeling for heat). If unable to approach for isolation, allow Hydrogen to burn until source is depleted. 7. Stabilize Impacted Plant Operations. 8. Notify Appropriate Supervision. XVIII. HURRICANES: oo 4 CONFIO 0-?9668 NTJAl Refer to Chlor-Alkali II Hurricane Procedure in addition to Section "B" of the Division Emergency Plan Manual. Chlor-Alkali II Operating Procedures EMRPL440 DOC Dow Confidential 3/10/96, 12:57 PM Page 14 of 17 XIX. FLOODS: Refer to Division Emergency Plant Manual, Section "C". XX. TORNADOES: The purpose of this Procedure is to keep people from working where quick escapes are not possible while conditions are favorable for Tornadoes, A. Tornado Watch A Tornado Watch means conditions are favorable for Tornadoes. When under these conditions, all jobs need to be evaluated to make sure no one is in a position to be trapped somewhere in the Plant without a chance to escape. Some examples are as follows: A. No work is allowed on piperacks. B. No work is allowed on Scaffolds over 10 feet tall C. All Vessel Entries will be canceled until watch is over. Also, an announcement should be made on the P.A. of the condition. Everyone should be familiar with the Safety Locations located throughout the Plant. B. Tornado Warning A Tornado Warning means Tornadoes have been spotted in the area. When under these conditions, all work is to stop and everyone is to report inside immediately No one is to go outside unless it is absolutely necessary. XXI. SEVERE FREEZE: Refer to CA II Level I and Level II Freeze Plans and the Division Plan. XXII. BOMB THREATS: Refer to Division Emergency Plan Manual, Appendix II XXIII. LOCATION OF CRITICAL BLOCK VALVES: All Critical Block Valves for Chemicals entering and leaving the CA II Block via pipelines are painted international orange and labeled as to the contents. Most of these valves are located in Block Limit Pipeways. These valves are all shown on one of the attached plot plans. Following the occurrence of any emergency, Plant Supervision will inspect and report any damage prior to start-up. XXIV. EMERGENCY RESPONSE FOR A TANK SPILL IN THE CAUSTIC AREA AND/OR STORAGE TANK AREA A. Problems/Hazards 1. Environmental Contamination A. B. Chlor-Alkali II Operating Procedures EMRPL440 DOC No existing dikes to contain spill Outer perimeter ditches bypass Permitted Outfall Dow Confidential 3/10/96, 12 57 PM Page 15 of 17 2. Property Damage 3. Safety - Chemical Exposure - Personnel Exposure since areas are well traveled. B. Definitions: 1. Massive Spill - A tank failure in which the contents are able to flow out without being restricted. This type of spill could dump contents of a Vessel in a short period of time. 2. Minor Spill - Small damage where contents can spill out at a low rate. Contents can be restricted or contained where the effects are not as critical. C. Spill In S-301 Area 1. Indication Of Spill Condition A. Visual Inspection of Tank B. Sump V Overflow Alarm C. Weir Level in S-301 Dropping for no apparent reason D. CA II Outfall pH rises suddenly (Only if contents of tank leaks into Power Trench) E. High pH in Ecology Area indicated by D-803's Filling Alarm and HCL Flow Deviation Alarm. 2. Response To Spill A. Notify Security of Caustic Spill (EXT.-333) B. Non-Essential Personnel Evacuation C. Isolate outer perimeter ditch by blocking culvert at Northeast corner of Block and Southwest corner of block. Pallets with sand bags and a drum lid are located by both locations. Place the drum lid in front of the culvert and pile the saftd bags behind the lid. D. Stop any product from entering the tank and transfer as much out of the tank as possible to minimize spill loss. D. Spill In Caustic Storage Areas 1. Indication Of Spill Condition A. Visual Sighting B. Erratic Level change in Tank C. Unexplained high pH in Ecology Area as indicated by D-803's Filling Alarm and/or HCL Flow Deviation Alarm. 2. Response a o2<?670 A. Notify Plant Security of Spill Condition (EXT.-333) CONF 7 DFNt B. Evacuate Non-Essential Personnel from area C. Isolate outer perimeter ditch by blocking the culvert at the Northeast corner of the Block and the Southwest corner of the Chlor-Alkali I! Operating Procedures EMRPL440 DOC Dow Confidential 3/10/96. 12 57 PM Page 16 of 17 Block. Pallets with sand bags and a drum lid are located by both locations. Place the drum lid in front of the culvert and pile the sand bags behind the lid. D. Stop any product from entering the tank and transfer as much out of the tank as possible to minimize the spill loss. E. If the spill is flowing across the road on the Western perimeter of CA II, keep an eye on the River Water Canal which supplies Cellulose and Methanes to make sure none of the spill is flowing into that canal. If it appears that any material may get into the canal, notify Cellulose and Methanes. XXV. SHUTDOWN OF BUILDING 3601 AIR HANDLING UNITS IN THE EVENT OF A SPILL OR FIRE (IF ACCESSIBLE): The Safety Contact, witn the Environmental Contact, and the MOD 5 Specialist, as backups, will shutdown the following Units: Laboratory A/C Unit Lunchroom A/C Unit Air Handling Units for B-3601 - Three Breakers in the NE corner of the Control Room on panels behind Caustic MOD 5 cans: DP-1-Bkr-1 (Labeled with Red Tape) DP-1-Bkr-2 (Labeled with Red Tape) Breaker next to DP-1 (South Side, Labeled with Red Tape) MCC 103 #7/2 (Control Room A/H Unit on Roof) After consideration, it was felt that the Computer A/H Unit could be left running. Important Note: Although Designated Personnel are responsible for shut down of the A/C and A/H Units, all CA II Personnel should be familiar with these locations for shutdown in the event that the above-mentioned Personnel are absent at the time of a Spill Chlor-Alkali II Operating Procedures EMRPL440 DOC Dow Confidential 029671 CONFIDENT I A!.. 3/10/96, 12:57 PM Page 17 of 17