Document EdDvQ0xnr3b38KVoXvRe1LLjn

o*& DOW U. S. A. Consolidated Audit Program POLYETHYLENE A PLANT - LAD draft Date ofReport: Superintendent: 10/9/96 Tony Grant, Bldg. 807 - LAD ~~ A/Lw cc: Buck Bailey, Bldg. 3301W, LAD Mike Young, Bldg. 807 LAD /'/,*** Chris Messelt, Bldg. 3502W LAD Allen Chauffe, Bldg. 807, LAD dc-`Aaa.C'v//; S*. Enclosed are the recommendations from the various audits for your response. According to ^ > ' o the Dow U.S. Area Consolidated Audit Program Guidelines and the OSHA Process Safety ` ,c Management (PSM) standard 1910.119, you must develop an implementation plan as a response to the recommendations. The plan must include the name(s) of the employee(s) ( assigned to each action item along with an expected and actual completion date for each--t*9 / item. /Vr7\^li/ Please note that efforts have been made by the Functional Audit Teams to help prioritize each recommendation. They will be identified as: M = Must Do, (based on compliance issues, government regulations, Dow policies or S&LP) and HR = Highly Recommended, (necessary to mitigate an anticipated or potential hazard). It is the responsibility of the plant/department supervision to communicate the results of the consolidated audit to all employees. Communication must include the results of the Process Hazard Analysis. PHA's include the Reactive Chemicals, Chemical Exposure Index (CEI), Process Safety and Loss Prevention/Fire/Burner Management audit and the Employee Survey Results. This must be completed within 90 days after the audit report date and documented. Please send your approved implementation plans to Connie Kalencki, Bldg. 3502W by December 8, 1996. We will forward a copy to members of the Core Audit Team and the appropriate section to the Functional Team Leaders. Enclosed Audit Recommendations: 1. Process Hazard Analysis 6. 2. Laboratory Audit 7. 3. Reactive Chemical Audit 8. 4. Loss Prevention/Fire Audit 9. 5. Hazardous Materials Transportation Review Occupational Health Audit Electrical Reliability Audit Security Audit Safety Audit Howard Wilkinson, Administrator LAD Consolidated Audit Program DO A 061890 CONFIDENTIAL LAD PROCESS HAZARD ANALYSIS (PHA's) Recommendations: 1. Communicate results of the Consolidated Audit to plant personnel within 90 days after the audit report date and document Guidelines For Communicating Process Hazard Analysis (PHA's) To Employees The OSHA Process Safety Management (PSM) Standard (29CFR 1910.119) requires that facilities covered by this standard perform a formal process hazard analysis, communicate the results of this analysis to plant employees whose work assignments are in the process and who may be affected by the recommendations or actions. Currently the LAD Consolidated Audit Process include PHA's (reactive chemical reviews, hazardous materials transportation reviews, chemical exposure index audits, fire & explosive index reviews). The following guidelines can be used to communicate the Process Hazard Analysis (PHA's) to plant employees. Communication to employees may be done in a regular scheduled safety meeting or during a safety training day and documented. REACTIVE CHEMICAL REVIEW: A. Review all worst case scenarios identified by the plant and LAD Reactive Chemicals Committee. Make sure that plant personnel have a thorough knowledge of the reactive chemicals potential. Discuss the safe operating limits and consequences of deviation. Discuss the reactive chemical control systems including hardware, software and procedures. Discuss all other safeguards or action plans that are aimed at avoiding and mitigating the consequences of each scenario. B. Review the recommendations from the LAD Reactive Chemicals Committee and the plant action plans to correct the recommendations. C. Review the results of the employee interviews which are done by the LAD Reactive Chemicals Committee during the Consolidated Audit and the plant follow-up actions to address any deficiencies. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL Page 2 DO A 061891 CONFIDENTIAL CHEMICAL EXPOSURE INDEX REVIEW: The Chemical Exposure Index (CEI) provides a simple method of rating the relative acute health hazard potential to people in neighboring plants or communities from possible chemical release incidents. Absolute measures of risk are very difficult to determine, but the CEI system will provide a method of ranking one hazard relative to another. A. Review the list of plant hazardous chemicals that were evaluated by the plant. B. Review the worst case scenarios and calculated CEI value. This shall include dispersion data and charts that were developed from the plant CEI review. C. Review all actions required to prevent the worst case. It may be a simple case of reviewing employee job responsibilities from an existing plant emergency drill. Any preventive maintenance, thickness checks, Technology Center recommendations, visual inspections and recommendations from the consolidated audit team should be reviewed also. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date FIRE & EXPLOSION INDEX: The Fire & Explosion Risk Analysis System is a step-by-step objective evaluation of the realistic fire, explosion and reactivity potential of process equipment and its contents. The purpose of the F&EI system is to: 1) Quantify the expected damage of potential fire, explosion and reactivity incidents in realistic terms. 2) Identify equipment that would be likely to contribute to the creation or escalation of an incident, and 3) Communicate the F&EI risk potential to management. A. Review the plant F&EI process units and classified hazard levels ("heavy", "moderate" etc.). See Table 6, pg. 38 - F&EI Guide, 7th edition. B. Review the list of process units in your plant that were reviewed. C. Review the evaluation of realistic fire, explosion and reactivity potential of the process unit and its contents. (Depending on the level of hazard, certain process equipment spacing, process equipment/piping standards and loss prevention principles are applied to the process to minimize the hazard level). Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL DO A 06189? CONFIDENTIAL Page 3 OCCUPATIONAL HEALTH AUDIT (Tuesday, August 27, 1996) AUDIT TEAM: Darlene Creel, Nancy Randolph, PLANT/ CONTACT: ATTENDING: Geralyn Trabeaux Howard Wilkinson, Buck Bailey, Allen Chauffe, Michael Leopold, Gerlyn Trabeaux, Clay Ainsworth, Tony Grant, Karen Williams, Darlene Creel WRITER: Darlene Creel GENERAL INDUSTRIAL HYGIENE/MEDICAL The I.H. Manual is complete and contains all the written programs (Hazard Communication, Hearing Conservation, Respiratory Protection, and Personal Protective Equipment). All necessary permanent postings (eg., Employee Rights under VPP and OSHA, OSHA Noise Standard, Job Safety and Health Protection, etc.) are located on bulletin board in lunchroom adjacent to the control room. All of the programs will be updated and put in the Operating Discipline format by the end of 1996. Recommendations: No recommendations at this time. HAZCOM PROGRAM Poly A Facility employees received HAZCOM training in 1995.The labeling of plant equipment and process area's were good; the analyzer houses had good warning signs. The HAZCOM/MSDS notebook are readily available in the control room area with up to date components (written program, list of chemicals, vessel/ID cross reference table, and MSDSheets). Recommendations: M 1. Label Heptane Bath in lab to comply with Hazard Communication labeling requirements (29CFR 1910.1200). Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL Page 4 DO A 061893 CONFIDENTIAL M 2. There are chemicals in the old lab that has been removed from the CPAI (Chemical & Physical Agent Inventory) and MSDS book because they are no longer used. They need to be disposed of properly. (29CFR 1910.1200). Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HEARING CONSERVATION The facility's written Hearing Protection Program is current, and annual training was conducted during 1995. Hearing protectors are readily available in storage bins at several locations in the block. The OSHA Occupational Noise Standard, 29 CFR 1910.95 is posted on the bulletin board in the lunch room adjacent to the control room. Recommendations: M 1. Install "Hearing Protection Required" sign near grinder in maintenance shop (S&LP Standard, S-103). Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date RESPIRATORY PROTECTION The facility's written Respiratory Protection Program is current and training was conducted during 1995. The mouthbit, escape only, equipment storage cabinet outside the control room area is well organized and maintained. The plant respirator cleaning station is posted and equipped with the necessary supplies. Recommendations: M 1. Correct labeling of Control Room Board breathing air hook-ups. The information is misleading by stating "Open Valve Behind Board", when the valve is not exactly behind that particular board (S&LP Standard, S-102) Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL DO A 061894 CONFIDFNTIAL Page 5 M 2. Remove dust mask respirators from tool storage cabinets and store in the appropriate location in the warehouse (CFR 1910.134). Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 3. Add to the monthly checklist or remove Scott-Air Pak stored in closet by the Permit Office (CFR 1910.134). Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date PERSONAL PROTECTIVE EQUIPMENT The plant's written program is current for 1995. Recommendations: No recommendations at this time. ERGONOMICS Ergonomics training was done in 1995. Recommendations: No recommendations at this time. THERMAL STRESS Heat Stress training was done in 1996. Postings are on the bulletin boards reminding employees of the necessary precautions relating to heat stress. Recommendations: No recommendations at this time. M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL Page 6 DO A 061895 CONFIDENTIAL VENTILATION The last comprehensive hood survey was performed by D& D Laboratories in July 1995. Recommendations: M 1. Before Lapping table is put back into service, contact Industrial Hygiene Department on possible relocation of table (29CFR 1910.94). Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 2. Install static pressure indicator on Laboratory fume hood exhaust duct (29CFR 1910.94). Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 3. Remove PPE, i.e. lab aprons, from restricting airflow to the fume hood. (29CFR 1910.94). Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 4. The lab fume hood sash is restricted to a 12" sash opening. Relocate the stopping block to the 12" mark to keep the sash from opening to greater than 12". (29CFR 1910.94). Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date WELDING Sources of ventilation for the welding area include wall fans and large doorways. Recommendations: No recommendations at this time. M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL Page 7 DO A 061896 CONFIDENTIAL ASBESTOS Poly A facility's asbestos communication program includes block entrance signs, an ACM inventory, and periodic Hazcom type training. Recommendations: No recommendations at this time. RADIATION Radioactive devices are located in several areas of the plant. The Certificate ofResponsibility is signed. The State Nuclear Energy Division Notice is posted in the lunch room. Recommendations: No recommendations at this time. LABORATORY AUDIT (September 17, 1996) AUDIT TEAM: A1 Ribes, Howard Wilkinson, Mark Ryland PLANT CONTACT: Mark Ryland WRITER: Howard Wilkinson, A1 Ribes All action items from the first audit have been completed. Recommendations: HR 1. Remove Argon And Oxygen cylinders outside of B-807. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 2. Demolish Nitrogen line to outside B-807 lab. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 3. Discard all old reagents, old oil samples and old bottles/chemicals under hood in B-807. M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL Page 8 DO A 061897 CONFIDENTIAL Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 4. B-804 Lab - Label food refrigerator in break room with a "No Chemical" sign. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 5. Replace all mercury thermometers with digital thermometers. If not, develop and communicate mercury clean-up procedure. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 6. Clean out chemical storage cabinet outside B-807. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date ELECTRICAL RELIABILITY AUDIT SUMMARY AUDIT TEAM: Billy Stears, Larry Oubre, Phil Bruder WRITER: Billy Stears The electrical reliability audit for Polyethylene A Plant was conducted in July, 1996 as per the Five Point Electrical Reliability Program. The overall condition of the electrical assets of Polyethylene A plant are good. Those items identified with an index of 4 or higher in the Electrical Reliability report need some attention and require a response. Please refer to the report. M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL Pa ec 9 DO A 061898 CONFIDENTIAL Recommendations: M 1. Proper labeling oftransformers and motors per S&LP S-214. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 2. All Items rated 4.0 or above or marked with an * require a response, (see report) Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 3. Electrical room doors: Install exit signs or lights per OSHA 1910.38(Q). Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 4. Remove PCB's signs on L-62 structure. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date REACTIVE CHEMICALS AUDIT (Tuesday, September 16, 1996) AUDIT TEAM: Buck Bailey, Gerald Wagener, Joe Schell ATTENDING: Howard Wilkinson, Joe Schell, Gerald Wagener, Buck Bailey, Tony Grant, Karen Williams, Allen Chauffe, Michael Leopold, Clay Ainsworth PLANT CONTACT: Tony Grant, Karen Williams WRITER: Gerald Wagener M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL Page 10 D A 062899 CONFTDFNTTAL Recommendations: HR 1. Concerning the Polyethylene "A" 10 Process Commandments: Degress C or F should be added to all temperature references. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 2. Concerning the risk of a dust explosion during addition of Zinc Stearate to the mineral oil tank:--Measure the oxygen concentration in the head space of the tank just prior to addition of the Zinc Stearate. If less than 10%, the potential for a dust explosion is practically non-existent.--If over 10%, data on the minimum ignition energy should be obtained to determine if static discharge could initiate a dust explosion. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date SECURITY AUDIT SUMMARY (Tuesday, June 25, 1996) AUDIT TEAM: Joe Goodwin PLANT CONTACT: Allen Chauffe WRITER: Joe Goodwin, Howard Wilkinson Employees challenge strangers in their work areas. A sign-in/out log is available for visitors to the plant in the control room area. Employees wear their ID badges in the work areas. Emergency communications and alert systems are in place and working well. Keep up the good work. Recommendations: None at this time M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL DO A 061900 CONFIDENTIAL Page 11 LOSS PREVENTION/FIRE/BURNER MGMT./CEI REVIEW (Tuesday, September 15, 1996) AUDIT TEAM: Buck Bailey, Karen Williams, Tony Grant, Bob Armstrong, Bill Franklin PLANT CONTACT: Karen Williams ATTENDING: Don Jones, Howard Wilkinson, Buck Bailey, Tony Grant, Karen Williams, Allen ChaufFe, Clay Ainsworth WRITER: Buck Bailey Following is a list of recommendations from the recent Consolidated Audit conducted at the Poly A plant. These were developed from a standard Loss Prevention questionnaire, plant inspection, and discussions with the plant staff and Technology Center. HR 1. Poly A experiences a significant number of "false alarms" from the MCC smoke detectors located in the switchgear cabinets. Correction usually requires, cleaning dust from the detectors. Develop and implement a plan to reduce the dust level in the MCC's. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 2. Following the Corporate "Process Risk Management Guideline - 1994, a F&EI greater than 128 requires a further risk review. For Poly A, two areas, the reactor and the peroxide storage, meet this criteria. The generally recommended method of analysis is the HAZOP study for the area in question. Contact Loss Prevention to further consider the benefit and plan of action for this risk analysis. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 3. Continue working with the Tech Center to decide whether to install video cameras in the reactor bays. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL DO A 061901 CONFIDENTIAL Page 12 HR 4. Conduct an audit of the product warehouse using the Corporate "Guideline for Warehouse Rating and Risk Analysis" checklist. Pass this on to the Material Handling group to contact Loss Prevention. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 5. Recent industry feedback indicates that OSHA is becoming particularly interested in building and control room siting issues. Describe in the "Equipment/Building Location" section the features that exist to minimize the risk due to a fire / explosion in the area. Ex. HAD activated sprinkler system, minimal occupancy in B-801. Consider the possibility and benefit of tripping the adjacent sprinkler systems with the combustible gas monitor system. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 6. Contact LHC to determine who "owns" the Poly Recycle lines and who should perform the periodic inspections. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 7. Follow up with Loss Prevention to complete the insurance package of information for the Corporate Insurance Department. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 8. Have Engineering drafting create a permanent F&EI plot plan drawing to show the calculated scenario circles. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL DO A 06190? CONFTDFNTI Al Page 13 SAFETY AUDIT (Tuesday, June 25, 1996) AUDIT TEAM: Don Jones, Howard Wilkinson, Julie Broome, Eddie Supple, Brian Pope, Ma Mitchell and Pam Usie, Mike Young PLANT CONTACT: ATTENDING: Allen Chauffe Buck Bailey, Howard Wilkinson, Allen Chauffe, Tony Grant, Karen Williams Clay Ainsworth, Geralyn Trabeaux, Mike Leopold WRITERS: Don Jones, Howard Wilkinson, Eddie Supple SAFETY QUESTIONNAIRE A. Program Structure and Planning No Recommendation B. Employee Participation No Recommendation C. Contractor Safety No Recommendation D. Accident/Incident Investigation and Reporting No Recommendation E. Audits No Recommendation F. Safe Work Practices No Recommendation G. Emergency Planning and Means of Egress No Recommendation H. Employee Training ** No Recommendation M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL DO A 061903 confidential Page 14 L Safe Operation of Motor Vehicles and Motorized Handling Equipment No Recommendation J. Off-The-Job Safety No Recommendation EMPLOYEE SURVEY Recommendations: HR 1. Review Pre-Audit Safety Survey results and take appropriate action. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date DOCUMENTATION & FIELD AUDIT w / j, > J* AUDIT TEAM: Julie Broome, Roddey Peebles, Pam Usie, Mark Mitchell, Brain Pope, ` Howard Wilkinson, Don Jones, Bob Gibson - Contract ~rC U M 1. Review CEI &FEI. Show plot plan with circles of influence. o\ 'X K. Williams Complete Follow-up: After the date has been miewed and up-dated the plan will be communicated to employees. 6/1/96. Read and sign communication posted 5/2/96. HR 2. Frequency of mechanical integrity inspections need to be reviewed with operators. B. LeBlanc M 3. Hansen quick connect air fittings on plant air ( several places ) in B-812. B. LeBlanc M 4. Emergency light in Millwrights shop doesn't work B-812. B. LeBlanc Complete 9/2/96 D0 A 061904 CONFIDENTIAL M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL Page 15 Follow-up: Work order put into system to have light repaired. M. Darensbourg, 8/14/96. W.O. # 76445050. Actual Completion Date M 5. Lean-to shop south west ofB-812, fire extinguisher last inspection date was June '92. A. Chaufle Complete 5/96 Follow-up: Annualfire extinguisher inspections are due in May. Will include this area in inspection process. Actual Completion Date M 6. Deluge trip valve north of D-250, wire terminal box is in bad condition and cover for trip linkage is not in place. A. Chauffe Follow-up: Calledfire protection 4/10/96. They will check out this box on their next quarterly audit Inspected by M. Darensbourg 8/14/96. Box still in bad shape. Put work order in to make repairs. W.O. # 76449950 M 7. Need toe boards around openings in grating decks, north ofHM-106B, HM-103B, above BAC- 7A/B, and above BAC-7C. K. Williams Follow-up: Expected completion date --10/1/96. HR 8. Large step-up to first rung of ladder to HMB-107. K. Williams Follow-up: Expected Completion date = 10/1/96. M 9. Utility stations not labeled. Air, water, steam, etc. K. Martin Follow-up: Labels were ordered 6/28/96 by M. Darensbourg. 8/14/96 labels still not in. M 10. Drum of oil next to C-202 not grounded. K. Martin / B. LeBlanc Follow-up: Work order in systemfor grounding by M. Darensbourg 8/14/96. W.O.# 76445200. M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL DO A 061905 CONFTDFNTTAL Page 16 M 11. Seold in MCC-5 says sheet #2 of 2; where is sheet #1? Last date on sheet 1/93. B. LeBlanc Complete Follow-up: Sheet updated 4/15/96. W.O. # 76450000 M 12. Seold in MCC-7 says sheet #2 of 2 ; where is sheet #l?Door partially blocked in MCC-7. B. LeBlanc Complete Follow-up: Sheet updated 4/15/96. W.O. # 76450000 M 13. Exit signs not lighted in B-804. Emergency lighting? A. ChaufTe Follow-up: Work request has been put into the systemfor lights to be installed Work Order # 76228750. ( Project) M 14. No load rating posted top ofB-804 by elevator. Area needs housekeeping. K. Martin Follow-up: Tried to make contact with elevator company againfor capacity rating with no luck, 8/14/96. M. Darensbourg. M 15. Fire extinguisher last inspection date '93 in storage area in B-804. A. ChaufTe Complete Folloyv-up: Annualfire extinguisher inspections are due in May. Will include this area in inspection process. M 15. Oil drum located at Aru #1 area not grounded. K. Martin / B. LeBlanc Followup: Work order in systemfor grounding by M. Darensbourg 8/14/96. W.O.# 76445200. M 16. Some compressor guards not connected at bottom. Some have larger holes than others. B. LeBlanc M 17. Ungrounded oil drums by C-109. K. Martin / B. LeBlanc Complete Folloyv-up: Work order written to install ground by M. Darensbourg, 8/14/96. W.O. # 76445200. DO A 061906 CONFIDFNTTAl. M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL Page 17 M 18. Monogoggle areas unclear, some painted on grating, others just signs. B. LeBlanc M 19. Pipe stand without slip ring under crane south endof B-803. B. LeBlanc M 20. Old style red tag on fan switch on south end of B-803. Unreadable. ICMartin HR 21. Insulation broken off and hanging from valve between Er-107/ 113. B. LeBlanc M 22. Not all slings have tags on them. B. LeBlanc M 23. Harness not inspected, lanyard expired in B-820. B. LeBlanc M 24. Ground wire for T-2 is spliced. K. Martin Follow-up: Work Order U 75898550 put into system by M. Darensbourg 6/28/96 to have wire replaced. M 25. Rope braces holding conduit near skimmer under deck of B-809. B. LeBlanc M 26. Many lights are out in compressor building B-809. B. LeBlanc Follow-up: Many lights were repaired 6/24/96. Lights are being addressed by electricians. ( Project) HR 27. Poison com in both compressor buildings. Is program complete? K. Williams Follow-up: This task is still in progress. When complete housekeeping will address this issue. M 28. Can't read crane capacity on north end B-819. B. LeBlanc HR 29. Catalyst pump yellow lines on floor need to be repainted. B. LeBlanc M 30. Loose grating on cable tray walkway 30 feet north of K-650 and another 50 feet south of K-650. Many clips loose or gone. B. LeBlanc M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL DO A 06190 CONF7DFNTIA Page 18 M 31. High voltage line? Hanging low to walkway crossing return canal. B. LeBlanc HR 32. B-810 freon storage lights not working. Water kegs stored inside with chemicals. B. LeBlanc / K. Martin M 33. AC-5 roofhas no guard rails or ladder guard. K. Williams Follow-up: Expected completion date - 6/1/97. (Project) HAZARDOUS MATERIALS TRANSPORTATION REVIEW (HMTR) AND DISTRIBUTION FACILITIES ASSESSMENT (DFA) (Monday, July 1, 1996) AUDIT TEAM: Dean Smith PLANT CONTACT: WRITER: Dean Smith HAZARDOUS MATERIALS TRANSPORTATION REVIEW Areas Reviewed: Cargo Tank Unloading Drum Off-loading D.O.T. Compliance Chemicals Reviewed: DRI # Transportation mode(s): __________ Highway_____________ DTBP -Di tertbutyl peroxide in Isopar C 4 * Bulk truck Isopar C 3 * Bulk truck Isobutane 4 * Bulk truck Methanol 4 55 gal drum PIV - tert-butylperoxypivolate * Bulk truck in Isopar C & Mineral Spirits 4 TPA-tert-butylperoxyacetate 4 * Bulk truck in Isopar C & Mineral Spirits TPO-tert-butylperoctoate 4 * Bulktruck t-b-peroxy-2-ethylhexanoate+naphtha+224-trimethylpentane (All incoming) M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL DO A 061908 CONFIDFNTT AL Page 19 HAZARDOUS MATERIALS TRANSPORTATION REVIEW - HMTR Inbound Bulk Material / Drum Off-Loading: M 1. No procedures found for off-loading drum receipts of methanol; procedures need to be in place for off-loading a DOT regulated commodity. This may be in the form of a check list and/or written procedures outlining DOT requirements as well as block safety requirements. Also, if contract/laborer is used to off-load truck, this person needs have DOT HazMat Employee training. If this person is only used to move pallets of hazardous materials to another location, they will need to have HazCom and PPE training as required by OSHA DISTRIBUTION FACILITY ASSESSMENT - DFA M 1. Check lists are part of the process of assigning responsibility; these checklists must be legibly signed - not initialed. Compliance related items: Tank Truck Area - Safety: HR 1. Some warning signs are present, but others are needed to insure driver awareness of safety requirements and hazards. HR 2. Some lines and valves with contents are identified - but there is a need to replace some and add others. HR 3. Isopar, Isobutane and initiators are unloaded on a concrete slab with some containment provided, however, an entire truck load cannot be contained. Additional comments: The HazCom manual is in bad shape - copies of MSDS's are out of date, tom and worn as well as being out of any kind of order. The I.H. dept, and/or the supplier can be contacted to replace MSDS copies as needed. Thanks to Garland Maxwell for his time and efforts in assisting with the completion of this review and assessment. Thanks to George Moore for a very smooth and cooperative review. Overall, the Poly B Plant is in excellent shape. M = Must-Do HR = Highly Recommended DOW CONFIDENTIAL ^ A 061909 CONFIDENTIAL Page 20