Document QgxpMK7z9rr0v8wN9rVrYvkqE

CHEMICAL EXPOSURE INDEX AUDIT CHLORINE I LOUISIANA DIVISION JULY 1991 Paul Yonts July 17,1991 CE1:AA3 DO A 0P3605 CONFIDENTIAL CHEMICAL EXPOSURE INDEX AUDIT PREPARATION INSTRUCTIONS These Audit Instructions are being sent to Louisiana Division plants/departments as an audit to be accomplished in the Consolidated Audit Program. You should start your preparation early to assure a thorough review package. A copy of the audit package should be sent to the Functional Team Leader at least ten calendar days prior to the audit. A AREAS OF CONCERN Only the area(s) of your operation which has a calculated Chemical Exposure Index(es) greater than 100 is covered by this audit, or those that show an odor detection radius beyond the fence line. (A CEI of less than 100 requires a review by the Superintendent and his Manager only!) B. REVIEW PACKAGE The following package requirements must be completed and sent to the Louisiana Division Auditing Facilitator at least 10 calendar days prior to the audit. 1. UST OF ALL CHEMICALS FOR WHICH CEI CALCULATIONS DONE This includes those with CEI's less than 100 or those with a potential odor detection beyond the fence line. 2. A CHEMISTRY SHEET This sheet should include all desired reactions as well as all undesired reactions. 3. A SIMPLIFIED PROCESS FLOWSHEET This flowsheet should include the vessels and quantity of chemicals with CEI's 100 or greater or those with an odor problem. 4. A BRIEF DESCRIPTION OF THE "WORST CREDIBLE SCENARIO FOR EACH SCENARIO WITH A CEI GREATER THAN 100. 5. A COPY OF THE SUMMARY SHEETS AS PER ATTACHED CE INDEX PROGRAM FOR CEI AND DISPERSION FOR EACH SCENARIO WITH A CE GREATER THAN 100 OR THOSE WITH AN ODOR PROBLEM. DO A 023606 CONFIDENTIAL .6 A PLOT PLAN AND AREA MAP WITH: a Three circles based on EEPG numbers These circles represent the distance (radii of exposure) that 1, 10 and 100 times the EEPG concentrations are predicted to travel for NEUTRAL atmospheric conditions. b. A circle based on the Odor Threshold If the Odor Threshold is less than the EEPG concentration, include a circle for the distance that concentration is predicted to travel for NEUTRAL atmospheric conditions. c. Location of gas monitors, spill detectors, etc. Clearly show the location and type of any device used to detect a release. 7. THE CEI PRE-AUDIT QUESTIONNAIRE (Attached, nine pages) 8. ONE COPY OF THE MASS & ENERGY BALANCE FOR YOUR PLANT. One mass and energy balance flowsheet set should be sent to the Process Engineering representative only. U.S. Area and Corporate Representatives The Functional Team Leader will invite appropriate Dow U.S. Area or Corporate Safety and Loss Prevention representatives for for reviews with CEI's of greater than 300 or greater than 400 respectively. Notification for outside auditors must be done thirty days in advance of the audit. DO A 023607 CONFIDENTIAL Chemical Exposure Index Audit Agenda OVERVIEW PRESENTATION TO THE AUDIT TEAM ('Allow 30 Minutes) 1. What is the status of the recommendations made in the previous review? a Have there been any major changes or additions to the plant since the last review? b. Are there any other specific concerns which should be addressed but were not identified in the CEI review? 2. Summarize the results of the CEI calculations. Include results of the odor threshold dispersion modeling. 3. Review the "worst credible" case loss of containment release scenarios including plot plans showing dispersion model results. 4. Discuss any CEI related incidents that have occurred. 5. Discuss your lines of defense that would prevent your "worst credible" release scenario from occurring. 6. Discuss the mitigation procedures for each scenario. 7. Discuss your plant's CEI related concerns generated from the audit preparation. 8. Discuss your plans for improving your operations from a CEI standpoint. PRE-AUDIT QUESTIONNAIRE (' Allow 30 minutes) A Review the information provided in the questionnaire on an exception basis. DOCUMENTATION AUDIT (* Allow one hour) Following the plant's presentation, two members of the audit team will examine the plant's program documentation. The plant's documentation should include: Emergency Plan P&ID's/Material Balance Flowsheet Operation Discipline In-Plant Training Program Maintenance Checklist Operating Procedure Area Monitoring System Records Piping Specifications Completeness and quality will be used as a criteria for evaluating the documentation. 00 A 023608 CONFIDENTIAL CHLORINE I CHEMICAL LIST 'ur^ CHEMICAL CEI AHH IQ Chlorine 288 4 1 Freon 96 1 NA C02 72 1 0 HC1 54 3 3 H2S04 12 1 NA CC14 01 NA EEEfi EEPGX1 EEPGX10 ] 3 436 1.08 37 2000 .13 .04 .01 2000 32 .09 .02 25 .51 .15 .06 25 .05 .004 .004 100 .001 .001 .001 Of ERPG-l 8.95 NA 0 1.75 NA NA CEI AHH TO EEPG EEPGX1 EEPGX10 EEPGX100 EPRG-1 Chemical Exposure Index Acute Health Hazard Scale Numbers Odor Threshold, (ppm) Dow Emergency Exposure Planning Guidelines, (ppm) Radii of Exposure at 1 times EEPG, (miles) Radii of Exposure at 10 times EEPG, (miles) Radii of Exposure at 100 times EEPG, (miles) Radii of Exposure at 1 times Odor Threshold, (miles) Paul Yonts July 18,1991 CEI:AA2 >o CHLORINE CHEMISTRY DESIRED REACTION 2NaCI + 2H2O -- > Hi + Cl2 + 2NaOH (Electrolysis) 2.5 pH (Aqueous rfcl) UNDESIRED REACTIONS CI2 + Organics -- > Heat (Possible Fire OR Explosion) Inadvertent Use Of Reactive Lubricants And Solvents In Chlorine Service. Prevented By Training And Material Controller CI2 + Fe + Heat -- > Fire Compressor Discharge Temperature Alarms At 300F, Compressors Trip At 325F DryCl2 + H --> Explosion Inadvertent Use Of Titanium Parts In Dry Chlorine Service. Prevented By Engineering Controls, Training, Special Labeling, And Segregated Parts Storage. CI2 + H2 -- > Explosion (H2 LEL 6%) Auxiliary Brine Supply And Redundant Instrumentation To Ensure Adequate Brine Head Level In Cells. H2 In Ch: Chromatograph Analyzers In Cell Area, Distribution Systems and Liquefaction Plant. Chlorine Into Liquefaction Plant Blocked Automatically At 5% H2 Concentration In Tail Gas. Paul Yonts CEI:AA6 July 17,1991 DO A 023610 CONFIDENTIAL. Chlorine I Block Flow Diagram: POWER TO CAUSTIC CHLORINE PLANT FLOW DIAGRAM 1) AIR PRODUCTS 2) POWER 1 3) VENT STORAGE, EVAPORATION A LOADING TANKCARS METHANES VINYL II WATER TREATMENT Paul Yonts July 17, 1991 CEI Audit DO POWER I/ll WORST CASE SCENARIOS FOR CEI GREATER THAN 100 Vl CHLORINE Liquid Sphere: A 1" hole develops in the bottom of the chlorine sphere and cannot be blocked in. Liquid chlorine is lost to the ground and adiabatic vaporization occurs. The liquid is collected in an underground containment pit. Vapors from the containment pit are blown to the Chlorine Scrubbers. The surface vaporization disperses to the atmosphere. A layer of ice will soon form over the liquid chlorine pool. The maximum chlorine in either sphere is 4.2 MM lbs. The total amount of liauid inventory is controlled at 3.5 lbs. At no time will either storage sphere exceed an'*3"' level with the total combined inventory never to exceed 7.0 MM lbs. T-54 has a maximum capacity of 5.2 MM lbs. T-56 has a maximum capacity of 4.0 MM lbs. In 15 minutes approximately 12,500 lbs. of li will spill. Of this, 6600 lbs would evaporate lorine inutes. Liquid Distribution Manifold: A liquid full section of line is blocked in. An over pressure occurs. The pressure is relieved from an 6" asbestos gasket failure. The leak is detected by the area chlorine monitors. The line pressure is 180 psia at -22 F. The leak can not be blocked in, but the line can be isolated. The over pressure can be relieved by manually valving the line to a dump tank, T-36. The longest liquid chlorine line section is approximately 275 feet. The total contents is 5100 lbs. of liquid chlorine which can be released and vaporized in 8 minutes. Paul Yonts CEItAAO July 17,1991 DO A 023613 CONFIDENTIAL WORST CASE SCENARIOS FOR CEI LESS THAN 100 SULFURIC ACID The strong drying tower recycle line ruptures, spilling 45 M lbs. of 98% sulfuric acid to the ditch in 15 minutes. Due to the low vapor pressure of 98% H2SO4 (PvaP < 1 mm Hg), no more than 50 lbs of acid would vaporize. HYDROCHLORIC ACID A 1" hole develops in the 36% HC1 line from Solvents. The line can be isolated within 10 minutes. 1000 lbs of HC1 would vaporize. FREON A 1" hole develops in the bottom of the freon storage tank and cannot be blocked in. 17 M lbs of freon would vaporize to the atmosphere in 15 minutes. CARBON DIOXIDE A 2" hole develops near the bottom of the C02 storage tank and cannot be blocked in. 28 M lbs of C02 will be released to the atmosphere. CARBON TETRACHLORIDE A 2" hole develops near the bottom of the CC14 storage tank and cannot be blocked in. 20 M lbs of CC14 spill. In 15 minutes, only 2.5 lbs will evaporate. Paul Yonts CEI:AA0 July 17,1991 DO A 023614 confidential CHEMICAL EXPOSURE INDEX SUMMARY Complete the following Table (See Note 1) by filling in and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as identified in the following formula (See "Definitions of Scale Numbers" CEI, page 6): ^. 1. X II. X III. X IV. X V. ACUTE HEALTH HAZARD SCALE NO. VAPOR QUANTITY SCALE NO. DISTANCE (RECIPROCAL) SCALE NO. MOLECULAR WEIGHT SCALE NO. PROCESS PENALTIES SCALE NO. VI. CHEMICAL EXPOSURE INDEX Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Rnnrro Liquid Sphere To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business Rniirr.n #? (if needed) To (1) Public Liquid Distribution Manifold (2) Other in-company Facility (3) Non-company Plant or Business 1. II. III. IV. V. VI. (CEI) 4 33 4 34 4 33 4 2 288 4 2 384 4 2 288 4 33 4 34 4 33 4 2 288 4 2 384 4 2 288 NOTE 1 -- The distance scale number in column III is the only factor normally expected to change, so column III and the corresponding CEI (column VI) are all that would normally be expected to differ from the first calculation for each source. NOTE 2 -- Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 -- Use additional sheets if additional sources with differing potential impact are present. NOTE 4 --- It is important to document the worst case scenarios for future reference. See "Review Procedure and Check List," page 7. Back ol Form C-91720 TT4S4S DO A 0236,15 CONFIDENTIAL 5 CHEMICAL EXPOSURE INDEX SUMMARY Complete the following Table (See Note 1) by filling in and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as identified in the following formula (See "Definitions of Scale Numbers" CEI, page 6): 1. ACUTE HEALTH HAZARD SCALE NO. X II. X III. X IV. X V. m VI. VAPOR QUANTITY SCALE NO. DISTANCE (RECIPROCAL) SCALE NO. MOLECULAR WEIGHT SCALE NO. PROCESS PENALTIES SCALE NO. CHEMICAL EXPOSURE INDEX Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source #1 Freon Storage Tank To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business Source #2 (if needed) ________________ To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business 1. II. III. IV. V. VI. (CEI) 1 4 3 4 2 96 1 4 4 4 2 128 1 4 3 4 2 96 NOTE 1 -- The distance scale number in column III is the only factor normally expected to change, so column III and the corresponding CEI (column VI) are all that would normally be expected to differ from the first calculation for each source. NOTE 2 -- Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 -- Use additional sheets if additional sources with differing potential impact are present. 'OTE 4 -- It is important to document the worst case scenarios for future reference. See "Review Procedure and Check List," page 7. Back of Form C-91720 DO A 023616 CONFIDENTIAL CHEMICAL EXPOSURE INDEX SUMMARY Complete the following Table (See Note 1) by filling in and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as identified in the following formula (See "Definitions of Scale Numbers" CEI, page 6): 1. ACUTE HEALTH HAZARD SCALE NO. X II. X 111. X IV. X V. " VI. VAPOR QUANTITY SCALE NO. DISTANCE (RECIPROCAL) SCALE NO. MOLECULAR WEIGHT SCALE NO. PROCESS PENALTIES SCALE NO. CHEMICAL EXPOSURE INDEX Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source #1 C09 Storage Tank To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business Source #2 (if needed) ________________ To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business 1. II. III. IV. V. VI. (CEI) 1 4 33 1 4 43 1 4 33 2 72 2 96 2 72 NOTE 1 -- The distance scale number in column III is the only factor normally expected to change, so column III and the corresponding CEI (column VI) are all that would normally be expected to differ from the first calculation for each source. NOTE 2 -- Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 -- Use additional sheets if additional sources with differing potential impact are present. IOTE 4 -- It is important to document the worst case scenarios for future reference. See "Review Procedure and Check List," page 7. Back of Form C-91720 now DO A 023617 CONFIDENTIAL 5 CHEMICAL EXPOSURE INDEX SUMMARY Complete the following Table (See Note 1) by filling in and multiplying the appropriate,Risk Factor Scale numbers for each of the major Risk areas as identified in the following formula (See "Definitions of Scale Numbers" CEI, page 6): 1. ACUTE HEALTH HAZARD SCALE NO. X II. X III. X IV. X V. VI. VAPOR QUANTITY SCALE NO. DISTANCE (RECIPROCAL) SCALE NO. MOLECULAR WEIGHT SCALE NO. PROCESS PENALTIES SCALE NO. CHEMICAL EXPOSURE INDEX >o Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source #1 HC1 Line from Solvents To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business Source #2 (if needed) ________________ To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business 1. II. III. IV. V. 3 23 3 1 54 3 24 3 23 3 1 72 3 1 54 NOTE 1 -- The distance scale number in column III is the only factor normally expected to change, so column III and the corresponding CEI (column VI) are all that would normally be expected to differ from the first calculation for each source. NOTE 2 -- Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 -- Use additional sheets if additional sources with differing potential impact are present. TOTE 4 -- It is important to document the worst case scenarios for future reference. See "Review Procedure and Check List," page 7. Back of Form 0*91720 TT4M 00 A 023618 CONFIDENTIAL 5 CHEMICAL EXPOSURE INDEX SUMMARY Complete the following Table (See Note 1) by filling in and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as identified in the following formula (See "Definitions of Scale Numbers" CEI, page 6): 1. X II. X III. X IV. X V. ACUTE HEALTH HAZARD SCALE NO. VAPOR QUANTITY SCALE NO. DISTANCE (RECIPROCAL) SCALE NO. MOLECULAR WEIGHT SCALE NO. PROCESS PENALTIES SCALE NO. VI. CHEMICAL EXPOSURE INDEX Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source #1 Drying Tower Recycle Line To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business Source #2 (if needed) ________________ To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business 1. II. III. IV. V. VI. (CEI) 1 1 34 1 12 1144 1 134 1 16 1 12 NOTE 1 -- The distance scale number in column III is the only factor normally expected to change, so column III and the corresponding CEI (column VI) are all that would normally be expected to differ from the first calculation for each source. NOTE 2 -- Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 -- Use additional sheets if additional sources with differing potential impact are present. 'OTE 4 -- It is important to document the worst case scenarios for future reference. See "Review Procedure -nd Check List," page 7. Back of Form C-91720 rr4 ^ 023619 DO IDFMTIAL- conf 5 CHEMICAL EXPOSURE INDEX SUMMARY f Complete the following Table (See Note 1) by filling in and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as identified in the following formula (See "Definitions of Scale Numbers" CEI, page 6): 1. ACUTE HEALTH HAZARD SCALE NO. X II. X III. X IV. X V. - VI. VAPOR QUANTITY SCALE NO. DISTANCE (RECIPROCAL) SCALE NO. MOLECULAR WEIGHT SCALE NO. PROCESS PENALTIES SCALE NO. CHEMICAL EXPOSURE INDEX Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source #1 t-54. Carbon Tetrachloride Storage To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business Source #2 (if needed)________________ To (1) Public (2) Other in-company Facility (3) Non-company Plant or Business 1. II. III. IV. V. VI. (CEI) 20 20 20 34 44 34 20 20 20 NOTE 1 -- The distance scale number in column III is the only factor normally expected to change, so column III and the corresponding CEI (column VI) are all that would normally be expected to differ from the first calculation for each source. NOTE 2 -- Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 -- Use additional sheets if additional sources with differing potential impact are present. NOTE 4 -- It is important to document the worst case scenarios for future reference. See "Review Procedure and Check List," page 7. Back ot Form C-91720 DO A 023620 CONFIDENTIAL 5 ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** Ch .ICAL EXPOSURE INDEX PLANT: CHLORINE I LOCATION: LAD CHEMICAL: CHLORINE TOTAL QUANTITY IN PLANT: 7000000.00 lb LARGEST SINGLE CONTAINMENT: 4200000.00 lb STORAGE TEMPERATURE: 1.00 deg F STORAGE PRESSURE: 45.00 psia BOILING POINT: -30.00 deg F FLASH POINT: 0.00 deg F MOLECULAR WEIGHT: 70.90 EEPG CONCENTRATION: 3.0 ppm EXPOSURE RISK POTENTIAL SUMMARY ACUTE HEALTH HAZARD FACTOR: 4 (1.0 - 9.9) VAPOR QUANTITY FACTOR: 3 (1,000 lbs - 10,000 lbs) MOLECULAR WEIGHT FACTOR: 4 ( > 45) ESS PENALTIES: 2 (overpressure or run-away reaction potential) DISTANCE TO THE PUBLIC TO DOW PLANTS TO OTHER BUSINESSES DISTANCE FACTOR 3 (1000 ft - 5279 ft) 4 ( < 1000 ft) 3 (1000 ft - 5279 ft) E.R.P. VALUE 288 384 288 EXPOSURE RISK POTENTIAL TO THE PUBLIC = 288 BIANNUAL REVIEW - SITE, SUPERINTENDENT AND MAJOR MANAGER THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** 00 A 0236?1 CONFIDENTIAL ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** L VERSION SUMMARY TOTAL DISCHARGED - 6600.00 LBS RELEASE DURATION - 15.00 MIN MOLECULAR WEIGHT - 70.90 SOURCE TEMPERATURE = 1.00 DEG F EEPG CONCENTRATION = 3.0 ppm SOURCE HEIGHT - 0.00 FT SOURCE DIAMETER - 0.00 FT EXIT VELOCITY = 0.00 FT/S PERCENT DILUTION - 0.00 AMBIENT TEMPERATURE = 86.00 DEG F THE RELEASE IS A GAS RELEASE THE RELEASE IS CONTINUOUS THE RADII OF EXPOSURE ARE BASED ON PEAK CONCENTRATIONS CONC (ppm) RADII OF EXPOSURE (miles) @ ground level - @ plume centerline UNSTABLE 12. mph (20 %)* NEUTRAL 8. mph (40 %)* STABLE 4. mph (40 %)* 3.0 0.762 3.644 23.848 30.0 0.261 0.907 3.726 300.0 0.103 0.244 0.841 * APPROXIMATE % OF TIME IN THIS WEATHER CONDITION UNSTABLE ATMOSPHERIC CONDITION - SLIGHT SOLAR RADIATION WITH LOW WIND SPEEDS (<10 mph) OR STRONG RADIATION WITH HIGH WIND SPEEDS (>10 mph). NEUTRAL ATMOSPHERIC CONDITION - WELL MIXED ATMOSPHERE DUE TO MODERATE/STRONG WIND SPEEDS (>7 mph) AND SLIGHT/MODERATE SOLAR RADIATION. ANY OVERCAST CONDITION. STABLE ATMOSPHERIC CONDITION - LOW WIND SPEEDS (<10 mph) AT NIGHT. THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** 00 A 023622 CONFIDENTIAL Hoi In Chlorine Sphere, 12,500 lbsSpilled Instantaniously lis ,T DATA CHEMICAL NAME: pp400 LEAK TYPE: I (C=CONTINUOUS I=INSTANTANEOUS) TOTAL AMOUNT SPILLED: 12500.00 LBS SPILL AREA: 1000.00 FT**2 AMBIENT TEMPERATURE: 86.00 deg F CHEMICAL STORAGE TEMPERATURE: 1.00 deg F SUBSTANCE OF GROUND: c (D=DRY SOIL, W=WET SOIL, C=CEMENT) GROUND TEMPERATURE: 86.00 deg F WIND VELOCITY: 8.00 MPH THE SPILL FALLS INTO CATEGORY 3 AS DEFINED IN THE SHELL SPILLS MANUAL 1. THIS ASSUMES THE AMOUNT FLASHED ADIABATICALLY IS NEGLIGIBLE COMPARED TO THE HEAT TRANSFER RATE IN THE FIRST MINUTE. 2. THIS ASSUMES EVAPORATION DUE TO HEAT TRANSFER DOMINATES THE FIRST SEGMENT OF TIME. 3. THIS ASSUMES EVAPORATION DUE TO MASS TRANSFER DOMINATES THE FINAL SEGMENT OF TIME. THE AMOUNT EVAPORATED BY HEAT TRANSFER: THE TIMEREQUIRED: 5.76 MIN THE AMOUNT EVAPORATED BY MASS TRANSFER: THE TIMEREQUIRED: 37.10 MIN 2837.41 LBS 9662.59 LBS DO A 023623 CONFIDENTIAL EwtP Hoi In Chlorine Sphere, 6600 lbs*5piil- in 15 Minut s lr\. T DATA CHEMICAL NAME: pp400 LEAK TYPE: I (C=CONTINUOUS I=INSTANTANEOUS) TOTAL AMOUNT SPILLED: 6600.00 LBS SPILL AREA: 1000.00 FT**2 AMBIENT TEMPERATURE: 86.00 deg F CHEMICAL STORAGE TEMPERATURE: 1.00 deg F SUBSTANCE OF GROUND: c (D=DRY SOIL, W=WET SOIL, C=CEMENT) GROUND TEMPERATURE: 86.00 deg F WIND VELOCITY: 8.00 MPH THE SPILL FALLS INTO CATEGORY 3 AS DEFINED IN THE SHELL SPILLS MANUAL 1. THIS ASSUMES THE AMOUNT FLASHED ADIABATICALLY IS NEGLIGIBLE COMPARED TO THE HEAT TRANSFER RATE IN THE FIRST MINUTE. 2. THIS ASSUMES EVAPORATION DUE TO HEAT TRANSFER DOMINATES THE FIRST SEGMENT OF TIME. 3. THIS ASSUMES EVAPORATION DUE TO MASS TRANSFER DOMINATES THE FINAL SEGMENT OF TIME. THE AMOUNT EVAPORATED BY HEAT TRANSFER: THE TIME REQUIRED: 5.76 MIN THE AMOUNT EVAPORATED BY MASS TRANSFER: THE TIME REQUIRED: 14.45 MIN 2837.41 LBS 3762.59 LBS _,n a 0236?a CONFIDE^*- QgflKINE W3RST CRSE fSCHRCE 1U Scenario: A 1" hole develops in the WiH-rm at the Chlorine sphpre and cannot be blocked in. From the liquid jet formula: <3l - 8*02 CcA (Dens.L) +pi-p2)" 0.5 I?3-!! and assuming approximately 30 ft. of liquid (H^) in the sphere, the amount discharged, is 1277.9 Ib/min - 21.3 Ib/sec. Using this value in the two phase jet formulas: w \gc PQ (Dens.L)A and Q 0.66 W"*39 * A{ (PQ) (Dens.L) (gc) > *5 Q * 828.9 lb/min discharged, therefore far 15 minutes... Q 3 12,433 lb liquid discharged. Variables used in formulas: Dens.L - 94.732 lb/cf (@ 1' from CRPRDP) P1 - 29.161 psia (P^P 8 l'P from CKPRQP) P2 14.696 psia DO A 023625 confidential ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** CU .ICAL EXPOSURE INDEX PLANT: CHLORINE I LOCATION: LAD CHEMICAL: CHLORINE TOTAL QUANTITY IN PLANT: 7000000.00 lb LARGEST SINGLE CONTAINMENT: 4200000.00 lb STORAGE TEMPERATURE: -22.00 deg F STORAGE PRESSURE: 180.00 psia BOILING POINT: -30.00 deg F FLASH POINT: 0.00 deg F MOLECULAR WEIGHT: 70.90 EEPG CONCENTRATION: 3.0 ppm EXPOSURE RISK POTENTIAL SUMMARY ACUTE HEALTH HAZARD FACTOR: 4 (1.0 - 9.9) VAPOR QUANTITY FACTOR: 3 (1,000 lbs - 10,000 lbs) MOLECULAR WEIGHT FACTOR: 4 ( > 45) ESS PENALTIES: 2 (overpressure or run-away reaction potential) DISTANCE TO THE PUBLIC TO DOW PLANTS TO OTHER BUSINESSES DISTANCE FACTOR 3 (1000 ft - 5279 ft) 4 ( < 1000 ft) 3 (1000 ft - 5279 ft) E.R.P. VALUE 288 384 288 EXPOSURE RISK POTENTIAL TO THE PUBLIC = 288 BIANNUAL REVIEW - SITE, SUPERINTENDENT AND MAJOR MANAGER THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DO A 023626 CONFIDENTIAL ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** D. VERSION SUMMARY TOTAL DISCHARGED = 5100.00 LBS RELEASE DURATION - 8.70 MIN MOLECULAR WEIGHT 70.90 SOURCE TEMPERATURE = -22.00 DEG F EEPG CONCENTRATION = 3.0 ppm SOURCE HEIGHT - 0.00 FT SOURCE DIAMETER * 0.00 FT EXIT VELOCITY * 0.00 FT/S PERCENT DILUTION = 0.00 AMBIENT TEMPERATURE - 86.00 DEG F THE RELEASE IS A GAS RELEASE THE RELEASE IS CONTINUOUS THE RADII OF EXPOSURE ARE BASED ON PEAK CONCENTRATIONS CONC (ppm) RADII OF EXPOSURE (miles) @ ground level - @ plume centerline UNSTABLE 12. mph (20 %)* NEUTRAL 8. mph (40 %)* STABLE 4. mph (40 %)* 3.0 0.877 4.364 33.039 30.0 0.298 1.075 4.512 300.0 0.116 0.286 1.000 * APPROXIMATE % OF TIME IN THIS WEATHER CONDITION UNSTABLE ATMOSPHERIC CONDITION - SLIGHT SOLAR RADIATION WITH LOW WIND SPEEDS (<10 mph) OR STRONG RADIATION WITH HIGH WIND SPEEDS (>10 mph). NEUTRAL ATMOSPHERIC CONDITION - WELL MIXED ATMOSPHERE DUE TO MODERATE/STRONG WIND SPEEDS (>7 mph) AND SLIGHT/MODERATE SOLAR RADIATION. ANY OVERCAST CONDITION. STABLE ATMOSPHERIC CONDITION - LOW WIND SPEEDS (<10 mph) AT NIGHT. THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DO A 023627 CONFIDENTIAL Blown Gasket In Liquid Chlorine Line, 5100 lbs Spill II T DATA CHEMICAL NAME: pp400 LEAK TYPE: I (C=CONTINUOUS I=INSTANTANEOUS) TOTAL AMOUNT SPILLED 5100.00 LBS SPILL AREA 1000.00 FT**2 AMBIENT TEMPERATURE 86.00 deg F CHEMICAL STORAGE TEMPERATURE: -22.00 deg F SUBSTANCE OF GROUND: C (D=DRY SOIL, W=WET SOIL, C=CEMENT) GROUND TEMPERATURE: 86.00 deg F WIND VELOCITY 8.00 MPH THE SPILL FALLS INTO CATEGORY 3 AS DEFINED IN THE SHELL SPILLS MANUAL 1. THIS ASSUMES THE AMOUNT FLASHED ADIABATICALLY IS NEGLIGIBLE COMPARED TO THE HEAT TRANSFER RATE IN THE FIRST MINUTE. 2. THIS ASSUMES EVAPORATION DUE TO HEAT TRANSFER DOMINATES THE FIRST SEGMENT OF TIME. 3. THIS ASSUMES EVAPORATION DUE TO MASS TRANSFER DOMINATES THE FINAL SEGMENT OF TIME. THE AMOUNT EVAPORATED BY HEAT TRANSFER: THE TIME REQUIRED: 5.76 MIN THE AMOUNT EVAPORATED BY MASS TRANSFER: THE TIME REQUIRED: 8.69 MIN 2837.41 LBS 2262.59 LBS CE) LIQUID CHLORINE BLOWN GASKET OVERPRESSURE ORIFICE SIZE FROM BLOWN GASKET GASKET BOLT CIRCLE 10-5/8" GASKET THICKNESS 1/8" NUMBER OF BOLTS (300#) 8 A * _X W - 2tiRW - 2E_(5-5/16 x .125) 8 84 - .521 in2 A = .004 ft.2 MAXIMUM LINE CONTENTS: V = LriR2 DIA = .5 FT. LENGTH = 275 FEET V 275 (ID LSI2 54 FT 3 4 MASS - 54FT3 X 95 LBS = FT3 5100 LBS CHLORINE LIQUID SPILL QUANTITY: QL-(.61) (A) PL 2qc (Pi-,Ed PL Ql * .61 (.004) (95) (8) 28080-2160 95 Ql= 30.6 lb => 1850 Ibs/min. s A = .004 ft2 Pi = 28080 psfa P2 * 2160 psfa 7/19/91 PYONTS.GSH DO A 023629 CONFIDENTS Al. TWO PHASE FLOWS; w = qc P0 PlA2 + X0PL Ql` Pl-PG w - 32 ft (95, lb) (28080 lb) (.004ft) (.004 ft2) + 1 .(95) S2 ft3 ft2 (95 -.027) 936.4 S2 w - 1.5 + 1 - 2.5 and 2.5 < 4.0 ... Therefore, Two Phase Flow applies. Q = .66 (w -.39) [A [P0* Pi_qc)-5)] ACTUAL 2 PHASE CHLORINE LOSS: Qs = .66 (w -.39) [A [P0 * PLqc)-5)] Qs = ..66 (2.5)'-39 [.004[(28080) (95)(32)]-5] Qs ** 17.1 LBS/S Qm 1023.8 LB/M IN. Q15 = 1023.8 LB/MIN X 15 MIN. = 15,356 LB/15MIN. 7/19/91 PYONTS.-GSH 00 A 023630 confidential MAJOR CHLORINE PLANT CHANGES SINCE 1989 CEI AUDIT Installed Dual Train, Oversized, Titanium Chlorine Scrubbers Eliminated "Worst Case Scenario" From Chlorine Liquid Manifold: 1" Nipples Removed Rectifiers 2 & 3 On MOD V Control Implementing Successful IPT Program Began Program To Replace Standard Packed Valves With Bellows Seal Valves In Liquid Chlorine Service Completed Preventative Maintenance On Gas Distribution Lines To EDC, Solvents And Glycol Installed Dual Nitrogen Feed System For Improved Plant Reliability Increase Plant Air Reliability Through Piping Upgrades And Completed Tie With Divisional Air System Transferred Cell Header Pressure Controller To MOD V Control Paul Yonts July 19,1991 CEI:AA4 DO A 023631 CONFIDENTIAL SUPERVISORS INVESTION OF ACCIDENT/INCIDENT - S-305 L-63 (REV. 5-90) _----- DOW CHEMICAL U.S.A. LOUISIANA DIVISION I0D-RMTC# JprLRWC# |C)PL SUPERVIS OR'S INVESTIGATION OF ACCID ENT/INCIDENT 0C-RMTC# ACCIDENT CLAS&IFICAT0W DATE OF ACCIDENT: 0C-RWC# INJURY NON INJURY TIME OF ACCIDENT: 0C-DAW* S&LP STANDARD VIOLATION DATE INVESTIGATED: 0550000PD EVIRON. X RxCHEM. DATE REP SUBMITTED: 01-24-91 1205 01-24-91 01-25-91 Block and Location of Accident Chlorine 1 Block 26 Name of InjuredMnvolved Employee N/A 1991-4 Class N/A Time at Dow (Mos). N/A Master No. N/A Time on Job (Mos.) N/A Contractor Involved/Supervisor N/A Chemical Released (EvIron/RxChem only) Chlorine Am unt/Unit of Measure (EnvIr/RxChem only) 15 lbs. Accident/Incident Description (10 Words or Less) Backpressure Due To C-100 Inst. Failure Accident / Incident Description (Full)------------------------------------------------------------------------------------------------------------------ A chlorine release occurred due to a pressure upset In the Chlorine Cell Area. Cell header pressure control failed (chlorine compressor surge controller) causing a positive pressure in the cells. The emergency pressure oontrol system activated?" starting the vent scrubber and reducing load by 40%. The control system was taken over by plant operators and brought"* under control. The situation was corrected before production was increased. r \TS CLASSIFICATION (List all that apply with code number and description from back page) ACCIDENT / INCIDENT INJURY BODY PART 355 Air Release Agency Reportable__________________________________ _______________________ JOB BEING PERFORMED (List one from Group I and all that apply from Group II 100 OPERATION / ROUTINE CAUSES (List All that with code number and description from back) ON SITE PRE-EXISTING 810 Equipment Failure_________________________ 015 Improper Design FOLLOW UP ACTION TO PREVENT RECURRENCE Action : Replace suroe control device.__ Responsibility : J- HaneyExpected Completion Date : 01-24-91 Actual Completion Date: 01-24-91 Action Install remote seal flow & press, transm. to prevent plugging of process nozzle. Responsibility : j. HanevExpected Completion Date : 05-01-91 Actual Completion Date: Action :___ Responsibility :Expected Completion Date :Actual Completion Date : ouperintendent's Signature Joe Muller Investigated By Haney, Serpas, Cutrer, Hebert, Cooke Signature of Injured None DO A 023632 CONFIDENTIAL LINES OF DEFENSE LIQUID CHLORINE STORAGE AREA o Leak Detection System o Underground Containment Sump o EBV, PSV Protection o Ability To Pump One Sphere To The Other o Procedures And Equipment For Operator Mitigation o Yearly NDT Thickness Testing For Both Spheres LIQUID CHLORINE DISTRIBUTION AREA o Leak Detection System o Quarterly NDT Thickness Testing On Discharge Lines o Procedures And Equipment For Operator Mitigation Paul Yonts July 19,1991 CEI:AA5 DO A 023633 CONFIDENTIAL L i il i ' Ul UL T r* c zz `-'UN'o RESPONSE . EMP RESPONSE TO CHLORINE. TOXIC RELEASE OR ENV IRQMEiJTAL INCIDENT CHLORINE RELEASE Tri 1 NoU:" Site 1 bv tel scheme at 333 or bv emeraencv radio : a. . Tell them the tvoe of release, gas or liauid. b. Maanitude of the release. small or larae. c. Area of the release. Sound the general alarm for the bioci- : a. Announce the area of the release. b n r* o u n c e t*n e w a n 1 n ' * c o i om and s a i a a r e a s . c. in the ever.*: of a la roe release, account for all oer sonne' d. Evacuate all non-= = = en'* la 1 personnel. I- eeD 0a.* - i jli-. . orner con': a mine ore r^xeaso. v-ijGuerrc js ri= corts of oroaress ir. t: L t r- z. E <- ... -J Z'X a JUt. i c. nfs; c c the release. Sound the general alarm for tr.e block: a. Announce the area of the release. b. Announce the wind direction and safe are*: fees bate 1 informed wicn rreaue c o n t a i. r. i n c t ne r e i s a a a . : o r VrC -1ENTAL I NO I DEN" o r on p.n A 0?3A34 confid^tiW- T-54/T-56 LEAK PROCEDURE IF T-54 OR T-56 DEVELOPS A LEAK: 1. Call 333 and notify Plant security immediately that there is a 'i siginificant liquid spill in the Chlorine Plant. Make an announcement in the Chlorine block. Evacuate non-essential personnel to the appropriate assembly area. 2. Locate the leak - isolate if possible 3. Allow chlorine to drain to sump. Turn off sphere sump pump. Turn on sump blower to AX-250. Keep caustic excess high in scrubbers. Cover sump drain under sphere that is not leaking. 4. Block in the "liquid in" EBV to the leaking sphere. Reduce the pressure in the sphere as muck as possible. Rapidly pump out of the sphere to the evaporators, Methanes, and/or tank cars. Consider using outside reflux on ST-55/65. 5. Ask CA-XX to stop sending liquid. Chlorine can be pumped from leaking sphere to the other by flowing from : the pumps > manifold > load rack > offloading line > CA-XX meter run > sphere. 6. Check breathing air and face masks in Control Room. Monitor wind direction closely. 7. Chlorine should continue to drain to sump. Once sphere is evacuated r leak has stopped, cover sphere drain. Keep blower on. REVISED 11-21-89 'HEREX^K.OPR #614 RL002028.DOC 60-05-03-00 DO A 023635 CONFIDENTIAL La T--5t 77 ^ J7-SEP-86 DO A 023636 CONFIDENTIAL | nil !'- I Ml I ( I l| 1 O'-.-'t-.l'H.'Itlj : mSTftiBUTXON SYSTEM ^61 17-S^P-86 D0 A 023637 CONFIDENTIAL FUTURE PLANS o PPM Chlorine Storage Sphere: Strip, Blast, Thickness Test, Hydrostatic Test, Paint and Re insulate T-54 o PPM Liquid Chlorine Line: Strip, Blast, Thickness Test, Hydrostatic Test, Paint and Re insulate P-54 Discharge Piping To Manifold o PPM CPE User Line: Strip, Blast, Thickness Test, Hydrostatic Test, Paint, Heat Trace and Re-insulate o Achieve Ability For Periodic Testing Of The EBV's On The Bottom Of The Chlorine Spheres o Continue With Formalized Training: IPT, Procedure Documentation, Operational Check Sheets And Spill Prevention o Continue With Bellow Seal Valve Installations o Continue Program To Prevent External Corrosion o Expand Usage Of Mod5 And Mod5 Remotes o Develop PM Program For Critical Liquid Chlorine Piping. o Develop Adjacent Plant Spill Scenarios With Collective Inter-Plant Participation o Continue With Yearly And Monthly Emergency Drills o Continue P&ID Updates Paul Yonts July 19,1991 CEI:AA5 073638 DO * DENI'S W' ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** 1^ PERSION SUMMARY TOTAL DISCHARGED = RELEASE DURATION = MOLECULAR WEIGHT * SOURCE TEMPERATURE EEPG CONCENTRATION 999.00 LBS 15.00 MIN 36.00 86.00 DEG F 3.0 ppm SOURCE HEIGHT = 0.00 FT SOURCE DIAMETER = 0.00 FT EXIT VELOCITY * 0.00 FT/S PERCENT DILUTION - 0.00 AMBIENT TEMPERATURE = 86.00 DEG F THE RELEASE IS A GAS RELEASE THE RELEASE IS CONTINUOUS THE RADII OF EXPOSURE ARE BASED ON PEAK CONCENTRATIONS CONC (ppm) RADII OF EXPOSURE (miles) @ ground level - @ plume centerline UNSTABLE 12. mph (20 %)* NEUTRAL 8. mph (40 %)* STABLE 4. mph (40 %)* 3.0 0.422 1.745 30.0 0.149 0.455 300.0 0.063 0.136 APPROXIMATE % OF TIME IN THIS WEATHER CONDITION 8.053 1.718 0.407 UNSTABLE ATMOSPHERIC CONDITION - SLIGHT SOLAR RADIATION WITH LOW WIND SPEEDS (<10 mph) OR STRONG RADIATION WITH HIGH WIND SPEEDS (>10 mph). NEUTRAL ATMOSPHERIC CONDITION - WELL MIXED ATMOSPHERE DUE TO MODERATE/STRONG WIND SPEEDS (>7 mph) AND SLIGHT/MODERATE SOLAR RADIATION. ANY OVERCAST CONDITION. STABLE ATMOSPHERIC CONDITION - LOW WIND SPEEDS (<10 mph) AT NIGHT. THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DO A 023639 CONFTDFNTIAL BLOCK 26 CHLORINE I owu CHEMICAL EXPOSURE INDEX AUDIT PRE-AUDIT QUESTIONNAIRE Please check off YES, NO or N/A (not applicable) for each question. Provide additional details if requested. When was the last CEI review? June 21.1989. What chemicals were discussed and what were the CEI values? .Chemical CEI Sulfuric Acid (98%) Hydrochloric Acid (36%) Carbon Dioxide Freon 12 12 54 72 96 Please list all chemicals in your plant that exhibit a Chemical Exposure Index (CEI) of 100 or greater. Chlorine Chlorine Liquid Sphere Distribution Manifold 288 288 Please list all chemicals that have spill/release scenarios (neutral atmospheric condition and "EEPG X 1") exhibiting a radius of exposure that exceeds the distance from your plant to the public. Chlorine Have these scenarios been included in the CAER/MIDAS program? Yes Please have appropriate map plots available for review at the audit Please list all chemicals that have spill release scenarios (neutral atmospheric condition and "ODOR THRESHOLD X 1") exhibiting a radius of exposure that exceeds the distance from your plant to the public. Chlorine Have these scenarios been included in the CAER/MIDAS program? Yes Please have appropriate map plots available for review at the audit DO A 023641 CONFIDENTIAL The following pre-audit questions apply to those areas of the operation that process, transfer, or store chemicals whose impact in the event of a release incident would have a significant negative impact on public areas. Impacts on or of immediately surrounding facilities should be considered in a secondary way. A. OPERATING PROCEDURES 1. Does the plant have checklists that are used to shutdown and clear equipment/piping to insure that the contents are not left in the equipment, or accidentally released into the environment? Yes, Reference 1, Attached, IPT. 2. Does the plant have checklists that are used for starting up out of service equipment/piping that insures that no raw materials, process streams or product will be accidentally released into the environment? Yes, Reference 2, Attached, IPT. 3. Does the plant have procedures for the initial opening of lines and equipment? Yes, Reference 3, Attached. 4. Does the plant have procedures that define exactly who is responsible for the operation, inspection and maintenance of adjacent and intra/interplant pipelines and associated equipment? Chlorine to user's C-9, Reference 4, Attached. a. Do they include normal operations? Monthly shift check C-9 B. PLANT COMMUNICATIONS 5. Does the plant have an up-to-date emergency call list? Yes, Reference 5, Attached. 6. Does the plant have written notification procedures for the following emergencies? Reference 6, Attached. a. Gas Release Yes b. Spill Yes c. Fire Yes d. Emergency Response Yes 7. Does the plant have procedures for establishing contact with Field Headquarters during an emergency? Yes, Reference 7, Attached. D0 * 023642 confidential I C. AREA MONITORING SYSTEMS 8. Does the plant use an area monitoring system for toxic materials? Yes, Reference 8, Attached. a. How often are these monitors checked and calibrated? Not designed to be calibrated. Checked once per week by Lab Tech. 9. Are plant personnel trained to respond to the alarms from area monitors? Yes, Reference 9, Attached. a. What is the frequency of retraining? Annual Drill, Monthly emergency drills D. PLANT PIPING SYSTEMS 10. Does the plant monitor corrosion in the piping systems of the facility? No a. How is monitoring done? 11. Does the plant have areas in the piping system that requires constant or repetitive repairs? Yes, CPE user line. Reference 10, Attached. a. Please describe what is being done to prevent recurrence. $80M to strip, blast, paint, replace and retrace. 12. Does the plant have a preventive maintenance program in place to monitor the integrity of the piping system? Consider all elements; i.e., paint, insulation, corrosion, supports, shoes, etc. Yes, $310M Preventive painting program. Reference 11, Attached. 13. Are outside-the-block material distribution systems monitored for leaks? Yes a. How is this done? C-9 b. How frequendy? Monthly 14. Do the plant's toxic material distribution systems undergo pressure testing on a routine basis? No, always done after maintenance. 15. Do the plant's toxic material distribution systems have prominendy displayed phone numbers for notification of problems and emergencies? Yes DO A 023643 CONFIDENTIAL E. PLANT MECHANICAL EQUIPMENT V 16. What kind of pumps docs the plant use in toxic service? 4-sealess canned pumps. (2-P-54, 2-P-56) 17. Are these the kind of pump systems that will minimize leak potential? (i.e., tandem or dual seals, sealess pumps, etc.) Yes 18. Does the plant have a preventive maintenance program in place for mechanical equipment? Yes, Reference 12, Attached. F. TRAINING FOR EMERGENCY RESPONSE 19. Have the scenarios for chemical spills and gas releases, that have the most probable chance of occurring, been reviewed with: Reference 13, Attached. a. Plant operators/technicians? Yes b. Supervision? Yes c. Other affected employees? Yes d. Process Engineering (CEINDEX Program)? Yes e. Safety and Loss Prevention? Yes f. Environmental (data of MIDAS system)? Yes g. Adjacent plant supervision? No 20. Have your reviews included all possible scenarios that would be deemed "major releases", affecting the public beyond the Dow fence line? Yes DO A 023644 CONFIDENTIAL 21. Does the plant conduct routine, periodic "what if' emergency drills on the release of toxic chemicals? Yes, Reference 14, Attached. a. Is each shift involved? Yes b. Do supervisors participate? Yes If ves. what level of supervision? Shift Supervisors and staff c. Is there a regular schedule for these exercises? Yes d. Is Industrial Security involved in these practice drills in any way? Yes, yearly If ves. in what way? Divisonal warning contacts with Dow Fire Department, State and Local Officals. Directs local traffic. e. How often are drills conducted? Yearly f. When was the last time your plant had a planned emergency drill involving the release of a toxic gas or liquid? 9/90 g. What chemical was used in your last planned emergency drill? Chlorine h. Have you used different toxic or odorless chemicals in previous drills? No 22. Does the plant have a formalized training program for those people who conduct periodic inspections of concerned facilities? (Example: weekly pipe inspection checklist, what to look for, etc.) No, in IPT development, estimated IQ 1992 completion. 23. How do you insure that "lessons to be learned" from incident investigations are passed on to all concerned personnel? Follow up to yearly Drill Safety Meetings, Long Term Notes, tailgates and IPT Documentation. D0 A 023645 CONFIDENTIAL 24. Does the plant have written procedures detailing how to mitigate releases of toxic chemicals in the plant? (Examples: pump to another tank, apply foam, drive a wooden peg, etc.) Yes, Reference 15, Attached. a. Does the plant periodically train operating personnel on these procedures and methods for mitigating liquid spills or gas releases from the facility? Yes How often? Yearly How is the training documented? C-9 25. Has the plant reviewed its emergency response personnel protective equipment inventory with Industrial Hygiene? (appropriateness, types, toers, etc.) . * ,,__ 26. Does the plant have sufficient quantities of emergency response personnel protective equipment on hand to satisfy the need in the event of a major emergency? Yes a. Is it kept at strategic locations for ease of access in case of an emergency? Yes, Emergency Response Room, Control Room, Brine Treating Lab. 27. Are there checklists employed for the periodic inspection, maintenance, and testing of the plant emergency equipment? (ammonia curtains, foam deluge systems, and fire monitors) Yes, Reference 16, Attached, C-9. a. How often? Weekly/Monthly b. Who does it? Shifts 2 8. Are all plant personnel trained in the proper use of the various personnel protective equipment employed for combatting liquid spills, gas releases, and fires? Yes a. How often? Respirator Annually, Quarterly SCBA SCBA - Quarterly w is this training documented? 9 DO A 023646 CONFIDENTIAL 29. How many people are involved in training on the proper emergency response to a liquid/vapor chemical release of concern? / I a. Operators/technicians b. Supervision (all levels) c. Others d. Total of above 36 4 4 44 30. Have you consulted with neighboring plants immediatley surrounding your facility to determine the effects of spills/releases by them on your plant and personnel? Yes, Reference 17, Attached. a. Do you have the proper type of personnel protective equipment if your plant is downwind of a spill or release from those facilities? Yes b. Sufficient quantities of equipment? Yes c. Is this equipment inspected or checked periodically? Yes d. Do you train your plant personnel on how to respond when exposed to a gas released from an adjacent plant? Yes, Monthly shift emergency training. How often? September 91, one time event. e. Do you participate in emergency drills when hypothetical releases originate in plants other than your own? Yes 7/1 0/91 PEV/daa DO CNFrDENTrAL DO A 023648 CONFIDENTIAL | STREH NUMBER ------------- i 2 3 4 s 6 T : 9 10 It 12 13 14 15 16 , 17 16 19 20 W< C HI* in/ __ i /iTt M / 1 l im/ __ C9*0NCNTS MW i _L a.1 la/m____________ TO 21 2 L9< im -UlMt.l D11IU 1X11 * -U1M -tHItt.tJ 1111*0 ini-- * 1111-- mi- 11*0-- 1 11*0*0 1 _____ai WW 4 --1M91 9*t 1 t**t t M< 1 m-c " t _____*J2 ____LI _____2_t _____2_l 4 1-- 0 ii-- a --1*222 _______2. 0 9 1 mu 1 _____U nrji * 2 ji___________________ _____Li _____U _____Li _____LI _____LX _____Li -------it _____Li _____Li _____Li ____Li _____Li _____Li 0 4M tt.pi tMI 1 < -- >> . W. tl *>' i|*M __ltgl-.l 'Ml -- 1*1* > i * _______2 5 M___________________ M.M l--l.l -inca l*4.t *** im H.* --. --1044,1 --1044.1 1044 1 1*44.1 n*i i ii*i.i 1 COB JUU Utl 1*11.1 iiii.i 1*11.4 Ml 0-- 1 MB 1 an i Bfl 1 0 00 0 * 0 11 0 iui e oa <M I ,,, i in i a 10 00 #0 *.? 1 0.1 1t 14 7 Mtm________________ h.w ______ 2 _______t t * 0 *.* 4 0 6 _________________ ______ 2 _______2 ______I ______1 ______2 ______2 ______2 ______9 ,,_____2 * 0 * * n**i l ***** I 0 ti J9 TOT*. LA/MI HIM).! IHIUI MM ft HUH.i (tail* at 1Mlt .oaua ll OMUFWf 12 -i>u 1 >CM * c*n.i MM* .* NN.1 m.i *m* *it.l f'C. !**. w. 0.4 11.1 . *.* in* * tin > MM.II M.1 *>*11 U M* 01.041 I.Mt M.lrt t.iri H.iri -- r 44.tif -- .01* 14 *4* r* --* 11.Ml m in 11.!** ii.au 10.--ft >1 cwchm.bc >miwm . l jtrom -mum Minw -** -4IMKM >mnn **11**M> H'HU*. I'M--i. -*M**. -M2'Ml. -MI'lt*. -.0011H4 IHt.lU H1IM0I. moHi. -t.fl)M1 -4.1MH* -S.I11U* ta. Li mt/iB 16 c>Bg> CMC___________ LL fluam lArtr_______ ll'M 'OBOO --0.1*14 1N1.1 ** 0.1100 Will IMH 1HH UM.l *1M .**10 10*4.4 a. MM 0.21*1 HM.i 4. MM ICC* 1-0040 IfCO irn.o mi 1.0*40 ; 1.0404 INI * mi tan.* Mil 1.0404 * Mil 04 U 4 i.aooo IHi *1 t 1.4000 im n o.* IMI IIM 11.Mil 111! 0 1a *M 111* 0 a M.an 119L 29 21 IKWMt__________ U *iai TMLM MCI WH TOMt TMIU 1011*2 TOll*) | T*f1*1 roi*> ML I* --ICC Main fC1V coh? rai* UWEt NOTES: DOW CONFIDENTIAL S3S 21 22 23 24 25 26 27 20 29 30 31 32 ^3^ _____2_1 I'M 00 01 0.1 M4 TMM. ? 0 UWtt * ______2 ______2 it 10--ffM MM * 1 B 4 * in.* 0* *1.1 imm.i JU,IU .-ill **#.4 0.0 4.4 0.* a. t a 1tn,f Ml #--*.* 0.0 0.0 0.0 a 0 o0 Ml 0 *.* ao ai Itft.t 0 Mil 11 < > lafM.ti 11041.01 !.* 114.01 I1.lt I*.144 I* 111 l* *11 1* 01* It.llft Ift.OBft M 10ft 1.1--Ml "111--11 -1.INM14 -1. 4*11(1 -DOSI1U -nil-- -1l**Oia. im* l 1.1 mill i 1I*A ft tin > Iftft. 1 11 t 00 0 # ft* Utl -- mi u. mi ftl MM ftt .* at u<a ,, miim______2 i **.* 0 0 1 4*1 ft a ll.ll 14. It tn.a in Mft IfttftMI. -*11 IIM -MI4 *11 , , * a a mim 1 mi ft* tut hrTM! UMK< lAMIO no IlftlM i-- r-" naH ||M|| Mtn *Aa ' twtai tialftft ' THB DOW CHEMICAL COM PANT iomswi Dimw_____________moox--g.tomti-- MATERIAL If HEAT BALANCE :.0RC t cnwnnON aae efM 810--10O~C50-00I HMB D0 A 073649 CONFIDENTIAL DO A 023fe& CONF V PREVIOUS REVIEW STATUS Listed Below are the Recommendations From The Previous CEI Audit Review. The Comments And Suggestions From Review Along With The Plant's Responses Are Attached. 1. Gas from the sump is evacuated to an undersized scrubber. Plans are to replace the scrubber. Scrubbers Replaced 7. A decision still needs to be made to either eliminate the one inch nipples or install the overpressure PSV's. Nipples Removed 8. Recommend that the electrical tracing be investigated to see if it can cause an over temperature problem. Electric heat tracing wiring would fault before the over temperature problem 9. Recommend that some method be found to test the EBV's on the bottom of the sphere on a periodic basis. Method Found. Will make modifications with next sphere outage. 10. The idea of reducing sphere pressure is still being evaluated. The idea of reducing sphere pressure is a major concern of the Chlorine Plant. This project will involve CATC help and capital expense to resolve. Paul Yonts July 18,1991 CEI:AA8 00 A 02,?S confident- DOW CHEMICAL U.S.A. July 12, 1989 LOUISIANA DIVISION P. O. BOX ISO PLAQUEMINE. LOUISIANA 70766-0160 604 3B9-S000 Jim Heaslip Joe Muller B4701T B2601 ex:: W. T. Austin J. G. Barksdale H. M. Bell J. Oldner B3701 B3701 B4701 B202 WHDC Listed belcw is the Chlorine I Plant's responses to HMTI-CEI Audit which was held on June 21, 1989: CEE REVIEW 5. What is the Chlorine Tech Center's reoomnendaticn cn the frequency of internal inspection of chlorine spheres? See attachment. 7. A decision still needs to be made to either eliminate the one inch nipples or install the overpressure PSV's. The decision has been made to eliminate the one inch nipples on the distribution manifold during the 1990 first quarter "A" Train outage. 8. Reoanmend that the elec, 'tracing be investigated to see if it can cause an overtenperature problem. IXie to materials of construction, electric heat tracing wiring would actually fault before reaching the overtenperature situation of a Chlorine-Iron fire. 9. Reocomend that some method be found to test the EBV's on the bottem of the sphere cn a periodic basis. A method of testing the EBV's on the bottom of the chlorine spheres on a periodic basis is being investigated. Plans are to devise a method of testing or partially testing the EBV's by 1990. AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY DO A 023652 CONFIDENTIAL HMTI-CEI RESPONSES -2- July 12/ 1989 10. The idea of reducing sphere pressure is still being evaluated. The idea of reducing sphere pressure is a major concern of the Chlorine Plant. This project will involve CATC help and capital expense to resolve this situation. This situation will be approached with the goal to determine the best way to reduce our sphere pressure to near atmospheric pressure. HMIT REVIEW 4. loading and unloading procedures are out of date but are being reviewed presently. The first draft of our loading and unloading procedures has been written and is awaiting review. 5. Recommend that the number of loaded tank cars be reviewed and a may-innm number be decided on. See Attachment Sincerely, Steve Landers Chlorine I Attachments gsh DOW CHEMICAL U.S.A. CEI - Quest. 5 Attachment Building B-2402, Phone 3481 mecp kt.iuas7>mi August 6, 1984 J. J. Leddy Chlor-Alkali Tech Center OCD LIQUID CHLORINE STORAGE SPHERE INSPECTION We recommend that the time between out of service inspections for chlorine spheres should be increased from five to at least ten years. We believe that the time between inspections could be increased to fifteen to twenty years or longer if corrosion monitors are located on either side (inlet and outlet) of the sphere. The reason for this recommendation is that the heat up and cool down cycles introduce periods of high thermal stress which .could cause cracking, and also because of the corrosion that takes place during the wash cycle. The corrosion monitors could be either electric resistance corrosion probes or coupons installed as shown on the attached drawing. Corrosion probes "and the instrument needed to read them can be purchased from either: Petrolite Instruments P.0. Box 2546 Houston, TX 77001 Phone 713-926-7431 or Rohrback Instruments 11861 East Telegraph Road Santa Fe Springs, CA 90670 Phone 213-949-0123 The corrosion probes should be all metal tubular without glass to metal seals. Pigtails can be run to an accessible location for taking readings. Readings should be taken after any upset which could cause corrosion and at a regular interval in between to insure that the instrument is working and people know how to use it. If weight loss coupons are used, I feel that four coupons should be placed on the end of a retractable (through a packing gland) probe so that one could be removed and replaced after any upset that could cause corrosion. Two of the coupons should be removed and replaced after 5 years of opera tion to determine the corrosion rate of the sphere. The results of all corrosion monitoring should be retained as part of the pressure vessel file. C. G. Arnold DO A 023654 CONFIDENTIAL. sh AN OPERATING unit OF THE DOW CHEMICAL COMPANY CHLORINE I LOUISIANA DIVISION LIQUID CHLORINE INVENTORY CONTROL Process storage : T-54 - MAX. CAPACITY 5.2 MM lbs. T-56 - MAX. CAPACITY 4.0 MM lbs. EMERGENCY SUMP STORAGE (located below the storage area) - 9.0 MM lbs. PROCESS STORAGE POLICY : THE TOTAL AMOUNT OF LIQUID INVENTORY WILL BE CONTROLLED AT 3.5 MM lbs. (1.0 MM lbs. of liquid chlorine inventory is necessary to maintain the proper net positive suction head on the liquid chlorine pumps.) AT NO TIME WILL EITHER STORAGE SPHERE EXCEED A 80% LEVEL WITH THE TOTAL COMBINED INVENTORY NEVER EXCEEDING 7.0 MM lbs. RAILROAD TANK CAR STORAGE : CHLORINE TANK CAR CAPACITIES - 90, 85, & 55 TONS RAILROAD TANK CAR STORAGE POLICY : RAILROAD TANK CAR INVENTORY IS A FUNCTION OF THE QUANTITY OF BUSINESS THAT IS ORIGINATED FROM THE CHLORINE I PLANT. A MINIMUM NUMBER OF LOADED TANK CARS, AS INVENTORY, IS ALWAYS DESIRED. AT NO TIME WILL MORE THAN SEVENTY TANK CARS BE ALLOWED, AS INVENTORY, WITHOUT MAJOR MANAGER APPROVAL. LIQUID CHLORINE INVENTORY GOAL IT IS THE ON GOING GOAL OF CHLORINE I TO MINIMIZE THE TOTAL AMOUNT OF WORKING INVENTORY. THIS WILL BE ACCOMPLISHED BE CONTINUED IMPROVEMENTS IN PRODUCTION PLANNING AND ENGINEERING. THIS GOAL WILL BE ACCOMPLISHED WITHOUT COMPROMISING THE PLANT'S CUSTOMERS. DPM 7/29/87 D0 A 023655 CONFIDENTIAL DOW CHEMICAL U.S.A. June 28, 1989 LOUISIANA DIVISION P. O. BOX ISO PLAQUEMINE, LOUISIANA 7076B-0150 604 380-8000 Steve Landers, B-2601 Joe Muller, B-2901 cc: J.G. Barksdale, B-3701 H.M. Bell, B-4701 J. Oldner, 2020 WHDC HMTI-CEI AUDIT AT CHLORINE June 21, 1989 COMMENTS AND SUGGESTIONS CEI Review 1. A large spill from the sphere will drain into a collection sump capable of holding the entire contents of the sphere. Gas from the sump is evacuated to an undersized scrubber. Plans are to replace the scrubber. 2. Inspection internally on the sphere is no longer done. Damage done to it during inspection was greater than through normal use. External inspections are still done on a regular basis. 3. Maximum capacity is administratively held to 2 1/2 million pounds. 4. Procedures are in place to prevent titanium from contacting dry chlorine. 5. What is the Chlorine Tech Center's recommendation on the frequency of internal inspection of chlorine spheres. 6. Replacement of corroded bolts and the installation of bellows seal valves has been done on the chlorine distribution lines to improve their condition. This is now audited on a regular basis from C-9. 7. A decision still needs to be made to either eliminate the one inch nipples or install the overpressure PSV's. 8. Recommend that the elec, tracing be investigated to see if it can cause an overtemperature problem. 9. Recommend that some method be found to test the EBV's on the DO A 023656 CONFIDENTIAL AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY MAXIMUM LINE CONTENTS 5100 LBS THEREFORE, ALL CHLORINE IN LINE CAN BE SPILLED IN 15 MINUTES. CONCLUSION: 5100 LBS CHLORINE WILL BE MAXIMUM SPILL QUANTITY. 7/1 9/91 PYONTSiGSH DO A 023657 CONFIDENTIAL  JCSSL?S*!_ri.Jj o ooo =NOITM Mnu 4IM yU ol Ic STOCK NON) BtOCX 41OETWL IEGZMO' ( 1 mm Mnun Of #v*t/ *>*. f* ' ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** CHS :CAL EXPOSURE INDEX PLANT: CHLORINE I LOCATION: LAD CHEMICAL: CHLORINE TOTAL QUANTITY IN PLANT: 7000000.00 lb LARGEST SINGLE CONTAINMENT: 4200000.00 lb STORAGE TEMPERATURE: -22.00 deg F STORAGE PRESSURE: 180.00 psia BOILING POINT: -30.00 deg F FLASH POINT: 0.00 deg F MOLECULAR WEIGHT: 70.90 TSEPG CONCENTRATION: 1.0 ppm EKP*--/ EXPOSURE RISK POTENTIAL SUMMARY ACUTE HEALTH HAZARD FACTOR: 4 (1.0 - 9.9) VAPOR QUANTITY FACTOR: 3 (1,000 lbs - 10,000 lbs) MOLECULAR WEIGHT FACTOR: 4 ( > 45) 'iss PENALTIES: 2 (overpressure or run-away reaction potential) DISTANCE TO THE PUBLIC TO DOW PLANTS TO OTHER BUSINESSES DISTANCE FACTOR 3 (1000 ft - 5279 ft) 4 ( < 1000 ft) 3 (1000 ft - 5279 ft) E.R.P. VALUE 288 384 288 EXPOSURE RISK POTENTIAL TO THE PUBLIC = 288 BIANNUAL REVIEW - SITE, SUPERINTENDENT AND MAJOR MANAGER THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ********** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL DO A 023659 CONFIDENTIAL ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** D, 'ERSION SUMMARY TOTAL DISCHARGED 5100.00 LBS RELEASE DURATION - 8.70 MIN MOLECULAR WEIGHT - 70.90 SOURCE TEMPERATURE = -22.00 DEG F EEPG CONCENTRATION = 1.0 ppm SOURCE HEIGHT = 0.00 FT SOURCE DIAMETER - 0.00 FT EXIT VELOCITY - 0.00 FT/S PERCENT DILUTION - 0.00 AMBIENT TEMPERATURE = 86.00 DEG F THE RELEASE IS A GAS RELEASE THE RELEASE IS CONTINUOUS THE RADII OF EXPOSURE ARE BASED ON PEAK CONCENTRATIONS CONC (ppro) RADII OF EXPOSURE (miles) @ ground level - @ plume centerline UNSTABLE 12. mph (20 %)* NEUTRAL 8. mph (40 %)* STABLE 4. mph (40 %)* 1.0 1.500 8.945 66.937 10.0 0.494 2.076 10.071 100.0 0.178 0.532 2.034 * APPROXIMATE % OF TIME IN THIS WEATHER CONDITION UNSTABLE ATMOSPHERIC CONDITION - SLIGHT SOLAR RADIATION WITH LOW WIND SPEEDS (<10 mph) OR STRONG RADIATION WITH HIGH WIND SPEEDS (>10 mph). NEUTRAL ATMOSPHERIC CONDITION - WELL MIXED ATMOSPHERE DUE TO MODERATE/STRONG WIND SPEEDS (>7 mph) AND SLIGHT/MODERATE SOLAR RADIATION. ANY OVERCAST CONDITION. STABLE ATMOSPHERIC CONDITION - LOW WIND SPEEDS (<10 mph) AT NIGHT. THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DO A 0236>60 CONFIDENTIAL ***** DOW CONFIDENTIAL **** * DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** CH,, .CAL EXPOSURE INDEX PLANT: CHLORINE I LOCATION: LAD CHEMICAL: HYDROCHLORIC ACID TOTAL QUANTITY IN PLANT: 53000.00 lb LARGEST SINGLE CONTAINMENT: 53000.00 lb STORAGE TEMPERATURE: 86.00deg F STORAGE PRESSURE: 14.70 psia BOILING POINT: 178.00 deg F FLASH POINT: 0.00 deg F MOLECULAR WEIGHT: 36.00 'EEPG CONCENTRATION: 3.0 ppm ~/ !=IT--' ? HIP^_ r ^ ?-' 6S. 5- r EXPOSURE RISK POTENTIAL SUMMARY ACUTE HEALTH HAZARD FACTOR: 3 (10 - 99) VAPOR QUANTITY FACTOR: 2 (100 lbs - 999 lbs) MOLECULAR WEIGHT FACTOR: 3 (34 - 45) -SS PENALTIES: 1 (no process penalties) DISTANCE TO THE PUBLIC TO DOW PLANTS TO OTHER BUSINESSES DISTANCE FACTOR 3 (1000 ft - 5279 ft) 4 ( < 1000 ft) 3 (1000 ft - 5279 ft) EXPOSURE RISK POTENTIAL TO THE PUBLIC = 54 NO REVIEW - SUPERINTENDENT AND MAJOR MANAGER APPROVAL E.R.P. VALUE 54 72 54 -- THE CHEMICAL EXPOSURE INDEX IS A SIMPLE, EMPIRICAL AND RELATIVE METHOD FOR RATING THE TOXIC HAZARDS OF CHEMICALS IN A QUANTITATIVE MANNER. ** FOR INTERNAL DOW USE ONLY ** - ***** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ****** DOW CONFIDENTIAL ***** DO A 023661 CONFIDENTIAL 1803 BUILDING August 27,1991 The Dow Chemical Company MiOlana Michigan 48674 LOUISIANA DIVISION L.D. Adcock 2306 W. T. Austin 3701 E. D. Crochet 3601 M. Currier 2303 K. L. Johnson 3601 G. D. Kusch 2303 G. L. Meier 3502-E J. J. Muller Jr. 2601 A. L. Royals III 3502-W M. D. Ryland 807 R. B. Speed R. L. Stevens M. J. Sticklen M. J. Torres Jr. midland G. G. Bond R. R. Cook R. D. Egedahl G. W. Engdahl R. H. Fike J. M. Lanham 901 807 8601 2601 1803 1803 1803 1803 1803 1803 V. T. May 1803 G. W. Olsen 1803 C. N. Park 1803 L. W. Rampy 1803 J. Saunders 1803 A. W. Schaffer 1803 M. G. Swank 1803 OIHER________ J. S. Biggs Torrence D. E. Crager Freeport J. McKirdy Hong Kong CORRECTION TO INDUSTRIAL HYGIENE REPORT NUMBER LAD-IH-91.01 ENTITLED "CHLORINE EXPOSURES AND WORK HISTORIES FOR PARTICIPANTS IN THE "PROSPECTIVE STUDY OF THE EFFECTS OF CHRONIC CHLORINE EXPOSURE IN MANUFACTURING ON RESPIRATORY HEALTH' ", FINAL REPORT An error was detected in the compiling of the exposure files involving the length of time over which a sample was collected. A different more accurate measure of the time length was used and the tables corrected. Clarification of several footnotes was also made. These corrections involved Tables 1-4, Tables 11-28, and Table 33. The changes resulted in only minor alterations in exposure numbers, a slight increase in most cases, and should not alter any of the preliminary findings. Please destroy the previous copy of the report and replace it with the current version (LAD-IH-91.01 (R)). If you have any questions regarding the revisions, please call. Bryce D. Landenberger Senior Research Statistician Health & Environmental Sciences (517)636-9005 0 A 02366? CONFIDENTIAL Louisiana Division Industrial Hygiene Report An Operating Unit of the Dow Chemical Company Department Industrial Hygiene File Number LAD-IH-91.01 (R) Data 8-27-91 Title; Chlorine Exposures and Work Histories for Participants in the "Prospective Study of the Effects of Chronic Chlorine Exposure in Manufacturing on Respiratory Health", Final Report Q~S. Set B. D. Landenberger J. S. Paul e wer's Signature Ci. R. M. A./HahLn--e-- I I Summarv/Recommendations S. K. Norwood This final report summarizes the 1984-88 chlorine exposures and work histories for participants in The Dow Chemical Company-Tulane University collaborative chlorine study described in the protocol, "Prospective Study of the Effects of Chronic Chlorine Exposure in Manufacturing on Respiratory Health." The exposure data collected during the study were subjectively compared for large changes that might preclude the combination of these data sets. No evidence was found to indicate that major differences existed. Thus, the data were combined into a single data set. The exposure group data were transformed into three separate data sets based on the assumed effectiveness of respirators during use. These categories were: completely effective (100%), partially effective (90%), and ineffective (0%). Categorization in this manner allows for examination of the potential exposure as well as a better estimate of actual exposure. Transformation of the control group was not required since respirators were not used. The data were tabled as time weighted averages (TWA's) with thresholds used to segment the data into peak exposures. The maximum potential TWA exposures ranged from 0.01 ppm to 0.30 ppm across all job assignments (based on respirator usage being 90% effective). Quality assurance procedures in the protocol were followed throughout the study. Laboratory validation studies indicated that field comparisons between the sulfamic acid collection method and the electrochemical chlorine monitors were not required after the first sampling cycle. It was also determined after the first cycle of data collection that no modifications in the original sampling strategy were required ot useful. Thus, the same sampling scheme outlined in the original protocol was followed throughout the study. Distribution LOUISIANA DIVISION L.D. Adcock 2306 *W. T. Austin 3701 E. D. Crochet 3601 M. Currier 2303 K. L. Johnson 3601 *G. D. Kusch 2303 G. L. Meier 3502-E J. J. Muller Jr. 2601 A. L. Royals III 3502-W *M. D. Ryland 807 *R. B. Speed *R. L. Stevens *M. J. Sticklen *M. J. Torres Jr. MIDLAND___________ *G. G. Bond R. R. Cook *R. D. Egedahl *G. W. Engdahl R. H. Fike J. M. Lanham 901 807 8601 2601 1803 1803 1803 1803 1803 1803 V. T. May 1803 G. W. Olsen 1803 *C. N. Park 1803 *L. W. Rampy 1803 J. Saunders 1803 A. W. Schaffer 1803 M. G. Swank 1803 QEEE__________ J. S. Biggs Torrence *D. E. Crager Freeport *J. McKirdy Hong Kong Cover sheet only DO A 023663 CONFIDFNTIAL LOUISIANA DIVISION INDUSTRIAL HYGIENE REPORT AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY CHLORINE 1 PLANT Department LAD-CHLORINE 91.01 File Number 7/16/1991 Date Title: Evaluation of employees' exposure to noise, asbestos, chlorine, and lead and associated Industrial Hygiene Activities at the Louisiana Division Chlorine 1 Plant, Plaquemine, Louisiana during 1990. During 1990, personal time weighted average (TWA) exposures to noise and chlorine were evaluated. Excursion or short term exposures to asbestos during specific tasks were evaluated and area monitoring for lead exposures during non-routine maintenance was performed. A sound level survey was conducted throughout the plant Employee exposures to asbestos during task related activities ranged from <0.01 to 0.09 fibers per cc of air. Task involving glove bag asbestos removal ranged between 0.01 to 0.09 fibers per cc of air and were potential exposures because personnel wore Noth 7700 half-face respirators equipped with high efficiency filters during the job. The job task of treating chlorine cells with wetted asbestos ranged from <0.01 to 0.04 fibers per cc of air. The job of treating cells is handled in a closed system. This data is well within the OSHA short term excursion limit of 1.0 fibers per cc of air for a 30 minute duration. All results were reported based on the limit of detection of 7 fibers/mm2. (Continued on Page 2) DISTRIBUTION: Plaquemine: L. Adcock T. Austin C. Cooke G. Kusch G. Meier J. Muller A. Royals A. Sandow * * * * * * * B-2306 B-3701 B-2601 B-2303 B-3502W B-2601 B-3502W B-3701 * Cover Sheets Only Midland: G. Engdahl V. May L. Rampy A. Schaffer M. Swank * * * B-1803 B-1803 B-1803 B-1803 B-1803 RESTRICTED FOR USE WITHIN THE DOW CHEMICAL COMPANY DO A 02366A onftdfntial C. Chlorine 1 EDUCATION and TRAINING SUMMARY Employees receive Hazard Communication (HazCom) Training in plant indoctrination and in annual HazCom meeting. The written Hazard Communication Manual is current and kept in the Industrial Hygiene Contact's office in B-2601. The manual is for everyone's use. Material Safety Data (MSD) Sheets are current and are kept in the Hazard Communication Manual. STRENGTHS Hazard Communication is emphasized through the HazCom Manual, the plant's indoctrination film, in the annual HazCom meeting and per job through the safe work permit OPPORTUNITIES for IMPROVEMENT Improve indoctrination training for technical and clerical new hires. Include review of ^A^for Indoctrination Training. Train Dow and non-Dow personnel on the proper method to label containers. Provide an efficient and effective method to communicate and document new health effects communications. KGJ 07/91 CQ A 023665 CONFIDENTIAL Chlorine 1 RESPIRATORY PROTECTION PROGRAM SUMMARY Respirator program is current and addresses the elements contained in S & LP Standard S-206. The IJi. contact is responsible for implementing the program and performing training and fit testing. All personnel are required to carry a mouthbit, escape respirator. Respirators are inspected as part of the C-9 safety checklist and in accordance with the Chlorine Respirator Block Policy. STRENGTHS Respirators are inspected regularly. Respiratory program is incorporated into In Plant Training(IPT). All personnel required to use a SCBA must demonstrate proficiency on an annual basis. OPPORTUNITIES for IMPROVEMENT Enforce proper cleaning of mouthbit respirators as defined in the Block Respiratory Policy. Continue pursuit and investigation of alternate methods to obtain sulfuric acid conditions other than a manual grab sample. X Complete respirator fit testing by end of 1992. KGJ 07/91 DO A 023666 CONFIDENTIAL Chlorine 1 VENTILATION PROGRAM SUMMARY Jobs such as lab chemical testing and cell operations sampling are provided with fume ventilation hoods. Vent hoods are inspected and tested annually for performance. STRENGTHS Ongoing testing/inspection/maintenance program for ventilation hoods. Flow sensing devices are permanently installed on lab fume ventilation hoods. The main laboratory hood has a cell effluent scrubber to neutralize chlorine. OPPORTUNITIES for IMPROVEMENT Evaluate the effectiveness of general shop ventilation during welding operations. KGJ 07/91 DO A 023667 CONFIDENTIAL Chlorine 1 HEARING CONSERVATION SUMMARY All Personnel are included in the hearing conservation program and are given annual audiograms. Also, periodic personal audio dosimeter monitoring is performed as well as an annual area noise survey. High noise warning signs are posted in appropriate areas. STRENGTHS Jobs with potential exposure to greater than 85 db(A) have been identified. Audiograms are performed on every employee annually. Have a written Block Hearing Conservation Program. Annual training is given on LAD Hearing Conservation Program. OPPORTUNITIES for IMPROVEMENT Update Hearing Conservation Training to include the block program and hearing attenuation effectiveness. Have Division noise expert perform octave band analysis of the plant and make recommendations for engineering improvements to reduce noise in areas above 90 decibels. KGJ 07/91 DO A 023668 CONFIDENTIAL Chlorine 1 PERSONAL PROTECTIVE EQUIPMENT SUMMARY Personal protective equipment is required by job procedure and by safe work multi permit. All PPE used is approved by the Division PPE committee. STRENGTHS Proper PPE is available and sufficient for all jobs. Verification of dielectric effectiveness of rubber boots is required and documented before entrance into the cell area. OPPORTUNITIES for IMPROVEMENT Promote Contractors to train their own employees on proper use of PPE. KGJ 07/91 DO A 023669 CONFIDENTIAL Chlorine 1 DATA GENERATION and MONITQEING SUMMARY The I.H. contact performs exposure monitoring for the block. All jobs of concern are monitored. Sampling devices are calibrated before and after each sample. There are 22 continuous Chlorine monitoring probes strategically located in the Chlorine Block. STRENGTHS An extensive database for potential chlorine exposure has been built through the DowTulane Epidemiology Study. Chlorine probes continually monitor the Chlorine Plant and display concentration readings along with the wind direction at the control board. OPPORTUNITIES for IMPROVEMENT Continue development of database for noise. Continue hazard evaluation and develop monitoring strategy based upon the evaluation. kg; 07/91 DO A 023670 CONFIDENTIAL Chiorine 1 ASBESTOS SUMMARY Chlorine's strategy for removal of asbestos is to use a non-asbestos replacement when the material is damaged or needs to be replaced. All asbestos work is handled by non-Dow employees who have received the required asbestos training. A program is currently in progress to eventually replace all asbestos gaskets with non-asbestos gaskets. STRENGTHS The Plant has an Asbestos Abatement Team that oversees the handling and containment of asbestos in the block. * An extensive survey of asbestos used in the Chlorine block has been completed and is documented. The hazards of asbestos are communicated annually in the HazCom Training. Asbestos gasket evaluation project has been started. OPPORTUNITIES for IMPROVEMENT Continue asbestos gasket evaluation project. Investigate alternative asbestos gasket storage practices. KGJ 07/91 DO A 023671 CONFIDENTIAL Chlorine 1 RADIATION SUMMARY There are four sealed radiation sources located in the Chlorine Block. One source is an Ohmart level detector for the Chlorine Storage sphere (T-56). Another source is an Ohmart density device for Hydrochloric Acid. The last two sources are for Texas Nuclear lab analyzers. The required warning signs are posted and the Division Radiation Officer handles any removal of the sources when required. STRENGTHS Radiation sources are handled according to Division requirements and are wipe tested by the Division Radiation Officer regularly. Proper postings are maintained. OPPORTUNITIES for IMPROVEMENT Include the effects of radiation as part of the Hazard Communication Training. Remove the Ohmart from T-56 the next time the vessel is scheduled for a vessel inspection. This job is to be done with the planning and supervision of the Division Radiation Officer. KGJ 07/91 Chlorine 1 GENERAL - INDUSTRIAL HYGIENE SUMMARY Asbestos is the only OSHA regulated chemical used in the block. It is only handled in a wet, closed system to do maintenance on chlorine cells. Accidental ingestion of chemicals due to lunch room location or washing practices has not been a problem. Dermatitis has not been a problem in the block. STRENGTHS Designated areas are used for storing food and eating lunch. Washrooms are strategically located next to lunchrooms to promote proper hygiene before ingesting food. OPPORTUNITIES for IMPROVEMENT Encourage washing hands and face before eating and smoking by adherence to the Block Industrial Hygiene Policy. KGJ 07/91 DO A 023673 CONFIDENTIAL Chlorine 1 medical SUMMARY The block adheres to the Division Medical Department's requirements for medical surveillance and testing. Results of medical tests are communicated to employees in a timely manner. STRENGTHS Medical Department requirements for surveillance/testing are followed. OPPORTUNITIES for IMPROVEMENT KGJ 07/91 DO A 023674 CONFIDENTIAL Chlorine 1 NON-DOW EMPLOYEES SUMMARY All non-Dow employees receive indoctrination training which includes required PPE, emergency response, and hazard communication. Hearing protection, gloves, respirators, monogoggles, and other PPE is supplied to the permanent in-block contractors. In-block contractors receive the same medical surveillance as Dow employees. Lunch room and change/shower facilities are provided for contractor use. STRENGTHS All non-Dow employees receive hazard communication training. MSD sheets are available for use. Non-Dow employees are included in I.H. monitoring program. Results of monitoring data are communicated annually. OPPORTUNITIES for IMPROVEMENT Communicate and document monitoring results in a more timely manner. KGJ 07/91 00 A 023675 confidential