Document Qk0oBxdnqMNDDQZXXJqJ5e0yE
Louisiana Division Consolidated Assessment
Hazardous Materials Transportation Review
Review Pate 7/14/96
Location-Division Louisiana
Plant Facility Glycol 1 Loading/ Central Rail Rack
Building(s) Bldg. 1501,
Superintendent - Charles Jackson / Stew Serpas Logistics
Major Author Tom Bulger
Review Team Members
______
Chemicals Reviewed: Propylene Oxide DRI-4 Propylene Dichloride DRI - 3
This document has been developed solely for use within The Dow Chemical Company, and is thus marked as "Restricted For Use Within Dow". Sharing of this document with persons not employed by or affiliated with The Dc Chemical Company must be cleared through the North America Safety, Loss Prevention, and Security Department
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HMTR Questionnaires
Introduction
Purpose Responsibility
This collection of questionnaires is a part of the Review Package for the Hazardous Materials Transportation Review (HMTR) which will be discussed in the Formal Review during the Consolidated Audit. Complete only the questionnaires that apply to your plant
To provide a basis for discussion, at the Formal Review, of the plant's awareness and understanding of its distribution responsibilities.
The plant superintendent is ultimately responsible for completing the questionnaires and distributing them when completed.
The superintendent may designate a knowledgeable person to complete and distribute the questionnaires.
Deciding which use this table to decide which complete13*1^ * ques^onna^es yu must complete.
If you...
Are preparing for a HMTR
Then fill in the...
Emergency Response Questionnaire and Equipment Construction Questionnaire
AND...
If you...
Then HU in the...
Ship bulk materials
Outbound Bulk Questionnaire
Receive purchased materials
Inbound Bulk Questionnaire
Ship or receive materials by marine vessel Marine Questionnaire
Ship bulk waste materials
Waste Questionnaire
What to do with the completed questionnaire
Distribute to the appropriate Review Committee members, at least three weeks prior to the Consolidated Audit.
Note: Contact your HMTR focal point for the names and numbers of copies to distribute.
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Name of Material
EMERGENCY RESPONSE QUESTIONNAIRE
Resource - Operations, Distribution Emergency Response, Site Emergency Services
1. Who are the Dow "Knowledgeable Plant Contacts" (KPCs) for an en route emergency?
Name _Tom Bulger
24 Hr Phone _(504) 353-8440
Name _AJ. Raymond
24 Hr Phone _(504) 353-8440
Name _Yvonne Williams
24 Hr Phone _(504) 353-8440
Name _ Lawrence Hughes
24 Hr Phone J504) 353-5733, pager 322-5733
2. How do you document that these contacts are trained and familiar with their role in a
distribution emergency response?
Ref: 29 CFR 1910.120
Yearly Training as documented in supervision files.
3. For purchased materials, who are "knowledgeable" contacts for an en route emergency?
Supplier Name N/A
24 Hr Phone
Supplier Name
24 Hr Phone
4. Are ALL inbound raw materials F.O.B. Dow? That is... Dow accepts ownership when it arrives at Dow's gate.
Yes [ ]
No [ ] Not Apply [ X ]
5. Do your plant's Knowledgeable Dow Contacts have a Distribution Emergency Response
(E/R) information packet, notebook, or briefcase for the both materials shipped and
received?
Yes [ X ]
No [ ] If" No", why not?______
One for the plant
6. What special properties of your material should be made known?
Propylene Oxide is flammable-------PDC - AL
7. What "specialized" equipment and/or resources would be necessary in a transportation incident? Consider: Drager or GasTec sample pump and tubes, explosimeters, absorbent materials, neutralizers, materials of construction, and clean-up and disposal information.
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Hazardous Materials Transportation Review HMTR Questionnaires
Explosive Meter, brass tools, Nomex, EPR "O" rings, Vtion "O" rings, PO and PDC
approved respirator.
____________________________________________________________
8. Is emergency response information included with all shipments made from the plant? Ref: 49 CFR 172.600
Bulk [X ] Package shipments [ X ] No [ ] Not Apply [ ]
If" No", why not?
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Name of Material Propylene Oxide and Propylene Dichloride
EQUIPMENT CONSTRUCTION QUESTIONNAIRE
Resource - Distribution Emergency Response, Distribution Regulatory Affairs, Tech Centers
1. What are the acceptable Department of Transportation (DOT) or International Maritime Organization (IMO) equipment specifications? Ref: 49 CFR 172 & 173
Not Known [ ]
Drum (like UN 1A1 or DOT 17E): Not Apply [X] Cylinder (like DOT 3A):Not Apply [X] Tank Truck (like MC 307): MC 330 or MC 331 for PO IMO Bulk Tank (like IM 101): IM10 for PDC Rail Car (like DOT 111A100): PD-DOT 111A100W. PQ-1054100W Other:Not Apply [ ]
2. Can this material be transported without requiring special local, state, or federal permits or approvals (like: DOT Exemptions or special approvals)? Ref: 49 CFR 107 Subpan B
Yes [X]
No [ ]
If" No", please attach copies of the exemptions or approvals.
3. How is the container material of construction verified for compatibility before loading? Ref: 49 CFR 173.22 Yes, Check sheets / TEDER sheets/ Spec Plate / NEW ACFX T/C's non AL
4. How is the gasket material verified for compatibility before loading? Ref: 49 CFR 173.22 PO - Tags on PS stamped "EPR "O" Rings"
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Name of Material Propylene Oxide and Propylene Dichloride
OUTBOUND BULK QUESTIONNAIRE
Resource - Manufacturing, Distribution/Traffic, Distribution Regulations, Industrial Hygiene, Product Tech Center, Distribution Emergency Response
1. List any special concerns for this material while in transit?
None Like: Anhydrous HC1 - Extended time will result in excessive pressure.
2. Do you have a process to verify?
Correct unit number Correct DOT vehicle specification
Yes [X] No [ ] Not Apply [ ] Yes [X] No [ ] Not Apply [ ]
Container integrity Analysis of heels
Yes [X] No ( ] Not Apply [ ] Yes [X] No [ ] Not Apply [ ]
Final securement
Yes [X] No [ ] Not Apply [ ]
Carrier has correct personal protective equipment Yes [X] No [ ] Not Apply [ ] (PO tank trucks and PDC tank trucks only)
3. Are you satisfied with the safety, service, and emergency preparedness of the companies transporting your materials?
Yes [ X] Yes [ X ]
No [ ] Not Apply [ ] for Rail No [ ] Not Apply [ ] for Truck
4. If" No", do you have a system to provide input to those evaluating carrier performance?
Yes [ ]
No [ ]
5. For truck transportation, is product specific driver training provided by Dow personnel?
Yes [ X]
No [ ] Not Apply [ ] (For PO transporting only)
6. Has personal protective equipment required for loading this product been tested or approved by the Industrial Hygiene Department? Ref: 29 CFR 1910.133 - 134
Yes [ X ]
No [ ]
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7. List the methods used to assure that the container is not overloaded: Ref: 49 CFR 173.24, 173.314 and LPP 8.1.4
For Rail MGD. High Pressure trip. Flow meter on PDC only
For Truck Weigh Scales. Liquid vent trip. Loader check list
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HMTR Questionnaires
Name of Material Propylene Oxide and Propylene Dichloride
OUTBOUND BULK QUESTIONNAIRE - continued
8. Is the vapor space prevented from passing through the flammable range during loading? Ref: LPP 8.1.4
Yes [X]
No [ ] Not Apply [ ] for Rail
Yes [X]
No [ ] Not Apply [ ] for Truck
9. Are only Dow personnel involved in loading this product?
Yes [ ]
No [X ]Not Apply [ ] for Rail (Dow trained contract loaders also)
Yes [ ]
No [X] Not Apply [ ] for Truck(Dow trained contract loaders also)
If "YES," go to Question 12
10. Have non-Dow personnel been trained in the proper handling of this material?
Yes [X]
No [ ] Not Apply [ ]
11. How do you assure the non-Dow loader uses the proper protective equipment during the loading operation? Training on Protective Equipment, Training verified by documentation.
12. What system do you have to verify that the driver or conductor has the required papers
and emergency response information? Ref: 49 CFR 172.600 Loading checklist, Emergency Response info on rail and tank truck bill of lading.
13. List any special concerns with loading this material. PDC - Do not load or Aluminum Tank Cars or Trucks
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Name of Material - POES NOT APPLY
INBOUND BULK QUESTIONNAIRE
Resource - Product Prime Buyer (through division Purchasing), Distribution Regulations, Distribution Emergency Response, Industrial Hygiene
1. Do you have a "system" to report supplier defects to the purchasing department?
Yes [ ]
No [ ]
2. List any concerns you have for this material while in transit?
Like: Anhydrous HC1 - Extended time will result in excessive pressure.
3. Has personal protective equipment required for unloading this product been tested or approved by the Industrial Hygiene Department? Ref: 29 CFR 1910.133-134
Yes [ ] No [ ]
4. Are only Dow personnel involved in unloading this product in your plant?
Yes [ ] No [ ]
5. Has the non-Dow unloader been trained in proper unloading procedures in your plant? Ref: 49 CFR 174.67 and 177.834
Yes [ ) No [ ] Not Apply [ ]
6. Who documents the training?
7. How do you assure the non-Dow unloader uses the proper protective equipment during the unloading operation? (Like: cooling tower chemicals, compressed gases, and other raw materials.)
8. Is the material analyzed for positive identification before unloading begins? Ref: Global Hazardous Materials Distribution Guidelines, Section 1.6
Yes [ ]
No [ )
9. Is the vapor space prevented from passing through the flammable range during unloading?
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Ref: LPP 8.1.4
Yes [ ]
No [ ] Not Apply [ ]
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Name of Material Propylene Oxide
MARINE QUESTIONNAIRE
Resource - Marine Technology Center (Freeport, TX), Marine Chartering (Houston, TX), Your
local Marine Dept
1. Are Dow personnel the only ones directly involved with the marine transfer (loading/unloading) operations for the material being shipped into or out of your facility?
Yes [X ]
No [ ]
2. If" No", how is training and/or licensing verified for the other people involved with the marine transfer? Ref: 46 CFR, Parts 10 and 123 4 5 6 7
3. Is the training documented?
Yes [X]
No ( ] Not Apply [ ]
4. Have the facilities of the department performing the transfer been audited via the Marine Tech Center or the Terminal Tech Center?
Yes [ ]
No [ X]
Not Apply [ ]
Date of last Review__ To be audited in 1997 by Distribution Technology Center
5. If "YES", attach a copy of the recommendations and response/action plans from the last Marine Tech Center or Terminal Tech Center audit.
Not Apply [ ]
6. Does your Marine Emergency Response Plan comply with the Dow Marine E/R Guidelines. Ref: 33 CFR, Parts 150 and 154
Yes [X ]
No [ ] Not Apply [ ]
If "NO", what are your plans to achieve compliance?________________________________
7. Is your marine E/R plan periodically tested?
Yes [ X]
No [ ] Not Apply [ ]
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HMTR Questionnaires
8. Is the testing of your marine E/R plan documented?
Yes [X ]
No [ ] Not Apply [ ]
9. Does the department responsible for loading check for the cleanliness and compatibility of the bulk container prior to loading?
Yes [X]
No [ ] Not Apply [ ] In addition to 3rd party inspection for such.
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Name of Material Propylene Oxide
MARINE QUESTIONNAIRE - continued
10. If you load on heels are they analyzed "for last contained"?
Yes [X ]
No [ ] Not Apply [ ]
11. How do you assure that reactive chemicals are not mixed during the loading/unloading
process? Pre Load Heel Samples, and Load Samples
12. List the methods used to assure that the vessel tank/container is not overloaded:
Ships have High/High level alarms--Manual and Electric, and Loader checks The Marine docks have pump kill switch
13. Is the vapor space prevented from passing through the flammable range during loading/unloading? Ref: LPP 8.2.3
Yes [X]
No [ ] Not Apply [ ]
14. Has personal protective equipment required for loading/unloading this product been tested or approved by the Industrial Hygiene Department?
Yes [X]
No [ ] Not Apply [ ]
15. How are carrier personnel informed of the hazards of the material being transported? Through ship posting of the Material Safety Data Sheet (MSDS)
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Hazardous Materials Transportation Review _____________________ _____________________________ HMTR Questionnaires
Name of Material DOES NOT APPLY
WASTE QUESTIONNAIRE
Resource - Environmental Services, Environmental Operations
1. Has Environmental Services reviewed your material within the last 2 years to determine if all EPA regulations are being followed?
Yes [ ]
No [ ] When?
2. What modes of transport are used to ship this material?
Package truck [ ] Bulk truck [ ] Vacuum truck [ ] Rail [ ] Other [ ]
3. Does the equipment (including drums, tanks, vacuum trucks, and other containers) used to transport this material meet DOT specifications?
Yes [ ]
No [ ] Not Apply [ ] Don't Know [ ]
4. Are only Dow personnel involved in loading/unloading this material?
Yes [ ]
No [ ]
If "YES," go to Question 7. 5. Have non-Dow personnel been trained in the proper handling of this material?
Yes [ ]
No [ ]
6. How do you assure the non-Dow loader/unloader uses the proper protective equipment during the loading/unloading operations?
7. Do you have a process to verify? Correct unit number Correct DOT vehicle specification Container integrity Analysis of heels Final securement Marking, labeling, and placarding
Yes [] Yes [] Yes [] Yes [] Yes [] Yes []
No[ ] Not Apply [ ] No[ ] Not Apply [ ] No[ ] Not Apply [ ] No[ ] Not Apply [ ] No[ ] Not Apply [ ] No[ ] Not Apply [ ]
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HMTR Questionnaires
8. Is the vapor space prevented from passing through the flammable range? Ref: LPP 8.1.4
Yes [ ]
No [ ] Not Apply [ ]
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Name of Material______________________________________________________
WASTE QUESTIONNAIRE - continued
9. What process do you have to assure that container is not overloaded? Ref: 49 CFR 173.24 and 173.314
10. What system do you have to verify that the driver, conductor, or tanker person has the required papers and emergency response information? Ref: 49 CFR 172.600
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