Document YD6qeGod2JKpxwrBbr9B5O4zV

1994 CHLOR-ALKALIII CONSOLIDATED AUDIT AUDIT RECOMMENDATIONS AND ACTION ELAN DATABASE 'This book is to reside in the Safety Compliance Checklist Files (Old C-9) and to be removed with the Safety & Training Coordinator's approval only." OO A 046?06 CONFTDFNTTAl APPENDIX A. SAFETY QUESTIONNAIRE DIVISION: PLANT/DEPARTMENT: BUILDING: REVIEW DATE/TIME: SAFETY AUDIT TEAM Safety Superintendent/Director/Engineer: Safety Functional Team Leader: Process S&LP (Audit) Specialist: Technology Center Representative: Other Audit Team Members: SAFETY AUDITEES Superintendent/Department Head: Plant/Department Personnel: Major Manager Page 1 Dow Confidential DO A 04A?07 OONF T DFNT I Al 9/93 hrw/dsj APPENDIX A. SAFETY QUESTIONNAIRE TABLE OF CONTENTS APPENDIX A. SAFETY QUESTIONNAIRE A-1. PROGRAM STRUCTURE AND PLANNING................................................................2 A-2. EMPLOYEE PARTICIPATION........................................................................................4 A-3. CONTRACTOR SAFETY.................................................................................................5 A-4. ACCIDENT/INCIDENT INVESTIGATION AND REPORTING................................ 6 A-5. AUDITS............................................................................................................................... 8 A-6. SAFE WORK PRACTICES................. 10 Safe Work Permits...................................................................................................... 10 Hot Work Permits....................................................................................................... 10 Line and Equipment Opening.................................................................................... 11 Confined Space Entry.................................................................................................12 Lockout and Tagout Procedures................................................................................ 13 Guarding and Interlocking..........................................................................................14 Fall Protection............................................................................................................. 14 A -7. EMERGENCY PLANNING AND MEANS OF EGRESS............................................ 15 A-8. EMPLOYEE TRAINING................................................................................................. 15 A-9. SAFE OPERATION OF MOTOR VEHICLES AND MOTORIZED HANDLING EQUIPMENT...................................................................17 A-10. OFF-THE-JOB SAFETY..................................................................................................18 A-11. PROCESS SAFETY MANAGEMENT LISTS................................................................19 APPENDIX B. EMPLOYEE SURVEY......................................................................................21 APPENDIX C. DOCUMENTATION REVIEW....................................................................... 23 APPENDIX D. FIELD INSPECTION.......................................................................................34 APPENDIX E EMPLOYEE/CONTRACTOR INTERVIEWS............................................... 51 00 A 046208 G0NFTDFNTTAI Page 2 Dow Confidential 9/93 hrw/dsj APPENDIX A. SAFETY QUESTIONNAIRE Question Identification for a Limited Audit: A = Dow rule or regulation B = Good practice/training C = Hazard Analysis A-l. PROGRAM STRUCTURE AND PLANNING B 1. Describe your plant/department safety organization. Include its relationship with the overall organization. (List teams and committees.) A Team/ Composition Committee Freq. of meetings OT7L- Minutes Published 7^ Pre-pub. Agenda p) / Pre-Est Charter B 2. Does the Superintendent/Department Head show visible support/ involvement for safety (policy, communications, letters to employees, intervention, MBWA, etc.)? Yes [*}--No [] If: yes, provide several exxaammppllp. '/wfe /P , w B Are safety expectations defined? hit-t/e Page 3 Dow Confidential ed ^ Yes [] No DO A 046709 OONFTDFNTIAl 9/93 hrw/dsj APPENDIX A. SAFETY QUESTIONNAIRE A 'Are there consequences for non-compliance with safety rules and procedures? Yes G^o [] If yes, provide several examples. ssd UP/> s B 3. Do the safety committee and/or natural work teams have mission / statements? Yes H^No [] If yes, please attach. A 4. Do employees attend safety meetings on a regular basis? YesiDH^^NNool[] B Are meetings held at least monthly? B quarterly? Yes G No H-'"' YesfH^oQ A Is there documentation of the meeting showing content of the meeting, name of the instructor, and who attended? Yes No G 1B B Is there a mechanism to insure 100% participation or follow-up on sa-fe-ty---m--e--e^tings?Yes[^No[] Is documentation being kept for 3 years? Yes ir No [] A 5. Do safety objectives, goals, plans exist in written form for your plant/department? Yes No [] B Who developed theOGPs? SfcfFtSMffr B How are they measured? -- Up>A^S drJ How often is the status reviewed? As/ Mad/A, B ' 77 Mr&s, B Is your reward/recognition tied to the achievemenit of vyour 0O<GFs? Va- tV'KTrt. n B 6. Do you use SPIP (Safety Performance Improvement Process) or DSIS (Dow Safety Improvement System) to evaluate your safety program? Yes [if'-flo G If no, then describe what you are using. Page 4 Dow Confidential 9/93 hrw/dsj DO A 046?10 GONFTDFNTTAl APPENDIX A. SAFETY QUESTIONNAIRE C 7. Is there a written suggestion system in effect for safety suggestion^? (jSd&Jp&A Aufti/e h Yes [] C If yes, how are suggestions followed up? ^AcUxJp, //a^ <2^ Mahf /fee*. B What is the normal response time? $ B What percent of employees participate in your suggestion program? JbSfA______ ni- '93 4 us<ue- 44% - <yr/>'<?<-) B 8. Do you have a safety recognition system? Yes |*rNo (] B 9. Do you communicate safety information? YesfpNo^T If yes, what methods do you use? F&rt-cs M. 77S, Ad 7%. 1 77 1? A-2. EMPLOYEE PARTICIPATION Reference: "Dow Minimum Requirements", and OSHA 1910.119 (C) A 1. Do you have a process to assure that each individual clearly understands his/her responsibility for safety (new employee orientation, safety meetings, annual one-on-one performance reviews, etc.)? Yes0^No[] B 2. Are annual personal safety goals required for employees? Yes H^No [] A 3. Have employees been informed of their responsibility to report hazards and injuries to their immediate supervisor in a timely manper? Yes OKNo [] A 4. Do employees participate in plant/department safety programs or activities as outlined in List 2 on page 19 of this questionnaire? Yes BKNo [] Page 5 Dow Confidential 9/93 hrw/dsj 00 A 046211 OONFTDFNTIAl APPENDIX A. SAFETY QUESTIONNAIRE A. Are employees consulted with on conducting and developing process hazard analyzes such as outlined in List 1 page 19 of this questionnaire? 2 Sr % Y 11 B. Are employees consulted with on the development of other PSM Elements as outlined in List 3 on page 20 of this questionnaire? Yesfl^oH A-3. CONTRACTOR SAFETY REFERENCE: "Dow Guidelines for a Contractor Safety and Loss Prevention Program" and OSHA 1910.119(H) A 1. Are contractors given plant specific safety orientation covering known potential for fire, explosion, or toxic release hazards? Yes H^No [] B 2. Do contractor supervisors attend and conduct contractor safety , investigations? Yes a NoO B Does a Dow representative attend also? Yes [fUo [] B Are contractor incidents documented and tracked to completion? Yes sH5o[] A 3. Is contractor safety performance audited during jobs in your plant? Yes 0'/No [J B If yes, how is it audited?, _/ fin f&rc> c A 4. Are pre-job safety meetings held prior to on-site contractor ^ activity? Yes ft^No [] Page 6 Dow Confidential DO A 04671? CONFTDFNTTAl 9/93 hrw/dsj APPENDIX A. SAFETY QUESTIONNAIRE B 5. Do "service" contractors (i.e., computer, telephone, copier, air conditioning, etc.) receive safety training'' / Yes [] No [if *7sO^eWty-^Si^ibc^l,rri^on*an3^roc^sf/^fe^rges stiar^wfth lafAfec' ted A 6. contractors? Yes H^5o [J 7. Are contract employees informed of the plant/department , emergency plan? Yes [tjyNo [J A 8. Do you assure that contract maintenance people are adequately trained? Yes W'-No (] A 9. Are contract employees provided access to plant process hazard analysis on request? uYes A 10. When selecting contractors do you obtain and evaluate Yes information regarding that contractors safety performance and programs? (site). aCjs [] A 11. Do you maintain a contractor injury/illness log related Yes [] No to work covered by the PSM standard? tAoA ( #/oc_ U A-4. ACCIDENT/INCIDENT INVESTIGATION AND REPORTING REFERENCES: "Dow Guidelines for Accident Investigation" and "Dow Guidelines for S/LP/S Reporting", Division Safety Standard and OSHA 1910.119 (M) Accidents and incidents involving or having significant potential for causing personal injury, property damage or loss, business interruption and all crimes or fraud against the Company shall be promptly investigated. Each incident shall be thoroughly analyzed and a corrective action plan implemented. Appropriate communications shall be made to Management and to all involved parties. Page 7 Dow Confidential DO A 046013 CONFTDFNTTAl. 9/93 hrw/dsj APPENDIX A. SAFETY QUESTIONNAIRE Type Incident DAWCs RWCs RMTCs Total OSHA record ables OSHA Incident Rate Total Injuries (first aid included) Near-Misses - PSA Others (Define) Spills & Leaks Process Safety Incidents Env. Incidents Motor Vehicle 199__ Dow Contractor | 199__ Dow Contractor 199__YTD Dow Contractor 1 i i | \ j j I jt||j i A 1. Do you have a notification procedure for accidents or incidents within your facility? Yes n No [] A 2. Do you have a process for investigating accidents/incidents? Yes 0"No [] B Who participates? ttlnJ S-ZO!T A Are contractor employees included in the investigation team if the incident involved the work of the contractor? Yes fT^o[] Page 8 Dow Confidential DO A coDF T A 9/93 hrw/dsj APPENDIX A. SAFETY QUESTIONNAIRE B Does yoi -------- ' ' ' -------------- ice link analysis0 A *Are all incident investigations initiated within 48 hours following the incident? YYeessHffi'SNo [] A 3. Is there a system in place to assure completion of correct* within the specified recommended time? B *What is the percent completion of corrective actions by the commit date? % A 4. Are incident findings and corrective actions communicated to affected workers via an incident investigation report? Yes [f [] A Are communications documented? Yes 0^No [] B 5. Do you encourage the reporting of near-miss type incidents? Yes 0<tfo [] A-5. AUDITS REFERENCE: "Dow Guidelines for Safety, Loss Prevention and Security Audits", "North American Consolidated Audit Process" and OSHA 1910.119 (O) C 1. Are internal audits or inspections conducted (sight glasses, expansion joints, housekeeping, guarding, mock OSHA, emergency signals, eye showers, etc.) ? B If yes, who conducts audits? OrJtZ _ / S ^ Page 9 Dow Confidential DO A 046?;K CONFTDFNTIAI 9/93 hrw/dsj APPENDIX A. SAFETY QUESTIONNAIRE A 2. Do you have a process in place to assure compliance with Safety Standards and Minimum Requirements (TX - SR #14, LA - ,C9, MI - S-005)? , Yes [] If ves, please describe, ^66/^0, (L~ *9 A Are there any exceptions/variances? B If yes, please descirbe. Yes H^No [1 A 3. Has your plant had an audit for compliance with Process Safety Management (PSM) Standards in the last 3 years? (Consolidated^ Audit) Yes DKwot] Date of last Consolidated Audit: A 4. Are audit findings documented? A Are corrective actions accomplished? Yes (TNo [] Yes [rtfo [] A Are corrective actions documented? A Are corrective actions communicated? Yes [^Ho U Yes [ifo [] B 5. Is management informed of appropriate audit findings? Yes [] Do programs exists for inspecting the following: B The use of quick opening valves on "end of the line service"? Yes [] No B Open ended lines capped and plugged? Yes [] No tf-"'' B Cross connections between utility lines (i.e., N2 to air)? Yes [] No B Cross connections between process and service or utility lines (i.e., service water and caustic)? a Yes [] No B-~-- Pag 10 (J Dow Confidential 9/93hrw/dsj DO A 04A71A OONPTDFNTT Al APPENDIX A. SAFETY QUESTIONNAIRE B Backflow preventers tested and maintained? Field hazard identification? Yes [] No Yes [4-No [J A-6, SAFE WORK PRACTICES Safe Work Permits REFERENCE: "US. Area Standard #4" A 1. Are safe work permits used for all jobs in the process area? Yes ^No [] B If no, please explain. CjJ A. XV / mf r Is. A 2. Are on-site inspections done for each permit? B If no, please explain. : Yes B^Nof] A 3. Is training provided for the use of safe work permits? Yes [1 B 4. Do you monitor safe work permits for accuracy and completeness?^ Yes [f'No [1 A 5. Are annual performance audits conducted? B Ho% are deviations handled?. Pjh -ZT" fp(LM ou+JU Yes [J No [] / AsP/ 7*~ ' Page 11 Dow Confidential 00 A 046717 OONFTDFNTTAl 9/93 hrw/dsi APPENDIX A. SAFETY QUESTIONNAIRE Hot Work Permits REFERENCE: "U.S. Area Standard #4", OSHA 1910.119 (K) and OSHA 1910.252(A) A 1. Do you have a plant procedure for hot work? _________B Who can perform hot work in the plant? (2?jja /1 Yes [jKNo [] 1 _0 AJr~. A 2. Are hot work permits issued for all hot work operations in or neartbe process? Yes H A 3. Is authorization of hot work preceeded by site inspection and designation of appropriate precautions? Yes H'rlo 11 B Who can authorize hot work? B What training is necessary? 0, A 4. Are areas requiring a hot work permit identified? Yes [`Tfio [] A Has management established areas and procedures for safe welding and cutting based on fire potential? .. . Yes0^No[] (Ui/j B 5. Are employees trained to identify sources of ignition? Yes [^No [] B 6. Do you require a fire watch on all hot work jobs? Yes [] No A Have fire watch personnel completed fire extinguisher training? Yes fiTNo [] B 7. Do you have a procedure for hot work if the fire protection system is down? y B 8. Do you have procedures and training for powder activate*! devices (Hilti guns, etc.)? Yes [] No Page 12 Dow Confidential DO A 046718 CONFIDENT! A1 9/93 hrw/dsj APPENDIX A. SAFETY QUESTIONNAIRE B 9. Are permits retained until completion of hot work operations? Yes TNo [J B 10. Are permits audited on a regular basis? Yes Line and Equipment Opening B 1. Have you categorized your line openings and addressed the minimum protective equipment for each? Yes [^No [] B 2. Are line opening tie points initialed by operations and maintenanpe'T Yes ff No [] B 3. For routine line openings, do written procedures exist in lieu of writing permits. Yes [] No f B 4. Is training provided on line and equipment opening? Yes erf^h Is training documented? ^ k ,, Yes n No [1 Confined Space Entry REFERENCE: "U.S. Area "Standard #5" and 29CFR 1910.146 A 1. Do you have a plant procedure for confined space entry? Yes 0"No (] B 2. Who can authorize a confined entry permit? 40 A -What training is required to authorize a permit? 7* fa F ti fa, A Do you have documentation of training? Yes tp-Nol] A 3. Is basic and plant training given to employees who use the , explosimeter/oxygen analyzer? Yes tJ^Ko [] Page 13 Dow Confidential DO A 046019 OONFTDFNTTAI 9/93 hrw/dsj APPENDIX A. SAFETY QUESTIONNAIRE A Do confined space rescue procedures exist iunwritten form for designated confined spaces?* Yes [] No B Are employees trained in rescue techniques? Yes [] No A 5. Are there any variances to the confined space standard? Yes ['f'No [] If yes, please describe. ,v t . A 6. Is training provided for safety observers? A 7. Are annual performance audits conducted? B *How are deviations handled? Yes rfiS [] Yes [] No 0-'"''' A 8. Are permits retained one year after completion of job? Yes GK^o [] A 9. Are permits posted ai entrances are they made available Yes Hr^oi) to entrants? fi-Tf. &v Lockout and Tagout Procedures REFERENCE: "U.S. Area Standard #3" and 29CFR 1910.147 C 1. Are there any areas where the concept of exclusive control is used? Yes [] NofT B If yes, please describe them. A 2. Are plant employees trained and is the training documented? Yes [rtfo [] A Is the training documented? Yes [f^o [] 00 A 046770 OONFTDFNTTAl. Page 14 Dow Confidential 9/93 hrw/dsj APPENDIX A. SAFETY QUESTIONNAIRE B 3. W o is responsible for locking and tagging equipment? f____ ____________________ 'fed^S' A 4. Are annual performance audits conducted? B *How are deviations handled? Yes[] No [t"- A 5. Are there any variances to this standard? If yes, what steps were taken? Yes 0 NoH B 6. Is there a central location for communication of lockout/tagout? Yes tK No [] B 7. Have there been any incidents due to improper lockout/tagout? Yes [} , B If yes, please describe. > t\Apfigj)gp- \fi^/i/g(gJbUJ A 8. Do you have lockout/tagout procedures for all major pieces of equipment? Yes [^No [] A *Are they kept up to date? Yes H'-'No [] Page 15 Dow Confidential 00 A 04b??! CONFTDFNTTAl 9/93 hrw/dsj APPENDIX A. SAFETY QUESTIONNAIRE Guarding and Interlocking REFERENCE: Dow "Minimum Requirements" A f, l.Dp you have a program inplace to assure that all guairds are replaced befltore ec Zr fio Q B 2. Do interlocks play an imporrtant role in proct--ecting employees? . Yes [] No Fall Protection REFERENCE: U.S. Area Standard #6 A 1. Have employees been trained in fall prevention equipment use? Yes B"Non A 2. Have you identified areas where fall prevention is necessary and required? Yes [iJ^No [] A 3. Are there any variances to this Standard. If yes, please describe. HI Yes [] NoH A 4. Do you have a policy regarding roof access? gs up HeF- A 5. Are annualperformance audits conducted? B How are deviations handled? AvVt1 7 Yes [] No Yes [] No A-7. EMERGENCY PLANNING AND MEANS OF EGRESS REFERENCE: "Dow Guidelines for Emergency Planning", OSHA 1910.119 (N) A 1. Do you have a plant/department emergency plan? Yes tfkNcTn B -Does the plan include in-place sheltering? Yes KK$oH Page 16 Dow Confidential 9/93 hrw/dsj 00 A 04h97? OONFTDFNTTAl APPENDIX A. SAFETY QUESTIONNAIRE A 2. Are plant/department emergency plan drills conducted? B Have local emergency crews participated in drills? (See page on fire fighting in Loss Prevention section.) Yes [] No B Does each employee participate in at least one hypothetical emergency each year? Yes [\--No f) A *Are deficiencies corrected and communicated? Yes [] No A #Are changes made and communicated? Yes[] No A 3. Do new employees receive emergency plan information? Yes 0^No [] B 4. Is the emergency plan information communicated to visitors? Yes H^No [] B 5. Are there at least two ways out from all process areas? Yes 0--Ffo [] A 6. Do exit doors open in the direction of travel from more hazardous to less hazardous areas? Yes [f'No f] A 7. Are bump bars provided on exit doors for areas which could have^- more than 50 people? Yes H^No [] A-8. EMPLOYEE TRAINING Reference: "Dow USA. Operating Training Standard", OSHA 1910.119 (G) A 1. Is training provided for supervision involved with hazardous chemicals? Yes [iT No [J A 2. Is training provided for maintenance staff involved with hazardous chemicals? A 3. Is training provided for operating personnel involved with hazardous chemicals? Page 17 Dow Confidential 9/93 hrw/dsj DO A 046??3 DONFTDFNTTA! APPENDIX A. SAFETY QUESTIONNAIRE A Initial ? Yes A Refresher ? A Do you have a list of skills and knowledge required for each operating job? Yes f No[l Does training for operating personnel include: B -Use of check-off lists? B -Supervisory involvement? Yes H^'NoJJ Yes [tKtfoT] B -Experienced operator involvement? Yes [I B -Written testing? A -Up-to-date operating procedures? Yes ftyo [] Yes fl^Np [] A -Emergency procedures? A -Reactive chemicals training? Yes YesfK^oJ] A -Safety Standards? Yes H^fio [] A -Step for each operating phase? Yes [] Initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup following a turnaround or emergency shutdown A -Operating limits? Yes n-"No [] A Consequences of deviations and steps required to avoid 0TM8 deviations. A -Safety and health considerations? Yes [t"TJo [] A Properties and hazards of chemicals used and precautions for preventing exposure. Yes y-"No [] A -Safety systems and their functions? A A 4. B Is there Written certification in lieu of documentation for employee-"' involved in operation the process before 5/26/92? Yes [] Is refresher training given? If yes, how often? Yes PKtfST] Page 18 Dow Confidential 9/93 hrw/dsj no A OONFTDFNTTAl APPENDIX A. SAFETY QUESTIONNAIRE A Have the employees operating the process been consulted? Yes \^No [] A 5. Do you have a post-training evaluation for new employees? 7Yes [r^n A 6. Do temporary employees receive training? Yes No [] A 7. Are plant superintendents and technical employees new to a plant trained in details of the process? Yes fcp'No [] A 8. For PSM initial training include: Overview of process and operating procedures. Specific safety and health hazards. Emergency operations including shutdown. Safe work practices applicable to job task. ,, .. . A 9 Is there a record documenting traioning for PSM? Yes A-9. SAFE OPERATION OF MOTOR VEHICLES AND MOTORIZED HANDLING EQUIPMENT B 1. Is driver's training provided? Yes [] No [] A 2. Is powered industrial truck training conducted? Yes H'-'No [] B What; types of powered industrial trucks do you use? ____ 2___L, ... /JoB Where is fuel stored? A 3. Is documentation of training kept? phuA 4. Is Daily Inspection documentation maintaliined? A If yes is it current (daily)? YesfF^U Yes [] No Yes [] NofcJ^ Page 19 Dow Confidential 9/93 hrw/dsj DO A CONFTDFNTTAL APPENDIX A. SAFETY QUESTIONNAIRE A 5. Are employees trained in the plant rules and regulations? Yes ft'-'No [] B 6. Is truck tractor training provided? Yes [] B Do you have vehicles which require the operator to have a commercial driver's license? Yes [] No B If yes, please describe. ________ ___________________________________ B 7. Do you use manlifts, baskets or beam extenders on your fork truck? Yes [] No B Have you considered the reduced capacity of the unit when using these items? Yes [] No A-10. OFF-THE-JOB SAFETY B 1. Is there a formal program for reporting of off-the-job injuries to Dpw personnel? Yes H^No [] B 2. Are the results of Dow employee off-the-job injuries collected and^ published for learning value? Yes [^No [] B 3. Are off-the-job statistics and learning situations utilized in plant safety meetings or discussions? Yes KKNo [] B 4. Are off-the-job programs made available to employees' families s (e.g., defensive driving)? , Yes P^No [] B 5. Are safety communications mailed to employees' homes? Yes [] No B 6. Page 20 Are off-the-job, home activity topics, etc., covered in safety meetings? List some of your most successful "off-the-job" oriented safety meeting topics. Yes ffwo [] *2<,*^2, `7'A^ s CL+^ 5>--v , / Dow Confidential 9/93 hrw/dsi n A 046??6 ^onfidfnttai APPENDIX A. SAFETY QUESTIONNAIRE A ll. PROCESS SAFETY MANAGEMENT LISTS LIST 1 *Fire and Explosion Index and Risk Analysis *Chemical Exposure Index and Risk Analysis Reactive Chemical Reviews and Risk Analysis Project Reviews (Safety, Health, Environmental, and Loss Prevention Reviews) Technology Center Reviews Insurance Inspections (Dow and Outside) Consolidated Audit Questionnaire ---' Process Hazard Analysis Section Process Control Reviews (MOD Computer Reviews)-"" HAZO'OP Warehouse Risk Analysis Other Qualitative and Quantitative Risk Assessments LIST 2 Safety Committees Safety Advisory Group Safety Meetings ^ Consolidated Audti Participation "" Project Review "" Pre-Start up Audits Incident Investigation Hazard Identification/Safety Suggestion Emergency Drills Safe Work Procedures^ Management Of Change Process Hazard Analysis (Reactive Chemical Review, F&EI, CEI) Page 21 Dow Confidential 00 A 046?07 CONFTDFNT TAl, 9/93 hrw/dsj APPENDIX A. SAFETY QUESTIONNAIRE A-11. PROCESS SAFETY MANAGEMENT LISTS LIST 3 (c) Employee Participation' / (d) Process Safety Information ' (e) Process Hazard Analysis (0 Operating Procedures J (g) Training t , / (h) Contractors ^ / (i) Pre-start Safety Review (j) Mechanical Integrity / / J(k) Hot Work Pennit J (l) Management of Change (m) Incident Investigation7 / (n) Emergency Planning and Response J (o) Compliance Audit (P) Trade Secrets Page 22 Dow Confidential DO A OONF IDF NTT A1 9/93 hrw/dsj lad caustic i 1994 CONSOLIDATED AUDIT ACTION STEPS RECOMMENDATION OCCUPATIONAL HEALTH AUDIT Clean refrigerator.in control room and microwave in 1 warehouse 2 Label degreaser vat and post MSDS 3 Unlabeled 5 gallon conlainef at degreaser 4 Unlabeled containers in oil slorage Add lab and supply chemicals 1o hazard chemical list in 5 Hazcom Manual 6 Review Planl Hearing Prolection program 7 Cleaning supplies needed at respirator cleaning station 8 Conduct a respirator effectiveness inspection 9 Maintain hood certification in old lab RESPONSIBILITY Lemelte/Spears Boudreaux Boudreaux Boudreaux Douglas Douglas Boudreaux Sumly Boudreaux 10 Repair leak on sandblaslrng cabinet 11 Welding rod conlainer have no hazard warning label 12 Vacuum ledge under gasket storage area REACTIVE CHEMICAL AUDIT 13 Survey user plants HAZARDOUS MATERIALS TRANSPORTATION REVIEW (HMTR) 14 Loader wilhin 25* of the truck (In the Procedure) 15 No "Caution Signs" at TC rack entrance 16 Grease "Chick-san* swivel joints Boudreaux Boudreaux Boudreaux Harrison Butler Yelverlon Yelverlon 17 Spill containment at Tank Car Loading area Heins ELECTRICAL LOSS PREVENTION IB Electrical Emphasis group recommendations 19 MCC upgrade Evaluate upgrade of smoke detector syslem in MCC in 20 conlrol room CRITICAL INSTRUMENTS Heins Heins Goudreaux ECD ACD Action Taken Reason for Overdue? 2/24/94 2/24/94 2/24/94 3/1/94 4/30/94 4/30/94 | 2/23/94 2/24/94 2/24/94 4X/S4 4/4/94 5/16/94 4/10/94 6/1/94 6/1/94 4/1/94 6/1/94 3/15/95 6/1/94 6/1/94 5/1/94 7/1/94 S/30/94 4/5/94 Refrigerator and microwave were cleaned Done as stated. Done as stated. Done as stated. Done as stated. Program reviewed. Done as stated. Done as stated. Laboratory hood certification will be maintained only if the hood is put back in service. Done as stated. Done as stated. Done as stated. N/A N/A N/A More time needed than alotted to complete task. N/A More time needed than alotted to complete task. N/A N/A More time needed than alotted 1o complete task. Submitted as a routine maintenance work request. Due to maintenance backlog, action item not completed by ECD. N/A 6/1/94 6/1/94 Done as staled. N/A S/1/94 S/1/94 2/18/94 199S-96 5/31/94 6/13/94 2/18/94 6/1/94 Done as slaled. Done as slated. Done as slated. More time needed than alotted 1o complete task. Signs look longer to make than anticipated. N/A No action wilt be taken in the foreseeable future. No mandatory environmental requirements exist. WeVe been able to historicatly manage spill potential via operating discipline. This has no economic driver. N/A 1995-96 1995-96 12/31/94 11/27/96 11/27/96 9/22/94 Duplicate recommendation. See Electrical Reliability Audit section below. Duplicate recommendation. See Efectricat Reliability Audit section below. Smoke delectors nol added. This is a risk management tssue. N/A N/A N/A 94audaet.xls Pg* 1 no A n4^?29 CONFTnFNTTAI 1/21/97 10: to AM LAD CAUSTIC 1 1994 CONSOLIDATED AUDIT ACTION STEPS RECOMMENDATION 21 Review "Fail Safe* plant valves and ESVs STORAGE TANKS 22 Review tank overflow and vent lines PRESSURE VESSELS / RELIEF DEVICES 23 PSV design and documentation records FIRE PROTECTION Develop a plan for each group for a worst cast fire 24 scenario PROJECT PREVIEWS Pre-starl up action steps to be documented, closed and 25 verified ELECTRICAL RELIABILITY AUDIT 26 No 1 hour fire barrier in conlrol room MCC's RESPONStBILITY Pankow ECO 6/1/94 Butler 5/31/94 Pankow 12/31/94 Boudreaux 6/30/94 Boudreaux / Sumly On going Heins / Pankow 3/31/97 27 South MCC does not have 24" min. clearance Heins / Pankow 28 Doors do not have panic hardware and some open inward Pankow 29 No smoke detectors in switch gear Boudreaux 3/31/97 61/95 12/31/94 30 Square "0* switch gear does not meet design Heins/Pa nkow 31 SEOLD* needs updated and to be posted 32 Train block electrical personnel on cable tray requirements Boudreaux / Fair Boudreaux t Fair 1995-96 7/1/94 7/1/94 33 Add grounding conductors to cable trays 34 Have Meter & Relay verify ground grid on a recommended schedule SAFETY AUDIT 35 Develop plan to improve completion on USCR's 36 Inspect cross ties on utility lines 1o process lines Conduct audits of safe work permits, confined space entry 37 and LOfTO 38 Develop LO/TO procedures for major pieces of equipment Heins / Fair r Boudreaux / Fair Sumly Spears / lemelle Sumly Spears / Morgan 39 Upgrade documentation of drills and follow up action steps Boudreau* 9/1/94 9/1/94 3/31/94 3/31/94 7/31/94 12/31/94 4/31/94 ACD 9/1/95 4/29/94 Action Taken Reason for Overdue? Some of the automatic valves were reviewed and documented. We will update as needed per the More time needed than alotted to MOC process. complete task. Done as staled. N/A 3/16/95 Responsibility for updating relief design calculations/documentalion was assumed by plant engineering and completed as required by Division goals. Ownership of action Kern transferred to Engineering department. ECD no longer valid. 6/17/94 Developed/conducted drills on this scenario and pcformed one drill per shift on the worst case fire N/A scenario. On going Handled through Ihe MOC process - at a level 6 per Operating Discipline N/A 6/1/95 9/22/94 11/27/96 4/22/94 9/28/94 3/16/95 8/1/94 3/29/94 2/22/94 10/31/94 6/1/95 4/4/94 Re-evafuale options during next electrical reliability audH. Need 1o evaluate real risk. Did nol gel to problem solution and cost phase. Cannot physically alter the wall without great expense. Re-evaluate options via next electrical reliability audit. All doors adjusted to open outward. No panic hardware installed (not required). Duplicate recommendation. See Electrical Section under Loss Prevention for action taken (#20). Spent extra time trying 1o determine alternate plan. A new MCC could not be justified. N/A N/A Could not justify the cost of this replacement at N/A the time. Plartwill take responsibility for timing. Done as stated. N/A Done as stated. More time needed than alotted 1o complete task. Most of Ihe conductors installed. Impacf on electrical reliability/safety was minimal. Submitted as a routine maintenance work request. Due to maintenance backlog, action Hem not completed by ECO. Done as slated. Schedule in place and managed N/A by the Electrical function. Improvement plan in place. Done as slated. Implemented BBS audit program. Done for major unit operations/equipmenl. N/A N/A Waiting on division audit forms to be doveloped. N/A Drill documentation sheets developed N/A 94sudact.xls Page 2 DO A 046330 CONFTDENTTAl 1/21/97 10:t0AM LAD CAUSTIC 1 1994 CONSOLIDATED AUDIT ACTION STEPS RECOMMENDATION 40 Upgrade documentation of pre-startup reviews RESPONSIBILITY Sumly 41 Upgrade C-9 inspection deficiencies documentation 42 Modify safety meeling documentation sheet Sumly Boudreaux 43 Assure training documentation is property completed. Boudreaux FIELD INSPECTION #1 44 Place covers on panels behind the board. 45 Housekeeping problem in conference room 46 Repair emergency light by O.P office (has burned out bulb) 47 Pul tool rest al or above centerline on grinder 48 Ensure protective equip, is available for grinder 49 Communicate not to sharpen soft materials on grinder wheel 50 Post inslruction/warning signs on threading machine 51 Ensure protective equip, is available for drill press 52 Post instructionAvaming signs on horiz. band saw Communicate need for store harnesses and lanyards 53 property Evaluate flammable and oxygen storage area for 20* 54 separation 55 Replace bulb on exit sigh north door of maintenance shop 56 Review improper/proper use of manlift baskels FIELD INSPECTION #2 57 Install "Contad Loader Before Entering" signs on T/C rack Jefferson Boudreaux Boudreaux Boudreaux Boudreaux Boudreaux Boudreaux Boudreaux Boudreaux Boudreaux Boudreaux Boudreaux Boudreaux Yetverton 58 Paint Tank Car rack Butter 59 Replace broken glass on analyzer house 60 Audit all permanent ladders for gales and chains 61 Install gates and chains on permanent ladders as needed 62 Repair hole in steps near T-26 63 Remove ladder #15 from service 64 Communicate 1o the need to wear hearing prot. with impact wrenches 65 Ground the drums in oil slorage area Boudreaux Sumly Sumly Butter Boudreaux Boudreaux Boudreaux 94 *ud ftct.xls ECO 7/1/94 9/30/94 3/31/94 4/30/94 3/31/94 4/15/94 6/1/94 5/1/94 5/1/94 5/1/94 5/1/94 5/1/94 5/1/94 5/1/94 5/1/94 5/1/94 5/1/94 6/1/94 12/31/94 ACD 7/22/94 7/31/94 3/15/94 12/31/94 3/31/94 3/31/94 5/30/94 4/16/94 4/31/94 4/8/94 6/14/94 3/31/94 6/14&4 4/8/94 4/1/94 5/1/94 5/1/94 6/13/94 12/10/96 4/30/94 3/31/94 7/1/94 9/1/94 2/28/94 4/30/94 5/1/94 7/20/94 3/31/94 7/1/94 5/20/94 2/10/94 6/30/94 5/25/94 Pag* 3 Action Taken Using S&LP form and following MOC process. Done as slated. Done as slated. Done as slated. Reason for Overdue? More time needed lhan slotted to complete task. N/A N/A Waited unlil year-end to confirm atl training needing documentation was complete. Done as staled. Done as staled. Done as stated Done as stated. Done as staled. Done as stated. Signs installed. Done as stated. Signs installed. Communication made. N/A N/A N/A N/A N/A N/A Signs delivery took longer than anticipated. N/A Signs delivery took longer than anticipated. N/A Evaluation complete and acceptable. N/A Bulb replaced. Done as staled. N/A N/A Signs installed. Signs delivery took longer lhan anlici paled. Painlrng in 1996 deferred due 1o other significant, Painting in 1996 deferred due to other significant, unexpected maintenance unexpected maintenance costs. Will paint if maintenance % available in 1997. costs. Will paint if maintenance $ available in 1997. Done as slated. Done as stated. Submitted as a routine maintenance work request. Due 1o maintenance backlog, action item not completed by ECD. N/A Done as stated. N/A Done as stated. Done as slated. Done as slated. Done as slated. N/A N/A More time needed than a lotted to complete task. Submitted as a routine maintenance work request. Due 1o maintenance backlog, action Hem not completed by ECD. do a 04f03i OONFTDFNT T AL 1/21/97 10:10 AM RECOMMENDATION 66 Verify grounding of flammable storage cabinet by lab FIELD INSPECTION #2 67 Label load limits on beam and hoists m planl 68 Improve house keeping in lank car loading area LAD CAUSTIC 1 1994 CONSOLIDATED AUDIT ACTION STEPS RESPONSIBILITY Boudreaux ECD 5/1/94 ACD Action Taken 5/30/94 Done as staled. Harrison Spears/Lemelle 6/1/94 on-Qoinq 5/31/96 On going Done as staled. Reason for Overdue? Submitted as a routine maintenance work request. Due 1o maintenance backlog, action item not completed by ECO. N/A B4ud*ctrxls P-0* 4 no. no/vp- 1/21/97 10:10 AM DOW U.S. AREA CONSOLIDATED AUDIT PROGRAM CHLOR-ALKALIII PLANT .F Date of Report: January 26, 1995 Superintendent: Gretchen LeBlanc, Bldg. 3601 cc: Monty Heins, Bldg. 3601, LAD Roddey Peebles, Bldg. 1601, LAD Chris Messelt, Bldg. 3502W, LAD John Gallamore, B-101, Freeport, TX Buck Bailey, Bldg. 3301W, LAD Terry Leigh, Bldg. 1601, LAD Bill Cook, A-1230, Freeport, TX Enclosed are the recommendations from the various audits for your response. According to the Dow U.S. Area Consolidated Audit Program Guidelines and the OSHA Process Safety 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 completion date for each item. Your plan must be reviewed and approved by the area Major Manager by March 15, 1995. 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 and documented. Please send your approved implementation plans to Connie Kalencki, Bldg. 3502W by March 29, 1995. 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. Occupational Health Audit 2. Laboratory Audit 3. Electrical Reliability Audit 4. Reactive Chemical Audit 5. Security Audit 6. Hazardous Materials Transportation Audit 7. Loss Prevention/Fire Audit M = Must-Do DOW CONFIDENTIAL Page 1 QO A OAft?--5 C.ONFTDFNTT Al HR = Highly Recommended 8. Safety Audit Howard Wilkinson, Administrator LAD Consolidated Audit Program M = Must-Do DOW CONFIDENTIAL Page 2 DO A 046334 CONF I OF NT t Al HR = Highly Recommended 1994 CA II Consolidated Air " Summary Project No. RC-01 Action Item Description Develop chemical compatability chart RC-02 Review E-205/D-227 reactive chemical issues RC-03 Chlorine Expansion Pot Concerns RC-04 C-205 Booster Compressor Issues RC-05 Review Titanium Storage Policy RC-06 CFC Reactive Chemical Review Documentation RC-07 Review positive ID test for H2S04 RC-08 Review electricai heating tracing system on CI2 lines RC-09 Nitrogen Compound Analysis For Brine RC-10 Update Reactive Chemicals Documentation for Bicarb reaction RC-11 Investigate/address MDEA contamination potential in raw brine RC-12 Define Reactive Chemicals training levels RC-13 Taffy Pot NCI3 analysis RC-14 Liquid CI2 pump EBV protection RC-15 Add S02 liberation reactions to Reactive Chem Packet Person Responsible Heins, Monty Haun, Elaine Harrison, Jeff Harrison, Jeff Gravouilla, Rocky LeBlanc, Gretchen Harrison, Jeff Fair, Leonard Caldwell, Steve Harrison, Jeff Caldwell, Steve Landry, Donnie Haun, Elaine Mellieon, Harold Harrison, Jeff Page 1 Expected Comp. Date 8/31/96 3/31/96 4/1/95 12/31/95 04/15/96 5/31/95 12/15/94 6/15/95 05/31/95 12/20/94 05/31/95 8/1/96 05/31/95 12/31/95 12/15/95 Actual Comp. Date 8/14/96 3/6/96 3/27/95 12/31/94 9/30/95 10/31/94 12/9/94 10/8/95 11/18/94 1/5/95 3/1/96 12/31/95 7/29/96 12/20/95 1/9/95 Status complete complete complete complete complete complete complete complete complete complete complete complete complete complete complete OO A 046235 C ONFTDFNTTAL 1994 CAII Consolidated Au ' Summary Project No. RC-16 Action Item Description Policy for Extinguishing a C/E trap hydrogen fire RC-17 Review oil/insulation fire potential in GT area RC-18 Hydrogen Collection Area Issues RC-19 Reactive Chemicals test data for absorbents RC-20 Update plants approved leak repair sealants list RC-21 Review procedures for lubricants and cleaning agents RC-22 Review lubricants and cleaning agents for Power area RC-23 Review T-201 startup procedures RC-24 Address user plant backflow potential in caustic lines RC-25 Review maint procedures for caustic service cleaning agents RC-26 Centralized location for Reactive Chem Hazard Eval data MISC-01 Communicate results of consolidated audit r OH-01 Lab does not have ownership OH-02 Work procedures need evaluation in pump seal room OH-03 Corroded safety can in oil storage area Person Responsible Pittman, Ed Kolder, Roy Haun, Elaine Douglas, Charles Heins, Monty Campbell, Floyd Kolder, Roy Mellieon, Harold Harrison, Jeff Campbell, Floyd Heins, Monty Heins, Monty Lively, Bill Campbell, Floyd Douglas, Charles Page 2 Expected Comp. Date 7/15/96 5/15/96 12/31/96 1/31/95 05/31/95 05/31/95 3/31/96 2/28/95 12/31/94 ; 6/1/96 3/31/95 12/31/95 05/31/95 3/31/95 12/31/94 Actual Comp. Date 1/23/96 3/31/96 10/30/96 1/31/95 8/31/95 5/30/95 3/29/96 2/15/95 6/1/94 4/15/95 2/15/95 10/31/95 5/1/95 3/28/95 12/20/94 Status complete complete complete complete complete complete complete complete complete complete complete complete complete complete complete DO A CONFTDFNTTAL 1994 CAII Consolidated Au ' Summary Project No. OH-04 Action Item Description Need to examine structural integrity of oil storage drum rack OH-05 Cell rodding cabinet needs new door sign OH-06 Labeling deficiencies need to be addressed OH-07 Review hazard chemical list OH-08 Communicate results of exposure monitoring OH-09 Flammable containers not in flammable cabinet OH-10 MSDS sheets need updating OH-11 Grinder needs hearing protection sign OH-12 Breathing air mask in control room needs secondary plastic bag OH-13 Breathing air masks on shop floor OH-14 Respirator training documentation records need to be dated OH-15 Acid suits found in plant OH-16 Need to move heavy valves from top shelves OH-17 Need to replace static pressure operating parameter tape OH-18 Sandblasting cabinet needs repairs Person Responsible Heins, Monty Armstrong, Steve Douglas, Charles Douglas, Charles Douglas, Charles Spears, Tony Douglas, Charles Campbell, Floyd Douglas, Charles Douglas, Charles Douglas, Charles Lively, Bill Campbell, Floyd Douglas, Charles Campbell, Floyd Expected Comp. Date 12/31/94 01/31/95 12/31/94 06/30/95 06/30/95 05/31/95 06/30/95 3/31/95 06/30/95 12/31/94 12/31/94 06/15/95 05/31/95 06/30/95 09/30/95 Actual Comp. Date 12/15/94 Status complete 1/15/95 complete 12/20/94 complete 4/30/95 complete 8/31/95 complete 3/7/95 complete 3/15/96 complete 3/28/95 complete 6/30/95 complete 12/31/94 complete 12/20/94 complete 6/15/95 complete 5/1/95 complete 4/28/95 complete 4/19/95 complete D0 A 04A237 1994 CA II Consolidated Aik* Summary Project No. OH-19 Action Item Description Need to remove welding warning signs for cadmium OH-20 Update the asbestos inventory OH-21 Bags of ACM waste not property sealed OH-22 Needs to wash down dried asbestos on pulp trailer OH-23 Need to bag material in asbestos waste drum OH-24 Need to store asbestos gaskets in designated area OH-25 Need to update inventory to include sludge acidification process OH-26 Need to replace deteriorated radiation label LAB-01 Need mercury spill procedure LAB-02 Need to register chlorine sample cylinder LAB-03 Need housekeeping inspections ELEC-01 Motors not properly identified ELEC-02 Need to add smoke detectors ELEC-03 Equipment stored in required clearance zone ELEC-04 Identify and remove abandoned conduit Person Responsible Campbell, Floyd Douglas, Charles Douglas, Charles Armstrong, Steve Armstrong, Steve Douglas, Charles Douglas, Charles Douglas, Charles Caldwell, Steve Breaux, Kevin Myer, Edie Fair, Leonard Heins, Monty Fair, Leonard Heins, Monty Page 4 Expected Comp. Date 05/30/95 09/30/95 12/31/94 12/31/94 12/31/94 12/31/94 12/31/94 12/31/94 07/31/95 07/31/95 07/31/95 06/30/95 06/30/96 06/30/95 09/30/95 Actual Comp. Date 5/18/95 12/31/95 12/20/94 12/20/94 12/20/94 12/20/94 12/20/94 12/31/94 9/18/95 7/23/95 7/31/95 8/15/95 4/30/96 6/10/95 1/15/95 Status complete complete complete complete complete complete complete complete complete complete complete complete complete complete complete 00 A 04fc?38 OONFTDFNTTAL 1994 CA II Consolidated Aik" Summary Project No. ELEC-05 Action Item Description SEOLO's posted are not current ELEC-06 Conduits not grounded at cabie tray DFA-01 All lines and valves need to be identified DFA-02 Display caution signs 0 FA-03 Need to recommend safety procedure for sodium bisulfite DFA-04 Hydrogen transfer hoses be put into Pressure Vessel Program DFA-05 Emergency block valves be installed on hydrogen system D FA-06 Need to conduct hydrogen trailer inspection DFA-07 Need training for personnel off-loading hazardous materials DFA-08 When off-loading must be attended by qualified person LP-01 Need update of office area air intake procedure LP-02 Inspect and correct interior fire wall design LP-03 Wooden hot box not acceptable LP-04 Need to review electrical area classifications plot plan drawings LP-05 Need to review fire extinguisher distribution and type Person Responsible Fair, Leonard Fair, Leonard Spears, Tony Mellieon, Harold MelNeon, Harold Kolder, Roy Kolder, Roy Kolder, Roy Landry, Donnie Douglas, Charles Landry, Donnie Kolder, Roy Beck, Mike Fair, Leonard Landry, Donnie Expected Comp, Date 06/30/95 12/31/95 07/31/95 07/31/95 06/30/95 6/30/96 08/15/95 03/30/96 12/31/94 06/30/95 12/31/94 12/31/96 5/1/96 07/31/95 8/1/96 Actual Comp. Date 6/30/95 1/15/95 4/15/95 7/31/95 3/28/96 6/15/96 11/15/95 3/18/96 12/20/94 3/15/96 12/31/94 7/26/96 4/15/96 6/30/95 6/30/95 Status complete complete complete complete compiete complete complete complete complete complete complete complete complete compiete complete 00 A 04>?39 CONFIDENTIAL 1994 CA II Consolidated AuC Summary Project No LP-06 Action Item Description Review the critical instruments list LP-07 Determine ioop tests LP-08 Review the hydrogen area for EBV's LP-09 Vendor supplied vessels need to meet pressure vessel program LP-10 Need to include recommendations of MOC audit LP-11 Project reviews need to be documented LP-12 Inspect liquid chlorine line LP-13 Conduct risk assessment study SAF-01 Develop a department safety policy statement SAF-02 Conduct annual performance audits SAF-03 Identify deviations from standard SAF-04 Supervisors read the answers to questions with no opinions SAF-05 Have all employees set personal safety goals SAF-06 Review emergency drills SAF-07 AH employees need to participate in annual emergency drills Person Responsible Long. Keith Heins, Monty Kolder, Roy Kolder, Roy Landry, Donnie Heins, Monty Haun, Elaine Haun, Elaine LeBlanc, Gretchen Landry, Donnie Landry, Donnie Heins, Monty Heins, Monty Landry, Donnie Landry, Donnie Page 6 Expected Comp. Date 8/30/96 3/1/97 07/31/95 07/31/96 12/31/94 06/30/95 05/01/95 12/31/96 12/05/94 12/31/94 6/01/96 06/30/95 05/15/95 3/31/96 12/31/95 Actual Comp. Date 8/15/96 Status complete 12/1/96 complete 12/31/94 complete 3/31/96 complete 12/31/94 complete 12/31/94 complete 5/1/95 complete 9/19/96 complete 12/5/94 complete 12/31/94 complete 12/31/95 complete 12/31/94 complete 3/15/95 complete 2/15/96 complete 12/31/95 complete 00 A 046,040 l.nNFTDFNTTAI. 1994 CA II Consolidated Aik" Summary Project No. SAF-08 Action Item Description PHA's to be reviewed with employees SAF-09 Inform employees of rights under OSHA Star Program SAF-10 Drill results must be critiqued SAF-11 Update department emergency plan SAF-12 Keep up-to-date completion dates on incidents SAF-13 Keep up-to-date completion dates on safety suggestions SAF-14 Perform checks on C-9 checklist SAF-15 Document deficiencies during C-9 inspections SAF-16 Update indoctrination video SAF-17 Enter required info on training documentation SAF-18 Covers left off panefs SAF-19 Housekeeping needs in training room and printer room SAF-20 Improper use of pedestal grinder SAF-21 Pipe threading machine needs larger signs SAF-22 Drill press needs signs Person Responsible Heins, Monty Landry, Donnie Landry, Donnie Landry, Donnie Landry, Donnie Landry, Donnie Landry, Donnie Landry, Donnie Douglas, Charles Landry, Donnie Beck, Mike Landry, Donnie Campbell, Floyd Campbell, Floyd Campbell, Floyd Page 7 Expected Comp. Date 11/1/95 04/30/96 12/31/95 12/31/94 8/1/96 8/1/96 12/31/95 8/1/96 8/31/96 8/1/96 12/31/94 06/30/96 05/31/95 06/30/95 06/30/95 Actual Comp. Date 10/31/95 Status complete 4/30/96 complete 12/31/95 complete 12/31/94 complete 8/1/96 complete 8/1/96 complete 12/20/95 complete 11/4/96 complete 8/19/96 complete 8/1/96 complete 12/31/94 complete 4/30/96 complete 5/1/95 complete 3/28/95 complete 3/28/95 complete DO A 046241 r.ONFTDFNTTAl 1994 CAII Consolidated Au '4 Summary Project No. SAF-23 Action Item Description Need shield around welding and cutting area SAF-24 Eyewashes with no covers SAF-25 Old eyewashes not capable of using covers SAF-26 Safety showers dripping with algae underneath SAF-27 Lots of safety showers leaking SAF-28 Fire extinguisher stations not labeled. SAF-29 Utility stations not color coded SAF-30 Nitrogen station by P-301 has no backboard SAF-31 MP-306-B guard needs to be replaced SAF-32 Modified coupling guards on some pumps SAF-33 Heat tracing exposed next to D-320 & D-317 SAF-34 Lots of unplugged quick opening valves in area SAF-35 Fire extinguisher not properly hung SAF-36 Fire extinguisher station not numbered SAF-37 Need to discard wooden ladder Person Responsible Campbell, Floyd Spears, Tony Lively, Bill Moniotte, Bobby Kolder, Roy Spears, Tony Kolder, Roy Kolder, Roy Lemelie, Rick Lemelle, Rick Moniotte, Bobby Lively, Bill Spears, Tony Lively, Bill Spears, Tony Page 8 Expected Comp. Date 05/31/95 03/31/95 03/31/95 11/30/95 06/30/95 06/30/95 06/30/95 06/30/95 10/31/95 ' 08/31/96 11/30/95 05/31/95 06/30/95 06/30/95 05/31/95 Actual Comp. Date 3/28/95 Status complete 3/31/95 complete 3/31/95 complete 11/30/95 complete 12/31/94 complete 3/30/95 complete 12/30/94 complete 12/30/94 complete 10/10/95 complete 8/19/96 complete 11/30/95 * complete 5/30/95 complete 3/15/95 complete 11/1/95 complete 1/19/95 complete 00 A 04674; CONF rDFNTTAI 1994 CA II Consolidated Air" Summary Project No. SAF-38 Action Item Description Feet missing on step (adder SAF-39 Handrail needs to be replaced SAF-40 No cover in 110V outlet SAF-41 Drainage sumps filled with dirt SAF-42 Safety shower needs painting SAF-43 Grating and hand rails need painting SAF-44 Demo area needs housekeeping SAF-45 MCC-106 needs housekeeping attention. SAF-46 CTW basin drain line corroded through SAF-47 Low level piping with head injury hazard SAF-48 Trolley at cooling tower in bad shape SAF-49 No handrails to platform SAF-50 P-350 D&C with no MCC label SAF-51 Stepladder with feet missing SAF-52 Uneven water flow to eyewash nozzles Person Responsible Lively, Bill Lemelle, Rick Lemeile, Rick Kolder, Roy Lemelle, Rick Lemelle, Rick Tedeschi, Steve Lively, Bill Kolder, Roy Kolder, Roy Kolder, Roy Moniotte, Bobby Fair, Leonard Spears, Tony Lively, Bill Page 9 Expected Comp. Date 05/31/95 06/30/95 10/31/95 06/30/96 10/31/95 10/31/95 12/31/94 05/31/95 07/31/95 06/30/96 06/30/96 11/30/95 07/1/95 05/31/95 03/31/95 Actual Comp. Date 5/1/95 Status complete 6/30/95 complete 9/29/95 complete 6/15/96 complete 10/10/95 complete 10/10/95 complete 12/31/94 complete 5/1/95 complete 3/31/95 complete 6/15/96 complete 6/15/96 complete 10/15/95 complete 6/25/95 complete 1/19/95 complete 3/31/95 complete no a 04a;m.i CONFTDFNTTAi 1994 CA II Consolidated AiC Summary Project No. SAF-53 Action item Description No labe! for circuit for P-357-B SAF-54 No ladder gate going up to platform SAF-55 Cylinders tied with rope SAF-56 Un labeled containers found throughout plant SAF-57 Safety shower eyewash with one cap missing SAF-58 Maul with taped handle SAF-59 Homemade tools found SAF-60 Fiberglass buildings full of fittings and wire SAF-61 Fire extinguisher with expired sticker SAF-62 Fire extinguisher has expired sticker and broken bracket SAF-63 Millwright area discrepancies SAF-64 Welding area tool cabinet discrepancies SAF-65 Acetylene cart without T-handle SAF-66 D-803 area needs housekeeping SAF-67 Close handle broken off flammable storage cabinet Person Responsible Fair, Leonard Landry, Donnie Mellieon, Harold Lively, Bill Spears, Tony Campbell, Floyd Campbell, Floyd Fair, Leonard Lively, Bill Gravouilla, Rocky Campbell, Floyd Campbell, Floyd Campbell, Floyd Spears, Tony Lively, Bill Page 10 Expected Comp, Date 05/31/95 8/1/96 05/31/95 12/31/95 03/31/95 05/31/95 05/31/95 05/31/95 05/31/95 05/31/95 06/30/95 05/31/95 05/31/95 05/31/95 06/30/95 Actual Comp. Date 5/31/95 7/1/96 5/31/95 11/1/95 3/31/95 2/1/95 2/10/95 3/28/95 3/15/95 3/31/95 5/1/95 3/31/95 3/28/96 1/19/95 6/5/95 Status complete complete complete complete complete complete complete complete complete complete complete complete complete complete complete DO A 04ft?44 CONFIDENTIAL 1994 CA II Consolidated AuA Summary Project No. SAF-68 Action Item Description DAK pack full of water SAF-69 Flammable storage cabinet needs housekeeping SAF-70 Entry requirements not posted on shack SAF-71 Utility station not labeled SAF-72 Platform by taffy pot needs housekeeping SAF-73 Air station west of taffy pot not labeled SAF-74 Area around taffy pots needs housekeeping SAF-75 Air utility needs labeling SAF-76 T-205 deck needs housekeeping SAF-77 Escape pack has yellow reading SAF-78 New compressor foundation area needs housekeeping SAF-79 Utility station needs labeling SAF-80 Ftousekeeping needs inside D-228 dike area SAF-81 Housekeeping needs around TC-201 SAF-82 Red light on oxygen monitor is lit. Person Responsible Spears, Tony Lively, Bill Landry, Donnie Kolder, Roy Spears, Tony Kolder, Roy Spears, Tony Kolder, Roy Spears, Tony Lively, Bill Spears, Tony Kolder, Roy Spears, Tony Lively, Bill Neyland, Wayne Page 11 Expected Comp. Date 05/31/95 Actual Comp. Da 2/22/95 Status complete 06/30/95 5/15/95 complete 06/30/95 6/1/95 complete 06/30/95 12/30/94 complete 05/31/95 1/20/95 complete 03/29/96 3/28/96 complete 05/31/95 1/20/95 complete 03/29/96 3/28/96 complete 05/31/95 1/20/95 complete 05/31/95 5/15/95 complete 05/31/95 1/20/95 complete 06/30/95 12/31/94 complete 05/31/95 1/20/95 complete 05/31/95 5/15/95 complete 05/31/95 4/30/95 complete D0 ^ conf^>fNT1A 1994 CA II Consolidated AiC Summary Project No. SAF-83 Action Item Description Hazardous waste under D-208 SAF-84 Caps not on eyewashes SAF-85 Compressed gas cylinder secured with cloth straps SAF-86 Liquefaction area has tripping hazards SAF-87 Nitrogen station not labeled SAF-88 Fire extinguishers sitting on ground SAF-89 Area full of old eyewashes without covers SAF-90 Unlabefed containers in oil storage area SAF-91 Oil storage area needs housekeeping SAF-92 Check chain security on block valves SAF-93 Escape pack needs replacing SAF-94 Oxygen sensor not working inside IH #12 SAF-95 No meter light indication IH #10 & 11 SAF-96 Nitrogen station on E-526 deck not labeled SAF-97 E-526, D-511 area needs housekeeping Person Responsible Lively, Bil! Lively, Bill Neyland, Wayne Lively, Bill Kolder, Roy Lively, Bill Lively, Bill Spears, Tony Lively, Bill Spears, Tony Lively, Bill Neyland, Wayne Neyland, Wayne Kolder, Roy Lively, Bill Page 12 Expected Comp. Date 05/31/95 Actual Comp. Date 5/15/95 Status complete 03/31/95 3/31/95 complete 05/31/95 5/25/96 complete 05/31/95 5/15/95 complete 06/30/95 12/31/94 complete 05/31/95 5/15/95 complete 03/31/95 3/31/95 complete 05/31/95 1/25/95 complete 05/31/95 5/15/95 complete 05/31/95 2/3/95 complete 05/31/95 5/15/95 complete 05/31/95 4/30/95 complete 05/31/95 4/30/95 complete 03/29/96 3/28/96 complete 05/31/95 5/15/95 complete HO A 04fc7>4fc CONFIDENTIAL 1994 CA II Consolidated Au Summary Project No. SAF-98 Action Item Description Ground wire off skid SAF-99 Area around C02 skid needs housekeeping SAF-100 Quick opening valves not plugged SAF-101 Quick opening valves not plugged SAF-102 Label skirt for vessel entry required SAF-103 Need ladder gate on platform SAF-104 Fire extinguisher sitting on ground SAF-105 Utility stations not labeled SAF-106 Hoses strung out on deck walkway SAF-107 Algae causing slipping hazard SAF-108 Hoses on ground SAF-109 Algae at stairway entrance SAF-110 Hoses and rope on deck SAF-111 Gas cylinder tied with rope SAF-112 Escape packs condition not good Person Responsible Fair, Leonard Spears, Tony Lively, Bill Spears, Tony Landry, Donnie Mellieon, Harold Spears, Tony Kolder, Roy Lively, Bill Kolder, Roy Spears, Tony Lively, Bill Lively, Bill Neyland, Wayne Landry, Donnie Page 13 Expected Comp. Date 7/31/95 05/31/95 05/31/95 05/31/95 4/30/96 06/30/95 05/31/95 06/30/95 05/31/95 06/30/95 . 05/31/95 05/31/95 05/31/95 05/31/95 8/1/96 Actual Comp. Date 6/30/95 Status complete 3/15/95 complete 5/15/95 complete 1/26/95 complete 4/30/96 complete 5/1/95 complete 2/8/95 complete 12/30/94 complete 5/15/95 complete 3/9/95 complete 2/4/95 complete 5/15/95 complete 5/15/95 complete 4/30/95 complete 8/1/96 complete DO A 046?47 OONF TDFNTT AL 1994 CA II Consolidated Au ' Summary Project No. SAF-113 Action item Description Platform gates are not closing LP-09 Vendor supplied vessels need to meet pressure vessel program SAF-15 Update indoctrination video Person Responsible Landry, Donnie Mellieon, Harold Landry, Donnie Expected Comp. Date 07/31/95 07/31/95 8/31/96 Actual Comp. Date 6/15/95 6/30/96 8/19/96 Status complete complete complete / Page !4 DO A 046048 OONFTDFNTTAi