Document YG24oYwdRj3NaBOzvDE0rDpKK

Louisiana Division ConsolidatedAudit LDSS PREVENTION LOSS PREVENTION PLANT:__________ BUILDING:2J21 REVIEW DATE & TIME: Chlorine I 3i, 1991____________8=00 . LOSS PREVENTION TEAM: SUPERINTENDENT: _ Joe Muller LOSS PREVENTION: Buck Bailev_____________________ SAFETY ENGINEER: Barry Guillory____________________________ TECHNOLOGY CENTER: chior-Aikaii__________________________ DEPARTMENT PERSONNEL:___________________________ SECTION MANAGER: ------------------------MAJOR MANAGER:___ W. T. Austin (To be completed by the Superintendent.) 3/7/91 DOW CONFIDENTIAL DO A 023028 CONFIDENTIAL Page 6 of 30 Louisiana Division Consolidated Audit i--n---r-'' ------------ -- )L LOSS PREVENTION A. ELECTRICAL SYSTEMS References: Minimum Requirements, National Electric Code, LPP 1. Is the electrical area classification plot plan up to date? (LPP 3.1) Yes [] No e] Plans: Hydrogen stacks north of Cell Area and T-99E should be classified. 2. For classified areas: Are electrical enclosures properly assembled, all doors closed, bolts in place and tight, conduit seals in place and intact? (National Electric Code) Yes [x] No [ ] 3. Are there any instances where the electrical installation is in conflict with the electrical classification plot plan? Please explain your plans to comply with the electrical code. No.______________________________________________________________________ 4. Does your plant have dual incoming feeders? Yes B No Q 5. What has been the plant experience during automatic electrical feeder transfers? T.arep motors connected to the faulted feeder would not restart. One chlorine train would be shutdown. 3/7/91 DOW CONFIDENTIAL D0 A 023029 CONFTDENTlAlL Page 7 of 30 Louisiana Division ConsolidatedAudit UffSPREYENDflN 6. Ar there any cable trays routed through flammable areas? Yes 2 NoQ Hydrogen Collection Area. 7. Do you have fire protection on any of your cable trays? Yes Q No 0 8. Considering possible unit fire exposures, are cable wall penetrations appropriately sealed with approved fire stops? (Urethane is nil an approved fire stop.) Yes 2 No Q If not, plans:! Dow Corning Fire Stop Product is used. 9. Are grounds in place and tests up to date? Yes 0 No Q If not, plans:_______________________________________ Tested by Dashell Corp. Report is attached. 10. Has your plant participated in the Division electrical audit within the past four (4) years? Yes 0 No Q In-progress now. PLEASE CONTACT CHARLIE PETERS TO BE SCHEDULED. 3/7/91 DOW CONFIDENTIAL A 023030 cDo^^ Page 8 of 30 Louisiana Division Consolidated Audit LOSS HHfcVfcN IIUN B. FIRE PROTECTION Reference: Minimum Requirements 11. Are your extinguishers up to date and in good condition? Yes B No 0 12. Are they properly located (i.e. offices, MCC, switchgear rooms)? Yes B NoO 13. Are the size and type of extinguishers appropriate to the anticipated fire--for example, a "C" rated extinguisher where electrical fires could be expected? Yes B No Q 14. Do office areas, MCC's, switchgear rooms, computer rooms, and unoccupied buildings have smoke detectors alarming in a 24-hr/day occupied area? (LPP 9.4 and 9.5) List Unprotected Areas: Office building, warehouse & shops. 15. How often are smoke detectors checked? (LPP 10.13) Annually Who performs these checks? Fire Department If you have these records, show example. 16. How is your structural steel protected from a spill fire? (LPP 10.10). Fire protection is not required. 17. Is fire proofing well maintained? (LPP 10.10) YesQ No Q NA0 3/7/91 DOW CONFIDENTIAL DO A 023031 CONFIDENTIAL Page 9 of 30 Louisiana Division Consolidated Audit LtfsarHsvsttiiua 18. What is your fire proofing system and would you recommend it? N/A____________ 19. Is there an inspection program? n/a Yes Q No Q 20. Are gas AND spill detectors adequately maintained (LPP 9.9.6) and tested monthly? (LPP 10.13) Yes 0 No 0 NAg 21. Would you recommend your gas detector system to others? YesQ No 0 NAQ If so, what brand are you using and what are you trying to detect? 22. Does the gas detector system trip area sprinkler systems? n/a Yes Q No Q What would be required to implement this? 23. Do you maintain foam within your area to fight fires? YesQ Nofl List process areas! Foam is maintained by Fire Department to cover liquid chlorine spills. 24. Do you have adequate fire monitors and fixed sprinkler systems to protect all flammable areas? Yes, two fire monitors in Hydrogen Collection Area and Sprinkler Systems for Dry Compressors. DO A 023032 CONFIDENTIAL 3/7/91 DOW CONFIDENTIAL Page 10 of 30 Louisiana Division Consolidated-Audit LUsarriEYtmiiat 25. Do you have a plant program to routinely exercise fire monitors? Yesg No D Monthly by Operations and semi-annually by Fire Department. 26. Have your employees participated in fire extinguisher training? Yes g No 0 When? Entire Plant in 1982. In the process of re-training now. 3/7/91 DOW CONFIDENTIAL DO A 023033 CONFIDENTIAL Page 11 of 30 DllUGE I SPRINKLER SYSItns References: Minimum Requirements Engineering Spec 47-102 S V S I I NS Adequate access to valves during an emergency {iMStt I__ L _L yes YES I YES Explosion or traffic exposure to valve Explosion or traffic exposure to piping Fire Department tag In place Is the valve Insulated per Engineering Spec 41-1027. Is the system adequately drained of water? Is the pilot system adequately drained of condensate? Is remote dump switch labeled? Date of most recent 2" drain test Static pressure in recent drain test (psIg) Flowing pressure in recent drain test (pstgl Design flow |gpm) 32 NOZZLES @ 28 GPM Design pressure at deluge valve Inlet (psig) Date of last flow test Were there plugged heads/corrected Are any pilot heads painted Is there any missing or damaged pipe Are chemicals In the area lighter than water NO I NO NO I NO yes YES I YES yes NO I NO yes YES I N/A yes N/A I N/A yes I YES I N/A l/ID/SS I N/A 1 N/A 92 N/A I NO 90 N/A I NO 2123 896 I NO II In/a Ino 10/12/86 I7/90 Ino yes/yes |nO / |NO / INO NO no INO fES (ES Use another page if you have tan six systems. C-52/62 Sprinklers Deluge Guns DO A 023034 CONFIDENTIAL uI i I Louisiana Division Consolidated Audit LOSS PREVENTION C. FIRED EQUIPMENT IF YOU DO NOT HAVE FIRED EQUIPMENT, CHECK BOX AND LEAVE THE REST OF SECTION C BLANK. NA fc] References: Minimum Requirements, LPP 13 23. Has your unit had any Burner Management System (BMS) safety incidents in the last three (3) years? YesQ NoO Be prepared to discuss the incidents and corrective actions taken at the time of the audit. 24. Is the separation of fired equipment from the process in compliance with LPP 2.2? Yes Q No Q If not, what protective features are used to address less than recommended distances? 25. Does your fired equipment adhere to LPP 13? Yes Q No 0 If not, be prepared to discuss exceptions at the time of the audit. 26. Provide a copy of your startup and relight procedures for your fired equipment. 27. List the conditions that will result in the auto shutdown of the fired unit. 3/7/91 DOW CONFIDENTIAL DO A 023035 CONFIDENTIAL Page 12 of 30 Louisiana Division Consolidated_Audit LOSS PREVENIICJN 28. List the type (THROX, TOX, boiler, fired heater, furnace, etc.) and number of each. 29. Have you had a burner management system audit? Yes Q No Q When? 3/7/91 DOW CONFIDENTIAL DO A 023036 CONFIDENTIAL Page 13 of 30 Louisiana Division Consolidated Audit LuaarncvB'iiiui'i D. CRITICAL INSTRUMENTS References: Minimum Requirements, LPP 15.5 30. Have your critical and important instruments been identified? Yes 3 NoO NAQ If ves. how manv are there? 99 31. Have test procedures been written? Yes 8 NoO NAQ Is your testing up to date? Yes fl NoQ NAQ Is testing documented? (IBM Critical Instrument System) Yes 0 No 0 NAQ 32. Do you test from the initiating device through the final control element? Yes a NoQ NAQ 33. Do you have a process control computer? Yes a NoO NAQ What kind do you have? Honevweil tdc 2000. Dow Mod5 What would happen if you lost power to your computer? Both systems have battery backup.________________________________ 34. What controls do you have in place to prevent bypassing critical instruments? Mod5 System alarms when Critical Instrument is bypassed. Operating disciline_is__used__on_other_^ontro^_s^tems^_^^_^_____i(ii>i(____i___i-- 35. Do all automatic valves fail safe? Yes No Q 36. Do you have documentation of how control systems are supposed to operate, including set point limits? IPT contains control descriptions for most Y6S Q No [] equipment. 37. Have you had an in-depth review of the English language program within the past two (2) years? Yes Q No All Mod5 English language is reviewed at installation. 38. Have you had an in-depth computer hardware review within the past two (2) years? Yes Q No g 3/7/91 DOW CONFIDENTIAL DO A 023037 CONFIDENTIAL Page 14 of 30 Louisiana Division Consolidated Audit LJJSS M-ICVfcN IIUN E. EMERGENCY BLOCK VALVES 39. Are all incoming and outgoing headers handling flammable or toxic materials fitted with remotely operated EBV's at the battery limits? Yes No g NA Q List the exceptions: Chlorine User Lines and HvHrngpn Line to Power I have no EBV's. 40. Are all vessels with greater than 5000 gallons of liquified flammable gasses or the equivalent amount of vapor fitted with remotely operated EBV's? Yes Q No NA g List the exceptions: 41. Are vessels with greater than 20,000 gallons of liquid at or above its flashpoint fitted with remotely operated EBV's? YesQ NoQ NAg List the exceptions: 42. Are there remotely operated EBV's on the lines to and from loading and unloading stations when hazardous materials are being handled? Yes Q No 0 NA g List the exceptions: 3/7/91 DOW CONFIDENTIAL D0 A 023038 CONFIDENTIAL Page 15 of 30 Louisiana Division Consolidated Audit Luaarncvaniui 43. Are all EBV's "fail safe" for all utility interruptions? Yes 0 No Q NAQ List the exceptions: ___________ 44. If the valve is in a fire exposure area, is it "fire safe"? Yes Q No a NAQ List the exceptions: Hydrogen Collection valves are not fire saf e. Are Gaskets "fire safe"? No- 45. Describe the preventive maintenance and testing program for the EBV's. All EBV's are tested monthly by Operations. All EBV's are tested semiannually by Instrument Group as part of Critical Instrument Program. 46. Do all critical unit operations handling flammable or toxic material have EBV'S? Yes 0 No Q 3/7/91 DOW CONFIDENTIAL do * 0?3M CO^1 Page 16 of 30 Louisiana Division Consolidated Audit LOSS,PREVENTION F. DRAINAGE Reference: LPP 2.4 47. Does sprinkler system operation cause flooding? Yes 0 NoQ If so, where? 48. Are all sewers trapped to prevent vapor backup? Yes Q No Q A/A What is needed? 49. Are tanks with liquid flashpoints less than 140 F diked or impounded? (LPP 7.6) Yes 0 No Q NA 0 In the event of a spill, would the liquid be impounded next to the tank? Yes D No 0 Is this risk acceptable? Yes 0 No Q N/A [x] 50. Are dike walls liquid-tight? (LPP 7.6) Are they tested? Yes B No 0 Yes G No 8 51. Is area drainage generally directed away from the process equipment? Yes 8 No D If no, indicate flammable drainage areas. 52. Do any trenches/ditches back up in the plant during heavy rainfall? Yesg No Q Locations: East-West Trench near C-40 Compressors 53. Does your plant have secondary containment? Yes 8 NoQ If so, are there written procedures covering their operation, 3/7/91 DOW CONFIDENTIAL Page 17 of 30 DO A 023040 CONFIDENTIAL Louisiana Division Consolidated-Audit LOSS PREVENTION especially during emergencies? Yes Q No Q 54. What is your plan for disposing of rain water? Rain water is discharged from East/West Trench. This trench is environmentally monitored. Is it written? Yes 0 No Q Spill Prevention Control & Counter-measure Plan Attached. 55. Do you have a plan for handling spilled materials? Yes 0 No Q G. EMERGENCY PLAN References: Minimum Requirements 56. Are copies of your unit emergency plan available to all personnel? Yes Q No Q Available on process computer and bound hard copy. 57. Are copies up to date? Yes Q No Q Last update: 9/90 58. Who updates the plan? Production Simprvisnr Frequency:. Annually 59. Does the plan include: (If not, be prepared to discuss why) Emergency call list? Yes Q No 0 NA Q Computer Version only. Emergency equipment plot plan (such as SCBA, deluge, C02, fire monitors, hose cabinets, etc.) Yes Q No Q NA Q Emergency equipment operating procedures for above equipment? Yes Q No Q na [x] Procedure for switching to alternate for each utility? Yes fl No Q DO A 023041 CONFIDENTIAL 3/7/91 DOW CONFIDENTIAL Page 18 of 30 Louisiana Division Consolidated Audit LOSS PHfcVfcNI iun Procedure for total loss for each utility? Brine, Power, Air and River Water Yesfl No Q Crash shutdown procedure? (time required: ) Procedure for total loss of rectifier power Orderly shutdown procedure? (time required: ) Yes 0 No Q Procedures in case of neighbor plant problems? Shift Supervisor will direct evacuation if YeS^j No 0 NA 0 needed. Procedure for loss of raw materials? Yes Q No 0 NA Q Brine & Power Gas release procedure? Yes 0 No Q NA 0 60. Does the plan include: (If not, be prepared to discuss why) (continued) Spill procedure? Yes 0 No 0 NA Q Fire fighting plans for each type of fire? Yes 0 No 0 NAQ Hydrogen Fires are covered, but chlorine/iron, chlorine/titanium, and oil fires are not covered. Emergency communications plan? Yes'll Nar0yNA 0 Chain of command defined? Yes Q No 0 NA 0 61. Is there a documented, .emergency. p.laq, training & retraining program? 62. Is training up to date and documented for all employees? 63. How often are hypothetical drills conducted? Monthly 64. Do you meet with Emergency Services and discuss fire fighting plans and hazards for your plan periodically? When access routes will be blocked for an Yes 0 No 0 NA 0 extended period of time. 3/7/91 I DOW CONFIDENTIAL Page 19 of 30 DO A 023042 CONFIDENTIAL Louisiana Division Consolidated Audit LLKSS PHbVfcNTION 65. Are vital records protected from loss (such as PC data, MOD V programs, training programs, business information)? Computer backup. VeS 0 No [] 66. Do you have emergency drills involving neighboring plants? Annual drill is announced to allow neighboring plants to respond. Yes 0 No 0 67. Are contractors adequately trained in what to do in an emergency? Yes 0 No Q All contractors are safety indoctrinated. Chlorine and Caustic Safe Handling Training. H. STORAGE TANKS 68. Have all tanks been visually inspected within the last year? Yes 0 NoQ NA0 69. Are tanks in the pressure vessel program? NA Q Yes Q No Q 70. Are NDT tests up to date? Yes0 No Q NA Q 71. Are all storage vessels electrically grounded? Yes 0 No Q 72. Have grounds been checked within the past five years? See Question 9 documentation. Yes 0 No Q 73. Do tanks have a system to protect against overpressure and vacuum (e.g. pad system, PVRV)? Yes No Q NA Q PSV's 74. Do you have tanks that have pad/depad systems to maintain inert atmospheres or to maintain positive pressures? Yesfl No 0 If yes, do you prevent the pressure from the pad system from exceeding the design pressure rating of the tank? Yes 0 No 0 HOW? Nitrogen source is regulated below vessel design pressure. Tanks have_gressure indication and safety valves. _____ 3/7/91 DOW CONFIDENTIAL Page 20 of 30 DO A 023043 CONFIDENTIAL Louisiana Division Consolidated Audit I Ofifi PREVENTION 75. What type of material is used for inerting? carbon dioxide in cell catholyte compartment while off-line,nitrogen for "/ Hydrogen Systems and HC1 tank. 76. Are your storage tanks in the original service for which they were intended? Yes Q No Q Exceptions: T37, T45, T13 77. What is the recommended type storage tank for that service today? These tanks are adequate for their service. 78. Have your vessels been checked to see if their protective devices are adequate for the service (e.g. fill/empty rates, fire exposure, etc.)? At installation. Yes 8 No 0 New PSV survey to be completed in 1992. 79. Are your tanks protected with redundant level indicating devices to prevent spills? Yes Q No Q 80. Are automatic shut off devices operated from these devices? T45 Inlet EBV Yes0 Nog 81. For unstable chemicals, is temperature monitored and alarmed? Yes Q No Q NA 0 If not, what parameters of storage are monitored? List 82. Are your PRV's, PVRV's, ERVs, etc., positioned correctly on your tanks to ensure that should the tank be over-filled, the liquid can escape through the protective device without over-pressuring the tank from hydraulic head? Yes Q No D na [x] List exceptions: no prv's, pvrv's, erv's in plant. 3/7/91 DOW CONFIDENTIAL C(? A 023044 coNFroe-NriAL Page 21 of 30 Louisiana Division Consolidated Audit LuaarHEVtNIlUN 83. What preventive maintenance exists for tank protective systems (i.e., levels, temperature, pad/depads, PVRV's, ERV, and flame arrestors)? Critical Instrument maintenance and safety valve maintenance. 84. Are spill detectors utilized in tank farm areas? Yes Q No 0 Na Q I. BUILDING LOCATIONS & FIRE RISK References: Minimum Requirements, LPP 2.2 & 12.2 85. Do buildings and process structures meet the minimum separation distances as required by the F&EI? Two conflicts Yes 0 No Q 86. For high occupancy buildings in your plant (offices, control rooms, shops), what category building does your process dictate? rat-poorv A - for proximity to Hydrogen Collection. 87. Do your buildings meet their appropriate categories? YesQ NoO Exceptions: 3/7/91 DOW CONFIDENTIAL 230^5 DO O COHp Page 22 of 30 Louisiana Division Consolidated Audit PHfcVENTlQN 88. Are buildings of non-combustible construction? Yes U No Q Exceptions: . Internal construction is not non-combustible. 89. Do you have any control rooms inside a Division 2 (semi- hazardous) electrical area? Yes Q No B If so, describe the air supply system - how it is monitored, and emergency procedures regarding flammable and/or toxic releases. 90. List major fire divisions. Cell Area, Hydrogen Collection, Brine Treating, Chlorine Drying Trains, Purification, Liquefaction, Evaporators, Offices, 480V MCC/UPS 91. Are penetrations of fire wail protected? Yesf] No Q Dow Corning Fire Stop is used. 92. Are fire doors operated and fusible link systems tested for Closing? No Fire Doors in Block. Yes [] No B 3/7/91 DOW CONFIDENTIAL DO A 023046 CONFIDENTIAL Page 23 of 30 LOGS PflCVCNflON AUDIT QUESTIONS OPERATING DISCIPLINE References: Minimum Requirements 75. List the components of your Operating Discipline: Formal In-Plant Training Program (IPT) -17- 76. Who has primary responsibility for the plant's operating discipline? IPT is maintained by full-time O.S. level employee. 77. How is the written portion of the operating discipline program handled? IPT is a vax-based system with access from anywhere in the Division. 78. Is that material up-to-date? Yes EJ No [] 79. How complete Is the operating discipline? 15 areas complete out of 22. See attached. 80. How and by whom Is operating discipline used? ipt is used to train new Operations' employees and to update experienced employees. 81. Are your PlIDs up to date? Yes [] No M How do you keep them up to date? Yes [] No N The plant is in the process of updating all P&ID's. completed in 1992. Project to be DO A 023047 CONFIDENTIAL Louisiana Division Consolidated Audit LijaarHEVtNiiUTC WAREHOUSE STORAGE References: Minimum Requirement, LPP 12.4. 93. Are warehouse spaces protected with a fire protection system? Yes 0 No Q 94. List the type system for each area. Fire Extinguishers only.___________ 95. Are pallets stored within the warehouse? YesQ Nog 96. Are pallet stacks less than eight (8) feet in height? Yes 0 No Q 00 A 023048 confidential 91 DOW CONFIDENTIAL Page 24 of 30 Louisiana Division Consolidated Audit 97. Where does sprinkler and fire fighting water drain? Plant drain system 98. List types of fork trucks. Gasoline 99. Where is fuel storage for the fork truck located? Near front office in diked area. K. PRESSURE VESSELS/RELIEF OEVICES/GLASS DEVICES/ EXPANSION JOINTS References: Minimum Requirements, LPP 6.5, 6.9, 100. Are all pressure vessels registered? If no, how many are not? Yes 0 No Q 101. Are there design calculations on all pressure vessels? Yes D No @ 102. If the two items above are lacking, do you have a formal plan and schedule to accomplish? Yes 0 No Q Timing? 1996 103. Do file folder(s) on each pressure vessel have the registration form, calculations, inspection and status change reports, spec sheets, record prints, U-1 forms, mill tests, and visual inspections? Yes Q NoB List exceptions: Calculations and spec sheets are not available for all vessels. 3/7/91 DOW CONFIDENTIAL Do A 023049 confidential Page 25 of 30 Louisiana Division Consolidated Audit LU^PHtVtMIIUN Status of Plant Pressure Relief Valve Program 104. Has responsibility for execution of PSV program been specifically assigned? Yes Q No 0 105. Are all PSV's registered? Yesg No Q 106. Are design calculations on all PSV's done? Yes Q No 0 If no, number incomplete?_ Schedule for completion? Survey complete in 1992. 107. Is there a file folder for each PSV with registration form, design calculations, specifications, and piping isometric sketch? Registration form only. YeS Q No Q 108. Provide the current status printout on pressure vessels and Safety valves. See attached. Glass Devices 109. Have all glass devices been registered? Yes Q No 0 Exceptions: See attached list. 110. Are glass devices adequately guarded? Yes 0 No Q 111. Are required inspections, maintenance, evaluation, and record keeping done? Yes 0 No Q Expansion Joints 112. Does the plant utilize expansion joints in potentially hazardous applications? Yesg NoQ P-47 suction - HC1 service do A 023050 CONFTDFNTIAL 3/7/91 DOW CONFIDENTIAL Page 26 of 30 Louisiana Division Consolidated Audit I t tVi KI-tPV&N I 113. Are all expansion joints registered? Yes 0 No g List exceptions: ^ __________________________ 114. Are required inspections, maintenance, evaluation, and record keeping done? Yes Q No Q 3/7/91 DOW CONFIDENTIAL D0 A 0?3051 CONFTDFNTTAL Page 27 of 30 Louisiana Division Consolidated Audit mSS PREVENTION L. CRITICAL EQUIPMENT 115. Have you identified your critical equipment? Yes Q No Q List: Attached. 116. Does the list include items such as large and/or unusual motors, transformers, foreign and/or domestic equipment requiring long deliveries? Yesg No Q 117. Do you have adequate spare parts to minimize downtime (business interruption)? Yes 0 No Q 118. Are spares/spare parts stored in a controlled environment? Yes 0 No Q Location: Warehouse 119. Are shafts rotated periodically? Frequently: Monthly Yes 0 No Q 120. Do you have adequate monitoring/protection devices for your identified critical equipment? Yes 0 No Q 121. Do you have an ongoing preventative maintenance program? Yes Q No Q 122. List types of high loss potential rotating equipment. Chlorine, Freon, Hydrogen Compressors/Liquid Chlorine Pumps, and Air Compressors. 123. Do you have vibration monitors? Yes g No Q If yes, what type? Bentley Nevada, IRD______________________ 3/7/91 DOW CONFIDENTIAL DO A 023052 CONFIDENTIAL Page 28 of 30 Louisiana Division Consolidated Audit UU&arHtVHMIlCJN 124. What is the plant practice to shut down on high vibration? Decision is based on shift supervisor judgement and advice from Maintenance Tech. 125. Do you have speed control? Yes g No Q If yeS, what type? P-260 steam turbines have self contained speed governer. 126. What is your control system on rotating equipment? TDC, Mod5, Pneumatic 127. Do you have redundant controls on rotating equipment? Redundant pressure control and surge control YeS Q No [] valves on C-100. C-52/62 discharge pressure. 128. What are your alarms and shutdowns on rotating equipment? Vibration alarm, temperature alarms and trips, oil pressure and temperature trip. Motor amps trip. 3/7/91 DO A 023053 CONFIDENTIAL DOW CONFIDENTIAL Page 29 of 30 Louisiana Division Consolidated Audit LOSS PREVENTION M. FLAMMABLE MIXTURES/COMBUSTIBLE DUSTS 129. Are flammable materials processed in open, ' structures? Ye tilated PartlyQ 130. Are flammable materials stored in your plant? Fuel only. Yes S NoQ 131. Are flammables loaded/unloaded in your plant? Yes Q NoQ Fuel only. 132. How do you prevent flammable mixtures in the vapor space of process tanks, storage tanks, rail cars, tank trucks, etc.? Tall gas system monitored for hydrogen/chlorine explosive mixture. Nitrogen purging in hydrogen equipment and HC1 tanks. 133. How do you prevent the events in the above question from happening, or know if they do happen? Inert purging and process analyzers. 134. Do you monitor system pressure and/or oxygen content in low positive pressure applications? Yes No Q Hydrogen Processing Train 135. Do you have a flare system in your unit? Yes Q No g NAQ If yes, how do you prevent backflashes in the system? , How do you maintain a non-flammable mixture within the flare header? How old is your flare tip?_______________________________ , Has it ever been inspected? Yes Q No Q 3/7/91 DOW CONFIDENTIAL Pane TM 30 D0 A 023054 CONFIDENTIAL Louisiana Division Consolidated Audi! LuaarricVeNUUM Is your flare tip on any kind of maintenance schedule? YesQ No Q Describe: ______________________________________ How do you insure that you have a flame?___________ 136. Has a study or program taken place to install protective or preventive devices? Yes Q No Q N/A W 137. Have reactive chemical tests been run on various dust mixtures? YesQ No Q n/a [x] 138. Does the plant have guidelines and programs addressing static electricity? YesQ No Q n/a [x] 139. Are regular checks made for electrical continuity in dust handling systems? YesQ No Q n/a [x] 140. Are there plant rules not allowing an accumulation of dust to build up on structural beams, surface of equipment, etc.? Yes 0 No Q n/a Ex] Describe: 141. Where dusts exist, have alternate methods of handling or isolation been considered? Yes Q No Q n/a [x] 3/7/91 DO A 023055 CONFIDENTIAL DOW CONFIDENTIAL Page 31 of 30 Louisiana Division Consolidated Audit I --"* - ------------ N. CONTROL OF PROCESS CHANGE/SAFETY & LOSS PREVENTION REVIEWS 142. Do you have a formal system in place to control Process Change? Yes H No [ ] If yes, please describe. Project Reviews. Management of Change Safety Standard implementation in progress. 143. How do you insure that the proper reviews are completed on any Process Change? Utilizing standard checklists and documenting results. 144. Does your department review projects for Safety & Loss Prevention concerns at each phase? Yes k] No [ ] Who iS involved? Manufacturing Representative, Plant Superintendent, S&LP depending on project size and scope. 145. Have you done a Hazard and Operability Study (HAZOP) on your process or process changes? Yes Q No 146. Do you have plans to do a HAZOP? Yes No Q 147. Are pre-start up audits done on all new projects? Provide examples if appropriate. Attached. Yes 0 NoQ 148. Do you have a way to be certain that the proper materials of construction are used in maintenance of new projects? Material Controller is our checkpoint. Yes Q NO fl 149. Do you have a list of proper gaskets for your plant? Plant Pipe Specifications Yes fl No Q 150. Do you have cast iron in process service? Yesfl No Q Hydrogen liquid ring compressors 151. Do you avoid the use of cast iron? Yes fl No Q 3/7/91 DOW CONFIDENTIAL Page 32 of 30 D0 A 023056 CONFIDENTIAL Louisiana Division Consolidated Audit LOSS PREVENTION C. Critical equipment availability. 0. Total replacement value of plant. 3/7/91 DOW CONFIDENTIAL oo A CqNFxd 05>30s? Page 34 of 30 Louisiana Division Consolidated Audit LOSS PREVENTION VI. APPENDIX A LOSS PREVENTION RESOURCE MATERIALS Minimum Requirements Minimum Requirements for S&LP June 1989 Guidelines Guidelines for Safety, Loss Prevention & Security Audits Guidelines for Emergency Planning Guidelines for a Motor Vehicle Accident Prevention Program Guidelines for Accident Investigation Fire & Explosion Index, 6th Edition Guidelines for Warehouse Rating Distribution Emergency Response System Guide Guidelines for Determining Dust Hazard Potential Guidelines for a Reactive Chemicals Program, 2nd Ed. Guidelines for Business Data & Process Control Computer Systems November 1989 September 1985 September 1989 November 1985 May 1987 March 1980 1985 October 1989 January 1987 March 1982 Loss Prevention Principles January 1989 Others Louisiana Division Reactive Chemicals Manual Louisiana Division Safety, & Loss Prevention Standards 3/7/91 DOW CONFIDENTIAL March 1990 Continuous DO A 023058 CONFIDFNTIAL Page 35 of 30