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(L ca 3 B si orci si aw33ofa @ofi)@l)B<glati<31 Hazardous Materials Transportation Review March 1991 Dow Confidential DO A 023850 CONFIDENTIAL Louisiana Division March 1991 Dow U.S.A The Dow Chemical Company PO Box 150 Plaaoemme Louisiana 70765-0150 To: Plant Superintendent/Department Head SUBJECT: HAZARDOUS MATERIALS TRANSPORTATION REVIEW (HMTR) The HMTR audit will be part of the Louisiana Division Consolidated Audit Process. The audit will be the responsibility of the Superintendent/Department Head. The purpose of this audit is to provide an in-depth review of our Louisiana Division hazardous materials transportation practices of materials which, if released, could possibly cause injury to the public. The audit will be reviewing the chemicals shipped or received, including the plant's waste materials with a Hazardous Materials Transportation Index (HMTI) of 2, 3, or 4. (Does not include pipeline transportation). You should begin your preparations by reviewing the attached program guidelines and developing or updating the HMT Indexes for your plants' various chemicals and potential loss of containment from worst case transportation scenario. You will need to complete and send a copy of the review package to the Audit Facilitator ten (10) calendar days prior to the audit. A HMTR Audit Team is required for a HMTI of 2, 3, or 4. A U.S. Area Loss Prevention Representative will be required for a HMTI of 3, or 4. A HMTI of 1 requires a review by the Superintendent and his Manager only. NOTE: Prompt response to the HMTI calculations is necessary. A 30 day pre-audit notification to the U.S. Area will be necessary for some materials. Contact Dean Smith at extension 8879 for U.S. Area Loss Prevention Representatives as audit team members (required for HMTI's of 3 or 4). Dean should also be contacted for a Functional Audit Team if the HMTI of materials is 2, 3, or 4. March 1991 Page Two The list of contacts below can be used as additional resources. Ind. Hygiene Purchasing Loss Prev. HMTI CEI F&EI Safety Gary Meier Randy Normand Buck Bailey Dean Smith Jim Gibson Maurice Oubre Don Jones 1809 8481 1539 8879 8163 8953 6097 Attached are the "Guidelines for a Hazardous Materials Transportation Review ", including the Audit Instructions which give the details about what is needed to prepare for the audit and how the audit will be conducted. If there are any questions concerning the audit, please contact me at extension 8879. Dean Smith HMTR Functional Team Leader Building 3302D Ext. 8879 GUIDELINES FOR A HAZARDOUS MATERIALS TRANSPORTATION REVIEW DO A 023853 CONFIDENTIAL CONTENTS Introduction What is a Hazardous Materials Transportation Review. Responsibilities Preparing For a Review What Products and Raw Materials Should BeReviewed? Worst Case Thinking Hazardous Materials Transportation Review Audit Preparation Instructions Hazardous Material Transportation Review Calculations Using Lotus 1, 2, 3 Hazardous Materials Transportation Review AuditAgenda Tables 1 . Skin Ranking Criteria for Hazardous Materials 2. C.E.I.-F.E.I. and Skin Ranking Grids 3. Typical Review Levels Appendix A. Relative Hazard Ranking B. Chemical Exposure Index (Tank Car Rupture of Ethylene Oxide) C. Fire & Explosion Index (Sample Form) D. Chemical Exposure Index (Tank Car Rupture of Liquid Chlorine) E. Chemical Exposure Index (Tank Car Rupture ofMethacrylonitrile -MAN) F. C.E.I. F.E.I. and Skin Ranking Grids (Sample Form) G. Swaps-Tolls-Trades H. Hazardous Materials Transportation Review Questionnaire (Not all Inclusive) 1 2 3 4 4 4 5 8 11 13 14 15 13 16 17 18 19 20 21 22 DO A 023854 CONFIDENTIAL INTRODUCTION This document is intended to aid in the set-up and execution of Hazardous Materials Transportation Review. Similar to Process Hazard Reviews currently conducted in Dow plants, the Hazardous Materials Transportation Review will address another area of safety - hazardous materials transportation practices. ,0 A 023855 CONFIDENTIAL 1- - WHAT IS A HAZARDOUS MATERIALS TRANSPORTATION REVIEW? The objective of a Hazardous Materials Transportation Review Is to anticipate and prevent, through a complete evaluation of transportation modes and various chemical properties. Incidents which may cause loss of containment of a chemical while being transported. While each review will vary with the nature of the product and the transportation requirements, a general outline Is as follows: * Review loading and securement procedures. Oo not limit to Dow Internal procedures, but Include Dow carriers, customer procedures used to secure "empties" returned to Oow, and procedures used by third party personnel Involved with swapping, tolling, or repacking operations performed for Dow. * Examine In-route procedures. Carefully review regulatory requirements, routing practices, emergency procedures, and other in-route procedures deemed Important. * Consider materials of construction and appropriateness of design used *"r each distribution container or package. * Review unloading procedures, Including product stewardship literature given to customers by Dow. 0236St 2- - C0^ RESPONSIBILITIES 1. Prioritize the currently transported materials. Determine the combined or individual numbers derived from the C.E.I.-F.E.I. and Skin Ranking Grids (Appendices A - F). The final Index obtained should help indicate the priority of the action to be taken. Another Important way to prioritize current materials Is the choice of a worst case leak scenario. This may be challenged and changed several times before obtaining a realistic leak scenario which truly reflects the hazard potential of a particular distribution package or piece of equipment. 2. Ensure consistent and appropriate practices based on the properties of each material shipped from more than one site. For example, the practices for shipping liquid chlorine should be consistent. (This does not necessarily mean equal.) The technology center can help serve this vital role. When creating Internal policies and guidelines, be sure they are essential for the safe transportation and storage of Dow's products and raw materials. Unnecessary policies and guidelines may restrict ano impede the distribution of products to Dow customers and raw materials to Dow plants. Keep In mind, once an operating discipline Is established. It nust be adhered to. 3. Develop pre-start up guidelines for transportation. Before the decision is made to ship or receive a product or raw material not previously transported, a pre-start up review of the transportation system to be used should be given. This is similar to the pre-start up review of the plant producing the product. 3- - A O?3857 PREPARING FOR A REVIEW What Products and Raw Materials Should Be Reviewed? Chemicals to be reviewed include: * All Dow products identified as having a Hazardous Materials Trans portation Index of 2, 3, or 4 using Appendix A (Tables 1 and 2). * All raw materials or purchased chemicals identified as having an HMTI of 2, 3, or 4 using Appendix A (Tables 1 and 2). * All Dow products (1) terminal 1zed or warehoused and shipped from a different location than where they were manufactured or (2) repackaged by others and shipped to a Dow customer. * Chemicals produced by other companies and shipped In Dow's name to Dow customers through swaps, tolls, and/or trades. (Appendix G) * All transported waste materials Identified as having an HMTI of 2, 3, or 4 using Appendix A (Tables 1 and 2). Worst Case Thinking Product Review Team members should use "worst case" thinking In evaluating the safety of the transportation operation. An evaluation should then be made of the "worst case" scenario consequences. For consistency, one should consider the following scenarios: 1. For bulk rail and bulk truck (including intermodal portable containers) - rollover and rupture of tank releasing entire contents. 2. For drum shipments - rollover of container and rupture of three drums. If a flammable material Is Involved, the ensuing fire would be expected to involve the entire contents of the container. 3. For cylinders - break off of the cylinder valve with material leaking from a 1" hole. NOTE: The suggested worst case scenarios should not preclude any scenarios that may be considered to be "worst case" by virtue of special chemical properties or equipment used. For example, drum quantities of easily polymerized material may heat up and result in an explosion. However, unreliability of protection systems should not be allowed to be a cause of an accident. Regular documented testing of all elements of the protection systems is essential. 4- - HAZARDOUS MATERIALS TRANSPORTATION REVIEW AUDIT PREPARATION INSTRUCTIONS These HMTR Audit Instructions are being sent to Louisiana Division plants/departments as an audit to be accomplished in the Consolidate Audit Process. You should start your preparations early and do a quality job on the Review Package. A. Chemicals of Concern The audit should review all chemicals shipped or received, including waste materials, with a Hazardous Materials Transportation Index (HMTI) of 2, 3 or 4. (An HMTI of 1 requires a review by the superintendent and his manager only.) Note: Pipeline transportation practices are not a part of this audit. B. Review Package The Review Package requirements must be completed and sent to the Louisiana Division Auditing Facilitator at least 10 calendar days prior to the audit. The Review Package should contain (for each chemical): 1. A copy of HMTR Audit Presentation, Page 7, Section I. 2. For chemicals involved in Swaps, Tolls, and Trades a completed Appendix G, Page 16. 3. A calculation of the HMTI with the associated CEI and F&EI data sheets or output from Lotus 1, 2, 3 programs. Also the dispersion data (for the quantities, distance, and conditions for the transportation worst case scenario) as per the CEI program instructions in the CEI Audit instructions. 4. A completed Physical Properties Sheet (see Appendix H, Page 17). 5- - HMT Review Audit Instructions 5. A completed Chemical Properties Sheet (see Appendix H, Page 18). 6. A completed Health and Environmental Effects Sheet (see Appendix H, Page 19). 7. A completed Equipment Construction Sheet (see Appendix H, Page 20). 8. A completed Loading Procedures Sheet (see Appendix H, Page 23-25). 10. A completed Unloading Procedures Sheet (see Appendix H, Page 26-27). 11. A completed Outplant Contracts Sheet (see Appendix H, Page 28-29). 12. A completed "Inventory Practices of Full Tank Cars and/or Tank Trucks" (see Appendix H, Page 30). 13. A Transportation Equipment Data and Emergency Response (TEDER) sheet. 14. A list of the shipping quantities by mode and the specification of the containers (railcar, tank truck, drum, etc.) used. 15. Emergency response call reports and accident investigation reports documentating corrective actions. 16. A copy of special governmental regulations required for shipment, such as DOT exemptions. 17. Any business information as it pertains to the distribution operations (i.e., customer selectivity...Have we ever turned down shipping to anyone or with any carrier because they failed to follow safe practices?). 00 A 023860 6- - CONFIDENTIAL NOTE: This package should be used as the basis for the pr.s.ntation which will be given to the Hazardous Materials Transportation Functional Audit Team on the day of the audit. The package will also be used by the HMTR Functional Audit Team to develop questions to be discussed during the review. C. U.S. Area Representatives The Functional Audit Team will invite appropriate Dow U.S. Area or Corporate representatives for reviews with HMTI's of 3 or 4 as needed. The plant will notify the Functional Audit Team Leader a minimum of 30 davs in advance. D. Plant Team The Material Owner (Superintendent) is responsible to organize his Plant Team which as a group is responsible to complete the audit questionnaire and make the presentation to the HMTR Functional Audit Team. E The-Audil Plant Team Presentation/Discussion: Your team should be prepared to lead a discussion with the Functional Audit Team which addresses each of the major areas of the questionnaire. Follow the attached Hazardous Material Transportation Review Audit Agenda. DO A 023861 confidential -7 Hazardous Materials Transportation Review Calculations Using Lotus 1-2-3 A copy of the Lotus 1-2-3* program is included for your use in calculating the Chemical Exposure and Fire & Explosion Indexes and the Skin (Hazard) Ranking for the Hazardous Materials Transportation Review. A sample spread sheet with data for 45,000 lbs. of acrylic acid is shown on the following page. The worse case scenario assumes the loss of the entire contents of the container. The entire spread sheet is "write protected" except for the description of the product and container and the 11 pieces of input data (shown on the screen in the green column) required for the calculations. The input data required is as follows: 1. The Dow EEPG concentration as shown in the CEI Audit instructions. (Note: If the EEPG value for your hazardous material is not available, use three times the TLV for the material). 2. The Material Factor as found in Appendix A of the F&EI Guide. 3. The NFPA Health Rating (Nh) as found in Appendix A of the F&EI Guide. 4. The NFPA Flammability Rating (Nf) as found in Appendix A of the F&EI Guide. 5. The Heat of Combustion (He) as found in Appendix A of the F&EI Guide. 6. The Molecular Weight of the hazardous material. 7. The Vapor Pressure in mm Hg at 25 degrees C. 8. Is the material thermally unstable below 100 degrees C. (That is, does a measurable exotherm [ARC or equivalent] take place below 100 degrees C.) Yes or No. 9. The physical state penalty. (Choose one from the three .choices given). DO A 023862 8- - CONFIDENTIAL 10. The pressure in PSI in the shipping container at 50 degrees C. 11. The Dermal LD50 in mg/kg for skin exposure. NOTE: The weight of material in the shipping container is fixed at 45,000 lbs. One the input data has been entered, press the F9 key to calculate the CEI, F&EI, and Skin Rank values, press ALT and P at the same time. If there are any questions regarding this Lotus spread sheet, please call Dean Smith at Ext. 8879. 'Trademark DO A 023863 CONFIDENTIAL -9- SAMPLE OUTPUT FROM LOTUS 1-2-3 PROGRAM HAZARDOUS MATERIALS TRANSPORTATION REVIEW CEI, F&EI, AND SKIN RANK CALCULATIONS (REVISED 5/14/90) TANK CAR STYRENE INPUT DATA EEPG CONCENTRATION PPM MATERIAL FACTOR (F&EI GUIDE) NFPA HEALTH RATING (Nh) NFPA FLAMMABILITY RATING (NO BTU'S PER MLBS MOLECULAR WEIGHT VAPOR PRESSURE MM HG @25 DEG C THERMAL INSTABILITY DEG C PHYSICAL STATE PENALTY VISCOUS LIQUID----------- .70 LIQUID..............................1.00 COMPRESSED GAS----------- 1.20 LIQUIFIED FLAM GAS -- 1.30 LBS OF PRODUCT PER CONTAINER SHIPPING PRESSURE(PSI OF MATERIA RELIEF VALVE SETTING (LBS) DERMAL LD50 FOR SKIN EXPOSURE 200.00 24 2 3 17.00 104 7.00 32 1.00 150,000 5 75 2,001 SUMMARY CEI 64.00 F&EI 142.22 SKIN RAN 0 CALCULATED FACTORS CHEMICAL EXPOSURE INDEX RANKING FIRE & EXLOSION INDEX RATING ACUTE HEALTH HAZARD FACTOR ACUTE HEALTH FACTOR SCALE # LBS VAPOR RELEASED IN 15 MIN. VAPOR QUANTITY SCALE # DISTANCE SCALE # MOLECULAR WEIGHT SCALE # SHIPPING PRESSURE FACTOR THERMAL INSTABILITY FACTOR PROCESS PENALTIES FACTOR PROCESS PENALTIES SCALE # CHEMICAL EXPOSURE INDEX CHEMICAL EXPOSURE SCALE # 21714.29 1.00 893.55 2.00 4.00 4.00 0.00 2.00 2.00 2.00 64.00 1.00 MATERIAL FACTOR GP BASE FACTOR HANDLING & TRANSFER FACTOR ACCESS FACTOR SPILL CONTROL FACTOR FI-GENERAL PROCESS FACTOR 24 00 1 00 0.S5 0.25 0 0 2.70 SP BASE FACTOR TOXIC MATERIALS FACTOR PROCESS OPERATION, PURGE FACT QUANTITY IN STORAGE FACTOR IGNITION SOURCE FACTOR (FIRED HT OPERATING PRESSURE FACTOR F2-SPECIAL PROCESS HAZARDS FACT i 00 0.40 0.20 0.40 0 00 0.09 2.19 SKIN RANKING 0.00 F3-UNIT HAZARD FACTOR (-F1/F2) F&EI-FIRE & EXPLOSION INDEX FIRE & EXPLOSION RANKING 5.93 142.22 4 i9-Sep-90 -10- D0 A 023864 confidential Hazardous Materials Transportation Review Audit Agenda I. Overview Presentation to the Audit Team (45 minutes) Note: Timing is approximate 1. Provide a list of all products and purchased materials as shown on plant cost sheets. 2. Review the hazardous materials to be covered in the audit, and the nature of the hazards (ie., flammable, reactive, toxic, etc.). Including the methods and modes of transportation. 3. Review any transportation incidents in the last two years. 4. Give the status of items agreed to be acted on by the plant from the previous HMTR audit. 5. Review your loader/unloader training program. 6. Based upon the answers given to the questions in the "Guidelines For A Hazardous Materials Transportation Review Process", discuss the major hazardous materials transportation concerns for the plant. 7. Review planned hazardous material transportation improvements. II. HMTR Guidelines Questionnaire (45 minutes) A. Review the information provided in the HMTR questionnaire on an exception basis. III. Documentation Audit and Facility Tour (30 minutes) A. Following the plant presentation, selected members of the Audit Team will examine the plant's loading/unloading areas and applicable documentation discussed during the audit. (Documentation should be readily available for the auditors). This will include: 1. Documentation of DOT training; 2. Examples of completed loading/unloading checksheets; 3. Loading/unloading procedures. -11- D A 023865 confidential IV. Audit Report A. The HMT Functional Audit Team Leader will summarize the team's findings and furnish the Audit Facilitator a written audit report of their recommendations by Monday following audit week. -12- DO A 023866 CONFIDENTIAL APPENOIX A RELATIVE HAZARD RANKING Oow products, products shipped by other companies to Dow customers in Dow's name, Dow-purchased raw materials, and transported Dow waste materials need to be ranked by using the Chemical Exposure Index (C.E.I.) calculations, the Fire and Explosion Index (F.E.I.) calculations and the effects of the chemical on skin contact. The numerical ranking for skin Is Intended to Indicate the relative risk from a single dermal exposure, such as might occur In a transportation accident, that could result In the absorption of acutely toxic or lethal amounts. It does not address skin burns or chronic absorption. The principal criterion used (See Table 1 below) Is the actual or estimated animal dermal LD50. When there have been cases of human lethality from a single skin exposure, the chemical In question should be ranked In the highest category, regardless of the lower animal toxicity (eg. phenol). TABLE 1 SKIN RANKING CRITERIA FOR HAZARDOUS MATERIALS TRANSPORTATION REVIEW PURPOSES SKIN RANK MSIS 4 Oermal LD50 of < 200 mg/kg or lethal to humans 3 Dermal LD50 of 200-500 mg/kg 2 Dermal LD50 of 501-1000 mg/kg 1 Dermal LD50 of 1001-2000 mg/kg or single exposure judged acutely toxic 0 Dermal LD50 of >2000 mg/kg. Dermal single exposure judged not to be toxic, or no information available. Once these indices are determined, they should be plotted on the C.E.I. F.E.I. and Skin Ranking Grids shown in Table 2 to obtain a Hazardous Materials Transportation Index (HMTI). -13- ft 023867 DO conf TABLE 2 HAZARDOUS MATERIAL TRANSPORTATION INDEX CHEMICAL EXPOSURE INDEX - FIRE ANO EXPLOSION INDEX - SKIN RANKING GRIDS c: 430+ 4 4 4 4 4 cm X c: 200-100 2 3 mj J 4 100-199 * ^ 24 1-99 l l2-4 0 i 2 ** j EFFECTS ON SKIN 00 l 2 2 4 0 1-60 61-96 7M77`12S + FIRE & EXPLOSION INDEX (F.E.I.) The purpose for calculating the HMTI Index is to determine: * Priority of product review * Level of management involvement in the reviews When calculating the C.E.I. in a transportation environment, the shortest distance (1,000 feet) from the point of release should be used. This is done because It is impossible to determine the point where loss of containment during transportation may occur.. Appendices B, C and D Illustrate typical calculations for the Dow-produced products Ethylene Oxide and Liquid Chlorine. Appendix E Illustrates a typical calculation for a Dow-purchased raw material, Methacrylonitrile. Appendix F places all of the above chemicals in the C.E.I.-F.E.I. and Skin Ranking Grids. Table 3 will indicate the action to be followed based on the ranking grid number of the chemicals. -14- DO A 023868 CONFIDENTIAL TABLE 3 TYPICAL REVIEW LEVELS This table Illustrates various review levels. The superintendent should be present for all different levels of the review. Ranking Qr.1<l No. Review Committee 1 Superintendent 4 Manager 2 Division Review Committee 3&4 Division Review Committee 4 Area Rep. -15- DO A 023869 CONFIDENTIAL. APPENDIX B CHEMICAL EXPOSURE INOEX Complete the following Table (See Note 1) by filling In and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as identified In the following formula: X. El Acute Seeitn Kaaare Sca:e No. fa~i c in. x Q7] X [vj VT. Vapor Quantity Scate No. Distance iKccsrocai) Scale No. Moieeaiar 'Ve-tat Scale No. Proem Prames Scsie No. Qeracai Exposure Icoex Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source #1 Tank Car Rupture of Ethvlene Oxide I. IL m. rv. V. VI. (CET; :1 1 m4 3 2 228 Source #2 (If needed) ! * NOTE 1 - The distance scale number In Column III for chemicals In a transportation environment will always be less than 1,000 feet. NOTE 2 Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 - Use additional sheets if additional sources with differing potential impact are present. -16- D0 A 023870 CONFIDENT!*^- FIRE AND EXPLOSION INOEX '.Ml Kauwm ^cation ETHYLENE OXIDE TAJIK CAR LN SOUTH iM.UAlU IT ** IT \.I*X.NJ m Moau UMt MATERIALS ANO PROCESS uu ir*n of oprraron : STARTUP . SHUTDOWN : 'OHM* OPERATION UK iuriAuull AOM MtttRUL ftcno* MATERIAL FACTOR (SEE TASLE I OR APPENOICES A OR SI nw iwuwwtwi mu <jq* wrqwow tm 4Qpi 1. GENERAL PROCESS HAZAROS PENALTY IASS FACTOR. A EXOTHERMIC CHEMICAL REACTIONS IFACTOR X 18 I at I. CNOOTHSRMtC FRQCESSSS .FACTOR 20 W OI C. MATERIAL HANOUNQ 4 TRANSFER (FACTOR IS 1 0S> ENCLOSED OR INOOOR FROCXSS UMTS .FACTOR 2S a l I. ACCESS t ORAMAOS ANO im CONTROL (FACTOR 2S a SOI GENERAL FROCSSS HAZAROS FACTOR (F.|. a 2. SPECIAL PROCESS HAZAROS SASC FACTOR. <00 a. rose uatiruuswfactor o n o aoi S. SUS-ATMOSRHCRtC FRtSSURf <100 mi SO C OFCRATION M OR NCAR FLAAAMARLf RANOS t mERTSO i TANK Farms STORAGE FLAMMABLE IIOUIOS 2 FROCESS UFSrr OR FURGE FAILURE J ALWAYS IN FLAMMABLE RANGE 0 OUST EXFLOSION (FACTOR 2S to 2.001 (SEE TAILS W " r- FRESSURS (SEE FOURS a OPERATING frcssurs . NOT INCRTtO REUEF SSTTINO . .S*0I `0 :o F LOW TSMRCRATURS (FACTOR 20 N .301 G. QUANTITY OR FLmMAKXVNSTASLl MATERIAL. QUANTITY . i UOLROS. GASES ANO REACTIVE MATERIALS IN FROCSSS (SCI F. 31 2 UOWOS OR OASES M STORAGE (SEE FiO 41 3. COMBUSTIBLE SOUOS M STORAGE. OUST in FROCESS (SEE *10 SI H CORROSION ANO EROSION (FACTOR . 1010 .7SI .STUM l I LEAKAGE - vOlNTS ANO RACKING (FACTOR 10 M SOI USE OF FIRED HEATERS (SEE *<G <1 K HOT OR. HEAT EXCHANGE SYSTEM (FACTOR IS 10 1 191 (SEE TABLE Ml OCTATIM.* EQUIPMENT 0 SPECIAL FROCESS HAZAROS FACTOR IF,). UNIT haZARO FACTCR (F. F, F, *<RE ANO EXFLOSION MOEX (F, mF . * i En . -17- DO A 023871 CONFIDENTIAL PENALTY USEO <00 T5T "IT ~W 2.70 1 00 .40 .33 .: j c APPENOIX 0 CHEMICAL EXPOSURE INDEX Complete the following Table (See Note 1) by filling In and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as Identified In the following formula: I. x jT] X m. x IV. X V. * VI. Acute Hsnfc Hazara Scale So. Vaoor Quantify Scaic So. Dauncs 'Recteracsi) Scaie No. Molecuar Weitat Scaie So. Praeaa Psssioes Scaie So. Caeaucai Eaaosure Index Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source #1 Tank Car Ruoture of Liauid Chlorine I. n. in. | iv. V. VT. 1 (CZD i 4. < i n 512 Source #2 (if needed) * NOTE 1 - The distance scale number In Column III for chemicals In a transportation environment will always be less than 1,000 feet. NOTE 2 - Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 - Use additional sheets if additional sources with differing potential impact are present. -18- a 023872 confidential. APPENDIX E CHEMICAL EXPOSURE INOEX Complete the following Table (See Note 1) by filling in and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as identified in the following formula: FI * E x m. x | rv. | :c (Tj - VL Acss Ks Sc:e No. V*cor Qmnarv Scic No. Dissnc (K<s.tel Sc:e ^ No. Maicssisr We;52: Sce No. ?rsesss Psscss Sc* No. C*=:c: liTCTUr? trees Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source fl ISO Container Tank Car Rupture of Methacrvlonitrile imi Source #2 (if needed) I. IL CL rv. V. VI. (CZT: 1 3 L -11 2SS 1 Ii l * NOTE 1 - The distance scale number in Column III for chemicals in a transportation environment will always be less than 1,000 feet. NOTE 2 - Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 - Use additional sheets if additional sources with differing potential impact are present. -19- DO A 023873 confidential APPENDIX F HAZARDOUS MATERIAL TRANSPORTATION INDEX Chemical Exposure Index Fire and Explosion Index - Skin Ranking Grids *00+ Cl, 4 4 4 4 :co-400 am% 100-299 1-99 l m 33 22 12 * 3 4 3 E.O. m 3 4 4 0l1 2 m j MAN EFFECTS ON SrCDf 0 0 l -m J 4 0 1-40 <l-M 97*07 OS* FIRE & EXPLOSION INDEX (F.E.L) CHEMICAL I'XTOSIIKK INOI-X fC .fi.l.) -20- DO A 023874 CONFIDENTIAL FIRE AND EXPLOSION INDEX *"o3uwI7 OCATION ETHYLENE OXIDE TANK CAR IN *0UTE t<M.uAr*s IT *1vRNRO IT ______________________________________________ MATERIALS ANO PROCESS iiitiuia * noau um' i*u iT*n of owuno* : START4JP . lMlT-eON ; -cri ml operation UK UAT*RIAuSl FOR UAfCAAA FACTOR MATERIAL FACTOR (SEE TABLE 1 OR AFPENOiCES A OR SI ** '**M*~**n -* m wmooraiufo oor aO*F> 2: 1. GENERAL PROCESS HAZAROS itf tierem penalty 00 penalty USED i 00 i EXOTHERMIC CHEMICAL REACTIONS (FACTOR 30 M 1 2S) 1 1. ENOOTHERM* PROCESSES .FACTOR 20 M *01 C. MATERIAL hanOUNQ 4 TRANSFER (FACTOR 23 W i OS) HI : ENCLOSED OR INOOOR RAOCZSS UMTS .FACTOR 2S l !. ACCESS * ORAMAOE ANO SPILL CONTROL (FACTOR 23 *01 - - U a HI r.?MCRAl IMSII MAXARBR FACTOR (Ft 2.70 1 2. SPECIAL PROCESS HAZAROS IA* FACTOR A TOXIC MATERMUS) (FACTOR 0 20 W 0 Ml 1. SUfl-ATUOSPHCPiC PRESSURE (100 ma m | 1 1 1 1 C OPERATION IN OR NEAR FLAMMABLE RANOE Z INERTED " NOT INSRTfO | 1 TANK FARMS STORAOE FLAMMABLE LlOUtOS 2. FNOCESS UFSET OR PUROI FAILURE } ALWAYS IN FLAMM>Lt RANGE 9 OUST EXPLOSION (FACTOR 2S M 2.001 (SEE TAELS HI ~ " ET PRESSURE (SEE FIGURE I OPERATING PRESSURE_______REUEP SETTINO _ _____ :91 t1 1 00 1 i 00 .40 *0 ! j iO :o .23 *0 ! F LOW TEMPERATURE (FACTOR 20 M JO) || G. QUANTITY OP AAMMABLEAMSTASL* MATERIAL: OUANTTTY_______ **.. H. _______ ITU* i i UOUCS. GASES ANQ REACTIVE MATERIALS M PROCESS (SEE PIG. 3) 2 UOLFOS OR OASES M STORAOS (SEE P<0 *l 3. COMBUSTIBLE SOLJOS M STORAGE. OUST IN PROCESS (SEE K3 II h CORROSION ANO EROSION (FACTOR .10 M.7S) ! 1 . :3 1 I LEAKAGE - JOINTS ANO PACKING (FACTOR 10 M 1 SOI | USE OF FIRED HEATERS (SEE *>G It 1 K HOT OR. HEAT EXCHANGE SYSTEM (FACTOR IS 10 l 1SI (SEE TABLE HIT ! *. Ctat(n* EQUIPMENT 10 UNIT Hi^AKd FACTOR it. F, > F, F*RF ANO EXPLOSION (NOE* (F, . MF . F A Fh DO A 0P^O-7C CONF I DENJ r AL Z-- e 1- ?- APPENOIX 0 CHEMICAL EXPOSURE INDEX Complete the following Table (See Note 1) by filling In and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as identified in the following formula: I. \cuut Hsaitd .axaro icsje No. x 1 a. | Vaoor Quanutv Scaic No. x m. Ouuncs Restored) Scaie Mo. X rv. Molccnar Weifnt Scaic No. X V. Precus Presides tczic No. s VT. c"teyjgi Ereosure Index Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source #1 Tank Car Rupture of Liquid Chlorine I. n. m. |i rv. 1 V. VI. rein 4 2 512 Source #2 (if needed) j 1i 11 1 t 1 I i * NOTE 1 - The distance scale number in Column III for chemicals in a transportation environment will always be less than 1,000 feet. NOTE 2 - Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 - Use additional sheets if additional sources with differing potential impact are present. -18- D A 023876 CONFIDENTIAL APPENDIX E CHEMICAL EXPOSURE INOEX Complete the following Table (See Note 1) by filling in and multiplying the appropriate Risk Factor Scale numbers for each of the major Risk areas as identified in the following formula: FI x E VV DL x [F * E3 Acss Hass Scare No. Vieor Qvu&ar/ Scare No. Dicanss (Rcaacerl Zczic /% Vo. Moiessiar We~ss Scare No. Prscaas Psaarsea Scarc No. VL s:cmiz trees Identification of Containment Vessels being evaluated: Name or Number (See Notes 2 & 3) Source 11 ISO Container Tank Car Rupture of i miMothicryionUrno Source #2 (if needed) I. IL DL rv. V. VI. (CZT: t * 3 A 41* 2SS 1 i 11 i 1 NOTE 1 - The distance scale number in Column III for chemicals in a transportation environment will always be less than 1,000 feet. NOTE 2 - Only different sources of the same chemical should be evaluated on this sheet. Use a separate Chemical Exposure Index for every different chemical. NOTE 3 - Use additional sheets if additional sources with differing potential impact are present. -19- DO A 023877 CONFIDENTIAL APPENDIX F HAZARDOUS MATERIAL TRANSPORTATION INDEX Chemical Exposure Index Fire and Explosion Index - Skin Ranking Grids *00+ a,| 4 4 4 4 :co-ioo A* mm 33 <* j 4 100-299 A 2 2 3 E.O. 0 l 1 2 3 MAN 1-99 l l 2 3 4 hrTECTS ON SKIN 00 l 2 m 3 4 o t-so <i-m rr.127 121 FIRE & EXPLOSION INDEX (F.E.L) CIIUMICAL HXTOSIIKH INOliX H.I.) -20- 00 A 023878 CONFIDENTIAL APPENDIX 6 SNAPS - TOLLS - TRADES Suggested Items to consider on swaps* tolls, trades and use of third party shipping containers, rail cars, storage tanks, etc. 1. Is your product Involved In swaps, tolls, or trades? Yes [] No [] 2. If no, do not answer the following questions. 3. If yes, who Is responsible for making the swaps, tolls, or trades agreements? _. 4. Does your plant have any Input Into the transportation practices for this product? Consider: Specifications for equipment Yes [] No [] Securement training and procedures for loading personnel Yes [] No [] Difference In quality which could result In customer problems, such as reactivity Yes [] No [] 5. Do non-Dow shippers load on heels? Yes [] No [] 6. Do non-Dow shippers load through dedicated piping/equipment when It is critical to do so? Yes [] No U 7. Oo non-Dow shippers load through cross header systems (possible contaminates)? Yes [] No [] 8. Are similarities and/or differences between Dow and other non-Dow shippers documented? Yes [] No [) -21- DO A 023879 CONFIDENTIAL APPENDIX H Hazardous Materials Transportation Review Questionnaire (Not Inclusive) The following Is a list of Items to consider when preparing a review. It Is by no means all Inclusive. The Product Review Team Is encouraged to modify and expand the list to best suit their Individual needs. I. PHYSICAL PROPERTIES 1. Molecular Weight 2. Odor 3. Appearance 4. Color 5. Chemical Formula 6. Solubility: In Water, Others 7. Bolling Point 8. Freezing Point 9. Flash Point (Method) 10. Flammable Limits 11. Autoignition Temperature 12. Oenslty of Material 13. Vapor Pressure - mm Hg at 20 C 14. Explosive Limits 15. Heats of Reaction -22- DO A 033880 CONFIDENTIAL HAZARDOUS MATERIALS TRANSPORTATION REVIEW QUESTIONNAIRE CHEMICAL PROPERTIES 1. Chemical composition If the material Is formulated or not pure. 2. Do you have ARC run on material? Yes [] No [] 3. Does material react with water? Yes [] No [] What are products? 4. Does material undergo autodecomposition? Yes [] No [] 5. Are the potential reactive chemical consequences of pH, water, rust, light, promoters and other possible containments known? Yes [] No [] 6. Does material polymerize? Yes [] No [] 7. If material freezes, will Inhibitor separate? Yes [] No [] 8. What are the products of oxidation (fire)? 9. List some of the main transportation related reactive chemical concerns, in order of magnitude or priority. ____________________ Answer question 9 even If an MSD sheet Is supplied. -23- c0o0 t^0 DENT HAZARDOUS MATERIALS TRANSPORTATION REVIEW QUESTIONNAIRE III. HEALTH AND ENVIRONMENTAL EFFECTS 1. What is acuta toxicity of the naterlals? - Inhalation (LC50 In ppm) _______________________________________ - Dermal (LD50 In mg/kg)_______ _____________________________ - Oral (LD50 In mg/kg) ____________________________________________ 2. Are potential health effects reversible? Yes U No [] 3. Can people readily escape contanlnated areas? Yes [] No[] 4. What Is effect on aquatic life? _________________________________ 5. Does material biodegrade? Yes (] No [] 6. Would a spill cause long-term groundwater toxicity problems? Yes [] No [] 7. Does material exhibit any warning properties? Yes [] No [] 8. Is material corrosive to skin? Yes U No (] 9. Has recommended protective equipment been tested? Yes [] No [] 10. Please Submit -- A Material Safety Oata Sheet (MSDS) -- A Transportation Equipment Oata-Emergency Response Sheet (TEDER) -24- DO A 023882 CONFIDENTIAL HAZARDOUS MATERIALS TRANSPORTATION REVIEW QUESTIONNAIRE IV. EQUIPMENT CONSTRUCTION 1. Is this product corrosive to the meterlel of construction of the shipping container? Yes [] No [] 2. Are specific Materials of construction required to be used or to be avoided? Yes [] No [] 3. Are materials of construction concerns communicated to the customer or supplier (eg. aluminum not acceptable for POC)? Yes [] No [] 4. How do you assure the proper material of construction Is being used? 5. Does this product require Insulation against extreme heat or cold conditions? Yes [] No (] If yes, how do you assure that Insulated equipment Is used? 6. What are the minimum equipment specifications for this product for the modes of transportation used (for DOT, IMO, etc.)? 7. What are the preferred specifications for this product for the modes of transportation used? ______________________________________ Which are used? -25- DO A 023883 CONFIDENTIAL HAZARDOUS MATERIALS TRANSPORTATION REVIEW QUESTIONNAIRE V. LOADING PROCEDURES 1. Is material of construction verified before loading? Yes [] No [] 2. Is material to be loaded In dedicated tank or shipping containers? Yes [] No U 3. Are hoses dedicated to this material? Yes [] No [] 4. Is there a potential for cross contamination In the loading process? Yes [] No [] 5. Who/How are checks for the cleanliness and Integrity of tank cars, trucks, drums, or other containers made before loading? Are there written procedures, checklists and training available? Yes [] No [] Are heels analyzed? Yes [] No [] 6. Are dew-point checks needed for this product prior to loading? Yes [] No U 7. Who Is responsible.for the general safety conditions of tank cars, trucks, drums, or other containers (leaking valves, brakes, tires, gaskets, floor surface In trailers, damage, mixed shipment product mix, etc.)7____ How are Inspections made? _ 8. Are drivers Involved In loading this product In your plant? Yes (] No U DO A 023884 CONFIDENTIAL 9. If so, do drivers have training In what to do In case of emergency In the plant? Yes [] No [] 10. Do drivers that load products have training on how to properly secure the shipping container? Yes [] No [] 11. How do you assure that trucks, rail cars, and containers are properly labeled and placarded for the hazard? 12. How do you assure that trucks, rail cars, containers, and marine vessels are properly secured after loading? 13. Are loading procedures current? Yes [] No [] Written by whom?_ Reviewed/Approved by whom? 14. What specific personal protective equipment Is required for loading this product? 15. Have loaders received DOT training within the last two years? Yes [] No [] 16. What measures are used to assure container Is not overloaded? 17. Is the vapor space prevented from passing through a flammable envelope during loading? Yes [] No [] Is Inert padding/purging required? Yes [] No [] -27- HAZARDOUS MATERIALS TRANSPORTATION REVIEW QUESTIONNAIRE IN ROUTE PROCEDURES 1. What is the driver selection process used by the carrier? 2. Are TEDER and MSD sheets available? Yes [ ] No l ] 3. Is there a specific packet for handling precautions given to the driver? Yes [ ] No [ J 4. Do you require drivers to have the same personal protective equipment as your loaders? Yes [ ] No [ J 5. What is the worst case reasonable situation that could occur? Have you conducted simulated loss of containment "What If" scenarios with people (including carriers) who can contribute to an emergency plan? Yes [ ] No [ J 6. Have you determined what evacuation plans would be recommended in case of an emergency? Yes [ 3 No [ J NOTE: Utilize the disperson data (for the quantities, distance.and conditions for the transportation worst case scenario) as per the CEI program instructions in the CEI audit. Information to be provided to emergency responders should be consistent with current DOT Emergency Response Guidebook recommendations for specifically named chemicals. 7. Is specialized equipment and/or a procedure required to respond to a leak of this product? Yes [ J No [ ] -28- DO A 023886 CONFIDENTIAL Is It available? Yes [] No [] Where? 8. Is there a maximum time a product can remain In a shipping container before It Is unloaded (e.g. anhydrous (HC1)? Yes [] No [] 9. Should this product require special transportation modes and routes? Yes [] No [] Why/Why not?__________ ____ 10. Are local, state, or federal special permits or approvals required (eg. Oot exemptions)? Yes [] No [) 11. What regulatory requirements are applicable (DOT, U.S. Coast Guard, IMO (International Marine), IATA (air)? 12. Do you place any restrictions on the carrier (le, daylight movement only, special routes, or weather restrictions)? Yes [] No (] 13. Who will be the "knowledgeable" Oow contacts In an emergency response (E/R) situation? 14. Does this product require special training for Dow's E/R Teams and medical personnel? Yes (] No (] If yes, what Is the frequency of training? 15. Does there need to be a definition of geographical responsibility on what E/R Team reacts to an emergency (1e. related to question 14)? This could be U.S., overseas, etc. Yes [) No [] -29- DO A 023887 CONFIDENTIAL 16. Oo drivers have training In what to do In case of emergency? Yes [] No [] Who provides the training? 17. Has a Driver Performance Evaluation Program been established? Yes [] No [] 18. What are the carrier policies regarding highway emergencies? (Oow recommends a first call to CHEMTREC be Included In the emergency plan. 19. Do you audit carrier performance relative to the transportation of your products? Yes [] No [] -30- HAZARDOUS MATERIALS TRANSPORTATION REVIEW QUESTIONNAIRE VII. UNL0ADIN6 PROCEDURES 1. Is material unloaded by driver or local operating personnel? Are they trained In the procedures? Yes [] No [] Ooes this Include emergency procedures In case of hose failures, gaskets, etc.? Yes [] No [] Who conducts the training and how often? Is the training documented? Yes [] No [] 2. Are unloading procedures current? Yes [] No [] Written by whom?. Reviewed and approved by whom? 3. Have procedures been established and customers Informed to ensure proper securement of the shipping container, rail car, truck, vessel or drums after unloading? Yes [] No [] 4. Should car, truck, or marine vessel be Inerted as It Is emptied? Yes [] No [] 5. Is the vapor space prevented from passing through a flammable envelope during unloading? Yes [] No [] 6. Is sampling/analysis required prior to unloading? Yes [] No [] -31- Do A 023889 CONFIDENTIAL 7. Are unloading areas equipped with the required safety equipment (1e, suitable fire extinguishing, equipment, spill basins, etc.)? Yes [] No [] 8. Are unloading operations "attended* throughout the entire period of unloading? Yes [] No [] Is the "attendance" by people, electronic devices, or both: For rail cars: For tank trucks: -32- DO A 023890 CONFIDENTIAL HAZARDOUS MATERIALS TRANSPORTATION REVIEW QUESTIONNAIRE VIII. OUTPLANT CONTRACTS (TERMINALS - WAREHOUSES - REPACKAGERS) Items to consider on use of off-site contracted services and operation: 1. Are facilities covered by Standard Dow Contract (l.e. approved by U.S. Area or Olvlslon Terminal's Focal Point)? Yes (] No (] Is there a current Contractual Exhibit B or Dow Operating Procedures In existence for the location? Yes [] No [] 2. Have facilities been audited and approved by U.S. Area Terminal's Focal Point or representative? Yes [] No [] 3. Is surrounding area free of residential or public facilities, l.e., hospitals, schools, etc.? Yes [] No [] What Is approximate distance to nearest public facility and the corresponding highest CEI number? What Is approximate distance to nearest residence and the corresponding highest CEI number? 4. Are contract facilities covered by Dow Technology Center Audits and/or QAC Reviews? Yes [] No [] 5. Are products positively Identified prior to loading or off-loading? Yes [] No [] How Is product quality monitored/maintained? 6. Have contract facility employees been trained In proper handling of Dow products with regard to Safety, Industrial Hygiene, Environmental, proper packaging (materials of construction), securement, etc.? Yes [] No [] D0 A 023891 CONFIDENTIAL -33- 7. Are appropriate blocking and bracing procedures available to cover loading of packaged goods? Yes [ ] No [ ] 8. Does facility have a formal emergency plan? Yes [ ] No [ ] Ability to prevent run-off water in case of a fire? Yes [ ] No [ ] Resource and Information; G. R. Mutscber U.S. Area Warehousing/Terminals Focal Point 2020 WHDC Midland, Michigan Phone (517) 636-5841 Ernie Wall Louisiana Division Terminals Focal Point Building 3302D Plaquemine, Louisiana Phone (504) 389-6497 -34- DO A 023892 CONFIDENTIAL HAZARDOUS MATERIALS TRANSPORTATION REVIEW QUESTIONNAIRE IX. INVENTORY PRACTICES OF FULL CONTAINERS 1. Is there a policy setting the maximum number of containers (rail car, trucks, drums, etc.) or quantity of material that can be stored at one location? Yes [] No (] Should there be? Yes [] No [] 2. Is It necessary to know the location, as well as types, of chemicals being Inventoried side-by-side while inside Oow? Yes [] No [) 3. Are Inhibitor levels or other time dependent variables monitored for chemicals In storage In shipping containers? Yes (] No (] How? 4. Have adequate safety-loss prevention and environmental principals (1e. fire monitors, flammable detectors, spill containment, CEI & F A El calculations) been considered for your materials? Yes (] No [] 5. Is reconfirmation of securement done prior to shipment? Yes U No H 6. Have emergency procedures, including hurricanes, freezing weather, etc. been developed for your materials In storage In shipping containers? Yes 0 No [] -35- DO A 023893 CONFIDENTIAL