Document jNQXDRbK1vd8zM8ZV4Q6xLrVp

PROCESS SAFETY AND LOSS PREVENTION AUDIT Page I VIII. LOSS PREVENTION INSURANCE REPORT (Including F&EI Risk Analysis) Contact your Loss Prevention Contact for instructions to assist you in filling out this document. (Revised 02/18/94; cmk) 1/8/97; LAD:bwb DO a 036985 O0NFTDFNTTA1 PROCESS SAFETY AND LOSS PREVENTION AUDIT Page II LOSS PREVENTION INSURANCE REPORT II. UNIT LOSS PREVENTION INFORMATION 1. Summary of Unit Features and Status Area/Country North America Site Plaquemine Unit Superintendent G. C. LeBlanc Division Louisiana Unit Chlor-Alkali 2 Location Date Piaquemine, LA 1-6-97 Building Number/s Date of Previous Inspection 3601 10-28-94 Type Of Operation Manufacturing - Chlorine / Caustic Inspected By (from Safety & Loss Prevention) Buck Bailey Inspected by (from Plant) John Dizor Give a written summary including overall evaluation comments, comparison to previous inspection, and summary of recommendations: (Revised 02/18/94; cmk) 1/8/97; LAD:bwb 00 A 036986 CONFTDFNTIAl PROCESS SAFETY AND LOSS PREVENTION AUDIT Page III LOSS PREVENTION INSURANCE REPORT 2. Summary of Ratings and Recommendations for Unit UNIT RISK FEATURES 3. Plant Condition and Appearance 4. Unit Risk Analysis Package 5. Changes Since Last Inspection 6. Features for Areas in Unit 7. Drainage and Containment 8. Tank Storage 9. Electrical & Instrument Conditions 10. Chemical Inventory & Isolation 11. Management Considerations 12. Plant Reliability R = Recommend Upgrading F = Fair G = Good E = Excellent R F G E N RECOMMENDATION A NUMBER(S) NA = Not Applicable Refer to Guideline for definitions of ratings. For recommendations see Pages Give a brief narrative background summary including history of unit with details on age, construction phases, original plant, etc. Chlor-Alkali 2 was started up in 1969 as a completely integrated chlorine/caustic production facility. The original plant has a two (2) rectifier/circuit operation with M-80 vintage cells. The 1970's New liquefaction train installed and started up. The 1980's Hydrogen collection trains installed and started up. MOD 5 control system installed on cell area. New ecology system with WP-800 and D-803 above ground tanks installed. Chlorine evaporation train installed. Bird centrifuges replaced flatbed filters for sulfate salt removal from caustic. The 1990's Completed MOD 5 conversion of chlorine and caustic areas. Sodium bisulfite replaced sodium thiosulfate for hypochlorite reduction in cell effluent. Electrolytic metals removal cells (iron cells) shutdown and demo'd. Eliminated C-201-B, spare dry chlorine compressor. Replaced CTW interstage coolers with air cooled fin fan interstage coolers. New R-123 freon system. Sped chlorine compressor, C-201A, gear box up. Demo'd weak sulfuric acid tanks (D-210, D-211). New vacuum breaker, VRD-201, replaced old vacuum breaker. Replaced brine salt column, D-108.________ ____________ _______________________________________________ (Revised 02/18/94; cmk) 1/8/97; LAD:bwb DO A 036987 OONFIDFNTIA1 PROCESS SAFETY AND LOSS PREVENTION AUDIT Page IV Rebuilt Sump-1. (Revised 02/18/94; cmk) 1/8/97; LAD:bwb A 036988 confidfntial PROCESS SAFETY AND LOSS PREVENTION AUDIT Page V LOSS PREVENTION INSURANCE REPORT 3. General Unit Information Plant Unit Chlor-Alkali 2__________________________________ Unit Products Chlorine (gas & liquid), 50% Caustic, and Hydrogen Raw Materials Brine, Fuel Gas (Methane), Cell Effluent, Hydrochloric Acid, Sulfuric Acid Operating Days/Week? 7 Operating Hours/Day? 24 No. of Shifts? 2 Date 1/6/97 Hours per Shift? 12 Plant Condition & Appearance - Description Operationally plant condition is acceptable, although, corrosion in the plant is noticeable in some areas. An active maintenance painting program is in place to address this situation.________________________________________ __ 4. Unit Risk Analysis Package Items which must be attached as part of Risk Analysis Package (Check if attached/Give any explanations) Block Flow Sheets OK Process Description OK Plot Plan with Areas of Exposure and Protection Features OK F. & E. 1. Risk Analysis Summary OK F. & E. 1. Calc. Sheets for Highest MPPD and Highest MPDO & Bl OK C. E. 1. Summary Sheets OK Business Interruption Data OK Replacement Value $99 MM Interdependencies with Other Dow Facilities & Which Facilities? Brine is supplied by Brine Production 30 miles south of Ptaquemine. Hydrochloric acid is supplied by Solvents. Chlorine 1 supplies sulfuric acid via pipeline. Fuel gas is supplied by Power & Utilities via pipeline. Chlorine 1 supplies some cell effluent, the rest is produced internally. Chlorine 1 takes all chlorine (gas & liquid) and hydrogen to distribute. Caustic 1 takes all 50% caustic to distribute. ____ Interdependencies with Non-Dow Facilities - Raw Material supplier, Utility Supplier, Final Processing, Sole Supplier, etc. Power can be supplied by the outside grid. Hydrogen to distribute is sent to Air Products just outside the Dow fenceline via pipeline from Chlorine 1. Spare Parts Available for Critical Equipment? Which Critical Equipment? Yes List Top 3 Critical Items 1. C-201A 2. C-520 3. RT-1/2 A/B Spares Available? Yes 5. Changes Since Last Loss Prevention Inspection Significant Changes to Plant Since Last Loss Prevention Inspection? Any Incidents Since Last Inspection? Eliminated undersized spare chlorine compressor, C-201B Sped up chlorine compressor gearbox, GR-201A Replaced cooling tower water / chlorine cross exchange interstage coolers with air / chlorine fin fan interstage coolers New R-123 freon system No incidents._______________ ______________________________________________________________________ Management of Change Program Established? Yes, in compliance with US Area standard and LAD supplement. Significant Capital Projects in Progress or Planned? Give Title and Amount of Capital. CA-2, Gas Turbine Control System $1,500 M CA-2, Acid Area Upgrade $ 846 M CA-2, First Effect Cross Exchanger $ 300 M L/P Review Done/Planned? Done Done Done Date? 11/96 7/96 7/95 (Revised 02/18/94; cmk) 1/8/97; LADibwb A 036989 CONFIDENT PROCESS SAFETY AND LOSS PREVENTION AUDIT Page VI LOSS PREVENTION INSURANCE REPORT 6. Features for Areas in Unit REFER TO PLOT PLAN WHICH IS TO BE ATTACHED. FEATURE AREA X Caustic Area Power Area Cell Area SEPARATION PER LPP 2.2? YES NO YES (CHANGE TOP HEADING NAME IF NEEDED.) Chlorine Hydrogen Ecology Warehouse Area Recovery Area Area YES NO YES YES Office/ Control Room YES FIRE WALLS FOR SEPARATION? HOUR RATINGS? PERCENT OF PLANT 20 30 25 15 5 2 1 2 VALUE? STRUCTURE AREA?(sqft) 130,800 29.5% 108,000 24.3% 67,200 15.1% 50,400 11.4% 24,000 6.4% 26,400 6.0% 4,800 1.0% 32,400 7.3% STRUCTURE HEIGHT?(ft) 50 40 15 50 30 50 30 15 NUMBER OF 3 22434 1 1 OPERATING LEVELS? TYPE OF CONSTRUC TION? (COMBUSTIBLE OR NOT?) OPEN OR CLOSED CONSTRUCTION? (PERCENT OPEN?) FIREPROOFING USED? (TYPE?) NC OPEN NC OPEN NC OPEN NC OPEN NC OPEN NC OPEN PARTIAL PARTIAL CLOSED CLOSED DELUGE & DRAINAGE IN LIEU OF FIRE PROOFING? SPRINKLER C-201A SYSTEMS? WATER DELUGE SYSTEMS? FOAM SYSTEMS? AUTOMATIC OR MANUAL MANUAL TRIGGERING OF SYSTEMS? HYDRANTS NO YES YES NO YES NO NO NO IN AREA? FIRE WATER NO YES YES NO YES NO NO NO MONITORS? INERTING Steam in N2 Purge N2 Purge N2 Purge SYSTEMS? turbine tunnels FIRE EXTINGUISHING Halon in SYSTEMS? (COjHALON, Computer ETC.) Room OTHER FIRE Smoke PROTECTION SYSTEMS? detectorsComputer and Lunch ____________________ Rooms (Revised 02/18/94; cmk) 1/8/97; LAD:bwb HO A 036990 CONFIDENTIAL PROCESS SAFETY AND LOSS PREVENTION AUDIT Page VII 1 OTHER SYSTEMS? YES YES YES YES YES YES YES YES SPECIFY.(portable flra I extinguishers) (Revised 02/18/94; cmk) 1/8/97; LAD.bwb nn A 036991 00NF7DFNT TAt. PROCESS SAFETY AND LOSS PREVENTION AUDIT Page VIII LOSS PREVENTION INSURANCE REPORT 7. Drainage and Containment Type of Impoundment - Remote Pit Vs Dike Dike Volume per LPP 7.6.2.G? Yes Testing of Drainage System? Yes Firewater Containment Considered? N/A Tank separation distances per LPP 7.6.6? Yes Worst Rainfall Considered? Yes, 24'/24hrs Open Trenches or Closed Drains? Open Trenches Plans/Equipment for emptying Pits/Dikes? Yes Drainage Away from Tanks & Equipment? Yes Vapor Suppression of Pit/Dike using Foam? Available from Fire Protection Dept. Impervious Containment Surfaces? Yes Operating Discipline to Keep Pits/Dikes Empty? Yes 8. Tank Storage Types of Tanks (Press. Vessels, Atm. tanks, etc.) Pressure Vessels and Atmospheric Tanks Redundant High Level Alarms? Yes Pressure Relief? PSV's, open vents, seal pots Codes Observed(A.P.I., A.S.M.E. U.L., T.U.V., etc.) API and ASME Interlock Between High Level Alarms & Pumping? No Vacuum Relief? VRD's, open vents, seal pots Vessel Registration Program? Yes With Inspection & Testing? Yes Pressure Vessel Relief Registration? Yes With Inspection & Testing? Yes 9. Electrical and Instrument Conditions Electrical Classifications Areas Well Defined?(See LPP 3.1) Yes El. Classification Drawing Up-To Date? Last Revision Date? Yes, 12/96 Redundant Electrical Feeds? Yes Backup Generators? No Grounding with Inspection Program? Yes, 1Q94. 5 year frequency. Oil Filled Electrical Equipment? Yes Oil Filled Equip. Indoors or Outdoors? Outdoors Cable Penetrations Sealed? Yes Cable Trays Exposed to Potential Fires? No Cable Trays Sprinkler Protected? No Type of Process Control MOD Control? MOD S, pneumatic Process Information Systems? GPI Vax Periodic Review of MOD Program? Yes Audits of MOD Program and Alarms? No 10. Chemical Inventory & Isolation Handling Flammable, Toxic or Corrosive Liquids and/or Gases Are There Flammable Liquids/Gases? Yes Is There Flammable Gas Detection? No Hazard Ratings Shown on Tanks? No Are there Toxic Liquids/Gases? Yes NFPA Ratings or Other Shown? No Are there Corrosive Liquids/Gases? Yes Emergency Block Valves Are EBVs Identified in Drawings?Yes, P&ID's and MOD graphics Frequency of Testing of EBVs? Bi-weekly What are they? Hydrogen and fuel gas (methane) Frequency of Testing Gas Detectors? N/A What are they? Chlorine What are they? Chlorine, Hydrochloric Acid, Caustic, & Sulfuric Acid Are EBVs Identified in Field? Partially Are EBVs Fire Rated in Flammable Service? N/A (Revised 02/18/94; cmk) 1/8/97; LADibwb DO A 03699? C0NFTDFNTTA1. PROCESS SAFETY AND LOSS PREVENTION AUDIT Page IX 1 Other Special Hazards i________________________________ Any Other Special Hazards which Increase Risk of Operation? No (Revised 02/18/94; cmk) 1/8/97; LAD:bwb 00 A 036993 mhftdfnttai' PROCESS SAFETY AND LOSS PREVENTION AUDIT Page X LOSS PREVENTION INSURANCE REPORT 11. Management Considerations Last Loss Prevention Inspection? 11/94 Last Consolidated Audit? 11/94 Other Audits or Reviews of Plant? (e.g. T/C) 6/96 - Tech Center Implementation of Minimum Requirements? Yes Emergency Plans Written for Unit? Yes Written Plans for Fire Protection Impairment? Yes, per LAD S&LP Standard Operator Training Procedures Written & Current? Yes Date of Last Hypothetical Emergency? 4Q96 Critical Instrument Program Established? Yes Operating Procedures Written & Current? Yes Emergency Plans Shared with Other Units & Off Site? NO Testing of Critical Instruments? Yes Preventative Maintenance Program in Place? Yes Reactive Chemicals Program? Yes Date of Last Reactive Chemicals Review? 10/94 Plant Contact Person for Loss Prevention? Gretchen LeBlanc Contractor Safety Program Established? Yes Smoking Regulations & Enforcement? Yes, LAD smoking policy Other Management Programs in Place Affecting Loss Prevention? List - e. g., Fire Protection Inspections, Insurance Inspections S&LP Audits - LAD C-9 Audit Program Safety Committee . Training - IPT Program MOC Program . Behavior Based Safety Program 12. Plant Reliability Production Capacity 720.0 MMIbs/yr Chlorine 839.0 MMIbs/yr Caustic Theoretical Hours/Year for Production Capacity? Hours/Year Loss Due to Outages or Reduced Rates Per Cent of Capacity for Year (1996) 102.4% Chlorine 105.6% Caustic Percent Reliability (Hours Operation at Theoretical Rate) (Total Hours Available) (Revised 02/18/94; cmk) 1/8/97; LAD:bwb 00 A 036994 OONF TDFNTJ4, PROCESS SAFETY AND LOSS PREVENTION AUDIT Page I VIII. LOSS PREVENTION INSURANCE REPORT (Including F&EI Risk Analysis) Contact your Loss Prevention Contact for instructions to assist you in filling out this document. (Revised 02/18/94; cmk) 1/13/97; LAD;bwb 00 * 036995 conftdfnttai PROCESS SAFETY AND LOSS PREVENTION AUDIT Page II_________ __________________________________ LOSS PREVENTION INSURANCE REPORT II. UNIT LOSS PREVENTION INFORMATION 1. Summary of Unit Features and Status Area/Country North America Site Plaquemlne Unit Superintendent G. C. Leblanc Division Louisiana Unit Caustic 1 Location Plaauemlne, LA Building Number/s 2901 Type of Operation Caustic Manufacturing Date 1/7/97 Date of Previous Inspection 2/22/94 Inspected By (from Safety & Loss Prevention) Buck Bailey Inspected by (from Plant) John Dizor Give a written summary including overall evaluation comments, comparison to previous inspection, and summary of recommendations: (Revised 02/18/94; cmk) 1/13/97; LAD:bwb 00 A 036996 cONFTbFNTTAl PROCESS SAFETY AND LOSS PREVENTION AUDIT Page III_________ _________________________________ LOSS PREVENTION INSURANCE REPORT 2. Summary of Ratings and Recommendations for Unit UNIT RISK FEATURES 3. Plant Condition and Appearance 4. Unit Risk Analysis Package 5. Changes Since Last Inspection 6. Features for Areas in Unit 7. Drainage and Containment 8. Tank Storage 9. Electrical & Instrument Conditions 10. Chemical Inventory & Isolation 11. Management Considerations 12. Plant Reliability R = Recommend Upgrading G = Good F = Fair E = Excellent R F G E N RECOMMENDATION A NUMBER(S) NIA = Not Applicable Refer to Guideline for definitions of ratings. For recommendations see Pages_____________________________ Give a brief narrative background summary including history of unit with details on age, construction phases, original plant, etc. The Caustic plant was built in 1958 with one (1) evaporator train and a capacity of 100,000 Ibs/day. In 1967, the second evaporator train was started up and the plant capacity was increased to 1,000,000 lbs/day. The train 1 evaporators were shut down in 1976. In 1984, the fourth effect evaporator was installed raising the capacity to 2,100,000 lb/day. In 1988, an evaporator area capacity upgrade increased plant capacity to 2,500,000 lb/day. 73% caustic production was stopped in 1990. In 1992-93, a new evaporator cross exchanger and expansion project increased the capacity to 3,300,000 lb/day. (Revised 02/18/94; cmk) 1/13/97; LAD:bwb ^ A 036997 CONFrOFNTTAl PROCESS SAFETY AND LOSS PREVENTION AUDIT Page IV___________________________________________ LOSS PREVENTION INSURANCE REPORT 3. General Unit Information Plant Unit Caustic Plant___________________________________ Unit Products 50% Caustic _______ _____ Raw Materials Cell Effluent Operating Days/Week? 7 Operating Hours/Day? 24 No. of Shifts? 2 Plant Condition & Appearance - Description The plant is in very good condition. The product storage tank farm needs a little work on drainage, however. Date 1/7/97 Hours per Shift? 12 4. Unit Risk Analysis Package Items which must be attached as part of Risk Analysis Package ( Check if attached/Give any explanations) Block Flow Sheets Yes Process Description Yes Plot Plan with Areas of Exposure and Protection Features Yes F. & E. 1. Risk Analysis Summary N/A F. & E. 1. Calc. Sheets for Highest MPPD and Highest MPDO & Bl N/A C. E. 1. Summary Sheets N/A Business Interruption Data N/A Replacement Value $82.3 MM Interdependencies with Other Dow Facilities & Which Facilities? Steam and power supplied by Power 1. Condensate returned to Power 1. Cell effluent supplied by Chlorine 1. Interdependencies with Non-Dow Facilities - Raw Material supplier, Utility Supplier, Final Processing, Sole Supplier, etc. None. Spare Parts Available for Critical Equipment? Which Critical Equipment? Yes. List Top 3 Critical Items 1. P-201 2, MP-201 3. P-204 Spares Available? Yes. 5. Changes Since Last Loss Prevention Inspection Significant Changes to Plant Since Last Loss Prevention Inspection? Any Incidents Since Last Inspection? Installed HE-201X, evaporator cross exchanger. Replaced primary salt column, D-205. No incidents. Management of Change Program Established? Yes. Significant Capital Projects in Progress or Planned? Give Title and Amount of Capital. CAU, Tank Farm Sump Upgrade $145 M CAU, Square D Switchgear $350 M E-201 Replacement (expense) $4000 M L/P Review Done/Planned? Planned Planned Done Date? 3/94 (Revised 02/18/94; cmk) 1/13/97; LADrbwb DO A 036998 conftdfnttai PROCESS SAFETY AND LOSS PREVENTION AUDIT PageV____________________________________________ LOSS PREVENTION INSURANCE REPORT 6. Features for Areas in Unit 3EFER TO PLOT PLAN WHICH IS TO BE ATTACHED. (CHANGE TOP HEADING NAME IF NEEDED.) FEATURE AREA X UNLOAD ING/ LOADING TANK FARM CELL EVAPORA EFFLUENT TION STORAGE CAUSTIC FINISHING CAUSTIC STORAGE WARE HOUSE SEPARATION PER Yas Yes Yes Yes Yes Yes LPP 2.27 FIRE WALLS FOR SEPARATION? HOUR RATINGS? PERCENT OF PLANT VALUE? 4.5% 9.0% 5.8% 47.1% 28.1% 4.3% 0.6% STRUCTURE AREA? (sqft) 50,000 400,000 163,000 80,000 73,000 41,000 50,000 STRUCTURE HEIGHT? (ft) 20 50 40 80 30 40 20 NUMBER OF 2 1 2421 1 OPERATING LEVELS? TYPE OF CONSTRUC TION? (COMBUSTIBLE OR NOT?) OPEN OR CLOSED CONSTRUCTION? (PERCENT OPEN?) FIREPROOFING USED? (TYPE?) NC Open NC Open NC Open NC Open NC Open NC Open Partial Closed DELUGE & DRAINAGE IN LIEU OF FIRE PROOFING? SPRINKLER SYSTEMS? DELUGE SYSTEMS? FOAM SYSTEMS? AUTOMATIC OR MANUAL TRIGGERING OF SYSTEMS? HYDRANTS IN AREA? FIRE WATER MONITORS? INERTING SYSTEMS? FIRE EXTINGUISHING SYSTEMS? (COjHALON, ETC.) OTHER FIRE PROTECTION SYSTEMS? OTHER SYSTEMS? 1 SPECIFY. OFFICE/ CONTROL ROOM 0.6% 19,500 15 1 Partial Closed Halon in Computer Room Smoke Detectors (Revised 02/18/94; cmk) 1/13/97; LAD:bwb DO A 03A999 CONFTDFNTTAl PROCESS SAFETY AND LOSS PREVENTION AUDIT Page VI___________________________________________ LOSS PREVENTION INSURANCE REPORT 7. Drainage and Containment Type of Impoundment - Remote Pit Vs Dike Dikes Volume per LPP 7.6.2.G? Yes Testing of Drainage System? N/A Firewater Containment Considered? N/A Open Trenches or Closed Drains? Open Drainage Away from Tanks & Equipment? N/A Plans/Equipment for emptying Pits/Dikes? Yes Vapor Suppression of Pit/Dike using Foam? N/A Tank separation distances per LPP 7.6.6? Yes Worst Rainfall Considered? Per LAD standard. Impervious Containment Surfaces? Block 29 Yes. Tank Farm No. Operating Discipline to Keep Pits/Dikes Empty? Yes 8. Tank Storage Types of Tanks (Press. Vessels, Atm. tanks, etc.) Atmospheric Redundant High Level Alarms? Yes Pressure Relief? Yes Codes Observed(A.P.I., A.S.M.E. U.L., T.U.V., etc.) Yes Interlock Between High Level Alarms & Pumping? No Vacuum Relief? Yes Vessel Registration Program? Yes With Inspection & Testing? Yes Pressure Vessel Relief Registration? Yes With Inspection & Testing? Yes 9. Electrical and Instrument Conditions rr. . , , ... . ... TT~ .. 1 ^ Electrical Classifications Areas Well Defined?(See LPP 3.1) i . ... _ El. Classification Drawing Up- To Date? Last Revision Date? Yes Yes Redundant Electrical Feeds? Yes Backup Generators? No Grounding with Inspection Program? Yes Oil Filled Electrical Equipment? Yes Oil Filled Equip. Indoors or Outdoors? Outdoors Cable Penetrations Sealed? Yes Cable Trays Exposed to Potential Fires? No Cable Trays Sprinkler Protected? N/A Type of Process Control - MOD Control? No TDC, Vax, Modicon Process Information Systems? Vax Periodic Review of MOD Program? No Audits of MOD Program and Alarms? No 10. Chemical Inventory & isolation Handling Flammable, Toxic or Corrosive Liquids and/or Are There Flammable Liquids/Gases? No Gases Is There Flammable Gas Detection? N/A Hazard Ratings Shown on Tanks? No Are there Toxic Liquids/Gases? No NFPA Ratings or Other Shown? No Are there Corrosive Liquids/Gases? Yes Emergency Block Valves Are EBV's Identified in Drawings? Yes Frequency of Testing of EBV's? Per critical instrument program What are they? N/A Frequency of Testing Gas Detectors? N/A What are they? N/A What are they? Caustic Are EBV's Identified in Field? No Are EBV's Fire Rated in Flammable Service? N/A (Revised 02/18/94; cmk) 1/13/97; LAD:bwb DO A 037000 CONFTDFNTTAL PROCESS SAFETY AND LOSS PREVENTION AUDIT Page VII___________________________________________ | Other Special Hazards 1 Any Other Special Hazards which Increase Risk of Operation? No (Revised 02/18/94; cmk) 1/13/97; LAD:bwb Do ^ONF TnS37001 TOfNTT1 PROCESS SAFETY AND LOSS PREVENTION AUDIT Page VIII__________________________________________ LOSS PREVENTION INSURANCE REPORT 11. Management Considerations Last Loss Prevention Inspection? 2/94 Last Consolidated Audit? 2/94 Implementation of Minimum Requirements? Yes Emergency Plans Written for Unit? Yes Operator Training Procedures Written & Current? Yes Date of Last Hypothetical Emergency? 4Q96 Written Plans for Fire Protection Impairment? N/A Critical Instrument Program Established? Yes Other Audits or Reviews of Plant? (e.g. T/C) 6/96 - Tech Center Operating Procedures Written & Current? Yes Emergency Plans Shared with Other Units & Off Site? No Testing of Critical Instruments? Yes Preventative Maintenance Program in Place? Yes Reactive Chemicals Program? Yes Date of Last Reactive Chemicals Review? 10/94 Plant Contact Person for Loss Prevention? G. C. Leblanc Contractor Safety Program Established? Yes Smoking Regulations & Enforcement? Yes, per LAD Smoking Policy Other Management Programs in Place Affecting Loss Prevention? List e. g., Fire Protection Inspections, Insurance Inspections S&LP Audits - LAD C-9 Audit Program Safety Committee Training - IPT Program MOC Program Behavior Based Safety Program 12. Plant Reliability Production Capacity 1,190 MMIbs/yr Caustic Per Cent of Capacity for Year (1996) 79.2% Theoretical Hours/Year for Production Capacity? Hours/Year Loss Due to Outages or Reduced Rates Percent Reliability (Hours.-Qperation at Theoretical Rate) (Total Hours Available) (Revised 02/18/94; cmk) 1/13/97; LAD:bwb DO A 03700? CONFTDFNTTAl AA <?I c c <r N o: c c o n t t o f ^mt PROCESS SAFETY AND LOSS PREVENTION AUDIT Page XI APPENDIX A - OSHA PSM EVALUATION AND DOCUMENTATION OSHA Process Safety Management of Highly Hazardous Chemicals These questions are to ascertain if OSHA 1910.119, Process Safety Management, applies to this facility. 1. Yes [X] No [] Does any process or storage area of this facility have any materials on the attached list in excess of the threshold quantity. 2. Yes [X] No [] Does any process or storage area of this facility have any flammable liquids or gases (flashpoint less than 100F) in quantities greater than 10,000 pounds, except for: Hydrocarbon fuels used solely as a fuel if not part of a process containing another highly hazardous chemical Flammable liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration. If the answer to either question is Yes, then this facility is covered by the OSHA PSM Standard and all plant action items in the following summary need to be evaluated and specific plant needs determined. The OSHA Process Safety Management regulations are consistent with Dow requirements. Compliance with Dow requirements will comply with OSHA PSM. Those that have the listed chemicals in the quantities listed by OSHA need to assure that documentation is in order. (Revised 02/18/94; cmk) 1/3/97; LAD:bwb DO A 037004 conftdfnttai PROCESS SAFETY AND LOSS PREVENTION AUDIT Page XII Appendix A to 1910.119 -- List of Highly Hazardous Chemicals. Toxics and Reactives (Mandatory) This Appendix contains a listing of toxic and reactive highly hazardous chemicals which present a potential for a catastrophic event at or above the threshold quantity. CHEMICAL NAME Acetaldehyde Acrolein (2-Propenal) Acrylyl Chloride Allyl Chloride Allylamine Alkylaluminums Ammonia, Anhydrous Ammonia Solutions (>44% Ammonia By Weight) Ammonium Perchlorate Ammonium Permanganate Arsine (also called Arsenic Hydride) Bis (Chloromethyl) Ether Boron Trichloride Boron Trifluoride Bromine Bromine Chloride Bromine Pentafluoride Bromine Trifluoride 3-Bromopropyne (also called Propargyl Bromide) Butyl Hydroperoxide (Tertiary) Butyl Perbenzoate (Tertiary) Carbonyl Chloride (see Phosgene) Carbonyl Fluoride Cellulose Nitrate (Concentration >12.6% Nitrogen) Chlorine Chlorine Dioxide CAS* 75-07-0 107-02-8 814-68-6 107-05-1 107-11-9 Varies 7664-41-7 7664-41-7 7790-98-9 7787-36-2 7784-42-1 542-88-1 10294-34-5 7637-07-2 7726-95-6 13863-41-7 7789-30-2 7787-71-5 106-96-7 75-91-2 614-45-9 75-44-5 353-50-4 9004-70-0 7782-50-5 10049-04-4 2500 150 250 1000 1000 5000 10000 15000 7500 7500 100 100 2500 250 1500 1500 2500 15000 100 5000 7500 100 2500 2500 1500 1000 (Revised 02/18/94; cmk) 1/3/97; LAD:bwb Do A 037005 CONFIDENT TAl, PROCESS SAFETY AND LOSS PREVENTION AUDIT Page XIII CHEMICAL NAME Chlorine Pentrafluoride Chlorine Trifluoride Chlorodiethylaluminum (also called Diethylaluminum Chloride) 1 -Chloro-2,4-Dinitrobenzene Chloromethyl Methyl Ether Chloropicrin Chloropicrin and Methyl Bromide Mixture Chloropicrin and Methyl Chloride Mixture Cumene Hydroperoxide Cyanogen Cyanogen Chloride Cyanuric Fluoride Diacetyl Peroxide (Concentration >70%) Diazomethane Dibenzoyl Peroxide Diborane Dibutyl Peroxide (Tertiary) Dichloro Acetylene Dichlorosilane Diethylzinc Diisopropyl Peroxydicarbonate Dilauroyl Peroxide Dimethyldichlorosilane Dimethylhydrazine, 1,1Dimethylamine, Anhydrous 2,4-Dinitroaniline Ethyl Methyl Ketone Peroxide (also Methyl Ethyl Ketone Peroxide; Concentration >60%) Ethyl Nitrite Ethylamine Ethylene Fluorohydrin CAS* 13637-63-3 7790-91-2 96-10-6 pQ** 1000 1000 5000 97-00-7 107-30-2 76-06-2 None None 80-15-9 460-19-5 506-77-4 675-14-9 110-22-5 334-88-3 94-36-0 19287-45-7 110-05-4 7572-29-4 4109-96-0 557-20-0 105-64-6 105-74-8 75-78-5 57-14-7 124-40-3 97-02-9 1338-23-4 5000 500 500 1500 1500 5000 2500 500 100 5000 500 7500 100 5000 250 2500 10000 7500 7500 1000 1000 2500 5000 5000 109-95-5 75-04-7 371-62-0 5000 7500 100 (Revised 02/18/94; cmk) 1/3/97; LAD:bwb i;o37, conftdfntjai PROCESS SAFETY AND LOSS PREVENTION AUDIT Page XIV CHEMICAL NAME Ethylene Oxide Ethyleneimine Fluorine Formaldehyde (Formalin) Furan Hexafluoroacetone Hydrochloric Acid, Anhydrous Hydrofluoric Acid, Anhydrous Hydrogen Bromide Hydrogen Chloride Hydrogen Cyanide, Anhydrous Hydrogen Fluoride Hydrogen Peroxide (52% by Weight or Greater) Hydrogen Selenide Hydrogen Sulfide Hydroxylamine Iron, Pentacarbonyl Isopropylamine Ketene Methacrylaldehyde Methacryloyl Chloride Methacryloyloxyethyl Isocyanate Methyl Acrylonitrile Methylamine, Anhydrous Methyl Bromide Methyl Chloride Methyl Chloroformate Methyl Ethyl Ketone Peroxide (Concentration >60%) Methyl Fluoroacetate Methyl Fluorosulfate Methyl Hydrazine Methyl Iodide CAS* 75-21-8 151-56-4 7782-41-4 50-00-0 110-00-9 684-16-2 7647-01-0 7664-39-3 10035-10-6 7647-01-0 74-90-8 7664-39-3 7722-84-1 7783-07-5 7783-06-4 7803-49-8 13463-40-6 75-31-0 463-51-4 78-85-3 920-46-7 30674-80-7 126-98-7 74-89-5 74-83-9 74-87-3 79-22-1 1338-23-4 453-18-9 421-20-5 60-34-4 74-88-4 TQ** 5000 1000 1000 1000 500 5000 5000 1000 5000 5000 1000 1000 7500 150 1500 2500 250 5000 100 1000 150 100 250 1000 2500 15000 500 5000 100 100 100 7500 (Revised 02/18/94; cmk) 1/3/97; LAD:bwb DO A 037007 CONFTDENTIAl PROCESS SAFETY AND LOSS PREVENTION AUDIT Page XV CHEMICAL NAME Methyl Isocyanate Methyl Mercaptan Methyl Vinyl Ketone Methyltrichlorosilane Nickel Carbonly (Nickel Tetracarbonyl) Nitric Acid (94.5% by Weight or Greater) Nitric Oxide Nitroaniline (para Nitroaniline) Nitromethane Nitrogen Dioxide Nitrogen Oxides (NO; NO2; N2O4; N2O3) Nitrogen Tetroxide (also called Nitrogen Peroxide) Nitrogen Trifluoride Nitrogen Trioxide Oleum (65% to 80% by weight; also called Fuming Sulfuric Acid) Osmium Tetroxide Oxygen Difluoride (Fluorine Monoxide) Ozone Pentaborane Peracetic Acid (Concentration >60% Acetic Acid; also called Peroxyacetic Acid) Perchloric Acid (Concentration >60% by weight) Perchloromethyl Mercaptan Perchloryl Fluoride Peroxyacetic Acid (Concentration >60% Acetic Acid; also called Peracetic Acid) Phosgene (also called Carbonyl Chloride) Phosphine (Hydrogen Phosphide) Phosphorus Oxychloride (also called Phosphoryl Chloride) CAS* 624-83-9 74-93-1 79-84-4 75-79-6 13463-39-3 7697-37-2 10102-43-9 100-01-6 75-52-5 10102-44-0 10102-44-0 10544-72-6 7783-54-2 10544-73-7 8014-94-7 TQ** 250 5000 100 500 150 500 250 5000 2500 250 250 250 5000 250 1000 20816-12-0 7783-41-7 10028-15-6 19624-22-7 79-21-0 100 100 100 100 1000 7601-90-3 594-42-3 7616-94-6 79-21-0 5000 150 5000 1000 75-44-5 7803-51-2 10025-87-3 100 100 1000 (Revised 02/18/94; cmk) 1/3/97; LAD.bwb 03700B DO A OONF"1 OFNTT Al PROCESS SAFETY AND LOSS PREVENTION AUDIT Page XVI CHEMICAL NAME Phosphorus Trichloride Phosphoryl Chloride (also called Phosphorus Oxychloride) Propargyl Bromide Propyl Nitrate Sarin Selenium Hexafluoride Stibine (Antimony Hydride) Sulfur Dioxide (liquid) Sulfur Pentafluoride Sulfur Tetrafluoride Sulfur Trioxide (also called Sulfuric Anhydride) Sulfuric Anhydride (also called Sulfuric Trioxide) Tellurium Hexafluoride Tetrafluoroethylene Tetrafluorohydrazine Tetramethyl Lead Thionyl Chloride Trichloro (Chloromethyl) Silane Trichloro (Dichlorophenyl) Silane Trichlorosilane Trifluorochloroethylene Trimethyoxysilane CAS* 7719-12-2 10025-87-3 106-96-7 627-3-4 107-44-8 7783-79-1 7803-52-3 7446-09-5 5714-22-7 7783-60-0 7446-11-9 7446-11-9 7783-80-4 116-14-3 10036-47-2 75-74-1 7719-09-7 1558-25-4 27137-85-5 10025-78-2 79-38-9 2487-90-3 JQ** 1000 1000 100 2500 100 1000 500 1000 250 250 1000 1000 250 5000 5000 1000 250 100 2500 5000 10000 1500 * Chemical Abstract Service Number ** Threshold Quantity in Pounds (Amount necessary to be covered by this standard.) Appendix B to 1910.119 - Block Flow Diagram and Simplified Process Flow Diagram (Nonmandatorvl (Revised 02/18/94; cmk) 1/3/97; LAD:bwb DO CO/Vp ? 37009 T0fNTT61 PROCESS SAFETY AND LOSS PREVENTION AUDIT Page XVII DEPARTMENT VPP/OSHA PROCESS SAFETY MANAGEMENT PROTOCOL (Refer to the OSHA PSM Communication) Compliance to OSHA regulation requirements is a basic tenant for participation in OSHA's Voluntary Protection Program. All elements of the OSHA Process Safety Management regulation must be in compliance as a prerequisite for VPP participation. I. EMPLOYEE PARTICIPATION A. Develop a written list of those safety activities that involve employees (examples in the OSHA PSM communication). Be sure employees participate in appropriate Process Hazard Analysis activities. B. Document the employee's participation in those programs. C. Provide access to Process Hazard Analyses. II. PROCESS SAFETY INFORMATION A. Review plant status on the following Operating Discipline sections. Process Technology Process Risk Management Industrial Hygiene B. Review the OSHA PSM communication and document the minimum process safety information that is required. III. PROCESS HAZARD ANALYSIS (Refer to OSHA PSM Communication) A. Retain the documentation of each Process Hazard Analysis. B. Assure that recommendations from the process hazard analysis are resolved in a timely manner and the resolution is documented. C. Communicate the results of the Process Hazard Analysis to affected employees. (Revised 02/18/94; cmk) 1/3/97; LAD:bwb A 037010 CONFIDENT! Al. PROCESS SAFETY AND LOSS PREVENTION AUDIT Page XVIII IV. OPERATING PROCEDURES A. Assure that operating procedures are reviewed at least annually and certified. (See Texas Operations Safety Standard T-13; III. E, F, G.) B. Assure that operating procedures include the elements listed in the U.S. Area Operating Discipline Standard and the OSHA PSM communication. V. TRAINING A. Assure that all operating employees in their job as of May 26, 1992, have been certified. B. Assure that new employees are trained as per the U.S. Area Operating Training Standard and the training is documented. VI. CONTRACTORS Assure that plant contractor orientation and safety communication is documented. VII. PRE-START UP SAFETY REVIEW A. Assure that projects have pre-start up reviews. B. Assure that resolution of the finding of these reviews are documented. (Revised 02/18/94; cmk) 1/3/97; LAD.bwb DO A 037011 CONFIDENT! Al ^ <t c t; ^f cc u- c PROCESS SAFETY AND LOSS PREVENTION AUDIT Page VIII APPENDIX B - PROCESS SAFETY AND LOSS PREVENTION FIELD VERIFICATION The Process Safety and Loss Prevention auditor will evaluate the following items during a field inspection. Answer all questions. Explain any questions answered "No" in the Comment Sections. A. OPERATING DISCIPLINE 1. Yes [X] No [] Is process safety information complete and available to the operating personnel? (Examine Sample Documents for Operating Discipline Questions 4A, 4B, 4C) 2. Yes [X] No [] Are operating procedures complete and available to the operating personnel? (Ask Control Room Operators) (Examine samples of Operating Discipline Questions 5C, 5D) 3. Yes [X] No [] Are operating procedures reviewed annually with documentation of the review? (Ask Operators) (Examine Samples to Verify Updating) Comments: B. DRAINAGE AND CONTAINMENT 1. Yes [X] No [] Is drainage generally away from the process area? (Field Observation) 2. Yes [] No [X] Are tanks located far enough away from dike walls so that a leak will not spray over the wall? (Field Observation) (Revised 02/18/94; cmk) 1/3/97; LADibwb ft o r 3?0^ PROCESS SAFETY AND LOSS PREVENTION AUDIT Page IX 3. Yes [X] No [] Are dikes without visible defects? (Field Observation) 4. Yes [] No [X] Area all pumps fitted with deadhead protection (i.e.; temperature or flow)? (Field Observation) Comments: C. WAREHOUSE STORAGE 1. Yes [X] No [] Are materials stored so as not to restrict the distribution of fire water from a sprinkler head (at least 18")? (Field Observation) 2. Yes [X] No [] Are empty pallets stacked less than eight feet in height? (Field Observation) Comments: D. BUILDING LOCATION AND FIRE RISK 1. Yes [X] No [] Are buildings of non-combustible construction? (Field Observation) 2. Yes [] No [X] Are fire doors, tracks, hardware and fusible link systems in good condition to allow closing? (Observe Door Operation) Comments: AV'4 (Revised 02/18/94; cmk) 1/3/97; LAD:bwb DO A 037014 CONFIDENTIAL PROCESS SAFETY AND LOSS PREVENTION AUDIT PageX E. ELECTRICAL SYSTEMS 1, Yes [X] No [] Are electrical enclosures in classified areas properly assembled? (Field Observation) 2. Yes [] No [X] Are there major cable trays routed through areas where flammable liquids can pool? (Field Observation) 3. Yes [] No [X] Are cable wall penetrations adequately sealed? (Observe Penetrations in Control Room and Switchgear Room) Comments: F. FIRE PROTECTION SYSTEMS 1. Yes [X] No [] Are fire protection systems in good condition? (Field Observation) 2. Yes [] No [X] Is structural steel and tank supports protected with deluge protection or fire proofing? (Field Observation) 3. Yes [X] NO []Is pipe insulation on hot lines in good condition? (Field Observation) Comments: 2. */* (Revised 02/18/94; cmk) 1/3/97; LADibwb 00 A 037015 OONFTDFNTTAL PROCESS SAFETY AND LOSS PREVENTION AUDIT Page XI __________ G. FIRED EQUIPMENT 1. Yes [] No [X] Is fired equipment adequately separated from the other process hazards (LPP 2.2.6)? (Field Observation) Comments: H. EMERGENCY BLOCK VALVES 1. Yes [X] No [] Are all incoming and outgoing headers handling flammable or toxic materials fitted with EBV's? (Field Observation, Ask Operators) (Revised 02/18/94; cmk) 1/3/97; LAD:bwb DO A 037016 CONFTDFNTTAl PROCESS SAFETY AND LOSS PREVENTION AUDIT Page XII 2. Yes [] No [X] Are all vessels handling flammables or combustibles with a flashpoint below 140F fitted with an EBV on the bottom of the tank (within 4 feet)? (Field Observation, Operator Interview) (Fire Rated Valve) Comments: I. TANK FARMS 1. Yes [X] No [] Is water routinely able to get between the tank foundation and bottom of tank? (Field Observation) 2. Yes [] No [X] Is soil in contact with the tank exterior shell? (Field Observation) 3. Yes [X] No [] Are tank grounds in place? (Field Observation) J. PRESSURE VESSELS AND RELIEF DEVICES 1. Yes [X] No [] Do file folder(s) on each pressure vessel (Pressure Containing Equipment) have the registration form, calculations, inspection and status change reports, spec sheets, record prints, U-l forms, mill tests, and visual inspections? (Examine a random 5% sample ofpressure vessel folders for complete records.) 2. Yes [X] No [] Are design calculations on all pressure relief devices done? (Examine a random 5% sample of folders for calculations, specifications and piping isometric sketch.) 3. Yes [X] No (] Are glass devices and expansion joints in potentially hazardous service registered and routinely inspected? (Examine a sample of documentation folders for registration and inspection frequency.) (Revised 02/18/94; cmk) 1/3/97; LAD:bwb DO A 037017 oonftofnttai PROCESS SAFETY AND LOSS PREVENTION AUDIT Page XIII K. CRITICAL INSTRUMENTS 1. Yes [X] No [] Do written test procedures exist? (Examine Several Examples) Yes [X] No [] Are they being used? 2. Yes [X] No [] Is testing documentation current? (Examine Testing Schedule vs. Completion) 3. Yes [X] No [] Do test procedures test from the initiating device through final control element? (Have one of the I&E technicians who does the testing explain a procedure.) L. TANK INSTRUMENTATION 1. Yes [X] No [] Are storage tanks protected with redundant level indicating devices? Yes [X] No [] Are storage tank level indicators on separate computer boards? (Verify by having I&E technician show audit example of redundant devices on storage tanks.) 2. Yes [] No [X] Are automatic actions taken from these high level devices? (Have I&E technician explain another operation.) (Revised 02/18/94; cmk) 1/3/97; LAD-.bwb DO A 007018 OONFTDFNT T AL AtP&jpt* O' _ ^ <i PROCESS SAFETY AND LOSS PREVENTION AUDIT Page XIV APPENDIX C Process Safety and Loss Prevention Resource Materials Guidelines for Burner Management Systems for Boilers & Process Furnaces June 1993 Guidelines for Safety, Loss Prevention and Security Audits November 1989 Guidelines for Emergency Planning September 1985 Guidelines for a Motor Vehicle Accident Prevention Program May 1992 Guidelines for Accident Investigation November 1985 Fire and Explosion Index, 7th Edition (At Printer)1994 Guidelines for Public Warehouse Rating and Risk Analysis January 1990 Guidelines for Determining Dust Hazard Potential October 1989 Guidelines for A Reactive Chemicals Program, 2nd Edition Reprinted November 1990 Guidelines for Business Data & Process Control Computer Systems March 1982 U.S.A.-2 Safety Standard Management of Change February 1992 Operating Discipline Standard for Operating Units of Dow U.S.A. January 1992 Minimum Requirements June 1989 Chemical Hazard Engineering Guideline Distribution Emergency Response Process 1993 ? Process Risk Management Guidelines for Facilities and Distribution 1994 Loss Prevention Principles 1991 Chemical Exposure Index September 1993 NFPA Codes Continuous Site Specific Reactive Chemicals Manual - Hazard Evaluation Procedure Manu il September 1993 (Texas Operations Only) Site Specific Safety Standards and Safety References Continuous OSHA Process Safety Management of Highly Hazardous 1992 Chemicals, Explosives and Blasting Agents Computer Security Policies & Procedures February 1990 (Revised 02/18/94; cmk) 1/3/97; LAD:bwb 00 A 0370P0 conftdfntiai STlSK A>j4lV-av'aoc.age PROCESS SAFETY AND LOSS PREVENTION AUDIT Page VIII RISKANAL YSIS PA CKA GE Reference: LPP 1.3.3 The Risk Analysis Package and the Loss Prevention Insurance Report will be sent to the insurance company broker and to Corporate Loss Prevention. Sufficient information should be given concerning the plant to allow the insurance companies to fully understand the process safety and loss prevention aspects of the plant. If there are any questions, contact Loss Prevention. The technology center can help ensure that no proprietary information is included. The following should be the contents of the Risk Analysis Package: 1. Fire and Explosion Index (F&EI) calculation sheets for the highest F&EI, Maximum Probable Property Damage (MPPD) and Maximum Probable Days Outage (MPDO). 2. Loss Control Credit Factors that apply to the plant. (Back of F&EI Form) 3. Plant Risk Analysis Summary Sheet of F&EI calculations. 4. Block plot plan showing areas of exposure circles for the higher risk process unit areas based on F&EI calculations.. 5. Simplified process flowsheet. (Include Emergency Block Valve Location) 6. Summary sheets covering the following information: A. Raw materials used with source and means of receipt. B. Final product distribution means. C. Availability of critical equipment. D. Essential utilities and reliability. E. Replacement value of the plant. F. Interdependence with other Dow facilities. A copy needs to be sent to your Loss Prevention Representative and it will be forwarded to Corporate Loss Prevention and the insurance company. (Revised 02/18/94; cmk) 1/3/97; LAD:bwb 'jON PROCESS SAFETY AND LOSS PREVENTION AUDIT Page I Block 36 - Chlor-Alkali 2 Process Summary Raw material for the chlor-alkali plant is brine supplied by pipeline from salt domes. The initial operation is an electrolytic reaction using diaphragm cells. Products of this reaction are chlorine gas, hydrogen, and weak caustic cell effluent. Two independent circuits of four cell series are used. Cell power is supplied by two 45 megawatt Westinghouse W-501A gas turbine driven generators. Each gas turbine generator is coupled to a steam turbine for startup and power augmentation. Backup power is available through a division tie using two 27 MVA regulating transformers. The cell power turbines are not synchronized to the power grid. The wet chlorine gas from the cells from the cells is dried, purified, liquefied, and evaporated in a single train system to produce 100% gas and liquid chlorine. The plant produces 1.9> million pounds of chlorine per day. 100% chlorine gas is piped to the division distribution header, and liquid chlorine is sent to the chlorine plant for loading into tank cars. Fifty six thousand pounds per day of hydrogen from the cells is scrubbed, compressed, and cooled in the hydrogen recovery area. The hydrogen is piped to the division header where the chlorine plant handles distribution to internal and external customers. Cell effluent is processed in a multiple effect evaporator train to reach a concentration of 50% caustic and remove .alt. The caustic is then cooled and filtered to further reduce the salt concentration. 2.3 million pounds per day of caustic are transferred to the division caustic plant where it is shipped by tank truck, tank car, or marine carriers. This plant typically runs at full capacity with load changes absorbed by the chlorine plant and caustic plant. There are no automatic sprinklers at CA2, but monitor nozzles are located throughout the block to cover all potential fire hazards. A manual sprinkler exists on the chlorine compressor to combat a chlorine and iron fire if necessary. Spare equipment is available for all major equipment. A gas turbine outage can be covered using backup power and steam from the division header until repairs are made. Caustic centrifuge has an installed spare. Rotating assemblies are stocked for the freon compressor and starter turbines. A spare rectifier transformer is stored in the Texas Division (Revised 02/18/94; cmk) 1/8/97; LAD:bwb PROCESS SAFETY AND LOSS PREVENTION AUDIT Page II BUSINESS INTERRUPTION SUMMARY-CHLOR ALKALI 2 A. Raw Material Supply Brine is supplied by pipeline from salt dome storage. Hydrochloric, and Sulfiuric acid are supplied by pipeline from other plants in the division. B. Product Shipping Chlorine production is delivered to Louisiana Division user plants by a pipeline distribution network, and tank cars are loaded at the chlorine plant for external customers. Caustic is pumped by pipeline to the caustic plant for distribution by tank truck, tank car and marine shipping. Hydrogen is sent by pipeline to the chlorine plant for distribution to internal and external customers. C. Essential Utilities Steam, Power, and Fuel Gas are all supplied by division network systems. D. Critical Equipment Spare equipment and parts are available in the Louisiana Division and other Dow locations, i. Loss Control Systems Fire Fighting water is supplied by the division system which includes nine diesel pumps, each capable of supplying 5000 GPM at 100 PSIG. These pumps start automaticaly on low pressure in the water header. Normal water supply is by electric pumps at the water treating plant that deliver a capacity of 3500 GPM. F. Replacement Cost $99 MM 1996 (Revised 02/18/94; cmk) 1/8/97; LAD:bwb 00 A 037024 confjdfnt TAI DO A 0 3 7 0 2 5 CONF ID F N T T A l PLANT EBV SYSTEM STEAM PURIFICATION FREON GAS LIQUEFACTION' (liquid r> o z> zo n -i i> z> T] O Z H Ni ^O I> \) - ?- LIQUID DISTRIBUTION r --------- STEAM REFLUX LIQUID STORAGE 1J LIGHTS REMOVAL GAS USERS TAILGAS REMOVAL TAILGAS REMOVAL JFD 10/94 1*1 A " : Itrarra inum m* rntgatmrd. j *U #***' 1 ^ *h 3!1 ---- i, mini* --rl <> *" -- vm AO MuWynim K2S9 L a=d_________ &}==Js TH DOW CMIMICAL MHMMIY MB AHnn twill OiniriCIIHK ^. ,Hi, 1 S' 1 B17 t. PROCESS SAFETY AND LOSS PREVENTION AUDIT Page IX___________________________________________ CAUSTIC PLANT PROCESS DESCRIPTION The Caustic 1 plant is made up of an evaporation train, a salt removal area and a finishing area. The evaporators are used to concentrate the caustic to 50%. The salt removal area consists of salt columns, centrifuges, and salt settlers which are used to process. The finishing end of the plant cools the caustic with heat exchangers and removes salt to production specifications in the sparkler filters. A caustic evaporator train is made up of four bodies configured as a triple-double evaporator system with a primary salt removal and a condensate collection system. The evaporator bodied are referred to as the fourth effect, third effect, second effect, and first effect. After the evaporators, salt, and sulfate are removed at the centrifuges. Additional processes are l)cooling and 2)final filtration in the Sparkler filters. The boiler grade condensate is returned to the Power plant for use in steam generation. As the cell effluent is increased in concentration, solid salt drops out of solution in the evaporators because of reduced solubility. This salt is collected in a settling tank by use of cyclones. From here it is fed to a salt column. Caustic concentration in the salt slurry from the bottoms of the salt column is monitored and controlled by the addition of condensate. Salt slurry is sent to the Chlorine plant where it is fed back to the chlorine cells. The product from the evaporator train is fed to a salt settling tank. The overflow is fed to a forwarding tank and the bottoms is fed to the centrifuges. The function of the centrifuge is to remove the salt and the sulfate. The product from the centrifuge goes to the forwarding tank and the slurry is sent to the sulfate salt column. This column removes the caustic from the salt with condensate spargers. Salt is sent to the Chlorine plant and caustic is sent to the user feed tank. Caustic leaving the centrifuges goes through two precoolers before entering the caustic cooling tank. The precoolers are used to cool the 50% caustic and preheat the cell effluent feed to the evaporators. Caustic is pumped through a set of heat exchangers with chilled water as the cooling media and into the sparkler feed tank. The sparkler filter operation is made up of six filters. After the sparkler filter operation the finished caustic is stored in the finished 50% storage tanks. (Revised 02/18/94; cmk) 1/13/97; LADibwb DO A 037079 OONFTDFNTTAl PROCESS SAFETY AND LOSS PREVENTION AUDIT PageX____________________________________________ BLOCK 29--CAUSTIC This is a production block. RAW MATERIALS Cell Effluent from Chlorine (Block 26) and from Chlor-Alkali II (Block 36) is received here via pipeline, and by typical evaporation processes, concentrated. FINISHED PRODUCT 288.75 MM lbs/quarter of 50% regular grade caustic are produced here. LOADING & SHIPPING 50% caustic and cell effluent are distributed to division users via pipeline. 50% regular grade caustic is shipped to customers by tank truck, tank car, barge, and ship. UTILITIES Steam is supplied by the division Power Plant. Electrical power is supplied by two independent power feeder lines, also from the division Power Plants. Process water is supplied from the division Water Treating Plant. River water and compressed air are supplied from Caustic owned equipment. Caustic supplies compressed air to the division air network. This network serves as Caustic's source of backup air when needed. Caustic also supplies river water to Chlorine(Block 26). Hydrochloric acid for pH control is supplied via pipeline from the Solvents Plant(Block 16). CRITICAL EQUIPMENT Non-spared critical equipment includes the first, second, and fourth effect evaporator recirculation pumps. LOSS CONTROL SYSTEMS The probability of fire in this block is very low. Besides fire extinguishers, the only fire prevention/control system in the block is smoke detectors in the control room, motor control centers, and computer room. The computer room has a Halon fire protection system. The block is completely contained. All spills and runoff drain to a trench system with sump pumps that transfer the liquid to a holding tank. (Revised 02/18/94; cmk) 1/13/97; LADibwb DO A 037030 CONFTDFNTTAl Col Effluent {incoming} Cal Effluent (incoming} X Sample Pt. Evaporation Sulfate Removd ^ X Salt Salt Removal Distribution aOWCHT.Ge>MLS:X)/t3/95 MAYFLOWER ROAD )0 CAUSTIC 1 LAD NPDES LA 0003301/LWDPS WP 1561 FORM SFrTIflM III