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Date of Report: DOW NORTH AMERICA CONSOLIDATED AUDIT PROGRAM Dow U.S.A. The Dow Chemical Company 6/4/95 Methanes Plant P 0 Box 150 Piaouemme, Louisiana 70765-0150 Superintendent: Don Taylor, Bldg. 4601 cc: Roddey Peebles, Bldg. 1601, LAD Maurice Oubre, Bldg. 6650, LAD Chris Messelt, Bldg. 3502W, LAD John Murphy, Bldg. 101, Freeport, TX Buck Bailey, Bldg. 3301W, LAD Vick McMurry, Bldg. 4601, LAD Terry Leigh, Bldg. 1601, LAD Enclosed are the recommendations from the various audits for your response. According to the Dow North American Area Consolidated Audit Program Guidelines and the OSHA Process Safety Management (PSM) standard 1910.119, you must develop an implementation plan as a response to the recommendations. The plan must include the name(s) of the employee(s) assigned to each action item along with an expected completion date for each item. Your plan must be reviewed and approved by the area Major Manager by July 7, 1995. Please note that efforts have been made by the Functional Audit Teams to help prioritize each recommendation. They will be identified as: M = Must Do, (based on compliance issues, government regulations, Dow policies or S&LP) and HR = Highly Recommended, (necessary to mitigate an anticipated or potential hazard). It is the responsibility of the plant/department supervision to communicate the results of the consolidated audit to all employees. Communication must include the results of the Process Hazard Analysis. PHA's include the Reactive Chemicals, Chemical Exposure Index (CEI), Process Safety and Loss Prevention/Fire/Bumer Management audit and the Employee Survey Results. This must be completed within 90 days after the audit and documented. Please send your approved implementation plans to Connie Kalencki, Bldg. 3502W by July 15,1995. We will forward a copy to members of the Core Audit Team and the appropriate section to the Functional Team Leaders. Enclosed Audit Recommendations: 1. LAD Process Hazard Analysis 2. Laboratory Audit 3. Electrical Reliability Audit 4. Reactive Chemical Audit 5. Security Audit 6. Hazardous Materials Trans. Audit 7. Loss Prevention/Fire Audit 8. Safety Audit The Occupational Health Audit recommendations will follow in a separate audit report. Howard Wilkinson, Administrator LAD Consolidated Audit Program DOW CONFIDENTIAL Payc 1 A 032378 CONFIDFNTTA! LAD PROCESS HAZARD ANALYSIS Recommendations: 1. Communicate results of the Consolidated Audit to plant personnel within 90 days after the audit report date. The communication must include a brief summary of the Reactive Chemical Review, Employee Survey results, Chemical Exposure Index results, Safety & Loss Prevention/Fire/Bumer Management Audit results. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 2 HR = Highly Recommended DO A 032379 CONFIDENTIAL OCCUPATIONAL HEALTH AUDIT 0 AUDIT TEAM: Dave Albert, Jackie Paul PLANT IH CONTACT: Mike Young WRITER: Maralee Marchant M = Must-Do DOW CONFIDENTIAL Page 3 HR = Highly Recommended DO A 032380 OONFTDFNTTAL LABORATORY AUDIT (April 5, 1995 - 10:30 a.m. - 12:00 p.m.) AUDIT TEAM: Howard Wilkinson, David Smith, A1 Ribes PLANT CONTACT: Terry Vavassuer WRITER: Howard Wilkinson, A1 Ribes The Methanes Plant laboratory seems to be running well since the last audit. All action items from previous audit have been completed and closed out. Cabinets are labeled and emergency shut-offs are in place for GC's. Recommendations: M 1. Remove all re-agents that are not needed in the process (calcium y carbide). Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 2. Clean out all spray paint cans. ActU i Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 3. Install sign on refrigerator door "Not Explosive Proof'. ^ Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 4 HR = Highly Recommended DO A 032381 CONFIDENTIAL ELECTRICAL RELIABILITY AUDIT SUMMARY (February 1995) AUDIT TEAM: Mike Gee PLANT CONTACT: WRITER: Mike Gee The electrical reliability audit for Chlorinated Methanes was conducted in February, 1995 as per the Five Point Electrical Reliability Program. Those items identified with an index of 4 or higher in the Electrical Reliability report need some attention and require a response. Please refer to the report. Condition of electrical assets of Methanes show a commitment to continuous improvement. The audit team Finds that CMP has an overall good condition. Recommendations: HR 1. Ten - fifteen percent of motors have grounds loose or not grounded to frame. Ground Motors pex L7C-0101-00 par 5.4. Train block electrical personnel in proper grounding practices. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 2. Ninety percent of cables in field junction box have the overall shield ungrounded. Connect overall shields to ground. Train block Instrument and Electrical personnel in proper grounding practices. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Musi-Do DOW CONFIDENTIAL Page 5 DO A 03238? CONFIDENT! A1 HR = Highly Recommended M 3. Safety Electrical One Line diagram is not current or correct. Correct SEOLD. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 4. Bus system not identified by SEOLD I.D. Label all switchgear bus with SEOLD I.D. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 6 HR = Highly Recommended DO A 037383 C.ONFTDFNTTAl REACTIVE CHEMICALS AUDIT Thursday, November 10, 1994 (8:30 a.m. to 11:00 a.m.) AUDIT TEAM: Gerald Wagener, Don Jones, John Monroe, Joe Schell, Buck Bailey, Scott Hanrahan, Mark Mitchell, Seb Corbino PLANT CONTACT: Kevin Kelley ATTENDING: Don Taylor, Julie Clebert, Joe Schell, Gary Rizzo, Buck Bailey, Vic McMurray, Jim Haney, Gerald Wagener, Barry Young, Kevin Kelley, Howard Wilkinson WRITER: Gerald Wagener RECOMMENDATIONS FROM REACTIVE PRE-CONSOLIDATED AUDIT REVIEW (served as new superintendent review) Thursday, November 10, 1994 (8:30 a.m. to 11:00 a.m.) M 1. Concerning the inadvertent use of titanium parts in dry chlorine: a. Add a statement to the block safety indoctrination package on the ^ reactive chemical hazards of using titanium part's in dry chlorine service. b. Consider adding a checksheet that addresses this hazard to maintenance procedures for equipment used in chlorine service. ^ Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 2. Concerning the reactive chemicals review slides for the Thermal Chlorinator: Add "Evacuation of personnel from reactor area during v/ start-up" to the lines of defense for avoiding injuries due to a possible deflagration/detonation Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 7 A 032384 CONFIDENTIAL HR = Highly Recommended M 3. Consider the following scenario and make sure appropriate safeguards are in place to avoid a runaway decomposition: D-l Tar pot is blocked in and 235# steam flow does not shut off. If the ^ decomposition temperature is not known ARC data should be generated. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 4. Review the materials of construction in the sulfuric acid demister and ^ make sure that they are compatible over the range of temperature and % sulfuric acid that will be encountered in normal and upset conditions. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date RECOMMENDATIONS FROM CONSOLIDATED AUDIT FINAL WRAP-UP MEETING Monday, April 18, 1995(10:30 a.m. to 11:30 a.m.) HR 1. There is no.reactive chemicals- contact person for the Methanes plant. This responsibility should be assigned to someone. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 2. Consider developing a reactive chemicals IPT module and include all the major worst case scenarios and lines of defense. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M Must-Do DOW CONFIDENTIAL PagcS 03?3B5 DO r.ONF't HR * Highly Recommended HR 3. Summaries of reactive chemicals reviews including the worst case scenarios and lines of defense should be reviewed with the outside operators and boardmen. ^ Action TakenfTo Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 4. Review job procedures and if there is a reactive chemical hazard associated with the job being performed consider adding a paragraph ^ listing the hazard. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 5, Train operators on the reactive hazard of inadvertently using a titanium part in dry chlorine service. Most did not know when J interviewed. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 6. Plant communications book co"uld be an excellent means for. communicating current reactive chemical issues. We only found one entry pertaining to reactive chemicals (Sealants database information from Kevin Kelley). Information on the incident involving methyl chloride in a tank car with aluminum baffles could not be located. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 7. Worst case scenarios for the various sections of the plant are not included with the procedures. Consider either including them with the procedures or include them in the new Dynamic Data Display system. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 9 HR = Highly Recommended DO A 033386 CONFTDFNTTAI HR 8. R-250 procedures for dumping spent catalyst: The specific hazard of spontaneous ignition of organic material on the spent alumina is not listed. The comment in the procedures is "because catalyst is so dry, we need to spray water mist on the catalyst as it is being sucked from the reactor to comply with landfill regulations." ^ Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 9. PSA carbon change out procedures need to be reviewed and the ^ flammability hazard of dry carbon in air need to be included. ' Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 10. A listing and summary of reactive chemicals data was not available for ^ the Methanes plant. This needs to be done and we recommend that the Tech Center assists. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 10 HR = Highly Recommended DO A 032387 CONFIDENTIAL SECURITY AUDIT SUMMARY (April 18, 1995) AUDIT TEAM: A1 Lott PLANT CONTACT: Bruce Miles WRITER: Howard Wilkinson/Al Lott Employees challenge strangers in their work areas. A sign-in/out log is available for visitors to the plant in the office area. Emergency communications and alert systems are in place and working well. Keep up the good work. Recommendations: No Recommendations at this time. M = Musi-Do DOW CONFIDENTIAL Page 11 HR = Highly Recommended DO A 033388 CONFIDFNTTAl HAZARDOUS MATERIALS TRANSPORTATION REVIEW (HMTR) AND DISTRIBUTION FACILITIES ASSESSMENT (DFA) AUDIT TEAM: Dean Smith PLANT CONTACT: WRITER: Julie Clebert Dean Smith On April 13, 1995 an HMTR/DFA was conducted at the CMP as part of the Louisiana Division Consolidated Audit Program. Chemicals of concern: Amylene (1-Pentene) Carbon Tetrachloride Chloroform Cyclohexane Methanol Methyl Chloride Methylene Chloride Sulfuric Acid DRI# -----j- 4 3 3 3 4 3 TRANSPORTATION MODE: Rail Hwy Marine Pkg R TT TT R/ISO/TT R R TT Y Y Y PRODUCT (P) FEED (F) F P F F P P F HMTR QUESTIONNAIRE: All areas reviewed are in excellent shape ! Continue development of information resources for the KPC ''notebook". Resources should include MSDS, ER/TED, T.I.M.E. info., Temperature vs Pressure curves, clean-up or neutralizing techniques reactivity info and/or source(s). M = Musi-Do DOW CONFIDENTIAL Page 12 HR = Highly Recommended D A 032389 CONrrDFNTTAI DISTRIBUTION FACILITIES ASSESSMENT D.O.T./Dow Compliance Area: Ml. At the time of the plant walk-through, the training coordinator was out of town for several days; please send a copy of one of your loaders and E/R team members training records for the 1994 and YTD training. HR 2. Please contact me either by phone or E-mail whenever you have an incoming shipment (residue or load) of hazmats that has a securement problem - especially if it happens to be shipped from another Dow facility. All other areas are in great shape. Thanks to Julie Clebert for all of her efforts to make this a very thorough and efficient review. M = Must-Do DOW CONFIDENTIAL Page 13 HR = Highly Recommended no A 033390 CONFIDENTIAL LOSS PREVENTION/FIRE/BURNER MGMT./CEI REVIEW (Tuesday, April 18, 1995) AUDIT TEAM: Kevin Alexcee, Bill Franklin, Roddey Peebles PLANT CONTACT: Jim Haney, Kevin Kelley, Steve Ledoux ATTENDING: Don Taylor, Julie Clebert, Kevin Alexcee, Gary Rizzo, Buck Bailey, Vick McMurray, Jim Haney, Stephen Ledoux, Kevin Kelley, Howard Wilkinson, Barry Young WRITER: Buck Bailey, Kevin Alexcee Following is a list of comments and recommendations resulting from the Consolidated Audit / Loss Prevention audit: The plant is generally in good condition with respect to Loss Prevention design, due in part to the recent plant capital expansion. Many of the current Loss Prevention design considerations were incorporated into that project. FLAMMABLE MIXTURES HR 1. Review the low pressure flammables storage tanks to assure that the controls and monitoring is adequate to prevent oxygen contamination. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 14 HR = Highly Recommended 00 A 032391 confidential FACILITY SITING - DRAINAGE HR 1. When the sprinkler system is next tested, verify that the surface drainage is adequate to avoid area flooding. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date EQUIPMENT / BUILDING LOCATION AND FIRE RISK HR 1. Review cable tray passage ways to be sure they are properly sealed to comply with good electrical installation guidelines. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 2. Review the possibility of installing a combustible gas monitor in the fresh air intake to office and control room. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date CHEMICAL EXPOSURE INDEX (CEI) HR 1. Review the layout of chlorine area monitors to reconsider the need for additional installations, specifically in the NW quadrant of the plant. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 2. JSome of the chlorine instrumentation valving is showing signs of corrosion. Also, some indications of gasket deterioration has been observed. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Musi-Do DOW CONFIDENTIAL Page 15 HR = Highly Recommended DO A 032392 CONFIDFNTTAI HR 3. Wrap up the documentation of the CEI calculations package. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 4. The Dow "Process Risk Management Guideline" requires a HAZOP study for any scenarios areas where the CEI exceeds 200. Since Dow y has reviewed this company guideline with OSHA, it is also an OSHA 1910.119 requirement. Review with Loss Prevention to determine the scope and timing of the HAZOP study activity. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date HAZOP See recommendation in the CEI section. ELECTRICAL SYSTEMS HR 1. Any recommendations from the Electrical Maintenance Dept. 5-Point Audit should be included here. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date FIRE PROTECTION SYSTEMS HR 1. Review and update the plant Fire Protection Plot Plan to comply with recent changes made in the area coverage. Contact Loss Prevention to initiate the activity. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 16 HR = Highly Recommended DO A 032393 CONFTDFNTIAi. HR 2. Review the smoke detector needs for B-4610 with the Fire Protection Dept. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 3. Review the CGD coverage in the new area of the plant; Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 4. Combustible gas detectors should be included on the critical instruments program. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date CRITICAL INSTRUMENT SYSTEMS HR 1. Review instruments test procedures. Several are listed as "Missing" or "Wrong name". Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 2. Some procedures do not indicate the exact process condition the instrument is intended to respond to. Trip or alarm set points should be noted exactly in the procedure to assure proper calibration checks. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 17 HR Highly Recommended DO A 032394 CONFIDENTIAL HR 3. Several of the procedures are redundant. Review these to be sure they provide adequate instruction for the instrument technician. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date EMERGENCY BLOCK VALVES HR 1. Review vessels with >5,000 gal. capacity to see if they comply with the current Tech Center and L.P.P. guidelines. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 2. Consider identification of EBV's per L.P.P. 1.5.5. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date PRESSURE VESSELS/PRESSURE RELIEF HR 1. A division plan is in progress to identify and document PSV's that must comply with requirements outlined in the OSHA 1910.119 Regulation. Coordinate this activity with the Process Engineering Dept, to develop a plan of action and schedule. Your area Safety Superintendent is also assigned to be involved in this effort. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page IK HR = Highly Recommended DO A 032395 CONFTDFNTIAl CRITICAL EQUIPMENT HR 1. Review the critical equipment list for anything not spared that would extend a plant outage due to lack of a replacement. (Ex. Thermal. , ( Chlorinator start up*rectifier, major compressor parts, etc.) Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date EMERGENCY PLAN M 1. Parts of the "Emergency Plan" questionnaire were incomplete. . Review to be sure these are adequately included in the plant procedures. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date INSURANCE PACKAGE M 1. Follow up with Loss Prevention to complete and review the insurance material that must be sent to the Corporate Loss Prevention office. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date OSHA PROCESS SAFETY MANAGEMENT M 1. Review the "Process Hazard Analysis" (F&EI, CEI, Reactive Chemicals) with the plant staff and operations and provide training on the process. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 19 HR = Highly Recommended DO A 032396 CONFIDENTIAL. M 2. Conduct a PHA training meeting with the plant technical and supervisor staff. Schedule with Loss Prevention to present the training and provide material for further presentation to the operations employees. This will include F&EI and CEI. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date The preparation and cooperation of the technical staff is appreciated very much. They started early and were well prepared for the pre-audit activity meetings. Loss Prevention and the Fire Protection Department are available as necessary to be involved in any follow up activity. M = Musi-Do DOW CONFIDENTIAL Page 20 HR = Highly Recommended DO A 032397 CONFIDENTIAL SAFETY AUDIT (April 18, 1995 -- 12:15 p.m. to 12:45 p.m.) AUDIT TEAM: Don Jones, Howard Wilkinson, Pam Usie, Roddey Peebles, Eddie Supple PLANT CONTACT: Brian Donnallo ATTENDING: Kevin Kelley, Larry Young, Jim Haney, Roddey Peebles, Brian Donatto, Vic McMurray, Don Jones, Gary Rizzo, Julie Clebert, Don Taylor, Howard Wilkinson WRITER: Don Jones, Howard Wilkinson, Roddey Peebles Listed as follows is the Final CMP "Safety" Consolidated Audit Report. If you have any questions or comments, please contact Howard Wilkinson on the Questionnaire, me on the Documentation Review and Roddey Peebles on the Employee Survey/Field Inspections. Thanks for the help! EMPLOYEE SURVEY Recommendations: M 1. Based on the Safety Employee Survey results and review with the CMP staff, action plans should be developed and implemented to address the following areas: a. Management Support: Questions 5,6,10 b. Employee Participation: Questions 12,13,14,15,16 c. Individual Responsibility for Safety: Questions 17,18, 19,20,22,24,26 d. Miscellaneous: Questions 27,28,29,30,31 Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Musi-Do DOW CONFIDENTIAL Piige 21 HR ' Highly Recommended O A 03?398 CONFIDENTIAL. SAFETY QUESTIONNAIRE A. Program Structure and Planning The Methanes plant recently re-organized its safety organization to better serve its employees. The new organization include a safety committee, six safety teams and a safety leadership team. Each team has its own safety responsibilities defined. The plant superintendent actively participate in all plant safety programs and communicate through safety/tailgate meetings and letters. Safety expectation, objectives, goals and plans are defined and communicated. The Behavior Based safety program is presently being use to address employee behavior and reduce accidents/incidents. Recommendations: HR 1. Define/communicate and document a specified time for response to safety suggestions and unsafe conditions. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date B. Employee Participation No Recommendation C. Contractor Safety No Recommendation D. Accident/Incident Investigation and Reporting Each employee has the responsibility to report all incidents to their immediate supervisor. Incidents are investigated promptly and communicated. Root cause analysis is use to determine cause. M = Must-Do DOW CONFIDENTIAL Page 22 HR * Highly Recommended 00 A 032399 CONFIDENTIAL Recommendations: M 1. Develop a plan to track corrective actions to closure on accident/incident reports. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date E. Audits No Recommendations. F. Safe Work Practices Recommendations: 1. Conduct annual performance audits of safe work permits, confined space entry and lockout/tagout. Also, deviations must be track to completion. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 2. Define who can authorize a confined space entry permit. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date G. Emergency Planning and Means of Egress No Recommendations. M = Musi-Do DOW CONFIDENTIAL Page 23 HR = Highly Recommended DO A 032400 CONFIDENTIAL H. Employee Training Recommendations: M 1. Documentation of training superintendent and technical employees new to the process must be maintained on file. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date I. Safe Operation of Motor Vehicles and Motorized Handling Equipment No Recommendations. J. Off-The-Job Safety No Recommendation DOCUMENTATION REVIEW A. Audits No recommendations. * B. Basic Safety M 1. Revise Plant Safety Policy per New Superintendent. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Musi-Do DOW CONFIDENTIAL Page 24 HR = Highly Recommended DO A 03?401 CONFIDENTIAL C. Unit Emergency Plans M 1. Emergency drill documentation looks good. However, include name of each individual participating in drill instead of shift name. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date D. Job Safety Analysis M 1. The Communique Book is used for communicating changes in procedures, etc. However, all applicable employees are not signing and dating. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date E. Accident/Incident Investigations M 1. Several corrective actions are well beyond the expected completion dates. Emphasis should be placed on completing these actions in a reasonable amount of time. However, in cases where the expected completion date cannot be met, a new expected completion date should be established. In addition, an explanation should be included as to why the original date was not met. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Musi-Do DOW CONFIDENTIAL Page 25 HR = Highly Recommended DO A 03240? CONFIDENT! A1 F. Safety and Health Suggestions M 1. Several corrective actions on Unsafe Condition Reports are beyond the expected completion date. Response time needs improvement. Emphasis should be placed on responding in a reasonable amount of time. However, in cases where the expected completion date cannot be met, a new expected completion date should be established. In addition, an explanation should be included as to why the original date was not met. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date G. Safety Equipment Inspections & Checks HR 1. Post C-9 checklist in control room. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 2. Perform checks on C-9 checklist and sign off on master on or before the due dates. All scheduled dates, next due date, last date, etc. blocks need to be completed. Acti n Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Musi-Do DOW CONFIDENTIAL Page 26 HR = Highly Recommended DO A 033403 CONFIDENT T At M 3. Deficiencies identified during the C-9 inspections must be documented and corrective actions tracked to completion. Documentation must show: * What corrective action was * Who completed corrective action * When corrective action was completed Champs System is being utilized in some cases but not all. There needs to be a more consistent approach. In addition there needs to be some follow-up to assure that items listed in the Champs System have been completed. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date H. Hazard Identification Inspections M 1. Deficiencies identified during inspections must be documented and corrective actions tracked to completion. Documentation must show: * What corrective action was * Who completed corrective action * When corrective action was completed Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date I. Predictive Preventive Maintenance No recommendations. J. Variances No recommendations. M = Musl-Do DOW CONFIDENTIAL Page 27 HR = Highly Recommended DO A 03?404 CONFIDENTIAL K. Contractors/Vendor/Visitor Orientation M 1. Update plant orientation. Include test as part of the orientation. 9** Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date L. Safety and Operations Training M 1. Some formal training on Mod V not being documented, Documentation must include the subject, instructor, date and signature of employees that attended. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M 2. Maintain technical employee training documentation on file and make sure accessible in a reasonable amount of time. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 3. Training in areas that is not applicable for a particular employee should be noted as "not applicable" on the documentation. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M 4. Documentation should include signature of employee participating in the training. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Musi-Do DOW CONFIDENTIAL Page 2X HR = Highly Recommended DO A 030405 CONFIDENTIAL M. Safety Committee Activities No recommendations. N. Safe Work Practices No recommendations. FIELD INSPECTION #1 A. Lockout/Tagout System 1. Red tagged equipment over ninety days - masters 6522, 6807, 6821, 6844, 6643, 6703, 7081. Some of these masters have been signed off but not cleared while others were never accepted. M Recommendation: Need to clear up all masters over ninety days by either retagging or permanent isolation. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date 2. On field check of master 7375 the air was not tagged as indicated on the master. M Recommendation: Train/retrain people on proper isolation and lockout/tagout procedures. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date 3. On field inspection of master 7345 the nitrogen purge check valve assembly was not as per S&LP 313. M Recommendation: Train employee on S&.LP 313 check valve assembly. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 29 HR = Highly Recommended DC A 037*06 confidentTM1 B. Safe Work Permit The safe work permit audit was conducted on 3/1/95. The results of the audit are attached. M Recommendation: Follow-up to correct all deficiencies noted in the audit. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date C. Control Board Area 1. Step ladder located inside Emergency Response Room blocking door. M Recommendation: Remove ladder and store properly. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual CompletionDate 2. An out of date plant "Critical Safety Procedures" book was found in the control room. M Recommendation: Remove Action TakenITo Be Taken: Responsibility Expected Completion Date Actual CompletionDate 3. Uncovered garbage can in designated eating area. M Recommendation: Cover Can Action TakenITo Be Taken: Responsibility Expected Completion Date Actual CompletionDate M = Must-Do DOW CONFIDENTIAL Page 30 HR = Highly Recommended DO A 032407 . CONFIDENTIAL D. Office Area 1. Project trailer HR a. Needs general housekeeping. Lots of things cluttering floors of empty offices. b. Lighted exit sign not lit. M Recommendation: Repair Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date 2. Maintenance Building a. Janitors closet cluttered with broken chair and junk. HR Recommendation: Perform housekeeping. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date b. Fire extinguisher sitting on floor in hall. HR Recommendation: Secure Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date 3. Main Office Building a. Uncovered garbage can in lunch room. M Recommendation: Cover can Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 31 HR = Highly Recommended 00 A 03?408 CONFIDENTIAL b. Unsecured fire extinguishers throughout building. HR Recommendation: Secure all fire extinguishers Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date c. Old Computer Room in need of a lot of housekeeping. Lots of junk and trash. HR Recommendation: Perform housekeeping Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date d. Fire extinguishers in old computer room with mounting bracket pulled loose from the wall. HR Recommendation: Repair Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR e. Area behind old- control board needs housekeeping attention. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date f. Five gallon container with no label behind old control board. M Recommendation: Relabel or properly discard. Action Taken/To Be Taken: Responsibility Expected Completi Actual CompletionDate M * Musi-Do DOW CONFIDENTIAL Page 32 HR = Highly Recommended DO A 03?a9 COMpl E. Lab Facilities See lab audit portion of consolidated audit r F. Motor Control Centers See Loss Prevention and Electrical portions of consolidated audit. G. Maintenance Shop and I&E Areas 1. Pedestal grinder a. Tool rest not at or above centerline of the wheel. M Recommendation: Position tool rest to be at or above centerline of wheel. Action Taken/To lie Taken: Responsibility Expected Completion Date Actual Completion Date b. Wheel is not square M Recommendation: Dress wheel to remove groove in center of wheel Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date c. No waming/instructions signs posted M Recommendation: Install instruction/waming signs Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Musi-Do DOW CONFIDENTIAL Page 33 HR = Highly Recommended DO A 032410 r.ONFTDFNTTAL 2. Pipe threading machine a. No waming/instruction signs posted M Recommendation: Install signs Action Taken/To Be Taken: Responsibility Expected Completion Date Actual CompletionDate 3. Drill Press a. No waming/instruction signs posted M Recommendation: Install signs Action Taken/To Be Taken: Responsibility Expected Completion Date Actual CompletionDate 4. Horizontal band saw N/A 5. Welding and cutting area a. No welding shield around area where welding occurs M Recommendation: Install curtain or welding shield. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual CompletionDate M = Musi-Do DOW CONFIDENTIAL Page 34 HR = Highly Recommended 0 A 03^4]1 CMFlDFNTlAi 6. Other equipment a. Jaws on bench vise badly warn M Recommendation: Replace jaws Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date 7. Hand held power tools M a- Drill with locking trigger - remove drill until trigger lock removed. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M b. Jig saw with paddle trigger and no safety - Remove jig saw Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date 8. Hand tools No Recommendations 9. Lifting tools No Recommendations 10. Safety Equipment No Recommendations . M = Must-Do DOW CONFIDENTIAL Page 35 HR = Highly Recommended DO A 03241? CONFIDENTIAL 11. Housekeeping a. Comers and side walls not cleared of excess material HR Recommendations: Perform general housekeeping Action Taken/To Be Taken: Responsibility Expected Completion Pate Actual Completion Date H. Warehouses No Recommendations. I. Spare Parts Storage No Recommendations J. Motorized Vehicles No Recommendations FIELD INSPECTION #2 A. Loading Rack M 1. Compressed gas cylinder outside AH #12 tied with nylon strap. Replace nylon strap with chain. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 2. The tank truck loading shack appears to be an air tight building, i.e. rubber gaskets on doors and windows. Check to make certain that with the air conditioner off that the building is not depleted of oxygen if occupied. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M * Musi-Do DOW CONFIDENTIAL Page .16 HR = Highly Recommended 00 A 03iM1 3 OONFIDFNTt Al. M 3. Quick opening valve not plugged on tank truck waste pot. Plug all quick opening valves in hazardous service. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 4. Hoses causing tripping hazard on tank truck loading deck. Perform housekeeping. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 5. Unlabeled container in tool cabinet. Label or properly dispose contents of container. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 6. Chainfall on loading filter deck held by rusty choker. Also there is no weight limit on beam holding choker and chainfall. Need to support chainfall with beam with marked capacity equal to or greater than chainfall. Discard rusty choker. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 7. Hoses causing tripping hazard on loading filter deck. Perform housekeeping. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 8. Hoses causing tripping hazard on south end of tank car loading rack. Perform housekeeping. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 37 HR = Highly Recommended HR 9. There is only one safety shower/eyewash station on north upper deck of tank car loading rack. Evaluate the need for a second shower/eyewash. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 10. Hazardous waste drums in non-designated storage area near tank car loading rack. Remove drums to designated storage area and properly dispose. Action TakenJTo Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 11. The waste pots are all purged with N2 through the use of N2 hoses. Hard pipe nitrogen to these waste pots instead of using hoses. B. Sulfuric Acid Area (C-6501 M 1. Nitrogen fittings used to hook to process line without proper block and bleed arrangement. Install nitrogen ties with proper block and bleeds. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 2. Numerous safety showers without eyewash nozzle covers. Emphasize to all employees, Dow and Contract, that these nozzles need to be covered when not in use. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 38 HR = Highly Recommended DO A 03?415 CONFIDENTIAL C. Acid Area (C-610) HR 1. Area chains down on the south side. Reinstall chains. Action TakenlTo Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 2. A line at the top of first stairs is supported with #9 wire. Install correct support. HR 3. D-610 deck needs housekeeping attention. Action TakenlTo Be Taken: Responsibility Expected Completion Date Actual Completion Date D. General Area M 1. Hoist in field not properly marked with rated capacity. Beams supporting hoists not marked with rated load capacity. Label both hoists and beams with rated capacity. Action TakenlTo Be Taken: Responsibility * Expected Completion Date Actual Completion Date M 2. Coupling guard on BL-500 doesn't completely cover rotating parts. Install guard to protect against rotating parts. Action TakenlTo Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 39 HR = Highly Recommended DO A 037416 CONFIDENTIAL HR 3. No entry instructions on the east door of AH #10. The instructions posted on the west door to the analyzer house calls for two green lights to be on before entering. There are no lights. Install proper/correct entry instructions and install green lights or change instructions. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 4. AH #7 has no door handle and only one green entry light for 02 content. Install door handle and check to see if second green light for entry is required. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 5. Chainfall and rope used to support a line in the pipe rack north of T-8. Install proper support. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 6. The instrument shop is using Hansen fittings on plant air. OSHA requires that a dedi'cated fitting be used for breathing air. Hansen fittings are Dow's choice for breathing air in LAD. Recommendation: Remove Hansen fittings in shop and make all employees aware of this requirement. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 7. The compressed gas cylinder rack north of instrument shop has some unlabeled bottles. Label cylinders or properly discard. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 40 HR = Highly Recommended HR 8. The maintenance shop needs housekeeping attention. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date DISTILLATION, CONDENSING & THERMAL CHORINATION AREA M I. Quick opening valves unplugged coming off of D-1300, D1302, P1320A, dry vent east of P-1320A, D-100 and P-1555B. Plug all quick opening valves in hazardous service. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 2. The valves and piping coming off of dry vent are about hip high and could cause a problem to people trying to get to the intercom. Look at relocating the intercom. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 3. Install rack for fire* hose north end of new train. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 4. Install hose racks by nitrogen stations. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M 5. Unmounted fire extinguisher between T-155A and T-1830. Mount fire extinguisher Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Musi-Do DOW CONFIDENTIAL Page 41 HR = Highly Recommended DO A 032418 C0NFTDENTTA1 HR 6. Safety Shower/Eye Wash station 2/PB-38402/CD1-450C next to T1555B is too close to the platform located behind the shower, potentially causing hazard to person in shower during a chemical exposure. Rotate shower ninety degrees to remove away from platform. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 7. Housekeeping Items a. Bolts/hoses, etc. by P-1320's b. Channel locks by T-1555B and P-1750 c. Valve handle on platform by T-1555A d. Nuts, bolts, etc. on top of building next to R-1300 e. Trash on platform in between fans EC 1540 f. Sling and tarp on platform by fans EC-1510 g. Hoses lying on deck above El500 h. Roll of cable left on deck next to R-1300 I. Trash inside vessel skirts D1150, 1140, 1110, C1260 j. Unlabeled container by cooling tower pump 1020B Action TakenlTo Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 8. Landing platform for transition ladder on T-1830 seems too small. Consult Engineering to see if platform meets all OSHA and Engineering requirements. Action TakenlTo Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 9. Entrance to ladder to the upper deck by V-170B in partially blocked by piping from K-1750 to El750. Rotate ladder ninety degrees to allow for unrestricted access. Action TakenlTo Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 42 HR = Highly Recommended DO A 037439 CONFTDFNTIAL M 10. No inspection date on fire extinguisher #98, only hydro test date marked. Have fire department inspect extinguisher and date. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 11. Old decontamination tags still on valves by fin fan coolers #2978, 2979, 2981, 2984 and 2987. Remove old tags. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 12. Labeling coming off of nitrogen station under fin fan. Relabel station. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 13. Scaffold #15576 on south side of E-1430 has access ladder right next to handrail causing to little clearance for climbing. Move access ladder to east side. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 14. Steam outlet on top deck by El302 with no label. Label all utility steamlines. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 15. Scaffold bracing on walking platform above El 302 causing tripping hazard. Remove hazard or use warning device to alert people to the hazard. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Musi-Do DOW CONFIDENTIAL Page 43 HR = Highly Recommended DO A 03?4?0 CONFIDENTIAL M 16. No ladder gate on the short ladder down to deck Ml lines to R-1300. Install ladder gate. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M 17. Grating clips not bolted down on third deck, R-1300, north side. Secure clips. Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 18. Utility station not labeled upper R1300 deck, north side. Label all utility stations. * Action Taken/To Be Taken: Responsibility Expected Completion Date Actual Completion Date M 19. Cylinders by AH-15 sitting on ground instead on grating to prevent bottom corrosion. Install grating for cylinder to sit on. Action TakenITo Be Taken: Re.s ,nsibility Expected Completion Date Acthal Completion Date M 20. Fire extinguisher on AH #14 & 15 not labeled/numbered. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 21. Actuator hanging by rope by T-1500. Install permanent support. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M s Must-Do DOW CONFIDENTIAL Page 44 HR = Highly Recommended DO A 037471 CONFTDFNTTAI, M 22. Nitrogen station not labeled on the deck by fire extinguisher #109. Label as per S&LP standard 313. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 23. Safety shower and eye wash #31, south side of cooling tower, second deck has a tripping hazard to anyone using the shower. Recommend rotating the shower ninety degrees to remove tripping hazard. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date HR 24. The first step to the ladder to T-251 appears to be too high. Consult with Engineering to see if the distances are in compliance with OSHA and Engineering standards. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M 25. The hand/off/auto switch to P-255B cannot be read. Relabel switch positions. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M 26. Cylinder by AH #13 not on grating. Install grating under cylinder to prevent bottom corrosion. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M 27. Quick opening valve between PI 500 A & B, T-1500 to tank car not plugged. Plug all quick opening valves in hazardous service. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 45 HR = Highly Recommended DO A 03747'? CONFTDFNTTAI. HR 28. The alarm button on safety shower/eye wash station #28 is labeled "pinch point". Recommend mounting alarm button a few inches higher to remove as a pinch point. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M 29. Several quick opening, unplugged, valves on vent line next to P1450C. Plug valves Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M 30. Grating not completely secured around P1030 A&B deck, T-1500 . deck, decking by V-1265. Recommend that all grating in plant be audited for proper securement since unsecured grating found in several locations. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M 31. The nitrogen stations in the block have no painted backboards as required by S&LP 313. Install painted backboards. Action TakenITo Be Taken: Responsibility Expected Completion Date Actual Completion Date M = Must-Do DOW CONFIDENTIAL Page 46 HR = Highly Recommended DQ A 0324?3 CONFIDENTIAL SAFE WORK PERMIT AUDIT DATE: 3/1/95 AUDITED BY: Brian Donatto, Roddey Peebles PERMIT AUDITED: Pull fuses and disconnect electrically P-513B 3/1/95 Audit notes: In Section I-#4, "NONE" was checked under special hazards to protect against. Although "NONE" was checked, there were four special hazards checked. In Section I-#5, the special equipment to address the special hazards did not address all of the special hazards checked. Section II, Line and Equipment Openings was filled out. This did not fit the permitted job. Red tag master was not in the Permit Office. PERMIT AUDITED: Dismantle scaffolding throughout the block 3/1/95 Audit notes: In Section I-#5 of two different permits for dismantling scaffolding, the special equipment to address the special hazards did not address all of the special hazards checked. One permit was written to dismantle scaffolding throughout the block. This is too general. Permits needs to be more specific and additional permits written if necessary to cover different areas of the plant. M = Musi-Do DOW CONFIDENTIAL Page 47 DO A 0324-24 CONFTDFNTTA1 HR = Highly Recommended PERMIT AUDITED: Replace R-250 a tail line - 2/27/95 Audit notes: In Section I-#5 the special equipment to address the special hazards did not address all of the special hazards checked. In Section II-#3 was checked "N.A". This should have been checked "No". This job required supplied air which was addressed in the special equipment and special instructions. To do this work without breathing air would have required cleaning and purging. PERMIT AUDITED: Run piping from oil cooler to seal on P-470 A 2/27/95 Audit notes: Section I-#5 did not list special equipment to protect against thermal bums and skin contact checked in Section I-#4. PERMIT AUDITED: Insulate RE-1540 A and R-250 a tail line - 2/27/95 Audit.notes: . " - Two different jobs in two different areas of the plant put on one permit. Should have written two permits. PERMITS AUDITED: Insulation jobs on R-250 B Audit notes: Worker list unacceptable. Workers should be listed on the permit or a crew roster should be used and attached to the permit. If a crew roster exists for red tagging on a job, then "See Roster" is acceptable. PERMIT AUDITED: Pull P-201 B - 2/25/95 Audit notes: M * Musi-Do DOW CONFIDENTIAL Pane 48 HR = Highly Recommended DO A 0324 CONFIDENT! <\ <L Section IV-Permit Close out not complete. Everything was checked off but permit worker closeout not signed. PERMIT AUDITED: Install AOV to DR-101 - 3/1/95 Audit notes: - Section I-#5 did not address all the special hazards checked in Section I#4. Field audit conducted. ' ' f\ Fitter was aware of hazards associated with the job. Permit had been reviewed with the fitter prior to beginning work. Fitter complimented the permit writer highly on the issuing of the permit and the detail of the on-site inspection. M ss Must-Do DOW CONFIDENTIAL Page 49 HR = Highly Recommended A 032^e> DO CON?