Document oDX9r8w7ZVdp8EEKOdkRoL2q8

L(DDD3s3siiEiai ]E)8v8s8nii (CnasD8dlfi(ldl AmidlSl Awirfyzp; (ZE> m hits fa /t> *<+-*" Chemical Exposure Index March 1991 Dow Confidential DO A 023586 CONFIDENTIAL LOUISIANA DIVISION MARCH, 1991 Dow U.S.A The Dow Chem cai Company PO Bo* 150 Piac^emne Louisiana '0765-0'50 TO: PLANT SUPERINTENDENT/DEPARTMENT HEAD RE: CHEMICAL EXPOSURE INDEX AUDIT The CEI Audit will be a part of the Louisiana Division Consolidated Audit Program. The audit will be the responsibilitj of the Superintendent/Department Head. The purpose of this audit is to provide an in-depth review of our Louisiana Division plant facilities that produce or handle quantities of materials which could, if released, possibly cause injury to persons outside our fence lines. The audit will be reviewing the section(s) of the plant that have a Chemical Exposure Index (CEI) of 100 or greater. You should start your preparations by reviewing the attached Chemical Exposure Index Guide and developing or updating the C.E.I.'s for your plant's various chemicals and potential loss of containment scenarios. You will need to complete and send a copy of the review package to the Audit Facilitator ten (10) calendar days prior to the audit. A CEI Functional Audit Team,Major Manager and a Superintendent from another department is required for areas with a CEI of 100300. In addition, a U.S. Area Loss Prevention Representative will be required for a CEI of 300 or greater. Also, a Corporate Representative will be required for a CEI above 400. A CEI of 100 requires a review by the Superintendent and Major Manager only. NOTE: Prompt response to the CEI calculations is necessary. A 30 day pre-audit notification to the U.S. Area will be necessary for some areas. Contact Jim Gibson at Ext. 8163, for a U.S. Area Loss Prevention Representative required on C.E.I.'s of greater than 300. Jim should also be contacted for a Functional Audit Team if the CEI is 100 or greater. Attached is a guide including instructions on what is needed to prepare for the audit and how the audit will be conducted. If there are any questions concerning the audit, please contact me. Jim Gibson CEI Functional Team Building 3301W Ext. 8163 Leader Guide for a Chemical Exposure Index Audit A OP3500 co^roFNrrA(8 Contents Purpose Preparation Instructions Agenda Personal Interview Questions Pre-Audit Questionnaire CEIndex-Chemical Exposure Index and Radii of Exposure Program (Index) 1 2 4 6 7 16 0?3?>q CO CHEMICAL EXPOSURE INDEX AUDIT PURPOSE To review potential release scenarios with a CEI greater than 100, or those that result in odor detection beyond the fence line. The goal is to prevent these potential releases from occurring. This goal can be accomplished by taking the following actions when possible. These actions are in priority order. 1. ELIMINATE THE POTENTIAL HAZARD WHERE POSSIBLE. 2. REDUCE THE POTENTIAL RELEASE. a Reduce the quantity of material. b. Reduce the duration of the release. c. Reduce the frequency of the release. 3. PROVIDE MITIGATION Reduce the impact of the potential release. 1- - D0 A 023590 CONFIDENTIAL CHEMICAL EXPOSURE INDEX AUDIT PREPARATION INSTRUCTIONS These Audit Instructions are being sent to Louisiana Division plants/departments as an audit to be accomplished in the Consolidated Audit Program. You should start your preparation early to assure a thorough review package. A copy of the audit package should be sent to the Functional Team Leader at least ten calendar days prior to the audit. A. AREAS OF CONCERN Only the area(s) of your operation which has a calculated Chemical Exposure Index(es) greater than 100 is covered by this audit, or those that show an odor detection radius beyond the fence line. (A CEI of less than 100 requires a review by the Superintendent and his Manager only!) B. REVIEW PACKAGE The following package requirements must be completed and sent to the Louisiana Division Auditing Facilitator at least 10 calendar days prior to the audit. 1. UST OF ALL CHEMICALS FOR WHICH CEI CALCULATIONS DONE This includes those with CEl's less than 100 or those with a potential odor detection beyond the fence line. 2. A CHEMISTRY SHEET This sheet should include all desired reactions as well as all undesired reactions. 3. A SIMPLIFIED PROCESS FLOWSHEET This flowsheet should include the vessels and quantity of chemicals with CETs 100 or greater or those with an odor problem. 4. A BRIEF DESCRIPTION OF THE "WORST CREDIBLE SCENARIO FOR EACH SCENARIO WITH A CEI GREATER THAN 100. 5. A COPY OF THE SUMMARY SHEETS AS PER ATTACHED CE INDEX PROGRAM FOR CEI AND DISPERSION FOR EACH SCENARIO WITH A CEI GREATER THAN 100 OR THOSE WITH AN ODOR PROBLEM. 2- - DO A 023591 CONFIDENTIAL .6 A PLOT PLAN AND AREA MAP WITH: & Three circles based on EEPG numbers These circles represent the distance (radii of exposure) that 1, 10 and 100 times the EEPG concentrations are predicted to travel for NEUTRAL atmospheric conditions. b. A circle based on the Odor Threshold If the Odor Threshold is less than the EEPG concentration, include a circle for the distance that concentration is predicted to travel for NEUTRAL atmospheric conditions. c. Location of gas monitors, spill detectors, etc. Clearly show the location and type of any device used to detect a release. 7. THE CEI PRE-AUDIT QUESTIONNAIRE (Attached, nine pages) 8. ONE COPY OF THE MASS & ENERGY BALANCE FOR YOUR PLANT. One mass and energy balance flowsheet set should be sent to the Process Engineering representative only. C U.S. Area and Corporate Representatives The Functional Team Leader will invite appropriate Dow U.S. Area or Corporate Safety and Loss Prevention representatives for for reviews with CEI's of greater than 300 or greater than 400 respectively. Notification for outside auditors must be done thirty days in advance of the audit. 3- - DO A 023592 CONFIDENTIAL Chemical Exposure Index Audit Agenda OVERVIEW PRESENTATION TO THE AUDIT TEAM (`Allow 30 Minutes) 1. What is the status of the recommendations made in the previous review? a Have there been any major changes or additions to the plant since the last review? b. Are there any other specific concerns which should be addressed but were not identified in the CEI review? 2. Summarize the results of the CEI calculations. Include results of the odor threshold dispersion modeling. 3. Review the "worst credible" case loss of containment release scenarios including plot plans showing dispersion model results. 4. Discuss any CEI related incidents that have occurred. 5. Discuss your lines of defense that would prevent your "worst credible" release scenario from occurring. 6. Discuss the mitigation procedures for each scenario. 7. Discuss your plant's CEI related concerns generated from the audit preparation. 8. Discuss your plans for improving your operations from a CEI standpoint. PRE-AUDIT QUESTIONNAIRE (* Allow 30 minutes) A. Review the information provided in the questionnaire on an exception basis. DOCUMENTATION AUDIT (* Allow one hour) Following the plant's presentation, two members of the audit team will examine the plant's program documentation. The plant's documentation should include: Emergency Plan P&ID's/Material Balance Flowsheet Operation Discipline In-Plant Training Program Maintenance Checklist Operating Procedure Area Monitoring System Records Piping Specifications Completeness and quality will be used as a criteria for evaluating the documentation. 4- - D0 A 023593 CONFIDENTIAL IV. HYPOTHETICAL EXERCISE ( Allow one hour) Two members of the audit team will simultaneously conduct an exercise designed to evaluate the response to an emergency situation involving a major release of chemical X. The production shift on duty the day of the audit will be given a written description of an emergency involving a major release of chemical X. The Superintendent and Safety Superintendent has previously developed an exercise based on an actual potential concern. The shift personnel will be given five minutes to develop a response to the situation (i.e., who would be notified, what actions would be taken in the field, etc.). Written materials may be utilized by the shift, i.e., operating discipline, checklists, etc. The production shift will then be asked to verbally describe their response to the audit team members. V. INTERVIEW C Allow one hour) A member of the audit team will interview an operator in the plant. See the attached questions. VI. WRAP UP (* Allow 30 minutes) The CEI Functional Team Leader will prepare a written report to be sent to the Audit Facilitator to be included in the Consolidated Audit report to the plant. If there are any questions on the audit procedures, please call Jim Gibson at Ext. 8163. * Note: The documentation audit, hypothetical exercise, and interview will take place currently. 5- - DO A 023594 CONFIDENTIAL CHEMICAL EXPOSURE INDEX AUDIT PERSONNEL INTERVIEW Introduce yourself and explain purpose of the audit to the interviewee. Emphasize to the interviewee that his/her information may be used in the feedback session at the end of the EOPC/CEI audit. However, names will be held in confidence. NOTE: All questions are not applicable to all interviewees. These are only guidelines. 1. How long have you been a Dow employee and in which plants and areas have you worked? 2. Explain your current job function. 3. Is this plant a good place to work in relation to chemical exposures and their effect on the public in general, beyond the Dow fence line? 4. Do you feet that supervision is receptive to suggestions regarding emergency response practice? Do you feel that supervision takes issues related to the CAER program, emergency planning, etc., seriously? Can you give an example? 5. What type of emergency response training have you received? Do you understand the hazards and the appropriate emergency responses? Does the training program include procedures to respond to spills or releases in the environment that may affect the public at large? 6. Are you familiar with the Chemical Exposure Indices (CEI) of your plant's products and raw materials? 7. What procedure do you follow for emergencies such as gas releases, spills, fires, etc.? 8. When was the last time you were personally involved in a planned emergency drill in your plant for the release of gas or liquid of concern? 9. How are emergency response policies communicated? 10. What type of training have you received in the proper use of personnel protective equipment employed for combating spills, gas releases, and fires? 11. Do you feel that Dow overall is doing all that is necessary to prevent you, your neighboring plants, and the public from being exposed to chemicals that are handled in your plant? 6- - DO A 023595 CONFIDENTIAL CHEMICAL EXPOSURE INDEX AUDIT PRE-AUDIT QUESTIONNAIRE Please check off YES, NO, or N/A (not applicable) for each question. Provide additional details if requested. When was the last CEI review?________ What chemicals were discussed and what were the CEI values? Chemical 11 Please list all chemicals in your plant that exhibit a Chemical Exposure Index (CEI) of 100 or greater. 1 2 3 Please list all chemicals that have spill/release scenarios (neutral atmospheric condition and "EEPG X 1") exhibiting a radius of exposure that exceeds the distance from your plant to the public. 1. 2. 3.____ YES NQ MIA ____ ____ _____ Have these scenarios been included in the CAER/MIDAS program? Please have appropriate map plots available for review at the audit. Please list all chemicals that have spill release scenarios (neutral atmospheric condition and "ODOR THRESHOLD X 1") exhibiting a radius of exposure that exceeds the distance from your plant to the public. 1.___ 2 3 yes Mfi MIA ____ ____ _____ Have these scenarios been included in the CAER/MIDAS program? Please have appropriate map plots available for review at the audit. 7- - DO A 023596 CONFIDENTIAL The following pre-audit questions apply to those areas of the operation that process, transfer, or store chemicals whose impact in the event of a release incident would have a significant negative impact on public areas. Impacts on or of immediately surrounding facilities should be considered in a secondary way. A. OPERATING PROCEDURES Yes No N/A ___ __ ___ 1. Does the plant have checklists that are used to shut down and clear equipment/piping to insure that the contents are not left in the equipment, or accidentally released into the environment? If the answer is ves: a. Please have documentation available for review at the audit. If the answer is na: b. How is this function accomplished? c. What are the plant's plans for doing this in the future? 2. Does the plant have checklists that are used for start ing up out of service equipment/piping that insures that no raw material, process streams or product will be accidentally released into the environment? If the answer is ves: a. Please give examples and documentation. If the answer Is Q: b. How does the plant accomplish this function? c. What are the plant's plans for this in the future? 8- - 00 A 023597 CONFIDENTIAL Yes No N/A 3. Does the plant have procedures for the initial opening of lines and equipment? If the answer is ves: a. Please have the documentation available for review at the audit. 4. Does the plant have procedures that define exactly who is responsible for the operation, inspection and main tenance of adjacent and intra/interplant pipelines and associated equipment? If the answer is ves; a. Do they Include normal operations? b. Do they Include emergency operations? c. Please have the documentation available for review at the audit. If the answer is ha: c. What are the plant's plans for developing these procedures? B. PLANT COMMUNICATIONS ___ __ ___ 5. Does the plant have an up-to-date emergency call list? If the answer Is qa: a. What are the plant's plans for developing one? 9- - a 023598 DO TDENTTAD COHf lai Ns m 6. Does the plant have written notification procedures for the following emergencies? a. Gas Release b. Spill c. Fire d. Emergency Response e. Other If ysi to any of the above: a. Please provide documentation at the audit for review. If ng to any of the above: f. Describe what the plant's plans are in this area? ___ __ ___ 7. Does the plant have procedures for establishing contact with Field Headquarters during an emergency? If the answer Is ves: a. Please provide documentation at the audit for review. C. AREA MONITORING SYSTEMS ___ __ ___ 8. Does the plant use an area monitoring system for toxic materials? If the answer is ves: a. How often are these monitors checked and calibrated? b. Please have documentation available at the audit for review- 9. Are plant personnel trained to respond to the alarms from area monitors? If the answer is ves: a. What is the frequency of retraining? 10- - DO A 023599 CONFIDENTIAL D. PLANT PIPING SYSTEMS Yes Nfl N/ 10. Does the plant monitor corrosion in the piping systems of the facility? If the answer is ves: a. How is monitoring done? b. Please provide the documentation at the audit for review. 11. Does the plant have areas in the piping system that requires constant or repetitive repairs? If the answer Is ves: a. Please describe what is being done to prevent recurrence. _____________________ ______ 12. Does the plant have a preventive maintenance program in please to monitor the integrity of the piping system? Consider all elements; l.e., paint, insulation, corro sion, supports, shoes, etc. a. Be prepared to discuss this at the audit. 13. Are outside-the-block material distribution systems monitored for leaks? a. How Is this done? _______________ __________ b. How frequently? 14. Do the plant's toxic material distribution systems undergo pressure testing on a routine basis? If the answer Is ves: a. How often? b. Please, provide documentation at the audit for review- 15. Do the plant's toxic material distribution systems have prominently displayed phone numbers for notification of problems and emergencies? 11- - DO A 023600 CONFIDENTIAL E. PLANT MECHANICAL EQUIPMENT N2 m ___ __ ___ 16. What kind of pumps does the plant use in toxic service? 17. Are these the kind of pump systems that will minimize leak potential? (I.e., tandem or dual seals, sealess pumps, etc.) If not can they be? 18. Does the plant have a preventive maintenance program in place for mechanical equipment? If the answer Is ves; a. Please have the documentation available for review at the audit. If the answer is nfi: b. What are the plant's plans to develop one? F. TRAINING FOR EMERGENCY RESPONSE 19. Have the scenarios for chemical spills and gas releases, that have the most probable chance of occurring, been reviewed with: ___ __ ___ a. Plant operators/technicians? ___ __ ___ b. Supervision? ___ __ ___ c. Other affected employees? ___ __ ___ d. Process Engineering (CEINDEX Program)? ___ __ ___ e. Safety and Loss Prevention? ___ __ ___ f. Environmental (data of MIDAS system)? ___ __ ___ g. Adjacent plant supervision? ___ __ ___ 20. Have your reviews included all possible scenarios that would be deemed "major releases", affecting the public beyond the Dow fence line? 12- - do A 023601 CONFIDENTIAL Yes No N/A 21. Does the plant conduct routine, periodic "what if" emergency drills on the release of toxic chemicals? a. Is each shift involved? b. Do supervisors participate? If what level of supervision? c. Is there a regular schedule for these exercises? d. Is Industrial Security Involved In these practice drills in any way? If in what way? e. How often are drills conducted? f. When was the last time your plant had a planned emergency drill Involving the release of a toxic gas or liquid? g. What chemical was used in your last planned emergency drill? h. Have you used different toxic or odorless chemicals in previous drills? 22. Does the plant have a formalized training program for those people who conduct periodic inspections of concerned facilities? (Example: weekly pipe inspection checklist, what to look for, etc.) 23. How do you insure that "lessons to be learned" from Incident investigations are passed on to all concerned personnel ? 13- - DO A 023602 CONFIDENTIAL Yes Nfl N/A 24. Does the plant have written procedures detailing how to mitigate releases of toxic chemicals in the plant? (Examples: pump to another tank, apply foam, drive a wooden peg, etc.) If the answer is ves: a. Does the plant periodically train operating personnel on these procedures and methods for mitigating liquid spills or gas releases from the facility? If how often? If y, how is the training documented? b. Please provide at least one example for review at the audit. 25. Has the plant reviewed its emergency response personnel protective equipment inventory with Industrial Hygiene? (appropriateness, types, numbers, etc.) 26. Does the plant have sufficient quantities of emergency response personnel protective equipment on hand to satisfy the need in the event of a major emergency? If the answer is ves: a. Is it kept at strategic locations for ease of access in case of an emergency? 27. Are there checklists employed for the periodic inspection, maintenance, and testing of the plant emergency equipment? (ammonia curtains, foam deluge systems, and fire monitors) If the answer is ves: a. How often? b. Who does it? __ ________________________ If the answer is nfl: c. Please discuss the plant's plans. 14- - do A 023603 CONFIDENTIAL izi m m 28. Are all plant personnel trained in the proper use of the various personnel protective equipment employed for combatting liquid spills, gas releases, and fires? If the answer is ves: a. How often? b. How is this training documented? 29. How many people are Involved in training on the proper emergency response to a liquid/vapor chemical release of concern? a. Operators/technicians b. Supervision (all levels) c. Others d. Total of above _________ _________ _________ _________ 30. Have you consulted with neighboring plants immediately surrounding your facility to determine the effects of spills/releases by them on your plant and personnel? If the answer Is a. Do you have the proper type of personnel protective equipment if your plant Is downwind of a spill or release from those facilities? b. Sufficient quantities of equipment? c. Is this equipment Inspected or checked periodically? If yes, how often? d. Do you train your plant personnel on how to respond when exposed to a gas released from an adjacent plant? If yfii, how often? e. Do you participate In emergency drills when hypo thetical releases originate in plants other than your own? If how often? If the answer Is na to #30: Please describe what the plant does In the event of one of these emergencies, and future plans. 2/90 15- - do A 023604 CONFIDENTIAL