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PROCESS SAFETY AND LOSS PREVENTION AUDIT Page 33 | Mechanical integrity I EMERGENCY BLOCK VALVES REFERENCES: LPP 17.1.6. A 1. Yes [] No [X] Are incoming and outgoing headers handling flammable or toxic materials fitted with EBVs at the battery limits? Chlorine Users and Hydrogen to Power Yes [X] No Q Are the EBV's remotely operated? Yes [X] No [] Are the EBV's on a P.M. program and exercised at least annually? What is the testing frequency? Monthly Have documents available at the audit. Plans: No current plans to change EBV system or tests A 2. Yes [X] No D Are all vessels or processing equipment with greater than 5,000 gallons (2,000 gallons, if expansion joints, hoses or swivel joints are involved) of flammable liquids, flammable (dangerous) gasses or the equivalent amount of vapor fitted with remotely operated EBV's? Details: Storage spheres A 3. Yes [X] No [] Are vessels or processing equipment with greater than 20,000 gallons (8,000 gallons, if expansion joints, hoses, or swivel joints are involved) of liquid at or above its flashpoint fitted with remotely operated EBV's? Plans: No storage of liquids at or above flashpoint B 4. Yes [X] No [] Are EBV's installed around critical equipment such as reactors, furnaces, etc., in case of emergency shutdown? Details: Cells. Compressors, and Absorber Columns at Chlorine Incoming fuel aas at Cell Service. A 5. Yes Q No [X] NA [] Are there remotely operated EBV's on the lines to and from loading and unloading stations when hazardous materials are being handled? Plans: EBV's are on Chlorine loading lines but not on Sulfuric Acid unloading. No plans in the near future 10/22/93 Confidential JFM:jl/22 Dow DO A 024046 CONFIDENTIAL PROCESS SAFETY AND LOSS PREVENTION AUDIT Page 34__________________________________ __________ B 6. Yes Q No [X] Are flexible unloading joints or swivel joints for tank car and truck loading and unloading for highly flammable or toxic materials protected on both ends by EBV's ? Plans: Supply end is protected bv EBV's while the car is protected bv a excess flow valve. A 7. Yes [X] NoQ NAQ Are EBV's "fail safe" for all utility interruptions? Plans:_____________ B 8. Yes Q No [X] NA Q If the valve is in a fire exposure area, is it "fire tested?"* Plans: Hvdroaen collection EBV's are not fire tested. No current Plans. A/B 9. Yes [] No [X] Are your EBV's identified as per L.P.P. 1.5.5. (painted yellow)? Plans: No Plans. Fire tested means approved by a testing agency for fire service. 10/22/93 Confidential JFM:jl/22 DO A 024047 CONFIDENTIAL Dow B