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LOSS PREVENTION AUDIT Page 1 Prepared by:_Jim Haney, Stephen Ledoux, Kevin Kelley (CEI)_ Date: 2/22/95 Reviewed by: Audit Team Date: 4/18/95 A=Dow Rule or Regulation B=Good Practice/Training C=Hazard Analysis VIL AUDIT QUESTIONS AND ANALYSIS | Operating Discipline | REFERENCE: Operating Discipline Standard for The Operating Units of Dow U.S.A. A 1. Yes [x] No [] Have you filled out the plant self-evaluation forms to assess your plants progress on Operating Discipline? Please provide these forms at the pre-audit meeting. Section II Process Technology Documentation Section V Process Risk Management Section VI Operating Procedures Section VII Process Control Section VIII Operational Reliability Section IX Dynamic Process Information Section XII Industrial Hygiene Plans: ____ A/B 2. Who has primary responsibility for the plant's Operating Discipline? Bruce Miles A/B 3. How is the written portion of the Operating Discipline program maintained? (Have this available at the audit meeting.) Maintained electronically by the program facilitator A 4. Process Safety Information (OSHA 1910.119, Paragraph d)(Review the Operating Discipline Self-Evaluation on Process Technology Documentation, Process Risk Management, Industrial Hygiene.) (Revised 02/18/94; cmk) %mS\ LADrbwb ^0 A 037777 ^ONFTDFNTTAi LOSS PREVENTION AUDIT Page 2________________ a. Is information included pertaining to the hazards of the chemicals used or produced by the process, and does the information include at least: YES nU~ X * Toxicity Information X PEL'S X * Physical Data X Reactivity Data X Corrosivity Data X Thermal and Chemical Stability Data X * Hazardous effects of inadvertent mixing of different materials that could forseeably occur? NOTE: MSDS's meeting the requirements of 29 CFR 1910.1200(g) may be used to the extent they contain the information required. b. Is information included concerning the technology of the process, and does it include at least: YES NO X A block flow diagram or simplified process flow diagram? X Process Chemistry? X Maximum intended inventory? *X Safe Upper and Lower Limits? X An evaluation of the consequences of deviations? (If the original technical information no longer exists, it may be developed in conjunction with the Process Hazard Analysis.) c. Is information included pertaining to equipment in the process, and does it include at least: YES NO X Materials of Construction? X Piping and Instrument Diagrams (P&ID's)? X Electrical Classification? X Relief System Design and Design Basis? X Ventilation System Design? X * Design Codes and Standards Employed? X Material & Energy Balances for Processes Built after 05/26/92? X * Safety Systems (e.g., interlocks, detection or suppression systems) (Revised 02/18/94; cmk) m/95; LAD:bwb DO A 037778 CONFIDFNTTAl LOSS PREVENTION AUDIT Page 3 ______ A 5. Operating Procedures (OSHA 1910.119, Paragraph f) (Refer to Operating Discipline Self-Evaluation on Operating Procedures) Yes [x] No [) Do written operating procedures exist for each process? Yes [x] No [] Do the procedures provide clear instructions for conducting activities safely? Do the operating instructions address, as a minimum, steps for each operating phase, including? YES X X X X X X X X X NO Initial Start-up? Normal Operations? Temporary Operations? Emergency Shut Downs? Conditions Requiring Emergency Shut Down? Assignment of Shut Down Responsibility to Qualified Operators? Emergency Operations? * Normal Shut Down? * Start-ups following a turnaround or emergency shut down? Yes [x] No [] Are operating procedures readily accessible to employees who work in or maintain a process? Yes [x] No [] Are operating procedures reviewed as often as necessary to assure that they reflect current operating practice? A/B 6. Yes [x] No [] Does the plant have a training process to keep people current on Operating Discipline? Plans: (Revised 02/18/94; cmk) 8/9/95; LADrbwb DO A 03? OONFTDFNT LOSS PREVENTION AUDIT Page 4_____ [ Process Hazard Analysis \ Process Hazard Analysis (PHA) is required by the OSHA PSM Standard 1910.119, Paragraph e). This section of the Loss Prevention Audit along with the Reactive Chemicals Review, Chemical Exposure Index Review, Fire and Explosion Index, Hazardous Materials Transportation Review and others, constitutes Process Hazard Analysis for existing Dow facilities. This section of your PS&LP Audit will be retained for the life of the plant. FLAMMABLE MIXTURES/COMBUSTJBLE DUSTS c 1. Yes [x] No [] Are flammable/combustible materials stored in your plant? c 2. Yes [x] No [] Are flammables loaded/unloaded in your plant? A 3. Yes [x] No [] Partly [] Are flammable materials processed in open, freely ventilated structures? (LPP 2.1.2.) Plans: B 4. How do you prevent flammable mixtures in the vapor space of process tanks, storage tanks, rail cars, tank trucks, etc.? (LPP 10.2) Closed dome loading, nitrogen padding of storage tanks, analysis with nitrogen purge on rail cars and tank trucks, and the use of a vent header system. Plans: C 5. Yes [x] No [] In process equipment operating under vacuum conditions, has the hazard of air introduction been evaluated? (Example: Packing leaks on vacuum pumps, vacuum conditions resulting from temperature change associated with shutdowns, normal low pressure operations, etc.) Plans: ___________________________ _ (Revised 02/18/94; cmk) 8/9/95; LADibwb OO A 032730 OONFTDFNTT Al LOSS PREVENTION AUDIT Page 5 B 6. Yes [x] No [] Do you monitor system pressure and/or oxygen content in low positive pressure applications? Plans: We measure oxygen on one of our three PSA units, PSA- 1770._______ __________ _ C 7. Yes [] No [x] a. Do you have a flare system? Yes [x] No [j b. Do you have a TOX, THROX? If yes to either of the above, how do youprevent backflashes in the system? Utilize flame arrestors and differential pressure control of vents.___________________ ___________________________ Yes [] No [x] Are temperature sensors utilized in conjunction with flame/detonation arrestors? Plans: ________ ____________________________ How do you avoid flammable mixture within the header? (LPP 14.2.7) Plans: Operator discipline, and warning signs. Yes [] No [] NA [x] Is your flare tip on a maintenance schedule? How do you insure that you have a flame? We use U.V. detectors on the Throx, R-750. C 8. Yes [] No [x] Does the plant/process have potential combustible dust flammability concerns? (LPP 11.1) If yes, answer the following questions: Yes [] No [] Have reactive chemical tests been run on the possible dust mixtures? Plans: ________________________________________________________ (Revised 02/18/94; cmk) 8/9/95; LAD:bwb DO A 03?73l al conf"* LOSS PREVENTION AUDIT Page 6 Yes[] Non Plans: Does the plant have static electricity guidelines and programs? (LPP3.6) Yes [] No[] Plans: Are regular electrical continuity checks made for solids handling systems? (LPP 11.1.3) Yes [] No[] Plans: Are there plant procedures and action taken to prevent an accumulation of dust to build on structural beams, surface of equipment, etc.? Yes [] No [] Plans: Where dusts exist, have alternate methods of handling or isolation been considered? (Revised 02/18/94; cmk) m/95; LAD:bwb on A O-Oh/p LOSS PREVENTION AUDIT Page 7 | Process Hazard Analysis - FACILITY SITING - DRAINAGE REFERENCES: LPP 2.4, LPP 7.6.3. B 1. Yes [] No [x] NA [] If one or more fire protection systems are activated, will flooding occur in the process area? If so, where? Plans:___________________________ _________________________ B 2. Yes [x] No [] Can trenches, ditches, sewers, etc., back-up into the plant? If so, where? Hydrochlorination___________ ___________ Plans: No plans. Likelihood is very small. We are equipped with five sump pumps for this area. B 3. Yes [xj No [] Would a fire in trenches, ditches, sewers, etc. expose the plant? If so, refer to LPP 2,4.4. for cover recommendations. Plans: __________________________________________________ _____ A 4. Yes [x] No [] Are all sewers trapped to prevent vapor backup? Plans: _ A 5. Yes [x] No [] NA [] Plans: Are tanks containing liquid with flash points less than 140F diked or impounded? (LPP 7.6) (Revised 02/18/94; cmk) 8/9/95; LAD:bwb OO A cnftofNT7a| LOSS PREVENTION AUDIT Page 8______________ ____ B 6. Yes [x] No [] Don't Know [] Are diked walls liquid-tight? (LPP 7.6) Yes [] No [x] Are they tested? Plans: ____________ _____________ A 7. Yes [x] No [] Are tanks located far enough from dike walls so that a leak will not spray over the wall. (LPP 7.6.2.) Plans: A 8. Yes [x] No [] Is area drainage generally directed away from the process equipment? Rate your drainage system: Excellent [x] Fair [] Adequate but Needs Improvement [] Plans: Recent upgrades in runoff systems______________________ B 9. Yes [x] No [] Are drainage areas including ditches clean and free of obstruction/debris? (LPP 7.6) B 10. Yes [x] No [] Does your plant have secondary containment? Yes [x] No [] If so, are there written procedures covering operation, especially during emergencies? Plans: A 11. Yes [x] No [] Do you have a written plan for handling spilled materials? Plans:_______ (Revised 02/18/94; cmk) 8/9/95; LAD:bwb DO A 037734 CONFTDFNTTAI LOSS PREVENTION AUDIT Page 9 Process Hazard Analysis WAREHOUSE STORAGE Warehouse - An attached or detached building for storage of raw materials, finished products or maintenance items or equipment. REFERENCES: Minimum Requirement, LPP 12.4. C 1. Yes [] No [x] Not Required [] Are warehouse areas protected with fire protection or detection systems? Plans: Warehouses are equipped with fire extinguishers. What is the warehouse inspection practice? Material management handles inspection and operation of warehouse. _______ _______ _____ ___________ C 2. Yes [] No [x] Are pallets stored within the warehouse? 12.4.3) Plans: _____ (LPP B 3. Yes [] No [x] Are empty pallet stacks less than eight (8) feet in height? (LPP 12.4.3.) Plans: B 4. NA [x] Where does sprinkler and fire fighting water drain? (LPP 12.4.4) Plans: (Revised 02/18/94; cmk) 8/9/95; LADrbwb DO A 037735 CONFTDFNTTAI LOSS PREVENTION AUDIT Page 10 C 5. What type fork truck is utilized in the warehouse? Diesel Powered [x] Gasoline Powered [x] LPG Powered [] List types of fork trucks. Diesel and gasoline fork trucks from the equipment yard.______________________________________________ C 6. Where is fuel storage for the fork truck located? (LPP 12.4.5) Out of block 46.______________________________________ _ Plans: ______ ____ ________________ ' C 7. Yes [] No [x] Are flammable or combustible liquids dispensed or drummed in the warehouse area? (LPP 12.4.5) Plans:________________________________________________ (Revised 02/18/94; cmk) 8/9/95; A D.bwb DO A 037706 CONFIDENTIAL. LOSS PREVENTION AUDIT Page 11 | Process Hazard Analysis 1 EQUIPMENT/BUILDING LOCATIONS AND FIRE RISK REFERENCES: Minimum Requirements, LPP 2.2. and 12.2. A 1. Yes [x] No [] Do buildings and process structures meet the minimum separation distances as calculated by the F&EI (LPP 2.2?) Yes [] No [] If minimum distance is not met, is the area protected? Plans for areas of concern: Yes [x] No[] Yes [] No [x] Plans: Has the construction for occupied buildings in high hazard plants been evaluated per LPP 12.2.? Are there significant areas of concern? Yes [x] Yes [x] Plans: UJ oo Are buildings of non-combustible construction? Are temporary buildings (trailers) located to avoid exposing other critical facilities? (i.e.: under power line, pipelines, flammable storage) B 4. Describe your buildings' air supply system. Review monitoring and emergency procedures regarding flammable and/or toxic releases. (LPP 12.1) Air supply to building 4601 and 4606 can be shut off during an emergency from the control room.__________________ (Revised 02/18/94; cmk) 8/9/95; LADibwb 030707 DO A OFNT1A1 LOSS PREVENTION AUDIT Page 12 Yes [x] No [] Can the air supply be shut down in an emergency? Yes [] No [x] Do you monitor the air intake for flammable/toxic material? Plans: A 5. Yes [] No [] NA[x] Are penetrations of fire walls properly protected? (LPP 3.5.6) Plans: The old control room is not well sealed on the cable tray penetration. A 6. Yes [] No [] NA[x] Plans: Are fire doors inspected periodically and fusible link systems tested for closing (LPP 10.13)? (Revised 02/18/94; cmk) %I9I9S\ LADrbwb 037733 DO A CONFl qFMTT. AF LOSS PREVENTION AUDIT Page 13 1 Process Hazard Analysis 1 HUMAN FACTORS (Technical systems and equipment designed so they can be used safely and efficiently by humans.) A 1. Yes [x] No [] During a Process Hazard Analysis (i.e.; Project Review, Management of Change Review), are human factors considered? (For Example: "What if the operator adds material B instead of material A?") Plans:_____ ______ B 2. Yes [x] No [] Is adequate information about process conditions (normal and upset) displayed in the control room? Plans:_______ B 3. Yes [x] No [] Are the displays visible from all normal areas in the control room? Plans:_______ B 4. Yes [xj No [] Are automatic safety features provided to cope with a process upset when either a rapid response or complex information process is required? Plans: _______________________________________ ___________________ B 5. Yes [] No [x] Must any instrument, display, or control be disabled or bypassed manually as a normal part of the operation? Plans: _____ (Revised 02/18/94; cmkj 8/9/95; LAD:bwb DO A 037739 CONFIDENTIAL LOSS PREVENTION AUDIT Page 14 B 6. Yes [x] No [] Are alarm set points and process computer software protected from unauthorized change? How: MOC AP's on critical setpoints. B Yes [x] No[] Are critical inputs to the process control computer protected from incorrect entries? Plans: B Yes [] No [x] Are there unnecessary alarms? Plans: nB Yes[x] No Is equipment labeling adequate for trained personnel to determine content and flow direction? Plans: B 10. Yes [x] No [] Do shifts communicate the process status (batch conditions, process abnormalities, equipment out of service, active work permits, etc.) to each other? How: Log book. Relief meetings. Control room dry erase board._ If not, plans: B 11. Yes [x] No [] Are checklists used for critical procedures? Plans: _________________ ____________ ____ (Revised 02/18/94; cmk) 8/9/95; LADibwb DO A 032740 GONFTDFNT T Al. LOSS PREVENTION AUDIT Page 15 B 12. Yes [x] No[] Do the people developing and reviewing procedures analyze the job for hazards and identify the hazards in the procedure? Plans: B 13. Yes [x] No [] Are operating personnel able to read and understand process control programs? Plans: B 14. Yes [x] No [] Are operating personnel trained in using the process information computer? Plans: (Revised 02/18/94; cmk) 8/9/95; LAD:bwb DO A 000741 GONFTDFNTIAl LOSS PREVENTION AUDIT Page 16 in BggHW^--pp--^1 [ Process Hazard Analysis Chemical Exposure Index (C.E.I.) Summary for Consolidated Audit When was the last C.E.I. Review? (Month/Year) September 1992 A 1. What chemicals were discussed and what were their respective C.E.I. values? CHEMICAL Chlorine Anhydrous HCI Methyl Chloride C.E.L 288 216 288 CHEMICAL C.E.L B 2. Please list ALL chemicals in your plant that will be reviewed during this audit. 1. Chlorine 2. Anhydrous HCI 3. Methyl Chloride 4. Methylene Chloride 5. Chloroform 6. Carbon Tetrachloride 7. Methanol B 3. Please list all chemicals that have potential spill/release scenarios with an ERPG/EEPG-2 hazard distance that exceeds the distance from your plant to the public. 1. Chlorine 2. Anhydrous HCI 3. Methyl Chloride 4. Methylene Chloride 5. Chloroform 6. (Revised 02/18/94; cmk) S/9/95; LAD:bwb DO A 037747 CONFTDrNTTAL LOSS PREVENTION AUDIT Page 17 CHEMICAL EXPOSURE INDEX B 1. Yes [x] No [] Does the plant have procedures for determining the level of release for emergency communication? Plans: CMP utilizes the standard division protocol for spill size assessment (catagory A,B,C). The sizes correlate as follows: A- inside block, B- leaving block, inside division, C-Outside division B 2. Yes [x] No [] Does the plant use an area monitoring system for the chemicals of CEI concern? If the answer is YES, list: Chemical Detector Type Chlorine Chlorine Area Monitor Methyl Chloride Combustible Gas Methanol Combustible Gas HQ None Detection Level 1-10 ppm 0-100% LEL 0-100% LEL N/A How often are these monitors checked and calibrated? Quarterly Yes [x] No [] Are plant personnel trained to respond to the alarms from area monitors? Plans: Operations personnel monitor the plant continuosly. In the event of a detector alarm, operators will investigate the area. Using proper safety and respiratory protection, they will assess the situation and respond accordingly, A 3. Have the scenarios for potential chemical spills and gas releases included in this audit been reviewed with:** TeS" "N(T" X Plant Operators/Technicians? X Supervision? X Other Affected Employees? X Process Engineering? X Safety and Loss Prevention? X Adjacent Plant Supervision? DATE REVIEWED Post Audit Review Post Audit Review Post Audit Review 4/95 -Audit personnel 4/95 -Audit personnel ** ** Adjacent plants are notified via a division wide, all area paging system. Plant security continuously updates the situation for each to ensure that personnel are taking appropriate precautions. Evacuations would be handled through the site emergency network and plant security. (Revised 02/18/94; cmk) 8/9/9*- VADrbwb DO A 007743 CONFTDFNTTAI LOSS PREVENTION AUDIT Page 18_______________ ______ Have you reviewed scenarios from neighboring plants that may affect your area with: ~yeS~ W" X Plant Operators/Technicians? DATE REVIEWED ** X Supervision? X Other Affected Employees? Plans: See response to question 3. Updates and evacuation needs are handled through Plant Security and updated by an all area paging system. B 4. Yes [x] No [] Does the plant conduct routine, periodic "what if' emergency drills on the release of toxic chemicals? When was the last drill? Month/Year: March 1995 Plans: CMP conducts quarterly emergency drills as per OSHA Star requirements. These~drills vary on topic covered? A March 1995 drill focused on response to an HOI spill, including formation of sweep teams and opertor response for a simulated plan shutdown. B 5. Yes [x] No [] Does the plant have written procedures detailing how to mitigate releases of chemicals in the plant? (Examples: pump to another vessel, apply foam, temporarily plug hole, etc.) Yes [x] No [] Does the plant periodically train operating personnel on these procedures? Plans: CMP has a very comprehensive procedure system active within the plant. The procedures for emergency shutdown of the thermalchlorination reactor (Chlorine scenario), HCI Purification (HC1 scenario), and Ml release at 1-814 (Methyl chloride scenario) are included. Operations procedures are reviewed anuallv and retrained on upon change. Operations utilizes procedures for all iobs. B 6. Yes [x] No [] Are there checklists employed for the periodic inspection, maintenance, and testing of equipment used to mitigate spills or releases? If yes, list: Equipment Last Inspection Last Test | ** 1 1 ** Plant security is responsible for periodic inspection and maintenance of fire protection equipment. Documentation audited by Steve Ledoux, 4/95 (Revised 02/18/94; cmk) 8/9/95; LAD:bwb 0^?7 LOSS PREVENTION AUDIT Page 19 ...... ... B 7. Yes [x] No [] Does the plant monitor corrosion/erosion in the piping systems of the facility? How is monitoring done? Piping is inspected by operations on routine operator rounds. In addition, CMP is implementing a piping inspection program in accordance with OSHA PSM requirements. B 8. Yes [] No [x] Does the plant have areas in the piping system that require constant or repetitive repairs? B 9. Yes [x] No [] Does the plant have a preventative maintenance program in place to monitor the integrity of the piping system? Consider all elements: i.e., paint, insulation, supports, shoes, etc. Plans: This preventative maintenance program is the same piping inspection program mentioned in response to question 7. B 10. Yes [x] No [] Does the plant have procedures that define exactly who has the responsibility for the operation, inspection, and maintenance of adjacent and intra/interplant pipelines and associated equipment? Plans: The Louisiana division is responsible for inspection of all out of block piping systems. The maintenance of the piping systems is the responsibility^ CMP. (Revised 02/18/94; cmk) 8/9/95; LAD:bwb DO A 037745 CONFTDFNTTAI LOSS PREVENTION AUDIT Page 20 | Process Hazard Analysis | HAZOP C 1. Do any of your unit operations have: Yes [] No [] an F&EI of 128 higher? Yes [x] No[] a C.E.I. of 200 or higher or? Yes [} No [] meet the criteria for conducting a HAZOP as outlined in the Process Risk Management Guidelines for Facilities and Distribution? Plans: CMP will analyze the results of the Consolidated Audit and complete HAZpP reviews for systems in accordance with auditor recommendations. B 2. Where a HAZOP Review has been performed (please list areas studied), what is the status of the recommendations from the HAZOP study? None to date. The consolidated audit process is a very detailed process hazard review. Full HAZOPs will be completed as dictated by auditors and division management. Process Process Unit ADDITIONAL RISK EVALUATION C 1. Yes [x] No [] Has any additional risk evaluation or quantitative risk assessment been done in your facilities? Plans: As mentioned in response to question 2 above, CMP has undergone the consolidated audit review process. The first review was in September 1992. Follow up items were well documented and completed within accepted time frames,' B 2. Yes [x] No [] Do you have a system for tracking risk evaluation recommendations until closed out? Plans: Consolidated Audit follow up items are tracked and monitored for status until completed. (Revised 02/18/94; cmk) 8/9/95; LAD:bwb OO A 037746 CONFTDFNT7AI LOSS PREVENTION AUDIT Page 21 I C. Mechanical Integrity ~1 Mechanical Integrity is a new term used in the OSHA Process Safety Management Regulation (1910.119, Paragraph J). At Dow, Mechanical Integrity includes the items in this section: Electrical Systems Fire Protection Systems Fired Equipment Critical Instrument Systems Emergency Block Valves Storage Tanks Pressure Vessels/Relief Devices/Glass Devices/Expansion Joints Critical and Rotating Equipment (Including Compressors and Pumps) Management Systems Piping, Compressors and Pumps (Revised 02/18/94; cmk) 8/9/95; LAD:bwb OO A 037747 CONFTDFNTTAl LOSS PREVENTION AUDIT Page 22 | Mechanical Integrity ELECTRICAL SYSTEMS REFERENCES: Minimum Requirements, National Electric Code, LPP 3. Included as part of the Loss Prevention Audit, is an Electrical 5-point inspection by the Electrical Maintenance Department. Contact your area electrical supervision to verify and coordinate this activity. Following is a list of some Loss Prevention items that will be included in that plant inspection: 1. The Electrical Area Plot Plan drawing should be reviewed and current. Contact Loss Prevention if revisions are required. (L.P.P.) Identify any installations that are in conflict with electrical plot plan. 2. The Safety Electrical One Line Diagram (SEOLD) should be reviewed and current per LAD S&LP S-214. 3. The electrical field audit will include an inspection of existing installations to observe mechanical integrity, maintenance needs, and conformance with L.P.P.-3., the National Electrical Code, and Area Classification practices. 4. The results of this Electrical Department 5-Point inspection audit will be included in the follow-up portions of this audit. B 1. Does your plant have: Yes [x] No [] *Redundant Electrical Power Supply? Yes [x] No [] *Redundant Feeds? Yes [] No [x] Diesel Generated Power Backup? Plans: ________________________________________________ *Some plants have redundant feeds but single transformers. B 2. Yes [x] No [] Is switch over automatic? (LPP 3.4) Last Date Exercised: ___________________________________ Plans: ________________________________________________ A 3. Yes [) No [x] Are there major cable trays routed through flammable liquid areas where pooling resulting from spills can occur? (LPP 3.2.5) Plans:___________________________________________________ (Revised 02/18/94; cmk) 8/?*^: LAD:bwb DO A 000748 OONFTDFNTTAl LOSS PREVENTION AUDIT Page 23________ ____________ B 4. Yes [] No [x] Do you have fire protection on any of your major cable trays, (i.e., water spray, drainage, routing, fire retardant materials)? (LPP 3.2.7) Explain: B 5. Yes [] No [x] Considering possible unit fire exposures, are all cable wall penetrations appropriately sealed with approved fire stops? (Urethane is not an approved fire stop.) (LPP 3.2.6) Plans: The old control room penetration is not properly sealed. Some of the cables will be demoed soon. (Revised 02/18/94: cmk) 8/9/95; LAD:bw_ 00 A 032749 C0NFIDFNT7A1 LOSS PREVENTION AUDIT Page 24________ Mechanical Integrity FIRE PROTECTION SYSTEMS REFERENCES: Minimum Requirements C 1. Yes [x] No [] Do you have fire monitors and/or fixed sprinkler systems to protect flammable areas? Plans: _____ A 2. Yes [x] No [] NA [] Do you have a plant program to routinely exercise/test fire monitors and fixed sprinkler systems? Plans: Not within the plant. Fire department. A 3. Yes [x] No [] Is your extinguisher inspection and testing up-todate? Plans: Monthly checks done in block. Annual audit by fire department.__________________________________________________ B 4. Yes [x] No [] Are the size and type of extinguishers appropriate to the anticipated fire -- for example, a "C" rated extinguisher where electrical fires could be expected? Yes [x] No [] Are they properly located (i.e., office, MCC, switchgear rooms)? Plans: ________________________________________ ______ (Revised 02/18/94; cmk) 8/9/95; LAD:bwb no A 03P750 OONFIDFNTJA! LOSS PREVENTION AUDIT Page 25 A 5. Yes [x] No [] NA [] Have your employees participated in annual fire extinguisher training? Last Training Date: 11/93. Three year training. Annual safety meeting film._____________________________ Plans: ____ _________________________ _______ _ B 6. Yes [] No [x] Do you have hose cabinets? Yes [] No [] If yes, are employees trained on their use? Yes [] No [] Is there a Preventative Maintenance Program on the hoses? Yes [] No [] Are the hose cabinets necessary? Date of last hose test: C 7. Yes [x] No[] Do office areas, MCC's, switchgear, computer rooms and unoccupied buildings have smoke detectors alarming in a 24-hour/day occupied area? (LPP 9.1 and 9.2) Plans: Building 4610 has no fire detectors. A 8. Yes [x] No [] Are checks of smoke detectors made routinely and documented? (LPP 10.13) Plans: Done by fire department. C 9. How is your structural steel protected from a spill fire? (LPP 10.10) Plans: Areas in the new plant are protected by concrete. Areas in the older plant are protected with Pyrocrete. (Revised 02/18/94; cmk) 8/9^5; LAD:bwb 00 A 03?75 OONFTDFNTTA1 LOSS PREVENTION AUDIT Page 26_____________________ B 10. Yes [x] No [] NA [] Yes [x] No [] Is fire proofing well maintained? (LPP 10.10.7) Is there an inspection program? Date of Last Inspection? 1/94_________________________________ Plans: B 11. Yes [x] No[] NA[] Is pipe insulation on hot lines (i.e.: 150# steam or DOWTHERM*) in good condition to prevent a chemical leak from entering the insulation and auto-igniting? (LPP 10.12.4) Plans: __________________ A 12. Yes [x] No [] NA [] Are gas AND spill detectors adequately maintained (LPP 9.9.6) and tested routinely? (LPP 10.13) Provide Documentation. Plans: Block 43 is on critical istrument list for gas detectors.____ B 13. Yes [x] No [] Do you maintain foam within your area to fight fires? (LPP 5.8) If yes, what kind of foam is used and when was the material last tested? Protien foam Contact the Fire Department for the above information. Plans:_______________________________ ____________ _____ Trademark of The Dow Chemical Company. (Revised 02/18/94; cmk) 8/9/95; LAD:bwb OO A 03775? CONFIDFNTTAI. LOSS PREVENTION AUDIT Page 27 B - DELUGE & SPRINKLER SYSTEMS REFERENCE: Fire Protection Manual -- The intent of this page is to assure that fire protection systems are properly maintained. Your Loss Prevention contact can assist with filling this out. EXAMPLE Adequate access to valves during an emergency? Yes Explosion or traffic exposure to valve? No Explosion or traffic exposure to piping? No Is the valve freeze protected? Yes Is the system adequately drained of water? Yes Is the pilot system adequately drained of condensate? Is remote dump switch labeled on deluge svstems? Date of most recent 2" drain test? Yes Yes 1713/85 Static pressure in recent drain test (psig)? 92 Flowing pressure in recent drain test (psig)? 90 Design flow (gpm)? 2123 Design pressure at deluge valve inlet (psig)? 11 Date of last flow test? 10/12/86 Were there plugged heads/corrected? Yes/Yes Are any pilot heads painted? No Is there any missing or damaged pipe? No / ", 3: // Use another page ifyou have more than three systems. (Revised 02/18/94; cmk) 8/9/95; LAD:bwb DO A 033753 CONFIDENT! Al. LOSS PREVENTION AUDIT Page 28 Mechanical Integrity FIRED EQUIPMENT C Yes [x] No[] NA [] Do you have fired equipment (furnaces, TOX, THROX, kilns, boilers)? REFERENCES: Minimum Requirements, LPP 13, Technology Center, Burner Management Guidelines List the type (THROX, TOX, boiler, fired heater, furnace, etc.) and number of each. (LPP 13.1, Appendix B) One Throx Unit B 1. Yes [] No [x] Has your unit had any Burner Management System (BMS) safety incidents in the last three (3) years? If Yes, how many? Be prepared to discuss the incidents and corrective actions taken at the time of the audit. A 2. Yes [x] No [] Is the separation of fired equipment from the process in compliance with LPP 2.2? If not, what protective features are used to address less than recommended distances? ________________________________________ Plans:______________________________________ ___________________ A 3. Complete the audit checklist in LPP 13.1, Appendix C and be prepared to discuss exceptions at the time of the audit. (Please attach a checklist for each fired heater.) Plans:____________________________________________ ________ __ (Revised 02/18/94; cmk) 8/9/95; LAD:bwb DO A 03?754 OONFIDFNTTAl LOSS PREVENTION AUDIT Page 29_____________________ B 4. Provide a copy of your start-up and relight procedures for your fired equipment. B 5. List the conditions that will result in the auto shutdown of the fired unit. A 6. Yes [x] No [] Have you had a Burner Management System Audit? Last Audit Date? Last consolidated audit. 9/92 Plans: What is your plant policy for a Burner Management System Audit Frequency? Once every three years. Frequency of Audit?: Every three years. (Revised 02/18/94; cmk) m/95; LAD:bwb DO A 032755 OONFTDFNTTAl LOSS PREVENTION AUDIT Page 30 1 Mechanical Integrity | CRITICAL INSTRUMENT SYSTEMS REFERENCES: Minimum Requirements, LPP 15.4. A 1. Yes [x] No [] Have your critical and important instrument systems been identified? See definition LPP 15.4.3. If yes, how many are critical? 70 to 100 Plans:_________________________________________________________ A 2. Yes [x] No [] Have test procedures been written? Yes [x] No [] Is your testing up-to-date? Yes [xj No [j Is testing documented? Have records available for inspection. (LPP 15.4.4) Plans: _____ _____ ______________________ B 3. Yes [x] No [] Do you test from the initiating device through the final control element? Discuss: Entire loop is tested from field device to control device. Plans: B 4. Yes [x] No[] Do you have a process control computer? What kind do you have? ModS, TDC, PICSVAX, and Modicon B 5. What would happen if you lost power to your computer? Battery backup would maintain power to the control computers___ (ModS, TDC). UPS system would maintain power to PICSVAX and Modicon. What is the amount of operating time available after power failure? ___ ModS - 24 hours, TDC-never been tested, UPS-1 hour at 84 amps/battery (Revised 02/18/94; cmk) m/95; LAD:bwb oo COhip Tr^TiAl LOSS PREVENTION AUDIT Page 31 Yes [x] No [] Is it adequate? When was your battery back-up last "load checked?" Date Last Checked: Mod5-9/94, UPS-10/93 Yes [x] No [] Have there been any computer failures since the last audit? If Yes, Discuss What Happened: Modserver shutdowns have caused communication programs to halt Plans:___________ _____________ _________ _________. A 6. What controls do you have in place to prevent bypassing critical instruments? Management of Change procedures_________________________ B 7. Yes [x] No [] Is the fail safe position of automatic valves documented? Yes [x] No [] Is the rationale for selecting the fail safe position documented? B 8. Yes [x] No [] Do you have documentation of how control systems are supposed to operate, including set point limits? B 9. When was your last in-depth review of the English language program? Date Last Reviewed: June to August, 1993 as well as periodic Plans: reviews each time a change is made to the control programs_ (most recent 2/9/95) (Revised 02/18/94; cmk) 8/9/95; LAD:bwb LOSS PREVENTION AUDIT Page 32 B 10. When was your last in-depth computer hardware and instrument reliability review? Date Last Checked: Computer-6*10/93 Instrument*2/95 (Quarterly) Plans:___________ _________________________ ____________ A 11. What is department procedure for programming changes involving critical and important instruments? Discuss: All changes must be done through the Management of. Change process________________________________ _______ _ Plans:____________________________________________ (Revised 02/18/94; cmk) 8/9/95; LAD:bwb DO A 007758 OONFTDFNTTAl LOSS PREVENTION AUDIT Page 33 ( Mechanical Integrity | EMERGENCY BLOCK VALVES REFERENCES: LPP 17.1.6. A 1. Yes [x] No [] Are incoming and outgoing headers handling flammable or toxic materials fitted with EBVs at the battery limits? Yes [x] No [] Are the EBV's remotely operated? Yes [x] No [j Are the EBV's on a P.M. program and exercised at least annually? What is the testing frequency? Annually Have documents available at the pre-audit. Plans: ____ __ A 2. Yes [) No [x] 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/toxic gasses or the equivalent amount of vapor fitted with remotely operated EBV's? Plans: ____ __________________________________ 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 EBVs? Plans: (Revised 02/18/94; cmk) 8/9/95; LADrbwb DO A 03?759 GONFTDFNTTAL LOSS PREVENTION AUDIT Page 34__________ B 4. Yes fx] No [] Are EBVs installed around critical equipment such as reactors, furnaces, etc., in case of emergency shutdown? Plans:_____ _____ _____ ______ ______________________ A 5. Yes [x] No [] NA [] Are there remotely operated EBV's on the lines to and from loading and unloading stations when hazardous materials are being handled? Plans: ____________________________________ _____________ ________ B 6. Yes [] No [x] Are flexible unloading joints or swivel joints for tank car and truck loading and unloading for flammable or toxic materials protected on both ends by EBV's ? Plans:______________________________________________________ ___ A 7. Yes [x] No [] NA [] Are EBVs "fail safe" for all utility interruptions? Plans: B 8. Yes [x] No[] NA [] If the valve is in a fire exposure area, is it "fire tested?"* Plans: A/B 9. Yes [] No [x] Are your EBV's identified as per L.P.P. 1.5.5. (painted yellow)? Plans: * Fire tested means approved by a testing agency for fire service. (Revised 02/18/94; cmk) . ^9/95; LAD:bwb r>0 A 0377&0 OONFrOFNTTAI LOSS PREVENTION AUDIT Page 35 Mechanical Integrity STORAGE TANKS REFERENCES: LPP6.11 A 1. Yes [x] No Have all tanks been visually inspected within the last year? (LPP 6.11.8) Check Criteria A 2. Yes [x] No Are tanks in a maintenance testing program? B 3. Yes [x] No Are storage tank non-destructive tests (NDTs) up-todate? B 4. Yes [x] No Is drainage around all tanks adequate to prevent water from getting between the tank foundation and the bottom of the tank? Plans: B Yes [] No [x] Has soil built up around tanks such that the exterior of the tank is in contact with the soil? Plans: A Yes [x] No [] Are all storage vessels electrically grounded? Plans: B Yes [x] No[] NA [] Do tanks have a system to protect against overpressure? Plans: (Revised 02/18/94; cmk) 8/9/95; LA7' ' 'b Dn A 033761 CONFIDENT! Al LOSS PREVENTION AUDIT Page 36 A 8. Yes [x] No [] NA [] Plans: Do tanks have a system to protect against vacuum? A 9. Yes [x] No [] Do you have tanks that have pad/depad systems to maintain inert atmospheres or to maintain positive pressures? (LPP 10.2) Yes [x) No [] If yes, do you prevent the pressure from the pad system from exceeding the design pressure rating of the tank? How? Tanks are protected by PVRV's and ERV*s B 10. What type of material is used for inerting? (LPP 10.2.2) Nitrogen__ What % oxygen is maintained? Not continuously measured B 11. Yes [] No [x] Are your storage tanks in the original service for which they were intended? Yes [x] No [] If no, do they meet the requirements for the present service? Plans: ____________________________________ _______ ________ B 12. Yes [x] No [] Have your vessels been checked to determine if their protective devices are adequate for the service (i.e., fill/empty rates, fire exposure, etc.)? Plans: _______________________________________________________ B 13. Yes [x] No [] Are your tanks protected with redundant level indicating devices to prevent spills? Plans: ______________________________ ___________ ________ (Revised 02/18/94; cmk) 8/9/95; LAD:bwb DO A 03?76>? CONFTDFNTTAt LOSS PREVENTION AUDIT Page 37___________________ B 14. Yes [xj No [] Are automatic shut off systems operated from these devices? Plans:________________________________________ _______________ C 15. Yes [] No [] NA [x] For unstable chemicals, is temperature monitored and alarmed? How would you respond to a temperature rise? ______________ Plans: If not, what parameters of storage are monitored? List:___________________________ _________ ___________ __ Plans: B 16. What preventive maintenance exists for tank protective systems (i.e., levels, temperatures, pad/depads, PVRV's, ERV, and flame arrestors)? PVRV's and ERV's are tested annually. Level indications are tested annually. Plans: B 17. Yes 0 No [x] Does your drain line or any other appendage off the tank extend below the elevation of the bottoms of the tank? If yes, how do you keep water, soil, etc., from coming in contact with this piping? (Revised 02/18/94; cmk) 8/9/95; LAD:bwb DO A CONFtD^NTI At. LOSS PREVENTION AUDIT Page 38 | Mechanical Integrity I PRESSURE VESSELS/RELIEF DEVICES/GLASS DEVICES! EXPANSION JOINTS REFERENCES: Minimum Requirements, LPP 6.5., 6.9, LAD Vessel Program, S-314 A 1. Yes [x] No [] Are all pressure vessels (Pressure Containing Equipment) registered? If no, how many are not? _ Plans:_________________________________________________ _ Yes [x] No [] Do you have any vendor-supplied tanks in your plant? (i.e., the vendor fills) How do you assure mechanical integrity for these vessels? Vendors inspect vessels periodically and replace when necessary. Plans: ,,_______________________________________________________ B 2. 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? (LPP 6.5.4.C) Plans: ________________________________________________ B 3. Who is responsible for managing the pressure vessel testing inspection program in your plant? Todd Hebert (Revised 02/18/94; cmk) 8/9^5; LAD:bwb HO A 030764 CONFTDFNTTAl LOSS PREVENTION AUDIT Page 39 C 4. List any vessels with suspected mechanical integrity problems. None _________________________ Plans: Have current inspection printout on pressure vessel and relief valve status available at the pre-audit. B 5. Who is responsible for managing the pressure relief devices (i.e., valves and rupture discs, vacuum reliefs) program? (LPP 14.3.4) Name? Todd Hebert_____________________________________________ A 6. Yes [x] No [] Are all pressure relief devices registered? (LPP 14.3.4) Plans: _________________________________________________ A 7. Yes [x] No [] Are design calculations on all pressure relief devices don^(Corporate Relief Design Manual) If no, number incomplete? Schedule for completion? _______________________________________ B 8. Yes[x] No [] Is there a file folder for each pressure relief device with registration form, design calculations, specifications and piping isometric sketch? Plans: (Revised 02/18/94; cmk) 8/9/95; LAD:bwb Oo A e CNfTO FNTTAi LOSS PREVENTION AUDIT Page 40 A 9. Yes [x] No [] Have all glass devices in hazardous service been registered? (Texas Safety Standard 0-40) Plans:______________________________ ________________ B 10. Yes [x] No [] Are glass devices in hazardous service adequately guarded? Plans: B 11. Yes [x] No [] Are required inspections, maintenance, evaluation and recordkeeping done for glass devices in hazardous service? (Texas Safety Standard 0-40) Plans: C 12. Yes [] No [x] Does the plant utilize expansion joints in hazardous applications? (Texas Safety Standard 0-43) A 13. Yes [] No [x] Are all expansion joints registered? Plans: _____________________________________________ B 13 a. Yes [x] No [] Are required inspections, maintenance, evaluation and recordkeeping done? Plans: B 14. Yes [x] No [] Does your plant have a test/replacement program for flexible hoses? Plans: _______ (Revised 02/18/94; cmk) 8/9/95; LAD.bwb 03?7^ oo A r.oH'P1 LOSS PREVENTION AUDIT Page 41 ____________________ t Mechanical Integrity | CRITICAL AND ROTATING EQUIPMENT These questions pertain primarily to large rotating equipment but also apply to equipment critical to the operation of the plant (hard to replace, costly). REFERENCES: LPP 16.1. nA/C 1. Yes [x] No Have you identified your critical equipment? (LPP 16.1.2) Plans: B 2. Yes [x] No [] Does the critical equipment list include items such as large and/or unusual motors, transformers, foreign and/or domestic equipment requiring long deliveries? (Centrifuges and Blowers) Plans: B 3. Yes [x] No [] Do you have adequate spare parts to minimize downtime (business interruption)? Plans: B 4. Yes [x] No [] Are spares/spare parts stored in a controlled environment? Plans: B 5. Yes [x] No[] Do you have adequate monitoring/protection devices for your identified critical equipment? (LPP 16.1.4) Plans: (Revised 02/18/94; cmk) 8/9/95; LAD:bwb DO A 032767 conftdfntjai LOSS PREVENTION AUDIT Page 42 HP B 6. Yes [x] No [] Do you have vibration monitors? Plans: __________________ ___________ B 7. Yes [x] No [] Do you have an on-going preventative maintenance program? (LPP 16.1.5) Please describe: Lube oil lab, MTS, and vibration group routinely test critical rotating equipment. Plans: _______________________ A 8. Yes [] No [x] Do you have dead-head protection on all pumps? (LPP 16.4.) Describe: Dead-head protection via ARC valves on all mag drive pumps. Plans: B 9. Yes [x] No [] Are stainless steel bolts a problem because of potential process or atmospheric corrosion? If so, how do you control their use? Piping specifications (Revised 02/18/94; cmk) 8/9/95; LAD:bwb D & 03 conftdfNtta( LOSS PREVENTION AUDIT Page 43_______________ I : Mechanical Integrity \ MANAGEMENT SYSTEMS REFERENCES: OSHA Process Safety Management (1910.119, Paragraph J) A 1. Yes [x] No [] Do you have written procedures to assure on-going integrity of process equipment? (i.e., pressure vessels, EBV's, fire protection systems, etc.) Plans: A 2. Yes [x] No [) Are the employees involved in maintaining the on-going integrity of process equipment given an overview of the process and its hazards, and trained in the procedures applicable to their job. Plans: ________ ________ ________ __________ ______ __________ A Yes [x] No [] Do inspection and testing procedures follow Dow site Division guidelines? Plans: A Yes [x] No [] Do the frequency of inspections and tests of process equipment meet accepted Dow site or Division guidelines? Plans: A Yes [x] No [] Are all inspections and tests documented as per Dow guidelines? Plans: (Revised 02/18/94; cmk) 8/9/95; LAD:bwb 00 A 03F7A9 C0NFIDFNTJA1. LOSS PREVENTION AUDIT Page 44 ________________ A 6. Yes [x] No [] Are suspected deficiencies corrected in a safe and timely manner after necessary means are taken to assure safe operations. Plans: _________ ______ A 7. Yes [x] No [] In the construction of new plants and equipment, is equipment fabricated according to Dow site or Division standards and suitable for the process application for which they will be used? Plans:___________ ___________________________ _________ A 8. Yes [x] No [] Are appropriate checks and inspections performed to assure that equipment is installed properly and consistently with design specifications? Plans: ,,___________________________________________ ___ ______ __ B 9. How do you assure that maintenance materials, spare parts and equipment are suitable for the process application for which they are being used? Piping specifications are used for all maintenance jobs. Spare parts are individually coded in the MSMS system ior each piece of equipment. Plans: _________________________ ________________ ________ ____ B 10. How do you assure the proper materials of construction are used in maintenance and new projects? Plans: Piping specifications and Management of Change standard (Revised 02/18/94; cmk) 8/9^5; LAD:bwb DO A 030770 CONF"fr)FNTT Al LOSS PREVENTION AUDIT Page 45 B 11. Yes [x] No [] Do you have a list of the proper gaskets for each part of your process? (LPP6.6) Plans:_______ Yes [x] No [] Is gasketing covered in your piping specification? (Revised 02/18/94; cmk) 8/9/95; LAD:bwb A 03777 CONFTOPNTTA1 LOSS PREVENTION AUDIT Page 46 Mechanical Integrity PIPING, PUMPS, COMPRESSORS REFERENCES: Pipeline Technology Center (Angleton, TX), Dow Pipeline-Texas Operations only (Freeport, TX) Texas Safety Standard M-72 B 1. Yes [x] No [] Do you have accurate drawings showing the routing of your pipelines? B 2. How often are your pipelines inspected? Annually B 3. Yes [x] No [] Are all your pipelines well identified and maintained? A 4. Yes [x] No [] Has definite ownership, including predictive, preventative maintenance (PPM) responsibilities, been clearly defined between the origin and termination of your pipelines? B 5. Yes [x] No [] If more than one owner is involved for outside-blocklimits pipelines, does each concur in writing with your interpretation of the extent of ownership? B 6. Yes [x] No [] Do you have records showing the design criteria for each of your pipelines (material of construction, MAWP, operating pressure, coatings, etc.)? Where is the information kept? Pipe specs and P&ID's (Revised 02/18/94; cmk) 8/9/95; LAD:bwb DO A 00P7 C.ONFTDFNTT IN <L LOSS PREVENTION AUDIT Page 47 B 7. Do you have a scheduled and documented periodic program for maintaining your pipelines for: Yes [x] No [] N/A [] Painting? Yes [xj No [j N/A [j Cathodic Protection? Yes [xj No [j N/A [j Ground Interface Deterioration? Yes [xj No [j N/A [j Surveillance? B 8. Yes [] No [x] Are your pipelines in the original service for which they were designed? B 9. Yes [x] No [] Do you maintain a record of pipeline repairs? B 10. Where are the repair records kept? Champs system and equipment files____________________ ___________________________ " B 11. If another owner is responsible for working on/repairing one of your outside-block-limits pipelines, how do they know the hazards (if any) associated with your materials? N/A B 12. Yes [x] No [] N/A [] When work is performed by others on lines adjacent to yours, do you inspect the repair scene to assure the integrity of your piping has not been compromised? B 13. Yes [] No[x] N/A [] Within the last 5 years, has your coated buried piping been free of leaks or other problems? If "NO", what type (material) of coating was involved? Tar paint,____ however, the cathodic protection was determined inadequate. B 14. Yes [] No [x] Other than visually, can you determine if your pipeline is leaking? (Revised 02/18/94; cmk) 8/9/95' ' D:bwb HO A 032773 CONFIDFNT T Al. LOSS PREVENTION AUDIT Page 48 B 15. Yes [x] No [] Do you have written contingency plans for handling leaks from your outside-block-limits pipelines? B 16. Yes[] No[] N/A[x] If more than one owner is involved, do they concur with your emergency contingency plans? B 17. Yes[x] No[] In a pipeline emergency, will you, as the owner, normally respond? B 18. Yes[] No [] N/A [x] If others are expected to respond, have they been included in training/planning necessary to handle a pipeline leak with your materials? B 19. Yes [] No [x] Is there a list of owner contacts available to those responding to the emergency? B 20. Yes [] No [x] Is the list of contacts dated and periodically updated? B 21. Yes [] No [x] Is Distribution E/R included on the "pipeline emergency" call list? B 22. Yes [x] No [] N/A [] If you handle flammable or combustible materials, are there provisions for grounding containers at the take-off point stations? B 23. What concerns do you have about your pipeline systems? Some lines (methanol, M2) are not on shoes. Some lines (M2, M3,__ and methanol) are underground at road and dike crossings. (Revised 02/18/94; cmk) 8A>/95; LAD:bwb DO A 032774 CONFTDFNTTAl. LOSS PREVENTION AUDIT Page 49 Management of Process Change/Project Reviews \ MANAGEMENT OF CHANGE REFERENCES: U.S. Area Standard No. 2, OSHA 1910.119 (1) A 1. Yes [x] No [] Does your plant's program for Management of Change include a written procedure which complies with Dow's U.S. Area Standard No. 2? A 2. When was your last audit for compliance with the Management of Change Standard? (Date) 11/94 Yes [x] No [] Have all recommendations from your last audit been closed? Please furnish documentation of your last audit findings. B 3. What is the involvement of your operation and maintenance personnel in the Management of Change process? Dow operations and maintenance can originate an MOC. First reviewers can be either be supervisor or engineer level persons. A 4. Please provide documentation of several completed checklists used for process changes during the pre-audit. A 5. Yes [x] No [] Are all employees, Dow as well as contractor, informed of and trained for process changes that affect them prior to the initiation of the change? How? The MOC sheet is followed and communication is required prior to start-up of the change. (Revised 02/18/94; cmk) 8/9/95; LAD:bwb nn a 03?775 LOSS PREVENTION AUDIT Page 50 | Management of Process Change/Project Reviews ~] PROJECT REVIEWS REFERENCES: Minimum Requirements, U.S. Area Standard No. 2 A 1. Yes [x] No [] Does your department have Engineering Project Reviews or other Project Review Processes? Who is involved? Superintendent, production supervisors, engineers, and supervisors.__________________________________ B 2. Describe your process for handling recommendations from the project reviews. Changes in projects are made by the project manager or manufacturing representative as discussed in the reviews. Please furnish documentation for the follow-up from these recommendations. B 3. Describe how new projects are integrated into the plant's operating discipline. Economics on new projects are reviewed in monthly project meetings. The projects are discussed and a decision is made to either carry out, hold, or eliminate the project. (Revised 02/18/94; cmkj 8/9/95; LAD:bwb On A 037776 OONFTDFNTTAI, LOSS PREVENTION AUDIT Page 51 1 E. Pre-Startup Safety Review 1 REFERENCES: Site Specific Standards, Dow Minimum Requirements, June 1989, OSHA 1910.119(i) A 1. Yes [x] No [] Do you have a Pre-startup Safety Review for all new facilities or changes to existing facilities? Plans: A 2. Do the pre-startup reviews address the following: a. Yes [x] No [] Construction and equipment in accordance with design specifications? Plans: b. Yes [x] No [] Safety, operating, maintenance and emergency procedures are in place and are adequate? Plans: c. Yes [x] No [] Have the recommendations from the project review process been completed or considered? Plans: d. Yes [x] No [] Recommendations from the plant Process Hazard Analysis have been resolved and implemented prior to startup? Plans: Please provide documentation for 2.a.b.c.d. (Revised 02/18/94; cmk) 8/9/95; LAD:bwb OO A 037777 CONFTDFNTT Al LOSS PREVENTION AUDIT Page 52________ A 3. Yes [x] No [] Do you verify that training for all employees involved in operating the process has been completed prior to start up? Plans:_________ ________ Please provide documentation. (Revised 02/18/94; cmk) 8/9/95; LAD:bwb HO A 032778 CONFIDENTIAL LOSS PREVENTION AUDIT Page S3 | Emergency Planning and Response | REFERENCES: Minimum Requirements, OSHA 1910.119 (n), OSHA 1910.38 Texas Operations Emergency Plan and Rough Weather Plan A 1. Yes [x] No [] Are copies of your Unit Emergency Plan available to all personnel? Plans: _______________________________ ________ A 2. Yes [x] No [] Are all copies up-to-date? Last update: 1/94______________________ Plans:____________________ ______ _ B Who updates the plan? Safety Coordinator Plans: _____ ______________________ __ Does the plan include: l - Yes [] No [] NA [] - Yes [] No [] Zo 2o - Yes [] - Yes [] - Yes [] Non - Yes [] nod na n z> z> z> z> - Yes [] - Yes [] - Yes [] - Yes [] Non Non No [] no n Emergency Call List? Procedure for switching to alternate for each utility? Procedure for total loss for each utility? Crash shutdown procedures? Time Required: Orderly shutdown procedure? Time Required: Procedures in case of neighbor plant problems? Procedure for loss of raw materials? Gas release procedures? Scenarios in CAER/MIDAS Program Spill procedure? (Revised 02/18/94; cmk) 8/9^5; LAD:bwb DO A 03P779 OONFTDFNTTAI May 28,1996 Loss Prevention Audit Section F. * Emergency Planning and Response These items were originally left blank. Here are the updated responses and explanations. 4________Does the plan include: Yes B No Emergency Call List. Yes n No Q N/A 0 Procedure for switching to alternate for each utility. Yes 0 No O Crash shutdown procedures Yes H No Yes E No n Orderly shutdown procedures Procedures in case of neighbor plant problems. Yes 0 No Procedures for loss of raw materials. Yes 0 No D Yes B No Gas release procedures. Scenarios in CAER/MIDAS. Yes El No Yes 0 No Q Liquid release spill procedure. Reactive chemicals Incident Procedures. Yes E No Yes B No Yes B No D Yes E No Yes H No Yes E No Yes El No Yes |2 No Yes El No 0 Fire fighting plans for each type of fire. Emergency communications plan. Chain of command defined. Escape procedures and routes. Procedures for post-evacuation employee accounting. Preferred means to report emergencies. Duties and procedures of employees who: Remain to operate critical equipment. Perform rescue and medical duties. The names for persons or locations to contact for more action plan information. The CMP phone list will be put on the Windows Express Procedure System CMP does not utilize alternate utilities. We do have back-up air from the Division but no action is required. If any utility is lost, that section of plant affected will go to safe shutdown. The MODS code for thermal and the Modicon logic for hydro and the Throx will cover any emergency crash shutdown taking everything to its fail safe position It will take 1-2 hours to secure the plant. All are in place. It will take 1-2 hours to secure the plant. We cocoon in all situations. If the situation gets bad enough, we added a line in Emergency plan which states that we will be directed by security if we ever need to evacuate our block. The MODS code for thermal and the Modicon logic for hydro and the Throx will cover any loss of raw materials which will result in an immediate shutdown taking everything to its fail safe position A statement was added to the spill procedure. These were run and copies filed in our records. However, they were not deemed appropriate to be added to the Division MIDAS system by Buck Bailey and Delaine Rawlings, 6/4/96. A statement was added to the spill procedure. The Top 10 worse case scenarios have been defined and reactive chemical comments have been added to our critical procedures. This is in our Emergency Plan. We have emergency radios in addition to plant radios and phones. This is in our Emergency Plan. This is in our Emergency Plan. This is in our Emergency Plan. This is in our Emergency Plan. This is in our Emergency Plan. This is in our Emergency Response Procedure.. This is in our Emergency Plan. Vic McMurray CMP DO A 03?7fi0 CONFTDFNTT Al LOSS PREVENTION AUDIT Page 53 ____ F. Emergency Planning and Response REFERENCES: Minimum Requirements, OSHA 1910.119 (n), OSHA 1910.38 Texas Operations Emergency Plan and Rough Weather Plan A 1. Yes [x] No [] Are copies of your Unit Emergency Plan available to all personnel? Plans: ________________ 2. Yes [x] No [} Are all copies up-to-date? Last update: 1/94_______________________ Plans: B 3. Who updates the plan? Safety Coordinator, Plans: A 4. Does the plan include: (If not, be prepared to discuss why.) - Yesfl No D - Yes [] No [] NA WA 1 D Emergency Call List? Procedure for switching to alternate for each utility? No [] No D Procedure for total loss for each utility? Crash shutdown procedures? Time Required: hi teJtf No [] Orderly shutdown procedure? Time Required: DNo NA [] Procedures in case of neighbor plant problems? D 0- Yesfl No NA Procedure for loss of raw materials? No [] NA [] No D NA No 0 NA 0 Gas release procedures? Scenarios in CAER/MIDAS Program - (-jaoe ru/\ Spill procedure? rwf added (Revised 02/18/94; cmk) S/9/95; LAD:bwH DO A 037781 CONFIDENT! Al. LOSS PREVENTION AUDIT Page 54 ____ - Yes 0 No D - Yesfl No D - Yes H No D - Yesfl No [] - Yes 0 No [] - Yes fj. No [] NA NA [] NA [] NA [] NA a NA n - Yes 0 No [] Reactive Chemical Incident Procedures? Fire fighting plans for each type of fire? Emergency communications plan? Chain of command defined? Escape procedures and routes? Procedures for post-evacuation employee accounting? Preferred means to report emergencies? - Duties and procedures of employees who: Yesfe No [] NA a Remain to operate critical equipment? Yes 0 No [] - Yes R- No D NA NA an Perform rescue and medical duties? The names for persons or locations to contact for more action plan information? Field Note Reference(s): B 5. Yes [x] No [] Is there a documented emergency plan training and retraining program? If yes, please describe: Annual emergency drills with operations. The drills are reviewed, improvements suggested, and the results are communicated to everyone. Plans: _________________________________________________________ A 6. Yes [x] No [] Is training up-to-date and documented for all employees? Plans:__ _____ B 7. Yes [x] No [] Does each employee participate in at least one hypothetical drill or table top each year? (Suggest a toxic scenario and flammable scenario.) List the hypothetical emergencies for the past year: Plans: (Revised 02/18/94; cmk) 8/9/95; LADrbwb 00 A 03P78? GONFTDFNTTAI LOSS PREVENTION AUDIT Page 54 - Yes [] No D NA D - Yes [] No [] NA [] - Yes [] - Yes - Yes [] No No [] No [] NA [] NA [] NA [] - Yes U No [] NA [] - Yes [] No U Reactive Chemical Incident Procedures? Fire fighting plans for each type of fire? Emergency communications plan? Chain of command defined? Escape procedures and routes? Procedures for post-evacuation employee accounting? Preferred means to report emergencies? - Duties and procedures of employees who: nYes [] No NA [] Remain to operate critical equipment? D nYes No NA [] Perform rescue and medical duties? - Yes D No a NA U The names for persons or locations to contact for more action plan information? Field Note Reference(s): B 5. Yes [x] No [] Is there a documented emergency plan training and retraining program? If yes, please describe: Annual emergency drills with operations. The drills are reviewed, improvements suggested, and the results are communicated to everyone. Plans: A 6. Yes [x] No [] Is training up-to-date and documented for all employees? Plans:_______ B 7. Yes [x] No [] Does each employee participate in at least one hypothetical drill or table top each year? (Suggest a toxic scenario and flammable scenario.) List the hypothetical emergencies for the past year: Plans: (Revised 02/18/94; cmk) 8/9/95; LADrbwb AO A 032783 CONFTOFNTTAt LOSS PREVENTION AUDIT Page 55____________ B 8. Yes [x] No [] NA [] Do you meet with Fire Department (Emergency Services) and discuss fire fighting plans and hazards for your plant periodically? Plans: During consolidated audit preparation B 9. Where are vital records kept and how are they protected? Equipment files and documentation is maintained in file cabinates in building 4601.__ B 10. Yes [] No [x] Do you have emergency drills involving neighboring plants? Plans: ______________________________________________________ A 11. Yes [x] No [] Are contractors adequately trained in emergency procedures? Plans: ____ A 12. Are emergency horns: - Yes [x] No [] Distinctive for each purpose of the alarm? - Yes [x] No [] Capable of being perceived above ambient noise and light levels by all employees in the affects portions of the workplace? - Yes [x] No [] Distinctive and recognizable as a signal to evacuate the work area or perform actions designated under the plant? - Yes [x] No [] Maintained in operating condition? - Yes [x] No [j Tested appropriately and restored to normal operating condition as soon as possible after test? - Yes [x] No [] Unobstructed, conspicuous and readily accessible, if they are manual alarm systems? (Revised 02/18/94; cmk) 8/9/95; LADibwb A 032784 CONFIDFNTTAl . .ANUFACTURING UNIT RISK ANALYSIS SUMMARY ! AftEA/CO UNTRY North America SITE Louisiana Divisioi PREPARED BY Steve Ledoux Process Unit Major Material Storage Sphere T-814 Methyl Chloride DIVISION LOCATION Louisiana Division manufacturing unit Plaquemine, La. TYPE OF OPERATION Chlorinated Methanes TOTAL MFG. UNIT REPLACEMENT VALUE $135 MM Manufacturing DATE 4/13/95 Material Factor F&EI Value of Area of Exposure $MM Base MPPD (1) $MM Actual Days MPPD (1) Outage $MM MPDO (2) Bl (3) Loss $MM 21 84 $1.30 $0.86 $0.41 12 $0.29 Storage Tank T-251 Methanol 16 45 $1.00 $0.41 $0.29 10 $0.23 MeCI Distillation C-1500 Methyl Chloride 21 42 $4.00 $1.97 $0.94 20 $0.47 ermal Chlorinator -i&aro &-130O Methyl Chloride 21 56 $4.00 $2.21 $1.05 22 $0.51 T/C Load Rack Methyl Chloride 21 92 $4.00 $2.77 $1.48 27 $0.62 MeCI Condensing D-1250 21 53 $1.00 $0.54 $0.26 9 $0.22 Methyl Chloride THROX R-750 Methane 21 116 $5.00 $3.81 $2.33 35 $1.16 Storage Blk. 43 Methyl Chloride 21 48 $1.50 $0.78 $0.39 12 $0.40 Hydrochlorinator R-250 Methyl Chloride 21 77 $15.00 $9.59 $4.96 55 $1.82 ' .) Maximum Probable Property Damage (2) Maximum Probable Days Outage 13) Business Interruption A 033785 CONF JOFNT TAI