Document ymd9GMoNb9MedDXJozex73xLV

1992 CAD CONSOLIDATED AUDIT CEI REVIEW PRESENTATION DOCUMENTATION JULY 1992 CEI PRE-AUDIT QUESTIONNAIRE DO A 046909 CONFTDFNTTAL A. OPERATING PROCEDURES 1. Does the plant have checklist that are used to shutdown and clear equipment/piping to insure that the contents are not left in the equipment, or accidentally released into the environment? NO (See reference #1) b. How is this function accomplished? The checklist/procedures are done on a job by job basis. c. What are the plant's plans for doing this in the future? To continue on as is. 2. Does the plant have checklist that are used for starting up out of service equipment/piping that insures that no raw material, process streams or product will be accidentally released into the environment? YES (See reference #2) 3. Does the plant have procedures for the initial opening of lines and equipment? YES (See reference #3) 4. Does the plant have procedures that define exactly who is 'esponsible for the operation, inspection and maintenance of adjacent and intra/interplant pipelines and associated equipment? NO. WE CURRENTLY USE THE DIVISION PIPEWAY POLICY B-5. WE WILL DEVELOP A LIST THAT DEFINES WHO IS RESPONSIBLE FOR THE OPERATION, INSPECTION AND MAINTENANCE OF INTRAPLANT PIPELINES. B. PLANT COMMUNICATIONS 5. Does the plant have up-to-date emergency call list? YES (See reference #4) 6. Does the plant have written notification procedures for the following emergencies? (See reference #5) a. Gas Release? YES no A 046^1o OONF T DT NT T Ai 6. cont. b. Spill? YES c. Fire? YES d. Emergency Response? e. Other? - Hurricane YES YES 7. Does the plant have procedures for establishing contact with field headquarters during an emergency? YES. The emergency plan details who should carry the radios and maintain contact with field headquarters. (See reference #5) C. AREA MONITORING SYSTEMS 8. Does the plant use an area monitoring system for toxic materials? KBS' (See reference #6) a. How often are these monitors checked and calibrated? They are checked and calibrated to five ppm monthly. 9. Are plant personnel trained to respond to alarms from area monitors? YES We train people informally on shift. We will develop a IPT module to better accomplish this function. D. PLANT PIPING SYSTEMS 10. Does the plant monitor corrosion in the piping systems of the facility? YES (See reference #7) a. How is monitoring done? A visual inspection is completed semiannually by operations as part of our C9 program. 11. Does the plant have areas in the piping system that requires constant or repetitive repairs? YES a. Please describe what is being done to prevent recurrence. We try to upgrade piping as moneys allow. 040911 DO A OONFT qFNTT Al 12. Does the plant have a preventive maintenance program in place to monitor the integrity of the piping system? NO. Beau Dunn, our new PPM coordinator, will be developing this program. 13. Are outside-the-block material distribution systems monitored for leaks? YES (See reference #7) a. How is this done? Operations walk out every line leaving our block. This is required by out C9 program. b. How frequently? Every six months. 14. Do the plant's toxic material distribution systems undergo pressure testing on a routine basis? PARTIALLY. We try to pressure test line and equipment during shutdowns or whenever it is practical. (See refemece #2) 15. Do the plant's toxic material distribution systems have prominently displayed phone numbers for the notification of problems and emergencies? YES (See reference #7? E. PLANT MECHANICAL EQUIPMENT 16. What kind of pumps does the plant use in toxicTservice? H2S04 - MAG DRIVE CHLORINE - CANNED PUMPS CCL4 - NO PUMPS - NITROGEN PRESSURE 17. Are these the kind of pump systems that will minimize leak potential? YES 18. Does the plant have a preventive maintenance program in place for mechanical equipment? YES (See reference #8) 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; 00 A 04091 GONF T DFNT T A 19. cont a. Plant operators? NO b. Supervision? YES c. Other affected employees? NO d. Process Engineering? YES e. Safety and loss Prevention? NO f. Environmental? NO g- Adjacent plant supervision? NO 20. Have your reviews included all possible scenarios that would be deemed "major releases", affecting the public beyond the Dow fence line? YES 21. Does the plant conduct routine, periodic "what if' emergency drills on the release of toxic chemicals? YES a. Is each shift involved? YES b. Do supervisors participate? YES - PLANT SUPERINTENDENT c. Is there a regular schedule for these exercises? YES THIS IS IN OUR SAFETY PROGRAM. d. Is Industrial Security involved in these practice drills in any way? SOMETIMES e. How often are the drills conducted? QUARTERLY f. When was the last time your plant had a planned emergency drill involving the release of a toxic gas or liquid? 1ST QTR 92 g. What chemical was used in your last planned emergency drill? CAUSTIC h. Have you used different toxic or odorless chemicals in previous drills? YES (See reference #9) 22. Does the plant have a formalized training program for those people who conduct periodic inspections of concerned facilities? NO - WE NEED TO DEVELOP A LPT MODULE TO ADDRESS THIS CONCERN. 23 How do you insure that "lessons to be learned" from incident investigations are passed on to all concerned personnel? WE DO THIS THROUGH SAFETY MEETINGS AND COMMUNIQUES. (See reference #10) 00 A 04^91 oonftdfimttai Does the plant have written procedures detailing how to mitigate releases of toxic chemicals in the plant? YES plant periodically hese procedures and methods for i id spills or gas releases from the facility? rence #5) ________ r __ eviewed its emergency response personnel protective equipment inventory with Industrial Hygiene? YES Our Industrial Hygiene contact, Dale Crochet, has kept the Industrial Hygiene department informed of our equipment. If at any time Dale has a question relating to this topic, he calls the department. 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? YES a. Is it kept at strategic locations for ease of access in case of emergency? YES (See reference #5) Are there checklist employed for the periodic inspection, maintenance, and testing of the plant emergency equipment? YES (See reference #11) a. How often? VARIES b. Who does it? OPERATIONS Are all plant personnel trained in the proper use of the various personnel protective equipment employed for combating liquid spills, gas releases, and fires? YES a. How often? YEARLY b. How is this training documented? THIS IS PART OF OUR C9 PROGRAM. (See reference #12( 00 A 046914 OONFTDFNTTAl. 29. How many people are involved in training on the proper emergency response to a liquid/vapor chemical release of concern? a. Operations 32 b. Supervision 08 c. Others 06 d. Total of above 46 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? NO Please describe what the plant does in the event of one of these emergeneiesrahcf future p of a. rele^selfy one of Che surromn e protected by our current emei equip DO A 046915 CONFTDFNTTAL EURPORflTION UJflSH PROCEDURE D-511, E-511, E-512, & E-513 - EQUIPMENT NEEDED: 2 - 2 10OO GALLON FRAC TANKS 2 - DIESEL PUMPS 1 - SUMP PUMP 2 - DOW OPERATORS TO FOLLOW JOB PRE WASH: D REMOVE E-51 I & E-512 POPPING VALVES 2) INSTALL BB WITH 2" BLEEDS ON VESSEL SIDES OF POPPING LINE ,) INSTALL BB ON LINE SIDE ( LEAVE LOOSE FOR PURGING) 4) REMOVE E-513 OH BV 5) INSTALL BB ON LINE SIDE ( LEAVE LOOSE FOR PURGING) 6) INSTALL BB WITH 2" BLEED ON VESSEL SIDE 7)-INSTALL BB ON D-51 1 OH SNIFF : 8) INSTALL SB ON LINES TO D-51 1 PSVS 9) INSTALL SB ON LIQUID CL2 TO D-51 1 1.0) REMOVE AND BB BOTH LEVEL TX TAPS ON D-51 1 1.1) REMOVE AND BB PRESSURE TX TAP ON E-513 ' 7) REMOVE AND BB BOTH LEVEL TX TAPS ON E-51 1 _ DO A 046)93 6 CONFTDFNTT Al WASH HOOKUP: 1) HOOK UP WASH INLET AT 2" BLEEDS ON E-5 1 1 AND E-5 12 POPPING VALVES 2) HOOK UP WASH OUTLET ON 2" BLEED AT E-5 13 OVERHEAD OUTLET 3) START CONDENSATE FLUSH 4) CONTINUE TO WASH FOR 30 MINUTES 5) SYSTEM IS NOW READY FOR HIGH PH WASH 6) WAIT UNTIL INLET AND OUTLET PH'S ARE THE SAME 7) DRAIN SYSTEM 8) DO P/W FLUSH 00 A 046917 OONFIDFNTTAI