Admin PD ISO

April 11, 2019 VIA EMAIL

Mr. Robert Rhode Lead EH&S Delivery Manager The Dow Chemical Company P.O. Box 1398 Pittsburg, CA 94565

Dear Mr. Rhode:

Subject: Preliminary Determination Audit Report for The Dow Chemical Company - CalARP Program Audit

Contra Costa Health Services Hazardous Materials Programs (CCHSHMP) has addressed the comments received on April 5, 2019, regarding technical inaccuracies within the Administrative Draft of the Preliminary Determination for the California Accidental Release Prevention (CalARP) Program audit for The Dow Chemical Company’s facility (Dow) located in Pittsburg, California. With this letter, CCHSHMP has now issued the Preliminary Determination for the audit that took place from October 1, 2018 through October 19, 2018. Attached to this letter is the Preliminary Determination report in its entirety.

Dow has 90 days, or by July 10, 2019, to respond in writing to CCHSHMP with proposed remedies and due dates to address the corrective actions identified. CCHSHMP is providing you with an electronic copy of the Summary of Action Items and Summary of Consider Items tables as enclosures to this letter to assist with this process.

Please contact me at 925-335-3226 if you have any questions.

Sincerely,

Habib Amin Habib Amin, Ph.D., P.E., CHMM Accidental Release Prevention Engineer

Enclosure (VIA EMAIL)

PRELIMINARY DETERMINATION

The Dow Chemical Company 901 Loveridge Road

Pittsburg, California 94565

Site ID: 729798

April 11, 2019

HAZARDOUS MATERIALS PROGRAMS

AdPD_Dow_100118_2019.doc April 11, 2019

Preliminary Determination

Contra Costa Health Services Hazardous Materials Programs (CCHSHMP) conducted an audit/inspection of the Dow Chemical Company (Dow), located at 901 Loveridge Road in Pittsburg from October 1, 2018 through October 19, 2018. CCHSHMP is required to conduct an audit/inspection per Sections 2775.2 and 2775.3 of the California Accidental Release Prevention (CalARP) Program Regulations (Title 19 Division 2 Chapter 4.5 of the California Code of Regulations). CCHSHMP conducted the audit/inspection in accordance with the Audit Plan for the California Accidental Release Prevention (CalARP) Program Audit/Inspection. This plan describes pre-audit, audit, and post-audit activities and is included in Attachment A. The completed questionnaires (e.g., “A11 – Process Safety Information”), including the basis for each recommended action item, are included as Attachment B. There may be questions receiving “R” answers that were not assigned an action. In these instances, a previous corrective action will address the identified deficiency. Additionally, CCHSHMP conducted interviews of approximately 18 employees and approximately 12 subject matter experts (those employees with responsibility for developing and or implementing one of the programs required by the CalARP Program regulations). Trends from these interviews are included in the “Findings” column of the questionnaires.

CCHSHMP appreciates the cooperation from Dow management and personnel during the audit and interview process. The participants were open in their discussion and helpful and exhibited high safety awareness and pride in the facility and company.

CCHSHMP reviewed the management system at the Dow Pittsburg facility and confirmed that a management system is in place to oversee compliance with various regulatory programs like CalARP. Dow assigned the various elements within these regulations to select individuals onsite under the direction of key program leaders: 1) Regulated Process Leader, 2) Environmental, Health & Safety (EH&S) Leader, 3) Engineering & Technology Leader, 4) Maintenance Leader and 5) Learning Leader. The Site Director has ultimate responsibility to ensure that the site meets all CalARP regulatory programs.

The site leadership meets regularly with senior management to communicate how well the facility is performing related to the CalARP program element compliance. This allows senior management to be apprised of any issues, so they can assure that proper resources are assigned and maintained. Metrics are used to gauge how well a program element is being managed and are typically viewed monthly at different levels of the organization. The facility has a process to report incidents and near misses to all employees including senior management. CCHSHMP found no CalARP programs on site with deficiencies significant enough to be attributable to a lack of resources or inadequate management commitment, except for compliance audit program which needs improvements as described below.

There needs to be a management system developed to verify employee participation in development of the prevention program elements. The management also needs to track compliance audit action closures and document completion dates when the deficiencies were corrected. Dow management should work to correct the deficiencies identified in this program,

AdPD_Dow_100118_2019.doc April 11, 2019

as listed in A18. Dow also needs to document all PHA findings and the corresponding recommendations and maintain them including their resolution for the life of the process. This item is further described in A12-28.

CCHSHMP identified 1 deficiency and 10 partial deficiencies in existing programs at the facility. This audit report identifies the corrective actions generated to correct all the deficiencies in Attachment C.

CCHSHMP also generated 17 corrective actions to improve upon programs that already comply with the requirements of the CalARP Program Regulations. These corrective actions begin with “consider” and are optional for Dow to incorporate. This audit report identifies all the suggestions to improve upon programs that already comply with the requirements of the CalARP Program Regulations in Attachment D.

Audit Reporting Process

Once CCHSHMP has completed an audit, an Administrative Draft of the Preliminary Determination report is issued, and the audited stationary source has 14 days to respond in writing to identify any technical and factual inaccuracies. If no written technical or factual inaccuracies are received, the Administrative Draft will then become the Preliminary Determination report. Once the Preliminary Determination has been issued, the stationary source has 90 days to respond in writing and provide proposed remedies and due dates to address the identified corrective actions. The stationary source can also identify which recommendations, if any, will be rejected in whole or in part. For those recommendations rejected, the stationary source shall explain the basis for the rejection and provide substitute revisions.

Upon receipt, CCHSHMP reviews the proposed remedies, due dates, and any rejections proposed and will communicate any final revisions to the stationary source. Once CCHSHMP agrees, the Summary of Actions Items Table contained within Attachment C and the Summary of Consider Items Table contained within Attachment D are modified to include the proposed remedies, due dates, and other approved revisions. A 45-day public review process begins after this time. After the conclusion of the public notice period and incorporation of any relevant public comments, the written Final Determination is issued.

Upon completion of the action items, the stationary source will provide CCHSHMP with a status update. The status update does not need to include actual copies of the documented resolutions (i.e. studies, updated policies, training documentation, etc.), but rather an overview of the actions taken to address the action items along with actual dates of completion.

ATTACHMENT A

Audit Plan for the California Accidental Release Prevention (CalARP) Program Audit/Inspection

Audit/Inspection Plan for the California Accidental Release Prevention (CalARP) Program

Prepared for:

The Dow Chemical Company North End of Loveridge Road

Pittsburg, California 94565

Site ID: 729798

August 28, 2018

Prepared by:

HAZARDOUS MATERIALS PROGRAMS

CalARP Audit Plan August 28, 2018 1

I. INTRODUCTIONThis document describes the plan for conducting a comprehensive audit/inspection of the programs,policies, and procedures developed by The Dow Chemical Company (Dow), located in Pittsburg,California, to satisfy the requirements of the California Accidental Release Prevention (CalARP)Program (Title 19 California Code of Regulations, Division 2 Chapter 4.5). A generic audit plan,including pre-audit/inspection, on-site audit/inspection, and post audit/inspection activities isincluded in Appendix A. This audit plan describes the pre-audit/inspection activities for the Dow.

II. ALLOCATE RESOURCESAccidental Release Prevention Engineers Habib Amin, Miguel Rizo, Robert Long, Kevin Ong andCho Nai Cheung will conduct the audit/inspection. The audit team will conduct qualityassurance/quality control (QA/QC) on the work plan and Written Preliminary and Written FinalDeterminations. The audit responsibilities will be distributed through the completion of thefollowing questionnaires:

Questionnaire Program Level 1

Responsibility

• A11 – Process Safety Information 3 Rizo • A12 – Process Hazard Analysis 3 Cheung • A13 – Operating Procedures 3 Long • A14 – Training 3 Rizo • A15 – Mechanical Integrity 3 Ong • A16 – Management of Change 3 Long • A17 – Pre-Startup Review 3 Long • A18 – Compliance Audits 3 Cheung • A19 – Incident Investigation 3 Amin • A20 – Employee Participation 3 Ong • A21 – Contractors 3 Amin • A22 – Emergency Response Program 1, 2, 3 Rizo • S1 – Hot Work Permit 3 Amin • S3 – Lockout / Tagout 3 Ong

Contra Costa Hazardous Materials Programs (CCHMP) will require one meeting room to accommodate the audit team members (i.e., ideally the room would be equipped with a table and sufficient electrical outlets for laptop computers). CCHMP will also require two or more meeting rooms to accommodate simultaneous employee interviews on scheduled days.

III. PURPOSE & SCOPEThe primary purpose of this audit/inspection is to evaluate Dow’s capability to effectively meet therequirements of the CalARP Program regulations, to verify the status of previous audit action items,and to identify potential regulatory deficiencies or areas where improvement is warranted. Asecondary purpose of the audit is to ensure that the Risk Management Plan (RMP) accuratelydescribes the accidental release prevention programs currently being implemented at Dow. Finally,CCHMP may identify areas of the accidental release prevention program that may be improvedbased on generally accepted practices and guidelines. All non-mandatory action items will beginwith “Consider…”.

1 - Refers to what CalARP Program levels (1, 2, or 3) applies to the questionnaire


The physical scope of the Dow audit/inspection includes the following covered processes as identified in the RMP:

- Block 310, Sulfuryl Fluoride (Program 3) [Hydrogen Fluoride, Sulfur Dioxide, Chlorine, Hydrogen Chloride]

- Block 520, Chlorine Storage (Program 3), Anhydrous Ammonia SCR (Program 3) [Chlorine, Ammonia]

- Block 560, Ag Chemical Intermediate (Program 3) [Chlorine]

- Block 640, Ag Chemical Intermediate (Program 3) [Aqueous Ammonia]

- Block 660, A & B Process (Program 3) [Chlorine, Hydrogen Chloride]

- Site Logistics, Railcar Storage (Program 3) [Chlorine, Hydrogen Fluoride, Sulfur Dioxide]

The historical scope of this audit/inspection is from the effective date of the CalARP Program regulations, August 19, 1996, to October 3, 2018, the starting date of this audit/inspection. The regulatory scope of this audit/inspection includes the requirements included within the CalARP Program regulations (T19 CCR Division 2 Chapter 4.5). The CalARP Program regulations also reference the following regulations: T8 CCR §3220 Emergency Action Plans T8 CCR §5192 Hazardous Waste Operations and Emergency Response T8 CCR §5189 Hot-Work Permits/Procedures T8 CCR §5194(g) SDS Requirements under Hazard Communications T8 CCR §2320/3314 Lockout/Tagout In addition to the preceding requirements, the following sources will be utilized in assessing compliance and formulating action items during the audit: • Contra Costa County CalARP Program Guidance Document • Accidental Release Prevention Requirements: Risk Management Programs Under the Clean

Air Act, Sections 112(r)(7) Parts III and IV of 40 CFR Part 68 • Pre-amble Part III of 40 CFR Part 68 • CAA Section 112(r) Frequently Asked Questions • Sections 25531-25543.3 of the California Health and Safety Code • Pre-amble to the OSHA PSM standard, 29 CFR §1910.119 • Questions and Answers to the Cal/OSHA PSM standard, T8 CCR §5189 • OSHA Instruction CPL 2-2.45A CH-1 Program Quality Verification Checklist • OSHA 3132, Process Safety Management, 1994 (Compliance Audits) • OSHA 3133, Process Safety Management Guidelines for Compliance, 1994 (Compliance

Audits) • Guidelines for Auditing Process Safety Management Systems, Center for Chemical Process


Safety, AIChE, 1993 Acceptance criteria for the audit/inspection will be determined on a case-by-case basis. CCHMP will determine whether the deficiencies represent isolated incidents (in which individual deficiencies would be identified to correct) or trends (in which program deficiencies would be identified to correct). CCHMP may take photographs in the field as part of the facility audit records. IV. QUESTIONNAIRES Dow has six Program 3 covered processes under the CalARP Program regulations. As a result, questionnaires associated with CalARP Program 3 will be completed (CalARP Program 3 questionnaires to be completed were identified in Section II of this Audit Plan and are included in Appendix B). The sampling size for the records will be determined on a case-by-case basis. CCHMP shall document the findings, including documents reviewed (see Appendix D) and records sampled, in the “Findings” column. The “Clarifications” column provides guidance to the auditors including suggested documents to review and interpretations from federal OSHA and federal EPA. CCHMP shall then provide the answer to the question in the “Answer” column. The following codes shall be applied: • Y Full compliance with all requirements of the question • N No compliance with the question’s requirements • P Partial compliance with the requirements • R An action item is listed elsewhere with cross reference • N/A The question is not applicable to the facility CCHMP shall develop a list of actions to resolve potential deficiencies in the risk management program or to resolve discrepancies between the risk management program and the RMP. These and other regulatory deficiencies are required to be addressed and will begin with “Ensure”. CCHMP may also develop a list of actions to improve a risk management program based on generally accepted practices or guidelines. These actions are non-mandatory and will begin with “Consider”. If no actions are developed, CCHMP shall enter “None”. V. EMPLOYEE & “KEY PERSONNEL” INTERVIEWS CCHMP shall meet with Dow personnel to review an organizational chart of employees and the existing shift schedule. CCHMP shall then identify approximately 5-10% of the employees to interview including personnel from operations, maintenance, and engineering. Employees shall also be notified that they may have union representation present, if they choose. Any employee not selected, but whom would like to be interviewed, will also be interviewed. Interviews will last approximately 30 minutes. CCHMP shall also meet with “key personnel” responsible for each CalARP Program requirement. The following “key personnel” were identified on the organizational chart on page 10 of the Executive Summary of the 7/14/14 RMP:


• Environmental, Health & Safety Leader • Emergency Services & Security Group • Engineering Leader • Maintenance Leader • Learning Leader • Site Committee and Team Members as necessary • CalARP Element Focal Points CCHMP will conduct procedural and/or P&ID walk-downs with qualified operators in the field during this audit. These walk-downs are anticipated to be in lieu of some or all of the sit down employee interviews and include an assessment of the relative accuracy of the written documents based on field observations and input from site personnel. Written notes of these walk-downs will be provided to Dow for their records. These walk-downs should be treated as personnel interviews and be without the presence of management and supervision. CCHMP will meet with local union representatives, as applicable, at the stationary source at the beginning of the audit/inspection. CCHMP will also meet with personnel to discuss the management system in place necessary to implement the CalARP Program and include a summary of this in the completed audit report. VI. AUDIT SCHEDULE CCHMP will begin the audit/inspections with an opening meeting to discuss the audit process and answer any specific questions by Dow. CCHMP encourages the attendance of all Dow CalARP Program key personnel, management staff, and union representatives (if applicable). Tentative Overall Schedule The on-site audit/inspection activities will start: October 1, 2018: 9:00 a.m. – 9:30 a.m. CCHMP Safety Orientation @ Dow 9:30 a.m. – 12:00 p.m. Opening meeting. An agenda is included in

Appendix D. 1:00 p.m. – 4:30 p.m. Audit CCHMP shall schedule weekly debriefings with Dow representatives, beginning the week of October 1, 2018. Preferably, the debriefings will be held in the late afternoon. During the debriefings, CCHMP will discuss their current draft findings and action items. Completion of all on-site audit/inspection activities is anticipated to be on or before October 19, 2018. This date may change depending on the circumstances. Dow may be able to rectify potential deficiencies before the conclusion of the audit/inspection. These deficiencies will still be included in the written report,


however, they will be identified as rectified.

VII. DOCUMENTS TO BE REVIEWEDCCHMP may request and review the documents listed in Appendix C during the on-site portion ofthe audit/inspection. Dow is expected to have this information compiled and available prior to theaudit/inspection.

VIII. PUBLIC COMMENTSCCHMP has concluded the public notice/comment period per §2745.2(c) and §2745.2(d) of theCalARP Program regulations for Dow’s RMP on April 1, 2016 and no comments were received.

IX. SITE SAFETY PLANCCHMP shall wear personal protective equipment (PPE) as appropriate (i.e., hard hat, safetyglasses/goggles, steel toed shoes, Nomex coveralls, hearing protection). CCHMP will not enter any areas where respiratory protection is required. CCHMP shall be escorted throughout the facility bypersonnel who are knowledgeable of the facility’s emergency action plan (i.e., evacuation routes,headcounting procedures, alarms).

CalARP Audit Plan A - 1

APPENDIX A OVERALL AUDIT PLAN

AUDIT ACTIVITIES

CCHMP followed the internal procedure, “Conducting Audit/Inspection Protocol”, adapted from the Guidelines for Auditing Process Safety Management Systems (Center for Chemical Process Safety, AIChE, 1993) for developing this work plan and for conducting the audit. This procedure includes specific tasks for three phases of the audit: Pre-Audit/Inspection, On-site Audit/Inspection, Post-Audit/Inspection. The specific tasks to be completed are as follows:

Pre-Audit/Inspection Activities

Allocate resources a. Select audit team members with the following attributes: auditing skills, knowledge

of the process, diligence, perceptiveness, thoroughness, objective, unbiasedb. Provide audit team members as needed with copies of the audit/inspection

questionnaires, objectives, sampling strategies, and secondary reference materialsc. Schedule the conference and meeting rooms required for the initial, daily, and closing

debriefing sessions; the employee interviews; and team meeting roomsd. Acquire any required audit equipment/software (i.e., computers, software for

recording, documentation forms, printers, copiers)

Clearly identify objectives of the audit/inspection a. Assign audit/inspection team members to programs to be reviewed based on

familiarity with the CalARP Program regulations, the processes, and availabilityb. Clearly identify “final products” from each of the audit/inspection team members

(i.e., agree on documentation format and ensure consistency with audit/inspectionreport and the trade secret policy)

Determine the scope of the audit/inspection a. Identify the physical scope of the audit/inspection – clearly identify the covered

processes that will be included in the evaluation and their boundariesb. Identify the historical scope of the audit/inspection under the CalARP Program – the

starting date of the program is August 19, 1996, the effective date of the CalARPProgram regulation. The starting date of subsequent audits, perhaps due to coveredprocess modifications, will be determined.

c. Identify the regulatory scope of the audit/inspection – the audit/inspection includesthe requirements of the CalARP Program regulation, Title 19, Division 2, Chapter4.5. The CalARP program regulation also references the following regulations:

T8 CCR§3220 Emergency Action Plans T8 CCR§5192 Hazardous Waste Operations and Emergency

Response T8 CCR§5189 Hot-Work Permits/Procedures


T8 CCR§5194(g) MSDS Requirements under Hazard Communications

d. Determine acceptance criteria for the audit (i.e., if one record out of 100 sampledshows that the written procedure was not followed does this constitute a finding andwarrant a recommendation)

Plan and organize the audit/inspection a. Develop (i.e., identify and revise as necessary) the questionnaires to be used by the

audit team members. This includes all questionnaires listed in Appendix B.b. Compile all secondary reference materials (e.g., OSHA Instruction 2-2.45A CH-1,

CAA Frequently Asked Questions, industry standards and techniques fromprofessional groups such as AIChE, ASME, Chlorine Institute, IIAR)

c. Determine documentation methodology (i.e., consistency in use of wording andcolumns) and audit team member’s deliverables (e.g., working papers, softwareprintout, interview information)

d. Determine sampling size and strategy for records (e.g., stratified).e. Schedule employee interviews and meetings with key personnelf. Schedule opening and closing meeting start times and participantsg. Schedule debriefing meetings, as needed.

Collect background information, as needed, from the list in Attachment G of Conducting Audits/Inspection Protocol (see Appendix D) Stationary sources may elect not to submit confidential business information (CBI) to CCHMP prior to the on-site portion of the audit. These documents will therefore need to be reviewed during the on-site portion of the audit, possibly increasing the duration of the audit. If the stationary source elects to submit CBI to CCHMP, it will be handled in accordance with the Trade Secret Policy.

Review public comments and written responses developed in accordance with Section 6.6 of the RMP/Safety Plan Completeness Review Protocol Also review any other comments or questions submitted by the public regarding the regulated source. All of the public comments should be available in each regulated source’s files under RMP/Safety Plan Completeness Review and Public Notices and Comments, and Written Responses to Comments.

Finalize audit/inspection scope, objectives, and methodology a. Develop a written audit plan. Follow the format included in Attachment I of

Conducting Audits/Inspections Protocol.b. Circulate the written audit plan to audit team members and to the regulated sourcec. Revise the written audit plan to reflect the audit team members’ and the regulated

source’s comments

On-site Audit/Inspection Activities The audit team leader is responsible for ensuring that the audit team members conduct the following activities/tasks.


Conduct opening meeting a. Discuss the audit objectives, scope, methodology, and schedule for the auditb. Conduct a tour of the stationary source with stationary source escorts (optional)c. Identify personnel who are responsible for the implementation of the various

elements of the program. Establish schedule, as necessary, for audit team membersto meet with personnel to discuss the programs and review records, and to conductP&ID and/or Procedure walk-downs as applicable

d. Receive any necessary safety training (emergency evacuation procedures) andspecialty PPE (e.g., alert monitors, escape respirators)

Review programs, policies, and procedures associated with the CalARP program including, but not limited to, those documents listed in Attachment G of Conducting Audits/Inspections Protocol

a. Identify any findings or potential deficiencies between the existing programs,policies, and procedures and the developed protocol

b. Identify any findings or inconsistencies between the existing programs, policies, andprocedures and the written RMP

c. Formulate action items to rectify any identified potential deficiencies orinconsistencies

Collect and record data to verify that the regulatory requirements are being met and that the stationary source programs, policies, and procedures are being implemented

a. Perform records reviews using the selected sampling strategies discussed inAttachment H of Conducting Audits/Inspections Protocol

b. Conduct an on-site conditions inspectionc. Perform interviews with selected management, operations, and maintenance

personneld. Perform and document the activities denoted with an asterisk (*) in the Clarifications

column of the protocol. The Clarifications column includes information fromOSHA, EPA, OES, and professional organizations that may or may not be applicableto the stationary source being audited. The auditors should use judgement inapplying the guidance.

e. Conduct procedural walk-downs in the field with qualified personnel as appropriateto verify accuracy of select procedures

f. Conduct P&ID walk-downs in the field with qualified personnel as appropriate toverify accuracy of select P&IDs

Document the audit/inspection a. Audit findings and action items should be written to “stand alone”b. The regulatory basis that supports the ensure action items (e.g., §2755.1) must be

identified in the question, findings, or referenced at the end of the ensure actionc. Action items should not be written to constrain the regulated source, in the event that

better alternatives may be availabled. Clearly differentiate between action items necessary for compliance and items

beneficial to safety but not necessary for compliance (These actions are non-mandatory and will begin with “Consider”)


e. Audit findings and action items should be objectively documented. Avoid making legal conclusions, characterizing conduct, or inappropriate connotations (e.g., grossly negligent, unprofessional operating practices, appalling)

f. Ensure that all findings and action items are true. Avoid speculating (e.g., “it appears”) or expressing opinions (e.g., “I believe”)

Evaluate audit information by applying the acceptance criteria Document “Y”, “P”, “N”, “R”, “N/A” in the “Answer” column of the questionnaire for each question. Avoid making conclusions based on a statistical summary (e.g., the stationary source is 60% in compliance with the CalARP Program regulation) because some audit questions are more indicative of a successful accidental release prevention program than others.

a. Acceptable (i.e., full compliance with the acceptance criteria): “Y” b. Incomplete (i.e., partial compliance with the acceptance criteria): “P” c. Negative (i.e., no compliance with the acceptance criteria): “N” d. Cross Reference (i.e., an action item is listed elsewhere): “R” e. Not applicable (i.e., acceptance criteria not applicable): “N/A”

Incorporate public comments into the questionnaires where appropriate.

Post-Audit/Inspection Activities The audit team leader is responsible for ensuring that the audit team members conduct the following activities/tasks. Prepare audit/inspection report and send to stationary source

a. Gather all audit/inspection documentation from audit team members b. Consider all public comments on the RMP formulated during the formal public

review (§2745.2 of the CalARP program regulations c. Generate a “written administrative draft preliminary determination” of necessary

revisions, including an explanation for the basis of the revisions, reflecting industry standards and guidelines (such as AIChE/CCPS Guidelines and ASME and API standards) to the extent that such standards and guidelines are applicable.

d. Distribute the written administrative draft preliminary determination to at least one other member of the audit team for that stationary source for a quality control review.

e. Address technical or factual inaccuracies, if necessary, in the written administrative draft preliminary determination as appropriately identified by the stationary source and then issue the written preliminary determination. Both the written Administrative Draft and the Preliminary Determination should be sent to the stationary source via email or certified mail.

f. Work with each regulated source to ensure the accuracy of the written preliminary determination. The regulated source may reject revisions, in a written response, and may propose a substitute recommendation. Documentation of meetings, including all agreements and points of contention shall be documented and maintained in each regulated source’s file. Unresolved issues between the CalARP team members and the regulated source will be handled in accordance with the Dispute Resolution Policy.


g. Both the written administrative draft preliminary determination and the written preliminary determination are public documents and shall be made available for review upon request.

Verify the implementation of proposed corrective actions from the stationary source CCHMP will review proposed remedies and due dates from the stationary source identified to address the action items and consider items formulated from the audit/inspection. The status of each resolution should be recorded in the appropriate column of the report. CCHMP will take enforcement action, in accordance with the Enforcement Policy, if the resolution status review demonstrates that the Stationary Source is not implementing the action items in a timely fashion as agreed upon.

CalARP Audit Plan B - 1

APPENDIX B QUESTIONNAIRES

(See Completed Questionnaires in Attachment B)

Copies of the complete questionnaires are included in this Appendix. The column titled “Type” identifies whether a question is included as an abridged question by the “Abr” notation. For this audit, CCHMP will focus on answering those questions with the abridged notation; however, retains the discretion to answer additional questions or even entire questionnaires based on information uncovered during the onsite audit.

CalARP Audit Plan C - 1

APPENDIX C DOCUMENTATION TYPICALLY REVIEWED DURING AN AUDIT

The following is a list of documents normally reviewed during a CalARP Program audit/inspection. Information tagged with a (*), or samples of this information, may be asked for in advance of the audit/inspection. All other information should be available for review during the audit/inspection. The documentation shown in bold may be available, to some extent, in the RMP; however, more detailed information may be required. Stationary sources may elect not to submit confidential business information (CBI) to CCHMP prior to the onsite portion of the audit.

Background Information * Plant/process descriptions* Plant plot plan* Plant CalARP program manual* Plant organization chart* List of covered chemicals* Rationale for covered and non-covered processes* Rationale for any claimed regulatory exemptions

Management System * Description of CalARP Program* Designation of responsible management* CalARP program policy statement and the Environmental Health and Safety Policy• Plant policies manual• Objective evidence of management commitment and leadership* CalARP program performance criteria* CalARP program progress reports* Description of system to track CalARP program action items• Records from tracking CalARP action items• Injury and illness log for employees• Evidence of communications of the CalARP program within and outside the company

Process Safety Information/Safety Information * PFD's or block flow diagrams• Process chemistry• Maximum intended inventory• Safe upper and lower limits for key operating parameters• Evaluation of consequences of process deviations• Materials of construction• P&ID's• Electrical classification* Process descriptions for covered processes• MSDS's for regulated substances• Engineering documents that list/show:

- codes and standards used in design and construction


- ventilation system design for process buildings, control rooms, other areas where peoplemay be located

- relief system design and design basis (more detailed than just data sheets)- material and energy balances- safety systems (e.g., interlocks, detection and shutdown systems)

• Documentation that equipment complies with recognized and generally accepted goodengineering practice (RAGAGEP)

* Listing of names of operators* Listing of names of engineers and areas of responsibility* Listing of names of maintenance technicians and engineers and areas of responsibility

Process Hazard Analysis/Hazard Review * Priority order for plant PHA's and documentation thereof* Schedule for plant PHA's* PHA manual or procedure* Rationale for selecting PHA technique(s) used• PHA reports (current and all previous)• PHA worksheets (current and all previous) and associated supplementary data* Listing of PHA team members with areas of expertise (may be part of PHA reports)• Documentation of PHA training for team members and team leaders* Description of system used to manage PHA recommendations• Records from managing PHA recommendations

Operating Procedures * Guidelines for generating, modifying and controlling operating procedures including format

and content* List of operating procedures for initial startup, normal operations, temporary operations,

emergency shutdown, emergency operations, normal shutdown, startup following aturnaround, startup after an emergency shutdown

* List of safe work practices including lockout/tagout; lifting equipment over process lines;capping over ended valves; opening process equipment or piping; excavation; control overentrance into a facility by maintenance, contractor, or other support personnel

* List of safe work practices for contractors• Annual certification of procedures• Operating procedures

Training * Description of training program (initial and refresher)• Training materials (initial and refresher)• Records of employee training (initial and refresher)• Certification of training where appropriate• Frequency of refresher training and documentation of employee consultation


Contractors * Contractor safety program • Records on contractor selection • Records on contractor use • Documentation of information communicated to contractors * Safety Manual for contractors (both employer and contractor) • Documentation of periodic contractor CalARP performance evaluation • Documentation of periodic contractor CalARP training evaluation • Documentation of actions taken to correct contractor deficiencies • Documentation showing control of contractor plant entry and egress • Injury and illness log for contract employees • Records of training of contractors (from Contract Employer) • List of names of contractor employees used Pre-startup Review * PSR procedure * PSR checklists • Completed PSR's Mechanical Integrity/Maintenance * MI program management policy document or procedure * Rationale for exclusion of any systems, equipment, or instrumentation • Relevant portions of manufacturers' manuals, codes and standards * List of maintenance procedures • Maintenance procedures • Documentation on use of MI procedures * Description of training program for process maintenance activities • Training materials • Records of employee training • Training certification documents for employees where appropriate • Inspection and test procedures (including instrumentation) • Records, including results, of inspection and testing • Description of system used to track the mechanical integrity program • Records on correction of deficiencies * Quality assurance program and procedures for new plants and equipment • Quality assurance records * Procedures for control of spares and other equipment and materials Hot Work Permit * Hot work permit procedure • Completed permits * Description of training for hot work activities • Records of employee training • Training certification documents for employees where appropriate


• Documentation of communication to contractors on hot work permitting programs

Management of Change * MOC procedure• MOC records

Incident Investigation * Description of II procedure* Lists of names for any II teams, past and present* Listing of incidents• Incident investigation reports* Description of system used to manage II findings• Records from tracking II report findings• Documentation on consultation with affected employees and contractors on II results

Compliance Audits * Audit procedure* Copies of any previous compliance audits (at least the two most recent audits)* Action plans from any previous audits* List of auditors and their areas of relevant expertise for previous audits• Records from tracking compliance audit findings• Triennial certification

Employee Participation * Employee Participation Plan• Records of employee participation in the prevention program elements of the CalARP

program

Emergency Response Program * ER plans• Evidence of compliance with T8 CCR 5192 where applicable* Designation of personnel who will respond to an emergency• Training records for these personnel* Designation of personnel who will assist with emergency evacuation• Training records for these personnel• Records documenting communication of ER plan to employees* Description of alarm system• Test and maintenance records for alarm system• Debriefings on any ER plan activations• Debriefings on any ER drills or exercises• Documentation of inspection, testing, and maintenance of emergency equipment• Copy of Consolidated Contingency Plan if applicable

CalARP Audit Plan D - 1

APPENDIX D OPENING MEETING AGENDA/REMARKS

I. IntroductionsII. Assess compliance of programs with CalARP regulations & confirm accuracy of the RMP.

A. CalARP Program Regulations1. 6 Program 3 processes2. 0 Program 2 processes3. 0 Program 1 processes

B. May identify “non-compliance” findings and develop “non-mandatory” action items. Thesewill be included in the report and begin with “consider”. CalARP Program regulationsrequires that we provide the basis for all ensure action items

C. If there is an action item that is resolved before the conclusion of the onsite audit, the actionitem will still be included in the report, but will be modified to identify it has already beenresolved

III. Approach – standard audit using all abridged questionnairesA. NEW – Conduct operating procedure and P&ID walk-downsB. Review documentation and meet with Key Personnel (To find out how the programs are

designed/supposed to function)1. Schedule meetings with Key Personnel

C. Verification of documentation1. Sample records – sample size will depend on number and importance of the records2. Conduct employee interviews – look for any trends

a. Schedule/ random selection (different shifts, different jobs, various lengthsof employment, etc.) – ideally 5-10%

b. If any employees want to talk with us that are not selected, let them knowthey can schedule time with us

c. Employees interviews are confidential – “no right or wrong answers”; themain purpose is to verify if employees were involved in certain tasks thatare required by regulations such as incident investigations, PHA teams; no“trick questions”; we take notes but names are not written down; interviewsusually lasts approximately 30 minutes

D. Expected duration of the on-site portion of the audit is 3 weeks. CCHMP may takephotographs in the field as part of the facility audit records

E. Weekly debriefings to discuss findingsF. Complete questionnaires (same format as RMP completeness review)G. October 19, 2018 is the expected audit completion date and closing meetingH. Administrative Draft “Preliminary Determination” within four to eight weeksI. Facility will have fourteen days to review draft for factual inaccuraciesJ. “Preliminary Determination” issued and facility will have 90 days to submit proposed

remedies and due dates to address any deficienciesK. Begin 45-day public notice period after CCHMP agrees to proposed remedies and due datesL. Schedule public meeting

ATTACHMENT B

Completed Questionnaires

A11 - CalARP Prevention Program: Process Safety Information (Program 3)

ID# Category Question Clarifications Findings Answer ActionsType

A11-02 Program 3 CalARP & ISO

Did the PHA team members have access to the compiled PSI while conducting the PHA? [T19 CCR §2760.1(a) & Section 450-8.016(a)(1)(A)]

* Review the PHA report and interview members of the PHA team to ascertain whether PSI was made available during the PHA.

As described in A11-11, the RC/PHA team members are provided a description of the process, block flow diagram, site map, compatibility chart and the process chemistry. Team members have access to all PSI including P&IDs as needed via electronic data management system.

Y NoneAbr


Does the information pertaining to the hazards of the regulated substances include reactivity data and chemical compatibility data during handling, use and application at the stationary source? [T19 CCR §2760.1(b)(4)& Section 450-8.016(a)(1)(A)(i)]

1. MSDS's must be supplemented with process chemistry information, including runaway reaction and overpressure hazards, if applicable [OSHA 3133, PSM Guidelines for Compliance, 1994] or [29 CFR 1910.119 Appendix C].

The facility maintains the SDS on the facility's online database, per interview with Operations personnel employees have access to the SDS via online database. Contra Costa Health Services Hazardous Material Program (CCHMP) performed a live navigation with the PSI SME and confirmed that all the covered process chemicals were listed in the eMSDS link, that is specific to the Pittsburg site. Per CCHMP request, Dow provided copies of the following SDS

-Ammonia, (Airgas) rev. 0.11 -Chlorine (K2 Pure) rev. 11/12/13 -Sulfur Dioxide (teckcominco) rev. 11/2/2004 -Hydrogen Fluoride (Honeywell) 11/06/15

CCHMP confirmed all the SDS had a Section 10 "Stability and Reactivity" of the SDS listed above. The Chlorine SDS lists incompatible materials, and conditions to avoid, examples include hydrogen fluoride should not be used with silica/glass products, sodium hydroxide is incompatible with strong alkalis, and ammonia reacts with oxidizers.

Y NoneAbr

Page 1 of 9Dow Chemical- 2018 CalARP Audit Findings11-Apr-19



Does the information pertaining to the hazards of the regulated substances include the hazardous effects of inadvertent mixing of different materials that could foreseeably occur? [T19 CCR §2760.1(b)(7) & Section 450-8.016(a)(1)(A)(i)]

* Look for written information regarding chemical incompatibility or reactive chemistry.1. Most MSDSs do not list all other chemicals that could be at the stationary source. If documentation is not found, recommend that the stationary source “consider” developing an “incompatibility or reactive chemical matrix”. [CCHMP Interpretation]

As discussed in A11-06, Section 10 Stability and Reactivity of all the SDS/MSDS, contain information regarding materials that are incapability.

Additionally, DOW has developed and maintains "Compatibility of Chemicals Chart" for each of the plants with covered processes. At a minimum all the matrix charts contained compatibility/reactivity information cross referenced with all other chemicals found within the plant. However CCHMP notes each chart varied in available information presented, some charts had NFPA rating class, absorbent, lubricant, and piping. The facility should consider establishing a minimum standard of information that is required for the compatibility matrix. CCHMP notes there is a lack of consistency in the compatibility designation, including varying colors, symbology (number & characters), descriptions, and number of designations used. The facility should consider adapting a common practice across all process "compatibility designations" including a consistent numbering/lettering, use of color, and description of designation. CCHMP believes that varying format may pose a human factors issues, for employees that have to work on multiple blocks (e.g. maintenance employees).

Below is a list of chemical compatibility charts reviewed and the information type presented/compared:

-MEI, rev. 4/3/2017 (absorbent, lubricants) -Chloropyridines, rev. 10/1/2018 (metal, pipe, PCE, gaskets, lubricants, insulation, sealants, absorbents, cleaners, chemicals)

Y NoneAbr



-FPI 560 block (metals, lined pipe, PCE, lubricants, coating, insulation, sealants, absorbents, chemical) -AFTF (NFPA rating, absorbents, chemicals) -Sulfuryl Fluoride (NFPA rating, absorbent, chemicals) -Manufacturing Services (NFPA rating, metals, pipe, PCE, gaskets, lubricants, chemicals) CCHMP notes per field observation, the compatibility charts are posted in the control rooms and accessible to operator and contract personnel.


Does the information pertaining to the technology of the process include process chemistry? [T19 CCR §2760.1(c)(1)(B) & Section 450-8.016(a)(1)(A)(iii)]

The process chemistry for 310 SF is detailed in the RC/PHA. The facility maintains the information pertaining to the technology and process chemistry in the RC/PHAs. CCHMP reviewed the RC/PHA for Block 310 SF, page 7 of which describes the process overview including the raw material storage, front end reaction, distillation & product storage, warehouse bottling and utilities. Appendix C contains the MEI Process and Trace Chemistry description. CCHMP verified similar information was also available in the Block 310 AFTF process.

Y NoneAbr




Does the information pertaining to the technology of the process include the maximum intended inventory? [T19 CCR §2760.1(c)(1)(C) & Section 450-8.016(a)(1)(A)(iii)]

1. Sources for vessel maximum capacity information could include a placard attached to the tank, documents from the manufacturer of the tank, log sheets, and the business plan.2. Trade association or industry standard may recommend limiting the usable volume of a vessel (e.g., tank not to be filled to more than 85% capacity). [CCC CalARP Program Guidance Document]

Dow maintains a document onsite titled "2018 AB2185 Combined Report/Hazardous Materials Inventory Data" that contains a listing of all the Tanks with both the Tank max inventory and the average inventory. The values presented in the table match the values reported to CERS. CCHMP reviewed the max daily / daily average. -Sulfur Dioxide (986,672 / 488,893 lbs) -Hydrogen Chloride (57,060 / 28370 lbs) -Hydrogen Fluoride (1,017,203 / 774,224 lbs) -Chlorine (7,616,823 / 4,804,605 lbs) -Anhydrous ammonia (4,000 / 2,560 lbs) -Aqueous Ammonia (27%) (151,578 / 75,289 lbs)

Aqueous ammonia was speciated in the table by all the concentrations, including 27% concentration, and lower concentrations including 13% aqueous ammonia (T-1301), and 1% (T-13003).

The table lists includes the Chemical Abstract Service (CAS) for materials. Per CCHMP review, the Ammonia aqueous CAS is identified as "7732-18-5" which is water. The SME flagged the error and intends to correct the error.

CCHMP notes that the values presented in the RMP, on page 3, table II-A (July 2014), lists Aqueous Ammonia at only 27%, and not at its lower concentrations. The RMP should include all the concentrations of aqueous ammonia that are above the regulated threshold including the 12,000 lbs of 13% aqueous ammonia concentration in (T-1301). Note the regulated threshold for aqueous ammonia is 500 lbs dry weight, so the facility should determine which concentrations qualify as "regulated"

P Ensure to update the RMP to include the total amount of aqueous ammonia (dry weight) for all concentrations.

Abr



substance.

Per follow-up interview with the EH&S Leader, the quantity reported in the RMP is mixture weight of the aqueous ammonia solution (water / ammonia) and not the total dry weight of ammonia. The RMP is intended for the regulators, the information within should only report only the regulated material, in this case the ammonia, not the solution mixture weight. The RMP needs to include the total amount of aqueous ammonia (dry weight) for all concentrations. Including the 12,000 lbs of 13% aqueous ammonia concentration in (T-1301).


Does the information pertaining to the technology of the process include safe upper and lower limits for such items as temperatures, pressures, flows, or compositions? [T19 CCR §2760.1(c)(1)(D) & Section 450-8.016(a)(1)(A)(iii)]

The facility maintains documentation of the Key Operating Limits, for all the operating blocks. CCHMP reviewed Key Operating Limits for 560 Block (rev. 8/29/18), Chloropyridines (rev. 5/31/16), L3F-Man Services (rev. 7/13/18) 9, MEI (rev. 7/24/18), and 310 Block (rev. 11/30/17). The Key Operating Limits list the temperature, level, flows and pressure limits for key equipment for each process and the limit associated with the process parameter. For each process deviation listed, the table includes the hazard, consequence and immediate actions required by the operator. Per interview with Operators, the Key Operating Limits are reviewed during training and are included in their "Board of Review" exam.

Y NoneAbr




Does the information pertaining to the equipment in the process include materials of construction? [T19 CCR §2760.1(d)(1)(A) & Section 450-8.016(a)(1)(A)(iv)]

1. Old/used equipment: analysis and/or testing appropriate to the new service with revised documentation of PSI is required [OSHA co-sponsored PSM workshops in Spring, 1993] [OSHA Instruction CPL 2-2.45A CH-1 Appendix B - Clarifications and Interpretations of the PSM standard, September 13, 1994].

The facility uses DOW global piping specification standards, which specify material of construction for each process. The specifications are established by various tech centers, Agricultural Intermediate (AI), Environmental (EN), Chlor-Alkali(CA). CCHMP randomly selected line specifications from the P&ID drawings, for the covered process. CCHMP reviewed the following line/pipe specifications

-Pipe Spec (CA-03) rev 02/06/18 (chlorine) -Pipe Spec. (AI-26) rev. 08/08/18 (HF) -Pipe Spec. (AI-25) rev. 05/15/18 (HF) -Pipe Spec (EN-03) rev. 01/30/18 (NH3)

Per CCHMP review of the specification the facility appears to be consistent with ASME B31.3. This includes performing pressure tests, sensitive leak test, and NDE (RT, UT, PT, MP). The material of construction are identified by ASTM, and component

Y NoneAbr


Does the information pertaining to the equipment in the process include relief system design and design basis? [T19 CCR §2760.1(d)(1)(D) & Section 450-8.016(a)(1)(A)(iv)]

1. PSV's are critical safety equipment and information that supports PSV design and specification are critical to maintain - simple data sheets are not enough, calculations or other detailed documents are required [OSHA co-sponsored PSM workshops in Spring, 1993] [OSHA Region VI presentation on PSM in January, 1994].

The facility maintains the original design specification for all the relief devices. CCHMP reviewed the design basis for the following relief devices: R-1462, R-73, R-74, R-29, R-30, R-31 and R-79. Each of the design specification included the relief scenario (assumptions), one or two phase relief, equation method, simulation data, dynamic head loss (pressure drop) calculations. CCHMP notes that relief devices were designed to either provide thermal relief as well as pressure relief.

Y NoneAbr




Does the information pertaining to the equipment in the process include ventilation system design? [T19 CCR §2760.1(d)(1)(E) & Section 450-8.016(a)(1)(A)(iv)]

1. Ventilation systems pertain to the control rooms or wherever personnel may be located. The ventilation system must be such to protect the personnel within the buildings. [CCHSHMP Interpretation]

DOW has developed multiple corporate standards to address ventilation system requirements, CCHMP reviewed standard "Loss Prevention Program (LPP) 12.1 Pressurization for buildings" 12.1 (rev. Aug. 2016) and "LPP 12.2 Occupied Buildings Subject to Process Hazards" (rev. Aug 2016). LPP 12.1 defines the requirements for design, installation, maintenance, and alarms for "Pressurization," a defined protection technique. LPP12.1 scope "provides requirement for pressurization of buildings including, but not limited to, control building, control rooms or other buildings, where there is a potential to have flammable and/or combustible gases or vapors, or combustible dusts, enter the building or room area but it is not intended preventing the influx of toxic and corrosive materials from entering a building or a room.

CCHMP reviewed LPP 12.2, which describes requirements and best practices to protect building occupants per API RP 752: explosions external to an occupied building or room, thermal radiation from pool or jet fires, and toxic releases. Section 4, covers the mandatory shelter in place requirements for the building, including rapid ventilation shutdown, communication, sealing building penetrations, and toxic gas detection warning limits.

DOW has performed ventilation review for the covered process control rooms. CCHMP reviewed the design basis for two Building 310 (9/17/03) and Building 565 (12/5/01) for 560 block. The documents provide an overview summary of the system, recommendations and compliance with Loss Prevention Program LPP 12.1 which mainly addresses flammable

Y NoneAbr



materials and not specifically toxic and corrosive materials. Per CCHMP review of the ventilation studies some items (e.g. system shut down limits) have been addressed, specific release scenarios have also been addressed in the PHA. Per review, CCHMP feels that ventilation design generally meets and addresses requirements in LPP 12.2 requirements.

The facility performs an LPP review every 5-years to ensure they are in compliance with the requirements. CCHMP reviewed the 550 block compliance checklist for LPP 12.1 and LPP 12.2.


Does the information pertaining to the equipment in the process include design codes and standards employed? [T19 CCR §2760.1(d)(1)(F) & Section 450-8.016(a)(1)(A)(iv)]

Pressure vessels greater than 15 psig are built to ASME BPVC, U1 stamps are maintained on the reactors and pressure vessels. Equipment is generally designed to ASME codes and Chlorine Institute recommendations. Heat exchangers are designed to TEMA and ASME BPVC. A third party onsite contractor maintains machinery design and seal designs.

Y NoneAbr


Does the information pertaining to the equipment in the process include material and energy balances for processes built after June 21, 1999? [T19 CCR §2760.1(d)(1)(G) & Section 450-8.016(a)(1)(A)(iv)]

1. PSM regulations require facilities to develop material and energy balances for processes built after September 1, 1992 [T8 CCR §5189(d)(3)(7)].

The facility has two covered process units (310 SF and the 310 - AFTF) that were built after September 1, 1992. The facility provided the process flow diagrams with the material and energy balances for these units. Per CCHMP review of the documentation, the PFD list the energy balances for each piece of equipment. In addition to the PFD described above, the facility maintains material and energy balances in modeling software that are used by the process engineers. These models are used to simulate various scenarios and evaluate any potential changes to the system.

Y NoneAbr




Does the information pertaining to the equipment in the process include safety systems (e.g., interlocks, detection, or suppression systems)? [T19 CCR §2760.1(d)(1)(H) & Section 450-8.016(a)(1)(A)(iv)]

Per review of the PSI index, DOW maintains process safety systems (including interlocks) in the following documentation: Critical Devices/Safety Instrumented Systems (SIS) device listing, Instruments That Require Testing (ITRT) Lists, and Fire Protection Strategy. CCHMP reviewed the 310 Block Critical Devices and the Chloropyridines ITRT. Both lists included device name, location, position, and system interface (e.g. MOD, BPCS).

The PSI SME provided flow diagrams that were essentially downloads from the MOD Graphics & SIS Loops. The facility maintains an up to date copy of each of the systems. CCHMP reviewed all the MOD diagrams and confirmed the interlocks identified on the list were up to date.

Y NoneAbr


Does the submitted RMP and Safety Plan accurately reflect the existing Process Safety Information Program at the stationary source? [T19 CCR §2745.2(d) & Section 450-8.016]

Section I.D.3. of the RMP, describes in general, the process safety information managed at the facility. AS discussed in question A11-12, inventories listed in Table II-A of the RMP need updating.

R NoneAbr

A11-28 Audit Follow-Up

Have all ensure action items associated with the previous CalARP/ISO audit of the stationary source been addressed within this prevention program questionnaire?

* Complete the status column in the previous CalARP/ISO audit's Summary of Action Item table for this prevention program.* Identify a new action item along with periodic written updates to CCHSHMP (e.g., monthly) to complete outstanding action items or proposed remedies identified that are past due.1. This question is only applicable to stationary sources that have had prior CalARP/ISO audits by CCHSHMP.

There were no ensure action items from the previous 2015 CalARP audit. Therefore this question is not applicable.

N/A NoneAbr


A12 - CalARP Prevention Program: Process Hazard Analysis (Program 3)



Did the stationary source use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed: (a) What-If (b) Checklist (c) What-If/Checklist (d) Hazard and Operability Study (HAZOP) (e) Failure Modes and Effects Analysis (FEMA) (f) Fault Tree Analysis (g) An appropriate equivalent methodology? [T19 CCR §2760.2(b) & Section 450-8.016(d)(1)

The facility uses a checklist review process that is called RCPHA (Reactive Chem PHA). The checklist includes the following topic areas:-A. General Information (25): management system overview including the new leader being familiar with the reactive chemistry of the unit -B. Chemical Exposure Index (CEI)(18)-C. Fire and Explosion Index (F&EI)(6)-D. Higher Risk Reviews (HAZOPS & LOPA) (16): screening for addition analysis such as HAZOP or LOPA-E. Additional Risk Evaluation (7): identification of QRA or other studies if they were performed-F. Reactive Chemicals data (23): questions to assess if appropriate test data have been obtained including changes to chemical concentrations, component, materials of construction, maintenance chemicals (oils, lubricants and solvents), residue shock sensitivity and dust explosion potential.-G. Confirmation of raw materials (7)-H. Materials of construction and maintenance materials (4)-I. Side Reactions and Reactive conditions (9)-J. Catalyst/initiators/mole sieves (9)-K. Monomers and reactive materials (10)-L. Flammable mixtures/dusts/& ignition Sources (15)-M. Control Systems/Computers (20)-N. Environmental Controls and Waste Handling (11)-O. Backflow/Emergency Flow Blocks (7)-P. Chemical Storage and Handling & Utilities (22)-Q. Plant Drainage (10)-R. Distribution Containers/Logistics (6)-S. Compatibility Chart (8)-T. Reactive Chemicals/Process Safety

Y NoneAbr



training and Scenarios (10)-U. Customer information (3)-V. Process Equipment Review: This is broken into equipment, exchangers, agitators, rotating equipment, fired equipment/hot oil systems and flares, distillation, vessels and piping, relief devices and vent systems.-W. Inherently Safe Design (32)-X. Human Design Factors and Personal protection (28) including additional question if there is a need to use the human factors checklist to brainstorm additional topics and if there are procedures that warrant human reliability assessment.-Y. Safe Plant layout and Building Design (20)-Z. Electrical Safe Design and Hazardous area Classification (10)

In addition, there are addition 35 questions that are titled "RCPHA addendum - CA PSM/RMP Compliance that supplements human design factors and personal protection, external events including Security Vulnerability Assessment. Per interview, on the first day of the RCPHA, the PHA team performs a field work of the process for an overview and then is divided into groups to perform a field verification checklist including: verifying PSI availability, drainage and containment, building location and fire risk, electrical, fire protection, fired equipment, emergency block valves, pressure vessels and relief devices, etc.

CCHMP considers this approach to be appropriate for determination of hazards related to the process being analyzed. In addition, the facility has a requirement "a new Plant Manufacturing Leader or Process Owner has to have a RCPHA review within 90 days of assuming the job. The review shall cover the basic understanding of the reactive chemicals/process hazard potential



associated with the operation and theReactive Chemicals committee may askfor a remedial follow up review meeting ifthe new leader does not convince thecommittee that he have sufficient reactivechemicals knowledge."




Do the PHA(s) address the hazards of the process? [T19 CCR §2760.2(c)(1) & Section 450-8.016(d)(1)]

* Review a representative sample of process-related equipment to determine whether hazards have been identified, evaluated, and controlled (i.e., electrical classifications are consistent with flammability hazards, pressure relief valves are properly designed and discharge to a safe area, pipework is protected from impact) [CalOSHA Consultation, Guidelines for Process Safety Management, Part 1, June 1994].1. Examples include: (a) failure of equipment to start, (b) operator stops equipment inadvertently, (c) valve mispositioned inadvertently, (d) possible exothermic reactions, (e) pressure relief, venting, or flare capacity inadequate or disabled, and (f) loss of utilities.2. Hazard analysis "by action items only", where the PHA includes only those hazards for which recommendations are made for safety improvements, and hazard analysis "by exception", where the PHA includes only those hazards for which the team felt there were significant consequences (e.g., explosions, toxic releases) are not acceptable. [OSHA Training Material Reference Manual].3. OSHA has not issued a clarification regarding "PHA by Exception"; however, OSHA Region VI issued a citation to Marathon Oil that used the specific phrase "HAZOP by Exception".4. The following question was answered by OHSA in a Beaumont, Texas meeting: In our PHA program, we concentrate on very serious hazards with potentially catastrophic consequences. Other hazards with less serious, non-catastrophic consequences are not included in the study and recommendations are not made as part of the PHA. We have other safety programs that address these hazards. Is this OK? Answer: The key thing is that only "catastrophic" possibilities are covered. Other possibilities still need to be addressed and documented as to why they are not catastrophic.

Per interview with Process Safety Technical lead, the RCPHA process includes a presentation. CCHMP reviewed the material for the 560 block RCPHA (June 2018) which include plant overview, process overview (chemistry, reactions and block flow diagram), previous RCPHA and risk reviews (various scenario and applicable safeguards), changes since the last RCPHA, major process hazards, previous incidents (incident info and key learnings), toxicity information, key parameters, reactive chem limits and then the questionnaire (checklist). CCHMP also reviewed the RCPHA review Presentation for block 310 (April 2017), this included for each plant, chemistry, side reactions, chemicals, flammables, block flow diagram, WCS, cardinal rules, incident history, potentially significant impact changes, key operating limits, critical device program, recent audit and previous RCPHA action items.

Per CCHMP review and field observation, each block and plant identifies "cardinal rules" these are actions that has serious consequences. For example: "do not use silica based absorbents to clean up spills containing HF>2%" and conditions to avoid to prevent decomposition or runaway reaction.

The checklist question included reactive chemicals and reactive materials assessment, flammable mixtures/dusts/ignition sources questions, backflows, control systems, etc. For example, in materials of construction, block 560 specifically identified that aluminum and titanium are not compatible with several parts of the process. For ignition sources, in the logistics RCPHA, N2 is used to offload all flammables, also tanks and vessels are nitrogen padded. For block 310, it was identified that there is no runaway reaction potential and also

Y NoneAbr



5. Do observations of a representativesample of process-related equipmentindicate that obvious hazards have beenidentified, evaluated, and controlled? (Forexample, hydrocarbon or toxic gas monitorsand alarms are present, pressure reliefvalves are properly designed and dischargeto a safe area) [OSHA Instruction CPL 2-2.45A CH-1 Appendix A].

there is back-flow prevention at thenitrogen inlet to some process vessels.Another example in block 310 discusstemperature when unwanted exothermicreaction occurs and that presence of HCLco-product causes reversal reaction. Italso identified that water, iron, pic acid andits esters are known to acceleratecorrosion in the process.

A12-08 Program3CalARP& ISO

Do the PHA(s) address theidentification of any previousincident which had a likelypotential for catastrophicconsequences? [T19 CCR§2760.2(c)(2) & Section 450-8.016(d)(1)]

1. Catastrophic consequence is defined tobe consistent with “catastrophic release”which means a major uncontrolled emission,fire, or explosion, involving one or moreregulated substances that presents animminent and substantial endangerment topublic health and the environment. [T19CCR §2735.3(m)]2. OSHA believes that it would be extremelyuseful if incident investigation report findingsand recommendations were reviewed in thesubsequent update or revalidation of theprocess hazard analysis (or hazard review)of the process [29 CFR 1910.119 preamble].

CCHMP notes that in sec. A, GeneralQuestions, there are a couple of questionsthat discuss process safety incidents:-5a Have Process Safety /ReactiveChemicals accidents or High potential"near miss" incidents occurred in the unitsince the last review?-5b Have any of these process safetyincidents had the potential to affect thepublic.6. Have Process Safety/ReactiveChemicals accidents/incidents occurred inthe technology in the last 3 years?7. Has your plant/technology had repeatprocess safety accidents?8. Has the "corporate memory" (memory oflearning from previous incidents) andoperating discipline been established toprevent recurrence.

Additionally, per interview, during theRCPHA review using a power pointpresentation material, the team discussedobservations and brain stormed on itemsof interest. Per CCHMP review of thepower point material, incident and keylearnings are reviewed including preventivemeasures that were implemented toprevent recurrence. See additionaldiscussion and examples in A12-07.

Y NoneAbr




Do the PHA(s) address theconsequences of failure ofengineering and administrativecontrols? [T19 CCR§2760.2(c)(4) & Section 450-8.016(d)(1)]

Per CCHMP review of the questionnaire, inthe process equipment review with specificequipment, there are questions regardingengineering and administrative controlssuch as:-does the failure of any heat transfersystem result in an uncontrollablecondition?-is monitoring provided to detect a leak?-have the fired units had a burnermanagement review within the past 7years? When? What is resolution of anyactions?-Does the facility utilize any High IntegrityProtections Systems (HIPS) to protectagainst over-pressure?-Does the facility use an area monitoringsystem for the chemicals of CEI concern?(the answer may include acid gasdetectors and results of the detectionlevels)-Is there periodic inspection, maintenance,and testing of equipment used to mitigatespills or releases?

Y NoneAbr




Do the PHA(s) address covered process and stationary source siting? [T19 CCR §2760.2(c)(5) & Section 450-8.016(d)(1)]

1. The CalARP program regulations only require that stationary source siting be reviewed. CCHMP has expanded this requirement to include a siting evaluation for the covered processes. [CCHMP Interpretation]

The checklist include calculation of the chemical exposure index (sec. B) and the Fire and Explosion index (C). These are calculations that review the chemical of concern and potential scenario for accidental releases.

Section Y is the Safe Plant layout and building design, and includes:-appropriate separation of process units per hazard evaluation to minimize property damage?-access for fire fighting and emergency response-drainage and impounding areas for flammable, toxic, reactive spills-location of ignition sources in relationship to potential flammable releases-control room, and other occupied building location (answer: no occupied buildings within F&EI radii).-is there adequate water supply to meet the worst case fire scenario?

Per interview with Process Safety Tech Lead, the facility used a third party (Baker Risk) to perform a site wide risk evaluation including overpressure, fire, toxic release and flammable scenarios in 2009. The study result did not identify any new concerns that was not already identified by Dow and being addressed.

Y NoneAbr




Do the PHA(s) address humanfactors? [T19 CCR§2760.2(c)(6) & Section 450-8.016(d)(1)]

1. Such factors may include a review ofoperator/process, operator/operator andoperator/equipment interface, the number oftasks operators must perform and thefrequency, the evaluation of extended orunusual work schedules, the clarity andsimplicity of control displays, automaticinstrumentation versus manual procedures,operator feedback, clarity of signs and codes(etc.) [OSHA Instruction CPL 2-2.45A CH-1:Appendix A PSM Audit Guidelines].

Per CCHMP review, the checklist includesection X "Human Design Factors andPersonal Protection) which have questionsregarding human machine interfacephysical environment, color coding,numbering and naming conventions,signage, operating procedures writtenclearly, utility hook-up, location of safetyequipment, etc.

CCHMP notes that the Block 310questionnaire states "310 control room hasbeen modified for improved Control Roomlayout and ergonomics".

In addition, the plants uses a HumanDesign Factors and Personal Protection(supplement) questions as additionalbrainstorming tools. This worksheet istitled 'RCPHA Addendum - CaliforniaPSM/RMP Compliance'.

Per review of the questionnaire andinterview, there is a site project to evaluateand upgrade all lighting to LED.

Y NoneAbr




Do the PHA(s) includeconsideration of externalevents, including seismicevents, as applicable? [T19CCR §2760.2(c)(8) & Section450-8.016(d)(2)]

* Review written documentation of seismicreview and compare against seismicguidelines.* Review external event considered (use of achecklist is acceptable). Documentation byexception is not sufficient.1. PHAs completed for other programs (e.g.,PSM) where external events were notconsidered shall be updated to includeexternal events [T19 CCR §2760.2(c)(8)].2. External events include nearby pipelineaccidents, releases of chemicals, sabotage,seismic activity, transportation accidents,maintenance activities, externalflooding/landslides, extreme winds, fire, fog,high/low temperatures, internal flooding.[Section 7.3.4 of CCHMP’s CalARPGuidance Document]3. For ISO regulated facilities, externalevents, including seismic, shall beconsidered for all covered processescontaining a regulated substance, if a publicreceptor is within the distance to a WCStoxic or flammable endpoint. [Section 450-8.016(d)(2) as amended under Co. Ord.2000-20]4. Did the PHA team reviewed afacility/equipment check for after a seismicevent to confirm that no damage wassustained as a result of the earthquake?

Per interview with SME, Dow uses anoutside engineering firm to perform the 5year seismic assessment. CCHMPreviewed a table titled "Revised 5 yearSeismic Assessment Schedule" as:1) 310 - last performed Dec. 2014 (dueDec 2019)2) 520 - last performed Dec. 2014 (dueDec 2019)3) 560 - last performed Dec 11-14, 20174) 660 - last performed Dec. 2013 (dueDec 2018)5) 720 - last performed Dec. 2017 (dueDec 2022)

CCHMP reviewed a 560 block Seismicassessment report that was dated June25, 2018 which states the walkdown of theunit was performed Dec. 11 - Dec. 14,2017. The report was stamped by a CAregistered professional civil engineer, andin section 2.0 methodology, it states thereview was conducted in accordance withthe guidance document for CalARPseismic assessments (Dec 2013)approved by the Region I Local EmergencyCommittee (LEPC). The assessment alsoincluded a review of the 2012 seismicassessment recommendations. CCHMPwas provided a copy of corrective andpreventive action tracking tool 468670which documented the action items fromthe 2017 seismic assessment. CCHMPwas told that the 2012 seismic action itemswere first risk ranked and any project riskscores below 100 (145 max) areconsidered to be discretionary andremaining action was not tracked in thecorrective and preventive action trackingtool system but rather in a spreadsheetformat. CCHMP reviewed this risk rankingthat includes loss potential, environmentalconsideration (regulated materials), Safety(structural engineer safety override andincident potential. Per SME interview, thecurrent approach is not to risk rank theactions but track in corrective and

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preventive action tracking tool and discuss the ultimate disposition (including evaluating of the support structure, etc.)

Per CCHMP review of the questionnaire, the RCPHA addendum includes: has a seismic assessment of the facility been completed within the last 5 years.

CCHMP also reviewed a seismic report that was titled "CalARP Seismic Assessment Block 640, Jan 2014." The seismic worksheet for this report was performed by two PEs.


Did at least one employee on the PHA team have experience and knowledge specific to the process being evaluated? [T19 CCR §2760.2(d) & Section 450-8.016(d)(1)]

CCHMP reviewed the following RCPHA reports and report listed participation from these individuals in attendance:-Block 560 (June 14, 2018) Technical Advisor, engineer, operations leader -Block 310 (April 25, 2017) Technical Advisor, Engineers, operations leader and representatives of the RC committee, multi-purpose operator-Site Logistics (March 15, 2016) Technical Advisor, project specialist, engineer, operational leader

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Was the PHA performed by a team with expertise in engineering and process operations? [T19 CCR §2760.2(d) & Section 450-8.016(d)(1)]

See listing of individuals that participated in the RCPHA.

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Did at least one member of the PHA team have knowledge in the specific PHA methodology used? [T19 CCR §2760.2(d) & Section 450-8.016(d)(1)]

1. For PHA team leaders, OSHA will look for documentation of formal training - course certificates are acceptable [OSHA co-sponsored PSM workshops in Spring, 1993].2. Non-team leader previous participation in a PHA would not qualify a team leader to lead an initial or update PHA [OSHA co-sponsored PSM workshops in Spring, 1993].3. For PHA team leaders, qualification gained through experience as a team leader is acceptable - OSHA might want to see examples of PHA reports led by a team leader qualified in this manner [OSHA co-sponsored PSM workshops in Spring, 1993].

Per discussion and review of the RCPHA reports, one of the team member in each of the RCPHA has a Process Safety Technical Leader who is very experienced in the PHA methodology.

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Has the stationary sourceestablished a system todocument what actions are tobe taken; develop a writtenschedule to complete theseactions within two and one-half(2.5) years of performing thePHA, or the next plannedturnaround (for those itemsrequiring a turnaround);document the final resolutiontaken to address eachrecommendation and the actualcompletion date? [T19 CCR§2760.2(e)]

* Request all stationary sources to considerusing a single system to track and documentthe resolutions of all recommendationsresulting from PHAs, incident investigations,compliance audits, etc.1. This question is for tracking actionstaken. [CCHMP Interpretation]2. The timeline applies to PHAs completedafter January 1, 2015.3. Stationary sources subject to ISO or RISOrequirements must complete PHA actionswithin one year as specified in A12-23.4. Turnaround means a planned processshutdown for the purpose of repair,maintenance, process modification,equipment upgrade, or other significantprocess activity. [T19 CCR §2735(aaa)].

CCHMP reviewed the Pittsburg siteProcess Hazard Analysis Policy (rev.1/24/2017) (p. 3) states "to ensure thataction items are promptly addressed andtracked, and that the review is properlydocumented, the Site Process SafetyFocal Point is responsible to originate thecorrective and preventive action trackingtool event so that he/she can monitorcompletion of action items." Correctiveand preventive action tracking tool is anelectronic database: Event and Action Toolthe facility uses. It also states thatcompletion of action items in a timelyfashion and in compliance with S-303-Corrective and Preventative Actions(CAPA) Safety Standard. Per CCHMPreview of S-303 (ODMS 05.04.02, rev.5/1/2017) sec. 02.02 corrective andpreventative action (CAPA) p. 8 PHAitems must be completed within 2.5 yearsof performing the PHA or the nextturnaround if a turnaround is required. Ora timetable approved by the CCHMP.

CCHMP also noted that the corrective andpreventive action tracking tool for the Block560 Dec 11-14, 2017 seismic assessmententries were included with the latest actionlisted as May 14, 2020 and a final actiondated Jun 14, 2020 to ensure thecorrective and preventive action trackingtool is validated. Therefore this is withinthe 2.5 years for the timing to addressaction items.

Section 3.0 states PHA event recordsshould be kept for life of facility.

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A12-21 Program3 CalARP

Has the stationary sourceestablished a system tocomplete actions on a timetableagreed upon with CCHMP if notwithin the timeline in questionA12-20? [T19 CCR §2760.2(e)]

1. The stationary source must document theagreed upon timetable with CCHMP andhow they are addressing the actions takenfrom the PHA recommendations. [CCHMPInterpretation]

CCHMP reviewed S-303 'corrective andpreventative Actions (CAPA) safetystandard' (ODMS 05.04.02, rev. 5/1/2017)on p.8 includes a statement to work withCCHMP for an agreed upon timetable if theaction item cannot be completed within the2.5 years or the next turnaround.

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Has the stationary sourceestablished a system tocommunicate the actions tooperating, maintenance, andother employees whose workassignments are in the processand who may be affected by therecommendations or actions?[T19 CCR §2760.2(e) & Section450-8.016(d)(4)]

* Enquire during employee interviews thelocation of PHA binders/results.1. PHA availability: Merely placing a copy ofthe PHA results in a common location is notenough - must provide "substantialcommunication" [OSHA Region VIpresentations on PSM in January, 1994].

Per record review, CCHMP was providedemail communication regarding theprocess hazard analysis and the actionitems for Site logistics, Block 310 andBlock 560.

CCHMP also reviewed the Pittsburg siteProcess Hazard Analysis Policy (rev.1/24/2017) (p. 3) that provides a templatefor communication of results to affectedemployees. The affected employeesshould include operations, maintenanceengineering and/or contract personnel,etc. It also states that a copy of thiscommunication must be retained with thePHA review documentations.

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A12-25 Program 3 CalARP

Did the stationary source consider the use of Inherently Safer Systems in the review of: new processes and facilities, existing processes, or in developing recommendations and mitigations for PHA’s? [Section D.1 of the CCC Safety Program Guidance Document]

* Request all CalARP facilities to consider use of inherently safer systems. Inherently Safer Systems are optional for CalARP Program only stationary sources.1. This question is not applicable to facilities subject to CCC Industrial Safety Ordinance (ISO) since more detailed Inherently Safer System questions must be answered in ISO questionnaire A34.2. Inherently Safer Systems include four levels of risk reduction in order of decreasing reliability (the first is the most reliable) as follows:a) Inherent - Eliminating the hazard by using materials and process conditions which are non-hazardous; e.g., substituting water for a flammable solvent.b) Passive - Minimizing the hazard by process and equipment design features that reduce either the frequency or consequence of the hazard without the active functioning of any device; e.g., the use of equipment rated for higher pressure.c) Active – Using controls, safety interlocks, and emergency shutdown systems to detect and correct process deviations; e.g., a pump that is shut off by a high level switch in the downstream tank when the tank is 90% full. These systems are commonly referred to as engineering controls.d) Procedural – Using operating procedures, administrative checks, emergency response, and other management approaches to prevent incidents, or to minimize the effects of an incident; e.g., hot-work procedures and permits. These approaches are commonly referred to as administrative controls.

Dow is not required to consider the use of inherently safer systems approaches in the review of new or existing processes. However, per CCHMP review of the RCPHA questionnaire, sec. w of the questionnaire are consideration for Inherently Safe Design including:-Intensification/minimization (8): e.g. has the location of the process equipment been designed to minimize the length of hazardous materials piping?-Substitution (4): e.g. has a less hazardous heat transfer media been considered?-Moderation or Attenuation (5): e.g. have you considered limiting the supply pressure of raw materials to less than the working pressure of the vessels to which they are delivered?-Simplification (10) e.g. for facilities with possible vapor cloud explosion, has layout considered separated process areas which handle significant quantities of high reactivity fuels from other areas?

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Has the PHA been updated andrevalidated by a team meetingthe requirements of §2760.2(d)at least every five years afterthe completion of the initial PHAto assure that the PHA isconsistent with the currentprocess? [T19 CCR §2760.2(f)& Section 450-8.016(d)(2)]

1. Updated and revalidated PHA'scompleted to comply with PSM areacceptable to meet the requirements of theparagraph, notwithstanding the requirementsof §2760.2(c). (Any updates or revalidationswhich occurred following August 1996 mustinclude the requirements of §2760.2(c)) [T19CCR §2760.2(a)].2. PHA revalidations should address thefollowing questions: (a) Does the currentPHA reflect all of the changes made sincethe last PHA? (b) Have any newrequirements, either voluntary or non-voluntary, emerged since the last PHA? (c)Did the last PHA contain any omissions? (d)Have there been any incidents since the lastPHA in the process unit to be revalidated, orin other process units/areas that affected theprocess unit to be studied?

CCHMP reviewed the 'RC/PHA reviewfrequency guidelines', rev. 2/22/2016 itstates 'the standard reactivechemicals/Process Hazard Assessment(RC/PHA) review frequency is every 3years for Dow facilities.'

CCHMP reviewed the following RCPHAs:-Block 560 (June 14, 2018) previous report(6/2/2015)-Block 310 AFTF(April 25, 2017) previousreport (April 25-27, 2014), SF (4/27/2017)-Site Logistics (March 15, 2016) previousreport (4/10/2013)

The guidelines also states that the RCPHAfrequency can be extended to five years ifthe facility is not OSHA PSM or EPA RMPand additional listed criteria are metincluding the facility have not had a majorProcess Safety incident within the past 3years.

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Has the stationary sourceretained copies of the PHA'sand updates or revalidations foreach covered process for thelife of the process? [T19 CCR§2760.2(g)]

Per interview and demonstration, RCPHAand previous HAZOP on the coveredprocess are kept on the intranet. CCHMPwas shown electronic locations of all thePHAs that was kept for Block 660. Similarfile structure exists for all blocks. CCHMPwas shown how to access the RCPHA bythe operator at Block 310.

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Has the stationary source retained copies of the documented resolution of the recommendations described in §2760.2(e) for the life of the process? [T19 CCR §2760.2(g) & Section 450-8.016(d)(4)]

1. At a minimum the documentation is to include the final resolution taken to address the recommendation and the actual completion date. [T19 CCR §2760.2(e)]

Per interview with Process Safety Technology Leader, the PHA team reviews findings with the Production Leader before the report is finalized and is an opportunity to provide input to the team regarding the recommendations. Per CCHMP review of the RCPHA reports and comparison to corrective and preventive action tracking tool database, CCHMP noted that not all PHA team recommendations are addressed and documented to be resolved.

In AFTF and Trifluoro Plant facility review (4/25/2017) action item #21 and #24 were not addressed or documented in the corrective and preventive action tracking tool. Item #11 the action is to evaluate only.

In the SF and SF warehouse (4/27/2017), action item #10, action item #16 and action item #18 were not documented in the corrective and preventive action tracking tool so no document of resolution. CCHMP further noted that action Item 5 was closed with "it will be implemented by LOPA Capital". Per discussion, the action is to "review the need to add an EBV on the vent flow between T-1W and the SF warehouse." CCHMP contends that this is a poorly worded recommendation and that the recommendation should include actually completing the task of installation of the EBV once it is determined to be necessary. Also, item #12 was closed with "these scenarios will be evaluated in the 2018 SF LOPA revalidation." Action items should only be closed after the task has actually been performed.

In site logistics (3/15/2016), item #2 indicated a completion date of Jun 20, 2016 and the action taken indicated with meeting set for Wed., June 22. Item #8 and #20 was closed with action taken "waiting on final MOC approval to publish to updates to WebEDMS". Item #5 was

P Ensure that all PHA findings and the corresponding recommendations are documented and maintained including the resolution. This is to be retained for the life of the process.

This is a modified repeat from the 2015 A12-24.

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closed out with "the project has beenadded to the plant PSTP….."

Per interview, currently the Process SafetyTechnology Leader is inputting the actionitems into corrective and preventive actiontracking tool rather than the facility. Anyalternate actions or comment should bedocumented if the decision is reached tonot complete the recommendation. See inA12-24 for justification and documentationto be retained for decision made toimplement or not implement all PHArecommended action items.

During the audit, CCHMP was providedmodified corrective and preventive actiontracking tool for the following:-corrective and preventive action trackingtool 447458 for Block 310, AFTF: Item 11,added "if there are not, update plant andsite documentation that T-XXX is CalARPcovered."-corrective and preventive action trackingtool 447460 for Block 310, SF: Item #5was edited to indicate incomplete andaction taken was deleted. Item #12 wasedited to be "not completed" and the actiontaken was deleted.-corrective and preventive action trackingtool 426888 for Site Logistics: Item #2 wasedited to say "met with…." CCHMP also noted that item #6 was clarified to includethe date the LOPA revalidation was held.Item #8 and #20 was edited to include theMOC number and the location of theCompatibility grid. Item #5 was edited toinclude "a separate action item has beengenerated…"

Per CCHMP's review and observation theaction taken have been address, theremaining action is to create the entry inthe corrective and preventive actiontracking tool for recommendations that wasmissing from the current corrective andpreventive action tracking tool anddocument if the action was addressed as



part of another system, was rejected andthe justification for rejection or if alternaterecommendations was generated.


Does the submitted RMPaccurately reflect the existingProcess Hazard AnalysisProgram at the stationarysource? [T19 CCR §2745.2(d)& Section 450-8.016]

CCHMP reviewed the RMP (7/14/2014),section I.D.3 PHA, p. 13 that discuss theevaluation of hazards associated with theoperation and it included discussions ofsecurity vulnerability assessments andseismic assessments. There is also adescription of a Dow Site Seismic Teamthat meets periodically to assess thewalkthrough information and status ofseismic upgrade projects. CCHMPconfirmed that the DSST is active.

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A12-30 AuditFollow-Up

Have all ensure action itemsassociated with the previousCalARP/ISO audit of thestationary source beenaddressed within thisprevention programquestionnaire?

* Complete the status column in the previousCalARP/ISO audit's Summary of Action Itemtable for this prevention program.* Identify a new action item along withperiodic written updates to CCHMP (e.g.,monthly) to complete outstanding actionitems or proposed remedies identified thatare past due.1. This question is only applicable tostationary sources that have had priorCalARP/ISO audits by CCHMP.

Per CCHMP review, one of the 2 2015CalARP action items has been addressed.A12-24 is being repeated in A12-28.

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A13 - CalARP Prevention Program: Operating Procedures (Program 3)



Did the stationary source prepare written operating procedures that provide clear instructions for safely conducting activities associated with each covered process? [T19 CCR §2760.3(a) & Section 450-8.016(a)(2)(A)]

1. If a new employee could be trained from the procedure without the presence of the previously trained and qualified employee, or if an employee returning from a leave of absence could operate the unit with the procedure, then the procedure probably has enough detail [OSHA co-sponsored PSM Workshops in Spring 93].2. The DCS output (screen) cannot itself be considered as an operating procedure, even if supplemented with written simplified loop diagrams and narrative description of the controls. Written operating procedures for the system, including the distributed controls must be written and can include the loop diagrams and narratives. [OSHA Instruction CPL 2-2.45A CH-1 Appendix B - Clarifications and Interpretations of the PSM Standard].3. CCHMP provided guidance on the types of operating procedures covered under the CalARP Program under “Requirements for Operating Procedures for Program 2,3 Stationary Sources Covered by CalARP Program”, correspondence, June 28, 2001. [CCHMP Interpretation]4. For stationary sources subject to the County’s Industrial Safety Ordinance (ISO), the level of detail and format for each procedure should be commensurate with the lowest level of experience for personnel responsible for conducting the task.

Per review, ODMS 05.03.04 L1 Procedure Policy & Requirements ( revised 1/2018) is the corporate policy for developing operating procedures for the sites. It states: "All applicable phases (except tasks defined as minimum risk), of operating field, laboratory, maintenance, and process equipment, including:-Startup-Normal operations-Emergency response-Maintenance-Turnarounds and cleanouts-Temporary activities not covered by Safe Work Permit (such as operations performed outside of normal operating limits or outside of normal operating practice, and intrusive troubleshooting)

Per review, DOW's Pittsburg Site Procedure Use Policy (PUP), revised 11/12/17, address the blocks which are being considered for the audit: 310, 560, 660, MEI (methyl ester intermediate), and Manufacturing Services. CCHMP reviewed 27 operating procedures across the different units that covered:-Emergency which cover emergency response. Time permitting, a copy of the emergency procedure shall be obtained and followed.-Routine which cover routine tasks (at least once per month. Also tasks with low risk). If person has not performed tasks within 14 days, person must obtain and review procedure but is not required to carry.-Non-Routine which cover procedures that are not covered by routine or emergency, or critical. This would

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include isolation procedures. Mustreview and understand procedure beforeperforming tasks and carry procedure orchecklist as each step is performed.-Critical (High Risk) which cover high risksteps or section; tasks with significantpotential for exposure to hazardouschemicals or physical agents; tasks toshut down, operator, or start-upequipment where there is a potential toresult in explosion, runaway reaction,catastrophic or LIFE event; tasks(procedures) credited as an independentlayer of protection by PHA (i.e., LOPA).Must review and understand procedurebefore performing tasks and carryprocedure or checklist as each step isperformed.

Per review, on page 7, the policyprovides information on requirements forLife Critical Standard.

In the Procedure Review Frequencysection, the last paragraph states:"Additionally, the procedure reviews willbe conducted per the review frequencieslisted in the table below."

Review policy on page 9:Emergency - annualRoutine - every 5 yearsNon-routine - every 4 yearsCritical - every 3 years

CCHMP reviewed the following:-AHM A0-227L Pressure Check CriticalProcedure Checklist, revised 3/27/17.

CCHMP reviewed the followingprocedures:-R-1100 Sampling LEO Procedure,revised 5/09/18-AHM-Chlorine Process Nitrogen Purgeand Isolation LEO, revised 04/26/17



-AHM-P-73A/B Pump Isolation LEO,revised 10/25/17-AHM-Railcar Bulged Relief Valve,revised 11/19/17-T-1301 NH3 Drum Loading Critical LEO,revised 02/15/17-AHM B-105 to T-161 Chlorine Line LeakMitigation Emergency, revised 09/27/18-Alpha Chlorine Evaporator ShutdownProcedure Checklist, revised 06/1/17-R-210 Response to High Pressure in HFLine Reactors, revised 12/25/15-310 Block-HF Header Line ClearingIsolation, revised 05/3/16-High Pressure Chlorine Line EmergencyShutdown, revised 06/22/18

-Pittsburg Chlorine Railcar OffloadingPolicy (revised 1/3/17)

This procedure covers the chlorine by K2Pure. Chlorine railcars are stored onsiteas safety stock.

Limits due to contract with K2 pure: 4railcars per month & 10 railcars perquarter

Section 1.1 Chlorine Institute Pamphlet66, edition 5, June 2015:

"6.4 STORAGE OF LOADED CHLORINETANK CARSFully loaded chlorine tank cars, properlyprepared for shipment, prior to shipmentof following shipment, may be safelyused for storage for any period of timenot exceeding the next scheduled valveservice. See CI Pamphlet 5 for moredetails."

Section 1.2 Service equipment intervalfor chlorine is 5 years

Block: 660, site logistics,




Are the written operating procedures consistent with the process safety information for the process? [T19 CCR §2760.3(a) & Section 450-8.016(a)(2)(A)]

* Compare operating procedures to P&IDs, equipment data sheets, consequence of deviation, operating limits, etc.

CCHMP reviewed the following procedures and found that they were consistent with the P&IDs for the process:

-R-210 Response to High Pressure in HF line to Reactors, drawing B303A-420 (revised 11/20/17). CCHMP was able to locate the valves DO(440) and DO(431), autovalve AO(408).

-AHM AO-227L Pressure Check Critical Procedure Checklist referenced procedure B1-19A-45 which did not have AO-227L. The SME provided drawing B1-20-45 (revised 2/22/18) which did have AO-227L.

CCHMP did a procedure walk of the operating procedures below in order to evaluate the accuracy of the procedures and the ability of the operators to perform tasks based on the procedures.

-310 Block HF Header Line Clearing Isolation Procedure (revised 5/3/16)-P-1301 A&B Isolation LEO Procedure (revised 5/21/17)-AHM-E-234 A or B Vaporization Startup Procedure Checklist (revised 9/30/15)

CCHMP determined that the procedure accuracy for all three procedures combined was 98%. However, CCHMP does not typically walk down an entire procedure and did not do a full procedure walkdown of any of these procedures.

CCHMP observed the following during the walkdowns:-The operating limits were not specified in one procedure.-Two procedures had steps that required a person to look at the MOD in the control room which was not specified in the procedure.-There were steps in the procedures that did not start with action verbs.

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CCHMP believes that human factorsconsiderations can be major contributorsto incidents and incidents with adverseoutcomes.

A13-03 Program 3CalARP &ISO

Do the procedures address initialstartup or startup following aturnaround? [T19 CCR§2760.3(a)(1)(A), §2760.3(a)(1)(G) &Section 450-8.016(a)(2)(A)]

1. Examples include: (a) preparation ofutilities, process lines, and instruments(b) equipment preparation and testing (c)inerting/purging of equipment [OSHATraining Material Reference Manual].

Per review, DOW's Pittsburg SiteProcedure Use Policy (PUP) addresses(page 2), among other things, tasks foroperating equipment (e.g. initial startup,normal operations, startup, shutdown,emergency, temporary), high risk(critical) tasks, potentially hazardoustasks, handling of chemicals, taskswhere a Safe Work Permit is not utilized(process, operating, field, andmaintenance)

CCHMP reviewed the followingprocedures that address startup fordifferent processes:-AHM-E_234 A or B Vaporization StartupProcedure Checklist (revised 9/30/15).--AHM-Alpha Chlorine Evaporator StartupCritical Procedure (revised 3/27/17)-AHM C-5/C-6 A & B Startup CriticalProcedure Checklist (revised 5/4/17)-AHM P-173A or B Startup Critical

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Do the procedures address temporaryoperations? [T19 CCR§2760.3(a)(1)(C) & Section 450-8.016(a)(2)(A)]

1. Examples may include specialconditions where safeguards may bebypassed, loading/unloading of catalystinto/out of a reactor, sampling, andequipment bypassing [OSHA TrainingMaterial Reference Manual].

Per review of the PUP, Dow classifiescertain procedures for tasks that areperformed infrequently as non-routine.This is a broad category that includesprocedures for tasks like reactorsampling or line isolation. Per SME,DOW does not use temporary operatingprocedures, instead choosing to put inplace permanent procedures for eventhose tasks that are infrequently used. Insome cases, Dow would archive aprocedure that is only used every fewyears. An archived procedure would bereviewed and activated as needed.

Unit MEI-R-1100 Sampling LEO (performed everyfew years)-T-1301 NH3 Drum Loading CriticalProcedure, revised 2/15/17 (performedmaybe once per year)

Unit 310-HF Header Line Clearing Isolation-AHM-Railcar Bulged Relief Valve-R-210 Response to High Pressure in HFline to Reactors Procedure

Unit 660-AHM-E-234 A or B Vaporization StartupProcedure Checklist

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Do the procedures address emergency shutdown, including conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner? [T19 CCR §2760.3(a)(1)(D) & Section 450-8.016(a)(2)(A)]

1. Examples may include conditions requiring emergency shutdown, and operating procedures or steps to take to control or mitigate an emergency condition [OSHA Training Material Reference Manual].

Per the PUP, Dow develops emergency shutdown procedures for different processes as needed. The emergency shutdown procedures include assigning responsibilities to people working within the unit. CCHMP reviewed the following emergency shutdown procedures:

-High Pressure Chlorine Line Emergency Shutdown (revised 6/22/18)

-Alpha Chlorine Evaporator Shutdown Procedure Checklist, revised 6/1/17.

-AHM B-105 to T-161 Chlorine Line Leak Mitigation Emergency (which includes shutdown), revised 9/27/18)

-SF Plant HF Railcar Critical Offloading Checklist (revised 2/28/17)

This procedure is marked in the Attributes and Categories: Critical, AOP (authorized operating procedure), Non-routine.

The Railcar loading process would be automatically shut down in the event that there was an issue with the offloading process by the EBVs (emergency block valve).

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Do the procedures addressemergency operations? [T19 CCR§2760.3(a)(1)(E) & Section 450-8.016(a)(2)(A)]

* Verify procedures exist to addresscomplete and partial loss of power to thesite/unit.1. Examples include procedures for lossof a utility such as process air,instrument air, cooling water, steam,nitrogen, power, etc.

CCHMP reviewed the procedures belowwhich were for loss of utilities for plantsMEI and unit 310:

-MEI Plant Loss of Steam (revised7/28/18)

The procedure describes the steps thatwould need to be taken in the event ofloss of steam. Then, for units R-101, R-201, T-203, R-301, F-300A/BR-280, T-3700, hot water system, R-1100, R-1200,R-1250, R-1400, R-1600, R-1700, R-1800, F-1803A/B, and B-500, the effectthat the loss of steam would have on theindividual units and how to address eachof them.

-Loss of Electricity Emergency Procedure(MEI)

The procedure above providesinformation about what to do in the eventof a loss of power in the followingscenarios: Loss of Electricity, Loss ofOne Transformer, or Loss of Dow Power(loss of power inside of the plant).

For the next two procedures, Dowdeveloped instructions on how to handleeach in the event of a loss of power tothe individual units or to the entire plant.The procedures detail the steps thatwould need to be taken in order to bringthe units back online once the power hasbeen restored.

-SF Plant Loss of MRU-150 CO2Response Procedure (revised 7/28/18)

-2,3 Penta Loss of Electricity EmergencyProcedure (revised 6/7/18)

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Do the procedures address startup after an emergency shutdown or partial shutdown? [T19 CCR §2760.3(a)(1)(G) & Section 450-8.016(a)(2)(A)]

1. Examples may include identifying the allowable process conditions for which emergency startup is permissible [OSHA Training Material Reference Manual].

Per interview with SME, the equipment procedure start ups for the different plants do not specify whether the procedures are to be used after a loss of power incident or reduced power or following routine maintenance. The startups would all be the same.

See A13-03 for details on some startup procedures that would be used following an emergency shutdown or partial shutdown.

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Do the procedures address consequences of deviations and steps required to correct or avoid deviating set operating limits? [T19 CCR §2760.3(a)(2) and §2760.1(c)(1)(E) & Section 450-8.016(a)(2)(A) and 450-8.016(a)(1)(A)(iii)]

1. The consequences of deviating beyond the parameter ranges should be consistent with the results of the process hazard analysis [OSHA Training Material Reference Manual].

Per review, the following procedures addressed consequences of deviations in the Consequences of Deviation section of the procedure:-AHM-Chlorine Process Nitrogen Purge and Isolation LEO Procedure-AHM AO-227L Pressure Check Critical Procedure Checklist-AHM-E-234 A or B Vaporization Startup Procedure Checklist-AHM C-5/C-6 A&B Shutdown Critical Procedure Checklist-R-1100 Sampling LEO Procedure-SF Plant HF Railcar Critical Offloading Checklist

Almost all operating procedures reviewed had a Consequence of Deviation section in which specific details for a deviation and the steps to correct the deviation were included. For example, in the SF Plant HF Railcar Critical Offloading Checklist, the Consequences of Deviation section has a table with two entries, one for Step H which was for the railcar being returned above 25 psig or plugs and caps not wrench tight which has a Consequence and How to Avoid columns each of which has something written underneath. For Step J, the dome not being securely opened and is not tied securely in the open position, the Consequence is potential injury and the How to Avoid is to use tie down straps.

Per review, some of the procedures related to loss of utilities have a different Consequence of Deviation listed. For the procedures below, the Consequence of Deviation for each: "If this procedure is not followed, significant safety and/or environmental incident could occur."

-MEI Plant Loss of Steam (revised 7/28/18) has a statement in the Consequences of Deviation section: "If this procedure is not followed, significant

Y NoneAbr



safety and/or environmental incident could occur." Both of these procedures address loss of electricity to either a unit or the entire plant. The How to Avoid section would not apply to these since they could be beyond the control of the facility.

-Loss of Electricity Emergency Procedures (revised 7/28/18)

-2,3 Penta Loss of Electricity Emergency Procedure (revised 6/7/18)




Do the operating procedures include safety and health consideration such as precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment? [T19 CCR §2760.3(a)(3)(B) & Section 450-8.016(a)(2)(B)]

* Review training records to ensure that employees have been trained in proper use of PPE. 1. MSDS may be referred to or attached to satisfy the personal protective equipment portion of this requirement. If MSDS are referenced in the operating procedures, the document containing the MSDS will be required to be annually certified to be current and accurate per §2760.3(b). [CCHMP Interpretation]

Per review, each procedure has a section, Hazards and Precautions, that covers the PPE, and, as appropriate, administrative and engineering controls.

-AHM-Railcar Bulged Relief Valve Procedure (revised 11/19/17) has in the Hazards and Precaution section a table listing Step, Hazard, and Precaution. In the Step column, the procedure has All; Hazard column, Chlorine Inhalation; Precaution column, Refer to Chloropyridines PPE grid for working with Chlorinated Pyridines. Underneath the table is a statement in bold type: "Refer to the MSDS for additional hazard information."

-AHM-P_73A/B Pump Isolation LEO Procedure (revised 10/25/17), in the Step column it has 4-9; Hazard column, Chlorine; and Precaution Column, Refer to Chloropyridines PPE grid for line openings.

Per live navigation with SME, Dow intranet has SDS's online in the eMSDS database. This database is available to anyone on site with computer access. An operator would be able to access SDS information by department or chemical name. The SME entered a department name, AFTF, and all of the chemicals for that department came up. When clicked, the hotlink brought up the corresponding SDS. CCHMP reviewed the SDS's for both Chlorine and HF, each having multiple SDS's due to the fact that Dow has elected to use multiple suppliers in the past for each. In the case of chlorine, Dow uses a local supplier and another Dow site as a backup. Per SME, the SDS's are kept current and once a year the SDS's are reviewed in order to identify those that are more than 5 years old. These are put into an archive folder on the network.

Y NoneAbr




Do the operating procedures include safety systems and their functions? [T19 CCR §2760.3(a)(4) & Section 450-8.016(a)(2)(C)]

Per review of the PUP, the policy specifies the procedure content (page 6) which includes a table with a heading of Content in the first column which has "Any applicable methods to mitigate hazards and risk. This information may be included or referenced." The second column is titled Additional Details and has in the cell:

Hazards and Precautions section with reference to the affected steps.Safe Operating Limits section.Consequences of Deviation section.Safety Systems section.

CCHMP reviewed the following procedures which included safety systems:

Unit 600 -AHM-R-3C, Chlorine Line Isolation LEO Procedure, revised 1/9/18. (Vents)

Unit 310-R-210 Response to High Pressure in HF line to Reactors Procedure, revised 12/25/15 (PSV)

-AHM C-5/C-6 A&B Shutdown Critical Procedure Checklist (revised 3/9/17) used by Alpha Reactor Tech to shut down C-5 and C-6 A&B. If system overpressures, the PSV will lift.

-AHM P-173A or B Startup Critical Procedure Checklist (revised 3/29/17) If system overpressures, the PSV will lift.

-Alpha Chlorine Evaporator Shutdown Procedure Checklist (revised 6/1/17) uses a vent system with vent valve AO(206) that will release pressure back to the chlorine system

Y NoneAbr




Did/does the stationary source annually certify that the operating procedures are current and accurate? [T19 CCR §2760.3(c) & Section 450-8.016(a)(2)(E)]

1. Sources are also to ensure that procedures are reviewed as often as necessary to assure that they reflect current operating practice (including changes that result in changes in process chemicals, technology, and equipment. [T19 CCR §2760.3(c) & Section 450-8.016(A)(2)(e)].

Per review of 05.03.04 L1 Procedures Policy and Requirements, (revised 01/2018) states on page 3: "Annually validate that the management system, for maintaining procedures as current and accurate, is working effectively." Underneath this statement, the policy states: "For PSM/RMP covered processes, annually document the certification that procedures are current and accurate [no punctuation]" Per review, Annual Certification of Critical and Other Operating Procedures (revised 9/29/16) provides instructions on the "annual certification of unit Critical and Other Operating Procedures."

Per review, the Annual Certification of Emergency Procedures (revised 9/29/16) provides instructions on the annual certification of unit Emergency procedures.

Per review of the PUP (page 10), the policy states: "The methods for validating the effectiveness of procedure reviews are managed at the department level."

Per review, the operating procedures for each unit are certified annually.

For Site Logistics:-Critical and Other Operating Procedures - signed by Associate Production Director and dated 3/31/18, previous 3/27/17, 3/29/16-Emergency Procedures - signed and dated 7/31/18, previous 8/3/17, 8/30/16

For MEI (DCTFP, Brine wash, KOPy and Etherification) process units:-Critical and Other Operating Procedures - signed and dated 3/31/18, previous 3/28/17, 3/31/16-Emergency - signed and dated 7/31/18, previous 8/31/17, 8/31/16

Y NoneAbr



For Manufacturing Services (520 block):-Critical and Other Operating Procedures - signed by Lead Production Manager and dated 3/27/18, previous 8/22/17, 3/29/16-Emergency - signed and dated 8/24/18, previous 8/17/17, 8/18/16

For 660 block:-Critical and Other Operating Procedures - signed by Associate Production Director II and dated 3/30/18, previous 3/31/17, 3/31/16-Emergency - signed and dated 8/31/18, previous 8/31/17, 10/3/16

For 560 block:-Critical and Other Operating Procedures - signed and dated 8/31/18, previous 8/28/17, 3/30/17-Emergency - signed and dated 3/29/18, previous 8/30/16, 9/27/17


For site logistics:-Critical and Other Operating Procedures - signed and dated 3/31/18, previous 3/27/17, 3/29/16-Emergency - signed and dated 7/31/18, previous 8/3/17, 8/30/16

CCHMP reviewed the procedures below that were supposed to be reviewed annually per the plant policy and were not. Each procedure has a section called Document Review Frequency and Approval and written in the next column is the frequency of review. Per interview with SME, these are Critical procedures that needed to have the review frequency updated in WebODMS.-AHM C-5/C-6 A&B Startup Critical



Procedure Checklist (last reviewed 5/4/17)-AHM-Alpha Chlorine Evaporators Startup Critical Procedure Checklist (last reviewed 3/27/17)-AHM P-173A or B Startup Critical Procedure Checklist (last reviewed 3/29/17 but there was an update on 4/9/18)-AHM C-5/C-6 A&B Shutdown Critical Procedure Checklist (last reviewed 3/09/17)-AHM AO-227L Pressure Check Critical Procedure Checklist (last reviewed 3/27/17)

CCHMP was provided updates for the procedure above with the review cycle changed to 3 years.

Per review, Annual PPE Grid Review Procedure, revised 9/29/16, states in the Frequency section: "ANNUAL: Refer to the Master Task List for the schedule for completion check."

CCHMP reviewed the revision histories for the PPE grids for 310 block, 660 block, Man Services, 560 block, MEI, and found that 2 out of the five were not reviewed annually. -560 block reviewed 8/22/16, 8/24/17 but not 2018-MEI block reviewed 8/23/16, 8/29/17 but not 2018.

Dow provided documentation that the PPE grids above had been reviewed in 2018.

MOC-560B2018080004, started 8/23/18, status time stamp 8/30/18, Update PPE Grid

MOC-MEI-2018080009, started 8/23/18, status time stamp 10/15/18, Update PPE Grid




Does the submitted RMP accurately reflect the Operating Procedures Program at the stationary source? [T19 CCR §2745.2(d) & Section 450-8.016]

The 2014 RMP (pages 17 & 18) accurately reflects the Operating Procedures Program at the stationary source.

Y NoneAbr



* Complete the status column in the previous CalARP/ISO audit's Summary of Action Item table for this prevention program.* Identify a new action item along with periodic written updates to CCHMP (e.g., monthly) to complete outstanding action items or proposed remedies identified that are past due.1. This question is only applicable to stationary sources that have had prior CalARP/ISO audits by CCHMP.

There was one action item from the previous audit that has been addressed.

Y NoneAbr


A14 - CalARP Prevention Program: Training (Program 3)



Has the stationary source ensured that each employee presently operating a process, and each employee newly assigned to a covered process have been trained in an overview of the process and in the operating procedures provided in Section 2760.3? [T19 CCR §2760.4(a)(1) & Section 450-8.016(a)(4)(A)]

* Review the source of training (e.g., equipment vendor) and training requirements (e.g., state regulatory requirement, industry-specific standard), content of training, training style (e.g., classroom, computer-based, OJT) to ensure that it is commensurate with the training content, and the means used to verify competency.1. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks [T19 CCR §2760.4(a)(1) & Section 450-8.016(a)(4)(A)].2. On-the-job training (OJT) is acceptable, as long as the OJT program is documented [OSHA Region VI presentation on PSM in January 1994].

CCHMP reviewed the Site Training Policy and Procedures ODMS 05.03.01 (7/18/18), which established the minimum requirements and responsibilities for managing the training program at the Pittsburg site. The ultimate responsibility of the training program lies with the training coordinator which is responsible for assigning curriculum per roles using the Training Assignment Matrix.

Per review of the policy and Operator interviews, the initial training topics are instructor lead training that is covered as part of the New Employee Orientation Program (NEOP) but it is also Computer Based Training (CBT) and skill demonstration. The NEOP is required to complete the training prior to being released to shift. This process can take generally 8-10 weeks but can vary depending on the individuals abilities. Per follow-up interviews with Operators, operators are assigned to a plant within days of being employed, where they begin the NEOP, under guide of experience operators. After NEOP, Operators are released to shift and continue their training for 4-6 months.

CCHMP reviewed the policy "System Procedure Site Training Overview" (rev. 7/18/18), which established the minimum requirements and responsibilities for the management of training on the Pittsburg site. This policy discusses the roles and responsibilities of management and the employees, describes the learning management system, the development of site curriculum, training documentation.

The facility has established a PSM

Y NoneAbr



certification process to ensure personnel involved with operations activities are trained in the covered process and the management elements. CCHMP reviewed "PSM Training Certification Guidance (4/28/17), which describes both initial and refresher certification process for PSM and California facilities. The certification verifies that employees have completed an up-to-date EH&S training Summary which lists classes related to various PSM management elements including PSI, PHA, Operating Procedure, Training, PSSR, MI, Hot Work, MOC, II, Emergency Planning & Response, Employee Participation. The second part of the verification process is to ensures personnel are "qualified" in specific area/facility/unit by verifying knowledge/skills and understanding of the critical procedures, emergency procedures, understanding of Process Overview, operating limits, safety/heath hazards, and safe work practices. Per interview with Operators the verification is completed by passing a "Board of Review" process.

Personnel are required to review "Emergency Procedures annually and the Critical procedures every three years. CCHMP reviewed the records of three Operators the received their initial PSM Training Certification. CCHMP confirmed that had reviewed the emergency procedures annually, and the critical procedures at least once every three years. The individuals are required to complete a board review in which they are tested on various operating scenarios.

DOW has established a "grandfather" clause for operators that have started before January 4, 1994, where an "on-the job-evaluation or equivalent may be completed. The facility tracks all the training personnel have completed in a training database which also tracks the



procedures that have been reviewed.


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Has refresher training beenprovided at least every three years,and more often if necessary, toeach employee operating a processto ensure that the employeeunderstands and adheres to thecurrent operating procedures of theprocess? [T19 CCR §2760.4(b) &Section 450-8.016(a)(4)(B)]

* Review documentation maintained at thestationary source to verify that refreshertraining was conducted at least every threeyears. Documentation must be maintainedby the stationary source to ensurecompliance with this requirement. [CCHMPinterpretation]

Per policy, reoccurring/refresher trainingoccurs as follows: periodic review ofinitial training, as needed (e.g. as part ofcorrective action for an incident); processchanges related to MOC reviews,changes to training content, asdetermined by SME or DepartmentLeadership.

Employees that are absent from workmore then 30 days must meet with thetraining coordinator and agree on atimeline to complete training. Additionallythey must review and acknowledge allMOC in-service notifications issuedduring their absence.

Operations personnel receive PSMtraining re-certification every three years.The recertification includes the Refreshertraining for the following procedures:-Operating Procedures - Critical

Operating Procedures-Emergency Response - Emergency

Shutdown, Startup following anemergency shutdown-Operating Limits - Critical operating

limits-Safe Work Practices

A training certificate is generated andrecord maintained onsite. CCHMPreviewed the refresher trainingcertifications for six employees selectedrandomly from a list. The certificationsincludes their name, date completed, jobclassification, and sign off by twoindependent reviewers. OperatingTechnicians must receivetraining/information on the followingtopics: Operating Procedures,Emergency Operations, Safe WorkPractices, and Operating Limits.Operating Technicians demonstrateknowledge through: Oral ProficiencyExams, In Plant Training Modules,Process Observation, Performance

Y NoneAbr



History, and Existing TrainingDocumentation. The training certificationpackage includes the supportingdocumentation Verification Checklist anda PSM Training Summary Sheet.

The PSM Training Summary Sheet listsapproximately 65 classes totalcategorized by the various managementelements (PSI, PHA, PSSR, etc.). Thelist includes the completion date of eachclass, and the frequency.


Does the stationary source prepareand maintain records that containthe identity of the employee, thedate of training, and the meansused to verify that the employeeunderstood the training? [T19 CCR§2760.4(c) & Section 450-8.016(a)(4)(C)]

1. An auditable training records system willinclude at a minimum: the employee’sname; the name or description of anyformal training undertaken by the employee;the date and duration of any formal training;the results of related tests and certificationattained; the expiration date of any relatedcertificate, license, etc.; and a copy ofexternal certificates, licenses, etc. awarded[Plant Guidelines for TechnicalManagement of Chemical Process Safety,CCPS].

The facility maintains the PSM TrainingCertificates for all Operators andMaintenance personnel who work in thecovered process. The facility alsomaintains Operator Board of Reviewresults for employees at the individualplants. The facility maintains a "2018PSM Certification Tracking Log" forpersons that are PSM certified but notassigned to the facility. The facility alsomaintains in the training database all thetraining completed.

The Maintenance training coordinatorprovided a copy of the Learning Matrixwhich outlines all the mandatory,recommended and non-required trainingfor Contractors, Maintenance personneland Maintenance leaders. The matrixalso identifies the timeframe in which thetraining must be completed (e.g. within 6months, 24 months, etc.) Maintenanceemployees are required to completeglobal mechanical integrity fundamentals,SIS support, IPL support, visualinspections recognition of corrosion

Y NoneAbr




Has the stationary source trained each employee involved in maintaining the on-going integrity of the process equipment in an overview of that process and its hazards? [T19 CCR §2760.5(c) & Section 450-8.016(a)(5)(C)]

1. Examples of training in "the hazards of the process" may be training in the safework practices (e.g. confined space entry, lockout/tagout) and HazCom training.2. The same qualification criteria required for process operators under the training element of the PSM standard will apply to maintenance technicians, including the "grandfather" clause [OSHA Region VI presentation on PSM in January 1994].3. OSHA identified that without continual attention to training needs due to process changes and other changes, little assurance will exist that maintenance employees will perform their tasks safely [federal OSHA PSM Preamble].

Maintenance employees are PSM certified similar to operators, however instead of assigned zone and areas, maintenance employees are PSM certified by discipline. The facility currently has two disciplines site wide, Instrumentation and Electrical (I&E) and Mechanical.

The facility handed CCHMP a document titled, "PSM Certification Training Information Sheet", (not dated, no revision) which is a training matrix that identifies all the required training for the varying maintenance positions. CCHMP reviewed the PSM Training Certificate of two Mechanical Technicians, three Maintenance Engineers, two Electrical Reliability Engineer, two I&E Techs and three Millwrights and confirmed that all the employees have completed the required minimum training as indicated by the training matrix. However, CCHMP review of the "PSM Training Summary Sheet" notes that some Millwrights had completed additional training. Per follow-up with the training coordinator the facility has developed a training matrix.

CCHMP reviewed the procedural steps in PSM Training Certification Guidance, on "How to Verify Knowledge and Skills", and notes that there is not a procedural step to cross reference "PSM Training Summary Sheet" and the "PSM Certification Training Information Sheet" matrix. The facility may also want to include the training matrix as an attachment to the policy.

Y NoneAbr




Has the stationary source trained each employee involved in maintaining the on-going integrity of the process equipment in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner? [T19 CCR §2760.5(c) & Section 450-8.016(a)(5)(C)]

* Review employee’s (i.e., those employees doing nondestructive tests, welding on pressure vessels, etc.) training records for certifications, content of training, means to verify competency, etc. [OSHA 3133, PSM Guidelines for Compliance, 1994].1. Examples of "the procedures applicable to the employee's job tasks" may include vocational school training, trade schools, and community colleges.2. CCHMP expects that the facility has a process that assures maintenance employees understand and adhere to the facility's written maintenance procedures applicable to their job tasks [CCHMP interpretation].

CCHMP reviewed the training records for the maintenance employs identified in A14-07. Per interview with maintenance employees, training is provided mainly on-the job with CBT training. Both electrical and machinery employs receive OEM training on new equipment as needed. Dow also hires personnel from the local technical institute so they have a general background in industrial systems.

Y NoneAbr


Does the submitted RMP accurately reflect the existing Training Program at the stationary source? [T19 CCR §2745.2(d) & Section 450-8.016]

Pages 18-20 of the submitted RMP (rev. July, 2014 CalARP Resubmittal – NOD Revisions) accurately reflects the operator training program. Page 20, in the Mechanical Integrity section, accurately describes the maintenance training program.

Y NoneAbr




There were no ensure action items from the previous CalARP audit for this regulatory topic, therefore this question is not applicable.

N/A NoneAbr


A15 - CalARP Prevention Program: Mechanical Integrity (Program 3)



Has the stationary source established and implemented written procedures to maintain the on-going mechanical integrity of process equipment? [T19 CCR §2760.5(b) & Section 450-8.016(a)(5)(B)]

1. “Mechanical integrity” means the process of ensuring that process equipment is fabricated from the proper materials of construction and is properly installed, maintained, and replaced to prevent failures and accidental releases [T19 CCR §2735.3(y)].2. The mechanical integrity program for a covered process applies to: (a) Pressure vessels and storage tanks, (b) Piping systems (including ancillary components such as valves), (c) Relief and vent systems and devices, (d) Emergency shutdown systems, (e) Controls (including monitoring devices and sensors, alarms, and interlocks), (f) Pumps, compressors and their drivers. [T19 CCR §2760.5(a) & Section 450-8.016(A)(5)(a)]3. Mechanical Integrity applies to tanks and vessels that are not pressurized as well as those that are pressurized [OSHA Instruction CPL 2-2.45A CH-1 Appendix B - Clarifications and Interpretations of the PSM Standard].4. For ISO covered stationary sources, mechanical integrity includes the use of Industry Codes, Standards, and Guidelines, which are defined as "the edition of the codes, standards, and guidelines in effect at the time of original design or construction for the design, construction, alteration, maintenance, or repair of process units, industrial equipment, or

Pressurized Equipment: CCHMP reviewed the Global Mechanical Integrity Safety Standard (GMISS; version 2.2, revised 12/31/2016) which is applied to the following equipment: pressure containing equipment (e.g., pressure vessels, storage tanks); piping systems containing hazardous chemicals; piping systems containing non-hazardous chemicals which, in the event of a catastrophic release, would cause a threshold quantity release of a hazardous chemical; pipelines containing hazardous chemicals; relief devices; and miscellaneous items (e.g., flexible hoses, leak repair clamps, expansion joints, line blind valves); and cooling towers. Inspection and testing procedures for the above equipment has been developed based on OEM manuals and applicable standards (e.g., API 510, API 570).

Appendix C of the GMISS identifies an Inspection Deferral Process which allows for up to two 10% inspection deferrals (for wood cooling tower inspection tasks, the deferral process allows for up to two 25% inspection deferrals) for a maximum of 20% of the prescribed inspection frequency (maximum of 50% for wood cooling towers inspection tasks). The first deferral would require approval from the Production Leader and the EH&S Delivery Leader; the second deferral would require approval from the Process Safety Technology Leader (geographic preferred), Site Leader, and Business manufacturing Technology Leader/Business Manufacturing Leader. Additionally, risk-based mechanical integrity (RBMI) deferrals for relief devices may not exceed 12 months.

Appendix D of the GMISS identifies a Repair Deferral Process similar to the Inspection Deferral Process described above. A repair deferral would require the completion of an engineering evaluation to determine that no additional risk would result from deferring the repair for a specified period of time and approval by the appropriate site leaders.

Y NoneAbr



other industrial facilities, structures, or buildings published by the American Petroleum Institute (API), the Chemical Manufacturers Association (CMA), the American Society of Mechanical Engineers (ASME) or the American National Standards Institute (ANSI) [Section 450-8.014(f)].

Rotating Equipment: Inspection and testing procedures for rotating equipment are described in various Loss Prevention Principles (LPPs), engineering standards, or are contained in OEM manuals. Listed below are several procedures related to rotating equipment:- P440 Vibration Analysis, Basic Data Analysis Procedure (undated)- 102 Pump Quality Check (revised 11/9/15)- 442 Pump Check Procedure (revised 6/29/17)- Pump Material Verification Critical Procedure Checklist (undated)

Electrical: The Global Instrument/Analyzer Integrity Manual (GIIM, not dated) identifies the requirements for installation, operation, maintenance, and modification of instrumentation and electrical equipment related to basic process control systems (BPCS) and safety instrumented systems (SIS). SIS element proof testing are listed as critical maintenance procedures; SIS validation procedures have been developed for each SIS loop. Per interview with the Instrumentation and Electrical (I&E) subject matter expert (SME), maintenance procedures for the maintenance of atmospheric sensors are derived from the OEM manuals.

Deferral processes for the repair and proof testing of instrumented protective systems (IPS). The deferral processes allow for up to a 100% deferral of proof tests (i.e., from 6 months to 1 year) and a one-time repair deferral similar to the GMISS deferral processes described above. Per interview with the I&E SME, the IPS deferral process has not been used in since the previous CalARP audit; CCHMP reviewed the on-site maintenance database Meridium and verified that the deferral process has not been applied to IPS.



A15-02 Program 3 Callard & ISO

Have inspections and tests been performed on process equipment? [T19 CCR §2760.5(d)(1) & Section 450-8.016(a)(5)(D)]

1. Federal OSHA issued a Letter of Interpretation for their PSM rule on September 16, 1996 (to the Lever Brothers Company) that specified that inspection and testing records under the mechanical integrity program must be maintained for the lifetime of the process.

Per review of the Corporate Equipment Records Manual, equipment records including testing and inspection records for process equipment must be maintained for the life of the plant or equipment plus 4 years. Per interview with the Maintenance Activity Coordinator and Maintenance Technician, alignment procedures that are used to record alignment data when installing equipment are maintained for a month and then discarded. CCHMP acknowledges that Dow's corporate record retention policy meets the regulatory requirements and must be followed.

P Ensure that inspection and testing documentation is maintained per the Corporate Equipment Records Manual.




Is the frequency of inspections and tests of process equipment consistent with the following (a) applicable manufacturer's recommendations (b) good engineering practices (c) prior operating experience? [T19 CCR §2760.5(d)(3) & Section

* Review and document the criteria used for inspection and test frequency, including trends and tracking methods.1. This includes frequencies recommended by applicable standards such as API, NACE, NFPA, etc., and through experience gained by on-site mechanical integrity personnel only if it is more stringent than the manufacturer’s recommendations and applicable standards. [CCHMP Interpretation]2. If prior operating experience is used as the basis for testing and inspection frequencies, the past trends and experience must be documented to establish the justification for the frequencies used. [CCHMP Interpretation]

Per Section 2.10.3 of the GMISS, the maximum visual inspection interval of pressure containing equipment and piping systems is 2.5 years.

Table 4 of the GMISS identified maximum inspection frequencies for the following equipment:

Pressure Vessels (consistent with API 510 and NBBI NB-23): - external inspection - 5 years maximum; internal inspection - 10 years maximum- thickness measurements and other non-destructive examinations (NDE) - 10 years maximum- boiler inspections - 1 year or per local Code and/or agreement with local jurisdictional regulations (not to exceed 3 years)

Storage Tanks Meeting Applicability Criteria (consistent with API 653): - external inspection - 5 years maximum- thickness measurements and other NDE - 5 years maximum- internal inspection metallic tanks - 20 years maximum- internal inspection non-metallic tanks - 10 years maximum

Relief Systems (consistent with API 576, NBBI NB-23, NFPA 68): - pressure safety valve (PSV) inspection or replacement - 10 years maximum- low pressure pressure relief valve (PRV), pressure-vacuum relief valve/vacuum relief vents/emergency relief vents (PVRV/VRV/ERV) inspection or replacement - 10 years maximum- rupture disk replacement - 5 years maximum - explosion vent systems visual/functional inspection (functional test applied only to hinged panels) - 5 years maximum- open tank vents & liquid sealed vents - 5 years maximum- boiler reliefs - 1 year maximum or per local Code and/or agreement with local jurisdictional regulations (not to exceed 3 years)

Flame Arresters - 5 years maximum (consistent with NFPA 68)

Y NoneAbr



Equipment in Registered Piping Systems (includes injection points, pumps, compressors, valves, connected mechanical equipment (i.e., filters), instrumentation (including tubing and tube fittings), and piping support systems) - performed in conjunction with piping system inspections

Above Ground Piping Systems Containing Threshold Quantities of Hazardous Chemicals or with the Potential to Release Threshold Quantities: - qualified inspector visual external inspection: Class 1 & 2 Service: 5 years maximum; Class 3 Service: 10 years maximum; injection points - depends on class interval unless historical inspection data justifies a longer interval per API 570 (2009), Table 2- thickness measurements and other NDE: Class 1 Service - 5 years maximum; Class 2 & 3 Service - 10 years maximum; injection points - 3 years maximum unless historical inspection data justifies a longer interval per API 570 (2009), Table 2

Safety Instrumented Systems (SIS)/Interlocks: The Global Instrument/Analyzer Integrity Manual (GIIM) includes several tables (Table A1-A5) that identify frequencies for functional checks, visual inspections, and proof testing of IPL components for both BPCS and SIS

Analyzers: Per interview with the Technologist, most analyzers (LEL, sulfur dioxide, hydrochloric acid, chlorine, anhydrous ammonia) are calibrated on a quarterly schedule; hydrogen fluoride analyzers are scheduled on a monthly basis

Rotating Equipment (pumps/compressors/motors) frequency set by OEM, operating experience:- lubrication schedule - variable depending on the piece of equipment, ranging between weekly and annually [verify in database using list of rotating equipment]- vibration monitoring - for the majority of rotating equipment, vibration monitoring is conducted on a 35-day mean interval; approximately 5% of rotating equipment is continuously monitored for vibration- oil analysis - conducted on a monthly or quarterly basis, depending on the requirements of the - compressor analysis - Dow utilizes a tool,



Compressor Performance Analysis (CPA), which analyzes the performance of reciprocating compressors in service

Per interview with the Global GMISS SME, risk-based inspection (RBI) intervals are in development for all process equipment; at this time, about 66% of the fixed equipment is covered by RBI. The process to extend inspection intervals beyond the prescribed intervals are discussed in A15-01.




Has the stationary source documented each inspection and test that had been performed on process equipment? [T19 CCR §2760.5(d)(4) & Section 450-8.016(a)(5)(D)]

1. Documentation of tests and inspections does not mean certification or validation by a third party or by signature [29 CFR 1910.119 preamble].

Per interview with multiple SMEs, equipment inspections and tests are maintained on the central ECC/SAP maintenance database and within various electronic equipment file locations. CCHMP reviewed several fixed equipment files and reviewed the following tests and inspections that have occurred since the previous CalARP audit:

- T-10: visual inspection conducted March 2018; NDT inspection conducted October 2017- T-4: visual inspection conducted April 2018- E460-PROFUM-GEN___-T-5: NDT inspection for thickness readings conducted on 2/8/17- E460-PROFUM-GEN___-T-55: UT inspection conducted on 2/13/17- E466-620BLK-AUXBLR-T-102: External Visual and NDT inspections conducted on 9/19/18

The following piping circuit inspection reports were reviewed:- From MOC 310-SF2016070001, hydrostatic pressure test on a new piping circuit conducted 11/28/16; non-destructive examination (NDE) of welds conducted 11/15/16- E460-PROFUM-GEN___-HF_CIRC.-01: visual and ultrasonic inspection conducted on 5/3/18- E460-PROFUM-GEN___-HF_CIRC.-06: visual and ultrasonic inspection conducted on 5/1/18- E460-PROFUM-GEN___-SO2_CIRC.-01: visual and ultrasonic inspection conducted on 5/17/18- E466-620BLK-AUXBLR-ANH_NH3_CIRC.-02: visual, ultrasonic, and radiographic inspection on 6/5/17; inspection results and previous data resulted in inspection interval to be extended from 27 months to 54 months- E466-620BLK-AUXBLR-ANH_NH3_CIRC.-03: visual and ultrasonic inspection conducted on 8/22/16

Equipment files were reviewed for the relief devices below which confirmed that the appropriate test documentation was maintained and the associated testing frequencies were followed:- R-1462 (18-month schedule): last tested 10/11/17; previously tested 6/7/16- P660-R-73 (24-month schedule): last tested 4/24/18; previously tested 5/4/16

P Ensure that area monitor calibrations are completed per the established inspection intervals.

Ensure that a practice is established to document each oil analysis that has been performed on process equipment.

Ensure that a method is established to retain machinery alignment information documentation.

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- P660-R-74 (24-month schedule): last tested April 2018; previously tested- P320-R-29 (54-month schedule): last tested 3/20/18; previously tested 3/28/17, - P320-R-30 (36-month schedule): last tested 7/6/17; previously tested 7/22/15- P320-R-31 (57-month schedule): last tested 4/20/16; previously tested 7/15/13- P320-R-78 (24-month schedule): last tested 4/10/17; previously tested 5/1/15 - P320-R-79 (12-month schedule): last tested 12/18/17; previously tested 1/23/17, 2/22/16- P420-R-40 (12-month schedule): last tested 8/17/18; previously tested 8/16/17, 9/19/16, 1/12/16- P420-R-41 (24-month schedule): last tested 1/8/18; previously tested 2/10/16- P560-R-35 (12-month schedule): last tested 11/16/17; previously tested 11/17/16- P560-R-36 (12-month schedule): last tested 1/11/18; previously tested 1/26/17, 3/4/16

The following instrumentation inspections were reviewed:- P-560 Chlorine Monitor Quarterly Inspection (covers AI(781)P - AI(793)P, AI(761)Q - AI(780)Q, AI(794)Q - AI(799)Q): conducted 9/22/18, 6/23/18, 3/26/18- IA10-Chlorine Monitor Calibration and SIS Proof Tests (covers AI(789)P, AI(761)Q, AI(763)Q - AI(780)Q, AI(795)Q - AI(799)Q: conducted 11/14/17- C619 High Temperature SIS Validation: conducted 7/22/16- IA10-P660 Chlorine Area Monitor Calibration: conducted 8/24/18, 7/24/18, 2/15/18, 1/3/18- SIF# 608.01 R-3D Loop Validation Test Procedure Checklist: completed 12/14/12- SIF# 553.01 R-3C Loop Validation Test Procedure Checklist: completed 12/14/12- C-619 High Temperature SIS Validation Procedure Checklist: completed 7/22/16- R-901 Flame SIS Validation Procedure Checklist: completed 12/21/17- C-619 Liquid Feed SIS Validation Procedure Checklist: completed 7/22/16- SIF-24 1 SIS Loop Validation Test Procedure Checklist: completed 1/16/18

The following vibration analyses conducted on



rotating equipment were reviewed:- P-634A: most recent analysis conducted 8/22/18- P-72: conducted 8/22/18- P-35A: conducted 9/18/18- P-30: conducted 9/5/18

Oil Analysis: The facility does not have consistent access to previous oil analyses. The facility contracts oil analyses to be performed by a third party contractor which makes the information accessible to Dow via an online portal. Per interview with Oil Technician the portal has not been working for approximately four weeks and the facility does not have access previous oil analyses outside the web portal. The facility does not save a digital copy to the equipment database, nor do they print a hard copy for the records. The facility relies on the contractor to manage their oil analysis records. The facility needs to establish a practice to document each oil analysis that has been performed on process equipment.

Machinery Alignment: The facility does not have a system to record final shaft alignments for rotating equipment requiring alignment. Per interview with Maintenance Activity Coordinator and Maintenance Technician, the facility is tracking the information in a database but when the migration went over to SAP the information was no longer being captured. Millwright personnel capture the information in one of five rotoaligns, and record the information in the procedure. However procedures are discarded after approximately one month and alignment information on equipment is not practical to retrieve and may not be available if done by a contractor.

From the above records, the chlorine area monitors for the 660 block were not consistently documented on physical records; several of the monitors identified by the IA10-Chlorine Monitor Calibration and (SIS) Proof Test Critical Procedure Checklist did not have any physical records available for review which demonstrated that calibration was conducted. Per review of the SAP database records, multiple quarterly chlorine monitor calibrations were not completed as scheduled for a majority of the monitors in the 660 block (e.g., AI-012A and AI-025A). Per interview, there were no deferrals



generated for the above maintenance items.

Per interview with the on-site Oil Analyst, oil samples are collected and sent off-site to be analyzed by a contractor with the results of the analyses stored online and made accessible through the portal provided by the contractor. CCHMP requested to review a sampling of the data from the oil analyses but Dow was unable to provide the documentation due to an issue with the web portal on the vendors side. Dow currently does not back up the oil analysis data to an onsite location. See A15-06 regarding oil analysis documentation.


Does the inspection and testing documentation identify: (a) the date of the inspection or test, (b) the name of the person who performed the inspection or test, (c) the serial number or other identifier of the equipment on which the inspection or test was performed, (d) a description of the inspection or test performed, (e) the results of the inspection or test? [T19 CCR §2760.5(d)(4) & Section 450-8.016(a)(5)(D)]

CCHMP reviewed the inspection and testing records discussed in A15-05 included the required data:- date of the test/inspection- name of the person who conducted the test/inspection- equipment identification number- type of test conducted (e.g., pop test, external inspection, NDT, internal inspection, hydrotest)- the results of the test (i.e., pass/fail, issues found)

Oil Analysis: As described in A15-05, the facility currently does not have access to the oil analysis documentation, so CCHMP was provided a sample report to review the type of information reported. Date sample, name of equipment, a description of the test results, results of the analysis and min. and max values. The oil analysis does not include the name of the sampler, however per Interview with Reliability SME, there is only one Oil Technician that collects the sample.

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Has the stationary source corrected deficiencies in equipment that are outside acceptable limits before further use or in a safe and timely manner when necessary means are taken to assure safe operation? [T19 CCR §2760.5(e) & Section 450-8.016(a)(5)(E)]

1. The acceptable limits should be defined under T19 CCR §2760.1(c), process safety information.2. Equipment found operating outside acceptable limits does not have to be shut down if other protective measures and continuous monitoring are available, and the deficiencies are corrected in a "safe and timely manner." [OSHA Instruction CPL 2-2.45A CH-1 Appendix B - Clarifications and Interpretations of the PSM Standard].

Per Section 2.10.13 and 2.10.14 of the GMISS, when a deficiency is noted, an assessment using the GMIM (Global Mechanical Integrity Manual) Deficiency Form or equivalent is made by the inspector, owner, materials SME, qualified designer, equipment SME, and people with other related expertise as appropriate with the timing for repair/monitoring plan established by a qualified inspector or designer. The GMIM Deficiency Form identifies general information about the deficient equipment (equipment number, functional location, equipment type, form initiation date, form initiator) and a Fitness for Service (FFS) Evaluation used to determine the resolution and resolution date. A list of procedures to conduct a FFS are described in the Engineering Specification G8S-4502-10 (dated 12/17/15) and include brittle fracture, uniform metal loss, local metal loss, pitting corrosion, blisters and laminations, weld misalignment and shell distortions, crack-like flaws, and fire damage. The majority of the equipment-specific FFS procedures reference API 579.

Two temporary MOCs covering temporary repairs were identified that included temporary repairs:- P520-2017060010 - temporary spool piece for leaking Teflon-lined pipe- FPI-A2017010001 - temporary leak clamp placed over leaking vent flange

One permanent MOC, FPI-A2017020002, involved a change in metallurgy for a series of rupture discs located downstream from multiple PRVs. These discs were damaged due to the discs being attached to a line that fed into a chlorine header that was susceptible to high back pressure. Once this occurred, it produced a corrosive environment that led to attacks on the carbon steel PRVs. An SME located the entry in the equipment database for the rupture disc, P420-D-19, which did not reference the new material being used. The entry was updated during the audit with the correct material.

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Does/did the stationary source assure that equipment as it is fabricated is suitable for the process application for which they will be used (in the construction of new plants and equipment)? [T19 CCR §2760.5(f)(1) & Section 450-8.016(a)(5)(F)]

* Review and document the criteria used for QA/QC of process equipment as it is fabricated – ask engineering department or equivalent.1. A QA/QC process includes providing the vendors with equipment performance and materials of construction requirements, and shop and field testing such as leak tests, hydro tests, operating curve tests, etc. [CCHMP Interpretation]

CCHMP reviewed several Piping Material Specification documents related to hydrogen fluoride/hydrofluoric acid (Eng Spec No AI-25, published 5/15/18; Eng Spec No AI-26, published 8/8/18), anhydrous ammonia (Eng Spec No EN-03, published 1/30/18), and chlorine (Eng Spec No CA-03, published 2/6/18). The notes regarding testing/inspection/examination identify the type of service (all considered normal fluid service as defined by ASME B31.3), radiography requirements for welds, and additional testing prior to installation if required (leak testing, hydrostatic testing, pneumatic testing).

CCHMP reviewed the Material Verification Program - Piping (G8S-5002-03, dated 9/14/15) identifies several levels for PMI examination:- PMI Examination Level 0 - Code Required PMV: visual inspection according to the referenced piping code- PMI Examination Level 1 - Sampling: X-ray fluorescence or spark OES for 25% of random finished welds, process wetted piping, and accessible valve components (at least 1 test from each welder; minimum of 2 tests per weld for pipe welds)- PMI Examination Level 2 - Full Finished: X-ray fluorescence or spark OES for 100% of finished welds, welded connections, and accessible valve components; for NPS 3" or greater, 4 readings on welds 90 degrees apart; for NPS 2" and below, 2 readings on welds 180 degrees apart- PMI Examination Level 3 - Full in Process: X-ray fluorescence or spark OES for 100% of root passes, 100% of finished welds, joined components, and accessible valve components; root pass tests required 1 test per nominal inch of diameter equally spaced around the pipe with a minimum of 2 tests per weld 180 degrees apart and a test of consumables used by the welder

Per interview with a maintenance planner, procedures for positive material identification (PMI) are used to verify any components or equipment received by the warehouse. CCHMP reviewed the Pump material Verification Critical Procedure Checklist (not dated) which is used to ensure the

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wetted parts of the pump is constructed of the required material through verification of existing pump material documentation or analysis using the XRF Alloy Analyzer for metallic components and FTIR Analyzer for non-metallic components.

Per interview with the Global GMISS SME, pipe testing and inspection requirements are defined in individual piping specifications developed by Dow. CCHMP reviewed one MOC, 310-SF2016070001 (start up dated 7/3/18), that included a new line used for reprocessing off-spec product. CCHMP reviewed the post-fabrication inspection records which included hydrostatic pressure testing and non-destructive examination of 20% of the welds.




Does/did the stationary source assure that appropriate checks and inspections have been performed to assure that equipment is installed properly and consistent with design specifications and the manufacturer's instructions? [T19 CCR §2760.5(f)(2) & Section 450-8.016(a)(5)(F)]

* Review and document the criteria used for QA/QC of process equipment as it is installed.1. This includes project monitoring, field weld X-rays, system leak checks, system hydro tests, positive material identification, etc. [CCHMP Interpretation]

CCHMP reviewed one MOC, 310-SF2016070001, that involved the installation of a 1" line used for reprocessing of off-specification product. Per interview with the Global GMISS SME and a review of the maintenance database, the inspections required for the installation of the new line were completed. The documentation of the inspection for the new piping circuit are discussed in A15-05.

Per interview with the Vibration Analyst, currently Dow does not require a baseline vibration analysis for newly or recently installed rotating equipment; however, it was acknowledged that a baseline vibration reading for critical equipment would be beneficial. Per API 686 Chapter 9 Section 4.21.1 and 4.21.4, "During initial start-up of the equipment, …[v]ibration signatures shall be obtained for all bearings."

Machinery Alignment: Per interview with Maintenance Technicians, Maintenance Personnel and the facility performs alignment on machinery. However as discussed in A15-05, the results of the alignment are not being retained so CCHMP was unable to confirm the actual results.

Gasket: CCHMP reviewed pipe specification CA-03 (rev. 2/6/18) that is rated for 300F @ 380 psig, and notes there are multiple gaskets identified. The specification calls for four types of gaskets, each with a list of different manufactures. In total there are 17 different gaskets that are acceptable for use. Per interview with maintenance personnel, Process Engineers, and Design Engineers, all 17 gaskets are acceptable for use on the process. CCHMP was also told that Dow uses a hierarchy to select the gasket. CCHMP further notes that the first and second choice of gaskets are also identified in The Chlorine Institute's Pamphlet 95, "Gaskets for Chlorine Service (Edition 5)". CCHMP further notes Pamphlet 95 provided the following annotations for those gaskets :

-Flexitallic Sigma 533, Tested for service conditions between 20°F (-7°C) and 72°F (22°C). -Garlock Gylon 3510, Tested for service conditions between 100°F (38°C) and -90°F (-68°C).

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CCHMP followed up with Dow Process Engineers who indicated that the technical team that is responsible for identifying the gaskets appropriate for the pipe specification's associated service recorded the following operating ranges for the above gaskets:

- From Dow's Commodity Dictionary: Flexitallic Sigma 533, temperature range of -350F to 500F- From OEM specification sheet: Garlock Gylon 3510, temperature range -350F to 500F @ 1200 psig


Does the submitted RMP and Safety Plan accurately reflect the Mechanical Integrity Program at the stationary source? [T19 CCR §2745.2(d) & Section 450-8.016]

CCHMP reviewed a description of Dow's mechanical integrity program on Page 20 of the submitted 2014 RMP and determined that the description generally reflects the program. The RMP includes a list of inspection intervals from relevant RAGAGEP (e.g., ASME, API) which may be applied to various pieces of process equipment; per interview with several SMEs, Dow has implemented risk based inspection intervals for some of the covered process equipment. CCHMP suggests updating the mechanical integrity section to reflect this in the next RMP submission.

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No ensure action items were issued in the 2015 CalARP audit. This quesiton is not applicable.

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A16 - CalARP Prevention Program: Management of Change (Program 3)

ID# Categor Question Clarifications Findings Answer ActionsType


Has the stationary source established and implemented written procedures to manage changes (except for "replacement in kind") to process chemicals, technology, equipment, and procedures? [T19 CCR §2760.6(a) & Section 450-8.016(a)(6)(A)]

* Review MOC policy to ensure the ISO stationary source has a process to conduct an ISSA for a “major change”, that could reasonably result in a MCAR. The policy should define what is considered a major change. Criteria for how site personnel would determine whether a change could reasonably result in a MCAR should also be included in policy.* Review MOC records for the ISO stationary source for any major changes and provide records to auditor doing A34 so ISS can be evaluated.1. "Replacement in kind" means a replacement that satisfies the design specifications [T19 CCR §2735.3(tt)].2. Examples of changes in process technology include (a) production rates (b) new equipment (c) change in catalysts (d) changes in operating conditions to improve yield or quality [OSHA 3133, PSM Guidelines for Compliance, 1994].3. Examples of changes in equipment include (a) materials of construction (b) piping arrangements (c) alarms and interlocks [OSHA 3133, PSM Guidelines for Compliance, 1994].4. Sources with Program 1 or 2 covered process that are undergoing a covered process modification, as described in §2745.11, must develop procedures to manage that change and notify CCHMP that those procedures have been established (and answer the MOC audit questions) [T19 CCR §2745.11].5. OSHA's PSM preamble identifies that changes made to operating procedures need to be handled through the MOC Program. Maintenance procedures were not specifically identified within the PSM preamble. The CalARP regulation states changes to "procedures" need to be managed and does not only limit it to

CCHMP reviewed ODMS (Operating Discipline Management System) 05.03.05, Management of Change Policy, Requirements & Performance Principles (revised 05/2016) which is the corporate policy; and S-334 Management of Change (revised 01/18/17) which is the plant policy. Per SME, the MOC (Management of Change) at the facility is generated using the electronic Global MOC tool and must meet the standards of the local policy as well as the corporate policy. S-334 also references L3 Global MOC Standard which is no longer being used as the MOC corporate policy. CCHMP also reviewed ODMS 05.03.05, L2 Management of Change Process (revised 05/2016).

Per review of ODMS 05.03.05, Level 1 Documentation MOC Process (revised 11/30/15) the following categories are used:

-Level 1 - changes that have low risk (minimal or no potential for personal injury, adverse health impact, environmental impact, product quality incident or economic loss) and do not require training other than MOC notification. A few examples of Level 1 changes: -Revising a normal operating procedure by removing a step that is no longer required.-Revising an inspection procedure to add or delete specific equipment requiring inspection.

-Level 2 - any change that is not defined as a Level 1 change. Examples of Level 2 changes:-Revisions to emergency and critical procedures.-Updates to area electrical and hot work classification.-Creation of new operating or maintenance

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operating procedures. Auditors need to verify that facilities with Program 3 covered processes have a way to manage changes to operating procedures through a MOC process and a formal policy or protocol to manage changes to maintenance procedures. [CCHMP interpretation]6. Examples of operating or maintenance procedure changes subject to MOC requirements include those that are beyond formatting, grammar, typographical errors, etc., and include changes, that are not associated with changes in process chemicals, technology or equipment. [CCHMP interpretation]7. Procedure changes that are independent of other changes require either that the MOC procedure/policy or separate procedures/policies clearly indicate that changes require a minimum of a technical basis/analysis, a health and safety review, and documentation of the above along with training and notification documentation, as appropriate. [CCHMP interpretation]

procedures.

CCHMP reviewed the following MOC's which covered different operating units within Dow. Per review of the policies above and the MOC's below, Dow generates MOCs for equipment that is not replacement in kind. Also, there were more MOC's for some units than others which meant that CCHMP had more to choose from in those units.

Unit 520

P520-2017010009, origination date 1/19/17, status time stamp 4/27/17

Unit 660

P660-2018020010 origination date 2/13/18, status time stamp 6/28/18P660-2018020010, origination date 2/13/18, status time stamp 6/28/18P660-2017040019, origination date 4/13/17, status time stamp 7/6/17P660-2016100013, origination date 10/17/16, effective date 1/19/17P660-2016040006, origination date 4/8/16, effective date 6/11/16P660-2016080008, origination date 8/11/16, effective date 9/1/16P660-2017010016, origination date 1/19/17, effective date 2/17/17

Unit 560

560P2016030006, origination date 3/29/16, effective date 3/30/16

Unit 310

310-SF2016050002, origination date 5/23/16, effective date 6/1/16

FPI-A201702002, origination date 2/21/17, effective date 5/25/17FPI-A201602004, origination date 2/15/16, effective date 2/23/16




Do the Management of Change procedures address the impact of the change on safety and health prior to any change? [T19 CCR §2760.6(b)(2) & Section 450-8.016(a)(6)(B)]

* Review PHA's, meeting minutes, or other reviews conducted to ensure that the impact of the change on safety and health was addressed.1. Sources with Program 1 or 2 covered process that are undergoing a covered process modification, as described in §2745.11, must develop procedures to manage that change and notify CCHMP that those procedures have been established (and answer the MOC audit questions) [T19 CCR §2745.11].

Per review of the MOCs in A16-01, there is a column titled Review Type Name that lists the different areas of review. One of those areas is Health and Industrial Hygiene. This group covers the safety and health topics related to MOCs. There are questions that cover topics such as impact to personnel safety, change on regulatory requirements, protective systems, EH&S requirements, and change involving TSCA 5(e) or SNUR chemicals. This applies only to MOCs that would impact safety and health as other MOCs do not have this section.

Per SME, Dow made a change to the MOC process. This was added February 2017 to the questionnaire as follows:

"[PITTSBURG] Are there any potential impacts on SAFETY OR HEALTH as a result of this change AND the SAFETY and/or HEALTH AND INDUSTRIAL HYGIENE reviews have not been added as part of the selected CIMS? (If YES add both a SAFETY and HEALTH & INDUSTRIAL HYGIENE review.)"

CIMS - change impact matrix

Per SME, this question is answered No if the Health and Industrial Hygiene and Safety (which are different sections of the questionnaire) questions already cover the health and safety impact. Below are a few examples of how the Health and Industrial Hygiene and Safety were evaluated as part of the MOCs: FPI-T2017120002, start 12/11/17, effective 1/25/18, Upgrade Respiratory Protection for Chlorinate/Fluoridated Pyridines, has both the Health and Industrial Hygiene and Safety sections.

FPI-B12016050005, start 5/12/16, effective 6/24/16, Mass Transition to RBI inspection intervals for E463 (AFTF and TRIFL) has

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both as well.

P660-201608008, start 8/11/16, effective 2/20/17, Beta: Increase High Pressure Chlorine Operating Pressure, has both.


Do the Management of Change procedures address modifications to and/or development of new operating and maintenance procedures prior to any change? [T19 CCR §2760.6(b)(3) & Section 450-8.016(a)(6)(B)]

1. Sources with Program 1 or 2 covered process that are undergoing a covered process modification, as described in §2745.11, must develop procedures to manage that change and notify CCHMP that those procedures have been established (and answer the MOC audit questions) [T19 CCR §2745.11].

CCHMP reviewed the MOCs from A16-01 and found that the MOC's below had either procedure updates or new procedures:

-560P2016030006, Procedure update for R600 E and 600 F (Reactors) shutdown Procedure Critical Checklist

-FPI-A2016020004, 541 Cleaning and isolation procedure checklist major revision.

-310-SF2016060004, Air gap N2 supply to T-5 and T-27

All of the procedures above were updated as a result of the MOCs.

The following MOCs required creating new procedures:

-310-SF2016050002, Created procedure SF Plant DO(506X) Clearing and Isolation Procedure Checklist (revised 5/23/16)

-P660-2016100013, Created procedure AHM-R-3C AO-323L Vent Valve Isolation (revised 10/17/16)

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Do the Management of Change procedures address the necessary time period for the change prior to any change? [T19 CCR §2760.6(b)(4) & Section 450-8.016(a)(6)(B)]

* Review records on how temporary changes are tracked and how the changes are restored to their original or design conditions.* Review the procedures and policies in place that address when a temporary change can be kept longer than specified in the MOC. 1. Sources with Program 1 or 2 covered process that are undergoing a covered process modification, as described in §2745.11, must develop procedures to manage that change and notify CCHMP that those procedures have been established (and answer the MOC audit questions) [T19 CCR §2745.11].2. Time limits should be defined for all temporary changes and monitored. Since otherwise, without control, these changes may tend to become permanent. The MOC procedure must also address how equipment and procedures are restored to their original or design conditions at the end of a temporary change [OSHA 3133, PSM Guidelines for Compliance, 1994].

Per review of S-334 (page 15), the Temporary MOCs timeline is governed by the Expiration section. This section states that an expiration date must be identified for each temporary MOC. It lists the tracking tools used for temporary MOCs as corrective and preventive action tracking (The Event & Action Tool), MTL (master task list), and SAP/ECC (equipment management system). It also states that a temporary MOC cannot be closed until the change has been returned to its original state. A temporary MOC expiration date can be extended but it would need to go through "re-review" and "re-approval" which must be documented in the electronic MOC tool.

Per review of documentation and interview with SME, the following MOCs would be considered temporary:

-MOC P660-2016110009, started 11/17/16, Beta: Seal Weld AI-239B dP transmitter connection, this would qualify as a temporary MOC (per SME), the title sheet lists Date needed (11/25/16), origination date (11/17/16), status time stamp (3/4/17), and classification expiration date (10/31/17).

-MOC P660-2017010016, started 1/9/17, Temporary Removal of B-52 LSH L047:DI:338 would also qualify as a temporary MOC. Date needed 2/3/17; status time stamp 2/27/17; classification expiration date 7/1/17.

-MOC P660-2016070009, needed 7/13/16, expiration date 7/31/2016-MOC P660-2016080011, needed 8/19/2016, exp date 10/31/16-MOC P660-2017110011, needed 12/8/17, exp date 11/30/18-MOC P660-2018050014, needed 6/15/18, exp date 11/30/18

CCHSHMP confirmed that Dow is following the plant policy by making sure that MOCs

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are closed by the expiration date. Per interview with an SME, getting an extension for a temporary MOC is not an easy process and would require going back through the same process. Instead of requesting an extension, the originator will instead generate a permanent MOC.




Are employees involved in operating a process informed of, and trained in, the change prior to start-up of the process or affected part of the process? [T19 CCR §2760.6(c) & Section 450-8.016(a)(6)(C)]

* Review training records or meeting minutes to show that affected employees were trained in the change.1. OSHA intends that the requirements for communication and training be completed prior to start but not necessarily before the change is made [29 CFR 1910.119 preamble].2. Sources with Program 1 or 2 covered process that are undergoing a covered process modification, as described in §2745.11, must develop procedures to manage that change and notify CCHMP that those procedures have been established (and answer the MOC audit questions) [T19 CCR §2745.11].

Per SME, the training for MOCs is documented via email. On the last page of each MOC is a box titled Notify Startup and Acknowledgement that lists the Effective Date and Effective Time in a separate box and then in a box below lists the Name and Date/Time Acknowledged. For the Date/Time Acknowledged column, some entries have a date followed by "Trained and Notified" and others only have the date. This would be for someone who only needed notification.

Per interview, the operators receive training that comes from an MOC either by a slide presentation distributed through email or by in person training (IPT). Per SME, most MOC related training is done using IPT.

CCHMP reviewed the following MOCs and training documentation that accompanied each:

-310-SF2015050002, status time stamp 12/2/15, Making adjustments from the V058 MOD to a different sequence. Per live navigation with SME, the training was conducted on 6/16, 6/17, and 6/22/15.

-FPI-A2016020003 (status time stamp 5/18/17) which is for a trial to replace rupture disks with PFA Teflon lining with graphite and change the set pressure to 15 psig @ 150 F (current is 4-8 psig @ 72 F).

The originator of the MOC marked a training question "Yes" in the Common section but one of the reviewers changed the training requirement to "No" on the MOC. This was carried through to the PSR Short form which had N/A for training.

-FPI-A2016020004 (status time stamp 3/23/16) which is for B-541 clearing and isolation procedure checklist. There is a training log attached to the MOC with training performed on 2/15, 2/16, 3/1, 3/11,

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3/22/16.

CCHSHMP verified that the training was completed as part of the MOC process. Per interview with SME, in the event that a person is on vacation or is absent for an extended period of time, that person would be required to be trained before coming back on shift.


Are maintenance employees whose job tasks will be affected by a change in the process informed of, and trained in, the change prior to start-up of the process or affected part of the process? [T19 CCR §2760.6(c) & Section 450-8.016(a)(6)(C)]

* Review training records or meeting minutes to show that affected employees were trained in the change.1. OSHA intends that the requirements for communication and training be completed prior to start-up but not necessarily before the change is made [29 CFR 1910.119 preamble].2. Sources with Program 1 or 2 covered process that are undergoing a covered process modification, as described in §2745.11, must develop procedures to manage that change and notify CCHMP that those procedures have been established (and answer the MOC audit questions) [T19 CCR §2745.11].

Per review, S-334 states under section Contractor Notification: "Contingent Staff and other contractors with Dow computer access are notified of changes in the same manner as Dow employees via the electronic MOC tool." Below this is a paragraph that describes how Independent Contractors and other contractors without access to Dow computers would receive information through the Contractor MOC Notification Process, revised 6/26/18. In this policy there is a form, Contractor MOC Notification Form, that is to be filled out with the MOC number, Contract Firm, MOC title, Scope, Justification, Contractor Name and Contractor signature, and date. Once this form is complete, it is emailed to the contacts at the contract company. In step 4 of the policy, there is a note to request that the contacts review the change with their personnel, have each affected employee sign and date the form, and to return it to the "DOW MOC Change owner."

CCHSHMP was informed that affected plant maintenance personnel are trained in process changes along with the operators. CCHSHMP confirmed that the MOCs in A16-08 that required training included maintenance personnel on the sign in sheets. These were FPI-A2016020003 and FPI-A2016020004.

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Does/did the stationary source ensure that if a change results in a change in the PSI (§2760.1 and Section 450-8.016(A)(1)), that this information will be updated accordingly? [T19 CCR §2760.6(d) & Section 450-8.016(a)(6)(D)]

1. Sources with Program 1 or 2 covered process that are undergoing a covered process modification, as described in §2745.11, must develop procedures to manage that change and notify CCHMP that those procedures have been established (and answer the MOC audit questions) [T19 CCR §2745.11].2. Sources should promptly update the PSI, at a minimum, PSI must be updated prior to the next PHA. (e.g., redline mark-ups of P&IDs need to be formalized). [CCHMP Interpretation]

CCHMP reviewed over 20 MOCs for different plants and found the following deficiencies:

Per review, MOC MEI-2018020002 (started 2/2/18, effective date 5/30/18) Install VFD on R-1200's agitator, has under the MOC checklist P&ID Master Updated with the action marked "Yes." This was for drawing BI-421-640 (revised 12/12/17). The drawing had a red MASTER stamped on it. Per the SME, this is the most up to date drawing. However, the drawing has not been updated with the new VFD since the MOC was issued.

Per review, MOC FPI-A2017020002 (status time stamp 12/13/17) for the rupture disc material to be changed to graphite permanently has the line for P&ID Master Updated marked "Yes." However, CCHMP was unable to confirm that this change had been documented in the PSI as there was no documentation related to the material

P Ensure that the P&ID is updated as part of the MOC process.

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Does/did the stationary source ensure that if a change results in a change in the operating procedures or practices (§2760.3 and Section 450-8.016(A)(2)), and/or results in a change in the written procedures to maintain the ongoing integrity of process equipment required by Section 2760.5 that such procedures or practices will be updated prior to the start-up of the process? [T19 CCR §2760.6€ & Section 450-8.016(a)(6)€]

1. Sources with Program 1 or 2 covered process that are undergoing a covered process modification, as described in §2745.11, must develop procedures to manage that change and notify CCHMP that those procedures have been established (and answer the MOC audit questions) [T19 CCR §2745.11].2. For this regulatory requirement, “updated accordingly” is interpreted to mean update the written operating procedures or practices prior to start-up of the process. [CCHMP Interpretation]

Per review, S-334 states in the Before/After Action Items section that, "The following action items must always be resolved BEFORE the change is placed IN SERVICE (i.e. started up)-Operating, Safety, Maintenance and Emergency Procedures created or updated and published.-Process Safety Information updated and available-Hazard Assessments completed and safeguards or layers of protection implemented.-Training completed.-Pre-startup Review completed."

CCHMP reviewed the MOCs below from A16-01. Each MOC contained information about changes related to the process including operating procedures.

Unit 660-P660-2016100013, effective 12/19/16-P660-201604006, effective 6/11/16

Unit 310-310-SF2016060004, effective 6/27/17-FPI-A2017020002, effective 5/25/17

Per CCHMP review, all of the operating procedures were updated as indicated in the MOCs prior to start up.

Y NoneAbr


Do the submitted RMP and Safety Plan accurately reflect the Management of Change Program at the stationary source? [T19 CCR §2745.2(d) & Section 450-8.016]

The submitted 2014 RMP accurately reflects the Management of Change Program (pages 20 & 21) at the stationary source.

Y NoneAbr






There was one action item from the previous CalARP audit which has been completed. This was for question A16-04.

Y NoneAbr


A17 - CalARP Prevention Program: Pre-Startup Review (Program 3)



Does/did the stationary source perform pre-startup safety reviews for modified stationary sources when the modification is significant enough to require a change in the process safety information? [T19 CCR §2760.7(a) & Section 450-8.016(a)(7)(A)]

* Review completed PSSR's and corresponding information. Employee interviews may identify changes to the regulated source which should have required a PSSR.1. A PSSR must occur if a change at a stationary source results in a change in PSI [CCC CAER MOC Workshop by Science Applications International Corporation, December 12, 2001]. (T19 CCR §2760.7(a))2. PSI must be modified before startup [OSHA Instruction CPL2-2.45A CH-1 Appendix B - Clarifications and Interpretations of the PSM Standard, September 13, 1994].3. Sources with Program 1 or 2 covered process that are undergoing a covered process modification, as described in §2745.11, must develop procedures to manage that change and notify CCHMP that those procedures have been established (and answer the PSSR audit questions) [T19 CCR §2745.11].4. Modified Stationary Source means a stationary source which has undergone an addition or change which qualifies as a "major change" as defined in T19 CCR §2735(x) [T19 CCR §2735(bb)].5. Major change means introduction of a new process, process equipment, or regulated substance, an alteration of process chemistry that results in any change to safe operating limits, or other alteration that introduces a new hazard [T19 CCR §2735(x)].

Per review, S-333 Pre-Startup Review (revised 9/28/18) provides the minimum requirements for doing a PSR (Pre-Startup Review) when changes to process or the facility using the MOC (management of change) or Global Project Methodology (GPM) work process. Per SME, the GPM is for new projects and the Dow Pittsburg facility has not built any new processes. There are processes in the pipeline that would use GPM but these projects are not going to be started for several years.

CCHMP reviewed section 02.01.01, titled Need for a PSR, of S-333. The PSR is required: "...for new facilities, changes that have potentially significant impact, modified facilities when change requires a change in PSI (process safety information), alterations or modifications that introduce new hazards, physical changes, or as determined by other policies and procedures.

In section 02.01.03, Team Members, the policy states that the audit team must include the change over or project manufacturing representative (or designee), safety representative (or designee), operations representative and/or other person affected by the change/modification, other as required (Industrial Hygiene, Engineering, Environmental, Tech center, maintenance, process safety, etc.)

Per review, S-333 PSR Short Form (revised 12/16/14) provides a Pre-Startup Review "...for a non-physical change or for minor physical changes at the discretion of the Change Owner, Subject Matter Reviewers and Final Approver."

CCHMP reviewed the following PSRs at

Y NoneAbr

Page 1 of 5Dow Chemical- 2018 CalARP Audit Findings22-Mar-19


Dow:-PSR Short form (dated 6/16/18) for MOC P660-2018020010

This was for adding Hastelloy C-276 in B-105 bottoms. Hastelloy C-276 was not part of the original materials list.

-Pre-Startup Review Checklist (dated 5/18/16) for MOC P660-2016040006 which was for installing H-7 (heat exchanger with design modifications)

This was the long form of the PSR which includes questions about MOC and PSR administration, PSI, Equipment, Operating Procedures, MI and Maintenance Procedures, Training. There are a list of action items on the form which would need to be completed either Before startup or after.

-PSR Short form (9/26/17) for MOC 56OP2017090007

This is a temporary MOC for replacing vent control valves R-600E and R-600F, AO-521 & 522 with valves outside of the pipe spec. The pipe spec is AI96 and the replacement valves line up with spec N5. This was due to a long lead time of about 28 weeks.

-Pre-Startup Review Checklist (dated 6/27/17) for MOC P660-201704001 which was for PT36643 Alpha LOPA Capital Gap Closure (Part 2 - FTA or fault tree analysis )

This was also the long form of the PSR. There were 13 action items from the PSR that needed to be closed either Before or After startup. All 13 action items were closed between June and December of 2017.

CCHMP reviewed several short PSR forms that did not have the MOC number on them, only the dates. Per live navigation with SME, CCHMP was able to determine that



the PSRs were kept electronically in folders with the MOCs.


Does/did the stationary source confirm, as a verification check, independent of the management of change process, that prior to the introduction of regulated substances to a process that safety, operating, maintenance, and emergency procedures are in place and adequate? [T19 CCR §2760.7(b)(2) & Section 450-8.016(a)(7)(B)]

1. Sources with Program 1 or 2 covered process that are undergoing a covered process modification, as described in §2745.11, must develop procedures to manage that change and notify CCHMP that those procedures have been established (and answer the PSSR audit questions) [T19 CCR §2745.11].

CCHMP reviewed the PSRs in A17-02 and found that each contained a checklist that covered, prior to startup, equipment change, documentation, risk, common (potentially significant impact, PSR, contractor notification form), business planning, health and IH (industrial hygiene), maintenance/reliability, operations/operability, process & design engineering, process control engineering, process safety & loss prevention, product quality assurance, research, safety, technology center, City of Pittsburg, EHS procedure only, PSR review, training, and environmental. Each line has a review type name, question name, action, and comment. All of the PSRs reviewed had verification checks, independent of the MOC process, that were performed prior to the implementation of the change. This included a date and a check of safety, operating, maintenance, or emergency procedures as appropriate.

Y NoneAbr




Does/did the stationary source confirm, as a verification check, independent of the management of change process, that prior to the introduction of regulated substances to a process that training of each employee involved in operating a process has been completed? [T19 CCR §2760.7(b) (4) & Section 450-8.016(a)(7)(B)]

1. Sources with Program 1 or 2 covered process that are undergoing a covered process modification, as described in §2745.11, must develop procedures to manage that change and notify CCHMP that those procedures have been established (and answer the PSSR audit questions) [T19 CCR §2745.11].

Per review of the PSRs from A17-02 Dow files the PSR in the same folder as the original MOC. The PSR has a field for training which would be filled in as appropriate.

Per review, MOC P660-201604006 had a training folder in the online MOC tool. CCHMP did a live navigation with the SME and confirmed that the training had been conducted on 6/10/16. The training was marked as complete in the PSR document as well. The effective date of the MOC was marked as 6/11/16.

Per review, MOC P660-2018020010 had a training sheet that was marked No for training but the PSR indicated that the training had been completed. Per live navigation with the SME, the MOC folder had the PSR short form filled out but there was no training roster. This could be because the person who filled out the PSR accidentally marked Yes on the PSR form. Per interview with SME, this particular MOC would not have required training as it was just adding another material type to the list of acceptable materials for the B-105 bottoms.

CCHMP reviewed the PSRs for 10 MOCs and found that each had performed a check of training that was independent of the MOC process. The PSRs reviewed were usually a month after the MOC checks were

Y NoneAbr


Does the submitted RMP and Safety Plan accurately reflect the Pre-startup Review Program at the stationary source? [T19 CCR §2745.2(d) & Section 450-8.016]

The submitted 2014 RMP (pages 21&22) accurately reflects the Pre-Startup Review Program at the stationary source.

Y NoneAbr





* Complete the status column in theprevious CalARP/ISO audit's Summary ofAction Item table for this preventionprogram.* Identify a new action item along withperiodic written updates to CCHMP (e.g.,monthly) to complete outstanding actionitems or proposed remedies identified thatare past due.1. This question is only applicable tostationary sources that have had priorCalARP/ISO audits by CCHMP.

There were no ensure action items from the previous audit. This question does not apply.

N/A NoneAbr


A18 - CalARP Prevention Program: Compliance Audits (Program 3)



Has the stationary source certified that they evaluated compliance with the provisions of this article at least every three years to verify that the procedures and practices developed under this chapter are adequate and are being followed? [T19 CCR §2760.8(a) & Section 450-8.016(a)(8)(A)]

* Review the signed and dated auditreports.1. The start point of the three-yearcompliance audit cycle under theRMP/CalARP program has the followingeffective dates: a) June 21, 1999 forstationary sources subject to the federalRMP program; b) June 21, 2002 forstationary sources subject to the stateCalARP program, but not subject to thefederal RMP program. [T19 CCR §2745.1and CCHMP interpretation]2. The first compliance audit forstationary sources that comply with thefederal PSM standard, 29 CFR§1910.119 is required by May 26, 1995.[OSHA Instruction CPL 2-2.45A CH-1Appendix B-Clarifications andInterpretations of the PSM StandardSeptember 13, 1994]3. CalOSHA's PSM standard, T8 CCR§5189, does not specify a frequency forconducting the Injury and IllnessPrevention Program audits. However,federal PSM specifies three years.CalOSHA uses the three-year frequencyin their compliance checklist.4. Employers must certify in writing thatthere has been a PSM compliance auditat least every three years [OSHAInstruction CPL 2-2.45A CH-1 AppendixB-Clarifications and Interpretations of thePSM Standard September 13, 1994].

CCHMP reviewed 05.04.06 L1 Audits Policy and Requirements, this is an excerpt from the 05.00 Common Management System policy (Dow Corporate standard, rev. 05 Jan 09). Section B. specified that an audit schedule must be created or updated at least annually.

CCHMP reviewed Certification statements for:1) 310 and 560 block: date of audit2/12-16, 2018, (signed 3/19-20/2018by the auditor and 4/2/2018 by theproduction leaders)2) 660 block: date of audit 4/11-15,2016 (signed 4/15 and 6/30 by auditorand 12/6/2016 by production leader);date of audit 5/10/2013 (signed 5/10and 7/15 by auditor and 7/18/2013 byproduction leader)3) 640 block: date of audit 2/19-23,2018 (signed 2/23 and 3/1/2018 by theauditors and 3/1/2018 by theproduction leader); date of audit 3/23-27, 2015 (signed 4/6/2015 by auditorsand production leader)4) 520 block and site logistics: date ofaudit 5/8-12, 2017 (signed 5/18/2017by auditor and production leader); dateof audit 6/16-23, 2014 (sign 8/28/2014by auditor and 8/29/2014 byProduction Leader).

The certification statement for Block 660-2016, Block 640-2015 & 2018 andBlock 520-2014 & 2017 states theoperations were reviewed pursuant toCalARP Program CCR Title 19, Div. 2,Chapter 4.5 sec 2755.6 (a) and/or2760.8 (a) and that "to the best of ourinformation, knowledge and beliefbased on this review, the procedures

P Ensure that compliance audit clearly assess the employee participation program including the employee participation in the development (and on-going maintenance) of the prevention program elements.

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and practices required to be developed under both the PSM standard and the RMP/CalARP rule, except for those concerns identified and discussed in the audit report findings, are adequate and being followed. The correction of any concerns identified and discussed in the audit report findings shall be documented by the plant".

The 2018 certification statement for Block 310 and 560 only referred to OSHA PSM and EPA RMP rule even though CCHMP notes that the certification statement for March 2015 identified CalARP as one of the requirement that was reviewed against.

CCHMP also reviewed the topics that were assessed during the compliance review, and noted there is not sufficient assessment on employee participation. Per discussion with EH&S delivery lead, auditors may use a combination of self assessment checklist, process Safety management compliance worksheet, interviews, etc. However, per CCHMP review of the self assessment checklist for ODMS 06.06.B3 'employee participation', it asks if employees participated in Health & Safety activities. In the compliance worksheet, 5 questions were asked regarding having a written employee participation program including if the program include involvement/consultation of employees in PHA and other PSM. However, based on interview with SME, auditors are not required to use these checklists and in practice, employees do not have a mean to input to the development of prevention programs as these are developed by corporate SMEs. Employee participation is mainly assessing if there is a way to communicate safety concerns; describe employee's responsibilities to



take action when safety concernsarise; and if employee have access toPHA and other information, etc. Seeadditional discussion of audit topicsand audit report in A18-03.



A18-02 Program3 CalARP& ISO

Has the compliance audit beenconducted by at least one personknowledgeable in the process?[T19 CCR §2760.8(b) & Section450-8.016(a)(8)(B)]

* Review audit team memberqualifications.1. “Knowledgeable in the process” refersto knowledge in the covered process thathas a regulated substance.2. Audits should be led by a personknowledgeable in audit techniques andwho is impartial to the facility beingaudited. [29 CFR 1910.119 – Appendix C]3. Small plant/processes may be auditedby only one knowledgeable person (i.e., a“team” is not required). [29 CFR1910.119 – Appendix C]

CCHMP reviewed 05.04.06 L1 AuditsPolicy and it specified that an auditmust be conducted by qualifiedauditors who are independent of directresponsibility for the activities beingaudited. CCHMP also reviewed EH&Saudit L3 standard, requirement no. 6states EH&S auditors and LeadAuditors must be trained and approvedbefore performing audits or theexceptions process be followed. Thenauditors are classified as New,Experienced or Expert auditorsaccording to their auditing and subjectmatter knowledge and experience. Theaudits may be performed by thecorporate auditors or by other facilitypersonnel that have been certified tobe Dow auditor.

Per CCHMP review, each of the EHSIntegrated Audit Reports includes auditplan, team and entity. The auditors aredivided by Dow's Operating DisciplineManagement System (ODMS)sections: Common ManagementSystems, responsible care, facilitiesoperations and may also includequality system. Per interview, theprocess safety auditor is the technicalperson that has the background andprocess knowledge and generally theexpectation is that this person is aProcess Safety Technical Lead.However, this common practice is nota requirement in the policy.

Per interview with EH&S DeliveryLead, at the opening meeting, theplant being audited does give a highlevel plant overview (aselected/condensed version of RCPHA) to the entire audit team and as apart of the assessment, interviewoperations staff that is familiar with themanagement system andknowledgeable about the process.

P Ensure that the facility candemonstrate how thecompliance audit wasconducted by at least oneperson knowledgeable in theprocess.



However, CCHMP was unable tolocate any documentation ofindividuals that participated or wereinterviewed from the facility as a partof the compliance audit activity.




Does/did the stationary source document the scope, methods used, results and findings in a report that is available for AA to review? [T19 CCR §2760.8(c) & Section 450-8.016(a)(8)(C)]

* Review the compliance audit reports. CCHMP reviewed 05.04.06 L1 Audits Policy and sec. C specified that audit procedures must be established and maintained that define a) how the audit scope and frequency are determined; b) responsibilities and requirements forconducting audits; c) how results arereported and records are maintained.

Per CCHMP review of the EHS Integrated Audit reports (see dates of reports in A18-01), the reports are reviewed based on Dow's Operating Discipline Management System (ODMS) sections: Common Management Systems, responsible care, facilities operations and EH&S requirements related to business, site, plant and government.

For Block 660, Common Management System, Responsible care and Facilities Operations were reviewed. For 520, 310 and 560 Common Management System, Responsible care, Quality system and Facilities Operations were reviewed. For 640, Common management System and Responsible care were reviewed.

CCHMP reviewed the 05.00 Common Management System Level of Requirements & Performance Principles and it included these following CalARP prevention elements:-Training (05.03.01)-Procedures (05.03.04)-Management of Change (05.03.05),includes the requirement for PSR(05.03.05 A4.e) and the requirement toupdate Process Safety Information aspart of PSR.-Corrective & Preventive Actions(05.04.02)-Investigations (05.04.05)-Audits (05.04.06)

N Ensure that the compliance audit report that is available for agency to review documents the scope, methods used, results and findings.

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Responsible care included these following CalARP prevention elements:-Personal Safety (06.05):Contractor,visitor Safety, hot work, Isolation ofenergy (IOE), Line & EquipmentOpening (LEO), Confined Space Entry(CSE), Safe Work Permit (SWP)-Process Safety (06.03, 06.08): globalMechanical Integrity Manual andSafety standard, Process RiskManagement, Safety SystemImpairment-Industrial Hygiene (06.05): HazardAwareness-Crisis and emergency management(06.04 and 06.10) includes emergencyplan and emergency preparedness,crisis management plan andnotification.

Per interview with EH&S Delivery Leader who is also a certified DOW auditor, each ODMS element focal point performs audit and self assessments mostly in a 3 year frequency. For CSE, SWP,LEO, HW, IOE, these self-assessments are performed annually. The EH&S integrated auditors will also use these self assessment checklist as part of the audit. CCHMP reviewed selected blank self-assessment checklists and noted that these checklists ask questions for the auditor to look at including suggestions on sample size and reference the ODMS elements and requirements. For example the MOC checklist includes question 5 "do you identify all associated documentation for changes and ensure that they are created or updated?", question 6 "are Pre-startup Reviews completed and documented when required?" However, per interview with EH&S Delivery Leader, use of the self assessment checklist is not mandatory and varies among the experience levels of the auditors.




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Does/did the stationary source promptly determine and document an appropriate response to each of the findings of the compliance audit and complete the resolution of these findings within one and one half (1.5) years after performing the compliance audit or the next planned turnaround for items requiring a turnaround? [T19 CCR §2760.8(d) & Section 450-8.016(a)(8)(D)]

1. The timeline shall not apply to any compliance audit completed prior to January 1, 2015. [T19 CCR §2760.8(d)]2. The stationary source may enter into an agreement with the AA for an extended timetable.3. Turnaround means a planned process shutdown for the purpose of repair, maintenance, process modification, equipment upgrade, or other significant process activity [T19 CCR §2735(aaa)].

CCHMP reviewed 05.04.06 L1 Audits Policy and sec. C specified that deficiencies identified during each audit must be addressed in a timely fashion by the corrective and preventive action process.

CCHMP reviewed S-303 Corrective and Preventative Actions standard (rev. 5/17/2017). Sec 00.05 states the standard supports Dow Chemical Operating Discipline Management standard including ODMS 05.04.02 Corrective and Preventative Actions and ODMS 05.04.06 audits and external requirements including CalARP. Sec 02.02.03 specifies target dates for corrective actions from audits to be "within one and half (1.5) years of performing the compliance audit or next turnaround (if the action requires a turnaround), or a timetable approved by the CCHMP." Section 03.00 also specifies that "the Event and Action Tool (EAT) is the tool used to document corrective and preventative actions identified through incident investigations, audits, self assessments, and management system reviews.

Per the compliance audit dates of the other blocks (see details in A18-01), the resolution of the findings are not yet delinquent.

CCHMP also noted that 05.04,02 Corrective/Preventive Actions Policy, sec A.4 stated "each organization shall validate effectiveness of corrective and preventive actions." However, the policy only specified the timing to complete validation of an event to be within 6 months of completion" for facilities that claim compliance with ISO 9001, ISO/TS 16949 or other regulated product. It is CCHMP's

Y NoneAbr



position that the verification the action taken did address the deficiency is an important operating discipline. CCHMP notes that the block 660 compliance audit report was distributed in August 22, 2016 and the last action was completed 12/19/2017 for EAT 437366 but not validated as of the time of the audit. EAT 429803 for major non-conformance was validated




Does/did the stationary source document the actual completion dates when deficiencies were corrected? [T19 CCR §2760.8(d) & Section 450-8.016(a)(8)(D)]

* Review the documentation regarding tracking of changes to correct deficiencies, including how scheduled dates are changed.1. The stationary source needs to document the final resolutions taken and actual completion dates when deficiencies were corrected. [CCHMP interpretation]

CCHMP reviewed printouts from the Event and Action Tool (EAT) database for Block 640, 520, 310, 560, 660.

CCHMP noted that in some instance, the documentation did not actually document the actual completion dates when the deficiency was corrected:-Block 310: compliance audit (#6) found 1 employee that did not receive required training but the action taken and completed was the training requirement was added to the learning requirements to the individuals. -Block 560: compliance audit finding (#1) identified a gap for training requirement in Block 560. The action taken and completed in May 2018 was that training is required to complete in July 2018.-Block 520/site logistics: compliance audit (#8), the audit found MOC program to non-conformance and recommended a management system to be implemented. From site logistics the item closed on April 30, 2018, with documented action taken and completed was a management system already in place, and individually regular reviews. For Block 520, are scheduled. (this does not address management system deficiency identified). The audit finding #59 marked complete on 10/26/2017 with action taken "will work with plants to make out side drum a less than 90" (this is not CalARP). -Block 660: Compliance audit (#21) found 1 employee is two weeks overdue for HAZWOPER Level A medical surveillance at Chloropyridines and is looking for restriction on the employee and to develop a sustainable process to be notified by Health Services. The action was closed out on Dec 28, 2016 "check with the plant nurse and Spec

P Ensure that the tracking for compliance audit action closure document the actual completion date when the deficiencies were corrected.

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Chem does not currently have anyone overdue for a medical assessment." This assessment was in the wrong facility. Compliance audit (#37) was closed out on 3/1/2017 "I have been trained and will be doing my hood audit for the entire site before the end of the year". (not CalARP)


Does the stationary source retain the two most recent compliance audit reports? [T19 CCR §2760.8(e) & Section 450-8.016(a)(8)(E)]

1. The start point of the three-year compliance audit cycle under the RMP/CalARP program has the following effective dates: a) June 21, 1999 for stationary sources subject to the federal RMP program; b) June 21, 2002 for stationary sources subject to the state CalARP program, but not subject to the federal RMP program. [T19 CCR §2745.1 and CCHMP interpretation]2. The first compliance audit for stationary sources that comply with the federal PSM standard, 29 CFR §1910.119 is required by May 26, 1995. [OSHA Instruction CPL 2-2.45A CH-1 Appendix B-Clarifications and Interpretations of the PSM Standard September 13, 1994]3. Employers are required to retain the two most recent compliance audit reports, as well as the documented actions in response to audit findings. The purpose of this provision is to focus on any continuing areas of concern that are identified through the compliance audits [29 CFR 1910.119 preamble].

Per the EH&S Audit L3 Standard, section 10, specifies the retention time for the EH&S Integrated Audit reports and their associated corrective & Preventive actions to be the last two EH&S Integrated audits.

CCHMP verified online that following EH&S Integrated audit reports:1) 310 and 560 block: date of audit 5/2015, 2/12-16, 20182) 660 block: date of audit 5/10/2013, 4/11-15, 2016 3) 640 block: date of audit 3/23/2015, 2/19-23, 2018 4) 520 block and site logistics: date of audit 6/2014, 5/8-12, 2017

Y NoneAbr


Does the submitted RMP and Safety Plan accurately reflect the existing Compliance Audits Programs at the stationary source? [T19 CCR §2745.2(d) & Section 450-8.016]

CCHMP reviewed the RMP (7/14/2014), section I.D.3(g) on p. 22 that discuss the overall compliance audit program, it also stated "A senior representative from the Environmental, Health, and Safety function (EH&S) is assigned the role of audit team leader." Per review of the compliance audit report, this may or may not be the case. Update the RMP to better reflect the current practice.

Y NoneAbr






There were no action items from the previous 2015 CalARP audit of this facility.

N/A NoneAbr


A19 - CalARP Prevention Program: Incident Investigation (Program 3)



Has the stationary source investigated each incident, which resulted in, or could reasonably have resulted in a catastrophic release of a regulated substance? [T19 CCR §2760.9(a) & Section 450-8.016(a)(9)(A)]

* Review the Incident Investigation policy to ensure the ISO stationary source has a process to conduct an ISSA if the investigation recommends a “major change” that could reasonably result in a MCAR. They should have a policy that defines major change and have criteria for how site personnel would determine whether a change could reasonably result in a MCAR. Policy wording should also identify to complete ISSA as soon as administratively practicable after completion of the incident investigation report.* Review incident investigation records for the ISO stationary source for any qualifying recommendations that trigger ISS and provide records to auditor doing A34 so ISS can be evaluated.* Review how the stationary source defines a "near miss" and how and when they investigate a "near miss".1. This may include "near misses". "Near misses" are an incident that has the potential for injury and/or property damage. [Guidelines for Auditing Process Safety Management Systems - CCPS]2. The intent of an incident investigation is for employers to learn from past experiences and thus avoid repeating past mistakes [OSHA 3133].3. The CCHMP Notification Policy requests that stationary

Per interview, Dow Pittsburg facility follows the following incident investigation Pittsburg Site Safety Standards:- S-305: Accident and Incident Investigation, 5/17/17- S-304: Near Miss Reporting, 3/14/17- S-303: Corrective and Preventative Actions, 5/17/17

Per a review of Standard S-305, the Pittsburg Site complies with the Investigations policy of the Dow Chemical Company. The site follows these processes by thoroughly investigating and analyzing accidents, incidents, unplanned events, and non-conformances using established Apollo Root Cause Analysis (RCA) incident investigation methodology.

Per a review of Standard S-304, it is the expectations of the Pittsburg Site that all employees and contractors will intervene and report near misses and other unsafe conditions. Per the standard, near miss is defined as any event or action , which under slightly different circumstances, could have resulted in injury or illness to people, equipment loss, or harm to the surrounding environment. A near miss may or may not meet a Root Cause Investigation (RCI) trigger criteria.

A Process Safety near Miss (PSNM) is a process safety incident that meets one or more process safety near miss event criteria (as referenced in the Pittsburg Site RCI Trigger Criteria document). A PSNM requires an RCI and the RCIs are tracked using the event and Action Tool described in standard S-303.

CCHMP reviewed the Safety Standard titled "Common RCI Trigger Criteria (Global, Business, Site)", not dated. This criteria document consists of a large table with columns identified as: Category, Trigger Criteria, trigger Point, Trigger Source, Recommended RCI Team Leader and recommended Team Members. Categories identified include: Personal Safety & Health, Process Safety, Process safety Near Miss and Environmental. For Process Safety, Trigger Criteria includes process Safety Incident, Property damage/business interruption, reactive chemical

Y NoneAbr



sources apply a root cause methodology to Major Chemical Accident or Releases as defined by County Ordinance Code Section 450-8.014(h).4. “Catastrophic release” means a major uncontrolled emission, fire, or explosion, involving one or more regulated substances that presents an imminent and substantial endangerment to public health and the environment. [T19 CCR §2735.3(m)]

event, chemical release, failure of a layer of protection, fire or explosion, high potential process safety near miss, potential chemical release due to mechanical integrity deficiency, relief device failure or activation, safety instrumented system activation, uncontrolled mobile equipment, uncontrolled reaction, unplanned mixing, violation of process safety rules, chemical release to air, and loss of primary containment.

CCHMP reviewed the site's Standard S-303 that addresses the process for addressing corrective & preventative actions. This standard describes how the site manages the investigations, including required training, roles and responsibilities, record keeping, action item tracking, self-auditing process and associated documentation.

CCHMP reviewed the facility's incident investigation database and reviewed approximately 14 incident investigations over the last three years associated with the six CalARP covered processes. There has not been any incidents involving an actual catastrophic release. Several of the incidents reviewed could be candidates as more significant near miss releases but were not identified as incidents that could have reasonably resulted in a catastrophic release.. Examples included: -- Multiple relief device failure (#442221, 9/22&29/2016 and 1/5/2017, Block 660)-- Slight exotherm was experienced during initial dilute ammonia charge (#452295, 7/24/2017, MEI Block 640).




Was a report prepared at the conclusion of every investigation? [T19 CCR §2760.9(d) & Section 450-8.016(a)(9)(D)]

CCHMP observed a live navigation of the electronic investigation database and the printed three summary tables of incident investigations completed since the previous CCHMP November 2015 CalARP audit. The summary tables were generated from the facility incident investigation database. One summary table was for 2016 and the last month in 2015, one summary table was for 2017 and one summary table was for January through September of 2018. Each summary table consisted of several columns that included event date, plant identification, incident description, and identification of the incident as an environmental event, personal safety event and process safety event. Each incident identified had a report that was maintained in the database. CCHMP reviewed 14 incident investigation reports identified as process safety events and noted that none were a catastrophic incident or could reasonably have resulted in a catastrophic release as noted in A19-01.

Per interview with the SME, all investigations that are performed are documented in the facility's corporate electronic incident investigation database. Per interview and a review of the corporate policy titled "Global Standard for Classification and Reporting of Process Safety & Containment Events" dated November 14, 2016, the incidents that need to be reported include the following Process Safety & Containment Events (PSCE):- Level 1, Most severe Consequences: A PSCE; These may include containment loss, human impact (fatality or hospitalization of any employee or contractor), a reactive chemicals event, community impact, or a fire/explosion resulting in greater than or equal to $100,000 of direct cost.- Level 2, Less severe consequence: The consequences include containment loss, human impact (injury for an employee or a contractor) or a reactive chemical event or a fire/explosion resulting in greater than $2500 of direct cost.Level 3, Lesser severe consequence: A PSCE must be designated as Level 3 if the consequences include the following: containment loss of a chemical where the L2 threshold quantity was released within a 24 hour period but not released in any 60 minute period, known injury to the community, a process safety near miss (PSNM), a reactive chemical event that does not

Y NoneAbr



meet L1 or L2 criteria, media involvement.- Level 4, Least severe consequence: A PSCE must be designated as Level 4 if the consequences include the following: containment loss of a chemical where a smaller distinct quantity of a low hazard liquid or solid material was released, a process safety near miss (PSNM) that does not meet the L3 criteria, work interruption while evaluating the risk to workers, or events having cleanup costs of non-Dow property or media involvement.




Does the incident investigation report include a description of the incident, including all of the data required under 2750.9(b)? [T19 CCR §2760.9(d) & Section 450-8.016(a)(9)(D)]

1. §2750.9(b) is the 5-year accident history, which includes: (a) date, time, and approximate duration of the r elease, (b) regulated substance(s) released, (c) estimated quantity released in pounds, (d) type of release event and its source, (e) weather conditions if known, (f) onsite impacts, (g) known offsite impacts, (h) initiating event and contributing factors if known, (i) whether offsite responders were notified if known, (j) operational or process changes that resulted from investigation of the release [T19 CCR §2750.9(b)].

CCHMP observed a live navigation of the facility's incident investigations electronic database, reviewed the printed summary of incidents described in A19-04, and reviewed the 14 select incident investigation reports identified as process safety evens and process safety near misses. Each incident included a description of the event. Of the incident investigation reports reviewed, three were found to be most significant (identified as Level 2 described in A19-04) and they included the following:

• Event 443205 Report: Release of 149.4 lbs. of anhydrous HCl from a compressor in Block 660 on 11/27/2016. • Event 443205 Report: Release of near 16 lbs. of chlorine and HCl due to a leak from a valve near a reactor in Block 560 on 3/21/2017. • Event 454402 Report: Release of near 33 lbs. of chlorine and HCl due to a leak from a control valve near a reactor (R-600F) in Block 560 on 9/22/2017.

The CalARP regulation was updated to require any qualifying incident that occurs on or after 1/1/15 to include the information listed in the clarification for this question within the incident investigation report. In reviewing the investigative reports for these three incidents, CCHMP confirmed that the required information is included either in the primary incident investigation database report or the additional information attached to the investigation report. Dow has developed additional Pittsburg site incident reports that were completed as Pittsburg site required reports that include EH&S Incident Report and the associated Emergency Services and Security (ES&S) Log Book Report. The EH&S Site Incident Reports include specific amounts of chemicals released, time and duration of the release, what part of the released quantity was contained and what part was released to air and any quantity that was released to dirt/ground/water or to the storm sewer, and initiating event and contributing factors if known any and operational or process changes that resulted from investigation of the release. The associated Emergency Services and Security (ES&S) Log Book Report includes information on weather conditions, if there were on site or off site impacts, and whether offsite responders were notified.

Y NoneAbr




Did/does the stationary source promptly address and resolve the incident report findings and recommendations and document the resolutions no later than one and one-half (1.5) years after the completion of the incident investigation, or two (2) years after the date of the incident, whichever is the earlier of the two dates, or the next planned turnaround for those items requiring a turnaround? [T19 CCR §2760.9(e) & Section 450-8.016(a)(9)(D)]

1. OSHA developed criteria for justifiably declining recommendations formulated during incident investigations. a) The finding upon which the recommendation is based contains factual errorsb) The recommendation is not necessary to protect the health of employees or contractorsc) An alternative measure to the recommendation would provide a sufficient level of protectiond) The report recommendation is infeasible [Settlement between labor and industry (Chemical Process Safety Report - August 94)].2. Turnaround means a planned process shutdown for the purpose of repair, maintenance, process modification, equipment upgrade, or other significant process activity. [T19 CCR §2735(aaa)]

The facility promptly addresses and resolves the incident report findings and recommendations and documents the resolutions consistent with the CalARP regulations described in this question. CCHMP reviewed the action items specified in the three most severe process safety incidents described in A19-07 and noted that the action items identified have been planned for completion or have already been completed well within the required time frame of one and one-half (1.5) years after the completion of the incident investigation, or two (2) years after the date of the incident, whichever is the earlier of the two dates and none required a turnaround. The facility policy S-303 Section 02.02 specifies the requirements for timely completion of incident investigations specified in this question.

Y NoneAbr


Are incidents "tracked" in any way to identify "trends" that may lead to prevention/risk reduction?

1. "Tracking trends" is optional for stationary sources; however it would be beneficial if stationary sources implement similar "optional” activities.

Dow Pittsburg facility conducts a periodic evaluation of their EH&S related events about once a year. These evaluations include process safety events and near miss reports and personal safety near miss reports. CCHMP reviewed the facility presentation slides from the "2016 EH&S Related Events Cause Summary". The primary causes for all EH&S events were reviewed from 2014-2016 and they addressed causes for maintenance and equipment, knowledge or skills, engineering design, operating procedures, and communications. Process Blocks 310, 560 and 660 have involved the highest number of issues related to maintenance and equipment that included equipment failure, fatigue or corrosion/erosion concerns.

Y NoneAbr


Do the submitted RMP accurately reflect the existing Incident Investigation Program at the stationary source? [T19 CCR §2745.2(d) & Section 450-8.016]

The submitted RMP dated July 14, 2014, pages 23-24 accurately reflects the existing Incident Investigation Program at the stationary source.

Y NoneAbr






There was one ensure action item associated with the previous CalARP audit within this questionnaire that has been addressed.

Y NoneAbr


A20 - CalARP Prevention Program: Employee Participation (Program 3)



Has the stationary source consulted with employees and their representatives on the development of the other elements of process safety management (other than PHA's)? [T19 CCR §2760.10(b) & Section 450-8.016(a)(3)]

1. The intent of "consult" is to exchange information, solicit input and participation from the employees and their representatives. It requires more than simply informing employees. [OSHA Instruction CPL 2-2.45A CH-1 Appendix B, September 1994]2. OSHA is looking for active participation - suggestion boxes and simple policy statements by management are not enough [OSHA co-sponsored PSM workshops in Spring 1993].3. Employers must consult with contractor employees to the same extent that they consult with direct-hire employees (subject to settlement terms) - contractor employer shares responsibility for ensuring that this is done [OSHA Instruction CPL 2-2.45A CH-1 Appendix B, September 1994].

CCHMP reviewed S-504 Employee Participation Safety Standard (revised 5/17/18) and identified employee participation roles for the prevention program elements:

PSI: Employees contribute to maintaining PSI as current and accurate by reviewing PSI documentation that are available.

Procedures: Operating procedures are developed by a department's operating personnel (operating technicians and technical staff) with employees responsible for ensuring that procedures in use are current and accurate prior to use. Per interview with operations staff, procedures are being reviewed for accuracy each time a procedure is used.

Training: Operations personnel are able to contribute to the training program by soliciting information to the site Learning Organization. Additional input regarding operator training may be provided during employee development plan discussions. Per interview with operations staff, the refresher training interval was established with employee input.

Mechanical Integrity: Mechanical integrity procedures are developed, reviewed, and executed by maintenance personnel. Per interview, the vibration monitoring program was developed by the current vibration analyst.

MOC: Employees receive training on the MOC process and can act as Change Originators, Change Owners. or Subject Matter Reviewers. Affected employees are notified of and trained on changes prior to startup or interacting with the change.

PSSR: Operations personnel participate in and lead pre-startup safety reviews as part of normal operations.

P Ensure that a feedback system between personnel and site leadership is developed for the continuous improvement of the prevention program elements.

Abr



Compliance Audits: Per interview, operations employees are not expected to be part of the compliance audit team; they may be interviewed as part of the compliance audit.

Incident Investigation: Employees and contractors may report incidents and participate on the investigation (as appropriate) with the results being communicated via Learning Experience Reports (LERs) or the Event and Action Tool (corrective and preventive action tracking system).

Contractors: Contract employees may contribute safety suggestions or report any unsafe conditions through CORE Network Cards or through a department's reporting system.

PHA: Employees with knowledge specific to the process participate as part of the PHA team. Additionally, PHA results and action plans are communicated to affected employees and all employees have access to the corrective and preventive action tracking system which documents PHA results. CCHMP reviewed the RCPHAs in A12-16 and noted that all RCPHAs identified a Technical Advisor (TA) that was PSM Certified in the process being reviewed. The TA is considered a process knowledgeable person when conducting the RCPHA as they have had previous process operating experience.

Per interview with SMEs, the time that a TA is operating a process is not documented; currently there are no minimum operation requirements to be PSM Certified on a process. Although the TA may have prior operating experience, CCHMP believes that an operator with day-to-day experience in operating a process will provide the required perspective during a RCPHA. If Dow continues to rely on TAs as the primary process knowledgeable representative on the RCPHA team, CCHMP recommends developing a new certification program that specifies the number of days that a TA must work in a process unit per quarter in order to maintain the certification for that unit and that this time must be documented.



Per review of the Employee Participation policy and interviews with personnel, currently there is no feedback system that is used by hourly personnel to provide management with input for the development and continuous improvement of the various prevention program elements.


Does the submitted RMP accurately reflect the Employee Participation Program at the stationary source? [T19 CCR §2745.2(d) & Section 450-8.016)]

CCHMP reviewed Pages 24 & 25 of the submitted 2014 RMP and determined that the Employee Participation description generally reflected the program at Dow.

Y NoneAbr




One ensure action item was issued in the 2015 CalARP audit to include operators/process technicians on the RCPHA teams and has been addressed.

Y NoneAbr


A21 - CalARP Prevention Program: Contractors (Program 3)



When selecting a contractor, does the stationary source obtain and evaluate information regarding the contract owner or operator's safety performance and programs? [T19 CCR §2760.12(b)(1) & Section 450-8.016(a)(11)]

1. This section applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. It does not apply to contractors providing the incidental services which do not influence process safety such as janitorial work, food and drink services, laundry, delivery or other supply services. [§2760.12(a)].2. Employers who use contractors to perform work in and around covered processes have to establish a screening process so that they hire and use only contractors who accomplish the desired job tasks without compromising the safety and health of any employees at a facility [OSHA 3133].

Per interview with the contractor program SME, the facility has about 150 domestic contractor employees which are here most of the times. For turn around or projects, there would be an additional 50 to 100 contractor employees making up the total number of 200-250 contractor employees on site as a maximum range.

Dow has a contractor prequalification process and ISNetworld is a tool to facilitate the contractor prequalification process. There are about 12 contractor companies that the facility works with 90% of the time and uses their employees to accomplish the projects or turn arounds. Dow may also work with specialized contractors for the remaining 10% of the work conducted by the contractors. The list of contractors that the facility may deal with is larger and is as much as 150 of which about 12 are mostly involved and remaining will be used for select specialty work.

Dow chose ISNetworld for prequalification of contractors around five years ago for this facility. They are now used for prequalification of all contractors. The information maintained by ISNetworld includes the following: - Last 3 years of OSHA 300 logs - documents any recordable injuries and the number of hours worked. A threshold number of 2.0 is used for recordable injury rates at Pittsburg Dow site.- Prequalification questionnaires - Written program reviews that include the required safety program, such as CalOSHA injury protection, fall protection, hazard communications programs, and specialty areas like confined space entry or catalyst replacement activity

Y NoneAbr



- OSHA current injury rate- Any previous citations from OSHA or EPA in particular if the facility has had fatalities or major incidents in the past three years.

CCHMP also reviewed the following two procedures related to contractor prequalification, selection and access standards:- Non-Dow Services on Dow Property, revised 5/30/2012 (Corporate Standard)- S-502, Pittsburg Site Access Standard, revised 2/1/2018 (Site Standard)

The corporate standard describes the requirements for contractor prequalification and selection. The site standard describes the minimum requirements for contractor prequalification which is normally via ISNetworld and obtaining access for any non-Dow service including all services provided by contractors.




Does/did the stationary source periodically evaluate and document the evaluation of the performance of the contract owner or operator in fulfilling their obligations as specified in T19 CCR §2760.12(c)? [T19 CCR §2760.12(b)(5) & Section 450-8.016(a)(11)]

1. The employer must ensure through periodic evaluations, that the training provided to contractor employees by the contract employer is equivalent to the training required for direct hire employees [OSHA Instruction CPL 2-2.45A CH-1 Appendix A, September 1994].2. Employers must periodically audit contractor's performance in the field. A records review alone is not acceptable [OSHA Region VI presentations on PSM in January, 1994].

Per interview, Behavior Based Performance (BBP) evaluation is conducted for the contractors that have been on site in the past calendar year. This consists of observing contractor work in the field by any of Dow employees. Many Dow employees periodically conduct BBP evaluation/observation of contractors working in their areas. The observations are then documented in a BBP database by company name and date of observation and identification of the observer. One way that the contractor evaluation is conducted is to review the data on these observations by the SME responsible for contractor program.

Per a live navigation review of BBP database, there were 230 BBP evaluation/observations logged for the largest contractor on site for their activities by the Dow site personnel. On average, the percentage of unacceptable behavior observed was about between 20 and 35 percent. The results of BBPs are shared with the contractors on a quarterly basis by the contractor program SME. The SME provides a written report to the contractor and the report includes a text of each observation performed as well as any behavioral trend that needs attention. The SME covers this analysis for about 10 to 12 contractor companies via providing them a written report and possibly a follow-up visit to address most significant issues.

CCHMP reviewed two example BBP reports that were prepared by the SME and submitted to the contractor involved. The reports included the dates and observations that had been documented for the contractor and highlighting some that were identified as unacceptable behavior. The target to be maintained for number of unacceptable behavior is below 20 percent. The report typically includes a

Y NoneAbr



bar chart illustrating the percent unacceptable behavior for each of the past six quarters and total number of observations.




Does/did the contract owner or operator assure that each contract employee is trained in the work practices necessary to safely perform his or her job? [T19 CCR §2760.12(c)(1) & Section 450-8.016(a)(11)]

* Review contractor training records to determine whether there is documentation that contract employees have been trained in the work practices necessary to perform their jobs safely. [CalOSHA Consultation, Guidelines for Process Safety Management, Part 1, June 1994].1. The facility should be knowledgeable in how the contract owner trains contract employees. [CCHMP Interpretation]2. The facility should request/review documentation from the contract owner to ensure that only properly trained contractors work on or near covered processes. Stationary sources do not have to maintain the actual training records on site, but should maintain at least a record of the review process. [CCHMP Interpretation]3. For NAICS codes: 324110 or 325110: For contracts awarded, extended or renewed as of January 1, 2014, at least 30 percent of the skilled journeypersons are graduates of an apprenticeship program for the applicable occupation that was either approved by the chief pursuant to Section 3075 of the Labor Code or located outside California and approved for federal purposes pursuant to the apprenticeship regulations adopted by the federal Secretary of Labor. As of January 1, 2015, at least 45 percent, and as of January 1, 2016, at least 60 percent. [SB54_Section 25536.7, SEC 2 (b)]

The contractor program SME conducts training audits of the contractors employees. These audits are targeted to contractor companies working in the covered processes such as contractors involved with mechanical repairs, insulation, painting, excavation, welding, water blasting, sand blasting, etc. Training audits are performed by the Dow SME by going to the contractor's office if local or remotely via web conferences. Typically the audit includes a review of the contractor Injury & Illness Prevention Program (IIPP), a review of experience in several key areas that the contractor works in and assessing quality of the training and training documentation to confirm that the required training has been done. SME maintains a copy of the training documentation for the individual training records reviewed in addition to an audit report that is completed for the audit per a preset template. These audits include a review of the critical core skills for select members of the contractor employees involved at the plant.

CCHMP reviewed the site procedures titled; "F4605, F4613 and F4614 Contractor Training Audit Procedure" dated 4/6/18 and "F4605, F4613 and F4614 Pittsburg Site Contractor Training Audit Program Schedule", not dated. Per a review of these procedures, the facility conducts training audits to verify that the contractor employees are receiving the appropriate training to safely perform their job. Per interview with the SME, the contractors that are working or may work on or near the covered process consist of four tiers as follows:

- Tier 1 Contractors: These contractors work onsite and in the covered process most of their time (about 90% of their time). These include contractors doing welding, grinding, pipe fitting, etc. There

Y NoneAbr



are currently 12 contractor companies in this category with about 150 contract employees.- Tier 2 Contractors: These contractors work onsite and in the covered process a few months of the year. There are currently 12 contractors in this category with about 50 contract employees.- Tier 3 Contractors: These contractors are here occasionally, may be a few weeks a year. There are currently about 5 contractors that are categorized in this tier.- Tier 4 Contractors: These are the contractors that may work here in the covered process for specific tasks. There are currently about 120 contractors in this tier.

CCHMP reviewed the Contractor Training Audit Procedure and as confirmed by interview, the procedure only provides a limited definition of the four contractor tiers and it should be updated consistent with SME interview definitions provided above and the latest improvements on these definitions.

Per interview with the SME, the facility audits contractors according to the following schedule:- Tier 1 Contractor: Every 3 years (12 contractors audited, once every quarter)- Tier 2 Contractors: Every 4 years (12 contractors audited, once every 4 months)- Tier 3 Contractors: Every 5 years (5 contractors audited, once every year)- Tier 4 contractors: Only audited when chosen to work onsite before coming on site to work.

CCHMP requested an operator for a Pittsburg "site" safety indoctrination for a contractor and the operator checked the electronic data available at the Block control room that showed the update was not done. However, a follow-up review by EH&S Department indicated that the contractor had actually completed the



annually updated Pittsburg site indoctrination that is conducted at OSCA, an outside training facility. CCHMP recommends that the site limits access to site indoctrination information which is based on OSCA evergreen electronic copy used for confirmation of the annual site indoctrinations.

When conducting operations interviews, CCHMP requested an operator for checking a contractor for having the Block indoctrination and noted that the hard copy of the list that was available was not up to date. CCHMP also recommends that hard copies of the Block specific training indoctrination for contractors are not used to verify the Block specific indoctrination updates. Dow personnel should only use the ever green electronic copy.

CCHMP reviewed five contractor training audit reports that were completed in the past six quarters since the updated contractor program has been in place. The training audit were all documented in a report and included several sections including the following:- Pittsburg site contractor training audit checklist- Contractor Audit Report- Contractor Safety Programs- Jobsite Safety Analysis (JSAs)- Training summaries and samples of tests conducted on training related to the work the contractor conducts at Dow.


Does the submitted RMP and Safety Plan accurately reflect the Contractors Program at the stationary source? [T19 CCR §2745.2(d) & Section 450-8.016]

The submitted RMP dated July 14, 2014 pages 25-27 accurately reflects the Contractors Program at the stationary source.

Y NoneAbr






There was one ensure action item associated with the previous CalARP audit that has been addressed.

Y NoneAbr


A22 - CalARP Emergency Response Program (Programs 1,2,3)


A22-01 Non Responding - Programs 1,2,3 CalARP & ISO

If the stationary source elects not to respond to accidental releases of regulated substances, have they developed and implemented an Emergency Action Plan as specified in T8 CCR §3220? [T8 CCR §5192(q)(1) & Section 450-8.016(a)(12)(D)]

* Verify the facility has an Emergency Action Plan. 1. Stationary sources are not required to respond to an accidental release of regulated substances.2. Stationary sources who will evacuate their employees from the danger area when an emergency occurs, and who do not permit any of their employees to assist in handling the emergency, are exempt from the requirements of developing and implementing an emergency response plan and other emergency response requirements identified within T8 CCR §5192(q) if they provide an emergency action plan (EAP) in accordance with T8 CCR §3220. The EAP includes (but is not limited to) escape routes, procedures for critical plant operations, head counting procedures, emergency reporting, alarm system, types of evacuations, and training.3. The EAP must be written, kept at the workplace, and made available for employee review.4. For those employers with 10 or fewer employees, a written EAP is not required, but the plan needs to be communicated orally to employees.

The facility responds to accidental releases of regulated substances, therefore this question is not applicable.

N/A NoneAbr




If the stationary source (with regulated flammable and/or regulated toxic substances) elects not to respond to accidental releases of regulated substances, has the stationary source documented that response actions have been coordinated with the local fire department and hazardous materials response agencies? [T19 CCR §2765.1(b)(1), §2765.1(b)(2) & Section 450-8.016(a)(12)(D)]

1. Stationary sources are not required to respond to an accidental release of regulated substances.2. Typically response actions for toxic regulated substances are coordinated with the CCHMP HazMat Team, the San Ramon Valley Fire Protection District in that area, Contra Costa Fire District, and if in Richmond, the Richmond Fire Department.

As described in A22-01, the facility responds to accidental releases of regulated substances, therefore this question is not applicable.

N/A NoneAbr


If the stationary source elects not to respond to accidental releases of regulated substances, are appropriate mechanisms and written procedures in place to notify emergency responders when there is a need for a response? [T19 CCR §2765.1(b)(3) & Section 450-8.016(a)(12)(D)]

* Verify the EAP contains procedures sufficient to address when and how to notify emergency responders.1. Stationary sources are not required to respond to an accidental release of regulated substances.2. The Emergency Action Plan (EAP) must identify the means of reporting accidental releases of regulated substances and other emergencies.

As described in A22-01, the facility responds to accidental releases of regulated substances, therefore this question is not applicable.

N/A NoneAbr



A22-07 Responding - Programs 1,2,3 CalARP & ISO

Does the emergency response plan include procedures for informing and interfacing with the public and local emergency response agencies about accidental releases, emergency planning, and emergency responses? [T19 CCR §2765.2(a)(1)(A) & Section 450-8.016(a)(12)(A)]

1. Stationary sources in California that respond to an accidental release of regulated substances must have an emergency response program consistent with T19 CCR §2765.2 and T8 CCR §5192.2. This requirement partially corresponds to T8 CCR §5192(q)(2)(A) and §5192(q)(2)(I).

The facility developed the Consolidated Contingency Plan (rev. May 2018) which outlines the facility's Emergency Response Plan. This plan is available to responders via the California Environmental Reporting System (CERS). The facility has an onsite terminal that can activate Contra Costa County Community Warning System to send out alerts to outside agencies and the community. This system alerts emergency responders and can send e-mail and/or text message alerts to those who opted to be notified.

The facility trains and plans with local emergency response agencies. The facility conducts an annual CAER Community drill, which includes participation from CCHMP, Pittsburg Police Department, Contra Costa County Fire Department, EPA, Bay Area Air Quality Management District, DTSC, and community hospitals. Past drill scenarios included mock release of chlorine with participants trained on coordinating response activities and managing the public safety.

Additionally, CCHMP performs an unannounced inspection to drill on the emergency response program.

The facility also participates in other events offsite with other emergency responders including the TransCAER Chlorine and the Continuing Challenge.

Y NoneAbr




Does the emergency response program include procedures for the use of emergency response equipment and for its inspection, testing, and maintenance? [T19 CCR §2765.2(a)(2) & Section 450-8.016(a)(12)(A)]

*Review record of the annual flow test SCBA-face pieces/regulator (by NFPA/manufacturer recommendation), 5-year hydrotesting on SCBA tanks (w/ stamp)1. Stationary sources in California that respond to an accidental release of regulated substances must have an emergency response program consistent with T19 CCR §2765.2 and T8 CCR §5192.2. This requirement partially corresponds to T8 CCR §5192(q)(2)(K) and §5192(g).3. This includes fire water piping systems and hydrants, fire water pumps and drivers, fire trucks, SCBA, fire extinguishers, etc. [CCHMP Interpretation]4. Annual SCBA facepiece flow test per NFPA 1981, Standard on Open-Circuit Self-Contained Breathing Apparatus (SCBA) for Emergency Services.

CCHMP reviewed policy on "Impairment Inspection, Testing and Maintenance of Fire Protection Systems (ODMS 06.03.B.10.06 / LPP 10.16 (Aug 2016)", which outlines the fire protection system, mandatory requirements, recommended requirements, and inspection table. The inspection schedule and scope is aligned to meet NFPA recommendations.

Per interview with SME, the facility contracts their fire system and safety system inspections to a third party contractor. CCHMP reviewed the annual inspection reports from 2016, 2017, and 2018.

All personnel that are part of the fire brigade are responsible for completing a proficiency "C-kit" training, which is a device used to capping railcar chlorine leaks. CCHMP reviewed the "Learning History" database and confirmed that employs received the training.

The facility has developed a site specific document "S-203 Emergency Preparedness and Response" (dated 2/12/18) which applies to all elements of emergency preparedness and response activities that occur at the Pittsburg site. The policy establishes the roles and responsibilities for all individuals.

Y NoneAbr




Does the emergency response program include training for all employees in relevant procedures and relevant aspects of the Incident Command System? [T19 CCR §2765.2(a)(3) & Section 450-8.016(a)(12)(A)]

1. Stationary sources in California that respond to an accidental release of regulated substances must have an emergency response program consistent with T19 CCR §2765.2 and T8 CCR §5192.2. This requirement corresponds to T8 CCR §5192(q)(6), (7), and (8).

All onsite employees receive introductory Incident Command System (ICS) training as part of their mandatory "Emergency Preparedness and Response Training. CCHMP reviewed the training slides and confirmed they discuss the Incident Command System (ICS). In addition, all Emergency Services and Security (ESS) Personnel and Operations Personnel, approximately 50 employees in total, completed FEMA training on "Introduction to the Incident Command System, ICS 100". The ESS Personnel complete "Industrial Fire Brigade Training" annually and Operations personnel (fire fighters) complete the same training every two years.

The facility performs sitewide training on Emergency Preparedness and Response Training. CCHMP requested the training verification for the last year and confirmed employees had completed training.

Y NoneAbr


Does the emergency response program include procedures to review and update, as appropriate, the emergency response plan to reflect changes at the stationary source and ensure that employees are informed of changes? [T19 CCR §2765.2(a)(4) & Section 450-8.016(a)(12)(A)]

1. Stationary sources in California that respond to an accidental release of regulated substances must have an emergency response program consistent with T19 CCR §2765.2 and T8 CCR §5192.2. Stationary sources need to have a program to periodically review and update their emergency response program. Relying on using the MOC process to make changes may not satisfy this requirement since the MOC process covers only what is being changed. The MOC process may not result in a complete or very frequent review of the response plan. [CCHMP Interpretation]

The facility has developed a site specific policy "Pittsburg Site Emergency- Contingency Plan Annual Review and Revision Procedure and Checklist. The procedure outlines the procedural steps for updating the Contingency Plan, distribution of the new information, the timing of reviews, and the management of controlled copies. CCHMP completed a three year look back at the Contingency Plans revision history and confirmed updates were completed on 5/5/16, 8/30/17, 1/31/18 and 4/26/18. As a further note CCHMP confirmed that the Contingency Plans have been uploaded to the CERS database. The facility uses the MOC process to manage document changes, including training and verification.

Y NoneAbr



A22-15 Programs 1,2,3 CalARP & ISO

Does the submitted RMP and Safety Plan accurately reflect the Emergency Response Program at the stationary source? [T19 CCR §2745.2(d) & Section 450-8.016]

Section I.F, p.27-29, of the RMP (dated July 2014 CalARP Resubmittal - NOD Revisions) accurately reflects the Emergency Response Program.

Y NoneAbr




There were no ensure action items associated with the previous CalARP audit for this regulatory topic, therefore this question is not applicable.

N/A NoneAbr


S01NR - Hot Work Permit (Program 3)


S01-02 Hot Work Program

Has management designated an individual responsible for authorizing cutting and welding operations in areas not specifically designed or approved for such processes? [T8 CCR §4848(a) via ANSI/ASC Z49.1-94, 3.2.1.3] Does the facility ensure that before welding or cutting is begun, inspection and authorization by a designated management representative is required? [T8 CCR §4848(a) via ANSI/ASC Z49.1-94, 6.3 and 3.2.2.3]

1. Secure the authorization for the cutting or welding operations from the designated management representative [T8 CCR 4848(a) via ANSI/ASC Z49.1-94, 3.2.2.3]2. Before hot work operations begin in a nondesignated location, a written hot work permit by the permit-authorizing individual shall be required. [T8 CCR §4848(a) via NFPA 51B 3-3.1]3. For facilities subject to PSM requirements, management must require that a supervisor or contractor supervisor is responsible for ensuring that cutting and welding are so scheduled that plant operations that might expose combustibles to ignition are not started during cutting or welding. [29 CFR §1910.252(a)(xiv)]4. The permit shall certify that the applicable portions of the fire prevention and protection requirements contained in Sections 4848 have been implemented prior to beginning the hot work operations. [T8 CCR 5189(k)]

The High Energy Hot Work Permit Item 9 requires higher level of approval for "High Energy Hot Work in a Flammable Area Requires Approval from Authorized Approver/Signature". Normally a member of operations is a permit issuer and is the authorizing individual and the high energy flammable area would require a Tech Advisor or Operations Leader or Production Leader approval. This requirement is also specified on page 6 of the Corporate standard: EH&S Global Hot Work Standard 06.05.09 (revised September 27, 2013), under the section titled "Person Providing Secondary Approval".

Y NoneAbr




Does the facility ensure that no welding or cutting is done unless the atmosphere is non-flammable and unless combustibles are moved away or protected from fire hazards? [T8 CCR 4848(a) via ANSI/ASC Z49.1-94, 6.1.1]

1. Management shall assure that hazards and safety precautions are communicated to workers prior to the start or work. [T8 CCR §4848(a) via ANSI/ASC Z49.1-94, 3.2.1.2]2. The permit shall certify that the applicable portions of the fire prevention and protection requirements contained in Sections 4848 have been implemented prior to beginning the hot work operations. [T8 CCR 5189(k)]3. Per discussion with CalOSHA (Dec 07), a hot work program that incorporates all the provisions of Sections 4848 and 6777 including training of personnel, on-the-job hazard identification and signature on the permit constitutes "certification".4. Document that safety precautions were met on the permit, and/or must be met within the hot work policy. If only stated in the policy, the stationary source should document on the permit that the policy was followed. [CCHMP Interpretation]

Per interview with the SME, about 6-8 hot work permits are issued sitewide per week on an average. During T/A, 6-8 hot work permits per day may be required. In a general basis, Process Block 660 has the majority of hot work permits.

CCHMP reviewed the EH&S Global Hot Work Standard 06.05.09, revised September 27, 2013. The requirements of this standard are in place to ensure the proper precautions are taken to prevent adverse impact in environments in which hot work is to be performed. Per this standard and interview, the authorized trained individuals are to issue safe work permits for hot work in flammable areas and high energy hot work. Secondary approval needs to be provided for safe work permits for high energy hot work in flammable areas. A hot work permit is a separate one page checklist form that is attached to the safe work permit.

Sections 2 through 6 of hot work permit specifies procedures to address questions such as hot work area classification, type of hot work, equipment status, and flammable atmosphere monitoring. Operators will bring along and use a flammable detection device to check the flammability of the area where hot work is planned to be used. Hot work is conducted periodically inside the process area and is used frequently during turn around. A zero LEL is required for any hot work conducted. Oxygen is required to be about 21%. The hot work permit requires documenting the permit issuer name, the date and %Oxygen and %LEL. If possible, the equipment is moved to a site fabrication shop which is a safer area away from the unit.

CCHMP reviewed 25 completed Safe Work/Hot Work permits from different parts of the plant including Block 660, Block 310 and Block 640 (MEI). This review confirmed that a Safe Work Permit was prepared for each hot work permit that was issued and the permits included the required authorization by operations, completion of the required sections of the permits, general area

Y NoneAbr



required permits and a description of the hot work, provision of a fire watch for high energy hot work, flammable atmospheric monitoring as required, PPE requirements and closeout signature indicating that the permit is no longer active and all work under the permit has stopped.

CCHMP also observed a hot work conducted at AFTF plant in the process Block 310. The hot work observed was conducted by an experienced welder that was with the site for more than 10 years and familiar with all of the permit requirements in the filed. The required Safe Work and Hot Work permits were available at the site and the CCHMP observed that the operations representatives and the welder observed the appropriate precautions.



S01-06 Hot Work Permit

Before a hot work permit is issued, does the permit authorizing individual verify that fully charged and operable fire extinguishers that are appropriate for the type of possible fire shall be available immediately at the work area? [T8 CCR §4848((a) via NFPA 51B 3-3.2(j)]

1. For facilities subject to OSHA PSM: fire extinguishing equipment shall be ready for instant use [29 CFR §1910.252(a)(2)(ii)]2. Is sufficient fire extinguishing equipment ready for use where welding and cutting work is being done; does management assure that proper personal protective and fire protection equipment is used; and assure that fire protection and fire extinguishing equipment are properly located at the site? [T8 CCR §4848((a) via ANSI/ASC Z49.1-94, 6.2.1.1 and 3.2.2.4]3. For facilities not subject to OSHA PSM, existing hose lines located within the hot work area defined by the permit are to be connected and ready for service, without being unrolled or charged. [T8 CCR §4848((a) via NFPA 51B 3-3.2(j)]4. These requirements should also be stated in a policy/procedure. [CCHMP Interpretation]

Per interview, the fire watch is responsible for bringing a fully charged and operable fire extinguisher to the hot work area. Fire extinguishers are monitored, checked and verified to be operable by a third party contractor on site. The verification is conducted periodically as needed. Area inspection by the permit authorizing individual and the fire watch is a specified requirement for high energy hot work before hot work is authorized.

Per a review of a site procedure titled "Fire Watch Checklist" dated 3/17/16, fire extinguishers must be provided by the workers/contractor. Per a review of the Global Safe Work Permit standard, 06.05.C revised January 13, 2016, Safe Work Permit requires documentation of many items including: "A place to indicate that specific emergency procedures and alarms, locations of assembly points and evacuation routes and the locations of emergency equipment including nearest safety showers, eye wash, fire extinguisher and telephone and/or intercom have all been reviewed and understood." However, neither the Safe Work permit nor the Hot Work Permit provide verification check confirming that the fully charged and operable fire extinguishers that are appropriate for the type of possible fire are available immediately at the work area. The related hot work procedures also need to be updated to include completion of this verification by permit issuer.

P Ensure to update the site hot work permit to include a verification check to confirm that fully charged and operable fire extinguishers that are appropriate for the type of possible fire are available immediately at the work area.

Ensure to update the site hot work procedures to include completion of this verification by permit issuer.

Abr




Does the facility ensure that where practical, the work is moved to a designated safe location? [T8 CCR §4848(a) via ANSI/ASC Z49.1-94, 6.1.2] Does the facility ensure that if the object to be welded or cut cannot readily be moved, all movable fire hazards in the vicinity are taken to a safe location? [T8 CCR §4848(a) and ANSI/ASC Z49.1-94,

1. Check that where objects to be welded or cut are not movable and where fire hazards cannot be removed, guards are used to confine the heat, sparks, and slag, and to protect the immovable fire hazards and nearby personnel [T8 CCR §4848(a) via NFPA 51B 3-3.2(l) and ANSI/ASC Z49.1-94, 6.1.4] 2. The requirement for first assessing whether the object to be welded or cut could be moved to an approved hot work area to perform the work should be in a hot work policy/procedure [CCHMP Interpretation] 3. Additional precautions should be taken if combustible metals are in the area or will be the focus of the hot work. This includes equipment or piping constructed of magnesium, titanium, or zirconium. Examples include welding or cutting on titanium heat exchangers. [CCHMP Interpretation]4. Document that safety precautions were met on the permit, and/or must be met within the hot work policy. If only stated in the policy, the stationary source should document on the permit that the policy was followed. [CCHS Interpretation] 5. Supervisors shall ensure that materials are not exposed to ignition by taking one or more of the following actions: have the work moved to a location free from combustibles and away from hazardous areas; have the combustibles moved a safe distance from the work or properly shielded against ignition if the work cannot readily be moved; or schedule welding and cutting so that such materials are not exposed during welding and cutting operations. [T8 CCR §4848(a) and ANSI/ASC Z49.1-94, 3.2.2.2]

Per interview, it is a practice for the facility to ensure that where practical, the work is moved to a designated safe location. Fabrication Shop that is a part of maintenance operation, is the preferred location for conducting hot work. The Hot Work corporate standard Page 4 specified that "Relocate any flammable or combustible materials where practical, outside the flammable or general area and away from the hot work."

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Does the permit authorizing individual require a fire watch be posted and ensure precautions are taken to prevent ignition of combustibles when performing hot work: (a) in a location where other than a minor fire might develop; (b) when combustible materials in building construction or contents are closer than 35 feet to the point of operation; (c) when combustible materials are more than 35 feet away but are easily ignited by sparks; (d) when wall or floor openings within a 35 feet radius expose combustible materials in adjacent areas, including concealed spaces in walls or floors; or (e) when combustible materials are adjacent to the opposite side of partitions, walls, ceilings, or roofs and are likely to be ignited (by conduction or radiation)? [T8 CCR §4848(a) via NFPA 51B 3-4.1 & 3-3.2(g)], ANSI/ASC Z49.1-94, 3.2.2.4, and 6.2.2]

1. Additional firewatchers shall be posted where it is necessary to observe areas that are hidden from the view of a single firewatcher (e.g., other side of partitions, walls, ceilings, etc.) if combustible materials could be ignited. [T8 CCR 4848(a) via NFPA 51B 3-4.3 and ANSI/ASC Z49.1-94, 6.2.3]2. Welding shall not be attempted on a metal partition, wall, ceiling or roof having a combustible covering nor on walls or partitions of combustible sandwich-type panel construction [T8 CCR §4848(a) via NFPA 51B 3-3.2(h)] 3. Cutting or welding on pipes or other metal in contact with combustible walls, partitions, ceilings, or roofs shall not be undertaken if the work is close enough to cause ignition by conduction [T8 CCR §4848(a) via NFPA 51B 3-3.2(i)] This includes ignition by convection, conduction and radiation. This includes hot taps [CCHMP Interpretation] 4. If hot work is done near walls, partitions, ceilings, or roofs of combustible construction, fire-retardant shields or guards shall be provided to prevent ignition. [T8 CCR §4848(a) via NFPA 51B 3-3.2(f)]5. Document that safety precautions were met on the permit, and/or must be met within the hot work policy. If only stated in the policy, the stationary source should document that the policy was followed. [CCHMP Interpretation]

Per a review of the Global Hot Work Standard, a fire watch must be present during all High Energy Hot Work in Flammable or General areas when:- There are flammables or combustibles within the affected area of the hot work.- There are flammables or combustibles that could be easily ignited regardless of distance.

Per interview, each process block has area maps that highlight the flammable areas and the general areas (no flammables) for the block and these area maps are identified as Hot Work Maps. CCHMP reviewed the hot work maps for all covered process areas including Block 660, Block 310, Block 640 (MEI) and Block 560. The area hot work maps are reviewed to address and confirm the requirements specified in this question.

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Has the stationary source ensured that the fire watch is maintained for at least ½ hour after the completion of the hot work operation to detect and extinguish smoldering fires; and that fire watchers are qualified individuals, knowledgeable about fire reporting procedures, and emergency rescue procedures, who are assigned duties to detect and prevent spread of fires? [T8 CCR §4848(a) via NFPA 51B 3-4.2 and ANSI/ASC Z49.1-94, 6.2.2 and 6.2.4]

1. Verification of fire watch qualifications may be from training documentation, or listing the requirements on the back of the permit. [CCHMP interpretation]2. Fire watch shall be trained in the use of fire extinguishing equipment, familiar with facilities for sounding an alarm in the event of a fire, watch for fires in all exposed areas, try to extinguish them only when obviously within the capacity of the equipment available, or otherwise sound the alarm. [T8 CCR §4848(a) via ANSI/ASC Z49.1-94, 6.2.4]3. Document that safety precautions were met on the permit, and/or must be met within the hot work policy. If only stated in the policy, the stationary source should document on the permit that the policy was followed. [CCHMP Interpretation]

Per the Corporate Standard Page 7 and interview during the hot work observed in Block 310, the fire watch is maintained for at least 30 minutes after the completion of the hot work operation to detect and extinguish smoldering fires. Fire watch is knowledgeable to shut down the hot work equipment, alert the person doing the hot work and initiate the proper response for the situation in the event of an injury, fire, gas release or other emergency.

Y NoneAbr


Are all welding and cutting equipment inspected as required to assure it is in safe operating condition? When equipment is found to be incapable of reliable safe operation, is the equipment repaired by qualified personnel prior to its next use or withdrawn from service? [T8 CCR §4848(a) via ANSI/ASC Z49.1-94, 3.1.1]

Per interview and a field observation of a hot work in Block 310, all equipment are inspected by the welder before use. If any deficiency is observed in the welding equipment, the welder will immediately stop work and request for correction of the deficiency before hot work can begin or continue. Two of the on site contractors provide the welders that may be required for a hot work job.

Y NoneAbr


Does the facility ensure that the area is inspected by the permit-authorizing individual at least once per day while the hot work permit is in effect to ensure that it is in a fire-safe area? [T8 CCR §4848(a) via NFPA 51B 3-3.4]

1. The permit-authorizing individual shall determine the length of the period for which the hot work permit is valid. [T8 CCR §4848(a) via NFPA 51B 3-3.3]2. Document that safety precautions were met on the permit, and/or must be met within the hot work policy. If only stated in the policy, the stationary source should document on the permit that the policy was followed. [CCHMP Interpretation]

Per interview and a review of the hot work standard, a trained process area operator is normally the authorizing hot work permit individual. Each permit has a 12 hour life to it and as each shift is 12 hours, the permit may be extended to the second shift if it starts in the middle of the first shift. Per interview, the area is inspected by the permit-authorizing individual at least once per day while the hot work permit is in effect.

Y NoneAbr




Does the submitted RMP accurately reflect the Hot Work Permit Program at the stationary source? [T19 CCR §2745.2(d)]

The submitted RMP dated July 14, 2014 page 25 accurately reflects the Hot Work Permit Program at the stationary source.

Y NoneAbr

S01-20 Audit Follow-Up


1. This question is only applicable to stationary sources that have had prior CalARP/ISO audits by CCHMP.2. Prior CCHMP audits may have designated action items for non-refineries based on requirements identified within T8 CCR §6777. Since T8 CCR §6777 is specific to petroleum industries, CCHS should review previous action items to see if a change to "consider" action is warranted.* Complete the status column in the previous CalARP/ISO audit's Summary of Action Item table for this prevention program.* Identify a new action item along with periodic written updates to CCHS (e.g., monthly) to complete outstanding action items or proposed remedies identified that are past due.

There were no ensure action items associated with the previous CalARP audit to be addressed here. This question is not applicable.

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S03c - Lockout/Tagout (Program 3)


S03-08 Hazardous Energy Control Procedure

Does/did the stationary source develop and use a written energy control procedure, which clearly and specifically outlines the following:a) The scope, purpose, authorization, rules, and techniques to be used for the control of hazardous energy; b) The means to enforce compliance including, but not limited to a statement of the intended use of the procedure; c) The means to enforce compliance including, but not limited to the procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy; andd) The means to enforce compliance including, but not limited to the procedural steps for the placement, removal, and transfer of lockout devices and tagout devices and the responsibility for them? [T19 CCR §2760.3(d)] [T8 CCR §3314(g)]

1. The energy control procedure applies when employees are engaged in the cleaning, repairing, servicing or adjusting of prime movers, machinery, and equipment [T8 CCR §3314(g)]2. Energy source is any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy [OSHA §1910.147(b)]

CCHMP reviewed the EH&S Isolation of Energy Sources Standard (LOTO policy; revised 4/12/16) which outlines the requirements for isolating equipment. The policy addresses the development of isolation procedures and the responsibilities of personnel that are involved with the isolation (e.g., maintenance personnel servicing equipment, operations personnel responsible for isolation). Operations personnel are responsible for the development of energy control procedures which identify the isolation points and devices required to safely isolate part of a process. The Red Tag Master (RTM) system employed requires isolation points to be tagged and/or locked.

Additional documentation used by the RTM system includes identification of personnel involved with the isolation process identified on the unique RTM documentation (RTM form) developed for the isolation job. The documentation identifies the equipment to be placed out of operation, the total number of red tags used for the isolation, and the reason for the isolation or work being conducted; a sign-off to identify ownership of the isolation job by the Facility Representative and verification of the placement of Red Tags identified by the Location Listing was completed by the Job Representative is included on the form. Tag removal and completion of the work that required isolation is also recorded on the RTM form.

Per interview, placement of additional locking devices by contractors is allowed and must be recorded on the RTM Location Listing.

Y NoneAbr



S03-09 Hazardous Energy Control Procedure

Does the energy control procedure clearly and specifically outline the means to enforce compliance including, but not limited to the requirements for testing a machine or equipment, to determine and verify the effectiveness of lockout devices, tagout devices and other energy control devices? [T19 CCR §2760.3(d)] [T8 CCR §3314(g)]

1. The energy control procedure applies when employees are engaged in the cleaning, repairing, servicing or adjusting of prime movers, machinery, and equipment [T8 CCR §3314(g)]2. Energy source is any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy [OSHA §1910.147(b)]

Per interview with the EH&S Delivery Specialist, all equipment isolation procedures require testing that verifies the effectiveness of the isolation procedure by attempting to activate the isolated system (i.e., attempting to start an isolated pump by actuating the electrical switch). CCHMP reviewed several pump isolation procedures discussed in S03-10 that included steps to verify the isolation was effective.

Y NoneAbr

S03-10 Hazardous Energy Control Procedures

Does the stationary source document hazardous energy control procedures, which include separate procedural steps for the safe lockout/tagout of each machine or piece of equipment affected by the hazardous energy control procedure? [T19 CCR §2760.3(d)] [T8 CCR §3314(g)]

1. The procedural steps for the safe lockout/tagout of prime movers, machinery or equipment may be used for a group or type of machinery or equipment, when either of the following two conditions exist: (condition 1) a. the operational controls named in the procedural steps are configured in a similar manner, b. the locations of disconnect points are identified, and c. the sequence of steps to safely lockout or tagout the machinery or equipment are similar; or (condition 2) the machinery or equipment has a single energy supply that is readily identified and isolated and has no stored or residual hazardous energy. [T8 CCR §3314(g)]2. The facilities should have separate control of energy procedures for each type of equipment or unique equipment. This is per CalOSHA. If a facility does not have separate procedures, CCHMP should only provide a

CCHMP reviewed the following sampling of isolation procedures:- AI-253W Isolation Procedure (revised 8/24/17)- B-155 Isolation LEO Procedure (revised 7/1/16)- B-1 Isolation and Draining Procedure (revised 7/26/17)- H-301 PSV #7553 Draining/Isolation LEO Procedure (revised 11/3/13)- 2,3 Penta Load Hose Isolation Procedure (revised 7/16/18)- P-3080 Pump Isolation LEO Procedure (revised 8/23/16)- P-503B Isolation Procedure (revised 7/21/18)- P501A&B Isolation LEO Procedure (revised 5/7/18)

The above procedures identified the steps required to properly isolate and tag the equipment by referencing the appropriate RTM Form.

CCHMP recommends the use of graphics in the Location Listing to identify isolation points as part of the isolation process to act as a training tool or provide additional clarity in isolation jobs.

Y NoneAbr



S03-12 Energy Control Procedure

Does the stationary source ensure that where lockout is used for energy control, the periodic inspection includes a review, between the inspector and authorized employees of their responsibilities under the hazardous energy control procedure being inspected; stationary source certifies that the periodic inspections have been performed; and the periodic inspection certification includes the following: a) Identifies the machine or equipment on which the energy control procedure was being utilized;b) The date of the inspection; c) The employees included in the inspection; andd) The person performing the inspection? [T19 CCR §2760.3(d)] [T8 CCR §3314(j)]

1. Energy source is any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy [OSHA §1910.147(b)]2. The periodic inspections shall be conducted to correct any deviations or inadequacies identified. [OSHA §1910.147 (c)(6)(B)]3. A periodic inspection of the energy control procedure(s) must occur at least annually. [T8 CCR §3314(j)]

Per interview with the EH&S Delivery Specialist, RTM lists are audited and certified monthly by the Safety Technician and an annual self assessment is conducted by the Safety Technician with authorized employees. The audit includes a review of an active isolation job for compliance with the LOTO policy and applicable isolation procedure; a review of documentation for an active isolation job; a review of documentation for an inactive isolation job (for release of equipment); a review of energy control operating procedures (if available); a review of training and documentation requirements. Any recommendations developed from the annual assessment are recorded and tracked via a compliance plan developed to address the identified deficiencies.

CCHMP reviewed the annual assessments completed for the 310 Block, 560 Block, and Chloropyridines Unit dated between March 2015 and March 2018 and noted the assessments included the items in (a)-(d) of the question.

Y NoneAbr

S03-21 Audit Follow-Up



No ensure action items were issued in the 2015 CalARP audit. This question is not applicable.

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ATTACHMENT C

Summary of Action Items

Summary of Action Items and Proposed Remedies

ID# Question Actions Proposed Remedy Due DateFindings

A11-12 Does the information pertaining to the technology of the process include the maximum intended inventory? [T19 CCR §2760.1(c)(1)(C) & Section 450-8.016(a)(1)(A)(iii)]

Ensure to update the RMP to include the total amount of aqueous ammonia (dry weight) for all concentrations.

Pittsburg Operations agrees to update its RMP to include the total amount of aqueous ammonia in covered process on a dry weight basis.

The site’s RMP is due for its five year update and resubmittal in July 2019. The proposed changes will be included in that update. Specifying the location of the indicated changes is not possible at this time.

08/31/19Dow maintains a document onsite titled "2018 AB2185 Combined Report/Hazardous Materials Inventory Data" that contains a listing of all the Tanks with both the Tank max inventory and the average inventory. The values presented in the table match the values reported to CERS. CCHSHMP reviewed the max daily / daily average. -Sulfur Dioxide (986,672 / 488,893 lbs) -Hydrogen Chloride (57,060 / 28370 lbs) -Hydrogen Fluoride (1,017,203 / 774,224 lbs) -Chlorine (7,616,823 / 4,804,605 lbs) -Anhydrous ammonia (4,000 / 2,560 lbs) -Aqueous Ammonia (27%) (151,578 / 75,289 lbs)

Aqueous ammonia was speciated in the table by all the concentrations, including 27% concentration, and lower concentrations including 13% aqueous ammonia (T-1301), and 1% (T-13003).

The table lists includes the Chemical Abstract Service (CAS) for materials. Per CCHSHMP review, the Ammonia aqueous CAS is identified as "7732-18-5" which is water. The SME flagged the error and intends to correct the error.

CCHSHMP notes that the values presented in the RMP, on page 3, table II-A (July 2014), lists Aqueous Ammonia at only 27%, and not at its lower concentrations. The RMP should include all the concentrations of aqueous ammonia that are above the regulated threshold including the 12,000 lbs of 13% aqueous ammonia concentration in (T-1301). Note the regulated threshold for aqueous ammonia is 500 lbs dry weight, so the facility should determine which concentrations qualify as "regulated" substance.

Per follow-up interview with the EH&S Leader, the quantity reported in the RMP is mixture weight of the aqueous ammonia solution (water / ammonia) and not the total dry weight of ammonia. The RMP is intended for the regulators, the information within should only report only the regulated material, in this case the ammonia, not the solution mixture weight. The RMP needs to include the total amount of aqueous ammonia (dry weight) for all concentrations. Including the 12,000 lbs of 13% aqueous ammonia concentration in (T-1301).

Wednesday, November 06, 2019 Page 1 of 15Dow Chemical- 2018 CalARP Audit Findings


A12-28 Has the stationary source retained copies of the documented resolution of the recommendations described in §2760.2(e) for the life of the process? [T19 CCR §2760.2(g) & Section 450-8.016(d)(4)]

Ensure that all PHA findings and the corresponding recommendations are documented and maintained including the resolution. This is to be retained for the life of the process.

This is a modified repeat from the 2015 A12-24.

Pittsburg Operations agrees to update the site Process Hazard Analysis (PHA) policy to include having the Regional Process Safety Technology Leader create the corrective action plan for responding to the PHA recommendations and a verification by a Corrective Actions work process subject matter expert that each corrective action has been properly closed out and actual date of completion is captured.

12/31/20Per interview with Process Safety Technology Leader, the PHA team reviews findings with the Production Leader before the report is finalized and is an opportunity to provide input to the team regarding the recommendations. Per CCHMP review of the RCPHA reports and comparison to EAT database, CCHMP noted that not all PHA team recommendations are addressed and documented to be resolved.

In AFTF and Trifluoro Plant facility review (4/25/2017) action item #21 and #24 were not addressed or documented in the EAT. Item #11 the action is to evaluate only.

In the SF and SF warehouse (4/27/2017), action item #10, action item #16 and action item #18 were not documented in the EAT so no document of resolution. CCHMP further noted that action Item 5 was closed with "it will be implemented by LOPA Capital". Per discussion, the action is to "review the need to add an EBV on the vent flow between T-1W and the SF warehouse." CCHMP contends that this is a poorly worded recommendation and that the recommendation should include actually completing the task of installation of the EBV once it is determined to be necessary. Also, item #12 was closed with "these scenarios will be evaluated in the 2018 SF LOPA revalidation." Action items should only be closed after the task has actually been performed.

In site logistics (3/15/2016), item #2 indicated a completion date of Jun 20, 2016 and the action taken indicated with meeting set for Wed., June 22. Item #8 and #20 was closed with action taken "waiting on final MOC approval to publish to updates to WebEDMS". Item #5 was closed out with "the project has been added to the plant PSTP….."

Per interview, currently the Process Safety Technology Leader is inputting the action items into EAT rather than the facility. Any alternate actions or comment should be documented if the decision is reached to not complete the recommendation. See in A12-24 for justification and documentation to be retained for decision made to implement or not implement all PHA recommended action items.

During the audit, CCHMP was provided modified EAT for the following:-EAT 447458 for Block 310, AFTF: Item 11, added "if there are not, update plant and site documentation that T-XXX is CalARP covered." -EAT 447460 for Block 310, SF: Item #5 was edited to indicate incomplete and action taken was deleted. Item #12 was edited to



be "not completed" and the action taken was deleted.-EAT 426888 for Site Logistics: Item #2 was edited to say "met with…." CCHMP also noted that item #6 was clarified to include the date the LOPA revalidation was held. Item #8 and #20 was edited to include the MOC number and the location of the Compatibility grid. Item #5 was edited to include "a separate action item has been generated…"

Per CCHMP's review and observation the action taken have been address, the remaining action is to create the entry in the EAT for recommendations that was missing from the current EAT and document if the action was addressed as part of another system, was rejected and the justification for rejection or if alternate recommendations was generated.

A15-02 Have inspections and tests been performed on process equipment? [T19 CCR §2760.5(d)(1) & Section 450-8.016(a)(5)(D)]

Ensure that inspection and testing documentation is maintained per the Corporate Equipment Records Manual.

Pittsburg Operations agrees to develop and implement a work process for maintaining inspection and testing records per the Corteva Agriscience record retention requirements.

12/31/20Per review of the Corporate Equipment Records Manual, equipment records including testing and inspection records for process equipment must be maintained for the life of the plant or equipment plus 4 years. Per interview with the Maintenance Activity Coordinator and Maintenance Technician, alignment procedures that are used to record alignment data when installing equipment are maintained for a month and then discarded. CCHMP acknowledges that Dow's corporate record retention policy meets the regulatory requirements and must be followed.



A15-05 Has the stationary source documented each inspection and test that had been performed on process equipment? [T19 CCR §2760.5(d)(4) & Section 450-8.016(a)(5)(D)]

Ensure that area monitor calibrations are completed per the established inspection intervals.

Ensure that a practice is established to document each oil analysis that has been performed on process equipment.

Ensure that a method is established to retain machinery alignment information documentation.

Pittsburg Operations agrees to update the appropriate work processes and/or procedures for area monitor calibrations to ensure that the calibrations are complete per the established inspection schedules.

Pittsburg Operations agrees to implement a work process to maintain oil analysis results in house.

Current procedures include instructions to record machinery alignment data. Pittsburg Operations agrees to develop and implement a work process to retain electronic copies of the completed procedures with the machinery alignment data.

01/31/20Per interview with multiple SMEs, equipment inspections and tests are maintained on the central ECC/SAP maintenance database and within various electronic equipment file locations. CCHMP reviewed several fixed equipment files and reviewed the following tests and inspections that have occurred since the previous Callard audit:

- T-10: visual inspection conducted March 2018; NDT inspection conducted October 2017- T-4: visual inspection conducted April 2018- E460-PROFUM-GEN___-T-5: NDT inspection for thickness readings conducted on 2/8/17- E460-PROFUM-GEN___-T-55: UT inspection conducted on 2/13/17- E466-620BLK-AUXBLR-T-102: External Visual and NDT inspections conducted on 9/19/18

The following piping circuit inspection reports were reviewed:- From MOC 310-SF2016070001, hydrostatic pressure test on a new piping circuit conducted 11/28/16; non-destructive examination (NDE) of welds conducted 11/15/16- E460-PROFUM-GEN___-HF_CIRC.-01: visual and ultrasonic inspection conducted on 5/3/18- E460-PROFUM-GEN___-HF_CIRC.-06: visual and ultrasonic inspection conducted on 5/1/18- E460-PROFUM-GEN___-SO2_CIRC.-01: visual and ultrasonic inspection conducted on 5/17/18- E466-620BLK-AUXBLR-ANH_NH3_CIRC.-02: visual, ultrasonic, and radiographic inspection on 6/5/17; inspection results and previous data resulted in inspection interval to be extended from 27 months to 54 months- E466-620BLK-AUXBLR-ANH_NH3_CIRC.-03: visual and ultrasonic inspection conducted on 8/22/16

Equipment files were reviewed for the relief devices below which confirmed that the appropriate test documentation was maintained and the associated testing frequencies were followed:- R-1462 (18-month schedule): last tested 10/11/17; previously tested 6/7/16- P660-R-73 (24-month schedule): last tested 4/24/18; previously tested 5/4/16- P660-R-74 (24-month schedule): last tested April 2018; previously tested- P320-R29 (54-month schedule): last tested 3/20/18; previously tested 3/28/17, - P320-R30 (36-month schedule): last tested 7/6/17; previously tested 7/22/15



- P320-R31 (57-month schedule): last tested 4/20/16; previously tested 7/15/13- P320-R78 (24-month schedule): last tested 4/10/17; previously tested 5/1/15 - P320-R79 (12-month schedule): last tested 12/18/17; previously tested 1/23/17, 2/22/16- P420-R-40 (12-month schedule): last tested 8/17/18; previously tested 8/16/17, 9/19/16, 1/12/16- P420-R-41 (24-month schedule): last tested 1/8/18; previously tested 2/10/16- P560-R-35 (12-month schedule): last tested 11/16/17; previously tested 11/17/16- P560-R-36 (12-month schedule): last tested 1/11/18; previously tested 1/26/17, 3/4/16

The following instrumentation inspections were reviewed:- P-560 Chlorine Monitor Quarterly Inspection (covers AI(781)P - AI(793)P, AI(761)Q - AI(780)Q, AI(794)Q - AI(799)Q): conducted 9/22/18, 6/23/18, 3/26/18- IA10-Chlorine Monitor Calibration and SIS Proof Tests (covers AI(789)P, AI(761)Q, AI(763)Q - AI(780)Q, AI(795)Q - AI(799)Q: conducted 11/14/17- C619 High Temperature SIS Validation: conducted 7/22/16- IA10-P660 Chlorine Area Monitor Calibration: conducted 8/24/18, 7/24/18, 2/15/18, 1/3/18- SIF# 608.01 R-3D Loop Validation Test Procedure Checklist: completed 12/14/12- SIF# 553.01 R-3C Loop Validation Test Procedure Checklist: completed 12/14/12- C-619 High Temperature SIS Validation Procedure Checklist: completed 7/22/16- R-901 Flame SIS Validation Procedure Checklist: completed 12/21/17- C-619 Liquid Feed SIS Validation Procedure Checklist: completed 7/22/16- SIF-24 1 SIS Loop Validation Test Procedure Checklist: completed 1/16/18

The following vibration analyses conducted on rotating equipment were reviewed:- P-634A: most recent analysis conducted 8/22/18- P-72: conducted 8/22/18- P-35A: conducted 9/18/18- P-30: conducted 9/5/18

Oil Analysis: The facility does not have consistent access to previous oil analyses. The facility contracts oil analyses to be performed by a third party contractor which makes the information



accessible to Dow via an online portal. Per interview with Oil Technician the portal has not been working for approximately four weeks and the facility does not have access previous oil analyses outside the web portal. The facility does not save a digital copy to the equipment database, nor do they print a hard copy for the records. The facility relies on the contractor to manage their oil analysis records. The facility needs to establish a practice to document each oil analysis that has been performed on process equipment.

Machinery Alignment: The facility does not have a system to record final shaft alignments for rotating equipment requiring alignment. Per interview with Maintenance Activity Coordinator and Maintenance Technician, the facility is tracking the information in a database but when the migration went over to SAP the information was no longer being captured. Millwright personnel capture the information in one of five rotoaligns, and record the information in the procedure. However procedures are discarded after approximately one month and alignment information on equipment is not practical to retrieve and may not be available if done by a contractor.

From the above records, the chlorine area monitors for the 660 block were not consistently documented on physical records; several of the monitors identified by the IA10-Chlorine Monitor Calibration and (SIS) Proof Test Critical Procedure Checklist did not have any physical records available for review which demonstrated that calibration was conducted. Per review of the SAP database records, multiple quarterly chlorine monitor calibrations were not completed as scheduled for a majority of the monitors in the 660 block (e.g., AI-012A and AI-025A). Per interview, there were no deferrals generated for the above maintenance items.

Per interview with the on-site Oil Analyst, oil samples are collected and sent off-site to be analyzed by a contractor with the results of the analyses stored online and made accessible through the portal provided by the contractor. CCHMP requested to review a sampling of the data from the oil analyses but Dow was unable to provide the documentation due to an issue with the web portal on the vendors side. Dow currently does not back up the oil analysis data to an onsite location. See A15-06 regarding oil analysis documentation.



A16-11 Does/did the stationary source ensure that if a change results in a change in the PSI (§2760.1 and Section 450-8.016(A)(1)), that this information will be updated accordingly? [T19 CCR §2760.6(d) & Section 450-8.016(a)(6)(D)]

Ensure that the P&ID is updated as part of the MOC process.

Pittsburg Operations agrees to ensure that the specific P&ID identified in the audit is properly updated and to provide refresher training to MOC Change Owners on the requirements associated with updating process safety information, including P&IDs, as part of the MOC process.

01/31/20CCHMP reviewed over 20 MOCs for different plants and found the following deficiencies:

Per review, MOC MEI-2018020002 (started 2/2/18, effective date 5/30/18) Install VFD on R-1200's agitator, has under the MOC checklist P&ID Master Updated with the action marked "Yes." This was for drawing BI-421-640 (revised 12/12/17). The drawing had a red MASTER stamped on it. Per the SME, this is the most up to date drawing. However, the drawing has not been updated with the new VFD since the MOC was issued.

Per review, MOC FPI-A2017020002 (status time stamp 12/13/17) for the rupture disc material to be changed to graphite permanently has the line for P&ID Master Updated marked "Yes." However, CCHMP was unable to confirm that this change had been documented in the PSI as there was no documentation related to the material change of the rupture disc.



A18-01 Has the stationary source certified that they evaluated compliance with the provisions of this article at least every three years to verify that the procedures and practices developed under this chapter are adequate and are being followed? [T19 CCR §2760.8(a) & Section 450-8.016(a)(8)(A)]

Ensure that compliance audit clearly assess the employee participation program including the employee participation in the development (and on-going maintenance) of the prevention program elements.

Pittsburg Operations believes that its employees have multiple opportunities to both participate in and provide continuous improvement feedback into the various prevention program elements. Specifically, employees provide continuous improvement feedback through the employee suggestion system, management system reviews and self-assessments. Pittsburg Operations will update its Employee Participation Safety Standard to explicitly state the methods by which employees provide continuous improvement feedback. In addition, as part of becoming Corteva Agriscience, additional means for employees to provide continuous improvement feedback for the prevention program elements will be evaluated and implemented as appropriate.

06/30/20CCHMP reviewed 05.04.06 L1 Audits Policy and Requirements, this is an excerpt from the 05.00 Common Management System policy (Dow Corporate standard, rev. 05 Jan 09). Section B. specified that an audit schedule must be created or updated at least annually.

CCHMP reviewed Certification statements for:1) 310 and 560 block: date of audit 2/12-16, 2018, (signed 3/19-20/2018 by the auditor and 4/2/2018 by the production leaders) 2) 660 block: date of audit 4/11-15, 2016 (signed 4/15 and 6/30 by auditor and 12/6/2016 by production leader); date of audit 5/10/2013 (signed 5/10 and 7/15 by auditor and 7/18/2013 by production leader)3) 640 block: date of audit 2/19-23, 2018 (signed 2/23 and 3/1/2018 by the auditors and 3/1/2018 by the production leader); date of audit 3/23-27, 2015 (signed 4/6/2015 by auditors and production leader) 4) 520 block and site logistics: date of audit 5/8-12, 2017 (signed 5/18/2017 by auditor and production leader); date of audit 6/16-23, 2014 (sign 8/28/2014 by auditor and 8/29/2014 by Production Leader).

The certification statement for Block 660-2016, Block 640-2015 & 2018 and Block 520-2014 & 2017 states the operations were reviewed pursuant to CalARP Program CCR Title 19, Div. 2, Chapter 4.5 sec 2755.6 (a) and/or 2760.8 (a) and that "to the best of our information, knowledge and belief based on this review, the procedures and practices required to be developed under both the PSM standard and the RMP/CalARP rule, except for those concerns identified and discussed in the audit report findings, are adequate and being followed. The correction of any concerns identified and discussed in the audit report findings shall be documented by the plant".


CCHMP also reviewed the topics that were assessed during the compliance review, and noted there is not sufficient assessment on employee participation. Per discussion with EH&S delivery lead, auditors may use a combination of self assessment checklist, process Safety management compliance worksheet, interviews, etc. However, per CCHMP review of the self assessment checklist for ODMS 06.06.B3 'employee participation', it asks if employees participated in Health & Safety



activities. In the compliance worksheet, 5 questions were asked regarding having a written employee participation program including if the program include involvement/consultation of employees in PHA and other PSM. However, based on interview with SME, auditors are not required to use these checklists and in practice, employees do not have a mean to input to the development of prevention programs as these are developed by corporate SMEs. Employee participation is mainly assessing if there is a way to communicate safety concerns; describe employee's responsibilities to take action when safety concerns arise; and if employee have access to PHA and other information, etc. See additional discussion of audit topics and audit report in A18-03.

A18-02 Has the compliance audit been conducted by at least one person knowledgeable in the process? [T19 CCR §2760.8(b) & Section 450-8.016(a)(8)(B)]

Ensure that the facility can demonstrate how the compliance audit was conducted by at least one person knowledgeable in the process.

Pittsburg Operations agrees to review the compliance auditing process and ensure that it clearly demonstrates how the audit was conducted by at least one person knowledgeable in the process and develop additional site auditing requirements as necessary if the existing work process is determined to be

06/30/20CCHMP reviewed 05.04.06 L1 Audits Policy and sec. A specified that an audit must be conducted by qualified auditors who are independent of direct responsibility for the activities being audited. CCHMP also reviewed EH&S audit L3 standard, requirement no. 6 states EH&S auditors and Lead Auditors must be trained and approved before performing audits or the exceptions process be followed. Then auditors are classified as New, Experienced or Expert auditors according to their auditing and subject matter knowledge and experience. The audits may be performed by the corporate auditors or by other facility personnel that have been certified to be Dow auditor.

Per CCHMP review, each of the EHS Integrated Audit Reports includes audit plan, team and entity. The auditors are divided by Dow's Operating Discipline Management System (ODMS) sections: Common Management Systems, responsible care, facilities operations and may also include quality system. Per interview, the process safety auditor is the technical person that has the background and process knowledge and generally the expectation is that this person is a Process Safety Technical Lead. However, this common practice is not a requirement in the policy.

Per interview with EH&S Delivery Lead, at the opening meeting, the plant being audited does give a high level plant overview (a selected/condensed version of RC PHA) to the entire audit team and as a part of the assessment, interview operations staff that is familiar with the management system and knowledgeable about the process. However, CCHMP was unable to locate any documentation of individuals that participated or were interviewed from the facility as a part of the compliance audit activity.



A18-03 Does/did the stationary source document the scope, methods used, results and findings in a report that is available for AA to review? [T19 CCR §2760.8(c) & Section 450-8.016(a)(8)(C)]

Ensure that the compliance audit report that is available for agency to review documents the scope, methods used, results and findings.

Pittsburg Operations agrees to review the compliance auditing process and ensure that the compliance audit report made available to CCHSHMP documents the scope, methods used, results and findings of the audit and develop additional site auditing requirements as necessary if the existing work process is determined to be insufficient.

06/30/20CCHMP reviewed 05.04.06 L1 Audits Policy and sec. C specified that audit procedures must be established and maintained that define a) how the audit scope and frequency are determined; b) responsibilities and requirements for conducting audits; c) how results are reported and records are maintained.

Per CCHMP review of the EHS Integrated Audit reports (see dates of reports in A18-01), the reports are reviewed based on Dow's Operating Discipline Management System (ODMS) sections: Common Management Systems, responsible care, facilities operations and EH&S requirements related to business, site, plant and government.

For Block 660, Common Management System, Responsible care and Facilities Operations were reviewed. For 520, 310 and 560 Common Management System, Responsible care, Quality system and Facilities Operations were reviewed. For 640, Common management System and Responsible care were reviewed.

CCHMP reviewed the 05.00 Common Management System Level of Requirements & Performance Principles and it included these following CalARP prevention elements:-Training (05.03.01)-Procedures (05.03.04)-Management of Change (05.03.05), includes the requirement for PSR (05.03.05 A4.e) and the requirement to update Process Safety Information as part of PSR.-Corrective & Preventive Actions (05.04.02)-Investigations (05.04.05)-Audits (05.04.06)

Responsible care included these following CalARP prevention elements:-Personal Safety (06.05):Contractor, visitor Safety, hot work, Isolation of energy (IOE), Line & Equipment Opening (LEO), Confined Space Entry (CSE), Safe Work Permit (SWP)-Process Safety (06.03, 06.08): global Mechanical Integrity Manual and Safety standard, Process Risk Management, Safety System Impairment-Industrial Hygiene (06.05): Hazard Awareness-Crisis and emergency management (06.04 and 06.10) includes emergency plan and emergency preparedness, crisis management plan and notification.

Per interview with EH&S Delivery Leader who is also a certified DOW auditor, each ODMS element focal point performs audit and



self assessments mostly in a 3 year frequency. For CSE, SWP,LEO, HW, IOE, these self-assessments are performed annually. The EH&S integrated auditors will also use these self assessment checklist as part of the audit. CCHMP reviewed selected blank self-assessment checklists and noted that these checklists ask questions for the auditor to look at including suggestions on sample size and reference the ODMS elements and requirements. For example the MOC checklist includes question 5 "do you identify all associated documentation for changes and ensure that they are created or updated?", question 6 "are Pre-startup Reviews completed and documented when required?" However, per interview with EH&S Delivery Leader, use of the self assessment checklist is not mandatory and varies among the experience levels of the auditors.



A18-05 Does/did the stationary source document the actual completion dates when deficiencies were corrected? [T19 CCR §2760.8(d) & Section 450-8.016(a)(8)(D)]

Ensure that the tracking for compliance audit action closure document the actual completion date when the deficiencies were corrected.

Pittsburg Operations agrees to develop and implement a work process which includes having a Corrective Actions work process subject matter expert validate that action items from compliance audits are properly closed out and actual date of completion is captured.

06/30/20CCHMP reviewed printouts from the Event and Action Tool (EAT) database for Block 640, 520, 310, 560, 660.

CCHMP noted that in some instance, the documentation did not actually document the actual completion dates when the deficiency was corrected:-Block 310: compliance audit (#6) found 1 employee that did not receive required training but the action taken and completed was the training requirement was added to the learning requirements to the individuals. -Block 560: compliance audit finding (#1) identified a gap for training requirement in Block 560. The action taken and completed in May 2018 was that training is required to complete in July 2018.-Block 520/site logistics: compliance audit (#8), the audit found MOC program to non-conformance and recommended a management system to be implemented. From site logistics the item closed on April 30, 2018, with documented action taken and completed was a management system already in place, and individually regular reviews. For Block 520, are scheduled. (this does not address management system deficiency identified). The audit finding #59 marked complete on 10/26/2017 with action taken "will work with plants to make out side drum a less than 90" (this is not CalARP). -Block 660: Compliance audit (#21) found 1 employee is two weeks overdue for HAZWOPER Level A medical surveillance at Chloropyridines and is looking for restriction on the employee and to develop a sustainable process to be notified by Health Services. The action was closed out on Dec 28, 2016 "check with the plant nurse and Spec Chem does not currently have anyone overdue for a medical assessment." This assessment was in the wrong facility. Compliance audit (#37) was closed out on 3/1/2017 "I have been trained and will be doing my hood audit for the entire site before the end of the year". (not CalARP)



A20-03 Has the stationary source consulted with employees and their representatives on the development of the other elements of process safety management (other than PHA's)? [T19 CCR §2760.10(b) & Section 450-8.016(a)(3)]

Ensure that a feedback system between personnel and site leadership is developed for the continuous improvement of the prevention program elements.

Pittsburg Operations believes that its employees have multiple opportunities to both participate in and provide continuous improvement feedback into the various prevention program elements. Specifically, employees provide continuous improvement feedback through the employee suggestion system, management system reviews and self-assessments. Pittsburg Operations will update its Employee Participation Safety Standard to explicitly state the methods by which employees provide continuous improvement feedback. In addition, as part of becoming Corteva Agriscience, additional means for employees to provide continuous improvement feedback for the prevention program elements will be evaluated and implemented as appropriate.

06/30/20CCHMP reviewed S-504 Employee Participation Safety Standard (revised 5/17/18) and identified employee participation roles for the prevention program elements:








Incident Investigation: Employees and contractors may report incidents and participate on the investigation (as appropriate) with the results being communicated via Learning Experience Reports (LERs) or the Event and Action Tool (EAT).




PHA: Employees with knowledge specific to the process participate as part of the PHA team. Additionally, PHA results and action plans are communicated to affected employees and all employees have access to the EAT which documents PHA results. CCHMP reviewed the RCPHAs in A12-16 and noted that all RCPHAs identified a Technical Advisor (TA) that was PSM Certified in the process being reviewed. The TA is considered a process knowledgeable person when conducting the RCPHA as they have had previous process operating experience.





S01-06 Before a hot work permit is issued, does the permit authorizing individual verify that fully charged and operable fire extinguishers that are appropriate for the type of possible fire shall be available immediately at the work area? [T8 CCR §4848((a) via NFPA 51B 3-3.2(j)]

Ensure to update the site hot work permit to include a verification check to confirm that fully charged and operable fire extinguishers that are appropriate for the type of possible fire are available immediately at the work area.

Ensure to update the site hot work procedures to include completion of this verification by permit issuer.

Pittsburg Operations agrees to update the site hot work permit to include a verification check to confirm that fully charged and operable fire extinguishers, appropriate for the type of hot work being conducted, are available in the immediate work area.

Pittsburg Operations agrees to update the site hot work procedures to include the verification by the permit issuer that fully charged and operable fire extinguishers appropriate for the type of hot work being conducted, are available in the immediate work area.

12/31/19Per interview, the fire watch is responsible for bringing a fully charged and operable fire extinguisher to the hot work area. Fire extinguishers are monitored, checked and verified to be operable by a third party contractor on site. The verification is conducted periodically as needed. Area inspection by the permit authorizing individual and the fire watch is a specified requirement for high energy hot work before hot work is authorized.

Per a review of a site procedure titled "Fire Watch Checklist" dated 3/17/16, fire extinguishers must be provided by the workers/contractor. Per a review of the Global Safe Work Permit standard, 06.05.C revised January 13, 2016, Safe Work Permit requires documentation of many items including: "A place to indicate that specific emergency procedures and alarms, locations of assembly points and evacuation routes and the locations of emergency equipment including nearest safety showers, eye wash, fire extinguisher and telephone and/or intercom have all been reviewed and understood." However, neither the Safe Work permit nor the Hot Work Permit provide verification check confirming that the fully charged and operable fire extinguishers that are appropriate for the type of possible fire are available immediately at the work area. The related hot work procedures also need to be updated to include completion of this verification by permit issuer.


ATTACHMENT D

Summary of Consider Items

Summary of Consider Items and Proposed Remedies

ID# Question Consider Proposed Remedy Due DateFindings

A11-09 Does the information pertaining to the hazards of the regulated substances include the hazardous effects of inadvertent mixing of different materials that could foreseeably occur? [T19 CCR §2760.1(b)(7) & Section 450-8.016(a)(1)(A)(i)]

Consider adapting a common designation practice for "Chemical Compatibility Charts" by consistently using the same symbology, colors and category descriptions.

Consider establishing a minimum standard for the type of information being presented/compared in the "Chemical Compatibility Charts" (e.g. piping material, gaskets, absorbents, NFPA class, and lubricants).

Pittsburg Operations agrees to implement a common format for chemical compatibility charts.

12/31/20As discussed in A11-06, Section 10 Stability and Reactivity of all the SDS/MSDS, contain information regarding materials that are incapability.

Additionally, DOW has developed and maintains "Compatibility of Chemicals Chart" for each of the plants with covered processes. At a minimum all the matrix charts contained compatibility/reactivity information cross referenced with all other chemicals found within the plant. However CCHSHMP notes each chart varied in available information presented, some charts had NFPA rating class, absorbent, lubricant, and piping. The facility should consider establishing a minimum standard of information that is required for the compatibility matrix. CCHSHMP notes there is a lack of consistency in the compatibility designation, including varying colors, symbology (number & characters), descriptions, and number of designations used. The facility should consider adapting a common practice across all process "compatibility designations" including a consistent numbering/lettering, use of color, and description of designation. CCHSHMP believes that varying format may pose a human factors issues, for employees that have to work on multiple blocks (e.g. maintenance employees).

Below is a list of chemical compatibility charts reviewed and the information type presented/compared:

-MEI, rev. 4/3/2017 (absorbent, lubricants) -Chloropyridines, rev. 10/1/2018 (metal, pipe, PCE, gaskets, lubricants, insulation, sealants, absorbents, cleaners, chemicals) -FPI 560 block (metals, lined pipe, PCE, lubricants, coating, insulation, sealants, absorbents, chemical) -AFTF (NFPA rating, absorbents, chemicals) -Sulfuryl Fluoride (NFPA rating, absorbent, chemicals) -Manufacturing Services (NFPA rating, metals, pipe, PCE, gaskets, lubricants, chemicals) CCHSHMP notes per field observation, the compatibility charts are posted in the control rooms and accessible to operator and contract personnel.



A12-25 Did the stationary source consider the use of Inherently Safer Systems in the review of: new processes and facilities, existing processes, or in developing recommendations and mitigations for PHA’s? [Section D.1 of the CCC Safety Program Guidance Document]

Consider adding the discussion of the risk reduction strategies concepts from Inherent to passive, active and procedural in the RCPHA policy and checklist.

Some existing heritage corporate guidelines touch on elements of risk reduction strategies but does not address them explicitly. Corteva Agrisciences is in the process of developing its policies and work processes for Hazard Identification and Risk Analysis (HIRA). The inclusion of a discussion of risk reduction strategies (i.e. hierarchy of controls) in the work process documentation will be recommended to the appropriate corporate team(s) for inclusion in the new policies and work processes.

10/31/19Dow is not required to consider the use of inherently safer systems approaches in the review of new or existing processes. However, per CCHMP review of the RCPHA questionnaire, sec. w of the questionnaire are consideration for Inherently Safe Design including:-Intensification/minimization (8): e.g. has the location of the process equipment been designed to minimize the length of hazardous materials piping?-Substitution (4): e.g. has a less hazardous heat transfer media been considered?-Moderation or Attenuation (5): e.g. have you considered limiting the supply pressure of raw materials to less than the working pressure of the vessels to which they are delivered?-Simplification (10) e.g. for facilities with possible vapor cloud explosion, has layout considered separated process areas which handle significant quantities of high reactivity fuels from other areas?



A13-02 Are the written operating procedures consistent with the process safety information for the process? [T19 CCR §2760.3(a) & Section 450-8.016(a)(2)(A)]

Consider reviewing/revising operating procedures as follows:

Consider using command style sentences for operating procedures.

Consider identifying steps in the operating procedure that require a check on the control panel.

Consider updating AHM AO-227L Pressure Check Critical Procedure Checklist with the appropriate P&ID references.

Operating procedures are written and maintained (i.e. periodically reviewed and updated as needed) by the Operating Technicians that use them. As such, if the Operating Technicians felt that the use of command style sentences was beneficial it would be included in that specific procedure. Therefore, Pittsburg Operations does not believe that using command style sentences in the procedure steps will provide any significant benefit to the users. No further action will be taken at this time.

Operating procedures are written and maintained (i.e. periodically reviewed and updated as needed) by the Operating Technicians that use them. As such, if the Operating Technicians felt that identifying steps that require a check on the control panel was beneficial it would be included in that specific procedure. Therefore, Pittsburg Operations does not believe that identifying the specific steps in operating procedures that require a check on the control panel will provide any significant benefit to the users. No further action will be taken at this time.

Pittsburg Operations agrees to update the AHM AO-227L Pressure Check Critical Procedure Checklist to reference the appropriate P&IDs.

08/31/19

08/31/19

10/31/19

CCHMP reviewed the following procedures and found that they were consistent with the P&IDs for the process:

-R-210 Response to High Pressure in HF line to Reactors, drawing B303A-420 (revised 11/20/17). CCHMP was able to locate the valves DO(440) and DO(431), autovalve AO(408).

-AHM AO-227L Pressure Check Critical Procedure Checklist referenced procedure B1-19A-45 which did not have AO-227L. The SME provided drawing B1-20-45 (revised 2/22/18) which did have AO-227L.

CCHMP did a procedure walk of the operating procedures below in order to evaluate the accuracy of the procedures and the ability of the operators to perform tasks based on the procedures.

-310 Block HF Header Line Clearing Isolation Procedure (revised 5/3/16)-P-1301 A&B Isolation LEO Procedure (revised 5/21/17)-AHM-E-234 A or B Vaporization Startup Procedure Checklist (revised 9/30/15)

CCHMP determined that the procedure accuracy for all three procedures combined was 98%. However, CCHMP does not typically walk down an entire procedure and did not do a full procedure walkdown of any of these procedures.

CCHMP observed the following during the walkdowns:-The operating limits were not specified in one procedure.-Two procedures had steps that required a person to look at the MOD in the control room which was not specified in the procedure.-There were steps in the procedures that did not start with action verbs.

CCHMP believes that human factors considerations can be major contributors to incidents and incidents with adverse outcomes.



A13-06 Do the procedures address emergency shutdown, including conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner? [T19 CCR §2760.3(a)(1)(D) & Section 450-8.016(a)(2)(A)]

Consider standardizing the operating procedure titles so that if a procedure is categorized as Critical or Emergency, it will have the appropriate keyword in the

Pittsburg Operations agrees to update its operating procedure templates and best practices to include the words "Critical" and "Emergency" in the procedure titles for procedures classified as critical or emergency. The procedure templates and best practices will be developed and implemented by the indicated target date. However, individual procedures will be updated as part of the normal procedure review process.

01/31/20Per the PUP, Dow develops emergency shutdown procedures for different processes as needed. The emergency shutdown procedures include assigning responsibilities to people working within the unit. CCHMP reviewed the following emergency shutdown procedures:

-High Pressure Chlorine Line Emergency Shutdown (revised 6/22/18)

-Alpha Chlorine Evaporator Shutdown Procedure Checklist, revised 6/1/17.

-AHM B-105 to T-161 Chlorine Line Leak Mitigation Emergency (which includes shutdown), revised 9/27/18)

-SF Plant HF Railcar Critical Offloading Checklist (revised 2/28/17)

This procedure is marked in the Attributes and Categories: Critical, AOP (authorized operating procedure), Non-routine.

The Railcar loading process would be automatically shut down in the event that there was an issue with the offloading process by the EBVs (emergency block valve).



A13-12 Do the operating procedures include safety and health consideration such as precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment? [T19 CCR §2760.3(a)(3)(B) & Section 450-8.016(a)(2)(B)]

Consider changing the abbreviation MSDS to SDS which is part of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

Pittsburg Operations agrees to update its procedure template to replace “MSDS” with “SDS”. Updates to existing procedures will occur as part of the periodic (1 to 5 years) procedure review for each individual procedure.

01/31/20Per review, each procedure has a section, Hazards and Precautions, that covers the PPE, and, as appropriate, administrative and engineering controls.

-AHM-Railcar Bulged Relief Valve Procedure (revised 11/19/17) has in the Hazards and Precaution section a table listing Step, Hazard, and Precaution. In the Step column, the procedure has All; Hazard column, Chlorine Inhalation; Precaution column, Refer to Chloropyridines PPE grid for working with Chlorinated Pyridines. Underneath the table is a statement in bold type: "Refer to the MSDS for additional hazard information."

-AHM-P_73A/B Pump Isolation LEO Procedure (revised 10/25/17), in the Step column it has 4-9; Hazard column, Chlorine; and Precaution Column, Refer to Chloropyridines PPE grid for line openings.

Per live navigation with SME, Dow intranet has SDS's online in the eMSDS database. This database is available to anyone on site with computer access. An operator would be able to access SDS information by department or chemical name. The SME entered a department name, AFTA, and all of the chemicals for that department came up. When clicked, the hotlink brought up the corresponding SDS. CCHMP reviewed the SDS's for both Chlorine and HF, each having multiple SDS's due to the fact that Dow has elected to use multiple suppliers in the past for each. In the case of chlorine, Dow uses a local supplier and another Dow site as a backup. Per SME, the SDS's are kept current and once a year the SDS's are reviewed in order to identify those that are more than 5 years old. These are put into an archive folder on the network.



A13-19 Did/does the stationary source annually certify that the operating procedures are current and accurate? [T19 CCR §2760.3(c) & Section 450-8.016(a)(2)(E)]

Consider eliminating the review frequency from the critical site procedures.

Pittsburg Operations agrees to implement a work process for systematically updating its critical procedures to remove the review frequency from the Document Information and History section of the procedures. The work process will be developed and implemented by the indicated target date. However, individual procedures will be updated on the scheduled determined by the work process.

01/31/20Per review of 05.03.04 L1 Procedures Policy and Requirements, (revised 01/2018) states on page 3: "Annually validate that the management system, for maintaining procedures as current and accurate, is working effectively." Underneath this statement, the policy states: "For PSM/RMP covered processes, annually document the certification that procedures are current and accurate [no punctuation]" Per review, Annual Certification of Critical and Other Operating Procedures (revised 9/29/16) provides instructions on the "annual certification of unit Critical and Other Operating Procedures."

Per review, the Annual Certification of Emergency Procedures (revised 9/29/16) provides instructions on the annual certification of unit Emergency procedures.

Per review of the PUP (page 10), the policy states: "The methods for validating the effectiveness of procedure reviews are managed at the department level."

Per review, the operating procedures for each unit are certified annually.

For Site Logistics:-Critical and Other Operating Procedures - signed by Associate Production Director and dated 3/31/18, previous 3/27/17, 3/29/16-Emergency Procedures - signed and dated 7/31/18, previous 8/3/17, 8/30/16

For MEI (DCTFP, Brine wash, KOPy and Etherification) process units:-Critical and Other Operating Procedures - signed and dated 3/31/18, previous 3/28/17, 3/31/16-Emergency - signed and dated 7/31/18, previous 8/31/17, 8/31/16

For Manufacturing Services (520 block):-Critical and Other Operating Procedures - signed by Lead Production Manager and dated 3/27/18, previous 8/22/17, 3/29/16-Emergency - signed and dated 8/24/18, previous 8/17/17, 8/18/16

For 660 block:-Critical and Other Operating Procedures - signed by Associate Production Director II and dated 3/30/18, previous 3/31/17, 3/31/16-Emergency - signed and dated 8/31/18, previous 8/31/17, 10/3/16

For 560 block:-Critical and Other Operating Procedures - signed and dated



8/31/18, previous 8/28/17, 3/30/17-Emergency - signed and dated 3/29/18, previous 8/30/16, 9/27/17


For site logistics:-Critical and Other Operating Procedures - signed and dated 3/31/18, previous 3/27/17, 3/29/16-Emergency - signed and dated 7/31/18, previous 8/3/17, 8/30/16

CCHMP reviewed the procedures below that were supposed to be reviewed annually per the plant policy and were not. Each procedure has a section called Document Review Frequency and Approval and written in the next column is the frequency of review. Per interview with SME, these are Critical procedures that needed to have the review frequency updated in WebODMS.-AHM C-5/C-6 A&B Startup Critical Procedure Checklist (last reviewed 5/4/17)-AHM-Alpha Chlorine Evaporators Startup Critical Procedure Checklist (last reviewed 3/27/17)-AHM P-173A or B Startup Critical Procedure Checklist (last reviewed 3/29/17 but there was an update on 4/9/18)-AHM C-5/C-6 A&B Shutdown Critical Procedure Checklist (last reviewed 3/09/17)-AHM AO-227L Pressure Check Critical Procedure Checklist (last reviewed 3/27/17)

CCHMP was provided updates for the procedure above with the review cycle changed to 3 years.

Per review, Annual PPE Grid Review Procedure, revised 9/29/16, states in the Frequency section: "ANNUAL: Refer to the Master Task List for the schedule for completion check."

CCHMP reviewed the revision histories for the PPE grids for 310 block, 660 block, Man Services, 560 block, MEI, and found that 2 out of the five were not reviewed annually. -560 block reviewed 8/22/16, 8/24/17 but not 2018-MEI block reviewed 8/23/16, 8/29/17 but not 2018.

Dow provided documentation that the PPE grids above had been reviewed in 2018.

MOC-560B2018080004, started 8/23/18, status time stamp 8/30/18, Update PPE Grid



MOC-MEI-2018080009, started 8/23/18, status time stamp 10/15/18, Update PPE Grid

A14-07 Has the stationary source trained each employee involved in maintaining the on-going integrity of the process equipment in an overview of that process and its hazards? [T19 CCR §2760.5(c) & Section 450-8.016(a)(5)(C)]

Consider updating the PSM Certification Guidance to establish a procedural step to perform a cross reference check between the "PSM Training Summary Sheet" and "PSM Certification Training Information Sheet", matrix.

Pittsburg Operations agrees to update its PSM Certification Guidance document to include a step to perform a cross reference check between the PSM Training Summary Sheet and the PSM Training Matrix.

03/31/20Maintenance employees are PSM certified similar to operators, however instead of assigned zone and areas, maintenance employees are PSM certified by discipline. The facility currently has two disciplines site wide, Instrumentation and Electrical (I&E) and Mechanical.

The facility handed CCHMP a document titled, "PSM Certification Training Information Sheet", (not dated, no revision) which is a training matrix that identifies all the required training for the varying maintenance positions. CCHMP reviewed the PSM Training Certificate of two Mechanical Technicians, three Maintenance Engineers, two Electrical Reliability Engineer, two I&E Techs and three Millwrights and confirmed that all the employees have completed the required minimum training as indicated by the training matrix. However, CCHMP review of the "PSM Training Summary Sheet" notes that some Millwrights had completed additional training. Per follow-up with the training coordinator the facility has developed a training matrix.

CCHMP reviewed the procedural steps in PSM Training Certification Guidance, on "How to Verify Knowledge and Skills", and notes that there is not a procedural step to cross reference "PSM Training Summary Sheet" and the "PSM Certification Training Information Sheet" matrix. The facility may also want to include the training matrix as an attachment to the policy.



A15-09 Does/did the stationary source assure that appropriate checks and inspections have been performed to assure that equipment is installed properly and consistent with design specifications and the manufacturer's instructions? [T19 CCR §2760.5(f)(2) & Section 450-8.016(a)(5)(F)]

Consider performing baseline vibration readings for critical rotating equipment per API 686 Chapter 9 Section 4.21.

Pittsburg Operations agrees to implement baseline vibration readings of critical rotating equipment.

12/31/20CCHMP reviewed one MOC, 310-SF2016070001, that involved the installation of a 1" line used for reprocessing of off-specification product. Per interview with the Global GMISS SME and a review of the maintenance database, the inspections required for the installation of the new line were completed. The documentation of the inspection for the new piping circuit are discussed in A15-05.

Per interview with the Vibration Analyst, currently Dow does not require a baseline vibration analysis for newly or recently installed rotating equipment; however, it was acknowledged that a baseline vibration reading for critical equipment would be beneficial. Per API 686 Chapter 9 Section 4.21.1 and 4.21.4, "During initial start-up of the equipment, …[v]ibration signatures shall be obtained for all bearings."

Machinery Alignment: Per interview with Maintenance Technicians, Maintenance Personnel and the facility performs alignment on machinery. However as discussed in A15-05, the results of the alignment are not being retained so CCHMP was unable to confirm the actual results.

Gasket: CCHMP reviewed pipe specification CA-03 (rev. 2/6/18) that is rated for 300F @ 380 psig, and notes there are multiple gaskets identified. The specification calls for four types of gaskets, each with a list of different manufactures. In total there are 17 different gaskets that are acceptable for use. Per interview with maintenance personnel, Process Engineers, and Design Engineers, all 17 gaskets are acceptable for use on the process. CCHMP was also told that Dow uses a hierarchy to select the gasket. CCHMP further notes that the first and second choice of gaskets are also identified in The Chlorine Institute's Pamphlet 95, "Gaskets for Chlorine Service (Edition 5)". CCHMP further notes Pamphlet 95 provided the following annotations for those gaskets :

-Flexitallic Sigma 533, Tested for service conditions between 20°F (-7°C) and 72°F (22°C). -Garlock Gylon 3510, Tested for service conditions between 100°F (38°C) and -90°F (-68°C).

CCHMP followed up with Dow Process Engineers who indicated that the technical team that is responsible for identifying the gaskets appropriate for the pipe specification's associated service recorded the following operating ranges for the above gaskets:

- From Dow's Commodity Dictionary: Flexitallic Sigma 533,



temperature range of -350F to 500F- From OEM specification sheet: Garlock Gylon 3510, temperature range -350F to 500F @ 1200 psig

A15-11 Does the submitted RMP and Safety Plan accurately reflect the Mechanical Integrity Program at the stationary source? [T19 CCR §2745.2(d) & Section 450-8.016]

Consider updating the Mechanical Integrity description in the RMP to reflect the implementation of RBI for covered process equipment.

Pittsburg Operations agrees to update the Mechanical Integrity description in its RMP to reflect the implementation of RBI for covered process equipment. The site’s RMP is due for its five year update and resubmittal in July 2019. The proposed changes will be included in that update. Specifying the location of the indicated changes is not possible at this time.

08/31/19CCHMP reviewed a description of Dow's mechanical integrity program on Page 20 of the submitted 2014 RMP and determined that the description generally reflects the program. The RMP includes a list of inspection intervals from relevant RAGAGEP (e.g., ASME, API) which may be applied to various pieces of process equipment; per interview with several SMEs, Dow has implemented risk based inspection intervals for some of the covered process equipment. CCHMP suggests updating the mechanical integrity section to reflect this in the next RMP submission.



A17-02 Does/did the stationary source perform pre-startup safety reviews for modified stationary sources when the modification is significant enough to require a change in the process safety information? [T19 CCR §2760.7(a) & Section 450-8.016(a)(7)(A)]

Consider adding the MOC number to the S-333 PSR Short Form.

Pittsburg Operations agrees to update the S-333 PSR Checklist short form to include the MOC number.

08/31/19Per review, S-333 Pre-Startup Review (revised 9/28/18) provides the minimum requirements for doing a PSR (Pre-Startup Review) when changes to process or the facility using the MOC (management of change) or Global Project Methodology (GPM) work process. Per SME, the GPM is for new projects and the Dow Pittsburg facility has not built any new processes. There are processes in the pipeline that would use GPM but these projects are not going to be started for several years.

CCHMP reviewed section 02.01.01, titled Need for a PSR, of S-333. The PSR is required: "...for new facilities, changes that have potentially significant impact, modified facilities when change requires a change in PSI (process safety information), alterations or modifications that introduce new hazards, physical changes, or as determined by other policies and procedures.

In section 02.01.03, Team Members, the policy states that the audit team must include the change over or project manufacturing representative (or designee), safety representative (or designee), operations representative and/or other person affected by the change/modification, other as required (Industrial Hygiene, Engineering, Environmental, Tech center, maintenance, process safety, etc.)

Per review, S-333 PSR Short Form (revised 12/16/14) provides a Pre-Startup Review "...for a non-physical change or for minor physical changes at the discretion of the Change Owner, Subject Matter Reviewers and Final Approver."

CCHMP reviewed the following PSRs at Dow:-PSR Short form (dated 6/16/18) for MOC P660-2018020010

This was for adding Hastelloy C-276 in B-105 bottoms. Hastelloy C-276 was not part of the original materials list.

-Pre-Startup Review Checklist (dated 5/18/16) for MOC P660-2016040006 which was for installing H-7 (heat exchanger with design modifications)

This was the long form of the PSR which includes questions about MOC and PSR administration, PSI, Equipment, Operating Procedures, MI and Maintenance Procedures, Training. There are a list of action items on the form which would need to be completed either Before startup or after.

-PSR Short form (9/26/17) for MOC 56OP2017090007



This is a temporary MOC for replacing vent control valves R-600E and R-600F, AO-521 & 522 with valves outside of the pipe spec. The pipe spec is AI96 and the replacement valves line up with spec N5. This was due to a long lead time of about 28 weeks.

-Pre-Startup Review Checklist (dated 6/27/17) for MOC P660-201704001 which was for PT36643 Alpha LOPA Capital Gap Closure (Part 2 - FTA or fault tree analysis )

This was also the long form of the PSR. There were 13 action items from the PSR that needed to be closed either Before or After startup. All 13 action items were closed between June and December of 2017.

CCHMP reviewed several short PSR forms that did not have the MOC number on them, only the dates. Per live navigation with SME, CCHMP was able to determine that the PSRs were kept electronically in folders with the MOCs.



A18-01 Has the stationary source certified that they evaluated compliance with the provisions of this article at least every three years to verify that the procedures and practices developed under this chapter are adequate and are being followed? [T19 CCR §2760.8(a) & Section 450-8.016(a)(8)(A)]

Consider always using the certification statement template that includes CalARP in future certification

Pittsburg Operations agrees to develop a compliance audit certification statement template that includes the appropriate CalARP references.

06/30/20CCHMP reviewed 05.04.06 L1 Audits Policy and Requirements, this is an excerpt from the 05.00 Common Management System policy (Dow Corporate standard, rev. 05 Jan 09). Section B. specified that an audit schedule must be created or updated at least annually.

CCHMP reviewed Certification statements for:1) 310 and 560 block: date of audit 2/12-16, 2018, (signed 3/19-20/2018 by the auditor and 4/2/2018 by the production leaders) 2) 660 block: date of audit 4/11-15, 2016 (signed 4/15 and 6/30 by auditor and 12/6/2016 by production leader); date of audit 5/10/2013 (signed 5/10 and 7/15 by auditor and 7/18/2013 by production leader)3) 640 block: date of audit 2/19-23, 2018 (signed 2/23 and 3/1/2018 by the auditors and 3/1/2018 by the production leader); date of audit 3/23-27, 2015 (signed 4/6/2015 by auditors and production leader) 4) 520 block and site logistics: date of audit 5/8-12, 2017 (signed 5/18/2017 by auditor and production leader); date of audit 6/16-23, 2014 (sign 8/28/2014 by auditor and 8/29/2014 by Production Leader).

The certification statement for Block 660-2016, Block 640-2015 & 2018 and Block 520-2014 & 2017 states the operations were reviewed pursuant to CalARP Program CCR Title 19, Div. 2, Chapter 4.5 sec 2755.6 (a) and/or 2760.8 (a) and that "to the best of our information, knowledge and belief based on this review, the procedures and practices required to be developed under both the PSM standard and the RMP/CalARP rule, except for those concerns identified and discussed in the audit report findings, are adequate and being followed. The correction of any concerns identified and discussed in the audit report findings shall be documented by the plant".


CCHMP also reviewed the topics that were assessed during the compliance review, and noted there is not sufficient assessment on employee participation. Per discussion with EH&S delivery lead, auditors may use a combination of self assessment checklist, process Safety management compliance worksheet, interviews, etc. However, per CCHMP review of the self assessment checklist for ODMS 06.06.B3 'employee participation', it asks if employees participated in Health & Safety



activities. In the compliance worksheet, 5 questions were asked regarding having a written employee participation program including if the program include involvement/consultation of employees in PHA and other PSM. However, based on interview with SME, auditors are not required to use these checklists and in practice, employees do not have a mean to input to the development of prevention programs as these are developed by corporate SMEs. Employee participation is mainly assessing if there is a way to communicate safety concerns; describe employee's responsibilities to take action when safety concerns arise; and if employee have access to PHA and other information, etc. See additional discussion of audit topics and audit report in A18-03.



A18-04 Does/did the stationary source promptly determine and document an appropriate response to each of the findings of the compliance audit and complete the resolution of these findings within one and one half (1.5) years after performing the compliance audit or the next planned turnaround for items requiring a turnaround? [T19 CCR §2760.8(d) & Section 450-8.016(a)(8)(D)]

Consider including validation as part of the action item closure for non ISO facilities.

The Corteva Agrisciences Corrective and Preventative Action (CAPA) tool includes an optional verification functionality at the individual action item level. The system is designed such that an action item is not considered closed until the verification (if required for that action item) is completed. Currently, verification of individual action items is not required at the corporate level. Additionally, Pittsburg Operations is not requiring the use of the verification function at this time as well. However, the use of the verification function is being proposed to address findings in this audit related to Process Hazard Analysis and Compliance Audits. Refer to the applicable ENSURE action items. No further action is planned at this time.

08/31/19CCHMP reviewed 05.04.06 L1 Audits Policy and sec. C specified that deficiencies identified during each audit must be addressed in a timely fashion by the corrective and preventive action process.

CCHMP reviewed S-303 Corrective and Preventative Actions standard (rev. 5/17/2017). Sec 00.05 states the standard supports Dow Chemical Operating Discipline Management standard including ODMS 05.04.02 Corrective and Preventative Actions and ODMS 05.04.06 audits and external requirements including CalARP. Sec 02.02.03 specifies target dates for corrective actions from audits to be "within one and half (1.5) years of performing the compliance audit or next turnaround (if the action requires a turnaround), or a timetable approved by the CCHMP." Section 03.00 also specifies that "the Event and Action Tool (EAT) is the tool used to document corrective and preventative actions identified through incident investigations, audits, self assessments, and management system reviews.

Per the compliance audit dates of the other blocks (see details in A18-01), the resolution of the findings are not yet delinquent.

CCHMP also noted that 05.04,02 Corrective/Preventive Actions Policy, sec A.4 stated "each organization shall validate effectiveness of corrective and preventive actions." However, the policy only specified the timing to complete validation of an event to be within 6 months of completion" for facilities that claim compliance with ISO 9001, ISO/TS 16949 or other regulated product. It is CCHMP's position that the verification the action taken did address the deficiency is an important operating discipline. CCHMP notes that the block 660 compliance audit report was distributed in August 22, 2016 and the last action was completed 12/19/2017 for EAT 437366 but not validated as of the time of the audit. EAT 429803 for major non-conformance was validated



A18-07 Does the submitted RMP and Safety Plan accurately reflect the existing Compliance Audits Programs at the stationary source? [T19 CCR §2745.2(d) & Section 450-8.016]

Consider updating the compliance audit program to better reflect the current practice.

Pittsburg Operations agrees to review the compliance auditing process against the site's RMP description of the compliance audit element and update as appropriate.

The site’s RMP is due for its five year update and resubmittal in July 2019. The proposed changes will be included in that update. Specifying the location of the indicated changes is not possible at this time.

08/31/19CCHMP reviewed the RMP (7/14/2014), section I.D.3(g) on p. 22 that discuss the overall compliance audit program, it also stated "A senior representative from the Environmental, Health, and Safety function (EH&S) is assigned the role of audit team leader." Per review of the compliance audit report, this may or may not be the case. Update the RMP to better reflect the current practice.



A19-07 Does the incident investigation report include a description of the incident, including all of the data required under 2750.9(b)? [T19 CCR §2760.9(d) & Section 450-8.016(a)(9)(D)]

Consider consolidating the EH&S Incident Report and the associated Emergency Services and Security (ES&S) Log Book Report into the primary Process Safety and Containment Events database report to simplify the incident reporting and tracking the informational reports.

Pittsburg Operations will continue to use supplement reports to meet the regulatory requirements. This is the most efficient option currently available based on the location, ownership and management of the data being used to meet the regulatory requirements. No further action is planned at this time.

08/31/19CCHMP observed a live navigation of the facility's incident investigations electronic database, reviewed the printed summary of incidents described in A19-04, and reviewed the 14 select incident investigation reports identified as process safety evens and process safety near misses. Each incident included a description of the event. Of the incident investigation reports reviewed, three were found to be most significant (identified as Level 2 described in A19-04) and they included the following:

• Event 443205 Report: Release of 149.4 lbs. of anhydrous HCl from a compressor in Block 660 on 11/27/2016. • Event 443205 Report: Release of near 16 lbs. of chlorine and HCl due to a leak from a valve near a reactor in Block 560 on 3/21/2017. • Event 454402 Report: Release of near 33 lbs. of chlorine and HCl due to a leak from a control valve near a reactor (R-600F) in Block 560 on 9/22/2017.

The CalARP regulation was updated to require any qualifying incident that occurs on or after 1/1/15 to include the information listed in the clarification for this question within the incident investigation report. In reviewing the investigative reports for these three incidents, CCHMP confirmed that the required information is included either in the primary incident investigation database report or the additional information attached to the investigation report. Dow has developed additional Pittsburg site incident reports that were completed as Pittsburg site required reports that include EH&S Incident Report and the associated Emergency Services and Security (ES&S) Log Book Report. The EH&S Site Incident Reports include specific amounts of chemicals released, time and duration of the release, what part of the released quantity was contained and what part was released to air and any quantity that was released to dirt/ground/water or to the storm sewer, and initiating event and contributing factors if known any and operational or process changes that resulted from investigation of the release. The associated Emergency Services and Security (ES&S) Log Book Report includes information on weather conditions, if there were on site or off site impacts, and whether offsite responders were notified.



A20-03 Has the stationary source consulted with employees and their representatives on the development of the other elements of process safety management (other than PHA's)? [T19 CCR §2760.10(b) & Section 450-8.016(a)(3)]

Consider developing a policy for TAs to have a minimum process operating time and that the hours are documented.

Pittsburg Operations continues to believe that Technical Advisors (TA) and Multi-Purpose Operators (MPO) are employees that meet the intent of the Employee Participation requirement to have employees participate in Process Hazard Analysis (PHA). Pittsburg Operations agrees to develop a written policy to require that TAs and MPOs that participate in PHAs as employees (i.e. operators) have documented time operating the plant "on shift". The policy will also specify the minimum time required for TAs and MPOs to have operated the plant.

12/31/20CCHMP reviewed S-504 Employee Participation Safety Standard (revised 5/17/18) and identified employee participation roles for the prevention program elements:








Incident Investigation: Employees and contractors may report incidents and participate on the investigation (as appropriate) with the results being communicated via Learning Experience Reports (LERs) or the Event and Action Tool (EAT).




PHA: Employees with knowledge specific to the process participate as part of the PHA team. Additionally, PHA results and action plans are communicated to affected employees and all employees have access to the EAT which documents PHA results. CCHMP reviewed the RCPHAs in A12-16 and noted that all RCPHAs identified a Technical Advisor (TA) that was PSM Certified in the process being reviewed. The TA is considered a process knowledgeable person when conducting the RCPHA as they have had previous process operating experience.





A21-05 Does/did the contract owner or operator assure that each contract employee is trained in the work practices necessary to safely perform his or her job? [T19 CCR §2760.12(c)(1) & Section 450-8.016(a)(11)]

Consider providing a clear definition of the four contractor tiers that have been referenced in the Contractor Training Audit Procedure.

Consider limiting access to the Pittsburg site-level Indoctrination information.

Consider verifying that hard copies of the Block specific training indoctrination for contractors are not used to verify the plant specific indoctrination updates. Dow personnel should only use the ever green electronic copy.

Pittsburg Operations agrees to update the Contractor Training Audit Procedure to provide clearer definitions of the four tiers used to identify contractor training review requirements.

Pittsburg Operations agrees to discontinue the use of the local database for tracking site indoctrinations and limit its use for tracking the completion of department indoctrinations only.

Pittsburg Operations agrees to improve the work process for managing block specific indoctrination completion dates such that Operations personnel access the most current block specific indoctrination data.

03/31/20The contractor program SME conducts training audits of the contractors employees. These audits are targeted to contractor companies working in the covered processes such as contractors involved with mechanical repairs, insulation, painting, excavation, welding, water blasting, sand blasting, etc. Training audits are performed by the Dow SME by going to the contractor's office if local or remotely via web conferences. Typically the audit includes a review of the contractor Injury & Illness Prevention Program (IIPP), a review of experience in several key areas that the contractor works in and assessing quality of the training and training documentation to confirm that the required training has been done. SME maintains a coy of the training documentation for the individual training records reviewed in addition to an audit report that is completed for the audit per a preset template. These audits include a review of the critical core skills for select members of the contractor employees involved at the plant.

CCHMP reviewed the site procedures titled; "F4605, F4613 and F4614 Contractor Training Audit Procedure" dated 4/6/18 and "F4605, F4613 and F4614 Pittsburg Site Contractor Training Audit Program Schedule", not dated. Per a review of these procedures, the facility conducts training audits to verify that the contractor employees are receiving the appropriate training to safely perform their job. Per interview with the SME, the contractors that are working or may work on or near the covered process consist of four tiers as follows:

- Tier 1 Contractors: These contractors work onsite and in the covered process most of their time (about 90% of their time). These include contractors doing welding, grinding, pipe fitting, etc. There are currently 12 contractor companies in this category with about 150 contract employees.- Tier 2 Contractors: These contractors work onsite and in the covered process a few months of the year. There are currently 12 contractors in this category with about 50 contract employees.- Tier 3 Contractors: These contractors are here occasionally, may be a few weeks a year. There are currently about 5 contractors that are categorized in this tier.- Tier 4 Contractors: These are the contractors that may work here in the covered process for specific tasks. There are currently about 120 contractors in this tier.

CCHMP reviewed the Contractor Training Audit Procedure and as confirmed by interview, the procedure only provides a limited definition of the four contractor tiers and it should be updated consistent with SME interview definitions provided above and the latest improvements on these definitions.



Per interview with the SME, the facility audits contractors according to the following schedule:- Tier 1 Contractor: Every 3 years (12 contractors audited, once every quarter)- Tier 2 Contractors: Every 4 years (12 contractors audited, once every 4 months)- Tier 3 Contractors: Every 5 years (5 contractors audited, once every year)- Tier 4 contractors: Only audited when chosen to work onsite before coming on site to work.

CCHMP requested an operator for a Pittsburg "site" safety indoctrination for a contractor and the operator checked the electronic data available at the Block control room that showed the update was not done. However, a follow-up review by EH&S Department indicated that the contractor had actually completed the annually updated Pittsburg site indoctrination that is conducted at OSCA, an outside training facility. CCHMP recommends that the site limits access to site indoctrination information which is based on OSCA evergreen electronic copy used for confirmation of the annual site indoctrinations.

When conducting operations interviews, CCHMP requested an operator for checking a contractor for having the Block indoctrination and noted that the hard copy of the list that was available was not up to date. CCHMP also recommends that hard copies of the Block specific training indoctrination for contractors are not used to verify the Block specific indoctrination updates. Dow personnel should only use the ever green electronic copy.

CCHMP reviewed five contractor training audit reports that were completed in the past six quarters since the updated contractor program has been in place. The training audit were all documented in a report and included several sections including the following:- Pittsburg site contractor training audit checklist- Contractor Audit Report- Contractor Safety Programs- Jobsite Safety Analysis (JSAs)- Training summaries and samples of tests conducted on training related to the work the contractor conducts at Dow.



S03-10 Does the stationary source document hazardous energy control procedures, which include separate procedural steps for the safe lockout/tagout of each machine or piece of equipment affected by the hazardous energy control procedure? [T19 CCR §2760.3(d)] [T8 CCR §3314(g)]

Consider using graphics to identify isolation points in the Location Listing of isolation procedures.

Operating procedures, including isolation procedures, are written and maintained (i.e. periodically reviewed and updated as needed) by the Operating Technicians that use them. As such, if the Operating Technicians felt that including graphics to identify isolation points was beneficial it would be included in that specific procedure. Therefore, Pittsburg Operations does not believe that using graphics to identify isolation points in the location listing of isolation procedures will provide any significant benefit to the users. No further action will be taken at this time.

08/31/19CCHMP reviewed the following sampling of isolation procedures:- AI-253W Isolation Procedure (revised 8/24/17)- B-155 Isolation LEO Procedure (revised 7/1/16)- B-1 Isolation and Draining Procedure (revised 7/26/17)- H-301 PSV #7553 Draining/Isolation LEO Procedure (revised 11/3/13)- 2,3 Penta Load Hose Isolation Procedure (revised 7/16/18)- P-3080 Pump Isolation LEO Procedure (revised 8/23/16)- P-503B Isolation Procedure (revised 7/21/18)- P501A&B Isolation LEO Procedure (revised 5/7/18)

The above procedures identified the steps required to properly isolate and tag the equipment by referencing the appropriate RTM Form.

CCHMP recommends the use of graphics in the Location Listing to identify isolation points as part of the isolation process to act as a training tool or provide additional clarity in isolation jobs.


Documents

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