DEQ-CFW_00065731

NORTH CAROLINA DIVISION OF
AIR QUALITY
Inspection Report
Date: 01 /27/2012
- Facility Data
DuPont Company - Fayetteville Works
22828 NC Highway 87 West
Fayetteville, NC 28302
Lat: 34d 50.6000m Long: 78d 50.2930m
SIC: 3081 / Unsupported Plastics Film And Sheet
NAICS: 326113 / Unlaminated Plastics Film and Sheet (except Packaging)
Manufacturing
Contact Data
Facility Contact 11 Authorized Contact
Michael Johnson Ellis McGaughy
Environmental Manager Plant Manager
[phone] [phone]
Inspector's Signature:
d
Date of Signature: 3 ; ,-
Technical Contact
Michael Johnson
Environmental Manager
[phone]
Comments:
19
Fayetteville Regional Office
DuPont Company - Fayetteville Works
NC Facility ID 0900009
County/FIPS: Bladen/017
Compliance -Data -
Inspection Date 01/23/2012
Inspector's Name Gregory Reeves
Operating Status Operating
Compliance Code Compliance - inspection
Action Code PCE
On -Site Inspection Result Compliance
Permit Data
Permit 03735 / T37
Issued 8/17/2011
Expires 1/31/2015
Classification Title V
Permit Status Active
1. DIRECTIONS TO SITE: Dupont Company - Fayetteville Works is located on NC Highway 87 in Bladen County.
From FRO, take Highway 87 South. The entrance to the facility is approximately 18 miles from FRO on the left
side of Highway 87 just before the Cumberland/Bladen County line.
2. SAFETY CONSIDERATIONS: The usual FRO safety gear is required (hardhat, safety glasses, safety shoes,
hearing protection). Entry into several areas of the plant require specialized safety gear. In the Nafion® reactor
area, personnel are not allowed to enter unless the process is not operating due to the safety hazards of the chemical
reaction process.
FACILITY DESCRIPTION: Dupont Company - Fayetteville Works is a chemical manufacturing facility located
in Bladen County. The facility employs approximately 500 employees and 250 full-time contractors on a 24 hr, 7
day per week basis. DuPont Fayetteville consists of six individual manufacturing plants, a boiler house and a waste
treatment operation. Several processes have PSD avoidance conditions. The facility has two permanent boilers
onsite, one permanent boiler which is permitted but not yet constructed, as well as one permitted temporary boiler.
The facility is subject to 40 CFR Part 68 for having a regulated substance above a threshold quantity in a regulated
process. The owner or operator of the facility submitted a summary of its Risk Management Program to EPA. In
response, EPA issued Facility Identifier number 1000 0002 8178 for the facility's Risk Management Plan (RMP).
The facility 112(r) coordinator is Joel Blake (910-678-1285).
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0
DuPont
I I2(r) Inspection Report
01 /23 /2012
Page 2 of 9
The owner or operator of the facility reported in the RMP four (4) processes subject to 40 CFR Part'68. These are:
Quantity of Chemical
Program
lbs
Level
TFEProcess - ---
- -- TetF fluoroetylene-
APFO Manufacturing
Oleum (fuming Sulfuric Acid)
50,000
3
Polyvinyl Fluoride (PVF)
Manufacturing
Vinyl Fluoride
130,000
1
Naflon® Manufacturing
Sulfur Trioxide
33,000
3
4. PROCESS DESCRIPTION: The APFO process at the DuPont facility combines 65% Oleum, a process catalyst,
and a.fluoro telemer (very small chain fluoro polymer) in a heated reactor to produce Perfluoro Octanoic Acid
(PFOA). This intermediate chemical is further reacted with additional chemicals to produce the ammonium salt,
Ammonium Perfluoro Octanoate (APFO, also known as C8). This chemical is a surfactant that is essential to the
production of Teflon KO. The DuPont Fayetteville Works is the only facility within the DuPont worldwide
organization that produces this chemical. This chemical is in the process of being discontinued in Teflon®
production. This necessitates a completely different production process for Teflon® production. The DuPont
Fayetteville Works is in the process of testing production of the replacement chemical for C8, using the existing
equipment in the facility.
65% Oleum is received at the facility in 30,000 lb tank trailers. It is pumped to the Oleum Storage Tank located
inside a temperature controlled, heated room which is maintained at a temperature of between 95-105°F (both oleum
and S03 freeze at approximately 33°C, or 91 OF). Displaced vapors from the Oleum Storage Tank are vented back to
the trailer. APFO production is done in batch mode. For each batch, approximately 2,000 lbs of Oleum is
transferred to the reactor vessel, along with the correct proportions of telomer and catalyst. The mixture is agitated
and heated (the reaction is endothermic) until all the telomer is reacted, which requires an excess of Oleum. After
the intermediate PFOA is formed, two separate phases are formed in the reactor - one with the PFOA, and one with
the remainder of the spent Oleum solution. The spent Oleum phase is drained into the Waste Acid Separator Tank.
The PFOA phase is pumped to the distillation process for further processing. Spent Oleum is either pumped back to
the process reactor, or is removed from the process to the Oleum Dilution Tank, where it is (carefully) diluted with
water to form 35% sulfuric acid, which is removed from the facility. The intermediate PFOA is then further
processed to produce the ammonium salt, APFO. Other parts of the APFO process are not subject to the 112(r)
program.
Note that DuPont expects to eliminate the usage of APFO in their plants in 2013, and will thus eliminate the use of
oleum. This will necessitate decertification of this process with EPA.
5. INSPECTION SUMMARY: On Monday 01/23/11, Mike Reid of RCO and I, Greg Reeves of FRO, visited the
DuPont facility to conduct a 112(r) RMP inspection. We met with Joel Blake, the facility 112(r) coordinator. We
stated our purpose to conduct a 112(r) inspection. Based on the RMP's hazard assessment for the facility, we chose
to focus the inspection the Ammonium Perfluorooctanoate (APFO) process. Oleum, commonly referred to as
fuming sulfuric acid, is a 112(r) regulated substance, and is a mixture of S03 and undiluted sulfuric acid, with
various percentages of S03 depending on the process. The APFO process at this facility utilizes 65% oleum, which
is 65% S03 and 35% sulfuric acid. We met in a conference room in the APFO facility offices to discuss the RMP,
Process Safety, and other items on the 112r checklist. Personnel involved in the meeting were: Joel Blake, the
facility 112(r) coordinator, Rick Movius, technical engineer, Charles Rogers, area manager, Ricky Martin, site Fire
Marshall, Herb Hancock, Eddie Rouse, and Ricky Goodman, involved with maintenance and mechanical integrity,
Dwayne Emanuel, training coordinator, Peter Leonard, site Safety, Health, and Environmental manager, Mark Cluff,
Fluoroproducts Unit Manager, James McCathern, Fluoroproducts Area Superintendent, and Kristen Grant, technical
engineer. While on the facility tour, we also met with and spoke with Terry Williams, the process control room
operator.
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DuPont
112(r) Inspection Report
01/23/2012
Page 3 of 9
6. COMPLIANCE DETERMINATION:
i. SUBPART A — GENERAL INFORMATION
Verified general facility information contained in the latest RMP submittal to EPA (submitted August 29,
2007). The facility is subject to the OSHA Process Safety Management (PSM) program. The APFO process is
designated as a LEVEL 3 program due to its potential to impact public receptors and because the process is also
subject to OSHA PSM requirements.
ii. SUBPART B — HAZARD ASSESSMENT
The facility has addressed worst -case scenario, alternative release scenario, and reported their 5-year accident
history within the latest RMP submittal. The facility has had no record of accident releases in the past 5 years.
iii. SUBPART C — PREVENTION PROGRAM FOR PROGRAM 2 FACILITIES
The APFO process is designated as a Level 3 program, and is not subject to this section of the RMP review.
iv. SUBPART D — PREVENTION PROGRAM FOR PROGRAM 3 FACILITIES
I. Process Safety Information [§68.65]
Note: the facility uses ASTM, API, ASME, and DuPont internal guidelines for maintenance and
inspection guidelines.
a. MSDS for all regulated substances
.APPEARS IN COMPLIANCE — the MSDS for Oleum was readily available
b. Flow/Block diagram of process
APPEARS IN COMPLIANCE— the process block flow diagrams were produced and discussed
c. Process Chemistry
APPEARS IN COMPLIANCE — the chemistry of the process was readily available, and chemical
formulas were shown to us
d. Maximum intended inventory of regulated substances
APPEARS IN COMPLIANCE — the maximum intended inventory, according to the latest RMP
submittal, is 50,000 lbs
e. Safe upper and lower temperatures, pressures, flows, and compositions
APPEARS IN COMPLIANCE — personnel were able to show a large amount of data which
documents their analysis of all process parameters
f. Evaluation of consequence of deviation from limits
APPEARS IN COMPLIANCE — personnel showed documentation of extensive evaluation of
consequences of deviation from process parameter limits, including temperature, pressure, process
level, flowrates, etc
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DuPont
112(r) Inspection Report
01 /23/2012
Page 4 of 9
g. Material of construction for equipment in process
APPEARS IN COMPLIANCE — personnel were able to show us the materials of construction of
all process equipment and piping, as well as discuss the corrosion properties of all materials in the
process
h. Piping and instrumentation diagram (P&IDs)
APPEARS IN COMPLIANCE— detailed P&IDs were available for reviewed processes and
equipment
i. Electrical classification
APPEARS IN COMPLIANCE— personnel were able to show the electrical classifications for
reviewed areas in the facility
j. Relief valve design and design basis
APPEARS IN COMPLIANCE — personnel showed us detailed information and forms concerning
the design and design basis for a random choice of equipment from the P&IDs. The information
was very comprehensive
k. Ventilation system design
APPEARS IN COMPLIANCE — personnel were able to show us the design criteria for ventilation
in the Oleum Storage Tank area
1. Design codes and standards employed
APPEARS LV COMPLIANCE — drawings and documents show that a number of standards are
used, including ASME, ASTM, API, and internal DuPont standards of performance and
fabrication
m. Material and energy balances (for sources constructed after June 21, 1999)
APPEARS IN COMPLIANCE — there was extensive information available about processes,
including material and energy balances
n. Safety Systems (interlocks, suppression, and/or detection)
APPEARS IN COMPLIANCE — personnel discussed various safety systems, including shutdown
interlocks in the process, emergency shutdown devices and controls, and detection systems
including smoke detectors in the Oleum Storage Tank area.
o. Process equipment complies with generally accepted good engineering practices, state and federal
design rules
APPEARS INCOMPLIANCE — many standards appear to be taken into account for design and
operation of this facility. Appears to meet the requirements in all areas
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DuPont
112(r) Inspection Report
01 /23/2012
Page 5 of 9
2. PROCESS HAZARD ANALYSIS [§68.69]
a. Identify hazards associated with process
APPEARS IN COMPLIANCE —The last PHA was completed -December -19, 2007. Prior to that, --
a PHA was completed in 2002. Plans are in place to complete a new PHA during this spring 2012.
b. Process meets all state and federal design rules or industry standards if applicable
.APPEARS IN COMPLIANCE — numerous standards are used in development of the process and
evaluation of process hazards, including ASTM, ASME, API, and internal DuPont standards
c. Results of analysis documented and problems resolved
APPEARS IN COMPLIANCE— the analysis from 2007 documented a few minor issues.
Records were reviewed which documented the systematic analysis and resolution of these issues.
d. Review updated every 5 years
APPEARS IN COMPLIANCE — records showed reviews in 2002 and 2007, with the next review
scheduled for spring 2012.
3, OPERATING PROCEDURES [§68.69]
a. Written operating procedures for each covered process as required by §68.69
APPEARS IN COMPLIANCE — there are extensive operating procedures for each process in this
facility
b. SOPs updated whenever major change occurs and prior to startup of the changed process
APPEARS IN COMPLIANCE — Management of Change (MOC) and Pre -Startup Safety Review
(PSSR) forms are documented electronically. Any change requires a number of reviews and
approvals by various plant personnel, including process operators, safety, environmental,
engineering, maintenance, and plant management.
c. SOPs for maintenance activities, including lockout/tagout, confined space entry, opening process
equipment and piping, and other activities
APPEARS IN COMPLIANCE — There are numerous procedures, forms, and approvals required
for various activities, including lockout/tagout, unloading of chemicals, electrical hot work,
cutting/welding hotwork, confined space entry, and others. Many of these are corporate -wide
requirements
4. TRAINING [§68.71]
a. Documentation of proper employee training, including initial and refresher training a minimum of
every three years on process and emergency response if applicable
APPEARS IN COMPLIANCE — there is extensive electronic documentation for training of each
individual on site, including scans of meeting and training materials showing employee signoff
DEQ-CFW 00065735

DuPont
112(r) Inspection Report
01/23/2012
Page 6 of 9
b. Operators are trained in new procedures prior to startup of a process after a major change (Emp
Interview)
APPEARS IN COMPLIANCE — we spoke with a number of the employees, including Terry
- - -- -
Williams, who is the control -room operator in -this facility: He verified -that whenever any changes
are made, he is trained and informed of the new procedures, processes, and hazards.
5. MECHANICAL INTEGRITY
a. SOPs for insuring mechanical integrity
APPEARSINCOMPLIANCE —There is extensive information available on the electronic
records documenting inspections, maintenance, and procedures for numerous tasks performed in
the plant, including normal repairs, ultrasonic thickness (UT) testing of vessels and piping, etc.
Documentation of repairs, work orders, problems found and solutions are readily available.
b. Employee training for process maintenance activities
APPEARS IN COMPLIANCE — There are extensive records of employee training in all aspects
of the operation, including maintenance activities
c. Inspection and testing on process equipment, pressure vessels and storage tanks, piping systems,
relief valves and vent systems, emergency shutdown systems
APPEARS IN COMPLIANCE — there are extensive records documenting various methods of
inspection and testing, including ultrasonic thickness (UT) testing of piping, tanks, and process
vessels, which is used in predictive maintenance activities and setting maintenance frequency.
d. Inspection and testing follow recognized and generally accepted good engineering practices
APPEARS IN COMPLIANCE — the facility utilizes a number of resources to determine how
items are maintained, including recommendation from the equipment manufacturers, ASME,
ASTM, API, internal DuPont standards, and others
e. Frequency of testing and inspections consistent with manufacturer's recommendations and good
engineering practices
APPEARS IN COMPLIANCE — numerous sources are used to determine frequency of testing,
inspection, and maintenance, including predictive maintenance intervals based on corrosion rates
determined using ultrasonic testing (UT) of piping, tanks, and vessels
6. MANAGEMENT OF CHANGE [§68.73]
a. Procedures that document basis for change, impact on health and safety, and modifications to
SOPs before change implemented.
APPEARS IN COMPLIANCE — there is extensive electronic documentation of the reviews of
changes made, including the basis for the change, benefits to be derived, the safety hazards
involved, and other factors
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DuPont
112(r) Inspection Report
01/23/2012
Page 7 of 9
b. Employees aware of change and trained in new SOPS.
APPEARS IN COMPLIANCE - Electronic documents and employee interviews confirmed that
e 'l OrrYTat1 c v I crrrigatl
made - - - - - - - -- -
c. Employees and contractors involved in potential changes that may affect their job tasks
APPEARS IN COMPLIANCE - We did not interview contractor personnel. However,
employees stated that contactor personnel were involved whenever changes were made
7. PRE -STARTUP REVIEW [§68.75]
a. Construction and equipment in accordance with design specifications
APPEARS IN COMPLIANCE - documentation showed that there are numerous reviews of
construction, equipment, procedures, safety hazards, etc prior to startup of any changes
b. Safety, operating, maintenance, and emergency procedures are in place
APPEARS IN COMPLIANCE - electronic documentation shows that there are extensive safety,
operating, maintenance and emergency procedures for this process.
c. Process hazard analysis conducted with recommendations and resolutions
APPEARS IN COMPLIANCE - the last PHA was completed in December 2007. Next scheduled
PHA is due to be completed in spring 2012. Recommendations and resolutions were included in
the last PHA, with documentation and signoff on resolutions to findings
d. Employees trained in new process(es)
APPEARS IN COMPLIANCE - it appears that there is extensive training of the workforce at this
site, with electronic documentation of it all. Records were easily produced for training for a
couple of randomly selected employees.
8. COMPLIANCE AUDITS [§68.79]
a. Owner/operator certified that they have evaluated compliance once every three years by person
knowledgeable of process
APPEARS IN COMPLIANCE - Compliance audits are done by two groups of people -
Fayetteville personnel, and corporate audit teams. Each is done on a 3-year rotation, with
approximately 18 months between the plant team audit and the corporate team audit, which results
in 2 complete audits every 3 years. The audit teams are composed of highly skilled and
knowledgeable personnel
b. Documentation of audit findings and response
APPEARS IN COMPLIANCE - documentation of audits is kept electronically, and is readily
available.
c. Two most recent compliance audits retained
APPEARS IN COMPLIANCE - these were readily available in the electronic records system
DEQ-CFW 00065737

DuPont
112(r) Inspection Report:
01/23/2012
Page 8 of 9
9. INCIDENT INVESTIGATIONS [§68.81]
a. Accidents with or potential for catastrophic releases have been investigated within 48 hours
-- _ -- - _ following incident -
APPEARS IN COMPLIANCE — there have been no incidents that appear to have the potential for
a catastrophic release. However, incident investigations were available for review for even the
smallest of leaks involving Oleum.
b. Findings documented, reviewed with employees, and retained for 5 years
APPEARS IN COMPLIANCE — all records are available electronically, and are very extensive
10. EMPLOYEE PARTICIPATION [§68.83]
a. Owner/operator has written plan for employee participation
APPEARS IN COMPLIANCE — there is an extensive plan in place
b. Employees aware of risk management program, hazard analyses, and process safety management
APPEARS IN COMPLIANCE— it appears all employees are heavily involved and trained
concerning this program
11. HOT WORK PERMITS
a. Hot work permits issued for work near or in affected processes
APPEARS IN COMPLIANCE — hot work permits are required both for electrical maintenance
and for cutting/welding maintenance
12. CONTRACTORS [§68.85]
a. Contractors informed of potential fire hazard and/or toxic release hazard associated with affected
processes
APPEARS IN COMPLIANCE — The facility has a number of full-time contract maintenance
employees from Fluor who help maintain the facility. These contractors receive the same training
and indoctrination that the DuPont employees receive. Most of these have been at the plant for a
number of years. Other contractors doing sporadic maintenance activities receive training specific
to the hazards they will encounter in their particular work
b. Contractors aware of emergency action plan
APPEARS IN COMPLIANCE — these contractors receive the same training as Dupont
employees, and are informed of the details of the emergency action plan, including evacuation
procedures
c. Owner/operator developed procedures for control of contractors in to and out of affected processes
APPEARS IN COMPLIANCE — all contractors and employees are tracked with electronic card
keys, which expire every 3 years and must be renewed including relevant training. Access to all
areas is controlled by these card keys.
DEQ-CFW 00065738

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112(r) Inspection Report
01/23/2012
Page 9 of 9
v. SUBPART E — EMERGENCY RESPONSE PROGRAM
ac�l� y coor ma e w� ire epa men , or o er oca agencies
APPEARS IN COMPLIANCE — Joel B lake, our contact at DuPont, was the director of the
Cumberland County LEPC and is heavily involved with the Bladen County LEPC, which is just now
getting organized. Several other personnel on site are also involved with Bladen County LEPC or
local fire departments.
2. Facility has Emergency Response Plan (if appropriate)
APPEARS IN COMPLIANCE — the facility has a documented emergency response plan
3. Employees are aware of Emergency Response Plan
APPEARS IN COMPLIANCE — the operators and other people involved with this audit were all
aware of the Emergency Response Plan and their role in it.
4. Is facility included in community emergency response plan?
APPEARS IN COMPLIANCE — The local LEPC is just now getting organized and details of
operation being determined. Local fire departments and Cumberland County LEPC are possible
contacts here.
7. CONCLUSIONS AND RECOMMENDATIONS
During our inspection of this facility, DuPont Fayetteville Works APPEARS IN COMPLIANCE with the
requirements of the 112(r) program.
Note that the facility will be decommissioning the APFO production in 2013 and replacing it with another
chemical process. The facility RMP will need to be revised and resubmitted to EPA at that time, or the facility
decertified if it no longer is subject to 112(r) requirements.
DEQ-CFW 00065739

North Carolina Division of Air Quality 112(r) Inspection Checklist - 40 CFR Part 68 DAQ, _
- - - - - - -
--
__--- od n ineerin ractices:`state and federal:desi n rules recommendations and resolutions.
Flrt} - - - - -- - -_
Mailing Address:' ,a>� as required by 6$.52 d. Employees trained in new process(es)
b. ( ) SOPS updated whenever major change occurs d prior 2. PROCESS HAZARD ANALYSIS - 68.67
Physical Address: to startup of the; changed': process a. ( Identify hazards associated wit process S. C PLIANCE AUDITS - 68.79
Y
b "( ' Process meets alhstate and federal design rules or a. (Omer/operator certified that they have evaluated
Count c 4. TRAINING - 68.54 . ndustry standards if applicable (See Reference Card) compliance once every three years by person
y ..
a. Documentation of " ro per employee fining, including c. ( 'Results ofanalysis documented and problems resolved nowledgeable of process
Premise Nod (if applicable ( ) p p. _ p
Phone Number: l initial and refresher training a min' um of every three zd. ( . Review updated every 5 years b: { Documentation of audit Endings and response
Facility Contact: years on process an emergency esponse _if applicable c. ( j Two;most recent compliance audit reports retained
y
0 tional: E-mail address_: b. ( )'Operators are;trained in new 'ocedures prior to startup 3. OP RATING PROCEDURES- 68:69 -
p ;. -
of a rocess after a ma or c ge`(Emp Interview) : a. ( Written operating procedures;for.eash covered process . 9.4NCIDENT INVESTIGATIONS - 68,81
Optional Websate address: P J ..
S required by 6$.69 a: ( Accidents with or potential for catastrophic releases
r
Is facility sub ect to OSHA PSM? or N S. MAINTENANCE _= 68,56 b. ( SOPS updated whenever major change occurs and priorhave :been investigated within 4:8 hours following
ty J
_ a. ( ) SOPS for ensuring m hanical integrity to s#artup of the changed process incident
ee trained r rocess maintenance activities c. SOPS for maintenance ac ivities, includm b: ( Findings documented; xeviewed with employees, and
What is/are the process program'level(s). s b. O ErnploY s p, ( g
c. ( )Contractors train for process maintenance activities loct�out/tagout, confined space entry; opening process .retained for five years'
Is facility using administrative controls? Y or;f d. ( )Inspection and Ling onprocess equiprrient equipmentand piping, and other, activities
10 E PLOYEE PARTICIPATION - 68.83
Are administrative controls document nd followed 6. COMPLIANC AUDITS = 68.58 4. T WING - 68.71 a. ( Owner/operator has written plan for employee .
a. Owner/ rator certifedthat the have evaluated a. Documentation of pro er employee training, including participation
properly,'. Y or N O P Y ( )� . p
complia e once every three years by person mttial `and -refresher training a minimum of every three b.-(Employees aware of risk in program; hazard
Has the facility met requirements for the man menf system knowl geable of process years on process and emergency response if applicable analyses, and process safety management
specified in 40 CFR §68.15? or N b. ( ) Doc entation .of audit findings and response b. Operators are trained in new procedures prior to startup
See Reference Card) c. ( ) Tw most recent compliance audit reports retained of a process after a major change (Emp Interview) 11.;HOT WORK PERMITS - 68.85
( 1 a. ( Hot work permits issued for work near or in affected
SUB ART B -HAZARD ASSESSMENT 7. INC ENT INVESTIGATIONS = 68.60 5. MECHANICAL INTEGRITY - 68.73 process(es)
a. ( Worst case scenarios) a. ( )Accidents with or potential for catastrophic releases a. ( OPs for, ensuring mechanical integrity
b. Alternative release scenarios have been investigated within 48 hours following : b. mployee training for process maintenance activities 12. ONTRACTORS - 6887
c (>
C. Five- ear accident histor Facili ma show do incident c.=Inspection`,and testing on process equipment, pressure a. Contractors informed of potential fire hazard and/or
Y Y( n Y -
_ b ) Findings documented, reviewed with employees, and vessels and storage tanks, piping systems, relief valves toxic release hazard associated with affected process(es)
accidents; on=site and off site history should be
documented) (See Reference Card) retained'for Eve years and vent systems, emergency shutdown systems, b.� Contractors aware of emergency action plan
controls, monitoring devices; alarms, and pumps c. V�> Owner/operator developed procedures for control of
SUBPART C -PREVENTION PROGRAM FOR SUBPART D -PREVENTION PROGRAM FOR d. Inspection and testing follow recognized and generally contractors in to and out ofaffected process(es)
PRO GRAM 2 FACILITLES check to ensure that the PROGRAM 3 FACILITIES (check to ensure that the accepted good engineering practices
documented and updated) following are documented and updated): e. X.? Frequency of testing'and inspections consistent with SUPBART E - EMERGENCY ZtESPONSE
following are P ) 1. P OCESS SAFETY INFORMATION - 68.65 / manufacturer's recommendations and good engineering PROGRAM (See Reference Card)
1, PROCESS SAFETY INFORMATION 68.0
a. ( ) MSDS for all regulated substancesa. ( IvISDS for all. regulated substances p a. (7Facility coordinated with LEPC, fire department, or
/ practices
b. ( ) Maximum -intended inventory of r ated substances. b.-Flow/block diagram of process(es) other local agencies
Safe upper and lowertem era es ressures Tows c. ,Process chemistry 6. MANAGEMENT OF CHANGE - 68.15 b. ( Facility has Emergency Response Plan (if appropriate)
c' �) pp p P a. Procedures :that document basis for. change,. im act on
and •coin ositions d. Maximum intended inventory of regulated substances g P C. (;r'j Employees are aware of Emergency Response Plan
p ` health and safe and modifcations.to SOPS before t'
E ui ; men# s ecifi.catio ( _p - p p
d O q p p e. Safe,up er and lower tem eratures, ressures, flows, ty, (determine through employee in- terviews)
. sed to design, build and operate and compositions change implemented d. (' Is facilityincluded in community emergency response
e. ( ) Codes and standard g , p
0 the f. ( "Evaluation of consequence of deviation from limits b. ( En ployees.aware of change and trained in new SOPS plan?' (Program 2 and 3 facilities)
process
m g. ( Material construction for equipment in process c, ( Employees and contractor involved in potential changes
p Are generally accep and good engineering practices affect their ob Masks .Em Interview with all the
n followed? Y or N h. iping and instrumentation diagram (P&IDS) that may f • J ( p ) Does facility have a Risk Management Pro
is leetrieal classification : required elements? ror N
L. PROCE HAZARD REVIEW 68.50 J. ( Relief system design and design basis 7. PRE -STARTUP REVIEW - 68.77 (for new and modified (See .Reference Card)
�o Id i hazards associated with rocess k. Ventilation system design proce s(es))
0 3 (� p 1. y Design, codes and standards em to ed a. ( Construction and equipment in accordance with design Inspector's Name: t
o �. O P - cess meets all state and federal design rules or N g p y -.,'
rn specifications
En n ustry standards if applicable (See Reference Card) m: (' aterial and energy balances (for sources constructed,,
/ fter June 21, 1999 b. (; `Safety, operating, maintenance, and emergency Signature: �'` � _ Date,,
I2�ults of review documented and problems resolved . )
o n. Safe systems interlocks, suppression, an r procedures are in place e
1. ( Re iew updated every 5 years ( Safety Y ( PP
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DEQ-CFW 00065741

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DEQ-CFW 00065742

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DEQ-CFW 00065743