Dow’s New Practice for Locating Temporary Portable Buildings

P. Partridge 9/29/05 UNRESTRICTED - May be shared with anyone Slide 1

Dow’s New Practice for Locating Temporary Portable Buildings

P. Partridge 9/29/05 UNRESTRICTED - May be shared with anyone

Dow guidelines issued following the explosion at BP’s Texas City facility on

March 23, 2005


DisclaimerThis presentation contains guidelines intended for use by Dow employees, in Dow facilities. Dow has compiled the information in this presentation as a part of an effort by its employees to collect and share their experience and expertise in safety, loss prevention and security. The contributors to this presentation believe the information provided is accurate, and they have provided this information in good faith.However, no warranty, express or implied, is given by Dow. When used by other than Dow employees, or other than in Dow facilities, those who use this presentation should use their independent judgment in evaluating information contained herein, and assume the risk for using the information. The user is solely responsible for compliance with applicable governmental requirements. References to "Dow" mean The Dow Chemical Company and its consolidated subsidiaries unless otherwise expressly noted.


• Implement “Portable Building Best Practice” document for location of portable buildings, and portable building MOC template.– A international team, including representatives from DDC,

Maintenance, Process Safety, Personal Safety, and EH&S Responsible Care Leaders worked together to compile the LearningEvent Report and Best Practice documents.

Dow Actions following BP Incident


Dow Portable Building Best Practices

• A portable building Management of Change (MOC) should be completed before any portable building is placed. It should be modified to meet local requirements.



• Except as provided below, temporary portable buildings or modular office buildings should not be placed within the distances shown in Table 1 or Table 2. – Instead of using the distances in Table 1,

calculated distances can be used.


Recommended Distances for Portable Buildings – Table 1

250 ft (80 m)

700 ft (215 m)

High e.g. ethylene, ethylene oxide,

propylene oxide (see LPP 12.2 for list)

60 ft (20 m)

200 ft ( 60 m)

Medium e.g. pentane, hexane , most

hydrocarbons

Use Table 2 distance (see Best Practice)

Use Table 2 distance (see Best Practice)

Low e.g. methane, ammonia, some

chlorinated organics

High Strength Portable Building (HSPB)

Distance*

Typical Portable Building Distance*

Fuel Reactivity

* Default spacing from process structure to nearest wall of building.



1 9 ft (3 m) of the centerline of a railroad track

2 20 ft (6 m) of a fire hydrant

3 15 ft (5 m) of a process sump or trench

4 25 ft (8 m) of uninsulated overhead power lines exceeding 13.8 kV

5 A Restricted or Flammable Area as defined in Dow Global Safety Standard 06.05.C.09 Hot Work Standard or Hazardous Classified Locations (see LPP 3.1)

6 15 ft (5 m) of a perimeter fence

7 25 ft (8 m) of a LPP 3.7 defined oil-filled transformer

8 25 ft (8 m) of a process pipeline containing flammable liquids or gases (pipelines for fuel to building heating not included)

building shall not be located within



building shall not be located within9

Distance to the following tanks or containers (The below distances can be reduced based on risk analysis using F&EI or LPP 12.2 tools. Contact your Process Safety Technology Center Leader for guidance.) :

Typical Flammable and Combustible Liquids and Liquefied Flammable Gases Spacing to Portable Buildings for Fire Consequences4

Category Capacity Distance to Edge of Building from

Tank Dike

< 10,000 gal (38 m3) 50 ft (15 m)

Atmospheric and low pressure storage – including refrigerated flammable storage (up to 15 psig or 1 atm)

> 10,000 gal (38 m3) 250 ft (76 m)

< 500 lb (227 kg) total storage 25 ft (8 m)

> 500 lb (227 kg) to 1 ton (907 kg) total storage

100 ft (30 m)

Pressurized storage (also portable containers) – pressurized flammable gases (e.g., LPG) [For railcars, see “Applicability” section.]

1 to 5 ton (907 to 4535 kg) total storage

250 ft (76 m)

Other vessels with larger flammable quantities

Contact your business Process Safety Technology Center Leader for guidance.



• Temporary portable buildings may be placed within the Table 1 distances if they are unoccupied (i.e., do not meet the definition of “occupied”) whenever the process area contains chemicals which under certain conditions have the potential to produce a vapor cloud explosion, fire, or toxic release.



• Tool trailers, supply trailers, or stack sampling trailers occupied by no more than one assigned occupant can be located within the Table 1 distance if administrative controls ensure that no one enters the trailers during operations such as starting up, shutting down, periods when flammables are being added to the process, process upsets, and other periods of particular process hazard concern.



• Occupied Portable Building – For the purposes of this document, a portable

building is defined as “occupied” if it meets either one of these criteria:

• one or more persons is present for more than 4 hours per day OR

• it is used for a lunchroom or a conference room



• Portable buildings placed where, in the event of an uncontrolledrelease, chemical concentrations can reach ERPG-3 levels as calculated by the Dow CEI tool or equivalent methods, should meet either of the following:

• (1) Be designed for shelter-in-place.• (2) Have an emergency response plan that includes the following:

– evacuation plan that directs personnel to a designated “shelter in place” or specified assembly area

– plan to account for occupants– Personal protective equipment (PPE) to be used by all occupants

during the evacuation.



• Shelter-In-Place occupied portable buildings should contain the following equipment:– Heating/Ventilation/ Air Conditioning (HVAC) systems capable

of rapid shutdown. This HVAC shutdown response should be included in the emergency response plan.

– Assembly points equipped with two-way emergency communications equipment (telephones are acceptable).

– A method of determining wind direction. – Exhaust fans and duct penetrations of exterior surfaces

equipped with a positive seal against infiltration of outside air.



• When locating temporary portable buildings or modular office buildings, the hazards of neighboring facilities should be considered.



• Temporary portable buildings should be procured and set up in accordance with applicable governmental and site requirements.



• Consider a step in the maintenance and construction procedures requiring removal of temporary portable buildings (within the areas described in Table 1) prior to the introduction of hazardous chemicals to the process or implementing control plans to keep portable buildings unoccupied during high hazard periods.


Stackable, up to 2 high

Consider the use of “High Strength Portable Buildings”when recommended spacing for traditional buildings unachievable.


High Strength Portable Buildings (HSPB)

• Industry benchmarking indicates that 20 to 30 other companies currently use HSPB’s.

• Standard Units: 12 ft X 40 ft• Transportable by an 18 wheeler • HSPB’s can be purchased or leased• Some designs are capable of withstanding 5.0 psi peak free field

blast overpressure


• Establish plans to reduce the number of people in the area at the times of plant startups, shutdowns, or abnormal operations. Include actions such as following:

– Plant procedures should be available for non-standard operations (startup, shutdown, upset conditions, loading flammables into the process, etc.) which identify appropriate actions to remove or minimize people in the area until a stable operating condition is established.

– Notify adjacent blocks about the non-standard operation time periods.– Consider whether portable offices for Construction, Turnaround or Project Management

personnel should be located in close proximity to operations facilities. Determine if it is possible to relocate personnel normally located in the area and allow those essential to Construction, Turnaround, and Maintenance Activities to utilize their office space.

– Review construction, turnaround and/or maintenance sequences, with consideration given to possibly moving work offsite to pre-fabrication shops.

– Consider adding a step to the maintenance and construction activities requiring removal of portable or temporary buildings from areas within XX feet {the spacing distances shown in the Portable Building Best Practice document} prior to the introduction of hazardous chemicals to the process

Dow Actions following BP Incident (continued)


• Ensure that all potentially impacted workers, including contract employees, are fully briefed on the appropriate activation of and response to area evacuation alerts, including evacuation routes. Reinforce that it is mandatory to sound the plant alert or evacuation warnings if there is concern that a plant upset condition may eventually lead to an unsafe situation (e.g., as soon as it is apparent that pressure in a vessel is rising and approaching the point of relief device set pressure if its discharge vents to the atmosphere).

• As part of any site-based Office Optimization projects, consider what personnel need to be located within the plants.



• Charter a Six Sigma project to transition the Portable Building “Best Practice” into a Dow Loss Prevention Principle or EH&S Standard.

• Consider:– feedback following the rollout of this

Learning Event Report– any industry-wide guidance from OSHA or

the US Chemical Safety Board following their investigations of the BP incident.



Questions / Discussion


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Dow’s New Practice for Locating Temporary Portable Buildings

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