Freeport Site Emergency Plan

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1 Title: Freeport Site Emergency Plan Freeport Site Function: Environmental, Health and Safety Procedure No.: Page: 1 of 78 Reviewed: 7/12/16 Effective: 8/1/2016 Supersedes: 10/2010 Preparer: Owner: Approver: Site Safety Representative Manager, Environ, Health & Safety VP and Gen. Mgr., Freeport ANNUAL REVIEW TRACKING Date Reviewer s Name and Title Notes 7/12/2016 T. Mageors / ER Coordinator See revision history.

2 Procedure No.: Page: 2 of 78 REVISION HISTORY Revision Description of Changes 7/12/16 rewrote site plan to create one document removed several lower tier checklists removed specific names from the plan and included titles only or referred to weekly on-call schedule added maps to beginning of plan added TOC outlining plan elements added revision history added annual review tracking to top of document adjusted capitalization of headings removed checklists and placed them in a separate document added rescue operations added note referencing RMP executive summary added ER drills (removed from Freeport Safety Meetings and Emergency Drill Standard) Effective Date 08/1/2016

3 Procedure No.: Page: 3 of 78 PLAN CONTENTS Maps... 5 BASF Site... 5 Dow Plant B PURPOSE DEFINITIONS EME (EOC) EMERGENCY SIGNALS EMERGENCY RADIO BROADCAST SYSTEM SITE EMERGENCY MANAGEMENT TEAM (SEMT) SITE EMERGENCY PLAN (SEP) NATIONAL INCIDENT MANAGEMENT SYSTEM (NIMS) COMMUNICATIONS EMERGENCY ACTION FLOW (Bomb Threat/Civil Disorder) EMERGENCY ACTION FLOW (Utilities Failure/Severe Weather) EMERGENCY ACTION FLOW (Fire/Explosion or Injury) EMERGENCY ACTION FLOW (Odor Complaint/Spill or Release) EMERGENCY ACTION FLOW (continued) EMERGENCY ACTION FLOW (continued) EMERGENCY ACTION FLOW EMERGENCY ACTION FLOW - TRACER EMERGENCY ACTION FLOW - CAER CORPORATE NOTIFICATION CORPORATE CRISIS MANAGEMENT CAER LEVEL WARNINGS AND ACTIONS METHODS OF COMMUNICATION RADIO SYSTEM EOC PHONE NUMBERS PERSONNEL ACCOUNTABILITY POST-INCIDENT/DRILL CRITIQUE AND ASSOCIATED DOCUMENTATION PROCEDURES BOMB THREAT CIVIL DISORDER FIRE INJURIES RESCUE SPILL / GAS RELEASES SEVERE WEATHER AND HURRICANES UTILITIES FAILURE RADIOLOGICAL INCIDENTS WORKPLACE VIOLENCE INCIDENT COMMAND INCIDENT COMMAND SYSTEM FOR HAZWOPER RESPONSES INTRODUCTION...38

4 Procedure No.: Page: 4 of HAZWOPER RESPONSE INITIATORS STAGES OF SEVERITY IMPLEMENTING THE ICS TEAM ROSTERS PRIMARY TEAM TECHNICAL SPECIALISTS BASF CORPORATE NOTIFICATION EXTERNAL NOTIFICATION Emergency Services / Regulatory COMMUNITY AWARENESS and EMERGENCY RESPONSE (CAER) PROCEDURE EMERGENCY CONTACTS EMERGENCY REPSONSE PLAN INDUSTRIAL CAER PLAN IMPLEMENTATION SOUTHWEST TRACER TEAM FREEPORT BRANCH ORGANIZATION COMMUNICATIONS PROCEDURE TRAINING / DRILLS ATTACHMENTS INCIDENT COMMAND PROCEDURES (Shift Safety Orientation) HOT ZONE ENTRY PROCEDURE DST TELEPHONE NUMBERS EMERGENCY SIGNALS EMERGENCY EQUIPMENT CAER ROADBLOCKS SECURITY THREAT REPORT MUTUAL AID EQUIPMENT - OTHERS EMERGENCY RESPONSE CONTRACTORS CURRENT PHONE NUMBERS AND OFFICE LOCATIONS NATIONAL INCIDENT MANAGEMENT SYSTEM (NIMS) FORMS DRILLS HAZWOPER Training Guidelines and Definitions...78

5 Procedure No.: Page: 5 of 78 MAPS BASF Site

6 Procedure No.: Page: 6 of 78 Dow Plant B

7 Procedure No.: Page: 7 of PURPOSE The Freeport Site is committed to a Site Emergency Plan (SEP) that can be activated instantaneously in the event an emergency arises. The plan will protect people and property within the plant site as well as public health and the environment. The Site Emergency Management Team (SEMT) will include and utilize all available resources necessary to protect people and property within the plant site and the surrounding community. The intent of the plan is to designate the leadership and emergency procedures that will be used to control the emergency as quickly and as safely as possible. All emergency procedures and remedial actions will take precedence over normal activities on the plant site. In addition to the SEP, each department will have a departmental plan for all work areas of the department. The titles and verbiage have been revised and is in compliance with NIMS (National Incident Management System). This plan will be communicated annually by department leaders at regularly scheduled safety meetings for all employees. The SEP can be activated by any individual within the plant site. Chris Witte Senior Vice President and General Manager

8 Procedure No.: Page: 8 of DEFINITIONS The number dialed to report a fire, spill, need for ambulance, or any other type of incident considered being an emergency EME (EOC) Facility in the 611 Building where designated Site Emergency Team members are to meet. The alternate location is the 1501 Building second floor Conference Room EMERGENCY SIGNALS Audible horns used to alert people that an emergency involving a fire, gas release, or spill is in progress. See Attachment III for definitions of each horn EMERGENCY RADIO BROADCAST SYSTEM The radio system that is used by Security to broadcast emergency messages to all control rooms and office areas SITE EMERGENCY MANAGEMENT TEAM (SEMT) The Site Emergency Management Team consists of those persons responsible for assuming assigned duties during an emergency. Their specific duties are outlined in Section 5.0. The names, addresses and telephone numbers are listed in Section 6.0. Note: In the event the EOC Manager or one of his alternates is not on site, any primary or alternate member of the Emergency Management Team will be the acting EOC Manager until relieved by the EOC Manager or one of his alternates SITE EMERGENCY PLAN (SEP) The plan that outlines the action taken in the event of an emergency NATIONAL INCIDENT MANAGEMENT SYSTEM (NIMS) A set of principles that provides a systematic, proactive approach guiding government agencies at all levels, nongovernmental organizations, and the private sector to work seamlessly to prevent, protect against, respond to, recover from, and mitigate the effects of incidents, regardless of cause, size, location, or complexity, in order to reduce the loss of life or property and harm to the environment.

9 Procedure No.: Page: 9 of COMMUNICATIONS 3.1. EMERGENCY ACTION FLOW (BOMB THREAT/CIVIL DISORDER) Incident Occurs 6222 Called Record Relevant Information Bomb Threat Civil Disorder Activate Bomb Threat Procedure Section 4 Notify EOC Manager HR Specialist Safety Specialist On-Call Monitor Emergency Radio Broadcast Notify Safety Specialist On-Call Is Further Action Needed? No Yes Notify EOC Mgr. No All Clear? Yes Issue All Clear Activate Civil Disorder Procedure Section 4.2 Issue Security Report Issue Security Report

10 Procedure No.: Page: 10 of EMERGENCY ACTION FLOW (UTILITIES FAILURE/SEVERE WEATHER) Incident Occurs 6222 Called Record Relevant Information Utilities Failure Severe Weather Emergency Radio Broadcast Emergency Radio Broadcast Notify Safety Spec On-Call Notify Safety Specialist On-Call Monitor Is Further Action Needed? No Monitor Yes Plant Shutdowns or Releases? Hurricane? Activate Plan No What Type Is Further Action Needed? Yes Freeze? Activate Plan Take Necessary Action All Clear? Yes Monitor No Yes Notify EOC Manager No All Clear? Notify EOC Manager Issue All Clear SEP Activated? Yes Yes Issue All Clear No EOC Activated? Issue Security Report Issue Security Report Yes Go To Page 3-5

11 Procedure No.: Page: 11 of EMERGENCY ACTION FLOW (FIRE/EXPLOSION OR INJURY) Incident Occurs 6222 Called Record Relevant Information Fire/Explosion Injury Emergency Radio Broadcast Emergency Radio Broadcast Is DOW F.D. Needed? No Yes Securtiy Notify DOW Fire Dept. Dispatch Ambulance Notify Safety Spec. On-Call Monitor Notify Safety Spec. On-Call Notify EOC Manager/ Safety Spec. On-call Yes Serious or Fatality? No All Clear? Yes No EOC Activated? No No Notify Emerg. Contacts HR/Unit/Other Issue All Clear Yes Send Company Rep. To Hospital Issue Security Report Prepare Press Stand-by Statement Go To Page 5 Issue Security Report

12 Procedure No.: Page: 12 of EMERGENCY ACTION FLOW (ODOR COMPLAINT/SPILL OR RELEASE) Incident Occurs 6222 Called Record Relevant Information Odor Complaint Spill or Release Notify Env & Safety Spec On-Call Emergency Radio Broadcast Environmental On-Call to Notify Owner to Correct Identify Sources Yes Source in BASF? No Level 2 Level 3 Site Security Activates EOC CAER Level? Level 0/1 Is Release Serious or RQ? Monitor All Clear? No No Yes Yes Env./Media On- Call Contact Complaintant Is Further Action Needed? Yes No Determine Source, if Possible Contact CAER Central Member Company Emitting Odor (if any) Issue Security Report Notify CAER Activate CAER Notify EOC Manager Safety Spec & Env On-Call Yes Yes Notify Safety Spec & Env On-Call EOC Mgr. EOC Activated? No Issue All Clear Issue Reports See Spill Reporting For Possible Further Action This Page Owner of Odor Issue Report Go To Page 5 Notify Agencies/ Employees

13 Procedure No.: Page: 13 of EMERGENCY ACTION FLOW (Continued) From Previous Page3-2, 3-3, 3-4, or 3-9 EOC Activated Primary Team Activated and Plant Notified by Emergency Radio Broadcast & Cell / Pager Evaluate Situation from Incident Commander Evaluate Situation and Required Actions From Page 3-6 Issue CAER Advisory Update (Liaison Officer) Yes Is CAER Message required or Update needed? Ensure Agencies Have Been Notified TRC NRC BCEPC TCEQ Establish Media Center Yes Yes No Is Spill/Release An RQ? No Media Center Needed? No Prepare Press Release Notify Next of Kin Yes Are Injuries Involved Send BASF Rep. to Hosptial No Go to Page 6

14 Procedure No.: Page: 14 of EMERGENCY ACTION FLOW (Continued) Continued from Page 3-5 Notify OSHA Within 8 Hours Yes Are 3 or more admitted or a fatality? No Communicate internal/external as needed Yes Are Plant Shutdowns Required? No Notify Corporate Emergency Response if needed. Arrange for Personnel coverage, Food & Supplies Yes Extended Duration of Event? No Issue Necessary Bulletins Go to Page 3-5 No All Clear? Yes Issue All Clear Debrief & Deactivate EOC

15 Procedure No.: Page: 15 of EMERGENCY ACTION FLOW Injured Persons Report Name: Company: Injury: Taken To: Company Contact Family Contacted Type Severity Person Phone # Y/N Missing Persons Report Name: Company: Time Company Contact For Headcount Status Update Onsite Contact Phone # Offsite Contact Phone #

16 Procedure No.: Page: 16 of EMERGENCY ACTION FLOW - TRACER Freeport Tracer Response Team **Source of TRACER Emergency or Freeport Security **The first knowledge of a TRACER emergency may come from any number of sources who may use local BASF telephone numbers, Freeport Security, Freeport Plant personnel, corporate telephone numbers or CHEMTREC. Freeport TRACER Team Response Coordinator Freeport Site Security Site Logistics Industrial Hygiene Off-Site Services No Freeport Product? Yes Notify Freeport EOC Manager Safety Specialist On-Call Manufacturing Representative No Is Environment Regulatory/ Medical/ Public Impacted? Investigate and Issue Incident Report Corporate Emergency Response Freeport TRACER Team Issue Response Report Yes Implement SEP (all or part) Page 3-5

17 Procedure No.: Page: 17 of EMERGENCY ACTION FLOW - CAER Community Alert Flow Chart The industrial CAER plan will be implemented as shown by the following flow chart (Ref. Section 7). See Section 7.0 for additional community alert procedures. Source of Emergency Industrial CAER Member Emergency Headquarters Fire Department Sheriff BCEPC Industrial CAER Central (Dow Security) Regulatory Agencies Secondary Notifications** Brazoria County Sheriff s Office CAN CAER Siren CAER Radio 1610 AM Broadcast Radio 238-CAER (2237) Mutual Aid County Judge/EM Office Affected Schools Community Police Affected Police Depts. Department of Public Safety Affected CAER Members Coast Guard Affected Communities Port of Freeport

18 Procedure No.: Page: 18 of CORPORATE NOTIFICATION Within North America, incidents that meet the following criteria should be reported immediately to the Corporate Emergency Response Center: Death or injury to any individual (contractor or employee) that requires hospital admission A release, spill, discharge of material, or fire that: Requires actions be taken to shelter and/or protect local residents and businesses Consists of a chemical release to the environment of >10 kg for marine pollutants, > 50 kg for dangerous goods/hazardous materials or > 1000 kg for non-hazardous materials, or Requires the mobilization of public sector resources (fire, police, etc.) Attracts or has the potential to attract significant public attention Any event that results in a significant disruption in normal operations and has the potential to negatively impact the supply chain. This includes but is not limited to utility failures, IT-system failures, transportation stoppages, labor issues and widespread weather abnormalities which result in: Significant property damages that exceed 100,000 euro (US$145,000) or, Significant production interruption that exceeds 500,000 euro (US$725,000). Production interruption costs include loss of income and any cost associated with plant restart. The telephone numbers to contact the Emergency Response Center are: in the United States & Canada in Mexico The Corporate BASF Emergency Response Center managers are responsible for assessing each incident and filing a Rapid Report with the Ludwigshafen Fire Department when applicable. However, during evenings, weekends and holidays, any BASF employee needing to consult Corporate Communications regarding an incident can do so by contacting an emergency on-call team member* through a dedicated phone number: Please list this number in your Emergency Response Plans and store in your cell phones.

19 Procedure No.: Page: 19 of CORPORATE CRISIS MANAGEMENT BASF Corporation has a Crisis Management Plan designed to enable the Corporation to respond to and recover from a crisis. A crisis is defined as an unplanned situation or event with: The potential to significantly impact BASF Corporation s operation or credibility. Or which poses a significant environmental, economic, safety or legal liability, and, in addition, May or will require significant Corporate-level resources to manage. 1. Initial notification should be made through the Corporate Emergency Response Hotline. The form detailing the pertinent information is found in the Crisis Manual in the EOC Conference room. 2. Site Leadership or the Crisis Administrative Specialist will communicate with an Executive VP who may deem a site emergency as a crisis. 3. If an emergency is deemed a crisis, an Administrative Center will be set up to manage the information exchange between the site and the Corporate Crisis Team. Detailed information on the Administrative Center is also located in the Crisis Manual CAER LEVEL WARNINGS AND ACTIONS Note: For CAER Incident reporting purposes Dow Chemical s Plant B and the BASF Freeport site are considered extension of each other s site boundaries Level 0 An incident is in progress, which can be handled within the boundaries of the block/unit. No impact is anticipated outside of the block/unit. Emergency horns may or may not be sounded. Roadblocks will be necessary to keep vehicles and personnel from entering plant areas. Locations for roadblocks will be designated by unit personnel based on the type, size, and direction of the release. Block personnel can handle all elements of the event. If the event is a HAZWOPER incident, see Section 5.0 for the Incident Command organization. If horns are sounded, Dow Security will be notified, and Site Safety Specialist will respond to assist in blocking roads, monitoring block perimeters, etc.

20 Procedure No.: Page: 20 of 78 Site Safety Specialist and the Incident Commander will coordinate communications for response efforts to the EOC Manager. The EOC Manager will determine if the EOC will be activated Level 1 An incident is in progress, which can be handled within the boundaries of the plant site. No impact is anticipated outside of the plant site. Roadblocks will be necessary to stop traffic adjacent to the block. Adjacent block personnel can be requested to help block roads. Emergency horns will be sounded. Block emergency and seek shelter horns should be shut off when the block and adjacent roads are secured. Dow Security will be notified, and Site Safety Specialist will respond to assist in blocking roads, monitoring block perimeters, etc. Site Safety Specialist and the Incident Commander will coordinate communications for response efforts to the EOC Manager. The EOC Manager will determine if the EOC will be activated Level 2 An incident is in progress, which appears that it can be handled within the boundaries of the plant site. However, the community could be impacted. The items in Level 1 plus The EOC is activated by Site Security. A complete site headcount will be performed. CAER Central (Dow Security) will be notified to answer community calls if received. CAER Central will put the local CAER officials on stand-by (if requested by the unit, or if the incident could go to Level 3). All CAER updates will be communicated by the Liaison Officer. Site Safety Specialist will provide air monitoring outside the block limits

21 Procedure No.: Page: 21 of 78 and off site. Site Safety Specialist and the Incident Commander will coordinate communications for response efforts to the EOC. Hospitals, schools, BCEPC, BEMC, Red Cross, and others are notified if necessary. The community could be impacted for a Level 2 is further defined as the following: Level 3 This is an incident or developing incident that has the potential to impact the community. An example is a runaway reaction that is being monitored, or a fire with the potential to spread. Any toxic or hazardous material actually released that has the possibility to impact the community but actual concentration is unknown should be a Level 3. An incident is in progress which will affect areas outside of the plant site. A full emergency condition exists for areas outside of the site. The EOC is activated by Site Security. A complete site headcount will be performed. The local CAER Emergency Procedures are activated. Local officials set up roadblocks in the community. The CAER sirens are sounded. The Community Alert Network (CAN) is normally activated unless specifically requested that it not be activated. (Residents within a twomile downwind radius are called on the telephone.) All CAER updates will be communicated by the Liaison Officer. Hospitals, schools, BCEPC, BEMC, Red Cross, and others are notified. Site Safety Specialist and Incident Commander will coordinate communications for response efforts to the EOC. See Section 9.0, Community Alert, for further community actions.

22 Procedure No.: Page: 22 of 78 For pipeline releases, a Level 3 event would be triggered when a release has the potential to impact people outside the boundaries of the pipeline right of way. Definition: Impact a safety or health hazard METHODS OF COMMUNICATION Reporting Report fires, explosions, spills, releases, ambulance requirements, or other emergency incidents using 6222 on any phone in the plant system. These calls are answered by Security Dispatch personnel and backed up by the Main Gate Security Office Emergency Radio Broadcast System Security maintains an emergency radio broadcast system to warn site personnel that an emergency exists Dow Direct Emergency Radio Site Security has a direct radio line to Dow from the Security Dispatch Office for communication of emergencies Harbor Terminal Emergency Response Radio The Harbor Terminal Marine Radio, located at the Ammonia Terminal, should be used to communicate to ships or barges Signal Horns These are audible horns, which can be activated from each control room. They are used to alert personnel of an emergency. See Attachment III for signal horn details Advisory Messages Advisory messages regarding unusual weather and hurricane status can be received by dialing 6444 on any plant phone. The last message will be recorded on 6444 after other emergency communications are made Unit Telephone Back-Ups The 900 MHz radio system will be used for a back-up of the plant telephones. Each control room, Security, the EMERGENCY OPERATIONS CENTER (EOC) and Safety has a base station that has the common talk group EMERGENCY TELEPHONE. This talk group can be used to contact other Control Rooms or Security when normal telephone contact cannot be made.

23 Procedure No.: Page: 23 of Emergency Response Radios The 900 MHz trunked radio system will be used for primary emergency communication. Some units will continue to use non-trunked radios to handle emergencies in their units. The Safety Specialist will relay information back to Security or EOC during emergencies. The following radio talk groups and procedures will be used during emergencies. When a site emergency exists, all radio communication should STOP except for those communicating about/on the emergency or for other extreme needs EMERGENCY RESPONSE TALK GROUPS HANDHELD BASE UNIT DESCRIPTION/USE 1A EMERG. NOT. Emergency Notification On all portable radios Security always monitors When orange (man-down) button is pushed, radio automatically switches to this talk group Used to contact security 1B EMERG. RESP. Emergency Response On all portable radios for tech. and Emergency Response Team Used by Incident Commanders for multi-unit emergencies 1C EOC Emergency Operations Center On all Emergency Response Team and Incident Commander radios Used when the EOC is activated or to communicate with I.C or Safety Spec. 2A GEN MGR Site Manager On EOC Radios and Safety Radios For use between Safety and Site Manager as a secure Talk Group 2B ECOLOGY Ecology On Ecology, Safety/Security Logistics, & Emergency Team radios Used by Ecology for daily work and by other Emergency. Response members

24 Procedure No.: Page: 24 of 78 HANDHELD BASE UNIT DESCRIPTION/USE during emergencies 3A SAF/SEC Safety/Security On all Safety, Security and Emergency Team radios Normally used by Security 3B AMBUL Ambulance On all Ambulance, Security and Emergency Team radios Used by Ambulance Response Team 4B/4C PLANTW 1 PLANTW 2 EMERG TEL Plant wide 1/Plant wide 2 On all radios For daily or emergency use by multiple or individual units Emergency Telephone Back-Up On all telephone back-up base stations in control rooms, EOC base stations and Security base stations Used as communication between control rooms if telephones are not functional Have a telephone interconnect function for calls outside the unit Incident Commander Radio Talk Group Production units will use the talk-group of the unit having the emergency. For Stage 1 incidents Incident Commanders should initially use the IC unit s talk group. For Stage 2-4 incidents, the Incident Commander will use talk group 1C, EOC. Initial communication between the Incident Commander and the Operations Section Chief should be in person, by telephone, or on the unit talk group. The Incident Commander will communicate back to the EOC on 1C. Talk Group 1B (Emergency Response) is another radio talk group that can be used specifically for emergencies. The Incident Commander must make known the talk group he will be using.

25 Procedure No.: Page: 25 of 78 Plant wide 1 & 2 can also be used for multi-unit emergencies because these talk groups are on all production radios. Either of these talk groups can be designated as the Incident Command talk group or can be assigned as a task force talk group Emergency Operations Center (EOC) Radio Talk Group The Emergency Operations Center (EOC) operates on Talk Group 1C (Emergency Operations Center). Safety, Ecology, Logistics, Incident Commander, or other Emergency Team Members will initially use 1C (EOC) to communicate to the EOC. If the EOC needs Security, they will normally use the 1C talk group. Security also monitors 1A and 3A Emergency Support Groups Radio Talk Group Emergency Support Groups like Safety, Ecology, Logistics, etc., can monitor Talk Group 1C, but should use their own talk groups for communication other than to the EOC. In addition, for long talks, the EOC should switch to the talk group of the affected department or unit, or use telephones if possible to clear up the Talk Group 1C (EOC) for other incoming communication Security Security will normally monitor four talk groups and the emergency telephone system during emergencies unless requested otherwise. 1A - Emergency Notification 3A - Safety /Security ET - Emergency Telephone (from all Control Room base stations) 3B Ambulance 1C- EOC RADIO SYSTEM The 900 MHz radio system is a trunked radio system. A trunked system means that many talk groups are arranged by computer software that operates on a small number of frequencies. If a total system software failure (called fail soft ) occurs, then all radio talk groups will be divided into five talk groups. A faint beep will be heard every 10 seconds to indicate the system is in fail soft. If electrical power is lost, an Un-interruptible Power Supply (UPS) will give backup power for a predetermined time.

26 Procedure No.: Page: 26 of EOC PHONE NUMBERS EOC Main Communications Specialist TES Specialist Utilities Specialist Polycaprolactam Specialist Contractor Specialist Capro Complex Specialist Acrylic Monomers Specialist Oxo/Diols Specialist Media Specialist Personnel Services Specialist Ecology Specialist Conference Call Phone Safety Specialist Hurricane Phone Normal Loss of Power FAX EOC Backup at 1500 Block Facilities Communications Specialist Planning Section Chief Utilities Specialist Polycaprolactam Specialist Contractor Specialist Capro Complex Specialist Acrylic Monomers Specialist Oxo/Diols Specialist Public Information Officer - Internal Public Information Officer - External Liaison Officer Conference Call Phone Safety Specialist Logistics Section Chief Hurricane Phone Normal N/A - Loss of Power N/A FAX PERSONNEL ACCOUNTABILITY Responsibilities A. Visitors and all employees entering units they are not permanently assigned to must sign in on the WAL (Work Authorization Log) or

27 Procedure No.: Page: 27 of 78 be covered by a SWP (Safe Work Permit) before entering process areas and before conducting any work within the unit. B. Visitors and all employees in affected areas will follow evacuation procedures to prescribed Assembly Points when Emergency Signals are sounded and wait for the ALL CLEAR signal. Visitors not signed into the WAL will be the responsibility of their BASF escorts Unit Emergencies A. Alliance and other construction or maintenance contractors (Zachry, Mundy, and large capital crews determined at mobilization) will have a procedure to perform a headcount for all affected personnel after a block emergency has occurred. Each company will communicate their head count results through one person to the Contractor Specialist at ext (if during normal work hours) and after normal work hours to the Security Main Gate at ext For emergencies where the EOC has been activated, the Contractor Specialist is located in the EOC at ext and will help compile and communicate the head count results to the Control Room through the EOC Manager. B. All other affected employees (BASF and Contractor) will be contacted by a Control Room representative. All personnel must wait at assembly points for the All Clear Signal. (Exception: Personnel at assembly points may need to summon help for assistance with injured personnel.) C. The Block or Unit Control room will ensure that headcounts are conducted for the unit(s) involved. SWP s and the WAL will be used to account for persons not permanently assigned to the Unit or Block. The Unit or Block is responsible to complete the headcount by checking assembly points and checking with the Contractor Specialist (at 6292 during normal work hours, 6800 if the EOC is activated). The Control Room will check with Security (Main Gate) after normal work hours. If unit personnel cannot access assembly points due to the emergency, adjacent units can be contacted for assistance with headcounts at assembly points. D. For persons assigned to the unit or block, a sign out log (board or other method) will be used to account for personnel. E. If fires or explosions can impact trailers or buildings adjacent to the block, a headcount for those areas must also be conducted. F. Units may utilize personnel from the Site Response Team (sister plants, etc.) to conduct headcounts using WAL s and SWP s.

28 Procedure No.: Page: 28 of 78 G. For emergencies where the EOC has been activated, all headcount results will be reported to the EOC as soon as they are completed. H. The ALL CLEAR signal should not be given until all headcounts are completed in affected areas Temporary Office Buildings and Trailers on the Perimeter, Adjacent to, or within Operating Blocks (includes permanent building inside block areas that are evacuated during block emergencies) A. All buildings must have a list of persons assigned to the building or trailer in the associated Control Room. B. The Control room will use this list in their headcount procedure if these buildings have been impacted. C. The buildings will have an evacuation plan (or directions) posted Permanent Office Buildings outside of operating Blocks A. Each building will have an evacuation plan to ensure that everyone is out of the building if asked to evacuate. B. Each building designated as a Seek Shelter will have a plan to eliminate outside air from entering (cocooning) POST-INCIDENT/DRILL CRITIQUE AND ASSOCIATED DOCUMENTATION Definitions: Site or Unit HAZWOPER Training Coordinator: Unit/site person responsible for ensuring that an annual ER drill schedule is developed and followed and coordinates the site HAZWOPER Employee Training Program. Requirements: The Site or Unit HAZWOPER Training Coordinator is responsible for organizing and conducting a critique following the conclusion of all emergency incidents or drills. The critique should include both verbal and written input from all appropriate participants. Where deficiencies are identified, an individual should be assigned the primary responsibility for correcting the deficiency and a due date should be established for that action. Action Tracker should be used to ensure all items are tracked until completion. An example critique form for documenting critique findings can be found in Appendix III. The first two pages of the critique form can be used for short, less complex emergency drills or incidents. The full critique form is recommended for longer, more complex drills or

29 Procedure No.: Page: 29 of PROCEDURES major incidents. Maintain critique documents for a minimum of three (3) years. Procedures outlined in this section describe emergency response actions for the following emergencies: Bomb Threat Civil Disorder Fire Injuries Rescue Spills & Releases Response for incidental releases and initial information for HAZWOPER responses Severe Weather Utilities Failure Incident Command Incidental releases that do not require a HAZWOPER emergency response are those where a release of hazardous substances is limited in quantity and poses no emergency or significant threat to the safety and health of employees. HAZWOPER responses are covered in Section 5 of the Emergency Plan. Note: Basic Life Support or higher level trained personnel must be on standby during an emergency response incident. Call 6222 to confirm Emergency Medical Services are on standby. (A list of all qualified emergency medical personnel on-site, their certifications, and how to contact them in an emergency is maintained by the Security Department) BOMB THREAT Person Receiving the Call The person receiving the call should attempt to gain the following information about the call and caller (use Security Threat Report - Attachment VI): Time To Go Off - When will it detonate? Location of Bomb - Building, Block, Process Area, Tank Farm Voice - Male/Female, Low/High Pitch, Smooth/Raspy Speech - Fast, Stutter, Accent, Slurred, Nasal, Lisp, Intoxicated, Disguised/Changing, Unusual Pronunciations, Monotone Composure - Excited, Irrational, Composed, Nervous Background Sounds - Machinery, Motor Vehicles/Trucks Other Information - Organization, Repeated Phrases, Gripes; is the individual familiar with the plant? Certain areas?

30 Procedure No.: Page: 30 of 78 REPORT INFORMATION TO SECURITY IMMEDIATELY VIA Security Notify the following functions or their alternates immediately: EOC Manager Human Resources Specialist Safety Specialist Security Specialist Emergency Action EOC Manager, Safety Specialist, Security Specialist, and Human Resources Specialist meet in EOC. A. Review the threat and determine what action will be taken. B. Determine how employees should be notified of the threat and start search procedures by one of the following procedures: General Threat (i.e., no specific location given) Issue appropriate message (by seizure phone, , or by each manager), A bomb threat has been received. Have Primary team members respond to the EOC. Search control rooms, offices, labs, shops, and other buildings. Look for unusual or out-of-place objects. If unusual or out-of-place objects are located: o Make no attempt to move or handle object; leave matter entirely to law enforcement o Evacuate all people from building/location. o Notify EOC. o Safety or Security will inform law enforcement. Once it is determined the area is clear, EOC Manager will issue an all clear. Specific Location Named Issue appropriate message (by seizure phone, , or by each manager), A bomb threat has been received for the (Bldg./Block). Implement department plans immediately. Evacuate the location immediately according to department/building plan. Note: Operating units must make provisions in their plan for continued operation or to shut down in an orderly fashion. The manager(s) of the location and individuals selected by the manager should search the specific area. If unusual or out-of-place objects are located:

31 Procedure No.: Page: 31 of 78 o o o o o o Make no attempt to move or handle bomb; leave matter entirely to law enforcement Evacuate all people from that building/location. Notify EOC. Safety or Security will inform law enforcement. Once it is determined the area is clear, EOC Manager will issue an all clear. If a time and place (or area) has been targeted, that area should suspend the search during the time the bomb was stated to go off, and personnel in that area should be relocated in a searched and dedicated safe area CIVIL DISORDER 4.3. FIRE C. Security Specialist will determine the need to notify the Brazoria County Sheriff, In case of civil disorder, the Security Officer s first responsibility will be to contact the EOC Manager, Human Resources Specialist, Security Specialist and Safety Specialist and receive further instructions. In such an emergency, plant entrances will be closed to all personnel who do not have approval through the EOC, and others will not be permitted to enter or leave the plant. Entrance approval will be given by phone, before coming to work, and transferred to personnel at plant entrances. If phone contact is not possible, appropriate BASF personnel, dispatched by the EOC, will be in contact with those at plant entrances to grant approval where needed. Personnel on duty will remain on their jobs and at their workstations until relieved and dismissed by their Team Leader. In the event that such an emergency occurs near shift end, personnel will be required to remain at work until proper relief can be arranged Department Notify Security at extension Say, I want to report a fire, then give your name, plant name or department and block number. Stay on the line until you are sure your message is understood. State if a fire truck is requested or if stand-by status is needed. If fire truck is requested, send someone to the designated block fire station to direct the fire truck. (See Attachment X for Fire Stations)

32 Procedure No.: Page: 32 of Security Officer Activate emergency radio broadcast. Request fire truck from Dow, if required. Activate Emergency Plan Fire Protection BASF Freeport uses Dow Chemical for fire brigade activities. Freeport employees are trained to respond to incipient fires. Freeport employees cannot perform fire brigade firefighting. Incipient firefighting is firefighting inside or outside of an enclosed structure or building when the fire has not progressed beyond incipient stage. The incipient stage refers to the severity of a fire in which the progression is in the early stage and has not developed beyond that which can be extinguished using portable fire extinguishers or hand lines flowing up to 125 gpm. A fire is considered to be beyond the incipient stage when the use of thermal protective clothing or selfcontained breathing apparatus is required or when required to crawl on the ground or floor to stay below smoke and heat. Thermal protective clothing and SCBAs are recommended as PPE from potential vapors that could be ignited when taking actions to shut down the plant and initiate incipient fire protection Freeport Employees Freeport employees will activate sprinkler systems, fire monitors, fire extinguishers and small hose/foam lines where needed to extinguish incipient fires. Security will direct Dow Fire Department to the block needing fire protection. Dow will proceed to fire stations designated on the site emergency map. BASF Operations Section Chief will send personnel to meet them at the Fire Stations for further directions. BASF Operations Section Chief will communicate with the Dow Fire Department to give information and to help assess the situation to mitigate the fire Dow Fire Department Dow Fire Department will proceed to the Fire Station at the block they are directed to. Fire stations are indicated by RED circles on the emergency map at the beginning of the plan. Dow will proceed to the area needed as directed by unit personnel and begin set up. Dow will communicate with the BASF Operations Section Chief or Incident Commander to assess the fire or situation. Dow Fire Department will evaluate the situation with BASF, set up equipment, call for additional manpower/equipment as needed, and attack the fire or situation (vapor suppression, etc.) as needed.

33 Procedure No.: Page: 33 of Mutual Aid Emergency Assistance from other industrial facilities as set up by the Emergency Assistance Agreement under Industrial CAER. Resources can be found in Attachment IX. The Dow fire brigade can request these additional resources as well as BASF personnel. The Incident Commander will request additional needs through the EOC, who will make the calls, give direction to arriving assistance, ensure staging areas are arranged, and provide escorts to the area needed INJURIES Department Notify Security at extension 6222 only if the ambulance is required. Say, I want to report an injury. Then give your name, plant name or department, and block number. Stay on the line until you are sure your message is understood. Send someone to the designated ambulance station to direct the ambulance. (See Maps at beginning of this plan for ambulance station reference) Security Activate seizure message alerting rescue members to respond Dispatch ambulance to the injury site. Notify on-call Safety Specialist, who will report to the incident location RESCUE Department Notify Security at extension 6222 if rescue is required. Say, We need rescue services at. Then give your name, plant name or department, and block number. Stay on the line until you are sure your message is understood. Send someone to the designated ambulance station to direct the rescue personnel. (See Maps at beginning of this plan for ambulance station reference) Security Activate seizure message alerting rescue members to respond. Dispatch ambulance to the location. Notify on-call Safety Specialist, who will report to the incident location SPILL / GAS RELEASES Department Report all spills (according to Ecology Standard #3) to Security at extension 6222, immediately, using the following guideline:

34 Procedure No.: Page: 34 of 78 Report to Security, the following information, for all environmental incidents: Location (block, department, area, if known) Person calling Type of incident (i.e. spill, gas release, odor, upset, maint., etc.) Product/material and amount of spill/release (give best estimate on amount) Level 0, 1, 2, or 3 (magnitude of release) Are horns sounded Cause of incident (vessel overflow, pump seal, gasket, etc.) Injuries, fire, other (see Safety Rules) Attachment No. 3 to Ecology Standard #3 is the Security Incident form, which outlines the information to be provided when reporting incidents Notify emergency on-call personnel per department guidelines. See RMP Executive Summary for information on site chemicals, storage and worst case scenarios. Intranet/freeport/en_GB/content/microsites/sites/freeport/services/e hs/risk-mgmt-plan Security Level 0 or 1 Initiate the Security Group Procedure that notifies site personnel of the emergency. Level 2 or 3 Initiate the Emergency Plan, including the CAER Community Alert Releases that may initiate a HAZWOPER Response and the Incident Command System (ICS) Note: In the event of a HAZWOPER Response, a plan for decontamination of response personnel must be in place prior to execution of HAZWOPER Response activities. You may refer to unit decontamination procedures or develop a new decontamination plan that is specific to the event. PPE for decontamination personnel will be at least one level above that of the entrants into the hot zone. For minimum decontamination requirements see: Decontamination Instructions.

35 Procedure No.: Page: 35 of 78 Releases of hazardous substances in the workplace can be categorized into two groups: Releases that are incidental and do not require a HAZWOPER response. Incidental releases that do not require a HAZWOPER response are those where a release of hazardous substances is limited in quantity and poses no emergency or significant threat to the safety & health of employees. Releases that require HAZWOPER response. These are covered in Section 5.0. If there is a question as to whether a HAZWOPER response is necessary, the safety specialist on-call should be contacted immediately by Security Limited Response Actions A process operator can take limited actions (i.e. turning a valve) to prevent the incident from increasing in severity, with less than four responders, as long as the process operator has met certain requirements. The process operators must: 1. Inform the incident command structure of an emergency by notifying the Team Leader, which notifies Site Security as defined in the Site Emergency Plan. This initiates all emergency response procedures. 2. Have adequate PPE. 3. Have adequate training in the procedures they are to perform. 4. Employ the buddy system. The buddy system criteria (when taking limited action) are satisfied with two people, the process operator and one other, his buddy. The process operator takes the limited action while the second man maintains line of site contact with him, to provide help in case the process operator gets into trouble. Note: Offensive HAZWOPER responses to clamp leaks, etc., require a buddy system with a minimum of 2 people in and 2 people as backup HAZWOPER Responder Resources (Back-Up Teams) There are three sources for additional responders from the Freeport Site: 1. Other members of the DST or DOT in the plant having the incident. 2. Support from the adjacent plants or plants within the same technology group. 3. Site Response Team - Issuance of a Help Request from the Site Response Team on the seizure phone system to acquire resources from across the Freeport site. This system would result in responders, one person from designated plants, meeting at a location designated

36 Procedure No.: Page: 36 of 78 on the seizure message to serve as additional resources for the Operations Section Chief and/or Incident Commander. Some plants do not have enough staffing to provide outside assistance. These plants have been designated not to send a response person. The team leader from all other plants will designate a person to be sent when the seizure call is received Site Response Team (SRT) Procedures 1. The plant needing assistance will request the help through Security by dialing Security will initiate a Seizure message for additional personnel. 2. The plant needing assistance will designate where the responders are to meet based on wind direction and location of the spill for safe access to the plant. 3. Once notified of a request for additional responders, those chosen to respond will proceed to the area designated by the requesting plant. Each responder will take a radio programmed with all talk groups and a SCBA to the designated area. 4. The requesting plant will normally provide all other emergency response equipment. 5. Responders may be requested to: block roads, meet the Dow Fire Brigade, be a backup entry team, set up decontamination, be a decon team member, retrieve equipment from other areas, fill in places in the incident command structure or provide other HAZWOPER response duties. 6. The Operations Section Chief or Incident Commander will establish the radio talk group to be used. If no talk group has been specified, the default talk group is 1A SEVERE WEATHER AND HURRICANES Information relating to local severe weather forecasts is received from Storm Geo or the National Weather Service. These messages are communicated to plant personnel through the seizure system. The Security Officer will notify the on-call Safety Specialist or alternate after regular working hours of severe weather messages issued. Tornado When conditions are favorable for a tornado that may affect the site, weather bulletins will be issued. If a tornado warning is issued for our area, a seizure message will be issued so everyone can prepare for possible seek shelter warnings. If a tornado is sighted that may affect our site, a seizure message will be issued for all personnel to seek appropriate shelter. Extremely Severe Thunderstorm/High Winds Action to be taken is essentially the same as for a tornado. If strong lightning is present that may affect our site, personnel should take cover inside. If time permits,

37 Procedure No.: Page: 37 of 78 secure all windows, doors and loose outside equipment/materials. Cranes should be lowered and personnel working in locations vulnerable to lightning strikes should be notified to move to safe areas. Flooding In the event of forecasted tropical storms, severe rainstorms and flooding, plants shall insure that adequate freeboard is maintained in containment areas, storage vessel areas, spill control areas and loading areas. Utilities will locate portable pumps in strategic areas located to assist with flood control. Flag Lake drainage canal, the fresh water canal and salt-water canal will be monitored for overflow into the site. Storm water drains should be monitored for blockage. Electrical equipment that can be flooded shall be protected from rising water or be shut down and de-energized, according to direction from Power Distribution. Hurricane - In the event a hurricane threatens the Brazosport area, information bulletins will be issued via and placed on The Freeport Site Hurricane Plan and individual department hurricane plans should be consulted for individual action to be taken UTILITIES FAILURE Department Emergencies such as loss of river water, steam, nitrogen, power, or other similar situations that have implications for other departments, will be reported to Security by calling extension State the nature of the emergency Request that the situation be communicated on the telephone seizure system. Make sure the message is understood Security Contact Safety Specialist On-Call Contact EOC Manager Safety Specialist Determine extent of failure-affected plants. Report to EOC Manager serious spills or multiple plant outage or other serious potentials EOC Manager Review extent of outage. Communication Specialist calls appropriate emergency members Considerations If communication system is not functional, arrange runners for obtaining information Inspect electrical equipment prior to restart Ensure headcount conducted for employees, contractors and visitors in affected area.

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