DuPont EMS 3rd Party Preps - Master File

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EMS 3rd Party Audit Action Items
Updated HSE Policy in proper Frames in all cabins
SEQS/ Non-SEQS Limits in proper frames in all cabins
Compoiste Sampling Regular Audits
EMS Sign boards along road sides (05 each for Amm-3/URUT-3, 03 ea for restof units)
Chemical skids and storage points secondary containment audit points closure
Drains issue at base plant closure
Oil Skimming Facility way forward (SNH)
GTE training pans EMS
TA training plans EMS
Post operators training plan EMS
JDs of Managers, supervisors and NMPTS to be reviewed to remove deficencies (wrong wording)
Focus on incidents filling, reporting (coordinator to check all limits break are reported)
NMPTS training sessions
Drain caps audit and Steward ship , there should be no water drippings
PFDs of each unit effluent generation and handling
Amm-3 T-01/T-02 pipe lines tagging
Unit wise record of accountability and rewards
Record of Objects of Unit managers and MPTS related to EMS
Update on numbers of CFP, WFP espacially to Unit Managers
Limits of IFC/SEQS comparison training of MPTS
Ammonia leakages surveys where applicable
Explosivity Surveys where applicable
Vents passing audit to be done and maintinace notification proofs
Steam Traps audits record and maintiance notifications proof
Energy conservation records to be made avilable
MSDS standadized with Spill conttrol mentioned on them
Do you know flyers (02 MA per Week, 01 from EA Coordinator)
Ammonia analyzer at NEQS pit of Amm-3

Remaining 02 ponds lining proper plan with target dates and approved budget info to be made avilable

Wayforward on flare issue to be finalized with process


documented plan for decomissioning of Tk-200 to be made avilable with target dates

Doumented evidence of Managers and EMS coordinators Objectives related to EMS to be made avilable

Unnessary Floor washing to be avoided and frequency of floor washing to be reduced


All units to update their D-level matrixes and include EMS related trainings
AIRAs details to be shared in D-levels
production Department projects done under the umbrell of 6sigma with positive environmental effect to be
shred with MPTS/NMPTS to increase awareness on environmental initatives
Environmental improvementplans to be developed at all units, ongoing projects are to be included and next
year plan to be prepared

C-2A/B area HK to be improved, oil dripping issue to eb takenup with FM and action plan to be finalized
All units to carry out audit of damaged insulations and raise notifications for repairs, maintaini ts record

All nits to improve HK in areas with bird dropping issue and Bird repplents installation plan with target dates
to be made avilabe
smoking area Hk to be improved and smoking at undesignated locations to be stopped at Pm&S
Ums to issue instruction to stop the usage of urea bags for other than urea handling

Fil 121 Sludge removal / Oil Spill due to mishandling / Boiler chemicals spills at Urut-1 to be added in AIRA

All units to review the risk ratings in AIRA and proper justification should be avilabel for each risk rating

Oil in Non SEQS effluent at TK-22 needs to be addressed by installing oil skimmer or other method & also
consider reducing at source
JDs of FM, Managers, Supervisors and NMPTS to be reviewed to remove deficiencies
All units to ensure that manuals (esp. EMS/PSM) are updated and approved
Documented plan on drains sggrigation to be made availble with target dates
Documented plan on de-dusting system to be made avilabe with taget dates
To bet aken up with process and finalize the plan for ammonia nalyzers installation at plant-1
All unit to ensure secondary containment for LO stations
Leaking CO2 bleeder towards R-101 repairs to be done
Practice of Water tanks over flow to be stopped at all units
Tk-22/299 drians Oil sources to be indetified and remidial actions to be proposed
all units to carry out RCA and iniate projeccts to reduce ammonia nad sulphates in effluents

KCO3 bags to be removed from area , No chemical should be present with out secondary containment

V2O5 is use at,Amm-2 to takeup the issue with process and document the way forward
NOX indication to be removed from DCS on Amm-3
LO drums to be removed from PT-3 bottom
Faulty sensors MN to be raised and record to be maintained of the issues- Amm-3
Amm-3 antifoam skid has spill issues since long, need to find out a solution for rectifying the spill rather
cleaning it

At all locations spill control measures are to be provide, URUT-3 sand can be provied at LO stations

Demin water tank dyke at Amm-2 was not as per standard / not fulfilling its design intent, also has lot of
damaged tiles which can result in soil contamination
Issue of dust mask type to be closed with HSE for use at PM&S

EMS 02 training sessions to be planned for NMPTS and MPTS


Waste segregation awareness sessions to be continued
D-level Trainings to be continuied
EMS Quiz - Do You know , series to be continued
IFC/SEQS standards to be shared with all
AIRAs to be discused in D-levels
Area oeprators awareness on area specific emissions to be enhanced
CFP and WFP number targets and goals to be shaerd in Trainings, D-level, shifts

Issue to be taken with HSE/Process to introduce spot sampling regeime of SEQS,Non SEQS Stream
MOC-P documents to be revied on all unit and any deficiencies found to be removed
Accountability data to be made available
motivation/Aprriciation data to be made avilable
Urut-1 operational safety & environmental review is suggested (A WHAT IF can be done to assess risks &
develop mitigation measures)

List of redundant equipment to be prepared and plan to be finalized for removal of redundant equipments

R-101 lining is suspected thinning, need to address on priority


Amm-3 Amm-2 URUT-3 URUT-1 Urea-2 PM&S
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NA In Progress NA NA NA NA
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NA NA NA In Progress NA NA
EMS 2nd Party Audit Action
In Progress
Complete
Items
Amm-3 PM&S Urea-2

Amm-2 URUT-1 URUT-3


t Action In Progress Complete
Amm-3 57 1 URUT-1
In Progress Complete
Amm-2 59 0 Urea-2
In Progress Complete
URUT-3 55 0 PM&S
Urea-2

URUT-3
In Progress Complete
60 0
In Progress Complete
60 0
In Progress Complete
53 0

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