March 17, 2003

Meeting Summary/Action Register

Presentations:
Presentation on Flaring
Mr. Dan Jason, LHC3 (Light Hydrocarbon 3) Production Leader, explained that light hydrocarbons (ethylene and propylene), are processed at the LHC3 plant as intermediates for production of other products manufactured in the company. Flaring is the controlled combustion of industrial gases. A flare is a safety device to prevent the direct release of gases into the air and it is an emission reduction device. It is used during plant startups and shutdowns, during process interruptions, when maintenance or specific operational tasks are being performed, and during normal operations for process vents.

Mr. Jason stated that the LHC2 and LHC3 plants process petroleum and/or natural gases to make ethylene and other intermediates. These plants provide feedstock for one-half of the other plants on the Plaquemine site. Ethylene is a component of antifreeze. It is also used to make plastics, vinyl acetate for paint, and ingredients for cleaners. The LHC2 and LHC3 plants employ 150 Dow employees and 120 contractors. Five years training and experience are required for full qualification as a Dow operation technician. Dow is the world’s largest ethylene producer, with 8 sites worldwide. The LHC plants are among Dow’s largest and most complex. The Plaquemine site was the first flexible feedstock site in the company, providing economic efficiency.

Safety and protecting the environment are Dow’s first priority, and the company is always looking for ways to improve the processes which includes reducing flaring. Reasons for reducing flaring are as follows:

1. Flaring affects the community by disturbing neighbors.
2. It affects the company because it wastes materials; and
3. It affects the environment because some gases are released into the environment.

Dow has planned maintenance shut downs that will require flaring in 2004 and 2005. Although the flares stay lit continuously like a pilot light on a stove, flaring may increase when it is necessary.

Ms. Crystal King stated that there were two flaring incidents at the LHC2 plant in 2000 – a compressor problem and a leak in a piping header. During a maintenance turnaround from October 2002 through February 2003, flaring was visible for about 2 weeks.

Mr. Jason stated that “Six Sigma” training is a new way of approaching problems. Dow employees are trained for 3 months to learn the new methods to solve problems. As a result of a Six Sigma project, a new flare tip, which will reduce noise, health and smoke, will be installed at the LHC3 plant during the scheduled 2005 maintenance shutdown. Mr. Shipp stated that flare tip replacement must be scheduled when the plant can be shut down completely.

Mr. Jason stated that information about flaring is prepared for media advisories and questions can be asked through a 24-hour hotline, 685-2DOW or 353-2DOW.

Mr. Brian Brown, stated that the Engage® and Nordel® plants use hydrocarbons to produce synthetic rubber and high impact plastics which are used in auto belts, tubes, and trim, weather stripping for cars, and appliances, etc. The plant employs 75 Dow employees and 80-90 contract employees. The Engage® plant is scheduled for startup in April 2003. The flare associated with the Engage® and Nordel® plants is a safety and emission reduction device.

Mr. Jim Story, Plant Production Leader, stated that Vector® is the trade name for rubberized plastic pellets produced at the plant. They are sold to downstream users in the production of asphalt modification, shingling, adhesives and glues, peel and stick labels, glue sticks, label makers, etc. Through polymer modification, these plastics are used in conjunction with other products to produce yet another product. Some of these products include plastic lids, stretchy film, polymer non-latex gloves, webbing for packaging, and photo-polymer plates (used in high speed printing). Mr. Story stated that flaring is an integral part of the process. Once every 2 hours, the reactor vents to the flare, reducing hydrocarbon emissions.

Answers to Questions Included the Following:

1. Heavy hydrocarbons are found in crude oil.
2. A furnace is the place where raw materials are heated up; a cracker is the generic term for the process.
3. The furnace is fueled with natural gas some of which is made in the plant’s process.
4. Feedstock includes ethane, propane, and a naptha-based material. The feedstock is burned in a tube through a thermal reaction.
5. What is going on at a certain time in a plant determines when and how long flaring takes place. Different streams and processes determine the magnitude and duration of the flaring.
6. The size of equipment used in the plant is determined by what materials are to be separated (height) and the volume of materials (width).
7. Typical process interruptions can include the formation of ice in vessels and power and utility limitations.
8. Flaring is a safety device to help reduce emissions. It is a controlled process.
9. The unburned portion of the flare can react in the atmosphere to form ozone.
10. The EPA and DEQ permit flaring. All cases needing flaring are identified and flare performance defined. Steam is added to the flare for more efficient combustion and reduction of smoke.
11. Flaring is the safest way to handle flammable materials coming from the processes; emissions from pressure relief valves, for example, go into the flare instead of going into the atmosphere. The unburned portion is reported to both the EPA and DEQ.
12. Each flare has a different limit for emissions. Permitting limits have been reduced over the years.
13. The new flare at the Engage® plant has the same capacity as the existing flare used for the Nordel® plant but will accommodate both plants.

Mr. Shipp stated that all emissions in flares must be reported. He will provide specific information to CAP members, if requested.

Mr. David Graham stated that flaring permits are set at health-based limits. Dow operates at 2/3 of its allowable limits yearly. Monitoring at the site has not indicated any unhealthy matters due to flaring.

Responsible Care Presentation
Mr. Graham provided the panel with Responsible Care information for the period February 11 – March 17, 2003. There were 4 site OSHA injuries so far in 2003 and no injuries of Dow or contract employees. There were 4 DEQ audits during this reporting period, and no serious transportation incidents were reported. He stated that Dow recently won OSHA’s most significant award.

“Dow in the News” Presentation
Ms. Babin provided the panel with community updates. Upcoming events include the Iberville Relay for Life on April 4, Household Hazardous Materials Day and March of Dimes Walk American on April 26.

Mr. Shipp stated that because of the rise in natural gas prices, customers are paying more for Dow products. Up to this point, there has been a 30-40% price increase, which was passed along as a cost of doing business. Natural gas prices are climbing so quickly that Dow is unable to raise its prices as fast as is needed to keep up with the costs. Some of the plants are running at reduced capacity now.

The next Dow CAP meeting will be held on April 14, 2003, at 6:00 p.m.