SAFEWORK PRACTICES EQUIVALENCY PROCEDURE FOR ACCESSING FLOATING ROOF TANKS ON STORAGE TANKS IN SERVICE CAT A-2 SOP #33

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1 SUNCOR ENERGY PRODUCTS DISTRIBUTION TERMINAL OPERATING MANUAL STANDARD OPERATING PROCEDURE SAFEWORK PRACTICES EQUIVALENCY PROCEDURE FOR ACCESSING FLOATING ROOF TANKS ON STORAGE TANKS IN SERVICE Date Issued: November 2012 Revision Date: November 2012 Review Date: November 2015 Revision # Initial Issue 1.0 PURPOSE Descent onto an in-service floating roof is considered a confined space entry and as such all requirements of Cat A-1 SOP #01, Confined Space Entry must be adhered to. However since the tank is still in service and not fully purged and isolated, an equivalent means of protection for the workers must be created. This procedure establishes guidelines and identifies equivalent levels of protection for individuals performing Cold Work involving descent onto floating roofs of storage tanks while in service within Distribution. 2.0 SCOPE This Standard Operating Procedure shall apply to all employees and contractors at Suncor Energy Distribution Terminals who are required to descend onto an in service floating roof. References in this document to Suncor Personnel include directors, officers, employees, contract workers, consultants and agents of Suncor. The scope of this document is to define and communicate the precautions and requirements that involve descent onto internal floating roofs of in service petroleum tanks by Suncor Personnel and applicable Contractors working within Distribution Page 1 of 14

2 3.0 REFERENCED DOCUMENTS API Publication 2026, Safe Access / Egress Involving Floating Roofs of Storage Tanks in Petroleum Service API Standard 2015, Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks API Recommended Practice 2016, Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks. NFPA 3256, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning or Repair. OEMS Element 9, Operational & Maintenance Controls PSM Standard, Operating & Safe Work Procedures, CO-S12A Distribution Standard Operating Procedure, Mechanical Isolation, SOP Cat A-1, SOP #03 Distribution Standard Operating Procedure, Electrical Isolation, SOP Cat A-2, SOP #09 Distribution Standard Operating Procedure, Work Permitting, Cat A-1, SOP #06 Distribution Standard Operating Procedure, Personal Protective Equipment, Distribution Standard Operating Procedure, Atmospheric Testing, Cat A-2, SOP #01 Distribution Standard Operating Procedure, Confined Space Entry, Cat A-1, SOP #01 This document applies to Suncor Personnel and Contractors who are working within Distribution Terminals. References in this document to Suncor Personnel include directors, officers, employees, contract workers, consultants and agents of Suncor. 4.0 RESPONSIBILITIES Terminal Management; It is the responsibility of Terminal Management, and the Contractor Supervisor to ensure that safe working conditions are pre-planned, prepared, and maintained during the entire confined space entry Responsible for ensuring full implementation and compliance of this standard operating procedure. Responsible for providing all lock-out hardware and tags that are required for compliance with this standard. Responsible to complete regular audits of confined space activities and document findings in Suncor reporting tool. Initial Issue Page 2 of 14

3 Responsible to ensure all Terminal Employees who are required to perform the requirements of this confined space procedure as part of their normal job function are verified for competency on an annual basis. developing and explaining the scope of work to be completed, the equipment number, service, and location; attending the confined space pre-job meeting; providing schematic drawings for the vessel internals if required/requested, identifying any known hazards, and determining the job priorities. Ensure all documents related to Confined Space Entry are retained for a minimum 1 year period. Contractor Supervisor or Job Foreman: Responsible to ensure full compliance with this procedure. Ensuring that all workers are adequately trained and qualified, as per this Standard Operating Procedure; Ensuring that, prior to entry into a confined space, all personnel assigned to the job are familiar with the applicable provisions of this Standard Operating Procedure Ensuring that, when respiratory protective equipment or any other PPE is required, the workers designated for the confined space entry and the Safety Watch have adequate training in its use application and any known limitations; Ensuring that all personnel involved with the entry are made aware of the layout of the confined space, and any hazards that could be encountered during work in the confined space; Confirm that a Safe Work Permit has been issued for Confined Space Entry according to the Work Permitting Standard Operating Procedure and utilized the Pre Entry documentation for reference. Ensure that the preparation and precautions are acceptable, understood and agreed to before accepting the Safe Work Permit for Confined Space Entry. Ensuring that the pre-job / pre-entry meetings are held and that the Confined Space Entry Checklists and Atmospheric Testing Logs are completed and retained until job completion; Being aware of and following all applicable Suncor Energy and Occupational Health and Safety Regulations. Ensuring a copy of the Confined Space Entry checklist and Work Permit are posted or readily available at the entrance to the Confined Space. Ensuring all requirements under the Work Permitting Standard Operating Procedure are complied with. Initial Issue Page 3 of 14

4 Operating Authority; Responsible to ensure full compliance with this procedure. Ensuring that the confined space has been properly prepared for entry; including the Danger Confined Space are suitable affixed at all entrances to the confined space. Visit work site with Performing Authority and review requirements of the confined space entry including the isolation points. Notify the Performing Authority of any changing conditions or potential impacts to the work area. Complying with atmosphere testing procedures and performing gas testing to determine atmospheric conditions. Ensuring all valves, MOV s and drain lines are in the appropriate position to prevent movement into or out of the tank Applying first locks and tags on associated equipment. Ensuring the tank has been in a static condition for a minimum of 1 hour Ensuring the tank is at it s high fill position Preparing and issuing the safe work permit. Being aware of the actual and potential hazards of the confined space. Being competent in (i.e. adequately qualified, trained, and experienced to perform the work safely) the proper procedures and precautions required for entry, and the importance of ensuring that these are followed; Ensuring that the person(s) accepting the permit understands the actual and potential hazards involved in the work area; Suspending the permit if the safe conditions on which the permit was issued cannot be maintained; Ensuring that the confined space is evacuated if the permit is suspended; Ensuring all entrances to the confined space are suitably barricaded and tagged at the end of each work period. Familiar with the configuration of the confined space; Trained in the selection and use of personal protective equipment; Be outfitted in applicable PPE for known and anticipated hazards and shall have a standby present. Initial Issue Page 4 of 14

5 Performing Authority; Responsible to ensure full compliance with this procedure. Responsible to review and accept the Safe Work Permit on behalf of themselves or on behalf of associated Workers who will be required to complete work under that permit. Responsible to verify that all sources of energy are isolated. Visit work site with Operating Authority and review requirements of the confined space entry including the isolation points. Complying with atmosphere testing procedures and performing gas testing to determine atmospheric conditions. Notify the Operating Authority of any changing conditions or potential impacts to the work area. Comply with all aspects of Mechanical Isolation, ie install all the appropriate locks and tags. Abide by all conditions of the work permit. Perform task as outlined on the Safe Work Permit in a safe and responsible manner. Workers entering the confined space; Abide by all conditions of the Safe Work Permit. Perform task as outlined on the Safe Work Permit in a safe and responsible manner. Notify the Operating Authority of any changing conditions or potential impacts to the work area. Install all the appropriate locks and tags. Hold a valid contractor orientation status and comply with all terminal rules and regulations. Follow the conditions detailed on the permit; Attend the pre- entry job meeting, as per Part II of the Confined Space Entry checklist.; Be informed of the actual and potential hazards to be encountered in the confined space; Use tools and equipment that are in good condition; Be competent (i.e. adequately qualified, trained, and experienced to perform the work safely) and/ or directly supervised by a competent worker; Be familiar with the configuration of the confined space; Be trained in the selection, care and use of applicable PPE; Be instructed on the proper procedures and precautions required for entry and the importance of ensuring that these are followed. Immediately comply with all requests of the Safety Watch Initial Issue Page 5 of 14

6 Safety Watch is responsible: Responsible to ensure full compliance with this procedure. Being familiar with the type of work to be completed, the configuration of the confined space and their role in the rescue procedure as identified on Part II of the Confined Space Entry Checklist. Ensure ALL workers entering the confined space are in compliance with the PPE requirements. Raise an alarm in the event of an emergency in the confined space. To NEVER enter the confined space in an attempt to rescue. Keep access and egress to and from confined space clear at all times. Be identified to ALL Workers. Watch for hazards inside and outside the confined space. Communicate any change in working conditions to the personnel in the confined space. Wear all required PPE and a reflective vest identifying him / her as Safety Watch Verify worker entry into the Confined Space with Part II of Pre Entry Meeting Checklist. Remain stationed at entry to confined space at all times. Maintain detailed log of work entry and egress into the confined space. Keep unauthorized people out of the space. Arrange for addition atmospheric testing as required by Part II of the Confined Space Entry Checklist. Maintain continuous voice or visual contact with workers in the confined space. Never leave entry until relieved by a qualified individual. Have a method of communication in the event of an emergency, (radio, air horn). Barricade and tag entrance to confined space when space is going to be unoccupied and unattended, ( breaks, lunch ). Ensure barricades and tags are affixed on alternate entrances to the confined space. Order authorized entrants out of the space when: conditions not allowed in the confined space are occurring observes behavioural effects of hazard exposure detects an uncontrolled hazard when an emergency occurs in the terminal Arrange for additional gas testing at intervals specified on Pre Entry or after space has been left unoccupied. Record all gas test results and time on Entry log Date, sign and return completed entry log to Operating Authority at the end of the working day. Initial Issue Page 6 of 14

7 5.0 PRECAUTIONARY STATEMENTS 5.1 Specific Hazards Typical hazards that may be encountered while executing confined space entry may include; Ergonomic Hazards Awkward Body Position Parts of Body in Line of Fire Work Environment Hazards Limited access / egress Exposure to electrical hazards Exposure to hydrocarbons or other chemicals Changes in lumination inside the roof area from the outside environment Danger from tank contents building up on access ladder rungs Respiratory hazards from bird droppings Slips or trips Oxygen Deficiency Falling Objects Personal Limitations Distractions in work area Confusing instructions No / lack of training Fitness for duty 5.2 Training a) Proper training and demonstrated competency are prerequisites to performing this Standard Operating Procedure. Every Worker involved with the entry into the confined space shall be trained by a person with adequate knowledge, training and experience Initial Issue Page 7 of 14

8 All employees who are required to utilize this procedure must review and successfully complete competency verification on an annual basis. Written records of Confined Space Training for each Employee must be kept on file and available for review. Training shall include; the recognition of hazards associated with confined spaces safe work practices for working in confined spaces and for performing related work. 5.3 Personal Protective Equipment Personal protective equipment as outlined in Distribution Standard Operating Procedure, Cat A- 1, SOP #10 or as specified in the Safe Work Permit depending on the work to be completed as per the job scope requirements. All personnel accessing the roof area for inspection of primary seal inspections must use fresh air. For tanks in sour service, fresh air must be used for ALL work. All workers required to donn SCBA or SABA must be certified in such equipment All entrants onto the floating roofs MUST wear a full body harness, attached to a life line, with the free end connected to a suitable anchor point 6.0 SUSTAINMENT AND CONTINUAL IMPROVEMENT This document is classified in Process Safety terms as a Safework Practice Procedure and as such must comply with the Safework Practice Standard as outlined in Distribution Procedure Program, Cat A-3, SOP #01. Nanaimo Terminal Management is to initiate document review process. To ensure this Standard Operating Procedure documents meets all applicable OEMS / PSM standards, this document is to be reviewed at a frequency not to exceed 3 years or when conditions change to warrant a review Initial Issue Page 8 of 14

9 7.0 DEFINITIONS Acceptable Atmospheric Levels; means that, (a) the atmospheric does not have a concentration of any explosive or flammable gas or vapour at above 1% of the LEL (b) the oxygen content of the atmosphere is at least 19.5 per cent but not more than 23 per cent by volume, normal atmospheric oxygen levels are 20.9%, and (c) the exposure to atmospheric contaminants does not exceed any applicable level set out in a regulations made under the OHSA or it s regulations (d) Test results that that are outside these parameters will require specially trained and certified personnel, and a detailed work plan to be available before entry in permitted Atmospheric Hazards; means, (a) the accumulation of flammable, combustible or explosive agents detected at above 1% of the LEL (b) an oxygen content in the atmosphere that is less than 19.5 per cent or more than 23 percent by volume, or (c) the accumulation of atmospheric contaminants, including gases, vapours, fumes, dusts or mists, that could: (i) result in acute health effects that pose an immediate threat to life, or (ii) interfere with a person s ability to escape unaided from a confined space, or (iii) exceed any applicable level set out in a regulations made under the OHSA or it s Regulations. Reference ACIGH tables for atmospheric contaminant exposure levels to cover those not listed in the updated 2012 OH&S table. Confined Space; According to the definition, there are five critical conditions that must be satisfied for a work space to qualify as a confined space: 1. Be enclosed or partially enclosed 2. Not be designed nor intended for continuous human occupancy 3. Have limited or restricted means for access / egress that may complicate the provision of first aid, evacuation, rescue or other emergency response. 4. Be large enough and so configured that a worker could enter to perform assigned work. 5. Where the potential for a hazardous atmosphere may exist. Floating roof tank; Any vertical open-top or covered cylindrical atmospheric vessel that is equipped with a floating roof. Initial Issue Page 9 of 14

10 In Service Tank; A tank containing an inventory of liquid that is either static or in the process of receiving / discharging liquid or mixing / circulating it s contents. High Roof Position; External Floating Roof Tank the position of the floating roof when the top of the pontoon is within 4 feet of the tank shell. Internal Floating Roof Tank The established operating maximum fill level of the tank. Low Roof Position; The position of the floating roof when it is 8 feet or less above it s minimum design elevation. Lower Explosive Limit; The lowest concentration of gas or vapour that will burn or explode if an ignition source is present at ambient temperature. Terminal Management; highest level of authority on site, may be manager, supervisor or a delegated responsibility Cold Work; means work that is not capable of producing a source of ignition. Hot Work; is generally categorized as any work in which heat is used or generated of such intensity that it is possible to ignite flammable liquids, vapours, gases or combustibles. Static Condition; A condition when the tank is not receiving / discharging liquid or mixing / circulating it s contents. Tank Isolation; The condition that exists when all tank valves are isolated as necessary to preclude the movement of material in or out of the tank, and all electrical devices are deenergized. Initial Issue Page 10 of 14

11 8.0 PROCEDURAL REQUIREMENTS 1. High Roof Position Work must be scheduled for a period when the floating roof is in the High Roof Position. Once the tank has reached the high level, a minimum of hours must be allowed for dissipation of vapours before entry onto the roof will be allowed. 2. Management of Change Entry onto the roof at a lower level other than specified in (1) will only be allowed after a Management of Change has been completed and approved. 3. Tools Only non-sparking, air powered or hand tools will be used. 4. Ventilation Continuous forced-air mechanical ventilation may be required to maintain a safe atmosphere above the internal floating roof. 5. Fall Potential The potential for falling through a roof and or floors of pontoons shall be evaluated during the planning stage of each job. Past inspection records must be consulted to satisfy this concern. Special precautions must be implemented to prevent falling through the roof any time a tank roof is suspected to be weak. 6. Tank Isolation; Tank valves that would allow movement of product in or out of the tank must be chained closed and tagged. Motorized valves must be de-energized and the hand-wheel chained closed and tagged. No product movement into or out of the tank during the confined space entry. 7. Piping; Any piping connected to the shell above the level of the floating roof must be blanked, except any sample taps and any overflow piping. Initial Issue Page 11 of 14

12 8. Electrical Equipment; All electrical equipment such as mixers, motorized valves, circulating pumps, must be deenergized. 9. Atmospheric Testing; Atmospheric testing of the roof area shall be performed prior to descent onto the floating roof. If work is to be performed near roof seals or other openings, additional tests must be performed to identify any potential hazards and assure that the atmosphere in the work area is not in the flammable range. Appropriate PPE shall be utilized while evaluating the atmosphere of the work area. The person conducting the atmospheric test must be protected as if performing work, I.e. SCBA, SABA, harness, life line, and utilize a back-up person Refer to Distribution SOP, Cat A-2, SOP #1, Atmospheric Testing. Continuous atmospheric testing must be worn by the entrants. No entry is to be allowed if the LEL level is greater than 10%. 10. Tank Level; Tank level must be held static for a minimum one hour prior to the gas testing. 11. Stand-By Person; Must be stationed immediately outside the work area to monitor activities on the floating roof. The Stand-By Person shall be equipped with; A radio capable of activating emergency response An air horn to alert personnel on the roof An approved safety vest for clear identification 12. Rescue Equipment; Must be staged at the entry point, available and ready for use prior to entry. 13. Electrical Equipment; All electrical equipment to be used on the floating roof must be rated for use in Class I, Div II atmospheres. Initial Issue Page 12 of 14

13 14. Adverse Weather; Adverse weather conditions will affect work being done on tank roofs. If lightning is observed in the vicinity, all elevated work shall be suspended and all Personnel moved to a safe area at ground level. Work may resume after 30 minutes or more have elapsed since the last strike. 15. Weight Distribution Weight distribution should be considered at all times and excessive weight concentrations should be avoided. Consideration should be given to placement of planks or plywood to improve weight distribution. 16. Cold Work Only cold work will be authorized on the roofs of floating roof tanks in hydrocarbon service. Tasks may include but not limited to; Adjustment of roof legs. Adjustment of vacuum breaker Adjustment / repair of level gauge Inspection of floating roof, pontoons, seals and fire protection system Unplugging of water drains Removing liquid or debris Adjustment / repair of anti rotation guides UT Thickness of roof and pontoons Mechanical repair of roof components Initial Issue Page 13 of 14

14 DATE AUTHOR DESCRIPTION REVISION November 2012 R. Rattray New document issue. Initial Issue Initial Issue Page 14 of 14

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