Pentane Standard. Standard Administrative. Document Owner (Title): Director, Environment & Regulatory. Summary of Changes

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1 Pentane Standard Document Number: RGS0028A Revision Date: 2017/01/23 Revision: 2 Review Cycle: 3 Years Standard Administrative Document Owner (Title): Director, Environment & Regulatory Applies To: Wood Buffalo Region Summary of Changes Rev No. Section Changed Revision Made 1 - New Document 2 References/ Sections 4, 5 Added personal gas detector information Scope This standard applies to all Suncor Energy Inc. employees, contractors, vendors and visitors and is part of Suncor s EHS management system. Purpose This standard is intended to ensure all Suncor employees and contractors in the Wood Buffalo region engaged in any work that could potentially lead to pentane exposure, are fully knowledgeable of the correct procedures to be followed to achieve full protection. Suncor commits to being diligent in our efforts to select the most effective control technologies available, and to ensure the best practices, as described in this standard are followed in the Wood Buffalo Region in line with Suncor s OEMS Element 3. This standard is intended to provide a framework for managing pentane in the workplace and shall be achieved through implementation of an ongoing program consisting of pentane hazard identification, evaluation, control, and worker surveillance. Considering the dynamic nature of the work process, equipment and environment, ongoing preventive maintenance shall play a key role in controlling worker exposure to pentane. Compliance This document applies to work performed at Suncor Energy operating sites in the Wood Buffalo Region that includes but is not limited to Base Plant, Firebag, MacKay River, Fort Hills, Pipelines and East Tank Farm. Page 1 of 9

2 Roles and Responsibilities The following individuals and groups have the following roles and responsibilities: Document Owner Ensures this document is reviewed according to the required revision cycle. Ensures the document is updated to accommodate changes to Suncor, provincial, and federal regulation. Ensures the document is updated to mitigate risks found as the result of an incident. Document Approver Ensures this standard is necessary and that it aligns with management and company direction. Employees Participate in Industrial Hygiene air monitoring assessments Participate in Air Purifying Respirator Training Wear appropriate PPE when required Comply with LMS0052A Respiratory Protection Standard Supervisors Ensures employees are given adequate time to participate in Industrial Hygiene air monitoring assessments. Ensure employees are given adequate time to participate in necessary training. Ensure employees wear adequate PPE when required Implement work practices to keep workers exposure as low as practicable Contractors Provide fit testing to their employees Provide Air Purifying Respirator Training to their employees Conduct personal monitoring on their employees Ensure their employees wear adequate PPE when required Implements work practices to keep workers exposure as low as possible Business Area Management Ensures employees meet the necessary training requirements. Industrial Hygiene Performs air sampling for pentane on a regular basis Communicate sampling results to affected employees and their supervisors in a timely manner Assists workers/supervisors and management in the selection of RPE and other control methods Recommend work practices and other controls to keep the workers exposure as low as possible. Page 2 of 9

3 References LMS0052A Respiratory Protection Standard RGS0008A Gas Detection for Hazardous Atmospheres Occupational Safety & Health Administration. Pentane. Chemical Book. Pentane. Centre for Disease Control. Occupational Health Guideline for Pentane ACGIH TLV Documentation for Pentane Terms, Definitions and Acronyms The following terms, definitions and acronyms are used in this standard: American Industrial Hygiene Association (AIHA) Ceiling Occupational Exposure Limit (Ceiling) Immediately Dangerous to Life and Health (IDLH) Lower Explosive Limit (LEL) A US non-profit organization that provides Industrial Hygiene information and resources. The concentration of a substance that must not be exceeded at any time. The limit is indicated by a C in in Schedule 1, Table 2 of the Alberta Occupational Health & Safety Code. Circumstances in which the atmosphere is deficient in oxygen or the concentration of a harmful substance in the atmosphere: Is an immediate threat to life May affect health irreversibly May have future adverse effects on health May interfere with a worker s ability to escape from a dangerous atmosphere. The lower value of the range of concentrations of a substance at which, in a mixture with air, may ignite. National Institute for Occupational Safety and Health (NIOSH) Occupational Exposure Limit (OEL) The U.S. federal agency responsible for conducting research and making recommendations for the prevention of work-related injury and illness An upper limit of airborne concentrations of various contaminants in the workplace. Typically, Occupational Exposure Limits are airborne concentrations averaged over an 8 hour work day and are reported as time weighted average concentrations. For some substances, a ceiling limit is applicable. If any of these are exceeded, a potential hazard from that substance is presumed to exist. Page 3 of 9

4 Respiratory Protective Equipment (RPE) Short Term Exposure Limit (STEL) Volatile organic compounds (VOC) Air purifying respirators (N95, half mask, full face) or air supplied respirators A 15-minute time weighted average of airborne concentration of a contaminant to which it is believed that workers can be continuously exposed for a short period of time without suffering from: Irritation chronic or irreversible tissue damage dose-rate dependent toxic effects narcosis of sufficient degree to increase the likelihood of accidental injury, impaired self-rescue or materially reduced work efficiency. Organic compounds containing one or more carbon atoms that have high vapour pressures and therefore evaporate readily to the atmosphere. Standard 1. Technical Information 1.1 Pentane is a naturally occurring hydrocarbon derived from petroleum. It is a colourless liquid that has an odour similar to gasoline. The boiling point is approximately 36 C. The explosive range of pentane is %. The odour threshold of pentane vapour has been reported by the AIHA as 1000 ppm, while other sources state an odour threshold of 2.2 ppm. 1.2 Pentane is less dense than water and is insoluble in water, therefore when mixed with water it will separate on top. Pentane vapours are denser than air and therefore will settle in low lying areas. 1.3 Pentane is highly flammable. Toxic gases and vapours (such as carbon monoxide) may be released in a fire involving pentane. 1.4 Pentane is incompatible with strong oxidizers, strong acids, alkalis, oxygen and combustible material. Mixtures with chlorine gas have produced explosions. Pentane is incompatible with some forms of plastics, rubber and coatings 1.5 In industry pentane is used as a blower in the creation of plastic foams, as a working medium in geothermal power station, as an additive to some refrigerants and as an active ingredient in some pesticides. It is often used as a solvent in laboratories as it evaporates easily. 1.6 Pentane is used as an additive in the process at Fort Hills (as an isopentane and n-pentane blend). It is also used in various locations in Upstream as a gas for LEL calibration and bump testing Page 4 of 9

5 1.7 At Fort Hills, pentane is transported to site via truck and is offloaded into storage bullets. From there it is introduced into the process. Those conducting the following tasks have been identified as having the potential to be exposed to pentane: offloading pentane preparing for maintenance and maintenance of pentane-containing pumps, piping and process vessels working on or adjacent to leaks in the process collecting and analysing samples 2. Health Effects 2.1 The exposure routes for pentane are inhalation, ingestion, skin contact and eye contact. The target organs are eyes, skin, respiratory system and central nervous system. Short Term Health Effects 2.2 Drowsiness, headache, confusion Irritation of the eyes and nose, cough, shortness of breath Unconsciousness and death at very high concentrations Long Term Health Effects 2.3 Drying and cracking of the skin Numbness, and weakness in the hands and feet 3. Occupational Exposure Limit Alberta OHS Code (2009) 3.1 Suncor Energy uses the following Occupational Exposure Limits (OELs) based on the Alberta OHS Code: 600 ppm for an 8-hour period 300 ppm for a 12-hour period There is no short term exposure limit (STEL) or ceiling limit for pentane IDLH 3.2 Section 4 of the Alberta OHS Code also states the following: An employer must ensure that a worker s exposure to any substance listed in Schedule 1, Table 2 is kept as low as reasonably practicable, and does not exceed its occupational exposure limit (OEL). Page 5 of 9

6 IDLH 3.3 In Alberta there is no regulatory requirement for workers exposed to pentane to have a health assessment. There are no additional regulatory requirements specific to pentane. IDLH 3.4 The IDLH (immediately dangerous to life and health) for pentane is 1500 ppm. NIOSH bases the IDLH on 10% of the lower explosive limit. NIOSH states that no toxicity is reported at this level and breathing concentration of 5000 ppm for 10 minutes did not cause dizziness in human volunteers. 4. Evaluation Note: prior to exposure monitoring a risk assessment will be done according to generally accepted Industrial Hygiene principles. Real Time Detection 4.1 Operational areas with a pentane hazard have fixed gas detection systems. Fort Hills has systems in the necessary operating areas which detect LEL and will alarm at 10% and 20% LEL for the point detectors or 1 LEL-meter and 2 LELmeter for open path detectors. 4.2 If the presence of pentane is suspected in a vessel or area, gas testing shall be conducted by operations and results communicated to Industrial Hygiene to determine the proper control measures. Testing shall be completed using a portable gas detector measuring LEL, Photoionization Detector (PID) or other pentane measuring methods, according to the monitoring equipment manufacturer s specifications. Measurements should be taken in the atmosphere inside of the vessel or areas where personnel are working. Equipment or areas that have potential for presence of pentane in exceedance of regulatory limits. If the equipment exceeds the criteria level, the equipment or area shall have barrier tape installed as per section 6. Work conducted in or on pentane containing equipment or area must utilize the controls listed in section 5 and must follow the safe work procedure as detailed in section 6. Sample results of periodic monitoring from pentane testing by operations will be recorded on the safe work permit. 4.3 Personal gas detectors are required for all personnel entering pentane hazardous areas. Air Monitoring 4.4 Where there is a potential for pentane exposure for a task that has never been evaluated, an Industrial Hygienist or technologist will conduct air monitoring according to strategies approved by a Suncor Industrial Hygienist Page 6 of 9

7 Air Monitoring 4.5 Air monitoring results will be used to: Ensure that personal exposure to pentane do not exceed established regulatory limits Determine the effectiveness of specific engineering/administrative controls of work practice in minimizing exposure to pentane Determine adequacy of selected respiratory protection 4.6 Records of air monitoring results will be maintained in the Industrial Hygiene and Medgate database, and communicated to the business area. Health Assessment Requirements 4.6 There are no specific health assessment requirements for pentane exposure. The following general health assessments will be conducted for workers needing to wear a respirator for pentane: 1. General health assessment (including occupational exposure history to Pentane) will be conducted as part of the hiring process 2. Fitness to wear a respirator evaluation 3. Quantitative respirator fit testing (based on Suncor Respiratory Standard LMS0052A) 4. Abnormal findings will be reviewed by the Occupational Health Physician and will include recommendations for follow-up if required. 5. Controls Engineering controls Administrative Controls If pentane is identified in a vessel, equipment or area, all feasible measures must be taken to prevent pentane from becoming airborne. Maintenance activities associated with equipment cleaning or repairs may disturb pentane to create a health hazard. The selection of the most appropriate control option(s) shall be governed by the specific task and specific work area and will be based on results from the initial evaluation. Possible controls include using engineered ventilation controls, air filtration, and closure of emission points that allows control of the concentration to levels below the OEL. All equipment or areas identified as pentane hazardous by testing as per Section 4 shall have restricted access as per Section 6.3. This restriction shall be removed once the equipment or area is closed and returned to service or testing indicates concentrations are below the OEL. In confirmed pentane areas, ensure that the pentane exposure hazard is evaluated when conducting Field Level Hazard Assessment (FLHA). Page 7 of 9

8 Personal Protective Equipment 5.5 All personnel entering Fort Hills Secondary Extraction must wear a personal gas detector due to the pentane hazard. Personal gas detector usage must meet the Gas Detection for Hazardous Atmospheres Standard RGS0008A. 5.6 Respiratory protective equipment is used to protect workers from inhaling airborne vapours. There are many types of respirators available. It is important to select the correct level of respiratory protection based on the type of work being done and the airborne concentrations of pentane at the work site. Refer to Suncor s Respiratory Protection Standard LMS0052A, when considering suitable RPE to be used for a particular task. The need for a respirator and respirator selection depends upon the airborne concentrations of pentane in the workplace. 5.7 The following table highlights the type of respirator to be used based on pentane concentration. In areas where the flammability is greater than 10% (1400 ppm pentane) but less than 20% (2800 ppm pentane) of the Lower Explosive limit, a supplied air respirator must be used. A worker must not enter or work in an area if more than 20% (2800 ppm pentane) of the LEL of a flammable or explosive substance is present in the atmosphere. This is reflected in the table below: Shift Length* Concentration (ppm) Mask Type 8 hours Half mask respirator with organic vapour cartridge Supplied air respirator (SAR) >2800** Workers cannot be present in area 10 hours Half mask respirator with organic vapour cartridge Supplied air respirator (SAR) >3000** Workers cannot be present in area 12 hours Half mask respirator with organic vapour cartridge Supplied air respirator (SAR) >2800** Workers cannot be present in area *regular shift length worker regardless of pentane exposure duration **or if there is a possibility of an uncontrolled release or if exposure levels are unknown 5.8 For non-fire emergencies, positive pressure SCBA and structural firefighter s protective clothing will provide only limited protection. 5.9 Appropriate RPE is to be donned in the laboratory when conducting sample analysis should existing engineering controls such as local exhaust ventilation or fume hoods be ineffective in removing pentane vapours from the worker s breathing zone. Page 8 of 9

9 5.10 Workers who may be exposed to pentane via skin contact or splashing shall ensure that they wear protective clothing that covers and protects the arms and legs. The specific level of chemical protective clothing required will depend on the conditions. The level of protection selected should be based on the potential pentane concentration and likelihood of contact. It could range from no chemical protective clothing being required, such as when pentane in a mixture is handled in closed systems and there is no personnel exposure, to nitrile gloves, a face shield and disposable coveralls as would be the case in certain spill situations Close fitting goggles or face shield shall be worn to protect the eyes from irritation or splashes. Where skin contact with liquids containing pentane occurs, the area shall be thoroughly washed with soap and water immediately Some general chemical protective clothing selection recommendations for exposure to pentane include nitrile (or similar material). 6. Safe Work Practices 6.1 Safe work practice as part of operational controls should be applied to control potential pentane exposure either from process equipment or in affected areas. A controlled work area must be established and access must be physically restricted by the use of red flagging labelled "DANGER - DO NOT ENTER", forming a perimeter around the work area where the concentration of the vapour is more than 600 ppm. The flagging is to be in place before the work begins, and shall be tagged and managed as per LMS0019A Erection, Identification and Removal of Flagging. In pentane hazardous sites, exposures shall be evaluated as per Section 4. Personnel shall wear PPE as identified in Section 5.6. Dispose of all hydrocarbon liquids in the appropriate disposal waste water system; never pour hydrocarbons down a water sink. All pentane waste cylinders/sample bottles shall be segregated, labelled, stored, disposed or reused, using established procedures as approved by Suncor Environmental Affairs. On skin or eye contact with pentane, immediately wash or shower for 15 minutes. Specific operational and emergency procedures related to flammability of pentane should be developed and used for pentane hazardous areas. End of Standard Page 9 of 9

10 The following individuals have approved and signed this document. UserName: Shamini Samuel (ssamuel) Title: Mgr Regional IH & Compliance Date: Wednesday, 01 February 2017, 07:07 PM Mountain Time Meaning: Approver 1 Signed ================================================