Procedure No.: PA-020-0052 Page: 1 of 17 Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager Document Revision Change Table Revision Number Revision Description Revised By Revision Date 01 Changed Header and Footer VB 06/08 Procedure Reviewed (No Changes) TF 12/08 Reviewed No changes TD 01/12 02 Changed Coordinator to Supervisor; removed Area Team Lead DS 11/15
Procedure No.: PA-020-0052 Page: 2 of 17 1. PURPOSE This policy establishes requirements for inert confined space entry for the NROC Site. This policy will be used in addition to the Site s Confined Space Procedure (PA-020-0004). An Inert Entry is required when removing or loading catalyst, packing or desiccants that are pyrophoric in nature and could create a fire when coming in contact with air. 2. DEFINITIONS 2.1. Inert Entry Attendant An individual stationed outside the confined space who monitors the Authorized Entrants. 2.2. Authorized Entrant An individual who is authorized by the employer to enter a confined space. 2.3. Confined Spaces Spaces which can be bodily entered, have limited or restricted means of egress, are not designed for continuous employee occupancy, and have one or more of the following characteristics: Contain or have the potential to contain a hazardous atmosphere (such as having held flammable, explosive, acidic, caustic, toxic materials) or where oxygen enriched or deficient atmospheres or noxious odors may exist. Contain a material that has the potential for engulfing an entrant. Have an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section. Contain any other recognized serious safety or health hazards; such as ionizing radiation, electric shock, temperature extremes, or moving parts. Such spaces include, but are not limited to: tanks, tank trucks, tank cars, duct work, vats, tubs, hoppers, bins, boilers, kilns, cooling towers, stacks, chimneys, sewers, trenches, pits, manholes, elevated or ground flares, or other similar equipment/structures. This may also include structures greater than four feet in height, or excavation that are greater than four feet in depth that have limited or restricted means of egress.
Procedure No.: PA-020-0052 Page: 3 of 17 2. DEFINITIONS cont d 2.4. Immediately Dangerous to Life or Health ( IDLH ) Any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health interfere with an individual s ability to escape unaided from a confined space. Included in this definition is an oxygen deficient atmosphere containing less than 19.5 percent oxygen by volume. (Refer to the NIOSH Pocket Guide to Chemical Hazards for IDLH limits for toxic chemicals) 2.5. Entry Rescue A confined space rescue that must be performed by having the rescue team enter the confined space. 2.6. Inert Entry The action by which a person passes through an opening into a confined space that has been filled or is filled with an inert gas such as nitrogen. This constitutes a IDLH environment where proper set-up and execution of work and safety systems is critical. At the Port Arthur Site, Inert Entries are used for the unloading and loading of potentially pyrophoric catalyst, packing or desiccants. These entries are done in nitrogen environments. 2.7. Hazardous Atmosphere An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self rescue, injury or acute illness from one or more of the following causes: Flammable gas, vapor or mist in any detectable concentration using a calibrated combustible gas indicator operating in the percent range of sensitivity. Airborne oxygen concentration below 19.5% or above 21.0%. Atmospheric concentration of any substance for which a dose or permissible exposure limit is published in 29 CFR 1910 Subpart G, Occupational Health and Environmental Control, or in Subpart Z, Toxic and Hazardous Substances, and which could result in the employee exposure in excess of its dose or permissible exposure limit. Any other atmospheric condition that is immediately dangerous to life or health. NOTE: For air contaminants for which OSHA has not determined a dose or permissible exposure limit, other sources of information; such as, Material Safety Data Sheets, ACGIH TLVs, published information, and internal documents may provide guidance in establishing acceptable atmospheric conditions.
Procedure No.: PA-020-0052 Page: 4 of 17 2. DEFINITIONS cont d 2.8. Entry Supervisor The person responsible for determining if acceptable entry conditions are present where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required. At the Port Arthur Facility, the shift coordinator normally acts as the entry supervisor, with the exceptions of plant turnarounds or shutdowns when others may act in this capacity. 3. SCOPE 4. PROCEDURE 4.1. Contractor Selection The Texas Hub s Contractor Selection Procedure (EHS Texas Hub Procedure) will be followed. For Inert Entry Contractors, the following additional reviews/discussions are required in the areas of training, medical records, procedures, equipment inspections and management commitment. The contractor must demonstrate to BASF a clear commitment to Safety as a core value and an ongoing cycle of continuous improvement. The following are key components of this review process: 4.1.1. Conduct a detailed review of the training program during the initial review of any Inert Entry Contractor considered for addition to the Approved Contractor List. This review should include quality of training materials, review of training records, instructor qualifications, and experience requirements in each position. It is critical that specific personnel who will carry out the inert entry have adequate training and experience. 4.1.2. All contractors that perform Inert Entry work must have their Safety Program reviewed, including Inert Entry and Rescue Procedures, against the key requirements of this document. 4.1.3. Review fit test records to ensure that personnel working in breathing air are routinely examined for medical fitness as required by OSHA 29 CFR 1910.134. 4.1.4. Review inspection and test records for all breathing air equipment, Life Support Systems, emergency rescue equipment and gas testing equipment to ensure it is routinely inspected and tested.
Procedure No.: PA-020-0052 Page: 5 of 17 4.2. Management Presentation Management of contractors who perform Inert Entry work must make a presentation to BASF Site Management prior to award of contract and annually thereafter. The presentation should include, at a minimum: 4.2.1. Demonstration of Management Commitment to Safety Senior Management Site Visits for sole purpose of EHS review Company Organizational Chart Review Organizational Roles & Responsibilities 4.2.2. Environmental, Health and Safety Program Review Equipment Program (Inspection, Replacement/Upgrade Personnel (Training, Experience, Crew Size) Company History (Experience in Type and Scope of job) Auditing (Pre-Job, Execution, Follow-up Actions) Job Observation Program Hazard Recognition Program Incident Investigation and Follow-up (Review of contractor incidents with changes implemented & corrective action closure times.) Three year history of near miss incidents Three year history of Safety Statistics 4.3. Pre-Job Planning Because of the critical nature of inert entry, it is important that both BASF and the contractor work together. Each party has critical tasks they must complete prior to starting the inert entry. Pre-planning every aspect of the job is required in order to complete the job successfully. Company Management Although a qualified contractor will perform the inert entry, BASF employees must be involved in the operation to provide the contractor with the proper facility knowledge, job expectations and accountability to complete the job safely. 4.3.1. Contractors written site safety and emergency/rescue plan will be reviewed by Shift Supervisor and Site EHS personnel before the start of work.
Procedure No.: PA-020-0052 Page: 6 of 17 4.3. Pre-Job Planning cont d 4.3.2. Prior to inert entry, the Area Maintenance Coordinator will coordinate a meeting to discuss the contractor s written plan for performing work under inert conditions. Meeting attendees shall include: Shift Supervisor Contractor Safety Representative EHS Representative Contractor Foreman Area Operations Coordinator Area Operations Technician Results of this meeting shall be documented and action items must be completed prior to start of the inert entry job. 4.3.3. A BASF representative is required to be in the entry area throughout the inert portion of the entry job. Extra coverage will be scheduled if necessary to comply with this requirement. 4.3.4. Air Supply must be Certified Grade D quality breathing air. A quality control check will be made by On-Site Safety Store personnel as the bottles are brought to the Site. The bottles will be individually tested and tagged. 4.3.5. Blended or synthetic air will NOT be used for supplied breathing air used by employees or contractors. Contractor Written Documentation Contractor must provide to BASF representative written documentation prior to commencement of work supporting qualifications for working in an inert environment. The minimum documentation required should include: 4.3.6. Employee service and current training records for all crew members. 4.3.7. Certification of emergency/rescue training.
Procedure No.: PA-020-0052 Page: 7 of 17 4.3. Pre-Job Planning cont d 4.3.8. Documentation of Confined Space Entry training consistent with OSHA 29 CFR 1910.146. 4.3.9. A written procedure for performing work. 4.3.10. A written emergency plan to include, but not limited to: Loss of N2 supply High N2 pressure High equipment O2 High equipment temperature Loss of Breathing Air Supply Emergency inside the reactor/dryer Plant Emergency outside of the reactor/dryer 4.3.11. Heat Stress Plan Contractor must provide written program for control of heat stress, such as work/rest regimens, monitoring workers and use of auxiliary cooling. 4.3.12. Job Safety Analysis The contractor must prepare a JSA, which is specific to the vessel being entered and the work being undertaken. The JSA needs to address all the risks associated with the work such as: Setting up the inert entry and catalyst handling equipment at the work site Access and egress to the equipment Provision for adequate lighting Control of access around the work site and around any open manways where nitrogen is being vented Lifting and rigging activities Manual handling activities Catalyst handling Removal of vessel internals (if required) Catalyst loading Installation of warning signs utilizing international caution/danger symbols
Procedure No.: PA-020-0052 Page: 8 of 17 4.3. Pre-Job Planning cont d 4.3.13. Contractors Equipment Inert entry requires specialized equipment that must be inspected and in good working order. Contractors must supply the equipment necessary for completing the job. Contractors must maintain a communications system for use by the employees working inside the inert atmosphere and those monitoring the work from the outside. This system must be capable of simultaneous communication with all connected personnel and must include a redundant system in the event the primary system fails. Entrants can be lowered into the vessel using a winch/hoist specifically designed for carrying people. A ladder can be used for access as well if it meets Site Standards found in PA-020-0013. All hand tools contractors bring on Site will be in good workable order. All designed safeguards will be remain in place and not tampered with or bypassed. Inherent Safe Connections will only be used. Labeling of all air and communications lines will be required. Any pneumatic equipment used inside the confined space will use nitrogen as the energy source. 4.3.14. Personal Protective Equipment A risk assessment should be conducted to determine the additional PPE required to protect the persons working inside the equipment from catalyst dust, any residual oil and any physical hazards.
Procedure No.: PA-020-0052 Page: 9 of 17 4.3. Pre-Job Planning cont d 4.3.15. Life Support Systems Two independent sources of air must be provided to a Helmet. The secondary air supply should cut-in automatically whenever the primary source is overextended or over breathing occurs. The entrant must wear an auxiliary escape air bottle. An Emergency Egress Line shall be supplied for each entrant for emergency egress. Air for these Emergency Egress Lines shall be supplied from an independent source. The helmet must be sufficiently secured to prevent inadvertent removal. The helmet must be in clean, workable order with all inspections complete and documented. The umbilical cord containing the air hoses must be adequately sheathed to protect the hoses and be designed such that the hoses cannot be detached should the umbilical cord be pulled or snagged. A trained attendant, located outside the confined space, must continuously monitor the air supply. An alarm, audible/visible, shall be provided to warn of low air pressure. An alarm will also be required to warn when secondary air has been activated. If for any reason the primary communication link fails, the persons working inside must be evacuated. BASF personnel will also be notified. The entrant working inside the vessel must be in visual contact of the attendant. An additional standby may be necessary in addition to other visual means such as CCTV.
Procedure No.: PA-020-0052 Page: 10 of 17 4.3. Pre-Job Planning cont d 4.3.16. Rescue/Evacuation Adequate emergency rescue facilities should be immediately available at the vessel manway and the contractors should be trained in its use. This should include: Hoisting device and wire lifeline to extract person from the inside of the confined space. Persons working inside the vessel should wear a harness (Shoulder D Ring Type), which enables the person to be lifted out of the vessel in a vertical position. A pre-planned means of lowering the person to the ground. (stokes basket) A radio or other means of summoning assistance. The attendant at the vessel must wear standard inert entry equipment so that in an emergency they can enter the vessel to assist the injured person. A spare set of standard inert entry equipment must be available at the vessel manway so that another technician can replace the safety standby. Trained personnel to provide emergency first aid and cardiopulmonary resuscitation (CPR) 4.3.17. When to Evacuate An evacuation of the vessel must occur under the following circumstances: Loss of primary communications systems Vessel temperature rise greater than 15 deg. F. Loss or problems with primary air Loss or problems with nitrogen purge Loss of power and/or lighting O2 concentration greater than 4% Whenever the Site s Emergency Horn goes off (with the exception of the weekly test that occurs every Monday at noon). Use of emergency egress bottle Anytime a vessel is evacuated, a thorough investigation must be performed to identify the cause(s) that led to the condition requiring evacuation. Entry shall not be permitted back into the space until corrective actions have been implemented to address the cause(s). The inert entry permitting process should be repeated and a new entry permit issued.
Procedure No.: PA-020-0052 Page: 11 of 17 4.3. Pre-Job Planning cont d 4.3.18. Process/Operations There must be a primary (truck/trailer) supply and secondary nitrogen (plant N2) supply to the vessel. The primary trailer supplying the nitrogen must be backed up by a second trailer that is staged on site. In the event that a nitrogen trailer runs empty, operations will switch over to the secondary plant nitrogen system until a trailer swap is accomplished. O2 and temperatures should be watched carefully during this time. Ideally there will be two nitrogen trailers on site at all times with a third trailer being in transport between the Site and the Nitrogen fill facility. Due to the potential for some catalyst to develop crust, planning the introduction of nitrogen supply must address methods to eliminate the potential for build-up of pressure below this crust. Operations personnel preparing the job will perform atmospheric testing to determine a safe zone. The area around the Inert Entry Operation will then be barricaded to limit personnel in the area. Warning signs should be posted at the point of access to the area (ladder cage, elevator, etc.) and the entry point. These signs should read IDLH Entry In Progress! Do not enter without operations approval! All open manways must be covered or otherwise protected from fall hazards. Operations must tag all valves in the N2 system to indicate OPEN or CLOSED position. Tags should be weatherproof and be secured with a tie wrap.
Procedure No.: PA-020-0052 Page: 12 of 17 4.4. Field Execution 4.4.1. Pre-Job Checks Prior to beginning the inert entry, a Pre-Job check is completed to ensure all planning activities, meeting action items, emergency and rescue plans have met BASF requirements. This step is to ensure all equipment is in place, to make final checks of the job, and be sure the space and personnel are prepared to complete the job safely. The following are key components of a facility programs related to field execution: Permit issuers must test all areas around the openings to determine boundaries of regulated areas. The boundaries will be barricaded to ensure non-entry personnel do not enter oxygen deficient environments. Open manways must be secured to prevent fall hazards. Any deviations from the Confined Space Permit or Inert Entry Procedure must be documented and signed off by appropriate personnel. 4.4.2. PPE The PPE hazard assessment completed during the planning phase should clearly identify the PPE required for all task being performed during each specific inert entry operation. Contractor supervision must enforce the implementation of the requirements identified by the Safe Work Permit. BASF will also audit the use of required PPE. 4.4.3. Emergency Plan Verification The emergency plans developed during the planning phase must be verified to ensure they are in place and all members of the rescue team understand their roles and responsibilities under these plans. It is equally important that entrants, attendants, support personnel and all employees involved in an inert entry know what to do in the event of an emergency.
Procedure No.: PA-020-0052 Page: 13 of 17 4.4. Field Execution cont d 4.4.4. Entry Conditions Vessel atmosphere requirements for inert entry with life support system breathing apparatus are outlined in the following table. If these levels are exceeded while an entry is in progress, the vessel must be evacuated until these levels are restored: Substance Max Value Comment Oxygen 4% The max limit set by API 2217A is 5%. The maximum limit for vacuum operations is 2%. This provides time for emergency action to be taken. Hydrocarbons 0 % This to be determined on a case by case basis depending on the individual job and circumstances. H2S 10ppm Limit based on avoiding H2S levels >10 ppm in the vicinity of the reactor manway platform. Benzene 1ppm Limit based on avoiding benzene levels >1 ppm in the vicinity of the reactor manway platform. CO 50ppm Should be tested when catalyst contains Nickel or Cobalt. This is to prevent the potential of highly toxic metal carbonyls.
Procedure No.: PA-020-0052 Page: 14 of 17 4.4. Field Execution cont d 4.4.5. Ongoing Monitoring Contractor In order to maintain a safe environment, the contractor should maintain a periodic log or checklist of continuous monitoring. BASF personnel will periodically audit these readings. The checklist or log must included: Vessel Temperature LEL Oxygen Concentration Air Supply (Primary & Secondary) Checks Communication Checks Operations Area operations technician will be responsible for maintaining a safe working environment. Responsibilities include: Audit of contractors to ensure ongoing monitoring is taking place Contact will BASF board technicians to ensure temperatures and other variables are maintaining Performing LEL/O2 readings determined by permit requirements Personal presence in the area of Inert Entry Issuance of all permits required for work being performed Ensuring adequate nitrogen flow is maintained Informing contractors of any emergency situations Ensuring company LEL meters are checked by bump testing at least once per shift
Procedure No.: PA-020-0052 Page: 15 of 17 4.4. Field Execution cont d 4.4.6. Vacuum Operations Vacuum operations can present additional and unique hazards during inert entry. The nature of the operation can affect the atmosphere in the vessel and present new physical hazards in and outside the space. These risks must be addressed from the approval process through execution. The following additional precautions need to be taken: All components including the ducting, the cyclone and vacuum equipment must be properly bonded together and must be grounded to prevent build-up of an electrostatic charge. Hoses can be eroded by catalyst and must be visually examined prior to each use. Vacuum equipment must be purged with nitrogen prior to use and a nitrogen supply should remain connected at all times. A vacuum system removes large amounts of nitrogen from the vessel. Nitrogen levels in the vessel must be regulated to maintain the proper concentration during vacuum operations. Exhaust should be discharged to a safe location. A barricade should be utilized to establish a safe zone around the vacuum truck. Vacuum operations must be stopped if the vessel O2 level rises above 4%. The location of the vacuum hose could hamper emergency egress from the vessel. This needs to be considered in the emergency evacuation procedures. Spent catalyst containers must be inerted before being loaded. At the end of the vacuuming operation, the internal components of the vacuum system should be thoroughly washed/cleaned to remove pyrophoric dust/residues. Filters should be routinely cleaned to prevent build-up of pyrophoric waste. 4.5. Post Job Critique At the conclusion of each inert entry job, there shall be a documented critique facilitated by BASF Operations/Maintenance/EHS Teams and the Inert Entry Contractor. The agenda for the critique shall include: Contractor review of Highlights and Opportunities Company review of Highlights and Opportunities Review of evacuations that were required and corrective actions Review of all audits performed during the job Review of all near misses and corrective actions Lessons learned
Procedure No.: PA-020-0052 Page: 16 of 17 5. RESPONSIBILITIES 5.1. Port Arthur Site Leadership Team Has primary responsibility for implementation of this procedure. 5.2. Environmental, Health, and Safety Manager Has primary responsibility for the initiation, re-issuance, administration, and/or interpretation of this procedure. 5.3. Port Arthur Employees and Contractors Have primary responsibility for adherence to procedure including identifying deficiencies in the procedure, and identifying, reporting and correcting activities not in compliance with the procedure 6. RELATED DOCUMENTS BC032.017 Confined Space Entry 29 CFR 1910.146 Confined Space Entry Health & Safety Procedure PA-020-0004 Confined Space Entry Health & Safety Procedure PA-020-0017 Personal Protective Equipment Health & Safety Procedure PA-020-0013 Ladders Attachment A Area Technician Checklist
PA-020-0052 Attachment A Area Technician Checklist Area Technician Time Date Entry Contractor Safety Checks Current & Updated? Area Housekeeping Acceptable? Effective:06/15/08 Approved by: EHS Manager