Doc #: 1000-AD Revision: - CONFINED SPACES SOP. Author(s): T. Lavoie/ M. Saucedo/ J. Dunlop/ Mtn. Supervisor

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Doc #: 1000-AD-015-0005 Revision: - CONFINED SPACES SOP Author(s): T. Lavoie/ M. Saucedo/ J. Dunlop/ Mtn. Supervisor

TABLE OF CONTENTS REVISION HISTORY... 3 1.0 INTRODUCTION... 4 2.0 DEFINITIONS... 4 3.0 HAZARDS ASSOCIATED WITH CONFINED SPACES... 4 4.0 CONTROL OF HAZARDS... 5 5.0 RESPONSIBILITIES... 5 5.1 Supervisor... 5 5.2 Employees and Contractors... 5 6.0 PROCEDURES... 6 6.1 Method of Clearing... 6 6.2 Methods of Isolation... 6 6.3 De-Energizing Equipment... 6 6.4 Atmospheric Testing of Confined Spaces... 6 6.5 Duties... 7 6.6 Immediately Dangerous to Life and Health (IDLH) Entry... 8 6.7 Use of Electrical Equipment... 9 6.8 Welding and Cutting... 9 6.9 Ventilation... 10 6.10 Temperature... 10 6.11 Entry Permits... 10 6.12 Training... 10 6.13 Record Keeping... 10 7.0 REFERENCES... 11 8.0 CONFINED SPACE ENTRY PERMIT EXAMPLE... 12 1000-AD-015-0005.Docx Page 2 of 13

REVISION HISTORY Rev Date Approved Sections Affected Reason for Change Remarks and/or Change Details Name -- 03/21/2017 Initiated T. Lavoie Approved by: Name, Facilities Manager Name, Mountain Facilities Supervisor Tammie Lavoie 21 March 2017 Tammie Lavoie, Safety Manager Date 1000-AD-015-0005.Docx Page 3 of 13

1.0 INTRODUCTION The control of confined spaces is enforced by OSHA 29 CFR 1910.146. This procedure will pertain to all NOAO-North employees and contractor personnel who may be required to conduct work inside of a confined space, or a permit-required confined space. This policy outlines the acceptable safety measures when dealing with confined space procedures. 2.0 DEFINITIONS Attendant A trained and capable individual, stationed outside the confined space, who monitors the entrants and can perform required duties during an emergency. Confined Space A confined space is a space that is large enough for a worker to enter, has limited or restricted means for entry and exit, and is not designed for continuous worker occupancy. Immediately Dangerous to Life and Health (IDLH) IDLH means any condition that poses an immediate or delayed threat to life, would cause irreversible, adverse health effects, or would interfere with an individual s ability to escape unaided from a permit space. Lower Explosive Limit (LEL) The minimum flammable vapor in air concentration below which flame propagation does not occur on contact with an ignition source. The LEL is expressed as a volume percentage of vapors in air. Non-Permit Required Confined Space A confined space that does not contain, or with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm. Permit-Required Confined Space A permit-required confined space is a space that has one or more of the following characteristics: 1) contains or has the potential to contain a hazardous atmosphere, 2) contains a material that has the potential for engulfing an entrant, 3) has an internal configuration such that an entrant could be trapped or asphyxiated, and 4) contains any other recognized, serious safety or health hazard. 3.0 HAZARDS ASSOCIATED WITH CONFINED SPACES The hazards associated with confined spaces are as follows: Excessive Heat Flammable or Explosive Atmospheres Flowing Liquids or Free-Flowing Solids 1000-AD-015-0005.Docx Page 4 of 13

Oxygen Deficiency Oxygen Enrichment Toxic Atmosphere 4.0 CONTROL OF HAZARDS Administrative All employees must review this document upon hire, and refresh as needed. Review training requirements in 6.12. Engineering Ventilation is the most commonly used engineering control in confined spaces. Ventilation is acceptable in the forms of mechanical, natural, and exhaust. If mechanical ventilation is used, a warning system must be in place so that workers can be notified in the event of a hazard, or ventilation failure. Elimination/Substitution Substitute entrants and attendants with authorized personnel, if needed. Personal Protective Equipment (PPE) Workers must wear suitable PPE when working with hazards in confined spaces. This may include: Appropriate clothing Closed-toe shoes Gloves Hard hat Harness and retrieval system Respiratory protection (must have clearance) Safety glasses Other, as needed 5.0 RESPONSIBILITIES 5.1 Supervisor Ensure that persons within their areas of responsibility comply with this policy and its implementing documents, and, in particular, have completed the required training prior to beginning work. 5.2 Employees and Contractors Follow all guidance provided in training and work processes to safely complete tasks inside confined spaces, and permit-required confined spaces. 1000-AD-015-0005.Docx Page 5 of 13

6.0 PROCEDURES 6.1 Method of Clearing Under normal conditions, all confined spaces will be drained and cleared of any vapors or residuals by the Facilities Department. Proper personal protective equipment will be used as required during clearing operations. Various methods such as using exhaust fans, natural ventilation, or blowers could be used to clear the area of possible vapors. Most tanks of water can be drained, and the residual can be pumped out. 6.2 Methods of Isolation The accepted methods of isolation are listed below. 1. Use of Blinds and Blanks The use of blinds and blanks must have pressure ratings equivalent to the maximum potential process pressure. Blinds and blanks must be made of a suitable, resistant material and, if possible, they must be installed between flanges next to the vessel. This will ensure the accumulation of the material between the vessel and the blind is minimized. An energy isolation plan must be completed for each vessel requiring entry, as well as hazardous energy associated with the entry utilizing the Lockout/Tagout Standard Operating Procedure (SOP) (1000-AD-015-0001). 6.3 De-Energizing Equipment Prior to entering a confined space, all power-driven equipment that has the potential to endanger the workers or cause additional hazards must be rendered inoperable according to the Lockout/Tagout SOP (1000-AD-015-0001). 6.4 Atmospheric Testing of Confined Spaces Once a confined space has been properly isolated and verified by the supervisor, testing of the atmospheric conditions must be done. The atmosphere of the confined space will be tested for oxygen, and flammable gases. If necessary, testing for toxic chemicals (such as chlorine vapors) will also be completed. All testing must be done by the Entry Supervisor, and witnessed by the attendant before entry is allowed. Fresh, outside air has the potential to dilute the samples, so caution must be taken to prevent this from occurring. Air moving devices should be shut down while obtaining samples at or near the opening of the space. All readings must be written on the Entry Permit. Supervisors and workers must check the appropriate Safety Data Sheets (SDSs) for the safe toxicity ranges. All confined spaces will be deemed as having insufficient atmospheric conditions until the tests prove otherwise. All testing must be done approximately thirty minutes or less before entry. The sequence of sampling and testing is listed below. 1. Oxygen Deficiency Testing An atmospheric oxygen concentration below 19.5% is considered an oxygen deficient environment, and an atmospheric oxygen concentration above 23.5% is considered an oxygen enriched environment. 1000-AD-015-0005.Docx Page 6 of 13

Oxygen Content (% by Volume) Effects and Symptoms (At Atmospheric Pressure) 23.5% Oxygen enriched, extreme fire hazard 20.9% Oxygen concentration in normal air 19.5% Minimum permissible oxygen level 15% to 19% Decreased ability to work strenuously; may impair coordination and may cause early symptoms for persons of coronary, pulmonary, or circulatory problems 10% to 12% Respiration further increases in rate and depth; poor judgement, blue lips 8% to 10% Mental failure, fainting, unconsciousness, ashen face, nausea, and vomiting 6% to 8% Recovery still possible after four to five minutes. 50% fatal after six minutes. Fatal after eight minutes. 4% to 6% Coma in 40 seconds, convulsions, respiration ceases, death 2. Flammable Gases The atmosphere must have a 0% LEL. 3. Chlorine Vapors The atmosphere should contain less than 0.5 ppm of chlorine, or less than 1 ppm of chlorine for entries lasting less than 15 minutes. 4. Other Contaminants Where other contaminants are present, the Entry Supervisor must consult with the Safety Manager to coordinate additional testing. 6.5 Duties 1. Entry Supervisor The Entry Supervisor must know what hazards are associated with the confined space(s), as well as what may be encountered during entry. The Entry Supervisor must remove any unauthorized individual who enters, or attempts to enter, the confined space. The Entry Supervisor must verify that the information included on the Entry Permit is current, accurate, and appropriately filled out. This person must also confirm that the applicable tests for confined space(s) have been conducted correctly and that the results have been recorded on the Entry Permit. Before the Entry Permit is endorsed and entry is allowed, all procedures and equipment specified on the permit must be in place. Once these steps have been completed, the Entry Supervisor is able to sign the permit. If any situation arises that puts the entrants in immediate danger, the Entry Permit must be terminated until a solution is reached. The completed Entry Permit and any problems encountered with the permit must be forwarded to the Safety Manager for review. 1000-AD-015-0005.Docx Page 7 of 13

2. Entrants Authorized entrants must know what hazards are associated with the confined space(s), as well as what may be encountered during entry. Entrants must be authorized to enter the confined space(s) and understand how to properly use the equipment provided. A stable line of communication must be established between the entrants and the attendant at all times. The entrants must inform the attendant of any new hazards discovered, or signs of exposure that are presumably unsafe. If any situation arises that puts the entrants in immediate danger, evacuation protocol from the attendant must be followed. Entrants must sign the Entry Permit, signifying these duties are understood and agreed to. 3. Attendant All confined space entries require the constant presence of an attendant. If a break is needed, another trained attendant must relieve the one on duty. The attendant must know what hazards are associated with the confined space(s), as well as what may be encountered during entry. Accurate identification and count of the authorized entrants is also required. Any individual who is not an authorized entrant must be warned to stay clear of the confined space and reported to the Entry Supervisor. A stable line of communication must be established between the entrants and the attendant at all times. The attendant must be aware of outside conditions that are changing and order an evacuation, if needed. An evacuation is warranted when an adverse condition is detected, when behavior effects of a hazardous exposure are being exhibited from the entrant(s), or when a situation outside of the confined space becomes too dangerous for the attendant to safely perform his or her duties. In the event of an emergency, the Entry Supervisor and the Safety Manager must be notified immediately. The attendant must sign the Entry Permit, signifying these duties are understood and agreed to. 4. Contractors All contractor personnel must provide documentation of completed Confined Space Training prior to entering any confined space(s) on site. If two contractors from separate companies are working together in the same confined space, special precautions must be taken to prevent endangering one another. Both workers must also be aware of each other s work that is being performed. When two or more contractors are present, an additional attendant is required for monitoring. 6.6 Immediately Dangerous to Life and Health (IDLH) Entry There are some circumstances where it may be necessary for workers to enter an area that cannot be cleared of chemical hazards, or where insufficient oxygen levels are present. Non-emergency entry (planned situations) into an IDLH environment is prohibited without a written working plan submitted to, and approved by the Entry Supervisor. An IDLH entry is also considered to be a last resort, as every alternative must be exhausted before this step is considered and executed. The conditions for entering into an IDLH confined space are listed below. 1000-AD-015-0005.Docx Page 8 of 13

1. Written Working Plan A written working plan must be submitted to, and approved by the Entry Supervisor. 2. Members on Standby A fully-equipped EMT, or an emergency response trained individual, must be available to respond in case of an emergency. This person is in addition to the attendant, and may be tasked with watching the air monitor. 3. Communication Constant communication must be maintained with the entrant. Accepted forms of communication include, but are not limited to, vocal interaction, radio, telephone, and signal line use. 4. PPE The entrant must be equipped with a safety harness, and a safety line. PPE should be appropriate for the hazards within and around the confined spaces. Improper use of PPE can lead to dangerous, and sometimes deadly, scenarios. More information on the Fall Protection Plan and its corresponding Rescue Plan can be found in the 1000- AD-015-0003 and 1000-AD-015-0004 SOPs. 6.7 Use of Electrical Equipment The use of electrically operated devices inside confined spaces must be reviewed by the specific application of use and the potential hazards involved. The decision to allow electrically operated devices to be used depends on if they are in accordance with the safety control permit. All portable, electrical lighting above 12 Volts must be explosionproof and plugged into a ground fault circuit interrupter. Other equipment, such as grinders, can also be used if plugged into a ground circuit interrupter. 6.8 Welding and Cutting When welding or cutting is necessary inside enclosed spaces, special precautions must be taken. Compressed gas cylinders must never be used inside confined spaces. All oxyacetylene and inert gas hoses must be removed from the confined spaces, or the hoses must be disconnected at the cylinder regulator during periods of non-use, such as breaks, lunch, or overnight. Arc welding leads and hoses for oxy-acetylene hoses must be checked by the welder prior to use in a confined space. Leaks in hoses, and damaged or broken insulation on welding leads must be repaired prior to use. When welding operations are paused, all electrodes must be removed from holders. Holders must be carefully placed so that accidental contact cannot occur. An approved fire extinguisher must always be available for emergency use at the entrance to the confined space(s). Burning or welding is not permitted in a confined space where there are other activities present that would increase the flammable gas levels inside. Any hot work completed must be recorded on the Entry Permit. 1000-AD-015-0005.Docx Page 9 of 13

6.9 Ventilation Adequate ventilation must be provided for all work completed in confined spaces to prevent fumes from building up. In most cases, natural ventilation is sufficient. If natural ventilation is not enough, forced air, or air movers, must be grounded and utilized. Excavation and pits must be tested to determine the extent of the hazard. Ventilation is required when it would help remove any accumulation pockets of hazardous materials. The guidelines for following forced ventilation when natural ventilation is inadequate are listed below. 1. Forced air ventilation must continue until all employees have left the confined space. 2. Air moving equipment must be able to pull through to evacuate the space of any lingering contaminants. Blowing air through the space will stir and circulate lingering contaminants. 3. The forced air ventilation supply must be from a clean source and may not increase the hazards in the space. Compressed air will never be used for ventilation in a confined space. 4. If achievable, at least two openings that are as far away from each other as possible must be opened. 5. Air moving equipment must be kept in good condition. The Facilities Department is responsible for maintaining this equipment. 6.10 Temperature During periods of extreme temperatures, ambient air temperatures must be determined inside the confined space prior to issuance of the Entry Permit. If the heat or cold presents a problem to the worker inside of a confined space, substitution of another authorized entrant is required. 6.11 Entry Permits An example of what OSHA considers a valid Confined Space Entry Permit, including the information that must be found on the permit and the directions for completing one, is available for review on pages 12-13 of this document. 6.12 Training The employer shall provide training to ensure that the purpose and function of the confined space program is understood by workers and that the knowledge and skills required for the safe entrance, task completion, and exit of workers from a confined space are acquired by workers. Workers also need to be trained on what the entry control permit is. Retraining must be provided when there is a change in job assignments, processes that present a new hazard, deviation from the Entry Permit, or when there is a change in confined space procedures. 6.13 Record Keeping Each completed Entry Permit and any problems encountered with the permit must be forwarded to the Safety Manager for review and safekeeping. Permits must be kept for a minimum of one year, and are required to be reviewed annually. 1000-AD-015-0005.Docx Page 10 of 13

7.0 REFERENCES The above information can be found at the following links: OSHA, 29 CFR 1910.146 https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9797&p_table=stan DARDS Western Illinois University http://www.wiu.edu/vpas/ehss/manuals/confinedspaces.php The Ohio State University http://ehs.osu.edu/filestore/occ%20health%20&%20safety/confined%20space%20progr am.pdf Confined Space Entry Permit https://www.osha.gov/dte/grant_materials/fy11/sh-22318-11/mod_6_cspermit.pdf 1000-AD-015-0005.Docx Page 11 of 13

8.0 CONFINED SPACE ENTRY PERMIT EXAMPLE CONFINED SPACE ENTRY PERMIT Confined Space Location/Description/ID Number: Date: Purpose of Entry: Time In/Time Out: Permit Canceled Time: Reason: Supervisor: Rescue and Emergency Services: Hazards of Confined Space Yes No Special Requirements Yes No Carbon Monoxide Hot Work Permit Required Combustible Dust Lines Broken, Capped, or Blanked Combustible Gas/Vapor Lockout/Tagout Electrical Hazard Purge-Flush and Vent Engulfment Hazard Secure Area-Post and Flag Entrapment Hazard Ventilation Hydrogen Sulfide Other: Mechanical Hazard Special Equipment Oxygen Deficiency Breathing Apparatus-Respirator Skin-Chemical Hazards Escape Harness Required Slip or Fall Hazard Fire Extinguisher Thermal Hazard Lifelines Toxic Fumes Lighting (Explosive-Proof, etc.) Toxic Gas/Vapor PPE ------------------------------------------- -------- -------- Tripod Emergency Escape Unit Communication Procedures: Chemical PEL* Test Start Time Test Stop Time % of Oxygen 19.5% to 23.5% % of LEL Less than 10% Carbon Monoxide 35 PPM (8 hr.) Hydrogen Sulfide 10 PPM (8 hr.) Other: *Do not enter if Permissible Entry Levels (PEL) are exceeded. Name(s) or Person(s) Testing: Test Instrument(s) Used (Include Name, Model, Serial Number and Date Last Calibrated): CFM-Ventilation: Size-Cubic Feet: Pre Entry Time: Supervisor Notified Before Entrance: Time Notified: 1000-AD-015-0005.Docx Page 12 of 13

Supervisor Notified After Entrance: Time Notified: Authorized Entrants: Authorized Attendants: PERMIT AUTHORIZATION I certify that all actions and conditions necessary for safe entry have been performed. Name (Print): Signature: Date: Time: Entry Procedure Checklist Complete the following steps before, during, and after a confined space entry: Step 1 Obtain a Permit-Required Confined Space Entry Form from the Safety Manager. Step 2 Notify the Entry Supervisor before the confined space entry. Step 3 Verify the confined space 4-Gas Detector has been calibrated and is in working order. Step 4 Complete the top portion of the Permit-Required Confined Space Entry Form. Step 5 Ensure all rescue equipment (tripod, lanyard, harness, etc.) is in place prior to entry. Step 6 Monitor the confined space with the 4-Gas Detector prior to entry. The entrant and attendant must sign the permit authorization section on the bottom of the permit to ensure all actions and conditions necessary for safe entry have been performed. Step 7 Employees or contractors entering the confined space must wear the 4-Gas Detector after the preatmosphere test. The employee or contractor must also have a full body harness and lanyard attached to the rescue tripod. Workers must have a radio and the correct PPE. Step 8 Employees and contractors can enter the confined space after Step 7 is completed. The entrant and attendant must fill out the applicable boxes and information (hazards and special requirements) on the Confined Space Entry Permit once he or she is inside of the confined space. The entrant must also gather the readings from the 4-Gas Detector and communicate them to the attendant on the permit. Step 9 The attendant must maintain constant communication with the entrant until he or she has exited the confined space. Step 10 The attendant must notify the Entry Supervisor once the entrant has exited the confined space. Step 11 The Permit-Required Confined Space Entry Form must be given to the Safety Manager for recordkeeping. 1000-AD-015-0005.Docx Page 13 of 13