Professional Documents
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Individual Unit
Procedure
Reviewed:
Preparer:
EHS Team Member
01/12
Effective:
Owner:
EHS Team Member
Page:
06/15/08
(Rev.01)
1 of 17
Supersedes: 01/05/06
(New)
Approver:
EHS Manager
Revision Description
Revised By
VB
TF
TD
Revision
Date
06/08
12/08
01/12
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Procedure
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1. PURPOSE
This policy establishes requirements for inert confined space entry for the NROC Site.
This policy will be used in addition to the Sites Confined Space Procedure (PA-0200004). 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.
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:
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DEFINITIONS contd.
2.4.
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.
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DEFINITIONS contd
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 Hubs 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.
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PROCEDURE contd
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 Coordinator, Area Team Lead and Site EHS personnel before the
start of work.
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PROCEDURE contd
4.3.
Shift Coordinator
Area Team Lead
Contractor Safety Representative
EHS Representative
Contractor Foreman
Area Operations Coordinator
Area Operations Technician
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PROCEDURE contd
4.3.
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4.3.
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.
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PROCEDURE contd
4.3.
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4.3.
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 Sites 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.
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PROCEDURE contd
4.3.
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.
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PROCEDURE contd
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.
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PROCEDURE contd
4.4.
Max Value
4%
Hydrocarbons
0%
H2S
10ppm
Benzene
1ppm
CO
50ppm
Comment
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.
This to be determined
on a case by case
basis depending on
the individual job and
circumstances.
Limit based on
avoiding H2S levels
>10 ppm in the vicinity
of the reactor manway
platform.
Limit based on
avoiding benzene
levels >1 ppm in the
vicinity of the reactor
manway platform.
Should be tested when
catalyst contains
Nickel or Cobalt. This
is to prevent the
potential of highly toxic
metal carbonyls.
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PROCEDURE contd
4.4.
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PROCEDURE contd
4.4.
4.5.
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RESPONSIBILITIES
5.1.
5.2.
5.3.
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
Effective:06/15/08
Time
Date
Entry Contractor
Safety Checks
Current &
Updated?
Area
Housekeeping
Acceptable?