I-D-05.40Page 1of 11

Revision: 6

SAFETY / SOSO / Current Issue:03/30/12
Revision: 6
By: P. Daigle
Verified by:___
Date:______/ PROTECTION FROM OXYGEN-DEFICIENT ATMOSPHERES
Date Reviewed:
03/30/12
/ I-D-05.40 Page 1 of 11 / Original Issue: 09/15/03
Originator: L. Hensley
STATEMENT OF PROCEDURE

This procedure applies to all work activities and situations which could potentially place employees, including contract employees and visitors, in an oxygen-deficient atmosphere. It includes operating activities as well as repair/alteration (maintenance) activities.

Nitrogen (N2), as a gas, is colorless and odorless. When nitrogen concentration increases, the oxygen concentration decreases and the atmosphere may contain less than 19.5% oxygen. Breathing atmospheres of less than 19.5% oxygen can lead to progressively more adverse health effects, including rapid death (see Table 1). Nitrogen displaces carbon dioxide in the lungs, which tells the body to stop breathing. Nitrogen is typically used to displace air to create an oxygen deficient atmosphere, but other gases such as helium and argon, can create similar hazards.

GreenLake uses nitrogen in several applications. As a gas, some uses include:

1.)inerting equipment to prevent flammable atmospheres;

2.)preparing equipment for maintenance by purging out hydrocarbons;

3.)removing air/oxygen in equipment before startup;

4.)blanketing tanks to prevent the ingress of air;

5.)certain welding operations;

6.)decommissioning equipment to prevent the “rusting” process;

7.)instrument air backup.

The use of nitrogen can be harmful. Due to the hazards of working in nitrogen atmospheres, alternative processes not requiring entry into an inert atmosphere must be considered and, when appropriate, become the preferred alternative.

Requirements for confined space entry are contained in SOSO I-D-05.10, Permit to Work. However, this procedure applies to preparing equipment for entry and for post entry work activities.

In addition to this procedure, all other applicable standards and requirements shall be followed.

This procedure does not apply to:

  • Transporting, connecting, and disconnecting of compressed gas cylinders
  • Use of helium cylinders for blowing up balloons
  • Emergency use of portable fire extinguishers and
  • Use of an inert gas for driving process equipment (e.g., pump) if the discharge is routed to an area not accessible to employees.

PROCEDURE

I-D-05.40Page 1of 11

Revision: 6

General Requirements

Inert gases shall not be used for:

a)Driving pneumatic tools, ventilation equipment, or other non-process gas-driven equipment

b)Inflating vehicle tires (except for airplane tires)

c)Dusting equipment, machinery, or clothing

d)Clearing potable water lines or other water lines that are located in occupied buildings

e)Drying breathing air lines or systems

f)Spray painting and abrasive blasting

Cylinder Storage

Inert gas or hazardous gas filled cylinders will not be stored inside buildings or confined spaces. Exempt from this are cylinders that are in use or connected to a regulator.

Nitrogen Supply

a)It is crucial that all nitrogen entering the facility is of high quality. An assurance method must be in place to guarantee good nitrogen that is free from oxygen.

Warning Signs

Warning signs shall be posted on equipment (excluding welding equipment) where an inert gas could expose an employee to an oxygen-deficient atmosphere, for example:

a)Equipment openings where an inert gas purge, blanket, or sweep is in an area accessible to employees

b)Equipment that contains an inert gas under normal operating conditions and could expose employees to an oxygen-deficient atmosphere when opened to perform a task, and

c)Buildings (e.g., bag houses, analyzer buildings) which could accumulate an inert gas due to leaks.

d)Warning signs shall contain the following or similar wording

“CAUTION INERT GAS - ASPHYXIATION HAZARD”

Inert Gas Purges/Blankets -

The following precautions shall be taken when nitrogen or other inert gases are being used to purge open out-of-service equipment in areas that could be accessible to employees:

a)The temporary release provisions of I-D-3.00 Lockout, Electrical and Mechanical, and I-D-05.25, Master Clearance Card Procedure, shall be followed when a purge is initiated on equipment locked-out or tagged out for repair/alteration work.

b)If feasible, the purge shall be routed to an area that is not accessible to employees.

c)If open-ended purges are in an area accessible to employees, the open-ended equipment purge shall be routed to a safe location, or barricaded to minimize the potential for employee exposure.

d)The purge shall not be directed where the inert gas could accumulate in an enclosed area accessible to employees.

e)The purge rate shall be minimized to the extent feasible.

Permits and Procedures -

Work areas and activities are to be reviewed to identify tasks or situations that could potentially expose employees to an oxygen-deficient atmosphere. Everyone associated with a task bears this responsibility including but not limited to; planners, project coordinators, production personnel, and the workers themselves. Examples of such tasks or situations are:

a)Opening equipment which is under an inert gas blanket or purge (e.g., tank vents, explosion panels, manways, tank hatches, tank cars, tank trucks, instrument leads, etc.)

b)Working on or around open equipment which is under an inert gas blanket or purge (e.g., asbestos removal enclosures, repair/alteration, scaffold erection/dismantling, purging drums, and applying inert gas blanket on drums) in an area accessible to personnel

c)Open flame operations in enclosed areas

d)Welding in an enclosed area when an inert gas (e.g., helium or argon) is being used as a welding shield

e)Activities which consume oxygen by oxidation (e.g., application of certain types of paints and coatings) in enclosed areas and

f)Opening and entering buildings or enclosed areas which have the potential for an inert gas leak (e.g., baghouses, analyzer buildings, laboratory sink cabinets which are connected to utility shafts).

The Confined Space/Hot Work permit, Master Clearance Card procedure and the Permit to Work procedure shall be used to control the hazards associated with planned, routine operations job tasks or situations which could potentially expose employees to an oxygen-deficient atmosphere.

The Confined Space/Hot Work permit, Master Clearance Card procedure and the Permit to Work procedure shall be used to control the hazards associated with repair/alteration (i.e., maintenance) activities or situations which could potentially expose employees to an oxygen-deficient atmosphere.

The Confined Space/Hot Work permit, Master Clearance Card procedure and the Permit to Work procedure shall address the following requirements as applicable; if possible, lock-out or tag-out inert gas sources. If the equipment cannot be locked-out/tagged out, minimize inert gas volume in areas accessible to employees.

a)The need for continuous oxygen monitoring (portable meter).

b)The need for a safety attendant and, if needed, specification of the duties.

c)Adequate ventilation to maintain oxygen content at 20.9%.

d)A safe working zone for personnel working around an inert gas, considering factors such as flow rate, area of openings, wind speed, wind direction, and surroundings. As a minimum, an employee’s face shall not be exposed within twelve inches of open equipment with an inert gas purge.

Note: This requirement does not apply to welding equipment that uses an inert gas.

Oxygen Deficient Vessel Entry Work(typically not done at GreenLake)

The below section applies only to planned work activities and does not apply to emergency response in which the work atmosphere went from acceptable levels to oxygen deficient. Planned work in oxygen deficient vessels is not typically done at the IneosGreenLake site and would require a specialty contractor.

No employee shall work in an environment where the oxygen content is below 20.9% without a Special Permit okayed by IneosSHE. If such work is approved, the following minimum precautions shall be taken:

1.Oxygen deficient vessel entry work is complex and immediately dangerous to life and health. Therefore, all reasonable alternatives must be considered before this option is selected. The consideration of alternative methods must be documented.

2.When oxygen deficient vessel entry work is in progress, no IneosGreen Lake Complex employee shall enter the oxygen deficient vessel under any circumstances for any reason.

3.For planned work activities, IneosGreen Lake Complex shall employ specialty contractors to perform oxygen deficient vessel entry work and rescue.

a.Specialized contractors employed to perform activities in oxygen deficient vessels must be able to demonstrate, prior to tendering a contract that their procedures and equipment meet or exceed, and are consistent with, the facility’s procedures and standards.

b.The contractor’s procedures and documentation must be consistent with industry practices.

c.These contractors must meet the site contractor selection safety criteria.

4.In addition to the general training and knowledge, all persons working in or around potentially oxygen deficient atmospheres must be trained regarding: procedures, personal protective equipment, continuous monitoring, standby personnel responsibilities, emergency procedures, and rescue plan.

5.A IneosGreen Lake Complex employee must be designated as responsible for the assurance of the safe execution of activities by IneosGreen Lake Complex employee and contractor personnel in or around potentially oxygen deficient atmospheres. This designated person must have the necessary training and experience to assure all requirements for safe execution of the work are in place.

6.Procedures, including a Group Risk Assessment, must be written to define how a vessel or other piece of equipment will be taken out of service, purged with nitrogen, accessed by personnel, work performed, and returned to service. The procedures shall be reviewed and deemed adequate by the designated IneosGreen Lake Complex employee, and must include:

a.Assurance (e.g. testing, analysis, QA/QC procedures, etc.) of the quality and reliability of the nitrogen source.

b.A diagram (or listing) of the vessel isolation points, nitrogen purging inlets, vents and outlets, entry points, internal fittings, etc.

c.Methods to verify nitrogen flow, control, and volume and venting.

d.Steps to control personnel access to the equipment and restricted area.

e.Steps to eliminate or minimize other activities not associated with the use of nitrogen but near the restricted area.

f.Steps to manage other risks unique to the activities (e.g., skin absorption of contaminants in the equipment).

g.Provisions to vent nitrogen from equipment to a location where the nitrogen does not create a hazard for unprotected personnel.

h.Rescue Plan

7.Atmospheric testing must be performed to identify the parameters of a restricted area – defined as area where oxygen concentration may be less than 19.5% by volume – to prevent unauthorized and/or unintentional entry of personnel.

a.Two trained and competent individuals, one conducting the testing and one available in appropriate PPE for rescue at a safe distance from the testing location, must perform the initial atmospheric testing.

b.During the initial testing, individuals must wear positive-pressure, continuous flow, full-face piece, supplied air respiratory protection, and appropriate rescue equipment. These persons must not enter the vessel or any area where oxygen concentrations are below 19.5% unless they wear appropriate protective equipment for entry into an oxygen deficient atmosphere.

c.Atmospheric testing must be conducted in conditions representative of actual work activities, with consideration given to the potential for environmental conditions (e.g., wind speed, direction, etc.) to change during the job.

d.Specialized gas test equipment for accurately measuring in an oxygen deficient atmosphere must be used.

e.The job site’s restricted area must be cordoned off (e.g., using tape, barricades, etc.) and signs must be posted at all access points to provide early warning to personnel who may approach the restricted area. As an example, the warning sign may include:

Danger – Nitrogen In Use

Life Threatening Hazard Present

Oxygen Deficient Atmosphere – BA Required

Authorized and Trained Personnel Only

f.All persons entering the restricted area must wear a full life support system to its employee (lock-on helmet; primary, secondary, egress air supplies; continuous communication system; full body harness with retrieval line attached. Retrieval/rescue equipment needed for the entry must be assembled and ready for use at the confined space entry point before access to the manhole is authorized for any work, even sampling. Rescue from the blanketed vessel should be the sole responsibility of the specialized contractor and no IneosGreen Lake Complex employee or other contractor shall be allowed entry at any time, even for rescue. Therefore, at any time when the specialized contractors are not available, the access points should be physically barriered and locked to prevent access.

8.Inert entry work and emergency procedures, including a rescue plan, must be in place to manage the risks to persons entering into an inert vessel. Table 1 is a checklist that provides the minimum safety review requirements for inert entry. Each site must still develop a job-specific safety plan.

9.Table 2 must be completed at least once per shift.

END OF PROCEDURE

Table 1

IDLH CONFINED SPACE ENTRY AUTHORIZATION

(Must Be Attached To IDLH CSE Safety Assurance Plan)

Unit: / Job location:
INEOS REP. (Days & Nights):
IDLH Contractor:
IDLH Hazard:
Justification for IDLH Confined Space Entry:
Alternatives Considered:
Yes / No
  1. Has the IDLH contractor been approved for work at INEOS?

  1. Will the IDLH contractor use any non-proprietary (e.g., labor pool, sub contractor) entry-team personnel?

  1. If Question 2 is ‘YES’, has the SHE Department approved (by individual) the use of non-proprietary entry-team personnel? If Question 2 is ‘NO’, leave the response blank or mark N/A.

  1. Has an IDLH CSE Safety Assurance Plan been developed?

  1. Does the plan include a description of the work?

  1. Does the plan include a pre-job safety assessment?

  1. Does the plan describe how the equipment will be prepared for IDLH entry?

  1. Does the plan include an isolation procedure?

  1. Does the plan include an inert purge assurance plan?

  1. Does the plan include a INEOS rescue coordination plan?

  1. Does the plan include a list of IDLH CSE Contractor entry-team personnel, their entry-team role(s), and the dates of their last training on IDLH CSE related skills?

  1. Has a request been made to waive the use of a retrieval line?

  1. If Question 5 is ‘YES’, has the Shift Superintendent/Emergency Preparedness Supervisor approved the waiver? If Question 5 is ‘NO’, leave the response blank or mark N/A.

(Signature of Leadership Team Representative) / Date
INEOS Job Representative / Date
IDLH Contractor Representative / Date
Shift Manager / Date

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Revision: 6

Table 2

IDLH Confined Space Entry
Audit

Date: / Time:
Contractor:
Verify / Comments
  1. Reviewed Reactor LOTO/isolation at beginning of shift

  1. Crew Size

  1. Review personnel locks attached to lock box with entry log

  1. Review Pre-entry Safety Checklist: (harness, helmet, Go/No-go test, umbilical, egress assembly, facemask seal, communication test, module status)

  1. Confined space entry data sheet

  1. Life support equipment monitoring data sheet

  1. Atmospheric Testing Log:

  1. Oxygen, <5%

  1. Combustible gas (< 10 %)

  1. Temperature

  1. Exclusion Zone Perimeter Oxygen

  1. IDLH CSE Personnel Log

  1. Exclusion zone and warning signs in place

  1. Housekeeping

  1. IDLH CSE entry-team personnel at their designated post?

(Name of Individual Completing This Survey: ______)