Guy Colonna, P.E.

55 th Annual MCA Seminar Bar Harbor, ME July 16, 2013

Cadillac Mountain, Acadia National Park

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Agenda

 Background  Confined space statistics  Recent incidents – CSB issues  OSHA 29 CFR 1910.146, Permit-Required Confined Spaces - overview  Aboveground Storage Tanks  API resources  TES Certification program  Practical issues  Marine Chemist role  Closing 3

PRE-INVENTORY

1. An OSHA confined space has the following: a) b) c) d) large enough to permit entry intended for continuous occupancy normal atmospheric ventilation limited or restricted entry or exit

PRE-INVENTORY

2. The following are tank classifications found in OSHA 29 CFR 1910.146, Permit Required Confined Spaces.

a) b) c) Non-confined space Non-permit required confined space Permit required confined space

PRE-INVENTORY

3. API 2015 and 2016 use which of the following safety designations?

a) b) c) d) e) Enter with restrictions Enter without restrictions Enter with special precautions Enter when inerted All of the above

PRE-INVENTORY

4. What is the maximum safe level of oxygen according to 29 CFR 1910.146?

a) b) c) d) e) 10% 19.5% 20.9% 23.5% None of the above

PRE-INVENTORY

5. According to the Permit-Required Confined Space standard, no permit is required when the space is unsafe. True False

Hazard Awareness

Lessons Learned

CSB Report – June 2007  Lack of hot work safety – Failure to recognize the hazards - use of welding tools in a flammable vapor environment – Failure to isolate fuel and ignition sources – Failure to manage hazards with well established, safe work practices (API, NFPA, OSHA)  Makeshift work platform  Safe hot work guidelines – NO permit issued

CSB Video – Death in the Oilfield

Hawaii

 October 17, 2008  Welding part of a catwalk connected to the top of an oil storage tank  Tank was approximately 15 feet tall and reportedly contained waste oil  Vapors from the tank were ignited by the welding activities and caused the explosion that propelled tank 30 feet  One fatality, 3 injured, 2 seriously

Ohio

 October 20, 2008  Welding catwalk on one of four large crude oil storage tanks at drill rig site when a tank exploded  Two fatalities  CSB sent investigative team – Looking for similarities with Hawaii and Mississippi

Seven Lessons from CSB Report

Seven Lessons from CSB Report

RECOGNITION

“Hazard Identification & Risk Assessment”  Identification of Spaces According to Definition  Identification of Hazards  Atmospheric (oxygen, flammability, toxicity)  Engulfment  Entrapment  Other physical or mechanical (energy sources, heat stress, noise)

EVALUATION

“Confirm or Deny Presence of Hazards and Determine Severity”  Qualitative Assessment  Use MSDS, other reference sources, and senses (subjective)  Quantitative Assessment  Measurement of atmospheric components; compare test results to established standards to determine whether a safe condition exists (objective)

CONTROL

“Action taken to eliminate or minimize hazards”  Engineering  Ventilation    Administrative  Isolation Substitution Safe Work Practices  Permits  Training  Personal Protective  Protective Clothing  Respiratory Protection  Follow-up atmospheric monitoring  Emergency and rescue

OSHA Points to MC for CS Evaluation – 1910.146, Appendix B

  Atmospheric testing is required for two distinct purposes:  evaluation of the hazards of the permit space and verification that acceptable entry conditions for entry into that space exist.

Evaluation testing. The atmosphere of a confined space should be analyzed using equipment of sufficient sensitivity and specificity to identify and evaluate any hazardous atmospheres that may exist or arise, so that appropriate permit entry procedures can be developed and acceptable entry conditions stipulated for that space.

Evaluation and interpretation of these data, and development of the entry procedure

(e.g., OSHA consultation service, or certified industrial

certified marine chemist

, should be done by, or reviewed by, a technically qualified professional hygienist, registered safety engineer, certified safety professional, , etc.) based on evaluation of all serious hazards.

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OSHA DEFINITION 29 CFR 1910.146

A confined space must have these characteristics:

 Large enough and so configured to permit entry and work  Not designed for continuous human occupancy  Limited or restricted means of entry and exit

PERMIT-REQUIRED CONFINED SPACE (PRCS)

Is a confined space that contains or may contain:

 Hazardous atmosphere (oxygen content, flammable, or toxic)  Engulfment hazard  Entrapment hazard  Other recognized serious safety hazard

CONFINED SPACE EXAMPLES

 Aboveground and underground storage tanks  Process vessels  Grain silos  Bins  Hoppers  Sewers  Utility vaults  Tanks on marine vessels

Confined Space Example – Diked Area

PRCS PROGRAM REQUIREMENTS

   Written program Identify and classify spaces Establish hazard control measures  Prevent unauthorized entry  Establish acceptable conditions  Isolation  Ventilation  Coordinate entry by multiple workers  Periodic reevaluation for change of conditions

PRCS PROGRAM REQUIREMENTS

 Develop permit system  Preparation  Issuance  Implementation  Cancellation  Returning space to service

PRCS PROGRAM REQUIREMENTS

 Provide specialized equipment  Atmospheric monitoring  Ventilation  PPE  Lighting  Communication  Emergency

PRCS PROGRAM REQUIREMENTS

 Designate key personnel  Entrants  Attendants  Entry supervisor  Qualified atmospheric tester  Emergency response

PRCS PROGRAM REQUIREMENTS

 Perform testing and monitoring  Prior to entry and periodically during entry and work  Establish rescue and emergency procedures  Procedures for contractors - multi-employer work sites  Provide information and training  Conduct program review

Confined Space Classifications

 Non-Permit Required Confined Space (API & OSHA)  Permit Required Confined Space (API & OSHA)  Non-Confined Space (API)

Non-Permit Required Confined Space

 Remember what a confined space is!

 Large enough and so configured to permit entry and work  Limited or restricted entry or exit  Not designed for continuous occupancy  Non-permit means the confined space has no identified hazards

Permit-Required Confined Space

 All characteristics of confined space as defined  Possesses one or more identified hazards  Hazardous Atmosphere  Engulfment hazard  Entrapment hazard  Other serious recognized hazard

Hazardous Atmosphere

 Expose employees to –  Risk of death  Incapacitation  Impairment of ability to self-rescue  Injury  Acute illness  As a result of exposure to –

Hazardous Atmosphere Criteria

 Flammable gas, vapor, mist in excess of 10% of lower flammable limit (LFL)  Airborne combustible dust at its LFL **  Oxygen concentration less than 19.5% and greater than 23.5% by volume  Toxic exposures in excess of PEL as found in Subpart G or Subpart Z  Any IDLH concentrations  Contains or potential, serious harm

DESIGNATED PERSONNEL - Entrant

 Trained to recognize hazards  Trained to use PPE as required  Communicate with attendant as necessary  Recognize symptoms of exposure  Understand principles of self-rescue

DESIGNATED PERSONNEL Attendant

 Remain outside space at all times  Trained to recognize hazards and exposure symptoms  Communicate with entrants  Communicate alarm, evacuate if necessary  May monitor more than one space at a time  Prevent unauthorized entrants  Alert to changing conditions

DESIGNATED PERSONNEL – Entry Supervisor

 Trained to recognize hazards  Authorizes entry based upon hazard assessment, identify acceptable conditions  Verify emergency plans and rescue personnel availability  Revoke permit if conditions change adversely  Terminate permit at job completion

DESIGNATED PERSONNEL Qualified Atmospheric Tester

 Responsible for conducting atmospheric monitoring  Trained to properly select, calibrate, use and maintain all required instruments  May be any of the key personnel - entrant, attendant, supervisor

DESIGNATED PERSONNEL - Rescue and Emergency Services  Either on-site or off-site permitted  Trained at least as entrants and in use of rescue equipment  Trained in basic first-aid/CPR and at least one member certified in both  Conduct annual drill  Coordination between employer and off-site provider

ANSI/API 2015 – Summary

 Scope and Applicability  Applies to atmospheric and low-pressure aboveground petroleum storage tanks  Includes decommissioning, hazard assessment, permit entry and work system, emergency planning, and recommissioning  Does not apply to pressure vessels, process vessels, underground storage tanks  Industry specific application of OSHA requirements in 29 CFR 1910.146

Testing the Tank Atmosphere

 Determine what atmospheric hazards to test for based upon MSDS or other source  Determine safe exposure limits  Develop written calibration requirements  Maintain verification of calibration for 1 year  Calibrate according to manufacturer

Atmospheric Testing

 Test in specific order  Test from outside tank initially  Test atmosphere outside the tank as well  Especially during degassing  Shut down ventilation prior to testing  Rule of thumb 10 – 15 minutes  Conduct periodic or continuous monitoring  Specialized testing – lead-in-air

Storage Tank Hazards

 Oxygen content  Fire and explosions  Toxic substances  Hydrogen sulfide  Organic Lead  Inorganic Lead  Aromatics  NORM  Other  Physical and other hazards  Tank function or design  Tank condition  Tank location  Physiological hazards (heat stress or cold stress)

API RP 2016 – Summary

 Tank Entry Supervisors will have the understanding, knowledge and skills to implement the specific tank cleaning procedures and practices presented in API 2016 in order to meet the requirements of ANSI/API 2015

Tank Entry Designations

 Enter Without Restrictions  Enter With Restrictions  Enter With Special Precautions  Entry When Inerted (See API 2217A)

Enter Without Restrictions

 Oxygen content – 19.5% to 23.5% by volume  Hydrocarbon vapor-in-air level inside the tank is 10% LEL or less  Atmospheric toxic levels inside the tank are within established exposure limits (PEL or TLV)

Enter With Restrictions

 The actual or potential atmospheric concentration levels require appropriate protective equipment or adjusted time  Review NFPA 326, Standard for the

Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair

 Similar designation

Enter With Special Precautions

 This designation applies when:  Oxygen content inside the tank is < 19.5% by volume  Hydrocarbon vapor-in-air level inside the tank is > 10% LEL  Atmospheric toxic levels inside the tank exceed the established exposure limits (PEL or TLV)

Entry When Inerted

 The oxygen content within the tank is less than 8% by volume (or less than 50% of the lowest oxygen concentration level required to support combustion – Limiting Oxidant Concentration (LOC))  NFPA 69, Standard on Explosion Prevention Systems contains values for LOC  Becomes an Enter With Special Precautions

Non-Confined Space

 Does not meet any conditions necessary to be considered a confined space  Atmospheric conditions same as ambient  No restrictions on entry or exit  Tank has been isolated  See provisions in OSHA 29 CFR 1910.146 (c)(7) concerning reclassification

Example of non confined space – one that could be reclassified by 1910.146(c)(7)

API Tank Entry Supervisor Certification (TES)

 Objective:  Enhance the quality and competency of tank entry and maintenance activities  Minimize the risks of confined space hazards  Improve the overall safety performance of tank maintenance operations  Process – combination of experience and examination 53

Project Planning

 Scope of Work & Site Plan  Materials & Equipment Information  Safety & Emergency Response  Personnel Qualification & Training  Classification & Work Permits  Hazards – Hazard Communication  Tank Information

Tank Preparation

 Facility Permits & Work Orders  Position Equipment  Remove Recoverable Product  Isolate Tank  Position, Bond & Start Eductor  Open Manway & Remove Remaining Product

Ventilation and Atmospheric Testing

 Identify supervisors & workers  Ventilate Tank  Conduct External Atmospheric Testing  Continue Ventilation & Retest  Issue Permits for Internal Testing

Enter to Visually Inspect and Evaluate

 Assess, Identify & Address Hazards  Implement CS Entry Program & Emergency Response Program  Test & Obtain Permits to Enter  Perform Pre-Clean Safety Inspection  Verify or Revise Scope of Work  Certify Tank Safe to Enter

Clean Tank

 Implement Cleaning Plan & Permits  Maintain Ventilation & Testing  Identify & Address Special Hazards  Monitor Activities & Security  Cancel Permits, Stop Work & Exit Tank if Conditions Change  Verify Completion of Cleaning

Entry for Repair

 Implement Work & CS Entry Plans  Identify, Address & Monitor Hazards  Determine Classification of Tank  Supervise & Monitor Work Activity  Maintain Site & Tank Security  Cancel Permits, Stop Work, Exit and Safe tank if Conditions Change

Return to Service

 Inspect Tank Before Closing  Verify Recommissioned as Planned  Address Tank Changes  Secure Tank & Clean Area  Conduct Post-Entry Briefing

API RP 2009, Safe Welding, Cutting

and Hot Work Practices

 Scope – Provide guidelines for safely conducting welding, cutting and other hot work activities in the petroleum and petrochemical industries  Hot tapping is excluded and covered by API RP 2201  Hot work defined as any operation that can produce sufficient heat, flame, spark or other source of ignition with the energy to ignite flammable gas, vapor or dust

API RP 2009

 Job analysis  Hazard evaluation and risk reduction  Implementation of safeguards  Testing for hazards  Hot work permits  Hot work in confined spaces  Work inside vessels  Work on exterior  Work on equipment in service  Work in buildings and pits  Work on piping

NFPA 326, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair  Chapter 4 – Basic Precautions  Chapter 5 – Preparation for Safeguarding  Chapter 6 – Testing Procedures  Chapter 7 – Control or Removal of Vapors  Chapter 8 – Inspection and Certification of Tanks and Containers  Chapter 9 – Procedures for Access to and Entry of Tanks  Chapter 10 – Cleaning Tanks and Containers

NFPA 326 Purpose

 Establishes minimum requirements for the safe opening, entry, and cleaning of a tank or container that contains or has contained flammable, combustible, or other hazardous substance vapors, liquids, or solid residues  …the safe removal of flammable, combustible, or other hazardous substance vapors, liquids, or solid residues from tanks or containers and the safeguarding of these vessels for entry, cleaning, or repair  …the minimum procedures that permit repair, hot work, or other operations that have the potential to create a fire, an explosion, or another hazard

Chapter 6 – Testing Procedures

 Safe entry, cleaning, or repair work requires tests for oxygen, flammable/combustible, or other hazardous substance vapors, with an appropriate instrument:       Before entry or re-entry Before start of alterations or repairs Before and during any hot work operations Continuously or periodically during the work After cleaning tanks to determine that cleaning is effective After any process or activity that might change conditions  Precautions also taken to ensure that tanks or containers that have held liquids with high flash points do not become hazardous during cutting and welding operations

Chapter 8 – Inspection and Certification of Tanks and Containers

 8.2.4 Hot Work Allowed  Establishes atmospheric thresholds  Oxygen enrichment – less than 23.5 % oxygen  Flammable/combustible atmospheres – 0 % LFL  Residues – removed sufficiently to prevent regeneration of dangerous concentrations of contaminants  Adjacent spaces highlighted (as applicable)

NFPA Safe Tank Entry Training Summary

 Establish safe work practices based on recognition, evaluation, and control principles  Recognize hazards inherent to space design as well as use or function  Recognize that work can change initial conditions  Perform frequent atmospheric monitoring  Use forced mechanical ventilation  Establish permit system  Train on safe work practices

Role for the Marine Chemist with AST

 Might not always be called to establish initial entry  Role of the attendant – frequent retesting of conditions  Hot work  Atmospheric monitoring expertise – especially for toxicity  Recognized within the petroleum/petrochemical AST environment 68

OSHA Standards

  1910.106 - Flammable and Combustible Liquids  1910.146 - Permit-Required Confined Spaces 1910.134 - Respiratory Protection  1910.147 - Control of Hazardous Energy  1910.1000 - Air Contaminants  1910.1200 - Hazard Communications

NFPA Codes & Standards

 NFPA 30, Flammable and Combustible Liquids Code  NFPA 326, Safeguarding Tanks or Containers for Entry, Cleaning or Repair  Related informational documents –  NFPA 306, Control of Gas Hazards on Vessels  NFPA 69, Explosion Prevention Systems

Key API Standards & Recommended Practices

 ANSI/API Standard 2015, Safe Entry and Cleaning of Petroleum Storage Tanks, 6 th Edition (2001)  ANSI/API Recommended Practice 2016, Recommended Practice for Entering and Cleaning Petroleum Storage Tanks, 1 st Edition (2001)  API Publication 2217A, Guidelines for Work in Inert Confined Spaces in the Petroleum Industry, 2 nd Edition (1997)  API Publication 2219, Safe Operation of Vacuum Trucks in Petroleum Service, 2 nd Edition (1999)

Informational API Standards & Recommended Practices – Part I  API Standard 653, Tank Inspection, Repair, Alteration, and Reconstruction (2001)  API RP 2003, Protection Against Ignitions Arising out of Static, Lightning and Stray Currents (1998)  API Publication 2009, Safe Welding, Cutting and Other Hot Work Practices in Refineries, Gas Plants and Petrochemical Plants (2002)  API Publication 2026, Safe Access/Egress Involving Floating Roofs of Storage Tanks in Petroleum Service (1998)

Informational API Documents – Part II

 API RP 2027, Ignition Hazards and Safe Practices for Abrasive Blasting in Atmospheric Storage Tanks in Hydrocarbon Service (2002)  API Publication 2201, Procedures for Welding or Hot Tapping on Equipment in Service (1995)  API Publication 2202, Dismantling and Disposing of Steel from Leaded Gasoline Aboveground Storage Tanks (1991)  API Publication 2207, Preparing Tank Bottoms for Hot Work (1998)

Informational API Documents – Part III

 API Publication 2220, Improving Owner and Contractor Safety Performance (1998)  API Publication 2221, Manager’s Guide to Implementing a Contractor Safety Program (1996)  API Publication 2350, Overfill Protection for Storage Tanks in Petroleum Facilities (1996)

Questions?

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Thank you!