Guy Colonna, P.E.55th Annual MCA Seminar

Bar Harbor, MEJuly 16, 2013

Cadillac Mountain, Acadia National Park

2

AgendaBackground

Confined space statisticsRecent incidents – CSB issues

OSHA 29 CFR 1910.146, Permit-Required Confined Spaces - overview

Aboveground Storage TanksAPI resourcesTES Certification programPractical issues

Marine Chemist roleClosing

3

PRE-INVENTORY1. An OSHA confined space has the following:

a) large enough to permit entryb) intended for continuous occupancyc) normal atmospheric ventilationd) limited or restricted entry or exit

PRE-INVENTORY2. The following are tank classifications found

in OSHA 29 CFR 1910.146, Permit Required Confined Spaces.

a) Non-confined spaceb) Non-permit required confined spacec) Permit required confined space

PRE-INVENTORY3. API 2015 and 2016 use which of the

following safety designations?a) Enter with restrictionsb) Enter without restrictionsc) Enter with special precautionsd) Enter when inertede) All of the above

PRE-INVENTORY4. What is the maximum safe level of oxygen

according to 29 CFR 1910.146?a) 10%b) 19.5%c) 20.9%d) 23.5%e) None of the above

PRE-INVENTORY5. According to the Permit-Required Confined

Space standard, no permit is required when the space is unsafe.

True False

Lessons LearnedCSB 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 platformSafe hot work guidelines

– NO permit issued

HawaiiOctober 17, 2008Welding part of a catwalk connected to

the top of an oil storage tankTank was approximately 15 feet tall and

reportedly contained waste oilVapors from the tank were ignited by the

welding activities and caused the explosion that propelled tank 30 feet

One fatality, 3 injured, 2 seriously

OhioOctober 20, 2008Welding catwalk on one of four large

crude-oil storage tanks at drill rig site when a tank exploded

Two fatalitiesCSB sent investigative team

– Looking for similarities with Hawaii and Mississippi

RECOGNITION“Hazard Identification & Risk Assessment”

Identification of Spaces According to Definition

Identification of HazardsAtmospheric (oxygen, flammability, toxicity)EngulfmentEntrapmentOther physical or mechanical (energy sources,

heat stress, noise)

EVALUATION“Confirm or Deny Presence of Hazards and Determine Severity”

Qualitative AssessmentUse 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”

EngineeringVentilationIsolationSubstitution

AdministrativeSafe Work PracticesPermitsTraining

Personal ProtectiveProtective ClothingRespiratory

ProtectionFollow-up

atmospheric monitoring

Emergency and rescue

OSHA Points to MC for CS Evaluation – 1910.146, Appendix BAtmospheric 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, should be done by, or reviewed by, a technically qualified professional (e.g., OSHA consultation service, or certified industrial hygienist, registered safety engineer, certified safety professional, certified marine chemist, etc.) based on evaluation of all serious hazards.

21

OSHA DEFINITION29 CFR 1910.146A 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 hazardEntrapment hazardOther recognized serious safety

hazard

CONFINED SPACE EXAMPLESAboveground

and underground storage tanks

Process vesselsGrain silosBins

HoppersSewersUtility vaultsTanks on marine

vessels

PRCS PROGRAM REQUIREMENTSWritten programIdentify and classify spacesEstablish hazard control measures

Prevent unauthorized entryEstablish acceptable conditionsIsolationVentilationCoordinate entry by multiple workersPeriodic reevaluation for change of conditions

PRCS PROGRAM REQUIREMENTSDevelop permit system

PreparationIssuanceImplementationCancellationReturning space to service

PRCS PROGRAM REQUIREMENTSProvide specialized equipment

Atmospheric monitoringVentilationPPELightingCommunicationEmergency

PRCS PROGRAM REQUIREMENTSDesignate key personnel

EntrantsAttendantsEntry supervisorQualified atmospheric testerEmergency response

PRCS PROGRAM REQUIREMENTSPerform 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 trainingConduct program review

Confined Space ClassificationsNon-Permit Required Confined Space (API & OSHA)

Permit Required Confined Space (API & OSHA)

Non-Confined Space (API)

Non-Permit Required Confined SpaceRemember what a confined space is!

Large enough and so configured to permit entry and work

Limited or restricted entry or exitNot designed for continuous occupancy

Non-permit means the confined space has no identified hazards

Permit-Required Confined SpaceAll characteristics of confined space

as definedPossesses one or more identified

hazardsHazardous AtmosphereEngulfment hazardEntrapment hazardOther serious recognized hazard

Hazardous AtmosphereExpose employees to –

Risk of deathIncapacitationImpairment of ability to self-rescueInjuryAcute illness

As a result of exposure to –

Hazardous Atmosphere CriteriaFlammable 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 volumeToxic exposures in excess of PEL as found in

Subpart G or Subpart ZAny IDLH concentrationsContains or potential, serious harm

DESIGNATED PERSONNEL - EntrantTrained to recognize hazardsTrained to use PPE as requiredCommunicate with attendant as

necessaryRecognize symptoms of exposureUnderstand principles of self-rescue

DESIGNATED PERSONNEL - AttendantRemain outside space at all timesTrained to recognize hazards and exposure

symptomsCommunicate with entrantsCommunicate alarm, evacuate if necessaryMay monitor more than one space at a timePrevent unauthorized entrantsAlert to changing conditions

DESIGNATED PERSONNEL – Entry SupervisorTrained to recognize hazardsAuthorizes 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 TesterResponsible for conducting

atmospheric monitoringTrained 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 ServicesEither on-site or off-site permittedTrained at least as entrants and in

use of rescue equipmentTrained in basic first-aid/CPR and at

least one member certified in bothConduct annual drillCoordination between employer and

off-site provider

ANSI/API 2015 – SummaryScope 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 limitsDevelop written calibration

requirementsMaintain verification of calibration for 1

yearCalibrate according to manufacturer

Atmospheric TestingTest in specific orderTest from outside tank initiallyTest atmosphere outside the tank as well

Especially during degassingShut down ventilation prior to testing

Rule of thumb 10 – 15 minutesConduct periodic or continuous

monitoringSpecialized testing – lead-in-air

Storage Tank Hazards

Oxygen contentFire and explosionsToxic substances

Hydrogen sulfideOrganic LeadInorganic LeadAromaticsNORMOther

Physical and other hazardsTank function or

designTank conditionTank locationPhysiological

hazards (heat stress or cold stress)

API RP 2016 – SummaryTank 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 DesignationsEnter Without RestrictionsEnter With RestrictionsEnter With Special Precautions

Entry When Inerted (See API 2217A)

Enter Without RestrictionsOxygen content – 19.5% to 23.5% by

volumeHydrocarbon vapor-in-air level

inside the tank is 10% LEL or lessAtmospheric toxic levels inside the

tank are within established exposure limits (PEL or TLV)

Enter With RestrictionsThe 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 RepairSimilar designation

Enter With Special PrecautionsThis 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 InertedThe 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 SpaceDoes not meet any conditions necessary to

be considered a confined spaceAtmospheric conditions same as ambientNo restrictions on entry or exitTank 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 PlanMaterials & Equipment InformationSafety & Emergency ResponsePersonnel Qualification & TrainingClassification & Work PermitsHazards – Hazard CommunicationTank Information

Tank Preparation

Facility Permits & Work OrdersPosition EquipmentRemove Recoverable ProductIsolate TankPosition, Bond & Start EductorOpen Manway & Remove Remaining

Product

Ventilation and Atmospheric Testing

Identify supervisors & workersVentilate TankConduct External Atmospheric TestingContinue Ventilation & RetestIssue Permits for Internal Testing

Enter to Visually Inspect and Evaluate

Assess, Identify & Address HazardsImplement CS Entry Program &

Emergency Response ProgramTest & Obtain Permits to EnterPerform Pre-Clean Safety InspectionVerify or Revise Scope of WorkCertify Tank Safe to Enter

Clean Tank

Implement Cleaning Plan & PermitsMaintain Ventilation & TestingIdentify & Address Special HazardsMonitor Activities & SecurityCancel Permits, Stop Work & Exit Tank if

Conditions ChangeVerify Completion of Cleaning

Entry for Repair

Implement Work & CS Entry PlansIdentify, Address & Monitor HazardsDetermine Classification of TankSupervise & Monitor Work ActivityMaintain Site & Tank Security Cancel Permits, Stop Work, Exit and Safe

tank if Conditions Change

Return to Service

Inspect Tank Before ClosingVerify Recommissioned as PlannedAddress Tank ChangesSecure Tank & Clean AreaConduct 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 2009Job analysisHazard evaluation

and risk reductionImplementation of

safeguardsTesting for hazardsHot work permits

Hot work in confined spaces

Work inside vesselsWork on exteriorWork on equipment

in serviceWork in buildings

and pitsWork on piping

NFPA 326, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair Chapter 4 – Basic PrecautionsChapter 5 – Preparation for SafeguardingChapter 6 – Testing ProceduresChapter 7 – Control or Removal of VaporsChapter 8 – Inspection and Certification of

Tanks and ContainersChapter 9 – Procedures for Access to and

Entry of TanksChapter 10 – Cleaning Tanks and

Containers

NFPA 326 PurposeEstablishes 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 ProceduresSafe entry, cleaning, or repair work

requires tests for oxygen, flammable/combustible, or other hazardous substance vapors, with an appropriate instrument:Before entry or re-entryBefore start of alterations or repairsBefore and during any hot work operationsContinuously or periodically during the workAfter cleaning tanks to determine that cleaning is

effectiveAfter 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 AllowedEstablishes atmospheric thresholds

Oxygen enrichment – less than 23.5 % oxygenFlammable/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 - SummaryEstablish safe work practices based on

recognition, evaluation, and control principlesRecognize hazards inherent to space design as

well as use or functionRecognize that work can change initial

conditionsPerform frequent atmospheric monitoringUse forced mechanical ventilationEstablish permit systemTrain on safe work practices

Role for the Marine Chemist with ASTMight not always be called to establish initial

entryRole of the attendant – frequent retesting of

conditionsHot workAtmospheric monitoring expertise –

especially for toxicityRecognized within the

petroleum/petrochemical AST environment

68

OSHA Standards 1910.146 - Permit-Required Confined

Spaces 1910.106 - Flammable and

Combustible Liquids 1910.134 - Respiratory Protection 1910.147 - Control of Hazardous

Energy 1910.1000 - Air Contaminants 1910.1200 - Hazard Communications

NFPA Codes & StandardsNFPA 30, Flammable and

Combustible Liquids CodeNFPA 326, Safeguarding Tanks or

Containers for Entry, Cleaning or Repair

Related informational documents –NFPA 306, Control of Gas Hazards on

VesselsNFPA 69, Explosion Prevention Systems

Key API Standards & Recommended PracticesANSI/API Standard 2015, Safe Entry and

Cleaning of Petroleum Storage Tanks, 6th Edition (2001)

ANSI/API Recommended Practice 2016, Recommended Practice for Entering and Cleaning Petroleum Storage Tanks, 1st Edition (2001)

API Publication 2217A, Guidelines for Work in Inert Confined Spaces in the Petroleum Industry, 2nd Edition (1997)

API Publication 2219, Safe Operation of Vacuum Trucks in Petroleum Service, 2nd Edition (1999)

Informational API Standards & Recommended Practices – Part IAPI 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 IIAPI 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 IIIAPI 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?

Thank you!gcolonna@nfpa.org