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BP OIL -- TOLEDO REFINERY

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Document Type: Procedure

Refinery Wide

Procedure No.: SAF 033

Effective Date: February 28, 2018

Inert Entry

Revision No.: 2

Owner: Michael Stack

Authorized By: Chris Conley

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SCOPE

This policy applies to all BP and Contract employees performing work in and around an area where inert entry work is being performed.

HEALTH

Special PPE & Special Hazards

Inert entry tasks involve entering confined spaces that are oxygen deficient and a known IDLH Atmosphere. No BP Employee is permitted to enter an inert atmosphere.

SAFETY

Chemical and physical hazards exist when completing inert entry into confined spaces. These hazards include IDLH atmospheres due to nitrogen in a confined space, pyrophoric hazards, and catalyst dust.

REFERENCE

DOCUMENTS

API Standard 2217A -- Guidelines for Safe Work in Inert Confined Spaces in the Petroleum and Petrochemical Industries

MAINT-E-033 Cranes and Lifting

SAF-032 – Confined Space Entry

SAF-023 – Using Direct Reading Gas Testing Equipment

SAF-026 – PPE Policy

SAF-033-FM- 01 – Inert Entry Confined Space Permit

SAF-037 – Lock Out/Tag Out Procedure

SAF-086 – Use of Nitrogen

SAF-109 – Respiratory Protection Program

SAF-116 – Barricading of Hazardous Activities

COW-PRO-002 – Control of Work Policy

OSHA Standards – 29 CFR 1910.132, 134, 146, 147, 1000, 1200

BP Technical Group Hydroprocessing Handbook

D-PRO 4.5-0100 Catalyst Change Out - Confined Space Inert Entry

Procedure No. SAF-033 Rev. No. 2

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SPECIAL MATERIALS &

EQUIPMENT

Supplied airline respirators, life support helmets, breathing air monitoring systems, video recording systems, speciality gas testing equipment

QUALITY Nitrogen quality must be maintained during inert entry activities.

ENVIRONMENTAL

Catalyst removal generates waste. Environmental policies are required to be followed.

1.0 Definitions

BP Contact – An individual designated by BP to be the point of contact between the Specialty Contractor and Operations. This individual must be clearly identified and is typically a maintenance Supervisor (Performing Authority) or TAR staff member.

Confined Space – Any space large enough and so configured that an employee can enter and perform assigned work, has limited or restricted means for entry or exit, and is not designed for continuous employee occupancy.

Entry Supervisor- The person responsible for determining if acceptable entry conditions are present at a confined space where entry is planned, for authorizing entry, overseeing entry operations, and for terminating entry. The duties of entry supervisor may be passed from one individual to another during the course of an entry operation. These responsibilities also may be transferred between the owner and contractors.

Hazardous Atmosphere – An atmosphere that may expose employees to the risk of injury, incapacitation, acute illness, impairment of ability to self-rescue (to escape unaided from a confined space), or death.

Hot Zone – The area around the entrance to the inerted confined space most likely to be affected by effluent gases; sometimes called the “restricted area.”

Inert Entry – Entry into a confined space that has / is purged with an inert gas (oxygen deficient).

Inert Entry Watch/Top Side Attendant – This is an authorized and trained representative from the Specialty Contractor who will watch and monitor the entrant working in an inert atmosphere. The Inert Entry Watch will be required to wear the same PPE as the person making the inert entry.


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Immediately Dangerous to Life or health (IDLH) -- The maximum concentration of an air contaminant from which one can escape without experiencing any escape-impairing or irreversible health effects. Total loss of respiratory protection in an inert atmosphere can cause virtually immediate impairment and result in rapid asphyxiation and death.

Life Support Unit (LSU) – The Life Support Unit is a module that is staged in the unit where all inert communications, monitoring, videotaping and data collection takes place. Staging of the LSU will be decided by BP Operations and the Specialty Contractor.

Nitrogen (N2) Purge –The process of introducing nitrogen into a reactor or vessel for the purpose of eliminating oxygen, thereby preventing combustion.

Nitrogen Supply Contractor – External party that supplies a source of nitrogen

Oxygen Deficient Atmosphere -- an atmosphere in which the oxygen (O2) content is below that needed for normal human function without impairment (below 19.5% O2).

Risk Assessment –Systematic examination of a task in order to identify all hazards, assess all risks, and identify safe methods of work to ensure that the hazards are eliminated or the residual risks are minimized. This is completed as an element of the Control of Work Program.

SDS – Safety Data Sheet

SIMOPS (Simultaneous Operations) –Other jobs or operations in the vicinity of the work, including members of your own work group, which may affect or be affected by the hazards of a task

Specialty/Catalyst Contractor – Contracted by BP to perform activities in oxygen deficient vessels or reactors

Pyrophoric– A material (e.g. iron sulfide, certain catalysts or certain carbonaceous materials) that, when exposed to air, can spontaneously oxidize and heat, providing a source of ignition if a flammable vapor/air mixture is present.


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2.0 Roles and Resposibilities

Inert Entry Contractor

Entry Supervisor Implement the Inert Entry Execution Plan.

Execute the Emergency Response Plan if necessary.

Determine if acceptable entry conditions are present.

Terminate entry when required.

Supervise the entry crew.

Inert Entry Watch Monitor the confined space entrant activities.

Initiate emergency response plan if needed.

Inert Entry Contractor Topside Supervisor

Perform continuous monitoring at the point of entry (i.e. the Hot Zone/Exclusion Zone) to ensure that the barricades are broad enough to protect those outside the Hot Zone/Exclusion Zone). (Note 1)

Life Support Unit (LSU) Attendant

Record the continuous gas monitoring readings on the inert entry log after initial entry and once per shift thereafter when the entrant is inside the confined space.

List by name each entrant on the entrant log and record the times they enter and exit the space.

Verify by video that the catalyst height differential does not exceed waist level.

Verify shift logs document minimum/maximum catalyst bed levels.

Record all alarms activated, false or actual when working under inert conditions after preparation for entry..

CSE Rescuer Perform rescue inside the inert confined space. (Note 2)

Assist in pre-entry verification of response systems and procedures.

BP

BP Contact Point of contact between Inert Entry Contractor and BP Operationas and supporting craft.

Inert Entry Single Point of Accountability (SPA) - or delegate. (SAF 033 Owner)

Authorize entry (can be delegated to the permit issuing authority as defined in D-PRO 4.5-0001).

Verify the safe execution of confined space inert entry related activities by BP and the Inert Entry Contractor personnel.

Verify the Inert Contractor’s Inert Entry Execution Plan and Emergency Response Plan is reviewed by a BP Safety Advisor.

Complete the self-verification checklist.

Recommend inert entry execution plan.

Emergency Response Specialist

Review and agree with the Inert Entry Contractor’s Emergency Response Plan.

Coordinate Emergency Response planning with Inert Entry Contractor prior to entry.

Operations Manager Recommend inert entry is preferred over alternative methods.

Approve Task Risk Assessment per D-PRO 4.5-0001

Approve Inert Entry Execution Plan.

Site HSSE Manager or Delegate

Review the Inert Entry Execution Plan.

Agree on approval of inert entry execution plan.

S&OR Entity Director Agree on inert entry versus alternatives as part of planning process.

Entity Leader Decision on inert entry versus alternatives as part of planning process

Notes:

1. The role of inert entry watch and Inert Entry Contractor topside supervisor can be the same individual if the BP SPA determines that this is acceptable / possible.

2. The CSE Rescuer cannot enter the space for any reason including rescue until a second rescuer is in place with proper PPE.

3.0 Inert Entry Planning __3.1 The unit process engineer shall review all reasonable


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alternatives to inert entry prior to the work proceed to the planning phase.

1. Use of hydrocarbon based catalyst passivation (e.g. – CatNap) in fresh air shall not be considered.

2. Use of water flooding shall be considered.

Note

Additional background on water flooding as an option

to inert entry can be obtained from the Refining

Technology & Engineering (RTE) Hydroprocessing

Group.

3. Other viable alternatives may be proposed to the S&OR Entity director for consideration.

__3.2 The written recommendation of the unit process engineer will be forwarded to the site Operations Manager for consideration. The Operations Manager makes the final recommendation to the Business Unit Leader that the inert entry is the preferred method.

__3.3 The Business Unit Leader decides whether catalyst handling activities using inert entry may procced to the execution phase with agreement form the S&OR entity director.

4.0 Contractor Selection

__4.1 For the initial contractor selection process, The Inert Entry Contractor shall submit the following for BP review:

a. Inert Entry Contractor policies & practices pertaining to:

i. Work zone control and Hot Zone/Exclusion Zone barricading

ii. PPE iii. Atmospheric monitoring iv. Emergency response plan v. Heat stress/fatigue management vi. Loading sock/equipment integrity

1. Refer to D-IG 4.5-0002 for additional information loading sock equipment and integrity.

vii. Training program viii. Any other Inert Entry Contractor practices or

procedures for inert entry b. Experience level for all Inert Entry Contractor staff

planned to be on site for the job.


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5.0 Nitrogen Purge

__5.1 Operations have responsibility for establishing a nitrogen purge on the inert entry space.

__5.2 Primary nitrogen supply to the vessel may be

sourced from the plant nitrogen system or an independent supply (usually truck). The primary source of nitrogen will be a joint decision between Technical Engineering and Operations.

a. The Reformer 3 Dedicated Nitrogen System cannot be used for anything other than maintaining the nitrogen bubble between the reactor and regen. No connections to the Reformer 3 Dedicated Nitrogen System can be made for any other purpose, including inert entry activities.

__5.3 A back up nitrogen source must be available in the case that primary supply is lost. The plant nitrogen system cannot serve as both the primary and backup supply for the same vessel.

__5.4 A Quality Assurance Plan for the source nitrogen

must be established by technical engineering prior to beginning inert entry activities. This can be documented as part of the Level 2 Risk Assessment and should include methods for collecting samples, acceptable limits, and frequency of samples.

__5.5 A relief valve must be present on the nitrogen truck

lines to prevent overpressure.

__5.6 Ensure that internal pressure of the inert confined space is not increasing because of the inerting gas. (bottom measurements and observation of back pressure can be used in most cases since inert gas is often introduced at the bottom of the vessel and flows out the top).

a. A back pressure test must be performed when nitrogen is being introduced through the bottom of the reactor.

b. The nitrogen backpressure test shall be as follows: i. Install a pressure gauge on the nitrogen

supply, as near to the vessel as practical. ii. Block in nitrogen supply and record time for

pressure to drop to atmospheric pressure. c. If the time to reach atmospheric pressure exceeds

5 seconds, entry to the confined space shall be


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prohibited as long as nitrogen continues to be introduced from the bottom.

__5.7 Control of all nitrogen supply valves to the inert

space will be transferred to the Specialty Contractor. The Specialty Contractor must tag these valves with legible, substantial tags that clearly indicates who is in control of the valve. Where the contractors program does not define the tag to be used. Use the tag in Appendx C.

6.0 Isolation, Lock Out/ Tag Out, and Permitting

__6.1 Inert entry requires positive isolation of the confined space, other than the nitrogen supply.

__6.2 The refinery isolations practice shall be adhered to.

__6.3 The Specialty Contractor may use their own Lock Out/ Tag Out locks and program provided that it meets or exceeds OSHA regulations. The Specialty Contractor will place a blue foreman’s lock onto the operations lock out point (key).

__6.4 The BP Performing Authority, Specialty Contractor Supervisor, and BP Safety Advisor are required to walk down the isolation plan prior to authorizing inert entry.

__6.5 SAF-033-FM-01 Confined Space Entry Permit for Inert Entry will be issued in place of a standard Confined Space Entry Permit while Inert Entry is taking place. A defined representative from the Specialty Contractor will serve as the Entry Supervisor. The Specialty Contractor will maintain their own Confined Space Entry documentation( sign in/out logs and gas testing results)

__6.6 A standard Confined Space Entry Permit will be issued and isolations re-verified if the vessel will be turned over to regular atmosphere for entry.

7.0 Ignition Sources and Tools

__7.1 All lights, tools, and cameras used in the confined space must meet the area electrical classification.

__7.2 Any air driven tools used in an Inert Confined Space will be driven from nitrogen, not air.

__7.3 Catalyst loading/unloading equipment will be properly grounded and bonded.


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8.0 Atmospheric Conditions

__8.1 Atmospheric conditions within the inert entry confined space must be maintained within the following limits:

o Oxygen – 0% - 4%

o Lower Explosive Limit (LEL) - <10%

o CO - <50ppm

o Hydrogen Sulfide - <10ppm

o Ambient Temperature - <100°F

WARNING

Specialty gas detection equipment is required for use in inert atmospheres. Contact the Safety Department for these instruments. The MSA Altair, Sirius, and BW Micro 5 cannot be used for the testing. (exception exists for the Altair with dilution fitting)

__8.2 If any of the above limits are exceeded or if either the vessel internal atmospheric or catalyst bed temperature increases 5°F in 15 minutes , an evacuation of the space is required.

__8.3 Initial gas testing of the inert entry confined space will be

performed by the Specialty Contractor and observed by a BP Safety Advisor (must also be a Level 1 Authorized Gas Tester). This must include Oxygen, LEL, CO, total petroleum hydrocarbon (a.k.a volatile organic compounds), benzene, and H2S. The BP Safety Advisor will sign the initial gas testing result on the Entry Permit. The BP Safety Advisor is required to confirm the Specialty Contractor is utilizing acceptable gas testing equipment for the inert atmosphere and the device is within calibration.

__8.4 Continuous gas testing of the space is required. All continuous gas testing must be performed with the entrants. The tubing on the gas detection devices must be sufficient to test the atmosphere at the elevation the entrants are located.

__8.5 Both a primary and secondary gas detector are required to be in place prior to entry operations. The secondary (back-up) shall be appropriately calibrated, charged (full batteries), and ready for use in the event of primary detector failure. The secondary device may be turned off until needed.


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__8.6 The Specialty Contractors logged gas testing readings will serve as the entry gas testing results after the initial test.

__8.7 Continuous internal atmospheric temperature monitoring

must be in place by the Specialty Contractor.

__8.8 Any use of TI’s to monitor temperature is governed by the hydroprocessing handbook: Attachment 21 - Reactor Temperatures for Entry. The unit process engineer should provide input to the Level 2 Task Risk Assessment on this subject as it varies depending on the vessel.

9.0 Breathing Air Supplies

__9.1 The Specialty Contractor is responsible for all breathing air supplies, equipment, testing, monitoring, and inspection outlined in this section.

__9.2 The minimum respiratory protection requirements for inert atmosphere entrants and the top side attendant are:

o Two (2) completely independent continuous air supplies and one secondary emergency egress air supply bottle.

o Lock-on life support helmet equipped with communication ability. This equipment will meet NIOSH, MSHA, or other equivalent standards.

o All umbilical lines (breathing air and communication) must be shielded from damage by a sufficient protective coating/sheath such as PU (UDF 20430) or an equivalent method.

o Primary air pressure monitor for each individual wearing helmet with audible and visual alarms to indicate low primary supply and regulated pressure

o A secondary air pressure monitor for each individual wearing a helmet, including an alarm indicating the cut-in of the secondary supply to any of the helmets and to alarm to indicate a low supply pressure.

__9.3 All umbilical lines being run to elevation will be secured as much as feasible to minimize movement of the lines due to wind.

__9.4 A battery-fed power supply must be equipped to cut in

automatically on failure of the electrical supply to the breathing air monitoring system.


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__9.5 The Specialty Contractor will complete a documented pre-

use inspection to ensure physical integrity and cleanliness of equipment.

__9.6 Refinery air systems shall not be used to supply breathing

air.

__9.7 The Specialty Contractor must continually monitor the air supply of the workers in and near the confined space. This person is responsible for ordering the evacuation of the space if the breathing air system is compromised or goes into an alarm state.

__9.8 The Specialty Contractor will ensure that purchased breathing air meets, at a minimum, Quality Verification Level D (formerly called Type I, Grade D), breathing air.

__9.9 The Specialty Contractor shall train and fit test all employees on the use of respiratory protection equipment in a manner that meets or exceeds OSHA requirements. Training records and fit test records must be made available upon arrival on site to perform work. The BP contact will review these records.

10.0 Logs and Video Monitoring

__10.1 The Specialty Contractor is required to provide a copy of their log at the end of each shift to their designated BP Safety Advisor. The following information must be included at a minimum:

o Entry and exit dates/times of all personnel o Gas testing results for Oxygen, LEL, CO, H2S, and

ambient temperature every 15 minutes. o Catalyst bed outages and conditions every hour o Any changes to catalyst removal methods or tools o Any changes to how nitrogen is being supplied to

the reactor, including flow rates. o Any evacuations of the space due to changes in

atmospheric conditions or safety concerns

__10.2 The Specialty Contractor must have video surveillance and recording capability. Recordings must be made available to BP upon request and retained by the Specialty Contractor for 30 days following the inert entry.

__10.3 The Specialty Contractor will perform a recorded video sweep (360°) around the current work location of the entrant every hour.


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11.0 Internal Work Practices

__11.1 The Specialty Contractor will have a work practice in place to prevent the engulfment of the entrant in catalyst.

o The Specialty Contractor shall never allow the catalyst wall height to exceed 3’ or waist height of the entrant, whichever height is lower, relative to the lowest level of the catalyst bed.

o The Specialty Contractor shall never allow catalyst to build up on walls or structures or in a manner that they could collapse and engulf or injure the entrant.

o Entrants shall not leave the hard ladder nor stand on any portion of the bed if a waist high differential in the bed’s height exists.

__11.2 The Specialty Contractor will provide and stage for use a spare vacuum hose of sufficient length to replace a hose damaged by catalyst bed cave-in. This hose must be rapidly deployable for rescue use.

__11.3 No Entrants into the inert space will exceed a

continuous interval of four hours in the space without at least a 45 minute break period outside the space. An 30 minute extension, may be provided on a case by case basis with approval of the BP Contact, and BP Safety Advisor supporting this activity.

__11.4 If a cable/rope ladder is going to be used in place of a hard ladder it must be documented in the Level 2 Task Risk Assessment. The ladder must be secured at each tray and the bottom of the vessel.

__11.5 The Specialty Contractor must assign a trained individual to monitor the following items continuously:

o Breathing air supply o Gas detection readings o Communications from entrant and top side

attendants o Radio channel 16A and the operations radio

channel (must have 2 BP radios)

__11.6 When feasible sock loading the length of the sock cannot exceed 25 feet. The sock and associated equipment must be protected from falling into the vessel. Longer socks are only permissible when there is no other


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feasible alternative; and the required evaluations and requirements in the Hydroprocessing Handbook Chapter 7.6.1 are implemented.

__11.7 The Specialty Contractor will submit their procedure for securing the sock and associated equipment from falling into the vessel. The BP contact will review these procedures and approve them or require added controls. These added controls will be documented as part of the Level 2 Risk Assessment.

__11.8 The Specialty Contractor will ensure that the primary and back-up inert entry staff are equipped with two (primary and secondary) communication devices.

Note

The secondary communication device can be a signal

device (such as an air horn), or other means of

communication that can be used to let the entrant

know that the primary communication device is not

working and the entrant needs to evacuate the space.

12.0 External Work Practices

__12.1 The Specialty Contractor is required to present a plan that includes their barricading procedure to control access to the work area. This includes work at grade, at heights, and establishing the “hot zone” on the top side of the vessel.

__12.2 The restricted work areas will be established and monitored by the Specialty Contractor. Signs will be posted that clearly warn that nitrogen is present.

__12.3 The Specialty Contractor will have exclusive control of the “hot zone” on the top side of the vessel. Only Specialty Contractor personnel are permitted within the “Hot zone.” BP Employees are prohibited from entering the hot zone, including for purposes of rescue.

__12.4 Non-specialty contractor personnel may be permitted in the topside area with specialty contractor approval, provided it is not a hot zone. This is provided the entry to the inert space is covered with a hard barricade, and gas monitoring shows no oxygen deficiency outside the space.


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__12.5 The Specialty Contractor will define areas that require

respiratory protection, including catalyst handling work at grade.

__12.6 A solid cover shall be used to prevent access to the main vessel entry point when entry is not in progress.

__12.7 Individuals that are loading catalyst into open containers under a nitrogen purge will be required to utilize airline respirators. (see diagram in Process Safety Booklet Ten: Hazards of Nitrogen and Catalyst Handling)

__12.8 All employees that are on the top side of vessel and outside of the “hot zone” or handling nitrogen blanketed catalyst at grade will be equipped with an oxygen monitor in addition to other required personal gas detection equipment.

__12.9 The requirements of SAF-116 – Barricading of Hazardous Activities must be adhered to by all personnel involved in the inert entry or working in the area.

__12.10 All spent catalyst and PPE waste must be handled per site environmental policies.

13.0 Additional Hazards __13.1 Engineering practices and sampling during vessel shut down and preparation must account for the monitoring of formation of nickel carbonyl [Ni (CO)4]. This is done by monitoring for Carbon Monoxide. Nickel carbonyl is formed by the reaction of carbon monoxide with nickel and is extremely toxic when inhaled.

o For catalyst systems using catalyst that contain base metals, the hazard to Nickel Carbonyl exposure shall be tested.

o Carbon monoxide content in the circulating gas shall be less than 10 ppm prior to cooling below 200 deg C (390 deg F).

o If Carbon monoxide content is greater than 10 ppm the catalyst shall be heated to 204° C (400°F), the circulating gas purged as necessary to reach <10 ppm, and cooling resumed.

__13.2 Loading of catalyst that is pre-sulphurised, pre-sulphided

or pre-activated catalysts that are classified as self


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heating must be done under inert atmosphere.

__13.3 The following potential hazards could exist and should be considered for documentation in the Level 2 Task Risk Assessment (L2TRA): o Catalyst beds not supporting workers weight o Hot spots inside catalyst bed o Dumping operations impacting stability of catalyst

bed and creating voids o Pyrophoric material o Elevated temperatures can cause heat stress or

fatigue o Sharp or abrasive objects/surfaces on trays, lugs,

brackets, internal supports o Cluttered or obstructed work space caused by poor

housekeeping o Congestion at job site caused by life-support lines

and personnel in area o Weather enclosures over entry points to an inert

vessel could become oxygen deficient o Unauthorized personnel in the area o Lighting levels o Adverse weather conditions o Dropped/falling objects

11.0 Rescue and Emergency Response

__14.1 The Specialty Contractor will provide written rescue and emergency response plans, specific to the inert entry taking place. The BP Emergency Response Specialist will review the plan for completeness. i. The Emergency Response Plan shall include the

following: 1. The use of non-entry rescue methods

whenever possible. 2. A defined plan that outlines tactics to have

readily available a spare vacuum hose (not vacuum unit) of sufficient length to replace a section torn off by catalyst bed cave-in, for rescue efforts.

3. A defined communication protocol for the Inert Entry Contractor to notify BP in the event of an emergency.

4. The location defined for a rescued worker to be transferred from the care of the Inert Entry Contractor to the Site/Entity emergency response team.


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__14.2 The Specialty Contractor will be responsible for initial confined space rescue efforts to include removing entrants from the space and the hot zone. If the Specialty Contractor has the training and equipment to complete a full rescue to grade, they will include that aspect in their plan.

__14.3 A winch will be immediately available to remove the entrant from the space.

__14.4 When the Inert Entry Contractor is equipped and qualified to complete the rescue and deliver a victim to grade for emergency medical care, a BP supplied high angle rope rescue team (a.k.a Confined Space Rescue Team) will not be required to be in the refinery provided the contractor can demonstrate their ability to complete the rescue in a timely manner.

__14.5 When a BP provided high angle is reqired to support the inert entry contractor:

a. BP onsite confined space rescue team is available on radio channel 16A and must be immediately notified if the Specialty Contractor initiates any type of rescue or emergency response effort.

b. The BP onsite confined space rescue team will be

available to assist the specialty contractor in removal of a patient from the top side of the vessel to grade.

c. The BP onsite confined space rescue team will provide a

rescue plan to supplement the Specialty Contractor’s plan, as appropriate.

d. BP employees are prohibited from entering the inert confined space for any purpose including rescue / emergency response.

__14.6 The Specialty Contractor is required to provide individuals trained to meet or exceed OSHA standards for all rescue operations that they have pre-planned to perform. These training records must be made available to BP upon arrival on site to perform work. The records will be verified by the BP Contact.


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__14.7 The Specialty Contractor will ensure that their plan accounts for the staging of appropriate personnel and equipment to respond in the case of an emergency.

15.0 Pre-planning and Responsibilities

__15.1 The BP Contact is responsible for: o Ensuring the Specialty Contractor has received a

copy of this procedure, other applicable site procedures, and applicable SDS sheets prior to entry taking place, preferably before arrival on-site.

o Ensure that the Specialty Contractor’s work plans and emergency response plans are received by BP and a copy provided, for review, to a BP Safety Advisor

o Review documents provided by the Specialty Contractor.

o Ensure that the Specialty Contractor is supplied with at least 2 BP radios.

o Must remain on-site for duration of inert entry activities.

__15.2 Operations is responsible for:

o Ensuring that the vessel has been properly prepared for entry and isolated from all energy sources.

o Issuing the final authorization for inert entry to begin by issuing Control of Work permits and the authorization of the Confined Space Entry Permit.

o Issuing a new Confined Space Permit and verifying isolation is still adequate if the vessel will be turned over to regular atmosphere for entry following inert entry.

__15.3 The BP Safety Advisor is responsible for:

o Verifying the isolation of the vessel, review of the Specialty Contractor’s plans and procedures, and administration of the Inert Entry Safety Work Assurance program.

o Witnessing the initial gas test and signing the initial entry gas test on the Confined Space Permit.

o Witnessing the initial gas test on the vessel if it is going to be turned over to regular atmosphere for entry following inert entry.

o Must remain on-site for the duration of confined space entry.

o The responsibilities of a BP Safety Advisor for purpose of Inert Entry may be delegated to the


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following individuals with approval from the Safety Team Leader:

o A contractor hired to fill the role of a BP Safety Advisor.

o A HSSE employee with equivalent training of a BP Safety Advisor.

__15.4 The Specialty Contractor is responsible for:

o An Inert Entry Execution Plan shall be developed by the Inert Entry Contractor to include:

Results of the L2TRA.

Inert Entry Contractor policies & practices pertaining to:

i. Work zone control and Hot Zone/Exclusion Zone barricading

ii. PPE iii. Atmospheric monitoring iv. Emergency response plan v. Heat stress/fatigue management vi. Loading sock/equipment integrity vii. Training program viii. Any other Inert Entry Contractor

practices or procedures for inert entry

Experience level for all Inert Entry Contractor staff planned to be on site for the job.

o Reviewing all BP procedures and SDS sheets provided to them and ensuring compliance for the duration of the work.

o Providing required training to their employees and ensuring competence for the job tasks they will be completing.

o Report any changes to job scope, failures of equipment, incident, injury or other unexpected event to their BP Contact immediately. These conditions require work to be stopped for reassessment.

o Providing and maintaining atmospheric monitoring equipment cabable of testing for the constituent listed in sections 8.0 and 9.0 of this procedure.

o Monitor the atmospheric conditions in the vessel and the wellbeing of their employees for the duration of the task.

o Ensure that minimum nitrogen flow is being maintained to the vessel.

o Responsible for providing any requested training,


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certifications, and logs to BP upon request or as defined in this procedure.

__15.5 All Level 2 Task Risk Assessments must be completed

with representatives from the Specialty Contractor present. This cannot be completed by teleconference and must include a review of the vessel drawing.

__15.6 The BP owner of this procedure will organize a meeting of the personnel shown in the table below for the review and approval of the Inert Entry Execution Plan: RAPID responsibilities for approval of Inert Entry Execution Plan

Recommend SAF 033 owner

Agree Entity HSSE Manager (or Delegate)

Entity Emergency Response Contact

Perform Inert Entry Contractor

Input TAR Manager/Maintenance Manager

Decide Entity Operations Manager

16.0 Self-verification __16.1 The Specialty Contractor will complete the Inert Entry Safe Work Assurance Checklist in Appendix A prior to entry each shift. The sheet that is completed for initial entry must be secured to the Confined Space Entry Permit and reviewed prior to entry by the BP Safety Advisor.

__16.2 A BP representative will complete the Inert Entry Safe Work Assurance Checklist in Appendix B at least once a shift. The BP Safety Advisor will coordinate this process. The following individuals will participate in the completion of the checklist, when assigned: o BP Safety Advisor o Safety Representative acting on behalf of BP o BP Contact o TAR Event Manager o TAR Manager o Operations Coordinator o Operations Lead (salary or hourly) o Area Operator o Process Engineer o Operations Superintendent

__16.3 The reporting process for deficiencies is noted on the

bottom of the checklists and must be followed.


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__16.4 Completed checklists will be returned to the BP Safety

Advisor and managed by the Safety Department.

17.0 Deviations __17.1 Any deviation from these established procedures shall be approved through a Management of Change.

__17.2 Turnarounds, Special Projects, Greenfield or Brownfield

work may be exempt from specific elements of this procedure provided they have a written plan that addresses inert entry activities and meets all OSHA requirements. The exemption from this procedure must be approved by consensus from the HSSE Manager and Operations Manager.

Revision history The following information documents at least the last 3 changes to this document, with all the changes listed for the last 6 months.

Date Revised By Changes

10/23/2015 S.Sedlak Initial Release M20151705-001

05/02/2016 S.Sedlak Removed requirement for an ambient vaporizer on nitrogen trucks, added requirements securing socks during loading, fixed discrepancy regarding catalyst wall heights on checklists, added clarification on who can fill the responsibilities of a BP Safety Advisor, added requirements for BP Contact to review specific documents prior to entry. M20161210-001

02/28/18 M Stack Added reference to D-PRO-4.5-0100. Added Inert Entry Planning and Contractor Selection Criteria. Added prohibition for non-Specialty Contractor Personnel in the hot zone. Added requirement for hard entry cover when entry not in process. Added prohibition for BP entry into the inert space for rescue. Added requirement for bongin/grounding of loading equipment. Added specific requirements for the prevention of nickel carbonyl formation. Added requirement for two communication devices. Added requirement for certifications of breathing air cylinders, Added specific language for nitrogen back pressure test, including Appendix with example. Specified more specific requirement around emergency response plan. Added specifics arounf inert entry execution development, review, and approval. Updated self verification checklists.

M2018328-001


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APPENDIX A

Confined Space Inert Entry Safe Work Assurance Checklist – Specialty Contractor


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Confined Space Inert Entry Safe Work Assurance Checklist Specialty Contractor

Must be completed prior to entry each shift and kept in life support trailer.

S = Satisfactory RA = Requires Attention NA = Not Applicable

Name_______________ Equipment __________________Date/Shift_____________

1. Equipment isolation and entry permits are in accordance with Toledo Procedures_____ 2. Procedures are in place to identify all persons authorized to enter the inert vessel._______ 3. Procedures are in place to prevent unauthorized persons from entering the vessel._______ 4. Provisions exist to prevent unauthorized entry into the vessels when there is no activity. (e.g., manway covers, hard barriers at ladder bases, etc…)__________________ 5. All persons entering, or potentially entering (e.g., rescue personnel) the vessel must wear appropriate equipment for working in an oxygen deficient vessel. The minimum expectations: • Two(2) completely independent continuous air supplies, and one secondary (e.g., emergency egress air supply of sufficient capacity for escape purposes ____________ • d. Certificate(s) from the supplier are present for testing and confirmation that all bottles of breathing air meets or exceeds ANSI/CGA G-7.1-1989 Grade D quality. • Lock-on Helmet mask type respiratory protection ____________ • Rescue personnel and equipment must be assembled and ready for use, at the vessel entry points of any vessel with oxygen deficient atmosphere. ____________

• Primary and secondary communication devices are present ____________ • A full body harness and tripod with retrieval line attached ________________6. Procedures and expectations are in place to ensure that at no time will the residual catalyst remain at a level higher than the worker’s waist relative to the lowest point of the catalyst bed level.____________ 7. Video surveillance equipment is in good working condition, with pan adjustments and recording capability.____________________ 9. Fall arrest equipment is tested, secured, and documented.______________________ 10.Gas monitor has been calibrated_______ 11. Entrants have armored umbilical cords, including air supply and communication lines:_______ 12. All umbilical’s, lighting cords, and other lines must go through the man way in a neat manner so not to interfere with ingress/egress._______________________ 13. Ingress/egress ladder is in good condition and secured appropriately.______ 14. Sufficient low voltage lighting is being used and set up in a way that prevents the cords from becoming entangled or compromised.________

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15. Contractor logs will effectively detail:

• Entry and exit dates and times of all personnel __________

• Catalyst bed outages _____________

• The catalyst bed condition (at least once an hour) ____________

• Any changes to catalyst removal methods and or tools________________________

• Any changes to how N2 is being supplied to the reactor. (Ie: bottom or horse shoe.)_____

• Gas monitoring log confirms <50ppm CO, < 4% O2, < 10% LEL, <10ppm H2S, <100F have been recorded every 15 minutes.________

• Breathing air cylinder manifold gauge readings monitored and logged.__________

• The contractor is prepared to rotate workers every 4 hours to mitigate fatigue and provide additional evaluation frequently enough to detect emerging hazards._______ ____

16. Rescue plan is documented and understood by all personnel approved for rescue in the inert atmosphere (e.g., the contractor)._____ 17. Shift starting toolbox talk has taken place with all crew members________ 18. Breathing air cylinders quality assurance has been provided (for CO and O2)._____ 19. MSDS sheets are available for spent & new catalyst_______________

Comments: ___________________________________ ___________________________________ ___________________________________ ___________________________________

Signature___________________________

Title_______________________________

Report any RA’s to your BP Contact prior to making entry. Keep this document in the life support trailer until BP Safety collects it.

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APPENDIX B

Confined Space Inert Entry Safe Work Assurance Checklist – BP


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Confined Space Inert Entry Safe Work Assurance Checklist BP

Must be completed once a shift by a designated BP Employee or delegate

S = Satisfactory RA = Requires Attention NA = Not Applicable

Name_______________ Equipment __________________Date/Shift_____________

1. Equipment isolation and entry permits are in accordance with Toledo Procedures(verify using CoW paperwork and CSE permit)_____

2. Barriers are in place to prevent unauthorized persons from entering the vessel both when the contractor is present and when there is no activity. ____________

3. Entry Contractor has completed and documented shift self-assessment._________

4. BP Ops is monitoring the closest catalyst bed TI’s to the work and has communication with life support trailer (ask the life support attendant to call for the reading)._________

5. Temperatures have not exceeded 100F, and if so, entry was suspended(verify by checking log and a conversation with the life support attendant)___________

6. Video surveillance equipment is being used to record reactor conditions and catalyst wall height has not exceeded 3’ (or waist height) at least every hour._________

7. Rescue plan is documented and understood by all personnel approved for rescue in the inert atmosphere (e.g., the contractor).__________________________

8. Rescue personnel (C&W) are on-site (call on 16A).______________

9) Rescue personnel (BP, Entry Contractor and CSR) know the patient transfer point

__________

10). Contractor logs effectively detail:

• Entry and exit dates and times of all personnel __________

• The catalyst bed outages _____________

• The catalyst bed condition (at least once an hour) ____________

• Any changes to catalyst removal methods and or tools________________________

Any changes to how N2 is being supplied to the reactor. i.e.: bottom or horse shoe.______

Gas monitor has been calibrated________

Gas monitoring log confirms <50ppm CO, < 4% O2, < 10% LEL, < 10ppm H2S, <100F have been recorded every 15 minutes.________

Breathing air cylinder manifold gauge readings monitored and logged.__________

The contractor is rotating workers every 4 hours to mitigate fatigue and provide additional evaluation frequently enough to detect emerging hazards.___________

11) Bonding and grounding of all unloading and loading equipment is in place __________

12) Two communication devices are in use to communicate with entrants(s) __________


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Comments: _____________________________________________________________ _______________________________________________________________________ _______________________________________________________________________

Print Name:_____________ Signature: ______________Title:____________________ Name of individuals spoken with:_____________________________________________ Return completed assessment to BP Safety Representative.

BP Safety will address any RA’s with BP Contact and document corrective actions on back.


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Appendix C: Nitrogen Valve Control Tag


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Appendix D: Example Nitrogen Backpressure Test

1. Ensure that a permit has been issued to install the nitrogen manifold. (sometimes called a Grubbs Manifold)

2. Install the nitrogen manifold as directed by the diagram below. The entry will NOT be allowed until a pass

has been achieved using the nitrogen manifold.

3. Valves C and E on the nitrogen manifold should be in the open position. Valves F & H will remain in the

closed position to ensure that the low pressure gauge will not be damaged from the nitrogen source during the

test.

4. Once the maximum nitrogen flow or SCFH intended for vacuuming purposes during entry has been

established, record the rates per hour and proceed to step #5.

5. Maintain maximum nitrogen flow for ten minutes and then record the pressure readings on gauge D.

Maintain maximum flow rate for an additional ten minutes to ensure that the swing of pressure has stabilized

from the first recorded reading. If the pressure has changed continue to purge at maximum nitrogen flow until

the pressure readings stabilize. (Note: there will be some fluctuations in readings). If there is no change in the

pressure from the initial or secondary readings proceed with the nitrogen pressure test.

6. Establish a clear & direct communication with the operator of the nitrogen supply.

7. To check for back pressure instruct the nitrogen operator to block nitrogen. Once the nitrogen operator has

communicated that he is shutting down, watch gauge D and block in valve C when the pressure has dropped

to the lowest established fluctuation point. When gauge D reaches 30 psig open valve F and there should be

an immediate rise and fall of pressure on gauge G. (Note: DO NOT OPEN VALVE IF GAUGE D IS ABOVE 30

PSIG. EQUIPMENT FAILURE or POTENTIAL INJURY MAY OCCUR with GAUGE G). The duration time once

valve C is blocked and gauge D & G reach zero must be five seconds or less.

8. Once gauge D & G have reached zero open valve H and check for any detectable back pressure. If

pressure is detected from valve H and is present for more than five seconds after the closing of valve C, the

test fails. (Note – two potential causes for the back pressure are a blockage in the catalyst bed, or isolation

blinds not installed correctly.) Caution: During step # 8, NITROGEN will be vented to the atmosphere. If

there are large amounts of NITROGEN being vented, proper PPE is required. (The area around the

nitrogen manifold should be considered IDLH and Breathing Air will be required. Back up Valve E is to

be used only in cases of emergency (i.e. failure of Valve C.

Example of a manifold to Control Nitrogen for the Inert Entry

SUPPORTS

ONLY


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Danger : If the NITROGEN flow cannot be maintained without the building of back pressure, shut

down the NITROGEN immediately. Alternative means of purging will be necessary in order to make

entry and remove the NITROGEN restrictions. If the nitrogen flow reaches an excess pressure at or

above 290 psig or causes any PRVs to activate immediately stop all flow of nitrogen to the reactor,

remove workers the top deck, and barricade ladders and access to the top deck. Before other action

is taken, perform a Risk assessment to determine the next course of action. Options to consider

when developing the risk assessment include:

A. Open Nitrogen purge for two hours and re-test crust/Nitrogen Flow check as described in 1-10 above.

If crust check is confirmed by pressure drop as described in step 8 above, it is OK to start work.

B. If Nitrogen pressure has dropped, but not to zero, or it took longer than 5 seconds, repeat step one

above.

C. Route nitrogen purge so that is not through the bed. Once the nitrogen purge is re-routed try to dump

a small amount out of the dump nozzle to see if the bed moves. If so, re-test crust nitrogen flow check

as described in 1-10 above.


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Appenxix E: Supplemental Gas Testing Information (Reference)

Introduction For confined space inert entries it is necessary to inert the vessel to reduce the percentage of oxygen from its normal 20% to a range of 5% or less. In many cases the inert atmosphere must be monitored for flammable gases in order to be aware of the hazards that might be present if the inert atmosphere failed or is removed. Traditional Wheatstone bridge/catalytic bead-based lower explosive limit (LEL) sensors require oxygen to detect flammable gases. A dilution fitting is typically used to introduce enough oxygen in the air to allow the LEL sensor to read properly.

What is a Dilution Fitting?

A typical dilution fitting is a plumbing device that is attached to a gas detection instrument sample inlet port, and then the sample hose is attached to the dilution fitting. When used, the sample flow going into the instrument passes through the dilution fitting. The dilution fitting has 2 small holes; one is in the sample gas stream path, and the second is through the side of the fitting and causes the instrument to take in ambient air. Essentially, the dilution fitting creates a calibrated “leak” into the incoming sample, and dilutes the sample with fresh air. If the dilution fitting is calibrated to be 1 to 1, then when used it will dilute the sample gas stream with an equal amount of ambient air.


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When is a dilution fitting needed?

There are at least two situations where a dilution fitting is needed. The first common usage is when a catalytic LEL sensor is used to test a space that is inerted (contains no oxygen). Since a catalytic sensor requires oxygen in order to operate, a 1 to 1 dilution fitting blends enough fresh air with the sample to provide enough oxygen for the sensor to properly detect flammable gases if they are present. The second common reason for using a dilution fitting is to extend the range of the gas monitor. When a dilution fitting is used, it reduces the reading of the gas monitor. If the gas monitor is calibrated to read correctly without the dilution fitting used, then when the fitting is used the gas monitor will read lower than what is actually in the gas sample. For example, if a 1 to 1 dilution fitting is used, since it dilutes the sample by 50%, this means that the reading will be half of what is actually present in the test space. In order to understand what the correct reading is, it is necessary for the operator to multiply the meter reading by 2. If a dilution fitting is 2 parts dilution to 1 part sample, then it knocks the reading down to 1/3 of the actual value, and in this case it is necessary to multiply the meter reading by 3 to get the actual concentration. So, a reading of 50% LEL is actually 150% LEL. A dilution fitting ratio can be affected by changes in pressure of the incoming gas sample. The fitting is calibrated to provide the correct dilution if the sample is drawn from atmospheric pressure. If the pressure is different, it can change the ratio. For example, if the sample is drawn from a strong vacuum, the fitting may have a difficult time pumping enough gas through the sample hole, and therefore it would draw a larger proportion of the sample through the dilution hole. In this case, you would be getting more dilution of the sample, and so the readings would be lower than expected. If the sample is drawn from a pressurized vessel, it may force too much gas through the sample hole and the pump will not be able to draw the correct amount from the dilution hole. In this case the reading may be higher than expected. In the case where it is testing an inerted space with a catalytic sensor, if insufficient dilution occurs then the LEL reading may be low or near zero because the catalytic sensor is not responding properly due to a lack of oxygen.

What is the difference between Catalytic detectors (Wheatstone bridge) & Infrared monitoring?

In detecting combustible gases in oil and gas, petrochemical and other applications, choosing between the two most common gas sensing technologies used for this purpose will be critical in ensuring a safe, reliable and cost effective solution. These technologies are catalytic combustion and infrared. There is clear need for both IR and catalytic detectors in industry. When making a choice, be sure to consider the field environment and the sources and types of gases that are being detected. Catalytic detectors are based upon the principle that when gas oxidizes it produces heat, and the sensor converts the temperature change via a standard Wheatstone Bridge-type circuit to a sensor signal that is proportional to the gas concentration. The active element is embedded in a catalyst. The reaction takes place on the surface of the catalyst, with combustible gases reacting exothermically with oxygen in the air to raise its temperature. This results in a change of resistance. The advantages of catalytic detectors are many, they are simple to operate, easy to install, calibrate and use, and have a Long life with a low replacement cost. The disadvantage for catalytic detectors is they require oxygen in order to detect hydrocarbons. The Infrared (IR) detection method is based upon the absorption of infrared radiation at specific wavelengths as it passes through a volume of gas. Infrared gas detection is based upon the ability of some gases to absorb IR radiation. There are some hydrocarbons and other flammable gases that have poor or no response on a general purpose IR sensor. In addition to aromatics and acetylene, hydrogen, ammonia and carbon monoxide also cannot be detected using IR technology with general purpose sensors of 3.4 micron specifications.


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