Supersedes: 2/16 (Rev.10) Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager

Transcription

1 Procedure No.: PA Page: 1 of 29 Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager Document Revision Change Table Revision Number Revision Description Revised By Revision Date 01 Incorporated BASF Corp. requirements TF 03/ Changed Header and Footer VB 06/08 03 Added monitoring requirements for West Road (4.4.5) and TF 06/09 added Attachments A, B and C. 04 Step Modified documentation requirements for West TAD 08/11 Road LEL testing and deleted attachment A 05 Corporate changes and added attachment A Fire Prevention TAD 11/11 Precautions 06 Modified steps 2.15, 2.16, 2.20, F, 4.6.1, and for TAD 9/12 clarification. 07 Added step and checklist for Heat Treating, attachment D TD 6/13 08 Added requirements from Health and Safety Advisory #219 TDF 12/14 09 Combined maps (Attachments B & C); Attachment D is now MD 07/2015 Attachment C. Updated 1. Purpose 2.8 & Defined Fire Guard and LEL Attendant DLS 2/29/ Revised Retention requirements Deleted references to Attachment D Added EHS Requirement N-R-OSA-001-EN-M to related docs 3. scope: temporary fab areas in which hot work is waived hot work out of unit where practical and safe to remove west road monitoring removed due to permanent area LP 9/14/ monitors 4.6. qualifications to issue hwp; permit duration / revalidation 4.10 program review 6. related documents; link to corporate procedure

2 Procedure No.: PA Page: 2 of PURPOSE To establish standards for welding, cutting, brazing, grinding, or other activities which require the use of open flames, or which may generate sparks, including electrical tools, electronic equipment, and vehicles which are sources of ignition with sufficient energy to ignite combustible materials or explosive atmospheres. 2. DEFINITIONS eyes Principle The use of at least 2 individuals to review a job or task together in the field to ensure all hazards are identified and eliminated/controlled through safe work practices, use of PPE, communication/awareness, etc At a minimum this includes a Permit Issuer and an individual performing the work Blue Area An area classification, for Hot Work activities, that does not have flammable or combustible processes. These areas would include maintenance shops, new construction grass root projects that have not been introduced to flammable service and processes that do not contain flammable materials Combustible A material that could be ignited by coming into contact with open flames, heat or sparks. This includes such items as paper, wood, plastic, cloth, liquid with a closed cup flash point at or above 100 degrees F (37.8 C), but below 200 degrees F (93.3 C) Container Any bag, barrel, bottle, box, can cylinder, drum, reaction vessel, storage tank piping or the like Electrically Classified Area Locations where fire or explosion hazards may exist due to the presence of flammable gases, flammable liquid-produced vapors, combustible liquid-produced vapors, combustible dusts, or ignitable fibers/flying. These areas are required to be classified by NFPA 70, Chapter 5 (Example: Class 1 Division 1, Group A) Explosive Atmosphere A range of concentrations of gases, dusts, or fibers with air that can support ignition. The range of concentrations is material-specific. The range for a material can vary based on pressure, temperature, and oxygen content Fire Box A temporary enclosure, usually constructed of fireproof tarps that is designed to contain all Hot Work sparks and slag.

3 Procedure No.: PA Page: 3 of DEFINITIONS cont d 2.8. Fire Guard A qualified employee or contractor that has been trained at ISTC, BEST Fire grounds, or locally, not performing the Hot Work, who is assigned the responsibility of watching for conditions that may produce a fire as a result of the Hot Work activities. These persons are assigned to High Energy Hot Work jobs. 2.9 Flammable A material that falls into one of the following categories: Aerosol, flammable means an aerosol that can yield a flame projection exceeding 18 inches as full valve opening, or a flashback (a flame extending back to the valve) at any degree of valve opening. Gas, flammable means: (A) A gas that, at ambient temperature and pressure, forms a flammable mixture with air at a concentration of 13% by volume or less; or (B) A gas that, at ambient temperature and pressure, forms a range of flammable mixtures with air to be more than twelve percent (12%) by volume, regardless of the lower limit. Gas, liquefied flammable means: a flammable gas that is handled in a liquid state by keeping it under pressure or at low temperatures. Class 1A flammable liquids, any material with a NFPA flammability rating of 4 and any material with an F+ rating on the German Gefahrstoffliste are liquefied flammable gases. Process conditions will determine whether or not a material is to be considered a liquefied flammable gas. Any flammable liquid stored or handled significantly above its boiling point, but kept liquid by pressure is also considered a liquefied flammable gas. Liquid, flammable means any liquid having a flashpoint below 100 deg F (37.8 deg. C) except any mixture having components with flashpoints of 100 deg. F (37.8 deg. C) or higher, the total of which make up 99% or more of the total volume of the mixture. Solid, flammable means a solid, other than a blasting agent or explosive, that is liable to cause a fire through friction, absorption of moisture, spontaneous chemical change, or retained heat from manufacturing or processing, or which can be ignited readily and when ignited burns so vigorously and persistently as to create a serious hazard High Energy Ignition Source Operations that produce high heat or excessive sparks, including torch cutting, brazing, welding, grinding, soldering, etc.

4 Procedure No.: PA Page: 4 of DEFINITIONS cont d 2.11 Hot Work Work involving welding, torch cutting, burning, brazing, grinding or the use of open flames, in areas other than maintenance shops or designated fabrication areas designed and maintained for such work, is considered Hot Work. In addition, the use of any spark producing tool or equipment (jack hammers, grinders, drills, etc.), the use of any non-rated electrical equipment, and Vehicle Access in electrically classified hazardous areas is also considered Hot Work Hot Tap A procedure used in the repair, maintenance, and service activities which involves welding on a piece of process equipment which cannot be isolated, depressurized, or cleared; for the purpose of installing connections or appurtenances. Refer to Hot Tap or Maintenance Procedure for Hot Tap requirements Ignition Sources Include, but are not limited to, open flames, electrical sparks and arcs, hot surfaces, pyrophoric reactions, motorized equipment, electrical tools, extension cords, portable lighting, cameras, cell phones, sandblasting, grinding, chipping, soldering, etc Incipient Stage Fire A fire which is in the initial or beginning stage and which can be controlled or extinguished by portable fire extinguishers, Class II standpipe or small hose systems without the need for protective clothing or breathing apparatus LEL Attendant Contractor employees trained at ISTC and locally who are assigned jobs with only low energy hot work (such as vehicle entry) Listed or Labeled Equipment that meets identified standards or has been tested and is suitable for a specific use. Independent testing laboratories, such as UL, TUV, CSA or others assign a listing number and maintain a list of products that meet the identified standards requirements. The organization maintains periodic inspection of the production of listed equipment. The listing organization will use some means to identify listed equipment, which can include labeling Low Energy Ignition Source Operations that produce low heat and little or no sparks, such as electrical tools, hammering, lighting, sandblasting, vehicles, etc.

5 Procedure No.: PA Page: 5 of DEFINITIONS cont d 2.18 Owning/Operating Department Approval (Section IV) A final, field check to confirm the permit requirements are met. The Shift Supervisor or their designee (Technician with 5 years or more experience at the Port Arthur site) will perform the permit approval for High Energy Ignition Sources. For Low Energy Ignition Sources or Vehicle Entries the area trained technician can perform the permit approval. All (High Energy, Low Energy or Vehicle Entries) must be approved in Section IV of the permit. The person performing the Owning/Operating Department Approval shall print their name in the Safe Work Permit, section IV. The approver for a High Energy Ignition Source cannot be the same person as the Permit Issuer. Approval indicates: The applicable work on the schedule matches the Safe Work Permit The conditions in the field are safe for the Work Crew to perform their work (i.e., valves did not leak through by checking low point bleeds, verifying bleed valves are not plugged, etc.) All Hazardous Energy Source devices have been physically tested and found to be de-energized (i.e., hit the start button ) No other Hazardous Energy Sources are attached to the equipment to be worked inside the boundaries defined by the tag out; example, all purge hoses and steam hoses used for preparation are disconnected, unless otherwise noted on the permit and/or Tag Out Sheet The Tag Out Sheets and other paperwork are filled out and accurate with all applicable spaces initialed or checked off The immediate area around the equipment to be worked has been checked with the appropriate gas testing equipment for hydrocarbons and/or for toxicity as needed. All applicable requirements of Attachment A are met. If any of the above requirements are not satisfactory, the permit shall not be signed or issued. Note: If the equipment isolation is performed by the same individual who completes the Isolation section of the Tag Out Sheet on the same shift the Safe Work Permit is issued, no additional or confirmation checks are needed beyond simply isolating the equipment prior to signing the Safe Work permit and Tag Out Sheet Owning/Operating Department The BASF unit or department that operates or is responsible for the daily operation of the process, area or facility where the work is being conducted.

6 Procedure No.: PA Page: 6 of DEFINITIONS cont d 2.20 Permit Acceptor Person responsible for obtaining approval to do work. The Permit Acceptor must understand the spoken and written language in which the permit is written. The Permit Acceptor has the responsibility to inform other workers working under the permit about the hazards of the job and the requirements of the permit Permit Extension The process used to extend an existing Hot Work Permit up to 2 hours past its indicated end time Permit Issuer (section VII) Personnel identified by the Operating/Owning Department who are a) are trained to recognize Hot Work situations, the requirements for issuing a permit, and the necessary means to safeguard against the hazards posed during these activities, b) are knowledgeable of the area and/or processes in which Hot Work is taking place along with the potential hazards, and c) takes responsibility for management of the Hot Work activity. The Permit Issuer must be a different individual than the individual performing the Hot Work activity and the Permit Acceptor. For the Port Arthur Facility, technicians who are trained in their respected areas will be Permit Issuers Portable Electronic Product 1 (PEP1) Battery powered or photovoltaic cell powered device worn in direct contact with the skin. Examples include electronic wristwatches worn in direct contact with the skin and hearing aids inserted in the ear. To be exempt from requirements of Hot Work, a PEP 1 device must meet all the following criteria: No visible sparks or excessive temperature during normal operation. No motors, unless the motor incorporates non-arcing technology. No visible damage. Powered by a maximum of two button cells (battery) No electrical connections accessible outside the product Red Area An area classification for defining Hot Work activities where flammable materials and flammable processes are present or those areas have contained flammable materials Re-issuing a Permit Means to void the previous permit for work and issue a new permit

7 Procedure No.: PA Page: 7 of DEFINITIONS cont d 2.26 Re-validate a Permit The process of reusing an existing Hot Work permit to authorize work by reviewing the work conditions (via the 4 Eyes Principle) specified on an existing permit, to ensure the scope, conditions and safety precautions listed on the existing permit have not changed. Required approval signatures must be obtained at the time of revalidation Tie-Point Tag An identification tag, pink and black, that is placed within one foot of where a tie-in is to take place. Specific piping Tie-In requirements are found in PA , and specific line cutting requirements are found in PA Vehicle Entry This refers to work activity involving the operation of any electrical, gas, diesel or internal combustion engine in a process area or the driving of any such motorized vehicle into a process area as defined by the owning department. Vehicle Entry is recognized as Low Energy Ignition Source Hot Work Yellow Area An area classification for defining Hot Work activities. These areas are free of flammable materials, but Combustible materials may be present or close enough to be ignited by sparks, convection or transferring of heat Work Crew The individuals assigned to a particular job. For this procedure, a Work Crew may be comprised of workers from more than one company provided each company involved and the Equipment Owner agree to the arrangement. A Safe Work Permit shall be issued for each Work Crew. Work Crew and Service Crew are the same for the purposes of this procedure Work Crew Representative Usually the foreman but could be any member of the Work Crew who is designated by the foreman to take responsibility for the Work Crew by receiving and signing the Safe Work Permit. This person is responsible to review the Safe Work Permit and any additional information they received with the Work Crew prior to the start of the permitted work.

8 Procedure No.: PA Page: 8 of SCOPE This procedure applies to production and utility areas on the Port Arthur site. Hot Work permits are not required: In the maintenance shop *Temporary or Permanent welding areas (where have been waived) as approved by the EHS manager Substations Designated contractor lay down areas as approved by the EHS Manager for each project. See Attachments B and C. TYPE OF IGNITION SOURCE LOCATION HIGH ENERGY LOW ENERGY Red Area In Process area battery limits, within 35 feet of process area, or within 35 feet of combustibles or flammables. Yellow Area Greater than 35 feet from process areas and/or any other combustibles or flammables. Blue Area Exempt Areas include fab areas within maintenance shops, & contractor lay down yards Safe Work Permit required Fire Guard Required. Initial & continuous LEL/0 2 monitoring Safe Work permit required Fire Guard required Initial & continuous LEL/O 2 monitoring required No Safe Work permit required No Fire Guard Required No LEL/O 2 required TABLE 3.1 Safe Work Permit required No Fire Guard Required Initial & continuous LEL/O 2 monitoring Safe Work permit required No Fire Guard Required Initial LEL/O 2 monitoring No Safe Work permit required No Fire Guard Required No LEL/O 2 required Deviations to the Scope of this procedure must have the approval of the Operations Manager (OM) of the area, the TES Manager Maintenance, and the EHS Manager or their designee. * Temporary Welding/Fabrication Areas (where have been waived) setup for turnarounds or plant construction activities must be initially reviewed and approved by EHS or the designated representative. These areas must be inspected at least every 30 days for the duration of use to ensure necessary fire prevention precautions are adequate and remain effective. A Orange Process Information Tag will be used to document inspection with the inspection date and inspectors name on the tag.

9 Procedure No.: PA Page: 9 of 29 3 PROCEDURE 4.1 Prohibitions to Hot Work Flame or Spark Producing Hot Work shall not be permitted in the following: In areas not authorized by a Permit Issuer In buildings or structures where the fire protection system is impaired. In the presence of explosive atmospheres. Where explosive atmospheres may develop inside uncleansed or improperly prepared tanks or equipment, which have previously contained Flammables or Combustible dust with air. In areas near the storage of large quantities of exposed Combustible or Flammable materials All Hot Work activities must be evaluated to determine whether the equipment upon which the Hot Work will be conducted can be practically & safely moved to a location outside the production area. If the equipment cannot be practically & safely moved, then Hot Work may be conducted in accordance with this procedure. 4.2 Atmospheric Testing Combustible Gas monitors shall be bump or span tested prior to each shift they are used, and calibrated in accordance with the manufacturer s recommendations Span testing prior to Hot Work shall allow for normal acceptable instrument deviations as determined by the manufacturer The area must be checked with a Combustible gas monitor. If monitoring indicates %LEL levels greater than 0%, Hot Work will not be performed until the source is found and eliminated and subsequent testing meets requirements. NOTE: The time between the initial monitoring and work beginning shall not exceed 30 minutes.

10 Procedure No.: PA Page: 10 of PROCEDURE cont d 4.3 Prior to Hot Work Activities Prior to issuing a permit to perform Hot Work, the following items must be completed: Prior to the performance of any Hot Work, the 4-eyes Principle shall be used to verify all applicable fire prevention precautions found in Attachment A have been implemented and documented on the permit prior to beginning of Hot Work. A Permit Acceptor must sign the permit to acknowledge and agree to the conditions of the permit The work area shall be checked with a Combustible Gas monitor to ensure that potential flammable atmospheres are not present Where practicable, Combustible materials shall be moved 35 feet from the Hot Work area or adequate measures taken to protect from ignition sources Hot Work that takes place on any process equipment must be isolated by means of a double block and bleed, disconnected with a sufficient air gap or blinded to maintain the integrity of the isolation. Blinds shall meet the requirements for material of construction, size and thickness Any heat treating activities will require the Attachment C be completed before start of work All lines/equipment in chemical service must be thoroughly cleaned and / or purged per Site operations procedures All lines or equipment must be isolated per Safety and Health Procedure PA Control of Hazardous Energy A Tie-Point Tag must be attached to or within one foot on the line or equipment where the tie-in will be performed. Specific requirements for Line cutting are found in PA Where Hot Work activities generate sparks and slag, a Fire Box shall be used. The Fire Box shall be large enough to allow for safe welding, burning and cutting activities and be designed to sufficiently contain sparks and slag. Fire Box coverings shall be composed of non-combustible "fireblankets" with junctures affixed to prevent escape of sparks and slag.

11 Procedure No.: PA Page: 11 of PROCEDURE cont d 4.3. Prior to Hot Work Activities cont d Ducts and conveyor systems that might carry sparks to distant Combustible materials shall be suitably protected or shut down Ditches, drains and vents must be covered or protected from sparks and slag. The fire retardant tarps must be kept wet, and care should be taken not to allow gas pockets to form below the tarps Hot Work areas shall be adequately barricaded to safeguard personnel against falling sparks and slag Any special precautions related to the Hot Work will be noted on the permit and will be communicated verbally to the Work Crew. 4.4 Vehicle Entry NOTE: If Hot Work Activities will effect or extend into another portion or section of the facility then a qualified technician from that area must be consulted Vehicle Entry is considered a Low Energy Ignition Source Hot Work. The entry requirements will be determined by the area classification for which the vehicle is permitted. (See Table 3.1) A. An initial atmospheric check is required where the vehicle will be operated. B. Blue Areas and plant roads outside of process areas containing flammable materials do not require a Vehicle Entry permit. C. Red Areas require an LEL Attendant (Walker) to escort the vehicle in/out while continuously monitoring atmospheric conditions. D. The vehicle escort shall maintain a distance of 30 feet ahead of the traveling vehicle. E. When required, the Safe Work permit shall be marked as Hot Work and Vehicle Entry.

12 Procedure No.: PA Page: 12 of PROCEDURE cont d 4.4. Vehicle Entry cont d Multiple vehicles used for the same job/task that are operating in close to each other may be covered under the same Vehicle Entry permit. Each vehicle shall be listed on the Safe Work Permit When welding, the welding machine is part of the Hot Work task and does not need a Vehicle Entry permit as long as the job is permitted as Hot Work Fire Guard Fire Guard Requirement A Fire Guard is required whenever High Energy Ignition Sources (i.e. welding, cutting, grinding or other activities which require the use of open flames or spark generating equipment that may result in a fire) in designated Red Areas, Yellow Areas where applicable or if any of the following conditions exist. A. Appreciable Combustible material is closer than 35 feet to the point of Hot Work. B. Appreciable Combustible materials are more than 35 feet away but may be easily ignited by sparks. C. Wall or floor opening within 35 foot radius expose Combustible material in adjacent areas including concealed spaces in walls or floors. D. Combustible materials are adjacent to the opposite side of metal partitions, walls, ceilings, or roofs and are likely to be ignited by conduction or radiation.

13 Procedure No.: PA Page: 13 of PROCEDURE cont d 4.5. Fire Guard cont d Fire Guard Requirement cont d Note1: Some jobs in elevated process areas may require additional Fire Guards. If this is determined, the Owning/Operating Supervisor approving the permit will note it on the permit. Note 2: Some jobs, depending upon the complexity and location, may require that a BASF Operations Technician be present. This will be determined and noted on the permit by the Owning/Operating Supervision authorizing the permit Fire Guard Responsibilities The primary function of the Fire Guard is the prevention of fire that may result from the Hot Work activities. When a Fire Guard is deemed necessary, they shall: A. Be trained and qualified as a Fire Guard. B. Be equipped with the proper fire fighting equipment (e.g., portable fire extinguisher designated for that purpose or fire water hose) and be trained on its use and limitations. C. Have a properly checked/calibrated Combustible gas monitor on the job site, and be trained in its use. D. Conduct air monitoring as stated on the permit upwind and near the point where Hot Work is being performed. E. Constantly observe for changing conditions, the presence of flammable or combustible materials, spark/slag containment, and the recognition of any abnormal events that may affect the ongoing Hot Work. F. Be in direct radio contact with the control room and/or permit issuer. G. Be equipped with a blast horn to provide warning to persons performing Hot Work if emergency conditions arise. H. Have the responsibility and authority to immediately shut down the Hot Work if hazardous conditions are observed.

14 Procedure No.: PA Page: 14 of PROCEDURE cont d 4.5. Fire Guard cont d Fire Guard Responsibilities cont d I. Must know how to shut off the gas supply or electric power to welding/burning/grinding machines. J. Must stop the job if conditions under which the permit was issued change, or sparks escape from the shielded areas. K. Be briefed on the potential hazards of the area and be knowledgeable of the means to obtain assistance and the activation of emergency alarms and procedures, and L. Be maintained for at least a half hour after completion of Hot Work operations to detect and extinguish possible smoldering fires Permit Requirements Permit Issuance (Section VII) A. The Owning/Operating Department shall issue the permit in the area where the work will be performed. B. The Operations Technician issuing the permit must conduct a field check of the area to ensure that all items in Section 4.3 have been satisfied Permit Authorization (Section IV) A. Permits designated as High Energy Ignition Sources-Hot Work (i.e. Welding, Cutting, Brazing) shall be approved by Owning/Operating Supervision or designee (top level outside technicians or higher) in section IV - Hot Work Requirements of the permit. B. Permits designated as Low Energy Ignition Sources-Hot Work (i.e. non-approved electrical equipment and vehicle entry) may be approved by the permit issuer.

15 Procedure No.: PA Page: 15 of PROCEDURE cont d 4.6. Permit Requirements cont d Permit Accessibility A. The Work Crew representative receiving the permit must also approve the permit and communicate the information on the permit to the work crew before work begins. B. The field copy of the permit shall be available at the job site for the duration of the job. C. The permit shall be posted at the job site Job Survey A. A qualified Operations Technician may be required by the Shift Supervisor to survey the job every two hours when a High Energy Hot Work job is taking place. B. The Technician shall initial and note the monitoring results on the job site copy of the permit to indicate the job has been surveyed Permit Content A. The permits must be printed and legible and include the date and times that the work may proceed. B. The Location: Include the area name/number of the large equipment in the area. C. A Job Description: Provide a brief description of the work to be conducted including tools that will be used. See the definition of Hot Work in Section 2. D. Equipment Preparation: Note that equipment has been properly prepared and include description of how equipment was isolated. A sketch or diagram may be used. Initial atmospheric tests must be documented. E. Precautions Taken Prior to Hot Work: For each item note that the particular precaution was taken, or that it is not applicable. See Section 4.3 for additional information regarding tasks that must be completed prior to Hot Work.

16 Procedure No.: PA Page: 16 of PROCEDURE cont d 4.6. Permit Requirements cont d Permit Content cont d F. Additional Precautions: Include any other additional or special precautions that must be included. G. Approvals: The approval process will vary based on the requirements in this procedure. The applicable approvals will be recorded in the appropriate location on the permit Permit Duration / Revalidation A. A Hot Work permit will be valid as long as the following do not change: The Permit Issuer The Permit Acceptor If either of the above change, the permit must be reissued or be revalidated. B. The maximum duration of a HW permit is one shift of work. After the maximum duration a Permit Issuer must issue a new permit or revalidate the original permit. C. If the scope (specific job) or type of Hot Work (High or Low Energy) changes, a new permit must be issued. D. To extend or Revalidate a Hot Work permit, you must follow the steps of procedure, PA , Safe Work permit, step through and including step with the exception that a hot work permit must at least be revalidated at the end of a shift. E. Permits issued for Hot Work must also be Re-validated if there is a break in work resulting in the absence of the Fire Guard (i.e. >30 minutes).

17 Procedure No.: PA Page: 17 of PROCEDURE cont d 4.6. Permit Requirements cont d Permit and Emergency Conditions A. If, during the course of Hot Work, an emergency alarm is sounded or an emergency condition occurs, equipment involved in the Hot Work (drills, welding equipment, etc.) shall be shut down, and permits will be automatically and immediately voided. B. After the emergency has been resolved, the area must be reevaluated and the permit must be re-issued or revalidated before Hot Work can be continued Closing Out the Hot Work Permit A. All permits are to be returned to the Permit Issuer following the permit duration or at completion of the work, whichever occurs first. B. The permit will be signed by a Work Crew Representative and the Owning/Operating department indicating that the work is complete Permit Review and Retention A. The BASF employee that closes out the permit will review completed permits for discrepancies and communicate the discrepancies with the permit issuer. B. Permits will be retained for 30 days Hot Work on Equipment Moved to Welding Areas Any pipe, vessel or equipment that has been removed from a process for Hot Work must be cleaned prior to Hot Work. Operations will be responsible for thoroughly cleaning the equipment prior to removal, verifying that the equipment has been cleaned, and tagging the equipment with an information tag that states: Equipment has been cleaned, The prior contents, The criteria used to determine cleanliness, The name of the person completing the tag information and the date. All information must be printed and legible.

18 Procedure No.: PA Page: 18 of PROCEDURE cont d 4.8. Other Special Precautions Ignitable Scale Deposits Special considerations should be given to conditions involving ignitable scale deposits, waxes, and other deposits that can accumulate on surfaces of vessels and piping and go undetected by air monitoring equipment until heated Pyrophoric Deposits When pyrophoric deposits, such as iron sulfide, are located in vessels, special precautions must be taken to prevent the spontaneous combustion of these materials when they are allowed to dry out and react with the oxygen of the air. The control of this reaction process can be attained by dissipating the heat involved until the atmosphere inside the vessel is below the LEL or by isolating the deposits from oxygen. The use of water spray in this operation will accomplish both objectives by reducing the heat of the reaction and by helping to isolate the pyrophoric deposits from the oxygen present during the vapor-freeing procedures Construction Site Procedures These shall be handled on a case-by-case basis with prior approvals from the affected Operations Manager, the EHS Manager and the TES Manager - Maintenance. In general: If the construction takes place more than 100 ft from equipment containing combustible or flammable liquids and/or gases, no hot work permit is required If the construction takes place < 100 ft from equipment containing combustible or flammable liquids and/or gases, one permit may be issued for all hot work. All other requirements of this procedure must be met.

19 Procedure No.: PA Page: 19 of PROCEDURE cont d Program Review The Port Arthur Site shall review the effectiveness of Hot Work practices at least annually to ensure that the Hot Work management system is properly implemented and the elements adequately control Hot Work activities. As a minimum the following elements shall be included in the review: Review the Site procedure and permit to ensure all currently required elements are included. A review of a representative sample of closed permits since the last program review to determine permitting effectiveness A review of all incidents and other nonconformance reports involving Hot Work activities that have occurred since the last Hot Work management system review. Inspection of at least one Hot Work job in progress to verify site practices comply with the site procedure. Interviews with a representative number of Permit Issuers, persons performing Hot Work, and other affected employees, including Contractor and Contracted Employees where applicable, to verify they understand their role/responsibility. A review of applicable equipment and instrument maintenance and calibration records. Annual reviews and forms are found in the Big 5 folder Training Personnel Involved in Hot Work Activities Permit Issuers, Fire Guard personnel, and personnel performing Hot Work shall receive training on how to recognize the applicability of Hot Work situations, the requirements for issuing a permit, and the necessary means to safeguard against the hazards posed during these activities. Training shall be delivered in accordance with the EHS curriculum assignment process. Retraining of an individual is required whenever: Deviations or inadequacies in an individual s performance of an applicable procedure indicate that lack of knowledge is a cause. An applicable procedure has been changed Personnel Not Directly Involved in Hot Work Activities Employees who do not directly perform hot work will receive instruction concerning their roles in the procedure and how hot work may affect their specific work duties.

20 Procedure No.: PA Page: 20 of Procedure cont d 4.11 training cont d 5. RESPONSIBILITIES Frequency Training shall be conducted during employee orientation and at least every three years after that Owning/Operating Supervision Responsible for developing and posting an area classification (Red, Yellow, and Blue) map in the control room or designated posting areas Site Leadership Team Has primary responsibility for implementation of this procedure Environmental, Health, and Safety Manager Has primary responsibility for the initiation, re-issuance, administration, and/or interpretation of this procedure. Conduct and document an annual review of the Hot Work written program Site Employees and Contractors Have primary responsibility for adherence to procedure including identifying deficiencies in the procedure and identifying, reporting and correcting activities not in compliance with the procedure.

21 Procedure No.: PA Page: 21 of RELATED DOCUMENTS 29 CFR (k) - PSM (Hot Work) 29 CFR Welding, Cutting and Brazing General Requirements Fire Prevention and Protection N-ID-OSA 016: Hot Work (Corporate Procedure) PA Safe Work Permits PA Hot Tap PA Control of Hazardous Energy PA Piping Tie In PA Line Breaking/Line Cutting Safe Work Permit Attachment A Fire Prevention Precautions Attachment B - BTP Hot Work Map Attachment C H/T Resistance Pre-startup Checklist N-R-OSA-001-EN-M Occupational Safety and Industrial Hygiene Program Review Checklist (Non-mandatory) 40 CFR Risk Management Plan Hot Work Permit (Program Level 3) American Petroleum Institute (API) Recommended Practice 2009, Safe Welding, Cutting, and Hot Work Practices in the Petroleum and Petrochemical Industries API Recommended Practice 2201, Safe Hot Tapping Practices in the Petroleum and Petrochemical Industries ANSI Z Safety in Welding and Cutting and Allied Processes, (American Welding Society) G-S-CL 100 M - Minimum Safety and Health Requirements Civil and Structure Work Instrument Society of America (ISA) RP Recommended Practice for Portable Electronic Products Suitable for Use in Class I and II, Division 2, Class I Zone 2, and Class III, Division 1 and 2 Hazardous (Classified) Locations National Fire Protection Association (NFPA) Standard 51B, Fire Prevention in the Use of Cutting and Welding Processes National Fire Protection Association (NFPA) Standard 70 National Electrical Code National Fire Protection Association (NFPA) Standard 497, Recommended Practice for the Classification of Flammable Liquids, Gases, or Vapors and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas

22 Procedure No.: PA Page: 22 of RELATED DOCUMENTS cont d National Fire Protection Association (NFPA) Standard 499, Recommended Practice for the Classification of Combustible Dusts and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas National Fire Protection Association (NFPA) Standard 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids

23 Procedure No.: PA Page: 23 of PRECAUTIONS FOR ALL HOT WORK Attachment A Fire Prevention Precautions 1.1 The equipment used to perform Hot Work shall be in satisfactory operating condition and in good repair. 1.2 All personnel performing Hot Work, including Contracted Employees and Contractor(s), shall be informed of the potential hazardous conditions in the work area and area emergency response procedures. 1.3 All work groups involved in or potentially affected by the Hot Work activities have received appropriate communication to ensure coordination of activities and prevent adverse impact. 1.4 When Hot Work is performed in Electrically Classified Areas, verification of the absence of an Explosive Atmosphere in the work area must be performed For Combustible Dusts, a visual inspection of the area where Hot Work will be performed must identify any accumulations and airborne dispersions. A. Accumulations of dust on any surfaces within the Applicable Distance must be removed prior to beginning Hot Work. Surfaces should be cleaned in a way that prevents dust cloud formation. The source of the dust should be eliminated for the duration of the Hot Work. B. Where airborne dispersions exist, Hot Work shall not be conducted until the source is eliminated, the airborne dispersion settles, and the accumulated dust is removed from the area For Flammable gases or Flammable vapors, a properly calibrated and functional combustible gas detector must be used. If a measurable level is detected using a combustible gas indicator operating in the percent range of sensitivity, Hot Work is not allowed or must cease until the source is found, eliminated and subsequent testing meets requirements. A. Combustible Gas Instrument Requirements Instruments are to be maintained according to manufacturer s specifications. Instrument calibration shall be documented indicating when the instrument was calibrated and who performed the calibration. Instruments are to be functionally tested by exposing the sensor to a known gas concentration before each use or daily, whichever is less frequent.

24 Procedure No.: PA Page: 24 of 29 The minimum oxygen concentration specified in the manufacturer s instructions must be present when conducting combustible gas monitoring. B. Combustible Gas Testing Locations In addition to tests of the general area, tests must be made at the specific area where Hot Work will be conducted or where sparks or other ignition sources may occur. Low points (such as sumps, drains, trenches) within the Applicable Distance of the Hot Work location must be included in the testing locations. 2. PRECAUTIONS FOR FLAME- OR SPARK-PRODUCING HOT WORK 2.1. Personnel performing welding or cutting shall be trained in the safe operation of their equipment If the object on which Flame- or Spark-Producing Hot Work is to be performed cannot be moved at least the Applicable Distance from Combustibles and Flammables, all movable fire hazards within the Applicable Distance shall be moved If all fire hazards cannot be removed, then fire-retardant covers or metal shields or fire-retardant guards or curtains shall be used to confine the heat, sparks, and slag, and to protect the immovable fire hazards. A. The edges of the covers shall be appropriately sealed to prevent sparks from getting to the fire hazards underneath. B. If several covers are needed, the edges must sufficiently overlap to prevent sparks from getting to the fire hazards underneath If neither can be accomplished, then Flame- or Spark-Producing Hot Work is prohibited Suitable fire extinguishing equipment shall be maintained at the area in a state of readiness for instant use Fire Guard At least one Fire Guard is required whenever Flame or Spark-Producing Hot Work is performed in locations where other than an incipient fire might develop or if any of the following conditions exist: A. Appreciable Combustibles or Flammables, in building construction or contents, are closer than the Applicable Distance to the point of Flameor Spark-Producing Hot Work, or B. Appreciable Combustibles or Flammables are more than the Applicable Distance away from the point of Flame- or Spark-Producing Hot Work, but may be easily ignited by sparks, or

25 Procedure No.: PA Page: 25 of 29 C. Wall or floor openings within the Applicable Distance expose Combustibles or Flammables in adjacent areas including concealed spaces in walls or floors, or D. Combustibles or Flammables are adjacent to the opposite side of metal partitions, walls, ceilings, or roofs and are likely to be ignited by conduction or radiation More than one Fire Guard may be required depending on the nature of the work. The Permit Issuer will make this determination when issuing the permit for the Hot Work The primary function of the Fire Guard is the prevention of fire that may result from Flame- or Spark-Producing Hot Work. When a Fire Guard is deemed necessary, a Fire Guard shall: A. Be present in the area where Flame- or Spark-Producing Hot Work is occurring for the entire duration of the work and for at least a half hour after completion of the Hot Work activities to detect and extinguish possible smoldering fires. B. Be equipped with the proper fire fighting equipment (e.g., portable fire extinguisher or water hose) and be trained on its use and limitations. C. Constantly observe for changing conditions, the presence of Combustibles or Flammables, spark/slag containment, and the recognition of any abnormal events which may affect the ongoing Flame- or Spark-Producing Hot Work. D. Have the responsibility and authority to immediately shut down the Hot Work if hazardous conditions are observed. E. Be briefed on the potential hazards of the area and be knowledgeable of the means to obtain assistance and the activation of emergency alarms and procedures Where Combustibles are on the floor, the floor shall be swept clean for the Applicable Distance and the following criteria shall also be met: Combustible floors shall be kept wet, covered with damp sand, or protected by noncombustible or fire-retardant shields Where floors have been wet down, personnel operating arc-welding equipment or cutting equipment shall be protected from possible shock Openings or cracks in walls or floors within the Applicable Distance of the Flame- or Spark-Producing Hot Work location shall be tightly covered with fire-retardant or noncombustible material to prevent the passage of sparks to adjacent areas.

26 Procedure No.: PA Page: 26 of Ducts and conveyor systems, that might carry sparks to distant Combustibles or Flammables, shall be shielded, or shut down, or both If Flame- or Spark-Producing Hot Work is done near walls, partitions, ceilings, or roofs of Combustible construction, fire-retardant shields or guards shall be provided to prevent ignition If Flame- or Spark-Producing Hot Work is done on one side of a metal wall, partition, ceiling, or roof, one of the following criteria shall be met: Precautions shall be taken to prevent ignition of Combustibles or Flammables on the other side by relocating the materials If it is impractical to relocate materials, a Fire Guard shall be provided on the side opposite from where the work is being performed Flame- or Spark-Producing Hot Work shall not be attempted on a metal partition, wall, ceiling or roof having a combustible covering or insulation, or on walls or partitions of combustible sandwich-type construction Flame- or Spark-Producing Hot Work that is performed on pipes or other metal that is in contact with Combustible walls, partitions, ceilings, roofs, or other Combustibles, shall not be undertaken if the work is close enough to cause ignition by conduction. 3. FLAME- OR SPARK-PRODUCING HOT WORK ON CONTAINERS 3.1 No Flame- or Spark-Producing Hot Work shall be performed in or on used drums, barrels, tanks, or other containers until they have been cleaned so thoroughly as to make absolutely certain there are no Flammables present or any substances such as greases, tars, acids, or other materials which when subjected to heat, might produce Flammable or toxic vapors. 3.2 Before beginning Flame- or Spark-Producing Hot Work on a used container, all pipe lines or connections to the used container shall be isolated. Isolation could consist of the following methods: A blank or stopper plate inserted in the line. Blanks must be of the construction and thickness to sustain the pressure for which the line is rated Double block or bleed valve arrangement where the two block valves are closed and the bleed is opened and secured by locks/tags Lines are disconnected and misaligned.

27 Procedure No.: PA Page: 27 of All hollow spaces, cavities, or containers shall be vented to protect against overpressure due to thermal expansion before preheating, cutting or welding. 3.4 Process vessels that contain packing, catalyst or trays, etc. may need special precautions (e.g. remove the materials, inert the vessel or submerge the material in water) to ensure materials inside the vessel do not ignite. 3.5 When High Energy or spark producing Hot Work is performed on a Container, continuous LEL monitoring shall be conducted outside and inside the Container for the duration of the Hot Work activity. 3.6 When the Container previously contained substances which when subjected to heat might produce toxic vapors, the Permit Issuer must determine appropriate safeguards. For example, depending on the nature of the work, specific materials involved, or ventilation equipment, chemical specific monitoring or additional personal protection equipment may be needed during the course of the work to ensure protection of personnel. 3.7 All hollow spaces, cavities or containers shall be vented to protect against overpressure due to thermal expansion before preheating, cutting or welding. Consider potential hazards in the vent path. 4 FLAME- OR SPARK PRODUCING HOT WORK INSIDE CONFINED SPACES (See also BC , Confined Space Entry) 4.1 When arc welding is suspended for any substantial period of time, such as during lunch or overnight, all electrodes shall be removed from the holders and the holders carefully located so that accidental contact cannot occur and the machine is disconnected from the power source. 4.2 To eliminate the possibility of gas escaping through leaks or improperly closed valves, when gas welding or cutting, the torch valves shall be closed and the gas supply to the torch positively shut off at some point outside the confined area whenever the torch is not to be used for a substantial period of time, such as during lunch hour or overnight. Where practicable, the torch and hose shall also be removed from the confined space.

28 BTP Hot Work Map Attachment B

29 BTP Hot Work Map Attachment C