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Inserting a Blind Flange in an Additive Line in an Operating Plant

Inserting a Blind Flange in an Additive Line in an Operating Plant. 2 Failed Roto Flate Valves need to be replaced. Blind flange to be installed in order to replace the 2 valves. 30 ft - 4” line to CRR 350 C, Nitrogen rich atmosphere with potential CO.

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Inserting a Blind Flange in an Additive Line in an Operating Plant

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  1. Inserting a Blind Flange in an Additive Line in an Operating Plant 2 Failed RotoFlate Valves need to be replaced Blind flange to be installed in order to replace the 2 valves 30 ft - 4” line to CRR 350 C, Nitrogen rich atmosphere with potential CO

  2. CRR – Carbon Reduction Reformer, 360 Celcius, - 20” WC Vacuum The 4” Additive Line is 30 ft long from bottom of the airlock to the entry into the CRR

  3. Background & Regulatory • Plant in start-up phase, unknown cool down time (96 hours approximate) and 80 – 100 hours to heat back up. Numerous equipment challenges encountered during previous heat up evolutions. • OSHA regulation 29 CFR 1910.147 requires the hazardous energy control process (lockout tagout) to be entered for servicing and maintenance if personnel could be exposed to unexpected hazards. • OSHA case law (Electronic Citation:1996 FED App. 0219P, 6th Cir) concluded that the term "unexpected" renders the lockout standard inapplicable to machines that give servicing employees sufficient advance notice or warning of machine start up to allow them to vacate the zone of danger and avoid employee injury. • In OSHA Enforcement Policy and Inspection Procedures, CPL 02-00-147, there are eleven factors that should be used to assess whether particular warning devices(s) are adequate and reliable to allow all employees to escape all types of hazardous energy in all circumstances that may occur.

  4. Hazard Mitigation & Control • Contractor, CWI, determined that 29 CFR 1910.147 was not applicable • Using the Enforcement Policy and Inspection Procedures, the contractor documented the 11 factors assessing the adequacy and reliability of the warning devices to allow all employees to escape all types of hazardous energy. • CWI thoroughly evaluated and documented the eleven factors and captured the controls in the maintenance working document (Work Order 641627). • There was no imminent hazard to the workers and therefore a Stop Work was not initiated. • In light of the court ruling in favor of GMC Delco, a contracting officer letter to the contractor directing them to shut-down and cool-down the plant and follow the 29 CFR 1910.147 regulation was not warranted.

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