Jody Jackson, CSP Director HSE Montrose Environmental Irvine, Ca

1. Hot Work and Fire Prevention Jody Jackson, CSP Director HSE Montrose Environmental Irvine, Ca

2. Fire Prevention - Hot Work

3. Agenda • Regulatory background • Importance of fire prevention during hot work operations • Your Experiences • OSHA’s welding, cutting, and brazing standard

4. Regulatory Background • OSHA’s Welding, Cutting, & Brazing 1910.252 • NFPA 51B-1962 (Welding/Cutting)(INC-BR) • OSHA PSM 29 CFR 1910.119 • Various Other OSHA references within standards

5. Importance of Fire Prevention During Hot Work Operations Hot Work is any work involving burning, welding, or similar operations that are capable of initiating fires or explosions. Such as: • Welding Processes • Heat Treating • Grinding • Thawing Pipe • Powder-Driven Fasteners • Hot Riveting • Similar Applications Producing a Spark, Flame or Heat

6. Importance of Fire Prevention During Hot Work Operations March 23, 2005: An explosion occurred at a BP Refinery in Texas City, Texas. Over 100 were injured, and 15 were confirmed dead, including employees of the Jacobs Corporation as well as BP. BP has since accepted that its employees contributed to the accident. Several level indicators failed, leading to overfilling of a knock out drum, and light hydrocarbons concentrated at ground level throughout the area. A nearby running diesel truck set off the explosion. What does this have to do with biogas? Everything!

7. Importance of Fire Prevention During Hot Work Operations • Philippines, gas incident 4 deaths . • UK, gas incident 1 death & 11 Serious Injuries (including serious burns from explosions and near fatal gas-related injuries) . • 13 other noted Injuries (including 11 firemen – mainly gas related)

8. Your HW Experiences? Discussion

9. DEFINITIONS FIRE WATCH An individual who is trained in the proper use of fire extinguishers and is familiar with the fire alarm system and/or emergency notification procedures. The fire watch must be present during work, breaks, and at least 30 minutes after the work has ended to guard against fire. FUEL GAS Anything flammable or combustible.

10. Fire Watching

11. DEFINITIONS HOT WORK Work performed with heat-producing equipment, such as heat guns, soldering tools, welding tools, electric arc cutting equipment, oxygen-fuel gas cylinders, etc. HOT WORK PERMIT A form that is often completed to document responsibilities and precautions during hot work, where combustible materials are/may be present.

12. Example – Hot Work Permit

13. OSHA’s and NFPA’s Welding, Cutting and Brazing Standards • Required basic precautions including: • responsibility for hot work; • protection of personnel; • removing, guarding, or shielding combustibles; • trained and equipped fire watch/es; • designated welding areas; • authorized written hot work permits and; • training and communication.

14. General Procedures for Hot Work • PLAN YOUR WORK!!!!! • Assign a fire watch. • Complete a hot work permit. • Make sure at least one portable fire extinguisher with an A-B-C rating is in place no more than 25 feet from the work area. Minimum of 20 lbs. • Inspect the area and all tools and equipment, including personal protective equipment (PPE). • Combustible materials must be located a minimum distance of 35 feet beneath or horizontally away from the cutting/welding area. When work or combustible materials cannot be relocated, the material must be protected from possible sparks by fire-resistant shields or noncombustible covers.

15. General Procedures for Hot Work LEL (Lower Explosive Limit) must be zero (0). Hot Work cannot be performed on containers, vessels, production equipment, tanks of anything that contain or that previously contained flammable fluids, gases, or solids unless these areas/equipment have been thoroughly cleaned, inverted, purged and tested for Zero (0) LEL. (Hot-Tap Exception). Goggles, or other suitable eye protection, are required at all times while performing hot work. Other PPE, such as gloves, face shields, helmets, foot protection, and clothing will be worn as required, depending on the task. 15 12/20/2019

16. General Procedures for Hot Work When oxy-acetylene welding and cutting is to be performed, all equipment, connections, cylinders, and hoses shall be inspected prior to use. One must make sure hands/gloves are free of oil or grease (hydrocarbons) prior to handling oxygen cylinders and apparatus. All compressed gas cylinders must legibly identify the gas content. Cylinders that have missing or illegible labels must be returned to the supplier. Cylinders must have the valve protection cap on when not in use and must be transported, used, and stored in an upright position. When not in use, oxygen cylinders must be stored a minimum of 20 feet away from acetylene, propane, natural gas, or any other fuel gas.  All cylinders must be stored in areas where they will be protected from tampering or physical damage, heat in excess of 130 degrees Fahrenheit and must be chained, strapped or otherwise secured to prevent them from being tipped over. 16

17. Procedures For Performing Hot Work The fire watch must observe the area for a minimum of 30 minutes after work is completed to ensure that there is no hazard of fire. Upon the completion of the work and post-job fire watch, note the time and sign the last section of the Hot Work Permit to close out the permit. While the Hot Work is being performed, the Hot Work Permit will be kept at the work. Atmospheric testing must be performed throughout the work cycle. After completion of the Hot Work and the Post-Work Fire Watch, the “work completion area” of the Hot Work Permit will be competed and reviewed by the supervisor or PIC. The completed Hot Work Permit will be maintained for at least one year and reviewed. 17 12/20/2019

18. Common Mistakes • Don’t prepare equipment for hot work properly. • Purging • Inadequate gas testing (too little) • Improper gas testing (wrong place) • Inadequate isolation • Not knowing how to use gas instruments (how much 02 is required?) • Failure to identify low-points and high-points

19. Common Mistakes • Don’t prepare equipment for hot work properly. • Don’t anticipate the impact of hot work on space or workers • Don’t consider alloy being welding on or with • Don’t look at the bigger picture • Don’t cover drains • Don’t gas test adjacent areas • Fail to train fire watch properly

20. Flammable Measurement – Simplify It • Don’t get hung up in the science behind what the flammable range is in a digester. Use the KISS method and choose a proper instrument that reads % LEL, NOT % Methane when measuring LEL. • Ensure when measuring LEL that you have sufficient O2 for your instrument.

21. Responsibilities • Permit Authorizing Individual Responsibilities cont… • determining that fire protection and extinguishing equipment is properly located at the site; • making sure a fire watch is available at the site and; • where a fire watch is not required, making a final check 30 min. after the completion of hot work to detect and extinguish possible smoldering fires.

22. Responsibilities • Fire Watch Responsibilities • being aware of the inherent hazards of the work site and of the hot work; • ensure that safe conditions are maintained; • have the authority to stop the hot work if unsafe conditions develop;

23. Responsibilities • Fire Watch Responsibilities cont… • having fire extinguishing equipment, as well as attending required training; • sounding and being familiar with alarm procedures in the facilities in the case of an uncontrolled fire and; • watching for fires in all exposed areas, during hot work operations and for at least 30 min. after completion, and trying to extinguish them only when they are within the scope of their training and equipment.

24. Responsibilities • Supervisor Responsibilities • Plan the work, communicate the plan; • ensuring all employees who perform hot work are trained on the Hot Work Program and it’s requirements; • safe handling and use of equipment, as well as determining any combustible or hazardous areas that are present in the work area;

25. Responsibilities • Supervisor Responsibilities cont… • protecting combustibles from ignition by having the work moved to a location free from combustibles, moving combustibles to a safe distance, or properly shielding against ignition; • seeing that Hot Work is not scheduled to be performed during operations that might expose combustibles to ignition;

26. Responsibilities • Supervisor Responsibilities cont… • obtaining a hot work permit from the PAI and determining that the hot work operator secures his approval that conditions are safe before performing any hot work; • ensuring that fire protection and extinguishing equipment are properly located at the site and employees are trained in its use; • making a fire watch available if needed;

27. Responsibilities • Employee (Persons Performing Hot Work) Responsibilities • completely adhering to the requirements of this program and attending required training; • understanding the emergency procedures in the event of a fire and shall have an awareness of the inherent risks involved;

28. Responsibilities • Employee (Employee Performing Hot Work) Responsibilities cont… • having the PAI's and supervisor's approval before starting the hot work operations; • stopping hot work operations and notifying management if an unsafe condition is identified; • Returning completed hot work permits to issuer.

29. Welding Areas • Designated areas • a designated fire resistant area or areas made of noncombustible construction. • Permit required areas • an area that requires a written hot work permit and shall be made safe by removing or protecting combustibles from ignition sources.

30. Welding Areas • Non-permissible welding areas • areas not authorized by management; • sprinklered buildings while such protection is impaired; • in the presence of an explosive atmosphere, including improperly prepared drums that once contained flammable materials and; • areas near storage of large quantities of exposed, readily ignitable materials.

31. Other Precautions • Confined Spaces • To prevent accidental contact, when arc welding is to be 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 be disconnected from the power source.

32. Other Precautions • Confined Spaces cont… • In order 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 space area whenever the torch is not to be used for a substantial period of time, such as during lunch hour or overnight. Where practical, the torch and hose shall also be removed from the confined space.

33. Other Precautions • Confined Spaces cont… • When welding or cutting is being performed in any confined space, the gas cylinders and welding machines shall be left on the outside. Before operations are started, heavy portable equipment mounted on wheels shall be securely blocked to prevent accidental movement.

34. Questions?