Aboveground Storage Tanks – Marine Chemists’ Role Safeguarding Entry and Work

1. Aboveground Storage Tanks – Marine Chemists’ Role Safeguarding Entry and Work Guy Colonna, P.E. 55th Annual MCA Seminar Bar Harbor, ME July 16, 2013

2. Cadillac Mountain, Acadia National Park

3. Agenda • Background • Confined space statistics • Recent incidents – CSB issues • OSHA 29 CFR 1910.146, Permit-Required Confined Spaces - overview • Aboveground Storage Tanks • API resources • TES Certification program • Practical issues • Marine Chemist role • Closing

4. PRE-INVENTORY 1. An OSHA confined space has the following: • large enough to permit entry • intended for continuous occupancy • normal atmospheric ventilation • limited or restricted entry or exit

5. PRE-INVENTORY 2. The following are tank classifications found in OSHA 29 CFR 1910.146, Permit Required Confined Spaces. • Non-confined space • Non-permit required confined space • Permit required confined space

6. PRE-INVENTORY 3. API 2015 and 2016 use which of the following safety designations? • Enter with restrictions • Enter without restrictions • Enter with special precautions • Enter when inerted • All of the above

7. PRE-INVENTORY 4. What is the maximum safe level of oxygen according to 29 CFR 1910.146? • 10% • 19.5% • 20.9% • 23.5% • None of the above

8. PRE-INVENTORY 5. According to the Permit-Required Confined Space standard, no permit is required when the space is unsafe. True False

9. Hazard Awareness

11. Lessons LearnedCSB Report – June 2007 • Lack of hot work safety • Failure to recognize the hazards - use of welding tools in a flammable vapor environment • Failure to isolate fuel and ignition sources • Failure to manage hazards with well-established, safe work practices (API, NFPA, OSHA) • Makeshift work platform • Safe hot work guidelines • NO permit issued

12. CSB Video – Death in the Oilfield

13. Hawaii • October 17, 2008 • Welding part of a catwalk connected to the top of an oil storage tank • Tank was approximately 15 feet tall and reportedly contained waste oil • Vapors from the tank were ignited by the welding activities and caused the explosion that propelled tank 30 feet • One fatality, 3 injured, 2 seriously

14. Ohio • October 20, 2008 • Welding catwalk on one of four large crude-oil storage tanks at drill rig site when a tank exploded • Two fatalities • CSB sent investigative team • Looking for similarities with Hawaii and Mississippi

16. Seven Lessons from CSB Report

17. Seven Lessons from CSB Report

18. RECOGNITION“Hazard Identification & Risk Assessment” • Identification of Spaces According to Definition • Identification of Hazards • Atmospheric (oxygen, flammability, toxicity) • Engulfment • Entrapment • Other physical or mechanical (energy sources, heat stress, noise)

19. EVALUATION“Confirm or Deny Presence of Hazards and Determine Severity” • Qualitative Assessment • Use MSDS, other reference sources, and senses (subjective) • Quantitative Assessment • Measurement of atmospheric components; compare test results to established standards to determine whether a safe condition exists (objective)

20. Engineering Ventilation Isolation Substitution Administrative Safe Work Practices Permits Training Personal Protective Protective Clothing Respiratory Protection Follow-up atmospheric monitoring Emergency and rescue CONTROL“Action taken to eliminate or minimize hazards”

21. OSHA Points to MC for CS Evaluation – 1910.146, Appendix B • Atmospheric testing is required for two distinct purposes: • evaluation of the hazards of the permit space and verification that acceptable entry conditions for entry into that space exist. • Evaluation testing. The atmosphere of a confined space should be analyzed using equipment of sufficient sensitivity and specificity to identify and evaluate any hazardous atmospheres that may exist or arise, so that appropriate permit entry procedures can be developed and acceptable entry conditions stipulated for that space. Evaluation and interpretation of these data, and development of the entry procedure, should be done by, or reviewed by, a technically qualified professional (e.g., OSHA consultation service, or certified industrial hygienist, registered safety engineer, certified safety professional, certified marine chemist, etc.) based on evaluation of all serious hazards.

22. OSHA DEFINITION29 CFR 1910.146 A confined space must have these characteristics: • Large enough and so configured to permit entry and work • Not designed for continuous human occupancy • Limited or restricted means of entry and exit

23. PERMIT-REQUIRED CONFINED SPACE (PRCS) Is a confined space that contains or may contain: • Hazardous atmosphere (oxygen content, flammable, or toxic) • Engulfment hazard • Entrapment hazard • Other recognized serious safety hazard

24. Aboveground and underground storage tanks Process vessels Grain silos Bins Hoppers Sewers Utility vaults Tanks on marine vessels CONFINED SPACE EXAMPLES

25. Confined Space Example – Diked Area

26. PRCS PROGRAM REQUIREMENTS • Written program • Identify and classify spaces • Establish hazard control measures • Prevent unauthorized entry • Establish acceptable conditions • Isolation • Ventilation • Coordinate entry by multiple workers • Periodic reevaluation for change of conditions

27. PRCS PROGRAM REQUIREMENTS • Develop permit system • Preparation • Issuance • Implementation • Cancellation • Returning space to service

28. PRCS PROGRAM REQUIREMENTS • Provide specialized equipment • Atmospheric monitoring • Ventilation • PPE • Lighting • Communication • Emergency

29. PRCS PROGRAM REQUIREMENTS • Designate key personnel • Entrants • Attendants • Entry supervisor • Qualified atmospheric tester • Emergency response

30. PRCS PROGRAM REQUIREMENTS • Perform testing and monitoring • Prior to entry and periodically during entry and work • Establish rescue and emergency procedures • Procedures for contractors - multi-employer work sites • Provide information and training • Conduct program review

31. Confined Space Classifications • Non-Permit Required Confined Space (API & OSHA) • Permit Required Confined Space (API & OSHA) • Non-Confined Space (API)

32. Non-Permit Required Confined Space • Remember what a confined space is! • Large enough and so configured to permit entry and work • Limited or restricted entry or exit • Not designed for continuous occupancy • Non-permit means the confined space has no identified hazards

33. Permit-Required Confined Space • All characteristics of confined space as defined • Possesses one or more identified hazards • Hazardous Atmosphere • Engulfment hazard • Entrapment hazard • Other serious recognized hazard

34. Hazardous Atmosphere • Expose employees to – • Risk of death • Incapacitation • Impairment of ability to self-rescue • Injury • Acute illness • As a result of exposure to –

35. Hazardous Atmosphere Criteria • Flammable gas, vapor, mist in excess of 10% of lower flammable limit (LFL) • Airborne combustible dust at its LFL ** • Oxygen concentration less than 19.5% and greater than 23.5% by volume • Toxic exposures in excess of PEL as found in Subpart G or Subpart Z • Any IDLH concentrations • Contains or potential, serious harm

36. DESIGNATED PERSONNEL - Entrant • Trained to recognize hazards • Trained to use PPE as required • Communicate with attendant as necessary • Recognize symptoms of exposure • Understand principles of self-rescue

37. DESIGNATED PERSONNEL - Attendant • Remain outside space at all times • Trained to recognize hazards and exposure symptoms • Communicate with entrants • Communicate alarm, evacuate if necessary • May monitor more than one space at a time • Prevent unauthorized entrants • Alert to changing conditions

38. DESIGNATED PERSONNEL – Entry Supervisor • Trained to recognize hazards • Authorizes entry based upon hazard assessment, identify acceptable conditions • Verify emergency plans and rescue personnel availability • Revoke permit if conditions change adversely • Terminate permit at job completion

39. DESIGNATED PERSONNEL - Qualified Atmospheric Tester • Responsible for conducting atmospheric monitoring • Trained to properly select, calibrate, use and maintain all required instruments • May be any of the key personnel - entrant, attendant, supervisor

40. DESIGNATED PERSONNEL - Rescue and Emergency Services • Either on-site or off-site permitted • Trained at least as entrants and in use of rescue equipment • Trained in basic first-aid/CPR and at least one member certified in both • Conduct annual drill • Coordination between employer and off-site provider

41. ANSI/API 2015 – Summary • Scope and Applicability • Applies to atmospheric and low-pressure aboveground petroleum storage tanks • Includes decommissioning, hazard assessment, permit entry and work system, emergency planning, and recommissioning • Does not apply to pressure vessels, process vessels, underground storage tanks • Industry specific application of OSHA requirements in 29 CFR 1910.146

42. Testing the Tank Atmosphere • Determine what atmospheric hazards to test for based upon MSDS or other source • Determine safe exposure limits • Develop written calibration requirements • Maintain verification of calibration for 1 year • Calibrate according to manufacturer

43. Atmospheric Testing • Test in specific order • Test from outside tank initially • Test atmosphere outside the tank as well • Especially during degassing • Shut down ventilation prior to testing • Rule of thumb 10 – 15 minutes • Conduct periodic or continuous monitoring • Specialized testing – lead-in-air

44. Oxygen content Fire and explosions Toxic substances Hydrogen sulfide Organic Lead Inorganic Lead Aromatics NORM Other Physical and other hazards Tank function or design Tank condition Tank location Physiological hazards (heat stress or cold stress) Storage Tank Hazards

45. API RP 2016 – Summary • Tank Entry Supervisors will have the understanding, knowledge and skills to implement the specific tank cleaning procedures and practices presented in API 2016 in order to meet the requirements of ANSI/API 2015

46. Tank Entry Designations • Enter Without Restrictions • Enter With Restrictions • Enter With Special Precautions • Entry When Inerted (See API 2217A)

47. Enter Without Restrictions • Oxygen content – 19.5% to 23.5% by volume • Hydrocarbon vapor-in-air level inside the tank is 10% LEL or less • Atmospheric toxic levels inside the tank are within established exposure limits (PEL or TLV)

48. Enter With Restrictions • The actual or potential atmospheric concentration levels require appropriate protective equipment or adjusted time • Review NFPA 326, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair • Similar designation

49. Enter With Special Precautions • This designation applies when: • Oxygen content inside the tank is < 19.5% by volume • Hydrocarbon vapor-in-air level inside the tank is > 10% LEL • Atmospheric toxic levels inside the tank exceed the established exposure limits (PEL or TLV)

50. Entry When Inerted • The oxygen content within the tank is less than 8% by volume (or less than 50% of the lowest oxygen concentration level required to support combustion – Limiting Oxidant Concentration (LOC)) • NFPA 69, Standard on Explosion Prevention Systems contains values for LOC • Becomes an Enter With Special Precautions