Simplified and Harmonized Standards MOC for ODMS 06.05 L3S Line & Equipment Opening

1. Simplified and Harmonized StandardsMOC for ODMS 06.05 L3SLine & Equipment Opening Revisions to the Line & Equipment Opening Standard Details on the inclusion of the variance 2010-00188 (Hot L&EO)

2. Background • The Line and Equipment Opening standard has been reviewed and requirements have been modified. • Recent unplanned events with an LEO as a component also have led to further clarifications in the standard

3. Implementation November 30, 2012 is the deadline for the implementation of the L&EO simplified/harmonized standard for Freeport. 3

4. Summary of Changes to the L&EO Standard New Requirement in Global L&EO Standard Modified Requirement in Global L&EO Standard Deleted Requirements (Freeport Additions)

5. Summary of Changes for hDow sites • Revised L&EO definition and applicability • Changes in requirements for identification of line breaks • Changes in procedure requirements • Expanded applicability of the requirement to complete a more thorough hazard analysis for higher hazard LEOs • Hot Line and Equipment Opening requirements from global variance 2010-00188 are included in the Global Line and Equipment Opening Standard • Self Assessment requirement added • Requirement for training added • Note: More details on each of the above changes are available on the following slides.

6. Freeport Additions - Removed • Equipment that cannot be vented or Isolated • Covered under Hot L&EO section • Use an Approved L&EO Tag to mark the location of all line and equipment openings, if other positive indication of exact location is not practical (Self Service Procurement #12306)Changes in procedure requirements • Covered in new standard as an option for marking L&EO and also covered by RTO standard • A person using breathing air while performing a task in a potential IDLH atmosphere shall be able to escape the hazardous environment without a discontinuation in the flow of breathing air to his/her mask. A Self-contained Breathing Apparatus (SCBA) or an in-line escape bottle shall be used in conjunction with breathing air if there is a potential of inhalation injury or illness from IDLH conditions (e.g., during line breaking, confined spate entry, restrictions to escape, etc.). If used, the in-line escape bottle shall be of adequate size to ensure safe egress from the IDLH risk area. • This is not specific to LEO and is covered by the Industrial Hygiene standards

7. Definition and Applicability of L&EO L&EO is defined as: - The act of opening a process or a part of a process to the atmosphere. - The removal or opening of equipment when that equipment is still connected to the process in any manner. - The act of opening lines/equipments or performing line breaks on equipments which are in their normal place/location, even after the equipment has been isolated from the process. - The act of opening lines/equipment associated with construction/demolition activities if in close proximity to in-service lines/equipment

8. Definition and Applicability of L&EO When does an L&EO begin and end? • A line or equipment opening begins when there is an effort to break the normal operating containment of the system (for example: at the point when the first bolt is loosened on a flange, or the first latch is opened on a centrifuge lid). • A line or equipment opening ends when either the last line or equipment break is completed or the process equipment is removed from its normal location and verified to be free of process hazards.

9. Identification and Documentation of Line Breaks The Safe Work Permit Issuer is responsible for: Indicate the location of the L&EO: the exact location(s) of all L&EOs, including subsequent line break(s), must be identified prior to any L&EO work being performed using one of the following methods: a. Temporary marking/tagging each break point, OR b. Use of permanent identification tags with unique ID number on each break point; the ID numbers of the permanent tags shall be recorded on the SWP or on a separate line break ID list that must be attached to the SWP, OR • Having an Operations Representative present to point out the exact location of the break as each break is initiated; His/Her name must be documented on the L&EO checklist (section II of the SWP). NOTE: The method of identification employed shall be documented on the L&EO checklist (section II of the SWP).

10. Identification and Documentation of Line Breaks Alternate methods for indicating L&EO locations with leadership approval: d. The requirement to positively identify each break point does not apply if the area associated with all the subsequent breaks is clearly identified (barricaded, enclosed, demarcated) and is not in close proximity with in-service lines and/or equipment. Facility/Workgroup leadership approval is required and must be documented. The following "Subsequent Breaks Area Identification" which can be used to document the leadership approval is made available as reference.

11. Identification and Documentation of Line Breaks Alternate methods for indicating L&EO locations with leadership approval: e. For demolition an alternate method which assures no L&EO/breaks are initiated on equipment that is not properly prepared may be used (i.e. use of tape or paint); If this option is selected, the method must be documented in a formal procedure or work practice and must be approved by a Personal Safety Expertise Center (PSEC) Member. The Color Coding, Demolition Tags and Pipe and Conduit Extraction procedures have been approved as an acceptable alternate method and do not require further review and approval. The above procedures are applicable only after the equipment has been released for demolition. L&EO/breaks required to prepare lines or equipment for demolition (isolate, separate and decontaminate) must follow the L&EO requirements.

12. New L&EO Permit (included on SWP) NEW NEW NEW NEW NEW

13. Additional Responsibilities for SWP Issuer: If temporary marking/tagging is used, each break point shall be verified, via discussion between the safe work permit issuer and permit acceptor, during the field walk-through for each and every permit. The following is also required: During the first field walk-through (when the very first permit for the work is issued) each identification marking/tagging must be initialed by the person accepting the SWP. If a location listing is being used, initial(s) may be recorded on the location listing document as each break point is identified. In case of multiple works being done in the same area, the system used shall ensure that each tag being used to identify the location of the breaks is clearly associated with the specific job If, during the L&EO, the need for additional break points is identified work must cease until the additional break points are identified via one of the acceptable methods listed above. Each temporary identification device may be removed as the line break begins and must be removed prior to returning the equipment to service.  Any removed identification device shall be immediately replaced if the associated line opening/breaking is interrupted before the opening is completed. 13

14. Additional Responsibilities for SWP Issuer: Communicate potential hazards and precautions to the personnel doing the L&EO.  Communicate the following to the people doing the L&EO: The status of the line or equipment to be opened. The potential hazards and the necessary precautions (what hazards are present, What PPE must be used, how the line must be opened, what barricading is required, etc...). Complete an on-site inspection when the job is finished to verify that all line breaks have been properly secured and line/equipment is ready to be returned to service. 14

15. L&EO Operating Procedure – Additions to Hazards and Safeguards Section: Hazards, Safeguards and Precautions - A description of chemical, physical, biological, or other hazards related to the L&EO and the necessary safeguards, precautions needed to address the hazards, including: i. Flammables – No change. ii. Radioactive sources – No change iii. Chemicals involved - special precautions for handling chemicals, such as: - Select monitoring equipment that can detect these chemicals - Specific hazard monitoring requirements which include: what, when and where to check, monitoring equipment details and requirements on how often to check - Corrosive materials - Emergency response procedures. 15

16. L&EO Operating Procedure – Additions to Hazards and Safeguards Section: iv. Environmental Considerations – No Change v. Clearing the Area - describe barricading and method to be used to restrict the access of persons not involved in the L&EO. vi. PPE - describe what PPE must be worn and when it must be worn. If chemicals are monitored, respiratory protection is required when detected airborne concentration is above the applicable Occupational Exposure Limit (OEL). Any differences in PPE/RPE requirements inside and outside barricading must be clearly stated. Details on when PPE can be relaxed shall be provided as well. vii. Special precautions - Any special precautions if removing pipe/equipment insulation (contamination of insulation by dangerous liquids) and for handling unstable or hazardous materials . 16

17. L&EO Operating Procedure – Deviations L&EO Operating Procedure must include a section for “Deviations” Deviations - the requirement for the procedure users to verify that conditions (e.g., extreme environmental conditions, physical/chemical conditions, and provision of different PPE) have not changed since the L&EO procedure was written. In case of changes, the work must be stopped and: the work being done reassessed to document new hazards and precautions if applicable, the additional Hazard Analysis must be completed as appropriate, the procedure updated. 17

18. L&EO Operating Procedure – New Section for Identifying L&EO Locations Identification of the L&EO locations: consideration must be given to the need for clarity regarding the location of all line breaks. a. For procedures that will be used solely by trained operations personal, general line break descriptions may be used in the procedure. b. For procedures that will be used by non-operations personal (e.g., maintenance) more detailed descriptions shall be used. Acceptable options include: i. Clear descriptions that uniquely identify each line break location (e.g., "suction and discharge flanges of the P-5A“, "the suction flange closest to the filter F-456"). Use of photos in the procedure may be considered as well. ii. Use of permanent L&EO identification tags/labels, referenced in the procedure. Each tag/label shall be unique and non-perishable. iii. The Operation Representative identifies all the exact location of the breaks in the field at the time each break is initiated 18

19. Changes to Requirements for Additional Hazard Analysis As part of the activities listed above one additional Hazard Analysis shall be performed, and reviewed with Facility / Work Group Leadership, if any of the below conditions exists: a. The line or equipment contains a combustible or flammable material at a process temperature above or within 10°F/5.5°C degrees of their flashpoint, or when ambient temperature is above or within 10°F/5.5°C of the flashpoint of the material. b. The concentration of flammables or combustibles is greater than to 25% of the Lower Explosive Limit before opening. c. Flammable, combustible, toxic, water reactive and/or unstable materials in the line or equipment has not been drained or cannot be fully drained and vented and/or the cleaning/decontamination process does not ensure cleaning of the content to acceptable levels. For example, dead legs, dead ends or low spots, hollow agitator shafts, canned motor pumps, closed ball valves, wiped film evaporators, unsuccessful purging/cleaning, plugging, etc 19

20. Changes to Requirements for Additional Hazard Analysis (Continued) d. The line or equipment contains solids that could trap flammable, combustible, toxic, water reactive and/or unstable materials. e. There is a history of flammable, combustible, toxic, water reactive and/or unstable materialsremaining in the system even after purging. f. Hot L&EO Note: For combustible material, the additional Hazard Analysis is not required in cases where a preliminary analysis indicates that there are no credible hazard scenarios; this preliminary analysis can be completed by using the Global L&EO SWP checklist (long). The results of the preliminary analysis shall be documented in the procedure (reference is available in the L&EO Procedure template). 20

21. Variance to IOES for Hot L&EO – Now Included in L&EO Standard Hot LEOs shall only be executed when all of the following conditions are met: a. Continuity of service is essential b. Shutdown of the system is impractical c. Isolation of the energy source could increase the likelihood of an EHS unplanned event. 21

22. Variance to IOES for Hot L&EO – Now Included in L&EO Standard Hot LEOs shall only be executed via a critical written procedure. In addition to hazards and precautions described in, " L&EO Operating Procedure Writer", the procedure shall meet the following requirements: a. The procedure describes special equipment to be used which will provide proven effective protection for employees. b. Written approval is provided by Facility/Work Group Leadership and an EHS Delivery Leader or EHS BOL: i. For routine and repetitive tasks this shall be documented on the Facility Hot L&EOs list, ii. For non-routine, non-repetitive tasks this approval must occur each time the task is performed. c. If the task is non-routine and non-repetitive, then an additional written approval must be provided from a Leader outside the facility/workgroup (such as EHS Delivery Leader from a different facility/workgroup/site, Responsible Care Leader, EHS Business Operations Leader, Business Manufacturing Leader, Business Reliability & Maintenance Leader) 22

23. Self-Assessments and Role Specific Training Self-Assessment form is available with a recommended frequency of 1 year Role Specific training (initial) for: Safe Work Permit Issuer Person performing the L&EO Person preparing the L&EO L&EO Training Requirements 23

24. Person Performing the L&EO If performing a non-routine L&EO covered by a procedure, the person performing the L&EO must print a copy of the procedure and have it in the field Additional Changes of Note 24

25. Additional Examples of L&EO Applicability Opening a process line or equipment to clear a blockage Disconnection of flexible hoses if connected to process/chemical lines Disconnection or uncapping of flexible hoses if connected to process utilities (nitrogen, steam, compressed air, ...) and capped, plugged, blinded or valved close at the end. All totes were previously in-scope; now may be exempted if specific criteria is met Additional Changes of Note 25

26. Exemptions from the L&EO Standard Routine sampling/draining activities which do NOT require task based PPE, in addition to work area access PPE (not hazardous sampling) Sampling activities using a truly Closed System, if PPE requirements are communicated through the PPE grid and the completed qualitative risk assessment for those activities in the QEA database shows a low priority (4 or 5) Equipment that has been removed from its normal process location and has been verified to be clear of process hazards (i.e. opening one pump at the mechanical shop which has been previously cleaned and decontaminated by operation) Tightening bolts / tubing fitting for first attempt leak repair Injecting grease to the packing gland of a valve stem (valves which are designed with grease fittings at the packing of valves) Opening non pressurized reservoirs with the intention of adding lubricant or checking lubricant level Disconnecting air supply off of automatic air valve Additional Changes of Note 26

27. Exemptions from the L&EO Standard Opening lines and/or equipment under construction which have never been used/pressurized and meet all of the following conditions: are not in close proximity to in-service lines and/or equipment which could lead to performing the opening/break on the wrong line/equipment newly constructed piping and/or equipment which is not connected to an existing process Heating, ventilation and air conditioning ductwork (HVAC), NOT local ventilation or process vents Opening valves on local exhausted ventilations which are routinely used to capture and remove emitted contaminants from the workplace environment Containers that are not connected to a process, as following examples: Drums Bags Bottles Cylinders Cans Totes (IBCs) that meet the Totes Exemption Criteria and are listed on the facility's Totes L&EO Exemption List. Additional Changes of Note 27

28. Additions to Facility Work Group Leadership Responsibilities Authorize individuals to use operating procedure for L&EO's Review additional Hazard Analysis for L&EOs (if required). Approve Hot L&EO's Approve the Totes L&EO Exemption list (if applicable) a. The list shall indicate, by chemical and/or family of similar products, the exemption criteria Additional Changes of Note 28

29. Additions to Definitions Section Acceptable Levels Break-in Point Additional Hazard Analysis HER Health Effect Rating Hot Bolting Hot L&EO Line Break Line Break Identification Line or Equipment Opening Local Ventilation Location Listing Permanent Identification Tag or Label Process QEA Database Toxic Material Truly Closed System Unstable Material Water Reactive Material Additional Changes of Note 29

30. Common Questions When does a L&EO begin and end? Answer: A line or equipment opening begins when there is an effort to break the normal operating containment of the system (for example: at the point when the first bolt is loosened on a flange, or the first latch is opened on a centrifuge lid). A line or equipment opening ends when either the last line or equipment break  is completed or the process equipment is removed from its normal location and verified to be free of process hazards. 30

31. Common Questions What must a person have in order to do an L&EO? Answer: Anyone performing an L&EO must have either a L&EO procedure (if an authorized procedure user) or a safe work permit. If a procedure is used to perform a non-routine L&EO, the procedure must be printed out and used in the field. 31

32. Common Questions What is a hot L&EO? Answer: The act of opening a line or equipment, for working on or servicing activity, that is not isolated (Isolation of Energy Sources Standard) from a hazardous energy source; such as when there is no isolation devices or when the isolation devices are not fully isolating the energy source(s) or there is a potential re-accumulation of energy to a hazardous level. 32

33. Common Questions What are the only 3 ways that are approved for indicating the location of the L&EO? Answer: Temporary tags, permanent tags or having an Operations Representative present to point out the exact location of the break as each break is initiated; His/Her name must be documented on the L&EO checklist (section II of the SWP). 33

34. Common Questions When is an additional hazard analysis required? Answer: An additional hazard analysis is required when any of the following occur: The line or equipment contains a combustible or flammable material at a process temperature above or within 10°F/5.5°C degrees of their flashpoint, or when ambient temperature is above or within 10°F/5.5°C of the flashpoint of the material. The concentration of flammables or combustibles is greater than to 25% of the Lower Explosive Limit before opening. Flammable, combustible, toxic, water reactive and/or unstable materials in the line or equipment has not been drained or cannot be fully drained and vented and/or the cleaning/decontamination process does not ensure cleaning of the content to acceptable levels. For example, dead legs, dead ends or low spots, hollow agitator shafts, canned motor pumps, closed ball valves, wiped film evaporators, unsuccessful purging/cleaning, plugging, etc The line or equipment contains solids that could trap flammable, combustible, toxic, water reactive and/or unstable materials. There is a history of flammable, combustible, toxic, water reactive and/or unstable materials remaining in the system even after purging. Hot L&EO 34

35. Common Questions What are the key components in an L&EO Operating Procedure? Answer: Status of the line; Hazards, Safeguards and Precautions needed to address the hazards in the line or equipment; line and equipment preparation (depressurization, isolation, confirm cleared, etc); deviations – procedure users must verify that conditions have not changed since the LEO procedure was written; identification of L&EO locations; and the opening procedure. 35

36. Common Questions What L&EO are exempted from the standard? Answer: See the L&EO exemption list. A good understanding of the types of tasks that are exempted from the standard is imperative for understanding when the L&EO standard applies Does the L&EO standard only apply to maintenance or servicing activities? Answer: No, the L&EO standard applies anytime line or equipment is opened to the atmosphere regardless of the role that is performing the task. The Hot L&EO requirements only apply when the Isolation of Energy Sources standard applies; therefore, hot L&EO are only applicable to maintenance and servicing activities. 36

37. Other QUESTIONS? FAQ Access the L&EO Standard using Keyword “LEO”