September 05, 2010
Safety Notes November 2009
Posted On: Nov 23, 2009 (16:16:06)

SAFETY NOTES

SAFETY AGENDA – AS OF NOV. 2009

1

Red Book

UPDATE PHONE LIST ON Emergency Procedures/Community Awareness

Appendix A – Employee Contact Numbers

 ÒEMERGENCY PROCEDURES/COMMUNITY AWARENESSÓ EMPLOYEE CONTACT NUMBER. 4/15/09

Rick Vogel to complete within 30 days. 09/24/09

Update.

10.14.09 – R.Vogel wants to know where this question is coming from?

  • R. Vogel has re-written the USCG Facility Response plan went from one book to three
  • R. Vogel  searched Plant 6 control room to find a document that would have management employee contact numbers couldnÕt find any
  • R. Vogel states Management contacts not for hourly employees to have access to

 

10.16.09 R. Vogel was given was given procedure months ago to update pulled off computer Jim to clarify.

3

ELECTRICAL EQUIPMENT THAT ELECTRICIANS WANT TO WORK ON WITHOUT DE- ENERGIZING POWER. OPERATORS CAN NOT ISSUE PERMIT WITHOUT DE-ENERGIZING PER H&S PROCEDURE. EXAMPLE: 24 VOLT TRANSMITTER WIRE EXPOSED TO INSTRUMENT TECH OR ELECTRICIAN OPENING ELECTRICAL BOX WITH IT BEING LOCKED OUT. MECHANICS DO NOT WANT IT LOCKED OUT. OPERATIONS SAY FEEL MECHANICS CAN RE-ENERGIZE WITH PLYERS AFTER OPENING BOX. NEED ADDITION TO LOCK/OUT TAG OUT PROCEDURE TO GOVERN THIS SO PROPER PERMIT MAY BE ISSUED WITHOUT A LOCK OUT. 4/15/09

 

Jay Rogers is working this issue with Rick Vogel and the E&I shop. Justin Donley and Tom Moon will help as additional language is being added. Review in July.

 

á      Will add language to the existing energy isolation procedure (Example, working on a switch that instrument tech does not want locked out).

á      Use Tom Moon and Justin Donley for proper language.

á       

De-energizing power: Dave Mortland and Dave Elliott will work issue with Rick Vogel and E&I shop.

 

When operating at Plant 4 and the electricians wanted to open a "hot" panel within # 10 Substation, the Electrical Shop supervisor would issue the permit to do the actual work on the live equipment.  The Plant Operator would co-sign the permit, allowing the electricians to enter the plant and access the substation.  Perhaps this is similar to the item # 3 from the 5 Person Safety Agenda, which I believe you agreed to address.  Thanks.

 

Lee Chilcote

 

4

CRITICAL SYSTEMS TESTING BY INSTRUMENT TECHS: 3/25/09

MARRIAGE OF MAINTENANCE PROCEDURES WITH PLANT PROCEDURE. These procedures are currently written by maintenance only. Need to have input with operations procedure writer so at critical steps the zone operator supporting the test know what to watch for, perhaps how to bypass the shutdown device or how to react while the equipment is being tested to avoid a real shutdown. Envision procedure writer input to be minimal in the procedure but critical to avoid an unwanted shutdown.

 

MAKE PLANT TRAINER AVAILABLE FOR FIRST TIME USE OF PROCEDURE IN PLANT.

NEED QUALIFIED EXTRA OPERATOR ON CREW FOR TESTING  CRITICAL EQUIPMENT IN MORE THAN ONE AREA WHEN PMÕs ARE BUNCHED UP AT THE END OF MONTH.

 

Reflects both operations and maintenance procedure. Rick Vogel presented the issue to Jack Parsil and Dave Elliott and is currently waiting for response.

Jim Hardy will follow up with Justin Donley and Kim Coker who will be writing one procedure to determine what it will look like, the value, and how much time is needed to complete one. Jim Hardy sent E-mail to R. Vogel about getting Kim & Justin together. Need buy-in from their supervisors to complete this task.

Align maintenance & operations procedures:  Need to arrange for Kim Coker & Justin Donley to initially review. Dave Elliott(?) will discuss with supervision.

 

Status?

 

 

 

5

INHIBITED CRITICAL ALARM LIST IN PLANTS: CURRENT LISTS NOT COMPLETE. 3/25/09

á      Definition of Critical Alarm supplied.

á      5 person suggest to use ÒSOPÓ procedures already developed in the plants as starting points to develop list.

 

Clarify which alarms fit description and each plant needs review. Rick Vogel to discuss path forward with Amy Wagoner.

 

Status?

 

 

6,7

UPDATE SAFETY AUDIT SPREAD SHEETS FOR PLANTS AND MAINTENANCE IN FALL. 4/15/09

 

SAFETY REPS TRAINING DATE? 4/15/09

á      Must have good turnover with prior safety rep at the very least, waiting to find out how many safety reps have changed throughout the refinery.

á      Must have training if safety rep agrees to do environmental audit with extra time allotted.

á      Received a lot of training material for fire equipment audits.

 

LADDERS

An issue that seems to be common among all the operating units is the lack of ladder management.  I have found them laying inside dike walls where they are tripping hazards and leaning against equipment but not in use (stored?).  In Plant 4 the ladders used to be all be tagged for identification and stored in designated locations.  This worked very well for auditing and for locating them when needed.  The governing document for the Monthly Safety Equipment Audits (1 HSS 108) is authored by the JHSC.  I would like to make this an agenda item, pursue it to some logical conclusion and implement same into the Monthly Audit.  Since 1 HSS 108 is due for review on June 30, 2009 and Plant Safety Representatives were just elected, now would be the ideal time to address this.  Changes to the procedure could be presented to the Safety Reps at the annual training.

 

Safety audit spread sheets and safety reps training: training will include review of audit sheets. Regarding Ladders: JHSC recommends identification of central ladder locations & include this in training. Important information for safety reps and operators.

 

 

8

5 PERSON COMMITTEE TRAINING DURING TERM OF CONTRACT. 4/15/09

 

Dave Mortland will check on opportunities for seminar training and possibility of expanding to others. 5/20/09

 

Dave Mortland researched some process safety management seminars. Olivia suggested their looking into seminars affiliated with or through Ohio Technology Chemical Council or American Chemical Council.

10.29.09

  • Reviewed Ohio Chemistry Council for training opportunities -  Ònothing at this timeÓ
  • Reviewed American Chemistry Council for training opportunities –Ònothing at this timeÓ
  • Waiting for response from R. Vogel on material submitted 09.09

 

10

OUTDATED POINT OF WORK CARDS. 4/15/09

Need to update POW cards, P6 has many pieces of equipment shown on the POW card map that has been demo-ed and removed. Also the new equipment is not shown on the POW card map.

POW cards needed for deliveries?

 

Safety department needs to complete updating.  Plants 2 & 3 are complete. 09/23/09

No additional updates at this point 10.16.09

 

13

NEW TYPE OF CLOTHING FOR LIVE FLARE JOBS AND SEWER OPENINGS. 3/25/09

  • Contact Cory Clark (R. Vogel)
  • Suggest that he gets sample clothing and meet with the pipefitters to see if they like it. Do not want it to be more cumbersome and restrict them from doing their job ever more, but understand it is light weight.

Cory Clark was to meet this week with a rep to look at new type of clothing. 5/20/09

 

During last week's Safety Day at Owens Community College I obtained a catalog from a vendor that has a "new" FR glove that, if the description is accurate, would be ideal for use during live flare projects, opening equipment above 20% LEL and any other similar situation.Ó  I gave this catalog to Chris Conley, who said he would follow up on this suggestion.  Please direct questions/comments to Chris.  Thank you.

 

Lee Chilcote

 

  • Cory Clark arranging meeting with sales representative. Haggemeyer has given Clark contact information. Include gloves in the discussion. (Chris Conley may have already discussed with Haggemeyer.  Need to confirm that.)

 

Rick to follow up with cory Clark. 9/23/09

  • Pipeshop has inspected material and garment there is interest 10.21.09

10.27.09

Great reception from the pipefitters on the Tactix TR51 Coat and Pants. In conversation with Jeff Socie, he would like to know what are the next steps forward in acquiring this gear? When would be a good time to discuss this?

 

14

UPDATE ON LOW-SPARKING TOOLS 3/25/09

USE OF LOW-SPARKING TOOLS WITH LEL AT JOB SITE (MAY INCLUDE BLANKING). Document or procedure update and possibly training needed on when we are going to require non-sparking tools. Incorporate in small tool procedure.

    • Question as to whether we are out of compliance regarding use of LOW sparking tools including brass. Rick Vogel will discuss with Sean Cornett and will also review with NER refineries. Verify if brass is standard for refineries.
    • Understand there are lower sparking tools than brass. Lee Chilcote to get together with Sean Cornett, pipefitters, TOPPS Rep, and others to get the proper tools ordered.
    • Remember to get these tool requirements to contractors.
    • Should railroad personnel be using low sparking tools on rail cars?

 

Lee Chilcote - Graig Shaw, Chris Lange, Ken Abernathy – Hourly personnel supplying input.

 

Lee:

 

Looks like we have enough tools to handle basic work.  Todd thinks that we are getting a couple of 3/4" drive socket sets to go along with the 1/2" sets we already have.

 

Chris

 

 

Safety Department to review procedure. Alignment with Green Book, etc.

 

Need the list of low sparking tools to verify all needs are met and possibly to share with other Sunoco refineries. List sent out. Complete 9/29/09

10.16.09 Management sent out inventory of Low Sparking tools

10.16.09 Address in Small tool procedure

 

15

PERMIT STOPPING POINTS Procedure 3/25/09

  • R. Vogel will check out stopping points on a procedure (includes verification of preceding steps, check it out, and sign off).
  • Gave R. Vogel a copy of the stop point check list from Philadelphia, Marcus Hook, Eagle Point & Toledo. Only Toledo requires a Chief Operator sign off.
  • E-Mail from procedure writer, How and when do we plan on training all of operations on the use of the new procedures? First of all they need to be aware that they even exist. This should happen well before they open it up on the Intranet and find out there are now different than before. Are the supervisors aware of the fact that they now have to sign off on them? To my knowledge, none of this stuff has been communicated to anybody.
  • E-Mail response from Chris Wright,  Procedure writers should continue to include stop points in all new start-up procedures as originally instructed. Operators will be expected to follow all procedures containing stop points as written. Until this issue is reviewed and resolved in a formal meeting we should all continue to adhere to the plan and guidance already provided.
  • E-Mail response from Clarence Young,  During the quarterly Procedure Writer Meeting yesterday the subject of procedure stop points was brought up for discussion. I was informed that this topic was on the schedule to be discussed at the next G&N meeting, so further discussion was tabled until the outcome of that meeting was communicated. It was suggested that we should not have procedures that have stop points available on the intranet if the use of stop points is in question. At that time I told the group I would follow up on the issue and provide guidance as soon as possible.    

 

The issue of the stop points does not appear to be on the G&N schedule for today. Regardless of that, Procedure Writers should continue to include stop points in all new startup procedures as originally instructed. Operators are expected to follow all procedures containing stop points as written. Until this issue is reviewed and resolved in a formal meeting we should all continue to adhere to the plan and guidance already provided.

 

  • At the time of these E-Mails, a S.S. was asked about the stop points in the procedures that were MOC-ed to be signed off in a plant. He was not aware of them and when shown had not seen or heard of them before.
  • Response from Clarence Young, Prior to tabling the discussion due to reports of an impending grievance, this issue was on the meeting agenda so the group could discuss the plan.  I will refrain from trying to lay out the plan in this e-mail, but I will say that we plan to provide written guidance and intend to roll this out to the organization as soon as possible.  If a startup procedure containing stop points must be used before the roll-out can be completed, we will review the material with the affected personnel as necessary.  You can expect to see something soon. 3/25/09

Per a Shift Supervisor – ÒYou should have been trained, I was trained.Ó

 

Most Shift Supervisors feel that all that is needed to change a procedure being used during a start-up or shutdown is to initial the steps for changes on the procedure which the chief is told to make, then add a reference note on the sign off portion at the stopping point.

 

Rick Vogel will discuss with other managers as there seems to be inconsistent interpretation. 9/23/09

 

Update

-Advisory Flash sent out 10.12.09 to all refinery users

-Shift Supervisors to be trained and rostered then Supervisors to train crews 10.16.09

 


Advisory Facts

Date (MM/DD/YY):

Time (HH:MM):

Business Line:

Facility:

Location:

 

Advisory Summary

Description: Procedure Stop Points

Stop points are being added to startup procedures.  This is being done to promote safety and consistency throughout Sunoco.

 

What are Stop Points?

Stop Points are sign off locations within procedures to allow operators and supervisors the opportunity to check the conditions of the unit against the Safe Upper and Lower Limits to identify any operational issues.  If the unit is not exceeding any Safe Upper and Lower Limits of operation, then the Stop Point is signed off and the startup proceeds.  If an issue is identified, corrective action is taken before the Stop Point is signed off. 

 

How do we use Stop Points?

The Zone Operator must initial on the small line next to the step number of each step of the operating procedure that has been completed.  The Zone Operator can initial them one at a time, in groups, or can communicate them verbally to someone else for initialing so as not to unnecessarily slow down the flow of work.  Once all of the steps prior to a stop point have been completed, the Zone Operator must wait until the stop point has been signed off before proceeding to the next step of the procedure. All non-editorial changes to procedures must be accompanied by an MOC (see the ÒWhat is a ChangeÓ document on Sunoco@Work). 

 

The Chief Operator must review all steps completed by the Zone Operator prior to the Stop Point.  The Chief Operator will note any issues, comments or any events that transpired while utilizing the procedure, then sign and date the stop point.  Once the Chief Operator has signed off, operations supervision will verify that the tasks have been completed, any documented issues have been resolved, and it is safe to proceed.  Operations supervision must then sign and date the Stop Point before the startup can continue.  The supervisor providing the final Stop Point signature should forward the completed procedure to the Administrative Assistant in the Training Department.

 

What is my responsibility?

Zone Operators who initial steps and Chief Operators as well as Operations Supervisors who sign off on stop points have the same responsibility and accountability that existed before Stop Points were added to the procedures.

 

Facility Contact: Clarence Young | Process Safety Coordinator | 419-697-6486

Control Tier: 1                                                                                                                                                        Revision Date: 8/1/2005

                                                                                                                                                                   Last printed 9/22/2009 12:52 AM

 

Paper copies are uncontrolled. This copy valid only at the time of printing. The controlled version of this document can be found at the Enterprise Learning Site on the Sunoco Intranet.

 

 

 

 

16

PAPER GASKETS USED ON PROCESS SIDE OF BLANKS IN PLACE OF FLEXATOLIC, THEN LINE PUT IN SERVICE AGAINST BLANK WITHOUT AN MOC FOR REPLACEMENT NOT IN KIND. 4/15/09

  • Planning jobs need improvement between Operations Planner & Maintenance Planner.

 

Importance of consistent criteria for defining blanks emphasized. Blanks need corrosion analysis if it will see process for even a short period of time during an outage. Scott Weidman. will secure blank list and descriptions and will work with OPÕs once definitions are clarified.

 

Update

10.16.09 Blanks need to be designated Òin service Ò blanks during planning process so they can be noted in work packages. Need to get the word out through safety flash or something so all are aware.

17

SINGLE POINT FAILURES: 4/15/09

  • Requested list of all refinery single point failures throughout the refinery for each joint meeting.
  • In my Plant, no emergency Procedure if our single point failure P-6372B went down.
  • Asked S.S. about how we would handle the routing of Jet. Gave him 3 possible ways of which he has to decide, said he would have to get back to me after talking it over with the F.S.S.  Later, the decision was given to operator, but feel the plan should have been in place.
  • Single point failure in another plant could have large impact on my plant. Want a plan, or a heads-up, so the crews can do a Òwhat ifÓ. The situation that would have been very had to handle when suddenly it actually happens, could be addressed by a  prepared crew if the chiefs did ÒWhat IfÕsÓ ahead of time with his/her crew. Does not have to be a formalized ÒWhat IfÓ.

 

Need to prioritize SPOFs as we have no list. Concern that refinery needs a list of SPOFs and ÒWhat IfÕs?Ó

Action Item: Jay Rogers will develop spreadsheet of SPOFs including upstream and downstream plant impact for discussion at the June JHSC meeting. Shift organization owns this with input from OPs. Spreadsheet will be used as tool to elicit discussion and once it is approved, it will be posted on Sharepoint. Shift Supervisors will also work with chief operators. 

J. Rogers to report back June meeting.

Rick Vogel to check with Jay Rogers on status of spreadsheet and once updated, suggestion to discuss daily at both shift changes with Shift Supervisors. 9/23/09

-Still in development 10.27.09

 

25

USING CHEATER BARS ON VALVES TO OPEN AND CLOSE THEM.  5/20/09

Using cheater bars is not acceptable.

The maintenance supervisor (Nahn) was supposed to start a maintenance PM program on valves.

Can not get a spanner on hard to turn chain valves.

Valves are should be able to be closed by one person with the proper tool. Two operators with spanners on one valve may go over the torque value of the valve.

All different sizes and makes of valves have a torque valve for tightening. Nahn was going to make groupings of valve sizes and give us one value for each group of valves. What part of this, if any, was done prior to him leaving? Once this is found out is somebody going to pick up the ball? Need list of valves that are hard to operate. Are hard to operate valves on upcoming shutdown list?

Plant 4 had 235 valves on the list and only 35 was replaced or repaired.

 

Need to identify the worst valves in the refinery and how many valves will be replaced during the TA.

  • R. Vogel distributed TA Scope valve list for Plants 2,3,4,&8. To access online, go to Sunoco@Work, R&S Areas, Turnaround, Toledo, Homepage, 2009 Turnaround, FCC.

 

Rick Vogel to discuss with Keith Schindler. Need to identify best alternatives to not using cheater bars with imput from chief operators and shift supervisors.

 

Status?

 

May 16, 2007

Valves, cheater bars, shutdown safety: are we properly engineering valves for the required services? Example, following TA, we have some new valves that do not close which is ergonomics issues. Why not? Both corporate and local engineers need to review. Also need RCFA on reasons valve failed. Fact Finding Form has been submitted on particular valve, but ongoing issues with many valves.

 

 

June 20, 2007

Question as to whether there is need to look at isolation valves around the entire refinery on a regular basis. Need system to be able to shut off a valve without hurting the entire system. J. Utendorf reported that work requests are being entered for valves that need work.

 

Jan. 18, 2007

Cheater Bars

Matt will set up meeting to include five-man reps, Ryan Elliott, Paul Hughes, Jack Parsil, Bob Kasprzak and Nhan Phandinh. Purpose of meeting is to discuss use of cheater bars and appropriate language in procedure regarding cheater bars. (Action Item)

-       10.16.09 R. Vogel provided a ÒpartialÓ Power Point Ò called Small Tool & Spanner Wrench Safety

-       Option – training?

26

NEW 5 PERSON MEMBERS NEED TRAINING ON LIVE FLARE PROCEDURE, OPENING EQUIPMENT ABOVE 20% LEL & VARIANCES. 3/25/09

 

Until the training happens, if a 5 person member would be more comfortable will another 5 person member at the meeting, it is not a problem.

Rick Vogel will be in contact with Jim Hardy, together they will do the training.

Norm Smith and/or Dave Mortland to attend live flare pre-meeting.

Will do the training as an agenda item at JHSC meeting. 9/23/09

 

Agenda item for Oct.

30

Live permits out at break times that conflict with X-rays (radiation). How can we address somebody being exposed to radiation if they have a permit to be in the area? Need H&S radiation procedure updated to address this.  05/20/08

 

H & S radiation procedure needs updating to include responsibility of X-ray personnel and others so that permit can be out or exceptions noted. Rick Vogel and Jim Hardy to address.

9/23/09

Update 

31

From:                        FOLEY, TYSON J 

Sent:                          Friday, April 24, 2009 12:24 PM

To:                              DAVIDSON, KATHY J; CONLEY, CHRISTOPHER; CHILCOTE, LEE I; ELLIS, DAVID L

Cc:                              CREDICOTT, JOHN W; EVANS, TIMOTHY S; WILCZYNSKI, MARC E; SCHINDLER, KEITH D

Subject:                    H-502

 

All,

 

After looking over H-502 this morning, engineering's judgment is that the heater presents no imminent danger to nearby personnel. The sides and bottom of heater are deteriorating, but the sides are supported by I-beams that provide its core structural integrity. Due to the deterioration in the heater's bottom, engineering recommends no personnel access underneath the heater and a barricade be placed around the heater to prevent personnel from getting close to it.

 

There is loose material on the heater's sides that could be asbestos and need to be analyzed. The areas in the sides of the heater that have been penetrated and have loose particles need to be wrapped to prevent release of particles to the air. The top of the heater is open, so rain water falls into the heater, which reduces the amount of airborne particles, but this adds to the load on the heater's already weak bottom and increases the risk of items falling through the bottom.


Engineering recommends that the heater be demolished or at least that the heater's internals be removed ASAP to reduce the risk of items falling through the bottom. If the heater is not demolished, thorough analysis needs to be performed on the heater to determine how much weight the bottom and sides can withstand.

 

Tyson Foley

Office: 419-697-6501

Cell: 419-392-6346

Fax: 866-743-0799

 

John Credicott

419-698-6683 

Also has an asbestos issue.

 

-10.15.09

á      Heater red taped

á      Per R Vogel ; heater tested for asbestos none found

-10.17.09 Has the refractory been exposed to over 1600 degree temperature? And could this material have become a form of Cristobalite and now be a potential silicosis issue?

 

Has the refractory been exposed to over 1600 degree temperature? And could this material have become a form of Cristobalite and now be a potential silicosis issue?

32

Understanding from electrician that operational personnel throwing a 600 volt breaker in a substation should be wearing a face shield, jacket, and gloves. Request we get a safety cabinet install in the substations with this equipment. 5/20/09

 

Safety cabinet installation in substations: Jim Hardy and Rick Vogel to check out.

 Start switches should be away from pumps (Note: P/5 incident on 9/01/09)

April 16, 2008

Electrical Training for Operators – Toby McDougle & John Plouffe

  • Toby presented proposal to give ARC Flash Training to operators. Also discussed placing flash jackets and face shields in all MCCÕs to be worn while operating a breaker. There is also a need for training on this.
  • We are not meeting all the standards of National Fire Prevention Association (NFPA) 70E.
  • JHSC unanimously endorsed need to meet the standard if we are not meeting it.
  • Refresher training should occur approximately every two –  three years. Also consider annual e-Prism, weekly safety topic.
  • Survey was completed and now Jonathan WhitlockÕs area is labeling switch racks and breaker panels.
  • Health & Safety department will adjust language in  Green Book accordingly.
  • Matt and Rick are meeting with Ray Villegas on Thursday to discuss training.

-10.15.09 No update

34

Per Green Book Procedure - Alarms/Evacuations (1 FS 304) and Green Book Procedure  - Aerial Work Platforms 1 MS 516, THE USE OF AERIAL LIFTS AND CRANES WILL BE PROHIBITED WHEN WIND SPEEDS ARE IN EXCESS OF 30 MPH. THE MANUFACTURER OF THE EQUIPMENT AND OPERATOR OF THE CRANE MAY INDICATE LESSER WIND SPEEDS LIMITATIONS ON EQUIPMENT.

  • Update the Green Book to more accurately reflect conditions in the field. Want documentation from the manufacturer and documentation of the comparison among wind speeds at Sun, Metcalf and Toledo. The case to make changes to the existing procedures is best made with objective evidence. Please include Erlin Moritz in discussion of changes to the Green Book.
  • The issue is that the anemometer is sheltered (disrupted) when the wind is out of the West Southwest. If you look at the history of the refinery's wind speed and the history throughout the day at Metcalf and Toledo airports they are way off. The greenbook has the wind speed as an issue at 30MPH ;  but the crane manufacture recommends the derating of its lift at 20MPH. The other day when we got on line, the weather station was reporting winds in excess of 29MPH with gusts of 35 and when we asked it was 26MPH and nothing was said. The problem is that we could be able to do work when it's at grade inside plants where we are sheltered. But when we are out there with 100 + ft of boom, then we get blown all over the place. We have several suggestions as to what to do but the way it is, is unsafe. Does the wind direction and speed gauge that's on top of the Lab work?

 

Rick Vogel to meet with Erlin Moritz regarding procedures and weather conditions in the field, specifically with use of aerial lifts and cranes.

The new 5 person currently has the crane procedure for review and also 1 MS 516 Aerial Work Lift Platforms 1 MS 516. Would like ErlinÕs input, sent him electronic cranes procedure where he will review section on wind speeds.

 

P/5 use to have wind direction & speed on PI. Could this be put on a screen for the guards with an alarm point set?

-10.15.09 per R Vogel guards have access to wind speed ,same as shift bosses

 

36

HYDROCARBON FILTERS FROM VARIOUS POINTS IN THE REFINERY AND DUMP THEM IN A BFI BOX TO BE LAND FILL WITH THE OTHER TRASH IN THE BFI BOX?

 

Why are we allowed to dump the Used filters from Plt 4's various filter lip box's and Plt 9's various lip filter box's into the BFI roll off box to be taken to the landfill with the general refinery trash? I sighted the used oil containers, and the spoil's policies, as examples of our current policy on how to handle hydrocarbon waste.

______________________________________________

From:          SHELT, STEVEN A 

Let me clarify the question.

 

Containers with "used oil" are put into a dumpster after they are emptied into the "used oil" tank. These containers consist of mostly plastic although another may be some intermingled metal or glass containers. These containers are sent directly to the landfill. This landfill is the same landfill we send our contaminated soil, trash and other nonhazardous process waste. "Used oil" filters are collected from the garage, drummed and sent to an incinerator. The incinerator utilizes the BTU value and the metal remaining is then sent to a metal reclaimer. These "used oil" filters could go directly to our local landfill but because of the high volume of metal we elect to send them off for the metal recycling.

 

Our contaminated soil procedure for a spill or leak is to have the material directly put into a roll off box and if the leak contains BTX the roll off box is to be covered during times it is not in use. There are many excavations that are not related to a spill or a leak of hydrocarbon material. Soils not containing hydrocarbon material can be placed on plastic or the ground but must have a sign placed at or near the excavation.

 

From:          SHELT, STEVEN A 

 

If you are wanting the answer to the question about the 9-2 and plant 4 filters, the environmental review was determined that the current method of disposal is correct. This material can be put in the paper box. As stated in the meeting with the T&T employees on 4/23/09, this material is sent to the same place as other hydrocarbon contaminated material. Due to the high amount of metal from the used oil filters in the garage these are sent out for incineration and the metal is reclaimed. If, by chance, future analytical results would be different we will have to set up different handling procedures for the material.

 

 

T & T are worried about being sighted for putting these filters in the wrong containers, along with the drivers who are carrying them out of the refinery.

 

R. Vogel will clarify with Steve Shelt & Elaine Moore and report back. 5/20/09

 

Should T&T get permit in orchard when picking up dumpster box full of used filters? Is it checked for LEL.

 

Per T&T – Now we just dump them into a B.F.I. box. Does this sound right?

-10.15.09 Environmental Dept. will address if EPA regulations change

- Additional clarification for next meeting

 

37

Isolation Of Energy Sources Procedures - 5/20/09

 

Request language clarified on what is acceptable isolation for pump removal.  Suggest single isolation, but add that blinds have bleeders on them.

  • Isolation of energy sources procedures: approved to add language Òblinds have bleeders on them.Ó

No language exists on isolation to open equipment in procedure.

Isolation at Tank Farm on bubbles in line marked with vessel numbers. If these are truly vessels they are not properly isolated for opening..

 

Jan. 16, 2008

Blanking vs Blinding When Pulling Pumps for Repair – Dick Bedee

á      Open flanges and pulling pumps leads to higher risk. This is multi-craft issue with various risks for different crafts. The procedure allows to blank or blind but there is an issue around blanking at the valve.  Need to weigh the risks.  Twin seal valves would eliminate risks, but this is long term solution that R & S would need to address.

á      Long term recommendation: When a unit is down, make an attempt to use twin seal valves when appropriate.

á      Short term recommendation: When pulling a pump, when applicable, remove spool pieces and install blind flanges with bleeders. All exceptions must be considered. Need to review maintenance procedures.  Includes contractors in running maintenance. Scott Weidman will discuss with Nhan Phandinh and report back at February meeting.

 

41

HIT list for MSDS obsolete since naphtha simplification. The HIT list is used so personnel can look up a piece of equipment in a unit by the equipment number and it will show the materials that piece of equipment contains. Was brought up to G. Lowry, C. Young, R. Rios, & M. Major. Response was that it would be updated prior to start-up. That was over three years ago. How many craftsmen were given the wrong MSDS to work on a piece of equipment?

-10.15.09 PSM / Tech Service Rick will speak November 2009

 

 

42

Car seal Safety procedure or policy needs developed. Currently in draft stage. June  2009

Sent back to R. Vogel with recommendations.

-10.15.09 Additional changes by corporate

-November 2009 update from R Vogel

 

43

Some R.V. valves positioned upside down. Is this a requirement? If so, do the shutdown coordinators know this?

-10.15.09 need asset numbers to address

45

CHILCOTE, LEE I 

Are contractors' fall protection equipment inspected and maintained to Sun

standards and, if so, how is the record keeping managed?  June 03, 2009

 

ROMSTADT, STEPHEN M 

The contractors have to have the annual inspection (some type of blue marking). It is up to the individual contractors to do the record keeping.

 

Paul Hughes

 

P&W Painting contractors were not within Plant 9 during the Safety Audit but they did have a staging area in the courtyard.  I looked over that equipment (fall protection, fire extinguisher, etc.) and it did seem to comply with our standards.  While walking back to the main gate a P&W truck passed me.  The occupants were wearing bright orange nomex, so perhaps they renewed their coveralls.  Thanks for the heads-up.

 

Lee Chilcote

 

As the contractors are gearing up with more & more equipment, would suggest to have safety reps before and during shutdown spot check for some type of blue marking indicating annual inspection of fall protection.

 

Suggest fire extinguishers also be spot checked.

ContractorÕs safety harnesses are hung outside all the time. DonÕt they need some standard as us.  7/1/09

  • 10.15.09 Contractors held to same standards as Sun
  • Safey Dept does spot checks
  • OSHA regs state that annual inspection by someone other than user

 

46

Karen and Keith

 

According to conversation that I heard in the control room, # 2 Tank Farm is supposed to be grandfathered from the requirement of posting confined space entry test results at the points of entry due to weather issues.  If this is accurate, where is it documented?  Also, I searched the CHIP System for the material that SPL is coating the excavated line with ("Temcoat" manufactured/distributed by Trenton) and did not locate the MSDS.  Is this material approved for use within the Refinery and can I obtain a copy of the MSDS?  Thank you.

 

Lee Chilcote

USW Safety Representative

419-697-6426

  • 10.15.09 - No grandfathering
  • R Vogel has no knowledge of this – Why?
  • Amy Wagner – No answer – where was it done? Plastic Sleeves?

47

E-IDENTIFICATION BADGES, HOW CAN THEY RECEIVE PERMITS? 4/15/09

By the Green Book they have to be escorted in order to receive a permit.

 

Delivery truck escorts. Electronic permit training: vehiculars require a permit. Delivery trucks drivers should require a permit, but supervision says they do not, will not supply escort for drivers that do not have badges allowing the drivers to receive a permit.

 

Understand contractors that load Harp are not badged, not escorted, and they are not required to wear H2S monitors? Sometimes they are in at 3:00 AM.

  • 10.15.09 Truck drivers not badged
  • What about Methanol delivery drivers enter into process untis unescorted
  • November 2009 update

 

49

Monitors should be tipped up to keep bees from getting into it. Could a safety flash be sent out about this?

  • 10.16.09 Conflicting messages
  • 10.15.09 R. Vogel & Safety Dept want left down

 

I spoke with the Fire Marshalls regarding the position of the nozzle for monitors.  They all really saw no major advantage and or benefit to storing in the upright position, although they all did state that they felt the potential for bees to nest was still present and a slight concern of obstructions getting into the nozzle tip in the upright position.  Any questions please feel free to let me know.

 

This issue came from the fire marshallÕs safetry rep?

51

Asked for mechanics and operations to report block valves (bad actors) in need of repair or replacement as they come across them. The ones they complain about to us (5 person) we will note to make sure they are in the system. Mechanics have no idea if they are in the system.

 

200+ valves at P/4 on scope for replacement, ended up with 35 being replaced.

  • 10.15.09 Management would like specific data concerning particular valves

Will get from Joe Fox.

54

Understand the procedure writers have a real concern about reducing the information contained in the SOP procedures, information that the subject matter expert feels should be left in the procedure to assist in near-miss and/or incident reporting. Would like to have Jim Hardy invited to the next meeting held by Clarence Young regarding SOP procedures, so he can get a feel for the procedure writers concerns. Meeting July 7th 11:30 – 1:00.

  • 10.16.09 Jim Hardy not released to attend meeting
  • 10.16.09 Procedures need to be consistent across board
  • Jim Hardy not released to attend meeting November meeting.

 

55

Peabody blanks (contain small line and valve within blank for draining). Could these be use in the refinery?

Would like a requirement that blind flanges (if room allows) be installed with a bleeder/vent valve on all installed blinds for depressuring prior to removal.

Realize that it may get done if it is requested in the package by the O.P, but this will fall short if not a requirement.

-10.15.09 Need to provide specific product data to Management for next meeting

56

Planning a job incorrectly can lead to an unsafe condition. Discussion.

-10.15.09 True statement! Constant Issue; Scott Weidman is addressing regularly

 

57

Running to failure is not safe, puts unit personnel at risk. Discussion

58

Steam leak list at P/6 is being generated now. Hopefully this is being done around the refinery. Note: Make it a priority to fix all the highline leaks that would create dangerous hanging ice above workforce.

-10.15.09 Winterization crews to begin work @ P6 10.20.09

 

 

 

59

Inspection – We have a problem with thin lines and overly clamped lines. Examples sour water line and P/6 off gas line at PCV-61016. What do we have to do to get inspection more proactive and less reactive? Has the record keeping improved over the last several months?

 

 

60

Roadway repair plan was developed several years ago with X amount of dollars approved to be spent each year. What is the plan for this summer? Tis summer has passed, what is the plan for next summer?

 

Oct. 18, 2006 JHSC Notes:

Roadways

Currently receiving $180,000 yearly for road work

 

Engineering brought in late last year to work with Roadway Project

 

Prioritizing list of roads identified included west of the Maintenance Building, West of E&I and West of Plants 2 and 3.

            Sending to Jim Parent to review for sewer considerations

            Then will send out for bid

 

Will be working around the expansion project – Need to check with Naphtha Sim Project to see what roads they will be replacing.

 

61

ÒA variance may be requiredÓ or Òworking on equipment above 20% meeting may be requiredÓ  Can the word get out to the O.P.Õs to get this language in the job steps so we can get a heads up?

 

63

Management of change discussion. 28 page procedure to fill out an MOC? 5 person has a possible solution to offer to the joint committee for the lengthly procedure.

66

From: CHILCOTE, LEE   to CONLEY, CHRISTOPHER; FANNIN, ERIC E

June 22, 2009

 

T-19001 has a leak 2/3 the way up on the east side of the tank.  In the past, this has been determined to be acidic water.  No barricading is in place.  It looks like this could also be impacting the railroad.

 

There are two cylinders in the water building that are sitting on concrete.  This floor sees a lot of moisture.  Also, I believe pressurized cylinders are to be hydro tested on some frequency.  Has this been done?

 

A new walnut shot pot is being built as we speak.  The discussion in the control room indicated that there are some ergonomic concerns with the design.  Now would be the time to address these issues as opposed to after it has been completed.  Thank you.

 

Lee,

 

- T-19001  I took a look at this yesterday.  At this time the leak does not appear to be impacting personnel safety.  That is not to say that it won't get worse, I have asked the OP to put in a work request to have this repaired.

 

Compressed gas cylinders require a hydro test every 5 years.  I'm not exactly sure which cylinders your referring to, but that is the requirement.

 

I spoke with Alan K. from the plant about the shot pot ergo issues.  He said that the engineer was made aware of these issues and that he was going to have them mitigated.  I will follow up to verify.

 

Christopher Conley

 

The Plant 2 cylinders in question are located to the right of the east entry door, green in color and chained to an upright support.  The date stampings on the them indicate that they may be overdue for testing.  Is there a system in place to manage these and all cylinders within the refinery?  Thank you.

 

Lee

 

67

E-prism on scaffolding, a discrepancy from our current procedures. On slide # 11 which is page 14 of 16 there is a note on yellow tags at the bottom of the slide indicating that when fall protection is req'd on a scaffold each worker must wear a personal fall protection device attached to a fixed point separate from the scaffold. A couple of years ago Matt Grimes obtained a letter from our scaffold manufacturer that indicated that the rails of the scaffold were tested and approved as anchor points when on the scaffold. In most cases in maintenance if fall protection is req'd on a scaffold we tie off according to that approval. Would hate to have someone see someone doing that shortly after completing their CBT and think that they are doing something wrong. 7/1/09

 

68

Schedule meeting for discussion about safety concerns of not properly manning newly created P/2 job on off shifts and weekends. 7/1/09

  • Greg Thomas, Jim Wesolowski, and Jack Parsil to meet to discuss manpower issues off shifts and weekends at new job in Plant 2.

 Do we know when this will be yet?

69

PSM policy – are we following what is described as employee involvement? What can the union side do to help increase this involvement?  7/1/09

 

71

T&S – bricks falling from roof at T&S railroad main entrance to office building. Area taped off, have to enter area through overhead doors. Believe it is vibration from trains. Repair & prevent.

 

Joe Haws

I had R- Gant look into this yesterday after the 5 man, he removed the lose brick so none should fall now. He will put an estimate together for Jay Utendorf. I will follow up with Jay to see his plan forward. 7/1/09

Status

72

Plant 9-1 using temporary hoses for permanent use, nitrogen to T-9201. 7/1/09

 

73

5 Person committee needs a little time off job duties to get a couple of HES procedures reviewed.  7/1/09

 

75

Radios that maintenance have in the tool room are ancient, some do not even hold a charge for a shift. Also the radio channels do not match up with the OperationÕs channel. Could be an accident waiting to happen. 7/1/09

 

Radio problems. Any radio user that has a problem can tag the radio stating the issue and give to security to have the radio repaired.  9/2/09

 

June 20, 2007

Radios: Current FEL incorporates radios into security upgrades. OPÕs did assessment of their radios and are submitting their requests. Frustration that radios still do not all communicate on same channel(s).

 

Nov 19, 2008

Refinery radio system: Our repeater system is obsolete and the FCC will require a different system to be in place by 2012 so options are being reviewed. Our time frame for replacement has not been determined but the 2009 budget will reflect a line item.

 

76

504 tank (virgin feed) currently getting hard pipe fabbed up since we had the release. Transfer hoses have been there for a year. Check out MOC, variances are only good for 6 months max, temporary hoses should have a limit on time in service. Should be a stamp on the hoses. Do we have hoses like this in other places in the refinery? 7/1/09

 

78

Clearly marking all possible exit routes in elevated areas such as Plant 9-4 fan deck, Plant 9-2/9-3 fan deck, Plant 8 Kellogg mixer area, Plant 6, Plant 5 compressor building, Plant 4 elevated structure areas, Plant 3 & Plant 2. There could be reflective exit signs made up for identifying all exit from the raised areas.

 

  • Rick Vogel distributed samples of exit and other signs which can be ordered and customized accordingly. Suggestion was made to have the safety reps and the safety specialists ÒauditÓ their areas to determine where and what signage is needed. This would take place after the TA.

 

 

79

Want to have a discussion of the use of Hot Tap Procedure/API 2201 for none piping situations. We are trying to apply a procedure to vessels that was written for piping. Need to write a procedure to better serve these situations.

 

As we are following the Hot Tap procedure, one thing that was absent from the material was an "Emergency Action Plan" covering if something was to go wrong, reviewing the API 2201 there is a template for this. This should be a simple thing  to do we can talk to it at 2:00.

 Also the Weld procedure from Matrix is a generic form, we need to remind the welders of this and there should be no "air arcing or gouging on this tank.

 

  • Hot Tap Procedure: Suggestion made to add an Emergency Action Plan to the Hot Tap Procedure or to even consider a separate procedure for this. Can use the API language as resource.

Per R. Vogel, will add language to the Hot Tap Procedure covering non-piping situations.

 

80

Want to discuss Machinery Guarding

82

Truck # 428, parked east of MOB, seems to be leaking gasoline from the fuel tank.  The person who used to manage the record keeping of trucks was terminated. Who is managing the record keeping now?

84

8/19/09 Live Flare T/A not handled according to the H&S Procedure. Vales were not verified to be isolated,

Live Flare

  • Discussion focused on isolating s, blocking out and locking valves. Need to verify Green Book language. Does it state that every valve that can be isolated, should be, during live flare process?
  • Live flare process also requires notification of people, however all may not be aware of this. Everyone should know when a live flare is taking place.
    • Suggestion made to use tags stating ÒDo Not Open During Live Flare.Ó Extra notification and communication will help protect folks. Concern expressed that someone could innocently open a valve if he/she has not been properly notified. Importance of chief operators knowing what is going on in entire refinery.
  • Recommendation made to add the following language to the Flare System: Procedure under Facility Shift Superintendent Responsibilities:
    • Notify Chief Operators of each unit that is tied into the flare system being worked on.

Procedure under Chief Operators Responsibilities:

    • Chief Operators of each unit  will notify Zone Operators.
  • Questions also as to the intent of Òisolation.Ó
  • Suggestion made to develop a list for each plant of valves that need to be closed (not locked out) before a live flare is done.
  • Question regarding need for valves to be car-sealed closed? Discussion about this is ongoing due to the various environmental regulations.
  • Recommendation made to isolate what ever can be and tag the valves. Tags could say ÒDo not open during live flare work.Ó Rick will get tags immediately.

 

Suggestion made to use signage like we have for working around critical equipment.  Danger, do not open during Live Flare work.

85

8/19/09 Isolation of Flare Header – Procedure was challenged by supervision.

Bring in example of P/6 procedure to show Safety Manager of intent.

86

V. Clyce use to do the main office & Sales? Fire department doing this monthly audit on extinguishes takes away from our other duties. Will she start doing these audits again?

87

MORTLAND, DAVID H 

8/11/09

Rick,

Yesterday your department put out a Heat Stress Advisory for the refinery which only covered the contractors and employees working outside. Apparently this doesn't cover employees working in buildings such as the Maintenance buildings?  Unfortunately the Maintenance building ,in particular the Machine Shop, had an inside temperature of 91 degrees Fahrenheit. Having no means to measure relative humidity could you have one of the Safety Specialists begin to monitor Relative Humidity & Temperature in the Maintenance Buildings where we have employees working in non-air conditioned areas. When appropriate, could you include the Maintenance buildings in any future Heat Stress Advisories.

Dave

The heat advisories (from the Safety Department or other agencies) are generally directed to personnel directly impacted by the sun due to the additional heat loading that entails. However, enclosed areas could also be impacted during certain conditions, such as confined spaces with lower ventilation. The Safety Department will gladly conduct additional testing if requested for specific areas (we tested T-851 recently per request). Based on your request below, we will conduct testing in the maintenance shops during the next heat advisory(s) to ascertain a correlation between outdoor and indoor conditions.

Rick.

_____________________________________________

 

88

8/19/09 Question about exchangers taken out of service at P/6 for the T/A. Per Sun Standard, seal welding on bleeders and bull plugs which may be needed is not included in the TA scope therefore not being done.. Should there be a deviation written?

Understand that all ½Ó bleeders are to be changed to ¾Ó bleeders at next opportunity, which is also not being done. Could you clear this up for us?

 

89

8/19/09 Operations supervisor does not feel they need a permit to enter a piece of equipment, also feel that inspection does not need a permit to enter a piece of equipment.

Safety flash put out which will be followed by a recommendation of the JHSC.

In addition to permit required confined space entries for individuals performing work, any individual wanting to enter for non-work activity, must notify the plant chief operator/coordinator who will then determine if a safe work permit is required.

 

  • Issue centered around confined space entry supervision and general discomfort with what is taking place in some instances during TA. Importance of everyone (including contractors) reading their permits and JSA's. Much discussion centered around purpose of someone entering confined space and the need for a permit. Importance of 'hole watch' emphasized.
  • Question as to whether all entries need to be permitted. JHSC will continue to discuss after TA is over.

 

90

8/19/09 Carber plugs should not be used for isolation, people have the wrong opinion of these. They hydrotest a weld in a line only outward in the position these are placed. They misrepresent their product, may not be used for isolation: example use the plug as a second valve for a double block and bleed. Need follow-up with personal requesting this style of plugs, stating its capabilities.

 

91

8/19/09 Rick Vogel will inquire of Super Heat responsibilities while their internal combustion engine is running.

92

8/19/09 Are light plants supposed to be shut off when nobody is in the area (breaks etc)? This is not happening.

á      JHSC needs more information on Light Plants and need for at least one person in the area to allow it to be in service.

 

93

8/19/09 22 % LEL to 54% LEL in refinery nitrogen source at P/6, and 100% LEL at some nitrogen drops at P/9. Most likely was happening during inert entry at Plant 6. How ca we have an inert entry where everything is to be blank except the nitrogen source when the nitrogen source in the refinery is not blanked away from high pressure hydrogen.

  • Share near miss with other Sunoco and non-Sunoco sites.
  • Look into the same type of contamination with our steam.
  • Need to be aware of dangers of high CO levels.
  • Suggestion was made to have hydrocarbon analyzers although no action was taken on this.
  •  Recommendation also made to use two trucks for inert entry with the second truck as an egress truck.
  • Also recommended to use hammer blank.
  •  Recognition by JHSC members that they donÕt want to make it difficult for operators to get nitrogen into the system in an emergency.
  •  Areas that were leaking have now been blanked. Need to check nitrogen system every day.
  • Rick Vogel and Jim Hardy will convene an ad hoc committee to review this issue after the TA. They will also obtain information from other refineries on this matter.

 

94

8/19/09 1910.146 OSHA reg, must have 3 dedicated rescue members on site, trained at a minimum on rope rescue. R. Vogel will look into it.

97

8/19/09 Brief discussion of street signage and dead end roads and need for improved signage and names communicated to employees and contractors. R. Vogel agrees and will look into it.

 

Status ?

 

Jan 18, 2008

Inquiries around status of securing road signs identifying names of refinery streets.

Work order has been submitted but it is Priority 4 (housekeeping)

It was noted that all point of work cards reference street names.

Matt will discuss with Heather how this can be moved up. Verify if it is considered safety issue.  No resolution on that during JHSC meeting. (Action Item)

 

98

Crane procedure is not useable. If we follow it, the jobs will be given to the contractors who will do the same thing we are doing, which is against this procedure. Example: percentage of what a crane can lift determines whether it is a critical lift. Know the lift weight before we lift it, nobody knows.

 

June 20, 2007

M. Grimes to work with Mike Rhuland on crane procedures. Need to meet DOT regulations and clarify Sunoco procedures.

99

P/3 operators needed instruction on how to use personal tie-offs. Marc Wilczynski wanted Ken Adams to go down and show them how to use them. Have to know structural strength. He is not a trainer, nor was anybody trained in the shop.              

100

From:          KENDZIERSKI, RENEE S    

WO#08-8264 is to remove an abandon line in highlines south of fresh tank.  Dave Mortland brought this to my attention today as he was up on the fresh tank removing P-8302 - some asbestos is falling off this piping and over the operators walkway.  I asked Korena to look at this and she has made ready for schedule.  Can we move this up on priority or possible make this a safety work order?

 

From:          WEIDMAN, D. S 

Sent:          Thursday, August 27, 2009 2:19 PM

Subject:      RE: Asbestos at fresh tank

 

Renee-

 

There is a standing W/O in place for emergency clean up of any fallen asbestos (W/O 09-000180)

It's a simple matter of contacting your area C/A to have AS&C perform the clean up and encapsulate any loose insulation that has a potential of falling.

 

The removal of the abandoned piping and the balance of the work can be scheduled using the refinery ranking process.

 

Scott Weidman

 

From:          KENDZIERSKI, RENEE S 

Sent:          Thursday, August 27, 2009 2:20 PM

To:              WEIDMAN, D. S; AKINS, COURTNEY L; EISENTRAGER, JAMES P; LEWIS, BEVAN

Subject:      RE: Asbestos at fresh tank

 

Then I would suggest we move this up on the priority list - make it a safety?

 

Does supervision not understand the asbestos policy?

 

The scaffold was put up and asbestos removed.  Thank you!

 

Although this item is complete, I would like to discuss a plan on re-educating personnel on asbestos clean-up and encapsulation when exposed asbestos has fallen.

 

 

101

A general foreman pulled a firewatch away from the job. She was stationed at the ground level. The foreman told the welder that he could be the fire watch when the fitter was grinding and the fitter could be the fire watch during the welding. I butted into the conversation and asked if there was a fire containment. They said yes. Then I asked if both were in the containment. Again the answer was yes. I asked if they were watching the ground area, they said they could not see it from the containment.

 I understand that we strive for 100% containment but it is not guaranteed. Shouldn't the fire watch be on the ground because they can not see or cover the 35 foot radius required?

102

Falling lead base paint in the C-601 structure. 8/28/09

103

 

_____________________________________________

From:          SCHRAMM, JEFFERY J 

Sent:          Sunday, August 30, 2009 8:57 AM

To:              MEREDITH, KEITH A; HUBER, KAREN S; HARDY, JAMES E

Subject:      BENZENE INCINERATOR DILUTION AIR

 

Keith,

 

It has been several months since we have had to "work around" the malfunctioning air dilution controller on the Benzene Incinerator system.  This air dilution controller is designed to provide the correct amount of air to incinerate Benzene vapors at 1600 deg. F. during the loading process. The problem is that the air dilution

controller has an integral part of the control system that "sticks" in the position shutting off air to the Incinerator causing the system to overload with combustible vapors if not caught and corrected in time. To me it is obvious that this presents a dangerous situation. We had an explosion on this system in the early 1990's as a result of an overload of combustibles on this system.  It boggles my mind that this situation has not been corrected yet we continue to load Benzene cars.  From what we are hearing, it is another case of "waiting on parts".  In the meantime, it is my opinion that this system not be used until corrected - it is an accident waiting to happen.

 

Respectfully submitted,

 

Jeff Schramm

 

Jeff,

            After speaking with Keith this morning regarding your concerns with the Benzene Incinerator.  I explained to Keith that we have an extra person available on shift today, so this person can assist with watching the Benzene Incinerator system while we load Benzene today.  Also, Keith stated that he will try to get a instrument person to look into this problem ASAP.  Thanks!

 

Sue

 

Status?

 

104

Safety Shower Alarms

 

During this morning's Safety Audit the green light for the Safety Shower near P-8304 was found to be not lit.  Per operations, the light and the alarm are out of service due to a maintenance related de-energized switch rack.  How is the lack of alarm to the control room being addressed (mitigation, communication, etc.)? 

 

Currently Plant 8 is informing permit receivers of the situation and that the radio will be the communication link to the control room.

This issue sheds light on the refinery-wide problem of lack of alarms to the control rooms when temporary safety showers are employed.  Radio communication is not feasible for operators since they usually work alone.  Past incidents, some of which have resulted in recordable injuries, are evidence that notification to the control room is vital.  I would like this to be resolved through the JHSC, as it covers the entire refinery.  Utilizing our collective knowledge along with industry best practices, I am confident that this problem will be solved. 

 

Lee Chilcote

 

106

M. Lambert

 

During an on-site visit of yesterday's explosion scene at P-501 B, I noticed white caulking around the metal cover (rather what was left of it).  Upon further inspection of the sister pump, P-501 A, I noted orange caulking around its metal cover.  No other pumps in the area seemed to have caulked covers.  What is the rule for this application?  Thank you.

 

Lee Chilcote

107

The last Machine Shop Safety Audit D. Mortland performed, many of the extinguishers have not been inspected since February 2008. According to the OSHA regulation:

Regulations (Standards - 29 CFR) : Portable fire extinguishers. - 1910.157

 

1910.157(e)(3)

The employer shall assure that portable fire extinguishers are subjected to an annual maintenance check. Stored pressure extinguishers do not require an internal examination. The employer shall record the annual maintenance date and retain this record for one year after the last entry or the life of the shell, whichever is less. The record shall be available to the Assistant Secretary upon request.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9811

Should we also be following this OSHA standard?

108

JSA procedure update per G&N. Refer to Company response per G&N, we have the hand out.

 

Jan 18, 2007

  • People are being pulled off work to do other work. Then they need permit and JSA. New employees have not received JSA training so not qualified to write. So someone else has to do. Inconsistency between day and night shifts.  Current procedure allows it. Importance of their being consistency which increases credibility.
  • Intent of JSA was to Òget another set of eyesÓ and review hazards before one starts a job. Perceived as Òtickler—another sheet of paper.Ó Does intent imply who has to do it or just that it gets done?
  • Importance of crafts people being trained on JSA when they come in. No formal training on this now. Training is Òon the jobÓ and therefore minimal.
  • Other concerns regarding JSA: It is more than Òtickler.Ó Requires signature. Important form. Needs to be filled out correctly. Some supervisors have refused to help hourly employees who have asked for assistance with JSA.
  • Night and day issues are reflective of planned and unplanned work. If people are pulled off a job for unplanned work, should have foreman sign off.
  • Noted that contractors have basic JSA and they take operators with them.
  • Purpose of JSA is for people doing the work to go over the hazards first.
  • Does it add value if another person other than the craftsman or operator reviews the JSA?
  • Any steps which make work safer add benefit.
  • Does the JSA need to be redone if work conditions change?
  • Is it sufficient to follow the nighttime procedures whereby the person getting the permit and the person issuing the permit are adequate?
  • (Action Item) Review procedure for consistency.

109

12 pack contractor air cylinders are stored (stacked) at gate #6 chemical, with Baker chemicals and others. Created dangerous area which T&T are trying to maneuver in.

112

Opening Refinery Sewers 1 GS XXX 5 person turned in suggestions for changes to this procedure on 06/15/09.

113

Abrasive Blasting 1 MS 510 5 person turned in suggestions for changes to this procedure on 06/15/09.

114

Aerial Work Platforms 1 MS 516 5 person turned in suggestions for changes to this procedure on 06/15/09.

116

Bonding and Grounding 1 GS 131  5 person turned in suggestions for changes to this procedure on 06/15/09.

117

Carbon Dioxide 1 HC 607 5 person turned in suggestions for changes to this procedure on 06/15/09.

118

Electrical Heating Tape/Tracing 1 MS 503 5 person turned in suggestions for changes to this procedure on 06/15/09.

119

Equipment Service Tag  1 GS 147 5 person turned in suggestions for changes to this procedure on 06/15/09.

120

Fire Equipment and Systems 1 FS 301 5 person turned in suggestions for changes to this procedure on 06/15/09.

Jim,

 

Attached is one of the reviewed safety procedures. I have incorporated suggested changes unless otherwise indicated. Also, I have replied to questions that were forwarded. Let me know if you would prefer to discuss face to face. Once we agree, I will post.

 

Regards,

Rick

 

Rick,

 

Safety Rep from the Fire Marshals brought it up, I will follow-up with the Rep to see if he was spoken to.

 

Jim

121

Flare System 1 GS 135 5 person turned in suggestions for changes to this procedure on 06/15/09.

Jim,

 

Attached is review of the Flare System safety policy. I have included answers to the questions forwarded. I would like to discuss the items concerning liquid in the system, as I am not following the point(s) being made.

 

Regards,

Rick.

 

122

Forklifts 1 MS 508 5 person turned in suggestions for changes to this procedure on 06/15/09.

123

Hazardous Materials Tank Delivery 1 HC 603 5 person turned in suggestions for changes to this procedure on 06/15/09.

124

Hydrogen Sulfide 1 HC 613 5 person turned in suggestions for changes to this procedure on 06/15/09.

125

Hydrostatic Testing Equipment 1 MS 511 5 person turned in suggestions for changes to this procedure on 06/15/09.

126

Incident Investigation 1 PS 205 5 person turned in suggestions for changes to this procedure on 06/15/09.

127

Iron Sulfide 1 HC 621 5 person turned in suggestions for changes to this procedure on 06/15/09.

128

Management of Change/PSSR 1 PS 200 5 person turned in suggestions for changes to this procedure on 06/15/09.

129

Nickel Carbonyl 1 HC 615 5 person turned in suggestions for changes to this procedure on 06/15/09.

130

Nitrogen 1 HC 625  5 person turned in suggestions for changes to this procedure on 06/15/09.

131

Personnel Platforms 1 MS 501 5 person turned in suggestions for changes to this procedure on 06/15/09.

132

Respiratory Protection 1 GS 113 5 person turned in suggestions for changes to this procedure on 06/15/09.

133

Ropes and Slings (Chokers) 1 MS 502 5 person turned in suggestions for changes to this procedure on 06/15/09.

134

Rotating Equipment 1 GS 118 5 person turned in suggestions for changes to this procedure on 06/15/09.

135

Safety Valves 1 GS 140 5 person turned in suggestions for changes to this procedure on 06/15/09.

136

Sandblasting Tanks 1 MS 507 5 person turned in suggestions for changes to this procedure on 06/15/09.

137

Scaffolds 1 MS 509 5 person turned in suggestions for changes to this procedure on 06/15/09.

138

Sewer Covering 1 GS 126 5 person turned in suggestions for changes to this procedure on 06/15/09.

139

Smoking 1 GS 102 5 person turned in suggestions for changes to this procedure on 06/15/09.

140

To Open Equipment 1 GS 143 5 person turned in suggestions for changes to this procedure on 06/15/09.

141

Variance to Safety Procedures 1 GS 137 5 person turned in suggestions for changes to this procedure on 06/15/09.

142

Ammonia Tank at P/2 has three NH3 sensors which activate a blue light. DoesnÕt a blue light indicate hydrocarbon. If we gas test our way into the blue lighted area our MSAÕs will not pick up NH3

 

Tom Lada,

 

I noticed there are no fire extinguishers mounted in the new area in addition to the monitors, has the fire marshall evaluated this area yet?

 

Also, no SCBA equipment for escape in the event of an ammonia mishap/emergency, nor is there a PPE locker near any of the ammonia handling, sampling areas. Also, as none of the ammonia area alarms come into the control room indicating there is a problem. Not sure about the safety showers either.

 

When will the procedures be posted and approved for the new area?

 

These items should be in place prior to starting the unit.

 

 

Status?

 

Tom,

 

We had a leak on the ammonia tank in the scrubber last night, it had been coming in to the TDC for 9 hours prior to that point. Why did we fill the ammonia tank with 2 of the 5 ammonia leak sensors not working? We were able to locate and stop the leak. I filed a FFF on the events last night. Did we follow a start up checklist before we filled that tank to inspect all the area leak detectors? The instrument shop reported that while troubleshooting the area alarms several strobe lights have been disconnected from the power source. We can not operate like this when placing the new equipment in service that system is live and we need and MOC to cover operations in the ammonia offloading area until the area panels can all be checked for operation without any switches turned off or wires disconnected. The other big piece of this is we had no Draeger tubes nor detectors available to use in our new area for checking the possible leaks. Chris Conley got us some last night but we should have had these before we loaded the tank in my opinion.

No Ammonia sensors on MSA?

No training on ammonia prior to filling tank?

Alarms not properly responded to?

Audiable alarm shut off because someone figured it was false and instructed crew to smell around on their rounds? Area not barricaded off and no restrictions on permits during this time.

The analyzers are smart analyzers. Lets you know if they are out of calibration, or if power is interrupted or any other malfunction. The alarms were true and the hourly followed supervision lead. Believe the exposure/PPE is something like 50 ppm – full face respirator, over 50 is fresh air and 300 ppm is IDLH. No MSA to test your way into area.

143

Showers are running cold   A couple of days there have been problems with Operations shutting off steam (during T/A) without any notification. Also, Campbell is replacing some mixing valves, tentatively scheduled for 10/10/09.

 

Note: The notification to shut off the 170# steam jumpover to the 60# steam during the T/A came from the F.S.S. P/6 told him that it was supplying the steam for the showers, but he was adamant that it did not and we were to shut it off.

 

 

Has the duct work been cleaned  Campbell checked the ductwork, determined that it wasnÕt dirty, did clean the supply and return grills.

145

Tom,

Subject: Leak detection systems inoperable or bypassed without MOC in Plant 2
I entered this in the log last night:

HES: Ammonia leak detectors do not work at the following: Ammonia skid 23025A (near hoppers), Ammonia Forwarding pump skid 23025B, #21550/21552 CO detectors East of control room do not work as they are bypassed and there is no MOC for any of these detectors.

I checked the area with the new detector provide to us. Recommend work in these areas be checked prior to entry. Recommend work in these areas be postponed until detectors are repaired or MOC is in place. Also, no alarm came into control room during testing.

Thanks,
Greg


From: CUADRADO, ADA L
Sent:
Wed 9/30/2009 10:22 PM
To:
THOMAS, GREGORY M

Greg as always we appreciate you bringing these issues to our attention for prompt resolution.  Here is the information we have from the E&I folks regarding your concerns
1.  Ammonia analyzers - these analyzers and probes are fully functional.  What this means is that in the event of a release the probes will detect the ammonia and alarm in the control room.  However there is a manual function to test the alarms that is not working.  According to E&I inspite of this they were able to test them and they have ensured us are fully functional.  There are some instrument techs in the refinery for s/u coverage and they have been sent to verify tonight.
2. These CO analyzers were wired incorrectly by the project group.  This was caught as part of our unit walkdowns.  Since then the wiring has been fixed.  The analyzers are functional but need to be calibrated.  Acccording to the instrument techs the cal gas will arrive tomorrow. 
A temp MOC will be entered by the FSS tonight to cover this.
Again thank you for bringing these issues to our attention. 

 

Ada Cuadrado

 

Ada,

 

It is my understanding that this issue is not resolved, no one came down to calibrate the CO detectors yesterday. Additionally, the emergency MOC in the plant is incomplete as there is no MOC champion, environmental, and Health & Safety review. According to 1 PS-200 the procedure governing MOCs any emergency MOC issued must go through the full review process after the fact. If you need anything from my end I will be in the plant today. We need a valid MOC as soon as possible.

 

Thanks for time,

Greg

 

Greg Thomas

 

MOC is complete.

 

As you were informed today the CO analyzers will be calibrated tomorrow.  OT has been set up for this to happen.

 

Thanks.

 

Ada

Why are the hourly constantly reminding supervision when an MOC is required and also ones that are not properly filled out? Should we start filling out FFF when we are operating without a required MOC.

To what extent have our Fire, Rescue and HAZMAT personnel been trained for dealing with anhydrous ammonia? 

146

Maintenance Safety Reps participating in the Monthly Safety Audits in their Area 10.28.09

The Shop Safety Reps should be participating in the Audits from now on.

148

During our Safety Reps meeting yesterday an issue was brought to our attention concerning the contract workforce. Apparently there have been some rental cranes, in particular there have been "carry-deck" cranes with open ROPS with no Load Moment Indicators and possibly no anti two block devices. These machines have been used in the refinery and the tank farm by the contract workforce. The concern raised is that we may be placing these contract workers in harms way without these devices. The Load Moment Indicator or the "crane computer" as it is sometimes referred to, informs the operator if the machine is near it's allowable capacity, protecting operator and other workers from potential machine failure. The anti two block device prevents the block from getting pulled into the boom and causing major damage. All of the Sun cranes have anti two block and load moment indicators and our concern is that we are not affording the contract work force similar protections. When a contract crane operator was asked how did he know if a weight was incorrectly calculated and overloaded without an LMI he responded the rear wheels will begin to lift off the ground. How can we protect all personnel within the refinery, could we possibly only allow rental cranes with Anti two block devices and LMI into the refinery?

  Are  the contractors knowledgeable of the Sun procedures Cranes - 1 MS 515  and Lifting 1 GS 125   ? 

149

The lighting in the 6 and 7-Track area has not been repaired. With the footing being treacherous in that area, we should make this a safety priority item. 

150

Expiration dates for the chemical transfer hoses. 

The Green Book mentions 2-year limits for "hoses", but not sure this applies to

our type of "transfer" hoses.  I'm thinking the hose manufacturer may have some

Recommendations, but I can't find that info in my files. For some reason, we were

asked to apply stickers to these hoses back in 2006 and put the date on the sticker,

but I'm not sure what this date is supposed to reference or what is the significance. 

151

Present practice of allowing anyone to write safe work permits at the Marine Terminal and Hocking Valley Dock. This may be somehow related to the fact that we do not have Electronic permit capability at the MT and HVD. At the Railroad, where we do have Electronic permitting, only the Rack Leader may issue permits.  In the Refinery, folks must be Chief Qualified to issue permits. 

152

None of the land line phones work in the Shanties and the radio's have a lot of interference and "bleed" from other plants at the RR for some reason.  There are also issues with the radio communication at the Dock and Marine Terminal where we have antiquated radios and have to be standing in certain areas to be able to communicate. Action?

153

Speed bumps at plant 9

            I have not been able to determine the department that installed them. (It was not the T/A group.) As soon as I find out, I will let you know.

 

Plant Protection installed the P/9 speed bumps due to complaints of contractors speeding and causing safety concerns by P/9 operators and other Sunoco personnel. The peak of the complaints was during the ramp up to the T/A and prior to the speed bumps being installed. Very few complaints after the speed bumps and some random patrols.

 

Thye complants about the speed bumps in place is that an ambalance leaving the refinery has to come to a dead stop and slowing roll over the speed bump.

 

Also it is hard on the T&T equipment to come to a complete stop and slowly roll over these bumps.

154

Who is the Sun Carpenter contact when an engineered scaffold is required?

            The Carpenters can contact their supervisor who in turn will notify the Engineering Department. Pass this information on to the safety reps.

156

Poor lighting and flashing lights at T&S R/R track. ¾ of the tracks have cars with some parked right up to the crossing and can not see if an engine is connected or can not see if one is moving because of the impaired vision with some parked up to the crossing.

            The switching crews on the Railroad use a remote device to activate the flashing lights. They are in working order. If there is an instance of these lights not being activated as required, it should be reported at once and  FFF should be generated.

            Temporary lighting has been added to the south end of the benzene loading rack and additional light plants can be requested and            delivered. The OP should be contacted if light plants are needed. A more long term solution will be implemented after the 3 mens building is demolished. New light poles are scheduled to be installed for permanent lighting in this area. Pass this information on to the safety reps.

157

Loaded fork lifts on public roads.

            Fork lifts can be driven on the public road as long as they are un-loaded and have a slow moving vehicle sign attached at rear.

            If fork lifts are seen on the public road carrying a load, it should be reported at once and  FFF should be generated. Pass this information on to the safety reps.

158

Foliage at R/R tracks & Pickle Road.

            J. Utendorf will inspect and contact the proper vendor for trimming as needed.

Status

159

Want to discuss Plant 9 personnel vacating P/9 locker room across from the control room & contractors being able to work in the buildings in the same area.

160

Bushings in place on pumps not up to SunÕs standards. Currently zone operators are to check all pumps and sign off for each pump that these types of bushings are not in place. Some are painted blue with the rest of the tubing and easy to miss. Worried about the sign-off also because all have not been trained on this type of substandard bushing.

161

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Safety Issues – Final Answer or OSHA Investigating

REDUCE SAFETY BACKLOG: 4/15/09

 

JHSC reviewed safety work orders. Language changes agreed upon in steps to reduce safety backlog  as follows:

    • Divide safety work orders by areas of Safety specialists. [done]
    • Safety specialist will make sure that safety work orders are indeed safety related
    • Safety specialists will advise as how the safety issue can be truly mitigated, if possible, (recommendation made for specialist to do this first before even entering work order as safety—Rick Vogel to address this), and removed from the safety work order list. 
    • Safety specialist meets with ABTsÕ to push to get overdue safety work completed.
    • Safety Specialist will judge whether safety part of work is completed in such a way as to take off the safety work order list.
    • Decide as a JHSC on a reasonable complete date for the few safety work orders that cannot possibly be completed by matrix time. Example – ordering a hydrant.
    • Secure commitment to get future safety work orders completed by end due date.

 05/20/09 Complete

  • Completed work items have been taken off the list. Safety specialists have been trained and can now access TeamWork (TW) after proper reviews with the ABTs before removing.

 

WHO CAN TAKE OFF RED LOCKS AFTER BEING DE-COMISSIONED. 4/15/09

á      Under Area Manager Authority, Operator will BE instructed to remove. This change will be added to the lock out/tag out procedure, but has not been done yet.

 

JHSC agreed that red locks are used for decommissioning equipment and an MOC is required to put locks on and to remove. It was noted that out of service items must be reviewed by the Area Superintendent and not the Area Manager.

 

Communicating Changes to HES Policies and Procedures should be followed for informing employees of the required MOC.

 

Lock-Out/tag-Out Procedure updated stating:

Note: An MOC will be required prior to removing O.O.S. locks and/or re-commissioning O.O.S. equipment. 05/20/09 Complete

  • Jack Parsil, Sean Cornett and the ABTs have signed off on using red locks for decommissioning equipment. Five-man need to review and sign off. Also, Lee Chilcote needs to do the same.

 

UPDATE ON LUBE MIST IH EVALUATION – ALSO INCLUDE UNIT MECHANICS, AND MARLIN ROUNDS. 3/25/09

Lube Mist Industrial Hygiene Evaluation – Eric Fannin

á      Plant 3 is where the sampling will begin, and move to other plants (based on findings).  Eric walked the Plant 3 areas with Jim Bettencourt. Eric set up monitors and sent out samples; however these samples were invalid and need to be redone. Sampling will be done again now and in warmer summer weather. Sampling will include 8-hour TWA area samples and personal samples on Operators during Marlin rounds, Unit Mechanics and Vibes personnel (as necessary). 

á      First round will be done in 30 days and Eric will report back to JHSC in May.

á      If samples show over-exposure, corrective action needs to be done immediately. Engineering is aware of this.

 

Notification of Exposure Monitoring Results: LubriMist System Exposure Monitoring Campaign #:X4EF090004

 

Supervisor: Please post a copy of this report for review by anyone who may perform the same tasks as those sampled.  

 

No actions required to be taken as a result of this Industrial Hygiene Survey. All exposures were below the established Sonoco Occupational Exposure Limit (SOEL)

 

Another round of LubriMist sampling will be completed during the peak summer months, and will include both area and personnel sampling.

 

PLANT 2 CLAMP – GET ENGINEERING (OSHA INVESTIGATING) 3/25/09

SCHLINDER, PROCESS TO DECIDE WHAT TYPE OF CLAMP TO BE USED.

HAS THERE BEEN X-RAY FOR STRESS?

NOW WE HAVE CONTROL OF THE LEAK, WHY DONÕT WE FIX IT BEFORE IT LEAKS AGAIN AND PUTS US BACK IN AN UNSAFE CONDITION?

  • Plant 2 wet gas leak clamp: Inspections and monitoring should continue until permanent fix is in place. Until line is replaced, suggestion made for installation of H2S and hydrocarbon permanent monitors. Rick will discuss with Sean Cornett and Jack Parsil.
  • Informed that we are not following schedule of monitoring.
  • Furnmanite clamp ordered.
  • 4/16/09 OSHA visit on complaints.

 

Furmanite box at Plant 2 supported by scaffolding framework. Has this been engineered to be the proper support? MOC for clamp, do we need an MOC for bracing?

 

Has been engineered to give proper support with structural scaffolding. per K. Schlinder. 05/20/09

 

VARIANCES ON INTRANET  4/15/09

  • R. Vogel will also ensure that current variances are listed on the Health & Safety page on Sunoco@work.
  • Will also include ÒOpening Equipment Above 20% of the LELÓ 

 

Page 3: Safety Procedure Variances, Live Flare Preview Meetings and work on equipment above 20% LEL are being posted electronically on the refinery public drive.

5/20/09 Complete

E-IDENTIFICATION BADGES, HOW CAN THEY RECEIVE PERMITS? 4/15/09

By the Green Book they have to be escorted in order to receive a permit, but we feel this is wrong without any training or not having the ability to pass the test.

 

The 5 person was misinformed. There is training and a test that these contractors have to pass. Both training and test was shown to joint committee. 5/20/09 Complete

 

MORNING OIL FLOW MEETING: 4/15/09

No action items, since 1st of year, has been entered into a spread sheet.

 

It was determined in the Oil Flow meeting that items that are not TOP (generally reliability items) will be tracked on an Excel spreadsheet and posted on the Health & Safety drive. Marilyn Rossnagel will administer this. Trina James, Marilyn and Rick will all be trained and have access to this site.

Action items being entered on ex-cel spread sheet. 05/20/09 Complete

TOPPS 4/15/09

No action items since March of 2009 have been entered into the E-Cat system.

 

TOP Rep will be trained on E-Cat system when she gets back from vacation. Will start entering action items from TOP investigations to fill the void since OMES stopped functioning in this capacity.  Trina James, Marilyn and Rick will all be trained and have access to this site.

  • TOP Action items are up to date and entered in E-cat. Trina James, TOP Coordinator, will begin entering action items from TOP investigations.

 

05/20/09 Complete

FIRE HYDRANTS 4/15/09

Hydrants and parts may take up to 6 weeks to be delivered once ordered. Can not order until hydrant gets on the scope and is dug up. After it is dug up a measurement is taken so parts can be ordered.

  • Why canÕt the priority be moved up to dig it up so the parts can get ordered sooner? Done.
  • Why canÕt we stock 5Õ & 51/2Õ hydrants since a lot of them fit those measurements? Done.
  • Why canÕt we stock fittings for the hydrants? They are now stocked.

 

Update: Approval to put several lengths of hydrants in storehouse.

Storehouse would not give us the one in stock because one is ordered for the job. Planners have to buy the one in stock.

 

Storehouse personnel will release the one in stock.

Most hydrants depth can be calculated to order hydrants before digging and will be done now. Just because a hydrant is out of service does not have to be worked on as safety if proven we have enough coverage with existing hydrants or monitors. Determination to be made by fire department.

 

05/20/09 Complete

When inside of the radiation ropes, the signs are blank on that side. Something should be written to let them know they are on the wrong side and weighted signs should be used so the signs will not turn on a windy day.

 

Need signs are to be added that can be viewed from either side of radiation rope. Example of new signs was shown to joint at meeting that is going to be used now.

 Complete 05/20/08

Bee Bopper Spray no longer at safety store. Maintenance workers were told by Linda she was instructed not to supply it anymore? Mechanics get jobs where there are wasp nests.

Complete 5/20/09

 

Bee Bopper Spray is available at the safety store and can be obtained with supervisor approval.

Completed 5/20/09

 

COMMINICATING CHANGES OF THE H&S PROCEDURES. PROCEDURE 1 HSS 106 NEEDS TO BE FOLLOWED REGARDING UPDATED TRAINING TO GREEN BOOK. 5/20/09

 

Rick Vogel says he is aware of this and it will be followed.

Awareness Completed

CUTTING OFF A CRAFT LOCK (TURNOVER LOCK) – NOT A PERSONAL CRAFT LOCK – WITHOUT A WALKDOWN. 4/15/09 (OSHA Investigating a specific lock that was cut off, but we want to address the practice in general.)

 

Safe work permit should not be closed out, need name of person walking down the job to close out permit.

Company views it as acceptable after a phone conversation and walkdown by any supervisor including operations.

Completed 9/23/09

P/2 catalyst dust went into bystander (mechanics) eye when Operations was dumping the catalyst. (OSHA Investigating)

PLANT 2 CLAMP – GET ENGINEERING (OSHA INVESTIGATING) 3/25/09

SCHLINDER, PROCESS TO DECIDE WHAT TYPE OF CLAMP TO BE USED.

HAS THERE BEEN X-RAY FOR STRESS?

NOW WE HAVE CONTROL OF THE LEAK, WHY DONÕT WE FIX IT BEFORE IT LEAKS AGAIN AND PUTS US BACK IN AN UNSAFE CONDITION?

  • Plant 2 wet gas leak clamp: Inspections and monitoring should continue until permanent fix is in place. Until line is replaced, suggestion made for installation of H2S and hydrocarbon permanent monitors. Rick will discuss with Sean Cornett and Jack Parsil.
  • Informed that we are not following schedule of monitoring.
  • Furnmanite clamp ordered.
  • 4/16/09 OSHA visits on complaints.

 

Furmanite box at Plant 2 supported by scaffolding framework. Has this been engineered to be the proper support? MOC for clamp, do we need an MOC for bracing?

 

Has been engineered to give proper support with structural scaffolding. per K. Schlinder.  Complete 05/20/09

 

Safety Showers

Railroad safety shower. It's one of those fancy, walk-in types. It worked

a few months until it's first winter then froze and broke internal piping and valves.  The attempts made to repair have been fruitless including: not having parts, getting the wrong parts, the parts not being the only things broken, craft key being removed with repair not made, back to "square one" with repairs (like nothing had ever been fixed, etc. This has been going on since the winter holidays - and still no safety shower. 

We had a portable which was taken away two months ago because Plant 9 needed it more than we did.  So, we went without a portable for over a month and didn't get that one until bringing it up at several safety meetings.  Now we're waiting on parts - AGAIN!  And they are acting like it's a new problem (remember, they never fixed the original ones!). 5/20/09

 

 

The latest example deals with the same planner coming down to "once again (multitude of times)" look over the job about a week ago and asked "where the safety shower was".

 

Safety shower is in service and working.

 

Safety shower alarm works locally in field, but does not alarm at security office. Truck drivers may have to use during off shifts. 7/1/09

Safety Shower at RR appears to be OK now and it alarms up at Gate 1 as originally designed.

 

From:                        ZAVALNEY, GARY P 

Sent:                          Thursday, July 16, 2009 11:08 AM

To:                              COLUMBUS, JAMES A; MEREDITH, KEITH A; BRUGGER, JOSHUA W

Cc:                              LOPEZ, THOMAS J

Subject:                    R/R safety shower

 

 

            Al can you pleas have the electricians look at the railroad safety shower.  There is a work order # 9-915 that can have some time added to it.  The problems are:

 

                        Red and Green lights

                        Does not alarm in the guard shack (could be instrument shop)

                        Check and see if heater/thermostat is working (could be instrument shop)

 

            If there is a new work order needed please let me know and I will get one in. 

 

            Tom, on your other question on the N2 regulator, operations did try to adjust it. 

 

                                                                                                                                                GPZ

Work Completed 08/02/09

Fix the line going to the lab, so that the trench can be backfilled. Another chunk of asphalt fell into the trench as it is getting more unstable for passing traffic. 5/20/09

 

Maintenance is ready to go, job is planned, line needs to be shutdown for repair.

Work Completed 09/02/09

Fix the line going to the lab, so that the trench can be backfilled. Another chunk of asphalt fell into the trench as it is getting more unstable for passing traffic. 5/20/09

 

Maintenance is ready to go, job is planned, line needs to be shutdown for repair.

Work Completed 09/02/09

SAFETY SHOWERS, GET PARTS ON STOCK AT SAFETY STORE. 3/25/09

  • Rick Vogel met with Mark Lambert and the refinery currently does not have temporary showers that are applicable for our needs. Need to insure that we have set up that is intrinsically safe. We need to check other options and gather some quotes. Rick Vogel will work with Materials Management to do this. Conversations with Encon and Hagemeyer to check their feasibility to provide appropriate equipment—we donÕt always have right parts in stock. Need to pull together our records of past orders for review. Rick Vogel will also work with Materials Management to initiate a process for better recordkeeping and tracking of parts. Also need to consider vendor managing the inventory of parts.

Complete 9/23/09

Safety Shower

Plant 9-5 needs another portable safety shower. Since they dug a trench for repair of two showers, not able to access portable from one side without a long walk around trench. Either add another shower or build a ramp across trench. Caustic area. 7/1/09

Work Complete 9/23/09

Check on procedure for lab bombs. Appears either the procedure needs changing or if adequate, need further training. 7/1/09

Work Completed 09/02/09.

We tried to get them to replace in kind or repair the air compressor in storehouse #1. That's been going on for several months. 5/20/09

 

We don't feel safe driving a small crane through a bunch of semi's ( sometimes it's just wait until they are finished before you proceed) with a restricted view because of some high pressure oxygen cylinders hanging in our way. We even looked up how much it would cost to replace the existing compressor, one that has all the bells and whistles. It was only 15 K. Pointing out that maintenance was abusing a compressor at the firehouse that was meant to be used for filling SCUBA packs not 6 packs and that when it is ruined the firehouse will need a new compressor as well for emergencies.

 

Sean's response was to follow us over with one on the hook. The gate was open at the terminal there were no trucks in the area and this was more a matter of inconvenience not safety.

 

FEL to put in new air compressor at storehouse has not been started yet.

If the air compressor at fire house goes bad, back up plan is to rent an air compressor.

 

Have copy of FEL draft presentation from 2/12/2009  project championed by Philip Wojcinski & Keith Nelson.

 

Rick Vogel gave some background and is reviewing information that Keith Nelson had prepared.

Six pack sets are currently Health and Safety departmentÕs responsibility. 12 sets need to be tested in 2009. Six packs need to be certified (hydro tested every five years).

 

Also, Rick Vogel will follow up with Sean Cornett regarding transport issues due to concerns of blocked vision when maneuvering around trucks at sales building.

Intent is to develop a plan which would include contingencies—e.g. rentals, shelf life of current compressors.

Discuss with Business Improvement Initiative Task Force the feasibility of new building instead of firehouse for compressors.

 

Report back to resolve transportation problem.

Additional discussion around compressors, 6-packs, and general hauling of bottles needs further review with employees in Truck & Tractor and any available JHSC members. Also need to review manuals. Rick Vogel to keep all posted on meeting time.

 

Company position is that T&T can load on a truck to transport.

09/02/09.

ONCE A DOUBLE SEAL FAILS, IT IS CONTAINED FROM THE ATMOSPHERE, SO IT DOES NOT GET FIXED IN A TIMELY MANNER. 5/20/09

Concerned about safe siting when double seals are thought to be in place.

 

Company states they will get these fixed in a timely manner, that letting them go is not acceptable.

Complete 9/23/09

Non engineered or certified carts containing the Fresh air 6 packs that we haul back and forth to the firehouse through the truck traffic to the firehouse. 5/20/09

According to Truck & Transfer personnel, carts are Sunoco made with no weight specifications and are not stamped.

Rick Vogel will report back about the homemade frames packaging the bottles.

Verify if OSHA has standard regarding transport of gas cylinders.

Should these be on a P.M, schedule? All threads that go through the bottom.

Company response is that these are inspected along with the bottles.

Completed 9/23/09

Standby Training for operators. Standbys are supposed to be trained annually? Usually plant operators get trained just prior to a shutdown.  05/20/08

 

Rick Vogel will look into it. If so, it will be addressed after the posting for a shutdown trainer. Has this happened?

 

Per R. Vogel – Operations is qualified through the CBTÕs.

 

Sun policy has been that only a sun person can be a standby for an hourly Sun entrant and only first class Sun standby on that craft can be a standby for a craftman in fresh air entry. Is this still our policy? Read below to understand why this is important to us.

 

Lessons Learned:

The following is a list highlighting concerns found with Confined Space Hole Watches:

Radio Use:

  • Attendants are walking over each other, not taking turns on the radio, making it difficult to discern communication.
  • Not talking clearly or slow enough to comprehend.
  • Not remaining on HW1 channel.
  • Using the radio to communicate other issues i.e. work not related to hole watch.
  • HORSEPLAY – mocking other traffic, playing/keying on the mic, playing songs over the radio, cursing, inappropriate language, etc.
  • Calling into the Hole Watch Supervisor for the time.

 

Hole Watch must clearly state their name (not nicknames), the location PER THE PREPLAN, and simply whether the space is ACTIVE or CLEAR.

 

 

Documentation:

  • Use first and last names, not nicknames or initials.
  • Entry Supervisor is Deb Harris, Scott Hinebaugh, or designee, not your foreman.

 

MUST DOÕS:

  • Include badge numbers of entrants and attendant.
  • Keep ACCURATE on/off duty time as well as Safe Work Permit time (Issued/Expiration) with your own time piece.
  • Include all information of top of page on any subsequent pages (if multiple pages are used).

 

Other issues:

  • Do not just leave the HW bucket until equipment is checked back in.
  • Get your STA and Safe Work Permit out before turning the paperwork in.
  • Do not leave continuous gas monitor in the confined space and expect others to retrieve it.
  • Please notify the Hole Watch Supervisor (Deb and/or Scott) if your company is working between shifts so there is coverage.
  • Please notify the Hole Watch Supervisor (Deb and/or Scott) if you are relieving someone from duty so they know who is on duty at all times.

 

Confined Space Hole Watch duties are safety – critical responsibilities that are governed by OSHA – take them seriously! 

 

Sun policy has been that only a sun hourly person can be a standby for an hourly Sun entrant and only first class Sun standby on that craft can be a standby for a craftman in fresh air entry. The company will verbally agree to this, nothing in writing. But they also added that this will be the norm, leaving the door open for exceptions. Complete 9/23/09

Removing Blind Flanges from Bottom Nozzles or Man-ways 1 MS 506 5 person turned in suggestions for changes to this procedure on 06/15/09

Jim,

 

Attached is the Blind Flange Removal procedure. I agree that this is not appropriate, will mark as obsolete and remove from our safety policies.

 

Regards,

Rick

Complete 11/09/09

Barricading Procedure – Rick Vogel distributed to JHSC. Members should review it and send comments to Rick and/or Jim. 5/20/09

Procedure sent back to R. Vogel with recommended changes.

-       10.15.09 November update

Jim,

 

Attached is the proposed barricading procedure. I made slight changes to the tag section to designate red tags for danger and yellow tags for caution. I removed the verbiage designating the tag shapes because contractors don't necessarily have the octagon or triangle shapes, and I don't think the shapes are as critical as the information contained. I am ready to post and train. Let me know your thoughts.

 

Regards,

Rick.

Complete 11/09/09

TOTE CONTAINMENTS NOT BEING DRAINED. 4/15/09

á      Containments around outdoor transformers. A&I foreman said they have all containments that are around their transformers on a list to be checked out after any rains and have PSC pump them down. Those from the shop say that is not true.  Scott Weidman to find out if these are on a PM list.

á      Find out who is responsible to keep them pumped down.

á      There are some that has not shown any level throughout the year. Must have a leaking containment that needs to be replaced.

á      How much after they fill up with rain water before it becomes a spill?

á      Get list for next joint meeting of containments and include ones that leak.

 

Containments are not being drained in timely way.

JHSC members expressed consensus for keeping oil drums in a central location with a secondary containment for chemicals.

Question to Scott Weidman as to whether totes could get a generic asset number.

Several options were discussed including having operators check the totes during their rounds and then tell OPs of status. Question as to whether PSC could drain out. One suggested recommendation was to add this to operator check list. Second suggested recommendation is for PSC to check the drains every time it rains. Operator could still informally check them out on their rounds.

Action Item: Rick Vogel will ask Elaine Moore if this can be included with the weekly pump seal document.

 

 

Plant 4 containments:

á      Containment for Baker Chemical BPB59470, located north end of East Side structure, is one-third full of liquid (water?).

á      3 containers North of old eastside control room.

á      1 container East of old Westside control room

á      1 West end of cooling tower.

 

Plant 6 containments:

á      2 barrel containments West of R-606.

 

Plant 8 containments:

á      1 in the Kellogg

á      2 in the DIB

á      3 north of switch room. (1 is not in use)

 

Plant 9 containments:

á      Three are located north of R-9102.

á      One is located south of P-9202.

á      One is located NW of H-9101.

á      Six are located in courtyard adjacent to H-9251 (across from Cooling Tower).

 

Tank Farm containments:

á        Northwest corner of #2 tank farm by railroad tracks.

 

Further discussion on tote containments which are not being drained in timely way. Although inspecting them is currently on monthly environmental audit, R. Vogel will make a recommendation from the JHSC to Operations that regularly checking containments and especially after rainfall be added to the weekend list as part of operator rounds. Procedure currently states that the OP advises the CA to contact PSC to drain containments during week.

 

Will be on standing orders; Rick Vogel to discuss with OPs by 9/30/09.

-Placed in standing oreders to OPÕs from Rick Vogel 10.16.09

 

Below is the verbiage added to the plant Operating Instructions per our request:

 

On weekend rounds or after heavy rains - check all secondary containments (permanent and temporary) around chemical totes, oil storage, etc., for accumulated water/material. Notify OP via log book and/or voice mail of any excess accumulation. OP will arrange for removal of the accumulated material.

Complete 11/09/09

NON ASBESTOS PROCEDURE NOT BEING FOLLOWED ANYWHERE IN THE REFINERY, HAS BEEN A PROCEDURE SINCE 2003: Brought to R. Vogel & M. Grimes attention on Oct 2008, and 4/15/09

R. Vogel: I asked Eric Fannin to research this during one of our breaks and I included a copy of his notes and findings. The corporate standard (also included) was revised and Matt Grimes had an action item to update the Toledo procedure. The item was transferred to Eric and given a 9/09 due date to complete. Eric has noted some of the changes coming. There are some requirements on indoor work vs. outdoor. There are PPE requirements as well, but they depend on the type of insulation and application (i.e., hand cutting vs power cutting). It appears our procedure does not provide the guidance, but just went worse case and vague ("where practical"). I have asked Eric to move the revision process up on his priority list.

 

Procedure was updated in corporate procedures and Eric Fannin is reviewing on the local level with the intent to complete prior to the Turnaround.

 

However, concern that our carpenters are unable to follow the 2003 procedure due to lack of necessary equipment has increased urgency of addressing. In addition, concern that non asbestos procedure is not being followed anywhere. Jim & Rick have agreed that this procedure needs to be changed soon.  Jim requests it happens before the next safety reps meeting.

 

á      Need updated draft procedure finalized.

á      Training needs per Procedure 1 HSS 106 regarding this updated procedure when completed.

 

Rick Vogel will distribute to JHSC this week. 6/17/09.

Rick Vogel distributed to JHSC. 7/22/09. 5 person reviewing.

 

Donny Tuit & I met with Rick Vogel to cover the Man Made Mineral Fibers (MMMF)) Draft procedure and the items we asked to have changed. The dry masonry piece was the big item, the masonry material will be added to the definition area. One outcome of this was, as Donny pointed out, was that currently the Combined craft shop cuts MMMF based insulation pieces on a powered band saw in the middle of the shop with no wetting or HEPA vacuum system. Rick ordered the saw to be locked out until the incorporation of HEPA vacuum is added. Concern is that we also need to protect the Advanced & Brand insulators in the same way and to have their saws locked out until we can verify that these pieces are compliant to the new MMMF Safety standard.

Their saw is unusable; they cut everything by hand per R. Vogel.

 

Man-made Mineral Fibers (MMMF) Procedure is ready to be published by October 31. Dave Mortland to review with combined crafts prior to being published.

 

 

From:      LEY, TOMMY B 

Sent:        Friday, October 16, 2009 6:37 AM

To:            VOGEL JR, RICHARD F; FANNIN, ERIC E; WEIDMAN, D. S; MORTLAND, DAVID H

Cc:            PETERS, KEVIN S

Subject:  Emailing: 16006

 

is the system that caught my eye.  With no monitoring information, I don't know what we are up against.  According to the meeting we had on the 15th, this is what I have been told to order.

 

Kevin, what do I need to get this ordered?

 

Thanks

 

- 10.20.09 Tommy Ley purchased HEPA vacuum /machine hooked to band saw

 

All,

Thursday, 15 October 2009 ,Scott Weidman and myself met with Combined Craft insulators, Steve Makey Maint.Training Consultant and  Eric Fannin to review the draft of the Man Made Mineral Fibers draft procedure. The document in draft was workable but everyone feels that there will be a need to provide a review period for all the Combined Craft mechanics and Chief Operators who will generate the safe work permits. The Action Items coming from the meeting will be:

 

á       Eric Fannin will be providing monitoring of the Combined Craft Stationary Insulation Band saw by Mid November 2009 to determine particulate exposure

á       Eric Fannin to contact corporate medical to determine criteria for Chest x-ray - "b" screen for Combined craft mechanics

á       Combined Craft mechanics and Tommy Ley will identify the appropriate HEPA filters for the saw and a secondary HEPA vacuum

á       Steve Makey will assist Rocky Lanier in developing additional training steps and update  in the Combined Craft Training Document

Steve Makey and Rocky Lanier to develop an updated guideline to operate Insulation band saw with additional health and safety precautions.

Complete 11/09/09

When deluge system is taken out of service and our pipefitter install plugs, the fire marshals are not notified to put it back in service. Sometimes these are out of service for weeks before being returned to proper service.

 

Understand a maintenance procedure has been written to capture this. Need follow-up on when this procedure is going to be rolled out so we can track the effectiveness of it. Also consideration should be made for addressing it in a Red Book procedure. May need to require an MOC for more than eight hours. 5/20/09

 

Concern expressed as to how to mark or note that a safety system has been disabled so the next fire marshal on duty knows it needs to be put back in service. Rick Vogel will report back at June meeting on Òflagging.Ó

Revised draft of maintenance procedure is being posted.

Maintenance procedure written and approved. Importance of training for supervisors emphasized. 9/23/09

Rick Vogel to follow up with Steve Mackie.

Update

-10.16.09  Rick will meet with Steve Makie every other Friday and address it then.

Complete 11/09/09

The lack of knowledge about the weight of the motors and pumps T&T lift, on lugs that have not been removed and installed with each lift. They are suppose to be certified lifting lugs, installed to there shoulder and at the correct angle for lifting.

 

Machinist can give the T&T driver that information.

The lugs in place they are using could be rusted and not support the weight.

Certified lifting lugs are in the tool room. 5/20/09

Do T&T personnel, machinist, planner (put the weight on the plan) need some training to make this happen?

 

Truck & Trailer lifts and proper weights - Norm Smith & Dave Mortland will make sure fitters and contractors are aware of correct procedure.

 

PM program for threads on motors for lifting lugs?

 

Joe:

PM for threads on motors for lifting lugs?  The check should follow our FAB procedure for checking bolts and nuts for re-use.  The shop should not use the fix eye bolts for lifting.  If the stud will fully engage the threaded connection on the side of the motor, the connection can be re-used.  The shop trainer purchased a set of swivel eyes for lifting and trained all of the machines to use the new set.

Keith

 

Kevin Carban,

The context in which the original statement was made by the T&T safety rep  regarding lifting vertical inline motors and pumps utilizing eye bolts in the field and the shop. If at all possible could we remind the machine shop members of the hoist rings that are located in the box at the North end of the shop and also the option of using two chokers in a double wrap choker hitch around the motor. There will be a training reminder for each shop in the next week covering this topic.

Dave Mortland

 

Various groups of people (including contractors) need to be educated on working guidelines and procedure. Dave Elliott and Dave Mortland to address. 9/23/09

-       August 2009 Maintenance training topic was developed for usage of Hoist rings and Eyebolts then  shared with crafts

-       Shouldered vs. Unshouldered eyebolts was discussed

-       Location of hoist rings and usage communicated

Follow up training in Machine Shop 10.21.09

Complete 11/09/09

The "Farm Wagons" that we haul things across the roads and around the refinery on were pointed out not to be engineered, stamped or inspected like we should for hauling material across or on the highway. If anything were to happen, it would be our licenses dinged for doing it. Especially since we have CDL's for hauling hazardous materials. Contractors also use those wagons.

 

Sean, I have obtained the required information on the wagons. This consists of axle size, tapered or straight axle, seal size, tire/rim size and number of wheel studs. I am now in the process of placing  a weight rating on each wagon axle. However I have not heard from inspection or engineering about how they would like to proceed as to rating the frames of the wagons.

 

Per T&T personnel - FEL is in place for a 3 axle wagon, building now per K. Peters.

     

I know that we discussed these wagons possibly needing to be licensed since they cross Woodville Rd., there is no such requirement. Could we get a document about this not being required?  I do have some suggestions that we could institute, install slow moving vehicle signs on the rear of each wagon, install reflective tape on each wagon, install safety chains, and trailer lights if these are used at night. Has this happened?

      I will have the axle ratings completed as soon as possible. I will forward a completed list and rating chart to you as soon as it is finished. Are the ratings completed?

 

Thanks, Mack Borders

 

Farm Wagons: Rick Vogel will obtain regulations and Dave Mortland will help identify hauled materials. Legal if traveling 25 mph or less, but need orange diamond placid for slow moving vehicle. Has not happened yet.

The wagons have cracks and were cobbled together when built.

Rick Vogel to follow up with Sean Cornett and Kevin Peters. 9/23/09

 

Status?

- 10.16.09 R.Vogel purchased slow moving vehicle signs for placement on farm wagons

Complete 11/09/09

Electricity operates gate at Tank Farm. During a power failure and an alarm to evacuate to Cardinal Stritch High School Parking lot, How are personnel suppose to leave the area if they can not get out the gate? What do I do, keep people inside. The barbs on the wire faces to keep personnel inside. 05/20/08

 

There is a clutch to release the gate so personnel can get out. T&S will be refresher trained on this per Joe Haws. 07/01/09

What about other personnel trapped when T&S personnel are not there? They also need training.  07/01/09

 

Keith,

 

In reading through Title 33 Navigation and Navigable Waters PART 154 current as of August 12, 2009,

it is stated in 154.735 (a) that:  Access to the facility by firefighting personnel, fire trucks, or other

emergency personnel is not impeded.

 

My interpretation of this is further support of our contention that T&S personnel should have a key to

access the facility main gate.  Going to a box behind a sign to access a bolt cutter to cut through a

heavy duty lock is not what I (nor probably a COTP) would consider unimpeded access.

 

Jeff Schramm

-10.16.09 MTSA Homeland Security & US Coast Guard require management to maintain control – not everyone will get key

-Option to use bolt cutters & cut lock

-10.16.09 R. Vogel -Tank Farm- if gate wonÕt open then just walk through Propane office

Complete 11/09/09

ERT

Everybody in the refinery is not familiar with jargon describing particular areas of the refinery. Example ÒStation XÓ or ÒStation X jrÓ Need information so ERT members can add to their refinery map. Nothing worse than getting a call for an ERT member to respond to an area described with a slang name that particular plant uses all the time. It will be next to impossible to get the operator to stop calling something by a slang term they have used for years, but we can gather these and put them on the ERT map.

 

The leaders of the ERT teams will respond to the concerns and R. Vogel will report back.

5/20/09

 

- 10.16.09 This issue was brought up by a fairly new refinery ERT member I will have follow up discussion with him.

 

Norm Smith will work with Rick on the Confined Space Entry and any other related procedures (non electrical) to revise draft(s) for review by JHSC at July meeting.

 

I can not believe that we use the follow information on the CBT for qualifying a standby, and or permit writer annually.

 

CBT for Confined Space Entry:

Note: A permit issuer also may serve as a stand-by person or entrant, as long as that person is trained and equipped as required for each role he or she fills. Leads me to believe that a permit issuer, trained to issue a permit for a confined space does not qualify him/her to be a standby or entrant.

 

Permitting:

A Confined Space Entry Permit must be written prior to an entry. Each permit is

valid for the work shift of the permit requestor or issuer, whichever is sooner. If the permit requestor needs to work past the issuer's shift, the requestor must

obtain a new permit or revalidation (depending on facility) from the incoming

shift. Does not agree with our electronic permit procedure.

 

The atmosphere in the space shall be tested as necessary or a minimum of twice a shift, to ensure that the forced air ventilation is preventing an accumulation of a hazardous atmosphere. We do not always have force ventilation and opur minimum check is 24 hours, sometimes longer during a T/A.

 

Contractor Entry – Contractors who will be required to perform confined space work must:

Be represented at pre-plan meetings, & review & sign the completed pre-plan prior to entry. Does not happen, nor is there a place designated for their signature.

 

RESPONSIBILITIES – Each Attendant/Standby shall:

Review and sign the Pre-Plan and the confined space permit. Verify that the entrants have reviewed the preplan and the entry permit. Again is not a requirement.

 

RESPONSIBILITIES – The Permit Issuer shall:

Remove any unauthorized individuals who enter or attempt to enter the space. We remove an unautorrized entrant?

Perform the necessary tests to the atmosphere for toxins if they may be present and enter the results on the permit and the entry tag. Gas tests must be conducted prior to entry and midshift. Does not happen.

Collect all permits and tags at the end of the shift/job, permits will be picked up by the guards when they do the postings. Our guards do the posting?

 

RESCUE:

All entrants must wear a chest? or full body harness during entry into a confined space for rescue purposes, unless it is determined that wearing the harness is more hazardous to the entrant and the requirement is waived on the preplan for that space.

 

A standby must be familiar with the retrieval equipment required at a permit required confined space, and may assist with non-entry rescue if requested. When did operations get retrieval training?

 

 

 

Sunoco requires that all employees who must write confined space permits or enter into confined spaces receive training as to its hazards, its procedures, & equipment required to do so safely. Is this referencing another training?

 

Maintenance Training & eLearning

Sunoco Learning & Development Dept.

Believe we should get three or four of these CBT a month so we can start working on correcting them.

 

- November 2009 Update

Rick Vogel sent out the up to date training CBT which was much better and answered all questions.

Complete 11/09/09

Electronic Permit Procedure – Personnel think this is an approved procedure. Unless it is viewed in the print mode, there is no indication that this is a draft procedure. 7/1/09

 

Have a real problem with two Safe Work Permit procedures. The electronic version that is still a draft is posted along with the other Safe Work Permit procedure.  There are contradictions between the two procedures.  Some operators choose which part of each procedure they want to follow. The electronic procedure has to be updated with the final changes and taken out of draft form with the other Safe Work Procedure archived. Have to review procedure by 5 person.

 

Anybody permit trained can issue permits at the dock & terminal (apprentices with two years experience writing permits in remote areas.) IsnÕt this against out procedure? Also at the terminal they are using the old style permits which they were never trained on. Usually chief operators are trained on writing and issuing permits by the plant trainer during their chief operator training. What about that all important box about agreeing that the job can be completed safely?

 

5/20/09 CHANGE PERMIT LANGUAGE FOR CHECK-OFF BOX AS FOLLOWS: (Grievance Filed)

The Operations and craft technician agreed at the job location that this job can be completed safely, but can not guarantee it.

 

Response: This language will not be changed on the permit, is not acceptable to write in a disclaimer.

 

Let me give you an example of the problem. When an operator issues most permits there is no issue with checking this box. The issue comes when an operator writes a permit that maintenance & operations are uncomfortable with. Examples would be issuing a live flare permit, or opening equipment  above 20% of the LEL. Recently on a live flare at P/9 an RV opened and pressured the flare line during a live flare going on at P/9. If this can happen within a plant, how can an operator or mechanic feel comfortable issuing this type of permit when other plants can dump to the flare which the permit issuing operator has no control. We follow the safety procedure regarding live flare work, but these are riskier jobs requiring fire marshal standbys, double nomex, non sparking tools. If the job was truly safe, why do we require fire Marshall standbys with charged hoses, two means of egress, etc? Those are the type of jobs we would like to write a disclaimer on the permit and have better language in the HES Safe Work Procedure defining what it means when we state on the permit that the job can be completed safely. The language in the procedure should be written clearer to address this.

 

Newly added language from G&N:

This box is required to be checked to issue the Safe Work Permit.  The purpose of the check box is a last verification, before the job is begun, that the proper safety measures (e.g., PPE, JSA) have been put into place before the job is started, so that a particular job can be completed as safely as possible.

Complete 11/09/09

Plant 6 storage pod does not have lights. Operators are trying to get something towards the back of the pod while trying to hold a flashlight under their arms. Contractors do not seem to have a problem getting lights for their pods.

Lights added.

Complete 11/09/09

Retrieval devices at the UG shipper vessels.

            During this current work project, the contractors will be using tri-pods at all vessel entry locations. Scaffolds poles are not being used for retrieval. Complete 11/09/09

 

 

 

 

 





Member Login
Username:

Password:


Not registered yet?
Click Here to sign-up.

Forgot Your Login?
Site Search
Site Map
RSS Feeds
<<  September 2010  >>
S M T W T F S
1 2 3 4
5 6 7 8 9 10 11
12 13 14 15 16 17 18
19 20 21 22 23 24 25
26 27 28 29 30
Important Links
Visit usw.org!
Visit www.usw.org/action_center!
Visit www.usw.org/wos!
Visit www.kaptur.house.gov/!
State of Ohio Medical Board Complaint Form
Ohio Bureau of Worker Compensation
Ohio Nurse Discipline Process
U.S. Occupational Health & Safety Administration
National Labor Relations Board
U.S. Equal Employment Oppurtunity Commission
Ohio Civil Rights Commission
USW 10-1 Sunoco Philadelphia Refinery
Toxic Free Communities/ US PIRG
Weather Report
Visit Unions-America.com!
 Top of Page © Copyright 2010, USW Local 912, All Rights Reserved.
Powered By UnionActive™
Hide the Right Hand Column