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. Vogelsearched 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.
áWill add language to
the existing energy isolation procedure (Example, working on a switch that
instrument tech does not want locked out).
áUse 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
áDefinition of Critical
Alarm supplied.
á5 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
áMust have good turnover
with prior safety rep at the very least, waiting to find out how many safety
reps have changed throughout the refinery.
áMust have training if
safety rep agrees to do environmental audit with extra time allotted.
áReceived 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.ÓI
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
10.16.09Address 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 assoon 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: 1Revision
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 aprepared 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.
-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 canwithstand.
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
áHeater
red taped
áPer 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 inGreen 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
áOpen 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.
áLong term
recommendation: When a unit is down, make an attempt to use twin seal valves
when appropriate.
áShort 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 Phandinhand 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 positionedupside 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
requiredÓCan 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 toCONLEY, 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-19001I 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
unitwill 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.
áJHSC 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:
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.
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 Grounding1 GS 1315 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 Systems1
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 5person 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 Investigation1 PS 2055 person turned in suggestions for changes to this
procedure on 06/15/09.
127
Iron Sulfide 1 HC 621 5person turned in suggestions for changes to this
procedure on 06/15/09.
128
Management of Change/PSSR 1 PS 2005
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 6255 person turned in
suggestions for changes to this procedure on 06/15/09.
131
Personnel Platforms 1 MS 501 5person
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 5025
person turned in suggestions for changes to this procedure on 06/15/09.
134
Rotating Equipment 1 GS 1185
person turned in suggestions for changes to this procedure on 06/15/09.
135
Safety Valves 1 GS 1405
person turned in suggestions for changes to this procedure on 06/15/09.
136
Sandblasting Tanks 1 MS 5075
person turned in suggestions for changes to this procedure on 06/15/09.
137
Scaffolds 1 MS 5095 person turned in
suggestions for changes to this procedure on06/15/09.
138
Sewer Covering1 GS 1265 person turned in suggestions for changes to this
procedure on 06/15/09.
139
Smoking 1 GS 1025 person turned in
suggestions for changes to this procedure on 06/15/09.
140
To Open Equipment 1 GS 1435
person turned in suggestions for changes to this procedure on 06/15/09.
141
Variance to Safety Procedures 1 GS 1375
person turned in suggestions for changes to this procedure on06/15/09.
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 coldA 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 cleanedCampbell 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?
Arethe 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 andFFF 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 andFFF 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
backlogas 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
áUnder
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
áPlant 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).
áFirst
round will be done in 30 days and Eric will report back to JHSC in May.
áIf
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 INTRANET4/15/09
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 2/12/2009project
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. Complete9/23/09
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
Complete11/09/09
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.
Complete11/09/09
TOTE CONTAINMENTS NOT BEING DRAINED. 4/15/09
áContainments
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.
áFind
out who is responsible to keep them pumped down.
áThere
are some that has not shown any level throughout the year. Must have a
leaking containment that needs to be replaced.
áHow
much after they fill up with rain water before it becomes a spill?
áGet
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:
áContainment for Baker Chemical BPB59470, located
north end of East Side structure, is one-third full of liquid (water?).
á3 containers North of old eastside control room.
á1 container East of old Westside control room
á1 West end of cooling tower.
Plant 6 containments:
á2 barrel containments West of R-606.
Plant 8
containments:
á1 in the Kellogg
á2 in the DIB
á3 north of switch
room. (1 is not in use)
Plant 9 containments:
áThree are located north of R-9102.
áOne is located south of P-9202.
áOne is located NW of H-9101.
áSix are located in courtyard adjacent to H-9251
(across from Cooling Tower).
Tank Farm containments:
áNorthwest 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.
Complete11/09/09
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.
áNeed updated draft
procedure finalized.
áTraining needs per
Procedure 1 HSS 106 regarding this updated procedure when completed.
RickVogel will distribute to JHSC this week. 6/17/09.
RickVogel 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 andEric 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:
áEric
Fannin will be providing monitoring of the Combined Craft Stationary Insulation
Band saw by Mid November 2009 to determine particulate exposure
áEric
Fannin to contact corporate medical to determine criteria for Chest x-ray -
"b" screen for Combined craft mechanics
áCombined
Craft mechanics and Tommy Ley will identify the appropriate HEPA filters for
the saw and a secondary HEPA vacuum
áSteve
Makey will assist Rocky Lanier in developing additional training steps and
updatein 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.
Complete11/09/09
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
-10.16.09Rick will meet with Steve Makie every other Friday and address it then.
Complete11/09/09
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 repregarding 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 thenshared with crafts
-Shouldered vs. Unshouldered eyebolts was discussed
-Location of hoist rings and usage communicated
Follow up training in
Machine Shop 10.21.09
Complete11/09/09
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 placinga 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
Complete11/09/09
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
Complete11/09/09
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.
Complete11/09/09
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 equipmentabove 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.
Complete11/09/09
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.
Complete11/09/09
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. Complete11/09/09