GENERAL SAFETY PROCEDURES



GENERAL SAFETY PROCEDURES

CONFINED SPACE ENTRY

Procedure Number: GSP-303

TABLE OF CONTENTS

CONFINED SPACE ENTRY - GSP-303

1.0 PURPOSE 3

2.0 SCOPE 3

2.1. Personnel and Activities Covered by this Procedure 3

2.2. Areas or Equipment Covered by this Procedure 3

2.3. Exemptions from this Procedure 4

3.0 DEFINITIONS 4

4.0 PREREQUISITES 7

5.0 PROCESS OVERVIEW OF CONFINED SPACE ENTRY 7

6.0 INSTRUCTIONS 7

6.1. Pre-Entry 7

6.2. Working in an OSHA Classified Non-Permit Confined Space (permit is required at Valero facilities) 7

6.3. Confined Space Entry Using Forced-Air Ventilation 7

6.4. Permit Required Confined Space Program (Normal Valero Entry Requirement) 7

6.5. Emergency Action Plan 7

6.6. Entry onto a Tank Roof More Than Four Feet from the Top of the Shell 7

7.0 ROLES AND RESPONSIBILITIES 7

7.1. Responsibilities of the Affected Person Conducting the Work 7

7.2. Responsibilities of the Attendant 7

7.3. Responsibilities of the Valero Responsible Person 7

8.0 REPORTING REQUIREMENTS 7

9.0 DOCUMENTATION AND RECORD RETENTION 7

9.1. Required Documentation 7

9.2. Document Storage and Retention Time 7

10.0 APPENDIX A - SAFE WORK PERMIT 7

11.0 APPENDIX B - CONFINED SPACE ENTRY LOG 7

12.0 APPENDIX C - INITIAL CONFINED SPACE EVALUATION FORM 7

13.0 APPENDIX D - EMERGENCY ACTION PLAN 7

PURPOSE

The purpose of this procedure is to:

1 Define the minimum conditions that must be met to ensure employee and contractor safety during entry and work in confined spaces; and

2 Comply with OSHA regulation 29 CFR 1910.146, Permit Required Confined Spaces.

SCOPE

1 Personnel and Activities Covered by this Procedure

This procedure applies all personnel, company or contractor, that enters confined spaces in or on Valero Terminaling and Distribution Company (Valero) owned, operated or maintained pipelines or facilities.

This procedure uses terminology consistent with OSHA 29 CFR 1910.146, however, Valero procedures require “the use of a confined space permit” to document decisions made regarding entry into all confined spaces, regardless if they are permit required or not permit-required spaces as classified by OSHA standards.

2 Areas or Equipment Covered by this Procedure

A confined space is normally considered to be an enclosure having limited means of access/egress, such as, but not limited to:

1 External floating roof tanks greater than four feet from top of the shell

2 Buried valve boxes or sumps with open tops greater than four (4) feet deep, or working platforms greater than four feet deep

3 Vessels and tanks (entered by a manway)

4 Pig or scraper traps

5 Internal floating roof tanks

6 Footing excavations and bell bottom pier holes

NOTE: This is a list of examples within Valero. Additional areas or equipment may also be considered confined spaces including enclosures or spaces where hazardous gases, mists, fumes, vapors or dust may accumulate or where oxygen deficiency may exist.

3 Exemptions from this Procedure

The following are exempt from this procedure:

1 Excavations (excluding footing excavations and bell bottom pier holes) where the Valero excavation procedure GSP-304 is used

2 Hyperbaric chambers and dry habitats that are regulated by the U.S. Coast Guard

3 Tank berms (if dirt is sloped properly or stairways with handrails or ramps are provided)

4 Tank berms (with concrete walls, and stairways with handrails)

5 A clean tank with a door sheet that is 50 square feet and tall enough for a person to easily enter and exit

6 External floating roof tanks less than four (4) feet from the top of the shell

7 Buried valve boxes or sumps with open tops less than four (4) feet deep or working platforms less than four (4) feet deep

8 Outdoor manifold areas where ventilation is sufficient to purge a hazardous atmosphere, and where physical hazards will not trap a person

9 Confined space entry in areas or facilities operated or maintained by other companies including other Valero operating companies, where:

- The use of their procedure and permit is required

- Their procedure meets the minimum requirements of Valero’s Confined Space Entry Procedure

DEFINITIONS

Administrative Assistant

Person responsible for filing, tracking, etc. of documents, this could be a company or contract Administrative Assistant, Operator, Mechanic, or Supervisor

Attendant

An individual stationed outside one or more permit-required confined spaces who monitors the entrants and who performs all attendant's duties assigned in this Safe Work Practice

Confined-Space

A space that meets all the following:

• It is large enough and so configured that an employee can bodily enter and perform assigned work

• It has limited or restricted means for entry or exit (e.g., tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may limit means of entry)

• It is not designed for continuous occupancy

Designated Health, Safety and Environmental (HSE) Representative

The designated HSE representative may be a Valero employee or group or it may be a contracted entity providing specialized services to assist in environmental, health, industrial hygiene, and safety compliance activities. Subject to corporate management approval, each facility may satisfy these responsibilities through a combination of in-house and outside contracted services

Emergency

Any occurrence (including any failure of hazard control or monitoring equipment) or event internal or external to the permit-required confined space that could endanger persons conducting the work (entrants)

Engulfment

The surrounding and enclosure of a person by a liquid or fine substance that can be inhaled to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, or crushing

Entry

The action by which a person's head and or whole body passes through an opening into a permit-required confined space. Entry includes work activities in that space and is considered to have occurred as soon as the head and/or whole body break the plane of an opening into the space. OSHA allows parts of the body, i.e., hands or feet to enter without using permit-required confined space entry procedures as long as the head does not break the plane of the opening into the space.

Eliminated

A hazard is considered to be eliminated when the surrounding area or equipment has been cleaned, purged, ventilated, flushed, blinded, locked-out, tagged-out, disconnected, or other means of removing the potential for injury or release.

General Ventilation

The process of flushing the atmosphere by supplying and exhausting large volumes of air.

Hazardous Atmosphere

An atmosphere that may cause injury or illness due to the presence of flammable vapors or toxic substances in excess of safe limits or any other atmospheric condition that is immediately dangerous to life or health. Examples of hazardous atmospheres are outside the safe limits defined below:

|Substance |Safe Limits |

|Oxygen |19.5 to 23.5% |

|Flammable Gas |Less than 5% lower explosive limit (LEL) |

|Toxics |Less than permissible exposure limit (PEL) |

NOTE: For air contaminants for which OSHA has not determined a dose or permissible exposure limit, other sources of information, such as Material Safety Data Sheets (MSDS), published information, and internal documents can provide guidance in establishing acceptable atmospheric conditions.

LEL is 5% which is half of Permissible LEL (10%) of OSHA. All Valero LEL readings greater than “0” must explore if there is an identifiable source for the LEL.

Immediately Dangerous to Life or Health (IDLH)

Any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape by themselves from a confined space

Isolation

The process by which a confined space is removed from service and completely protected against the release of energy and material into the space by such means as: Blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages

Local Exhaust Ventilation

The process of capturing contaminants at their point of origin and removing them.

Non-Permit Confined Space

A confined space that does not contain or have the potential to contain any hazard (i.e., hazardous atmosphere or physical hazard) capable of causing death or serious physical harm. Part A of a permit must be completed to document decisions made in determining classification.

Originator

The originator of the confined space entry permit is the person requesting permission to enter a confined space. This person is responsible for ensuring necessary steps have been taken to eliminate the possibility of confined space injuries.

Oxygen Deficient Atmosphere

An atmosphere containing less than 19.5 percent oxygen by volume

Oxygen Enriched Atmosphere

An atmosphere containing more than 23.5 percent oxygen by volume

Permit-Required Confined Space (OSHA defined)

A confined space that has any of the following characteristics:

• It contains or has a potential to contain a hazardous atmosphere

• It contains a material that has the potential for engulfing an entrant

• It has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section

• It contains any other recognized serious safety or health hazard

Person Conducting the Work

A Valero employee or contract personnel who are authorized by Valero to enter a confined space. The person conducting the work is responsible to comply with all conditions and requirements on the permit. The person conducting the work may also be the Valero Responsible Person.

Valero Responsible Employee

A Valero Responsible Employee, in Confined Space Procedure, is an employee who prepares the equipment in order to perform the necessary entry work, as outlined in this procedure.

Each Valero Responsible Employee must receive training in the Confined Space Entry Procedure GSP-303, and other confined space entry information required to ensure the safe and effective planning, preparation, and isolation of the confined space.

Valero Responsible Employee means a person with specific training, knowledge and experience in the area for which the person has the responsibility and the authority to control the equipment and requirements outlined in this procedure. A Valero Responsible Employee must be familiar with the construction and operation of the subject equipment and the associated hazards.

Physical Hazard

Any recognized non-atmospheric hazard such as moving equipment or exposed electrical parts which could cause injury

Potential

The possibility of a space containing or developing a hazardous atmosphere or other safety hazard. The history of the equipment or the activity to be performed in the space should be taken into consideration when determining if a potential exists

Qualified Gas Tester

The Valero designated person with the training and competencies required to conduct the atmospheric testing, understanding of associated procedures requiring atmospheric testing, calibration and testing of the atmospheric testing equipment, and understanding of the work operating area affected by the atmospheric testing

Rescue Service

The personnel designated to rescue entrants from confined spaces, whether internal or external trained rescue personnel

Retrieval System

The equipment (including a retrieval line, chest or full-body harness, and a lifting device or anchor) used for non-entry rescue of persons from a confined space

Safe for Entry with Ventilation

The atmosphere in the space after ventilation is not expected to approach a hazardous atmosphere. This is necessary so that if the ventilation shuts down for any reason, the workers will have enough time to recognize the hazard and either exit the space or restore the ventilation. A guideline of 50 percent of the level of flammable or toxic substances that would constitute a hazardous atmosphere without ventilation applied to the space, and may be used to make the determination that atmospheric conditions are safe (i.e., 50% of 10% LEL is 5% LEL, 50% of 25 ppm PEL for carbon monoxide is 12.5 ppm, 50% of 10 ppm PEL for hydrogen sulfide is 5 ppm, etc.).

Note: Any elevated LEL reading should initiate additional area evaluation to ensure that there is no hazard source causing the elevated LEL reading.

Side Entry

Entryways not more than 3-1/2 feet above the level at which work is to be performed.

Manager

The management representative with overall responsibility for the terminal, area, site or function

Supervisor or his Designated Representative

The management representative with immediate responsibility for the terminal, area, site or function. The Supervisor or his designee is responsible for the implementation of this procedure. This person has overall responsibility for adherence to the procedures and coordinates Valero equipment and Responsible Employees for the work being done.

Testing

The process used to identify and evaluate hazards in a confined space. Testing includes specifying the tests that are to be performed in the confined space. Testing enables the Qualified Valero Responsible Person to devise and implement adequate control measures for the protection of authorized entrants and to determine if acceptable entry conditions are present immediately prior to, and during entry.

Top Entry

Vertical Entry. Entryways more than 3-1/2 feet above the level at which work is to be performed

Ventilation

The process of removing or displacing contaminants from a space or, of supplying oxygen to an oxygen deficient atmosphere. There are two types of ventilation; local exhaust ventilation, and general ventilation.

PREREQUISITES

The following are required conditions for any person performing work within confined spaces in accordance with this procedure:

1 Only employees trained on this procedure are allowed to perform work involving confined space entry.

2 Persons conducting entry rescue must be trained to OSHA 1910.146 requirements in addition to the rescue training requirements.

NOTE: Contact the Designated HSE Representative for additional information.

PROCESS OVERVIEW OF CONFINED SPACE ENTRY

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INSTRUCTIONS

1 Pre-Entry

The Originator determines if the space to be entered meets the criteria set by OSHA for a confined space. A confined space exists and this procedure applies if the space meets all of the following:

1 Is large enough so a person can enter and work in the space

2 Entry or exit into the space is restricted or limited (restricted includes ladders, manways, crawl spaces, etc.)

3 Is not designed for continuous employee occupancy

NOTE: If the space does not meet all of the above, this procedure does not apply. Other procedures may apply.

If the space meets all of the above, The Valero Responsible Person and the Person Conducting the Work determine the type of confined space and which sections in this procedure to follow.

There are three types of confined space which are defined below:

1 Non-Permit Confined Space requiring the use of permit section A to document decisions (follow sections 6.1 and 6.2). (See permit example, Appendix A)

2 Confined Space Requiring Ventilation for control of unacceptable atmospheric hazards, requires use of permit sections A and B (follow sections 6.1 and 6.3).

3 Permit Required Confined Space requires the use of the entire permit plus an emergency action plan (follow sections 6.1, 6.4, 6.5, and 6.3 if using ventilation).

NOTE: Valero requires the use of a permit to document entry into all confined spaces that fall into the three distinct categories. A permit is required for entry into all confined spaces. Each permit will require unique information depending on conditions.

The following depicts an example scenario for each of the three respective confined space designations:

• A tank has been thoroughly cleaned and properly isolated following Permit Required Confined Space entry procedures. Gas testing has shown neither detectable toxic atmospheres nor physical hazards and entry/exit is unrestricted. The space can now be designated a Non-Permit Confined Space.

• A work crew enters the tank to perform repairs using a flammable epoxy. Gas testing shows that toxic vapors are now present in concentrations above acceptable levels. However, gas testing has also shown that these levels can be reduced to less than hazardous levels by using forced-air ventilation from outside the tank. The space is now a Confined Space Requiring Ventilation. (The use of ventilation does not make a space a Non-Permit Confined Space because the ventilation does not eliminate the hazard.)

• If a worker spills a large volume of epoxy which raises the levels of vapors above acceptable levels even with forced-air ventilation, the space again becomes a Permit Required Confined Space.

The Originator enters the date; start time and valid to time, then completes part “A”, of the Valero Safe Work Permit (see below example 6.1.A) including:

1 Issued to

2 Location

3 Description of the work to be done

4 Equipment Name and Number

5 Confined space entry checkbox; and confined space evaluation number

Example 6.1.A

Date: _____________________ Start Time: ___________ (AM ( PM Valid To: ___________ (AM ( PM

(No permit is valid beyond the start of the next work day)

Permit Type (Check All That Apply): ( General/Cold Work ( Hot Work ( Vehicle Entry ( Excavation

|A. Work Scope (Must be completed for all permitted work activities) |

Issued To: _____________________________________________ Location: ________________________________________

(Name/Company)

Description of Work (Be Specific): _______________________________________________________________________________________

_____________________________________________________________ Equipment Name and/or Number __________________________

( Confined Space Entry (Refer to Initial Confined Space Evaluation No) ____________________________

The Valero Responsible Person specifies and documents on the permit the number of the confined space Evaluation Form (part A), which details the methods to be used to ensure isolation and initial cleaning or purging of the space. The permit is reviewed with the Person Conducting the Work. The Qualified Valero Responsible Person completes the “Initial Confined Space Evaluation Form” (See Appendix C) which includes:

• Preparation Checklist

• Atmospheric Testing

• Approvals

• Cancellation (upon completion of work)

The Person Conducting the Work prepares the job site and completes “Confined Space Preparations” section “F” of work permits (see Example 6.1.b below).

Ensuring all equipment listed below is present at the work site as necessary, is in good working order, and is set up so as not to impede egress or present a safety hazard:

• Gas detection equipment (all spaces section “B” of work permit)

• Barriers to prevent unauthorized or accidental entry

• Signage indicating “Permit Required Confined Space Entry”

• Communications equipment (intrinsically safe and properly classified for area classification)

• Personal Protective Equipment (section “H” of Work Permit)

• Lighting equipment (classed for location) needed to enable Persons Performing The Work to see well enough to work safely and to exit the space quickly in an emergency

• Equipment, such as ladders, if needed for safe entry and exit by authorized entrants

• Electrical equipment and tools protected with a GFCI

Example 6.1.b

|B. General Preparations & Atmospheric Testing (General Preparations must be completed for all safe work permits) |

Check Off All Items:

GENERAL PREPARATIONS ATMOSPHERIC TESTING - REQUIRED? ( YES ( NO

|Yes |N/A | |Initial Gas Test |Gas Re-Tests |

|( ( Joint job site visit conducted |Oxygen ________% (19.5%-23.5%)|Oxygen ________% (19.5%-23.5%) |Oxygen ________% (19.5%-23.5%) |

|( ( Process Valero overview prepared & reviewed |Combustible:_______%LEL ( ................
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