Swp Hot Work Guidelines

Hot Work This document is intended as a general guideline to assist Contractors with understanding and applying Safe Work Practice expectations.

Posted March 29, 2012 © 2012 Chevron U.S.A. Inc.

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Table of Contents 1.0 Guidelines ........................................................................................................................... 3

2.0 Requirements ..................................................................................................................... 3

3.0 Terms and Definitions ....................................................................................................... 5

4.0 Roles, Responsibilities and Training Requirements ....................................................... 9

4.1 Initial Training ......................................................................................................... 12 4.2 Refresher Training ...................................................................................................... 12

5.0 Instructions ...................................................................................................................... 12

5.1 Hot Work Associated with Tanks, Vessels, and Piping .......................................... 13 5.2 Designated Safe Hot Work Areas ............................................................................ 14

5.2.1 Permit to Work............................................................................................... 16 5.2.2 Hot Work Permit ............................................................................................ 16

5.3 Permit Changes ........................................................................................................ 16 5.3.1 Permit Revalidation ....................................................................................... 17 5.3.2 Recording Changes ........................................................................................ 17 5.3.3 Permit Re-Evaluation ..................................................................................... 17

5.4 Contractors .............................................................................................................. 18 5.5 Jobsite and Equipment Preparation ......................................................................... 18 5.6 Gas Testing Requirements ....................................................................................... 21

5.6.1 Initial Gas Testing .......................................................................................... 23 5.6.2 Work Delays .................................................................................................. 23 5.6.3 Follow-up Gas Testing ................................................................................... 23

5.7 Conditions for Work Stoppage ................................................................................ 24 5.8 Fire Watch ............................................................................................................... 24 5.9 Work Completion .................................................................................................... 24

6.0 Records ............................................................................................................................. 25

6.1 Required Records .................................................................................................... 25 6.2 Retention Requirements .......................................................................................... 25

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1.0 Guidelines Ensure that hot work is performed in a safe and controlled manner.

The BOEM Welding Plan, the Non-Welding Hot Work Plan and the Gulf of Mexico Hot Work Guidelines do not apply to Welding Habitats. A separate Welding Habitat Plan must be submitted to and approved by the appropriate BOEM District Supervisor before using a welding habitat in conjunction with welding activities. A copy of the Welding Habitat Plan and the approval letter must be available on the facility where the welding habitat is being used.

2.0 Requirements 1. Consider all cold work alternatives before performing hot work.

2. Hazards associated with the hot work shall be identified and mitigated prior to beginning work. NOTE: Hot tapping requires additional precautions.

3. Personnel involved in hot work activities shall be trained and competent in the roles for which they are responsible.

4. A Qualified Gas Tester must conduct gas testing prior to hot work where there is a potential for flammable gases to be present. The Qualified Gas Tester shall determine the frequency of gas testing based on the potential risk.

A Firewatch assumes the role and duties of the Qualified Gas Tester. (See 4.0 Roles, Responsibilities and Training Requirements)

5. Fire Watch must be present where open flame hot work is carried out, except in designated safe welding areas.

6. The hot work must begin within 30 minutes after the Qualified Gas Tester has tested the area and cleared it for hot work to start.

7. When the work has been completed according to the job scope, the Work Team Leader must close out and return the Hot Work Permit and permit-related documents to the permit approver after:

• The jobsite has been left in a safe, clean and orderly condition.

• Adequate time (30 minutes) has elapsed for the Fire Watch to verify the condition of the jobsite.

• The work that was performed meets the required scope and specifications.

8. If work is interrupted by Stop Work Authority, weather conditions, alarms or unforeseen dangerous conditions, the Hot Work Permit must be revalidated before work can be restarted.

9. Hot tapping is not covered under this Guideline. It is considered a high risk activity which requires Subject Matter Expert input, written procedures and a high level of management approval.

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Additional Precautions: The BOEM Welding Plan, the Non-welding Hot Work Plan and the Hot Work Guidelines do not apply to hot tapping operations. A separate Hot Tapping Plan must be submitted to and approved by the appropriate BOEM District Supervisor before any hot tapping operations are commenced. A copy of the Hot Tapping Plan and the approval letter must be available on the facility where the hot tapping is being conducted.

Drilling and Well Work Activities

The BOEM Welding Plan stipulates that welding is not permitted during drilling, completion, or workover operations unless the fluids in the well are non-combustible and entry of formation hydrocarbons into the wellbore(s) is precluded by either mechanical means or a positive overbalance toward the formation. Welding is not permitted during wireline operations.

Reminder: This only applies to Drilling Fluids and Welding in Undesignated Safe Welding Areas!

For purposes of planning and conducting welding operations in Undesignated Safe Welding Areas, parameters have been established for "combustible liquids or fluids" based on the liquid's flash point.

• Liquids having a flashpoint at or below 200 degrees F shall be considered combustible and no welding should be conducted outside of Designated Safe Welding Areas during Well Work Activities.

o An BOEM Departure / Waiver must be obtained if welding needs to occur during these conditions

• Liquids having a flashpoint above 200 degree F shall be considered non-combustible (for welding purposes ONLY) and welding outside of Designated Safe Welding Areas may be conducted PROVIDED that said welding is permitted via the Daily Welding Permit process AND the 35 feet restrictions are applied to the mud system.

o The "mud system" includes all components of mud handling, circulating, shaking, storage, and testing.

Typical flashpoint ranges (in degrees F) of three common classes of mud are provided for general planning purposes. SPECIFIC flashpoints should be determined (from the MSDS, mud engineer, or vendor, etc) before final permission and the welding operations beginning. When unknown, you should assume the flashpoint to be below 200 F.

• Oil-based mud's typical flashpoint range is 120 F to 180 F • Synthetic-based mud's typical flashpoint range is 260 F to 275 F. • Water-based mud in non-combustible and does not have a flashpoint.

One must remain vigilant and aware that the properties of mud may change once circulation begins and the system should be monitored closely for changes that may warrant suspension of welding operations.

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3.0 Terms and Definitions The following terms and definitions apply to the Safe Work Practice (SWP) Guidelines for Hot Work:

Classified Hazardous Area – Any area classified as a hazardous zone area (Zone 0, 1 or 2 or Class I, Division 1 or 2) in accordance with API RP 505/API RP 500 or other equivalent local standards.

All of the Gulf of Mexico locations and facilities are considered Class I as per API RP 500 - Hazardous material is flammable gas or vapor. Ex: Oil refineries, natural gas compressor stations, etc. Further distinctions are made depending upon the nature of the hazards in the area.

Class I, Division 1

Locations in which:

• Hazardous concentrations of flammable gases or vapors may exist under normal operating conditions

• Hazardous concentrations of such gases or vapors may exist frequently because of repair or maintenance operations or because of leakage

• Breakdown or faulty operation of equipment or processes might release hazardous concentrations of flammable gases or vapors, and might also cause simultaneous failure of electrical equipment

Class I, Division 2

Locations in which:

• Volatile flammable liquids or flammable gases are handled, processed, or used, but in which the hazardous liquids, vapors, or gases will normally be confined within closed containers or closed systems from which they can escape only in case of accidental rupture or breakdown of such containers or systems, or in case of abnormal operation of equipment

• Hazardous concentrations of gases or vapors are normally prevented by positive mechanical ventilation, and which might become hazardous through failure or abnormal operations of the ventilating equipment

• That are adjacent to a Class I, Division 1 location, and to which hazardous concentrations of gases or vapors might occasionally be communicated unless such communication is prevented by adequate positive-pressure ventilation from a source of clean air, and safeguards against ventilation failure are provided

Unclassified

Areas that are not classified as Division 1 or Division 2.

Confined Space – A space that:

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

• Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults and pits are spaces that may have limited means of entry)

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• Is not designed for continuous employee occupancy

Fire Watch – An individual who is competent in basic firefighting and whose role is to observe conditions in the immediate and adjacent areas of hot work to ensure it is performed safely, and to sound the alarm if necessary. The Fire Watch will extinguish any incipient fire that occurs, if safe to do so.

Gas Testing

• Use of portable detection equipment by the Qualified Gas Tester, including detector tubes and combustible gas indicators, to determine levels of oxygen and flammable or toxic vapors and gases.

• A process whereby the required gas tests are continuously or intermittently monitored. Continuous or intermittent gas testing is normally required when there is a likelihood of changing gas concentrations and/or there is a high risk to workers if the gas concentration changes unexpectedly.

Hazardous Atmosphere – Atmosphere(s) that expose personnel to the risk of death, incapacitation, impaired ability to self-rescue, injury, or acute or chronic illness that may be caused by any of the following:

• An atmospheric concentration of any substance in excess of the permissible exposure limit (PEL) that could result in employee exposure, for example, to benzene or hydrogen sulfide.

• Flammable gas, vapor or mist in excess of 10 percent of its lower explosive limit (LEL).

• An atmospheric oxygen concentration less than 19.5 percent or above 23 percent.

• Any other atmospheric condition that is immediately dangerous to life or health (IDLH).

Hot Tap – A procedure used in repair, maintenance and service activities that involves welding on and then cutting an opening into a piece of equipment (pipelines, vessels or tanks) that is under pressure or in service, for the purpose of installing connections or appurtenances. A special procedure is required to weld a connection onto a pipe, vessel or tank that is in service without leaking any of the contents or causing an explosion or fire.

Hot Work – Any work activities that introduce a potential ignition source of any kind to the jobsite in a Classified Area. Open flame sources include, but are not limited to, activities such as welding, cutting, brazing, burning and grit-blasting. Closed flame sources may include battery-operated personal electronic devices and portable internal combustion engines (those that are not a properly designed and permanently installed part of the facility). Driving vehicles into a classified hazardous area, for example, tank impounding basins, is another source of closed flame ignition.

Types of Hot Work These guidelines apply to all hot work performed. For ease of referencing and understanding, hot work is classified in the following categories:

• Welding, burning and associated grinding • Non-welding hot work (all other ignition sources)

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Non-welding hot work (all other ignition sources)

Many ignition sources other than welding, burning and associated grinding have been recognized. Various sources have been recognized as threats while perhaps others have gone unnoticed or unchallenged.

The proliferation of portable electronic devices (PEDs) has introduced many new ignition sources into our operations. Many of these new ignition sources have been identified and the risk associated with them addressed. Perhaps some have slipped under our radar. Technological advances promise even more as of yet unknown threats in the future.

The purpose of this section is to create awareness of unrecognized threats and to provoke thought processes that prevent them from entering our operations without proper risk assessment and planning.

The matrix is built on risk of device and the area in which it is to be used. Higher risk items are open flames, sparking devices, hot surfaces etc. and lower risk items include battery-operated devices.

Some devices may be exempted from the permit process by a self -governed screening process against seven criteria. The screening may be done individually, as a group (during safety meetings, tailgate meetings, JSA reviews, etc) or some areas /groups may elect to designate one or more persons to screen all such devices. Regardless of how the screening is done, ALL seven of the criteria must be true for the exemption to apply. See the Non-Welding Hot Work Risk Matrix for details.

Barbecuing and Bar-B-Q Pits and Grills

Given the nature and uniqueness of Bar-B-Q pits and grills, a specific JSA and Use Permit has been created for the activity of barbecuing. The JSA and Use Permit is designed to provoke safety concerns and precautions that here-to-fore have gone largely unconsidered. The permit includes a New Location Checklist and a Pre-use Checklist.

The New Location Checklist should be filled out for each location of a Bar-B-Q grill and then used as a master for the subsequent Pre-use Checklist and approval to light that pit each time it is to be used.

The cook and/or other personnel involved with the actual cooking process should have a copy of the JSA and Use Permit for the duration of the time the grill is lit and hot.

Hot Work Permit – A permit issued in addition to a Permit to Work to grant the Company and/or contractor employees permission to perform hot work.

Utilize both a Daily Welding Permit and a Daily Non-Welding Hot Work Permit.

Inert Atmosphere – An atmosphere consisting primarily of an inert gas such as nitrogen or carbon dioxide that is effectively oxygen-free.

Initial Gas Testing – Gas test, or tests, that are conducted prior to beginning work and that are designed to determine the following:

• Requirements for confined space entry

• Whether the area is safe for hot work

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The tests may be conducted in two parts: testing a confined space initially from the outside and then testing again on the inside to determine if it is safe for work to commence.

Lower Explosive Limit (LEL) – The lowest mixture of hydrocarbon vapor and air that will support combustion. Typically indicated on gas testing equipment as “100%,” it is sometimes referred to as lower flammable limit (LFL).

Qualified Gas Tester – A person who is competent in the use of portable gas-testing equipment and has successfully demonstrated use of the equipment in the field. This person must also be competent in recognizing risks inherent to hot work and confined space entry.

A Firewatch assumes the role and duties of the Qualified Gas Tester. (See 4.0 Roles, Responsibilities and Training Requirements)

Button-type Battery (also known as a button cell, disc or coin battery)

A battery shaped and sized like a button or coin, commonly found in watches and other small devices. See picture for examples of various button-type batteries

Certified Person

A person who has taken tests and has been "checked-out" by appropriate governing bodies attesting that the person is capable of meeting the standards for which they are certified.

Explosion Proof Enclosures

Enclosures capable of withstanding an internal explosion and preventing its propagation to the external atmosphere.

Hermetically Sealed Devices

Devices designed to prevent flammable gases from coming in contact with sources of ignition, such as arcing contacts or high-temperature components. Note – Suitable for use in Division 2 and unclassified areas.

Intrinsically Safe Devices

Devices that are incapable of releasing sufficient electrical or thermal energy under normal or abnormal equipment operating conditions to cause ignition of a specific ignitable atmospheric mixture in its most easily ignitable concentration. Note – Suitable for uses in any hazardous (classified) location for which they are approved.

Inert

Lacking the power to move; Deficient in active properties. Rendering contents or vessels inert requires one or more proactive actions to be taken to remove/reduce active properties of the contents or vessels. Examples may include displacing contents with water or maintaining a sufficient nitrogen blanket on the vessel or contents.

Incipient Firefighting

The firefighting philosophy is for fighting fires in the beginning stages. A good rule of thumb is if you are not comfortable approaching the fire with the extinguisher available, then evaluate other options. "The best way to protect a facility from fire is to prevent the fire from occurring."

Qualified Person

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A person who is deemed capable of doing the desired task/action by a supervisor or ranking expert in that task. For instance, a welding supervisor may deem a welder helper qualified to operate the welding equipment for minor maintenance issues; or an HES Coordinator may deem a fire watch capable of operating the gas detector and/or fire-fighting equipment.

Non-Incendive Equipment

Equipment that is not capable of igniting a flammable mixture under normal circumstances, but ignition is not necessarily prevented under abnormal circumstances.

Note – Suitable for use only in Division 2 and unclassified areas.

PED - Portable Electronic Device

(Also known as a PEP - Portable Electronic Products) – All battery-operated devices such as radios, analyzers, cameras, laptops, cell phones, pagers, palm pilots, etc.

Production Areas

Areas where flammable petroleum gas, volatile liquids or sulfur are produced, processed (e.g., compressed), stored, transferred (e.g., pumped) or otherwise handled before entering the transportation process.

Self-governed

Ownership and responsibility for the task or action rest with the individual. It is the responsibility of each individual to ensure the PEDs they bring or wear into classified areas meet the exempting criteria or have a permit for the device if it does not meet the criteria.

Welding

All activities connected with welding, burning and associated grinding. It does not include hot tapping. Hot tapping requires separate plans, permits and approvals.

Well Bay

The area on the facility within the perimeter of the outermost wellheads.

Zero Energy State

Simply stated Zero Energy State is the absence of electrical current or power, stored pressure, or mechanical energy. (i.e. Extension cords must be disconnected from the power source prior to making or breaking connections either to other extension cords or to electrical devices.)

4.0 Roles, Responsibilities and Training Requirements There must be clearly defined roles, and personnel must meet the training and competency requirements of this guideline prior to starting work. A single individual may fulfill more than one role as long as he or she meets the competency requirements and is able to fully meet multiple responsibilities. When selecting personnel for these positions, consider the candidate’s level of experience and past performance.

The following roles and responsibilities are specific to hot work.

• Qualified Gas Tester

• Fire Watch

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• Person Performing Hot Work

There are typically several individuals involved in hot work operations. This section will identify these individuals and what their roles and responsibilities are before, during and after hot work activities. Note: ALL EMPLOYEES and CONTRACTORS have the right and the responsibility to stop any and all work that is being performed in an unsafe manner or that is not in compliance with federal or state regulations or company policies.

PIC (Person In Charge) or Designee (OS, DSM/WSM, OIM or Designee)

The person responsible for the hot work activity to be performed. This can include the following:

• Operations Supervisor • Drill Site Manager / Well Site Manager • Offshore Installation Manager • Or Designee

The PIC or Designee is responsible for the following - • Ensure that a copy of the BOEM Approved Welding

Plan and the BOEM Approval Letter is on file on the platform or rig.

• Follow the BOEM-approved Hot Work Plan, Permits, and Guidelines for both state and OCS locations.

• Before any hot work is performed, review the approved plan regarding personnel responsibilities, personnel safety, welding equipment, and work area inspection criteria.

• Review and complete the Daily Non-Welding Hot Work Permit or the Daily Welding Permit before introducing any ignition source into an area not designated by the BOEM as a "safe welding area".

• The PIC or Designee is responsible for coordinating the issuance of the Daily Welding Permit or the Daily Non-welding Hot Work Permit and for getting all of the appropriate signatures as required.

On-Site Reviewer (Operations Representative and/or Asset Development Representative, Facility Rep., Paint Inspector, I&E Rep., DSM/WSM)

The on-site representative that will be responsible for the following

• On-location to review work area before work begins • Initiation of the Permit to Work Process • Discuss work scope, Safe Work Practices and review

JSA. • Signs off on permit • Not required to remain on location, decides based on

risk of work being performed • The Operations Representative on-site reviewer may

also be the Operations Location Person In Charge.

An on-site reviewer shall be assigned and planned for each hot

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work activity during job planning.

Operations Location - Person-in-Charge (Typically O&M Personnel, Company/Contract)

The person located on site in charge of operations for the facility. This person

• Normally operates the facility • Can sign off on permit • May also act/serve as the on-site reviewer • If on-site reviewer leaves, this person becomes

responsible.

Welding Supervisor

The on-site contract welding representative who is responsible for the welding / burning operations. This may often be the welder. Specific duties are defined in the BOEM Welding Plan.

Welder

The person(s) actually is doing the welding. Welders working on structural components, vessels, piping and pipelines must be certified as defined in the BOEM Welding Plan.

Fire Watch (also known as Qualified Fire Watch)

A person adequately trained, capable of, and solely designated to operate gas detection and incipient firefighting equipment during ALL welding and burning operations performed outside of approved designated safe welding areas. The Fire Watch shall assist with inspection of work area. The BOEM Welding Plan provides further details of Fire Watch requirements and duties.

Others

Individuals that perform cutting, burning, and grinding activities are not required to be certified. However, they must be deemed qualified by the Welding Supervisor and/or the PIC or Designee and are subject to these guidelines and the BOEM Welding Plan as appropriate. Please see the Minor Maintenance Items of these Guidelines.

Required Signatures on Permits

Daily Welding Permit Non-Welding Daily Hot Work Permit

• PIC or Designee • Welding Supervisor • On site Reviewer • Fire Watch(es) • Final authority to begin welding is

given by Operations Supervisor, Offshore Installation Manager, Drill Site Manager/Well Site Manager and/or Delegated Person in Charge's signature.

• Permit Applicant • PIC or Designee • Exceptions to permit shall be approved by

signature of Operations Supervisor, Offshore Installation Manager, Drill Site Manager/Well Site Manager, and/or the Delegated Person in Charge.

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In the event that logistics (work at a remote site with no fax or email capabilities) make it impractical to secure an original signature of the OS, OIM, DSM/WSM and/or the Delegated Person In Charge, the On-Site Reviewer must conduct the following before Hot Work is allowed to begin:

• Contact the OS, OIM, DSM/WSM and/or Delegated Person In Charge and discuss the scope of work

• Verify that Permit to Work has been completed and a JSA has been conducted to include a thorough evaluation of potential hazards

• Discuss and agree that if the scope of work changes, the job will shut down and a new permit will be required

After the above conditions have been met, The On-Site Reviewer will sign the Hot Work Permit indicating the name of the Person In Charge granting approval for work to begin, and the time and date approval was granted. The permit will be retained by the On-Site Reviewer for the duration of the work and a copy will be forwarded to the field office location as soon as possible.

Minor Maintenance Items

There are occasions where minor maintenance (welding or burning or cutting) must be performed on non-structural components, non-vessels, non-piping or non-pipelines. Often, someone can handle these items other than a certified welder. It is permissible under these guidelines for non-certified welding personnel to perform such work provided they are qualified to operate the cutting / burning equipment AND comply with the BOEM Welding Plan. Personnel may be deemed qualified by the Operations Supervisor, Person-in-charge, or the Welding Supervisor.

To be clear, this DOES NOT include work or maintenance on structural components (handrails, supports, etc.), vessels, piping or pipelines. When in doubt, an appropriately certified welder must perform the work.

4.1 Initial Training Personnel must meet the competency requirements of this standardized safe work practice prior to starting work.

4.2 Refresher Training Refresher training must be provided as follows:

• As required by each company’s Policies and Procedures

• As needed when identified by: verification, inspections, incidents or audits

5.0 Instructions Hot work must be permitted and managed in accordance with the Managing Safe Work Process.

When considering work that involves hot work in a Classified Hazardous area, always consider whether there is a viable alternative, for example, using a hand or pneumatic saw for cold cutting rather than using a cutting torch, or moving the item outside of the Classified Hazardous area.

The following are examples of hot work:

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• Using non-explosion-proof electrical equipment or battery operated electronic devices (including mobile phones, inspection and testing equipment, such as ultra-sound and X-ray) in a hazardous area if the equipment is not certified intrinsically safe

• Operating motorized vehicles (battery operated or internal combustion) within a hazardous area or diked area where flammable vapors may be present

• Burning acetylene or gas

• Welding, brazing, cutting, grinding or chipping

• Soldering

• Using electric resistance heaters

• Performing abrasion blasting, using high-pressure hydro-jet, etc.

• Using electric or air-driven power tools capable of causing “hot” sparks or enough energy to ignite a flammable mixture (i.e., jack hammers, rattle guns, etc.)

• Using any equipment that generates an exposed flame or hot filament

5.1 Hot Work Associated with Tanks, Vessels, and Piping Welding on any tank, vessel, or any piping connected to the tank or vessel while the tank or vessel is in service is a deviation from this hot work guideline. It requires Subject Matter Expert input, written procedures, and a high level of management approval.

Welding In or On Tanks, Pressure Vessels and associated Piping • Welding In or On any Tank, Pressure Vessel or any associated piping connected to the

Tank or Pressure Vessel is considered a departure from the Hot Work Guidelines and is considered a safety sensitive activity which requires full written procedures and collaboration with Subject Matter Expert (MSW Advisors – Confined Space and Hot Work).

• The Referenced Guidelines provide the minimum guidance to plan, review, approve and execute the work and are not restrictive or limiting.

• Please use Guidelines for Hot Work In and On Pressure Vessels and Tanks when planning and executing Hot Work On and In Tanks and Pressure Vessels.

NEVER do hot work above the liquid level on the shell of any tank, vessel or piping that is not isolated, regardless of service.

Hot work on the shell of a tank, vessel or piping attached to a tank or vessel requires at least 1 meter (3 feet) of liquid coverage above the area of the hot work.

ALWAYS disconnect or blind piping from the tank (or other equipment) before performing hot work on the piping.

ALWAYS assume that the vapor space of any tank that is in service is in the flammable range when planning and conducting hot work activities close to tanks. Gas testing by itself does not guarantee that the entire vapor space is not in the flammable range. Special precautions may be required to separate the tank and attached piping from the location of the hot work.

Gas testing by a Qualified Gas Tester is mandatory at any openings and within any enclosed spaces anywhere below the location where hot work is being conducted. Gas testing is also required at any openings within 15 meters (50 feet) horizontally of where the hot work is being conducted.

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All openings and gaps into equipment, tanks, or piping within 15 meters (50 feet) shall be sealed by using sand bags, drain covers, fire blankets, or other means that prevent sparks from entering the opening or gap before allowing hot work to commence.

Welding on/near piping and associated connections

In general, it is permissible to weld near hydrocarbon piping without shutting in the production in that piping provided that the piping and associated connections are properly "made-up", well maintained and adequately shielded. Additionally, there must not be any factors that increase the risk of leakage such as pressure shocks or thermal shocks, excessive piping loads, corrosion, etc.

• Associated connections may include but are not limited to the following items: • Flanges • Screwed connections • Manual block valves • Check valves • Sample valves (with plugs installed) • Bleed valves (with plug or blind installed)

Welding near/on process control valves and gas actuated valves

These items should be treated as process equipment and addressed as defined in the thirty-five feet and ten feet requirements. This is because they are frequently and automatically stroked and thus pose a greater threat of introducing hydrocarbons into the hot work area via their seals and packing than do manual block valves. Actuated valves that utilize a flammable hydrocarbon to drive the actuator pose an inherent risk due to the release of gas during normal operation.

To reiterate, welding, burning or grinding should never be conducted in any area that is Classified Div 1 or Div 2 unless that area is shut in and/or shielded or rendered inert as prescribed by the thirty-five feet and ten feet restrictions. Refer to the facility Area Classification drawing to determine the classification of the area in which the work is to be performed.

5.2 Designated Safe Hot Work Areas Specific area(s) can be designated to be Safe Hot Work Areas. These areas must be pre-approved by Management in consultation with Health, Environment and Safety subject matter experts. These areas vary from facility to facility, and generally have the following characteristics:

• Do not contain combustible and flammable material within 10 meters (35 feet) of the area

• Free of flammable atmospheres

Hot Work carried out in the designated Safe Hot Work Area does not require a Hot Work permit, except when hot work is being performed on equipment which may have contained a flammable gas or liquid.

NOTE: When personnel are carrying only non-intrinsically safe devices (e.g., battery operated equipment or occupational hygiene monitoring equipment), these personnel must also carry a continuously monitoring gas detector. If the gas detector alarm sounds, they must immediately stop work and vacate the area and inform facility personnel of the alarm. No Fire Watch is required in these situations.

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Place/Location of Hot Work

Designated Safe-Welding (Hot Work) Areas

A specific area designated to be a safe welding (hot work) area. For OCS locations, the appropriate BOEM District Supervisor must approve each designated safe welding area. For Non-OCS locations, the BOEM criteria shall apply and the designation must be approved by the Operations Manager. These areas must be clearly identified on the facility and on facility plats. Hot work activities should be performed at designated safe, open, non-restricted fabrication areas when practical.

These areas:

• Vary from facility to facility • Must be clearly marked and identified • Shall not contain combustible and flammable material within 35 feet of

the area • Shall be free of combustible atmospheres • Must be approved by an BOEM District Supervisor; All BOEM

Districts will recognize this approval • Shall have a drawing posted at the facility showing the location of the

Designated Safe Hot Work Area along with the BOEM approval letter

A Daily Welding Permit or Daily Non-Welding Hot Work Permit shall not be required in Designated Safe Hot Work Areas, except when such hot work is being performed on equipment, which may have contained a flammable gas or liquid.

Undesignated Safe-Welding (Hot

Work) Areas

These areas shall include: • Those locations not identified as safe welding and burning areas; • Areas where equipment containing hydrocarbons or other combustible

materials are located within 35 feet of any hot work or burning operation.

• An appropriate Hot Work Permit shall be issued prior to the commencement of hot work in these areas.

Dual Classification Areas

There will be occasions where hot work will span both Designated and Undesignated Safe-welding (Hot Work) Areas. In these cases, you should follow the requirements of the Undesignated Safe-welding (Hot Work) Area.

Overboard Water

Discharge Points

30 CFR 250.113b states that while you weld, overboard water discharge point(s) must be monitored and if a flammable liquid is discharged, all welding must be stopped.

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5.2.1 Permit to Work All hot work requires permit authorization. Refer to the Permit to Work Process for instructions.

5.2.2 Hot Work Permit Hot Work Permits must be used in conjunction with a Permit to Work. Hot Work Permits are distinguishable from other permits. The permits must have a duplicate copy at a minimum. The permit and associated documentation must be available in the language appropriate for the Permit Approvers and Work Team Leaders.

The Hot Work Permit is broken into three sections: A, B, and C. The request for and completion of the Hot Work Permit requires:

Section A – To be completed by the Work Team Leader and submitted to the Permit Approver along with a Permit to Work as a request for entry.

Section B – To be completed by the Permit Approver.

Section C – To be signed by the designated parties, as applicable.

Hot Work Permits Relative to these Gulf of Mexico Hot Work Guidelines, there are only two permits that must be considered for Hot Work purposes - the Daily Welding Permit and Daily Welding Permit Instructions) and the Daily Non-Welding Hot Work Permit and Risk Matrix and Instructions

Permit Retention

Copies of all Hot Work Permits should be maintained at the respective headquarter facilities for three years. While this is not a regulatory requirement, it is considered a good practice for internal audit teams to be able to assess how well the Hot Work Guidelines and Process are being implemented. Previous audits have cited poor records for same as gaps to be addressed.

Special Note: Hot Work Permits must be re-issued for scope changes or changes in one or more of the issuing and/or authorizing personnel.

Hot Work Process Flowcharts

Process flowcharts for both types of Hot Work listed in the Types of Hot Work section are at the appropriate forms below. Important highlights include:

• JSAs • Welding equipment inspections • Fire watch requirements • Thirty-five and ten feet requirements • Permit copies and distribution • "Scope creep" issues

5.3 Permit Changes Permits are revalidated in accordance with the Permit to Work Process. In all cases, before a Hot Work Permit can be extended, there must be a valid Permit to Work in place for the period to be covered by the revalidation.

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5.3.1 Permit Revalidation Should site conditions change the Hot Work Permit must be revalidated before work can be restarted. Revalidation requires the Work Team Leader and/or the Area Controller to verify that all conditions and requirements on the permit remain in effect. The work may be resumed only after the Permit Approver has given approval to restart the permitted work.

NOTE: If work is stopped for more than 30 minutes without a Fire Watch present to ensure conditions do not change, the Hot Work Permit must be revalidated. Before the Hot Work Permit is revalidated the Permit Approver or designee must confirm the following:

• The Work Team Leader has not changed.

• The entire work crew has not changed.

• All conditions, requirements, and controls required by the Hot Work Permit, the related Permit to Work and the JSAs remain in place.

• The on-duty Qualified Gas Tester has conducted the required gas testing.

• Zero percent LEL is present.

• A valid Permit to Work is in place.

• The approved Fire Watch is assigned and present in the hot work area.

• The required fire-fighting equipment is on hand and in good operating condition.

• The Permit Approver and Work Team Leader have discussed the jobsite conditions and are in agreement that the work can be continued safely.

• The Permit Approver and Work Team Leader have authorized the Hot Work Permit in the revalidation section.

• All copies of the Hot Work Permit have been updated.

NOTE: The extension or renewal of a Hot Work Permit may be performed only by the Permit Approver during the shift(s) for which they are responsible for Hot Work.

5.3.2 Recording Changes Only the Permit Approver can make changes to the information on the permit. Any changes made must be documented on all copies of the permit and communicated to the Work Team Leader.

5.3.3 Permit Re-Evaluation Work must be stopped and the permit re-evaluated under any of the following conditions:

• Change of the entire work crew.

• Change of Work Team Leader.

• No qualified Fire Watch designated for the hot work.

• Change in jobsite conditions (e.g. a leak or spill in the area, environmental conditions change, or if there are conditions that go beyond those approved in the permit).

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• Serious injury, incident or near loss (near miss) at the jobsite.

5.4 Contractors Contractors shall use these guidelines unless they have been reviewed; through the Contractor HES Management, process to use their own procedure(s).

5.5 Jobsite and Equipment Preparation Competent personnel must complete the steps needed to properly and safely prepare the jobsite and equipment for the start of work.

Typical preparations that are specific to hot work may include, but are not limited to, the following:

• Removing combustible materials within 10 meters (35 feet) of the hot work area. If combustible materials can not be removed, they must be protected by fire-resistant coverings or shields, or kept wet.

All Tarps used for hot work purposes shall be Fire Retardant Tarps and shall meet the following specifications:

• Be red in color • Must have a durable label (affixed, marked or sewn) identifying it with either the letters

FR or the words Fire Retardant. • Be silicone coated or impregnated (to keep the material from becoming air borne / friable) • Have grommets

Note: Tarp applicability and inspection should be included in the Hot Work JSA's.

Tarps used for other purposes (blasting/painting, etc.) are not required to be fire retardant or meet the color and Fire Retardant Requirements.

• Sealing drains within 15 meters (50 feet) of the hot work by plugging and filling with water, or by another equivalent method, to form a seal. Vents in the vicinity of (including vents on the decks above and below) hot work shall be routed away from the vicinity of the hot work, or the input source to the vents shall be safely isolated.

• Barricade and mark the area.

• Arranging for continuous ventilation during hot work.

• Positioning fire-fighting equipment.

• Notifying facility personnel.

• Ensuring there is a designated Fire Watch at the jobsite.

• Inspecting all hot work equipment and ensure that it is safe to use.

• Gas-testing the jobsite and the surrounding 15 meters (50 feet) by a Qualified Gas Tester.

• Communicating to all affected parties through a pre-job briefing.

Shut-in/Shield Requirements

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The BOEM stipulates that Well Bays and Production Areas be properly shielded and possibly shut-in if the welding or hot work is to take place within thirty-five feet and ten feet respectively.

Thirty-Five Feet Restrictions

Any equipment containing hydrocarbons or other flammable substances must be moved at least thirty-five feet horizontally from the welding area. Move similar equipment on lower decks at least thirty-five feet from the point of impact where slag, sparks, or other burning materials could fall.

If moving this equipment is impractical, the equipment must be protected with flame proofed covers, shielded with metal or fire-resistant guards or curtains, or the flammable substances must be rendered Inert.

In addition, combustible materials must be moved from the area or properly shielded.

Ten Feet Restrictions

In addition to the thirty-five feet restrictions:

• Welding is not permitted within ten feet of a well bay unless you have shut in all producing wells at the surface safety valve (SSV) in that well bay.

• Welding is not permitted within ten feet of a production area unless you have shut in that production area. On satellite wells, any welding within ten feet of the wellhead requires closure of the SSV.

Atmospheric Vessels and Open Production Vessels

In addition to the 35ft. and 10ft welding restrictions you must insure that the person authorizing the permit for welding near atmospheric production equipment has conducted a discussion to account for all atmospheric equipment and identify additional safety precautions which may be required. Additional safety measures must be captured in the other precautions sections on the daily welding permit.

Primary concerns and discussion topics may include but not be limited to:

• Loss of Gas Blanket • Entry of Air by Thermal Cycling and Weathering • Some operations conducted during shut-in may introduce air into an Atmospheric

Vessel.

Well Bay and Production Area Clarity

The well bay is the area on the facility within the perimeter of the outermost wellheads.

Production Areas

Production areas are perhaps the most complex item to address in broad guidelines for diverse facilities. As described above in the Thirty-Five Feet and Ten Feet Restrictions, regulations stipulate that certain precautions, up to and including shutting-in of production, be taken in regard to hot work in or near production areas. On the surface, this seems simple, but as plans for hot work are being considered and developed, "What-if questions seem to come up immediately.

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The BOEM defines Production Area in 30 CFR 250 as: Areas where flammable petroleum gas, volatile liquids or sulfur are produced, processed (e.g., compressed), stored, transferred (e.g., pumped) or otherwise handled before entering the transportation process.

The following discussion is provided to assist personnel in determining the production area for your hot work project.

Consider the ignition source (welding arc, torch, etc) as the center of thirty-five feet AND ten feet radius (seventy feet and twenty feet diameters) spheres. If any part of a hydrocarbon production component/process equipment is within those spheres, then that component/equipment is defined as the "Production Area" and must be addressed as defined in the thirty-five feet and ten feet requirements.

Hydrocarbon components / equipment may include but are not limited to the following items

• Separators • Sumps • Other pressure & atmospheric vessels/tanks • Pumps • Compressors • Pig traps • Process control valves • Gas actuated valves • Meters • Drip pans • Non-plugged sample & bleed valves • Control panels utilizing hydrocarbons as a control medium

Caution: For ALL hydrocarbon components/equipment and piping within buildings or enclosures, the entire building/enclosure is considered to be a "production area" and it must be addressed as defined in the thirty-five and ten feet requirements. Potential accumulation of vapors in an inadequately ventilated area is the primary driver for this precaution.

Welding Equipment

Spark Arrestors and Drip Pans

Engine-driven welding machines shall be equipped with spark arrestors and drip pans. Exhaust piping from diesel engines shall be equipped with spark arrestors.

Shutdown Devices & Diesel Engine Air Intakes

Diesel engines that are continuously manned shall be equipped with either remote-operated manual or automatic air intake shutdown devices. The BOEM considers diesel engines "continuously manned" when personnel are on the same deck and level as the machine. Diesel engines that are not continuously manned shall be equipped with automatic air intake shutdown device to shut down the engine in the event of run-away.

Flashback Arrestors

All oxygen/acetylene set-ups MUST have a flashback arrestor check valve installed at the torch head AND at the regulators.

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Leads

All welding leads should be completely insulated and in good condition. The ground lead should be completely insulated and in good condition. The connection to the "structure" must be checked to ensure it is not loose. It should be monitored periodically to ensure it is not arching or sparking and if so, steps taken to correct it.

Oxygen and Acetylene Bottles

Oxygen and acetylene bottles should be secured in a safe place and in good condition. Pre-use inspections should look for corrosion, poor/loose connections, improper parts/fittings, etc. Hoses must be leak free and properly equipped with fittings, gauges, and regulators.

Shielding Materials

"Fire Blankets" are the preferred method for shielding production areas and equipment for hot work purposes as discussed in these guidelines. Fire Blankets are red, flame retardant fiber cloth that can be used dry when deployed as a vertical barrier or over head but must be wet when used below the hot work site. These tarps must have a durable label (affixed, marked or sewn) identifying it with either the letters FR or the words Fire Retardant. Combustible materials (e.g. poly-tarps, plywood) are not to be used as hot work shields.

Inspection of Welding Equipment

The Welding Supervisor is responsible for ensuring the welding equipment meets specifications above as well ensuring that it works properly. The welding job must be deferred until all deficiencies are corrected.

Firefighting Equipment

Usable Firefighting Equipment

Firefighting equipment that has been inspected and properly maintained as required by regulations and/or policy AND is expected to perform as it is intended. The fire watch must know how to operate each specific type of equipment in the area that may be used in the event of a fire. The Representative must ensure the fire watch is capable of operating the equipment.

Additional preparations specific to opening equipment may include, but are not limited to, the following:

• Ensuring positive isolation refer to Isolation of Hazardous Energy (formerly LO/TO process)

• Depressurizing

• Purging, flushing, draining or venting

5.6 Gas Testing Requirements Gas testing is required prior to hot work except in designated Safe Hot Work Areas. Gas testing must be performed by a Qualified Gas Tester. The frequency of gas testing shall be stated in the Permit to Work for approval.

1. Contractor provided gas detectors.

In general PHD 5 gas detectors should be replaced with the new standard MSA-ALTAIR 5 as repairs or maintenance becomes necessary on existing units. Operations personnel may elect a different schedule based on their specific needs. It is desired to remove all PHD 5 gas detectors by December 31, 2010.

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It is recognized that certain conditions and situations may require a deviation from this guideline. However, all such deviations must be presented and approved by the OELT AND meet the following minimum requirements:

• Have multiple alarm modes (audible, LED, vibration) • Have some sort of auto calibration • Have in-field maintenance capability

2. Welding contractors and 3rd party contractors on drilling rigs.

Contractors may use the gas detector of their choice provided their personnel are trained/qualified to operate that specific model. All maintenance and calibration records as well as appropriate documentation should be made available onsite. Calibration and Testing Warning! To calibrate or bump test this unit, you must use the approved calibration gas provided from the unit distributor or an equivalent quality calibration gas. For "0" calibrations make sure the instrument is located in fresh air.

Calibration

Application of a known concentration of gas applied to the unit to verify the detector responds accurately through its entire range. Calibrations should be performed per the manufacturer's suggested calibration schedule. For the BioSystems PHD models, this is every 30 days. Since some units may not be used often enough to merit such calibration, these units MUST be calibrated prior to use.

Bump Test

Application of a known concentration of gas applied to the unit to verify the detector alarms at specified limits.

Bump test should be performed prior to the first time a detector is used each day. It may be bump tested more often.

It is not acceptable to use acetylene or pure natural gas to perform a Bump Test.

Good Practice Ideas: Some groups are recording some atmospheric test results on the back of the Hot Work Permit. They are capturing Time, Oxygen %, LEL %, and H2S (ppm).

Smart shall be used to document the monthly calibration and testing Gas Detection Units..

Fixed Gas Detectors

A fixed gas detector may not be used in lieu of a portable gas detector for hot work purposes. The primary reason for this is that the fixed detector is not likely to be "in the vicinity" of the ignition source(s).

Actions to be taken in event the gas detector's alarm(s) go off:

1. Notify all personnel associated with hot work immediately.

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2. If welding job is in progress, stop all welding activities and turn off all equipment. 3. If non-welding hot work is in progress, stop all spark-generating items such as grinders,

etc. 4. DO NOT turn off or power down any PEDs such as laptops, etc. 5. DO NOT turn on or power up any PEDs such as laptops, etc. 6. Evacuate personnel to a safe area. 7. Carry the gas detector with you. 8. Notify the Company Representative and await further instructions.

5.6.1 Initial Gas Testing Initial gas testing must include testing for oxygen and flammable vapor or other toxic gases and vapors as identified in the hazard analysis. The types and frequency of gas testing required must be based on the location of the hot work and potential hazards. The results of such a test will be used to determine:

• Whether the area is safe for hot work

• Whether additional vessel purging is necessary

• Time limitations for hot work to be conducted

Initial testing must be performed after the hot work jobsite and equipment have been properly isolated and prepared.

Gas testing for LEL must be performed in the surrounding area for a distance of 15 meters (50 feet). Hot work must not be performed if the LEL is greater than zero percent and/or if residues of combustible liquids are present except for hot tapping, for which specific precautions must be taken.

If gas test results indicate greater than zero percent LEL, the source of the flammable gas or vapor must be identified and actions must be taken to eliminate it.

NOTE: If, at any time during the performance of the hot work, subsequent gas testing reveals an LEL of greater than zero percent, then the hot work is to be immediately stopped and the Hot Work Permit must be re-evaluated. The Hot Work Permit may not be reissued until the source of the flammable vapor is determined and eliminated and further gas testing indicates a zero percent LEL.

5.6.2 Work Delays The hot work must occur within an agreed period of time after the work is authorized. In all cases, if the hot work did not start within 30 minutes after the Qualified Gas Tester has tested the area and cleared it for hot work to start, the Hot Work Permit must be revalidated before hot work can begin again.

5.6.3 Follow-up Gas Testing The Qualified Gas Tester will determine the frequency of follow-up gas testing based on the potential identified hazards. The required frequency of gas testing must be noted on the Hot Work Permit.

NOTE: Any hot work performed inside a confined space requires continuous gas testing in the area of the Hot Work.

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5.7 Conditions for Work Stoppage During any non-emergency work stoppage, work site must be left in a safe condition, for example, non-essential equipment must be turned off and secured. Work must be stopped and the Permit Approver and Work Team Leader must reevaluate the Hot Work Permit if the jobsite is left unattended and/or under any of the following conditions:

• Changes in jobsite condition(s) that present a risk after permit issuance

• LEL greater than zero percent is detected

• Portable or continuous gas test equipment failure (for example, battery depleted)

• Change in scope of work, such as additional work not originally anticipated

• A safety concern has been raised by a worker or company representative

• Occurrence of a minor incident or near loss during a job task

• The job is left unattended

• When the environmental conditions change

• The Fire Watch leaves the hot work area

• The original finish time listed on the Hot Work Permit has been reached

• The Permit to Work is no longer valid

5.8 Fire Watch A person must be designated to act as a Fire Watch. They must be competent and equipped to perform Fire Watch duties.

Fire Watch duties must be maintained for at least 30 minutes after hot work ceases. During this time, the Fire Watch must inspect the adjacent areas where sparks or flames may have traveled and look for signs of combustion.

NOTE: When personnel are carrying only non-intrinsically safe devices (e.g., battery operated equipment or occupational hygiene monitoring equipment) these personnel must also carry a continuously monitoring gas detector. If the gas detector alarm sounds they must immediately stop work and vacate the area and inform facility personnel of the alarm. No Fire Watch is required in these situations.

5.9 Work Completion When the work has been completed, the Work Team Leader must return the Hot Work Permit and permit-related documents to the permit approver. The permit approver or designee must review the jobsite to ensure that the following conditions have been met:

• The jobsite has been left in a safe, clean and orderly condition.

• At least 30 minutes has elapsed for the Fire Watch to verify the condition of the jobsite.

• The work performed meets the required scope and specifications.

If the above conditions have been met, the permit approver or designee must sign and date the Hot Work Permit to signify completion.

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6.0 Records

6.1 Required Records The following records will be kept:

• Copies of permits and associated documentation shall be maintained in accordance with the Permit to Work Guideline.

6.2 Retention Requirements Documentation shall be retained as required by local regulation, company policy, or for a minimum of six months, whichever is greater.

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