TITLE Pipelines & Distribution/Volume 3 - Maintenance

SECTION 02: Critical Procedures

SUBJECT 10: Entering on Internal Floating Roofs - Tanks

PURPOSE AND SCOPE

The purpose of this subject is to document the procedures for entry onto internal
floating roofs (IFR) in all product tanks in order to drop or lift roof support legs or
perform seal inspections.

REFERENCE

PDM 01-04-06: Safety: Personal Protective Equipment

PDM 03-02-02: Critical Procedures: Confined Space Entry

PDM 03-02-05: Critical Procedures: Lockouts and Forceful Removal of a Lock

PDM 03-23-03: Safety & Environmental - Personal Safety: Air Testing and Monitoring

ASSOCIATED DOCUMENTS

0302F05.Doc: Tank Entry onto Internal Floating Roof Checklist

0302F21.Doc: Confined Space Equipment Checklist

DEFINITIONS

EM TCP

ExxonMobil Tank Cleaning Plan

PROCEDURE

Rationale for Entering onto IFRs

Descent onto a floating roof tank while it is in hydrocarbon service can be hazardous.
Only essential work should be performed and it should be limited to cold work.
There are three reasons that justify the confined space entry when the tank is filled with
hydrocarbon:

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Pinning/unpinning IFR legs in the maintenance position.

Unpinning legs in operating position.
Checking floating roof seals as per API Inspection Checklist

Background

The internal floating roofs support legs are normally in the minimum inventory position
and are landed at varying heights as low as 2.4 feet. The roof legs must be pinned at
the maintenance positions (6.5 to 7 feet) before a tank is taken out of service so that
cleaning, inspection and other work can progress safely.

NOTE: This procedure is also valid if unpinning legs when the tank is filled with
hydrocarbon.

Roof Construction

Internal floating roofs are historically designed to support a minimum of 500 lb./sq. ft.
Most roof designs exceed this minimum requirement. Tank IFR construction and
integrity to be reviewed prior to any planned entry onto the IFR.

Procedure Limitations

This procedure for entering IFR tanks has defined limitation. If variables are outside of
the documented limitations, a separate safe work plan must be developed.

Note: It is required to complete the leg pinning/ unpinning work, as per the EM TCP
guidelines. No one is permitted to enter the tank for this work, unless an IOL assigned
representative is on site, to supervise the work.

This procedure is not valid for Mayflower floating aluminum roofs without platforms.

Conditions for Entering on the Roof of an IFR Tank in Product Service

Before entering a tank that is in product service, the following conditions should be
observed:

An experienced and approved IOL ATCS or OSSR must be appointed to direct and
be responsible for the entire operation.

All necessary equipment must be on site and must have been checked to make sure
that it is working properly. (As per the Confined Space Equipment checklist PDM
0302F21).

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At least one person must know and have qualified experience with gas testers.
Tests must be made for oxygen and vapour (flammability) content. Results must be
within the limits defined in Table 1 of PDM 03-23-03. (IOL Assigned Rep.)

Roof exhaust eductor ventilation may be used, where required, to gas free the space
above the IFR sufficiently and if needed maintain it within the Table 1 defined
limits. (As per the EM TCP & PDM 03-02-30).

If weight limitations/restrictions are not known check with the tank (floating roof)
manufacturer to determine whether the floating roof is safe to walk on. If the
condition is not known include the API approved Inspector as part of the team and
complete a full inspection of the IFR prior to the leg pinning activity. The
maximum allowable weight concentration may also be checked with the help of
EMP Tank Specialist contact. NOTE: Test can be done with sandbags.

If the floating roof does not have walkways, plywood boards or a snow fence may
be used to walk on (aluminium roofs only). Work must be performed from these
walkways.

The level of the floating roof should be as high as practical but not less than 75%.
The roof should have been at this level for at least four hours.

The fixed cone roof must have been inspected and found safe to walk on. Plywood
boards may be used where the roof cover steel plate integrity may be uncertain.

All inlet and outlet valves should be closed and locked or car sealed in the closed
position.

All electrical equipment on the tank and including motorized valves should be
locked out at the main panel and padlocked (PDM 03-02-05).

Atmospheric conditions must be acceptable for entry to the tank, i.e., no electrical
storms in the forecast.

All precautions to control static electricity must be taken, i.e., bonding equipment to
the tank, wearing anti static clothing covers, touching bare tank metal with bare
hand for a few seconds at a gas free location prior to entry.

All roof manholes and hatches must be left open.

H2S monitors are required if the Site Manager deems that there is an H2S risk.
(PDM 03-23-03)

Enough people must be available to take part in the operation:

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Workers

Tank Diameter:

Less than 50 ft. - Three-person crew

50 - 100 ft. - Four-person crew

Larger than 100 ft. - Five-person crew

The contractor is to meet the minimum personnel requirements by provincial OH & S

standards. In addition, the specifics of the entry may require personnel greater than the
above noted minimums.

Worker Positioning

At the bottom of the external stairs.

At the top manhole - communication device available.

If more than one person inside - one person will remain at the bottom of internal
ladder.

Personal Protective Equipment (PPE)

Follow PPE procedures (PDM 01-04-06 and Table 1 in PDM 03-23-03)

All workers must have fresh air breathing air equipment.

Inside worker must wear full-face mask; external workers must have full-face
masks available.

Workers who enter the tank must wear and use supplied air breathing
equipment.

They must also wear a safety harness with a lifeline attached to a means of
retrieval, such as a winch.

The person at the manhole must also be equipped with fresh air breathing
equipment for use in case entry should be made into the tank for rescue.

The person outside at ground level must have available, supplied air breathing
equipment and some means of communicating (such as a two-way radio) with
the terminal/plant office.

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One of the two workers positioned outside (or someone on site, readily
available), will have been trained in cardio pulmonary resuscitation (CPR).

Initial Tank Entry

Before entry is made into the tank, gas testing for O2 and LEL content must be
conducted through the cone roof manholes and hatch vents. (PDM 03-23-03)

Samples should be taken at one-foot intervals above the floating roof to ensure that
LEL vapours are not stratified in the confined space.

At this time, a visual inspection of the internal ladder and floating roof must be made to
indicate physical condition and whether there is any liquid on the floating roof.

When gas test samples are found to be within permissible limits, and visual inspection
reveals no obvious mechanical deficiencies, personnel may descend onto the roof.

A most important consideration is adequate safe lighting. Whether light is from hand
held flashlights or from external power source, the equipment must be explosion-proof
or intrinsically safe.

The supplied air breathing equipment must be used continuously throughout the stay in
the tank, because of the potential sudden release of hydrocarbon vapour past the seal.
Gas testing must also be made continuously while work is in progress.

Absolutely no hot work shall be performed in the tank.

Equipment Required For Tank Entry

The following equipment and tools are required for entering tanks:

One SCBA rated at 30 minutes and one spare air cylinder per person at site or other
supplied air breathing equipment.

1/2" lifeline and lift body type safety harnesses (minimum length is the tank
diameter)

one combustible gas/vapour tester with a minimum a 1.9 meters (6 ft.) probe

one oxygen analyzer

rescue equipment available at tank entry manhole

one portable explosion-proof flashlight per person

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One fire extinguisher, 9 kg (20 lb.) dry chemical at entry manhole and one on top of
the stairs.

one rescue type stretcher that fits through entry manhole available on site

Confined Space Entry Form

Follow these procedures, in conjunction with Confined Space Entry Procedures

(PDM 03-02-02)

Complete form 0302F03.Doc, and have signed off appropriately.

Entry Checklist

Complete form 0302F05.Doc.

Rescue Considerations

Tank entry is to be completed with full-face fresh air breathing equipment in place.

In the event of an emergency, communication is a prime responsibility.

The outside safety watchman will not attempt any rescue support unless additional
help is present at the manway.

The individual with CPR skills should not go into the tank unless there is no other
alternative. The victim should be extracted if possible prior to first aid activities.

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