BP OIL -- TOLEDO REFINERY

Document Type: Procedure No.:

Procedure Refinery Wide SAF 033

Effective Date: Revision No.: 2

February 28, 2018 Inert Entry

Owner: Authorized By: Chris Conley Page 1 of 23

Michael Stack

SCOPE This policy applies to all BP and Contract employees

performing work in and around an area where inert entry
work is being performed.
HEALTH Inert entry tasks involve entering confined spaces that
are oxygen deficient and a known IDLH Atmosphere. No
Special PPE & Special Hazards BP Employee is permitted to enter an inert atmosphere.
SAFETY Chemical and physical hazards exist when completing
inert entry into confined spaces. These hazards include
IDLH atmospheres due to nitrogen in a confined space,
pyrophoric hazards, and catalyst dust.
REFERENCE API Standard 2217A -- Guidelines for Safe Work in
DOCUMENTS Inert Confined Spaces in the Petroleum and
Petrochemical Industries
MAINT-E-033 Cranes and Lifting
SAF-032 – Confined Space Entry
SAF-023 – Using Direct Reading Gas Testing
Equipment
SAF-026 – PPE Policy
SAF-033-FM- 01 – Inert Entry Confined Space Permit
SAF-037 – Lock Out/Tag Out Procedure
SAF-086 – Use of Nitrogen
SAF-109 – Respiratory Protection Program
SAF-116 – Barricading of Hazardous Activities
COW-PRO-002 – Control of Work Policy
OSHA Standards – 29 CFR 1910.132, 134, 146, 147,
1000, 1200
BP Technical Group Hydroprocessing Handbook
D-PRO 4.5-0100 Catalyst Change Out - Confined
Space Inert Entry

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 Procedure No. SAF-033 Rev. No. 2

SPECIAL MATERIALS & Supplied airline respirators, life support helmets,

EQUIPMENT breathing air monitoring systems, video recording
systems, speciality gas testing equipment

QUALITY Nitrogen quality must be maintained during inert entry

activities.
ENVIRONMENTAL Catalyst removal generates waste. Environmental
policies are required to be followed.

1.0 Definitions BP Contact – An individual designated by BP to be the point of

contact between the Specialty Contractor and Operations. This
individual must be clearly identified and is typically a
maintenance Supervisor (Performing Authority) or TAR staff
member.

Confined Space – Any space large enough and so configured

that an employee can enter and perform assigned work, has
limited or restricted means for entry or exit, and is not designed
for continuous employee occupancy.

Entry Supervisor- The person responsible for determining if

acceptable entry conditions are present at a confined space
where entry is planned, for authorizing entry, overseeing entry
operations, and for terminating entry. The duties of entry
supervisor may be passed from one individual to another during
the course of an entry operation. These responsibilities also may
be transferred between the owner and contractors.

Hazardous Atmosphere – An atmosphere that may expose

employees to the risk of injury, incapacitation, acute illness,
impairment of ability to self-rescue (to escape unaided from a
confined space), or death.

Hot Zone – The area around the entrance to the inerted

confined space most likely to be affected by effluent gases;
sometimes called the “restricted area.”

Inert Entry – Entry into a confined space that has / is purged

with an inert gas (oxygen deficient).

Inert Entry Watch/Top Side Attendant – This is an authorized

and trained representative from the Specialty Contractor who will
watch and monitor the entrant working in an inert atmosphere.
The Inert Entry Watch will be required to wear the same PPE as
the person making the inert entry.

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 Procedure No. SAF-033 Rev. No. 2

Immediately Dangerous to Life or health (IDLH) -- The

maximum concentration of an air contaminant from which one
can escape without experiencing any escape-impairing or
irreversible health effects. Total loss of respiratory protection in
an inert atmosphere can cause virtually immediate impairment
and result in rapid asphyxiation and death.

Life Support Unit (LSU) – The Life Support Unit is a module

that is staged in the unit where all inert communications,
monitoring, videotaping and data collection takes place. Staging
of the LSU will be decided by BP Operations and the Specialty
Contractor.

Nitrogen (N2) Purge –The process of introducing nitrogen into a

reactor or vessel for the purpose of eliminating oxygen, thereby
preventing combustion.

Nitrogen Supply Contractor – External party that supplies a

source of nitrogen

Oxygen Deficient Atmosphere -- an atmosphere in which the

oxygen (O2) content is below that needed for normal human
function without impairment (below 19.5% O2).

Risk Assessment –Systematic examination of a task in order to

identify all hazards, assess all risks, and identify safe methods of
work to ensure that the hazards are eliminated or the residual
risks are minimized. This is completed as an element of the
Control of Work Program.

SDS – Safety Data Sheet

SIMOPS (Simultaneous Operations) –Other jobs or operations

in the vicinity of the work, including members of your own work
group, which may affect or be affected by the hazards of a task

Specialty/Catalyst Contractor – Contracted by BP to perform

activities in oxygen deficient vessels or reactors

Pyrophoric– A material (e.g. iron sulfide, certain catalysts or

certain carbonaceous materials) that, when exposed to air, can
spontaneously oxidize and heat, providing a source of ignition if
a flammable vapor/air mixture is present.

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 Procedure No. SAF-033 Rev. No. 2

2.0 Roles and Resposibilities

Inert Entry Contractor
Entry Supervisor  Implement the Inert Entry Execution Plan.
 Execute the Emergency Response Plan if necessary.
 Determine if acceptable entry conditions are present.
 Terminate entry when required.
 Supervise the entry crew.
Inert Entry Watch  Monitor the confined space entrant activities.
 Initiate emergency response plan if needed.
Inert Entry Contractor  Perform continuous monitoring at the point of entry (i.e. the Hot Zone/Exclusion Zone) to
Topside Supervisor ensure that the barricades are broad enough to protect those outside the Hot
Zone/Exclusion Zone). (Note 1)
Life Support Unit (LSU)  Record the continuous gas monitoring readings on the inert entry log after initial entry and
Attendant once per shift thereafter when the entrant is inside the confined space.
 List by name each entrant on the entrant log and record the times they enter and exit the
space.
 Verify by video that the catalyst height differential does not exceed waist level.
 Verify shift logs document minimum/maximum catalyst bed levels.
 Record all alarms activated, false or actual when working under inert conditions after
preparation for entry..
CSE Rescuer  Perform rescue inside the inert confined space. (Note 2)
 Assist in pre-entry verification of response systems and procedures.
BP
BP Contact  Point of contact between Inert Entry Contractor and BP Operationas and supporting craft.
Inert Entry Single Point of  Authorize entry (can be delegated to the permit issuing authority as defined in D-PRO 4.5-
Accountability (SPA) - or 0001).
delegate. (SAF 033 Owner)  Verify the safe execution of confined space inert entry related activities by BP and the Inert
Entry Contractor personnel.
 Verify the Inert Contractor’s Inert Entry Execution Plan and Emergency Response Plan is
reviewed by a BP Safety Advisor.
 Complete the self-verification checklist.
 Recommend inert entry execution plan.
Emergency Response  Review and agree with the Inert Entry Contractor’s Emergency Response Plan.
Specialist  Coordinate Emergency Response planning with Inert Entry Contractor prior to entry.
Operations Manager  Recommend inert entry is preferred over alternative methods.
 Approve Task Risk Assessment per D-PRO 4.5-0001
 Approve Inert Entry Execution Plan.
Site HSSE Manager or  Review the Inert Entry Execution Plan.
Delegate  Agree on approval of inert entry execution plan.
S&OR Entity Director  Agree on inert entry versus alternatives as part of planning process.
Entity Leader  Decision on inert entry versus alternatives as part of planning process
Notes:
1. The role of inert entry watch and Inert Entry Contractor topside supervisor can be the same individual if the BP SPA
determines that this is acceptable / possible.
2. The CSE Rescuer cannot enter the space for any reason including rescue until a second rescuer is in place with prope r
PPE.
3.0 Inert Entry Planning __3.1 The unit process engineer shall review all reasonable
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 Procedure No. SAF-033 Rev. No. 2

alternatives to inert entry prior to the work proceed to the

planning phase.

1. Use of hydrocarbon based catalyst passivation (e.g. –

CatNap) in fresh air shall not be considered.

2. Use of water flooding shall be considered.

Note
Additional background on water flooding as an option
to inert entry can be obtained from the Refining
Technology & Engineering (RTE) Hydroprocessing
Group.

3. Other viable alternatives may be proposed to the

S&OR Entity director for consideration.
__3.2 The written recommendation of the unit process engineer
will be forwarded to the site Operations Manager for
consideration. The Operations Manager makes the final
recommendation to the Business Unit Leader that the inert
entry is the preferred method.
__3.3 The Business Unit Leader decides whether catalyst
handling activities using inert entry may procced to the
execution phase with agreement form the S&OR entity
director.
4.0 Contractor __4.1 For the initial contractor selection process, The
Selection Inert Entry Contractor shall submit the following for BP
review:
a. Inert Entry Contractor policies & practices
pertaining to:
i. Work zone control and Hot Zone/Exclusion
Zone barricading
ii. PPE
iii. Atmospheric monitoring
iv. Emergency response plan
v. Heat stress/fatigue management
vi. Loading sock/equipment integrity
1. Refer to D-IG 4.5-0002 for additional
information loading sock equipment
and integrity.
vii. Training program
viii. Any other Inert Entry Contractor practices or
procedures for inert entry
b. Experience level for all Inert Entry Contractor staff
planned to be on site for the job.
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 Procedure No. SAF-033 Rev. No. 2

5.0 Nitrogen Purge __5.1 Operations have responsibility for establishing a

nitrogen purge on the inert entry space.

__5.2 Primary nitrogen supply to the vessel may be

sourced from the plant nitrogen system or an independent
supply (usually truck). The primary source of nitrogen will
be a joint decision between Technical Engineering and
Operations.
a. The Reformer 3 Dedicated Nitrogen System cannot
be used for anything other than maintaining the
nitrogen bubble between the reactor and regen. No
connections to the Reformer 3 Dedicated Nitrogen
System can be made for any other purpose,
including inert entry activities.

__5.3 A back up nitrogen source must be available in the

case that primary supply is lost. The plant nitrogen system
cannot serve as both the primary and backup supply for
the same vessel.

__5.4 A Quality Assurance Plan for the source nitrogen

must be established by technical engineering prior to
beginning inert entry activities. This can be documented
as part of the Level 2 Risk Assessment and should include
methods for collecting samples, acceptable limits, and
frequency of samples.

__5.5 A relief valve must be present on the nitrogen truck

lines to prevent overpressure.

__5.6 Ensure that internal pressure of the inert confined

space is not increasing because of the inerting gas.
(bottom measurements and observation of back pressure
can be used in most cases since inert gas is often
introduced at the bottom of the vessel and flows out the
top).
a. A back pressure test must be performed when
nitrogen is being introduced through the bottom of
the reactor.
b. The nitrogen backpressure test shall be as follows:
i. Install a pressure gauge on the nitrogen
supply, as near to the vessel as practical.
ii. Block in nitrogen supply and record time for
pressure to drop to atmospheric pressure.
c. If the time to reach atmospheric pressure exceeds
5 seconds, entry to the confined space shall be
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 Procedure No. SAF-033 Rev. No. 2

prohibited as long as nitrogen continues to be

introduced from the bottom.

__5.7 Control of all nitrogen supply valves to the inert

space will be transferred to the Specialty Contractor. The
Specialty Contractor must tag these valves with legible,
substantial tags that clearly indicates who is in control of
the valve. Where the contractors program does not define
the tag to be used. Use the tag in Appendx C.

6.0 Isolation, Lock __6.1 Inert entry requires positive isolation of the confined space,
Out/ Tag Out, and other than the nitrogen supply.
Permitting
__6.2 The refinery isolations practice shall be adhered to.

__6.3 The Specialty Contractor may use their own Lock Out/ Tag
Out locks and program provided that it meets or exceeds
OSHA regulations. The Specialty Contractor will place a
blue foreman’s lock onto the operations lock out point
(key).

__6.4 The BP Performing Authority, Specialty Contractor

Supervisor, and BP Safety Advisor are required to walk
down the isolation plan prior to authorizing inert entry.

__6.5 SAF-033-FM-01 Confined Space Entry Permit for Inert

Entry will be issued in place of a standard Confined Space
Entry Permit while Inert Entry is taking place. A defined
representative from the Specialty Contractor will serve as
the Entry Supervisor. The Specialty Contractor will
maintain their own Confined Space Entry documentation(
sign in/out logs and gas testing results)

__6.6 A standard Confined Space Entry Permit will be issued and

isolations re-verified if the vessel will be turned over to
regular atmosphere for entry.

7.0 Ignition Sources __7.1 All lights, tools, and cameras used in the confined space
and Tools must meet the area electrical classification.

__7.2 Any air driven tools used in an Inert Confined Space will be
driven from nitrogen, not air.

__7.3 Catalyst loading/unloading equipment will be properly

grounded and bonded.

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 Procedure No. SAF-033 Rev. No. 2

8.0 Atmospheric __8.1 Atmospheric conditions within the inert entry confined
Conditions space must be maintained within the following limits:
o Oxygen – 0% - 4%
o Lower Explosive Limit (LEL) - <10%
o CO - <50ppm
o Hydrogen Sulfide - <10ppm
o Ambient Temperature - <100°F

WARNING
Specialty gas detection equipment is required for use in
inert atmospheres. Contact the Safety Department for
these instruments. The MSA Altair, Sirius, and BW Micro
5 cannot be used for the testing. (exception exists for the
Altair with dilution fitting)

__8.2 If any of the above limits are exceeded or if either the

vessel internal atmospheric or catalyst bed temperature
increases 5°F in 15 minutes , an evacuation of the space is
required.

__8.3 Initial gas testing of the inert entry confined space will be
performed by the Specialty Contractor and observed by a
BP Safety Advisor (must also be a Level 1 Authorized Gas
Tester). This must include Oxygen, LEL, CO, total
petroleum hydrocarbon (a.k.a volatile organic compounds),
benzene, and H2S. The BP Safety Advisor will sign the
initial gas testing result on the Entry Permit. The BP Safety
Advisor is required to confirm the Specialty Contractor is
utilizing acceptable gas testing equipment for the inert
atmosphere and the device is within calibration.

__8.4 Continuous gas testing of the space is required. All

continuous gas testing must be performed with the
entrants. The tubing on the gas detection devices must be
sufficient to test the atmosphere at the elevation the
entrants are located.

__8.5 Both a primary and secondary gas detector are required to

be in place prior to entry operations. The secondary (back-
up) shall be appropriately calibrated, charged (full
batteries), and ready for use in the event of primary
detector failure. The secondary device may be turned off
until needed.

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__8.6 The Specialty Contractors logged gas testing readings will

serve as the entry gas testing results after the initial test.

__8.7 Continuous internal atmospheric temperature monitoring

must be in place by the Specialty Contractor.

__8.8 Any use of TI’s to monitor temperature is governed by the

hydroprocessing handbook: Attachment 21 - Reactor
Temperatures for Entry. The unit process engineer should
provide input to the Level 2 Task Risk Assessment on this
subject as it varies depending on the vessel.

9.0 Breathing Air __9.1 The Specialty Contractor is responsible for all breathing air
Supplies supplies, equipment, testing, monitoring, and inspection
outlined in this section.

__9.2 The minimum respiratory protection requirements for inert

atmosphere entrants and the top side attendant are:
o Two (2) completely independent continuous air
supplies and one secondary emergency egress air
supply bottle.
o Lock-on life support helmet equipped with
communication ability. This equipment will meet
NIOSH, MSHA, or other equivalent standards.
o All umbilical lines (breathing air and
communication) must be shielded from damage by
a sufficient protective coating/sheath such as PU
(UDF 20430) or an equivalent method.
o Primary air pressure monitor for each individual
wearing helmet with audible and visual alarms to
indicate low primary supply and regulated pressure
o A secondary air pressure monitor for each
individual wearing a helmet, including an alarm
indicating the cut-in of the secondary supply to any
of the helmets and to alarm to indicate a low supply
pressure.

__9.3 All umbilical lines being run to elevation will be secured as

much as feasible to minimize movement of the lines due to
wind.

__9.4 A battery-fed power supply must be equipped to cut in

automatically on failure of the electrical supply to the
breathing air monitoring system.
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__9.5 The Specialty Contractor will complete a documented pre-

use inspection to ensure physical integrity and cleanliness
of equipment.

__9.6 Refinery air systems shall not be used to supply breathing

air.

__9.7 The Specialty Contractor must continually monitor the air

supply of the workers in and near the confined space. This
person is responsible for ordering the evacuation of the
space if the breathing air system is compromised or goes
into an alarm state.

__9.8 The Specialty Contractor will ensure that purchased

breathing air meets, at a minimum, Quality Verification
Level D (formerly called Type I, Grade D), breathing air.

__9.9 The Specialty Contractor shall train and fit test all
employees on the use of respiratory protection equipment
in a manner that meets or exceeds OSHA requirements.
Training records and fit test records must be made
available upon arrival on site to perform work. The BP
contact will review these records.
10.0 Logs and Video __10.1 The Specialty Contractor is required to provide a copy of
Monitoring their log at the end of each shift to their designated BP
Safety Advisor. The following information must be
included at a minimum:
o Entry and exit dates/times of all personnel
o Gas testing results for Oxygen, LEL, CO, H2S, and
ambient temperature every 15 minutes.
o Catalyst bed outages and conditions every hour
o Any changes to catalyst removal methods or tools
o Any changes to how nitrogen is being supplied to
the reactor, including flow rates.
o Any evacuations of the space due to changes in
atmospheric conditions or safety concerns

__10.2 The Specialty Contractor must have video surveillance

and recording capability. Recordings must be made
available to BP upon request and retained by the Specialty
Contractor for 30 days following the inert entry.

__10.3 The Specialty Contractor will perform a recorded video

sweep (360°) around the current work location of the
entrant every hour.
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11.0 Internal Work __11.1 The Specialty Contractor will have a work practice
Practices in place to prevent the engulfment of the entrant in
catalyst.
o The Specialty Contractor shall never allow the
catalyst wall height to exceed 3’ or waist height of
the entrant, whichever height is lower, relative to
the lowest level of the catalyst bed.
o The Specialty Contractor shall never allow catalyst
to build up on walls or structures or in a manner
that they could collapse and engulf or injure the
entrant.
o Entrants shall not leave the hard ladder nor stand
on any portion of the bed if a waist high differential
in the bed’s height exists.

__11.2 The Specialty Contractor will provide and stage for

use a spare vacuum hose of sufficient length to replace a
hose damaged by catalyst bed cave-in. This hose must be
rapidly deployable for rescue use.

__11.3 No Entrants into the inert space will exceed a

continuous interval of four hours in the space without at
least a 45 minute break period outside the space. An 30
minute extension, may be provided on a case by case
basis with approval of the BP Contact, and BP Safety
Advisor supporting this activity.

__11.4 If a cable/rope ladder is going to be used in place of

a hard ladder it must be documented in the Level 2 Task
Risk Assessment. The ladder must be secured at each
tray and the bottom of the vessel.

__11.5 The Specialty Contractor must assign a trained

individual to monitor the following items continuously:
o Breathing air supply
o Gas detection readings
o Communications from entrant and top side
attendants
o Radio channel 16A and the operations radio
channel (must have 2 BP radios)

__11.6 When feasible sock loading the length of the sock

cannot exceed 25 feet. The sock and associated
equipment must be protected from falling into the vessel.
Longer socks are only permissible when there is no other
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 Procedure No. SAF-033 Rev. No. 2

feasible alternative; and the required evaluations and

requirements in the Hydroprocessing Handbook Chapter
7.6.1 are implemented.

__11.7 The Specialty Contractor will submit their procedure

for securing the sock and associated equipment from
falling into the vessel. The BP contact will review these
procedures and approve them or require added controls.
These added controls will be documented as part of the
Level 2 Risk Assessment.

__11.8 The Specialty Contractor will ensure that the

primary and back-up inert entry staff are equipped with
two (primary and secondary) communication devices.

Note
The secondary communication device can be a signal
device (such as an air horn), or other means of
communication that can be used to let the entrant
know that the primary communication device is not
working and the entrant needs to evacuate the space.

12.0 External Work __12.1 The Specialty Contractor is required to present a plan that
Practices includes their barricading procedure to control access to
the work area. This includes work at grade, at heights,
and establishing the “hot zone” on the top side of the
vessel.

__12.2 The restricted work areas will be established and

monitored by the Specialty Contractor. Signs will be
posted that clearly warn that nitrogen is present.

__12.3 The Specialty Contractor will have exclusive control of the

“hot zone” on the top side of the vessel. Only Specialty
Contractor personnel are permitted within the “Hot zone.”
BP Employees are prohibited from entering the hot zone,
including for purposes of rescue.

__12.4 Non-specialty contractor personnel may be permitted in

the topside area with specialty contractor approval,
provided it is not a hot zone. This is provided the entry to
the inert space is covered with a hard barricade, and gas
monitoring shows no oxygen deficiency outside the space.
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__12.5 The Specialty Contractor will define areas that require

respiratory protection, including catalyst handling work at
grade.

__12.6 A solid cover shall be used to prevent access to the

main vessel entry point when entry is not in progress.

__12.7 Individuals that are loading catalyst into open containers

under a nitrogen purge will be required to utilize airline
respirators. (see diagram in Process Safety Booklet Ten:
Hazards of Nitrogen and Catalyst Handling)

__12.8 All employees that are on the top side of vessel and
outside of the “hot zone” or handling nitrogen blanketed
catalyst at grade will be equipped with an oxygen monitor
in addition to other required personal gas detection
equipment.

__12.9 The requirements of SAF-116 – Barricading of Hazardous

Activities must be adhered to by all personnel involved in
the inert entry or working in the area.

__12.10 All spent catalyst and PPE waste must be handled

per site environmental policies.

13.0 Additional Hazards __13.1 Engineering practices and sampling during vessel shut
down and preparation must account for the monitoring of
formation of nickel carbonyl [Ni (CO)4]. This is done by
monitoring for Carbon Monoxide. Nickel carbonyl is
formed by the reaction of carbon monoxide with nickel
and is extremely toxic when inhaled.
o For catalyst systems using catalyst that
contain base metals, the hazard to Nickel
Carbonyl exposure shall be tested.
o Carbon monoxide content in the circulating
gas shall be less than 10 ppm prior to
cooling below 200 deg C (390 deg F).
o If Carbon monoxide content is greater than
10 ppm the catalyst shall be heated to 204°
C (400°F), the circulating gas purged as
necessary to reach <10 ppm, and cooling
resumed.

__13.2 Loading of catalyst that is pre-sulphurised, pre-sulphided

or pre-activated catalysts that are classified as self
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heating must be done under inert atmosphere.

__13.3 The following potential hazards could exist and should be

considered for documentation in the Level 2 Task Risk
Assessment (L2TRA):
o Catalyst beds not supporting workers weight
o Hot spots inside catalyst bed
o Dumping operations impacting stability of catalyst
bed and creating voids
o Pyrophoric material
o Elevated temperatures can cause heat stress or
fatigue
o Sharp or abrasive objects/surfaces on trays, lugs,
brackets, internal supports
o Cluttered or obstructed work space caused by poor
housekeeping
o Congestion at job site caused by life-support lines
and personnel in area
o Weather enclosures over entry points to an inert
vessel could become oxygen deficient
o Unauthorized personnel in the area
o Lighting levels
o Adverse weather conditions
o Dropped/falling objects

11.0 Rescue and __14.1 The Specialty Contractor will provide written rescue and
Emergency emergency response plans, specific to the inert entry
Response taking place. The BP Emergency Response Specialist
will review the plan for completeness.

i. The Emergency Response Plan shall include the

following:
1. The use of non-entry rescue methods
whenever possible.
2. A defined plan that outlines tactics to have
readily available a spare vacuum hose (not
vacuum unit) of sufficient length to replace a
section torn off by catalyst bed cave-in, for
rescue efforts.
3. A defined communication protocol for the Inert
Entry Contractor to notify BP in the event of an
emergency.
4. The location defined for a rescued worker to
be transferred from the care of the Inert Entry
Contractor to the Site/Entity emergency
response team.
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__14.2 The Specialty Contractor will be responsible for initial

confined space rescue efforts to include removing
entrants from the space and the hot zone. If the Specialty
Contractor has the training and equipment to complete a
full rescue to grade, they will include that aspect in their
plan.

__14.3 A winch will be immediately available to remove the

entrant from the space.

__14.4 When the Inert Entry Contractor is equipped and

qualified to complete the rescue and deliver a victim to
grade for emergency medical care, a BP supplied high
angle rope rescue team (a.k.a Confined Space Rescue
Team) will not be required to be in the refinery provided
the contractor can demonstrate their ability to complete
the rescue in a timely manner.

__14.5 When a BP provided high angle is reqired to support the

inert entry contractor:

a. BP onsite confined space rescue team is available on

radio channel 16A and must be immediately notified if
the Specialty Contractor initiates any type of rescue or
emergency response effort.

b. The BP onsite confined space rescue team will be

available to assist the specialty contractor in removal of a
patient from the top side of the vessel to grade.

c. The BP onsite confined space rescue team will provide a

rescue plan to supplement the Specialty Contractor’s
plan, as appropriate.

d. BP employees are prohibited from entering the inert

confined space for any purpose including rescue /
emergency response.

__14.6 The Specialty Contractor is required to provide

individuals trained to meet or exceed OSHA standards
for all rescue operations that they have pre-planned to
perform. These training records must be made available
to BP upon arrival on site to perform work. The records
will be verified by the BP Contact.

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__14.7 The Specialty Contractor will ensure that their plan

accounts for the staging of appropriate personnel and
equipment to respond in the case of an emergency.

15.0 Pre-planning and __15.1 The BP Contact is responsible for:

Responsibilities o Ensuring the Specialty Contractor has received a
copy of this procedure, other applicable site
procedures, and applicable SDS sheets prior to
entry taking place, preferably before arrival on-site.
o Ensure that the Specialty Contractor’s work plans
and emergency response plans are received by BP
and a copy provided, for review, to a BP Safety
Advisor
o Review documents provided by the Specialty
Contractor.
o Ensure that the Specialty Contractor is supplied
with at least 2 BP radios.
o Must remain on-site for duration of inert entry
activities.

__15.2 Operations is responsible for:

o Ensuring that the vessel has been properly
prepared for entry and isolated from all energy
sources.
o Issuing the final authorization for inert entry to
begin by issuing Control of Work permits and the
authorization of the Confined Space Entry Permit.
o Issuing a new Confined Space Permit and verifying
isolation is still adequate if the vessel will be turned
over to regular atmosphere for entry following inert
entry.

__15.3 The BP Safety Advisor is responsible for:

o Verifying the isolation of the vessel, review of the
Specialty Contractor’s plans and procedures, and
administration of the Inert Entry Safety Work
Assurance program.
o Witnessing the initial gas test and signing the initial
entry gas test on the Confined Space Permit.
o Witnessing the initial gas test on the vessel if it is
going to be turned over to regular atmosphere for
entry following inert entry.
o Must remain on-site for the duration of confined
space entry.
o The responsibilities of a BP Safety Advisor for
purpose of Inert Entry may be delegated to the
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 Procedure No. SAF-033 Rev. No. 2

following individuals with approval from the Safety

Team Leader:
o A contractor hired to fill the role of a BP
Safety Advisor.
o A HSSE employee with equivalent training
of a BP Safety Advisor.

__15.4 The Specialty Contractor is responsible for:

o An Inert Entry Execution Plan shall be developed
by the Inert Entry Contractor to include:
 Results of the L2TRA.
 Inert Entry Contractor policies & practices
pertaining to:
i. Work zone control and Hot
Zone/Exclusion Zone barricading
ii. PPE
iii. Atmospheric monitoring
iv. Emergency response plan
v. Heat stress/fatigue management
vi. Loading sock/equipment integrity
vii. Training program
viii. Any other Inert Entry Contractor
practices or procedures for inert
entry
 Experience level for all Inert Entry Contractor
staff planned to be on site for the job.
o Reviewing all BP procedures and SDS sheets
provided to them and ensuring compliance for the
duration of the work.
o Providing required training to their employees and
ensuring competence for the job tasks they will be
completing.
o Report any changes to job scope, failures of
equipment, incident, injury or other unexpected
event to their BP Contact immediately. These
conditions require work to be stopped for
reassessment.
o Providing and maintaining atmospheric monitoring
equipment cabable of testing for the constituent
listed in sections 8.0 and 9.0 of this procedure.
o Monitor the atmospheric conditions in the vessel
and the wellbeing of their employees for the
duration of the task.
o Ensure that minimum nitrogen flow is being
maintained to the vessel.
o Responsible for providing any requested training,
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 Procedure No. SAF-033 Rev. No. 2

certifications, and logs to BP upon request or as

defined in this procedure.

__15.5 All Level 2 Task Risk Assessments must be completed

with representatives from the Specialty Contractor
present. This cannot be completed by teleconference
and must include a review of the vessel drawing.
__15.6 The BP owner of this procedure will organize a meeting
of the personnel shown in the table below for the review
and approval of the Inert Entry Execution Plan:

RAPID responsibilities for approval of Inert Entry

Execution Plan
Recommend SAF 033 owner
Agree Entity HSSE Manager (or Delegate)
Entity Emergency Response Contact
Perform Inert Entry Contractor
Input TAR Manager/Maintenance Manager
Decide Entity Operations Manager

16.0 Self-verification __16.1 The Specialty Contractor will complete the Inert Entry
Safe Work Assurance Checklist in Appendix A prior to
entry each shift. The sheet that is completed for initial
entry must be secured to the Confined Space Entry
Permit and reviewed prior to entry by the BP Safety
Advisor.

__16.2 A BP representative will complete the Inert Entry Safe

Work Assurance Checklist in Appendix B at least once a
shift. The BP Safety Advisor will coordinate this process.
The following individuals will participate in the completion
of the checklist, when assigned:
o BP Safety Advisor
o Safety Representative acting on behalf of BP
o BP Contact
o TAR Event Manager
o TAR Manager
o Operations Coordinator
o Operations Lead (salary or hourly)
o Area Operator
o Process Engineer
o Operations Superintendent

__16.3 The reporting process for deficiencies is noted on the

bottom of the checklists and must be followed.
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 Procedure No. SAF-033 Rev. No. 2

__16.4 Completed checklists will be returned to the BP Safety

Advisor and managed by the Safety Department.

17.0 Deviations __17.1 Any deviation from these established procedures shall be
approved through a Management of Change.

__17.2 Turnarounds, Special Projects, Greenfield or Brownfield

work may be exempt from specific elements of this
procedure provided they have a written plan that
addresses inert entry activities and meets all OSHA
requirements. The exemption from this procedure must be
approved by consensus from the HSSE Manager and
Operations Manager.

Revision history The following information documents at least the last 3 changes to this document,
with all the changes listed for the last 6 months.

Date Revised By Changes

10/23/2015 S.Sedlak Initial Release M20151705-001

05/02/2016 S.Sedlak Removed requirement for an ambient vaporizer on

nitrogen trucks, added requirements securing socks
during loading, fixed discrepancy regarding catalyst
wall heights on checklists, added clarification on
who can fill the responsibilities of a BP Safety
Advisor, added requirements for BP Contact to
review specific documents prior to entry.
M20161210-001

02/28/18 M Stack Added reference to D-PRO-4.5-0100. Added Inert

Entry Planning and Contractor Selection Criteria.
Added prohibition for non-Specialty Contractor
Personnel in the hot zone. Added requirement for
hard entry cover when entry not in process. Added
prohibition for BP entry into the inert space for
rescue. Added requirement for bongin/grounding of
loading equipment. Added specific requirements for
the prevention of nickel carbonyl formation. Added
requirement for two communication devices. Added
requirement for certifications of breathing air
cylinders, Added specific language for nitrogen back
pressure test, including Appendix with example.
Specified more specific requirement around
emergency response plan. Added specifics arounf
inert entry execution development, review, and
approval. Updated self verification checklists.
M2018328-001

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 Procedure No. SAF-033 Rev. No. 2

APPENDIX A
Confined Space Inert Entry Safe Work Assurance Checklist – Specialty Contractor

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 Procedure No. SAF-033 Rev. No. 2

Confined Space Inert Entry Safe Work Assurance Checklist

Specialty Contractor
Must be completed prior to entry each shift and kept in life support trailer.
S = Satisfactory RA = Requires Attention NA = Not Applicable
Name_______________ Equipment __________________Date/Shift_____________
1. Equipment isolation and entry permits are • Primary and secondary communication
in accordance with Toledo devices are present ____________
Procedures_____ • A full body harness and tripod with retrieval
line attached ________________6.
2. Procedures are in place to identify all Procedures and expectations are in place to
persons authorized to enter the inert ensure that at no time will the residual
vessel._______ catalyst remain at a level higher than the
worker’s waist relative to the lowest point of
3. Procedures are in place to prevent the catalyst bed level.____________
unauthorized persons from entering the
vessel._______ 7. Video surveillance equipment is in good
working condition, with pan adjustments and
4. Provisions exist to prevent unauthorized recording
entry into the vessels when there is no capability.____________________
activity. (e.g., manway covers, hard barriers
at ladder bases, 9. Fall arrest equipment is tested, secured,
etc…)__________________ and
documented.______________________
5. All persons entering, or potentially
entering (e.g., rescue personnel) the vessel 10.Gas monitor has been calibrated_______
must wear appropriate equipment for
working in an oxygen deficient vessel. The 11. Entrants have armored umbilical cords,
minimum expectations: including air supply and communication
• Two(2) completely independent continuous lines:_______
air supplies, and one secondary (e.g.,
emergency egress air supply of sufficient 12. All umbilical’s, lighting cords, and other
capacity for escape purposes lines must go through the man way in a neat
____________ manner so not to interfere with
• d. Certificate(s) from the supplier are ingress/egress._______________________
present for testing and confirmation that all
bottles of breathing air meets or exceeds 13. Ingress/egress ladder is in good
ANSI/CGA G-7.1-1989 Grade D quality. condition and secured appropriately.______

• Lock-on Helmet mask type respiratory
protection ____________
• Rescue personnel and equipment must be
assembled and ready for use, at the vessel
entry points of any vessel with oxygen
deficient atmosphere. ____________
14. Sufficient low voltage lighting is being
used and set up in a way that prevents the
cords from becoming entangled or
compromised.________
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 Procedure No. SAF-033 Rev. No. 2

15. Contractor logs will effectively detail: Comments:

• Entry and exit dates and times of all ___________________________________
personnel __________
___________________________________
• Catalyst bed outages _____________
• The catalyst bed condition (at least once ___________________________________
an hour) ____________
___________________________________
• Any changes to catalyst removal methods
and or tools________________________
• Any changes to how N2 is being supplied
to the reactor. (Ie: bottom or horse Signature___________________________
shoe.)_____
Title_______________________________
• Gas monitoring log confirms <50ppm CO,
< 4% O2, < 10% LEL, <10ppm H2S,
<100F have been recorded every 15 Report any RA’s to your BP Contact prior to
minutes.________ making entry.
• Breathing air cylinder manifold gauge
readings monitored and Keep this document in the life support trailer
logged.__________ until BP Safety collects it.

• The contractor is prepared to rotate

workers every 4 hours to mitigate fatigue
and provide additional evaluation
frequently enough to detect emerging
hazards._______ ____

16. Rescue plan is documented and

understood by all personnel approved for
rescue in the inert atmosphere (e.g., the
contractor)._____

17. Shift starting toolbox talk has taken

place with all crew members________

18. Breathing air cylinders quality assurance

has been provided (for CO and O2)._____

19. MSDS sheets are available for spent &

new catalyst_______________ Page 2 of 2

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 Procedure No. SAF-033 Rev. No. 2

APPENDIX B
Confined Space Inert Entry Safe Work Assurance Checklist – BP

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 Procedure No. SAF-033 Rev. No. 2

Confined Space Inert Entry Safe Work Assurance Checklist

BP
Must be completed once a shift by a designated BP Employee or delegate
S = Satisfactory RA = Requires Attention NA = Not Applicable
Name_______________ Equipment __________________Date/Shift_____________
1. Equipment isolation and entry permits are 10). Contractor logs effectively detail:
in accordance with Toledo Procedures(verify • Entry and exit dates and times of all
using CoW paperwork and CSE personnel __________
permit)_____
• The catalyst bed outages _____________
2. Barriers are in place to prevent
unauthorized persons from entering the • The catalyst bed condition (at least once
vessel both when the contractor is present an hour) ____________
and when there is no activity. • Any changes to catalyst removal methods
____________ and or tools________________________
3. Entry Contractor has completed and  Any changes to how N2 is being supplied
documented shift self- to the reactor. i.e.: bottom or horse
assessment._________ shoe.______
4. BP Ops is monitoring the closest catalyst  Gas monitor has been calibrated________
bed TI’s to the work and has communication
with life support trailer (ask the life support  Gas monitoring log confirms <50ppm CO,
attendant to call for the reading)._________ < 4% O2, < 10% LEL, < 10ppm H2S, <100F
have been recorded every 15
5. Temperatures have not exceeded 100F,
minutes.________
and if so, entry was suspended(verify by
checking log and a conversation with the life  Breathing air cylinder manifold gauge
support attendant)___________ readings monitored and
logged.__________
6. Video surveillance equipment is being
used to record reactor conditions and  The contractor is rotating workers every 4
catalyst wall height has not exceeded 3’ (or hours to mitigate fatigue and provide
waist height) at least every hour._________ additional evaluation frequently enough to
7. Rescue plan is documented and detect emerging hazards.___________
understood by all personnel approved for
rescue in the inert atmosphere (e.g., the 11) Bonding and grounding of all unloading
contractor).__________________________ and loading equipment is in place
__________
8. Rescue personnel (C&W) are on-site (call
on 16A).______________ 12) Two communication devices are in use
to communicate with entrants(s)
9) Rescue personnel (BP, Entry Contractor __________
and CSR) know the patient transfer point
__________

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 Procedure No. SAF-033 Rev. No. 2

Comments: _____________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
Print Name:_____________ Signature: ______________Title:____________________
Name of individuals spoken with:_____________________________________________
Return completed assessment to BP Safety Representative.
BP Safety will address any RA’s with BP Contact and document corrective actions on back.

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Appendix C: Nitrogen Valve Control Tag

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 Procedure No. SAF-033 Rev. No. 2

Appendix D: Example Nitrogen Backpressure Test

1. Ensure that a permit has been issued to install the nitrogen manifold. (sometimes called a Grubbs Manifold)

2. Install the nitrogen manifold as directed by the diagram below. The entry will NOT be allowed until a pass
has been achieved using the nitrogen manifold.

3. Valves C and E on the nitrogen manifold should be in the open position. Valves F & H will remain in the
closed position to ensure that the low pressure gauge will not be damaged from the nitrogen source during the
test.

4. Once the maximum nitrogen flow or SCFH intended for vacuuming purposes during entry has been
established, record the rates per hour and proceed to step #5.

5. Maintain maximum nitrogen flow for ten minutes and then record the pressure readings on gauge D.
Maintain maximum flow rate for an additional ten minutes to ensure that the swing of pressure has stabilized
from the first recorded reading. If the pressure has changed continue to purge at maximum nitrogen flow until
the pressure readings stabilize. (Note: there will be some fluctuations in readings). If there is no change in the
pressure from the initial or secondary readings proceed with the nitrogen pressure test.

6. Establish a clear & direct communication with the operator of the nitrogen supply.

7. To check for back pressure instruct the nitrogen operator to block nitrogen. Once the nitrogen operator has
communicated that he is shutting down, watch gauge D and block in valve C when the pressure has dropped
to the lowest established fluctuation point. When gauge D reaches 30 psig open valve F and there should be
an immediate rise and fall of pressure on gauge G. (Note: DO NOT OPEN VALVE IF GAUGE D IS ABOVE 30
PSIG. EQUIPMENT FAILURE or POTENTIAL INJURY MAY OCCUR with GAUGE G). The duration time once
valve C is blocked and gauge D & G reach zero must be five seconds or less.

8. Once gauge D & G have reached zero open valve H and check for any detectable back pressure. If
pressure is detected from valve H and is present for more than five seconds after the closing of valve C, the
test fails. (Note – two potential causes for the back pressure are a blockage in the catalyst bed, or isolation
blinds not installed correctly.) Caution: During step # 8, NITROGEN will be vented to the atmosphere. If
there are large amounts of NITROGEN being vented, proper PPE is required. (The area around the
nitrogen manifold should be considered IDLH and Breathing Air will be required. Back up Valve E is to
be used only in cases of emergency (i.e. failure of Valve C.

Example of a manifold to Control Nitrogen for the Inert Entry

SUPPORTS
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 Procedure No. SAF-033 Rev. No. 2

Danger : If the NITROGEN flow cannot be maintained without the building of back pressure, shut
down the NITROGEN immediately. Alternative means of purging will be necessary in order to make
entry and remove the NITROGEN restrictions. If the nitrogen flow reaches an excess pressure at or
above 290 psig or causes any PRVs to activate immediately stop all flow of nitrogen to the reactor,
remove workers the top deck, and barricade ladders and access to the top deck. Before other action
is taken, perform a Risk assessment to determine the next course of action. Options to consider
when developing the risk assessment include:

A. Open Nitrogen purge for two hours and re-test crust/Nitrogen Flow check as described in 1-10 above.
If crust check is confirmed by pressure drop as described in step 8 above, it is OK to start work.
B. If Nitrogen pressure has dropped, but not to zero, or it took longer than 5 seconds, repeat step one
above.
C. Route nitrogen purge so that is not through the bed. Once the nitrogen purge is re-routed try to dump
a small amount out of the dump nozzle to see if the bed moves. If so, re-test crust nitrogen flow check
as described in 1-10 above.

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Appenxix E: Supplemental Gas Testing Information (Reference)

Introduction

For confined space inert entries it is necessary to inert the vessel to reduce the percentage of oxygen from its normal
20% to a range of 5% or less. In many cases the inert atmosphere must be monitored for flammable gases in order to be
aware of the hazards that might be present if the inert atmosphere failed or is removed. Traditional Wheatstone
bridge/catalytic bead-based lower explosive limit (LEL) sensors require oxygen to detect flammable gases. A dilution
fitting is typically used to introduce enough oxygen in the air to allow the LEL sensor to read properly.

What is a Dilution Fitting?

A typical dilution fitting is a plumbing device that is attached to a gas detection instrument sample inlet port, and then the
sample hose is attached to the dilution fitting. When used, the sample flow going into the instrument passes through the
dilution fitting. The dilution fitting has 2 small holes; one is in the sample gas stream path, and the second is through the
side of the fitting and causes the instrument to take in ambient air. Essentially, the dilution fitting creates a calibrated
“leak” into the incoming sample, and dilutes the sample with fresh air. If the dilution fitting is calibrated to be 1 to 1, then
when used it will dilute the sample gas stream with an equal amount of ambient air.

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When is a dilution fitting needed?

There are at least two situations where a dilution fitting is needed. The first common usage is when a catalytic LEL
sensor is used to test a space that is inerted (contains no oxygen). Since a catalytic sensor requires oxygen in order to
operate, a 1 to 1 dilution fitting blends enough fresh air with the sample to provide enough oxygen for the sensor to
properly detect flammable gases if they are present. The second common reason for using a dilution fitting is to extend
the range of the gas monitor. When a dilution fitting is used, it reduces the reading of the gas monitor. If the gas monitor
is calibrated to read correctly without the dilution fitting used, then when the fitting is used the gas monitor will read lower
than what is actually in the gas sample. For example, if a 1 to 1 dilution fitting is used, since it dilutes the sample by 50%,
this means that the reading will be half of what is actually present in the test space. In order to understand what the
correct reading is, it is necessary for the operator to multiply the meter reading by 2. If a dilution fitting is 2 parts dilution
to 1 part sample, then it knocks the reading down to 1/3 of the actual value, and in this case it is necessary to multiply the
meter reading by 3 to get the actual concentration. So, a reading of 50% LEL is actually 150% LEL.

A dilution fitting ratio can be affected by changes in pressure of the incoming gas sample. The fitting is calibrated to
provide the correct dilution if the sample is drawn from atmospheric pressure. If the pressure is different, it can change
the ratio. For example, if the sample is drawn from a strong vacuum, the fitting may have a difficult time pumping enough
gas through the sample hole, and therefore it would draw a larger proportion of the sample through the dilution hole. In
this case, you would be getting more dilution of the sample, and so the readings would be lower than expected. If the
sample is drawn from a pressurized vessel, it may force too much gas through the sample hole and the pump will not be
able to draw the correct amount from the dilution hole. In this case the reading may be higher than expected. In the case
where it is testing an inerted space with a catalytic sensor, if insufficient dilution occurs then the LEL reading may be low
or near zero because the catalytic sensor is not responding properly due to a lack of oxygen.

What is the difference between Catalytic detectors (Wheatstone bridge) & Infrared monitoring?

In detecting combustible gases in oil and gas, petrochemical and other applications, choosing between the two most
common gas sensing technologies used for this purpose will be critical in ensuring a safe, reliable and cost effective
solution. These technologies are catalytic combustion and infrared. There is clear need for both IR and catalytic detectors
in industry. When making a choice, be sure to consider the field environment and the sources and types of gases that
are being detected.

Catalytic detectors are based upon the principle that when gas oxidizes it produces heat, and the sensor converts the
temperature change via a standard Wheatstone Bridge-type circuit to a sensor signal that is proportional to the gas
concentration. The active element is embedded in a catalyst. The reaction takes place on the surface of the catalyst, with
combustible gases reacting exothermically with oxygen in the air to raise its temperature. This results in a change of
resistance. The advantages of catalytic detectors are many, they are simple to operate, easy to install, calibrate and use,
and have a Long life with a low replacement cost. The disadvantage for catalytic detectors is they require oxygen in
order to detect hydrocarbons.

The Infrared (IR) detection method is based upon the absorption of infrared radiation at specific wavelengths as it passes
through a volume of gas. Infrared gas detection is based upon the ability of some gases to absorb IR radiation. There are
some hydrocarbons and other flammable gases that have poor or no response on a general purpose IR sensor. In
addition to aromatics and acetylene, hydrogen, ammonia and carbon monoxide also cannot be detected using IR
technology with general purpose sensors of 3.4 micron specifications.

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