KANKAKEE POLYMER PLANT SAFETY PROCEDURE

HOT WORK PERMIT

Written By: C. Rosenow Original Issue Date: 03/10/92

Total Pages: 15 Document Number: SP-05

APPROVAL LOG
DATE SIGNATURE

DISTRIBUTION
COPY NO. OWNER/LOCATION
1 Safety Procedure Manual

UNCONTROLLED COPY
 KANKAKEE POLYMER PLANT SAFETY PROCEDURE

Title: Hot Work Permit Revised: 2/24/06

No.: SP-05 Page: 2 of 15

REVISION LOG
DATE DESCRIPTION OF CHANGE
3/10/92 Original Issue
10/7/93 Revision - General Review
2/24/95 Revision - Put into ISO format
8/3/95 Revision - General Review
9/10/96 Revision - Included welding shield requirements in Section 3.11 d.
04/03/98 Revision- Added welding U/V Guidelines
6/29/99 Revision – Annual Review (clarified specific barrier tape usage)
3/1/00 Revision- Annual Review and revised plant job titles and responsibilities per
plant re-organization
3/10/00 Revision- added requirements necessary for Hot Work performed in
Confined Spaces [Section 3.11(i)]
9/07/00 Revision- Added “Records Generated’ Section
4/20/01 Revision - Annual Review - No updates req’d
5/9/01 Revision - Updated responsibilities due to plant reorganization. EHS
Coordinator will be the primary contact for the safety approval on permit.
7/9/02 Revision – Annual Review (including permit process and interviews), No
updates Required.
2/17/03 Revision – Added conditions when a Hot Work Permit must be voided
3/21/03 Revision – Annual Review Updated the isolation requirements for non-
hazardous material piping. Revised the approval process to allow the
Operation Coordinator to be the primary permit authorizer.
6/15/04 Revision – Annual Hot Work Permit Procedure Review – No Changes
Req’d

UNCONTROLLED COPY
 KANKAKEE POLYMER PLANT SAFETY PROCEDURE

Title: Hot Work Permit Revised: 2/24/06

No.: SP-05 Page: 3 of 15

REVISION LOG
DATE DESCRIPTION OF CHANGE
9/16/05 Revision – Annual Hot Work Permit procedure Review –
2/24/06 Revision— Misc. changes to procedure and permit, changed Operation
Coordinator to Permit Writer. Added additional information to scope
about electrical enclosures, concrete/asphalt cutting and monomer
unloading. Revised atmosphere check under permit Writer
responsibilities.

UNCONTROLLED COPY
 KANKAKEE POLYMER PLANT SAFETY PROCEDURE

Title: Hot Work Permit Revised: 2/24/06

No.: SP-05 Page: 4 of 15

1.0 PURPOSE

To prevent fires, explosions, or the generation of toxic materials during hot work.

2.0 SCOPE

This standard covers all hot work activities in the process building, monomer tank
farm, and all plant sumps, trenches, and catch basins where flammable or
combustible materials may be present. Hot Work for the purpose of this standard is
defined as any open flame, welding arc, mechanical or electrical device that is
capable of igniting a flammable environment. Any electrical equipment used in the
plant will be deemed capable of igniting a flammable environment unless it has been
approved by a national testing laboratory (Underwriters Laboratory, Factory Mutual,
etc.) for use in a hazardous environment.

A Hot Work Permit is required in all areas within the plant (excluding the
maintenance shop and contractor’s parking lot and as described by this procedure)
where welding, brazing, metal cutting or grinding, or any other similar activity is done
with intense heat or open flames. In addition, any electrical equipment (excluding
explosion-proof rated equipment) used in classified areas will need a Hot Work
Permit as defined by this standard.

A Hot Work Permit is required for opening electrical enclosures in classified areas
with the exception of those enclosures which are intrinsically safe.

All concrete cutting will require a hot work permit due to the possibility of cutting re-
enforcement metal embedded in the concrete.

During periods of monomer unloading no Hot Work Permit will be issued in the
unloading or storage areas.

A copy of the Hot Work Permit is attached to the controlled copy of this procedure in
the Safety Procedure Manual.

3.0 RECORDS GENERATED

3.1 Hot Work Permit

3.2 Annual Review Documentation by EHS Manager (or designee) on Review

Log

3.3 Procedure guidelines for hot work performed in the Contractor’s parking lot

UNCONTROLLED COPY
 KANKAKEE POLYMER PLANT SAFETY PROCEDURE

Title: Hot Work Permit Revised: 2/24/06

No.: SP-05 Page: 5 of 15

4.0 STANDARD

4.1 No hot work will be performed in the plant without following all of the
requirements of this section. The following approvals will be required prior
to beginning the hot work:

Permit Writer: The Operations Coordinator’s approval is required for

all Hot Work Permits.

The EHS Coordinator will be the primary back-up for

the Operation Coordinator.

The Operations Supervisor will assume responsibility

for the Operation Coordinator’s activities during shifts
where the Operation Coordinator (or the EHS
Coordinator) is not present and a Hot Work Permit is
necessary.

The Maintenance Department will be responsible for all

“Operations" identified responsibilities whenever Hot
Work activities are performed in the Maintenance
Building. Note: Hot Work performed in the
Contractor’s Parking Lot and the Welding Booth
located in the Maintenance Building does not require
a Hot Work Permit. See requirements for these areas
below.

Maintenance/
Contractors: Maintenance Technician performing the work will sign
the Hot Work Permit. If a contractor performs the hot
work, the contractor is responsible for providing this
signature approval.

The Operations Technician (the person performing the

work) is also responsible for signing the permit when
the activity is performed by Operations.

EHS: The Operation Coordinator has the primary responsibility

for this approval.

The EHS Coordinator is the primary back-up to the

Operation Coordinator. The EHS Department can also
be contacted for additional assistance, whenever the

UNCONTROLLED COPY
 KANKAKEE POLYMER PLANT SAFETY PROCEDURE

Title: Hot Work Permit Revised: 2/24/06

No.: SP-05 Page: 6 of 15

need arises.

The Operations Supervisor will complete the EHS sign-

on (including permit signature, atmospheric monitoring,
and permit monitoring) during shifts where the
Operation Coordinator (or the EHS Coordinator) is not
present and a Hot Work Permit is necessary. To avoid
this situation, this type of work should be scheduled on
day shifts whenever possible.

4.2 The Operations Department is responsible for identifying all work

necessary to ready the area for hot work. Operation Department is also
responsible for keeping the surrounding area free of hazardous materials.

4.3 The need for a Hot Work Permit will be identified on the Safe Work Permit
form. The Permit Writer will originate the Hot Work Permit and perform all
atmospheric monitoring required prior to performing the hot work.
Readings will be taken at enough locations to be representative of the
entire work area. The Plant’s Hot Work Permit form will be used for all hot
work done at the Kankakee Polymer Plant. The Hot work Permit will be
completely filled out, any items not applicable will be marked N/A.

4.4 Maintenance and/or Contractor representatives (where appropriate) will

sign on the Hot Work Permit only after all parties have agreed on the
appropriate safeguards.

4.5 The Permit Writer is responsible for recording the expiration time at the end
of the Hot Work or when the Hot Work Permit expires (due to the shift
schedule or a predetermined expiration). Prior to this permit expiration, a
thorough inspection of the work area must be made to ensure it is left in a
safe condition.

4.6 One Hot Work Permit will be issued to cover all activities associated with
one task involving hot work.

4.7 Hot Work Permit Distribution:

White Copy: To be maintained by the Operations Department during the

hot work. This copy will be posted on the Work Permit Board
(located in the Contractor Sign-In Room), while the work is
being performed. Additionally, the Job Description Board
(located in the Control Room) will be updated to include a
UNCONTROLLED COPY
 KANKAKEE POLYMER PLANT SAFETY PROCEDURE

Title: Hot Work Permit Revised: 2/24/06

No.: SP-05 Page: 7 of 15

description of the Hot Work Permit.

Note: The Job Description Board is used to list all Hot Work
Permits that are currently active. Operation Technicians
working in the Control Room are expected to review this
board prior to the beginning of their work shift and
periodically throughout the shift. It will be immediately
updated as Hot Work Permit are initiated and completed.

After the Hot Work Permit is complete and the permit sign-
off in place, both the White and Hard Copies will be
forwarded to the EHS Department for storage.

Hard Copy: Posted at the job-site until the hot work is complete.

4.8 Before beginning any hot work, all involved individuals shall:

4.8.1 Determine that a valid Hot Work Permit has been posted at the job-
site.

4.8.2 Review and comply with the permit safeguards and protective
equipment requirements.

4.9 Anyone performing hot work (requiring a permit) must have a fully executed
Safe Work Permit prior to beginning the work. This includes all contractors,
inspectors, supervisors, operations personnel, and maintenance personnel.

4.10 No Hot Work Permit will be valid for more than one shift. If the work is to
occur over more than one shift, then a new permit must be issued at the
start of the new shift.

4.11 The Hot Work Permit becomes void under the following conditions:
 If the fire/emergency alarm sounds
 At a given time specified on the Hot Work Permit
 At the end of the shift on which it is issued
 If the work does not commence within two hours or if work ceases for
over one hour

4.12 Hot Work Responsibilities:

4.12.1 The Operations Department is responsible for the following:

UNCONTROLLED COPY
 KANKAKEE POLYMER PLANT SAFETY PROCEDURE

Title: Hot Work Permit Revised: 2/24/06

No.: SP-05 Page: 8 of 15

a. Preparing the hot work area and equipment for work. This
preparation may include steaming lines, inspections of pump
seals and flanges (etc.), and ensuring that all affected vessels
and lines have been blinded and cleared.

b. Accompanying the Permit Writer or contractor, as appropriate,

on the initial inspection to ensure the area is ready to begin the
hot work.

c. Informing the Permit Writer, or maintenance/contractor, of the

need to monitor for hazardous materials that may be present.

d. Maintaining the area around the hot work area in a safe

condition. For example, prohibit the filling of a flammable liquid
storage tank while hot work is underway in the same area. The
intent is to prevent the release of any hazardous materials into
the environment that might endanger the hot work activities.
Operation Department is responsible for notifying the individuals
performing the work if conditions change, making the hot work
no longer safe. The Permit Writer must also be notified and the
work stopped immediately. The Hot Work Permit will then be
ended and work started only after the situation is corrected and
a new Hot Work Permit is prepared.

e. Check the work area after the hot work has been completed to
insure that everything has been left in a safe condition.

4.12.2 The Permit Writer has the following responsibilities after Operations
has prepared the work area:

a. Verifying that the equipment and area are properly prepared for
hot work.

b. Checking for oxygen content, where appropriate. Note that this

must precede the test for Flammability!

c. Testing for the presence of a flammable atmosphere (L.E.L.).

d. Test for the presence of hazardous materials, where

appropriate.

e. Specifying the necessary safeguards and protective equipment

based upon the test results.
UNCONTROLLED COPY
 KANKAKEE POLYMER PLANT SAFETY PROCEDURE

Title: Hot Work Permit Revised: 2/24/06

No.: SP-05 Page: 9 of 15

f. Upon completion of the testing, fill out the Hot Work Permit and
communicate the requirements to all personnel involved in the
hot work.

4.12.3 The Maintenance Technician/contractor (the individuals/group

actually performing the hot work) has the following responsibilities
after Operations has prepared the work area:

a. Verifying that the equipment and area are properly prepared for hot
work.

b. Ensuring the necessary safeguards and protective equipment, are

in-place as indicated by the Safe Work Permit/Hot Work Permit
and based upon the atmospheric monitoring results.

c. Ensuring that the safeguards and protective requirements noted in

the permit are complied with.

d. Upon completion of the atmospheric testing by the Permit Writer,

signing the Hot Work Permit and communicate the
requirements to all personnel involved in the hot work.

e. Notifying the Permit Writer of any significant changes in the work

area or safety problems encountered in the work.

f. Notifying the Permit Writer of the need for a Hot Work Permit.

g. Providing the safeguards noted on the Hot Work Permit such as fire
watch, fire extinguisher, sealed sewers, etc.

4.13 Before the Hot Work Permit is issued, the area must be prepared as follows
(Responsibility for performing these tasks is with the individual performing
the hot work unless noted otherwise):

a. The Permit Writer will check for a flammable or combustible atmosphere

in sufficient enough locations to assure no combustible or flammable
atmosphere exists, the results of which must show the work area (also
the up wind or up gradient areas) to be 0% of the L.E.L. The Permit
Writer may also determine that continuous monitoring may be required
due to the potential for changing conditions. The oxygen content in the
work area must be below 22% to proceed. Note that most flammable
liquids have different response factors to LEL meters so any work
UNCONTROLLED COPY
 KANKAKEE POLYMER PLANT SAFETY PROCEDURE

Title: Hot Work Permit Revised: 2/24/06

No.: SP-05 Page: 10 of 15

done with a measurable LEL cannot be performed without the prior

consultation with the EHS Manager. In these circumstances, the
first approach should always be to take alternative steps to reduce
the measurable LEL to 0. Should this not possible, then a PID will
be used to check for actual concentrations (adjusted for the
appropriate response factors) to ensure that the levels are between
0% and 2%.

b. When flammable or combustible materials are on the floor or ground, the

floor or ground should be swept or flushed for a radius of at least 35 feet.
Combustible floors, holes or cracks in the floor must be kept wet,
covered with dry sand, or protected by fire-resistant shields. All
manholes, catch-basins or trenches should be covered or continuously
flushed with water.

c. The area must be visually inspected for leaks of flammable or

combustible materials from pump seals, flanges, valves, etc.

d. Fire-proof welding shields (visual barriers) must be placed around all

electric arc welding activities when safe distances can not be maintain
by barrier tape (See Appendix I for safe distances from the Welding
Source). Shields must be placed to eliminate arc exposure to personnel
working in, around, above and below the Hot Work Permit area.

e. A Fire Watch must be assigned to the job when there are open flames,
welding, or cutting involved. The Permit Writer will determine if a Fire
Watch is needed for all other Hot Work on a case-by-case basis. The
Fire Watch (if necessary) must be provided with a 20 pound dry
chemical ABC fire extinguisher as a minimum. Note that the Permit
Writer does have the ability to specify an alternative type of unit should it
be appropriate for the work (for example a portable Halon unit may be
appropriate for an electrical closet).

i. The Fire Watch's primary responsibility is to maintain visual, voice,

sound, or line contact with the individual(s) performing the hot work.
They must watch for fires in the area where the work is being
performed and may try to extinguish a fire if it is determined to be
within the capabilities of the equipment provided. The Permit Writer
should ensure that the fire watch has the training and skills to use
the available fire extinguishing equipment.

ii. The Fire Watch will not leave the immediate area when the hot
work is in progress. The Fire Watch can play an active part in the
UNCONTROLLED COPY
 KANKAKEE POLYMER PLANT SAFETY PROCEDURE

Title: Hot Work Permit Revised: 2/24/06

No.: SP-05 Page: 11 of 15

work, but must stop all other activities when the ignition source is
actually initiated.

iii. The Fire Watch must be able to summons outside assistance at all
times during the hot work. This can be accomplished by the use of
plant radios, air horns, or voice/hand signals. They will be expected
to immediately summons outside assistance should a fire occur.
They will be expected to immediately notify the Operations
Supervisor should a fire occur which they have extinguished.

f. All combustibles and flammables will be relocated at least 35 feet

horizontally from the work area. Where relocation is impracticable, work
can proceed if the combustibles are protected with flameproof covers or
otherwise shielded with metal or fire-resistant guards or curtains.

g. Nearby personnel will be protected from any exposure to heat, sparks,

slag, etc. The posting of the Hot Work Permit will be a visual signal to all
personnel that hot work is in progress.

h. No open flame cutting or welding will be allowed in sprinkled buildings

where the sprinkler system is impaired or non-functional.

i. Hot Work in a confined space will require, not only a Hot Work Permit; it
will also require a Safe Work Permit and Confined Space Entry Permit.
The following special requirements apply to all welding, cutting and
grinding in permit required confined spaces:

1. A minimum ventilation of 2000 cfm per welder will be

provided;

2. When welding is performed on the outside of the

confined space in which it is possible for welding vapors
and dust to enter the confined space, positive ventilation
pressure shall be applied and/or verified for the confined
space;

3. Welding machines and gas cylinders must be left outside

the space;

4. Gas cylinder valves will be shut off at the tank valves

whenever the torch (shielding gas) is not in use in a
confined space;

UNCONTROLLED COPY
 KANKAKEE POLYMER PLANT SAFETY PROCEDURE

Title: Hot Work Permit Revised: 2/24/06

No.: SP-05 Page: 12 of 15

5. Continuous oxygen monitoring will be required and

regulators inspected for proper flow rates when shielding
gases such as argon are used in the confined space;

6. Protective barriers will be provided for all hot metal

surfaces resulting from welding, cutting, or grinding
activities.

4.14 The work area must be maintained in a safe condition. The following
conditions must be adhered to:

a. Sampling or draining of flammable or combustible liquids cannot be

done in the area surrounding the hot work.

b. Hot work cannot be done within diked areas of a flammable or

combustible liquid tank farm while any tanks are being filled.

c. No activities shall be performed in or adjacent to the hot work area that

could cause the release of flammable or combustible materials into the
hot work area.

d. If any conditions change causing a hazard, or a potential hazard, the hot

work must stop immediately. A new permit must be issued before the
work can resume.

4.15 The following activities must be done at the end of the hot work project:

a. The individual performing the hot work must make a final check of the
area to ensure that everything has been left in a safe condition.

b. The Fire Watch must remain in the area for at least thirty minutes
(unless otherwise specified on the Hot Work Permit) after the completion
of the work when welding, brazing, or other similar activity involving an
open flame or intense heat has been performed. Certain situations may
require longer attendance, so the 30 minutes should be viewed as a
minimum.

c. The Permit Writer will inspect the hot work area before returning the
area back to service.

Note: In rare exceptions, it may not be possible to close electrical

junctions or openings where wiring repairs or construction are infeasible
to complete at the end of the work (i.e. in electrical classified area, wiring
UNCONTROLLED COPY
 KANKAKEE POLYMER PLANT SAFETY PROCEDURE

Title: Hot Work Permit Revised: 2/24/06

No.: SP-05 Page: 13 of 15

pulled through conduits, but can not be sealed in the conduit at the
completion of the work). In such instances, either of two actions may be
taken:
 A new Hot Work would be issued to continued the work during the next
shift, or
 The opening where wiring is exposed must be sealed with materials
necessary to prevent flammable gas to penetrate the electrical system
(i.e. duct tape, plastic, and if necessary oakum to seal the opening)

d. The Permit Writer must immediately sign-off the permit identifying the
time the work was completed. This sign-off will be completed prior to the
equipment being put back into service.

4.16 A Lock-out/Tag-out and Isolation Form must be prepared for all hot work
that requires isolation and/or blinding. This list must include the type,
location, service, and number of blinds installed for the hot work. The
minimum blinding requirements are as follows:

4.16.1 Before any hot work is done on vessels, reactors, tanks,

exchangers, or lines that contained flammable or combustible
materials, the equipment must be isolated, cleaned, and vapor freed.
Isolation will be considered achieved by disconnecting lines and
installing blind flanges, installing pancake blinds, or other equally
effective means approved by the EHS Department. Dropping or
closing a valve in a line is not an acceptable means of isolation. The
following exceptions apply:

a. Lines for instrument taps must be disconnected at the tap

where residual flammable or combustible process materials
may exist.

b. Gauge glasses and level float chambers must be removed,

blinded, or rotated out of position unless they have been
properly cleaned and free of flammable or combustible process
materials.

c. Hot Tapping (The prior approval of the Project/Process

Engineer and EHS Manager must be secured before any hot
tapping is done on flammable or combustible process systems)

UNCONTROLLED COPY
 KANKAKEE POLYMER PLANT SAFETY PROCEDURE

Title: Hot Work Permit Revised: 2/24/06

No.: SP-05 Page: 14 of 15

4.16.2 Only Utility water, boiler feed water, deionized water, fire water,
steam condensate, potable water, steam, air, and finish product
lines may be isolated using a double block and bleed valve. The
Bleed valve must be located between the double block and verified
to be open. The bleeder must also be locked in the open position.

If this is not possible, a blind flange or pancake blind must be

installed.

4.16.3 Where installed, blinds shall be located at the flange closest to the
vessel or the section of piping where the hot work will be performed.
A variance from the EHS Department must be obtained if the blind is
to be located elsewhere, or if no flanges exist.

4.17 The EHS Manager (or their designee) will perform an annual review of the
Hot Work Permit Procedure, including a sampling of permit forms and a
field observation of a permit in progress. Input will be solicited from permit
writers and affected individuals as necessary to ensure that the process is
effective and functional. Any required corrections or improvements will be
added to the procedure and appropriate training provided.

UNCONTROLLED COPY
 APPENDIX I

Safe Distances from Weld Arc for Protection from UV Radiation

Welding Shielding Current Safe distances (Ft) from arc

Process Gas A for:
10 min. 4 hr. 8 hr

Manual
Metal Arc - 100-200 33 133 230

TIG Argon 50 3 13 23
150 10 40 65
300 17 76 131

Plasma Arc
Welding Plant Air 100-275 18 76 131

Plasma Arc
Cutting
(dry) Plant Air 400-1000 26 104 180

Plasma Arc
Cutting (w/
water
injection) Nitrogen 300 36 143 246
750 18 76 131

UNCONTROLLED COPY