Cat A 2 SOP 33 FR Tank

SUNCOR ENERGY PRODUCTS
DISTRIBUTION TERMINAL OPERATING MANUAL
STANDARD OPERATING PROCEDURE
SAFEWORK PRACTICES
EQUIVALENCY PROCEDURE FOR ACCESSING FLOATING
ROOF TANKS ON STORAGE TANKS IN SERVICE
CAT A-2 SOP #33
Date Issued: November 2012 Revision Date: November 2012
Review Date: November 2015 Revision # Initial Issue
1.0 PURPOSE
Descent onto an in-service floating roof is considered a confined space entry and as such all
requirements of Cat A-1 SOP #01, Confined Space Entry must be adhered to. However since the
tank is still in service and not fully purged and isolated, an equivalent means of protection for the
workers must be created.
This procedure establishes guidelines and identifies equivalent levels of protection for
individuals performing “Cold Work” involving descent onto floating roofs of storage tanks while
in service within Distribution.
2.0 SCOPE
This Standard Operating Procedure shall apply to all employees and contractors at Suncor
Energy Distribution Terminals who are required to descend onto an in service floating roof.
References in this document to “Suncor Personnel” include directors, officers, employees,
contract workers, consultants and agents of Suncor.
The scope of this document is to define and communicate the precautions and requirements
that involve descent onto internal floating roofs of in service petroleum tanks by Suncor
Personnel and applicable Contractors working within Distribution
2012-01
Accessing Floating Roofs on Storage Tanks in Service Page 1 of 14
Current Version of Document is Maintained Electronically
Printed Versions are Uncontrolled
Accessing Floating Roofs on Storage Tanks in Service
CAT A-2 SOP #33
3.0 REFERENCED DOCUMENTS
API Publication 2026, Safe Access / Egress Involving Floating Roofs of Storage Tanks in
Petroleum Service
API Standard 2015, Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks
API Recommended Practice 2016, Guidelines and Procedures for Entering and Cleaning
Petroleum Storage Tanks.
NFPA 3256, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning or
Repair.
OEMS Element 9, Operational & Maintenance Controls
PSM Standard, Operating & Safe Work Procedures, CO-S12A
Distribution Standard Operating Procedure, Mechanical Isolation, SOP Cat A-1, SOP #03
Distribution Standard Operating Procedure, Electrical Isolation, SOP Cat A-2, SOP #09
Distribution Standard Operating Procedure, Work Permitting, Cat A-1, SOP #06
Distribution Standard Operating Procedure, Personal Protective Equipment,
Distribution Standard Operating Procedure, Atmospheric Testing, Cat A-2, SOP #01
Distribution Standard Operating Procedure, Confined Space Entry, Cat A-1, SOP #01
This document applies to Suncor Personnel and Contractors who are working within Distribution
Terminals. References in this document to “Suncor Personnel” include directors, officers,
employees, contract workers, consultants and agents of Suncor.
4.0 RESPONSIBILITIES
Terminal Management;
It is the responsibility of Terminal Management, and the Contractor Supervisor
to ensure that safe working conditions are pre-planned, prepared, and maintained during the
entire confined space entry
Responsible for ensuring full implementation and compliance of this standard operating
procedure.
Responsible for providing all lock-out hardware and tags that are required for compliance
with this standard.
Responsible to complete regular audits of confined space activities and document findings in
Suncor reporting tool.
Accessing Floating Roofs on Storage Tanks in ServiceInitial Issue Page 2 of 14

CAT A-2 SOP #33
Responsible to ensure all Terminal Employees who are required to perform the requirements
of this confined space procedure as part of their normal job function are verified for
competency on an annual basis.
developing and explaining the scope of work to be completed, the
equipment number, service, and location;
attending the confined space pre-job meeting;
providing schematic drawings for the vessel internals if required/requested, identifying any
known hazards, and determining the job priorities.
Ensure all documents related to Confined Space Entry are retained for a minimum 1 year
period.
Contractor Supervisor or Job Foreman:

Responsible to ensure full compliance with this procedure.
Ensuring that all workers are adequately trained and qualified, as
per this Standard Operating Procedure;
Ensuring that, prior to entry into a confined space, all personnel assigned to the job are
familiar with the applicable provisions of this Standard Operating Procedure
Ensuring that, when respiratory protective equipment or any other PPE is required, the
workers designated for the confined space entry and the Safety Watch have adequate training
in its use application and any known limitations;
Ensuring that all personnel involved with the entry are made aware of the layout of the
confined space, and any hazards that could be encountered during work in the confined
space;
Confirm that a Safe Work Permit has been issued for Confined Space Entry according to the
Work Permitting Standard Operating Procedure and utilized the Pre Entry documentation for
reference.
Ensure that the preparation and precautions are acceptable, understood and agreed to before
accepting the Safe Work Permit for Confined Space Entry.
Ensuring that the pre-job / pre-entry meetings are held and that the Confined Space Entry
Checklists and Atmospheric Testing Logs are completed and retained until job completion;
Being aware of and following all applicable Suncor Energy and Occupational Health and
Safety Regulations.
Ensuring a copy of the Confined Space Entry checklist and Work Permit are posted or
readily available at the entrance to the Confined Space.
Ensuring all requirements under the Work Permitting Standard Operating Procedure are
complied with.

CAT A-2 SOP #33
Operating Authority;
Ensuring that the confined space has been properly prepared for entry; including the “Danger
Confined Space” are suitable affixed at all entrances to the confined space.
Visit work site with Performing Authority and review requirements of the confined space
entry including the isolation points.
Notify the Performing Authority of any changing conditions or potential impacts to the work
area.
Complying with atmosphere testing procedures and performing gas testing to determine
atmospheric conditions.
Ensuring all valves, MOV’s and drain lines are in the appropriate position to prevent
movement into or out of the tank
Applying first locks and tags on associated equipment.
Ensuring the tank has been in a “static” condition for a minimum of 1 hour
Ensuring the tank is at it’s high fill position
Preparing and issuing the safe work permit.
Being aware of the actual and potential hazards of the confined space.
Being competent in (i.e. adequately qualified, trained, and experienced to perform the work
safely) the proper procedures and precautions required for entry, and the importance of
ensuring that these are followed;
Ensuring that the person(s) accepting the permit understands the actual and potential hazards
involved in the work area;
Suspending the permit if the safe conditions on which the permit was issued cannot be
maintained;
Ensuring that the confined space is evacuated if the permit is suspended;
Ensuring all entrances to the confined space are suitably barricaded and tagged at the end of
each work period.
Familiar with the configuration of the confined space;
Trained in the selection and use of personal protective equipment;
Be outfitted in applicable PPE for known and anticipated hazards and shall have a standby
present.

CAT A-2 SOP #33
Performing Authority;
Responsible to review and accept the Safe Work Permit on behalf of themselves or on behalf
of associated Workers who will be required to complete work under that permit.
Responsible to verify that all sources of energy are isolated.
Visit work site with Operating Authority and review requirements of the confined space
entry including the isolation points.
Complying with atmosphere testing procedures and performing gas testing to determine
atmospheric conditions.
Notify the Operating Authority of any changing conditions or potential impacts to the work
area.
Comply with all aspects of Mechanical Isolation, ie install all the appropriate locks and tags.
Abide by all conditions of the work permit.
Perform task as outlined on the Safe Work Permit in a safe and responsible manner.
Workers entering the confined space;

Abide by all conditions of the Safe Work Permit.
Perform task as outlined on the Safe Work Permit in a safe and responsible manner.
Notify the Operating Authority of any changing conditions or potential impacts to the work
area.
Install all the appropriate locks and tags.
Hold a valid contractor orientation status and comply with all terminal rules and
regulations.
Follow the conditions detailed on the permit;
Attend the pre- entry job meeting, as per Part II of the Confined Space Entry checklist.;
Be informed of the actual and potential hazards to be encountered in the confined space;
Use tools and equipment that are in good condition;
Be competent (i.e. adequately qualified, trained, and experienced to perform the work safely)
and/ or directly supervised by a competent worker;
Be familiar with the configuration of the confined space;
Be trained in the selection, care and use of applicable PPE;
Be instructed on the proper procedures and precautions required for entry and the
importance of ensuring that these are followed.
Immediately comply with all requests of the Safety Watch

CAT A-2 SOP #33
Safety Watch is responsible:

Being familiar with the type of work to be completed, the configuration of the confined
space and their role in the rescue procedure as identified on Part II of the Confined Space
Entry Checklist.
Ensure ALL workers entering the confined space are in compliance with the PPE
requirements.
Raise an alarm in the event of an emergency in the confined space.
To NEVER enter the confined space in an attempt to rescue.
Keep access and egress to and from confined space clear at all times.
Be identified to ALL Workers.
Watch for hazards inside and outside the confined space. Communicate any change in
working conditions to the personnel in the confined space.
Wear all required PPE and a reflective vest identifying him / her as Safety Watch
Verify worker entry into the Confined Space with Part II of Pre Entry Meeting Checklist.
Remain stationed at entry to confined space at all times.
Maintain detailed log of work entry and egress into the confined space.
Keep unauthorized people out of the space.
Arrange for addition atmospheric testing as required by Part II of the Confined Space
Entry Checklist.
Maintain continuous voice or visual contact with workers in the confined space.
Never leave entry until relieved by a qualified individual.
Have a method of communication in the event of an emergency, (radio, air horn).
Barricade and tag entrance to confined space when space is going to be unoccupied and
unattended, ( breaks, lunch ).
Ensure barricades and tags are affixed on alternate entrances to the confined space.
Order authorized entrants out of the space when:
conditions not allowed in the confined space are occurring
observes behavioural effects of hazard exposure
detects an uncontrolled hazard
when an emergency occurs in the terminal
Arrange for additional gas testing at intervals specified on Pre Entry or after space has
been left unoccupied.
Record all gas test results and time on Entry log
Date, sign and return completed entry log to Operating Authority at the end of the
working day.

CAT A-2 SOP #33
5.0 PRECAUTIONARY STATEMENTS
5.1 Specific Hazards
Typical hazards that may be encountered while executing confined space entry may include;
Ergonomic Hazards
Awkward Body Position
Parts of Body in Line of Fire
Work Environment Hazards

Limited access / egress
Exposure to electrical hazards
Exposure to hydrocarbons or other chemicals
Changes in lumination inside the roof area from the outside environment
Danger from tank contents building up on access ladder rungs
Respiratory hazards from bird droppings
Slips or trips
Oxygen Deficiency
Falling Objects
Personal Limitations
Distractions in work area
Confusing instructions
No / lack of training
Fitness for duty
5.2 Training
a) Proper training and demonstrated competency are prerequisites to performing this Standard
Operating Procedure.
Every Worker involved with the entry into the confined space shall be trained
by a person with adequate knowledge, training and experience

CAT A-2 SOP #33
All employees who are required to utilize this procedure must review and
successfully complete competency verification on an annual basis.
Written records of Confined Space Training for each Employee must be kept on file
and available for review.
Training shall include;

the recognition of hazards associated with confined spaces
safe work practices for working in confined spaces and for performing related work.
5.3 Personal Protective Equipment

Personal protective equipment as outlined in Distribution Standard Operating Procedure, Cat A-
1, SOP #10 or as specified in the Safe Work Permit depending on the work to be completed as
per the job scope requirements.
All personnel accessing the roof area for inspection of primary seal inspections must use fresh
air. For tanks in sour service, fresh air must be used for ALL work. All workers required to donn
SCBA or SABA must be certified in such equipment
All entrants onto the floating roofs MUST wear a full body harness, attached to a life line, with
the free end connected to a suitable anchor point
6.0 SUSTAINMENT AND CONTINUAL IMPROVEMENT
This document is classified in Process Safety terms as a Safework Practice Procedure and as
such must comply with the Safework Practice Standard as outlined in Distribution Procedure
Program, Cat A-3, SOP #01.
Nanaimo Terminal Management is to initiate document review process.
To ensure this Standard Operating Procedure documents meets all applicable OEMS / PSM
standards, this document is to be reviewed at a frequency not to exceed 3 years or when
conditions change to warrant a review

CAT A-2 SOP #33
7.0 DEFINITIONS
Acceptable Atmospheric Levels; means that,
(a) the atmospheric does not have a concentration of any explosive or flammable gas or
vapour at above 1% of the LEL
(b) the oxygen content of the atmosphere is at least 19.5 per cent but not more than 23 per
cent by volume, normal atmospheric oxygen levels are 20.9%, and
(c) the exposure to atmospheric contaminants does not exceed any applicable level set out
in a regulations made under the OHSA or it’s regulations
(d) Test results that that are outside these parameters will require specially trained and
certified personnel, and a detailed work plan to be available before entry in permitted
Atmospheric Hazards; means,

(a) the accumulation of flammable, combustible or explosive agents detected at above 1%
of the LEL
(b) an oxygen content in the atmosphere that is less than 19.5 per cent or more than 23
percent by volume, or
(c) the accumulation of atmospheric contaminants, including gases, vapours, fumes, dusts
or mists, that could:
(i) result in acute health effects that pose an immediate threat to life, or
(ii) interfere with a person’s ability to escape unaided from a confined space, or
(iii) exceed any applicable level set out in a regulations made under the OHSA or it’s
Regulations. Reference ACIGH tables for atmospheric contaminant exposure levels to
cover those not listed in the updated 2012 OH&S table.
Confined Space; According to the definition, there are five critical conditions that must be
satisfied for a work space to qualify as a confined space:
1. Be enclosed or partially enclosed

2. Not be designed nor intended for continuous human occupancy
3. Have limited or restricted means for access / egress that may complicate the provision of
first aid, evacuation, rescue or other emergency response.
4. Be large enough and so configured that a worker could enter to perform assigned work.
5. Where the potential for a hazardous atmosphere may exist.
Floating roof tank; Any vertical open-top or covered cylindrical atmospheric vessel that is
equipped with a floating roof.

CAT A-2 SOP #33
In Service Tank; A tank containing an inventory of liquid that is either static or in the process of
receiving / discharging liquid or mixing / circulating it’s contents.
High Roof Position;

External Floating Roof Tank – the position of the floating roof when the top of the
pontoon is within 4 feet of the tank shell.
Internal Floating Roof Tank – The established operating maximum fill level of the
tank.
Low Roof Position; The position of the floating roof when it is 8 feet or less above it’s
minimum design elevation.
Lower Explosive Limit; The lowest concentration of gas or vapour that will burn or explode if
an ignition source is present at ambient temperature.
Terminal Management; highest level of authority on site, may be manager, supervisor or a

delegated responsibility
Cold Work; means work that is not capable of producing a source of ignition.
Hot Work; is generally categorized as any work in which heat is used or generated of such
intensity that it is possible to ignite flammable liquids, vapours, gases or combustibles.
Static Condition; A condition when the tank is not receiving / discharging liquid or mixing /
circulating it’s contents.
Tank Isolation; The condition that exists when all tank valves are isolated as necessary to
preclude the movement of material in or out of the tank, and all electrical devices are de-
energized.

CAT A-2 SOP #33
8.0 PROCEDURAL REQUIREMENTS

1. High Roof Position
Work must be scheduled for a period when the floating roof is in the High Roof Position. Once
the tank has reached the high level, a minimum of 24 – 48 hours must be allowed for dissipation
of vapours before entry onto the roof will be allowed.
2. Management of Change
Entry onto the roof at a lower level other than specified in (1) will only be allowed after a
Management of Change has been completed and approved.
3. Tools
Only non-sparking, air powered or hand tools will be used.
4. Ventilation
Continuous forced-air mechanical ventilation may be required to maintain a safe atmosphere
above the internal floating roof.
5. Fall Potential
The potential for falling through a roof and or floors of pontoons shall be evaluated during the
planning stage of each job. Past inspection records must be consulted to satisfy this concern.
Special precautions must be implemented to prevent falling through the roof any time a tank roof
is suspected to be weak.
6. Tank Isolation;
Tank valves that would allow movement of product in or out of the tank must be chained closed
and tagged. Motorized valves must be de-energized and the hand-wheel chained closed and
tagged. No product movement into or out of the tank during the confined space entry.
7. Piping;
Any piping connected to the shell above the level of the floating roof must be blanked, except
any sample taps and any overflow piping.

CAT A-2 SOP #33
8. Electrical Equipment;
All electrical equipment such as mixers, motorized valves, circulating pumps, must be de-
energized.
9. Atmospheric Testing;
Atmospheric testing of the roof area shall be performed prior to descent onto the floating roof. If
work is to be performed near roof seals or other openings, additional tests must be performed to
identify any potential hazards and assure that the atmosphere in the work area is not in the
flammable range.
Appropriate PPE shall be utilized while evaluating the atmosphere of the work area. The person
conducting the atmospheric test must be protected as if performing work, I.e. SCBA, SABA,
harness, life line, and utilize a back-up person Refer to Distribution SOP, Cat A-2, SOP #1,
Atmospheric Testing.
Continuous atmospheric testing must be worn by the entrants.
No entry is to be allowed if the LEL level is greater than 10%.
10. Tank Level;

Tank level must be held static for a minimum one hour prior to the gas testing.
11. Stand-By Person;

Must be stationed immediately outside the work area to monitor activities on the floating roof.
The Stand-By Person shall be equipped with;

• A radio capable of activating emergency response
• An air horn to alert personnel on the roof
• An approved safety vest for clear identification
12. Rescue Equipment;

Must be staged at the entry point, available and ready for use prior to entry.
13. Electrical Equipment;

All electrical equipment to be used on the floating roof must be rated for use in Class I, Div II
atmospheres.

CAT A-2 SOP #33
14. Adverse Weather;

Adverse weather conditions will affect work being done on tank roofs. If lightning is observed in
the vicinity, all elevated work shall be suspended and all Personnel moved to a safe area at
ground level. Work may resume after 30 minutes or more have elapsed since the last strike.
15. Weight Distribution

Weight distribution should be considered at all times and excessive weight concentrations should
be avoided. Consideration should be given to placement of planks or plywood to improve weight
distribution.
16. Cold Work

Only cold work will be authorized on the roofs of floating roof tanks in hydrocarbon service.
Tasks may include but not limited to;

• Adjustment of roof legs.
• Adjustment of vacuum breaker
• Adjustment / repair of level gauge
• Inspection of floating roof, pontoons, seals and fire protection system
• Unplugging of water drains
• Removing liquid or debris
• Adjustment / repair of anti rotation guides
• UT Thickness of roof and pontoons
• Mechanical repair of roof components

CAT A-2 SOP #33
DATE AUTHOR DESCRIPTION REVISION

November 2012 R. Rattray New document issue. Initial Issue


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SUNCOR ENERGY PRODUCTS

DISTRIBUTION TERMINAL OPERATING MANUAL

STANDARD OPERATING PROCEDURE

3.0 REFERENCED DOCUMENTS

Accessing Floating Roofs on Storage Tanks in ServiceInitial Issue Page 2 of 14

Contractor Supervisor or Job Foreman:

Accessing Floating Roofs on Storage Tanks in ServiceInitial Issue Page 3 of 14

Accessing Floating Roofs on Storage Tanks in ServiceInitial Issue Page 4 of 14

Workers entering the confined space;

Accessing Floating Roofs on Storage Tanks in ServiceInitial Issue Page 5 of 14

Safety Watch is responsible:

Accessing Floating Roofs on Storage Tanks in ServiceInitial Issue Page 6 of 14

5.0 PRECAUTIONARY STATEMENTS

5.1 Specific Hazards

Work Environment Hazards

Accessing Floating Roofs on Storage Tanks in ServiceInitial Issue Page 7 of 14

Training shall include;

5.3 Personal Protective Equipment

6.0 SUSTAINMENT AND CONTINUAL IMPROVEMENT

Nanaimo Terminal Management is to initiate document review process.

Accessing Floating Roofs on Storage Tanks in ServiceInitial Issue Page 8 of 14

Atmospheric Hazards; means,

1. Be enclosed or partially enclosed

Accessing Floating Roofs on Storage Tanks in ServiceInitial Issue Page 9 of 14

High Roof Position;

Terminal Management; highest level of authority on site, may be manager, supervisor or a

Accessing Floating Roofs on Storage Tanks in ServiceInitial Issue Page 10 of 14

8.0 PROCEDURAL REQUIREMENTS

Accessing Floating Roofs on Storage Tanks in ServiceInitial Issue Page 11 of 14

Continuous atmospheric testing must be worn by the entrants.

No entry is to be allowed if the LEL level is greater than 10%.

10. Tank Level;

11. Stand-By Person;

The Stand-By Person shall be equipped with;

12. Rescue Equipment;

13. Electrical Equipment;

Accessing Floating Roofs on Storage Tanks in ServiceInitial Issue Page 12 of 14

14. Adverse Weather;

15. Weight Distribution

16. Cold Work

Tasks may include but not limited to;

Accessing Floating Roofs on Storage Tanks in ServiceInitial Issue Page 13 of 14

DATE AUTHOR DESCRIPTION REVISION

Accessing Floating Roofs on Storage Tanks in ServiceInitial Issue Page 14 of 14

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