MANAGEMENT

OF INERT
CONFINED
SPACE ENTRY

A: Bro
B : Ya
A : Delta P di reactor tu tinggi
B: Ba jadi ?

After shutdown of the plant, upon borescope inspection, the two men found a lot of refractory material
on the inlet distributor of the reactor and upon inspection at the upstream of the reactor which is the
steam superheater, the refractory material were completely gone on the lower dish side.

A: Bro
B: ya
A: Aku mau skimming pyrophoric catalyst dalam reactor tu
B: Bole tu ko buat jak

MANAGEMENT OF INERT CONFINED SPACE ENTRY

A high delta P / pressure drop / differential pressure build up in a reactor usually cause a premature
shutdown of a plant unit. For large petrochemical plant or O&G facilities, this would give cost impact
to them as premature shutdown to clean or skim the reactor catalyst could cost thousands of ringgit
even millions to them. Aside from cost impact, there is also a significant occupational safety and
health impact for the workers that will do the cleaning job inside the reactor especially reactor that
contain pyrophoric material. A reactor / vessel containing pyrophoric material is considered as
hazardous because upon opening the manhole, the catalyst may react with air and become an
ignition source. (When pyrophoric material exposed to air -
- https://www.youtube.com/watch?v=pYOseLxpB-s&spfreload=10)

To prevent the pyrophoric catalyst from reacting with air, a vessel usually will be introduced with an
inert gas, usually nitrogen, to blanket the catalyst (called nitrogen blanketing). The nitrogen blanket
will create a slight positive pressure in the vessel helping to prevent any air ingression that could
cause oxidative degradation or combustion. BUT, this will lead to an inert atmosphere inside the
vessel where the oxygen content are usually less than 5%.

A proper management of the cleaning activity inside the inert confined space must be carried out as
to safeguard the safety and health of the worker that might go inside the vessel to carry out the
cleaning and inspection activity. Some of the key items / concerned issue / main arrangement, but not
limited to the followings, are:

A) ADMINISTRATIVE CONTROL

Administrative control can be carried out through the establishment of a proper written procedure
regarding how the workers perform the work, rescue plan, implementation of PTW, the manning plan,
identification of responsibility of all party during the work and many more

B) TRAINING AND COMPETENCY

Ensure all the workers have been trained regarding confined space, working in inert atmosphere and
safe handling of catalyst. For inert confined space, PERSONALLY, AESP alone is not enough, the
workers must undergo a special inert entry program that conducted by approved training provider.
One that I know is NIOSH. Though this requirement, as far as I’m concerned, is not mentioned in the
confined space industrial code of practice (ICOP) yet it is better to obligate them to undergo the
certification training because there is a gap between those two training. How about the AGT ? if the
AGT cannot do the gas test without entering the vessel (let say that the probe just not long enough),
Does he/she also must have an inert entry certification to do the gas test inside the vessel ?
Personally, from my point of view, still YES !!!!

Aside from the inert entry competency, don’t forget the others such as first aider, ES and etc.

C) RISK ASSESSMENT

This one is the most crucial part. Risk assessment must be made prior conducting the activity. This is
to identify the hazards related to inert confined space, assess the risk and then determine the risk
control method. The principal hazards related to inert confined space is oxygen deficiency (as we are
intentionally drop the oxygen level in order to control fire / combustion hazard) where the oxygen level
typically kept under 5% volume. Other hazards/issue concern are pyrophoric material, physical
hazards such as internal catalyst tray, catalyst engulfment, excessive heat

Just conduct a job hazards analysis, catalyst MSDS review, SWIFT study and any other method that
you deemed suitable before the work.

D) ENERGY ISOLATION

Take the related P&ID, study any potential ingress such as steam, feed water, process gas and
others into the vessel and then apply positive isolation. If necessary, consider electrical isolation for
any related feed pump.

E) LIFE SUPPORT SYSTEM

Not the typical SCBA, but a combination of helmet, umbilical cable, communication console (there will
be a microphone inside the helmet for communication purpose), command console, manifold bottle
rack and escape set. Ensure the life support system is explosion proof

Ensure all oxygen bottle are full.

Workers must be fit tested and all seal system is in good condition

F) INSPECTION

Conduct inspection. Equipment inspection, let say they want to bring lighting inside the reactor, is it
explosion proof and the required voltage comply with the regulation ?? are the tools used are of non
spark ??

Inspect the life support system. Is it in a good working condition ??

G) EMERGENCY

Make a rescue plan, let say the reactor is 20 meter high, how to bring down the collapse worker,
using crane or skylift, if the workers collapse inside, how you want to bring him out, manual pully ?
pneumatic fall block arrestor ???

Do a simulation of emergency condition. Try to specify when to evacuate the inert confined space.
Aside from hearing the emergency alarm or failure of life support system, a personnel shall
immediately be removed from the inert confined space when the following conditions exist

- Oxygen at or above 5% volume

- 10% LEL or greater
- If the temperature increment is 3degC within 15 minutes
- If temperature inside vessel is more than 40 degC (as it could lead to significant heat stress to
worker)
- When the inert gas supply is loss

And many more.

Don’t forget the provision of safety equipment, stretcher, resuscitation equipment, tripod, winch,
lifeline and many more. The emergency arrangement should also include the catalyst spill scenario
outside of the vessel.

H) PERSONAL PROTECTIVE EQUIPMENT

MANDATORY !!!! its not just the entrant, the worker outside the vessel and handling the spent
catalyst must wear appropriate PPE.

I) INERT GAS SUPPLY

The source of inert gas must be verified to ensure that the inert atmosphere will be maintained.
Always maintained the slight positive pressure inside the vessel, if you sucked out the catalyst using
vacuum, and the vacuum does not integrate with a recycling system you might want to add up
nitrogen supply at the vacuum point (which is of course usually from top manhole)

J) TESTING AND MONITORING

When to enter??? is it when the LEL below 10% and oxygen content between 19.5 – 23.5 and so on
??? Nope it has its own range. Usually the reading are less than 10% LEL(same as conventional),
less than 4% O2, then you can go inside the vessel. Noted that, gas testing for inert confined space is
different from the usual one. For the usual one, we have been train to use the catalytic type of gas
detector, and for catalytic type of gas detector, you must have a sufficient level of oxygen to measure
the LEL level. So you might want to consider your gas detector if you want to do gas testing in the
inert confined space. (Maybe can use this
???? http://www.raesystems.com/sites/default/files/content/resources/Application-Note-
231_AreaRAE-Inert-for-Inert-Gas-Confined-Space-Entry_10-09.pdf )

K) ENVIRONMENT

After skimming, there might be an unwanted spent/used catalyst, discuss properly with your
environment officer regarding the management of that catalyst, from deactivation, storage and its
disposal.

Label the catalyst drum !!!!!!

That’s all. Thank you

Reference

1) API 2217A, Guideline for safe work in inert confined space in the petroleum and petrochemical
industry
2) Industry code of practice for safe working in a confined space 2010, DOSH
3) PTS 60.2110 Guideline working in inert space
4) PTS 60.2105 Standard entry into confined space
5) ANSI Z117.1 Safety requirement for confined space
6) NFPA 69, standard on the explosion prevention system, table C-1, Limiting Oxidant concentration
for flammable gases when nitrogen or carbon dioxide are used as diluents