Experiential Development of Good

Practice for Confined SpaceEntries

Confined space entry is not simply limited to the entry of specific plant vessels. Artificially created
situations can also lead to environments which are effectively confined spaces. The development is
addressed of procedures for ensuring safe working practices in any of these situations. Many aspects
are discussed of confined space entry by examining case studies and regulatory requirements, which
were used over the years to develop an approach to this potentially hazardous area of ammonia plant
operation.

Colin P. Lynas
ICI Synetix, Billingham, Cleveland, TS23 1LB, U.K.

Introduction experiences in the field of confined space entries.

It is my experience from meeting many ammonia

M
ost aspects of life benefit substantially
from experience, and nowhere is that more
true than when we consider our daily lives
at work. This is not to say that it is the be all and end
all of being able to do your job. However, those of us
who have been around a little bit longer than others will
undoubtedly have seen and done things which will
have had a significant impact upon the way hi which
we currently lead our working lives.
Among the people who pick up this article and look
through it quickly or read it thoroughly, there are no
doubt many thousands of years of experience of life in
general, and, one would imagine, the operation of
ammonia plants hi particular.
It is with this in mind that this article is hopefully
written in such a way as to add a little to that vast sea
of knowledge by sharing a small portion of others
plant people across the world that we are a practical
group of people and learn a tremendous amount from
simply talking to each other and openly discussing
events and incidents hi which we were involved or of
which we have intimate knowledge. Hopefully, you
will find this article true to that feeling hi its style and
content.
In my current job as a Technical Sales Manager with
Synetix in the U.K., it may not be immediately obvious
how or why I should be writing an article on confined
space entries. I do have some background in the chem-
ical industry (around 33 years) and, of that, the last 23
years or so have been directly involved with ammonia
production or a related field. In Synetix we have an
interesting mixture of backgrounds among the people
that we send out to plants around the world, and some-
times these people, in the course of their normal work,

AMMONIA TECHNICAL MANUAL 34 2002

have to enter vessels or confined spaces. Being
involved to some extent in the guidance and training
that we give to people with limited experience of ves-
sel entries began to make me appreciate just how much
of that guidance (some of it now law) was developed
from the experiences within ICI over the many operat-
ing years in its history.
With this in mind, and having had several occasions
in my life when I was involved in incidents from which
profound learning was gained, I was moved to share a
few of those incidents in this article. For those readers
who have experienced the same or similar incidents, it
is then hoped that it serves as a refresher which sharp-
ens the memory. For those who have not been involved
in anything like these incidents, it is sincerely hoped
that this article helps to stop you from being so!
What is a Confined Space?
In the U.K.'s Health and Safety Executives Confined
Space Regulations a confined space is defined as fol-
lows:
"Any place, including any chamber, tank, vat, silo,
pit, trench, pipe, sewer, flue, well or other similar space
in which, by virtue of its enclosed nature, there arises a
reasonably foreseeable specific risk".
Some confined spaces are fairly easy to identify, such
as enclosures with limited openings:
• storage tanks
• silos
• reaction vessels
• enclosed drains
• sewers
Others may be less obvious, but can be equally dan-
gerous, for example:
• open-topped chambers
• vats
• combustion chambers in furnaces, and so on
• ductwork
• unventilated or poorly ventilated rooms.
On average, work in confined spaces kills 15 people
every year in the U.K. across a wide range of indus-
tries, from those involving complex plant through to
simple storage vessels. In addition, a number of people
are seriously injured. Those killed include not only
people working in the confined space, but those who
AMMONIA TECHNICAL MANUAL
try to rescue them without proper training and equip-
ment.
One confined space which you may say is less obvi-
ous came to our attention on the ammonia plants at ICI
in the mid 1980s. We were heavily committed to iden-
tifying and removing asbestos from the plants, and we
had a major program underway to make the plants
totally free of asbestos. When an area of asbestos, say,
lagging on a pipeline, was identified, it was "sealed" in
polythene and when it was convenient stripped out by
registered contractors.
When the stripping was carried out, and this was
often with the plant online, the contractors would usu-
ally erect a "tent" around the area to be stripped. As the
contractors were always reputable and registered with
the appropriate authorities, the plant personnel were
only ever involved in issuing permits to work for the
safe erection of the tent. What happened inside the tent
was left up to "the experts" who supplied all the neces-
sary equipment for stripping out the asbestos without
harm to themselves or anyone else on the plant.
On one of these occasions we were looking around a
tent constructed above the de-aerator on one of our
plants before the work started. To our surprise, as we
looked at the outside of the tent, we could see the tail
pipe of a gas vent line disappearing through the floor of
the tent. When we looked inside the tent, we could see
the open end of the vent protruding into the working
area within the tent.
We had clearly created a confined space complete
with its own built-in hazard! It is not certain whether
across the company we treated asbestos stripping tents
as confined spaces before that incident, but we certain-
ly did after it. The outcome of the incident enquiry that
followed was clear in that from then on that we treated
an asbestos stripping tent as a confined space entry,
complete with air tests, and complete risk assessment
for the advent of a dangerous atmosphere. The asbestos
stripping activity then almost became a secondary con-
sideration.
I came across another situation when a confined
space was not identified when I visited another organi-
zation who had no direct links with the chemical nidus-
try. The organization was operated by a part of the
British aerospace industry, and for that reason detail
will be kept to a minimum. One of the facilities shown
35 2002
to us was a testing station for aircraft engines. We were
shown into an unventilated cubicle about 3 m square
where there was a panel with over 500, 6 mm diameter
tube connections which were pressure points from var-
ious parts of the engine being tested. As we looked
around, we saw a supply line from which another line
was connected to the pressure tappings. We were told
that because of the risk of aviation fuel coming back
into the cubicle, they were purged with nitrogen. The
people operating the facility had not realized that they
had created a confined space and that they were intro-
ducing over 500 sources of nitrogen into that confined
space. They informed us later that, due to our com-
ments and information we subsequently sent them
about the hazards of nitrogen, they had completely
changed their procedures around entry into the cubicle
and it now has a continuous oxygen analysis system
installed.
Residues...
Anyone who has ever been involved in confined
space entries will be aware of the hazards of residues
left in vessels, and the need to clean these out before
any entry is made. However, we had an experience of
when we felt we had done everything necessary to
clean out an apparently fairly clean vessel and we still
had an incident.
The vessel concerned was a CO2 condenser, on a liq-
uid CO2 plant in which liquid ammonia on the shell
side is used to condense high pressure CÛ2 gas. The
vessel was due for statutory testing after 10 years of
continuous operation. After looking at every way of
carrying out the inspection without a vessel entry, we
could not find a way of avoiding it and we planned with
an entry in mind.
The condenser was completely disconnected from
the plant and indeed was lifted down from its position
approximately 30 m up on a structure and positioned
on the roadway next to the plant. The condenser coil
was withdrawn from one end of the vessel and a large
manway was removed from the opposite end, leaving
an empty cylindrical vessel approximately 10 m long
with a perfect path for air to flow through the openings
at each end.
AMMONIA TECHNICAL MANUAL
Having been on ammonia duty, the vessel was thor-
oughly washed with cold water from the outside using
fire water hoses and the water drained from the vessels
drains on to the roadway. Visual inspection of the
inside of the vessel showed no obvious signs of any
residue and an air test was carried out. The air test
showed a perfectly safe and breathable atmosphere in
the vessel and the ammonia concentration in the atmos-
phere was quoted by the laboratory staff as less than 5
ppm.
As the vessel was to be given a thorough metallurgi-
cal test, the vessel walls had to be perfectly clean and
the first task was to put 2 people into the vessel to carry
out that cleaning. The entry permit was completed and
was signed and the cleaners entered the vessel. Within
approximately 5 min., the two men rushed out of the
vessel complaining of being affected by a very strong
smell of ammonia. A very quick test was carried out
and the ammonia concentration in the air hi the vessel
was found to be over 100 ppm.
When a close inspection was made of the inside of
the vessel, it was found that there was a very thin film
of oil / wax adhering to the walls of the vessel. This oil
had obviously been laid down over the years of opera-
tion as the ammonia used for condensation had been
boiled off. Within this oil was trapped ammonia which
was released into the atmosphere inside the vessel
when the film was disturbed by the cleaning process.
Naturally, there was an investigation into the incident
and everyone involved in the job admitted that they had
not seen the oil film as a major hazard as it was barely
discernible on the walls of the vessel. Resulting from
the investigation, it was decided that procedures would
be changed for vessels in which such a situation could
arise, and that such vessels should be cleaned from the
outside with either steam or hot water to remove any
such oil films. This, of course, leads to another prob-
lem, that of disposing of the oil contaminated washings
- but that is another story!
When is a Safe Atmosphere Not a Safe
Atmosphere?
The answer to this question is fairly straightforward
of course — when you introduce into that safe atmos-
36 2002
phere a material that could present a risk. I am sure all
of the people reading this article will have come across
just such situations. An example is the cleaner who
takes into the vessel a volatile solvent to clean off those
stubborn areas, for instance, or, of course, the most
common: the metallurgist who needs to take a solvent
into the vessel to carry out dye penetration tests for
crack detection.
I am sure that we all have procedures and safeguards
to take account of these situations, but sometimes there
are situations which take us by surprise.
On one such occasion, a storage tank was being pre-
pared for inspection. It was felt that since the tank had
been used to store liquid CO2, and as the vessel was
very long with only one manway on the top and an 8 in.
exit on the bottom, ventilation may be a problem. In
this case it was decided to use air driven "ejector" type
air movers to provide a flow of air through the vessel.
A mobile air compressor provided the air for the air
movers, and the movers were positioned to give a flow
of air into the top of the vessel and out of the bottom.
The air movers were left in position overnight, and, the
following morning, the air test was carried out by the
laboratory staff.
The air test proved acceptable, the permit was issued
to carry out the work in the vessel, and the air movers
were left in commission.
When the maintenance team approached the vessel,
they could see a light fume coming from the bottom
exit of the vessel. When they looked more closely, they
found the vessel to be filled with a light haze and there
was a strong smell of oil.
It transpired that the air compressor used had devel-
oped a problem and oil from the compressor had been
entrained in the air flow which had in turn been blown
into the storage tank.
From this incident, we once again altered our proce-
dures to prescribe oil free air compressors when any air
driven device was to be used during a confined space
entry. This not only meant when air movers were to be
used, but also other air driven equipment, for example,
air driven tools which are very commonly used for
work in vessels, such as grinders for taking out defects
discovered during inspections. The air from these tools
of course is exhausted into the atmosphere in the ves-
sel and therefore should be considered a source of haz-
AMMONIA TECHNICAL MANUAL
ard.
One other occasion in which a hazardous material
can enter a previously safe atmosphere in a confined
space is in the case of a hazardous material entering the
space from a leak in the area local to the confined
space. In most cases of course we would either know of
such a leak and take precautions to stop the ingress of
hazardous material or indeed repair the leak before the
entry takes place. However, one situation which
became apparent to us as a potential problem which
was unforeseen was in the case of a release of toxic
material leading to a toxic emergency generally on the
site.
Obviously, in the situation of a toxic emergency any
work in the vessel would stop and the people involved
would retire to their toxic refuge. However, when the
emergency is over, is the atmosphere in the confined
space still safe? In most cases the chance of the entry
being affected by the material released is minimal.
However, it was felt that the risk was real and the pro-
cedure now is that, after a toxic emergency, whether the
local plant is affected or not, the entry permit is can-
celled and "NO ENTRY" signs are erected at all
entrances to the confined space. A new air test and
entry permit must then be issued before work in the
confined space may continue.
While considering when a safe atmosphere changes
to an unsafe one, there is of course always the chance
that the safety of a particular situation may change
while there are people working in the confined space.
In cases where it was feasible, we moved in the mid-
1990s toward at least one person in the vessel wearing
a personal oxygen monitor. These monitors would
sound an alarm when the oxygen concentration fell
below around 19.5%. One location where we would
insist on oxygen monitors was when working in a
nitrogen compressor house on an argon recovery plant.
While strictly speaking this was not a confined space
entry, the building was significantly soundproof and, to
all intents and purposes, fairly well sealed. Anyone
working in the building had to carry an oxygen moni-
tor and could not work alone.
One other interesting aspect of that particular build-
ing arose during the HAZOP studies when the plant
was designed. The building was fitted with oxygen
detectors which, as well as being connected to an alarm
37 2002
system, were connected to warning lights on each entry
to the building. The point that came out during our
HAZOP discussions was that the warning lights should
be extinguished in case of a low oxygen measurement
and not illuminated. This was in case failure of the
bulbs in the lights led to the possibility of someone
entering under alarm conditions; also the lights were
made green to show safe entry was possible.
Training and Validation
Naturally, good training is key to having competent
people in positions where they will have to manage
confined space entries, and the training will very much
depend on the type of entries that each individual will
be involved with. However, the philosophy we have
tended to use over the years has been very much based
on working practical real life situations which have
occurred either within our company or from our shared
experience with others.
It is my belief that training in confined space entries
and how to manage them is probably the most impor-
tant training that a plant manager on any chemical plant
will ever undertake in his career. The training should be
thorough and detailed and should cover as many exam-
ples from the safety literature available as possible. The
validation of potential signatories of entry permits
AMMONIA TECHNICAL MANUAL
should be rigorous and if possible carried out by inde-
pendent assessors.
For those who read this who as part of their daily
duties have to put their signatures on entry permits, I
would say check, check, and check again. However
well you know someone or however much you trust
them — do not take the word of anyone else as to the
integrity of a confined space. Use your own judgment
— you are responsible for the safety and possibly the
lives of the people entering that space.
Being a little bit scared when you approach the entry
permit to sign it is not a bad thing; it may just make you
check again!
A Final Thought...
One last situation which I will leave the reader to
ponder upon:
Mentioned in an earlier section was the consideration
of asbestos stripping tents as a confined space entry. In
the mid-1980s, in the middle of a major overhaul, a sit-
uation arose where we had to erect an asbestos strip-
ping tent within the radiant box of the primary reformer
on one of our ammonia plants. The primary reformer
radiant box was already the subject of a confined space
entry permit!
38 2002