Health, Safety And Environmental Policy

June Origination Date: October 7, 2011 Revision Date: 2012 Release Authorized by: Danny Trahan, Safety Director Manual Rev 4

BENZENE AWARENESS

TABLE OF CONTENTS [Alt + Right/Left = Page Forward/Back]

PURPOSE...... 1 SCOPE...... 2 APPLICATION...... 2 DEFINITIONS...... 2 1.0 GENERAL REQUIREMENTS...... 2 1.1. Exposure Limits...... 2 2.0 METHODS OF REDUCING EXPOSURE...... 2 2.1. Engineering and Work Practices Controls...... 2 2.2. Respiratory Protection...... 2 2.3. Additional Personal Protective Equipment (PPE)...... 3 3.0 EMPLOYEE TRAINING...... 3 4.0 REGULATED AREAS...... 3 5.0 EXPOSURE MONITORING...... 4 5.1. Initial Monitoring...... 4 5.2. Periodic Monitoring...... 4 5.3. Employee Notification...... 5 5.4. Observation of Monitoring...... 5 5.5. Atmospheric Testing...... 5 6.0 MEDICAL SURVEILLANCE...... 5 6.1. Initial and Periodic Medical Evaluations...... 5 6.2. Medical Evaluations as a Result of Emergency Exposures...... 5 6.3. Medical Records...... 5 7.0 EXPOSURE HAZARDS...... 6 7.1. Routes of Entry...... 6 7.2. Effects of Overexposure...... 6 A. Acute...... 6 B. Chronic...... 6 7.3. First Aid Procedures...... 6 7.4. Physical Data...... 6

Copyright © 2012, P2S. All Rights Reserved. P2S Health, Safety & Environmental Page 1 June Origination Date: October 7, 2011 Revision Date: 2012 Release Authorized by: Danny Trahan, Safety Director Manual Rev 4

BENZENE AWARENESS

PURPOSE The purpose of this policy is to minimize occupational exposure to benzene and meet the requirements of the OSHA Benzene Standard 29 CFR 1910.1028.

SCOPE This procedure applies to projects where exposures to benzene can occur. This plan is to be reviewed as part of the annual corporate assessment, any time that monitoring data indicates there is an increase in exposure levels or there is a change in a process.

APPLICATION This procedure will apply to all work places for all project and contract personnel at all project locations.

DEFINITIONS This procedure contains no unique definitions.

1.0 GENERAL REQUIREMENTS

1.1. Exposure Limits

Permissible Exposure Limit (PEL) 1.0 ppm (parts per million) averaged over 8 hours. Short-Term Exposure Limit (STEL) 5.0 ppm averaged over 15 minutes. Action Level (AL) - The exposure level at which various parts of the benzene standard are required to be implemented, for example, medical surveillance and training. The AL is 0.5 ppm averaged over 8 hours.

2.0 METHODS OF REDUCING EXPOSURE

2.1. Engineering and Work Practices Controls

Employer should be aware of Owners contingency plan provisions. Employees must be informed where benzene is used in host facility and aware of additional plant safety rules. Where feasible, benzene exposures should be controlled through engineering controls and work practices. Respirators and protective clothing should be used to control exposures that are intermittent or caused by emergency conditions and while awaiting engineering controls to be implemented.

2.2. Respiratory Protection

Respiratory Protection shall be NIOSH approved and as outlined below; Benzene Concentration Respirator* Cartridge Unknown (i.e., no air Supplied Air Not applicable sampling information and/or

Copyright © 2012, P2S. All Rights Reserved. P2S Health, Safety & Environmental Page 2 June Origination Date: October 7, 2011 Revision Date: 2012 Release Authorized by: Danny Trahan, Safety Director Manual Rev 4

BENZENE AWARENESS

emergency response for a release) Less than 1.0 ppm None required Not applicable Greater than or equal to 1.0 Half-Mask Air Organic vapor (Black) or ppm, but less than 10 ppm Purifying organic vapor / acid gas *Yellow) cartridges Greater than or equal to 10 Full Face Air Organic vapor (Black) or ppm, but less than 50 ppm Purifying or organic vapor / acid gas supplied Air *Yellow) cartridges Equal to or above 50 ppm Supplied Air Not Applicable

2.3. Additional Personal Protective Equipment (PPE)

When liquids containing benzene are present, additional PPE i.e., aprons, chemical suites, gloves, boots, goggles and face protection shall be used to prevent eye contact and limit dermal exposure. PPE must meet the requirements of 29 CFR 1910.133 and provided at no cost to employees.

3.0 EMPLOYEE TRAINING

All employees working in areas with potential benzene exposures must be properly trained. Training will be conducted upon initial employment and repeated annually or any time there is a change in this procedure. Employees must receive additional training if there is a change in or addition of a process or operation that creates the potential for exposure. The project HSE department is responsible for tracking and maintaining employee training records. Training will include the specific hazards of benzene, the contents of the benzene standard medical surveillance program and the appropriate protective measurements to control benzene exposures during normal operations and emergency situations. Area emergency alarms and evacuation routes, the location of emergency eye wash stations and showers and emergency phone numbers are to be included as part of the employees pre-job STA.

4.0 REGULATED AREAS

Potential locations where employees may be exposed to Benzene are:  Petroleum refining sites  Tank Gauging (tanks at producing, pipeline and refining operations  Field maintenance

Toxicity, Color, Odor, Solubility, Flammability and Toxic by-products are characteristics of Benzene. Whenever airborne concentrations of benzene in an area or specific operation exceed or can be reasonably expected to exceed 1.0 ppm the areas and or operations are to be identified and regulated. The project HSE Manager is responsible for contacting the client HSE department to ascertain area(s) or operations that are or have the potential to exceed 1.0 ppm level.

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BENZENE AWARENESS

The project HSE Manager shall identify the areas or operations on a facility plot plan. The plot plan is to be included as part of the New Hire Orientation program, Hazard Communication Program and Benzene Exposure training module. The following are examples of activities that can be reasonably expected to be a Benzene Regulated Area:  Venting, draining, blinding or opening process equipment and piping containing or having contained greater than I0% benzene.  Unplanned releases or spills greater than 5 gallons of liquids which contain 0. I% or more of benzene (i.e., gasoline, crude oil, crude ethyl benzene, mixed xylenes).

To limit access to authorized personnel, the regulated area should be posted with the appropriate warning signs. Warning signs should contain the following warning: DANGER BENZENE CANCER HAZARD FLAMMABLE - NO SMOKING AUTHORIZED PERSONNEL ONLY RESPIRATORY PROTECTION REQUIRED

Once established, an area will remain regulated until monitoring indicates the concentration of benzene in the air is less than 1.0 ppm. Only employees trained in the hazards of benzene are permitted to enter a benzene regulated area. All personnel entering a regulated area will wear all appropriate respiratory protection and protective clothing.

5.0 EXPOSURE MONITORING

Personal exposure monitoring will be coordinated by the Project HSE Department.

5.1. Initial Monitoring

Initial personal monitoring will be performed to determine representative exposures for each job function in which exposures to benzene may exceed the OSHA action limit or short-term exposure limit.

5.2. Periodic Monitoring

For job functions in which initial monitoring indicates benzene exposure above the action level, a periodic monitoring program will be established. Periodic Monitoring will be completed depending on exposure levels. For employees who are or may be exposed to benzene at or above the action level 30 or more days per year -above the PEL 20 or more days-for employees who have been exposed to more than 10 PPM of benzene for 30 or more days in a year.  Periodic monitoring will be conducted semi-annually when engineering controls or work practices do not reduce benzene exposure below the PEL or STEL.  Periodic monitoring will be conducted annually when engineering controls or work practices do not reduce benzene exposures below the action level.

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BENZENE AWARENESS

5.3. Employee Notification

Each employee monitored will be notified in writing of his/her personal monitoring result within 15 days of the receipt of analytical results. In the event of overexposure, the individual will be notified of any corrective action through his/her supervisor.

5.4. Observation of Monitoring

The monitoring process may be observed by all employees whom the monitoring affects.

5.5. Atmospheric Testing

Benzene specific Draeger tube, bag sample and gas chromatograph (GC) analysis shall be used to conduct atmospheric testing. Atmospheric testing will be conducted for confined spaces that have contained benzene or other areas that have been identified as benzene regulated area.

6.0 MEDICAL SURVEILLANCE

6.1. Initial and Periodic Medical Evaluations

Employees working in areas who have potential exposure to benzene shall receive pre-employment and periodic medical evaluations. If initial or periodic medical evaluations indicate an abnormal condition, further evaluations will be given and referrals made as determined by the project physician. Medical evaluations will be done periodically for individuals that have been identified as having benzene exposures above 10 ppm for 30 or more days per year. Health effects of Benzene include eye and skin irritations and short term breathless, Irritability, Euphoric, etc.

6.2. Medical Evaluations as a Result of Emergency Exposures

In the event of exposure, without the use of proper respiratory protection, to an unforeseen release of benzene- containing vapor or liquid, the employee shall provide a urine specimen to the Project HSE Department. The specimen must be collected no sooner than 6 hours and no later than 8 hours following the exposure. If the urine specimen indicates an abnormal condition further evaluation will be performed and referrals made as determined by the project physician.

6.3. Medical Records

Medical records associated with benzene medical surveillance will be maintained by the Project HSE Department. An employee’s medical records shall be made available to the Assistant Secretary, the Director, affected employees and designated employee representatives.

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BENZENE AWARENESS

7.0 EXPOSURE HAZARDS

Benzene is listed as a carcinogen; therefore any exposure to benzene should be avoided. Benzene liquid is highly flammable and vapors may form explosive mixtures in air. Fire extinguishers must be readily available. Smoking is prohibited in areas where benzene is used or stored.

7.1. Routes of Entry

Inhalation is the primary route of entry into the body. Exposures may occur during accidental spills and release or in/near confined spaces. These exposures typically can be experienced in operations such as sampling, liquid draining and equipment maintenance. Skin Contact presents a possible route of absorption, but generally at a much lower rate than through the respiratory system. Benzene is poorly absorbed through the skin, but can find its way into the blood stream through cuts, cores, etc. Benzene is a solvent and an irritant to the skin. The primary effect of skin contact is defatting, resulting in dermatitis. Ingestion of benzene is a remote form of exposure and is mainly due to poor personal hygiene practices such as failure to wash hands before eating, chewing, dipping or smoking.

7.2. Effects of Overexposure

A. Acute

Overexposure to high concentrations of benzene may result in feelings of breathlessness, irritability, euphoria, or light headiness. Irritation of the eyes, nose and respiratory tract may be experienced. Headaches, dizziness, nausea, or intoxication may develop. Severe exposure may lead to convulsions and loss of consciousness. B. Chronic

Repeated or prolonged exposure to benzene, without the use of personal protective equipment, may result in various blood disorders. Anemia and leukemia, a fatal cancer of the blood, are examples of adverse effects that may result from exposure to benzene.

7.3. First Aid Procedures

Remove exposed employee to an uncontaminated atmosphere. Wash exposed skin with soapy water. Remove benzene wetted clothing immediately. If benzene is ingested, do not induce vomiting. Seek medical attention.

7.4. Physical Data

Color Clear and colorless Odor Characteristic pleasant acrid odor at low concentrations; disagreeable at higher concentrations. Odor Threshold Greater than 4.6 PPM Explosive Limits 1.4 - 8% Boiling point 176 F Specific Gravity 0.879 Floats on water Vapor Density 2.8 Heavier than air