A few years back I worked at an oil refinery, we were all (refinery wide training due to an accident that killed 4 and injured 1 maintenance workers) given classes in Confined Space Entry. During the training we were asked to give examples of a confined space, and I said "The waist water treatment ponds". I was told that those ponds were not confined space. Yet they are clearly areas of limited egress, a person could be completely engulfed, contained operating equipment and there was no MSDS for the fluid contained in the space (pond). These ponds received all of the effluent from the refinery sewer system. It included fecal material and plant process runoff from leaks, overflows, wash downs and rain. I tried for several months to argue that it was a confined space and that there should be a written procedure for electrical maintenance of the aerator motors (480V 3phase up to 5hp). Typical maintenance required an electrician to maneuver a dinghy out to the faulty motor by lifting the mooring cables of the other aerators over the boat and then after disconnecting the motor from its cord connection, and lashing the pontoon to his boat, make a return trip this time lifting the mooring cables over the boat and the aerator. (This required him to stand up in the boat and to come into physical contact with the fluid in the pond). At the end of a very lengthy discussion it was decided that the current method was adequate and that it was not a confined space so no formal procedure was necessary. Realizing that the safety culture would not change I decided to change employeers. But to this day I think about the accident and the reluctance of that plant to begin to take action concerning unsafe conditions.
Hi there Ray. Welcome to ECN!. Based on the information you've given us here, I'd agree that this area does constitute a Confined Area of sorts. Mainly based on the limited egress available to anyone in that area. My understanding of a confined area is an area that is unsafe because of a lack of ventilation and/or the presence of Flammable/Hazardous Gases. This also being coupled with the lack of room in which to move around, hence the egress problem. Personally, I don't like the idea of rowing a dinghy over the top of a pond containing human faecel matter either and I hope that you guys were provided with adequate PPE in case of a fall from the dinghy. Glad that you had good sense to walk away from management with an attitude towards to safety like that.
#150143 - 10/04/0401:30 PMRe: Waist Water Treatment Pond Airators
To be fair, it must be said that, by the time it reached the first pond, part of the digestion of the fecal material has already been done by up stream processes. And unless the waste water treatment system overflowed, so it wasn’t exactly raw sewage. However that does not mean that it is free of hazards, and the refinery did not, (because it would have to admit that it was something other than water in that first pond), create an MSDS for the effluent. In addition to fecal material there are various known hazardous petrochemicals of unknown and varying amounts in the effluent mix. It could include Naphtha, Benzene, MTBE, Gas, Gas Oil, and many other substances used or created in the refining process. It isn’t possible to contain every bit of the material from the refining process, and when containment is lost, it either evaporates or it goes into the waist water system. If the lose of containment is larger (a rupture or overflow) than the upstream waste water treatment processes can handle, then the excess goes directly to the pond. That is not a common occurrence but it had happened, and it could happen while someone was on the pond. In written documents to the company and the county I indicated that the electrician performing the task was required to stand up in the boat in order to negotiate the craft under the mooring cables. However none of the individual issues were addressed, rather the company focused on the general question of, "How is this maintenance performed in similar processes in other locations". (And that seems to be how it’s done everywhere) My point here is that often times companies and the well meaning employees in lower level management positions become locked into methods that, even when they are presented with obvious information about the safety of that method, insist that that is the only way to do the task. When I began to discuss this issue with them, most of the maintenance people who were involved, and even those who had done the job years ago and now were promoted or assigned to other departments, were behind the companies position that the job was "dangerous but do-able". It wasn't until I made a point for point comparison to other, "confined space entry", jobs in the plant that any of the hourly maintenance people changed their position. To demonstrate just how firmly entrenched attitudes can be let me explain that the as a result of the four maintenance workers who were killed the county insisted that the company hire a qualified engineering company to do a “safety culture study” of the plant and the company agreed that along with this they would completely shut down the operations for six weeks and provide six weeks of safety training for EVERYONE in the plant. We received training on every Safety Order in the in the plant, fire fighting, CPR, cranes, PPE, Lock Out Tag Out, etc. It was during these training sessions that I first began the discussions about the ponds. During that period the CEO held several meetings where he personally addressed the entire staff at the plant. On one occasion the stated that if that plant could not operate safely he would shut it down for good. Later I was to discover that this statement was interpreted by most of my fellow employees to mean that if the union did not meet the company’s contract proposals he would use safety issues to shut the plant down. The company had shut down another plant that it had recently acquired for six months until the union there agreed to contract changes. And for that same period the investigating engineering company held public meetings with the county to discuss the progress of their work. The meetings were held in the evening so that anyone concerned could attend. Of more than 450 hourly employees in the plant, I was the only one to attend those meetings. On more than one occasion other employees would make comments to the effect that if we (I) kept making waves the plant could be closed and we would all be looking for jobs. I was a maintenance electrician at that plant for 6 years, and I had been evolved in the maintenance and renovation of the plant power distribution systems and the electrical systems of several of the plant refining processes. My last assignment was to the training department where I scheduled and/or presented training events and wrote safe work procedures for the electrical department. It would be highly unlikely that I would ever be required to perform that task, so it was never a matter of my personal safety, rather the safety of others.