esh logo                                                          

 


 

                                                                                                                                Reviewed and Approved By:

                                                                                                                               

                                                                                                                                ______________________________

                                                                                                                                     PSFC Supervisor     

 

                                                                                                                                _______________________________                                                                                                                                                                                                    PSFC Supervisor

 

                                                                                                                                _______________________________

                                                                                                                                Catherine L. Fiore, PSFC Safety Officer

 

Title:         Procedure for Issuance of Confined Space Permits

 

Procedure #:     PSFC-CS-93004

 

Filename:  conf_permit_pro.doc

 

 

Author:    C. L. Fiore

 

 

Version:   2.0

 

 

Date:      Original:  5/12/93, Revised 7/16/2008

 

 

System:      Confined Space Permits

 

 

Persons Responsible:   C. Fiore, R. Granetz, D. Garnier, R. Vieira

 

 

Other Personnel:    See attached list of approved personnel

 

       

 

                              

 

 

Introduction:

 

 

This document will detail the procedure to be followed in issuing confined space permits at the Plasma Science and Fusion Center.

 

Several areas have been identified as confined spaces at the Plasma Science and Fusion Center.

 

These include: the Alcator C-Mod vacuum vessel, the inside of the top cover of the Alcator C-Mod igloo, the alternator and lube oil tanks, the LDX vacuum vessel, and the VTF vacuum vessel.  These areas may require permits for confined space entry under certain conditions:

Alcator C-Mod vacuum vessel during welding operations (introduction of an electrical hazard) or after activation of internal elements (radiation hazard); or at any time during which solvents are to be used in any of the spaces. The alternator spaces require permits for any entry.

 

These areas will be posted as permit-required spaces when a permit is needed for entry.

 

  

 

 

Scope:

 

This document is designed to help provide for safe access to confined spaces at the PSFC in accordance with 29CFR 1910.146[1].

 

 

Safety Analysis:

 

Air quality is a primary concern for working inside the confined spaces at the PSFC.  The air must be monitored for oxygen content and for the buildup of combustible and hazardous fumes.  If hazardous materials have been introduced into an area the air should be tested for content of these.

 

The Alcator C-Mod vacuum vessel could contain background radiation levels or radioactive contamination sufficient to require limitation of stay time, protective clothing, or respiratory protection for entrants.

 

There is potential for electrical shock from the welding operations as well as exposure to ultraviolet radiation.  In addition,  welding could cause spattering from the welding arc and a buildup of welding related fumes (CO, metal  oxides, ozone.)  Operations using a stud welding gun are very loud during the discharge.

 

Injury could occur from bumping into structures and studs installed inside the  experiment.

 

 

Definitions:

 

 

 

Confined Space means a space that (1) is large enough and so configured that an employee can bodily enter and perform assigned work; and (2) has limited or restricted means for entry or exit, and (3) is not designed for continuous employee occupation.

 

Entry means the action by which a person passes through an opening into a permit-required space.  Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant's body breaks the plane of an opening into the space.

  

Entry permit means the written or printed document that is provided by the employer to allow and control entry into a permit space and that contains the information specified in this document.

 

Hazardous atmosphere means and atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue, injury, or acute illness from one or more of the following causes: (1) Flammable gas, vapor, or mist in excess of 10% of its lower flammable limit (LFL); (2) Airborne combustible dust at a concentration that meets or exceeds its LFL; (3) Atmospheric oxygen concentration below 19.5 % or above 23.5%; (4) Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in Subpart G, Occupational Health and Environmental Control, or in Subpart Z, Toxic and Hazardous Substances, of this part and which could result in employee exposure in excess of its dose or permissible exposure limit; (5) Any other atmospheric condition that is immediately dangerous to life or health.

 

Hot Work Permit means the employer's written authorization to perform operations (for example, riveting, welding, cutting, burning, and heating) capable of providing a source of ignition.

 

Oxygen deficient atmosphere means an atmosphere containing less than 19.5% oxygen by volume.

 

Oxygen enriched atmosphere means an atmosphere containing more than 23.5% oxygen by volume.

 

Permit-required confined space (permit space) means a confined space which contains one or more of the following characteristics: (1) Contains, or has a potential to contain a hazardous atmosphere;  (2) Contains a material that has the potential for engulfing an entrant; (3) Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or (4) Contains any other recognized serious safety or health hazard.''

 

 

Responsibilities:

 

The Entry Supervisor, in addition to the responsibilities ascribed to confined space entrants, is responsible for overseeing the permit entry process.  This includes:

 

     (1) Preparation and verification of permits.  This includes verification that all prescribed tests and procedures have been performed, that all required equipment is available, and that rescue services and a means to summon them are available.

 

     (2) Monitoring of the entry to see that conditions and procedures are consistent with the permit.

 

     (3) Removal of unauthorized persons from the area.

 

     (4) Termination or cancellation of an entry permit as required.

 

The Confined Space Entrant is responsible for:

 

     (1) Understanding the hazards associated with the confined space entry from all sources which pertain:  chemical (from MSDS), reduced oxygen, electrical, radiation, engulfment, mechanical, etc.

 

     (2) Proper use of all required equipment.

 

     (3) Communication with attendant.

 

     (4) Recognition of requirements for self-rescue, and proceeding with self-rescue when necessary.

 

     (5) Obeying orders from attendant and the entry supervisor.

 

     (6) Complying with all applicable safety procedures established for his/her project, and with the procedures established by the MIT Safety Program and by the MIT Plasma Science and Fusion Center Safety Committee.

 

The Confined Space Attendant is responsible for monitoring and protecting confined space entrants.  This includes

 

     (1) Understanding the hazards associated with the confined space entry from all sources which pertain:  chemical (from MSDS), reduced oxygen, electrical, radiation, engulfment, mechanical, etc.

 

 

     (2) Proper use of all required equipment.

 

     (3) Communication with entrant.

 

     (4) Recognition of requirements for self-rescue, and ordering the entrant to proceed with self-rescue when necessary.

 

     (5) Ordering evacuation if an uncontrolled hazard is detected, if the entrant exhibits behavioral effects of hazardous material exposure, if predetermined entry times are exceeded, if a situation develops outside the space which could endanger entrants, or the attendant can no longer perform his/her duties.

 

     (6) Summoning rescue personnel as required.

 

     (7) Following instructions of the entry supervisor.

 

 

Assumptions:

 

A written and approved procedure for entry into the specific confined space is on hand and all entrants, supervisors, and attendants are familiar with it.

 

Entrants, supervisors, and attendants have received general confined space training as well as training for the job at hand.  Those who will perform work requiring other training, such as respirator use, welding, or radioactive materials handling have received this training as well.

 

Any other required permits, such as radiation work authorizations or welding permits have been obtained.

 

No person will be required to remain inside the vessel longer than he or she feels comfortable.  

 

 

Required Equipment:

 

The procedure for the entry should specify all required equipment.

 

 Procedure:                                                                                                    

 

 

     1. The entry supervisor shall check the entry procedure and make sure that all of the required equipment has been assembled.

 

     2. The entry supervisor shall make sure that any ventilation equipment has been installed and is operating satisfactorily.

 

     3. The entry supervisor shall check that all required measurements of atmosphere have been performed and that levels are in a satisfactory range.

 

     4. The entry supervisor shall satisfy him/herself that the attendants and entrants understand their responsibilities and the procedure to be followed.

 

     5. The entry supervisor shall fill out the permit (blanks should be obtained from the ES&H office) and post it at the entry site.

 

     6. At completion of the entry the entry supervisor shall return the permit to the ES&H office.

 

Training:

 

Those authorized to issue confined space entry permits (see below) shall be familiar with this procedure and the requirements for all participants in a confined space entry.  Training on this procedure will be given as part of the PSFC confined space training.

 

References:                                                                              

 

 

[1]Federal Register,     Vol. 58, No. 9, 1910.146, “Permit Required Confined Spaces for General Industry; Final Rule”, 29CFRParts 1910, Federal Register, Vol. 58, No. 9, (January 14, 1993), p. 4463

 

[2]Confined Space Program for the Plasma science and fusion Center, C. L. Fiore, 3/24/93

 

 Persons authorized as entry supervisors:

 

 

Alcator:

 

Gary Dekow

 

Robert Granetz

 

Ian Hutchinson

 

Brian Labombard

 

Bruce Lipschultz

 

Sam Pierson

 

Rui Vieira

 

Steve Wukitch

       

Alternator:

 

Mike Rowell

        

LDX:

 

Darren Garnier

       

VTF:

 

Jan Egedal